PETITION PROPOSING A TOLERANCE FOR ACETAMIPRID USE IN PRODUCTION OF STRAWBERRY AND OTHER LOW-GROWING BERRIES VOLUME 1 OF 2 TITLE PAGE

PETITION PROPOSING A TOLERANCE FOR ACETAMIPRID USE IN PRODUCTION OF STRAWBERRY AND OTHER LOW-GROWING BERRIES VOLUME 1 OF 2 TITLE PAGE KENNETH S. SAMOIL INTERREGIONAL RESEARCH PROJECT NO. 4 RUTGERS, THE STATE UNIVERSITY OF NEW JERSEY 500 COLLEGE ROAD EAST, SUITE 201W PRINCETON, NJ 08540 New Jersey Agricultural Experiment Station Publication No. A-27200-47-06 Supported by State, U.S. Hatch Act & other U.S. Department of Agriculture Funds. IR-4 Acetamiprid Petition for Strawberry and Other Low-Growing Berries Page 1 of 61

VOLUME 1 - TABLE OF CONTENTS Page No. VOLUME 1 OF 2 TITLE PAGE...1 VOLUME 1 - TABLE OF CONTENTS...2 LETTER OF AUTHORIZATION...3 SECTION A...4 SECTION B...5 SECTION C...42 SECTION D...43 SECTION E...57 SECTION F...58 SECTION G...60 IR-4 Acetamiprid Petition for Strawberry and Other Low-Growing Berries Page 2 of 61

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SECTION A THE NAME, CHEMICAL IDENTITY, AND COMPOSITION OF ACETAMIPRID Please refer to letter of authorization, Page 3 Formulation used in testing: Assail 70 WP Insecticide EPA Reg. No. 8033-23-4581 IR-4 Acetamiprid Petition for Strawberry and Other Low-Growing Berries Page 4 of 61

SECTION B THE AMOUNT, FREQUENCY AND TIME OF APPLICATION OF ACETAMIPRID IR-4 Acetamiprid Petition for Strawberry and Other Low-Growing Berries Page 5 of 61

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SECTION C FULL REPORT OF INVESTIGATIONS MADE WITH RESPECT TO THE SAFETY OF THE PESTICIDE CHEMICAL ACETAMIPRID Please refer to letter of authorization, Page 3, to access the following data: a) Human safety data b) Domestic animal safety data c) Fish and wildlife safety data. IR-4 Acetamiprid Petition for Strawberry and Other Low-Growing Berries Page 42 of 61

SECTION D THE RESULTS OF TESTS ON THE AMOUNT OF ACETAMIPRID RESIDUES REMAINING IN OR ON THE RAW AGRICULTURAL COMMODITY STRAWBERRY IR-4 Acetamiprid Petition for Strawberry and Other Low-Growing Berries Page 43 of 61

