Modification of the existing maximum residue levels for propaquizafop in various crops

Transcription

1 REASED PII ADPTED: 03 February 2016 PUBLISHED: 19 February 2016 doi: /j.efsa Abstract Modification of the existing maximum residue levels for propaquizafop in various crops European Food Safety Authority (EFSA) In accordance with Article 6 of Regulation (EC) o 396/2005, the evaluating Member State (EMS) Austria, received an application from the company Makhteshim Agan Industries Ltd to modify the existing maximum residue levels (MRL) for the active substance propaquizafop in cauliflowers and various root and oilseed crops. In addition, the EMS Italy received an application from the company ADAMA Quena.V. to modify the existing MRLs in head cabbages and the group lettuces and salad plants. Considering that propaquizafop is an ester variant of quizalofop and since two different MRL datasets are proposed for propaquizafop and quizalofop (including quizalofop-p) under Regulation (EC) o 396/2005, EFSA suggests the two following options: 1) to set specific MRL values for propaquizafop for the crops under consideration; 2) to delete the MRLs for propaquizafop from the EU legislation and to report all MRLs for all quizalofop ester variants in the EU legislation as quizalofop, considering that the current residue definition reported as quizalofop incl. quizalofop-p would have to be amended to quizalofop and quizalofop esters, including propaquizafop expressed as quizalofop (sum of isomers). Sufficient data were submitted to propose specific MRLs for propaquizafop for the crops under consideration, except for the group lettuces and salad plants since a sufficient number of trials on open leaf varieties of lettuce has not been provided to support an extrapolation. The deletion of the MRLs for propaquizafop as proposed under option 2 would only request to increase the MRL for mustard seeds from the limit of quantification (LQ) of 0.05 to 0.06 mg/kg. Based on the risk assessment results, EFSA concludes that the proposed uses of propaquizafop will not result in a consumer exposure exceeding the toxicological reference values and therefore is unlikely to pose a consumer health risk. European Food Safety Authority, 2016 Keywords: propaquizafop, quizalofop, various crops, MRL application, consumer risk assessment Requestor: European Commission Question number: EFSA-Q and EFSA-Q Correspondence: pesticides.mrl@efsa.europa.eu EFSA Journal 2016;14(2):4402

2 Suggested citation: EFSA (European Food Safety Authority), Reasoned opinion on the modification of the existing maximum residue levels for propaquizafop in various crops. EFSA Journal 2016;14(2):4402, 31 pp. doi: /j.efsa ISS: European Food Safety Authority, 2016 Reproduction is authorised provided the source is acknowledged. The EFSA Journal is a publication of the European Food Safety Authority, an agency of the European Union. 2 EFSA Journal 2016;14(2):4402

3 Summary In accordance with Article 6 of Regulation (EC) o 396/2005, the evaluating Member State (EMS) Austria, received an application from Makhteshim Agan Industries Ltd to modify some existing MRLs for the active substance propaquizafop. In addition, the EMS Italy received an application from the company ADAMA Quena.V. to modify the existing MRLs in head cabbages and the group lettuces and salad plants. Austria proposed to set MRLs at 0.1 mg/kg in celeriacs, parsnips, parsley roots, radishes, poppy seeds, soya beans and mustard seeds and at 0.5 mg/kg in cauliflowers. Italy proposed to increase the MRL from 0.2 to 0.3 mg/kg in head cabbages and from 0.1 to 0.2 mg/kg in lettuces and salad plants. Austria and Italy drafted evaluation reports in accordance with Article 8 of Regulation (EC) o 396/2005 which were submitted to the European Commission and forwarded to EFSA on 4 December 2013 and 9 ovember 2015 respectively. EFSA bases its assessment on the evaluation reports submitted by the EMS Austria and Italy. Since propaquizafop is an ester variant of the active substance quizalofop-p, the Draft Assessment Reports (DAR) prepared under Directive 91/414/EEC, the Commission Review Reports, the conclusions on the peer review of the pesticide risk assessment and reasoned opinions issued for both active substances propaquizafop and quizalofop-p were considered in this evaluation. The toxicological profile of propaquizafop was assessed in the framework of the peer review under Directive 91/414/EEC (hereafter peer review) and the data were sufficient to derive an acceptable daily intake (ADI) of mg/kg body weight (bw) per day. o acute reference dose (ARfD) was deemed necessary. Separate toxicological reference values were set for the other quizalofop ester variants. Expressed as quizalofop equivalent, the lowest ADI was proposed at mg/kg bw per day and the lowest ARfD at 0.08 mg/kg bw. The metabolism of propaquizafop in primary crops was investigated in the oilseeds/pulses (cotton, soybean), leafy (lettuce) and root (sugar beet) crop groups. The residue definitions for enforcement and risk assessment were proposed as sum propaquizafop and quizalofop, expressed as quizalofop (sum of isomers) in the conclusion of the peer review. Considering that once applied, all ester variants (including propaquizafop) are hydrolysed to quizalofop, EFSA proposed an overall residue definition covering all esters as sum quizalofop esters, quizalofop, expressed as quizalofop (sum of isomers). Several analytical methods were proposed to monitor propaquizafop residues in plants. Most of them refer to methods where propaquizafop residues are analysed and quantified as quizalofop (propaquizafop acid) and not as propaquizafop. Additional validation data were submitted in the framework of these MRL applications. Provisionally, EFSA proposes to conclude that sufficient enforcement methods are available, considering that all analytical methods for all ester variants will be reconsidered during the review of the existing MRLs under Article 12 of Regulation (EC) o 396/2005 (hereafter Article 12 MRL review) that will be initiated by 2016 for all quizalofop ester variants. The current residue definition set in Regulation (EC) o 396/2005 is limited to propaquizafop only. EFSA proposes the following options for the setting of MRLs: ption 1: MRLs are proposed as propaquizafop. ption 2: Since the residue in plants following the application of the active substance propaquizafop is quizalofop (as for the other ester variants), it is proposed to withdraw the MRLs set for propaquizafop in Regulation (EC) 396/2005 and to report the MRLs for all quizalofop ester variants under quizalofop, considering that the current residue definition quizalofop incl. quizalofop-p would have to be amended to sum quizalofop and quizalofop esters, including propaquizafop expressed as quizalofop (sum of isomers). Under option 1 and when expressed as propaquizafop equivalent, EFSA concludes that a sufficient number of residue trials were submitted to derive MRL proposals of 0.15 mg/kg on celeriacs, parsley roots and radishes, of 0.3 mg/kg on cauliflowers and head cabbages and of 0.08 mg/kg on poppy and mustard seeds and soya beans. In contrast, a sufficient number of trials conducted on open leaf varieties of lettuce has not been provided to propose an MRL for lettuces and salad plants. Under option 2, no changes in the MRL values currently listed for quizalofop under Regulation (EC) 396/2005 are requested, except for mustard seeds, whose MRL would need to be increased from limit of quantification (LQ) of 0.05 mg/kg to 0.06 mg/kg. 3 EFSA Journal 2016;14(2):4402

