1 

### UNITED STATES ENVIRONM ENTAL PROTECTION AGENCY WASHINGTON, D.C. 20460
OFFICE OF CHEMICAL SAFETY AND POLLUTION PREVENTION 

### Nove mber 2 7 , 2013 GENERIC DATA CALL-IN NOTICE CERTIFIED MAIL Dear Sir or Madam: This Notice requires you and ot her registrants of pesticide products containing the active ingredient(s) identified in Attachments 1 and 2 of this Notice to submit certain data as noted herein to the U.S. Environmental Protection Agency (EPA, the Agency). These data are necessary for the Registration Review of your pesticid e product(s) in its Registration Review case and to maintain the continued registration of your product(s) containing the active ingredient(s). Within 90 days af ter you receive this Notice, y ou must respond as set forth in Section III below. Your response must state: 1. How you will comply with the requirements set forth in this Notice and its Attachments 1 through 5; or, 2. Why you believe you are exempt from the re quirements listed in this Notice and in Attachment 3, Generic Requirements Status and Registrant's Response Forms and Instructions Form, (see section III-B); or, 3. Why you believe EPA should not require your su bmission of data in the manner specified by this Notice (see section III-D). If you do not respond to this Noti ce, or if you do not satisfy EPA that you will comply with its requirements or should be exempt or excuse d from doing so, then th e registration of your product(s) subject to this Notice wi ll be subject to suspension. We have provided a list of all of your products subject to this Notice in Attachment 2, Generic Data Call-In Response Forms And Instructions Form, as well as a list of all registrants who were sent this Notice (Attachment 4). The authority for this Notice is section 3(c)(2 )(B) of the Federal Inse cticide, Fungicide and Rodenticide Act (FIFRA), as ame nded 7 U.S.C. section 136a(c)(2)(B ), sections 3(g)(2)(A) and (B) of FIFRA, as amended 7 U.S.C. sections 136 (a)(g)(2)(A) and (B), and section 408(f)(1)(A) of the Federal Food, Drug, and Cosmetic Act (FFDCA), 21 U.S.C. section 346a(f)(1)(A). This notice is also authorized by 40 CFR Part 155.48 and 40 CFR 155.53(b), which are sections in the Agency’s Registration Review regulations addressi ng the use of Data Call-In Notices as part of Registration Review. Collection of this information is in compliance with the Paperwork Reduction Act (44 U.S.C. 3501 et seq.) as approved by the Office of Management and Budget (OMB) under Control Number 2070-0174.

This Notice is divided into si x sections and five Attachments. The Notice itself contains information and instructions applicable to a ll Data Call-In Notices. The Attachments contain specific chemical information and instructi ons. The six sections of the Notice are:2 

### Section I. Why You Are Receiving This Notice Section II. Data Required By This Notice Section III. Compliance With Requirements Of This Notice Section IV. Consequences Of Failure To Comply With This Notice Section V. Registrants' Obligation To Re port Possible Unreasonable Adverse Effects Section VI. Inquiries And Responses To This Notice The Attachments to this Notice are: Attachment 1. Data Call-In Chemical Status Sheet Attachment 2. Generic Data Call-In Response Forms and Instructions Attachment 3. Generic Requirements Status and Registrant's Response Forms and Instructions Attachment 4. List of All Registra nts Sent this Data Call-In Notice Attachment 5. Additional Documents and Information

• Confidential Statement of Formula and Instructions

• Certification of Attempt to Enter into an Agreement with Registrants for Development of Data

• Certification with Respect to Citation of Data

• Paperwork Reduction Act Notif ication for DCI Respondents SECTION I. WHY YOU ARE RECEIVING THIS NOTICE The Agency has reviewed existing data for the ac tive ingredient(s) identified in Attachments 2 and 3 of this Notice, and reevaluated the data needed to support conti nued registration of the subject active ingredient (s) and the continuation of any exis ting tolerances or exemptions for such active ingredient. This reevaluation conducted as part of Registration Review identified additional data necessary to assess the health and safety of the continued use of products containing this active ingredient(s ). You have been sent this Notice because you have product(s) containing the subject active ingredient(s). SECTION II. DATA REQUIRED BY THIS NOTICE
A. DATA REQUIRED The data required by this Notice ar e specified in the Attachment 3, Generic Requirements Status and Registrant's Response Forms and Instructions Form. Depending on the results of the studies required in this Notice, additional testing may be required. B. SCHEDULE FOR SUBMISSION OF DATA You are required to submit the data or otherw ise satisfy the data requirements specified in Attachment 3, Generic Requirements Status and Registrant's Response Forms and Instructions Form, within the time frames provided. C. TESTING PROTOCOL All studies required under this Notice must be conducted in accordance with test standards outlined in the Pesticide Assessment Guidelines for those studies for which guidelines have been established. These EPA Guidelines are available from the National Technical Information Service (NTIS), Attn: Order Desk, 5285 Port Roya l Road, Springfield, VA 22161 (tel: 703-605- 6000).3 

### Protocols approved by the Or ganization for Economic Cooperation and Development (OECD) are also acceptable if the OECD-recommended test standards conform to those specified in the Pesticide Da ta Requirements regulation (40 CFR Part 158.70). When using the OECD protocols, they should be modified as appropriate so that th e data generated by the study will satisfy the requirements of 40 CFR Part 158. Normally, the Agency will not extend deadlines for complying with data requi rements when the stud ies were not conducted in accordance with acceptable standards. Th e OECD protocols are available from 2001 L Street, N.W., Suite 650, Wash ington, D.C. 20036 (Tele phone number 202-785-6323; Fax telephone number 202-785-0350). All new studies and proposed protocols submitted in response to this Data Call-In Notice must be in accordance with Good Laboratory Practices [40 CFR Part 160.3(a)(6)]. D. REGISTRANTS RECEIVING PREVIOUS SECT ION 3(c)(2)(B) OR (4)(f)(1)(A) NOTICES ISSUED BY THE AGENCY Unless otherwise noted herein, this Data Call-In does not in any way supersede or change the requirements of any previous Data Call-In(s) , or any other agreements entered into with the Agency pertaining to such prior Notice. Registra nts must comply with the requirements of all Notices to avoid issuance of a Notice of Intent to Susp end their affected products. SECTION III. COMPLIANCE WITH REQUIREMENTS OF THIS NOTICE A. SCHEDULE FOR RESPONDING TO THE AGENCY The appropriate responses initially required by this Notice must be submitted to the Agency within 90 days after your receipt of this Notice. Failure to adeq uately respond to this Notice within 90 days of your receipt will be a basis for issuing a Notice of Intent to Suspend (NOIS) affecting your products. Th is and other bases for issuance of NOIS due to failure to comply with this Notice are pres ented in Section IV-A and IV-B. B. OPTIONS FOR RESPONDING TO THE AGENCY The options for responding to this Notice are: 1) voluntary cancellation, 2) delete use(s), (3) claim generic data exemption, (4 ) agree to satisfy the data requirements imposed by this Notice or (5) request a data waiver(s). A discussion of how to respond if you chose the Voluntary Cancellation option, the Delete Use(s) option or the Generic Data Exemption option is presented below. A discussion of the various options available for satisfying the data requirements of this Notice is contained in Section III-C. A discussion of op tions relating to requests for da ta waivers is contained in Section III-D. There are two forms that accompany this Notice of which, depending upon your response, one or both must be used in your response to the Agency. These forms are the Attachment 2, Generic Data Call-In Response Forms And Instructions Form and the Attachment 3, Generic Requirements Status and Registrant 's Response Forms and Instructions Form. The Attachment 2, Generic Data Call-In Response Forms And Instructions Form must be submitted as part of every response to this Noti ce. Please note that the company's authorized representative is required to sign the first page of the Attachment 2, Generic Data Call-In Response Forms And Instructions Form and the Attachment 3, Generic Requirements Status and Registrant's Response Forms and Instructions Form and initial any subsequent pages. The forms contain separate detailed instructi ons on the response options. Do not alter the4 

### printed material. If you have questions or need assistance in preparing your response, call or write the contact person identified in Attachment 1. 1. Voluntary Cancellation - You may avoid the requirements of this Notice by requesting voluntary cancellation of your pr oduct(s) containing the active ingredient(s) that is the subject of this Notice. If you wish to vol untarily cancel your product, you must submit a completed Attachment 2, Generic Data Call-In Response Forms And Instructions Form, indicating your election of th is option. Voluntary cancellation is item number 5 on the Attachment 2, Generic Data Call-In Response Forms And Instructions Form. If you choose this option, this is the only fo rm that you are required to complete. If you choose to voluntarily can cel your product, further sa le and distribution of your product after the effective date of cancellati on must be in accordance with the Existing Stocks provisions of this Notice wh ich are contained in Section IV-C. 2. Use Deletion - You may avoid the requirements of th is Notice by eliminating the uses of your product to which the requirements apply. If you wish to amend your registration to delete uses, you must submit the Attachment 3, Generic Requirements Status and Registrant's Response Forms and Instructions Form, a completed application for amendment, a copy of your proposed ame nded labeling, and all other information required for processing the application. Use deletion is option number 7 on the Attachment 3, Generic Requirements Status and Registrant's Response Forms and Instructions Form. You must also complete an Attachment 2, Generic Data Call-In Response Forms And Instructions Form by signing the certification, item number 8. Application forms for amending registrations may be obtained from the Registration Division (Main Office), (703) 305-5447. If you choose to delete the use( s) subject to this Notice or uses subject to specific data requirements, further sale, distribution, or us e of your product after one year from the due date of your 90 day response, mu st bear an amended label. Note: If all registrants for the subject ac tive ingredient respond to this notice by requesting cancellation or de letion of uses, all toleran ces associated with the registration or deleted uses will be revo ked pursuant to FFDCA section 408(f)(2). 3. Generic Data Exemption - Under section 3(c)(2)(D) of FIFRA, an applicant for registration of a product is exempt from the requirement to submit or cite generic data concerning an active ingredient(s) if the ac tive ingredient(s) in the product is derived exclusively from purchased, registered pesticide products co ntaining the active ingredient(s). EPA has concluded, as an exercise of its discretion, that it normally will not suspend the registration of a product which w ould qualify and continue to qualify for the generic data exemption in section 3( c)(2)(D) of FIFRA. To qualify, all of the following requirements must be met:

a. The active ingredient(s) in your regist ered product must be present solely because of incorporation of another registered product which contains the subject active ingred ient(s) and is purchased from a source not connected with you; and, b. Every registrant who is the ultimate s ource of the active ingr edient(s) in your product subject to this DCI must be in compliance with the requirements of this Notice and must remain in compliance; and5 

