Triticonazole Summary of Analytical Chemistry and Residue Data DP#s: 360624; 325956, 353372

Page 1 of 37 UNITED STA

TES ENVIRONMENTA L PROTECTION AGENCY WASHINGTON, D.C. 20460 OFFICE OF PREVENTION, PESTICIDE AND TOXIC SUBSTANCES MEMORANDUM Date : June 12, 2009 SUBJECT: Triticonazole . Application for New Seed Treatment Uses on C ereal Grains

(Except Rice) (PP#8F7420) . Summary of Analy tical Chemistry

and Residue Data . PC Code: 125620 DP Barcode s : 325956, 353372 , and 360624 Decision No.: 359614, 394309 , 399232 Registration No. : 7969 - xxx Petition No.: #8F7420 Regulatory Action: Section 3 R egistration Risk Assessment Type: NA Case No.: NA T XR No.: NA CAS No.: 131983 - 72 - 7 MRID No.: See MRID Summary Table 40 CFR: § 180. 583 Ver.Apr.08 FROM: Amelia M. Acierto, Chemist

Risk Assessment Branch 3 Health Effects Division ( 7509P) Through: Stephen Funk, Senior Science Advisor

Risk Assessment Branch III Health Effects Division (7509P) To: Shaja Joy

ner, RM #20 Fungi cide Branch Registration Division (7505P) MRID Sum ma ry Table MRID No. Study Type Com me nts 47511902 860.1340 Crops New DER; 47511902 .der.doc 45595401 860.1380 Wheat RACs and processed New DER; 45595401.der.doc 46568301 860.1380 Triazoles New DER; 46568301.der.doc 47470203 860.1500 Cereal grains New DER; 47470203 .der.doc 47511901 860.1520 Wheat, corn, rice , sorghum New DER; 47511901.der.doc 47399201 860.1850 Lettuce, Radish and Wheat New DER; 47399201.der.docTriticonazole Summary of Analytical Chemistry and Residue Data DP#s: 360624; 325956, 353372

Page 2 of 37 This document was originally prepared under contract by Dy namac Corporation ( 1901 Research Boulevard, Suite 220 ; Rockville, MD 20850). The document has been reviewed by the Health Effects Division (HED) and revised to reflect current Office of Pes ticide Programs (OPP) policies. Executive Summary Triticonazole is a systemic triazole fungicide that is currently registered for seed treatment on barley and wheat for the control of various seed - borne diseases. Triticonazole is formulated as liquid flowable formulation s . The first food/ fee d use was requested under PP#9F6051 in 2001 by Aventis Crop Science (EPA Company No. 264 ) ; the Aventis products have since been transferred to BASF (EPA Company No. 7969). BASF C ro p Protection has submitted a tolerance petition, PP#8F7420, and Section 3 request to register Triticonazole HL Fungicide (EPA Reg. No. 7969 - xxx , a 4.17 lb ai/gal liquid flowable formulation) for seed treatment use s on cereal grains (except rice) at a maximum rate of 0.05 lb ai/100 lb seed . Concurrently , BASF has proposed the es tablishment of permanent t olerances for residues of triticonazole in/on the following crop groups : Grain, cereal, group 15 ( except rice ) ................................ .............. 0.0 5 ppm Grain, cereal, forage, fodder and straw, group 16 (except rice) ..... 0. 1 0 ppm Tolerances have been established under 40 CFR § 180.583(a) for residues of the fungicide triticonazole, (1 RS

) - ( E) - 5 - [(4 - chlorophenyl)methylene] - 2,2 - dimethyl - 1 - (1 H - 1,2,4 - triazol - 1 - yl methyl)cyclopentanol , from the treatment of seed prior to planting in/on barley grain, hay

and straw, and wh eat grain, forage, hay and straw, each at 0.0 5 ppm. There are no Codex or Mexican MRL s established for residues of triticonazole . Canadian MRL s are established for triticonazole in/on barley, wheat , and oats , each at 0.01 ppm. T he nature of the residu e in plant commodities is considered adequately understood only

for the purpose of the proposed/registered seed treatment uses on cereal grain - ty pe crops. B ased on the barley and wheat metabolism studies , triticonazole is metabolized primarily via hydroxylation of the dimethylcyclopentane moiety to form a series of dihydroxy metabolites which subsequently cleave to form numerous minor polar metabolites . N o triazole metabolites [1,2,4 - triazole (T) , triazolyl alanine (TA) , or triazolyl acetic acid (TAA)] were detected in barley or wheat grain . HED has previously

determined that triticonazole is the residue of concern in barley and wheat from seed treatment uses . This determination may be extended to include seed treatment uses for all crop commodities in the cereal grains crop group. T he nature of the residue in livestock commodities is considered adequately understood only

for the purpose of the proposed/registered seed treatment uses on cereal grain - ty pe crops , based on marginally

adequate dairy

cattle and laying hen studies with phenyl - labeled triticonazole only . HED has previously

deemed that triticonazole is the residue of concern in ruminants and poultry from seed treatment uses on barley and wheat . This determination may again be extended to include seed treatment uses for all crop commodities in the cereal grains crop group.Triticonazole Summary of Analytical Chemistry and Residue Data DP#s: 360624; 325956, 353372

Page 3 of 37 The contribution of triazole derivatives [1,2,4 - triazole , triazolyl alanine, and triazolyl acetic acid ] from the use of triticonazole on barley and wheat to the aggregate expo sure for human health risk assessment has been previously considered (DP# 322215, 2/7/06, M. Doherty et al. ). An adequate LC/MS and LC/MS/MS method ( Method 148.02) is available for the enforcement of the proposed tolerances for triticonazole in cereal grain matrices . A similar method, LC /MS/MS m ethod (Method 562/0 ) , was used for data collection in the cereal grain field trial and processing studies. The method was adequate for data collection based on acceptable method verification and concurrent method recoveries. The validated LOQ was 0.01 ppm for triticonazole in/on all cereal grain crop matrices. The data requirements for testing with multiresidue method s have been fulfilled. Based on the results of the testing, the multiresidue methods are not app ropriate for determining triticonazole residues. Li vestock feeding studies, livestock tolerances, and livestock enforcement methods are not required for the purpose of this petition. Based on the recommended tolerances for triticonazole residues in lives tock feedstuffs, the maximum reasonable dietary burdens (MRDB) for livestock were calculated at 0.0 89 ppm for beef cattle, 0.3 46 ppm for dairy cattle, 0.0 3 8 ppm for poultry, and 0.0 42 ppm for swine. The results of the reviewed cow and poultry metabolism s tudies along with the low levels of residues found in the cereal grain field trials indicate that there is no reasonable expectation that quantifiable residues of triticonazole will occur in livestock commodities [40 CFR § 180.6(a)(3)]. HED will re - examine this determination if additional uses on livestock feedstuffs are proposed in the future. Adequate data are available supporting the stability of triticonazole residues during frozen storage of samples collected from the cereal grain crop field trials a nd processing studies. Adequate storage stability data are also available for the triazole - related metabolites (T, TA, and TAA) to support the storage conditions and durations of wheat, corn, sorghum, and rice grain samples from the field stu dies, and whe at flour and polished rice from the processing study . The adequacy of the additional triazole storage stability data to support the storage durations of cereal grain forages, fodders and/or straws, corn kernel plus cob with husk removed ( K+CWHR) , and sorghum stalks from the cereal grain field trial studies will be determined when the final results of an ongoing triazole storage stability study are submitted to the Agency . According to current Agency policy , storage stability

in the raw agricultural commodity (RAC) can be translated to the processed commodity . The submitted magnitude of the residue data are adequate to support the requested seed treatment uses for cereal grain crops (except rice). There are adequate data for the representative crops of th e cereal grain groups 15 and 16 to establish crop group tolerances. The number and locations of field trials were conducted according to the OPPTS 860.1500 guidelines. The seed treatment rate (0.05 lb ai/100 lbs seed) used in the field trials reflects th e proposed use of Triticonazole HL Fungicide (EPA Reg. No. 7969 - xxx) on barley , field corn and popcorn, oats, rye, wheat, and triticale. However, the rate reflects 5x and 2.5x the proposed seed treatment rate for sweet corn and sorghum, respectively .Triticonazole Summary of Analytical Chemistry and Residue Data DP#s: 360624; 325956, 353372

Page 4 of 37 Residues of triticonazole were below the L OQ of 0.01 ppm in treated wheat grain, corn grain, corn K+CWHR, and sorghum grain. Low but quantifiable residues of triticonazole were observed in rice grain. The available data support a tolerance level of 0.01 ppm for cereal grains, group 15 (except rice). The value of 0.05 ppm proposed by the petitioner is excessive, when rice is excluded. Moreover, the 0.01 ppm level harmonizes with Canada. A revised Section F must be submitted to reflect the tolerance rec ommendation of 0.01 ppm for cereal grains, group 15 (except rice). The individual tolerances established for barley grain and wheat grain at 0.05 ppm in 40 CFR §180.583(a) should be deleted when the crop group tolerance is established. Residues of triti conazole were also nonquantifiable in treated field and sweet corn forage and stover, and sorghum forage and stover. Quantifiable residues of triticonazole were observed in treated wheat forage, hay and straw, and rice straw. Appropriate tolerance level s were determined statistically

(see Appendix I) according to Guidance for Setting Pesticide Tolerances Based on Field Trial Data SOP . T he residue data for rice straw was excluded from the spreadsheet because the petitioner is not apply ing for use on rice. The tolerance spreadsheet calculated tolerances of 0.20 ppm for wheat forage, 0.25 ppm for wheat hay, and 0.20 ppm for wheat straw. HED recommends a crop group tolerance of 0.25 ppm based on the highest calculated value for the representative crop (wheat hay ). A revised Section F must be submitted to reflect the tolerance recommendation of 0.25 ppm for the forage, fodder, and straw of cereal grain s, group 16 (except rice) . The individual toleran ces established for barley

hay and straw, and wheat forage, hay and straw in 40 CFR §180.583(a) should be deleted when the crop group tolerance is established . The processing data for field corn, rice, sweet sorghum, and wheat are adequate . The results indicate that residues of triticonazole were nonquantifi able (<0.01 ppm) in the cereal grain RACs (corn, rice, wheat, and sorghum) grown from seeds treated at 250 g triticonazole/100 kg seed (5x the maximum proposed seed treatment rate). Analysis of rice processed matrices showed that residues of triticonazole may concentrate in hulls (2.8x) but not significantly in bran (1.1x); residues in polished rice were nonquantifiable. As the petitioner is not seeking to register use on rice at this time, no tolerances are required for rice processed matrices. The conf ined rotational crop study is acceptable. The application rate used in the study reflects 1.4x the equivalent per acre rate for cereal grain crops. The metabolism of triticonazole in rotated crops appears similar to those observed for primary crops, except that triazole - related metabolites were detected in the rotated crops. The data indicate that residues of triticonazole may be present at >0.01 ppm in 30 - DAT rotated lettuce (0.017 ppm), radish tops (0.049 ppm) and wheat forage (0.041 ppm), straw (0.133 ppm) and chaff (0.139 ppm); 120 - DAT rotated radish tops (0.016 ppm), and wheat forage (0.019 ppm), straw (0.150 ppm), and chaff (0.114 ppm); and 365 - DAT rotated wheat forage (0.025 ppm), straw (0.086 ppm) and chaff (0.133 ppm). Wheat hay

was not analy

ze d but forage and straw were analy zed, and residues of triticonazole were found in forage and straw. The proposed label for the 4.17 lb/gal FS specifies that “planting of any crop not listed on the label within 30 days after planting treated seed is not all owed”. The results of the submitted confined rotational crop study do not support this restriction. The data from the confined rotational crop study

indicate that triticonazole residues greater than 0.01 ppm were detected atTriticonazole Summary of Analytical Chemistry and Residue Data DP#s: 360624; 325956, 353372

Page 5 of 37 the 30 - day

PBI . To support a 30 - day plantback restriction on the label, limited field rotational crop data for leafy

vegetables, root and tuber vegetables, foliage of root and tuber vegetables , and a cereal grain are required. Until the requested data are provided, the label must be modified to specify a 120 - day

(4 - month) plantback restriction for leafy vegetables, a 365 - day

(12 - month) plantback restriction for root and tuber vegetables, and prohibit the planting of all other crops not listed on the label. Analy tical standards for triticonazole are currently available in the EPA National Pesticide Standards Repository . Regulatory Recommendations and Residue Chemistry Deficiencies HED has examined the residue chemistry database for triticonazole and conclude s that pending submission of a revised Section B (see requirements under Directions for Use) and a revised Section F (see requirements under Proposed Tolerances), there are no residue chemistry issues that would preclude granting conditional registration for the requested seed treatment uses on cereal grain crops (except rice) and the establishment of tolerances for residues of the fungicide triticonazole, (1 RS

