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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

WASHINGTON, D.C. 20460

OFFICE OF

CHEMICAL SAFETY AND

POLLUTION PREVENTION

MEMORANDUM

Date: January 4, 2011

SUBJECT: Fluazifop-P-Butyl. Amended Section 3 Registration Request to Add New Uses on 

Bananas, Citrus, Grapes, and Sugar Beets. Summary of Analytical Chemistry and 

Residue Data.

PC Code: 122809 DP Barcode: 385205

Decision No.: 421334 Registration No.: 100-1001

Petition No.: 9F7624 Regulatory Action: New Use Registration

Risk Assessment Type: NA Case No.: 2285

TXR No.: NA CAS No.: 79241-46-6

MRID No.: Summary Table Provided Below 40 CFR: 180.411

FROM: Peter Savoia, Chemist

Risk Assessment Branch V

Health Effects Division (7509P)

THRU: William H. Donovan, Ph.D., Chemist

Risk Assessment Branch V

Health Effects Division (7509P)

TO: Kathryn Montague/Michael Walsh, RM 23

Herbicide Branch 

Registration Division (7505P)

MRID Summary Table

MRID No. Study Type Comments

47874601 860.1500 (banana) 47874601.der.doc

47874602 860.1500 (citrus) 47874602.der.doc

47874603 860.1500 (sugar beet) 47874603.der.doc

47874604 860.1500 (grapes) 47874604.der.doc

47874605 860.1520 (grapes) 47874605.der.doc

47874606 860.1520 (sugar beet) 47874606.der.doc

This memorandum revises the August 31, 2010 version (D380017) by refining the recommended

fluazifop-P-butyl tolerance level for the dried pulp citrus processed commodity. 

The initial memorandum was prepared by Versar, reviewed by the Health Effects Division

(HED), and revised as needed for correctness, language and to reflect current Office of Pesticide 

Programs (OPP) policies.
Fluazifop-P-butyl Summary of Analytical Chemistry and Residue Data DP No. 385205

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Prior actions made to develop the fluazifop-P-butyl herbicide active ingredient (ai) have identified a 

number of studies that are required for completing data gaps. In accordance, a number of Data Call-In

(DCI) submissions have been provided by the registrant in order to satisfy these database 

requirements. These studies are as follows:

• Carrot and endive nature of residue studies, test guideline 860.1300.

• Ruminant and poultry nature of residue studies, test guideline 860.1300. 

• Radiovalidation study made for the tolerance enforcement method proposed for analyzing plants, 

test guideline 860.1340. 

• Method validation study made for the tolerance enforcement method proposed for analyzing 

poultry, eggs and livestock, test guideline 860.1340.

• Cattle and poultry feeding studies, test guideline 860.1480.

• Confined rotational crop study, test guideline 860.1850. 

An assessment of these studies is currently in progress and will be addressed in a separate 

memorandum in due course. Should the results of the studies submitted in response to the 

registration DCI impact the conclusions reached in the present document, appropriate changes will be 

made at that time. No further discussion of these in review studies will be included in this 

memorandum.

Executive Summary

Fluazifop-P-butyl [(R)-2-(4-((5-(trifluoromethyl)-2-pyridinyl)oxy)phenoxy)propanoic acid, butyl 

ester] is a selective herbicide registered for postemergence control of perennial and annual grass 

weeds. It is the resolved isomer (R enantiomer) of fluazifop-butyl [(R,S)-2-(4-((5-(trifluoromethyl)-2-

pyridinyl)oxy)phenoxy) propanoic acid, butyl ester]. After application fluazifop-P-butyl is rapidly

hydrolyzed to fluazifop acid (R enantiomer) where it accumulates in the meristems of grass weeds 

working to interrupt lipid synthesis in susceptible plants. Fluazifop-P-butyl end-use products are 

registered in the United States to Syngenta Crop Protection, Inc. under the trade names Fusilade®, 

Fusion®, Oramec®, Tornado®, and Typhoon®. 

This herbicide active ingredient is the resolved isomer (R enantiomer) of fluazifop-butyl (PC code 

122805) which has since been cancelled resulting in only fluazifop-P-butyl to be supported for reregistration. The Residue Chemistry Chapter of the Fluazifop-P-Butyl TRED (referred to herein as 

the Residue Chapter) was issued on August 17, 2005 (DP No. 319907, S. L. Kinard, 08/17/2005). It 

provided the Residue Chemistry Assessments that went into the “Report on FQPA Tolerance 

Reassessment Progress and Interim Risk Management Decisions (TRED) for fluazifop-P-butyl.”

In the current petition, Syngenta Crop Protection, Inc. requests the establishment of permanent 

tolerances for the residues of fluazifop-P-butyl in/on the following crop and processed commodities:

Banana................................................................................ 0.01 ppm

Citrus (whole fruit) ............................................................ 0.05 ppm

Citrus (dried pulp).............................................................. 0.40 ppm

Citrus (oil).......................................................................... 0.05 ppm

Citrus (juice) ...................................................................... 0.05 ppm

Grapes................................................................................ 0.01 ppm
Fluazifop-P-butyl Summary of Analytical Chemistry and Residue Data DP No. 385205

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Sugar beet (root)................................................................. 0.25 ppm

Sugar beet (top)....................................................................1.5 ppm

Sugar beet (dried pulp).........................................................1.0 ppm

Sugar beet (molasses)...........................................................3.5 ppm

The end-use product relevant for this petition request is Fusilade® DX Herbicide (EPA Reg. No. 100-

1070), an emulsifiable concentrate formulation containing 24.5% ai of fluazifop-P-butyl (equivalent 

to 2 lb ai/gal). The petitioner wishes to amend the product label for Fusilade® DX Herbicide to add 

new uses on banana, citrus, grapes, and sugar beets. Fusilade® DX Herbicide is proposed for 

multiple foliar or vineyard/orchard floor applications at maximum seasonal rates of 1.125 lb ai/A for 

bananas, grapes, and citrus and 0.75 lb ai/A for sugar beets. Applications are to be made with an 

adjuvant using ground or aerial equipment. The proposed Pre-Harvest Intervals (PHIs) for the 

requested new uses range from 0 days on treatments made to bananas up to 90 days for sugar beet

applications.

Fluazifop-butyl isomers are List B chemicals with parent and fluazifop-acid (free and conjugated) 

regulated for tolerance expression as the residues of concern used to determine misuse (DP No. 

D319907, S. L. Kinard, 08/17/2005). Its registered uses include dry beans, carrot, cotton, endive 

(escarole), macadamia nut, onion, peanut, pecan, soybean, spinach, stone fruit, and sweet potato. It

also carries tolerances with regional registrations on asparagus, coffee, pepper, and rhubarb along 

with being registered for use on lawns as a weed control application. Tolerances are established under 

40 CFR §180.411(a) for residues of the herbicide fluazifop-P-butyl which include both the free and 

conjugated forms of its resolved isomer expressed as fluazifop. There are no Section 18 emergency

exemptions in effect but fluazifop-P-butyl tolerances are likewise established under 40 CFR 

§180.411(c) which carry regional restrictions expressed as fluazifop.

The nature of the residue in both plants and livestock cannot yet be described as adequately

understood. For the current action, an acceptable soybean metabolism study is available, and the 

soybean metabolism study will also support the proposed uses on the other crops addressed herein. 

The Metabolism Assessment Review Committee (MARC) concluded that the residues of concern for 

tolerance expression for plants and animals are parent and fluazifop-acid (free and conjugated) since 

they are adequate to determine misuse. The MARC also concluded that the residues of concern in

plants for risk assessment are parent, fluazifop-acid (free and conjugated), 5-trifluoromethyl-2-

pyridone, and 2-(4-hydroxyphenoxy) propionic acid (free and conjugated). The residues of concern in 

animals for risk assessment are parent and fluazifop-acid (free and conjugated) (DP No. D298939, S.

L. Kinard, 6/22/2004).

There are adequate residue analytical methods listed in PAM II for tolerance enforcement and data 

collection. For the enforcement of tolerances for fluazifop-P-butyl residues of concern, a High 

Performance Liquid Chromatography/Ultra-Violet Spectrometry (HPLC/UV) method is available for 

crop commodities. In conjunction, HPLC/UV and Gas Chromatography/Mass Spectrometry

(GC/MS) methods are available for milk and animal commodities. The stated quantitation limits are 

0.02-0.05 ppm for crop commodities, 0.01 ppm for milk, and 0.02 ppm for animal tissues. In 

addition, the FDA PESTDATA database dated 11/01 (PAM Volume I, Appendix I) indicates that 

fluazifop-butyl (only) is completely recovered using Multiresidue Methods Sections 302 (Luke 

Method; Protocol D) and 303 (Mills, Onley, and Gaither Method; Protocol E, nonfatty food). 
Fluazifop-P-butyl Summary of Analytical Chemistry and Residue Data DP No. 385205

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To support this petition, the field trial samples were analyzed for residues of total fluazifop 

(fluazifop-P-butyl, fluazifop free and conjugated) using either a GC/MS or Fluorine-19 Nuclear 

Magnetic Resonance (19F NMR) protocol. These procedures provide a total determination by

hydrolyzing the fluazifop ester or acid conjugates and then derivatizing them to form the fluazifop 

methyl ester for quantitation with residues being reported as fluazifop. The protocols are adequate for 

data collection based upon acceptable method validation and concurrent method recoveries.

The current petition requests the establishment of tolerances on dried pulp citrus and sugar beet tops, 

commodities which have been considered livestock feedstuffs. Following revision of the Table 1 

Feedstuffs in 2008, sugar beet tops were removed as being a significant feed item, and thus it no 

longer contributes to the dietary burden of cattle. The potential contribution of citrus dried pulp to the 

livestock dietary burden was considered by assuming a concentration factor of 13x and comparing the 

resulting residue contribution to that of soybean hulls, the current roughage component in the dietary

burden calculation. Since soybean hulls has a higher tolerance than the recommended tolerance level 

of dried pulp citrus, the current tolerances on meat, milk, poultry, and eggs are considered adequate 

and should remain unchanged. This conclusion should be re-examined upon receipt of the requested 

processing study for citrus. 

The submitted field trial data for bananas are adequate. The field trials were conducted according to 

the proposed use rate and PHI. The maximum residues of total fluazifop were less than the 0.01 ppm 

Limit of Quantitation (LOQ) in/on bananas harvested 0 days after the last of three broadcast 

applications. For this application program, treatments were made using the 2 lb/gal Emulsifiable 

Concentrate (EC) formulation applied at ≈1x the proposed seasonal use rate to the soil. Based on the 

LOQ, the best estimate for a tolerance for bananas is 0.01 ppm.

