EPA Reg. No. 86363-19

1
Material Sen t fo r Dat a Extractio n

Reg. #

Description:

D Material(s ) Sen t to Dat a Extractio n Contractors

12 Ne w Stampe d Labe l Date d '0/31/ 1 1

D Notificatio n Dated _

D Ne w CSF(s ) Date d _

D Other : _

D Decisio n # \

Other Action/Comment s

File this covershee t and attached materials in the jacket. I t mus t be

well organized and clipped together, NO T STAPLED. The n give th e

jacket wit h th e coversheet and materials to staff in the Information

Services Center (ISC) (Roo m S-4900). I f a jacket i s full or only

available as an image, pleas e file material s in a new jacket an d bring i t

down to the (ISC) . Fo r further informatio n pleas e call 703-605-0716.

Reviewer: Maggi e Rudic k

Phone: 703-347-025 7 Division : RD/H B

Date:

2
U.S. ENVIRONMENTA L PROTECTIO N

AGENCY

Office o f Pesticide Programs

Registration Division (7505P)

Ariel Rios Building

1200 Pennsylvania Ave. , N W

Washington, D.C . 2046 0

NOTICE OF PESTICIDE:

x Registratio n

Reregistration

(under FIFRA, as amended)

EPA Reg. Number:

86363-19

Date of Issuance:

OCT 3 1 201 1

Term of Issuance: Unconditional

Name of Pesticide Product :

KT Propanil 80DF

Name and Address of Registrant (include ZIP Code) :

Scott Baker

Lighthouse Produc t Services

c/o Kaizen Technologies

1555 Mai n Street, Suite A3-205

Windsor, CO 80550

Note: Changes in labeling differing i n substance from tha t accepted i n connection wit h this registration must be submitted to and accepted by the

Registration Divisio n prior to use of the label in commerce. I n any correspondence on this product alway s refe r to the above EPA registration number .

On the basis of information furnishe d b y the registrant, the above name d pesticide is hereby registered/reregistere d unde r the Federal Insecticide,

Fungicide and Rodenticid e Act. Registratio n is in no way to be construed a s an endorsement o r recommendation o f this product by the Agency. I n order

to protect health and the environment, the Administrator, on his motion, may at any time suspend o r cancel the registration of a pesticide in accordanc e

with the Act. Th e acceptance of any name i n connection with the registration of a product under this Act is not to be construed a s giving the registrant a

right to exclusive use of the name or to its use if it has been covered by others.

The Basic Confidential Statement o f Formula (CSF) date d 08/05/2011 is acceptable.

This product is registered in accordance wit h FIFRA section 3(c)(5) provided that you:

1. Submi t and/or cite all data required for registration review/reregistration of your product when the

Agency requires all registrants of similar products to submit data.

2. Mak e the following labe l revision:

a. Revis e "EPA REG . NO. 86363-xx" to "EPA REG . NO. 86363-19."

b. Assur e that the establishment number and net contents are also added to the final printed

label.

3. Shoul d you wish to retain the company's website on your label, then please be aware that the

language presented i n the website becomes labelin g under the Federal Insecticide Fungicide and

Rodenticide Act and is subject to the false and misleading provisions of 40 CFR 156.10(a)(5) .

Therefore should the Agency find o r if it is brought to our attention that a website contains claims

substantially differing fro m th e EPA approved section 3 registration, the website will be referred

to the EPA's Office of Enforcement and Compliance Assurance.

4. Submi t one (1) copy of the revised final printed label for the record .

If these conditions are not complied with, the registration will be subject to cancellation in accordance with

FIFRA sec. 6(e). You r release for shipment of the product constitutes acceptanc e o f these conditions. A

stamped copy of the labe l is enclosed for your records.

3
If you have any questions regarding this notice, please contac t Maggi e Rudic k of my staff at 703-347-0257 o r

rudick.maggie@epa.gov.

Signature of Approving Official :

Kable Bo Davis, Produc t Manager 2 5

Herbicide Branc h

Registration Divisio n (7505P)

Date:

OCT 3 1 201 1

4
KT Propanil 80DF

Propanil Herbicid e

ACCEPTE D

OCT 3 1 201 1 ,

tfcdo? lha Fods?.a l

Fur

as amended , fo r Uw

For Postemergence Control of Broadleaf an d Grass Weeds in Rice: Fields

Aei,

°-HS- anfc3-i q

Active Ingredient:

Propanil: 3', 4'-Dichloropropionanilide 81.00 %

Other Ingredients: 19.00 %

TOTAL: 100.00 %

This product contains 0.8 Ib. of active ingredient per pound of formulated product.

EPA Reg. No. 86363-

EPA Est. No.

Net Contents:

KEEP OUT OF REACH OF CHILDREN

CAUTION

First Aid

If on skin or clothing:

• Tak e off contaminated clothing.

• Rins e skin immediately wit h plenty of water for 15-20 minutes .

• Cal l a poison control center or doctor for treatment advice .

If in eyes:

• Hol d eye open and rinse slowly and gently with water for 15-20 minutes.

• Remov e contact lenses, if present, after the first 5 minutes, then continue rinsing

eye.

• Cal l a poison control center or doctor for treatment advice.

If swallowed:

• Cal l a poison control center or doctor immediately for treatment advice .

• Hav e person sip a glass of water if able to swallow.

• D o not induce vomiting unless told to do so by a poison control center or

doctor.

Do not give anything by mouth to an unconscious person.

If inhaled:

• Mov e person to fresh air.

• I f person in not breathing, call 911 or an ambulance, then give artificial

respiration, preferable mouth-to-mouth, if possible.

• Cal l a poison control center or doctor for further treatment advice.

Have the product container or label with you when calling a poison control center or

doctor, or going for treatment.

Manufactured for:

Kaizen Technologies LLC

1555 Main Street

Suite A3-206

Windsor, CO 80550

102611

Page 1 of 18

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Precautionary Statements

Hazards to Humans and Domestic Animals

Caution. Harmful if swallowed or absorbed through skin. Causes moderate eye

irritation. Avoid contact with skin, eyes, or clothing.

Personal Protective Equipment (PPE)

Some materials that are chemical-resistant t o this product are natural rubber > 14

mils. Fo r more information, follow instructions in Supplement 3 of PR Notice 93-7. If

you want more options, follow the instructions for category A on an EPA chemicalresistant category selection chart.

Mixers, loaders, and other handlers exposed to the concentrate must wear:

• Coverall s over long-sleeve shirt and long pants,

• Chemical-resistan t glove s made of any waterproof material,

• Chemical-resistan t footwear plus socks,

• Chemical-resistan t headgear , if overhead exposure, and

• Chemica l resistan t apron.

Applicators and other handlers exposed to the dilute must wear:

• Long-sleeve d shirt and long pants,

• Shoe s plus socks, and

• Chemical-resistan t gloves made of any waterproof material

See Engineering Control s for additional requirement s and options.

Follow manufacturer's instruction s for cleaning/maintaining PPE. If no such

instructions for washables exist, use detergent and hot water. Keep and wash PPE

separately from other laundry. Discar d clothing or other absorbent materials that have

been drenched or heavily contaminated with this product's concentrate. Do not reuse

them.

Engineering Controls :

When handlers us e closed systems in a manner that meet the requirements listed in

the Worker Protection Standard (WPS) for agricultural pesticides [40 CFR 170.240 (d)

(4-6)], the handler PPE requirements ma y be reduced or modified as specified in the

WPS.

Pilots must use an enclosed cockpit that meets the requirements liste d in the Worker

Protection Standard (WPS) for agricultural pesticides [4 0 CFR 170.240 (d)(6)] .

Human flagging prohibited. Flaggin g to support aerial application is limited to use of

the Global Positioning System (GPS) or mechanical flaggers.

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User Safety Recommendations

Users should :

• Wash hands before eating, drinking, chewing gum, using tobacco or using the

toilet.

• Remov e clothing/PPE immediately i f pesticide gets inside. Then wash

thoroughly and put on clean clothing.

• Remove PPE immediately afte r handling this product. Wash the outside of

gloves before removing. As soon as possible, wash thoroughly and change

into clean clothing.

Environmental Hazards

This pesticide i s toxic to fish and aquatic invertebrates. Do not apply directly to water

except as specified on this label. Do not contaminate water when cleaning equipment

or disposing of equipment washwater s or rinsate.

This chemical ha s properties and characteristics associated with chemicals detecte d

in groundwater. The use of this chemical prior to flooding may result in shallow

groundwater contamination due to cracks in the subsoil of the rice paddy.

This produc t ma y contaminat e wate r throug h runof f following rainfal l event s an d b y

seepage through levees. Runoff of this product will be reduced by avoiding application

when rainfal l i s forecasted t o occu r withi n 4 8 hours . Levee s shoul d b e constructed

with adequate time prior to chemical application s o that they are compacted to reduce

seepage and to hold a 3 to 6 inch flood.

Notice: Read the entire label. Use only according to label directions. Before

using this product, read Warranty Disclaimer, Inherent Risks of Use, and

Limitation of Remedies elsewhere on the label. If terms are unacceptable, return

at once unopened.

Directions for Use

It is a violation of Federal la w to use this product in a manner inconsistent with its

labeling.

Read all Directions for Use carefully before applying.

Do not apply this product in a way that will contact workers or other persons, either

directly or through drift. Only protected handlers may be in the area during application.

For any requirements specific to your state or tribe, consult the agency responsible for

pesticide regulation.

Do not plant or transplant crops in the treated area for at least 60 days following an

application of this product .

Page 3 of 18

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Agricultural Use Requirements

Use this product only in accordance with its labeling and with the Worker Protection

Standard, 40 CFR part 170. This Standard contains requirements for the protection of

agricultural workers on farms, forests, nurseries, and greenhouses, and handlers of

agricultural pesticides. I t contains requirements for training, decontamination, notification,

and emergency assistance. It also contains specific instructions and exceptions pertaining

to the statements on this label about personal protective equipment (PPE) and restrictedentry interval. The requirements in this box only apply to uses of this product that are

covered by the Worker Protection Standard.

Do not enter or allow worker entry into treated areas during the restricted entry interval

(REI) of 24 hours.

PPE required for early entry to treated areas that is permitted unde r the Worker Protection

Standard and that involves contact with anything that has been treated, such as plants, soil

or water, is:

• Coveralls ,

• Chemical-resistan t glove s made of any waterproof materials,

• Chemical-resistan t footwear plus socks, and

• Protectiv e eyewear

Storage and Disposal

Do not contaminate water, food, or feed by storage or disposal.

Pesticide Storage: Do not use, pour, spill or store near heat or open flame. If the entire

contents are not used, protect remaining material from moisture and heat. Resealing by

rolling top down and storage under roof are recommended. Keep containers closed when

not in use.