) - ( E) - 5 - [(4 - chlorophenyl)methylene] - 2,2 - dimethyl - 1 - (1 H - 1,2,4 - triazol - 1 - yl methyl)cyclopentanol , from the treatment of seed prior to planting in/on: Grain, cereal, group 15 (except rice) .................................... ... 0 .0 1 ppm Grain, cereal, forage, fodder, and straw, group 16 (except rice) ...... 0. 25 ppm Moreover, upon establishment of the above tolerance s for grain, c ereal, group 15 (except rice) and grain, cereal, forage, fodder, and straw, group 16 (except rice), the existing tolerances listed in 40 CFR 180 (a) should be removed: barley, grain; barley, hay ; barley , straw; wheat, forage; wheat, grain; wheat, hay ; whe at, straw . A human health risk assessment is forthcoming. 860.1200 Directions for Use • The label for Triticonazole HL Fungicide must be amended to include the following rotational crop restrictions: a 120 - day plantback interval for leafy vegetable s , a 365 - day plantback interval root and tuber vegetables, and prohibit the planting of all other crops not listed on the label. 860.1550 Proposed Tolerances • A revised Section F must be submitted to reflect the tolerance recommendation of 0.01 ppm fo r cereal grains, group 15 (except rice) ; to reflect the tolerance recommendation of 0.25 ppm for grain , cereal, forage, fodder, and straw, group 16 (except rice ); and to reflect the correct commodity definition s as listed in Table 9 .Triticonazole Summary of Analytical Chemistry and Residue Data DP#s: 360624; 325956, 353372

Page 6 of 37 HED recommends conver sion of conditional registration to unconditional registration for the cereal grains (except rice) upon adequate resolution of data pertaining to storage stability and field accumulation in rotational crops. 860.1380 Storage Stability • To support the reported results for 1,2,4 - triazole and the triazole conjugates, the final report of the ongoing storage stability study with free triazole and triazole conjugates in plant commodities must be submitted. 860.1900 Field Accumulation in Rotational Crops

• Data from l imited field accumulation studies on rotational crop s are required. Background The chemical structure and n omenclature of triticonazole and triazole - related metabolites , and the physicochemical properties of the technical grade of triticonazole are , respectively, presented in Tables 1 and 2. Table 1. Triticonazole Nom enclature . Chemical structure

C H 3 C H 3 O H N N N

Cl Common name Triticonazole Company experimental name BAS 595 F (formerly RPA 4000727) IUPAC name (±)(E) - 5 - (4 - chlorobenzylidene) - 2,2 - dimethyl - 1 - (1 H - 1,2,4 - triazol - 1 - ylmethyl)cyclopentanol CAS name 5 - [(4 - chlorophenyl)methylene] - 2,2 - dimethyl - 1 - (1 H - 1,2,4 - triazol - 1 - ylmethyl)cyclopentanol CAS registry number 131983 - 72 - 7 End - use product (EP) Triticonazole HL (4.17 lb ai/gal fl owable liquid; EPA Reg. No. 7969 - xxx) Chemical structure of T metabolite N H N N 1,2,4 - Triazole Chemical structure of TA metabolite N N N O H N H 2 O Triazole alanine or triazolylalanineTriticonazole Summary of Analytical Chemistry and Residue Data DP#s: 360624; 325956, 353372

Page 7 of 37 Table 1. Triticonazole Nom enclature . Chemical structure of TAA metabolite N N N O H O Triazole acetic acid or triazolylacetic acid Ta ble 2. Physicochemical Properties of Chemical : Triticonazole . Parameter Value Reference Melting point/range 140 oC; PAI displays two crystalline forms melting at 137 and 141 oC BASF document number 2002/1016091 1 pH Not available Density 1.21 g/mL (P AI) BASF document number 2002/1016091 1 Water solubility 8.4 mg/L at 20 oC Solvent solubility (at 20 oC) Hexane 0.12 g/L Methanol 18.2 g/L Acetone 74.5 g/L Toluene 12.6 g/L Dichloromethane 191 g/L Ethyl acetate 48.6 g/L n - Octanol 6.2 g/L Vapor pres sure <0.1 x 10 - 5 PA at 50 oC Dissociation constant, pKa Does not dissociate Octanol/water partition coefficient, Log(KOW) Log P = 3.29 at 20 oC UV/visible absorption spectrum Not available 1 As referenced in MRID 47470203. 860.1200 Directions for Use A summary

of the proposed use directions is presented in Table 3. Information pertaining to the proposed use pattern was obtained from a 2008 specimen label submitted for Triticonazole HL Fungicide Seed Treatment (4.17 lb/gal FS). The EP is proposed for the control of various seed borne diseases in cereal crops except rice. Table 3 shows that Triticonazole HL Fungicide Seed Treatment is proposed for seed treatment on cereal grains (except rice) at a maximum rate of 0.05 lb ai/100 lb seed. The end - use product Charter® Fungicide Treatment (EPA Reg. No. 7969 - 386; accepted 6/27/2007) is currently registered on barley

and wheat for preplant seed treatment at a maximum rate of 0.005 lb ai/100 lb seed. Table 3. S ummary of Proposed Seed Treatm ent Use of Triticonazole . Application Ty pe Formulation [EPA Reg. No.] Seed Treatment

Applic ation Rate (lb ai/100 lb seed) Maximum Seeding Rate 1 (lb seed planted/A) Maximum Equivalent

Field Applic ation Rate 2 (lb ai/A) Barley Seed Treatment 4.17 lb/gal FS

[79 69 - xxx] 0.005 - 0.050 96 0.048

Field Corn and Popcorn (includes seed production)Triticonazole Summary of Analytical Chemistry and Residue Data DP#s: 360624; 325956, 353372

Page 8 of 37 Table 3. S ummary of Proposed Seed Treatm ent Use of Triticonazole . Application Ty pe Formulation [EPA Reg. No.] Seed Treatment

Applic ation Rate (lb ai/100 lb seed) Maximum Seeding Rate 1 (lb seed planted/A) Maximum Equivalent

Field Applic ation Rate 2 (lb ai/A) Seed Treatment 4.17 lb/gal FS

[7969 - xxx] 0.005 - 0.050 1 5 0.008 Sweet Corn Seed Treatment 4.17 lb/gal FS

[7969 - xxx] 0.010 15 0.002 Oats Seed Treatment 4.17 lb/gal FS

[7969 - xxx] 0.005 - 0.050 128 0.064 Rye Seed Treatment 4.17 lb/gal FS

[7969 - xxx] 0.005 - 0.050 112 0.056 Sorghum Seed Treatment 4.17 lb/gal FS

[7969 - xxx] 0.010 - 0.020 10 0.002 Wheat and Triticale Seed Treatment 4.17 lb/gal FS

[7969 - xxx] 0.005 - 0.050 150 0.075 G eneral Use Directions and Limitations : T o be applied as a water - based mixture using standard or mist - type seed treatment application equipment . A colorant must be added to identify the treated seed. The proposed label does not include water amounts need ed to provide the mixture or slurry rate for optimum coverage, but recommends consulting a seed - treatment specialist. The product may be tank- mixed with other water - based seed treatments. U se of treated seed for food, feed, or oil processing is prohibite d . P lanting of any crop not listed on the label within 30 days after planting treated seed is not allowed . 1 From Science Advisory Council for Exposure, Standard Operating Procedure, SOP #15, 3/2/04 . 2 Calculated by the study reviewer using the maximu m seed treatment rate and maximum seeding rate. Conclusions . The submitted label for Triticonazole HL Fungicide Seed Treatment is adequate to allow evaluation of the residue data relative to the proposed use . However, the proposed 30 - day plantback inter

val for all crop s not listed on the label is not acceptable . The submitted confined rotational crop study, which was conducted at 1.4x the proposed maximum equivalent field application rate for cereal grains, indicates that residues of triticonazole may b e present at >0.01 ppm in 30 - DAT rotated lettuce, radish tops and wheat forage, straw and chaff; 120 - DAT rotated radish tops, and wheat forage, straw, and chaff; and 365 - DAT rotated wheat forage, straw and chaff . The label for Triticonazole HL Fungicide must be amended to include the following rotational crop restrictions: a 120 - day plantback interval for leafy vegetables, a 365 - day

plantback interval for root and tuber vegetables, and prohibit the planting of all other crops not listed on the label. Data from l imited field accumulation studies on rotational crops are required . 860.1300 Nature of the Residue - Plants Residue Chemistry Memo DP# 262566, 6/6/2001, N. Dodd (PP#9F6051)Triticonazole Summary of Analytical Chemistry and Residue Data DP#s: 360624; 325956, 353372

Page 9 of 37 F ield and greenhouse studies were previously submi tted investigating the metabolism of [triazole 14 C] - and [phenyl 14 C] - triticonazole in spring and winter wheat and barley . Inthe initial greenhouse study

and two field studies (wheat and barley seeds treated with [triazole 14 C]tri ticonazole), the total radioactive residues ( TRRs ) were determined, but samples were either not extracted or the characterization of extracted 14 C - residues was very limited. The most complete analyses were conducted in two field studies: (i) with [triazo le 14 C]triticonazole at 187 g ai/100 kg seed (3 . 7x the maximum proposed seed treatment use of 50 g ai/100 kg seed) in wheat and 299 g ai/100 kg seed (6x) in barley ; and (ii) with [phenyl 14 C]triticonazole at 155 g ai/100 kg seed (3 . 1x) in wheat and 242 g ai/100 kg seed (4 . 8x) in barley . In these studies, the 14 C - residues in RAC samples were identified as parent, one of the dihydroxy metabolites (RPA 404766, RPA 404886, RPA 406341, RPA 406780), the Z isomer of parent (RPA 406203), or characterized as minor unknowns (each <10% TRR) that were generally polar in nature. However, extraction of various samples in these studies was incomplete as residual solids accounted for >10% of the TRR and >0.05 ppm. As determined in the [triazole 14 C] - triticonazole metabol ism study , no triazole, triazolylalanine, or triazolyl acetic acid were detected in wheat and barley grain. These are metabolites of some triazole fungicides, for which free triazole may be of toxicological concern. The petitioner has been advised that i n future plant metabolism studies , which may be conducted to reflect future application methods (i.e., foliar or soil application), the petitioner should also look for triazole py ruvate. T he metabolism of triticonazole in wheat and barley was considered ad equately understood for the purposes of the use of triticonazole as a seed treatment on cereal grains . Based on the available wheat and barley metabolism data, triticonazole is metabolized in wheat and barley primarily via hydroxylation of the dimethylcyc lopentane moiety to form a series of dihydroxy metabolites. The residues which were identified were parent, RPA 404766, RPA 404886, RPA 406341, RPA 406780, and the Z isomer of the parent (RPA 406203). Subsequent cleavage of the dihydroxy

metabolites resu lts in the formation of numerous minor (<10% TRR) metabolites that are generally

more polar in nature. HED’s Metabolism Assessment Review Committee determined on 5/1/01 that triticonazole per se is the residue of concern in wheat and barley for seed treatment uses. The available metabolism studies supporting seed treatment uses on barley and wheat may

be extended to include seed treatment uses on all crop commodities in the cereal grains crop group. 860.1300 Nature of the Residue - Livestock Residue Chemistry Memo DP# 262566, 6/6/2001, N. Dodd (PP#9F6051) D airy cow and hen studies were previously submitted. One ruminant metabolism study was conducted on dairy

cows using [U - phenyl 14 C ] - triticonazole at dosing levels of 1 ppm ( 3.1 x the MRB D for dairy

cattle ) and 10 ppm ( 3 1x) for seven consecutive days. Detectable radioactive residues were found in liver, high - dose kidney , and high - dose milk. Residues identified by HPL C in the liver were parent, RPA 404886, RPA 406341, RPA 406780, RPA 404766, and /or RPA 406972 (each <0.001 ppm in low dose) . Residues identified by HPL C in the high - dose kidney were parent, RPA 404886, RPA 406341, RPA 404766, and RPA 406972. The identity of RPA 406780 in high - dose liver was confirmed by MS . RPA 406780 was identified as the major residue in high - dose liver. The identity of RPA 404886 in high - dose kidney was confirmed byTriticonazole Summary of Analytical Chemistry and Residue Data DP#s: 360624; 325956, 353372

Page 10 of 37 TLC. Residues in milk, muscle, and fat were not identified since radioactive residue s were nondetectable (<0.001 ppm in milk and <0.004 ppm in muscle and fat) at the 1 ppm dosing level, and ≤ 0.001 ppm in milk and nondetectable (<0.004 ppm) in muscle and fat at the 10 ppm dosing level. A poultry metabolism study

was conducted on laying hens using [U - phenyl 14 C] - triticonazole at dosing levels of ~1 ppm ( 125x the MRBD for poultry ) and ~10 ppm ( 1 2 5 0x) for 14 consecutive days. Detectable radioactive residues were found in whole eggs, liver, high - do s e muscle, high dose skin with fat, and high - dose peritoneal fat. Residues identified by HPL C in high - dose eggs were parent, RPA 404886, RPA 404766, RPA 406780, RPA 406972, and RPA 406 341 . Re sidues identified by