### c. You must have provided to EPA an accurate and current "Confidential Statement of Formula" for each of your products to which this Notice applies. To apply for the Generic Data Exemption you must submit a completed Attachment 2, Generic Data Call-In Response Forms And Instructions Form and all supporting documentation. The Generic Data Exemption is item number 6a on the Attachment 2, Generic Data Call-In Response Forms And Instructions Form. If you claim a generic data exemption, you are not required to complete the Attachment 3, Generic Requirements Status and Registrant's Response Forms and Instructions Form. Generic Data Exemption cannot be selected as an op tion for product specific data. If you are granted a Generic Data Exemption, you rely on the efforts of other persons to provide the Agency with the required data. If the registrant(s) who have committed to generate and submit the required data fail to take appropriate steps to meet the requirements or are no longer in compliance wi th this Data Call-In Notice, the Agency will consider that both they and you are not in compliance and will normally initiate proceedings to suspend the registrations of both your and their product(s), unless you commit to submit and do submit the required data within the specified time. In such cases the Agency generally will not grant a time extension for submitting the data. 4. Satisfying the Data Requirements of this Notice - There are various options available to satisfy the data requirements of this Notice. These options are discu ssed in Section III-C of this Notice and comprise options 1 through 6 on the Attachment 3, Generic Requirements Status and Registrant 's Response Forms and Instructions Form and option 6b and 7 on the Attachment 2, Generic Data Call-In Response Forms And Instructions Form. If you choose option 6b or 7, you must submit both forms as well as any other information/data pertaining to the option chosen to address the data requirement. 5. Request for Data Waivers - Data waivers are discussed in Section III-D of this Notice and are covered by options 8 and 9 on the Attachment 3, Generic Requirements Status and Registrant's Response Forms and Instructions Form. If you choose one of these options, you must submit both forms as well as any othe r information/data pertaining to the option chosen to address the data requirement. C. SATISFYING THE DATA REQUIREMENTS OF THIS NOTICE If you acknowledge on the Attachment 2 Generic Data Call-In Response Forms And Instructions Form that you agree to satisfy the data re quirements (i.e. you select option 6b and/or 7), then you must select one of the six options on the Attachment 2, Generic Data Call-In Response Forms And Instructions Form related to data production for each data requirement. Your option selection is to be entered under item number 9, "Registrant Response." The six options related to data produ ction are the first six options discussed under item 9 in the instructions for completing the Attachment 3, Generic Requirements Status and Registrant's Response Forms and Instructions Form. These six options are listed immediately below with information in parentheses to guide registrants to additional instructions provided in this Section. The options are: 1. I will generate and submit data within the specified time frame (Developing Data),6 

### 2. I have entered into an agreement with one or more registrants to develop data jointly (Cost Sharing), 3. I have made offers to cost-share (Offers to Cost Share), 4. I am submitting an existing study that has not been submitted previously to the Agency by anyone (Submitting an Existing Study), 5. I am submitting or citing data to upgrade a study classified by EPA as partially acceptable and upgradeable (Upgrading a Study), 6. I am citing an existing study that EPA has classified as acceptable or an existing study that has been submitted but not revi ewed by the Agency (Citing an Existing Study). Option 1, Developing Data – If you choose to develop the required data, th en it must be in conformance with the Agency’s deadlines and other requirements that are referenced herein and in the attachments. All data generated and submitted must comply with the Good Laboratory Practice (GLP) rule (40 CFR Pa rt 160), be conducted according to the Pesticide Assessment Guidelines (PAG), be in conformance with PR Notice 86-5, and, as applicable, comply with 40 CFR Part 26, “Protection of Human Subjects.” In addition, certain studies require Agency appr oval of test protocol s in advance of study initiation. Those studies for which a protocol must be submitted have been identified in the Attachment 3, Generic Requirements Status and Registrant's Response Forms and Instructions Form and/or footnotes to the form. If you wish to use a protocol which differs from the options discussed in Section II-C of this Notice, you must submit a detailed description of the proposed protocol and your reason for wishing to use it. The Agency may choose to reject a protocol not specified in Section II-C. If the Agency rejects your protocol, you will be notified in writing, however, you should be aware that rejection of a proposed protocol will not be a basis for extending the deadline for submission of data. A progress report must be submitted for each study within 90 days from the date you are required to commit to generate or unde rtake some other mean s to address that study requirement, such as making an offer to cost-share or agreeing to share in the cost of developing that study. A 90-day pr ogress report must be submitted for all studies. This 90-day progress report must in clude the date the study was or will be initiated and, for studies to be started w ithin 12 months of commitment, the name and address of the laboratories or individual s who are or will be conducting the study. In addition, if the time frame for submission of a final report is more than 1 year, interim reports must be submitted at 12 month intervals from the date you are required to commit to generate or otherwise address the requirement for the study. In addition to the other information specified in the preceding paragraph, at a minimum, a brief description of current activity on a nd the status of the study must be included as well as a full description of any probl ems encountered since the last progress report. The time frames in the Generic Requirements Status and Registrant's Response Forms and Instructions Form (Attachment 3) are the ti me frames that the Agency is7 

### allowing for the submission of completed study reports or protocols. The noted deadlines run from the date of the receipt of this Notice by the registrant. If the data are not submitted by the deadline, each registrant is subject to receipt of a Notice of Intent to Suspend the affected registra tion(s) and the affected tolerances or exemptions are subject to revocation. If you cannot submit the data/reports to the Agency in the time required by this Notice and intend to seek additional time to meet the requirement(s), you must submit a request to the Agency which includes: (1 ) a detailed descrip tion of the expected difficulty and (2) a proposed schedule in cluding alternative dates for meeting such requirements on a step-by-step basis. You must explain any technical or laboratory difficulties and provide documentation from the laboratory performing the testing. While EPA is considering your request, the original deadline remains. The Agency will respond to your request in writing. If EPA does not grant your request, then the original deadline remains. Normally, extens ions can be requested only in cases of extraordinary testing problems beyond the e xpectation or control of the registrant. Extensions will not be given in submitting th e 90-day responses. Extensions will not be considered if the request for extension is not made in a timely fashion; in no event shall an extension request be considered if it is submitted at or after the lapse of the subject deadline. Option 2, Agreement to Share in Cost to Develop Data – If you choose to enter into an agreement to share in the cost of producing the required data but will not be submitting the data yourself, you must provide the name of the registrant who will be submitting the da ta. You must also provide EPA with documentary evidence that an agreement has been formed. Such evidence may be your letter offering to join in an agreement and the other registrant's acceptance of your offer, or a written statement by the parties that an ag reement exists. The agreement to produce the data need not specify all of the terms of the final arrangement between the parties or the mechanism to resolve the terms. FIFRA section 3(c)(2)(B) provides that if the parties cannot resolve the terms of the agreement they may resolve their differences through binding arbitration. Option 3, Offer to Share in the Cost of Data Development – If you have made an offer to pay in an atte mpt to enter into an agreement or amend an existing agreement to meet the requirem ents of this Notice and have been unsuccessful, you may request EPA (by sele cting this option) to exercise its discretion not to suspend your registrati on(s), although you do not comply with the data submission requirements of this Notice. EPA has determined that as a general policy, absent other re levant considerations, it will not suspend the registration of a product of a registrant who has in good faith sought and continues to seek to enter into a joint data development/cost shari ng program, but the other registrant(s) developing the data has refused to accept your offer. To qualify for this option, you must submit documentation to the Agency proving that you have made an offer to another registrant (who has an obligation to submit data) to share in the burden of developing that data. You mu st also submit to the Agency a completed EPA Form 8570-32, Certification of Offer to Cost Share in the Development of Data . In addition,8 

### you must demonstrate that the other registrant to whom the offer was made has not accepted your offer to enter into a cost sharing agreement by including a copy of your offer and proof of the other registrant's recei pt of that offer (such as a certified mail receipt). Your offer must, in addition to a nything else, offer to share in the burden of producing the data upon terms to be agreed or failing agreement to be bound by binding arbitration as provided by FIFRA sec tion 3(c)(2)(B)(iii) and must not qualify this offer. The other registrant must also inform EPA of its election of an option to develop and submit the data required by this Notice by submitting a Generic Data Call-In Response Forms And Instructions Form (Attachment 2) and a Generic Requirements Status and Registrant 's Response Forms and Instructions Form (Attachment 3) committing to develop and submit the data required by this Notice. In order for you to avoid suspension unde r this option, you may not withdraw your offer to share in the burdens of developing the data. In addition, the other registrant must fulfill its commitment to develop and submit the data as required by this Notice. If the other registrant fails to develop the data or for some other reason is subject to suspension, your registration as well as that of the other registrant will normally be subject to initiation of suspension proceedings, unless you commit to submit, and do submit the required data in the specified time frame. In such cases, the Agency generally will not grant a time ex tension for submitting the data. Option 4, Submitting an Existing Study – If you choose to submit an existing study in response to this Notice, you must determine that the study satisfies the requi rements imposed by this Notice. You may only submit a study that has not been previously submitted to the Agency or previously cited by anyone. Existing studies are studies which predate issuance of this Notice. Do not use this option if you are submitting data to upgrade a study. (See Option 5). You should be aware that if th e Agency determines that the existing study is not acceptable, the Agency will require you to co mply with this Notice, normally without an extension of the required date of su bmission. The Agency may determine at any time that a study is not valid and needs to be repeated. To meet the requirements of the DCI Noti ce for submitting an existing study, all of the following four criteria must be clearly met :
a. You must certify at the time that the existing study is submitted that the raw data and specimens from the study are available for audit and review and you must identify where they are available. This must be done in accordance with the requirements of the Good Laborat ory Practice (GLP) regulation, 40 CFR Part 160. As stated in 40 CFR Part 160.3(7) " raw data means any laboratory worksheets, records, memoranda, notes, or exact copies thereof, that are the result of original observa tions and activities of a study and are necessary for the reconstruction and evaluation of the re port of that study. In the event that exact transcripts of raw da ta have been prepared (e.g., tapes which have been transcribed verbatim, dated, and verifi ed accurate by signature), the exact copy or exact transcript may be substituted for the original source as raw data. Raw data may include photographs, microfilm or microfiche copies, computer9 

### printouts, magnetic media, including di ctated observations, and recorded data from automated instruments." The term "specimens", according to 40 CFR Part 160.3(7), means "any material derived from a test system for examination or analysis." b. Health and safety studies completed after May 1984 must also contain all GLP-required quality assurance and qual ity control information, pursuant to the requirements of 40 CFR Part 160. Regi strants must also certify at the time of submitting the existing study that such GLP information is available for post-May 1984 studies by including an a ppropriate statement on or attached to the study signed by an authorized official or representative of the registrant.

