**EXPLA NA**  **TORY HISTORY A PPENDIX III**  On May 21, 2009 , the Agency

issued the Phase 5 Rer egistration Eligibility Decision (RED) Document Product Data Call

- InNotice pursuant to section 4(g)(2)(B) of FIFRA , which required the registrants of product s containing P yr ethrins used as an active ingredient to develop and submit certain data. The data/information w ere determined to be necessary

to satisfy the reregistration requirements of section 4(g). Failure to comply with the requirements of a Phase 5 Reregistratio n Eligibility Document Product Data Call

- InNotice (PDCI ) is a basis for suspension under section 3(c ) ( 2 ) ( B) of FI FRA. Paul A. Keane & Associates (hereinafter referred to as “Paul Keane”) the authorized agent for the Py rethrum Board of Keny a, received the Py rethrins RED and Product Data Call

- In , as evidenced by the submission of the 90

- Day Response, Requirements Status and Registrant’s Response Form, dated October 13, 20 09

. Inthe cover letter for the 90

- Day Response, Paul Keane specifically referenced the May

21, 2009 PDCI

. On the for

m, the Py rethrum Board of Keny a indicated an intent ion to submit data to su pport their py

rethrins product, EPA Registration Number 4713

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. On March 19, 2010, Paul Keane submitted acute toxicity and product chemistry

data to support reregistration. Tho s e data were reviewed and the acute toxicity data were found to be acceptable, but the product chemistry data w ere found to be deficient, as described in the Agency review by

Nina Simeonova on March 9, 2011. Inan Agency le tter from Moana Appley ard on March 11, 2011 to Mary Beth Endres of RegWest, the product chemistry review of March 9, 2011, was included. The Agency letter also stated that the required data were due within 10 day s from receipt of the letter. On May 11, 2 012, the Py

rethrum Board of Keny a changed their authorized agent to RegWest Company , L LC (hereinafter referred to as “ RegWest ”). RegWest submitted data to the Agency on June 13, 2012 . The data were reviewed by Maria Piansay on June 19, 201 2

. According to the review, the C onfidential S tatement of F ormula was deficient as well as data on 830.6313, Stor age Stability ; data on 830.6317, Corrosion Characteristics ; and data on 830.6320, Stability to metals and metal ions. These deficiencies were reported to Kim Davis of RegWest in an Agency letter from Moana Appley ard, dated June 25, 2012, and the registrant was required to submit the data within 10 day s of receipt of the Agency ’s letter. Repeated a gency communications via email from Moana Appley ard on September 9, 2013 and February

3 , 2014, requested the overdue data from RegWest

. On February 5, 2014, RegWest responded to the emails with a declaration from the company that they will pay their maintenance fees for 2014. Moana Appley ard replied by email on February 5, 2014 that the product would be suspended if the outstanding data was not submitted to the Agency

. On July

4, 2014, RegWest sent an email to Moana Appley ard stating an intention to conduct the required studies over the next y ear . Moana Ap pley ard responded with an email stating the Agency ’s intention to suspend the product until the data are submitted and determined to be acceptable.The required data to support product reregistration for the affected py rethrins product remain overdue at this time. T herefore, this Notice of Intent to Suspend is being issued for EPA Registration Number 4713

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