HPL C in high - dose liver were parent, RPA 404886, and RPA 406972. Residues identified in peritoneal fat by TL C subsequent to HPL C were parent, RPA 406341, and RPA 404886. Residues in poultry muscle were not identified because of low radioactiv ity . T he metabolism of triticonazole in ruminants and poultry is considered adequately understood for the purposes of uses of triticonazole as a seed treatment on cereal grains. The HED Metabolism Asses sment Review Committee determined on 5/1/01 that triticonazole is the residue of concern in livestock for seed treatment uses on barley and wheat . The available metabolism studies supporting seed treatment uses on barley and wheat may

be extended to inclu de seed treatment uses on all crop commodities in the cereal grains crop group. For future uses other than seed treatment uses, ruminant and poultry metabolism studies with the 14 C label in the triazole ring will be needed in addition to new phenyl - labeled ruminant and poultry metabolism studies required because of multiple deficiencies regarding the submitted phenyl - labeled studies. 860.1340 Residue Analytical Methods Enforcement method Residue Chemistry Memo DP# 262566, 6/6/2 001, N. Dodd (PP#9F6051) Inconjunction with a previous triticonazole petition (PP#9F6051) for seed treatment use s on barley and wheat, HED has determined that the LC /MS and L C/MS/MS methods (Aventis Method MS 148.02) are suitable fo r enforcing tolerances for residues of triticonazole and two of its dihydroxy

metabolites RPA 404886 and RPA 406341 . The method measures each analy te individually

in/on wheat and barley

RACs and processed commodities. Using this method, residues are extracted with water:acetone. No hydrolysis step is included to release conjugate residues. The reported LOQ for the LC/MS/MS method was 0.002 ppm for all three analy tes in forage, straw and grain. A successful independent laboratory validation has been c on ducted for Aventis Method MS 148.02 on wheat forage. HED concludes that Aventis Method MS 148.02 would also be adequate for the enforcement of recommended tolerances addressed in this document. For future uses other than seed treatment, additional data regarding the analyt ical method must be addressed (see DP# 262566 , 6/6/2001, N. Dodd).Triticonazole Summary of Analytical Chemistry and Residue Data DP#s: 360624; 325956, 353372

Page 11 of 37 Data - Collection Method DER Reference: 47511902.der.doc Samples of RAC s (wheat forage, hay, straw and grain; field corn, forage, grain and stover; sweet corn forage, K+CWHR, and stover; sorghum forage, grain, and stover; and rice grain and straw) and processed (wheat bran and flour; corn oil and starch; and rice hulls, bran and polished rice) commodities were analy

zed for residues of triticonazole using LC/MS/MS Metho d 562/0 . The data - collection method is similar to the enforcement method discussed above . Method 562/0 method was modified for analysis of cereal grain matrices to eliminate the clean - up step which was not needed because no matrix interference occurred. BASF has submitted descriptions and validation data (MRID 47511902) for Method 562/0. Using this m ethod, residues in crop samples are extracted with a mixture of methanol and water, centrifuged, and then partitioned with dichloromethane. Triticonazole residues are quantitated by LC /MS/MS. Acceptable method validation recoveries were obtained for triticonazole from bean, corn grain, straw and forage, lemon, lettuce, and rapeseed fortified with triticonazole at 0.01 and 0.10 ppm. Residues of triticonaz ole were quantitated using both mass ion transitions (318.0 →70.0 and 318.0→125.0). Average recoveries were within the acceptable range of 70 - 120% and RSDs were <20% for triticonazole in all tested matrices. The fortification levels used in method validation are adequate to bracket expected residue levels in cereal grain matrices from the associated field trials. Confirmatory analysis may

be performed using the second daughter ion transition. Cereal grain RAC s and processed samples were also analy zed for the triazole - related metabolites, triazole (T), triazolylacetic acid (TAA) and triazolylalanine (TA) using LC/MS/MS Methods D0508 and D0604 (grain). Briefly, residues in samples were extracted with acetonitrile (ACN):water (70:30, v:v). The extract was evaporated to dry ness (or near dry

ne ss for grain and K+CWHR), redissolved in 0.1% formic acid in water and filtered through a sy ringe filter for LC /MS/MS analysis. Corn oil samples were extracted with ACN/0.1% formic acid in water and hexane using liquid - liquid partitioning. The hexane pha se was discarded , and the remainder evaporated to dry

ness and redissolved in 0.1% formic acid in water for analysis. MS/MS detection in the positive ionization mode was used to monitor ion transitions o f m/z 70.1 → 43.2 for T, m/z 128.1 → 70.2 for TAA, and m/z 157.1 → 88.1 for TA. Inthe field trials, the validated LOQ was 0.05 ppm each for T, TA, and TAA in all cereal grain matrices, except for T and TAA in grain and K+CWHR, which had L OQs of 0.01 ppm each. Inthe processing studies, the validated L OQ was 0.01 ppm each for T and TAA, and 0.05 ppm for TA in cereal grain matrices . The above LC/MS/MS methods ( 562/0 for triticonazole; D0508 and D0604 for triazoles) were adequately

validated in conjunction with the analysis of field trial and processing samples using untreated samples of each commodity fortified with the appropriate analy tes at levels bracketing the residues found in the treated samples. The petitioner reported that because triazole - related compounds are commonly found in plants in nature, two untreated controls were used to establish the background apparent residues in controls for each analy tical set.Triticonazole Summary of Analytical Chemistry and Residue Data DP#s: 360624; 325956, 353372

Page 12 of 37 Samples from a wheat storag e stability study were analy

zed for residues of triticonazole and its metabolites RPA 406341 and RPA 404886 using the enforcement method L C/MS Method 148.02 (revision 2) entitled “Method of Analysis for the Determination of RPA 400727 (Triticonazole) and its Metabolites RPA 404886 and RPA 406341 in Wheat and Barley Matrices by L C/MS.” The validated L OQ based on method verification data was 0.05 ppm for each analy te in all wheat matrices. Briefly, forage , hay , straw, germ, and bran samples were soaked overnight in acetone, and extracted twice again with water:acetone (1 :9, v:v). The concentrated extract was mixed with ACN and diluted with water for clean - up through a C18 solid phase extraction (SPE) cartridge; residues were eluted with 5% methanol in ACN. The eluate was evaporated to just dry

ness and reconstituted in A CN:water (1:1, v:v) for L C/MS analysis. Grain and flour samples were soaked overnight in water:acetone (9:1, v:v) and extracted twice again with acetone. The concentrated extract was mixed with a small amount of acetone, and water with sodium chloride fo r partitioning with DCM . Partitioning with DCM was repeated twice. The DCM phases were combined, evaporated to just dry ness and reconstituted in ACN:water (1:1, v:v) for L C/MS analysis. The method was adequately validated prior to and in conjunction with the analysis of the stored samples. Concurrent recoveries were generally within the acceptable range of 70 - 120% for triticonazole and the two metabolites in all wheat commodities fortified with each analy te at 0.50 ppm. Acceptable method verification recoveries were also obtained for triticonazole residues in wheat matrices fortified at 0.05 and 0.50 ppm. Conclusions . The LC /MS/MS m ethod , 562/0 , is adequate for collecting data on residues of triticonazole in/on cereal grain RAC s (wheat forage, hay , straw and grain; field corn, forage, grain and stover; sweet corn forage, K+CWHR, and stover; sorghum forage, grain, and stover; and rice grain and straw) and processed (wheat bran and flour; corn oil and starch; and rice hulls, bran and polished rice) commo dities . The LC /MS/MS m ethod s , Methods D0508 and D0604 , are adequate for collecting data on residues of 1,2,4 - triazole, TA and TAA in/on cereal grain matrices. The previously submitted LC /MS and L C/MS/MS methods (Aventis Method MS 148.02 ) would also be su itable for enforc ing the recommended tolerances. As noted under PP#9F6051, for future uses other than seed treatment, additional data regarding the analy tical method must be addressed. No methods have been submitted or are required for analysis of trit iconazole residues in livestock commodities. The proposed seed treatment use on cereal grain crop s falls under 40 CFR § 180.6(a)(3). 860.1360 Multiresidue Methods Residue Chemistry Memo DP# 262566, 6/6/2001, N. Dodd (PP#9F6051) Multiresidue method testi ng data were previously submitted for triticonazole, RPA 406341, and RPA 404886. The multiresidue methods are not adequate for enforcement since recoveries were obtained only

with Protocol D , and the recoveries were not adequate. These data were forwarde d to FDA.Triticonazole Summary of Analytical Chemistry and Residue Data DP#s: 360624; 325956, 353372

Page 13 of 37 860.1380 Storage Stability Storage Stability

Study with Triticonazole on Wheat DER Refere nce: 45595401.der.doc Residue Chemistry Memo DP# 262566, 6/6/2001, N. Dodd (PP#9F6051) BASF has submitted the final report of a storage stability study w ith triticonazole on wheat. Interim data up to 12 months were previously reviewed in connection with a tolerance petition for wheat and barley

(PP#9F6051; DP# 262566, 6/6/2001, N. Dodd). The final study report reflects a maximum storage interval of 18 mo nths and was required as a condition of registration under PP#9F6051. Samples of untreated wheat grain, forage, straw, hay and processed bran, flour and germ were fortified with triticonazole or its metabolites RPA 406341 and RPA 404886 at 0.5 ppm each an aly

te, except for months 1 through 18 where RPA 404886 was fortified at 0.28 ppm in all matrices. Samples were stored frozen ( - 20 oC) for up to 18 months . Actual storage intervals tested were 0, 1, 3, 6, 9, 12, 15, and 18 months. Wheat samples were analy zed for residues of triticonazole and its metabolites RPA 406341 and RPA 404886 using L C/MS Method 148.02 (revision 2), entitled “Method of Analysis for the Determination of RPA 400727 (Triticonazole) and its Metabolites RPA 404886 and RPA 406341 in Wheat and Barley

Matrices by

L C/MS.” Samples were analy zed by Enviro - Test L aboratories (Edmonton, Alberta, Canada). The method was adequate for data collection based on acceptable concurrent method recoveries; the validated LOQ based on method verification data was 0.05 ppm for each analy

te in all wheat matrices. The final study

results i ndicate that residues of triticonazole and its metabolites RPA 406341 and RPA 404886 were relatively stable in/on the raw agricultural commodities of wheat (forage, hay, grain, and straw) as well as in its processed commodities (germ, flour, and bran) when stored frozen ( - 20 oC) for up to 18 months. Interim Results of a Storage Stability Data Study

with 1,2,4 - Triazole (T), Triazolyl alanine (TA), and Triazolyl a cetic Acid (TAA ) In Apples, Wheat Flour, Peanut Butter, Milk, and Eggs DER Reference: 46568301.der.doc The U.S. Triazole Task Force has submitted the interim results of an ongoing storage stability study with 1,2,4 - triazole (T), triazolyl alanine (TA) and triazolyl a cet ic acid (TAA) in selected crop and animal matrices ( apples, wheat flour, peanut butter, milk, and eggs ) . The study submission reported that when completed, the final study report will include analysis of additional samples for up to a two - ye ar time point. Homogenized samples of apples, eggs, and milk were spiked with T at 0.20 ppm, or a mixture of TA and TAA at 0.20 ppm for each analy te. Samples of homogenized wheat flour and peanut butter were spiked with T at 0.20 ppm, or TA and TAA at 1.0 ppm for each analy te. The fortification level used for peanut butter cannot be confirmed; therefore, raw data are required in the final study report to confirm the actual fortification levels. Fortified and unfortified samples were stored frozen (≤ - 20 oC) and analy z ed following 0, 1, 3, 6, and 12 months of storage.Triticonazole Summary of Analytical Chemistry and Residue Data DP#s: 360624; 325956, 353372

Page 14 of 37 Samples were analy

zed for residues of T, TA, and TAA using L C/MS/MS Method Meth - 160 (Py xant L abs Inc. Method Addendum Revision #2). Adequate concurrent method recovery data were provided to confirm that LC /MS/MS Method Meth - 160 is adequate for data collection. The validated L OQs were 0.010 ppm for each analy te in apples; 0.010 ppm each for TA and TAA, 0.005 ppm for T in milk; and 0.010 ppm for T and 0.030 ppm each for TA and TAA in wheat flour. The interim data suggest that residues of T, TA and TAA are reasonably stable when stored frozen for up to one year in/on apples, wheat flour, peanut butter, milk, and eggs. The Task Force noted that the protocol specified that peanut butter be stored refrigera ted (<10 oC) for the storage stability

study to support the USTTF and USDA PDP (Pesticide Data Program) monitoring studies. In a deviation from the protocol, peanut butter samples were instead stored frozen (< - 20 oC). The peanut butter storage stability testing is planned to be repeated with samples stored refrigerated. Other Storage Stability

Data Interim storage stability

data for T, TA, and TAA in canola seed, turnip roots, mustard greens, and wheat straw, grain, and forage were previously referenced in association with a prothioconazole petition ( PP#4F6830; DP#s 303508 & 314517, S. Funk, 8/21/2006). The final report on the storage stability study with the triazoles which are required as confirmatory data; that may support the storage conditions and durations of wheat, corn, sorghum, and rice foliage matrices and corn K+CWHR have been received and is being reviewed separately . Sample storage conditions and intervals Table 4 lists the information pertaining to the storage conditions and intervals of samples incurred in the current field trial and processing studies.Triticonazole Summary of Analytical Chemistry and Residue Data DP#s: 360624; 325956, 353372

