REGISTRATION

9468-43 
-.--

ISB'S Front-end PRlA Completeness Screen 

Draft 3; 10/25107 

1'1';\ I ~c(;cipt Date: SEP 22 2010 EPA Reg. Number: 94 {, /{ - 11. GCheck List Item - '" , 

Yes No 

lias the PRIA Fce been Paid; is a copy of the check or ;( Pay.gov receipt included in the Submission Package? .. ----

Is 1111 Application Form (EPA FOITIl 8570-1) Included in the 

Suhmisslon PUL:kage, is it completely tilled out and signed I 

induding package type? 

-~--.---

Is u Confidential Statement of Formula (EPA Fonn 8570~ 

3 29) Included in the Submission Package, is it completely '/ filled nut and signed (boxes 1~21)? 

Is a Formulator's Exemption Statement (EPA Form 8570-

>< 27) Included in the Submission Package? .--._. 

Is u Ccrtificlitioll with Respect to Citation of Dato (EPA 

hmll g570-34) Included in the Submission Package? X ----.--~~ 

Is a Ulltn Matrix (EPA Fonn 8570-35) Included ill the >( Submission Package? 

-- 7 Is 

--,,-~-

a LlIhcl Included in the Submission Package? CD X 

Arc nata Included in the Submission Package? X ,,--". 

'I Is the Submission an Amcndment? ."""-

NIA 

1
NEW APPLICATIONS 

DATE: SEP 22 2010 

FILE NUMBER: _-1-9...:...:%:.......2_-...:...:&1_6 __ _ 

FEP (OPPIN ENTRY) LtI SEP 22.2010 

(Initial & date) . 

FILE ROOI\1: ------

(Initial & date) 

SIG: 

(Initial & date) 

FILE ROOM: _____ _ 

(Initial & date) 

I ASSIGN TO PM .. t (NO DATA) 

__ JACKET TO SHELF (DATA) 

2
Material to be added to an e-Jacket/Jacket 

R N qy lp sc- - y / ego O. Y 

Description: __________________ _ 

1. D Placement within the e-Jacket/jacket: 

/cvt)efault: (chronological, top = newest) 

D File Location: (PDF page number, i.e., "before page 

45") 

2. D Send to Data Extraction contractors this material: 

~ Newly stamped accepted label 

D Notification "7 {'\VJ0 on:oLu ~ E NewCSF ~ D Other: __________ ~_ 

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

must be well organized and clipped together, NOT STAPLED. 

Then give the material with this coversheet to staff in the 

Information Services Center (Room S-4900). 

Reviewer's Name: _--!.A...!:u!:!.t""u""'m.!.!!..!n'-'M=e""tz"'lg:J;e~r'___ ___ _ 

Phone: 305-5314 Division: IRB 

Date: ~ \ \ I \ \ 

Created March 17, 2009 

3
111>1.1

10057

"" U.s. ENVIRONMENTAL PROTECTION AGENCY EPA Reg. ""umber: DatI' of Issllanec: 

, -. fa \ omcc ofPcsticide Programs 

\~IU/, RegistratiOIl Division (7505C) 9468-43 

1200 Pellnsylvania Ave .. N.W. JAN 111011 "llPR~ Washington, D.C. 20460 

NOTICE OF PESTICIDE: Term OrlssuHllec: ...x Registration 

(undcr FIFRA, as amended) _ Reregistration Unconditional 

""amI' ofPcsticidc Product: 

Impale Insecticide 

Name alld Addrcss of Registrant (inel ude ZIP Code): 

Ritter Chemical, LLC 

c/o Michael Kellogg 

Pyxis Regulatory Consulting, Inc. 

4110 136'h St. NW 

Gig Harbor, WA 98332 

Note: Changes in labeling differing in substance from that accepted in connection with this registration must be submitted to and accepted by the 

Registration Division prior to llSC of the label in commcree. 111 any correspondencc on this product always refer to thc above EPA registration number. 

On the basis of information fllrnished by the registrant, thc above named pesticide is hereby registcrcd/rcrcgistered lInder the Federal Insecticide, Flingicide 

nnd Rodenticide Act. 

Registration is in no way to be construed as an endorsement or recommend.1tion of this prodnct by the Agcncy. tn order to protect health and the 

environment, the Administrator, on his motion, may at any timc suspcnd or cancel tile registration of a pesticide in a~cordancc with the Act. Thc acceptance 

of any name in connection with the rcgistration of a product undcr this Act is not 10 be construed as giving the registrant n right to exelllSive usc of the name 

or to its usc if it has been covered by others. 

This product is unconditionally registered in accordance with FIFRA section 3(c)(5) provided 

that you: 

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

Agency requires all registrants of similar products to submit such data. 

2. Make the following label changes before you release the product for shipment: 

• Revise the EPA Registration Number to read, "EPA Reg. No 9468-43." 

• On page 3, revise the heading "DIRECTIONS FOR USE" by making it more prominent so 

that it is clear that all of the sections following are under this section. 

• On page 6, under "APPLICATION INSTRUCTIONS," put the subheading "Restriction:" in 

front ofthe sentence that reads "DO NOT apply more than 0.5 lbs. active ingredient per acre, 

per year, regardless of formulation or method of application" for prominence. 

- s;g"'t;~';"f0f0- DatI': JAN 11 1011 

Venus Eagle, Product Manager 01 

Insecticide-Rodenticide Branch, Registration Division (7505P) 

4
Page 2 

EPA Reg. No. 9468·43 

• On page 10, in the last sentence of the crop box for "COTTON," revise the statement "Refer 

to BIDRIN 8 product label for specific use instructions; observe all use restrictions .. ," to 

read ""Refer to BIDRIN 8 product label for specific use instructions; follow all use 

restrictions ... " 

• On page 42, in the "FOLIAR" section of the box for "Ornamentals and Non-bearing Fruit 

and Nut trees, Shrubs, Evergreens, Flowers, Foliage Plants, Groundcovers, Interior 

Plantscapes, and Vegetable plants intended for resale only" add the restriction "DO NOT 

apply more than .8 pints (12.8 fl. oz.) (OAlbs AI) per acre per year for application to outdoor 

ornamentals. " 

• On page 43, in the "USE RATES" section of the box for "Ornamentals and Non-bearing 

Fruit and Nut trees, Shrubs, Evergreens, Flowers, and Groundcovers," revise the rates in the 

sentence "You may use the higher rate(O.2 fl. oz) only" to read "You may use the higher 

rate(0.20 fl. oz) only" for consistency purposes. 

• On page 43, in the "Restrictions" section of the box for "Ornamentals and Non-bearing Fruit 

and Nut trees, Shrubs, Evergreens, Flowers, and Groundcovers," revise the restriction to read 

"DO NOT apply more than 0.8 pints (12.8 fl. oz.) (O.4lbs AI) per acre per year." 

• On page 46, in the bottom of the crop box for "EBB & FLOOD APPLICATION," revise the 

5th note by revising the word "NOTE:" to read "RESTRICTION:" 

3. Storage stability (830.6317) and corrosion characteristics (830.6320) data must be submitted 

within 18 months from the date of this registration notice. 

4. Submit one copy ofthe revised final printed label for the record 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. If you have any questions, please contact Autumn Metzger at 703-305-53 14 or 

metzger .autumn@epa.gov. 

A stamped copy ofthe label is enclosed for your records. 

Enclosure 

Venus Eagle 

Product Manager 01 

Insecticide-Rodenticide Branch 

Registration Division (7505P) 

5
[MASTER LABEUCOVER PAGE] 

Note: This Master label contains 2 Sub-labels which bear directions for use in Commercial 

Agriculture; and in Nursery, Greenhouse and Landscape Ornamentals. 

IMPALE 

INSECTICIDE 

SUB-LABEL A: COMMERCIAL AGRICULTURE 

SUB-LABEL B: NURSERY, GREENHOUSE and LANDSCAPE ORNAMENTALS 

ACTIVE INGREDIENT: 

I midacloprid: 1-[(6-Chloro-3-pyridinyl)methyl]-N-nitro-2-imidazolidinimine....... 40.4% 

OTHER INGREDIENTS: ................................................................................. 59.6% 

TOTAL: ............................................................................................................ 100.0% 

EPA Reg. No. 94GB-xx 

Manufactured for: 

Ritter Chemical, LLC 

P.O. Box 430974 

Houston, TX 77243 

ACCEPTED 

With COMMENTS 

In EPA Letter Dated' 

JAN 111011 . Under the Federal Insecticide Fungicide 

and ~~denticj?e Act, As amended, for the 

pestiCide Registered under EPA Reg. No: 

9l.\ (" ~ LJ ?? 

1 

EPA Est. No. 

6
[MASTER LABEUCOVER PAGE] 

IMPALE 

INSECTICIDE 

A SYSTEMIC AND FOLIAR INSECTICIDE FOR USE ON FIELD CROPS including COTTON, TOBACCO, POTATO, 

SOYBEANS and PEANUTS; IN CITRUS, TREE NUT, and FRUIT ORCHARDS; 

ON FIELD and GREENHOUSE VEGETABLES; ON BERRY, BUSH and VINE CROPS; 

and ON OTHER LISTED CROPS 

ACTIVE INGREDIENT: 

Imidacloprid: 1 ~[(6-Chloro-3-pyridinyl)methyll-N-nitro-2-imidazolidinimine ......... , .. ...... 40.4% 

OTHER INGREDIENTS: ................................ ,................................................. ............. 59.6%, 

TOTAL: ........................................... , .............................................................................. 100.0% 

Contains 4 pounds of imidacloprid per gallon. 

eyes: 

KEEP OUT OF REACH OF CHILDREN 

CAUTION 

• person to i . 

• If person is not breathing, cal! 911 or an ambulance, then give artificial 

respi""iiion,, preferably by mouth-to-mouth, if 

• 

• Call a poison 

iIi 

control center or doctor immediately for treatment advice. 

• Have person sip a glass of water if able to swallow. 

• Do not induce vomiting unless told to do so by a poison control center or 

doctor. 

• i i 

• aft'" t',e first 5 minutes, then continue 

rinsing 

• Rinse skin immediately with plenty of water for 15-20 minutes. 

• I 

I or doctor, or 

going for treatment. For e~~~il~:C~ information concerning this product, call the National 

Pesticides Information Center 1-800-858-7378 seven days a week, 6:30 am to 4:30 pm 

EPA Reg. No. 9468-xx 

Manufactured for: 

Ritter Chemical, LLC 

P.O. Box 430974 

Houston, TX 77243 

EPA Est. No. 

Net Contents: Gals. 

2 

7
[SUB-LABEL A: COMMERCIAL AGRICUL TUREj 

PRECAUTIONARY STATEMENTS 

HAZARDS TO HUMANS AND DOMESTIC ANIMALS 

CAUTION 

Hannful if inhaled. Harmful if swallowed. Causes moderate eye irritation. Avoid breathing spray mist. Remove and wash 

contaminated clothing before reuse. Wash thoroughly with soap and water after handling and before eating, drinking, chewing 

gum or using tobacco. Avoid contact with eyes or clothing. Wear protective eye wear. Wear long sleeved shirt and long pants, 

socks, shoes, and chemical resistant gloves made of waterproof material such as banier laminate, butyl rubber, nitrile rubber, 

neoprene rubber, natural rubber, polyethylene, polyvinylchloride (PVC) or viton. 

PERSONAL PROTECTIVE EQUIPMENT (PPE) 

Applicators and other handlers must wear: 

• Long-sleeved shirt and long pants. 

• Chemical-resistant gloves made of any waterproof material such as, barrier laminate, butyl rubber, nitrile rubber, 

neoprene rubber, natural rubber, polyethylene, polyvinylchloride (PVC) or viton. 

• Shoes plus socks. 

Follow manufacturer's instructions for cleaning/maintaining personal protective equipment, PPE. If no such instructions for 

washables exist, use detergent and hot water. Keep and wash PPE separately from other laundry. 

Engineering Controls Statement: When handlers use closed systems, enclosed cabs, or aircraft in a manner that meets 

the requirements listed in the Worker Protection Standard (WPS) for agricultural pesticides [40 CFR 170.240(d)(4-6)], the 

handler PPE requirements may be reduced or modified as specified in the WPS. 

USER SAFETY RECOMMENDATIONS 

User must: 

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

• Remove clothing immediately if pesticide gets inside. Then wash thoroughly and put on clean clothing. 

• Remove PPE immediately after handling this product. Wash the outside of gloves before removing. As soon as 

possible, wash thoroughly and change into clean clothing. 

ENVIRONMENTAL HAZARDS 

DO NOT apply directly to water, to areas where surface water is present or to intertidal areas below the mean high water 

mark. DO NOT contaminate water when disposing of equipment washwaters. This product is highly toxic to bees exposed to 

direct treatment or residues on blooming crops or weeds. DO NOT apply this product or allow lt to drift to blooming crops or 

weeds if bees are visiting the treatment area. This product is toxic to wildlife and highly toxic to aquatic invertebrates. This 

chemical demonstrates the properties and characteristics associated with chemicals detected in ground water. The use of this 

chemical in areas where soils are penneable, particularly where the water table is shallow, may result in groundwater 

contamination. 

DIRECTIONS FOR USE 

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

DO NOT apply this product in a way that will contact workers or other persons, either directly or through drift. Only protected 

handlers may be in the area during application. For any requirements specific to your State or Tribe, consult the agency 

responsible for pesticide regulation. 

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[SUB-LABEL A: COMMERCIAL AGRICUL TUREj 

AGRICULTURAL USE REQUIREMENTS 

Use this product only in accordance with its labeling and with the Worker Protection Standard, 40 CFR part 170. This 

Standard contains requirements for the protection of agricultural workers on fanns, forests, nurseries, and greenhouses, 

and handlers of agricultural pesticides. It contains requirements for training, decontamination, notifICation, and emergency 

assistance. It also contains specific instructions and exceptions pertaining to the statements on this label about personal 

protective equipment (PPE) and restricted-entry interval. The requirements in this box only apply to uses of this product that 

are covered by the Worker Protection Standard. 

DO NOT enter or allow worker entry into treated areas during the restricted entry interval (REI) of 12 hours. 

Exception: !f the product is soil-injected or soil-incorporated, the Worker Protection Standard, under certain circumstances, 

allows workers to enter the treated area if there will be no contact with anything that has been treated. 

PPE required for early entry to treated areas that is permitted under the Worker Protection Standard and that involves 

contact with anything that has been treated, such as plants, soil. or water, is: 

• Coveralls 

• Chemical-resistant gloves made of any waterproof material such as, barrier laminate, butyl rubber, nitrile rubber, 

neoprene rubber, natural rubber, polyethylene, polyviny!chloride (PVC) or viton 

• Shoes plus socks 

PRODUCT INFORMATION 

Thorough uniform coverage is necessary to achieve insect control. A spray adjuvant may be used to improve coverage. This 

product may not knockdown established and heavy insect populations with a single application. Two applications may be 

required to achieve control; retreat if needed and as directed on this !abel. This product may be tank mixed with other 

insecticides as specified for knockdown of pests or for improved control of other pests. 

Applying this product to crops grown for production of true seed intended for private or commercial planting may be allowed 

under State specific supplemental labeling but is generally not permitted. As with any insecticide, care must be taken to 

minimize exposure of this product to honey bees and other pOllinators. Additional information on this product uses for listed 

crops and other questions may be obtained from the Cooperative Extension Service, PCA's, consultants or your !ocal Ritter 

Chemica!, LLC representative. 

Restrictions 

• Do not use this product on crops requiring bee pollination during broom and a minimum of 10 days prior to broom. 

RES!STANCE MANAGEMENT 

Some insects are known to develop resistance to insecticides after repeated use. As with any insecticide, the use of this 

product must conform to resistance management strategies established for your use area. 

This product contains a Group 4A insecticide called imidacloprid. Insect biotypes with acquired or inherent tolerance to group 

4A insecticides may eventually dominate the insect population if Group 4A insecticides are used repeatedly as the 

predominant method of control of targeted species. This may eventually result in partial or total ross of control of those 

species by this product and other Group 4A products. 

The active ingredient in this product is a member of neonicotinoid chemica! group. Avoid using a brock of more than three 

consecutive applications of this product and/or other Group 4A products having the same or similar mode of action. 

Following a neonicotinoid block of treatments, Ritter Chemical, LLC strongly encourages the rotation to a block of 

applications with effective products of a different mode of action before using additional applications of neonicotinoid 

products. Use of a block rotation or windowed approach, along with other IPM practices, is considered an effective use 

strategy for preventing or delaying an insect's pest's ability to develop resistance to this class of chemistry. 

Foliar applications of this prcduct or other Group 4A products from the neonicotinoid chemical class must not be used on 

crops previously treated with a long-residual, soil-applied product from the neonicotinoid chemical class. 

Other Group 4A, neonicotinoid products used as foliar treatments include: Actara, Assail, Calypso, Centric, Intruder, Impulse, 

Leverage, Pasada, Provado, Trimax Pro and Venom. Other 4A Group, neonicotinoid products used as soillseed treatment 

include: Admire Pro, Advise, Alias, Belay, Crutch, Couraze, Cruiser, Gaucho, Macho, Macho Max, Platinum, Venom and 

Widow. Contact your local extension specialist, certified crop advisor and/or product manufacturer for additional insect 

resistance management recommendations. Also, for more information on Insect Resistance Management (!RM), visit the 

Insecticide Resistance Action Committee (IRAC) on the web at http'/lirac-online.orql. 

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[SUB-LABEL A: COMMERCIAL AGRICUL TUREj 

PRODUCT USE PRECAUTIONS 

OBSERVE THE FOLLOWING PRECAUTIONS WHEN MIXING AND APPLYING IN THE VICINITY OF AQUATIC AREAS 

SUCH AS LAKES; RESERVOIRS; RIVERS; PERMANENT STREAMS, MARSHES OR NATURAL PONDS; ESTUARIES 

AND COMMERCIAL FISH FARM PONDS. 

SPRAY DRIFT MANAGEMENT 

The responsibility of avoiding spray drift is with the applicator. The applicator must consider weather related factors and the 

interaction of application equipment when making application decisions. 

Mixing and Loading Requirements 

The use of a properly designed and maintained containment pad for mixing and loading of any pesticide into application 

equipment is required. If containment pad is not used, maintain a minimum distance of 25 feet between mixing and loading 

areas and potential surface to groundwater conduits such as field sumps, uncased well head, sinkholes or field drains. 

Aerial Applications 

The spray boom should be mounted on the aircraft so as to minimize drift caused by wing tip vortices. The minimum practlcal 

boom length should be used, and must not exceed 75% of the wing span or rotor diameter. 

Importance of Droplet Size 

The droplet size is an important factor and can influence drift. Typically smaller droplet sizes, such as less than 150 to 200 

microns, have a greater tendency to drift compared to larger droplets. Applications typically should be made to deliver the 

largest droplet range that provides adequate control and coverage. Fonnation of very small droplets may be minimized by 

appropriate nozzle selection. 

Wind Speed Restrictions 

Drift potential increases at wind speeds of less than 3 mph (due to inversion potential) or more than 10 mph. However, many 

factors, including droplet size, canopy and equipment specifICations detennine drift potential at any given wind speed. DO 

NOT apply when winds are greater than 15 mph and avoid gusty and windless conditions. 

Restrictions During Temperature Inversions 

00 NOT make aerial or ground applications during temperature inversions. Drift potential is high during temperature 

inversions. Temperature inversions typically restrict vertical air mixing, which then could cause small suspended droplets to 

remain close to the ground and move laterally in a concentrated cloud. Temperature inversions typically are characterized by 

increasing temperature with altitude and are common on nights with limited cloud cover and light to no wind. They begin to 

fonn as the sun sets and often continue into the moming. Their presence can be indicated by ground fog; however if fog is 

not present, inversions can also be identified by the movement of smoke from a ground source. Smoke that layers and 

moves laterally in a concentrated cloud (under low wind conditions) indicates an inversion, while smoke that moves upward 

and rapidly dissipates indlcates good vertical mixing. 

Airblast (Air Assist) Specific Recommendations for Tree Crops and Vineyards 

Airblast sprayers carry droplets into the canopy of trees/vines via a radially, or laterally directed air stream. The following 

specifIC drift management practices must be followed. 

• Adjust deflectors and aiming devices so that spray is only directed into the canopy; 

• Block off upward pointed nozzles when there is no overhanging canopy; 

• Use only enough air volume to penetrate the canopy and provide good coverage; 

• DO NOT allow the spray to go beyond the edge of the cultivated area (i.e., turn off sprayer when turning at end rows); 

• Only spray inward, toward the orchard or vineyard, for applications to the outside rows. 

No-Spray ZOne Requirements for Foliar Applications 

DO NOT apply by ground within 25 feet, or by air within 150 feet of lakes, reservoirs, rivers, permanent streams, marshes or 

natural ponds, estuaries and commercial fish fann ponds. 

RUNOFF MANAGEMENT 

DO NOT cultivate within 10 feet of the aquatic areas to allow growth of a vegetative fitter strip. When used on erodible soils, 

best management practices for minimizing runoff must be employed. 

ENDANGERED SPECIES NOTICE 

Under the Endangered Species Act, it is a Federal Offense to use any pesticide in a manner that results in the death of a 

member of an endangered species. Consult your local county bulletin, County Extension Agent, or Pesticide State Lead 

Agency for information conceming endangered species in your area. 

ROTATIONAL CROPS 

Crops which are listed on imidacloprid labels or crops that have existing tolerances for imidacloprid may be planted in treated 

areas as soon as practical after the last imidacloprid application. Crops that are not found on an imidacloprid label, or crops 

5 

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[SUB-LABEL A: COMMERCIAL AGRICULTURE] 

that do not have existing tolerances for imidacloprid, must not be planted in treated areas for 12-months after the last 

application. Refer to the table below for plantback intervals for different crops. Note that if cover crops are planted any time 

after an application of this product, those crops must not be grazed or harvested for food or feed. 

ROTATIONAL CROPS - PLANT -BACK INTERVALS 

IMMEDIATE PLANT-BACK: 

All crops on this label plus the following crops not on this label: barley, canala, corn (field, pop & sweet). rapeseed, 

sorghum, sugar beet and wheat. 

30-DAY PLANT-BACK: 

Cereals (including buckwheat, millet, oats, rice, rye, and triticale), soybeans and safflower 

10-MONTH PLANT-BACK: 

Onions and bulb vegetables 

12-MONTH PLANT-BACK: 

All other crops 

APPLICATION INSTRUCTIONS 

This product can be applied as a foliar spray, or as a soil treatment (see Crop Specific Restrictions and Limitations). 

Thorough unifonn coverage is necessary to achieve insect control. Use adequate spray volumes, properly calibrated 

application equipment, and an adjuvant to improve coverage. Failure to provide adequate coverage and retention of this 

product on leaves and fruit may result in loss of insect control or delay in onset of activity. 

This product may not knockdown established and heavy insect populations with a single application. Two applications may 

be required to achieve control. Scout fields and retreat if needed. 

This product may be tank mixed with other insecticides for knockdown of pests or for improved control of other pests. 

Apply this product with properly calibrated ground or aerial application equipment. 

Minimum spray volumes unless otherwise specified on the Crop Specific Restrictions and Limitations section are 10 

gallons/Acre by ground applications and 5 gallons/Acre through aerial equipment. 

