EPA Registration Jacket 86044‐2
1
2

Page 1 of2 

RE: Your question about EPA Reg. No. 86044-2 - reducing tox signal word from Danger 

to Caution 

Amy Roberts 

to: 

Philip Errico 

05/3112011 02:16 PM 

Cc: 

Kable Davis 

Show Details 

Thanks Phil - The info is appreciated. Regards, 

Amy Plato Roberts 1 Senior Regulatory Consultant 

Technology Sciences Group Inc. (TSG) 

712 Fifth Street, Suite A 1 Davis, CA 95616 

CA Tel: 530.757.14321 DC Tel: 202.828.89641 Fax: 530.757.12991 

!Jfoberts@TSGUSA.com 

Visit us at www.TSGUSA.com 

-----Original Message-----

From: Errico.Philip@epamail.epa.gov [mailto:Errico.Philip@epamail.epa.gov 1 

Sent: Tuesday, May 31, 2011 6:28 AM 

To: Amy Roberts 

Cc: Davis.Kable@epamail.epa.gov 

Subject: Your question about EPA Reg. No. 86044-2 - reducing tox signal word from 

Danger to Caution 

Amy, 

As you know, ROOTPLUG is a 100% repack of a product that has Danger as the Tox 

Signal Word, and therefore also must have the same Signal Word. 

To change the Signal Word to Caution, the 100% repacked product can be change to a 

product that has the same Signal Word of Caution, if you can find one to meet the needs 

of your product as used. The use of child resistant packaging would not be justification to 

change the Signal Word from Danger to Caution. 

Regards, 

Philip (Phil) V. Errico, Senior Chemist U. S. Environmental Protection Agency Office of 

Pesticide Programs Registration DivisionlHerbicide Branch (7505C) 

Phone: 703-305-6663 

file:IIC:IDocuments and Settingslperric021Locai SettingsITemplnotesFCBCEEI-webI599.... 5/3112011 
3

Amy, 

Your question about EPA Reg. No. 86044-2 - reducing tox signal word from 

Danger to Caution 

Philip Errico to: Amy Roberts 05/31/201109:27 AM 

Cc: Kable Davis 

As you know, ROOTPLUG is a 100% repack of a product that has Danger as the Tox Signal Word, and 

therefore also must have the same Signal Word. To change the Signal Word to Caution, the 100% 

repacked product can be change to a product that has the same Signal Word of Caution, if you can find 

one to meet the needs of your product as used. The use of child resistant packaging would not be 

justification to change the Signal Word from Danger to Caution. 

Regards, 

Philip (Phil) V. Errico, Senior Chemist 

U. S. Environmental Protection Agency 

Office of Pesticide Programs 

Registration Division/Herbicide Branch (7505C) 

Phone: 703-305-6663 

Fax: 703-308-1825 

Email: Errico.Philip@epa.gov 
4

RE: Registration Notice and Stamped Label (EPA Reg. No. 86044-2) -

QUESTION 

t 

Amy Roberts 0 Philip Errico 04/28/2011 06:35 PM 

Cc: Kable Davis 

Hi Phil/Bo: 

Sorry to bug you. but I still need some help on the below question (as 

highlighted). Any thoughts? 

Regards. 

Amy Plato Roberts I Senior Regulatory Consultant 

Technology Sciences Group Inc. (TSG) 

712 Fifth Street. Suite A J Davis. CA 95616 

CA Tel: 530.757.1432 I DC Tel: 202.828.8964 I Fax: 530.757.1299 I 

aroberts@TSGU5A.com 

Visit us at www.TSGUSA.com 

-----Original Message-----

From: Amy Roberts 

Sent: Wednesday. March 09, 2011 1:39 PM 

To: 'errico.philip@epa.gov' 

Subject: FW: Registration Notice and Stamped Label (EPA Reg. No. 86044-2) -

QUESTION 

Hi Phil: 

The registrant of this product wants me to explore what it would take to: 

1) Reduce the signal word to CAUTION; and. 

2) Add back on residential use sites for the attached product label. 

My initial thought is that it would need to be in child resistant packaging 

(per 40 CFR 157) to accomplish both those goals. Do you have any thoughts 

or guidance on the matter? 

Regards. 

Amy Plato Roberts J Senior Regulatory Consultant Technology Sciences Group 

Inc. (TSG) 

712 Fifth Street. Suite A I Davis. CA 95616 CA Tel: 530.757.1432 J DC Tel: 

202.828.8964 I Fax: 530.757.1299 J aroberts@TSGUSA.com Visit us at 
5

www.TSGUSA.com 

-----Original Message-----

From: Davis.Kable@epamail.epa.gov [mailto:Davis.Kable@epamail.epa.gov] 

Sent: Friday} February 18~ 2011 9:59 AM 

To: Amy Roberts 

Subject: Registration Notice and Stamped Label (EPA Reg. No. 86044-2) 

AmyI hope all is well. Please find attached the registration notice and 

stamped label for ROOTPLUG (EPA Reg. No. 86044-2). I'll also mail you paper 

copies. If you have any questions} please let me know. 

Have a relaxing weekend! 

Sincerely} 

Bo 

Kable Bo Davis 

Product Manager 25 

U.S. Environmental Protection Agency 

Herbicide Branch 

Registration Division (7505P) 

1200 Pennsylvania Ave. NW 

Washington~ DC 20460 

Tel: 703 306-0415 

Email: davis.kable@epa.gov 

From: 

To: 

Date: 

Forwarded by Kable Davis/DC/USEPA/US on 02/18/2011 12:56 PM -----

cts/cts/QP/U5EPA/U5@EPA 

Kable Davis/DC/U5EPA/U5@EPA 

02/18/2011 12:51 PM 

Subject: 

Please open the attached document. This document was digitally sent to you 

using an HP Digital Sending device. (See attached file: 

[Untitled]. pdf) 

CONFIDENTIALITY NOTICE: This e-mail and any attachments contain informatiOn from TechnologySciences Group Inc., and are intended soiely 

for the use of the named recipient or recipients. Any dissemination of thiS e_mail by anyone other than an intended recipient is strictly 

prohibited. If you are not a named recipient, you are prohibited from any further viewing of the e-mail or any attachments or from making any 

use of the e-mail or attachments. If you believe you have received this e-mail in error, notify the sender immediately and permanently delete 

the e-mail, any attachments, and all copies thereof from any drives or storage media and destroy any printouts of the e-mail or attachments. 
6

Material to be added to an e-Jacket/Jacket 

Reg. No. Decision # L[::, II ~ ~ 

Description: , 

\N:i. yO '-" .... /) - ( sy_ -\v, "-.-" 

2\nlu 

1. Placement within the e-JackeUjacket: 

D Default: (chronological, top = newest) 

D File Location: (eg. "before page 45 in .pdf) 

2. ~end to Data Extraction contractors this material: 

ErNewly stamped accepted label 

D Notification 

D NewCSF 

D Other: 

3. Attach this coversheet to the top of the material or jacket. It must be well 

organized and clipped together, NOT STAPLED. Then give the material with 

this coversheet to staff in the Information Services Center (Room S-4900). 

Reviewer: X-U Division: RD 

Phone: 30 <0 - 0 '{ l) Date: s-s-l\ 

Created May 3, 2011 
7

ij;\ U.S. ENVIRONMENTAL PROTECTION AGENCY EPA Reg. Number: Date oflssuance: 

Office of Pesticide Programs 

s • Registration Division (7505P) \; ~ 86044-2 FEB 1 7 1011 

~LPA~;# 1200 Pennsylvania Ave., N.W. 

Washington, D.C. 20460 

NOTICE OF PESTICIDE: Term of Issuance: X Registration 

_ Reregistration Unconditional 

(under FiFRA, as amended) 

Name of Pesticide Product: 

ROOTPLUG 

Name and Address of Registrant (include ZIP Corle): 

PLUGGAB Inc. 

c/o Amy Roberts 

Technology Sciences Group Inc. 

115018'" Street, N.W. 

Washine;ton, D.C. 20036 

'N~~e/Ch~g~;':hifabeli~'g' diff~ng ins'ub~ce from tmtaccepted in cqnnection' with this registration must be submitted to and accepted by the 

Regl~trirti6n'Di~m;;ii '~ri~~ to','lise ~i the'lai;~i ni"cbmm:erce.' In any correspondeii~ on' this product alwah refer to the above EPA registration number. " <" '.' ':. .... .... . .' . 

On the basis of illfonnation furnished by the registrant, tbe above named pesticide is bereby registered/reregistered under the Federal Insecticide, Fungicide 

and Rodenticide Act. 

Registration is in no way to be construed as an endorsement or recommendation oftbis product by the Agency. In order to prott:{;t health and tbe 

environment, the Administrator, on bis motion, may at any time suspend or cancel the registration of a pesticide in accordance with the Act The acceptance 

of any name in connection with the registration ora product under this Act is not to be construed as giving the registrant a right to exclusive IISC oftbe name 

or to its lise if it has been covered by others. 

