EPA Reg. No. 86363-20

1
Material Sen t for Dat a Extractio n

Reg. #

Description:

D Material(s ) Sent to Data Extraction Contractors

12 Ne w Stamped Labe l Dated

D Notificatio n Date d

D Ne w CSF(s ) Dated

D Other :

D Decisio n #:

Other Action/Comment s

File this coversheet and attached material s in the jacket. I t mus t be

well organized and clipped together, NOT STAPLED. The n give th e

jacket wit h th e coversheet and materials to staff i n the Information

Services Center (ISC ) (Roo m S-4900). I f a jacket i s full or only

available as an image, pleas e file material s i n a new jacket an d bring i t

down to the (ISC). Fo r further information pleas e call 703-605-0716 .

Reviewer: Maggi e Rudic k

Phone: 703-347-025 7 Division : RD/H B

Date:

2
U.S. ENVIRONMENTA L PROTECTIO N

AGENCY

Office o f Pesticide Programs

Registration Divisio n (7505P)

Ariel Rio s Buildin g

1200 Pennsylvani a Ave. , N W

Washington, D.C . 2046 0

NOTICE O F PESTICIDE:

x Registratio n

_ Reregistratio n

(under FIFRA, as amended )

EPA Reg . Number:

86363-20

Date of Issuance :

2011

Term of Issuance :

Name of Pesticide Product:

KT Propanil 4SC

Name and Address o f Registrant (includ e ZIP Code):

Scott Baker

Lighthouse Product Services

c/o Kaizen Technologies

1555 Mai n Street, Suite A3-205

Windsor, CO 80550

Note: Changes i n labeling differing i n substance fro m tha t accepted i n connection wit h this registration mus t be submitted to and accepted by the

Registration Divisio n prior t o use of the label i n commerce. I n any correspondence o n this product alway s refe r to the above EPA registration number .

On the basis of information furnished b y the registrant, the above name d pesticide is hereby registered/reregistered unde r the Federal Insecticide,

Fungicide and Rodenticid e Act. Registration is in no way to be construed a s an endorsement or recommendation o f this product by the Agency. I n order

to protect health and the environment, the Administrator, on his motion, may at any time suspend or cancel the registration of a pesticide in accordanc e

with the Act. Th e acceptance o f any name i n connection with the registration of a product under this Act is not to be construed as giving the registrant a

right to exclusive use of the name or to its use if it has been covered b y others.

The Basic Confidentia l Statement o f Formula (CSF) date d 08/05/201 1 is acceptable .

This product is registered i n accordance wit h FIFRA section 3(c)(5 ) provide d tha t you:

1. Submi t and/or cite all data require d for registration review/reregistration of your product when the

Agency require s all registrants o f similar products to submit data.

2. Mak e the following labe l revision:

a. Revis e "EPA REG . NO. 86363-xx" to "EPA REG . NO. 86363-20."

b. Assur e that the establishment numbe r and net contents ar e also added t o the final printed

label.

3. Shoul d you wish to retain the company's website on your label, then please b e aware tha t the

language presente d i n the website become s labelin g under the Federal Insecticid e Fungicide and

Rodenticide Act and is subject to the false and misleading provisions of 40 CFR 156.10(a)(5) .

Therefore shoul d the Agency find or if it is brought to our attention that a website contain s claims

substantially differing from the EPA approved sectio n 3 registration, the website wil l be referred

to the EPA's Offic e of Enforcement and Compliance Assurance .

4. Submi t one (1) copy of the revised final printed label for the record.

If these conditions are not complied with, the registration wil l be subject to cancellation in accordance wit h

FIFRA sec . 6(e). You r release fo r shipment of the product constitutes acceptanc e o f these conditions. A

stamped cop y of the labe l is enclosed fo r your records.

3
If you have any questions regarding this notice, pleas e contac t Maggie Rudic k of my staff at 703-347-0257 o r

rudick.maggie@epa.gov.

Signature of Approving Official:

Kable Bo Davis, Produc t Manager 25

Herbicide Branch

Registration Divisio n (7505P)

Date:

OCT 3 1 201 1

4
KT Propanil 4 SC

Herbicide

For Postemergence Weed Control in Rice

Active Ingredient:

Propanil: 3', 4'-Dichloropropionanilide 41.4 %

Other Ingredients: 58.6 %

TOTAL: 100.00 %

This product contains 4 Ib. of active ingredient pe r gallon.

EPA Reg. No. 86363

EPA Est. No.

Net Contents:

KEEP OUT OF REACH OF CHILDREN

CAUTION

First Aid

If inhaled:

• Mov e person to fresh air.

• I f person i n not breathing, call 911 or an ambulance, then give artificia l

respiration, preferabl e mouth-to-mouth, i f possible.

• Cal l a poison control center or doctor for further treatment advice.

If on skin or clothing :

• Tak e off contaminated clothing.

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

• Cal l a poison control center or doctor for treatment advice .

If in eyes:

• Hol d eye open and rinse slowly and gently with water for 15-20 minutes .

• Remov e contact lenses, if present, after the first 5 minutes, then continue rinsing

eye.

• Cal l a poison control center or doctor for treatment advice.

If swallowed:

• Cal l a poison control center or doctor immediately for treatment advice.

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

• D o not induce vomiting unless told to do so by a poison control center or doctor.

• D o not give anything by mouth to an unconscious person.

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

doctor, or going for treatment.

Manufactured for:

Kaizen Technologies LLC

1555 Main Street

Suite A3-206

Windsor, CO 80550

102611

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Precautionary Statements

Hazards to Humans and Domestic Animals

Caution. Avoid contact with skin, eyes, or clothing. Avoid breathing vapor or spray mist.

Wash thoroughl y wit h soa p an d water afte r handling . Remov e contaminate d clothin g

and wash before reuse.

Personal Protective Equipment (PPE)

Some materials that are chemical-resistant t o this product are natural rubber > 14

mils. Fo r more information, follow instructions in Supplement Three of PR Notice 93-7.

If you want more options, follow the instructions for category A on an EPA chemical

category selection chart.

Mixers, loaders, and other handlers cleaning up spills or equipment or

otherwise exposed to the concentrate and handlers removing an unrinsed probe

must wear:

• Coverall s over long-sleeve shir t and long pants,

• Chemical-resistan t glove s made of any waterproof materials,

• Chemical-resistan t footwear plus socks,

• Chemical-resistan t headgear, i f overhead exposure, and

• Chemica l resistan t apron, when mixing and loading.

• Protectiv e eyewear if the system operates under pressure .

Pilots and handlers removing a triple rinsed probe must wear:

• Long-sleeve d shirt and long pants,

• Shoe s plus socks, and

• Chemical-resistan t gloves made of any waterproof material such as butyl rubber,

nitrile rubber, or neoprene rubber (all >14 mils)

See Engineering Controls for additional requirement s and options.

User Safety Requirements

Follow manufacturer's instructions for cleaning/maintaining PPE . If no such

instructions for washables exist, use detergent and hot water. Keep and wash PPE

separately from other laundry. Discard clothing or other absorbent materials that have

been drenched or heavily contaminate d with this product's concentrate. D o not reuse

them.

Engineering Controls:

Mixers and loaders must either:

(1) use a closed system that meets the requirements liste d in the Worker Protectio n

Standard (WPS) for dermal protection of agricultural pesticides [4 0 CFR

170.240(d)(4)],OR

(2) Use the probe system described below:

PROBE SYSTEM

Specific requirements for use of the probe closed mixing/loading system :

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Remove plug from bung of drum containing this product only when drum is sitting on the

ground or on a secure level platform, with the bung end of the drum pointed up. Do not

pour this product from its drum. Transfe r product from the drum to the mixing tank by

use of suction hose connected at one end to the suction pump on the mixing tank and

connected at the other end to a probe (dip tube) that is inserted through the bung

opening into the drum. D o not handle the probe or bung in a manner that allows

dripping or splattering o f the product onto yourself or any other person. Do not touch the

portion of the probe that has been in contact with this product until after the probe has

been triple rinsed with water. If all of the product is removed from the drum, then triple

rinse the probe while it remains inside the drum.

UN-RINSED PROBES

If an un-rinsed probe must be removed from the drum, then use an anti-drip flange, and

immediately transfer the probe into a container of rinse water. The anti-drip flange must

be designed to remove excess propanil product from the probe as it is extracted from

the drum. Tak e the following steps if the probe must be disconnected from the suction

hose before both the probe and the hose have been triple rinsed:

(1) Equip the probe end of the hose with a shut off valve,

(2) Install a dry break coupling between the valve and the probe,

(3) Close the shut-off valve before disconnecting the probe.

ALL TRANSFER SYSTEM S

In addition, mixer s and loaders using all systems must: wear the personal protective

equipment require d in the PPE section of this labeling for mixers and loaders, wear

protective eyewear, if the system operates under pressure, and when using a system

that meets the requirements i n the WPS as a closed system or using a probe system

when the probe is not removed, chemical-resistant footwear must be provided, be

immediately available , and be used in an emergency, such as a broken package, spill,

or equipment breakdown .

All systems must be capable of removing the pesticide from the shipping container and

transferring it into mixing tanks and/or application equipment. At any disconnect point,

the system must be equipped with a dry disconnect or dry couple shut-off device that is

warranted by the manufacturer t o minimize drippage .

Flaggers: Human flagging i s prohibited. Flaggin g to support aerial application is limited

to use of the Global Positioning System (GPS) or mechanical flaggers.

Enclosed Cabs for Aerial Applicators: Pilot s must use an enclosed cockpit that meets

the requirements liste d in the Worker Protectio n Standard (WPS) for agricultural

pesticides [4 0 CFR 170.240(d)(6)] .

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User Safety Recommendations

Users should:

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

• Remov e clothing/PPE immediately i f pesticide get s inside. Then wash thoroughly and put

on clean clothing.

• Remove PPE immediately afte r handling this product. Wash the outside of gloves before

removing. As soon as possible, wash thoroughly and change into clean clothing.

Environmental Hazards

This pesticide i s toxic to fish and aquatic invertebrates . Do not apply directly to water

except as specified on this label. Do not contaminate water when cleaning equipment

or disposing of equipment washwaters or rinsate.

This chemical ha s properties and characteristics associated with chemicals detected

in groundwater. The use of this chemical prior to flooding may result in shallow

groundwater contamination due to cracks in the subsoil of the rice paddy.

This produc t ma y contaminat e wate r throug h runof f following rainfal l event s an d b y

seepage through levees . Runoff of this product will be reduced by avoiding application

when rainfal l i s forecasted t o occu r withi n 4 8 hours . Levee s shoul d b e constructed

with adequate time prior to chemical application s o that they are compacted to reduce

seepage and to hold a 3 to 6 inch flood

Notice: Read the entire label. Use only according to label directions. Before

using this product, read Warranty Disclaimer, Inherent Risks of Use, and

Limitation of Remedies elsewhere on the label. If terms are unacceptable, return

at once unopened.