This product may also be applied by overhead chemigation (see CHEMIGATION APPUCATION section below) if allowed 

in crop specific application section. 

Apply specified rate per acre as a foliar spray as pest populations begin to build. DO NOT apply more than 0.5 Ibs. active 

ingredient per acre, per year, regardless of fcinnulation or method of application. 

Mix Preparation 

To prepare the application mixture: 

1. Fin the spray tank with a portion of the required amount of water and begin agitation. 

2. Add t!'le specified amount of Impale. 

3. Fill the tank with the remaining water needed. Maintain sufficient agitation during mixing and application. 

NOTE: This product may also be used with other pesticides and/or fertilizer solutions; refer to the Tank Mix and Compatibility 

Note below. When tank mixtures of this product and other pesticides are involved, prepare the tank mixture as specified 

above and follow the suggested Mixing Order below. 

Tank Mixes 

Unless otherwise prohibited on this label or the label of an intended tank mix product, this product may be applied in 

combination with any pesticide registered for the same crop, timing, and method of application. Observe the most restrictNe 

label statements of various tank mix products used. IMPORT ANT: PESTICIDE TANK MIXES MAY INCREASE THE RISK 

OF MIXING INCOMPATIBILITIES, REDUCED EFFECTIVENESS ANDIOR CAUSE CROP INJURY OR LOSS. ANY 

UABIUTY FOR LOSS, INJURY OR DAMAGE RESULTING FROM A TANK MIXTURE NOT SPECIFIED ON THIS 

LABEL OR IN MANUFACTURER'S SUPPLEMENTAL LABELING DISTRIBUTED FOR THIS PRODUCT IS 

SPECIFICALLY DISCLAIMED BY MANUFACTURER. 

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[SUB-LABEL A: COMMERCIAL AGRICULTURE] 

Compatibility 

Before full-scale mixing of this product with other pesticides, fertilizers, secondary plant nutrients, adjuvants, surfactants or 

oils, you must detennine the compatibility of the proposed mixture. Use proportionate quantities of each ingredient and mix in 

a small container. Always mix one product thoroughly with the dlluent before adding another product. If no incompatibility is 

evident after 30 minutes, the mixture is generally compatible for spraying. To evaluate potential short tenn effects of applying 

the mixture, test the tank mix combination on a few plants or a small area before larger-scale treatments. Wait at least 2 to 3 

days for problems to become apparent. 

Mixing Order 

When pesticide mixtures are needed, add wettable powders first, this product or other f10wables second, and emulsifiable 

concentrates last. Ensure good agitation as each component is added and do not add an add~ional component until the 

previous is thoroughly mixed. A fertilizer/pesticide compatibility agent may be needed if a fertilizer solution is to be added to 

the mixture. Be sure to maintain constant agitation during both mixing and application to ensure uniformity of spray mixture. 

Further information on Tank Mixes is available from your local Ritter Chemical, LLC representative. 

CHEMIGATION APPLICATION 

Types of Irrigation Systems 

Chemigation applications of this product may be made to crops through overhead sprinkler chemigation systems if spedfied 

in crop- specific sections. Restriction: DO NOT apply this product through any other type of irrigation system. 

Water Volume 

Chemigation applications of this product must be made as concentrated as possible. Retention of this product on target site 

of insect infestation is necessary for optimum activity. During chemigaJion of this product, do not exceed 0.10 inches/Acre of 

water volume. 

Uniform Water Distribution and System Calibration 

The irrigation system must provide uniform distribution of treated water. Crop injury, lack of effectiveness, or illegal pesticide 

residues in the crop can result from non-uniform distribution of treated water. The system must be calibrated to uniformly 

apply the rates specified. If you have questions about calibration, contact State Extension Service specialists, equipment 

manufacturers or other experts. 

Chemigation Monitoring 

A person knowledgeable of the chemigation system and responsible for ~s operation, or under the supervision of the 

responsible person, shall shut the system down and make necessary adjustments should the need arise. 

Drift 

DO NOT apply when the wind speed favors drift beyond the area intended for trealment. 

Required System Safety Devices 

The system must contain a functional check valve, vacuum relief valve, and low-pressure drain appropriately located on the 

irrigation pipeline to prevent water source contamination from backflow. The pesticide injection pipeline must contain a 

functional automatic, quick-closing check valve to prevent the flow of fluid back toward the injection pump. The pesticide 

injection pipeline must also contain a functional, normally closed, solenoid-operated valve located on the intake side of the 

injection pump and connected to the system interlock to prevent fluid from being withdrawn from the supply tank when the 

irrigation system is either automatically or normally shut down. The system must contain functional interlocking controls to 

automatically shut off the pesticide injection pump when the water pump motor stops. The irrigation line or water pump must 

include a functional pressure switch which will stop the water pump motor when the water pressure decreases to the point 

where pesticide distribution is adversely affected. Systems must use a metering pump, such as a positive displacement 

injection pump (e.g., diaphragm pump) effectively designed and constructed of materials that are compatible with pesticides 

and capable of being fitted with a system interlock. 

Using Water from Public Water Systems 

Public water system means a system for the provision to the public of piped water for human consumption if such system 

has at least 15 service connections or regularly serves an average of at least 25 individuals daily at least 60 days out of the 

year. Chemigation systems connected to public water systems must contain a functional, reduced-pressure zone, back flow 

preventer (RPZ) or the functional equivalent in the water supply line upstream from the point of pesticide introduction. As an 

option to the RPZ, the water from the public water system must be discharged into a reservoir tank prior to pesticide 

introduction. There shall be a complete physical break (air gap) between the outlet end of the fill pipe and to top or overflow 

rim of the reservoir tank of at least twice the inside diameter of the fill pipe. The pesticide injection pipeline must contain a 

functional automatic quick-closing check valve to prevent the flow of fluid back toward the injection. The pesticide injection 

pipeline must contain a functional normally closed solenoid-operated valve located on the intake side of the injection pump 

7 

12
[SUB-LABEL A: COMMERCIAL AGRICULTURE] 

and connected to the system interlock to prevent fluid from being withdrawn from the supply tank when the irrigation system 

is either automatically or manually shut down. The system must contain functional interlocking controls to automatically shut 

off the pesticide injection pump when the water pump motor stops or in cases where there is no water pump, when the water 

pressure decreases to the point where pesticide distribution is adversely affected. Systems must use a metering pump such 

as a positive displacement injection pump (e.g. diaphragm pump) effectively designed and constructed of materials that are 

compatible with pesticides and capable of being fitted with a system interlock. 

8 

13
[SUB-LABEL A: COMMERCIAL AGRICUL TUREI 

CROP-SPECIFIC DIRECTIONS FOR USE 

FIELD CROPS 

COTTON 

SOIL APPLICATIONS 

Pests Fluid Quncesl1,OOO row-feet Fluid ounceslAcre 

For control of: 

Cotton aphid 8.5 - to.6 Plant bugs 0.65 (Depending on row-spacing) Thrips 

Whiteflies 

Application Methods 

Apply specified dosage by one of the following methods: 

t In-furrow or narrow band spray. When applying as an in-furrow spray, direct application on or below the seed at planting: OR 

2. Narrow band application below the eventual seed bed row in a bedding operation 7 or fewer days before planting; OR 

3. Chemiqation into root zone throuqh low-pressure drip or trickle iniqation equipment. 

Restrictions 

Maximum amount of product allowed per crop season: 10.6 fluid ounceslAcre (0.33 Ib AIIAcre) 

Maximum number of active ingredient applications per crop season: 6 

DO NOT apply more than 0.5 lb. of active ingredient per acre per season of any imidacloprid containing products, including seed 

treatment, soil and foliar uses. 

DO NOT graze treated fields after any application of this product. 

See Resistance Manaaement section of this label. 

FOLIAR APPLICATIONS 

Pests Fluid ounceslAcre 

For control of: 

Cotton aphid 

Cotton flea hopper 

Bandedwinged whitefly t.O - 2.0 Plant bugs (excludes Lygus hesperus) 

Green stink bug 

Southern green stink bug 

BoliwormIBudworm··i ovicidal effect) 

For suppression of: 

Lygus bugs (Lygus hesperus) 

Whiteflies~ (other than banded winaed whiteflv) 

2.0 

Application Methods 

A I throu h ro erl calibrated round, aerial, or chemi ation a lication e ui ment. 

Restrictions 

Pre·Harvest Interval (PHI): 14 days 

Minimum interval between applications: 7 days 

Maximum amount allowed per season: 10.0 fluid ounceslAcre (0.3 t lb. AliA) 

DO NOT apply more than 0.5 lb. of active ingredient per acre per year of any imidacloprid containing products, including seed 

treatment, soil and foliar uses. 

DO NOT graze treated fields after any application of this product. 

TANK MIX APPLICATIONS 

Pests Impale Rate BIDRIN 8 Rate 

(in addition to those listed above) Fluid ounceslAcre Fluid ounceslAcre 

For early season control of: t.6 - 3.2 Thrips 

For mid to late season control of: 

Plant bugs 1.0-1.5 

Stink bugs (including Brown stink bug) 4.0- 8.0 Grasshoppers 

Saltmarsh caterpillar 

Cotton leafperforator 

Remarks 

This product can be tank mixed with other pesticides and/or fertilizer solutions. When tank-mixing this product with other pesticides, prepare 

the tank mixture as specified above in the Mix Preparation instructions section. Follow the following general mixing order: 

1. Add wettable powders first; 

2. Add this product or other flowables second; 

3. Add emulsifiable concentrates last. 

9 

14
[SUB-LABEL A: COMMERCIAL AGRICUL TUREj 

iii 

H 

POTATO 

SOIL APPLICA liONS 

Pests Fluid Qunces/1,OOO row-feet Fluid ounces/Acre 

For control of: 

Aphids 

Colorado potato beetle 

flea beetles 

Leafhoppers 

Potato psyllid 

For suppression of: 0.45 - 0.65 6.5 -10.0 

Wireworms (with in-furrow spray 

at planting) 

For suppression of disease symptoms of: 

Potato leaf roll virus (PlRV) 

Potato yellows 

Net necrosis (PlRV) 

Application Methods 

Apply specified dosage in one of the following methods: 

1. In-furrow spray during planting directed on seed pieces or seed potatoes; OR 

2. Subsurface side-dress on both sides of the row covered with 3 or more inches of soil; OR 

3. Narrow band spray at ground cracking direclly over the row during hilling covered with 3 or more inches of soil; OR 

4. Narrow band directly below the eventual seed row in a bedding operation 7 or fewer days before planting. For effective 

pest control or suppression, applications of this product must be placed below soil surface and in contact with seed piece 

or within root zone. For potatoes grown onl~~ghIY permeable soils with ~n~;IOW water table, at-plant applications of this 

oroduct mav be made in a 2 to 4 inch band width of olanter shoe open in and completely covered. 

Restrictions 

Maximum amount of product allowed per crop season: 10.0 fluid ounces/Acre (0,31 Ib Al/Acre 

FOLIAR APPLICATIONS 

Pests Fluid ounces/Acre 

For control of; 

Aphids 

Colorado Potato beetle 1.5 Flea beetles 

Fleahoppers 

Ps lIids 

Application Methods 

Apply as a broadcast or directed spray method through properly calibrated ground, aerial or chemigation application equipment. 

ThorouQh coveraQe of foliaQe is necessarv. 

Restrictions 

Pre-Harvest Interval (PHI): 7 days 

Minimum interval between applications: 7 days 

Maximum amount allowed per season: 6.4 fluid ounces/Acre (0.20 lb. AlIA) 

SEED PIECE APPLICATIONS 

Pests Fluid ounces/100 Ibs seed Fluid ounces/Acre 

For control of: 

Aphids 

Colorado potato beetle 

Flea beetles 0.2 - 0.4 4.0-8.0 

leafhoppers 

Potato psyllid 

Wireworms' (seed oiece orotectionl 

For suppression of disease 

symptoms of; 

Potato leaf roll virus (PLRV) 0.4 8.0 

Potato yellows 

Net necrosis'(PlRVl 

A lication Methods 

10 

15
[SUB-LABEL A: COMMERCIAL AGRICULTURE] 

Apply specified dosage as a diluted spray onto seed pieces using a shielded spray system. Dilute with 3 parts water, or less, to 

1 part this product. Agitate or stir spray solution as needed. Fungicidal or inert absorbent dusts may be applied after this 

product's application. Apply only in areas with adequate ventilation or in areas that are equipped to remove spray mist or dust. 

Plan! seed pieces as soon as possible after treating avoiding prolonged exposure of seed pieces treated with this product to 

sunlight and in accordance with the recommendation of your local Extension specialist. Consult your local Ritter Chemical, LLC 

reoresentative or cran nrotection nroduct dealer for information relevant to vour area. 

Remarks 

Based on a seedin rate of 2000 Ibs/Acre 

Restrictions 

Maximum amount of product allowed per crop season: 10.0 fluid ounces/Acre (0.31 Ib AIiAcre) 

DO NOT use treated seed pieces for food, feed, or fodder. 

DO NOT apply any subsequent applications of this product or any imidacloprid containing product (in-furrow) following a seed-piece 

treatment of this produc!. 

Aool~ ·O~I~ -in areas that are eauiooed to remove sorav mist or dust or with adeauate ventilation. 

SOYBEAN 

FOLIAR APPLICATIONS 

Pests Fluid ounces/Acre 

For control of; 

Aphids 

Bean leaf beetle 

Cucumber beetles / Rootworm adults 1.5 

Japanese beetle (adults) 

Leafhoppers 

Whiteflies 

Application Methods 

Apply as a broadcast or directed spray method through properly calibrated ground, aerial or chemigation application equipment. 

Thorounh coverane of foliane is necessarv. 

Restrictions 

Pre-Harvest Interval (PHI): 7 days 

Minimum interval between applications: 7 days 

Maximum amount allowed per crop season: 4.5 fluid ounces/Acre (0.14Ib. AliA) 

1 This use is noi·o~rmitted in CA unless othelWise directed bv state ·~pproved supolementallabelina. 

TOBACCO 

SOIL APPLICATIONS 

Pests Fluid ounces/1,000 plants 

. (as seedlinq tr~v drench) 

Fluid ounces/1 ,000 plants 

(in-furrow or tran~plant-wat;r) For control of: 

Aphids 0.5 0.7 

Flea beetles 

For control of: 

Mole crickets 0.7-1.4 0.9-1.4 Whiteflies 

Wireworms 

For suppression of di$~a;;'~c;~Ptoms of: 

Tomato snotted wilt virus S 1.4 1.4 

Application Methods 

Apply specified dosage of this product in one of the following methods: 

1. Uniform, broadcast foliar spray to seedlings in trays (tray drench) not more than 7 days prior to transplanting, followed 

immediately by overhead irrigation to wash this product from foliage into potting media. Failure to wash this product from 

foliage may result in a reduction in pest control. Transplants must be handled carefully during setting to avoid dislodging 

treated potting media from roots.; OR 

2. In-furrow spray or transplant-water drench during setting.; OR 

3. Chemication into root zone throunh low-nressure drio, trickle, micro-sorinkler or eauivalent eauioment. 

Remarks 

Important Note: Proper tray drench applications of this product have been shown to be the most efficacious method of 

application. However, the specified rate of this product may be applied as a combination of the tray drench in the planthouse 

and/or transplant-water drench in field. Adverse growing conditions may cause a delay in uptake of this product into the plant and 

a dela in control. 

Restrictions 

Pre-Harvest Interval (PHI): 14 days 

11 

16
[SUB-LABEL A: COMMERCIAL AGRICUL TUREj 

0.8 -1.6 

1.6 

method j or 

I 

Minimum j applications: 7 

" 

PEANUT 

SOIL APPLICATIONS 

Pests Fluid ounceslAcre 

For control of: 

Aphids 8.0-12.0 Leafhoppers 

lMliteflies 

For suppression of: 12.0 Thrips 

A lication Methods 

Apply as a: 

1. Chemigation into root-zone through properly calibrated low-pressure (drip, trickle, micro-sprinkler or equivalent) 

equipment; OR 

2. In-furrow sorav directed on or below seed. 

Remarks 

Applications of this product have been shown to increase the incidence of Tomato spotted wilt virus (TSWV), and possibly other 

tospoviruses, on mulUple varieties of peanut. Prior to making product applications, contact the State, Cooperative This use is not 

permitted in CA unless otherwise directed by state approved supplemental labeling. Extension Service, or Ritter Chemical, LLC 

representative, for recommendations to discuss the risk and benefits of imidacloprid applications. 

Restrictions 

Pre-Harvest Interval (PHI): 14 days 

Maximum amount allowed per crop season: 12.0 fluid ounces/Acre (0.38 lb. AlIA) 

1 This use is not permitted in CA unless otherwise directed by state approved supplemental labeling. 

FOLIAR APPLICATIONS 

Pests Fluid ounceslAcre 

For control of: 

Aphids 1.4 Leafhoppers 

Whiteflies 

A lication Methods 

Apply as a broadcast or directed spray method through properly calibrated ground, aerial or chemigation application equipment. 

Thorouqh coveraqe of foliaqe is necessary. 

Restrictions 

Pre-Harvest Interval (PHI): 14 days 

Minimum interval between applications: 5 days 

Maximum amount allowed per crop season: 4.2 fluid ounceslAcre (0.13 lb. AliA) 

1 This use is not permitted in GA unless otherwise directed by state approved supplemental labeling. 

12 

17
[SUB-LABEL A: COMMERCIAL AGRICULTURE] 

VEGETABLE CROPS 

CUCURBIT VEGETABLES: Chayote (fruit), Chinese waxgourd (Chinese preserving melon), Citron melon, Cuban 

pumpkin, Cucumber, Gherkin, Gourd (edible, includes hyotan, cucuzza, hechima, Chinese okra), Momordica spp. (includes 

balsam apple, balsam pear, bitter melon, Chinese cucumber), Muskmelon (hybrids and/or cultivars of Cucumis melo including 

true cantaloupe, cantaloupe, casaba, Crenshaw melon, golden pershaw melon, honeydew melon, honey bails, mango melon, 

Persian melon, pineapple melon, Santa Claus melon, snake melon and Winter melon), Pumpkin, Squash (includes summer 

squash types such as: butternut squash, calabaza, crookneck squash, Hubbard squaSh, scallop squaSh, straightneck squash, 

vegetable marrow and zucchini, and winr~)~ squash types such as acorn squash and spaghetti squash}, Watermelon (includes 

hVbrids and/or varieties of Citrul/us /anatus . 

SOIL APPLICATIONS (FIELD) 

Pests Fluid ounces/Acre 

For control of: 

Aphids 

Cucumber beetles 8.0-12.0 Leafhoppers 

Thrips (foliage-teeding thrips only) 

Whiteflies 

For suppression of disease symptoms of: 

Bacterial wilt (as vectored by various cucumber beetles) 12.0 

Leaf silvering resulting from whitefly feeding 

A lication Methods 

Apply specified dosage of this product in one of the following methods: 

1. Chemigation into root zone through low-pressure drip, trickle, micro-sprinkler or equivalent equipment; 

2. In-furrow spray directed on or below seed; 

3. Narrow (2 or less) surface band spray over seed-line during planting incorporated to a depth of 1 to t.5 with sufficient 

irrigation within 24 hours of application; 

4. Narrow band spray directly below eventual seed row in bedding operation 14 or fewer days before planting; 

5. Post-seeding drench, transplant-water drench, or hill drench: 

6. Subsurface side-dress on both sides of each row. This oroduct must be incorcorated into root-zone. 

Restrictions 

Pre-Harvest Interval (PHI): 21 days 

Maximum amount of product allowed per application: 12.0 fluid ounces/Acre (0.38 Ib AI/Acre) 

DO NOT use on crops grown for seed unless allowed by state-specific supplemental labeling 

GREENHOUSE APPLICATIONS1 

Pests Fluid ounces/1000 plants 

For control of: 

Aphids 0.05 

Whiteflies 

A lication Methods 

Apply specified dosage to seedlings in trays in the planthouse, targeting soil media (tray drench), not more than 7 days prior to 

transplanting, in one of the following manners: 

1. Uniform, broadcast high-volume foliar spray, followed immediately by sufficient overhead irrigation to wash this product 

from foliage into potting media without loss of gravitational liquid from the bottom of the tray. Failure to wash this product 

from foliage may result in reduced pest control; OR 

2. Injection into overhead irrigation system, using adequate volume to thoroughly saturate soil media without loss of 

qravitational solution from the bottom of the tray. 

Remarks 

The application made in the planthouse is not intended as a substitution for a field application. An additional field application must 

be made within 2 weeks following transplanting to provide continuous protection. Applications of higher rates or increased number 

of applications in planthouse may result in significant plant iniury. Transplants must be handled carefully during setting to avoid 

dislodging treated potting media from roots. 

Important Note: Not all varieties of cucurbit vegetables have been tested for tolerance to this product applied to seedling flats. 

Therefore, treat a small number of plants and confirm tolerance for 7 days prior to treatin!=! entire planthouse. 

Restrictions 

Maximum number of greenhouse applications: 1 

Maximum amount of product allowed per greenhouse application: 0.05 fluid ounce (0.001568 Ib AI)/1,OOO plants. 

DO NOT use on crops grown for seed unless allowed by state-specific supplemental labeling. 

1 This use is not permitted in CA unless othelWise directed by state approved supplementallabelinq. 

13 

18
[SUB-LABEL A: COMMERCIAL AGRICUL TUREj 

AphidS 

Colorado potato beetles 

Flea beetles 

Leafhoppers 

only) 

i 

I 

symptoms 

Eggplant, Ground cherry, Okra, Pepper (including bell, chili, cooking, pimento and 

i 

Okra & Pepper 

8.0 -16.0 

Other Listed Crops 

8.0 -12.0 

Chemigalion into low-pressure trickle, micro-sprinkler or equivalent equipment; 

2. In-furrow spray directed on or seed; 

3. Narrow (2 or less) surface band spray over seed-line during planting incorporated to a depth of 1 to 1.5 with sufficient 

irrigation within 24 hours of application; 

4. Narrow band spray directly below eventual seed row in bedding operation 14 or fewer days before planting; 

5. drench, , or hill drench; 

Maximum amount of product allowed on Okra and Pepper per application: 16.0 fluid ouncesfAcre (0.5 Ib AlfAcre). 

Maximum amount of product allowed on other listed fruiting vegetable crops per application: 12.0 fluid ouncesfAcre (0.38Ib 

I 

" Ii 

Aphids 

Colorado potato beetle 1.5-2.5 

Leaf I 

2.5 

Ii i or 

I i a II program, i 

and different modes of actions are utilized in a blocked or windowed approach. additional 

Ritter Chemical, LLC representative, Extension Specialist or crop advisor. 

adult whiteflies . 

. I dosage of this product by ground equipment Time Ii to a damaging pest 

Ii I I. 

inteNal between applications: 5 days 

amount of product allowed 7.7 fluid ounce (0.24 Ib AI)fA 

I I Ii 

GREENHOUSE 

0.05 

Ii more 

" i i 

14 

19
[SUB-LABEL A: COMMERCIAL AGRICULTURE] 

from foliage into potting media without loss of gravitalionalliquid from the bottom of the tray. Failure to wash this product 

from foliage may result in reduced pest control; OR 

2. Infection into overhead irrigation system, using adequate volume to thoroughly saturate soil media without loss of 

aravitational solution from the bottom of the trav.-

Remarks 

The application made in the planthouse is not intended as a substitution for a field application. An additional field application must 

be made within 2 weeks following transplanting to provide continuous protection. Applications of higher rates or increased number 

of applications in planthouse may result in significant plant iniury. Transplants must be handled carefully during setting to avoid 

dislodging treated potting media from roots. 