SECTION D ACETAMIPRID: MAGNITUDE OF THE RESIDUE ON STRAWBERRY The purpose of this study was to collect and analyze treated and untreated residue samples from appropriate field sites according to the application parameters requested to provide the sponsor with residue chemistry data to support an acetamiprid tolerance. Acetamiprid, the active ingredient in Assail 70 WP Insecticide, controls aphids, Japanese beetles, lygus bugs, plant bugs, thrips, and whiteflies in strawberry production. Executive Summary IR-4 has received requests from Michigan, North Carolina, and Pennsylvania for the use of acetamiprid on strawberry. To support this requested use, magnitude of residue data were collected from ten field trials located in NAFTA Regions described in Table B.1.3. Residue data that have been collected from strawberry trials will also support tolerances on bearberries, bilberries, lowbush blueberries, cloudberries, cranberries, lingonberries, muntries, and partridgeberries. Each field trial site consisted of one untreated control plot and one treated plot. Soil characteristics of each of the trial sites are summarized in Table B.1.1. Common cultural practices were followed to maintain the crop. Additional maintenance pesticides and fertilizers were used at most of the sites to produce a commercial quality strawberry. Application type, timing, rates and number of applications are summarized in Table B.1.2. At each trial, two foliar applications of the test substance 6-9 days apart were made to the treated plots. The application rates ranged from 0.124 to 0.134 lb ai/a per application for a total rate range of 0.252 to 0.265 lb ai/a per season (see Table B.1.2). All applications were made using appropriate spray equipment, and the spray volume was sufficient to provide adequate dispersal of the test substance. Sampling started in the untreated control plot and ended in the treated plot. At all the field trials, samples were harvested 1 day after the last application (see Table C.3). Additionally, at the CA*57 trial, duplicate samples were collected 3, 5, and 9 days after the last application. The samples were analyzed using a working method very similar to the reference method, KP-216R1: Preliminary LC/MS/MS Analytical Method for Determination of Assail 70 WP Insecticide (Acetamiprid) in Crop Matrices, written by Fenn Li and Paul Reibach, Cerexagri, 9/6/2003. Method suitability was evaluated both prior to sample analysis and concurrently with sample analysis. The method validation recoveries ranged from 82% to 101%. Concurrent recoveries obtained during sample analysis ranged from 88% to 103%. The LOD for the method was calculated to be 0.000768 ppm and the LOQ was calculated to be 0.00231 ppm. The lowest level of method validation (LLMV) for strawberry was 0.01003 ppm for acetamiprid. Additional information regarding method recoveries can be found in Table C.1. Analytical sets typically consisted of calibration standards, unfortified controls, fortified controls, and treated samples. A calibration standard was injected at the beginning and end of each analytical set. IR-4 Acetamiprid Petition for Strawberry and Other Low-Growing Berries Page 44 of 61

The total residues of acetamiprid ranged from 0.03 to 0.25 ppm in samples taken at 1 day after the last application. In the decline trial (CA*57), the residues declined from a mean of 0.23 ppm in samples taken at 1 day after the last application, to 0.19 ppm in samples taken at 3 days, to 0.15 ppm in samples taken at 5 days, to 0.09 ppm in samples taken at 9 days. See Table C.3 for additional information. The storage interval for field-treated samples in this study ranged from 6 to 109 days (see Table C.2). Storage stability samples were fortified with acetamiprid at 0.1003 ppm soon after the receipt of the samples by the analytical laboratory. The storage stability samples were held in frozen storage under similar conditions to the field generated samples. After 148 days of freezer storage, the storage stability samples were analyzed for acetamiprid. The recoveries for the storage stability samples were in the range 87% to 89%; see Table C.2. A concurrent recovery for a spike analyzed along with the storage stability samples was 92%. This data indicates that acetamiprid is stable under the conditions which the samples were held between harvest and analysis. The nature of the residues of acetamiprid is adequately understood, and an acceptable analytical method is available for enforcement purposes. The registration of this use would provide the growers with an effective insecticide. A. BACKGROUND INFORMATION The test substance used in the study was Assail 70 WP Insecticide. The active ingredient of the test substance used in this study is acetamiprid, of the class pyridylmethylamine. The nominal concentration of the active ingredient is 70%. The parent compound is the only compound mentioned in the tolerance expression (40CFR180.578). The samples were analyzed for acetamiprid only. IR-4 Acetamiprid Petition for Strawberry and Other Low-Growing Berries Page 45 of 61

Table A.1: Test Compound Nomenclature Compound: Acetamiprid Chemical Structure: C 10 H 11 ClN 4 Common Name: Acetamiprid Company Experimental Name: NI-25 IUPAC Name: (E)-N 1 -[(6-chloro-3-pyridyl)methyl]-N 2 -cyano-n 1 -methylacetamidine CAS Name: (1E)-N-[(6-chloro-3-pyridinyl)methyl]-N -cyano-n-methylethanimidamide CAS #: 135410-20-7 End-Use product/ep: Assail 70 WP Insecticide IR-4 Acetamiprid Petition for Strawberry and Other Low-Growing Berries Page 46 of 61

