Maximum Residue Level
Maximum Residue Level
Maximum Residue Level
doi:10.2903/j.efsa.2015.4311
Suggested citation: EFSA (European Food Safety Authority), 2015. Reasoned opinion on the
modification of the existing maximum residue level (MRL) for bromoxynil in chives. EFSA Journal
2015;13(11):4311, 18 pp. doi:10.2903/j.efsa.2015.4311
ISSN: 1831-4732
© European Food Safety Authority, 2015
Reproduction is authorised provided the source is acknowledged.
Summary
In accordance with Article 6 of Regulation (EC) No 396/2005, the evaluating Member State (EMS)
Belgium compiled an application to modify the existing maximum residue level (MRL) for the active
substance bromoxynil in chives. Belgium drafted an evaluation report in accordance with Article 8 of
Regulation (EC) No 396/2005, which was submitted to the European Commission and forwarded to
the European Food Safety Authority (EFSA) on 2 September 2015.
EFSA bases its assessment on the evaluation report submitted by the EMS, the draft assessment
report (DAR) prepared under Council Directive 91/414/EEC, the Commission review report on
bromoxynil and the conclusions from EFSA reasoned opinion on the review of the existing maximum
residue levels for bromoxynil.
The toxicological profile of bromoxynil was assessed in the framework of the peer review under
Directive 91/414/EEC and the data were sufficient to derive an acceptable daily intake (ADI) of
0.01 mg/kg body weight (bw) per day and an acute reference dose (ARfD) of 0.04 mg/kg bw.
The metabolism of bromoxynil in primary crops was investigated following foliar application on
cereal/grass (wheat, maize, alfalfa) and the pulses/oilseeds crop groups (cotton). The peer review
considered alfalfa to cover a third crop group and proposed the residue definition for the risk
assessment and enforcement in all plant commodities as ‘bromoxynil’. The Article 12 MRL review
agreed with this proposal and the residue definition in Regulation (EC) No 396/2005 was set as
‘bromoxynil and its salts, expressed as bromoxynil’. There are adequate analytical methods available
to control bromoxynil residues in chives according to the existing enforcement residue definition.
EFSA concludes that the submitted supervised residue trials on spring onions are sufficient to derive a
MRL proposal of 0.08 mg/kg, extrapolated to chives.
Specific studies investigating the nature and magnitude of bromoxynil residues under processing are
not required due to low residues in raw commodity. Bromoxynil degrades rapidly in the soil and
therefore bromoxynil residues are not expected to occur at relevant levels in rotational crops.
Bromoxynil residues in livestock were not assessed as chives are not fed to livestock.
The consumer risk assessment was performed with revision 2 of the EFSA Pesticide Residues Intake
Model (PRIMo). EFSA updated the consumer risks assessment conducted in the framework of the
Article 12 MRL review, taking into account the median (STMR) and highest (HR) residue levels derived
for chives from the residue trials conducted on spring onions. The highest calculated chronic intake
accounted for 7% of the ADI (WHO Cluster B). The contribution of residues in chives to the total
consumer exposure was below 0.1% of the ADI. An acute consumer risk was not identified in relation
to the MRL proposal for chives (0.02% of the ARfD).
EFSA concludes that the intended use of bromoxynil on chives will not result in a consumer exposure
exceeding the toxicological reference values and therefore is unlikely to pose a health risk to
consumers.
EFSA proposes to amend the existing MRL as reported in the summary table below.
