DEPAR'I'MENf OJF' AGRJICUJL'I'URE 

DllVllSllON OJF' AGRJlClJJL'I'URAL RESOURCES 

March 15,2016 

Tawanda Maignan, Team Leader 

Emergency Response Team (7505P) 

USEPA/OPP 

Document Processing Desk (EMEX) 

Room S4900, One Potomac Yard 

2777 S. Crystal Drive 

Arlington, VA 22202 

C.L. "BUTCH"' OTTER 

Governor 

CELIA R. GOULD 

Director 

Re: Emergency use of pyridate, formulated as the product Tough Herbicide (Not currently 

registered in the U.S.) for use on mint to control broadleafweeds, in particular Redroot Pigweed, 

Armaranthus retroflexus and Kochia, Kochia scoparia in Ada, Canyon, Elmore, Gem, Owyhee, 

Payette and Washington counties in Idaho. 

A. Summary of General Information 

1. Type of Exemption: 

Specific 

2. Contact Persons: 

Steve Salisbury (Teclmical) 

Mint Industry Research Council 

PO Box4059 

Salem, OR 97302-1059 

Phone: 503-551-3747 

Email: steve@pacificagresources.com 

Dr. Don Morishita (Scientific) 

University of Idaho 

Kimberly Research & Ext. Center 

3793 North 3600 East 

Kimberly, ID 83341-5076 

Phone:208-423-4691 

Email: don@uidaho.edu 

2270 Old Penitentiary Road • P.O. Box 790 • Boise, Idaho 83701 • (208) 332-8605 • Fax (208) 334-3547 • www.agri.idaho.gov 
Roger Batt (Economics) 

Idaho Mint Commission 

55 SW 5th Ave. #100 

Meridian, ID 83642 

Phone 208-888-0988 

Email: Roger@amgidaho.com 

Liesbeth Bosman (Registrant) 

Belchim Crop Protection, Inc. 

Techno1ogie1aan 7 

1840 Londerzeel 

Belgium 

Phone: +32 (0) 473 86 52 33 

Email: Liesbeth.Bosman@Belchim.com 

3. Description of Pesticide 

Active Ingredient: Pyridate 

Trade Name: Tough Herbicide SEC, not currently registered in U.S. 

Formulation: Emulsifiable concentrate formulated at 55.8% (5.0 lb. ai. per gal.) and 44.2% 

inert ingredients. 

Registrant/Manufacturer: Belchim Crop Protection is a Belgium-based company (EPA Co. 

No. 91746). The U.S. distributor is Engage Agro USA Corp. 

4. Description of Proposed Use 

a. Sites to be Treated 

There is just over 18,000 acres of mint grown in Idaho. It is estimated that approximately 

9,000 (50%) of this acreage will need to be treated with Tough. The mint production areas 

are located in southwest Idaho counties of Ada, Canyon, Elmore, Gem, Owyhee, Payette 

and Washington. There is also some production in the southcentral county of Twin Falls. 

The soils of these mint growing counties are generally productive, deep, and fertile in 

agricultural areas where a diversity of crops are also grown. 

b. Method of Application 

The herbicide will be applied by ground-driven spray equipment by licensed applicators 

according to the proposed Section 3 product label and Section 18 label. Tough may not be 

applied by aerial methods, or through any type of irrigation system and prohibitions on 

these types of applications are included on the Section 18 label. 

c. Rate of Application 

A maximum of .9375lb. active ingredient per acre (24 ounces of product per acre) in 20-40 

gallons of water per acre will be applied during the growing season. 
d. Maximum Number of Applications 

A maximum of two applications of Tough per growing season may be made, if necessary, 

with a minimum of 14 days between applications. Applications may be made between 

April 1 and December 31, 2016. No applications may be made within 49 days of harvest. 

e. Total Acreage to be Treated 

It is estimated that approximately 9,000 acres (50% of total Idaho acreage) will need to be 

treated with Tough. 

f. Total pesticide to be used 

An estimated 3,375 gallons (16,875lbs ofa.i.) of herbicide are expected to be applied. 

