EPA Reg. No. 71532-7

Volume 1 part 2
.... 

August 8, 2005 

Mr. George LaRocca (PM Team 13) 

Office of Pesticide Programs (7504C) 

US Environmental Protection Agency 

Ariel Rios Building 

1200 Pennsylvania A venue, NW 

Washington, DC 20460 

SUBJECT: LG Life Sciences, Ud. 

.. 9' 

"LG Permethrin Technical PH Insecticide"; EPA Reg. No. 71532-7 and 

"LG Pennethrin 3.2 EC Agricultural Insecticide"; EPA Reg. No. 71532-15 

Submittal of Final Labeling 

Dear Mr. LaRocca: 

As per the Notices of Pesticide Registration, please find enclosed copies of final labeling with the 

changes and corrections made as stated in each Notice. 

Should you have any questions or otherwise wish to reach me, please feel free to contact my 

office at (203) 740-1200. 

115 Obtuse Hill. Brookfield, Connecticut 06804· USA 

Voice: 203.740.1200" Fax: 203.740.1220· Email: lmiller@biologicconsulting.com 

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1
LG PERMETHRIN TECHNICAL PH 

INSECTICIDE 

AN INSECTICIDE FOR FORMULATING USE ONLY 

NOTREVIEWBD 

In Accordance with PR Notice 82-2 

Based on Draft Labeling Dated 

FOR FORMULATION OF MOSQUITO CONTROL PRODUCTS 

AND ULV MOSQUITO CONTROL AGENTS. 

ACTIVE INGREDIENT: 

·Permethrin ............................................................................................................... 95.2'% 

OTHER INGREDIENTS: ............ . .. .. .. ........................ ............. ............ .................. .. ................. 4.8% 

* (3-Phenoxyphenyl) methyl(±) cis, trans-3-(2,2dich loroethenyl)-

2,2-dimethylcyclopropanecarboxylate 

cis/trans ratio: min. 35% (±) cis and max. 65% (±) trans. 

KEEP OUT OF REACH OF CHILDREN 

CAUTION 

See Back Panel For Additional Precautions 

Manufactured by: 

LG Life SCiences, Ltd. 

20 Voido-dong 

Youngdungpo-gu 

Seoul, Korea 

EPA Reg. #71532-7 

EPA Est. #71532-KOR-1 

Net Contents: 110 Ibs. 

Total 100.0% 

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2
•• 

PRECAUTIONARY STATEMENTS 

Hazards to Humans and Domestic Animals 

CAUTION 

Harmful if swallowed or absorbed through skin. Causes moderate eye irritation. Avoid contact with eyes, 

skin or clothing. Prolonged or frequently repeated skin contact may cause allergic reactions in some 

individuals. Wash thoroughly after handling. 

Environmental Hazards 

This product is extremely toxic to fish. Keep out of lakes, streams, ponds, tidal marshes or estuaries. Do 

not contaminate water by cleaning of equipment or disposal of wastes. Do not discharge effluent 

containing this product into lakes, streams, ponds, estuaries, oceans or other waters unless in 

accordance with the requirements of a National Pollutant Discharge Elimination System (NPDES) permit 

and the permitting authority has been notified in writing prior to discharge. Do not discharge effluent 

containing this product to sewer systems without previously notifying the local sewage treatment plant 

authority. For guidance contact your State Water Board or Regional Office of the EPA. 

Physical and Chemical Hazards 

Do not use or store near heat or open flame. 

First Aid 

If Swallowed: Call a poison control center or doctor immediately for treatment advice. Have person sip 

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

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

If 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 15-20 minutes. Remove contact 

lenses, if present, after the first 5 minutes, then continue rinsing eye. Call a pOison control center or 

doctor for treatment advice. 

User Safety Recommendations 

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

DIRECTIONS FOR USE 

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

STORAGE AND DISPOSAL 

Prohibitions: Do not contaminate water, food or feed by storage or disposal. Open dumping is 

prohibited. Do not reuse empty container. 

