EPA Reg. No. 7969-333

Vol. 3

(formerly 53263-28) 
e e C 

Material to be added to a Mini-Jacket 

(in the case where an e-Jacket exists) 

Reg. No. ~3Z-6 3 -- 2-'6 

Send to SIG: check box IS] 

This material is: 

~ New stamped-accepted label 

~ NewCSF 

D Notification 

D Final Printed Label 

o Other: --------------

Instructions: Attach this notice on top of the 

material. It must be clipped all together and 

there should be NO STAPLES in the material. 

Then give the material with this coversheet to 

staff in the Information Services Center (Room 

230). 

Reviewer's Name: Pit AJ bGv;t/Y 

Phone: 3 os-- 7sYG Division: 12-5) 

Date: s-/ njot> 

Current as of Tuesday, May 16, 2006 

1
UNITED ST4jES ENVIRONMENTAL PRO TION AGENCY 

Eliot I. Harrison 

Cognis Corporation 

c/o Lewis and Harrison 

122 C Street, NW, Suite 740 

Washington, DC 20001 

Dear Mr. Harrison: 

Subject: Revised Ingredient Statement 

AgniqueMMF 

MAR 1 5 2006 

EPA Registration No. 53263-28 

Your Submission Dated October 11, 2005 

The labeling referred to above, submitted in connection with registration under the Federal 

Insecticide, Fungicide, and Rodenticide Act, as amended, is acceptable. A stamped copy is enclosed 

for your records. Please submit one (1) final printed copy for the above mentioned label before 

releasing the product for shipment. 

Enclosure 

DK: 305-7546: IRBIPM01 

SYMBOL • 7505C 

SURNAHB • D. Kenny 

DATE • 3/15/06 

EPA Form 1320-1 (12-70) 

Sincerely yours, 

Daniel C. Kenny 

Product Manager (01) 

Insecticide-Rodenticide Branch 

Registration Division (7505C) 

CONClJRRENCES 

OFFICIAL FILE COPY 

2
AGNIQUE® MMF 

MOSQUITO LARVICIDE & PUPICIDE 

Monomolecular Surface Film for Control of Immature Mosquitoes and Midges 

ACTIVE INGREDIENT: 

Poly(oxy-1.2·ethanediyl). a-(C 1&-10 branched and linear alkyl) -ro-hydroxy- .. ...... ". 100% 

KEEP OUT OF REACH OF CHILDREN 

CAUTION 

See Back Panel for Additional Precautions and Product Information 

FIRST AID (TREATMENT) 

If ON SKIN : • Take off contaminated clothing. 

OR • Rinse skin immediately with plenty of water for 15-20 

CLOTHING: minutes. 

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

IF IN EYES: • Hold eye open and rinse slowly and gently with plenty of 

I water for 15-20 minutes. I 

I • Remove contact lenses, if present, after the first 5 j 

I minutes, then continue rinsing eye. 

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

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

cen!er or doctor, or going for treatment. 

EPA Reg. No, 53263-28 

Revised 3·13·06 

ACCEPTED 

MAR 1 5 2006 

under the Federal Insedidde. ~, and Rodenddde Ad. as aInended, foe the pestiddc 

Regi*red ODd« 

EPA Reg. No. 53 '2.' 3 ,. 2$ 

EPA Establishment No. ___ _ 

PRECAUTIONARY STATEMENTS 

HAZARDS TO HUMAN AND DOMESTIC ANIMALS 

CAUTION: Avoid contact with skin, eyes or clothing, Wash thoroughly with 

soap and water after handling, 

DIRECTIONS FOR USE 

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

its labeling. To be used in governmental mosquito control program, by 

professional pest control operators, by homeowners, or in other mosquito or 

midge control operations. 

APPLICATION DIRECTIONS 

This product may be applied by both ground and aerial applications, To use, 

calculate the desired rate based on water surface area. The water depth is not a 

a factor in rate determination. Spray the desired rate of AGNIQUeC' MMF onto ,., 

the surface of the water. No dilution is required and a fan spray is 

recommended . The MMF will spread to cover hard to access areas, For large 

areas with dense vegetation it is recommended that application is made in 

several locations to assist in the spreading action, Do not pour or inject a 

stream spray directly into water. AGNIQU~ MMF is not visible on the surface 

of the water. Excess MMF on the water surface will form a white globule. 

APPLICATION sITes 

This product is for the control of immature mosquitoes and midges in areas 

where they breed and develop. This product may be used in habitats including 

potable water and irrigation waters, permanent and semi-permanent waters, 

irrigated croplands and pastures, and waters with outlets to narural water 

bodies. The following habitats provide examples of where the product can be 

applied but is not intended to be all inclusive. 

Fresh and Brackish Water: fresh water and salt marshes, (containerized] ponds, 

lakes, stonn water, drainage systems and retention & detention basins, roadside 

ditches, grassy swales, flooded fields and pastures, potable water containers, 

reservoirs, irrigated croplands, temporary and semi-permanent woodland pools, tidal 

water, and other areas where water accumulates, 

Residential Areas: [Containerized] ponds, storm water basins. tree holes, rain 

barrels, landscape and ornamental ponds, tires, storm drains, stationary flower pots, 

pot holes, gutters, tarps, potable water containers and residential areas where water 

accumulates and provides ideal breeding habitats for mosquitoes or midges, Not for 

Homeowner U.e in the State of New York. 

Polluted Waters: Sewage lagoons, percolation ponds, animal waste effluent 

lagoons. septic ditches, waste treatment facility areas, etc, 

Page 1 of 3 

e 

3
MOSQUITO HABITAT 

Fresh and Brackish Water* 

Polluted Waters" 

MIDGE HABITAT ested Rate Ra eA 

Fresh and Polluted Waters 0.5-1 .0 gallons/acre (5 - 10 literlhectare) 

• The lower rate (0.2 gallons/acre) is recommended when only pupae control is 

desired and in sites with no emergent vegetation and low organic content 

• Use higher rates when emergent or surface vegetation Is present. due to the 

wicldng action of the product. The more vegetation or the drier the vegetation. the 

higher the required rate. 

