# EPA Registration Jacket 87290
‐1

### ) 

## PYXIS REGULATORY CONSULTING, I'NC. 4110 

### 136'h St. NW 

### Gig Harbor, WA 98332

COURIER DELIVERY Kathryn Montague (PM 23) DocumentProcessing Desk (FNL LBL) OfficeofPesticidePrograms (7504P) U.S. Environmental Protection Agency Room S-4900, OnePotomacYard 2777 S. Crystal Drive Arlington, VA 22202 October 28, 2010 Phone: 253-853-7369 Fax: 253-853-5516 www.PyxisRC.com

RE: Willowood, LLC

- Willowood Ethofumesate SC (EPA Reg. No. 87290-1) Submission ofFinal ProductLabeling pertheAgency Letter dated April 22, 20I0
Dear Ms. Montague,
On behalf ofWillowood, LLC and in response to the Agency letter dated April 22, 2010 please find enclosed the final product labeling for Willowood Ethofumesate SC(EPA Reg. No. 87290-1). In support ofthis submission, we submitthefollowing documents: I. 

### CompletedApplication for Registration (EPA Form 8570-1) 2. One (I) 

### copy oftheWillowood Ethofumesate SC final product labeling 3. Letter ofAuthorization

Please feel free to contact me by phone (253) 853-7369 or by email atRoss@PyxisRC.comifyou have any questions orneed any additional infonnation.

Sincerely,

Ross Gilbert

Enclosures

cc: B. Heinze; Willowood, LLC 

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6.r•• d imtrur.#oM onrevtllY. IHlfo,.com"'.a"" form Form ADDroved. ,>1B No. 2070.ooSC**,~i._**

# '-'8-95

United States 

# §Registration OPP Identifier Number 

# &EPA Environmental Protection Agency Amendment Washington, DC 20460 

### I 

### Other Application for Pesticide

- Section I 1. Company/Product Number 2. EPA Product Maneger 3. Proposed Classification 87290-1 K. Montague 

# o None 

# D Restricted 4. Compeny/Product (Neme) PM# Willowood, LLC IWillowood Ethofumesate SC 23 5. Name and Address of Applicant (Includo ZIP Codo/ 6. Expedited Reveiw. In accordance with FIFRA Section 3(c)(31

Willowood, LLC (b)(il, my product is similar or identical in composition and labeling clo Pyxis Regulatory Consulting, Inc. to: 4110 136th SI. NW EPA Reg. No. Gig Harbor, WA 98332 

# DChock ifthis Is a now address Product Name 

### Section

- II 

# D Amendment

- Explein balow.

# ~ Final printed labels in repsonse to 

### 4/22/2010 Agency lettar deted 

# D Resubmission in rasponse to Agency lettar detad 

# D "Me Too" Application. 

# D Notification

- Explain below. 

# D Other

- Explain below.
Explanation: Use edditionel pegels) if necessary. IFor section I and Section ILl Submission offinal printed labeling perthe Agency letterdated April 22, 2010.



### Section

- III 1. Material Thi. Product Will Be Packaged In: Child-Resistant Packaging Unit Packaging Water Soluble Packaging 2. Type of Container 

# tzj Yes 

# tzres

# ~ Yes

# ~~"

I No 

### I No 

### .t ptastic No Glass


### • Certification must If "Yas" No. per If "Yes" No. per Paper Unit Packaging wgt. containsl Package wgt containar Other (Specify) 

### be submitted I 3. Location of Nat Contents Info/mation 4. Siza(s) Rateil Container 

# 15. Locetion of Leb.1 Directions j -. On Label 

### [{J Lebel 

# U Container 2.5,5 gallon 

# t=3 On Labeling accompanying product 6. Mennel in Which Lebel is Affixed to Product 

# l:J Uthogroph 

# 0 Other J Paper Pelued StenciOd

### Section

- IV 1. Contact Point (Compl9t9 it9m$ dir9Ctly b910w forid9ntlfic8tion ofindividu91 to bo contllct9d. ifn9Ce$SlIry, to proc9$$ this application.) Name Titla Telephone No. (Include Area Code)

Ross Gilbert Agent (253) 853,1'10<3£:' Certification 6.**~Date** Application I certifythat the statements Ihave made on this form and all attachments thereto are true. accurate end complete.**~R)e~~~8d** Iacknowledge that any knowlinglly false or misleading statement may be punishable by fine or**imprisorvne7l~**or; -' , both under applicable law. :**'~** (Stamped)