9,000acre * 24 fl.oz. * 2 applications= 3,375 gal. offormulated product. 

3,375 gal* 5lb a.i./ gal= 16,875lbs of active ingredient. 

g. Use season 

We are requesting application beginning April 1 through December 31, 2016. A fall 

application after harvest may be necessary if conditions promoting weed growth occur. No 

applications will be made within 49 days of harvest. 

h. Harvest Dates 

The majority of peppermint acreage is harvested once in August. However, some 

peppermint growers are double cutting their crop. Double-cut mint is harvested twice 

during the growing year, once in June and again in late August or early September. 

Spearmint is harvested twice during the growing season, once in the middle of June and 

again in the middle of August. 

i. Other Restrictions, User Precautions, and Requirements 

Federal and supplemental labels address reentry and worker protection, environmental 

hazards and restrictions (see attached label). Treated fields or forage from treated fields 

may not be used for livestock feed or grazing. Tough will not be applied through any type 

of irrigation system or by air. To protect endangered freshwater invertebrate species, 

Tough will not be applied within 100 yards of any freshwater spring. 

5. Alternative Methods of Control 

a. Registered Post-Emergent Herbicide Alternatives 

1. Bentazon (Basagran)- Provides inconsistent (partial) post-emergence control of 

Kochia. Does not control pigweed. Weeds emerging after application are not 

controlled. 

2. Bromoxynil (Maestro) - Phytotoxic to actively growing mint. Cannot be applied 

above 70 degrees F to actively growing mint. Only gives partial control ofKochia and 

Pigweed seedlings. Kochia and Pigweed seeds germinate (multiple flushes) 

throughout the growing season. 
3. Clethodim (Select Max)- Grass weed control only. 

4. Clopryalid (Stinger)- For spot treatment, post emergence control ofbroadleafweeds 

(canada thistle, dandelion). Destroys mint which comes in contact with the herbicide. 

Does not control Kochia or Pigweed 

5. MCPB (Thistrol)- Can only be applied early post-emergent to weeds and to dormant 

or small/newly emerged mint. It is limited to pmtial control of Canada thistle and field 

bindweed. Does cause crop injury and loss of oil yield. 

6. Quizalifop (Assure II)- Grass weed control only. 

7. Sethoxydim (Poast Plus) - Grass weed control only. 

8. Terbacil (Sinbar)- Does not control Kochia and Pigweed has developed resistant 

biotypes, due to years of continuous use. It is not effective on weeds that have grown 

beyond the seedling stage. Carmot be used when rotating from mint into other crops 

the following year, due to soil persistence m1d crop rotational restriction. Cannot be 

used on sandy, loamy sands, or soils with less than 1% organic matter without crop 

injury. 

b. Other alternatives 

Mechanical weed control methods such as tillage are not feasible or practiced in actively 

growing mint due to the destruction of the crop. Tillage in mint at any time also spreads the 

disease Verticillium Wilt, a fungal pathogen in mint which is spread by the movement of 

soil and debris. Tillage also spreads the rhizomes and stolons of perennial weeds. Hand 

rogueing is cost prohibitive and does not provide season long control of weeds as weed 

seeds continue to germinate in the soil throughout growing season. In addition, the labor 

needed for hand weeding is not available in most mint growing regions. Crop rotation is 

practiced when feasible, but mint is a perennial crop and is left in production for 3 to 5 years, 

or longer. Research on biological control methods is currently being conducted, but as of to 

date no effective methods have been developed. 

c. On-going research for chemical alternatives 

The mint industry has placed a high priority on finding altematives to pyridate for 

post-emergence broadleafweed control. The industry has diligently invested several 

hundred thousands of dollars of research funds over the past decade towm·d this effort. 