4 Processing studies on cauliflower and head cabbages were submitted. However, since standard hydrolysis studies on the nature of the residues of propaquizafop are not available, EFSA does not recommend the listing of the derived processing factors in Annex IV of Regulation (EC) 396/2005. Based on the available information, EFSA concludes that significant residue levels are unlikely to occur in rotational crops, provided that the active substance is used according to the proposed uses. The residues levels observed in the crops under consideration do not request an amendment of the MRLs for animal commodities listed as propaquizafop or as quizalofop in the current EU Regulations. The consumer risk assessment was performed with the revision 2 of the EFSA Pesticide Residues Intake Model (PRIMo). Two different assessments were conducted taking into account the two options proposed for the setting of MRLs for propaquizafop. ption 1: The chronic consumer risk assessment was conducted taking into account the median residue levels (STMR) derived for the crops under consideration in this reasoned opinion and the MRLs set for propaquizafop in the EU legislation for the other plant and animal commodities. Based on the ADI of mg/kg bw per day, no chronic concern was identified, the highest calculated intake being 30% of the ADI (UK, Toddler). An acute risk assessment was not conducted as the setting of an ARfD was concluded to be not necessary for propaquizafop. This assessment should however be considered as a large underestimation, since not considering the additional contribution to the consumer exposure resulting from the uses of the other quizalofop ester variants. ption 2: The consumer risk assessment was conducted considering all MRLs set for quizalofop under the current EU Regulation (except mustard seeds where the supervised trials median residue (STMR) and highest residue (HR) values were used as input values) and the lowest ADI and lowest ARfD derived during the peer review for the different quizalofop ester variants. Based on this worst case scenario and considering all possible uses of the different quizalofop esters variants, no intake concerns were identified for the consumers, the highest chronic intake accounting for 90% of the ADI (WH, cluster B) and the highest acute intake for the crops under consideration in the MRL applications for 33% of the ARfD for cauliflower (L child). EFSA concludes that the intended uses of propaquizafop on celeriacs, parsnips, parsley roots, radishes, cauliflowers, head cabbages, poppy seeds, mustard seeds and soya beans will not result in a consumer exposure exceeding the lowest toxicological reference values set for the different quizalofop ester variants and therefore are unlikely to pose a consumer health risk. Therefore, EFSA proposes to the risk managers to decide which of these two options should be considered for the setting of MRLs for propaquizafop. ption 1: Setting of MRLs for propaquizafop Code (a) Commodity Existing EU MRL Proposed EU MRL Comment/Justification Enforcement residue definition: propaquizafop Celeriacs 0.05* 0.15 EU and SEU. Extrapolation from trials on Parsnips 0.05* 0.15 carrots Parley roots 0.05* Radishes 0.05* Cauliflowers 0.05* 0.3 SEU only Head cabbages EU and SEU uses Lettuce & salad plants 0.1 no proposal Insufficient number of trials on open leaf varieties to support an extrapolation Poppy seeds 0.05* 0.08 EU and SEU. Extrapolation from trials on Mustard seeds 0.05* 0.08 rapeseeds Soyabeans 0.05* 0.08 EU only. Extrapolation from trials on rapeseeds. EU: northern Europe; SEU: southern Europe (a): Commodity code number according to Annex I of Regulation (EC) 396/2005 *: indicates that the MRL is set at the limit of analytical quantification (LQ) 4 EFSA Journal 2016;14(2):4402

5 ption 2: Deletion of MRLs for propaquizafop from Regulation (EC) o 396/2005. MRLs for all quizalofop ester variants reported under quizalofop Since the residue in plants following the application of the active substance propaquizafop is quizalofop (as for the other ester variants), it is proposed to withdraw the MRLs set for propaquizafop under Regulation (EC) 396/2005 and to report the MRLs for all quizalofop ester variants under quizalofop, considering that the current residue definition quizalofop incl. quizalofop-p would have to be amended to quizalofop and quizalofop esters, including propaquizafop, expressed as quizalofop (sum of isomers). o changes in the MRL values currently listed for quizalofop under Regulation (EC) 396/2005 are requested since, when expressed as quizalofop equivalent, MRL values for propaquizafop are all below the MRL values reported for quizalofop in the EU Legislation, except for mustard seeds whose MRL would need to be increased from the LQ of 0.05 mg/kg to 0.06 mg/kg. Code (a) Commodity Existing EU MRL Proposed EU MRL Comment/Justification Enforcement residue definition: quizalofop and quizalofop esters, including propaquizafop, expressed as quizalofop (sum of isomers) Mustard seeds 0.05* 0.06 EU and SEU. Extrapolation from trials on rapeseeds. EU: northern Europe; SEU: southern Europe (a): Commodity code number according to Annex I of Regulation (EC) 396/2005 *: indicates that the MRL is set at the limit of analytical quantification (LQ) 5 EFSA Journal 2016;14(2):4402

