Docket Number EPA -HQ -OPP

- 2007

- 1089 www.regulations.gov



## Quizalofop-ethyl Quizalofop-p-ethyl
Interim Registration Review Decision Case Number 7215

December 2014

Approved by:



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**~'"1.AA,.:p** Richard P. Keigwin, Jr. Director Pesticide Re-evaluation Division

Date:



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**o! L-/-**  ,Table of Contents Contents I. INTRODUC ' fiON . ........ . .. .. .. .. . ... . ... ............................ .. .. .. .. .. .. . ....................... . ..... .. ... .. ... . ....... . 3 II. USE AND USAGE . . ............ . .. .. ..................................... . ... . ......... .. ...... ....... .......... . ................. 6 III. SCIENTIF I C ASSESSMENTS ............................................................................................... 6 A. Human Health Assessment .. . ......... ............ ........................... .. ...... ... ..................... . ...... .......... 6 1. Risk Est imate s ........ . .. .. .. .. .. . ...................... . ... . .. .. .. ... .. .. .. . ..... ... ................. . .. ... .. ... ........... 6 2. Human I ncidents . . ...... . .. . ...................... .. ... . ................................................... . ............... 7 3. Food To l erances ........................................................................................... . ..... . ......... 8 4. Data Needs ........................................................................................ 7 B. Environmental Assess ment. ..... ............................ .................... .......... ............. 7 1. Environm en tal Fate and Expo s ur e ............................................................. 7 2. Ecological Risk Estimates ......... .. .. .................. .... .. .. . ................................. .. .. .. ... . ......... 9 3. Ecological I nciden t s ............................................. . ........................................ . ... .. ... .. .. 13 4 . Ecological R i sk Charac t erization for Non-Lis t ed Species ........................ . . . .. . ... 1 1 Endangered Species Assessment .......................................................................................... 15

Endocrine Disruptor Screening Program .............................................................................. 1 5 IV. INTERIM REGISTRATION REVIEW DE C ISIO N ............................................................ 17

V. NEXT STEPS AND TlMELINE ......................................................................... . ... .. ........... 19 References ................................ . . . ................. . . . .. .. . . .. .. . . .............. .. .. .. . .. .. . ........ 18

Appendix A: Summary of Actions T aken for Qui z a l ofo p ... .. .. .. .. .. .. .. ......... . ..... . ... .. ... .. .. ... ........... 21 Appendix B: Qui za lofop Label Table ..... . ....... . ................ . ... . ... . ... . ............. .. ............. . ... .. ............. 20 2

### I. INTRODUCTION
This document is the Environmental Protection Agency 's (EPA o r the Agency) Interim Regis tration Revie w Decision for quizalofop , which appears as two diff erent isomer mixtures: qu iza lofop -ethy l (PC co de 128711) and qui zalofop-p-ethyl (PC code 128709) and is being issued pursuant to 40 CFR sect ions 15 5 .56 and 1 55.58 (case 7215). A re gi stration review decision i s the Agency's determination whet her a pesticide meets , or does not meet , the standard fo r regis tration in the Federal Insecticide , Fungicide, and Rodenticide Act (FIFRA). The Agency may i ssue , whe n it determines it to be appropriate , an Interim Registration Review Decision before completing a registration review. Among o ther things , the Interim Regi stration Review Decision may: 1) require new ri s k mitigation measures; 2) imp ose interim ri sk mi tigation measures; 3) identify data or informatio n re quired to complete the revi ew; and 4) include schedul es for s ubmi tting the required d ata, conducting the new ri s k assessment and comp leting the registrati on review. For further info rmation on qui zalofop , additional document s can be found in EPA 's public docket (EPA-HQ-OPP-2007-1089) at www. regulation s.gov. FIFRA , as amended by the Food Qua lity Pro tection Act (FQPA) of 1996 , mandated the continuous re view of existing pesticides. All pe sticides dist ributed or sold in the United State s genera ll y must be registered by the EPA based on scientific data s ho wing that they will not cause unreaso nabl e risks to human health or to the environment when used as directed on product labeling

. The re g i str ati on review program is intended to make sure that , as the ab ili ty to assess and reduce risk evo l ves and as policies and practic es change, all regi stered p es ticides continue to meet the stat utory standard o f no unreas onable adverse effects. Changes in sc ienc e, public po li cy, and pe sticide u se practices will occur over time. Through the registratio n review program , the Agency periodically re-evalu ates pesticides to make sure that as these changes occur , product s in the marketpl ace can continue to be used s af ely. I nformation o n this program is provided as www.epa.gov/oppsrrd 1/regi stration review/

. In 2006 , the Agency implement ed the registration review pro gram pursuant to FIFRA section 3(g) and wi ll review each regi stered p estic ide every 15 years t o determine whethe r it co ntinues to meet the FIFRA standard for registrati on. The first pes ti c ide product containing quizalofop-ethyl was regi s tered in 1 988 and the first pesticide product containing quizalofop-p-ethyl was registered in 1990

. Quizalofop was not s ubject to reregistration because products containi ng it were first regi stered after November 1984.
Pursuant to 4 0 CFR section 155.50 , EPA formally initiated regis tratio n review for quizalofop (case 7215). The following highli ght s are signific ant events that have occurred during the registration revi ew of qui zalofop and can b e found in the public docket (EPA-HQ -OPP-2007- 1 089, accessed at www.regulations.gov):

• Dec ember 19 , 2007

- Publication of the quiza lofop Summary Document for a 60-day public comment period. The Summary Do cument included the Pr eliminary Work Plan (PWP) and was accompanied by the scoping document and problem formulation

. Four public com ments were received during the 60 -day comment period fo r the quizalofop PWP.

