EPA Registration Division contact: Andrew Ertman; 703-308-9367 

Interregional Research Project No. 4

PP No. 2E7979 

 EPA has received a pesticide petition (2E7979) from Interregional Research 

Project No. 4, Rutgers, The State University of New Jersey, 500 College Road East, Suite 

201W, Princeton, NJ 08540 requesting, pursuant to section 408(d) of the Federal Food, 

Drug, and Cosmetic Act (FFDCA), 21 U.S.C. 346a(d), to amend 40 CFR part 180 by 

establishing a tolerance for residues of glyphosate N-(phosphonomethyl) glycine in or on 

the raw agricultural commodity Vegetable, root and tuber, Group 1, except sugar beet at 

6.0 parts per million (ppm),teff, forage and teff, hay at 100 ppm, and Oilseed Crops, 

Group 20 at 40 ppm, and convert Borage, seed, Crambe, seed, Jojoba, seed, Lesquerella, 

seed, Meadowfoam, seed, Mustard, seed and Sesame, seed all at 0.1 ppm; Flax, seed at 

4.0 ppm; Flax, meal at 8.0 ppm; Canola, seed and Rapeseed, seed at 20 ppm; Cotton, 

undelinted seed at 40 ppm and Safflower, seed and Sunflower, seed at 85 ppm to Oilseed, 

group 20 at 40 ppm. Also convert Vegetable, bulb, group 3 at 0.2 ppm to Vegetable, 

bulb, group 3-07 at 0.2 ppm. Convert Okra at 0.5 ppm and Vegetable, fruiting, group 8 at 

0.1 ppm to Vegetable, fruiting, group 8-10 at 0.1 ppm. Convert Fruit, citrus, group 10 at 

0.5 ppm to Fruit, citrus, group 10-10 at 0.5 ppm. Convert Fruit, pome, group 11 at 0.2 

ppm to Fruit, pome, group 11-10 at 0.2 ppm. Convert Cranberry, Grape, Juneberry, 

Kiwifruit, Lingonberry, Salal, Strawberry and Berry group 13 at 0.2 ppm to Berry and 

small fruit, group 13-07 at 0.2 ppm. 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. 

A. Residue Chemistry

 1. Plant metabolism. The qualitative nature of glyphosate residues in plants and 

livestock is adequately understood. The terminal residue to be regulated in nontransgenic 

plants and transgenic crops modified to express the Agrobacterium sp. EPSPS and 

oxireductase genes is glyphosate per se. For certain crops (currently only soybeans and 

corn) that have a transgenic variety engineered to express the microbial glyphosate 

acetyltransferase gene (gat4601), the combined residues to be regulated are glyphosate 

and N-acetyl-glyphosate. The crops being considered here do not currently have an 

acetyltransferase gene inserted. The qualitative nature of the glyphosate residue will not 

be changed as a result of the proposed tolerance changes. Glyphosate herbicides are not 

applied directly to livestock, so the only potential exposure is via glyphosate residues in 

their diet. On December 3, 2008, EPA published a final rule (EPA-HQ-OPP-2007-0147; 

FRL-8385-7) amending section 180.364 to reflect that the terminal residue to be 

regulated in livestock (and in soybean commodities and grain aspirated fractions) is 

glyphosate and its metabolite N -acetyl-glyphosate, expressed as glyphosate.

 2. Analytical method. Adequate enforcement methods are available for analysis of 
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residues of glyphosate and its metabolite, AMPA, in or on plant and livestock 

commodities. These methods include: Gas-Liquid Chromatography (GLC)—Method I in 

Pesticides Analytical Manual (PAM) II, 0.05 ppm limit of detection; High Performance 

Liquid Chromatography (HPLC) with fluorometric detection, 0.0005 ppm LOD (limit of 

detection); and gas chromatography/mass spectrometry (GC/MS) method for glyphosate 

in crops has also been validated by EPA’s Analytical Chemistry Laboratory (ACL). 

Thus, adequate analytical methods are available for residue data collection and 

enforcement of the proposed tolerances for glyphosate.

 3. Magnitude of residues. Data on the magnitude of glyphosate residue in carrot 

and sweet potato are being submitted along with the Petition to support the proposed 

amendment of the tolerance for root and tuber vegetables, Crop Group 1. No new residue 

data were generated to support the establishment of the proposed tolerance for teff forage 

and hay, or for establishment of a group tolerance for oilseed crops, Crop Group 20. 