6 Table of contents Abstract... 1 Summary... 3 Background... 7 Terms of reference... 7 The active substance and its use pattern... 7 Assessment Method of analysis Methods for enforcement of residues in food of plant origin Methods for enforcement of residues in food of animal origin Mammalian toxicology Residues ature and magnitude of residues in plant Primary crops Rotational crops ature and magnitude of residues in livestock ption 1: Propaquizafop MRL proposals for products of animal origin ption 2: Quizalofop MRL proposals for animal matrices Consumer risk assessment Conclusions and recommendations References Abbreviations Appendix A Good Agricultural Practice (GAPs) Appendix B Pesticide Residue Intake Model (PRIMo) Appendix C Used compound codes EFSA Journal 2016;14(2):4402

7 Background Regulation (EC) o 396/ establishes the rules governing the setting of pesticide MRLs at European Union level. Article 6 of that Regulation lays down that any party having a legitimate interest or requesting an authorisation for the use of a plant protection product in accordance with Council Directive 91/414/EEC 2, repealed by Regulation (EC) o 1107/2009 3, shall submit to a Member State, when appropriate, an application to set a MRL in accordance with the provisions of Article 7 of that Regulation. Austria, hereafter referred to as the evaluating Member State (EMS) Austria, received an application from the company Makhteshim Agan Industries Ltd 4 to modify the existing MRLs for the active substance propaquizafop in various root and tuber crops, cauliflowers and various oilseeds. In addition, Italy hereafter referred to as the evaluating Member State (EMS-IT), received an application from the company ADAMA Quena.V. 5 to modify the existing MRLs in head cabbages and the group lettuces and salad plants. These applications were notified to the European Commission and EFSA and were subsequently evaluated by the EMSs in accordance with Article 8 of the Regulation. After completion, the evaluation reports were submitted to the European Commission who forwarded the applications and the evaluation reports to EFSA on 4 December 2013 and 9 ovember 2015, respectively. Applications were included in the EFSA Register of Questions with the following reference number and the subject: EFSA-Q : EFSA-Q : Propaquizafop - Application to modify the existing MRLs in various crops. Propaquizafop - Application to modify the existing MRLs head cabbage, lettuce and other salad crops. Austria proposed to raise the existing MRL of propaquizafop from the limit of quantification (LQ) of 0.05 mg/kg to 0.5 mg/kg in cauliflowers and to 0.1 mg/kg in celeriacs, parsnips, parsley roots, radishes, poppy and mustard seeds and soya beans. Italy proposed to increase the MRLs for head cabbages from 0.2 to 0.3 mg/kg and from 0.1 to 0.2 mg/kg for lettuces and salad plants. EFSA proceeded with the assessment of the applications and the evaluation reports as required by Article 10 of the Regulation. Terms of reference In accordance with Article 10 of Regulation (EC) o 396/2005, EFSA shall, based on the evaluation report provided by the evaluating Member State, provide a reasoned opinion on the risks to the consumer associated with the application. In accordance with Article 11 of that Regulation, the reasoned opinion shall be provided as soon as possible and at the latest within three months (which may be extended to six months where more detailed evaluations need to be carried out) from the date of receipt of the application. Where EFSA requests supplementary information, the time limit laid down shall be suspended until that information has been provided. The active substance and its use pattern Propaquizafop is the IS common name for 2-isopropylidenamino-oxyethyl (R)-2-[4-(6-chloroquinoxalin-2-yloxy)phenoxy]propionate (IUPAC). Propaquizafop is an ester variant of the active substance quizalofop-p (R-isomer) which is approved for use as herbicide in Europe, together with the 1 Regulation (EC) o 396/2005 of the Parliament and of the Council of 23 February 2005 on maximum residue levels of pesticides in or on food and feed of plant and animal origin and amending Council Directive 91/414/EEC. J L 70, , p Council Directive 91/414/EEC of 15 July 1991 concerning the placing of plant protection products on the market. J L 230, , p Regulation (EC) o 1107/2009 of the European Parliament and of the Council of 21 ctober 2009 concerning the placing of plant protection products on the market and repealing Council Directives 79/117/EEC and 91/414/EEC. J L 309, , p Makhteshim Agan Industries Ltd., Golan Street, Airport City, Israel. 5 ADAMA Quena.V., Pos Cabai office Park, Unit 13, P.. Box 403, Curacao, etherlands Antilles. 7 EFSA Journal 2016;14(2):4402