3• June 12 , 2008- F inal Work Plan (FWP) for quizalofop was issued. During the comment period, the Agency re-evaluated certain ecological effects data and made changes to the quizalofop work plan. The FWP modified the PWP to include additional anticipated aquatic plant toxicity testing (GLN 850.4400) and aquatic emergent testing on rice (Special Protocol). The FWP also removed the anticipated data requireme nt for chronic early lif e-cycle toxicity testing on estuarine marine invertebrates (GLN 850.1350). • December 16 , 2009- Generic Data Call-In Notice (G D C I ) for quizalofop was issued. • March 20, 2013 - The Agency placed in the docket the Registration R e view-Ecological Risk Assessm e nt and Effects Determination of Quizalofop-p-ethyl and the Quizalofop Ethyl and Qui z aiofop-p-ethyl , Summary of Human Health Risk Assessment for

Regi stration Review for a 60-day public com ment period. During that t ime , one submission was received from DuPont De Nemours and Company , but the comments did not result in revi s ions to the risk asse s sments. • March 14 , 2014 - T he Agenc y publi s hed the Response to Publi c Co mments on the Quizalofop ( P C: 12 871 1 ) and Qui z alofop-p- e th y l ( PC: 128 7 09 ) R e gi s tration Review Preliminar y Ri s k Assessment and Qui z alofop Ethyl and Qui z alofop-p-ethyl , Response to Comments on the Human Health Risk A sse ssment for Registration R e view. • Jul y 18 , 2014 - The Agency published the Quizalofo p Proposed Interim R egistration Review Deci s ion in docket numb er EPA-HQ-OPP-2007-1 089 for a 60-day public comment period. The Agency also publi s hed an addendum to the environmental fate and ecological ri s k assessment for quizalofop , titled " Refinement s to th e Qui z alofop Preliminar y Ri s k Asse ssment in Support of R e gistration Review " . The addendum refme s the original ri s k a s sessment and adds further risk characterization. The Agency received comments from the Center for Biological Diversity. The comments add r essed the Agency ' s duty under the Endangered Species Act (ESA) to consult wit h the US Fish and Wildlife Service and the National Marine Fisheries Service (the Services) on the registration rev i ew of quizalofop. Public Comments One public c o mm e nt from the Center for Bio l ogica l Diversity wa s s ubmitted to the Agency during the 60 day public comment period for the Quizalofop Proposed Interim Decision. The comment addressed the Agency ' s responsibilities under the Endang e red Species Act (ESA). The comment is summar iz ed herein along with the Agency's respon se. The Cente r for Biological Diver sity ' s comme nt i n its e n t ir ety i s located in the quizalofop regis tration review docket (EPA-HQ-OPP-2007

- 1 089) at www.regulations.gov. Comments submitted by the Center for Biological Diversity in EPA-HQ-OPP-2007-1089- 0041. Comment: The Ce nt e r for Biological Diver s ity ' s (CBD) comments fo c u s on the EPA ' s independent duty und e r the Endangered Sp ec i e s Act (ESA) to consult with the U.S. Fish and 4Wildlife Service and the National Marine Fisheries Service (the Services) on the registration review ofquizalofop. Agency Response: E PA has re viewed the comments from CBD on the Quiza lofop Proposed Interim Deci sio n and plans to address many of the concerns raised by CBD as part of the implementation plan for assessing the risks of pesticides to li sted species bas ed on the recommendations ofthe April2013 National Academy of Sciences (NAS) report. EPA will address concerns specific to quizalofop in connection with the development of its final registration review decision for quizalofop.
In November 2013, the E PA, along with the U.S. Fish & Wildlife Service (US FWS) , the National Marine Fisheries Service (NMFS) (collectively, the Services), and the U.S. Department of Agriculture (USDA) released a summary of their joint Interim Approaches for assessing risks to li sted species from pesticides. The Interim Approaches were developed jointly by the agencies in response to the National Academy of Sciences' (NAS) recommendations and reflect a common approach to risk assessment shared by the agencie s as a way of addressing scientific differences between the EPA and the Services. The NAS report outlines recommendations on specific scientific and technical issues related to the development ofpesticide ri s k assessments that EPA and the Services must conduct in connection with their obligations under the Endangered Species Act (ESA) and FIFRA.
The joint Interim Approaches were released prior to a st akeholder workshop held on November 1 5, 2013. In addition, the EPA presented the joint Interim Approaches at the December 2013 Pesticide Program Dialogue Committee (PPDC) and State-FIFRA Issues Research and Evaluation Group (SFIREG) meetings, and held a stakeholder workshop in April 20 14, allowing additional opportunitie s for stakeholders to comment on the Interim Approaches. As part of a phased, iterative process for developing the Interim Approaches , the agencies will also consider public comments on the Interim Approaches in connection with the development of upcoming Registration Review decisions

. The details of the joint Interim Approaches are contained in the white paper " Interim Approaches for National-Level Pesticide E ndangered Specie s Act Assess ments Based on the Recommendations of the National Academy of Sciences April 2013 Report ," dated November 1 , 2013. Given that the agencie s are continuing to de velop and work toward implementation of the Interim Approaches to assess the potential ri s ks of pesticide s to listed species and their designated critical habitat, the ecological risk assessment supporting this Interim Registration Review Decision for qui zalof op does not conta in a complete ESA analysis that include s effects determinations for specific li sted species or designated critical habitat. Although EPA has not yet comp leted effects determinations for specific species or habitats , for this preliminary assessment EPA conducted a screening-level assessment for a ll taxa of non-target wildlife and plants that assumes for the s ake of the as sessment that listed species and designated crit ical habitats may be present in the vicinity of the application of quizalofop. This screening level assessment will allow EPA to focus its future eva luation s on the types of species where the potential for effects exists once the scientific methods being developed by the agencies have been fully vetted. While the agencies continue to develop a common method for ESA analysis , the regulatory section of the Interim Registration Review Decision document will describe the level of ESA analysis completed for this particular registration review case. Once the agencie s

5have fully developed and implemented the scientific methods necessary to comp lete risk assessments for endangered and threatened (listed) s pecies and their designated critical habitats , these methods will be applied to subsequent analyses for quiza l ofop as part of completing this registration review. II. USE AND USAGE Quizalofop i s a se l ective post-emergence herbicide. Quizalofop appears as two different isomer mixtures: quizalofop-ethyl and quizalofop-p-ethyl. Quizalofop-p-ethyl is composed so l e ly of the pesticidally active isomer, and all quizalofop products currently in the marketplace contain t hi s isomer ; there are no pesticide re g i strat ions for products containing q ui za l ofop-ethyl (a 50/50 racemic mixture of active and inactive i so mers). Both quizalofop -p-et hyl and quizalofop-ethyl are referred to collectively as quizalofop. Quizalofop i s a systemic herbicide registered for use to control annua l and perennial weeds in various food / feed and non - food/non-feed crops. Food and feed uses include grains , legumes , cotton , garlic, mint , soybean , sugar beets , sunflower, pineapple , and Chinese cabbage. Non -food/non- feed uses include cottonwood and poplar plantations and uncultivated areas such as fencerows, roadsides, and paved areas. Th ere are no registered residential uses of quiza l ofop. An estimated average of 53,500 lb s of quiza l ofop (averaged from 2003-201 0) is applied on agricultural crops in the U.S. each year. The majority is applied to dry beans /pe as and soybeans (approximat ely 20,000 lbs each). Other minor usage commodities are sunflowers (a pproximately 4 , 000 lbs) , sugar beets (approximate l y 3,000 lbs), canolalrapeseed (approximately 2,000 lbs) , alfalfa and cotton (approximately 1,000 lb s each), as well as barley , green beans , garlic , onions, and green peas (<500 lb s eac h ). The Age n cy does not ha ve usage estimates for non-agricultural use sites. III. SCIENTIFIC ASSESSMENTS A. Human Health Assessment The HED seeping document , its supporting documents, and the most updated Agency science policies and risk assessment · methodologies were used to prepare a quantitative risk assessment in su pport of the registration re view of quizalofop. T he most recent human health risk assessment was conducted in 2011 to assess new uses on various crops. For a detailed discussion, see the Quizalofop Ethyl and Quizalo.fop-p-ethyl, Summary of Human Health Risk Assessmentfor Registration Review , dated December 1 1 ,2012 in the public doc ket EPA-HQOPP-2007-1 089 , which can be accessed on http://www.regulations.gov/. 1. Risk Conclusions Dietary Exposure Assessment An acute dietary risk assessment was not performed because toxicity was not observed