However, data from two additional glyphosate residue studies conducted outside the U.S. 

on oilseed rape are being submitted along with this petition to further support the increase 

in the oilseed crop group tolerance. Any secondary glyphosate residues occurring in 

livestock commodities will be covered by existing tolerances.

B. Toxicological Profile

 EPA has evaluated the available toxicity data and considered its validity, 

completeness, and reliability as well as the relationship of the results of the studies to 

human risk. The toxicity database is complete with the exception of recently-required 

studies on acute and subchronic neuorotoxicity and immunotoxicity. There is no 

evidence of neurotoxicity in any of the toxicology studies. Accordingly, although an 

acute and subchronic neurotoxicity studies are now required as part of new data 

requirements, EPA does not believe that conducting these studies will result in a lower 

POD than that currently used for overall risk assessment, and therefore, a database 

uncertainty factor is not needed to account for lack of these studies EPA has also 

considered available information concerning the variability of the sensitivities of major 

identifiable subgroups of consumers, including infants and children.

 1. Acute toxicity. Glyphosate is of low acute toxicity following oral, dermal, and 

inhalation exposure. It is a mild eye irritant, slight skin irritant, and is not a dermal 

sensitizer in guinea pigs. Inhalation risk assessments are not required based on the low 

toxicity of the formulation products (toxicity category III or IV) and the physical 

characteristics of the technical product. An acute dose and endpoint for assessing acute 

risk have not been selected for any population subgroups because no effect that could be 

attributed to a single exposure (dose) was observed in oral toxicity studies including the 

developmental toxicity studies in rats and rabbits. 

Table 1 Acute Toxicity Profile - Test Substance 

Guideline 

No. Study Type MRID(s) Results Toxicity Category
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Table 1 Acute Toxicity Profile - Test Substance 

870.1100 Acute oral 41400601 LD50 > 5,000 mg/kg IV 

870.1200 Acute dermal 41400602 LD50 > 5,000 mg/kg IV 

870.1300 Acute inhalation None 

The requirement for an 

acute inhalation LC50

study was waived 

None 

870.2400 Acute eye irritation 41400603 

Corneal opacity or 

irritation clearing in 7 

days or less 

III 

870.2500 Acute dermal irritation 41400604 Mild or slight irritant IV 

870.2600 Skin sensitization 00137138 Not a sensitizer None 

 2. Genotoxicty. In vitro and in vivo genotoxicity studies have been conducted with 

glyphosate. Short term assays for genotoxicity consisting of a bacterial reverse mutation 

assay (Ames test), an in vitro assay for cytogenetic damage using Chinese hamster ovary 

cells, and in vivo cytogenic assay in rat bone marrow have been conducted on glyphosate. 

These studies all show a lack of genotoxicity. 

Table 2 Genotoxicity Profile 

Guideline No./ Study 

Type Results

Gene Mutation 

870.5265 

Non-mutagenic when tested up to 1000 ug/plate, in presence and 

absence of activation in S. typhimurium strains TA98, TA100, 

TA1535 and TA1537. 

Gene Mutation 

870.5300 

Non-mutagenic at the HGPRT locus in Chinese hamster ovary cells 

tested up to cytotoxic concentrations or limit of solubility, in 

presence and absence of activation. 

In Vivo Cytogenetics - 

Bone Marrow 870.5385 

Non-mutagenic in rat bone marrow chromosome assay up to 1000 

mg/kg in both sexes of Sprague Dawley rats. 

870.5550 

 Rec - Assay and Gene 

Mutation Assay 

There was no evidence of recombination in the rec-assay up to 

2,000 ug/disk with B. subtilis H17 (rec+) and M45 (rec-). Negative 

for reverse gene mutation, both with and without S-9, up to 5,000 

ug/plate (or cytotoxicity) with E.coli SP2hcrA and S. typhimuarium

TA98, TA100, TA1535, TA1537, and TA1538. 

 3. Reproductive and developmental toxicity. Acceptable developmental toxicity 

studies in the rat and rabbit are available, as is an acceptable 2-generation reproduction study 
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in the rat. No significant reproductive and developmental toxic effects were found. A focal 

tubular dilation of the kidneys was observed in a 3-generation reproductive study on rats at 

the 30-mg/ kg/day high dose treatment level (HDTL); however, a 2-generational reproductive 

study on rats did not observe the same effect at the 1,500-mg/ kg/day HDTL, nor were any 

adverse reproductive effects observed at any dose level. EPA concluded that the focal 

tubular dilation of the kidneys at the 30-mg/kg/day level was a spurious rather than a 

glyphosate-related effect. 

