Page 1 of 49 UNITED STA

TES ENVIRONMENTA L PROTECTION A GENCY WASHINGTON, D.C. 20460 OFFICE OF CHEMICAL SAFETY AND POLLUTION PREVENTION MEMORANDUM Date: 6/30/10 SUBJECT: Mefenoxam . Petition for Tolerances in Support of New Use s on Snap Bean s and

the Caneberry

Subgroup, Expanded Use s on the Bulb and Green Onion Su b groups and the Bushberry

Subgroup, and Amended Use on Spinach. Summary of Analy tical Chemistry

and Residue Data. PC Code: 113502 DP Barcode: D 371307 Decision No.: 416985 Registration No s . : 100 - 801, 100 - 804, 100 - 1202 Petition No.: 9E7591 Regulatory Action s : Section 3 Registration/ Amended Section 3 Registration Risk Assessment Type: NA Case No.: NA T XR No.: NA CAS No.: 70630 - 17 - 0 MRID No.: See MRI D Summary Table 40 CFR: 180.546 (Mefenoxam) FROM: Nancy

Dodd, Chemist Risk Assessment Branch I II Health Effects Division (7509P) THROUGH: Leung Cheng, Senior Chemist

Risk Assessment Branch I II Health Effects Division (7509P) TO: Barbara Madden, RM#5

Registration Division (7505P) MRID Sum ma ry Table MRID No. Study Type Com me nts 47803101 860.1500 Snap Bean New DER; 47803101.der.doc 47803102 478 03103 860.1500 Caneberry New DER; 47803103.der.doc 47803104 47803105 860.1500 Spinach New DER; 47803105 .der.doc This document was originally prepared under contract by Dy namac Corporation ( 1901 Research Boulevard, Suite 220 ; Roc kville, MD 20850 ). The document has been reviewed by the Health Effects Division (HED) and revised to reflect current Office of Pesticide Programs (OPP) policies.Mefenoxam Summary of Analytic al Chemistry and Residue Data DP#: 371307

Page 2 of 49 Executive Summary Mefenoxam [ methyl N

- (2,6 - dimethylphenyl) - N

- ( m ethox ya cetyl) -D - alanin at e ] belongs to the phenylamine class of sy stemic fungicides (Group 4). Phenylamides are effective against soil borne diseases caused by Pythium and Phytophthora and foliar diseases caused by Phycomycetes (downy mildews) on a wide variety of crops. Mefenoxam is the enriched R - enantiomer of the fungicide metalaxyl, which is a racemic mixture of R - and S

- enantiomers (also referred to as the D - and L - enantiomers, respectively ) . Metalaxyl is a L ist A chemical; the Residue Chemistry Chapter for the Metalaxyl Reregistration Eligibility Decision (RED) Document was issued on 6/16/94. Mefenoxam has replaced metalaxyl in Sy ngenta Crop Protection, Inc. products . B ecause it is the most fungicidally active component of the mixture, it may

be used at half the application rates of metalaxyl. HED has concluded ( DP# 223261, 4/2 4 /96, L . Kutney ) that the established tolerances for metalaxy l will be adequate to support the use of mefenoxam on the same crops provided that ( 1 ) the use rates for mefenoxam are one - half the rate of metalaxyl; ( 2 ) mefenoxam applications are made in the same way as for metalaxyl; and ( 3 ) the labels restrict the use of both pesticides concurrently on the same crop. The In terregional Research Project No. 4 (IR - 4) has submitted a request for amended registration for three Sy

ngenta products: a 4 lb ai /gal emulsifiable concentrate (EC) formulation, Ridomil Gold® EC (EPA Reg. No. 100 - 801); a 4 lb ai /gal liquid soluble concentrate (SL ) formulation, Ridomil Gold ® SL(EPA Reg. No. 100 - 1202); and a 5% wettable powder (WP) formulation, Ridomil Gold®/Copper (EPA Reg. No. 100 - 804). The 5% WP formulation is a multiple active ingredient ( MAI ) product containing 5% mefenoxam and 60% copper hydroxide. For the 4 lb ai /ga l EC and SLformulations, the petitioner is proposing to: (1) expand the registered use on onions to include additional crop s that are now included in the bulb vegetable crop group 3 - 07 ; (2) reduce the preharvest interval (PHI ) for spinach from 21 to 3 days ; (3) expand the registered foliar use of the 4 lb ai /gal EC and SLformulations on head and leaf lettuce to cover all members of the leafy

vegetables group ; (4) add new uses on the caneberry subgroup 13 - 07A ; and (5) expand the registered use on blueberr ies to cover the bushberry subgroup 13 - 07B . HED note s that mefenoxam is currently registered for use on legume vegetables and raspberries; however, the proposed uses reflect less restrictive use patterns than those currently registered . For the 5% WP for mulation, the petitioner is proposing to: (1) expand the registered use on onions to include additional crop s that are now included in the bulb vegetable crop group 3 - 07 and snap beans; (2) reduce the PHIfor spinach from 21 to 3 day s ; (3) add new uses on snap bean s ; and ( 4 ) add new uses on the caneberry subgroup . The use patterns addressed herein reflect a combination of proposed and registered use directions for all crops except snap beans and caneberries. The 4 lb ai /gal EC and SL formulations are p roposed /registered for preplant incorporated and/or at - planting soil applications to onions , leafy vegetables , caneberries, and bushberries at 0.25 - 1.8 lb ai/A/application, for postemergence and/or post - planting soil applications to caneberries and bushber ries at 1.8 lb ai/A/application, and for postemergence foliar application to leafy vegetables /spinach at 0.125 lb ai/A/application. The 5% WP formulation is proposed /registered for one to four postemergence foliar applications to onions , spinach, snap beans, and caneberries at 0.1 - 0.125 lb ai/A/application, with applications generally to be made following soil application of the EC or SLformulation. The proposed /registered maximum seasonal rates for combined soil and foliar applications are 1.3 lbMefenoxam Summary of Analytic al Chemistry and Residue Data DP#: 371307

Page 3 of 49 ai/A f or green bulb vegetables, 1.4 lb ai/A for spinach and snap beans, 1.5 lb ai/A for onions, , and 3.6 lb ai/A for caneberries and bushberries; and the proposed/registered PHI s are 10 and 7 day s for dry

bulb and green onions, respectively , 7 day s for le afy v e getables (except spinach), 3 day s for spinach, 6 day s for snap beans, 45 day s (soil application ) and 0 day s (foliar application ) for caneberries, and 0 day s for blueberries. Insupport of the proposed /registered uses , I R - 4 is proposing under PP#9E7591 the establishment of permanent tolerances for residues of the fungicide mefenoxam, ( R ) and ( S ) - 2 - [2,6 - dimethyl(phenyl) - methoxy acetylamine] - propionic acid methyl ester, and its metabolites containing the 2,6 - dimethylaniline moiety , and N - (2 - hy droxy

methyl - 6 - methylphenyl) - N - (methoxy acetyl) - alanine methyl ester , in/on the following raw agricultural commodities: Bean, snap, succulent ................................ ................................ ..... 0.35 pp m Caneberry , subgroup 13 - 07A ................................ ......................... 0.80 pp m Bushberry

subgro up 13 - 07B ................................ ............................ 2.0 ppm Onion, bulb, subgroup 3 - 07A ................................ .......................... 3.0 ppm Onion, green, subgroup 3 - 07B ................................ ....................... 10.0 ppm Spinach ................................ ................................ ............................. 8.0 ppm IR - 4 has also proposed that the established tolerance for lingonberry be removed when the tolerance for the bushberry subgroup is established. T olerances for mefenoxam are established under 40 CFR §180.546 and are expressed in terms of combined residues of (

R ) - and ( S

) - 2 - [2,6 - dimethyl(phenyl) - methoxy acetylamine] - propionic acid methyl ester and its metabolites containing the 2,6 - dimethylaniline moi ety , and N - (2 - hy droxy methyl - 6 - methylphenyl) - N - (methoxy acetyl) - alanine methyl ester , each expressed as mefenoxam equivalents. Tolerances are established on globe artichoke, fresh and dried herbs, and a variety

of tropical fruits , and range 0.05 - 55 ppm. To lerances for metalaxyl are established under 40 CFR § 180.408 and are expressed in terms of the combined residues of the fungicide metalaxyl [ N - (2,6 - dimethylphenyl) - N

- (methoxy acetyl) alanine methyl ester], and its metabolites containing the 2,6 - dimethylanil ine moiety , and N - (2 - hy droxy methyl - 6 - methylphenyl) - N - (methoxy acetyl) - alanine methyl ester, each expressed as metalaxyl equivalents. The established tolerances for crop commodities range d from 0.1 - 25 ppm , and established tolerances for livestock commoditie s range from 0.02 ppm for milk to 0.4 ppm for fat, kidney , and liver of cattle, goat, hog, horse, poultry , and sheep. In addition, a tolerance with regional registration has been established under 180.408(c) for papay a at 0.1 ppm, and tolerances for indir ect or inadvertent residues of metalaxyl are established under 180.408(d) for barley , cereal grain, oat, and wheat commodities ranging from 0.2 ppm (grain) to 2.0 ppm (forage and straw). The registered uses for mefenoxam that are relevant to the subject p etition are supported by the following metalaxyl tolerances: blueberry at 2.0 ppm, onion, bulb at 3.0 ppm; onion, green at 10.0 ppm; and spinach at 10.0 ppm. In addition, a tolerance on vegetable, legume, group 6 is established at 0.2 ppm, and a toleranc e on raspberry is established at 0.5 ppm. The nature of the residue in plants and livestock is adequately understood for mefenoxam, based on metalaxyl metabolism studies on potato, grape, lettuce , goat, and hen . Metabolites can beMefenoxam Summary of Analytic al Chemistry and Residue Data DP#: 371307

Page 4 of 49 separated into four clas ses: (1) those containing a 2,6 - dimethylaniline (2,6 - DMA) moiety ; (2) those containing a 2 - hy droxy methyl - 6 - methylaniline (HMMA) moiety ; (3) those containing a ring hy droxylated dimethylaniline (Ring - OH) moiety ; and (4) those containing a benzoic acid moie ty . The nature of the residue in rotational crops is adequately understood for mefenoxam based on confined rotational crop studies conducted with metalaxy l o n lettuce , sugar beet, and wheat. Metabolism in rotated crops generally proceeds by

the same path way s seen in primary crops, resulting in the same four classes of metabolites. HED originally concluded that the mefenoxam residues to be regulated for the tolerance expression and for dietary assessments would be as follows: Inplants : (

R ) - and ( S

) - 2 - [( 2,6 - dimethylphenyl) - methoxy acetylamino] - propionic acid methyl ester, its metabolites containing the 2,6 - DMA moiety , and N - (2 - hy droxy

methyl 6 - methylphenyl) - N

- (methoxy acetyl)alanine methyl ester (CGA - 94689) , each expressed as mefenoxam equivalents. Inlivestock : (

R ) - and ( S

) - 2 - [(2,6 - dimethylphenyl) - methoxy acetylamino] - propionic acid methyl ester, its metabolites containing the 2,6 - DMA moiety , and its metabolites containing the HMMA moiety , each expressed as mefenoxam equivalents. Inrotational crops : (

R ) - and ( S

) - 2 - [(2,6 - dimethylphenyl) - methoxy acetylamino] - propionic acid methyl ester, its metabolites containing the 2,6 - DMA moiety, and CGA 94689 , each expressed as mefenoxam equivalents, except that 2 - [(methoxy acetyl)(2 - methoxy - 1 - methyl - 2 - oxoethyl)amino] - 3 - methylbenzoic acid (CGA - 108905) would also be included in the risk assessment for cereal grain rotational crops and N - (3 - hy droxy 2,6 - dimethylphenyl) - N

- (methoxy acetyl)alanine methyl ester (CGA - 100255) would be included in the risk assessment for leafy vegetable (

Brassica and non - Brassica ) rotational crops . The HED R isk Assessment Review Committee (RARC) subsequently determined ( r eport dated 2/14/07 ) that : (1) the residue to be regulated (in the tolerance expression) in plant and livestock commodities is (

R ) - and ( S

) - 2 - [(2,6 - dimethylphenyl) - methoxy acetylamino] - propion ic acid methyl ester ; (2) the current/reassessed tolerance levels should be retained ; (3) for risk assessment, the residues of concern in plant and livestock commodities are metalaxyl/mefenoxam, its metabolites containing the 2,6 - DMA moiety , its metabolite s containing the HMMA moiety , its metabolites containing the Ring - OH moiety , and its metabolites containing the benzoic acid moiety ; and (4) the available residue chemistry data can be used and factors may

be employ ed to estimate the total residues of conc ern in dietary risk assessments. There are no livestock feedstuffs associated with the proposed /registered use s on onions, leafy vegetables/ spinach, snap beans, caneberries, and bushberries . Therefore, no livestock metabolism data, enforcement methods, storage stability data, or feeding studies are required to support this petition. The residue analy

tical methods available for tolerance enforcement in plant commodities are common moiety

methods which determine residues of metalaxyl/mefenoxam that are c onvertible to 2,6 - DMA . T hese methods include: (1) Method I in the Pesticide Analy tical Manual ( PAM ), Vol. I I (Method AG - 348) which determines residues in plant commodities using gas - liquid chromatography

with alkali flame - ionization detection ( GLC/AFID ) ; and (2) Method AG - 395Mefenoxam Summary of Analytic al Chemistry and Residue Data DP#: 371307

Page 5 of 49 (sent to FDA for inclusion in PAM , Vol. I I as Method I II), an improved version of Method AG 348, which determines residues in plant commodities using GL C with nitrogen - phosphorus detection (NPD ) . Neither Method AG - 348 nor Method AG - 3 95 distinguish between the R - and S - en an tiomers of m etalaxyl/mefenoxam; however, a confirmatory high performance liquid chromatography

method with mass spectrometric detection that u tilizes a chiral column ( chiral LC /MS ) , Method 456 - 98, is available for th e enantioselective determination of the D - and L enantiomers of metalaxyl in crops . This method has been adequately validated by

ACB/BEAD , and a revised version of the method has been submitted for inclusion in PAM , Vol. I I. HED has determined that the 2,6 - DMA common moiety residue analy

tical methods available for tolerance enforcement and used for data collection will not adequately recover all of the metalaxyl/mefenoxam residues of concern in the current tolerance expressions. While these methods are adequate to recover residues of metalaxyl/mefenoxam per se, they will not adequately

recover metabolites containing the HMMA moiety and may not adequately

recover all metabolites containing the 2,6 - DMA moiety with the certainty

needed to set legal limit s , nor are they likely to recover metabolites containing the Ring - OH moiety or the benzoic acid moiety . As a result, in addition to the changes to the tolerance expression and the residues of concern for risk assessment addressed above, the HED RARC deter mined that: (1) the multiresidue method PAM , Vol. ISection 302 (Protocol D), which completely recovers metalaxyl/mefenoxam per se , is an adequate enforcement method for the determination of metalaxy l/mefenoxam per se in plant and livestock commodities ; an d (2) a ll future metalaxyl/mefenoxam magnitude of the residue data should include ( a ) analy sis for residues of parent only using the multiresidue method PAM , Vol. ISection 302 in order to establish more appropriate tolerance levels , and ( b ) analy sis using a 2,6 - DMA common moiety method , including recovery data for parent, CGA - 62826, and CGA 94689 , in order to refine dietary risk assessments. Samples from the submitted snap bean and caneberr y trials were initially

analy zed for residues of mefenoxam per se using a chiral LC /MS method, Method 456 - 98. Samples of spinach from the submitted field trials and selected samples of snap bean and caneberries were analy zed for combined residues of mefen oxam/metalaxyl , and metabolites convertible to 2,6 - DMA using a gas chromatography

