REGISTRATION

87290-18 
( 

Completion of 21-Day Content Screen 

PM - ..:::..-.;;))~ 

EPA Reg. #(File Symbol) 67)90-1<1 

Decision # D ____ _ 

Data package delivered to 

you on ;ifliit . (date) 

Jacket/Mini-jacket will be 

transferred to you today. 

(Pick up from Document Center) 

// 6c'C'rJ 5//7L?c: 0 ??? 

Thank you, ~ 

Registration Division's 21-Day Content Team 

To /v!'-' .~ I L1
( 

Memorandum 

Date: I / S / I I 

To: ___ -'-P1..JL!ltJL---".d-c.LS ___ " Regulatory Manager 

From: Information Services Branch, ITRMD 

Your receipt of this data submission is not an 

indication that MRIDs for the enclosed studies have 

been posted to OPPIN. 

We expect tillat it willI be approximately 5 days 

from the above date before the study-level data is 

available ill OPPIN. 

If you have any questions about this process, 

please contact Teresa Downs (305-5363). 

This is a: 'iRfully accepted submission 

o partially accepted submission 

o rejected submission 

2
To the Document Center (ITRMD) 

*Please transfer jacket/mini-jacket to the Product Manager 

Team circled below: 

Minor Use Section: PM-5 

Insecticide Branch: PM-10 PM-13 

Herbicide Branch: PM-23 PM-25 

Fungicide Branch: PM-20 PM-21 PM-22 

InsectIRodent Branch: PM-1 PM-7 

*Reminder to PM - If applicable, pick-up data from the 

Screening Room. 

Processed by RD's Completeness Check Team 

(team Member Signature) (Date) 

3
( ( 

21-Day Screen Completed by 

Contractor 

21-Day Expires on I~ /3- 1/ 

Jacket # '?7 cJ'lt! - kI 

MRID# 1f%33'-3 

Content Screen: Recommended to 

[pas~}Fail 

86-5 Review:\passedYFailed/NA 

Transfer This Jacket to: 

4
.. 

ISB'S Front-end PRlA Completeness Screen 

Draft 3; 10/25/07 

occiplDuto: /,;2./23 /10 EPA Reg. Number: 87:290-f<I 

Cheek,List Item' 

',," --' .. '. , , 

-las the PRIA Fee been Paid; is a copy of the check or 

lay.goy reccipl included in the Submission Package? .--

san Appliciltion FOl'm (EPA Form 8570-1) Included in lhe 

:~ s 'uhmiss'ioll Package, is it completely filled oul and signed 

lu.:luding package type? _._. 

I s a Confidential Statement of Formula (EPA Fonn 8570~ 

3 2 I)~ ,Included in the Submission Package, is it completely 

'I 

7 

illod out Hnd signed (boxes 1-21)? 

I S 11 Formnlatol"s Exemption Statement (EPA Ponn 8570-

2 7) Included in thc Submission Package? 

-"--

s \I Ccrtific~'tion with Respect to Citation of Data (EPA 

:ornl g570<~4) Tncluded in the Submission Package? .. -

I S II nat I! Matrix (EPA Form 8570-35) Included in the 

S 'uhmission Package? 

-_._-. 

,'i U Lahellncludcd in thc Submission Package? 

X A rc Ihbl Included in Ihe Submission Package? . 

\) s the Snbmissi01l nn Amcndment? 

Yes No N/A 

5
( 

Reg. No. F7ZiU-1 y 

oescription:'---J...CM'-LOl...lf-->.:.2.\'_· ._-------------

1. ?~Iacement within the e-Jacketljacket 

yoefault: (chronola§ical, top = newest) 

o File locotiGn: (PDF pa!Je number, Le., "before page 

45") 

2. 0 ~end to :Data Extraction contractors·this material: "7 _. 0 Newly stamped accepted label 

/ Notification 7 NewCSF 

o Other: ----------~---

3. Attach this coversheet to the top af the material ar jacket. It 

must be welt organEeda~ clipped to§~, NOT STAPLED. 

Then give the ~rial with this coversheet to staff in the 

Inrormation SE;llVices Center (Reom S-49(0). 

Reviewer's Name: ...l.8d...L:::..-1-' :.:L1_~---i'f-/-6-=· =--____ __ iJ 

Phone: 36~-'7 -'3 58 Division:-,-lD~_~ 

Date: ff 7 .// 

Created August 14, 2008 

6
( ( 

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 

WASHINGTON, D.C. 20460 

Lori Kohler 

Wagner Regulatory Associates, Inc. 

P.O. Box 640 

7460 Lancaster Pike, Suite 9 

Hockessin, DE 19707 

OFFICE OF CllEMICAl. SAFETY 

ANI) POLLUTION PREVEl'o'TION 

Subject: EPA Reg. 87290-18! Willowood Propanil4 SC Notification 

Dear Ms. Kohler: 

The Agency is in receipt of your Application for Pesticide Notification under Pesticide 

Registration Notice (PRN) 98-10 dated 4-19-llfor the product EPA Reg. 87290-18! Willowood 

Propani14SC. The Registration Division (RD) has conducted a review of this request for its 

applicability under PRN 98-10 and finds that the action falls within the scope ofPRN 98-10. The 

revised basic csf is acceptable. 

If you have any questions please call Erik Kraft at 703-308-9358 or email atKraft.Erik@epa.gov . 

Sincerely, 

)Gg;;~ 

Product 

Kab I e Bo 

Manager 

DavIs .~ 

25 

Herbicide Branch 

Registration Division (7505P) 

7
I ( 

, 

'~1 ,W,~ 

ff~!~lt~j0 ruE~,R(Jll~,ll1~~,}£E:~ Wagner Regu!atory Associates, Inc. 

P.O. Box 640 

April19,2011 7460 lancaster Pike, Suite 9 

Hockessin, Delaware 19707 

Office of Pesticide Programs (NOTIF) 

Attn: Kable Davis, PM 25 

U. S. Environmental Protection Agency 

1200 Pennsylvania Ave" N,W, 

Washington, D,C, 20460 

Dear Mr. Davis; 

Re: Willowood Propani1 80DF (EPA Reg, No, 87290-17) & 

Willowood Propani14SC (EPA Reg, No, 87290-18) 

•••• • • •• •• 

•••• 

• •••• 

• 

•• • •• • • •• 

•••• • •• •• • 

• 

• • •••••• 

• 

• • •••••• 

• 

Notice of revised basic Confidential Statement of Formula (CSF) per PR Notice 

98-10 

Wagner Regulatory Associates, Inc., on behalf ofWillowood LLC, hereby notifies the 

Agency that the producers listed in Box 2 ofthe CSFs have been revised per PR Notice 

98-10, No other changes have been made to these CSFs, 

Enclosed for the Agency's file is: 

Letter from Willowood LLC authorizing Wagner Regulatory Associates, Inc. 

to serve as Agent 

EPA Notification form (EPA Form 8570-1) for each product 

One copy of revised CSFs (EPA Form 8570-4) for each product 

Please feel free to contact me at (302) 234-0991 or lori@wagnerreg.com if you have any 

questions or require additional information. 

Respectfully submitted, 

Lori Kohler 

Agent for Willowood LLC 

• ••••• 

• •• • • 

•••••• • • •• 

• •••• • • .. , .. 

8
W/L 

Your preferred manufacturer of post patent products 

August 31,2010 

To: Whom it-May Concern 

Re: Designation of Agent for: 

Willowood USA, LLC 

1600 NW Garden Valley Blvd. 

Suite 130 

Roseburg, OR 97471 

Dear Sir or Madam: 

•••• • • •••• 

•••• 

• •••• 

• .. ., . . · .. •••• · .. ., . 

• 

• • •••• •• 

• 

• • •••••• 

• 

This letter serves as notification that Willowood USA, LLC has appointed Wagner 

Regulatory Associates, Inc. 0NRA Inc.) to serve as the Agent on our company's behalf 

regarding all state and federal regulatory matters relative to products that Willowood 

USA, LLC will register with US EPA and the states. Please fOlWard all correspondence 

for our company and its products to: 

Wagner Regulatory Associates, Inc. 

P.O.80x640 

Hockessin, DE 19707-0640 

Thank you for your time and assistance. Please feel free to call me at if you have any 

questions. 

Respectfully submitted, 

Brian Heinze 

PresidentlCEO 

cc: WRA, Inc, 

. • ••••• ., 

• • 

• ••••• • • .. ••••• 

• • 

••••• 

1600 NW Garden Valley Blvd, Suite 130 • Roseburg, OR 97471 • 541,679,9963' FAX 541.679.4650 • www,WiliowoodUSA.com 

9
Please rea~jnslrucfions on reverse before come.teti"-~ form. Form Approver"-'v1B No. 2070-0060. Approval expires 05-31-98 

.. t : ...... ~fjistration OPP Identifier Number 

aEPA United States 

Environmental Protection Agency Amendment 

Washington, DC 20460 X Other 

Application for Pesticide - Section I 

1. CompanylProduct Number 2. EPA Product Manager 3. Proposed Classification 

87290~18 Kable Davis 

4. CompanylProduct (Name) PM. [i$J None Restricted 

Willowood, LLClWiliowood Propanil 4 SC 25 

5. Name and Address of Applicant (Include Zip Code) 6. Expedited Review. In accordance with FIFRA Section 3(c)(3) 

Willowood, LLC 

(b)(I), my product is similar or identical in composition and labeling 

to: 

clo Wagner Regulatory Associates, Inc. 

P.O. Box 640 

EPA Reg. No. 

Hockessin, DE 19707 Product Name: 

o Check if this is 8 new address 

Section - 11 

D Amendment - Explain below. D Final prinled labels in response to 

Agency letter dated 

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

~ Notifica!ion - Explain below. D Other - Explain below. 

Explanation: Use additional page(s) if necessary. (For Section I and Section II.) 

Notification of revised basic CSF per PR Notice 98~10. This notification is consistent with the provisions of PR Notice 98~10 and EPA 

regulations at 40 CFR 152.46, and no other changes have been made to the labeling or the confidential statement of formula of this 

product. I understand that it is a violation of 18 U.S.C. Sec. 1001 to willfully make any false statement to EPA I further understand that if 

this notification is not consistent with the terms of PR Notice 98~10 and 40 CFR 152.46, this product may be in violation ofFIFRA and I 

ma be subiect to enforcement action and oenalties under sections 12 and 14 of FIFRA 

Section - 111 

1. Material This Product Will Be Packaged In: 

ChH~r~;;·paCkag;ng U~ckaging W~Soluble Packaging 2. T e of Container 

Yes Yes Metal 

X No X- No X- No Plastic 

It ·Yes· No. per It "Yes· No. per Glass 

... Certifrcation must Unit Packaging wgl. conlainer Package wgt conlainer Paper 

be submitted I X Other (Specify) HOPE lined bags 

3. Location of Net Contents Information 4. Size(s) Retail Container 5. Location of Label Directions 

m Label D Container 2.5 gallons, 30 gallons, bulk ti3 On Label 

X On Labeling accompanying product 

6. Manner in Which Label is Affixed to Product § Lithograph CJ other - X Paper glued 

Stenciled 

Section - IV 

1. Contact Point Complete {tems direct{ below for identification of individual to be contacted, if necessa • to rocess this a lication. 

Name I Title I ~ell~~hone No. (Include Area Code) 

Lori Kohler Agent for Willowood, LLC 302 2340991 

Certification 6. Date Application 

I certify that the statements I have made on this form and all attachments thereto are true, accurate and complete. Received 

! acknowledge thai any knowingly false or misleading slatement may be punishable by fine or imprisonment or 

both under applicab!e law. (Stamped) . " . " • c " ( , 

2.Si~,~ 3. Title • , , , , , , . , , , , , ' " , , , " , , , , , , Agent for Willowood, LLC " , . , , , , . , 

• . " , 

4. Typed Name 5. Date 

Lori Kohler April 19, 2011 , , , , " , , , , .. ,--"'-'~:- ThiS IS a reproduction of EPA Form 8570·1 (Rev. 8~94) PrevIous editions are obsolete. , ( ,( ,( 

, , " t , ,c' < ( 

10
Prim Letter 

Enter More Information 

Tracking 

11
12
Material Sent for Data Extraction 

Reg # _-,,-3 7~2 q-,-"O~--L1.l1 8 __ _ 

Description: NIJJ) 6a.s:c., GSF 

GY Material(s) Sent to Data Extraction Contractors: 

• 

D New Stamped Label Dated ___ _ 

D Notification Dated ____ _ 

New CSF(s) Dated June. 22,2011 

D Other: _________ _ 

~ Deci s ion #: _-L~ S",-,=,3.:,L:'.""-la--l-1 ______ _ 

D Other Action/Comments: ________ _ 

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

must be well organized and clipped together, NOT STAPLED. 

Then give the material with this coversheet to staff in the 

Information Services Center (Room 5-4900). 

Reviewer: b~ b~baw 

Phone: 3'-/7 - 807J. D ivi si 0 n: _-,-f...-,-I~=--__ _ 

Date: ~~ ______________ _ Created February 3, 2011 

13
( 

UNITED STATES ENVIRO"'MENTAL PROTECTION AGENCY 

WASHINGTON. D.C. 20460 

Willowood USA LLC 

c/o Ms. Lori Kohler 

Wagner Regulatory Associates, Inc. 

P.O. Box 640 

7217 Lancaster Pike, Suite A 

Hockessin, Delaware 19707 

AUG 1 8 2011 

OFFICE OF CHDnC\ L S,\FETY 

.... ""D POLU;TIQN PREVE:\"T10:X 

Subject: Notification per PR Notice 98-10- Change of Active Ingredient Source 

Willowood Propanil 80 DF, EPA Reg. No. 87290-17 and 

Willowood Propanil4 SC, EPA Reg. No. 87290-18 

Application Dated June 22, 2011 

Dear Ms. Kohler: 

The Agency is in receipt of your Application for Pesticide Notification under Pesticide 

Registration Notice (PRN) 98-10 for the subject product. 

The Registration Division (RD) has conducted a review of these requests under PRN 98-10 

and finds that the actions requested are acceptable. The basic formulations submitted with these 

applications (dated June 22, 2011) will supersede all previously accepted basic formulations. 

If you have any questions, please call me directly at 703-305-1243 or Beth Benbow at 703-

347-8072. 

Kable Bo Davis, Product Manager 25 

Herbicide Branch 

Registration Division (7505P) 

Office of Pesticide Programs 

14
June 22, 2011 

Document Processing Desl< (NOTIF) 

AnN: Kable Davis, PM 25 

Registration Division (7S04P) 

U.s, Environmental Protection Agency 

Office of Pesticide Programs 

Room 5-4900, One Potomac Yard 

2777 South Crystal Drive 

Arlington, VA 22202-4501 

Dear Mr. Davis: 

( 

Wagner Regl.llatolY Associates, Ittc. 

P.O. Box 640 

7217 Lancaster Pike, Suite A 

Hockessin, Delaware 19707 

Subject: Willowood Propanil80 DF, EPA Registration Number 87290-17 and 

Willowood Propanil4 SC, EPA Registration Number 87290-18 

Notification of Change of Source for Technical Grade Active Ingredient per PR Notice 

98-10 

Wagner Regulatory Associates, Inc., on behalf ofWil!owood USA LLC, respectfully submits the following 

Notification of change of source of technical grade active ingredient for the basic Confidential Statement 

of Formula (CSF). In support of til is notification, the following documents are attached: 

• Letter from Willowood USA LLC appointing Wagner Regulatory Associates, Inc. as its agent 

• Application for Pesticide Registration (8570-1) 

• Confidential Statement of Formula (8570-4), 2 copies 

• Formulators Exemption (8570-27) 

Please feel free to contact me via email at lori@wagnerreg.comortelephone at (302) 635-7281 if you 

have any questions. 

Respectfully submitted, 

Lori 

!&u~ Kohler 

Agent for Willowood USA LLC 

Enclosures 

, " , , 

, < , , < , " , 

, , , " , , 

, , , < " < , 

, " " 

15
PleaS8 read instroctions Olr reverse before comr/ 1 form. FOlm Aoaro 1MB No. 2070-0060. Aparoval expires 05-31-98 

•• agistration OPP Identifier Number 

oEM United States 

Environmental Protection Agency Amendment 

Washington, DC 20460 X Other 

Application for Pesticide - Section I 

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

87290-18 Kable Davis 

4. Company/Product (Name) PM. llil None Restricted 

Willowood USA, LLCNViliowood Propanil 4 SC 25 

5. Name and Address of Applicant (InC/ude Zip Code) 6. Expedited Review. In accordance with FIFRA Section 3(c)(3) 

Willowood USA, LLC 

(b)(I), my producl is similar or identical in composition and labeling 

to: 

clo Wagner Regulatory Associates, Inc. 

P.O. Box 640 

EPA Reg. No. 

Hockessin, DE 19707 Product Name: 

o Check if this is a new address 

Section - II 

0 Amendment - Explain below. 0 Final printed labels in respon~ D pO' 

Agency letter dated 

0 Resubmission in lesponse to Agency letter dated 0 "Me Too" Application. AUG 1 8 2011 

Il9 NOtification - Explain below. 0 Other· Explain below. 

Explanation: Use additional page(s) if necessary. (For Section I and Section II.) 

Notification of change of source of active ingredient per PR Notice 98-10. This notification is consistent with the provisions ot PR Notice 98-

10 and EPA regulations at 40 CFR 152.46, and no other changes have been made to the labeling or the confidential statemenl of formula 

of this product. I understand that it is a violation of 18 U.S.C. Sec. 1001 to willfully make any talse statement to EPA. I further understand 

that it this notification is not consistent wilh the terms ofPR Notice 98-10 and 40 CFR 152.46, this product may be in violation ot FIFRA 

and I may be subject to entorcement action and penalties under sections 12 and 14 of FIFRA. 

Section - III 

1. Material This Product Will Be Packa ed In: 

ChH~F;;·paCka9in9 U~ckaging W~ Soluble Packaging 2. Type ot Container 

Ves Ves Metal 

X No X No X No Plastic 

If "Yes" No. per It "Yes" No. per Glass 

* CeItfffcatfon must Unit Packaging wgt. container Package wgt container Paper 

be submitted I X Other (Specify) HOPE lined bags 

3. Location of Net Contents Information 4. Slze(s) Retail Container 5. Location ot Label Directions 

[K] Label D Container 2.5 gallons Ii3 On Label 

X On Labeling accompanying product 

6. Manner in Which Label is Affixed to Product § Lith09caph c::::::J Other - X Paper glued 

Stenciled 

Section -IV 

1. Contact Point Comptete items directly below for identification of individual to be contacted, if necessal}', to process this application.) 

Name I Title I Telephone No. (Include Area Code) 

Lori Kohler AQent tor Willowood USA, LLC (302i 635-7281 

Certification 6. Date Arpr,~atbn 

I certify that the statements I have made on this fOlm and all attachments thereto are t/Ue, accU/ate and complete. ReceiveU' < 

I acknowledge that any knowingly false or misleading statement may be punishable by fine 01 imprisonment or < , , , , , ' 

< < both under applicable law. ; (~tal'lped) < 

2.Si9~;)~ 3. Title , " , , " , . < , « « 

Agent tor Willowood USA, LLC < < < "{ , " ( { , . 4. Typed Name < , " ( , 

, < 

Lori Kohler June 22, 2011 ({ { { < c 

< 

.. < < This IS a reproduction of EPA Form 8570-1 (Rev. 8-94) PrevIous editions are obsolete. , { « " 

16
(' 

Form approved. OM8 No. 2070'()060, 2070-0057, 2U70'()107, 2070-0122, 2070-0164. 

&EPA 

United States 

Environmental Protection Agency 

Washington, DC 20460 

Formulator's Exemption Statement 

(40 CFR 152.85) 

Applicant's Name and Address EPA File SymbollReglstra\!on Number 

87290-18 

Willowood LLC Product Name 

C/O Wagner Regulatory Associates, Inc. Willowood Propanil 4 SC 

P.O. Box 640 

Hockessin, DE 19707 

Dale at Confidential statement at Formuta (EPA Form 8570-4) 

06/22/2011 

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

(1) This product contains the following active Ingredlent(s): 

Propanil 

(2) Of these, each active ingredient listed In paragraph (4) is present solely as the result of the use at that active ingredient in the manufacturing, 

formulation or repackaging another product which contains that active ingredient which is registered under FIFRA Section 3, is purchased by 

us from another person and meets the requirements of 40 CFR section 158.50(e)(2) or (3). 

(3) Indicate by checking (A) or (8) below which paragraph applies: 

71 (A) An accurate Confidential statement of Form uta (EPA FORM 8570-4) 10r the above identified product is attached to this statement. 

That formula statement indicates, by company name, registration number, and product name, the source of Ihe active ingredlent(s) tisted in 

paragraph (1). 

OR 

-, (8) The Confidential Statement of Formula (CSF)(EPA Form 8570-4) referenced above and on file with the EPA is complele. current, an 

accurate and contains the information required on the current CSF. 

(4) The following active ingredients In this product qualify for the formulator's exemption. 

Source 

Active tngredient Product Name Registration Number 

Propanil Propanil Technical 87829-1 

Signa~ AAJv~ Name and Trtte Date 

Lori Kohler, Agent " 06/22/2011 

EPA Form 8570-27 (Rev. 06-2004) Copy 1 EPA 

Copy 2 - Applicant copy 

17
July 15, 2011 

Document Processing Desk 

Mr. Kable Davis, PM 25 

Registration Division (7504P) 

U.S. Environmental Protection Agency 

Office of Pesticide Programs 

1200 Pennsylvania Avenue NW 

Washington, D.C. 20460 

Dear Mr. Davis, 

Subject: Willowood Propanil4SC 

Final Printed Label 

EPA Registration Number 87290-18 

( 

Wagner Regulatory Asrodate5, Inc. 

P.O. BoxMO 

7217 l:lnC.l~ter Pike, Suite A 

Hockessin, Delawilre 19707 

Wagner Regulatory Associates, Inc., on behalf of Willowood USA LLC, respectfully submits the 

enclosed final printed label for the subject product as required in the EPA Notice of Pesticide 

Registration dated March 9, 2011. No changes were made to this label. Also enclosed is an 

Agent letter and EPA Application form (8570-1). 

Please note that this label was printed prior to the approval of the Notification of Minor Label 

Revision dated June 8, 2011 (copy enclosed) which modified the following sentence to include 

the word "beans" at California Department of Pesticide Regulation's request: "Avoid drift or 

accidental application from turning aircraft on beans, cotton, soybeans, com, safflower, seedling 

legumes, vegetables, orchards, vineyards, gardens, shrubs and ornamentals". This approved 

wording will be included in the label at the next printing. 

Please feel free to contact me via email at lori@wagnerreg.com or telephone at (302) 635~ 7281 if 

you have any questions or require additional information. 

Respectfully submitted, 

Lori Kohler 

Agent for Willowood USA LLC 

Enclosure 

" , , , '" < ~ ( < 

", , 

, , , , , < ' , , 

18
WILlOWOOD US~ Your preferred manufacturer of post patent products 

August 31, 2010 

To: Whom it-MaY"Concern 

Re: Designation of Agent for: 

Willowood USA, LLC 

1600 NW Garden Valley Blvd. 

Suite 130 

Roseburg, OR 97471 

Dear Sir or Madam: 

This letter serves as notification that Willowood USA, LLC has appointed Wagner 

Regulatory Associates, Inc. (WRA, Inc.) to serve as the Agent on our company's behalf 

regarding all state and federal regulatory matters relative to products that Willowood 

USA, LLC will register with US EPA and the states. Please forward all correspondence 

for our company and its products to: 

Wagner Regulatory Associates, Inc. 

P.O. Box 640 

Hockessin, DE 19707-0640 

Thank you for your time and assistance. Please feel free to call me at if you have any 

questions. 

Respectfully submitted, 

, , ( c 

Brian Heinze 

President ICED 

cc: WRA, Inc. 

«_c<C~­

, , , . , 

, 

• , 

, ( , < , < \ ~. 

, ' 

, L , L ( 

, . \ ' " " ( 

" , . 

• " 

, .. ' .. ' , , , , < 

, .. " 

1600 NW Garden Valley Blvd. Suite 130 • Roseburg, OR 97471 ·541.679.9963· FAX 541.679.4650 • www.WillowoodUSA.com 

19
Please read instructions on reverse before comnf,< 'lfOlm. Form Approvi 1MB No. 2070-0060. Approval expires 05-31-98 . , 

r.egistration OPP Identifier Number 

oEM United States 

Environmental Protection Agency Amendment 

Washington, DC 20460 X Other 

AODIication for Pesticide - Section I 

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

87290-18 Kab[e Davis 

4. Company/Produci (Name) PM# [g] None Reslricted 

Willowood, LLCNVillowood Propani[ 4SC 25 

5. Name and Address of Applicant (Include Zip Code) 6. Expedited Review. [n accordance wilh F[FRA Section 3(c)(3) 

(b)(I), my product is similar or identical in composition and [abeling 

Willowood, LLC to: 

clo Wagner Regu[atory Associates, Inc. EPA Reg. No. 

P.O. Box 640 

Hockessin, DE 19707 Product Name: 

0 Check if this is a new address 

Section - II 

0 Amendment - Explain below. I)g Final prinled labels in response to 

Agency leller dated March 9, 2011 

0 Resubmission in response to Agency leller dated 0 "Me Too" Application. 

0 Notification' Explain below. 0 Other - Explain below. 

Exp[anation: Use additional page(s) if necessary. (For Section [ and Seclion [I.) 

Section - III 

1. Materia[ This Product Will Be Packaaed In: 

Child-Resistant Packaging U~ckaging W~ Soluble Packaging 2. TVDe of Container [ij Ye,' Ye, Yes Meta[ 

X No T No ~ No X Plastic 

If "Yes" No. per If "Yes" No. per G[ass 

* CertmcaUon must Unil Packaging wgl. container Package wgt container Paper 

be submitted I Other (Specify) HDPE lined bags 

3. Location of Net Contents Information 4. Size(s) Relai[ Container 5. Location of Label Directions 

[K] Label D Container 2.5 gallons EJ On Labe[ 

X On Labe[ing accompanying product 

6. Manner in Which Labe[ is Affixed to Product § Uthograph 0 Other - X Paper glued 

Stenciled 

Section - IV 

1. Conlact POint7Cor1lD7ete items dfrectiV below for identification of individual to be contacted, if necessa ,10 rocess J~i~ lication. 

Name 1 TIt[e 1 ~e~~~hone No. ([nc[ude A,e,b Code) 

Lori Koh[er AQent for Willowood, LLC 302 635'-{.('61 

Certification ':.'6. lJa~e App[~cation 

I certify Ihatthe stalements I have made on this form and all allachmenlS thereto are true, accurale and complele. ,~ .. R~l<elved 

I acknowledge that any knowingly false or misleading stalement may be punishable by fine or imprisonment or ' - . both under applicable law. , (S~mped) "''' ,~ ... ' , 2, Sigoature ~ . 1/0. PI A 3. Tit[e . 

~'v '''- Agent forWillowood, LLC '.' ,. . . ~ , , , 

4. Typed Name 

Lori Koh[er Ju[y 15. 2011 - ~"' . , 

" ThiS IS a reproduction of EPA Form 8570-1 (Rev. 8-94) PrevIOus editions are obsolete. 

20
I 

Herbicide -For Postemergence Weed Control in Rice 

ACTIVE INGREDIENT: 

Propanil: 3', 4'-Dichloropropionanilide .................................... 41.4% 

OTHER INGREDIENTS: ........................................................ 58.6% 

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

This product contains 4 lb. of active ingredient per gallon. 

KEEP OUT OF REACH OF CHILDREN 

CAUTION 

See inside label booklet for First Aid, Precautionary Statements and Directions 

for Use including Storage and Disposal instructions. 

EPA Reg. No. 87290-18 

Manufactured For: 

Wllowood, LLC 

1600 NW Garden Valley Blvd. #120 

Roseburg, OR 97471 

Jcb-54257 

54251 propanil 4SC BIt.indd 1 

EPA Est. No. 37429-GA-001 (BT) 0 

7081S-GA-002 (CV) 0 

Letter(s) in lot number correspond to 

letter{s) following the EPA Est. No. 

NET CONTENTS: 30 Gallons 

"'-"'" . .. , " , 

-' 

" , <-, c , , 

, v' c' 

< '. , , , 

" ., , _. c .-

. " 

",1,_ 

c· I' ," , 

, 6/1/l~ ", , .. , , 

, , , ,. c 

. 

21
( f 

FIRST AID 

If inhaled: · Move person to fresh air. 

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

preferably mouth-la-mouth, if possible. 

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

If on skin or • Take off contaminated clothing. 

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

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

lfin eyes: • Hold eye open and rinse slowly and gently with water for 15-20 minutes. 

• Remove contact lenses, if present, after the first 5 minutes, then continue rinsing eye. 

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

If swallowed: • Call a poison control center or doctor immediately for treatment advice. 

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

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

• Do 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. 

2 

54257 prop~nll 4SC 11K. in"" ~ 

, " t, ~ c , , < 

< 

" ' 

, , , , 

. 

<" 

22
( 

PRECAUTIONARY STATEMENTS 

HAZARDS TO HUMANS AND DOMESTIC ANIMALS 

CAUTION 

Avoid contact with skin, eyes, or clothing. Avoid breathing vapor or spray mist. Wash thoroughly with soap and waler after handling. 

Remove contaminate{! clothing and wash balora reuse. 

PERSONAL PROTECTIVE EQUIPMENT (PPE) 

Some materials thai are chemical-reslstanllo this product are natural rubber:t 14 mils. For more Inlonnalion, tallow Instructions in 

Supplement Three of PR Notice 93-7. If you want mOre options, tollow the instructions lor category A on an EPA chemical category 

selection chart. 

Mixers, looder5, end olher handlers cloonlng up spills or oqulpment or otherwise exposed 10 Iho concentrate and handters 

romovlng an unrlnsod probe must wear: 

• Coveralls over long-sleeve shirt and long pants, 

• Chemical-resistant gloves mooe 01 any walerproot materials, 

• Chemical-re~istant footwear plus ~ocks, 

• Chemical-reslstant headgear, if overhead expo~ure, and 

• Chemical resistant apron, when mixing and loading 

• Prote>:tive eyewear if the system operates under p!essure. 

Pilots lind handlers romouing a tripte rinsed probe must weer. 

• Long·sleeved shirt and long pents, 

• Shoe~ plus oocks, and 

• Chemical-resistant gloves mado at any watmproot materiat wch a~ butyl rubber, nitrile rubber, or neoprene rubber (all> 14 mils) 

Se Engineering Controls tor additional requirements and options. 

USER SAFETY REQUtREMENTS 

Follow manufacturer's instructions for cleaning/maintaining PPE.lf no such instructions tor wash abies exist, use detergent and hot 

water. Keep and wesh PPE separately from other laundry. Discard clothing or other ab""rbent materials that have been drenchoo or 

heavily contaminatoo with this product's concentrate. Do not reuse them, 

ENGINEERING CONTROLS 

Mixers and loaders must either: 

(tl use a closed system that meets the requirements listed in the Worker Protection Standard (WPS) tor dermal protection at 

agriculturat pesticides 140 CFR t70.240(d)(4)1, 

OR 

121 Use the probe system described below: 

PROBE SYSTEM 

Specilic requirements for use 01 the probe closed mlxingfloading system: 

Remove plug from bung 01 drum containing this product only when drum rs sitting on the ground or on a secura level platfonn, with the 

bung end of the drum pointed up. 

00 not pour thi" product from its drum. Transfer 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 dn,Im. Do not handle the probe or bung in a manner that allows dripping or ~plaUering of 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 Mple rinsed with 

water. II all of the product Is removed from the drum, then triple rinse the probe while it remains inside the drum. 

