REGISTRATION

87290-17 
Reg. No. 1:,7zyo-/7 

DesCrir;ttion:._NL-"--,><Ow.i-,-: :\-\~. _____________ _ 

1. /Placement within the e-Jacketljacket: 

. / Default: (cnronological, Wfl = newest) 

o File lGCatien: (PDF pa§e !'lumber, Le., "before page 

45") 

2~nd to Data Extraction contraetorsthis material: 

o Newly stamped accepted label 

~ Notification '. 

~ NewCSF 

/ o CHher: _________________ ~---

3. Attacn this coversheet to the Wfl of the material or jacket. I! 

must Be weB ~ aAEJ cIippecl~, N6'f STAPLED. 

Then give the material with this co:versheet to staff in the 

Information Services Center (Room S-49Qe~. 

Reviewer's Name: -lr~j,ce·~=-"~(_c._V<J#'--_____ _ 

Phone: J () ~ '/ J ;;(1 

Date: 9'7- L I 

Division:Qs? ).:::~ __ _ 

Created August 14, 2008 

1
UNl'fED STATES ENVIRONMENTAL PROTECTION AGENCY 

WASHINGTON, D.C. 20460 

Lori Kohler 

Wagner Regulatory Associates, Inc. 

P.O. Box 640 

7460 Lancaster Pike, Suite 9 

Hockessin, DE 19707 

Subject: EPA Reg. 87290-17/ Willowood Propanil 80DF Notification 

Dear Ms. Kohler: 

OFFICE OF CHUIICAL SAFETY 

AND POLLtiTIO:>J PREVENTION 

The Agency is in receipt of your Application for Pesticide Notification under Pesticide 

Registration Notice (PRN) 98-10 dated 4-19-11 for the product EPA Reg. 87290-17/ Willowood 

Propanil80DF. The Registration Division (RD) has conducted a review of this request for its 

applicability under PRN 98-10 and finds that the action fhlls within the scope ofPRN 98-10. The 

revised basic csf is acceptable. 

If you have any questions please call Erik Kraft at 703-308-9358 or email atKraft.Erikla:l.epa.gov. 

Sincerely, 

Kable Bo Davis 

Product Manager 25 

Herbicide Branch 

Registration Division (7505P) 

2
April 19, 2011 

Office of Pesticide Programs (NOTIF) 

Attn: Kable Davis, PM 25 

U. S. Environmental Protection Agency 

1200 Pennsylvania Ave., N.W. 

Washington, D.C. 20460 

Dear Mr. Davis; 

Re: Willowood Propanil 80DF (EPA Reg. No. 87290-17) & 

Willowood Propanil4SC (EPA Reg. No. 87290-18) 

Wagner Regulatory Associates, Inc. 

P.O. Box 640 

7460 Lancaster Pike, Suite 9 

Hockessin, Delaware 19707 

Notice of revised basic Confidential Statement of Fonnula (CSF) per PR Notice 

98-10 

Wagner Regulatory Associates, Inc., on behalf of Willowood LLC, hereby notifies the 

Agency that the producers listed in Box 2 of the CSFs have been revised per PR Notice 

98 w lO. No other changes have been made to these CSFs. 

Enclosed for the Agency's file is: 

Letter from Willowood LLC authorizing Wagner Regulatory Associates, Inc. 

to serve as Agent 

EPA Notification fonn (EPA Form 8570-1) for each product 

One copy of revised CSFs (EPA Form 8570-4) for each product 

Please feel free to contact me at (302) 234-0991 or lori@wagnerreg.comifyouhaveany 

questions or require additional information. 

Respectfully submitted, 

Lori Kohler 

Agent for Willowood LLC 

3
WIUOWOOD usa Your preferred manufacturer of post patent products 

August 31,2010 

To: Whom it-May Concern 

Re: Designaflon of Agent for: 

Witlowood USA, LLC 

1600 NW Garden Valley Blvd. 

Suite 130 

Roseburg, OR 97471 

Dear Sir or Madam: 

This letter serves as notification that WHiOWDOd USA, LLC has appointed Wagner 

Regulatory Associates, Inc. (lNRA, Inc.) to serve as the Agent on our company's behalf 

regarding all state and federal regulatory matters relative to products that Willowood 

USA, LLC will register with US EPA and the states. Please forward all correspondence 

for our company and its products to: 

Wagner Regulatory Associates, Inc. 

P.O. Box 640 

Hockessin, DE 19707-0640 

Thank you for your time and assistance. Please feel free to call me at if you have any 

questions. 

Respectfully submitted, 

Brian Heinze 

PresidentlCEO 

cc: WRA, Inc. 

1600 NW Garden Valley Blvd. Suite 130 • Roseburg, OR 97471 ·541.679.9963' FAX 541.679.4650 • www.WillowoodUSA.com 

4
Please read instructions on reverse before comp/etir" 'orm. Fonn Aoo/Oved "!~B No, 2070-0060. Aoproval exoires 05-31-98 

" )stration OPP Identifier Number 

United States c---

.oEPA Environmental Protection Agency Amendment 

Washington, DC 20460 X Other 

Application for Pesticide - Section I 

1. CompanylProduct Number 2. EPA Product Manager 3. Proposed Classification 

87290-17 Kable Davis 

4. CompanylProduct (Name) PM" [8J None Restricted 

Willowood, LLClWiliowood Propanil 80 OF 25 

5. Name and Address of Applicant (Include Zip Code) 6. Expedited Review. In accordance with FIFRA Section 3(c)(3) 

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

WHiowood, LLC to: 

clo Wagner Regulatory Associates, Inc. EPA Reg. No. 

P.O. Box 640 

Hockessin, DE 19707 Product Name: 

o Check if this is a new address 

Section -II 

D Amendment - Explain below. D Final printed labels in response to 

Agency letter dated 

D Resubmission in response to Agency letter dated D "Me Too" Application. 

ijg Notificatlon - Explain below. D Othel - Explain below. 

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

Notification of revised basic CSF per PR Notice 98-10. This notification is consistent with the provisions of PR Notice 98-10 and EPA 

regulations at 40 CFR 152.46, and no other changes have been made to the labeling or the confidential statement offormula of this 

product. I understand that it is a violation of 18 U.S.C. Sec. 1001 to willfully make any false statement to EPA. I further understand that it 

this notification is not consistent with the terms of PR Notice 98-10 and 40 CFR 152.46, Ihis product may be in violation of FIFRA and I 

may be sub'ect to enforcement action and penalties under sections 12 and 14 of FIFRA. 

Section -III 

1. Material This Product Will Be Packaged In: 

Child-Resistant Packaging U~ckagjng W~ Soluble Packaging 2. Type of Container Ii3 Yes· Yes Yes Metal 

X No X No X No Plastic 

If "Yes" No. per If "Yes" No. per Glass 

* Certification must Unit Packaging wgt. container Package wgt container Paper 

be submitted I X Other (Specify) HOPE lined bags 

3. Location of Net Contents Information 4. Size(s) Retail Container 5. Location of Label Directions 

[K] Label D Conlainer 50lb III On Label 

X On Labeling accompanying product 

6. Manner in Which Label is Affixed to Product § Uthograph c:::::::J Other - X Paper glued 

Stenciled 

Section - IV 

1. Contact Point Com lete items direct! below for idenfificafion of individual to be confacfed, if necessa ./0 rocess fhis a licafion. 

Name I Title I ~el,~~hone No. (Include Area Code) 

Lori Kohler Agent forWillowood, LLC 302 234 0991 

Certification 6. Date Application 

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

I acknowledge that any knowingly false or misleading statement may be punishable by fine or imp/isonment 01 

both under applicable law. (SUo.tTI!)e<:J) 

2.~~~ 3. Title 

Agent for Willowood, LLC 

4. Typed Name 5. Date 

· Lori Kohler April 19, 2011 · · • .. This IS a reproductIOn of EPA Form 8570 - - 1 (Rev. 8 94) PrevIous editIOns are obsolete. 

5
6
7
Material Sent for Data Extraction 

Reg # _...:...'6 '_2_QO_-....:..1....:..7 __ _ 

Descri ptio n: _.!-'!V=VP-'=----'6"-.:o.._s_, c=--t_S_I=" ______ _ 

CY Material(s) Sent to Data Extraction Contractors: 

o New Stamped Label Dated ___ _ 

o Notification Dated ____ _ 

WI New CSF(s) Dated Jvne.. 22,20LI 

o Other: _________ _ 

~ Decisio n #: __ Lj-'..5..::..· --"3.....:3_5_1'----_____ _ 

o Other ActionjComments: ________ _ 

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

must be well organized and clipped together, NOT STAPLED. 

Then give the material with this coversheet to staff in the 

Information Services Center (Room S-4900). 

Reviewer: b<0R b6hbouJ 

Phone: 347 - 807~ D ivi sio n: _-,-fZ.::..:I~=--__ _ 

Date: ~~ _______________ _ Created February 3, 2011 

8
VNlTED STATES E\fVIRO:\!VIENTAL PROTECTION AGENCY 

WASHINGTON. D.C. 20460 

Willowood USA LLC 

c/o Ms. Lori Kohler 

Wagner Regulatory Associates, Inc. 

P.O.Box 640 

7217 Lancaster Pike, Suite A 

Hockessin, Delaware 19707 

OFFICE OF C/lD/lCAL SAFETY 

A;\'D POLIXTIO'i PIlEVE;\'T10:,< 

AUG 1 8 2011 

Subject: Notification per PR Notice 98-10 - Change of Active Ingredient Source 

Willowood Propanil 80 DF, EPA Reg. No. 87290-17 and 

Willowood Propanil4 SC, EPA Reg. No. 87290-18 

Application Dated June 22, 2011 

Dear Ms. Kohler: 

The Agency is in receipt of your Application for Pesticide Notification under Pesticide 

Registration Notice (PRN) 98-10 for the subject product. 

The Registration Division (RD) has conducted a review of these requests under PRl"'J 98-10 

and finds that the actions requested are acceptable. The basic fonnulations submitted with these 

applications (dated June 22, 2011) will supersede all previously accepted basic fonnulations. 

If you have any questions, please call me directly at 703-305-1243 or Beth Benbow at 703-

347-8072. 

Sincerely, 

~e X~~ Bo Davis, Product Manager 25 

Herbicide Branch 

Registration Division (7505P) 

Office of Pesticide Programs 

9
June 22, 2011 

Document Processing Desk (NOTIF) 

AnN: Kable Davis, PM 25 

Registration Division (7504P) 

u.s. Environmental Protection Agency 

Office of Pesticide Programs 

Room 5-4900, One Potomac Yard 

2777 South Crystal Drive 

Arlington, VA 22202-4501 

Dear Mr. Davis: 

P.O. sux 640 

7217 L2ncastE',' Pike) Suite A 

r~{)Ck~ssl;1, Q",iaware 1970/ 

Subject: Willowood Propanil80 DF, EPA Registration Number 87290-17 and 

Willowood Propanil4 SC, EPA Registration Number 87290-18 

Notification of Change of Source for Technical Grade Active Ingredient per PR Notice 

98-10 

Wagner Regulatory Associates, Inc., on behalf of Willowood USA LLC) respectfully submits the following 

Notification of change of source of technical grade active ingredient for the basic Confidential Statement 

of Formula (CSF). In support ofthis notification, the following documents are attached: 

• Letter from Willowood USA LLC appointing Wagner Regulatory Associates, Inc. as its agent 

o Application for Pesticide Registration (8570-1) 

$- Confidential Statement of Formula (8570-4), 2 copies 

• Formulators Exemption (8570-27) 

Please feel free to contact me via email at lori@wagnerreg.com or telephone at (302) 635-7281 if you 

have any questions. 

Respectfully submitted) 

IIffIJ :;aJv~ Lori Kohler 

Agent for Willowood USA LLC 

Enclosures 

10
Form approved. OMB No. 2070-0060, 2070-0057, 4u70-0107, 2070-0 f22, 2070-0 f64. 

&EPA 

United States 

Environmental Protection Agency 

Washington. DC 20460 

Formulator's Exemption Statement 

(40 CFR 152.85) 

Applicant's Name and Address EPA Fite Symbol/Registration Number 

87290-17 

Willowood LLC Product Name 

c/o Wagner Regulatory Associates, Inc. Willowood Propanil 80DF 

P.O. Box 640 

Date of Confidential Statement of Formula (EPA Form 8570·4) 

Hockessin, DE 19707 

06/22/20 II 

As an authorized representative of the applicant for registration of the product identified above, I certify that: 

(f) This product contains the following active ingredient(s): 

Propanil 

(2) Of these, each active ingredient listed in paragraph (4) is present solely as the result of the use of that active ingredient in the manufacturing, 

formulation or repackaging another product Which contains that active ingredient which is registered under FIFRA Section 3, is purchased by 

us from another person and meets the requirements of 40 CFR section f58.50(e)(2) or (3). 

(3) Indicate by checking (A) or (B) below which paragraph applies: 

II (A) An accurate Confidential Statement of Formula (EPA FORM 8570-4) for the above identified product is attached to this statement. 

That formula statement indicates, by company name, registration number, and product name, the source of the active ingredient(s) listed in 

paragraph (1). 

OR 

..., (8) The Confidential Statement of Formula (CSF)(EPA Form 8570-4) referenced above and on file with the EPA is complete, current, an 

accurate and contains the information required on the current CSF. 

(4) The following active ingredients in this product qualify for the formulator's exemption. 

Source 

Active Ingredient Product Name Registration Number 

Propanil Propanil Technical 87829-1 

Si~t). 9J:P~ Name and Title Oat;--------

Lori Kohler, Agent D 06/22/2011 - EPA Form 857027 . . (Rev. 06 2004) Copy f CPA 

Copy "2 • Ap'llicant copy 

11
Please read ins/ructions on reverse b efore com· 1 form, FO/m APPIOI ,MB No. 2070-0060. ApPlova expires 05-31-98 

i.,egistration OPP Identifier Number 

i--

&EM United States 

Environmental Protection Agency Amendment 

Washington, DC 20460 X Other 

Application for Pesticide - Section I 

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

87290-17 Kable Davis 

4. Company/Product (Name) PM" l!iI None Restricted 

Wlllowood USA, LLCIWiliowood Propanil80 OF 25 

5. Name and Address of Applicant (Indude Zip Code) 6. Expedited Review. In accordance with FIFRA Section 3(c)(3) 

Willowood USA, LLC 

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

to: 

clo Wagner Regulatory Associates, Inc. EPA Reg. No. 