Important Note: Not all varieties of cucurbit vegetables have been tested for tolerance to this product applied to seedling flats. 

Therefore, treat a small number of olants and confirm tolerance for 7 davs orior to treatina entire olanthouse. 

Restrictions 

Maximum number of greenhouse applications allowed: 1 

Maximum amount of product allowed per greenhouse application: 0.05 fluid ounce (0.001568 Ib AI)/1,000 ptants. 

DO NOT use on crops grown for seed unless allowed by state¥specific supplemental labeling. 

1 This use is not permitted in CA unless otherwise directed by state approved supplemental labeling. 

GREENHOUSE VEGETABLES: Mature Cucumber and Tomato plants in production greenhouses ONLY. 

Pests Fluid ounces/1000 plants 

For control of: 

Aphids 0.7 

Whiteflies 

A lication Methods 

Apply specified dosage in a minimum of 16 gallons of water for tomatoes and 21 gallons of water for cucumbers using soil 

drenches, micro-irrigation, drip irrigation, or hand-held or motorized calibrated irrigation equipment. DO NOT apply to immature 

plants since phytotoxicity may occur. 

Remarks 

Make apptication when infestation pressure surpasses threshold and beneficials are not able to maintain pest populations 

below damage thresholds. Repellency of bumble bee pollinators and negative effects on some beneficials (Onius 

sp.) can occur when this product is applied. 

Many yarieties of yegetables haye been tested for tolerance to this product and show good safety. However, certain 

varieties may show more sensitivity to this product. Therefore, treat a few plants before treating the whole greenhouse. 

Restrictions 

Pre-Harvest Interval (PHI): 0 days 

Maximum number of applications per crop season: 1 

Maximum amount of product allowed per crop season: 0.7 ftuid ounce (0.022 lb. AI)/1,000 ptants. 

DO NOT use on crops qrown for seed unless allowed bv state-specific supplementallabelinq. 

GLOBE ARTICHOKE 

SOIL APPLICATION 

Pests Ftuid ounces/1000 plants 

For control of: 

Aphids 8.0 -16.0 

Leafhoppers 

A lication Methods 

Apply specified dosage of this product in one of the following methods: 

1. Chemigation into root zone through low-pressure drip, trickle, micro-sprinkler or equivalent equipment; OR 

2. In-furrow spray directed on or below seed. 

Restrictions 

Pre-Harvest Interval (PHI): 7 days 

Maximum amount of product altowed per crop season: 16.0 ftuid ounce/Acre (0.50 lb. AI/A) 

1 This use is not permitted in CA untess otherwise directed by state approved supplemental labeling. 

FOLIAR APPLICATION 

Pests Fluid ounces/1000 ptants 

For control of: 

Aphids 1.6 - 4.0 

Leafhoppers 

Application Methods 

Apply this product as a broadcast or directed spray method through properly calibrated ground, aerial or chemigation application 

equipment. Thorough coverage of foliage is necessary. 

15 

20
[SUB-LABEL A: COMMERCIAL AGRICULTURE] 

Restrictions 

Pre-Harvest Interval (PHI): 7 days 

Minimum Interval between applications: 14 days 

Maximum amount of product allowed per crop season: 16.0 fluid ounce/Acre (0.50 lb. AI/A) 

HERBS: Angelica, Balm (lemon balm). Basil (fresh and dried). Borage, Burnet, Camomile, Catnip, Chervil (dried). Chinese 

chive, Chive, Clary, Coriander (cilantro or Chinese parsley leaves), Costmary, Culantro (leaf), (leaf). Dillweed, Horehound, 

Lavender, , Lovage I i I Nasturtium, Parsley I, Rosemary. Rue, 

For control of: 

Aphids 

Flea beetles 

Leafhoppers 8.0 -12.0 

Whiteflies 

one II 

spray during planting on or below seed; OR 

2, spray or transplant-water drench during setting or transplanting; OR 

3. or below eventual seed-line; OR 

all')WE,d per season: 

i i an spray at a rate not to 

may improve coverage and control. 

Not all crops and/or varieties listed above have been tested for 

I 

Minimum interval : 5 days 

Maximum 

16 

II 

1.4 

10< 

ose 

effects. Without specific knowledge about a particular 

II 

21
[SUB-LABEL A: COMMERCIAL AGRICUL TUREj 

HEAD and STEM BRASSICA VEGETABLES': Broccoli, Broccoli raab (rapim), Brussels sprouts, 

Cabbage, Cauliflower, Cavalo broccoli, Chinese (gaiJon) broccoli, Chinese (bok chay) cabbage, Chinese (napa) cabbage, Chinese 

mustard (gai chay) cabbage, Collards, Kale, Kohlrabi, Mizuna, Mustard greens, Mustard spinach, Rape greens, plus Turnip tops 

(leaves). 

LEAFY VEGETABLES : Amaranth (leafy amaranth, Chinese spinach, tampaia), Arugula (Raquette), Chervil, 

Chrysanthemum (edible leaved and garland), Corn salad, Cress (garden), Cress (upland, yellow rocket, winter cress), Dandelion, 

Dock (S~(rrel), Endive (escarole), Lettuce (head and leaf), Drach, Parsley, Purslane (garden and winter), Raddicchio (red chicory), 

SpinaCh including New Zealand and vine (Malabar spinach, Indian spinach)), Watercress2 (including upland). 

SOIL APPLICATIONS (FIELD) 

Pests Fluid ounces/Acre on 36 inch rows 

For control of: 

Aphids 

Leafhoppers 5_0 - t2,0 

Thrips (foliage-feeding only) 

Whiteflies 

A lication Methods 

Apply specified dosage of this product in one of the following methods: 

,. Chemigation into root-zone through low-pressure drip, trickle, micro-sprinkler or equivalent eqUipment; OR 

2. In-furrow spray directed on or below seed; OR 

3. Narrow (2" or less) surface band spray over seed-line during planting incorporated to a depth of 1 to 1.5" with sufficient 

irrigation within 24 hours of application; OR 

4. Narrow band spray directly below eventual seed row in bedding operation t4 or fewer days before planting; OR 

5. Post-seeding drench, transplant-water drench, or hill drench; OR 

6. Subsurface side-dress on both sides of each row. This product must be incorporated into root-zone. 

Restrictions 

Pre-Harvest Interval (PHI): 2t days 

Maximum amount of product allowed per season: t2.0 fluid ounces/Acre (0.38 Ib AI/Acre) 

1 DO NOT use on crops grown for seed unless permitted by state-specific supplemental labeling. 

2 For applications made to watercress, production fields must be drained of water at least 24 hours prior to application and water 

must not be reapplied to the field for a minimum of24 hours following application. Applications must be made to fully leafed-up 

canopies only. DO NOT apply to native cress growing in streams or other bodies of water. 

FOLIAR APPLICATIONS FIELD) 

Pests Fluid ounces/Acre 

For control of: 

Aphids 

Flea beetles 1.5 

Leafhoppers 

Whiteflies 

Application Methods 

Apply this product as a broadcast or directed spray method through properly calibrated ground, aerial or chemigation application 

eouioment. Thorouah coveraae of foliaae is necessarv, 

Restrictions 

Pre-Harvest Interval (PHI): 7 days 

Minimum interval between applications: 5 days 

Maximum amount of product allowed per season: 7.7 fluid ounces/Acre (0.24 Ib, AI/A) 

1 DO NOT use on crops grown for seed unless permitted by state-specific supplemental labeling. 

2 For applications made to watercress, production fields must be drained of water at least 24 hours prior to application and water 

must not be reapplied to the field for a minimum of 24 hours following application. Applications must be made to fully leafed-up 

canopies onlv. DO NOT appl to native cress arowina in streams or other bodies of water. 

LEAFY PETIOLE VEG ET ABLES: Cardoon, Celery, Celtuce, Chinese celery (freSh leaves and stalk only), 

Florence fennel (inciudinQ sweet anise, sweet fennel, finocchio), Rhubarb, Swiss chard 

SOIL APPLICATIONS FIELD 

Pests Fluid ounces/Acre (on 36 inch rows 

For control of: 

Aphids 

Leafhoppers 5.0 -12.0 

Thrips (foliage-feeding only) 

Whiteflies 

Application Methods 

A I s ecified dosa e of this roduct in one of the followin methods: 

17 

22
[SUB-LABEL A: COMMERCIAL AGRICUL TUREj 

1. Chemigation into root-zone through low-pressure drip, trickle, micro-sprinkler or equivalent equipment; OR 

2. In-furrow spray directed on or below seed; OR 

3. Narrow (2" or less) surface band spray over seed-line during planting incorporated to a depth of 1 to 1 B' with sufficient 

irrigation within 24 hours of application; OR 

4. Narrow band spray directly below eventual seed row in bedding operation 14 or fewer days before planting; OR 

5. Post-seeding drench, transplant-water drench, or hill drench; OR 

6. Subsurface side-dress on both sides of each row, This product must be incorporated into root-zone. 

Restrictions 

Pre-Harvest Interval (PHI): 45 days 

Maximum amount of product allowed per season: 12.0 fluid ounces/Acre (0.38 Ib A!!Acre) 

DO NOT use on crop~-~r'own for seed unless permitted bv state-specific supplementallabelina. 

LEGUME VEGETABLES (except Soybean, dryl: 

Edible podded and Succulent shelled pea and Bean and Dried Shelled Pea and Bean including: 

Bean - Lupinus spp. (grain lupin, sweet lupin, white lupin, and white sweet lupin) 

Bean - Phaseo/us spp. (field bean, kidney bean, lima bean, navy bean, pinto bean, runner bean, snap bean, tepary bean, wax 

bean) Bean - Vigna spp. (adzuki bean, asparagus bean, blackeyed pea, caljang, Chinese longbean, cowpea, Crowder pea, moth 

bean, mung bean, rice bean, Southem pea, urd bean, yardlong bean) 

Pea - Pisum spp. (dwarf pea, edible-pod , English pea, field pea, garden pea, green pea, snow pea, sugar snap pea) 

Other Beans and Peas - Broad bean bean), Guar, Jackbean, Lablab bean (hyacinth bean), Lentil, 

Aphids 

Flea beetles 

Leafhoppers 

Whiteflies 

; 

Bean common mosaic virus 

Bean golden mosaic virus 

8.0 -12.0 

one 

i into root zone through low-pressure drip, trickle, micro-sprinkler or equivalent equipment; OR 

2. In-furrow spray at planting directed on or below seed; OR 

3. In a narrow (2" or less) surface band over seed-line during planting incorporated to a depth of 1 to 1.5" with sufficient 

irrigation within 24 hours following application; OR 

4. In a narrow band i I below the eventual seed row in a bedding operation 7 or fewer days before planting; OR 

per season: 12.0 fluid ounces/Acre «'O~.~3~8~lb~~'~~bL ____________ J 

I ~ II Ii 

Maximum amount of 

1.4 

Ii 

Minimum interval applications: 7 days 

Maximum amount of product allowed per season: 4.2 fluid ounce (0.13 Ib A!!A) 

for seed unless I I " 

18 

23
[SUB-LABEL A: COMMERCIAL AGRICUL TUREj 

Burdock (edible) t, Garrott, Celeriact , Chervil (turnip-rooted) t, Chicoryf, 

,~~~~~~~~~~~~~parsniPt, Radish

t

, Oriental radish (diakon) t, Rutabaga

t

, Salsify (black) t, Salsify 

J (except Potato): Arracacha, Arrowroot, Artichoke (Chinese 

and sweet)t Chayote Chufa, Dasheen (Iaro) t, 

; , 

I . 

AphidS 

Flea beetles 0.35 -0.85 5.0 -12.0 

Apply specified dosage of this product in one of the following methods: 

1. Chemigation into root zone through low-pressure drip, trickle, micro-sprinkler or equivalent equipment; OR 

2. In-furrow spray (rate specified per 1,000 row-feet) or, shanked-in 1 to 2 inches below seed depth during planting; OR 

3. In a narrow (2 inches or less) band directly (1 to 2 inches) below the eventual seed row in a bedding operation 14 or fewer 

before planting. 

I. i occur I crop 

development, or 

adequate residual 

is continuous. Rates of this less than 0.7 fluid ounce/1 ,000 row-feet will not provide 

Crops treated with this product grown on very high organic matter soils (muck) may also require 

additional 

f The 

control. 

Pre-Harvest Interval for Tuberous and Corm Vegetables: 3 days (leaves); 125 days (corms) 

Maximum amount of product allowed per crop season: 12.0 fluid ounces/Acre (0.38 Ib AI/Acre) 

Maximum applications per crop season: 1 

NOT use for seed unless permitted labeling. 

il Ii 

Aphids 

Flea beetles 

iii 

Minimum interval between applications: 5 days 

Maximum amount of product allowed per crop season: 

Radish: 1.4 fluid ounce (0.044Ib AliA) 

All other listed crops: 4.2 fluid ounces/Acre (0.13 lb. AlIA) 

Maximum applications per crop season: 

Radish: t 

All other listed crops: 3 

DO NOT use on for seed unless 

1 This " 

19 

1.4 

I oc " 

24
[SUB-LABEL A: COMMERCIAL AGRICULTURE] 

SUGARBEET: (California only) 

SOIL APPLICATIONS (FIELD 

Pests Fluid ounces/Acre 

For control of: 

Aphids 

Flea beetles 

Leafhoppers 

Whiteflies 3.0-6.0 

For suppression of disease symptoms of: 

Western yellows virus 

Beet curly top hybrigeminivirus (BCTV) 

A lication Methods 

Apply specified dosage of this product in the following method: 

Apply specified dosage in sufficient carrier volume to insure uniform application. Apply directly below each seed furrow either 

dUrin"g the bedding operation immediately prior to planting or at the time of planting. 

Remarks 

The low rate may be applied to aid establishment of stands in whitefly areas, or for early season control of the other pests listed. 

Restrictions 

Maximum amount of product allowed per crop season: 6.0 fluid ounces/Acre (0.19 Ib AI/Acre) 

DO NOT apply during bloom or within 10 days prior to bloom or when bees are actively foraging. 

DO NOT use on crops qrown for seed unless permitted by state-specific supplementallabelinq. 

IMPALE CONVERSION CHART FOR LINEAR APPLICATION ONLY -----

RATE RATE fluid oUnces/1,000 row-feet fluid 

ounces/Acre Based on average row spacing (in inches): 

10 15 20 25 30 35 40 45 

10 0.10 O. t5 0.19 0.24 0.29 0.34 0.38 0.43 

12 0.12 0.17 0.23 029 0.35 0.40 0.46 0,52 

14 0.14 0.20 0.27 0.34 0.40 0.47 0.54 0.61 

16 0.16 023 0,31 0.39 0.46 0.54 0.61 0.69 

18 . .-._ ... 9:.E _ ..__ Q,-~(L .. 0.35 0.43 0.52 0.61 0.69 0.78 - .. - --_. 

20 0,19 0.29 0.38 0.48 0.58 0.67 0.77 0.86 

22 0.21 0.32 0.42 0.53 0.63 0.74 0.84 0.95 

24 0.23 0.35 0.46 0.58 0.69 0.8t 0.92 1,04 

26 0.25 0.38 0.50 0.62 0.75 0.87 1.00 1.12 

28 0.27 0.40 0.54 0.67 0.81 0.94 1.07 1.21 

30 0.29 0.43 0.58 0.72 0.86 1.01 1.15 1.29 

32 0.31 0.46 0.61 0.76 0.92 1.07 1.23 1.38 

Important Note: Rate of this product applied alfects the length of control and, to a considerable extent, the 

degree of control or effect. Row-spacing X rate combinations in shaded blocks may not provide adequate residual pest 

control and are not recommended for long-term, residual control. Use higher labeled rates where infestations may 

occur later in crop development or where pest pressure is continuous. Ritter Chemical, LLC offers no warranty for 

use of this product at rates below 0.35 fluid ounce/1 ,000 row- feet (the Row~Spacing/Rate combinations that are 

shaded). 

20 

25
[SUB-LABEL A: COMMERCIAL AGRICULTURE] 

BERRY, BUSH and VINE CROPS 

12.0 -16.0 

Ii 

000 

i roo! zone through low-pressure drip, trickle, micro-sprinkler or equivalent equipment after plants are 

or on perennial crops in early spring prior to bud opening; OR 

2. plant material or plant hole treatment juS! prior to, or during transplanting; OR 

3. As a band the row in a minimum of 20 of waler per , followed by to 

I mulch 

L may occur later i crop development 

I 

Maximum amount II per crop season: 16.0 fluid ounces/Acre (0.50 Ib AI/Acre) 

DO NOT apply during bloom or within 10 prior to bloom or when bees are actively foraging. 

DO NOT make both a $oil and Ii on the same crop in the same season. 

I II I II Ii 

SOIL APPLICATIONS (post-harvest use on perennial va~ri@ejtietS~)~~~~=======~ 

beetie, aod 8.0 -12.0 White grub complex 

I i I 

dosage of this product in one of the following 

As a ground spray via boom or backpack sprayer in a minimum of 20 gallons of water per acre; 

As a row-band spray using an aqusted amount of product based on the treated row band area ii" p,"OOortiOo to the amount 

required per full acre. The bandwidth must be equivalent to the width of 

I 

iI 

iI 

Minimum interval applications: 5 days 

II II 

i' 

i' 

i 

Ii i' 

" 

Maximum amount of product allowed per crop season: 4.6 fluid ounces/Acre (O.14 lb. AI/A) 

1,5 

DO NOT apply during bloom or within 10 prior to bloom or when bees are actively foraging. 

il Ii Ii 

21 

i or Ii 

26
[SUB-LABEL A: COMMERCIAL AGRICUL TUREj 

DO NOT use on crops grown for seed unless allowed by state-specific supplemental labeling. 

BUSHBERRY: Blueberry, Currant, Elderberry, Gooseberry, Huckleberry, Junebeny, Ligonberry, Salal 

SOIL APPLICATIONS 

Pests Fluid ounces/Acre 

For control of: 

Japanese beetle 

(adults, feeding on foliage) 8.0 - 16.0 White grub complex 

(grubs of Asiatic garden beetle, European and Masked chafer, 

Japanese beetle and Oriental beetle) 

Application Methods 

Apply specified dosage of this product in one of the following methods: 

1. Chemigation into root zone through low-pressure drip, trickle, micro-sprinkler or equivalent equipment; OR 

2. 18-inch band on each side of the row followed with 0.25 inch of irriaation immediatelv after aoolication. 

Remarks 

For grub control, apply this product to control 1st or 2nd (early) instar larvae. Application may be made post-bloom up to 7 days 

prior to harvest, or post-harvest until October 1st. For control of Japanese beetle larvae, make applications from June 1 to July 

15. DO NOT apply during bloom. 

Application to grass covered rows, row middles, drive lanes, headlands, and other grassy areas in and around the berry field will 

control resident grub populations. Applications directed to the root zone will help protect berry plant roots from grub feedi ng. 

Apply this product to moist soil. If necessary, apply one hour of irrigation water immediately before application. To ensure maximum 

efficacy, 0.5 to 1 inch of irrigation water or rainfall must be applied or received within 24 hours of application of this product to 

facilitate movement into the soil and in10 the roO"! zone. 

Restrictions 

Pre-Harvest Interval (PHI): 7 days 

Maximum amount of product allowed per crop season: 16.0 fluid· ounces/Acre (0.50 Ib AI/Acre) 

DO NOT apply pre-bloom or during bloom or when bees are actively foraging. 

FOLIAR APPLICATIONS 

Pests Fluid ounces/Acre 

For control of: 

Aphids 1.2-1.6 

Leafhoppers/Sharpshooters 

For control of: 

Japanese beetles (adults) 2.4 - 3.2 

Thrios (foliaqe feedinq) 

For control of: 3.2 Blueberry maggot 

A lication Methods 

Apply this product as a broadcast or directed spray method through properly calibrated ground, aerial or chemigation application 

equipment. Thorough coverage of foliage is necessary. 

Restrictions 

Pre-Harvest Interval (PHI): 3 days 

Minimum interval between applications: 7 days 

Maximum amount of product allowed per season: 16.0 fluid ounces/Acre (0.5 lb. AI/A) 

Maximum number of product applications per crop season: 5 

Maximum application volume (water): Ground: 20.0 GPA; Air: 5.0 GPA 

DO NOT apply pre-bloom or during bloom or when bees are activel foraainQ. 

CANEBERRY: Blackberry (Rubus eubatus, including bingleberry, black satin berry, boysenberry, Cherokee blackberry, 

Chesterberry, Cheyenne blackberry, corybeny, darrowberry, dewberry, Dirksen thomless berry, Himalayaberry, hullberry, 

Lavacabeny, Loganbeny, lowberry, Lucretiaberry, mammoth blackberry, marionberry, nectarberry, olallieberry, Oregon evergreen 

berry, Phenome~ai~eny, rangeberry, ravenberry, rossberry, Shawnee blackber~~l.youngberry, and varieties and/or hybrids of 

these). Raspberry black and red, Rubus occfrJenta/is, Rubus strfgosus, Rubus frJaeus . 

SOIL APPLICATIONS 

Pests Fluid ounces/Acre 

For control of: 

Aphids 8.0 -16.0 Leafhoppers 

Whiteflies 

For control of: 12.0 16.0 

22 

27
[SUB-LABEL A: COMMERCIAL AGRICULTURE] 

16.0 

" drip, trickle, micro-sprinkler or equivalent equipment; OR 

Maximum 

DO NOT 

II I i 

,""w"dper season: 16.0 fluid ounces/Acre (O.Slb AI/Acre) 

I i I 

Ii 

applications: 7 days 

3.2 

product allowed per season: 9.6 fluid ounces/Acre (0.3 lb. AlIA) 

bloom or within 10 days prior to bloom or when bees are actively foraging. 

. in CA unless otherwise I I Ii 

CRANBERRY 

SOIL APPLICATIONS 

Pests Fluid ounces/Acre 

For control of: 

Rootgrubs (Scarab) 

Rootwonns' (Chrvsomelid) 

8.0 - 16.0 

Application Methods 

Apply this product to moist soil. Apply specified dosage of this product in one of the following methods: 

1. As a soil spray (ground application) directed to the root and crown area using a minimum of 20 gal afwater per acre; OR 

2. As a chemigation application with 600 to 1,000 gallons water. 

Immediately upon application, this product must be incorporated into root zone by 0.1 to 0.3 inch water/Acre, either with the 

chemigation application or through irrigation/rainfall if not applied through chemigation. Inadequate incorporation within 24 hours of 

application may result in reduced control. 

Rootgrubs and Rootworms 

Make application post-bloom immediatel after honevbees are removed. Application should tarQet earlv instar larvae. 

Remarks 

Best control may be achieved when application is made post-bloom immediately after bees are removed. Target early instar 

larvae. This product has not been tested for crop response in tank mixes with other registered fungicides or insecticides. If 

tank mixing is desired, premix a sample of this product and the desired fungicide or insecticide partner at labeled rates and apply 

to a small area. Evaluate crop response within 48 hours and for at least two weeks prior to utilizing the tank mix on larger 

acreage. If crop in'ury results from the premix test, do not appl' the tank mix to lan=ler acreaqe. 