This product is conditionally registered in accordance with FIFRA section 3(c )(5) provided that 

you: 

1. Submit and/or cite all data required for registration of your product under FIFRA sec 3( c)(5) 

when the Agency requires all registrants of similar products to submit such data; and submit 

acceptable responses required for registration review of your product under FIRA section 

3(g). 

2. Make the following label changes before you release the product for shipment: 

a. Revise the EPA Registration Number to read, "EPA Reg. No. 86044-2". 

b. Add the batch number to product label in disposable containers before shipment. 

c. Add the EPA Establishment Number to product label before shipment. 

Sig"JfG~ ~ 

Date: 

FEB 1 7 1011 

Kable Bo Davis, Product Manager (25) 

Herbicide Branch, Registration Division (7505P) 

EPA FOrnl85 , 0 6 -
8

Page 2 

EPA Reg. No. 86044-2 

3. The alternate brand names, PLUGGED and SWEPLUG, are acceptable. 

4. The data requirements for storage stability (830-6317) and corrosion characteristics (830-

6320) have not been satisfied, and must be submitted within eighteen months of the date of 

this letter. 

5. Submit one copy oftbe revised final printed label for the record before yOll release the product 

for shipment. 

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

accordance with FIFRA section 6(e). Your release for shipment of the product constitutes acceptance of 

these conditions. 

A stamped copy of the label is enclosed for your records. If yOll have any questions regarding 

this notice, please contact Phil Errico at (703) 305-6663 or errico.philip@epa.gov. 

Enclosure- Stamped Labeling 

Kable Bo Davis 

Product Manager (25) 

Herbicide Branch 

Registration Division (7505P) 
9

ROOTPLUG 

(Alternate Brand Names: "PLUGGED"; "SWEPLUG") 

NOT FOR USE AT RESIDENTIAL, SCHOOL AND INSTITUTIONAL USE SITES. 

This product can be used to kill trees and stumps in the non-food/non-feed sites: forests; parks; 

highway, utility, and railroad right-af-ways; and industrial and fence row sites. Can be used to 

kill the trees and stumps of Alder, Ash, Aspen, Beech, Birch, Cherry, Elm, Lime, Maple, Oak 

and Poplar. 

Active Ingredient: 

Glyphosate, in the form of its ammonium salt* ........ 74.70% 

Inert Ingredients: ................................................. 25.30% 

Total: ................................................................... 100.00% 

*Equivalent to 67.9% of the acid glyphosate 

KEEP OUT OF REACH OF CHILDREN 

DANGERlPELIGRO 

Si usted no entiende la etiqueta, busque a alguien paraque se la explique a usted endetalle. (If 

you do not understand the label, find someone to explain it to you in detail.) 

FIRST AID 

IF IN EYES: • Hold eye open and rinse slowly and gently with water for 15-20 minutes 

• Remove contact lenses, if present, after the first 5 minutes, then 

continue rinsing. 

• Call a poison control center or doctor for treatment advice. 

IF • Immediately call a poison control center or doctor for treatment advice. 

SWALLOWED: • Do not induce vomiting unless told to do so by a poison control center 

or doctor. 

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

• Do not give anythinq bv mouth to an unconscious person. 

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

I going for treatment. You may also call 314-694-4000 for emergency treatment information. 

NOTE TO PHYSICIAN: Probable mucosal damage may contraindicate the use of gastriC 

lavage. 

SEE [BACK, SIDE, REAR] PANEL FOR ADDITIONAL PRECAUTIONARY STATEMENTS. 

Manufactured (for) (by): 

PLUGGAB Inc. 

511 Avenue of the Americas, Suite 316 

New York, NY 10011 

EPA Reg. No.: 86044-E 

EPA Est. No.: 

Batch Code: 

Net Contents: 

ACCEPTED 

With COMMENTS 

In EPA LeHer Dated: 

\=e....~,,0=v '-f \'""1 j 2.0 \ \. 

Under the Federal Insecticide, Fungicide 

and Rodenticide Act, As amended, for the 

pesticide Registered under EPA Reg. No: 

J!0 0 1/1(- d-- ~ 

ROOTPLUG; EPA Reg. No. (86044-E) 

MASTER LABEL - Label version (3) dated February 16. 2011 

Page 1 of 5 
10

PRECAUTIONARY STATEMENTS 

HAZARDOUS TO HUMANS AND DOMESTIC ANIMALS: DANGER. Ingredients in 

ROOTPLUG cause eye burns. Harmful if swallowed. Do not get ingredients in eyes, on skin, or 

on clothing. 

PERSONAL PROTJ;CTIVE EQUIPMENT (PPE): Applicators and other handlers must wear: 

• Coveralls worn over long~sleeved shirt and long pants. 

• Chemical-resistant footwear plus socks. 

• Chemical-resistant gloves. 

• Protective eyewear such as goggles. 

Discard clothing that becomes contaminated with the ingredients in ROOTPLUG. Do not 

reuse them. Follow manufacturer's instructions for cleaning I maintaining PPE. If there are no 

such instructions for wash ables, use detergent and hot water. Keep and wash PPE separately 

from other laundry. 

USER SAFETY RECOMMENDATIONS: Users should: 

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

• Remove clothing immediately if pesticide gets inside. Then wash thoroughly and put on 

clean clothing. 

• Remove PPE immediately after handling this product. Wash the outside of gloves 

before removing. As soon as possible, wash thoroughly and change into clean clothing. 

ENVIRONMENTAL HAZARDS: To protect the environment, do not allow pesticide to enter or 

run off into stonn drains, drainage ditches, gutters or surface waters. Applying this product in 

calm weather when rain is not predicted for the next 24 hours will help to ensure that wind or 

rain does not blow or wash pestiCide off the treatment area. Sweeping any product that lands on 

a driveway, sidewalk, or street, back onto the treated area of the lawn or garden will help to 

prevent run off to water bodies or drainage systems. 

DIRECTIONS FOR USE 

It is a violation of federal law to use this product in a manner inconsistent with its labeling. 

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. It 

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 restricted entry interval. The requirements in 

this box only apply to uses of this product that are covered by the Worker Protection Standard. 

There is no re~entry interval (REI). Only protected applicators are allowed in area during 

treatment of sites. 

Non~Agricultural Use Requirements 

The requirements in this box apply to uses of this product that are not within the scope of the 

Worker Protection Standard for agricultural pesticides (40 CFR Part 170). The WPS applies 

when this product is used to produce agricultural plants on farms, forests, nurseries or 

greenhouses. 

ROOTPLUG, EPA Reg. No. (86044-E) 

MASTER LABEL - Label version (3) dated February 16, 2011 

Page 2 of5 
11

Keep all unprotected persons out of area during treatment of sites. 

When used as directed, this product kills trees and stumps of Alder, Ash, Aspen, Beech, Birch, 

Cherry, Elm, Lime, Maple, Oak and Poplar. This product can be used for killing trees in areas 

where surface water is present or in intertidal areas. For effective results, ROOTPLUG must be 

applied such that the contents of the active ingredient is in direct contact with the tree's phloem 

tissue (the first living tissue under the bark). 

Treatment of stumps 

Drill a hole 1 1/8 inch deep from above the stump, or into the side of the stump, with a 1/2 inch 

drill bit. When drilling from above, drill as close to the bark as possible with each hole spaced 2 

1/3 - 3 1/8 inches apart. Insert a ROOTPLUG into each hole and use a hard rubber hammer to 

drive it into the stump. For best results, treatment of stumps should occur no more than two 

days after tree has been felled. 

Treatment of trees 

For standing trees, drill holes at a depth of 1 1/8 inches using a 1/2 inch drill bit and insert one 

ROOTPLUG into each hole as indicated in the table. 

Treatment of standinQ trees 

Species Diameter of tree at breast Number of ROOTPLUGs 

height 

Alder, Aspen, Beech, 2.5 inches 1 

Birch, Elm, lime, 4 inches 2 

Maple 5.5 inches 3 

7 inches 4 

8 inches and above One every 3 inches 

Ash, Cherry, Oak, 2.5 inches 2 

Poplar 4 inches 4 

5.5 inches 6 

7 inches 8 

8 inches and above One every 1 % inches 

Visible roots One in each root 

The contents of ROOTPLUG move throughout the tree from the point of injection to all roots and 

shoots. Effects appear gradually (normally within 2-4 weeks depending on moisture conditions 

and growth stage) beginning with wilting followed by yellowing and browning of the foliage, and 

finally with deterioration of all roots and shoots. 

PRECAUTIONS AND RESTRICTIONS 

• DO NOT OPEN OR SEPRATE THE ROOTPLUG UNITS. 

• DO NOT USE ROOTPLUG ON RESIDENTIAL, SCHOOL OR INSTITUTIONAL SITES. 

• DO NOT USE THE HARD RUBBER HAMMER IN SUCH A MANNER THAT WILL 

COMPROMISE THE INTEGRITY OF THE ROOTPLUG UNITS. 