Page 15 of 37 Table 4 . Summary of Storage Conditions and Duration s of Samples fromCrop Field Trial and

Processing Studies. Matrix Storage

Tem p . (°C) Actual Storage

Duration Interval of Demonstrat ed Storage Stability Triticonazole Wheat forage < - 5 224 - 323 days (7.4 - 10.6 months) Residues of triticonazole are relatively stable in/on wheat forage, hay, straw and grain stored frozen for

up to 18 months. Wheat hay 200 - 295 days (6.6 - 9.7 months) Wh eat grain 175 - 261 days (5.8 - 8.6 months) Wheat straw 173 - 265 days (5.7 - 8.7 months) Corn forage 124 - 256 days (4.1 - 8.4 months) Corn grain 106 - 184 days (3.5 - 6.1 months) Corn stover 109 - 342 days (3.6 - 11.3 months) Corn K+CWHR 105 - 258 days (3.5 - 8. 5 months) Sorghum forage 142 - 247 days (4.7 - 8.1 months) Sorghum grain 109 - 158 days (3.6 - 5.2 months) Sorghum stover 112 - 161 days (3.7 - 5.3 months) Rice grain 97 - 226 days (3.2 - 7.4 months) Rice straw 106 - 182 days (3.5 - 6.0 months) Corn, grain (f or processing) < - 5 120 days (3.9 months) 18 months in wheat grain Rice, grain (for processing) 131 - 203 days (4.3 - 6.7 months) 18 months in wheat grain Rice, polished 131 - 203 days (4.3 - 6.7 months) 18 months in wheat grain Rice, hulls 30 days (1.0 month ) None required Rice, bran 30 - 47 days (1.0 - 1.5 months) 18 months in wheat bran Sorghum, stalk (for processing) 154 days (5.1 months) 18 months in wheat grain and forage Wheat, grain (for processing) 173 days (5.7 months) 18 months in wheat grain Tri azoles Wheat grain < - 5 185 - 309 days (6.1 - 10.2 months) Residues of T, TA, and TAA are relatively stable in wheat flour (and apple, peanut butter, milk and eggs) stored frozen for up to 12 months). Corn grain 114 - 192 days (3.8 - 6.3 months) Sorghum grain 107 - 155 days (3.5 - 5.1 months) Rice grain 102 - 177 days (3.4 - 5.8 months) Corn K+CWHR 96 - 249 days (3.2 - 8.2 months) Awaiting final report Wheat forage 229 - 323 days (7.5 - 10.6 months) Wheat hay 217 - 310 days (7.1 - 10.2 months) Wheat straw 182 - 267 days (6.0 - 8.8 months) Corn forage 119 - 250 days (3.9 - 8.2 months) Corn stover 99 - 332 days (3.3 - 10.9 months) Sorghum forage 145 - 250 days (4.8 - 8.2 months) Sorghum stover 119 - 167 days (3.9 - 5.5 months) Rice straw 107 - 183 days (3.5 - 6.0 months)Triticonazole Summary of Analytical Chemistry and Residue Data DP#s: 360624; 325956, 353372

Page 16 of 37 Table 4 . Summary of Storage Conditions and Duration s of Samples fromCrop Field Trial and

Processing Studies. Matrix Storage

Tem p . (°C) Actual Storage

Duration Interval of Demonstrat ed Storage Stability Corn , grain (for processing) < - 5 142 - 206 days (4.7 - 6.8 months) 12 months in wheat flour Corn, grits 70 - 71 days (2.3 months) None available * Corn, flour 70 - 71 days (2.3 months) 12 months in wheat flour Corn, oil 11 - 12 days (0.4 months) None required Corn, meal 70 - 71 days (2.3 months) None available * Corn, starch 8 - 9 days (0.3 months) None required Rice, grain (for processing) < - 5 154 - 210 days (5.1 - 6.9 months) 12 months in wheat flour Rice, polished 28 - 37 days (0.9 - 1.2 months) 12 months in wheat flo ur Rice, hulls 28 - 40 days (0.9 - 1.3 months) None available * Rice, bran 28 - 31 days (0.9 - 1.0 months) None required Sorghum, stalk (for processing) 177 - 178 days (5.8 - 5.9 months) Awaiting final report Sorghum, syrup 21 days (0.7 months) None required Wheat, grain 292 - 315 days (9.6 - 10.4 months) 12 months in wheat flour Wheat, bran 54 - 62 days (1.8 - 2.0 months) None available * Wheat, flour 53 - 57 days (1.7 - 1.9 months) 12 months in wheat flour Wheat, middlings 55 - 56 days (1.8 months) None available * Wheat, shorts 55 - 56 days (1.8 months) None available * Wheat, germ 55 - 68 days (1.8 - 2.2 months) None available * *According to current HED policy, storage stability in the raw agricultural commodity can be translated to the processed commodity. Conclusio ns . The available storage stability data for triticonazole residues in wheat matrices are adequate and may

be translated to the other cereal grains (corn, sorghum, and rice) to support the storage durations and conditions of samples from the submitted fie ld and processing studies. The interim storage stability data submitted by

the U.S. Triazole Task Force for the triazole related metabolites suggest that residues of T, TA and TAA are reasonably stable when stored frozen for up to one year in/on apples, wheat flour, peanut butter, milk, and eggs. The data for wheat flour may

be translated to wheat, corn, sorghum, and rice grain samples from the field and processing studies , and to corn and wheat flour and polished rice from the processing study . The a dequacy

of the additional triazole storage stability data to support the storage durations of cereal grain forages, fodder s and/or straw s , corn K+CWHR, and sorghum stalks from the cereal grain field trial will be determined when the final results of the ongoing triazole storage stability study are submitted to the Agency . Supporting storage stability data for triazole residues are not required for corn oil and starch; rice bran; and sorghum sy rup as these matrices were analy zed within 30 days of processing . However, n o a dditional supporting freezer storage stability data are required for T, TA, and TAA in rice hulls, corn grits and meal, and wheat bran, middlings, shorts, and germ since , a ccording to current Agency policy , storage stability

in the raw agri cultural commodity

(RAC) can be translated to the processed commodity .Triticonazole Summary of Analytical Chemistry and Residue Data DP#s: 360624; 325956, 353372

Page 17 of 37 860.1400 Water, Fish, and Irrigated Crops There are no proposed uses relevant to this guideline topic . The petitioner noted that they are not seeking to register use on rice , a crop which may be irrigated, at this time. 860.1460 Food Handling There are no proposed uses that are relevant to this guideline topic. 860.1480 Meat, Milk, Poultry, and Eggs Residue Chemistry Memo DP# 262566, 6/6/2001, N. Dodd (PP#9F6051) The maximum theoretical dietary burden s (MTDB) for livestock were previously calculated as 0.09 ppm for beef cattle, 0.14 ppm for dairy cattle, and 0.05 ppm for poultry and swine, based on barley and wheat seed treatment uses (PP#9F6051). No tole rances were established for residues of triticonazole in livestock commodities. Based upon the proposed seed treatment uses on additional cereal grain crops and the recommended tolerances for triticonazole residues in/on livestock feedstuffs, the maximum reasonable dietary

burdens (MRDB) for livestock are 0. 089 ppm for beef cattle, 0. 3 46 ppm for dairy cattle, 0.0 3 8 ppm for poultry, and 0.0 42 ppm for swine ( see Table 5 below). Table 5 . Calculation of Dietary Burdens of Triticonazole Residues to Livestock. Feedstuff Ty pe 1 % Dry Matter2 % Diet2 Recommended Tolerance (ppm) Dietary Contribution (ppm) 3 Beef Cattle Wheat, hay R 88 15 0.25 0.043 Sorghum, grain CC 86 40 0.05 0.023 Wheat milled bypdts CC 88 40 0.05 0.023 Untreated PC PC -- 5 -- 0 TOTAL BURDEN -- -- 100 -- 0.089 Dairy Cattle Oat, forage R 30 30 0.20 0.200 Wheat, forage R 25 15 0.20 0.120 Sorghum, grain CC 86 45 0.05 0.026 Untreated PC PC -- 10 -- 0 TOTAL BURDEN -- -- 100 -- 0.346 Poultry Wheat, grain CC 89 75 0.05 0.038 Untreated PC PC -- 25 -- 0 TOTAL BURDEN -- -- 100 -- 0.038 Swine Corn, field, grain CC 88 85 0.05 0.042 Untreated PC PC -- 15 -- 0 TOTAL BURDEN -- -- 100 -- 0.042 1 R: Roughage; CC: Carbohydrate concentrate; PC: Protein concentrate.Triticonazole Summary of Analytical Chemistry and Residue Data DP#s: 360624; 325956, 353372

Page 18 of 37 2 OPPTS 860.1000 Table 1 Fe edstuffs ( June 2008 ). 3 Contribution = ([tolerance /% DM] X % diet) for beef and dairy cattle; contribution = ([tolerance] X % diet) for poultry and swine. Ruminant and poultry

feeding studies have not been submitted, and none are required at this tim e. Based on the available cow and poultry metabolism studies, and low levels of residues found in the cereal grain (corn, rice, sorghum and wheat) field trials, there is no reasonable expectation that quantifiable residues of triticonazole will occur in l ivestock commodities [40 CFR § 1 80. 6(a)(3)] . Therefore, livestock feeding studies and tolerances are not required at this time. I f the use of triticonazole is expanded to include uses other than seed treatments or additional livestock feed items, the need for feeding studies will be re - evaluated. 860.1500 Crop Field Trials DER Reference : 47470203.der.doc HED had previously

reviewed magnitude of the residue data (PP# 9F6051 ; DP# 262566, 6/6/2001, N. Dodd) for triticonazole and its metabolites RPA 40634 1 and RPA 404886 in/on barley and wheat following preplant seed treatment. BASF Cro p Protection is now seeking the registration of Triticonazole HL Fungicide (EPA Reg. No. 7969 - xxx ) for preplant seed treatment use s on cereal grain crops (except rice). Th e supporting magnitude of the residue study (MRID 47470203) has been reviewed, and the Executive Summary of the Data Evaluation Record is reproduced below. BASF has submitted field trial data for triticonazole on corn (field and sweet), rice, sorghum, and wheat, the representative crops of the cereal grain crop groups 15 and 16 . A total of 58 field trials w as conducted in the United States and Canada during the 2006 - 2007 growing season. Fifteen wheat trials were conducted in Zones 2 (GA; 1 trial), 4 (AR; 1 trial), 5 (KS, ND, MN; 3 trials), 6 (TX; 1 trial), 7 (ND, NE, SD; 4 trials), 8 (OK, TX; 4 trials), and 11 (WA; 1 trial). Fifteen field corn trials were conducted in Zones 1 (PA; 1 trial), 2 (GA; 1 trial), 5 (IA, IL, I N, KS, MB, MN, ND, SD, WI ; 12 trial s), and 6 (TX; 1 trial). Four sweet corn trials were conducted in Zones 3 (FL; 1 trial), 10 (CA; 1 trial), 11 (ID, 1 trial), and 12 (BC; 1 trial). Twelve grain sorghum trials were conducted in Zones 2 (GA; 1 trial), 4 (AR; 1 trial), 5 (IA, IL, KS and MN; 4 trials), 6 (OK, TX; 2 trials), 7 (NE; 1 trial), and 8 (TX; 3 trials). Finally, twelve rice trials were conducted in Zones 4 (AR, MS, LA; 7 trials), 5 (MO; 1 trial), 6 (TX; 2 trials), and 10 (CA; 2 trials). At each test location, the crops were grown from seeds treated with a 4.2 lb/gal flowable liquid formulation of triticonazole, prior to planting, at 50 g ai/100 kg seed (0.05 lb ai/100 lb seed; 1x the maximum proposed seed treatment use on cereal grain crops). The triticonazole formulation was mixe d with Apron XL(mefenoxam; a seed fungicide) and colorant. A separate plot (untreated) was planted with seed treated with Apron XL and colorant only . The applications made to sorghum seed also included py raclostrobin, and sorghum plants were also foliarly treated with py raclostrobin; these py

raclostrobin data are not reviewed herein. The cereal RAC samples were collected at normal harvest. Wheat forage was collected at the 6 - 8 inch stage to stem elongation (jointing) stage. Wheat hay was harvested at the early flower (boot) to soft dough stage and allowed to field dry for 1 - 8 days prior to collection. Wheat grainTriticonazole Summary of Analytical Chemistry and Residue Data DP#s: 360624; 325956, 353372