Table A.2. Physicochemical Properties Parameter Chemical: Melting point/range ph Density Water Solubility ( C) Solvent Solubility (mg/l at C) Vapour Pressure at C Dissociation Constant (pk a ): Octanol/Water Partition Coefficient Log (K ow ): UV/visible Absorption Spectrum: Table Intentionally Left Blank Value Reference IR-4 Acetamiprid Petition for Strawberry and Other Low-Growing Berries Page 47 of 61

B. Experimental Design B.1. Study Site Information Table B.1.1 Soil Characterization and Summary of Meteorological Conditions Trial Trial Location Soil characteristics Meteorological Comments Trial Start (City, State or Province) CEC (meq/100 ID Year Type %OM ph Rainfall Temperatures g) CA*56 Salinas, CA 2004 Sandy loam 2.3 7.8 12 Normal Normal CA*57 Salinas, CA 2004 Sandy loam 2.3 7.8 12 Normal Normal CA58 Madera, CA 2004 Loam 0.91 5.8 NA 1 Normal Normal FL26 Dover, FL 2004 Fine sand 2.1 6.8-7.0 NA 1 Normal Normal NJ14 Bridgeton, NJ 2004 Sandy loam 2.1 6.5 4.4 Above normal in April Above normal NS04 St. Edouard de Kent, NB 2004 Sandy loam 2.5 5.3 NA 1 Normal Normal ON01 Thorndale, ON 2004 Fine sandy loam 3.6 7.1 NA 1 Normal Normal OR08 Aurora, OR 2004 Loam 4.77 5.7 NA 1 Normal Normal QC11 St. Paul d Abbotsford, QC 2004 Loamy fine sand 3 6.4 11.4 Normal Normal WI07 Arlington, WI 2004 Silt loam 6.5 5.9 NA 1 Normal Normal 1 NA = Not Available IR-4 Acetamiprid Petition for Strawberry and Other Low-Growing Berries Page 48 of 61

Table B.1.2.1: Study Use Pattern Trial ID Trial Location (City, State or Province) CA*56 Salinas, CA 2004 CA*57 Salinas, CA 2004 CA58 Madera, CA 2004 FL26 Dover, FL 2004 NJ14 Bridgeton, NJ 2004 1 EP = End-use Product Application Trial Start Year EP 1 Timing Rate lb ai/a RTI 2 (days) Application Number Method Total Rate lb ai/a Tank Mix Adjuvants Assail 70 Mature fruit 0.130 --- 1 Foliar Broadcast Spray WP Mature fruit 0.130 7 2 Foliar Broadcast Spray 0.260 None NA Assail 70 Mature fruit 0.130 --- 1 Foliar Broadcast Spray WP Mature fruit 0.131 7 2 Foliar Broadcast Spray 0.261 None NA Assail 70 Mature and immature fruit 0.130 --- 1 Foliar Broadcast Spray WP Mature and immature fruit 0.130 7 2 Foliar Broadcast Spray 0.260 None NA Assail 70 Fruiting 0.134 --- 1 Foliar Directed Spray WP Fruiting 0.131 7 2 Foliar Directed Spray 0.265 None NA Assail 70 Fruiting 0.132 --- 1 Foliar Broadcast Spray WP Fruiting 0.132 6 2 Foliar Broadcast Spray 0.264 None NA 2 Retreatment Interval 3 Only applicable for cotton commodities. Harvest Procedures 3 IR-4 Acetamiprid Petition for Strawberry and Other Low-Growing Berries Page 49 of 61