c. You must certify that each study ha s been conducted according to the Pesticide Assessment Guidelines (PAG ) or meets the purpose of the PAG (both available from NTIS). A study not conducted according to the PAG may be submitted to the Agency for consideration if the registrant believes that the study clearly meets the purpose of the PAG. The registrant is referred to 40 CFR Part 158.70 which states the Agency's policy regarding acceptable protocols. If you wish to submit the study, you must, in addition to certifying that the purposes of the PAG are met by the study, clearly articulate the rationale why you believe the study meet s the purpose of the PAG, including copies of any supporting information or data. You must identify each deviation from the PAG and you need to explain and justify why the study should be accepted notwithstanding such deviation(s). It has been the Agency's experience that studies co mpleted prior to January 1970 rarely satisfied the purpose of the PAG and that necessary raw data are usually not available for such studies. d. If any existing study involves testing subject to 40 CFR Part 26, you must comply with all applicable requirements in EPA’s regulations at 40 CFR Part 26 entitled “Protection of Human Subjects.” If you submit an existing study, you must certify that the study meets all requirements of the criteria outlined above. If EPA has previously reviewed a prot ocol for a study you are submitting, you must identify any action taken by the Agency on the protocol and must i ndicate, as part of your certification, the manner in which all Agency comments, concerns, or issues were addressed in the fi nal protocol and study. If you know of a study pertaining to any re quirement in this Notice which does not meet the criteria outlined above but does contain factual information regarding unreasonable adverse effects, you must notify the Agency of such a study. If such a study is in the Agency's files, you need onl y cite it along with th e notification. If not in the Agency's files, you must submit a summary and copies as per PR Notice 86-5. Option 5, Upgrading a Study – If a study has been classified as partially acceptable and upgradeable, you may submit data to upgrade that study. The Agency will review the data submitted and determine if the requirement is satisfied. If the Agen cy decides the requirement is not satisfied,10 

### you may still be required to submit new da ta normally without any time extension. Deficient, but upgradeable studies will nor mally be classified as supplemental. However, it is important to note that not all studies classified as supplemental are upgradeable. If you have questi ons regarding the classificat ion of a study or whether a study may be upgraded, call or write the cont act person listed in Attachment 1. If you submit data to upgrade an existing study, you must satisfy or supply information to correct all deficiencies in the study iden tified by EPA. You must provide a clearly articulated rationale of how the deficiencies have been remedied or corrected and why the study should be rated as acceptable to EP A. Your submission must also specify the MRID number(s) of the study which you are attempting to upgrade and be in conformance with PR Notice 86-5. Do not submit additional data for the purpose of upgrading a study classified as unacceptable and determined by the Agency as not capable of being upgraded. This option should also be used to cite da ta that has been previously submitted to upgrade a study, but has not yet been reviewed by the Agency. You must provide the MRID number of the data submission as well as the MRID number of the study being upgraded. The criteria for submitting an existing study, as specified in Option 4 above, apply to all data submissions intended to upgrade studies. Additionally your submission of data intended to upgrade studies must be accompanied by a certification that you comply with each of those criteria as well as a certification regarding protocol compliance with Agency requirements. Option 6, Citing Existing Studies – If you choose to cite a study that has been previously submitted to EPA, that study must have been previously classified by EPA as acceptable or it must be a study which has not yet been reviewed by the Agency. Acceptable toxicology studies generally will have been classified as "core-guideline" or "core minimum." For ecological effects studies, the classification generally would be a rating of "core." For all other disciplines the classification w ould be "acceptable." With respect to any studies for which you wish to select this option you must provide the MRID number of the study you are citing a nd, if the study has been reviewed by the Agency, you must provide the Agency's classification of the study. If you are citing a study of which you are not the original data submitter, you must submit a completed copy of Certification wi th Respect to Citations of Data (in PR Notice 98-5) EPA Form 8570-34 . D. REQUESTS FOR DATA WAIVERS There are two types of data waiver responses to this Notice. The first is a request for a low volume/minor use waiver and the second is a wa iver request based on yo ur belief that the data requirement(s) are inapplicable and do not apply to your product. 1. Low Volume/Minor Use Waiver (Option 8 on the Attachment 3, Generic Requirements Status and Registrant's Response Forms and Instructions Form) Section 3(c)(2)(A) of FIFRA requires EPA to consid er the appropriateness of re quiring data for low volume, minor use pesticides. In implementing this provision EPA cons iders as low volume11 

### pesticides only those active ingredient(s) whose total production vol ume for all pesticide registrants is small. In determining whether to grant a low volume, minor use waiver the Agency will consider the extent, pattern a nd volume of use, the economic incentive to conduct the testing, the importance of the pesticide, and the exposure and risk from use of the pesticide. If an active ingredient(s) is used for both high volume and low volume uses, a low volume exemption will not be approv ed. If all uses of an active ingredient(s) are low volume and the combined volumes for a ll uses are also low, then an exemption may be granted, depending on review of other information outlined below. An exemption will not be granted if any registrant of th e active ingredient(s) elects to conduct the testing. Any registrant receiving a low volume minor use waiver must remain within the sales figures in their forecast supporting the wa iver request in order to remain qualified for such waiver. If granted a waiver, a regi strant will be required, as a condition of the waiver, to submit annual sales reports. The Agency will respond to requests for waivers in writing. To apply for a low volume, minor use waiver, you must submit the following information, as applicable to your product(s) , as part of your 90- day response to this Notice:

a. Total company sales (pounds and dolla rs) of all registered product(s) containing the active ingredient(s). If a pplicable to the active ingredient(s), include foreign sales for those products th at are not registered in this country but are applied to sugar (cane or beet), coffee, bananas, cocoa, and other such crops. Present the above information by year for each of the past five years. b. Provide an estimate of the sales (pounds and dollars) of the active ingredient(s) for each major use site. Present the above information by year for each of the past five years.

c. Total direct production cost of product( s) containing the active ingredient(s) by year for the past five years. Incl ude information on raw material cost, direct labor cost, adver tising, sales and marketing, and any other significant costs listed separately. d. Total indirect production cost (e.g. plant overhead, amortized plant and equipment) charged to product(s) cont aining the active ingr edient(s) by year for the past five years. Exclude all n on-recurring costs that were directly related to the active ingredient(s), such as costs of initial registration and any data development.

e. A list of each data requirement for whic h you seek a waiver. Indicate the type of waiver sought and the estimated cost to you (listed separately for each data requirement and associated test) of c onducting the testing ne eded to fulfill each of these data requirements. f. A list of each data requirement for wh ich you are not seeking any waiver and the estimated cost to you (listed separately for each data requirement and associated test) of conduc ting the testing needed to fulfill each of these data requirements.12 

### g. For each of the next ten years, a year-by-year forecast of company sales (pounds and dollars) of the active ingred ient(s), direct production costs of product(s) containing the active ingredie nt(s) (following the parameters in item c above), indirect production costs of product(s) containing the active ingredient(s) (following the parameters in item d above), and costs of data development pertaining to the active ingredient(s). h. A description of the importance and unique benefits of the active ingredient(s) to users. Discuss the use patterns and the effectiveness of the active ingredient(s) relative to registered alternative chemicals and non-chemical control strategies. Focus on benefits unique to the active ingredient(s), providing information that is as quantitative as po ssible. If you do not have quantitative data upon which to base your estimates, then present the reasoning used to derive your estimates. To assist the Agency in determining the degree of importance of the active i ngredient(s) in terms of its benefits, you should provide information on any of the following factors, as applicable to your product(s): (a) documentation of the usefulness of the active ingredient(s) in Integrated Pest Management, (b) description of the beneficial impact s on the environment of use of the active ingredient(s), as opposed to its registered alternatives, (c) information on the breakdown of the active ingredient(s) after use and on its persistence in the environment, and (d) description of its usefulne ss against a pest(s) of public health significance. Failure to submit sufficient information for the Agency to make a determination regarding a request for a low volume minor use waiver will result in denial of the request for a waiver. Low volume minor use waivers ma y not be available for data required for continuation of tolerances or exemptions. 2. Request for Waiver of Data (Option 9 on the Attachment 3, Generic Requirements Status and Registrant's Response Forms and Instructions Form). This option may be used if you believe that a particular data requirement should not apply because the corresponding use is no longer registered and no to lerance or tolerance exempti on exists or the requirement is inappropriate. You must submit a rati onale explaining why you believe the data requirements should not apply. You must al so submit the curren t label(s) of your product(s) and, if a current c opy of your Confidential Statemen t of Formula is not already on file you must submit a current copy. You will be informed of the Ag ency's decision in writing. If the Agency determines that the data requirements of this Notice do not apply to your product(s), you will not be required to supply the data pursuant to FIFRA s ection 3(c)(2)(B) or se ction 4(f)(1)(A). If EPA determines that the data are required for your product(s), you must choose a method of meeting the requirements of this Notice w ithin the time frame provided by this Notice. Within 30 days of your receipt of the Ag ency's written decision, you must submit a revised Attachment 3, Generic Requirements Status and Registrant's Response Forms and Instructions Form indicating the option chosen.13 

### SECTION IV. CONSEQUENCES OF FA ILURE TO COMPLY WITH THIS NOTICE A. NOTICE OF INTENT TO SUSPEND RE GISTRATION/ORDER REVOKING OR MODIFYING TOLERANCE OR EXEMPTION The Agency may issue a Notice of Intent to Su spend products subject to this Notice or an order revoking or modifying associated tolerances or tolerance exemptions due to failure by a registrant to comply with the requirements of this Data Call-In Notice, pursuant to FIFRA section 3(c)(2)(B) or FFDCA section 408(f). Even ts which may be the basis for issuance of a Notice of Intent to Suspend or of an order re voking or modifying associated tolerances or exemptions include, but are not limited to, the following: 1. Failure to respond as required by this Noti ce within 90 days of your receipt of this Notice. 2. Failure to submit on the required schedule an ac ceptable proposed or final protocol when such is required to be submitte d to the Agency for review. 3. Failure to submit on the required schedule an adequate progre ss report on a study as required by this Notice. 4. Failure to submit on the required schedule ac ceptable data as required by this Notice. 5. Failure to take a required action or submit ad equate information pertaining to any option chosen to address the data requirements (e.g., any required action or information pertaining to submission or ci tation of existing studies or offers, arrangements, or arbitration on the sharing of co sts or the formation of Task Forces, failure to comply with the terms of an agreement or arbitration con cerning joint data development or failure to comply with any terms of a data waiver). 6. Failure to submit supportable cert ifications as to the conditi ons of submitted studies, as required by Section III-C of this Notice. 7. Withdrawal of an offer to share in the cost of devel oping required data. 8. Failure of the registrant to whom you have tendered an offer to share in the cost of developing data and provided proof of the registra nt's receipt of such offer, or failure of a registrant on whom you rely for a generic data exemption either to:

a. Inform EPA of intent to develop and submit the data required by this Notice on an Attachment 2, Generic Data Call-In Response Forms And Instructions Form and an Attachment 3, Generic Requirements St atus and Registrant's Response Forms and Instructions Form; or, b. Fulfill the commitment to develop and submit the data as required by this Notice; or,

c. Otherwise take appropriate steps to m eet the requirements stated in this Notice, unless you commit to submit and do submit the required data in the specified time frame. 9. Failure to take any required or appropri ate steps, not mentioned above, at any time following the issuance of this Notice.14 