2. Signature

# ~~ 3. Titl. ,J , ,J

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### , Agent ' ,;))-,

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## ..**~** 4. Typed Name 

# r 5. Date 

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# I 'J.1. , -:>-.!)I 0 • ' J ; • Ross Gilbert ,,) ; 

### , 

## ,

. . . EPA Form 8570·1 IRev. 3·941 PreVIous editions ere obsolete

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## '. White

- EPA File Copy (on(linaJ) y.now - AppHcent C<>py}} ;



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# IDWillowood 

# ETHOFUMESATESC
SuspensionConcentrate
BROAD SPECTRUM HERBICIDE forselective control ofweeds in sugar beets, garden beets, onions, garlic, shallots (in all states) and carrots inWashington and Oregon only. GRASS SEED HERBICIDEforselective control ofweeds in certain grass seed crops and commercial sod production in California, Idaho, Nevada, Oregon and Washington. 

### ACTIVE INGREDIENT: 

### % 

### by Weight Ethofumesate (2-ethoxy-2, 3-dihydro-3, 3-dimethyl5-benzofuranyl methanesulfonate)

............................................ 42.0% OTHER INGREDIENTS:

............................................................ 58.0% TOTAL:

....................................................................................100.0% This product contains 4.0 Ibs. active ingredient per galion. 

## KEEP OUT OF REACH OF CHILDREN 

# CAUTION

See inside label bookletfor FirstAid and additional Precautionary Statements. 

### EPA Reg. No. 87290-1 Manufactured For: Willowood, LLC 1600 NWGarden Valley Blvd. #130 Roseburg, OR 97471 

### EPA Est. No. 37429-GA-001(BT) 37429-GA-002(BO) Letter(s) in lot number correspond to letter(s) following the EPA Est. No. 

## NET CONTENTS: 2.5 Gallons

### FIRST AID Ifswallowed: • Call a poison control centeror doctor immediatelyfortreatment advice. 

### • Have person sip a glass of water if ableto swallow. 

### • Do not induce vomiting unless told to do so by the poison control centerordoctor.
• Do not Qive anvthinq by mouth to an unconscious person, Ifinhaled: 

### • Move person to fresh air. 

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

preferably by**mouth~to-mouth,** ifpossible. 

### • Call a poison control center ordoctorforfurthertreatment advice. Ifin eyes: 

### • Hold eye open and rinse slowly and gentlywith waterfor 15-20 minutes. 

### • Remove contact lenses, if present, afterthe first 5 minutes, then continue rinsing eye. • Call a poison control centerordoctorfortreatment advice. Ifon skin or 

### • Take off contaminated clothing. clothing: 

### • Rinse skin immediatelywith plenty ofwaterfor 15-20 minutes. 

# · Call a poison control centerordoctorfortreatment advice. HOT LINE NUMBER
Have the product containerorlabel with you when calling a poison control centerordoctor, orgoing fortreatment. Foremergency information concerning this product, call the National Pesticides Information Center (NPIC) at 1-800-858-7378 seven days a week, 6:30 am to 4:30 pm Pacific Time oryour poison control centerat 1-800- 222-1222.

2

### PRECAUTIONARY STATEMENTS HAZARDS TO HUMANSAND DOMESTICANIMALS CAUTION. Harmful if swaJlowed or inhaled. Avoid breathing vapororspray mist PERSONAL PROTECTIVE EQUIPMENT (PPE): Some materialsthat are chemical-resistantto this product are polyethylene or polyvinyl chloride. Ifyou want more options, followthe instructions for categoryA on an EPA chemical-resistance category selection chart. All mixers, loaders. applicators and other handlers mustwear: • Long-sleeved shirt and long pants • Protective Chemical-resistantgloves (except flaggers, or applicator in cockpits, and enclosed cabs)
• Shoes plus socks See Engineering Controls for additional requirements. On·Site Closed Mixing and loading System Engineering Controlsfor Liquid Formulationsfor Commercial Dry Bulk Fertilizer Impregnation Mixers and loaders must use a closed system designed bythe manufacturerto provide dermal and inhalation protection to enclose the pesticide to prevent it from contacting handlers orother peopleAND the system is functioning properly and is used and maintained in accordance with the manufacturer's written operating instructions, The handlers:
• Must wear PPE listed on this label • Must wear protective eyewear ifthesystem operates underpressure • Must have immediatelyavailable for use in an emergency, such as a spill, or equipment breakdown, chemical resistant footwear and

