DRAFT

Under Review by US EPA

Supplemental Information for Petition for Determination of Nonregulated Status for

Herbicide Tolerant DAS-68416-4 Soybeans

GF-2654 TS Draft Label

UNDER REVIEW BY US EPA

The undersigned submits this information under 7 CFR 340.6 to support the determination that the 

article should not be regulated under 7 CFR 340.

Submitting Company:

Dow AgroSciences LLC

Submitted by:

__________________________________

Mark S. Krieger

Regulatory Leader

Regulatory Sciences & Government Affairs

Dow AgroSciences LLC

9330 Zionsville Road

Indianapolis, IN 46268

Telephone: (317) 337-3458

FAX: (317) 337-4649

mkrieger2@dow.com

June 24, 2011
DRAFT

Under Review by US EPA

Summary

Dow AgroSciences (DAS) has submitted a petition to the United States Department of Agriculture 

(USDA)’s Animal and Plant Health Inspection Service (APHIS) for the determination of 

nonregulated status for DAS-68416-4 soybeans, which provides tolerance to the herbicides 

2,4-dichlorophenoxy acetic acid (2,4-D) and glufosinate.

This information in this draft label was submitted to the United States Environmental Protection 

Agency (EPA) supporting DAS’ April 2011 application to EPA to register the use of a new end-use 

formulation of 2,4-D on DAS-68416-4 soybean. 
DRAFT

Under Review by US EPA
DRAFT

Under Review by US EPA

1. GF-2654 TS “Draft” Label

GF-2654 TS

EPA Reg. No. 62719-XXX

Registration Notes:

Proposed Section 3 label.
(Base label):

GF-2654 TS

Herbicide

For control of broadleaf weeds in soybeans containing DAS-68416-4

Group 4 HERBICIDE

Active Ingredient:

2,4-Dichlorophenoxyacetic acid, 

choline salt ....................................56.3%

Other Ingredients .......................................43.7%

Total .........................................................100.0%

2,4-dichlorophenoxyacetic acid - 38.4% - 3.8 lb/gal

Keep Out of Reach of Children

DANGER PELIGRO

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.)

Precautionary Statements

Hazards to Humans and Domestic Animals

Corrosive • Causes Irreversible Eye Damage • Harmful If Swallowed, Inhaled Or 

Absorbed Through The Skin

Do not get in eyes, on skin, or on clothing. Avoid breathing vapor or spray mist. Wash 

thoroughly with soap and water after handling.

Personal Protective Equipment (PPE)

Some materials that are chemical-resistant to this product are made of any waterproof material. 

If you want more options, follow the instructions for category A on an EPA chemical resistance 

category selections chart.

All mixers, loaders, applicators and handlers must wear: 

 Long-sleeved shirt and long pants

 Shoes plus socks

 Chemical-resistant gloves 

 Protective eyewear

 Chemical resistant apron when mixing or loading, cleaning up spills or equipment, or 

otherwise exposed to the concentrate
Supplemental Information for USDA Petition for Nonregulated Status of DAS-40278-9 Corn

DowAgroSciences LLC

See engineering controls for additional requirements.

Follow manufacturer's instructions for cleaning/maintaining PPE. If no such instructions for 

washables exist, use detergent and hot water. Keep and wash PPE separately from other laundry. 

Engineering Controls 

When handlers use closed systems or enclosed cabs in a manner that meets the requirements 

listed in the Worker Protection Standard (WPS) for agricultural pesticides [40 CFR 170.240 

(d)(4-6)], the handler PPE requirements may be reduced or modified as specified in the WPS.

User Safety Recommendations

Users should:

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

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

clean clothing.

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

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

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 eye. Call a poison 

control center or doctor for treatment advice.

If on skin or clothing: Take off contaminated clothing. Rinse skin immediately with plenty of 

water for 15-20 minutes. Call a poison control center or doctor for treatment advice.

If swallowed: Call a poison control center or doctor immediately for treatment advice. Have 

person sip a glass of water if able to swallow. Do not induce vomiting unless told to do so by the 

poison control center or doctor. Do not give anything by mouth to an unconscious person.

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.

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

going for treatment.

Note to Physician: Probable mucosal damage may contraindicate the use of gastric lavage.

Environmental Hazards

This product is toxic to fish and aquatic invertebrates. For terrestrial uses: Do not apply directly 

to water, to areas where surface water is present, or to intertidal areas below the mean high water 

mark. Drift or runoff may adversely affect aquatic invertebrates and non-target plants. Drift and 

runoff may be hazardous to aquatic organisms in water adjacent to treated areas. Do not 

contaminate water when disposing of equipment washwaters or rinsate.