### B. BASIS FOR DETERMINATION THAT SU BMITTED STUDY IS UNACCEPTABLE The Agency may determine that a study (even if submitted within the required time) is unacceptable and constitutes a basis for issuance of a Notice of Intent to Suspend or an order revoking or modifying a tolerance or tolera nce exemption. The grounds for suspension include, but are not limited to, failure to meet any of the following: 1. EPA requirements specified in the Data Call -In Notice or other documents incorporated by reference (including, as a pplicable, EPA Pesticide Assessment Guidelines, Data Reporting Guidelines, and GeneTox Health Effects Test Guidelines) regarding the design, conduct, and reporting of required st udies. Such requirements include, but are not limited to, those relating to test material, test procedures, selection of species, number of animals, sex and distribution of animals, dose an d effect levels to be tested or attained, duration of test, and, as appli cable, Good Laboratory Practices. 2. EPA requirements regarding the submission of protocols, including th e incorporation of any changes required by the Agency following review. 3. EPA requirements regarding the reporting of data, including the manner of reporting, the completeness of results, and the adequacy of any required supporting (or raw) data, including, but not limited to, require-ments refe renced or included in this Notice and that set forth in PR 86-5. All studies must be s ubmitted in the form of a final report; a preliminary report will not be considered to fulfill the submission requirement. 4. Requirements, as applicable, set forth in 40 CFR Part 26 entitled “Protection of Human Subjects.” C. EXISTING STOCKS OF SUSPENDED OR CANCELED PRODUCTS EPA has statutory authority to permit continued sale, distribution and use of existing stocks of a pesticide product which has been suspended or canceled if doing so would be consistent with the purposes of FIFRA. The Agency has determined that such dispos ition by registrants of existing stocks for a suspended registration when a FIFRA section 3( c)(2)(B) data request is outstanding would generally not be consistent with the Act's purposes. Accord ingly, the Agency anticipates granting registrants permission to sell, distri bute, or use existing stocks of suspended product(s) only in exceptional circumstances. If you believe such di sposition of existing stocks of your product(s) which may be suspe nded for failure to comply with this Notice should be permitted, you have the burden of clea rly demonstrating to EPA that granting such permission would be consistent with the Act. Y ou must also explain wh y an "existing stocks" provision is necessary, including a statement of the quantity of existing stocks and your estimate of the time required for their sale, distribution, and use. Unless you meet this burden, the Agency will not consider any request pertaining to the continued sale, distribution, or use of your exis ting stocks after suspension. If you request a voluntary cancellation of your product(s) as a response to this Notice and your product is in full compliance with all Agency requirements, you will have, under most circumstances, one year from the date your 90 day response to this Notice is due, to sell, distribute, or use existing stocks. Normally, the Agency will allow persons other than the registrant such as independent distributors, retailers and end us ers to sell, distribute or use such existing stocks until the stocks are exhaus ted. Any sale, distribution or use of stocks of

### voluntarily canceled products containing an active ingredient(s) for which the Agency has particular risk concerns will be detennined on case-by-case basis. Requests for voluntary cancellation received after the 90 day response period required by this Notice will not result in the Agency granting any additional time to**sell~ distribute~**  

### or use existing stocks beyond a year from the date the 90 day response was due unless you demonstrate to the Agency that you are in full compliance with all Agency requirements, including the requirements of this Notice. For**example~** 

### if you decide to voluntarily cancel your registration six months before a 3 year study is scheduled to be submitted, all progress reports and other information necessary to 

### establish that you have been conducting the study in an acceptable and good faith marmer must have been submitted to the Agency, before EPA will consider granting an existing stocks provision. 

### SECTIONV. REGISTRANTS' OBLIGATION TO REPORT POSSIBLE UNREASONABLE ADVERSE EFFECTS Registrants are reminded that FIFRA section 6(a)(2) states that if at any time after a pesticide is registered a registrant has additional factual information regarding unreasonable adverse effects on the environment by the**pesticide~** 

### the registrant shall submit the information to the Agency. Registrants must notify the Agency of any factual information they have, from whatever source, including but not limited to interim or preliminary results of**studies~** 

### regarding unreasonable adverse effects on man or the environment. This requirement continues as long as the products are registered by the Agency. 

### SECTION VI. INQUIRIES AND RESPONSES TO THIS NOTICE If you have any questions regarding the requirements and procedures established by this Notice, call the contact person listed in Attachment 1, the 

### Data Call-In Chemical Status Sheet. All responses to this Notice (other than voluntary cancellation requests and generic data exemption claims) must include a completed Attachment**2~** 

### Generic Data Call-In Response Forms And Instructions Form and a completed Attachment**3~** 

### Generic Requirements Status and Registrant's Response Forms and Instructions Form and any other documents required by this Notice, and should be submitted to the contact person identified in Attachment 1. If the voluntary cancellation or generic data exemption option is chosen, only the Attachment 2, 

### Generic Data Call-In Response Forms And Instructions Form need be submitted. Sincerely,

# ~~ci~ Susan Lewis, Acting Director Antimicrobials Division Office of Pesticide Programs U.S. Environmental Protection Agency

1 5EPA Antimicrobials Division DCI Attachments 

# Attachment 1. Data Call

- In Data Chemical Status SheetEPA Antimicrobials Division DCI Attachments DATA CALL

- IN CHEMICAL STATUS SHEET Please submit all responses to the GDCI using the information below. To expedite processing, please include the GDCI identification number (e.g., GDCI-123456-789) in the Subject line of all DCI

- related correspondence. By US mail : Document Processing Desk (DCI/AD) By express or courier service: Document Processing Desk (DCI/AD) Attn: Reevaluation Team Leader, PM 36 Attn: Reevaluation Team Leader, PM 36 US EPA (7510P) US EPA (7510P) 1200 Pennsylvania Ave. N.W. One Potomac Yard (South Building) Washington, DC 20460 2777 S. Crystal Dr. Arlington, VA 22202 If you have chemical

- specific questions or need assistance responding to the GDCI, please contact the chemical review manager (CRM) managing the DCI : Elizabeth Watkins , watkins.elizabeth @epa.gov , 703-347-0 241

.EPA Antimicrobials Division DCI Attachments 

# Attachment 2
. Generic Data Call

- In Response Form and InstructionsInitial to indicate certification as to information on this page (full text of certification is on page one). Date INSTRUCTIONS: Please type or print in ink. Please read carefully the attached instructions and supply the information requested on this form. Use additional sheet(s) if necessary.

2. Case # and Name 3. Date and Type of DCI and Number

4. EPA Product Registration 5. I wish to cancel this product registration voluntarily 6. Generic Data 7. Product Specific Data
6a. I am claiming a Generic Data Exemption because I obtain the active ingredient from the source EPA registration number listed below. 6b. I agree to satisfy Generic Data Requirements as indicated on the attached form entitled "Requirements Status and Registrant's Response." 7a. My product is an MUP and I agree to satisfy the MUP requirement on the attached form entitled "Requirements Status and Registrant's Response." 7b. My product is an EUP and I agree to satisfy the EUP requirement on the attached form entitled "Requirements Status and Registrant's Response." OMB Approval 2070-0174

1. Company Name and Address 2045 - Sodium 2-benzyl-4-chlorophenate Chemical # and Name: 062203 Sodium 2-benzyl-4-chlorophenate 27-Nov-2013 GENERIC ID # GDCI-062203-1356 United States Environmental Protection Agency

Washington, D.C. 20460 DATA CALL-IN RESPONSE 1 Page of 1

8. Certification: I certify that the statements made on this form and all attachments are true, accurate, and complete. I acknowledge that any knowingly false or misleading statement may be punishable by fine, imprisonment or both under applicable law. Signature and Title of Company's Authorized Representative ______________________________________________________ 10. Name of Company N/A
N/A N/A
N/A

9. Date

11. Phone NumberEPA Antimicrobials Division DCI Attachments INSTRUCTIONS: DATA CALL

- IN RESPONSE FORM These instructions apply to the form titled “Data Call

- In Response” and are to be used to respond to generic Data Call

- Ins issued as part of EPA's Registration Review Program unde r the Federal Insecticide, Fungicide, and Rodenticide Act. Please read these instructions carefully before filling out the forms. Items 1 through 4 have been preprinted on the form. Items 5 through 7 must be completed by the registrant as appropriate. It ems 8 through 11 must be completed by the registrant before submitting a response to the Agency. The public reporting burden for this collection of information is estimated to average 15 minutes per response, including time for reviewing instructions, searching existing data sources, gathering and maintaining the data needed, and completing and reviewing the collection of information. Send comments regarding the burden estimate or any other aspect of this collection of information, including suggestions fo r reducing this burden, to Chief, Information Policy Branch, Mail Code 2136, U.S. Environmental Protection Agency, 1200 Pennsylvania Ave. N.W., Washington, D.C. 20460; and to the Office of Management and Budget, Paperwork Reduction Project 2070 -0107, Washington, D.C. 20503.
Item # DATA CALL

- IN RESPONSE Information Item 1. This item identifies your company name, number and address.
Item 2. This item identifies the case number, case name, EPA chemical number and chemical name. Item 3. This item ident ifies the type of Data Call

- In. The date of issuance is date stamped. Item 4. This item identifies the EPA product registrations relevant to the data all

