EPA Registration 86008‐1
1
Page 2-*Confidential Statement of Formula may be entitled to conf
3

Material Sent for Data Extraction 

Reg # 8CooolS-1 

Description: Rc':)i ~---fi'<A-+lOIj 

IZJ Material(s) Sent to Data Extraction Contractors: 

% New Stamped Label Dated '6/5/1/ 

o Notification Dated ____ _ 

New CSF(s) Dated ____ _ 

o Other: _______________ _ 

o eci si 0 n #: __ Lf,---4,---o==-= <O~I 2>~ __ 

o Other ActionjComments: _____________ _ 

Attach this coversheet to the top of the material or jacket. It 

must be well organized and clipped together, NOT STAPLED. 

Then give the material with this coversheet to staff in the 

Information Services Center (Room 5-4900). 

Reviewer: Mindy Ondish 

Phone: 703-605-0723 Division: RD/PM Team 25 

Date: _________ ~~~/_5~j~II _____________ ___ 
4

U.S. ENVIRONMENTAL PROTECTION AGENCY 

Office of Pesticide Programs 

Registration Division (7505P) 

Ariel Rios Building 

1200 Pennsylvania Ave., NW 

Washington, D.C. 20460 

NOTICE OF PESTICIDE: 

.lL Registration 

__ Reregistration 

EPA Registration 

Number: 

86008-1 

Date of Issuance: 

AUG 5 2011 

Term of Issuance: Unconditional 

Name of Pesticide Product: 

(under FIFRA, as amended) Imazapyr Technical 

Name and Address of Registrant (include ZIP Code): 

Forerock, LLC clo Pyxis Regulatory Consulting, Inc. 

6648 Buffalo Speedway 4110 1361h Street, NW 

Houston, TX 77005-3833 Gig Harbor, WA 98332 

On the basis of 'lnformation fumished by the registrant, the above named pesticide is hereby registered/reregistered under the Federal Insecticide, 

Fungicide and Rodenticide Act. Registration is in no way to be construed as an endorsement or recommendation of this product by the Agency. In 

order to protect health and the environment, the Administrator, on his motion, may at any time suspend or cancel the registration of a pesticide in 

accordance with the Act. The acceptance of any name in connection with the registration of a product under this Act is not to be construed as giving 

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

This product is registered in accordance with FIFRA provided that you: 

1. Submit andlor cite all data required for registration reviewlreregistration of your product when 

the Agency requires all registrants of similar products to submit data. 

2. Submit one-year Storage Stability (Guideline 830.6317) and Corrosion Characteristics 

(Guideline 830.6320) studies within eighteen (18) months from the date of this notice. 

The Basic Confidential Statement of Formula (CSF) dated February 9, 2011 is acceptable. 

A stamped copy of the label is enclosed for your records. Submit one (1) copy of the revised final 

printed label before you release the product for shipment. If these conditions are not complied 

with, the registration will be subject to cancellation in accordance with FIFRA §6(e). Your release 

for shipment of the product constitutes acceptance of these conditions. 

If you have any questions regarding this Notice, please contact Mindy Ondish at (703) 605-0723 or 

at ondish.mindy@epa.gov. 

Signature of Approving OfficIal: 

Kable Bo Davis 

Product Manager 25 

Herbicide Branch 

Registration Division (7505P) 

EPA Form 8570-6 

Date: 

AUG 5 2011 
5

Imazapyr Technical 

FOR FORMULATION INTO HERBICIDES 

ACTIVE INGREDIENT: 

Imazapyr: 

2-[4-, 5-d ihyd ro-4-methyl-4-( 1-methylethyl)-5-oxo-1 H-imidazo 1-2 -yIJ-3-

pyridinecarboxylic acid ......................................................... ' ....................... 98.8% 

OTHER INGREDIENTS: ........ ,,"" " ........ ,,""""" """ "" """. """""""" ",," """ """ "" 1.2% 

TOTAL:." .. " """" .. " ...... " ..... "". " ... "." .. "" ..... "" ..... " ..... "" ...... " ... " ... ".". ,,' " ...... " .. 100.0% 

KEEP OUT OF REACH OF CHJLDREN 

DANGERlPELlGRO 

Si usted no entiende la etiqueta, busque a alguien para que se la explique a usted en detalle. 

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

FIRST AID 

Ifin eyes: • Hold eye open and rinse slowly and gently with water for 15-20 minutes. 

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

rinsing eye. 

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

If on skin or • Take off contaminated clothing. 

clothing: • Rinse skin immediately with plenty of water for 15-20 m'lnutes. 

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

If inhaled: • Move person to fresh air. 

• If person is not breathing, call 911 or an ambulance, then give artificial 

respiration, preferably by mouth-to-mouth if possible. 

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

HOT LINE NUMBER 

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

or going for treatment You may also contact CHEMTREC at 1-800-424-9300 for 

emeraency medical treatment information. 

Note to Physician: Probably mucosal damage may contraindicate the use of astric lavage. 

Net Weight: 165(lb) (75kg) 

EPA Reg. No. 86008-1 

EPA Est. No. ACCEPTED 

AUG 5 2011 

Under the Federal Insecticide, 

Fungicide. and Rodenticide ACI 

as amended, for the pesticide 

registered under 

EPA Reg. No. <3 CoQ oB - \ 

Manufactured for: 

Forerock, LLC 

6648 Buffalo Speedway 

Houston, TX 77005 
6

PRECAUTIONARY STATEMENTS 

HAZARDS TO HUMANS AND DOMESTIC ANIMALS 

DANGER. Corrosive. Causes irreversible eye damage. Harmful jf absorbed through skin or 

inhaled. Do not get in eyes, or on clothing. Avoid contact with skin. Avoid breathing dust. 

Wear protective eyewear (goggles, face shield or safety glasses). Wash thoroughly with soap 

and water after handling and before eating, drinking, chewing gum, using tobacco or using the 

tollet. Remove and wash contaminated clothing before reuse. 

PHYSICAL AND CHEMICAL HAZARDS 

Do not mix or store this product or solutions of this product in unlined steel containers. 

ENVIRONMENTAL HAZARDS 

This product is toxic to plants. Do not discharge effluent containing this product into lakes, 

streams, ponds, estuaries, oceans, or other waters unless in accordance with the requirements 

of a National Pollutant Discharge Elimination System (NPDES) permit and the permitting 

authority has been notified in writing prior to discharge. Do not discharge effluent containing 

this product to sewer systems without previously notifying the local sewage treatment plant 

authority. For guidance contact your State Water Board or Regional Office of the EPA. 

DIRECTIONS FOR USE 

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

Only for formulation into herbicides (liquid, wettable powder (in water soluble bags only) and 

granular} for the following uses: 

(1) Field Corn, Forestry, Aquatic, Grass pasture and rangeland, Non-cropland areas such as 

railroad, utility, pipeline and highway rights-of-way, utility plant sites, petroleum tank farms, 

pumping installations, fence rows, storage areas, and non-irrigation ditchbanks. 

(2) Uses for which USEPA has accepted the required data or citations of data that the 

formulator has submitted in support of registration. 

(3) Uses for experimental purposes that are in compliance with USEPA requirements. 

STORAGE AND DISPOSAL 

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

PESTtCtDE STORAGE: Store in original container in a well-ventilated area separately from fertilizer, 

feed and foodstuffs. Avoid cross-contamination with other pesticides. 

PESTICIDE DISPOSAL: Pesticide wastes are acutely hazardous. Improper disposal of excess 

pesticide, spray mixture or rinsate is a violation of federal law. Dispose of excess or waste pesticide by 

use according to label directions, or contact your State Pesticide or Environmental Control Agency, or the 

Hazardous Waste representative at the nearest EPA Regional Office for guidance. 

CONTAINER DISPOSAL: Supersack--Nonrefillable container. Do not reuse or refill this container. 

Completely empty bag into application equipment; then dispose of empty bag in a sanitary landfill or by 

incineration, or by other procedures approved by state and local authorities. Drum liner--Nonrefillable 

container. Do not reuse or refill this container. Completely empty removable liner by shaking and tapping 

sides and bottom to loosen clinging particles. Empty residue into application equipment then dispose of 

empty removable liner in a sanitary landfill or by incineration, or by other procedures approved by state 

and local authorities. Drum- Nonrefillable container. Do not reuse or refill this container. When 

completely empty offer for recycling if available or dispose of drum in a sanitary landfill or by incineration, 

or by other procedures approved by state and local authorities. 

Imazapyr Technical Label 2. 
7

CONDITION OF SALE AND LIMITATION OF WARRANTY AND LIABILITY 

Upon Purchase or use of this product, Purchaser and user agree to the following terms: 

Warranty: Forerock LLC (the Company) warrants that this product conforms to the chemical description 

on the label and is reasonably fit for the purpose referred to in the directions for use, subject to the 

exceptions noted below, which are beyond the Company's control. To the extent consistent with 

applicable law, the Company makes no other representations or warranty express or implied, concerning 

the product, including no implied warranty of merchantabilitY or fitness for a particular purpose. No such 

warranty shall be implied by law, and no agent or representative is authorized by the Company to make 

such warranty. 

Terms of Sale: The Company's direction for use for this product must be followed carefully. It is 

impossible for eliminate risks inherently associated with use of this product. Crop injury, ineffectiveness 

or other unintended consequences may result because of such factors as weather conditions, presence 

of other materials, or the manner of use or application (including failure to adhere to label directions.), all 

of which are beyond the Company's control. All such risks are assumed by the user. 

Limitation of Liability: To the extent consistent with applicable law, the exclusive remedy against the 

Company for any cause of action relating to the handling or use of the product is a claim for damages. To 

the extent consistent with applicable law, in no event shall damages or any other recovery of any kind 

exceed the price of the product which caused the alleged loss, damage, injury or other claim. To the 

extent consistent with applicable law, under no circumstances shall the Company be liable for any 

special, indirect. incidental or consequential damages of any kind, including loss of profits or income, and 

any such claims are hereby waived. Some States do not allow the exclusion or limitation of incidental or 

consequential damages. 

The Company and the seller offer this product, and the purchaser and user accept this product, 

subject to the foregoing warranty, terms of sale and limitation of liability, which may be waived or 

modified only by an agreement in wr"rting signed on behalf of the Company by an authorized 

representative. 

[EPA Approval date] 

Imazapyr Technical Label 3. 
8

REGISTRATION NOTE FOR RECORD 

This document may contain CBI. For internal Aaencv use onlv. 