ROOTPLUG; EPA Reg. No. (86044-E) 

MASTER LABEL - Label version (3) dated February 16. 2011 

Page 3 of 5 
12

STORAGE AND DISPOSAL 

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

PESTICIDE STORAGE: Store in original container in a cool dry and locked place inaccessible 

to children and pets. Keep container tightly closed when not in use. At the end of each use 

period, place unused plugs into the original container and reseal. 

PESTICIDE DISPOSAL AND CONTAINER HANDLING: 

If empty - Nonrefillable container. Do not reuse or refill this container. Place in trash or offer for 

recycling if available. 

If partly filled - Wastes of this product may cause irreversible eye damage and may be 

dangerous. Improper disposal of excess pesticide or rinsate is a violation of Federal law. 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 Regional Office for guidance. Never place unused product down indoor or outdoor 

drain. 

WARRANTY - PLUGGAB Inc. warrants that this product conforms to the chemical description 

on the label and is reasonably fit for the purposes set forth in the Complete Directions for Use 

label booklet ("Directions") when used in accordance with those Directions under the conditions 

described therein. TO THE EXTENT CONSISTENT WITH APPPLICABLE LAW, NO OTHER 

EXPRESS WARRANTRY OR IMPLIED WARRANTY OF FITNESS FOR PARTICULAR 

PURPOSE OR MECHANTABILITY IS MADE. 

ROOTPLUG; EPA Reg. No. (86044·E) 

MASTER LABEL - Label version (3) dated February 16, 2011 

Page 4 of 5 
13

OPTIONAL LABEL CLAIMS: 

A stump treatment method from PLUGGAB Inc, containing glyphosate formulation of 

ammonium salt granulate. 

ROOT PLUG can be used in any weather at any time of the year. 

ROOTPLUG is patented, 8701680-4 

ROOTPLUG; EPA Reg. No. (86044-E) 

MASTER LABEL-label version (3) dated February 16, 2011 

Page 5 of 5 
14

History: 

RE: Pending EcoPlug (86044-R) - Change in product name 

Amy Roberts to: Kable Davis ,,-f'1 Ilf, 3 '" 

Cc: PhilipErri~ 530- ,S 1- '1 d-'" 

This message has been replied to. 

02f09{2011 12:40 PM 

Thanks Bo. I will work with Phil on the label and much appreciate the 

information. Regards, 

Amy Plato Roberts I senior Regulatory Consultant 

Technology Sciences Group Inc. (TSG) 

712 Fifth Street, Suite A I Davis, CA 95616 

CA Tel: 530.757.1432 I DC Tel: 202.828.8964 I Fax: 530.757.1299 I 

aroberts@TSGUSA.com 

Visit us at www.TSGUSA.com 

CONFIDENTIALITY NOTICE: 

This e-mail and any attachments contain information from Technology Sciences 

Group Inc., and are intended solely for the use of the named recipient or 

recipients. Any dissemination of this e-mail by anyone other than an intended 

recipient is strictly prohibited. If you are not a named recipient, you are 

prohibited from any further viewing of the e-mail or any attachments or from 

making any use of the e-mail or attachments. If you believe you have received 

this e-mail in error, notify the sender immediately and permanently delete the 

e-mail, any attachments, and all copies thereof from any drives or storage 

media and destroy any printouts of the e-mail or attachments. 

-----Original Message-----

From: Davis.Kable@epamail.epa.gov [mailto;Davis.Kable@epamail.epa.gov) 

Sent: Wednesday, February 09, 2011 9:32 AM 

To: Amy Roberts 

Cc: Errico.Philip@epamail.epa.gov 

Subject: RE: Pending EcoPlug (86044 R) - Change in product name 

Amy~ 

I apologize for the delay in responding. I spoke with my branch chief 

and she confirmed that the efficacy requirement and RUP determination 

are no longer issues of concern. As a result, the only remaining 

roadblocks concern necessary label changes. Phil can work with you on 

making these required revisions. I looked over your proposed new 

product names and they all seem fine with me. 

I hope all is well. Enjoy the remainder of your Wednesday. 

Sincerely, 

Bo 

Kable Bo Davis 

Product Manager 25 

U.S. Environmental Protection Agency 

Herbicide Branch 

Registration Division (7505P) 

1200 pennsylvania Ave. NW 

Washington, DC 20460 

Tel: 703 306-0415 

Email: davis.kable@epa.gov 
15

From: 

To: 

Cc: 

Date: 

subject: 

"Amy Roberts" <ARoberts@TSGUSA.COM> 

Kable Davis/DC/USEPA/US@EPA 

Philip Errico/DC/USEPA/US@EPA 

02/02/2011 12:42 PM 

RE: Pending EcoPlug (86044-R) - Change in product name 

Dear Bo and Phil: 

When you are back and get time to look at this pending application, the 

registrant has agreed to changing the product name. The new name 

options are: "RootP1uglf or "Plugged" or "SwePlug". I will add the 

first as the primary brand name and the other two as alternate brand 

names. I will wait to send an updated label to Phil until it is known 

if there are any other label changes. 

Regards, 

Amy Plato Roberts I Senior Regulatory Consultant 

Technology Sciences Group Inc. (TSG) 

712 Fifth Street, Suite A I Davis, CA 95616 

CA Tel: 530.757.1432 I DC Tel: 202.828.8964 I Fax: 530.757.1299 I 

aroberts@TSGUSA.com 

Visit us at www.TSGUSA.com 

CONFIDENTIALITY NOTICE: 

This e-mail and any attachments contain information from Technology 

Sciences Group Inc., and are intended solely for the use of the named 

recipient or recipients. Any dissemination of this e-mail by anyone 

other than an intended recipient is strictly prohibited. If you are not 

a named recipient, you are prohibited from any further viewing of the 

e-mail or any attachments or from making any use of the e-mail or 

attachments. If you believe you have received this e-mail in error, 

notify the sender immediately and permanently delete the e-mail, any 

attachments, and all copies thereof from any drives or storage media and 

destroy any printouts of the e-mail or attachments. 

From: Davis.Kable@epamail.epa.gov (mailto:Davis.Kable@epamail.epa.gov) 

Sent: Monday, January 31, 2011 2:35 PM 

To: Amy Roberts 

Cc: Errico.Philip@epamail.epa.gov 

subject: Re: Pending EcoPlug (86044-R) 

AmyThank you for the email. I'm unfortunately at home today with a 

stomach-bug. In addition, I'll be away from the office for the next two 

days at the national bed bug summit. I'm taking note of your email and 

will look into it in further detail when I return to the office on 

Thursday. Talk soon! 

sincerely, 

Bo 

- - - - - "Amy Roberts" <ARoberts@TSGUSA.COM;;. wrote: 

To: Kable Davis/DC/USEPA/US@EPA 

From: "Amy Roberts" <ARoberts@TSGUSA.COM;;. 
16

Date: 01/31/2011 01:38PM 

Cc: Philip Errico/DC/USEPA/US@EPA 

Subject: pending EcoPlug (86044-R) 

Dear Bo: 

I am checking in on the status of a pending registration for a product 

called EcoPlug (86044-R) that has a PRIA due date of February 17, 2011. 

I just touched bases with phil Errico who advised that a few issues have 

been identified with this submission today, and I am hoping we can sort 

them out in short order without a 75-day letter or PRIA extension. My 

understanding is the issues are as follows: 

1) The proposed primary brand name EcoPlug is an issue. We will 

change that (to something non-eco) and I will get in touch with the 

registrant (in Sweden) today to get an alternative identified. I will 

hold off on submitting an updated label back to phil with a new brand 

name until I hear back if there are any other label changes needed. 

2) The company will be responsible for submitting product-specific 

efficacy data. As long as this is a condition of registration that is 

not a problem. I know the registrant has efficacy data, although there 

is obviously not time to get it in and reviewed prior to the February 17 

due date, so I am hoping that can be a condition. 

3) The DANGER signal word (copied from the repack of the source 

product) might cause a RUP determination. As this is a contained system 

that does not involve direct applicator/handler contact I am hoping that 

is not the case, but will wait to hear back from the Agency on that 

matter. 

I communicated to phil that I am available to make any modifications 

necessary to meet that February 17, 2011 PRIA due date. 

Thanks in advance and best regards, 

Amy Plato Roberts I Senior Regulatory Consultant 

Technology Sciences Group Inc. (TSG) 

712 Fifth Street, Suite A I Davis, CA 95616 

CA Tel: 530.757.1432 I DC Tel: 202.828.8964 I Fax: 530.757.1299 I 

aroberts@TSGUSA.com 

Visit us at www.TSGUSA.com 

CONFIDENTIALITY NOTICE: 

This e-mail and any attachments contain information from Technology 

Sciences Group Inc., and are intended solely for the use of the named 

recipient or recipients. Any dissemination of this e-mail by anyone 

other than an intended recipient is strictly prohibited. If you are not 

a named recipient, you are prohibited from any further viewing of the 

e-mail or any attachments or from making any use of the e-mail or 
17

attachments. If you believe you have received this e-mail in error, 

notify the sender immediately and permanently delete the e-mail, any 

attachments, and all copies thereof from any drives or storage media and 

destroy any printouts of the e-mail or attachments. 
18

MRID for RootPlug 

Amy Roberts 

to: 

Philip Errico 

02114/2011 12:49 PM 

Show Details 

Hi Phil: 

Page 1 of! 