Directions for Use

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

labeling.

Read all Directions for Use carefully before applying.

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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Agricultural Use Requirements

Use this product only in accordance with its labeling and with the Worker Protectio n

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. I t 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. Th e requirements i n 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 interva l

(REI) of 24 hours.

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:

• Coverall s over long-sleeve shirt and long pants

• Chemical-resistan t gloves made of any waterproof materials,

• Chemical-resistan t footwear plus socks,

• Protectiv e eyewear

Storage and Disposal

Do not contaminate water, food, or feed by storage or disposal.

Pesticide Storage: Ground all metal containers when transferring product. Protect from

freezing. I f stored below 32F and crystals form, warm to 72F for 24 hours, periodicall y

shaking or rolling container to reconstitute.

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

spray mixture or rinsate is a violation of Federal Law. Wastes resulting from the use of this

product must be disposed of on site or at an approved waste disposal facility. I f these

wastes cannot be disposed of by use according to label instructions, contact your State

Pesticide or Environmental Control Agency, or the Hazardous Waste representative at the

nearest EPA region office for guidance.

Container Handling: NONREFILLABLE CONTAINER (EQUA L TO OR LESS THAN 5

GALLONS): Do not reuse or refill this container. Triple rinse container (or equivalent)

promptly after emptying. Triple rinse 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 % full with water and recap. Shake for 10 seconds. Pour rinsate into

application equipment o r 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. Offer for

recycling, if available.

NONREFILLABLE CONTAINER (GREATE R THAN 5 GALLONS): Do not reuse or refill

this container. Triple rinse container (or equivalent) promptly after emptying. Triple rinse as

follows: Empty the remaining content s into application equipment or a mix tank. Fill the

container % 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. Turn the container over onto its

other end and tip it back and forth several times. Empt y the rinsate into application

equipment o r a mix tank or store rinsate for later use or disposal. Repeat this procedure

Page 5 of 19

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two more times. Offer for recycling, if available.

REFILLABLE CONTAINER: Refill this container with pesticide only . D o not reuse this

container for any other purpose. Cleaning the container before final disposal is the

responsibility o f the person disposing of the container. Gleaning 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 mix tank. Fill the

container about 10 percent full with water. Agitate vigorously or recirculate water with the

pump for 2 minutes. Pou r or pump rinsate into application equipment o r rinsate collection

system. Repeat this rinsing procedure two more times.

Product Information

KT Propanil 4 SC for postemergence wee d control in rice is formulated as a

suspension concentrate containing 4 Ib active ingredient per gallon. KT Propanil 4 SC

is not a hormone-type herbicide , but kills susceptible weeds by direct contact action.

For this reason, thorough coverage of emerged weeds is essential for best results. KT

Propanil 4 SC has no preemergence or residual herbicidal activity. Only weeds that

have emerged and are exposed at time of application will be controlled. Apply KT

Propanil 4 SC only to fields that have been drained of floodwater. KT Propanil 4 SC is

most effective if applied when susceptible grasses and broadleaf weeds are small and

growing actively under favorable soil moisture and weather conditions. Early weed

control removes weed competition from the rice crop, saves moisture, and generally

contributes to increased yields.

Read Mixing and Equipment labe l instructions before application. When tank

mixing, always read all individual manufacturers' labels. In interpreting all labels for

the tank mixture, the most restrictive situations must apply.

Chemigation: Do not apply this product through any type of irrigation syste m

SPRAY DRIFT MANAGEMENT

Avoiding spray drift at the application site is the responsibility of the applicator and the

grower. The interaction of many equipment and weather related factors determine the

potential for spray drift. The applicator and the grower are responsible for considering

all these factors when making decisions .

The following drift management requirement s must be followed to avoid off-target drift

movement from aerial applications to agricultural field crops.

1. Th e distance of the outer most operating nozzles on the boom must

not exceed 3/4 the length of the wingspan or 90% of the rotor blade

diameter.

2. Nozzle s must always point backward parallel with the air stream and

never be pointed downwards more than 45 degrees .

Where states have more stringent regulations, they should be followed.

Page 6 of 19

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The applicator should be familiar with and take into account the information covered in

the following Aerial Drift Reduction Advisory.

Aerial Drift Reduction Advisory

Information on Droplet Size: The most effective way to reduce drift potential is to

apply large droplets. The best drift management strategy is to apply the largest

droplets that provide sufficient coverage and control. Applying larger droplets reduces

drift potential, but will not prevent drift if applications are made improperly, or under

unfavorable environmenta l conditions (see Wind, Temperature and Humidity, and

Temperature Inversions).

Controlling Droplet Size:

• Volum e - Use high flow rate nozzles to apply the highest practical spray

volume. Nozzles with higher rated flows produce larger droplets.

• Pressur e - Use the lower spray pressures recommended for the nozzle.

Higher pressure reduces droplet size and does not improve canopy

penetration. When higher flow rates are needed, use higher flow rate

nozzles instead of increasing pressure.

• Numbe r of Nozzles - Use the minimum number of nozzles that provide

uniform coverage.

• Nozzl e Orientation - Orienting nozzles so that the spray is released

parallel to the airstream produces larger droplets than other orientations

and is the recommended practice . Significant deflection from horizontal

will reduce droplet size and increase drift potential.

• Nozzl e Type - Use a nozzle type that is designed for the intended

application. With most nozzle types, narrower spray angles produce larger

droplets. Consider using low-drift nozzles. Solid stream nozzles oriented

straight back produce the largest droplets and the lowest drift.

Application Height: Applications should not be made at a height greater than 10 feet

above the top of the largest plants unless a greater height is required for aircraft

safety. Making applications at the lowest height that is safe reduces exposure of

droplets to evaporation and wind.

Swath Adjustment: When applications are made with a cross wind, the swath will be

displaced downwind. Therefore, on the up and downwind edges of the field, the

applicator must compensate for this displacement b y adjusting the path of the aircraft

upwind. Swath adjustment distance should increase with increasing drift potential

(higher wind, smaller drops, etc.).

Wind: Drift potential is lowest between wind speeds of 2-10 mph. However, many

factors, including droplet size and equipment type, determine drift potential at any

given speed. Application should be avoided below 2 mph due to variable wind

direction and high inversion potential. Note: Local terrain can influence wind patterns.

Every applicator should be familiar with local wind patterns and how they affect spray

drift.

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Temperature and Humidity: When making applications i n low relative humidity, set

up equipment t o produce larger droplets to compensate for evaporation. Drople t

evaporation is most severe when conditions are both hot and dry.

Temperature Inversions: Applications shoul d not occur during a local, low level

temperature inversio n because drift potential is high. Temperature inversion s restric t

vertical air mixing, which causes small suspended droplets to remain i n a

concentrated cloud. This cloud can move in unpredictable directions due to the light

variable winds common during inversions. Temperature inversions are characterized

by increasing temperature with altitude and are common on nights with limited cloud

cover and light to no wind. They begin to form as the sun sets and often continue into

the morning. Their presence can be indicated by ground fog; however, i f fog is not

present, inversions can also be identified by the movement of the smoke from a

ground source or an aircraft smoke generator. 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 indicates good vertical air mixing.

Sensitive Areas: The pesticide should only be applied when the potential for drift to

adjacent sensitive areas (e.g., residential areas , bodies of water, known habitat for

threatened or endangered species, non-target crops) is minimal (e.g. , when wind is

blowing away from the sensitive areas).

Spray Drift Restrictions for All States

• Appl y only when the wind speed is less than or equal to 10 mph at the

application site .

• Appl y as a medium or coarser spray (ASAE standard 572).

• Fo r ground applications, apply using a nozzle height of no more than 4 feet

above the ground or crop canopy.

• Fo r aerial applications, do not apply by air if drift can occur to sensitive

nontarget crops or plants that are within 10 0 feet of the application site. Do

not release spray at a height greater than 10 feet above the ground or crop

canopy. The boom length must not exceed 75% of the wingspan or 90% of

the rotor blade diameter. D o not make any type of application int o

temperature inversions .

For Use on Rice Grown in California Only

Restrictions

• Preharves t Interval: Do not appl y this product within 60 days of rice

harvest.

• Chemigation : Do not apply this product through any type of irrigation

system.

• D o not appl y more than a maximum of 6 quarts of KT Propanil 4 SC (6 Ib

active ingredient) pe r acre in a single application or exceed 8 quarts of KT

Propanil 4 SC (8 Ib of active ingredient) pe r acre total dosage per season.

• I n California: Use KT Propanil 4 SC only where rice fields are

completely draine d or a minimal amoun t of water remains. I f high water

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level is desired, re-floo d field after 12 hours and before 7 days after

treatment. Thi s will discourage new weed infestations .

• D o not appl y this product to any crop other than rice. KT Propanil 4 SC

will cause injury to most crops except cereal grains and perennial grasses.

• D o not apply this product (directly or indirectly) to wild rice (Zizania

spp.).

• Avoi d drift or accidental application from turning aircraft on cotton,

soybeans, corn, safflower, seedling legumes , vegetables, orchards,

vineyards, gardens, shrubs and ornamentals. Once applied, K T Propanil 4

SC does not release fumes hazardous to nearby crops.

• D o not apply to fields nor drain water from treated fields into areas where

commercial catfish or crayfish (crawfish) farming is practiced.

• D o not graze treated fields or feed treated forage within 60 days of the

last application.

• D o not rotat e treated land to other crops or transplant to crops other than

rice for 60 days following treatment o f this product.

• D o not appl y this product within 14 days before or after carbamate or

organophosphate insecticid e applications. Otherwise, serious injuries to

rice may occur.

• Wate r drained from treated ric e fields must not be used to irrigate

other crops or released within V* mile upstream of a potable water

intake in flowing water (e.g. river, stream, etc,) or within % mile of a

potable water intake in a standing body of water, such as a lake,

pond, or reservoir.

• D o not appl y when weather conditions favor drift from area to be

treated.

• D o not plan t or transplant crops in the treated area for at least 60 days

following an application of this product .

Emergency Release Provisions

Do not discharge water from treated rice paddies in California following treatment ,

unless excessive rainfal l completely submerges th e rice crop and forces prematur e

release, for:

• 7 days in dry seeded ric e in California

• 7 days for water-seeded ric e in California

Weeds Controlled

Annual sedges

Barnyardgrass

 a

Crabgrass

Early watergrass

 a'D

Junglerice

 a

Late watergrass

 a'D

Ricefield bullrush

Rice flatsedg e

Smallflower umbrell a plant

Cyperus spp .

Echinochloa crus-galli

Digitaria spp .