Numerous pre-emergent and post-emergent herbicides have been tested and evaluated with 

little or no success. Pre-emergence herbicides evaluated include pendamethalin, terbacil, 

saflufenacil, sulfentrazone, flumioxazin, oxyfluorfen, pyroxasulfone and both oxyfluorfen 

and flumioxazin impregnated on fertilizer. Post-emergence herbicides that have been tested 

include bentazon, terbacil, bromoxynil, bicyclopyrone, mesotrione, tembotrione, 

topramezone, fluroxypyr, MCPB, and carfentrazone. These herbicides are either too 

injurious to the mint or do not adequately control the pigweed. A letter from Dr. Rick 

Boydston, USDA-ARS, summarizes mint herbicide research since 2006. 
In summary, despite extensive effmis, the mint industry has not been able to successfully 

find an adequate replacement for pyridate (Tough herbicide) to provide post-emergence 

weed control, without causing significant injury to the mint crop. Therefore, weed control 

remains an urgent situation challenging the ability to produce high quality mint oil. 

In addition to the urgency of the situation, it is important to note that post-emergence 

broadleaf weed control has recently developed into a non-routine situation due to the 

increased demand for double-cut production acreage. Many acres have been forced to 

double-cut production to meet recent global regulatory and market demands. Fmiher 

description of this non-routine situation is discussed in Section B Pmi 2 (Description of the 

Emergency Condition) of this request. 

6. Efficacy ofthe Proposed Use 

Results of efficacy and comparative field trials are attached. However, trial data in Idaho is 

limited. Therefore, a letter of support fi·om Dr. Rick Boydston, USDA-ARS, in Prosser, W A is 

attached (Attach #6) to help explain the benefits and usability of Tough in mint production. Dr. 

Boydston has been instrumental in weed control research in mint production for nearly three 

decades. Additionally, Dr. Don Morishita, Superintendent and Extension Professor at the 

University of Idaho-Kimberly Research and Extension Center, is available for comment on weed 

control in mint production. 

Tough selectively controls annual weeds in mint without causing significant crop injury. 

Risks to rotational crops are minimized due to the short half-life and low soil persistence leading to 

no residual impact to subsequent crops. Tough is the only known broadleafherbicide that can 

provide post-emergent control of weeds without impacting crop yield. 

7. Residue Information 

Residue trials for mint were conducted by the IR-4 Program in 1994. Applications made in 

accordance with the requested provisions are not expected to result in residues of pyridate and its 

metabolites in excess of 0.2 ppm for peppermint and spearmint tops. These tolerances have been 

established by the EPA and are recorded under CFR 180.462 (see Attach #7). Secondm-y residues 

in meat, poultry, and eggs m·e not expected to result. 

8. Risk Information 

On May 3, 2000 the EPA established tolerances of0.2 ppm for residues ofpyridate and its 

metabolites in/on peppermint and spearmint tops (see Attach #8). Information regarding py:ridate 

toxicology and aggregate exposure can be found in the finaltule published in the Federal Register 

May 3, 2000, volume 65, number 86, pages 25647-25652. 

a. Human Health 

Tough herbicide poses little potential risks to humans, domestic animals, wildlife, and the 

environment. The acute oral LD50 for male rats is> 5,000 mg/kg. The active ingredient 

has a low dermal irritation potential and a low inhalation hazard. Acute dermal LD50 for 

rabbits is> 2,000 mg/kg. Inhalation LC50 >4.37 mg./Lair. Primary dermal irritation study 

indicated it is mildly irritating to rabbit skin (EPA Health Effects Division of the Office of 

Pesticide Programs, 2000). 
The EPA concluded that residues of pyridate in drinking water do not contribute 

significantly to the aggregate acute human health risk. The acute human health risks 

resulting from exposure to pyridate in food and water are below EPA's level of concern for 

all population subgroups. As for chronic risk, the EPA also concluded that no harm will 

result from aggregate chronic exposure. 

It was also determined that pyridate is not carcinogenic in either rat or mouse, and therefore 

is not expected to pose a cancer risk to humans. 