It looks like the MRID No. for the product chemistry group A is: 481650~01. Attached is a listing of aU 

data that shows up on file at EPA. There was another group A data volume submitted earlier (March 

2010) but f am assuming it was deficient and the second one is the number to go by, but maybe both 

should be referenced. 

I hope that helps. Regards, 

Amy Plato Roberts I Senior Regulatory Consultant 

Technology Sciences Group Inc. (TSG) 

712 Fifth Street, Suite A I Davis, CA 95616 

CATel: 530.757.1432 I DC Ter: 202.828.89641 Fax: 530.757.1299 I aroberts@TSGUSA.com 

Visit us at www.TSGUSA.com 

CONFIDENTIALITY NOTICE: 

This e-mail and any attachments contain information from Technology Sciences Group Inc., and are intended solely forthe use of the named recipient or 

recipients. Any dissemination of this e-mail by anyone other than an intended recipient is strictly prohibited. If you are not a named recipient, you are 

prohibited from any further viewing of the e-mail or any attachments or from making any use of the e-mail or attachments. If you believe you have 

received this e-mail in error, notify the sender immediately and permanently delete the e-mail, any attachments, and all copies thereof from any drives or 

storage media and destroy any printouts of the e-mail or attachments. 

file:IIC:lDocuments and Settingslperric021Local SettingsITemplnotesFCBCEEI-web9521.... 2/14/2011 
19

44-R) - Change in product name 

Page I of3 

ime to look at this pending application, the registrant has agreed to changing the product name. The new name options 

" or "SwePlug". I will add the first as the primary brand name and the other two as alternate brand names. I will wait to 

 until it is known if there are any other label changes. 

gulatory Consultant 

 (TSG) 

s, CA 95616 

202.828.89641 Fax: 530.757.12991 

n informatiOrl from Technology Sciences Group Inc., and are irltended solely for the use of the rlamed n:,cipierlt or recipients, Any dissemination of this e-mail by arlY0rle 

tly prohibited. If you are not a named recipient, you are prohibited from any further viewing of the e-mail or any attachments or from making any use of the e-mail or 

ceived this e-mail in error, notify the sender immediately and permanently delete the e-mail, arlY attachmerlts, arid all copies thereof from arlY drives or storage media and 

ttachments. 

.epa.gov [maato:Davis.Kable@epamail.epa,gov] 

2011 2:35 PM 

a.gov 

ug (86044-R) 

I'm unfortunately at home today with a stomach-bug, In addition, I'll be away from the office for the next 

bed bug summit, I'm taking note of your email and will look into it in further detail when I return to the office 

ettingslperric021Local SettingsITemplnotesFCBCEEI-web5248.htrn 21712011 
20

berts@TSGUSA.COM> wrote: -----

A/US@EPA 

Roberts@TSGUSA.COM> 

M 

NUS@EPA 

 (86044-R) 

Page 2 of3 

status of a pending registration for a product called EcoPlug (86044-R) that has a PRIA due date of 

st touched bases with Phil Errico who advised that a few issues have been identified with this 

am hoping we can sort them out in short order without a 75-day letter or PRIA extension. My 

ues are as follows: 

name EcoPlug is an issue. We will change that (to something non-eco) and I wm get in touch with the registrant (in Sweden) 

entified. I will hold off on submitting an updated label back to Phil with a new brand name until] hear back if there are any 

ble for submitting product-specific efficacy data, As long as this is a condition of registration that is not a problem. I know the 

although there is obviously not time to get it in and reviewed prior to the February 17 due date, so I am hoping that can be a 

opied from the repack of the source product) might cause a RUP determination. As this is a contained system that does not 

ler contact I am hoping that is not the case, but will wait to hear back from the Agency on that matter. 

hat I am available to make any modifications necessary to meet that February 17, 2011 PRIA due date. 

best regards, 

ettings\perric02\Local Settings\Temp\notesFCBCEE\-web5248.htm 21712011 
21

eglliatory COllsllltallt 

nc. (TSG) 

is, CA 95616 

: 202.828.89641 Fax: 

Page 3 of3 

 intornlfllion from Technology Sciences Gronp Inc., and are inlended solely for Ihe use or Ihe IImncd recipiclll or recipienis. Any disseminalion of Ihis c-mail by anyonc 

y prohibited. If you are not n named recipienl, you are prohibited frnm nny filrther viewing oflhe c-mail or any or from making nny lise oflhc e-mnil or 

ceived Ihis e-mnil in error, nOlilY Ihe scnder immedialciy and permanenlly delete Ihe e-mail, any anachmems, and all copies thereof (rom flny drives or slorage media and 

aehmenls. 

ettingslperric021LDcai Settingsl TemplnotesFCBCEEI-web5248.htm 2!712011 
22

. . -. F • OMR No ,..,a._ 

United Stote. § Registration OPP kfentjfie, Numb., 

&EPA Environmental Protection Agency Amendment 

W.,hington, DC 20480 Other 

AppHcation for Pesticide - Section I 

1. Cornpany/Product Numb., 2. EPA Product Manage' a. Proposed Chtssification 

86044-E Kable Davis 0 Nono 0 .. .-.. 

4. Company/Produ~ (Neme) PM. 

ROOTPLUG 25 

s. Nama end Addr." of Applic.nt (Inc/urn ZIP Cod.) 6. Expedited Reveiw. In accordance with FIFRA Section 31ellal 

PLUGGAB (bHil. mv product is similar or identical in composition and labeling 

511 AvenueoftheAmericas, Suite 316 to: 

New York, NY 10011 EPA Reg. No. 

o ChM:k if thi$ is. • nlfW orJdrtlu Product Name 

Section - 0 

0 Amendment· Explain below. U Final printed labol. in fopSOn," to 

Agency lettllr deted 

0 RNUbnUs~on In rO$po"" to Agancy lett., d~ 0 ·M. Too· Application. 

0 Notification· ExpltJin balow. E) OlMr - Explain below. 

Explanation: Usa additional pagel,) if neee",ry. {For svction land section 11.1 

Updated 8570-1 Form for a pending application. 

Section - 01 

1. Meterfal Thr. Produce Will BII pact.ted In: 

ChiJcf·Resietent Peck.gino Unit P.ackeging Weter Soluble Peckaging 2. Type of Conteln., 8 v .. 8 v .. ~ V .. 

I N. I N. N. ~~'" " PlQtic 

GIUB 

• CertHication must If -Yes- No. per If -Yes~ No. per P",,, 

Unit Packolging wgt. container Peckage wgt clnteinor Other ISpecifyt --... """'"'"~ ... btl wbmitt«I 

3. location of Net Content. Informetion 4. Sb:als' Retell Contain.r /5. location of label Oirectioft!l 

fl Lob" r J Container 10.25.100 plugs Ld On labeling accompanying product 

6. Mlnnar in Which Lebel it: Affix~ to PrO<kJct U Lithograph U 0 ..... 

P~O~Ued Sten .. 

Section -IV 

1. Contect Point (Comp/ata itams ~fly bmw for idHltHiwlfian of inrJiWdwl to ba conflICted. if n4'cNnlY. to proCtlSS this ~tion.( 

Nom, Title Telephone No.llnclude Attie Codel 

Amy Roberts, Technology Sciences Group, Inc. Regulatory Consultant (530) 757·1432 

Certification 6. Oet. Applieetion 

I certi1v trn,t the statoments I nave made on this form 0Ild 011 Ittachmlnte tbMeto •• true. eccur.t. 4'nd complot •• Roc""", 

I acknowledge that enV knowlinQllv false 01 n'Ii:tleading stetement may ba purn.hable by fin. or imprisonmant 01 (S_) both under eppliceJ.'.w. 

2.Sign~ , ( 3. Titl, 

/y,'l.~ RegUlatory Agent for PlUGGAB 

4. T,;..i,_ ~ 5.0ate 

Amy Roberts. 2-16-11 

.. . .. Whftto EPA FIiI Cop., {ongln.o . 
23

Fw: Label changes for product with EPA Reg. No. 86044-E with attachment 

Philip Errico to: Amy Roberts 02/16/2011 08:15 AM 

Cc: Kable Davis 

Amy, 

Please see attachment for label changes which were left out in the last email. 