P,O. Box 640 

Hockessin, DE 19707 Product Name: 

o Check if this is a Hew address 

Section - II 

0 Amendment - Explain below. 0 Final printed labels in responseillU I I IIV,. 

Agency letter dated 

0 Resubmission in response to Agency lettel dated 0 "Me Too" Application. AUG 1 8 2011 

Ill! Notification - Explain below. 0 Othel - Explain below. 

Explanation: Use additional page(s) if necessary. (For Section I and Section 11.) 

Notiflcation of change of source of active ingredient per PR Notice 98-10. This notification Is consistent with the provisions of PR Notice 98-

to and EPA regulations at 40 CFR 152.46, and no other changes have been made to the labeling orthe confidential statement of formula 

of this prcxluct I understand that it is a violation of 18 U.S.C. Sec. 1001 to willfully make any false statement to EPA, I further understand 

that if this notification is not consistent with the terms of PR Notice 98-10 and 40 CFR 152.46, this product may be in violation ofFIFRA 

and I may be subject to enforcement action and penalties under seclions 12 and 14 of FIFRA. 

Section -III 

1. Material This Product Will Be PackaQed In: 

Child-Resistant Packaging U~ckaging W~Soluble Packaging 2. T e of Container Ii3 Yes' Yes Yes Metal 

X No X No X No Plastic 

If "Yes" No. per If "Yes" No. pel Glass 

* Certification must Unrt Packaging wgt. container Package wgt containel Paper 

be submitted I X Other (Specify) HOPE lined bags 

3. Location of Net Contents Information 4. Size(s) Retail Container 5. Location of Label Directions 

00 Label D Container 151bs tK3 On Label 

X On Labeling accompanying product 

6. Manner in Which Label Is Affixed to Product § Lithogcaph D Other - X Paper glued 

Stenciled 

Section -IV 

1. Contact Point (Com lete items direcfl below fot identification of individual fo be contacted, if necessary, to process tfJ/2. jlPplicatiol1. 

Name I Title I TelephQf\e, ~o" (Inciw:ie A,'e", Code) 

Lori Kohler Agent for Willowood USA, LLC (302i 625-7:.0 

Certification 6. Da(e Applir.ation 

I certify that the statements I have made on this fOfm and all attachments Ihereto ale tlUe, accurate and complete. '~e.::eived 

I acllOowledge that any knowingly false or misleading statement may be punislJable by fine or imprisonment or 

both under applicable law. (Cta,npt..d) 

2.S;9Z~~ 3, Title 

Agent for Willowood USA, LLC 

4. Typed Name 

Lori Kohler June 22, 2011 

r. ThiS Is a reproduction of EPA Form 8070-1 (Rev. 8-94) PrevIous editions are obsolete. 

12
Material Sent for Data Extraction 

Reg # __ .;;...3-,-7 ::.?_'1-'-'O'--I_,'--__ 

Desc ri pti 0 n: ____ R'-'-e::...'1~·\5-\--'-'-ro.::-"::+t"-'--"dJ-------

IZI Material(s) Sent to Data Extraction Contractors: 

New Stamped Label Dated 3/ICe/11 

o Notification Dated ____ _ 

l2J New CSF(s) Dated 62/(S/1 \ 

o Other: _________ _ 

~ Decision #: __ 4-,-,-4.=3:....:5:....:'_5_ _ 

o Other Action/Comments: ________ _ 

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

must be well organized and clipped together, NOT STAPLED. 

Then give the material with this coversheet to staff in the 

Information Services Center (Room 5-4900). 

Rev i ewer: __ -,-M.....,i.!..!n-,=,dJ..y-,O",-n!...!.d",-'",,1 s"-'h'---______ _ 

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

Date: ______ 3_/_/1_/_1_1 ________ __ 

13
~('i"'O S"r4l".o:: U.S. ENVIRONMENTAL PROTECTION AGENCY EPA Registration Date of Issuance: 

i~~ Office of Pesticide Programs Number: -

"" :.:: ill Registration Division (7504P) 

~ ~ tA ~ " ~ G ~,:,"1 

Ariel Rios Building i'iliil LJil "* ~ 87290-17 ~"'" < 1200 Pennsylvania Ave., NW "<. PRO"i'f,V Washington, D.C. 20460 

NOTICE OF PESTICIDE: Term of Issuance: Unconditional ..L Registration 

__ Reregistration Name of Pesticide Product: 

(under FIFRA, as amended) Willowood Propanil 80DF 

Name and Address of Registrant (include ZIP Code): 

Willowood USA. LLC c/o Wagner Regulatory Associates, Inc. 

1600 NW Garden Valley Blvd., Suite 130 P.O. Box 640 

Roseburg, OR 97471 Hockessin, DE 19707 

Note: Changes in labe~ng differing in substance from that accepted in connection with this registration must be submitted to and accep:ed by the 

Registration Division prior to use of the label in commerce. In any correspondence on this product alway's refer to th'e above EPA registration number. ' , 

On the basis of information furnished by the registrant, the above named pesticide is hereby registered/reregistered under the Federal Insecticide, 

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

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

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

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

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

1. Submit and/or cite all data required for registration review/reregistration of your product when 

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

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

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

The Basic and Alternate #1 Confidential Statements of Formula (CSFs) dated February 15, 2011 

are acceptable. 

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

printed label before you release the product for shipment. Products shipped after eighteen (18) 

months from the date of this Notice or the next printing of the label, whichever occurs first, must 

bear the new revised label. If these conditions are not complied WITh, the registration will be 

subject to cancellation in accordance WITh FIFRA §6(e). Your release for shipment of the product 

constitutes acceptance of these conditions. 

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

at ondish.mindy@epa.gov. 

Signature of Approving Official: 

J{~~( Date: 

Kable Bo Davis ~-- MAR , 6 2011 

v \ ~ [ 

Product Manager 25 

Herbicide Branch 

Registration Division (7505P) 

EPA Form 8570 6 . 

14
87290.17.2011031S.v1.pdf EPA Initial Registration Draft Label 

Willowood Propanil 80DF 

Propanil Herbicide 

For Postemergence Control of Broadleaf and Grass Weeds in Rice Fields 

Active Ingredient: 

Propanil: 3', 4'-Dichloropropionanilide ....................................................... 81.00% 

Other Ingredients: ...................................................................................... t9.00% 

TOTAL: ................................................................................................... 100.00% 

This product contains 0.8 lb. of active ingredient per pound of formulated product. 

EPA Reg. No. 87290-17 

EPA Est. No. 

Net Contents: 

KEEP OUT OF REACH OF CHILDREN 

CAUTION 

First Aid 

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 in eyes: 

• Hold eye open and rinse slowly and gently with water for t5-20 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 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 a poison control center or 

doctor. 

• Do not give anything by mouth to an unconscious person. 

If inhaled: 

• Move person to fresh air. 

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

respiration, preferable mouth-to-mouth, if possible. 

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

Have the product container or label w'rth you when calling a pOison control center or 

doctor, or going for treatment. 

Manufactured for: 

WiIJowood LLC 

t600 NW Garden Valley Blvd. Suite 130 

Roseburg, OR 97471 

Page 1 of 19 

ACCEPTED 

I MAR 1 6 2011 Under the Federnl Insecticide, 

! Fungicide, and Rodenticide Act 

as amended, for tlte pesticide , ! n.:glstered under 

i EPA Reg. No. Sl0l.90-n , 

15
87290.17.20110316.V1.pdf EPA Initial Registralion Draft Label 

Precautionary Statements 

Hazards to Humans and Domestic Animals 

Caution. Harmful if swallowed or absorbed through skin. Causes moderate eye 

irritation. Avoid contact with skin, eyes, or clothing. 

Personal Protective Equipment (PPE) 

Some materials that are chemical-resistant to this product are natural rubber;;: 14 

mils. If you want more options, follow the instructions for category A on an EPA 

chemical category selection chart. 

Mixers, loaders, and other handlers exposed to the concentrate must wear: 

Coveralls over long-sleeve shirt and long pants, 

Chemical-resistant gloves made of any waterproof material, 

Chemical-resistant footwear plus socks, 

Chemical-resistant headgear, if overhead exposure, and 

Chemical resistant apron. 

Applicators and other handlers exposed to the dilute must wear: 

Long-sleeved shirt and long pants, 

Shoes plus socks, and 

Chemical-resistant gloves made of any waterproof material 

See Engineering Controls for additional requirements and options. 

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

instructions for wash abies exist, use detergent and hot water. Keep and wash PPE 

separately from other laundry. Discard clothing or other absorbent materials that have 

been drenched or heavily contaminated with this product's concentrate. Do not reuse 

them. 

Engineering Controls: 

When handlers use closed systems in a manner that meet the requirements listed in 

the Worker Protection Standard (WPS) for agricuttural pesticides [40 CFR 170.240 (d) 

(4-6), the handler PPE reqUirements may be reduced or modified as specified in the 

WPS. 

Pilots must use an enclosed cockpit that meets the requirements listed in the Worker 

Protection Standard (WPS) for agricultural pesticides [40 CFR 170.240 (d)(6)]. 

Human flagging prohibited. Flagging to support aerial application is limited to use of 

the Global Positioning System (GPS) or mechanical flaggers. 

Page 2 of 19 

16
87290.17.20110316.Y1.pdf 

User Safety Recommendations 

Users should: 

EPA Initial Registration Oraft Label 

• 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. 

Environmental Hazards 

This pesticide is toxic to fish and aquatic invertebrates. Do not apply directly to water 

except as specified on this label. Do not contaminate water when cleaning equipment 

or disposing of equipment washwaters or rinsate. 

This chemical has properties and characteristics associated with chemicals detected 

in groundwater. The use of this chemical prior to flooding may result in shallow 

groundwater contamination due to cracks in the subsoil of the rice paddy. 

This product may contaminate water through runoff following rainfall events and by 

seepage through levees. Runoff of this product will be reduced by avoiding application 

when rainfall is forecasted to occur within 48 hours. Levees should be constructed 

with adequate time prior to chemical application so that they are compacted to reduce 

seepage and to hold a 3 to 6 inch flood 

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 elsewhere on the label. If terms are unacceptable, return 

at once unopened. 

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. 

Page 3 of 19 

17
87290.17.20110316V1.pdf EPA Initial Registration Draft Label 

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 restrictedentry 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 24 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 materials, 

• Chemical-resistant footwear plus socks, and 

• Protective eyewear 

Page 4 of 19 

18
87290. t7.20 t 10316.V1.pdf EPA Initial Registration Draft label 

Storage and Disposal 

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

Pesticide Storage: Do not use, pour, spill or store near heat or open flame. If the 

entire contents are not used, protect remaining material from moisture and heat. 

Resealing by rolling top down and storage under roof are recommended. Keep 

containers closed when not in use. 

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

spray mixture or rinsate is a violation of Federal Law. Wastes resulting from the use of 

this product must be disposed of on site or at an approved waste disposal facility. 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 region office for guidance. 

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

Completely empty bag into application equipment. Then, offer for recycling, if available 

or dispose of empty bag in a sanitary landfill or by incineration, or, if allowed by State 

and local authorities, by burning. If burned, stay out of smoke. 

Steps to be taken in Case Material is Released or Spilled: Sweep or shovel into 

containers for disposal or reworking. Keep dusting to a minimum. Flush contaminated 

are with a large amount of water to a chemical or sanitary sewer containing a settling 

pit. 

Product Information 

Willowood Propanil 80 DF for postemergence weed control in rice is formulated as an 

80% active dry flowable formulation. Wllowood Propanil 80 DF is not a hormone-type 

herbicide, but kills susceptible weeds by direct contact action. For this reason, 

thorough coverage of emerged weeds is essential for best results. Willowood Propanil 

80 DF has no preemergence or residual herbicidal activity. Only weeds that have 

emerged and are exposed at time of application will be controlled. Apply Willowood 

Propanil8D DF only to fields that have been drained of floodwater. Willowood Propanil 

80 DF is most effective if applied when susceptible grasses and broadleaf weeds are 

small and growing actively under favorable soil moisture and weather conditions. Early 

weed control removes weed competition from the rice crop, saves moisture, and 

generally contributes to increased yields. 

Read Mixing and Equipment label instructions before application. When tank 

mixing, always read all individual manufacturers' labels. In interpreting all labels for 

the tank mixture, the most restrictive situations must apply. 

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

Page 5 of 19 

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87290.17.20110316.v1.pdf EPA Initial Registration Draft label 

SPRAY DRIFT MANAGEMENT 

Avoiding spray drift at the application site is the responsibility of the applicator and the 

grower. The interaction of many equipment and weather related factors determine the 

potential for spray drift. The applicator and the grower are responsible for considering 

all these factors when making decisions. 

The following drift management requirements must be followed to avoid off~target drift 

movement from ground and aerial applications to agricultural field crops. 

• Apply only when the wind speed is less than or equal to 10 mph at the 

application site. 

• Apply as a medium or coarser spray (ASABE standard 572. t). 

• For ground applications, apply using a nozzle height of no more than 4 feet 

above the ground or crop canopy. 

• For aerial applications, do not apply by air if drift can occur to sensitive nontarget crops or plants that are within tOO feet of the application site. Do not 

release spray at a height greater than 10 feet above the ground or crop 

canopy. The boom length must not exceed 75% of the wingspan or 90% of 

the rotor blade diameter. Do not make any type of application into 

temperature inversions. When applications are made with a cross-wind, the 

swath will be displaced downwind. The applicator must compensate for this 

displacement at the downwind edge of the application area by adjusting the 

path of the aircraft upwind. 

Where states have more stringent regulations, they must be followed. 

The applicator should be familiar with and take into account the information covered in 

the following Aerial Drift Reduction Advisory. 

Aerial Drift Reduction Advisory 

Information on Droplet Size: The most effective way to reduce drift potential is to 

apply large droplets. The best drift management strategy is to apply the largest 

droplets that provide sufficient coverage and control. Applying larger droplets reduces 

drift potential, but will not prevent drift if applications are made improperly, or under 

unfavorable environmental conditions (see Wind, Temperature and Humidity, and 

Temperature Inversions). 

Controlling Droplet Size: 

• Volume - Use high flow rate nozzles to apply the highest practical spray 

volume. Nozzles with higher rated flows produce larger droplets. 

• Pressure - Use the lower spray pressures recommended for the nozzle. 

Higher pressure reduces droplet size and does not improve canopy 

penetration. When higher flow rates are needed, use higher flow rate 

nozzles instead of increasing pressure. 

