UNITED STATES ENVIRmlMENTAL PROTECTION AGENCY

WASHINGTON, D.C. 20460

APIl 14 2011

OFFICE OF CHEMICAL SAfETY

AND POLLUTION PREVENTION

MEMORANDUM

SUBJECT:

FROM :

TIIRU:

TO:

BEAD Chemica l Profil e for Registration Review: Metsulfuron-methyl

(pc code 122010)

Bill Phillips, II, PhD, Agronomist

Biological Anal ysis Branch PII':. /.

Jihad , Alsadek, PhD, Economi

.

st <./

-rc,UII- if~4-

Science Information and Analysis Branch

Stephen Smearman, Economist II- L . 1. •. Economic Analysis Branch vlJlClfllJ/1 ~~

Biological and Economic Analysis Division (7503P)

Arnet Jones, Chief /~~~n;)~ Biological Analysis Branch l~"---' -

Sc

Diann

ience

Sim

Inf

s,

orm ation

Chief ~~and ~SBranch .

Timothy Kiely, Chief ( ..

Economic Analysis Branch

".J

Biological and Economic Andysk ivision Ci5.Ql.!

Jill Bloom, Chemical Review Manager

Risk Management and Implementation Branch 2

Pesticide Re-evaluation Division (7508P)

Product Review Panel date: March 23, 2011

INTRO DUCTION

The purpose ofthis document is to convey usage information and a broad overview ofthe pest

management roles of pesticides that are beginning to undergo registration review. The

anticipated audience consists ofthe team of EPA staff currently evaluating the registration status

of metsulfuron-methyl (pc code 122010). and eventually the general public . This doc ument

build s upon the data already provided in the "Usage and Label Use Data Packages" that are also

1
provided to Registration Review teams by BEAD. The document is based on information and

data available to BEAD as of February 16, 2011.

In agronomic product ion, metsulfuron-methyI is an herbicide that is used postemergence to

control broadleaf weeds in grass field/row crops (e.g. barley, pasture grass, wheat...),

horticultural crops (e.g. ornamental...) and tree plantations/nurseries. In addition, metsulfuronmethyl is used in non-crop areas such as dewatered areas (e.g. canals, flood plains, lakes.. .),

conservation reserve areas, fallow lands, forests, vegetation management areas (e.g. airport,

roadside... ), and turfgrass. Overall, the majority of agricultural use of this herbicide is in winter

and spring wheat followed by pastureland.

Metsulfuron-methyl is a sulfonylurea herbicide with the mechanism of action of inhibiting the

production of the enzyme acetolactate synthesis (ALS). The Herbicide Resistance Action

Committee and Weed Science Society of America classify this herbicide in group B/2. 1 There

are currently 43 different ALS resistant weed species in the United States. More than 30% of the

total resistant weed species in the United States are resistant to herbicides in this herbicide

family' As an example , the biotypes of the invasive exotic weed kochia (Kochia scoparia (L)

Roth) are resistant specifically to the herbicide metsulfuron-methyl, kochia is one ofthe more

difficult to control weeds that can significantly reduce crop growth and yield.

USE SITES

Agricultural Use Sites

There are many agricultural use sites for this herbic ide and they vary from grass row crops to

horticultural crops and various tree crops (For a detailed list of the specific crops see appendix

A).

Non-Agricultural Use Sites

There is a wide variety of non-agricultural use sites for this herbicide which include dewatered

areas, conservation reserve areas, fallow lands, pastures, rangeland, forests, vegetation

management areas, and turfgrass (For a detailed list of the specific areas see appendix B).

COMMON FORMULATIONS AND APPLICATION METHODS

Metsulfuron-methyl is formulated as a water dispersible granule and emulsifiable concentrate.

USAGE'

Agricultural

Based on private market pesticide usage data, the annual total agricultural usage averaged 31,000

pounds active ingredient (a.i.) for approximately 9 million acres for an overall average of 0.003

lb. a.i. per acre. The average a.i. rate for both winter and spring wheat is 0.003 lbs. a.i. per acre,

while the average a.i. rate for pastureland is 0.010 lbs. a.i. per acre. The use of metsulfuronmethyl, in pounds a.i., is mainly on winter wheat, spring wheat, and pastureland.'

I Herbicide Resistant Action Committee

http://www.hracglobal.comIPublications/ClassificationofHerbicideModeofActionitabidl222lDefault.aspx

2 ALS inhibitor Resistant Weeds Globally - 20 10 http://www.weedscience.org/summary/CounrrySummary.asp

l GfK Kynerec, 2004-2008

4 Ibid

2
From 1998-2008, the large st markets in terms of total pounds of activ e ingredient appl ied, in

order from highe st to lowest use, are winter wheat (58%), pasture/range (27%), and spring wheat

(8%). The use of metsulfuron-methyl, in terms ofthe acres treated from highest to lowest, are

winter wheat (74%), pastureland (10%), and spring wheat (8%) which did not change.