The product label addresses the risks to worker/applicator by outlining handler precautions 

and required personal protective equipment. 

b. Potential to be found in drinking water 

The potential for exposure to residues of pyridate in drinking water is negligible due to its 

low water solubility (l.Smg/L at 20 C), strong soil adsorption (Kd = .3-26) and shmt 

half-life (7-21 days). Pyridate is essentially immobile in all soil types and any risks to 

surface or groundwater contamination will be negligible. 

The EPA Health Effects Division determined that pyridate does not possess the 

enviromnental fate parameters associated with a compound that could leach to 

groundwater. However, the parameters of its de gradate indicate that under unusual 

conditions such as flooding, where anaerobic conditions persist in topsoil for up to 60 days, 

the degradate could possibly leach to groundwater or run off to surface water. Pyridate is 

not listed in the EPA Pesticides in Ground Water Database, nor is there an EPA Maximum 

Contaimnent Level or health advisory. 

c. Residential Uses 

Pyridate is not registered for use in ornamentals or in residential areas. 

d. Common Mode of Action 

Pyridate is a Group 6 herbicide, HRAC Group C3 (Herbicide Resistance Action 

Committee, www.hracglobal.com). It belongs to the phenyl-pyridazine family of 

herbicides. Its site of action is inhibition photosynthesis by blocking electron transpmt in 

photosystem II (reactions taking place in the chloroplast thylakoid membranes). 

e. Endangered or Threatened Species 

Endangered or threatened species listed by the USFWS within the mint production 

counties of Ada, Canyon, Elmore, Gem, Owyhee, Twin Falls, and Washington are listed in 

Attachment #9. 

The use of Tough herbicide in accordance to the label in mint fields should not pose a risk 

to any threatened or endangered species. 

f. Beneficial Organisms 

Tough is not toxic to bees and other beneficial insects (i.e. lady beetles, predatory mites). 

See the attached EPA Enviromnental Fate and Effects Division (EFED) report. 
g. Fish and Aguatic Organisms 

Pryridate is considered toxic to estuarine organisms. However, due to its strong soil 

adsorption and short half-life, if applied according to the label it should not pose a risk to 

estuarine organisms (see attached EPA EFED report). The label states that this material 

should not be applied within 100 yards of any freshwater spring, directly to water, to areas 

where surface water is present, or to intertidal areas below the mean high water mark. 

9. Coordinate with Other Agencies 

The Idaho Fish and Game Office of the U.S. Fish and Wildlife Service will receive a copy 

of this request. Any comments received will be forwarded to the U.S. EPA. 

10. Notification of Registrant 

Belchim Crop Protection has been notified and their letter of support is attached (see 

Attach #11). In addition, Engage Agro USA Corp. is the U.S. distributor and they have also been 

notified. A letter of support from Engage Agro USA is also attached (see Attach #12). 

11. Enforcement Program 

The Idaho State Department of Agriculture (ISDA) has adequate authorities for enforcing 

provisions of Section 18 emergency exemptions. ISDA will require the registrant (or 

manufacturer, if unregistered) of Tough herbicide, Belchim Crop Protection, to prepare and make 

available to end users supplemental labeling that complies with ISDA and EPA requirements for 

the emergency use, if approved. The Mint Industry Research Council (MIRC), in cooperation with 

Belchim Crop Protection and Engage Agro USA, will be required to provide the ISDA a report 

summarizing results of the emergency use after the end of the use period. 

12. Repeat Uses 

Tough has been previously used under a Section 18 from 1999-2000. Tough was later 

registered under a Special Local Need registration from 2001-2007 after tolerances were 

established in 2000. 

13. Progress Toward Registration 

Tough was originally registered as a pesticide for use on corn and peanuts in the U.S. in 1997. 

The original registrant was Sandoz Agro and the product was registered under the EPA Reg. No. 