following a single dose of quizalofop . Similarly a cancer risk assessment was not performed 6because quizalofop is classified as Category D, not class ifiabl e as to human carcinogenicity. A screening-level chronic dietary risk assessment was performed that included both food and drinking water. Children l-2 years old were found to have the highest chronic dietary risk estimate at 29% of the chronic population adjusted dose (cPAD) , which is well below the Agency ' s level of concern of 100% ofthe cPAD. All other population subgroups had chronic dietary risk estimates below that estimated for chi ldren 1-2 years old.
Residential Exposure Assessment Since quizalofop i s not registered for use in residential settings, a residential assessment was not performed for registration review

. Aggregate Exposure Assessment Aggregate risk estimates take into account both dietary (food and drinking water) and residential sources of exposure. Since quizalofop is not registered for residential use , the aggregate assessment for quizalofop included only food plus drinking water exposure estimates and were not different than those described above.
Cu mulative Effects
Section 408(b )(2)(D) (v) ofthe Federal Food, Drug , and Cosmetic Act (FFDCA) requires the Agency to cons ider the cumulative effects of expos ure to quizalofop and other substances that have a common mechanism of toxicity. These considerations include the possible cumulative effects of such residues on infants a nd children.
EPA has not made a common mechanism ofto xicity finding for quizalofop and any other substances , and quizalofop does not appear to produce a toxic metabolite produced by other substances. Therefore, EPA has not assumed that quizalofop has a common mechanism of to xicity with other substances and a cumulative effects assessment was not performed. Occupational Exposure Assessment
The occupational exposure assessment estimates ri sk to workers in an occupational setting via the dermal and inhalation routes ofexposure. Quizalofop is not toxic via the dermal route according to available dermal toxicity data and therefore a dermal endpoint was not selected for risk assessment. Quizalofop h as low toxicity via the inhalation route and it is not volatile , and therefore inhalation exposures of concern are not expected. To support thi s low hazard estimation, the Agency performed a screening -level assessment to est imate inhalation exposure risk for worker s applying and handling quizalofop products for a number of high acreage crops. Risk estimates were not of concern with margins of exposure (MOEs) estimated to range from 2,900 to 211,000 (with MOE of I00 as the level of concern). 

### 2. Human Incidents
For thi s registration review , an initial incident search was conducted in 2007 and an updated search was conducted in 2012. Eight quizalofop incidents were identified in the
7Incident Data System ( IDS) from 1999 to 2012; these incidents were associated with symptoms including rashes, cramping , swelling, diarrhea , nausea, dizziness , lethargy , and hypothermia. Ten incidents were identified from the Poison Contro l Center Data from 1993 to 2005; effects

reporte d were headaches , eye irri t a t ion, and throat i rri tat i on. Three case s assoc i ate d wi t h one dr i ft event in 2005 w e r e ident i fied i n the Nat i ona l Inst i tute of Occupational Safety and Hea l th (N I OSH) Sentinel Event Notification System for Occupational Risk s (SENSOR) from 1 998 to 20 08. T he thre e cases we re classified as low in seve rit y . There is not a concern at this time based on the continued l ow f requenc y and seve rit y of incident cases f or qui za l o fop. For additional d e tail s, please refer to Revi ew ofQuizalofop Incid e nt R eports in docket EPA-HQOPP-2007 - 1089 , wh i ch can be accessed at www.regulations.gov. 3. Food T olerances Toleranc es for r es idues of quizalofop on f oo d are established in 40 CF R § 180.441. Maximum residu e limit s (MRLs) for quizalofop have not been establ i s h e d by Mexico or Codex. The C anadian and U.S. residue definiti ons fo r qui za lofop are similar but not ide ntical. The Agency will pursue harmonizing certain tolerances w ith Canadian MRL s durin g r egistration review; these are s ummari ze d in T able 2 of the Quizalofop Ethyl and Quizalofop-p-ethyl , Sum mar y of Human Health Risk Assessment for R egistra tion R ev i ew. 4. Data Needs The followin g residue chemistry data w e r e identified as data gaps from othe r r eg i s t rationr e lated actions: 1 ) G uid e lin e 860.1360 - Multire s idue methods 2) Guideline 860.1380 - Storage stabi lit y 3) Guideline 860. 1 52 0- P r ocessed food and feed

4 ) G uid e line 860.1650-Analytica l reference standard s S ince t h e p u bl ication of the 2012 h uman health risk assess m en t , the Agency h as received stud i e s t o support guidelines 860. 1 380 and 86 0 . 1 520 . Guidelines 8 60 . 1360 (mu l t i res id ue m e t hods) and 860. 1 650 (ana l ytical reference standards) remain as data gaps for qui za lofop. Since t h ese studies

are meant to s upport a new use registration on su nfl owe r, these data gaps do not impact the regi st ration r ev i ew human health risk assessment for quizalofop. In addition to the li ste d data gap s, the Agency be l ie v e s that the g r azi n g rest r iction on the Assure II label (EPA R eg istration Number 352 -541) is imp r actical for bar l ey and wheat and sho uld be removed t o improve clarity (please see the document titl e d Quizalofop-p

- ethyl. Data

C all - In in Support of th e C ondition of Registration.for Use on Sunflower (P P # OF60 7 6) and Summary of Analyti ca l C hemistry and Re s idu e Data to Support Registration R e view, loca t ed in the quiza l ofop registration review docket EPA-HQ-OPP

- 2007-1 089 , f o r add i t i ona l i nformation).