The states with the most agricultural usage in terms of pounds a.i. applied are Kansas (25%),

Oklahoma (17%), Texas (15%), and Montana (10%).

Non-Agricultural

Non-agricultural usage data are not available from our current data sources.

USE TRENDS'

Historical usage data from 1998-2008 are de tailed for winter wheat, spring wheat, and

pastureland in figures one, two , and three, respecti vely. The bar-graph in Figure I shows use on

winter wheat fluctuates from year to year with no clear trend. Similarly figure 2 shows use on

spring wheat fluctuates from year to year with a declining trend. Figure 3 shows a changing

pattern and a peak in 2004 for pastureland. {rfK Kynetec surveyed pasture/range from 1998 to

2004, and pastureland thereafter. Data have been combined and values for pastureland have

been calculated accordingly.

Figure I. Pounds of Metsulfuron-methyl Applied to Winter Wheat (1998-2008)

Winter Wheat

25 ,000 ,----- - - - --- - - - - - - - - -

Pounds A.I.

o L.,- L.,- L.,- L.,- -r-r- L.,- -r-r- L,

1998 1999 2000 2001 2002 2003 2004 2005 2006 2007 2008

Years

Figure 2. Pounds of Metsulfuron-methyl Applied to Spring Wheat (1998-2008)

S Ibid

3
Spring Wheat

5,000 -,------ - - - - - - - - - - - - - -

Pounds A.I.

o

1998 1999 2000 2001 2002 2003 2004 2005 2006 2007 2008

Yea rs

Figure 3. Pound s of Metsulfuron-methyl Applied to Pastureland (1998-2008)

Pat ureland

' 4,000 -,---------------------

PoundsA.I.

o

1998 1999 2000 2001 2002 2:>03 2004 2005 2006 2007 2008

veers

BIOLOGICAL ASPECTS RELEVANT TO METSULF URON-M ETHYL

Reported in the U.S., there are 43 weed species with biotypes resistant to herbicides in the family

to which metsulfuron-methyl belongs. This herbicide family has the largest number of herbicide

resistant weed biotypes in the United States. Of these weed biotypes there are a few weeds that

are specifically resistant to metsulfuron-methyl, including the broadleaf weed kochia. Kochia is

considered one of the "Most Important Herbicide-Resistant Species" as classified by the

International Survey of Herbicide Resistant Weeds

6

. This weed species has been demonstrated

to be difficult to control and reduces crop yields.'

6 Most Important Herbicide-Resistant Species http://www.wt edscience.orglWorstWeeds.GIF

7 Metsulfuron-methyl 60EG IVM. Arysta LifeSciences North America Corp.

http://www.cdms.net/LDat/ld87J000.pdf

4
In non-crop areas, including rangeland areas, metsulfuron-methyl is used to control annual and

perennial broadleaf weeds as well as brush weed species. While the use ofthis herbicide is

postemergence, there is some short-term residual weed control''. However, this is not considered

a typical use for this herbicide .

HISTORY OF BEAD ASSESSMENTS FOR METSULFURON-METHYL

BEAD found several Section 18 requests and alternative analyses for the use of metsulfuronmethyl on various weed species for the period 1999-20 IO. These include:

Section 18 Analyses

• Review of Kansas and Oklahoma Requests for Emergency Exemption of Metsulfuron for

Use in Sorghum to Control BroadleaiWeeds, especially Pigweed, Puncturevine and

Velvetleaf (99KS11 , 990K13). Final disposition - Withdrawn

• Review ofTexas Request for Emergency Exemption of Metsulfuron-methyl for Use in

Sorghum to Control Triazine-resistant Pigweeds (OO-TX-Ol). Final disposition - Issued

• Review of Request for Emergency Exemption for Use of Metsulfuron-methyl to Control

Triazine Resistant Weeds in Sorghum (02-CO-14)(DP Barcode D283520). Final

disposition - Withdrawn

• Review of Section 18 Exemption Requests from Texas (09-TX-15), (DP# 361715); (09-

TX-16), (DP# 361716) and Oklahoma (09-0K-02); (DP# 361729); (09-0K-03); (DP#

361731) for the Use of Pastora (Mixture ofNicosulfuron and Metsulfuron) to Control

Sandbur Species (Cenchrus spp.) in Bermudagrass (Cyanodon dactylon) Pastures and

Hay Fields. Final disposition - Withdrawn

• Review of Section 18 Emergency Exemption Requests from Texas (10-TX-02) (DP#

373875) and Oklahoma (IO-OK-OI) IDP# 374708) for the Use of Pastora (Mixture of

Nicosulfuron and Metsulfuron) to Control Sandbur Species (Cenchrus spp.) in

Bermudagrass (Cyanodon dactylon) Pastures and Hay Fields. Final disposition - Issued

Alternative Analyses

Inthe BEAD data base there are several analyses that included metsulfuron-methyl for use

on sites including: wheat, bermudagrass, sugarcane, pineapple, field com, and popcorn.

s Metsulfuron-methyl 60EG IVM. Arysta Lifegciences North America Corp.

http://www.cdms.net/LDatJld87JOOO.pdf

5
INFORMATION THAT MAY BE USEFUL FO R BEAD'S FUTURE WORK ON

METSULFURON-METHYL

Obtaining additional information on the following items would help to inform future BEAD

assessments of the importance of metsulfuron-methyl and may be required as part of the

registration review of this pesticide.