Page 6 of 19 

20
87290.17.20110316V1.pdf EPA Initial Regis1ralion Draft label 

• Number of Nozzles - Use the minimum number of nozzles that provide 

uniform coverage. 

• Nozzle Orientation - Orienting nozzles so that the spray is released 

parallel to the airstream produces larger droplets than other orientations 

and is the recommended practice. Significant deflection from horizontal 

will reduce droplet size and increase drift potential. 

• Nozzle Type - Use a nozzle type that is designed for the intended 

application. With most nozzle types, narrower spray angles produce larger 

droplets. Consider using low-drift nozzles. Solid stream nozzles oriented 

straight back produce the largest droplets and the lowest drift. 

Application Height: Applications should not be made at a height greater than 10 feet 

above the top of the largest plants unless a greater height is required for aircraft 

safety. Making applications at the lowest height that is safe reduces exposure of 

droplets to evaporation and wind. 

Swath Adjustment: When applications are made with a cross wind, the swath will be 

displaced downwind. Therefore, on the up and downwind edges of the field, the 

applicator must compensate for this displacement by adjusting the path of the aircraft 

upwind. Swath adjustment distance should increase with increasing drift potential 

(higher wind, smaller drops, etc.). 

Wind: Drift potential is lowest between wind speeds of 2-1 0 mph. However, many 

factors, including droplet size and equipment type, determine drift potential at any 

given speed. Application should be avoided below 2 mph due to variable wind 

direction and high inversion potential. Note: Local terrain can influence wind patterns. 

Every applicator should be familiar with local wind patterns and how they affect spray 

drift. 

Temperature and Humidity: When making applications in low relative humidity, set 

up equipment to produce larger droplets to compensate for evaporation. Droplet 

evaporation is most severe when conditions are both hot and dry. 

Temperature Inversions: Applications should not occur during a local, low level 

temperature inversion because drift potential is high. Temperature inversions restrict 

vertical air mixing, which causes small suspended droplets to remain in a 

concentrated cloud. This cloud can move in unpredictable directions due to the light 

variable winds common during inversions. Temperature inversions are characterized 

by increasing temperature with altitude and are common on nights with limited cloud 

cover and light to no wind. They begin to form as the sun sets and often continue into 

the morning. Their presence can be indicated by ground fog; however, if fog is not 

present. inversions can also be identified by the movement of the smoke from a 

ground source or an aircraft smoke generator. Smoke that layers and moves laterally 

in a concentrated cloud (under low wind conditions) indicates an inversion, while 

smoke that moves upward and rapidly dissipates indicates good vertical air mixing. 

Page7of19 

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87290.17.2011031S.v1.pdf EPA Inilial Registration Draft Label 

Sensitive Areas: The pesticide should only be applied when the potential for drift to 

adjacent sensitive areas (e.g., residential areas, bodies of water, known habitat for 

threatened or endangered species, non-target crops) is minimal (e.g., when wind is 

blowing away from the sensitive areas). 

For Use on Rice Grown in California Only 

Restrictions 

• Preharvest Interval: Do not apply this product within 60 days of rice 

harvest. 

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

system. 

• Do not apply more than a maximum of 7.5 Ib of Willowood Propanil 80 DF 

(6 Ib active ingredient) per acre in a Single application or exceed 10 Ib of 

Willowood Propanil 80 DF (8 Ib of active ingredient) per acre total dosage 

per season. 

• In California: Use Willowood Propanil80 OF only where rice fields are 

completely drained or a minimal amount of water remains. If high water 

level is desired, re-flood field after 12 hours and before 7 days after 

treatment. This will discourage new weed infestations. 

• Do not apply this product to any crop other than rice. Willowood Propanil 

80 DF will cause injury to most crops except cereal grains and perennial 

grasses. 

• Do not apply this product (directly or indirectly) to wild rice (Zizania 

spp.). 

• Avoid drift or accidental application from turning aircraft on beans, 

cucurbits, cotton, soybeans, corn, safflower, seedling legumes, 

vegetables, orchards, vineyards, gardens, shrubs and ornamentals. Once 

applied, Willowood Propanil80 OF does not release fumes hazardous to 

nearby crops. 

• Applications to fields where catfish farming is practiced and drain water 

from treated fields into areas where catfish farming is practiced is 

prohibited. 

• Do not graze treated fields or feed treated forage within 60 days of the 

last application. 

• Do not rotate treated land to other crops or transplant to crops other than 

rice for 60 days following treatment of this product. 

• Do not apply this product within 14 days before or after carbamate or 

organophosphate insecticide applications. Otherwise, serious injuries to 

rice may occur. 

• Water drained from treated rice fields must not be used to irrigate 

other crops or released within 1/2 miles upstream of a potable 

water intake in flowing water (e.g. river, stream, etc,) or within 1/2 

miles of a potable water intake in a standing body of water, such as 

a lake, pond, or reservoir. 

• Do not apply when weather conditions favor drift from area to be 

treated. 

Page 8 of t9 

22
87290.17.20110316.Y1.pdf EPA Initial Registration Draft Label 

Emergency Release Provisions 

Do not discharge water from treated rice paddies in California following treatment, 

unless excessive rainfall completely submerges the rice crop and forces premature 

release, for: 

• 7 days in dry seeded rice in California 

• 7 days for water-seeded rice in California 

Weeds Controlled 

Annual sedoes evoerus SO~. 

Barnvardorass ' Echinochloa crus-oalli 

Crabgrass Digitaria SO~. 

Early watergrass ',0 Echinochloa oryzoides 

JunQlerice a E. c%num 

Late waterQrass a,a Echinochloa phvl/opoqon 

Ricefield bull rush Scirous mucronatus 

Rice flatsedoe Cvoerus iria 

Smallflower umbrella plant Cyperus difformis 

a In isolated instances, biotypes of barnyardgrass/watergrass may develop that 

cannot be effectively controlled by propanil alone. Where these biotypes are known or 

suspected to be present, and are found in a mixed weed population in which 

Willowood Propanil 80 OF is effective, tank mix Willowood Propanil 80 OF at labeled 

rate with other rice herbicides that are recommended for control of 

barnyardgrass/watergrass (up to the 3 leaf stage). 

b Applications to early and late watergrass made past the 4 leaf stage will result in 

partial control. 

Timing and Dosage 

Early Timing and Rates 

Apply Willowood Propanil 80 OF when a satisfactory stand of rice has been 

established that will tolerate flooding. The amount of Willowood Propanil 80 OF to 

apply depends upon the growth stage and condITion of the target weeds. Willowood 

Propanil 80 DF is most effective if applied when susceptible grasses and broadleaf 

weeds are small and actively growing under favorable soil moisture and weather 

conditions. Use a higher rate in the rate range for heavy weed infestations, weeds in 

advanced stages of growth, or when growing conditions are less than optimum. 

Emergency treatments made to weeds in advanced growth stages, such as when 

grass weeds are tillering, must occur at least 60 days before harvest. 

For best results, apply Willowood Propanil 80 OF at the rate of 3.75 to 5 Ib (3 to 4 Ib 

active ingredient) per acre when the grasses are actively growing in the 1 to early 4 

leaf stage. This rate will also control many seedling broadleaf and aquatic weeds. 

Page90f19 

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87290.17.20110316.V1.pdf EPA Initial Registration Draft Label 

Generally, this will be 15 to 25 days after planting. 

Mid-Timing and Rates 

Willowood Propanil 80 OF can be applied at the rate of 5 to 7.5 Ib (4 to 6 Ib active 

ingredient) per acre to actively growing grasses in the 4 to 6 leaf and early tillering 

stage, or when they are in the 2 to 4 leaf stage but stressed under dry soil conditions. 

Generally, this will be 20 to 30 days after planting. 

Use of Surfactants: The addition of a crop oil concentrate at 1 to 2 pints per acre, or 

other 80% active nonionic surfactant at a rate of 1 to 2 pints per 100 gallons of spray 

mixture, is recommended. 

Rescue Timing and Rates 

Apply Willowood Propanil 80 OF at the rate of 6.25 to 7.5 Ib (5 to 6 Ib active 

ingredient) in 15 gallons of spray per acre for emergency control of older tillering 

grass. Generally, this will be 30 to 40 days after planting. If the field is already flooded, 

the water should be lowered or drained before spraying to expose more of the grass 

and weeds. Emergency treatment should be considered as a salvage operation only 

and cannot be relied upon for total control of grass and weeds. 

Mixing Directions 

Willowood PropanU 80 OF will disperse more quickly jf water temperature is 50°F or 

warmer. Use only clean water for spraying. With the pump and agitator running, slowly 

add the specified amount of Willowood Propanil 80 OF into a partially filled mix tank. 

The jet or tank agitators must be positioned to create a rippling or rolling action on the 

liquid surface and to provide complete agitation at the bottom of the tank, preventing 

dead spots where the material can accumUlate. A centrifugal pump is suggested to 

provide additional propeller shear action for dispersing and mixing this product. To 

avoid foaming, keep filling and bypass lines below the liquid surface. Willowood 

Propanil 80 OF must be completely dispersed and mixed prior to application. 

If a tank mixture is to be applied, always conduct a compatibility test prior to use by 

mixing proportional amounts of all spray ingredients in a test vessel Gar). The order of 

addition to water should be dry flowables or wettable powders first, flowables second, 

liquid formulations third, and crop oil concentrate last. Allow for each material to go 

into solution prior to the addition of the next material. Shake the mixtUre vigorously 

and allow it to stand for frfteen minutes. Rapid precipitation of the ingredients and 

failure to re-suspend when shaken indicates that the mixture is incompatible and 

should not be applied. 

As each material is added to the spray mixture, always allow for complete mixing 

before adding the next ingredient. Add crop oil concentrate last and continue agitation 

while filling the mixing tank to the desired spray volUme. 

00 not add Willowood Propanil80 OF directly to the spray tank of aircraft. Once 

properly dispersed in mix tank, pump spray mixture to aircraft spray tank (include 

Page 10 of 19 

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87290.17.20110316.V1.pdf EPA Inilial Registration Draft Label 

rinsate from mix tank). To ensure uniformity of sprays, maintain good agitation 

throughout application. 

Application Equipment 

Aircraft 

Fixed wing aircraft or helicopters should have well~designed spray systems that 

produce a uniform pattern of medium or coarser spray droplets. Apply Willowood 

Propanil80 OF in no less than 10 gallons of total spray per acre with boom-nozzle 

sprayers. Increase volume to 12 to 15 gallons per acre for larger or denser stands of 

grass or during periods of low humidity. 

The optimum effective spray swath width depends on operating conditions and type of 

aircraft being used. For uniform spray coverage with fixed-wing aircraft or helicopter, 

spray swath width should not exceed the width of wing span or rotor plus 10%. 

Measure the swaths accurately for flagging. 

Ground Sprayers 

Use standard low-pressure herbicide boom sprayers equipped with flat fan nozzles. 

Use nozzle sizes that deliver medium or coarser droplets in 15 to 20 gallons total 

spray per acre at 40 to 50 psi and at ground speeds not in excess of 3 to 4 mph. 

Adjust boom height so nozzle spray patterns meet uniformity. Avoid raising boom too 

high. 

Flush all equipment with clear water after each day's use. Clean all equipment, 

including nurse tanks, used for Willowood Propanil 80 DF, WITh detergent wash 

followed by a water rinse, before and after spraying other pesticides or other crops. 

Crop Tolerance and Growing Conditions 

All leading commercial varieties of rice are exceptionally tolerant to Willowood 

Propanil80 OF. A temporary yellowing or tip burn of rice may be noted after treatment, 

but new growth is normal. Severe leaf burn and partial killing of rice may occur if the 

product is applied when rice is under stress and in a weakened growth condition due 

to disease or insect infestations, excessive soil salts, overwatering, or prolonged 

drought and extremely hot weather. Growers are cautioned not to spray under such 

conditions and/or when maximum daily temperatures have been or are expected to 

exceed 100°F. 

Page 11 0119 

25
87290.17.20110316V1.pdf EPA Initial Regislration Draft label 

Effect of Climatic Conditions and Cultural Practices on Weed Control 

Field and Seedbed Preparation 

Fields should be accurately leveled and contoured and have well-prepared seedbeds 

free of clods. Such conditions encourage uniform and rapid emergence of rice, grass 

and broad leaf weeds, allowing more accurate timing and coverage of Wiliowood 

Propanil 80 OF sprays for optimum weed control. 

Water Management 

Before application of Willowood Propanil80 OF, drained or dry planted fields should 

be flushed as often as necessary to prevent drying and crusting. Flushing encourages 

unifonn emergence and vigorous growth of grass, broad leaf weeds and rice, which is 

essential for optimum weed control. Flushing of fields should occur when weeds and 

rice are actively growing at time of treatment. Make sure the field is drained prior to 

treatment so that grasses and broadleafweeds are fully exposed. Weeds that are 

partially submerged in standing water at time of application wi!! not be satisfactorily 

controlled. 

Treated fields should be flooded before a second infestation of grass develops. To 

prevent additional grass weed seed from genninating, rice fields should be flooded 

within 24 hours after spraying, or as soon as possible after 24 hours. 

Temperature 

The temperature a few days before and after applying Willowood Propanil80 OF has 

an important effect on the weed-killing activity. The activity increases as daily 

maximum temperatures increase above 75°F and decreases as the daily maximum 

temperatures decline below 75T 00 not apply Willowood Propanil 80 OF when 

maximum temperatures have been or are expected to stay below '65°F or exceed 

100°F. Less than optimum temperature at time of application is not critical so long as 

the temperature exceeds 75eF during the day. 

Relative Humidity and Rain 

Grasses and weeds are more responsive to Willowood Propani! 80 OF during periods 

of high humidity when the foliage is moist or covered by dew. When the humidity is 

very low, spray tends to evaporate before reaching weed foliage. For best results 

under low relative humidity conditions, increase spray volume to 12 to 15 gallons per 

acre. Do not spray if rain is expected within 8 hours to avoid loss of deposited spray 

and herbicide adsorption by the weeds. 

Wind 

Do not apply when the wind speed exceeds 10 mph to avoid drift hazard to sensitive 

crops and the possibility of uneven (streaked) applications. 

Page 12 of 19 

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87290.17.20110316.V1.pdf EPA Initial Registration Draft Label 

Compatibility With Other Chemicals 

Tank mix applications of Willowood Propanil80 OF with other herbicides, insecticides, 

spray adjuvants, or liquid fertilizers may reduce crop tolerance and/or weed control or 

impair mixing properties. Use of these products in tank mix applications with 

Willowood Propanil 80 OF is done at the user's risk. 