EPA Reg. No.1 File Symbol: 86008-R (1) 

Product Name: Imazapyr Technical 

Application Date: 2/15/11 

Action Description: R310 

PRODUCT CHEMISTRY: (DP387482; 7/29/11) 

Basic CSF 2/9111 

Submitted product chemistry studies (MRID 48394801-04) 

Substantially similar to Reg# 241-286 

Data Gap: Storage Stability and Corrosion Characteristics 

ACUTE TOXICITY: (DP387483; 8/3/11) 

Cite-all method of data support 

Acute toxicity profile based on substantial similarity to Reg# 241-286 

Tax Category I for Primary Eye Irritation 

Tax Category III for Acute Dermal and Acute Inhalation 

Tax Category IVINegative for all other routes of exposure 

GENERIC DATA: 

Cite-all method of generic imazapyr data support 

LABEL REVIEW: 

Imazapyr 98.8% TGAI product for formulation into uses on field corn, forestry, aquatic, 

pasture/rangeland, and non-crop areas. 

COMMENTS: 

Imazapyr technical product from unregistered source 

Sent label comments via email on 8/4/11; revised label submitted on 8/4/11 

DECISION: 

Unconditional Registration with Data Requirements 

Reviewer: I Mindy Ondish I Date: I 8/4/11 
9

RE: 86008-R Imazapyr technical label comments 

Ann Tillman to: Ondish 08/04/2011 05:30 PM 

2 attachments 

086008~ 1.2011 0804.Jmazapyr Technical 

~ Jabel v1 revised_tracked.pdf 

"""-I i~ 086008·1.20110804.JmazapyrTechnicallabel v1 revised.pdf 

Mindy, 

I've attached 

clean copy) . 

revised copies 

Let me know if 

of the label (version with changes tracked and a 

you need any other changes. Thanks. 

Ann 

Ann M. Tillman, ph.D. 

Pyxis Regulatory Consulting, Inc. 

4110 136th st. NW 

Gig Harbor, WA 98332 

Office (253) 853-7369 

Fax (253) 853-5516 

Email Ann@pyxisRC.com 

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

From: Ondish.MindY@8pamail.epa.gov {mailto:Ondish.Mindy@epamail.epa.gov] 

Sent: Thursday, August 04, 2011 4:59 PM 

To: Ann Tillman 

Subject: 86008-R Imazapyr technical label comments 

Hi Ann, 

Your proposed label for Imazapyr Technical (86008-R) requires the following 

changes: 

1. Change the order of the FIRST 

or clothing", then "If inhaled". 

may be removed. 

AID 

The 

statements to "If in eyes", 

"If swallowed" -statement is 

2. Change the EPA Reg. No. to "86008-1". 

"If on skin 

optional and 

3. Change the HAZARDS TO HUMANS AND DOMESTIC ANIMALS statement to "DANGER 

Corrosive. CauseS irreversible eye damage. Harmful if absorbed through skin 

or inhaled. Do not get in eyes or on clothing. 

Avoid contact with skin. Avoid breathing dust. Wear protective 

eyewear ... contaminated clothing before reuse." 

4. Under Terms of Sale, change the first sentence to "The Company's 

directions for use for this product must be followed carefully." 

Please submit revised label (preferably via email) by 8/15 for review. 

Sincerely, 
10

Mindy Ondish 

Biologist / Risk Manager 

Herbicide Branch (PM Team 25) 

Registration Division (7505P) 

Office of Pesticide Programs 

U.S. Environmental Protection Agency 

(703) 605-0723 
11

EPA File Symbol 86008~R 

PC Code 128821 (imazapyr) 

) 

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 

WASHINGTON, D.C. 20460 

OFFICE OF CHEMICAL SAFETY AND 

POLLUTION PREVENTION 

OFFICE OF PESTICIDE PROGRAMS 

REGISTRATION DIVISION (7505P) 

TECHNICAL REVIEW BRANCH 

SIMILARITY DETERMINATION 

03/AUG/201 I 

MEMORANDUM 

Subject: Name of Pesticide Product 

EPA Reg. No. !File Symbol: 

Imazapyr Technical 

86008-R 

DP Barcode: D387483 

Decision No: 445613 

Action Code: R310 

PC Code: 128821 (imazapyr) 

From: 

To: 

Applicant: 

Eugenia McAndrew, Biologist 

Technical Review Branch 

Registration Division (7505P) 

Mindy Ondish, RM Team 25 

Herbicide Branch 

Registration Division (7505P) 

F orerock LLC 

6648 Buffalo Speedway 

Houston, TX 77005 

FORMULA nON FROM LABEL: 

Active IngredientCs): 

Irnazapyr 

Other IngredientCs): 

Page lof3 

Total: 

% bywt. 

98.8 

1.2 

100.0% 
12

EPA File Symbol 86008-R 

PC Code 128821 (imazapyr) 

ACTION REQUESTED: The Risk Manager requests: "New registration application for 98.8% 

imazapyr technical product. Claiming substantial similarity to 241-;286." 

BACKGROUND: Forerock LLC has applied for registration of Imazapyr Technical, 

EPA File Symbol 86008-R, claiming similarity to Arsenal Herbicide Technical, EPA Reg. No. 

241-286. The active ingredient in both products is imazapyr (98.8% in the proposed product vs. 

98.5% in the cited product). The registrant is using the cite-all method of data support to satisfy 

the acute toxicity data requirements. A basic CSF dated February 9, 2011, label and company 

letter are included in the submission. 

A search of the OPP electronic databases shows that the cited product, 241-286, was most 

recently assigned an acute toxicity profile during reregistration (Lewis; D359768; 

16IDEC/2008). 

RECOMMENDATIONS: 

1. TRB compared the formulations of the proposed product, 86008-R, and the cited product, 

241-286, and concluded that the two products are substantially similar. 

2. The acute toxicity profile for the proposed product, Imazapyr Technical, EPA File Symbol 

86008-R, is as follows: 

acute oral toxicity IV cited EPA Reg. No. 241-286 

acute dermal toxicity III cited EPA Reg. No. 241-286 

acute inhalation toxicity III cited EPA Reg. No. 241-286 

primary eye irritation I cited EPA Reg. No. 241-286 

primary skin irritation IV cited EPA Reg. No. 241-286 

dermal sensi tization negative cited EPA Reg. No. 241-286 

3. This memorandum pertains only to the decision concerning whether the subject product is 

similar to the cited product from an acute toxicological view point. For the purposes of this 

action, TRB has made no further determination of the adequacy of the toxicological data base or 

the precautionary label of the cited product. 

4. The proposed basic CSF submitted for 86008-R was reviewed and accepted by the IRE 

Product Chemistry Team (Abramovitch; D387482; EPA File Symbol 86008-R; 02/ AUG/2011). 

Page 2 of3 
13

EPA File Symbol 86008-R 

PC Code 128821 (imazapyr) 

LABELING: Based on the toxicity profile above, the following are the precautionary and first 

aid statements for this product as obtained from the Label Review System: 

PRODUCT 10 #: 086008-00001 

PRODUCT NAME: Imazapyr Technical 

PRECAUTIONARY STATEMENTS 

SIGNAL WORD: DANGER 

Hazards to Humans and Domestic Animals: 

Corrosive. Causes irreversible eye damage. Harmful if absorbed through skin. Harmful if inhaled. Do not 

get in eyes or on clothing. Avoid contact with skin. Avoid breathing dust. Wear protective eyewear 

(goggles, face shield, or safety glasses). 

First Aid: 

If in eyes: 

-Hold eye open and rinse slowly and gently with water for 15-20 minutes. 

-Remove contact lenses, if present, after the first 5 minutes, then continue rinsing. 

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

If on skin: 

-Take off contaminated clothing. 

-Rinse skin immediately with plenty of water for 15-20 minutes. 

-CaU a poison control center or doctor for treatment advice. 

If inhaled: 

-Move the person to fresh air. 

-If person is not breathing, call 911 or an ambulance, then give artificial respiration, preferably mouth-tomouth if possible. 

-CaU a poison control center or doctor for further treatment advice. 

User Safety Recommendations: 

Wash thoroughly with soap and water after handling and before eating, drinking, chewing gum, using 

tobacco or using the toilet. Remove and wash contaminated clothing before reuse. 

Note to Physician: 

Probable mucosal damage may contraindicate the use of gastric lavage. 

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

treatment. You may also contact 1-800-xxx-xxxx for emergency medical treatment information. 

Page 3 of3 
14

DATA EVALUATION RECORD 

IMAZAPYR 

(IMAZAPYR TECHNICAL) 

STUDY TYPES: Product Identity and Composition (OPPTS 830.1550) 

Primary Reviewer; 

Description of Materials Used to Produce the Product (OPPTS 830.1600) 

Description of the Formulation Process (OPPTS 830.1650) 

Discussion of Formation oflmpurities (OPPTS 830.1670) 

Preliminary Analysis (OPPTS 830.1700) 

Certified Limits (OPPTS 830.1750) 

Enforcement Analytical Method (OPPTS 830.1800) 

Physical and Chemical Characteristics (OPPTS 830.6302-830.7950) 

MRlDs 483948-01 through 483948-04 

Prepared for 

Registration Division 

Office of Pesticide Programs 

U.S. Environmental Protection Agency 

One Potomac Yard 

2777 South Crystal Drive 

Arlington, V A 22202 

Prepared by 

Summitec Corporation 

9724 Kingston Pike, Suite 602 

Knoxville, Tennessee 37922 

Task Order No. 3-A-71 

Thomas C. Marshall, Ph.D. Signature: 

Date: 

Secondary Reviewers: 

Dennis Opresko, Ph.D. Signature: 

Date: 

Robert Ross, M.S., Program Manager Signature: 

Date; 

Qual ity Assurance: 

Angie Edmonds, B.S. Signature: 

Date: 

Disclaimer 

This review may have been alJered subsequenJ to Jhe conJractor's signalures above. 

Summitec Corp. for the U.s. Environ mental Projection Agency under Contract NO.EP-W-II-OI4 
15

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 

WASHINGTON, D.C. 20460 

DATE: July 29, 2011 

OFl'ICE OFCHEUICAL SAFETY 

AND POLLUTlON PREVENTIO:"l 

OFFICE OF PESTlClDE PROGRAi\1S 

REGISfRATlON DIVISION (75(lSP) 

SUBJECT: Product Chemistry Review of "Imazapyr Technical" TGAIIMUP 

FROM: 

THROUGH: 

Akiva Abramovitch, Ph.D. 

Technical Review Branch I RD (7505P) 

Shyam B. Mathur, Ph.D. 

Product Chemistry Team Leader 

Technical Review Branch/RD (7505P) 

1 

~ TO: Mindy Ondish, Reviewer IKable Davis, Product Manager, RM 25 

Herbicide Branch I RD {7505P} 

DP BARCODE: 387482 

DECISION No.: 445613 

REGISTRATION NO./FILE SYMBOL NO.: 86008-R 

PRODUCT NAME: Imazapyr Technical 

PC CODE: 128821 

REGISTRANT: Forerock, LLC 

USE: Herbicide 

FOOD U3E: Yes L\1 c·, 

MRID Numbers: 483948~01 through 483948~04 

INTRODUCTION: 

The registrant is seeking a new product registration that the registrant claims is substantially similar to an 

existing product (Reg. No. 241~286) .. To support the registration, product chemistry data was provided in 

MRID 483948~01 through 04. The registrant also submitted a Confidential Statement of Formula (CSF) 

for the basic formulation (February 9, 2011). This review has been altered subsequent to the contractor's 

signatures .. 