( GC ) /MS method, defined by working method numbers YARL - 0601A (caneberry

), - 0601 C (snap bean), and - 0601 D (spinach) which was derived, with minor modifications, from Method AG - 395. The data collection methods were adequate for data collection based on acceptable method validation and concurrent recovery data for mefenoxam . The lowest l evel of method validation (L LM V) was 0.05 ppm for snap bean and caneberries using Method 456 - 98, and the L LM Vs were 0.1 ppm for spinach and 0.05 ppm for snap bean and caneberries using Methods YARL - 0601A, - 0601C , and - 0601D . The study results for snap bean and caneberry , reflecting the original analy sis for mefenoxam only and re - analy sis of the selected field trial samples for parent + metabolites, were presented to HED’s Chemistry

Science Advisory

Council (ChemSAC) with a request to use conversion factors ( calculated by

dividing the residues obtained on re - analy sis of certain field trial sample s by the original values ) to calculate residues in the remaining field trial samples for setting residue values for the risk assessment . The calculated conversion factors are: for snap beans, 1x for 0 - day preharvest interval (PHI ), 1.8x for the 6 - to 7 - d ay PHI , and 3x for the 13 - to 14 - day PHI ; and 1.3x for caneberries . The ChemSAC agreed (see minutes of 2/25/09 meeting) that parent + metabolites to parent ratios could be used to estimate residue levels for risk assessments in snapMefenoxam Summary of Analytic al Chemistry and Residue Data DP#: 371307

Page 6 of 49 beans and caneberries , with the provision that these ratios would not necessarily be correct/adequate for these commodities for future risk assessments if refinements were necessary . The submitted crop field trial studies are supported by adequate storage stability data. Pending amendment of the proposed labels, a dequate field trial data have been submitted for snap beans , and adequate data have been submitted for spinach treated with a soil application of the EC or SLformulation followed by foliar application of the WP f ormulation . For caneberries , an additional field trial conducted in Zone 5 or 6 and including residue decline data is required as a condition of registration; the proposed use must also be amended . The submitted data used to determine tolerances for snap bean and caneberries reflected analy sis of samples for mefenoxam per se ; the data for spinach reflected analy sis for combined residues of mefenoxam/metalaxyl and metabolites convertible to 2,6 - DMA. The crop field trial data for spinach will support a red uction in PHIfrom 21 day s to 3 day s, pending label amendments. Data are not available to support expanded foliar use of the 4 lb ai /gal EC and SLformulations on spinach or other members of the leafy

vegetables group. The submitted crop field trial data for spinach will support a tolerance of 8.0 ppm for spinach; however, because the submitted data are not representative of all registered uses of mefenoxam on spinach, HED recommends against establishing a reduced tolerance for mefenoxam on spinach. The existing tolerance of 10 ppm for spinach , established under 40 CFR §180. 408, is appropriate. The proposed tolerances for snap bean and the caneberry subgroup are too high; tolerances should be established at 0.20 ppm for snap bean and 0.70 ppm for caneber ry subgroup 13 - 07A. Adequate crop field trial data for meta la xyl are available to support expanded use of mefenoxam on members of the bulb and green onion subgroups and bushberry subgroup. The available data will support establishment of the proposed t olerances for residues of mefenoxam in/on onion, bulb, subgroup 3 - 07A at 10 ppm; onion, green, subgroup 3 - 07B at 3.0 ppm; and bushberry subgroup 13 - 07B at 2.0 ppm. In conjunction with establishment of the proposed tolerance for the bushberry subgroup, the mefenoxam tolerance for lingonberry can be removed. Adequate field rotational crop data are available to support the established plantback intervals for mefenoxam. Codex MRL s, expressed in terms of metalaxyl per se for plant commodities , are establishe d for spinach at 0.1 and onion at 0.03 ppm. Canadian ( Pest Management Regulatory Agency ; PMRA) MRL s for mefenoxam (metalaxyl - M) are covered by MRL s established for metalaxyl, the unresolved isomeric mixture , which are expressed in terms of N - (2,6 - dimethyl phenyl) - N

- (methoxy acetyl) -DL - alanine methyl ester, including metabolites that can be converted to the 2,6 - dimethylaniline moiety , calculated as metalaxyl equivalents . Canadian MRL s are established for spinach at 10 ppm, bulb onion at 3.0 ppm, green onion at 10 ppm, bean at 0.2 ppm, raspberry at 0.2 ppm, and blueberry

at 2.0 ppm . No Mexican MRL s are established for mefenoxam or metalaxyl. With the adoption of the tolerance expression recommended by the RARC, the U.S. tolerance expression will be in harmon ization with Codex MRL s but not with PMRA MRL s.Mefenoxam Summary of Analytic al Chemistry and Residue Data DP#: 371307

Page 7 of 49 Regulatory Recommendations and Residue Chemistry Deficiencies HED has examined the residue chemistry database for mefenoxam and metalaxyl . Pending submission of a revised Section B ( see requirements under Directions for Use) and a revised Section F (see requirements under Proposed Tolerances), there are no residue chemistry issues that would preclude granting full registration for the requested use s of mefenoxam on members of the bulb and green onion subgroups , spinach, snap beans, and bushberry subgroup, or conditional registration for the requested use on the can e berry subgroup. Tolerances for residues of mefenoxam per se are recommended as follow: Bean, snap, succulent ................................ ................................ ..... 0. 20 pp m Caneberry

subgroup 13 - 07A ................................ .......................... 0.70 pp m Bushberry

subgroup 13 - 07B ................................ ............................ 2.0 ppm Onion, bulb, subgroup 3 - 07A ................................ .......................... 3.0 ppm Onion, green, subgroup 3 - 07B ................................ .......................... 10 ppm Spinach ................................ ................................ .............................. 10 ppm As a condition of registration, additional crop field trial data are required for caneberries (see requirements under Crop Field Trials). Inthe absence of supporting crop field trial data, HED recommends against expanding the registered foliar uses of the 4 lb ai/gal EC and SL formulations on head and leaf lettuce to include spinach or any

other memb ers of the leafy vegetables except Brassica crop group. A human health risk assessment is forthcoming. Note to PM: Based on the tolerance expression s recommended by HED ’s Risk Assessment Review Committee ( 2/14/07, W. Britton) and by HED in the metalaxyl /mefenoxam registration review (DP#368461, N. Dodd, 4/13/10) , and to be consistent with Codex, the tolerance expression for mefenoxam should be revised according to HED’s Interim Guidance on Tolerance Expressions (5/27/09, S. Knizner) to state: “ Tolerances are established for residues of mefenoxam, including its metabolites and degradates, in or on the commodities in the table below. Compliance with the tolerance levels specified below is to be determined by measuring only metalaxyl (methyl N - (2,6 - dimethy lphenyl) -

N - (methoxyacetyl) -

D L - alanin at e ) . ” Note to PM: When the recommended tolerance on Bushberry subgroup 13 - 07B is established, the tolerance for l ingonberry should be removed .Mefenoxam Summary of Analytic al Chemistry and Residue Data DP#: 371307

Page 8 of 49 860.1200 Directions for Use A revised Section B must be submitted refle cting the following changes to the proposed use directions. For onions:  Since the WP label for bulb onions indicates a maximum of 0.4 lb ai/A/season of foliar applied mefenoxam, the proposed use directions for the 4 lb ai /gal EC and SL formulations should be revised to reflect the following maximum seasonal rate for bulb onion: “Do not exceed the equivalent of 1.0 lb ai/A per crop of soil - applied and 0.4 lb ai/A per crop of foliar - applied mefenoxam - containing products.”  The proposed use directions for the 5% WP formulation should be revised to reflect the following maximum seasonal rates: (1) for bulb onion, “Do not exceed the equivalent of 1.0 lb ai/A per crop of soil - applied and 0.4 lb ai/A per crop of foliar - applied mefenoxam - containing products”; and (2) for green onion, “Do not exceed the equivalent of 1.0 lb ai/A per crop of soil - applied and 0.3 lb ai/A per crop of foliar applied mefenoxam - containing products.” For leafy vegetables /spinach :  The proposed labels for Leafy Vegetables and Spinach Only must be revised. The 3 - day PHI for spinach can be applied only to application ty

pes and rates supported by the 3 - day PHIdata (i.e., soil application at 1.0 lb ai/A/season and foliar application at 0.25 lb ai/A/season). Soil application of the EC formu lation can be translated to the SL formulation. Based on the available data for spinach at the proposed 3 - day PHI , the proposed use directions for Spinach Only should be revised to specify soil surface application of the EC or SL formulation s and foliar d irected or broadcast spray applications of the WP formulation , and to specify the following maximum seasonal rate s : “Do not exceed the equivalent of 1.0 lb ai/A per crop of soil - applied mefenoxam containing products at planting and 0.25 lb ai/A of foliar - applied mefenoxam containing products.” The proposed changes to the existing Leafy Vegetables section of the existing labels to establish a 3 - day PHIfor spinach should be removed.  For the 4 lb ai /gal EC and SL formulations, spinach and all other members of the leafy vegetables except Brassica crop group, except head and leaf lettuce, must be removed from the use directions for Part 2 of the proposed label; the reference to Part 2 of the label that appears in Part 1 should be revised accordingly .  On the 5 % WP formulation label, the statement referring to a 21 - day PHIfor spinach should be removed.  The proposed use directions for all three products must be amended to specify that no adjuvants may

be added to spray

mixtures for foliar use on spinach.  When HE D approved the registered use of the 4 lb ai/gal EC formulation on head and leaf lettuce ( DP# 324493, 3/17/06, L . Cheng ), certain label revisions were required which have not been made. These revisions also apply to the label for the 4 lb ai/gal SL formul ation. As previously required under DP# 324493, Part 1 of the labels for the 4 lb ai/gal EC and SL

formulations should be revised to specify that no more than one soil directed application may

be made, and Part 2 should be revised to specify a maximum of 4 foliar - directed applications.Mefenoxam Summary of Analytic al Chemistry and Residue Data DP#: 371307

Page 9 of 49 Snap Beans :  The proposed use directions for the 5% WP formulation must be revised to specify a maximum of two applications per season at 0.1 lb ai/A/application and to reflect the following maximum seasonal rate for snap bean: “Do not exceed the equivalent of 0.5 lb ai/A per crop of soil - applied mefenoxam containing products at planting and 0.2 lb ai/A per crop of foliar - applied mefenoxam - containing products.”  The proposed use directions for the 5% WP formulation must be revised to propose a 7 - day preharvest interval (PHI ). Four of eight field trials have a 7 - day PHIand four have a 6 - day PHI .  The proposed use directions must be amended to specify that no adjuvants may

be added to spray mixtures for foliar use on snap be an s . Caneberries :  The proposed use directions for the 4 lb ai /gal EC and SL formulation s for the caneberry subgroup must be revised to specify a maximum of one soil application per season at 1.8 lb ai/A and to reflect the following maximum seasonal rate: “ Do not exceed the equivalent of 1.8 lb ai/A per crop of soil - applied and 0.2 lb ai/A per crop of foliar - applied mefenoxam - containing products for a maximum seasonal application rate of 2.0 lb ai/A.”  To clarify

the use pattern for established plantings sp ecified in Part 2 of the labels for the 4 lb ai /gal EC and SL

formulations, the use directions should be revised to indicate that applications are to be directed toward the base of the plants.  The proposed use directions for the 5% WP formulation must be r evised to specify a maximum of two foliar applications per season at 0.1 lb ai/A/application and to reflect the following maximum seasonal rate: “ Do not exceed the equivalent of 1.8 lb ai/A per crop of soil - applied and 0.2 lb ai/A per crop of foliar - appli ed mefenoxam - containing products for a maximum seasonal application rate of 2.0 lb ai/A. ”  For all three products , bromberre must be corrected to brombeere and nectaberry must be corrected to nectarberry .  The proposed use directions for all three products must be amended to specify that no adjuvants may

be added to spray

mixtures for foliar use on caneberries. Bushberries :  The following berries are not members of bushberry subgroup 13 - 07B and must be removed from the crops listed under the bushberry subgro up on the labels for the 4 lb ai /gal EC and SL

formulations : bilberry , bearberry , cloudberry , muntries, and partridgeberry .  To clarify

the use pattern for established plantings specified in Part 2 of the labels for the 4 lb ai /gal EC and SL

formulations, the use directions should be revised to indicate that applications are to be directed toward the base of the plants.  For both products, hostaberry must be corrected to jostaberry .  When the proposed use on bushberries is registered for the 4 lb ai /gal EC an d SL formulations, the separate use directions for lingonberries may be removed from the labels.Mefenoxam Summary of Analytic al Chemistry and Residue Data DP#: 371307

Page 10 of 49 860.1550 Proposed Tolerances

 Based on the tolerance expression s recommended by the RARC and by

HED in the metalaxyl/mefenoxam registration review, and to b e consistent with Codex, the tolerance expression proposed by

I R - 4 under PP#9E7591 must be revised . The tolerance expression should be stated as follows:

Tolerances are established for residues of mefenoxam, including its metabolites and degradates, in or on the commodities in the table below. Compliance with the tolerance levels specified below is to be determined by measuring only metalaxyl [methyl N - (2,6 - dimethylphenyl) - N

- (methoxy acetyl) -D

L - alaninate].  The p roposed tolerances for snap bean and the cane berry subgroup are too high; tolerances should be established at 0.20 ppm for snap bean and 0.70 ppm for caneberry subgroup 13 - 07A .  The proposed tolerance for spinach is too low; a tolerance should be established at 10 ppm.  In conjunction with establishmen t of the proposed tolerance for the bushberry subgroup, the mefenoxam tolerance for lingonberry can be removed.  The proposed tolerance for the caneberry subgroup must be revised to reflect the correct commodity

definition: “ Caneberry

subgroup 13 - 07A .” HE D recommends that conversion of conditional registration to unconditional registration for the requested uses on the caneberry subgroup may be considered upon submission of the following crop field trial data . 860.1500 Crop Field Trials

 To fulfill geogra

phic distribution requirements, an additional field trial must be conducted in Zone 5 (raspberry

) or 6 (blackberry

). The required trial should include additional sampling intervals to assess residue decline.Mefenoxam Summary of Analytic al Chemistry and Residue Data DP#: 371307

Page 11 of 49 Background T he chemical structure and nomen clature of mefenoxam and its regulated metabolites/metabolite moieties are presented in Table 1. The phy sicochemical properties of the technical grade of mefenoxam are presented in Table 2. Inaddition, the chemical names and structures of metabolites re ferenced herein are presented in Appendix I . Table 1. Test Com pound Nom enclature. Compound

C H3 N O

C H3 O C H3 C H3 O C H3 O

Common name m efenoxam; m etalaxyl - M Company experimental name CGA - 329351 IUPAC name m ethyl N - (methoxyacetyl) -N

- (2,6 - xylyl) -D - alaninate CAS name methyl N - (2 ,6 - dimethylphenyl) -N

- (methoxyacetyl) -D - alanin at e CAS registry number 70630 - 17 - 0 End - use product (EP) Ridomil Gold® EC (4 lb ai /gal EC; EPA Reg. No. 100 - 801) Ridomil Gold® Copper ( 5 % WP; EPA Reg. No. 100 - 804) Ridomil® Gold SL (4 lb ai /gal EC; EPA Reg. No. 100 - 1202) Regulated metabolite in plant and rotational crop commodities N O

C H 3 O C H

3 O O C H 3

O H C H 3

N - (2 - hydroxymethyl - 6 - methylphenyl) -N - (methoxyacetyl)alanine methyl ester ; CGA - 94689 Regulated metabolite mo iety in plant, livestock, and rotational crop commodities C H 3 N C H3