Pesticide Disposal: Pesticide wastes are toxic. Improper disposal of excess pesticide,

spray mixture or rinsate is a violation of Federal Law. Wastes resulting from the use of this

product must be disposed of on site or at an approved waste disposal facility. If these

wastes cannot be disposed of by use according to label instructions, contact your State

Pesticide or Environmental Control Agency, or the Hazardous Waste representative at the

nearest EPA region office for guidance.

Container Handling: Nonrefillable container. Do not reuse or refill this container .

Completely empty bag into application equipment. Then, offer for recycling, if available or

dispose of empty bag in a sanitary landfill or by incineration, or, if allowed by State and

local authorities, by burning. If burned, stay out of smoke.

Steps to be taken in Case Material is Released or Spilled: Sweep or shovel into

containers for disposal or reworking. Keep dusting to a minimum. Flus h contaminated are

with a large amount of water to a chemical or sanitary sewer containing a settling pit.

Product Information

KT Propanil 80DF for postemergence weed control in rice is formulated as an 80%

active dry flowable formulation. KT Propanil 80DF is not a hormone-type herbicide, but

kills susceptible weeds by direct contact action. Fo r this reason, thorough coverage of

emerged weeds is essential for best results. KT Propanil 80DF has no preemergence

or residual herbicidal activity. Only weeds that have emerged and are exposed at time

Page 4 of 18

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of application will be controlled. Apply KT Propanil 80DF only to fields that have been

drained of floodwater. KT Propanil 80DF is most effective if applied when susceptible

grasses and broadleaf weeds are small and growing actively under favorable soil

moisture and weather conditions. Early weed control removes weed competition from

the rice crop, saves moisture, and generally contributes to increased yields.

Read Mixing and Equipment labe l instructions before application. When tank

mixing, always read all individual manufacturers' labels. In interpreting all labels for

the tank mixture, the most restrictive situations must apply.

Chemigation: D o not apply this product through any type of irrigation system

SPRAY DRIFT MANAGEMENT

Avoiding spray drift at the application site is the responsibility of the applicator and the

grower. The interaction of many equipment and weather related factors determine the

potential for spray drift. The applicator and the grower are responsible for considering

all these factors when making decisions.

The following drift management requirements must be followed to avoid off-target drift

movement from ground and aerial applications to agricultural field crops.

• Appl y only when the wind speed is less than or equal to 10 mph at the

application site.

• Appl y as a medium or coarser spray (ASABE standard 572.1).

• Fo r ground applications, appl y using a nozzle height of no more than 4 feet

above the ground or crop canopy.

• Fo r aerial applications, do not apply by air if drift can occur to sensitive nontarget crops or plants that are within 10 0 feet of the application site. Do not

release spray at a height greater than 10 feet above the ground or crop

canopy. The boom length must not exceed 75% of the wingspan or 90% of

the rotor blade diameter. Do not make any type of application into

temperature inversions. When applications are made with a cross-wind, the

swath will be displaced downwind. The applicator must compensate for this

displacement at the downwind edge of the application area by adjusting the

path of the aircraft upwind.

Where states have more stringent regulations, they must be followed.

The applicator should be familiar with and take into account the information covered in

the following Aerial Drift Reduction Advisory.

Aerial Drift Reduction Advisory

Information on Droplet Size: The most effective way to reduce drift potential is to

apply large droplets. The best drift management strategy is to apply the largest

droplets that provide sufficient coverage and control. Applying larger droplets reduces

drift potential, but will not prevent drift if applications are made improperly, or under

Page 5 of 18

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unfavorable environmental conditions (see Wind, Temperature and Humidity, and

Temperature Inversions) .

Controlling Droplet Size:

• Volum e - Use high flow rate nozzles to apply the highest practical spray

volume. Nozzles with higher rated flows produce larger droplets.

• Pressur e - Use the lower spray pressures recommended for the nozzle.

Higher pressure reduces droplet size and does not improve canopy

penetration. When higher flow rates are needed, use higher flow rate

nozzles instead of increasing pressure.

• Numbe r of Nozzles - Use the minimum numbe r of nozzles that provide

uniform coverage.

• Nozzl e Orientation - Orienting nozzles so that the spray is released

parallel to the airstream produces larger droplets than other orientations

and is the recommended practice. Significant deflection from horizontal

will reduce droplet size and increase drift potential.

• Nozzl e Type - Use a nozzle type that is designed for the intended

application. With most nozzle types, narrower spray angles produce larger

droplets. Consider using low-drift nozzles. Solid stream nozzles oriented

straight back produce the largest droplets and the lowest drift.

Application Height: Applications should not be made at a height greater than 10 feet

above the top of the largest plants unless a greater height is required for aircraft

safety. Making applications at the lowest height that is safe reduces exposure of

droplets to evaporation and wind.

Swath Adjustment: When applications are made with a cross wind, the swath will be

displaced downwind. Therefore, on the up and downwind edges of the field, the

applicator must compensate for this displacement b y adjusting the path of the aircraft

upwind. Swath adjustment distance should increase with increasing drift potential

(higher wind, smaller drops, etc.). .

Wind: Drift potential is lowest between wind speeds of 2-10 mph. However, many

factors, including droplet size and equipment type, determine drift potential at any

given speed. Application should be avoided below 2 mph due to variable wind

direction and high inversion potential. Note: Local terrain can influence wind patterns.

Every applicator should be familiar with local wind patterns and how they affect spray

drift.

Temperature and Humidity: When making applications in low relative humidity, set

up equipment to produce larger droplets to compensate for evaporation. Droplet

evaporation is most severe when conditions are both hot and dry.

Temperature Inversions: Applications should not occur during a local, low level

temperature inversion because drift potential is high. Temperature inversions restrict

vertical air mixing, which causes small suspended droplets to remain in a

Page 6 of 18

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concentrated cloud. This cloud can move in unpredictable directions due to the light

variable winds common during inversions. Temperatur e inversion s are characterized

by increasing temperature with altitude and are common on nights with limited cloud

cover and light to no wind. They begin to form as the sun sets and often continue into

the morning. Their presence can be indicated by ground fog; however, if fog is not

present, inversion s can also be identified by the movement of the smoke from a

ground source or an aircraft smoke generator. Smoke that layers and moves laterally

in a concentrated cloud (under low wind conditions) indicates an inversion, while

smoke that moves upwar d and rapidly dissipates indicate s good vertical air mixing.

Sensitive Areas: The pesticide should only be applied when the potential for drift to

adjacent sensitive areas (e.g., residential areas, bodies of water, know n habitat for

threatened or endangered species, non-target crops) is minimal (e.g. , when wind is

blowing awa y from the sensitive areas).

For Use on Rice Grown in California Only

Restrictions

• Preharves t Interval: Do not apply this product within 60 days of rice

harvest.

• Chemigation : Do not apply this product through any type of irrigation

system.

• D o not appl y more than a maximum o f 7.5 Ib of KT Propanil 80DF (6 Ib

active ingredient) pe r acre in a single application or exceed 1 0 Ib of KT

Propanil 80DF (8 Ib of active ingredient) per acre total dosage per season.

• I n California: Use KT Propanil 80DF only where rice fields are

completely draine d or a minimal amount of water remains. If high water

level is desired, re-floo d field after 12 hours and before 7 days after

treatment. This will discourage new weed infestations.

• D o not appl y this product to any crop other than rice. KT Propanil 80DF

will cause injury to most crops except cereal grains and perennial grasses.

• D o not apply this product (directly o r indirectly) to wild rice (Zizania

spp.).

• Avoi d drift or accidental application from turning aircraft on beans,

cucurbits, cotton , soybeans, corn, safflower, seedling legumes ,

vegetables, orchards , vineyards, gardens, shrubs and ornamentals. Once

applied, K T Propanil 80DF does not release fumes hazardous to nearby

crops.

• Application s to fields where catfish farming i s practiced and drain water

from treated fields int o areas where catfish farming is practiced is

prohibited.

• D o not graze treated fields or feed treated forage within 60 days of the

last application.

• D o not rotat e treated land to other crops or transplant to crops other than

rice for 60 days following treatment of this product.

• D o not appl y this product within 14 days before or after carbamate or

organophosphate insecticide applications. Otherwise, serious injuries to

Page7.of18

11
rice may occur.

• Wate r drained from treated rice fields must not be used to irrigate

other crops or released within 1/2 miles upstream of a potable

water intake in flowing water (e.g. river, stream, etc,) or within 1/2

miles of a potable water intake in a standing body of water, such as

a lake, pond, or reservoir.

• D o not apply when weather conditions favor drift from area to be

treated.

Emergency Release Provisions

Do not discharge water from treated rice paddies in California following treatment,

unless excessive rainfall completely submerges the rice crop and forces premature

release, for:

• 7 days in dry seeded rice in California

• 7 days for water-seeded rice in California

Weeds Controlled

Annual sedges

Barnyardgrass

 a

Crabgrass

Early watergrass

 a'D

Junglerice

 a

Late watergrass

 a'D

Ricefield bullrus h

Rice flatsedge

Smallflower umbrell a plan t

Cyperus spp .

Echinochloa crus-galli

Digitaria spp .

Echinochloa oryzoides

E. colonum

Echinochloa phyllopogon

Scirpus mucronatus

Cyperus iria

Cyperus difformis

a

 I n isolated instances, biotypes of barnyardgrass/watergrass may develop that

cannot be effectively controlled by propanil alone. Where these biotypes are known or

suspected to be present, and are found in a mixed weed population in which KT

Propanil 80DF is effective, tank mix KT Propanil 80DF at labeled rate with other rice

herbicides that are recommended for control of barnyardgrass/watergrass (up to the 3

leaf stage).

b

 Application s to early and late watergrass made past the 4 leaf stage will result in

partial control.

Timing and Dosage

Early Timing and Rates

Apply KT Propanil 80DF when a satisfactory stand of rice has been established that

will tolerate flooding. The amount of KT Propanil 80DF to apply depends upon the

growth stage and condition of the target weeds. KT Propanil 80DF is most effective if

applied when susceptible grasses and broadleaf weeds are small and actively growing

under favorable soil moisture and weather conditions. Use a higher rate in the rate

range for heavy weed infestations, weeds in advanced stages of growth, or when

growing conditions are less than optimum. Emergenc y treatments made to weeds in

advanced growth stages, such as when grass weeds are tillering, mus t occur at least

60 days before harvest.

Page 8 of 18

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For best results, apply KT Propanil 80DF at the rate of 3.75 to 5 Ib (3 to 4 Ib active

ingredient) pe r acre when the grasses are actively growing in the 1 to early 4 leaf

stage. This rate will also control many seedling broadleaf and aquatic weeds.