The submitted field trial data for citrus are adequate. The field trials were conducted according to the 

proposed use rate and PHI. The maximum residues of total fluazifop were less than the 0.03 ppm 

LOQ in/on citrus harvested 12-14 days after the last of three broadcast applications. For this 

application program, treatments were made to the orchard soil beneath the trees using the 2 lb/gal EC 

formulation applied at ≈1x to 2x the proposed seasonal use rate. Based on the LOQ, the best estimate 

for a tolerance for citrus is 0.03 ppm.

The submitted field trial data for grapes are adequate. The field trials were conducted according to 

the proposed use rate and PHI. The maximum residues of total fluazifop were less than the 0.01 ppm 

LOQ in/on grapes harvested 49-50 days after the last of three broadcast applications. For this 

application program, treatments were made to the vineyard floor beneath the grape vines using the 2 

lb/gal EC formulation applied at ≈1x the proposed seasonal use rate. Based on the LOQ, the best 

estimate for a tolerance for grapes is 0.01 ppm.
Fluazifop-P-butyl Summary of Analytical Chemistry and Residue Data DP No. 385205

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The submitted field trial data for sugar beets are adequate having been appropriately made according 

to the proposed use rate and PHI. For this test program, both sugar beet tops and the roots were 

quantitated for determining the magnitude of the residue. The maximum residues of total fluazifop 

were 1.45 ppm in/on sugar beet tops and 0.23 ppm in/on sugar beet roots harvested 89-90 days after 

the last of three broadcast foliar applications. Treatments were all made using the 2 lb/gal EC 

formulation applied at ≈1x the proposed seasonal use rate. The residue data for sugar beet roots were 

entered into the Agency’s tolerance spreadsheet as specified by the Guidance for Setting Pesticide 

Tolerances Based on Field Trial Data SOP to determine an appropriate tolerance level. The 

spreadsheet provides a best estimate of a tolerance at 0.25 ppm for the sugar beet roots. With regards

to sugar beet tops, no tolerance is needed for this commodity since it is no longer considered a 

significant feed item.

The submitted sugar beet and grape processing studies are acceptable. For sugar beets, total fluazifop 

residues concentrated in dried pulp (processing factor of 3.9x) and molasses (14x) but do not appear 

to concentrate in refined sugar (0.36x). For grapes, total fluazifop residues do not appear to 

concentrate in raisins or juice (<1x). This data along with the sugar beet root HAFT (0.22 ppm), 

indicate that a tolerance is needed for fluazifop-P-butyl residues of concern in sugar beet dried pulp at 

1.0 ppm and molasses at 3.5 ppm. No tolerances are needed for the sugar beet refined sugar or the 

grape processed commodities.

As was previously concluded by the Agency (DEB No. 6343, M. J. Bradley, 08/15/1990), the 

submitted citrus processing study is not acceptable. Given the age of the original submission, the 

petitioner should provide a new study. While the processing study is conducted, tolerances for citrus 

processed commodities should be set based on maximum theoretical concentration factors for the 

appropriate fractions: 2x for juice and 1000x for oil. These factors along with the citrus HAFT of 

0.03 ppm, indicate that fluazifop-P-butyl tolerance levels for citrus juice and oil should be 0.06 and 

30.0 ppm, respectively. With regard to dried pulp citrus, there is no theoretical concentration factor 

determined for this processed commodity. However, in a recent chlorantraniliprole review, an 

examination of 27 pesticides having dried pulp citrus tolerances was made to determine a practical 

maximum concentration factor (DP No. D361791, D. Rate, 01/08/2010). This review found 

concentration factors range between 2-13x for dried pulp citrus. Therefore, using the practical

maximum concentration factor of 13x for fluazifop along with the citrus HAFT of 0.03 ppm, a 

resulting tolerance of 0.40 ppm should be set for dried pulp citrus. 

Regulatory Recommendations and Residue Chemistry Deficiencies

Provided the petitioner submits a revised Section F, HED concludes that the residue chemistry

database supports a conditional registration and establishment of permanent tolerances for the 

proposed new uses of fluazifop-P-butyl. Tolerances are to be established for residues of the herbicide 

fluazifop-P-butyl, including its metabolites and degradates, in or on the commodities listed below. 

Compliance with the tolerance levels specified below is to be determined by measuring only the sum 

of fluazifop-P-butyl, butyl(R)-2-[4-[[5-(trifluoromethyl)-2-pyridinyl]oxy]phenoxy]propanoate, and 

the free and conjugated forms of the resolved isomer of fluazifop, (R)-2-[4-[[5-(trifluoromethyl)-2-

pyridinyl]oxy]phenoxy]propanoic acid, calculated as the stoichiometric equivalent of fluazifop, in or 

on the commodity.
Fluazifop-P-butyl Summary of Analytical Chemistry and Residue Data DP No. 385205

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Banana................................................................................ 0.01 ppm

Fruit, citrus, group 10-10 ................................................... 0.03 ppm

Citrus, oil ...........................................................................30.0 ppm

Citrus, dried pulp ............................................................... 0.40 ppm

Citrus, juice........................................................................ 0.06 ppm

Grape.................................................................................. 0.01 ppm

Sugar, beet, root ................................................................. 0.25 ppm

Sugar, beet, dried pulp .........................................................1.0 ppm

Sugar, beet, molasses...........................................................3.5 ppm

An unconditional registration may be appropriate upon determination of the adequacy of a new citrus 

processing study (see requirements under Processed Food and Feed). A revised human-health risk 

assessment which includes these new crop uses is forthcoming in a separate document (D385178).

860.1520 Processed Food and Feed

As was previously concluded by the Agency (DEB No. 6343, M. J. Bradley, 08/15/1990), the 

submitted citrus processing study is not acceptable. Given the age of the original submission, the 

petitioner should provide a new study.

860.1550 Proposed Tolerances

The proposed tolerances should be revised to reflect the recommended tolerance levels and correct 

commodity definitions as specified in Table 8. 

Background

Fluazifop-P-butyl [(R)-2-(4-((5-(trifluoromethyl)-2-pyridinyl)oxy)phenoxy)propanoic acid, butyl 

ester] is a selective herbicide used for the post-emergence control of perennial and annual grass 

weeds. It is the resolved isomer (R enantiomer) of fluazifop-butyl (PC code 122805) which has since 

been cancelled resulting in only fluazifop-P-butyl to be supported for re-registration. The fluazifopbutyl isomers are List B chemicals with parent and fluazifop-acid (free and conjugated) regulated for 

tolerance expression as the residues of concern used to determine misuse (DP No. D319907, S. L. 

Kinard, 08/17/2005). The Phase 4 Reviews for fluazifop-butyl and fluazifop-P-butyl were completed 

on 02/26/1991. The subsequent Phase 5 review of these studies has also been completed. This 

includes the Residue Chemistry Science Assessments with respect to the Report on FQPA Tolerance 

Reassessment Progress and Interim Risk Management Decisions (TRED) for fluazifop-P-butyl issued 

on 08/17/2005. For review, the chemical structure and nomenclature of fluazifop-P-butyl, including 

its free acid fluazifop-P as well as the physicochemical properties of the technical grade of fluazifopP-butyl are presented below in Tables 1 and 2. 
Fluazifop-P-butyl Summary of Analytical Chemistry and Residue Data DP No. 385205

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Table 1. Fluazifop-P-butyl Nomenclature.

Compound

N

F3C

O

O

H

CH3

O

O

C4H9(n)

Common name Fluazifop-P-butyl

Company experimental name Not available.

IUPAC name Butyl (2R)-2-(4-{[5-(trifluoromethyl)pyridin-2-yl]oxy}phenoxy)propanoate

CAS name (R)- 2-(4-((5-(trifluoromethyl)-2-pyridinyl)oxy)phenoxy)propanoic acid, butyl 

ester

CAS registry number 79241-46-6

End-use product (EP) Fusilade® DX (2 lb/gal EC; EPA Reg. No. 100-1070)

Compound

N

F3C

O

O

H

O

OH

CH3

Common name Fluazifop-P (free acid)

Chemical name (R)-2-(4-[5-(trifluoromethyl-2-pyridinyl)oxy]phenoxy)propionic acid

Table2. Physicochemical Properties of Fluazifop-P-butyl. 

Parameter Value Reference1

Melting point/range Decomposes at 210 oC

164 oC at 0.02 mm Hg

2002 Farm Chemicals Handbook

RCB No. 1674, 2/3/87, L. Cheng

pH Not dispersible in water RCB No. 1674, 2/3/87, L. Cheng

Density 1.22 g/cc (PAI) and 1.20 g/cc (T) 

at 20 oC

RCB No. 809, 6/3/86, L. Cheng

Water solubility 1 mg/L RCB No. 1674, 2/3/87, L. Cheng

Solvent solubility Soluble in most organic solvents

>500 g/L in acetone, 

dichloromethane, ethyl acetate, 

hexane, methanol, toluene, and 

xylene

2002 Farm Chemicals Handbook

RCB No. 1674, 2/3/87, L. Cheng

Vapor pressure 3 x 10-8 KPa at 20 oC RCB No. 809, 6/3/86, L. Cheng

Dissociation constant, pKa -3.1 (by calculation) RCB No. 809, 6/3/86, L. Cheng

Octanol/water partition coefficient, 

Log(KOW)

4.5 at 20 oC RCB No. 809, 6/3/86, L. Cheng

UV/visible absorption spectrum Not available

1DP No. D348246, D. Soderberg, 09/16/2008
Fluazifop-P-butyl Summary of Analytical Chemistry and Residue Data DP No. 385205

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860.1200 Directions for Use

A summary of the proposed/amended use patterns for bananas, citrus, grapes and sugar beets is 

presented in Table 3. The information presented in Table 3 was obtained from a specimen label 

provided by Syngenta for the Fusilade® DX Herbicide (EPA Reg. No. 100-1070).

Table 3. Summary of Directions for Use of Fluazifop-P-butyl.

Commodity

Trade 

Name 

(EPA 

Reg. No.)

Application 

Timing, 

Type, and 

Equipment

Application 

Rate

(lb ai/A)

Maximum 

Number 

Applications 

per Season

Maximum 

Seasonal 

Application 

Rate

(lb ai/A)

PHI

(days)

Use 

Directions 

and 

Limitations

Bananas Fusilade® 

DX (100-

1070)

Ground and 

aerial

0.375 3 1.125 0 days RTI: 30 

days

Citrus Ground and 

aerial

0.375 3 1.125 14 days RTI: 21 days

Grapes Ground and 

aerial

0.375 3 1.125 50 days RTI: 14 days

Sugar beet Ground and 

aerial

0.375 2 0.75 90 days RTI: 14 days

Do not enter or allow worker entry into treated areas during the restricted entry interval (REI) of 12 hours following 

application. 