Table B.1.2.2: Study Use Pattern Trial ID NS04 Trial Location (City, State or Province) St. Edouard de Kent, NB ON01 Thorndale, ON 2004 OR08 Aurora, OR 2004 Application Trial Start Year EP 1 Timing Rate lb ai/a RTI 3 (days) Application Number Method 2004 Assail 70 75% fruiting 0.131 2 --- 1 Foliar Broadcast Spray WP 90% fruiting 0.132 2 9 2 Foliar Broadcast Spray Assail 70 Vegetative 0.129 2 --- 1 Foliar Broadcast Spray WP Fruiting 0.129 2 7 2 Foliar Broadcast Spray Assail 70 Green and red fruit 0.129 --- 1 Foliar Directed Spray WP Ripe fruit 0.131 6 2 Foliar Directed Spray Total Rate lb ai/a Tank Mix Adjuvants 0.263 2 None Harvest Procedures 4 NA 0.258 2 None NA St. Paul Flowering to ripe fruit 0.132 2 --- 1 Foliar Broadcast Spray QC11 d Abbotsford, QC 2004 Assail 70 WP Fruiting 0.131 2 0.263 2 None NA 7 2 Foliar Broadcast Spray Assail 70 Fruiting 0.128 --- 1 Foliar Broadcast Spray WI07 Arlington, WI 2004 0.252 None NA WP Fruiting 0.124 6 2 Foliar Broadcast Spray 1 EP = End-use Product 2 For metric equivalents, see Field Data Summaries 3 Retreatment Interval 4 Only applicable for cotton commodities. 0.260 None NA IR-4 Acetamiprid Petition for Strawberry and Other Low-Growing Berries Page 50 of 61

Table B.1.3: Trial numbers and geographical locations Crop: Strawberry NAFTA Canada US Growing Region Submitted Required Submitted Required 1 1 1 0 1 1 1A 2 1 1 3 1 1 4 5 1 1 1 5A 0 2 1 2 1 5B 1 1 6 7 7A 8 9 10 3 3 11 12 0 3 1 1 1 13 14 15 16 17 18 19 20 21 Total 3 2,3 5 7 1 8 1 The USEPA requirement for a Region 1 trial was met by the data collected from the Canadian trial in New Brunswick. 2 The Canadian requirement for a Region 5A trial was met by the data collected from the US trial in Wisconsin. Wisconsin is in US Region 5, but is considered to be in Canadian Region 5A. 3 The Canadian requirement for a Region 12 trial was met by the data collected from the US trial in Oregon. IR-4 Acetamiprid Petition for Strawberry and Other Low-Growing Berries Page 51 of 61

B.2. Sample Handling and Preparation The samples were shipped to the analytical laboratory frozen either by ACDS freezer truck or by overnight air express packed in dry ice. All samples arrived frozen and intact at the analytical laboratory. The samples were checked in and stored frozen. The samples were ground with dry ice and then stored frozen till extraction and analysis. B.3. Analytical Methodology The samples were analyzed using a working method very similar to the reference method, KP-216R1: Preliminary LC/MS/MS Analytical Method for Determination of Assail 70 WP Insecticide (Acetamiprid) in Crop Matrices, written by Fenn Li and Paul Reibach, Cerexagri, 9/6/2003. Residues of acetamiprid are extracted from the ground strawberry samples using a solution of methanol:water (1:1, v/v). The extract is cleaned by solid phase extraction using Waters Oasis HLB, 6cc/200mg cartridges. The eluate is transferred to a volumetric flask and brought to the appropriate volume with water. The extract volume is adjusted to be within the calibrated volume range for instrumental analysis. The sample is then analyzed for acetamiprid by LC/MS/MS. Method suitability was evaluated both prior to sample analysis and concurrently with sample analysis. The method validation recoveries ranged from 82% to 101%. Concurrent recoveries obtained during sample analysis ranged from 88% to 103%. The LOD for the method was calculated to be 0.000768 ppm and the LOQ was calculated to be 0.00231 ppm. The lowest level of method validation (LLMV) for strawberry was 0.01003 ppm for acetamiprid. Additional information regarding method recoveries can be found in Table C.1. Analytical sets typically consisted of calibration standards, unfortified controls, fortified controls, and treated samples. A calibration standard was injected at the beginning and end of each analytical set. C. RESULTS AND DISCUSSION Application type, timing, rates and number of applications are summarized in Table B.1.2. At each trial, two foliar applications of the test substance 6-9 days apart were made to the treated plots. The application rates ranged from 0.124 to 0.134 lb ai/a per application for a total rate range of 0.252 to 0.265 lb ai/a per season (see Table B.1.2). All applications were made using appropriate spray equipment, and the spray volume was sufficient to provide adequate dispersal of the test substance. Sampling started in the untreated control plot and ended in the treated plot. At all the field trials, samples were harvested 1 day after the last application (see Table C.3). Additionally, at the CA*57 trial, duplicate samples were collected 3, 5, and 9 days after the last application. IR-4 Acetamiprid Petition for Strawberry and Other Low-Growing Berries Page 52 of 61