Echinochloa oryzoides

E. colonum

Echinochloa phyllopogon

Scirpus mucronatus

Cyperus iria

Cyperus difformis

Page 9 of 19

13
a

 I n isolated instances, biotypes of barnyardgrass/watergrass may develop that

cannot be effectively controlled by propanil alone. Where these biotypes are known or

suspected to be present, and are found in a mixed weed population in which KT

Propanil 4 SC is effective, tank mix KT Propanil 4 SC at labeled rate with other rice

herbicides that are recommended for control of barnyardgrass/watergrass (up to the 3

leaf stage).

b

 Application s to early and late watergrass made past the 4 leaf stage will result in

partial control.

Timing and Dosage Recommendations

Early Timing and Rates

Apply KT Propanil 4 SC when a satisfactory stand of rice has been established that

will tolerate flooding. The amount of KT Propanil 4 SC to apply depends upon the

growth stage and condition of the target weeds. KT Propanil 4 SC is most effective if

applied when susceptible grasses and broadleaf weeds are small and actively growing

under favorable soil moisture and weather conditions. Use a higher rate in the

recommended rat e range for heavy weed infestations, weeds in advanced stages of

growth, or when growing conditions ar e less than optimum. Emergency treatment s

made to weeds in advanced growt h stages, such as when grass weeds are tillering,

must occur at least 60 days before harvest.

For best results, apply KT Propanil 4 SC at the rate of 3 to 4 quarts (3 to 4 Ib active

ingredient) pe r acre when the grasses are actively growing in the 1 to early 4 leaf

stage. This rate will also control many seedling broadlea f and aquatic weeds.

Generally, thi s will be 15 to 25 days after planting. I n order to insure satisfactory weed

control, do not apply less than 3 quarts of KT Propanil 4 SC per acre in a single spray

application.

Mid-Timing and Rates

KT Propanil 4 SC can be applied at the rate of 4 to 6 quarts (4 to 6 Ib active

ingredient) pe r acre to actively growing grasses in the 4 to 6 leaf and early tillering

stage, or when they are in the 2 to 4 leaf stage but stressed under dry soil conditions.

Generally, thi s will be 20 to 30 days after planting.

Use of Surfactants: The addition of a crop oil concentrate at 1 to 2 pints per acre, or

other 80% active nonionic surfactant at a rate of 1 to 2 pints per 100 gallons of spray

mixture, i s recommended .

Rescue Timing and Rates

Apply KT Propanil 4 SC at the rate of 5 to 6 quarts (5 to 6 Ib active ingredient) in 15

gallons of spray per acre for emergency control of older tillering grass. Generally, this

will be.30 to 40 days after planting. I f the field is already flooded, the water should be

lowered or drained before spraying to expose more of the grass and weeds.

Emergency treatment should be considered as a salvage operation only and cannot

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14
be relied upon for total control of grass and weeds.

Mixing Directions

KT Propanil 4 SC will disperse more quickly if water temperature is SOT or warmer.

Use only clean water for spraying. With the pump and agitator running, slowl y add the

recommended amount of KT Propanil 4 SC into a partially filled mix tank. The jet or

tank agitators must be positioned to create a rippling or rolling action on the liquid

surface and to provide complete agitation at the bottom of the tank, preventing dead

spots where the material can accumulate. A centrifugal pump is suggested to provide

additional propeller shear action for dispersing and mixing this product. To avoid

foaming, keep filling and bypass lines below the liquid surface. KT Propanil 4 SC must

be completely dispersed and mixed prior to application.

If a tank mixture i s to be applied, always conduct a compatibility test prior to use by

mixing proportional amounts of all spray ingredients in a test vessel (jar). The order of

addition to water should be dry flowables or wettable powders first, flowables second,

liquid formulations third, and crop oil concentrate last. Allow for each material to go

into solution prior to the addition of the next material. Shak e the mixture vigorously

and allow it to stand for fifteen minutes. Rapid precipitation of the ingredients and

failure to re-suspend when shaken indicates that the mixture is incompatible and

should not be applied.

As each material i s added to the spray mixture, always allow for complete mixin g

before adding the next ingredient. Add crop oil concentrate last and continue agitation

while filling the mixing tank to the desired spray volume.

Do not ad d KT Propanil 4 SC directly to the spray tank of aircraft. Once properly

dispersed i n mix tank, pump spray mixture to aircraft spray tank (include rinsate from

mix tank). To ensure uniformity of sprays, maintain good agitation throughout

application.

Application Equipment

Aircraft

Fixed wing aircraft or helicopters should have well-designed spray systems that

produce a uniform pattern of medium-fine spra y droplets. Apply KT Propanil 4 SC in

no less than 10 gallons of total spray per acre with boom-nozzle sprayers. Increase

volume to 12 to 15 gallons per acre for larger or denser stands of grass or during

periods of low humidity.

The optimum effective spray swath width depends on operating conditions and type of

aircraft being used . For uniform spray coverage with fixed-wing aircraft or helicopter,

spray swath width should not exceed the width of wing span or rotor plus 10%.

Measure the swaths accurately for flagging.

Ground Sprayers

Use standard low-pressure herbicide boom sprayers equipped with flat fan nozzles.

Page 1 1 of 19

15
Use nozzle sizes that deliver a medium-fine drople t in 15 to 20 gallons total spray per

acre at 40 to 50 psi and at ground speeds not in excess of 3 to 4 mph. Adjust boom

height so nozzle spray patterns meet uniformity. Avoid raising boom too high.

Flush al l equipment with clear water after each day's use. Clean all equipment,

including nurs e tanks, used for KT Propanil 4 SC, with detergent wash followed by a

water rinse, before and after spraying other pesticides or other crops.

Crop Tolerance and Growing Conditions

All leading commercial varieties of rice are exceptionally tolerant to KT Propanil 4 SC.

A temporary yellowing or tip burn of rice may be noted after treatment, but new growth

is normal. Severe leaf burn and partial killing of rice may occur if the product is applied

when rice is under stress and in a weakened growth condition due to disease or insect

infestations, excessive soil salts, over-watering, or prolonged drought and extremely

hot weather. Growers are cautioned not to spray under such conditions and/or when

maximum daily temperatures have been or are expected to exceed 100°F.

Effect of Climatic Conditions and Cultural Practices on Weed Control

Field and Seedbed Preparation

Fields should be accurately leveled and contoured and have well-prepared seedbed s

free of clods. Such conditions encourage uniform and rapid emergence of rice, grass

and broadleaf weeds, allowing more accurate tinning and coverage of KT Propanil 4

SC sprays for optimum weed control.

Water Management

Before application of KT Propanil 4 SC, drained or dry planted fields should be flushed

as often as necessary to prevent drying and crusting. Flushing encourages uniform

emergence an d vigorous growth of grass, broadleaf weeds and rice, which is essential

for optimum weed control. Flushing of fields should occur when weeds and rice are

actively growing at time of treatment. Make sure the field is drained prior to treatment

so that grasses and broadleaf weeds are fully exposed. Weeds that are partially

submerged i n standing water at time of application will not be satisfactorily controlled.

Treated fields should be flooded before a second infestation of grass develops. To

prevent additional grass weed seed from germinating, rice fields should be flooded

within 24 hours after spraying, or as soon as possible after 24 hours.

Temperature

The temperature a few days before and after applying KT Propanil 4 SC has an

important effect on the weed-killing activity . The activity increases as daily maximum

temperatures increas e above 75°F and decreases as the daily maximum

temperatures decline below 75°F. Do not apply KT Propanil 4 SC when maximum

temperatures hav e been or are expected to stay below 65°F or exceed 100°F. Less

than optimum temperature at time of application is not critical so long as the

temperature exceeds 75eF during the day. .

Page 12 of 19

16
Relative Humidity and Rain

Grasses and weeds are more responsive to KT Propanil 4 SC during periods of high

humidity when the foliage is moist or covered by dew. When the humidity is very low,

spray tends to evaporate before reaching weed foliage. Fo r best results under low

relative humidity conditions , increase spray volume to 12 to 15 gallons per acre. Do

not spra y if rain is expected within 8 hours to avoid loss of deposited spray and

herbicide adsorption b y the weeds.

Wind

Do not appl y when the wind speed exceeds 10 mph to avoid drift hazard to sensitive

crops and the possibility of uneven (streaked) applications. ,

Compatibility With Other Chemicals

Tank mix applications of KT Propanil 4 SC with other herbicides, insecticides, spray

adjuvants, or liquid fertilizers ma y reduce crop tolerance and/or weed control or impair

mixing properties . Use of these products in tank mix applications with KT Propanil 4

SC is done at the user's risk.

Liquid Fertilizer: Premixing this product in a ratio of 1 part KT Propanil 4 SC to 2

parts water is recommended prio r to mixing with liquid fertilizer.

Adverse Reaction to Insecticides

Rice plants may be severely injured or killed if KT Propanil 4 SC is applied in tank mix

combinations or sequentially befor e or after certain insecticides. D o not combine KT

Propanil 4 SC with carbamate insecticides suc h as carbaryl, etc., or

organophosphorus insecticides (suc h as malathion and methyl parathion, etc). Do not

apply any of the carbamate or organophosphorus insecticides to rice fields within 14

days before or after KT Propanil 4 SC. Do not use carbamate or systemic

organophosphorus insecticides on rice fields to be treated with KT Propanil 4 SC.

Do not apply KT Propanil 4 SC to rice fields planted with rice seed treated with bird

repellents containing methiocarb. Consult local Extension specialist for current

recommendations of approved insecticides on rice

For Use on Rice Grown in Southern United States Only

Arkansas, Louisiana, Mississippi, Missouri, Texas

Restrictions

• Preharves t Interval: Do not apply this product within 60 days of rice

harvest.

• Chemigation : Do not apply this product through any type of irrigation

system.

• D o not appl y more than a maximum of 6 quarts of KT Propanil 4 SC (6 Ib

active ingredient) pe r acre in a single application or exceed 8 quarts of KT

Propanil 4 SC (8 Ib of active ingredient) per acre total dosage per season.

Page 1 3 of 19

17
• D o not plan t or transplant crops in the treated area for at least 60 days

following application.

• D o not apply this product to any crop other than rice. KT Propanil 4 SC

will cause injury to most crops except cereal grains and perennial grasses.

• D o not appl y this product (directl y or indirectly) to wild rice (Zizania

spp.).

• Avoi d drift or accidental application from turning aircraft on cotton,

soybeans, corn, safflower, seedling legumes , vegetables, orchards,

vineyards, gardens, shrubs and ornamentals. Once applied, K T Propanil 4

SC does not release fumes hazardous to nearby crops.

• D o not apply to fields nor drain water from treated fields into areas where

commercial catfish or crayfish (crawfish) farming is practiced.

• D o not graze treated fields or feed treated forage within 60 days of the

last application .

• D o not rotate treated land to other crops or transplant to crops other than

rice for 60 days following treatment of this product.