This chemical has properties and characteristics associated with chemicals detected in 

groundwater. The use of this chemical in areas where soils are permeable, particularly where the 
Supplemental Information for USDA Petition for Nonregulated Status of DAS-40278-9 Corn

DowAgroSciences LLC

water table is shallow, may result in groundwater contamination. Application around a cistern or 

well may result in contamination of drinking water or groundwater.

Agricultural Use Requirements

Use this product only in accordance with its labeling and with the Worker Protection Standard, 

40 CFR Part 170. Refer to the label booklet under "Agricultural Use Requirements" in the 

Directions for Use section for information about this standard.

(Storage and Disposal for rigid containers 5 gal or less)

Storage and Disposal

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

Pesticide Storage: Keep container tightly closed when not in use. If exposed to subfreezing 

temperatures, the product should be warmed to at least 40°F and mixed thoroughly before using.

Pesticide Disposal: Pesticide wastes are toxic. Improper disposal of excess pesticide, spray mixture, or 

rinsate is a violation of Federal law and may contaminate groundwater. If these wastes cannot be 

disposed of by use according to label instructions, contact your State Pesticide or Environmental Control 

Agency, or the Hazardous Waste Representative at the nearest EPA Regional Office for guidance.

Container Handling: Nonrefillable container. Do not reuse or refill this container. 

Triple rinse or pressure rinse container (or equivalent) promptly after emptying. Triple rinse as follows: 

Empty the remaining contents into application equipment or a mix tank and drain for 10 seconds after the 

flow begins to drip. Fill the container 1/4 full with water and recap. Shake for 10 seconds. Pour rinsate 

into application equipment or a mix tank or store rinsate for later use or disposal. Drain for 10 seconds 

after the flow begins to drip. Repeat this procedure two more times. Pressure rinse as follows: Empty 

the remaining contents into application equipment or a mix tank and continue to drain for 10 seconds after 

the flow begins to drip. Hold container upside down over application equipment or mix tank or collect 

rinsate for later use or disposal. Insert pressure rinsing nozzle in the side of the container, and rinse at 

about 40 psi for at least 30 seconds. Drain for 10 seconds after the flow begins to drip. Then offer for 

recycling if available or puncture and dispose of in a sanitary landfill, or by incineration, or by other 

procedures allowed by state and local authorities.

(Storage and Disposal for refillable rigid containers larger than 5 gal)

Storage and Disposal

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

Pesticide Storage: Keep container tightly closed when not in use. If exposed to subfreezing 

temperatures, the product should be warmed to at least 40°F and mixed thoroughly before using.

Pesticide Disposal: Pesticide wastes are toxic. Improper disposal of excess pesticide, spray mixture, or 

rinsate is a violation of Federal law and may contaminate groundwater. If these wastes cannot be 

disposed of by use according to label instructions, contact your State Pesticide or Environmental Control 

Agency, or the Hazardous Waste Representative at the nearest EPA Regional Office for guidance.

Container Handling: Refillable container. Refill this container with pesticide only. Do not reuse this 

container for any other purpose.

Cleaning the container before final disposal is the responsibility of the person disposing of the container. 

Cleaning before refilling is the responsibility of the refiller. To clean the container before final disposal, 

empty the remaining contents from this container into application equipment or a mix tank. Fill the 

container about 10% full with water and, if possible, spray all sides while adding water. If practical, 

agitate vigorously or recirculate water with the pump for two minutes. Pour or pump rinsate into 

application equipment or rinsate collection system. Repeat this rinsing procedure two more times. Then 

offer for recycling if available, or puncture and dispose of in a sanitary landfill, or by incineration, or by 

other procedures allowed by state and local authorities.

(Storage and Disposal for nonrefillable rigid containers larger than 5 gal)
Supplemental Information for USDA Petition for Nonregulated Status of DAS-40278-9 Corn

DowAgroSciences LLC

Storage and Disposal

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

Pesticide Storage: Keep container tightly closed when not in use. If exposed to subfreezing 

temperatures, the product should be warmed to at least 40°F and mixed thoroughly before using.

Pesticide Disposal: Pesticide wastes are toxic. Improper disposal of excess pesticide, spray mixture, or 

rinsate is a violation of Federal law and may contaminate groundwater. If these wastes cannot be 

disposed of by use according to label instructions, contact your State Pesticide or Environmental Control 

Agency, or the Hazardous Waste Representative at the nearest EPA Regional Office for guidance.

