Modification of the existing maximum residue levels for potassium phosphonates in various crops
2020; Wiley; Volume: 18; Issue: 9 Linguagem: Inglês
10.2903/j.efsa.2020.6240
ISSN1831-4732
AutoresMaria Anastassiadou, Giovanni Bernasconi, Alba Brancato, Luis Carrasco Cabrera, Lucien Ferreira, Luna Greco, Samira Jarrah, Aija Kazocina, Renata Leuschner, José Oriol Magrans, Ileana Miron, Stéfanie Nave, Ragnor Pedersen, Hermine Reich, Alejandro Rojas, Angela Sacchi, Miguel Santos, Anne Theobald, Bénédicte Vagenende, Alessia Verani,
Tópico(s)Pesticide Exposure and Toxicity
ResumoEFSA JournalVolume 18, Issue 9 e06240 Reasoned OpinionOpen Access Modification of the existing maximum residue levels for potassium phosphonates in various crops EFSA (European Food Safety Authority), Corresponding Author EFSA (European Food Safety Authority) pesticides.mrl@efsa.europa.eu Correspondence: pesticides.mrl@efsa.europa.euSearch for more papers by this authorMaria Anastassiadou, Maria AnastassiadouSearch for more papers by this authorGiovanni Bernasconi, Giovanni BernasconiSearch for more papers by this authorAlba Brancato, Alba BrancatoSearch for more papers by this authorLuis Carrasco Cabrera, Luis Carrasco CabreraSearch for more papers by this authorLucien Ferreira, Lucien FerreiraSearch for more papers by this authorLuna Greco, Luna GrecoSearch for more papers by this authorSamira Jarrah, Samira JarrahSearch for more papers by this authorAija Kazocina, Aija KazocinaSearch for more papers by this authorRenata Leuschner, Renata LeuschnerSearch for more papers by this authorJose Oriol Magrans, Jose Oriol MagransSearch for more papers by this authorIleana Miron, Ileana MironSearch for more papers by this authorStefanie Nave, Stefanie NaveSearch for more papers by this authorRagnor Pedersen, Ragnor PedersenSearch for more papers by this authorHermine Reich, Hermine ReichSearch for more papers by this authorAlejandro Rojas, Alejandro RojasSearch for more papers by this authorAngela Sacchi, Angela SacchiSearch for more papers by this authorMiguel Santos, Miguel SantosSearch for more papers by this authorAnne Theobald, Anne TheobaldSearch for more papers by this authorBenedicte Vagenende, Benedicte VagenendeSearch for more papers by this authorAlessia Verani, Alessia VeraniSearch for more papers by this author EFSA (European Food Safety Authority), Corresponding Author EFSA (European Food Safety Authority) pesticides.mrl@efsa.europa.eu Correspondence: pesticides.mrl@efsa.europa.euSearch for more papers by this authorMaria Anastassiadou, Maria AnastassiadouSearch for more papers by this authorGiovanni Bernasconi, Giovanni BernasconiSearch for more papers by this authorAlba Brancato, Alba BrancatoSearch for more papers by this authorLuis Carrasco Cabrera, Luis Carrasco CabreraSearch for more papers by this authorLucien Ferreira, Lucien FerreiraSearch for more papers by this authorLuna Greco, Luna GrecoSearch for more papers by this authorSamira Jarrah, Samira JarrahSearch for more papers by this authorAija Kazocina, Aija KazocinaSearch for more papers by this authorRenata Leuschner, Renata LeuschnerSearch for more papers by this authorJose Oriol Magrans, Jose Oriol MagransSearch for more papers by this authorIleana Miron, Ileana MironSearch for more papers by this authorStefanie Nave, Stefanie NaveSearch for more papers by this authorRagnor Pedersen, Ragnor PedersenSearch for more papers by this authorHermine Reich, Hermine ReichSearch for more papers by this authorAlejandro Rojas, Alejandro RojasSearch for more papers by this authorAngela Sacchi, Angela SacchiSearch for more papers by this authorMiguel Santos, Miguel SantosSearch for more papers by this authorAnne Theobald, Anne TheobaldSearch for more papers by this authorBenedicte Vagenende, Benedicte VagenendeSearch for more papers by this authorAlessia Verani, Alessia VeraniSearch for more papers by this author First published: 21 September 2020 https://doi.org/10.2903/j.efsa.2020.6240Citations: 3 Requestor: European Commission Question numbers: EFSA-Q-2018-00462; EFSA-Q-2018-00574; EFSA-Q-2020-00277; EFSA-Q-2020-00385 Acknowledgements: EFSA wishes to thank the following for the support provided to this scientific output: Chris Anagnostopoulos, Laszlo Bura, Georgios Chatzisotiriou, Viktoria Krivova, Silvia Ruocco and Viktor Toth. Adopted: 24 August 2020 AboutSectionsPDF ToolsExport citationAdd to favoritesTrack citation ShareShare Give accessShare full text accessShare full-text accessPlease review our Terms and Conditions of Use and check box below to share full-text version of article.I have read and accept the Wiley Online Library Terms and Conditions of UseShareable LinkUse the link below to share a full-text version of this article with your friends and colleagues. Learn more.Copy URL Share a linkShare onFacebookTwitterLinkedInRedditWechat Abstract In accordance with