Storage: Keep container closed when not in use. Do not store near food or feed. Protect from freezing. 

In case of spill or leak on floor or paved surfaces, soak up with sand, earth or synthetic absorbent. 

Remove to chemical waste area. 

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

rinsate is a violation of Federal law. 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 of the nearest EPA Regional Office for guidance. 

Container Disposal: Triple rinse (or equivalent): then offer for recycling or reconditioning or puncture 

and dispose of in a sanitary landfill, or by other procedures approved by state and local authorities. 

2 

3
.-• .J - • 

Formulators using this product are responsible for obtaining EPA registration for their formulated product 

which may be labe,led for the use patterns as found listed on this label. 

ONLY FOR FORMULAT!ON INTO AN INSECTICIDE FOR THE FOLLOWING USES: 

TERRESTRIAL NON-FOOD USE* AND DOMESTIC OUTDOORS. 

FOR THE CONTROL OF MOSQUITOES, GNATS, BITilNG AND NON-BITING MIDGES, BLACKFLlES, 

DEERFLIES AND OTHER BITING FLIES. 

* EXCEPTION: This product may be used to formulate mosquito control products that are labeled for 

application over growing crops and range grasses that have established tolerances for permethrin. 

CONDITIONS OF SALE AND LIMITATION OF WARRANTY AND LIABILITY 

NOTICE: Read the entire Directions for Use and Conditions of Sale and limitation of Warranty and 

Liability before buying and using this product. If the terms are not acceptable, return the product at once, 

unopened, and the purchase price will be refunded. 

The Directions for Use of this product should be followed carefully. It is impossible to eliminate all risks 

inherently associated with the use of this product. Crop injury, ineffectiveness or other unintended 

consequences may result because of such factors as manner of use or application, weather or crop 

conditions, presence of other materials or other influencing factors in the use of the product, which are 

beyond the control of LG Ufe SCiences, Ltd. or Seller. All such risks shall be assumed by Buyer and 

User, and Buyer and User agree to hold LG Life Sciences, Ltd. and Seller harmless for any claims 

relating to such factors. 

LG Life Sciences. Ltd. warrants that this product conforms to the chemical description on the label and is 

reasonably fit for the purposes stated in the Directions for Use, subject to the inherent risks referred to 

above, when used in accordance with directions under normal use conditions. This warranty does not 

extend to the use of this product contrary to label instructions, or under abnormal conditions or under 

conditions not reasonably foreseeable to or beyond the control of Seller or lG Life Sciences, Ltd. and 

Buyer and User assume the risk of any such use. To the extent permitted by law, LG Life Sciences, ltd. 

MAKES NO WARRANTIES OF MERCHANTABILITY OR OF FITNESS FOR A PARTICULAR PURPOSE 

NOR ANY OTHER EXPRESS OR IMPLIED WARRANTY EXCEPT AS STATED ABOVE. 

To the fullest extent permitted by law LG life Sciences, Ltd. or Seller shall not be liable for any incidental, 

consequential or special damages resulting from the use or handling of this product. TO THE EXTENT 

PERMITTED BY LAW, THE EXCLUSIVE REMEDY OF THE USER OR BUYER, AND THE EXCLUSIVE 

LIABILITY OF LG LIFE SCIENCES, LTD. AND SELLER FOR ANY AND ALL CLAIMS, LOSSES, 

INJURIES OR DAMAGES (INCLUDING CLAIMS BASED ON BREACH OF WARRANTY, CONTRACT, 

NEGLIGENCE. TORT, STRICT LIABILITY OR OTHERWISE) RESULTING FROM THE USE OR 

HANDLING OF THIS PRODUCT, SHALL BE THE RETURN OF THE PURCHASE PRICE OF THE 

PRODUCT OR, AT THE ELECTION OF lG LIFE SCIENCES, LTD. OR SELLER, THE REPLACEMENT 

OF THE PRODUCT. 

LG Life Sciences, Ltd. and Seller offer this product, and Buyer and User accept it, subject to the foregoing 

conditions of sale and limitations of warranty of liability, which may not be modified except by written 

agreement Signed by a duly authorized representative of LG Life Sciences. Ltd. 