Table of contents
Abstract .........................................................................................................................................1
Summary .......................................................................................................................................3
Background....................................................................................................................................5
The active substance and its use pattern .........................................................................................5
Assessment ....................................................................................................................................6
1. Method of analysis ..............................................................................................................6
1.1. Methods for enforcement of residues in food of plant origin ...................................................6
1.2. Methods for enforcement of residues in food of animal origin ................................................7
2. Mammalian toxicology .........................................................................................................7
3. Residues.............................................................................................................................7
3.1. Nature and magnitude of residues in plant ...........................................................................7
3.1.1. Primary crops .....................................................................................................................7
3.1.2. Rotational crops ................................................................................................................ 10
3.2. Nature and magnitude of residues in livestock .................................................................... 10
4. Consumer risk assessment ................................................................................................. 10
Conclusions and recommendations ................................................................................................ 11
References ................................................................................................................................... 12
Abbreviations ............................................................................................................................... 13
Appendix A – Good Agricultural Practice (GAPs) .......................................................................... 15
Appendix B – Pesticide Residue Intake Model (PRIMo) ................................................................ 16
Appendix C – Used compound code(s) ....................................................................................... 18
Background
Regulation (EC) No 396/20051 establishes the rules governing the setting of pesticide maximum
residue levels (MRLs) at European Union (EU) level. Article 6 of the 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) No
1107/2009,3 shall submit to a Member State, when appropriate, an application to modify a MRL in
accordance with the provisions of Article 7 of the Regulation.
Belgium,4 hereafter referred to as the evaluating Member State (EMS), compiled an application to
modify the existing MRL for the bromoxynil in chives. This application was notified to the European
Commission and the European Food Safety Authority (EFSA) and was subsequently evaluated in
accordance with Article 8 of the Regulation. After completion, the evaluation report was submitted to
the European Commission and to EFSA on 2 September 2015. The application was included in the
EFSA Register of Questions with the reference number EFSA-Q-2015-00491 and the following subject:
Bromoxynil: Application to modify MRL in chives
Belgium proposed to raise the existing MRL of bromoxynil in chives from the limit of quantification of
0.02 mg/kg to 0.05 or 0.08 or 0.10 mg/kg. EFSA proceeded with the assessment of the application
and the evaluation report as required by Article 10 of the Regulation.
In accordance with Article 10 of Regulation (EC) No 396/2005, EFSA shall, based on the evaluation
report submitted by the EMS, provide a reasoned opinion on the risks to the consumer associated with
the application.
In accordance with Article 11 of the 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 if more detailed
evaluations need to be carried out) from the date of receipt of the application. If EFSA requests
supplementary information, the time limit laid down shall be suspended until that information has
been provided.
1
Regulation (EC) No 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. OJ L 70, 16.03.2005,
p. 1–16.
2
Council Directive 91/414/EEC of 15 July 1991 concerning the placing of plant protection products on the market. OJ L 230,
19.08.1991, p. 1–32.
3
Regulation (EC) No 1107/2009 of the European Parliament and of the Council of 21 October 2009 concerning the placing of
plant protection products on the market and repealing Council Directives 79/117/EEC and 91/414/EEC. OJ L 309, 24.11.2009,
p. 1–50.
4
Belgium, FPS Health, Food chain safety and Environment DG4, Place Victor Horta 40, Box 10, 1060, Brussels, Belgium
5
Commission Directive 2004/58/EC of 23 April 2004 amending Council Directive 91/414/EEC to include alpha-cypermethrin,
benalaxyl, bromoxynil, desmedipham, ioxynil and phenmedipham as active substance. OJ L 120, 24.4.2004, p.26-29.
6
Commission Implementing Regulation (EU) No 540/2011 of 23 May 2011 implementing Regulation (EC) No 1107/2009 of the
European Parliament and of the Council as regards the list of approved active substances. OJ L 153, 11.06.2011, p. 1–186.
existing MRLs of bromoxynil according to Article 12 of Regulation (EC) No 396/2005 (here after Article
12 MRL review) has been finalized and an EFSA opinion has been issued (EFSA, 2012).
The EU MRLs for bromoxynil are established in Annex II of Regulation (EC) No 396/2005. The MRL
changes that were reported in the EU legislation since the entry into force of the regulation are
summarised in Table 1.
Table 1: Overview of the MRL changes since the entry into force of Regulation (EC) No 396/2005
Codex maximum residue limit (Codex MRL, CXLs) are not established for bromoxynil. The details of
the intended GAP for bromoxynil in Belgium on chives are given in Appendix A.