... Use higher rates in polluted water habitats for effective control 

"Rea lication is recommended eve _two ~eJcs durilg the midge season 

{Note to Review: the following use diAK:tions will be provided on product marl(eted to commercial 

and institutional users.} 

APPLICATION NOTES 

Rate of Kill: The rate of kill when using MMF is dependent on the species, the 

life stage, the habitat and the temperature. Pupicidal action will typically result 

in 24 hours. Larvicidal action will usually result in 24-96 hours. If the film is 

present, as indicated by the indicator oil, control will be achieved. 

Indicator Oil: AGNIQUee MMF is not visible on the surface of the water. To 

check the habitat for the presence and persistence of the product, add a drop 

of AGNIQUE® MMF Indicator Oil to several locations in the habitat. If the 

Indicator Oil forms a tight bead on the surface of the water, then the MMF is 

present tor control. 

Persistence: The AGNIQU~ MMF surface film typically persiSts on the 

water's surface for 5 to 22 days. Polluted waters will cause more rapid 

degradation of the film. Higher application rates will prolong film life and extend 

the interval between retreatment. 

Species: Mosquitoes and midges that require little or no surfaca contact for 

breathing will be affected by the product during the pupae and emerging adult 

life stages. 

Wind: The high end of the dosage rate is recommended when spraying 

habitats where multi-directional winds of 10mph (16kmlhr) or greater are 

expected to persist. While the film will be pushed by the winds, it will re-spread 

quickly once the winds have subsided. If persistent unidirectional winds of 10 

mph (16kmJhr) or greater are expected, the displacement of the surface film 

may result in poor control. 

Spray Tanks: Thoroughly clean and dry the spray system of contaminants 

such as petroleum oils, water, detergents and conventional toxicants prior to 

adding AGNIQU~ MMF. Detergents will destroy the film-forming of the 

AGNIQU~ MMF; other contaminants (water and oil) can result in the 

formation of an unsprayable paste. 

Dilution: AGNIQU~ MMF is typically applied to the water's surface without 

dilution. However, if it is desired to spray higher volumes of liqUid. AGNIQUr:-

Revised 10 11~5 

MMF may be diluted using a high shear injection system that dilutes the MMF 

at the nozzle to a maximum of 10% in water. Do not add AGNIQUe- MMF to 

water in non-agitated spray systems. Conventional bypass recirculation will 

not provide adequate agitation to effectively miX MMF in water. 

Expanding Waters: Significant expansion of the habitat's surface due to rain 

or tidal fluxes can be compensated for by using a dosage that is based on the 

largest expected surface area. This will ensure complete coverage, and 

eliminate the need for re-treatment of the flooded area . 

{Note to Relliew: the following use diIections will be provided on product marl<eted to household 

users} 

APPLICATION NOTES 

Rate of Kill: The rate of kill when using MMF is dependent on the species, the 

life stage, the habitat and the temperature. Pupicidal action will typically result _ 

in 24 hours. Larvicidal action will usually result in 24-96 hours. If the film is _ 

present, control will be achieved. 

Persistence: The AGNIQU~ MMF film typically persists on the water's 

surface for 5 to 22 days. Polluted waters will cause more rapid degradation of 

the film. Higher application rates will prolong fdm life and extend the interval 

between retreatment. 

Species: Mosquitoes and midges that require little or no surface contact for 

breathing will be affected by the product during the pupae and emerging adult 

life stages. 

Wind: The high end of the dosage rate is recommended when spraying 

habitats wheffi multi-directional winds of 10mph (16kmlhr) or greater are 

expected to persist. While the film will be pushed by the winds, it will re-spread 

quickly once the winds have subsided. If persistent unidirectional winds of 10 

mph (16kmlhr) or greater are expected, the displacement of the surface film 

may result in poor control. 

Dilution: AGNIQU~ MMF is typically applied to the water's surface without 

dilution. Do not dilute product with water or other products. 

Expanding Waters: SignifJCanI expansion of the habitat's surface area due to 

rain or tidal fluxes can be compensated for by using a dosage that is based on _ 

the largest expected surface area. This will ensure comp/ete coverage, and 

eliminate the need for re-treatment of the flooded area. 

Page 2 af 3 

4
... ..,.._ . ",." ..... U'''' ...... ~ .. n .w ""'''"1' ••• 0. - ... _ ... __ .. ~~ ... -.-..- ........... ~ 

Surface Area of Standing Water Suggested Quantity of 

AGNIQUee MMF . 

1 to 75 square feet Four full trigger applications of the spray 

bottle containing AGNIQUEe MMF* 

75-100 square feet Six full trigger applications of the spray 

bottle containing AGNIQU~ MMF* 

Every additional 100 square feet Four to six full trigger applications of the 

spray bottle containing AGNIQUeMMF* 

1,000 square feet 40 to 60 full trigger applications (1-1 .5 

oz.) 

* The application rate can vary between 1 and 3.0 oz. per 1000 sq. fl (0.1 to 

0.3 oz. 1100 SQ. ft.). Maximum application rate is 3.0 oz per 1000 SQ. ft. 

• • ....... . . _ ......... . _ ........................ _ ..... ow. __ - _.. . -.- -- --. . ... .. _._. Surface Area of Standing Water Suggested Quantity of 

AGNIQUe- MMF 

1 to 75 square feet One full trigger application of the spray 

bottle containing AGNIQU~ MMF* 

75-100 square feet Two full trigger applications of the spray 

bottle containing AGNIQU~ MMF* 

Every additional 100 square feet Two to three full trigger applications of 

the spray bottle containing AGNIQU~ 

MMF* 

1,000 ~uare feet 20-25 full trigger applications (1-1 .5 oz.) 

*The application rate can vary between 1 and 3.0 oz. per 1000 sq. ft. (0.1 to 

0.3 oz. 1100 SQ. ft.). Maximum application rate is 3.0 oz per 1000 SQ. ft. 

{Note 10 Review: the following storage and disposal language Wl11 appear 011 household 

conta/ners.} 

STORAGE AND DISPOSAL 

If empty: Do not reuse this container. Place in trash or offer for recycling if 

available. 00 not allow product to freeze. 

If partly filled: Call your local solid waste agency or 1-800-CLEANUP for 

disposal instructions. Never place unused product down any indoor or outdoor 

drain. 

{Note to Review: the foIIcwing ch8lt will be used on containers larger than 1 gallOll in size.} 

STORAGE AND DISPOSAL 

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

Pesticide Storage: Do not allow storage containers to rust. Rust contaminants 

may clog spray nozzles. 00 not allow product to freeze. 