Container Handling: Nonrefillable container. Do not reuse or refill this container. 

Triple rinse or pressure rinse container (or equivalent) promptly after emptying. Triple rinse as follows: 

Empty the remaining contents into application equipment or a mix tank. Fill the container 1/4 full with 

water. Replace and tighten closures. Tip container on its side and roll it back and forth, ensuring at least 

one complete revolution, for 30 seconds. Stand the container on its end and tip it back and forth several 

times. Turn the container over onto its other end and tip it back and forth several times. Empty the 

rinsate into application equipment or a mix tank or store rinsate for later use or disposal. Repeat this 

procedure two more times. Pressure rinse as follows: Empty the remaining contents into application 

equipment or a mix tank and continue to drain for 10 seconds after the flow begins to drip. Hold container 

upside down over application equipment or mix tank or collect rinsate for later use or disposal. Insert 

pressure rinsing nozzle in the side of the container, and rinse at about 40 psi for at least 30 seconds. 

Drain for 10 seconds after the flow begins to drip. Then offer for recycling if available, or puncture and 

dispose of in a sanitary landfill, or by incineration, or by other procedures allowed by state and local 

authorities.

Refer to label booklet for Directions for Use.

Notice: Read the entire label. Use only according to label directions. Before using this 

product, read Warranty Disclaimer, Inherent Risks of Use, and Limitation of Remedies at 

end of label booklet. If terms are unacceptable, return at once unopened.

In case of emergency endangering health or the environment involving this product, call 1-800-

992-5994. 

Agricultural Chemical: Do not ship or store with food, feeds, drugs or clothing.

EPA Reg. No. 62719-XXX EPA Est. _________

®

Trademark of Dow AgroSciences LLC

Produced for 

Dow AgroSciences LLC

9330 Zionsville Road

Indianapolis, IN 46268 

Net Contents _____
Supplemental Information for USDA Petition for Nonregulated Status of DAS-40278-9 Corn

DowAgroSciences LLC

(cover, shipping container):

GF-2654 TS

Herbicide

For control of broadleaf weeds in soybeans containing DAS-68416-4

Active Ingredient:

2,4-Dichlorophenoxyacetic acid, 

choline salt ....................................56.3%

Other Ingredients .......................................43.7%

Total .........................................................100.0%

2,4-dichlorophenoxyacetic acid - 38.4% - 3.8 lb/gal

Keep Out of Reach of Children

DANGER PELIGRO

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.)

Agricultural Use Requirements

Use this product only in accordance with its labeling and with the Worker Protection Standard, 

40 CFR Part 170. Refer to the label booklet under "Agricultural Use Requirements" in the 

Directions for Use section for information about this standard.

Refer to inside of label booklet for Directions for Use.

Notice: Read the entire label. Use only according to label directions. Before using this 

product, read Warranty Disclaimer, Inherent Risks of Use, and Limitation of Remedies at 

end of label booklet. If terms are unacceptable, return at once unopened.

In case of emergency endangering health or the environment involving this product, call 1-800-

992-5994. 

Agricultural Chemical: Do not ship or store with food, feeds, drugs or clothing.

EPA Reg. No. 62719-XXX EPA Est. _________

®

Trademark of Dow AgroSciences LLC

Produced for 

Dow AgroSciences LLC

9330 Zionsville Road

Indianapolis, IN 46268 

Net Contents _____
Supplemental Information for USDA Petition for Nonregulated Status of DAS-40278-9 Corn

DowAgroSciences LLC

(Page 1 through end):

Precautionary Statements

Hazards to Humans and Domestic Animals

DANGER

Corrosive • Causes Irreversible Eye Damage • Harmful If Swallowed, Inhaled Or 

Absorbed Through The Skin

Do not get in eyes, on skin, or on clothing. Avoid breathing vapor or spray mist. Wash 

thoroughly with soap and water after handling.

Personal Protective Equipment (PPE)

Some materials that are chemical-resistant to this product are made of any waterproof material. 

If you want more options, follow the instructions for category A on an EPA chemical resistance 

category selections chart.

All mixers, loaders, other applicators and handlers must wear: 

 Long-sleeved shirt and long pants

 Shoes plus socks

 Chemical-resistant gloves 

 Protective eyewear

 Chemical resistant apron when mixing or loading, cleaning up spills or equipment, or 

otherwise exposed to the concentrate

See engineering controls for additional requirements.