3 

4
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Mr. Lawrence A. Miller JUL 2 7 2005 

Agent for LG Life Sciences Ltd. 

115 Obtuse Hill 

Brookfield, Connecticut 06804 

Dear Mr. Miller: 

Subject: Amendment- designate use over crops with tolerances 

LG Permethrin Technical PH Insecticide 

EPA Registration Number 71532-7 

Your submission dated May 5, 2005 

The amendment referred to above, submitted in connection with 

registration under FIFRA section 3 (c) (7) (a), is acceptable provided 

that you: 

1. Submit and/or cite all data or other material required for 

registration/reregistration of your product under FIFRA 

section 3(c) (5) or FIFRA section 4 when the Agency requires 

all registrants of similar products to submit such data. 

2. Make the labeling changes listed below before you release 

the product for shipment bearing the amended labeling: 

a) Delete ~In No event shall LG Life Sciences, Ltd. or seller be 

liable for any incidental, consequential or special damages 

resulting from use or handling of this product." This statement is 

overly broad and implies buyer has no legal right to recover 

damages from manufacturer and is unacceptable under statutory and 

regulatory standards. we recommend revising it to read "To the 

fullest extent permitted by law LG Life Sciences, Ltd., Inc or 

Seller shall not be liable for any ... etc." or " It is LG Life 

Sciences, Ltd. intent that in no case shall LG Life Sciences, Ltd. 

or Seller be liable ... etc. n • 

5
3. Submit three (3) copies of your final printed labeling 

before you release the product for shipment. 

If these conditions are not complied with, the registration 

will be subject to cancellation in accordance with FIFRA section 

6 (e) . Your release for shipment of the product constitutes 

acceptance of these conditions. 

A stamped copy of the label is enclosed for your records. 

Enclosure 

Sincerely, 

George T. LaRocca 

Product Manager 13 

Insecticide Branch 

Registration Division (7505C) 

6
LG PERMETHRIN TECHNICAL PH 

INSECTICIDE 

AN INSECTICIDE FOR FORMULATING USE ONLY 

FOR FORMULATION OF MOSQUITO CONTROL PRODUCTS 

AND ULVMOSQUITO CONTROL AGENTS. 

ACTIVE INGREDIENT: 

AOtEPTED 

wtth COllWENTS 

In EPA Lettet- DIded 

, JUL 2 7 2005 

*Permethrin .................................................... " ......................................................... 95.2% 

OTHER INGREDIENTS:..................... ................ ........................................ .................. ....... ... 4.8'% 

• (3-Phenoxyphenyl )meth yl(±) cis, trans-3-(2,2dich loroethenyl)-

2,2-dimethylcyclopropanecarboxylate 

cis/trans ratio: min. 35% (±) cis and max. 65% (±) trans. 

KEEP OUT OF REACH OF CHILDREN 

CAUTION 

See Back Panel For Additional Precautions 

Manufactured by: 

LG Life SCiences, Ltd. 

20 Vaido-dong 

Youngdungpo-gu 

Seoul, Korea 

EPA Reg #71532~7 

EPA Est. #71532-KOR-1 

Net Contents: 110 Ibs. 

Total 100.0% 

7
PRECAUTIONARY STATEMENTS 

Hazards to Humans and Domestic Animals 

CAUTION 

Harmful if swallowed or absorbed through skin. Causes moderate eye irritation. Avoid contact with eyes, 

skin or clothing. Prolonged or frequently repeated skin contact may cause allergic reactions in some 

individuals. Wash thoroughly after handling. 

Environmental Hazards 

This product is extremely toxic to fish. Keep out of lakes, streams, ponds, tidal marshes or estuaries. Do 

not contaminate water by cleaning of equipment or disposal of wastes. Do not discharge effluent 

containing this product into lakes, streams, ponds, estuaries, oceans or other waters unless in 

accordance with the requirements of a National Pollutant Discharge Elimination System (NPDES) permit 

and the permitting authority has been notified in writing prior to discharge. Do not discharge effluent 

containing this product to sewer systems without previously notifying the local sewage treatment plant 

authority. For guidance contact your State Water Board or Regional Office of the EPA. 