T he labe l currentl y indicates that grazing of liv es t oc k is prohibited in tr ea t ed areas. 8B. Environmenta l Assessment
Fo r non -li sted species , the Agency identified no risk concerns for bird s, rep tiles , and te rre strial-p hase amphibians , terrestrial invertebrates , terrestria l dico ts, estuarine /marine fish , freshwater invertebrates, estuar ine /marine invertebrates and aquatic plants. H owever , pot e ntial risks were identified for non-li s ted mammal s, terrestrial monocots, and freshw ater fi sh

**~nd** aquatic-phase amphibians

. These risks are summa rized below

. For detailed di scussions of all aspects of the environmental risk assessment , see the Registration Review -Ecologica l Risk Assessment and Effects Determination ofQuizalofop-p

- ethyl, dated February 19 , 2013, and sub sequent Refinements to the Quizalo fop Preliminary Ri skAssessment in Support o f Regi st

ration Review, dated March 20,2014 , in the public docket (EPA-HQ-OPP- 2007 -1089 ) which can be access
. ed on http: //www.regul ation s .gov /.
The Agency al so comp leted a screening-level endangered and threate n ed (listed) species assessment for quizal ofop and identified potentia l risks t o several taxa (mammal s, fr es hwater fish (su rroga te for aquatic-phase amphibians) , f resh w ater invertebrates , estuarine /marine invertebrates, and mono cots). The Agency is currently working w ith its federal counterparts and other stakeholders to implement an interim approach for assessing potential ri s k to listed spec ies and their de s ignated critical habitats. Onc e the scientific methods nece ssary to complete ri s k assessment s for lis ted species and their de s ig nate d critical habitat s are finali zed , the Agency will complete its e ndangered s pec ies assessment fo r quizalofop. As such , only scree ning -level risks to li sted species w ill be e numerated here

. Risks to listed species w ill not be ch a r acterized herein

. 1. E nvironmenta l Fate and Exposure Quizalofop-p -ethyl i s re la tively stable to hydrolysis and stable to photolysis in water and soil. Quizalofop -p-ethyl d egrades to quizal ofop acid, 3-0H-quizalofop acid , and phenolic compounds. Quizalofop ac id and 3 -0H- quizalofop acid are degradates of concern fo r aquatic expo s ure s. Quizalofop ac id appears to be less persistent than the parent, quizalofop-p -ethyl , and 3 -0H-qu iza lofop acid und er aerobic condition s; but both are moderately mobil e
. T he toxicity of quizalofop-p-ethyl, qui zalofop acid, and 3

- 0H-quiza lofop are cons idered rou ghly equivalent for ecolo gica l ri sk assessment , which is a con servative assumption. The fate and effects data are largely available only for the parent chemical , quizalofop-p- ethy l. Therefore a total toxic residues (TIR) approach was u sed to adjust expo sure half-li ves to account for the duration of expo sure to all three chemicals ofconcern. 2. Risk Conclusions
Risk to Terres trial Organisms Direct e ffects to terrestrial organisms are listed below. The Agency identified direct effects to mammals and terrest rial and w etland /riparian plants. The Agency h as not made an effects determination for li sted terre strial bird s, reptiles , terre strial-phase amphibians, mammal s, terrestrial invertebrates , and terrestrial and w etland /riparian plants at this time and will address risks to li sted species at a later stage of regi stration review. The Agenc y is making a "no effect " determinat io n for non- vascular aquatic plants because there are curre ntly no listed non-vascular aquatic p l ant s (please see the document titl ed Registration Review-Ecological Risk Assessment

9and Effects Determination ofQuizalofop-p-ethyl for additiona l information on all risk conclusions). Birds, Reptil es, and Terrestrial-Phase Amphibians . Acute dose-based and dietary-based r i sk quotients ( RQ s) could not be calcu l ated to evaluate risk becau se only non-definitive acute toxicity data were availab l e. To estimate acute risks to birds , reptil es, and terrestrial-phase amphibians, the non-d efini ti ve toxicity values were directly compared to the est imated environmental concentrations (EECs) and found to be not of concern. Therefor e, the potential for risk is considered to be low for acute dose-based and

dietary

- based exposure of birds, reptiles , and terrestrial-phase amphibian s from quizalofop for all registered uses. Chronic dietary-based RQs were ca l culated for the m aximum app li cation rates of quizalofop for all uses. RQs ranged from 0.01 to 0.52, and none of the uses exceeded the

Agency's chronic le ve l of concern (LOC) of 1. Thus, chronic effects to birds , reptiles, and terrestrial -p hase amphibians are considered unlikely. The risk assessment thus did not identi fy direct effects to listed or non-listed terrestrial b i rds, rept il es, and terrestrial-phase amphibian s . Mammal s Acute dose-based RQs were calculated for the maximum application r ates for all quizalofop uses. RQs ranged from <0.01 to 0.05. None of the uses produ ce d RQs above the Age ncy ' s listed spec i es LOC of 0.1. Therefore , acute effects to listed and non-listed mammals

are not expected. RQs were calculated for dietary and dose-based chronic exposures. C hronic d i etarybased RQs ranged from 0.01 to 0.93 a nd none of the uses exceeded th e Agency's chronic LOC of 1. Howev er, chronic dose-based RQs ranged from 0.01 to 8.10 and a ll u ses had multiple scena rios that exceeded the Agency's chronic LOC of I. The highe s t chronic dose-based RQs were for use on pineapple in Puerto Rico and Hawaii , and use on ornamentals and shade trees. T herefore , there i s the potential for chronic risk to both listed and non-listed mammals for all quizalofop uses.

T he risk assessment thus identified only chronic risk to both listed and non -l isted mammals. Terrestrial Inv er t ebra tes Only non-definitive honeybee tox icity data were available. Conseq uently , the highest EEC was compared wit h the acute contact LD so value for the honeyb ee and found to be lower . There fore , based upon qualitative analysis , the potential for acute risk to both listed and nonlisted terrestrial invertebrates is not expected. 10Direct effects to listed and non-listed terrestrial in sec t s are n ot exp ected. 