Follow manufacturer's instructions for cleaning/maintaining PPE. If no such instructions for 

washables exist, use detergent and hot water. Keep and wash PPE separately from other laundry. 

Engineering Controls 

When handlers use closed systems or enclosed cabs in a manner that meets the requirements 

listed in the Worker Protection Standard (WPS) for agricultural pesticides [40 CFR 170.240 

(d)(4-6)], the handler PPE requirements may be reduced or modified as specified in the WPS.

User Safety Recommendations

Users should:

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

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

clean clothing.

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

removing. As soon as possible, wash thoroughly and change into clean clothing.
Supplemental Information for USDA Petition for Nonregulated Status of DAS-40278-9 Corn

DowAgroSciences LLC

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 eye. Call a poison 

control center or doctor for treatment advice.

If on skin or clothing: Take off contaminated clothing. Rinse skin immediately with plenty of 

water for 15-20 minutes. Call a poison control center or doctor for treatment advice.

If swallowed: Call a poison control center or doctor immediately for treatment advice. Have 

person sip a glass of water if able to swallow. Do not induce vomiting unless told to do so by the 

poison control center or doctor. Do not give anything by mouth to an unconscious person.

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.

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

going for treatment.

Note to Physician: Probable mucosal damage may contraindicate the use of gastric lavage.

Environmental Hazards

This product is toxic to fish and aquatic invertebrates. For terrestrial uses: Do not apply directly 

to water, to areas where surface water is present, or to intertidal areas below the mean high water 

mark. Drift or runoff may adversely affect aquatic invertebrates and non-target plants. Drift and 

runoff may be hazardous to aquatic organisms in water adjacent to treated areas. Do not 

contaminate water when disposing of equipment washwaters or rinsate.

This chemical has properties and characteristics associated with chemicals detected in 

groundwater. The use of this chemical in areas where soils are permeable, particularly where the 

water table is shallow, may result in groundwater contamination. Application around a cistern or 

well may result in contamination of drinking water or groundwater.

Directions for Use

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

Read all Directions for Use carefully before applying.

Do not apply this product in a way that will contact workers or other persons, either directly or 

through drift. Only protected handlers may be in the area during application. For any 

requirements specific to your state or tribe, consult the agency responsible for pesticide 

regulation.
Supplemental Information for USDA Petition for Nonregulated Status of DAS-40278-9 Corn

DowAgroSciences LLC

Agricultural Use Requirements

Use this product only in accordance with its labeling and with the Worker Protection Standard, 

40 CFR Part 170. This Standard contains requirements for the protection of agricultural workers 

on farms, forests, nurseries, and greenhouses, and handlers of agricultural pesticides. It contains 

requirements for training, decontamination, notification, and emergency assistance. It also 

contains specific instructions and exceptions pertaining to the statements on this label about 

personal protective equipment (PPE), and restricted-entry interval. The requirements in this box 

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

Do not enter or allow worker entry into treated areas during the restricted entry interval (REI) of 

48 hours.

PPE required for early entry to treated areas that is permitted under the Worker Protection 

Standard and that involves contact with anything that has been treated, such as plants, soil, or 

water, is:

• Coveralls

• Chemical-resistant gloves made of any waterproof material

• Shoes plus socks

• Protective eyewear

Storage and Disposal

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

Pesticide Storage: Keep container tightly closed when not in use. If exposed to subfreezing 

temperatures, the product should be warmed to at least 40°F and mixed thoroughly before using.

Pesticide Disposal: Pesticide wastes are toxic. Improper disposal of excess pesticide, spray mixture, or 

rinsate is a violation of Federal law and may contaminate groundwater. If these wastes cannot be 

disposed of by use according to label instructions, contact your State Pesticide or Environmental Control 

Agency, or the Hazardous Waste Representative at the nearest EPA Regional Office for guidance.

Nonrefillable containers 5 gallons or less:

Container Handling: Nonrefillable container. Do not reuse or refill this container. 

Triple rinse or pressure rinse container (or equivalent) promptly after emptying. Triple rinse as follows: 

Empty the remaining contents into application equipment or a mix tank and drain for 10 seconds after the 

flow begins to drip. Fill the container 1/4 full with water and recap. Shake for 10 seconds. Pour rinsate 

into application equipment or a mix tank or store rinsate for later use or disposal. Drain for 10 seconds 

after the flow begins to drip. Repeat this procedure two more times. Pressure rinse as follows: Empty 

the remaining contents into application equipment or a mix tank and continue to drain for 10 seconds after 

the flow begins to drip. Hold container upside down over application equipment or mix tank or collect 

rinsate for later use or disposal. Insert pressure rinsing nozzle in the side of the container, and rinse at 

about 40 psi for at least 30 seconds. Drain for 10 seconds after the flow begins to drip. Then offer for 

recycling if available or puncture and dispose of in a sanitary landfill, or by incineration, or by other 

procedures allowed by state and local authorities.