chemical resistant apron Follow manufacturer's instructionsfor cleaning/maintaining PPE. If no such instructions forwashables exist, use detergent and hot water. Keep and wash PPE separatelyfrom other laundry. ENGINEERING CONTROLS STATEMENT When handlers use closedsystems, enclosed cabs, or aircraft in a mannerthat meetsthe requirements listed in theWorker Protection Standard (lNPS) for agricultural pesticides [40 CFR 170.240 (d) [4-6)), the handler PPE requirements may be reduced or modified asspecified in theWPS. Pilots must use an enclosed cockpit that meets the requirements listedin theWorker Protection Standard (lNPS) for agricultural pesticides [40 CFR 170.240(d)(6)]. USER SAFETY REQUIREMENTS

Users should:

• Wash hands before eating. drinking, Chewing gum, using tobacco, or using the toilet. • Remove clothingJPPE immediately if pesticide gets inside. Then wash thoroughlyand put on clean clothing. • Remove PPE immediately after handling this product. Wash the outside ofgloves before removing. As soon as possible,

wash thoroughly and change into clean clothing.

ENVIRONMENTAL HAZARDS This pesticide is toxic to fish. Do notapplydirectlyto water, orto areas where surfacewater is present, orto intertidal areas below the mean high water mark. Drift and runoff may be hazardous to aquatic organisms in wateradiacent to treated areas, Do not contaminate water when disposing ofequipmentwashwatersorrinsate.

3USE PRECAUTIONS Willowood EthofumesateSC ortank mixes must be usedfor label listed purposes and at label specified rates only. (DO NOT OVERTREAT). Do not graze livestock on treated crops. Do not apply this product through any type of irrigation system. If crop is lost dueto climatic orsoil conditions following application of Willowood Ethofumesate se ortank mixes, do not plant crops other than sugar beets or ryegrass in treated land during the same season. Do not retreat field with Willowood Ethofumesate se. Iffields are replanted to sugar beets, reseed into treated band. Do not rotatewith any crops otherthan sugar beets orryegrass for: • t2 months following preplant 'Incorporated, preemergence, conventional postemergence applications, orsplit (low rate) applications

totaling more than 12 fl. oz. (0.375 lb. aVacre); .6 monthsfollowing split (low rate) postemergence applications totaling t2 fl. oz. (0.375 lb. ai/acre) or less. Thorough tillage, including moldboard plowing, should precede the planting of crops otherthan sugar beets orryegrass. Do not useWillowood Ethofumesate seon muck orpeatsoils. Do not allow spray mixture to stand in tank overnight. Flush and drain spray equipment after each day's use. Store unused spray mixture in tightly-sealed containers and protectfrom frost. This label must be in the possession ofthe user at the time ofpesticide application. 

### DIRECTIONS FOR USE It is aviolation of Federal law to use this product in a manner Inconsistentwith its labeling. Read entire Directions for Use and Condition ofSale and Limitation ofWarranty and Liability before using this product. Do not apply this product in a waythatwill contactworkers or other persons, either directlyor through drift. Only protected handlers may be in the area during application. For any requirements specific to your State orTribe. consult the agency responsible for pesticide regulation. SHAKE CONTAINER WELL BEFORE USING,

AGRICULTURAL USE REQUIREMENTS Usethis product only in accordancewith its labeling and with the Worker Protection Standard, 40 CFR Part t70. This Standard contains requirements forthe protection ofagricultural workers on farms, forests, nurseries, and greenhouses, and handlers of agricultural pesticides. Itcontains requirements for training, decontamination, notification, and emergency assistance. Italso contains specitic instructions and exceptions pertaining to the statements on this label about personal protective equipment (PPE), and restricted-entry interval. The requirements in this box only applyto 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 t2 hoursfor all crops, except tun grown forsod. The REI for tun is 9 days. The REI for each crop is listed in the directions for use associated with each crop. Exception: If the product is soil-injected orsoil-incorporated, the Worker Protection Standard, under certain circumstances, allows workerstoenterthe treated area 'Ifthere will be no contactwith anything that has been treated. PPE required for early entry to treated areas that is permitted underthe Worker Protection Standardand that involves contactwith anythingthat has been treated, such as plants, soil, orwater, is:
• Coveralls • Chemical-resistant gloves made of anywaterproof material
• Shoes plussocks Notifyworkers of the application by warning them orally and by posting warning signs at entrancesto treated areas.