- in. Please note that you are also responsible for informing the Agency of your response regarding an y product that you believe may be covered by this Data Call-In but that is not listed by the Agency in Item 4. You must bring any such apparent omission to the Agency's attention within the period required for submission of this response form. Item 5. Ch eck this item for each product registration you wish to cancel voluntarily. If a registration number is listed for a product for which you previously requested voluntary cancellation, indicate in Item 5 the date of that request. Since this Data Call -in requires both generic and product specific data, you must complete item 5 on both Data Call-In response form. You do not need to complete any item on the Generic Requirements Status and Registrant's Response Forms and Instructions Form.EPA Antimicrobials Division DCI Attachments Item # DATA CALL

- IN RESPONSE Information Item 6a. Check this Item if the Data Call

- In is for generic data as indicated in Item 3 and you are eligible for a Generic Data Exemption for the chemical listed in item 2 and used in the subject product. By electing this exemption, you agree t6 the terms and conditions of a Generic Data Exemption as explained in the Data Call-In Notice. If you are eligible for or claim a Generic Data Exemption, enter the EPA registration Number of each registered source of that active ingredient that you use in your product. Typically, if yo u purchase an EPA-registered product from one or more other producers (who, with respect to the incorporated product, are in compliance with this and any other outstanding Data Call-In Notice), and incorporate that product into all your products, you may c omplete this item for all products listed on this form. If, however, you produce the active ingredient yourself, or Use any unregistered product (regardless of the fact that some of your sources are registered), you may not claim a Generic Data Exemption and you may not select this item

Item 6b. Check this Item if the Data Call

- In is for generic data as indicated in Item 3 and if you are agreeing to satisfy the generic data requirements of this Data Call -In. Attach the "Generic Requirements Status and Registrant's Response Forms and Instructions" Form that indicates how you will satisfy those requirements. Note: You may provide additional information that does not fit on this form in a signed letter that accompanies your response. For example, you may w ish to report that your product has already been transferred to another company or that you have already voluntarily cancelled this product. For these cases, please supply all relevant details so that EPA can ensure that its records are correct. Item 7a. Not Applicable Item 7b. Not Applicable Item 8. This certification statement must be signed by an authorized representative of your company and the person signing must include his/her title. Additional pages used in your response must be initialed and dated in the space provided for the certification. Item s 9, 10, 11. Provide date of signature, name of company, and telephone number.EPA Antimicrobials Division DCI Attachments 

# Attachment 3. Generic Requirements Status and Registrant's Response Form and Instructions13. Phone Number 10. Certification: I certify that the statements made on this form and all attachments are true, accurate, and complete. I acknowledge that any knowingly false or misleading statement may be punishable by fine, imprisonment or both under applicable law.

12. Name of Company 11. Date OMB Approval 2070-0174 United States Environmental Protection Agency

Washington, D.C. 20460 REQUIREMENTS STATUS AND REGISTRANT'S RESPONSE INSTRUCTIONS: Please type or print in ink. Please read carefully the attached instructions and supply the information requested on this form. Use additional sheet(s) if necessary.

4. Guideline Requirement Number 5. Study Title Progress Reports

2 3 1 6. Use

Pattern 7. Test Substance 8. Time Frame (Months) 9. Registrant

Response P R O T O C O L 1. Company Name and Address 2. Case # and Name 3. Date and Type of DCI and Number

Signature and Title of Company's Authorized Representative _________________________________________________________________ 835.1110
835.2120

835.2240

835.3110
835.3220
835.3240

835.3280

850.1010 Activated sludge sorption isotherm

Hydrolysis of parent and degradates as a function of pH at 25 C Direct photolysis rate of parent and degradates in water Ready biodegradability Porous pot test Simulation Test-Aerobic Sewage Treatment-Activated Sludge Simulation Tests to Assess the Biodegradability of Chemicals Aquatic invertebrate acute toxicity, test, freshwater daphnids 2045 - Sodium 2-benzyl-4-chlorophenate Chemical # and Name: 062203 Sodium 2-benzyl-4-chlorophenate 27-Nov-2013 GENERIC ID # GDCI-062203-1356

O,K,M,Q,N,S,L,T,EE,R,U O,K,M,Q,N,S,L,T,EE,R,U
O,K,M,Q,N,S,L,T,EE,R,U
O,K,M,Q,N,S,L,T,EE,R,U O,K,M,Q,N,S,L,T,EE,R,U O,K,M,Q,N,S,L,T,EE,R,U
O,K,M,Q,N,S,L,T,EE,R,U
O,K,M,Q,N,S,L,T,EE,R,U EP; PAI; TGAI PAIRA; TGAI

TGAI
EP; PAI; TGAI EP; PAI; TGAI EP; PAI; TGAI
EP; PAI; TGAI

TGAI 12
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N 3OMB Approval 2070-0174 United States Environmental Protection Agency

Washington, D.C. 20460 REQUIREMENTS STATUS AND REGISTRANT'S RESPONSE INSTRUCTIONS: Please type or print in ink. Please read carefully the attached instructions and supply the information requested on this form. Use additional sheet(s) if necessary.

4. Guideline Requirement Number 5. Study Title Progress Reports

2 3 1 6. Use

Pattern 7. Test Substance 8. Time Frame (Months) 9. Registrant

Response P R O T O C O L 1. Company Name and Address 2. Case # and Name 3. Date and Type of DCI and Number

850.1025
850.1035
850.1055
850.1300
850.1400
850.1710
850.1730
850.3300
850.4500
850.4550 Oyster acute toxicity test (shell deposition)

Mysid acute toxicity test Bivalve acute toxicity test (embryo larval) Daphnid chronic toxicity test Fish early-life stage toxicity test Oyster BCF
Fish BCF Modified Activated Sludge, Respiration Inhibition Test Algal Toxicity Cyanobacteria (Anabaena flos-aquae) Toxicity 2045 - Sodium 2-benzyl-4-chlorophenate Chemical # and Name: 062203 Sodium 2-benzyl-4-chlorophenate 27-Nov-2013 GENERIC ID # GDCI-062203-1356

O,K,M,Q,N,S,L,T,EE,R,U O,K,M,Q,N,S,L,T,EE,R,U O,K,M,Q,N,S,L,T,EE,R,U O,K,M,Q,N,S,L,T,EE,R,U O,K,M,Q,N,S,L,T,EE,R,U O,K,M,Q,N,S,L,T,EE,R,U O,K,M,Q,N,S,L,T,EE,R,U O,K,M,Q,N,S,L,T,EE,R,U O,K,M,Q,N,S,L,T,EE,R,U O,K,M,Q,N,S,L,T,EE,R,U TEP; TGAI
TGAI TEP; TGAI
TGAI
TGAI PAIRA; TGAI PAIRA; TGAI EP; PAI; TGAI TEP; TGAI TEP; TGAI 12
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N 3Date OMB Approval 2070-0174 United States Environmental Protection Agency

Washington, D.C. 20460 REQUIREMENTS STATUS AND REGISTRANT'S RESPONSE INSTRUCTIONS: Please type or print in ink. Please read carefully the attached instructions and supply the information requested on this form. Use additional sheet(s) if necessary.

4. Guideline Requirement Number 5. Study Title Progress Reports

2 3 1 6. Use

Pattern 7. Test Substance 8. Time Frame (Months) 9. Registrant

Response P R O T O C O L 1. Company Name and Address 2. Case # and Name 3. Date and Type of DCI and Number

870.3465
870.3800
870.7800
875.1200
875.1400
875.1700
875.2300
875.2500
875.2800
SS-1220 90-day inhalation toxicity

Reproduction and fertility effects Immunotoxicity Dermal exposure--Indoor Inhalation exposure--indoor
Product Use Information Indoor surface residue dissipation Inhalation exposure Description of human activity Quantitative dermal sensitization study 2045 - Sodium 2-benzyl-4-chlorophenate Chemical # and Name: 062203 Sodium 2-benzyl-4-chlorophenate 27-Nov-2013 GENERIC ID # GDCI-062203-1356

O,K,M,Q,N,S,L,T,EE,R,U O,K,M,Q,N,S,L,T,EE,R,U O,K,M,Q,N,S,L,T,EE,R,U O,K,M,Q,N,S,L,T,EE,R,U O,K,M,Q,N,S,L,T,EE,R,U O,K,M,Q,N,S,L,T,EE,R,U O,K,M,Q,N,S,L,T,EE,R,U O,K,M,Q,N,S,L,T,EE,R,U O,K,M,Q,N,S,L,T,EE,R,U O,K,M,Q,N,S,L,T,EE,R,U TGAI
TGAI
TGAI
TGAI
TGAI
TGAI
TEP
TEP
TEP EP; PAI; TGAI 24
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Y 3United States Environmental Protection Agency Washington, D.C. 20460 FOOTNOTES AND KEY DEFINITIONS FOR GUIDELINE REQUIREMENTS 2045 - Sodium 2-benzyl-4-chlorophenate GDCI-062203-1356

1

2

3

4 Key: Residue of Concern = Residue of Concern; TEP = Typical End Use Product [TEP]; TGAI = Technical Grade Active Ingredient [TGAI]; TGAI/PAIRA = Technical Grade of the Active Ingredient or Pure Active Ingredient, Radio Labelled; TGAI, TEP = Technical Grade of the Active Ingredient or Technical End-Use Product; TGAI/PAI = Technical Grade Active Ingredient, Pure Active Ingredient

The post application inhalation exposure data will be used to assess the residential and/or occupational inhalation risks to estimate reentry exposure to fogging from a thermal fogger product use. This data is needed to conduct an inhalation postapplication assessment. The Agency anticipates needing additional data to quantitatively address skin sensitization for risk assessment purposes during the registration review process. Severe dermal irritation and allergic type reactions in animal tests. In addition, human incidents have been reported following exposure to OBPCP and or its sodium and potassium salts. The fabric use specifically triggers this special dermal sensitization study. A dose response study is needed based on the expected prolonged dermal contact associated with clothes made out of fabrics impregnated with OBPCP. Protocols must be submitted for approval prior to the initiation of the study. Details for developing protocols are available from the Agency. Results for studies conducted for (i) the freshwater green alga, Selenastrum capricornutum, (ii) the freshwater diatom, Navicula pelliculosa, (iii) the marine diatom, Skeletonema costatum, and (iv) the cyanobacteria species Selenastrum capricornutum, Navicula pelliculosa, Skeletonema costatum, and Anabaena flos-aquae must be submitted to satisfy this requirement. For the cooling tower use a Tier II vascular plant study, Lemna sp., is required. If the green algae IC50 is > 1.0 ppm then the data for the other three algal species is waived. Final 850 guidelines for the algal testing were posted in June 2012. The Public Draft OPPTS 850.5400 Algal Toxicity guideline was split into two separate guidelines and renumbered with the cyanobacteria species separated into OCSPP 850.4550 and the other three species under OCSPP 850.4500. Residue data for countertops would be needed to assess dermal and incidental oral exposure and an indirect dietary exposure assessment. Protocols must be submitted for approval prior to the initiation of the study. Details for developing protocols are available from the Agency. Case # and Name: DCI Number: 1 Page: of

