-I L I PESTICIEE ASSESSMENT GUItELINES SUBDIVISION O RESIDCE CHEMISTRY Series 171-4 Specialty Applications (I) Classification of Seed Treatments and Treatment of Crops Grown for Seed Use Only as Non-Food or Food Uses (II) Macyiitude of the Residue: Post-harvest Fumigation of Crops and Processed Foods and Feeds (III) Magnitude of the Residue: Post-harvest Treatment (Except Fumigation) of Crops and Processed Foods and Feeds ADDENDUM 5 ON DATA REPORTING Prepared by: Michele Leparulo Loftus, Ph.D. Residue Chemistry Branch Hazard Evaluation Division Project Manager: Elizabeth M. K. Leovey, Ph.D. Hazard Evaluation Division Office of Pesticide Programs U.S. Environmental Protection Agency ------- Subdivision O - Speciality Applications Table of Contents of Addendum Discussion Introduction 3 Response to Public Comments 3 Guidelines Part I: Classification of Seed Treatments and Treatment of 5 Crops Grown for Seed Use Only as Non-Pood or Pood Uses Part II: Magnitude of the Residue: Post-harvest Fumigation of 12 Crops and Processed Foods and Feeds Part III: Magnitude of the Residue: Post-harvest Treatment 19 (Except Fumigation) of Crops and Processed Foods and Feeds Table of Contents for Part I Introduction Guideline Master Cover Page Table of Contents I. Introduction II. Materials and Methods III. Results and Conclusion IV. Raw Data and Information on Individual Field Trials V. Certification VI. References VII. Appendices 5 6 6 6 6 6 9 10 11 11 11 ------- Table of Contents for Part II Introduction Guideline Master Cover Page Tfeble of Contents I. Introduction II. Materials and Methods III. Results and Conclusions IV. Raw D&ta and Information on Individual Trials V. Certification VI. References VII. Appendices Table of Contents for Part III Introduction Guideline Master Cover Page Table of Contents I. Introduction II. Materials and Methods III. Results and Conclusions VI. Raw Data and Information on Individual Trials V. Certification VI. References VII. Appendices 12 12 12 12 13 13 16 17 18 18 18 19 19 19 19 20 20 22 23 24 24 25 -2- ------- PESTTCIEE ASSESSMENT GUIEELINES RESIDUE CHEMISTRY Specialty Applications Subdivision O, Series 171-4 DATA REPORTING FOREWORD The Data Reporting Guidelines are addenda to the Pesticide Assessment puidelines (Subdivision O), designed primarily to aid the petitioner/registrant in generating reports compatible with the Environmental Protection Agency's review process. They were intended also to clarify ambiguities in the Interpretation of the existing Pesticide Assessment Guidelines .^/ The Data Reporting Guidelines are not intended to introduce new data requirements or -evisions to the Pesticide Assessment Guidelines, nor are they intended for jse by Agency reviewers as a mere checklist. While following the Data Reporting luidelines is not mandatory, data submitters are encouraged to submit complete •eports which can be efficiently reviewed by the Agency. The Agency realizes here are sections in the Data Reporting Guidelines which do not apply in all ases. Therefore, registrants should exercise judgment in deciding vhich ortions are germane to a specific data submission. , This guidance pertains to the substance of the data report. PR Notice 6-5, effective on November 1, 1986 (available from the Registration Support id Emergency Response Branch, Office of Pesticide Programs, US EPA), pertains 3 the physical formating of reports (which are referred to as "studies") id sutmittal packages. Some of the requirements in PR Notice 86-5 are i inflatory. i The Data Reporting Guideline on Specialty Applications is divided into 1 nree parts: (I) Classification of Seed Treatments and Treatment of Crops C -own for Seed Use Only as Non-Food or Pood Uses? (II) Postharvest Fumigation c : Crops and Processed Foods and Feeds; (III) Post-harvest Treatment (Except I migation) of Crops and Processed Foods and Feeds. Each part gives the i rmat/outline recommended by the Agency to be used by the petitioner/ r gistrant for reports on the particular specialty application study. RESPONSE TO PUBLIC COMMENTS The purpose of this section is to acknowledge and address the concerns expressed in the letters of comments received by the Agency in response to In addition, Residue Chemistry Standard Evaluation Procedures, designed to aid Agency reviewers in their evaluations of pesticide residue data, are available. They provide a nore thorough clarification of the existing Pesticide Assessment Guidelines. -3- ------- the public notice in the FEDERAL REGISTER of October 15, 1986 (51 FR 36753). The only conment received concerning these guidelines was that the guidelines should not contain technical details on why the test is necessary, how it should be run and how the data will be evaluated; these should be covered by the Pesticide Assessment Guidelines