Article 6 of Regulation (EC) No 396/2005, the applicants Tilco-Alginure GmbH, ADAMA Agriculture BV, Lainco S.A., Exclusivas Sarabia S.A., Biovert S.L. and Landwirtschaftskammer Steiermark submitted requests to the competent national authorities in Germany, France, Greece and Austria to modify the existing maximum residue levels (MRLs) for the active substance potassium phosphonates in various crops. The data submitted in support of the different requests were found to be sufficient to derive MRL proposals for all crops under assessment. Adequate analytical methods for enforcement are available to control the residues of potassium phosphonates in the crops under assessment. Based on the risk assessment results, EFSA concluded that the long-term intake of residues resulting from the use of potassium phosphonates according to the reported agricultural practices is unlikely to present a risk to consumer health. The consumer risk assessment shall be regarded as indicative and a more realistic intake assessment will be performed in the framework of the joint review of MRLs for fosetyl and phosphonates. The reliable end points, appropriate for use in regulatory risk assessment are presented. Summary In accordance with Article 6 of Regulation (EC) No 396/2005, Tilco Alginure GmbH submitted an application to the competent national authority in Germany (evaluating Member State, EMS) to modify the existing maximum residue levels (MRLs) for the active substance potassium phosphonates in garlic and shallots. The EMS 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 07 April 2020. EFSA assessed the application and the evaluation report as required by Article 10 of the MRL regulation. To accommodate for the intended uses of potassium phosphonates, the EMS proposed to raise the existing MRLs expressed as fosetyl equivalent from the limit of quantification (LOQ) of 2.0 to 30 mg/kg in garlic and shallots. Moreover, still in accordance with Article 6 of Regulation (EC) No 396/2005, ADAMA Agriculture BV submitted an application to the competent national authority in France (EMS) to modify the existing MRL for the active substance potassium phosphonates in wine grapes. The EMS 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 EFSA on 11 July 2018. EFSA assessed the application and the evaluation report as required by Article 10 of the MRL regulation. EFSA identified data gaps and further clarifications, which were requested from the EMS. On 20 July 2020, the EMS submitted a revised evaluation report, which replaced the previously submitted evaluation reports. To accommodate for the intended use of potassium phosphonates, the EMS proposed to raise the existing MRLs expressed as fosetyl equivalent from 100 to 200 mg/kg in wine grapes. Furthermore, also in accordance with Article 6 of Regulation (EC) No 396/2005, Lainco S.A., Exclusivas Sarabia S.A. and Biovert S.L. submitted an application to the competent national authority in Greece (EMS) to modify the existing MRLs for the active substance potassium phosphonates in avocados, table olives and olives for oil production. The EMS 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 EFSA on 14 May 2020. EFSA assessed the application and the evaluation report as required by Article 10 of the MRL regulation. EFSA requested some clarifications from the EMS on 16 June 2020. On 12 August 2020, the EMS submitted a revised evaluation report, which replaced the previously submitted evaluation report. To accommodate for the intended uses of potassium phosphonates, the EMS proposed to raise the existing MRLs expressed as fosetyl equivalent from 50 to 70 mg/kg for avocados and from the limit of quantification (LOQ) of 2 to 100 mg/kg in table olives and olives for oil production. Finally, still in accordance with Article 6 of Regulation (EC) No 396/2005, Landwirtschaftskammer Steiermark submitted an application to the competent national authority in Austria (EMS) to modify the existing MRL for the active substance potassium phosphonates in horseradishes. The EMS 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 EFSA on 1 June 2018. EFSA assessed the application and the evaluation report as required by Article 10 of the MRL regulation. EFSA identified data gaps, which were requested from the EMS. On 30 June 2020, the EMS submitted a revised evaluation report, which replaced the previously submitted evaluation report. To accommodate for the intended use of potassium phosphonates, the EMS proposed to raise the existing MRLs expressed as fosetyl equivalent from the limit of quantification (LOQ) of 2.0 to 200 mg/kg in horseradishes. Based on the conclusions derived by EFSA in the framework of Directive 91/414/EEC, the data evaluated under previous MRL assessments and the additional data provided by the EMSs in the framework of these applications, the following conclusions are derived. The