Usage data information, such as methods of application, is needed on the major non-agricultural

sites such as those listed in appendix S , Airports/Bare grounds/Barrier strips/Fallow

lands/Fencerows/Marshes/Railroads.

6
ApPENDIX A

AGRONOMIC USE S ITES FOR M ETSULFURON-METHYL9

BLAC KBERRIES (FOLIAR TR EATMENT)

BEAN S (DRY) (FOLIAR TREATM ENT)

ALFALFA (FOLIAR TREATMENT)

CEREAL CROPS (FOLIAR TREATMENT)

GRA IN CROPS (FOLIAR TREATMENn

BARL EY (FOLIAR TREATMENT)

BARL EY (SPRING) (FO LIAR

TREATMENT)

BAR LEY (WI NT ER) (FOLIAR

TREATMENT)

BARL EY (FA LLOW) (FOLIAR

TREATMEN T)

BARLEY (FALLOW) (SOIL TREAT ME NT)

BARLEY (SOIL TREATMENT)

BARL EY (WI NT ER) (SOIL TREATMENn

SO RGHUM (GRAIN) (FOLIAR

TREATMENn

SORGHUM (GRAIN) (SOI L TREATMENT)

WHEAT (FOLI AR TREATMENT)

WHE AT CDURUM) (FOLIA R

TREATM ENT)

WHEAT (FALL)(FOLIAR TREATMENT)

WH EAT (S PRING) (FOLIAR

TREATMENT)

WH EAT (WINTER) (FOLIAR

TREATM ENn

WHEAT (FALLO W) (FOLIAR

TREATMENT)

WH EAT (ABE) (WINTER) (FOLIA R

TREATMENT)

WH EAT (SOIL TREATMENT)

WH EAT (FALLOW) (SOIL TREATM ENT)

WHEAT (O URUM) (SOIL TREATMENT)

WHEAT (SPR ING) (SO IL TR EATMENT)

WHEAT (W INTER)(SO IL TREATMENT)

TRITICALE (FOLIAR TREATMENT)

TRITICA LE (SOI L TREATMENT)

ANNUAL BLUEGRASS (FOLIAR TREATMENT)

BFRMUDAGRASS (FOLIAR TREATMENT)

BERMU DAGRASS (LAWNS) (FO LIAR TREAT MENT)

BERMUDAGRASS (ORNAMEN TA L TURF) (FOLIAR

n:EATMENT)

BERM UDAGRASS (SO IL TREATMENT)

BFRMUDAGRASS (ORN AMENTAL TU RF) (SO IL

TI :EATM ENT)

BLUE GRA MAG RASS

BLUE GRA MAG RASS (FOLIAR TREATMENT)

Bl U E GRAMAG RASS (OR NAMENTAL TURF) (FOLIAR

~EATMENT)

BLUE GRA MAGRASS (SOIL TREATMENT)

BLUEGRASS (FOLIAR TREATMENT)

Bl U EGRASS (ORN AMENTAL TURF)(FOLIA R

TI :EATM ENT)

BLUEGRASS (SO IL TREATMENT)

BCFFALOGRASS (LA WNS) (FOLIAR TREAT MENT)

BCFFALOGRASS (ORNAMENTA L TURF) (FO LIAR

TEEATMENT)

BIJFFALOGRASS (FO LIAR TREATMENn

BIJFFALOGRASS (ORNAMENTAL TU RF) (SOIL

ATM ENT)

BIJFFALOGRASS (SOIL TREATMENT)

CII.RPETG RASS (O RN AMENTAL TU RF) (SOIL

TF ~EA TM ENT)

CENTIPEDEGRASS (ORNA MENTA L TURF) (FOLIAR

TEEATMENT)

CI NTIPEDEG RASS (FOLIAR TREATMENT)

CENTIPEDEGRASS (SOI L TREATM ENT)

CENTJPEDEGRASS (ORNAMENTA L TURF) (SOIL

TI :EATMENT)

CHESTED WH EATGRASS (OR NAMEN TAL TURF) (FOLIAR

TREATMENT)

CI:EST ED WHEATGRASS (FOLIAR TREATMENT)

CHEST ED WHEATGRASS (SOIL TREAT MENT)

EMERALD ZOY SIA

FESCUE (ORNAMENTA L TURF) (FOLIAR TREATMENT)

9 Information was obtained from the Agency' s database and has not been compared to the list of sites on the product

labels.

