### 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 registra nt for dimethomorph is a member of FESTF and

is entitled to rely on FESTF data on endange red 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 fr om 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 (E PA Registration Nos. 241-383, 241-395, 241-410,

241-411, and 241-419) during registrati on 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 pl ans with the Agency and requests that

BASF follow the standard procedures for re questing voluntary cancellation of the noted

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

risk assessments, EPA will review the list of active product regist rations 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 tolera nces 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 estab lished tolerances of 10.0 ppm for “lettuce, head” and “lettuce,

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

for their customers because regul atory 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 comme nt, BASF and the Agency previously

corresponded on this issue via email in Febr uary 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 onl y rather than parent pl us degradates. With

the development of new HPLC (high performan ce liquid chromatography) conditions, the polar

### 3 peak was retained and separated into severa l components which individually never exceeded

10% of the total app lied radioactivity.

EPA Response: The aerobic aquatic metabolis m 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 Envi ronmental 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 maximu m 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 dimethom orph. 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 Canadi an 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 toleran ces and MRLs are listed in Appendix 1 below

which includes Canadian and Mexican MRLs.

### 4 Appendix 1: International Re sidue Limit (IRL) Status

Summary of US and International Tolerances and Maximum Residue Limits

Residue Definition :

US Canada Mexico 1 Codex 2

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 Mexico 1 Codex 2

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 Mexico 1 Codex 2

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 Mexico 1 Codex 2

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

1 Mexico 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