~:~i 

Label changes lor product with EPA Reg No. 86044-[ doc 

Philip (Phil) V. Errico, Senior Chemist 

U. S. Environmental Protection Agency 

Office of Pesticide Programs 

Registration Division/Herbicide Branch (7505C) 

Phone: 703-305-6663 

Fax: 703-308-1825 

Email: Errlco.Philip@epa.gov 

---- FOlwarded by Philip Errico/OClUSEPA/US on 02/16/2011 08:12 AM ----

From: 

To: 

Cc: 

Date: 

SUbject: 

Amy, 

Philip Errico/OC/USEPAIUS 

Amy Roberts <ARoberts@TSGUSA.COM> 

Kable Davis/DC/USEPAlUS@EPA, Meredith Laws/DC/USEPAlUS@EPA 

02/16/201107:32 AM 

Label changes for product with EPA Reg. No. 86044-E 

Please see the attachmented label changes for your ROOTPLUG product with EPA Reg. No. 86044-E. 

Please also email a revised 8570-1 with the primary name and two alternate names. ! have no problem 

using your email for the name changes, but! have had problems in the past with our !abeling unit when 

the registration name and the 8570-1 name are not the same for a new product. 

!f you foresee any problem with getting the revised labe! back to me today by 12pm, your time, let me 

know. This registration is due tomorrow, and if the date can't be met, we will need an extension. 

Thanks. 

Philip (Phil) V. Errico, Senior Chemist 

U. S. Environmental Protection Agency 

Office of Pesticide Programs 

Registration Division/Herbicide Branch (7505C) 

Phone: 703-305-6663 

Fax: 703-308-1825 

Email: Errico.Phi!ip@epa.gov 
24

Label changes for product with EPA Reg. No. 86044-E 

I. On page 1, under "ROOTPLUG", add "NOT FOR USE AT RESIDENTIAL, SCHOOL, 

AND INSTITUTIONAL SITES". 

Replace the paragraph under "ROOTPLUG" with 'THIS PRODUCT CAN BE USED TO 

KILL TREES AND STUMPS IN THE NONFOODINONFEED SITES, FORESTS; PARKS; 

HIGHWAY, UTILITY, AND RAILROAD RIGHT-OF-WA YS; AND INDUSTRIAL AND 

FENCE ROW SITES". 

Also add, efficacy considerations pennitting, "CAN BE USED TO KILL THE TREES AND 

STUMPS OF ALDER, ASH, ASPEN, BEECH, BIRCH, CHERRY, ELM, LIME, MAPLE, 

OAK, AND POPLAR". 

Change the signal word, "DANGER", to "DANGERIPELlGRO", and add under 

"DANGERIPELIGRO", "Si usted no entiende la etiqueta, busque a alguien paraque se la 

explique a usted endetalle. (If you do not understand the label, find someone to explain it to 

you in detail.) 

2. On page 2, under "HAZARDS TO HUMAl'lS AND DOMESTIC ANIMALS:", change 

entire paragraph to read "INGREDIENTS IN ROOTPLUG CAUSES EYE BURNS. 

HARJv1FUL IF SWALLOWED. Do not get ingredients in eyes, on skin, or on clothing." 

Add the subheading "PERSONNAL PROTECTIVE EQUIPMENT (PPE):", then add 

"Applicators and other handlers must wear: 

• Coveralls worn over long-sleeved shirt and long pants. 

• Chemical-resistant footwear plus socks. 

• Chemical-resistant gloves. 

• Protective eyewear such as goggles." 

Then add the paragraph "Discard clothing that becomes contaminated with the 

ingredients in ROOTPLUG. Do not reuse them. Follow manufacturer's instructions for 

cleaning/maintaining PPE. If there are no such instructions for washables, use detergent and 

hot water. Keep and wash PPE separately from other laundry." Add an "USER SAFETY 

RECOMMENDATIONS" box, and in the box add "Users should: 

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

• Remove clothing immediately if pesticide gets inside. Then wash thoroughly and 

put on clean clothing. 

• Remove PPE immediately after handling this product. Wash the outside of gloves 

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

clothing. 

Under "DIRECTIONS FOR USE", remove "DO NOT OPEN OR SEPARATE THE PLUG". 

Move it under "PRECAUTIONS AND RESTRICTIONS" as discussed below. 

Add an AGRICULTURAL USE REQUIREMENTS box with the standard wording, but no 

re-entry interval or early entry PPE. Add "There is no re-entry interval (REI)." Also add the 

1 
25

specific sentence for ROOTPLUG, "Only protected applicators are allowed in area during 

treatment of sites." 

Add a ''NON-AGRICULTURAL USE REQUIREMENTS" box with the standard language. 

Add the specific sentence for ROOTPLUG, "Keep all unprotected persons out of area during 

treatment of sites." 

Under "Treatment of stumps", use "1 118 inches" and "1/2 inches" instead of "1 118" and liz" 

" 

Define what a "special drill bit" is, or remove the term. 

Add" ... hard rubber" before hammer. 

Maintain the same units of measurement, and use" 2 113 - 3 118 inches apart" instead of "6~8 

cm apart". 

At the end of the "DIRECTIONS FOR USE", add a section labeled "PRECAUTIONS AND 

RESTRICTIONS", and add the bullets 

• DO NOT OPEN OR SEPARATE THE ROOTPLUG UNITS. 

• DO NOT USE ROOTPLUG ON RESIDENTIAL, SCHOOL, OR INSTITUTIONAL 

SITES. 

• DO NOT USE THE HARD RUBBER HAMMER IN SUCH A MANNER THAT 

WILL COMPROMISE THE INTEGRETY OF THE ROOTPLUG UNITS. 

3. On page 3, remove the last sentence, "This warranty is also subject to the conditions and 

limitations stated herein." The conditions and limitations were already stated immediately 

above this sentence, and this sentence appears misleading. 

2 
26

PLUGGAB 

511 AVENUE OFTHEAMERICAS, SUITE #316, NEW YORK, N.Y. USA 

PHONE: +46 8 54027967, FAX: +46 8 4410892, MOBILE: +46707504953 

EMAIL: info@pluggab.com WEBB: www.pluggab.com 

20090223 

Re: Application to register our pesticide ECOPLU MAX. 

Please find enclosed documents that we think should be apropriate to complete the application. If not, plese get back to 

us at your earliest convinience. 

The product applied from above in small tree and a bit bigger. 

Regards, 

Sverker G. Olsson 
27

21-Day Screen Completed by 

Contractor 

21-Day Expires on r?~ If -I () 

Jacket # $60 cPI-E 

MRID# /f? /00 

Content Screen: Recommended to 

IPas~Fan 

86-5 Review· Passe Failed/NA 

Transfer This Jacket to: 
28

PRlA 2 - 21 Day Content Screen Review Worksheet 

(EPA/OPP Use Only) 

3/23/09 

21 Day Screen Start Date: , 7 - z C -/0 

Experts In-Processing Signature: rt? ¢"' ./-6rM...-JUDI--J Date '7-2) -/0 Fee Paid: Yes ~ Division management contacted on issues No Yes Date 

EPA Reg. Number: ¥ ~ 0 t.; t; _ EPA Receipt Date: 7-ZC-IO 

1 

2 

3 

4 

5 

6 

Items for Review 

Application Form (EPA Form 8570-I)(link to form) signed & complete 

including package type 

Yes No N/A* 

Confidential Statement of Formula all boxes completed, fonn signed, and X 

dated Form to 

a) All inerts (link to http://www.epa.gov/opprdOOIlinerts/).no 

including fragrances, approved for the proposed uses (see 

Footnote 

Certification with Respect to Citation of Data (EPA Form 8570-34) (Link to 

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

Certificate and data matrix consistent 

If applicant is relying on data that are compensable, is the offer 

to pay statement included. (see Footnote B) 

yes no 

Exemption Statement (EPA Form 8570-27) (Link to form) 

and signed (N/ A if source is unregistered or applicant owns the 

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

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

Selective Method 

b) Cite-All (Fee category experts use) 

c) Applicant ovms all data (Fee category experts use) 

5 Copies of Label (link to http://www.epa.gov/oppfeadlllabelingllrmD 

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

http://www.epa.gov/pesticidesfregulating/registering/submissionsfindex.htm#labels 

I 

x 
29

7 Is the data package consistent with PR Notice 86-5 (link to PRN 86-5) X 

Notice of Filing (link to 

8 h ttl2:/ /www.e[!a.gov/J!esticides/regulating/tolerance eetitions.htm) included 

with petitions (link to 

http://www.epa.2ov/pesticides/re2ulatinvtolerances.htm) ~I 9 

If applicable for conventional applications, reduced risk rationale (link to 

http://www.epa.gov/opprdOOl!workplan/reducedrisk.html) X 

Required Data (link to 

htt)]::/ /www.eI!a.gov/nesticides/regulatin2fdafa reguirements.htm) and/or 

data waivers. See Footnote C. 

a) List study (or studies) not included with application 

10 

, 

2 
30

Comments: 

.r., 

* N/A - Not Applicable 

Footnotes 

A During the 21 day initial content review, all eSFs will be reviewed to determine 

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

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

example, removing the inert, substituting it with an approved inert, submitting 

documentation that EPA approved the inert for the proposed pesticidal uses, correcting 

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

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

eSF and may require submission of data. All information, forms. data 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 complete 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 uses even if a product is currently registered by consulting the inert Web 

3 
31

site [link to http://www.epa.gov/opprdOOllinerts/lists.html] and 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. Some inert 

ingredients are no longer approved for food uses or certain types of uses. The 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 Assessment 

Branch (IIAB) at inertsbranch@epa.gov and resolve the issue. Copies ofthe 

correspondence with IIAB resolving the issue should accompany the application. All 

new inerts except PIP inerts are reviewed by lIAB. The IIAB should also be contacted 

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

inert review process. Questions on PIP inerts should be directed to the Chief of 

Microbial Pesticides Branch [Link to 

http://www.epa.gov/oppbppdllbiopesticides/contacts bppd.htm J. 