• D o not appl y this product within 14 days before or after carbamate or

organophosphate insecticide applications . Otherwise, serious injuries to

rice may occur.

• Wate r drained from treated rice fields must not be used to irrigate

other crops or released within Y2 mile upstream of a potable water

intake in flowing water (e.g. river, stream, etc,) or within 7z mile of a

potable water intake in a standing body of water, such as a lake,

pond, or reservoir.

• D o not apply when weather conditions favor drift from area to be

treated.

Emergency Release Provisions

Water holding (discharge) interval s for flood water from treated rice paddies following

treatment i n the southern United States (AR, LA, MS, MO, and TX):

• Fo r delayed flood (water-seeded) ric e grown south of Interstate Highway 10 from

the Texas/Louisiana border to Houston and east of State Highway 35 from

Houston to Port Lavaca- Flood water must be held for 10 days after application,

unless excessive rainfall completely submerge s the rice crop and forces

premature release. For Texas rice grown in areas north or west of these

boundaries, the water holding interval will be 7 days.

• Fo r delayed flood (water-seeded) ric e in the southern Louisiana south of

Highway 14 - Floo d water must be held for 15 days after propanil application,

unless excessive rainfal l completely submerge s the rice crop and forces

premature release. For delayed flood (water-seeded) ric e in Louisiana, north of

the Highway 14 boundary, the water holding interval is 7 days.

• Fo r rice in all other parts of the southern United States not mentioned above -

Flood water must be held for 7 days after application unless excessive rainfal l

Page 14 of 19

18
completely submerges the rice crop and forces premature release.

Weeds Controlled

KT Propanil 4 SC provides selective postemergenc e control of the following weeds in

rice:

Annual sedges

Barnyardgrass

 a

Beakrush (spearhead)

Broadleaf signalgras s

Crabgrass

Curly dock

Foxtail

Goosegrass

Gulfcockspur

Hemp sesbania (coffeebean)

Hoorahgrass

Junglerice

 a

Mexicanweed

Paragrass

Red root pigweed

Redweed

Rice flatsedge

Smallflower umbrellaj>lan t

Spikerush (wiregrass )

Texas panicum

Watergrass

 a

Woolly croton

Cyperus spp.

Echinochloa crus-galli

Rhynchospora corniculata

Bracharia platyphytia

Digitaria spp.

Rumex crispus

Setaria spp.

Eleusine indica

Echinochloa crus-pavonis

Sesbania herbacea

Fimbristylis miliaceae

E. colonum

Caperonia castanaefolia

Panicum purpurascens

Amaranthus retroflexus.

Melochia corchorifolia

Cyperus iria

Cyperus difformis

Eleocharis spp.

Panicum texanum

Echinochloa spp.

Croton spp.

a

 I n isolated instances, biotypes of barnyardgrass/watergrass may develop that

cannot be effectively controlled by propanil alone. Where these biotypes are known or

suspected to be present, and are found in a mixed weed population in which KT

Propanil 4 SC is effective, tank mix KT Propanil 4 SC at labeled rate with other rice

herbicides that are recommended for control of barnyardgrass/watergrass (up to the 3

leaf stage).

Timing and Dosage Recommendations

Early Timing and Rates

Apply KT Propanil 4 SC when a satisfactory stand of rice has been established tha t

will tolerate flooding. The amount of KT Propanil 4 SC to apply depends upon the

growth stage and condition of the target weeds. KT Propanil 4 SC is most effective if

applied when susceptible grasse s and broadleaf weeds are small and actively growing

under favorable soil moisture and weather conditions. Use a higher rate in the

recommended rat e range for heavy weed infestations, weeds in advanced stages of

growth, or when growing conditions are less than optimum. Emergenc y treatments

made to weeds in advanced growth stages, such as when grass weeds are tillering,

must occur at least 60 days before harvest.

Page 15 of 19

19
For best results, appl y KT Propanil 4 SC at the rate of 3 to 4 quarts (3 to 4 Ib active

ingredient) pe r acre when the grasses are actively growing in the 1 to early 4 leaf

stage. This rate will also control many seedling broadlea f and aquatic weeds.

Generally, this will be 15 to 25 days after planting.

Mid-Timing and Rates

KT Propanil 4 SC can be applied at the rate of 4 to 6 quarts (4 to 6 Ib active

ingredient) pe r acre to actively growing grasses in the 4 to 6 leaf and early tillering

stage, or when they are in the 2 to 4 leaf stage but stressed unde r dry soil conditions .

Generally, this will be 20 to 30 days after planting.

Use of Surfactants: The addition of a crop oil concentrate at 1 to 2 pints per acre, or

other 80% active nonioni c surfactant at a rate of 1 to 2 pints per 100 gallons o f spray

mixture, i s recommended.

Rescue Timing and Rates

Apply KT Propanil 4 SC at the rate of 5 to 6 quarts (5 to 6 Ib active ingredient) in 15

gallons of spray per acre for emergency control of older tillering grass. Generally, this

will be 30 to 40 days after planting. If the field is already flooded, the water should be

lowered or drained before spraying to expose more of the grass and weeds.

Emergency treatmen t shoul d b e considered as a salvage operation onl y and cannot

be relied upon for total control of grass and weeds.

Mixing Directions

KT Propanil 4 SC will disperse mor e quickly i f water temperature is 50°F or warmer.

Use only clean water for spraying. With the pump and agitator running, slowly add the

recommended amount of KT Propanil 4 SC into a partially filled mix tank. The jet or

tank agitators must be positioned to create a rippling or rolling action on the liquid

surface and to provide complete agitation at the bottom of the tank, preventing dea d

spots where the material can accumulate. A centrifugal pump is suggested to provide

additional propeller shear action for dispersing and mixing this product. To avoid

foaming, keep filling and bypass lines below the liquid surface. KT Propanil 4 SC must

be completely disperse d an d mixed prior to application .

If a tank mixture is to be applied, always conduct a compatibility test prior to use by

mixing proportional amounts of all spray ingredients in a test vessel Qar). The order of

addition to water should be dry flowables or wettable powder s first, flowables second ,

liquid formulations third, and crop oil concentrate last. Allow for each material to go

into solution prior to the addition of the next material. Shak e the mixture vigorously

and allow it to stand for fifteen minutes. Rapid precipitation of the ingredients and

failure to re-suspend when shaken indicates that the mixture i s incompatible and

should not be applied

As each material is added to the spray mixture, always allow for complete mixing

before adding the next ingredient. Add crop oil concentrate las t and continue agitatio n

Page 16 of 19

20
while filling the mixing tank to the desired spray volume.

Do not add KT Propanil 4 SC directly to the spray tank of aircraft. Once properly

dispersed in mix tank, pump spray mixture to aircraft spray tank (include rinsate from

mix tank). To ensure uniformity of sprays, maintain good agitation throughout

application.

Application Equipment

Aircraft

Fixed wing aircraft or helicopters should hav e well-designed spra y systems tha t

produce a uniform pattern of medium-fine spra y droplets. Apply KT Propanil 4 SC in

no less than 10 gallons o f total spray per acre with boom-nozzle sprayers. Increas e

volume to 12 to 15 gallons per acre for larger or denser stands of grass or during

periods of low humidity.

The optimum effective spray swath width depends on operating conditions and type of

aircraft being used. For uniform spray coverage with fixed-wing aircraft or helicopter,

spray swath width should not exceed the width of wing span or rotor plus 10% .

Measure the swaths accurately for flagging.

Ground Sprayers

Use standard low-pressure herbicid e boo m sprayers equipped with flat fan nozzles.

Use nozzle sizes that deliver a medium-fine drople t in 15 to 20 gallons total spray per

acre at 40 to 50 psi and at ground speeds not in excess of 3 to 4 mph. Adjust boom

height so nozzle spray patterns meet uniformity. Avoid raising boom too high.

Flush all equipment with clear water after each day's use. Clean all equipment,

including nurse tanks, used for KT Propanil 4 SC, with detergent wash followed by a

water rinse, before and after spraying other pesticides or other crops.

Crop Tolerance and Growing Conditions

All leading commercial varieties of rice are exceptionally tolerant to KT Propanil 4 SC.

A temporary yellowing or tip burn of rice may be noted after treatment, but new growth

is normal. Sever e leaf burn and partial killing of rice may occur if the product i s applied

when rice is under stress and in a weakened growth condition due to disease or insect

infestations, excessive soil salts, overwatering, or prolonged drought and extremely

hot weather. Growers are cautioned not to spray under such conditions and/or when

maximum dail y temperatures hav e been or are expected to exceed 100°F .

Effect of Climatic Conditions and Cultural Practices on Weed Control

Field and Seedbed Preparation

Fields should be accurately leveled and contoured an d have well-prepared seedbed s

free of clods. Such conditions encourage uniform and rapid emergence of rice, grass

and broadleaf weeds, allowing more accurate timing and coverage of KT Propanil 4

SC sprays for optimum weed control

Page 17 of 19

21
Water Management

Before application of KT Propanil 4 SC, drained or dry planted fields should be flushed

as often as necessary to prevent drying and crusting. Flushing encourages uniform

emergence and vigorous growth of grass, broadleaf weeds and rice, which is essential

for optimum weed control. Flushing of fields should occur when weeds and rice are

actively growing at time of treatment. Make sure the field is drained prior to treatment

so that grasses and broadleaf weeds are fully exposed. Weeds that are partially

submerged i n standing water at time of application will not be satisfactorily controlled.

Treated fields should be flooded before a second infestation of grass develops. To

prevent additional grass weed seed from germinating, rice fields should be flooded

within 24 hours after spraying, or as soon as possible after 24 hours.

Temperature

The temperature a few days before and after applying KT Propanil 4 SC has an

important effect on the weed-killing activity . The activity increases as daily maximum

temperatures increas e above 75°F and decreases as the daily maximum

temperatures decline below 75°F. Do not apply KT Propanil 4 SC when maximum

temperatures have been or are expected to stay below 65°F or exceed 100°F. Less

than optimum temperature at time of application i s not critical so long as the

temperature exceeds 75eF during the day.

Relative Humidity and Rain

Grasses and weeds are more responsive to KT Propanil 4 SC during periods of high

humidity when the foliage is moist or covered by dew. When the humidity is very low,

spray tends to evaporate before reaching weed foliage. Fo r best results under low

relative humidity conditions , increase spray volume to 12 to 15 gallons per acre. Do

not spra y if rain is expected within 8 hours to avoid loss of deposited spray and

herbicide adsorption by the weeds.

Wind

Do not appl y when the wind speed exceeds 10 mph to avoid drift hazard to sensitive

crops and the possibility o f uneven (streaked) applications .

Compatibility With Other Chemicals

Tank mix applications of KT Propanil 4 SC with other herbicides, insecticides, spray

adjuvants, or liquid fertilizers ma y reduce crop tolerance and/or weed control or impair

mixing properties. Use of these products in tank mix applications with KT Propanil 4

SC is done at the user' s risk.