Restrictions 

Pre-Harvest Interval (PHI): 30 days 

Maximum amount of product allowed per season: 16.0 fluid ounces/Acre (O.5Ib AI/Acre) 

DO NOT apply during bloom or within 10 days prior to bloom or when bees are actively foraging. 

GRAPES: American bunch grape, Muscadine grape, and Vinifera grape. 

SOIL APPLICATIONS 

Pests Fluid ounces/Acre 

For control of: 

European fruit lecanium 8.0 -16.0 Leafhoppers/Sharpshooters 

Meal buqs 

23 

28
[SUB-LABEL A: COMMERCIAL AGRICULTURE] 

Phylloxera spp. 

For suppression of: 

Grapeleaf skeletonizer 

Nematodes1 16.0 

For suppression of disease symptoms of: 

Pierce's disease 

A lication Methods 

Apply specified dosage of this product in one of the following methods: 

1. Chemigation into root zone through low-pressure drip, trickle, micro-sprinkler or equivalent equipment; OR 

2. Subsurface side-dress shanked into the root zone on both sides of the plants followed by irrigation; OR 

3. Hill drench in sufficient water to insure incornoration into the root zone followed bv irrioation. 

Remarks 

Make application between bud-break and the pea-berry stage. A total of 14 fluid ounces/acre is required under the following 

conditions: 

1. Where vigorous vine growth is expected 

2. In warmer growing areas 

3. Where mealybug and European fruit lecanium populations are expected to be heavy 

4. Where vine populations exceed 600 per acre, or; 

5. For suppression of nematodes 

1 Repeated and regular use of this product over multiple consecutive growing seasons controls existing Phylloxera infestations 

over time or prevents Phylloxera from becoming established. 

1For suppression of nematodes, apply 14 fluid ounces in a single application or two 7 -fluid ounce applications on a 30 to 4S-day 

intelVal. Only make treatments by 1) chemigation into root zone through above ground low pressure drip, tickle, micro sprinkler or 

equivalent equipment or 2) French plow technique, followed immediately by sufficient irrigation to move the product into the 

entire root zone of the plant. Repeated and regular use of this product over several consecutive growing seasons provides 

thea~eatest d~~ree of nematode s~~oression and vields the areatest olant response. 

Restrictions 

Pre-Harvest Interval (PHI): 30 days 

Maximum amount of product allowed oer season: 16.0 fluid ounces/Acre (O.Slb AI/Acre) 

FOLIAR APPLICA nONS 

Pests Fluid ounces/Acre 

For control of: 

Leafhoppers/Sharpshooters 1.2-1.6 

Mealvb·u·as 

For control of: 

Gr~oeleaf skeletonizer 1.6 

A lication Methods 

Apply speCific dosage of this product using properly calibrated ground application equipment only. 

directed ;~~a~ to infested areas ensuri~~thorouqh coveraoe. 

Apply as a broadcast or 

Pre-Harvest Interval (PHI): 0 days 

Minimum intelVal between applications: 14 days 

Maximum amount of product a!!owed·~~r crop season: 

i 

through I 

shanked into 

Restrictions 

3.2 fluid ounces/Acre (0.1 lb. AliA) 

9.6 

equivalent equipment; OR 

followed irrigation; OR 

M,;xi,n"," amount of " per crop season: 9.6 fluid ounces/Acre (0.3 Ib AI/Acre) 

i I I 

I . 

24 

29
[SUB-LABEL A: COMMERCIAL AGRICUL TUREj 

For control of: 

I 3.2 Aphids 

A lication Methods 

~~~il~/hiS prOdUC~~~ a brO~da~ast or directed spray method through properly calibrated ground. aerial or chemigation application 

e UI ment. Thorou h covera e of faliaoe is necessarY. 

Restrictions 

Pre-Harvest Interval (PHI): 28 days 

Minimum interval between applications: 21 days 

Maximum amount of nroduct allowed ner season: 9.6 fluId ouncesfAcre 10.3 lb. AIIAI 

I COFFEE: 

SOIL 

I of' 

Aphids 

Leafhoppers 8.0 - 16.0 

,;~;,:~. n of, 

',~ : j dO:~n~~ ~~~t:o~~'~'~~~~~;ow-pcessu,e drip 'dokle, mio":~~::'~~i~' equi,ai~;: OR 

i B;~;I-'~~il-rl~~-n~h'i~~ i t~~:~~~ez~ne on both S:de~ t~~the t 7nnf> followed Ii i 

I (PHI), 7~,ay. 

~n'':v;r "rbl~;;;; per crop season: 1S.0 fluid ounces/Acre (O.5lb AI/Acre) 

! P~i~OT a.~p~~~uring. I j"';~ . i i.

a 

1~n~:%sS prior t~ blo~m or j'b~' bees are actively foraging. 

I usels I I II I I I I I 

I 

lof' 

Aphids 

i 3.2 

F~~;,;~' n of' 

I i; pioduct as a ;r-directed spray method ".' calibrated ground, aerial or application i 

Minimum interval ~ i 7 days 

I ~~x~m~Tm amoun~,~f ~hl;;~' ~~I:;i'th;nP1e~ ~~~ ~~~~~::b11:~~flUid ou~~:!.~A;rr: (O.Slb. AliA) 

25 

30
[SUB-LABEL A: COMMERCIAL AGRICULTURE] 

CITRUS, TREE NUT and ORCHARD CROPS 

CITRUS (containerized): Calamondin, Citrus citron, Citrus hybrids (includes chironja, tangelo, and tangor), 

Grapefruit, Kumquat, Lemon, Lime, Mandarin (taoo,,,'oe), Pummelo, Orange (sweet and sour), Tangelo. Satsuma mandarin, White 

Aphids 

Asian citrus psyllid 

Black fly 

Ii 

Citrus leafminer Leafhoppers/Sharpshooters 

Mealybugs 

Scales 

volume and necessary 

container as a soil drench or through low-pressure drip or trickle i i 

thorough uniform distribution throughout the media without loss of 

0.38 

0.63 -1.25 

1.25 

( ( 

i carrier to ensure 

water from the container. For optimal results, 

CITRUS: Calamondin, Citrus citron, Citrus hybrids (includes chironja, tangelo, and tangor), Grapefruit, Kumquat, Lemon, 

Lime, Mandarin (tangerine), Pummelo, Orange (sweet and sour), Tangelo, Satsuma mandarin, White sapote (Casimiroa spp.), and 

other cultivars and/or -hybrids of these. 

SOIL APPLICATIONS 

Pests Fluid ounces/Acre 

For control of: 

Aphids 

Asian cit/us psyllid 

Black fly 

Citrus leafminer 8.0 - 16.0 Leafhoppers/Sharpshooters 

Mealybugs 

Scales 

Termites (FL only) 

Whiteflies 

For suppression of: 

Citrus nematode 

Thrips (foliage-feeding thrips only) 16 For suppression of disease symptoms of: 

Citrus tristeza virus (CTV) through vector control 

Citrus yellows 

A plication Methods 

Apply specified dosage of this product in one of the following methods: 

1 Chemigation into root zone through low-pressure drip, trickle, micro-sprinkler or equivalent equipment. Apply to newly 

planted trees or those previously trained to drip, trickle or micro-sprinkler irrigation. Soil must be lightly pre-wetted to break 

soil surface tension prior to applications of this product. Chemigation application can be made separate to normal irrigation 

but followed by 10 to 20 minutes of additional watering to move this product into root zone. Allow 24 hours before initiating 

subsequent irrigations; OR 

2. Soil surface band spray on both sides of the tree. Bands must overlap atthe tree base to create a continuous band within the 

drip-line area of the tree, to be followed immediately with light sprinkler irrigation sufficient to move the product into the 

upper portion of the root zone. This method is suitable for very coarse soils with 0.75% organic matter or less; OR 

3. Drench to base of tree not exceeding one quart total solution per tree immediately around trunk of tree and extending outward 

covering the entire fibrous root system of the tree. Only for trees up to 8 feet tall; OR 

4. For control of existina termite infestations, aoolv soecified dosaae in 1 to 4 auarts of total solution volume, deoendina on size 

26 

31
[SUB-LABEL A: COMMERCIAL AGRICUL TUREI 

trunk; " 

5. For suppression of citrus nematode, apply specific dosage through low pressure chemigation or soil surface spray only, 

ensuring complete coverage of the root system and utilizing application directions stated above for the respective application 

method, Repeated and regular use of this I consecutive growing seasons provides the greatest degree of 

I 

I, 

per crop season: 16.0 fluid ounceslAcre (0.5 lb. 

i i fO I 

Aphids Asian citrus psyllid 

Black fly 

LeafhopperslSharpshooters 

leafminers 

Mealybugs 

Scales 1 

I 

f.4 - 2.0 

(dilute applicatlon) 

2.0 

4.0-8.0 

(depending on tree size, target pest, and infestation 

pressure) 

8.0 

i may i Ii i 

i are appropriate, increase the spray solution concentration to apply an equivalent rate per acre to that applied in 

application. The 8.0 fluid ouncefAcre rate is based on full sized trees. This rate may be reduced proportionally for 

trees. 

" 

Minimum interval b~';~~:,~' Maximum amount?f season: 16.0 fluid ounceslAcre (0.5 lb. 

, I 

POMEFRUIT: Apple, Crabapple, Loquat, Mayhaw, Pear (including Oriental pear), Quince 

SOIL APPLICATIONS 

Pests Fluid ouncesfAcre 

For control of: 

Aphids (including Wooly apple aphid) 8.0 - f2.0 

Leafhoppers 

Application Methods 

Apply specified dosage of this product in the following method: Chemigation into root-zone through low-pressure (drip, trickle, 

micro-sprinkler or eauivaleni)-eouipment. 

Restrictions 

Pre-Harvest Interval (PHI): 21 days 

Maximum amount of product allowed per crop season: 12.0 fluid ouncesfAcre (0.38 lb. AlIA) 

DO NOT apply during bloom or within fO days prior to bloom or when bees are activelv foraoino. 

FOLIAR APPLICATIONS 

Pests Fluid ouncesl100 allons Fluid ouncesfAcre 

For control of: 0.4 - 0.8 f.6 - 3.2 Leafhoppers 

For control of: 

Aphids (except Woolly apple aphid) 

Apple maggot Leafminers 0.8 3.2 

San Jose scale 

For use on Pears Only to control: 

Mealybugs 2.0 8.0 

Pear psylla 

A lication Methods 

27 

32
[SUB-LABEL A: COMMERCIAL AGRICUL TUREj 

Apply specific dosage of this product as a broadcast or directed spray to infested area ensuring thorough coverage. Apply this 

I product throuah oroDerlv calibrated ground or aerial equipment 

Remarks 

Combine a lications tar elin a Ie ma ot with manufacturer's s eeified rate of a sticker. 

Pre-Harvest Interval (PHI): 7 days 

Minimum interval between sprays: 10 days 

Restrictions 

Maximum amount of product allowed per crop season: tS.O fluid ounces/Acre (0.5 lb. AI/A) 

DO NOT apply during bloom or within 10 days prior to bloom or when bees are actively foraQinq. 

IIIJ4.TE 

SOIL 

Aphids 8.0 16.0 

I dosa9,' ~f Ihls ".' I 110 th, , I 

M~vjn ;,: ~~~~~~fa~'~~~d per crop season: 16.0 fluid ounces/Acre (Q,Slb. AliA) 

~O, NOT apply rl"rin"; bloom ..?~ within 10 days prior to bloom or when bees are actively foraging. 

'Th'sos,'so~t~~:"~: JlocAool,ss " Ib~~1 ~II~ ____________________ ~ 

P"IS F[o[d FOf [010 

Aphids 

Leafhoppers/Sharpshooters 

I Apply 

i oaf, 

, ,do"9eofthls 

I 

3.2 

~ ,re, "." ,,,e"9' Apply this "" I 

,~============~ 

STONEFRUIT; Apricot, (including sweet and tart), Nectarine, Peach, Plum (including Chickasaw, Damson and 