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

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

information [link to http://www.epa.gov/opprdOOllinerts/tips.pdfl must also be included 

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

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

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

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

fragrance supplier to provide the component information to the Agency or promptly upon 

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

cannot or are not identified or 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 conventional new products and PIPs 

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

applicant with the following options: 

1. Correct the application by, for instance, correcting the 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. Submit the information and data needed for the Agency to approve the 

unapproved inert If this option is selected and implemented, the Agency may 

request an extension in the PRIA decision review timeframe to accommodate 

the inert review/approval process; 

4 
32

3. Withdraw the application (the Agency retains 25% of the full fee 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 Applications 

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. Correct the application by, for instance, correcting the 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. Submit the infonnation 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. (This option may change the PRIA 

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

time and a larger fee. If additional fees are due, they must be received by the 

Agency within the 21 day content review period.) 

3. Withdraw the application (the Agency retains 25% of the full fee for the fee 

category estimated); or 

Ifnone of the above options is selected and 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. Correct 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. Submit the infonnation and data needed for the Agency to approve the 

unapproved inert. If 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. If this option is selected and implemented, the 

Agency will discuss harmonizing the timeframe for both actions. 

5 
33

3. Withdraw the application (the Agency retains 25% of the full fee for the fee 

category estimated); or 

Ifnone of the above options is selected and 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 to 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 authorizations of offers to pay will be placed into either R30 I or 

A531. The Agency recommends that authorizations of offers to pay be submitted with 

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

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

prior to submitting their application to the Agency. Documentation of such discussions 

should be submitted with the study waiver. 

6 
34

I ( 

Script for Rejection Phone calls 

Contact Name: "'j h, <:;hQ( f"' ~ 

Phone #: ;;10;;> - f~P -89"-'1 

Email: fI1ev<en@+SJ()S"-.L~ 

First Calliinitials: Second Calliinitials: 

Date: 7/:.4 

Time: 1-/5 

Date: 

Time: 

, EPA contractor. 

I'm calling regarding your submission in support of 

+r/;c(\b"1Jy, 4r- '1'<£c1 '[s,b,h'&.-... KW o </..f-E "£cD f' lv5 

We have found the following deficiencies regarding: 

PR Notice 86.5: Yes or No 

Volume/Stndy Title: 

Volume/Study Title: 

Volume/Study Title: 

Additional volumes continued on back of page: Yes or No 

Application Package: ~or No 

b",k Iht.:..f-r-;\( 1'~ISS;:J s3IJ ~·3D2 I i?30. &30'-/ j)q-ht 

These deficiencies have been approved by EPA. 

The corrections can be faxed to 703-305-5060/Attn: _______ _ 

Second Call1Email: 

If we do not receive the corrections by , we will process 

your submission, accordingly. Please direct all future calls and 

correspondence to the appropriate EPA Risk Manager. 
35

RE: Application for Registration of Ecoplug 

Megha Even to: Jennifer Drobish 

Cc: Sree Nair 

Hi Jennifer. 

07/29/201002:47 PM 

Attached please find a revised data matrix. Sorry for missing color and 

odor. 

THanks, 

Megha S. Even 

Regulatory Scientist 

Technology Sciences Group Inc. 

1150 18th Street NW, Suite 1000 

Washington DC 20036 

Tel: 202-828-8954 

Fax: 202-872-0745 

email: meven@tsgusa.com 

web: www.tsgusa.com 

----~Original Message---~-

From: Drobish.Jennifer@epamail.epa.gov 

[mailto:Drobish.Jennifer@epamail.epa.gov] 

Sent: Thursday, July 29, 2010 1:51 PM 

To: Megha Even 

Cc: Nair.Sree@epamail.epa.gov 

subject: Application for Registration of Ecoplug 

Ms Even, 

This is Jennifer Drobish, EPA contractor. I am writing to follow up on 

the message that I left regarding the subject application. Data for 

guidelines 830.6302 and 830.6304 are missing. If this data has already 

been generated, you can add these guidelines and the MRIDs to the Data 

Matrix. If the data has not been generated it will need to be and 

submitted. If you have any questions please feel free to contact me. 

Thank you, 

Jennifer Drobish 

EPA Contractor 

703-305-1671 
36

( ! 

UNITED STATES ENVIRONMENTAL PROTECTIuN AGENCY 

WASHINGTON, D.C. 20460 

July 28, 20 I 0 

OPP Decision Number: D-437729 

EPA File Symbol or Registration Number: 86044-E 

Product Name: ECOPLUG 

EPA Receipt Date: 26-Jul-2010 

EPA Company Number: 86044 

Company Name: PLUGGAB 

SVERKER OLSSON 

PLUGGAB 

511 AVENUE OF THE AMERICAS, SUITE 316 

NEW YORK, NY 10011-

OFFICE OF 

PREVENTION, PESTICIDES AND 

TOXIC SUBSTANCES 

SUBJECT: Receipt of Application and 75% Small Business Waiver Request 

Dear Registrant: 

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

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

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

screen, the Office of Pesticide Programs has detelTIlined that this Action is subject to a Pesticide 

Registration Service Fee as defined in the Pesticide Registration Improvement Act. 

The Action has been identified as Action Code: R31 0 

NEW PRODUCT;NON-FAST TRACK (INCLUDES REVIEWS OF PRODUCT 

CHEMISTR Y;ACUTE TOXICITY;PUBLIC HEALTH PEST EFFICACY); 

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

detennination is made regarding your request. If your waiver request is approved, the decision 

review time period vvill start on the date of approval. If 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. 

S~rely, 0 

Front /.,..V/...Uld... End Processing ~ Staff 

Infonnation Technology & Resources Management Division 
37

IFee for Servicel 

JI 

(8791850-

This package includes the following I I for Division 

I 

@ New Registration °AD 

° Amendment I!- oBPPD 

@RD 

/¥Stu9ieS? ,r/Fee Waiver? [,- I S#-kLL 1S'..t Sll"''-''S.'' A~V<-~' k M J.<j zJ'l IS gr. o volpay % Reduction: f}it->u I 

Receipt No. s-I 879185 

EPA File Symbol/Reg. No. I 86044-E 

Pin-Punch Date: I 7/26/2010 

o This item is NOT subject to FFS action. 

[KJ 

Action Code: I Parent/Child Decisions: 

Requested: 

Granted: 

Amount Due: 

o Uncleared Inert in P7duct 

Reviewe r::_i!.-lL~-"---:ll:::::!::::::::!::::::3~J,G'--!I!L1'S~ Date: 1! "G'd ! () 

o Inert Clea ed for Intended Us 

I 

Remarks: 

NeT[; f'-I~L' 2 CO ?LJ..(i;; 1$ /VOT /Hr,Lo ?lLvi-TL 

I 

i 

I 

I 
38

r 

Sverker Olsson 

Fran: 

Skickat: 

Till: 

paygovadmin@maiLdoc_twai.gov 

den 24 juri 201018:33 

sverker@pluggab.com 

Amne: Pay.Gov Payment Confirmation 

THIS IS AN AUTOMATED MESSAGE. PLEASE DO NOT REPLY. 

Your transaction has been successfully completed. 

Transaction Summary 

Application Name: PRIA Service Fees 

pay.gov Tracking IO: 2516EB6E 

Agency Tracking IO: 74128501967 

Account Holder Name: Sverker Olsson 

Transaction Type: Sale 

Transaction Amount: $1,145.00 

Billing Address: Kommendorsvagen 19 

City: Akersberga 

Zip/Postal Code: 18492 

country: SWE 

Card Type: Master Card 

Card Number: ************5860 

Transaction Date: Jul 24, 2010 12:32:36 PM 

Decision Number: 

Registration Number; 

company Name: PLUGGAB 

Company Number: 86844-R 

Action Code: R318 

1 

(,' , (, (' 

'( ( ( 

" , 
39

PI, • read' t ~ • ... ~ ~J fo~. FonnA rovek JM9 No. 2070-00 I .,.,;~ 2·28·9 • 

United Stetes ~ Registration opp Identifier Number 

oEPA Environmental Protection Agency Amendment 

W.,shington, DC 20460 Other 

Application for Pesticide • Section I 

1. Company/Product Number 2. EPA Product Manager 3. Propos&e\ Cla •• ificetion 

86044·R Jim Tompkins o Nono D Restricted 

4. Company/Product IName) PM. 

ECOPLUG 25 

5. Noma lind Addross of Applicant Ilnclude ZIP Cods} 6. Expedited Reveiw. In accordance with FlFAA Section 3(c)(3) 

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

511 Avenue of the Americas, Suite 316 to: 

New York, NY 10011 EPA Reg. No. 