Footnotes: The following footnotes are referenced in column two (5. Study Title) of the Requirements Status and Registrant's Response form. These footnotes apply in addition to any test notes included in 40 CFR Part 158 with respect to the particular data requirement. Use Categories Key:
K - Residential

L - Indoor food use

M - Indoor nonfood use

N - Indoor medical use
O - Residential Indoor use
Q - Residential outdoor use R - Agricultural premises and equipment S - Food handling/storage establishments premises and equipment T - Commercial, institutional and industrial premises and equipment U - Residential and public access premises

EE - Indoor use 3United States Environmental Protection Agency Washington, D.C. 20460 FOOTNOTES AND KEY DEFINITIONS FOR GUIDELINE REQUIREMENTS 2045 - Sodium 2-benzyl-4-chlorophenate GDCI-062203-1356

5

6

7

8

9

10

11

12

13 Key: Residue of Concern = Residue of Concern; TEP = Typical End Use Product [TEP]; TGAI = Technical Grade Active Ingredient [TGAI]; TGAI/PAIRA = Technical Grade of the Active Ingredient or Pure Active Ingredient, Radio Labelled; TGAI, TEP = Technical Grade of the Active Ingredient or Technical End-Use Product; TGAI/PAI = Technical Grade Active Ingredient, Pure Active Ingredient

Product use data will be needed to characterize any uncertainties with regard to the application equipment. Product use data will be needed to characterize any uncertainties with regard to post application exposure scenarios. These data will clearly identify the specific equipment used to deliver OBPCP to the use site, which in high exposure scenarios, such a metal working fluids will allow the Agency to refine its risk assessment. Product use data will be needed to characterize any uncertainties with regard to the application equipment. Product use data will be needed to characterize any uncertainties with regard to post application exposure scenarios. Exposure studies are required for following scenarios: fogging, trigger spray, aerosol spray, sponge/wipes, high pressure spray, all other sprays, and mixing/loading. Exposure may occur while using a wet mist fogger for agricultural premises. Exposure may occur while spraying with a trigger pump cleaning spray in a bathroom, kitchen or other areas of the home or office. Exposure may occur while spraying with a aerosol can in a bathroom, kitchen or other areas of the home or office. Exposure may occur while sponging or wiping disinfectant on a hard surface area. Exposure may occur from high pressure sprays in agricultural premises. Exposure may occur from sprays from machinist exposures. Exposure may occur while pouring preservative in a manufacturing setting for metal working fluids, rubber, leather, textiles, and cooling water. Protocols must be submitted for approval prior to the initiation of the study. Details for developing protocols are available from the Agency. Data reporting and calculations are required when handler exposure data are submitted.
Exposure studies are required for following scenarios: fogging, trigger spray, aerosol spray, sponge/wipes, high pressure spray, all other sprays and mixing/loading. Exposure may occur while using a wet mist fogger for agricultural premises.Exposure may occur while spraying with a trigger pump cleaning spray in a bathroom, kitchen or other areas of the home or office. Exposure may occur while spraying with a aerosol can in a bathroom, kitchen or other areas of the home or office. Exposure may occur while sponging or wiping disinfectant on a hard surface area. Exposure may occur from high pressure sprays in agricultural premises. Exposure may occur from sprays from machinist exposures. Exposure may occur while pouring preservative in a manufacturing setting for metal working fluids, rubber, leather, textiles, and cooling water. Protocols must be submitted for approval prior to the initiation of the study. Details for developing protocols are available from the Agency. Data reporting and calculations are required when handler exposure data are submitted.EPA published draft guidance under guideline 850.6800 and has since published final guidance for this study under guideline 850.3300: http://www.regulations.gov/#!documentDetail;D=EPA-HQOPPT-2009-0154-0021. OECD Test Guideline 209 can also be used as guidance for this study, available online at http://www.oecd-ilibrary.org/content/book/9789264070080-en. The results of the Activated Sludge Respiration Inhibition Test (ASRI) will determine which of these four biodegradation tests is/are required. If the ASRI test EC50 is less than or equal to 20 mg/L, then either the (i)Biodegradation in Activated Sludge Study or (ii) Simulation Test - Aerobic Sewage Treatment: A. Activated Sludge Units or (iii) the Porous Pot Test is required. If the ASRI test EC50 is greater than 20 mg/L, then the registrant must conduct either: (i) Ready Biodegradability or (ii) a) Biodegradation in Activated Sludge or b) Simulation Test - Aerobic Sewage Treatment: A. Activated Sludge Units or c) the Porous Pot Test. If the Ready Biodegradability study is conducted and passes, then no further testing is required. If, however, the antimicrobial fails the Ready Biodegradability study, then the a) Biodegradation in Activated Sludge or b) Simulation Test - Aerobic Sewage Treatment: A. Activated Sludge Units, or c) the Porous Pot study is required. EPA has a published final guideline for this study: http://www.regulations.gov/#!documentDetail;D=EPA-HQ-OPPT-2009-0152-0017. The required biodegradation study required is based on results of an Activated Sludge Respiration Inhibition test. EPA has a published final guideline for this study: http://www.regulations.gov/#!documentDetail;D=EPA-HQ-OPPT-2009-0152-0036. The required biodegradation study required is based on results of an Activated Sludge Respiration Inhibition test.

EPA has a published final guideline for this study: http://www.regulations.gov/#!documentDetail;D=EPA-HQ-OPPT-2009-0152-0034. The required biodegradation study is based on results of an Activated Sludge Respiration Inhibition test.

EPA has a published final guideline for this study: http://www.regulations.gov/#!documentDetail;D=EPA-HQ-OPPT-2009-0152-0024. The required biodegradation study required is based on results of an Activated Sludge Respiration Inhibition test. Case # and Name: DCI Number: 2 Page: of 3United States Environmental Protection Agency Washington, D.C. 20460 FOOTNOTES AND KEY DEFINITIONS FOR GUIDELINE REQUIREMENTS 2045 - Sodium 2-benzyl-4-chlorophenate GDCI-062203-1356

14
15
16

17
18 Key: Residue of Concern = Residue of Concern; TEP = Typical End Use Product [TEP]; TGAI = Technical Grade Active Ingredient [TGAI]; TGAI/PAIRA = Technical Grade of the Active Ingredient or Pure Active Ingredient, Radio Labelled; TGAI, TEP = Technical Grade of the Active Ingredient or Technical End-Use Product; TGAI/PAI = Technical Grade Active Ingredient, Pure Active Ingredient

EPA has a published final guideline for this study: http://www.regulations.gov/#!documentDetail;D=EPA-HQ-OPPT-2009-0152-0003 Data from either 850.1025 or 850.1055 are required to satisfy this study. Based upon decreased thymus weights and thymic lymphoid depletion which were noticed in the 90-day oral rat study conducted with OBPCP (MRID 40376301, 41248202, 41462401), EPA has concerns about the potential immunotoxicity of this chemical. Reported incidents of autoimmune thrombocytopenia, nose/mouth bleeding, aplastic anemia and leukemia in humans following exposure to OBPCP also raises concern for immunotoxicity. As a result of significant increase in post-implantation loss in the high dose group, a human incident, and chronic dietary exposure a reproductive study is needed. As a result of inhalation exposures to high pressure sprays, fogging, trigger sprays and aerosols; the Agency anticipates that a 90-day inhalation study will be needed to develop short- and intermediate- toxicity inhalation endpoints. Case # and Name: DCI Number: 3 Page: of 3EPA Antimicrobials Division DCI Attachments INSTRUCTIONS : REQUIREMENTS STATUS AND REGISTRANT’S RESPONSE FORM 

### These instructions apply to the form titled “Requirements Status and Registrant’s Response” and are to be used to respond to generic Data Call-Ins issued as part of EPA's Registration Review program under the Federal Insecticide, Fungicide, and Rodenticide Act. Items 1 through 8 have been preprinted on the form. Item 9 must be completed by the registrant as appropriate. Items 10 through 13 must be completed by the registrant before submitting a response to the Agency. You may provide additional information that does not fit on th e fo rm in a signed letter that accompanies this response. For example, you may wish to report that your product has al read y been transferred to another company or that the product has already been voluntarily cancelled. The public reporting burden for this collection

- of information is estimated to average 30 minutes per response, including time for reviewing instructions, searching existing data sources, gathering and maintaining the data needed, and completing and reviewing the collection of information. Send comments regarding the burden estimate or any other aspect of this collection of information, including suggestions for reducing this burden, to Chief, Information Policy Branch, Mail Code 2136, U.S. Environmental Protection Agency,1200 Pennsylvania Ave. N.W., Washington, D.C. 20460; and to the Office of Management and Budget, Paperwork Reduction Project 2070-0107, Washington, D.C. 20503.
Item # DATA CALL

- IN RESPONSE Information 1 This item completed by the Agency provides identifying information for the company subject to the Data Call

- In

. 2 This item completed by the Agency identifies the case number, case name, EPA chemical number and chemical name. 3 This item completed by the Agency identifies the type of Data Call

- In. The date of issuance is date stamped. Note the unique identification number (ID#) assigned by the Agency. This ID number must be used in the t ransmittal document for any data submissions in response to this Data Call

- In Notice. 4 This item completed by the Agency identifies the guideline reference number of studies required. These guidelines, in addition to the requirements specified in the Dat a Call

- In Notice, govern the conduct of the required studies. Note: Required studies for which no guideline exists (i.e., “special studies), registrants are generally required to submit a protocol for EPA review prior to initiating the study. 5 This ite m completed by the Agency identifies the study title associated with the guideline reference number and whether protocols and 1,2, or 3- year progress reports are required to be submitted in connection with the study. As noted in Section III of the Data Cal l-In Notice, 90-day progress reports are required for all studies. If an asterisk appears in Item 5, EPA has attached information relevant to this guideline reference number to the Generic Requirements Status and Registrant's Response Forms and Instructio ns Form.EPA Antimicrobials Division DCI Attachments Item # DATA CALL