Generally, this will be 15 to 25 days after planting.

Mid-Timing and Rates

KT Propanil 80DF can be applied at the rate of 5 to 7.5 Ib (4 to 6 Ib active ingredient)

per acre to actively growing grasses in the 4 to 6 leaf and early tillering stage, or when

they are in the 2 to 4 leaf stage but stressed under dry soil conditions. Generally, this

will be 20 to 30 days after planting.

Use of Surfactants: The addition of a crop oil concentrate at 1 to 2 pints per acre, or

other 80% active nonionic surfactant at a rate of 1 to 2 pints per 100 gallons of spray

mixture, is recommended .

Rescue Timing and Rates

Apply KT Propanil 80DF at the rate of 6.25 to 7.5 Ib (5 to 6 Ib active ingredient) in 15

gallons of spray per acre for emergency control of older tillering grass. Generally, this

will be 30 to 40 days after planting. If the field is already flooded, the water should be

lowered or drained before spraying to expose more of the grass and weeds.

Emergency treatment should be considered as a salvage operation only and cannot

be relied upon for total control of grass and weeds.

Mixing Directions

KT Propanil 80DF will disperse more quickly if water temperature is 50°F or warmer.

Use only clean water for spraying. With the pump and agitator running, slowly add the

specified amount of KT Propanil 80DF into a partially filled mix tank. The jet or tank

agitators must be positioned to create a rippling or rolling action on the liquid surface

and to provide complete agitation at the bottom of the tank, preventing dead spots

where the material can accumulate. A centrifugal pump is suggested to provide

additional propeller shea r action for dispersing an d mixing this product. To avoid

foaming, kee p filling and bypass lines below the liquid surface. KT Propanil 80DF

must be completely dispersed and mixed prior to application.

If a tank mixture is to be applied, always conduct a compatibility test prior to use by

mixing proportional amounts of all spray ingredients in a test vessel (jar). The order of

addition to water should be dry flowables or wettable powders first, flowables second,

liquid formulations third, and crop oil concentrate last. Allow for each material to go

into solution prior to the addition of the next material. Shak e the mixture vigorously

and allow it to stand for fifteen minutes. Rapid precipitation of the ingredients and

failure to re-suspend when shaken indicates that the mixture is incompatible and

should not be applied.

As each material is added to the spray mixture, always allow for complete mixing

before adding the next ingredient. Add crop oil concentrate last and continue agitation

while filling the mixing tank to the desired spray volume.

Page 9 of 18

13
Do not ad d KT Propanil 80DF directly to the spray tank of aircraft. Once properly

dispersed in mix tank, pump spray mixture to aircraft spray tank (include rinsate from

mix tank). To ensure uniformity of sprays, maintain good agitation throughout

application.

Application Equipment

Aircraft

Fixed wing aircraft or helicopters should have well-designed spray systems that

produce a uniform pattern of medium or coarser spray droplets. Apply KT Propanil

80DF in no less than 10 gallons of total spray per acre with boom-nozzle sprayers .

Increase volume to 12 to 15 gallons per acre for larger or denser stands of grass or

during periods of low humidity.

The optimum effective spray swath width depends o n operating condition s an d type of

aircraft being used. For uniform spray coverage with fixed-wing aircraft or helicopter,

spray swath width should not exceed the width of wing span or rotor plus 10%.

Measure the swaths accurately for flagging.

Ground Sprayers

Use standard low-pressure herbicide boom sprayers equipped with flat fan nozzles.

Use nozzle sizes that deliver medium or coarser droplets in 15 to 20 gallons total

spray per acre at 40 to 50 psi and at ground speeds not in excess of 3 to 4 mph.

Adjust boom height so nozzle spray patterns meet uniformity. Avoid raising boom too

high.

Flush all equipment with clear water after each day's use. Clean all equipment,

including nurs e tanks, used for KT Propanil 80DF, with detergent wash followed by a

water rinse, before and after spraying other pesticides or other crops.

Crop Tolerance and Growing Conditions

All leading commercial varieties of rice are exceptionally tolerant to KT Propanil 80DF.

A temporary yellowing or tip burn of rice may be noted after treatment, but new growth

is normal. Severe leaf burn and partial killing of rice may occur if the product is applied

when rice is under stress and in a weakened growth condition due to disease or insect

infestations, excessive soil salts, overwatering, or prolonged drought and extremely

hot weather. Growers are cautioned not to spray under such conditions and/or when

maximum daily temperatures hav e been or are expected to exceed 100°F .

Effect of Climatic Conditions and Cultural Practices on Weed Control

Field and Seedbed Preparation

Fields should be accurately leveled and contoured and have well-prepared seedbeds

free of clods. Such conditions encourage unifor m and rapid emergence o f rice, grass

and broadleaf weeds, allowing more accurate timing and coverage of KT Propanil

80DF sprays for optimum weed control.

Page 10 of 18

14
Water Management

Before application of KT Propanil 80DF, drained or dry planted fields should be

flushed as often as necessary to prevent drying and crusting. Flushing encourages

uniform emergence and vigorous growth of grass, broadleaf weeds and rice, which is

essential for optimum weed control. Flushing of fields should occur when weeds and

rice are actively growing at time of treatment. Make sure the field is drained prior to

treatment so that grasses and broadleaf weeds are fully exposed. Weeds that are

partially submerged i n standing water at time of application will not be satisfactoril y

controlled.

Treated fields should be flooded before a second infestation of grass develops. To

prevent additional grass weed seed from germinating, ric e fields should be flooded

within 24 hours after spraying, or as soon as possible afte r 24 hours.

Temperature

The temperature a few days before and after applying KT Propanil 80DF has an

important effect on the weed-killing activity . The activity increases as daily maximum

temperatures increas e above 75°F and decreases as the daily maximum

temperatures decline below 75°F. Do not apply KT Propanil 80DF when maximum

temperatures have been or are expected to stay below 65°F or exceed 100°F. Less

than optimum temperature at time of application is not critical so long as the

temperature exceed s 75eF during the day.

Relative Humidity and Rain

Grasses and weeds are more responsive to KT Propanil 80DF during periods of high

humidity when the foliage i s moist or covered by dew. When the humidity i s very low,

spray tends to evaporate before reaching weed foliage. For best results under low

relative humidity conditions, increase spray volume to 12 to 15 gallons per acre. Do

not spra y if rain is expected within 8 hours to avoid loss of deposited spray and

herbicide adsorption by the weeds.

Wind

Do not appl y when the wind speed exceeds 10 mph to avoid drift hazard to sensitive

crops and the possibility o f uneven (streaked) applications.

Compatibility With Other Chemicals

Tank mix applications of KT Propanil 80DF with other herbicides, insecticides, spray

adjuvants, or liquid fertilizers may reduce crop tolerance and/or weed control or impair

mixing properties. Us e of these products in tank mix applications with KT Propanil

80DF is done at the user's risk.

Adverse Reaction to Insecticides

Rice plants may be severely injured or killed if KT Propanil 80DF is applied in tank mix

combinations or sequentially before or after certain insecticides. D o not combine KT

Propanil 80DF with carbamate insecticides such as carbaryl, etc., or

organophosphorus insecticide s (such as malathion and methyl parathion, etc). Do not

Page 1 1 of 18

15
apply any of the carbamate or organophosphorus insecticides to rice fields within 14

days before or after KT Propanil 80DF.

Do not apply KT Propanil 80DF to rice fields planted with rice seed treated with bird

repellents containing methiocarb. Consult local Extension specialist for current

recommendations of approved insecticides o n rice

For Use on Rice Grown in Southern United States Only

Arkansas, Florida, Louisiana, Mississippi, Missouri, South Carolina,

Tennessee, Texas

Restrictions

• Preharves t Interval: Do not apply this product within 60 days of rice

harvest.

• Chemigation : Do not apply this product through any type of irrigation

system.

• D o not appl y more than a maximum o f 7.5 Ib of KT Propanil 80DF (6 Ib

active ingredient) pe r acre in a single application or exceed 1 0 Ib of KT

Propanil 80DF (8 Ib of active ingredient) pe r acre total dosage per season.

• D o not apply this product to any crop other than rice. KT Propanil 80DF

will cause injury to most crops except cereal grains and perennial grasses .

• D o not apply this product (directly or indirectly) to wild rice (Zizania

spp.).

• Avoi d drift or accidental application from turning aircraft on beans,

cucurbits, cotton, soybeans, corn, safflower, seedling legumes,

vegetables, orchards , vineyards, gardens, shrubs and ornamentals. Once

applied, KT Propanil 80DF does not release fumes hazardous to nearby

crops.

• Application s to fields where catfish farming is practiced and drain water

from treated fields into areas where catfish farming is practiced is

prohibited.

• D o not graze treated fields or feed treated forage within 60 days of the

last application.

• D o not rotate treated land to other crops or transplant to crops other than

rice for 60 days following treatment of this product.

• D o not apply this product within 14 days before or after carbamate or

organophosphate insecticide applications . Otherwise, serious injuries to

rice may occur.

• Wate r drained from treated rice fields must not be used to irrigate

other crops or released within 1/2 miles upstream of a potable

water intake in flowing water (e.g. river, stream, etc,) or within 1/2

miles of a potable water intake in a standing body of water, such as

a lake, pond, or reservoir.

• D o not apply when weather conditions favor drift from area to be

treated.

Page 12 of 18

16
Emergency Release Provisions

Water holding (discharge) interval s for flood water from treated rice paddies following

treatment i n the United States :

• Fo r delayed flood (water-seeded) rice grown south of Interstate Highwa y 10

from the Texas/Louisiana border to Houston and east of State Highway 35 from

Houston to Port Lavaca- Flood water must be held for 10 days after application,

unless excessive rainfal l completely submerge s the rice crop and forces

premature release . For Texas rice grown in areas north or west of these

boundaries, the water holding interval will be 7 days.

• Fo r delayed flood (water-seeded) rice in southern Louisiana south of Highway

14 - Floo d water must be held for 15 days after propanil application, unless

excessive rainfall completely submerges the rice crop and forces premature

release. For delayed flood (water-seeded) ric e in Louisiana, north of the

Highway 14 boundary, the water holding interva l is 7 days.

• Fo r rice in CA and all other parts of the United States not mentioned above -

Flood water must be held for 7 days after application unles s excessive rainfal l

completely submerges th e rice crop and forces premature release.