D Chflck if rhi$ rs. new sddr9S$ Product Name 

Section· II 

D Amendment - Explain below. U Final printad I,bel. in repsonse to 

Agency 10«8r dated 

0 Rosubmission in response to Agency letter dated 10/7/09 D ~Ma Too~ Applicetion. 

D Notification - Explain below. D Other - Explain below. 

Explanation; Use additional pagels) it nacessery. tFor section I end Saction II.) 

This submission of an application to register a new enduse product is proVided to the Agency in response to a "no grant" issued on Oct. 7, 2009. The 

application was withdrawn and is resubmitted herein. A Small Business Waiver and PRIA fees are included in this submission (Pay.Gov Tracking ID: 

2516EB6E Agency Tracking 10: 74128501967). Please see the cover leller for additional "Information. 

Contact Information; Megha S. Even. meven@tsgusa.com; fax number 202-872-0745; voice number 202-828-8954 

Section· III 

t. Metarial Thi. Product Will Ba Pecbged In: 

Child-Resistant Packaging Unit Packaging Water Soluble Peckaging 2. Type of Containar 8Y

" 8Y

" B y" [;J M",I 

.f No .f No 

J' Plastic 

No Glass 

.. CtJrtification must If ~Vas~ No. par If "Ves~ No. p!r Peper 

Unit Peckeging wgt. container Packaga wgt contalnar Other (Specify) , .... ~"""' .. """"""~"'. 

be submitted 

3. location of Net Contents Information 4. Size(5) Retail Contllinor 5. location of labal Directions 

[{I lubal U Container 10,25,100 plugs ~ On labeling accompanying produc( 

6. Manner in Which lubal is Affixad to Product oUthograPh 0 Other 

Peper Pt,ued Stenci ed 

Section· IV 

I. Contect Point (Compi.to ftoms directly b%w for idrmtificatfon of rndlvidulll to b. conracrad. if nOCO$$ary, to proCfJ$S this ap,*~·M;o"!J 

" ". Nama Tltla Telephone No.,I!nciu,de Area Code) 

Megha Even, Technology Sciences Group, Inc. Regulatory Scientist (202) 828-8954 ",:. /J6')' <);)-3- ,. 

oy 

. , , , , , 

Certification 6. Dat~ A~plicetion 

I cenify that tha statemonts I hove made on this form and aU attachments tharato aro true, accurata and c~mrl!,,'iI Fie.,elvf'(l 

I acknowladge that eny knowlinQlly felse or misleeding stetament may be punishablo by fina or imprillonment ur I~tamped) both under appliceble law. 

2. Signeture 3. Title 

~01A Regulatory Agent for PlUGGAB 

4_ Typed Nama V OC 5.00ta 

Megha Shah Even 7/26/10 

.. EPA Form 8570-1 (ReV. 3-94) PreVIous edillons ore obsolete. . . Whit •• EPA FiJ. Copy (on;lnaJl Vellew • Applicant Copy 
Pages 40-41-*Claimed confidential by submitter*
42

VOLUME 1 OF 2 OF SUBMISSION 

TRANSMITTAL DOCUMENT 

NAME AND ADDRESS OF SUBMITTER: 

PLUGGAB 

511 Avenue of the Americas, Suite 316 

New York, NY 10011 

REGULATORY ACTION: 

Resubmission of application to register ECOPLUG (EPA Reg. No. 86044-R) in response to 

a "no grant" from EPA in a letter dated Oct. 7, 2009. 

PRIA Code R310 

TRANSMITTAL DATE: 

July 26, 2010 

LIST OF SUBMITTED STUDIES: 

MRID 

NUMBER 

VOLUME 

NUMBER 

1 012 

2012 

COMPANY NAME: 

COMPANY OFFICIAL: 

COMPANY CONTACT: 

EPA STUDY TITLE 

(Transmittal Document) 

ECOPLUGTM 

Product Properties Part A 

PLUGGAB 

Megha$. Even 

GUIDELINE 

NUMBER 

830.1550 - 830.1900 

Megha S. Even, Regulatory Consultant 

Technology Sciences Group, Inc. 

1150 18th Street, N.W., Ste. 1000 

Washington, DC 20036 

(202) 828-8954; meven@tsgusa.com 

Page 1 of! 
43

Form Approvo. 1MB No. 2070-0060. Approval Expiro. 5·31-98. 

United Stllte' 

&EPA Environmental Protection Agency 

W .. hinoton. DC 20460 

Formulator's Exemftion Statement 

(40 CFR 1 2.851 

Applicant's Name and AddrallS EPA File SymbollRagistration Numbor 

PLUGGAB 86044-R 

511 Avenue of the Americas, Su'ite 316 

New York:, NY 10011 Product Name 

ECOPLUG 

oete of Confidential StetllfTl.nt of Formule (EPA Form 857D-4J 

July 26, 2010 

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

111 This product contains the following active ingredient(s): 

Glyphosate, ammonium salt 

121 Of 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, is purchased by us from another producer, and is labeled for at least 

each use for which my product is proposed to be labeled. 

13) Indicate by checking (A) or (B) below which paragraph applies: 

~ (A) An accurate Confidential Statement of Formula (EPA FORM 857().4j for the above identified product 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 11), 

D OR 

(B) The Confidential Statement of Formula (CSF) (EPA Form 8570-41 referenced above and on file with the EPA is 

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

14) The following active ingredients in this product Qualify for the formulator's exemption. 

Source 

Active Ingredient Product Name Regi.tration Numb ... 

Glyphosate, ammonium salt 

« 

. 

Signature /1Mx,yll L L-. 

Name and Title Date 

Megha S. Even, Regulatory Consultant 7/2& liD 

EPA Form 8570:27 (R.y~5)J white ~ EPA copy 

Yellow - Applic.nt cOPY 

*Product ingredient source information may be entitled to confidential treatment*
44

F onn Approve dOMS No.2070-o 060 

--.. '" UNITED STATES ENV(RONMENTAl PROTECTION AGENCY \l.lI!'ll ,;:;;I 401 M Street, SoW. 

WASHINGTON, D.C. END USE ONLY 20460 

Paperwork Reduction Act Notice: The public reporting burden for this collection of infonnation 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 and completing the necessary forms. Send 

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, 40t M Street, S.W., Washington, DC 20460. 

00 not send the completed form to this address. 

Certification with Respect to Citation of Data 

Applicant's/Registranfs Name, Address, and Telephone Number EPA Registration NumberlFile Symbol 

PLUGGAB, 51 t Avenue of the Americas, Suite 316, New York, NY 1001 t 86044-R 

Active Inoredientfs) andfor representative test compound/s) Date 

103604 July 26, 2010 

General Use Pattem/s) (list all those da'lmed for this product USin!l 40 CFR Part 158) Product Name 

Outdoor ECOPLUG 

NOTE: If your product is a 100% repackaging of another purchased EPA-registered product labeled for all the same uses on your label, you do not need to 

submit this form. You must submit the Formulator's Exemption Statement (EPA Form 8570-27). 

0 I am responding to a Data-Call-In Notice, and have included with this form a list of companies sent offers of compensalion (the Dala Matrix fonn should 

be used forthis purpose). 

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

0 I am using the cite-all method of support, and have included with this form 0 I am using the selective method of support {or cije-all option 

a list of companies sent offers of compensation (the Data Matrix form under the selective method), and have included with this form a 

should be used for this purpose). completed list of data requirements (the Data Matrix fonn must be 

used). 

SECTION II: GENERAL OFFER TO PAY 

(Required if using the cite-all method orwhen using the cite-all option under the selective method 10 satisfy one or more data requiremenls] 

0 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 rrr: CERTIFICATION 

I certEfy that Ihis application for registration, this fonn for reregistration, orthis Data-Call-In response is supported by all data submitted or dted in the 

application for registration, the form for rereg'Etration, or the Data-Call-In response. In addition, if the cite-all option or cite-all option under the selective method is 

indicated in Seclion I, this application is supported by all dala in the Agency's files that (1) concem 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 ofthls application if the application sought the initial registration of a product of identical or similar composition and 

uses. 