Refillable containers larger than 5 gallons:

Container Handling: Refillable container. Refill this container with pesticide only. Do not reuse this 

container for any other purpose.

Cleaning the container before final disposal is the responsibility of the person disposing of the container. 

Cleaning before refilling is the responsibility of the refiller. To clean the container before final disposal, 

empty the remaining contents from this container into application equipment or a mix tank. Fill the 

container about 10% full with water and, if possible, spray all sides while adding water. If practical, 

agitate vigorously or recirculate water with the pump for two minutes. Pour or pump rinsate into 
Supplemental Information for USDA Petition for Nonregulated Status of DAS-40278-9 Corn

DowAgroSciences LLC

application equipment or rinsate collection system. Repeat this rinsing procedure two more times. Then 

offer for recycling if available, or puncture and dispose of in a sanitary landfill, or by incineration, or by 

other procedures allowed by state and local authorities.

Nonrefillable containers 5 gallons or larger:

Container Handling: Nonrefillable container. Do not reuse or refill this container. 

Triple rinse or pressure rinse container (or equivalent) promptly after emptying. Triple rinse as follows: 

Empty the remaining contents into application equipment or a mix tank. Fill the container 1/4 full with 

water. Replace and tighten closures. Tip container on its side and roll it back and forth, ensuring at least 

one complete revolution, for 30 seconds. Stand the container on its end and tip it back and forth several 

times. Turn the container over onto its other end and tip it back and forth several times. Empty the 

rinsate into application equipment or a mix tank or store rinsate for later use or disposal. Repeat this 

procedure two more times. Pressure rinse as follows: Empty the remaining contents into application 

equipment or a mix tank and continue to drain for 10 seconds after the flow begins to drip. Hold container 

upside down over application equipment or mix tank or collect rinsate for later use or disposal. Insert 

pressure rinsing nozzle in the side of the container, and rinse at about 40 psi for at least 30 seconds. 

Drain for 10 seconds after the flow begins to drip. Then offer for recycling if available, or puncture and 

dispose of in a sanitary landfill, or by incineration, or by other procedures allowed by state and local 

authorities.

Product Information

GF-2654 TS herbicide is intended for broadleaf weed control in soybeans containing the DAS68416-4 trait. 

Apply GF-2654 TS as a water spray when target weeds are actively growing. Application under 

drought conditions may give poor results. Generally, the lower dosages specified on this label 

will be satisfactory for young, succulent growth of susceptible weed species. For less susceptible 

species and under conditions where control is more difficult, use higher specified rates. Deeprooted perennial weeds such as Canada thistle and field bindweed usually require repeated 

applications for satisfactory control. Consult your State Agricultural Experiment stations or 

Extension Service Weed Specialists for recommendations from this label that best fit local 

conditions.

Use Precautions and Restrictions

Be sure that use of GF-2654 TS conforms to all application regulations.

Chemigation: Do not apply this product through any type of irrigation system.

Do not aerially apply this product.

Use of this product in certain portions of California, Oregon, and Washington is subject to the 

January 22, 2004 Order for injunctive relief in Washington Toxics Coalition et al. v. EPA, C01-

0132C, (W.D. W.A.). For further information, please refer to EPA website: 

http://www.epa.gov/espp/litstatus/wtc/index.htm.

Herbicide Resistance Management

2,4-D choline, the active ingredient in this product, is a Group 4 herbicide (synthetic auxin). Some 

naturally occurring weed biotypes that are tolerant (resistant) to 2,4-D may exist due to genetic variability 

in a weed population. Where resistant biotypes exist, the repeated use of herbicides with the same mode 

of action can lead to the selection for resistant weeds. Certain agronomic practices reduce the likelihood 
Supplemental Information for USDA Petition for Nonregulated Status of DAS-40278-9 Corn

DowAgroSciences LLC

that resistant weed populations will develop and can be utilized to manage weed resistance once it 

occurs.

Proactively implementing diversified weed control strategies to minimize selection for weed populations 

resistant to one herbicide or more is recommended. A diversified weed management program may 

include the use of multiple herbicides with different modes of action and overlapping weed spectrum with 

or without tillage operations and/or other cultural practices. Research has demonstrated that using the 

labeled rate and directions for use is important to delay the selection for resistance.