The general label use directions specify that: (1) adjuvants (crop oil concentrate, non-ionic surfactant, 

or other approved adjuvants) plus liquid nitrogen fertilizer may be used on soybeans; (2) ground and 

aerial applications are to be made in a minimum of 5 gal/A; (3) for chemigation (sprinkler irrigation), 

adjuvants are not to be used in the manner described for use in conventional applications or applied 

with a system connected to a public water system; and (4) the restricted-entry interval is 12 hours. 

Rotational grass crops such as corn, sorghum and cereals are not to be planted within 60 days of last 

application.

Conclusions: The label directions are adequate to allow evaluation of the residue data relative to the 

proposed use. There are no aerial application restrictions specified on the label. For the banana, 

citrus, and grape field trials that were conducted, treatment was made to the orchard/vineyard floor 

below the plant canopy which is not an aerial application method.

860.1300 Nature of the Residue - Plants

Residue Chemistry Memo, DP No. D319907, 08/17/2005, S. L. Kinard (TRED Residue Chemistry Chapter)

HED MARC Decision Memo, DP No. D298939, 06/22/2004, S. L. Kinard

The Fluazifop-P-Butyl Residue Chapter of the TRED (DP No. 319907, S. L. Kinard, 08/17/2005) 

concluded that the nature of the residue in soybeans is adequately understood. No new plant 

metabolism studies for the proposed new use crops were submitted as part of the current petition. 

The MARC has determined that for tolerance expression, parent and fluazifop-acid (free and 

conjugated) are the residues of concern since they are adequate to determine misuse. The MARC also 

concluded that the residues of concern in plants for risk assessment are parent, fluazifop-acid (free 

and conjugated), 5-trifluoromethyl-2-pyridone, and 2-(4-hydroxyphenoxy) propionic acid (free and 

conjugated). 
Fluazifop-P-butyl Summary of Analytical Chemistry and Residue Data DP No. 385205

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860.1300 Nature of the Residue - Livestock

The MARC has concluded that for tolerance expression and risk assessment, parent and fluazifopacid (free and conjugated) are the residues of concern since they are adequate to determine misuse.

860.1340 Residue Analytical Methods

Residue Chemistry Memo, DP No. D319907, 08/17/2005, S. L. Kinard (TRED Residue Chemistry Chapter)

Enforcement methods

For the enforcement of tolerances for fluazifop-P-butyl residues of concern, PAM Vol. II lists two 

methods, Method I for animal tissues and milk and Method II for oily and non-oily crops. The stated 

detection limits are 0.02-0.05 ppm for crops, 0.01 ppm for milk, and 0.02 ppm for animal tissues. In 

Method I, samples (except fat) are extracted with acetonitrile/acetone/hexane, which separates 

residues of fluazifop and fluazifop-butyl (found in the acetonitrile/acetone layer) from residues of 

fluazifop lipophilic conjugates (found in the hexane layer). Fluazifop and fluazifop-butyl are 

determined in milk using an HPLC/UV instrumental technique. In tissue samples, fluazifop-butyl is 

converted to fluazifop via hydrolysis, and then its residues are methylated using diazomethane, and 

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

cleaned up by florisil chromatography, hydrolyzed to fluazifop, and determined by HPLC/UV. For 

fat, samples are extracted with chloroform/methanol at reflux (2 hours) and residues of fluazifop, 

fluazifop-butyl, and lipophilic conjugates are hydrolyzed to fluazifop, methylated, and determined by

GC/MS.

For Method II, residues of fluazifop-butyl, fluazifop, and any ester or acid conjugates are extracted 

from crop samples using acetonitrile and hydrochloric acid. Residues are then hydrolyzed to 

fluazifop and cleaned up using a coagulation procedure, solvent partitioning, and silica column 

chromatography for determination by HPLC/UV. Residues may be confirmed by GC/MS following 

methylation with diazomethane. Consequently, neither of the enforcement methods distinguishes the 

optical isomers of fluazifop-butyl or fluazifop.

Data collection methods

Samples collected from the crop field trial and processing studies were analyzed for residues of 

fluazifop using either a GC/MS method or a 19F NMR method. The GC/MS methods used were 

Method 45820-M-1 by Zeneca (bananas in MRID No. 47874601) and Method RR 91-014B by

Zeneca (grapes in MRID Nos. 47874604 & 47874605, sugar beet in MRID Nos. 47874603 &

47874606, and citrus in MRID No. 47874602). The 19F NMR method used was based on Plant 

Protection Division Analytical Method no. 83 and was employed for analyzing a portion of the citrus

studies that were provided (citrus in MRID Nos. 41373705 & 41373706). In all, these methods are 

based on the protocols listed in PAM Vol. II, Method II. These procedures work by hydrolyzing the 

target analytes (fluazifop-P-butyl, fluazifop, and any ester or acid conjugates) to a common moiety

(fluazifop acid) for quantitation with residues being reported as fluazifop equivalents. 
Fluazifop-P-butyl Summary of Analytical Chemistry and Residue Data DP No. 385205

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For the GC/MS method used on bananas, residues are extracted from crop samples using a mixture of 

acetonitrile and dilute acid, hydrolyzed to fluazifop using hydrochloric acid, and cleaned up on a 

silica SPE cartridge. Residues are derivatized to form the methyl ester of fluazifop prior to GC/MS 

quantitation. In regard to the GC/MS method used on grapes, sugar beet and citrus, residues are 

extracted from crop samples using a mixture of acetonitrile and dilute acid. Residues are then 

hydrolyzed to fluazifop using hydrochloric acid, and cleaned up by solvent partitioning and 

adsorption chromatography. Residues are derivatized to form the methyl ester derivative of fluazifop 

prior to GC/MS quantitation. For the 19F NMR method used on citrus, residues are extracted from 

crop samples using a mixture of acetonitrile and concentrated hydrochloric acid, hydrolyzed to 

fluazifop using hydrochloric acid, and cleaned up by solvent partitioning. Residues are derivatized to 

form the methyl ester of fluazifop prior to 19F NMR quantitation. 

Adequate method verification analyses were made prior to the determination of the field samples

using fluazifop-P-butyl and fluazifop-P fortified sugar beet tops (0.01 and 10 ppm), sugar beet roots 

(0.01 and 1.0 ppm), and grapes (0.01 and 1.0 ppm). In addition, acceptable concurrent method 

recoveries were obtained for fluazifop-P-butyl from fortified samples of bananas at 0.01 and 0.5 ppm, 

sugar beet root, dried pulp, and refined sugar at 0.01 and 1.0 ppm, sugar beet tops at 0.01 and 10.0

ppm, and grapes, grape juice and raisins at 0.01 and 1.0 ppm. For sugar beet molasses, acceptable 

concurrent method recoveries were obtained for fluazifop-P-butyl from samples fortified at 0.01 and 

10.0 ppm. However, the average concurrent recovery for sugar beet molasses was slightly below the 

generally acceptable range of 70 to 120% at the 15.0 ppm fortification level. Similarly, for citrus 

study MRID No. 47874602, acceptable concurrent method recoveries were obtained for fluazifop-Pbutyl from samples fortified at 0.01 ppm. However, average concurrent recovery was slightly below 

the generally acceptable range of 70 to 120% for the citrus samples analyzed at the 1.0 ppm. For 

citrus studies MRID Nos. 41373705 and 41373706, acceptable concurrent method recoveries were 

obtained for fluazifop-P-butyl from samples fortified at 0.05 ppm (whole fruit and processed 

commodities) and 1.0 ppm (whole fruit only). The fortification levels are adequate to bracket 

expected residue levels of total fluazifop in banana, citrus, grape, and sugar beet matrices, except for 

the processed citrus commodities in which residues for chopped peel, dried pulp, molasses, and oil 

were higher than the fortification level.

Conclusions: The existing GC/MS enforcement methods, or the modified versions, are adequate for 

collecting data on residues of fluazifop-P-butyl and fluazifop in/on banana, citrus, grape, and sugar 

beet commodities. The method will be adequate for tolerance enforcement purposes for these 

commodities. 

860.1360 Multiresidue Methods

Residue Chemistry Memo, DP No. D319907, 08/17/2005, S. L. Kinard (TRED Residue Chemistry Chapter)

The FDA PESTDATA database dated 11/01 (PAM Volume I, Appendix I) indicates that fluazifopbutyl is completely recovered using Multiresidue Methods Sections 302 (Luke Method; Protocol D) 

and 303 (Mills, Onley, and Gaither Method; Protocol E, nonfatty food); recovery using Section 304 

(Mills Method; Protocol F, fatty food) is variable.
Fluazifop-P-butyl Summary of Analytical Chemistry and Residue Data DP No. 385205

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860.1380 Storage Stability

48412503.der.doc D. Soderberg Storage Stability of Residues of various crops and Processed Fractions Stored for up to 

18 Month in Deep Freeze

Storage stability data have been reviewed in conjunction with earlier actions undertaken for fluazifopP-butyl which indicate that its residues are stable in a number of crop commodities. As such, its 

stability has been investigated in a wide variety of frozen crop commodities and documented in

several prior reports generated by Syngenta. These reports demonstrate that residues of fluazifop are 

stable in/on soybeans, sugar beets, green beans, strawberries, oilseed rape, coffee, cauliflower, onions, 

potatoes, peanuts, macadamia nuts, tomatoes, endive, and celery for durations of 3 to 28 months (DP

No. D348246, D. Soderberg, 09/16/2008). Given the results obtained from these prior studies, this 

data is adequate in directly supporting or can be translated to corroborate the sample storage intervals 

incurred in these field trials. Although no data were provided to substantiate the holding times that 

were incurred for many of the processed commodities tested, none are needed since these analyses 

were made within thirty (30) days of production. A summary of the storage durations and conditions 

of the samples from the crop field trials and processing studies provided to support this petition are 

presented below in Table 4 for review. 

Table 4. Summary of Storage Conditions and Intervals of Samples from Crop Field Trials. 

Matrix MRID Storage

Temperature (°C) 1

Actual Storage

Duration2

Interval of Demonstrated

Storage Stability

Banana 47874601 ≤ -20 217 to 282 days

(7.2 to 9.4 months)

None. Up to 28 months in a 

variety of crops at -20oC ± 10oC.

Citrus 47874602 < 0 24 to 71 days

(0.77 to 2.4 months)

None. Up to 28 months in a 

variety of crops at -20oC ± 10oC.