7
SUGA RCANE (FOLIAR TREATMENT)

SUGARCANE (SOIL TREATMENn

CORN (FIELD)(SOIL TREATMENn

COTTON (FOLIAR TREATMENT)

SOYBEANS (SOIL TREATMENn

MILLET (SOIL TREATMENT)

BARLEY (FOLIAR TREATMENT)

WHEAT (FOLIAR TREATMENT )

PASTURES (RYEGRASS) (FOLIAR

TREAT MENT )

PASTURES (RYEGRASS) (SOIL

TREATMENT)

SAND BLUESTEM (FOLIAR

TREATMENT)

PASTURES (GRASS) (FOLIAR

TREATMENT)

PASTURES (GRASS) (SO IL TREATMENT)

SWITCHGRASS (FOLIAR TREATMENT)

SWITCHGRASS (RA NGELAND) (FOLIAR

TREATM ENT)

SWITCIIGRASS (SO IL TREATMENT)

SWITCBGRASS (RANGELAND) (SOIL

TREATMENT)

WHEATGRASS (FOLIAR TREATMENn

PASTURES (WHEATGRASS) (FOLIAR

TREATME NT)

WHEATGRA SS (ORNAMENTAL TURF)

(FOLIAR TREATMENT)

PASTURES (BERMUDAGRASS)

PASTURES (BERMUDAGRASS) (FOLIAR

TREATMENT)

BERMUDAGRASS (FORAGE) (FOLIAR

TREATMENn

BERMUOAGRASS (PASTURES) (SOIL

TREATMENT)

SIDE-OATS GRAMA (FOLIAR

TREATMENT)

SIDE·OATS GRAMA (ORNAMENTAL

TURF)(FOLIAR TREATMENT)

SIDE-OATS GRAMA (SOIL TREATMENT)

LOVEGRASS (FOLIAR TREATMENT)

LOVEGRASS (SOIL TREATMENT)

LITTLE BLUESTEM (FOLIAR

TREATM ENT)

LITTLE BLUESTEM (RANGE LAND)

(FOLIAR TREATMENn

LITTLE BLUESTEM (ORNA MENTAL

TURF) (FOLIAR TREATMENT)

FESCUE (FOLIAR TREATMENn

FESCUE (:;OIL TREATMENn

KENTUCKY BLUEGRA SS (ORNAM ENTA L TURF)

(FOLIAR TREATMENT)

KENTUCKY BLUEGRASS (FOLIAR TREATMENn

KENTUCKY BLUEGRASS (ORNAMENTAL TURF) (SOIL

TREATMLNn

KENTUCK Y BLUEGRA SS (SOIL TREATM ENT)

ORCHARDGRASS (O RNAMENTAL TURF) (FOLIAR

TREATMENT)

ORCHARDGRASS (FOLIAR TREATMENT)

ORCHARDGRASS (SOIL TREATMENT)

RYEGRASS (PERENNIAL) (SOIL TREATMENT)

ST. AUGLI STINEGRASS (LAWNS ) (FOLIAR TREATMENT)

ST. AUGU STINEGRASS (ORNAMENTAL TURF) (FOLIA R

TREATMLNn

ST. AUGlI STINEGRASS (FOLIAR TREATMENT)

ST. AUGUSTINEGRA SS (ORNAMENTA L TURF) (SOIL

TREATMLN T)

ST. AUGUSTINEGRA SS (SOIL TREATMENT)

ST. AUGUSTINEGRASS (FLORATAM) (LAWNS ) (SO IL

TREATMENT)

ST. AUGUSTINEGRA SS (GROWN FOR SOD)

TALL FESCUE (FOLIAR TREATMENT)

TALL FESCUE (SOIL TREATMENT)

TIMOTHY (ORNAMENTAL) (FOLIAR TREATMENT)

TIMOTHY (SO IL TREATMENT)

WEEPING LOVEGRASS (FOLIAR TREATMENT)

ZOYSIAG ,ASS (LAWNS) (FOLIAR TREATMENT)

ZOYSIAG<ASS (ORNAMENTAL TURF) (FOLIAR

TREATML:NT)

ZOYSIAG,ASS (FOLIAR TREATMENT)

ZOYSIAG<A SS (ORNAMENTAL TURF) (SOIL

TREATMI:Nn

ZOYSIAG <ASS (SOIL TREATMENn

INTE RMEDIATE WHEATGRASS (FOLIAR TREATMENT)

INTE RME DIATE WHEATGRASS (SOIL TREATMENT)

BROMEGRASS (FOLIAR TREATMEN T)

BROMEGRAS S (ORNAM ENTAL TURF) (FOLIAR

TREATMF:Nn

BROMEGRASS (SOIL TREATMENT)

8
LITTLE BLUESTEM (RANGELAND)

(SOIL TREATMENT)

LITTLE BLUESTEM (SOIL TREATMENT)

BLUEGRASS (FORAGE) (FOLIAR

TREATMENT)

PASTURES (BLUEGRASS) (FOLIAR

TREATMENT)