and Standard Evaluation Procedures (SEPs). The Agency has included the introductory materials as a convenience to data submitters and to clarify relevant sections in the Pesticide Assessment Guidelines of difficulty for some registrants. ------- Classification of Seed Treatments and Treatment of Crops Grown for Seed Only as Non-Food or Pood Uses Treatment of Crops Grown for__Seed Use Only For the treatanent of crops grown for seed use only to be classified as a non-food use, the following requirements must be met: (1) the seed itself or its sprouts are not raw agricultural conmodities ;£/ 2) there is no livelihood of residues in crops grown from harvested seed; (3) subsequent to treatment, all parts of the crop are not fit for human or animal consumption. Details of these requirements and any exceptions are given in Part I of the Standard Evaluation Procedure for Specialty Applications.^/ If the treatment of the crop grown for seed use only is classified as a non-food use, no residue studies are needed. If the treatment of the crop grown for seed use only is classified as a food use, metabolism and crop field studies are needed. The formats for the metabolism and crop field studies^/ are addressed in separate Data Reporting Guideline documents being developed concurrently, and the registrant/petitioner is referred to those Data Reporting Guidelines when the treatment of crops grown for seed use only is classified as a food use. Seed Treatments For seed treatments to be classified as a non-food use, data fron a radiotracer study are needed demonstrating no uptake of radioactivity to the aerial portion and edible root (both human and livestock consumption) portion of the crop.£/ If the radiotracer study demonstrates that the particular seed treatment is a non-food use, no further studies are needed. If the seed treatment is classified as a food use, plant metabolism and crop field studies^/ are needed, and the registrant is referred to the Data Reporting Guidelines for those studies. 2/ 40 CFR 180.l(e): Raw agricultural ccmmodities include among other things ~~ fresh fruits, vfliether or not they have been washed and colored or otherwise treated in their unpeeled natural form; vegetables in their raw or natural state, \4iether or not they have been stripped of their outer leaves, waxed, prepared into fresh green salads, etc.; grains, nuts, eggs, raw milk, meats, and similiar agricultural produce. It does not include foods that have been processed, fabricated, or manufactured by cooking, freezing, dehydrating, or milling. £/ The Standard Evaluation Procedure (SEP) for Specialty Applications is being developed concurrently. £/ See Data Reporting Guideline for Magnitude of the Residue: Crop Field Trials; and Data Reporting Guideline for Nature of the Residue; Plants, available from the National Technical Information Service (NTIS), PB86-248192 and PB87-208641 respectively. 5/ For additional details, see Part I of the SEP for Specialty Applications. -5- ------- -6- The guideline given below in Part I of the Data Reporting Guideline for Specialty Applications is a format/outline for the radiotracer study determining whether or not the seed treatment results in uptake of radioactivity to the aerial edible and root portions of the crop. The report for this study should include all information necessary to provide a complete and accurate description of the study. GUIDELINE MASTER CDVER PAGE Title page and additional documentation requirements (i.e., requirements for data submission and procedure for claims of confidentiality of data) if relevant to the study report should precede the content of the study fomatted below. These requirements are described in PR Notice 86-5. TABUS CF CONTENTS I. IMTRDDUCTION A. Background and Historical Information on the Pesticide 1. Brief summary of nature of the residue in plants, including the structures of the parent and residues considered to be of toxicological concern; 2. Brief summary and references for residue data for the pesticide active ingredient on this commodity and related comiiodities available fran other sources; and 3. list of current and former section 3, 5, 24(c) registrations and section 18 exemptions for the oomtxlity under study and related commodities. B. Purpose of Study C. Abstract of Study 1. Brief sunnary of application and field procedures; 2. Results, including unexpected problems; and 3. Conclusions. II. MKTERIAIS AND fCTHODS A. Test substance 1. Identification of the test pesticide active ingredient (a.i.), including chemical name, cannon name (ANSI, BSI, ISO), registrant developmental/experimental name and chemical structure; 2. Description of the radiolabeled test material; ------- I -7- Identify the radiolabel and the site of the label. A rationale should be provided for