41373705 <-18 456 to 686 days

(16 to 25 months)

Citrus (for 

processing) 41373706 <-18 589 days (21 months)

Citrus, dried pulp 41373706 <-18 591 days (21 months)

Citrus, oil 41373706 <-18 654 days (23 months)

Citrus, juice 41373706 <-18 592 days (21 months)

Grapes 47874604 < 0 8 to 45 days

(0.25-1.5 months) None. Up to 28 months in a 

Grapes (for variety of crops at -20oC ± 10oC.

processing) 47874605 < 0 36 days (1.2 months)

Grape, juice 47874605 < 0 29 days (1.0 months) None. Storage stability data is not 

required because the samples 

were extracted/analyzed within 

approximately 30 days from 

processing.

3

Grape, raisins 47874605 < 0

43 days (1.4 months)

Sugar beet, top 47874603 < 0 9-75 days

(0.25-2.5 months)

None. Up to 28 months in a 

variety of crops at -20oC ± 10oC.

Sugar beet, root 47874603 < 0 9-75 days

(0.25-2.5 months) 12 months in sugar beet root 

Sugar beet, root (MRID No. 00157193).

(for processing) 47874606 < 0 48 days (1.6 months)

Sugar beet, 

refined sugar 47874606 < 0 53 days (1.8 months) None. Storage stability data is not required because the samples were 
Fluazifop-P-butyl Summary of Analytical Chemistry and Residue Data DP No. 385205

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Table 4. Summary of Storage Conditions and Intervals of Samples from Crop Field Trials. 

Matrix MRID Storage

Temperature (°C) 1

Actual Storage

Duration2

Interval of Demonstrated

Storage Stability

Sugar beet, dried 

pulp 47874606 < 0 48 days (1.6 months) extracted/analyzed within approximately 30 days from 

processing.

4

Sugar beet, 

molasses 47874606 < 0 48 to 51 days (1.6 to 1.7 months)

1

For all crops except bananas, storage temperature at the analytical facility was <0oC prior to homogenization and then ≤-

15oC until analysis.

2 Actual storage duration is from harvest to extraction. 

3

For grapes, the storage duration between processing and extraction was 33 days for grapes, 26 days for grape juice, and 

30 days for raisins.

4

For sugar beets, the storage duration between processing and extraction was 28 to 31 days for molasses, 32 days for 

sugar beet roots, 32 to 33 days for dry pulp, and 33 days for refined sugar.

Conclusions: The petitioner included a summary of the storage stability data in each of the field trial 

submissions. Submitted storage stability data demonstrate that total residues of fluazifop-P were 

stable in/on various crops and processed commodities. Data specifically for grapes, grape juice, 

raisins, citrus, citrus dried pulp, citrus oil, citrus juice, sugar beet tops, sugar beet dried pulp, sugar 

beet refined sugar, and sugar beet molasses are not available. For the grape and sugar beet processed 

commodities, storage stability data are not required because the samples were analyzed within 

approximately 30 days of processing. For the other Raw Agricultural Commodities (RACs), stability

studies are available or existing data for other similar crops can be translated to substantiate the 

storage durations that were incurred. As such, there are adequate stability data available to support 

the sample storage conditions and durations incurred for all of the RACs pursuant to this petition. For 

the most part, the storage stability studies which are noted were generally conducted at -20oC whereas 

a majority of the samples were stored at <0oC prior to homogenization and then at ≤-15oC until 

analysis at the laboratory (except bananas which were stored at the laboratory at <-20oC). 

860.1400 Water, Fish, and Irrigated Crops

For the purpose of this summary, this guideline requirement is not relevant to this evaluation since 

Fluazifop-P-butyl has no registered or proposed uses on water or aquatic food and feed crops.

860.1460 Food Handling

For the purpose of this summary, this guideline requirement is not relevant to this evaluation since 

Fluazifop-P-butyl has no food-handling uses which are being proposed.

860.1480 Meat, Milk, Poultry, and Eggs

Residue Chemistry Memo, DP No. D348246, 09/16/2008, D. Soderberg (PP#7F7289 Residue Chemistry Chapter)

In evaluating the data provided to support this petition, the establishment of tolerance limits will be 

recommended for several RACs commonly recognized for use as livestock feedstuffs. This would 

include establishing tolerance limits for citrus dried pulp and sugar beet tops which are requested in 

part with this action. The maximum theoretical dietary burdens to livestock were previously

evaluated in the prior residue chemistry chapter prepared to support pending uses on dry beans and 

peanuts (DP No. D348246, D. Soderberg, 09/16/2008). The resulting theoretical dietary burdens of 
Fluazifop-P-butyl Summary of Analytical Chemistry and Residue Data DP No. 385205

Page 13 of 31

fluazifop-P-butyl to livestock were put forward with the updated version of Table 1 (Table 1 

Feedstuffs June 2008) and are presented below in Table 5 for review.

Table 5. Calculation of Dietary Burdens of Fluazifop-P-butyl Residues to Livestock.

Feedstuff Type1 % Dry 

Matter2 % Diet2 Recommended Tolerance (ppm)

Dietary Contribution 

(ppm)

3

Beef Cattle

Soybean, hulls R 90 20 2.5 0.555

Untreated CC CC NA 65 NA 0

Soybean, meal PC 92 15 2.5 0.408

TOTAL BURDEN -- -- -- 0.963

Dairy Cattle

Soybean, hulls R 90 15 2.5 0.417

Untreated R R NA 30 NA 0

Carrot, culls CC 12 10 2.0 1.667

Untreated CC CC NA 35 NA 0

Soybean, seed PC 89 15 2.5 0.421

TOTAL BURDEN -- -- -- 2.505

Poultry

Untreated CC CC NA 75 NA 0

Soybean, meal PC -- 25 2.5 0.625

TOTAL BURDEN -- -- -- 0.625

Swine

Untreated CC CC NA 85 NA 0

Soybean, meal PC -- 15 2.5 0.375

TOTAL BURDEN -- -- 0.375

1

 R: Roughage; CC: Carbohydrate concentrate; PC: Protein concentrate.

2

 OPPTS 860.1000 Table 1 Feedstuffs (June 2008). 

3

 Contribution = ([tolerance /% DM] X % diet) for beef and dairy cattle; contribution = ([tolerance] X % diet) for poultry 

and swine. 

4

 N/A: Not applicable. Tolerances/uses of Fluazifop-P-butyl have not been registered or proposed for this feedstuff. 

These calculations are considered tentative because plant and animal metabolism studies remain 

outstanding and additional field trials are required for some crops. It was also noted that there are 

label restrictions against the grazing or harvesting of peanut hay as well as soybean forage and hay

which are appropriate according to Table 1 of 860.1000. In all, the addition of the use on peanut did

not affect the theoretical dietary burden of fluazifop residues to livestock. Soybeans were found to 

have a larger impact and these matrices were incorporated into the previous dietary burden 

calculations. The effect of use on cowpea forage and hay along with residues on the soybean 

aspirated grain fractions will be evaluated after these data have been submitted. Prior calculated 

dietary burden maximums of fluazifop-P-butyl were reported to beef/dairy cattle at 4.49 ppm, 1.00 

ppm to poultry, and 0.70 ppm to swine. These differ significantly from the updated values presented 

in Table 5 due to the current calculations being based on a “reasonably balanced” diet and the 

reduction in the diet percentage for carrot culls.

 

Nonetheless, in assessing the new uses pursuant to this petition, sugar beet tops are no longer a 

contributor to the dietary burden of cattle because when updating the Table 1 Feedstuffs it was 
Fluazifop-P-butyl Summary of Analytical Chemistry and Residue Data DP No. 385205

Page 14 of 31

removed as being a significant feed item. Although in the assessment of prior actions sugar beet tops 

would have comprised a large portion of the beef and dairy cattle diet, it is no longer a factor for 

consideration in the calculation of dietary burden. With regards to dried pulp citrus, the tolerance of 

this livestock feed item is being set based on a practical maximum concentration factor of 13x. In

comparing the recommended tolerance level of 0.40 ppm for this commodity to the 2.5 ppm tolerance 

level of soybean hulls (roughage component) now in the dietary burden calculation, no increase in the 

dietary burden to livestock results. Hence, the prior calculations for secondary transfer of fluazifop-Pbutyl residues to meat, milk, poultry, and eggs remain current. 

Conclusions: No change in the tolerances of meat, milk, poultry, and eggs is needed at this time. 

860.1500 Magnitude of the Residue in Crops

DER References: 47874601.der.doc (banana)

47874602.der.doc (citrus)

R062698.tif (MRID 41373705) (citrus)

47874603.der.doc (sugar beet)

47874604.der.doc (grape)

Syngenta Crop Protection has submitted field trial data for fluazifop-P-butyl on bananas, citrus, 

grapes, and sugar beets. A summary of the residue data is presented in Table 6.

Table 6. Summary of Residue Data from Crop Field Trials with Fluazifop-P-Butyl.

Crop matrix Total Applic. 

Rate

(lb ai/A)

PHI 

(days)

Residue Levels (ppm)

N Min. Max. HAFT1 Median Mean Std. 

Dev.

Bananas (proposed use = 1.125 lb ai/A total application rate, 0-day PHI)

Banana, bagged 1.125 0 10 <0.01 <0.01 <0.01 <0.01 <0.01 N/A

Banana, unbagged 1.125 0 10 <0.01 <0.01 <0.01 <0.01 <0.01 N/A

Citrus (proposed use = 1.125 lb ai/A total application rate, 14-day PHI)

Orange 1.10 – 1.15 12-14 14 <0.012<0.01 <0.01 <0.01 <0.01 N/A

1.5 14 5 <0.033<0.03 <0.03 <0.03 <0.03 N/A

2.25 14 5 <0.03 <0.03 <0.03 <0.03 <0.03 N/A

Lemon 1.5 14 5 <0.03 <0.03 <0.03 <0.03 <0.03 N/A

2.25 14 5 <0.03 <0.03 <0.03 <0.03 <0.03 N/A

Grapefruit 1.14 12-14 2 <0.01 <0.01 <0.01 <0.01 <0.01 N/A

1.5 14 5 <0.03 <0.03 <0.03 <0.03 <0.03 N/A

2.25 14 5 <0.03 <0.03 <0.03 <0.03 <0.03 N/A

Grapes (proposed use = 1.125 lb ai/A total application rate, 50-day PHI)

Grapes 1.11 – 1.16 49-50 24 <0.01 <0.01 <0.01 <0.01 <0.01 N/A

Sugar beets (proposed use = 0.75 lb ai/A total application rate, 90-day PHI)

Sugar beet, top 0.747-0.764 89-90 24 0.02 1.45 1.01 0.390 0.425 0.277

Sugar beet, root 0.747-0.764 89-90 24 <0.01 0.23 0.215 0.070 0.080 0.051

1

 HAFT = Highest average field trial result.

2

 LOQ of the GC/MS method used for the quantitation of the sample results noted.