3 , ( C C , { 

, " 

, , 

L ____________________________________ ~~'~:·~, l ~ ,-- " ,r ,1.-, -

~42~7 Propanil 4SC DK.indd ,6/I1t'. t:l21" 'c '-' 

23
UN_RINSED PROSES 

II an un-rinsed probe munl bo removed lrom the drum, then use an anti-drip flange, and immediately transfer the probe Into a container 

01 finne water. The anti-drip flange must be designed to remove excess propana product from the proba an It Is extractad from the drum. 

Take the following steps ~ the probe must be disconnected from the suction hose before both the probe and the hose have been triple 

rinsed: 

(t) Eqvip the probe end ot the hose w~h a shut oft varve, 

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

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

ALL TRANSFER SYSTEMS 

In addition. mixers and loaders using all systems must: Wear tho personal protect .... e equipment required in the PPE section of this labeling lor mixers and loaders, wear protect"'e eyewear. ~ the system operates under pressure. and when using a system that meets the 

roquirements in the WPS as a closed system or using a probe system when the probo is not romoved, chemicat-resistant footwear mvst 

be provided, be immediately available. and bo used in an emergency, such as a broken package, spill, or equipment breakdown. 

All systems must be capable of removing the pesticide lrom the shipping contain~r and tmnsfening it into mixing tanks am;!lor application equ~ment. At any disconnect point, tho system must bo equipped \'rith a dry disconnect or dry couple shut-off device that is 

warranted by the manufacturer to min"mize drippage. 

Aaggers' Human flagging ... prohibited. Flagging to support aerial application is limited to uso of the Global Positioning System (GPS) or 

mechanical flaggers. 

Enclosed Cabs for Aerial Applicators: Pilots must use on enclosed cockpit that meets tho requirements listed in tho Worker Protection 

Standard (lNPS) lor agricultural pesticides (40 CFR t70.240(d)(6)). 

User Safety Recommendations 

Usors should: 

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

Remove clothing/PPE immediately if pesticide gets inside. Than wash thoroughly and put on clean clothing. 

Remove PPE Immediately aller handling this product. Wash the outside of gloves before removing. As soon ali possible, 

wash thoroughly and change Into clean clothing. 

Environmontal Hozurds 

this pesticide is toxic to fish and aquatlc inverlebrates. Do not apply directly to water except as specified on this label. 00 not 

contaminate water when cleaning equipment or disposing of equipment wasnwaters or rinsate. 

This chemical has properties and characteristics aSSOciated with chemicals detected in groundwater. The use of this chemical prior to 

flooding may result in shallow grovndwater contamination due to cracks in the subsoil of the rice paddy. 

This product may contaminate water through runolf following rainlall events and by seepage through levees. Runoff of this product will 

be reduced by auoiding applicatkm when rainfall is forecasled to occur w~hin 46 hours. Levees should be constructed with adequate 

lime prior to chemical application so that they are compacted to reduce seepage and to hold a 3 to 6 Inch flood. 

Notlco: ROlld tho ontlre Illbet. Use onty according to lebel directions. Soforo using this product, road Warranty Dlsclalmor. 

tnheront Risks of Uso, and Limitation of Remedies elsewhero on tho 10bol.1f tonns aro unaccopt~blo. roturn at onco unopenod. 

DIRECTiONS FOR USE 

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

Read all Directions for Use caretully before applying. 

Do not apply this product In a way that will contact workers or other person:;, either directly or through drill. Only protected handlers 

may be in the area during application. For any requirements spec1fic to your state or tribe, consult the agency responsible for pesticide 

regulation. 

, " 

4 " ' ~ 

L __________________ ~~'---.;" J', ~ ,-- , , 

54157 Pt"opanil 4SC eK.indd • 

" , , , 

, " , 61I1t'. 

< c' , 

24
( 

Agricuttural Uso Requirements 

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

contains requirements for the protection of agricultural workem on larms, loresls, nurseries, and greenhouses, and handlers of 

agriCI.Jllural pesticides. II contains requirements lor training, decontamination, notification, and emergency assistance. It also 

contains specific Instrucllons and exceptions pertaining to the statements ollinis labe! about personal protective equipment 

(pPE) and restricted-entry interval. The requirements in this box only apply to uses of this product that are covered by Ihe 

Worker Protection Standard. 

Do not enter or allow worker entry into Veale<;! areas during the restricted entry interval (REI) of24 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: 

Coveratl~ over long-sleeveshirt and long pants 

Chemical-resistant gloves made of any waterproof materials, 

Chemical-resistant tootwear plus socks, 

Protective eyewe;rr 

STORAGE AND DISPOSAL 

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

Pe5t1c1do Storngo: Ground all metal containers when transferring product. Protect trom freezing. It stored below 32'F and 

crystats torm, w;rrm to 72°F tor 24 hours, periodically shaking or rolling container to reconstitute. 

Pestlcldo Disposal: Pesticide wastes are toxic. Improper disposel of excoss pesticide, spray mixture or rinsate is a violation 

ot Federal Law. Wastes resulting from the use 01 tht5 product must be disposed ot on site or at an approved waste disposal 

facility. If these wastes cannot bo disposed ot by use accord"'g to label instructions, contact yourStato Pesticido or 

Environmental Control Agency, orthe Hazardous Waste representative at the nearest EPA region otfice for guidance. 

Container Handling: NONREFILLABLE CONTAINER (EQUAl TO OR LESS THAN 5 GAlLONS): Do not reuse or rolill this 

container. Triple rinse container(or equivalent) promptly atter emptying. Triple rinse as tollows: Empty tho rcmaining conlimts 

into application equipment or a mix tank and drain lor to seconds atter the How begins to drip. Fill the container I'< tull with 

water and recap. Shake tor to seconds. Pour rinsate into application equpment or a mix tank or store rinsate for later use 

or disposal. Drain for to seconds alter tho How begins to drip. Repeat this procedure two more times. Oller for recycling, if 

available. 

NONREFILLABLE CONTAINER (GREATER THAN 5 GAlLONS): Do not reuse or retill this container. Triple rinse container (or 

equivalent) promptly after emptying. Triplo r"'se as tollollls: Empty the remaining contents into application equipment or a 

mix tenk. Fill tho containor 'Ii full lIIith lIIater. Replace and tighten closures. Tip container On its side and roillt back and torth, 

ensuring at loast ono complete revolution, for 30 seconds. Stand the container on its end and tip it baCk and torth several 

times. Tum the container over onto its other end and tip it back and torth severallTmes. Emptythe rinsate into application 

equipment or a mix tank or store rinsato tor lator Use or dlsposal. Repeat this procedure tll/O more times. Olter for reCYCling, it 

available. 

REFILLABLE CONTAINER; Refill this container with posticido only. Do not reuse this container for any other purpose. Cleaning 

the container before final disposal Is tho responsibility ot the person dlEposing ot the container. Cleaning before relilling is tho 

responsibility ot tho rofiller. To clean the conta"'er belore final disposal, empty tho rcmaining contents trom this container into 

application equipment or mix tanl<. Fill the container about 10 percent tull with water. Agitate vigorously or recirculate weter 

with the pump for 2 minutes. Pour or pump rinsate into application equipment or rinsate collection system. Repeat tht5 rinsing 

procedure two moro times. 

5 ... " , 

L-____________ ~~~l.-

54257 propanil 4SC BK.indd 

.. 

• 

• " . 

. , 

,.1,--

.1.' 

, " < < 

25
( 

PRODUCT INFORMATION 

Willowood ?ropanll4SC for postemergence weed control in rice is formulated as a suspension concentrate containing 4 Ib actiue 

Ingredient per gallon. Willowood Propanil4SC is not a hormone-type herbicide, but kills susceptible weeds by direct contact action. For 

thi~ reason, thorough coverage of emergeclweecls is essential forbes! re<'..ults. Willowood Propanil4SC has no preernergence o.residual 

herbicidal aCliuity. Only weeds that ha\.le emerged and are exposed at time of application will be controlled. Apply Wjlowood Propanil 

4SC only to fields that haUl! been drained 01 fioodwater. Willowood Propanil4SC Is most effectiue if applied when susceptible graMas 

and broadleafweeds aresmall and growing actively under fauorable soil moisture and Weather condlions. Early weed control removes 

weed competition from the rice crop, salleS mol5ture, and generally contributes to increased yields, 

Read Mlxtng and Equipment label instructions before application. When tank mixing, always read all indluiduat manufacturers' labels. In 

interpreting all labels for the tank mixture, the most restrictive ~Ituatlons must apply, 

Chomlgatton: Do not apply this product through any type of Irrigation system. 

SPRAY DRIFT MANAGEMENT 

AUoiding spray d@attheapplic:ationsltelstheresponSibilityoftheapplicator 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 connldering all these 

factors when making decisions. 

The following drilt management requirements must be followed to avoid off-target drill mouement from aerial applications to agricultural 

r~dcrops. 

1. The distance of the outermost operating nozzles On the boom must not exceed 3/4 the length of the wingspan or 90% of 

the rotor blade diameter. 

2. Nozzles must always point backward parallel w~h the air stream and never be pointed down<vards more than 45 degrees. 

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

The applicator should be familiar with and take into account the information couered in the lollowing Aerial Orift Reduction Advisory. 

AERIAL DRIFT REDUCTION ADVISORY 

Infonnotlon on Droplot Slzo:lhe mOSI elleelive way to reduce drilt potential Is to apply large droplets. The best drift management 

slfategy is to apply the largest droplets that provide sufficient couemge and control. Applying larger droptets reduces drift potential, but 

will not preuent drift Ii applications are made improperly, or under unfavorable environ menial cond~ions (see Wind, Temperature ruld 

Humidity, ruld Temperature Inuerslons). 

Controllin!:/ Droplot Size: 

Volumo * Use high fiow rate nozzles to apply the highest practical spray volume. Nozzles w~h higher mted tlows produce 

larger droplets. 

Pros~ure· Use the lourerspmy pressures recommended for the no;ule. Higher pres.sure reduces droplet size and does not 

Improve canopy penetration. When higher flow rates are needed, use higher flow rate nozzles instead of increasing preSS\Jre. 

Number of Nozzlos - U~ethe mln"mum number of nozzles that prouide uniform couerage. 

Nozzle 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. 

Noula Typo - Use a nozzle type that Is designed for the Intended application. With most nozzle types, narroUrer spray 

angles produce larger droplets. ConnlderuSing 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 hetght greater than tOfeet 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 

euaporation and wind. 

Swath AdJustmont: When applications are made with a cross wind, the swath will be displaced downwind. Therefore, On the up and 

downwnd edges of tho field, the applicator must compensete forthls displacement by adjusting the path of the aircratlupwind. Swath 

adjustment distance should increase with "'creasing drilt potential (higher wind, smaller drops, etc.l. 

, " 

6 

54257 propanil 4SC 8K.indd 6 

t' « '.' , 

" " , 

, 

" " , 

, 

" 

,--

, ".1, __ 

I ' ", , 

,6/1I2l 1:121" 

" " 

26
( 

Wind: Drift potential;$ lowes! between wind speeds 01 2-10 mph. However, many/actors, including droplet slzo and equipment type, 

determine dnft potential at any given speed. Application should be avoided below 2 mph due to venable wind dTrecfion and high 

inversion potential. Note: Local terrain can influence wind p~ttems. Every applicator should be familiar w~h local wind patterns and how 

they affect spmydrift. 

Temperature and Humidity: When making applications in low relative humidity, set up equipment to produce larger droplets to 

compensate lor evapomtion. Oroplet evaporatlon;s most severa when conditions are both hot and dl)'. 

Tampcratur(! Inverstons: Applications should not occur during a local, low level temperature inversion hecavse drift potential is high. 

Temperature inversions restrict vertical air mixing, which causes small suspended droplets to remain in a concenlrated cloud. This 

cloud can move In unprediclable direclions due to the lighl va-iable winds common during Invemions. Tempermure in~ersions are 

characterized by increasing temperature w~h altitude and are common on nights with lim~ed cloud cover and light to no wind. They 

begin to form as the sun sets and often continue into the moming. Their presence can be indicated by ground fog; however, if log is 

not present. inversions can aiso be Identilied by the movement 01 the smoke from aground sourea or an alreralt smoke generator. 

Smoke that layers and moveslateralty in a concentrated cloud (under loW wind conditions) indicates an inversion. whil$smoke that 

moves upward and rapidly dissipates indicates good vertical air mixing. 

Sonsitive Arens: The pesticide should only be applied when the potential for dift to adiacent sensitive areas (e.g .• resTdentialareas. 

bodies of water. known habitat forthreatened or endangered species. non-target crops) is minimal (e.g .. when wind is blowing away 

from the sensitive areas). 

Spray Drift Rostrlcttons for Aft Statos 

Apply only When the wind speed Is less than orequal to to mph at the application site. 

Apply as a medium or coarser spray (ASAE standard 572). 

For ground applications. apply vslng a nozzle height of no more than 4 feet above the ground or crop canopy. 

For aerial applications, do not apply by air if drift can occur to sensitive nontarget crops or plants that are within 100 feet 

01 the application site. Do not release spray at a height greater than fO teet above the ground or crop canopy. The boom 

length must not exceed 75% ot the wingspan or 90% ot the rotorbtade diameter. 00 not make any type of application into 

temperature inversions. 

For Use 00 Rice Grown in California Only 

Restrictions 

PretmlVOst Interval: Do not apply this product w~hin 60 days of rice harvest. 

Chomlglltlon: 00 not apply this product through any type 01 irrigation s~tem. 

00 not apply mOle than a maximum of 6 quarts ot Willowood Propanil4SC (6 Ib active ingredient) per acre in a single 

application or exceed a quarts ofWiliowood Propan~ 4SC (6 Ib of active ingredient) per acre total dosage per season. 

In Callfornlo: Use Willowood Propanil 4SC ontywhere rice fields are completely drained or a minimal amount of water 

remains. II high water level In desired, re-tlood field after 12 hours and before 7 days after treatment. This will discourage 

new weed infestations. 

00 not apply this product to any crop other than rioo. Willowoed Propanil4SC will cause iniury to most crops except cereal 

grains and perennial grasses. 

Do not ~pply this product (directly or Indirectly) to wild rice (Ziz.Jnia spp.). 

Avoid drift or aCCidental application from turning aircraft on cotton, soybeans, corn, safflower, seedling legumes, vegetables, orchards, vineyards, gardens, shrubs and ornamentals. Once applied, Willowood Propanil4SC does not release 

fumes hazardous to nearbycroj)5. 

Do not apply to fieldS nor drain water from treated fields into areas where commercial catfish or crayfish (crawfish) tanning 

is practiced. 

Do not graze treated fields or foed treated forage within 60 days otthe last application. 

Do not retatll treated land to other crops or transplant to crops other than nee for 60 days following treatment of this 

product. 

Do not apply this product within 14 days before or alter carbamate or organophosphate insecticide applications. Otherwise, 

serious iniurles to rice may occur. 

" 

7 

54257 propttnil 4SC aK.indd 

, " 

, , 

, 

, 

c < , ' , 

, ,c,' ' 

, 

" 

,--

,,1:_-

"I, ' 

, 6/t/ll 

27
( ( 

For Use on R!ce Grown jn California Onlv {continuecO 

RoslrlcUons 

Waler drained from treated rice fieldS must nol bn used to irrigate other crops or released within 112 mile upstream 01 a 

potable waler Intake In flowing water (e.g. river, stream, etc.) or w~hjn 112 mile of a potable waler Intake in a standing body 

of water, such as a lake, pond, o.reservoir. 

Do not apply when weather cond~ions fauo. drift from area 10 be treated. 

Emergency Release Provisions 

Do not discharge waler from treated rice paddies in California following treatment, unless eKcessive rainfall completely submerges Ihe 

rice crop and forces premature release, for: 

7 days in dry seeded rice in Calffomia 

7 days for water-seeded rice in California 

Weeds Controlled 

Annuel sedges Cypen1S spp. 

Barnyardgrass • Echinochloo C1I1s·garli 

Crabgra:m Digifaria spp. 

Early watergrass U Echfnochloa ol)'ZOides 

Junglerice' E. colonum 

Late watergrass" Echinochfoa phyllopogon 

Ricefleld bullruoh Sclrpus mucronatus 

Rice !latsedge Cypervslrla 

Smalltlower umbrella plant Cypervs diiformis 

nces blot esof am ard rass/wale rassma develo thai cannot e effectiuel coni Iledb , • In isolated insta , yp b Y g rg Y P b y ro y p opanil alone. 

Where Ihese blotypes are known or suspecled to be present, and are found In a mlKed weed populatton In which 'Nillowood Propanil 

4SC Is effective, tank mix Willowood Propanil4SC at labeled rate with other rice herbicides Ihat are recommended for control of 

bamyardgrasslwatergra~ (up to the 3 leal sI~ge). 

b Applications to early and late watergrass made past the 4 leaf stage will result in parttal control. 

Timing and Dosage Recommendations 

E~rly Tlmtng and Rates 

ApplyWiliowood Propanil4SC when a saUsfactorystand of rice has been established th~t will tolerate flooding. The amount ofWiIlowood Propantl4SC 10 apply depends upon the growth stage and condllion of the target weeds. Willowood Propanil4SC ts most 

effactiue if applied when susceptible grasses and broadleaf weeds are small and actively growing underfauorable soli moisture and 

weather conditions. Use a higher rate In the recommended rate range for heavy weed Infestalions, WOOds In advanced slages of growth, 

or when growing conditions are tess than optimum. Emergency treatments m~de 10 well{ls in advanced growth stages, such as when 

grass weeds are tillering, must occur at least 60 days belore harvest. 

For best results, apply'Nillowood Propanil4SC at the rate of 3to 4 quarts (3t041b active ingledientl per acre when the grasses are 

actively growing in Ihe 1to early41eaf stage. This rate will aloo control many seedling broadleat and aquatic weeds. Generally, this will 

be 15 to 25 days afterplanling. In order to Insure satisfactory weed control, do nol apply less than 3 quarts of Willowood Propanil4SC 

per acre In a single sprayaWlication. 

8 "" , 

.. , 

". , 

54257 J;'rop~nil 4SC ell.indd e ,., , 

"·1 .. 

6tH}1 

" " , 

.. ,., . 

28
Restrictions 

( 

For Use on Rice Grown in Southern United States Only 

Arkansas, Louisiana, Mississippi, Missouri, Texas 

Preh8rvem Intorval: Do not apply this product wilhin 60 days 01 rice harvesi. 

Chomfgllt1on: Do not applythls product through any type of irrigation system. 

Do not apply more than a maximum of 6 quarts of Willowood Propanl14SC (Bib active Ingredienll per acre In II single 

appllcallon or exceed 8 quarts 01 Willowood Propanl14SC (8 Ib 01 activo Ingrenlent) per ecretotal dosage per season. 

Do not plant or transplant crops in the treated area for at leasl 60 days following appllcallon. 

Do not apply Ihls product to any crop olherthan rice. Willowooo Propanil4SC will cause injury to most crops except cereal 

grains and perennial grasses. 

Do not apply Ihls producl (direcllyor Indireclly) to wild rice (Zizania spp.). 

Avoid drift or accidental application from turning aircraft on collon. soybeans. corn. salflower. ~eedling legumes. 

vegelables, orchard~. vineyards. gardenn. shrub~ and ornamentals. Once applied. Willowood Propanil4SC does not release 

fumes hazardou~ 10 nearby crops. 

Do not appty to fields nor drain water from Irealed fields Inlo areas whera commercial catfinh or crayl<sh (crawli:lh) farming 

is practiced. 

Do not graze treated fields or feed treated forage w~hin 60 days of the last applicalion. 

00 not rolate trealed land to other crops or trannplant to crops other than rice for 60 days following trealment of this 

product. 

Do not apply this product wilhin t4 days before or after carbamate or organophosphate inseclicide applicalions. Otherwise, 

serious injuries to rica may occur. 

Water drained from Ireated rics fields must not be used to irrigate other crops or released wilhin fl2 mile upstream of a 

potable water intake in flowing water(e.g. river, stream, etc.) or w~hln 112 mile of a potable waler Inlake In a slandlng body 

of water, such w;; a lake. pond, or reservoir. 

Do not apply when weather cond~ions favor drift from area 10 be lreated. 

Emergency Release Provisions 

Water holding (discharge) intervals for flood water from trealed rice paddles following trealment in Ihe ~oUlhern Unlled Slates (M. LA. 

MS, MO. and TX): 

For delayed flood (water-seededl rice grown south of Interstale Highway to from the TexasILouisiana border 10 Houslon 

and east of Stale Highway 35 from Houslon 10 Port Lavaca- Flood waler musl be held for to days afler applicallon. unless 

excessive rainfall completely submsrges the rice crop and forces premature release. For Texas rice grown in areas north or 

west of these boundaries. the water holding inlerval will be 7 days. 

For delayed flood JlVater-seeded) rice In southern Louisiana south of Highway t4 - Flood water muSI be held for 15 clays 

after propanll application. unless excessive rainfall complelely submerges the rice crop and forces premature release. For 

delayed flood (water-seeded) rice in Loulsiana. north 01 the Highway 14 boundary. the waler holding interval Is 7 days. 

For rice in all other parts of Ihe ~outhem Uniled Siaies not menlloned above- Flood waler mu~t be held for 7 days after 

application unless excesllive rainfall completely submeryes the rice crop and forces premature release. 

, " 

11 

----------------------------------------------------c-----------------------------"CC7<-C----~'"',_J ,<I'" ,---

, , , ~ : " : r ,---

54257 proponil 4SC 8K.ind<! u 

", , 

, ' , 

29
Weeds Controlled 

Willowood PropanU 4SC provides selective poslemergence control of the following weeds in rice: 

Annual sedges Cyperus spp. 

B~rny~rdgrass • Echinoc/lfoa crus-galli 

Beakrush (spearhead) Rhynchospora comicul<!ta 

8roadleaf signalgra&i Bmcharill platyphylill 

Crabgrass Digi/ario spp. 

Curly dock Auroox crispus 

Foxtail Setaria spp. 

Goosegrass Eleusine indiC<! 

Gull cockspur Echlrrochloa crus-pavonls 

Hemp sesbanla (coffeabean) Sesbania herbacea 

Hoorahgrass Fimbrislylis rniliaceaa 

Junglerice' E. cofonum 

Mexicanweed Caperonill castanaefor."a 

Parngrass Panlcum purpurascens 

Redroot pigweed Amaronlhus relroflexus 

Redweed Mefoch/a corchorifolia 

Rice fiatsedge Cyperus fria 

Smallflower umbrell~ plMt Cyperus difformis 

SpikefUsh [wiregroilS) Eleocharls spp. 

Texas panlcum Pan(cum texanum 

Watergrass' Echinochfoa spp. 

Woolly croton Crotonspp . 

• In isolated instances, biotypes of bamyardgra5Sl'watergrass may develop that cannot bo effectively controlled by propanil alone. 

Where these blotypes are known or suspected to bo present, and ate found in a mixed weed population in which Willowood Propanil 

4SC Is effective, tank mix Willowood Propanil 4SC at labeled rate with other rice herbicide51hat are recommended for control 01 

barnyaIdgrasslwatergrass (up to the Sleaf stage). 

Timing and Dosage Recommendations 

Early Timin9 and Rates 

Apply Willowood Propanil4SC when 3 satisfacto!), ~and 01 rice has been established that wiliiole/ate flooding. The amount of 

Willowood Propanll4SC to apply depends upon the growth siage and cond~ion 01 the target weeds. Willowood Propanil4SC Is most 

effeclive if applied when susceplible grasses and broadleaf weed5 are small and actively growing under favorable $011 moisture and , c , 

12 

'---------------------------------------------------------------------------------------------"",-ccc-----~'~ cc:c. ~" 

" ' " I " , " ,--

54257 propanil 4SC B~.indd " c 6/1111 1,121" " " " 

30
( ( 

weathercond~ions. Use a higher rate in Ihe recommended rale range for hea"Yweed infestations, weeds ,n advanced stages 01 growth, 

or when growing conditions are lass than optimum. Emergencylrealmenls made \0 weeds in ad~anced growth slagel>, such as when 

grass weeds are lillerin9, must occur at leasl60 days before harvest. 

Forbesl results, applyW,llowood Propanli4SC at the rale 01310 4 quarts (3 to 4 Ib active Ingredient) per acte when the grasses are 

actively growing In the 1 to early41eaf stage. This rale will also control many seedling broadleaf and aquatic weeds. Generally. this will 

be 1510 25 days after planting. 

Mid-Timing and Rates 

Willowood Propanil4SC can be applied allhe rale of 410 6 quarts (4 \0 61b aclive ingredient) per acre \0 actively groWOlg grasses in the 

4 to 0 leaf and early tillering stage. or when they are in the 2 to 4 leat stage but stressw under dry soil conditions. Generally. this will be 

201030 days after planting. 

Uso of Surfactants: The addition of a crop oil con centrale all10 2 pinls per acre. or olher 80% active nonlonic surfactant al a rate of I 

102 pinls per 100 gallons of spray mixture. is recommended. 

Rescue TIming and Rates 

ApplyWillowood Propanil4SC at Ihe rate of 510 8 quarts (510 6 Ib a<;live ingredient) in 15 gallons 01 spray per acre for emergency 

control of older tiltering grass. Generally. this will be 30 to 40 days after planting. If the field is alreaclyflooded, Ihe water should be 

lowered ordratned before spraying 10 expose more oflhe gra:;s and weeds. Emergency Ireatmenl should be conslderad as a salvage 

operation only and cannot be relied upon for lotal control of grass and wews. 

Mixtng Dtroctions 

Willowood Propanil4SC will disperse more quickly if water temperature is 50"F or warmer. Une only dean water for spraying. With Ihe 

pump and aghtor running, slowly add the recommended amounl 01 Willowood Propanil4SC into a partially filled mix tank. The iet or 

tank agitators must be positioned to creale a rippling or rolling action on Ihe liqutd surface and 10 provide complete agitation at tho 

bollom of the lank. prevenling de3d spots whero tho material can accumulate, A cenlrilugal pump is suggesled 10 provide additional 

propeller shear action lor dispersing and mixing this prodUct. To avoid foaming. keep filling and bypass lines below the liquid surface. 

Willowood Propanil4SC musl be completely dispersed and mixed prior 10 application. 

II a lank mixture in 10 be applied. always conduct a compalibilitylesl priorlo use by mixing proportional amounts of all spray Ingredients 

in a tesl vessel Uar). The order o! addition 10 waler should be dry fiowables orwettab!e powders firsl, Uowables second. liquid formulalions third. and ClOp 011 concentrate last. Allow for each material 10 go into solution priorlo the addnion oflhe next material. Shake the 

mbClurevigorously and allow it to sland for fifteen minutes. Rapid precipitation of Ihe ingredienls and failure 10 re·suspend when shaken 

indicates Ihal the mixture is incompatible and shOUld not be applied. 

As each materia! is added to the spraymlldure, always allow for complete mixing before adding the next ingredient. Add crop oil 

concentrate lasl and continue agitation whila filling the mixing tank 10 Ihe desired spray volume. 

Do nol add Willowood Propanil4SC directly 10 the spray lank 01 ail(:rait. Once properly dispersed in mix tank. pump spray mixturelo 

aircraft sprnylank (include rinsate from miX lank). To ensure unilormrty of sprays. maintain good agitalion throughoul epplication. 

Application Equipment 

Aircraft 

Rxed wing aircrn!1 orhelicoplers shoutd have well-designed spray systems Ihat produce a unilorm pallem 01 medium·!ine spray drop· 

lets, Apply Willowood Propani! 4SC in no!ess than 10 gallons of IOt31 spray per acre wilh boom-nozzle sprnyers. Increase volume 10 12 

to 15 gallons per acre for larger or deMerstands of grass or during periods o! low humidity. 

The optimum effective spray !Wath width depends on operating conditions and Iype o! airerall being used. For uni!orm spray coverage 

wilh fixed-wing aircraft or helicopter, spray swath width shOUld not exceed the width o! wing span or rotor plus \0%. Measure Ihe 

swaths aecurately for lIagging. 

Ground Sprayers 

U~e slandard lov,..pressure herbicide boom sprayers equippod with fiat fan nozzles. Una nozzle sizes that deliver a mediUm-line droplet 

in 151020 gallons lotal spray per acre a! 40 10 50 psi and e\ ground spews nol in excess of 3 to 4 mph. Adiust boom heighl so noule 

spraypallems meel uniformity. Avoid raising boom too high. 

Rush all equipment with clear water after each day's use. Clean all equipment. including nurse lanks. used for Willowood Propanil4SC. 

with detergent wash followed by a water rinse. beforo end after spraying other pesticides or olher crops. 

13 " , , , 

, , , 

, 

" 

, " " ~ ,-- '" , " , , 

, 

, " 'I , " " «' , , 

, ,{ (I , G/1/~1 l: 12 lmi 

" " SUS7 fropanil 4SC eK.indd 13 

31
( 

Crop To!eronco and Growing CondlUons 

All leading commercial varletles of rice are Qxceptlonallylolerant 10 WilloW<'.lod Propanil4SC. A temporary yellovring or lip bum Q\ rice 

may be noted after treatment, but new growth,s normal. Severe leaf burn and partial killing 01 rice may occur ij Ihe product is applied 

when rice i~ under stress and in a weakened growth condition due \0 disease or Insecllnfeslations, excessive soil salls, ovelWalering, or 

prolonged drought and extremely hOi weather. Growers are cautioned no\lo spray under such conditions ancJ/orwnen mrudmum daily 

temperatures have been or are expected \0 exceed 100°F, 

Effect of Climatic Conditions and Cultural Practices on Weed Control 

Fiold and Soedbod PreparaUon 

FIelds shOUld be accurately leveled and contoured and have well-prepared seedbed~ free ot clods. Such conditions encourage uniform 

and rapid emergence of rice. graus and broadleat weed~. allowtng more accurate timing and coverage 01 Willowood Propanil4SC 

sprays for optimum weed control. 

Wator Management 

Before application of Willowood Propanil4SC, drained or dry planted fields shOUld be fiushed as ollen as necess3ry to prevent drying 

and crusting. Flushing encourages uniform emergence and vigorous growth of grass. broadleat weeds and rice. which is essential for 

optimum weed control Flushing ot fields shOUld occur when weeds and rice are actively growing et time of treatment. Make sure the 

field Is drained prior to treatment so that grasses and broadleaf weeds arefulty exposed. Weeds that are p1lrtially submerged In standing 

water at time of application will not be satislactorily controlled. 

Treated tlelds should be lIooded before a ~econd intestation of gr= develops. To prevent additionalgras~ weed seed trom germinating. 

rice tields should be flooded within 24 hours after spmying, or as soon as possible alter24 hours. 

Tompomtum 

The temperature a few days before and atter applying W,lIowood Propanl14SC has an Important effect on tha weed·killing activity. The 

activity Increases as daily maximum temperatures Incraase abova 7soF and decreiWes as tha daily maximum temperatures decline below 7S'F. Do not apply Willowood Propanil 4SC when maximum temperetures have been or are expected to ~ey below 6S"F or exceed 

100'F. Les:; than optimum temperature at time 01 application Is not critical so long as the temperature exceeds 75"F during the day. 

Retatlvo Humidity and Ratn 

Grasses and weeds are more respon~ive to Willowood Propanil 4SC during periods of high humidity when the 10liBge is moist or 

covered by dew. When the humidity Is very low, spray tends to evaporate belore reaching weed fOliage. For best results under low 

relative humidity conditions. Increase spmy volume to 12to t5 gallons par acre. Do not ~pmy if rain i~ expected within 8 hours to avoid 

loss ot deposited spray and herbicide ad~orplion by the weed'>. 

Wlod 

Do not apply when tho wind spoed oxceods \0 mph to avoid drift hazard to ~en~itive crop~ and the po!)Sibility of uneven (~treaked) 

applications. 