Pesticide Disposal: Wastes resulting from the use of this product may be 

disposed of on site or at an approved waste disposal facility. 

Container Disposal: Triple rinse, then offer for recycling or reconditioning or 

puncture and dispose of in a sanitary landfill, or by other procedures approved 

by state or local authorities. 

Revised 10-11-05 

NOTICE 

Cognis Corporation makes no warranty, express or implied of merchantability, 

fitness or otherwise concerning the use of this product other than as indicated 

on the label. User assumes all risks, storage or handling not in strict 

accordance with the label. 

For information on this pestiCide product (including health) concerns, medical 

emergencies or pestiCide incidents, call the National Pesticide 

Telecommunication Net work at 1-800-858-7378. 

{-OR-} 

For assistance call the __ Help Line 1-800-_-__ Monday through Friday 

7 am to 5 pm Central Time. 

Stops Mosquitoes from Breeding _ 

Stop Mosquitoes Before they Start .. 

Stops Mosquito Emergence 

Standing Water Treatment 

Spreads to cover hard to reach areas 

Can be used in habitats containing birds, fish, pets and wildlife 

Use every two weeks or as needed 

Biodegradable 

Peel Here for Directions 

See pull out label for additional use instructions 

See pull out label for Rrst Aid Treatment 

May be used in potable water 

Use on: [Containerized} ponds, pools, ditches, irrigation water, flood water 

areas, other areas where mosquitoes breed and develop 

Net (Contents) (WT) _____ _ 

c) n IS 

Cognis Corporation 

4900 Este Avenue 

Cincinnati, OH 45232-1419 

1-800-254-1029 

Page 3 of3 

-

5
LEWIS & 

HARRISON 

COMultante In Government Aftelre 

122 C Street. N.W .. Suite 7"0 

Washington. D.C. 20001 

telephone 202.393.3903 

faIC 202.393.3906 

Dan Kenny, Product Manager # 1 

Insecticide Branch 

Registration Division (7505C) 

Office of Pesticide Programs 

Environmental Protection Agency 

1801 South Bell Street 

Arlington, VA 22202 

re: Agnique MMF 

EPA Reg. No. 53263-28 

Registrant: Cognis Corporation 

March 13,2006 

Revised Label and Confidential Statement of Formula 

Dear Dan: 

As we discussed, please find revised five (5) copies of a revised product label and Confidential 

Statement of Fonnula (CSF) for Agnique MMF. The revised label and CSF are in accordance 

with Kerry Leifer's review dated March 7, 2006. 

If you have any questions about this SUbmission, please contact me at (202) 393-3903, ext. 14. 

Sincerely, 

Eliot Harrison 

Agent for Cognis 

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

6
?(Lof05;;f) 

AGNIQUE® MMF 

MOSQUITO LARVICIDE & PUPICIDE 

Monomolecular Surface Film for Control of Immature Mosquitoes and Midges 

ACTIVE INGREDIENT: 

Poly (oxy-1 ,2-ethanediyl), a-i!{O ~C 4_ hYdroXYI .......................... 100% 

C/~_2.0 

KEEP OUT OF REACH OF CHILDREN 

CAUTION 

See Back Panel for Additional Precautions and Product Information 

FIRST AID (TREATMENT) 

IF ON SKIN • Take off contaminated clothing. 

OR • Rinse skin immediately with plenty of water for 15-20 

i 

! 

I 

I CLOTHING: minutes. I 

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

IF IN EYES: • Hold eye open and rinse slowly and gently with plenty of 

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. 

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

center or doctor, or going for treatment. 

EPA Reg. No. 53263-28 

_ ~ 15-fP-lf-JV-( 

tV! LA.- ~v~/'1I--r 

-3) fL-

••• '2. . . . . ... .....( 

• •• • ••• 

• • • • • • • • 

•• • • • • • • • 

• • •• • 

• • • • • • • • • • • • • 

17; 

( ~c, 

• • • • ••• 

bPA bstablishment No. .. . ------- -. .. .. • • •• • • • •••• 

L-11/3GL 

PRECAUTIONARY ST ATEM ENTS 

HAZARDS TO HUMAN AND DOMESTIC ANIMALS 

CAUTION: Avoid contact with skin, eyes or clothing. Wash thoroughly with 

soap and water after handling. 

DIRECTIONS FOR USE 

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

its labeling. To be used in governmental mosquito control program, by 

professional pest control operators, by homeowners, or in other mosquito or 

midge control operations. 

APPLICATION DIRECTIONS 

This product may be applied by both ground and aerial applications. To use, 

calculate the desired rate based on water surface area. The water depth is not _ 

a factor in rate determination. Spray the desired rate of AGNIQUE® MMF onto ,., 

the surface of the water. No dilutioD is required and a fan spray is 

recommended. The MMF will spread to cover hard to access areas. For large 

areas with dense vegetation it is recommended that application is made in 

several locations to assist in the spreading action. Do not pour or inject a 

stream spray directly into water. AGNIQUE® MMF is not visible on the surface 

of the water. Excess MMF on the water surface will form a white globule. 

APPLICATION SITES 

This product is for the control of immature mosquitoes and midges in areas 

where they breed and develop. This product may be used in habitats including 

potable water and irrigation waters, permanent and semi-permanent waters, 

irrigated croplands and pastures, and waters with outlets to natural water 

bodies. The following habitats provide examples of where the product can be 

applied but is not intended to be all inclusive. 

Fresh and Brackish Water: fresh water and salt marshes, [containerized] ponds, 

lakes, storm water, drainage systems and retention & detention basins, roadside 

ditches, grassy swales, flooded fields and pastures, potable water containers, At 

reservoirs, irrigated croplands, temporary and semi-permanent woodland pools, tidal ,., 

water, and other areas where water accumulates. 

Residential Areas: [Containerized] ponds, storm water basins, tree holes, rain 

barrels, landscape and ornamental pon~s , tires, storm drains, stationary flower pots, 

pot holes, gutters, tarps, potable water containers and residential areas where water 

accumulates and provides ideal breeding habitats for mosquitoes or midges. Not for 

Homeowner Use in the State of New York. 

Polluted Waters: Sewage lagoons, percolation ponds, animal waste effluent 

lagoons, septic ditches, waste treatment facility areas, etc. 

