EPA REGISTRATION DIVISION COMPANY NOTICE OF FILING FOR PESTICIDE PETITIONS

Grass, Forage and Fodder CG17 Tolerance Petition, Ju ly 201 3

EPA Registration Division contact: Kathryn Montague , Herbicide Branch, Product Manager , Team 23, 703

- 305

- 1243

BASF Co rporation

3F8192

EPA has received a pesticide petition 3F8192 from BASF Corporation , 26 Davis Drive, P.O. Box 13528, Research Triangle Park, North Carolina 27709

- 3528 proposing, pursuant to section 408(d) of the Federal Food, Drug, and Cosmetic Act (FFD CA), 21 U.S.C. 346a(d), to amend 40 CFR part 180. 649 by amending tolerance s for residues of Saflufenacil in or on the raw agricultural plant commodities grass forage at 1 5 parts per million (ppm) , grass hay at 20 parts per million (ppm), grass seed screeni ngs at 0.9 parts per million (ppm), grass straw at 1.5 parts per million (ppm) , and livestock commodities animal fat at 0.05 parts per million (ppm), animal liver at 45 parts per million (ppm), and animal meat byproducts (except liver) at 0.5 parts per mil lions (ppm)

. Compliance with the plant commodity tolerances levels is to be determined by measuring only the sum of Saflufenacil, 2

- chloro

- 5

- [3,6

- dihydro

- 3

- methyl

- 2,6

- dioxo

- 4

- (trifluoromethyl)

- 1(2 H )

- pyrimidinyl]

- 4

- fluoro

- N

- [[methyl(1

- methylethyl)amino]sulf onyl]benzamide, and its metabolites N

- [2

- chloro

- 5

- (2,6

- dioxo

- 4

- (trifluoromethyl)

- 3,6

- dihydro

- 1(2 H )

- pyrimidinyl)

- 4

- fluorobenzoyl]

- N '

- isopropylsulfamide and N

- [4

- chloro

- 2

- fluoro

- 5

- ({[(isopropylamino)sulfonyl]amino} carbonyl)phenyl]urea, calculated as the sto ichiometric equivalent of Saflufenacil , while c ompliance with the animal commodity tolerances levels is to be determined by measuring only Saflufenacil, 2

- chloro

- 5

- [3,6

- dihydro

3

- methyl

- 2,6

- dioxo

- 4

- (trifluoromethyl)

- 1(2 H )

- pyrimidinyl]

- 4

- fluoro

- N

- [[methyl(1

- methylethyl)amino]sulfonyl]benzamide , in or on the commodit ies. EPA has determined that the petition contains data or information regarding the elements set forth in section 408 (d)(2) of FDDCA; however, EPA has not fully evaluated the sufficiency of the submitted data at this time or whether the data supports granting of the petition. Additional data may be needed before EPA rules on the petition.2

A. Residue Chemistry

1. Plant metabolism

. Previously submitted metabolism data for corn, soybean, and toma to and a confined rotational crop study are adequate to elucidate the nature of the residue in plants resulting from preplant/preemergence application , a postemergence
directed at the base of plants underneath the leaf canopy application , and a pre

harvest /desiccant application

. An additional nature of residue study was also previously submitted with a postemergence application in rice as a representative monocot (grass) species. The metabolism of Saflufenacil in plants following a postemergence application is similar to the metabolism of Saflufenacil in plants following a preplant/preemergence application. Therefore, the residues of concern for the tolerance expression and risk assessment consist of Saflufenacil, M800H11, and M800H35.

2. Analytical metho d. Adequate enforcement methodology (liquid chromatography/mass spectrometry/mass spectrometry (LCMS/MS) methods for plant and livestock commodities are available to enforce the tolerance expression

.