3

 LOQ of the 19F NMR method used for the quantitation of the sample results noted.
Fluazifop-P-butyl Summary of Analytical Chemistry and Residue Data DP No. 385205

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Banana (MRID No. 47874601)

Five field trials were conducted in/on bagged and unbagged bananas in the United States during the 

1999 growing season. The trials were conducted in Zone 3 (1 trial in Florida) and Zone 13 (4 trials in 

Hawaii). For each trial, three applications of the 2 lb/gal EC formulation of fluazifop-P-butyl were 

made at a target rate of 0.375 lbs fluazifop-p-butyl/acre for a total seasonal rate of 1.125 lb a.i./acre.

All applications were made in spray volumes of 17 to 29 gal/A (GPA) using ground-based equipment. 

An adjuvant was added to the spray mixture for all applications (non-ionic surfactant or crop oil 

concentrate). Each test site consisted of a control and treated plot for both bagged and unbagged 

bananas. Applications were made by broadcast spray to the soil at 60, 30, and 0 days prior to normal 

harvest. Banana whole fruit samples were collected at the normal harvest which was immediately

following the last application (PHI of 0 days). 

Residues of fluazifop-p-butyl, fluazifop, and conjugate esters in bananas were determined as total 

fluazifop using ABC method 45820-M-1. This method is a modification of the Zeneca method 

entitled “Determination of Total Fluazifop in Crops by Gas Chromatography.” The LOQ for total 

fluazifop residues was set at 0.01 ppm. The method was adequate for data collection based on 

concurrent method recoveries. 

Sample storage conditions and durations incurred for this study which support this action are reported 

in Table 4. No storage stability data have been submitted for bananas specifically. Nonetheless, the 

stability of fluazifop-P-butyl has been investigated in a wide variety of frozen crop commodities and 

documented in several prior reports generated by the registrant. These reports show residues are 

stable in/on soybeans, sugar beets, green beans, strawberries, oilseed rape, coffee, cauliflower, onions, 

potatoes, peanuts, macadamia nuts, tomatoes, endive, and celery for durations of 3 to 28 months.

Following three applications of fluazifop-p-butyl at a seasonal target application rate of 1.125 lbs 

ai/A, residue levels (reported as total fluazifop) were below the LOQ (0.01 ppm) in all bagged and 

unbagged samples of whole bananas (PHI of 0 days). 

Conclusions: The submitted residue data for bananas are adequate in fulfilling these data 

requirements. The number and locations of the field trials are in accordance with OPPTS Guideline 

860.1500 for bananas. The trials were made to appropriately reflect the proposed maximum seasonal 

use pattern. Adequate stability data available for other similar crops can be translated to substantiate 

the storage conditions and durations that were incurred. Based on the LOQ, the best estimate for a 

tolerance for bananas is 0.01 ppm.

Citrus (MRID No. 41373705)

A total of fifteen field trials were conducted in the United States during the 1986 growing season 

in/on oranges (n=5), grapefruit (n=5), and lemons (n=5). For oranges, 5 trials were conducted in 

Zone 3 (Florida). For the grapefruit and lemons, 2 trials were conducted in Zone 3 (Florida), 1 trial in 

Zone 6 (Texas), and 2 trials in Zone 10 (1 trial in California and 1 trial in Arizona). For each trial, 

two treated test plots were established. One plot received three applications of the 2 lb/gal EC 

formulation of fluazifop-P-butyl at a target rate of 0.5 lbs fluazifop-p-butyl/acre for a total seasonal 

rate of 1.5 lb ai/acre. The other plot received three applications of the 2 lb/gal EC formulation of 

fluazifop-P-butyl at a target rate of 0.75 lbs fluazifop-P-butyl/acre for a total seasonal rate of 2.25 lb 
Fluazifop-P-butyl Summary of Analytical Chemistry and Residue Data DP No. 385205

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ai/acre. The three applications were made at approximate 21 day re-treatment intervals using ground 

equipment that directed the spray to the ground beneath the trees. Citrus fruit were harvested 14 days 

after the last application. 

The analytical method used for data collection was ICI Plant Protection Method 82. The method 

performed extraction with acetonitrile:concentrated HCl to convert residues to fluazifop. The 

procedure employed similar clean-up steps as those specified in PAM II method, but final 

determination using this protocol is made by 19F NMR analysis. Residues in citrus were reported as 

total fluazifop. The LOQ for total fluazifop residues was set at 0.03 ppm. This method is adequate 

for data collection based upon acceptable concurrent recovery data from oranges, grapefruit, and 

lemons fortified at 0.05 ppm and 1.0 ppm. 

Sample storage conditions and durations incurred for this study which support this action are reported 

in Table 4. Samples of citrus fruit were analyzed within 25 months of harvest. No storage stability

data have been submitted for citrus specifically. Nonetheless, the stability of fluazifop-P-butyl has 

been investigated in a wide variety of frozen crop commodities and documented in several prior 

reports generated by the registrant. These reports show residues are stable in/on soybeans, sugar 

beets, green beans, strawberries, oilseed rape, coffee, cauliflower, onions, potatoes, peanuts, 

macadamia nuts, tomatoes, endive, and celery for durations of 3 to 28 months.

Following the applications of fluazifop-p-butyl at a seasonal target application rate of 1.5 lbs ai/A and 

at 2.25 lb ai/A, fluazifop-p-butyl residues (reported as total fluazifop) were below the LOQ (0.03

ppm) in oranges, grapefruit and lemon (PHI 14 days). 

Citrus (MRID No. 47874602)

A total of eight field trials were conducted in the United States during the 2000 growing season in/on 

oranges (n=7) and grapefruit (n=1). For oranges, 3 trials were conducted in Zone 3 (Florida), 1 trial 

in Zone 6 (Texas), and 3 trials in Zone 10 (1 trial in Arizona; 2 trials in California). For grapefruit, 1 

trial was conducted in Zone 3 (Florida). For each trial, three applications of the 2 lb/gal EC 

formulation of fluazifop-P-butyl were made at a target rate of 0.375 lbs fluazifop-P-butyl/acre for a 

total seasonal rate of 1.125 lb ai/acre. Each test site consisted of a untreated control and treated test 

plots. The three applications were made by broadcast spray to the orchard soil beneath the trees, 19 to 

21 days apart and citrus fruit were harvested 12 to 14 days after the last application (PHI of 12 to 14 

days). Applications were made using ground equipment in 19 to 26 gal/A spray volumes with an 

adjuvant (non-ionic surfactant or crop oil concentrate).

Residues of fluazifop-P-butyl and fluazifop-P were extracted by hydrolyzing the ester or acid 

conjugates to fluazifop which are then derivatized to the methyl ester and analyzed by GC/MS. 

Residues in citrus were reported as total fluazifop. The LOQ for total fluazifop residues was set at 

0.01 ppm. This method is adequate for data collection based upon acceptable method validation 

recovery data in grapes at the 0.01 ppm and 1.0 ppm fortification levels and concurrent recovery data 

in citrus at the 0.01 ppm fortification level. The average concurrent recovery at the 1.0 ppm 

fortification level was only 68.4% which is slightly outside the generally acceptable range of 70 to 

120%. However, this is not a concern because the 0.01 ppm fortification level more accurately

reflects the residue levels in the RAC samples than does the 1.0 ppm fortification level.

The samples were stored frozen from collection through analysis with the storage conditions and 
Fluazifop-P-butyl Summary of Analytical Chemistry and Residue Data DP No. 385205

Page 17 of 31

durations incurred for this study being reported in Table 4. The maximum storage interval from 

sampling to extraction was 71 days (2.4 months). All sample extracts were analyzed within 1 day of 

extraction. No storage stability data have been submitted for citrus specifically. Nonetheless, the 

stability of fluazifop-P-butyl has been investigated in a wide variety of frozen crop commodities and 

documented in several prior reports generated by the registrant. These reports show residues are 

stable in/on soybeans, sugar beets, green beans, strawberries, oilseed rape, coffee, cauliflower, onions, 

potatoes, peanuts, macadamia nuts, tomatoes, endive, and celery for durations of 3 to 28 months.

Following 3 treatments of fluazifop-p-butyl at the seasonal application rate of 1.125 lbs ai/A, residues

(reported as total fluazifop) were below the 0.01 ppm LOQ in oranges and grapefruit (12-14 day PHI). 

Conclusions: By combining the 1986 and 2000 trials, the submitted data are adequate in fulfilling the 

test guideline requirements for citrus. The number and locations of the field trials follow OPPTS 

Guideline 860.1500 for citrus fruit crop group 10 (12 orange, 6 grapefruit & 5 lemon trials). They

generally reflect the proposed maximum seasonal use pattern, although the trials made in 1986 

(MRID No. 41373705) were performed at a 1.3x and 2x greater rate. Adequate stability data 

available for other similar crops can be translated to substantiate the storage conditions and durations 

that were incurred. Based on the LOQ, a 0.03 ppm tolerance is estimated for citrus and a revised 

section F should be submitted specifying this recommend limit. 

Grapes (MRID No. 47874604)

Twelve field trials were conducted on grapes during the 2000 growing season, encompassing Zone 1 

(2 trials in NY), 10 (8 trials in CA), and 11 (1 trial in OR and 1 trial in WA). Separate untreated 

control and treated test plots were established at each trial site. At each test location, three broadcast 

spray applications of the 2 lb/gal EC formulation of fluazifop-P-butyl were made to the vineyard floor 

beneath the grape vines at a target application rate of 0.375 lb ai/A/application, for a total target 

seasonal rate of 1.125 lb ai/A. Applications were made 12 to 15 days apart in spray volumes of 10 to 

30 gal/A at 9 trial sites and 8 to 10 gal/A at 3 trial sites. Adjuvants (non-ionic surfactant or crop oil 

concentrate) were used at all the sites and the grapes subsequently harvested at a PHI of 49-50 days. 

Samples of grapes were analyzed for total fluazifop residues (fluazifop-P-butyl, fluazifop free and 

conjugated) using a GC/MS protocol. This procedure is a common moiety method which hydrolyzes 

any ester or acid conjugates and treats the resulting extract to form the methyl ester of fluazifop so 

that a total determination can be made. This method is adequate for data collection based upon 

acceptable method validation and concurrent method recoveries. The validated LOQ was 0.01 ppm 

for grapes. 