Liquid Fertilizer: Premixing this product in a ratio of 1 part KT Propanil 4 SC to 2

parts water is recommended prio r to mixing with liquid fertilizer.

Adverse Reaction to Insecticides

Rice plants may be severely injured or killed if KT Propanil 4 SC is applied in tank mix

combinations or sequentially before or after certain insecticides . D o not combine KT

Page 18 of 19

22
Propanil 4 SC with carbamate insecticides such as carbaryl, etc., or

organophosphorus insecticides (suc h as malathion and methyl parathion, etc). Do not

apply any of the carbamate or organophosphorus insecticides to rice fields within 14

days before or after KT Propanil 4 SC. Do not use carbamate or systemic

organophosphorus insecticides o n rice fields to be treated with KT Propanil 4 SC.

Do not apply KT Propanil 4 SC to rice fields planted with rice seed treated with bird

repellents containing methiocarb. Consult local Extension specialist for current

recommendations o f approved insecticides on rice.

LIMIT OF WARRANTY AN D LIABILITY IMPORTANT: READ BEFORE USE

Read the entire Directions for Use, Conditions, Disclaimer of Warranties and

Limitations o f Liability befor e using this product. If terms are not acceptable, return the

unopened product container at once.

By using this product, user or buyer accepts the following Conditions , Disclaimer of

Warranties an d Limitations of Liability .

CONDITIONS: The directions for use of this product are believed to be adequate and

must be followed carefully .

However, it is impossible t o eliminate all risks associated with the use of this product.

Crop injury, ineffectiveness or other unintended consequences may result because of

such factors as weather conditions, presence of other materials, or the manner of use

or application, all of which are beyond the control of Kaizen Technologies LLC . To the

extent consistent with applicable law , all such risks shall be assumed by the user or

buyer.

DISCLAIMER OF WARRANTIES: TO THE EXTENT CONSISTENT WITH

APPLICABLE LAW, KAIZEN TECHNOLOGIES LLC MAKES NO OTHER

WARRANTIES, EXPRESS OR IMPLIED, OF MERCHANTABILITY OR OF FITNESS

FOR A PARTICULAR PURPOSE OR OTHERWISE, THAT EXTEND BEYOND THE

STATEMENTS MAD E ON THIS LABEL. To the extent consistent with applicable law ,

no agent of Kaizen Technologies LL C is authorized to make any warranties beyond

those contained herei n or to modify the warranties contained herein. TO THE

EXTENT CONSISTENT WITH APPLICABLE LAW, KAIZEN TECHNOLOGIES LLC

DISCLAIMS ANY LIABILITY WHATSOEVER FO R SPECIAL, INCIDENTAL OR

CONSEQUENTIAL DAMAGES RESULTING FROM THE USE OR HANDLING OF

THIS PRODUCT .

LIMITATIONS O F LIABILITY: TO THE EXTENT CONSISTEN T WITH APPLICABLE

LAW, THE EXCLUSIVE REMEDY OF THE USER OR BUYER FOR ANY AND ALL

LOSSES, INJURIES OR DAMAGES RESULTING FROM THE USE OR HANDLING

OF THIS PRODUCT, WHETHER I N CONTRACT, WARRANTY, TORT,

NEGLIGENCE, STRICT LIABILITY O R OTHERWISE, SHAL L NOT EXCEED THE

PURCHASE PRICE PAID, OR AT KAIZEN TECHNOLOGIES LLC' S ELECTION, THE

REPLACEMENT OF PRODUCT.

Page 19 of 19

23
RE: Propanil New Products - 86363-EN and 86363-RO

Scott Baker to : Maggi e Rudick 10/26/201 1 05:32 PM

2 attachments

KT Propanil 4 SC Label 102611.pdf K T Propanil 80 DF Label 102611.pdf

Maggie,

Attached are revised labels per your comments. However , I do need a little

help on 86363-RO you asked for a triple rinse statement, I am not familiar

with what you are looking for here, I cannot find anything in PRN 2007-4

pertaining to dry products in plastic bags which references triple rinsing,

can you please give me some more guidance on what you are looking for here?

Thanks,

Scott Baker

Lighthouse Produc t Services

Regulatory & Supply Chain Consulting

Lighting the Path of Your Product Needs

3937 Cedarwood Lan e

Johnstown, C O 80534

970-313-6654

Fax 970-667-4010

Original Message

From: Rudick.Maggie@epamail.epa.gov [mailto:Rudick.MaggieOepamail.epa . gov]

Sent: Wednesday, October 26, 2011 2:59 PM

To: sbaker@lhpsonline.com

Subject: Propanil New Products - 86363-EN and 86363-RO

Mr. Baker,

Please see attached labels for KT Propanil 4SC and KT Propanil 80DF dated

August 11 , 2011. Pleas e make the marked changes and submit clean copies

back to me. I f you have any questions or concerns, don't hesitate to call

or email me.

Thank you!

Maggie L. Rudick

U. S. Environmental Protection Agency

Registration Division

Herbicide Branch; Team 25

(703) 347-025 7

Rudick.Maggie@epa.gov

(See attache d file: Propanil -R O with EPA markup.pdf)(See attached file:

KT Propanil 4 SC Label 072711 with EPA markup.pdf)

24
PRIA 2-21 Da y Content Screen Review Workshee t

(EPA/OPP Us e Only)

3/23/09

21 Day Screen Start Date : §" ~ I S~ ~ / _

Experts In-Processin g Signature :

Division management contacted o n issues N o

f /-f#n«/*'£t'

_

t

"

J

 Dat e $ ~

f

 7-/ J

Yes _ Dat e

Fee Paid: Ye s

,

v

EPA Reg. Number: ^3^3 . £ fi) EPA Receipt Date: C - _ / C^" _ / f

Items for Review

1

2

3

4

5

6

Application Form (EPA Form 8570-l)(lin k to form) signed & complete

including package type

Confidential Statemen t of Formula all boxes completed, for m signed, and

dated (EPA Form 8570-4 ) (Lin k to form)

a) Al l inerts (link to http://www.epa.g

including fragrances, approved f

Footnote A)

ov/opprdOO 1 /inerts/), ye s

or the proposed use s (se e

xC

no

Certification wit h Respect to Citation of Data (EPA Form 8570-34 ) (Link to

form) completed an d signed (N/A if 100% repack )

Certificate and data matrix consisten t

If applicant is relying on data that are compensable, is the offer

 ve s

to pay statement included, (see Footnote B)

no

If applicable, is there a letter of Authorization for exclusive use only.

Formulator's Exemption Statemen t (EPA Form 8570-27 ) (Lin k to form)

completed an d signed (N/A if source is unregistered o r applicant owns th e

technical)

Data Matrix (EPA Form 8570-35 ) (Lin k to form) both interna l and external

copies (P R 98-5) (Lin k to PR 98-5) completed an d signed (N/A if 100 %

repack)

yes

a) Selectiv e Method (Fe e category experts use) ^

b) Cite- All (Fee category experts use)

c) Applicant owns all data (Fe e categor y experts use )

5 Copies of Label (link to http://www.epa.gov/oppfeadl/labeline/lrm/]

(Electronic labels o n CD are encouraged and guidanc e i s available)* li

http://www.epa.gov/pesticides/regulating/registering/submissions/index.htmttlabe

)

no

nk to

!lS

Yes

X

X

No N/A*

X

X

X

V

••

X

J

25
Is the data package consistent with PR Notice 86-5 (lin k to PRN 86-5)

Notice of Filing (link to

http://www.epa.gov/pesticides/regulating/tolerance petitions.htm ) included

with petitions (link to

http://www.epa.gov/pesticides/regulating/tolerances.htm)

If applicable fo r conventional applications, reduce d ris k rational e (link to

http://www.epa.gov/opprd001/workplan/reducedrisk.html) X

Required Dat a (link to

http://www.epa.gov/pesticides/regulating/data requirements.htm ) and/or

data waivers. Se e Footnote C.

10

a) Lis t study (or studies) not included with application

26
Comments:

JUU ^WJr-P - 'OUU*- I S Jol^A £^k-*J

V-^"1^^ ^ , f \ . . | E

fl/

* N/A - Not Applicable ' ^

Footnotes

A. Durin g the 21 day initial content review, all CSFs will be reviewed to determin e

whether all inerts listed, including fragrances, are approved for the proposed uses. I f 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 pesticida l uses, correctin g

mistakes on the CSF, etc . or 2) provide the data to support OPP approval of the inert or 3)

withdraw the application. Removin g or substituting an inert ingredient will require a new

CSF and may require submission of data. Al l information, forms, dat a and

documentation resolvin g the inert issue must have been received b y the Agency or the

application withdrawn within the 21 day period, otherwise, the Agency will reject the

application as described below .

To successfully complete this aspect of the 21 day initial content screen , applicants ar e

strongly encouraged to verify tha t all inert ingredients have been approved for the

application's uses even if a product is currently registered by consulting the inert Web

3

27
site [link to http://www.epa.gov/opprd001/inerts/Iists.html1 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. Som e inert

ingredients ar e no longer approved for food uses or certain types of uses. Th e 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 tha t the

inert has been approved , the applicant should contact the Inert Ingredient Assessmen t

Branch (IIAB) at inertsbranch@epa.gov and resolve the issue. Copie s o f the

correspondence with IIAB resolving the issue should accompany the application. Al l

new inerts except PIP inerts are reviewed by IIAB. Th e IIAB should also be contacted

for any questions on what supporting data needs to be submitted for and the Agency's

inert review process. Question s on PIP inerts should be directed to the Chief of

Microbial Pesticide s Branc h [Link to

http://www.epa.gov/oppbppdl/biopesticides/contacts bppd.html .

When a brand, trade, or proprietary name of an inert ingredient is listed on a CSF,

additional information such as an alternate name of the inert, CAS number or other

information [lin k to http://www.epa.gov/opprd001/inerts/tips.pdf1 must also be included

to enable the Agency to determine if it has been approved. Eac h component o f an inert

mixture (including a fragrance) must be identified. I n some cases, the supplier of the

mixture or fragrance may need to provide this information to the Agency. Prio r to the

Agency's receip t of an application, applicants must arrange with a proprietary mixture or

fragrance supplie r to provide the component informatio n to the Agency or promptly upon

EPA's request. I f the inert ingredients in a proprietary blend (including fragrances)

cannot or are not identified or provided within the 21-day content review period, th e

Agency will reject the application.

During the 21 day content review, applicants should submit information to the individual

identified by the Agency when the applicant is informed of an unapproved inert.