3. Magnitude of residues. Field trials in the US were carried out to determine the magnitude of the residue following sequential postemergence application s of Saflufenacil made in grass grown for forage, hay and seed production . Field trials were carried out using the maximum label rate, the maximum number of applications, and the minimum pre

- harvest interval (PHI) for use in forage grasses . Detected combined residues of Saflufenacil plus metabolites in the crop commodities support the proposed tolerances. A dairy cattle feeding study was conducted to determin e if any secondary transfer of Saflufenacil residues occur from treated feedstuffs to bovine matrices.

B. Toxicological Profile

1. Acute toxicity. Saflufenacil has low acute toxicity via the oral, dermal, and inhalation routes of exposure. It is slight ly irritating to the eye but is neither a dermal irritant nor sensitizer

.

2. Genotoxicty. Saflufenacil is weakly clastogenic in the in vitro chromosomal aberration assay in V79 cells in the presence of S9 activation; however, the response was not3

evident in the absence of S9 activation. It is neither mutagenic in bacterial cells nor clastogenic in rodents in vivo

.

3. Reproductive and developmental toxicity. Increased fetal and offspring susceptibility to S aflufenacil were observed in the developmental t oxicity studies in the rat and rabbit and in the 2
– generation reproduction study in the rat. Developmental effects such as decreased fetal body weights and increased skeletal variations occurred at doses that were not maternally toxic in the developmental study in rats, indicating increased quantitative susceptibility. In rabbits, developmental effects such as increased liver porphyrins were observed at doses that were not maternally toxic, indicating increased quantitative susceptibility. In the 2

– generati on reproduction study in rats, offspring effects such as increased number of stillborn pups, decreased viability and lactation indices, decreased pre

- weaning body weight and/or body

- weight gain, and changes in hematological parameters were observed at a do se resulting in less severe maternal toxicity (decreased food intake, body weight/weight gain and changes in hematological parameters and organ weights indicative of anemia), indicating increased qualitative susceptibility.

4. Subchronic toxicity. Short

- term, subchronic, and chronic toxicity studies in rats, mice, and dogs identified the hematopoietic system as the target organ of saflufenacil. Protoporphyrinogen oxidase inhibition in the mammalian species may result in disruption of heme synthesis which in turn causes anemia. In these studies, decreased hematological parameters (red blood cells (RBC), hematocrit (Ht), mean corpuscular volume (MCV), mean corpuscular hemoglobin (MCH), and mean corpuscular hemoglobin concentration (MCHC)) were seen at about the same dose level across species, except in the case of the dog, where the effects were seen at a slightly higher dose. These effects occurred around the same dose level from the short

- term through long

- term exposures without increasing in severity. Effe cts were also seen in the liver (increased weight, centrilobular fatty change, and lymphoid infiltrate) in mice, the spleen (increased spleen weight and extramedullary hematopoiesis) in rats, and in both these organs (increased iron storage in the liver an d extramedullary hematopoiesis in the spleen) in dogs. These effects also occurred around the same dose level from the short

- term through long

- term exposures without increasing in severity. No dermal toxicity was seen at the limit dose in a 28

– day dermal t oxicity study in rats.
There was no evidence of neurotoxicity or neuropathology in the toxicity database fo r S aflufenacil. In the acute neurotoxicity study, a decrease in motor activity was observed on the first day of dosing at the limit dose in males onl y. The finding was not accompanied by any other neuropathological changes and was considered a reflection of a mild and transient general systemic toxicity and not a substance

- specific neurotoxic effect. In the subchronic neurotoxicity study, systemic toxi city (anemia), but no evidence of neurotoxicity, was seen in males and females.4

There was no evidence of immunotoxity in the toxicity database for Saflufenacil. In the immunotoxicity study conducted in male mice, systemic toxicity (signs of anemia and liv er effects) w as seen, but the effects were not indicative of immunotoxicity. There were no effects on sheep red blood cell (SRBC) IgM antibody titers or immune system organ weights (spleen and thymus) in the treated mice. In the 90

- day oral toxicity study in rats, t he increase in spleen weight seen only in rats is attributable to an increased clearance of defective RBCs (i.e., defective hemoglobin synthesis) and is thus an indication of toxicity to the hematopoietic system rather than to the immune system

.