In a prenatal developmental toxicity study in rats, maternal (systemic) effects observed 

included mortality, increased clinical signs, and reduced body-weight gain at the HDTL 

(3,500-mg/kg/day). Developmental (fetal) effects were observed only in the high-dose group 

and included decreases in total implantations/dam and nonviable fetuses/dam, increased 

number of litters and fetuses with unossified sternebrae, and decreased mean fetal body 

weights. In a prenatal developmental toxicity study in rabbits, maternal (systemic) effects 

observed included mortality and clinical signs of toxicity at the HDTL (350-mg/kg/day). In 

the rabbit, developmental toxicity was not observed at any dose. On the basis of 

developmental studies in rats and rabbits and reproductive findings in rats, glyphosate 

exhibited no evidence of increased susceptibility of offspring. 

A developmental neurotoxicity study was not required.

Table 3 Reproductive and Developmental Toxicity Profile

Guideline No./ Study 

Type Results

870.3700a 

Prenatal developmental 

in rodents (Rat) 

Maternal NOAEL = 1000 mg/kg/day 

LOAEL = 3500 mg/kg/day based on reduced activity, mortality, 

and reduced body weight gain. 

Developmental NOAEL = 1000 mg/kg/day 

LOAEL = 3500 mg/kg/day based on increased incidence in the 

number of fetuses and litters with unossified sternebrae and 

decreased fetal body weight. 

870.3700b 

Prenatal developmental 

in (Rabbit) 

Maternal NOAEL = 175 mg/kg/day 

LOAEL = 350 mg/kg/day (HDT) based on mortality, diarrhea, soft 

stools, and nasal discharge. 

Developmental NOAEL = 350 mg/kg/day (HDT) 

LOAEL = not established. 

870.3800 

Reproduction and 

fertility effects, 

2-generation (Rat) 

Parental/Systemic NOAEL = 500 mg/kg/day in males and females 

LOAEL = 1500 mg/kg/day (HDT) in males and females based on 

soft stools, decreased body weight gain and food consumption. 

Reproductive NOAEL  1500 mg/kg/day (HDT) in males and 

females 

Offspring NOAEL = 500 mg/kg/day (HDT) in males and females 

LOAEL = 1500 mg/kg/day in males and females based on 

decreased body weight gain during lactation. 
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 4. Subchronic toxicity. In rodent feeding studies, glyphosate showed a NOAEL of 

500 mg/kg/day in a 90-day mouse study and 1445 mg/kg/day (HDT) in a 90-day rat 

study. In a 21/28-day rabbit dermal toxicity study the NOAEL was 1000 mg/kg/day and 

the LOAEL was 5000 mg/kg/day based on slight erythema and edema on intact and 

abraded skin of both sexes. 

Table 4 Subchronic Toxicity Profile

Guideline No./ Study 

Type Results

870.3100 

90-Day oral toxicity 

(Mouse) 

NOAEL = 500 mg/kg/day in males and females 

LOAEL = 2500 mg/kg/day (HDT) in males and females based on 

decreased body weight gains. 

870.3100 

90-Day oral toxicity 

(Rat) 

NOAEL = 1445 mg/kg/day (HDT) 

LOAEL = not established 

870.3200 

21/28-Day dermal 

toxicity (Rabbit) 

NOAEL(local irriation) = 1000 mg/kg/day in males and females 

LOAEL (local irriation) = 5000 mg/kg/day based on slight 

erythema and edema on intact and abraded skin of both sexes. 

NOAEL (systemic) = 5000 mg/kg/day (HDT) 

 5. Chronic toxicity. A chronic feeding/carcinogenicity study in rats found no 

systemic effects in any of the parameters examined (body weight, food consumption, 

clinical signs, mortality, clinical pathology, organ weights, and histopathology). In a 

second chronic feeding/carcinogenicity study in rats tested at higher dietary levels, a 

lowest observed-adverse-effect level (LOAEL) was identified at 940-

milligrams/kilograms/day (mg/kg/day) & 1,183-mg/kg/day (male/female) based on 

decreased body-weight gains in females and increased incidence of cataracts and lens 

abnormalities, decreased urinary pH, increased absolute liver weight, and increased 

relative liver weight/brain weight in males. No evidence of carcinogenicity was found in 

rats or mice. In a chronic toxicity study in dogs, no systemic effects were found. 