5594 7-168. Syngenta eventually assumed ownership of the product and the new EPA Reg No. was 

100-880. Additional residue information was submitted by IR-4 for mint and tolerances were 

established for peppe11nint and spearmint tops at 0.20 ppm (CFR 180.462) in the Final Rule, 

published in the Federal Register vol. 65, No. 86, May 3, 2000 pages 2564 7-25652. Even though 

mint was not added to the federal label, several states issued Special Local Need registrations for 

use in mint. Product registration was voluntarily cancelled by the registrant (Syngenta) in 2004 and 

the product was no longer marketed in the U.S. Recently, Belchim Crop Protection acquired the 

marketing rights for pyridate fi·om Syngenta. Belchim is currently working with the USEP A to 

establish the necessary infonnation needed to re-register Tough in the U.S. 

B. Summary of Economic Loss 
1. Pest(s) to be Controlled 

The pests causing an emergency are broadleaf weeds, in particularly Redroot Pigweed, 

Armaranthus retrojlexus and Kochia, Kochia scoparia. 

2. Discussion ofthe Emergency Condition 

This request is due to the emergency condition existing in mint from the post-emergence of 

pigweed, kochia, and other broadleafweed communities that cmmot be effectively controlled in 

active growing mint crops. All crops suffer yield losses from populations of weeds, but unlike 

other crops, the quality of mint oil is also affected by weeds. Both the quality and marketability of 

the mint crop is dependent upon weed free fields. 

The recent increase in global demand for the production of double-cut mint oil has created 

a non-routine situation that poses additional stress on the need for adequate post-emergence 

broadleafweed control. Pre-emergence herbicides applied in February and early March to dormant 

mint dissipate to low levels that no longer control weeds after 4-6 weeks. The mint crop canopy 

suppresses any new weed emergence or establishment after this period. Once the mint canopy is 

removed with a mid to late June harvest (first cutting), new weed flushes follow. These new 

flushes include both summer mmual grasses and later germinating broadleaf weeds, such as 

pigweeds. The grass weeds are easily controlled with registered grass active herbicides. However, 

there are no effective post-emergence herbicides that m·e labeled in mint for pigweed control 

during the second half of the growing season following the first harvest of mint. 

The increased demand for double-cut mint is a result of both global regulatory challenges 

and the increasing desire for the oil quality that is produced in double-cut production. The global 

regulatory issues involve the concern of menthofuran and pulegone contents in the mint oil and the 

limits of these compounds that are allowable in oil to deem it acceptable in markets. The reduction 

of these compounds and the increase of other desirable oil quality traits can be achieved through 

double-cut production. The market has shifted to a higher demand for double-cut mint, but the 

acreage to meet the demand is not adequate due to management challenges associated with 

double-cut production. Post-emergence broadleafweed control is the primmy management 

challenge facing double-cut production. Producers do not have viable broadleaf weed control 

options to address this challenge. 

Redroot pigweed present in mint at 1.6 weeds/yd2 renders mint oil unmarketable, due to 

off-flavors imparted during the distillation process. OSU resemch also demonstrated that a redroot 

pigweed infestation of 10 plants/ft2 caused a peppermint oil yield reduction 34.4lbs/acre, a 46% 

reduction. Furthermore, both redroot and prostrate (A. blitoides) pigweeds have developed terbacil 

resistant biotypes. 

Kochia, a summer annual, cm1 reach heights of six feet high and several feet in diameter, 

hindering harvest operations and competes for nutrients and light. In addition, an infestation of2.3 

kochia plants/ft2 

can reduce mint oil yields by over 30% in addition to reducing oil quality. 

Mechanical tillage is not a post emergence weed control option in mint because tillage will 

destroy growing mint, eliminate irrigation rills in surface irrigated fields, and will spread 

devastating diseases in mint such as Verticillium wilt (Verticil! tum dahliae). Terbacil (Sinbar), the 

commonly used herbicide registered for weed control in mint, is weak on pigweed species and has 

become even less effective in controlling pigweeds due to the development of resistant biotypes. 