Revised 10-11-05 Page 1 of 3 

7
" 

Note to Review: the fol/owing chart will be used on containers laroer than 1 oal/on in size:} 

MOSQUITO HABITAT Suggested Rate Range 

Fresh and Brackish Water* 0.2-1.0 gallons/acre (2 - 10 liters/hectare) 

Polluted Waters** 0.35-1.0 gallons/acre (3.5-10 liters/hectare) 

MIDGE HABITAT Suggested Rate Rangel\ 

Fresh and Polluted Waters 0.5-1.0 gallons/acre (5 - 10 liter/hectare) 

* The lower rate (0.2 gallons/acre) is recommended when only pupae control is 

desired and in sites with no emergent vegetation and low organic content 

* Use higher rates when emergent or surface vegetation is present, due to the 

wicking action of the product. The more vegetation or the drier the vegetation, the 

higher the required rate. 

** Use higher rates in polluted water habitats for effective control 

1\ Reapplication is recommended every two weeks during the midge season 

{Note to Review: the fol/owing use directions will be provided on product marketed to commercial 

and institutional users:} 

APPLICATION NOTES 

Rate of Kill: The rate of kill when using MMF is dependent on the species, the 

life stage, the habitat and the temperature. Pupicidal action will typically result 

in 24 hours. Larvicidal action will usually result in 24-96 hours. If the film is 

present, as indicated by the indicator oil, control will be achieved. 

Indicator Oil: AGNIQU~ MMF is not visible on the surface of the water. To 

check the habitat for the presence and persistence of the product, add a drop 

of AGNIQUE® MMF Indicator Oil to several locations in the habitat. If the 

Indicator Oil forms a tight bead on the surface of the water, then the MMF is 

present for control. 

Persistence: The AGNIQUE® MMF surface film typically persists on the 

water's surface for 5 to 22 days. Polluted waters will cause more rapid 

degradation of the film. Higher application rates will prolong film life and extend 

the interval between retreatment. 

Species: Mosquitoes and midges that require little or no surface contact for 

breathing will be affected by the product during the pupae and emerging adult 

life stages. 

Wind: The high end of the dosage rate is recommended when spraying 

habitats where multi-directional winds of 10mph (16km/hr) or greater are 

expected to persist. While the film will be pushed by the winds, it will re-spread 

quickly once the winds have subsided. If persistent unidirectional winds of 10 

mph (16km/hr) or greater are expected, the displacement of the surface film 

may result in poor control. , 

Spray Tanks: Thoroughly clean and dry the spray system of contaminants 

such as petroleum oils, water, detergents and conventional toxicants prior to 

adding AGNIQUE® MMF. Detergents will destroy the film-forming of the 

AGNIQUE® MMF; other contaminants (water and oil) can result in the 

formation of an unsprayable paste. 

Dilution: AGNIQUE® MMF is typically applied to the water's surface without 

dilution. However, if it is desired to spray higher volumes of liquid, AGNIQUE® 

Revised 10-11-05 

: 

MMF may be diluted using a high shear injection system that dilutes the MMF 

at the nozzle to a maximum of 10% in water. Do not add AGNIQUE® MMF to 

water in non-agitated spray systems. Conventional bypass recirculation will 

not provide adequate agitation to effectively mix MMF in water. 

Expanding Waters: Significant expansion of the habitat's surface due to rain 

or tidal fluxes can be compensated for by using a dosage that is based on the 

largest expected surface area. This will ensure complete coverage, and 

eliminate the need for re-treatment of the flooded area. 

{Note to Review: the fol/owing use directions will be provided on product marketed to household 

users.} 

APPLICATION NOTES 

Rate of Kill: The rate of kill when using MMF is dependent on the species, the 

life stage, the habitat and the temperature. Pupicidal action will typically result a 

in 24 hours. Larvicidal action will usually result in 24-96 hours. If the film is . 

present, control will be achieved. 

Persistence: The AGNIQUE® MMF film typically persists on the water's 

surface for 5 to 22 days. Polluted waters will cause more rapid degradation of 

the film. Higher application rates will prolong film life and extend the interval 

between retreatment. 

Species: Mosquitoes and midges that require little or no surface contact for 

breathing will be affected by the product during the pupae and emerging adult 

life stages. 

Wind: The high end of the dosage rate is recommended when spraying 

habitats where multi-directional winds of 10mph (16km/hr) or greater are 

expected to persist. While the film will be pushed by the winds, it will re-spread 

quickly once the winds have subsided. If persistent unidirectional winds of 10 

mph (16km/hr) or greater are expected, the displacement of the surface film 

may result in poor control. 

Dilution: AGNIQUE® MMF is typically applied to the water's surface without 

dilution. Do not dilute product with water or other products. 

Expanding Waters: Significant expansion of the habitat's surface area due to e 

rain or tidal fluxes can be compensated for by using a dosage that is based on 

the largest expected surface area. T.his will ensure complete coverage, and 

eliminate the need for re-treatment of the flooded area. 

Page 2 of 3 

8
, . 

.. -~ .... , ..... .... ....... . ........ .... ........ ... """ -" ..... -- ---- -_ ... _ ... _ ...... _-- .. . _ ... - -_. Surface Area of Standing Water Suggested Quantity of 

AGNIQUE® MMF 

1 to 75 square feet Four full trigger applications of the spray 

bottle containing AGNIQUE® MMF* 

75-100 square feet Six full trigger applications of the spray 

bottle containing AGNIQUE® MMF* 

Every additional 100 square feet Four to six full trigger applications of the 

spray bottle containing AGNIQUE® 

MMF* 

1,000 square feet 40 to 60 full trigger applications (1-1 .5 

oz.) 

* The application rate can vary between 1 and 3.0 oz. per 1000 sq. ft. (0.1 to 

0.3 oz. 1100 sq. ft.). Maximum application rate is 3.0 oz per 1000 sq. ft. 

- - -- -- .. _. - y - - - - - - . .. _. - -- -_.- .- . - -- - --

Surface Area of Standing Water Suggested Quantity of 

AGNIQUE® MMF 

1 to 75 square feet One full trigger application of the spray 

bottle containing AGNIQUE® MMF* 

75-100 square feet Two full trigger applications of the spray 

bottle containing AGNIQUE® MMF* 

Every additional 100 square feet Two to three full trigger applications of 

the spray bottle containing AGNIQUE® 

MMF* 

1,000 square feet 20-25 full trigger applications (1-1.5 oz.) 