R2 R1

2,6 - dimethyl a nili ne moiety (2,6 - DMA when R1=R2=H ) Regulated metabolite mo iety in livestock commodities N C H 3 R2 R1 O H 2 - hydroxymethyl - 6 - methylalanine (HMMA when R1=R2=H )Mefenoxam Summary of Analytic al Chemistry and Residue Data DP#: 371307

Page 12 of 49 Table 2. Physicochem ical Properties of Mefenoxam . Parameter Value 1 Reference Boiling point/range >270 o C (PAI) MRID 43800301; DP# 223261, 4/24/96 , L. Kutney pH 5 - 6 at 25 °C (1% aqueous dispersion; TGAI) Density 1.125 g/cm 3 (20 °C; TGAI) Water solubility 26 g/L (25 °C; PAI) Solvent solubility Completely miscible in acetone, dichloromethane, ethyl acet ate, methanol, n octanol, and toluene; 59 g/L in n - hexane at 25 °C (TGAI). Vapor pressure 3.3 x 10 - 3 (25 °C; PAI) Dissociation constant, pK a None in 1 - 10 pH range (PAI) Octanol/water partition coefficient, Log(K OW ) 1.71 at 25 °C (TGAI) UV/visible absorption spectrum Not available 1 TGAI = Technical grade of the active ingredient; PAI = Purified active ingredient. 860.1200 Directions for Use IR - 4 has submitted proposed amended use directions for three products registered to Sy ngenta: a 4 lb ai / gal EC formulation, Ridomil Gold® EC (EPA Reg. No. 100 - 801 ; label dated 7/7/09 ); a 4 lb ai /gal SL formulation, Ridomil Gold® SL(EPA Reg. No. 100 - 1202 ; label dated 7/30/09 ) ; and a 5% WP formulation, Ridomil Gold®/Copper (EPA Reg. No. 100 - 804 ; label dated 7 /30/09 ). The 5% WP formulation is an MAI product containing 5 % mefenoxam and 60% copper hy droxide. For the 4 lb ai /gal EC and SL formulations, the petitioner is proposing to: (1) expand the registered use on onions to include additional crops that are now included in the bulb vegetable crop group 3 - 07; (2) reduce the preharvest interval (PHI ) for spinach from 21 to 3 day s; (3) expand the registered foliar use of the 4 lb ai /gal EC and SLformulations on head and leaf lettuce to cover all members of the leafy vegetables group; and (4) add new uses on the caneberry subgroup; and (5) expand the registered use on blueberries to cover the bushberry subgroup . For the 5% WP formulation, the petitioner is proposing to : (1) expand the registered use on onions to include additional crop s that are now included in the bulb vegetable crop group 3 - 07; (2) reduce the PHIfor spinach from 21 to 3 day s ; (3) add new use s on snap beans; and (4) add new use s on the caneberry

subgroup . The proposed use directions for th e EC and SLformulations are divided into two parts on the labels : “Part 1: Soil - In

jected or Soil - In corporated Applications” and “Part 2: Soil Directed and Other Foliar Applications.” The proposed c hanges to the crops or use patterns from those which appear on the accepted labels are highlighted in Table 3.Mefenoxam Summary of Analytic al Chemistry and Residue Data DP#: 371307

Page 13 of 49 Table 3. Sum ma ry of Directions for Use of Mefenoxam . Applic. Timing, Ty pe, and Equipment 1 Formulation

[EPA Reg. No.] Applic.

Rate (lb ai/A) Max. No.

Applic. per Season Max. Seasonal

Applic. Rat e (lb ai/A) PHI

(days) Use Directions and

Limitations 2 Onions 3 : Dry Bulb including Garlic, Onions (dry bulb), Shallots (dry bulb); and Green including Green eschalots, Green onions, Green shallots, Japanese bunching onions, Leeks, Spring onions, Scallion s. Including hybrids, cultivars, and varieties of these. Other Dry Bulb Crops: Great - headed Garlic, Serpent Garlic, Lily Bulb, Chinese Onion Bulb, Pearl Onion, Potato Onion Bulb. Other Green Bulb Crops: Chive (fresh leaves), Chinese Chive (fresh leave s), Hosta Elegans, Fritillaria (leaves), Kurrat, Lady’s Leek, Beltsville Bunching Onion, Onion (fresh),

Macrostem Onion, Tree Tops Onion, Welsh Onion (tops), Shallot (fresh leaves) Preplant incorporated (broadcast or band) At planting Soil spray (broadca st or band) 4 lb/gal EC

[100 - 801] 4 lb/gal SL [100 - 1202] 0.25 - 0.50 Not specified 1.0 soil + 0.5

foliar applied (dry bulb) 1.0 soil + 0.3 foliar applied (green) Not

specified Part 1 : Apply in water or

liquid fertilizer. For preplant incorporated applic ation, mechanically incorporate in the top 2 inches of soil. For banded applications, use a 7 - inch band. Postemergence Foliar 5% WP

[100 - 804] 0.1 4 (dry bulb and seed) 3 (green) 0.4 10 (dry bulb) 7 (green) Begin applications w hen conditions are favorable for disease, but before infection; continue at a 14 - day RTI. Use of a suitable spreader - sticker is recommended. Leafy Vegetables (Except Brassica): Celery, Endive (Escarole), Lettuce (Head and Leaf), Parsley, Rhubarb, Spinach, Swiss chard. Addition al Leafy Vegetable Crops: Amaranth, Arugula, Cardoon, Celtuce, Chervil, Chinese Celery, Chrysanthemum (edible - leaved), Chrysanthemum (garland), Corn salad, Cress (garden), Cress (Upland), Dandelion, Dock (Sorrel), Florence Fennel (finochio), Orach, Pursla ne (garden), Purslane (w inter),

Radicchio (red chicory), Spinach (New Zealand), and Spinach (vine) Preplant incorporated (broadcast or band) At planting Soil spray (broadcast or band) 4 lb/gal EC

[100 - 801] 4 lb/gal SL [100 - 1202] 0.50 - 1.0 Not specified 1.0 soil + 0.4

foliar applied (all except spinach) 1.0 soil + 0.25 shank to soil or 0.4 foliar applied (spinach) 7

(all except spinach) 3 (spinach) Part 1 : Apply in water or

liquid fertilizer. For preplant incorporated application, mechanically incorp orate in the top 2 inches of soil. For banded applications, use a 7 - inch band.

Postemergence Foliar 4 lb/gal EC

[100 - 801] 4 lb/gal SL [100 - 1202] 0.063 -

0.125 Not

specified 1.0 soil + 0.4

foliar applied 7 4

(all except spinach) 3 (spinach) Part 2 : Ap ply only in a

tank mix with other fungicides, when conditions are favorable for disease; continue at a 14 - day RTI.Mefenoxam Summary of Analytic al Chemistry and Residue Data DP#: 371307

Page 14 of 49 Table 3. Sum ma ry of Directions for Use of Mefenoxam . Applic. Timing, Ty pe, and Equipment 1 Formulation

[EPA Reg. No.] Applic.

Rate (lb ai/A) Max. No.

Applic. per Season Max. Seasonal

Applic. Rat e (lb ai/A) PHI

(days) Use Directions and

Limitations 2 Spinach only

Shank injections Soil 4 lb/gal EC

[100 - 801] 4 lb/gal SL [100 - 1202] 0.125 2 1.0 soil + 0.25 shank to soil or 0.4 foliar app lied 3 Part 1 : Apply in addition

to preplant incorporated or at - planting soil spray applications 5 , 21 days after planting or first cutting; a second application may be made after the next cutting at a 21 - day retreatment interval.

Postemergence Foliar 5 % WP

[100 - 804] 0.125 2 Not specified 3 Apply 21 days after preplant or at - planting application of the 4 lb/gal EC formulation at 0.5 - 1 lb ai/A or immediately after each repeated cutting. Make 1 - 2 applications at a 14 - day RTI; avoid late season application s. Snap Beans Postemergence Foliar 5% WP

[100 - 804] 0.1 4 0.4 6 Begin applications at onset of disease; continue at a 7 - day RTI. Caneberry (Blackberry and Raspberry) Subgroup: Blackberry, Raspberry (Red and Black), Wild Raspberry

Cultivars, Including hy

brids, cultivars, and varieties of these. Subgroup includes Andean Blackberry, Arctic Blackberry, Bingleberry, Black Satin Berry, Boysenberry, Brom berre, California Blackberry, Cherokee Blackberry, Chesterberry, Cheyenne Blackberry, Common Blackberry, Cory

berry, Darrow

berry, Dew

berry, Dirksen Thornless Berry, Evergreen Blackberry, Himalayaberry, Hullberry, Lavacaberry, Loganberry, Lowberry, Lucretiaberry, Mammoth Blackberry, Marionberry, Mora, Mures Deronce, Nectaberry, Northern Dew berry, Olallieberry, Oreg on Evergreen Berry, Phenomenalberry, Rangeberry, Ravenberry, Rossberry, Shawnee Blackberry, Southern Dewberry, Tayberry, Youngberry, Zarzamora At planting Soil spray (broadcast or band) 4 lb/gal EC

[100 - 801] 4 lb/gal SL [100 - 1202] 1.8 1 (implied) 3.6

soi l applied 45 Part 1 : New plantings: For banded applications, use an 18 - inch band Postemergence Soil spray (band) 1.8 Not specified Part 2 : Established plantings: Apply in a 3 - ft band over the row

before plants start to grow

in the spring. Postemer gence Foliar 5% WP

[100 - 804] 0.1 4 3.6 soil + foliar applied 0 Begin applications w hen conditions are favorable for disease, but before infection; continue at a 7 - day RTI.Mefenoxam Summary of Analytic al Chemistry and Residue Data DP#: 371307

Page 15 of 49 Table 3. Sum ma ry of Directions for Use of Mefenoxam . Applic. Timing, Ty pe, and Equipment 1 Formulation

[EPA Reg. No.] Applic.

Rate (lb ai/A) Max. No.

Applic. per Season Max. Seasonal

Applic. Rat e (lb ai/A) PHI

(days) Use Directions and

Limitations 2 Bushberry Subgroup: Blueberries (High and Low Bush), Currants, Elderberry, Goosebe rry, Highbush Cranberry, Including hybrids, cultivars, and varieties of these. Other Bushberries in Subgroup: Aronia Berry, Highbush Blueberry, Lowbush Blueberry, Bearberry, Bilberry, Buffalo Currant, Chilean Guava, Cloudberry, Black Currant, Red Currant , Elderberry, European Barberry, Gooseberry, Highbush Cranberry, Edible Honeysuckle, Huckleberry, Hostaberry, Juneberry, Lingonberry,

Muntries, Native Currant, Partridgeberry, Salal, Sea Buckthorn. At planting Soil spray (broadcast or band) 4 lb/gal EC

[1 00 - 801] 4 lb/gal SL [100 - 1202] 1.8 1 (implied)

3.6

soil applied 0 Part 1 : Application is to be made to new plantings . For banded applications, use an 18 - inch band . Post - planting Soil spray (band) 1.8 1 Part 2 : New plantings: After initial at - plant ing application, reapply once during a period favorable for root rot. Postemergence Soil spray (band) 1.8 2 Part 2 : Established plantings: Apply in a 3 - ft band over the row

before plants start to grow

in the spring. Re - apply once during the period m ost favorable for root rot. 1 Information pertaining to equipment type appears on the accepted labels; use of ground, aerial, and irrigation equipment is approved for all products. Ground applications are to be made in ≥20 gal/A of water, and aerial applications are to be made in ≥3 gal/A of water. 2 For the proposed and registered labels for the 4 lb/gal EC and SL formulations, Part 1 = Soil - Injected or Soil Incorporated Applications and Part 2 = Soil Directed and Other Foliar Applications. RTI = Retreatment interval. 3 The proposed and accepted labels for the 5% WP formulation a lso list onions grown for seed. 4 For the 4 lb/gal SL formulation, Section B reflects foliar use on all leafy vegetables listed; on the Data Package Label, the proposed use is listed for head and leaf lettuce and spinach. The registered labels for both products reflect foliar use on head and leaf lettuce only. 5 This statement appears on the 4 lb/gal EC label only; use directions for the 4 lb/gal SL state: Shank in 21 days after planting or after the first cutting.Mefenoxam Summary of Analytic al Chemistry and Residue Data DP#: 371307

Page 16 of 49 The accepted label s inc lude the following r otational crop restrictions : (1) 0 day s for crops for which use of mefenoxam/metalaxyl is registered; (2) 40 day s (5% WP formulation) and 14 day s (4 lb ai /gal EC and SL formulations) for cereal grains other than corn; ( 3 ) 9 months for corn ; and (4) 12 months for any

crop for which use of mefenoxam/metalaxyl is not registered . The directions on the 5% WP label further state that deciduous fruit and nut crops and other perennial crops may

be planted immediately

following last application of mefenoxam provided they will not bear harvestable fruit within 12 months. HED note s that the cover letters accompanying the accepted labels for the 4 lb ai /gal EC and SL formulations and the 5% WP formulation require that the following statement be ad ded: “Maximum usage when applying both metalaxyl and mefenoxam containing products to the same crop within the same season: Do not apply more than the maximum seasonal total for the active ingredient as stated on the label of the product containing the l owest seasonal total on that crop.” Conclusions . The submitted use directions are sufficient to allow evaluation of the submitted and available residue data relative to the proposed use pattern s and crops . T he submitted and available data for mefenoxam and metalaxyl will support the requested use s of mefenoxam on onions ( and other green and dry bulb crops) , snap beans , spinach , and the caneberry and bushberry subgroups , pending revision of the proposed labels as indicated below. HED note s that a s stated in OPPTS 860.1500, data may be translated among the SL and EC formulation classes and other formulation ty pes which are diluted in water prior to application for applications directed to the soil (as opposed to foliar treatments). Onions : P reviously

rev iewed crop field trial data for metalaxyl on bulb onions and green onions will support the proposed expanded use on the onions listed in Table 3 , provided the following changes to the use directions ar e made:  T he proposed use directions for the 4 lb ai /gal EC and SLformulations should be revised to reflect the following maximum seasonal rate for bulb onion: “Do not exceed the equivalent of 1.0 lb ai/A per crop of soil - applied and 0.4 lb ai/A per crop of foliar applied mefenoxam - containing products.”  The p roposed use directions for the 5% WP formulation should be revised to reflect the following maximum seasonal rates: (1) for bulb onion, “Do not exceed the equivalent of 1.0 lb ai/A per crop of soil - applied and 0.4 lb ai/A per crop of foliar - applied mefeno xam - containing products”; and (2) for green onion, “Do not exceed the equivalent of 1.0 lb ai/A per crop of soil - applied and 0.3 lb ai/A per crop of foliar applied mefenoxam - containing products.” HED note s that the expanded list of onions that appears on each label could additionally include the bulb onions daylily

bulb and fritillaria bulb, and the green onion wild leek. Leafy vegetables /spinach : Revisions are needed to the proposed labels as follow.