Additionally, terbacil cannot be used when weeds are beyond the seedling stage and when rotating 

from mint to other crops due to residual carryover. The only alternative method of controlling 

these weeds is hand-rogueing, but the unavailability oflabor and excessive cost where labor is 
available, eliminates rogueing as a viable weed control method. Again, there are presently no 

effective post -emergent means of controlling these weeds in mint. 

The mint industry has been diligently investing research funds to discover effective 

post-emergent broadleafweed herbicides that are safe to the crop. Pyridate has proven to be 

effective on broadleaf weeds as well as possesses acceptable post -emergence crop safety needed 

for mint production. Populations of problem weeds have reached economically devastating levels 

and is impacting the producer's ability to compete in the market. Additionally, the recent increased 

demand for double-cut mint has forced production into and created an non-routine situation for 

mint producers who have no effective and viable post-emergence broadleafweed control options. 

The use of Tough herbicide for post-emergence weed control in mint is critical to maintaining U.S. 

mint oil quality and market share in today's global economy. 

3. Additional Benefits Information 

4. Discussion of Economic Loss 

Redroot Pigweed/Kochia and broadleaf weed communities have become serious weed 

pests of mint growers in Idaho. The lack of any post emergent weed control options, (no effective 

registered herbicide, and the presence of herbicide-resistant pigweed) have created an emergency 

situation for Idaho mint growers. Furthe1more, the recently increased demand for double-cut mint 

has created an non-routine situation in weed control for mint producers. Economic thresholds for 

these problem weeds are very low. Weeds resistant to herbicides which mature and form seeds, 

soon establish large populations of the resistant biotype, if not controlled. 

Studies performed by OSU weed scientists show yield losses ranging from 22%to 47% 

from the target weeds individually. Kochia and Redroot Pigweed are often found in complexes of 

other weeds, which further reduces the yield and quality of mint oil. 

Five-Year History of Idaho Production 

Average Average Gross Cost of Net 

Year Yield Price Revenue Production Revenue 

(lbs I acre) ($I lbl ($I acre) ($I acre) ($I acre) 

2011 103 $21 $2,170 $2,038 $132 

2012 103 $21 $2,162 $2,038 $124 

2013 96 $21 $2,016 $2,038 ($22) 

2014 108 $21 $2,266 $2,038 $228 

2015 118 $21 $2,477 $2,038 $439 

Average 106 $21 $2,218 $2,038 $180 

I. Yield and price data were obtained from mint industry oil growers and buyers. 

2. Cost of production is based on 2013 University of Idaho Enterprise Budget. 

3. A Joss does not necessarily mean a negative cash flow, but rather that the grower will not earn a 

return on capital and management contributions (hourly wage, labor, etc) equal to what could be 

earned in an alternative investment of the land producing the mint crop. 
Tier 2 Analysis 

A Tier 2 Significant Economic Loss (SEL) analysis illustrates the reduction of oil yield and 

quality as well as the loss of gross revenue due to the devaluation of tainted oil resulting from weed 

contaminants. The yield comparison reflects a 35% yield reduction (OSU trial data) on the portion 

of the acres (50%) faced with the impact of post-emergent weed control challenges. 

Furthermore, the yield calculations are based on the five-year average (2011-15) of 106 

lbs/acre. As previously stated in this request, the estimated acreage ofldaho mint is 18,000 acres 

and approximately 9,000 acres (50%) would be treated with Tough herbicide. 

As for marketable oil quality, it is estimated that the use of Tough herbicide would increase 

pure quality oil by 20%, thus reducing the amount of tainted devalued oil by the san1e. The 

devaluation of tainted oil ranges from a small percentage deduction to complete rejection/loss. 

Based on industry knowledge, an average devaluation of 35% was used for this analysis. 

The Emergency situation results in 20% more tainted oil that has 35% less value realized 

by the growers. In all, this is a loss greater than $13Million to the mint producers in Idaho. 