4SPRAY DRIFT MANAGEMENT This chemical can contaminate surface water through spraydrift. Avariety offactors including weather conditions (e.g. wind direction, wind speed, temperature, relative humidity) and method of application (e.g. ground, aerial) can influence pesticide drift. The applicator must evaluate all factors and make appropriate adjustmentswhen applying this product. Wind Speed**~** 00 not applywhen wind speeds are greater than 15 mph. Temperature Inversions**~** Do not make applications into areas of temperature inversion or stable atmospheric conditions. 

## SUGAR BEETS PRODUCT INFORMATION Willowood Ethofumesate SC is a selective herbicide for use in sugar beetsfor the control oftheweed speCies listed below. It provides effective control ofthese weeds for upto 10 weeksfollowing application. Residual control ofweeds is dependent upon soil moisture conditions; rate of herbicide used, and soil texture. The activityofWi!!owood Ethofumesate SC in the soil is reduced as the soil texture becomes finer and organic matter increases. Aerial Application Rate Restriction: Do not apply morethan 1.5 Ibs. a.i. (3 pints of product) per acre with aircraft. PRECAUTIONS/RESTRICT/ONS Following a preemergence treatment ofWillowood Ethofumesate SC, do not applyconventional rates ofWillowood Ethofumesate SC postemergence where more than 6 pints were applied preplant or preemergence. Do not apply more than 3.75 Ibs. a.i. (7 pints ofproduct) peracre per season for sugar beets. See Use Precautions for additional information on proper use, WEED SPECIES CONTROLLED Annual Broadleaf Weeds Black nightshade (Solanum nigrum) Common chickweed (SJeffaria media) Common lambsquarters (Chenopodium album) Common purslane (Portulaca o/eracea) Kochia (Kochia scoparia) Ladysthumb (Polygonum persicaria) Pennsylvania smartweed (polygonum pennsylvanicum) Redroot pigweed (Amaranfhus retroflexus) Russian thistle (Salsola kalivar. tenuifolia) Wild buckwheat (Po/ygonum convolvulus) Annual Grass Weeds Annual bluegrass (Poa annua) Barnyardgrass' (Echinochloa crus-gal/i) Canarygrass (Phalaris canariensis) Green foxtail (Setaria viridis) Large crabgrass (Digitaria sanguinalis) Volunteer barley (Hordeum sp.) Volunteer wheat (Trificum sp.) Wild oats" (Avena fafua) Yellow foxtail (Setaria glauca)

• Control of barnyardgrass may be reducedwith theWillowood Ethofumesate SC + Pyramin®tank mix because ofthe lower rate ofWillowood Ethofumesate SC recommended

. •• Control ofwild oats has been inconsistent in Minnesota and North Dakota.

WiUowood Ethofumesate SC alone wi!! also reduce competition from these HARD-TO-CONTROLweeds: Annual Sowthistle (Sonchus o/eraceus) Puncturevine (Tl1bu/us ferrestris) Shepherdspurse (Gapseffa bursa-pastoris) Purple nutsedge (Cyperus rotundus) Yellow nutsedge (Cyperus esculentus) Apply tank mixes only in specific regions orStates and in accordancewith directions on label.