Weeds Controlled

KT Propanil 80DF provides selective postemergenc e control of the following weeds in

rice: Annual sedges

Barnyardgrass

 a

Beakrush (spearhead)

Broadleaf signalgrass

Crabgrass

Curly dock

Foxtail

Goosegrass

Gulf cockspur

Hemp sesbania (coffeebean)

Hoorahgrass

Junglerice

 a

Mexicanweed

Paragrass

Redroot pigweed

Redweed

Rice flatsedge

Smallflower umbrella plant

Spikerush (wiregrass )

Texas panicu m

Watergrass

 a

Woolly croton

Cyperus spp .

Echinochloa crus-galli

Rhynchospora corniculata

Bracharia platyphytia

Digitaria spp .

Rumex crispus

Setaria spp .

Eleusine indica

Echinochloa crus-pavonis

Sesbania herbacea

Fimbristylis miliaceae

E. colonum

Caperonia castanaefolia

Panicum purpurascens

Amaranthus retroflexus

Melochia corchorifolia

Cyperus iria

Cyperus difformis

Eleocharis spp .

Panicum texanum

Echinochloa spp .

Croton spp .

Page 13 of 18

17
a

 I n isolated instances, biotypes o f barnyardgrass/watergrass ma y develop that

cannot be effectively controlled by propanil alone. Where these biotypes are known or

suspected to be present, and are found in a mixed weed population in which KT

Propanil 80DF is effective, tank mix KT Propanil 80DF at labeled rate with other rice

herbicides that are recommended for control of barnyardgrass/watergrass (up to the 3

leaf stage).

Timing and Dosage

Early Timing and Rates

Apply KT Propanil 80DF when a satisfactory stand of rice has been established that

will tolerate flooding. The amount of KT Propanil 80DF to apply depends upo n the

growth stage and condition of the target weeds. KT Propanil 80DF is most effective if

applied when susceptible grasses and broadleaf weeds are small and actively growing

under favorable soil moisture and weather conditions. Use a higher rate in the rate

range for heavy weed infestations, weeds in advanced stages of growth, or when

growing conditions are less than optimum. Emergenc y treatments made to weeds in

advanced growth stages, such as when grass weeds are tillering, mus t occur at least

60 days before harvest.

For best results, apply KT Propanil 80DF at the rate of 3.75 to 5 Ib (3 to 4 Ib active

ingredient) pe r acre when the grasses are actively growing in the 1 to early 4 leaf

stage. This rate will also control many seedling broadleaf and aquatic weeds.

Generally, thi s will be 15 to 25 days after planting.

Mid-Timing and Rates

KT Propanil 80DF can be applied at the rate of 5 to 7.5 Ib (4 to 6 Ib active ingredient )

per acre to actively growing grasses in the 4 to 6 leaf and early tillering stage, or when

they are in the 2 to 4 leaf stage but stressed unde r dry soil conditions. Generally, this

will be 20 to 30 days after planting.

Use of Surfactants: The addition of a crop oil concentrate at 1 to 2 pints per acre, or

other 80% active nonionic surfactant at a rate of 1 to 2 pints per 100 gallons of spray

mixture, is recommended.

Rescue Timing and Rates

Apply KT Propanil 80DF at the rate of 6.25 to 7.5 Ib (5 to 6 Ib active ingredient) i n 15

gallons of spray per acre for emergency control of older tillering grass. Generally, this

will be 30 to 40 days after planting. If the field is already flooded, the water should be

lowered or drained before spraying to expose more of the grass and weeds.

Emergency treatment should be considered as a salvage operation only and cannot

be relied upon for total control of grass and weeds.

Mixing Directions

KT Propanil 80DF will disperse more quickly if water temperature is 50°F or warmer.

Use only clean water for spraying. With the pump and agitator running, slowly add the

specified amount of KT Propanil 80DF into a partially filled mix tank. The jet or tank

Page 14 of 18

18
agitators must be positioned to create a rippling or rolling action on the liquid surface

and to provide complete agitation at the bottom of the tank, preventing dead spots

where the material can accumulate. A centrifugal pump is suggested to provide

additional propeller shear action for dispersing and mixing this product. To avoid

foaming, kee p filling and bypass lines below the liquid surface. KT Propanil 80DF must

be completely disperse d and mixed prior to application.

If a tank mixture i s to be applied, always conduct a compatibility test prior to use by

mixing proportiona l amounts of all spray ingredients i n a test vessel (jar). The order of

addition to water should be dry flowables or wettable powders first, flowables second,

liquid formulations third, and crop oil concentrate last. Allow for each material to go

into solution prior to the addition of the next material. Shake the mixture vigorously

and allow it to stand for fifteen minutes. Rapid precipitation of the ingredients and

failure to re-suspend when shaken indicates that the mixture is incompatible an d

should not be applied.

As each material i s added to the spray mixture, always allow for complete mixin g

before adding the next ingredient. Add crop oil concentrate last and continue agitation

while filling the mixing tank to the desired spray volume.

Do not add KT Propanil 80DF directly to the spray tank of aircraft. Once properly

dispersed i n mix tank, pump spray mixture to aircraft spray tank (include rinsate from

mix tank). To ensure uniformity o f sprays, maintain good agitation throughout

application.

Application Equipment

Aircraft

Fixed wing aircraft or helicopters should have well-designed spray systems that

produce a uniform pattern of medium or coarser spray droplets. Apply KT Propanil

80DF in no less than 10 gallons of total spray per acre with boom-nozzle sprayers .

Increase volume to 12 to 15 gallons per acre for larger or denser stands of grass or

during periods of low humidity.

The optimum effective spray swath width depends on operating conditions and type of

aircraft being used. For uniform spray coverage with fixed-wing aircraft or helicopter,

spray swath width should not exceed the width of wing span or rotor plus 10%.

Measure the swaths accurately fo r flagging.

Ground Sprayers

Use standard low-pressure herbicide boo m sprayers equipped with flat fan nozzles.

Use nozzle sizes that deliver medium or coarser droplets in 15 to 20 gallons total

spray per acre at 40 to 50 psi and at ground speeds not in excess of 3 to 4 mph.

Adjust boom height so nozzle spray patterns meet uniformity. Avoid raising boom too

high.

Flush all equipment with clear water after each day's use. Clean all equipment,

Page 15 of 18

19
including nurse tanks, used for KT Propanil 80DF, with detergent wash followed by a

water rinse, before and after spraying other pesticides or other crops.

Crop Tolerance and Growing Conditions

All leading commercial varieties of rice are exceptionally tolerant to KT Propanil 80DF.

A temporary yellowing or tip burn of rice may be noted after treatment, but new growth

is normal. Severe leaf burn and partial killing of rice may occur if the product is applied

when rice is under stress and in a weakened growth condition due to disease or insect

infestations, excessive soil salts, overwatering, or prolonged drought and extremely

hot weather. Growers are cautioned not to spray under such conditions and/or when

maximum daily temperatures have been or are expected to exceed 100°F.

Effect of Climatic Conditions and Cultural Practices on Weed Control

Field and Seedbed Preparation

Fields should be accurately leveled and contoured and have well-prepared seedbeds

free of clods. Such conditions encourage uniform and rapid emergence of rice, grass

and broadleaf weeds, allowing mor e accurate timing and coverage of KT Propanil

80DF sprays for optimum weed control

Water Management

Before application of KT Propanil 80DF, drained or dry planted fields should be

flushed as often as necessary to prevent drying and crusting. Flushing encourages

uniform emergence an d vigorous growth of grass, broadleaf weeds and rice, which is

essential for optimum weed control. Flushing of fields should occur when weeds and

rice are actively growing at time of treatment. Make sure the field is drained prior to

treatment so that grasses and broadleaf weeds are fully exposed. Weeds that are

partially submerged i n standing water at time of application will not be satisfactorily

controlled.

Treated fields should be flooded before a second infestation of grass develops. To

prevent additional grass weed seed from germinating, ric e fields should be flooded

within 24 hours after spraying, or as soon as possible after 24 hours.

Temperature

The temperature a few days before and after applying KT Propanil 80DF has an

important effect on the weed-killing activity. The activity increases as daily maximum

temperatures increas e above 75°F and decreases as the daily maximum

temperatures decline below 75°F. Do not apply KT Propanil 80DF when maximum

temperatures hav e been or are expected to stay below 65°F or exceed 100°F. Less

than optimum temperature at time of application is not critical so long as the

temperature exceeds 75eF during the day.

Relative Humidity and Rain

Grasses and weeds are more responsive to KT Propanil 80DF during periods of high

humidity when the foliage is moist or covered by dew. When the humidity is very low,

spray tends to evaporate before reaching weed foliage. For best results under low

Page 16 of 18

20
relative humidity conditions , increase spray volume to 12 to 15 gallons per acre. Do

not spra y if rain is expected within 8 hours to avoid loss of deposited spray and

herbicide adsorption by the weeds.

Wind

Do not appl y when the wind speed exceeds 10 mph to avoid drift hazard to sensitive

crops and the possibility of uneven (streaked) applications.

Compatibility With Other Chemicals

Tank mix applications of KT Propanil 80DF with other herbicides, insecticides, spray

adjuvants, or liquid fertilizers may reduce crop tolerance and/or weed control or impair

mixing properties. Use of these products in tank mix applications with KT Propanil

80DF is done at the user's risk.

Adverse Reaction to Insecticides

Rice plants may be severely injured or killed if KT Propanil 80DF is applied in tank mix

combinations or sequentially before or after certain insecticides. Do not combine KT

Propanil 80DF with carbamate insecticides such as carbaryl, etc., or

organophosphorus insecticides (such as malathion and methyl parathion, etc.). Do not

apply any of the carbamate or organophosphorus insecticides to rice fields within 14

days before or after KT Propanil 80DF.

Do not apply KT Propanil 80DF to rice fields planted with rice seed treated with bird

repellents containing methiocarb. Consult local Extension specialist for current

recommendations of approved insecticides o n rice.

LIMIT OF WARRANTY AND LIABILITY IMPORTANT: READ BEFORE USE

Read the entire Direction s for Use, Conditioris, Disclaime r of Warranties and

Limitations o f Liability befor e using this product. If terms are not acceptable, return the

unopened product container at once.

By using this product, user or buyer accepts the following Conditions, Disclaimer of

Warranties and Limitations of Liability .

CONDITIONS: The directions for use of this product are believed to be adequate and

must be followed carefully.

However, it is impossible t o eliminate al l risks associated with the use of this product.

Crop injury, ineffectiveness or other unintended consequences may result because of

such factors as weather conditions, presence of other materials, or the manner of use

or application, all of which are beyond the control of Kaizen Technologies LLC. To the

extent consistent with applicable law , all such risks shall be assumed by the user or

buyer.