Table C.1: Summary of Recoveries Matrix Analyte Spike level (ppm) Sample size (n) Strawberry Acetamiprid 0.01003 6 Type of Recovery 1 MV 89 MV 87 MV 85 MV 86 MV 82 MV 86 Recoveries (%) Mean ±Std Dev. 86 2 Strawberry Acetamiprid 0.02006 1 CR 90 90 --- Strawberry Acetamiprid 0.1003 13 Strawberry Acetamiprid 1.003 4 MV 88 MV 88 MV 87 CR 94 CR 95 CR 96 CR 91 CR 88 CR 93 CR 89 CR 103 CR 90 CRSS 92 MV 100 MV 101 MV 100 CR 94 92 4 99 3 1 MV = Method Validation Recoveries; CR = Concurrent Recoveries; CRSS = Concurrent Recoveries, Storage Stability Table C.2: Summary of Storage Conditions Matrix (RAC or Extract) Analyte Storage Stability Recoveries (%) 87 Storage Temp. ( C) Maximum Actual Sample Storage Duration (days) Limit of Demonstrated Storage Stability (days) Strawberry Acetamiprid 87-25 to -15 109 148 89 IR-4 Acetamiprid Petition for Strawberry and Other Low-Growing Berries Page 54 of 61

Table C.3: Residue Data from Strawberry Field Trials Trial ID CA*56 Trial Location (City, State or Province) NAFTA Growing Region Trial Start Year Crop Variety Commodity Total Rate lbs ai/a 1 Residues from Treated Samples Acetamiprid Total PHI Max. (days) (ppm) (ppm) Salinas, CA 10 2004 Strawberry Ventana Fruit with cap removed 0.260 1 0.23 0.24 0.24 CA*57 Salinas, CA 10 2004 Strawberry Camarosa Fruit with cap removed 0.261 1 3 5 9 0.22 0.24 0.24 0.19 0.19 0.19 0.15 0.15 0.15 0.09 0.09 0.09 CA58 Madera, CA 10 2004 Strawberry Seascape Fruit with cap removed 0.260 1 0.11 0.11 0.11 FL26 Dover, FL 3 2004 Strawberry Festival Fruit with cap removed 0.265 1 0.25 0.22 0.25 NJ14 Bridgeton, NJ 2 2004 Strawberry Avalon Fruit with cap removed 0.264 1 0.06 0.06 0.06 NS04 St. Edouard de Kent, NB 1 2004 Strawberry Annapolis Fruit 3 0.263 2 1 0.09 0.09 0.09 ON01 Thorndale, ON 5 2004 Strawberry Mesiabi Fruit with cap removed 0.258 2 1 OR08 QC11 0.04 0.04 0.04 Aurora, OR 12 2004 Strawberry Totem Fruit with cap removed 0.260 1 0.13 0.10 0.13 St. Paul d Abbotsford, QC 5B 2004 Strawberry Jewel Fruit with cap removed 0.263 2 1 0.05 0.05 0.05 WI07 Arlington, WI 5/5A 2004 Strawberry Honeoye Fruit with cap removed 0.252 1 0.03 0.03 0.03 1 Treatment 02 consisted of 2 foliar applications of ASSAIL 70 WP Insecticide. 2 For metric equivalents see Field Data Summaries. 3 The field data book from this trial had no indication of cap removal. IR-4 Acetamiprid Petition for Strawberry and Other Low-Growing Berries Page 55 of 61