EU pesticides peer review concluded that, given the elementary nature of potassium phosphonates and according to available data from public literature, the main metabolite of potassium phosphonates in plants is phosphonic acid. Studies investigating the effect of processing on the nature (hydrolysis studies) of potassium phosphonates conducted with its main metabolite demonstrated that phosphonic acid is stable. In rotational crops, the major residue was phosphonic acid. Based on the metabolic pattern identified in metabolism studies, hydrolysis studies, the toxicological significance of the metabolite, the EU pesticides peer review proposed a general residue definition for potassium phosphonates in plant products as ‘phosphonic acid and its salts, expressed as phosphonic acid’ for both enforcement and risk assessment. The current residue definition for enforcement set in Regulation (EC) No 396/2005 is ‘Fosetyl-Al (sum of fosetyl, phosphonic acid and their salts, expressed as fosetyl)’. This residue definition for enforcement is in common with other two active substances approved for use in plant protection products in the EU, disodium phosphonate and fosetyl-Al. The residue definitions are applicable to primary crops, rotational crops and processed products. EFSA concluded that for the crops assessed in these applications, the metabolism of potassium phosphonates in primary and in rotational crops, and the possible degradation in processed products have been sufficiently addressed and that the previously derived residue definitions are applicable. Sufficiently validated analytical methods are available to quantify residues of potassium phosphonates in the crops assessed in these applications according to the enforcement residue definition set in the EU legislation (as fosetyl equivalents) and proposed during the EU pesticides peer review (as phosphonic acid). The methods enable quantification of residues at or above an LOQ of 0.01 mg fosetyl/kg and 0.1 mg phosphonic acid/kg. The available residue trials are sufficient to derive MRL proposals for all the crops under consideration. EFSA derived MRL proposals according to both the existing and the proposed residue definition for enforcement. Specific studies investigating the magnitude of potassium phosphonates in processed products were provided for olive oil and allowed concluding that concentration of residues is not expected (median processing factor < 0.05). A tentative processing factor of 1.3 in wine was derived in the framework of the EU pesticides peer review. A peeling factor of 1.1 could also be derived for avocados from the data submitted in the related MRL application. The occurrence of residues of potassium phosphonates in rotational crops was investigated in the framework of the EU pesticides peer review. Based on the available information, EFSA could not exclude that the uses of potassium phosphonates according to the proposed GAP will not result in significant residues of phosphonic acid in rotational crops. Therefore, Member States should consider the need for setting specific risk mitigation measures to avoid the presence of potassium phosphonates residues in rotational crops. Residues of potassium phosphonates in commodities of animal origin were not assessed since the crops under consideration in these MRL applications are normally not fed to livestock. The toxicological profile of potassium phosphonates was assessed in the framework of the EU pesticides peer review under Directive 91/414/EEC and the data were sufficient to derive an acceptable daily intake (ADI) of 2.25 mg/kg body weight (bw) per day for phosphonic acid, which is the toxicologically relevant metabolite of potassium phosphonates in products of plant and animal origin. An acute reference dose (ARfD) was deemed unnecessary. The consumer risk assessment was performed with revision 3.1 of the EFSA Pesticide Residues Intake Model (PRIMo). For the calculation of the chronic exposure, EFSA used the median residue values (STMR) as derived from the residue trials on the crops under consideration, the STMR available from previously issued EFSA opinions and from recently implemented Codex MRLs. For the remaining commodities of plant and animal origin, the existing MRLs as established in the EU legislation, recalculated to express them as phosphonic acid, were included in the risk assessment. Using the toxicological reference value set for potassium phosphonates, no long-term consumer intake concerns were identified; the calculated long-term exposure accounted for a maximum of 48% of the ADI (DE child diet). EFSA also performed an indicative risk assessment using the proposed revised ADI of 1 mg/kg bw per day applicable to phosphonic acid according to the recent EFSA conclusion on fosetyl, noting that the value is not yet formally adopted. The long-term dietary exposure