5PREPLANT INCORPORATEDAND PREEMERGENCEAPPLICATIONS SOIL PREPARATION: The soil should be prepared according to good agricultural practices. Large clodscan reducethe effectiveness ofWillowood Ethofumesate SC and tank mixes. All existing vegetative growth should bethoroughlyworked into the soil before treatment. SPRAY EQUIPMENT: Apply Willowood Ethofumesate SC alone orin tank mixes to the soil using standard low pressure (20 to 50 psij spray equipment. Spray equipment should be carefully calibrated before use and checked frequently during applicationto see that it isfunctioning properly. Do not use smaller than 50-mesh strainer. Uniformlyapply the label-listed rates of Willowood Ethofumesate SC ortank mixes in 10 to 60 gallons ofwater peracre on a broadcast basis. Avoid overlaps since crop injury may result. When applying Willowood Ethofumesate SC or tank mixes in a band; checkto make certain that the band width is accurateforthe dosage rate being applied. The spraytank and lines should be thoroughly cleaned and rinsed priorto using Willowood Ethotumesate SC. INCORPORATION EQUIPMENT: Where soil incorporation is recommended, use a hooded power- orground-driven rotary tiller, rOiling cultivator, or similar equipment properly adjusted to uniformly incorporateWillowood EthofumesateSC or tank mixes to a depth of 1 to 2 inches. Deeper incorporation may reduce effectiveness. Do not applyWillowood Ethofumesate SC ortank mixesthrough soil injectorshanks. Incorporation should be accomplished priorto planting. If done after planting, proper precautions should be taken to avoid damaging or moving the crop seed. See belowfor Layering Application. LAYERING APPLICATION: Spring:Form beds with appropriate bedding equipment. Pre-irrigate field 'If necessary. Remove bed top with suitable de-ridging machinery to provide a minimum width of to" across the top of the bed. ApplyWillowood Ethofumesate SC in a band at the specified rate indicated in the appropriate regional dosage table and cover the treated band with 1 inch ofsoil using ditchers ordiscs equipment. Shapethe bed with roller shaper and irrigate untIl the tops ofthe beds are thoroughly wetted. Irrigatefrom furrows on both sides of the row. Fall: This method of application can be used when spring moisture is marginal orwhere irrigationwater is not available atplanting time. Fall bedding utilizes thewinter-accumulated moisture to enhance activation ofthe herbicideand to aid in germination ofthe sugar beet crop. Prepare the field (as for planting; plow; pack. and float, etc.), in the fall, usually late Septemberor October.ApplyWillowood Ethofumesate SC in a band to the soil surface at the specified rate indicated in the appropriate regional dosage table. Be sure that the soil surface to be treated isfree of trash and vegetation. Cover the treated bands with soil and form beds or ridges using ditchersor discs. In the spring when the soil is sufficientlydryto be worked. de-ridge the bedsdown to within 1/2" to 1" ofthe treated layer using suitable equipment such as the Kirchner bedderor Oregon Northslope harrow. When de-ridging, maintain the original bedding guidancesystem by using a bull tongue chisel, slide guides or similar equipment. This will ensure thatthe planterwill follow in the treated band. Plant sugar beets in the de-ridged area when the soil conditions allow. APPLICATION INSTRUCTIONS Sugarbeets grown underrainfall: ApplyWillowood Ethofumesate SC alone or in a tank mix preemergence at time ofplanting or shortly after, but prior toweed germination, Willowood EthOfumesate SC ortank mix does not require mechanical soil incorporation provided that sufficient rainlall occursshortly following application to activate the chemical, One-half inch of rainfall is usually adequateforactivation. In areas where rainfall can bemarginal for activation, such as the Red RiverValley (Minnesota and North Dakota), it is recommended that Willowood Ethofumesate SC orthe tank mix be applied before orat the timeof planting and incorporated into the soil. Sugarbeets grown underfurrow irrigation:ApplyWillowood Ethofumesate SC alone orin a tank mix to the soil surface preplant orat time ofplanting, butpriorto weed gennination, and incorporate into the soil. Where sugar beets are grown in beds, applyWillowood Ethofumesate SC or tank mix after bedding and incorporate. Since Willowood Ethofumesate SC ortank mix must have moisture to control weeds effectively, irrigate until tops of beds are thoroughlywetted. Sugarbeets grown undersprinkler irrigation:ApplyWillowood Ethofumesate SC alone or in atank mix preemergence at time of planting or shortly after, and irrigate priorto crop and weed germination, Repeat irrigation as necessary to maintain good moisture in uppersoil layer, Apply at least one-half inch of water during first irrigation. Do not mechanically incorporate Willowood Ethofumesate SC ortank mix intothe soil undersprinkler irrigation. Cultural Practices FollowingApplication: When properly applied, Willowood Ethofumesate SC alone orin atank mixwill provide up to ten weeks control ofsusceptible weed species, When cultivating fields in which Willowood Ethofumesate 8C or tank mixes have been banded, care should be exercisedto minimize the movement of untreated soil into thetreated band. Where a broadcast application has been made, do not cultivate deeperthan two inches, as this reduces the effectiveness ofWillowood Ethofumesate SC ortank mixes.