SUMMARY OF FINDINGS: 

1 The product chemistry data corresponding to guideline reference 830.1550 (product identity & 

composition) satisfy the data requirements of 40CFR§158.155. The data corresponding to guideline 

reference 830.1750 (certified limits) satisfy the requirements of 40CFR§158.175 [MRID No. 483948~011. 

The concentration of active ingredient given on the CSF for the basic formulation matches the label. 

2. The product chemistry data submitted corresponding to guideline reference 830.1600 (description of 

material used to produce the product) satisfy the data requirements of 40CFR§ 158.160 [MRID No. 

483948-011· 
16

i 

BARCODE: 387482; Reg. No. /rILE SYMBOL No.:86008-R; PRODUCT NAr,IE; ImazapyrTechnical 

3. The product chemistry data submitted corresponding to guideline reference 830.1620 (description of 

production process) satisfy the data requirements for 40CFR§158.162 [MRID No. 483948-01). 

4. The product chemistry data submitted corresponding to guideline reference 830.1670 (discussion of 

the formation of impurities) satisfy the data requirements for 40CFR§158.167 [MRID No. 483948-01). 

There are no known impurities of toxicological concern (MRID 483948-01 and -02). 

5. The product chemistry data submitted corresponding to guideline reference 830.1700 (preliminary 

analysis) to support the claims on the CSF satisfy the data requirements of 40CFR§158.170 [MRID No. 

483948-02). 

6. The product chemistry data submitted corresponding to the guideline reference 830.1800 (enforcement 

analytical method) satisfy the data requirements of 40CFR§158.180 [MRID 483948-01). An HPLC method 

is described with PDA detection. Validation studies and chromatograms were provided. 

7. The product chemistry data submitted corresponding to guidelines 830 Series Subgroup B (physical· 

chemical properties) satisfy the data requirements of 40CFR§158.190 [MRID No. 483948-03) with the 

exception of storage stability and corrosion data [MRID No. 483948-04]. 

CONCLUSIONS: 

The TRB has reviewed the product chemistry data submitted for Imazapyr Technical (produced by 

Forerock, LLC) and has concluded that: 

1. All product chemistry data submitted for guideline 830 Series group A are acceptable. 

2, The proposed CSF dated February 9, 2011 for the basic fonnulation is acceptable. 

3. The product chemistry data corresponding to 830 series group B (physical-chemical properties) are 

acceptable with the exception of storage stability and corrosion data. 

4. This product is substantially similar to the cited product EPA Reg. No. 241-286. The impurities listed 

on the basic CSF dated February 9, 2011 also appear on the "me-too" CSF with the exception of #2 

which is related to Imazapyr ( and the registrant claims that 

it is of no toxicological concern. 

830.1550. Product identity & composition: (MRID No. 483948-01) 

Common Name: Imazapyr 

Chemkal name (CAS): (±)-2·[4,-5-dihydro-4·methyl-4-( 1·methylethyl)-5-oxo-1 H·imidazol-2-yIJ·3-

pyridinecarboxylic acid 

(IUPAC): 2-(4·lsopropyl-4-methyl·5-oxo-2·imidazolin-2·yl)nicotinic acid 

CAS No.: 81334-34-1 

PC Code No.: 128821 

Empirical Formula: C13H1SN303 

Molecular Weight 261.3 

Structural Formula: 

2 

*Commercial/financial information may be entitled to confidential treatment* *Manufacturing process information may be entitled to confidential treatment*
17

BARCODE: 387482; Reg. No. /rILE SYMBOL No.:86008-R; PRODUCT Nk..w-IE: Imazapyr Technical 

830 Series <, ,B '~ I 

Table 2: I and , IP , ot: I I IIGAI 

GlN , MRID Status Resu!tor 

830.6302 Color A WhI" 

I slate 483948-03 A Solid 

830.6304 Odor 483948-03 A Slight acetic acid. 

830.63t3 Stability to normal and 483948-03 A Stable to normal and elevated temperatures, and in 

elevated the presence of metals and metal ions for 14 days 

mol",. .1 ions 

830.6314 OxidatJonfreduction: 483948-04 W Product does not contain any ingredien! considered 

chemical incompatibility reactive. Imazapyr MSDS stares it can react with 

strong oxidizers, although th·ls statement is in 

conflict with other statements on the MSDS that 

water :~ o!~i~ ·materia!s are appropriate fire- : fighting· !. 

830.6315 Flammability 483948-04 W :I ~~Ii? and , ,. CSF . , ;;;~; 

830.6316 Explodability 483948-04 W Product has no functional groups associated with 

i i 

8(oe,,, ",bllity _G '" ",,,Ide d," If' 

19 , NIA Solid ,"d , , '1q"1d prod"," 

C , G 'wHi ""Ide dot, If' 

pH A 26 ot 2" 2 "C 

830.7050 UVNisible absorption 483948-03 A Wavelength; molar absorption at t xtO-! M: 

At neutral (pH value not provided): log € '" 4.14 @ 

AmID< 209 nm. 

At acidic (pH value not provided): log t '" 3.97@ 

Am"" 232 nm; Log € '" 4.08@Amax207nm. 

~:I~~~~e (f~ value :2:1~~g E '" 3.78@ ; om; log ,~ 4.31@_,""; '>Un. 

830.7100 , NIA ,Solid 

830.7200 Melt'og po'o' A __ 171.6 'c, 

"0 "'0 Bolllo, polo! --"'" ~d 

"","0 Deo,lty -'- 1.27D ,I" ot 22 'C 

830.7370 Dissociation constants in 483948-03 A f:;~~;F t.J"C not provided; 

i i 13'" Edlt'oo. p. 555) 

830.7550 Partition coefficient 483948-04 A ~oin~;t ~ 3~· ~d~O~~ ;~5~~)m The Pesticide 

830.7840 Water solubility 483948-04 A 

~!~;~i 25'C ,,"e 

830.7950 Vapor pressure 483948-04 A ' MOO"". 

I~:, ;N~, , ' \; w; ~:~Y;r~ot , G' ; I '" In progress; 

4 
18

, ' 

BARCODE: 387482; Reg. No. wILE SYMBOL No.:86008-R; PRODUCT Nk,VIE: lmazapyrTechnicaJ 

il Ii 

483948-01 A 

483948-01 A 

A 

483948-01 A 

r 

830.1800 (enforcement analytical method) 

The enforcement analytical method to determine the content of active ingredient is an HPLC method with 

a PDA detector. Validation studies and sample chromatograms were provided. The registrant provided 

the following details in MRID 483948-01: 

Fromp.11 

The pUlity test fur imazapyr TGA! were perfonnod by IfPLC method according to SwRl 

T AP-O I ~0408-094. Thesrunples were prepared atab:mt 1 mglmLfn Milli-Q water and further dihtted 

4O-fold with MiIli-Q water. The analysis was perfcnne<i on a Watf:rs HPLC using ~ FDA detector 

monitoring a UV runge of21 0 to 400' nm wim an extraded wavelength of280 nm. The system was 

equlppem with <'t Supfllco Discovery C18 2S(:.m,. 4.6 rom, Sum column. Th.~mobile phase was 35% 

Methano:l:65% pH 3 MiHi.Q water .adjusted with a-phosphoric acid at a flow rate of J ,0 miJmin. 

3 
Pages 19-23-*Manufacturing process information may be entitled to confidential treatment*
24

UNf, _.l STATES ENVIRONMENTAL PROTECTlvN AGENCY 

WASHINGTON, D.C. 20460 

February 28,2011 

JANELLE KAY 

PYXIS REGULATORY CONSULTING, INC. 

FOREROCK, LLC 

4110 136TH STREET, NW 

GIG HARBOR, W A 98332-

Report of Analysis for Compliance with PR Notice 86-5 

OFFICE OF 

PREVENTION, PESTICIDES AND 

TOXIC SUBSTANCES 

Thank you for your submittal of 17-FEB-l1. Our staff has completed a preliminary 

analysis of the material. The results are provided as follows: 

Your submittal was found to be in full compliance with the standards for submission of 

data contained in PR Notice 86-5. A copy of your bibliography is enclosed, annotated with 

Master Record ID's (MRIDs) assigned to each document submitted. Please use these numbers in 

all future references to these documents. Thank you for your cooperation. If you have any 

questions concerning this data submission, please raise them with the cognizant Product 

Manager, to whom the data have been released. 
25

PYJ. )REGULATORYCONSULTINt. .• NC. 

4110136th StNW 

Gig Harbor, WA 98332 

OVERNIGHT DELIVERY 

Bo Davis (PM 25) 

Document Processing Desk (REGFEE) 

Office of Pesticide Programs (7504P) 

U.S. Environmental Protection Agency 

Room 8-4900, One Potomac Yard 

2777 S. Crystal Drive 

Arlington, VA 22202 

RE: Forerock, LLC 

Imazapyr Technical (EPA File Symbol 86008-

Application for New Pesticide Registration 

PRIA Category R3 10 

Dear Mr. Davis, 

February 14,2011 

) 

483948·00 

Phone: 253-853-7369 

Fax: 253-853-5516 

www.PyxisRC.com 

On behalf of Forerock, LLC, we are sUbmitting an application for registration of Imazapyr Technical. In 

support of this application, we submit the following documents: 

l. Application fora New Pesticide Registration (EPA Form 8570-1) 

2. Confidential Statement of Formula (EPA Form 8570·4) 

3. Three (3) Copies of the Proposed Labeling 

4. A CD containing an electronic version of the label 

5. Certification with Respect to Label Integrity 

6. Agency Internal Use Copy of the Data Matrix 

7. Public File Copy of the Data Matrix 

8. Certification with Respect to Citation of Data (EPA Form 8570·34) 

9. Documentation ofSmalJ Business for 75% PRIA fee reduction 

10. Copy of the PRlA payment from pay.gov 

11. Letter of Authorization 

12. Product Specific Data (3 copies each): 

48384801 Volume I 830.1550,830.1600, Tillman, A.M. Product Identity and Composition, Description 

830.1620,830.1670, of the Materials Used, Description of the Production Process, 

830.1750,830.1800 Discussion of the Formation oflmpurities, Certified Limits and 

Enforcement Analytical Method for Imazapyr Technical. 

Contains Confidential Business Information 

48394802 Volume 2 830.1700,830.1800 Sun, G. Preliminary Analysis ofImazapyr Technical Grade 

Active Ingredient. Contains Confidential Business 

Information 

48384803 Volume 3 830.6302, 830.6303, Sun, G. Imazapyr Technical Grade Active Ingredient Physical 

830.6304, 830.6313, and Chemical Characteristics. 