DISCLAIMER OF WARRANTIES: TO THE EXTENT CONSISTENT WITH

APPLICABLE LAW, KAIZE N TECHNOLOGIES LLC MAKES NO OTHER

WARRANTIES, EXPRESS OR IMPLIED, OF MERCHANTABILITY OR OF FITNESS

Page 1 7 of 18

21
FOR A PARTICULAR PURPOSE OR OTHERWISE, THAT EXTEND BEYOND THE

STATEMENTS MADE ON THIS LABEL. To the extent consistent with applicable law,

no agent of Kaizen Technologies LL C is authorized to make any warranties beyond

those contained herein or to modify the warranties contained herein. TO THE

EXTENT CONSISTENT WITH APPLICABLE LAW, KAIZEN TECHNOLOGIES LLC

DISCLAIMS ANY LIABILITY WHATSOEVE R FO R SPECIAL, INCIDENTAL O R

CONSEQUENTIAL DAMAGES RESULTING FROM THE USE OR HANDLING OF

THIS PRODUCT.

LIMITATIONS O F LIABILITY: TO THE EXTENT CONSISTENT WITH APPLICABLE

LAW, THE EXCLUSIVE REMEDY OF THE USER OR BUYER FOR ANY AND ALL

LOSSES, INJURIES OR DAMAGES RESULTING FROM THE USE OR HANDLING

OF THIS PRODUCT, WHETHER I N CONTRACT, WARRANTY, TORT,

NEGLIGENCE, STRICT LIABILITY OR OTHERWISE, SHAL L NOT EXCEED THE

PURCHASE PRICE PAID, OR AT KAIZEN TECHNOLOGIES LLC'S ELECTION, THE

REPLACEMENT OF PRODUCT.

Page 18 of 18

22
W - r RE : Propanil New Products - 86363-EN and 86363-RO

Scott Baker to : Maggi e Rudick 10/26/201 1 05:32 PM

2 attachments

A» A »

-••a. i«« »

KT Propanil 4 SC Label 102611.pdf KT Propanil 80 DF Label 102611.pdf

Maggie,

Attached are revised labels per your comments. However , I do need a little

help on 86363-RO you asked for a triple rinse statement, I am not familiar

with what you are looking fo r here, I cannot find anything i n PRN 2007-4

pertaining to dry products in plastic bags which references tripl e rinsing ,

can you please give me some more guidance on what you are looking for here?

Thanks,

Scott Baker

Lighthouse Product Services

Regulatory & Supply Chain Consulting

Lighting the Path of Your Product Needs

3937 Cedarwood Lan e

Johnstown, C O 80534

970-313-6654

Fax 970-667-4010

Original Message

From: Rudick.Maggie@epamail.epa.gov [mailto:Rudick.Maggie@epamail.epa.gov ]

Sent: Wednesday, October 26, 2011 2:59 PM

To: sbaker@lhpsonline.co m

Subject: Propanil New Products - 86363-EN and 86363-RO

Mr. Baker,

Please see attached labels for KT Propanil 4SC and KT Propanil 80D F dated

August 11, 2011. Pleas e make the marked changes and submit clean copies

back to me. I f you have any questions o r concerns, don't hesitate to call

or email me.

Thank you!

Maggie L. Rudick

U. S. Environmental Protection Agency

Registration Division

Herbicide Branch; Team 25

(703) 347-0257

Rudick.MaggieOepa.gov

(See attached file: Propanil -RO with EPA markup.pdf)(See attached file:

KT Propanil 4 SC Label 072711 with EPA markup.pdf)

23
PRIA 2-2 1 Da y Content Scree n Review Workshee t

(EPA/OPP Us e Only)

3/23/09

21 Day Screen Start Date: _ ^ - / 5~ - / / _

Date £'/"?-// Fe e Paid: Yes

Yes _ Dat e _

Experts In-Processing Signature :

Division management contacted o n issues N o

EPA Reg. Number: EPA Receipt Date:

Items for Review Yes No N/A*

Application Form (EPA Form 8570-l)(lin k to form) signed & complete

including package type X

Confidential Statement of Formula all boxes completed, form signed, and

dated (EPA Form 8570-4 ) (Link to form) X

a) Al l inerts (link to http://www.epa.gov/opprd001/inerts/),

including fragrances, approved for the proposed uses (see

Footnote A)

yes

X

no

Certification wit h Respec t to Citation of Data (EPA Form 8570-34) (Lin k to

form) completed an d signed (N/A if 100% repack )

Certificate and data matrix consistent x_

If applicant is relying on data that are compensable, is the offe r

to pay statement included, (see Footnote B)

yes no

If applicable, is there a letter of Authorization for exclusive use only.

Formulator's Exemption Statement (EPA Form 8570-27 ) (Lin k to form)

completed an d signed (N/A if source is unregistered o r applicant owns the

technical) X

Data Matrix (EPA Form 8570-35) (Link to form) both internal and external

copies (PR 98-5) (Link to PR 98-5) completed an d signed (N/A if 100%

repack)

a) Selectiv e Method (Fee category experts use)

b) Cite-All (Fee category experts use)

c) Applicant owns all data (Fe e category experts use)

yes

5 Copies of Label (link to http://www.epa.gov/oppfeadl/labeling/lrm/ )

(Electronic labels on CD are encouraged and guidance is available)( link to

http://www.epa.gov/pesticides/regulating/registering/submissions/index.htmttlabels

24
Is the data package consisten t wit h PR Notice 86-5 (lin k to PRN 86-5) X

Notice of Filing (link to

http://www.epa.gov/pesticides/regulating/tolerance petitions.htm ) included

with petitions (lin k to

http://www.epa.gov/pesticides/regulating/tolerances.htm)

If applicable for conventional applications, reduce d risk rational e (lin k to

http://www.epa.gov/opprd001/workplan/reducedrisk.html)

Required Dat a (link to

http://www.epa.gov/pesticides/regulating/data requirements.htm ) and/o r

data waivers. Se e Footnote C.

10

a) Lis t study (or studies) not included with application

25
Comments:

V-

* N/A - Not Applicable

Footnotes

A. Durin g the 21 day initial content review, all CSFs will be reviewed to determin e

whether all inerts listed, including fragrances, are approved for the proposed uses. I f an

unapproved inert is identified, the applicant must either 1 ) resolve the inert issue by, for

example, removing the inert, substituting it with an approved inert, submittin g

documentation that EPA approved the inert for the proposed pesticida l uses, correcting

mistakes on the CSF, etc. or 2) provide the data to support OPP approval of the inert or 3)

withdraw the application. Removin g or substituting an inert ingredient will require a new

CSF and may require submission of data. Al l information, forms, dat a and

documentation resolving the inert issue must have been received by the Agency or the

application withdrawn within the 21 day period, otherwise, the Agency will reject the

application as described below.

To successfully complet e this aspect of the 21 day initial content screen , applicants are

strongly encouraged to verify that all inert ingredients have been approved for the

application's use s even if a product is currently registered by consulting the inert Web

3

26
site [link to http://www.epa.gov/opprd001/inerts/lists.htmn an d if the inert is not

approved, to obtain the necessary inert approval prior to submitting an application

to register a pesticide product containing that inert ingredient. Som e inert

ingredients ar e no longer approve d for food uses or certain type s of uses. Th e name

and/or CAS number on a CSF must match the name and CAS number on this web site.

Simple typographical errors in the name or CAS number have resulted in processing

delays.

If an inert is not listed on the inert ingredient web site and the applicant believes that the

inert has been approved , the applicant should contact the Inert Ingredient Assessmen t

Branch (IIAB) at inertsbranch @epa.gov and resolve the issue. Copie s o f the

correspondence wit h IIAB resolving the issue should accompany th e application. Al l

new inerts excep t PIP inerts are reviewed by IIAB. Th e IIAB should also be contacted

for any questions on what supporting dat a needs to be submitted for and the Agency's

inert review process. Question s o n PIP inerts should be directed t o the Chief of

Microbial Pesticides Branc h [Link to

http://www.epa.gov/oppbppdl/biopesticides/contacts bppd.html .

When a brand, trade, or proprietary name of an inert ingredient is listed on a CSF,

additional information such as an alternate name of the inert, CAS number or other

information [lin k to http://www.epa.gov/opprd001/inerts/tips.pdf1 must also be included

to enable the Agency to determine if it has been approved. Eac h component of an inert

mixture (including a fragrance) must be identified. I n some cases, the supplier of the

mixture or fragrance may need to provide this information to the Agency. Prio r to the

Agency's receipt of an application, applicants must arrange with a proprietary mixture or

fragrance supplie r to provide the component informatio n to the Agency or promptly upon

EPA's request. I f the inert ingredients in a proprietary blend (including fragrances)

cannot or are not identified o r provided within the 21-day content review period, the

Agency will reject the application .

During the 21 day content review, applicants should submit information to the individual

identified by the Agency when the applicant is informed of an unapproved inert.

Unapproved Inerts Identified on CSFs

All applications except conventiona l new products and PIPs

Once an unapproved inert is identified on a CSF, the Agency will contact th e

applicant with the following options:

1. Correc t the application by, for instance, correcting th e inert's identity or CAS

number, providing documentation that the inert has been approved, or

removing the unapproved inert from the CSF or replacing it with one that is

approved for the application's uses; or

2. Submi t the information and data needed fo r the Agency to approve the

unapproved inert. I f this option is selected an d implemented, the Agency may

request an extension in the PRIA decision review timeframe to accommodat e

the inert review/approval process;

27
3. Withdra w the application (the Agency retains 25% of the full fe e for the fee

category estimated); or

If none of these options is selected and implemented by the applicant within the

21 day content review period, the Agency will reject the application and retain

25% of the full fee of the category identified.

Conventional New Product Application s

When the Registration Division identifies an unapproved inert on a CSF with an

application for a new product that the applicant has not identified as requiring an

inert approval (R311, R312 or R313), it will contact the applicant with the

following options:

1. Correc t the application by, for instance, correctin g the inert's identity or CAS

number, providing documentation tha t the inert has been approved, or

removing the unapproved inert from the CSF or replacing it with one that is

approved for the application's uses; or

2. Submi t the information and data needed for the Agency to approve the

unapproved inert, including any required petition to establish or amend a

tolerance or exemption from a tolerance. (Thi s option may change the PRIA

category for the application, which could require a longer decision review

time and a larger fee. I f additional fees ar e due, they must be received by the

Agency within the 21 day content review period.)

3. Withdra w the application (the Agency retains 25% of the full fe e for the fee

category estimated); or

If none of the above options is selected an d implemented during the 21-day

content-review period, the Agency will reject the application and retain 25% of

the appropriate fee for the new product-inert approval category.