6WILLOWOOD ETHOFUMESATE SC ALONE DOSAGE TABLE 1 (All Regions Except North Dakota and Minnesota);
Rate ofWillowood Ethofumesute SC perAcre' Soil Texture**7~inch** Band Width Z Broadcast 22" Row 28" Row 30" Row
Coarse Textured Soils; Sands, 2 1/4 to 3 3/4 Pints 3/4 to 1 1/4 Pints 2/3 to 1 Pint 1/2 to 1 Pint loamy sands and sandy loams
Medium Textured Soils: Siltloams, clay loams which contain less than 33/4to 6 Pints 1 1/4 to 2 Pints 1to 1 1/2 Pints 1to 1 3/4 Pints 3% organic matter

Fine Textured Soils: Siltloams, clay loams, clayswhich contain more than 6to 7 1/2 Pints 2to 2 1/2 Pints 1 1/2 to 2 Pints 1 1/2to t 3/4 Pints 3% organic matter

, Use the higher rate within each soil texture category on the finer texture soils andlorwhere Kochia, barnyardgrass or black nightshade are expected to be a problem,

2 For other band or row widths, adiustthe rate in proportion to the area actuallytreated,
DOSAGETABLE 2 (North Dakota and Minnesota only): Willowood Ethofumesate SC perAcre Soil Texture 7-inch Band Width' Broadcast 22" Row Coarse Textured Soils; Sandy toams only 6 Pints 2 Pints
MediumTextured Soils: Silt loams and clay loams 6 Pints 2 Pints
Fine Textured Soils: Heavy clays 7 1/2 Pints 21/2 Pints

, Forother band or row Widths, adjust the rate In proportion to the area actuallytreated.

7WlllOWOOD ETHOFUMESATE SC + PYRAMIN® (TANK MIX) This tank mixwill control these additional broadleafweeds: Annual sowthistle (Sonchus oleraceus) Black mustard (8rassica nigra) Buffalobur (Solanum rostratum) Coastfiddleneck (Amsinckia intermedia) Common groundsel (Senecio vulgaris) Common ragweed (Ambrosia artemisiifo/la) Cutleaf nightshade (Solanum triflorum) Groundcherry (Physalis spp.) Henbit (Lamium amp/exicau/e) Nettleleaf goosefoot (Chenopodium mura/e) Prickly lettuce (Lactuca serriola) Prostrate knotweed (polygonum avicu/are) Shepardspurse (Capsella bursa-pastoris) Mixing Directions: When mixing Wi!!owood Ethofumesate SC in the spraytankwith PyramJn, fill the spraytankwith 1/2 ofthetotal amount ofwater to be used and add Wi!!owood Ethofumesate SC first. Agttate spray solutionthoroughly and continuously. See Pyramin label for additional mixing directions. CALIFORNIA (winter-grown sugarbeets only): Undersprinkler irrigation orwhere natural rainfall is adequate, apply this tank mixpreemergence. See pyramin label for precautions regarding application ofsprinkler irrigation. Where furrow irrigation is to be used, apply preplant incorporated. Prepare seedbed orform bedsfor planting. Then use rotary tiller type ofincorporation and'Incorporate notmore than 2 inches deep. Plant sugar beets and irrigate. Sub-irrigate until tops of beds are thoroughlywetted. Refer to Dosage Table 3 for specified rates.

DOSAGETABLE 3 (California, winter-grown sugar beets only):
Willowood Ethofumesate SC perAcre PYRAMIN DF perAcre SoilTexture Broadcast 10-inch Band Width1,2 Broadcast 10-inch Band Width (Forcalibration 30" Row (Forcalibration 30" Row purposes only) purposes only)

Coarse Textured Soils: Sands. NOT RECOMMENDED loamy sands and sandy loams
MediumTextured Soils: Silt loams, clay loams which contain less than 3 to 3 1/4 Pints 1 to 1 1/4 Pints 4 1/2 Pounds t 112 Pounds 3% organic matter

Fine Textured Soils: Clay loams which contain morethan 3% organic 4 to 5 1/4 Pints f 1/3 to t 3/4 Pints 4 t/2 Pounds t 1/2 Pounds matterand clays



### , For other brand or rowWidths, adlust rates In proportion to the area actually treated. Do not applythiS mixture broadcast.