~~~' ~ 

~~~ 

roots ';;;;o~oOO~'P'~f in this product's solution for 

~ up to 5 minutes . .t!";~~ ~~§§'~.O~~~~ on roots soon as 

[ i 

(including Wooly apple aphid) 8.0 -12.0 

i, zone I , i , I 

28 

33
[SUB-LABEL A: COMMERCIAL AGRICULTURE] 

Aphids 

Green June beetle 

Japanese beetle 

Leafhoppers/Sharpshooters 

Plant bugs 

Rose chafer 

; 

Ii 

Interval (PHI): 0 days 

Minimum interval between applications: 7 days 

0.8 

spray area 

Maximum amount of product allowed per crop season: 9.6 fluid ounces/Acre (O.30 lb. AlIA) 

Minimum Ii volume Ground: 50 Air: 25 GPA 

I ; I 

, P",-Ha,,',,' Interval (PHI): 7 days 

Minimum interval between applications: 10 days 

Maximum amount of product allowed per crop season: 16.0 fluid QunceslAcre (0.50 lb. AlIA) 

Minimum application volume Ground: 50 GPA; Air: 25 GPA 

1.6 - 3.2 

2.4 - 3.2 

3.2 

coverage. 

TREE NUTS: Almond, Beechnut, Brazil nut, Butternut, Cashew, Chestnut, Chinquapin, Filbert, Hickory nut, Macadamia 

I Ii 

Aphids 

Leafhoppers/Sharpshooters 

Mealybugs 

Spittlebugs 

Termites 

Two-lined spittlebugs 

8.0-16.0 

16.0 

i one i 

into root zone through low-pressure drip, trickle, I equivalent equipment. Pre-wet soil prior to 

applications of this product and allow soil to dry following application and i to subsequent irrigation; OR 

2. Emitter or spot application in a minimum of 4 fluid ounces of mixture per emitter site; OR 

3. Shank or subsurface side-dress, injected to a depth just above or just within the root zone and between the trunk and drip 

line of the tree canopy. Apply this product in a minimum of 10 gallons per acre using multlple shanks on both sides of trees. Ensure 

product placement is below sad or orchard floor debris. Irrigation covering entire treated area must follow within 48 hours to 

promote uptake by root system; OR 

4. For control of termites, I dosage to moist soil as a high-volume drench to the basal portion of the tree 

il iii I 

29 

34
[SUB-LABEL A: COMMERCIAL AGRICULTURE] 

a depth of 18 to 24 inches. Allow soil to dry following treatment and prior to applying any irrigation, 

Remarks 

Use higher rates when applied by shank or subsurface side-dress, used on larger trees, soils with high clay content, for high plant 

populations, and/or where extended control is desired. Under some conditions, control may not occur for 14 or more days or 

unlil two (2) irrigations have been made. Applications made later in the season may result in reduced efficacy. 

Restrictions 

Pre-Harvest Interval (PHI): 7 days 

Maximum amount of product allowed per crop season: 16.0 fluid ounces/Acre (0.50 lb. At/A) 

DO NOT apply cluring bloom or within 10 days prior to bloom or when bees are actively foraging. 

1S0il Application in Tree Nut orchards is not permitted in California unless otherwise directed bv supplemental labelinQ, 

FOLIAR APPLICATIONS 

Pests Fluid ounces/Acre 

For control of: 

Aphids (except Black pecan aphid) 

Leafhoppers/Sharpshooters 1.4-2.8 Phylloxera spp. (leaf infestations) 

Spittlebugs 

Whiteflies 

For control of: 

Black pecan aphid 3.2 Mealybugs 

San Jose scale 1 

A lication Methods 

Apply specific dosage of this product as a broadcast or directed spray to infested area ensuring thorough coverage. I product through properly calibrated ground or aerial equipment. 

Apply this 

Remarks 

Applications for control of San Jose scale must be timed according to crawler stage, treating each successive generation. Two 

applications on a 10 to 14-day interval may be reQuired to achieve control. 

Restrictions 

Pre-Harvest Interval (PHI): 7 days 

Minimum interval between applications: 6 days 

Maximum amount of product allowed per crop season: 11.5 fluid ounces/Acre (0.36 lb. AI/A) 

Minimum application volume (water): Ground: 50 GPA; Air: 25 GPA 

DO NOT apply during bloom or within 10 days prior to bloom or when bees are actively foraginQ. 

BANANA and PLANTAIN 

SOIL APPLICATIONS 

Pests F!uid ounces/Acre 

For control of: 

Aphids 

Leafhoppers 8.0 - 16.0 

For suppression of: 

Sca!es 

A lica1ion Methods 

Apply specified dosage oft~:~ IProduct in the following method: Chemigation into root-zone through low-pressure (drip, trickle, 

micro-sprinkler or equivalent eouioment. 

Restrictions 

Pre-Harvest Interval (PHI): 0 days 

Maximum amount of product allowed per crop season: 16.0 fluid ounces/Acre (0.50 lb. AliA) 

1This use is not permitted in CA unless otherwise directed by supplemental labeling. 

FOLIAR APPLlCAT!ONS 

Pests F!uid ounces/Acre 

For contro! of: 

Aphids 3.2 Leafhoppers 

Thrips 

A lication Methods 

Apply specified dosage of this product as a broadcast or directed spray to infested area ensuring thorough coverage. 

product through properly calibrated ground or aerial equipment. 

Apply this 

Remarks 

Aerial application of this product may result in slower activity and reduced control relative to results from ground application. 

Addition of an organosilicone adjuvant at a rate not to exceed 2.0 fluid ounces/100 gallons finished sprav-solution may improve 

30 

35
[SUB-LABEL A: COMMERCIAL AGRICUL TUREI 

covera e and est control. 

Restrictions 

Pre-Harvest Interval (PHI): 0 days 

Minimum interval between applications: 14 days 

Maximum amount of product allowed per crop season: 16.0 fluid ouncesfAcre (0.5 lb. AlfA) 

TROPICAL FRUIT: Acerola, Atemoya1

: Avocado, Birida1, Black sapote, Canistel, Cherimoya1

, Custard apple1, Feijoa, 

Jaboticaba, Guava, Llama\ Longan, Lychee, Marney sapote, Mango, Papaya, Passionfruit, Persimmon, Pulasan, Rambulan, 

Sapodllla, Soursop\ Spanish lime, Star a'PPle, Starfruil, SUQar apple1

, Wax "ambu. 

SOIL APPLICATIONS 

Pests Fluid ounces/Acre 

For control of: 

Aphids 

Avocado lacebug 12.0 -16.0 

Leafhoppers 

Whiteflies 

For suppression of: 

Scales 16.0 

Thrips (foliage-feeding thrips only) 

Application Methods 

Apply specified dosage of this product in the following method: Chemigation into root-zone through low-pressure 

(drip, trickle, micro*sprinkler or equivalent) equipment. 

Restrictions 

Pre-Harvest Interval (PHI): 6 days 

Maximum amount of product allowed per crop season: 16.0 fluid ounces/Acre (0.50 lb. AI/A) 

1Soi! application use on noted crops is not permitted in California unless otherwise directed by supplemental 

labelinQ. 

FOLIAR APPLICA nONS 

Pests Fluid ounces/Acre 

For control of: 

Aphids 

Leafhoppers/Sharpshooters 

Mealybugs 

Thrips 3.2 

Whiteflies 

For suppression of: 

Thrips 

A lication Methods 

Apply specific dosage of this product as a broadcast or directed spray to infested area ensuring thorough coverage. 

Applv this product throuqh properly calibrated qround or aerial equipment. 

Remarks 

Ground applications of this product are more effective than aerial applications. 

Restrictions 

Pre*Harvest Interval (PHI): 7 days 

Minimum interval between applications: 10 days 

Maximum amount of product allowed per crop season: 16.0 fluid ounces/Acre (0.5 lb. AliA) 

DO NOT apply during bloom or within 10 days prior to bloom or when bees are activelv foraaina. 

31 

36
[SUB-LABEL A: COMMERCIAL AGRICULTURE] 

OTHER CROPS 

Christmas Trees 

SOIL APPLICATIONS 

Pests Fluid ouncesfAcre 

For control of: 

White grub complex (e.g., grubs of Asiatic garden 8.0 - 16.0 beetle, European and M~~ked chafer, Japanese 

beetle and Oriental beetle 

Application Methods 

Soil incorporation and movement of this product to the root zone is required for activity. This product can be incorporated most 

readily when applied to moist soil. Apply specified dosage in one of the following methods: 

1. Chemigalion into root zone through low-pressure drip, trickle, micro-sprinkler or equivalent equipment; OR 

2. 18-inch band on each side of the row (small trees) to full broadcast application (large trees) followed by rainfall or 0.25 to 1 

inch of irrigation within 12 hours after application. 

~ Remarks 

this roduct durin adult fIi h1 activit. or u to mid-Jul when first instar larvae are present. 

Restrictions 

Maximum amount of product allowed per crop season: 16.0 fluid ouncesfAcre (0.50 lb. AliA) 

1 This use is not permitted in California unless otherwise directed by supplemental labeling. 

FOLIAR APPLICATIONS 

Pests Fluid ouncesfAcre 

For control of: 

Aphids 1.6-3.2 Adelgids 

Sawflies 

A lication Methods 

Apply specific dosage of this product as a broadcast or directed spray to infested area ensuring thorough coverage. Apply this 

I product throuqh properly calibrated qround or aerial equipment. 

Remarks 

Ground applications of this product are more effective than aerial applications. 

For gall-forming adelgids, time applications to coincide with full bud-swell or first bud-break of earliest bud-breaking trees. Once 

I aalls form soravino this oroduct is ineffective. 

Restrictions 

Minimum interval between applications: 7 days 

Maximum amount of product allowed per crop season: 16.0 fluid ouncesfAcre (0.5 lb. AliA) 

8.0-16.0 

, ; 

1. Chemigation through low-pressure drip irrigation; OR 

2. For narrow row, cutting orchardsfnurseries used for plant propagation, shank into root zone followed by adequate inigation to 

promote uptake. Adequate irrigation depends on soil moisture level at application. Underdry conditions 0.25 inchfacre is 

; 

may require I of slower uptake. Phyl/oxerina, apply the year, from 

Pests 

32 

37
[SUB-LABEL A: COMMERCIAL AGRICUL TUREj 

For control of: 

Cottonwood leaf beetle 

one i 

6.65 to 13.3 (unhydrated cuttingslwhips) 

13.3 to 20,0 (partially hydrated cutlingsfwhips) 

13.3 (unhydrated cuttingstwhips) 

20.0 (partially hydrated cuttingsfwhips) 

cut (hydrated) cuttings/whips, plant i in specified solution concentration for 24 hours prior to cold 

storage. removal from cold storage, plant as needed; OR 

2. For previously hydrated cuttings/whips removed from cold storage, allow plant material to reach room temperature and soak in 

specified solution concentration for 24 hours prior to planting. 

care in disposal residual soaking solution. Apply solution to existing trees or other registered crops as long as all 

Ii i i 

affect the amount of product into plant material. a constant soaking inteNal of 24 dry '"tti~"'N'hi'" absorb a 

higher quantity of solution and require a lower concentration. Conversely, more hydrated cuttingsfwhips I I and 

require a concentration. Soaking of cuttings/whips must occur in a covered container in absence of UV light. II Populus sp. 

have been tested for safety. Without specific about a Popu/us sp. 

" 

Ii 

J , 

1.6-3.2 

; 

a broadcast i spray method through properly calibrated ground, aerial or chemigation 

Ii 

r i 

Maximum amount of allowed per season: 16.0 fluid ounces/Acre (0.5Ib. AltA) 

DO NOT apply during bloom or with 10 days prior to bloom or when honeybees are actively foraging. 

'Use as a foliar application to Poplar/Cottonwood is not permitted in California unless otherwise directed by supplemental 

I 

33 

38
[SUB-LABEL A: COMMERCIAL AGRICULTURE] 

COMMERCIAL POULTRY PRODUCTION FACILITIES 

POULTRY HOUSING STRUCTURES 

Pests Fluid ounces 11,000 ft" 

For control of: 3.0 Darkling beetles 

Hide beetles'(Oermestids) (90 ml) 

Application Methods 

Apply between flocks after de..caking and sanitation procedures have been completed. Apply as a spot, crack and crevice, or 

surface spray on floors, walls, and support beams of structure. Apply using a minimum of 1/2 to 2 gallons of spray mixture per 

1000 square feet. To prepare the spray mixture, fill the spray tank with 1f2 the required amount afwater, then add the specified 

amount of product. Add the remaining water while agitating or mixing. Maintain constant agitation while applying. 

Apply spray mixture to the entire footing including 1 foot up the wall above the footing, and in 3 to 4 foot wide bands directly 

beneath all feed lines. The areas beneath the feed lines typically harbor large numbers of adult and larval stages of the target 

pest when an infestation occurs. Measure these areas to determine the appropriate amount of spray mixture to apply. For 

structures that are prone to large lnfestations, treat the footings including 1 foot up the wall and the entire floor area of the 

structure. 

Cracks and crevice areas also are prone to large infestations of the target pest. Apply as a crack and crevice treatment around 

wall insulation or other areas that may harbor the target pest. If structures have supporting beams, treat the floor with a 1 foot 

band around each beam and apply 2 feet up the beam. 

For structures prone to extreme infestation, treat the entire structure with a broadcast application. Apply 3.0 fluid ounces in 2 

gallons of water per 1000 square feet of surface. Apply as a broadcast spray to areas where litter has accumulated (floor, under 

feed and water lines, lower sections of walls, cornerS)~ 

Remarks 

In order to avoid problems with pest resistance to imidacloprid, rotate to an insecticide with a different mode of action every 2-3 

flocks. Rotate between 3 different insecticide mode of action classes labeled for control of target pests during a calendar year. 

Restrictions 

DO NOT apply when birds are present or within 7 days of bird placement. 

DO NOT allow food or feed to be contacted by the spray. 

Remove feed and water from the treatment area before apph inQ. 

Pests Fluid ounces f Gallon 

For control of: 0.125-0.25 

Nuisance ants (314 -1.5 TSP) 

A ilcation Methods 

Apply as a crack and crevice or wall void treatment inside structures. Apply to cracks, crevices, drilled holes, onto walls, around 

entry points such as doors, windows, vents, eaves, soffits, and utility access openings. If nests are present in voids, apply into 

the void if possible. Apply evenly to treatment surfaces but not to the point of runoff. Apply to areas around the exterior of the 

structure where ants may present (soil, turf, ornamental shrubs and plantings, and groundcover in close proximity to or touching 

the structure). For above-ground nests, such as in wood posts, decks, or fences, or in trees, spray into holeslopenings where ants 

are travelina and on the wood surface. 

Restrictions 

DO NOT use for control of native or imported fire ants, harvester ants or pharaoh ants. 

Keeo oeoole and oets out of treated areas until soravs have dried. 

34 

39
[SUB-LABEL A: COMMERCIAL AGRICULTURE] 

STORAGE AND DISPOSAL 

DO NOT contaminate water, food or feed by storage or disposal. 

PESTICIDE STORAGE: Store in a cool, dry place and in such a manner as to prevent cross contamination with other 

pesticides, fertilizers, food, and feed. Store in original container and out of the reach of children, preferably in a locked 

storage area. Handle and open container in a manner as to prevent spillage. [f the container is leaking, invert to prevent 

leakage. If container is leaking or material spilled for any reason or cause, carefully dam up spilled material to prevent runoff. 

Refer to Precautionary Statements on label for hazards associated wtth the handling of this material. DO NOT walk through 

spilled material. Absorb spilled material with absorbing type compounds and dispose of as directed for pesticides below. [n 

spill or leak incidents, keep unauthorized people away. 

PEST[CIDE D[SPOSAL: Wastes resulting from the use of this product may be disposed of on site or at an approved waste 

disposal facility. 

CONT A[NER D[SPOSAL: 

For Nonrefillab[e Container. DO NOT reuse or refill this container. Triple rinse or pressure rinse container (or equivalent) 

promptly after emptying. Then offer for recycling, if available, or puncture and dispose of in an approved sanitary landfill, or by 

incineration, or, if allowed by state and local authorities, by burning. [f burned, stay out of smoke, 

Trip[e rinse containers small enough to shake (capacity :s: 5 gal[ons) as follows: Empty the remaining contents into 

application equipment or a mix tank and drain for 10 seconds after the flow begins to drip. Fill the container "X full with water 

and recap. Shake for 10 seconds. Pour rinsate into application equipment or a mix tank, or store rinsate for later use or 

disposal. Drain for 10 seconds after the flow begins to drip. Repeat this procedure two more times. 

Triple rinse containers too large to shake (capacity> 5 gallons) as follows: Empty the remaining contents into application 

equipment or a mix tank. Fill the container Y4 full with water. Replace and tighten closures. Tip container on its side and roll 

it back and forth, ensuring at least one complete revolution, for 30 seconds. Stand the container on its end and tip it back 

and forth several times. Empty the rinsate into application equipment or a mix tank, or store 

rinsate for later use or disposal. Repeat this procedure two more times. 

Pressure rinse as follows: Empty the remaining contents into application equipment or mix tank and drain for 10 seconds 

after the flow begins to drip. Hold container upside down over application equipment or mix tank, or collect rinsate for later 

use or disposal. Insert pressure rinsing nozzle in the side of the container and rinse at about 40 PSI for at least 30 seconds. 

Drain for 10 seconds after the flow begins to drip. 

For Refillab[e container. Refill this container with pesticide only. DO NOT reuse this container for any other purpose. 

Cleaning the container before final disposal is the responsibility of the person disposing of the container. Cleaning before 

refilling is the responsibility of the refiller. To clean the container before final disposal, empty the remaining contents from this 

container into application equipment or a mix tank. Fill the container about 10% full with water and, If possible, spray all sides 

while adding water. Agitate vigorously or recirculale water with the pump for two minutes. Pour or pump rinsate into 

application equipment or rinsate collection system. Repeat this rinsing procedure two more times. When this container is 

empty, replace the cap and seal all openings that have been opened during use; retum the container to the point of purchase 

or to a designated location. This container must only be refilled with the pesticide product. DO NOT reuse the container for 

any other purpose. Prior to refilling, inspect carefully for damage such as cracks, punctures, abrasions, worn out threads and 

closure devices. Check for leaks after refilling and before transport. DO NOT transport if this container is damaged or leaking. 

If the container is damaged, or leaking, or obsolete and not returned to the point of purchase or to a designated location, 

triple rinse emptied container and offer for recycling, if available, or dispose of container in compliance with state and local 

reQulations. 

WARRANTY D[SCLAIMER 

The directions for use of this product must be followed carefully. TO THE EXTENT CONS[STENT W[TH 

APPLICABLE LAW, (1) THE GOODS DELIVERED TO YOU ARE FURN[SHED "AS [S" BY MANUFACTURER OR 

SELLER AND (2) MANUFACTURER AND SELLER MAKE NO WARRANT[ES, GUARANTEES, OR 

REPRESENTAT[ONS OF ANY KIND TO BUYER OR USER, E[THER EXPRESS OR [MPLlED, OR BY USAGE OF 

TRADE, STATUTORY OR OTHERW[SE, WITH REGARD TO THE PRODUCT SOLD, [NCLUD[NG, BUT NOT L1M[TED 

TO MERCHANTAB[L1TY, F[TNESS FOR A PART[CULAR PURPOSE, USE, OR ELlG[B[L1TY OF THE PRODUCT FOR 

ANY PART[CULARTRADE USAGE. UN[NTENDED CONSEQUENCES, [NCLUD[NG BUT NOT LlM[TED TO 

[NEFFECT[VENESS, MAY RESULT BECAUSE OF SUCH FACTORS AS THE PRESENCE OR ABSENCE OF OTHER 

MATER[ALS USED [N COMB[NAT[ON W[TH THE GOODS, OR THE MANNER OF USE OR APPLlCAT[ON, [NCLUD[NG 

WEATHER, ALL OF WHICH ARE BEYOND THE CONTROL OF MANUFACTURER OR SELLER AND ASSUMED BY 

BUYER OR USER. THIS WR[TING CONTAINS ALL OF THE REPRESENTATlONS AND AGREEMENTS BETWEEN 

BUYER, MANUFACTURER AND SELLER, AND NO PERSON OR AGENT OF MANUFACTURER OR SELLER HAS 

35 

40
[SUB-LABEL A: COMMERCIAL AGRICUL TUREj 

ANY AUTHORITY TO MAKE ANY REPRESENTATION OR WARRANTY OR AGREEMENT RELATING IN ANY WAY TO 

THESE GOODS. 

LIMITATION OF LIABILITY 

TO THE EXTENT CONSISTENT WITH APPLICABLE LAW, IN NO EVENT SHALL MANUFACTURER OR SELLER BE 

LIABLE FOR SPECIAL, INCIDENTAL, OR CONSEQUENTIAL DAMAGES, OR FOR DAMAGES IN THEIR NATURE OF 

PENALTIES RELATING TO THE GOODS SOUD, INCLUDING USE, APPLICATION, HlANDLlNG, AND DISPOSAL. TO 

THE EXTENT CONSISTENT WITH APPLICABLE LAW, MANUFACTURER OR SELLER SHIALL NOT BE LIABLE TO 

BUYER OR USER BYWAY OF INDEMNIFICATION TO BUYER OR TO CUSTOMERS OF BUYER, IF ANY, OR FOR 

ANY DAMAGES OR SUMS OF MONEY, CLAIMS OR DEMANDS WHATSOEVER, RESULTING FROM OR BY REASON 

OF, OR RISING OUT OF THE MISUSE, OR FAILURE TO FOLLOW LABEL WARNINGS OR INSTRUCTIONS FOR USE, 

OF THE GOODS SOLD BY MANUFACTURER OR SELLER TO BUYER. ALL SUCH RISKS SHIALL BE ASSUMED 

BYTHE BUYER, USER, OR ITS CUSTOMERSTOTHE EXTENT CONSISTENT WITH APPLICABLE LAW, BUYER'S OR 

USER'S EXCLUSIVE REMEDY, AND MANUFACTURER'S OR SELLER'S TOTAL LIABILITY SHALL BE FOR DAMAGES 

NOT EXCEEDING THE COST OF THE PRODUCT 

If you do not agree with or do not accept any of directions for use, the warranty disclaimers, or limitations 

on liability, do not use the product, and return it unopened to the Seller, and the purchase price will be 

refunded. 

Actara®, Centric®, Cruiser® and Platinum® are trademarks of a Syngenta Crop Protection, Inc. 

Assail® is a trademark of Ni~on Soda Co., Ltd. 

Admire@, Calypso®, Gaucho, Leverage@, Provado® and TrimaxTM are trademarks of Bayer. 

Advise® is a registered trademark of Winfield Solutions, LLC. 

Alias TM and Pasada TM are trademarks of Makkteshim Agan of North America, Inc. 

BetayTM is a trademark of Arysta LifeScience North America Corporation. 

Bidrin® is a trademark of AMVAC Chemical Corporation. 

Clutch® is a registered Irademark of Sumilomo Chemical Takeda Agro Company. 

Couraze® is a trademark of Cheminova, Inc. 

IntruderTM "is a trademark of E.!. duPont de Nemours and Company. 

Macho® is a regislered trademark of Albaugh, Inc. 

[EPA approval dater 

36 

41
[SUB-LABEL B: NURSERY, GREENHOUSE and LANDSCAPE ORNAMENTALS] 

IMPALE 

INSECTICIDE 

A SYSTEMIC and FOLIAR INSECTICIDE FOR USE on ORNAMENTALS, FRUIT and NUT 

TREES, and VEGETABLE PLANTS grown in LAWN and LANDSCAPE AREAS, in 

GREENHOUSES, NURSERIES, and INTERIOR PLANTS CAPES. 

ACTIVE INGREDIENT: 

1m idacloprid: 1 ~[(6-Ch loro-3-pyridi nyl) m ethyIJ-N-n itro-2 -im idazolidi n im ine. ............. 40.4% 

OTHER INGREDIENTS: ...... " .. ".................... ................................. ............ 59.6% 

TOTAL: ..................................... . ....................................................... H ••••• 100.0% 

Contains 4 pounds of imidacloprid per gallon. 

If inhaled: • 

• 

• 

If swallowed: • 

• 

• 

• 

If in eyes: • 

• 

• 

If on skin 0' • 

clothing: • 

• 

KEEP OUT OF REACH OF CHILDREN 

CAUTION 

FIRST AID 

Move person to fresh air. 

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

respiration, preferably by mouth-ta-mouth, jf possible. 

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

Call a poison control center or doctor immediately for treatment advice. 

Have person sip a glass of water if able to swallow. 

Do not induce vomiting unless told to do so by a poison control center or 

doctor. 

Do not aive anvthina bv mouth to an unconscious oerson. 

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 noison control center or doctor for treatment advice. 

Take off contaminated clothing. 

Rinse skin immediately with plenty of water for 15-20 minutes. 

Call a ooison control center or doctor for treatment advice. 

HOT LINE NUMBER 

Have the product container or label with you when calling a poison control center or doctor, or 

going for treatment. For emergency information concerning this product, call the National 

Pesticides Information Center (NPIC) at 1-800-858-7378 seven days a week, 6:30 am to 4:30 pm 

Pacific Time or vour Doison control center at 1-800-222-1222 . .. See inside label booklet for additional Precautionary Statements. 

EPA Reg. No. 94G8-xx EPA Est. No. 

Manufactured for: 

Ritter Chemical, LLC 

P.O. Box 430974 

Houston, TX 77243 

Net Contents: Gals. 

37 

42
[SUB-LABEL B: NURSERY, GREENHOUSE and LANDSCAPE ORNAMENTALS] 

PRECAUTIONARY STATEMENTS 

HAZARDS TO HUMANS AND DOMESTIC ANIMALS 

CAUTION 

Harmful if inhaled. Harmful if swallowed. Causes moderate eye irritation. Avoid breathing spray mist. Remove and 

wash contaminated clothing before reuse. Wash thoroughly with soap and water after handling and before eating, 

drinking, chewing gum or using tobacco, Avoid contact with eyes or clothing. Wear protective eye wear. Wear long 

sleeved shirt and long pants, socks, shoes, and chemical resistant gloves made of waterproof material such as barrier 

laminate, butyl rubber, nitrile rubber, neoprene rubber, natural rubber, polyethylene, polyvinylchloride (PVC) or viton. 

PERSONAL PROTECTIVE EQUIPMENT (PPE) 

Applicators and other handlers must wear: 

• Long-sleeved shirt and long pants. 

• Chemical-resistant gloves made of any waterproof material such as, barrier laminate, butyl rubber, nitrile 

rubber, neoprene rubber, natural rubber, polyethylene, polyvinylchloride (PVC) or viton. 

• Shoes plus socks. 

Follow manufacturer's instructions for cleaning/maintaining personal protective equipment, PPE. If no such 

instructions for washables exist, use detergent and hot water. Keep and wash PPE separately from other laundry. 

Engineering controls statement: When handlers use closed systems, enclosed cabs, or aircraft in a manner that 

meets the requirements listed in the Worker Protection Standard (WPS) for agricultural pesticides [40 CFR 

170.240(d)(4-6)), the handler PPE requirements may be reduced or modified as specified in the WPS. 

USER SAFETY RECOMMENDATIONS 

User must: 

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

Remove clothing immediately if pesticide gets inside. Then wash thoroughly and put on clean clothing. 

Remove PPE immediately after handling this product. Wash the outside of gloves before removing. As soon as 

possible, wash thoroughly and change into clean clothing. 

ENVIRONMENTAL HAZARDS 

DO NOT apply directly to water, areas where surface water is present or to intertidal areas below the mean high water 

mark. DO NOT contaminate water when disposing of equipment washwaters. This product is highly toxic to bees 