830.7000,830.7050, 

830.7200,830.7300 
26

48394804 Volume 4 830.6314,830.6315, 

830.6316,830.6317, 

830.6319,830.6320, 

830.6321,830.7100, 

830.7220,830.7370, 

830.7520,830.7550-

7570,830.7840-

7860, 830.7950 

B. Davis 

Feb. 14,2011 

Page 2 of2 

Tillman, A. M. Imazapyr Technical Waiver Requests for 

Certain Phys-Chem Properties. 

We would like to note that Forerock, LLC is using the cite-all method of support. As per EPA's 

interpretations of40 CFR Parts 152.86(b)(2)(i) and I 52.93(b)(2)(i), Forerock, LLC submitted notices of 

intent to apply and offers to pay to all companies on the September 30, 2010 Data Submitter's List. This 

action falls under Category R31 0 (46: New manufacturing use product) because it is an application for 

registration of a new manufacturing use product which is substantially similar to a currently registered 

product. The PRIA fee nonnally due is $4,807 but Forerock LLC is submitting documentation for a small 

business fee reduction of 75% to $1,201.75. This fee has been paid. This action has a decision time line 

of 6 months. 

We trust you will find this application complete. However, please feel free to contact me by email at 

Ann@pyxjsRC.com or by phone at (253) 853-7369 if you have any questions or need any additional 

infonnation. 

Sincerely, 

Ann M. Tillman 

Enclosures 

cc: Ingrid Wang, Forerock, LLC 
27

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 

WASHINGTON, D.C. 20460 

March 3, 201l 

OPP Decision Number: D-445613 

EPA File Symbol or Registration Number: 86008-R 

Product Name: IMAZAPYR TECHNICAL 

EPA Receipt Date: 3-Mar-20 11 

EPA Company Number: 86008 

Company Name: FOREROCK, LLC 

Ann Tillman 

PYXIS REGULATORY CONSULTING, INC. 

FOREROCK, LLC 

4110 136TH STREET, NW 

GIG HARBOR, WA 98332-

OFFICE OF 

PREVENTION, PESTICIDES AND 

TOXIC SUBSTANCES 

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

Dear Registrant: 

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

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

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

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

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

The Action has been identified as Action Code: R31 0 

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

CHEMISTRY;ACUTE TOXICITY;PUBLIC HEALTH PEST EFFICACY); 

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

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

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

receive an invoice for the outstanding balance. 

If you have any questions, please contact the Pe ·cide Registration Service Fee 

Ombudsman at (703) 308-9362. 
28

"~~;:". .~. 

Re: FW: Registration Application Subject to Registration Service Fee for 

Forerock LLC, D-445613 Gl 

• ··u.&·~ Stephen Schaible to: John Jamula, Christopher Green 03/03/201112:19 PM 

Cc: Ann Tillman 

JJ, 

Please recode the application for 86008·R (D445613) from R300 to R31 O. The request is for registration 

of a manufacturing use product which is claimed to be substantially similar to an existing product, and 

product specific data are submitted for review. This should be an R310. 

Chris- the small business waiver request for this action are included as an attachment to the email below. 

There is a post·'lt note from Teresa in the actual jacket indicating that this information was not included, 

but the registrant quickly provided this information in response to the receipt email that was sent out. 

Than ks! Steve 

Stephen A. Schaible 

U.S. Environmental Protection Agency 

Office of Pesticide Programs 

Registration Division (7505P) 

1200 Pennsylvania Avenue, NW 

Washington, DC 20460 

ph: (703)308-9362 

fax: (703)305-6920 

Ann Tillman St13ve;)3erow'is tHe'message I re_ceived today re ... 02125/2011 01 :36:20 PM 

From: 

To: 

Date: 

Ann Tillman <Ann@PyxisRC.com> 

Stephen SchaibleJOC/USEPAlUS@EPA 

02/25/2011 01 :36 PM 

Subject: FW: Registration Application Subject to Registration Service Fee for Forerock LLC, 0-445613 

Steve, 

Below is the message I received today regarding the Forerock LLC submission. 

Attached is the cover letter from the submission as well as the small business 

documentation. Can you please check the PRIA category? 

Please let me know if there is anything else I 

this. I won't pay any additional fees until I 

and the decision on the small business waiver. 

questions. Thanks much. 

Ann 

Ann M. Tillman, Ph.D. 

Pyxis Regulatory Consulting, Inc. 

4110 136th St. NW 

Gig Harbor, WA 98332 

Office (253) 853-7369 

Fax (253) 853-5516 

Email Ann@PyxisRC.com 

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

need to do to follow up on 

hear back on the PRIA category 

Call me if you have any 
29

From: DCOPPAPPS01/DC/USEPA/US@epamail.epa.gov [ 

mailto:DCOPPAPPS01/DC/USEPA/Us@epamail.epa.gov] On Behalf Of Pesticide 

Registration Improvement Act 

Sent: Friday, February 25, 2011 11:41 AM 

To: Ann Tillman 

Subject: Registration Application Subject to Registration Service Fee 

February 25, 2011 

OFFICE OF 

PREVENTION, PESTICIDES AND 

TOXIC SUBSTANCES 

PLEASE RETURN A COPY OF THIS LETTER WITH PAYMENT Or Pay On-Line at www.Pay.Gov 

(See Below for Details) 

OPP Decision Number: D-445613 

EPA File symbol or Registration Number: 86008-R Product Name: IMAZAPYR 

TECHNICAL EPA Receipt Date: 17-Feb-2011 EPA Company Number: 86008 Company 

Name: FOREROCK, LLC 

Ann Tillman 

PYXIS REGULATORY CONSULTING, INC. 

FOREROCK, LLC 

4110 136TH STREET, NW 

GIG HARBOR, WA 98332-

SUBJECT: Receipt of Registration Application Subject to Registration service 

Fee 

Dear Registrant: 

The Office of Pesticide Programs has received your application 

for registration. If you submitted data with this application, the results of 

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

administrative screen, the Office of Pesticide Programs has determined that 

this Action is subject to a Pesticide Registration Service Fee as defined in 

the Pesticide Registration Improvement Act. 

The Action has been identified as Action Code: R300 

NEW PRODUCT;ME-TOO PRODUCT FAST TRACK; 

The fee associated with this action is $ 1,434. payment in the amount 

of $ 1,201.75 has been received. Please remit additional payment in the 

amount of $ 232.25. Although the transmittal indicated that small business 

fee waiver documentation was included we found no evidence of such 

documenatation. 

By USPS: 

USEPA Washington Finance Center 

Pesticide Registration Service Fee 

st. Louis, MO 63197-9000 

By Courier: 

U.S. Bank 

PO Box 979074 
30

Government Lockbox 979074 

1005 Convention Plaza 

SL-MO-C2-GL 

St. Louis, 

Telephone: 

MO 

(412 ) 

63197 

236-2294 

All payments must be in United States currency by check, bank 

draft, or money order drawn to the order of the Environmental protection 

Agency. To ensure proper credit, please write the OPP DECISION NUMBER on your 

check, and enclose a copy of this letter with your payment. 

Effective November 1, 2006, fees may be paid on-line via credit card or 

electronic fund transfer. To submit a payment on-line, visit www.pay.gov. 

From the pay.gov home page, select "search by form name." 

From the next page, select lip," then click on "Pesticide Registration 

Improvement Act. Fee Payment" and complete the form, making certain to use the 

decision number and registration number on the invoice you receive from the 

Pesticide Program in the space provided. 

You may be eligible for a partial waiver of the registration service fee 

if, for example, you qualify as a small business or are applying for a minor 

use, or if your application is solely associated with an IR-4 tolerance 

petition. please be advised that if you intend to request a waiver, you must 

do so in writing within 15 days of receipt of this invoice instead of 

remitting the amount indicated above. OPP will not consider waiver requests 

after the registration service fee has been paid. Information regarding 

eligibility and how th request and document a fee waiver is available on the 

OPP Fee for Service web site at www.epa.gov/pesticides/fees. 

Please send Registration Service Fee Waiver requests to: 

By USPS: 

Document Processing Desk (WAIVER) 

Office of Pesticide Programs (7S04C) 

(7S04C) 

U.S. Environmental Protection Agency 

Protection 

Agency 

1200 pennsylvania Ave NW 

Potomac Yard 1 

Washington, DC 20460 

Arlington, VA 22202 

By Courier: 

Document processing Desk (WAIVER) 

Office of Pesticide Programs 

U.S. Environmental 

Room S4900 

2777 S. Crystal Dr. 

A PRIA decision time review period will not start until a fee waiver is 

granted and/or the Agency receives certification that the outstanding fee has 

been paid. If the Agency does not receive certification of payment for this 

action or a fee waiver request within the next 14 days, the Agency will 

presume that you no longer want to pursue this action. 

The Agency will then reject your application and issue an invoice for any 
31

applicable outstanding fees. 

If you have any questions, please contact the Pesticide 

Registration Service Fee Ombudsman at (703) 308-9362. 

Sincerely, 

Front End processing 

Staff 

Information Technology & 

Resources Management Division 

2011 0214 lore rock imazapyr technical application 

~ lor small business waiver {75%).pdl 
32

PRIA 2 - 21 Day Content Screen Review Worksheet 

(EP AlOPP Use Only) 

/] /7 3/23/09 

21 Day Screen Start Date: __ -",-<><-,-,.;,-,--~/~/ ______ ~ 

Experts In-Processing Signature: j3, ,<'2.-. Date .;.2 ':'~-!I Fee Paid: Yes v 

Division management contacted on issues 'No, ___ Yes Date _____ _ 

EPA Reg. Number: f too EPA Receipt Date: 0< - I 7 - I J 

I 

2 

3 

Items for Review 

Application Form (EPA Fonn 8570-1)(1ink to form) signed & complete 

including package type 

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

a) All inerts (link to bttp://www.epa.gov/opprdOOlJinerts/), 

including fragrances, approved for the proposed uses (see \/ 

Footnote A. 

no 

Certification with Respect to Citation of Data (EPA Fonn 8570-34) (Link 10 

fonn) completed and signed eN/A if 100% repack) 

Certificate and data matrix consistent 

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

to pay statement included. (see Footnote B) 

yes no 

Yes No N/A* 

x. 

I 

~=If 4 completed :f!1S and' ==~ (N/ A if source is unregistered o71r~~~~!!;~o~w~ns~th;:;;:;e\-t---t--t---j 

5 

Data Matrix (EPA Fonn 8570-35) (Link to fonn) both internal and external 

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

Selective Method 

b) Cite-AlI (Fee category experts use) 

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

5 Copies of Label (link to http://www.epa.gov/oppfeadi/Iabelingflrm!) 

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

http://www.epa.gov/pe8ticidesiregulating/registeringisubmissionslindex.htm#labels X 

1 
33

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

Notice of Filing (link to 

S htt[!:llwww.eQ3.gov/[!esticidesireguIatin2ftolerance uetitions.htm) included 

with petitions (link to 

h tip :llwww • ep •. aov/p estieides/reeul.tin""tol er.nees.h tm) -L 

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

http://www.epa.gov/opprdOOllworkpl.nJredueedrisk.html) ""-

Required Dat. (link to 

httI!:I/www.eI!3.gov/nesticides/regylatinf!!data .t:eguirements.htm) and/or 

data waivers. See Footnote C. 

