Residue definition

If the relevant residue cannot be properly determined using a routine multi-method, an alternative method must be proposed. In the case of residues consisting of a variety of structurally related compounds, a common moiety method may be acceptable in order to avoid the use of an excessive number of methods for individual substances. For example, the relevant residue of isoproturon in plant material is defined as the sum of isoproturon and all metabolites containing the 4-isopropylaniline group. Therefore, residues are determined following hydrolysis as 4-isopropylaniline and are expressed as 4-isopropylaniline equivalents. It is not necessary to validate the method individually for all possible metabolites which are covered by the residue definition (e.g., all metabolites which contain the 4-isopropylaniline group), provided that it is demonstrated that in the first step, the conversion to the common moiety is complete. However, common moiety methods often lack sufficient specificity, and should therefore be avoided if possible. If need be, their use must be justified. 

The enforcement method must be suitable for the determination of all compounds included in the residue definition in order to enable Member States to determine compliance with MRLs. It is not feasible to validate a method for all commodities if a wide range of MRLs are set. Therefore, a concept of crop groups was developed in SANCO/825/00. The following crop groups with representative crops are presented ... 

The use of common moiety methods acceptable in exceptional circumstances where there is no other practical means of determining the target analyte, and in these cases, full justification is required. This should include an explanation of why the compound cannot be determined by a specific analytical technique. For existing a.i., common moiety methods are also acceptable, in cases where the residue definition includes a common moiety. Moreover, validation data must be presented separately for all relevant components. 

Validation should be carried out for each component of the residue definition in each sample matrix used for risk assessment purposes. 

The method must be capable of determining all components (a.i. and relevant/major metabolites) that are included in the residue definitions used in the assessment of risk to nontarget organisms. For ground (drinking) water and air, the risk to con-sumers/operators or bystanders must also be considered. 

The activities of enforcement laboratories should not be focused on irrelevant problems. Therefore, a clear definition of the relevant residue is needed. In the crops and food sector, procedures are well established to derive the two residue definitions, one for risk assessment and one for monitoring, from metabolism studies. As far as environmental samples are concerned, there is much potential for improvement. There are no clear criteria as to which metabolites should be included in monitoring and control programs. Additionally, the development of criteria for nonpriority pesticides, e.g., naturally occurring compounds or low-risk products, which can be excluded from monitoring exercises would be helpful for laboratories and evaluators. 

The toxic effects of selected plant analytes will be assessed by comparison with the toxicides of similar metabolites found in animal metabolism studies. The amount of the analytes reported in the plant metabolism study is one of the important factors used to establish the residue definition. 

Prior to registration, an agreed commitment to the residue component(s) which should be analyzed does not exist. This is contrary to the situation with residue methods, which are developed after MRL setting. Therefore, to establish an acceptable residue definition is the first step necessary prior to any method development. This residue definition for enforcement methods is based on the results of metabolism studies and may cause serious difficulties, especially if the metabolic pathways of the parent compound are very complex, generating a large number of metabolites. 

In those cases where the total residue in not represented by a single marker compound, a more complex residue definition is necessary. The hydrolytically unstable ester of bromoxynil octanoate is presented as an example here (Table 1). 

Here two components, the free phenol and the intact ester, are included in the residue definition. Usually, analytical methods for the determination of bromoxynil and its octanoate begin with hydrolysis during maceration of the sample. If those methods are validated, the sole fortification of the octanoate is sufficient. However, in other existing methods, hydrolysis follows a separate extraction step. In that case, the chosen solvent must be able to extract both compounds with equal efficiency. 

Table 1 Example of a residue definition based on two compounds...

In summary, the proposal of an appropriate definition of the residue is not a process which follows simple and unambiguous rules in each case. The differences between residue definitions of some European MRLs and US tolerances illustrate the importance of harmonization. However, the great effort sometimes necessary to reach a suitable and accepted residue definition, which considers the needs of risk assessors (toxicologists) and the feasibility aspects of residue analysts, is clearly a vital prerequisite for any method development and validation. 

Most often studies will be accepted by regulatory authorities even if they do not contain all information. For example, a summary, the scope, a separate notice regarding the residue definition or a schematic diagram of the analytical procedure are helpful and may avoid additional questions, but they are not essential. Also, detailed specification of standard glassware or chemicals commonly used in residue analysis is less important. Finally, data about extraction efficiency or analyte stability can be offered in separate studies or statements, which are also valid for other methods. However, each method must precisely describe at the minimum ... 

To demonstrate the validity of an analytical method, data regarding working range/ calibration, recovery, repeatability, specificity and LOQ have to be provided for each relevant sample matrix. Most often these data have to be collected from several studies, e.g., from several validation reports of the developer of the method, the independent laboratory validation or the confirmatory method trials. If the intended use of a pesticide is not restricted to one matrix type and if residues are transferred via feedstuffs to animals and finally to foodstuffs of animal origin, up to 30 sets of the quality parameters described above are necessary for each analyte of the residue definition. Table 2 can be used as a checklist to monitor the completeness of required data. 

Often solvents do not extract 100% of the total radioactive residue. In this case, knowledge about the concentration of the target analyte(s) in the extract and the filter cake is necessary. Even if large amounts of radioactivity remain in the solid residual materials, the extraction efficiency may be sufficient if this unextracted radioactivity is permanently bound to the matrix or if it is associated with compounds which are not included in the residue definition. Finally, in all cases a well performed metabolism study can provide the answers needed, even where residues in the edible parts of treated crops or animals do not occur. If incurred residues do not occur, clearly the determination of extraction efficiency is not required. 