exposed to direct treatment or residues on blooming crops or weeds. DO NOT apply this product or allow it to drift to 

blooming crops or weeds if bees are visiting the treatment area. This product is toxic to wildlife and highly toxic to 

aquatic invertebrates. This chemical demonstrates the properties and characteristics associated with chemicals 

detected in ground water. The use of this chemical in areas where soils are permeable, particularly where the water 

table is shallow, may result in groundwater contamination. 

DIRECTIONS FOR USE 

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

DO NOT apply this product in a way that will contact workers or other persons, either directly or through drift. Only 

protected handlers may be in the area during application. For any requirements specific to your State or Tribe, consult 

the agency responsible for pesticide regulation. 

Shake well before using. 

DO NOT apply when wind speed favors drift beyond the area intended for treatment. 

AGRICULTURAL USE REQUIREMENTS 

Use this product only in accordance with its labeling and with the Worker Protection Standard, 40 CFR part 170. 

This Standard contains requirements for the protection of agricultural workers on farms, forests, nurseries, and 

greenhouses, and handlers of agricultural pesticides. It contains requirements for training, decontamination, 

notification, and emergency assistance. It also contains specific instructions and exceptions pertaining to the 

statements on this label about personal protective equipment (PPE) and restricted-entry interval. The 

requirements in this box only apply to uses of this product that are covered by the Worker Protection Standard. 

DO NOT enter or allow worker entry into treated areas during the restricted entry interval (REI) of 12 hours. 

Exceotion: If the product is soil-iniected or soil-incorporated, the Worker Protection Standard, under certain 

38 

43
[SUB-LABEL B: NURSERY, GREENHOUSE and LANDSCAPE ORNAMENTALS] 

circumstances, allows workers to enter the treated area if there will be no contact with anything that has been 

treated. 

PPE required for early entry to treated areas that is permitted under the Worker Protection Standard and that 

involves contact with anything that has been treated, such as plants, soil, or water, is: 

• Coveralls 

• Chemical-resistant gloves made of any waterproof material such as, barrier laminate, butyl rubber, nitrile 

rubber, neoprene rubber, natural rubber, polyethylene, polyvinylchloride (PVC) or viton 

• Shoes DrUS socks 

NON-AGRICULTURAL USE REQUIREMENTS 

The requirements in this box apply to uses of this product that are NOT within the scope of the Worker 

Protection Standard for agricultural pesticides (40 CFR part 170). The WPS applies when this product is used 

to produce agricultural plants on farms, forests, nurseries, or greenhouses. 

• Keep children and pets off treated areas until sprays have dried. 

PRODUCT INFORMATION 

Thorough unifonn coverage is necessary to achieve target pest control. A spray adjuvant may be used to improve 

coverage. This product may not knockdown established and heavy insect populations with a single application. Two 

applications may be required to achieve control; retreat if needed and as directed on this label. This product may be 

tank mixed with other insecticides as specified for knockdown of pests or for improved control of other pests. 

Apply this product as a broadcast or directed spray application. Time applications to begin as target pest populations 

begin to build. Ensure that the treated area receives a thorough, uniform coverage of the spray solution. To improve 

coverage, a spray adjuvant may be added to the Impale tank mix. 

Apply using either ground equipment in a minimum spray volume of 10 gallons per acre or with aerial equipment in a 

minimum spray volume of 5 gallons of water per acre. Use adequate spray volumes and calibrated application 

equipment. 

RESISTANCE: Some insects are known to develop resistance to insecticides after repeated use. As with any 

insecticide, the use of this product must conform to resistance management strategies established for the use area. 

Consult your local or state pest management authorities for details. 

Mix Preparation 

To prepare the application mixture: 

1. Fill the spray tank with a portion of the required amount of water and begin agitation. 

2. Add the specified amount of Impale. 

3. Fill the tank with the remaining water needed. Maintain sufficient agitation during mixing and application. 

This product can be used with other pesticides and/or fertilizer solutions; refer to the Tank Mix and Compatibility 

Notes below. When tank mixtures of this product and other pesticides are involved, prepare the tank mixture as 

specified above and follow the suggested Mixing Order below. 

This product may be applied by chemigation (see APPLICATION THROUGH IRRIGATION SYSTEMS section below) 

if allowed in the specific application sections. 

TANK MIXES 

Unless otherwise prohibited on this label or the label of an intended tank mix product, this product may be applied in 

combination with any pesticide registered for the same crop, timing, and method of application. Observe the most 

restrictive label statements of various tank mix products used. IMPORTANT: PESTICIDE TANK MIXES MAY 

INCREASE THE RISK OF MIXING INCOMPATIBILITIES, REDUCED EFFECTIVENESS AND/OR CAUSE CROP 

INJURY OR LOSS. ANY LIABILITY FOR LOSS, INJURY OR DAMAGE RESULTING FROM A TANK MIXTURE 

NOT SPECIFIED ON THIS LABEL OR IN MANUFACTURER'S SUPPLEMENTAL LABEliNG DISTRIBUTED 

FOR THIS PRODUCT IS SPECIFICALLY DISCLAIMED BY MANUFACTURER. 

Compatibility 

Before full-scale mixing of this product with other pesticides, fertilizers, secondary plant nutrients, adjuvants, 

surfactants or oils, you must detennine the compatibility of the proposed mixture. Use proportionate quantities of 

each ingredient and mix in a small container. Always mix one product thoroughly with the diluent before adding 

another product. If no incompatibility is evident after 30 minutes, the mixture is generally compatible for spraying. To 

evaluate potential short term effects of applying the mixture, test the tank mix combination on a few plants or a small 

area before larger-scale treatments. Wait at least 2 to 3 days for problems to become apparent, IMPORTANT: 

39 

44
[SUB-LABEL B: NURSERY, GREENHOUSE and LANDSCAPE ORNAMENTALS] 

MIXING WITH OTHER SUBSTANCES MAY INCREASE THE RISK OF MIXING INCOMPATIBILITIES, REDUCED 

EFFECTIVENESS ANDIOR CAUSE CROP INJURY OR LOSS. ANY LIABILITY FOR LOSS, INJURY OR 

DAMAGE RESULTING FROM A MIXTURE NOT SPECIFIED ON THIS LABEL OR IN MANUFACTURER'S 

SUPPLEMENTAL LABELING DISTRIBUTED FOR THIS PRODUCT [S $PEC[FtCALL Y DISCLAIMED BY 

MANUFACTURER. 

Mixing Order 

When pesticide mixtures are needed, add wettable powders first, this product or other f10wables second, and 

emulsifiable concentrates last. Ensure good agitation as each component is added and do not add an additional 

component until the previous is thoroughly mixed. A fertilizer/pesticide compatibility agent may be needed jf a fertilizer 

solution is to be added to the mixture. Be sure to maintain constant agitation during both mixing and application to 

ensure unilormity of spray mixture. Further information on Tank Mixes is available from your local Ritter Chemical, 

LLC representative. 

APPLICATION THROUGH IRRIGATION SYSTEMS (CHEMIGATION) 

This product may be applied at rates specified on this label either alone or in tank mixture with other pesticides and 

chemicals registered for application through irrigation systems. The normal dilution ratio is 1 :100 to 1 :200, depending 

on the system. Always meter the product into the irrigation water during the first part of the irrigation cycle. The 

product may be mixed separately prior to injection. Agitation may be necessary if the mixture is allowed to stand 

more than 24 hours. 

• DO NOT connect an irrigation system (including greenhouse systems) used for pesticide application to a public 

water system unless the pesticide label~prescribed safety devices for public water systems are in place. 

• Apply this product only through micro~irrigation (individual spaghetti tube), drip irrigation, overhead irrigation, 

and ebb and flood or hand~held or motorized calibrated irrigation equipment and only as directed in the 

specific directions. DO NOT apply Ihis producl through any olher type of irrigalion system. Crop injury or lack 

of effectiveness can result from non~uniform distribution of treated water. 

Be sure to remove scale, pesticide residue and other foreign matter from the tank and entire irrigation 

system prior to application. 

• A person knowledgeable 01 the chemigation system and responsible for its operation, or a person who is 

under the supeNision of the responsible person, shall shut the system down and make necessary 

adjustments should the need arise. 

• II you have any questions about calibration, contact State Extension SeNice specialists, equipment 

manufacturers or other experts. 

SAFETY DEVICES FOR IRRIGATION SYSTEMS CONNECTED TO PUBLIC WATER SUPPLIES 

If the source of water for your irrigation system is a public water supply, follow the instructions below: 

1. Public water system means a system for the provision to the public of piped water for human consumption 

if such system has at least 15 seNice connections or regularly seNes an average of at least 25 

individuals daily at least 60 days out of the year. 

2. Chemigation systems connected to public water systems must contain a functional, reduced~pressure 

zone, backflow preventer (RPZ) or the functional equivalent in the water supply line upstream from the point 

of pesticide introduction. As an option to the RPZ, water from the public water system must be discharged 

into a reseNoir tank prior to pesticide introduction. There shall be a complete physical break (air gap) 

between the outret end of the fill pipe and the top or overflow rim of the reseNoir tank of at least twice the 

inside diameter of the fill pipe. 

3. The pesticide injection pipeline must contain a functional, automatic quick-closing check valve to prevent 

the flow of fluid back toward the injection pump. 

4. The pesticide injection pipeline must contain a functional, normally closed, solenoid~operated valve 

located on the intake side of the injection pump and connected the system interlock to prevent fluid from 

being withdrawn from the supply tank when the irrigation system is either automatically or manually shut 

down. 

5. The system must contain functional interlocking controls to automatically shut off the pesticide injection 

pump when the water pump motor stops, or in cases where there is no water pump, when the water 

pressure decreases to the point where pesticide distribution is adversely affected. 

6. Systems must use a metering pump, such as a positive displacement injection pump (e.g., diaphragm 

pump) effectively designed and constructed of materials that are compatible with pesticides and capable 

of being fitted with a system interlock. 

40 

45
[SUB-LABEL B: NURSERY, GREENHOUSE and LANDSCAPE ORNAMENTALS] 

7. DO NOT apply when wind speed favors drift beyond the area intended for treatment. 

SAFETY DEVICES FOR IRRIGATION SYSTEMS NOT CONNECTED TO A PUBLIC WATER SUPPLY 

If the source of water for your irrigation system is NOT a public water supply, follow the instructions below: 

1. The system must contain a functional check valve, vacuum relief valve and low pressure drain appropriately 

located on the irrigation pipeline to prevent water source contamination from backflow. 

2. The pesticide injection pipeline must contain a functional, automatic, quick-closing check valve to prevent 

the flow of fluid back toward the injection pump. 

3. The pesticide injection pipeline must also contain a functional normally closed solenoid-operated valve 

located on the intake side of the injection pump and connected to the system interlock to prevent fluid 

from being withdrawn from the supply tank when the irrigation system is either automatically or manually 

shut down. 

4. The system must contain functional interlocking controls to automatically shut off the pesticide injection 

pump when the water pump motor stops. 

5. The irrigation line or water pump must include a functional pressure switch which will stop the water pump 

motor when the water pressure decreases to the point where the pesticide distribution is adversely 

affected. 

6. Systems must use a metering pump such as a positive displacement injection pump (e.g. diaphragm pump) 

effectively designed and constructed of material that is compatible with pesticides and capable of being 

fitted with a system interlock. 

7. DO NOT apply when wind speed favors drift beyond the area intended for treatment. 

Water Volume 

Chemigation applications of this product must be made as concentrated as possible. Retention of this product on target 

site of insect infestation is necessary for optimum activity. Chemigation of this product in water volumes exceeding 

0.10 inch/Acre is not recommended. 

Uniform Water Distribution and System Calibration 

The irrigation system must provide uniform distribution of treated water. Crop injury, lack of effectiveness, or illegal 

pesticide residues in the crop can result from non-uniform distribution of treated water. The system must be calibrated 

to uniformly apply the rates specified. If you have questions about calibration, you should contact State Extension 

SelVice specialists, equipment manufacturers or other experts. 

Chemigation Monitoring 

A person knowledgeable of the chemigation system and responsible for its operation, or under the supervision of the 

responsible person, shall shut the system down and make necessary adjustments should the need arise. 

Drift 

DO NOT apply when wind speed favors drift beyond the area intended for treatment. 

RESTRICTIONS 

DO NOT graze treated areas or use clippings from treated areas for feed or forage. 

Prevent runoff or puddling of irrigation water following application. 

Keep children and pets off treated area until dry. 

DO NOT apply this insecticide to areas which are water logged or saturated, which will not allow penetration into the 

root zone of the plant. 

Treated areas may be replanted with any crop specified on an imidacloprid label, or with any crop for which a 

tolerance exists for the active ingredient. For crops not listed on an imidacloprid label, or for crops for which no 

tolerances for the active ingredient have been established, a 12-month plant-back interval must be observed. 

APPLICATION INSTRUCTIONS 

NURSERY and GREENHOUSE GROWN ORNAMENTALS and VEGETABLE PLANTS 

This product is for foliar and systemic insect control in and around field-grown nursery and container stock, indoor 

and outdoor ornamentals (including both greenhouse and interior plantscapes) and ornamentals grown in flats, on 

benches or in beds. Apply this product by foliar application or soil applications; including soil injection, drenches, and 

broadcast sprays. Foliar applications offer locally systemic activity against insect pests. Soil applications will result in 

translocation of the active ingredient upward into the plant system from root uptake. To assure optimum root uptake, 

apply product where the growing portion of the target plant can absorb the active ingredient. The addition of a 

41 

46
[SUB-LABEL B: NURSERY, GREENHOUSE and LANDSCAPE ORNAMENTALS] 

nitrogen containing fertilizer, where applicable, into the solution has been shown to enhance the uptake of the active 

ingredient. When making soil applications to plants with woody stems, systemic activity will be delayed until the 

active ingredient is translocated throughout the plant. In some cases, this translocation delay could take 60 days or 

longer. For this reason, soil applications must be made prior to anticipated pest infestation to achieve optimum levels 

of control. 

Larvae of: 

Adelgids 

Aphids 

Interior I 

Japanese beetles (adults) 

Lacebugs 

Leaf beetles (including Elm, Viburnum) 

Leafhoppers/Sharps hooters 

leaf miners 

bs, Evergreens, Flowers, 

I 

0.75 

(22 ml) 

" 

as upon use i Ii 

i on hard-te-wet foliage such as holly, or ivy, the of a spreader/sticker is recommended. If concentrate 

or mist type spray equipment is used, apply an amount of product on the treatment area equivalent to the amount that would be 

used in a dilute application. This insecticide has been found to be compatible with commonly used fungicides, miticides, liquid 

fertilizers, and other commonly used insecticides. The physical compatibility of this product may vary with different sources of 

pesticide products and local cultural practices. Any tank mixture which has not been previously tested must be prepared on a 

small scale (pint or quart jar), using the proper proportions of pesticides and water to ensure the physical compatibility of the 

use on 

Chinese 

White grub larvae such as: 

Japanese beetle larvae, 

Chafers, 

more 

" 

i i 

" 

0.23 - 0.30 

(7.0 - 9.0 ml) 

per acre per year 

" Greens, Pepinos, 

10.0 -12.8 

(0.625 - 0.8 pints) 

" 

Only for use on vegetable plants intended for resale including: Broccoli, Chinese Broccoli, Broccoli Raab, Brussel Sprouts, 

Cabbage, Chinese CaUliflower, Ground Cherry, Kale, Kohlrabi, Lettuce, Mustard Greens, Pepinos, 

42 

47
[SUB-LABEL B: NURSERY, GREENHOUSE and LANDSCAPE ORNAMENTALS] 

Ornamental and Non-bearing Fruit and Nut trees, Shrubs, Flowers, and Groundcover 

SOIL APPLICATION (injection & drench) 

Pests USE RATES 

For TREES : 

Use the following rates as a function of tree diameter at breast 

height (DBH): 

For control of: Apply 0.05 - 0.20 fl oz (1.5 - 6.0 ml) per inch of trunk diameter 

Adelgids (DBHl, 

Aphids You may use the higher rate (0.2 fl oz) only Black vine weevil larvae 

Emerald ash borer' for trees greater than 15 DBH to control the following pests: 

Eucalyptus long horned borer' . 

Flatheaded borers (including Bronze birch and Alder)' Asian longhorned beetle 

Japanese beetles Emerald Ash Borer 

Lace bugs Eucalyptus longhorned borer 

Leaf beetles (including Elm and Viburnum) Bronze birch borer 

Leafhoppers/Sharpshooters Alder borer 

Leafminers 

Restriction: Do not apply more than 12.8 fI oz (0.4 Ib of active Mealybugs 

Pine tip moth larvae ingredient) per acre per year. 

Psyllids Diameter at Breast Height (D.B.H.) = is measured at 4.5 feet from Royal palm bugs 

Sawfly larvae the around. 

Soft scales 

White grub larvae SHRUBS: per foot of shrub height 

Whiteflies 

0.05 - 0.10 fluid ounces (1.5 - 3.0 ml) 

FLOWERS and GROUDCOVER: 

0.23 - 0.30 fluid ounces (7.0 - 9.0 ml) /1000 F"r 

For suppression of: Use the higher rates listed in the TREES, SHRUBS, FLOWERS Armored scales 

Thrips and GROUNDCOVER sections above. 

A lication methods for TREES and SHRUBS 

Soil injection: Mix the required dosage in sufficient water to inject an equal amount of solution in each hole. Maintain a low 

pressure and use sufficient solution for distribution of the liquid into the treatment zone. Keep the treated area moist for 7 to 10 

days. DO NOT use· less than 4 holes per tree or shrub. 

S ecific Soil In ection methods for trees and lar e shrubs: 

GRID System: Holes must be spaced on 2.5 foot centers, in a grid pattern, extending to the drip line of the tree. 

CIRCLE System: Apply in holes evenly spaced in circles, (use more than one circle dependent upon the size of the tree) 

beneath the drip line of the tree extendinq in from that line. 

BASAL System: Space injection holes evenly around the base of the tree trunk no more than 6 to 12 inches out from the 

base. 

Soil Drench: Uniformly apply the dosage in no less than 10 gallons of water per 1 ,000 square feet as a drench around the base 

of the tree or shrub, directed to the root zone. Remove plastic or any other barrier that will stop solution from reaching the root 

zone. 

Remarks 

Application to trees already heavily infested with listed borers may not prevent the eventual loss of the trees due to existing pest 

damaae and tree stress. 

Restrictions 

DO NOT apply using Soil Injection methods in Nassau or Suffolk Counties of New York. 

DO NOT applv more than 0.8 pints (0.4 Ibs AI) per acre per vear. 

A lication methods for FLOWERS and GROUNDCOVER 

Apply as a broadcast treatment and incorporate into the soil before planting or apply after plants are established. For control of 

target pest, immediately irrigate following application to established plants. 

Bark Media: Media with 30% or more bark content may confer a shorter period of protection when treated with this product. 

43 

48
[SUB-LABEL B: NURSERY, GREENHOUSE and LANDSCAPE ORNAMENTALS] 

GRASSY AREAS IN NURSERIES 

Apply this product to grassy areas under and around field and container grown plants, on roadways and other grassy 

areas in and around nurseries to control soil inhabiting pests. Use this product for the suppression of Mole crickets 

and Cutworms. The active ingredient in this product has sufficient residual activity so that applications can be made 

prior to the egg laying activity of the target pest. Base the need for an application on historical monitoring of the site, 

previous records and experience, current season adult trapping, and other methods. Make applications prior to egg 

hatch of the target pests. Sufficient irrigation or rainfall is needed to facilitate the movement of active ingredient 

through the thatch. 

Pests Fluid ounces/1 ,000 FT Fluid ounces/Acre 

For control of: 

Larvae of: 

Annual bluegrass weevil 

Asiatic garden beetle 

Billbugs 

Black turfgrass ataenius 0.23 - 0.30 10.0 -12.8 Chafers (Northem masked, (7.0 - 9.0 ml) (0.625 - 0.8 pints) Southern masked, European) 

Green June beetle 

Japanese beetle 

Mayor June beetle 

Oriental beetle 

Phyllophaga spp 

For control of: 

Mole crickets 1 0.30 12.8 

For suppression of: 

Chinchbuqs2 

(9.0 ml) (O.S pints) 

Application Methods 

Apply this product in sufficient water to provide adequate distribution over the treatment area. The use of accurately calibrated 

equipment normally used for the application of soil insecticides is required. Use equipment which will produce a uniform, coarse 

spray droplet, use a low pressure setting to eliminate off target drift. Check calibration periodically to ensure that eqUipment is 

working properly. 

Irrigation or rainfall must occur within 24 hours after application to move the active ingredient through the thatch. DO NOT mow 

turf or lawn area until after sufficient irriqation or rainfall has occurred so that uniformitY of application will not be affected. 

Remarks 

For control of grubs, billbugs and annual bluegrass-weeVil, make application prior to egg hatch of the target pest Consult your 

local turf, state Agricultural Experiment Station. or State Extension Service Specialists for more specific information regarding timing 

of application. 

1 For control of Mole crickets make application prior to or during the peak egg hatch period. When adults or large nymphs are 

present and actively tunneling, make a curative insecticide application with the application of this product. See tank mixing 

section above for general instructions on tank mixtures. 

2 For suppression of Chinchbuqs. make application prior to or durinq the hatchinq of the first instar nymphs. 

Restrictions 

Maximum application rate per acre per year: 0.8 pints (12.8 fluid ounces) (O.4lb of active ingredient) 

DO NOT make application when treatment area is waterlogged or soil is saturated with water. Adequate distribution of the active 

ingredient cannot be achieved when these conditions exist The treatment area must be in such a condition that the rainfall or 

irrigation will penetrate vertically in the soil profile. 

TURFGRASS (including Sod farms) 

Use this product for the control of soil inhabiting pests of turfgrass. Use this product for suppression of cutworms and 

chinch bugs. Use as directed on turfgrass on siles such as home lawns, business and office complexes, shopping 

complexes, multi-family residential complexes, golf courses, airports, cemeteries, parks, playgrounds, athletic fields 

and sad farms. The active ingredient in this product has sufficient residual activity so that applications can be made 

preceding the egg laying activity of the target pests. Base the need for an application on historical monitoring of the 

site, previOUS records or experiences, current season adult trapping or other methods. Make applications prior to 

egg hatch of the target pests, followed by sufficient irrigation or rainfall to move the active ingredient through the 

thatch. 

44 

49
[SUB-LABEL B: NURSERY, GREENHOUSE and LANDSCAPE ORNAMENTALS] 

Pests Fluid ounces/1 ,000 FT Fluid ounces/Acre 

For control of: 

Larvae of: 

Annual bluegrass weevil 

Asiatlc garden beetle 

Billbugs 

Black turfgrass ataenius 

Chafers (Northern masked, 0.23- 0.30 10.0 -12.8 

Southern masked, European) (7.0- 9,0 ml) (0.625 - 0.8 pints) 

European crane fly 

Green June beetle 

Japanese beetle 

Mayor June beetle 

Oriental beetle 

Phyllophaga spp. 

For control of: 

Mole crickets 1 0.30 12.8 

For suppression of: 

Chinchbu~s2 

(9.0 mil (0.8 pints) 

A lication Methods 

Apply this product in sufficient water to provide adequate distribution over the treatment area. The use of accurately calibrated 

equipment nOffilally used for the application of soil insecticides is required. Use equipment which will produce a uniform, coarse 

spray droplet, use a low pressure setting to eliminate off target drift. Check calibration periodically to ensure that equipment is 

working properly, 

Irrigation or rainfall must occur within 24 hours after application to move the active ingredient through the thatch. DO NOT mow turf 

or lawn area until after sufficient irri ation or rainfall has occurred so that uniformity of application will not be affected. 

Remarks 

For control of grubs, European crane fly. billbugs and annual bluegrass-weeVil, make application prior to egg hatch of the target 

pest. Consult your local turf, state Agricultural Experiment Station, or State Extension Service Specialists for more specific 