PIP Applications

When the Biopesticide and Pollution Prevention Division identifies an

unapproved inert on a PIP CSF and a request to approve the inert does not

accompany the application, it will contact the applicant with the following

options:

1. Correc t the application by, for instance, correcting the spelling or name of the

inert to that in 40 CFR 174 , or providing documentation that the inert has been

approved; or

2. Submi t the information and data needed for the Agency to approve the

unapproved inert. I f an inert ingredient tolerance exemption petition is

required, the petition must be received by the Agency and the B903 fee paid

within the 21 day period. I f this option is selected and implemented, the

Agency will discuss harmonizing the timeframe for both actions.

5

28
3. Withdra w the application (the Agency retains 25% of the full fe e for the fee

category estimated); or

If none of the above options is selected an d implemented during the 21 day

content review period, the Agency will reject the application and retain 25% of

the fee.

B. A policy on documentation of offers t o pay is still being developed, however, for a

me-too or fast track (similar/identical) new product, R300 or A530, an application

without the necessary authorization s of offers t o pay will be placed into either R301 or

A531. Th e Agency recommends tha t authorizations of offers t o pay be submitted with

other PRIA applications to avoid delays in the Agency's decision.

C. Biopesticid e applicants are advised to contact the Agency and discuss study waivers

prior to submitting their application to the Agency. Documentatio n of such discussions

should be submitted with the study waiver. .

29
R 300 and 30 1

I

100% identical (repack): YE S or Ccircle one")

{If yes, it's a 100% repack - then product chemistry, acute toxicity and efficacy dat a

are not required }

Data on Group and A and B must be submitted - Group A and B can not be cited.

Guideline

No.

830.1550

830.1600

830,1650

830.1670

830.1700

830.1750

830.1800

Group A: Produc t Chemistry Data

Study Title

Product Identity & Composition

Description o f materials used to produce the

product

Description of formulation process

Discussion on the formation of impurities

Preliminary analysis

Certified limits (158.345 )

Enforcement analytical method

Data

submitted

Yes

<S

^

/

/

z/

No

X

Guideline

No.

830.6302

830.6303

830.6304

830.6314

830.6315

830.6316

830.6317

830.6319

830.6320

830.6321

830.7000

830.7100

830.7300

Group B: Produc t Chemistry Data

Study Title

Color

Physical State

Odor

Oxidation/Reduction (Chemica l

incompatibility)

Flammability

Explodability

Storage stability

Miscibility

Corrosion Characteristics

Dielectric Breakdow n voltage

PH

Viscosity

Density

Data

submitted

Yes

^

/

/

/

/

/

/

/

S

S

/

/

~7

No

30
t

R 300 and 30 1

New products must provide a bridging rationale document. Th e bridging document

directs OPP to use a currently registered se t of 6 acute toxicity data and label; instead

of submitting product specific data.

Guideline

No.

870.1100

870.1200

870.1300

870.2400

870.2500

870.2600

Acute toxicity ( 6 pack)

Study Title

Acute Oral (LD50)

Acute Dermal (LD50 )

Acute Inhalation (LC50)

Acute Eye Irritation

Acute Dermal Irritatio n

Dermal Sensitization

Cited

Yes

-^

/

/

^

'

s

No

Efficacy - which guideline depends on the proposed label use and they must cite the

data to be used for the bridging rationale.

Guideline

No.

810.3100

810.3200

810.3300

810.3400

810.3500

810.3600

810.3800

Efficacy Study Titles

Soil Treatments for Imported Fire Ants

Livestock, Poultry, Fur and Wool-Bearin g

Animal Treatments

Treatments to Control Pest s of Humans

and

Pets

Mosquito, Black Fly, and Bitin g Midge

(Sand Fly) Treatments

Premises Treatments

Structural Treatments

Methods for Efficacy Testing of Termite

Baits

Cited

Yes No

X

PC

y

y

y

\

v

Comments

31
UNITED STATES ENVIRONMENTAL PROTECTIO N AGENCY

WASHINGTON, D.C . 2046 0

August 17, 2011

OFFICE OF

PREVENTION, PESTICIDES AN D

TOXIC SUBSTANCES

OPP Decision Number: D-45324 5

EPA File Symbol or Registration Number: 86363-RO

Product Name: K T PROP ANIL 80DF

EPA Receipt Date: 15-Aug-201 1

EPA Company Number: 86363

Company Name: KAIZE N TECHNOLOGIES, LLC

SCOTT BAKER

LIGHTHOUSE PRODUCT SERVICES

KAIZEN TECHNOLOGIES, LLC

3937 CEDARWOOD LANE

JOHNSTOWN, CO 80534 -

SUBJECT: Receip t of Application and 75% Small Business Waiver Request

Dear Registrant:

The Office o f Pesticide Programs has received your application, 75% small business

waiver request, and certification of payment. I f you submitted data with this application, the

results of the PRN-86-5 screen will be communicated separately. Durin g the administrative

screen, the Office o f Pesticide Programs has determined that this Action is subject to a Pesticide

Registration Servic e Fee as defined in the Pesticide Registration Improvement Act.

The Action has been identified as Action Code: R300

NEW PRODUCT;ME-TOO PRODUCT FAST TRACK;

Your request for waiver has been forwarded for review. Yo u will be notified in writing when a

determination is made regarding your request. I f your waiver request is approved, the decision

review time period will start on the date of approval. I f your waiver request is denied, you will

receive an invoice for the outstanding balance.

If you have any questions , please contact the Pesticide Registration Service Fee

Ombudsman at (703) 308-9362.

Sincerely,

Front End Processing Staff

Information Technology & Resources Management Division

32
|Fee for Servce (g o 1502q~

This package includes the following

®New Registration

0

 Amendment

D

 Studies?

 D Fee Waiver?

D

volpay % Reduction:

for Division

°AD

°BPPD

®RD

Risk Mgr. 25

Receipt No. S -

EPA File Symbol/Reg. No.

Pin-Punch Date:

901502

86363-RO

8/15/2011

This item is NOT subject to FFS action.

Action Code:

Requested:

Granted:

Amount Due:

Parent/Child Decisions:

Inert Cleared

Reviewer:

Remarks:

for Intended Use Uncleared Inert in Product

_ Date :

33
Scott Baker

From: paygovadmin@mail.doc.twai.go v

Sent: Thursday , August 11, 2011 2:16 PM

To: sbaker@Lhpsonline.co m

Subject: Pay.Go v Payment Confirmation

THIS IS AN AUTOMATED MESSAGE . PLEAS E DO NOT REPLY.

Your transaction ha s been successfully completed .

Transaction Summary

Application Name: PRIA Service Fee s

Pay.gov Trackin g ID: 254531MK

Agency Tracking ID: 74227746518

Name On Account: Lighthous e Product Services Transactio n Type : ACH

Debit Transaction Amount: $358.50 Payment Date: Aug 12., 2011 Account

Type: Busines s Checking Routing Number: Account Number:

##*###******9354

Transaction Date : Aug 11, 2011 4:16:14 PM Number of Payments

Scheduled: 1

Frequency: OneTime

Decision Number:

Registration Number : 86363-

Company Name: Kaizen Technologies LL C

Company Number: 86363

Action Code : R300

34 *Commercial/financial information may be entitled to confidential treatment*
WRA

Wagner Regulator y Associates / Inc .

P.O. Bo x 640

7217 Lancaster Pike, Suite A

Hockessin, Delawar e 1970 7

July 7, 2011

Mr. Kable Davis

Registration Division (7504P)

U.S. Environmental Protection Agency

Office o f Pesticide Programs

Room S-4900 , One Potomac Yar d

2777 Sout h Crystal Driv e

Arlington, Virginia 22202-450 1

RE: Authorizatio n to access Willowood USA LLC registration data

Dear Mr. Davis,

Willowood USA LLC hereby authorizes the US EPA to access, reference and use the

below listed data owned and submitted by Willowood USA LLC to support the named

product registration application for Kaizen Technologies, LLC. The composition and

formulation o f Willowood Propanil 4SC and KT Propanil 4SC are identical. The

composition and formulation o f Willowood Propanil 80DF and KT Propanil 80DF ar e

also identical.

Product:

KT Propanil 4SC

KT Propanil 80DF

Applicant:

Kaizen Technologies, LL C - EPA Company No . 8636 3

1555 Main Street, Suit e A3-20 6

Windsor, CO 80550

• •

• •

• • • ••

• •

• ••• •

35
WRA

Wagner Regulator y Associates, Inc .

P.O. Bo x 640

7217 Lancaste r Pike, Suite A

Hockessin, Delawar e 1970 7

Willowood Propanil 80D F

MRID No.

48333401

MRID No.

48333402

MRID No.

48333403

Wagner Regulatory Associates, Inc . (2010) Willowood Propanil 80D F

Product Identity and Composition, Description o f Beginning Materials,

Manufacturing Process, and Discussion o f Formation of Impurities.

Willowood LLC, Roseburg, OR. Non-confidential portion 6 pages,

Confidential portio n 46 pages.

Wagner Regulator y Associates, Inc . (2010) Willowood Propanil 80D F

Preliminary Analysis, Certified Limits and Enforcement Analytical Method.

Willowood LLC, Roseburg, OR. Non-confidential portio n 6 pages,

Confidential portio n 1 5 pages.

Miller, Ronald (2010) Propanil 80DF Produc t Chemistry Volume III.

Analytical & Regulatory Chemistry, Inc., Sumter, South Carolina . Report

Number ARC-EX-858-004-P-1. 1 4 pages.

Willowood Propanil 4SC

MRID No.

48336301

MRID No.

MRID No.

Wagner Regulatory Associates, Inc . (2010) Willowood Propanil 4SC

Product Identity and Composition, Descriptio n o f Beginning Materials ,

Manufacturing Process, and Discussion o f Formation o f Impurities.

Willowood LLC, Roseburg, OR. Non-confidential portion 6 pages,

Confidential portion 59 pages.

Wagner Regulatory Associates, Inc . (2010) Willowood Propanil 4SC

Preliminary Analysis, Certified Limits and Enforcement Analytical Method .

Willowood LLC, Roseburg, OR. Non-confidential portion 6 pages,

Confidential portion 1 7 pages.

Miller, Ronald (2010) Propanil 4SC Product Chemistry Volume III.

Analytical & Regulatory Chemistry, Inc. , Sumter, Sout h Carolina . Report

Number ARC-EX-872-006-P-1. 1 5 pages.

If you have any questions concerning this authorization, please contact the undersigned at

302-635-7281 o r lori@wagnerreg.com .

•

• ••

Sincerely, . .