Adverse Reaction to Insecticides 

Rice plants may be severely injured or killed if Willowood Propanil 80 OF is applied in 

tank mix combinations or sequentially before or after certain insecticides. Do not 

combine Willowood Propanil 80 OF with carbamate insecticides such as carbaryl, etc., 

or organophosphorus insecticides (such as malathion and methyl parathion, etc). Do 

not apply any of the carbamate or organophosphorus insecticides to rice fields within 

14 days before or after Willowood Propanil 80 OF. 

Do not apply Willowood Propanil 80 OF to rice fields planted with rice seed treated 

with bird repellents containing methiocarb. Consult local Extension specialist for 

current recommendations of approved insecticides on rice 

For Use on Rice Grown in Southern United States Only 

Arkansas, Florida, Louisiana, Mississippi, Missouri, South Carolina, 

Tennessee, Texas 

Restrictions 

• Preharvest Interval: Do not apply this product within 60 days of rice 

harvest. 

• Chemigalion: Do not apply this product through any type of irrigation 

system. 

• Do not apply more than a maximum of 7.5 Ib of Willowood Propanil 80 OF 

(61b active ingredient) per acre in a single appl"lcation or exceed 10 Ib of 

Willowood Propanil 80 OF (8 Ib of active ingredient) per acre total dosage 

per season. 

• Do not apply this product to any crop other than rice. Willowood Propanil 

80 OF will cause injury to most crops except cereal grains and perennial 

grasses. 

• Do not apply this product (directly or indirectly) to wild rice (Zizania 

spp.). 

• Avoid drift or accidental application from turning aircraft on beans, 

cucurbits, cotton, soybeans, corn, safflower, seedling legumes, 

vegetables, orchards, vineyards, gardens, shrubs and ornamentals. Once 

applied, Willowood Propanil 80 OF does not release fumes hazardous to 

nearby crops. 

• Applications to fields where catfish farming is practiced and drain water 

from treated fields into areas where catfish farming is practiced is 

prohibITed. 

Page 13 of 19 

27
87290.17.20110316.Y1.pdf EPA Initial Registration Draft Label 

• Do not graze treated fields or feed treated forage within 60 days of the 

last application. 

• Do not rotate treated land to other crops or transplant to crops other than 

rice for 60 days following treatment of this product. 

• Do not apply this product within 14 days before or after carbamate or 

organophosphate insecticide applications. Otherwise, serious injuries to 

rice may occur. 

• Water drained from treated rice fields must not be used to irrigate 

other crops or released within 1/2 miles upstream of a potable 

water intake in flowing water (e.g. river, stream, etc,) or within 1/2 

miles of a potable water intake in a standing body of water, such as 

a lake, pond, or reservoir. 

• Do not apply when weather conditions favor drift from area to be 

treated. 

Emergency Release Provisions 

·Water holding (discharge) intervals for flood water from treated rice paddies following 

treatment in the UnITed States: 

• For delayed flood (water-seeded) rice grown south of Interstate Highway 10 

from the Texas/Louisiana border to Houston and east of State Highway 35 from 

Houston to Port Lavaca- Flood water must be held for 10 days after application, 

unless excessive rainfall completely submerges the rice crop and forces 

premature release. For Texas rice grown in areas north or west of these 

boundaries, the water holding interval will be 7 days. 

• For delayed flood (water-seeded) rice in the southern Louisiana south of 

Highway 14 - Flood water must be held for 15 days after propanil application, 

unless excessive rainfall completely submerges the rice crop and forces 

premature release. For delayed flood (water-seeded) rice in Louisiana, north of 

the Highway 14 boundary, the water holding interval is 7 days. 

• For rice in CA and all other parts of the United States not mentioned aboveFlood water must be held for 7 days after application unless excessive rainfall 

completely submerges the rice crop and forces premature release. 

Weeds Controlled 

Willowood Propanil80 OF provides selective postemergence control of the following 

weeds in rice· 

Annual sedoes evoerus soo. 

Barnyardgrass a Echinoch/oa crus-gal/i 

Beakrush (spearhead) Rhynchospora cornicu/ata 

Broadleaf signalgrass Bracharia platvphvtia 

Crabgrass Diqitaria soP. 

Curlv dock Rumex crislJus 

Page14of19 

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87290.17.20110316.V1.pdf EPA Initlal Registration Draft Label 

Foxtail Setaria spp. 

GooseQrass Eleusine indica 

Gull cockspur Echinochloa crus-oavonis 

Hemp sesbania (coffeebean Sesbania herbacea 

Hoorahgrass Fimbristvlis miliaceae 

Junglerice a E. c%num 

Mexicanweed Caperonia castanaefo/ia 

Paragrass Panicum purpurascens 

Redroot piQweed Amaranthus retrof/exus. 

Redweed Melochia corchorifoJia 

Rice flatsedoe Cvoerus iria 

Smallflower umbrella plant Cyperus difformis 

Spikerush (wiregrass) Eleocharis spp. 

Texas panicum Panicum texanum 

WaterQrass a Echinochloa spp. 

Woollv croton Croton spp. 

a In isolated instances, biotypes of barnyardgrass/watergrass may develop that 

cannot be effectively controlled by propanil alone. Where these biotypes are known or 

suspected to be present, and are found in a mixed weed population in which 

Willowood Propanil 80 OF is effective, tank mix W,llowood Propanil 80 OF at labeled 

rate with other rice herbicides that are recommended for control of 

barnyardgrass/watergrass (up to the 3 leal stage). 

Timing and Dosage 

Early Timing and Rates 

Apply Willowood Propanil80 OF when a satisfactory stand of rice has been 

established that will tolerate flooding. The amount olWiliowood Propanil8D OF to 

apply depends upon the growth stage and condition 01 the target weeds. Willowood 

Propanil 80 OF is most effective if applied when susceptible grasses and broadleaf 

weeds are small and actively growing under favorable soil moisture and weather 

conditions. Use a higher rate in the rate range for heavy weed infestations, weeds in 

advanced stages of growth, or when growing conditions are less than optimum. 

Emergency treatments made to weeds in advanced growth stages, such as when 

grass weeds are tillering, must occur at least 60 days before harvest. 

For best results, apply Willowood Propanil 80 OF at the rate 013.75 to 5 Ib (3 to 4 Ib 

active ingredient) per acre when the grasses are actively growing in the 1 to early 4 

leaf stage. This rate will also control many seedling broad leaf and aquatic weeds. 

Generally, this will be 15 to 25 days after planting. 

Mid-Timing and Rates 

Willowood Propanil8D OF can be applied at the rate 015 to 7.5 Ib (4 to 6 Ib active 

ingredient) per acre to actively growing grasses in the 4 to 6 leaf and early tillering 

stage, or when they are in the 2 to 4 leaf stage but stressed under dry soil conditions. 

Page 150f19 

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87290.17.20110316.V1.pdf EPA Initial Registration Draft Label 

Generally, this will be 20 to 30 days after planting. 

Use of Surfactants: The addition of a crop oil concentrate at 1 to 2 pints per acre, or 

other 80% active nonionic surfactant at a rate of 1 to 2 pints per 100 gallons of spray 

mixture, is recommended. 

Rescue Timing and Rates 

Apply Willowood Propanil80 DF at the rate of 6.25 to 7.5 Ib (5 to 6 Ib active 

ingredient) in 15 gallons of spray per acre for emergency control of older tillering 

grass. Generally, this will be 30 to 40 days after planting. If the field is already flooded, 

the water should be lowered or drained before spraying to expose more of the grass 

and weeds. Emergency treatment should be considered as a salvage operation only 

and cannot be relied upon for total control of grass and weeds. 

Mixing Directions 

Willowood Propanil80 OF will disperse more quickly if water temperature is 50°F or 

warmer. Use only clean water for spraying. With the pump and agitator running, slowly 

add the specified amount ofWiliowood Propanil80 OF into a partially filled mix tank. 

The jet or tank agitators must be positioned to create a rippling or rolling action on the 

liquid surface and to provide complete agitation at the bottom of the tank, preventing 

dead spots where the material can accumulate. A centrifugal pump is suggested to 

provide additional propeller shear action for dispersing and mixing this product. To 

avoid foaming, keep filling and bypass lines below the liquid surface. Willowood 

Propanil 80 OF must be completely dispersed and mixed prior to application. 

If a tank mixture is to be applied, always conduct a compatibility test prior to use by 

mixing proportional amounts of all spray ingredients in a test vessel (jar). The order of 

addition to water should be dry flowables or wettable powders first, flowables second, 

liquid formulations third, and crop oil concentrate last. Allow for each material to go 

into solution prior to the addition of the next material. Shake the mixture vigorously 

and allow it to stand for fifteen minutes. Rapid precipitation of the ingredients and 

failure to re-suspend when shaken indicates that the mixture is incompatible and 

should not be applied 

As each material is added to the spray mixture, always allow for complete mixing 

before adding the next ingredient. Add crop oil concentrate last and continue agitation 

while filling the mixing tank to the desired spray volume. 

Do not add Willowood Propanil80 DF directly to the spray tank of aircraft. Once 

properly dispersed in mix tank, pump spray mixture to aircraft spray tank (include 

rinsate from mix tank). To ensure uniformity of sprays, maintain good agitation 

throughout application. 

Page 16 of 19 

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87290.17.20110316.V1.pdf EPA InNial Regis1ration Draft Label 

Application Equipment 

Aircraft 

Fixed wing aircraft or helicopters should have well-designed spray systems that 

produce a uniform pattern of medium or coarser spray droplets. Apply Willowood 

Propanil80 OF in no less than 10 gallons of total spray per acre with boom-nozzle 

sprayers. Increase volume to 12 to 15 gallons per acre for larger or denser stands of 

grass or during periods of low humidity. 

The optimum effective spray swath width depends on operating conditions and type of 

aircraft being used. For uniform spray coverage with fixed-wing aircraft or helicopter, 

spray swath width should not exceed the width of wing span or rotor plus 10%. 

Measure the swaths accurately for flagging. 

Ground Sprayers 

Use standard low-pressure herbicide boom sprayers equipped with flat fan nozzles. 

Use nozzle sizes that deliver medium or coarser droplets in 15 to 20 gallons total 

spray per acre at 40 to 50 psi and at ground speeds not in excess of 3 to 4 mph. 

Adjust boom height so nozzle spray patterns meet uniformity. Avoid raising boom too 

high. 

Flush all eqUipment with clear water after each day's use. Clean all equipment, 

including nurse tanks, used for Willowood Propanil 80 OF, with detergent wash 

followed by a water rinse, before and after spraying other pesticides or other crops. 

Crop Tolerance and Growing Conditions 

All leading commercial varieties of rice are exceptionally tolerant to Willowood 

Propanil 80 OF. A temporary yellowing or tip burn of rice may be noted after treatment, 

but new growth is normal. Severe leaf burn and partial killing of rice may occur if the 

product is applied when rice is under stress and in a weakened growth condition due 

to disease or insect infestations, excessive soil salts, ovelWatering, or prolonged 

drought and extremely hot weather. Growers are cautioned not to spray under such 

conditions and/or when maximum daily temperatures have been or are expected to 

exceed 100T 

Effect of Climatic Conditions and Cultural Practices on Weed Control 

Field and Seedbed Preparation 

Fields should be accurately leveled and contoured and have well-prepared seedbeds 

free of clods. Such conditions encourage uniform and rapid emergence of rice, grass 

and broad leaf weeds, allowing more accurate timing and coverage of Willowood 

Propanil 80 OF sprays for optimum weed control 

Water Management 

Before application of Willowood Propanil 80 DF, drained or dry planted fields should 

be flushed as often as necessary to prevent drying and crusting. Flushing encourages 

Page 17of19 

31
87290.17.20110316V1.pdf EPA Inilial Registration Draft label 

uniform emergence and vigorous growth of grass, broadleaf weeds and rice, which is 

essential for optimum weed control. Flushing of fields should occur when weeds and 

rice are actively growing at time of treatment. Make sure the field is drained prior to 

treatment so that grasses and broad leaf weeds are fully exposed. Weeds that are 

partially submerged in standing water at time of application will not be satisfactorily 

controlled. 

Treated fields should be flooded before a second infestation of grass develops. To 

prevent additional grass weed seed from germinating, rice fields should be flooded 

within 24 hours after spraying, or as soon as possible after 24 hours. 

Temperature 

The temperature a few days before and after applying Willowood Propanil 80 OF has 

an important effect on the weed-killing activity. The activity increases as daily 

maximum temperatures increase above 75°F and decreases as the daily maximum 

temperatures decline below 75"F. 00 not apply Willowood Propanil80 OF when 

maximum temperatures have been or are expected to stay below 65°F or exceed 

100°F. Less than optimum temperature at time of application is not critical so long as 

the temperature exceeds 75eF during the day. 

Relative Humidity and Rain 

Grasses and weeds are more responsive to Willowood Propanil 80 OF during periods 

of high humidity when the foliage is moist or covered by dew. When the humidity is 

very low, spray tends to evaporate before reaching weed foliage. For best results 

under low relative humidity conditions, increase spray volume to 12 to 15 gallons per 

acre. Do not spray if rain is expected within 8 hours to avoid loss of deposited spray 

and herbicide adsorption by the weeds. 

Wind 

Do not apply when the wind speed exceeds 10 mph to avoid drift hazard to sensitive 

crops and the possibility of uneven (streaked) applications. 

Compatibility With Other Chemicals 

Tank mix applications of Willowood Propanil 80 OF with other herbicides, insecticides, 

spray adjuvants, or liquid fertilizers may reduce crop tolerance and/or weed control or 

impair mixing properties. Use of these products in tank mix applications with 

Willowood Propanil 80 OF is done at the user's risk. 

Adverse Reaction to Insecticides 

Rice plants may be severely injured or killed if Willowood Propanil 80 OF is applied in 

tank mix combinations or sequentially before or after certain insecticides. Do not 

combine Willowood Propanil 80 OF with carbamate insecticides such as carbaryl, etc., 

or organophosphorus insecticides (such as malathion and methyl parathion, etc). Do 

not apply any of the carbamate or organophosphorus insecticides to rice fields within 

14 days before or after Willowood Propanil 80 OF. 

Page 18 of 19 

32
87290.17.2011031S.v1.pdf EPA Initial Registration Draft Label 

Do not apply Willowood Propanil 80 DF to rice fields planted with rice seed treated 

with bird repellents containing methiocarb. Consult local Extension specialistfor 

current recommendations of approved insecticides on rice. 