selection of a radiolabel other than l^C and for the site of the label (where possible the ring position should be labeled). The purity, specific activity in Curies/mole and disintegrations per minute per gram (dprn/g) should be reported here. 3. Identification of the pesticide formulated product(s) in which the radiolabeled pesticide active ingredient was applied, including trade name, type (EC, WP, G, etc.), pounds of active ingredient per gallon, percent a.i. by weight, EPA registration nuntoer, and manufacturer; and 4. Physical state and nature of the solvent, carrier, bait, adjuvant or other matrix in which the pesticide was applied. B. Test Crop Note: If more than one trial is carried out using different varieties, sites, etc., the registrant may prefer to include the following in Chapter IV, RW7 DATA AND INFORMATION ON INDIVIDUAL FIELD TRIALS. 1. Identification of the test crop including variety and crop group classification according to 40 CFR §180.34(f), as revised June 29, 1983; 49 FR 29855; 2. Identification of specific crop part(s) harvested and subjected to analysis for radioactivity; and 3. Developmental stage (s), general condition (imtiature/mature, green/ripe, fresh/dry, etc.), size(s) of the test crop at time of harvest. C. Test Site Note: If more than one trial is carried out using different varieties, sites, etc., the registrant may prefer to include the following in Chapter TV, RW DATA AND INFORMATION ON INDIVIDUAL FIELD TRIALS. 1. Description of test site; Overall testing environment (outdoor test plots, greenhouse, plant growth chamber); location (county and state); environmental conditions (tenperature, rainfall, sunlight); soil type; 2. Location (county, state); and 3. Cooperator. D. Field Trial Methods Note: If more than one trial is carried out using different ------- -8- varieties, sites, cultural practices, etc., the registrant may prefer to include this in Chapter IV, DATA PND INFORMATION ON INDIVIDUAL FIELD TRIALS. 1. Detailed description of application of radiolabeled pesticide to seeds: Information to be reported includes dose rate, pounds active ingredient and formulated product per pounds seed, concentration of treatment solution, volume of application solution per pounds seed, formulation, physical state in vhidi pesticide is applied, diluent, additives, etc., method of application (hopper box, commercial equipment) . The pesticide should be applied at the maximum proposed application rate. 2. Field trial lay-out: Information to be reported includes size of plots/pots, number of plants per plot/pot, number of plots/pots, number of plants per unit area, length of raws and row spacing. 3. Farming practice: Information on practices such as cultivation, irrigation, and treatments with other pesticides should be included here. 4. Harvest procedures, including the number of days between planting and harvesting. E. Sampling, Handling and Storage 1. Dates of sampling, shipping, storage, and analyses; 2. Description of sampling procedure and size of samples; and 3. ffandling, pre-shipping, shipping, post-shipping storage conditions, including storage times ._£/ F. Analytical Prpc^ure^/Instrumention7/ 1. Description of sample preparation (i.e., dissection, grinding, lyophilization, number of plants contained in one sample, etc.) prior to analyses of radioactivity; and 2. Details of analytical method to measure radioactivity, including descriptions of equipment and instrument parameters. Refer to the Data Reporting Guideline on Storage Stability available from NTIS, PB86-248192. Also refer to the Data Reporting Guideline on Analytical Methods available from NTIS, PB86-248192. ------- -9- G. Quality Control Description of control measures and precautions followed to ensure the fidelity of the field tests, samples and measurement of the residue. H. Other Pertinent Information on Materials and Methods III. RESUWS MJD CONCLUSIONS A. Brief Summary of Study Procedures The summary of the study procedures should include the number of field trials, descriptions of the application of the radiolabeled pesticide to the seed (dose rate, method, formulation), the site (greerhouse, outdoors, plant growth chamber), number of days between planting and harvest, number of plants sampled, parts of the plant analyzed for radioactivity, and the method of detection. B. Results 1. Total recovered (i.e., combustible) radioactivity on seeds at time of planting, if measured: The radioactivity should be reported as: a. disintegrations per minute (dpm) b. dpm/ug c. ppm equivalents (expressed as parent compound). 