Unapproved Inerts Identified on CSFs

All applications except conventional new products and PIPs

Once an unapproved inert is identified on a CSF, the Agency will contact the

applicant with the following options:

1. Correc t the application by, for instance, correcting the inert's identit y 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. Submi t the information and data needed for the Agency to approve the

unapproved inert. I f this option is selected and implemented, the Agency ma y

request an extension in the PRIA decision review timeframe to accommodate

the inert review/approval process;

28
t

3. Withdra w the application (the Agency retains 25% of the full fe e for the fee

category estimated); or

If none of these options is selected an d implemented by the applicant within the

21 day content review period, the Agency will reject the application and retain

25% of the full fe e 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 a s requiring an

inert approval (R311, R312 or R313), it will contact the applicant with the

following options:

1. Correc t the application by, for instance, correcting the inert's identity or CAS

number, providing documentation tha t 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. Submi t the information 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. (Thi s option may change the PRIA

category for the application, which could require a longer decision review

time and a larger fee. I f additional fees are due, they must be received by the

Agency within the 21 day content review period.)

3. Withdra w the application (the Agency retains 25% of the full fe e for the fee

category estimated); or

If none of the above options is selected an d implemented durin g 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 Divisio n 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. Correc t th e application by, for instance, correcting th e spelling or name of the

inert to that in 40 CFR 174, or providing documentation that the inert has been

approved; or

2. Submi t the information and data needed fo r the Agency to approve the

unapproved inert. I f 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. I f this option is selected an d implemented, the

Agency will discuss harmonizing the timeframe for both actions.

5

29
3. Withdra w the application (the Agency retains 25% of the full fe e for the fee

category estimated); or

If none of the above options is selected an d implemented durin g 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 t o 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 t o pay will be placed into either R301 or

A531. Th e Agency recommends tha t authorizations of offers t o pay be submitted with

other PRIA application s to avoid delays in the Agency's decision.

C. Biopesticid e applicants are advised to contact the Agency and discuss study waivers

prior to submitting their application to the Agency. Documentatio n of such discussions

should be submitted with the study waiver.

30
R 300 and 30 1

t

100% identical (repack): YE S or rcircleonel

{If yes, it's a 1 00% repack - then proatTct chemistry, acute toxicity and efficacy data

are not required }

Data on Group and A and B must be submitted - Group A and B can not be cited.

Guideline

No.

830.1550

830.1600

830,1650

830.1670

830.1700

830.1750

830.1800

Group A: Produc t Chemistry Data

Study Title

Product Identity & Composition

Description of materials use d to produce the

product

Description of formulation process

Discussion on the formation of impurities

Preliminary analysis

Certified limit s (158.345 )

Enforcement analytical metho d

Data Od K

submitted

Yes

L^

i/

U^'

I/

L/

\y

No

^

M

Guideline

No.

830.6302

830.6303

830.6304

830.6314

830.6315

830.6316

830.6317

830.6319

830.6320

830.6321

830.7000

830.7100

830.7300

Group B : Produc t Chemistry Data

Study Title

Color

Physical State

Odor

Oxidation/Reduction (Chemica l

incompatibility)

Flammability

Explodability

Storage stability

Miscibility

Corrosion Characteristics

Dielectric Breakdow n voltage

PH

Viscosity

Density

Data

submitted

Yes

^

^

y

\y

i/

o/

^

v/

IX

{/

I/

NX

V

No

31
f

R 300 and 30 1

New products must provide a bridging rationale document. Th e bridging document

directs OPP to use a currently registered set of 6 acute toxicity data and label; instead

of submitting product specific data.

Guideline

No.

870.1100

870.1200

870.1300

870.2400

870.2500

870.2600

Acute toxicity ( 6 pack)

Study Title

Acute Oral (LD50)

Acute Dermal (LD50 )

Acute Inhalation (LC50)

Acute Eye Irritation

Acute Dermal Irritatio n

Dermal Sensitization

Cited

Yes

i/

/

/

/

/

J

J

No

Efficacy - which guideline depends on the proposed label use and they must cite the

data to be used for the bridging rationale.

Guideline

No.

810.3100

810.3200

810.3300

810.3400

810.3500

810.3600

810.3800

Efficacy Study Titles

Soil Treatments for Imported Fire Ants

Livestock, Poultry, Fur and Wool-Bearin g

Animal Treatments

Treatments to Control Pest s of Humans

and

Pets

Mosquito, Black Fly, and Bitin g Midge

(Sand Fly) Treatments

Premises Treatments

Structural Treatments

Methods for Efficacy Testing of Termite

Baits

Cited

Yes No

X

y

X

V

)<

X

y.

Comments

32
ATES ENVIRONMENTAL PROTECTIO PROTECTIONS N AQENC ^ Y

WASHINGTON, D.C . 2046 0

August 17, 2011

OFFICE OF

PREVENTION, PESTICIDES AN D

TOXIC SUBSTANCES

OPP Decision Number: D-45324 7

EPA File Symbol or Registration Number: 863 63 -EN

Product Name: K T PROP ANIL 4SC

EPA Receipt Date: 15-Aug-20 1 1

EPA Company Number: 86363

Company Name: KAIZE N TECHNOLOGIES, LLC

SCOTT BAKER

LIGHTHOUSE PRODUCT SERVICES

KAIZEN TECHNOLOGIES, LLC

3937 CEDARWOOD LANE

JOHNSTOWN, CO 80534 -

SUBJECT: Receip t of Application and 75% Small Business Waiver Request

Dear Registrant:

The Office o f Pesticide Programs has received your application, 75 % small business

waiver request, and certification of payment. I f you submitted data with this application, the

results of the PRN-86-5 screen will be communicated separately. Durin g the administrative

screen, the Office o f 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 a s Action Code: R300

NEW PRODUCT;ME-TOO PRODUCT FAST TRACK;

Your request for waiver has been forwarded for review. Yo u will be notified in writing when a

determination is made regarding your request. I f your waiver request is approved, the decision

review time period will start on the date of approval. I f your waiver request is denied, you will

receive an invoice for the outstanding balance.

If you have any questions , please contact the Pesticide Registration Service Fee

Ombudsman at (703) 308-9362.

Sincerely,

****

Front End Processing Staff

Information Technology & Resources Management Division

33
|Fee for Service! {901503m -

This package includes the following

®New Registration

°Amendment

D

 Studies?

 D Fee Waiver?

n

volpay % Reduction:

for Division

°AD

°BPPD

®RD

Risk Mgr. 25

Receipt No. S -

EPA File Symbol/Reg. No.

Pin-Punch Date :

901503

86363-EN

8/15/2011

This item is NOT subject to FFS action.

^ActtorrCode:

Requested:

Granted:

Amount Due: $

Inert Cleare

Reviewer:

Remarks:

Parent/Child Decisions:

for/Intended Use

 H

U\As

Uncleared Inert in Product

Date:

34
Scott Bake r

From: paygovadmin@mail.doc.twai.go v

Sent: Thursday , August 11, 2011 2:15 PM

To: sbaker@Lhpsonline.co m

Subject: Pay.Go v Payment Confirmation

THIS IS AN AUTOMATED MESSAGE . PLEAS E DO NOT REPLY.

Your transaction ha s been successfully completed .

Transaction Summar y

Application Name: PRIA Service Fee s

Pay.gov Trackin g ID: 254531FC

Agency Tracking ID: 74227746285

Name On Account: Lighthous e Product Services Transactio n Type: ACH

Debit Transaction Amount: $358.50 Payment Date: Aug 12, 2011 Account

Type: Busines s Checking Routing Number: Account Number:

##**********9354

Transaction Date : Aug 11, 2011 4:14:56 PM Number of Payments

Scheduled: 1

Frequency: OneTime

Decision Number:

Registration Number : 86363-

Company Name: Kaizen Technologies LL C

Company Number: 86363

Action Code : R300

35 *Commercial/financial information may be entitled to confidential treatment*
WRA

Wagner Regulatory Associates , Inc .

P.O. Bo x 640

7217 Lancaster Pike , Suite A

Hockessin, Delaware 1970 7

July 7, 2011

Mr. Kable Davis

Registration Divisio n (7504P)

U.S. Environmenta l Protection Agenc y

Office o f Pesticide Program s

Room S-4900 , On e Potomac Yar d

2777 Sout h Crysta l Driv e

Arlington, Virgini a 22202-450 1

RE: Authorizatio n to access Willowoo d USA LLC registration data

Dear Mr. Davis,

Willowood USA LLC hereby authorizes the US EPA to access, reference and use the

below listed data owned and submitted by Willowood USA LLC to support th e named

product registration applicatio n for Kaizen Technologies, LLC . The composition an d

formulation of Willowood Propanil 4SC and KT Propanil 4SC are identical. The

composition and formulation of Willowood Propanil 80DF an d KT Propanil 80DF ar e

also identical.

Product:

KT Propanil 4SC

KT Propanil 80D F

Applicant:

Kaizen Technologies, LLC - EPA Company No .

1555 Main Street, Suit e A3-206

Windsor, CO 80550

86363

36
WRA

Wagner Regulatory Associates , Inc .

P.O. Bo x 640

7217 Lancaste r Pike , Suite A

Hockessln, Delaware 19707

Willowood Propanil 80DF

MRID No.

48333401

MRID No.

48333402

MRID No.

48333403

Wagner Regulatory Associates, Inc. (2010) Willowood Propanil 80D F

Product Identity and Composition, Description of Beginning Materials,

Manufacturing Process, and Discussion of Formation of Impurities.

Willowood LLC, Roseburg, OR. Non-confidential portion 6 pages,

Confidential portion 46 pages.

Wagner Regulatory Associates, Inc. (2010) Willowood Propanil 80DF

Preliminary Analysis, Certified Limits and Enforcement Analytical Method.

Willowood LLC, Roseburg, OR. Non-confidential portion 6 pages,

Confidential portio n 1 5 pages.

Miller, Ronald (201 0) Propanil 80DF Product Chemistry Volume III.

Analytical & Regulatory Chemistry, Inc., Sumter, South Carolina. Report

Number ARC-EX-858-004-P-1. 1 4 pages.

Willowood Propanil 4SC

MRID No.

48336301

MRID No.

MRID No.

Wagner Regulatory Associates, Inc. (2010) Willowood Propanil 4SC

Product Identity and Composition, Description of Beginning Materials,

Manufacturing Process, an d Discussion of Formation of Impurities.

Willowood LLC, Roseburg, OR. Non-confidential portion 6 pages,

Confidential portion 59 pages.

Wagner Regulatory Associates, Inc. (2010) Willowood Propanil 4SC

Preliminary Analysis, Certified Limits and Enforcement Analytical Method.

Willowood LLC, Roseburg, OR. Non-confidential portion 6 pages,

Confidential portion 17 pages.

Miller, Ronald (2010) Propanil 4SC Product Chemistry Volume III.

Analytical & Regulatory Chemistry, Inc., Sumter, South Carolina. Report

Number ARC-EX-872-006-P-1. 1 5 pages.