*The application rate can vary between 1 and 3.0 oz. per 1000 sq. ft. (0.1 to 

0.3 oz. 1100 sq. ft.). Maximum application rate is 3.0 oz per 1000 sq. ft. 

{Note to Review: the following storage and disposal language will appear on household 

containers:} 

STORAGE AND DISPOSAL 

If empty: Do not reuse this container. Place in trash or offer for recycling if 

available. Do not allow product to freeze. 

If partly filled: Call your local solid waste agency or 1-800-CLEANUP for 

disposal instructions. Never place unused product down any indoor or outdoor 

drain. 

{Note to Review: the fol/owing chart will be used on containers larger than 1 gal/on in size:} 

STORAGE AND DISPOSAL 

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

Pesticide Storage: Do not allow storage containers to rust. Rust contaminants 

may clog spray nozzles. Do not allow product to freeze. 

Pesticide Disposal: Wastes resulting from the use of this product may be 

disposed of on site or at an approved waste disposal facility. 

Container Disposal: Triple rinse, then offer for recycling or reconditioning or 

puncture and dispose of in a sanitary landfill, or by other procedures approved 

by state or local authorities. 

Revised 10-11-05 

NOTICE 

Cognis Corporation makes no warranty, express or implied of merchantability, 

fitness or otherwise concerning the use of this product other than as indicated 

on the label. User assumes all risks, storage or handling not in strict 

accordance with the label. 

For information on this pesticide product (including health) concerns, medical 

emergencies or pesticide incidents, call the National Pesticide 

Telecommunication Net work at 1-800-858-7378. 

{-OR-} 

For assistance call the __ Help Line 1-800-_-__ Monday through Friday 

7 am to 5 pm Central Time. 

Stops Mosquitoes from Breeding e 

Stop Mosquitoes Before they Start 

Stops Mosquito Emergence 

Standing Water Treatment 

Spreads to cover hard to reach areas 

Can be used in habitats containing birds, fish, pets and wildlife 

Use every two weeks or as needed 

Biodegradable 

Peel Here for Directions 

See pull out label for additional use instructions 

See pull out label for First Aid Treatment 

May be used in potable water 

Use on: [Containerized] ponds, pools, ditches, irrigation water, flood water 

areas, other areas where mosquitoes breed and develop 

Net (Contents) (WT) _____ _ 

Cognis Corporation 

4900 Este Avenue 

Cincinnati, OH 45232-1419 

1-800-254-1029 

Page 30f3 

e 

9
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 

WASHINGTON, D.C. 20460 

March 7, 2006 

OFFICE OF PREVENTION, 

PESTICIDES, AND TOXIC SUBSTANCES 

MEMORANDUM 

SUBJECT: 

FROM: 

TO: 

Review of Amendment to Change Nomenclature of Active Ingredient 

Agnique MMF Mosquito Larvacide & Pupicide 

EPA Reg. No. 53263-28 

DP# 323953 

Kerry 

Inert Ingredien 

Leifer ~ e me ranch 

Registration Division ( 505C) 

Dan Kenny (PM-01 ) 

I nsecticide-Rodenticide Branch 

Registration Division (7505C) 

In a submission dated October 11,2005, the registrant of Agnique MMF 

Mosquito Larvacide & Pupicide (EPA Reg. No. 53263-28), Cognis Corporation (through 

their agent, Lewis & Harrison), requested that the nomenclature associated with the 

product's active ingredient be revised from "poly(oxy-1 ,2-ethanediyl), a-isooctadecyl-whydroxy-It to "poly(oxy-1,2-ethanediyl), a-iso(C14_2o)-w-hydroxy-" and that the 

manufacturing process be modified to allow for the use of an additional source of 

starting material. These two requests are addressed below. 

I. Revision of Active Ingredient Nomenclature 

The current approved Confidential Statement of Formula (CSF) for Agnique MMF 

Mosquito Larvacide & Pupicide (EPA Reg. No. 53263-28) dated August 27,1996, lists 

the active ingredient as "poly(oxy-1 ,2-ethanediyl), a-isooctadecyl-w-hydroxy-" with a 

Chemical Abstracts Service (CAS) Registry Number of 52292-17-8. The product is 

formulated as 1 00% active ingredient. The most recent approved product label 

(accepted July 14, 2003) has an active ingredient declaration of "poly(oxy-1 ,2-

ethanediyl), a-Isooctadecyl-w-hydroxyl" (sic) with the weight percentage of active 

ingredient being given as 1 00%. 

Poly(oxy-1 ,2-ethanediyl), a-isooctadecyl-w-hydroxy- is also referred to by the 

synonym POE isostearyl alcohol. The process by which POE isostearyl alcohol is 

manufactured involves the ethoxylation of isostearyl alcohol. The registrant has 

10
! 

submitted analytical data on the composition of the isostearyl alcohol starting material 

used in the manufacture of the Agnique MMF active ingredient as well as the POE 

isostearyl alcohol active ingredient. Both the isostearyl alcohol starting material and the 

POE isostearyl alcohol active ingredient were analyzed using reversed-phase high 

performance liquid chromatography (RP-HPLC) separation followed by mass 

spectroscopy (MS) detection. The RP-HPLC/MS data included in the 10/11/2005 

submission indicate that the isostearyl alcohol starting material used in the manufacture 

of Agnique MMF is comprised of linear and branched forms of octadecanol (a C18 

alcohol) as well as various amounts of other C16-C20 alcohols. The POE isostearyl 

alcohol active ingredient also is comprised of ethoxylated C18 alcohols as well as 

various amounts of other C16-C20 alcohol ethoxylates. 

II. Use of an Additional Source of Starting Material 

In the 10/11/2005 submission, the registrant also seeks to use an additional 

source of starting material in addition to the isostearyl alcohol currently being utilized. 

The registrant is proposing to utilize NEODOL 67, a product manufactured by Shell 

Chemicals, in the manufacture of Agnique MMF. NEODOL 67 is described by Shell 

Chemicals as a "C16 and C17 high purity primary alcohol" in its product datasheet 

(http://www.shellchemicals.com/chemicals/pdf/neodol/neodol 67.pdf?section=our prod 

ucts). The registrant has provided RP-HPLC/MS data on NEODOL 67 with 

demonstrate consistency with the Shell Chemicals description and specifications of 

NEODOL 67. 