- IN RESPONSE Information 6 This item completed by the Agency identifies the code associated with the use pattern of the pesticide. A brief description of each code follows: A Terrestrial food B Terrestrial feed C Terrestrial non -food D Aquatic food E Aquatic non-food outdoor F Aquatic non- food industrial G Aquatic non-food residential H Greenhouse food I Greenhouse non-food crop J Forestry K Residential L Indoor food M Indoor non-food N Indoor medical O Indoor residential 7 This item completed by the Agency identifies th e code assigned to the substance that must be used for testing. A brief description of each code follows: MP : Manufacturing-Use Product MPITGAI : Manufacturing- Use Product and Technical Grade ActiveIngredient PAI : Pure Active Ingredient PAI/M : Pure Active I ngredient and Metabolites PAI/PAIRA : Pure Active Ingredient or Pure Active Ingredient Radiolabelled P AIRA : Pure Active Ingredient Radiolabelled PAIRA/M : Pure Active Ingredient Radiolabelled and Metabolites P AIRA/PM : Pure Active Ingredient Radiolabelled and Plant Metabolites TGAI : Technical Grade Active Ingredient TGAI/PAI : Technical Grade Active Ingredient or Pure Active Ingredient TGAI/PAIRA : Technical Grade Active Ingredient or Pure Active Ingredient Radiolabelled TGAI/TEP : Technical Grade Active Ingred ient or Typical End

- Use Product MET : Metabolites IMP: Impurities DEGR: Degradates 8 This item completed by the Agency identifies the time frame allowed for submission of the study or protocol identified in item 5. The time frame runs from the date of you r receipt of the Data Call

- In notice.EPA Antimicrobials Division DCI Attachments Item # DATA CALL

- IN RESPONSE Information 9 Enter the appropriate Response Code or Codes to show how you intend to comply with each data requirement. Brief descriptions of each code follow. The Data Call

- lit Notice contains a fuller description of each of the se options. 1. Developing Data: I will conduct a new study and submit it within the time frames

' specified in item 8 above. By indicating that I have chosen this option, I certify that I will comply with all the requirements pertaining to the conditions for submittal of this study as outlined in the Data Call

- In Notice and that I will provide the protocols and progress reports required in item 5 above. 2. Agreement to Cost Share: I have entered into an agreement with one or more registrants to develop data jointl y. By indicating that I have chosen this option, I certify that I will comply with all the requirements pertaining to sharing in the cost of developing data as outlined in the Data Call

- In Notice. 3. Offer to Cost Share: I have made an offer to enter into an agreement with one or more registrants to develop data jointly. I am also submitting a completed "Certification of offer to Cost Share in the Development of Data" form. I am submitting evidence that I have made an offer to another registrant (who has an ob ligation to submit data) to share in the cost of that data. I am including a copy of my offer and proof of the other registrant's receipt of that offer. I am identifying the party which is committing to submit or provide the required data; if the required study is not submitted on time, my product may be subject to suspension. I understand that other terms under Option 3 in the Data Call

- In Notice apply as well. 4. Submitting Existing Data: I will submit an existing study by the specified due date that has nev er before been submitted to EPA. By indicating that I have chosen this option, I certify that this study meets all the requirements pertaining to the conditions for submittal of existing data outlined in the Data Call

- In Notice and I have attached the need ed supporting information along with this response. 5. Upgrading a Study: I will submit by the specified due date, or will cite data to

- upgrade a study that ' EPA has classified as partially acceptable and potentially upgradeable. By indicating that I have ch osen this option, I certify that I have met all the requirements pertaining to the conditions for submitting or citing existing data to upgrade a study described in the Data Call

- In Notice. I am indicating on attached correspondence the Master Record Identification Number (MRID) that EPA has assigned to the data that I am ' citing as well as the MRID of the study I am attempting to upgrade. 6. Citing a Study: I am citing an existing study that has been previously classified by EPA as acceptable, core, core minimum, or a study that has not yet been reviewed by the Agency

. If reviewed, I am providing the Agency's classification of the study. 7. Deleting Uses: I am attaching an application to amend my product’s (or products’) labeling to delet e the uses for which the data are required

. 8. Low Volume/Minor Use Waiver Request: I have read the statements concerning low volume

- minor use data waivers in the Data Call

- In Notice and I request a low

- volume minor use waiver of the data requirement. I am attaching a detailed justif ication to support this waiver request including, among other things, all information required to support the request. I understand that unless the Agency provides a written response waiving the requirement to submit data, the data remain required and are to be submitted according to the timelines specified in the Data Call

- In Notice. 9. Request for Waiver of Data: I have read the statements concerning data waivers other than low volume minor

- use data waivers in the Data Call

- In Notice and I request a waiver of the data requirement. I am attaching a rationale explaining why I believe the data requirements do not apply. I am also submitting a copy of my current labels. (You must also submit a copy of your Confidential Statement of Formula if not already on file with EPA). I understand that unless the Agency provides a written response waiving the requirement to submit data, the data remain required and are to be submitted according to the timelines specified in the Data Call

- In Notice.EPA Antimicrobials Division DCI Attachments 

# Attachment 4. List of All Registrants Sent t his Data Call

- In NoticeUnited States Environmental Protection Agency Washington, D.C. 20460 LIST OF ALL REGISTRANTS SENT THIS DATA CALL-IN NOTICE 2045 - Sodium 2-benzyl-4-chlorophenate Case # and Name: 1 Page: of 1

1769

211
34810
3862 NCH CORP

CENTRAL SOLUTIONS, INC. WEXFORD LABS, INC. ABC COMPOUNDING CO, INC Co. Nr. Company Name Agent For Company

2727 CHEMSEARCH BLVD.
401 FUNSTON ROAD
325 LEFFINGWELL AVE.
P.O. Box 16247 Address City ZIP

IRVING
KANSAS CITY
KIRKWOOD

ATLANTA 75062
66115
63122
303210247 OMB Approval 2070-0174

State

TX
KS
MO
GA DCI Number: GDCI-062203-1356EPA Antimicrobials Division DCI Attachments 

# Attachment 5. Additional Documents and Informat ionConfident/.! Bu•1iHt•• lnform•tion : Doe. Not Cont•ln N•tion•l Security_/nform•tion (E

. 0

. 12065) Form Approved

. OMB No

.**2070 0d** **~l,** "" Print Forll'l 1 1
· 31

- 98 

# &EPA United States A

. 

## 0 Basic Formu l ation B

. Environmental Protection Agency 

## D 

# D D See Instructions on Back Washington, DC 20460 Alternative Formulation Page of Office of Pesticide Programs (7505CI

- Confidential Statement of Formula
1

. Name and Address of Applicant/Registrant (lncluds ZIP Gods} 2

. Nama and Address of Producer (Include ZIP Gods}



### -· 3

. Product Name 4

. Reg i strat i on No ./ F i te Symbo l 5

. EPA Product Mgr!Team No

. 6. Country Where Formulated

7. Pounds/Get or Bulk Density B

. pH 9

. Flesh Point/Flame Extension

10. Components in Formulati o n (List as actually 13

. Each Component in 14

. Cert i fied L i m i

t• introducsd into ths formulation

. Givs commonly f ormulation %by We i g ht 16

. P ur poae EPA USE ONLY accsptad chem i cal namB, trads nsme , and CAS 1 1

. Supp l ier Name & Addre ss 12

. EPA Reg

. No

. b

. 'J(, by a . Upper b

. l owe r in a

. Amount We i gh! limi t limi t For m ulat i on number

. }



### -- ·· ------ -



### - ---··-

- ·

16. Typed Nama of Approving Official 17. Total Weight 100%



### -- 18. Signature of Approving Official 

# I 19. Title 1 20

. Phone No. Pn<lude Areo Codel 1 21

. Data

EPA Form 8670-41Rev. 8-941 .. Wh1te • EPA F1la Copy longmall Pmk

- Apphcant 

## * U.&QPO:**1~20/20414**

### Instructions and Paperwork Act Notice Please Read Carefully Before Completing This Form
Paperwork Reduction Act Notice
The public reporting burden for this collection of information is estimated to average 1.0 hour per response, including familiarization with the form, organizing the necessary information, and completing the form. Send any comments regarding the burden estimate or any other aspect of this collection of information, including suggestions for reducing this burden to: Chief, Information Policy Branch, 2136, U.S. Environmental Protection Agency, 401 M Street, S.W., Washington, D.C. 20460.


### Instructions

The complete chemical composition of each pesticide must be known so it can he evaluated for registration under the Federal insecticide, Fungicide, and Rodenticide Act, as amended

. This form is designed for reporting the ingredients used in the formulation of
a pesticide product. It must be completed and submitted with each application for new registration of a pesticide and application for amended registration if the revision involves a formula change

. Block A: Check the appropriate action for which you are submitting the form

. Block B: Number all pages consecutively. Enter on each page the total number of pages submitted. If more than one page is required, number them "I of2", "2 of2", "3 of3 ", etc.
1. Name and Address of Applicant/Registrant: Enter the name and address of your finn or authorized agent.
2. Name and Address of Producer: Specify the name of the producer and the address of the site where this product will be produced

. 3. Product Name: Specify the complete name of this pesticide product as it will appear on the label. This name must be the same as that which appears on the application form. 4. Rcgistlation Number/File Symbol: Enter the EPA registration number
or file symbol, if known for this product

S. EPA Product Managerffeam Number: Enter the name and team number of the EPA Product Manager assigned to this product, if known. 6. Country Where Formulated: Specify the country where this product is formulated

7. Weight per Gallon/Bulk Density: For a liquid product specify pounds per gallon of formulated product. For a powder or granular product, enter the hulk density of formulated product (as used). Enter weight per unit if the product is produced as a tablet, briquette, or other uniformly shaped product 8

. pH: Enter the pH of aqueous formulations and products which are either dispersible or soluble in water. If not applicable enter "N/ A"

.
9. Flash Point/Flame Extension: Specify the flash point as determined by the regulations for pressurized products and/or products known or suspected to bum. State the results of the flame extension test for pressurized products including positive flashbacks. 10. Components in Fonnulation: List as actually introduced into the formulation. For each component in your formulation, provide the product name, commonly accepted chemical , the trade name, and the Chemical Abstract {CAS) number for each identifiable ingredient present in the product. CAS numbers may be obtained from the Chemical Abstract Service of the American Chemical Society, Columbus, OH. For each original and alternate source of each active ingredient in the product, indicate the percent purity of the manufacturing use product, technical product, or other source of active ingredient. If one or more components will be obtained from more than one source, enter all alternate sources and all alternate EPA Reg

. Nos. in blocks 10, II, and 12 or on a separate attachment. Attention: (Special Instructions for Columns 10, 13, and 14) Any impurities greater than or equal to 0

. 1% (or less than 0.1% if the impurity is toxicologically significant) which are associated with the active ingredient(s) of n technical grade (manufacturing or reformulating use) product or an end
use P.roduct produced by an integrated formulations system should also be listea in column I 0, and the corresponding amount, percent by weight, and upper certified limits in columns 13 and 14

. 11. Supplier Name and Address: Provide the name and address of the supplier of each component in the formulation

. If one or more components will be obtained from more than one source , specify the names addresses of the alternate sources also.