Table C.4: Summary of Residue Data from Strawberry Field Trials Total Application PHI Treated Sample Residue Levels (ppm) Commodity Treatment Rate, lb ai/a (days) Analyte n Min. Max. HAFT 1 Mean Std. Dev. Strawberry Assail 70 WP 0.252 to 0.265 1 Acetamiprid 20 0.03 0.25 0.24 0.12 0.08 Strawberry Assail 70 WP 0.261 3 Acetamiprid 2 0.19 0.19 0.19 0.19 --- Strawberry Assail 70 WP 0.261 5 Acetamiprid 2 0.15 0.15 0.15 0.15 --- Strawberry Assail 70 WP 0.261 8 Acetamiprid 2 0.09 0.09 0.09 0.09 --- 1 HAFT = Highest Average Field Trial. IR-4 Acetamiprid Petition for Strawberry and Other Low-Growing Berries Page 56 of 61

SECTION E Since it is unlikely that residues of acetamiprid in or on strawberry and other lowgrowing berries will exceed the proposed tolerances, methods for removing the residues are not necessary. IR-4 Acetamiprid Petition for Strawberry and Other Low-Growing Berries Page 57 of 61

SECTION F PROPOSED TOLERANCE FOR THE PESTICIDE CHEMICAL ACETAMIPRID USE IN OR ON STRAWBERRY AND OTHER LOW-GROWING BERRIES AMENDS 40 CFR 180.578 The petitioner, IR-4, on behalf of the Agricultural Experiment Stations of Michigan, North Carolina, and Pennsylvania requests the establishment of a tolerance for combined residues of the insecticide acetamiprid N1-[(6-chloro-3-pyridyl)methyl]- N2-cyano-N1-methylacetamidine in or on the following commodities: Proposed Tolerance Commodity (Parts per million, ppm) Strawberry 0.60 Bearberry 0.60 Bilberry 0.60 Blueberry, lowbush 0.60 Cloudberry 0.60 Cranberry 0.60 Lingonberry 0.60 Muntries 0.60 Partridgeberry 0.60 IR-4 Acetamiprid Petition for Strawberry and Other Low-Growing Berries Page 58 of 61

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SECTION G REASONABLE GROUNDS IN SUPPORT OF OUR PETITION FOR ACETAMIPRID ON STRAWBERRY AND OTHER LOW-GROWING BERRIES IR-4 Acetamiprid Petition for Strawberry and Other Low-Growing Berries Page 60 of 61

Section G The IR-4 Project received a request from the states of Michigan, North Carolina, and Pennsylvania for the clearance of acetamiprid in or on strawberry. Acetamiprid is wanted as a foliar application to control aphids, Japanese beetles, lygus bugs, plant bugs, thrips, and whiteflies in strawberry production. Strawberry is the representative commodity for Lowgrowing berry subgroup 13G that has been accepted at EPA. This subgroup includes bearberry, bilberry, lowbush blueberry, cloudberry, cranberry, lingonberry, muntries, and partridgeberry. Ten field trials were conducted in the USA and Canada to develop residue data in support of tolerances. The nature of the residues of acetamiprid is adequately understood, and an acceptable analytical method is available for enforcement purposes. Based on these results, the establishment of the tolerances proposed for strawberry and other lowgrowing berries in Section F of this volume would provide the growers with an effective insecticide for the control of aphids, Japanese beetles, lygus bugs, plant bugs, thrips, and whiteflies. IR-4 Acetamiprid Petition for Strawberry and Other Low-Growing Berries Page 61 of 61