8 other ester variants quizalofop-p-ethyl and quizalofop-p-tefuryl. The chemical structures of propaquizafop, quizalofop ester variants and their main metabolites are reported in Appendix C. Propaquizafop belongs to the class of aryloxyphenoxypropionate herbicides (commonly called FPs ), such as diclofop and fluazifop-p. They are absorbed by foliage and translocated into plants. They interfere with the synthesis of fatty acids by competitively binding to the acetyl-coenzyme A carboxylase (ACCase). Propaquizafop and the ester variants quizalofop-p-ethyl and quizalofop-p-tefuryl were evaluated in the framework of Directive 91/414/EEC with Italy and Finland designated as rapporteur Member States (RMS). The Draft Assessment Report (DAR) of propaquizafop (Italy, 2005) and quizalofop-p-ethyl and quizalofop-p-tefuryl (Finland 2007a, 2007b) have been peer reviewed and EFSA conclusions are available (EFSA, 2008a, 2008b). These active substances were included in Annex I of this Directive by Directive 2009/37/EC 6 which entered into force on 1 December In accordance with Regulation (EU) o 540/ propaquizafop, quizalofop-p-ethyl and quizalofop-p-tefuryl are approved under Regulation (EC) o 1107/2009, repealing Directive 91/414/EEC. The EU MRLs for propaquizafop are established in Annex IIIA of Regulation (EC) o 396/2005. EFSA reasoned opinions on the modification of MRLs for propaquizafop have not been published since the entry into force of this Regulation. The existing EU MRLs for propaquizafop on celeriac, parsnips, parsley roots, radishes, cauliflowers, poppy seeds, soya beans and mustard seeds are set at the LQ of 0.05 mg/kg. For head cabbages and lettuces and salad plants, MRLs are set at 0.2 and 0.1 mg/kg respectively. The review of the existing MRLs for propaquizafop according to Article 12 of Regulation (EC) o 396/2005 (hereafter Article 12 MRL review) is expected to be initiated by 2016 and will consider in parallel all quizalofop ester variants; propaquizafop, quizalofop-p- ethyl and quizalofop-p-tefuryl. Codex Alimentarius has not established CXLs for propaquizafop and for quizalofop ester variants. The details of the GAPs supported by the applicant in the framework of the current MRL application are reported in Appendix A. Assessment EFSA bases its assessment on the evaluation reports submitted by the EMS-AT (Austria, 2013) and EMS-IT (Italy, 2015), the Draft Assessment Reports (DAR) on propaquizafop (Italy, 2005) and on quizalofop-p-ethyl and quizalofop-p-tefuryl (Finland, 2007a, 2007b) prepared under Council Directive 91/414/EEC, the Commission Review Reports on propaquizafop (European Commission, 2009) and quizalofop-p (European Commission, 2010b), the conclusions on the peer review of the pesticide risk assessment of the active substances propaquizafop (EFSA, 2008a) and quizalofop-p (EFSA, 2008b) and a previously issued reasoned opinion on quizalofop-p (EFSA, 2012). The assessment is performed in accordance with the legal provisions of the Uniform Principles for the Evaluation and the Authorisation of Plant Protection Products adopted by Commission Regulation (EU) o 546/ and the currently applicable guidance documents relevant for the consumer risk assessment of pesticide residues (European Commission, 1996, 1997a, 1997b, 1997c, 1997d, 1997e, 1997f, 2000, 2010a, 2010c, 2015; ECD, 2009, 2011). 6 Commission Directive 2009/37/EC of 23 April 2009 amending Council Directive 91/414/EEC to include chlormequat, copper compounds, propaquizafop, quizalofop-p, teflubenzuron and zeta-cypermethrin as active substances. J L 104, , p Commission Implementing Regulation (EU) o 540/2011 of 23 May 2011 implementing Regulation (EC) o 1107/2009 of the European Parliament and of the Council as regards the list of approved active substances. J L 153, , p Commission Regulation (EU) o 546/2011 of 10 June 2011 implementing Regulation (EC) o 1107/2009 of the European Parliament and of the Council as regards uniform principles for evaluation and authorisation of plant protection products. J L 155, , p EFSA Journal 2016;14(2):4402

9 1. Method of analysis 1.1. Methods for enforcement of residues in food of plant origin Different analytical methods were reported in the DAR (Italy, 2005) and the evaluation reports (Austria, 2013; Italy, 2015) to analyse propaquizafop residues in plant commodities. - The methods reported in the DAR were concluded to be not sufficiently validated during the peer review (EFSA, 2008a). Globally, these methods include a hydrolysis step to convert propaquizafop and its metabolites quizalofop and quizalofop-phenol to a common moiety CGA which is further quantified by GC/PD, GC/MS or HPCL/UV. Alternatively, methods to quantify propaquizafop and quizalofop separately by HPLC/MS/MS were also reported. - A method to monitor residues of propaquizafop in plants according to the residue definition proposed in the conclusion of the peer review was assessed under the current MRL application (Austria, 2013; Italy 2015). The method involves the hydrolysis of propaquizafop to quizalofop and the quantification of quizalofop by HPLC-MS/MS. This method was validated in high water (apple, tomato) and high oil (oilseed rape) content commodities with an LQ of mg/kg. An interlaboratory validation (ILV) is however not available. All reported methods are not stereo-selective and therefore, propaquizafop or quizalofop isomers are quantified together. Moreover, these methods are supposed to analyse not only for propaquizafop, but for total residues including propaquizafop, quizalofop and also quizalofop-phenol for some of them. Therefore, they are more appropriate to analyse propaquizafop residues according to the residue definition proposed in the conclusion of the peer review than to analyse samples according to the residue definition reported under Regulation (EC) 396/2005 and limited to propaquizafop only. Finally and referring to the EU Reference Laboratories (EURL) database, the Quick, Easy, Cheap, Effective, Rugged, and Safe (QuEChERS) analytical method (CE, 2008) using HPLC-MS/MS quantification has been validated to analyse propaquizafop in high water, high acid and high oil content matrices at LQs in the range of or 0.01 mg/kg (EURL). In addition, a QuEChERS variant method involving an alkaline hydrolysis step where propaquizafop residues are analysed as quizalofop is also available, but with limited validation data in high water, high oil and dry/starch matrices. In conclusion the availability of a fully validated analytical method to monitor propaquizafop residues in all matrix groups according to the current residue definition or the residue definition proposed in the conclusion of the peer review cannot be confirmed. EFSA proposes that residue definitions for all quizalofop esters and the availability of ad-hoc analytical methods are reconsidered in the framework of the review of the existing MRL under the Article 12 Regulation (EC) 396/2005, expected to be initiated in Methods for enforcement of residues in food of animal origin Analytical enforcement methods for the determination of propaquizafop residues in commodities of animal origin were not assessed in the framework of this application as no changes are proposed to the MRLs currently set for animal commodities. 2. Mammalian toxicology The toxicological profile of propaquizafop and the other ester variants was assessed in the framework of the peer review under Directive 91/414/EEC (EFSA, 2008a, 2008b). Proposed toxicological reference values are compiled in Table 1. Considering that the residues of concern for risk assessments were expressed as quizalofop in the conclusion of the peer review (EFSA, 2008a), the lowest ADI set for quizalofop-p-ethyl (0.009 mg/kg bw per day) and the lowest ARfD set for quizalofop-p-tefuryl (0.1 mg/kg bw) were corrected by their molecular weights 9 to a value of mg/kg bw day and 0.08 mg/kg bw respectively, to be 9 Molecular weight propaquizafop: 443.9; quizalofop and quizalofop-p: 344.8; quizalofop-p-ethyl: 372.8; quizalofop-ptefuryl: EFSA Journal 2016;14(2):4402

