2 

Comment EPA-HQ-OPP-2013-0045-0009 from FESTF:

Comment: The FIFRA Endangered Species Task Force (FESTF) submitted a comment 

informing the Agency that the technical registrant for dimethomorph is a member of FESTF and 

is entitled to rely on FESTF data on endangered species proximity to dimethomorph uses. 

EPA Response: The Agency thanks FESTF for its comment and will consider this information 

during registration review. 

Comment EPA-HQ-OPP-2013-0045-0010 from BASF Corporation, the 

technical registrant of dimethomorph:

Comment 1 (page 1 of BASF’s document): BASF informed the Agency they do not plan to 

support several dimethomorph products (EPA Registration Nos. 241-383, 241-395, 241-410, 

241-411, and 241-419) during registration review. BASF noted that they are in the process of 

cancelling these registrations with state agencies, and once that is completed, BASF will submit 

to EPA for voluntary cancellation. 

EPA Response: EPA thanks BASF for sharing these plans with the Agency and requests that 

BASF follow the standard procedures for requesting voluntary cancellation of the noted 

products. Before working on the preliminary registration review human health and ecological 

risk assessments, EPA will review the list of active product registrations and use sites. Only 

currently registered products and use sites will be considered in the risk assessments. 

Comment 2 (pages 8, 9 of BASF’s document): BASF noted a trade issue caused by a 

discrepancy in the dimethomorph tolerances in 40 CFR §180.493. In May 2012, EPA 

established a tolerance at 30.0 ppm for Crop Group 4, leafy vegetables (except Brassica). 

However, the previously established tolerances of 10.0 ppm for “lettuce, head” and “lettuce, 

leaf” were not removed from 40 CFR at that time. BASF notes that this has created a trade issue 

for their customers because regulatory authorities from importing countries are regulating lettuce 

based on the individual lettuce tolerances of 10.0 ppm rather than the 30.0 ppm tolerance for the 

leafy vegetable group. 

EPA Response: As BASF mentioned in their comment, BASF and the Agency previously 

corresponded on this issue via email in February and March 2013. EPA intends to issue a 

technical correction to remove the individual lettuce tolerances as a proposed rule in the Federal 

Register in 2013. 

Comment 3 (page 8 of BASF’s document): BASF stated that based on a newer aerobic aquatic 

metabolism study (MRID 48326905), they believe that the drinking water assessment residues of 

concern should be based on parent dimethomorph only rather than parent plus degradates. With 

the development of new HPLC (high performance liquid chromatography) conditions, the polar 
3 

peak was retained and separated into several components which individually never exceeded 

10% of the total applied radioactivity. 

EPA Response: The aerobic aquatic metabolism study (MRID 48326905), showed no major 

metabolites >10% of the total applied radioactivity. HED and EFED conclude the drinking 

water assessment residue of concern should be based on the parent, dimethomorph only. (For 

further details, see the Environmental Fate and Effects Division’s response to comments 

document in the dimethomorph docket.)

Comment 4 (page 7 of BASF’s document): BASF notes that EPA’s statement, “There are 

currently no Canadian or Mexican maximum residue limits (MRLs) for residues of 

dimethomorph...” is incorrect, and states that there are MRLs for dimethomorph in Canada 

which were established and published by PMRA in December 2012. 

EPA Response: EPA thanks BASF for this information. An updated summary of the 

international tolerances and MRLs are listed in Appendix 1 below which include Canadian and 

Mexican MRLs. 

 

Comment 5 (pages 21-23 of BASF’s document): BASF provided clarification and corrections 

regarding existing US tolerances for dimethomorph. The shown US tolerances are partially 

incorrect (for instance, the US tolerance for grapes is 3.0 ppm) and not all commodities are 

listed. For completeness the established Canadian tolerances should be added. BASF further 

noted that the list of Canadian tolerances and Codex MRLs was not complete in Attachment 6, 

“International Residue Limit Status” of the Dimethomorph Human Health Assessment Scoping 

Document in Support of Registration Review (1/31/13). 

EPA Response: EPA thanks BASF for this information. The dimethomorph scoping document 

only listed the latest proposed uses (grapes, leafy Brassica vegetables, leafy vegetables, and 

onions). Also, it is noted that the established US tolerances for grapes is 3 ppm and for raisins is 

7 ppm; the scoping document inaccurately reported 4 ppm for grapes and 6 ppm for raisins. An 

updated summary of the international tolerances and MRLs are listed in Appendix 1 below 

which includes Canadian and Mexican MRLs. 