Assessment
EFSA bases its assessment on the evaluation report submitted by the EMS (Belgium, 2015), the DAR
(and its addendum) prepared under Directive 91/414/EEC (France, 2000, 2001), the Commission
review report on bromoxynil (European Commission, 2004) and the conclusions from EFSA reasoned
opinion on the review of the MRLs for bromoxynil (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) No 546/2011 7 and the currently
applicable guidance documents relevant for the consumer risk assessment of pesticide residues
(European Commission, 1996, 1997a–g, 2000, 2010a, b, 2011; OECD, 2011).
1. Method of analysis
In the framework of the Article 12 MRL review a method using LC-MS/MS quantification (and ILV) was
submitted and evaluated for the determination of bromoxynil esters (bromoxynil octanoate) and
bromoxynil with an LOQ of 0.01 mg/kg in high water (tomatoes), dry/starch (wheat grain), high acid
(citrus) and high oil (oilseed rape) content commodities (EFSA, 2012). This method includes a
hydrolysis step converting all esters to bromoxynil prior to analysis. The esters of bromoxynil,
however, are rapidly hydrolysed in plants (EFSA, 2012).
The multi-residue QuEChERS method in combination with HPLC-MS/MS was also concluded to be
sufficiently validated to analyse bromoxynil with an LOQ of 0.002 to 0.01 mg/kg in high water, high
acid content and in dry commodities (EFSA, 2012). However, this method does not include a
hydrolysis step and is therefore not expected to include esters of bromoxynil.
It is concluded that there are adequate analytical methods available to control bromoxynil residues in
chives (high water content commodity) according to the existing enforcement residue definition.
7
Commission Regulation (EU) No 546/2011 of 10 June 2011 implementing Regulation (EC) No 1107/2009 of the European
Parliament and of the Council as regards uniform principles for evaluation and authorisation of plant protection products. OJ L
155, 11.06.2011, p. 127–175.
2. Mammalian toxicology
The toxicological profile of the active substance bromoxynil was assessed in the framework of the
peer review under Directive 91/414/EEC and toxicological reference values were established by the
European Commission (Table 2).
Table 2: Overview of the toxicological reference values
3. Residues
The detailed results of the metabolism studies are reported in the previously issued EFSA reasoned
opinion on the Article 12 MRL review (EFSA, 2012). Total radioactive residues (TRRs) in edible plant
parts were consistently very low with bromoxynil identified as the main component of residues in
conventional crops. Occasionally, small amounts of bromoxynil ester were also detected. Other
metabolites were found in very small percentages of the total extractable residues. In genetically
modified cotton, the main component of residues was identified as 3,5-dibromo-4-hydroxybenzoic acid
(approximately 50% of TRR).
During the peer review alfalfa was considered sufficient to cover a third crop group and the residue
definition for the risk assessment and enforcement in all plant commodities was proposed as
‘bromoxynil’. The Article 12 MRL review agreed with the proposals of the peer review. Consequently,
the residue definition which formerly included esters, was modified by Commission Regulation
1146/20148 to ‘bromoxynil and its salts, expressed as bromoxynil’.
For the uses on chives EFSA concludes that the metabolism of bromoxynil is sufficiently addressed and
the residue definitions for enforcement and risk assessment agreed during the peer review are
applicable.
8
Commission Regulation (EU) No 1146/2014 of 23 October 2014 amending Annexes II, III, IV and V to Regulation (EC) No
396/2005 of the European Parliament and of the Council as regards maximum residue levels for anthraquinone, benfluralin,
bentazone, bromoxynil, chlorothalonil, famoxadone, imazamox, methyl bromide, propanil and sulphuric acid in or on certain
products. OJ L 308, 29.10.2014, p.3-60.
Extrapolation to chives
(a): NEU: Outdoor trials conducted in northern Europe, SEU: Outdoor 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
(c): Any information/comment supporting the decision and OECD MRL calculation (unrounded/rounded values)
(d): HR: Highest residue level according to the residue definition for risk assessment.
(e): STMR: Median residue level according to residue definition for risk assessment.
The estimated exposure was then compared with the toxicological reference values derived for
bromoxynil (see Table 2). The results of the intake calculation are presented in Appendix B of this
reasoned opinion.
The total calculated chronic intake accounted for up to 7% of the ADI (WHO, Cluster B). The
contribution of residues in chives to the total consumer exposure was below 0.1% of the ADI.