10 expressed as quizalofop equivalent. These values were taken into account to conduct an overall consumer risk assessments considering all quizalofop ester variants (see Section 4). Table 1: verview of the toxicological reference values set for the different ester variants Source Year Value Study Safety factor Propaquizafop ADI EC mg/kg bw per day Chronic mouse 100 ARfD EC 2009 ot necessary. Quizalofop-P-ethyl ADI EC mg/kg bw per day 2-year rat (a) 100 ARfD EC 2010 ot necessary. Quizalofop-P-tefuryl ADI EC mg/kg bw per day 2-year rat 100 ARfD EC mg/kg bw Rat development 100 (a): The ADI of quizalofop-p-ethyl (R-isomer of quizalofop) was derived using the racemate (EFSA, 2008b). All metabolites identified in the metabolism studies were not considered of higher toxicity than parent, and therefore concluded to be covered by the reference values set for propaquizafop (EFSA, 2008a). 3. Residues 3.1. ature and magnitude of residues in plant Primary crops ature of residues The metabolism of propaquizafop in primary crops was evaluated in the framework of the peer review under Directive 91/414/EEC. Studies were performed using 14 C-propaquizafop either labelled on the phenyl or the quinoxaline moieties in the leafy, root and pulses/oilseeds crop groups. The overview of the metabolism study designs is presented in Table 2. Table 2: Summary of available metabolism studies in plants Crop groups Crops Application Sampling (b) Comments Leafy Lettuce Foliar, g/ha 77 DAT Root Sugar beet Foliar, g/ha 84 DALA Pulses/ilseeds Soya bean nto leaf (a), g/ha, BBCH 13 0 to 28 DAT Foliar (a), g/ha, BBCH , 14; 8, 15 DAT Foliar, g/ha 66, 100 DALA Cotton nto leaf, 180 g/ha, BBCH 13, 0 to 51 DAT Foliar (a), g/ha, BBCH 14 6, 12, 22 DAT Foliar, g/ha 20 to 44 DALA (a): o-glp study since conducted prior to the implementation of GLP requirements. (b): DAT: days after treatment, DALA: days after the last application The metabolism of propaquizafop in plants proceeds primarily by the hydrolysis of the ester link to yield quizalofop, which generally represents the major component of the residues, accounting for 5% to 35% of the total radioactive residues (TRR) at harvest. Propaquizafop was only observed in significant proportions in immature plant samples collected within 15 days following the application and also in mature soya beans and sugar beet roots but in low proportions (ca. 7% TRR). Having regard to some deficiencies, clarification on the uncharacterised radioactivity in the leaves and roots of sugar beet and green parts and seeds of cotton or new metabolism studies in a root crop and a pulses/oilseeds crop were requested in the conclusion of the peer review (EFSA, 2008a). Provisionally, based on the propaquizafop metabolism studies and pending the submission of the requested data, the residue definition for monitoring and risk assessment were proposed as sum of 10 EFSA Journal 2016;14(2):4402

11 propaquizafop and quizalofop, expressed as quizalofop (sum of isomers) in the conclusion of the peer review (EFSA, 2008a). Since it was clear from the additional metabolism studies conducted with the other esters (quizalofopethyl, quizalofop-p-ethyl, quizalofop-p-tefuryl) that, once quizalofop formed after hydrolysis of the ester link, the metabolic pathways of the different esters in plants are similar, an overall residue definition for monitoring and risk assessment covering all ester variants of quizalofop was initially proposed as sum of quizalofop-esters, quizalofop and quizalofop conjugates expressed as quizalofop (sum of isomers) in the conclusions of the peer review. However, since conjugates were mainly detected in immature plants shortly after application, EFSA concluded that the inclusion of conjugates in the residue definitions, especially for monitoring, was not necessary (EFSA, 2008a, 2008b). It is noted that the current residue definition set under Regulation (EC) o 396/2005 is different and restricted to propaquizafop only. It should be highlighted that a full re-assessment of available metabolism studies for all quizalofop ester variants (including propaquizafop) will be performed in framework of the Article 12 MRL review. Magnitude of residues In the submitted residue trials conducted with the active substance propaquizafop, the vast majority of the samples were analysed and quantified for quizalofop and therefore, residues were reported in the study reports as quizalofop equivalent (propaquizafop acid equivalent). When requested, these values were expressed as propaquizafop by EFSA, considering the respective molecular weights. These data are therefore not representative of the residue definition reported under Regulation (EC) o 396/2005 which supposes the samples to be analysed as propaquizafop. In contrast, they are fully appropriate for conducting a consumer risk assessment since the metabolism studies have shown quizalofop to be the relevant residues in plants following application of the active substance propaquizafop. Samples from six trials conducted on carrots (2 northern Europe (EU) and 4 southern Europe (SEU)) were analysed and quantified as propaquizafop. Residues were all below the LQ of 0.01 mg/kg. In contrast, positive residues (0.012 to mg/kg quizalofop equivalent) were measured in five northern trials when samples are analysed as quizalofop. These data confirm the metabolism studies where it was concluded that all quizalofop esters are rapidly hydrolysed in plants and therefore that the residues in plants are not the esters but quizalofop and further degradation components. Having regard to the abovementioned comments, EFSA proposes the following two options for the setting of MRLs for propaquizafop: ption 1: MRLs are proposed and expressed as propaquizafop and derived from the residue trials where samples were analysed as quizalofop. Trials where samples were analysed as propaquizafop are disregarded considering that: - The enforcement analytical methods submitted by the applicants in the framework of the peer review and Article 10 procedures refer to methods where samples were analysed and quantified as quizalofop. Therefore, the MRLs already reported in the EU legislation were derived from trials considering quizalofop residues and not propaquizafop residues alone. - The residues relevant for consumer risk assessments (quizalofop) are not taken into account when samples are analysed as propaquizafop. ption 2: Since the residue of concern in plants following the application of the active substance propaquizafop is quizalofop (as for the other ester variants), it is proposed to withdraw the MRLs set for propaquizafop under Regulation (EC) 396/2005 and to report the MRLs for all quizalofop ester variants under quizalofop, considering that the current residue definition reported as quizalofop incl. quizalofop-p would have to be amended to quizalofop and quizalofop esters, including propaquizafop expressed as quizalofop (sum of isomers). Moreover, since following application, residues in plants are mostly recovered as quizalofop and not as esters, it is not possible to conclude after analyses whether the residues result from the use of the active substance propaquizafop or from the uses of another ester variant EFSA Journal 2016;14(2):4402