### Terrestrial and Wetland/Riparian Plant s Dicots did not exceed the Agency 's LOC of 1 for any scenario mod e led. For ground applications, RQs ranged from < 0.01 to 0.18. For aerial app li cations, RQs ranged from 0.01 to 0.25. Therefore, li sted and non-listed dicot s are not expected to be at risk from any of the registered quizalofop uses.
Monocots w er e more sens itive than di cots to quizalofop and there is potential for dire ct effects to listed and non-listed monocots. A ll ground and aerial spray dri ft scenario s exceeded the Agency's LO C of 1. Ground application RQs ranged from <0. 0 1 to 1.42 and aerial application RQs ranged from 0.11 to 13.15. Therefore, there is the potential for direct effects to listed and non-li sted ter res trial monocots for all reg is tered uses of qui zalofop. Direct effects to li sted and non-listed dicots are not expected since R Qs did not exceed the LOC of 1. Direct effec ts to listed and non-listed monocots are expected as RQs exceeded the LOC of 1.
Risk to Aquatic Organisms
Direct effects to aquatic organisms are li sted below. The Agency identified direct effects to freshwater fish and aquatic-phase amphibian s. The Agency has not m ad e an effects determ ination for li s ted freshwater fish , aquatic-phase amphibians, estuarine/marine fish , freshwater invertebrates, estuarine/mari ne invertebrates, and aquatic vascu la r plants at this ti me and will address ri sks to lis ted species at a later stage of re gistrati on review. Freshwater Fish and (Aquatic -Phase) Amphibians
Acute RQs for f res hwa ter fish (surro gate for aquatic-phase amphibi an s) rang e d from 0.001 to 0.028 and did not exceed the Agency's li sted species LO C of0.05 for any ofthe registered qu izalofop uses. Therefore, adverse effects to li sted and non- li sted f res hwater fish on an acute exposure basis are not expected for registered uses of quizalofop.
Chronic RQ s for freshwater fish (surrogate for aquatic -phase amphib ians) ranged from 0.069 to 1.86. Two u ses exceeded the chro ni c LOC of 1 : pineapple (groun d and aerial ) , and paved areas (ground and aerial). The RQ s for all other quizalofop u ses were below the chronic LOC of 1.
Acute effects to li s ted and non-listed fre s hw ater fish and aquatic-phase amphibians are not expected s ince RQs were below the lis ted s pec ies LOC of0 .05. Chronic RQs exceeded the chronic LOC of 1 , therefore, c hronic ri sk to li sted and non-listed freshwater fish and amphibian s is expec te d.

11Estuarine / Marine Fish · Acute data were not available for estuarine/ m ar in e fi s h; however, the f r eshwater fish acu t e data w ere determined to be s uffici ently protect i ve to u se as a su rr ogate. As wi th the freshwater fish, acute RQs for estuari n e/mar i ne fish ranged from 0.001 to 0.028 and did not excee d the listed species LOC of 0.05 for any of the registered quizalofop uses. Th e r efore, adverse effects to listed and non-listed estuarine / marine fish from the reg i stered uses of quizalofop-p

- ethyl are not expected on an acute exposure basis. Chronic RQ s ranged from 0.007 to 0.224 and did not exceed the Agency ' s chronic LOC of 1. Th e r efore, adverse effects to li sted and non-listed estuar in e/marine fish are not expected from the r egistered u ses of q ui za lofop on a chronic basis. Direct acute effec ts to li ste d and p.on- li ste d estuarine/marine fish are mot expec ted since acute RQs were below the li sted species LOC of 0.05. Chronic effects to listed and non-listed estuar ine / marine fish are not expected since the chro nic RQs did not exceed the chro ni c LOC of l. Freshwater Invertebrates Ac ut e RQ s for freshwater invertebrat es ranged from 0.002 to 0.057. No uses exceeded th e non-listed species LOC of0.5. However , acute RQs exceed the li s t ed species LOC of0.05. Chronic RQs for freshwater invertebrates were all <0.001. None of the RQs exceeded the chronic LOC of 1 for any re giste red use of quizalofop. Direct effects to listed fresh water invertebrates are expected on an acute basis s i nce acute RQs exceed the li sted species LOC of 0.05. Chronic direct effects to listed and non-listed freshwater invertebrates are not expected s in ce RQs were below the chronic LOC of 1.

E stuarine/Marine Invertebrates Acute RQ s for estuar in e/marine inv ertebrates ranged from 0.004 to 0. 133. No uses exceeded the non-li sted species LOC of0.5. However , RQs for two uses exceeded the acute listed species LOC of 0.05: pineapple (ground and aeria l ), and paved areas (ground and aerial). Chronic RQs for estuarine / marine invertebrates ranged from 0.002 to 0.057. None of the RQs exceeded the c hr o nic LOC for I for any regi ste red use of quiza l ofop. Direct acute effects t o li ste d es tua r i ne/mar in e inv e rteb ra t es a r e expected on an acute ba sis as ac ute RQ s exceed the li sted s pe cies LOC of 0.05 for two uses. Direct chronic effects to listed and non-listed estuarine / marine invertebrates are not expected since RQs were below the chron i c LOC ofl. 1 2Aquatic Vascular and Non-vascular Plants Aquatic vascular plant RQs ranged from 0.015 to 0.580. Aquatic non-vascular plant RQs were all <0.00 I. None of the aquat ic plant RQs exceeded the LOC of 1 for any registered use of quizalofop.
Direct effects to li sted and non-li sted aquatic vascular and non
- vascular plants are thu s not expected as RQs did not exceed the LO C of 1.



### 3. Ecological Incidents According to a search conducted for quizalofop on September 26 , 2012, using the Ecological Incident Information System (EllS), one major and one minor inc ident were reported fo r quizalofop from 1988 to 20 12. The major incident occurred when spray drift from an application of quizalofop and sodium fomesafen to soybeans impacted home gardens. The minor incident was associated with minor p lant damage. For additional details, please refer to Registration Review-Ecological RiskAssessment and Effects Determination ofQuizalofop-pethyl, dated February 19 ,20 13 in docket EPA-HQ -OPP-2007-1089 , which can b e accessed at www.regulations.gov.


### 4. Ecological Risk Characterization for Non-Listed Species
Eco logical risk estim ates for quizalofop represent screening -level analysis where the Agency uses reasonable worst-case scenarios and conservative assumptions with the intention that estimates do not underestimate risk. EPA has determined that there is potential for adverse effects to non-listed mammals and freshwater fish and aquatic-phase amphibians (chronic RQs exceed LOCs) as well as non-listed terrestrial and wetland/riparian plants (RQs for monocots exceed LOCs) based on its screening-level risk assessment. Mammals
The preliminary ecological risk assessment identified chronic risk to small and medium sized mammals consuming short grass from all uses of quizalofop. The assessment also identified chronic risk to aJl mammals from use on pineapple and ornamental and/or shade trees. Chronic risk to mammal s was estimated using a two-generation rat reproduction study in which parental , Fl , and F2 generations are exposed to different do ses of quizalofop via treated food , but the study is not designed to determine the duration of time needed to manif est adverse effects. As a result , it was unc ertain if adverse effects observed in mammals were the result of short-term exposure during a critical development window or longer term exposure. The Agency further refined its assessment of chronic risk to mammals by analyzing data from a pre-natal development rat study which tested shorter exposure durations (see Refinements to the Quizalojop Preliminary Risk Assessment in Support of Registration Review, dated March 20, 2014). Results sugge sted that adverse effects (decreased pup survival) were not the result of short-term exposure
. Consequently , risk to mammals i s believed to be lo w if the exposure duration is short (less than 10 days). At the highest application rate (pineapple at 2 applications at 0.208 lb ai/A with 7 day intervals), EECs were not high enough to cause adverse chronic
13effects. Since this is true fo r the highest use rate, on pineapple, it is assumed that it would apply to all of the other quizalofop uses with lower application rates. Thus, chronic risk to mammals is expected to be low. Furthermore, with regard to the chronic ri s k to large mammal s from u se on pineapple and o rnam en ta Vshade trees , there are a number of factors which the Agency eva luat ed. Pineapple is on l y g r own in ve r y s m all areas of Puerto Rico a nd Ha waii, which limit s th e number of large mammal species potentially ex p osed to quizalofop. Ornamental and / o r shade tree produ c tion is unlikely to occur in area s where large mammals forage , as most production occurs indoors in greenhouses or outdoors in l arge industrial-sized l ots in urban/suburban areas. Terrestrial and wetland/r iparian plants Only monocots had RQs that exceeded the LOC. In the risk assessment, conservative