 T he proposed labels for Leafy Vegetables and Spinac h Only must be revised. The 3 - day PHIfor spinach can be applied only to application ty

pes and rates supported by the 3 - day PHIdata. The submitted spinach crop field trial data reflect a single at - plantingMefenoxam Summary of Analytic al Chemistry and Residue Data DP#: 371307

Page 17 of 49 application of the 4 lb ai/gal EC formulation at 1.0 lb ai/A followed by two foliar applications of the 5% WP formulation at 0.125 lb ai/A/application for a total seasonal application rate of 1.25 lb ai/A . Soil application of the EC formulation can be translated to the SLformulation . Based on the available data for spinach at the proposed 3 - day PHI , the proposed use directions for Spinach Only should be revised to specify soil surface application of the EC or SL formulations and foliar directed or broadcast spray applications of the WP formulation, and to specify the following maximum seasonal rates: “Do not exceed the equivalent of 1.0 lb ai/A per crop of soil - applied mefenoxam containing products at planting and 0.25 lb ai/A of foliar - applied mefenoxam containing products.” The proposed changes t o the existing Leafy Vegetables section of the existing labels to establish a 3 - day PHIfor spinach should be removed.  The available and submitted crop field trial data for leafy vegetables do not support expanding the registered foliar uses of the 4 lb ai /gal EC and SL formulations on head and leaf lettuce to include spinach or any other members of the leafy vegetables except Brassica crop group. For the 4 lb ai/gal EC and SL formulations, spinach and all other members of the leafy

vegetables except Brass ica crop group, except head and leaf lettuce, must be removed from the use directions for Part 2 of the proposed label; the reference to Part 2 of the label that appears in Part 1 should be revised accordingly .  On the 5% WP formulation label, the statemen t referring to a 21 - day PHIfor spinach should be removed.  No spray

adjuvants were used in the submitted crop field trials on spinach. HED has concluded that spray

adjuvant use must be prohibited on product labels when the field trials did not include adj uvants (see minutes of 4/16/08 ChemSAC meeting). Therefore, the product label for foliar applications must be amended to specify that no adjuvants may be added to spray

mixtures for foliar use on spinach.  When HED approved the registered use of the 4 lb a i/gal EC formulation on head and leaf lettuce ( DP# 324493, 3/17/06, L . Cheng ), certain label revisions were required which have not been made. These revisions also apply to the label for the 4 lb ai/gal SL formulation. As previously required under DP# 3 24493, Part 1 of the labels for the 4 lb ai /gal EC and SL

formulations should be revised to specify that no more than one soil directed application may

be made, and Part 2 should be revised to specify a maximum of 4 foliar - directed applications. Snap Bean s : The submitted crop field trial data for snap bean do not reflect the maximum proposed seasonal rate for snap bean. The submitted snap bean crop field trial data reflect a single at - planting application of the 4 lb ai/gal EC formulation at 0.5 lb ai/A followed by two foliar applications of the 5% WP formulation at 0.1 lb ai/A/application for a total seasonal application rate of 0.70 lb ai/A. The data may be used to support foliar use of the 5% WP on snap bean provided the proposed use directions are am ended as specified below .  The proposed use directions for the 5% WP formulation must be revised to specify a maximum of two applications per season at 0.1 lb ai/A/application and to reflect the following maximum seasonal rate for snap bean: “Do not excee d the equivalent of 0.5 lb ai/A per crop of soil - applied mefenoxam containing products at planting and 0.2 lb ai/A per crop of foliar - applied mefenoxam - containing products. ”Mefenoxam Summary of Analytic al Chemistry and Residue Data DP#: 371307

Page 18 of 49  The proposed use directions for the 5% WP formulation must be revised to propose a 7 - day preharvest interval (PHI ). Four of eight field trials have a 7 - day PHIand four have a 6 - day PHI .  No spray

adjuvants were used in the submitted crop field trials on snap bean. Therefore, the product label for foliar applications must be amended to specify that no adjuvants may be added to spray

mixtures for foliar use on snap bean. If the petitioner wishes to support the proposed use pattern of a maximum of four foliar applications to snap beans at 0.1 lb ai/A/application following soil applicatio n at 0.5 lb ai/A, crop field trial data reflecting that use pattern must be submitted. Caneberries : The submitted crop field trial data for blackberries and raspberries do not reflect the maximum proposed seasonal rate for caneberries . The submitted can eberry field trial data reflect two foliar applications of the 5% WP formulation at 0.1 lb ai/A/ application following a single at - planting application of the 4 lb ai/gal EC formulation at 1.8 lb ai/A for a total seasonal application rate of 2.0 lb ai/A . The data may be used to support foliar use of the 5% WP on caneberries provided the proposed use directions are amended as specified below.

 The proposed use directions for the 4 lb ai /gal EC and SL formulation s for the caneberry subgroup must be revised to specify a maximum of one soil application per season at 1.8 lb ai/A and to reflect the following maximum seasonal rate: “ Do not exceed the equivalent of 1.8 lb ai/A per crop of soil - applied and 0.2 lb ai/A per crop of foliar - applied mefenoxam - containi ng products for a maximum seasonal application rate of 2.0 lb ai/A. ”  To clarify

the use pattern for established plantings specified in Part 2 of the label s for the 4 lb ai /gal EC and SL

formulations , the use directions should be revised to indicate that ap plications are to be directed toward the base of the plants.  The proposed use directions for the 5% WP formulation must be revised to specify a maximum of two foliar applications per season at 0.1 lb ai/A/application and to reflect the following maximum se asonal rate: “ Do not exceed the equivalent of 1.8 lb ai/A per crop of soil - applied and 0.2 lb ai/A per crop of foliar - applied mefenoxam - containing products for a maximum seasonal application rate of 2.0 lb ai/A. ”  For all three products , bromberre must be corrected to brombeere and nectaberry must be corrected to nectarberry .  No spray

adjuvants were used in the submitted crop field trials on caneberries. Therefore, the product label for foliar applications for all three products must be amended to specify that no adjuvants may

be added to spray

mixtures for foliar use on caneberries. If the petitioner wishes to support the proposed maximum seasonal rate of 3.6 lb ai/A for soil and foliar applications to caneberries, crop field trial data reflecting that u se pattern must be submitted. HED notes that the accepted labels for the 4 lb ai/gal EC and SL formulations include use directions for raspberries reflecting postemergence use at 0.125 lb ai/A/application in the spring and in the fall after harvest with a 45 - day PHI . This use is supported by the established tolerance for metalaxyl residues in/on raspberries at 0.5 ppm.Mefenoxam Summary of Analytic al Chemistry and Residue Data DP#: 371307

Page 19 of 49 Bushberr ies : P reviously

reviewed crop field trial data for metalaxyl on blueberry will support the proposed expanded use of the 4 lb ai / gal EC and SLformulations on the bushberries listed in Table 3 , except as noted below . The accepted labels for the 4 lb ai /gal EC and SL formulations include separate use directions for lingonberries that are similar to the registered use on blueberries. The following changes to the use directions are recommended.  The following berries are not members of the bushberry subgroup 13 - 07B and must be removed from the crops listed under the bushberry subgroup: bilberry , bearberry , cloudberry , muntries, and partridgeberry .  To clarify

the use pattern for established plantings specified in Part 2 of the label s for the 4 lb ai /gal EC and SL

formulations , the use directions should be revised to indicate that applications are to be directed toward the base of the pl ants.  For both products, hostaberry must be corrected to jostaberry .  When the proposed use on bushberries is registered for the 4 lb ai /gal EC and SL formulations, the separate use directions for lingonberries may be removed from the labels. B ilberry , be arberry , cloudberry , muntries, and partridgeberry are members of crop subgroup 13 - 07G (lowgrowing berry

) or 13 - 07H (lowgrowing berry subgroup, except strawberry ). To support the proposed use patterns for the 4 lb ai /gal EC and SL on these berries, additio nal crop field trial data would be required reflecting application to the representative commodities of strawberry (for subgroup 13 - 07G) or cranberry (for subgroup 13 - 07H). Although the accepted labels for the 4 lb ai /gal EC and SL formulations include us e directions for cranberry and strawberry , the use directions are more restrictive than the proposed use pattern for bushberries : maximum seasonal rate of 2.65 lb ai/A and 45 - day PHIfor cranberry , and maximum seasonal rate of 1.5 lb ai/A for strawberry . 860.1300 Nature of the Residue - Plants Residue Chemistry Memo No DP#, 2/14/07, W. Britton (RARC Report) Residue Chemistry Memo DP# 269910, 10/27/00, N. Dodd, A. Low it, and M. Bonner (MARC Decision) Residue Chemistry Memo DP# 268454, 10/17/00, N. Dodd, A . Low it, and M. Bonner (Issues to be presented to MARC) The nature of the residue in plants is adequately understood for mefenoxam, based on metalaxyl metabolism studies on potato, grape, and lettuce . The data indicate that metalaxyl is taken up, transl ocated, and extensively metabolized by

plants. Metabolism involves oxidation of a ring methyl group to the alcohol and then the carboxylic acid, hydroxylation of the phenyl group, hy droly sis of the methyl ester and methyl ether bonds, and N - dealkylation. Metabolites can be separated into four classes: (1) those containing a 2,6 - DMA moiety ; (2) those containing an HMMA moiety ; (3) those containing a Ring - OH moiety ; and (4) those containing a benzoic acid moiety . HED originally

concluded that the mefeno xam residues to be regulated for the tolerance expression and for dietary assessments would be (

R ) - and ( S

) - 2 - [(2,6 - dimethylphenyl) - methoxy acetylamino] - propionic acid methyl ester, its metabolites containing the 2,6 - DMA moiety , and CGA - 94689 , each expressed as mefenoxam equivalents.Mefenoxam Summary of Analytic al Chemistry and Residue Data DP#: 371307

Page 20 of 49 The HED Risk Assessment Review Committee (RARC) subsequently determined (report dated 2/14/07) that: (1) the residue to be regulated (in the tolerance expression ) in plant and livestock commodities is (

R ) - and ( S

) - 2 - [(2,6 - dimethylphenyl) - methoxy acetylamino] - propionic acid methyl ester ; (2) the current/reassessed tolerance levels should be retained; (3) for risk assessment, the residues of concern in plant and live stock commodities are metalaxyl/mefenoxam, its metabolites containing the 2,6 - DMA moiety , its metabolites containing the HMMA moiety , its metabolites containing the Ring - OH moiety , and its metabolites containing the benzoic acid moiety ; and (4) the availab le residue chemistry data can be used and factors may

be employ ed to estimate the total residues of concer n in dietary

risk assessments. Inconnection with registration review of mefenoxam (DP#368461, N. Dodd, 4/13/10) , HED r ecommend ed for modification of the tolerance expression for mefenoxam (40 CFR §180.546) according to the new compliance/measurement policy ( Interim Guidance on Tolerance Expressions , Steve Knizner, May 27, 2009 ) as follows: Tolerances are established for residues of mefenoxam, incl uding its metabolites and degradates, in or on the commodities in the table below. Compliance with the tolerance levels specified below is to be determined by measuring only metalaxyl [methyl N - (2,6 - dimethylphenyl) - N

- (methoxy acetyl) -D

L - alaninate]. 860.13 00 Nature of the Residue - Livestock There are no livestock feedstuffs associated with the proposed use s on bulb vegetables, spinach, snap beans/edible - podded beans, caneberries, and bushberries. Therefore, data requirements for livestock metabolism are not relevant to this tolerance petition. 860.1340 Residue Analytical Methods Residue Chemistry Memo DP# 333767, 3/7/07, B. Cropp - Kohlligian Residue Chemistry Memo No DP#, 2/14/07, W. Britton (RARC Report) Residue Chemistry Memo DP# 274194, 4/20/01, N. Do dd Residue Chemistry Memo DP# 269910, 10/27/00, N. Dodd, A. Low it, and M. Bonner (MARC Decision) Residue Chemistry Memo DP# 268454, 10/17/00, N. Dodd, A. Low it, and M. Bonner (Issues to be presented to MARC) The residue analy

tical methods available for e nforcement of tolerances in crop commodities are common moiety

methods which determine residues of metalaxyl/mefenoxam and metabolites that are convertible to 2,6 - DMA. These methods include: (1) Method I in PAM , Vol. I I (Method AG - 348) which determines r esidues in plant commodities using GL C/AFI D; and (2) Method AG - 395 (sent to FDA for inclusion in PAM , Vol. I I as Method I II), an improved version of Method AG - 348, which determines residues in plant commodities using GL C/NPD. Neither Method AG - 348 nor M ethod AG - 395 distinguish between the R - and S - enantiomers of metalaxyl/mefenoxam; however, a c hiral L C/MS method, Method 456 - 98 , for the enantioselective determination of the D - and L - enantiomers of metalaxyl in crops has been adequately

validated by

ACB/B EAD , and a revised version of the method has been submitted for inclusion in PAM , Vol. I I.Mefenoxam Summary of Analytic al Chemistry and Residue Data DP#: 371307

Page 21 of 49 HED has determined that the 2,6 - DMA common moiety residue analy

tical methods available for tolerance enforcement and used for data collection will not adequately recover all of the metalaxyl/mefenoxam residues of concern in the current tolerance expressions. While these methods are adequate to recover residues of metalaxyl/mefenoxam per se, they will not adequately

recover metabolites containing the HMMA moiety an d may not adequately

recover all metabolites containing the 2,6 - DMA moiety with the certainty

needed to set legal limits , nor are they likely to recover metabolites containing the Ring - OH moiety or the benzoic acid moiety . As a result, in addition to the changes to the tolerance expression and the residues of concern for risk assessment addressed above, the HED RARC determined that: 1) the multiresidue method PAM , Vol. ISection 302 (Protocol D), which completely recovers metalaxyl/mefenoxam per se (>80% according to FDA PESTDATA) is an adequate enforcement method for the determination of metalaxyl/mefenoxam per se in plant and livestock commodities; and (2) all future metalaxyl/mefenoxam magnitude of the residue data should include (a) analy sis for residu es of parent only

using the multiresidue method PAM , Vol. ISection 302 (Protocol D) in order to establish more appropriate tolerance levels; and (b) analy sis with a 2,6 - DMA common moiety method and recovery

data for parent, CGA - 62826, and CGA - 94689 in ord er to refine dietary risk assessments. Data collection methods: Samples of snap bean and caneberries from the crop field trial studies included in this petition were analy zed for residues of mefenoxam per se using Method 456 - 98 with minor modifications. Samples of spinach, and selected samples of snap bean and caneberries were analy

zed for combined residues of mefenoxam, metalaxyl , and metabolites convertible to 2,6 - DMA using a GC/MS metho d, defined by working method number s YARL 0601A (caneberry

) , - 0601C (snap bean), and - 0601D (spinach) which was derived, with minor modifications, from Method AG - 395. The modifications included minor changes in equipment and glassware, modification of the solid - phase extraction ( SPE ) clean - up procedure to remove the use of trifluoroacetic acid for derivatization, and MS instead of NPD . For Method 456 - 98, samples were extracted with methanol:water (80:20, v:v) at reflux, then filtered and applied to a C1 8 SPE cartridge to remove co - extractives. The purified extract was reduced to aqueous, acidified with 0.10 N HCl, diluted with water, and partitioned with dichloromethane (DCM). The DCM phase was cleaned up on a silica SPE cartridge, using ethyl acetate in hexane (40% v:v) to elute residues . The extract was evaporated to dry ness, reconstituted in mobile phase, and filtered for analy sis by chiral reverse - phase LC/MS. The LLM V was 0.05 ppm for snap bean and caneberr ies . For Method YARL - 0601A, C, and D, samples were extracted with methanol:water (80:20, v:v) at reflux, then filtered. An aliquot was reduced to dry ness, redissolved in water, and combined with methanesulfonic acid, then refluxed to produce 2,6 - DMA. Water, hexane, and 25% NaOH were added, and the mixture was subjected to reflux/steam distillation. The resulting hexane phase was collected and applied to a silica SPE cartridge , using DCM to elute residues. The DCM phase was reduced to near dry ness and reconstituted in DCM for analy sis by GC/ MS. Residues were converted to mefenoxam equivalents using a molecular weight conversion factor of 2.305. The LLM V s w ere 0.1 ppm for spinach and 0.05 ppm for snap bean and caneberries.Mefenoxam Summary of Analytic al Chemistry and Residue Data DP#: 371307