CompaUblllty WIth Dthor Chomlcals 

Tank mix applications of Willowood Propanil 4SC with other herbicides. inseclicide~, ~pray adjuvants, or liquid fertmzers may reduce 

crop tolerance andlor weed control or impair mixing properties. U~e otthese procluct~ in tanlrmix applications with Willovrood Propanil 

4SC is done at the u~er's risk. 

Uquld ForUizor: Promixing thi~ product in a mtio of 1 part Willowood Propanil4SC to 2 paris water is recommended prior to mixing 

wah liquid fertilizer. 

Adverse Roaction to Insoctlcides 

Rice plants may bo soverely injurod or kill~d ifWiliowood Propanil4SC i~ applied in tank mix combinations or sequentially before or aller 

certain insecticides. Do not combine Willowood Propanil4SC with carbamate insectTcides such as carbaryl. etc .• or organophosphorus 

insecticides (such as melathion and methyl parathion. etc.]. Do not apply any 01 the carbamate or organophosphorus insecticides to rica 

fields within 14 days before or afterWillowood Prepanil4SC. Do not use carbamate or systemiC organophosPloru~ insectiCides on rice 

fields to be treated with Willowood Propanil4SC. 

Do not apply Willowood Propanil4SC to rice linlds planted with rice seed treated with bird repellents containing methiocarb. Consult 

local Exten~ion specialist tor current re\:ommendation~ 01 approved insecticides on rice. 

, C< 

14 C( c< ~I' 

----------------------------------------------------------------------------------7~CC._C<'C_----'t~~ ( __ __ 

S42S7 propanil 4SC aK.indd 

, , , < c ~ 

, , 

" , ' < , 

, c, <" 6ftla 

(( " " 

" 

32
( 

LIMIT OF WARRANTY AND LIABILITY 

IMPORTANT: READ BEFORE USE 

Read the entire Directions tor Use, Cond~ions, Dl:;ctaimer of Warranties and Limitations 01 Liability betore using this product. If terms are 

not acceptable, retum the unopened product container at once. 

By using this product, user or buyer accepts the following Conditions, Disctaimer 01 Warranties and Limitations of Liability. 

CONOmONS: The directions for lise 01 this product are believed to be 3dequate and mU5! be followed caretully. 

However, it Is impossible to eliminate all ,i~ks assOCiated with the u~e of this product. Crop injury. ineffectiveness or other unintended 

consequences may result because 01 such tactors as weather conditions. presence of other materiats, or the manner of lise or epplicaUon, all of which are beyond the control 01 Willowood, LLC. To tha extent conslstent wah applicable law, all ~lIch risks shalt be assllmed 

by the user or buyer. 

OISCLAlMER OF WARRANTIES: TO THE EXTENT CONSISTENTWlTH APPLtCA8LE LAW, WILLOWOOD, LLC MAKES NO OTHER 

WARRANTIES, EXPRESS OR IMPLtEO, OF MERCHANTABILITY OR OF FITNESS FOR A PARTICULAR PURPOSE OR OTHERWISE, 

THAT EXTEND BEYONO THE STATEMENTS MADE ON THIS LABEL. To the extent consistent with appliceble law, no agent 01 Wit--

lowood, LLC is authorized to make /lily warranties beyond those contained herein or to modify the warranties contalned herein. TO 

THE EXTENT CONSISTENT WITH APPLICABLE LAW, WILLOWOOD, LLC OISCLAlMS ANY LIABILITY WHATSOEVER FOR SPECIAL, 

INCIDENTAL OR CONSEQUENTIAL DAMAGES RESULTING FROM THE USE OR HANDLING OF THIS PRODUCT. 

LIMITATIONS OF LIABILITY: TO THE EXTENT CONSISTENT WITH APPLICABLE LAW, THE EXCLUSIVE REMEOY OF THE USER OR 

BUYER FOR ANY AND ALL LOSSES, INJURIES OR DAMAGES RESULTING FROM THE USE OR HANDLING OF THIS PRODUCT, 

WHETHER IN CONTRACT, WARRANTY, TORT, NEGLIGENCE, STRICT LIABILITY OR OTHERWISE. SHALL NOT EXCEEO THE PUR· 

CHASE PRICE PAID, OR ATWlLLOWOOO, LLC'S ELECTlON, THE REPLACEMENT OF PRODUCT. 

EPA 20t10309 , " 

15 

54257 propanil 4SC lIK.imld is 

" l" , , , 

, " , 

33
( 

, " 

" , " , " 16 , , , 

" '-__________________________________________________________________________________________ ~~~~~4~ 

~4257 ~rop4nil 4SC BK.indd " 

c { ( C c , 

, ( { ({ c 

, ' , ( { ( "I ' , (, {<, 

, " 

34
Material to be added to an e-Jacket/Jacket 

Reg. No. Decision # 45013>1 

Description: 

1. Placement within the e-Jacket/jacket: 

lEi Default: (chronological, top = newest) 

D File Location: (eg. "before page 45 in .pdf') 

2. D Send to Data Extraction contractors this material: 

D Newly stamped accepted label 

rzI Notification 

D NewCSF 

D Other: __________ _ 

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

organized and clipped together, NOT STAPLED. Then give the material with 

this coversheet to staff in the Information Services Center (Room S-4900). 

Reviewer: Maggie Rudick 

Phone: 703-347-0257 

Division: RD 

Date: 06/ Of /2011 

Created June 8, 2011 

35
( 

UNITED STATES ENVIRONl\IENTAL PROTECTION AGENCY 

WASHINGTON, D.C. 20460 

Cheryl Wagner 

Willowood, LLC 

c/o Wagner Regulatory Associates, Inc. 

P.O. Box 640 

Hockessin, DE 19707 

OFFICE OF CIIEMICALSAFET\' 

AI\D POLLVT10l\ pnE\'DiTIO:\' 

JUN 8 2011 

Subject: Notification per PR Notice 98-10 - Minor Label Revision 

Willowood Propanil4 SC 

EPA Reg. No. 87290-18 

Application Dated - May 26, 20 II 

Dear Ms. Wagner: 

The Agency is in receipt of your Application for Pesticide Notification under Pesticide 

Registration Notice (PRN) 98-10 for the subject product. 

The Registration Division (RD) has conducted a review of this request for its applicability 

under PRN 98-10 and finds that the action requested falls within the scope ofPRN 98-10. The 

label submitted with the application has been date-stamped "Notification" and will be placed in 

our records. 

If you have any questions regarding this letter, please contact Maggie Rudick at (703) 347-

0257 or rudick.maggie@epa.gov. 

Sincerely, 

Kable Bo Davis, Product Manager 25 

Herbicide Branch 

Registration Division (7505P) 

36
PI ease rea inS rucffons on reverse bfore e con( '" , 

Fo/mAppro" A OMB No. 2070-0060. Approval expires 05-31-98 , \ . ~egistration OPP Identifier Number 

oEPA United States 

Environmental Protection Agency Amendment 

Washington. DC 20460 X Other 

Application for Pesticide" Section I 

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

87290-18 Kable 80 Davis 

4. Company/Product (Name) PM" [8] None Restricted 

Willowood, LLCfWillowood Propanil 4 se 25 

5. Name and Address of Applicant (lnC/ude Zip Code) 6. Expedited Review. In accordance with FIFRA Section 3{C){3) 

Willowood, LLC (b){J), my product is similar or identical in composilion and labeling 

to: 

c/o Wagner Regulatory Associates, Inc. EPA Reg. No. 70506-167 

P.O. Box 640 

Hockessin, DE 19707 Product Name: Starn 4SC Herbicide 

D Check if this rs a new address 

Section - II 

0 Amendment - Explain below. 0 Final printed labels in response to NOTIFICA71 'j 

Agency letter dated (j)ir\ 

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

X Notification _ Explain below. 0 Other - Explain below. JUN - 8 2011 

Explanation: Use additional page{s) if necessary. (For Section I and Section II.) Minor Label change per PR Notice 98-10. This 

notification is consistent with the provisions of PR Notice 98-10 and EPA regulations at 40 CFR 152.46, and no other changes have been 

made to the labeling orthe confidential statement of formula for this product. I understand that it is a violation of 18 U.S.C. Sec. 1001 to 

willfully make any false statement to EPA. I further understand that if this notification is not consistent with the terms of PR Notice 98-10 

and 40 CFR 152.46, this product may be in violation of FIFRA and I may be subject to enforcement action and penalties under sections 12 

and 14 of FIFRA. 

Section " III 

1. Material This Product Will Be Packaged In: 

Child-Resistant Packaging U~ckaging W~ Soluble Packaging 2. T e of Container 5[1 Yes' Yes Yes Metal 

X No X No ex No Plastic 

If "Yes" No. per If "Yes" No. per Glass 

1< Certification must Unit Packaging wgt. container Package wgt container Paper 

be submitted I X Other (Specify) HOPE lined bags 

3. Location of Net Contents Information 4. Size{s) Retail Container 5, Location of Label Directions 

o Label D Container 2.5 gallons, 30 gallons, bulk [ij On Label 

X On Labeling accompanying product 

6. Manner in l/oJhich Label is Affixed to Product § Lithograph 0 Other - X Paper glued 

Stenciled 

Section " IV 

1. Contact Poinl Com lete items direct! below for identification of individual to be contacted, if necessa ,to roces$. th:s c lication. 

Name I Title I ~el~)~'Yl'~.I'l.!('. (Incluce. Ari..a Code) 

Cheryl Wagner Agent for Willowood, LLC 302 635·',2t9 ' 

Certification ' 6. Date Apo;icatic;n 

I certify that the statements I have made on this form and all attachments theleto are true, accurate and complete. ,< t 'R'3Ceived< < c , ~ 

I acknowledge that any knowingly false or misleading statement may be punishable by fine or imprisonment or \ , 

, , \ 

both under applicable law. 

" \\ (Stamped) 

2. Signature 3. Title , , 

. , , , 

I:..5l.. W Agent for Willowood, LLC , , _L c " , , , 

4. Typed Name 5. Date , 

, " " 

Cheryl Wagner May 26, 2011 , 

.. ThiS . IS a reproduction of EPA Form 8570 1 (Rev. 8-94) PrevIOus editions are obsolete . 

37
May 26, 2011 

Document Processing Desk (NOTIF) 

ATTN: Kable Bo Davis, PM Team 25 

Registration Division 

U.s. Environmental Protection Agency 

Office of Pesticide Programs (7504P) 

Room S-4900, One Potomac Yard 

2777 South Crystal Drive 

Arlington, Virginia 22202-4501 

Dear Mr. Davis, 

Subject: Willowood Propanil4 SC, EPA Reg. No. 87290-18 

Notification of typographical label change 

Wagner Regulatory Associates, Inc. 

P.O. 80x 640 

7460 Lancaster Pike, Suite 9 

Hockessin, Delaware 19707 

Wagner Regulatory Associates, Inc., as agent for Willowood, LLC (87290), is submitting the enclosed Notification 

for the above referenced product. The sentence "Avoid drift or accidental application from turning aircraft on beans, 

cotton, soybeans, com, safflower, seedling legumes, vegetables, orchards, vineyards, gardens, shrubs and 

ornamentals" has been modified to include the word "beans" at California Department of Pesticide Regulation's 

request. This sentence can be found on Pages 10 and 15 of the attached label. The word "beans" is highlighted for 

your convenience. 

In support of this request, the following documents are enclosed: 

• Letter from Willowood LLC appointing Wagner Regulatory Associates, Inc. as its agent 

• Application for Pesticide Registration (8570-1) 

• A copy of the revised label with the change highlighted for convenience 

• A copy of email correspondence providing your authorization to submit this change via notification 

If you have any questions about this submission please contact the undersigned at Cheryl@wagnerreg.com or (302) 

635-7289. 

Respectfully submitted, 

~\...-:)~ 

Cheryl Wagner 

Agent for Willowood, LLC 

Enclosures 

" ( , , , 

" " c 

c ,,' , , , , 

<, " 

, 

c ( , , , , 

, , " " 

" " . , 

38
( 

87290.18.20110303.V1.pdf EPA Approved Label 

Willowood Propanil 4 SC 

Herbicide 

NOTIFICATION 

JUN - 8 2011 

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 lb. of active ingredient per gallon. 

EPA Reg. No. 87290-18 

EPA Est. No. 37429-GA-001; 70815-GA-002 

Net Contents: 30 gal. 

KEEP OUT OF REACH OF CHILDREN 

CAUTION 

First Aid 

If inhaled: 

• Move person to fresh air. 

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

respiration, preferable mouth-to-mouth, if possible. 

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

If on skin or clothing: 

• Take off contaminated clothing. 

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

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

If in eyes: 

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

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

eye. 

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

If swallowed: 

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

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

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

• Do not give anything by mouth to an unconscious person. 

Have the product container or label with you when calling a poison control ~nt9:,or 

doctor, or going for treatment. 

Manufactured for. 

Willowood LLC 

1600 NW Garden Valley Blvd. Suite 130 

Roseburg, OR 97471 

Page 1 of 22 

' C c c c , , , , , , , . . , " < t t , . · , " t< , , t 

· , · , " " ( 

" , 

, 

, " ,( 

, , 

( c< " ( , 

, . ( t" " , 

, . " " . , 

39
87290.18.20110303V1.pdf 

Precautionary Statements 

Hazards to Humans and Domestic Animals 

EPA Approved Label 

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

Wash thoroughly with soap and water after handling. Remove contaminated clothing 

and wash before reuse. 

Personal Protective Equipment (PPE) 

Some materials that are chemical-resistant to this product are natural rubber ~ 14 

mils. For 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 un rinsed probe 

must wear: 

• Coveralls over long-sleeve shirt and long pants, 

• Chemical-resistant gloves made of any waterproof materials, 

• Chemical-resistant footwear plus socks, 

• Chemical-resistant headgear, if overhead exposure, and 

• Chemical resistant apron, when mixing and loading. 

• Protective eyewear if the system operates under pressure. 

Pilots and handlers removing a triple rinsed probe must wear: 

• Long-sleeved shirt and long pants, 

• Shoes plus socks, and 

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

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

See Engineering Controls for additional requirements 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 contaminated with this product's concentrate. Do not reuse 

them. 

Engineering Controls: 

Mixers and loaders must either: 

( , , , < , 

, " , , 

, 

c c c , 

, " " . 

< < C , , , ( 

(' ('" 

(1) use a closed system that meets the requirements listed in the Wor".<:dr Pro':ec!lon 

Standard (WPS) for dennal protection of agricultural pesticides [40'I.),:"R: ' 

170.240(d)(4)], OR" , , 

. " , " (2) Use the probe system described below: ' 

Page 2 of22 

" ( " , 

40
87290.18.20110303.V1.pdf EPA Approved Label 

PROBE SYSTEM 

Specific requirements for use of the probe closed mixingfloading system: 

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. Transfer 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. Do not handle the probe or bung in a manner that allows 

dripping or splattering of 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. Take 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 SYSTEMS 

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

equipment required 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 in 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 andlor 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 to minimize drippage. 

Flaggers: Human flagging is prohibited. Flagging to support aerial application is limited 

to use of the Global Positioning System (GPS) or mechanical flaggers.; "; '; , ,,' , , , 

, , . Enclosed Cabs for Aerial Applicators: Pilots must use an enclosed cocklli\ Ihat m·eel. : 

the requirements listed in the Worker Protection Standard (yVPS) for agricultural:, .• :. 

pesticides [40 CFR 170.240(d)(6)]. co:" , " " , · . , , " " 

, 

· 

{', (, 

· 

Page 3 of 22 

41
87290.18.20110303.V1.pdf 

User Safety Recommendations 

Users should: 

EPA Approved Label 

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

• Remove clothing/PPE immediately if pesticide gets inside. Then wash thoroughly and put 

on clean clothing. 

• Remove PPE immediately after handling this produc!. Wash the outside of gloves before 

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

Environmental Hazards 

This pesticide is 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 has properties and characteristics associated with chemicals detected 

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

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

This product may contaminate water through runoff following rainfall events and by 

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

when rainfall is forecasted to occur within 48 hours. Levees should be constructed 

with adequate time prior to chemical application so 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, eitbe[" 

directly or through drift. Only protected handlers may be in the area d~rind appfica\icn. 

For any requirements specific to your state or tribe, consult the ageni:y reiponsible for 

pesticide regulation. tt ~ <c: :. t: 

Page 4 of22 

,( . , • t" t c 

, " . " ' 

· , , . " , 

· 

42
87290.18.20110303.V1.pdf EPA Approved Label 

Agricultural Use Requirements 

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

Standard, 40 CFR part 170. This Standard contains requirements for the protection of 

agricultural workers on farms, forests, nurseries, and greenhouses, and handlers of 

agricultural pesticides. It contains requirements for training, decontamination, notification, 

and emergency assistance. It also contains specific instructions and exceptions pertaining 

to the statements on this label about personal protective equipment (PPE) and restrictedentry interval. The requirements in this box only apply to uses of this product that are 

covered by the Worker Protection Standard. 

Do not enter or allow worker entry into treated areas during the restricted entry interval 

(REI) of 24 hours. 

PPE required for earty entry to treated areas that is penmitted under the Worker Protection 

Standard and that involves contact with anything that has been treated, such as plants, soil 

or water, is: 

• Coveralls over long-sleeve shirt and long pants 

• Chemical-resistant gloves made of any waterproof materials, 

• Chemical-resistant footwear plus socks, 

• Protective eyewear 

Page 5 of 22 

( c < < , c . ,. 

, , 

, 

, " 'c , 

. 

~ ,<. , ,. 

" . , 

, .. < ( <, 

, . , c, " , 

. " " 

43
I 

87290.18.20110303.V1.pdf EPA Approved Label 

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. If stored below 32F and crystals fonm, warm to 72F for 24 hours, 

periodically 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. If 

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

State Pesticide or Environmental Control Agency, or the Hazardous Waste 

representative at the nearest EPA region office for guidance. 

Container Handling: NONREFILLABLE CONTAINER (EQUAL 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 Y. full with water and recap. Shake for 10 seconds. Pour rinsate 

into application equipment or a mix tank or store rinsate for later use or disposal. Drain 

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

Offer for recycling, if available. 

NONREFILLABLE CONTAINER (GREATER 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. Fill 

the container Y. 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 oontainer 

over onto its other end and tip it back and forth several times. Empty the rinsate into 

application equipment or a mix tank or store rinsate for later use or disposal. Repeat 

this procedure two more times. Offer for recycling, if available. 

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

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

responsibility of the person disposing of the container. Cleaning before refilling is the 

responsibility of the refiller. To clean the container before final disposal, empty the 

remaining contents from this container into application equipment or mix tank. ,Fcill, t~e 

container about 10 percent full with water. Agitate vigorously or recir,clil('llp water wi\h 

the pump for 2 minutes. Pour or pump rinsate into application equipinentbr rins,ate, 

collection system. Repeat this rinsing procedure two more times. ,."': '" ',: 

Page 6 of22 

" " , , , , 

., " , 

, 

, 

" " " 

44
87290.18.20110303.V1.pdf EPA Approved label 

Product Information 

Willowood Propanil 4 SC for postemergence weed control in rice is formulated as a 

suspension concentrate containing 4 Ib active ingredient per gallon. Willowood 

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. Willowood Propanil4 SC has no preemergence or residual herbicidal 

activity. Only weeds that have emerged and are exposed at time of application will be 

controlled. Apply Willowood Propanil4 SC only to fields that have been drained of 

floodwater. Willowood Propanil4 SC is most effective if applied when susceptible 

grasses and broad leaf 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 label 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 system 

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 requirements must be followed to avoid off-target drift 

movement from aerial applications to agricultural field crops. 

1. The 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. Nozzles 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. 

, ", 

The applicator should be familiar with and take into account the information cove"jd:in 

the following Aerial Drift Reduction Advisory. : :! 

Page 7 of 22 

, , , c c c' , , 

, , 

" ,'(' , , 

. " , , , 

, . , . . " « 

· , , , " . , , 

, · " " 

· 

• " ... 

· 

45
87290.18.20110303.V1.pdf EPA Approved Label 

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 improperty, or under 

unfavorable environmental conditions (see Wind, Temperature and Humidity, and 

Temperature Inversions). 

Controlling Droplet Size: 

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

volume. Nozzles with higher rated flows produce larger droplets. 

• Pressure - 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. 

• Number of Nozzles - Use the minimum number of nozzles that provide 

uniform coverage. 

• Nozzle 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. 

• Nozzle 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 by 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 of2-10 mph. Ho~ve\'eF, many, . 

factors, including droplet size and equipment type, determine drift potentia'; at allY , 

given speed. Application should be avoided below 2 mph due to varial'*, \'iind ' •• ',: 

direction and high inversion potential. Note: Local terrain can influence Wind pa'1ern~. 

Every applicator should be familiar with local wind patterns and how th'&y '"ffect 'spray 

drift. " ,,' , , , , :, 

Page 8 of 22 

46
87290.18.20110303.V1.pdf EPA Approved Label 

Temperature and Humidity: When making applications in [ow relative humidity, set 

up equipment to produce larger droplets to compensate for evaporation. Drop[et 

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

Temperature Inversions: App[ications should not occur during a loca[, [ow [evel 

temperature inversion because drift potential is high. Temperature inversions restrict 

vertical air mixing, which causes small suspended droplets to remain in 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, iffog 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 [ayers and moves [aterally 

in a concentrated cloud (under [ow 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 

o Apply only when the wind speed is less than or equal to 10 mph at the 

application site. 

o App[y as a medium or coarser spray (ASAE standard 572). 

o For ground applications, apply using a nozzle height of no more than 4 feet 

above the ground or crop canopy. 

o For aerial applications, do not apply by air if drift can occur to sensitive 

nontarget crops or plants that are within 100 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. Do not make any type of application into 

temperature inversions. 

Page 9 of 22 

, <- " <- < , " '. '. < 

, 

, " , <- ( , , , , 

<- ", , , , 

" 

, " ,( 

\ < ( , , " <-, , , , , , c c , , , , " " ' , , , , " " , 

, 

, " , ' , 

47
87290.18.20110303.V1.pdf EPA Approved Label 

For Use on Rice Grown in California Only 

Restrictions 

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

harvest. 

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

system. 

• Do not apply more than a maximum of 6 quarts of Willowood Propanil4 

SC (6 Ib active ingredient) per acre in a single application or exceed 8 

quarts of Willowood Propanil4 SC (8 Ib of active ingredient) per acre total 

dosage per season. 

• In California: Use Willowood Propanil 4 SC only where rice fields are 

completely drained or a minimal amount of water remains. If high water 

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

treatment. This will discourage new weed infestations. 

• Do not apply this product to any crop other than rice. Willowood Propanil 

4 SC will cause injury to most crops except cereal grains and perennial 

grasses. 

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

spp.). 

• Avoid drift or accidental application from turning aircraft on "_""ill,,, cotton, 

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

vineyards, gardens, shrubs and ornamentals. Once applied, Willowood 

Propanil 4 SC does not release fumes hazardous to nearby crops. 

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

commercial catfish or crayfish (crawfish) farming is practiced. 

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

last application. 

• Do not rotate treated land to other crops or transplant to crops other than 

rice for 60 days following treatment of this product. 

• Do not apply this product within 14 days before or after carbamate or 

organophosphate insecticide applications. Otherwise, serious injuries to 

rice may occur. 

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

other crops or released within Y, mile upstream of a potable water 

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

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

pond, or reselVoir. 

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

treated. ,<" < < 

, " • , ( ,i; , 

t (,' , , , " , 

Emergency Release Provisions , , , , < c ,', 

Do not discharge water from treated rice paddies in California following !,6atrneni, : ' 

unless excessive rainfall completely submerges the rice crop and fOrG£~cl1~ematute' c 

release, for: .' " , ( , , • 7 days in dry seeded rice in California :" , , , 

• 7 days for water-seeded rice in California :, , .. , 

Page 10 of 22 

48
87290.18.20110303.V1.pdf EPA Approved Label 

Weeds Controlled 

Annual sedqes Cyperus spp. 

Barnyardgrass a Echinochloa crus-galli 

Crabqrass Oiqitaria spp. 

Early waterg rass a, Echinochloa oryzoides 

Junqlerice a E. c%num 

Late watergrass a,' Echinochloa phy/fopogon 

Ricefield bullrush Scirpus mucronatus 

Rice flats edge Cyperus iria 

Smal~lower umbrella plant Cyperus difforrnis 

a In isolated instances, biotypes of bamyardgrass/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 

Willowood Propanil4 SC is effective, tank mix Willowood Propanil4 SC at labeled rate 

with other rice herbicides that are recommended for control of 

bamyardgrass/watergrass (up to the 3 leaf stage). 

b Applications 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 Willowood Propanil 4 SC when a satisfactory stand of rice has been established 

that will tolerate flooding. The amount ofWiliowood Propanil4 SC to apply depends 

upon the growth stage and condition of the target weeds. Willowood Propanil4 SC is 

most effective if applied when susceptible grasses and broad leaf weeds are small and 

actively growing under favorable soil moisture and weather conditions. Use a higher 

rate in the recommended rate range for heavy weed infestations, weeds in advanced 

stages of growth, or when growing conditions are less than optimum. Emergency 

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

tillering, must occur at least 60 days before harvest. 

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

active ingredient) per acre when the grasses are actively growing in the 1 to early 4 

leaf stage. This rate will also control many seedling broad leaf and aquatic weeqs.,·, 

Generally, this will be 15 to 25 days after planting. In order to insure ~atii3'~8ctory'liv~ed 

control, do not apply less than 3 quarts of Willowood Propanil 4 SC per acre in a, ' 

single spray application. C-l ~ l < ~ l,,' (; 

, , , ' " " , l 

Mid-Timing and Rates ",", , 

Willowood Propanil4 SC can be applied at the rate of 4 to 6 quarts (4.to ,3 Ib active, 

ingredient) per acre to actively growing grasses in the 4 to 6 leaf and early tillerin!) ". 

Page 11 of22 

, ' ( " " , , 

49
( 

87290.18.20110303.v1.pdf EPA Approved Label 

stage, or when they are in the 2 to 4 leaf stage but stressed under 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 nonionic surfactant at a rate of 1 to 2 pints per 100 gallons of spray 

mixture, is recommended. 

Rescue Timing and Rates 

App[y Willowood Propani[ 4 SC at the rate of 5 to 6 quarts (5 to 6 [b active ingredient) 

in 15 gallons of spray per acre for emergency control of older tittering grass. Genera[[y, 

this will be 30 to 40 days after planting. [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 

be relied upon for total control of grass and weeds. 

Mixing Directions 

WiI[owood Propani[ 4 SC will disperse more quickly if 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 Willowood Propani[ 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. 

Willowood Propanil4 SC must be completely dispersed and mixed prior to application. 

[f a tank mixture is to be applied, always condue! a compatibility test prior to use by 

mixing proportional amounts of a[[ spray ingredients in a test vessel Oar). The order of 

addition to water should be dry flowab[es or wettable powders first, flowab[es second, 

liquid fonmu[ations third, and crop oil concentrate last. A[[ow for each material to go 

into solution prior to the addition of the next material. Shake 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 is added to the spray mixture, always allow for complete mixing 

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

while fi[ling the mixing tank to the desired spray volume. 

( " ( 

Do not add Willowood Propanil4 SC directly to the spray tank of airqrpft. Dnce", , , : 

properly dispersed in mix tank, pump spray mixture to aircraft spray tan~ (include' 

rinsate from mix tank). To ensure uniformity of sprays, maintain good:~a!13tion ':".: 

throughout application. . ,.: 

Page 12 of22 

" , , , . 

. " .. , 

... ,. , 

• 

. 

" " " 

50
87290.18.20110303V1.pdf EPA Approved Label 

Application Equipment 

Aircraft 

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

produce a uniform pattern of medium-fine spray droplets. Apply Willowood 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. 

Use nozzle sizes that deliver a medium-fine droplet 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 Willowood 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 Willowood 

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, overwatering, 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. 

Page 130f22 

, "", 

, " , , " , , , , , c , 

, , 

, 

L C < , 

, " " , 

, , , 

" " , ' , " < • < 

, 

<-

, 

51
87290.18.20110303.V1.pdf 

/ 

\ 

EPA Approved Label 

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 seedbeds 

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

and broad leaf weeds, allowing more accurate timing and coverage of Willowood 

Propanil4 SC sprays for optimum weed control. 

Water Management 

Before application of Willowood Propanil4 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, broad leaf 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 in 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 Willowood Propanil4 SC has 

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

maximum temperatures increase above 75°F and decreases as the daily maximum 

temperatures decline below 75°F. Do not apply Willowood 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 is not critical so long as 

the temperature exceeds 75'F during the day. 

Relative Humidity and Rain 

Grasses and weeds are more responsive to Willowood Propanil4 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. For best results 

under low relative humidity conditions, increase spray volume to 12 to 15 gallons per 

acre. Do not spray if rain is expected within 8 hours to avoid loss of deposited spray 

and herbicide adsorption by the weeds. 

, (" 

, ,. Wind ,,"" ,,' 

Do not apply when the wind speed exceeds 10 mph to avoid drift ha*arCi 1,0 sensitive 

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

Page 14 of22 

, 

" , " , 

, " ' , 4 

. 

" 

52
( 

87290.18.20110303.V1.pdf EPA Approved Label 

Compatibility With Other Chemicals 

Tank mix applications of Willowood Propanil4 SC with other herbicides, insecticides, 

spray adjuvants, or liquid fertilizers may reduce crop tolerance andlor weed control or 

impair mixing properties. Use of these products in tank mix applications with 

Willowood Propanil 4 SC is done at the user's risk. 

Liquid Fertilizer: Premixing this product in a ratio of 1 part Willowood Propanil4 SC 

to 2 parts water is recommended prior to mixing with liquid fertilizer. 

Adverse Reaction to Insecticides 

Rice plants may be severely injured or killed if Willowood Propanil 4 SC is applied in 

tank mix combinations or sequentially before or after certain insecticides. Do not 

combine Willowood Propanil4 SC with carbamate insecticides such as carbaryl, etc., 

or organophosphorus insecticides (such 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 Willowood Propanil 4 SC. Do not use carbamate or systemic 

organophosphorus insecticides on rice fields to be treated with Willowood Propanil 4 

SC. 

Do not apply Willowood 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 

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

harvest. 

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

system. 

• Do not apply more than a maximum of 6 quarts of Willowood Propanil4 

SC (6 Ib active ingredient) per acre in a single application or exceed 8 

quarts of Willowood Propanil 4 SC (8 Ib of active ingredient) per acre total 

dosage per season. 

• Do not plant or transplant crops in the treated area for at least 60 days 

following application. 

• Do not apply this product to any crop other than rice. Willowood Propan!l 

4 SC will cause injury to most crops except cereal grains~an;Lpereiinial : 

grasses. ; < ~ , ' 

• Do not apply this product (directly or indirectly) to wild rics {is.ania' ,,' , : 

spp.). "~ ~c,'., 

• Avoid drift or accidental application from tuming aircraft 011 jJ~.jn~1 cott9n, 

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

vineyards, gardens, shrubs and ornamentals. Once applied, Willow6bd " 

Page 15 of22 

, 

, " 

53
87290.18.20110303.V1.pdf EPA Approved Label 

Propanil 4 SC does not release fumes hazardous to nearby crops. 

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

commercial catfish or crayfish (crawfish) farming is practiced. 

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

last application. 

• Do not rotate treated land to other crops or transplant to crops other than 

rice for 60 days following treatment of this product. 

• Do not apply this product within 14 days before or after carbamate or 

organophosphate insecticide applications. Otherwise, serious injuries to 

rice may occur. 

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

other crops or released within Y, mile upstream of a potable water 

',ntake in flowing water (e.g. river, stream, etc,) or within Y, mile of a 

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

pond, or reselVoir. 

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

treated. 

Emergency Release Provisions 

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

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

• For delayed flood (water-seeded) rice 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 submerges 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. 