Tier 2 Idaho Economic Analysis of Yield and Quality Loss 

Baseline Emergency Change %Change 

Yield (lbs/acre) 2,421,692 1,908,000 -513,692 -21% 

Pure (%of yield) 90% 70% 

(lbs/acre) 2,179,523 1,335,600 -843,923 -39% 

Tainted (%of yield) 10% 30% 

(lbs/acre) 242,169 572,400 330,231 136% 

Price, Pure ($/lb) $21.00 $21.00 

Price, Tainted ($/lb) $13.65 $13.65 

Gross Revenue ($/acre) $49,075,595 $35,860,860 -$13,214,735 -27% 

Summary 

Approximately 50% of the peppermint and spearmint grown in Idaho is harvested twice per 

year. Prior to the voluntary cancellation of Tough in 2004, this product was the only product 

available to mint growers to control broadleaf weeds after the first cutting and before the rows 

closed. The presence of these broadleaf weeds, such as kochia and redroot pigweed, steals light 

and nutrients, but can also impart flavors to the mint oil that make it unmarketable. Even 

though the industry has invested a significant amount of money in research to find a 

replacement herbicide, they have not been successful. 
The new owner of this active ingredient has recently begun the process of reregistering it in the 

U.S. and intends to include both peppermint and spearmint crops on the federal label. The industry 

has not been able to find an effective alternative to pyridate in mint and is requesting tl1e USEP A to 

consider allowing them to once again use pyridate for the control broadleaf weeds in both 

peppermint and spearmint. 

Please contact me if there are questions about this request. 

Sincerely yours, 

~/r-a~. 

~:e ~nson, Administrator 

Idaho State Dept of Agriculture 

208-332-8S31 (phone) 

208-334-3547 (fax) 

george.robinson@isda.idaho.gov 

Pc: Steve Salisbury, MIRC 

Roger Batt, Idaho Mint Commission 

Don Morishita, U of I 

Ronda Hirnyck, U ofl 

Liesbeth Bosman, Belchim Crop Protection 

Eric Maurer, Engage Agro USA 

Russ Holder, US Fish & Wildlife 

David Priebe, ODA 

Steve Foss, WDA 

Supporting Attachments 

1. Tough SEC Package Label. 

2. Tough SEC Section 18 Supplemental Label. 

3. Tough SEC MSDS. 

4. Tolerance of Peppermint to Pyridate. Oregon State University Efficacy Data. Hyslop Farm, 

Corvallis, OR. 1993. 

S. Efficacy and Crop Safety Data 1997, 1998,2002. Dr. Gary Lee, University ofldaho. 

Parma R&E Center. Parma, ID. 

6. Letter of Support. Dr. Rick Boydston, USDA-ARS. Prosser, W A. 

7. Federal Register. Vol. 6S, No. 86. Wednesday, May 3, 2000. pp. 2S647-256S2. 
8. EPA Health Effects Division Risk Assessment. Pyridate (i.e. Tough®) in/or on Brassica 

Head and Stem Subgroup, Collards and Mint. January 24, 2000. 

9. Endangered/Threatened Species Found in Idaho Mint Producing Counties. February 2016. 

http://ecos.fws.gov/tess public/ 

10. EPA Environmental Fate and Effects Division- Pyridate Report. December 12, 1989. 

11. Belchim Crop Protection N.V./S.A. Letter of Support. January 13, 2016. 

12. Engage Agro USA, LLC. Letter of Support. February 4, 2016. 

13. The Effect of Weeds on Mint Oil Yield and Quality. Heap, I. Department of Crop and Soil 

Science. Oregon State University. 

14. Herbicide Resistant Weeds in Mint. Heap, I. WeedSmart, Corvallis, OR. 

15. Pyridate Properties and Characteristics. Heap, I. pp. 89-91. 

16. Costs & Returns Estimates for Peppermint Establishment & Production Center Pivot, No 

Fumigation. Painter, K, et.al. University ofldaho. 2013 

17. Letter summarizing weed research efforts searching for altematives to pyridate. Dr. Rick 

Boydston. USDA-ARS. Prosser, WA. March 1, 2016.