Physical and Chemical Hazards 

Do not use or store near heat or open flame. 

First Aid 

If Swallowed: Call a poison control center or doctor immediately for treatment advice. Have person sip 

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

center or doctor. Do not g1ve anything by mouth to an unconscious person. 

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 15·20 minutes. Remove contact 

lenses, if present, after the first 5 minutes, then continue rinsing eye. Call a poison control center or 

doctor for treatment advice. 

User Safety Recommendations 

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

DIRECTIONS FOR USE 

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

STORAGE AND DISPOSAL 

Prohibitions: Do not contaminate water, food or feed by storage or disposal. Open dumping is 

prohibited. Do not reuse empty container. 

Storage: Keep container closed when not in use. Do not store near food or feed. Protect from freezing. 

In case of spill or leak on floor or paved surfaces, soak up with sand, earth or synthetic absorbent. 

Remove to chemical waste area. 

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

rinsate is a violation of Federal law. 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 of the nearest EPA Regional Office for guidance. 

Container Disposal: Triple rinse (or equivalent): then offer for recycling or reconditioning or puncture 

and dispose of in a sanitary landfitl, or by other procedures approved by state and local authorities. 

2 

8
Formulators using this product are responsible for obtaining EPA registration for their formulated product 

which may be labeled for the use patterns as found listed on this label. 

ONLY FOR FORMULATION INTO AN INSECTICIDE FOR THE FOLLOWING USES: 

TERRESTRIAL NON-FOOD USE* AND DOMESTIC OUTDOORS. 

FOR THE CONTROL OF MOSQUITOES, GNATS, BITING AND NON-BITING MIDGES, BLACKFLlES, 

DEERFLIES AND OTHER BITING FLIES. 

* EXCEPTION: This product may be used to formulate mosquito control products that are labeled for 

application over growing crops and range grasses that have established tolerances for permethrin. 

Do not use this product to formulate products intended tor Terrestrial Food Crops, Aquatic Uses, 

Greenhouse Uses, Forestry or Indoor Uses. 

CONDITIONS OF SALE AND LIMITATION OF WARRANTY AND LIABILITY 

NOTICE: Read the entire Directions for Use and Conditions of Sale and Limitation of Warranty and 

Liability before buying and using this product. If the terms are not acceptable, return the product at once, 

unopened, and the purchase price will be refunded. 

The Directions for Use of this product should be followed carefully. It is impossible to eliminate all risks 

inherently associated with the use of this product. Crop injury, ineffectiveness or other unintended 

consequences may result because of such factors as manner of use or application, weather or crop 

conditions, presence of other materials or other influencing factors in the use of the product, which are 

beyond the control of LG Life Sciences, Ltd. or Seller. All such risks shall be assumed by Buyer and 

User, and Buyer and User agree to hold LG Life Sciences, Ltd. and Seller harmless for any claims 

relating to such factors. 

LG Life Sciences, Ltd. warrants that this product conforms to the chemical description on the label and is 

reasonably fit for the purposes stated in the Directions for Use, subject to the inherent risks referred to 

above, when used in accordance with directions under normal use conditions. This warranty does not 

extend to the use of this product contrary to label instructions, or under abnormal conditions or under 

conditions not reasonably foreseeable to or beyond the control of Seller or LG Life Sciences, Ltd. and 

Buyer and User assume the risk of any such use. To the extent permitted by law, LG Life Sciences, Ltd. 

MAKES NO WARRANTIES OF MERCHANTABILITY OR OF FITNESS FOR A PARTICULAR PURPOSE 

NOR ANY OTHER EXPRESS OR IMPLIED WARRANTY EXCEPT AS STATED ABOVE. 