2. The distribution of radioactivity in the treated crop at the time of harvest or sampling: The data to be reported are the total recovered (i.e., combustible) radioactivity remaining at time of sampling or harvest on the whole plant and on the plants parts of interest; i.e., the aerial and edible root portions of the plant. The radioactivity for the whole plant and the plant parts should be reported in tabular format as: a. dpni b. dpm/ug c. ppm equivalents (expressed as parent conpound). For the plant parts, the radioactivity should also be expressed as: d. The percentage of the total recovered radioactivity in the whole plant. ------- -10- 3. Graphs and figures of the results: Graphs, if provided, should be acconpanied by tables of actual values fron which graphs were constructed. 4. Narrative of results: Narrative should include a discussion of the quantitative accountibility for a majority of the total radioactivity recovered fron the aerial and edible root portions of the plant and a discussion of unexpected problems, the way in which they were resolved, and explanations for apparently aberrant, atypical values. C. Conclusions The registrant's conclusion on whether or not the results of this study and any other relevant studies support a non-food use classification for the seed treatment in question should be given. IV. RAW DATA AND INFORMATION C® INDIVIDUAL FIELD TRIALS A. Details of Radicjactive Counting Data for Selected Representative Samples Details should include counting times, total counts recorded, corrected counts, counting efficiencies, other raw data (sample sizes, ppm equivalents found, sensitivity, limit of detection) and other pertinent information needed to check the registrant's calculations. B. Inscription of Calculations, Including Examples C. Description of Statistical Tests, Including^Examples D* Represejitative^ Raw Data Figures As applicable, printout sheets, chronatograms, spectra, etc. E. Detailed Descriptions of Each Field Trial Note: Some of this information is the same included under Chapter II, MATERIALS AND METHODS. It is not necessary to include this in more than one location in the report. The registrant may decide where to report this information. 1. Information to be reported for each field trial includes: a. Test crop (see chapter II.B of this guideline); b. Test site (see diapter II.C of this guideline); c. Field trial methods (see chapter II.D of this guideline); ------- mm~\ I—. d. Dates (treatment of seeds, planting, sowing, transplanting, sampling/harvest, receipt in laboratory, storage, analysis, etc.); e. Length of storage of samples; and f. Sample identification. P. Other Any additional information the registrant considers appropriate and relevant to provide a complete and thorough description of the study. V. CERTIFICATION Certification of authenticity by the Study Director (including signature, typed name, title, affiliation, address, telephone number and date). VI. REFERENCES VII. APPENDICES A. Reprints of published and unpublished literature, company reports, letters, etc., not expected to be in CPP files, but which the registrant feels will aid the review of the study. B. Other pertinent information vfoich does not fit in any other section of this outline. ------- II Magnitude of the Residue: Post-harvest Fumigation of Crops and Processed Foods and Feeds Part II of the Eata Reporting Guideline for Specialty Applications is an outline/format for a report on a study to determine the magnitude of the residue which will result on raw crops and processed foods and feeds as a result of post-harvest fumigation. Other post-harvest treatments are the subject of Part III of this Data Reporting Guideline. Fumigation may be defined as the act of releasing and dispersing a toxic chemical so that it reaches the organism wholly or primarily in the gaseous or vapor state. Both the raw agricultural conmodities and its processed products may be treated post-harvest by fumigation. The report for a study on the post-harvest fumigation of raw crops and processed foods and feeds should include all information necessary to provide a oanplete and accurate description of the study. The study should answer the following question: what is the maximum level of "total toxic residue"^/ that will result in or on the raw food or feed or processed food or feed from the proposed post-harvest fumigation of the raw or processed cutiaudity with the pesticide formulated product? Actual residue data on commodities as consumed should be provided in cases where tolerance level residues lead to unreasonable risks. Crop group considerations should also be addressed, and an effort should be made to achieve harmonization with applicable International Residue Limits (Codex). GUIIELINE MASTER COVER PAGE Title page and additional documentation requirements (i.e., requirements for data submission and procedure for claims of confidentiality of data) if relevant to the study report should precede the content of the study formatted below. These requirements are