Page 22 of 49 The data collection methods were adequate for data collection based on acceptable method validation and concurrent recovery data. Fortification levels were adequate to bracket residues found in treated samples. Conclusions . The available and submitted residue analy tical methods data are adequate to satisfy data requirements f

or this petition. A dequate methodology is available for tolerance enforcement purposes for the residue of concern in crop commodities, mefenoxam per se , as determined by

the RARC. These methods include Method 456 - 98 and PAM multiresidue method Protocol D . Samples of crop commodities from the submitted crop field trials were analy zed for residues of mefenoxam per se and for combined residues of mefenoxam, metalaxyl, and metabolites convertible to 2,6 - DMA using adequate data collection methods. HED note s that although samples from the submitted crop field trials were analy zed using a 2,6 - DMA common moiety

method, recovery

data were provided for parent only ; no recovery data were provided for metabolites CGA - 62826, and CGA - 9 4689 as required in the RARC decision to refine dietary

risk assessment s. HED note s that the method used for determination of residues of mefenoxam per se in snap beans and caneberries did not include determination of the L - enantiomer, which is included i n the tolerance expression. However, the ratio of D - enantiomer to L - enantiomer in mefenoxam products is >90% (DP# 223261, 4/24/94, L . Kutney ) . Therefore, the lack of analy sis for the L enantiomer would not significantly affect the residue results for sna p bean and caneberry . The petitioner should note for future submissions that the tolerance expression for mefenoxam includes the L - enantiomer, and therefore, as stated above, analy tical methods should include determination of both the D - and L - enantiomers. 860.1360 Multiresidue Methods Residue Chemistry Memo No DP#, 2/14/07, W. Britton (RARC Report) Residue Chemistry Memo DP# 268454, 10/17/00, N. Dodd, A. Low it, and M. Bonner (Issues to be presented to MARC) The FDA PESTDATA database (dated 06/05) indicates that metalaxyl is completely recovered (>80%) using the multiresidue method in PAM , Vol. I , Section 302 (Protocol D) , but is not recovered using Sections 303 and 304 (Protocols E and F). In addition, metabolite CGA - 100255 was found to have small, variable recovery (37 - 146%) using Section 302. Metabolite CGA 37734 was completely

recovered using Section 302 but was not recovered using Sections 303 and 304. Metabolites CGA - 94689A and 94689B had small, variable recovery (39 - 108%) using Section 302 but were not recovered using Sections 303 and 304. Metabolite CGA - 62826 was not recovered through any

of the protocols. The HED RARC previously determined that the multiresidue method PAM , Vol. ISection 302 (Protocol D), which completely recovers metalaxyl/mefenoxam per se (>80% according to FDA PESTDATA) is an adequate enforcement method for the determination of metalaxyl/mefenoxam per se in plant and livestock commodities.Mefenoxam Summary of Analytic al Chemistry and Residue Data DP#: 371307

Page 23 of 49 860.1380 Stor age Stability Residue Chemistry Memo DP# 223261, 4/23 /96 , L. Kutney Storage stability

data are available for metalaxyl indicating that weathered residues of metalaxyl and metabolites are stable in spinach stored frozen ( - 20 oC) for up to 39 months ( MRI D 4 3446901, DP # 223261 , L . Kutney , 4/23/96 ). C oncurrent storage stability stud ies were conducted to support the storage intervals and conditions of samples from the submitted snap bean and caneberry field trials ; samples were fortified with mefenoxam per se . The data demonstrate that for samples analy zed for residues of mefenoxam per se , residues were stable during frozen storage for u p to 609 day s (20.0 months) for snap bean and 296 day s (9.7 months) for caneberr y , and that for samples analy zed for combined residues of mefenoxam/metalaxyl and metabolites convertible to 2,6 - DMA , residues were stable for up to 1716 day s (56.4 months) for snap bean and 1360 day s (44.7 months) for caneberry . No 0 - day

data were provided in the concurrent storage stability stud ie s ; storage stability studies should alway s include a 0 - day sampling interval to establish the residue levels present at the time samples are placed into storage [see OPPTS 860.1380(d)(6)(i)]. The storage intervals and conditions of samples from the field trials submitted in association with the subject petition are presented in Table 4. Table 4. Summary of Storage Conditions and Durations of Sam ples fromCrop Field Trial Studies Matrix Storage Tem perature (°C) Actual Storage

Duration (months) Interv al of Demonstrated Storage Stability (months) Spinach ≤ - 12 909 - 1168 days (29.9 - 38.4 months) Adequate storage stability data are available

demonstrating that c om

bined residues of metalaxyl and metabolites are stable for up to 39 mo nths in/on spinach. Sn ap Bean (Original analysis: Method 456 - 98) ≤ - 12 479 - 655 days (15.8 - 21.5 months) Concurrent storage stability data indicate that

residues of mefenoxam per se are stable for up to 609 days (20 months) . Snap Bean (Reanalysis: Method YARL - 0601C) ≤ - 12 1573 - 1 595 days (51.7 - 52.5 months) Concurrent storage stability data indicate that

residues of mefenoxam per se , determined as combined residues of metalaxyl, mefenoxam, and metabolites convertible to 2,6 - DMA , are stable for up to 1716 (56 months) . Caneberries (Original analysis: Method 456 - 98) ≤ - 12 133 - 182 days (4.4 - 6.0 months) Concurrent storage stability data indicate that

residues of mefenoxam per se are stable for up to 296 days (9.7 months) . Caneberries (Reanalysis: Method YARL - 0601A) ≤ - 12 1387 - 1402 days (45.6 - 46.1 months) Concurrent st orage stability data indicate that

residues of mefenoxam per se, determined as combined residues of metalaxyl, mefenoxam, and metabolites convertible to 2,6 - DMA, are stable for up to 1360 days (44.7 months) . Conclusions . The available storage stability data for spinach and the submitted concurrent storage stability

data for snap beans and caneberries are adequate to support the submitted cropMefenoxam Summary of Analytic al Chemistry and Residue Data DP#: 371307

Page 24 of 49 field trials. The data indicate that there are no storage stability issues , and no corrections for decline on s torage are needed. 860.1400 Water, Fish, and Irrigated Crops This guideline topic is not relevant to the proposed use s . 860.1460 Food Handling This guideline topic is not relevant to the proposed use s . 860.1480 Meat, Milk, Poultry, and Eggs There are no livestock feedstuffs associated with the proposed use s on bulb vegetables, spinach, snap beans/edible - podded beans, caneberries, and bushberries. Therefore, data requirements pertaining to meat, milk, poultry , and eggs are not relevant to this toler ance petition. 860.1500 Crop Field Trials DER References: 47803101.der .doc ( S nap bean ; includes review of MRID 47803102 )

47803103.der .doc ( C aneberr ies; includes review of MRID 47803104 ) 47803105.der .doc ( S pinach) Residue Chemistry Memo DP # 223261, 4/24 /96, L. Kutney Residue Chemistry RED Chapter, DP# 197037, 6/16/ 9 4, S. Hummel HED has concluded ( DP# 223261) that the established tolerances for metalaxyl will be adequate to support the use of mefenoxam on the same crops provided that ( 1 ) the use rates fo r mefenoxam are one - half the rate of metalaxyl; ( 2 ) mefenoxam applications are made in the same way as for metalaxyl; and ( 3 ) the labels restrict the use of both pesticides concurrently on the same crop. Onion, bulb, subgroup 3 - 07A and onion, green, sub group 3 - 07B IR - 4 is proposing to expand the registered use of mefenoxam on bulb and green onions to support the new bulb onion subgroup 3 - 07A and the green onion subgroup 3 - 07B. Bulb onion is the representative commodity of the bulb onion subgroup , and g reen onion is the representative commodity

of the green onion subgroup . No residue data were provided in support of the proposed expanded use. The registered use of mefenoxam on bulb and green onions is supported by crop field trial data for metalaxyl o n these crops , reflecting a variety of use patterns, which were summarized in the Metalaxyl Registration Standard dated 6/22/87. For bulb onion, the use patterns tested included preemergence soil application of an EC formulation at 2 lb ai/A followed by f ive foliar applications of a WP formulation at 0.2 lb ai/A/application for a maximum seasonal rate of 3.0 lb ai/A; PHI s ranged 7 - 34 day s. For green onion, the use patterns tested included preemergence soil application of an EC formulation at 2 lb ai/A fol lowed by three or four foliar applications of a WP formulation at 0.2 lb ai/A/application for maximum seasonal rates of 2.6 or 2.8 lb ai/A; PHI s ranged 7 - 14 day s. The available data were re - assessed for the Residue Chemistry Chapter of the Metalaxyl REDMefenoxam Summary of Analytic al Chemistry and Residue Data DP#: 371307

Page 25 of 49 w here it was concluded that no additional data were needed for dry bulb or green onion . T olerance s of 3 .0 and 10.0 ppm are established for meta la xyl on bulb and green onion, respectively . As specified in DP# 223261, the use rates for mefenoxam are one - hal f the rate of metalaxyl , and mefenoxam applications are made in the same way as for metalaxyl ; therefore, the data for metalaxyl are adequate to support the proposed use of mefenoxam. Conclusions . The proposed /registered use of mefenoxam on bulb and gree n onion is supported by adequate crop field trial data for metalaxyl . Minor r evisions to the EC, SL , and WP labels must be made as requested under Section 860.1200. Because bulb onion is the representative commodity

of the bulb onion subgroup, and green onion is the representative commodity of the green onion subgroup , HED has no objections to expanding the registered use to cover the members of the crop subgroup s . The available data for bulb and green onion will support tolerance s of 3.0 ppm for onion, bulb subgroup 3 - 07A, and 10 ppm for the onion, green, subgroup 3 - 07B , respectively . Spinach Under PP#9E7591, I R - 4 is proposing to reduce the established PHIfor use of mefenoxam on spinach from 21 day s to 3 day s. In conjunction with this request, I R - 4 has submitted revised use directions for the 4 lb ai /gal EC and the SLformulation s indicating that they wish to expand the registered foliar uses on head and leaf lettuce for one or both products to include all members of the leafy vegetables crop group. Insupport of the reduced PHIfor spinach, IR - 4 submitted field trial data for mefenoxam on spinach. Nine spinach field trials were conducted in Zones 1 (NY; 1 trial), 2 (MD and NJ; 3 trials), 6 (TX; 2 trials), 8 (CO; 1 trial), and 10 (CA; 2 trials) during 2004. At each test site, one untreated and one treated plot were established. Each treated plot received an initial s oil surface spray application of a 4 lb ai /gal EC formulation made at planting at ~1.0 lb ai/A. Seed was planted immediately be fore or following application on the same day , except at the two CA sites and the CO and NJ sites, where seed was planted the day before application. The at - planting application was followed by two foliar directed or broadcast spray applications of a 5% W P formulation made at ~0.125 lb ai/A/application, for a total seasonal rate of ~1.25 lb ai/A ( 1 x the maximum proposed seasonal application rate for this formulation on spinach) . The first foliar application was made 25 - 60 day s after the soil application, and the second foliar application was made 12 - 15 day s after the first foliar application. All applications were made using ground equipment in spray volumes of 29 - 64 gal/A; no adjuvants were used. Samples of mature spinach leaves were collected 2 - 4 day s following the final application. Samples were analy

zed using an adequate GC/MS method that determines combined residues of mefenoxam, metalaxyl, and metabolites convertible to the 2,6 - DMA moiety as 2,6 - DMA. The LLM V was 0.10 ppm. Sample storage interv als and conditions are reported in Table 4. Adequate storage stability data are available to support the crop field trials. The results of the spinach field trials are presented in Table 5 . Following one at - planting soil application of the 4 lb ai /gal E C formulation at 0.97 - 1.0 lb ai/A and two broadcast foliarMefenoxam Summary of Analytic al Chemistry and Residue Data DP#: 371307

Page 26 of 49 applications of the 5% WP at 0.122 - 0.127 lb ai/A/application for total application rates of 1.21 - 1.25 lb ai/A, combined residues of mefenoxam/metalaxyl and metabolites determined as 2,6 - DMA were 1. 47 - 6.19 ppm in/on spinach leaves harvested 2 - 4 day s after application. A residue decline trial was not included in the study . Table 5 . Summary of Residue Data fromField Trials with Mefenoxam . Crop matrix Total Applic.

Rate (lb ai/A) PHI

(days) Residue Levels (ppm) 1

n Min. Max. HAFT 2 Median Mean Std. Dev. SPINACH (proposed use for 5% WP = 1.0 lb ai/A soil + 0.25 lb ai/A foliar for 1.25 lb ai/A total application rate; 3 - day PHI ; proposed use for 4 lb ai/ gal EC and SL = 1.0 lb ai/A soil + 0.4 lb ai/A foliar for 1. 4 lb ai/A total application rate; 3 - day PHI ) Spinach leaves 1.21 - 1.25 2 - 4 18 1.47 6.19 5.85 3.07 3.26 1.34 1 Combined residues of mefenoxam, metalaxyl, and metabolites convertible to 2,6 - DMA. 2 HAFT = Highest Average Field Trial. The r epresentative crops for the l eafy vegetables (except Brassica vegetables) crop g roup are celery , head lettuce, leaf lettuce, and spinach. Conclusions. The submitted field trial residue data for spinach are adequate to support a reduction in PHIto 3 days for spinach treated with a s oil application of the EC or SL formulation followed by

foliar application of the WP formulation. The submitted crop field trial data will support a reduction in PHIfor spinach treated with this combination of products only . A dditional field trial data reflecting foliar application of EC and SLformulations to spinach with a 3 - day PHIwould be required to support a reduction in PHI for the proposed foliar uses of the 4 lb ai/gal EC and SL

formulations on spinach. Based on current Agency policy , data for the W P formulation cannot support EC or SL foliar applications with short PHI s , and EC data cannot be translated to SL for foliar applications with short PHI s . T he reviewer could not find any data for metalaxyl/mefenoxam su pporting foliar application of an SL fo rmulation on leafy

vegetables. Inthe absence of supporting crop field trial data, HED recommends against expanding the registered foliar uses of the 4 lb ai/gal EC and SL formulations on head and leaf lettuce to inc lude spinach or any

other members of the leafy vegetables ( except Brassica vegetables) crop group. To expand the registered foliar uses of the 4 lb ai/gal EC and SL formulations on head and leaf lettuce to include all members of the leafy vegetables (exce pt Brassica vegetables) crop group, data reflecting foliar uses of the EC and SL formulations on spinach and celery reflecting the proposed use rate and PHI must be submitted or referenced. If spinach is to have a 3 - day PHI while the others in the crop gr oup have a 7 - day PHI , spinach would have to be excluded from the crop group tolerance and have its own tolerance. T he number and location of field trials are in accordance with OPPTS Guideline 860.1500 for spinach . HED notes that one trial was conducted in Zone 8 instead of Zone 9, but the trial was located near the border between the two zones. Samples were analy zed for combined residues of mefenoxam and metabolites convertible to 2,6 - DMA using an acceptable method, and adequate storage stability

data are available to support the study .Mefenoxam Summary of Analytic al Chemistry and Residue Data DP#: 371307