Sample storage conditions and durations incurred for this study which support this action are reported 

in Table 4. Samples were stored frozen for a maximum duration of 45 days (1.5 months) from 

harvest to analysis. Samples from all but three sites were extracted within one month of harvest. All 

sample extracts were analyzed within 1 day of extraction. No storage stability data have been 

submitted for grapes specifically. Nonetheless, the stability of fluazifop-P-butyl has been investigated 

in a wide variety of frozen crop commodities and documented in several prior reports generated by

the registrant. These reports show residues are stable in/on soybeans, sugar beets, green beans, 

strawberries, oilseed rape, coffee, cauliflower, onions, potatoes, peanuts, macadamia nuts, tomatoes, 

endive, and celery for durations of 3 to 28 months. Alternately, stability data are not required for 
Fluazifop-P-butyl Summary of Analytical Chemistry and Residue Data DP No. 385205

Page 18 of 31

samples that are stored frozen for less than 30 days, which includes the majority of the samples in this 

study. As such, the available stability data support the sample storage durations/conditions incurred 

for the crop field trials made on grapes.

Residues of total fluazifop were <LOQ (0.01 ppm) in/on grapes harvested 49 to 50 days after the last 

of three vineyard floor applications of the 2 lb/gal EC formulation at a total rate of 1.11 to 1.16 lb 

ai/A/season. 

Conclusions. The submitted residue data for grapes are adequate in fulfilling these data requirements. 

The trials were made to appropriately reflect the proposed maximum seasonal use pattern. Adequate 

stability data available for other similar crops can be translated to substantiate the storage conditions 

and durations that were incurred. Based on the LOQ, the best estimate for a tolerance for grapes is 

0.01 ppm.

Sugar beet (MRID No. 47874603)

Twelve field trials were conducted on sugar beets during the 2000 growing season, encompassing 

Zones 5 (2 trials in MN, 2 trials in ND, and 1 trial in WI), 7 (1 trial in NE), 8 (1 trial in KS), 9 (1 trial 

in MT), 10 (2 trials in CA), and 11 (1 trial in ID and 1 trial in WA). Separate untreated control and 

treated test plots were established at each trial site. At each test location, two foliar broadcast spray

applications of the 2 lb/gal EC formulation of fluazifop-P-butyl were made to sugar beets at a target 

application rate of 0.375 lb ai/A/application, for a total target seasonal rate of 0.75 lb ai/A. 

Applications were made at 12- to 14-day retreatment intervals in spray volumes of 10 to 30 gal/A at 9 

trial sites and 8 to 10 gal/A at the other 3 trial sites. Adjuvants (non-ionic surfactant or crop oil 

concentrate) were used at all sites and the sugar beets subsequently harvested at a PHI of 89 to 90 

days. 

Samples of sugar beet tops and roots were analyzed for total fluazifop residues (fluazifop-P-butyl, 

fluazifop free and conjugated) using a GC/MS protocol. This procedure is a common moiety method 

which hydrolyzes any ester or acid conjugates and treats the resulting extract to form the methyl ester 

of fluazifop so that a total determination can be made. This method is adequate for data collection 

based upon acceptable method validation and concurrent method recoveries. The LOQ was 0.01 ppm 

for sugar beet tops and roots. 

Sample storage conditions and durations incurred for this study which support this action are reported 

in Table 4. Samples were stored frozen for a maximum of 75 days (2.5 months) from harvest to 

analysis. All sample extracts were analyzed within 2 days of extraction. The available storage 

stability data demonstrate that residues of fluazifop are generally stable in/on sugar beet roots stored 

frozen for up to 12 months (MRID No. 00157193). Storage stability data are also available which 

demonstrate that residues of fluazifop are stable in/on a wide variety of other crop matrices for 3 to 28 

months. The available storage data support the sample storage durations/conditions incurred for the 

crop field trials made on sugar beet tops and roots.

For the application program tested, samples were harvested 89 to 90 days after the last of two 

broadcast foliar applications made with the 2 lb/gal EC formulation at total rates of 0.747-0.764 lb 

ai/A/season. In accordance, maximum residues of total fluazifop were found to be 1.45 ppm in/on 

sugar beet tops and at 0.23 ppm for the roots.
Fluazifop-P-butyl Summary of Analytical Chemistry and Residue Data DP No. 385205

Page 19 of 31

Conclusions. The submitted residue data for sugar beets are adequate in fulfilling these data 

requirements. The trials were made to appropriately reflect the proposed maximum seasonal use 

pattern. Adequate stability data are available for this RAC to substantiate the storage conditions and 

durations that were incurred. The residue data for sugar beets were entered into the Agency’s 

tolerance spreadsheet as specified by the Guidance for Setting Pesticide Tolerances Based on Field 

Trial Data SOP to determine an appropriate tolerance level (Appendix I). The spreadsheet provides a 

best estimate of a tolerance at 0.25 ppm for sugar beet roots. In regard to sugar beet tops, no tolerance 

will be required for this commodity since it is no longer considered to be a significant food or feed 

item. A revised Section F should therefore be submitted to include only the HED-recommended 

tolerance of 0.25 ppm for residues in/on sugar beet roots.

860.1520 Processed Food and Feed

DER References: R062698.tif (MRID No. 41373705) (citrus)

47874605.der.doc (grapes)

47874606.der.doc (sugar beets)

Syngenta Crop Protection has submitted processing studies for fluazifop-P-butyl on citrus, grapes, 

and sugar beets. A summary of the processing factors is presented below in Table 7 for review.

Table 7. Summary of Processing Factors for Fluazifop-P-Butyl.

RAC Processed Commodity Processing Factor

Grapes Raisins ≤1x

Juice ≤1x

Sugar beets Refined Sugar 0.36x

Dried Pulp 3.9x

Molasses 14x

Citrus (MRID No. 41373705) 

In a single citrus (orange) trial conducted in FL during the 1986 growing season using the 2 lb/gal EC 

formulation of fluazifop-P-butyl. For this test program, three applications were made at the nominal 

rate of 3.75 lb ai/A/application, for a total seasonal rate of 11.25 lb ai/A (10x the maximum proposed 

seasonal rate for citrus). Applications were made at 21 day intervals using ground equipment, with 

the spray directed to the ground beneath and around the trees. Samples of oranges were harvested 14

days after the last application and processed into chopped peel, dried pulp, molasses, juice, and oil.

The analytical method used for data collection was ICI Plant Protection Method 82. The method 

performed extraction with acetonitrile:concentrated HCl to convert residues to fluazifop. The 

procedure employed similar clean-up steps as those specified in PAM II method, but final 

determination using this protocol is made by 19F NMR analysis. Residues in citrus are reported as 

total fluazifop. The LOQ for total fluazifop residues was set at 0.03 ppm. This method is adequate 

for data collection based upon acceptable concurrent recoveries from the matrices fortified at 0.05 

ppm. Sample storage conditions and durations incurred for this study which support this action are 

reported in Table 4. 
Fluazifop-P-butyl Summary of Analytical Chemistry and Residue Data DP No. 385205

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Samples of citrus fruit were analyzed within 25 months of harvest. No storage stability data have 

been submitted for citrus specifically. Nonetheless, the stability of fluazifop-P-butyl has been 

investigated in a wide variety of frozen crop commodities and documented in several prior reports 

generated by the registrant. These reports show residues are stable in/on soybeans, sugar beets, green 

beans, strawberries, oilseed rape, coffee, cauliflower, onions, potatoes, peanuts, macadamia nuts, 

tomatoes, endive, and celery for durations of 3 to 28 months.

Total fluazifop residues were <LOQ (0.03 ppm) in/on the whole oranges treated with fluazifop-Pbutyl at a total of 11.25 lb ai/A. Following processing of the whole oranges, total fluazifop residues 

were 1.7 ppm in chopped peel, 2.6 ppm in dried pulp, 0.09 ppm in molasses and oil, and <LOQ (0.03 

ppm) in juice. Based on these data, processing factors would be 87x in dried pulp, 3x in oil, and <1x 

in juice. However, the Petitioner states that processing factor in dried pulp is unreasonable 

considering that oranges contain about 86% water. Therefore, the Petitioner calculated processing 

factors by assuming that the residue in the whole oranges was 0.65 ppm, as calculated from the total 

residue found in the processed commodities and the weight of the starting oranges. The resulting 

reported processing factors were 4x for dried pulp, 2.6x for peel, 1.7x for molasses, and 0.14x for oil.

Conclusions: EPA previously concluded that proposed tolerances in citrus fruit and dried citrus 

cannot be determined (DEB No. 6343, M. J. Bradley, 08/15/1990). Rather then attempting to upgrade 

these results, it would be prudent for the petitioner to provide a new study given the age of this data 

submission. To satisfy the establishment of tolerances for the citrus processed commodities, the 

theoretical concentration factors are therefore used for setting the pertinent limits on juice (2x) and oil 

(1000x). These factors along with the citrus HAFT of 0.03 ppm, determine that an appropriate 

fluazifop-P-butyl tolerance for citrus juice would be 0.06 ppm and 30.0 ppm for the oil fraction. In 

regard to citrus dried pulp, there is no theoretical concentration factor determined for this processed 

commodity. Nonetheless, in a recent action made for chlorantraniliprole, a snap-shot of 27 pesticides 

having citrus dried pulp limits was made to determine a practical maximum concentration factor for 

this processed commodity (DP No. D361791, D. Rate, 01/08/2010). This determination found that 

concentration factors range between 2-13x for the citrus dried pulp tolerances which were examined. 

Therefore, using the maximum concentration factor of 13x for fluazifop along with the citrus HAFT 

of 0.03 ppm, a resulting tolerance of 0.40 ppm should be set for the citrus dried pulp processed 

commodity. 

Grapes (MRID No. 47874605) 

A single field trial was conducted during the 2000 growing season on grapes, encompassing Zone 10

(1 trial in CA). Separate untreated control and treated test plots were established at the trial site. 

Three broadcast spray applications of the 2 lb/gal EC formulation of fluazifop-P-butyl were made to 

the vineyard floor beneath the grape vines to conduct this trial. Treatments were made at a target 

application rate of 1.875 lb ai/A/application, with a 14-day retreatment interval (RTI), for a total 

target seasonal rate of 5.63 lb ai/A (5x the maximum application rate). Grapes were harvested 50 

days after final treatment. The grape RACs were processed into grape juice and raisins.

Samples of the grape RAC and its processed commodities were analyzed for total fluazifop residues 

(fluazifop-P-butyl, fluazifop free and conjugated) using a GC/MS protocol. This procedure is a 
Fluazifop-P-butyl Summary of Analytical Chemistry and Residue Data DP No. 385205

Page 21 of 31

common moiety method which hydrolyzes any ester or acid conjugates and treats the resulting extract 

to form the methyl ester of fluazifop so that a total determination can be made. This method is 

adequate for data collection based upon acceptable method validation and concurrent method 

recoveries. The LOQ was 0.01 ppm for all grape matrices. 