described in PR Notice 86-5. TABLE CF GOOTENTS The term "total toxic residue" is used to describe the sum of the parent and its degradation products, metabolites (free or bound), and impurities that are considered to be of toxicological significance, and therefore warrant regulation. -12- ------- -13- I. OTTODUCTION A. Background and historical information on the pesticide 1. Brief summary of nature of the residue in plants, including the structures of the parent and the residues considered to be of toxicological significance; 2. Brief summary and references for residue data for the pesticide active ingredient en this commodity and related camiudities, available fron other sources; and 3. list of current or former section 3, 5, 24(c) registrations and section 18 exemptions for the pesticide active ingredient on the coimodity under study or related camodities. B. Purpose of Study C. Abstract of Study 1. Brief summary of application procedures ; 2. Results, including unexpected problems; and 3. Conclusions. II. MATERIALS AND NEIHDDS A. Test Substance 1. Identification of the test pesticide active ingredient (a.i.), including chemical name, cannon name (ANSI, BSI, ISO), registrant developmental/experimental name and chemical structure; 2. Identification of the pesticide formulated product(s) in vhich the pesticide active ingredient was applied, including trade name, type (EC, WP, G, etc.), pounds of active ingredient per gallon, percent a.i. by vreight, EPA registration number and manufacturer; 3. Information on the matrix in which the formulated pesticide was applied and on any additives; and 4. Physical/chemical parameters on the test substance. B. Test Raw or Processed Comiodity Note: If more than one trial is carried cut using different varieties, fumigation chambers, conditions, etc., the registrant may prefer to include the following in Chapter IV, RAW DATA AND INFORMATION ON INDIVIDUAL TRIALS. ------- -14- 1. Identification of the raw or processed test canmodity, including variety and crop group classification according to 40 CFR §180.34(f), as revised June 29, 1983; 48 FR 29855; 2. Identification of specific crop part(s) harvested, fumigated and analysed; 3. Developmental stage(s), general condition (immature/mature, green/ripe, fresh/dry, etc.), size(s) of the test ccmmodity at tine of fumigation; 4. Size and kind of containers holding the connDdity (e.g. wood burlap, etc.); and 5. Information on whether the raw or processed coimnodity, or its storage container, had been treated prior to the test post-harvest treatment, including application rates, ffll's and the residue prior to the test post-harvest treatment. C. Test Site Note: If more than one trial is carried out using different varieties, sites, etc., the registrant may prefer to include the following in Chapter IV, R2W DATA AND INFORMATION ON INDIVIDUAL TRIALS. 1. Description of fumigation chamber Information to be reported includes: a. Type of fumigation chamber (grain elevator and flat storage, tarpaulin covering, shophold, fumigation, vault, vacuum chamber, etc.); b. Size and geometry of fumigation chamber; c. Measures taken to seal the fumigation chamber (e.g., covering surfaces with asphalt paper or plastic tarpaulins, sealing of vents, windows, cracks, etc.); d. Drafts inside the chamber; e. Temperature inside the chamber; and f. The relative size of the chamber as compared to the conmodity load. 2. Location of fumigation chamber Information to be reported includes: a. Oounty and state; b. Environmental conditions (temperature, wind, temperature); and ------- -15- c. Gooperator. D. Application of the Pesticide Note: If more than one trial is carried out using different varieties, fumigation chantoers, conditions, etc., the registrant may prefer to include the following in Chapter TV, RAW DATA AND INFORMATION ON INDIVIDUAL TRIALS. 1. Type of fumigant dispensing system and method of fumigant volatilization; 2. Measures taken to hasten gas circulation; 3. Dose rate, exposure time, temperature, and pressure; 4. layout of the fumigation (i.e., discharge points and positioning of circulating fans/blowers in relation to arrangement of commodities, size of stacks of caimpdities, etc.); 5. Number and date(s) of application(s) ; and 6 . Formulation . E. Aeration of the OcmTDdi ties 1. The aeration time and the dates of the aeration; 2. Description of aeration procedures inside (e.g., removal of seals and covers, opening of doors and windows, use of exhaust fans and air suction systems) and outside the fumigation chamber; and 3. Description of any aeration following sampling. F. Sampling, fteijdling, and Storage 1. Dates of sampling, shipping, storage and, analyses; 2. Description of sampling procedure, including the location of the sampling (e.g., top, bottom or side outer layer