parameters were chosen to model spray drift from groun d applications (max imum application rate , high boom, very fine to fine droplet s i ze , 90'h data percentile) and aer i a l applications ( maximum application rate , very fin e to fme droplet s iz e). When AgDRIFT was rerun with l ess conservative application paramete rs (inc r eased droplet size, redu ced boom height) , est imat ed buffer distances were reduced by hundreds of feet (see table 5 of Refinements to the Quizalofop Preliminary Risk Ass e ssment in support of Regi s tration R eview, dated March 20, 2014). In real world scenarios, applicators would be expected t o a pply quizalofop at larger drop l et size s and at application rates s ui tab l e to the crop being tre ate d and only when wind conditions were

favorable. Estimated r ea l world risk to monocots are expected to be l ess than est imat e d in the Agency's ri sk assessment , wh i ch is nece ssarily conservative. Freshwater fi s h and aquatic-phase amphibians The chronic RQs for freshwater fish (a surrogate for aquati c -ph ase a mphibians ) exceeded the LOCs for two uses: pineapple and pav e d areas . The pineapple u se is geog raphically

re s tricted to Hawaii and Pu erto Rico. The other u se, paved areas , i s nation-wide. The Agency does not believe that ri sk to fres hwater fish/aquatic-phase amphibians are of conce rn because pineapple is grown in very small areas of Puert o Rico and Hawaii. Additionally , quiza l ofop use on pineapple is limited to an even smaller subse t of these areas.

According to the University of Ha wa ii at Manoa , quizalofop is typ i cally appl i ed at 1 to 2 kglha (0.892 -1.784lb s / A) on 0.5% of the acreage (Sipes , 2000) . The paved area sce nario was modeled u s in g th e conservative assump t io n that 100% of the qui z alofop app l i ed to an acre is available for off -site transport. Howev er, realistically, thi s number is likely much lower as quizalofop i s being used as a spot treatment for weeds tha t are present in cracks within a paved area. It is unl ik e l y that quizalofop would be applied over an

entire acre of paved area. 14Endangered Species Assessment
In November 2013 , the EPA, along with the U.S. Fi sh 

### & Wildlife Service (US FWS ) , the National Marine Fisheries Service (NMFS) (collecti vely , the Services), and the U .S. Department of Agriculture (US DA) released a summary oftheirjoin t Interim Approaches for assessing risks to listed species from pesticides. The Interim Approaches were developed jointly by the agencies in re sponse to the National Academy of Sciences' (NAS) recommendations and reflect a common approach to risk assessment shared by the agencie s as a way of addressing scientific differences between the EPA and the Services. The NAS report outlines recommendations on specific scientific and technical issues related to the development ofpesticide risk assessments that EPA and the Services must conduct in connection wit h their obligation s under the Endangered Species Act (ESA) and FIFRA.
The joint Interim Approaches were released prior to a stakeholder workshop held on November 15 , 20 13. In addition, the EPA presented the joint Interim Approaches at the December 2013 Pesticide Program Dialo gue Committee (PPDC) and State-FIFRA Issues Research and Evaluation Group (SFIREG) meetings, and held a stakeholder workshop in April 2014, allowing additional opportunities for stakeholders to comment on the Interim Approaches. As part of a phased, iterative process for developing the Interim Approaches, the agencies will also consider public comments on the Inte rim Approaches in connection with the development of upcoming registration review decisions. The details of the joint Interim Approaches are contained in the white paper " Interim Approaches for Nation al-Level Pe sticide Endangered Species Act Assessments Based on the Recommendations ofthe National Academy of Sciences April 2013 Report," dated Novem ber 1, 2013. Given that the agencies are continuing to develop and work toward implementation of the Interim Approaches to assess the potential risks of pesticides to listed species and their designated critical habitat , the ecological ri sk assessment supporting thi s Interim Registration Re view Decision for quizalofop does not contain a complete ESA analysis that includes effects determination s for specific li sted species or designated critical habitat. Although EPA has not yet completed effects determinations for specific species or habitats, for this preliminary assessment EPA conducted a screening-level assessment for all taxa of non-target wildlife and plants that assumes for the sake of the assessment that listed species and designated critical habitats may be present in the vicinity of the application of quizalofop

. This screening-level assessment will allow EPA to focus its future eva luation s on the types of species where the potential for effects exists once the scientific methods being developed by the agencies hav e been fully vetted. Once the agencies have fully developed and implemented the scientific method s necessary to complete risk ass essment s for endangered and threatened (lis ted) species and the ir designated critical habitats, these methods will be app li ed to subsequent analyses for quizalofop as part of completing this registration review.