PASTURES (BLUEGRASS ) (SOIL

TREATMENT)

PASTURES (FESCUE) (FOLIAR

TREATMENT)

FESCUE (FORAGE-FODDER) (FOLI AR

TREATMENT)

PASTURES (FESCUES) (SOIL

TREATMENT)

ORCHARDGRASS (FOLIAR

TREATMENT)

PASTURES (ORCHARDGRASS) (FOLIAR

TREATMENT)

PASTURES (O RCHARDGRASS) (SOIL

TREATMENT)

TIMOTHY (FOLIAR TREATM ENT)

PASTURES (TIMOTHY) (FOLIAR

TREATMENT)

PASTURES (TIMOn-IV) (SOIL

TREATMENT)

WESTERN WH EATGRA SS (FOLI AR

TREATMENT)

WESTERN WHEATGRASS (SOIL

TREATMENT)

RANGELAND (GRASS ES) (FOLIAR

TREATMENT)

RANGELAND (GRASSES)

(RENOVATlON)(FOLlAR TREATMENT)

RANGELAND (GRASSES) (SOIL

TREATMENT)

BROME GRASSES (FORAGE) (FOLIAR

TREATMENT)

PASTURES (BROMEGRASS) (FOLIAR

TREATMENT)

PASTURES (BROMEGRAS S) (SOIL

TREATMENT)

BIG BLUESTEM (RANGELAND) (FOLIAR

TREATM ENT)

BIG BLUESTEM (FOLIAR TREATMENT)

BIG BLUEST EM (ORNAMENTAL TURF)

(FOLIAR TREATMENT)

BIG BLUEST EM (RANGELAN D) (SOIL

TREATMENT)

BIG BLUESTEM (SOIL T REATMENT)

CAUCASIAN BLUESTEM (FOLIAR

TREATMENT)

INDIANGRASS (FOLIAR TREATMENT)

INDIANGRASS (RANGELAND) (FOLIAR

BROMEGRASS (SEED TREATMENT)

BLUEBUNCH WHEATGRASS (FOLIAR TREATMENT)

RUSSIAN WILDRYE (FOLIARTREATMENT)

SMOOTH BROMEGRASS

SMOOTH BROMEGRASS (ORNAMENTAL TURF) (FOLIAR

TIlEATMENT)

BROMEGRASS (SMOOTH) (FOLIAR TREATM ENT)

ZOYSIAGRASS (MEYER) (ORNAMENTAL TURF) (FOLIAR

THEATMENT)

ZOYSIAGRASS (MEYER) (ORNAMENTAL TURF) (SOIL

TREATMENT)

FINE FESCUE (ORNAMENTALTURF) (FOLI AR

TREATMENT)

FI NE FESCUE (FOLIAR TREATMENT)

FI NE FESCUE (SOIL TREATMENT)

FINE FESCUE (ORNA MENTAL TURF) (SOIL TREATMENT)

TALL WHEATGRASS (FOLIAR TREATMENT)

TALL WHEATGRASS (SOIL TREATMENT)

GREEN SPRANGLETOP (FOLIAR TREATMENT)

ORNAMENTAL WOODY VINES(TRANSPLANTS)

ROSES (WILD) (FOLIAR TREATMENT)

SNOWBERRY (FOLIAR TREATMENT)

KUDZU (FOLIAR TREATMENT)

ORNAMENTAL CONIFERS (FOLIAR TREATMENT)

DOUGLAS-FIR (FOLIAR TREATMENT)

DOUGLAS· FIR (SOILTREATMENT)

DOUGLAS-FIR(TRANSPLANTS)

GRAND FIR (FOLIAR TREATMENT)

GRAND FIR (SOIL TREATMENT)

GRAND FIR(TRANSPLANTS)

LOBLOLLY PINE (FOLIAR TREATMENT)

LOBLOLLY PINE (SOIL TREATMENT)

LOBLOLLY PINE (TRANSPLANTS)

LONGLEAF PINE(SOILTREATMENT)

9
TREATMENT)

INDIANGRASS (FOLIAR TREATMENT)

INDIANGR ASS (SOIL TREATM ENT)

INDIANGRASS (RANGELAND) (SOIL

TREATMENT)

BUFFALOGRASS (FOLIAR TREATMENT)

BUFFALOGRASS (RANGELAN D)

(FOLIAR TREATMENT )

ASIATIC BLUESTEM (FOLIAR

TREATMENT)

BLUE GRAMAGRASS (FORAGE)

(FOLIAR TREATMENT)

BLUE GRAMAGRASS (SOIL

TREATMENT)

CLOVER (CRIMSON) (SOIL

TREATM ENT)

PASTURES

PASTURES (FOLIAR TREATMENT)

PASTURES (SOIL TREATMENT)

AGRICULTURAL FIELDS (FALLOW)

(FOLIAR TREATMENT)

RANGE LAN D

RANGELAN D (FOLIAR TREATMENT)

RANGELAND (SOIL TREATM ENT)