Sample storage conditions and durations incurred for this study which support this action are reported 

in Table 4. Samples were stored frozen from harvest to extraction for up to 36 days (1.2 months) for 

grapes, 29 days (1 month) for grape juice, and 43 days (1.4 months) for raisins. The storage duration 

between processing and extraction was 33 days for grapes, 26 days for grape juice, and 30 days for 

raisins. Samples were analyzed within 0-2 days of extraction. No storage stability data have been 

submitted for grapes specifically. Nonetheless, the stability of fluazifop-P-butyl has been investigated 

in a wide variety of frozen crop commodities and documented in several prior reports generated by

the registrant. These reports show residues are stable in/on soybeans, sugar beets, green beans, 

strawberries, oilseed rape, coffee, cauliflower, onions, potatoes, peanuts, macadamia nuts, tomatoes, 

endive, and celery for durations of 3 to 28 months.

Total fluazifop residues were found to be <LOQ (0.01 ppm) in/on the grape RAC harvested 50 days 

after the last of three treatments made at a 5x seasonal application rate (5.64 lb ai/A/season). Total 

fluazifop residues were also found to be <LOQ (0.01 ppm) in/on the grape juice and raisin processed 

grape fractions. As such, the observed processing factors for grape juice and raisins are less than the 

theoretical concentration factor of 4.7x for raisins (based on the loss of water on processing grapes 

into raisins; OPPTS 860.1520, Table 1) and 1.2x for grape juice (based on separation of components; 

OPPTS 860.1520, Table 3).

Conclusions: The grape processing data are adequate in fulfilling these data requirements. These

data indicate that total fluazifop residues do not appear to concentrate in raisins or grape juice. As a 

result, no tolerance is therefore needed for raisins or grape juice.

Sugar beets (MRID No. 47874606) 

A single field trial was conducted on sugar beets during the 2000 growing season, encompassing 

Zone 11 (1 trial in WA). Separate untreated control and treated test plots were established at the trial 

site. Two foliar broadcast spray applications using the 2 lb/gal EC formulation of fluazifop-P-butyl 

were made to sugar beets to conduct this trial. Treatments were made at a target application rate of 

1.875 lb ai/A/application, with a 14-day RTI, for a total target seasonal rate of 3.75 lb ai/A (5x the 

maximum application rate). Sugar beets were harvested 90 days after final treatment. The sugar beet

RAC was processed into refined sugar, dry pulp and molasses.

Samples of the sugar beet RAC and its processed commodities were analyzed for total fluazifop 

residues (fluazifop-P-butyl, fluazifop free and conjugated) using a GC/MS protocol. This procedure 

is a common moiety method which hydrolyzes any ester or acid conjugates and treats the resulting 

extract to form the methyl ester of fluazifop so that a total determination can be made. This method is 

adequate for data collection based upon acceptable method validation and concurrent method 

recoveries. The validated LOQ was 0.01 ppm for all sugar beet matrices. 

Sample storage conditions and durations incurred for this study which support this action are reported 

in Table 4. Samples were stored frozen from harvest to extraction for 48 days (1.6 months) for sugar 
Fluazifop-P-butyl Summary of Analytical Chemistry and Residue Data DP No. 385205

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beet roots, and dry pulp, 48 to 51 days (1.6 to 1.7 months) for molasses, and 53 days (1.8 months) for 

refined sugar. The storage duration between processing and extraction was 28 to 31 days for 

molasses, 32 days for sugar beet roots, 32 to 33 days for dry pulp, and 33 days for refined sugar. 

Samples were analyzed on the day of extraction. Storage stability data demonstrate that residues of 

fluazifop are generally stable in/on sugar beet roots stored frozen for up to 12 months (MRID No. 

00157193). Although no storage stability studies are available for the sugar beet processed fractions 

of sugar beets, no data are required since extraction/analysis occurred within approximately 30 days 

from processing. 

Average total fluazifop residues were found to be 0.86 ppm in/on the sugar beet RAC (root) harvested 

90 days after the last of two broadcast foliar treatments made at a 5x seasonal application rate (3.79 lb 

ai/A/season). In processed sugar beet fractions, average total fluazifop residues were found to be 0.31 

ppm in refined sugar, 3.35 ppm in the dry pulp, and 12 ppm in molasses. A comparison of the 

residues in the RAC with those in each processed fraction resulted in concentration factors of 0.36x 

for refined sugar, 3.9x for dry pulp, and 14x for molasses. These concentration factors are consistent 

with the theoretical concentration factor of 12.5x for sugar (based on separation of components; 

OPPTS 860.1520, Table 3) and the maximum observed concentration factor of 20x (OPPTS 

860.1520, Table 4) for dry pulp and molasses.

Conclusions: The sugar beet processing data are adequate in fulfilling these data requirements. 

These data indicate that total fluazifop residues do not appear to concentrate in sugar beet refined 

sugar, but may concentrate in sugar beet dried pulp and sugar beet molasses. Based on the sugar beet

root HAFT (0.22 ppm) and the average processing factor for dried pulp (3.9x) and molasses (14x), 

expected residues in these fractions are 0.86 ppm and 3.1 ppm, respectively. Likewise, no tolerance is 

needed for the sugar beet refined sugar processed commodity. As a result, the proposed tolerances of 

1.0 ppm in dried pulp and 3.5 ppm for molasses are adequate for these sugar beet processed 

commodities.

860.1650 Submittal of Analytical Reference Standards

Analytical standards for fluazifop-P-butyl and fluazifop-P (resolved (R) isomer of fluazifop acid) are

currently available in the EPA National Pesticide Standards Repository. The fluazifop-P-butyl 

standard expires 1/1/2011. Analytical reference standards must be replenished as requested by the 

Repository. The reference standards should be sent to the Analytical Chemistry Lab, which is located 

at Fort Meade, to the attention of either Theresa Cole or Thuy Nguyen at the following address:

USEPA

National Pesticide Standards Repository/Analytical Chemistry Branch/OPP

701 Mapes Road

Fort George G. Meade, MD 20755-5350

(Note that the mail will be returned if the extended zip code is not used.)
Fluazifop-P-butyl Summary of Analytical Chemistry and Residue Data DP No. 385205

Page 23 of 31

860.1850/860.1900 Confined and Field Accumulation in Rotational Crops

The following plantback restriction exists on the product label (EPA Reg. No. 100-1070): a 60-day

plantback interval for rotational crops such as corn, sorghum, and cereals. This plantback interval is 

also appropriate for sugar beet.

860.1550 Proposed Tolerances

In a meeting on March 3, 2004, the MARC concluded that for tolerance expression, parent and 

fluazifop-acid (free and conjugated) are the residues of concern since they are adequate to determine 

misuse (DP No. D298939, S. L. Kinard, 06/22/2004). An acceptable soybean metabolism study is 

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

undergoing Agency review. In accordance, tolerances are established under 40 CFR §180.411(a)(1) 

and (c)(1) for residues of fluazifop-butyl, including free and conjugated fluazifop, expressed as 

fluazifop. For fluazifop-P-butyl, including free and conjugated fluazifop (R isomer), tolerances are 

likewise established under 40 CFR §180.411(a)(2) and (c)(2) with residues expressed as fluazifop. Its 

registered uses include dry beans, carrot, cotton, endive (escarole), macadamia nut, onion, peanut, 

pecan, soybean, spinach, stone fruit, and sweet potato. It also carries tolerances with regional 

registrations on asparagus, coffee, pepper, and rhubarb along with being registered for use on lawns as 

a weed control application.

For this action, field trials on bananas, citrus, grapes, and sugar beets along with corresponding 

studies made on the pertinent processed commodities were submitted to support this petition request. 

In evaluating the field trials provided by the registrant, these studies were found to be adequate in

satisfying these residue chemistry data requirements. In regard to the banana, grape, and citrus RACs, 

residues levels in all of the treated samples analyzed were found to be below the LOQ of the test 

method. As such, the proposed tolerance of 0.01 ppm specified by the registrant for bananas and 

grapes is acceptable. Following this approach a revised tolerance of 0.03 ppm for citrus based upon 

the corresponding LOQ of the test method is therefore recommended instead of the 0.05 ppm level 

proposed by the registrant. Total fluazifop residues in/on sugar beet RACs were found to be readily

quantifiable at levels greater then the LOQ of the test method. In accordance, the Agency’s Guidance 

for Setting Pesticide Tolerances Based on Field Trial Data was utilized for determining appropriate 

tolerance levels for sugar beet roots (Appendix I). Based on these calculations, the proposed sugar 

beet tolerance of 0.25 in roots is adequate.

In evaluating of the corresponding processing study data that were provided, it can be concluded that 

no additional tolerances are needed for grape juice and raisins as well as sugar beet refined sugar. 

However, residues of fluazifop were found to concentrate in sugar beet dry pulp (3.9x) and sugar beet

molasses (14x). Based on the sugar beet root HAFT of 0.22 ppm and the processing factors

calculated for dried pulp and molasses, expected residues in these fractions are 0.86 ppm and 3.1

ppm, respectively. As a result, the tolerances of 1.0 ppm in dried pulp and 3.5 ppm for molasses 

proposed by the registrant are adequate for these sugar beet processed commodities. 

For the citrus processed commodities, the petitioner has also proposed tolerances of 0.40 ppm in dried

pulp along with 0.05 ppm in juice and oil. However, EPA previously concluded that proposed 

tolerances in citrus fruit and dried citrus cannot be determined (DEB No. 6343, M. J. Bradley, 

08/15/1990). Rather then attempting to upgrade these results, it would be prudent for the petitioner to 
Fluazifop-P-butyl Summary of Analytical Chemistry and Residue Data DP No. 385205

Page 24 of 31

provide a new study given the age of this data submission. To satisfy the establishment of tolerances 

for the citrus processed commodities, the theoretical concentration factors are therefore used for 

setting the pertinent limits on juice (2x) and oil (1000x). These factors along with the citrus HAFT of 

0.03 ppm, determine that an appropriate fluazifop-P-butyl tolerance for citrus juice would be 0.06 

ppm and 30.0 ppm for the oil fraction. In regard to citrus dried pulp, there is no theoretical 

concentration factor determined for this processed commodity. Using a practical maximum 

concentration factor of 13x as identified in a recent chlorantraniliprole action, along with the citrus 

HAFT of 0.03 ppm, a fluazifop-P-butyl tolerance of 0.40 ppm for citrus, dried pulp is appropriate.

The current petition requests the establishment of tolerances on dried pulp citrus and sugar beet tops, 

commodities which have been considered livestock feedstuffs. Following revision of the Table 1 

Feedstuffs in 2008, sugar beet tops were removed as being a significant feed item, and thus it no 

longer contributes to the dietary burden of cattle. The potential contribution of citrus dried pulp to the 

livestock dietary burden was considered by assuming a concentration factor of 13x and comparing the 

resulting residue contribution to that of soybean hulls, the current roughage component in the dietary

burden calculation. Since soybean hulls has a higher tolerance than the recommended tolerance level 

of dried pulp citrus, the current tolerances on meat, milk, poultry, and eggs are considered adequate 

and should remain unchanged. This conclusion should be re-examined upon receipt of the requested 

processing study for citrus. 