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

10 

2 
34

Comments: 

Nb ,,,,,,,-Is £,.,.".- \-,:N'''''..,) - Ac-i-;,,<- ~ T",?~,",,-j.;t:5 n...1'1 

l'<ssd n-S' 'K~;'<W ,,,,ui> '/fc3 s 1);, 

* N/A - Not Applicable 

Footnotes 

A. During the 21 day initial content review, all CSFs will be reviewed to detennine 

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

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

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

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

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

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

eSF and may require submission of data. All infonnation, founs, data and 

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

application withdrawn within the 21 day period, otherWise, the Agency will reiect the 

application as described below. 

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

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

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

3 
35

site [link to http://www.epa.gov/opprdOOllineltsilists.html] and if the inert is not 

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

to register a pesticide product containing that inert ingredient. Some inert 

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

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

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

delays. 

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

inert has been approved, the applicant should contact the Inert Ingredient Assessment 

Branch (IIAB) at inertsbranch@epa.govandresolvetheissue. Copies of the 

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

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

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

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

Microbial Pesticides Branch [Link to 

http://www.epa.gov/oppbppdllbiopesticides/contactsbppd.htm]. 

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

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

information [link to http://www.''l'a.gov/opprdOOllinerts/tips.pdf] must also be included 

to enable the Agency to detennine ifit has been approved. Each component of an inert 

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

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

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

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

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

cannot or are not identified or provided within the 2l-day content review period, the 

Agency will reject the application. 

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

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

Unapproved Inerts Identified on CSFs 

All applications except conventional new products and PIPs 

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

applicant with the following options: 

1. Correct the application by, for instance, correcting the inert's identity or CAS 

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

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

approved for the application's uses; or 

2. Submit the information and data needed for the Agency to approve the 

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

request an extension in the PRIA decision review timeframe to accommodate 

the inert review/approval process; 

4 
36

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

category estimated); or 

Ifnone of these options is selected and implemented by the applicant within the 

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

25% of the full fee of the category identified. 

Conventional New Product Applications 

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

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

inert approval (R311, R3l2 or R313), it will contact the applicant with the 

following options: 

I. Correct the application by, for instance, correcting the inert's identity or CAS 

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

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

approved for the application's uses; or 

2. Submit the infonnation and data needed for the Agency to approve the 

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

tolerance or exemption from a tolerance. (TIlls option may change the PRlA 

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

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

Agency within the 21 day content review period.) 

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

category estimated); or 

Ifnone of the above options is selected and implemented during the 21-day 

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

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

PIP Applications 

When the Biopesticide and Pollution Prevention Division identifies an 

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

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

options: 

I. Correct the application by, for instance, correcting the speliing or name of the 

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

approved; or 

2. Submit the infonnation and data needed for the Agency to approve the 

unapproved inert. If an inert ingredient tolerance exemption petition is 

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

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

Agency will discuss harmonizing the timeframe for both actions. 

5 
37

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

category estimated); or 

If none ofthe above options is selected and implemented during the 21 day 

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

the fee. 

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

me-too or fast track (similarlidentical) new product, R300 or A530, an application 

without the necessary authorizations of offers to pay wiIl be placed into either R301 or 

AS31. The Agency recommends that authorizations of offers to pay be submitted with 

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

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

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

should be submitted with the study waiver. 

6 
38
39

'] 

UI'" /ED STATES ENVIRONMENTAL PROTEC flON AGENCY 

WASHINGTON, D,C. 20460 

February 25,2011 

PLEASE RETURN A COpy OF THIS LETTER WITH PAYMENT 

Or Pay On-Line at wmv.Pay.Gov (See Below for Details) 

OPP Decision Nwnber: D-445613 

EPA File Symbol or Registration Nwnber: 86008-R 

Product Name: lMAZAPYR TECHNICAL 

EPA Receipt Date: l7-Feb-2011 

EPA Company Nwnber: 86008 

Company Name: FOREROCK, LLC 

Ann Tillman 

PYXIS REGULATORY CONSULTING, INC. 

FOREROCK, LLC 

4110 136TH STREET, NW 

GIG HARBOR, WA 98332-

OFFICE OF 

PREVENTION, PESTICIDES AND 

TOXIC SUBSTANCES 

SUBJECT: Receipt of Registration Application Subject to Registration Service Fee 

Dear Registrant: 

The Office of Pesticide Programs has received your application for registration. If you 

submitted data with this application, the results of the PRN-86-5 screen will be communicated 

separately. During the administrative screen, the Office of Pesticide Programs has determined 

that this Action is subject to a Pesticide Registration Service Fee as defined in the Pesticide 

Registration Improvement Act. 

The Action has been identified as Action Code: R300 

NEW PRODUCT;ME-TOO PRODUCT FAST TRACK; 

The fee associated with this action is $ 1,434. Payment in the amount of $ 1,201.75 has 

been received. Please remit additional payment in the amount of $ 232.25. Although the 

transmittal indicated that small business fee waiver documentation was included we found 

no evidence of such documenatation. 
40

By USPS: 

USEPA Washington Finance Center 

Pesticide Registration Service Fee PO Box 979074 

S1. Louis, MO 63197-9000 

By Courier: 

U.S. Bank 

Government Lockbox 979074 

1005 Convention Plaza 

SL-MO-C2-GL 

S1. Louis, MO 63197 

Telephone: (412) 236-2294 

All payments must be in United States currency by check, bank draft, or money order 

drawn to the order of the Environmental Protection Agency. To ensure proper credit, please 

write the OPP DECISION NUMBER on your check, and enclose a copy of this letter with your 

payment. 

Effective November 1, 2006, fees may be paid on-line via credit card or electronic fund 

transfer. To submit a payment on-line, visit www.pay.gov. From the pay.gov home page, select 

"search by fann name." From the next page, select "P," then click on "Pesticide Registration 

Improvement Act Fee Payment" and complete the [onn, making certain to use the decision 

number and registration number on the invoice you receive from the Pesticide Program in the 

space provided. 

You may be eligible for a partial vvaiver of the registration service fee if, for example, you 

qualify as a small business or are applying for a minor use, or if your application is solely 

associated with an IR-4 tolerance petition. Please be advised that if you intend to request a 

waiver, you must do so in writing within 15 days of receipt of this invoice instead of remitting 

the amount indicated above. OPP will not consider waiver requests after the registration service 

fee has been paid. Infonnation regarding eligibility and how th request and document a fee 

waiver is available on the OPP Fee for Service web site at www.epa.gov/pesticides/fees. 

Please send Registration Service Fee Waiver requests to: 

By USPS: 

Document Processing Desk (WAIVER) 

Office of Pesticide Programs (7504C) 

U.S. Environmental Protection Agency 

1200 Pennsylvania Ave NW 

Washington, DC 20460 

By Courier: 

Document Processing Desk (WAIVER) 

Office ofpesticide Programs (7504C) 

U.S. Environmental Protection Agency 

Room S4900 Potomac Yard I 

2777 S. Crystal Dr. 

Arlington, VA 22202 
41

A PRIA decision time review period will not start until a fee waiver is granted and/or the 

Agency receives certification that the outstanding fee has been paid. If the Agency does not 

receive certification of payment for this action or a fee waiver request within the next 14 days, 

the Agency will presume that you no longer want to pursue this action. The Agency will then 

reject your application and issue an invoice for any applicable outstanding fees. 

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

Ombudsman at (703) 308-9362. 

Sincerely, 

Frol)l.Ency ro~sjng: taff -L-

)"fo77TeChn ogy & Resources Management Division 

/! / 

v/ 
42

IFee for Servicel 

f 

{890694KThis package includes the following 

I @ New Registration 

i ° Amendment. 

I ~ Studies? Gi'Fee Waiver? 

I D volpay % Reduction: '15 

, I for Division 

°AD 

°BPPD 

Risk Mgr. 

Receipt No. s-I 890694 

:===== 

EPA File Symbol/Reg. No. :=1 =86=0=0=8-=R= 

Pin-Punch Date: 1 2/17/2011 

D This item is NOT subject to FFS action. 

Action Code: I r'p~-a-re-n-tlC-h i-Id-D-e-c-is-io-n-s-: ! 

Req"e,ted ''''0,0 ~ I ,,~'~~t>"'" I 

Granted: I R~9r~,t~fil~ '1)/1 1/1 i 

Amount Due: $ I L{ 3Lf / [111 r fJ I 

L-___________________ I~--------

Uncleared Inert in Product 

Date: c5! /Ol4/ 11 
43
44

) 

FEE FOR SERVICE 
45

, , j ) 

PYX1S REu'ULATORY CONSULTING, INC. 

411 0 136th st. NW 

Gig Harbor, WA 98332 

OVERNIGHT DELIVERY 

So Davis (PM 25) 

Document Processing Desk (REGFEE) 

Office of Pesticide Programs (7504P) 

U.S. Environmental Protection Agency 

Room S-4900, One Potomac Yard 

2777 S. Crystal Drive 

Arlington, VA 22202 

RE: Forerock, LLC 

Imazapyr Technical (EPA File Symbol 86008-

Application for New Pesticide Registration 

PRIA Category R31 0 

Dear Mr. Davis, 

February 14,2011 

) 

Phone: 253-853-7369 

Fax: 253-853-5516 

www.PyxisRC.com 

On behalf of Forerock, LLC, we are submitting an application for registration of Imazapyr Technical. In 

support of this application, we submit the following documents: 

1. Application for a New Pesticide Registration CEPA Form 8570-1) 

2. Confidential Statement of Fonnula (EPA Form 8570-4) 

3. Three (3) Copies of the Proposed Labeling 

4. A CD containing an electronic version of the label 

5. Certification with Respect to Label Integrity 

6. Agency Internal Use Copy of the Data Matrix 

7. Public File Copy of the Data Matrix 

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

9. Documentation of Small Business for 75% PRIA fee reduction 

10. Copy of the PRIA payment from pay.goy 

II. Letter of Authorization 

12. Product Specific Data (3 copies each): 

Volume I 830.1550,830.1600, 

830.1620,830.1670, 

830.1750,830.1800 

Volume 2 830.1700,830.1800 

Volume 3 830.6302,830.6303, 

830.6304, 830.6313, 

830.7000,830.7050, 

830.7200,830.7300 

Tillman, A.M. Product Identity and Composition, Description 

of the Materials Used, Description of the Production Process, 

Discussion of the Fonnation of Impurities, Certified Limits and 

Enforcement Analytical Method for Imazapyr Technical. 

Contains Confidential Business Information 

Sun, G. Preliminary Analysis ofImazapyr Technical Grade 

Active Ingredient. 