information regarding timing of application. 

1 For control of Mole crickets make application prior to or during the peak egg hatch period. When adults or large nymphs are 

present and actively tunneling, make a curative insecticide application with the application of this product. See tank mixing 

section above for general instructions on tank mixtures. 

2 For suppression of Chinchbuqs, make application prior to or durinq the hatchinq of the first instar nymphs. 

Restrictions 

Maximum application rate per acre per year: 12.8 fluid oz (0.8 pints) (OA Ib of active ingredient) 

DO NOT make application wilen treatment area is waterlogged or soil is saturated with water. Adequate distribution of the active 

ingredient cannot be achieved when these conditions exist. The treatment area must be in such a condition that the rainfall or 

irrigation will penetrate vertically in the soil profile. 

EBB & FLOOD APPLICATION 

Apply this product through Ebb and Flood applications. To assure accurate uptake prior to treatment, bring a minimum of 

10 plants up to a known field capacity and allow to dry out for one or two days. Re-wet these plants to determine how 

much water on average each plant will absorb to bring it back at field capacity. Use the volume absorbed per plant 

(keeping pot sizes uniform) multiplied by the number of pots being treated. Add to this volume a required minimum to 

flood your smallest treatment area. This will minimize the return back to the storage tank. Re-use the retumed volume with 

subsequent irrigation or nutrients on the same plants. 

Ornamental and vegetable plants5 grown in containers 

Herbaceous species Woody perennials, 

Pests Pot size 

including ve~etable Herbaceous species 

plants including vegetable (Inches) (1 or 2 plants/pot) plants' 13 or more/o~tl 

ml 1100 plants 

For control of: 2 

Adelgids 

0.80 1.25 

Aphids 3 1.25 1.85 Armored scales (suppression) 

45 

50
[SUB.LABEL B: NURSERY, GREENHOUSE and LANDSCAPE ORNAMENTALS] 

Fungus gnats (larvae only) 4 1,65 2.50 Japanese beetles (adults) 

Lacebugs 

Leaf Beetles (including Elm and 5 2.10 3.15 

Viburnum) 

Leafhoppers/Sharpshooters 6 2.50 3,85 

Leafminers 

Mealybugs 7 2.95 4.55 Psyllids 

Root mealybugs2 

8 3,30 5.00 Root weevil complex: 

(such as Ap':oka, Black vine, 

Citrus root)3 9 3.70 5.55 

Soft scales 

Thrips (suppression)4 10 4.15 6.25 

Whiteflies 

White grub larvae 11 4.50 7.15 

(such as Japanese beetie, 

Masked chafers, European 

chafer, Oriental beetle, Asiatic 12 5.00 8.35 

1 Fungus gnat larvae in the soil will be controlled by drench or incorporation. No adult Fungus Gnat control. Other foliar insect 

control is achieved by the uptake of this product from a healthy root system translocating the active ingredient up into the plant. 

2 Root Mealybug control will require a thorough drenching of containerized media. Coverage is essential for control while 

minimizing the amount of leachate. Rate: 1.0 fluid ounces (30 ml) in 150 gallons of water. 

3 Citrus Root Weevil: For use on non-bearing citrus nursery stock. 

4 Thrips suppression on foliage only. Thrips in buds and flowers will not be suppressed. 

6 Note: For use on vegetable plants intended for resale only including: Broccoli, Chinese Broccoli, Broccoli Raab, Brussels 

Sprouts, Cabbage, Chinese Cabbage, Cauliflower, Collards, Eggplant, Ground Cherry, Kale, Kohlrabi, Lettuce, Mustard 

Greens, Pepinos, Peppers, Potatoes, Rape 

DRENCH and IRRIGATION APPLICATIONS 

Use this product for drench and irrigation application only on greenhouse and nursery grown ornamentals, vegetable 

plants intended for resale only, and interior plantscapes using soil drenches, mirco*irrigation, drip irrigation, 

overhead irrigation, ebb and flood irrigation, or hand*held or calibrated motorized irrigation equipment. Apply this 

product at the rates listed on the label either alone or in tank mixtures with other pesticides and chemicals registered 

for application through irrigation systems. The normal dilution ratio is 1:100 to 1:200, depending on the system. 

Always meter the product into the irrigation water during the first part of the irrigation cycle. The product may be 

mixed separately prior to injection. Agitation is necessary if the mixture is allowed to stand more than 24 hours. 

Remove scale, pesticide residue and other foreign matter from the tank and entire irrigation system. Only use this 

product through micro irrigation (individual spaghetti tubes), drip irrigation, overhead irrigation, ebb and flood, or 

handheld or motorized calibrated irrigation equipment. Crop injury or lack of effectiveness can result from non 

uniform distribution of treated water. 

RESTRICTION: DO NOT apply this product through any other type of irrigation system. 

Ornamental and vegetable plants5 grown in containers 

Herbaceous species Woody perennials, 

Pests including ve~etable Herbaceous species Container size plants including vegetable (inches) (1 or 2 plants/potl plants' (3 or more/pot) 

# of Containers treated with 1.0 fluid oz (30 ml) 

For control of: 2 3000 2000 

Adelgids 3 2000 1350 

Aphids 

Fungus gnats (larvae only)l 4 1500 1000 

Japanese beetles (adults) 5 1200 800 

Lacebugs 6 1000 650 

46 

51
[SUB-LABEL B: NURSERY, GREENHOUSE and LANDSCAPE ORNAMENTALS] 

Leaf Beetles (including Elm and 7 850 550 

Viburnum leaf beetles) 8 750 500 Leafhoppers (including glassywinged sharpshooter) 9 675 450 

Leafminers 10 600 400 Mealybugs 

Psyllids It 550 350 

Root mealybugs2 12 500 300 

Root weevil complex: A lication method 

(such as Apopka, Black vine, Use sufficient volume to wet most of the potting medium without loss of liquid from the Citrus root weevils)3 bottom of the container. Apply according to label directions, Follow application with Soft scales 

Thrips (suppression)4 moderate irrigation. Irrigate carefully during the next 10 days in order to avoid loss of 

active inQredient due to leachinQ. Whiteflies 

Ornamental and vegetable plants5 White grub larvae grown in flats, benches, or beds 

(such as Japanese beetie, 0.34 fL oz. (10 mL) per 1,000 square feet 

Masked chafers, European A lication method chafer, Oriental beetle, Asiatic 

Mix required amount in sufficient water to uniformly cover the area being treated. Do not garden beetle) use less than 2 gallons of mixture per t,OOO square fee!. Apply as a broadcast treatment 

and incorporate into the medium before planting or apply after plants are established. To 

optimize control lightly water the treated areas if application is made to established 

piants. Allow no leaching or runoul for to days after application. 

Remarks 

1 Fungus gnat larvae in the soil will be controDed by drench or incorporation. No adult Fungus Gnat control. Other foliar insect 

control is achieved by the uptake of this product from a healthy root system trans locating the active ingredient up into the plant. 

2 Root Mealybug contrOl will require a thorough drenching of containerized media. Coverage is essential for control while 

minimizing the amount of leachate. Rate: 1.0 fluid ounces (30 mf) in 150 gallons of water. 

3 Citrus Root Weevil: For use on non-bearing dtrus nursery stock. 

4 Thrips suppression on foliage only. Thrips in buds and flowers will not be suppressed. 

6 For use on vegetable plants intended for resale only including: Broccoli, Chinese Broccoli, Broccoli Raab, Brussels 

Sprouts, Cabbage, Chinese Cabbage, Cauliflower, Collards, Eggplant, Ground Cherry, Kale, Kohlrabi, lettuce, Mustard 

Greens, Pepinos, Peppers, Potatoes, Rape 

Pests 

Containerized plants 

Container Size (gallons) # of Containers treated with 1.0 fluid oz (30 ml) 

For control of: 

Adelgids 1 340 - 244 

Aphids 

Fungus gnats (larvae only)1 

Japanese beetles (adults) 2 280-2tO 

Lacebugs 

Leaf Beetles (including Elm and 

Vibumum) 3 220 - t85 

leafhoppers/Sharpshooters 

leafminers 

Mealybugs 5 t60 - t10 

Psyllids 

Root mealybugs2 

Root weevil complex: 7 100 - 75 

(such as ARoka, Black vine, 

Citrus root)3 

Soft scales 10 60-45 

Thrips (suppression)4 

Whiteflies 

While grub larvae 15 40-30 

(such as Japanese beetle, 

Masked chafers, European 

chafer, Oriental beetle, Asiatic 20 20-15 

qarden beetle) 

Application method 

47 

52
[SUB.LABEL B: NURSERY, GREENHOUSE and LANDSCAPE ORNAMENTALS] 

Apply in sufficient water to wet the potting medium. Make applications prior to egg hatch of the target pest Irrigate moderately 

after application to move the active inqredient into the root zone. 

Remarks 

1 Fungus gnat larvae in the soil will be controlled by drench or incorporation. No adult Fungus Gnat conlrol. Otherfoliarinsect 

control is achieved by the uptake of this product from a healthy root system Iranslocating the active ingredient up into the plant. 

2 Root Mealybug control will require a thorough drenching of containerized media. Coverage is essential for control while 

minimizing the amount of leachate. Rate: 1.0 fluid ounce (30 mL) in t50 gallons of water. 

3 Ci1rus Root Weevil: For use on non-bearing citrus nursery stock. 

4Thrips suppression on foHaqe only. Thrips in buds and flowers will not be suppressed. 

Field and Forest Nurseries 

Pests Fluid ounces 11,000 ft of row Fluid ounces I 1,000 s uare ft 

For com rol of: 

White grub larvae1 0.34 

(such as Japanese beetle, 1.0 (10 ml) 

Masked chafers, European (30ml) 

chafer, Oriental beetle, Asiatic 12.8 Fluid ounces I Acre 

garden beetle) 

A lication method 

Apply as a uniform band on either side of the row using a band width six (6) inches wider than the actual root ball diameter to be 

duo. 

Remarks 

Mowing of the vegetation in the area to be treated to a height of 3 inches or less prior to application will improve the consistency 

of control. 

Apply May through July. For target pest control, treatment must be followed by rainfall or irrigation. 

1 For grub control in areas of turf, apply as a broadcast application using 0.25 - 0.34 fluid ounces (7 - 10 ml) per 1,000 square 

feet (10.9 - t2.8 fluid ounces I Acr~) 

Restrictions 

DO NOT use less than 2 gallons of spray volume per 1,000 square feet (85 GPA). 

DO NOT exceed 12.8 fluid ounces I acre per year (0.4 Ibs AliA). 

DO NOT allow bands in ad'acent rows to overlap. 

LANDSCAPE ORNAMENTALS and PLANTINGS 

This product is for use on ornamentals and plantings in commercial and residential landscapes and interior plantscapes. It is 

a systemic product. Apply this product by foliar application or soil applications; including soil injection, drenches, and 

broadcast sprays. Foliar applications offer locally systemic activity against insect pests. Soil applications will result in 

translocation of the active ingredient upward into the plant system from root uptake. Apply this product where the growing 

portion of the target plant can absorb the active ingredient. The addition of a nitrogen containing fertilizer, where applicable, 

into the solution has been shown to enhance the uptake of the active ingredient. When making soil applications to plants with 

woody stems, systemic activity will be delayed until the active ingredient is translocated throughout the plant. In some cases, 

this translocation delay could take 60 days or longer. For this reason, soil applications must be made prior to anticipated pest 

infestation to achieve optimum levels of control. 

Ornamental and Non-bearing Fruit and Nut trees, Shrubs, Evergreens, Flowers, Foliage Plants, 

Groundcovers, Interior Plantscapes 

FOLIAR APPLICATION 

Pests Fluid ounces/1DO allons of water 

48 

53
[SUB-LABEL B: NURSERY, GREENHOUSE and LANDSCAPE ORNAMENTALS] 

For control of: 

Larvae of: 

Adelgids 

Aphids 

Japanese beetles (adults) 

Lacebugs 

Leafbeetles (including Elm, Viburnum) 

Leafhoppers/Sharpshooters 

Leaf miners 

Mealybugs 

Sawfly larvae 

Whiteflies 

trees, Flowers, Foliage Plants, 

0.75 

(22 ml) 

Use this product to control 

available as a food source 

scale insects, mealybugs and other sucking pests on ornamentals to limit the honeydew 

0",""". ant populations. Applications can then be supplemented with residual sprays, bait 

i amount water and apply as 

foliar applications on hard-Ie-wet foliage such as holly, pine, or ivy, addition of a spreader/sticker is recommended. 

concentrate or mist type spray equipment is used, use an equivalent amount of product on the area sprayed, as would be used 

in a dilute application. This insecticide has been found to be compatible with commonly used fungicides, miticides, liquid 

fertilizers, and other commonly used insecticides. The physical compatibility of this product may vary with different sources of 

pesticide products and local cultural practices. Any tank mixture which has not been previously tested must be prepared on a 

small scale (pint or quart jar). using the proper proportions of pesticides and water to ensure the physical compatibility of the 

White grub larvae such as: 

I I 

Japanese beetle larvae, 

Chafers, 

PhylJophaga spp., 

beetle, 

" 

I I 

0.23 -0.30 

(7.0 - 9.0 ml) 

10.0-12.8 

(0.625 - 0.8 pints) 

fruit and nut trees. 

Ornamental and Non-bearing Fruit and Nut trees, Shrubs, Flowers, and Groundcover 

SOIL APPLICATION 

Pests USE RATES 

For control of: For TREES : 

Adelgids 

Aphids Use the following rates as a function of tree diameter at breast 

Black vine weevil larvae height {DB H): 

Emerald ash borer1 

Eucalyptus longhorned borer1 

Flatheaded borers (includino Bronze birch and Alder)l 

Apply 0.05·0.20 fl oz (1.5 - 6.0 ml) per inch of trunk diameter 

"'BH). 

49 

54
[SUB-LABEL B: NURSERY, GREENHOUSE and LANDSCAPE ORNAMENTALS] 

Ornamental and Non-bearing Fruit and Nut trees, Shrubs, Flowers, and Groundcover 

SOIL APPLICATION 

Pests USE RATES 

Japanese beelles 

Lace bugs You may use the higher rate (0.2 fl oz) only 

Leaf beetles (including Elm and Viburnum) for trees greater than 15 DBH to control the following pests: 

Leafhoppers/Sharpshooters 

Leafminers Asian longhomed beetle 

Mealybugs Emerald Ash Borer 

Pine tip moth larvae Eucalyptus longhorned borer 

Psyllids Bronze birch borer 

Royal palm bugs Alder borer 

Sawfly larvae 

Soft scales Restriction: Do not apply more than 12.8 fI oz (0.4 Ib of active 

White grub larvae ingredient) per acre per year. 

Whiteflies 

Diameter at Breast Height (O.S.H.) = is measured at 4.5 feet 

from the Qround. 

SHRUBS: per foot of shrub height 

0.05 - 0.10 fluid ounces (1.5 - 3.0 ml) 

FLOWERS and GROUDCOVER: 

0.23 - 0.30 fluid ounces (7.0 9.0 ml) ! 1000 FT2 

For suppression of: Use the higher rates listed in the TREES, SHRUBS, FLOWERS Armored scales 

Thrips and GROUNDCOVER sections above. 

Application methods for TREES and SHRUBS 

Soil injection: Mix the required dosage in sufficient water to inject an equal amount of solution in each hole. Maintain a low 

pressure and use sufficient solution for distribution of the liquid into the treatment zone. Keep the treated area moist for 7 to 10 

days. DO NOT use less than 4 holes per tree or shrub. 

S ecific Soilln'ection methods for trees and lar e shrubs: 

GRID System: Holes must be spaced on 2.5 foot centers, in a grid pattern, extending to the drip line of the tree. 

CIRCLE System: Apply in holes evenly spaced in circles, (use more than one circle dependent upon the size of the tree) 

beneath the drip line of the tree extendino in from that line. 

BASAL System: Space injection holes evenly around the base of the tree trunk no more than 6 to 12 inches out from the 

base. 

Soil Drench: Unifonnly apply the dosage in no less than 10 gallons of water per 1,000 square feet as a drench around the base 

of the tree or shrub, directed to the root zone. Remove plastic or any other barrier that will stop solution from reaching the root 

zone. 

Remarks 

Application to trees already heavily infested with listed borers may not prevent the eventual loss of the trees due to existing 

oest damaoe and tree stress. 

Restrictions 

DO NOT apply using Soil Injection methods in Nassau or Suffolk Counties of New York. 

DO NOT aooly more than 0.8 pints (O.4lbs AI) per acre per year. 

Ap lication methods for FLOWERS and GROUNDCOVER 

Apply as a broadcast treatment and incorporate into the soil before planting or apply after plants are established. Irrigate 

immediately followino application to established plants. 

Pomefruits: Apple, Crabapple, Loquat, Mayhew, Pear, Pear (oriental), Quince 

FoLIAR APpLICATION 

Pests USE RATES 

For control of: 

Aphids {except Wooly apple aphid)1 0.75 fluid ounces (22 ml)! 100 gallons 3.0 fluid ounces! Acre 

Leafhoppers!Sharpshooters2 of water (gO ml) 

LeafminersJ 

50 

55
[SUB-LABEL B: NURSERY, GREENHOUSE and LANDSCAPE ORNAMENTALS] 

Apply the specified dosage as a as needed after petal-fall is 

" per acre 

on a standard II i for large trees. 

, For control of Rosy apple aphid, II caused by the pest. 

2 For late season (preharvest) Ii. apply this product while most Leafhoppers are In the nymphal stage 

3 For first generation Leafminer control, make I application as soon as petal-fall IS complete Greatest Leafmlner control will 

result from the earliest possible application. For 2nd and succeeding generations of leafmmer, optimal control IS obtained from 

applications made early in the adult flight against egg and early instar larvae. A 2nd application may be required 10 days later if 

severe pressure continues or if generations are overlapping. A single appllcation may result in suppression only. This product 

will not control late state larvae. 

4 For control of Mealybugs, insure good spray coverage of the trunk and scaffolding limbs or other resting sites of the 

, , 

ounces per acre i 

DO NOT than 5 applications. 

Allow 10 or more days between applications. 

Allow at least 7 days between last application and harvest. 

DO NOT use on Pomefruits grown for commercial production. 

Ornamental Pecan trees 

Yellow pecan aphid 

Black aphid 

Pecan I I 

Pecan 

0.75 fluid ounces (22 ml) 1100 gallons 

of water 

Ii as i 

3.0 fluid ounces! Acre 

(gOml) 

maybe to achieve control. I Thorough uniform coverage of foliage is necessary for optimal 

control. of an organosilicone-based spray adjuvant at a rate not to exceed the adjuvant manufacturer's use rate may 

per acre volume present. rate 

" 

DO more than 3 applications per year. 

Allow 10 or more days between applications. 

DO NOT use on Pecans grown for commercial production. 

in California I 

Grapes 

FOLIAR APPLICATION 

Pests USE RATES 

For control of: 0.75 fluid ounces (22 ml) !100 gallons 1.5 fluid ounces/ Acre 

Leafhoppers/Sharpshooters 

Mealybugs 

of water (45 ml) 

Application methods 

Apply specified dosage of this product as a foliar spray using 200 gallons of water per acre. 

Restrictions 

51 

56
[SUB-LABEL B: NURSERY, GREENHOUSE and LANDSCAPE ORNAMENTALS) 

DO NOT apply more than 3.0 fluid ounces (0.09 Ibs AI) per acre per year. 

Allow 14 or more days between applications. 

Annlication can be made un to and includinn the da of harvest. 

STORAGE AND DISPOSAL 

DO NOT contaminate water, food or feed by storage or disposal. 

PESTICIDE STORAGE: Store in a cool, dry place and in such a manner as to prevent cross contamination with other 

pesticides, fertilizers, food, and feed. Store in original container and out of the reach of children, preferably in a locked 

storage area. Handle and open container in a manner as to prevent spillage. If the container is leaking, invert to prevent 

leakage. If container is leaking or material spilled for any reason or cause, carefully dam up spilled material to prevent 

runoff. Refer to Precautionary Statements on label for hazards associated with the handling of this material. DO NOT walk 

through spilled material. Absorb spilled material with absorbing type compounds and dispose of as directed for pesticides 

below. In spill or leak incidents, keep unauthorized people away. 

PESTICIDE DISPOSAL: Wastes resu~ing from the use of this product may be disposed of on site or at an approved waste 

disposal facility. 

CONT AtNER DISPOSAL: 

Nonrefillable container: 00 NOT reuse or refill this container. Triple rinse (or equivalent) promptly after emptying. Empty 

the remaining contents into application equipment or a mix tank and drain for 10 seconds after the flow begins to drip. Fill 

the container 1/4 full with water and recap. Shake for 10 seconds. Pour rinsate into application equipment or a mix tank or 

store rinsate for later use or disposal. Drain for 10 seconds after the flow begins to drip. Repeat this procedure two more 

times. 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. Plastic containers are also disposable by incineration, or, if allowed by State and 

local authorities, by buming. If bumed, stay out of smoke. 

WARRANTY DISCLAIMER 

The directions for use of this product must be followed carefully. TO THE EXTENT CONSISTENT WITH 

APPLICABLE LAW, (1) THE GOODS DELIVERED TO yOU ARE FURNISHED "AS IS" BY MANUFACTURER 

OR SELLER AND (2) MANUFACTURER AND SELLER MAKE NO WARRANTiES, GUARANTEES, OR 

REPRESENTATiONS OF ANY KIND TO BUYER OR USER, EITHER EXPRESS OR IMPLIED, OR BY USAGE OF 

TRADE, STATUTORY OR OTHERWISE, WITH REGARD TO THE PRODUCT SOLD, INCLUDING, BUT NOT 

LIMITED TO MERCHANTABILITY, FITNESS FOR A PARTiCULAR PURPOSE, USE, OR ELIGIBILITY OF THE 

PRODUCT FOR ANY PARTICULARTRADE USAGE. UNINTENDED CONSEQUENCES, INCLUDING BUT NOT 

LIMITED TO INEFFECTIVENESS, MAY RESULT BECAUSE OF SUCH FACTORS AS THE PRESENCE OR 

ABSENCE OF OTHER MATERIALS USED IN COMBINATION WITH THE GOODS, OR THE MANNER OF USE 

OR APPLICATION, INCLUDING WEATHER, ALL OF WHICH ARE BEYOND THE CONTROL OF 

MANUFACTURER OR SELLER AND ASSUMED BY BUYER OR USER. THIS WRITING CONTAINS ALL OF THE 

REPRESENTATIONS AND AGREEMENTS BETWEEN BUYER, MANUFACTURER AND SELLER, AND NO 

PERSON OR AGENT OF MANUFACTURER OR SELLER HAS ANY AUTHORITY TO MAKE ANY 

REPRESENTATION OR WARRANTY OR AGREEMENT RELATiNG IN ANY WAY TO THESE GOODS. 

LIMITATION OF LIABILITY 

TO THE EXTENT CONSISTENT WITH APPLICABLE LAW, IN NO EVENT SHALL MANUFACTURER OR SELLER 

BE LIABLE FOR SPECIAL, INCIDENTAL, OR CONSEQUENTIAL DAMAGES, OR FOR DAMAGES IN THEIR 

NATURE OF PENALTIES RELATING TO THE GOODS SOLD, INCLUDING USE, APPLICATION, HANDLING, 

AND DISPOSAL. TO THE EXTENT CONSISTENT WITH APPLICABLE LAW, MANUFACTURER OR SELLER 

SHALL NOT BE LIABLE TO BUYER OR USER BYWAY OF INDEMNIFICATION TO BUYER OR TO CUSTOMERS 

OF BUYER, IF ANY, OR FOR ANY DAMAGES OR SUMS OF MONEY, CLAIMS OR DEMANDS WHATSOEVER, 

RESULTiNG FROM OR BY REASON OF, OR RISING OUT OF THE MISUSE, OR FAILURE TO FOLLOW LABEL 

WARNINGS OR INSTRUCTIONS FOR USE, OF THE GOODS SOLD BY MANUFACTURER OR SELLER TO 

BUYER. ALL SUCH RISKS SHALL BE ASSUMED BYTHE BUYER, USER, OR ITS CUSTOMERS.TOTHE 

52 

57
[SUB-LABEL B: NURSERY, GREENHOUSE and LANDSCAPE ORNAMENTALS] 

EXTENT CONSISTENT WITH APPLICABLE LAW, BUYER'S OR USER'S EXCLUSIVE REMEDY, AND 

MANUFACTURER'S OR SELLER'S TOTAL LIABILITY SHALL BE FOR DAMAGES NOT EXCEEDING THE COST 

OF THE PRODUCT. 

If you do not agree with or do not accept any of directions for use, the warranty disclaimers, or limitations 

on liability, do not use the product, and return it unopened to the Seller, and the purchase price will be 

refunded. 

[EPA approval date] 

53 

58
Hi Mike, 

RE: 9468~UG - Signed Reg letter and stamped label D 

Autumn Metzger to: Mike Kellogg 01/11/2011 03:32 PM 

As promised here are your signed letter and stamped label. Please let me know if you have any questions. 

thanks, 

9468·43 signed registration letter and stamped labell·11·11.pdl 

Autumn Metzger 

Biologist 

U.S. Environmenlal Prolection Agency 

Insecticide~Rodenticide Branch 

Registration Division (7505P) 

1200 Pennsylvania Ave. NW 

Washing1on, DC 20460 

Tel: 703305·5314 

Fax: 703 308~5433 

Email: metzger.autumn@epa.gov 

Mike Kellogg 

From: 

To: 

Date: 

Subject: 

Autumn, 

Autumn, Revised label attached. 

Mike Kellogg <Mike@PyxisRC.com> 

Autumn Metzger/DC/USEPNUS@EPA 

01/10/201112:30 PM 

RE: 9468~UG 

Revised label attached. 

Regards, 

Mike Kellogg 

Pyxis Regulatory Consulting, Inc. 

.~,",··/·""YV"'0x~{.;·:.:;):F:>S 

dltjgJ%1.W61g{!!P}j~1RM 

f{' 8U\?m \-SS l ~ 

<;~ irK\jU"J 

From: Metzger.Autumn@epamail.epa.gov [Metzger.Autumn@epamail.epa.gov] 

Sent: Monday, January 10, 2011 6:48 AM 

To: Mike Kellogg 

Subject: 9468~UG 

Hi Mike, 

the PM found a few more minor things that we can add to the letter, however 

she noticed something else fairly'big so she cannot stamp off until fixed. 

59
On page 34, the title is "Commerical Livestock production facilities" however 

it should read "Commerical Poultry production facilities" as that it the only 

known use for imidacloprid like that. I talked to and they are also 

going to be changing this on their parent product to match. 

Please fix this last thing and we will be ready to stamp tomorrow. thanks. 

autumn[attachment "009468-000UG.20110110.Impale label.v4.pdf" deleted by 

Autumn Metzger!DC!USEPA!USl 

60

*Product ingredient source information may be entitled to confidential treatment*
Autumn, 

RE: comments for 9468-UG 

Mike Kellogg 10: Au1umn Metzger 

Revised labels attached both in Word and .PDF. 

any additional changes. 

Regards, 

Mike Kellogg 

Pyxis Regulatory Consulting, Inc. 

4110 136th St. NW 

Gig Harbor, WA 98332 

T: 253-853-7369 

F: 253-853-5516 

--»--Original Message-----

01/05/2011 03:26 PM 

v:'.(s v'o Y\!\ \ '3 '5 If'\, 

~ '(YC( \j V ""2----

Let me know should you require 

From: Metzger.Autumn@epamail.epa.gov [mailto:Metzger.Autumn@epamail.epa.gov] 

Sent: Wednesday, January 05, 2011 9:15 AM 

To: Mike Kellogg 

Subject: RE: comments for 9468-UG 

Hey, 

I'm sorry I thought I responded to this and was waiting on your label -

however I see that I never sent that message! 

I think something more generic than re-listing each rate would work 

best. Maybe like "Use the higher rate as listed per section" or 

something like that. And yes, go ahead and replace on page 43 too. 

thanks! 

Autumn Metzger 

Biologist 

U.S. Environmental Protection Agency 

Insecticide-Rodenticide Branch 

Registration Division (7505P) 

1200 pennsylvania Ave. NW 

·Washington, DC 20460 

Tel: 703 305-5314 

Fax: 703 308-5433 

Email: metzger.autumn@epa.gov 

1

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I believe it means to use the higher rate specified in the sections of 