In no event shall LG Life Sciences, Ltd. or Seller be liable for any incidental, consequential or special 

damages resulting from the use or handling of this product. TO THE EXTENT PERMITTED BY LAW, 

THE EXCLUSIVE REMEDY OF THE USER OR BUYER, AND THE EXCLUSIVE LIABILITY OF LG Life 

Sciences, Ltd. AND SELLER FOR ANY AND ALL CLAIMS, LOSSES, INJURIES OR DAMAGES 

(INCLUDING CLAIMS BASED ON BREACH OF WARRANTY, CONTRACT, NEGLIGENCE, TORT, 

STRICT LIABILITY OR OTHERWISE) RESULTING FROM THE USE OR HANDLING OF THIS 

PRODUCT, SHALL BE THE RETURN OF THE PURCHASE PRICE OF THE PRODUCT OR, AT THE 

ELECTION OF LG Life Sciences, Ltd. OR SELLER, THE REPLACEMENT OF THE PRODUCT. 

LG Life Sciences, Ltd. and Seller offer this product, and Buyer and User accept it, subject to the foregoing 

conditions of sale and limitations of warranty of liability, which may not be modified except by written 

agreement signed by a duly authorized representative of LG Life Sciences, Ltd. 

3 

9
PI_6e,e.d, ' Dn ",vente befD", 'fDFm. Form OMB No, .... , .. , A .. amir_ 2-2B-95 

, United States § Registration OPPldantifierNu~r 

&EPA Environmental Protection Agency v Amendment 

Washington. DC 20460 Other 

Appl ..... : ... - for II ... .,.,~ l"- . .. '""~~'U" . ~ II 

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

71532-7 G. LaRocca DNone D Restricted 

4. Company/Product (Name) PM' 

LG Permethrin Technical PH 13 

5. Name and Address of Applicent /Include ZIP Code) 6. Expedited Reveiw. In accordance with FIFRA Section 3(c)(3) 

LG Ufe Sciences, Ltd. c/o BIOLOGIC, Inc. (b)(i). my product is similar or identical in composition and labeling 

115 Obtuse Hill Road to: 

EPA Reg. No. 8329-66 

Brookfield, CT 06804 D Check if this is 8 n8W address Product Name Clarke Permethrin Technical 

~ Amendment - EXplain below. 

S~tiOll U 

U Final printed labels in repsonse to 

Agency letter dated 

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

D Notification - Explain below. D Other - Explain below. 

Explanation: Use additional pagels) if necessary. (For section I and Saction II.) 

This amendment is to add language to allow the use of this product by formulators having end-use products labeled for application over certain agricultural 

crops and range grasses (e.g. those crops that have established permethrin tolerances). In addition, the label has been revised to make it consistent with 

similar permethrin technical products intended to formulate mosquito adulticides. The text added has been underlined and the deleted text has been lined 

through. This action will not fall within scope of PRIA. 

co. .:, 

,,",",,""VII III 

1 Material Thl. Product WiD Be .. __ , ._ ... _ In: 

Child-Resistant Packaging Unit Packaging Water Soluble Packaging 2. Type of Container 

BYes BYes B Yes 

No No 

[;r~ Plastic 

No Glass 

* Certification must If ·Yes· No. per If ·Yes· No. par Paper 

Unit Packaging wgt. container Package wgt container Other (Specify) be submitted 

I 

!3. Location of Net "v ........ Q Information 4. Size(s) Retail Container 15~ LOCjtiOn of Label Directions 

l J Label l J Container 

6. Mannar in Which Label is Affixed to Product l J Uthograph 0 Other 

Paper .Ptlued Stenclild 

Section IV 

1 Contact Point ,,.. , items directly below for of, .I:. I to btl •••••• ,,/ if. " to process this .J 

Name Title Telephone No. (Include Area Code) 

Jane M. Miller Agent for LG Life Sciences, Ltd. (203) 740-1200 

· ! ••• 

Certification 6. Oat4t 1jliOlition 

I certify that the statements I have made on this form and all attachments thereto are true, accurate and complete. Recei~ • • ••• I acknowledge that any knowlinglly false or misleading statement may be punishable by fine or imprisolVTlent or (SU1nDed) 

both under applicable law. 