FOREST LANDS

FOREST TREES (FOLIAR TREATM ENT)

ORNAMENTAL VEGETATION (FOLIAR

TREATMENT)

ORNAMENTAL WOODY PLANTS

(FOLIAR TREATM ENT)

ORNAMENTAL WOODY PLANTS (SOIL

TREATMENT)

ORNAMENTAL WOODY PLANTS

(INJECTION TREATMENT)

ORNAM ENTAL WOODY PLANTS

(STUMP TREATMENT)

ORNAM ENTAL VINES (FOLIAR

TREATMENT)

WEED HOSTS OF PLANT PATHOG ENS

(FOLIAR TREAT MENT)

ORNAMENTAL TURF (GOLF APRONS)

(FOLIAR TREATM ENT)

ORNAMENTA L TURF (GO LF COURSE

ROUGH) (FOLIAR TREATMENT)

ORNAM ENTAL TURF (GOLF COURSES)

(FOLIAR TREATM ENT)

ORNA MENTAL TURF (GOLF

FAIRWAYS) (FOLIAR TREATMENT)

ORNAMENTAL TURF (GOL F GREENS)

(FOLIAR TREATMENT)

ORNAMENTAL TURF (GOLF TEES)

(FOLIAR TREATM ENT)

LONGLEAF PINE (TRANS PLANTS)

NORWAY SPRUCE (FOLIAR TREATMENT)

NORWAY SPRUCE (SOIL TREATMENT)

PINE (SEEDLINGS) (FOLIAR TREATMENT)

PONDEROSA PINE (FOLIAR TREATMENT)

PONDEROSA PINE (SOIL TREATMENT)

PONDEROSA PINE (TRANSPLANTS)

RED PINE (FOLIAR TREATMENT)

RED PINE (SOIL TREATMENT)

YELLOW I' OPLAR (FOLIAR TREATMENT)

YELLOW I' OPLAR (SOIL TREATMENT )

YELLOW I' OPLAR (DORMANT APPLICATION)

WESTERN REDCEDAR (FOLIAR TREATMENT)

WESTERN REDCEDAR (SO IL TREATMENT)

WHITE SPRUCE (FOLIAR TREATMENT)

WHITE SPRUCE (SOIL TREATMENT)

BLACK HILLS SPRUCE (FOLIAR TREATMENT)

SITKA SPRUCE (FOLIAR TREATMENT)

SITKA SPRUCE (SOIL TREATMENT )

SITKA SPRUCE (TRANS PLANTS)

SLASH Pn, E (FOLIAR TREATMENT)

SLASH PINE (SOIL TREATMENT)

SLASH PINE (TRANS PLANTS)

WESTERN HEMLOCK (SOIL TREATM ENT)

WESTERN HEMLOCK (TRANSPLANTS)

RED ALDER (FOLIAR TREAT MENT)

RED ALDER (SOIL TREATMENT)

BLACK SFRUCE (SOIL TREATMENT)

ALBERTA SPRUCE (FOLIAR TREATMENT)

POPLAR (HYBRIDS) (SOIL TREATM ENT)

PONDERCSA PINE (PLANTAT ION) (FOLIAR

TREATMl;NT)

10
ORNAMENTAL TURF (GOLF APRONS)

(SOIL TREATMEN T)

ORNAMENTAL TURF (GOLF COURSES)

(SOIL TREATMENT)

ORNAMENTA L TURF (GOLF COURSE

ROUGH) (SOIL TREATMENT)

ORNAMENTA L TURF (GO LF

FAIRWAYS) (SOIL TREATMENT)

ORNAMENTA L TURF (GO LF TEES)(SOIL

TREATMENT)

ORNAMENTAL TURF (INDUSTRIAL)

ORNA MENTAL TURF (PARKS) (FOLIAR

TREATMENT)

ORNAMENTAL TURF (RENOVATION)

(FOLIAR TREATMENT)

ORN AMENTAL TURF (FOLIAR

TREATMENT)

ORNAMENTAL TURF (ATHLETIC

FIELDS) (FOLIAR TREATM ENT)

ORNAMENTAL TURF (CEMETERIES)

(FOLIAR TREATMENT)

ORNAMENTAL TU RF (IN DUSTRIAL)

(FOLIAR TREATMENT)

ORNAMENTAL TURF (COMM ERCIAL)

(FOLIAR TREATME NT)

ORNAMENTAL TURF (PARKS) (SOIL

TREATMEND

ORNAM ENTAL TURF (SOIL

TREATMENT)

ORN AMENTAL TURF (ATHLETIC

FIELDS) (SOIL TREATMENT)

ORNAM ENTAL TURF (CEMETERIES)

(SOIL TREATMENT)

ORNAMENTAL TURF (INDUSTRIAL)

(SOIL TREATMENT)

ORNAMENTAL TURF (COM MERCIAL)

(SOIL TREATMENT)

ORNAMENTAL TURF (FOR SOD)