Lori Kohler

Agent for Willowood USA LLC

36
LIGHTHOUSE PRODUCT SERVICES

Regulatory an d Supply Chain Consultin g

Augusts, 2011

Subject: Offe r to Pay Data Compensation

Please be advised that Kaizen Technologies, (Kaizen ) 155 5 Main Street, Suite A3-206,

Windsor, C O 80550 ("Kaizen") has filed with the U.S . Environmental Protectio n Agency

an application t o register "KT PROPANIL 80DF, and KT PROPANIL 4SC, EPA Reg. No.

86363-XXXXX", which contains th e active ingredien t propanil , thi s application include s

uses supported by data that may have been provided by your company. I n support of its

request, Kaizen has indicated its reliance on data previously submitted by your company

to the extent that reliance on that data i s necessary t o support Kaizen applications and ,

further, Kaize n ha s indicate d tha t i t i s prepare d t o compensat e you r compan y a s i s

appropriate for the use of that data and in accordance with FIFRA § 3(c)(1)(F).

By thi s lette r Kaize n indicate s it s willingnes s immediatel y t o commenc e discussion s

looking toward a negotiated resolutio n of the data compensation issue . W e encourage

your review and confirmation of any data submitted to the Agency that may be relevant to

the Kaizen application, an d would appreciate receiving , at your earlies t convenience, a

list of the relevant study titles, their MRI D Numbers, and cost information for each of the

listed studies.

We suggest that an early meeting between our respective representatives would facilitate

resolution of the data compensation issue. I n this connection I urge that you direct your

representative to contact my office at your earliest convenience.

If no response is received within 60 days from the date of this letter, Kaizen will deem

that no compensation to your company is required.

Sincerely,

Scott Baker

Regulatory Agent

Does / does not own compensable data applicable to the subject registrations .

• •••

Does /does not require compensation for Kaizen Technologies citation of this data. •... .

By: Date :

Signature

..*•<

"SHINING TH E LIGHT ON YOUR REGULATORY NEEDS"

3937 Cedarwood Lane Johnstown , Colorado 80534

970-313-6654 Fax-970-667-401 0 sbaker@lhpsonline.co m

37
Form Approved. OMB No. 2070-0060. Approval Expire s 5-31-98 .

United States

1f^.DPA Environmenta l Protection Agency

^^•••l «^» Washington . DC 20460

Formulator's Exemption Statement

(40 CFR 152.85)

Applicant's Nam e and Address EP A File Symbol/Registration Numbe r

Kaizen Technologies

1555 Main Street, Suite A3-206

Windsor, CO 80550

86363-

Product Name

KT PROPANIL 80DF

Date of Confidential Statement o f Formula (EP A Form

8-5-11

As an authorized representative of the applicant for registration of the product identified above, I certify that:

(1 ) Thi s product contains the following activ e ingredient(s):

Propanil CAS #709-98-8

S570-4I

(2) O f these, each active ingredient listed in paragraph (4) is present solely as the result of the use of that active

ingredient in the manufacturing, formulation or repackaging another product which contains that active ingredient

which is registered under FIFRA Section 3, i s purchased by us from another producer, and is labeled for at least

each use for whic h my product is proposed to be labeled.

(3) Indicat e by checking (A) or (B) below which paragraph applies:

[Xj (A ) An accurate Confidential Statement of Formula (EPA FORM 8570-4) fo r the above identified produc t is

attached to this statement. That formula statement indicates, by company name, registration number, and product

name, the source of the active ingredient(s) listed in paragraph (1).

OR

|LJ (B ) The Confidential Statement of Formula (CSF) (EPA Form 8570-4) referenced above and on file with the EPA is

complete, current, and accurate and contains the information required on the current CSF.

(4) Th e following active ingredients i n this product qualify for the formulator's exemption.

Source

Active Ingredient

Propanil

Signature / ji/ O

Product Name

Name and Title

Scott Baker - Regulatory Agent

Registration Numbe r

•:• •:• .' . •:• .- . .

• : .'..:. v :

Date • fv •••,(• " "•" "

0 "j " ^ (

•

•

•

•

EPA Form 8570-27 (Rev. 8-95 )

* U.S . QPO: 199&-388-820/2O41 3

II I - EPA copy

' - Applicant copy

38 *Product ingredient source information may be entitled to confidential treatment*
Form Approved OMB No. 2070-006 0

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

401 M Street, S.W.

WASHINGTON, D.C. 2046 0

Paperwork Reduction Act Notice : Th e public reporting burden for this collection of information is estimated to average 1.25 hours per response for registration

and 0.25 hours per response for reregistration and special review activities, including time for reading the instructions an d completing the necessary forms. Sen d

comments regarding burden estimate or any other aspect of this collection of information, including suggestions for reducing the burden to: Director, OPPE

Information Management Division (2137), U.S. Environmental Protection Agency, 401 M Street, S.W., Washington, DC 20460.

Do not send the completed form to this address.

Certification with Respect to Citation of Data

Applicant's/Registrant's Name, Address, and Telephone Number

Kaizen Technologies, 1555 Main Street, Suite A3-206, Windsor, CO 80550

Active Inqredientfs) and/o r representative test comooundfs)

Propanil

General Use Pattem(s) (lis t al l those claimed for this product usinq 40 CFR Part 158)

Terrestrial foo d crop, Aquatic food crop (as specified on label)

EPA Registration Number/File Symbol

86363-

Date

August 5, 201 1

Product Name

KT PROPANIL 80D F

NOTE: If your product i s a 100% repackaging o f another purchased EPA-registere d produc t labeled for all the same uses on your label, you do not need to

submit this form. Yo u must submit the Formulator's Exemptio n Statement (EPA Form 8570-27).

D

I am responding t o a Data-Call-in Notice , and have included with this form a list of companies sent offers of compensation (the Data Matrix form should

be used for this purpose).

SECTION I: METHOD OF DATA SUPPORT (Chec k one method only)

D

I am using the cite-all method of support, and have included wit h this form

a list of companies sent offers of compensation (the Data Matrix form

should be used for this purpose).

0

1 am using the selective method of support (or cite-all option

under the selective method), and have included with this form a

completed list of data requirements (th e Data Matrix form must be

used).

SECTION II: GENERAL OFFE R TO PAY

[Required if using the cite-all method or when using the cite-all option under the selective method to satisfy one or more data requirements ]

[•I I hereby offer and agree to pay compensation, to other persons, with regard to the approval of this application, to the extent required by FIFRA.

SECTION III: CERTIFICATIO N

I certify that this application for registration, this form for reregistration, or this Data-Call-in respons e is supported by all data submitted or cited in the

application for registration, the form for reregistration, or the Data-Call-in response . I n addition, if the cite-all option or cite-all option under the selective method is

indicated in Section I, this application i s supported by all data in the Agency's files that (1) concern the properties or effects of this product or an identical or

substantially similar product, or one or more of the ingredients in this product; and (2) is a type of data that would be required to be submitted under the data

requirements in effect on the date of approval of this application i f the application sought the initial registration of a product of identical or similar compositio n an d

uses .

I certify that for each exclusive use study cited in support of this registration or reregistration, that I am the original data submitter or that I have obtaine d

the written permission of the original data submitter to cite that study.

• •• •

I certify that for each study cited in support of this registration or reregistration that is not an exclusive use study, either: (a) I am the original data

submitter; (b) I have obtained the permission of the original dat a submitter to use the study in support of this application; (c) all periods of eligiflilfty for

compensation have expired for the study; (d) the study is in the public literature; or (e) I have notified in writing the company that submitted the^Rioy a/id hav e

offered (I) to pay compensation t o the extent required by sections 3(c)(1)(F) and/or 3(c)(2)(B) of FIFRA; and (ii) to commence negotiations to'determine the

amount and terms of compensation, if any, to be paid for the use of the study. , • • •

I certify that in all instances where an offer of compensation is required, copies of all offers to pay compensation and evidence of ttieif d»lw«ry in t f

accordance with sections 3(c)(1 )(F) and/or 3(c)(2)(B) of FIFRA are available and will be submitted to the Agency upon request. Shoul d I fail to produce such •

evidence to the Agency upon request, I understand that the Agency may initiate action to deny, cancel or suspend the registration o f my product inceiformity with

FIFRA. *.. * • •• !

• •

I certify that the statements I have made on this form and al attachments to it are true, accurate, and complete. I acknowledge that any

knowingly false or misleading statement may be punishable by fine or imprisonment or both under applicable law .

"""" Xd&L -

Date

Augusts, 201 1

Typed or Printed Name and Title • • • • • °

Scott Baker - Regulatory Agen t

EPA Form 8570-34 (9-97) Electronic an d Paper versions available. Submit only Paper version.

39
Based on Form Approved OMB No. 2070-0060

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY . — • .

401 M Street, S.W.

WASHINGTON, D.C. 2046 0 •"•'. '

• • •

Paperwork Reduction Act Notice: Th e public reporting burden for this collection of information i s estimated to average 0.25 hour s per response for registration activitie s and 0.25 hours per •

reregistration and special review activities, including time for reading the instructions and completing the necessary forms. Sen d comments regardin g the burden estimate or any otrfer aspe'ct of thie«

collection of information, including suggestion s for reducing the burden to: Director , OPPE Information Managemen t Division (2137), U.S. Environmental Protec t on Agency, 401 M StjeeJ.S.W.,

Washington, DC 20460. D o not send the form to this address. *«. * I . .

DATA MATRI X

Date 08/05/20 1 1

Applicant's/Registrant's Name & Address

Kaizen Technologies, LLC , 1555 Main Street, Suite A3-206, Windsor, CO 80550

EPA Reg. No./File Symbo l 86363 - Jtoeell.of 2

Product . .