To aid in the prevention of developing 2,4-D resistant weeds, Dow AgroSciences recommends the 

following practices:

Herbicide Selection:

 Rotate the use of GF-2654 TS with non-auxin (non-Group 4) herbicides.

 Utilize a broad spectrum soil-applied herbicide as a foundation treatment.

 Utilize tank mixes of herbicides or sequential applications of herbicides with alternative modes of action.

 Avoid using more than two applications of a Group 4 herbicide, such as GF-2654 TS, within a single 

growing season unless mixed with another mode of action herbicide with overlapping spectrum.

 Apply full rates of GF-2654 TS at the specified time (correct weed size) to minimize escapes of tolerant 

weeds.

Crop Selection and Cultural Practices:

 Incorporate additional weed control practices whenever possible, such as mechanical cultivation, 

delayed planting, crop rotation, and weed-free crop seeds, as part of an integrated weed control 

program.

 Do not allow weed escapes to produce seeds, roots or tubers.

 Thoroughly clean plant residues from equipment before leaving fields suspected to contain resistant 

weeds.

 Scout fields after application to detect weed escapes or shifts in weed species.

 If resistance is suspected, treat weed escapes with an alternate mode of action or cultivation.

 Report any incidence of repeated non-performance of this product against a particular weed species to 

the local retailer, county extension agent, or Dow AgroSciences representative.

Because the presence of herbicide resistance in weed populations is difficult to detect prior to use, Dow 

AgroSciences accepts no liability for any losses that may result from the failure of this product to control 

weeds resistant to this mode of action. Incidents of non-performance should be reported to the local 

retailer, county extension agent, or Dow AgroSciences representative.

Spray Drift Management

A variety of factors including weather conditions (e.g., wind direction, wind speed, temperature, 

relative humidity) and method of application can influence pesticide drift. The applicator must 

evaluate all factors and make appropriate adjustments when applying this product.

Droplet Size

When applying sprays that contain GF-2654 TS as the sole active ingredient, or when applying 

sprays that contain GF-2654 TS mixed with other active ingredients, use drift reducing nozzle 

tips in accordance with manufacturer recommendations that produce a droplet size classification 

of coarse or coarser (ASABE S-572 standard).

Wind Speed
Supplemental Information for USDA Petition for Nonregulated Status of DAS-40278-9 Corn

DowAgroSciences LLC

Do not apply at wind speeds greater than 15 mph. Only apply this product if the wind direction 

favors on-target deposition and there are no sensitive areas (including residential areas, bodies of 

water, known habitat for nontarget species, nontarget crops) within 250 feet downwind. 

Temperature Inversions

If applying at wind speeds less than 3 mph, the applicator must determine if: a) conditions of 

temperature inversion exist, or b) stable atmospheric conditions exist at or below nozzle height. 

Do not make applications into areas of temperature inversions or stable atmospheric conditions.

Susceptible Plants

Do not apply under circumstances where spray drift may occur to food, forage, or other plantings 

that might be damaged or crops thereof rendered unfit for sale, use or consumption. Susceptible 

crops include cotton, okra, flowers, fruit trees, grapes (in growing stage), fruit trees (foliage), 

soybeans that do not contain the DAS-68416-4 trait, ornamentals, sunflowers, tomatoes, beans, 

other vegetables, and tobacco. Small amounts of spray drift that may not be visible may injure 

susceptible broadleaf plants.

Other State and Local Requirements

Applicators must follow all state and local pesticide drift requirements regarding application of 

2,4-D herbicides. Where states have more stringent regulations, they must be observed.

Equipment

All ground application equipment must be properly maintained and calibrated using appropriate 

carriers or surrogates. 

Groundboom Application

Use the minimum boom height based upon the nozzle manufacturer’s recommendations.

Mixing Directions

GF-2654 TS – Alone

Mix GF-2654 TS only with water unless otherwise directed on this label. Add about half of the water to 

the mixing tank, then add GF-2654 TS with agitation, and finally the rest of the water with continuing 

agitation. Note: Adding oil, wetting agent, or other surfactant to the spray mixture may increase 

effectiveness on weeds, but also may reduce selectivity to crops resulting in crop damage.

GF-2654 TS - Tank Mix

When tank mixing, read and follow the label of each tank mix product used for precautionary 

statements, directions for use, weeds controlled, and geographic and other restrictions. Use in

accordance with the most restrictive label limitations and precautions. Do not exceed any active 

ingredient’s maximum use rates when tank mixing. Do not tank mix this product with any 

product containing a label prohibition against tank mixing with 2,4-D.