• For delayed flood (water-seeded) rice in the southern Louisiana south of 

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

unless excessive rainfall completely submerges the rice crop and forces 

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

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

• For 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 rainfall 

completely submerges the rice crop and forces premature release. 

Page 16 of22 

, {{' 

, ,. 

" 

, {{ , . 

. " , " . 

, .. " { 

. 

54
( 

87290.18.20110303.V1.pdf EPA Approved Label 

Weeds Controlled 

Willowood Propanil 4 SC provides selective postemergence control of the following 

weeds in rice" 

Annual sedges Cyperus spp. 

BamyardQrass ' Echinochloa crus-aalli 

Beakrush (spearhead) Rhynchospora cornicu/ala 

Broadleaf siQnalQrass Bracharia olalvohvlia 

Crabgrass Diailaria spp. 

Curly dock Rumex crispus 

Foxtail Setaria soo. 

Goosegrass Eleusine indica 

Gulf cockspur Echinochloa crus-oavonis 

Hemp sesbania (coffee bean) Sesbania herbacea 

HoorahQrass Fimbrislvlis miliaceae 

Junglerice ' E. c%num 

Mexicanweed Caperonia caslanaefolia 

Paragrass Panicum purpurascens 

Redroot piQweed Amaranthus relrof/exus. 

Redweed Me/ochia corchorifolia 

Rice flatsedQe Cvperus iria 

Smallflower umbrella plant Cyperus difformis 

Spikerush (wireQrass) Eleocharis spp. 

Texas panicum Panicum texanum 

WaterQrass' Echinochloa spp. 

Woolly croton Crolon spp. 

, In 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 

Willowood Propanil 4 SC is effective, tank mix Willowood 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 Willowood Propanil4 SC when a satisfactory stand of rice has been established 

that will tolerate flooding. The amount of Willowood Propanil 4 SC to apply depe'n~s~ 

upon the growth stage and condition of the target weeds. Willowood t'rd?~nil 4 SC is 

most effective if applied when susceptible grasses and broadleaf we6ds ate sm.ell ,ar;;d 

actively growing under favorable soil moisture and weather conditions: ~s~ a higher' 

rate in the recommended rate range for heavy weed infestations, weeds<ih adv&nceJ 

stages of growth, or when growing conditions are less than optimum. 'E(Oecgency , 

treatments made to weeds in advanced growth stages, such as when'grass wee9~,~[e 

tillering, must occur at least 60 days before harvest. : 

, " , • C 

Page 17 of22 

55
87290.18.20110303.V1.pdf EPA Approved Label 

For best results, apply Willowood Propanil4 SC at the rate of 3 to 4 quarts (3 to 4 Ib 

active ingredient) per acre when the grasses are actively growing in the 1 to early 4 

leaf stage. This rate will also control many seedling broadleaf and aquatic weeds. 

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

Mid-Timing and Rates 

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

ingredient) per acre to actively growing grasses in the 4 to 6 leaf and early tiIIering 

stage, or when they are in the 2 to 4 leaf stage but stressed under 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 non ionic surfactant at a rate of 1 to 2 pints per 100 gallons of spray 

mixture, is recommended. 

Rescue Timing and Rates 

Apply Willowood 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 treatment should be considered as a salvage operation only and cannot 

be relied upon for total control of grass and weeds. 

Mixing Directions 

Willowood Propanil4 SC will disperse more quickly if 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 Willowood 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. 

Willowood Propanil 4 SC must be completely dispersed and 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 Oar). 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. Shake the mixture vigorocslY' ': 

and allow it to stand for fifteen minutes. Rapid precipitation of the ingred!e[,ts and, 

failure to re-suspend when shaken indicates that the mixture is incorrip'atitile anp , : 

,,<,t' c< " 

should not be applied : ,', , , t , " " , 

, 

As each material is added to the spray mixture, always allow for compiJt',; mixing , 

before adding the next ingredient. Add crop oil concentrate last and conthlue ag:t~t;bn 

Page 18 of22 

, 

, 

.. , 

56
87290.18.20110303.V1.pdf EPA Approved Label 

while filling the mixing tank to the desired spray volume. 

Do not add Willowood 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 have well-designed spray systems that 

produce a uniform pattem of medium-fine spray droplets. Apply Willowood 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. 

Use nozzle sizes that deliver a medium-fine droplet 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 Willowood 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 Willowood 

Propanil4 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, overwatering, or prolonged 

drought and extremely hot weather. Growers are cautioned not to spray under such 

conditions andlor when maximum daily temperatures have been or are expected to , 1(' 

exceed 10QoF. c,,' ~ ",C«E 

, ,t, 

, " 

Effect of Climatic Conditions and Cultural Practices on Weed Cdntro[" "",< , . , , 

, , , ., 

(. " 

,f, " Field and Seedbed Preparation "'" ," " , 

Fields should be accurately leveled and contoured and have well-prepa,.ed;seedbeds 

free of clods. Such conditions encourage uniform and rapid emergence'Of rice, urBs8 

, 

. ' , . " , , 

Page 19 of 22 

57
87290.18.20110303.V1.pdf EPA APproved Label 

and broad leaf weeds, allowing more accurate timing and coverage ofWiliowood 

Propanil 4 SC sprays for optimum weed control 

Water Management 

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

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

uniform emergence and vigorous growth of grass, broad leaf 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 broad leaf weeds are fully exposed. Weeds that are 

partially submerged in standing water at time of application will not be satisfactorily 

controlled. 

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

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

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

Temperature 

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

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

maximum temperatures increase above 75°F and decreases as the daily maximum 

temperatures decline below 75'F. Do not apply Willowood 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 is not critical so long as 

the temperature exceeds 75'F during the day. 

Relative Humidity and Rain 

Grasses and weeds are more responsive to Willowood Propanil4 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. For best results 

under low relative humidity conditions, increase spray volume to 12 to 15 gallons per 

acre. Do not spray if rain is expected within 8 hours to avoid loss of deposited spray 

and herbicide adsorption by the weeds. 

Wind 

Do not apply 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 applicaflons of Willowood Propanil4 SC with other herbicides, 'l~sectiO!ifa~, 

spray adjuvants, or liquid fertilizers may reduce crop tolerance and/otw~e:d control or 

impair mixing properties. Use of these products in tank mix applicatio'ns with ,',; , , ' < < < 

Willowood Propanil 4 SC is done at the user's risk. : : 

" , • , '.L 

" < < 

, , 

< < " < ' , 

Liquid Fertilizer: Premixing this product in a ratio of 1 part Willowood ProfJanil 4 SC 

to 2 parts water is recommended prior to mixing with liquid fertilizer. .. ,,' :, .,:, , 

• , " " 

Page 20 of 22 

58
( 

87290.18.20110303.V1.pdf EPA Approved Label 

Adverse Reaction to Insecticides 

Rice plants may be severely injured or killed if Willa wood Propanil4 SC is applied in 

tank mix combinations or sequentially before or after certain insecticides. Do not 

combine Willowood Propanil4 SC with carbamate insecticides such as carbaryl, etc., 

or organophosphorus insecticides (such 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 Willowood Propanil4 SC. Do not use carbamate or systemic 

organophosphorus insecticides on rice fields to be treated with Willowood Propanil 4 

SC. 

Do not apply Willowood 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. 

LIMIT OF WARRANTY AND LIABILITY 

IMPORTANT: READ BEFORE USE 

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

Limitations of Liability before 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 and Limitations of Liability. 

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

must be followed carefully. 

However, it is irnpossible to 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 Willa wood 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, WILLOWOOD LLC MAKES NO OTHER WARRANTIES, 

EXPRESS OR IMPLIED, OF MERCHANTABILITY OR OF FITNESS FOR A 

PARTICULAR PURPOSE OR OTHERWISE, THAT EXTEND BEYOND THE 

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

no agent of Willowood LLC is authorized to make any warranties beyond those 

contained herein or to modify the warranties contained herein. TO THE EXTENT 

CONSISTENT WITH APPLICABLE LAW, WILLOWOOD LLC DISCLAIMS ANY 

LIABILITY WHATSOEVER FOR SPECIAL, INCIDENTAL OR CONSEQUENTIAL": 

DAMAGES RESULTING FROM THE USE OR HANDLING OF THIS\P'R,QDUci.', ~ ~ c' 

, ., 

LIMITATIONS OF LIABILITY: TO THE EXTENT CONSISTENTWITH'hPF.!L1CA8LI':' 

LAW, THE EXCLUSIVE REMEDY OF THE USER OR BUYER FOR !,,I':IY,AND:"'L'~' 

LOSSES, INJURIES OR DAMAGES RESULTING FROM THE USE Off H:A.NDLlN3 

OF THIS PRODUCT, WHETHER IN CONTRACT, WARRANTY, TORT;" :. ,,:. , 

. . , .. , " 

Page 21 of22 

59
( 

87290.18.20110303.V1.pdf EPA APproved Label 

NEGLIGENCE, STRICT LIABILITY OR OTHERWISE, SHALL NOT EXCEED THE 

PURCHASE PRICE PAID, ORATWILLOWOOD LLC'S ELECTION, THE 

REPLACEMENT OF PRODUCT. 

Page 22 of22 

<-""Cf 

, " , < " , 

" , , t , , , 

,_, , c, , , , " " , 

t ,t' , " , , < 

, 

, . 

" " , ' , < " " , 

, ' , , " " , 

• " " < , 

60
87290.18.20110303.V1.pdf EPA Approved Label 

and broad leaf weeds, allowing more accurate timing and coverage of Willowood 

Propanil 4 SC sprays for optimum weed control 

Water Management 

Before application of Willowood Propanil4 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, broadleafweeds 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 in 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 Willowood Propanil 4 SC has 

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

maximum temperatures increase above 75°F and decreases as the daily maximum 

temperatures decline below 75°F. Do not apply Willowood Propanil4 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 is not critical so long as 

the temperature exceeds 75'F during the day. 

Relative Humidity and Rain 

Grasses and weeds are more responsive to Willowood Propanil4 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. For best results 

under low relative humidity conditions, increase spray volume to 12 to 15 gallons per 

acre. Do not spray if rain is expected within 8 hours to avoid loss of deposited spray 

and herbicide adsorption by the weeds. 

Wind 

Do not apply 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 Willowood Propanil4 SC with other herbicides, i~sectiOjg:a~, 

spray adjuvants, or liquid fertilizers may reduce crop tolerance and/or w~'e:d control or 

impair mixing properties. Use of these products in tank mix applicatio'ns with ,', ~ I< \ t ~ < 

Willowood Propanil 4 SC is done at the user's risk. : ~ ,., , , ~ ,\ 

\ t t (,' 

, 

Liquid Fertilizer: Premixing this product in a ratio of 1 partWillowooc(P,rOIc,aniI4 SC 

to 2 parts water is recommended prior to mixing with liquid fertilizer. . .. ,' : . , , :, , 

Page 20 of 22 

, " ... 

61
87290.18.20110303.V1.pdf EPA Approved Label 

Adverse Reaction to Insecticides 

Rice plants may be severely injured or killed if Willowood Propanil 4 SC is applied in 

tank mix combinations or sequentially before or after certain insecticides. Do not 

combine Willowood Propanil 4 SC with carbamate insecticides such as carbaryl, etc., 

or organophosphorus insecticides (such as malathion and methyl parathion, etc). Do 

not apply any of the carbamate or organophosphorus insecticides to rice fields within 

14 days before or afterWiliowood Propanil4 SC. Do not use carbamate or systemic 

organophosphorus insecticides on rice fields to be treated with Willowood Propanil 4 

SC. 

Do not apply Willowood 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. 

LIMIT OF WARRANTY AND LIABILITY 

IMPORTANT: READ BEFORE USE 

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

Limitations of Liability before 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 and 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 to 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 Willa wood 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, WILLOWOOD LLC MAKES NO OTHER WARRANTIES, 

EXPRESS OR IMPLIED, OF MERCHANTABILITY OR OF FITNESS FOR A 

PARTICULAR PURPOSE OR OTHERWISE, THAT EXTEND BEYOND THE 

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

no agent of Willowood LLC is authorized to make any warranties beyond those 

contained herein or to modify the warranties contained herein. TO THE EXTENT 

CONSISTENT WITH APPLICABLE LAW, WILLOWOOD LLC DISCLAIMS ANY 

LIABILITY WHATSOEVER FOR SPECIAL, INCIDENTAL OR CONSEQUENTIAV' ~ 

DAMAGES RESULTING FROM THE USE OR HANDLING OF THIS\P'~QDUcf. " , ' , , ",,'( <.' ( 

LIMITATIONS OF LIABILITY: TO THE EXTENT CONSISTENT WITH hPFiLlCAI:lLl':' 

LAW, THE EXCLUSIVE REMEDY OF THE USER OR BUYER FOR AN',' AND~Al'~' 

LOSSES, INJURIES OR DAMAGES RESULTING FROM THE USE bWHf\NDLlN3 

OF THIS PRODUCT, WHETHER IN CONTRACT, WARRANTY, TORT,' • : •. , :. 

Page 21 of22 

, 

, . " ,.- • 

62
( 

87290.18.20110303.V1.pdf EPA Approved label 

NEGLIGENCE, STRICT LIABILITY OR OTHERWISE, SHALL NOT EXCEED THE 

PURCHASE PRICE PAID, ORATWILLOWOOD LLC'S ELECTION, THE 

REPLACEMENT OF PRODUCT. 

Page 22 0122 

c," , , c , 

, " . " , : 

« ( , ( , . , • • 

','" ( 

, " c , , 

t ,(, 

· " c ~ , 

, , 

, " ,( (' 

· , ("" ( 

· 

" ( . " 

63
Cheryl Wagner 

From: 

Sent: 

To: 

Subject: 

Attachments: 

Jim Wagner 

Regulatory Consultant 

Tel: 302-635-7290 

Mobile: 302-530-5745 

-----Original Message-----

{ 

James Wagner <james@wagnerreg.com> 

Thursday, May 26, 2011 2:25 PM 

'Cheryl Wagner' 

FW; Propanil4SC label 

pic231S2.jpg 

From: Davis.Kable@epamail.epa.gov [mailto:Davis.Kable@epamail.epa,gov] 

Sent: Thursday, May 26, 201111:11 AM 

To: James Wagner 

Subject: Re: Propanil4SC label 

I think it would be acceptable to submit this as a notification. In the cover letter, be sure to state that you are just 

correcting typo and that you already ran this past me. 

Enjoy your Thursday. 

Sincerely, 

Bo 

Kable Bo Davis 

Product Manager 2S 

U.S. Environmental Protection Agency 

Herbicide Branch 

Registration Division (7S0SP) 

1200 Pennsylvania Ave. NW 

Washington, DC 20460 

Tel: 703 306-0415 

Email: davis.kable@epa.gov 

From: 

To: 

Date: 

"James Wagner" <james@wagnerreg.com> 

Kable Davis/DC/USEPA/US@EPA 

OS/26/2011 09:59 AM 

1 

, { , { ~, 

, < 

< < 

{ { ( { c { , < 

" ( , , < 

, ,,, " 

, ,,{ < < , 

" < 

< {' ,{ 

< 

{ { " ( 

, 

{ , , " 

( " " { 

, 

64
Subject:Propanil4SC label 

Hi Bo, 

Quick questionThe Willowood Propanil4SC label Reg No 87290-18 approved by RD has a typo in the restriction sentence below. The 

crop "beans" was omitted from the sentence in the approved label. My question - can we add the word back in by 

notification? The 'me too' product label Reg No 

70506-167 (attached) includes the word 'beans' in this sentence. 

California caught the typo and wants the change. The other option is to delete the word 'seedling' before legumes so 

that legumes covers all growth stages for legumes and then by definition legumes includes 'beans' . 

• Avoid drift or accidental application from turning aircraft on beans, cotton, soybeans, corn, safflower, seedling 

legumes, cucurbits, vegetables, orchards, vineyards, gardens, shrubs, and ornamentals. Once applied, Stam 4SC does not 

release fumes hazardous to nearby crops. 

Thanks, 

Jim Wagner 

Regulatory Consultant 

Tel: 302-635-7290 

Mobile: 302-530-5745 

(Embedded image moved to file: pic23152.jpg)WRA_LOGO [attachment "Ppls.getimage-7.pdf" deleted by Kable 

Davis/DC/USEPA/USj 

, t < C 

, , 

, 

, 

.;< , 

2 

" , , 

, 

, t< " 

, ' ( <" ( , 

, 

CI " , 

65
Your preferred manufacturer of post patent products 

August 13, 2010 

Re: Designation of Agent for: 

WiJlowood Propanil, LLC 

1600 NW Garden Valley Blvd. 

Suite 130 

Roseburg, OR 97471 

Dear Sir or Madam: 

Th'ls letter selVes as notification that Willowood Propanil, LLC has appointed Wagner 

Regulatory Associates, Inc, (WRA, Inc.) to serve as the Agent on our company's behalf 

regarding all state and federal regulatory matters relative to products that Willowood 

Propanil, LLC will register with US EPA and the states. Please forward all 

correspondence for our company and its products to: 

Wagner Regulatory Associates, Inc, 

P.O. Box 640 

Hockessin, DE 19707·0640 

Thank you for your time and assistance. Please feel free to call me at if you have any 

questions, 

RJ:: sUb,)m)itl,;,e-::Jd

L

' 'L<~'-t--"-' 

Brian Heinze 

PresidentlCEO 

cc: WRA, Inc. <~{«< 

, " , , . , 

( ", 

, , 

" 

< < , , , , < 

-~ .... --..... ---------

'0 ,," , , 

" , < , , ( , 

, " < < , 

"" ( 

, 

" " " , 

1600 NW Garden Valley Blvd. Suite 130· Roseburg, OR 97471 ·541.679.9963· FAX 541.679.4650 • www.WiHowoodUSA.com 

66
, 

U.S. ENVlkONMENTAL PROTECTION 

EPA Reg. Number: AGENCY Dale of Issuance: 

.$-,"1.'<.0 sr ... ,,~ 

Office of Pesticide Programs 87290-18 t ~ ". ~'-tl " Registration Division (750SP) MAR - 9 2011 '<,,~I-/ Ariel Rios Building 

"I( p"C1\~ 1200 Pennsylvania Ave., NW 

Washington, D.C. 20460 

NOTICE OF PESTICIDE: Tenn of Issuance: Conditional 

L Registration 

~ Reregistration Name of Pesticide Product: 

(under FIFRA, as amended) Willowood Propanil4 SC 

Name and Address of Registrant (include ZIP Code): 

Willowood LLC 

1600 NW Garden Valley Blvd., Suite 130 

Roseburg, OR 97471 

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

prior to use ofthc label in eommerce. In any correspondence on this product allVayS refer \0 the above EPA reRistration number. 

On the basis of information furnished by the registrant, the above named pesticide is hereby registered/reregistered under thc Federa! Insecticide, Fungicide and 

Rodenticide Act. Registration is in no way to be construed as an endorsement or recommendation of this product by the Agency. In order to protect health and the 

environment, the Administrator, on his motion, may at any time suspcnd or eancel the registration of a pesticide in accordance with thc Act. The acceptance of any 

name in connection with the registrotion ofa product under this Act is not to be eonstrued as giving the registrant a right to exclusive usc ofthc name orto its use if it 

has bccn covered by others. 

This product is conditionally registered in accordance with FIFRA sec. 3( c)(7)(A) provided that you: 

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

Agency requires all registrants of similar products to submit data. 

2, Submit one-year storage stability (Guideline 830.6317) and corrosion characteristics (Guideline 

830,6320) studies, These studies must be conducted in commercial containers with observations 

recommended at 0, 1,3,6,9 and 12 month intervals. 

3, Submit one copy of the final printed label for the record. 

If these conditions are not complied with, the registration will be subject to cancellation in accordance 

with FIFRA sec, 6(e), Your release for shipment of the product constitutes acceptance of these conditions. 

The Basic and Alternate Formulation Confidential Statements of Formula (CSFs), dated February 15, 

2011, are acceptable and have been placed in the product file as the CSFs of record for this product. 

A stamped copy of the label is enclosed for your records. Copies of the Agency's product chemistry 

and acute toxicology reviews for this product are also enclosed. 

Signature of Approving Official: Date: 

Kable 

Product~anager25 

Bo Davis 

):U~~ MAR -9 20il 

Herbicide Branch 

Registration Division (7505P) . EPA Form 8570·6 

67
87290.XXXXX.2011 0303. V1.pdf EPA Initial Regislralion Draft Label 

Active Ingredient: 

Willowood Propanil 4 SC 

Herbicide 

For Postemergence Weed Control in Rice 

Propanil: 3', 4'-Dichloropropionanilide ...................................................... .41.4% 

Other Ingredients: ...................................................................................... 58.6% 

TOTAL: ................................................................................................... 100.00% 

This product contains 4 lb. of active ingredient per gallon. 

EPA Reg. No. 87290-

EPA Est. No. 

Net Contents: 

KEEP OUT OF REACH OF CHILDREN 

CAUTION 

First Aid 

If inhaled: 

• Move person to fresh air. 

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

respiration, preferable mouth-to-mouth, if possible. 

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

If on skin or clothing: 

• Take off contaminated clothing. 

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

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

If in eyes: 

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

• Remove contact lenses, if present, after the first 5 minutes, then continue rinSing 

eye. 

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

If swallowed: 

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

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

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

• Do 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: 

Willowood LLC 

1600 NWGarden Valley Blvd. Suite 130 

Roseburg, OR 97471 

Page 1 of 22 

'ACCEPTED 

MAR - 9 2011 

IJn!J:<tIw • __ 

Fwli!Icl"'cnd~M. 

nil nmoodc.1 bthe ~ 

Nl,\lH'mod_ ,~d / ~ ilPAR",No. !{7.<Y'tJ- , 

68
( 

87290.XXXXX.20110303.v1.pdf EPA Initial Registration Draft Label 

Precautionary Statements 

Hazards to Humans and Domestic Animals 

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

Wash thoroughly with soap and water after handling. Remove contaminated clothing 

and wash before reuse. 

Personal Protective Equipment (PPE) 

Some materials that are chemical-resistant to this product are natural rubber ~ 14 

mils, For 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 un rinsed probe 

must wear: 

• Coveralls over long-sleeve shirt and long pants, 

• Chemical-resistant gloves made of any waterproof materials, 

• Chemical-resistant footwear plus socks, 

• Chemical-resistant headgear, if overhead exposure, and 

• Chemical resistant apron, when mixing and loading. 

• Protective eyewear if the system operates under pressure. 

Pilots and handlers removing a triple rinsed probe must wear: 

• Long-sleeved shirt and long pants, 

• Shoes plus socks, and 

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

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

See Engineering Controls for additional requirements 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 contaminated with this product's concentrate. Do not reuse 

them. 

Engineering Controls: 

Mixers and loaders must either: 

(1) use a closed system that meets the requirements listed in the Worker Protection 

Standard (WPS) for dermal protection of agricultural pesticides [40 CFR 

170.240(d)(4)], OR 

(2) Use the probe system described below: 

Page 2 of22 

69
87290.XXXXX.20110303.V1.pdf EPA Initial Registration Draft Label 

PROBE SYSTEM 

Specific requirements for use of the probe closed mixinglloading system: 

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. Transfer 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. Do not handle the probe or bung in a manner that allows 

dripping or splattering of 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. Take 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 SYSTEMS 

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

equipment required 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 in 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 to minimize drippage. 

Flaggers: Human fiagging is prohibited. Flagging to support aerial application is limited 

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

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

the requirements listed in the Worker Protection Standard (WPS) for agricultural 

pesticides [40 CFR 170.240(d)(6)]. 

Page 30f22 

70
( 

87290.XXXXX.20110303.V1.pdf 

User Safety Recommendations 

Users should: 

EPA initial Registration Draft Label 

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

• Remove clothing/PPE immediately if pesticide gets inside. Then wash thoroughly and put 

on clean clothing. 

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

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

Environmental Hazards 

This pesticide is 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 has 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 product may contaminate water through runoff following rainfall events and by 

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

when rainfall is forecasted to occur within 48 hours. Levees should be constructed 

with adequate time prior to chemical application so 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. 

Page 4 of22 

71
, 

I 

87290.XXXXX.20110303.v1.pdf EPA Initial Registration Draft Label 

Agricultural Use Requirements 

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

Standard, 40 CFR part 170. This Standard contains requirements for the protection of 

agricultural workers on farms, forests, nurseries, and greenhouses, and handlers of 

agricultural pesticides. It contains requirements for training, decontamination, notification, 

and emergency assistance. It also contains specific instructions and exceptions pertaining 

to the statements on this label about personal protective equipment (PPE) and restrictedentry interval. The requirements in this box only apply to uses of this product that are 

covered by the Worker Protection Standard. 

Do not enter or allow worker entry into treated areas during the restricted entry interval 

(REI) of 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: 

• Coveralls over long-sleeve shirt and long pants 

• Chemical-resistant gloves made of any waterproof materials, 

• Chemical-resistant footwear plus socks, 

• Protective eyewear 

Page 5 of 22 

72
( I 

87290.XXXXX.20110303.V1.pdf EPA Inltlal Registration Draft label 

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. If stored below 32F and crystals form, warm to 72F for 24 hours, 

periodically 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. If 

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

State Pesticide or Environmental Control Agency, or the Hazardous Waste 

representative at the nearest EPA region office for guidance. 

Container Handling: NONREFILLABLE CONTAINER (EQUAL 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 fiow begins to 

drip. Fill the container Y. full with water and recap. Shake for 10 seconds. Pour rinsate 

into application equipment or a mix tank or store rinsate for later use or disposal. Drain 

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

Offer for recycling, if available. 

NONREFILLABLE CONTAINER (GREATER 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. 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. Empty the rinsate into 

application equipment or a mix tank or store rinsate for later use or disposal. Repeat 

this procedure two more times. Offer for recycling, if available. 

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

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

responsibility of the person disposing of the container. Cleaning before refilling is the 

responsibility of the refiller. To clean the container before final disposal, empty the 

remaining contents from this container into application equipment or mix tank. Fill the 

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

the pump for 2 minutes. Pour or pump rinsate into application equipment or rinsate 

collection system. Repeat this rinsing procedure two more times. 

Page 6 0122 

73
( ( 

87290 .XXXXX.2011 0303. V1.pdf EPA Initial Registration Drafllabel 

Product Information 

WiIIOWDOd Propanil 4 SC for postemergence weed control in rice is formulated as a 

suspension concentrate containing 4 Ib active ingredient per gallon. Willowood 

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. Willowood Propanil4 SC has no preemergence or residual herbicidal 

activity. Only weeds that have emerged and are exposed at time of application will be 

controlled. Apply Willowood Propanil4 SC only to fields that have been drained of 

floodwater. Willowood Propanil 4 SC is most effective if applied when susceptible 

grasses and broadleafweeds 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 label 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 system 

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 requirements must be followed to avoid off-target drift 

movement from aerial applications to agricultural field crops. 

1. The 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. Nozzles 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. 

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

the following Aerial Drift Reduction Advisory. 

Page 7 of 22 

74
87290.XXXXX.2011 0303. V1.pdf EPA Initial Registration Draft label 

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 environmental conditions (see Wind, Temperature and Humidity, and 

Temperature Inversions). 

Controlling Droplet Size: 

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

volume. Nozzles with higher rated flows produce larger droplets. 

• Pressure - 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. 

• Number of Nozzles - Use the minimum number of nozzles that provide 

uniform coverage. 

• Nozzle 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. 

• Nozzle Type - Use a nozzle type that is designed for Ihe intended 

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

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

slraighl back produce Ihe largesl droplels and Ihe lowest drift. 

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

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 by 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 wilh local wind patterns and how they affect spray 

drift. 

Page 8of22 

75
87290.XXXXX.2011 0303. V1.pdf EPA Initial Registration Draft Label 

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

up equipment to produce larger droplets to compensate for evaporation. Droplet 

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

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

temperature inversion because drift potential is high. Temperature inversions restrict 

vertical air mixing, which causes small suspended droplets to remain in 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, if 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 

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

application site. 

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

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

above the ground or crop canopy. 

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

nontarget crops or plants that are within 100 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. Do not make any type of application into 

temperature inversions. 

Page 9 of22 

76
I 

87290.XXXXX.20110303.v1.pdf 

For Use on Rice Grown in California Only 

Restrictions 

EPA Inilial Regislralion Oral! Label 

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

harvest. 

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

system. 

• Do not apply more than a maximum of 6 quarts of Willowood Propanil4 

SC (6 Ib active ingredient) per acre in a single application or exceed S 

quarts ofWiliowood Propanil4 SC (Sib of active ingredient) per acre total 

dosage per season. 

• In California: Use Willowood Propanil4 SC only where rice fields are 

completely drained or a minimal amount of water remains. If high water 

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

treatment. This will discourage new weed infestations. 

• Do not apply this product to any crop other than rice. Willowood Propanil 

4 SC will cause injury to most crops except cereal grains and perennial 

grasses. 

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

spp.). 

• Avoid drift or accidental application from turning aircraft on cotton, 

soybeans, com, safflower, seedling legumes, vegetables, orchards, 

vineyards, gardens, shrubs and ornamentals. Once applied, Willowood 

Propanil 4 SC does not release fumes hazardous to nearby crops. 

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

commercial catfish or crayfish (crawfish) farming is practiced. 

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

last application. 

• Do not rotate treated land to other crops or transplant to crops other than 

rice for 60 days following treatment of this product. 

• Do not apply this product within 14 days before or after carbamate or 

organophosphate insecticide applications. Otherwise, serious injuries to 

rice may occur. 

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

other crops or released within Y, mile upstream of a potable water 

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

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

pond, or reservoir. 

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

treated. 

• 

Emergency Release Provisions 

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

unless excessive rainfall completely submerges the rice crop and forces premature 

release, for: 

• 7 days in dry seeded rice in California 

• 7 days for water-seeded rice in California 

Page10of22 

77
87290.XXXXX.20110303.V1.pdf EPA In~ial Registration Draft label 

Weeds Controlled 

Annual sedges Cyperus spp. 

Barnyardgrass a Echinoch/oa crus-galli 

Crabgrass Diqitaria spp. 

Early watergrass ,., Echinoch/oa orvzoides 

Junolerice a E. c%num 

Late watergrass a, Echinoch/oa phyllopogon 

Ricefield bullrush Scirpus mucronatus 

Rice fiatsedge Cyperus iria 

Smallflower umbrella plant Cvperus difformis 

a In isolated instances, biotypes of bamyardgrass/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 

Willowood Propanil4 SC is effective, tank mix Willowood Propanil4 SC at labeled rate 

with other rice herbicides that are recommended for control of 

barnyardgrasslwatergrass (up to the 3 leaf stage). 

b Applications 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 Willowood Propanil 4 SC when a satisfactory stand of rice has been established 

that will tolerate fiooding. The amount of Willowood Propanil 4 SC to apply depends 

upon the growth stage and condition of the target weeds. Willowood Propanil4 se is 

most effective if applied when susceptible grasses and broad leaf weeds are small and 

actively growing under favorable soil moisture and weather conditions. Use a higher 

rate in the recommended rate range for heavy weed infestations, weeds in advanced 

stages of growth, or when growing conditions are less than optimum. Emergency 

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

tillering, must occur at least 60 days before harvest. 

For best results, apply Willowood Propanil4 SC at the rate of 3 to 4 quarts (3 to 4 Ib 

active ingredient) per acre when the grasses are actively growing in the 1 to early 4 

leaf stage. This rate will also control many seedling broadleaf and aquatic weeds. 

Generally, this will be 15 to 25 days after planting. In order to insure satisfactory weed 

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

single spray application. 

Mid-Timing and Rates 

Willowood Propanil4 SC can be applied at the rate of 4 to 6 quarts (4 to 6 Ib active 

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

Page 11 of22 

78
( 

87290.XXXXX.2011 0303. V1.pdf EPA Initial Registration Draft Label 

stage, or when they are in the 2 to 4 leaf stage but stressed under 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 nanionic surfactant at a rate of 1 to 2 pints per 100 gallons of spray 

mixture, is recommended. 