Page 27 of 49 Although no residue decline data were included in the submission, adequate residue decline data are available for mefenoxam and metalaxyl to support the submitted study . Previously reviewed data indicate that residues o f mefenoxam/metalaxyl declined or did not increase with increasing sampling interval in: (1) basil harvested at 7, 14, and 21 day s (DP#s 257785 and 266898, 4/20/01, N. Dodd); (2) broccoli, cauliflower, and cabbage harvested at 7 and 14 day s ( P P# 2F04072 , 1/15/93, M. Peters); and (3) lettuce harvested at 4 - 5, 7, and 14 day s (DP# 156811, 6/21/91, S. Bacchus). The submitted field trial data , reflecting combined residues of mefenoxam/metalaxyl and metabolites convertible to 2,6 - DMA, w ould support a tolerance of 8.0 p pm and a reduced PHI of 3 day s for spinach treated with a soil application of the EC or SL formulation followed by

foliar application of the WP formulation . ( Refer to Appendix I I for the tolerance calculation .) However, b ecause the submitted dat a are not representative of all registered uses of mefenoxam on spinach (see , for example , the 2.5% granular formulation; EPA Reg. No. 100 - 798), HED recommends against establishing a reduced tolerance for mefenoxam on spinach. The existing tolerance of 10 ppm for spinach, established under 40 CFR §180.408, is appropriate. Snap bean IR - 4 submitted field trial data for mefenoxam on snap beans. Eight field trials were conducted in Zones 1 (NY; 1 trial), 2 (MD; 1 trial), 3 (FL ; 1 trial), 5 (WI ; 3 trials), 10 (CA; 1 trial), and 11 (WA; 1 trial) during 2002. At each test site, one untreated and one treated plot were established. Each treated plot received an initial s oil surface spray application of a 4 lb ai /gal EC formulation made at planting at ~0.50 lb ai/A; seed was planted immediately following application on the same day . The at - planting application was followed by two foliar directed or broadcast spray applications of a 5% WP formulation made at ~0.10 lb ai/A/application, for a total seasonal rate of ~0.70 lb ai/A (~ 0.8 x the maximum seasonal application rate of 0.90 lb ai/A for snap bean based on registered soil and proposed foliar application ) . The first foliar application was made 45 - 79 day s after the soil application, and the second foliar appl ication was made 7 - 8 day s after the first foliar application. All applications were made using ground equipment in spray volumes of 30 - 57 gal/A; no adjuvants were used. Samples of snap beans were collected from each test site at commercial maturity , 6 - 7 day s after the final application. At two sites, additional samples were collected 0 and 13 - 14 day s after final application to assess residue decline. Samples from the snap bean field trials were initially analy zed for residues of mefenoxam per se using an adequate chiral LC/MS method. Samples from the CA trial, including decline samples, were subsequently

reanaly zed using an adequate GC/MS method that determine d combined residues of mefenoxam, metalaxyl, and metabolites convertible to the 2,6 - DMA moiety as 2,6 - DMA. The L LM V was 0.05 ppm for both methods. Sample storage intervals and conditions are reported in Table 4. Adequate concurrent storage stability data were submitted to support the crop field trials. The study results, reflecting the origin al analy sis for mefenoxam only and re - analy sis of the CA field trial samples for parent + metabolites, were presented to ChemSAC with a request to use conversion factors calculated by dividing the residues obtained on re - analy sis of the CA fieldMefenoxam Summary of Analytic al Chemistry and Residue Data DP#: 371307

Page 28 of 49 trial samp les by

the original values to calculate residues in the remaining field trial samples for setting residue values for the risk assessment . The calculated conversion factors are: 1x for 0 - day PHI , 1.8x for the 6 - to 7 - day PHI , and 3x for the 13 - to 14 - day PHI . ChemSAC agreed (see minutes of 2/25/09 meeting) that parent + metabolites to parent ratios could be used to estimate residue levels for risk assessments in snap beans, with the provision that these ratios would not necessarily

be correct/adequate for these commodities for future risk assessments if refinements were necessary . The results of the s nap bean field trials are presented in Table 6 . Following one at - planting soil application of the 4 lb ai/ gal EC formulation at 0.48 - 0.51 lb ai/A and two br oadcast foliar applications of the 5% WP at 0.10 lb ai/A/application for total application rates of 0.68 - 0.71 lb ai/A, residues of mefenoxam per se were <0.05 - 0.168 ppm in/on snap beans harvested at a 13 - to 14 - day PHI . Following re - analy sis of samples fr om the CA trial, and recalculation of residues in samples from the remaining field trials based on the results of the CA trials, combined residues of mefenoxam/metalaxyl and metabolites determined as 2,6 - DMA were estimated to be <0.05 - 0.282 ppm. The res idue decline data from the CA trial indicate that residues of mefenoxam generally declined with increasing PHI . Because residues were <LLMV in/on all samples from the WI decline trial, residue decline could not be assessed. Table 6 . Summary of Residue D ata fromField Trials with Mefenoxam . Crop matrix 1 Total Applic.

Rate (lb ai/A) PHI

(days) Residue Levels (ppm)

n Min. Max. HAFT 2 Median Mean Std. Dev. SNAP BEAN (proposed use = 0.4 lb ai/A total application rate foliar only; 6 - day PHI) ( proposed + registered use = 0.5 lb ai/A soil + 0.4 lb ai/A foliar for 0.9 lb ai/A total application rate ) Mefenoxam per se Snap Bean (Original analysis) 0.68 - 0.71 6 - 7 16 <0.05 0.168 0.137 0.05 0.061 0.032 Combined residues of mefenoxam/metalaxyl and metabolites co nvertible to 2,6 - DMA Snap Bean (Reanalysis/ calculation) 0.68 - 0.71 6 - 7 16 <0.05 0.282 0.246 0.05 0.075 0.068

1 Original analysis: samples were originally analyzed for residues of mefenoxam per se . Reanalysis/calculation: samples from the CA site were re - analyzed for combined residues of mefenoxam/metalaxyl and metabolites convertible to 2,6 - DMA; for all other trials, the original residue results were corrected using a conversion factor of 1.8x. 2 HAFT = Highest Average Field Trial. Conclusions. The submitted field trial residue data for snap bean are adequate. Provided the label is amended as indicated in OPPTS 860.1200 to specify a maximum of two foliar applications , a maximum seasonal application rate o f 0.50 lb ai/A for soil applications + 0.2 l b ai/A for foliar applications, and a 7 - day PHI , the study adequately reflect s the proposed use pattern for snap bean , and the number and location of field trials are in accordance with OPPTS Guideline 860.1500. Samples were initially analy zed for residue s of mefenoxam per se using an acceptable method, and selected samples were re - analy zed for combined residues of mefenoxam/metalaxyl and metabolites convertible to 2,6 - DMA using an acceptable method . Calculation of combined residues in remaining crop samp les using a 1.8x conversion factor wasMefenoxam Summary of Analytic al Chemistry and Residue Data DP#: 371307

Page 29 of 49 approved by

ChemSAC. A dequate concurrent storage stability data were submitted to support the study . The submitted field trial data , reflecting residues of mefenoxam per se , will support the proposed tolerance of 0. 20 ppm for snap bean . Caneberry

subgroup 13 - 07A IR - 4 submitted field trial data for mefenoxam on blackberries and raspberries, the representative commodities of caneberry subgroup 13 - 07A. Six caneberry field trials were conducted in the U.S. in Zones 2 (NC and NJ; 2 trials), 10 (CA; 2 trials), 11 (WA; 1 trial), and 12 (WA; 1 trial) during 2002. Two trials were conducted using blackberry varieties (blackberry

and boy senberry

), and four trials were conducted using raspberry varieties (red and black). A t each test site, one untreated and one treated plot were established. Each treated plot received an initial s oil surface spray application, directed toward the base of the plants, of a 4 lb ai /gal EC formulation made at flowering to early fruiting at ~1. 8 lb ai/A. The soil application was followed by two foliar directed spray applications of a 5% WP formulation made at ~0.10 lb ai/A/application to plants bearing fruit, for a total seasonal rate of ~2.0 lb ai/A (0.6x the maximum proposed seasonal applicat ion rate for caneberries). The first foliar application was made 35 - 45 day s after the soil application, and the second foliar application was made 6 - 7 day s after the first foliar application. All applications were made using ground equipment in spray vol umes of 30 - 101 gal/A; no adjuvants were used . Berry s amples were collected from each test site at commercial maturity , on the day of the final application (0 - day PHI ). Samples from the caneberry field trials were initially

analy zed for residues of mefe noxam per se using an adequate chiral LC/MS method. Samples from the NC and NJ trials and one CA trial (02 - CA27) were subsequently reanaly zed using an adequate GC/MS method that determines combined residues of mefenoxam, metalaxyl, and metabolites convert ible to the 2,6 - DMA moiety as 2,6 - DMA. The L LM V was 0.05 ppm for both methods. Sample storage intervals and conditions are reported in Table 4. Adequate concurrent storage stability data were submitted to support the crop field trials. The study resul ts, reflecting the original analy sis for mefenoxam only and re - analy sis of the NC, NJ, and CA field trial samples for parent + metabolites, were presented to ChemSAC with a request to use a 1.3x conversion factor, calculated by dividing the average residue s obtained on re - analy sis for each of the three trials by the average residues obtained on original analy sis , to calculate residues in the remaining field trial samples for setting residue values for the risk assessment . ChemSAC agreed (see minutes of 2/2 5/09 meeting) that parent + metabolites to parent ratios could be used to estimate residue levels for risk assessments in caneberry , with the provision that these ratios would not necessarily be correct/adequate for these commodities for future risk assess ments if refinements were necessary . The results of the caneberry field trials are presented in Table 7 . Following one soil surface spray application of the 4 lb ai /gal EC formulation at 1.75 - 1.98 lb ai/A and two broadcast foliar applications of the 5% W P at 0.10 lb ai/A/application for total application rates of 1.95 - 2.18 lb ai/A, residues of mefenoxam per se were 0.213 - 0.554 ppm in/on caneberries harvested at a 0 - dayMefenoxam Summary of Analytic al Chemistry and Residue Data DP#: 371307

Page 30 of 49 PHI . Following re - analy sis of samples from the NC, NJ, and one CA trials, and recalcul ation of residues in samples from the remaining field trials based on the reanaly sis results, combined residues of mefenoxam/metalaxyl and metabolites determined as 2,6 - DMA were estimated to be 0.277 - 0.691 ppm. A residue decline trial was not included i n the study . Table 7 . Summary of Residue Data fromField Trials with Mefenoxam . Crop matrix 1 Total Applic.

Rate (lb ai/A) PHI

(days) Residue Levels (ppm)

n Min. Max. HAFT 2 Median Mean Std. Dev. CANEBERRY (proposed use = 3.6 lb ai/A total applicatio n rate , soil + foliar applied ; 0 - day PHI for foliar application ) Mefenoxam per se Caneberries (Original analysis) 1.95 - 2.18 0 12 0.213 0.554 0.527 0.296 0.329 0.106 Combined residues of mefenoxam/metalaxyl and metabolites convertible to 2,6 - DMA Caneberries (Reanalysis/ calculation) 1.95 - 2.18 0 12 0.277 0.691 0.686 0.370 0.412 0.135

1 Original analysis: samples were originally analyzed for residues of mefenoxam per se . Reanalysis/calculation: samples from the NC, NJ, and one CA (02 - CA27) trials were re - analyzed for combined residues of mefenoxam/metalaxyl and metabolites convertible to 2,6 - DMA; for all other trials, the original residue results were corrected using a conversion factor of 1.3x. 2 HAFT = Highest Average Field Trial. Conclusions. Th e submitted field trial residue data for caneberries are not adequate for a permanent registration but will support a conditional registration . The field trial locations are not in accordance with 860.1500 , and no residue decline data were submitted . To fulfill geographic distribution requirements, one additional field trial must be conducted in Zone 5 (raspberry ) or 6 (blackberry

). The required field trial should include additional sampling intervals to assess residue decline. (Note: Three studies wer e conducted in Zones 10, 11, and 12 instead of three studies in Zone 12 as suggested in OPPTS 860.1500 ; however, Bernard Schneider, contacted by Dy namac, indicated that the three trials conducted in Zones 10, 11, and 12 would be sufficient in lieu of three studies in Zone 12 as suggested in OPPTS 860.1500 .) T he proposed use directions for caneberries on the EC, SL, and WP labels must be amended as indicated in OPPTS 860.1200 . Samples were initially

analy zed for residues of mefenoxam per se using an acce ptable method, and selected samples were re - analy zed for combined residues of mefenoxam and metabolites convertible to 2,6 - DMA using an acceptable method. Calculation of combined residues in remaining crop samples using a 1. 3 x conversion factor was approv ed by ChemSAC. A dequate concurrent storage stability data were submitted to support the study . T he submitted field trial data , reflecting residues of mefenoxam per se , will support a tolerance of 0.70 ppm for caneberry subgroup 13 - 07A . Refer to Appendix II for the tolerance calculation.Mefenoxam Summary of Analytic al Chemistry and Residue Data DP#: 371307

Page 31 of 49 Pending submission of the additional required field trial data, the tolerance will be recalculated and a revised tolerance proposal may be needed. Bushberry

subgroup 13 - 07B IR - 4 is proposing to expand the registered us e of mefenoxam on blueberry to support the bushberry subgroup 13 - 07B. Blueberry is the representative commodity of the bushberry subgroup. No residue data were provided in support of the proposed expanded use . The registered use of mefenoxam on blueber

ry is supported by

crop field trial data for metalaxyl on blueberry that were reviewed under PP#7F3470/FAP#7H5520 ( 3/6/87, M. Nelson), reflect ing two soil applications at 3.6 lb ai/A/application for a maximum seasonal rate of 7.2 lb ai/A , with a 0 - day PHI . The available data were re - assessed for the Residue Chemistry Chapter of the Metalaxyl RED which concluded that no additional data were needed for blueberry . A tolerance of 2.0 ppm is established for meta la xyl on blueberry . As specified in DP# 223261, the use rates for mefenoxam are one - half the rate of metalaxyl , and mefenoxam applications are made in the same way as for metalaxyl ; therefore, the data for metalaxyl are adequate to support the proposed use of mefenoxam . Conclusions . The registered use of mefenoxam on blueberry is supported by

a dequate crop field trial data for metalaxyl , and the proposed use pattern for mefenoxam on bushberry subgroup 13 - 07B is identical to the registered use on blueberry . Because b lueberry is the representati ve commo dity

of the bushberry

subg roup , HED has no objections to expanding the registered use to cover the crop subgroup provided the revisions requested under Section 860.1200 to the EC and SLlabels for bushberries are made . The available data for blueberry wil l support a tolerance of 2.0 ppm for the bushberry subgroup 13 - 07B 860.1520 Processed Food and Feed HED does not require residue data for any processed commodities associated with onion, legume vegetables/ spinach, snap beans , caneberries , or bushberries . Therefore, data requirements for processed food and feed are not relevant to this tolerance petition. 860.1650 Submittal of Analytical Reference Standards An analy tical standard for mefenoxam (expiration date of 2/28/2014) is curr ently available in the National Pesticide Standards Repository (personal communication with Dallas Wright, ACB, 12/9/09 ).Mefenoxam Summary of Analytic al Chemistry and Residue Data DP#: 371307

Page 32 of 49 860.1850 Confined Accumulation in Rotational Crops Residue Chemistry Memo No DP#, 2/14/07, W. Britton (RARC Report) Residue Chemis try Memo DP# 269910, 10/27/00, N. Dodd, A. Low it, and M. Bonner (MARC Decision) Residue Chemistry Memo DP# 268454, 10/17/00, N. Dodd, A. Low it, and M. Bonner (Issues to be presented to MARC) The nature of the residue in rotated crops is adequately unders tood for mefenoxam, based on confined rotational crop studies conducted with metalaxy l on lettuce, sugar beet, and wheat . Metabolism of metalaxyl in rotated crops generally proceeds by

the same pathway s as seen in primary crops with the formation of four classes of metabolites: ( 1 ) those containing the 2,6 - DMA moiety ; ( 2 ) those containing the HMMA moiety ; ( 3 ) those containing a Ring - OH moiety ; and ( 4 ) those containing a benzoic acid moiety . The following differences were noted. Two ring - hy droxylated met abolites were detected in rotated lettuce: Metabolite CGA - 100255 accounted for 11% of the TRR in immature lettuce; and a second compound, which would represent an N - dealkylation product of CGA - 100255, designated N1b agly cone, was detected in hy droly sates of aqueous and insoluble fractions, at 16% of the immature lettuce TRR. These compounds were also found in mature lettuce with 8% of the TRR as CGA - 100255 and 11% as N1b agly cone; both were released from glucose conjugates. In rotated wheat grain, the ma jority of the identified residues (35.2% out of 43.0% identified) were metabolites oxidized to benzoic acid metabolites, including CGA - 108905 , which was found at 33.7% TRR. HED previously concluded that the mefenoxam residues in rotational crops to be r egulated for the tolerance expression and for dietary assessments are (