Tank Mix Compatibility Testing: A jar test is recommended prior to tank mixing to ensure 

compatibility of this product and other pesticides. Use a clear glass quart jar with lid and mix the 

tank mix ingredients in their relative proportions. Invert the jar containing the mixture several 

times and observe the mixture for approximately 1/2 hour. If the mixture balls-up, forms flakes, 
Supplemental Information for USDA Petition for Nonregulated Status of DAS-40278-9 Corn

DowAgroSciences LLC

sludges, jels, oily films or layers, or other precipitates, it is not compatible and the tank mix 

combination should not be used.

Mixing with Liquid Micronutrient Fertilizer: This product may be combined with liquid 

micronutrient fertilizer suitable for foliar application to accomplish broadleaf weed control and 

fertilization of soybean in a single operation. Use liquid micronutrient fertilizer at rates 

recommended by the supplier. Chelated forms of micronutrient fertilizers are recommended to 

reduce potential for precipitate formation in the spray tank. Test for mixing compatibility as 

described above before mixing in a spray tank. Always read and follow directions for use and 

mixing instructions provided on micronutrient product label.

Sprayer Clean-Out

To avoid injury to desirable plants, thoroughly clean equipment used to apply this product before 

re-use or applying other chemicals.

1. Rinse and flush application equipment thoroughly after use at least three times with water. 

Dispose of all rinse water by applying to treatment area or applying to non-cropland area 

away from water supplies.

2. During the second rinse, add 1 quart of household ammonia for every 25 gallons of water or 

use commercially available tank cleaner solution. Circulate the solution through the entire 

system so that all internal surfaces are contacted (15 to 20 minutes). Let the solution stand 

for several hours, preferably overnight.

3. Flush the solution out of the spray tank through the boom.

4. Rinse the system twice with clean water, recirculating and draining each time.

5. Remove nozzles and screens and clean separately.

6. If equipment is to be used to apply another pesticide or agricultural chemical to a 2,4-D 

susceptible crop, additional steps may be required to remove all traces of 2,4-D, including 

cleaning of disassembled parts and replacement of hoses or other fittings that may contain 

absorbed 2,4-D.

Application Directions

Apply with calibrated ground equipment using sufficient spray volume to provide adequate 

coverage of target weeds or as otherwise directed in specific use directions. For best results in a 

broadcast application, use a spray volume of 10 gallons or more per acre for ground equipment. 

Where states have regulations which specify minimum spray volumes, they must be observed. 

In general, increase spray volume as crop canopy, height and weed density increase in order to 

obtain adequate spray coverage. Do not apply less than 5 gallons total spray volume per acre.

Application Rate 

The lower dosages given will be satisfactory for young, succulent growth of sensitive weed 

species. For less sensitive species and under conditions where control is more difficult, the 

higher dosages will be needed. 

Application Timing

Apply GF-2654 TS when weeds are young and actively growing.
Supplemental Information for USDA Petition for Nonregulated Status of DAS-40278-9 Corn

DowAgroSciences LLC

Weeds Controlled

1.1 Annual or Biennial Weeds

bittercress, smallflowered

buttercup, smallflowered1

carpetweed

cocklebur, common

coffeeweed

copperleaf, Virginia

galinsoga

horseweed (marestail)

jimsonweed

knotweed1

kochia

lambsquarters, common

lettuce, prickly1

mallow, little1

mallow, Venice1

marshelder

morningglory, ipomea species

mustards (except blue 

mustard)

nightshade, black1

nightshade, hairy1

pennycress, field

pepperweed1

pigweed, palmer1

pigweed, redroot1

pigweed, smooth1

purslane, common

pusley, Florida

ragweed, common

ragweed, giant

rape, wild

rocket, yellow

salsify, common1

salsify, western1

shepherdspurse

sicklepod

smartweed (annual species)1

sowthistle, annual

Spanishneedles

sunflower

sweetclover

tansymustard

thistle, Russian (tumbleweed)1

velvetleaf

waterhemp, common

1.2 Perennial Weeds

alfalfa1

artichoke, Jerusalem1

bindweed (hedge, field and 

European)1

blue lettuce

clover, red1

coffeeweed

cress, hoary1

dandelion1

docks1

dogbanes1

eveningprimrose, cutleaf

garlic, wild1

ivy, ground1

onion, wild1

sowthistle, perennial

thistle, Canada1

1May require application to small weeds, repeat applications, and/or use of higher specified rates 

of this product. 
Supplemental Information for USDA Petition for Nonregulated Status of DAS-40278-9 Corn

DowAgroSciences LLC

Specific Use Directions

Agricultural Use Requirements for Crops: For the following crop use, follow PPE and reentry instructions in the Agricultural Use Requirements section of this label.