Rescue Timing and Rates 

Apply Willowood Propanil4 se 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 tillenng 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 treatment should be considered as a salvage operation only and cannot 

be relied upon for total control of grass and weeds. 

Mixing Directions 

Willowood Propanil4 se will disperse more quickly if 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 Willowood Propanil4 se into a partially filled mix 

tank. The jet or tank agitators must be positioned to create a nppling 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. 

Willowood Propanil 4 se must be completely dispersed and 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 Oar). 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. Shake 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 is added to the spray mixture, always allow for complete mixing 

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 add Willowood Propanil4 se 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. 

Page 12 of 22 

79
87290.XXXXX.20110303.V1.pdf EPA Initial Registration Draft label 

Application Equipment 

Aircraft 

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

produce a uniform pattem of medium-fine spray droplets. Apply Willowood Propanil4 

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. 

Use nozzle sizes that deliver a medium-fine droplet 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 wtth clear water after each day's use. Clean all equipment, 

including nurse tanks, used for Willowood Propanil4 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 Willowood 

Propanil4 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, overwatering, 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. 

Page 13 of22 

80
( 

87290.XXXXX.20110303.V1.pdf EPA Initial Regis1raUon Draft Label 

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 seedbeds 

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

and broad leaf weeds, allowing more accurate timing and coverage of Willowood 

Propanil4 SC sprays for optimum weed control. 

Water Management 

Before application ofWiliowood Propanil4 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, broadleafweeds 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 broad leaf weeds are fully exposed. Weeds that are 

partially submerged in 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 Willowood Propanil4 SC has 

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

maximum temperatures increase above 75°F and decreases as the daily maximum 

temperatures decline below 75°F. Do not apply Willowood Propanil4 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 is not critical so long as 

the temperature exceeds 75eF during the day. 

Relative Humidity and Rain 

Grasses and weeds are more responsive to Willowood Propanil4 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. For best results 

under low relative humidity conditions, increase spray volume to 12 to 15 gallons per 

acre. Do not spray if rain is expected within 8 hours to avoid loss of deposited spray 

and herbicide adsorption by the weeds. 

Wind 

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

crops and the possibility of uneven (streaked) applications. 

Page 14 of22 

81
( 

87290.XXXXX.20110303.V1.pdf EPA InHial Regislralion Draft label 

Compatibility With Other Chemicals 

Tank mix applications of Willowood Propanil4 SC with other herbicides, insecticides, 

spray adjuvants, or liquid fertilizers may reduce crop tolerance and/or weed control or 

impair mixing properties. Use of these products in tank mix applications with 

Willowood Propanil 4 se is done at the user's risk. 

Liquid Fertilizer: Premixing this product in a ratio of 1 part Willowood Propanil4 se 

to 2 parts water is recommended prior to mixing with liquid fertilizer. 

Adverse Reaction to Insecticides 

Rice plants may be severely injured or killed if Willowood Propanil4 SC is applied in 

tank mix combinations or sequentially before or after certain insecticides. Do not 

combine Willowood Propanil4 se with carbamate insecticides such as carbaryl, etc., 

or organophosphorus insecticides (such 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 Willowood Propanil4 SC. Do not use carbamate or systemic 

organophosphorus insecticides on rice fields to be treated with Willowood Propanil4 

SC. 

Do not apply Willowood 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 

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

harvest. 

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

system. 

• Do not apply more than a maximum of 6 quarts of Willowood Propanil 4 

SC (6 Ib active ingredient) per acre in a single application or exceed 8 

quarts of Willowood Propanil4 SC (8 Ib of active ingredient) per acre total 

dosage per season. 

• Do not plant or transplant crops in the treated area for at least 60 days 

following application. 

• Do not apply this product to any crop other than rice. Willowood Propanil 

4 SC will cause injury to most crops except cereal grains and perennial 

grasses. 

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

spp.). 

• Avoid drift or accidental application from turning aircraft on cotton, 

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

vineyards, gardens, shrubs and ornamentals. Once applied, Willowood 

Page 150f22 

82
( 

87290.XXXXX.20110303.v1.pdf EPA Initial Registration Draft Label 

Propanil4 SC does not release fumes hazardous to nearby crops. 

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

commercial catfish or crayfish (crawfish) farming is practiced. 

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

last application. 

• Do not rotate treated land to other crops or transplant to crops other than 

rice for 60 days following treatment of this product. 

• Do not apply this product within 14 days before or after carbamate or 

organophosphate insecticide applications. Otherwise, serious injuries to 

rice may occur. 

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

other crops or released within % 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 reselVoir. 

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

treated. 

Emergency Release Provisions 

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

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

• For delayed flood (water-seeded) rice 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 submerges the rice crop and forces 

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

boundaries, the water holding intelVal will be 7 days. 

• For delayed flood (water-seeded) rice in the southern Louisiana south of 

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

unless excessive rainfall completely submerges the rice crop and forces 

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

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

• For rice in all other parts of the southern United States not mentioned aboveFlood water must be held for 7 days after application unless excessive rainfall 

completely submerges the rice crop and forces premature release. 

Page 16 of 22 

83
, 

( I 

87290.XXXXX.20110303.V1.pdf EPA Initial Registration Draft Label 

Weeds Controlled 

Willowood Propanil 4 SC provides selective postemergence control of the following 

weeds in rice" 

Annual sedoes Cvperus spp. 

Barnvardorass a Echinochloa crus-aatli 

Beakrush (spearhead) Rhynchospora corn/culata 

Broadleaf signalgrass Bracharia platyphytia 

Crabgrass Digitaria spp. 

Curly dock Rumex crispus 

Foxtail Setaria spp. 

Gooseorass Eleusine indica 

Gulf cockspur Echinochloa cru$-oavon;s 

Heme sesbania (coffeebean Sesbania herbacea 

Hoorahgrass Fimbr/stylis mil/aceae 

Junglerice a E. co/anum 

Mexicanweed Caperonia castanaefolia 

ParaQrass Panicum purpurascens 

Redroot pioweed Amaranthus retrofiexus. 

Redweed Me/ochia corchorifolia 

Rice fiatsedge Cyperus iria 

Smallflower umbrella plant Cyperus difformis 

Spike rush (wireorass) Eleocharis spp. 

Texas panicum Panicum texanum 

Watergrass a Echinochloa spp. 

Woolly croton Croton spp. 

a In 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 

Willowood Propanil 4 SC is effective, tank mix Willowood 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 Willowood Propanil 4 SC when a satisfactory stand of rice has been established 

that will tolerate flooding. The amount ofWiliowood Propanil4 SC to apply depends 

upon the growth stage and condition of the target weeds. Willowood Propanil 4 SC is 

most effective if applied when susceptible grasses and broad leaf weeds are small and 

actively growing under favorable soil moisture and weather conditions. Use a higher 

rate in the recommended rate range for heavy weed infestations, weeds in advanced 

stages of growth, or when growing conditions are less than optimum. Emergency 

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

tillering, must occur at least 60 days before harvest. 

Page 170f22 

84
( 

87290.XXXXX.20 f 1 0303.V1.pdf EPA Initial Registration Draft Label 

For best results, apply Willowood Propanil 4 SC at the rate 013 to 4 quarts (3 to 4 Ib 

active ingredient) per acre when the grasses are actively growing in the 1 to early 4 

leaf stage. This rate will also control many seedling broad leaf and aquatic weeds. 

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

Mid-Timing and Rates 

Willowood Propanil 4 SC can be applied at the rate 014 to 6 quarts (4 to 6 Ib active 

ingredient) per acre to actively growing grasses in the 4 to 6 leal and early tillering 

stage, or when they are in the 2 to 4 leaf stage but stressed under 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 nan ionic suriactant at a rate of 1 to 2 pints per 100 gallons of spray 

mixture, is recommended. 

Rescue Timing and Rates 

Apply Willowood Propanil4 SC at the rate 015 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. lIthe 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 

be relied upon for total control of grass and weeds. 

Mixing Directions 

Willowood Propanil4 se will disperse more quickly if water temperature is 50°F or 

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

add the recommended amount olWiliowood Propanil4 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 01 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 loaming, keep filling and bypass lines below the liquid surface. 

Willowood Propanil4 SC must be completely dispersed and mixed prior to application. 

II 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 Oar). 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. Shake 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 is added to the spray mixture, always allow for complete mixing 

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

Page 18 of22 

85
( 

87290.XXXXX.2011 0303. V1.pdf EPA Initial Registration Draft Label 

while filling the mixing tank to the desired spray volume. 

Do not add Willowood 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 have well-designed spray systems that 

produce a uniform pattern of medium-fine spray droplets. Apply Willowood Propanil4 

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. 

Use nozzle sizes that deliver a medium-fine droplet 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 Willowood Propanil4 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 Willowood 

Propanil4 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, overwatering, 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 seedbeds 

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

Page 19 of 22 

86
( 

87290.XXXXX.2011 0303. V1.pdf EPA Initial Registration Draft Label 

and broad leaf weeds, allowing more accurate timing and coverage of Willa wood 

Propanil4 SC sprays for optimum weed control 

Water Management 

Before application ofWiliowood Propanil4 SC, drained ordry 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 broad leaf weeds are fully exposed. Weeds that are 

partially submerged in 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 Willowood Propanil 4 SC has 

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

maximum temperatures increase above 75°F and decreases as the daily maximum 

temperatures decline below 75°F. Do not apply Willowood Propanil4 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 is not critical so long as 

the temperature exceeds 75e

F during the day. 

Relative Humidity and Rain 

Grasses and weeds are more responsive to Willowood Propanil4 se 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. For best results 

under low relative humidity conditions, increase spray volume to 12 to 15 gallons per 

acre. Do not spray if rain is expected within 8 hours to avoid loss of deposited spray 

and herbicide adsorption by the weeds. 

Wind 

Do not apply 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 Willowood Propanil 4 se with other herbicides, insecticides, 

spray adjuvants, or liquid fertilizers may reduce crop tolerance and/or weed control or 

impair mixing properties. Use of these products in tank mix applications with 

Wiliowood Propanil4 SC is done at the users risk. 

Liquid Fertilizer: Premixing this product in a ratio of 1 part Willowood Propanil4 SC 

to 2 parts water is recommended prior to mixing with liquid fertilizer. 

Page20 of 22 

87
87290.XXXXX.20110303.V1.pdf EPA Initial Regislralion Draft Label 

Adverse Reaction to Insecticides 

Rice plants may be severely injured or killed if Willowood Propanil 4 SC is applied in 

tank mix combinations or sequentially before or after certain insecticides. Do not 

combine Willowood Propanil4 SC with carbamate insecticides such as carbaryl, etc., 

or organophosphorus insecticides (such 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 Willowood Propanil4 SC. Do not use carbamate or systemic 

organophosphorus insecticides on rice fields to be treated with Willowood Propanil4 

SC. 

Do not apply Willowood Propanil4 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. 

LIMIT OF WARRANTY AND LIABILITY 

IMPORTANT: READ BEFORE USE 

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

Limitations of Liability before 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 and 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 to 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 ofWiliowood 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, WILLOWOOD LLC MAKES NO OTHER WARRANTIES, 

EXPRESS OR IMPLIED, OF MERCHANTABILITY OR OF FITNESS FOR A 

PARTICULAR PURPOSE OR OTHERWISE, THAT EXTEND BEYOND THE 

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

no agent of Willowood LLC is authorized to make any warranties beyond those 

contained herein or to modify the warranties contained herein. TO THE EXTENT 

CONSISTENT WITH APPLICABLE LAW, WILLOWOOD LLC DISCLAIMS ANY 

LIABILITY WHATSOEVER FOR SPECIAL, INCIDENTAL OR CONSEQUENTIAL 

DAMAGES RESULTING FROM THE USE OR HANDLING OF THIS PRODUCT. 

LIMITATIONS OF LIABILITY: TO THE EXTENT CONSISTENT 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 IN CONTRACT, WARRANTY, TORT, 

Page 21 of22 

88
( ( 

87290.XXXXX.20110303.V1.pdf EPA Initial Registration Draft Label 

NEGLIGENCE, STRICT LIABILITY OR OTHERWISE, SHALL NOT EXCEED THE 

PURCHASE PRICE PAID, OR AT WILLOWOOD LLC'S ELECTION, THE 

REPLACEMENT OF PRODUCT. 

Page 22 of 22 

89
Hi Susan, 

RE: Label Changes Required for Willowood Propanil 4SC (EPA File Symbol: 

87290-RI) 

Catherine Byrd to: Susan Stanton 03/03/2011 04:57 PM 

I have attached a revised label. Please let me know if you need anything 

else. 

Thank you, 

Catherine M. Byrd 

Regulatory Associate 

P.O. Box 640 

7460 Lancaster Pike, Suite 9 

Hockessin, Delaware 19707 

P: 302.234.2780 

F: 302.234.7570 

www.wagnerreg.com 

-----Original Message-----

From: Stanton.Susan@epamail.epa.gov [mailto:Stanton.Susan@epamail.epa.gov] 

Sent: Thursday, March 03, 2011 3:14 PM 

To: Catherine Byrd 

Cc: Davis.Kable@epamail.epa.gov 

Subject: Label Changes Required for Willowood propanil 4SC (EPA File Symbol: 

87290-RIJ 

Catherine, 

As I mentioned in my earlier phone call, some changes must be made to 

the Willowood Propanil 4SC label to comply with the propanil RED. 

Specifically, you must: 

Revise the heading "Mixers, loaders and other handlers exposed to the 

concentrate must wear:" in the PPE section on page 2 to read: 

"Mixers, loaders, ground applicators, and handlers cleaning up spills 

or equipment or otherwise exposed to the concentrate and handlers 

removing an unrinsed probe must wear:" 

Revise the "Chemical resistant apron" requirement for mixers, 

loaders ... to read "Chemical-resistant apron, when mixing and 

loading. " 

Add "Protective eyewear if the system operates under pressure" to the 

PPE for mixers, loaders .... 

Revise the heading nApplicators and other handlers must wear" to read 

"pilots and handlers removing a triple-rinsed probe must wear:" At 

your discretion, you may delete the requirement in this section for 

"Chemical-resistant gloves ..... n 

Insert the heading "User Safety Requirements n above the paragraph 

which begins "Follow manufacturer's instructions ... " 

Revise the Engineering Controls section on page 2 to read as follows: 

ENGINEERING CONTROLS 

Mixers and loaders must either: 

90
( 

(1) use a closed system that meets the requirements listed in the 

Worker Protection 

Standard (WPS) for dermal protection of agricultural pesticides 

[40 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: 

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. 

Transfer 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. 

Do not handle the probe or bung in a manner that allows 

dripping or 

splattering of 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. 

Take 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 SYSTEMS 

In addition, mixers and loaders using all systems must: 

wear the personal protective equipment required 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 in 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 

91
, 

I 

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 to minimize drippage. 

Flaggers: Human flagging is prohibited. Flagging to support aerial 

application is limited 

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

flaggers. 

Enclosed Cabs for Aerial Applicators: pilots must use an enclosed 

cockpit that meets 

the requirements listed in the worker Protection Standard (WPS) 

for agricultural 

pesticides (40 CFR 170.240(d) (6)]. 

7. On page 6, delete the statement "These requirements do not apply 

to forestry applications, public health uses or to applications using 

dry formulations" at the end of the second paragraph under "Spray 

Drift Management," since they're not relevant to this product. 

8. Remove the word "General" from the heading "General Spray Drift 

Restrictions for All States" on page 8. 

9. In the restrictions for rice in California (page 9) and the 

Southern U.S. (page 15) the distance from potable water intakes in 

flowing water and standing bodies of water should be changed from 2 

miles to 1/2 mile. 

please submit a revised label (preferably by email) making these 

changes. As the PRIA date isn't too far away, a prompt response 

would be much appreciated. If you need clarification or have any 

questions about any of these required changes, feel free to call me 

at (703) 305-5218. 

Thanks, 

Susan 

92
( ( 

To: "Catherine Byrd" <Catherine@wagnerreg.com>, 

Cc: Kable DavisIDC/USEPAlUS, 

for WilJowood 4SC 

Catherine, 

As I mentioned in my earlier phone call, some changes must be made to the Willowood PropaniI 4SC 

label to comply with the propanil RED. Specifically, you must: 

1. Revise the heading "Mixers, loaders and other handlers exposed to the concentrate must wear:" in the 

PPE section on page 2 to read: "Mixers, loaders, ground applicators, and handlers cleaning up spills 

or equipment or otherwise exposed to the concentrate and handlers removing an unrinsed probe 

must wear:" 

2. Revise the "Chemical resistant apron" requirement for mixers, loaders ... to read "Chemical-resistant 

apron, when mixing and loading." 

3. Add "Protective eyewear if the system operates under pressureR to the PPE for mixers, loaders .... 

4. Revise the heading "Applicators and other handlers must wearR to read "Pilots and handlers 

removing a triple-rinsed probe must wear:" At your discretion, you may delete the requirement in this 

section for "Chemical-resistant gloves ..... " 

5. Insert the heading RUser Safety Requirements" above the paragraph which begins "Follow 

manufacturer's instructions ... " 

6. Revise the Engineering Controls section on page 2 to read as follows: 

ENGINEERING CONTROLS 

Mixers and loaders must either: 

(1) use a closed system that meets the requirements listed in the Worker Protection 

Standard (WPS) for dermal protection of agricultural pesticides [40 CFR 

170.240(d)(4)], 

OR 

(2) Use the pr~be system described below: 

PROBE SYSTEM 

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

• 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. 

• Transfer 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. 

• Do not handle the probe or bung in a manner that allows dripping or 

splattering of the product onto yourself or any other person. 

• Do not touch the portion ofthe 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. 

• Take the following steps if the probe must be disconnected from the suction 

93
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~offvalve before disconnecting the probe. 

ALL TRANSFER SYSTEMS 

In addition, mixers and loaders using all systems must: 

• wear the personal protective equipment required 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 in 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 to minimize drippage. 

Flaggers: Human flagging is prohibited. Flagging to support aerial application is limited 

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

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

the requirements listed in the Worker Protection Standard (WPS) for agricultural 

pesticides [40 CFR 170.240(d)(6)). 

7. On page 6, delete the statement ''These requirements do not apply to forestry applications, public 

health uses or to applications using dry formulations" at the end of the second paragraph under 

"Spray Drift Management," since they're not relevant to this product. 

8. Remove the word "General" from the heading "General Spray Drift Restrictions for All States" on 

page 8. 

9. In the restrictions for rice in California (page 9) and the Southern U.S. (page 15) the distance from 

potable water intakes in flowing water and standing bodies of water should be changed from 2 miles to 

1/2 mile. 

Please submit a revised label (preferably by email) making these changes. As the PRIA date isn't too 

far away, a prompt response would be much appreciated. If you need clarification or have any 

questions about any of these required changes, feel free to call me at (703) 305~5218. 

Thanks, 

Susan 

94
a7290.XXXXX.201 01222. V1.pdf EPA Initial Regislralion Draft Label 

Active Ingredient: 

Willowood Propanil 4 SCI / 

Herbicide 

For Postemergence Weed Control in Rice / 

/ 

Propanil: 3', 4'-Dichloropropionanilide ....................................................... 41.4% ,,-

Other Ingredients: ..................................................................................... 58.6% 

TOTAL: ................................................................................................... 100.00% ' 

This product contains 41b. of active ingredient per gallon/ 

EPA Reg. No. 87290- I 

EPA Est. No. , 

Net Contents: I KEEP OUT OF REACH OF CHILDREN 

CAUTION ,,-

First Aid 

If inhaled: 

• Move person to fresh air. 

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

respiration, preferable mouth-to-mouth, if possible. 

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

If on skin or clothing: 

• Take off contaminated clothing. 

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

• Call a pOison control center or doctor for treatment advice. 

If in eyes: 

• Hold eye open and rinse slowly and gently with waterfor 15-20 minutes. 

/ 

/ 

/ 

• Remove contact lenses, 'if present, after the first 5 minutes, then continue rinsing 

eye. 

• Call a pOison control center or doctor for treatment advice. 

If swallowed: 

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

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

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

• Do not give anything by mouth to an unconscious person. J 

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

doctor, or going for treatment. .I 

Manufactured for: 

Willowood LLC 

1600 NW Garden Valley Blvd. Suite 130 

Roseburg, OR 97471 

Page 1 of21 

I 

95
87290.XXXXX. 201 01222.V1.pdf EPA Initial Registration Draft Label 

Precautionary Statements 

Hazards to Humans and Domestic Animals 

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

Wash thoroughly with soap and water after handling. Remove contaminated clothing 

and wash before reuse. 

Personal Protective Equipment (PPE) 

Some materials that are chemical-resistant to this product are natural rubber ~ 14 / 

mils. For 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 c {_ ?'? _ 1 vp spdG- Ilr "-'i.vl?"'-/- tJr Il!/..nvis<-

rP"~ct' tJlt#-'· ~ Mixers, loaders, nd MAef handler)lfexposed to the concentrate~~ ~k ./ 0 Coveralls over long-sleeve shirt and long pants, . re""""'/i .... 1 {. Chemical-resistant gloves made of any waterproof materials, ~ VllrlItU.d. 

r o Chemical-resistant footwear plus socks,' 'jJ",bl--

o Chemical-resistant headgear, if overhead exposure, and 

• Chemical resistant apronJ.lL: ... Mj~I""'1 ..,..,.;L /~A4t-i"1 

• '1Jroltt'/'-r-e ~~W~A~ IF II.- JyJk ..... op.,...~ (ft1#P-- 'jJr~fJv¥e-_ 

AppliGatoFs and other handlers'must wear:~ . ... -fr; (._n-"'fe.£ '7"v.6~ • Long-sleeved shirt and long pants, f7,ot''''VlI'11 IJ r' -

o Shoes plus socks, and 

emlca -resistant gloves made of any waterproof material such as butyl rubber, 

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

See Engineering Controls for additional requirements and options. 

I/Sk" .>,.;;.1-1' ~,/<-,In" .. -:f.r , 

Follow manu'lacturer'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 contaminated with this product's concentrate. Do not reuse 

them. 

Engineering Controls: __ 

When ha~ use closed systems in a manner that meet the requi ts lisl'ld in 

the Worker Protec I ndard (WPS) for agricultural pe .. s [40 CFR 170.240 (d) 

(4-6), the handler PPE reqUir may be red or modified as specified in the 

WPS. Pilots must use an enclosed coc . at meets the requirements listed in tr.e 

Worker Protection Standard or agricultu ticides [40 CFR 170.240 (d)(6)]. 

HUman flagging prohibi . lagging to support aerial app . is limited tv IJS& of 

the Global Posi . g System (GPS) or mechanical flaggers. 

-Sw 'P-:3 // .r ;>4~d-r:r /.iJ_ 

Page 2 of 21 

96
( 

87290.XXXXX.201 01222.V1.pdf EPA Initial Registration Draft label 

User Safety Recommendations 

Users should: 

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

• Remove clothing/PPE immediately if pesticide gets inside. Then wash thoroughly and put V 

on clean clothing. /' 

• Remove PPE immediately after handling this product. Wash the outside of gloves befl>fe 

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

Environmental Hazards 

This pesticide is 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 Of rinsate. , /" 

This chemical has properties and characteristics associated with chemicals detectect/' 

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 product may contaminate water through runoff following rainfall events and bV 

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

when rainfall is forecasted to occur within 48 hours. Levees should be constructe 

with adequate time prior to chemical application so 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. Ifterms are unacceptable, return 

at once unopened. 

Directions for Use / 

It is a violation of Federal law to use this product in a manner inc~stent with its 

labeling. / 

Read all Direclions for Use carefully before applying. 

Do not apply this product in a way that will contact workers or other persons, e;thbl / 

directly or through drift. Only protected handlers may be in the area during ap~hc"tion. 

For any requirements specific to your state or tribe, consult the agency responsible for 

pesticide regulation. 

Page 3 of21 

97
( 

87290.XXXXX.20101222.v1.pdf EPA Initial Registration Draft Label 

Agricultural Use Requirements , 

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

Standard, 40 CFR part 170. This Standard contains requirements for the protection of 

agricultural workers on farms, forests, nurseries, and greenhouses, and handlers of / 

agricultural pesticides. It contains requirements for training, decontamination, nottficatioll', 

and emergency assistance. It also contains specific instructions and exceptions pertaining 

to the statements on this label about personal protective equipment (PPE) and restrictedentry interval. The requirements in this box only apply to uses of this product that are 

covered by the Worker Protection Standard. 

Do not enter or allaWWorker entry into treated areaS during the restricted entry interval 

(REI) of 24 hour"v 

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

Standard and that involves contact with anything that has been treated, such as plants, soil 

or water, is: 

• Coveralls over long-sleeve shirt and long pants 

• Chemical-resistant gloves made of any waterproof materials, 

• Chemical-resistant footwear plus socks, 

• Protective eyewear 

Page 4 of21 

98
( 

87290.XXXXX.20101222.V1.pdf EPA Initial Registralion Draft Label 

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. If stored below 32F and crystals form, warm to 72F for 24 hours, v 

periodically shaking or rolling container to reconstttute. 

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. If / 

these wastes cannot be disposed of by use according to label instructions, oontact y6ur 

State Pesticide or Environmental Control Agency, or the Hazardous Waste 

representative at the nearest EPA region office for guidance. 

Container Handling: NONREFILLABLE CONTAINER (EQUAL 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 oontents into/ 

application equipment 01 a mix tank and drain for 10 seconds after the flow begi..t to 

drip. Fill the container 14 full with water and recap. Shake for 10 seconds. Pour rinsate 

into application equipment or a mix tank or store rinsate for later use or disposal. Drain 

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

Offer for recycling, if available. 

NONREFILLABLE CONTAINER (GREATER 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. Fill 

the container 14 full with water. Replace and tighten closures. Tip container on tts 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. Empty the rinsate into 

application equipment or a mix tank or store rinsate for later use or disposal. Repeat 

this procedure two more times. Offer for recycling, if available. 

REFILLABLE CONTAINER: Refill this container wtth pesticide only. Do not reuse this 

container for any other purpose. Cleaning the container before final disposal i" bl~ 

responsibility of the person disposing of the container. Cleaning before refilling i:ythe 

responsibiltty of the refiller. To clean the container before final disposal, empty 'he 

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 v.'i,h 

the pump for 2 minutes. Pour or pump rinsate into application equipment or rinsale 

collection system. Repeat this rinsing procedure two more times. 

Page 5 of 21 

99
87290.XXXXX.201 01222V1.pdf ( EPA Initial Registration Draft Label 

Product Information 

Willowood Propanil 4 SC for postemergence weed control in rice is formulated as a 

suspension concentrate containing 4 Ib active ingredient per gallon. Willowood 

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. Willowood Propanil4 SC has no preemergence or residual herbicidal / 

activity. Only weeds that have emerged and are exposed at time of application will bV 

controlled. Apply Willowood Propanil4 SC only to fields that have been drained of 

floodwater. Willowood Propanil 4 SC is most effective if applied when susceptible 

grasses and broad leaf 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 label instructions before application. When tank / 

mixing, always read all individual manufacturers' labels. In interpreting alilabels4'6r' 

the tank mixture, the most restrictive situations must apply. .. / 

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

SPRAY DRIFT MANAGEMENT / 

~ 

Avoiding spray drift at the application site is the responsibility of th7aPplicator and the . 

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

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

all these factors when making decisions. 

The wing drift management requirements must followed ;,to~a~v~o~id~Off~-~ta~rget drift 

movemen aerial applicat~t era s. :r: ~ 

not a ,pu ic healt ses or to applica Ions using dry 

fa mulatiopsz-

=-

1. The distance of the 0 er n operating nozzles on the boom must 

not exceed 3/4 the ngth of the . span or 90% of the rotor blade 

diameter. 

2. Nozzles mu always point backward paralle ·th the air stream and 

never be ointed downwards more than 45 degre 

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

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

the following Aerial Drift Reduction Advisory. 

Page 6 of21 

100
87290.XXXXX.20101222.V1.pdf EPA Initial Registration Draft Label 

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 environmental conditions (see Wind, Temperature and Humidity, and 

Temperature Inversions). 

Controlling Droplet Size: 

• Volume - Use high flow rate nozzles to apply the highest practical spra 

volume. Nozzles w·rth h"gher rated flows produce larger droplets. 

• Pressure - 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. 

• Number of Nozzles - Use the minimum number of nozzles that provide 

uniform coverage. 

• Nozzle 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. # 

• Nozzle Type - Use a nozzle type that is deSigned for the intended gre.-, 

application. With most nozzle types, narrower spray angles produce la er 

droplets. Consider using low-drift nozzles. Solid stream nozzles orient d 

straight back produce the largest droplets and the lowest drift. 

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

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 by adjusting the path of the aircr ft 

upwind. Swath adjustment distance should increase with increasing drift potential 

(higher wind, smaller drops, etc.). 

Wind: Drift potential is lowest between wind speeds of 2-1 a 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 pattems. 

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

drift. 

Page 7 of 21 

101
87290.XXXXX.201 01222.V1.pdf ( EPA Initial Registration Draft Label 

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

up equipment to produce larger droplets to compensate for evaporaiion. Droplet 

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

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

temperature inversion because drift potential is high. Temperature inversions restrict 

vertical air mixing, which causes small suspended droplets to remain in 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 V 

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, iffog is not 

present, inversions can also be identlfied 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 I 

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 0 

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

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

blowing away from the sensitive areas). 

C.".,,,,I Spray Drift Restrictions for All States 

/ 0 Apply only when the wind speed is less than or equal to 10 mph at the 

application site. 

o Apply as a medium or coarser spray (ASAE standard 572). 

o For ground applications, apply using a nozzle height of no more than 4 feet 

above the ground or crop canopy. 

o For aerial applications, do not apply by air if drift can occur to sensitive 

nontarget crops or plants that are within 100 feet of the application SITe. 0 

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. Do not make any type of application into 

temperature inversions. 

Page 8 0121 

102
87290.XXXXX.201 01222. V1.pdf EPA Initial Registration Draft label 

For Use on Rice Grown in California Only 

Restriction>; 

• Preharvest Interval: Do not apply this product within 60 days of rice v"" 

harvest. / 

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

system. 

• Do not apply more than a maximum of 6 quarts of Willowood Propanil 4 

SC (6 Ib active ingredient) per acre in a single application or exceed 8 ~ quarts of Willowood Propanil 4 SC (8 Ib of active ingredient) per acre total 

dosage per season. 

• In California: Use Willowood Propanil 4 SC only where rice fields are 

completely drained or a minimal amount of water remains. If high water 

level is desired, re-flood field after 12 hours and before 7 days after Vtreatment. This will discourage new weed infestations. 

-<_I:-.-... -A .• ~O.-:r/r Do not apply this product to any crop other than rice. Willowood Propanil 

4 SC will cause injury to most crops except cereal grains and perennial 

grasses. 

/. Do not apply this product (directly or indirectly) to wild rice (Zizania 

rI spp.). 

• Avoid drift or accidental application from turning aircraft on cotton, 

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

vineyards, gardens, shrubs and ornamentals. Once applied, Willowood' 

Propanil4 SC does not release fumes hazardous to nearby crops. / 

• Do not apply to fields nor drain water from treated fields into areas where' 

commercial catfish or crayfish (crawfish) farming is practiced. /' 

• Do not graze treated fields or feed treated forage within 60 days of the V 

last application. 

/-Do not rotate treated land to other crops or transplant to crops other than 

rice for 60 days following treatment of this product. 

j o Do not apply this product within 14 days before or after carbamate or 

organophosphate insecticide applications. Otherwise, serious injuries toV 

rice may occur. '!vI Water drained from treated ric~s must not be used to irrigate I / 

other crops or released withi~iles upstream of a po\llQ.le ~ rz-..-

intake in flowfng water (e.g. river, stream, etc,) or withir(2::ffiifes of a 

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

f pond, or reservoir. 