LIMIT OF WARRANTY AND LIABILITY 

IMPORTANT: READ BEFORE USE 

Read the entire Directions for Use, Conditions, Disclaimer of Warranties and 

Limitations of Liability before using this product. If terms are not acceptable, return the 

unopened product container at once. 

By using this product, user or buyer accepts the following Conditions, Disclaimer of 

Warranties and Limitations of Liability. 

CONDITIONS: The directions for use of this product are believed to be adequate and 

must be followed carefully. 

However, it is impossible to eliminate all risks associated with the use of this product. 

Crop injury, ineffectiveness or other unintended consequences may result because of 

such factors as weather conditions, presence of other materials, or the manner of use 

or application, all of which are beyond the control ofWiliowood LLC. To the extent 

consistent with applicable law, all such risks shall be assumed by the user or buyer. 

DISCLAIMER OF WARRANTIES: TO THE EXTENT CONSISTENT WITH 

APPLICABLE LAW, WILLOWOOD LLC MAKES NO OTHER WARRANTIES, 

EXPRESS OR IMPLIED, OF MERCHANTABILITY OR OF FITNESS FOR A 

PARTICULAR PURPOSE OR OTHERWISE, THAT EXTEND BEYOND THE 

STATEMENTS MADE ON THIS LABEL. To the extent consistent with applicable law, 

no agent of Willowood LLC is authorized to make any warranties beyond those 

contained herein or to modify the warranties contained herein. TO THE EXTENT 

CONSISTENT WITH APPLICABLE LAW, WILLOWOOD LLC DISCLAIMS ANY 

LIABILITY WHATSOEVER FOR SPECIAL, INCIDENTAL OR CONSEQUENTIAL 

DAMAGES RESULTING FROM THE USE OR HANDLING OF THIS PRODUCT. 

LIMITATIONS OF LIABILITY: TO THE EXTENT CONSISTENT WITH APPLICABLE 

LAW, THE EXCLUSIVE REMEDY OF THE USER OR BUYER FOR ANY AND ALL 

LOSSES, INJURIES OR DAMAGES RESULTING FROM THE USE OR HANDLING 

OF THIS PRODUCT, WHETHER IN CONTRACT, WARRANTY, TORT, 

NEGLIGENCE, STRICT LIABILITY OR OTHERWISE, SHALL NOT EXCEED THE 

PURCHASE PRICE PAID, OR AT WILLOWOOD LLC'S ELECTION, THE 

REPLACEMENT OF PRODUCT. 

Page 190f19 

33
REGISTRATION NOTE FOR RECORD 

EPA Reg. No.1 File Symbol: 87290-RT (17) 

Product Name: Willowood Propanil 80DF 

Application Date: 12/17/10 

Action Description: R300 

PRODUCT CHEMISTRY: (DP386236; 2/14/11) 

Revised basic & alternate #1 CSFs 2/15/11 

Submitted own product chemistry studies (MRID 48333401-03) 

Substantially similar to Reg# 70506-166 

Data Gaps: Storage Stability & Corrosion Characteristics 

ACUTE TOXICITY: (DP386237; 2/23/11) 

Using cite-all method of acute tox data support 

Substantially similar to Reg# 70506-166 

The tax review could not find the tax profile for the cited product; however a search in 

the database found a tox review dated 5/21/07 DP339978 for reregistration of the cited 

product with the following tax categories: 

Tox Category III for Acute Oral, Acute Dermal, and Primary Eye Irritation 

Tox Category IV for Acute Inhalation and Primary Dermal Irritation 

Not a Skin Sensitizer 

GENERIC DATA: 

Fonmulator's exemption for propanil 

LABEL REVIEW: 

Similar to Reg# 70506-166; 81 % propanil dry flowable for postemergence use in rice 

Revised label submitted 3/16/11 

COMMENTS: 

DECISION: 

Unconditional Registration with Data Requirements 

Reviewer: I Mindy Ondish I Date: I 3/16/11 

34
OP BARCODE No.: 0386236 F!LE SYMBOL No.: 87290-RT PRODUCT NAME: Wi!!owood Propanil 80 OF 

DECISION No.: 443515 PC Code(s): 028201 ACTION CODE: R 300 FOOD Use: Yes 

DATE OUT: 

SUBJECT: 

February 14, 2011 

End Use Product Chemistry Review 

Product Name: Willowood Propanil 80 OF 

) 

Shyam Mathur, ~ » ,,-j2:v,~ 1 

Product Chemistry Team Leader D 6~'V, \ ') !:.UIJ / rji---; ____ Technical Review Branch/RO (7505P) ~~) \ \J\ \ \ 0( P ~ 

FROM: 

Mindy Ondish I Linda Arrington, RM 25 , / ~3 7)/ Herbicide Branch I RD (7505P) .?-( ~ 

TO: 

Company Name: 

Formu!ation Type: 

INTRODUCTION: 

Wi!!owood LLC 

Dry Flowable (DF) 

The registrant has submitted an application for the registration of the new end use product 

Willowood Propanil80 OF. In support of the registration application, the registrant has submitted 830 series 

group A & group B data with MRIO Nos. 483334-01 through 483334-03. The registrant has also submitted 

CSF's for basic & alternate formulations (both dated 12-17-10) and the product !abel. On the advice of the 

Agency, the registrant submitted a revised basic CSF and alternate CSF #1 (both dated 2-15-11). The 

registrant has claimed that the proposed product is substantially similar to registered product with Reg. No. 

70506-166. TRB has been asked to determine the acceptability of the product chemistry data submitted to 

support the proposed revised basic & alternate CSF's and also determine the substantial similarity to the 

registered product. 

SUMMARY OF FINDINGS: 

1. Name of Active Ingredient(s): Propanil (81.0%) 

2. The registrant claims this product is substantially similar in composition to Reg. No. 70506-166. 

3. All of the source materials of the active ingredient are derived from registered sources- [Xl Yes [ 1 No 

4. All inert ingredients have been screened by IIAB (12-27-10) and found to be approved for the proposed 

labeled uses. 

5. Confidential Statement of Formula{s): 

[Xl Basic - Dated: 12-17-10; Re-submitted: Dated - 02-15-11 

[Xl Alternate CSF' #1 - Dated: 12-17-10; Re-submitted: dated - 02-15-11 

Alternate CSF(s) complies with 40CFR§152.43: [X] Yes [1 No [ 1 NA 

1 

35
DP BARCODE No.: 0386236 FILE SYMBOL No.: 87290-RT PRODUCT NAME: WiI!owood Propanil 80 OF 

DECISION No.: 443515 PC Code(s): 028201 ACTION CODE: R 300 FOOD Use: Yes 

6. Product label 

a. Ingredient statement: Nominal concentration of AI listed on CSF(s} concurs with product label (PR Notice 

91-2). 

[Xl Yes, jf not, explain below: 

Metallic equivalent: [ 1 Yes [Xl NA; 

Soluble arsenic: [[ Yes [Xl NA 

Isomeric ratios: [J Yes [Xl NA 

b. Health related sub statements: Product contains? 

Petroleum distillate at > 10%: [l Yes [XJ No [ 1 NA 

Methanol at > 4%: [ 1 Yes [Xl No [ 1 NA 

c. Physical chemical hazard statement: Product label requires a statement per 40 CFR §156.78 for: 

flammability, explosive potential or electric insulator breakdown? 

[[Yes [X[No 

Is the sub statement in compliance with 40CFR§156.78 [Xl NA, if not, explain below: 

d. Label requires an additional Storage and Disposal statement: [ [Yes [Xl No; if yes explain below: 

2 

36
DP BARCODE No.: 0386236 FILE SYMBOL No.: 87290~RT PRODUCT NAME: Willowood Propanil 80 DF 

DECISION No.: 443515 PC Code(s): 028201 ACTION CODE: R 300 FOOD Use: Yes 

7. Group A: Product Chemistry Data 

TRB's determination of the acceptability for the proposed product is listed in the tables below. 

Data submitted 

TRB's Guideline 

No. Study Title Assessment MRID Nos. 

Yes No 

of Data 

Product Identity & Composition 

830.1550 X A 483334-01 

Description of materials used to 

830.1600 produce the product X A 483334-01 

Description of formulation 

830.1650 process X A 483334.()1 

Discussion on the formation of 

830.1670 impUrities X A 483334.()1 

830.1700 Preliminclry analysis NA 483334-01 

Standard certified Proposed 5% limits 

limits X A for the AI instead of 

Certified 3% with 

limits Proposed Limits X A justification. 

(158.350) Justification for Standard limits 

wider limits have been 

proposed for the 

inert ingredients. 

830.1750 X A 483334-02 

Enforcement analytical method 483334-02 

830.1800 X A GC-FID (IS) 

A = Acceptance, N = Not Acceptable, G = Data Gap, W = Waiver Request, I = In Progress, NA = Not 

Applicable 

3 

37
DP BARCODE No.: 0386236 FILE SYMBOL No.: a7290-RT PRODUCT NAME: Willowood Propanil 80 OF 

DECISION No.: 443515 PC Code(s): 028201 ACTION CODE: R 300 FOOD Use: Yes 

a. Group B: 

Guideline Study Title Value or Qualitative TRB's MRID Nos. 

No. Description Assessment 

of Data 

830.6303 Physical State Solid (extruded granules) A 483334·03 

830.6315 Flammability NA A 483334·03 

830.6316 Explodability NA A 483334·03 

830.7000 loH 9.22 A 48333~·03 

830.7300 Density (units) 0.575 g!ee (35.9 Ibs!cu. ft.) A 483334·03 

A = Acceptance, N = Not Acceptable, G = Data Gap, W = Waiver request, NA = Not applicable, I = In 

progress. 

Note: 830.6314 - The test substance showed an increase in temperature of aoc when mixed with 

Potassium permanganate (5%). 

4 

38
DP BARCODE No.: 0386236 FILE SYMBOL No.: 87290~RT PRODUCT NAME: WiI1owood Propanil 80 DF 

DECISION No.: 443515 PC Code(s): Q28201 ACTION CODE: R 300 FOOD Use: Yes 

CONCLUSIONS: 

The TRB has reviewed the product chemistry data submitted for the proposed end~use product and has 

concluded that: 

1. The proposed revised CSF's for basic formulation & alternate formulation #1 (both dated 02~15~11) are 

acceptable. 

2. The data submitted corresponding to guidelines 830.1600 (description of materials used to produce the 

product), 830.1650 (description of formulation process), and 830.1670 (discussion on the formation of 

impurity), 830.1750 (certified limits) and 830.1800 (enforcement analytical method) are acceptable. Based on 

the justification provided, the proposed non-standard certified limits (5% instead of 3%) for the acflve 

ingredient are acceptable. 

3. The product chemistry data submitted corresponding to guidelines 830.6302 (color), 830.6303 (physical 

state), 830.6304 (odor), 830.6314 (oxidation/reduction), 830.6315 (flammability), 830.6316 (explodability), 

830.7000 (pH), and 830.7300 (density) are acceptable. 

4. The registrant must submit the results of one year storage stability (830.6317) and corrosion 

characteristics (830.6320) stUdies on completion. It is recommended that observations should be made at 0, 

3,6, g, 12 months intervals. According to the applicant, these studies are in progress. 

5. The proposed product with File Symbol No. 87290~RT was determined to be substantially s'lmilar to the 

cited product with Reg. No. 70506~ 166 from the product chemistry point of view. 

5 

39
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 

WASHINGTON, D.C. 20460 

Office of Chemical Safety and 

Pollution Prevention 

February 23, 2011 

MEMORANDUM 

Subject: 

From: 

To: 

Applicant: 

Name of Pesticide Product: Willowood Propanil80 DF 

EPA File Symbol: 87290-RT 

DP Barcode: 0386237 

Decision No.: 443515 

Action Code: R300 

PC Code: 028201 Propanil 

Breann Hanson, Biologist g ~~ c" 

Technical Review Branch (TRB) !i'/ e:L:: 

Registration Division (RD; 7505P) 11' d_~ 

Mindy Ondish, RM Team 25 

Herbicide Branch 

Registration Division (7505P) 

Willowood, LLC 

c/o Wagner Regulatory Associates, Inc. 

PO Box 640 

Hockessin, DE 19707 

FORMULATION FROM LABEL: 

Active Ingredient: 

028201 Propanii CAS No. 709-98-8 

% bywt 

81.00 

Other Ingredients: 20.00 

Total: 100.00%* 

* According to submitted label; ingredieuts do not add up to 100% 

40
PC Code: 028201 

EPA File Symbol: 87290-RT 

ACTION REQUESTED: The Risk Manager requests: "New registration for 81 % propanil EP, claiming 

substantial similarity to Reg# 70506-166. Submitted own product chemistry studies and basic and 

alternate CSFs dated 12/17/2010. Using cite-all method to support acute tax data. Provided proposed and 

cited labels and CSFs. Please review ... " 

BACKGROUND: Willowood, LLC (herein the "registrant") has applied for registration of Willowood 

Propanil80 DF, EPA File Symbol: 87290-RT, claiming similarity to Starn 80 EDF, EPA Reg. No. 70506-

166. Both the proposed and cited products are labeled for post-emergence weed control in rice. Included 

in the data package were the label and basic and alternate #1 CSFs for the proposed product (CSFs dated 

12/17/2010), label and basic CSF for the cited product (CSF dated 8/22/2007), application and letter from 

the registrant. The registrant is claiming the "cite-all" method of support for acute toxicity data 

requirements. 

A memorandum detailing the acute toxicity studies reviewed which support 70506-166 cannot be located 

in any Agency database. 

COMMENTS AND RECOMMENDATIONS: 

1. TRB has evaluated the fonnulations of the proposed product, 87290-RT, and the cited product, 70506-

166, and has detennined that they are substantially similar in toxicity. In addition, the cited and proposed 

product labels are substantially similar in labeling of use sites. The acute toxicity data reviewed for 

registration of70506-166 can be bridged to 85678-RT. 

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

the cited product from an acute toxicological view point. For the purposes of this action, TRB has made 

no detenninations of the adequacy of the toxicological data base orthe precautionary label of the cited 

product. 

Page 2 of2 

41
UNITL,J STATES ENVIRONMENTAL PROTECTIl,.rI'-l AGENCY 

WASHINGTON, D.C. 20460 

December 28, 2010 

JAMES M. WAGNER 

WAGNER REGULATORY ASSOCIATES, INC. 