Endocrine Disruptor Screening Program
As required by FIFRA and FFD CA , EPA reviews numerous studies to assess potential adverse outcomes from exposure to chemicals. Collectively , these studies include acute ,
15subehronic and chronic toxicity, including assessments of carcinogenicity , neurotoxicity, developmental , reproductive, and general or systemic toxicity . These studies i nclude endpoints w hi ch may be s u sceptib l e to endocrine influence , including effects on endocr in e target organ histopathology, organ weights, estrus cyclicity , sexual maturation, fertility , pregnancy rates, reproductive loss, and sex ratios in offspring. For eco l ogica l hazard assessments , EPA evaluates acute tests and chronic stud ies that assess growth , developmental and reproductive effects in different taxonomic groups. As part of its most r ecent registration decision for quizalofop , EPA reviewed these data and selected the most sensitive endpoints for relevant risk assessment scena rios from the existing hazard database. However , as required by FFDCA section 408(p) , quizalofop is subject to the endocrine screening part of the Endocrine Disrupter Screening Program (EDSP). EPA has developed t h e EDSP to determine whet her certain s u bstances (including pesticide active and other ingredients) may have an effect i n humans or wi l dlife similar to an effect produced by a " naturally occurring estrogen , or other such endocrine effects as the Administrator may designate. " The EDSP employs a two - tiered approach to making the statuto rily required determinations. Tier 1 consists of a battery of 11 screening assays to identify the potential of a chemical substance to interact with the estrogen , androgen , or thyroid (E , A , or T) hormonal systems. Che micals that go through Tier 1 screening and are found to have the potentia l to interact withE, A , or T hormonal systems wi ll proceed to the next stage of the EDSP

where EPA will determine which, if any., of the Tier 2 tests are necessary based on the available

data. Tier 2 testing i s designed to id en tify any adverse endocr in e -r elated effects caused b y the substance, and establish a dose-response relationship between the dose and the E, A, or T effect.

U nder FFDCA section 408(p ), the Agency must screen all pesticide chemicals. Between

October 2009 and February 2010 , EPA issued test orders/DCis for the first group of 67 chemicals, which contains 58 pesticide active ingredients and 9 inert ingredients. A second li s t of chemicals identified for E DSP screening was pub li s hed on June 14 , 2013 1 and includes some pesticides scheduled for registration review and chemicals found in water. Neither of these lists should be construed as a li st of known or lik ely endoc rine disrupters. For furt h er information on the status of the EDSP , the policies and procedures , the lists of chemicals , future li sts, the test

g uidelines and the Tier 1 sc reening battery , please visit our website. 2 Quizalofop i s o n List 2. List 2 represent s the next set of chemicals for which EPA intends to issue test orders/DCis in the near future. I n the interim, EPA is making no human health or environmental safety findings associated with the ES DP screen in g of quizalofop. Before completing the registration review , the Agency will make an EDSP FFD CA section 408(p) determination. 1 See http : // www.regulation s.g ov / # !documentOetaii;D = E PA-HQ-OPPT-2009-0 477-0074 for the fmal second li st of chem icals. 2 http: // www.epa . gov / endo / 16

### IV. INTERIM REGISTRAT IO N REVIEW DECISION
A. To le rance Amendments
A lthough EPA has determined that there are no adverse human health effects from all uses of quiza lofop, the Agency will pursue changes to the quizalofop toleranc es in the interest of harmonization with MRL s for certain commodities established in Canada. B. Risk Mitigation Measures and Regulatory Rationale The Agency believes there is the potential for adverse effects to non-listed mammals , freshwater fish , aquatic-phase amphibian s, and terrestrial and wetland/riparian plants. In order to addre ss potential ecological effects, the quizalofop technical registrants (DuPont, Nissan, and Sharda) , based on discussions with the Agency, will amend their affected product registrati ons and labels to incorporate the following ri sk mitigation measu res: 1) Limit spot treatments and clari fy use directions on quizalofop label s for products with use on paved areas. 2) Delete aerial applicat ion to pineapple. 3) Delete aerial application to non-food/non

-feed crops and ryegrass crops grown under co ntrac t for seed production. 4) De lete aerial application in eucalyptus plantation s. 5) De lete aerial application to hybrid poplar plantings. 6) Delete aerial application to non-crop areas (such as fence rows , road si des, equipment sto rage areas , and similar areas). 7) Include medium /coarse or larger spray droplet size requirements on the labels for all ground broadcast appli cation s. 8) Include coarse or larger spray droplet s ize requi rements on the labe ls for all aerial broadcast app li cations

. With the adoption of these risk mitigation measures , the Agenc y believes that estimated risk to non-listed mammals , freshwater fish , aquatic

-phase amphib ians , and terrestrial and wetland/riparian plants are lower (see App endix A

. Summary of Actions Taken for Quizalofop)

. . Also , in consideratio n of quiza lofop's utility as an herbicide that selectively controls certain monocot weeds, it has importance in certain minor use niche markets (e.g. , dry beans/peas , mint , pineapple , sunflower, and ornamental trees ).
In addition to the above listed changes , the Agency believes that the grazing restriction on the Assure II label (EPA Reg
. 352

- 541) will be removed. The label currently states that grazing of livestock i s prohibited in treated areas. The removal of this language i s meant to improve the clarity of the label.
DuPont, Nissan, and Sharda are currently wo rkin g with the Agency to revise their quizalofop labels to reflect the changes identified above. Below i s the regulatory rationale for
1 7these actions. Proposed amended labels have already been submitted to the Agency for review and will be amended as part of registration review. Regulatory Rationale To reduce spray drift risks to non-target plants , the registrants volunta r ily agreed to increase the droplet size for both ground broadcast and aerial application. Applicators applying quizalofop by ground broadcast equipment will be required by the labels to use application . technology that will deliver medium coarse , or larger spray droplets and applicators applying quizalofop by air broadcast application will be required to use application technology that will deliver coarse or larger spray droplets as defined in the American Society of Agricultural and Biological Engineers standard ANSI/ ASA E S572.1. The intended impact of making these changes is to reduce the distance that spray droplets will drift from the site of application and

reduce exposure to non-target plants. Furthermore, the registrants have voluntarily agreed to change product labels to remove aerial application for some uses: pineapple, non-food/non-feed crops and ryegrass crops grown under contrac t for seed production, eucalyptus plantations, hybrid poplar plantings, and non-crop areas (such as fence rows , roadsides, equipment storage areas, and similar areas). These label changes are intended to result in reduced off-site transport into terrestrial areas , streams, river, lakes, and other water bodies and therefore reduce exposure to non-target plants and freshwater fish , aquatic-phase amphibians, and other aquatic organisms. According to the University of Hawaii at Manoa, pesticides are usually applied to pineapple crops via ground application with truck-mounted boom sprayers (Bartholomew et al., 2002), so this labeling change is unlikely to

substantially affect pineapple growers.

For application of quizalofop to paved areas , the Agency believes (and the technical registrants agree) that this use is intended to be a spot treatment. However, current labels do not define specific applications as spot treatments. The registrants have voluntarily agreed to add

label language which includes spot treatment directions for all products intended to be used on paved areas. Spot treatments will be defined on the quizalofop labels as an applicatio n applied to less than 10% of the total paved area. Risk to freshwater fish and aquatic-phase amphibians is expected to be lower with the incorporation of these label changes. C. Interim Registration Review Decision

In accordance with 40 CFR Sections 155.56 and 155.58, the Agency is issuing this Interim Registration Review Decision. Except for the EDSP and ESA components of this case, the Agency has made the following Interim Registration Review Decision: (1) guidelines 860.1360 multi-residue methods and 860.1650 analytical reference standards are still data gaps; and (2) changes to the affected registrations and their labeling as described in this document are needed at this time (see Appendix B. Quizalofop Label Table). In this interim registration review decision, EPA is making no human health or environmen t al safety findings associated with the EDSP screening of quizalofop, nor is it making a complete endangered species finding. The Agency's final registration review decision for 18quizalofop will be issued once an ESA Section 7 consultation with the Services has taken place , and an EDSP FFDCA section 408(p) determination has b een made.