R ) - and ( S

) - 2 - [(2,6 - dimethylphenyl) - methoxy acetylamino] - propionic acid methyl ester, its metabolites containing the 2,6 - DMA moiety , and CGA - 94689 , each expressed as mefenoxam equivalents, except that 2 - [(methoxy acetyl)(2 - methoxy - 1 - methyl - 2 - oxoethyl)amino] - 3 - methylbenzoic acid (CGA - 108905) would also be included in the risk assessment for cereal grain rotational crops and N - (3 - hy droxy 2,6 - dimethylphenyl) - N

- (methoxy acetyl)alanine methyl ester (CGA - 100255) would be included in the risk assessment for leafy vegetable (

Brassica and non - Brassica ) rotational crops . The HED RARC subsequently determined that the residue to be regu lated (in the tolerance expression) in crop commodities is ( R ) - and ( S

) - 2 - [(2,6 - dimethylphenyl) - methoxy acetylamino] - propionic acid methyl ester and that for risk assessment, the residues of concern in crop commodities are metalaxyl/mefenoxam, its metabolit es containing the 2,6 - DMA moiety , its metabolites containing the HMMA moiety , its metabolites containing the Ring - OH moiety , and its metabolites containing the benzoic acid moiety . The RARC further noted that CGA - 100255 and CGA - 108 9 05 need not be included in future dietary risk assessments since there is little likelihood that these metabolites could be recovered by any of the 2,6 - DMA common moiety methods.Mefenoxam Summary of Analytic al Chemistry and Residue Data DP#: 371307

Page 33 of 49 860.1900 Field Accumulation in Rotational Crops Residue Chemistry Memo DP# 333767, 3/7/07, B. Cro pp - Kohlligian. Residue Chemistry Memo No DP#, 2/14/07, W. Britton (RARC Report) Residue Chemistry Memo DP# 276001, 9/13/01, N. Dodd Residue Chemistry Memo DP# 269910, 10/27/00, N. Dodd, A. Low it, and M. Bonner (MARC Decision) Residue Chemistry Memo DP# 268 454, 10/17/00, N. Dodd, A. Low it, and M. Bonner (Issues to be presented to MARC) Residue Chemistry Memo DP#s 203675 and 206108, 10/17/94, S. Hummel F ield rotational crop data for metalaxyl were previously reviewed. Residues were determined in the commod ities of rotational broccoli, cabbage, corn, lettuce, red beets, rye, soy beans, sugar beets, sweet potatoes, and wheat planted following metalaxy l - treated potatoes, tobacco, and wheat (soy

bean was planted after the wheat primary crop). Application rates w ere 3 - 6 lb ai/A for potatoes and tobacco and 1 - 2 lb ai/A for wheat. Plantback intervals ranged from 6 - 12 months, with the exception of winter wheat and ry e , which were planted 1 - 6 weeks after treatment of potatoes and 3 - 19 months after treatment of tobacc o. Combined residues of metalaxyl and metabolites convertible to 2,6 - DMA were determined; recovery data were only

provided for metalaxyl per se . Under the metalaxyl reregistration process, HED concluded (DP#s 203675 and 206108) that the available field rotational crop studies were inadequate but could be upgraded by providing additional recovery

data demonstrating that the enforcement method and the analy tical methods used for the field rotational crop studies w ould detect representative metalaxyl metab olites containing the 2,6 - DMA and HMMA moieties. Additional supporting recovery data for metabolites were submitted and reviewed under DP# 276001 and DP# 333767 , which indicated that the established enforcement method, AG - 395 was not adequate for the dete rmination of residues of metalaxyl/mefenoxam metabolite s CGA - 94689 , CGA - 62826, and P1/P2 in crop commodities . M ethod modifications to improve recoveries for metabolites CGA - 94689 and CGA - 62826 were required . Inconsideration of the RARC recommendations for mefenoxam, no additional data are required to support the metalaxyl field rotational crop studies. The established plantback intervals for mefenoxam on rotated crops are supported by adequate data. HED note s that tolerances for indirect or inadverten t residues of metalaxyl were previously established for a number of cereal grain commodities primarily in support of rotation to cereal grains following potato. 860.1550 Proposed Tolerances Residue Chemistry Memo No DP#, 2/14/07, W. Britton (RARC Repor t) Residue Chemistry Memo 223 261, 4/24/96 , L. Kutney IR - 4 , on behalf of the Agricultural Experiment Stations of CA, FL , OR, and GA, is proposing the establishment of tolerances for residues of the fungicide mefenoxam, ( R ) - and ( S

) - [2,6 - dimethyl(phenyl) - me thoxy acetylamine] - propionic acid methyl ester, and its metabolites containing the 2,6 - dimethylaniline moiety , and N - (2 - hy droxy

methyl - 6 - methylphenyl) - N - (methoxy acetyl) - alanine methyl ester.Mefenoxam Summary of Analytic al Chemistry and Residue Data DP#: 371307

Page 34 of 49 The HED Risk Assessment Review Committee (RARC) has determined th at the residue to be regulated (in the tolerance expression) in plant and livestock commodities is ( R ) - and ( S

) - 2 - [(2,6 - dimethylphenyl) - methoxy acetylamino] - propionic acid methyl ester, and that the current/reassessed tolerance levels should be retained. Inconnection with registration review of metalaxyl/mefenoxam (DP#368461, N. Dodd, 4/13/10), HED r ecommend ed for modification of the tolerance expression s for metalaxyl (40 CFR §180.408) and mefenoxam (40 CFR §180.546) according to the new compliance/meas urement policy ( Interim Guidance on Tolerance Expressions , Steve Knizner, May 27, 2009 ) as follows: Tolerances are established for residues of me talaxyl, including its metabolites and degradates, in or on the commodities in the table below. Compliance w ith the tolerance levels specified below is to be determined by measuring only metalaxyl [methyl N - (2,6 - dimethylphenyl) - N

- (methoxy acetyl) -D

L - alaninate]. Tolerances are established for residues of mefenoxam, including its metabolites and degradates, in or on the commodities in the table below. Compliance with the tolerance levels specified below is to be determined by measuring only metalaxyl [methyl N - (2,6 - dimethylphenyl) - N

- (methoxy acetyl) -D

L - alaninate]. Tolerances for mefenoxam are currently established under 40 CFR §180.546 and are expressed in terms of ( R ) - and ( S

) - 2 - [(2,6 - dimethyl(phenyl) - methoxy acetylamin e ] - propionic acid methyl ester, its metabolites containing the 2,6 - dimethylaniline moiety , and N - (2 - hy droxy

methyl - 6 - methylphenyl) - N

- (methoxy acetyl) - alanine methyl ester, each expressed as mefenoxam equivalents. Tolerances for metalaxyl are currently established under 40 CFR §180.408 and are expressed in terms of the combined residues of the fungicide metalaxyl [ N - (2,6 - dimethylphenyl) - N

- (methoxy acetyl) alanine methylester], and its metabolites containing the 2,6 - dimethylaniline moiety , and N

- (2 - hy droxy

methyl - 6 - methylphenyl) - N - (methoxy acetyl) - alanine methyl ester, each expressed as metalaxyl equivalents. HED previously

concluded ( DP# 223261) that the established tolerances for metalaxyl will be adequate to support the use of mefenoxam on the same crops provided that ( 1 ) the use rates for mefenoxam are one - half the rate of metalaxyl; ( 2 ) mefenoxam applications are made in the same way as for metalaxyl; and ( 3 ) the labels restrict the use of both pesticides concurrently on the same crop. The registered uses for mefenoxam that are relevant to the subject petition are supported by the following metalaxyl tolerances: blueberry at 2.0 ppm, onion, bulb at 3.0 ppm; onion, green at 10.0 ppm; and spinach at 10.0 ppm. In addition, a tolerance on vegetable, legume, group 6 is established at 0.2 ppm, and a tolerance on raspberry is established at 0.5 ppm. Based on the tolerance expression s recommended by the RARC and by HED in the metalaxyl/mefenoxam registration review, and to be consistent with Codex, the toleranceMefenoxam Summary of Analytic al Chemistry and Residue Data DP#: 371307

Page 35 of 49 expression proposed by

I R - 4 under PP#9E7591 must be revised . T he tolerance expression for mefenoxam should be stated as follows: Tolerances are established for residues of mefenoxam, including its metabolites and degradates, in or on the commodities in the table below. Compliance with the tolerance levels specified below is to be determined by measuring only metalaxyl [methyl N - (2,6 - dimethylphen yl ) - N

- (methoxy acetyl) -D

L - alaninate]. HED notes that measuring mefenoxam as metalaxyl would be consistent with Codex. T he proposed and recommended tolerances for the petition are listed in Table 8 . Pending label amendments, a dequate crop field trial data reflecting the proposed use pattern s were submitted for purposes of establishing tolerances on spinach and snap bean . For caneberrie s, an additional field trial conducted in Zone 5 or 6 is required as a condition of registration ; label amendments are a lso needed . The tolerance spreadsheet in the Agency ’s Guidance for Setting Pesticide Tolerances Based on Field Trial Data was utilized in determining appropriate tolerance levels for spinach and caneberries . T he tolerance spreadsheet could not be used to calculate the tolerance for snap bean because ~88 % of residues were <L LM V ; the recommended tolerance for snap bean was based on the maximum observed residues. The submitted data used to determine tolerances for snap bean and caneberries reflected analy si s of samples for mefenoxam per se ; the data for spinach reflected analy sis for combined residues of mefenoxam/metalaxyl and metabolites convertible to 2,6 - DMA. The proposed tolerances for snap bean and the caneberry subgroup are too high; tolerances shoul d be established at 0.20 ppm for snap bean and 0.70 ppm for caneberry subgroup 13 - 07A. The submitted crop field trial data for spinach will support a tolerance of 8.0 ppm for spinach; however, because the submitted data are not representative of all reg istered uses of mefenoxam on spinach (see , for example , the 2.5% granular formulation ; EPA Reg. No. 100 - 798 ) , HED recommends against establishing a reduced tolerance for mefenoxam on spinach. The existing tolerance of 10 ppm for spinach, established under 40 CFR §180.408, is appropriate. A tolerance for metalaxyl residues in/on legume vegetables exists under 40 CFR § 180.408 at 0.2 ppm for combined residues of parent and metabolites convertible to 2,6 - DMA . In I R - 4’s submission, the data for these combin ed residues showed values exceeding 0.2 ppm (maximum value was 0.282 ppm, and this value was an actual residue value, as opposed to a calculated value ) . However, the HED Risk Assessment Review Committee (RARC) determined (report dated 2/14/07) that the re sidue to be regulated (in the tolerance expression) in plant commodities is ( R ) - and ( S

) - 2 - [(2,6 - dimethylphenyl) - methoxy acetylamino] - propionic acid methyl ester. Therefore, a tolerance under 40 CFR §180.546 for residues of mefenoxam in/on snap beans at 0. 20 ppm is appropriate. A tolerance exists under 40 CFR §180.408 for metalaxyl residues in/on raspberry at 0.5 ppm whereas HED is now recommending a tolerance under 40 CFR §180.546 of 0.7 0 ppm on the caneberry subgroup. The metalaxyl tolerance will rema in in 40 CFR § 180.408 to support any uses of metalaxyl on raspberry .Mefenoxam Summary of Analytic al Chemistry and Residue Data DP#: 371307

Page 36 of 49 Adequate crop field trial data for meta la xyl reflecting application according to the proposed use pattern s , but at rates corresponding to twice the maximum proposed single application and seasonal rates for mefenoxam , are available for purposes of establishing tolerances on onions and bushberries. The available data will support establishment of the proposed tolerances for residues of mefenoxam in/on onion, bulb, subgroup 3 - 07A at 3. 0 ppm; onion, green, subgroup 3 - 07B at 10 ppm; and bushberry subgroup 13 - 07B at 2.0 ppm. IR - 4 noted that in conjunction with establishment of the proposed tolerance for the bushberry subgroup, the mefenoxam tolerance for lingonberry can be removed. Codex MRL s, expressed in terms of metalaxyl per se for plant commodities , are established for spinach at 0.1 and onion at 0.03 ppm. Canadian MRL s for mefenoxam (metalaxyl - M) are covered by

MRL s established for metalaxyl, the unresolved isomeric mixture , which are expressed in terms of N

- (2,6 - dimethylphenyl) - N

- (methoxy acetyl) -DL - alanine methyl ester, including metabolites that can be converted to the 2,6 - dimethylaniline moiety , calculated as metalaxyl equivalents. Canadian MRL s are established for spinach at 10 ppm, bulb onion at 3.0 ppm, green onion at 10 ppm, bean at 0.2 ppm, raspberry at 0.2 ppm, and blueberry at 2.0 ppm. No Mexican MRL s are established for mefenoxam or metalaxyl. With the adoption of the tolerance expression recommended by the RARC, the U.S . tolerance expression will be in harmonization with Codex MRL s but not with PMRA MRL s. Table 8 . Tolerance Sum ma ry for Mefenoxam . Commodity Tolerance (ppm) Comments; Correct Commodity Definition Established Proposed Recommended Bean, snap, succule nt -- 0.35 0. 2 0 Caneberry, subgroup 13 - 07A -- 0.80 0.70 Caneberry subgroup 13 - 07A Bushberry subgroup 13 - 07B -- 2.0 2.0 Onion, bulb, subgroup 3 - 07A -- 3.0 3.0 Onion, green, subgroup 3 - 07B -- 10.0 10 Spinach -- 8.0 10 The existing tolerance for sp inach, listed under 40 CFR §180.408, is 10. Lingonberry 2.0 -- Remove Residues on lingonberry will be covered by the tolerance on bushberry subgroup 13 - 07BMefenoxam Summary of Analytic al Chemistry and Residue Data DP#: 371307

Page 37 of 49 References DP#: N/A Subject: PP# 7F3470/FAP# 7H5520/EPA Reg. No. 100 - 607. Metalaxyl in or on

Bl ueberries, Walnuts, Almonds, Almond Hulls, Stone Fruits, Dried Apricots , and Prunes. Evaluation of Analy tical Method and Residue Data. [Accession Nos. 265762, 265763, 265764, 265765.] [CB Nos.: 1676, 1677, 1678.] From: M. Nelson To: L. Rossi and Toxic ology Branch Date: 3/6/87 MRI Ds: 00164649 DP#: 156811 Subject: PP#0F3893 (EPA Reg. Nos. 100 - 607, 100 - 608): Metalaxyl Technical:

(Ridomil® 2E). Tolerance In/On L eafy Vegetables (Excluding Brassica Vegetables, Excluding Spinach). Analy sis of Residue Dat a and Analy tical Method. CBTS #7171. From: S. Bacchus To: R. Chambliss/S. L ewis Date: 6/21/91 MRI Ds: 41587800, 41587801 DP#: N /A Subject: PP# 2F04072: 1. Metalaxyl (Ridomil® 2E Fungicide, EPA Reg. No. 100 - 607) in

or on members of the Brassica (cole) l eafy vegetables crop grouping; evaluation of request for amended registration, analy tical method and residue data of mustard greens. From: M. Peters To: B. Chambliss/S. L ewis Date: 1/15/93 MRI D: 42159801 DP# : 197037 Subject: Metalaxyl (113501) - Case No. 0081. Product and Residue Chemistry Chapters for the Reregistration Eligibility Document (RED). CB No. 12906. From: S. Hummel To: D. Edwards Date: 6/14/94 MRI Ds: NoneMefenoxam Summary of Analytic al Chemistry and Residue Data DP#: 371307