The established tolerances for livestock commodities are 0.05 ppm for total fluazifop residues in milk 

and the meat and meat byproducts of cattle, goat, hog, horse, and sheep, and fat, meat and meat 

byproducts of poultry. These levels remain appropriate.

The available residue data provided for fluazifop-P-butyl are adequate to support the establishment of 

new permanent tolerance levels recommended for the RACs proposed in this action. There are no 

Codex, Canadian or Mexican established Maximum Residue Limits (MRLs) for residues of fluazifopP-butyl in/on bananas, citrus, grapes and sugar beets. As a result, international harmonization is not 

an issue for this data evaluation concerning any of these crops. The proposed tolerances should 

therefore be revised and a new Section F submitted to reflect the recommended tolerance levels and 

correct commodity definitions specified below in Table 8.

Table 8. Tolerance Summary for Fluazifop-P-butyl.

Commodity Established 

Tolerance 

(ppm)

Proposed 

Tolerance 

(ppm)

Recommended 

Tolerance (ppm)

Comments; Correct Commodity Definition

Tolerances Proposed for 40 CFR §180.411(a)(1)

Banana -- 0.01 0.01

Citrus -- 0.05 0.03 Fruit, citrus, group 10-10

Citrus, oil -- 0.05 30.0

Citrus, dried pulp -- 0.40 0.40

Citrus, juice -- 0.05 0.06

Grapes -- 0.01 0.01

Beet, sugar, root -- 0.25 0.25

Beet, sugar, top -- 1.5 None Removed from Table 1 Feedstuffs, June 2008

Beet, sugar, dried pulp -- 1.0 1.0

Beet, sugar, molasses -- 3.5 3.5
Fluazifop-P-butyl Summary of Analytical Chemistry and Residue Data DP No. 385205

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References

DP No.: D319907

Subject: Fluazifop-P-butyl. REVISED TRED – Report on FQPA Tolerance Reassessment 

Progress and Interim Risk Management Decisions. Residue Chemistry

Considerations. Case No. 2285.

From: S. L. Kinard

To: D. Locke

Dated: 08/17/2005

MRID Nos.: 00093840-1, 00093843, 00093845, 00137763, 00144014, 00151494, 00157191, 

001517193, 40140401, 40241901, 40341601, 40361104, 40361108, 40361111, 

40693108, 40725701, 40831303-5, 40831307, 40831309-10, 41018001, 41373703.

DP No.: D298939

Subject: Fluazifop-P-butyl. Report of the Metabolism Assessment Review Committee. 

From: S. L. Kinard

To: Y. Donovan

Dated: 03/17/2004

MRIDs: None

DP No.: None

Subject: PP#0F3842/FAP#0H5596. Fluazifop-P-butyl on Citrus. Evaluation of Analytical 

Methods and Residue Data. MRID Nos. 41373701-06. DEB No. 6343. Hed Project 

No. 0-0683.

From: M. J. Bradley

To: J. Miller

Dated: 08/15/1990

MRID Nos.: 41373701 - 41373706.

DP No.: D361791

Subject: Chlorantraniliprole. Amended Section 3 Registration Request for Uses on Various 

Field, Vegetable, and Fruit Crops and Discussion of Future Registration and Tolerance 

Requests. Summary of Analytical Chemistry and Residue Data.

From: D. Rate

To: V. Eagle and K. Davis

Dated: 01/08/2010

MRID Nos.: 47588201-11 and 47588214-29
Fluazifop-P-butyl Summary of Analytical Chemistry and Residue Data DP No. 385205

Page 26 of 31

DP No.: D348246

Subject: Fluazifop-P-Butyl. Section 3 Registration Request to Add New Uses on Beans (Dry), 

Peanuts and Soybeans. Summary of Analytical Chemistry and Residue Data.

From: D. Soderberg

To: J. Miller

Dated: 9/16/2008

MRID Nos.: 47285501-05; 46412503

MRID No.: 00157193 Atreya, N. C. and Froggatt, D. A. (1983) Reside Data Report No. 

PP009B157 Storage Stability Study; Sugar beet, Strawberries, Oilseed Rape, Green 

Beans and Cauliflower. Study Number: PP009BC04. Unpublished study prepared by

Imperial Chemical Industries PLC Plant Protection Division. 22 pages.

Attachments: 

International Residue Limit Status sheet

Appendix I - Tolerance Assessment Calculations

Template Version September 2005
Fluazifop-P-butyl Summary of Analytical Chemistry and Residue Data DP No. 385205

Page 27 of 31

International Residue Limits 

Fluazifop-P-butyl (122809; 08/26/2010)

Summary of US and International Tolerances and Maximum Residue Limits 

Residue Definition:

US Canada Mexico2 Codex3

40 CFR 180.411:

Plant/Livestock: butyl(R)-2-[4-[[5-

(trifluoromethyl)-2-

pyridinyl]oxy]phenoxy]propanoate, and 

the free and conjugated forms of the 

resolved isomer of fluazifop, (R)-2-[4-[[5-

(trifluoromethyl)-2-

pyridinyl]oxy]phenoxy]propanoic acid, 

expressed as fluazifop.

butyl (RS)-2-[4-[[5-

(trifluoromethyl-2-

pyridinyl]oxy]phenoxy]

propanoate

(calculated as acid)

None

Commodity1 Tolerance (ppm) /Maximum Residue Limit (mg/kg)

US Canada Mexico2 Codex

Banana 0.01 None None

Fruit, citrus, crop group 10 0.03

Citrus, dried pulp 0.40

Citrus, juice 0.06

Citrus, oil 30.0

Grapes 0.01

Beet, sugar, root 0.25

Beet, sugar, dried pulp 1.0

Beet, sugar, molasses 3.5

Completed: M. Negussie/08/30/2010

1

Includes only commodities of interest for this action. Tolerance values should be the HED recommendations and not 

those proposed by the applicant.

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

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

postharvest treated 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.
Fluazifop-P-butyl Summary of Analytical Chemistry and Residue Data DP No. 385205

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Appendix I

Tolerance Assessment Calculations

For each of the crops listed below, the Guidance for Setting Pesticide Tolerances Based on Field 

Trial Data (SOP), along with the tolerance spreadsheet (January 2008 version), was used for 

calculating recommended tolerances.

Sugar beet, Root

The dataset used to establish a tolerance for fluazifop-P-butyl on sugar beet root consisted of field 

trial data representing seasonal application rates of 0.747-0.764 lb ai/A (two applications at a target of 

0.375 lb ai/A) with a 89- to 90-day PHI. As specified by the Guidance for Setting Pesticide 

Tolerances Based on Field Trial Data SOP, the field trial application rates and PHIs are within 25% 

of the maximum label application rate and minimum label PHI, respectively. The residue values used 

to calculate the tolerance are provided in Table I-2.

Samples from 11 of the 12 field trials were above the LOQ (LOQ = 0.01 ppm). Residues less than the 

LOQ were assigned values of 0.01 ppm. The fluazifop-P-butyl-sugar beet root dataset was entered 

into the tolerance spreadsheet. The result from the approximate Shapiro-Francia test statistic (Figure 

I-6) indicated that the assumption of log normality should be rejected. Visual inspection of the 

lognormal probability plot (Figure I-3) provided in the spreadsheet confirmed that the dataset is not 

lognormal.

Since the field trial data for fluazifop-P-butyl on sugar beet roots are not lognormal, the mean plus 3 

standard deviations should be selected as the tolerance value. Using the rounding procedure as 

outlined in the Guidance for Setting Pesticide Tolerances Based on Field Trial Data SOP, the mean 

plus 3SD rounds to the value 0.25 ppm (Figure I-4). Therefore, 0.25 ppm is the recommended 

tolerance level for fluazifop-P-butyl on sugar beet roots.
Fluazifop-P-butyl Summary of Analytical Chemistry and Residue Data DP No. 385205

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Table I-1. Residue data used to calculate tolerance for fluazifop-P-butyl on sugar beet root.

Regulator: EPA

Chemical: Fluazifop-p-butyl

Crop: Sugar beet root

PHI: 89-90 Days

App. Rate: 0.747-0.764

Submitter: Syngenta Crop Protection, Inc. 

Residues LN(Residues) Z-scores

0.06 -2.81 -0.48

0.05 -3.00 -0.88

0.09 -2.41 0.48

0.1 -2.30 0.60

0.08 -2.53 0.16

0.07 -2.66 -0.26

0.05 -3.00 -0.73

0.07 -2.66 -0.16

0.06 -2.81 -0.37

0.07 -2.66 -0.05

0.1 -2.30 0.73

0.11 -2.21 0.88

0.01 -4.61 -1.95

0.01 -4.61 -1.50

0.08 -2.53 0.26

0.08 -2.53 0.37

0.02 -3.91 -1.24

0.03 -3.51 -1.04

0.05 -3.00 -0.60

0.07 -2.66 0.05

0.11 -2.21 1.04

0.11 -2.21 1.24

0.2 -1.61 1.50

0.23 -1.47 1.95
Fluazifop-P-butyl Summary of Analytical Chemistry and Residue Data DP No. 385205

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Figure I- 3. Lognormal probability plot of fluazifop-P-butyl field trial data for sugar beet root.

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

1.0000

0.5000

0.2500

0.1250

0.0625

0.0313

0.0156

0.0078

y = 0.7436x - 2.7571

R2 = 0.8814

Concentrations

Percentiles

Lognormal Probability Plot
Fluazifop-P-butyl Summary of Analytical Chemistry and Residue Data DP No. 385205

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Figure I- 4. Tolerance spreadsheet summary of fluazifop-P-butyl field trial data for sugar beet root.

Regulator: EPA

Chemical: Fluazifop-p-butyl

Crop: Sugar beet root

PHI: 89-90 Days

App. Rate: 0.747-0.764

Submitter: Syngenta Crop Protection, Inc.

n: 24

min: 0.01

max: 0.23

median: 0.07

average: 0.08

95th Percentile 99th Percentile 99.9th Percentile

EU Method I

Normal

0.20 0.20 0.25

(0.20) (0.25) (--)

95/99 Rule 0.25 0.40 0.70

(0.40) (0.80) (--)

EU Method II

DistributionFree

0.20

Mean+3SD

0.25

UCLMedian95th

0.40

Approximate 

Shapiro-Francia 

Normality Test 

Statistic

0.8814

0.05 >= p-value > 0.01 : Reject lognormality 

assumption