Page 19 of 37 and straw were harvested at maturity . Sorghum forage was harvested at the soft dough to hard dough stage, and grain and stover were harve sted at maturity . Rice grain (kernel plus hull) and straw were also harvested at maturity . At the field trials planted with sweet corn varieties, corn kernel and cobs with husks removed (K+CWHR) were collected at commercial maturity . Forage was collecte d prior to the harvest of K+CWHR, and stover was collected at maturity following collection of K+CWHR. A dditional fresh corn samples were harvested at the milk stage from 5 of the field corn sites to represent K+CWHR samples. Corn forage was harvested at the late dough/early dent stage from the field corn trials. Corn grain and stover from the field corn trials were harvested at maturity . All samples were analy

zed for triticonazole using L C/MS/MS Method 562/0. The method is adequate for data collection and was validated using wheat forage, hay, grain and straw; corn forage, K+CWHR, grain and stover; sorghum forage, grain, and stover; and rice grain and straw. The validated method L OQ was 0.01 ppm in/on all tested cereal grain RACs. Samples were also analy

zed for the triazole - related metabolites, triazole (T), triazoly lacetic acid (TAA), and triazolylalanine (TA) using LC/MS/MS Methods D0508 and D0604 (grain). The validated method L OQ was 0.05 ppm for each analy te in all cereal RACs, except for T and TAA in grain and K+CWHR, which had L OQs of 0.01 ppm each. Prior to the analysis for triticonazole residues, samples were stored frozen for maximum durations of 10.6 months for wheat forage, hay, grain and straw, 11.3 months for corn, forage, grain, stover and K+CWHR, 8.1 months for sorghum forage, grain and stover, and 7.4 months for rice grain and straw. Adequate storage stability data are available for wheat matrices which may be translated to corn, sorghum and rice matrices, and will support the storag e conditions and durations of samples from the cereal grain field trials. Prior to the analysis for triazole residues, samples were stored frozen for maximum durations of 8.8 - 10.6 months for wheat forage, hay, grain and straw, 6.3 - 10.9 months for corn, fo rage, grain, stover and K+CWHR, 5.1 - 8.2 months for sorghum forage, grain and stover, and 5.8 - 6.0 months for rice grain and straw. Storage stability of the triazole - related metabolites (T, TA, and TAA) has been demonstrated in apple, wheat flour, peanut butter, milk , and eggs stored frozen for up to 12 months. Because T, TA, and TAA appear re asonably stable, data for wheat flour may tentatively be translated to support the storage conditions and durations of wheat, corn, sorghum, and rice grain samples fro m the subject field trials. The stability confirmation will be assessed when the final report of an ongoing study investigating the storage stability of T, TA and TAA in canola seed, turnip roots, mustard greens, and wheat straw, grain , and forage is subm itted and reviewed The results of the field trials are summarized below in Table 6 . T able 6 . S ummary of Residue Data fromCrop Field Trials with Triticonazole . Commodity Applic.

Rate (g ai/100 kg seed) DAP

(days) Residue Levels (ppm) 1

n Min. Max . HAFT 2 Median (STMdR) Mean

(STMR) Std.

Dev. 3Triticonazole Summary of Analytical Chemistry and Residue Data DP#s: 360624; 325956, 353372

Page 20 of 37 T able 6 . S ummary of Residue Data fromCrop Field Trials with Triticonazole . Commodity Applic.

Rate (g ai/100 kg seed) DAP

(days) Residue Levels (ppm) 1

n Min. Max . HAFT 2 Median (STMdR) Mean

(STMR) Std.

Dev. 3 Proposed Rate on Barley, Corn ( Field and Pop ) , Oats, Rye, Wheat , and Triticale = 0.050 lb ai/100 lb seed Proposed Rate on Sweet Corn = 0.010 lb ai/100 lb seed P roposed Rate on Sorghum = 0.020 lb ai/100 lb seed) Triticonazole Wheat, forage 50 35 - 102 30 <0.01 0.10 0.10 0.02 0.04 0.028 Wheat, hay 50 56 - 135 30 <0.01 0.08 0.08 0.02 0.03 0.026 Wheat, grain 50 90 - 177 30 <0.01 <0.01 <0.01 0.01 0.01 NA Wheat, straw 50 90 - 177 30 <0.01 0.08 0.08 0.03 0.03 0.024 Corn, forage 4 50 78 - 155 38 <0.01 <0.01 <0.01 0.01 0.01 NA Corn, grain 50 112 - 161 30 <0.01 <0.01 <0.01 0.01 0.01 NA Corn, stover 4 50 92 - 176 38 <0.01 <0.01 <0.01 0.01 0.01 NA Corn, K+CWHR 50 71 - 114 18 <0.01 <0.01 <0.01 0.01 0.01 NA Sorghum, forage 50 61 - 113 24 <0.01 <0.01 <0.01 0.01 0.01 NA Sorghum, grain 50 90 - 199 24 <0.01 <0.01 <0.01 0.01 0.01 NA Sorghum, stover 50 90 - 199 24 <0.01 <0.01 <0.01 0.01 0.01 NA Rice, grain 50 114 - 182 24 <0.01 0.02 0.02 0.01 0.01 0.003 Rice, straw 50 114 - 182 24 <0.01 0. 04 0.04 0.01 0.02 0.009 Triazole (T) Wheat, forage 50 35 - 102 30 <0.05 <0.05 <0.05 0.05 0.05 NA Wheat, hay 50 56 - 135 30 <0.05 <0.05 <0.05 0.05 0.05 NA Wheat, grain 50 90 - 177 30 <0.01 <0.01 <0.01 0.01 0.01 NA Wheat, straw 50 90 - 177 30 <0.05 <0.05 <0.05 0.05 0.05 NA Corn, forage 4 50 78 - 155 38 <0.05 <0.05 <0.05 0.05 0.05 NA Corn, grain 50 112 - 161 30 <0.01 <0.01 <0.01 0.01 0.01 NA Corn, stover 4 50 92 - 176 38 <0.05 <0.05 <0.05 0.05 0.05 NA Corn, K+CWHR 50 71 - 114 18 <0.01 <0.01 <0.01 0.01 0.01 NA Sorghum, forage 50 61 - 113 24 <0.05 <0.05 <0.05 0.05 0.05 NA Sorghum, grain 50 90 - 199 24 <0.01 <0.01 <0.01 0.01 0.01 NA Sorghum, stover 50 90 - 199 24 <0.05 <0.05 <0.05 0.05 0.05 NA Rice, grain 50 114 - 182 24 <0.01 <0.01 <0.01 0.01 0.01 NA Rice, straw 50 114 - 182 24 <0.05 <0.05 <0.05 0.05 0.05 NA Triazolylalanine (TA) Wheat, forage 50 35 - 102 30 <0.05 0.12 0.11 0.05 0.05 0.015 Wheat, hay 50 56 - 135 30 <0.05 0.14 0.13 0.05 0.06 0.021 Wheat, grain 50 90 - 177 30 <0.05 0.26 0.24 0.06 0.10 0.063 Wheat, straw 50 90 - 17 7 30 <0.05 0.07 0.07 0.05 0.05 0.004 Corn, forage 4 50 78 - 155 38 <0.05 <0.05 <0.05 0.05 0.05 NA Corn, grain 50 112 - 161 30 <0.05 0.35 0.31 0.05 0.07 0.065 Corn, stover 4 50 92 - 176 38 <0.05 <0.05 <0.05 0.05 0.05 NA Corn, K+CWHR 50 71 - 114 18 <0.05 0.26 0. 24 0.05 0.07 0.061 Sorghum, forage 50 61 - 113 24 <0.05 0.10 0.08 0.05 0.05 0.010 Sorghum, grain 50 90 - 199 24 <0.05 0.39 0.38 0.05 0.08 0.091 Sorghum, stover 50 90 - 199 24 <0.05 0.26 0.25 0.05 0.07 0.057 Rice, grain 50 114 - 182 24 <0.05 0.29 0.29 0.05 0.07 0.066 Rice, straw 50 114 - 182 24 <0.05 <0.05 <0.05 0.05 0.05 NATriticonazole Summary of Analytical Chemistry and Residue Data DP#s: 360624; 325956, 353372

Page 21 of 37 T able 6 . S ummary of Residue Data fromCrop Field Trials with Triticonazole . Commodity Applic.

Rate (g ai/100 kg seed) DAP

(days) Residue Levels (ppm) 1

n Min. Max . HAFT 2 Median (STMdR) Mean

(STMR) Std.

Dev. 3 Triazolyl - acetic acid (TAA) Wheat, forage 50 35 - 102 30 <0.05 <0.05 <0.05 0.05 0.05 NA Wheat, hay 50 56 - 135 30 <0.05 0.13 0.11 0.05 0.06 0.016 Wheat, grain 50 90 - 177 30 <0.01 0.20 0.20 0.0 4 0.05 0.046 Wheat, straw 50 90 - 177 30 <0.05 0.10 0.10 0.05 0.05 0.011 Corn, forage 4 50 78 - 155 38 <0.05 <0.05 <0.05 0.05 0.05 NA Corn, grain 50 112 - 161 30 <0.01 <0.01 <0.01 0.01 0.01 NA Corn, stover 4 50 92 - 176 38 <0.05 <0.05 <0.05 0.05 0.05 NA Corn, K+CWHR 50 71 - 114 18 <0.01 <0.01 <0.01 0.01 0.01 NA Sorghum, forage 50 61 - 113 24 <0.05 0.07 0.06 0.05 0.05 0.004 Sorghum, grain 50 90 - 199 24 <0.01 0.37 0.35 0.01 0.04 0.095 Sorghum, stover 50 90 - 199 24 <0.05 <0.05 <0.05 0.05 0.05 NA Rice, grain 50 114 - 182 24 <0.01 0.50 0.50 0.03 0.07 0.134 Rice, straw 50 114 - 182 24 <0.05 0.34 0.34 0.05 0.08 0.082 1 For statistical calculations, the LOQ (0.01 ppm for triticonazole; 0.05 ppm for each triazole analyte, except for T and TAA in corn grain and K+CWHR which have a LOQ of 0.01 ppm each) was used for all values reported below the LOQ. 2 HAFT = Highest Average Field Trial. 3 Standard deviation is not applicable (NA) when all samples have residues below the LOQ. 4 Represented by 8 sweet corn samples, and 30 field corn samples . Corn forage samples from the sweet corn trials were harvested prior to collection of K+CWHR from 3 trials and 50 days after in the other trial, and corn forage from the 5 field corn trials, which also collected fresh corn to represent K+CWHR and bridge sweet corn requirements, was harvested 1 - 5 weeks after samples of fresh corn at the milk dough stage. The field corn forage samples do not actually

represent sweet corn forage ty pically collected prior to or with K+CWHR; however, given that residues of triticonazole were nonquantifiable in all corn forage samples and application was made to seed prior to planting, no additional sweet corn forage samples will be required. Conclusions . The submitted residue data are adequate to support th e requested seed treatment use s for cereal grain crops (except rice) pending submission of the final study report from an ongoing triazole - related residues storage stability study . There are adequate data for the representative crops of the cereal grain groups 15 and 16 to establish crop group or individual tolerances. The number and locations of field trials were conducted according to the 860.1500 guidelines . The seed treatment rate (0.05 lb ai/100 lbs seed) used in the field trials reflect s the propos ed use of Triticonazole HL Fungicide (EPA Reg. No. 7969 - xxx ) on b arley , f ield c orn and p opcorn, o ats, r

ye , wheat , and triticale. However, the rate reflect s 5x and 2.5x the proposed seed treatment rate for sweet corn and sorghum, respectively . Residues of triticonazole were below the L OQ of 0.01 ppm in treated wheat grain, corn grain, corn K+CWHR , and sorghum grain . It is noted that the seed treatment rate used for sweet corn and sorghum were exaggerated. L ow but quantifiable residues of triticonazole were observed in rice grain. However, b ecause the petitioner is excluding the use of Triticonazole HL Fungicide on rice, the available data will support a tolerance at the L OQ (0.01 ppm) for the cereal grains, group 15 (except rice) .Triticonazole Summary of Analytical Chemistry and Residue Data DP#s: 360624; 325956, 353372