I certEfy that for each exclusive use study cited in support of this registration or reregistration, that I am the original dala submitter or that I have obtained 

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

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

submitter, (b) I have obtained the permission of the orlginal data submitter to use the study in support of this application; (c) all periods of eligibility for 

compensation have expired for the study; (d) the study is in the public literature; or (e) I have notified in wrlting the company that subm~ted the study and have 

offered (I) to pay compensation to the extent required by sections 3(c)(t)(F) andfor 3(c)(2)(8) of FIFRA; and (ii) to commence negotiations to d6t't!I,rir~e the 

amount and tenns of compensation, if any, to be paid for the use ofthe sludy. ", , 

" , I certify that in all instances where an offer of compensation is reqUired, copies of all offers to pay compensation and evidence of their d"'liV;dry in 

accordance with sections 3(c)(1)(F) andfor 3{c)(2)(B) of FIFRA are available and will be submitted to the Agency upon requf'st. Should 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 regiS~atio~, of~:l1y produ~ i~ conforml\y with 

FlFRA. 

" , " 

I certify that the statements I have made on this form and all attachments to It arc true, accurate, and complete.' I ackno\"l"lrire that any 

knowingly false or misleading statement may be punishable by fine or imprisonment or both under applicable la",·, 

" , 

Signature !1itI(;' Q~ Date Typed or Printed Name and Title 

7/26/10 Megha S. Even, Regulatory Consultant 

EPA Fonn 857Q.:J4 (9-97) EI ~I{rcan Paper versions available. Submil only Paper version. 

0' 
45

( 

R 310 

Must submit Group A and B product chemistry data for each proposed product. 

End Use IEP) or Manufacturing Use IMP) product or Technical Grade of the Active Ingredient ITGAI) 

EP Dala MP Dala 

Guideline Group A: Product Chemislry Data Submilfed Submilfed TGAI 

No. SIudy Tille Yes No Yes No Yes No 

830.1550 Product Identity & Composilion v 

Description of materials used to 

830.1600 v I produce the product 

830.1650 Description of formulation process v 

830.1670 Discussion on the formation of impurities v 

830,1700 Prelim'lnary analysis /' 

830.1750 Certified limils 1158,3451 V' 

830.1800 Enforcement analytical method V' 

EP Data MP Data 

Guideline Group B: Product Chemislry Data Study ~1.Il>J'!: 

metal ions 

Ii 

i I 

Point 

i i 

Water 

not 

1 
46

R 310 

New products must either: 1) supply the product specific acute toxicity 6 pack data (listed below), 

or 2) provide a bridging rationale document. The bridging document directs opp to use a currently 

registered set of 6 acute toxicity data and label; instead of submitting product specific data. 

Data 

Guideline Acute toxicity (6 pack) submitted Cited 

No, study Title Yes No Yes No 

870.1100 Acute Oral [LD50) v 

870.1200 Acute Dermal (LD50L v" 

870.1300 Acute Inhalation [LC50) ./ 

870.2400 Acute Eye Irritation ./ 

870.2500 Acute Dermal Irritation / 

870.2600 Dermal Sensitization / 

Efficacy - which guideline is used depends on the proposed label use 

Data 

Guideline submitted Cited 

No. Study Title Yes No Yes No Comments 

810.3100 Soil Treatments for Imoorted Fire Ants v 

Livestock, Poultry, Fur and Wool-Bearing 

810.3200 Animal Treatments v 

Treatments to Control Pests of Humans 

and 

810.3300 Pets ./ 

Mosquito, Black Fly, and Biting Midge 

810.3400 [Sand Fly) Treatments ./ 

810.3500 Premises Treatments v 

810.3600 structural Treatments ./ 

Methods for Efficacy Testing of Termite 

810.3800 Baits / 

2 
47

F

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 

401 M Street, S.W. lEND US

WASHINGTON, D.C. 20460 

Paperwork Reduction Act Notice: The public reporting burden for \hilS coUection of Information ilS estimaled 10 average 0.25 hours per response for registration and 0.25 

reregistrafion and special review activities, including time for reading the instructions and completing the necessary forms. Send comments regarding the burden estimate or any ot

information, including suggeslionsfor reUuclng the burden to: Director, OPPE Information Management DiviSion (2 (37), U.S. Environmental Protect'lon Agency, 40f M street, S.W

send the form to this address. 

DATA MATRIX 

Date 7129/20 fO EPA Reg NoJFile Symbol 86044-R 

Name & Address Product 

PLUGGAB, 5ff Avenue of the Americas, Suite 3t6, New York, NY ro011 ECOPLUG 

Ingredient Glyphosate, ammonium salt - PC Code ro3604 

GuideHne Reference Guideline Study Name MRID Number Submitter 

OPPTS 830. f550 Productldenlily and Composition TSA PluggAB 

DPPTS 830. f600 Description of Methods Used 10 Produce the Product TBA PluggAB 

OPPTS 830.t650 Description or the Formulation Process TSA PluggAB 

OPPTS 830. f670 Discussion of the Formation of Impurities TSA PluggAB 

OppTS 830. flOO Preliminary Analysis TSA PluggAB 

OPPTS 830.t750 Certifled Umits TSA PluggAB OPPT$ 830. f800 EnforeemenlAnalytical Method TBA PluggAB 

DPPTS 830.1900 Submitial ot Samples TSA PluggAB 

OPPT$ 830.6302/6304 Color/Odor 40853901 Monsanto Company 

OPPTS 830.6303 Physical Slate 4085390f Monsanlo Company 

DPPTS 830.63t4 Oxidation/Reduction: Chemical Incompatibility 40853901 Monsanto Company 

OPPTS 830.63 IS Flammability 40953901 Monsanto Company 

OPPTS 830.6316 ExplodabilHY 4085390t Monsanlo Company 

OPpTS 930.6317 Storage Stability 43038101 Monsanto Company OPPTS 830.63t9 Miscibility 40853901 Monsani<J Company 

Signature Irvvj!/lJ Name and Tille 

Megha S. Even. Regulatory Consultant for PLU

EPA Form 8570-35\?j1J Electro "1'! aper versions availabte. Submit only Paper version. Agency tnto
48

,.-.. , F

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 

401 M Street, S.W. lEND USE 

WASHINGTON, D.C, 20460 

Paperwork Reductlon Act Notice: The public Il!porting burden for \hjs collection of information is estimated to average 0.25 hours per response for registration activities and 0.25 

reregistration and special review activities, including time for reading Ihe instructions and oompteting Ihe necessary forms. Send comments regarding Ihe burden estimate or any ol

inrormalion, including suggestions for reducing the burden 10; Director, OPPE Information Management Division {2t37), U.S. Environmental Protection Agency. 401 M Street, S.W.

send the form 10 this address. 

DATA MATRIX 

Dale 7/29/2010 EPA Reg No.lFi1e Symbol 86044·R 

Applicant'slRi!Qistran\'s Name &Address Product 

PLUGGAB, 511 Avenue of the Amelicas, Suite 316, New York, NY 10011 ECOPLUG 

Ingredient Glyphosate, ammonium salt· PC Code 103604 

GUideline Reference Number Guideline Study Name MRID Number Submitter 

OPPTS 830,6320 Corrosion Characterislics 43038101 Monsanto Company 

OPPTS 830.632t Dielectric breakdown Voltage 40853901 Monsanto Company 

OPPTS 830,7000 pH 4085390t Monsanto Company 

OPPTS 830.7100 Viscosity 40853901 Monsanto Company 

OPPTS 830.7300 Density, Bulk Density. Specific Gravity 40853901 Monsanto Company OPPTS 870. t100 Acule Oral Toxiclty In Rals Waiver- AC"'1pt Cat 1 ptuggAB 

OPPTS 870.1200 Acute Dermal ToxicHy Waiv",· Accept Cat r PluggAB 

OPPTS 870.1300 Acute InhalaUon Toxicity Waiver· Accept Cat 1 PluggAB 

OPPTS 870.2400 Primary Eye Irritation Waivel- Ac"'"pt Cat.l PluggAB 

OPPTS 870.2500 Primary Skin Irritation Walver- Ac"'1p! Cat! PluggAB 

OPPTS 870.2600 Skin Sensitization Waiver· Accep! Cal.! PluggAB 

Signature Name and TItle 

Megna S. Even, Regulatory Consultant for PLU

EPA Form 8570-35 (9-97) Electroiifr7.lnd Submit only Paper version. Agoncy tnte
49

A 

" 

". 

IFII.E SYMBOL 

• 

. &, 

CONFIDENTIAL STATEMENT OF'FORMULAENCLOSEDr 

DATE 

SUBMITTED 

Ut L62010 

SUBMITTED BY (,I) 

APPI.ICANT BASte SUPPLIER Do Not Write Comments, 

Formula, or Parts of Formula 

on This Envelope 

NOTE 

It shall be unlawful-for any person to use for his oWl;t' 

Of to reveal, other than to the Secretary, or officials Of employe'es 'a 

the United States Department of Agriculture or other, Feder,s,1 

or to the courts In response to a subpoena. or'to physicians. end 

emergencies to phannaclst& and other qualffied persons, for use" 

the preparation of antidotes, In accordance with such directions 

the Secretary may prescdbe, ,any Information relative to formulas 

products acquired by authortty of Section 4 of the 

Fungtclde. and Rodenticide Act. .. 

..... 
tial Statement of Formula may be entitled to confidential treatment*
ngredient source information may be entitled to confidential treatment*