5. Chronic toxicity. Carcinogenicity studies in rats and mice showed no evidence of increased incidence of tumors at the tested doses. Saflufenacil is classified as not likely to be carcinogenic to humans.

6. Animal metabolism. Rat metabolism data indi cate that Saflufenacil is well absorbed and rapidly excreted. The maximum concentration of Saflufenacil in blood and plasma was reached within 1 hour (h) of dosing and declined rapidly after 24 h. Excretion of orally dosed Saflufenacil was essentially co mplete within 96 h, with the majority eliminated within the first 24 to 48 h. There was a sex

- dependent difference in the excretion of orally administered Saflufenacil. The main route of elimination in male rats was via the feces, while urinary excretion was the major route of elimination in females. The sex

- dependent excretion was more pronounced at the low

- dose level than at the high

- dose level. Also, males had significantly higher biliary excretion of Saflufenacil residues than females. Exhalation w as not a relevant excretion pathway of Saflufenacil. At 168 h after dosing, Saflufenacil residues remaining in tissues were very low and occurred mainly in carcass, liver, skin, and gut contents.
The parent molecule and 3 major metabolites were identified and isolated from urine and feces. There were no significant gender differences in metabolic profiles. Saflufenacil was metabolized by three major transformation steps, which were demethylation of the uracil ring system, degradation of the N

- methyl

- N

- iso propyl group to NH 2 , and cleavage of the uracil ring, forming a sulfonylamide group. The metabolism of Saflufenacil in the animals is well understood.

7. Metabolite toxicology

. No metabolites of toxicological concern are identified.

8. Endocrine disrup tion

. No specific tests have been conducted with S aflufenacil to determine whether the chemical may have an effect in humans that is similar to an effect5

produced by a naturally occurring estrogen or other endocrine effects. However, there were no signifi cant findings in other relevant toxicity studies (e.g., sub

- chronic and chronic toxicity, developmental toxicity and multi

- generation reproductive studies) which would suggest that S aflufenacil produces any endocrine disruption.

C. Aggregate Exposure

1. Die tary exposure. Exposure assessments were conducted to evaluate the potential risk due to acute and chronic dietary exposure of the U.S. population to combined residues of S aflufenacil and metabolites M800H11 and M800H35. The current established tolerance v alues are listed in the U.S. 40 CFR § 180.649. Th is analysis include s all the crops with established tolerances ; the proposed import tolerances for sugarcane, cane at 0.03 ppm, sugarcane, molasses at 0.075 ppm, and sugarcane, refined sugar at 0.045 ppm (p ending EPA review, submitted July 2012) ; the proposed amended tolerance on rice commodities (pending EPA review, submitted December 2012) ; the propos ed amended tolerances on barley and wheat (pending EPA review, submitted June 2013); and the newly proposed new tolerances on forage grass commodities and newly proposed amended tolerances in animal commodities

.
i. Food. Acute Dietary Exposure Assessment
Acute dietary exposure estimates were conducted using the curren tly established tolerances for S aflufenaci l (40 CFR 180.649) ; the proposed import tolerances for sugarcane, cane at 0.03 ppm, sugarcane, molasses at 0.075 ppm, and sugarcane, refined sugar at 0.045 ppm (pending EPA review, submitted July 2012) ; the proposed amended tolerance on rice commodities (p ending EPA review, submitted December 2012) ; and the proposed amended tolerances on barley and wheat commodities (pending EPA review, submitted June 2013); and the newly proposed new tolerances on forage grass commodities and newly proposed amended toleran ces in animal commodities

. The assessment was conducted using tolerance values, default process factors, and 100% crop treatment factors. The consumption data was from the USDA Continuing Survey of Food Intake by Individuals (CSFII 1994

- 1996, 1998) and the EPA Food Commodity Ingredient Database (FCID) using Exponent's Dietary Exposure Evaluation Module (DEEM

- FCID) software.