Glyphosate has been classified as “a Group E” carcinogen—no evidence of 

carcinogenicity to humans—based on the absence of carcinogenicity in mice and rats. 

Table 5 Chronic Toxicity Profile

Guideline No./ Study 

Type Results

870.4100b 

Chronic toxicity (dog) 

NOAEL = > 500 mg/kg/day in males and females (HDT) 

LOAEL = not established. 
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Table 5 Chronic Toxicity Profile

Guideline No./ Study 

Type Results

870.4300 

Carcinogenicity 

(Mice) 

NOAEL = 750 mg/kg/day in males and females 

LOAEL = 4500 mg/kg/day in males and females based on 

significant decreased body weight gain in both sexes and 

hepatocyte necrosis in females. 

No evidence of carcinogenicity

870.4300 

Chronic/Carcinogenicity (Rat) 

NOAEL = 362 mg/kg/day in males, 447 mg/kg/day in females 

LOAEL = 940 mg/kg/day in males, 1183 mg/kg/day in females 

based on decreased body weight gain in females, increased 

incidence of cataracts and lens abnormalities in males. 

No evidence of carcinogenicity

 6. Animal metabolism. In the rat metabolism study, absorption was estimated to 

be 30-36% in males and females. Glyphosate was excreted unchanged in the feces and 

urine (97.5% minimum). The only metabolite present in the excreta was small amounts 

of AMPA. Less than 1% of the absorbed dose remained in the carcass, primarily the 

bone. Repeated dosing did not alter metabolism, distribution, and excretion.

 7. Metabolite toxicology. The residue of concern for risk assessment purposes for 

crops that do not contain a glyphosate acetyltransferase gene, and which the crops being 

considered in this Petition do not, is glyphosate per se. The metabolite AMPA is not 

included in either the tolerance expression or the risk assessment. In a meeting of the 

HED Metabolism Committee held 8/19/92, the Committee determined that, based on 

toxicological considerations, AMPA need not be regulated and should be dropped from 

the tolerance expression (Memo, R. Perfetti, 10/10/92). Furthermore, in a meeting of the 

HED Metabolism Committee held 3/17/94, the Committee discussed whether uses that 

result in significantly higher residues of AMPA in plants and livestock commodities in 

the future would require that AMPA be reintroduced into the tolerance expression of 

glyphosate. The Committee determined that, based on toxicological considerations, 

AMPA need not be regulated regardless of levels observed in foods or feeds (Memo, R. 

Perfetti, 3/17/94).

 8. Endocrine disruption. EPA is required under the FFDCA, as amended by FQPA, 

to develop a screening program to determine whether certain substances (including all 

pesticide active and other ingredients) “may have an effect in humans that is similar to an 

effect produced by a naturally occurring estrogen, or other such endocrine effects as the 

Administrator may designate.” Following recommendations of its Endocrine Disruptor and 

Testing Advisory Committee (EDSTAC), EPA determined that there was a scientific basis 

for including, as part of the program, the androgen and thyroid hormone systems, in addition 

to the estrogen hormone system. EPA also adopted EDSTAC’s recommendation that the 

Program also include evaluations of potential effects in wildlife. 
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Glyphosate is on the EPA list of the initial 67 pesticide active ingredients and pesticide inert 

high production volume chemicals to be screened under the first phase of EPA’s Endocrine 

Disruption Screening Program (EDSP). This is not a list of “endocrine disruptors” or 

“potential endocrine disruptors;” it is simply a list of chemicals to be the first to go through 

EPA’s evaluation process. The process that EPA used to prioritize substances for screening 

did not include a determination of potential endocrine activity of any of the substances, but 

rather the potential for exposure. Glyphosate, a widely-used herbicide with multiple uses, 

was included on this list of initial active ingredients to be tested because it met the exposure 

criteria. Test orders for glyphosate were issued January 14, 2010, with test data to be 

submitted beginning January 2012. 

Glyphosate has undergone extensive testing, including a battery of acute, sub-chronic, and 

chronic tests, and a number of developmental and reproductive studies, mammalian and 

wildlife, capable of detecting effects on endocrine mediated events. The results from these 

studies, along with other scientifically relevant information, provide reliable and functionally 

equivalent information to the Tier 1 screening assays and demonstrate that glyphosate is not 

an endocrine active substance.