12 As already mentioned, the Article 12 MRL review will be initiated for all quizalofop esters in 2016 and therefore, a consolidated review will be proposed in the framework of this procedure. Pending the outcomes of the Article 12 MRL review, EFSA proposes to the risk managers to decide whether option 1 or option 2 should be considered for the setting of MRLs for the crops under consideration in this reasoned opinion. ption 1: MRLs proposed as propaquizafop Since residue data were reported as quizalofop equivalent (propaquizafop acid equivalent) in the residue trial reports, residue levels and MRL proposals in Table 3 were reported as quizalofop equivalent. MRL proposals as propaquizafop equivalent (reported within brackets) were calculated using the ECD MRL calculator (ECD, 2011) following conversion of the individual residue level to propaquizafop equivalent. a. Celeriacs, parsnips, parsley roots, radishes GAP: g/ha, PHI 30 days The applicant proposes to derive MRLs for celeriacs, parsnips, parsley roots and radishes by extrapolation from residue trials conducted on carrots Seven residue trials on carrots conducted in northern EU with samples analysed for as quizalofop were submitted. All trials were conducted in compliance with the supported GAP. Residues at harvest, 27 to 31 days after applications, were in the range of <0.01 to 0.06 mg/kg resulting in an MRL proposal of 0.09 mg/kg (0.15 mg/kg propaquizafop equivalent). Since celeriacs, parsnips, parsley roots and radishes are minor crops in EU and considering the extrapolation rules reported in the guideline SAC 7525/VI/95 rev. 10.1, EFSA concludes that the residue dataset is sufficient to propose an MRL of 0.15 mg/kg (propaquizafop equivalent) for northern EU, by extrapolation from trials on carrots. An MRL is not proposed to support the uses in SEU, since samples from the four submitted trials were not analysed as quizalofop, but as propaquizafop and since SEU GAPs were defined for parsley roots only and not for the other crops. b. Cauliflowers EU GAP: g/ha, PHI 30 days SEU GAP: g/ha, PHI 30 days Eight northern trials on cauliflower in which samples were analysed for quizalofop were submitted. All trials were overdosed (+27% to +39%) since conducted with a single application at 190 to 208 g/ha. Residue values were therefore scaled to the nominal application rate of 150 g/kg (scaling factors of 0.72 to 0.79) to derive an MRL proposal of 0.2 mg/kg (0.3 mg/kg propaquizafop equivalent). nly six residue trials conducted according to the SEU GAP were submitted. Since cauliflowers are major crops in SEU, the number of trials is not sufficient to derive an MRL proposal to cover the uses of propaquizafop on cauliflower in SEU. c. Head cabbages EU GAP: g/ha, PHI 30 days SEU GAP: g/ha, PHI 30 days Thirteen northern trials were submitted where samples were analysed for quizalofop. All trials were overdosed (+24% to +37%) since conducted with a single application at 186 to 205 g/ha. Residue values were therefore scaled to the nominal application rate of 150 g/kg (scaling factors of 0.73 to 0.81) to derive an MRL proposal of 0.1 mg/kg (0.15 mg/kg propaquizafop equivalent). Four southern residue trials conducted with an application rate of 184 to 202 g/ha were submitted. Since head cabbage is a minor crop in SEU, the number of trials is sufficient to derive an MRL proposal of 0.3 mg/kg (0.3 mg/kg propaquizafop equivalent) to cover the uses of propaquizafop in SEU. An MRL of 0.3 mg/kg (0.3 mg/kg propaquizafop equivalent) is proposed to cover the EU and SEU uses of propaquizafop on head cabbages. d. Lettuces and salad plants SEU GAP: g/ha, PHI 25 days In support of an extrapolation to the group lettuces and salad plants, eight SEU outdoor trials (Italy, France) were provided. All samples were analysed and quantified for quizalofop. EFSA concludes that the submitted dataset does not allow an extrapolation as requested since: 12 EFSA Journal 2016;14(2):4402