or center of stack; side or middle of chamber), size of the samples, and measures taken to prevent desorption of the fumigant during sampling; and 3. Handling, pre-shipping, shipping, and post-shipping storage conditions, including storage times^/, special measures taken to prevent desorption of the fumigant during the time between sampling and analysis, and description of sample containers and storage temperature . _£/ See Data Reporting Guideline on Storage Stability available from NTIS, PB86-248192. ------- -16- G. Analytical Prpcedares/Instruinention^Q/ 1. Description of sample preparation (compositing, subsampling, grinding, extraction, etc.) and measures taken to prevent desorption of the fumigant during sample preparation; and 2. Details of analytical method to measure residue, including descriptions of equipment/instrumentation and instrument parameters. H. Quality Control Description of control measures and precautions to ensure the fidelity of the field test, samples and measurement of the residue. I. Any OtherJPertinent Information on Material and Methods III. RESULTS AND CONCLUSIONS A. Brief Suntrary of the Study Procedures The sumnary of the study procedures should include the number of trials, the commodities, vfriether the uamiodities had been previously treated with the test active ingredient, descriptions of the fumigations and fumigation chambers, the formulation, aeration time, and the method of detection. B. Results of Analyses of Treated and Control Samples and Fortified Samples 1. Tables of the results Residue data should be given in a tabular format, providing the followLng information: a. Commodity; b. Plant part; c. Type of fumigation chamber; d. Dose; e. Exposure time; f. Temperature; g. Aeration time; and Refer to the Data Reporting Guideline on Analytical Methods available fron NTIS, PB86-248192. ------- -17- h. Residue; residue testing should extend beyond sampling immediately after the label specified aeration to include studies to follow the rate of residue decline that could be expected under various shipping and storage conditions and temperature. 2. Graphs and Figures of the Results: Graphs, if provided, should be accanpanied by tables of actual values frcm which graphs were constructed. 3. Narrative on the results: Narrative should include a discussion of unexpected problems and ways in which they were resolved and explanations for apparently aberrant, atypical values. E. Conclusions on the Appropriate Tolerance(s) for the Proposed Use(s) W. RAW DATA AND INFORMATION ON INDIVIDUAL TRIALS A. Raw Data Tables for JResidue^Analyses^ of: Tjreated^ ^Control and Fortification Recovery Samples and Standards B. Representative Raw jjata ^Figures 1. As applicable, printouts, spectra, chrcmatograms of treated samples, control samples, fortified samples and standards, etc.; and 2. Calibration curves. C. Description of Calculations, Including Examples D. Description of Statistical Tests, Including Exanples E. Detailed Descriptions of Each Trial Note: Some of this information is the same included under MATERIALS AND METHODS (Chapter II of the format). It is not necessary to include this information in more than one location in the report. The registrant may decide where to report this information. 1. Information should be reported for each trial on: a. Test raw or processed commodity (see Chapter II.B of this guideline); b. Test site (see Chapter II.C of this guideline); c. Application of the pesticide {see Chapter II.D of this guideline); ------- -18- d. Aeration of the conraodities (see Chapter II.E of this guideline); e. C&tes (fumigation, aeration, sanpling, receipt at laboratory, analyses, etc.)? and f. Sample identification. F. Other Any additional information the registrant considers appropriate and relevant to provide a cotplete and thorough description of the study. V. CERTIFICATION Certification of authenticity by the Study Director (including signature, typed name, title, affiliation, address, telephone nuntoer and date). VI. REFERQCES VII. APPENDICES A. Reprints of published and unpublished literature, company reports, letters, etc., not expected to be in O?P files, but which the registrant feels will aid the review of the study. B. other pertinent infomation which does not fit in any other section of this outline. ------- Ill Magnitude of the Residue: Post-harvest Treatment (Except Fumigation) of Crops and Processed Poods and Feeds Part III of the Cata Reporting Guideline for Specialty Applications is an outline/format for a report of a study to determine the magnitude of the residue vihich will result on raw crops and processed foods and feeds as a result of post-harvest treatments, except fumigation. Post-harvest fumigation is the subject of Part II of this Eata Reporting Guideline. Post-harvest treatments of foods and feeds are applied by various means, including dips, drenches, mechanical foamers, and spray and brush applicators. The pesticide may be applied directly (to the commodity) or indirectly (to the storage bin). Often, the application of a wax coating on the comnDdity is involved. Both the raw agricultural commodity and its processed product may be treated post-harvest. Additional details on post-harvest treatments are given in Part III of the Standard Evaluation Procedure for Specialty Applications .