accounted for a maximum of 97% of the ADI (DE child, NL toddler). The contribution of residues in the crops under consideration is minor (all individually at or below 6% of the ADI). When excluding from this exposure calculation the commodities for which the existing EU MRLs are set at the LOQ, assuming that no uses are authorised on these crops, and taking into account the peeling factor for citrus fruits, the overall chronic exposure to phosphonic acid residues is below the ADI (91% of the ADI). All these exposure calculations shall be regarded as indicative since information on the contribution for all authorised uses and all sources leading to residues of phosphonic acid is not available at this stage. For a number of products, the exposure calculations were performed with the MRLs instead of the STMRs which are likely to overestimate the exposure to residues arising from the use of potassium phosphonates in plants. EFSA concluded that the proposed uses of potassium phosphonates on garlic, shallots, wine grapes, avocados, table olives, olives for oil production and horseradishes will not result in a consumer exposure exceeding the toxicological reference values and therefore is unlikely to pose a risk to consumers’ health. As the joint review of MRLs for fosetyl and phosphonates under Article 43 of Regulation (EC) No 396/2005 is not yet finalised, the conclusions reported in this reasoned opinion are indicative and may need to be reconsidered in the light of the outcome of the MRL review. EFSA proposes to amend the existing MRLs as reported in the summary table below. Full details of all endpoints and the consumer risk assessment can be found in Appendices B–D. Codea Commodity Existing EU MRL (mg/kg) Proposed EU MRL (mg/kg) Comment/justification Enforcement residue definition: 1) Existing enforcement residue definition: fosetyl-Al (sum of fosetyl, phosphonic acid and their salts, expressed as fosetyl) 2) Proposed enforcement residue definition: phosphonic acid and its salts, expressed as phosphonic acid 0220010 Garlic 2* 1) 30 2) 20 The submitted data on onions are sufficient to derive an MRL proposal for the intended NEU use on garlic by extrapolation. Risk for consumers unlikely 0220030 Shallots 2* 1) 30 2) 20 The submitted data on onions are sufficient to derive an MRL proposal for the intended NEU use on shallots by extrapolation. Risk for consumers unlikely 0151020 Wine grapes 100 1) 200 2) 150 The submitted data are sufficient to derive an MRL proposal for the intended NEU and SEU uses on wine grapes. The MRL proposal reflects the more critical residues situation of NEU use. Risk for consumers unlikely 0163010 Avocados 50 1) 70 2) 50 The submitted data are sufficient to derive an MRL proposal for the intended SEU use on avocados. Risk for consumers unlikely 0161030 Table Olives 2* 1) 100 2) 80 The submitted data on olives are sufficient to derive an MRL proposal for the intended SEU use on table olives. Risk for consumers unlikely 0402010 Olives for oil production 2* 1) 100 2) 80 The submitted data on olives are sufficient to derive an MRL proposal for the intended SEU use on olives for oil production. Risk for consumers unlikely 2013040 Horseradishes 2* 1) 200 2) 150 The submitted data are sufficient to derive an MRL proposal for the intended NEU use on horseradishes. Risk for consumers unlikely MRL: maximum residue level; NEU: northern Europe; SEU: southern Europe. * Indicates that the MRL is set at the limit of analytical quantification (LOQ). a Commodity code number according to Annex I of Regulation (EC) No 396/2005. Assessment The European Food Safety Authority (EFSA) received different applications to modify the existing maximum residue levels (MRLs) for potassium phosphonates in various crops. The detailed description of the intended uses of potassium phosphonates in these crops, which are the basis for the current MRL applications, is reported in Appendix A. Potassium phosphonates is the ISO common name for potassium hydrogen phosphonate and dipotassium phosphonate (IUPAC names). The chemical structures of the active substance and its main metabolites are reported in Appendix E. Potassium phosphonates was evaluated in the framework of Directive 91/414/EEC1 with France designated as rapporteur Member State (RMS) for the representative use as a foliar spraying on grapes. The draft assessment report (DAR) prepared by the RMS has been peer reviewed by EFSA (EFSA, 2005, 2012b). Potassium phosphonates was approved2 for the use as fungicide on 1 October 2013. The process of renewal of the first approval has not yet been initiated. The EU MRLs for potassium phosphonates are established in Annexes IIIA of Regulation (EC) No 396/20053. The current residue definition for enforcement is set as the ‘sum of fosetyl, phosphonic acid and their salts, expressed as fosetyl’. Thus, the existing MRLs reflect