WILLOWOOD USA, LLC 

PO Box 640 

HOCKESSIN, DE 19707-0640 

Report of Analysis for Compliance with PR Notice 86-5 

OFFlCEOF 

PREVENTION, PESTICIDES AND 

TOXIC SUBSTANCES 

Thank you for your submittal of20-DEC-l o. Our staff has completed a preliminary 

analysis ofthe materiaL The results are provided as follows: 

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

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

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

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

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

Manager, to whom the data have been released. 

42
1. 

2. 

3. 

4. 

DATA TRANSMITTAL DOCUMENT 

Name and Address of Submitter 

Wi!lowood, LLC 

clo Wagner Regulatory Associates 

PO Box 640 

Hockessin, DE 19707 

Regulatory Action In Support Of Which This Package Is Submitted 

Application for Registration 

WiUowood Propanil80 OF 

Transmittal Date 

December 17, 2010 

List of Submitted Studies 

~~.--.-------... ~--.--- .... ~~.--.----,==---.----------

48333401 Vol. 1: Wagner Regulatory Associates, Inc. (2010) WiJJowood Propani180 OF 

Product Identity and Composition, Description ofBegillning Materials, Manufacturing 

Process, and Discu,ssion ofFonnation ofhnpurities. Willowood, LLC, Roseburg, OK 

NOll-confidential portion 6 pages, Confidential portion 46 pages. 

-48-333'4-:0:-2---V;;r2:\.Vagner-Re~iatory A'ssociates, Inc:-(201O) wfilowood PropanilSO-Oit--

Preliminary Analysis, Celtified Limits aud Enforcement Analytical Method. 

Willowood, LLC, Roseburg, OR. Non-confidential pOltion 6 pages, Confidential 

portion 15 pages . 

. _---"_._---"" .. -_._--------"-"."-" .. --_. _. __ ._-._."."--_._._ .... _-

48333403 Vol. 3: Miller, Ronald (20ID) Propanil 80 DF Product Chemistry Volume Ill. 

Analytical & Regulatory Chemistry, Inc., Sumter, South Carolina. Report Number 

ARC~EX-858~004-P-1. 14 pages. 

Company Official: 

Company Name: 

Company Contact: 

Catherine M. Byrd 

Name 

Wagner Regulatory Associates, Inc, 

Agent for WiHowood, LLC 

Catherine M. Byrd 

Name 

Signature 

(302) 234-2780 

Phone 

483334-00 

43
PRIA 2 - 21 Day Content Screen Review Worksheet 

(EPA/OPP Use Only) 

3123109 

21 Day Screen Start Date: 12 - 2" - / 0 

Experts In-Processing Signature: JVl E t./,qlt~ liJ(. 701.1 Date I Z - 23 -16 Fee Paid: Yes 

• Division management contacted on issues No Yes Date ______ _ 

EPA Reg. Number: If 7 '2 ? 0 ~ r<.. T EPA Receipt Date: /7.. - 20 -/0 

1 

2 

3 

Item's for Review Yes No N/A* 

Application Form (EPA Fonn 8570¥ 1 )(link to form) signed & complete 'Vincluding package type 1'\ 

Confidential Statement of Formula all boxes completed, form signed, and 'v 

dated 1\ 

a) All inerts (link to http://www.epa.gov!opprdOOllinerts/), 

including fragrances, approved for the proposed uses (see 

Footnote 

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

form) completed and signed (N/A if 100% repack) >:. 

Certificate and data matrix consistent 

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

to pay statement included. (see Footnote B) 

If 

yes 

Formulator's (EPA to form) 

no 

4 and signed (N!A if source is unregistered or applicant owns the 

5 

6 

Data Matrix (EPA Form 8570~35) (Link to form) both internal and external 

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

a) Selective Method (Fee 

b) Cite~All (Fee category experts use) 

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

5 Copies of Label (link to http://www.epa.gov/oppfeadl/labeling/lrm/) 

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

http://www.epa.gov/pesticides/regulating!registering/submissions/index.htm #Iabels 

I 

44
7 Is the data package consistent with PR Notice 86-5 (link to PRN 86-5) .~ 

Notice of Filing (link to 

8 httI!:/lwww.eI!3.gov/I!esticides/regulating/tolerance I!etitions.htm) included X with petitions (link to 

http://www.epa.govipesticidesiregulating/tolerances.htm) 

9 If applicable for conventional applications, reduced risk rationale (link to )( http://www.epa.gov/opprdOOl/workplan/reducedrisk.html) 

Required Data (link to 

h ttl!:/ /www.ena. go v/~esticides/regulatineldata reguirements.htm) and/or 

data waivers. See Footnote C. 

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

10 

2 

45
Comments: :50 "',«l ")~;,\e\;~> ~IL ),')jd ; A tk kelt 0+ \k :s1"J,'~ 

,,0+ (p,~vi,,,,,,\ ""' \"" \"oJvct: ~3o'17o')G3\5;b3[,,}G3\'\J(,3;>'\~l7\bO, 

\<v~~;T ~D \k ?"\ "" ded~'- ,"",," ~o f'OGGod., 'i13 0 ,G3170,.d (,";:co 

""v \ I"J\ C1..J. 0> uY'>.J.<,{N<'1 . 

\ f"~:{e~Ie"'~-;:' O~ \'IA~ \~ 1,,,\ do "k ~Jj U'f 'to IDO!,;, \\eT h,,\ '\5 ",,"," >,,,,<-\~':, '~<;r -...-Jh/\..l" W~\VL \,'t-{' " \ ,"-$\1'" I2k?A \-0 

C",l\ \'v't- ~ ". ~ vJ ~\"'- + \. I:>r> '" ;\- \.0 +\.,c. r:> _M '.:i <" \-\ e'r\ tl' C!'l. 

"3\",c\ll> p"'-505C(\ 06--5 "(2,0,,),t.0

' 

... \ ('-- --\0 c\ u,):: ,r, flJi,. 

-:s,::VH?{.lr> 0fr(b\JC" tor 0 

_}"" '5' "...,~::> c-''; i"..s . 

JQck~-+- \:,;\eeJ. (JV.L J,-'c C(\'--\+('A\--~' 

* N/A - Not Applicable 

Footnotes 

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

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

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

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

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

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

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

CSF and may require submission of data. All infonnation, forms. data and 

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

application withdrawn within the 21 day period, otherwise, the Agency will reject the 

application as described below. 

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

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

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

3 

46
site [link to http://www.epa.gov/opprdOOllincrtsllists.html] and if the inert is not 

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

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

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

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

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

delays. 

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

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

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

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

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

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

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

Microbial Pesticides Branch [Link to 

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

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

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

information [link to http://www.epa.gov/opprdOOllinerts/tips.pdfJmustalso be included 

to enable the Agency to determine if it has been approved. Each component of an inert 

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

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

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

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

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

cannot or are not identified or provided within the 21-day content review period, the 

Agency will reject the application. 

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

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

Unapproved Inerts Identified on CSFs 

All applications except conventional new products and PIPs 

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

applicant with the following options: 

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

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

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

approved for the application's uses; or 

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

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

request an extension in the PRIA decision review timeframe to accommodate 

the inert review/approval process; 

4 

47
3. Withdraw the application (the Agency retains 25% of the full fee for the fee 

category estimated); or 

If none of these options is selected and implemented by the applicant within the 

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

25% of the full fee of the category identifIed. 

Conventional New Product Applications 

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

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

inert approval (R311, R312 or R313), it will contact the applicant with the 

following options: 

1. COlTect the application by, for instance, cOlTecting the inert's identity or CAS 

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

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

approved for the application's uses; or 

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

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

tolerance or exemption from a tolerance. (This option may change the PRIA 

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

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

Agency within the 21 day content review period.) 

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

category estimated); or 

If none of the above options is selected and implemented during the 2I-day 

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

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

PIP Applications 

When the Biopesticide and Pollution Prevention Division identifies an 

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

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

options: 

1. COlTect the application by, for instance, correcting the spelling or name of the 

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

approved; or 

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

unapproved inert. If an inert ingredient tolerance exemption petition is 

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

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

Agency will discuss hannonizing the timeframe for both actions. 

5 

48
3. Withdraw the application (the Agency retains 25% of the full fee for the fee 

category estimated); or 

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

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

the fee. 

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

me-too or fast track (similar/identical) new product, R300 or A530, an application 

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

A531. The Agency recommends that authorizations of offers to pay be submitted with 

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

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

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

should be submitted with the study waiver. 

6 

49
ISB'S Front-end PRlA Completeness Screen 

Draft 3; 10/25107 

r-'~-I~~ Receipt Date: I;'/.fl pi 0 EPA Reg. Number. F7d 90 -,<! r -- Check.ListIt~ Yes No 

1 Has the PRIA Fee been Paid; is a copy of the check or 

Puy.gov receipt included in the Submission Package? 0./" ... - -

I, an Application Form (EPA Form 8570-1) Included in the 

2 Submission Package, is it completely filled out and signed V 'including package type? 

-.---

1::; a Confidential Statement of Formula (EPA Fonn 8570-

3 29) Included in the Submission Package, is it completely 

lilled out and signed (boxes l-21)? 

,/ 

4 Is a Formulator's Exemption Statement (EPA Foun 8570- V 27) Included in the Submission Package? .,---" 1--

5 Is Cl Certification with Respect to Citation of Data (EPA 0./" 

Form 8570-34) Included in the Submission Package? --- , 

~- Is a Data Matrix (EPA Form 8570-35) Included in the ,/ Submission Package? I 

L 7 is a Label Included in the Submission Package? VL~ Arc Data Included in the Submission Package? v 

I " L __ Is the Submission an Amendment? 0./" 

I 

NiA 

I 

I I 

I 

I 

50
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 

WASHINGTON, D.C. 20460 

December 23,2010 

OPP Decision Number: D-443515 

EPA File Symbol or Registration Number: 87290-RT 

Product Name: WILLOWOOD PROP ANIL 80 DF 

EPA Receipt Date: 20-Dec-2010 

EPA Company Number: 87290 

Company Name: WILLOWOOD USA, LLC 

CATHERINE BYRD 

WAGNER REGULATORY ASSOCIATES, INC. 

WILLOWOOD USA, LLC 

POBox 640 

HOCKESSIN, DE 19707-0640 

OFFICE OF 

PREVENTION, PESTICIDES AND 

TOXIC SUBSTANCES 

SUBJECT: Receipt of Registration Application Subject to Registration Service Fee 

Dear Registrant: 

The Office of Pesticide Programs has received your application and certification of 

payment. If you submitted data with this application, the results of the PRN-86-5 screen will be 

communicated separately. During the administrative screen, the Office of Pesticide Programs 

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

the Pesticide Registration Improvement Act. 

The Action has been identified as Action Code: R300 

NEW PRODUCT;ME-TOO PRODUCT FAST TRACK; 

No additional payment is due at this time. 

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

Ombudsman at (703) 308-9362. 

~/ Sincerely, L----<----:::---~r-;;; ,-

Fron!--End-Proc'" si;lg--Sta ~-

/nilirmati07lll1010 & Resources Management Division 

, 

/ l, / 

! 

51
IFee for Servicel (887645KThis package includes the following 

@ New Registration 

°Amendment 

:; Studies? o Fee Waiver? 

o volpay % Reduction: __ 

for Division 

°AD 

°BPPD 

@RD 

Risk Mgr. []I] 

Receipt No. s-I 887645 

EPA File Symbol/Reg. No. I 87290-RT 

Pin-Punch Date: I 12/20/2010 

This item is NOT subject to FFS action. , 

"Action Code: Parent/Child Decisions: . 

Requested: [Paw [ 

Granted: [K3DO [ 

= Amount Due: $ It.{:,q- i I 

, 

1;vvrb ~-f'f'(I~."J'---izf/t 1::t/:?..7/lo - -

j)(l Inert Cleared for Intended Use 0 

Reviewer: cKvYYloYikJ 

Remarks: ~-

Uncleared Inert in Product 

Date: I ~ /lsl/v 

52
53
FEE FOR SERVICE 

54
I of 1 

/ ~ Online Payment https:llwww,pay.gov/paygov/naymentsiauthori zePlas ticCardPa yrncnt hIlT 

QnUn<.> Paymonl 

Step 3: Confirm Paymelll 11213 

Th,mk you. 

Your transacIion has bean successfully completed. 

Pay,gov Trocklng Inform.tlon 

Applk.tlon Name: PRI .... S~,,<ce F~e3 

Pay.gov Tracking 10: 2524PEJH 

Agency Trocklng 10: ;4160;?23I6i3 

Tr"n,~ction O~\(l and Timo: 1211;12010 '15,t9 EST 

P~ymcnt Summ.ry 

Addr<lss Intorm.llon 

Aocount Hold~r Name: Bri.n Hoi""" 

Billing Address: 1600 NV/Gard.n Vs!ley BI,;j 

BlllingAdd,..,5S 2: Sle 130 

City: RO$~burg 

Sl;;1t~ I Plovlnce: OR 

Zip 1 Postol Code: 9?47t 

Country: USA 

Account InformOilon 

Cud Typo: Masl.rCmd 

C.rd Number: '~''''''''-eOO5 

Oed.loll Number: 

Regi.tr.Uon Nunlbi/f: 

Company N.m@:V"illo,,"<lodLLC 

Company Number: 8;290 

AcUon Codc: R~OO 

P.ym"n1lnforma~on 

PaymontAmounl; $1,434 00 

Transaction O.le .nd Time: t21t7120 lOIS' 19 EST 

12!f7i20 103: 19 Plv 

55
W!L 

WlllOWOOD usa Your preferred manufacturer of post patent products 

August 31, 2010 

To: Whom itMay Concern 

Re: Designation of Agent for: 

Willowood USA, LLC 

1600 NW Garden Valley Blvd. 

Suite 130 

Roseburg, OR 97471 

Dear Sir or Madam: 

This letter selVes as notification that Willowood USA, LLC has apPointed Wagner 

Regulatory Associates, Inc. (WRA, Inc.) to serve as the Agent on our company's behalf 

regarding all state and federal regulatory matters relative to products1hat Willowood 

USA, LLC will register with US EPA and the states. Please forward all correspondence 

for our company and its products to: 

Wagner Regulatory Associates, Inc. 

P.O. Box 640 

Hockessin, DE 19707·0640 

Thank you for your time and assistance. Please feel free to call me at if you have any 

questions. 

Respectfully submitted, 

Brian Heinze 

PresidentlCEO 

cc: WRA, Inc. 

1600 NW Garden Valley Blvd. Suite 130 • Roseburg, OR 97471 ·541.679.9963' FAX 541.679.4650 • www.WillowoodUSA.com 

56
Certification with Respect to Label Integrity 

version: 9/11102 

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

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

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

included with this submission. 