EPA Form 8570-4 (Rev. 8-94) Reverse "U

. S. GOP : 2000-519-239/94558 12. EPA Reg. No.: Specify the EPA registration number , if any, for each active ingredient in the formulation. If an unregistered active ingredient is used, have the suppliers submit the chemical specifications, as well as any data required under 40 CFR Part 158. 13. Each Component in Formulation a
. Amount: Specify the quantity of each component as actually introduced into the formulation. Units (e.g ., pounds, grams, gallons, liters) should be expressed as used in the formulation

. If the quantity is a liquid measure, enter the volume and the specific gravity or the pounds per gallon of the component.

b. Percent by Weight: Specify the weight percentage of each component in your formulation

. Check Your Calculations

. Note that the weight percentage in many cases will not agree with that shown on the label ingredient statement where the weight percentage of the per active ingredient(s) must he declared

. Attention: Producers of Microbial Products: Special instructions for Column l3b

. ) Please state the percent of active ingredient in British International Units (BIUs). International Toxic Units (ITUs). Polyhedral Inclusion Bodies (P!Bs)(viruses}, Colony Forming Units (CFUs)(Fungi}, as appropriate, and include an equivalent statement of active ingredient per milligram, ounce , pound, etc. of product (e.g ., a 50% active Bacillus thuringiensis product may have an equivalency value of 1.59 million Aedis aegypti ITU per pound of product
14. Certified Limits: These limits are to be set based on representative sampling and chemicnl analysis {i

. e ., quality control) of the product.

a
. Upper Limit: Specify the maximum percentage of each active ingredient, intentionally added inert ingredient, and any impuritie s greater than 0.1% to he permitted in the product.
b

. Lower Limit: Specify the minimum percentage of each active ingredient and intentionally added inert ingredient to he permitted in the product
15. Purpose In Fonnulation: Specify the purpose of each ingredient both active and inert. (For example, disinfectant , herbicide, syne rgis t s urfactant, defoamer, sequestrant, etc.) If space is insufficient , abbreviate. 16. Typed Name of Approving Offirial: Complete this item for identification of individual to he contacted if necessary

17. Total Weight: Specify the total weight of the batch (column l3a

. ) 18-21: Complete these items for identification of individual to be contacted if necessary
.United States Environmental Protection Agency Washington, D.C. 20460 CE RT IFICAT ION OF ATT EM PT TO ENTE R IN TO AN AGREEMENT WITH REGISTRANTS FOR DEVELOPMENT OF DATA Form Approved. OM B Nos. 2070-0057; 2070-0107; 2070-0122; 2070-0164
Paperwork Reduction Act Notice: The public reporting burd en fo r this co llection o f inform ation is estim ated to average 15 minutes per response including time for reading the instructions, searching existing data sources, gathering and maintaining the data needed and completing and reviewing the collection of information. Send comm ents regarding the burden estimate or any other aspect of this collection of information, including suggestions for reducing the burden to: Director, Collection Strategies Division (2822T), U.S. Environmental Protection Agency, 1200 Pennsylvania Avenue, N.W ., W ashington, DC 20460. Do not send the form to this address.
Please f ill in blanks below Company Name Company Number

Chemical Name EPA Chemical Number

I Certify that: My company i s willing to develop and submit the data required by EPA under the authority of the Federal Insecticide, Rodenticide and Fungicide Act (FIFRA), i f necessary

. , my company would prefer to enter into an agreement with one or more registrants t o develop jointly or share i n the cost of developing data. My firm has offered i n writing to enter into such an agreement. That offer was irrevocable and included an offer t o be bound by arbitration under section 3(c)(2)(B)(iii) of FIFRA if final agreement on all terms could not be reached otherwise. m ade to the following fir m (s) on the following date(s): However

This offer was Name of Firm(s) Date of Offer

Certification: I certify that I am duly authorized to represent the company name above, and that the statements that I have made on this form and all attachments therein are true, accurate and complete. I acknowledge that any knowingly false or misleading statement may be punishable by fine or imprisonment or both under applicable law. Signature of Company’s Authorized Represe ntative Date

Name and Title (Please Print or Type)

EPA Form 8570-32 (12-2003)Form Approved OMB Nos. 2070-0060; 2070-0057; 2070-0107; 2070-0122; 2070-0164
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

1200 Pennsylvania Avenue, N.W. WASHINGTON, D.C. 20460
Paperwork Reduction Act Notice: The public reporting burden for this collection of information is estimated to average 1.25 hours per response for registration and 0.25 hours per response for reregistration and special review activities, including time for reading the instructions 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, Collection Strategies Division (2822T), U.S. Environmental Protection Agency, 1200 Pennsylvania Avenue, N.W., Washington, DC 20460. Do not send the completed form to this address. Certification with Respect to Citation of Data Applicant's/Registrant's Name, Address, and Telephone Number EPA Registration Number/File Symbol
Active Ingredient(s) and/or representative test compound(s) Date
General Use Pattern(s) (list all those claimed for this product using 40 CFR Part 158) Product Name

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). I am responding to a Data-Call-In Notice, and have included with this form a list of companies sent offers of compensation (the Data Matrix form should be used for this purpose).

SECTION I: METHOD OF DATA SUPPORT (Check one method only) I am using the cite-all method of support, and have included with this form I am using the selective method of support (or cite-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 form must be used). SECTION II: GENERAL OFFER TO PAY [Required if using the cite-all method or when using the cite-all option under the selective method to satisfy one or more data requirements] I hereby offer and agree to pay compensation, to other persons, with regard to the approval of this application, to the extent required by FIFRA.

SECTION III: CERTIFICATION I certify that this application for registration, this form for reregistration, or this Data-Call-In response is supported by all data submitted or cited in the application for registration, the form for reregistration, or the Data-Call-In response. In addition, if the cite-all option or cite-all option under the selective method is indicated in Section I, this application is supported by all data in the Agency's files that (1) concern the properties or effects of this product or an identical or substantially similar product, or one or more of the ingredients in this product; and (2) is a type of data that would be required to be submitted under the data requirements in effect on the date of approval of this application if the application sought the initial registration of a product of identical or similar composition and uses . I certify that for each exclusive use study cited in support of this registration or reregistration, that I am the original data submitter or that I have obtained the written permission of the original data submitter to cite that study.

I certify that for each study cited in support of this registration or reregistration that is not an exclusive use study, either: (a) I am the original data submitter; (b) I have obtained the permission of the original 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 writing the company that submitted the study and have offered (I) to pay compensation to the extent required by sections 3(c)(1)(F) and/or 3(c)(2)(B) of FIFRA; and (ii) to commence negotiations to determine the amount and terms of compensation, if any, to be paid for the use of the study.

I certify that in all instances where an offer of compensation is required, copies of all offers to pay compensation and evidence of their delivery in accordance with sections 3(c)(1)(F) and/or 3(c)(2)(B) of FIFRA are available and will be submitted to the Agency upon request. 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 registration of my product in conformity with FIFRA. I certify that the statements I have made on this form and all attachments to it are true, accurate, and complete. I acknowledge that any knowingly false or misleading statement may be punishable by fine or imprisonment or both under applicable law.
Signature Date Typed or Printed Name and Title

EPA Form 8570-34 (12-2003) Electronic and Paper versions available. Submit only Paper version.

## ATTENTION DCI RESPONDENTS Under the Paperwork Reduction Act (PRA), 44 U.S. C. 3501 et seq ., an agency may not conduct or sponsor, and a person is not required to respond to, a collection of information unless it displays a currently valid OMB control number. The approval of an information collection can only be valid for up to three years, at which time the agency must obtain a renewal of that approval. The currently valid OMB control numbers for the EPA regulations that appear in 40 CFR, after initial display in the final rule, are listed in 40 CFR part 9 and are included on the response form or collection instrument. For forms, in addition to the required inclusion of the OMB control number for the Information Collection Request (ICR) containing the form, EPA has traditionally included the ICR expiration date on the form. When forms remain substantively unchanged for many years, the printed inventory of the form may not be exhausted before the expiration date used on the form. If the same form is approved as part of the renewal process, the agency may continue to use the remaining stocks of the paper form, even though that form contains• an obsolete expiration date. Although all of the attached forms that you are asked to utilize in responding to this DCI are currently approved by OMB, some contain obsolete expiration dates, or address and per response burden information in the PRA Notice. EPA is currently in the process of updating the electronic files of these forms, which are available on the internet at http://www.epa.gov/opprd001/forms, at which time EPA will also update the contents of the PRA Notice included on each form or as part of the instructions for the form. The public reporting and record keeping burden for this collection is estimated to average about 1063 hours per response for OPP's Registration Review DCIs and 596 hours for O PP's Reregistration DCIs. This includes the time for review of the instructions, read and discuss test requirements, discuss test and protocol with the Agency, plan activities, search existing data sources, gather and maintain the data needed, create infor mation, compile, process, complete and review the collection of information, complete written forms, record, disclose, and display information, and store, file or maintain information. This information (under Docket ID No. EPA- HQ

- OPP -2007-0923- 004) from Ta ble 1 and Table 1b of the Final Supporting Statement for an Information Collection Request (ICR) for the Pesticide Data Call

In Program may be accessed via: http://www. regulations.gov , or by: http://www.regulations.gov/#!docketDetail;D=EPA

- HQ

- OPP -2007- 0923;dct=FR%252BPR%252BN%252BO%252BSR Send comments regarding this burden estimate or any other aspect of this collection of information, including suggestions for reducing the burden, to Director, Collection Strategies Division (Mail Code 2822T), U.S. Environmental Protection Agency, 1200 Pennsylvania Ave., NW, Washington, D.C. 20460. Include the OMB control number in any correspondence, but do not submit the form or report to this address. The actual information or form should be submitted in accordance with the instructions accompanying the information or form, specified in the corresponding regulation. The supporting statement for the Information Collection Request (ICR) covering this DCI request is entitled " Pesticides Data Call -In Program " (OMB No. 2070-0174; EPA No. 2288.01). OMB No. 2070-0174 expires on November 3 0 , 201 3. For more information about the Agency's burden estimates, please go to the following RegInfo.gov website produced by the Office of Management and Budget (OMB): http://www.reginf o.gov/public/do/PRAMain and search for the control number (2070-0174).