ORNA MENTA L LAWNS (FOLIAR

TREATMENT)

ORNAMENTAL TURF (LA WNS) (FOLIAR

TREATMENT)

ORNAMENTAL TURF (LAWNS)(SOIL

TREATMENT)

SITKA SPRUCE (PLANTATION) (FOLIAR

TREATMENT)

LOBLOLLY PINE (FOREST) (FOLIAR

TREATMENT)

LOBLOLLY PINE (PLANTAn ON)

(FOLIAR TREATMENT)

LOBLOLLY PINE (FOREST) (SOIL

TREAT MENT)

LOBLOLLY PINE (PLANTATION) (SOIL

TREATMENT)

RID PINE (FOREST)(SOIL TREATMENT)

DOUG LAS -FIR (PLAN TAn ON) (FOLIAR TREATMENT)

DOUGLAS-FIR (FOREST) (SOIL TREATMENT)

PI" "lE(TRANSPLANTS)

POPLAR (PLANTATION) (FOLIAR TREATMENT)

YELLOW POPLAR (FOREST) (FOLIAR TREATMENT)

GIlAND FIR (PLANTAT ION)(FOLIAR TREATMENT)

SLAS H PINE (FOREST) (FOLIAR TREAT MENT)

SLASH PINE (PLANTATION ) (FOLIAR TREATMENT)

SL. ASH PINE (FOREST) (SOIL TREATMENT)

SLASH PIN E (PLANTATION) (SOIL TREATMENT)

WESTERN HEMLOCK (FOREST) (FOLIAR TREATMENT)

BLACK SPRUCE (FOREST) (FOLIAR TREATMENT)

BLACK SPRUCE (FOREST) (SOIL TREATMENT)

WHITE SPRUCE (PLANTATION) (FOLIAR TREATMENT)

KLEINGRASS (FOLIAR TREATMENT)

HARDWOOD FOREST TREES (FOLIAR TREATMENT)

HARDWOOD TREES (FOREST) (SOIL TREATM ENT)

HARDWOODS (STU MP TREAT MENT)

CON IFERS (FOREST) (FOLIAR TREATMENT)

CON IFER PLANTINGS (SOIL TREATMEN T)

CON IFERS (SEED LINGS)

CONIFERS (TRAN SPLAN TS)

CON IFER RELEASE (FOLIAR TREATMENT)

CON IFER RELEASE (FOLIAR TREATMENT)

CON IFER RELEASE (SOIL TREATME NT)

FOREST PLANTATIONS (FOLIAR TREATMENT)

CON IFER PLANTINGS (FOLIAR TREATM ENT)

CON IFER PLANTINGS (NURSERY)

11
ApPENDIX B

NON-AGRICULT URAL USE SITES FOR M ETSULFURON-METHYLIU

AIRPORTS (FOLIAR TREATMENT)

AIRPORTS (INJECTION TREATMENT)

AIRPORTS (SO IL TREATMENT)

AIRPORTS (STUMP TREATMENT)

BARE GROUND

BARRIER STRIPS (FOLIAR TREATMENT)

BARRIER STRIPS (SOIL TREATMENT)

BOG LA KES (WA TER TREATMENT)

CA MPGROUNDS

COMME RCIAUINST ITUT IONALIINDUSTRIAL AREAS

(OUTDOOR)

CONSERVATION RESERV E PROGRAM LAND

(FOLIAR TREATM ENT)

CONS ERVATION RESERVE PROGRAM LAND (SOIL

TREATMENT)

CROPLAND BORDERS (FOLIAR TREATMENT)

CROPLAND BORDERS (SOIL APPLICATION)

DITCH BANKS (FOLIAR TREATMENT)

DRA INAGE CANALS

DRAINAGE DITCH BANKS (FOLIAR TREATM ENT )

DRAINAGE DITCH BANKS (SOIL TREATM ENT)

DRA INAGE DITCHES

DRA INAGE DITCHE S (FOLI AR TREATMENT)

FALLOW LAND (FOLIAR TREAT MENT)

FAL LOW LAND (SOIL TREATMENT)

FARM FUEL STO RAGE AREAS (FOLIAR

TREATMENn

FARM FUEL STO RAGE AREAS (SOIL TREATMENT)

FARM YAR DS (FOLIAR TREATM ENT)

FARM YARDS (SOIL TREATM ENT)

FENCE ROWS (FOLIAR TREATMENT)

FENCEROWS (AG RICULTU RAL) (SOIL TREATMENn

FENCEROWS (FOLIA R TREATMENT)

FENCEROWS (NONAGRICULTU RA L) (FOLIAR

TREATMENT)

FENCEROWS (NONAG RICULTU RAL) (SOIL

TREATM ENT)

AIRPORTS (INJECTION TREATM ENT)

AIRPORTS (SOIL TREATM ENT)

AIRPORTS (STUMP TREATM ENT)

BARE GROUN D

BARRIER STRIPS (FOLIAR TREATMENT)