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

treated. 

Emerge~cy Release Provisions / 

Do not discharge water from treated rice paddies in California following treatment" /' 

unless excessive rainfall completely submerges the rice crop and forces prematur/( 

release, for: / 

• 7 days in dry seeded rice in California 

• 7 days for water-seeded rice in California / 

Page90f21 

103
87290.XXXXX.20101222.v1.pdf 

( 

EPA Initial Registration Draft Label 

Weeds Controlled , 

AnnualsedQes Cvperus spp. 

Barnyardgrass' Echinochloa crus-gal/i 

Crabgrass Diqitaria spp. 

Earlv waterqrass ',0 Echinochloa oryzoides /' 

Junglerice a E. co/onum ./ 

Late waterqrass a,o Echinochloa phvllopogon 

Ricefield bullrush Scirpus mucronatus 

Rice flatsedqe Cvperus iria 

Smallflower umbrella plant Cyperus difformis 

, In isolated instances, biotypes of barnyardgrass/watergrass may develop that 

cannot be effectively controlled by propanil alone. Where these biotypes are known 9r' 

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

Willowood Propanil4 SC is effective, tank mix Willowood 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 

partial 

Applications 

control. 

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

Timing and Dosage Recommendations 

Early Timing and Rates 

Apply Willowood Propanil4 SC when a satisfactory stand of rice has been established 

that will tolerate flooding. The amount ofWillowood Propanil4 SC to apply depends

V upon the growth stage and condition of the target weeds. Willowood Propanil4 SC is· 

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

actively growing under favorable soil moisture and weather conditions. Use a higher 

rate in the recommended rate range for heavy weed infestations, weeds in advanced 

stages of growth, or when growing conditions are less than optimum. Emergency 

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

tillering, must occur at least 60 days before harvest. 

For best results, apply Willowood Propanil4 SC at the rate of 3 to 4 quarts (3 to 4 Ib 

active ingredient) per acre when the grasses are actively growing in the 1 to early 4 

leaf stage. This rate will also control many seedling broad leaf and aquatic weeds. / 

Generally, this will be 15 to 25 days after planting. In order to insure satisfactory weet 

control, do not apply less than 3 quarts ofWillowood Propanil4 SC per acre in a 

single spray application. 

Mid-Timing and Rates 

Willowood Propanil4 SC can be applied at the rate of 4 to 6 quarts (4 to 6 Ib active jI 

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

Page 10 of21 

104
( 

87290.XXXXX.20101222.V1.pdf EPA Initial Regis1ration Draft Label 

stage, or when they are in the 2 to 4 leaf stage but stressed under 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, oV 

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

mixture, is recommended. 

Rescue Timing and Rates 

Apply Willowood Propanil4 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. V 

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

be relied upon for total control of grass and weeds. 

Mixing Directions 

Willowood Propanil4 SC will disperse more quickly if 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 Willowood 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. 

Willowood Propanil 4 SC must be completely dispersed and 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 Gar). 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. Shake 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 is added to the spray mixture, always allow for complete mixing / 

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

while filling the mixing tank to the desired spray volume. 

Do not add Willowood Propanil4 SC directly to the spray tank of aircraft. Once / 

properly dispersed in mix tank, pump spray mixture to aircraft spray tank (include V 

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

throughout application. 

Page 11 of21 

105
( ( 

87290.XXXXX.20101222.V1.pdf EPA Initial Registration Draft Label 

Application Equipment 

Aircraft 

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

produce a uniform pattern of medium-fine spray droplets. Apply Willowood Propanil4 ./ 

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

Increase volume to 12 to 15 gallons per acre for larger or denser stands of grass or (j) during periods of low humidity. . J 

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

:::araft being used. F ~;s:::~~);::~:~:~:~:.~=r:'8 IN"! ~1-1 <.J 

Measure the swaths accurately for fiaggin ~ tp4EJIJlS 

Ground Sprayers 

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

Use nozzle sizes that deliver a medium-fine droplet 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 boomV 

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 Willowood 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 Willowood 

Propanil4 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, Dverwatering, or prolonged V 

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. 

Page 12of21 

106
( 

87290.XXXXX.201 01222. V1.pdf EPA Initial Registration Draft Labsl 

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 seedbedVs 

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

and broadleaf weeds, allowing more accurate timing and coverage of Willowood 

Propanil4 SC sprays for optimum weed control. 

Water Management 

Before application of Willowood Propanil4 SC, drained or dry planted fields should be 

flushed as often as necessary to prevent drying and crusling. Flushing encourages 

unifonn emergence and vigorous growth of grass, broad leaf weeds and rice, which is 

essential for opflmum weed conlrol. Flushing of fields should occur when weeds and V 

rice are actively growing at time of trealment. Make sure the field is drained prior to 

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

partially submerged in standing water at time of application will not be satisfactorily 

coni rolled. 

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

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 Willowood Propanil4 SC has 

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

maximum temperatures increase above 75°F and decreases as the daily maximum 

lemperatures decline below 75°F. Do not apply Willowood Propanil4 SC when . / 

maximum temperatures have been or are expected to stay below 65°F or exceed {/ 

100"F. Less than oplimum temperature at time of application is not crttical so long as 

the temperature exceeds 75eF during the day. 

Relative Humidity and Rain 

Grasses and weeds are more responsive to Willowood Propanil4 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. For best results ~ 

under low relative humidtty conditions, increase spray volume to 12 to 15 galions perV 

acre. Do not spray if rain is expected within 8 hours to avoid loss of deposited spray 

and herbicide adsorption by the weeds. 

Wind .... / 

Do not apply when the wind speed exceeds 10 mph to avoid drift hazard to sens~ 

crops and the possibility of uneven (streaked) applications. 

Page 13 of 21 

107
I ( 

87290.XXXXX.201 01222. V1.pdf EPA InHial Regislra1ion Draft Label 

Compatibility With Other Chemicals 

Tank mix applications of Willa wood Propanil4 SC with other herbicides, insecticides,/ 

spray adjuvants, or liquid fertilizers may reduce crop tolerance andlor weed control or 

impair mixing properties. Use of these products in tank mix applications with 

Willowood Propanil 4 SC is done at the user's risk. 

Liquid Fertilizer: Premixing this product in a ratio of 1 part Willowood Propanil4 SC / 

to 2 parts water is recommended prior to mixing with liquid fertilizer. 

Adverse Reaction to Insecticides 

Rice plants may be severely injured or killed if Willa wood Propanil4 SC is applied in 

tank mix combinations or sequentially before or after certain insecticides. Do not 

combine Willowood Propanil 4 SC with carbamate insecticides such as carbaryl, etc., 

or organophosphorus insecticides (such as malathion and methyl parathion, etc). Do / 

not apply any of the carbamate or organophosphorus insecticides to rice fields within V 

14 days before or afterWiliowood Propanil4 SC. Do not use carbamate or systemic 

organophosphorus insecticides on rice fields to be treated with Willowood Propanil 4 

SC. 

Do not apply Willowood Propanil 4 SC to rice fields planted with rice seed treated witV 

bird repellents containing meth·,ocarb. Consult local Extension speciai"tstfor current 

recommendations of approved insecticides on rice 

For Use on Rice Grown in Southern United States Only V 

Arkansas, Louisiana, Mississippi, Missouri, Texas 

Restrictions 

• Preharvest Interval: Do not apply this product within 60 days of rice v' 

harvest. 

• Chemigation: Do not apply th·,s product through any type of irrigation .,/" 

system. 

• Do not apply more than a maximum of 6 quarts of Willa wood Propanil4 ~ 

SC (6 Ib active ingredient) per acre in a single application or exceed 8 V 

quarts of Willowood Propanil 4 SC (8 Ib of active ingredient) per acre total 

dosage per season. ~ 

• Do not plant or transplant crops in the treated area for at least 60 days 

following application. 

• Do not apply this product to any crop other than rice. Willowood Propanil /'" 

4 SC will cause injury to most crops except cereal grains and perennial 

grasses. 

• Do not apply this product (directly or indirectly) to wild rice (Zizania ~ spp.). 

• Avoid drift or accidental application from turning aircraft on cotton, 

soybeans, com, safflower, seedling legumes, vegetables, orchards, 

vineyards, gardens, shrubs and ornamentals. Once applied, Willowood 

~age 14 of21 

108
( 

87290.XXXXX.20101222.V1.pdf EPA InDia] RegistraHon Draft Label 

PropaniI 4 SC does not release fumes hazardous to nearby crops. ~ 

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

commercial catfish or crayfish (crawfish) farming is practiced. /' 

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

last application. .-/' 

• Do not rotate treated land to other crops or transplant to crops other tha" 

rice for 60 days following treatment of this product. 

• Do not apply this product within 14 days before or after carbamate or / 

organophosphate insecticide applications. Otherwise, serious injuries i6 

rice may occur. I/Z ? 

• Water drained from treated ric fie must not be used to irrigate /1 ? 

other crops or released within 2 iIes upstream of a po~l~ h . 

intake in flawing water (e.g. ri r, stream, etc,) or withi'(3Jffiues of a 

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

pond, or reservoir. 

• Do not apply when weather conditions favor drift from area to b 

treated. 

Emergency Release Provisions 

Water holding (discharge) intervals for flood water from treated rice paddi:~ ;oIlo~in9 ..A.-.-

treatment in the seuthe", United States (AR, LA, MS, MO, and TX): ~-

• For delayed flood (water-seeded) rice 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 apPlicationp unless excessive rainfall completely submerges 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. 

• For delayed flood (water-seeded) rice in the southern Louisiana south of 

Highway 14 - Flood water must be held for 15 days after propaniI application, 

unless excessive rainfall completely submerges the rice crop and forces 

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

the Hi9~ry, the water holding interval is 7 days. 

• For ric!7l'rylall other parts of the seutJ lelll United States not mentioned above -

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

completely submerges the rice crop and forces premature release. 

Page 15 of 21 

109
87290.XXXXX.20101222.V1.pdf ( ( 

EPA Initial Registration Draft Label 

Weeds Controlled 

Willowood Propanil4 SC provides selective postemergence control of the following 

weeds in rice· 

Annual sedQes Gyperus sPP. 

Bar'lyardgrass ' Echinoch/oa crus-gal/i 

Beakrush (spearhead) Rhynchospora comicu/ata 

Broadleaf signalgrass Brachanap/atyphytia 

Crabgrass Digitana sPP. 

Curlydock Rumex cnspus 

Foxtail Setaria spp. 

Gooseqrass Eleusine indica 

Gulf cockspur Echinoch/oa crus-pavonis 

Hemp sesbania (coffeebean) Sesbania herbacea 

Hoorahgrass Fimbnstylis miliaceae 

JunQlerice ' E. c%num 

Mexicanweed Gaperonia castanaefolia 

ParaQrass Panicum purpurascens 

Redroot pigweed Amaranthus retroflexus. 

Redweed Me/ochia corchonfolia 

Rice fiatsedge Gyperus ina 

Smallflower umbrella plant Gyperus difformis 

Spikerush (wireQrass) E/eocharis spp. 

Texas panicum Panicum lexanum 

Waterqrass ' Echinoch/oa soo. 

Woolly croton Groton spp. 

, In isolated instances, biotypes of barnyardgrass/watergrass may develop that 

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

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

Willowood Propanil 4 SC is effective, tank mix Willowood Propanil4 SC at label 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 Willowood Propanil4 SC when a satisfactory stand of rice has been established 

that will tolerate flooding. The amount ofWiliowood Propanil4 SC to apply depends 

upon the growth stage and condition of the target weeds. Willowood Propanil4 SC is / 

most effective if applied when susceptible grasses and broadleafweeds are small avid 

actively growing under favorable soil moisture and weather conditions. Use a higher 

rate in the recommended rate range for heavy weed infestations, weeds in advanced 

stages of growth, or when growing conditions are less than optimum. Emergency 

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

tiIIering, must occur at least 60 days before harvest. 

Page 16 of 21 

110
( 

87290.XXXXX.20101222.V1.pdf EPA Initial Registration Draft label 

For best res~lts, apply Willowood Propanil 4 SC at the rate of 3 to 4 quarts (3 to 4 Ib 

active ingredient) per acre when the grasses are actively growing in the 1 to early 4 /' 

leaf stage. This rate will also control many seedling broadleaf and aquatic weeds. V 

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

Mid-Timing and Rates 

Willowood Propanil4 SC can be applied at the rate of 4 to 6 quarts (4 to 6 Ib active 

ingredient) per 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. V 

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

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

other 80% active non ionic surfactant at a rate of 1 to 2 pints per 100 gallons of sprayV 

mixture, is recommended. 

Rescue Timing and Rates 

Apply Willowood Propanil4 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 fillering 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. V 

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

be relied upon for total control of grass and weeds. 

Mixing Directions 

Willowood Propanil4 SC will disperse more quickly if 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 Willowood Propanil4 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. 

Willowood Propanil 4 SC must be completely dispersed and 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 f10wables or wettable powders first, flowables second, / 

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

into solution prior to the addition of the next material. Shake 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 is added to the spray mixture, always allow for complete mixing 

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

Page 17 of 21 

111
i ( 

87290.XXXXX.20101222.V1.pdf EPA initial Registration Draft Label 

while filling the mixing tank to the desired spray volume. 

Do not add Willowood Propanil4 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 have well-designed spray systems that 

produce a uniform pattern of medium-fine spray droplets. Apply Willowood Propanil4 / 

SC in no less than 10 gallons of total spray per acre with boom-nozzle sprayers. V" 

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 /' 

aircraft being used. For uniform spray coverage with fixed-wing aircraft or helicopt;;(' 

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 fiat fan nozzles. 

Use nozzle sizes that deliver a medium-fine droplet 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 V 

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 Willowood Propanil 4 SC, WITh detergent wash follo,!,ejV' 

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

Crop Tolerance and Growing Conditions 

All leading commercial varieties of rice are exceptionally tolerant to Willowood 

Propanil4 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, DveIWatering, or prolonged V 

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 seedbeds II 

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

Page 18 of2l 

112
8729D.XXXXX.2D1 01222. V1.pdf EPA Initial Registration Draft label 

and broad leaf weeds, allowing more accurate timing and coverage of Willowood 

Propanil 4 SC sprays for optimum weed control 

Water Management 

Before application of Willowood Propanil4 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 weedsrrnd . 

rice are actively growing at time of treatment. Make sure the field is drained prio t 

treatment so that grasses and broad leaf weeds are fully exposed. Weeds that a e 

partially submerged in 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 flo~d~d / 

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

Temperature 

The temperature a few days before and after applying Willowood Propanil4 SC has 

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

maximum temperatures increase above 75°F and decreases as the daily maximum / 

temperatures decline below 75°F. Do not apply Willowood Propanil 4 SC when V 

maximum temperatures have 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 75'F during the day. 

Relative Humidity and Rain ~i 

Grasses and weeds are more responsive to Willowood Propanil4 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. For best result 

under low relaflve humidity conditions, increase spray volume to 12 to 15 gallons per 

acre. Do not spray if rain is expected wtthin 8 hours to avoid loss of deposited spray 

and herbicide adsorption by the weeds. 

Wind 

Do not apply when the wind speed exceeds 10 mph to avoid drift hazard to sensitiv~ 

crops and the possibility of uneven (streaked) applications. 

Compatibility With Other Chemicals 

Tank mix applications of Willowood Propanil 4 SC with other herbicides, insecticid,;,s, .--/ 

spray adjuvants, or liquid fertilizers may reduce crop tolerance and/or weed controJ.9v" 

impair mixing properties. Use of these products in tank mix applications with 

Willowood Propanil4 SC is done at the user's risk. 

Liquid Fertilizer: Premixing this product in a ratio of 1 part Willowood Propanil,4 foG 

to 2 parts water is recommended prior to mixing with liquid fertilizer. V 

Page190f2f 

113
, 

, 

87290.XXXXX.20101222.V1.pdf ( ( EPA Initial Registration Draft label 

Adverse Reaction to Insecticides 

Rice plants may be severely injured or killed ifWillowood Propanil4 SC is applied in 

tank mix combinations or sequentially before or after certain insecticides. Do not~ 

combine Willowood Propanil4 SC with carbamate insecticides such as carbaryl, tc. 

or organophosphorus insecticides (such as malathion and methyl parathion, etc) 0 

not apply any of the carbamate or organophosphorus insecticides to rice fields within 

14 days before or after Willowood Propanil4 SC. Do not use carbamate or systemic 

organophosphorus insecticides on rice fields to be treated with Willowood Propanil4 

SC. 

Do not apply Willowood Propanil 4 SC to rice fields planted with rice seed treated 'A(ith // 

bird repellents containing methiocarb. Consult local Extension specialist for current V 

recommendations of approved insecticides on rice. 

LIMIT OF WARRANTY AND LIABILITY 

IMPORTANT: READ BEFORE USE 

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

Limitations of Liability before using this product. If terms are not acceptable, urn the 

unopened product container at once. 

By using this product, user or buyer accepts the following Conditions, IS71aime of 

Warranties and Limitations of Liability. 

CONDITIONS: The directions for use of this product are believed to b€:3dequate and 

must be followed carefully. 

However, it is impossible to eliminate all risks associated with the use ofthis product. 

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

such Jactors as weather conditions, presence of other materials ' the manner of use 

or application, all of which are beyond the control of Willow LLC. To the extent 

consistent with applicable law, all such risks shall be ass med by the user or buyer,' ~ 

DISCLAIMER OF WARRANTIES: TO THE EXTENT CONSISTENT WITH / 

APPLICABLE LAW, WILLOWOOD LLC MAKES NO OTHER WI',RRA,r,IT1ES, 

EXPRESS OR IMPLIED, OF MERCHANTABILITY OR OF FITN~FOR A 

PARTICULAR PURPOSE OR OTHERWISE, THAT EXTEND BEYOND THE 

STATEMENTS MADE ON THIS LABel. To the extent consistent with applicable law, 

no agent of Willowood LLC is authorized to make any warranties beyond those 

contained herein or to modify the warranties contained herein. TO THE EXTENT 

CONSISTENT WITH APPLICABLE LAW, WILLOWOOD LLC DISCLAIMS ANY / 

LIABILITY WHATSOEVER FOR SPECIAL, INCIDENTAL OR CONSEQUENTIAL / 

DAMAGES RESULTING FROM THE USE OR HANDLING OF THI PRODUCT,., 

LIMITATIONS OF LIABILITY: TO THE EXTENT CONSISTENT WI H APR 'ItABLE 

LAW, THE EXCLUSIVE REMEDY OF THE USER OR BUYER FO AND ALL 

LOSSES, INJURIES OR DAMAGES RESULTING FROM THE USE OR HANDLING 

OF THIS PRODUCT, WHETHER IN CONTRACT, WARRANTY, TORT, 

Page 20 of21 

/ 

114
87290.XXXXX.20101222.V1.pdf ( EPA Initial Registration Draft Label 

NEGLIGENCE, STRICT LIABILITY OR OTHERWISE, SHALL NOT EXCEED THE 

PURCHASE PRICE PAID, OR AT WILLOWOOD LLC'S ELECTION, THE 

REPLACEMENT OF PRODUCT. 

Page 21 of21 

115
, . ( 

DATA PACKAGE BEAN SHEET 

Date: 02-Feb-2011 

Page 1 of2 

* * * Registration Information * * * 

Registration: 87290-RI - WILLOWOOD PROPANIL 4 SC 

Company: 87290 - WrLLOWOOD USA, LLC 

Risk Manager: RM 25 - Linda Arrington - (703) 305-6249 Room# PY1 5-6651 

Risk Manager Reviewer: Susan Stanton SSTANTON 

Sent Date: --- Calculated Due Date: 13-Apr-20 t t 

Type of Registration: Product Registration - Section 3 

Action Desc: (R300) NEW PRODUCT;ME-TOO PRODUCT FAST TRACK", 

Ingredients: 028201, Propanil(4t.4%) 

* * * Data Package Information * * * 

Expedite: 0 Yes. No Date Sent: 02-Feb-20 t t 

DP Ingredient: 028201, Propanil 

DP Title: New Me-Too Product 

Decision #: 443657 

DP #: (386417) 

PRIA 

Parent DP #: 

Submission #: 887956 / 

rtY/ti;JY 

Edited Due Date: ____ _ 

Due Back: ___ ~ 

CSF Included: • Yes 0 No Label Included: • Yes 0 No Parent DP #: ____ _ 

Assigned To Date In Date Out 2>4b'--l.\ 

Organization: "R~D~/~T"R~B,---______ _ _ ____ Last Possible Science Due Date: ~f-N!WG11 

Team Name: ,C~H,E~M,---_______ _ Science Due Date: ____ _ 

Reviewer Name: __________ _ Sub Data Package Due Date: ____ _ 

Contractor Name: __________ _ 

* * * Studies Sent for Review * * * 

Printed on Page 2 

* * * Additional Data Package for this Decision * * * 

No Additional Data Packages 

* * * Data Package Instructions * * * 

Attn: TRB/CHEM 

Willowood, LLC. has submitted an application to register this new propanil product, claiming substantial similarity to Stam 4SC Herbicide (EPA 

Reg. No. 70506·167. The company has submitted product chemistry data as identified in the attachment to this bean sheet in support of 

registration. Please determine whether the submitted product chemistry data support registration and whether the submitted CSFs (basic and 

alternate) and proposed label are acceptable. 

Copies of the company's cover letter, data matrix, CSFs (for the new and cited product) and label (for the new and cited product) are attached, 

along with the submitted product chemistry data. rm not sure you need the cited product labetlCSFs, since they've submitted their own data, 

but I'm including them just in case. If you need other information, just let me know. 

Thanks, 

Susan 

116
( Page 2 ( 

DP#: (386417) * * * Studies Sent for Review * .. * Decision#: (443657) 

-,' ""'M'6""'';'<-'"'1''' , "~'''>I ;'iilb'A"'d!""ii""" ""c''''''''''''''1 <'-"_M;' - ' </\ -.' ····.··.·O!·,·,·,··,·;;;;-.·R' ;;:,-;:""-;;,..-,,, --' .•.••.•...... -' '," ------<.· .. ·.·.·.· .. ·.· .•. · .. '.···.1 .. ••· .• · .• · ..·.· ... '.---- -- "_ .... · ... h;\I·'-;;,',",' , ..........•.•..................... ··.···.·.1 ".,; "p;"."'" ';X,'''. ;".",,,'04,0<', ".,.,!,;x'::.' .,'3.;.;,.. ., • .,., ,.~ . v; ., . 

48336301 Byrd, C. (2010) Product Chemistry - Product Identity and 

Composition, Description of Materials Used to Produce the 

Product, Description of the Production Process, Description of the 

Formulation Process, and Discussion of Formation of Impurities: 

48336303 

48336303 

48336302 

48336302 

48336301 

48336300 

48336303 

48336303 

48336303 

48336301 

48336303 

48336303 

48336303 

48336301 

Willowood Propanil4 SC. Unpublished s1udy prepared by 

Willowood LLC. 65 p. 

Miller, R. (2010) Propanil 4SC - Product Chemistry: Product 

Properties: Color, Physical Slate, Odor, Oxidalion/Reduction: 

Chemical Incompatibil~y, pH, Viscosity, and Density. Project 

Number: ARC/EXl872/006/P/1. Unpublished study prepared by 

Analytical & Regulatory Chemistry, Inc. 15 p. 

Miller, R. (2010) Propanil4SC - Product Chemistry: Product 

Properties: Color, Physical Slate, Odor, Oxidation/Reduction: 

Chemical Incompatibility, pH, Viscosity, and Dens~y. Project 

Number: ARCIEXl872/006/P/1. Unpublished study prepared by 

Analytical & Regulatory Chemistry, Inc. 15 p. 

Byrd, C. (2010) Willowood Propanil 4 SC: Preliminary Analysis, 

Certified Limits and En10rcement Analytical Method. Project 

Number: ARC/DP/MTH/211/PI2. Unpublished study prepared by 

Willowood USA, LLC. 23 p. 

Byrd, C. (2010) Willowood Propanil 4 SC: Preliminary Analysis, 

Certified Limits and Enforcement Analytical Method. Project 

Number: ARC/OP/MTH/21t/PI2. Unpublished study prepared by 

Willowood USA, LLC. 23 p. 

Byrd, C. (2010) Product Chemistry - Product Identity and 

Composition, Description 01 Materials Used to Produce1he 

Product, Description of the Production Process, Description of the 

Formulation Process. and Discussion 01 Formation of Impurities: 

Willowood Propanil4 SC. Unpublished s1udy prepared by 

Willowood LLC. 65 p. 

Willowood, LLC (2010) Submission 01 Product Chemistry Data in 

Support 01 the Application for Registration 01 Willowood Propanil4 

SC. Transmittal of 3 Studies. 

Miller, R. (20 to) Propanil 4SC - Product Chemistry: Product 

Properties: Color. Physical State, Odor, Oxida1ion/Reduction: 

Chemical Incompatibility. pH, Viscos~y, and Density. Project 

Number: ARCIEXl872/006/P/1. Unpublished study prepared by 

Analytical & Regulatory Chemistry. Inc. 15 p. 

Miller. R. (2010) Propanil 4SC - Product Chemistry: Product 

Properties: Color, Physical State. Odor, Oxidation/Reduction: 

Chemical Incompatibility, pH, Viscosity, and Density. Project 

Number: ARC/EXl8721006/P/1. Unpublished study prepared by 

Analytical & Regulatory Chemistry, Inc. 15 p. 

Miller, R. (2010) Propanil4SC - Product Chemistry: Product 

Properties: Color, Physical Stale. Odor, Oxidation/Reduction: 

Chemical Incompa1ibility, pH, Viscosity, and Density. Project 

Number: ARC/EXl8721006/P/t. Unpublished study prepared by 

Analytical & Regulatory Chemistry, Inc. 15 p. 

Byrd, C. (2010) Product Chemistry - Product Identity and 

Composition, Description 01 Materials Used10 Produce1he 

Produc1, Description 01 the Production Process, Description 01 the 

Formulation Process, and Discussion 01 Formation 01 Impurities: 

Willowood Propanil4 SC. Unpublished study prepared by 

WilJowood LLC. 65 p. 

Miller, R. (2010) Propanil 4SC - Product Chemistry: Product 

Properties: Color, Physical State, Odor, Dxidation/Reduction: 

ChemicallncompatibilMy, pH, Viscosity, and Density. Project 

Number: ARC/EXl872/006/P/t. Unpublished s1udy prepared by 

Analytical & Regulatory Chemistry, Inc. t5 p. 

Miller, R. (2010) Propanil4SC - Product Chemistry: Product 

Properties: Color, Physical State, Odor, Oxidation/Reduction: 

Chemical Incompatibility. pH, Viscosity, and Density. Project 

Number: ARCIEXl872/006/P/1. Unpublished study prepared by 

Analytical & Regulatory Chemistry, Inc. 15 p. 

Miller, R. (2010) Propanil4SC - Product Chemis1ry: Product 

Properties: Color, Physical State, Odor, Oxida1ion/Reduction: 

Chemical Incompatibility, pH, Viscosity, and Density. Project 

Number: ARC/EXl8721006/P/1. Unpublished study prepared by 

Analytical & Regulatory Chemistry, Inc. 15 p. 

Byrd, C. (2010) Product Chemistry - Product Identity and 

Composition, Description of Materials Used to Produce the 

Product, Description of the Production Process, Description of the 

Formulation Process, and Discussion of Formation of Impurities: 

Willowood Propanil4 SC. Unpublished study prepared by 

Willowood LLC. 65 p. 

830.t670/Discussion 0110rmation 01 

impurities 

830.6313/Stability to normal and 

elevated temperatures. metals, and 

metal ions 

830.7300/Densitylrelative density 

830.17501Certified limits 

830.1700/Preliminary analysis 

830.1650/Descrip1ion 01 formulation 

process 

830.7000/pH 

830.6304/Ddor 

830.6314/0xidizing or reducing 

action 

830.1600/Description 01 materials 

used10 produce the product 

830.6315/Flammability 

830.6303/Physical state 

830.710ONiscosity 

830.1550/Product Identity and 

composition 

117
( Page 2 

DP#: (3864 t7) *" * Studies Sent for Review * * * Decision#: (443657) 

:';;;?Jij);~lJ;it;;hil rj&wi:;;4I~Y:?1: ;:h1!J~$lIt4'$;:DjT,jy:;j{ /(-ZKHI tg,;:'+~ft;;::\{i{?:;'iy[;\;;,g;d't0;Qs%55iUiit6ci;~efe:te'rjCin >///,/<'/ ",,:,:~,>/': :-:>:Li;1-:/ k/ '£jr;s\:', ,,'::';::dUj8ijjfij'e~'i'§"J:?S~-\ ,,';:;;<{:I 

48336301 Byrd, C. (2010) Product Chemistry - Product Identity and 

Composition, Description of Materials Used to Produce the 

Product, Description of the Production Process, Description of the 

Formulation Process, and Discussion of Fonnaiion of Impurities: 

48336303 

48336302 

Willowood Propanil4 SC. Unpublished study prepared by 

Willowood LLC. 65 p. 

Miller, R. (2010) Propanil 4SC * Product Chemistry: Product 

Properties: Color, Physical State, Odor, Oxidation/Reduction: 

Chemical Incompatibility, pH, Viscosity, and Density. Project 

Number: ARC/EXl8721006/P/1. Unpublished study prepared by 

Analytical & Regulatory Chemistry, Inc. 15 p. 

Byrd, C. (2010) Wil!owood Propanil4 SC: Preliminary Analysis. 

Certlfied limits and Enforcement Analytical Method. Project 

Number: ARC/OP/MTH/2 t UPf2. Unpublished study prepared by 

Willowood USA .. LLC. 23 p. 

830.1620/Description of production 

process 

830.6302/Color 

830. t800/Enforcement analytical 

method 

118
( 

DP BARCODE No.: 386417 

PC Coders): 028201 

FILE SYMBOL No.: 87290-RI 

ACTION CODE: R 300 

DATE: February 13,2011 

SUBJECT: End Use Product Chemistry Review 

Product Name: Willowood Propanil4SC 

FROM: Akiva Abrarnovitch 

Product Chemistry Team 

DECISION No.: 443657 

FOOD Use: Yes 

Technical Review Branch I Registration Division (7505P) 

TO: PM 25 Kable Davis/Susan Stanton 

Herbicide Branch I Registration Division (7505P) 

Company Name: Willowood Propani14SC 

Formulation Type: Liquid Herbicide (solution) 

INTRODUCTION: 

The applicant requested a new food use and non food end use product. In support of the application, 

the applicant submitted product chemistry data corresponding to guideline 830 series, group A & 

group B. The registrant claims that their product is substantially similar to product EPA Reg. No. 

70506-167 by United Phosphorous 

TRB has been asked to determine the acceptability of the product chemistry data and the proposed 

basic and alternate CSFs dated December 22, 2010 (Replaced by February 15,2011 CSFs). 

SUMMARY OF FINDINGS: 

1. Name of Active Ingredient(s): Propanil 

2. All of the source materials of the active ingredient are derived from registered sources. 

3. All inert ingredients have been screened by IIAB and found to be approved for the proposed 

labeled uses (food use). 

4. Confidential Statement of Formula(s): 

[Xl Basic and Alternate Dated: 12122/10 

Basic and Alternate CSFs resubmitted (corrected) 02115111 (differ in manufacturing sites) 

119
DP BARCODE No.: 386417 FILE SYMBOL No.: 87290-Rl 

PC Code(s): 028201 ACTION CODE: R 300 

5. Product label: 

DECISION No.: 443657 

FOOD Use: Yes 

a. Ingredient statement: Nominal concentration of AI listed on CSF(s) concur with product label 

(PR Notice 91-2) 

[ X] Yes, if not, explain below: 

Metallic equivalent: [ ] Yes [X] NA; 

Soluble arsenic: [ ] Yes [X] NA 

Isomeric ratios: [ ] Yes [X] NA 

b. Health related sub statements: Product contains? 