the table for TREES, SHRUBS or FLOWERS and GROUNDCOVER depending on 

where the armored scales or thrips appear. So we could replace "Use the 

high rate" with: 

TREES: 

SHRUBS: 

FLOWERS 

0.20 fl oz (6.0 mll per inch of truck diameter 

0.10 fluid ounces (3.0 ml) 

and GROUNDCOVER: 0.30 fluid ounces (9.0 ml) / 1000 FT2 

Do you agree? The same language "Use the high rate" also appears in the 

table on pg. 43. Should we replace that language as well? 

Regards, 

Mike Kellogg 

Pyxis Regulatory consulting, Inc. 

4110 136th St. NW 

Gig Harbor, WA 98332 

T: 253-853-7369 

F: 253-853-5516 

-----original Message-----

From: Metzger.Autumn@epamail.epa.gov 

62
mailto :Metzger .Aut:;,umn@epamail.epa.govJ 

Sent: Wednesday, D'e:'ce'mber:r:;i"g",>;'<'20l:0,:<J2"i:S'9> J?tt;,',,& To: Mike Kellogg "-',' ,',"'", ,-

Subject: RE: comments for 9468-UG 

Hi Mike, 

Only a few minor things missed we can add in the amendment letter. 

However, on page 50 in the box continued from previous page for " 

nursery, greenhouse and landscape ornamentals" the last rate section for 

"Suppression of: Armored scales and Thrips" says "use the high 

rate" .... what does that mean? we need an actual rate here or something 

that makes more sense than that. Sorry I didn't notice this before and 

I'm sure you just copied what was on the other label but see if you can 

figure out what they meant and we can fill that in. 

thanks, 

Autumn Metzger 

Biologist 

U.S. Environmental Protection Agency 

Insecticide-Rodenticide Branch 

Registration Division (7505P) 

1200 Pennsylvania Ave. NW 

washington, DC 20460 

Tel: 703 305-5314 

Fax: 703 308-5433 

Email: metzger.autumn@epa.gov 

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Ah, OK, I understand. I've attached both a .PDF 

version of the label with comments incorporated. 

should you require anything further and hope you 

Regards, 

Mike Kellogg 

Pyxis Regulatory Consulting, Inc. 

4110 136th St. NW 

Gig Harbor, WA 98332 

T: 253-853-7369 

F: 253-853-5516 

-----Original Message-----

From: Metzger.Autumn@epamail.epa.gov 

mailto:Metzger.Autumn@epamail.epa.gov] 

Sent: Wednesday, December 29, 2010 4:55 AM 

To: Mike Kellogg 

Subject: RE: comments for 9468-UG 

Hi Mike, 

Hope you had a good holiday. 

version and word 

please let me know 

have a Happy New Year! 

I actually just cut and pasted all the exact wording needed into your 

crop box (and deleted the footnote since it was included above) . 

you say two exceptions ... is there another one? 

Autumn Metzger 

Biologist 

U.S. Environmental Protection Agency 

Insecticide-Rodenticide Branch 

64
Registration Division (7505P) 

1200 Pennsylvania Ave. NW 

Washington, DC 20460 

Tel: 703 305-5314 

Fax: 703 308-5433 

Email: metzger.autumn@epa.gov 

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65
IRE: comments for 9468-UG 

---------------------------------------------------------I 

Autumn, 

I've finished incorporating your changes with two exceptions. In two 

instances there is a table footnote that reads, "Use higher rate for 

larger trees (over 8" D.B.H.) or for difficult to control insects or for 

trees with severe infestations." 

In the comment you had stated you had exact language that needs to be 

added and you would send it separately. 

Regards, 

Mike Kellogg 

Pyxis Regulatory Consulting, Inc. 

4110 136th St. NW 

Gig Harbor, WA 98332 

T: 253-853-7369 

F: 253-853-5516 

From: Metzger.Autumn@epamail.epa.gov 

mailto:Metzger.Autumn@epamail.epa.gov] 

Sent: Monday, December 20, 2010 7:30 AM 

To: Mike Kellogg 

Subject: RE: comments for 9468-UG 

Hey Mike, 

sorry this took so long! We have updated (again for the 9th time) the 

language for doubling the rate for the tree drench and I had to wait 

until that was finalized to add it onto yours. 

Please see attached my mark-ups on your label. We had already went the 

first part together. 

The last thing -- we changed the max rate that read "per season" to read 

"per year" in many of the crop categories. Please change them back to 

"per season." After thinking about it some more, I think Ithat it makes 

more sense to keep them "per crop" so we'll know the "crop max" and then 

at the beginning of the label you already listed the "per year max". 

Sorry to make you have to re-do those. 

Please send me a CLEAN copy of the updated label whenever you get a 

chance. I am in most all of the holiday season (or working from home) so 

just email me if you have questions and I can call you back incase I am 

not in the office. 

thanks! 

Autumn 

66
I.m located in washington State so I'm 3 hours behind you. 

Regards, 

Mike Kellogg 

Pyxis Regulatory Consulting, Inc. 

4110 136th St. NW 

Gig Harbor, WA 98332 

T: 253-853-7369 

F: 253-853-5516 

From: Metzger.Autumn@epamai1.epa.gov 

mailto:Metzger.Autumn@epamail.epa.gov] 

Sent: Monday, November 22, 2010 11:25 AM 

To: Mike Kellogg 

Subject: comments for 9468-UG 

Hi Mike, 

I haved finished reviewing 9468-UG. Do you have any time this wednesday 

to go over them? I would allot 30-40 minutes for this. I am available 

most of the day so propose any time between 10am-3pm EST that works for 

you. If Wednesday is not good we can do it next week after the holiday. 

thanks, 

Autumn 

[attachment "20100921 Impale label submitted to EPA.doc" removed by 

Autumn Metzger/DC/USEPA/US] 

[attachment "009468-xxxxx.20100921.Impale label.pdf" removed by Autumn 

Metzger/DC/USEPA/US] 

[attachment "009468-000UG.20101229.Impale label.v2.pdf" deleted by 

Autumn Metzger/DC/USEPA/US] [attachment "20101229 Impale label with EPA 

20101130 and 20101220 comments incorporated.doc" deleted by Autumn 

Metzger/DC/USEPA/US] 

67
PRIA 2 - 21 Day Content Screen Review Worksheet 

(EP AlOPP Use Only) 

Ci 3/23/09 

21 Day Screen Start Date: __ "-- /-~.2;,:;:Z __ -.;/~D,-______ .,,-

Experts In-Processing Signature: i? ."<-- Date '7 :2 '/-10 Fee Paid: Yes ~ Division management contacted on issues No Yes Date ______ _ 

EPA Reg. Number: 1 Wp~ -U & EPA Receipt Date: '1-7..7... -/0 

Items for Review Yes No 

1 Application Form (EPA Form 8570-1 )(link to fornl) signed & complete 

including package type X 

Confidential Statement of Formula all boxes completed, fann signed, and X2 

dated (EPA Form 8570-4) (Link to form) 

a) All inerts (link to http://www.epa.gov/opprdOOllinerts/), yes no 

including fragrances, approved for the proposed uses (see 

Footnote A) N 0 ~N' ·tt;; 

3 Certification with Respect to Citation of Data (EPA Fann 8570-34) (Link to 

fmID) completed and signed (N/A if 100% repack) 

Certificate and data matrix consistent 

If applicant is relying on data that are compensable, is the offer yes no 

to pay statement included. (see Footnote B) 

If applicable, is there a letter of Authorization for exclusive use only. 

Formulator's Exemption Statement (EPA Fonn 8570~27) (Link to fonn) 

4 completed and signed (N!A if source is unregistered or applicant owns the X. teclmical) 

Data Matrix (EPA Form 8570-35) (Link to fonn) both internal and external 

copies (PR 98-5) (Link to PR 98-5) completed and signed (N/A if 1 00% 

repack) 

5 yes no 

a) Selective Method (Fee category experts use) 

b) Cite-All (Fee category experts use) ~ ...•.•.. ' ....•. 

,"i;:' ,-

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

5 Copies of Label (link to httl2:!!www.el2a.gov/ol2I!feadlllabelin1!lIrm/) 

6 (Electronic labels on CD are encouraged and guidance is available)( link to X http://www.epa.gov/pesticides/regulating/registering/submissions/index.htm#labels 

) 

1 

N/A* 

7-. 

X 

y68
7 Is the data package consistent with PR Notice 86-5 (link to PRN 86-5) X 

Notice of Filing (link to 

8 h ttQ:/ /www.eQ3.gov/Qesticides/regulatimYtolerance I,.!etitions.htm) included 

with petitions (link to 

http://www.cpa.~ov/pesticides/regulating!tolerances.htm) -,.L. 

9 If applicable for conventional applications, reduced risk rationale (link to ;;-L-, http:lhY\ll/y't'.epa.gov/opprdOOllworkplanJreducedrisk.html) 

Required Data (link to 

h ttI! :flwww. ella. go v /Qcsticides/regulatin f!.! data reguirements.htm) and/or 

data waivers. See Footnote C. 

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

10 

2 

69
Comments: 

!\Jo 

* N/A - Not Applicable 

Footnotes 

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

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

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

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

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

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

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

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

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

application withdrawn within the 21 day period. othef\vise. the Agency will reiect the 

application as described below. 

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

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

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

3 

70
site [link to http://www.epa.gov/opprdOOllinerts/lists.html] and if the inert is not 

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

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

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

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

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

delays. 

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

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

Branch (lIAB) at ipelisbranch@epa.gov and resolve the issue. Copies of the 

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

new inerts except PIP inelis are reviewed by lIAB. The HAB should also be contacted 

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

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

Microbial Pesticides Branch [Link to 

http://v..'Ww.epa.gov/oppbppdl!biopesticides!contacts bppd.h tm ] . 

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

additional infonnation such as an alternate name of the ineli, CAS number or other 

information [link to http://www.epa.gov/opprdOOI/inerts/tips.pdf] must also be included 

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

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

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

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

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

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

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

Agency will reject the application. 

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

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

Unapproved Inerts Identified on CSFs 

All applications except conventional new products and PIPs 

Once an unapproved inert 1S identified on a CSF, the Agency will contact the 

applicant with the following options: 

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

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

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

approved for the application's uses; or 

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

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

request an extension in the PRIA decision review timeframe to accommodate 

the inert review/approval process; 

4 

71
3. Withdraw the application (the Agency retains 25% of the full fee for the fee 

category estimated); or 

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

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

25% of the full fee of the category identified. 

Conventional New Product Applications 

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

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

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

following options: 

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

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

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

approved for the application's uses; or 

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

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

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

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

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

Agency within the 21 day content review period.) 

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

category estimated); or 

Ifnone ofllie above options is selected and implemented during the 21-day 

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

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

PIP Applications 

When the Biopesticide and Pollution Prevention Division identifies an 

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

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

options: 

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

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

approved; or 

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

unapproved inert. If an inert ingredient tolerance exemption petition is 

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

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

Agency will discuss harmonizing the timeframe for both actions. 

5 

72
3. Withdraw the application (the Agency retains 25% ofthe full fee for the fee 

category estimated); or 

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

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

the fee. 

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

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

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

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

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

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

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

should be submitted with the study waiver. 

6 

73
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 

WASHINGTON, D,C, 20460 

September 23,2010 

OPP Decision Number: D-440095 

EPA File Symbol or Registration Number: 9468-UG 

Product Name: IMPALE 

EPA Receipt Date: 22-Sep-2010 

EPA Company Number: 9468 

Company Name: RITIER CHEMICAL, LLC 

JANELLE KAY 

PYXIS REGULATORY CONSULTING, INC. 

RITTER CHEMICAL, LLC 

4110 136TH STREET, N.W, 

GIG HARBOR, W A 98332-

OFFICE OF 

PREVENTION, PESTICIDES AND 

TOXIC SUBSTANCES 

SUBJECT: Receipt of Registration Application Subject to Registration Service Fee 

Dear Registrant: 

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

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

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

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

the Pesticide Registration Improvement Act. 

The Action has been identified as Action Code: R300 

NEW PRODUCT;ME-TOO PRODUCT FAST TRACK; 

No additional payment is due at this time. 

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

Ombudsman at (703) 308-9362. 

Z 

Resources Management Division 

I 

74
;I 

IFee for Servicel {882636=-

~---------------~---~-~-, 

This package includes the following 

@ New Registration 

° Amendment 

I::: Studies? [J Fee Waiver? 

for Division 

OAD 

OBPPD 

@RD 

Risk Mgr. OJ 'L [] vol pay % Reduction: -- ________________________________ ~ ______ .~ ___________ J ___________________________ _ __ J I~---------~---------------------------------------------------------~--------~------------i 

I Receipt No. s-I 882636 1 ' 

EPA File Symbol/Reg. No. 1 9468-UG 1 

Pin-Punch Date: 1 9/22/2010 1 

,---~~-~~-~------~---------------- ------------------------------------------------------------------------ ---------------j 

~, 

L This item is NOT subject to FFS action. 

'-------.t\ction-C-o-de-:-------l :-ParentiCh i Id Decisions :i 

Requested: 1 ~ 300 

, Granted: 1123DiJ 

'LAmount Due: $ 1/ '5b~ i I 

¥ I:;~::!;t-=; ~ll~I" U"'M,ed loert ~~ R · ~ I q eVlewer: I () I-t ,A <:, '" , Date: -«3-/0 I ----'-----"'-'c:::.L..:"---_ 

Remarks: J 00 % I"e. f4 C i<-

75
'fth;t<frf?¢t: 1-", 

ReC,elPt DescriPtion: " 

-~OO~%~,",op:':C:kOO"f:.C':':9"i&O:":':",:o~,;_7"O,:,Op:,o,""Cct"-----------c----

r 

Print leUer 

Enter More Information 

Tracking 

",~Rec'e1Pftontent ,- "LA: 

I,R"";2":-'-'c-!=-····"···~···"'···""'·cS····.'f'f=··· =~ 

l'.pe<u."~ •..•... 

{' 

View(Edit 

76

*Product ingredient source information may be entitled to confidential treatment*
FEE FOR SERVICE 

77
Mike Kellogg 

From: 

Sent: 

To: 

paygovadmin@maiLdoc.twaLgov 

Tuesday, September 21, 2010 11 :44 AM 

Mike Kellogg 

Subject: Pay,Gov Payment Confirmation 

THIS IS AN AUTOMATED MESSAGE. PLEASE DO NOT REPLY. 

Your transaction has been successfully completed. 

Transaction Summary 

Application Name: PRIA Service Fees 

pay.gov Tracking ID: 251HBSH3 

Agency Tracking 1D: 74139955748 

Account Holder Name: Mike Kellogg 

Transaction Type: Sale 

Transaction Amount: $1,365.00 

Billing Address: 4110 136th St. NW 

City: Gig Harbor 

State/Province: WA 

Zip/Postal Code: 98332 

Country: USA 

Card Type: American Express 

Card Number: ***********1049 

Transaction Date: Sep 21, 2010 2:43:32 PM 

Decision Number: 

Registration Number: 9468-xx 

Company Name: Ritter Chemical~ LLC 

Company Number: 9468 

Action Code: R300 

1 

78
-- SfI r""d l",rnJctio -~ m -'"= 'mm A. rovo ,v1R NO. '07 fI~" I 2.28-95 

Unitod Stot05 Registration opp Idontifier Number 

&EPA Environmental Protection Agency Amendment 

Washington, OC 20460 Other 

Application for Pesticide ~ Section I 

1. companlrroduct Numbor 2. EPA Product Manager 3. Proposed Classification 

9468- b V. Eagle [ i] Nono o Restricted 

4. Company/Product INomo) PM. 

Ritter Chemical, LLC I Impale 1 

5. Namo and Addres5 of Applicont (Ineludl1 ZIP Cadtl/ 6. Expedited Reveiw. In accordance with FIFRA Section 3{c){3) 

Ritter Chemical, llC (b){i), my product is similar or identical in composition and labeling 

Clo Pyxis Regulalory Consulting, Inc. to: 

4110 136th SI. NW EPA Reg. No. 

Giq Harbor. WA 98332 D Choe/( if lhis;s 8 ntlw addrl1s$ Product Name 

Section - II 

0 Amondment - Explain bolow. U Finol printed labels In ropsonsa to 

Ag~mcv latter datad 

0 Rasubmission in respons& to Agancv lonor dotod [2] "Mo Too" Applicetion. 

0 Notification - Exploin below. 0 Other· Explain bolow. 

Explanation: Use odditional pllj}tI(sl if necessary. (For 58ction I ond Soction ILl 

This application falls under R300 (44) since it is a 100% repack of a registered end~use product and no data is being submitted. 

The fee due is $1365 and the decision timeline is 3 months. A receipt of pre~payment from pay.gov is enclosed with this 

application for registration. Should you have any questions, please contact me at (email) Mike@PyxisRC.com or (phone) 253~ 

853-7369. 

Section - III 

,. M"ariol Thi" Product Will Be Packaged In: 

Child-Rasistont Packaging Unit Peckaging Water Solublo Packaging 2. Typo of Container 

t2l ::' t2]Y", t2l Y" EJMot., .f No 

,/ Plastic 

No Glass 

• CfNtification must If ~Yas~ No. por If ~Yes~ No. por Papor 

Unit Packaging wgt. contoinor Packogo wgt container Other (Spacify) be submitted 

I 

3. location of Not Contonts Informotion 4. SilOls) Retail Contoiner 5. locotion of lobol Oiroction, 

[{! lebel U Containar 1, 2.5, 30 gallon t=J On Lobol ------- On Labelin~ .ccompony;ng product 

6. Menner in Which labol is Affixed to Product lJ lithograph D Other 

of Paper ~Iued Stonci ad 

Section -IV 

t. Contllct Point {CamplDtD Iltlms d/rtlc«V below for idtlntificsrron of rndMdulII ro bD contacrod, if ntlCDssary. ro proCflSS this spplicfltion./ 

Namo Titla Tlliephone No. (Include Area Code) 

Michael Ke)logg Agent 253-853-7369 

Certification 6. O_<ltll; .... I-"Iicetion 

I certify that tho statemonts I have modo on this form ond all ettachmonts thereto are trua, accurate and con.plet~: :- Ra"f,.i":t:j 

I ocknowlodge thet any knowlingllv flliso or misleading statemont moy be punishable by fine or imprisonment or _ (Stamped) both undor IIpplicoble law. -- 2.::;:._ It)A~ 3. Title 

Agent 

4. Tvped Name // ----- 5. Oate 

Michael Kellogg g/al/f(] .. EPA Form 8570-1 lRav. 3-941 ProvlOu, odmona are obsolote. White· EPA FUe Copy longm.J) Yanow· Applicant Copy 

79

*Product ingredient source information may be entitled to confidential treatment*
PYXl" REGULATORY CONSULTING, .NC. 

4110 136!h St. NW 

Gig Harbor, WA 98332 

COURIER DELIVERY 

Venus Eagle (PM 1) 

Document Processing Desk (REGFEE) 

Office of Pesticide Programs (7504P) 

u.s. Environmental Protection Agency 

Room S-4900, One Potomac Yard 

2777 S. Crystal Drive 

Arlington, VA 22202-4501 

September 21,2010 

RE: Ritter Chemical, LLC - Impale (EPA Reg. No. 9468- ) 

Application for a New Pesticide Registration 

Dear Ms. Eagle, 

Phone: 253-853-7369 

Fax: 253-853-55\6 

www.PyxisRC.com 

On behalf of Ritter Chemical, LLC please find the enclosed application materials for registration of 

Impale, an end-use product containing imidac10prid as the active ingredient. 

In support ofthi5 application, we submit the following documents: 

1. Application for a New Pesticide Registration (EPA Fonn 8570~ I) 

2. Receipt of PRIA pre~payment from pay.gov 

3. Confidential Statements of Formula (Basic and Alternate Formulation dated September 21, 2010) 

4. Five (5) copies of the proposed labeling 

5. One copy of the proposed label on CD 

6. Certification With Respect to Label Integrity 

7. Formulator's Exemption Statement (EPA Form 8570~27) 

8. Letter of Authorization 

We trust you will find this application complete and in compliance with the requirements for registration 

1mder FIFRA. Please feel free to call me if you have any questions or need any additional information. 

Sincerely, 

~J)~ Michael Kellogg 

Enclosures 

cc: J. Smith; Ritter Chemical, LLC 

80
Form approved. OMS No. 2070-0060. 2070-0057. <!u, 0-Ot07, 2070-0122, 2070-0164. 

a EPA 

United States 

Environmental Protection Agency 

Washington, DC 20460 

Formulator's Exemption Statement 

(40 CFR 152.85) 

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

Ritter Chemical, LLC 9468-

P.O. Box 430974 Product Name 

Houston, TX 77243 Impale " 

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

09/2112010 

As an authorized representatiue of the applicant for registration of the product identified above. I certify that: 

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

lmidacloprid 

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

formulation or repackaging another product which contains that actiue ingredient which is registered under FIFRA Section 3. is purchased by 

us from another person and meets the requirements ot 40 CFR section 158 .50(e)(2) or (3). 

(3) Indicate by checking (A) or (8) below which paragraph applies: 

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

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

paragraph (1). 

OR 

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

accurate and contains the information required on the current CSF. 

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

Source 

Active Ingredient Product Name Registration Number 

Imidaclopdd 

n 

~;iitl/~1 Name and Tille Date 

Michael Kellogg / Agent " "-;V;7( lie} 

Ef'A Form 8570-27 (Rev. 06-2004)/ CoPy 1 - EPA 

CoPy 2 - Applicant copy 

81

*Product ingredient source information may be entitled to confidential treatment*
~3§)and 301 

100% identical [repack): ~or NO [circle one) 

{If yes, it's a 100% repac - en product chemistry, acute tOXICity and efficacy data 

are not required} 

Data on Group and A and B must be submitted - Group A and 8 can not be cited. 

Data 

Guideline Group A: Product Chemistry Data submitted 

No. Study Title Yes No 

830.1550 Product Identity & Composition 

Description of mater'lols used to produce the 

830.1600 product 

830.1650 Description of formulation process 

830.1670 Discussion on the formation of impurities 

830.1700 Preliminary analysis 

830.1750 Certified limits [158.345) 

830.1800 Enforcement analytical method 

Data 

Guideline Group B: Product Chemistry Data submitted 

No. Study Title Yes No 

830.6302 Color 

830.6303 Physical State 

830.6304 Odor 

Oxidation/Reduction [Chemical 

830.6314 incompatibility) 

830.6315 Flammability 

830.6316 Explodability 

830.6317 Storaqe stability 

830.6319 Miscibility 

830.6320 Corrosion Characteristics 

830.6321 Dielectric Breakdown YoltoQe 

830.7000 pH 

830.7100 Viscosity 

830.7300 DensBy 

1 

82
Certification with Respect to Label Integrity 

version: 9/11/02 

I certify that the information (including, but not limited to, text, tables, and graphics) 

contained in the electronic file identified below by file name and submitted with this 

certification is the same information as that on the paper copies of these documents 

included with this submission. 

IPROPOSED LABEL 

Date Submitted 

EPA Registration # to EPA Electronic file name 

9468-xx September 21, 009468-xxxxx.20 1 00921.1mpaJe label.pdf 

2010 

I certify that the statements that I have made on this form are true, accurate, and 

complete. I acknowledge that any knowingly false or misleading statements may be 

punishable by fine or imprisonment or both under applicable law. 

Date 

Michael Kellogg 

Name (typed) 

Agent 

Title 

83
There is an ELECTRONIC LABEL for this action 

You can use Acrobat to compare the e-Iabel to the previous version (and find the 

changes). You can also use Acrobat to mark-up the e-Iabel with your comments. 

If e-Iabel was submitted via 

CD-ROM with paper application 

then you will find e-Iabel in 

Electronic Label library 

If thO e-/abolls not found In tile ELL tlllm if was probably nol named 

correctly and could nol be entered hlta tho ELL. However, the file 

can be re/rievodfrom tile CD Which Is reteinedby tho Ffont End. 

or If e-Iabel was submitted via 

XML E-Submission (no paper) 

then you will find e-Iabel in 

Documentum 

See overview of processing e-Iabels on other side of this sheet. 

If you have any questions on e-Iabels, please contact one of your division e-Iabel experts: 

AD 

BPPD 

RD 

Willie Abney 

Renae Whitaker 

Tracy Lantz 

Tom Harris 

308-1689 

308-7003 

308-6415 

308-9423 

84
Pages 85-86 - *Confidential Statements of Formula may be entitled to confidential treatment*