Conclusion and Recommendations 

Based on the compositional analysis information submitted on both the isostearyl 

alcohol starting material and the POE isostearyl alcohol active ingredient, the most 

appropriate chemical nomenclature that should be used to describe this active 

ingredient is "poly(oxy-1,2-ethanediyl), a-(C16-20 branched and linear alkyl)-whydroxy-" and this name should appear on both the product's CSF and label as the 

active ingredient name. The CAS Reg. No. of 52292-17-8 that is listed on the 

proposed CSF dated October 11,2005 is specific to poly(oxy-1 ,2-ethanediyl), aisooctadecyl-w-hydroxy-" and should not be associated with poly(oxy-1 ,2-ethanediyl), a-

(C16-20 branched and linear alkyl)-w-hydroxy-." A CAS Reg. No. that corresponds to 

poly(oxy-1 ,2-ethanediyl), a-(C16-20 branched and linear alkyl)-w-hydroxy- should be 

used. 

Based on the compositional analysis information submitted on NEODOL 67, the 

Shell Chemicals datasheet for NEODOL 67, and the compositional analysis provided on 

the NEODOL 67 ethoxylate, it has been concluded that the active ingredient formed 

from NEODOL 67 and ethylene oxide comports with the name "poly(oxy-1 ,2-

ethanediyl), a-(C16-20 branched and linear alkyl)-w-hydroxy-" and that the composition 

of the active ingredient formed from NEODOL 67 and ethylene oxide would not 

significantly differ from the POE isostearyl alcohol active ingredient in Agnique MMF, 

therefore the use of NEODOL 67 in the manufacture of Agnique MMF is acceptable. 

20f2 

11
LEWIS & 

HARRISON 

Consultants In Govarnmant Affairs 

122 C Street, N.W., Suite 740 

Washington, D.C. 20001 

telephone 202.393.3903 

fax 202.393.3906 

Daniel Kenny, Product Manager (01) 

Insecticide-Rodenticide Branch 

Registration Division (7505C) 

Office of Pesticide Programs 

Environmental Protection Agency 

1801 South Bell Street 

Arlington, V A 22202 

re: Agnique MMF, EPA Reg. No. 53263-28 

Registrant: Cognis Corporation 

October 11, 2005 

Amendment to Change Nomenclature of Active Ingredient 

PRIA Category R34 

Dear Dan: 

As a follow-up to the May 19,2005 meeting and the June 11,2005 submission concerning Agnique 

MMF, I am formally submitting an amendment for this product. The amendment proposes to revise 

the nomenclature ofthe active ingredient from poly (oxy-1.2-ethanediyl), a.-isooctadecyl-co-hydroxyl 

to poly (oxy-1,2-ethanediyl), a.-iso (CI4_

2o)-co-hydroxyl and would also allow the use of alternate 

beginning materials in the manufacture of the active ingredient. 

Please note that the documents submitted on June 11, 2005 in support of this change are being 

resubmitted in the appropriate "86-5" format. In addition, five copies ofthe amended product label 

and a Confidential tatement of Formula (C ) with the revised name ofthe active ingredient are 

enclosed. No other changes have been made to the product label or CSF. 

If you have any questions regarding this submission, please contact me at (202) 393-3903, ext. 14. 

Sincerely, 

Eliot 

~ Harrison 

Agent for Cognis 

12
Please read ills/rue/ions 011 reverse before comple lIf!iorm. Form Approved, OMB No. 2070-0060 A~oval expires 05-31-98 

EPA United States D Registration OPP Identifier Number 

Environmental Protection Agency 0 Amendment 296886 Washington, DC 20460 D Other 

Application for Pesticide - Section 1 

I. Company/Product Number 2. EPA Product Manager 3. Proposed Classification 

53263-28 Daniel Kenny 

4. Company/Product (Name) PM# ~None D Restricted AGNIQUEMMF Team 31 

5. Name and Address of Applicant (Inc/ude ZIP Code) 6. Expedited Review. In accordance with FIFRA Section 3(cX3)(b)(l), my product is 

Cognis Corporation similar or identical in composition and labeling to: 

4900 Este Avenue EPA Reg. No. 

Cincinnati, OH 

o Check if/his is a new addresss Product Name 

Section - n 

[8] Amendment - Explain below. D Final printed labels in response to Agency letter dated _ _ _ 

o Resubmission m response to Agency letter dated o "Me Too" Application 

D Notification - Explain below. D Other - Explain below 

Explanation: Use additional page(s) is necessary. (For Section I and Section II.) 

Change in the nomenclature for the active ingredient. Refer to cover letter for details. 

PRIA Category R34 

Section -ill 

I. Material This Product Will Be Packaged In: 

Child-Resistant Packaging Unit Packaging Water Soluble Packaging 2. Type of Container 

Dyes- DYes DYes o Metal 

o No o No D No D Plastic 

*CertijicatiOit must be If "Yes" No. pcr If "Yes" No. pc" o Glass 

submitted Unit Packaging wgt. container Package wgt. Container o Paper 

D Othcr (Spccifiy) 

3. Location ofN t Cuntents Information 4. Size(s) Retail Contamer 5. Location of Label Directions 

D l.abel o Container 21 oz. o On Label 

D On labeling accompanying product 

6. Manner 111 Whl h Label l. Aflixed to PlOduct o Lithograph o Othcr 

o Paper glued 

o Stenciled 

Section - IV 

I. Contact Point (Complete ilellls direc/ly below for idell/ijicalion of individual to be contacted. if lIecessary. to process this application) 

Name Title Telephone No. (Include Area Code) 

Eliot L Harrison Agent for Cognis (202) 393-3903 

Certification 6. Date Application Received 

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

that any knowingly false or misleading statemcnt may be punishable by fine or imprisonment or both under applicable law. (Stamped) 

2. s;'"""~~:v V 3. Title 

Agent for Cog1!is 

4. Typed Name \ v 5. Date 

Eliot 1. Harrison October 11, 2005 

--- EPA Form 8570-( (Rev. 8-94) Previous editions are obsolete . . Whlte- EPA Fi le Copy (ongmal) Yellow- Applicant Copy 

13
CBI Cross-Reference Number 3 

This cross-reference number is used in the study in place of the following pages at the 

indicated volume and page numbers. 