Petroleum distillate at> 10%: [] Yes [X]No [ ]NA 

Methanol at> 4%: [ ] Yes [X] No [ ] NA 

c. Physical chemical hazard statement: Product label requires a statement per 40 CPR § 156.78 

for: flammability, explosive potential or electric insulator breakdown? 

[]Yes [X] No 

Is the sub statement in compliance with PR Notice 97-6? [X] Yes, ifnot, explain below: 

d. Label requires an additional Storage and Disposal statement: [ ] Yes [X] No; if yes explain 

below: 

2 

120
( ( 

DP BARCODE No.: 386417 FILE SYMBOL No.: 87290-RI DECISION No.: 443657 

PC Coders): 028201 ACTION CODE: R 300 FOOD Use: Yes 

7, Group A: Product Chemistry Data 

TRB's detennination of the acceptability of the data for the proposed product is listed in the 

tables below. 

Data TRB's 

Guideline submitted Assessment 

No. Study Title Yes No of Data MRIDNos. 

Product Identity & Y 483363-01 

830.1550 Comnosition A 

Description of materials used Y 483363-01 

830.1600 to nroduce the nroduct A 

Description of formulation Y 483363-01 

830.1650 nrocess A 

Discussion on the [onnation 483363-01 

830.1670 of imnurities Y A 

830.1700 Preliminary analysis ** NA 

Standard 

certified Y 

Certified limits A 

limits 

(158.350) Prooosed Limits 

Justification for 483363-01 

830.1750 wider limits 

Enforcement analytical 483363-02 

830.1800 method Y A 

A ~ Acceptance. N ~ Not Acceptable. G ~ Data Gap. 

W = Waiver Request, I = In Progress, NA = Not Applicable 

** Group A and B product chemistry data are required for both the end use product and the 

active ingredient source. 

3 

121
( ( 

DP BARCODE No.: 386417 FILE SYMBOL No.: 87290-RI DECISION No.: 443657 

PC Coders): 028201 ACTION CODE: R300 FOOD Use: Yes 

8. GroupB: 

Guideline Study Title Value or Qualitative MRID Nos. 

No. Description 

483363-03 

830.6303 Physical State Liquid (beige) 

483363-03 

830.6315 Flammability None 

483363-03 

830.6316 Explodability None 

483363-03 

830.7000 IpH 6.45 

1.167 gm/ml9.74lb/gal at 483363-03 

830.7300 Density (units) 24C 

A = Acceptance, N = Not Acceptable, G = Data Gap, W = Waiver request, 

NA = Not applicable, I = In progress 

CONCLUSIONS: 

Data Status 

A 

A 

A 

A 

A 

TRB has reviewed the CSF(s) and product chemistry data for the proposed end use product and 

has concluded: 

1. Basic and Alternate CSFs dated 2115/2011 are acceptable and will be added to our files. 

2. All required Group A data were reviewed and determined to be Acceptable 

3. All required Group B data were reviewed and determined to be Acceptable; exceptguidelines 830.6317 (storage stability) and 830.6320 (corrosion characteristics). The 

registrant is required to generate one year storage stability & corrosion characteristics study. 

The recommended observations periods are 0, 1,3,6,9, & 12 months intervals. 

4. The proposed label was screened as it pertains to the product chemistry requirements. The 

final review of the proposed label and uses are the purview of the PM team. 

5 This product is identical in composition product EPA Reg. No.70506-167 STAM 4SC. 

4 

122
I 

DP BARCODE No.: 386417 FILE SYMBOL No.: 87290-Rl 

PC Code(s): 028201 ACTION CODE: R 300 

CONFIDENTIAL APPENDIX: 

DECISION No.: 443657 

FOOD Usc: Yes 

Carry-over impurities in intentionally added ingredients 

Inert ingredients in the end-use product are recognized formulation ingredients (see Confidential 

Statement of Formula). There is no known or apparent opportunity for introducing impurities of 

significance from use of the listed inert ingredients. 

5 

123 *Manufacturing process information may be entitled to confidential treatment*
DATA PACKAGE BEAN SHEET 

Date: 02-Feb-2011 

Page 1 Of 1 

Decision #: 443657 

DP #: (386419) 

PRIA 

Parent DP #: 

* * * Registration Information * * * 

.

='="'-"-""------___ subm~ission:j:# .. :,.,8~879~6 Registration: 87290~RI ~ WILLOWOODJ:'ROPANIL 4 SC 

Company: 87290· WILLOWOOD USA, LLC 

Risk Manager: RM 25 - Linda Arrington - (703) 305-6249 Room# PY1 S-6651 

Risk Manager Reviewer: Susan Stanton SSTANTON 

Sent Date: ____ _ Calculated Due Date: 13-Apr-2011 Edited Due Date: ____ _ 

Type Of Registration: Product Registration - Section 3 

Action Desc: (R300) NEW PRODUCT;ME-TOO PRODUCT FAST TRACK', 

Ingredients: 028201, PropanU(41.4%) 

* * * Data Package Information * * * 

Expedite: 0 Yes • No Date Sent: 02-Feb-2011 Due Back: ___ _ 

DP Ingredient: 028201, Propanil 

DP Titre: New Me-Too Product 

CSF Included: • Yes 0 No Labe! !ncluded: • Yes 0 No Parent DP #: ___ _ 

Assigned To Date In Date Out 

Organization: cR~D~/~T~R~B,-______ _ 

Team Name: cT~O~X _________ _ 

Reviewer Name: __________ _ 

Contractor Name: __________ _ 

* * * Studies Sent for Review * * * 

No Studies 

A~'-'­ :7-'-'-' 

Last Possible Science Due Date: ~ 

Science Due Date: ____ _ 

Sub Data Package Due Date: ____ _ 

* * * Additional Data Package for this Decision * * * 

Can be printed on its own page J. 

* * * Data Package Instructions * * * , . ) : 

Attn: TRBfTOX 

Willowood, LLC. has submitted an application to register this new propanil product, claiming substantial similarity to Stam 4SC Herbicide (EPA 

Reg. No. 70506-167). The company is using 1he cite-ali method of support for acute toxicity data and has made a general offer to pay in 

compliance with the regulations. Please determine whether the product is substantially similar to EPA Reg. No. 70506-167 and whether the 

proposed precautionary !anguage on the label is appropriate 10r this product. 

Copies of the company's cover letter, data matrix, CSFs (for the new and cited product) and labe! (for the new and cited product) are attached. 

If you need other information, just let me know. 

Thanks, 

Susan 

124
EPA File Symbol 87290-RI 

PC Code 02820 I (propanil) 

( 

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 

WASHINGTON, D.C. 20460 

OFFICE OF CHEMICAL SAFETY AND 

POLLUTION PREVENTION 

o lIMARl20 11 

TECHNICAL REVIEW BRANCH 

SIMILARITY DETERMINATION 

MEMORANDUM 

Subject: 

From: 

To: 

Applicant: 

Name of Pesticide Product: 

EPA Reg. No.lFile Symbol: 

DP Barcode: 

Decision No: 

Action Code: 

PC Code: 

Willowood Propanil 4SC 

87290-Rl 

D3864l9 

443657 

R300 

028201 (propanil) 

Eugenia McAndrew, Biologist ~./1LciL.£.w Technical Review Branch g ~ ~ Registration Division (7505P) 

Susan Stanton, RM Team 25 

Herbicide Branch 

Registration Division (7505P) 

Willowood, LLC 

c/o Wagner Regulatory Associates, Inc. 

P.O. Box 640 

Hockessin, DE 19707 

FORMULATION FROM LABEL: 

Active Ingredient(s): 

Propanil 

Inert Ingredient(s): 

Total: 

% bywt. 

41.4 

58.6 

100.00% 

ACTION REQUESTED: The Risk Manager requests: Willowood, LLC has submitted an 

application to register this new propanil product, claiming substantial similarity to Starn 4SC 

Herbicide (EPA Reg. No. 70506-167). 

Page I of3 

125
EPA File Symbol 87290-RI 

PC Code 028201 (propanil) 

( ( 

BACKGROUND: Willowood, LLC has applied for registration of Willowood Propanil 4SC, 

EPA File Symbol 87290-RI, claiming similarity to Starn 4 SC, EPA Reg. No. 70506-167. 

The active ingredient in both .products is 41.4% propaniL The Registrant is using the cite-all 

method of data support to satisfy the acute toxicity data requirements. The submission includes 

basic and alternate # 1 CSFs dated December 22, 2010 for the proposed product, basic and five 

alternate CSFs for the cited product all dated August 22, 2007, labels for both products, a data 

matrix and company letter. 

A search of the OPP electronic databases shows that six acute toxicity studies were submitted to 

support the registration of the cited product, 70506-167 (transferred from 62719-482). These 

studies were reviewed and classified as acceptable in a prior TRB memo (Hashim; D284375; 

EPA File Symbol 62719-UIE; 08/0CT/2002). 

RECOMMENDA TraNS: 

1. TRB compared the formulations of the proposed product, 87290-RI, and the cited product, 

70506-167, and determined that the two products are substantially similar. 

2. The acute toxicity profile for the proposed product, Willowood Propanil4SC, EPA File 

Symbol 87290-RI, is as follows: 

acute oral toxicity 

acute dermal toxicity 

acute inhalation toxicity 

primary eye irritation 

primary skin irritation 

dermal sensitization 

IV 

IV 

IV 

IV 

IV 

negative 

cited 

cited 

cited 

cited 

cited 

cited 

EPA Reg. No. 70506-167 

EPA Reg. No. 70506-167 

EPA Reg. No. 70506-167 

EPA Reg. No. 70506-167 

EPA Reg. No. 70506-167 

EPA Reg. No. 70506-167 

3. This memorandum pertains only to the decision concerning whether the subject product is 

similar to the cited product from an acute toxicological view point. For the purposes of this 

action, TRB has made no further determination of the adequacy of the toxicological data base or 

the precautionary label of the cited product. 

4. The proposed basic and alternate CSFs dated December 22, 2010 must be accepted by the 

TRB Product Chemistry Team. 

Page 2 of3 

126
EPA File Symbol 87290-RI 

PC Code 02820 I (propanil) 

( ( 

LABELING: Based on the toxicity profile above, the following are the precautionary and first 

aid statements for this product as obtained from the Label Review System: 

PRODUCT ID #: 

PRODUCT NAME: 

SIGNAL WORD: 

(optional) 

087290-00018 

Willowood Propanil4 SC 

PRECAUTIONARY STATEMENTS 

CAUTION 

Hazards to Humans and Domestic Animals: 

First Aid: No statements are required. Category III statements may be used. 

Personal Protective Equipment for Handlers: Wear: Long-sleeved shirt and long pants, socks, 

shoes. 

Page 3 of3 

127
" ( 

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 

WASHINGTON, D.C, 20460 

PESTICIDES AND 

08/0CT/2002 

MEMORANDUM 

~ ~OFPREVENTION' TOXIC SUBSTANCES 

Subject: Name of Pesticide Product: . Stam' 4 SC 

EPA File Symbol: 62719-UIE -1'+'1;\,,( 'L lOSb~' \1 7 

DP Barcode: D284375 v~ r u e 

From: 

To: 

Case No: 072423 

PC Code: 028201 

Masih Hashim, Toxicologist 

Technical Review Branch 

Registration Division (7505C) 

Wesley Allen, PM Team 25 

Herbicide Branch 

Registration Division (7505C) 

Applicant: Dow AgroSciences LLC 

9330 Zionsville Road 

Indianapolis, IN 46268 

FORMULATION FROM LABEL: 

Active Ingredient(s): 

Propanil 

Inert Ingredient(s): 

Total: 

% bywt, 

41.4 

58,6 

100, 

0% 

128
( 

ACTION REQUESTED: PM requests review of acute toxicity data for File Symbol 

62719-UIE Propanil (41.4%). 

BACKGROUND: Dow AgroSciences LLC has submitted a set of acute toxicity studies to 

support the registration of STAM* 4 SC, EPA File Symbol 62719-UIE. The animal studies 

were conducted at the Rohm and Haas Toxicology Department, Spring House, PA and MPI 

Research, Mattawan, MI. 

RECOMMENDATIONS: The following studies have been reviewed and found to be in 

compliance wit the Sub Division F guidelines. The toxicology profile for 62719-UIE is as 

follows: 

acute oral toxicity IV acceptable MRID 457074-03 

acute dermal toxicity IV acceptable MRID 457074-04 

acute inhalation toxicity IV acceptable MRID 457074-05 

primary eye irritation IV acceptable MRID 457074-06 

primary skin irritation IV acceptable MRID 457074-07 

dermal sensitization neg. acceptable MRID 457074-08 

LABELING: 

PRODUCT ID #: 062719-00482 

PRODUCT NAME: STAM* 4 SC 

PRECAUTIONARY STATEMENTS 

SIGNAL WORD: CAUTION 

Hazards to Humans and Domestic Animals: 

Wear: long-sleeved shirt and long pants, Socks, Shoes, and gloves. 

First Aid: 

129
1. DP BARCODE: 

2. PC CODE: 

3. CURRENT DATE: 

D284( 

028201 

10-8-02 

( 

4. TEST MATERIAL: Stam' 4 SC (PropaniI4l.4%) 

Study/Species/Lab 

MRID Results 

Study # IDate 

Acute oral toxicity/rat 457074-03 LDso> 5000 mg/kg (males 

Rohm and Haas Tax Labl OOR- females combined) 

098 110-9-00 

Acute dermal toxicity/rat 457074-04 LDso> 5000 mg/kg (males 

Rohm and Haas Tax Lahl OOR- females combined) 

257 I 3-6-01 

Acute inhalation toxicity/ rat! 457074-05 LC" > 3.6 mgIL 

MP! research I 285-062/9-12-0l. 

Primary eye irritation/rabbit 457074-06 Conjunctivitis resolving 

I Rohm and Haasl 00R-2591 3-6- within 24 hours. Mild 

01 irritant 

Primary dermal irritation/rabbit 457074-07 Mild irritant 

I Rohm and Haasl 00R-2581 3-6-

01 

Dermal sensitization/guinea pig 457074-08 Not a sensitizer 

Rohm and Haas! 00R-2611 4-16-

01 

Tox. Core 

Cat. Grade 

IV A 

IV A 

IV A 

IV A 

IV A 

- A 

Core Grade Key: A ::;Acccptable, S "'" Supplementary, U = Unacceptable, V::; Self Validated 

10 

130
(- ( 

UNITeD STATES ENVIRONMENTAL PROTECTION AGENCY 

WASHINGTON, D.C. 20460 

January 5, 2011 

JAMES M. WAGNER 

WAGNER REGULATORY ASSOCIATES, INC. 

WlLLOWOOD USA, LLC 

PO Box 640 

HOCKESSIN, DE 19707-0640 

Report of Analysis for Compliance with PR Notice 86-5 

OFFICE OF 

PREVENTION, PESTICIDES AND 

TOXIC SUBSTANCES 

Thank you for your submittal of23-DEC-IO. Our staff has completed a preliminary 

analysis of the material. The results are provided as follows: 

Your submittal was found to be in full compliance with the standards for submission of 

data contained in PR Notice 86-5. A copy of your bibliography is enclosed, armotated with 

Master Record IDls (MRIDs) assigned to each document submitted. Please use these numbers in 

all future references to these documents. Thank you for your cooperation. If you have any 

questions concerning this data submission, please raise them with the cognizant Product 

Manager, to whom the data have been released. 

131
132
( 

December 22,2010 

Document Processing Desk (REGFEE) 

ATTN: Kathryn Montague, PM Team 23 

Registration Division 

U.S. Environmental Protection Agency 

Office of Pesticide Programs (7504P) 

Room 8-4900, One Potomac Yard 

2777 South Crystal Drive 

Arlington, Virginia 22202-4501 

Dear Ms. Montague, 

483383'()O 

Wagner Regulatory Associates, Inc. 

P.O. Box 640 

7460 Lancaster Pike, Suite 9 

Hockessin, Delaware t9707 

Subject: Application to regisle.· a new end-lise product containing a cunen tty registered Ilctive ingredient-

':WilIowood Propanil 4 se" 

Wagner Regulatory Associates, Inc., as agent for Willowood, LLC (87290), is requesting registration ofthe above 

referenced product. This product is substantially similar to the propanil product (Starn 4SC Herbicide) registered by 

United Phosphorus, Inc. under EPA Registration Number 70506~ 167. 

In support of this request, the folIowing documents and studies are attached: 

" Letter fl:om Willowood LLC appointing Waguer Regulatory Associates, Iltc. as its agent 

" Application for Pesticide Registration (8570~ 1) 

" Confidential Statement ofFOffilula (8570-4), 2 copies 

e Certification with Respect to Citation of Data (8570~34) 

" FOimulators Exemption (8570-27) 

" Data Matrix (S570~35) 

" Data Transmittal Document 

" Product Identity and Composition data (3 copies) as outlined in the trallsmittal document 

" Preliminary Analysis data (3 copies) as outlined in the transmittal document 

" Physical and Chemical Propelties data (3 copies) as outlined in the transmittal document 

" Draft labeling, 3 copies and CD 

" Certification with Respect to Label Integrity 

" A copy of the EPA approved label for EPA Reg. No. 70506~167 and 

" A copy of the receipt confinning payment of the required registration fees. 

Willowood, LLC has submitted payment to U.S.EP A in accordance ,vitIl PRIA II Fee Table - FYI VFYI2, for 

action category R300 ~ $1,434. 

If you have any questions about tIlis submission please contact the undersigned at CatIlelineriV.wagnerreg:cuili oj' 

(302) 234-2780. 

RespectfuIly submitted, 

Catherine M. Byrd 

Agent for Willowood, LLC " " ' 

Enclosures 

133
1. 

2. 

3. 

4. 

48338301 

48338302 

48336303 

( 

DATA TRANSMITTAL DOCUMENT 

Name and Address of Submitter 

Willowood, LLC 

clo Wagner Regulatory Associates 

PO 60x640 

Hockessin, DE 19707 

( 

Regulatory Action In Support Of Which This Package Is Submitted 

Application for Registration 

Willowood Propanil4 SC 

Transmittal Date 

December 22, 2010 

List of Submitted Studies 

Vol. I: Wagner Regulatory Associates, Inc. (2010) Willowood Propanil4 SC Product 

Identity and Composition, Description ofBeginnillg Materials, Manufacturing Process, 

and Discussioll ofFonnation oflmpurities. Willowood, LLC, Rosehurg, OR. NOllconfidential portion 6 pages, Confidential portion 59 pages. 

Vol. 2: Wagner Regulatory Associates, Inc. (2010) Wi]lowood Propanil4 SC 

Preliminary Analysis, Certified Limits and Enforcement Analytical Method. 

WIllowood, LLC, Roseburg, OR Non·confidential portion 6 pages, Confidential 

portion 17 pages. 

Vol. 3: Miller, Ronald (2010) PropaniI 4 SC Product CIlCmistry Volume m. 

Analytical & Regulatory Chemistry, Inc., Sumter, South Cm·olina. Report Number 

ARC-EX-872·006-P-I. 15 pages. 

-----------_._------

Company Official: 

Company Name: 

Company Contact: 

Catherine M. Byrd 

Name 

Wagner Regulatory Assoclates, Inc. 

Agent for Willowood, LLC 

Catherine M. Byrd 

Name 

Signature 

(302) 234-2780 

Phone 

134
, 

I 

PRIA 2 - 21 Day Content Screen Review Worksheet 

(EPAlOPP Use Only) 

3/23/09 

21 Day Screen Start Date: Ii!. - '2.:l - / 0 

Experts In-Processing Signature: rvl.r j./-,q'-UV;V,;I7N Date J'2 -3d -/0 Fee Paid: Yes / 

Division management contacted on issues No Yes Date 

EPA Reg. Number: 'is 7 2. "1 0 - R. I EPA Receipt Date: J2..-'l3- /0 

1 

2 

3 

4 

5 

Items for Review 

Application Form (EPA Form 8570-1)(link (0 form) signed & complete 

including package type 

Yes No N/A* 

Confidential Statement of Formula all boxes completed, fonn signed, and 1\ 

a) All inerts (link to http://www.epa.gov/opprdOOl/inerts/), 

including fragrances, approved for the proposed uses (see 

Footnote A) 

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

fom1) completed and signed (NIA if 100% repack) 

Certificate and data matrix consistent 

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

to pay statement included. (see Footnote B) 

If , is there a letter of Authorization for exclusive use 

yes no 

Fonn to . 

completed and signed (N/A if source is unregistered or applicant owns the 

Data Matrix (EPA Fonn 8570-35) (Link to form) both internal and external 

copies CPR 98-5) (Link to PR 98-5) completed and signed (N/A if 100% 

Selective Method 

b) Cite-All (Fee category experts use) 

c) Applicant owns all data (Fee category experts use) 

5 Copies of Label (link to http://www.epa,gov/oppfeadlnaheling!lrmJ) 

6 (Electronic labels on CD are encouraged and guidance is available)( link to X 

http://www.epa.gov/pesticides/regulating/registering/submissions/index.htm#labels 

I 

135
( ( 

7 Is the data p_;).ckage consistent with PR Notice 86-5 (link to PRN 86-5) I.-, 

Notice of Filing (link to 

8 htt(!:lIwww.e(!3.gov/)2esticides/regulatingltolerance I!etitions.htm) included X with petitions (link to 

http://www.epa.gov/pesticides/reguiating/toierances.htm) 

9 If applicable for conventional applications, reduced risk rationale (link to )( http://www.epa.gov/opprdOOl/workplan/reducedrisk.html) 

Required Data (link to 

httJ! ://www . eQ3.gov/Resticides/regulatin gldata reguirements.htm) and/or 

data waivers. See Footnote C. 

a) List study (or studies) not included with application 

10 

2 

136
( ( 

Comments: o-J-iJd:es posreJ /'(,-0' (ev;eev. 

V? S JbS 

"' NlA - Not Applicable 

Footnotes 

A. During the 21 day initial content review, all CSFs will be reviewed to determine 

whether all inerts listed, including fragrances, are approved for the proposed uses. If an 

unapproved inert is identified, the applicant must either 1) resolve the inert issue by, for 

example, removing the inert, substituting it with an approved inert, submitting 

documentation that EPA approved the inert for the proposed pesticidal uses, correcting 

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

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

CSF and may require submission of data. All infonnation. fOnTIs. data and 

documentation resolving the inert issue must have been received by 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 are 

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

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

3 

137
( i 

site [link to http://www.epa.gov/opprdOOllinerts/iists.htmllandifthe inert is not 

approved, to obtain the necessary inert approval prior to submitting an application 

to register a pesticide product containing that inert ingredient. Some inert 

ingredients are no longer approved for food uses or certain types of uses, The name 

andlor CAS number on a CSF must match the name and CAS number on this web site. 

Simple typographical errors in the name or CAS number have resulted in processing 

delays. 

If an inert is not listed on the inert ingredient web site and the applicant believes that the 

inert has been approved, the applicant should contact the Inert Ingredient Assessment 

Branch (lIAB) at inertsbranch@epa.gov and resolve the issue. Copies of the 

correspondence with IlAB resolving the issue should accompany the application. All 

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

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

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

Microbial Pesticides Branch [Link to 

h up:/ /www.epa.gov/oppbppdl/biopesticides!contactsbppd.htm ] . 

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 [link to http://www.epa.gov/opprdOOllinertsltips.pdfj must also be included 

to enable the Agency to determine if it has been approved. Each component of an inert 

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

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

Agency's receipt of an application, applicants must arrange with a proprietary mixture or 

fragrance supplier to provide the component information to the Agency or promptly upon 

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

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

Agency will reject the application. 

During the 21 day content review, applicants should submit 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. Correct the application by, for instance, correcting the inert's identity or CAS 

number, providing documentation that the inert has been approved, or 

removing the unapproved inert from the CSF or replacing it with one that is 

approved for the application's uses; or 

2. Submit the information and data needed for the Agency to approve the 

unapproved inert. If this option is selected and implemented, the Agency may 

request an extension in the PRIA decision review timeframe to accommodate 

the inert review/approval process; 

4 

138
( ( 

3. Withdraw the application (the Agency retains 25% of the full fee for the fee 

category estimated); or 

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

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

25% of the full fee of the category identified. 

Conventional New Product Applications 

When the Registration Division identifies an unapproved inert on a CSF with an 

application for a new product that the applicant has not identified as requiring an 

inert approval (R311, R3l2 or R3 13), it will contact the applicant with the 

following options: 

1. Correct the application by, for instance, correcting the inert's identity or CAS 

number, providing documentation that the inert has been approved, or 

removing the unapproved inert from the CSF or replacing it with one that is 

approved for the application's uses; or 

2. Submit the 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. (This option may change the PRIA 

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

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

Agency within the 21 day content review period.) 

3. Withdraw the application (the Agency retains 25% of the full fee for the fee 

category estimated); or 

If none of the above options is selected and implemented during the 21-day 

content-review period, the Agency will reject the application and retain 25% of 

the appropriate fee for the new product-inert approval category. 

PIP Applications 

When the Biopesticide and Pollution Prevention Division identifies an 

unapproved inert on a PIP CSF and a request to approve the inert does not 

accompany the application, it will contact the applicant with the following 

options: 

1. Correct the application by, for instance, correcting the spelling or name of the 

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

approved; or 

2. Submit the information and data needed for the Agency to approve the 

unapproved inert. If an inert ingredient tolerance exemption petition is 

required, the petition must be received by the Agency and the B903 fee paid 

within the 21 day period. If this option is selected and implemented, the 

Agency will discuss harmonizing the timeframe for both actions. 

5 

139
( ( 

3. Withdraw the application (the Agency retains 25% of the full fee for the fee 

category estimated); or 

If none of the above options is selected and implemented during the 21 day 

content review period, the Agency will reject the application and retain 25% of 

the fee. 

B. A policy on documentation of offers to pay is still being developed, however, for a 

me-too or fast track (similarlidentical) new product, R300 or A530, an application 

without the necessary authorizations of offers to pay will be placed into either R301 or 

AS31. The Agency recommends that authorizations of offers to pay be submitted with 

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

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

prior to submitting their application to the Agency. Documentation of such discussions 

should be submitted with the study waiver. 

6 

140
( 

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 

WASHINGTON, D.C. 20460 

December 30, 2010 

OPP Decision Number: D-443657 

EPA File Symbol or Registration Number: 87290-RI 

Product Name: WILLOWOOD PROPANIL 4 SC 

EPA Receipt Date: 23-Dec-2010 

EPA Company Number: 87290 

Company Name: WILLOWOOD USA, LLC 

Catherine Byrd 

WAGNER REGULATORY ASSOCIATES, INC. 

WILLOWOOD USA, LLC 

POBox 640 

HOCKESSIN, DE 19707-0640 

OFFICEQF 

PREVENTION, PESTICIDES AND 

TOXIC SUBSTANCES 

SUBJECT: Receipt of Registration Application Subject to Registration Service Fee 

Dear Registrant: 

The Office of Pesticide Programs has received your application and certification of 

payment. If you submitted data with this application, the results of the PRN~86-5 screen will be 

communicated separately. During the administrative screen, the Office of Pesticide Programs 

has determined that this Action is subject to a Pesticide Registration Service Fee as defined in 

the Pesticide Registration Improvement Act. 

The Action has been identified as Action Code: R300 

NEW PRODUCT;ME-TOO PRODUCT FAST TRACK; 

No additional payment is due at this time. 

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

Ombudsman at (703) 308-9362. 

Sincerely, . 

141
( ( 

IFee for Servicel {887956bThis package includes the following 

@ New Registration 

°Amendment 

for Division 

OAD 

oBPPD 

@RD 

[;i] Studies? o Fee Waiver? 

o volpay % Reduction: __ Risk Mgr. []I] 

----------------------------, 

Receipt No. s-I 887956 

EPA File Symbol/Reg. No. 1 87290-RI 

Pin-Punch Date: 1 12/23/2010 

1- This item is NOT subject to FFS action. 1. __ • __ ' 

--------- ---- -- -------------------------- ------------------

i-·····················ActronCode: Parent/Child Decisions: . 

. Requested: 1 e: '3LlD 1 

Granted: I iZ.. 301) I 

Amount Due: $ l)JY+ . U/) 

[ljJ Inert Clear d for Intended Use D Uncleared Inert in Product 

Reviewer:---.J~~LLQ~L---_ 

Remarks: 

Date: /2-17-"'1 1/ v 

j J 

142
f 

I' 

Print Letter 

Enter More Information 

143
P/ease read ins/ructions on reverse before comf l'~g ;fo~'m~. _________ -"Fo~'~mrA~oo~'''~\',' 'JMB No. 2070-0060. Approval expires 05-31-98 rK- r~egistration OPP Identifier Number 

.oEM United States 

Environmental Protection Agency 

Washington, DC 20460 

Amendment 

i-- Other 

Application for Pesticide - Section I 

1. CompanylProduct Number 

87290 - RI 

2. EPA Product Manager 

Kathryn Montague 

3. Proposed Classification 

4. CompanylProduct (Name) 

Willowood, LLCNllillowood Propanil4 SC 

PM# 

23 [R] None Restricted 

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

Willowood, LLC 

6. Expedited Review. In accordance with FIFRA Section 3(c)(3) 

(b)(I), my product is similar or identical in composition and labeling 

to: 

o 

o 

o 

cia Wagner Regulatory Associates. Inc. 

P.O. Box 640 

Hockessin, DE 19707 

D Check if tlJis Is a flew address 

EPA Reg. No. 70506-167 

Product Name: Stam 4SC Herbicide 

Section - II 

Amendment - Explain below. 

Resubmission in response to Agency letter dated ____ _ 

Notification - Explain below. 

o 

Il9 

o 

Final printed labels in response to 

Agency letter dated 

'Me Too" Application. 

Other - Explain below. 

Explanation: Use additional page(s) if necessary. (For Section I and Section 11.) 

Section - III 

1. Materiat This Product Will Be Packaged In: 

Child-Resistant Packaging U~ckaging W~ Soluble Packaging D Yes* Yes Yes 

[]] No X No T No 

~1f~"Y~e=,~ .. JL----.N~o~.=pe=,-tT.If~"Y~e=,~ .. l----N~o=.~p~e=,-i 

Unit Packaging wgt. container Package wgt container 

2. Type of Container 

Metal 

1-----1 Plastic 

Glass 

1-----1 Paper I< Certification must 

besubm;tied I x Other (Specify) HOPE lined bags 

3. Localion of Net Contents Information 

m Label D Container 

4. Size(s) Retail Container 

2.5 gallons, 30 gallons, bulk 

5. Location of Label Directions 

c:J On Label 

[]=:I On Labeling accompanying product 

6. Manner in Which Label is Affixed to Product 

~ Lithograph 

X Paper glued 

Stenciled 

Other ____ _ 

Section - IV .... .. .. " 

1. Contact Point Complete items directly betow for Identifica/ion of individual to be contac/ed, if necessalY, to process this app/lcatb'h~i . 

Name 

Catherine M. Bvrd I Title I Telephone No. (InclutH:~ArEm Code) 

Aoent for Willowood, LLC I (302i 234 2780 <, , , ~ '~~ 

Certification 6. Date AppJiearorr ,", 

I certify that the statements I have made on Ihis fOlm and all attachmenls thereto are true, accurate and complete. Received < < (' , ( ~ , 

I acknowledge Ihat any knowingly false or misleadIng statement may be punishable by fine or imprisonment or " , • , ' 

both untiel applicable law. (~ta.~rl"d) 

2. Signature 3. Title ' 

4. Typed Name 

Catherine M. Byrd 

Agent for Willowood, LLC 

5. Date 

12122/2010 

ThiS IS a reproduction of EPA Form 8570-1 (Rev. 8-94) PrevIous edilions are obsolete. 