C. Aggregate Exposure

 Aggregate exposure for glyphosate is the combination of chronic dietary exposure 

(food + drinking water) and short- and intermediate-term non-dietary oral exposure from 

residential (home lawn care) and recreational (golf, swimming) use exposure.

 1. Dietary exposure. In evaluating dietary exposure to glyphosate, exposure under 

the petitioned-for tolerances as well as all existing glyphosate tolerances in 40 CFR 

180.364 were considered.

 i. Food. Quantitative acute dietary exposure and risk assessments are performed 

for a food-use pesticide if a toxicological study has indicated the possibility of an effect 

of concern occurring as a result of a 1-day or single exposure. No such effect has been 

identified in the toxicological studies for glyphosate; therefore, a quantitative acute 

dietary exposure assessment is unnecessary. 

A chronic dietary exposure assessment was conducted using the food consumption data 

from the United States Department of Agriculture Continuing Survey of Food Intake by 

Individuals (USDA CSFII) (1994–1996 and 1998). The chronic analysis assumed 

tolerance-level residues, 100 percent crop treated (PCT), and Dietary Exposure 

Evaluation Model (DEEM (version 7.81)) default processing factors and incorporated 

glyphosate drinking water monitoring data. 

EPA has concluded that glyphosate does not pose a cancer risk to humans; therefore, a 

dietary exposure assessment for the purpose of assessing cancer risk is unnecessary.

 ii. Drinking water. Monitoring data from the United States Geological Survey 

(USGS) National Water-Quality Assessment Program (NAWQA) was used to calculate 

drinking water exposure. For chronic dietary risk assessment, the water concentration 
8

value of 13.5 parts per million (ppm) was used to assess the contribution to drinking 

water.

 2. Non-dietary exposure. The term ‘‘residential exposure’’ is used to refer to nonoccupational, non-dietary exposure (e.g., for lawn and garden pest control, indoor pest 

control, termiticides, and flea and tick control on pets). The agricultural use on root and 

tuber vegetables, teff and oilseed crops is not anticipated to result in residential exposure. 

However, residential exposure is anticipated from the registered broadcast and spot 

treatment to residential lawns, gardens, and recreational areas including parks and golf 

courses. Based on the registered residential use patterns, there is a potential for shortterm and intermediate-term dermal and inhalation exposures to homeowners who mix 

and apply products containing glyphosate. Since short- and intermediate-term dermal and 

inhalation endpoints were not selected, no residential handler/applicator exposure 

assessment was conducted. Post-application dermal and inhalation exposure assessments 

were not conducted since short- and intermediate-term dermal and inhalation endpoints 

were not selected. Based on registered use patterns, toddlers may have short-term postapplication incidental oral exposure from hand-to-mouth, object to mouth, and soil 

ingestion behavior on treated lawns and swimmers may have short-term post-application 

incidental oral exposures from treated surface water. Exposures and risks from these 

scenarios were assessed because an applicable endpoint was identified. Further 

information regarding EPA standard assumptions and generic inputs for residential 

exposures may be found at http://www.epa.gov/pesticides/trac/science/trac6a05.pdf.

D. Cumulative Effects

 Section 408(b)(2)(D)(v) of FFDCA requires that, when considering whether to 

establish, modify, or revoke a tolerance, the Agency must 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 

glyphosate to share a common mechanism of toxicity with any other substances, and 

glyphosate does not appear to produce a toxic metabolite produced by other substances. 

For the purposes of this tolerance action, therefore, EPA has assumed that glyphosate 

does not have a common mechanism of toxicity with other substances. For information 

regarding EPA’s efforts to determine which chemicals have a common mechanism of 

toxicity and to evaluate the cumulative effects of such chemicals, see EPA’s Web site at 

http://www.epa.gov/pesticides/cumulative.

E. Safety Determination

 Based on conservative risk assessments, EPA concludes that there is a reasonable 

certainty that no harm will result to the general population or to infants and children from 

aggregate exposure to glyphosate residues. 

 1. U.S. population. A chronic dietary risk assessment of glyphosate was conducted 

using the current and the proposed new and increased tolerances for all root and tuber 

vegetables included in Crop Group 1, except sugar beet, and all oilseed crops included in 

Crop Group 20, except cottonseed. Since it is proposed that tolerances for the animal feed 
9

commodities teff forage and teff hay be made the same as the current tolerance for Crop 

Group 16, Forage, Fodder and Straw of Cereal Grains, no additional residue exposure would 

be expected through the consumption of meat. 