VOLUME PAGE NUMBERS ~ ~~~ON 1=.oR GEl£f~o~ HFAA RE~ERENCE. 

1 24-25 Manufacturing Process 1 O(d)(1 )A) 

DELETED PAGES: 

FORMULATION PROCESS 

Page 22 0(24 

14 *Manufacturing process information may be entitled to confidential treatment*
Page 23 of24 

15 *Manufacturing process information may be entitled to confidential treatment*
. OLUME 1 OF 1 

STUDY TITLE 

•••••• • •• • • It.. ••••• 

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• . . · - . • •• 

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• ••• · _. •• • 

Characterization of the Active Ingredient in Agnique MMF, EPA Reg. No. 53263-28, and 

the Use of an Alternative Beginning Material in the Manufacturing Process 

DATA REQUIREMENT 

OPPTS Guideline Numbers: 

830.1550 

830.1600 

AUTHOR 

Jianhua Mao, Ph.D. 

Eliot Harrison 

STUDY COMPLETED ON 

June 11, 2005 

PERFORMING LABORATORY 

Cognis Inc. 

4900 Este Avenue 

Cincinnati, OH 

Page 1 of27 

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16
• 

Material to be added to a Mini-Jacket 

(in the case where an e-Jacket exists) 

Send to SIG: check box D 

This material is: 

.r-! New stamped-accepted label 

NewCSF o . Notification 

D Final Printed Label 

c Other: --------------

Instructions: Attach this notice on top of the 

mater~al. It must be clipped all together and 

there should be NO STAPLES in the material. 

Then give the material with this coversheet to 

staff in the Information Services Center (Room. 

230). 

Reviewer's Name: oJi?Iiv' ~ ~ 

Phone: ,/VJ JtJ:fS9Pf Division: -Red __ 

Date: <fJ5~ ~/, 

Current as of Wednesday, March 01 , 2006 

17
UNITED STATES • ENVIRONMENTAL PROTECTION 

JI I 5 ? 0.8 

Ms. Catherine Rice 

c/o Cognis Corporation 

Lewis & Harrison 

122 C Street, N.W. Suite 740 

Washington, DC 20001 

WASHINGTON, D.C. 20460 

Subject: Addition of CASRN to the Confidential Statement of Formula 

Agnique MMF Mosquito Larvicide & Pupicide 

EPA Reg. No. 53263-28 

Your Submission date, May 18, 2006 

Dear Ms. Rice: 

OFFICE OF 

PREVENTION, PESTICIDES AND 

TOXIC SUBSTANCES 

The Agency has received and reviewed your alternate confidential statement of formula 

for the above named product dated May 18, 2006 with the addition of CASRN. The CSF is 

acceptable and has been placed in the Agency file. If there are questions call me at 703 305-

5409. 

Sincerely, 

/sl 

Dani Daniel 

Insecticide-Rodenticide Branch 

Registration Division 7505P 

RecycledlRecyclabl •• Printed wfth Vegetable 011 Based Inks on 100% Recycled Paper (40% Postoonsumer) 

18
, 

LEWIS & 

HARRJSON 

Consultants in Government Affair. 

May 18, 2006 

• 

122 C Street, N.W., Suite 740 

Washington, D.C. 20001 

telephone 202.393.3903 

fax 202.393.3906 

Document Processing Desk (7505P) 

Office of Pesticide Programs (AMEND) 

US Environmental Protection Agency 

One Potomac Yard 

2777 S Crystal Drive 

Arlington, VA 22202 

ATTN: Daniel Kenny 

Product Manager, Team 7 

RE: Cognis Corporation 

Agnique MMF Mosquito Larvicide & Pupicide 

(EPA Reg. No. 53263-28) 

Updated CSF to add CASRN 

Dear Mr. Kenny: 

• 

Hand Delivered 

On behalf of Cognis Corporation ("Cognis"), I am submitting an updated 

Confidential Statement of Formula (CSF) for the product, Agnique MMF 

Mosquito Larvicide & Pupicide (EPA Reg. No. 53263-28). The only difference 

between the approved CSF and the updated CSF is the addition of the CASRN 

to the active ingredient. This was requested in Kerry Leifer's review dated March 

7, 2006 (attached). 

If you have any questions or if I may be for further assistance, please contact me 

at 202-393-3903 ext.13 or bye-mail atcrice@lewisharrison.com 

Catherine Rice 

Agent for Cognis Corporation 

•••• 

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• 

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19
UNITED STATES •ENVIRONMENTAL PROTECTION AGENCY • 

WASHINGTON, D.C. 20460 

OFFICE OF PREVENTION, 

PESTICIDES, AND TOXIC SUBSTANCES 

March 7, 2006 

MEMORANDUM 

SUBJECT: 

FROM: 

TO: 

Review of Amendment to Change Nomenclature of Active Ingredient 

Agnique MMF Mosquito Larvacide & Pupicide 

EPA Reg, No. 53263-28 

DP# 323953 

Kerry Leifer 1!.~. Inert Ingredien~ ~e me ranch 

Registration Division ( 505C) 

Dan Kenny (PM-01) 

Insecticide-Rodenticide Branch 

Registration Division (7505C) 

In a submission dated October 11, 2005, the registrant of Agnique MMF 

Mosquito Larvacide & Pupicide (EPA Reg. No. 53263-28), Cognis Corporation (through 

their agent, Lewis & Harrison), requested that the nomenclature associated with the 

product's active ingredient be revised from "poly(oxy-1 ,2-ethanediyl), a-isooctadecyl-whydroxy-" to "poly(oxy-1 ,2-ethanediyl), a-iso(C14-2o)-w-hydroxy-" and that the 

manufacturing process be modified to allow for the use of an additional source of 

starting material. These two requests are addressed below. 