KT PROPANIL 80D F •

Ingredient(s) Propani l

Guideline Reference Number

830.1550

830.1600

830.1650

830.1670

830.1750

830.1800

830.1900

830.6302

830.6303

830.6304

830.6314

830.6315

830.6316

830.6317

830.6319

830.6320

830.6321

830-7000

860-7100

830.7300

Guideline Study Nam e

Product Identity and Composition

Description of Materials Used to Produce the Product

Description of Formulation Proces s

Discussion o f Formation of Impurities

Certified Limit s

Enforcement Analytical Method

Submittal of Samples

Color

Physical State

Odor

Oxidation / reductio n

Flammability/Flame Extensio n

Explodability

Storage Stability

Miscibility

Corrosion Characteristic s

Dielectric Breakdown Voltage

pH

Viscosity

Density

MRID Number

48333401

48333401

48333401

48333401

48333402

48333402

48333403

48333403

48333403

48333403

48333403

48333403

48333403

48333403

48333403

48333403

48333403

48333403

48333403

^ 1M1 _

Submitter

Willowood LLC

Willowood LLC

Willowood LL C

Willowood LL C

Willowood LLC

Willowood LL C

Willowood LLC

Willowood LLC

Willowood LLC

Willowood LL C

Willowood LLC

Willowood LLC

Willowood LLC

Willowood LL C

Willowood LLC

Willowood LLC

Willowood LLC

Willowood LL C

Willowood LLC

Status

LOA

LOA

LOA

LOA

LOA

LOA

LOA

LOA

LOA

LOA

LOA

LOA

LOA

LOA

LOA

LOA

LOA

LOA

LOA

Name and Title Scot t Baker

Regulatory Agent

Note

1

Date

08/05/201 1

Based on EPA Form 8570-35 (9-97) Electroni c an d Paper versions available. Submi t only Paper version. Agency Internal Use Copy

40
Based on Form Approved OMB No. 2070-0060

UNITED STATES ENVIRONMENTAL PROTECTION AGENC Y

401 M Street, S.W .

WASHINGTON, D.C. 2046 0

Paperwork Reduction Act Notice: Th e public reporting burde n for this collection of information is estimated to average 0.25 hours per response for registration activities and 0.25 (jours f er •

reregistration and special review activities, including time for reading the instructions and completing the necessary forms. Sen d comments regarding the burden estimate or any other aspec t of th««

collection of information, including suggestions for reducing the burden to: Director , OPPE Information Management Division (2137), U.S. Environmental Protection Agency, 401 M St{eei,»S>W.,

Washington, DC 20460 . D o not send the form to this address. *«, * « ,_ ,

DATA MATRI X ~~T ~ ~

Date 08/05/201 1 EPA Reg. No./File Symbol 86363 - t«o f 2

Applicant's/Registrant's Name & Address

Kaizen Technologies, LLC , 1555 Main Street, Suite A3-206, Windsor, CO 80550

Product

KT PROPANIL 80DF

Ingredient(s) Propani l

Guideline Referenc e Number

Name and Title Scot t Baker

Based on EPA Form 8570-35 (9-97) Electroni c an d Paper versions available . Submi t onl y Paper version.

41
Based on Form Approved OMBJYo* €070-0060

UNITED STATES ENVIRONMENTAL PROTECTIO N AGENC Y "•••• '

401 M Street, S.W. •"•' •

WASHINGTON, D.C. 20460 •". " . .

Paperwork Reduction Act Notice: Th e public reporting burden for this collection of information is estimated to average 0.25 hours per response for registration activitie s and 0.25 tiours per • •

reregistration and special review activities, including time for reading the instructions and completing the necessary forms. Sen d comments regardin g the burden estimate or any other aepsct of this

collection o f information, including suggestions for reducing the burden to: Director , OPPE Information Management Division (2137), U.S. Environmental Protection Agency, 401 M Street, 2.W., • •

Washington, DC 20460. D o not send the form to this address. . . .

DATA MATRIX •...; .

Date 08/05/20 1 1

Applicant's/Registrant's Nam e & Address

Kaizen Technologies, LLC , 1 555 Main Street, Suite A3-206, Windsor, C O 80550

EPA Reg. No./File Symbol 86363 - Page 2 o f 2

Product ••••• •

KT PROPANIL 80DF

Ingredient(s) Propani l

Guideline Referenc e Number

870.1100

870.1200

870.1300

870.2400

870.2500

870.2600

Guideline Study Name

Acute Oral Toxicity

Acute Dermal Toxicity

Acute Inhalation Toxicity

Acute Eye Irritation

Acute Dermal Irritation

Skin Sensitization

MRID Number

Cite-All

Cite-All

Cite-All

Cite-All

Cite-All

Cite-All

Si9"al"re

 .Jjfc&L -

Submitter Status

PAY

PAY

PAY

PAY

PAY

PAY

Name and Title Scot t Baker

Regulatory Agent

Note

2

2

2

2

2

2

Date

08/05/201 1

....

<

{

Based on EPA Form 8570-35 (9-97) Electronic an d Paper versions available. Submi t only Paper version. Agency Internal Use Copy

42
Based on Form Approved OMB/4o» £070-0060

UNITED STATES ENVIRONMENTA L PROTECTION AGENC Y

401 M Street, S.W.

WASHINGTON, D.C. 2046 0

Paperwork Reduction Act Notice: Th e public reporting burden for this collection of information is estimated to average 0.25 hours per response for registration activities and 0.25tiours per • •

reregistration and special review activities, including time for reading the instructions and completing the necessary forms. Sen d comments regarding the burden estimate or any other acp»ct of this

collection of information, including suggestions for reducing the burden to: Director , OPPE Information Management Division (2137), U.S. Environmental Protection Agency, 401 M Street, 3.W., • •

Washington, DC 20460. D o not send the form to this address. , , ,

DATA MATRI X

Date 08/05/201 1 EPA Reg. No./File Symbol 86363 - Page 2 o f 2

Applicant's/Registrant's Name & Address

Kaizen Technologies, LLC, 1555 Main Street, Suite A3-206, Windsor, CO 80550

Product

KT PROPANIL 80DF

Ingredient(s) Propani l

Guideline Reference Number Submitter Status

PAY

PAY

PAY

PAY

PAY

PAY

Name and Title Scot t Baker

Regulatory Agent

Note

Date

08/05/2011

Based on EPA Form 8570-35 (9-97) Electronic and Paper versions available. Submi t only Paper version.

43
1 . Submitta l of Samples

2. Offe r To Pay Letter

DATA MATRIX FOOTNOTES

Not required at this time for end use product s

Studies which offer to pay letter has been sent. See list below

EL D U PONT DE NEMOURS AND CO.,

inn? MARK-FT QTRFFT

ZMINGTON,DE 19898

MQNSANTO COMRANY

1300 I STREET, NW , SUITE 450 EAST

WASHINGTON.DC 2000 5

PROPAN|L TASK FQRCE

600 13T H STREET, NW

WASHINGTON.DC 20005

UNITED PHOSPHORUS, INC

KING OF PRUSSIA.PA 19406

Ripprn i i r

5100 TOPLAR AVENUE, SUITE 2428

MEMPHISJN 38137

• •

• •

•• • •

• •

••* •

44
LIGHTHOUSE PRODUCT SERVICES

Regulatory ind Suppl y Chai n Consulting

August 11, 201 1

Document Processin g Desk (REGIS)

Office of Pesticide Programs

U.S. Environmental Protection Agency

Room S-4900, One Potomac Yard

2777 S. Crystal Drive

Arlington, VA 22202

Subject: K T PROPANIL 80DF - EPA Reg. No. 86363-

Lighthouse Product Services, Regulatory Agent for Kaize n Technologies LLC, is submitting the enclosed

information t o support a new end use registration. Pleas e find the following enclosed:

1. EP A Form 8570-1 Application for Pesticide

2. Receipt for PRI A Fee

3. Lette r of Authorization for Produc t Chemistry Studies

4. EP A Form 8570-4 Confidential Statement of Formul a ( 2 copies)

5. EP A Form 8570-27 Formulator's Exemptio n Statement

6. EP A Form 8570-34 Data Citation

7. EP A Form 8570-35 Dat a Matrix

8. Cop y of Offer To Pay Letter

9. Produc t label: KT PROPANIL 4SC (5 copies)

10. Smal l Business Waiver Fee Request (Voluntary Small Business Certification Form) *

Please contact m e at 970-313-6654 or by e-mail: sbaker@lhpsonline.com if there are any questions or

comments concerning this submission.

Sincerely,

Scott Baker

Agent for Kaize n Technologies LLC.

"SHINING THE LIGHT O N YOUR REGULATOR Y NEEDS "

3937 Cedarwood Lane Johnstown , Colorado 80534

970-313-6654 Fax-970-667-401 0 sbaker@lhpsonline.co m

45
***e retd instruction* on r»v*r*f befon completing ITM Form Approvad. OMB^o . 2070-OO60. Approva l expire s 2-28-95

United States

Environmental Protection Agency

Washington. D C 20460

Registration

Amendment

Other

OPP Identifier Numbe r

Application for Pesticide - Section I

1. Company/Product Number

4. Company/Product (Name)

KT PROPANIL 80DF

2. EPA Product Manager

Davis

PM*

25

3. Proposed Classification

None Restricted

5. Name and Address of Applicant (Include ZIP Code)

Kaizen Technologies

1555 Main Street, Suit e A3-205

Windsor, CO 80550

6. Expedited Reveiw. I n accordance with FIFRA Sectio n 3(c){3)

(b)(i), my product is similar or identical in composition and labeling

to:

EPA Reg. No.

87290-17

Check if this is a new address Product Name

WILLOWOOD PROPANIL 80DF

Section - II

Amendment - Explain below.

Resubmission in response to Agenc y letter dated.

Notification - Explain below.

Rnal printed label s in repsonse to

Agency letter dated

"Me Too" Application .

Other - Explain below.

Explanation: Us e additional page(s) if necessary . (Fo r section I and Section II.)

R300, application for a new end use product.

Section - III

1. Material This Product Will B« Packaged In:

Child-Resistant Packaging

Yes

• No

* Certification must

be submitted

If "YesUnit Packagin g wgt.No. per

container

Water Soluble Packaging

Yes

• No

If "YesPackage wg tNo. per

container

_L

2. Type of Container

Metal

Plastic

Glass

Paper

Other (Specify)

3. Location of Net Contents Information

Label Container

4. Size(s ) Retai l Container

5, 10, 20lb, Supe r Sack s

5. Location of Label Directions

J Attache d to container

6. Manner in Which Label is Affixed to Produc t Lithograph

Paper glued

Stenciled

Other sel f adhesive

Section - IV

1. Contact Point (Complet e item s directly below for identification of individual to be contacted, i f necessary, to process this application.!

Name

Scott Baker

Title

Regulatory Agen t

Telephone No* {Include Area Code)

970-313-665% •"• "

Certification

I certify that the statements I have made on this form and all attachments thereto are true, accurate and complete.

I acknowledge that any knowlinglly fals e or misleading statement may be punishable b y fine or imprisonment or

both under applicable law.

2. Signature

4. Typed Name

Scott Bake r

3. Title

Regulatory Agent

5. Date

August 10, 201 1

6..Date,Applicat$)n * ' .

• (Stamped ) * • • • • • •• • •••• •

• •

EPA Form 8570-1 (Rev . 3-94) Previou s editions are obsolete. White - EPA File Copy (original ) Yello w - Applicant Copy

46
10/3 1 1,,

Confidential Bus/ness Information: Doe s Not Contain National Security Information (E.O . 12065 )

EPA For m 8570-4 (Rev. 2-85) Previous editions are obsolete inert s Approve d for Foo d Use under 40 CFR 180.920,

Pre-Harvest Application t o Growing Crops

47

*Confidential Statement of Formula may be entitled to confidential treatment*
48