UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 

WASHINGTON D.C., 20460 

APR 13 2015 

OFFICE OF CHEMICAL SAFETY 

AND POLLUTION PREVENTION 

.MEMORANDUM 

SUBJECT: Response to Dow Agro Science (DAS) Comments on Oxyfluorfen (111601) 

BEAD Chemical Profile (BCP) 

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TO: Benjamin Askin, Chemical Review Manager 

Risk Management and Implementation Branch 1 

Pesticide Re-evaluation Division (7508P) 

Peer Review Panel Date: 8 April, 2015 
BEAD reviewed the comments submitted by Dow Agro Sciences, LLC (DAS) on EPA's 

oxyfluorfen registration review docket. Our responses to the registrant's comments are provided 

below. The comments were all related to the BEAD Chemical Profile (BCP) on oxyfluorfen. 

1. DAS comment on use sites: 

''The non-agricultural use sites are listed incorrectly. As per current product labels, this 

entry should be updated to read: Oxyfluorfen is also registered for non-crop use, 

including nonfood producing, non-cultivated agricultural or non-agricultural areas such 

as highway and utility rights-of-way, roadways, industrial sites, tank farms, storage areas, 

airports, fencerows, levee banks (only on side way from water channel), farmsteads, 

windbreaks and shelter breaks." 

BEAD's response: 

The non-agricultural site listing in BEAD's Chemical Profile is not intended to present 

every specific use site. Rather the documents presents an overview of the use sites found 

across all oxyfluorofen registrations. The Label Data Report for oxyfluorfen, found on 

the public docket, has a complete list of use sites. 

2. DAS comment on formulation types: 

"The listing of formulation types is incorrect. This entry should be corrected so that it 

reads: emulsifiable concentrate, suspension concentrate, and granular." 

BEAD's response: 

BEAD appreciates the clarification and acknowledges that oxyfluorfen is not formulated 

as a flowable concentrate. However, there are active non-DAS registrations formulated as 

ready to use (RTU) (239-2516 is an example). 

3. DAS comment on application methods: 

''The listing of application equipment is incorrect. This portion of the entry should be 

updated so that it reads: Band/broadcast application·equipment includes handheld 

sprayers, tractor mounted conventional ground sprayers, ground sprayers mounted on 

wheels pulled by tractors or A TV's, and by aerial. " 

Original language on BCP: 

It is applied as band treatment, broadcast, and by chemigation. Application equipment 

includes handheld sprayers and tractor mounted conventional ground sprayers. 

BEAD's response: 
BEAD appreciates the specifics offered in the registrant's response. However, the 

purpose of this listing is to broadly characterize the application equipment across all 

registrations for this chemical. The Label Data Report for oxyfluorfen, found on the 

public docket, has a complete list of application methods for oxyfluorfen. 

4. DAS comment on role of oxyfluorfen in pest management: 

"The Agency states on page 8 of 11 : 

Oxyfluorfen (Goal2XL) formulation is used at the two- to four-leaf stage of the crop, but 

the Goal Tender formulation can be used at the lst true leaf stage. (University of 

California IPM Guidelines, 2014 (2))." 

"DAS disagrees with this statement. As per the current product labels, for direct seeded 

onion, both Goal Tender and Goal 2XL can be applied when the onion is at greater than 

two-leaf stage to control two- to four-leaf weeds. For dry bulb onion, Goal Tender only 

(not Goal2XL) can be applied when the onion is at 1 leaf or greater growth stage." 

BEAD's response: 

BEAD appreciates the clarification from DAS and will consider this information as the 

registration review continues. 

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