13 - ne trial has to be disregarded as not conducted according to the supported GAP, since performed with an application rate of 100 g/ha and since the proportionality approach cannot be applied to residue levels below the LQ (<0.05 mg/kg propaquizafop equivalent) - Five trials only were conducted on open leaf varieties. Finally, a total of seven trials of which five conducted on open leaf varieties are available while, according to the SAC 7525/VI/95 rev guideline (European Commission, 2015), a total of eight trials on open leaf varieties are requested to support an extrapolation to the whole group lettuces and salad plants. e. Poppy seeds, mustard seeds, soya beans EU and SEU GAP: g/ha, PHI 90 days The applicant proposes to derive MRLs for poppy seeds, mustard seeds and soya beans by extrapolation form residue trials conducted on rapeseeds. Ten northern residues trials on rapeseed with samples analysed for quizalofop were submitted. All trials were overdosed (+25% to +37%) since conducted with a single application at 187 to 207 g/ha. Data were scaled to the nominal application rate of 150 g/ha (scaling factors in the range of 0.72 to 0.80). In some locations, treatments at two different BBCH growth stages were investigated (BBCH 39 and BBCH 51) and the highest level was considered for MRL calculation. Based on this dataset, an MRL proposal of 0.06 mg/kg is derived for EU (0.08 mg/kg propaquizafop equivalent). Four southern trials only were submitted with all residue levels below the LQ of 0.01 mg/kg. Since poppy and mustard seeds are minor crops, the datasets are sufficient to extrapolate an MRL proposal of 0.06 mg/kg (0.08 mg/kg propaquizafop equivalent) to these crops and covering the EU and SEU uses. In contrast, soya bean is a major crop in EU and SEU and therefore no sufficient trials were submitted to cover the extrapolation and the uses of propaquizafop in southern EU. The results of the residue trials, the related risk assessment input values (highest (HR) and median (STMR) residue levels) and the MRL proposals are summarised in Table 3. Storage stability of propaquizafop residues in plant matrices was investigated during the peer review (Italy, 2005). Residues were found to be stable at -18 C for up to 24 months in high water (tomato), high water/starch (carrot, sugar beet) and high oil (soya bean, rapeseed) content matrices. As the supervised residue trial samples were stored for less than 9 months prior to analyses, it is concluded that the data are valid with regard to storage stability. According to the EMS, the analytical methods used to analyse the trial samples as quizalofop were sufficiently validated and fit for purpose (Austria, 2013; Italy, 2015). EFSA concludes that the submitted data are sufficient to derive the following MRL proposals (expressed as propaquizafop equivalent): 0.15 mg/kg Celeriacs, parsnips, parsley roots and radishes, by extrapolation from trials on carrots and covering the EU uses only 0.3 mg/kg Cauliflowers, EU uses only 0.3 mg/kg Head cabbages, EU and SEU 0.08 mg/kg Poppy and mustard seeds, by extrapolation from trials on rapeseed and covering the EU and SEU uses 0.08 mg/kg Soya beans, EU uses only In contrast, no sufficient trials were submitted to cover the uses of propaquizafop on celeriacs, parsnips, parsley roots, radishes and cauliflowers in southern EU, to propose an MRL for the group lettuces and salad plants and to derive an MRL on soya beans in SEU EFSA Journal 2016;14(2):4402

14 Table 3: verview of the available residues trials data Commodity (GAPs) Region (a) Individual trial results (b) Comments MRL proposal HR (c) STMR (b) Trials were conducted with propaquizafop but samples analysed for quizalofop and residues expressed as quizalofop equivalent in the study reports and in the table here below. MRL, HR and STMR as propaquizafop equivalent are reported within brackets, based on a molecular weight of (quizalofop) and (propaquizafop). Carrots (1 150 g/ha, PHI 30 days) EU 2 <0.01; 0.012; 0.016; 0.017; 0.025; MRL ECD : 0.09/0.1 (quiz.); 0.12/0.15 (propaquiz.) Extrapolation to celeriacs, parsnips, parsley roots and radishes 0.1 (0.15) (0.079) (0.021) Cauliflowers (1 150 g/ha, PHI 30 days) Cauliflowers (1 200 g/ha, PHI 30 days) Head cabbage (1 150 g/ha, PHI 30 days) Head cabbage (1 200 g/ha, PHI 30 days) Lettuce (1 150 g/ha, PHI 25 days) Rape seed (1 150 g/ha, PHI 90 days) EU 0.013; 0.017; 0.025; 0.030; 0.041; 0.044; 0.100; (scaled values) All trials overdosed, conducted at 190 to 208 g/ha. Data have been scaled to 150 g/ha MRL ECD : 0.20/0.2 (quiz.); 0.25/0.3 (propaquiz.) SEU 0.02; 0.021; 0.077; 0.110, 0.147; Cauliflower is a major crop in SEU and therefore insufficient trials were submitted to derive an MRL proposal. EU 4 <0.01, 0.012, 0.013, 0.014, 0.017, 0.018, 0.020, 0.023, 0.039, (scaled values) All trials overdosed, conducted at 186 to 205 g/ha. Data have been scaled to 150 g/ha MRL ECD : 0.1/0.1 (quiz.); 0.13/0.15 (propaquiz.) 0.2 (0.3) no proposal 0.1 (0.15) SEU 0.018, , LMR ECD : 0.22/0.3 (quiz.); 0.29/0.3 (propaquiz.) 0.3 (0.3) SEU 2 <0.01, 2 <0.02, 2 <0.02, 0.07 Underlined values: trials on open leaf varieties. Extrapolation to the whole group Lettuce and salad plants not recommended, insufficient number of trials on open leaf varieties. EU 5 <0.01, 0.011; 0.014; 0.015; 0.017; (scaled values) All trials were overdosed since conducted at 187 to 207 g/ha. Data have been scaled to 150 g/ha MRL ECD : 0.06/0.06 (quiz.); 0.08/0.08 (propaquiz.) Extrapolation to poppy and mustard seeds (EU and SEU) and soya beans (EU only). no proposal 0.06 (0.08) (0.140) (0.104) (0.144) (0.060) SEU 4 < * (a): EU: utdoor trials conducted in northern Europe, SEU: utdoor trials conducted in southern Europe, Indoor: indoor EU trials or Country code: if non-eu trials. (b): Individual residue levels considered for MRL calculation are reported in ascending order (2 <0.01, 0.01, , 0.04, 0.08, , 0.15, 0.17) and expressed a quizalofop equivalent, (c): HR: Highest residue level as quizalofop equivalent (as propaquizafop equivalent within brackets). (d): STMR: Median residue level as quizalofop equivalent (as propaquizafop equivalent within brackets) (0.045) (0.017) (0.035) (0.012) 14 EFSA Journal 2016;14(2):4402