If you have any questions concerning this authorization, please contact the undersigned at

302-635-7281 or lori@wagnerreg.com.

Sincerely,

Lori Kohler

Agent for Willowood USA LLC

37
Form Approved. OM B No. 2070-0060. Approval Expires 5-31-98.

United State i

Environmental Protection Agency

Washington. DC 2O460

Formulator's Exemptio n Statemen t

(40 CFR 152.85)

Applicant's Name and Address

Kaizen Technologie s

1555 Main Street, Suite A3-206

Windsor, CO 80550

EPA Fil e Symbol/Registration Number

86363-

Product Nam e

KT PROPANIL 4SC

Date o f Confidential Statement of Formula IEPA For m 857O-4I

8-5-11

As an authorized representative of the applicant for registration of the product identified above, I certify that:

(1) Thi s product contains the following active ingredient(s):

Propanil CAS #709-98-8

(2) O f these, each active ingredient listed in paragraph (4) is present solely as the result of the use of that active

ingredient in the manufacturing, formulatio n or repackaging another product which contains that active ingredient

which i s registered under FIFRA Section 3, is purchased by us from another producer, and is labeled for a t least

each use for which my product is proposed to b e labeled.

(3) Indicat e by checking (A) or (B) below which paragraph applies:

BXl (A ) An accurate Confidential Statemen t of Formula (EPA FORM 8570-4) fo r th e above identified product i s

attached 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

|LJ (B ) The Confidential Statemen t of Formula (CSF) (EPA Form 8570-4) referenced above and on file with the EPA is

complete, current, and accurate and contains the information require d on the current CSF.

(4) Th e following activ e ingredients i n this product qualify for the formulator's exemption.

Source

Active Ingredient

Propanil

Signature . , n .

JWttU~

Product Name

Name and Title

Scott Baker - Regulatory Agent

Registration Number

• . .. . ... .

• * . • ... .

.. . . * . . • • • *

Date * * ... . . .

EPA Form 8570-27 (Rev. 8-95)

* U.S.QPC C 1996-388-820/20413

...

• • . Ywow»-«AppUcant cop y

• .... .

38 *Product ingredient source information may be entitled to confidential treatment*
LIGHTHOUSE PRODUCT SERVICES

Regulatory and Supply Cha m Consulting

Augusts, 2011

Subject: Offe r to Pay Data Compensation

Please b e advised that Kaize n Technologies , (Kaizen ) 1555 Mai n Street , Suit e A3-206 ,

Windsor, C O 80550 ("Kaizen") has filed with th e U.S. Environmental Protectio n Agency

an application to register "KT PROPANIL 80DF, and KT PROPANIL 4SC, EPA Reg. No.

86363-XXXXX", whic h contain s th e activ e ingredien t propanil , thi s applicatio n include s

uses supported b y data that may have been provided by your company. I n support of its

request, Kaize n has indicated its reliance on data previousl y submitted by your company

to the extent that relianc e o n that data i s necessary t o support Kaize n applications and,

further, Kaize n ha s indicate d tha t i t i s prepare d t o compensat e you r compan y a s i s

appropriate for the use of that data and in accordance with FIFRA § 3(c)(1 )(F).

By thi s lette r Kaize n indicate s it s willingnes s immediatel y t o commenc e discussion s

looking toward a negotiate d resolutio n o f the data compensatio n issue . W e encourag e

your review and confirmation of any data submitted to the Agency that may be relevant to

the Kaize n application, an d would appreciat e receiving , a t you r earlies t convenience , a

list of the relevant study titles, their MRI D Numbers, and cost information for each of the

listed studies .

We suggest that an early meeting between our respective representative s would facilitate

resolution of the data compensation issue . I n this connection I urge that you direct your

representative to contact my office at your earliest convenience.

If no response is received within 60 days from the date of this letter, Kaizen will deem

that no compensation to your company is required.

Sincerely,

Scott Baker

Regulatory Agent

Does / does not own compensable data applicable to the subject registrations .

Does /does not require compensation for Kaizen Technologies citation of this data.

By: Date :

Signature

•

• i

"SHINING THE LIGHT ON YOUR REGULATORY NEEDS"

3937 Cedarwood Lane Johnstown , Colorado 80534

970-313-6654 Fax-970-667-401 0 sbaker@lhpsoniine.co m

39
Form Approved OMB No. 2070-0060

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

401 M Street, S.W.

WASHINGTON, D.C. 2046 0

Paperwork Reduction Act Notice: Th e public reporting burden for this collection of information is estimated to average 1.25 hours per response for registratio n

and 0.25 hours per response for reregistration and special review activities, including time for reading the instructions an d completing the necessary forms. Sen d

comments regarding burden estimate or any other aspect of this collection of information, including suggestions for reducing the burden to: Director, OPPE

Information Management Division (2137), U.S. Environmental Protection Agency, 401 M Street, S.W., Washington, DC 20460.

Do not send the completed form to this address.

Certification with Respect to Citation of Data

Applicant's/Registrant's Name, Address, and Telephone Numbe r

Kaizen Technologies, 155 5 Main Street, Suite A3-206, Windsor, CO 80550

Active Inqredient(s) and/or representative test compound(s)

Propanil

General Use Pattem(s) (list al l those claimed for this product using 40 CFR Part 158)

Terrestrial food crop, Aquatic food crop (as specified on label)

EPA Registration Number/File Symbol

86363-

Date

August 11, 2011

Product Name

KT PROPANIL 4SC

NOTE: If your product is a 100% repackaging of another purchased EPA-registered product labeled for all the same uses on your label, you do not need to

submit this form. Yo u must submit the Formulator's Exemption Statement (EPA Form 8570-27).

I am responding t o a Data-Call-in Notice, and have included with this form a list of companies sent offers of compensation (the Data Matrix form should

be used for this purpose) .

SECTION I: METHOD OF DATA SUPPORT (Check one method only)

I am using the cite-all method of support, and have included with this form

a list of companies sent offers of compensation (the Data Matrix form

should be used for this purpose).

0

1 am using the selective method of support (or cite-all option

under the selective method), and have included with this form a

completed list of data requirements (th e Data Matrix form must be

used).

SECTION II: GENERAL OFFER TO PAY

[Required if using the cite-all method or when using the cite-all option under the selective method to satisfy one or more data requirements]

I t^l I hereby offer and agree to pay compensation, to other persons, with regard to the approval of this application, to the extent required by FIFRA.

SECTION III: CERTIFICATIO N

I certify that this application for registration, this form for reregistration, or this Data-Call-in response is supported by all data submitted or cited in the

application for registration, the form for reregistration, or the Data-Call-in response. I n addition, if the cite-all option or cite-all option under the selective method is

indicated in Section I, this application is supported by all data in the Agency's files that (1) concern the properties or effects of this product or an identical or

substantially similar product, or one or more of the ingredients in this product; and (2) is a type of data that would be required to be submitted under the data

requirements in effect on the date of approval of this application if the application sought the initial registration of a product of identical or similar composition and

uses .

I certify that for each exclusive use study cited in support of this registration or reregistration, that I am the original data submitter or that I have obtained

the written permission of the original data submitter to cite that study.

• •••

I certify that for each study cited in support of this registration or reregistration that is not an exclusive use study, either: (a) I am the origjr^aT data

submitter; (b) I have obtained the permission of the original data submitter to use the study in support of this application; (c) all periods of eligibility for

compensation have expired for the study; (d) the study is in the public literature; or (e) I have notified in writing the company that submitted thg ^tti^/ajnd have

offered (I) to pay compensation to the extent required by sections 3(c)(1 )(F) and/or 3(c)(2)(B) of FIFRA; and (ii) to commence negotiations to determine the

amount and terms of compensation, if any, to be paid for the use of the study. • • • •

• • * I certify that in all instances where an offer of compensation is required, copies of all offers to pay compensation and evidence of the:- dslwary in f t t

accordance with sections 3(c)(1 )(F) and/or 3(c)(2)(B) of FIFRA are available and will be submitted to the Agency upon request. Shoul d I fail fo produce such •

evidence to the Agency upon request, I understand that the Agency may initiate action to deny, cancel or suspend the registration of my product inJAiJformity with

FIFRA. *» . • •• •

I certify that the statements I have made on this form and al attachments to it are true, accurate, and complete. I acknowledge that any

knowingly false or misleading statement may be punishable by fine or imprisonment or both under applicable law. • • • • •

*- MJL

Date

Augusts, 201 1

Typed or Printed Name and Title • • • • *

Scott Baker - Regulatory Agent

EPA Form 8570-34 (9-97) Electronic and Paper versions available. Submit only Paper version.

40
Based on Form Approved OMBJ^q, 2070-0060

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY *.... •

401 M Street, S.W. .••.« .

WASHINGTON, D.C. 20460

Paperwork Reduction Act Notice: Th e public reporting burden for this collection of information is estimated to average 0.25 hours per response for registration activities and 0.25

reregistration and special review activities, including time for reading the instructions and completing the necessary forms. Sen d comments regarding the burden estimate or any ot

collection of information, including suggestions for reducing the burden to: Director , OPPE Information Management Division (2137), U.S. Environmenta l Protection Agency, 401 M

Washington, D C 20460 . D o not send the form to this address.

fiOQrS Tblr . .

he/ a$p,e,ct of this

Street, 8.W., . .

DATA MATRIX . .

Date 08/05/201 1

Applicant's/Registrant's Nam e & Address

Kaizen Technologies, LLC, 155 5 Main Street, Suite A3-206, Windsor, CO 80550

EPA Reg. No./File Symbol 86363 - •Page 1 o f 2

Product ^ ••••• •

KT PROPANIL 4SC

Ingredient(s) Propani l

Guideline Reference Number

830.1550

830.1600

830.1650

830.1670

830.1750

830.1800

830.1900

830.6302

830.6303

830.6304

830.6314

830.6315

830.6316

830.6317

830.6319

830.6320

830.6321

830-7000

860-7100

830.7300

Guideline Stud y Name

Product Identity and Composition

 x

Description of Materials Used to Produce the Product

Description of Formulation Process ^

Discussion of Formation of Impurities

Certified Limits

 v

Enforcement Analytical Method

Submittal of Samples

Color \

Physical State N

Odor

 N

Oxidation / reduction

 N

Flammability/Flame Extension

 N

Explodability \

Storage Stability \

Miscibility \

Corrosion Characteristics

 N

Dielectric Breakdown Voltage " ^

pH \

Viscosity

Density \

MRID Number

/ 48336301

i 48336301

,48336301

,,48336301

.48336302

' 48336302

, 48336303

, 48336303

' 48336303

j 48336303

,48336303

' 48336303

. 48336303

• 48336303

/ 48336303

' 48336303

' 48336303

i 48336303

, 48336303

**"" LfcQJ -

Submitter

Willowood LLC

Willowood LLC

Willowood LLC

Willowood LLC

Willowood LLC

Willowood LLC

Willowood LLC

Willowood LLC

Willowood LLC

Willowood LLC

Willowood LLC

Willowood LL C

Willowood LLC

Willowood LLC

Willowood LLC

Willowood LLC

Willowood LLC

Willowood LLC

Willowood LLC

Status

LOA

LOA

LOA

LOA

LOA

LOA

LOA

LOA

LOA

LOA

LOA

LOA

LOA

LOA

LOA

LOA

LOA

LOA

LOA

Name and Title Scot t Baker

Regulatory Agent

Note

1

Date

08/05/201 1

....