### V. NEXT STEPS AND TIMELINE

A. Implementation of Mitigation Measu r es Registrants are required to submit proposed amended labels that include the agreed-upon changes to the Agency for approval within 60 days following issuance of the Interim Regi stration Review Deci sio n. The changes are described in Appendic es A and B. B. Final Registration Review Decision
EPA will make a final registration review decision for quizalofop after ESA Section 7 consultation with the Services has tak en place and an E D SP FFDCA section 408(p) determination has been made
.

1 9References Bart h olomew, Duane P., Kennet h G. R ohrbach, and Da l e 0. Evans. "P ineapple Cu lti vat i o n in Hawaii." College ofTropical Agriculture and Human Resources. University of Hawaii at

Manoa , October 2002. Web. Jul y 8 , 20 14 . h ttp: // www.ctahr.hawa ii .edu/oc / freepubs / pdf / f _ n7.pdf Sipes, Brent. "C rop Profile for Pineapples in Hawaii " . N ational Information System for the Regional !PM Centers. United States D epartment of Agriculture , Januar y 2000. Web. J uly 7, 20 14. http: l/ www.ipmcenters.org/cropprofile s/ docs / hipineapples.pdf 20Appendix A: Summary of Mitigation for Quizalofop Registration Review Case#: 7215 PC Codes: 128711 (quizalofop-ethyl) and 128709 (quizalofop-p-ethyl) Chemica l Type : herbicide Chemical Family: aryloxyphenoxy-propionate Mode of Action: inhibition of acetyl CoA carboxylase enzyme
Affected Source of Route of Exposu r e Duration of Risk(s) o f Concern Mitigatio n

**~omment** P

opulation(s) Exposure Exposure

./ Mammals ./ Water ./ In ges tion ./ Acute ./ Chronic ./ Restr ict ./ Monocots ./ Residues ./ In h alation ./ Sub- toxici ty application ./ Freshwater at/on site ./ Dermal chronic ./ R e productiv e methods fish of absorption ./ Chronic ./ End oc rine ./ Re q ui re spray ./ Aquatic tre atment ./ Transplacental disruption drift reduct io n phase ./ Dietary ./ Indi rect amphibians ./ Air (aerosols during s pra ying, vapor) ./ Soil EXAMPLES Affected Source of Route of E xposu re Duration of Ri sk(s ) of Co nce rn Mitigation

**~omment** Population(s) E xposure Exposure

Monocots Water,

**~ystemic,** direct

**hort term,**  Long-term Restrict application Risk to non-target Residues contact Long

- term, exposure methods, plants reduced by at/on/near Require spray drift Implementing site of reduction droplet size

reatment equirements and

**~oil** emoval of aerial application for some uses Mammals Dietary, Dermal, Acute, Chronic toxicity Restrict application

**~pray** drift reduction

**~ir** Ingestion, Chronic methods, measures reduce Inhalation, Require spray drift

**~xposure** to nonTransplacental reduction arget plants, wh ich

**~re** potential food

**~ources** for mammals Freshwater fish, Wate r Dermal ,

**~cute, ~cute**  toxicity Restrict application

**~pray** drift reduction

**~quatic** phase Inge stio n

**~h ronic**  **hron ic**  toxicity methods , mea sures and spot !a mphibians Require spray drift

**~reatment** directions reduction, !On label s reduce off-

**~pot** treatment

**~ite** transport to label language jwaterway s

2 1IIIDocketNumberEPA-HQ-OPP-2007-1089www.regulations.govAppendixB:QuizalofopLabelTableDescriptionSpottreatmentlanguageforuseonpavedareasSummaryofLabelingChangesforQuizalofopUsesAmendedLabelingLanguageforQuizalofopUseProductsEndUseProducts"Forpavedareas,applyspot/smallareatreatmentsonly.Donottreat>I0%ofthetotalpavedareaasspot/smallareatreatment."Removalofaerialapplicationtopineapple"Applybygroundapplicationequipmentonly.Donotapplybyair."Removalofaerialapplicationtononfood/non-feedcropsgrownforseed"Applybygroundapplicationequipmentonly.Donotapplybyair."productionRemovalofaerialapplicationineucalyptus.plantations"Applybygroundapplicationequipmentonly.Donotapplybyair."Removalofaerialapplicationtohybridpoplarplantings"Applybygroundapplicationequipmentonly.Donotapplybyair."- -PlacementonLabelApplicationInformationUnder"NonagriculturalUses"SpecificCropUsesUnder"ForUseinPineapple"SpecificCropUsesUnder"ForUseOnNon-Food/Non-FeedCropsGrownUnderContractForSeedProduction"iSpecificCropUsesUnder"ForUseInEucalyptusPlantations"SpecificCropUsesUnder"ForEstablishmentofHybridPoplarPlantings"20Summary of Labeling Changes for Quizalofop Uses

Description Amended Labe l ing Language for Quizalofop Use Pr oducts Pl acement on L abel

E nd Use Product s

Removal

of aeria l Application

application to non-crop In formation

areas (such as fence "

Apply by ground application equipment only. Do not apply by air. "

row s , roadsides

, equipment

storage areas , Under "Nonand etc) Agricu ltur al Uses"

Medium/coar se or larger Application

s pray droplet s ize Equipme n t

r

equirements for all " Wh en applying by g round

, use spray nozzles that will deliver med i um /c oarse or larger spray droplets as defined in the

g r ound broadcast American Soc iety of Agricultural and Biological Engineers (ASABE) s tandard ANSI/ASAE S572.1 (March 2009)."

Under "Grou n d

applications · Appl i catio n "

Coarse or larger spray App l ication

droplet size requirements Equ ipm ent

for

all aerial broadcast " When app l ying by air, use spray nozzles that will deliver coarse or larger spray droplets as defined in the American

applications Society of Agricultural and Biological Engineers (ASABE) standard ANSIIASAE S572.1 ( March 2009). " Under

"Ae rial Application "

Remo val o f grazi n g Restriction

language Under " Grazing

Del ete gr azing restriction lan guage.

Re s triction " 2 1