I~fonnation 

Contains Confidential Business 

Sun, G. Imazapyr Technical Grade Active Ingredient Physical 

and Chemical Characteristics. 
46

Volume 4 830.6314,830.6315, 

830.6316,830.6317, 

830.6319,830.6320, 

830.6321,830.7100, 

830.7220,830.7370, 

830.7520,830.7550-

7570,830.7840-

7860,830.7950 

B. Davis 

Feb. 14,2011 

Page 2 of2 

Tillman, A. M. Imazapyr Technical Waiver Requests for 

Certain Phys-Chem Properties. 

We would like to note that Forerock, LLC is using the cite-all method of support As per EPA's 

interpretations of 40 CFR Parts 152.86(b)(2)(i) and 152.93(b)(Z)(i), Forerock, LLC submitted notices of 

intent to apply and offers to pay to all companies on the September 30, 2010 Data Submitter's List. This 

action falls under Category R310 (46: New manufacturing use product) because it is an application for 

registration of a new manufacturing use product which is substantially similar to a currently registered 

product. The PRIA fee normally due is $4,807 but F orerock LLC is SUbmitting documentation for a small 

business fee reduction of75% to $1,201.75. This fee has been paid. This action has a decision time line 

of6 months. 

We trust you will find this application complete. However, please feel free to contact me by email at 

Ann@PyxisRC.com or by phone at (Z53) 853-7369 if you have any questions or need any additional 

information. 

Sincerely, 

Ann M. Tillman 

Enclosures 

cc: Ingrid Wang, Forerock, LLC 
47

Sarah Greubel 

From: 

Sent: 

To: 

Subject: 

paygovadmin@mail.doc.twai.gov 

Tuesday, February 1S, 201110:08AM 

Sarah Greubel 

Pay.Gov Payment Confirmation 

THIS IS AN AUTOMATED MESSAGE. PLEASE DO NOT REPLY. 

Your transaction has been successfully completed. 

Transaction Summary 

Application Name: PRIA Service Fees 

Pay.gov Tracking ID: 252JF8P4 

Agency Tracking 10: 74175718181 

Account Holder Name: Ingrid Yin Wang 

Transaction Type: Sale 

Transaction Amount: $1)281.75 

Billing Address: 

Billing Address 2: 

City: Houston 

State/Province: TX 

Zip/Postal Code: 77024 

Country: U5A 

Card Type: Master Card 

Card Number: ************8514 

Transaction Date: Feb 1S) 2011 1:08:16 PM 

Decision Number: 

Registration Number: 

Company Name: Forerock llC 

Company Number: 86808 

Action Code: R318 

1 

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*Personal privacy information*
48

R 300 and 301 

100% identical (repack): --:;-,Y~Ej;S~O~rrt~ict~c~irc~l~etO~n~e~ {If yes, it's a 100% repack - then ct chemistry, acute toxicity and efficacy data 

are not required} 

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

Data 

Guideline Group A: Product Chemistry Data 

submitted 

No. Study Title Yes No 

830,1550 Product Identity & Composition ;y 

Description of materials used to produce the 

.y 830.1600 product 

830.1650 Descriotion of formulation process X 

830,1670 Discussion on the formation of impurities X830,1700 Preliminarvanalysis ~ 

830.1750 Certified limits (158.345) X 

830.1800 Enforcement anatvtical method >< 

Data 

Guideline Group B: Product Chemistry Data submitted 

No. Study Title Yes No 

830.6302 Calor .l( 

830,6303 Physical state >( 

830,6304 Odor >\ 

Oxidation/Reduction (Chemical 

830.6314 X incompatibifJly) 

830.6315 Flammability x 

830,6316 Explodability ->\ 

830,6317 storaQe stability x:: 

830,6319 Miscibility X 

830.6320 Corrosion Characteristics X. 

830.6321 Dielectric Breakdown voltaae X 

830.7000 pH X 

830.7100 Viscosity X 

830.7300 Density X 

1 
49

R 300 and 301 

New products must provide a bridging rationale document. The bridging document 

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

of submitting product specific data. 

Guideline Acute toxicity (6 pack) Cited 

No. Study Tille Yes No 

870.1100 Acute Oral (LD50) X 

870.1200 Acute Dermal (LD50) X 

870.1300 Acute Inhalation (LC50) )( 

870.2400 Acute Eye Irritation ~ 

870.2500 Acute Dermal Irritation x: 

870.2600 Dermal Sensitization -< 

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

data to be used for the bridging rationale. 

Guideline Cited 

No. Efficacv Study Tilles Yes No Comments 

810.3100 Soil Treatments for Imported Fire Ants 

Livestock Poultry, Fur and Wool-Bearing " 810.3200 Animal Treatments \ 

Treatments to Control Pests of Humans 

and 

810.3300 Pets X 

Mosquito. Black Fly, and Biting Midge 

810,3400 I (Sand Flv) Treatments X 

810.3500 Premises Treatments X 

810.3600 Structural Treatments \( 

Methods for Efficacy Testing of Termite ;< 810.3800 Baits 

2 
50

Certification with Respect to Label Integrity 

version: 9111/02 

I certify that the information (including, but not limited to, text, tables, and graphics) 

contained in the electronic file identified below by file name and submitted with this 

certification is the same infonnation as that on the paper copies of these documents 

included with this submission. 

IPROPOSED LABEL 

Date Submitted 

EPA Registration # to EPA Electronic file name 

086008-000xx Feb. 14, 2011 086008-000xx.2011 0214.lmazapyr Technical 

label v1.pdf 

I certify that the statements that I have made on this form are true, accurate, and 

complete. I acknowledge that any knowingly false or misleading statements may be 

punishable by fine or imprisonment or both under applicable law. 

Signature 

Ann M. Tillman 

Agent, Forerock, LLC 

Feb. 14,2011 

Date 

-' , " - . 

", , 

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.. 
51

Form APproved OMS No. 207O-QOOO 

UNITED STATES ENViRONMENTAL PROTECTION AGENCY 

401 M street, S,W. 

WASHINGTON, D.C. 20460 

Paperwork Reduction Act Notice: The public reporting blNden forthis collection oftnformatl<ln is estimated to average t.2~ houJ"$ per response ferreglstraHon 

and 0.25 hours per response ferreregistration and speciat review acliYflies, including time fer reading the instructions and completing the necessary ferms. send 

comment6 regarding burden estimate or any other aspect of this coUection ofinforma~on, tnduolng suggestions for reducing the burd"en to: Director, OPPE 

Infonnation Managoment Diviston (2t37), U.S. Environmental Protection Agency, 401 M Street. S.w., Washington. DC 2Q.4.60. 

Do not send the compteted form to this address. 

Certification with Respect to Citation of Data 

ApPilcant'slRl!lllstranfs Name, Address. and Telephone Number EPA ReAistl"l!tion Number/FUe Svmbol 

rcrmock, LLC clo Pyxis RellulaloryConsulting 41 ro t361h Sl. NW Gill Harbor, WA 98332 t253-a53-7369) 86008-

Aclive tnqredi/lnlfs) andlor representative test comOoundts) 

tmaupyr 

Date 

General Use Pattern,s) (list all those daimed for !hiS product usinA 40 CFR Part 151.1t 

Terrestrial and Aquatic FOodlfeed crop·,Terrestrial Noncrop 

Product Name 

ImaZilpyr Technical 

NC'TE; If your product is a 100% rep~cl(aglng of another purchased EPA-registemd product labeled for all the same uses on your label, you do not need to 

subm~ this form. You must submit the Formulator'S Exempllon Statemont (EPA Form 8570-27). 

o 

o 

t am responding to a Data-Call-tn Notice, and have indlKled with this form a list of companies sent offers of compensation ,the Data Mallix form should 

be used for this purpose). 

SEcnON t: METHOD OF DATA SUPPORT (Check one method only) 

I am using tha cite-all method ohupport, and have included with this form 

a list of companlos sen! offers of compensation (the Data Matrix form 

should be used for this purpose). 

I am using the selective method ot support (or clte-all option 

under the sotective method), and have indllded wfth this form a 

completed list of data requirements (tho Data Matrix fonn ml.l$t be 

used). 

SECTION II: GENERAL OFFER TO PAY 

[Required If using the cite-ali method or when using the cite-all opHon under the selective method to satisfy one or more data requlrementsi 

0·· t hereby offer alld agree to pay compensa~on. to other persons. with regard to the approval of thIS ~pplicaHon, to tho extent required by FIFRA. 

SECTtON ttl: CERTIFICATION 

I certffy that this application for I"e\llstraUon, this form forrereglstra~on, or thiS Data-Call-tn response Is supported by all data submFtted or cited In the 

application for reglstratton, the form for reregistration, or the Data-CalHn response. In addition, If the cite-all option or dte-all option under the selective method ts 

indicated In Section I, thiS application Is supported by all data in the Agency·s files that (t) concern the properties or effects ofthfs product or an lden~cal or 

substantially similar product, orone or more of the ingredients in this product; and (2) is a type of data that would be required to be submitted underth6 data 

requirements in effect on the date of approval of this application If the application sought the Initial registration of a product of ldenijcal or similar composition and 

···'..es. 

I certify that for each exclusive use study cited In support of this registration or reregistration, that t am the origlnat data sUbmltler or that t have obtained 

the wrtti.en permission of the original data submitter to cle that study. , , , , 

•• > • I certify that for each study citad in support of this registraHon or rel"e\listration that Is not an exdusive use study, either: (a) I am the Oriqinal data 

submitter; (b) I have obtained tho permission of the originat data submitter to lise tho study in sUPport ofth·ls application; (c) all periods of erlglbirrtg ib~ , 

compensation have expired for tho stlldy; (d) the study is in tho public titerature; or (e) I have notified in wli~ng the company that submitted the 5tlitly amlrhaw 

oll"ere" (I) to pay compensation to the oxtont required hy sections 3(c)(I)(F} andlor3(c)(2)(B) of FtFRA; and (~) to commence n?SoYations to doterrni~ tho 

amount and terms of compellSation, if any, to be paid for the use of the study. ; > , , 

, • > , , , 

t certify that tn all instances where an offer of compensation is required, copIDs of all offers to pay compensation and Wio1en~;of thetr30livery in 

ace< rdanco wHh sections 3(c)(t)(F) and/or3(c)(2)(S) of FIFRA are available and will be submitted to the Agency upon request. ShC'J:d t fail to ~,d~ce s~ch 

flvid nCl.! to theAgoncy upon request, I understand that the Agency may Initiate action to deny, cancet or suspend the reglstrati?'J .,fJllY product in COlffonhitywith 

FIF~. ' •• , , 

t cortlfy that tho statemonts I have made on this form and att attachments to It are true, accurato. and cornploto. 

tngly faIM or mlstoadtng statement may bO puntshablo by fine or tmprlsonment or both under applicable taw. 

t acknowloogo tt.at any , • > , > , 

, 

r ,. > 

Sig ture Typed or Printod Name and TIIlo 

Ann M. Tillman, Agent 

, 

EPAF 1ffi1 8570-34 (9-97) ElectroniC and Paper versiOns ava·llable. Submit onty Paper version. 
52

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 

401 M Street, S.W. 

WASHINGTON, D.C. 20460 

Paperwork Reduction Act Notice: The public reporting burden for this collection of informalion is estimated to average 0-25 hours per response for registration activities and 0.2

reregislralion and special review aclivities, including time for reading the inslruclions and completing the necessary forms. Send comments regard·flg the burden esl"lmate or any 

information, induding suggeslions for reducing the burden to: Oirector, OPPE Information Managemenl Oivision (2137), U.S. Environmenlal Protection Agency, 401 M S.W

send the form to this address. 