The result ing exposure estimates were compared against the S aflufen a cil acute Population Adjusted Dose (aPAD) of 5 mg/kg b.w./day for all populations. This endpoint is based on the NOAEL of 5 00 mg/kg/day with the standard inter

- and intra

- species uncertainty factors of 100X and an FQPA safety factor of 1. The expos ure for all sub

- population was less than 1.0 % utilization of the aP AD. The results of the acute dietary assessment are presented in Table 1.6

Table 1. Results for S aflufenacil Acute Dietary Exposure Analysis Considering all Proposed Tolerances using DEEM

- FCID at the 95 th Percentile , food only

Population Exposure Estimate %aPAD
Subgroups (mg/kg b.w./day)

U.S. Population 0.004245 0.08
All Infants (< 1 year old) 0.005366 0.11
Children (1

- 2 years old) 0.008178 0.16
Children (3

- 5 years old) 0.00715 0.14
Children (6

- 12 years old) 0.005251 0.11
Youth (13

- 19 years old) 0 .003346 0.07
Adults (20

- 49 years old) 0.003179 0.06
Adults (50+ years old) 0.002275 0.05
Females (13

– 49 years old) 0.002658 0.05

The results of the analysis show that for all populations, the estimated exposures are well below the Agency's level of concern (< 100% aPAD). Additional refinements in the dietary risk assessment (i.e. utilizing anticipated residue values, percent crop treated values) would further reduce the estimated exposure values.
Chronic Dietary Exposure Assessment
Chronic dietary e xposure estimates were conducted using the currently established tolerances for Saflufenacil (40 CFR 180.649) ; the proposed import tolerances for sugarcane, cane at 0.03 ppm, sugarcane, molasses at 0.075 ppm, and sugarcane, refined sugar at 0.045 ppm (pend ing EPA review, submitted July 2012) ; the proposed amended tolerance on rice commodities (pending EPA review, submitted December 2012) ; and the proposed amended tolerances on barley and wheat commodities (pending EPA review, submitted June 2013); and the n ewly proposed new tolerances on forage grass commodities and newly proposed amended tolerances in animal commodities. The assessment was conducted using tolerance values, default process factors, and 100% crop treatment factors. The consumption data was f rom the USDA Continuing Survey of Food Intake by Individuals (CSFII 1994

- 1996, 1998) and the EPA Food Commodity Ingredient Database (FCID) using Exponent's Dietary Exposure Evaluation Module (DEEM

- FCID) software.7

The chronic Population Adjusted Dose (c PAD) used for U.S. population and all sub

- populations is 0.046 mg/kg bw/day. This endpoint is based on the NOAEL value of 4.6 using the standard inter

- and intra

- species uncertainty factors of 100X and with a FQPA safety factor of 1. The most highly expos ed population sub

- group was children 1

- 2 years of age which utilized 9.7 % cPAD. The results of the chronic dietary assessment are presented in Table 2.

Table 2. Results for S aflufenacil Chronic Dietary Exposure Analysis Considering all Proposed Toleranc es using DEEM

- FCID , food only

Population Exposure Estimate %cPAD
Subgroups (mg/kg b.w./day)

U.S. Population 0.001592 3.5
All Infants (< 1 year old) 0.002049 4.5
Children (1

- 2 years old) 0.004472 9.7
Children (3

- 5 years old) 0.003711 8.1

Children (6

- 12 years old) 0.002515 5.5
Youth (13

- 19 years old) 0.001471 3.2
Adults (20

- 49 years old) 0.00134 2.9
Adults (50+ years old) 0.001113 2.4
Females (13

- 49 years old) 0.001167 2.5

The results of the analysis show that for all populations, the exposure s are far below a level of concern (< 100% cPAD). Additional refinements in the chronic dietary risk assessment (i.e. utilizing anticipated residue values and percent crop treated values) would further reduce the estimated exposure values.