The Tier 1 chronic dietary analysis for glyphosate is a conservative estimate of dietary 

exposure that uses tolerance level residues and 100% crop treated. Under this assumption, 

exposure to glyphosate from food and water will utilize only 5.3% of the chronic population 

adjusted dose (cPAD) for the general U.S. population. Based on its use pattern, chronic 

residential and recreational exposure to residues of glyphosate is not expected. 

Based on the completeness and reliability of the toxicity data and the conservative exposure 

assessment, it can be concluded that there is a reasonable certainty that no harm will result to 

the general U.S. population from chronic aggregate exposure to glyphosate residues.

 2. Infants and children. Section 408(b)(2)(C) of FFDCA provides that EPA shall 

apply an additional tenfold (10X) margin of safety for infants and children in the case of 

threshold effects to account for prenatal and postnatal toxicity and the completeness of 

the database on toxicity and exposure unless EPA determines based on reliable data that a 

different margin of safety will be safe for infants and children. This additional margin of 

safety is commonly referred to as the FQPA SF. In applying this provision, EPA either 

retains the default value of 10X, or uses a different additional safety factor when reliable 

data available to EPA support the choice of a different factor. 

There is no quantitative or qualitative evidence of increased susceptibility of rats or rabbit 

fetuses to in utero exposure in developmental studies. A focal tubular dilation of the 

kidneys was observed in a 3-generation reproductive study on rats at the 30-mg/kg/day 

HDTL; however, a 2-generational reproductive study on rats did not observe the same 

effect at the 1,500-mg/kg/day HDTL, nor were any adverse reproductive effects observed 

at any dose level. A clear NOAEL was established and the chronic reference dose was set 

at a level well below (׽17-fold) this effect. Therefore, the endpoints selected for risk 

assessment are protective of the effects seen in the 3-generation rat reproduction study. 

There are no residual uncertainties for pre- or postnatal toxicity. 

EPA has determined that reliable data show the safety of infants and children would be 

adequately protected if the FQPA SF were reduced to 1X. That decision is based on the 

following findings: 

- The toxicity database is complete with the exception of recently-required studies on 

acute and subchronic neuorotoxicity and immunotoxicity. There is no evidence of 

neurotoxicity in any of the toxicology studies. Accordingly, although an acute and 

subchronic neurotoxicity studies are now required as part of new data requirements, EPA 

does not believe that conducting these studies will result in a lower POD than that 

currently used for overall risk assessment, and therefore, a database uncertainty factor is 

not needed to account for lack of these studies. 

- The toxicology database for glyphosate does not show any evidence of treatment-related 

effects on the immune system. The overall weight of evidence suggests that this chemical 
10

does not directly target the immune system. Accordingly, although an immunotoxicity 

study is required as a part of the new data requirements in the 40 CFR part 158 for 

conventional pesticide registration, EPA does not believe that conducting a functional 

immunotoxicity study will result in a lower POD than that currently use for overall risk 

assessment, and therefore, a data base uncertainty factor is not needed to account for lack 

of this study. 

- There is no quantitative or qualitative evidence of increased susceptibility of rats or 

rabbit fetuses to in utero exposure in developmental studies. 

- The dietary analysis of exposure to glyphosate is conservative as it assumes tolerance 

level residues and 100 PCT. EPA made conservative (protective) assumptions in the 

water modeling used to assess exposure to glyphosate in drinking water. EPA used 

similarly conservative assumptions to assess post-application exposure of children as well 

as incidental oral exposure of toddlers. 

Based on the exposure assumptions, chronic exposure to glyphosate from food will 

utilize 12.5% of the cPAD for children 1–2 years old, the population group receiving the 

greatest exposure.

F. International Tolerances

Several countries (EU, Australia, Israel, Russia and others) have established a 

group tolerance or maximum residue limit (MRL) for glyphosate in or on all or some of 

the root and tuber vegetable crops listed in Crop Group 1 in the U.S.; all of them are at or 

less than 0.1 ppm. The same is true for some or all of the oilseed crops listed in Crop 

Group 20 in the U.S. There are no international tolerances for glyphosate in or on teff 

forage and hay.