Soybeans Containing DAS-68416-4

The directions are for use on soybeans containing the DAS-68416-4 trait. This is a patented 

gene that provides tolerance to 2,4-D choline herbicides. Information on crop varieties 

containing DAS-68416-4 may be obtained from your seed supplier.

Application Timing

GF-2654 TS

(pint/acre) Use Directions

preplant (burndown)

preemergence

1 – 2.1 Use the high rate in the rate range for less 

susceptible weeds, weeds in advanced stages of 

development, or under less favorable growing 

conditions.

Preplant: Apply anytime prior to and up 

through soybean planting to control emerged 

broadleaf weed seedlings or existing cover 

crops.

Preemergence: Apply anytime after planting 

but before soybean emerges to control 

broadleaf weed seedlings or existing cover 

crops.

postemergence

annual or perennial 

broadleaf weeds

Apply when weeds are small and soybean 

growth stage is no later than R2 (full flowering 

stage).

Make one to two applications with a minimum 

of 12 days between applications.

Restrictions:

 These directions are only for soybeans identified as containing DAS-68416-4.

 Preharvest Interval: Do not apply within 30 days of harvest.

 Do not graze treated soybean.

 Do not harvest for forage or hay.

 Do not apply more than one preemergence application and no more than two postemergence 

applications per use season.

 Do not apply more than 6.3 pints of GF-2654 TS (3 lb of acid equivalent) per acre per use 

season.

 Do not apply GF-2654 TS to soybeans later than the R2 stage.
Supplemental Information for USDA Petition for Nonregulated Status of DAS-40278-9 Corn

DowAgroSciences LLC

2. Terms and Conditions of Use

If terms of the following Warranty Disclaimer, Inherent Risks of Use and Limitation of 

Remedies are not acceptable, return unopened package at once to the seller for a full refund of 

purchase price paid. To the extent permitted by law, otherwise, use by the buyer or any other 

user constitutes acceptance of the terms under Warranty Disclaimer, Inherent Risks of Use and 

Limitation of Remedies.
Supplemental Information for USDA Petition for Nonregulated Status of DAS-40278-9 Corn

DowAgroSciences LLC

Warranty Disclaimer

Dow AgroSciences warrants that this product conforms to the chemical description on the label 

and is reasonably fit for the purposes stated on the label when used in strict accordance with the 

directions, subject to the inherent risks set forth below. TO THE EXTENT PERMITTED BY 

LAW, Dow AgroSciences MAKES NO OTHER EXPRESS OR IMPLIED WARRANTY OF 

MERCHANTABILITY OR FITNESS FOR A PARTICULAR PURPOSE OR ANY OTHER 

EXPRESS OR IMPLIED WARRANTY.

Inherent Risks of Use

It is impossible to eliminate all risks associated with use of this product. Crop injury, lack of 

performance, or other unintended consequences may result because of such factors as use of the 

product contrary to label instructions (including conditions noted on the label, such as 

unfavorable temperatures, soil conditions, etc.), abnormal conditions (such as excessive rainfall, 

drought, tornadoes, hurricanes), presence of other materials, the manner of application, or other 

factors, all of which are beyond the control of Dow AgroSciences or the seller. To the extent 

permitted by law, all such risks shall be assumed by buyer.

Limitation of Remedies

To the extent permitted by law, the exclusive remedy for losses or damages resulting from this 

product (including claims based on contract, negligence, strict liability, or other legal theories), 

shall be limited to, at Dow AgroSciences' election, one of the following:

1. Refund of purchase price paid by buyer or user for product bought, or

2. Replacement of amount of product used.

To the extent permitted by law, Dow AgroSciences shall not be liable for losses or damages 

resulting from handling or use of this product unless Dow AgroSciences is promptly notified of

such loss or damage in writing. To the extent permitted by law, in no case shall Dow 

AgroSciences be liable for consequential or incidental damages or losses.

The terms of the Warranty Disclaimer, Inherent Risks of Use and Limitation of Remedies cannot 

be varied by any written or verbal statements or agreements. No employee or sales agent of Dow 

AgroSciences or the seller is authorized to vary or exceed the terms of the Warranty Disclaimer 

or Limitation of Remedies in any manner.

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