• . 2. C::'n. ••• ,-,yo 3. Title ..... : . • •• 

'.'(\L~ I\J\). ~ 

. ~ 

Agent for LG Life Sciences, Ltd. • •••• • •• • • • • •• 

4. Typed'NanJ 5. Date •••• ••••• 

• • 

Jane M. Miller May 5,2005 • •••• 

• •••• 

•••• • 

EPA Form 8570-1 IRev. 3-941 Previous editions are obsolete. Whit •• EPA File Copy (origin'" yen .. ~AppIlCMt Copy 

•• • 

10
May 5,2005 

Mr. George T. LaRocca 

Product Manager, PM Team 13 

hlsecticide Branch 

Registration Division (7505C) 

Office of Pesticide Programs 

U.S. Environmental Protection Agency 

Ariel Rios Building 

1200 Pennsylvania Avenue, N.W. 

Washington, D.C. 20460 

SUBJECT: LG Permethrin Technical PH Insecticide; EPA Reg. No. 71532-7. 

Dear Mr. LaRocca: 

This is in further ref~rence to our most recent telephone conversation regarding the above 

subject. During that discussion, you advised us that it was not possible to make the proposed 

labeling changes by notification. 

With this letter, LG Life Sciences Ltd. hereby submits a label amendment for its "LG Permethrin 

Technical PH Insecticide"; EPA Reg. No. 71532-7 to allow use of the technical grade product by 

those formulators having end-use products labeled for application over certain agricultural crops 

and range grasses (e.g. those crops that have established pennethrin tolerances). In addition, we 

are suggesting removal of the current use restriction to accommodate this amendment, and to 

make this label consistent with other permethrin technical grade products intended to formulate 

mosquito adulticides (e.g. "Clarke Pennethrin TecImical Insecticide"; EPA Reg. No. 8329-66). 

Because a number of formulators have amended their end-use products to allow overspraying 

certain crops and range grasses, they have stopped using LG's product because ofthe current use 

restriction. For this reason, we are kindly requesting an expeditious review and approval of this 

label amendment so that LG can resume its nOlmal business activities. 

We are enclosing an application for a pesticide amendment, as well as three (3) copies ofthe 

draft labeling for your review and consideration. 

e to call me at (203) 740-1200 if! can be of any assistance. 

ence A. Miller 

ipal 

nt for LG Life Sciences, Ltd. 

115 Obtuse Hill· Brookfield, Connecticut 06804· USA 

Voice: 203.740.1200· Fax: 203.740.1220· Email: Imiller@biologicconsulting.com 

• ••• • • •••• 

• ••• • •• 

•• • 

• 

• •• •• • •••• 

• 

•••• 

• • •••• 

• ••• • •• •• • 

• ••••• 

• •• • • 

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• • -. • •••• 

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11
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 

WASHINGTON, D.C. 20460 

BIOLOGIC, INC. 

LG LIFE SCIENCES, LTD. 

115 OBTUSE HILL ROAD 

BROOKFIELD, CT 06804-

May 11,2005 

PRODUCT NAME: LG PERMETHRIN TECHNICAL PH 

COMPANY NAME: LG LIFE SCIENCES, LTD. 

EPA FILE SYMBOL: 71532-7 

EPA RECEIPT DATE: 05/09105 

SUBJECT: RECEIPT OF AMENDMENT 

DEAR REGISTRANT: 

OFFICE OF 

PREVENTION, PESTICIDES AND 

TOXIC SUBSTANCES 

The Office of Pesticide Programs has received your application for an amendment and it 

has passed an administrative screen for completeness. 

During the initial screen we determined that the application appears to qualify for fast 

track review. The package will now be forwarded to the Product Manager for review to 

determine its acceptability for fast track status. 

If you have any questions, please contact Registration Division, Risk Management Team 

13, at (703) 305-6100. 

Sincerely, 

I. j. lkP1J.uFront End Processing Staff 

Information Services Branch 

Information Resources and Services Division 

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