 
4 

Appendix 1: International Residue Limit (IRL) Status 

Summary of US and International Tolerances and Maximum Residue Limits  

Residue Definition:

US Canada Mexico1 Codex2

US [40 CFR §180.493(a) General]

Plants/Livestock: dimethomorph, (

E,Z ) 4‐[3‐(4‐chlorophenyl)‐3‐(3,4‐

dimethoxyphenyl)‐1‐oxo‐2‐

propenyl]morpholine

(E,Z)‐4‐[3‐(4‐

chlorophenyl)‐3‐(3,4‐

dimethoxyphenyl)‐ 

1‐oxo‐2‐

propenyl]morpholine

dimethomorph

(sum of isomers)

Commodity Tolerance (ppm) /Maximum Residue Limit (mg/kg)

US Canada Mexico1 Codex2

Brassica, head

and stem,

subgroup 5A

6.0 6 broccoli, brussels sprouts, cabbage,

cauliflower, Chinese broccoli,

Chinese mustard cabbages, kohlrabi,

napa Chinese cabbages

1 broccoli,

2 cabbage head

0.02 kohlrabi

Brassica, leafy

greens,

subgroup 5B

30.0 30 broccoli raab, bok choy Chinese

cabbages, collards, kale, mustard

greens, mustard spinach, rape

greens

   

Ginseng 0.90     

Grape 3.0 3 2

Grape, raisin 7.0

7 raisins

5 dried grapes (=

currants, raisins and

sultanas)

Hop, dried

cones

60 40 hops (dried) 80 hops, dry

Lettuce, head 10 30 10

Lettuce, leaf 10 30    

Onion, bulb,

subgroup 3‐

07A

0.6 0.6 Chinese onions, Daylilies, dry bulb

onions, fritillaria bulbs, garlic, great‐

headed garlic, lilies, pearl onions,

potato onions, serpent garlic, shallot

bulbs

   

Onion, green,

subgroup 3‐

07B

15.0 15 Beltsville bunching onions,

elegans hosta, fresh (Chinese chive

leaves, chive leaves), fresh onions,

fritillaria leaves, green onions,

kurrats, lady's leek, leeks, macrostem

onions, shallot leaves, tree onion

tops, Welsh onion tops, wild leeks

   

Potato 0.05 0.01 0.05

Potato, wet

peel

0.20     

Taro, corm 0.5     
5 

Summary of US and International Tolerances and Maximum Residue Limits  

Residue Definition:

US Canada Mexico1 Codex2

Taro, leaves 6.0     

Turnip, greens 20.0     

Vegetable,

cucurbit, group

9

0.5

   

0.5 fruiting

vegetables,

cucurbits (except

fungi, edible;

mushrooms and

sweet corn (corn‐

on‐the‐cob and

kernels)

Vegetable,

fruiting, group

8

1.5 3  African eggplants, bell peppers,

bush tomatoes, coconas, currant

tomatoes, eggplants,  garden

huckleberries, goji berries,

groundcherries, martynias,

naranjillas,  nonbell peppers, okras,

pea eggplants, pepinos, roselles,

scarlet eggplants, sunberries,

tomatillos, tomatoes, tree tomatoes

1 fruiting

vegetables other

than cucurbits

5 peppers chili dried

Vegetable,

leafy (except

Brassica) group

4

30.0 30 Amaranth, arugula, cardoon,

celery, celtuce, Chinese celery, corn

salad, dandelion leaves, dock, edible

leaved chrysanthemum, endives,

fresh chervil leaves, fresh Florence

fennel leaves and stalks, fresh parsley

leaves, garden cress, garden purslane

, garland chrysanthemum, head

lettuce, leaf lettuce, Malabar

spinach, New Zealand spinach, orach,  

radicchio, rhubarb, spinach, swiss

chard, upland cress,  winter purslane

10 corn salad,

lettuce, head

MRLs with NO US Equivalent

13‐07D.  

Small fruit vine

climbing

subgroup

3 Amur river grapes, gooseberries,  

hardy kiwifruit, maypop, schisandra

berries    

Edible offal

(mammalian)     0.01 (*)

Eggs      0.01 (*)

Meat (from

mammals

other than

marine

mammals)

    0.01 (*)
6 

Summary of US and International Tolerances and Maximum Residue Limits  

Residue Definition:

US Canada Mexico1 Codex2

Milk      0.01 (*)

Pineapple      0.01 (*)

Poultry meat      0.01 (*)

Poultry , Edible

offal of     0.01 (*)

Strawberry      0.05

        

Completed:  M. Negussie; 07/18/2013 1Mexico adopts US tolerances and/or Codex MRLs for its export purposes.

2 * = absent at the limit of quantitation; Po = postharvest treatment, such as treatment of stored grains.  

PoP = processed postharvest treated commodity, such as processing of treated stored wheat. (fat) = to

be measured on the fat portion of the sample. MRLs indicated as proposed have not been finalized by

the CCPR and the CAC.

(c) Tolerances with regional registrations . Tolerances with regional registrations are established

for residues of the fungicide dimethomorph, ( E,Z ) 4‐[3‐(4‐chlorophenyl)‐3‐(3,4‐dimethoxyphenyl)‐1oxo  

2‐propenyl]morpholine, in or on the following commodities:

Commodity Parts per million

Bean, lima, succulent 0.60

(d) Indirect or inadvertent residues. Tolerances are established for the indirect or inadvertent

residues of the fungicide dimethomorph, in or on the commodities in the following table. Compliance

with the following tolerance levels specified in the following table is to be determined by measuring only

dimethomorph ( E,Z )‐4‐[3‐(4‐chlorophenyl)‐3‐(3,4‐dimethoxyphenyl)acryloyl]morpholine calculated in

or on the following commodities:

Commodity Parts per million

Wheat, forage 0.15

Wheat, hay 0.15

Wheat, straw 0.4