9
The calculation of the long-term exposure (chronic exposure) is based on the mean consumption data representative for 22
national diets collected from MS surveys plus 1 regional and 4 cluster diets from the WHO GEMS Food database; for the acute
exposure assessment the most critical large portion consumption data from 19 national diets collected from MS surveys is
used. The complete list of diets incorporated in EFSA PRIMo is given in its reference section (EFSA, 2007).
An acute consumer risk was not identified in relation to the MRL proposal for chives (0.02% of the
ARfD).
EFSA concludes that the intended use of bromoxynil on chives will not result in a consumer exposure
exceeding the toxicological reference values and therefore is unlikely to pose a consumers health risk.
References
Belgium, 2015. Evaluation report on the modification of MRLs for bromoxynil in chives prepared by the
evaluating Member State Belgium under Article 8 of Regulation (EC) No 396/2005, 6 July 2015, pp.
12.
European Commission, 1996. Appendix G. Livestock Feeding Studies. 7031/VI/95-rev.4.
European Commission, 1997a. Appendix A. Metabolism and distribution in plants. 7028/IV/95-rev.3.
European Commission, 1997b. Appendix B. General recommendations for the design, preparation and
realisation of residue trials. Annex 2. Classification of (minor) crops not listed in the Appendix of
Council Directive 90/642/EEC. 7029/VI/95-rev.6.
European Commission, 1997c. Appendix C. Testing of plant protection products in rotational crops.
7524/VI/95-rev.2.
European Commission, 1997d. Appendix E. Processing studies. 7035/VI/95-rev.5.
European Commission, 1997e. Appendix F. Metabolism and distribution in domestic animals.
7030/VI/95-rev.3.
European Commission, 1997f. Appendix H. Storage stability of residue samples. 7032/VI/95-rev.5.
European Commission, 1997g. Appendix I. Calculation of maximum residue level and safety intervals.
7039/VI/95.
European Commission, 2000. Residue analytical methods. For pre-registration data requirement for
Annex II (part A, section 4) and Annex III (part A, section 5 of Directive 91/414). SANCO/3029/99-
rev.4.
European Commission, 2004. Review report for the active substance bromoxynil. Finalised in the
Standing Committee on the Food Chain and Animal Health at its meeting on 13 February 2004 in
view of the inclusion of bromoxynil in Annex I of Council Directive 91/414/EEC. SANCO/4347/2000-
Final, 13 February 2004, 104 pp.
European Commission, 2010a. Classes to be used for the setting of EU pesticide Maximum Residue
Levels (MRLs). SANCO 10634/2010 Rev. 0, finalised in the Standing Committee on the Food Chain
and Animal Health at its meeting of 23–24 March 2010.
European Commission, 2010b. Residue analytical methods. For post-registration control.
SANCO/825/00-rev.8.1.
European Commission, 2011. Appendix D. Guidelines on comparability, extrapolation, group
tolerances and data requirements for setting MRLs. 7525/VI/95-rev.9.
EFSA (European Food Safety Authority), 2007. Reasoned opinion on the potential chronic and acute
risk to consumers health arising from proposed temporary EU MRLs. The EFSA Journal 2007, 32r,
1-1141. doi:10.2903/j.efsa.2007.32r
EFSA (European Food Safety Authority), 2012. Reasoned opinion on the review of the existing
maximum residue levels (MRLs) for bromoxynil according to Article 12 of Regulation (EC) No
396/2005. EFSA Journal 2012;10(8):2861, 41 pp. doi:102903/j.efsa.2012.2861
France, 2000. Draft assessment report on the active substance bromoxynil prepared by the rapporteur
Member State France in the framework of Council Directive 91/414/EEC, February 2000. Available
online: www.efsa.europa.eu
France, 2001. Addendum to the draft assessment report on the active substance bromoxynil prepared
by the rapporteur Member State France in the framework of Council Directive 91/414/EEC.