Page 38 of 49 DP#s : 203675 and 206108 Subject: Metalaxyl (113501) - Reregistration Case No. 0081. Addendum to RED Residue

Chemistry

Chapter, Rotational Crop Studies (GL N 165 - 1 and 165 - 2), Supporting Storage Stability

Data. CB Nos. 13740, 14131 From: S. Hummel To: J. L oranger Date: 10/17/94 MRI Ds: 42195401, 42196502, 42196503, 41870308, 43317302 DP# : 223261 Subject: Mefenoxam: Replacement of Metalaxyl Technical with Mefenoxam Technical;

Review of Bridging Data, CBTS No. 16909. PRI ORI TY 6. TOX 375AA, ID #:000100 - TOR PRAT CASE #: 039771 From: L. Kutney To: D. Stubbs and D. McCall Date: 4/2 4 /96 MR ID s: 43800300, 43800301, 43800322, 43800323, 43889801 - 43889803, 43889821,

43896901 - 43896905 DP# : 268454 Subject: Mefenoxam. I ssues to be Presented to the HED Metabolism Assessment Review

Committee. PC Code 113502; Case No. 290692; Submission No. S553336 . From: N. Dodd, A. L owit, and M. Bonner To: G. Kramer Date: 10/17/00 MRI Ds: None DP# : 269910 Subject: Mefenoxam. Metabolism Assessment Review Committee (MARC) Decision

Document for Meeting Held on 10/24/00. Chemical #113502. Case # 290692 . Submission # S553336. From: N. Dodd , A. L owit, and M. Bonner To: G. Kramer Date: 10/27/00 MRI Ds: None DP#s : 257785 and 266898 Subject: PP#9E06005. Mefenoxam (HelixTM) on Herb Subgroup (Crop Subgroup 19 - A)

and Mint. Section 3 Registration and Permanent Tolerance Requ est. Residue Chemistry

Review: Evaluation of Analy tical Method s and Residue Data . From: N. Dodd To: R. Forrest/ S. Brothers Date: 4/20/01 MRI Ds: 44847601, 44847602Mefenoxam Summary of Analytic al Chemistry and Residue Data DP#: 371307

Page 39 of 49 DP# : 274194 Subject: PP#9F05044, 9E06005, and 9E06057. Mefenoxam on Canola, Herb Subgroup

(Crop Subgroup 19 - A), Fresh Mint, and Various Minor or Tropical Fruits. Evaluation of Method Validation Report dated 2/22/01. From: N. Dodd To: S. Brothers/R. Forrest and T. Ellwanger/M. Waller Date: 4/20/01 MRI Ds: None DP# : 276001 Subject: Metalaxyl/Mef enoxam Analy

tical Method Recovery

Data in Plants. From: N. Dodd To: M. Waller/T. Ellwanger Date: 9/13/01 MRI D: 44208107 DP# : 324493 Subject: Mefenoxam. Ridomil GoldTM EC (EPA Reg. No. 100 - 801). Label Amendment

for Cole Crops, Cucurbits, L ettuce and Grape s. From: L. Cheng To: R. Westin/M. Waller Date: 3/17/06 MRI Ds: None DP# : None Subject: Metalaxyl/Mefenoxam. Report of the Risk Assessment Review Committee

(RARC1). From: W. Britton To: B. Cropp - Kohlligian Date: 2/14/07 MRI Ds: None DP# : 333767 Subject: Mefenoxam. Summary of Analy tical Chemistry

and Residue Data. PP#s 5F7018 and 9E6057. From: B. Cropp - Kohlligian To: M. Ottley Date: 3/7/07 MRI Ds: 46714701 - 46714707 DP# : 366407 Subject: Mefenoxam. Amendments for Grapes, L eafy Vegetables except Brassica , and Potatoes. From: N. Dodd To: M. Waller/T. Gibson Date: 11/12/09 MRI Ds: NoneMefenoxam Summary of Analytic al Chemistry and Residue Data DP#: 371307

Page 40 of 49 Attachments: In ternational Residue L imit Status sheet Appendix I - Chemical Name and Structure Table Appendix I I - Tolerance Assessment Calculations Tem plate Version April 2008Mefenoxam Summary of Analytic al Chemistry and Residue Data DP#: 371307

Page 41 of 49 

## INTERNATIONAL RESIDUE LIMIT STATUS Chemical Name: methyl N - (2,6 - dimethylphenyl) -N

- (methoxyacetyl) -D alanin at e Common Name: m efenoxam (metalaxyl - M)  Proposed tolerance  Reevaluated tolerance X Other - Recommended Date: 03/03/1 0 Codex Status (Maximum Residue Limits) U. S. Tolerances  No Codex proposal step 6 or above  No Codex proposal step 6 or above for the crops requested Petition Number: PP#9E7591 DP Barcode: D371307 Other Identifier: Residue definition (step 8/CXL): metalaxyl (plant); sum of metalaxyl and metabolites containing the 2,6 - dimethylaniline moiety, expressed as metalaxyl (livestock). Metalaxyl - M MRLs are at Step 6, pending resolution of the status of metalaxyl CXLs. Reviewer/Branch: RAB3

– Nancy Dodd Residue definition: methyl N - (2,6 - dimethylphenyl) -N

- (methoxyacetyl) -D

L - alanin at e Crop (s) MRL (mg/kg) (Step 6) Crop(s) Tolerance (ppm) Caneberry subgroup 13 - 07A 0. 7 0 Bean, snap, succulent 0. 2 0 Spinach 0.1 (existing CXL 2 for metalaxyl) Spinach Re mains at 10 Bushberry subgroup 13 - 07B 2.0 Lingonberry Remove Onion, bulb 0.03 (existing CXL 2 for metalaxyl) Onion, bulb, subgroup 3 - 07A 3.0 Onion, green, subgroup 3 - 07B 10 Limits for Canada Limits for Mexico 1 X No Limits (metalaxyl MRLs apply)  No Limits for the crops requested X No Limits  No Limits for the crops requested Residue definition: Residues of the resolved isomer metalaxyl - M are covered by MRLs established for metalaxyl, the unresolved isomeric mixture . N - (2,6 - dimethylphenyl) -N

- ( methoxyacetyl) - DL - alanine methyl ester, including metabolites that can be converted to the 2,6 - dimethylaniline moiety, each expressed as metalaxyl equivalents The follow ing are metalaxyl MRLs: Residue definition: N/A A 2004 listing gives numerous crops fo r both metalaxyl and metalaxyl - M, but w ithout tolerance values.

Crop(s) MRL (mg/kg) Crop(s) MRL (mg/kg) Raspberry 0.2 Bean 0.2 Spinach 10Mefenoxam Summary of Analytic al Chemistry and Residue Data DP#: 371307

Page 42 of 49 

## INTERNATIONAL RESIDUE LIMIT STATUS Chemical Name: methyl N - (2,6 - dimethylphenyl) -N

- (methoxyacetyl) -D alanin at e Common Name: m efenoxam (metalaxyl - M)  Proposed tolerance  Reevaluated tolerance X Other - Recommended Date: 03/03/1 0 Blueberry 2 Onion, bulb 3.0 Onion, green 10 Notes/Special Instructions: S. Funk, 03/01/2010. 1 M exico adopts Codex MRLs or US tolerances for its export purposes.Mefenoxam Summary of Analytic al Chemistry and Residue Data DP#: 371307

Page 43 of 49 APPENDIX I. Chem ical Nam es and Structures of Mefenoxam/Metalaxyl and Metabolites. Common name; Company code Chemical name Chemical structure Mefenoxam; CGA - 329351 methyl N - (2,6 - dime thylphenyl) -N

- (methoxyacetyl) -D - alanin at e C H3 N O

C H3 O C H3 C H3 O C H3 O

Metalaxyl; CGA - 48988 methyl N - (2,6 - dimethylphenyl) -N

- (methoxyacetyl) -D

L - alanin at e C H 3 N O

C H 3 O C H 3 C H 3 O O C H 3

CGA - 62826 N - (2,6 - dimethylphenyl) -N

- (methoxyacetyl) alanine C H 3 N O

C H 3 O C H 3 C H 3 O O H

CGA - 94689 N - (2 - hydroxymethyl - 6 - methylphenyl) -N

- (methoxyacetyl) alanine methyl ester N O

C H 3 O C H

3 O O C H 3

O H C H 3

CGA - 108905 2 - [(methoxyacetyl)(2 - methoxy - 1 - methyl - 2 - oxoethyl)amino] - 3 - methylbenzoic acid N O

C H 3 O C H 3 C H 3 O O C H 3 H O O CMefenoxam Summary of Analytic al Chemistry and Residue Data DP#: 371307

Page 44 of 49 APPENDIX I. Chem ical Nam es and Structures of Mefenoxam/Metalaxyl and Metabolites. Common name; Company code Chemical name Chemical structure CGA - 100255 N - (3 - hydroxy - 2,6 - dimethylphenyl) - N - (methoxyacetyl)alanine methyl ester C H 3 N O

C H 3 O C H 3 C H 3 O O C H 3

O HMefenoxam Summary of Analytic al Chemistry and Residue Data DP#: 371307

Page 45 of 49 Appendix II. Tolerance Assessment Calculations. For e ach of the crops listed below, the Guidance for Setting Pesticide Tolerances Based on Field Trial Data ( SOP ) , along with the tolerance spreadsheet (August 2009 version) , was used for calculating recommended tolerances. As specified in the SOP, the minimum of the 95% upper confidence limit (UCL ) on the 95 th percentile and the point estimate of the 99 th percentile was selected as the tolerance value in cases when the dataset was large (greater than 15 samples) and reasonably

lognormal. For datasets that wer e small ( ≤15 samples) and reasonably lognormal, the upper bound estimate of the 95th percentile based on the median residue value was compared to the minimum of the 95% UCL on the 95th percentile and the point estimate of the 99th percentile, and the minimum value was selected as the tolerance value. The rounding procedures specified in the SOP were also used. Caneberry

(crop subgroup 13 - 07A) The dataset used to establish a tolerance for mefenoxam on caneberries consisted of field trial data for blackber

ries and raspberries (the representative crops of subgroup 13 - 07A) representing application rates of ~2.0 lb ai/A (one s oil surface application at ~1.8 lb ai/A and two foliar directed spray

applications at ~0.10 lb ai/A/application) with a 0 - day PHI . Pend ing requested label revisions, the field trial application rates and PHI s are within 25% of the maximum label application rate and minimum label PHI , respectively . The field trial PHI s are within 25% of the minimum label PHI , the field trial application r ate s are lower than the maximum label rate of 3.6 lb ai/A. Because n o field trial data were submitted reflecting the maximum label rate, we have assumed the petitioner intends to support the maximum label rate used in the field trials, 2.0 lb ai/A. The r esidue values that were entered into the tolerance spreadsheet are provided in Table II - 1. All field trial sample results for mefenoxam per se in/on caneberries were above the L LM V (LLMV = 0.05 ppm ). The caneberry dataset contained 12 samples. V isual in spection of the lognormal probability

plot (Figure II - 1 ) and the results from the approximate Shapiro - Francia test statistic (Figure II - 2 ) indicate d that the dataset was reasonably lognormal. Using the tolerance spreadsheet, the recommended tolerance is 0.70 ppm for caneberries. Table II - 1. Residue data used to calculate tolerance for m efenoxamon crop subgroup 13 - 07A. Regulator: EPA Chem ical: Mefenoxam Crop: Caneberry PHI: 0 days App. Rate: 1.95 - 2.18 lb ai/A Submitter: IR - 4 MRID Citation: MRI D 47803103 Residues of m efenoxam per se

0.325 0.359 0.279 0.382Mefenoxam Summary of Analytic al Chemistry and Residue Data DP#: 371307

Page 46 of 49 Table II - 1. Residue data used to calculate tolerance for m efenoxamon crop subgroup 13 - 07A. Regulator: EPA Chem ical: Mefenoxam Crop: Caneberry PHI: 0 days App. Rate: 1.95 - 2.18 lb ai/A Submitter: IR - 4 MRID Citation: MRI D 47803103 Residues of m efenoxam per se

0.242 0.213 0.267 0.233 0.277 0.313 0.499 0.554 Figure II - 1. Lognorm al probability plot of m efenoxamfield trial data for caneberry. 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 y = 0.3032x - 1.1551 R 2 = 0.9473

PercentilesConcentrations EPA Mefenoxam Caneberry 0 days 1.95-2.18 lb ai/A IR-4Mefenoxam Summary of Analytic al Chemistry and Residue Data DP#: 371307

Page 47 of 49 Figure II - 2. Tolerance spreadsheet sum ma ry of m efenoxamfield trial data for caneberry. Regulator: EPA Chemical: Mefenoxam Crop: Caneberry PHI: 0 days App. Rate: 1.95-2.18 lb ai/A Submitter: IR-4

n: 12 min: 0.21 max: 0.55 median: 0.30 average: 0.33 95th Percentile 99th Percentile 99.9th Percentile 0.60 0.60 0.70 (0.70) (0.80) (--) 0.60 0.70 0.80 (0.80) (1.0) (--) 0.80 0.70 1.8 0.9473 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

Spinach The dataset used to establish a tolerance for mefenoxam on spinach consisted of field trial data representing application rates of ~1.25 lb ai/A (one s oil surface application at ~ 1.0 lb ai/A/application and two foliar directed spray applications at ~0.125 lb ai/A/application) with a 2 - to 4 - day

PHI . 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 that were entered into the tolerance spreadsheet are provided in Table I I - 2. All field trial sample results for combined residues of mefenoxam and metabolites convertible to 2,6 - DMA in/on spinach were above the L LM V (LLMV = 0. 10 ppm ). The spinach dataset contained 18 samples. Visual inspection of the lognormal probability plot (Figure II - 3 ) and the results from the approximate Shapiro - Francia test statistic (Figure II - 4 ) indicate d that the spinach dataset was reasonably

lognormal. Us ing the tolerance spreadsheet, the recommended tolerance is 8.0 ppm for spinach.Mefenoxam Summary of Analytic al Chemistry and Residue Data DP#: 371307

Page 48 of 49 Table II - 2. Residue data used to calculate tolerance for m efenoxamon spinach. Regulator: EPA Chem ical: Mefenoxam Crop: Spinach PHI: 2 - 4 days App. Rate: 1.211 - 1.253 lb ai/A Submitter: IR - 4 MRID Citation: MRID 47803105 Com bined r esidues of m efenoxam/ m etalaxyl + m etabolites c onvertible to 2,6 - DMA 1.47 1.72 1.95 1.98 2.22 2.39 2.64 3.02 3.02 3.11 3.13 3.16 3.43 4.01 4.64 5.02 5.50 6.1 9Mefenoxam Summary of Analytic al Chemistry and Residue Data DP#: 371307

Page 49 of 49 Figure II - 3. Lognorm al probability plot of m efenoxamfield trial data for spinach . Lognormal Probability Plot

99.9 99 98 95 90 80 70 50 30 20 10 5 2 1 0.1 7.0000

3.5000

1.7500

0.8750 y = 0.4181x + 1.1029 R 2 = 0.9824

PercentilesConcentrations EPA Mefenoxam Spinach 2-4 days 1.211-1.253 lb ai/A IR-4

Figure II - 4. Tolerance spreadsheet sum ma ry of m efenoxamfield trial data for spinach. Regulator: EPA Chemical: Mefenoxam Crop: Spinach PHI: 2-4 days App. Rate: 1.211-1.253 lb ai/A Submitter: IR-4

n: 18 min: 1.47 max: 6.19 median: 3.07 average: 3.26 95th Percentile 99th Percentile 99.9th Percentile 6.0 7.0 8.0 (7.0) (8.0) (--) 6.0 8.0 11 (9.0) (12) (--) 9.0 8.0 17 0.9824 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