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, 2011DRAFT 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

- dichlorop henoxy 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 EPADRAFT Under Review by US EPA


### 1. GF

- 2654 T S “Draft” Label



# GF

- 2654 TS

EPA Reg. No. 62719

- XXX



### Reg istration 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 und erstand 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 glov es

 Protective eyewear

 Chemical resistant apron when mixing or loading, cleaning up spills or equipment, or otherwise exposed to the concentrateSupplemental Information for USDA Petition for Nonregulated Status of DAS

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See engineering controls for additional requirements.

Follow manufacturer's instructions for cleaning/maintai ning 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, d rinking, 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 of f 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.

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

to water, to ar eas 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 treat ed 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, partic ularly where theSupplemental Information for USDA Petition for Nonregulated Status of DAS

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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 i ts 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 ac cording 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 th e 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 fo r 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 o r 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. Imprope r 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 Ag ency, 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 app lication 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 applicati on 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 autho rities.

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

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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 m ay 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 ri nse 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 o r 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 sanita ry 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 Warran ty 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.

Agric ultural 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 sec tion 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 Li mitation 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

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- 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

thor oughly 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 che mical 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 an d 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 cle an clothing.Supplemental Information for USDA Petition for Nonregulated Status of DAS

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- 9 Corn

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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 ad vice. 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 callin g a poison control center or doctor, or going for treatment.

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

E nvironmental 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 ar eas 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 violatio n 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

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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 requirement s 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 are as 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

• Protec tive 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 a ccording 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: Nonrefil lable 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 s econds 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 t o 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 applicati on 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

rec ycling 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,

a gitate vigorously or recirculate water with the pump for two minutes. Pour or pump rinsate intoSupplemental Information for USDA Petition for Nonregulated Status of DAS

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application equipment or rinsate collection system. Repeat this rinsing procedure two more times. Then offer for recycling if available, or puncture and disp ose 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 contai ner 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 ti mes. 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 conti nue 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 DAS

68416

- 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. D eep

rooted 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 la bel 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 re fer 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 likelihoodSupplemental Information for USDA Petition for Nonregulated Status of DAS

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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 o r 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 demonstr ated 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 m ore 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 m inimize 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

wee ds 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 c ontain 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 SpeedSupplemental Information for USDA Petition for Nonregulated Status of DAS

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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

wa ter, 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 ot her 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 p esticide 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 o r 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 w ater 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 se lectivity 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 severa l 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

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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 Micron utrient 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

rec ommended 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 flus h 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 overn ight.

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 pestici de 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 Direc tions

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

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Weeds Controlled

1.1 Annual or Biennial Weeds

bittercress, smallflowered buttercup, smallflowered 1
carpetweed cocklebur, common

coffeeweed copperleaf, Virginia galinsoga horseweed (marestail) jimsonweed

knotweed 1

kochia lambsquarters, common lettuce, prickly 1

mallow, little 1

mallow, Venice 1

marshelder morningglory, ipomea species mustards (except blue mustard)

nightshade, black 1

nightshade, hairy 1

pennycress, field pepperweed 1 pigweed, palmer 1
pigweed, redroot 1
pigweed, smooth 1
purslane, common pusley, Florida ragweed, common ragweed, giant rape, wild rocket, yellow salsify, common 1
salsify, western 1
shepherdspurse sicklepod smartweed (annual species) 1

sowthistle, annual Spanishneedles

sunflower

sweetclover tansymustard thistle, Russian (tumbleweed) 1

velvetleaf waterhemp, common

1.2 Perennial Weeds

alfalfa 1

artichoke, Jerusalem 1
bindweed (hedge, field and European) 1

blue lettuce clover, red 1

coffeeweed cress, hoary 1

dandelion 1 docks 1
dogbanes 1
eveningprimrose , cutleaf garlic, wild 1
ivy, ground 1

onion, wild 1
sowthistle, perennial thistle, Canada 1

1 May 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

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Specific Use Directions

Agricultural Use Requirements for Crops: For the following crop use, follow PPE and re

entry instructions in the Agricultural Use Requirements section of this label.

Soybeans Containing DAS

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- 4

The directions are for use on soybeans containing the DA S

- 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 t o 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

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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

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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

EXPRE SS 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 contra ry 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 applic ation, 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 los ses 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.

® TMTrademark of Dow Agr oSciences LLC EPA accepted __/__/__