Available online: www.efsa.europa.eu
OECD (Organisation for Economic Co-operation and Development), 2011. OECD MRL calculator:
spreadsheet for single data set and spreadsheet for multiple data set, 2 March 2011. In: Pesticide
Publications/Publications on Pesticide Residues. Available online: http://www.oecd.org
Abbreviations
a.s. active substance
ADI acceptable daily intake
ARfD acute reference dose
BBCH growth stages of mono- and dicotyledonous plants
bw body weight
CAC Codex Alimentarius Commission
CF conversion factor for enforcement to risk assessment residue definition
CXL Codex maximum residue limit (Codex MRL)
DAR draft assessment report
DAT days after treatment
DT90 period required for 90% dissipation (define method of estimation)
ECD electron capture detector
EFSA European Food Safety Authority
EMS evaluating Member State
GAP good agricultural practice
GC gas chromatography
GM genetically modified
HPLC high performance liquid chromatography
HR highest residue
ILV independent laboratory validation
ISO International Organisation for Standardisation
IUPAC International Union of Pure and Applied Chemistry
LOQ limit of quantification
MRL maximum residue level
MS Member States
MS/MS tandem mass spectrometry detector
NEU northern Europe
OECD Organisation for Economic Co-operation and Development
PHI pre-harvest interval
PRIMo (EFSA) Pesticide Residues Intake Model
QuEChERS
RD residue definition
RMS rapporteur Member State
SC suspension concentrate
STMR supervised trials median residue
TMDI theoretical maximum daily intake
TRR total radioactive residue
Remarks:
(a) For crops, EU or other classifications, e.g. Codex, should be used; where relevant, the (i) g/kg or µg/L
usage situation should be described (e.g. fumigation of a structure) (j) Growth stage at last treatment (Meier U, 2001. Growth Stages of mono- and
(b) Outdoor or field use (F), glasshouse application (G) or indoor application (I) dicotyledonous plants. BBCH Monograph, 2nd Ed., Federal Biological Research Centre of
(c) e.g. biting and sucking insects, soil-born insects, foliar fungi, weeds Agriculture and Forestry, Braunschweig, Germany, 2001), including where relevant,
(d) e.g. wettable powder (WP), water soluble granule (WG) information on season at time of application
(e) GCPF Codes - GIFAP Technical Monograph No 2, 1989 (k) The minimum and maximum number of application possible under practical conditions of
(f) all abbreviations must be explained use must be provided
(g) Method, e.g. high volume spraying, low volume spraying, spreading, dusting, drench (l) PHI - minimum pre-harvest interval
(h) Kind, eg. overall, broadcast, aerial spraying, row, individual plant, between the plants. (m) Remarks may include: Extent of use/economic importance/restrictions
type of equipment used must be indicated
Conclusion:
The estimated Theoretical Maximum Daily Intakes (TMDI), based on pTMRLs were below the ADI.
A long-term intake of residues of bromoxynil is unlikely to present a public health concern.
Acute risk assessment /children - refined calculations Acute risk assessment / adults / general population - refined calculations
No of commodities for which ARfD/ADI No of commodities for which No of commodities for which No of commodities for which ARfD/ADI is
is exceeded (IESTI 1): --- ARfD/ADI is exceeded (IESTI 2): --- ARfD/ADI is exceeded (IESTI 1): --- exceeded (IESTI 2): ---
*) The results of the IESTI calculations are reported for at least 5 commodities. If the ARfD is exceeded for more than 5 commodities, all IESTI values > 90% of ARfD are reported.
**) pTMRL: provisional temporary MRL
***) pTMRL: provisional temporary MRL for unprocessed commodity
Conclusion:
For bromoxynil IESTI 1 and IESTI 2 were calculated for food commodities for which pTMRLs were submitted and for which consumption data are available.
No exceedance of the ARfD/ADI was identified for any unprocessed commodity.
bromoxynil 3,5-dibromo-4-hydroxybenzonitrile Br
bromoxynil-phenol
HO N
Br
Br
Bromoxynil- 2,6-dibromo-4-cyanophenyl
O
heptanoate heptanoate
CH 3(CH 2) 5 C O CN
6
Br
Br
Bromoxynil octanoate 2,6-dibromo-4-cyanophenyl
O
octanoate
CH3 (CH2 )6 C O CN
Br
3,5-dibromo-4-
hydroxybenzoic acid