the use of fosetyl-(Aluminium), disodium phosphonate or potassium phosphonates leading to the higher residue. The review of existing MRLs according to Article 12 of Regulation (EC) No 396/2005 (MRL review) is not yet finalised. For fosetyl, the MRL review is completed (EFSA, 2012a). However, the modifications of the existing MRLs proposed have not yet been legally implemented since it is appropriate to await the MRL review for the related active substances, i.e. potassium phosphonates and disodium phosphonate, as these active substances share the common metabolite phosphonic acid. EFSA has received from the European Commission a mandate to provide a reasoned opinion on the joint review of maximum residue levels (MRLs) for fosetyl and phosphonates in or on food and feed according to Article 43 of Regulation (EC) No 396/2005 and this assessment is currently ongoing. EFSA has issued several reasoned opinions on the modification of MRLs for potassium phosphonates (EFSA, 2018b,d, 2019b, 2020a,b). The proposals from these reasoned opinions have been considered in recent MRL regulation(s).4 Certain Codex maximum residue limits (CXLs) have been taken over in the EU MRL legislation.5 In accordance with Article 6 of Regulation (EC) No 396/2005, Tilco Alginure GmbH submitted an application to the competent national authority in Germany (EMS) to modify the existing MRLs for the active substance potassium phosphonates in garlic and shallots. The EMS drafted an evaluation reports 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 7 April 2020. To accommodate for the intended uses of potassium phosphonates, the EMS proposed to raise the existing MRL expressed as fosetyl equivalent from the limit of quantification (LOQ) of 2.0 to 30 mg/kg in garlic and shallots. Moreover, still in accordance with Article 6 of Regulation (EC) No 396/2005, ADAMA Agriculture BV submitted an application to the competent national authority in France (EMS) to modify the existing MRL for the active substance potassium phosphonates in grapes. The EMS drafted an evaluation reports in accordance with Article 8 of Regulation (EC) No 396/2005, which was submitted to the European Commission and forwarded to EFSA on 11 July 2018. EFSA identified data gaps and further clarifications, which were requested from the EMS. On 20 July 2020, the EMS submitted a revised evaluation report (France, 2018), which replaced the previously submitted evaluation reports. To accommodate for the intended uses of potassium phosphonates, the EMS proposed to raise the existing MRL expressed as fosetyl equivalent from 100 to 200 mg/kg in wine grapes. Furthermore, also in accordance with Article 6 of Regulation (EC) No 396/2005, the applicants Lainco S.A., Exclusivas Sarabia S.A. and Biovert S.L. submitted an application to the competent national authority in Greece (EMS) to modify the existing MRLs for the active substance potassium phosphonates in avocados, table olives and olives for oil production. The EMS 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 EFSA on 14 May 2020. EFSA assessed the application and the evaluation report (Greece, 2020) as required by Article 10 of the MRL regulation. EFSA requested some clarifications from the EMS on 16 June 2020. On 12 August 2020, the EMS submitted a revised evaluation report, which replaced the previously submitted evaluation report. To accommodate for the intended uses of potassium phosphonates, the EMS proposed to raise the existing MRLs expressed as fosetyl equivalent from 50 to 70 mg/kg for avocados and from the limit of quantification (LOQ) of 2.0 to 100 mg/kg in table olives and olives for oil production. Finally, still in accordance with Article 6 of Regulation (EC) No 396/2005, Landwirtschaftskammer Steiermark submitted an application to the competent national authority in Austria (EMS) to modify the existing MRLs for the active substance potassium phosphonates in horseradishes. The EMS 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 EFSA on 1 June 2018. EFSA assessed the application and the evaluation report as required by Article 10 of the MRL regulation. EFSA identified data gaps, which were requested from the EMS. On 30 June 2020, the EMS submitted a revised evaluation report (Austria, 2018), which replaced the previously submitted evaluation report. To accommodate for the intended use of potassium phosphonates, the EMS proposed to raise the existing MRLs expressed as fosetyl equivalent from the limit of quantification (LOQ) of 2.0 to 200 mg/kg in horseradishes. EFSA based its assessment on the evaluation reports submitted by the individual EMSs (Austria, 2018; France, 2018; Germany, 2020; Greece, 2020;), the draft assessment report (DAR) and its addendum on potassium phosphonates (France, 2005, 2012) prepared under Council Directive 91/414/EEC and the renewal assessment report (RAR) on fosetyl (France, 2017, 2019) prepared under Regulation (EU) No 1107/20096, the Commission review report on potassium phosphonates (European Commission, 2013), the conclusion on the peer review of the pesticide risk assessment of the active substances potassium phosphonates (EFSA, 2012b) and fosetyl (EFSA, 2018c), as well as the conclusions from previous EFSA opinions on potassium phosphonates and fosetyl (EFSA, 2009, 2015b, 2018b,d, 2019b, 2020a,b) and the MRL review of fosetyl (EFSA, 2012a). For reasons of efficiency, the four MRL applications were combined in one reasoned opinion. For these applications, the data requirements established in Regulation (EU) No 544/20117 and the guidance documents applicable at the date of submission of the application to the EMS are applicable (European Commission, 1997a,b,c,d,e,f,g, 2000, 2010a,b, 2017; OECD, 2011, 2013). 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 546/20118. As the joint review of MRLs for fosetyl and phosphonates under Article 43 of Regulation (EC) No 396/2005 is not yet finalised, the conclusions reported in this reasoned opinion may need to be reconsidered in the light of the outcome of the MRL review. A selected list of end points of the studies assessed by EFSA in the framework of these MRL applications including the end points of relevant studies assessed previously, are presented in Appendix B. The evaluation reports submitted by the EMSs (Austria, 2018; France, 2018; Germany, 2020; Greece, 2020,) and the exposure calculations using the EFSA Pesticide Residues Intake Model (PRIMo) are considered as supporting documents to this reasoned opinion and, thus, are made publicly available as background documents to this reasoned opinion. 1 Residues in plants 1.1 Nature of residues and methods of analysis in plants 1.1.1 Nature of residues in primary crops The metabolism of potassium phosphonates in primary crops was assessed during the EU pesticides peer review (EFSA, 2012b). It was concluded that data from the public literature are sufficient to address the metabolism in plants which mainly involves the transformation of potassium phosphonate salts into phosphonic acid. No further studies on the metabolism of potassium phosphonates in primary crops were submitted in the present MRL applications and are required. For the intended uses, the metabolic behaviour in primary crops is sufficiently addressed. 1.1.2 Nature of residues in rotational crops Among all crops under consideration garlic, shallots and horseradishes could be grown in rotation with other crops. According to the soil degradation studies evaluated in the framework of the EU pesticides peer review of fosetyl, moderate to high soil persistence (DT90 91 to > 1,000 days) is reported for phosphonic acid, which is a common metabolite of fosetyl, disodium phosphonate and potassium phosphonates (EFSA, 2018c). Therefore, transfer of soil residues from treatments of antecedent crops need to be considered. EFSA noted that no confined residue study is available for potassium phosphonates. However, due to the chemical nature of potassium phosphonates, no other breakdown products than phosphonic acid are expected, and therefore, studies addressing the nature of residues in rotational crops were not deemed necessary. Moreover, studies on the nature of residues in rotational crops (root/tuber crops, leafy crops and cereals) were assessed in the framework of the EU pesticides peer review of fosetyl (EFSA, 2018c) and support the conclusion that the metabolite phosphonic acid is the major residue observed in rotational crops. For the intended uses, the metabolic behaviour in rotational crops is sufficiently addressed. 1.1.3 Nature of residues in processed commodities The effect of processing on the nature of phosphonic acid, which is the main product produced from the metabolism of potassium phosphonates, was investigated in the framework of the EU pesticides peer reviews for potassium phosphonates and fosetyl (EFSA, 2012b, 2018c). These studies showed that phosphonic acid is hydrolytically stable under standard processing conditions representative of pasteurisation, baking/brewing/boiling and sterilisation. 1.1.4 Methods of analysis in plants Different analytical methods were previously assessed with view on their use for enforcement of the MRLs for potassium phosphonates (EFSA, 2012b, 2018c). Sufficiently validated methods using high-performance liquid chromatography with tandem mass spectrometry (HPLC–MS/MS) are available for the determination of residues as phosphonic acid and fosetyl in matrices with high water, dry/high starch, high acid and high oil content. The methods can be used for the determination of fosetyl in all plant commodity groups with an LOQ of 0.01 mg fosetyl/kg and for the determination of phosphonic acid in high water, high a
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