ii. Drinking water

. All S aflufenacil uses were examined at maximum use rates, maximum number of applications, and all proposed application methods to determine which use would result in the highest water concentrations. Based on results from the PRZM

- GC and PRZM /EXAMS models estimates, the highest acute Estimated Drinking Water Concentrations (EDWC ’s ) for S aflufenacil were estimated to be 111 ug/L (ppb) from ground water and th e8

highest chronic EDWC’s for S aflufenacil were estimated to be 73 ug/L (ppb) from ground wate r . Drinking water exposure contributions were assessed based on the maximum estimated S aflufenacil water concentrations, and water consumption and body weights reported in CSFII, using DEEM

- FCID software. The acute and chronic estimated water exposure v alues are summarized in Tables 3 and 4, respectively. Drinking water exposure accounts for less than 1 % of the aPAD and up to 8.6 % of the cPAD for all populations.

Table 3. Results for S aflufenacil Acute Water Exposure Analysis Considering the Maximum Estimated Acute Drinking Water Concentration using DEEM

- FCID

Population Water Exposure Estimate % aPAD
Subgroups (mg/kg b.w./day)

U.S. Population 0.006053 0.12
All Infants (< 1 year old) 0.018957 0.38
Children (1

- 2 years old) 0.009333 0.19

Children (3

- 5 years old) 0.007573 0.15
Children (6

- 12 years old) 0.005786 0.12
Youth (13

- 19 years old) 0.005041 0.10
Adults (20

- 49 years old) 0.005956 0.12
Adults (50+ years old) 0.005306 0.11
Females (13

- 49 years old) 0.006041 0.12

Table 4. Results for S af lufenacil Chronic Water Exposure Analysis Considering the Maximum Estimated Chronic Drinking Water Concentration using DEEM

- FCID

Population Water Exposure Estimate %cPAD
Subgroups (mg/kg b.w./day)9

U.S. Population 0.001529 3.3
All Infants (< 1 year ol d) 0.003941 8.6
Children (1

- 2 years old) 0.002205 4.8
Children (3

- 5 years old) 0.001858 4.0
Children (6

- 12 years old) 0.001340 2.9
Youth (13

- 19 years old) 0.001115 2.4
Adults (20

- 49 years old) 0.001525 3.3
Adults (50+ years old) 0.001508 3.3

Females (13

- 49 years old) 0.001519 3.3

Acute Aggregate Exposure and Risk (food and water)
The aggregate acute risk includes exposure of Saflufenacil from food and water (Table 5). The result s demonstrate that the use of S aflufenacil does not result in an unacce ptable acute risk.

Table 5. Estimated Acute Aggregate Exposure and Risk of S aflufenacil

. Population Subgroup Food Exposure (mg/kg/day) Water

Exposure (mg/kg/day) Total Exposure

(mg/kg/day) % aPAD

U.S. Population 0.004245 0.006053 0.01030 0.21

All Inf ants (< 1 yr old) 0.005366 0.018957 0.02432 0.49

Children 1

- 2 years 0.008178 0.009333 0.01751 0.35

Children 3

- 5 years 0.00715 0.007573 0.01472 0.29

Children 6

– 12 years 0.005251 0.005786 0.01104 0.22

Youth 13

- 19 years 0.003346 0.005041 0.00839 0.17

A dults 20

- 49 years 0.003179 0.005956 0.00914 0.18

Adults + 50 0.002275 0.005306 0.00758 0.1510

Females 13

- 49 years 0.002658 0.006041 0.00870 0.17
aPAD = 5 mg/kg bw/day

Short

- and Intermediate

- Term Aggregate Exposure and Risk (food, water, and residential)

Short

- and intermediate

- term aggregate risk assessments include exposure from food, water, and residential uses. There are no residential uses for S aflufenacil therefore a short

- and intermediate

- term aggregate risk assessment is not required.
Chronic Ag gregate Exposure and Risk (food and water)
The aggregate chronic risk includes exposure of S aflufenacil from food and water (Table 6)

. The result s demonstrate that the use of S aflufenacil does not result in an unacceptable chronic risk.