IPROPOSED LABEL 

Date Submitted 

EPA Registration # to EPA Electronic file name 

87290-XX 12(17(2010 87290.XXXXX.20101217.Vl.pdf 

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

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

punishable by fine or imprisonment or both under applicable law. 

Signature 

Catherine M. Byrd 

Name (typed) 

Agent for Willowood, LLC 

Title 

12/17/2010 

Date 

57
1. 

2. 

3. 

4. 

DATA TRANSMITTAL DOCUMENT 

Name and Address of Submitter 

Willowood, LLC 

clo Wagner Regulatory Assoc'lates 

PO Box 640 

Hockessin, DE 19707 

Regulatory Action In Support Of Which This Package Is Submitted 

Application for Registration 

Wtllowood Propanil 80 DF 

Transmittal Date 

December 17, 2010 

List of Submitted Studies 

Vol. ==""-""-"""--""""" I: Wagner Regulatory Associates, Inc. (2010) Willowood Propanil SO DF 

I)roduct Identity <Iud Composition. Description of Beginning Materi<lls. Manufacturing 

Process, and Discussion of Formation of Impilrities. WillolVood, LLC, Rosebmg. OR. 

Non-confidential portion 6 pages, Confidential portiol) 46 pages. 

Vol. 2: Wagner Regulatory Associates, Inc. (2010) Willowood Propanil 80 OF 

PreJimilJary Analysis, Celtified Limits and Enforcement Analytical Method. 

Willowood, LLC, Roseburg, OR. Non"coutldential portion 6 pages, Contldential 

portion 15 pages. 

---"""""--,,"""-""""-"""-""""""-""-""" .-:=;;-;;C"" """"""""""-""""-""""-",,,,,,-,, """,,-,,,,-""" 

Vol. 3: Miller, Ronald (20 I 0) Propanil 80 DF Product Chemistry Volume HI. 

Analytical & Regulatory Chemistry, Inc., Sumter, South Carolina. Repon Number 

ARC-EX-858-004~P-I. 14 pages. 

Company Official: 

Company Name: 

Company Contact: 

Catherine M. Byrd 

Name 

Wagner Regulatory Associates, Inc, 

Agent for WiUowood, LLC 

Catherine M. Byrd 

Name 

Signature 

(302) 234",,2780 

Phone 

58
":orm approved. OMS No. 2070-0060, 2070-0057, 2070-u I 07, 2070-0122. 2070-0164. 

,s,EPA United States 

Environmental Protection Agency 

Washington, DC 20460 

Formulator's Exemption Statement 

(40 CFR 152.85) 

Applicant's Name and Address EPA File Symbol/Registration Number 

87290- D 

Willowood LLC Product Name 

c/o Wagner Regulatory Associates, Inc. Willowood Propanil 80DF 

P.O. Box 640 

Date of Confidential Statement of Formula (EPA Form 8570-4) 

Hockessin, DE 19707 12/17/2010 

As an authorized representative of the applicant for registration of the product identified above, I certify that 

(1) This product contains the following actlve ingredient(s): 

Propanil 

(2) Of these, each active ingredient listed in paragraph (4) is present solely as the result of the use of that active Jrwedient in·~~.e mrnufacturing. 

formulation or repackaging another product which contains that active ingredient which is registered under F'FRA Section 3,'1<' purchased by 

us from another person and meets the requirements of 40 CFR section 158.50{e)(2) or (3). 

(3) Indicate by checking (A) or (8) betow which paragraph applies: 

01 (A) An accurate Confidential Statement of Formula (EPA FORM 8570-4) for the above 'Identified product is attached to thh btdt..l).lent 

That formula statement indicates, by company name, registration number, and product name, the source of the active ingre<:tie.'1t(s} listed in 

paragraph (1). 

OR 

-, (8) The Confidential Statement of Formuta (CSF)(EPA Form 8570-4) referenced above and on file with the EPA is complete, current, an 

accurate and contains the information required on the current CSF. 

(4) The following active ingredients in this product qualify for the formulator's exemption. 

Source 

Active Ingredient Product Name Registration Number 

Propanil 

Si9~'~atV Name and Title Date 

Catherine Byrd, Agent 1211712010 

EPA Form 8570 . 27 (Rev. 06_2004) Copy 1 EPA 

Copy 2 ~ Applicant copy 

59 *Product ingredient source information may be entitled to confidential treatment*
Form Aooroved OMB NOS, 2070-0060; 2070-0057; 2070-0t07; 2070-0122; 2070-0164 

~~ 

... '~"'" UNITED STATES ENVIRONMENTAL PROTECTION AGENCY , ~J 1200 Pennsylvania Avenue, N.W. 

WASHINGTON, D,C. 20460 

Paperwork Reduction Act Noticc: The pubtic reporting burden for this collection ofinfonnation is estimated to average t.25 hours per response for registration 

and 0.25 hours per response for reregistration and speciat review activities, including time for reading the inslruCiions and completing the necessary fonns. Send 

comments regarding burden estimate or any other aspect of III is wttection of information, including suggestions for reducing the burden to: Director, Collection 

Strategies Division (2822T), U.S. Environmental Protection Agency, t200 Pennsytvania Avenue, N.W., Washington, DC 20460, Do not send the completed fonn 

10 this address, 

Certification with Respect to Citation of Data 

Applicanl's/Registrant's Name, Address, and Telephone Number EPA Registration NumberlFile Symbot 

Willowood, LLC c/o Wagner Regulatory Associates, P,O. Box 640, Hockessin, DE t9707 87290 

Active InaredienUs) and/or representative test comoound(s) Date 

Propanil t2/t7/2010 

General Use Pattem(s) 01st all those claimed forthis product using 40 CFR Part 158) Product Name 

Terrestrial Food Willowood Propanil 80 DF 

NOTE: If your product is a 100% repackaging ot another purchased EPA-registered product labeled tor all the same uses on your label, you do not need to 

submit this torm. You must submit the Formulator's Exemplion Statement (EPA Form 8570-27). 

0 I am responding to a Data-Call-In Notice, and have included with this torm a list ot companies sent offers ot compensation (lhe Data Matrix torm should 

be used tor this purpose). 

SECTION I: METHOD OF DATA SUPPORT (Check one method only) 

0 I am uSing the cile-all method ot support, and have included with this form IZI I am using the selective method ot support (6r: c;If'-1I' oplion 

a list of companies sent offers ot compensalion (the Data Matrix torm under the selective method), and have inclut.ed with this form a 

should be used fbr this purpose). compleled list ot data requirements (the Datt ~.~atrix torm must be 

used). . . 

SECTION II: GENERAL OFFER TO PAY . 

IRequired it using the cite-all method or when using the c~e-all oplion under the selective methOd to salisfy one or more data r€<":ulI'emenlsl 

IZI I hereby offer and agree to pay compensation, 10 other persons, wilh regard to the approval Of this application, to the exlent required Iff ,F!FPA: 

SECTION III: CERTIFICATION 

I certify that this application for regislration, this form tor reregistration, or this Data-Call-In response is supported by aU data submitleu 'ut CIted in the 

ap~ication tor reg'lstralion, the torm tor reregislralion, or the Data-Call-In response. In addition, 'it the cite-all option or cite-all option under the sel~~;ve method is 

indicated in Section I, this application is supported by all data in the Agency's flies that {t} concern the properties or effects ot this product or an identical or 

substantially similar product, or one or more ot the ingredients in this product; and {2} is a type ot data that would be required to be submitted under the data 

requirements in effect on the date ot approval ot this application it Ihe application sought the Initial registration ot a product ot identical or similar composition and 

uses. 

I certrry that tor each exclusive use study dted in support ot this registration or reregistration, that I am the original data submitter or that I have oblained 

the written permission of the original data submitter to cite that study, 

I certify that tor each study cited in support ot this registration or reregistration that is not an exclusive use study, either: (a) I am the original dala 

submitter; (b) I have obtained the permission ot the original data submitter to use the study in support ot this appliC<llion; {c} all periods of eligibility for 

compensation have expired tor the study; {d} the stUdy Is In the public literature; or {e} I have notified in wriling the company that submitted the study and have 

offered {I} to pay compensafion to the extent required by sections 3{c}{t}fF} and/or 3{c){2)(B) ot FIFRA; and {ii} to commence negotiations to determine the 

amount and terms ot compensation, it any, to be paid tor the use ot the study. 

I certify that in all instances where an offer of compensation is required, copies of all offers to pay compensation and evidence ot their delivery in 

accordance with sections 3{c}(t)(F} and/or 3{c}{2}{B} ot FIFRA are available and will be submitted to the Agency upon request. Should I fail to produce such 

evidence to the Agency upon request, I undersland that the Agency may initiate action to deny, cancel or suspend the registration ot my producl in contormity with 

FIFRA. 

I certify that the statements I havo made on this fonn and all attachments to It are true, accurate, and complete. I acknowlodgo that any 

knowingly f<ltso or misleading statement may bo punishable by fine or Imprisonment or both under applieabto law. 

Signa lure (}ffjjwv;w Ii4 ~ Date Typed or Printed Name and Title 

121t7/20tO Catherine M. Byrd, Agent 

EPA Form 8570-34 {t2 -2003} ElectroniC and Paper versions available. Submit only Paper version. 

60
R~nd301 

" 100% identical (repack): _YJJE~S,-"oLr -1""z:;J-) ---Llc",k"c",le,-"ounSje 

{If yes, it's a I 00% repack - then pr ct chemistry, acute toxicity and efficacy data 

are not required} 

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

Data 

Guideline Group A: Product Chemistry Data sUbmitted 

No. Study Title Yes No 

830.1550 Product Identitv & Composition v' 

Description of materials used to produce the 

830.1600 I product V 

830.1650 Description of formulation process ./ 

830.1670 Discussion on the formation of impurities V 

830.1700 Preliminary analvsis X 

830.1750 Certified limits (158.3451 , v' 

830.1800 Enforcement analvtical method V 

Data 

Guideline Group B: Product Chemistry Data sUbmitted 

No, Study Title Yes No 

830.6302 Color ~ 

830.6303 Physical State V 

830.6304 Odor 'V 

Oxidation/Reduction (Chemical 

830.6314 incompatibility) c/ 

830.6315 Flammability X 

830.6316 Explodability K 

830.6317 Storaqe stabilitv )( 

830.6319 Miscibility K. 

830.6320 Corrosion Characteristics .K 

830.6321 Dielectric Breakdown YoltaQe .K 

830.7000 IpH lwi 

830.7100 Viscosity x.. 

830.7300 Density \/ 

1 

k' 1, +" I~ '" ,-"/ 

!' ( 

61
/' "'", f ft T' Fonn Approved OMB No. 2070-0060 ~~~ UNITED STATES ENVIRONMENTAL PROTECTION AGENCY \" ,""".,.. 401 M Street, S.W. 

WASHINGTON, D_C. 20460 

Paperwork Reduction Ad Notic-e: The puhlic repOIting bllrden for this collection of information is estimated to average 0.25 hours per respouse for registration activities and 0.25 

hours per respouse tor reregistration aud special review activities, including time for reading the instruction aud completing tlie necessary fonns. Send comments rt:.sa~dhg tlie 

bW'den estimate or any other aspect of this collection of infomlation, including suggestions for reducing the burden to: Director, OPPE Inlonnation Management 01"1ision (2137), 

U.S. Environmental Protectiou A<Jency, 401 M Street. S.W., Washington DC 20460. 1)0 not send the form to this address. _ 

DATA MATRIX 

Date: 12/17(2010 EPA Rcg No.! Filc Symbol: 82790- i Pag:::, lof3 

Applicant'siRcgistrant's Name and Address: Wil1owood LLC Product: 

c/o Wagner Regulatory Associates Inc, 

P.O. Box 640 Willowood Propallil80 OF 

Hockessin, DE 19707 

Ingrediem: Propanil 

Guideline Refereuce Number I Guideline Study Name MRID Number Submitter Status Note 

PRODUCT SPECiFIC 

830.1550, 830.1600, 8}0.1650, Product identity, compositionlDescription of Wi lIowood LLC Own 

830.1670. materials Used to Produce the 

Product/Description of FOlillulatiol1 

ProcessfOiscussion of Formation oflmpurities 

830.1700 Preliminarv Analvsis Willowood LLC Owu 

830.1750 Celtification of Limits Willowood LLC Own 1 

830.1800 Enforcement Analytical Method Willowood LLC OW" 

830.6302 Color Willowood LLC Own 

830.6303 Odor Willowood LLC Own 

830.6304 Physical State Willowood LLC Own 

830,6313 Stabilitv to Norma I & Elevated Temperatures Willowood LLC Own 

830.6314 Oxidation/Reduction Willowood LLC Own 

830.6315 Flanunability Wi11owood LLC Own 

830.6316 Exolodabilitv Willowood LLC Own 

830.6317 Accelerated Storage Stabilirv Willowood LLC Own 

830.6319 Miscihility Willowood LLC Own 

830.6320 Corrosion C1mracteristics Willowood LLC Own 

830.6321 Dielectric Breakdown Voltaoe Willowood LLC Own 

830.7000 IpH Willowood LLC Own 

830.7050 UVNisible Lioht Absorption Willol'lood LLC Own 

830.7100 Viscosit' Willowood LLC Own 

830.7"")00 Meltin!!, Point Willowood LLC OIVU 

Si""",",e ~ f'x- &jdName and Title Date 

Catheriue M. Byrd. 12/17/2010 

Agent for Willowood LLC 

EPA Form 8570-35 (9-97) Electronic and Paper versions available. Submit ouly Paper verSiOl1. Agenc}' lutcrnal Usc Cop}' 

62
,'A .,." '''-. '; Form Approved OMB No. 2070-0060 ,~, UNITED STATES ENV[RONMENT AL PROTECTION AGENCY '>".,,,,,,#' 

401 M Street, S.W. 

WASHINGTON D.C. 20460 

Paperworl, Reduction Aet Notice: The public repOiting burden forthis collection of information is estimated to average 0.25 hours per response for registration activities find 0.25 

hours per response for reregistration and special review activities, including time for reading the instnlction and completing the necessary fonns. Send conuuents regarding the 

bmden estimate or any other aspect of this collection of infornlation, including suggestions foJ' reducing lhc burden to: Director, OPPE Information l\-lanagement Division (2 I3 7), 

US. Environmental Protection A"encv, 40 I M Sn'eet, S,W., \Vashington DC 20460. Do not send the fonn to this address. 