"\, . .. , '" , 

144
Pay.go\' - Online Payment ( 

Onlino Paymont 

Step 3; Confirm Payrrl!!nt 

Thank you. 

Your tr;lnS3ctlon has been successfully completed. 

Pay.gov Tr.c~lng Inforn'aUon 

AppUcallon N'one: PRIf.. Ser"c<> Fe,," 

pay.gov Tr.cklng ID: 2~21..\2CEI 

AgencyTracklnglD: 7411..\16G~450 

Tran.aellon 0.10 andTlmo: 12.<2212010 1~.51 EST 

Poymonl Summory 

https:!/www_pay_go\'! P(' '~'w/pa }mell1s/authori ze P las tlcCardPa ylDent. html 

1 t 213 

Mdron Inlormallon Accounllnformallon Paymant Inlormallon 

1 ofl 

Accounl Holdcr Namo; Bn"" H<li",,~ 

BIlling Addreu: 1600 I-rNGard&nVolley BI·.'d 

Billing Addres52: SUI& 13() 

City: Ro~eb...-g 

St>.lel Province: OR 

ZlpIPo.IlIICode: 97<171 

Counlry: USA 

Card Type: MaslerCard 

Cord Number: ----"--6005 

Doclslon Numbor: 

Rl!glslr'lion Number: 

Company Name, 'tmowood LlC 

Company Number: 8i290 

AcUon Cod.: R30.:l 

Paym.nl Amounl: 51.434 00 

Tron.oclion Dale and Tim.: 1212212010 13;SI EST 

" 

" 

< < < , , , ' 

< " 

< 

" 

" < 

< " 

< £ , , 

12122/20101:54 P]\1 

145
( ( 

December 22, 2010 

DOClllnent Processing Desk (REG FEE) 

ATTN: Kathryn Montague, Pl ... 1 Team 23 

Registration Division 

Wagner Regulatory Associates, Inc. 

P.O. Box 640 

U.S. Environmental Protection Agency 

Office of Pesticide Programs (7504P) 

Room S-4900, Onc Potomac Yard 

2777 South Crystal Drive 

7460 Lancaster Pike, Suite 9 

Hockessin, Delaware 19707 

Arlington, Virginia 22202-4501 

Dear Ms. Montague. 

Subject: Application to registe[' a new cnd-lise product containing a currently registered active ingredient -

"Willowood Propanil4 SC" 

Wagner Regulatory Associates, Inc., as agent for Willowood. LLC (87290), is requesting registration of the above 

relerenced product. This product is substantially similar to the propanil product (Starn 4SC Herbicide) registered by 

United Phosphorus. Inc. under EPA Registration Number 70506-167. 

In SUppOit ofthis request, the following documents and srudies are attached: 

• Letter from Willowood LLC appointing Wagner Regulatory Associates, Inc. as its agent 

• Application for Pesticide Registration (8570-1) 

• Confidential Statement of Formula (8570-4), 2 copies 

• Certification with Respect to Citation of Data (8570-34) 

• Fonnulators Exemption (8570-27) 

• Data Matrix (8570-35) 

• Data Transmittal Docllment 

• Product Identity and Composition data (3 copies) as outlined in the transmittal document 

• Preliminary Analys is datu (3 copies) as outlined in the transmittal document 

• Physical and Chemical Propelties dala (3 copies) as outlined in the transmittal document 

• Draft labeling, 3 copies and CD 

• Certification with Respect to Label Integrity 

• A copy ofthc EPA approved label for EPA Reg. No. 70506-167 and 

• A copy of the receipt confirming payment ofthe required registration fees. 

Willowood, LLC has submitted payment to U.s.EPA in accordance with PRlA II Fee Table - FYI IIFYI2, for 

action category R300 - $1,434. 

< , 

If you have any questions about this submission please contact the undersigned at CatherinefiV\Vagnerreg~cbhi of 

(302) 234-2780. « < 

Respectfully submitted, 

Catherine M. Byrd 

Agent for WillolVood, LLC 

Enclosures 

,. ~ ~ 

< " 

" <, < , < " 

. . t < t ~ t t 

• 

t , t t 

" 

146
1. 

2. 

3. 

4. 

( 

DATA TRANSMITTAL DOCUMENT 

Name and Address of Submitter 

WilJowood, LLC 

clo Wagner Regulatory Associates 

PO Box 640 

Hockessin, DE 19707 

( 

Regulatory Action In Support Of Which This Package Is Submitted 

Application for Registration 

Willowood Propanil 4 SC 

Transmittal Date 

December 22,2010 

List of Submitted Studies 

Vol. I: Wagner Regulatory Associates, Inc. (1010) Willowood Propanil4 SC Product 

Identity and Composition, Description ofBeginnillg Materials, Manufacturing Process, 

and DisCllssion of Formation oflmpurities. Willowood, LLC, Roseburg, OR. Nonconfidential portion 6 pages, Confidential portion 59 pages. 

Vol. 2: Wagner Regulatory Associates, Inc. (2010) Willowood Propani14 SC 

Preliminary Alialysis, Certified Limits and Enforcement Analytical Method. 

Willowood, LLC, Roseburg, OR. Non-confidential pOltion 6 pages, Confidential 

portion 17 pages. 

Vol. 3: Miller, Ronald (2010) Propanil4 SC Product Chemistry Volume III. 

Analytical & Regulatory Chemisn'y, Inc., Sumter, South Carolina. Report Number 

ARC-EX-872-0D6-P-1. 15 pages. 

Company Official: 

Company Name: 

Company Contact: 

Catherine M. Byrd 

Name 

Wagner Regulatory Associates, Inc. 

Agent for Willowood, LLC 

Signature 

< < { { ~ < ~ { < 

" < < < < « 

_____ ~(3~02Q)~2~34±-~27~8illO~_7;~« H 

Catherine M. Byrd 

Name Phone < < < '{ {{ 

< ( { { < c ( 

< 

{{, { 

, { { I 

{ ~ <<< • < <. < 

147
W/L 

WIUOWOOD US~ Your preferred manufacturer of post patent products 

August 31, 2010 

To: Whom it-May Concern 

Re: Des'lgnation of Agent for: 

Willowood USA, LLC 

1600 NW Garden Vatley Btvd. 

Suite 130 

Roseburg, OR 97471 

Dear Sir or Madam: 

This letter serves as notification that Willowaod USA, LLC has appointed Wagner 

Regulatory Associates, Inc. (WRA, Inc.) to serve as the Agent on our company's behalf 

regarding all state and federal regulatory matters relative to products that Willowood 

USA, LLC will register with US EPA and the states. Please forward all correspondence 

for our company and its products to: 

Wagner Regulatory Associates, Inc. 

P.O. Box 640 

Hockessin, DE 19707·0640 

Thank you for your time and assistance. Please feel free to call me at if you have any 

questions. 

, , 

Respectfully submitted, ' < ~ < < , 

" 

~ 

, , , , , , " 

Brian Heinze " , , , " , PresidentlCEO , , , 

" " 

cc: WRAi Inc. 

, , " « • , 

(' « 

(', . 

< ~ c, . , , , 

~ c , , • , 

' « , • , , , < " 

1600 NW Garden Valley Blvd. Suite 130 • Roseburg, OR 97471 • 541 .679.9963' FAX 541.679.4650· www.willowoodUSA.com 

148
( 

Form ADoroved OMB Nos. 2070-0060; 2070-0057: 207(}-0107: 2070·0122: 2070-0164 

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 

1200 Pennsylvania Avenue, N.W. 

WASHINGTON, D.C. 20460 

Paperwork Reduction Act Notice: The public reponing burden for this collection of information is estimated to avcrngc 1.25 hours per respoltSll tor registrntion 

and 0.25 hours per response for reregistration and special revielV Hctivilies, inc1lX1ing time for reading the inSbUctions and rompleting the necessary forms. Send 

comments regarding burden estimate or any OIlIer aspect of this collection ofinfonnation, including suggestions tor reducing the burden to: Director, Collection 

Strategies Division (2822T), U.S. Environmental Protection Agency, 1200 Pennsylvania Avenue, N,W., Washington, DC 20460. Do not send the completed tbrm 

to this address. 

Certification with Respect to Citation of Data 

Applicant'sJReglstrant's Name, Address, and Telephone Number 

Willowood, LLC c/o Wagner Regulatory Associates, P.O. Box 640, Hockessin, DE 19707 

Actlve InQredlenl(s) andJor representative test compound(s) 

Propanil 

General Use Pattem(s) (list all those claimed for Ihls product usin!140 CFR Part 158) 

Terrestrial Food 

EPA Registration Number/File Symbol 

87290 

Date 

1212212010 

Product Name 

Willowood Propanll4 SC 

NOTE: lfyour 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. You must submit the Formulator's Exemption Statement (EPA Form 8570-27). 

D I am responding to a Data-Gall·ln Notice, and have included with this form a list of companies sent offers of compensation Ohe Data Matrix form should 

be used forlhis purpose). 

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

D I am using the dte-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). 

[2] I am using the selective method of support (or cne-all option under the selective method), and have included with this form a 

completed list of data requirements Ohe Data Matrix form must be 

used). 

SECTION II: GENERAL OFFER TO PAY 

(Required if using the cne-all method or when using the cite-all option under the selective method to satisfy one or more dala requirementsJ 

[2] I hereby offer and agree to pay compensation, to olher persons, with regard to the approval of this application, to the extent required by FIFRA 

SECTION 111: CERTIFICATION 

I certify that this application for regislration, this form for reregistration, or this Dala-Cal1-ln response is supported by all data submitted or cned in the 

appllcalion for registralion, the form for reregistration. or the Data-Call-In response. In addnion, if the dte-all option or cite-all oplion under Ihe selective melhod 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 submltled under the data 

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

uses. 

I certify that for each exdusive use sludy dted in support of this reglstralion or reregislration, that I am the original data submltler or that I,have obtained 

the written permission of the original data submitter to Clle that study. ,< < ( , C , 

I certify that for each sludy cited in support of this registration or reregistration that Is not an exclusive use study, either: (a) I am th£ (,~gIr1d.1 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 eligbilHy.fc.r' 

compensalion have expired for the study; (d) the sludy is in the public literalure; or (e) I have notified in writing the company that submitted the stut!y and have. < , " 

offered 0) to pay compensation t~ th~ extent required by sections 3(c)(1)(F) andJor 3(c)(2)(B) of AFRA; and (ii) to commence negotiations to p~el1lJ.ine the t 'J' 

amount and terms of compensaUon, If any, to be paid for the use ofthe sludy. « < «< ~L"" 

, I 

I certify thai In all instances where an offer of compensation Is required, copies of all offers to pay compensation and evldence ofthei, d~liv~ry in 'j 

accordance with sections 3(c)(1)(F) and/or 3(cJ(2){B) of FIFRA are available and will be submitted to the Agency upon request. Should I fail io.;l:"od:.lce such < , C I 

evidence to the Agency upon request, I understand that the Agency may inniale action to deny, cancel or suspend the registration of my product in,t;Onfonnlly \'ri'n , 

FIFRA. 

>te«( 

I certify thai the statements I have made on this form and all attachments to it are true, accurate, and complete. 

knowingly false or misleading statemem may be punishable by fine or Imprisonment or both under applicablo law. 

I acknowledgo that any 

Signature (} ~ J 

i!tll/ll/tt;Ju.. D-Jef-J 

Date 

1212212010 

EPA Form 8570-34 (12-2003) Electronic and Paper versions available. Submit only Paper version. 

Typed or Printed Name and Title 

Catherine M. Byrd, Agent 

'( « , , c , ( , 

149
( ( 

Form approved. OMB No. 2070-0060. 2070·0057. ~ .... 10-0107. 2070-0122. 2070-0164. 

eEPA 

United States 

Environmental Protection Agency 

Washington, DC 20460 

Formulator's Exemption Statement 

(40 CFR 152.85) 

Applicant's Name and Address EPA Fite Symbol/Registration Number 

87290- .. Willowood LLC Product Name 

clo Wagner Regulatory Associates, Inc. Willowood Propanil 4 SC 

P.O. Box 640 

Hockessin, DE 19707 

Date of Confidentiat Statement of Formula (EPA Form 8570-4) 

12/2212010 

As an authOrized representative of the applicant for regtstratlon of the product identified above. t certify that: 

(1) This product contains the fottowing aclive ingredient(s): 

Propanil 

(2) Of these, each active ingredient listed in paragraph (4) Is present solely as the resuH ofthe use of thai active ingredient in the manufacturing. 

formutalion or repackaging another product Which contains that active ingredient which is registered under FIFRA Section 3, is purchased by 

us from another person and meets the requirements of 40 CFR section 158.50(e)(2) or (3). 

(3) Indicate by checking (A) or (8) below which paragraph appUes: 

71 (A) An accurate Confidential Slatement of Formula (EPA FORM 857(}-4) for the above identified product ts attached to this statement. 

That formula statement indicates. by company name, registration number, and product name, the source of the ac!ive Ingredtent(s) listed in 

paragraph (1). 

OR 

, (8) The Confidential Statement of Formula (CSF)(EPA Form B570-4) referenced above and on file IoVith the EPA Is complete. current. an 

accurate and contains the information required on the current CSF. 

(4) The fottoloVing active Ingredients in this product qualify forthe formulalor's exemption. 

Source 

Aclive Ingredient Product Name Registrat~on NUPlber 

Propanil <~«t 

, • , 

" 

• ;" :1 

" , . . • , • 

• " < <, " 

• • '"I' • • , I 

" " " , : ' 1 

· , <" ' 

· • 

signa~~;h. Name and Title 0.10 ' , .. , . • 

UJJJrlflll2h NJrziJ Catherine Byrd, Agent 12/22/2010 '" < · , '" , EPA Form 8S70-27 (Rev. 06 2004) . Copy 1 EPA 

Copy 2 - Applicant copy 

150 *Product ingredient source information may be entitled to confidential treatment*
( ( 

R 300 and 301 

100% identical (repack): -;-YLfE",S,-"oLr -+"",,,-;-~c,,,ir,,c,-,Ie,,o,,,n,,,e,,,-

{If yes, it's a 100% repack - then p uct 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, 

Data 

Guideline Group A: Product Chemistry Data submitted 

No, study Title Yes No 

830.1550 Product Identity & Composition X 

Description of materials used to produce the 

830.1600 product X 

830.1650 Description of formulation process Y.. 

830.1670 Discussion on the formation of impurities X 

830.1700 Preliminary analysis X 

830.1750 Certified limits (158.345) X 

830.1800 Enforcement analytical method )( 

Data 

Guideline Group B: Product Chemistry Data submitted 

No, study Title Yes No 

830.6302 Color X 

830.6303 Physical State X 

830.6304 Odor X 

Oxidation/Reduction (Chemical 

830.6314 incompatibility) )( 

830.6315 Flammability )( 

830.6316 Explodability X 

830.6317 StoraQe stability X 

830,6319 Miscibility ';( 

830.6320 Corrosion Characteristics X 

830.6321 Dielectric Breakdown voltage X 

B30.7000 pH )( 

830.7100 Viscosity \ 

830.7300 Density 'y, 

1 

151
R 300 and 301 

New products must provide a bridging rationale document. The bridging document 

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

of submitting product specific data. 

Guideline Acute toxicity (6 pack) Cited 

No. Study Title Yes No 

870.1100 Acute Oral ILD50) X 

870.1200 Acute Dermal {LD50} X 

870.1300 Acute Inhalation ILC50} X 

870.2400 Acute Eye Irritation x: 

870.2500 Acute Dermal Irritation y., 

870.2600 Dermal Sensitization y., 

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

data to be used for the bridging rationale. ",_"- no " ",-I 

~ 

Guideline Cited 

No. Efficacy Study Titles Yes No Comments 

810.3100 Soil Treatments for Imported Fire Ants 

Livestock, Poultry, Fur and Wool-Bearing 

810.3200 Animal Treatments 

Treatments to Control Pests of Humans 

and 

810.3300 Pets 

Mosquito, Black Fly, and Biting Midge 

810.3400 (Sand Fly) Treatments 

810.3500 Premises Treatments 

810,3600 structural Treatments 

Methods for Efficacy Testing of Termite 

810.3800 Baits 

2 

152
(oft ... ·,. Fom) Approved OMB No. 2070~OO60 

~l ", __ to' UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 

401 M Street, S.W. 

WASHINGTON, D.C. 20460 

Papenvork Reduction Act Notice: The public repOltiug burden for this collection ofiufomlation is estimated to average 0.25 hours per response for registration activities and 0.25 

hours pel' response for reregistration and special review activities, includiug time for reading the instmction and completing the necessmy forms. Send comments regarding the 

burdeu estimate or any other aspect of this collection ofinfonnation, including suggestions for redllciug the burden to: Director, OPPE Infonnation Management Division (2137), 

U.S. Environmental Protection A1!encv, 401 M Street, S.W., Washhle:ton DC 20460. Do not send the fonn to this address. 

DATA MATRIX 

Date: 12/22/2010 

Applicant'sJRegistt'am's Name and Address: Willowood LLC 

clo Wagner Regnlatory Associates Inc. 

P.O. Box 640 

Hockessin, DE 19707 

Ingredient: Propanil 

Guideline Refel'ence Nnmber I Guidelinc Study Name 

PRODUCT SPECIFIC 

830.1550,830.1600.830.1650, 

830.1670, 

Product identity, composition/Description of 

materials Used to Produce the 

ProductiDescliption of Fom1Ulation 

Process/Discussion of Formation of Impurities 

830.1700 I Preliminary Aualvsis 

830.1750 ! CCltificatioll of Limits 

830.1800 I Enforcement Analytical Method 

830.6302 ! Color 

830.6303 ! Odor 

830.6304 I Physical State 

830.6313 ! Stability to Nonual & Elevated Temperatures 

830.6314 I Oxi{lationJReduction 

830.6315 I Flammabilitv 

830.6316 I Explodabilitv 

830.6317 I Accelerated Storage Stability 

830.6319 I Miscibilitv 

830.6320 I Corrosion Characteristics 

830.6321 I Dielectric Breakdown Voltage 

MRID Number 

EPA Reg No.1 File Symbol: 82790-

Product: 

Willowood Propanil 4 SC 

Submittel' 

Willowood LLC 

Willowood LLC 

Willowood LLC 

Willowood LLC 

Willowood LLC 

Willowood LLC 

Willowood LLC 

Willowood LLC 

Willowood LLC 

Willowood LLC 

Willowood LLC 

Willowood LLC 

Willowood LLC 

Willowood LLC 

Willowood LLC 

830.7000 ~ pH~~ ~~: ~:'" I WJllowood LLC 

830.7050 ::_:_:_._~ ~ UytVi$jblst'Ligh:\ Absorption ,,"" H mn - _. T T ,... ll1VWVVU LL'-' 

830.7100 :~ ~Vlscosit ~,," ;" Willowood LLC 

830.7200 Melting Point Willowood LLC 

0" 

Signature WiWWIW"'· '(1/l. tl)J" ~" ~ tk!J.i. :: 

Nallle and Title 

Catherine M. Byrd, 

Agent fur Willowood LLC 

EPA Form 8570-35 (9-97) Electronic and Paper versions available. Submit only Paper version. 

I Page 1 of3 

Staills Note 

Own 

Own 

Own 

Own 

Own 

Own 

Own 

Own 

Own 

Own 

Own 

Own 

Own 

Own 

Own 

Own 

Own 

Own 

Own 

I Date 

12/22/2010 

I 

Agency Internal Use Copy 

" 

153
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 

401 M Street. S.W. 

Paperwork Reduction Act Notice: The p\lblic 1"€:]lorting burden for this collection of information is estimated to average 0.25 hours per res]lonse for registration activities and 0.25 

hours per response for reregistration and special review activities, including time for reading the instruction and completing the necessary forms. Send comments regarding the 

burden estimate or allY other aspect oflhis collection ofinfonnation, including suggestions for reducing the burden to; Director, OPPE Infonnation Management Division (2137), 

U.S. Environmental Protection A enc " 401 M Street, S.W., Wasliiu"ton DC 20460. Do not send the fOlm to this address. n ~ 'l"' ~ ",,- ~ 'l"'nTV 

Name 

c/o Wagner Regnlatory Associates Inc. 

P.O. Box 640 

Ingredient: u .. 

Guideline Reference Number Gniticline Study Name MRID Number 

830.7220 Boilill" Poillt 

830.7300 Relative Densitv 

830.7370 Dissocation Constants in Water 

830.7520 Particle Size. Fiber Length, and Diameter 

Distribution 

830.7550 Octanol/Water Partition Coefficient 

830.7840 Solubility in Oroanic Solvents 

830.7840 Water Solubili ' 

830.7950 Vapor Pressure 

870.1100, 870.1200, 870.1300, Acute Oral Toxicity, Acute Demlal Toxicity, Cite All 

870.2400,870.2500,870.2600 Acute Inhalation Toxicity. Primal)' Eye 

In'jtation, Primary Skin In·itation, Skin 

Sensitization 

'C' , , , , ~~~ ~~" 

, C C " " " C C 

, , , , C , , " " , C , C C C , , ' , ' C " " " C 

, " "" "" " C C C 

Signfltnre 

~rc '1tdH ' C "d" /:. :. '. ~ " 1.,,"" 

EPA Form 8570-35 (9-97) Electronic and P<lper versions available. Submit only Paper version. 

Willowood Propanil4 SC 

Submitter Status Note 

Willowood LLC Own 

Willowood LLC Own 

Willowood LLC Own 

Willowood LLC Own 

Willowood LLC Own 

Willowood LLC Own 

Willowood LLC Own 

WilIowood LLC Own 

Agricultural Handlers Exposure Pay 

Task Force 

Macon, MO 

Agricultural Reentry Task Force 

Washington, DC 

Drexel Chemical Co. 

Memphis, TN 

E.I. DnPont De Nemours and Co. Inc. 

Wilmin!rton, DE 

FIFRA Endangered Species Task 

Force, LLC 

Washington, DC 

Name and Title Date 

Catherine M. Byrd, 12/2212010 

Agent for Willowood LLC 

Agency Internal Use Copy 

-

154
(~) Fonn Approved OMB No. 2070-0060 

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY .""",::1 401 M Street, S.W. 

WASHINGTON, D.C. 20460 

Paperwork Reduction Act Notice: The public reporting burden for this collection ofinfonnation is estimated to average 0.25 hours per response tbr registration activities and 0.25 

hours per response for reregistration and special review activities, including time for reading the instruction and completing the necessary fonns. Send comments regarding the 

burden estimate or any other aspect of this collection of info rmati 011, including suggestions for reducing the burden to: Director, DPPE Infonnation Management Division (2137), 

U.S. Environment'll Protection A!!encv, 401 M Street, S. W., Washincton DC 20460. Do not send the foml to this address. 

DATA MATRIX 

Date: 12/22/2010 EPA Reg No.! File Symbol: 81790- I Page 3 of3 

Applicant's/Registnmt's Name and Address: Willowood LLC Product: 

c/o Wagner Regul'ltol)' Associates Inc. 

P.O. Box 640 Willowood Propallil4 SC 

Hockessin, DE 19707 ~ 

Ingredient: Propanil 

Guideline Reference Numbcr Guidcline Study Name MRID Number Submitter Status Note 

Generic End,mgered Species Task Force 

Gia- Harbor. WA 

Monsanto Company 

Washington, D.C. 

Outdoor Residential Exposure Task 

Force, LLC 

Washington, DC 

Propanil Task Force 

Washin.gtOlI, D.C. 

RiceCo LLC 

Memohis, TN 

Spray Drift Task Force - Washington, DC 

Uuited Phosphorus, Inc. 

Kino ofPmssia, PA I 

Footnotes: I) Certification of Limits is provided in the Confideutial Statement ofFOflnula EPA fonn 8574-4 

~'O o~~ 

0 

0 0 0 

0 0 0 

0 0 0 

0 

~ 0 ~ ~~~ Name and Title Date ~r' ''',(; ~ rJJJ. ~rz[ 0 Catherine M. Byrd, 12/2212010 !. - . -~ 

Signahlre , .. ,1:::-]: .. : Agent for Willowood LLC 

EPA Form 8570-35 (9-97) Electronic and Paper versions available. Submit only Paper versIOn. Agcncy Iuternal Use Copy 

155
r.. '-1. Form Approved OMB No. 2070~0060 

(~) UNITED STATES ENVIRONMENTAL PROTECTION AGENCY ,~,-.. -" 

401 M Street, S.W. 

WASHINGTON, D.C. 20460 

Paperwork Rednction Act Notice: The public reporting burden for this collection of infonnation is estimated to average 0.25 honrs per response for registration activities and 0.25 

hours per response for reregistration and special review activities, including time for reading the instruction and completing the necessary fomls. Send comments regarding the 

burden estimate or aliy other aspect of this collection ofinfOlmation, inchlding suggestions for reducing the burden to: Director, OPPE Infonnation Management Division (2137), 

U.S. Environmental Protection Agenc\,. 401 M Street, S.W. Washh~gton DC 20460. Do not send the fOlm to this address. 

DATA MATRIX 

Date: 12/22/2010 

Applicant'siRegistrant's Name and Address: Willowood LLC 

c/o Wagner Regulatory Associates Inc. 

P.O. Box 640 

Hockessin, DE 19707 

1ngredient: Propanil 

Reference Number I Gnideline StUily Name MRlD Number 

... 0m~· iC· 1J0&f/ ~!::: ,( ~ .: ~ 

Signatnre ' - .. -

EPA Form 8570~35 (9~97) Electronic alld Paper versiolls available. Submit only Paper version. 

EPA RegNo.! File Symbol: 87290 

Product: 

Willowood Propanil4 SC 

Name and Title 

Catherine M. Byrd, 

Agent for Willowood LLC 

I Page I of3 

Date 

1212212010 

Agency Interllal Use Copy 

, 

156
-- ---

" ft. "'4. FOrol Approved OMB No. 2070·0060 

t~l UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 0."...,7 40 I 1\1 Street, S. W. 

WASHINGTON, D.C. 20460 

Pnperwork Reduction Act Notice: The public reporting burden for this collection of info rotation is estimated to average 0.25 hours per response for registration activities and 0.25 

hours per response for reregistration and special review activities, including time for reading the instmction and completing the necessm)' fonns. Send comments regarding the 

bnrden estimate or any other aspect ofthis collection ofinfonnation, including suggestions for reducing the burden to: Director, OPPE Infonnation Management Division (2137), 

U.S. Environmental Protection AgencY, 401 M Street, S.W., Washington DC 20460. Do not send the fonn to this address. 

DATA MATRIX 

Date: 12122/2010 EPA Reg No.1 File Symbol: 87290 I Page 2 of3 

Applicant'sfRegistrant's Name mid Address: Willowood LLC Prodnct: 

clo Wagner Regulatory Associates Inc. 

P.O. Box 640 Willowood Propanil 4 SC 

Hockessin, DE 19707 - Ingredient: Propanil 

Note 

-

Species 

~f'x- ~;r?j} "; Name and Title Date 

Catherine 1\1. Byrd, 12122/2010 . ['!j:f , • '-" 

> • Agent for Willowood LLC Sionature ./ . - . - . 

EPA Fonn 8570~35 (9-97) Electronic and Paper versions available. Submit only Paper version. Agency Internal Use Copy 

157
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 

401 M Street, S.W. 

Pnpenvorli Reduction Act Notice: The public repOiting bllfden for 

hours per response for reregistration andspeciaJ review activities, . 

is estimated to average 0.15 hours per response for registration 

time for reading the instlllction and completing the necessary fonns. Send comments regarding the 

burden estimate or any other aspect of this collection of infommtion, for reducing the bttrden to: Director, QPPE lnfotmation Management Division (2137), 

. address. 

Name 

Ingredient Propanil 

CF 

~ f'x- &jd~ cec 

clo Wagner Regulatory Associates Inc. 

P.O. Box 640 

~A" 

Willowood Propanil 4 SC 

Note 

Name 

Catherine M. Byrd, 12/2212010 

Agent for Willowood LLC 

158
There is an ELECTRONIC LABEL for this action 

You can use Acrobat to compare the e-Iabel to the previous version (and find the 

changes). You can also use Acrobat to mark-up the e-Iabel with your comments. 

If e-Iabel was submitted via 

CD-ROM with paper application 

then you will find e-Iabel in 

Electronic Label Library 

If Iho e-/ebel is not found In tim ELL tJlan it was probably not named 

correctly and could not be entered into the ELL. However, the file 

can be retn'oved from the CD whIch Is rolalnedby the Front End. 

or If e-Iabel was submitted via 

XML E-Submission (no paper) 

then you will find e-Iabel in 

Documentum 

See overview of processing e-Iabels on other side of this sheet. 

If you have any questions on e-Iabels, please contact one of your division e-Iabel experts: 

AD Willie Abney 308-1689 

Renae Whitaker 308-7003 

Tracy Lantz 308-6415 

BPPD 

RD Tom Harris 308-9423 

159
( 

Certification with Respect to Label Integrity 

version: 9/11/02 

I certify that the information (including, but not limited to, text, tables, and graphics) 

contained in the electronic file identified below by file name and submitted with this 

certification is the same information as that on the paper copies of these documents 

included with this submission. 

IPROPOSED LABEL 

Date Submitted 

EPA Registration # to EPA Electronic file name 

87290-XX 12/22/2010 87290.XXXXX.201 01222. Vl.pdf 

I certify that the statements that I have made on this form are true, accurate, and 

complete. I acknowledge that any knowingly false or misleading statements may be 

punishable by fine or imprisonment or both under applicable law. 

Signature 

Catherine M. Byrd 

Name (typed) 

12/22/2010 

Date 

« , " , , « 

(~o,,, 

, ,. < t < < • 

Agentfor Willowood. LLC 

Title 

.. . · . " , 

· " " " 

· , , , , . " , 

,,' , 

,,' , 

, , " . , , , " . 

160
1. 

2. 

3. 

4. 

( 

DATA TRANSMITTAL DOCUMENT 

Name and Address of Submitter 

Willowood, LLC 

c/o Wagner Regulatory Associates 

PO Box 640 

Hockessin, DE 19707 

Regulatory Action In Support Of Which This Package Is Submitted 

Application for Registration 

Willowood Propanil4 SC 

Transmittal Date 

December 22,2010 

list of Submitted Studies 

Vol. I: Wagner Regulatory Associates, Inc. (2010) Willowood Propanil4 SC Product 

Identity and Composition, Description of Beginning Materials, Manllfacturiug Process, 

and Discllssion of Formation of Impurities. Willowood, LLC, Roseburg, OR. Non~ 

confidential portion 6 pages, Confidential portion 59 pages. 

""-,--,-----"---- -----"-----

Vol. 2: Wagner Reglllatory Associates, Inc. (20 I 0) Willowood Propanii 4 SC 

Preliminary Analysis, Certified Limits and Enforcement Analytical Method. 

WiUowood, LLC, Roseburg, OR. Non~confidential portion 6 pages, Confidential 

portion 17 pages. 

Vol. 3: Miller, Ronald (2010) Propanil4 SC Product Chemistry Volume Ill. 

Analytical & Regulatory Chemistl)" Inc" Slllnter, South Carolina. Report Number 

ARC~EX~872~006~P~1. 15 pages. 

Company Official: 

Company Name: 

Company Contact: 

Calherine M. Byrd 

Name 

Wagner Regulatory Associates, Inc. 

Agent for Willowood, LLC 

Signature 

< < { , { C c < 

• 

" { ~'" . Catherine M. Byrd __ ---'("'30,,2"-) ... 23"'4,,-2"'7'-'8"'O __ ~<:-. < < • < 

Name Phone { < { 

< <. 

< < {' 'C { c, { , 

, { { { { , { 

, 

. {' { 

'{ {{ 

, {p {. 

161
Pages 162-167 - *Confidential Statements of Formula may be entitled to confidential treatment*