Table 6. Estimated Chronic Aggregate Exposure and Risk of S aflufenacil
Population Subgroup Food Exposure (mg/kg/day) Water Exposure

(mg/kg/day) Total

Exposure (mg/kg/day) % cPAD

U.S. Population 0.001592 0.001529 0.00312 6.8
All Infants (< 1 yr old) 0.002049 0.003941 0.00 599 13.0

Children 1

- 2 years 0.004472 0.002205 0.00668 14.5

Children 3

- 5 years 0.003711 0.001858 0.00557 12.1

Children 6

– 12 years 0.002515 0.001340 0.00386 8.4

Youth 13

- 19 years 0.001471 0.001115 0.00259 5.6

Adults 20

- 49 years 0.00134 0.001525 0.0028 7 6.2

Adults + 50 0.001113 0.001508 0.00262 5.7

Females 13

- 49 years 0.001167 0.001519 0.00269 5.8
cPAD = 0.046 mg/kg bw/day.

2. Non

- dietary exposure

. The term ‘‘residential exposure’’ is used to refer to non

occupational, non

- dietary exposure (e.g., for lawn and garden pest control, indoor pest control, termiticides, and flea and tick control on pets). Saflufenacil is not registered for any11

specific use patterns that would result in residential exposure. Therefore, a non

- dietary exposure and risk eva luation was not conducted.

D. Cumulative Effects
"Section 408(b)(2)(D)(v) requires that, when considering whether to establish, modify, or revoke a tolerance, the Agency consider “available information'' concerning the cumulative effects of a particular pesticide's residues and “other substances that have a common mechanism of toxicity." EPA has not found S aflufenacil to share a common mechanism of toxicity with any other substances, and S aflufenacil does not appear to produce a toxic metabolite produced by other substances. For the purposes of this tolerance petition , therefore, EPA will assume that S aflufenacil does not have a common mechanism of toxicity with other substances.

E. Safety Determination

1. U.S. population. Based on the current risk asses sments, BASF conclude s that the acute aggregate and the chronic aggregate exposure from the use of S aflufenacil does not result in an unacceptable risk.

2. Infants and children

. Based on the current risk assessments, BASF conclude s that the acute aggrega te exposure and the chronic aggregat e exposure from the use of S aflufenacil does not result in an unacceptable risk.

F. International Tolerances

N ational maximum residue limits ( MRLs ) for Saflufenacil are available in a number of countries as referenced b elow.

Codex CXLs for Saflufenacil are available for numerous plant and animal commodities (website reference: http://www.codexalimentarius.net/pestres/data/pesticides/details.html?id=251 );
Canadian MRLs for Saflufenacil (including its metabolites) are es tablished and harmonized with US Tolerances for various crops and livestock commodities (website reference: http://pr

rp.hc

- sc.gc.ca/mrl

- lrm/results

- eng.php )
Japanese MRLs for Saflufenacil are established for numerous plant and animal commodities (website reference: http://www.m5.ws001.squarestart.ne.jp/foundation/agrdtl.php?a_inq=24250 )12

S outh Korean MRLs for Saflufenacil are established for numerous plant commodities (website reference: http://fse.foodnara.go.kr/residue/pesticides/pesticides_mrl_korea_vie w.jsp?pesticideCode=P 01627 )
Australian MRLs for Saflufenacil are established for numerous plant and animal commodities (website reference: http://www.apvma.gov.au/residues/docs/mrl_table1_december_2012.pdf )

B razilian MRLs for Saflufenacil are established for a few plant commodities (website reference: http://portal.anvisa.gov.br/wps/wcm/connect/db5a2c804b9a7f57afa2bfaf8fded4db/S16+

- +Saflufenacil.pdf?MOD=AJPERES )
An application for Saflufenacil MRLs in the European Union to support imported produce is

cur rently under review by EU Commission and EFSA