Page 22 of 37 Residues of triticon azole were also nonquantifiable in treated field and sweet corn forage and stover, and sorghum forage and stover. Quantifiable residues of triticonazole were observed in treated wheat forage, hay and straw, and rice straw. The appropriate tolerance level s were statistically

calculated (see Appendix I) according to Guidance for Setting Pesticide Tolerances Based on Field Trial Data SOP. The residue data for rice straw was excluded from the spreadsheet because the petitioner is not applying for use on rice . The tolerance spreadsheet calculated tolerances of 0.20 ppm for wheat forage, 0.25 ppm for wheat hay, and 0.20 ppm for wheat straw. Based on the maximum residue determined for the representative crops, HED recommends a crop group 16 tolerance for triti conazole of 0.25 ppm. A revised Section F must be submitted to reflect the tolerance recommendation for the forage, fodder, and straw of cereal grain , group 16. The residue data and tolerances recommended in this document will also support the currently registered seed treatment uses of Charter® Fungicide Treatment (EPA Reg. No. 7969 - 386) for preplant seed treatment on barley and wheat. 860.1520 Processed Food and Feed DER Reference : 47511901.der.doc BASF has submitted a processing study for triticon azole with field corn, rice, sweet sorghum, and wheat. Four field trials were conducted (one field trial for each representative crop) in the United States during the 2007 growing season. At each test location, cereal grain crops were grown from seed s treated with a 4.2 lb/gal flowable liquid formulation of triticonazole, prior to planting, at 250 g ai/100 kg seed (4 oz ai/100 lb seed; 5x the proposed seed treatment rate) . T he triticonazole formulation was mixed with Apron XL(mefenoxam; a seed fungicide ) and a colorant. A separate plot (untreated) was planted with seed treated with Apron XL and colorant only . The application made to sorghum seed additionally included py raclostrobin; the py raclostrobin data are not reviewed herein. Samples of field c orn, rice and wheat grain, and sweet sorghum stalks were collected at maturity and processed using procedures simulating commercial practices for corn grits, meal, oil (dry and wet milled), starch and flour; rice hulls, bran and polished rice; sorghum sy ru p; and wheat bran, flour, middlings, shorts, and germ. All samples were analy

zed for triticonazole using L C/MS/MS Method 562/0. The method was adequate for data collection based on acceptable concurrent method recoveries with wheat grain, corn grain, sorghum stalk, and rice grain, bran, hulls and polished rice. The validated method LOQ was 0.01 ppm in/on all tested cereal grain RACs and processed matrices. Samples were also analy

zed for the triazole - related metabolites, triazole (T), triazoly l - acetic ac id (TAA) and triazolylalanine (TA) using LC/MS/MS Methods D0508 and D0604 (grain). The validated method L OQ was 0.01 ppm for T in wheat grain, bran, and flour; corn grain oil and starch; sorghum stalks; and rice grain, bran, hulls and polished rice, and TAA in wheat grain, bran, germ, middlings, shorts and flour; corn grain, flour, grits, meal, oil and starch; sorghum stalks and sy

rup; and rice grain, bran, hulls and polished rice. The validated L OQ for TA was 0.05 ppm in wheat grain, bran, germ, middling s, shorts and flour; corn grain, flour, grits, meal,Triticonazole Summary of Analytical Chemistry and Residue Data DP#s: 360624; 325956, 353372

Page 23 of 37 oil and starch; sorghum stalks and sy rup; and rice grain, bran, hulls, and polished rice. RAC samples were stored frozen from harvest to analysis for triticonazole residues for up to 6.7 months for corn grain, rice grain, sorghum stalks, and wheat grain. The only processed commodities analy

zed for triticonazole residues were stored frozen from collection to analysis f or up to 1 month for rice hulls, 1.5 months for wheat bran , and 6.7 months for polished rice . Storage stability

data for triticonazole are available for wheat grain , forage, hay, and straw, and processed wheat germ, flour and bran which may be translated to support the storage durations of corn, rice, and wheat grain, sorghum stalks, and ri ce bran from the subject processing studies. The maximum storage durations of RAC samples from harvest to analysis of triazole residues were 10.4 months for corn, rice and wheat grain and 5.9 months for sorghum stalks. Because T, TA, and TAA appear relatively stable, data for wheat flour may be translated to support the storage conditions and durations of wheat, corn, sorghum, and rice grain (RAC) samples from the subject processing study . A final report for stability of T, TA and TAA in canola seed, turnip roots, mustard greens, and wheat straw, grain , and forage is to be submitted upon completion. The maximum storage durations for processed matrices from collection to analysis for triazole metabolites were 0.3 - 0.4 months for corn oil and starch; 1 mo nth for rice bran and 1.2 - 1.3 months for hulls and polished rice; 0.7 months for sorghum sy rup; and 1.8 - 2.3 months for corn flour, grits and meal, and wheat bran, flour, middlings, shorts and germ. The submitted storage stability data for wheat flour will support the storage durations of corn and wheat flour samples and may be translated to support polished rice samples . Supporting storage stability data are not required for corn oil and starch; rice bran; and sorghum sy rup as these matrices were analy zed within 30 days of processing. Supporting storage stability data are, however, required for T, TA and TAA in frozen rice hulls, corn grits and meal, and wheat bran, middlings, shorts, and germ . The processing data for field corn, rice, sweet sorghum, and wheat showed that residues of triticonazole were nonquantifiable (<0.01 ppm) in the RACs (corn, rice, and wheat grain or sorghum stalk) grown from seeds treated at 250 g triticonazole/100 kg seed. Corn, sorghum and wheat processed matrices were, therefore, not analy zed. However, rice processed matrices were analy zed because some quantifiable residues were detected in the field trials conducted at the nominal rate (see 47470203.der.doc). Residues of triticonazole were <0.01 ppm in polished rice, 0.025 - 0. 031 ppm in hulls, and 0.010 - 0.011 ppm in bran. Based on the results of the rice processing study , residues of triticonazole may concentrate in hulls (2.8x) but do not appear to significantly

concentrate in bran (1.1x). Processing factors in polished rice could not be calculated because residues were nonquantifiable in both the RAC and processed matrix. Residues of the triazole - related metabolite T were nonquantifiable (<0.01 ppm) in corn, rice and wheat grain, and sorghum stalks (RACs) and the processed commodities of wheat bran and flour, corn oil (dry

and wet milled) and starch, and rice hulls, bran and polished rice. Processing factors could not be calculated for these matrices, and analysis of all processed matrices was not required being that T resi dues were nonquantifiable in the respective RAC samples. Residues of the triazole - related metabolite TA were nonquantifiable (<0.05 ppm) in sorghum stalks and processed sy

rup; therefore, processing factors could not be calculated. However, residues of TA were quantifiable in wheat grain (0.08 ppm), corn grain (0.08 - 0.09 ppm), and riceTriticonazole Summary of Analytical Chemistry and Residue Data DP#s: 360624; 325956, 353372

Page 24 of 37 grain (0.06 - 0.07 ppm). Residues of TA were 0.18 - 0.20 ppm in wheat bran, <0.05 ppm in flour, 0.06 ppm in middlings, 0.08 ppm in shorts, and 0.13 - 0.23 ppm in germ; 0.052 - 0.06 0 ppm in corn grits, 0.098 - 0.105 ppm in meal, and <0.05 ppm in oil (dry and wet milled), starch and flour; and <0.05 ppm in rice hulls and polished rice, and 0.39 - 0.40 ppm in bran. Based on the results of the wheat, corn and rice processing studies, resid ues of TA do not concentrate in wheat flour (0.6x), middlings (0.8x) and shorts (1x); corn grits (0.6x), oil (dry and wet milled; 0.6x), starch (0.6x), flour (0.6x), and meal (1.1x); and rice hulls (0.7x) and polished rice (0.7x). Residues of TA appear to concentrate in wheat bran (2.4x) and germ (2.3x); and rice bran (5.7x). Residues of the triazole - related metabolite TAA were nonquantifiable (<0.01 ppm) in corn grain and sorghum stalks (RACs) and processed corn grits, meal, oil (dry and wet milled), starch and flour, and sorghum sy

rup, therefore, processing factors could not be calculated. However, residues of TAA were quantifiable in wheat grain (0.03 ppm) and rice grain (0.10 ppm). Residues of TAA were 0.04 ppm in wheat bran, 0.02 - 0.03 ppm in flour, 0.03 ppm in middlings, 0.03 ppm in shorts, and 0.03 ppm in germ; and 0.05 - 0.12 ppm in rice hulls, 0.05 - 0.06 ppm in polished rice, and 0.58 - 0.65 ppm in rice bran. Based on the results of the wheat and rice processing studies, residues of TAA do not concentrate in wheat flour, middlings, shorts, and germ (1x); and rice hulls (0.9x) and polished rice (0.6x). Residues of TAA appear to concentrate in rice bran (6.2x) and only slightly in wheat bran (1.3x). The observed processing factors of triticonazole in rice hulls (2.8x) and bran (1.1x) were below the theoretical concentration factors (860.1520, Table 3; based on separation into components) of 5x for rice hulls and 7.7x for rice bran. The theoretical concentration factors (860.1520; Table 3) for other cereal grain matrices tested are 25x for corn oil, 7.7x for wheat bran, 1.4x for wheat flour, and 8.3x for wheat shorts. No theoretical concentration factors are cited for sweet sorghum in 860.1520. A summary

of the processing factors for triticonazole and the triazoles TA and TAA is presented in Table 7 . T is not included because residues were nonquantifiable in the RAC and all processed matrices tested. Table 7 . Summary of Processing Factors for Triticonazole and Triazoles .

RAC Pro cessed Commodity Processing Factor 1 Triticonazole TA TAA Wheat Bran NA 2.4x 1.3x Flour NA 0.6x 1x Middlings NA 0.8x 1x Shorts NA 1x 1x Germ NA 2.3x 1x Corn Grits NA 0.6x NC Meal NA 1.1x NC Oil, dry milled NA 0.6x NC Oil, wet milled NA 0.6x NC Starch NA 0.6x NC Flour NA 0.6x NC Sorghum, sweet Syrup NA NC NCTriticonazole Summary of Analytical Chemistry and Residue Data DP#s: 360624; 325956, 353372

Page 25 of 37 Table 7 . Summary of Processing Factors for Triticonazole and Triazoles .

RAC Pro cessed Commodity Processing Factor 1 Triticonazole TA TAA Rice Polished rice NC 0.7x 0.6x Hulls 2.8x 0.7x 0.9x Bran 1.1x 5.7x 6.2x 1 NA = Not analyzed because residues were nonquantifiable in the RAC at nominal and exaggerated rates. NC = Not calculated because residues were nonquantifiable in both the RAC and processed matrix. Conclusions . The processing data for field corn, rice, sweet sorghum , and wheat are adequate pending submission of additional supporting freezer storage stability data for T, TA , and TAA in rice hulls, corn grits and meal, and wheat bran, middlings, shorts, and germ for up to 2 months . The results indicate that residues of triticonazole were nonquantifiable (<0.01 ppm) in the c e real grain RAC s (corn, ric e, wheat , and sorghum) grown from seed s treated at 250 g triticonazole/100 kg seed (5x the maximum proposed seed treatment rate) . The p rocessed corn, sorghum , and wheat matrices were not further analy zed . Analysis of rice processed matrices showed that residues of triticonazole may concentrate in hulls (2.8x) but not significantly in bran (1.1x) ; residues in polished rice were nonquantifiable . As the petitioner is not seeking to register use on rice at this time , no tolerances are required for rice proce ssed matrices. However, based on the HAFT for rice grain (0.02 ppm) and processing factors of 2.8x for hulls, the maximum expected triticonazole residues would be 0.06 ppm in rice hulls. 860.1650 Submittal of Analytical Reference St andards Analy tical standards for triticonazole are currently available in the EPA National Pesticide Standards Repository (personal communication with Dallas Wright, ACB, 2 /23/09 ) , expiration date 7/8/2014 . 860.1850 Confined Accumulation in Rotational Crops DER Reference : 47399201.der.doc Residue Chemistry Memo DP# 262566, 6/6/2001, N. Dodd (PP#9F6051) BASF has submitted a confined rotational crop study with [ 14 C - phenyl]triticonazole and [3(5) - 14 C - triazole]triticonazole. The study was submitted in s upport of the current petition and in response to the condition of registration requirement under PP# 9F6051 ( DP# 262566, 6/6/2001, N. Dodd). Each radiolabeled test substance was applied as a solution in methanol to bare soil in pots maintained in a greenhouse at a nominal rate of 0.107 lb ai/A. After soil treatment, rotational crops consisting of lettuce, radish, and spring wheat were planted 30, 120 and 365 days. L ettuce, radish roots and tops, and wheat grain, chaff and straw were harvested at maturity, and wheat forage was harvested 61 - 63 days after planting (DAP). Total radioactive residues (TRR) were determined for the rotated crops; see Table 8 below. TRR ranged from 0.003 ppm in phenyl - label radish root (365 - day PBI) to 0.848 ppm in triazole - lab el wheat chaff (120 - day

PBI) . Significantly

higher TRR (by

a factor of ≥ 3) were observed in the triazole - label matrices than in the respective phenyl - label matrices. TRR ty pically declined with later plantback intervals (PBI s), except in mature wheat matrices (straw, chaff, and/or grain).Triticonazole Summary of Analytical Chemistry and Residue Data DP#s: 360624; 325956, 353372

Page 26 of 37 Table 8 . Total Radioactive Residues in Rotated Lettuce, Radish, and Wheat Matrices. Matrix Plantback interval (days) Phenyl Label (ppm) Triazole Label (ppm)