^V The report for a study on the post-harvest treatment of raw crops and processed foods and feeds should include all information necessary to provide a complete and accurate description of the study. The study should answer the following question: vihat is the maximum level of "total toxic residue" that will result in or on the raw food or feed or processed food or feed from the proposed post-harvest treatment of the raw or processed commodity with the pesticide formulated product? Actual residue data on commodities as consumed should be provided in cases where tolerance level residues lead to unreasonable risks. Crop group considerations should also be addressed, and an effort should be made to achieve harmonization with applicable International Residue Limits (Codex). GUIDELINE BISTER ODVER PAGE Title page and additional documentation requirements (i.e., requirements for data submission and procedure for claims of confidentiality of data) if relevant to the study report should precede the content of the study formatted below. These requirements are described in PR Notice 86-5. TABLE CF CDNTEOTS To be published. -19- ------- -20- I. INTRODUCTION A. Background and Historical Information on the Pesticide 1. Brief summary of nature of the residue in plants, including the structures of the parent and the residues considered to be of toxicological significance; 2. Brief summry and references for residue data on this commodity and related ccnrodities available from other sources; and 3. List of current or former section 3, 5, 24(c) registrations and section 18 exemptions for the commodity under study or related corarDdities. B. Purpose of Study C. Abstract of Study 1. Brief summary of application procedures? 2. Results, including unexpected problems; and 3. Conclusions. II. MATERIALS AND METHODS A. Test Substance 1. Identification of the test pesticide active ingredient (a.i.), including chemical name, cannon name (ANSI, BSI, ISO), registrant developmental/experimental name and chemical structure; 2. Identification of the pesticide formulated product(s) in which the pesticide active ingredient was applied, including trade name, type (EC, WP, G, etc.), pounds of active ingredient per gallon, percent a.i. by weight, EPA registration number and manufacturer; and 3. Information on the matrix (e.g., water, wax) in which the formulated pesticide was applied and on any additives. TraJe and diemical names for the matrix substance and additives should be provided. B. Test Raw or Processed Comnodity Note: If more than one trial is carried out using different varieties, application procedures, conditions, etc., the registrant may prefer to include the following in Chapter IV, RAW DATA AND INFORMATION ON INDIVIDUAL TRIALS. ------- -21- 1. Identification of the raw or processed test caimodity, including variety and crop group classification according to 40 CFR §18Q.34(f), as revised June 29, 1983; 48 ER 29855; 2. Identification of specific crop part(s) harvested, treated, and analysed; 3. Developmental stage(s), general condition (inmature/niature, green/ripe, fresh/dry, etc.), size(s) of the test oonnodity at time of treatment; and 4. Information on whether the oanmodity or storage container had been treated with the test active ingredient prior to the test post-harvest treatment, including application rates, mi's, and the residue prior to the test post-harvest treatment. C. Test Site Note: If more than one trial is carried out using different varieties, application procedures, conditions, etc., the registrant may prefer to include the following in Chapter IV, RAW DATA AND INTOBMATION CN INDIVIDUAL TRIALS. 1. Description of test site; Overall testing environment (outdoor, indoor, climate controlled packinghouse, etc.), temperature; 2. Location (county, state); and 3. Oooperator. D. Application of the Pesticide Note: If more than one trial is carried out using different varieties, application procedures, conditions, etc., the registrant may prefer to include this in Chapter IV, RAW DATA AND INFORMATION CN INDIVIDUAL TRIALS. 