I. Revision of Active Ingredient Nomenclature 

The current approved Confidential Statement of Formula (CSF) for Agnique MMF 

Mosquito Larvacide & Pupicide (EPA Reg. No. 53263-28) dated August 27,1996, lists 

the active ingredient as "poly(oxy-1 ,2-ethanediyl), a-isooctadecyl-w-hydroxy-" with a 

Chemical Abstracts Service (CAS) Registry Number of 52292-17-8. The product is 

formulated as 1 00% active ingredient. The most recent approved product label 

(accepted July 14, 2003) has an active ingredient declaration of "poly(oxy-1 ,2-

ethanediyl), a-Isooctadecyl-w-hydroxyl" (sic) with the weight percentage of active 

ingredient being given as 1 00%. • ••• 

• • •••• 

Poly(oxy-1 ,2-ethanediyl), a-isooctadecyl-w-hydroxy- is also referred to by the-· :.: 

synonym POE isostearyl alcohol. The process by which POE isostearyl alcohol is ••• • 

manufactured involves the ethoxylation of isostearyl alcohol. The registrant has ...: 

.. " 

• • •••••• • 

• 

•••• • • •••• 

•••• · ., 

•••••• • •• • • 

•••••• 

• • • • 

••••• • • • •••• 

20
• • 

submitted analytical data on the composition of the isostearyl alcohol starting material 

used in the manufacture of the Agnique MMF active ingredient as well as the POE 

isostearyl alcohol active ingredient. Both the isostearyl alcohol starting material and the 

POE isostearyl alcohol active ingredient were analyzed using reversed-phase high 

performance liquid chromatography (RP-HPLC) separation followed by mass 

spectroscopy (MS) detection. The RP-HPLC/MS data included in the 10/11/2005 

submission indicate that the isostearyl alcohol starting material used in the manufacture 

of Agnique MMF is comprised of linear and branched forms of octadecanol (a C18 

alcohol) as well as various amounts of other C16-C20 alcohols. The POE isostearyl 

alcohol active ingredient also is comprised of ethoxylated C18 alcohols as well as 

various amounts of other C16-C20 alcohol ethoxylates. 

II. Use of an Additional Source of Starting Material 

In the 101-11/2005-submission, the registrant also see-ks to use an additional - --

source of starting material in addition to the isostearyl alcohol currently being utilized. 

The registrant is proposing to utilize NEODOL 67, a product manufactured by Shell 

Chemicals, in the manufacture of Agnique MMF. NEODOL 67 is described by Shell 

Chemicals as a "C16 and C17 high purity primary alcohol" in its product datasheet 

(http://www.shellchemicals.com/chemicals/pdf/neodollneodoI 67.pdf?section=our prod 

ucts). The registrant has provided RP-HPLC/MS data on NEODOL 67 with 

demonstrate consistency with the Shell Chemicals description and specifications of 

NEODOL 67. 

Conclusion and Recommendations 

Based on the compositional analysis information submitted on both the isostearyl 

alcohol starting material and the POE isostearyl alcohol active ingredient, the most 

appropriate chemical nomenclature that should be used to describe this active 

ingredient is "poly(oxy-1,2-ethanediyl), a-(C16-20 branched and linear alkyl)-whydroxy-" and this name should appear on both the product's CSF and label as the 

active ingredient name. The CAS Reg. No. of 52292-17-8 that is listed on the 

proposed CSF dated October 11, 2005 is specific to poly(oxy-1 ,2-ethanediyl), aisooctadecyl-w-hydroxy-" and should not be associated with poly(oxy-1,2-ethanediyl),_a-

(C16-20 branched and linear alkyl)-w-hydroxy-." A A ego o. hat c r pon 0 

01 - ,2- h n i f), 1 - br nchad and II r Ikyl -w-h r - h Id b 

Based on the compositional analysis information submitted on NEODOL 67, the 

Shell Chemicals datasheet for NEODOL 67, and the compositional analysis provided on 

the NEODOL 67 ethoxylate, it has been concluded that the active ingredient formed 

from NEODOL 67 and ethylene oxide comports with the name "poly(oxy-1 ,2-

ethanediyl), a-(C16-20 branched and linear alkyl)-w-hydroxy-" and that the composLttGlii. 

of the active ingredient formed from NEODOL 67 and ethylene oxide would not •••• • 

significantly differ from the POE isostearyl alcohol active ingredient in Agnique MM~:. :.: 

therefore the use of NEODOL 67 in the manufacture of Agnique MMF is acceptable. .. 

2of2 

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21
;n"I'YIII"',t;""" on reverse before 

EPA United States 

Environmental Protection Agency 

Washington, DC 20460 

Form 

o Registration 

I:8J Amendment 

o Other: 

Application for Pesticide - Section I 

2. EPA 

Daniel 

PM# 

01 

ager 

res 05-31-98 

opp Identifier Number 

297085 

3. Proposed Classification 

r8J None o Restricted 

6. Expedited Review. In accordance with FIFRA Section 3(c)(3) 

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

to: 

EPA Reg. No. ___________ _ 

Product Name __________________________ ___ 

Section - II 

Amendment - Explain below. Final printed labels in response to Agency letter dated ____ _ 

Resubmission in response to Agency letter dated ____ __ D "Me Too· Application 

Notification - below. Other - below 

Explanation: Use additional page(s) if necessary. (For Section I and Section II). 

Addition of the CASRN to the Confidential Statement of Formula in response to Kerry Leifer's review 

dated March 7, 2006. No other changes are being proposed. 

*Certification must 

be submitted 

Section - III 

If "Yes· No. per 

Unit Packaging wgt. container 

Soluble Packaging 

No. per 

container 

2. Type of Container 

D Metal 

D Plastic 

D Glass 

D Paper 

D Other (Specifiy) 

3. Location of Net Contents Information 

D Label D Container 

ize(s) Retail Container 5. Location of 

D On Label 

6. Manner in Which Label is Affixed to Product Lithograph 

Paper glued 

Stenciled 

Other ________________________________ _ 

Name 

Eliot I. Harrison, Lewis & Harrison, 122 C 

St. NW Suite 7 Washi DC 20001 

Section -IV 

Agent for Cognis Corp. 

Certification 

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

acknowledge that any knowingly false or misleading statement may be punishable by fine or imprisonment or both 

under law. 

2. "" .... >t"". 

revious editions are 

Agent for Cognis Corp. 

5. 

M 2006 

White- EPA File 

Code) 

202-393-3903 

Received 

(Stamped) 

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(original) ~lIo .... 

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22
Pages 23-25 - *Confidential Statements of Formula may be entitled to confidential treatment*