:*•.

i

Based on EPA Form 8570-35 (9-97) Electroni c and Paper versions available. Submi t only Paper version. Agency Interna l Use Copy

41
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

401 M Street, S.W .

WASHINGTON, D.C. 2046 0

Based on Form Approved OMB No^ 2070-0060

Paperwork Reduction Act Notice: Th e public reporting burden for this collection of information is estimated to average 0.25 hours per response for registration activities and 0.25 BoVJrS f>8r . ,

reregistration and special review activities, including time for reading the instructions and completing the necessary forms. Sen d comments regarding the burden estimate or any othej as^ct of this

collection of information, including suggestions for reducing the burden to: Director , OPPE Information Management Division (2137), U.S. Environmental Protection Agency, 401 M Street, 3.W. ,

Washington, DC 20460 . D o not send the form to this address.

DATA MATRIX

Date 08/05/201 1 EPA Reg. No./File Symbol 86363 - •Page 1 o f 2

Applicant's/Registrant's Nam e & Address

Kaizen Technologies, LLC , 1555 Main Street, Suite A3-206, Windsor, CO 80550

Product

KT PROPANIL 4SC

Ingredient(s) Propani l

Guideline Reference Number

Name and Title Scot t Baker

Based on EPA Form 8570-35 (9-97) Electronic and Paper versions available. Submi t only Paper version.

42
Based on Form Approved OMB £40. 2(370-0060

UNITED STATES ENVIRONMENTAL PROTECTIO N AGENC Y .••.- .

401 M Street, S.W.

WASHINGTON, D.C . 2046 0 . " . • *

••••••

• • •

Paperwork Reduction Act Notice: Th e public reporting burden for this collection of information is estimated to average 0.25 hours per response for registration activities and 0.25 hsurs per

reregistration and special review activities, including time for reading the instructions and completing the necessary forms. Sen d comments regarding the burden estimate or any otrTe/asp&t of thie«

collection of information, includin g suggestions for reducing the burden to: Director, OPPE Information Management Division (2137), U.S. Environmental Protection Agency, 401 M Street, S.W., . .

Washington, DC 20460. D o not send the form to this address. . .

DATA MATRIX :

Date 08/05/201 1

Applicant's/Registrant's Nam e & Address

Kaizen Technologies, LLC, 155 5 Main Street, Suite A3-206, Windsor, CO 80550

EPA Reg. No./File Symbol 86363 - Staged of 2

Product

KT PROPANIL 4SC

Ingredient(s) Propani l

Guideline Reference Number

870.1100

870.1200

870.1300

870.2400

870.2500

870.2600

Guideline Study Name

Acute Oral Toxicity

Acute Dermal Toxicity

Acute Inhalation Toxicity

Acute Eye Irritation

Acute Dermal Irritation

Skin Sensitization

MRID Number

Cite-All

Cite-All

Cite-All

Cite-All

Cite-All

Cite-All

Signature

 / Ju? i jWAlijL.

Submitter Status

PAY

PAY

PAY

PAY

PAY

PAY

Name and Title Scot t Baker

Regulatory Agent

Note

2

2

2

2

2

2

Date

08/05/2011

Based on EPA Form 8570-35 (9-97) Electronic and Paper versions available. Submi t only Paper version. Agency Internal Use Copy

43
Based on Form Approved QMS We«3Cf70-006 0

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

401 M Street, S.W .

WASHINGTON, D.C. 2046 0

Paperwork Reduction Act Notice : Th e public reportin g burden for this collection o f information is estimated to average 0.25 hours per response for registration activities and 0.25 hour»pw

reregistration and special review activities, includin g time for reading the instructions and completing the necessary forms. Sen d comments regarding the burden estimate or any othesaspest o f this •

collection o f information, including suggestions for reducing the burden to: Director , OPPE Information Management Division (2137), U.S. Environmental Protection Agency, 401 M Street S.W. ,

Washington, DC 20460. D o not send the form to this address. , ,

DATA MATRIX

Date 08/05/201 1 EPA Reg. No./File Symbol 86363 - J.of 2

Applicant's/Registrant's Nam e & Address

Kaizen Technologies, LLC, 1555 Main Street, Suite A3-206, Windsor, CO 80550

Product

KT PROPANIL 4SC

Ingredient(s) Propani l

Guideline Reference Number Submitter Status

PAY

PAY

PAY

PAY

PAY

PAY

Name and Title Scot t Baker

Regulatory Agent

Note

Date

08/05/2011

Based on EP"A Form 8570-35 (9-97) Electronic an d Paper versions available. Submi t only Paper version.

44
1 . Submitta l of Samples

2. Offe r To Pay Letter

DATA MATRIX FOOTNOTES

Not required at this time for end use products

Studies which offer to pay letter has been sent. See list below

El. D U PONT DE NEMOURS AND CO.,

•mnv MARK-F T QTRFFT

mMINGTON,DE 19898

MONSANTQ COMPANY

1300 I STREET, NW , SUITE 450 EAST

WASHINGTON.DC 2000 5

PROPANIL TASK FORC E

600 13T H STREET, NW

WASHINGTON.DC 2000 5

UNITED PHOSPHORUS , INC

KNG O F PRUSSIA.PA 1940 6

RICECO LLC

5100 POPLAR AVENUE, SUITE 2428

MEMPHIS.TN38137

45
LIGHTHOUSE PRODUC T SERVICE S

Rcgulitory and Supply Chai n Consulting

August 11, 201 1

Document Processin g Desk (REGIS)

Office of Pesticide Programs

U.S. Environmental Protectio n Agenc y

Room S-4900, One Potomac Yard

2777 S. Crystal Drive

Arlington, VA 22202

Subject: K T PROPANIL 4SC - EPA Reg. No. 86363-

Lighthouse Product Services, Regulatory Agent for Kaize n Technologies LLC, is submitting the enclosed

information to support a new end use registration. Pleas e find the following enclosed:

1. EP A Form 8570-1 Application for Pesticide

2. Receip t for PRI A Fee

3. Lette r of Authorization for Produc t Chemistry Studies

4. EP A Form 8570-4 Confidential Statement of Formula ( 2 copies)

5. EP A Form 8570-27 Formulator's Exemption Statemen t

6. EP A Form 8570-34 Data Citation

7. EP A Form 8570-35 Data Matrix

8. Cop y of Offer To Pay Letter

9. Produc t label: KT PROPANIL 4SC (5 copies)

10. Smal l Business Waiver Fee Request (Voluntary Smal l Business Certification Form) *

Please contact m e at 970-313-6654 o r by e-mail: sbaker@lhpsonline.com if there are any questions o r

comments concerning this submission.

Sincerely,

Scott Baker

Agent for Kaize n Technologies LLC.

"SHINING TH E LIGHT ON YOUR REGULATORY NEEDS"

3937 Cedarwood Lane Johnstown , Colorado 80534

970-313-6654 Fax-970-667-401 0 sbaker@lhpsonline.co m

46
VrJ^je read instruction* on reverse bffom completing form. Form Approved. OM B No. 2070-0060. Approva l expires 2-28-95

United States

Environmental Protectio n Agenc y

Washington, D C 20460

Registration

Amendment

Other

opp ldentifiar Number

Application for Pesticid e - Section 1

1 . Company/Product Number

4. Company/Product (Name)

KTPROPANIL4SC

2. EPA Product Manage r

PMf

25

3. Proposed Classification

None Restricted

5. Name and Address of Applicant (Include ZIP Code)

Kaizen Technologies

1555 Main Street, Suite A3-205

Windsor, CO 80550

Check if this is a new address

6. Expedited Reveiw. I n accordance with FIFRA Sectio n 3(c)(3 )

(b)(i), m y product is similar or identical in composition and labeling

'EPA Reg . NO. 87290-18

Product Name

WILLOWOOD PROPANIL 4SC

Section - II

Amendment - Explain below.

Resubmission in response to Agency letter dated.

Notification - Explain below.

Final printed label s in repsonse to

Agency letter dated

"Me Too" Application .

Other - Explain below.

Explanation: Us e additional page(s ) if necessary . (Fo r section 1 an d Section II.)

R300, application for a new end use product.

Section - III

1. Material This Product Will Be Packaged In:

Child-Resistant Packaging

[ Yo s

• No

* Certification must

be submitted

Unjt

 packaging wgt . contafner

Water Soluble Packaging

I Ye s

• No

If "Yes "

Package wg t

No. per

container

2. Type of Container

Metal

Plastic

Glass

Paper

Other (Specify)

3. Location of Net Contents Informatio n

\^1 Labe l L J Containe r

4. Size(s ) Retai l Container

1, 2.5, 15 , 30, 55, 110 , 275 Gal, Bul k

5. Location of Label Directions

Attached to container

6. Manner in Which Label is Affixed to Produc t Lithograph

Paper glue d

Stenciled

Other sel f adhesive

Section - IV

1 . Contact Point (Complet e items directly below for identification of individual to be contacted, if necessary, to process this apgticatiot.1

Name

Scott Bake r

Title

Regulatory Agen t

Telephone No . tlnojude Area Code)

970-31 S-66&. . * . *

Certification

I certify that the statements hav e made on this form and all attachments theret o are true, accurate and complete.

I acknowledge that any knowlinglly false or misleading statemen t ma y be punishable by fine or imprisonment or

both under applicable law .

2. Signature

4. Typed Name

Scott Bake r

3. Titl e

Regulatory Agent

5. Date

August 10, 2011

e.jJate Application • :

•ftevewed ...,. ,

(

 (Stamped ) * • • *

*,»*!•••• •

EPA Form 8570-1 (Rev. 3-941 Previous editions ar e obsolete. Whfte - EPA File Copy (original ) Yello w - Applicant Copy

47
EPA Form 8570-4 (Rev . 2-85 ) Previous editions ar e obsolete

Inerts Approve d for Foo d Use under 40 CFR 180.920,

Pre-Harvest Application to Growing Crops

1 1 . _/ - /

'K v/"(|,v i /2o| (

48

*Confidential Statement of Formula may be entitled to confidential treatment*
49

*Confidential Statement of Formula may be entitled to confidential treatment*
• • • • • •

50