DATA MATRIX 

Date February 14, 2011 EPA Reg. No.lFile Symbol 86008- 

Applicant'sJRegistrant's Name & Address Producl 

Forerock, LLC Imazapyr Technical 

6648 Buffalo Speedway 

Houston, TX 77005 

Ingredient Imazapyr (CAS No. 81334-34·1) 

Guideline Reference Number Guidel"lne Study Name MRID Number Submitter 

Product Specific Data Requirements 

830.1550 Product !dentity and Composition Volume 1 Forerock, LLC 830.1600 Description of Materia!s Used to Produce the Volume 1 Forerock, LLC 

Product 

830.1620 Description of Production Process Volume 1 Forerock, LLC 

830.1650 Description of Formulation Process 

830.1670 Discussion of Formation of Impurities Volume 1 Forerock, LLC 830.1700 Preliminary Analysis Volume 2 Forerock, LLC 830.1750 Certified Limits Volume 1 Forerock, LLC 830.1800 Enforcement Analytical Method Volume 1 Forerock, LLC 

Volume 2 

830.6302 Color Volume 3 Forerock, LLC 

830.6303 Physical State Volume 3 Forerock, LLC 830.6304 .odor Volume 3 Forerock, LLC 

u <-

830.6313 to )'tormal and Elevated Temperatures, Volume 3 Forerock, LLC 

\\1etal Ions 

830.6314 Oxidation/Reduction: ChemicallncorTlpatibility Volume 4 Forerock, LLC 

830.6315 Flarr;'milanj!y Volume 4 Forerock, LLC 

Signature ,. : "' :" : '" : : Name and TiHe 

AnnM. Tillman,Consu!tant 

... 

-- -

EPA Form 8570-35 (9-97) Electronic and Paper versions available. Submit only Paper version. Agency I
53

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 

401 M Street, S.W. 

WASHINGTON, D.C. 20460 

Paperwork Reduction Act N01ice: The public reporting burden for this conection of information is eslimated 10 average 0.25 hours per response for registration activities and 0.2

reregistration and special review acli'Jities. including time for reading the instructions and compleling the necessary forms. Send commenls regarding the burden estimale or any o

information. including suggestions for reducing Ihe burden to: Oirector. OPPE Information Management Division (2137), U.S. Environmental Protection Agency, 401 M Street, S.W

send tile form to this address. 

DATA MATRIX 

Oate February 14, 2011 EPA Reg. No.lFite Symbol 86008· 

Applicant'slRegistrant's Name & Address Producl 

Forerock, LLC Imazapyr Technical 6648 Buffalo Speedway 

Houston, TX 77005 

In(lredient Imazaovr (CAS No. 81334-34-1 

Guideline Reference Number Gu'ldeline Siudy Name MRID Number Submitter 

830.6316 EXRlodability Volume 4 Forerock, LLC 830.6317 Storaae Stabill!Y.. Volume 4 Forerock, LLC 

830.6319 Miscibilitv 

830.6320 Corrosion Characteristics Volume 4 Forerock, LLC 

830.6321 Dielectric Breakdown Voltage 830.7000 I pH Volume 3 Forerock, LLC 

830.7050 UVNisible Absorption Volume 3 Forerock, LLC 

830.7100 Viscosity_ 830.7200 MeltinQ PointiMeltinQ RanQe Volume 3 Forerock, LLC 

830.7220 Boilinq PointiBoilinQ RanQe 

830.7300 Density/Relative Density/Bulk Density Volume 3 Forerock, LLC 830.7370 DissOCiation Constants in Water Volume 4 Forerock, LLC 830.7520 Particle size, fiber le!lgth, diameter distribution 830.7550 Partition COeffICient (n-octanol/water), Shake 

!fJQsk Metl4-J't:! 

Volume 4 Forerock, LLC 

830.7560 Partitibh ebefflcient (n-octanol/water), 

Generator Column Method 

830.7570 P nol/water), 

· · · · ,EstirllatiDn by tiquid ·Ghromato9raphy · · . .. w Signature · · . . . Name and Title 

Ann M. Tillman. Consultant 

EPA Form 8570-35 (9-97) Electronic and Paper velSions avaitable. Slbmit only Paper version. Agency In
54

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 

401 M Street, S.W. 

WASHINGTON, D.C. 20460 

Papetwork Reduction Act NoUce: The public reporting burden for this collection of infonna\ion is estimaled to average 0.25 hours per responSe for registration activities and 0.2

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

infonnation, inctuding suggestions for reducing the burden to: Director, OPPE Infonnation Management Oivision (2137), U.S. Environmentat Protection Agency, 401 M Street, SW

send the fonn to this address. 

DATA MATRIX 

Oale February 14, 2011 

Applicanl'sJRegistranl's Name & Address 

tngredient tmazapyr(CAS No. 81334·34-t\ 

Forerock, LLC 

6648 Buffalo Speedway 

Houston, TX 77005 

Guideline Reference Nvmber Guidetine Study Name 

830.7840 830.7860 830.7950 870.1100 

870.1200 870.1300 

870.2400 870.2500 

870.2600 

Water Solubtllty: Column Elution Method; 

Shake Flask Method 

Water Solubility, Generator Column Method 

VaDor Pressure 

Acute Oral Toxicitv: Rat 

Acute Dermal Toxicity: Rat 

Acute Inhalation Toxicitv: Rat 

Primarv Eve Irritation: Rabbit 

Primarv Dermal Irritation 

Dermal Sensitization 

Imazapyr Generic Data Requirements 

EPA Reg. NoJFile Symbol 86008- 

Product 

Imazapyr Technical 

MRtDNumber Submiller 

Volume 4 Forerock, LLC Volume 4 Forerock, LLC 

Cite-All Cite-All 

Cite-All 

Crre-AII 

Crre·AII 

Cite-All 

Forerock LLC will make to companies on the Sept. 30, 

2010 Data Submitters List for I I ! 

" , - " Cite-All Nufarm Americas, Inc. 

. " '1'1 , 

Signature " . 

EPA Fonn 8570·35 (9-97) Electronic and Paper vers'lons available. Submit only Paper version. 

Cite·AII I BASF COrp. I 

Cite-All E. I. DuPont de Nemours and 1 

Co. Inc. 

Name and Title 

Ann M. Tillman, Consultant 

Agency In
55

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 

401 M Street, S.W. 

WASHINGTON, D.C. 20460 

Paperwork Reduction Act Notice: The public reporting burden for this collection of information is eslimated 10 average 0.25 hours per response for regislration aclivilies and 0.2

reregis/ranon and special review adivines, induding lime for reading Ihe instructions and the necessary forms. Send comments regarding the burden estimale or any 

information, including suggeslions for reducing the burden 10: Direclor, OPPE Information Management Division {2137), U.S. Environmental Proleclion Agency. 401 M Street, S.W 

send the form to this address. 

DATA MATRIX 

Dale Februarv 14, 2011 EPA Reg. NO.lFile Symbol 86008· 

Applicanl'slRegislran!'s Name & Address Product 

Forerock, LLC Imazapyr Technical 6648 Buffalo Speedway Houston, TX 77005 

Inoredient Imazaov-;:(CAS No. 81334-34-nGUideline Reference Number Guiderme StUd" Name MRIDNumber Submiller 

Cite-All PSI/Gordon Corp. Cite-All BASF Corp. Cite-All Aoan Chem Mfo Ltd Cite-All Nufarm Limited 

Cite-All Sorav Drift Task Force 

Cheminova, Inc. 

Cite-All United Phosphorus, Inc. 

Cite-All Outdoor Residential 

Exposure Task Force, LLC 

Cite-All Agricultural Reentry Task 

Force 

Cite-All FI FRA Endangered Spec·les 

Task Force LLC 

Cite-Ali Veaetation Manaaement LLC 

· • , . · Cite-All Agricultural Handlers 

--. " · 

Exposure Task Force · , . .. , .. . 

. _" · 

Cite-All Gro-Pro LLC 

" ... Cite-All Etiqra LLC 

Sigmture , , . . . . . , . , . . . Name and TiUe 

, 

, • · . , · , . . Ann M. Tillman, Consultant 

-- , .. ow" " , '" , . , 

EPA Form 8570-35 (9-97) Eleclronic and Paper versions available. Submil only Paper version. Agency I
56

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 

401 M Street, S.W. 

WASHINGTON, D.C. 20460 

Paperwork Reduction Act Notice: The public reporting bUrden for this collection of information is eslimaled to average 0.25 hours per response for registration aclivilies and 0.2

reregistration and special review activities, including time for read"mg the instructions and completing the necessary forms. Send comments regarding the burden eslimale or any o

information. includin9 suggestions for reducing the burden to: Oireclor. OPPE Informalion Managemenl Division (2 f37), U.S. Environmental Protection Agency, 401 M Sireet, S.W

send the form to this address. 

DATA MATRIX 

Date February 14, 2011 EPA Reg. NO.lFile Symbol 86008- 

Applicant'sfRegistrant's Name & Address Product 

Forerock, LLC Imazapyr Technical 

6648 Buffalo Speedway 

Houston, TX 77005 

If!ll..I:.edient Imazaovr CAS No. 81334-34-1 

Guideline Reference Number Guideline Siudy Name MRIO Number Submitter 

Cite-All Generic Endangered Species 

Task Force 

Cite-All AmTide, LLC 

Signature Name and TiUe 

Ann M. Tillman, Consultant 

- - - - - - _ .... _ .. _---

-., 

EPA Fonn 8570-35 (9·97) Eleclronic and Paper versions available. Submit only Paper version. Agency In
57

Endnotes for Data Matrix for Imazapyr Technical 

1830.1650. These data are not required for the registration of a technical product. See 830,1620 for 

production process information. 

2 830.6314 • Forerock, LLC requests a waiver from the requirement for determination of chemical 

incompatibility (oxidation/reduction) for Imazapyr Technical since Imazapyr Technical does not contain 

any material that would be considered an oxidizing or reducing agent (please refer to the Confidential 

Statement of Formula). Imazapyr Technical is not expected to react with common oxidizing or reducing 

agents although the MSDS for this product indicates it can react with strong oxidizers. However, the 

MSDS indicates that water spray, foam, carbon dioxide, and dry extinguishing media can be used as 

appropriate fire·fighting materials for Imazapyr Technical. 