In contrast to many other validation protocols, the description of the NMKL validation process starts with the protocol of planned validation. This protocol should include, e.g., the needs of the client, available equipment, the chemical form in which the analyte occurs (i.e., in pesticide analysis the residue definition), matrix types, the availability of reference materials and the working range. Consequently, an extra paragraph is dedicated to the requirements for the documentation of validation results, which refers to the rules in Section 5.4.4 of EN 45001 (amended by ISO 17025). 

The integration of analytical methods in European standards requires their acceptance by several national experts within special working groups and in a final weighted vote of National Standards Bodies. Therefore, there needs to be very high confidence in the performance of methods. Consequently, methods should be tested in inter-laboratory method validation studies, with the exception of those multiresidue methods which are widely used throughout Europe. In the case of CEN methods there is no doubt about residue definition but detailed requirements about the number of matrices and concentration levels in validation experiments do not exist. Eor this reason it may be that CEN methods are validated for important crops only. 

Sulfonylurea herbicides are generally applied to crops as an early post-emergent herbicide. Crops that are tolerant to these herbicides quickly metabolize them to innocuous compounds. At maturity, residues of the parent compound in food and feed commodities are nondetectable. Metabolites are not considered to be of concern, and their levels are usually nondetectable also. For this reason, the residue definition only includes the parent compound. Tolerances [or maximum residue limits (MRLs)] are based on the LOQ of the method submitted for enforcement purposes and usually range from 0.01 to 0.05 mg kg (ppm) for food items and up to O.lmgkg" for feed items. There is no practical need for residue methods for animal tissues or animal-derived products such as milk, meat, and eggs. Sulfonylurea herbicides are not found in animal feed items, as mentioned above. Furthermore, sulfonylurea herbicides intentionally dosed to rats and goats are mostly excreted in the urine and feces, and the traces that are absorbed are rapidly metabolized to nontoxic compounds. For this reason, no descriptions of methods for animal-derived matrices are given here. 

The residue definition is for the parent, bispyribac-sodium, only... 

The crop residue definition includes parent flucarbazone-sodium and the A/-desmethyl flucarba-zone metabolite (I). The soil and water residue definitions include parent flucarbazone-sodium and the sulfonic acid, sulfonamide and A/,0-dimethyl triazoli-none (NODT) metabolites... 

Regulatory position The residue definition for pyriminobac-methyl is for the combined E- and Z-isomers. ... 

Pyrithiobac-sodium is a pre- and post-emergence herbicide to control broad-leaved weed and grasses The residue definition is for the parent, pyrithiobac-sodium, only. 

Reguiatory position The residue definition includes terbacil and its three primary metabolites. Metabolite A, Metabolite B and Metabolite C... 

Stable to acid and base in the pH range 3-8. Thenylchlor is a chloroacetamide herbicide for the preemergence and post-planting control of annual grass and broad-leaved weeds in paddy rice The residue definition is for the parent, thenylchlor, only... 

Oxime carbamates are generally applied either directly to the tilled soil or sprayed on crops. One of the advantages of oxime carbamates is their short persistence on plants. They are readily degraded into their metabolites shortly after application. However, some of these metabolites have insecticidal properties even more potent than those of the parent compound. For example, the oxidative product of aldicarb is aldicarb sulfoxide, which is observed to be 10-20 times more active as a cholinesterase inhibitor than aldicarb. Other oxime carbamates (e.g., methomyl) have degradates which show no insecticidal activity, have low to negligible ecotoxicity and mammalian toxicity relative to the parent, and are normally nondetectable in crops. Therefore, the residue definition may include the parent oxime carbamate (e.g., methomyl) or parent and metabolites (e.g., aldicarb and its sulfoxide and sulfone metabolites). The tolerance or maximum residue limit (MRL) of pesticides on any food commodity is based on the highest residue concentration detected on mature crops at harvest or the LOQ of the method submitted for enforcement purposes if no detectable residues are found. For example, the tolerances of methomyl in US food commodities range from 0.1 to 6 mg kg for food items and up to 40 mg kg for feed items. ... 

Azoxystrobin degrades rapidly and extensively in/on treated crops and in the environment. The residue definition of azoxystrobin in/on crops is for the parent compound only... 

The residue definition of famoxadone includes only famoxadonefor plants and animals. Forsoil and water, IN-JS940 (CAS No. 157874-97-0) and IN-KZ007 have also been included in the residue definition. 

Regulatory position The residue definition is for both imibenconazole and its primary metabolite (imibenconazole-debenzyl)... 

The residue definition include mepanipyrim and its hy-droxylated metabolite 1-(2-anilino-6-methylpyrimidin-4-ynyl)-2-propanol (abbreviated as propanol form)... 

Regulatory position The residue definition consists of tebuconazole alone for crops, soil, and water... 

The residue definition for plant samples is acetamiprid only. In soil, it includes acetamiprid and three of its... 

The residue definition includes alanycarb and its metabolite, methomyl (determined as methomyl oxime)... 

The residue definition for crops includes only azinphos-methyl... 

The residue definition includes benfuracarb and two of its metabolites, carbofuran and 3-hydroxycarbofuran... 

Regulatory position The residue definition of hexythiazox for plant/crops is for hexythiazox itself... 

Stable in acidic, neutral and basic aqueous solutions Pale yellowish solid, faint characteristic odor Flash point 119°C (Pensky-Martens closed tester) Pyriproxyfen is an insect growth regulator which acts both as an ovacide and as an inhibitor of development (juvenile hormone mimic) against white flies, scale, and psylla. The specificity of pyriproxyfen, and its low mammalian toxicity, allow for some variation in application timing. For example, the lack of toxicity to bees allows pyriproxyfen to be applied during bloom on apple trees, and its low mammalian toxicity allows for a very short pre-harvest interval on citrus The residue definition is for pyriproxyfen alone... 

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