BARRIER STRIPS (SOIL TREATMENT)

BOG LAKES (WATER TREATMENT)

CAMPGROUNDS

CO MMERCIAL/ INST ITUT IONAL/INDUSTRIA

L AREAS (OUTDOOR )

CONSERVATIO N RESERVE PROGRAM

LAND (FOLIAR TREATMENT)

CONSE RVATION RESERV E PROG RAM

LAND (SOIL TREATM ENT)

CROPLAND BORDERS (FOLIAR

TREATMENT)

CROPLAND BORDERS (SOI L APPLICAn ON)

DITCH BANK S (FOLIAR TREATMENn

DRAINAGE CANALS

DRAINAGE DITCH BANK S (FOLIAR

TREATMENn

DRAINAGE DITC H BANKS (SOIL

TREATM ENT)

DRAI NAG E DITCH ES

DRAINAG E DITCH ES (FOLIAR TREATMENT)

FALLOW LAND (FOLIAR TRE ATMENT)

FALLOW LAND (SOI L TRE ATMENT)

FARM FUEL STORAG E AREAS (FOLIAR

TREATMENT)

FARM FUEL STORAGE AREAS (SO IL

TREATMENT)

FARM YAR DS (FOLIAR TREATMENT)

FARM YARD S (SO IL TREATM ENT)

FENCE ROWS (FO LIAR TREATM ENT)

FENCEROW S (AGRlCULTURAL) (SOI L

TREATMENT)

FENCEROWS (FOLI AR TREATMENT)

FENCEROWS (NONAG RICULTURAL)

(FOLIAR TREATMENT)

FENCEROWS (NONAGRICULTURAL) (SOIL

TREATMENT)

FENCEROW S (SOI L TREATMENT)

10 Information was obtained from the Age ncy 's database and bas not been compared to the list ofsites on the

prod uct labe ls.

12
FENCEROWS (SOIL TREATMENT)

FLOOD PLAIN (DRY) (FOLIAR TREATMENT I

FLOOD PLAINS (WATER TREATMENT)

FORMULATING USE ON LY NO SITE

IND USTRI AL AREAS (OUTDOOR) (FOLIAR

TREATM ENT)

INDUSTRIAL AREAS (OUTDOOR) (SOIL

TREATMENT)

INDUSTRI AL PLANT SITES

INDUSTRI AL SIT ES

INDUSTRIAL SITES (FOLIAR TREATMENT)

INDUSTRI AL SITES (SOIL TREATMENT)

INTERMITTENTLY FLOO DED AREAS (DAMP AREAS)

INT ERMITTENTLY FLOODED AREAS (PERl fI .'I ETERS)

LAKES (WATE R TRE ATMENT)

LOW VOLUME (LV) APPLICATION

LUMBER YAR DS (FOLIAR TREATMENT)

LUMBER YARDS (SOIL TREATM ENT)

MANU FACTURING USE ONLY NO SITE

MARS HES (S URROUNDING VEGETATION-FOLIAR

TREATME NT)

MARSHES (WATE R TREATMENT)

MILITARY INSTAL LATIO NS

MILITARY INSTALLATIONS (OUTDOOR) (FOLIAR

TREATM ENT)

NON AGRICULTU RAL AREAS (W ILDLIFE REFUGE)

NONCROP AREA S

NONCROP AREAS (FOLIAR TREATMENT)

NONCROP AREAS (GRASS Y)

NONCROP AREAS (SO IL TRE ATMENT)

FLOOD PLAI N (DRY) (FOLIAR TREATMENT)

FLOOD PLAINS (WAT ER TREATM ENn

FORMULATING USE ONLY NO SITE

INDUSTRIAL AREAS (OUT DOOR) (FOLIAR

TREATMENT)

INDUSTRIAL AREAS (OUTDOOR) (SOI L

TREATMENT)

INDUSTRIAL PLANT SITES

IND USTRIAL SITES

INDUSTRIAL SITES (FO LIAR TREATM ENn

IND USTRIAL SITES (SOIL TREATM ENn

INT ERMIlTENTLY FLOODED AREAS (DAMP

AREAS)

INTERM IlTENTLY FLOODED AREAS

(PERIMETERS)

LAKES (WATER TREATMENT)

LOW VO LUME (LV) APPLICATION

LUMB ER YARDS (FOLIAR TREATM ENT)

MANUFACTURING USE ONLY NO SiTE

MARSHES (SURROUN DING VEGETATIONFOLIAR TREATMENT)

MARSHES (WATER TREATMENT)

MILITARY INSTALLATIONS

MILITA RY INSTA LLATIONS (OUTDOOR)

(FOLIAR TREATM ENT)

NONAGRICULTU RAL AREAS (WILDLIFE

REFUGE)

NONCROP AREAS

NON CROP AREAS (FOLIA R TREATM ENT)

NONCROP AREAS (GRASSY)

NONCROP AREAS (SOIL TREATMENT)

PARK ING LOTS

13