1. Physical state in which the pesticide was applied; 2. Description of method/equipment for pesticide application; e.g., direct (applied to conmDdity) or indirect (applied to storage container), dips, drenches, mechanical foamers, spray applicators, brush applicators, wax applicators; 3. Pounds active ingredient and formulation per pounds treated ccranodity, concentration of treatment solution, volume of treatment solution per pounds treated cannodity, exposure time, number of treatments, temperature of solution; 4. Description of post-harvest practices acccmpanying the post-harvest treatment such as application of wax coatings after treatment, ------- -22- detexgent washes, and rinses, including number, timing, and \Olume; 5. Date(s) of application(s); and 6. fbrmulation. F. Sampling, Handling and Storage 1. Dates of sampling, shipping, storage and analyses; 2. Description of sampling procedure and size of the samples; and 3. Handling, pre-shipping, shipping, and post-shipping storage conditions, including storage times-jj/. G. Analytical Procedures/Instrumention^V 1. Description of sample preparation (ccnpositing, subsampling, grinding, extraction, etc.); and 2. Details of analytical method to measure residue, including descriptions of eguipment/instrurnentation and instrument parameters. H. Quality Ccjrt.rol Description of control measures and precautions to ensure the fidelity of the field test, samples and measurement of the residue, I. Any Other Pertinent Informaticn on Material ara3 Methods III. RESULTS AND CONCLUSIONS A. Brief Summary of Study Procedures The summary of the study procedures should include the number of trials, the coraiDdities, vhether the conrrodities had been previously treated with the test active ingredient, description of the post-harvest treatment (e.g., concentration, exposure time, temperature), the formulation, and the method of detection. B. Results of Analysesof^Treated ara^ Control Samples and Fortified Samples see Data Reporting Guideline on Storage Stability available from NTIS, PB86-248192. See Data teporting Guideline on Analytical Methods available fron NTIS, PB86-248192. ------- -23- 1. Tables of the results Residue data should be given in a tabular format, providing the following information, as applicable: a. Ocmno3ity; b. Plant part; c. Method/equipment for pesticide application; d. Pounds active ingredient per pounds connodity; e. Concentration of treatment solution; f. Volume treatment solution per pounds cannodity; g. Exposure time; h. Number of treatments; i. Other pertinent information afreet ing the level of residue (e.g., use of wax, rinse, volume and time of rinse); j. Formulation; and k. Residue; residue testing should provide information on the rate of residue decline that could be expected under various shipping and storage conditions and temperature. 2. Graphs and figures of the results: Graphs, if provided, should be acconpanied by tables of actual values from vfriich graphs were constructed. 3. Narrative on the results: Narrative should include a discussion of unexpected problems and ways in which they were resolved and explanations for apparently aberrant, atypical values. C. Conclusions on the Appropriate Tolerance(s) for the Proposed Use(s) IV. RAW DATA AND INFORMATION ON INDIVIDUAL TRIALS A. Raw Data Tables for Residue Analyses of Treated, Control and Fortification Recovery Samples, and Standards ------- -24- B. Representative Raw Data Figures 1. As applicable, printouts, spectra, chrcmatograms of treated samples, control samples, fortified samples and standards, etc.; and 2. Calibration curves. C. Descrigticai^jjf J^loulations, Including Example^ D. Description of Statistical Tests, Including Examples E. Detailed Descriptions of Each Trial Note: Some of this information is the same included in Chapter II, MATERIALS AND METHODS. It is not necessary to include this information in more than one location in the report. The registrant may decide where to report this information. 1. Infonnation to be reported for each trial includes: a. Test raw or processed commodity (see chapter II.B of this guideline); b. Test site (see chapter II.C of this guideline); c. Application of the pesticide (see chapter II.D of this guideline); d. Dates (treatment, sampling, shipping, receipt in laboratory, storage, analyses, etc.); e. Length of storage of samples; and f. Sample identification. F. Other Any additional information the registrant considers appropriate and relevant to provide a conplete and thorough description of the study. V. CERTIFICATION Certification of authenticity by the Study Director (including signature, typed name, title, affiliation, address, telephone number and date). VI. REFERENCES ------- -25- VII. APPENDICES A. Reprints of published and unpublished literature, company reports, letters, etc., not expected to be in CPP files, but vfriidi the registrant feels vail aid the review of the study. B. Other pertinent infornation vhich does not fit in any other section of this outline. ------- |