3 830.6315 • Forerock, LLC requests a waiver from the requirement of this data requirement since 

ImazapyrTechnical is a solid and does not contain any ingred'lents that are flammable. Please refer to 

the Confidential Statement of Formula for Imazapyr Technical. 

4 830.6316 _ Forerock, LLC requests a waiver from this data requirement because imazapyr does not 

have the chemical bonds or fUnctional groups associated with explosive chemicals. 

5 830.6317, 830.6320 • Per PR Notice 92·5, storage stability and corrosion characteristics data are not 

required to be submitted unless specifically requested by the Agency. Forerock, LLC agrees to 

conduct these studies if required as a condition of registration. 

s 830.6319, 830.7100 _ Miscibility data are required when the product is an emulsifiable liquid and to be 

diluted with petroleum solvents. Viscosity data are required if the product is a liquid. Imazapyr 

Technical is a solid technical material and therefore these data requirements are not applicable. 

7830.6321 _ These data are required if the product 'IS an end-use product. This data requirement is not 

applicable to Imazapyr Technical. 

8830.7220 _ This data requirement is not applicable to Imazapyr Technical because it is a solid. Refer to 

guideline 830.7200 for melting point data. 

9830.7520 _ Forerock, LLC is seeking a waiver for this data requirement fOr Imazapyr Technical because 

the product is not a fibrous material. 

) , " , , ) , " , ~ , > 

, , , , , , , , , > } 

, " 

Page 1 of 1 
58

Forerock LLC 

6648 Buffalo Speedway, Houston, TX 77005-3833, USA 

Pho//e: (832) ~58-6888 (( ::",', . 

.I~lII)1tlr) JO. :!O! I 

Tu W!WIll II MUJ' ('(1I1CO;:I'I): 

Deal" Sir or M,ldwll' 

P!~~s~ ICllhis fwa sert'e 10 c(mfi)"1)) IIIlII Py\i~ Ih'~III,II(lI'Y CllIISlilliIlY .. Jnc i~ mllhoril.Cu It) Hel a~ 

<1",':111 Jill" F(lI"cl1)cf>. !J.e !J:!'j\ t"I1I)1(11)I);> Nlllllhcr 1$6JlIlI$. Jwlim.! Ih.: liS J':I)\'inllllll~'nl;1] 

Prnll'cliol) i\~Clll'! amJ stale gllvl'rnillclll:iI jlg~'IKie~ ill all 11I11l1<:r, r~'y;lrdill;! 1Ilir p~sli..:iJ,· 

r~'gistnlli\lns pUf'illanl ttl Ihe h'ucml JII~Cllicit!c. J"IIIIi!ICitic iIIlJ I{odcllli~'idc "')el (HFJI'j{A"J. -, 

U.S,c. * 13(J cl SCI!. ,1Il1l Sl<lIe Ill)\". 

II' ylll) !Iave mry qllcsi iOIlS, picasI..' dn 111>1 J)csilal~' 111 l1l1)1i)1,:1 IIll', 

Sincerely. 

Sincerely. 

OllieI..' Mantlgcr , ; , " , , 

)'" } 

" , " ) 

, , , . , , , . '-

, 

" 

, , , , , , , 

, , 

" 

"", , , 

), " 
59

') 

PYXIS lllio'ULATORY CONSULTING, INC 

4110 136th St. NW 

Gig Harbor, WA 98332 

OVERNIGHT DELIVERY 

Bo Davis (PM 25) 

Document Processing Desk (REGFEE) 

Office of Pesticide Programs (7504P) 

U.S. Environmental Protection Agency 

Room S-4900, One Potomac Yard 

2777 S. Crystal Drive 

Arlington, VA 22202 

RE: Forerock, LLC 

Imazapyr Technical (EPA File Symbol 86008-

Application for New Pesticide Registration 

PRIA Category R31 ° 

Dear Mr. Davis, 

February 14,2011 

) 

Phone: 253-853-7369 

Fax; 253-853-5516 

www.PyxisRC.com 

On behalf of Forerock, LLC, we are submitting an application for registration of Imazapyr Technical. In 

support of this application, we submit the following documents: 

1. Application for a New Pesticide Registration (EPA Form 8570-1) 

2. Confidential Statement of Formula (EPA Form 8570-4) 

3. Three (3) Copies of the Proposed Labeling 

4. A CD containing an electronic version of the label 

5. Certification with Respect to Label Integrity 

6. Agency Internal Use Copy of the Data Matrix 

7. Public File Copy of the Data Matrix 

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

9. Documentation of Small Business for 75% PRlA fee reduction 

10. Copy of the PRlA payment from pay.gov 

11. Letter of Authorization 

12. Product Specific Data (3 copies each); 

Volume I 830.1550,830.1600, Tillman, A.M. Product Identity and Composition, Description 

830.1620,830.1670, of the Materials Used, Description of the Production Process, 

830.1750, 830.1800 Discussion of the Fonnation oflmpurities, Certified Limits and 

Enforcement Analytical Method for Imazapyr Technical. 

Contains Confidential Business Information 

Volume 2 830.1700,830.1800 Sun, G. Preliminary Analysis oflmazapyr Technical Grade 

Active Ingredient Contains Confidential Business 

Information 

Volume 3 830.6302,830.6303, Sun, G. Imazapyr Technical Grade Active Ingredient Physical 

830.6304, 830.6313, and Chemical Characteristics. 

830.7000,830.7050, 

830.7200, 830.7300 
60

Volume 4 830.6314,830.6315, 

830.6316, 830.6317, 

830.6319.830.6320, 

830.6321,830.7100, 

830.7220,830.7370, 

830.7520,830.7550-

7570,830.7840-

7860 830.7950 

B. Davis 

Feb. 14,2011 

Page 2 of2 

Tillman, A. M. Imazapyr Technical Waiver Requests for 

Certain Phys-Chem Properties. 

We would like to note that Forerock, LLC is using the cite-all method of support. As per EPA's 

interpretations of 40 CFR Parts 152.86(b)(2)(i) and 152.93(b)(2)(i), Forerock, LLC submitted notices of 

intent to apply and offers to pay to all companies on the September 30, 2010 Data Submitter's List. This 

action falls under Category R31 0 (46: New manufacturing use product) because it is an application for 

registration of a new manufacturing use product which is substantially similar to a currently registered 

product. The PRIA fee normally due is $4,807 but Forerock LLC is submitting documentation for a small 

business fee reduction of 75% to $1,201.75. This fee has been paid. This action has a decision time line 

of6 months. 

We trust you will find this application complete. However, please feel free to contact me by email at 

Ann@PyxisRC.com or by phone at (253) 853-7369 if you have any questions or need any additional 

information. 

Sincerely, 

Ann M. Tillman 

Enclosures 

cc: Ingrid Wang, Forerock, LLC 
61

". • l '" -. '" "" OM. 7 ' ,.". 

Unitod Stet .. § Registration opp Identifier NUmber 

a.EPA Environmental Protection Agency Amendment 

Wnhil1gton, DC 20460 Other 

Application for Pesticide - Section I 

1. Company/Ptoduct Numb" 2. EPA Product Menag., 3. Propoeod elu_ific,tlon 

86008 -If' B. Davis [2] None o R .. tricted , 4. Company!pro(1ucl INemel 

Forerock, llC Ilmazapyr Technical PM' 25 

S. Name and Addreu of Applioent (lncludfl ZIP Cod.} 6. ExpedIted Reveiw. In accotdance with FIFRA Section 3fclf3) 

Foretock, LlC fbHi), my ptoduct is similar at identical in composition and labeling 

c/o Pyxis Regulatory Consulting. Inc. to: 241-286 4110 136thSl. NW EPA Reg. No. 

Gia Hatbor. WA 98332 

, o Ch.ck if th;s Is. m~w ndd(fl$$ Product Name Arsenal Technical Herbicide 

Section - II 

0 Amendment - Exploin bllow. U Finll printed laball In roplonll to 

Aglney Ilttlr dated 

0 Rusubminion in rupon .. to Agency lutter dllted 0 ~Mu Too~ Application. 

0 Notificltion' Explein below. 0 Othor - Exploin bllow. 

Explanation: u~o additional pagals) if nocaullry. IFor section I and Soctlon 11.1 

This application falls under PRIA Category R310 (46: New product) because it is an applicalion for rl,lgislration of new manufacturing use producl which is 

substantially similar to a currently regislered product. The PRIA fee normally dul,l is $4,807 but Forerock llC is submitting documl,lnlalion for a small business 

lee reducl'lon of 75% 10 $1,201.75. This fee has been paid. This aclion has a decision time line of 6 months. 

Section - III 

1. Mat.rialThlll Product WdlBe Packagad In: ~ 

... ~ 

Child·Rusl,"nr Pllckaging Unit Packeging Watar Solubla Packaging 2. Typa of Container •••• 

t?] " [2]'" [1j V •• V •• QM ... ' ,,' , Plaatic ., • .f N. .f No No lira., ' : ' 

a CortifiCilt/on must 

If ~Yes~ Na. par If -Yaa~ No. por ?Ir' • gned Oberbcmrd dl"\Jm 

Unit Packaging wgt. container Packoga wgt contoiner • ~thH~!lpoCltyr; SJ~Nd\" btl submitted " i , " , " , 

3, lacation of Not Contlntl Information 4. Si~ar.) Retail Container ) 5. Locatian of Laba~Di~"C1ion. " 1 [{J Containor 16510 (75 kg) fJ-]onLobol ""'~>~' , Labal o~ Laliollng a<companylng "",du<t 

0 , 6. M!!lI"1ner in Which Lebilia Affixed ro Product ljUthogrePh Other ,~~~~. 

Paper p'lutd ~ 

Stand ltd , , 

Section - IV > •••• ~ 

, 

t. Contact Point fCCNTIpJflta itflfT\$ dirfICfJy bflJow fer idflntificlltrrm of indMrJl.I~ fO b. conhlctfld, ff naCfI$$M¥, to proCfU thI$IIpp!(ClItion./ 

Name TItle Telaphone No. !Include Ar .. Code) 

Ann M.·TilIman Agent (253) 853-7369 

Certification 6. Oeta Application 

I cortily that the 51lt1mantl I have modi on this form Ind ellettachment. tharoto a .. trua, accurllta end COmpletll. Recaivod 

I acknowlldga thlltllny knowlinglly 111118 or mllileodino stotlment may ba pun/,heble by rine or Imprisonment or 

both under opplicilblaillw. (Stamped) 

2. Signaturll 

~fkI~ 3. TItle 

Agent 

4. Typed Namo 5. Oota 

Ann M. TIllman 2/ I j~1 d-<J If 

.. EPA Form 8570-1 tRlllv. 3-94) ProV1oua edltlone 8r. obeoleta. Wh~ -EPA FIla Copy 1000ginal) -