15 ption 2: MRLs for all quizalofop esters (including propaquizafop) reported as quizalofop. As explained here above, this second option proposes to withdraw the MRLs set for propaquizafop in Regulation (EC) 396/2005 and to report MRLs for all quizalofop ester variants under quizalofop, considering that the current residue definition set as quizalofop incl. quizalofop-p would have to be amended to quizalofop and quizalofop esters, including propaquizafop, expressed as quizalofop (sum of isomers). The MRLs currently into force for propaquizafop and quizalofop in the EU legislation and listed in Regulations (EU) o 839/ and (EU) o 500/ respectively, are summarised in Table 4. MRLs for propaquizafop have been recalculated as quizalofop equivalent and the MRLs proposed for the different crops under option 1, inserted in this table are highlighted in bold. When expressed as quizalofop equivalent, all MRLs set for propaquizafop in Regulation (EU) o 839/2008 are lower than the MRLs set for quizalofop in Regulation (EU) o 500/2013 and therefore, covered by the MRLs and LQs reported for quizalofop, with a single exception: the MRL of 0.06 mg/kg proposed for mustard seeds (0.08 mg/kg propaquizafop equivalent) is slightly higher than the LQ of 0.05 mg/kg set for quizalofop. Providing that the MRL for mustard seeds is increased from 0.05* mg/kg to 0.06 mg/kg and the residue definition for quizalofop amended to quizalofop and quizalofop esters, including propaquizafop, expressed as quizalofop (sum of isomers) it can be concluded that the withdrawal of all MRLs of propaquizafop in the EU legislation are covered by the MRLs set for quizalofop in Regulation (EU) o 500/ Commission Regulation (EC) o 839/2008 of 31 July 2008 amending Regulation (EC) o 396/2005 of the European Parliament and of the Council as regards Annexes II, III and IV on maximum residue levels of pesticides in or on certain products 11 Commission Regulation (EU) o 500/2013 of 30 May 2013 amending Annexes II, III and IV to Regulation (EC) o 396/2005 of the European Parliament and of the Council as regards maximum residue levels for acetamiprid, Adoxophyes orana granulovirus strain BV-0001, azoxystrobin, clothianidin, fenpyrazamine, heptamaloxyloglucan, metrafenone, Paecilomyces lilacinus strain 251, propiconazole, quizalofop-p, spiromesifen, tebuconazole, thiamethoxam and zucchini yellow mosaik virus - weak strain in or on certain products 15 EFSA Journal 2016;14(2):4402

16 Table 4: MRLs in the EU legislation for quizalofop and propaquizafop (a) Code individual products Quizalofop MRLs Propaquizafop MRLs expressed as quizalofop propaquiz FRUIT FRESH R FRZE UTS (i) Citrus fruit (ii) Tree nuts (iii) Pome fruit (v) Berries 0.05* 0.04* 0.05* (iv) Stone fruit Apricots, Cherries, Plums, thers 0.05* 0.04* 0.05* Peaches * 0.05* VEGETABLES FRESH R FRZE (i) Root and tuber vegetables (a) Potatoes (b) Tropical root and tuber vegetables (c) ther root and tuber vegetables except sugar beet Beetroot, Horseradish, Salsify, Swedes, Turnips * 0.05* Carrots Celeriac, Parsnips, Parsley roots, Radishes (ii) Bulb vegetables Garlic, Shallots, Spring onions, thers * 0.05* nions (iii) Fruiting vegetables * (iv) Brassica vegetables (a) Flowering brassica Broccoli Cauliflower, thers (b) Head brassica Brussels sprouts, thers * 0.05* Head cabbage (c) Leafy brassica * 0.05* (d) Kohlrabies * 0.05* (v) Leaf vegetables, herbs and edible flowers (a) Lettuce and salad plants (b) Spinach and similar leaves Spinach Purslane, Beet leaves (chard), thers * (c) grape leaves (d) Watercress (e) Witloofs * (f) Herbs and edible flowers (vi) Legume vegetables Peas (with pods) Beans, Peas (without pods), Lentils, thers * (vii) Stem vegetables Asparagus, Celery, Globe artichokes Cardoons, Fennel, leek, Rhubarb, Bamboo, Palm, thers * 0.05* (viii) Fungi, mosses & lichens (ix) Algae & prokariotes 0.05* 0.04* 0.05* PULSES * 0.05* ILSEEDS AD ILFRUITS (i) ilseeds Linseed * 0.05* Sunflower seed Rapeseed Mustard seeds 0.05* Cotton seed Poppy seeds, soyabeans 0.1* Peanuts, Sesame, Pumpkin, thers 0.1* 0.04* 0.05* (ii) il fruits 0.05* 0.04* 0.05* CEREALS 0.05* 0.04* 0.05* TEA, CFFEE, HERBAL IFUSIS AD CCA (i)tea(ii) Coffee (iv) Cocoa (v) Carob 0.05* 0.04* 0.05* (iii)herbal infusions (dried) * 0.05* HPS (dried) 0.05* 0.04* 0.05* SPICES (i) Seeds Anise, caraway, celery, cumin, Dill, Fennel, fenugreek 0.05* 0.04* 0.05* Coriander seed * 0.05* (ii) Fruits (iii) Bark (iv) Roots (v) Buds (vi) Flower (vii) Aril 0.05* 0.04* 0.05* SUGAR PLATS Sugar beet (root) EFSA Journal 2016;14(2):4402