Combustion Calculated 1 Combustion Calculated 1 Lettuce 30 0.020 0.024 0.065 0.065 120 0.014 0.014 0.026 0.025 365 0.005 0.004 0.029 0.024 Radish, roots 30 0.009 0.009 0.099 0.094 120 0.006 0.006 0.055 0.056 365 0.003 0.003 0.031 0.029 Radish, tops 30 0.072 0.067 0.279 0.256 120 0.052 0.040 0.33 1 0.286 365 0.011 0.009 0.128 0.043 Wheat, forage 30 0.067 0.042 0.199 0.129 120 0.049 0.035 0.155 0.095 365 0.029 0.015 0.141 0.107 Wheat, straw 30 0.209 0.181 0.629 0.580 120 0.345 0.298 0.675 0.576 365 0.282 0.198 0.520 0.455 Wheat, chaff 3 0 0.181 0.174 0.509 0.571 120 0.151 0.141 0.848 0.786 365 0.106 0.095 0.562 0.549 Wheat, grain 30 0.008 0.008 0.453 0.948 120 0.054 0.053 0.689 0.706 365 0.025 0.028 0.682 0.773 1 Calculated by the summation of extractable and nonextractable radi oactivity; these values were used by the petitioner for all further calculations. To characterize and identify radioactive residues in rotated crops, samples were sequentially extracted and partitioned with organic solvents. The nonextractable residues in representative 120 - DAT wheat grain and straw were further released with aqueous ammonia extraction and enzy me hydrolysis. Initial identification of extracts and hydrolysates was accomplished by co chromatography

using several HPLC systems, and confirmation of residues was made by LC /MS/MS. TRR accountabilities were 63 - 120% for phenyl - label rotated crop matrices and 34 - 209% for triazole - label rotated crop matrices. Accountabilities indicate that the extraction procedures may

not have adequately

released radioactivity

in some rotated crop matrices, but TRR levels in the extracted samples were sufficient to characterize the residues in rotated crops matrices. The parent, triticonazole, was the only residue identified in phenyl - label rotated crop matric es. Triticonazole accounted for 4.2 - 15.4% TRR (<0.01 ppm) in 30 - DAT lettuce, radish root and tops, and wheat forage and chaff, and 6.5% TRR (0.012 ppm) in 30 - DAT wheat straw; 30 - DAT wheat grain was not analy zed because extractable radioactivity was only 0 .002 ppm. In 120 - DAT rotated crop samples, triticonazole accounted for 0.2 - 10.0% TRR (<0.01 ppm) in lettuce, radish tops, and wheat forage, chaff, and grain, and 8.2% TRR (0.025 ppm) in wheat straw; 120 - DAT radish root was not analy zed because extractable radioactivity was only 0.004 ppm. In 365 - DAT rotated crop samples, triticonazole accounted for 3.5 - 4.8% TRR (<0.01 ppm) in wheat straw and chaff; other 365 - DAT crop matrices (lettuce, radish tops and root, wheat grain and forage) were not analy

zed becaus e extractable radioactivities were only 0.002 - 0.006 ppm.Triticonazole Summary of Analytical Chemistry and Residue Data DP#s: 360624; 325956, 353372

Page 27 of 37 The parent, triticonazole, was also identified in all triazole - label rotated crop matrices, except wheat grain. Triticonazole accounted for 7.8% TRR (<0.01 ppm) in 30 - DAT radish root, and 19.2 - 32.1 % TRR (0.017 - 0.133 ppm) in 30 - DAT lettuce, radish tops, and wheat forage, straw and chaff. In 120 - DAT rotated crop samples, triticonazole accounted for 5.2% and 5.5% TRR (<0.01 and 0.016 ppm) in radish root and tops, respectively, 22.3% TRR (<0.01 ppm) in lettuce, and 14.5 - 26.0% TRR (0.019 - 0.150 ppm) in wheat forage, straw and chaff. In 365 - DAT rotated crop samples, triticonazole accounted for 6.6 - 13.6% TRR (<0.01 ppm) in lettuce, radish root, and radish tops, and 18.9 - 24.1% TRR (0.025 - 0.133 ppm) in wheat forage, straw and chaff. Triazole - related metabolites, TA and TAA, were identified in triazole - label rotated crop matrices. TA accounted for 1.0 - 6.4% TRR (0.004 - 0.017 ppm) in 30 - DAT lettuce, wheat straw, and wheat grain, and 10.8 - 40.4% TRR (0.028 - 0.103 ppm) in radish root and tops, and wheat forage and grain. TAA was only identified in 30 - DAT lettuce at 12.2% TRR (0.008 ppm) and wheat straw, chaff, and grain at 17.1 - 29.8% TRR (0.139 - 0.173 ppm). In 120 - DAT rotated crop samples, TA residues increased in most mature matrices and accounted for 13.2% TRR (0.003 ppm) in lettuce, and 6.8 - 44.4% TRR (0.013 - 0.313 ppm) in radish root and tops, and wheat forage, chaff and grain; TA was not detected in 120 - DAT wheat straw. In 365 - DAT rotated crop samples, TA residu es increased in all matrices, except wheat grain, and accounted for 21.7 - 24.8% TRR (0.005 - 0.007 ppm) in lettuce and radish root, 34.7 - 40.7% TRR (0.015 - 0.044 ppm) in radish tops and wheat forage, and 8.5 - 8.8% TRR (0.048 - 0.066 ppm) in wheat chaff and grain; TA was detected at low levels (2.0% TRR, 0.009 ppm) in 365 - DAT wheat straw. TAA was not detected in any

120 - or 365 - DAT samples. An unknown polar peak, accounting for ~5 - 18% TRR (0.002 - 0.059 ppm), was detected in all triazole - label rotated crop matrices, except wheat grain. The unknown peak generally declined with later plantback intervals. L C/MS/MS of the aqueous phase of the methanol extract of radish top and ethyl acetate phase of the methanol extract of wheat straw confirmed no significant isotope p attern and no evidence for free triazole in the unknown peak. The unknown was characterized as a polar cluster consisting of more than 25 peaks at negligible levels; however, quantitative data were not provided. The remaining extractable residues were ch aracterized as polar, medium polar, or nonpolar peaks accounting for ~1 - 16% TRR ( ≤0.001 to ≤0.016 ppm) in phenyl - label samples and ~1 - 29% TRR ( ≤0.001 to ≤0.027 ppm) in triazole label - samples. All samples and extracts were stored frozen prior to analysis. Based on the analysis dates obtained from the HPL C chromatograms, the m ajority of rotated crop samples were initially analy zed within six months of harvest. Several samples (i.e., 30 - DAT lettuce, radish roots and tops, and wheat forage, straw and chaff; 120 - DAT wheat straw; and 365 - DAT lettuce, wheat forage and chaff) were s tored for up to 9.6 months prior to initial HPL C analysis. HPL C analyses and co - chromatography to further characterize and confirm metabolite identifications were conducted on samples/extracts stored up to ~18 months. The dates of sample extraction, part itioning, and further hydrolysis of nonextractable wheat grain and straw samples were not reported. Re - analysis of methanol extracts of phenyl - label lettuce, radish root, radish tops and spring wheat (30 - DAT), and triazole - label lettuce, radish root and wheat grain (30 - DAT) demonstrate similar metabolic profiles in the re - analy zed (~13 months after initial analysis) and initial sampleTriticonazole Summary of Analytical Chemistry and Residue Data DP#s: 360624; 325956, 353372

Page 28 of 37 extracts. Re - extraction and re - analysis of phenyl - label radish top and triazole - label radish root and wheat grain samples (~14 - 15 months after the initial analysis) also demonstrate similar extractability

and metabolic profiles in the re - extracted and initial samples. Given that the majority of samples appear to have been analy zed within 6 months, the available storage stabi lity data will be considered adequate to support the subject study . Based on the submitted confined rotational crop study, HED concludes that metabolism of triticonazole in rotational crops involved degradation of triticonazole in the soil resulting in th e formation of free triazole. As a very polar compound, free triazole is easily taken up by

the plants and transformed to triazolylalanine (TA), which is further metabolized to triazolylacetic acid (TAA) and other polar conjugates. The occurrence of resi dual radioactivity indicates that a portion of residues was incorporated and/or associated into natural products, such as starch, cellulose and/or lignins. Conclusions . The confined rotational crop study is acceptable . The application rate used reflects 1.4x the e quivalent per acre rate proposed for cereal grain crops. The m etabolism of triticonazole in rotated crops appears similar to th ose observed for primary crops , except that triazole - related metabolites were detected in the rotated crops . The dat a indicate that residues of triticonazole may be present at >0.01 ppm in 30 - DAT rotated lettuce ( 0.017 ppm) , radish tops (0.049 ppm) and wheat forage (0.041 ppm) , straw (0.133 ppm) and chaff (0.139 ppm) ; 120 - DAT rotated radish tops (0.016 ppm), and wheat f orage (0.019 ppm), s traw (0.150 ppm), and chaff (0.114 ppm) ; and 365 - DAT rotated wheat forage (0.025 ppm) , straw (0.086 ppm) and chaff (0.133 ppm) . Wheat hay

was not analy

zed but forage and straw were analy zed, and residues of triticonazole were found in forage and straw. 860.1900 Field Accumulation in Rotational Crops The proposed label for the 4.17 lb/gal FS specifies that “planting of any crop not listed on the label within 30 days after planting treated seed is not allowed”. The results of the submitted confined rotational crop study do not support this restriction. The data from the confined rotational crop study

indicate that triticonazole residues greater than 0.01 ppm w ere detected at the 30 - day

PBI . T o support a 30 - day plantback restriction on the label, limited field rotational crop data for leafy

vegetable s, root and tuber vegetables , foliage of root and tuber vegetables , and a cereal grain are required. Until the requested data are provided, the label must be modified to specify a 120 - day

( 4 - month) plantback restriction for leafy vegetables, a 365 - day

(12 - month) plantback restriction for root and tuber vegetables, and prohibit the planting of all other crops not listed on the label. Although triticonazole was detected at >0.01 ppm in rotate d wheat forage, straw, and chaff planted at the 30 - , 120 - and 365 - day PBI s, the levels of triticonazole found in the confined rotational crop studies were below the recommended t olerance of 0.25 ppm for the forage, fodder, and straw of cereal grain crop group. Therefore, residues which may be found in rotated cereal grain crops (foliage) in the confined rotational crop study would not be expected to exceed the recommended tolerances for triticonazole. Nevertheless, HED continues to request data on a rotat ed cereal grain because the cereal grain represents other crops and residues in wheat as a rotational crop are often the highest .Triticonazole Summary of Analytical Chemistry and Residue Data DP#s: 360624; 325956, 353372

Page 29 of 37 860.1550 Proposed Tolerances Tolerances have been established under 40 CFR §180.583(a) for residues of the fungicide tritic onazole, (1 RS

) - ( E) - 5 - [(4 - chlorophenyl)methylene] - 2,2 - dimethyl - 1 - (1 H - 1,2,4 - triazol - 1 - yl methyl)cyclopentanol , from the treatment of seed prior to planting in/on barley grain, hay

and straw, and wheat grain, forage, hay and straw, each at 0.05 ppm. HED has previously determined that triticonazole is the residue of concern in barley and wheat from seed treatment uses . This regulatory

decision may

be extended to include all crop commodities in the cereal grains crop group . The petitioner has not specified th e tolerance expression with the proposed tolerances in Section F of the petition . T he submitted residue data for field corn grain, sweet corn K+CWHR, sorghum grain, and wheat grain , which are the rep resentative c ommodities of the cereal grain group , do not support the proposed tolerance for the ‘ Grain, cereal, group 15 (except rice) ’ at 0. 0 5 ppm . The data do support a tolerance for ‘Grain, cereal, group 15 (except rice)’ at 0.01 ppm. A revised Section F must be submitted to reflect the tolerance recomm endation of 0.01 ppm for “Grain, cereal, group 15 (except rice)” at 0.01 ppm. The established individual tolerances for wheat grain and barley grain must be deleted when the crop group tolerance is established. T he submitted residue data for corn forage a nd stover, sorghum forage and stover, and wheat f o rage, hay, and straw are adequate to determine a tolerance level for the forage, fodder, and straw of cereal grains crop group (except rice). Since the residues in wheat commodities were highest, the tolerance levels for wheat forage, wheat hay, and wheat straw were statistically calculated (see Appendix I) according to Guidance for Setting Pesticide Tolerances Based on Field Trial Data SOP (January 2008 version) . B ecause >10% of the residues were below th e LOQ (<0.01 ppm) , the maximum likelihood estimation (MLE) procedures were needed to impute censored values. The tolerance spreadsheet calculated tolerances of 0.20 ppm for wheat forage, 0.25 ppm for wheat hay, and 0.20 ppm for wheat straw . HED recommend s a crop group tolerance of 0.2 5 ppm for the forage, fodder, and straw of the cereal grain crop group , group 16, based on the highest calculated value for the wheat commodities (0.25 ppm for wheat hay ) . A revised Section F must be submitted to reflect the tolerance recommendation of 0.25 ppm for “Grain, cereal, f

orage, fodder, and straw, group 16 (except rice) ” as shown in Table 9. The established individual tolerances for barley hay and straw, and wheat forage, hay and straw must be deleted when the cro p group tolerance is established. T he processing data for corn, sorghum , and wheat showed no concentration of triticonazole residues following seed treatment at 5x. The processing data for rice showed that residues of triticonazole concentrated in hull s (2.8x) but not significantly in bran (1.1x). As rice is excluded from the proposed seed treatment uses on cereal grains, no tolerances are required for the processed commodities of cereal grains for the purpose of this action. Based on the available co w and poultry metabolism studies, and low levels of residues found in the cereal grain field trials, there is no reasonable expectation that quantifiable residues of triticonazole will occur in livestock commodities [40 CFR § 180.6(a)(3)]. Therefore, lives tock tolerances are not required at this time.Triticonazole Summary of Analytical Chemistry and Residue Data DP#s: 360624; 325956, 353372