DATA MATRIX 

Date: [2/17/2010 EPA Reg No.1 Fi[e Symbol: 82790- I Page 2 oD 

Appjicant's/Registrant's Namc and Address: Willowood LLC Product: 

clo Wagner Regulatory Associates Inc. 

P.O. Box 640 \Vi1l0\1'00d Propanil 80 OF 

Hockessin, DE 19707 

Ingredient Propanil 

Guideline RcfeJ'ence Number Guideline Study Name MRlD Number Sulimitter Status Note 

830.72?0 Boiling Point Willowood LLC Own 

830.7300 Relative Density willowood LLC Own 

830.7370 Dissocation Constants in Water Willowood LLC Own 

830.7520 Pmticie Size, Fiher LengJh, and Diameter Wi[lowood LLC Own 

Distribution 

830.7550 Octanol/Water Partition Coefficient Willowood LLC Own 

830.7840 Su[ubi[itv in Organic Solvents willowood LLC Own 

830.7840 Water So[ubility Willowood LLC Own 

830.7950 Vapor Pressure Willowood LLC Own 

870.1100,870. [200, 870.1300, Acute Oral Toxicity, Acllte Dermal Toxicity, Cite All Agricultural Handlers Exposure Pay 

870.2400, 870.2500, 870.2600 Acnte rnhalation Toxicity, Primary Eye Task Force 

fJTitation, Primary Skin hTitation, SUn Macon, MO 

Sensitization 

Agricultural Reentry Task Force 

Washington, DC 

Drexe[ Chemical Co. 

l\.femphis, TN 

EJ. DuPont De Nemours and Co, illc. 

Wilmington, DE 

FIFRA Endangered Species Task 

Force, LLC 

_Washington, QC --------- --------

~fl-&jrzi- Name and Title Date 

Catherine M. Byrd. 1'2117/2010 

Agent for Wi![owood LLC 

Si"nature 

EPA Form 8570~35 (9-97) [Ieclronic and Paper V('rsions available. Submit OJ] Iy Paper versIOn. Agency Intcrna[ lIsc Coov 

63
,f"" '" __ 

Form Approved OMB No. 2070-0060 f ft iI 

\~) UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 

401 M Street, S.W. 

WASHiNGTON, D.C 20460 

Paperwol'k Reduction Act Notice: The puhlic repOlting bmden forthis collection of in for milt ion is estimatC(1 to average 0.25 hours per response for regislration activities alld 0.25 

hours per response for reregistration and special review activities, iJ)cluding time for reading lhe instrllction and completing lhe necessary fonns. Send comments regarding lhe 

bLD'den estimate or any other aspect of this collection of infomlation, including suggestions for reducing the burden to: Director, OPPE Infonnation Management Division (2137), 

U.S. Environmental Protectioll A"enc\!, 401 M Street, S. W., Washi~(!:toll DC 20460. Do not send the fon11 to this address. 

DATA MATRIX 

Dale: 12/17/2010 EPA Reg No.1 File Symbol: 82790- J Page 3 of3 

Applicant's/Registrant's Name and Address: WilJowood LLC Product: 

clo Wagner Regulatory Associates Inc. 

P.O. Box 640 WilJowood Propanil 80 OF 

Hockessill, DE 19707 

Ingredient: Propanil 

GllideJine Rcference Number Guideline Shldy Name MRID Number Submitter Status Notc 

Generic Endangered Species Task Force 

Gig Hflrbor, WA 

Monsanto Company 

Washington, D.C. 

Outdoor Residential Exposnre Task 

Force, LLC 

Washingtoll, DC 

Propanil Task Force 

Washin ~ton, D.C. 

ruceeo LLC 

Memphis, TN 

Spray Drift Task Force 

Washingtoll, DC 

United Phosphorlls, inc. 

King ofPmssia, PA 

Footnotes: I) Celtiticalion ofUmils is provided ill the Contidential Slalemenl ofFonnula EPA lonn 8574-4 

S'IgmrUf'--_&JJwr;;;w 'Yx-&jrf..-

Name and Title Date 

Catherine M. Byrd, 12117/2010 

Agent for Willowo(ld LLC .. --.. --_ .. 

EPA Form 8570-35 (9~97) E!t~clroJlic and Paper versions avnilable, SUhlllil oilly Paper verSIOIl. Agencv Intcl'n::l11 l~{> ('nrw 

64
/<~~'; FOl1ll Approved Ol\.fB No. 2070-0060 '~" UNITED STATES ENVIRONMENTAL PROTECTION AGENCY \. i " .... ,<. 40 I M Street, S. W. 

WASHINGTON, D.C. 20460 

Pa pc rwork Reductioll Act Notice: The public repolting burdell for this collection of infonnatiou is estimated to average 0.25 hours per response for ~~g;';t~·atioll activities and 0.25 

hOllrs per response for rcrcgistration and special review activities, illcilldillg time for reading the instwction and completing tlte necessmy forms. Seud COlTIlhellts regardillg the 

burdell estimate or allY other aspccl of this collection of infonnation, inc\udillg suggestions for rcducing the burden to: Dircctor, OPPE intornmtion l\-hungt:l1lellt Division (2137), 

U.S. ElIviwllmelltal Protection Agencv, 40 I M Street S. W., Washiugtoll DC 20460. Do 1I0t scud the form to this address. 

DATA MATRIX 

Date: 12!l7!2010 

Applicant's!Registraut's Nmne mid Address: Willowood LLC 

c/o Wagller Regulatory Associates Inc. 

P.O. Box 640 

Huckessin. DE 19707 

Ingredient: Propauil 

Refcrcucc N umbcr \ Guidcliuc Study Name MRID Numbcr 

Si12l1atlJre 

WJwwiwYx.&fdEPA Form 8570-35 (9·97) Electronic and Paper versions available. SlIblllit ouly Paper version. 

EPA Rcg No.1 File Symbol: 87290 

Product: 

Willolvood Propanil 80 OF 

Name alld Title 

Catherine M. Byrd, 

AgCllt for Willowood LLC 

I Page I of3 

Date 

12/17/2010 

Agency Intcrllal Usc COllY 

65
l-~<i';:" ; Foml Approved OMB No. ~O70-0060 

\~; UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 

<".,.." 401 M Street, S.W. 

WASHINGTON, D.C. 20460 

Paperwork Reduction Act Notice: The public repOiting burdell tor this collection of in fOTlllati 011 is estimated to average 0.25 homs per response for registratioll activities and 0.25 

hours per respollse for reregistration and special review activities, illcilldillg time for reading the instrllction and completillg tile necessalY tbrms. Send comments regarding tile 

burdeu estim<Jte or any other aspect of this collection of infonnation. illChldillg suggestions for reducing tile bllrden to: Director, OPPE Information Management Division (2 t37), 

U.S. Euvirolll1lental Protection A"ency, 401 M Street, S.W., Washillgton DC 20460. Do 1I0t send the form to tliis address. 

DATA MATRIX 

Date: 12/]7i2010 

ApplicantslRegistrant's Name alld Address: Willowood LLC 

c/o \Vaguer Regillatory Associates Inc. 

P.O. Box 640 

Hockessin. DE 19707 

lngredieut Propanil 

~-.... 

Guidcline Refercuce Number Study Name 

Si"nature ~fl-&frf--

EPA Form 8570-35 (9~97) Electronic alld Pnper versions ilvaiJnble. SJlbiliit oilly Paper Version. 

EPA Reg No.! File Symbol: 87290 

Prodllct 

Willowood Propanil 80 OF 

-_ ... 

Task Force 

MO 

Naille and Title 

Catherine M. ByTd, 

-_ ... 

Agellt for Willowood LLC 

Exposure 

Co, Inc. 

Task Force 

I Page 2 of3 

Status Note 

Pay 

Date 

J2117i2{lJO 

Agency Intel"llal Use Copy 

66
/'"A"\, Form Approved OMB No. 2070·0060 

, ~; ; UNITEO STATES ENVIRONMENTAL PROTECTION AGENCY "''''''''~ 401 M Street, S.W. 

WASHINGTON, D.C. 20460 

Paperwork Reduction Act Notice: The public reporting bW'den for this collection ofinformation is estimated to average 0.25 hours per response for registration activities and 0.25 

hours per response tor reregistration and special review activities, including time for reading the instruction and completing the necessllry fonns. Send comments regarding the 

burden estimate or any other aspect of this collection ofintonmtion, including sllggestions for red\ICing the burden to: Director, OPPE Intormation Management Division (2137). 

U.S. Environmental Protection Agencv, 401 M Street, S.W., Washin>...>1:on DC 20460. Do not send the l'onn to this address. 

DATA MATRIX 

Date: 12/17/2010 EPA Reg No.1 File Symbol: 87290 I Page 3 of3 

Applicant'siRegistrant's Name and Address: Willowood LLC Product: 

clo Wagner Regulatory Associates Inc. 

P.O. Box 640 Wi1\owood Propanil 80 DF 

Hockessin, DE 19707 

Ingredient: Propanil 

Propanil Task Force 

Name and Title Date 

Signature ~ Ix. &frtl--- Catherine Ivt Byrd, 12/17/2010 

Age11t for Wi1lowood LLC 

EPA Form 8570-35 (9-97) Electronic and Paper versions available. Submit only Pflper version. Agency Internal Use Copy 

67
December 17, 20 I 0 

Document Processing Desk (REGFEE) 

ATTN: Kathryn Montaglle, PM Team 23 

Registration Division 

U.S. Environmental Protectioll Agency 

Office of Pesticide Programs (7504P) 

Roolll S-4900, One Potomac Yard 

1777 S011th Crystal Drive 

Arlington, Virginia 22202-4501 

Dear Ms. Montaglle, 

Wagner Regulatory Associates, Inc. 

P.O. Box 640 

7460 Lancaster Pike, Suite 9 

Hockessin, Delaware 19707 

S11bject: Application to register a new end-use product containing a currelltly registered active ingredient-

"Willowood Propanil SO DF" 

Wagner Regulatory Associates, Inc., as agent tor WilJow{]od, LLC (87290), is reqllesting registmtion of the above 

referenced Ilfoduet. This product is substantially similar to the propanil product (Stam 80 EDF) registered by United 

Phosphorus, Inc. under EPA Registration Nlimber 70506-166. 

In snpport of this request. the tollowing documents and stlldies are attached: 

• Letter from WiJlowood LLC appointing Wagner Regulatory Associates, Inc. as its agent 

• Application for Pesticide Registration (8570-1) 

• Confidential Statement ofFormllla (8570-4), 2 copies 

• Certification with Respect to Citatioll of Data (8570-34)' 

• Formulators Exemption (8570-27) 

• Data Matrix (8570-35) 

• Dala Transmittal Document 

• Product Identity and Composition data (3 copies) as olltlined in the transmittal document 

• PrelimimHY Analysis data (3 copies) as outlined in the lJ"ansmit!<ll dOCJlmtlnt 

• Physical and Chemical Properties data (3 copies) as Olltlined in the transmittal docllmellt 

• DraH labeling, 3 copies alld CD 

• Cel1ification with Respect to Label IlltegJity 

• A copy of the EPA approved label for EPA Reg. No, 70506-166 and 

• A copy (lfthe receipt confirming payment of the reqnired registration fees. 

WiJ\{]wood, LLC has submitted paymellt to U.S,EPA in accordance with PRIA II Fee Table - FYII!FYI2, for 

action cHtegory R300 - $1,434. 

If y011 have any quest ions about this SlIbm ission please contact the 1 mdersigned at CatheIillerqJ\:iJ,!gnem:.~g.com or 

(302) 234-2780. 

Respectfully s1Ibmitte(], 

Catherine M, Byrd 

Agt..'llt for WiI\owood, LLC 

Enclosures 

68
Please read iflstructions on reverse before completino . "'n. Form Approved, ('. No, 2070·0060. ADoroval eXDires 05·31·98 

~ Re~ . ..ltration OPP Identifier Number 

United States .oEM Environmental Protection Agency Amendment 

Washington, DC 20460 e-- Other 

Application for Pesticide - Section I 

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

87290 -)!--r- James Tompkins 

4. CompanylProduct (Name) PM" llil None Restricted 

Willowood, LLCJWi!lowood Propanil 80 OF 25 

5. Name and Address of Applicant (Include Zip Code) 6. Expedited Review. In accordance with FIFRA Section 3(c)(3) 

Willowood, LLC 

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

to: 

clo Wagner Regulatory Associates, Inc. 

P.O. Box 640 

EPA Reg. No. 70506-166 

Hockessin, DE 19707 Product Name: Stam 80 EDF Herbicide 

D Check if fhis is a new address 

Section - II 

0 Amendment - Explain below. 0 Final printed labels in response to 

Agency lettel dated 

0 Resubmission in response to Agency letter dated Iill "Me Too" Application. 

0 Notification - Explain below. 0 Other - Explain below. 

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

Section - III 

1. Material This Product Will Be Packaged In: 

Child-Resistant Packaging U~ckaging W~ Soluble Packaging 2. T e of Container Ii3 Yes' Yes Yes Metal 

X No X No X No Plastic 

If "Yes" No. per It "Yes' No. per Glass 

" Cerliflcailon must Unit Packaging wgt. container Package wgt container Paper 

be submitted I X Other (Specify) HDPE lined bags 

3. Localion of Net Contents Information 4. Size(s) Retail Container 5. Location of Label Directions 

m Label D Container 50lb ~ On Label 

X On Labeling accompanying product 

6. Manner in Which Label is Affixed to Product § Ulhogcaph CJ Other - X Paper glued 

Stenciled 

Section - IV 

1. Contact Point Com lete items direct! below for identification of individual to be contacted, if necessa , to recess this a Hcafion.) 

Name I Title I ~el~~~one No. (Incllode f...I.:;a Code) 

Catherine M. Byrd Agent for Willowood, LLC 302 2342780 

Certification !, 6., Date APi ,Iication 

I certify that the statements I have made on this form and all attachments thereto are liue, accUiate and complete. I Received 

I acknowledge that any knowingly false 01 misleading statement may be punishable by fine or imprisonment or • 

both tinder applicable law. (Stwmpd) 

2. Signature 3. Title 

~fx.&fd- Agent for Willowood, LLC I 

4. Typed Name 5. Date 

Catherine M. Byrd 12/17/2010 

Tills IS a reproductIon of EPA Form 8570-1 (Rev. 8-94) PrevIOus edilions are obsolete. 

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Pages 70-74 - *Confidential Statements of Formula may be entitled to confidential treatment*