Page 30 of 37 A summary

of the recommended tolerances for the petition is listed in Table 9 . There are no Codex or Mexican MRL s established for residues of triticonazole . Canadian MRL s are established for triticonazole per se in/on barley, wheat and oats each at 0.01 ppm. Table 9 . Tolerance Sum ma ry for Triticonazole Commodity Established/Proposed Tolerance (ppm) Recommended

Tolerance (ppm) Comments ; C orrect Commodity D efinition Established tolerances under 180.583 ( a) Barley, grain 0.05 Remove Barley grain will be covered with the establishment of the cereal grain, group 15 (except rice) tolerance . Barley, hay 0.05 Remove Increase in the tolerance based on residues resulting from new uses. Barley hay and straw and wheat forage will be covered with the establishment of the cereal grain group 16 (except rice) tolerance . Barley, straw 0.05 Remove Wheat, forage 0.05 Remove Wheat grain 0.05 Remove Barley grain will be covered with the establishment of the cereal grain, group 15 (except rice) tolerance Wheat, hay 0.05 Remove Increase in the tolerance based on residues resulting from new uses. Wheat hay and straw and will be covered with the establishment of the cereal grain group 16 (except rice) tolerance. Wheat, s traw 0.05 Remove

T olerances to be established under 180.583 (a) Grain, cereal, group 15 (except rice) 0.05 0.01 . Grain, cereal, forage, fodder, and straw , group 16 (except rice) 0.10 0.2 5 .Triticonazole Summary of Analytical Chemistry and Residue Data DP#s: 360624; 325956, 353372

Page 31 of 37 References DP#: 270496 Subject: PP#9F6051. Triticonazole on Barley and Wheat. Method Validation Request. From: N. Dodd To: F.D. Griffith Dated: 12/7/2000 MRIDs: 44904518, 44904519 DP#: 262566 Subject: PP#9F6051. Triticonazole Seed Treatment on Barley and Wheat. Review of Analy tical Methods and Residue Data. First Food Use Review. From: N. Dodd To: S. Gardner - Jenkins/M. Waller Dated: 6/6/2001 MRIDs: 44904515 - 25, 44995701 - 06 DP#: 322215 Subject: 1,2,4 - Triazole, Triazole Alanine, Triazole Acetic Acid: Human Health Aggregate

Risk Assessment in Sup port of Reregistration and Registration Actions for Triazole - derivative Fungicide Compounds. From: M. Doherty ; K. Raffaele; K. Farwell; S. Dapson; K. Schumacher; J. Arthur; D.

Hrdy ; I . Maher To: T. Gibson/C. Giles Parker; M. Goodis; S. L ewis Dated: 2/7/2006 MRIDs: None DP#: 303508 & 314517 Subject: PP#4F6830. Prothioconazole. Petition for Establishment of Tolerances for Use

on Barley , Oilseed (Except Sunflower and Safflower) Crop Group, Dried Shelled Pea and Bean (Except Soy bean) Crop Subgroup, P eanut, Rice, and Wheat. Summary of Analy tical Chemistry

and Residue Data. From: S. Funk To: L. Coppolino Date: 8/21/06 MRIDs: 46246139, 46246141 - 50, 46246201 - 11, 46246213 - 27, 46477701 - 04 Attachments: International Residue Limit S tatus sheet Appendix I - Tolerance Assessment Calculations Template Version September 2005Triticonazole Summary of Analytical Chemistry and Residue Data DP#s: 360624; 325956, 353372

Page 32 of 37 

## INTERNATIONAL RESIDUE LIMIT STATUS Chemical Name: (1RS) - (E) - 5 - [4 - chlorophenyl) methylene] - 2,2 - dimethyl 1 - (1H - 1,2,4 - triazol 1ylmethyl)cyclopentanol Common Name : Triticonazole X Proposed tolerance  Reevaluated tolerance  Other Date: 02/2009

Codex Status (Maximum Residue Limits) U. S. Tolerances X No Codex proposal step 6 or above  No Codex proposal step 6 or above for the crops requested Petition Number: PP# 8F7420 DP#: 36062 4 Other Identifier: Decision # 399232 Residue definition (step 8/CXL): N/A Reviewer/Branch: P. Deschamp, A. Acierto/RAB3 Residue definition: triticonazole per se Crop (s) MRL (mg/kg) Crop(s) Tolerance (ppm) Grain, cereal, group 15 (except rice) 0.05 Grain, cereal, forage, fodder and straw , group 16 (except rice) 0.10

Limits for Canada Limits for Mexico  No Limits  No Limits for the crops requested X No Limits  No Limits for the crops requested Residue definition: 5 - [(4 - chlorophenyl)methylene] - 2,2 - dimethyl - 1 - (1 H

- 1,2,4 - triazol - 1 - ylmethyl)cyclopentanol Residue definition: N/A Crop(s) MRL (mg/kg) Crop(s) MRL (mg/kg) Barley 0.01 Wheat 0.01 Oats 0.01 Notes/Special Instructions: S.F unk, 02/19/2009.Triticonazole Summary of Analytical Chemistry and Residue Data DP#s: 360624; 325956, 353372

Page 33 of 37 Appendix I. Tolerance Assessment Calculations. Wheat The dataset used to establish tolerances for triticonazole on wheat forage, hay, and straw consisted of field trial data representing application rates of 50 g ai/100 kg seed (see d treatment), with samples collected at ty pical commercial harvest. As specified by the Guidance for Setting Pesticide Tolerances Based on Field Trial Data (SOP), the field trial application rates are within 25% of the maximum label application rate. The residue values that were entered into the tolerance spreadsheet are provided in Table I - 1. Because 4 of 30 field trial sample results for wheat forage, 8 of 30 field trial sample results for wheat hay , and 6 of 30 field sample results for wheat straw were below the LOQ, maximum likelihood estimation (MLE) procedures were needed to impute censored values. For these matrices v isual inspection of the lognormal probability plot s (Figure s I - 1, I - 3, and I - 5 ) and the results from the approximate Shapiro - Francia test statistic (Figure s I - 2, I - 4, and I - 6 ) indicate d that the datasets were reasonably lognormal. Since the field trial data for triticonazole on wheat forage, hay, and straw represent large dataset s (i.e., more than 15 samples) and are reasonably lognor mal, the minimum of the 95% upper confidence limit (UCL) on the 95 th percentile and the point estimate of the 99 th percentile should be selected as the tolerance value. Using the rounding procedure as outlined in the SOP, the recommended tolerances are 0. 20 ppm for wheat forage, 0.25 ppm for wheat hay, and 0.20 ppm for wheat straw. Table I - 1. Residue data used to calculate tolerance for Triticonazole on Wheat Forage, Hay and Straw. Regulator: EPA EPA EPA Chemical: Triticonazole Triticonazole Triticonaz ole Crop: Wheat, forage (MLE) Wheat, hay (MLE) Wheat, straw (MLE) PHI: Not applicable Not applicable Not applicable App. Rate: 50 g ai/100 kg seed 50 g ai/100 kg seed 50 g ai/100 kg seed Submitter: BASF Crop Protection BASF Crop Protection BASF Crop Pr otection MRID Citation: MRID 47470203 MRID 47470203 MRID 47470203 Residues of Triticonazole (ppm) 1 0.070 0.070 0.030 0.050 0.070 0.040 0.005 0.002 0.020 0.006 0.010 0.020 0.010 0.004 0.004 0.010 0.005 0.005 0.100 0.060 0.050 0.090 0.060 0.060 0.050 0.080 0.030 0.070 0.080 0.040 0.020 0.006 0.006 0.020 0.006 0.007Triticonazole Summary of Analytical Chemistry and Residue Data DP#s: 360624; 325956, 353372

Page 34 of 37 Table I - 1. Residue data used to calculate tolerance for Triticonazole on Wheat Forage, Hay and Straw. Regulator: EPA EPA EPA Chemical: Triticonazole Triticonazole Triticonaz ole Crop: Wheat, forage (MLE) Wheat, hay (MLE) Wheat, straw (MLE) PHI: Not applicable Not applicable Not applicable App. Rate: 50 g ai/100 kg seed 50 g ai/100 kg seed 50 g ai/100 kg seed Submitter: BASF Crop Protection BASF Crop Protection BASF Crop Pr otection MRID Citation: MRID 47470203 MRID 47470203 MRID 47470203 Residues of Triticonazole (ppm) 1 0.009 0.007 0.010 0.009 0.010 0.020 0.030 0.010 0.020 0.030 0.020 0.020 0.020 0.020 0.030 0.020 0.020 0.020 0.020 0.009 0.008 0.020 0.009 0.009 0.020 0 .020 0.010 0.020 0.030 0.020 0.050 0.070 0.080 0.060 0.070 0.080 0.090 0.030 0.080 0.080 0.040 0.080 0.020 0.030 0.040 0.020 0.020 0.040 0.030 0.060 0.040 0.030 0.040 0.060 1 Bolded residues are MLE calculated values for residues reporte d as below the LOQ (<0.01 ppm).Triticonazole Summary of Analytical Chemistry and Residue Data DP#s: 360624; 325956, 353372

Page 35 of 37 Figure I - 1. Lognorm al probability plot of triticonazole field trial data for wheat forage . Lognormal Probability Plot

99.9 99 98 95 90 80 70 50 30 20 10 5 2 1 0.1 1.0000 0.5000 0.2500 0.1250 0.0625 0.0313 0.0156 0.0078 0.0039 y = 0.8382x - 3.6367 R 2 = 0.9514

PercentilesConcentrations EPA Triticonazole Wheat, Forage (MLE) Not applicable 50 g ai/100 kg seed BASF Crop Protection

Figure I - 2. Tolerance spreadsheet sum ma ry of triticonazole field trial data for wheat forage . Regulator: EPA Chemical: Triticonazole Crop: Wheat, Forage (MLE) PHI: Not applicable App. Rate: 50 g ai/100 kg seed Submitter: BASF Crop Protection

n: 30 min: 0.00 max: 0.10 median: 0.02 average: 0.04 95th Percentile 99th Percentile 99.9th Percentile 0.09 0.15 0.15 (0.10) (0.15) (--) 0.15 0.20 0.35 (0.20) (0.35) (--) 0.15 0.15 0.15 0.9514 p-value > 0.05 : Do not reject lognormality assumption Approximate Shapiro-Francia Normality Test EU Method I Normal

UCLMedian95th 95/99 Rule EU Method II Distribution-Free Mean+3SDTriticonazole Summary of Analytical Chemistry and Residue Data DP#s: 360624; 325956, 353372

Page 36 of 37 Figure I - 3. Lognorm al probabi lity plot of triticonazole field trial data for wheat hay . Lognormal Probability Plot

99.9 99 98 95 90 80 70 50 30 20 10 5 2 1 0.1 1.0000 0.5000 0.2500 0.1250 0.0625 0.0313 0.0156 0.0078 0.0039 0.0020 y = 1.0293x - 3.866 R 2 = 0.9405

PercentilesConcentrations EPA Triticonazole Wheat, Hay (MLE) Not applicable 50 g ai/100 kg seed BASF Crop Protection

Figure I - 4. Tolerance spreadsheet sum ma ry of triticonazole field trial data for wheat hay . Regulator: EPA Chemical: Triticonazole Crop: Wheat, Hay (MLE) PHI: Not applicable App. Rate: 50 g ai/100 kg seed Submitter: BASF Crop Protection

n: 30 min: 0.00 max: 0.08 median: 0.02 average: 0.03 95th Percentile 99th Percentile 99.9th Percentile 0.08 0.10 0.15 (0.10) (0.15) (--) 0.15 0.25 0.60 (0.25) (0.50) (--) 0.15 0.15 0.15 0.9405 p-value > 0.05 : Do not reject lognormality assumption Approximate Shapiro-Francia Normality Test EU Method I Normal

UCLMedian95th 95/99 Rule EU Method II Distribution-Free Mean+3SDTriticonazole Summary of Analytical Chemistry and Residue Data DP#s: 360624; 325956, 353372

Page 37 of 37 Figure I - 5. Lognorm al probability plot of triticonazole field trial data for wheat straw . Lognormal Probability Plot

99.9 99 98 95 90 80 70 50 30 20 10 5 2 1 0.1 1.0000 0.5000 0.2500 0.1250 0.0625 0.0313 0.0156 0.0078 0.0039 0.0020 y = 0.8931x - 3.752 R 2 = 0.9502

PercentilesConcentrations EPA Triticonazole Wheat, Straw (MLE) Not applicable 50 g ai/100 kg seed BASF Crop Protection

Figur e I - 6. Tolerance spreadsheet sum ma ry of triticonazole field trial data for wheat straw . Regulator: EPA Chemical: Triticonazole Crop: Wheat, Straw (MLE) PHI: Not applicable App. Rate: 50 g ai/100 kg seed Submitter: BASF Crop Protection

n: 30 min: 0.00 max: 0.08 median: 0.03 average: 0.03 95th Percentile 99th Percentile 99.9th Percentile 0.08 0.09 0.15 (0.09) (0.15) (--) 0.15 0.20 0.40 (0.20) (0.40) (--) 0.09 0.15 0.15 0.9502 p-value > 0.05 : Do not reject lognormality assumption Approximate Shapiro-Francia Normality Test EU Method I Normal

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