2 Use the higher rate ofWillowood Ethofumesate SCwithin each soil tex1ure category on the finer-textured soils and/or where volunteer barley orwheat are expectedto be a problem.

8Precautions: Do not exceed 3/4 inch ofsprinkler irrigation perset untilthe beets have two true leaves. Do not usethetank mix under conditions where Pyramin alone is not recommended. Before use, read the Pyamin labelfor additional information and precautions. CENTRAL AND EASTERN STATES, INCLUDING MICHIGAN AND OHIO: This tank mix controls the additional weed, common ragweed, and other broadleafweeds specified in the weed table. Apply preemergence atthetimeofplanting or shortly after, but before weed germination, using specified rates listed in Dosage Table 4. Do not mechanically incorporate the herbicides intothe soil as crop injury may result. Do not use this tank mix where Pyramin alone is not recommended. Before use, read Pyramin label for additional information and precautions.

Soil Texture

Coarse Textured Soils: Sandy loams only
MediumTextured Soils: Silt loams, clay loams which contain lessthan 3% organic matter Fine Textured Soils: Clay loamswhich contain more than 3% organic matter and clays DOSAGETABLE4 (Central and Eastern States Only):
Willowood Ethofumesate SC perAcre Nnch Band Width' Broadcast 22" Row 28" Row

3 Pints 1 Pint 3/4 Pint

4 Pints 1 114 Pints 1 Pint

5 Pints 1 1/2 Pints 1 1/4 Pints Broadcast

2 t/40ts.

30ts.

30ts.

1 For other band orrowWidths, adjust the rate In proportion to the area actually being treated. Preplant and Preemergence Use Precautions PYRAMIN FL perAcre 7·inch Band Width' 22" Row 28" Row

3/40t. t/20t.

10t. 3/401.

10t. 3/401.

Willowood Ethofumesate SC applied alone or in tank mixes according to labeldirectionsand under normal growing conditions may cause temporary leaffusion, distortion and stunting. Crop injury may occurduring early growthwhen crop is stressed due to herbicide residue carryover, highly saline oralkaline soils, unusually cold and wet weather or improperly placedfertilizers or soil insecticides. Unusually dry, windy weather, which dries the upper soil layer, following application ofWillowood Ethofumesate SC. may reduce effectiveness. DO NOT OVERTREAT: The useof higherthan label-listed rates may cause beet injury and/or carry over problems. Crop Planting Precautions: Ifcrop is lostdue to unfavorable growth conditions following treatment, do not replant with crops otherthan sugar beetsor ryegras$ in treated land during the same season. If fields are replanted tosugar beets, reseed into treated band. Do notretreat field with conventional rates ofWiflowood Ethofumesate SC in the same season. PastemergenceApplication Product Information The tank mixes ofWillowood Ethofumesate SC plus Betamix® or Betanex® Herbicides applied postemergence broaden and enhance the control of weeds. The choice 01 tank mixes is dependent upon weed species present. Willowood Ethofumesate SC alone is not recommended for postemergent use.

9Tank mixes ofWmowood Ethofumesate SC plus Betamix®or Betanex® applied postemergence control the lollowing weeds: Annual Broadleaf Weeds Annual sowthistle (Sonchus oleraceus) Black nightshade (Solanum nigrum) Hairy nightshade (Solanum sarrachoides) Coast fiddleneck (Amsinckia intermedia) Common chickweed (Sfel/aria media) Common lambsquarters (Chenopodium album) Common ragweed (Ambrosia artemisiffolia) Groundcherry (Physalis /anceifoliaJ Kochia' (Kochia scoparia) Ladysthumb (Po/ygonumpersicaria) London rocket (Sisymbrium irio) Nettleleafgoosefoot (Chenopodium mura/e) Pennsylvania smartweed (Polygonumpennsylvanicum) Prostrate pigweed (Amaranthus gracizans) Redroot pigweed (Amaranfhus refroflexus) Purslane (Portulaca oleraceus) Shepherdspurse (Capse/la bursa·pasforis) Wild buckwheat (Pofygonum convolvulus) Wild mustard (Brassica kaber) 'Spray kochia while in the rosette stage, less than one inch in diameter. Annual Grass Weeds Annual bluegrass (poa annua) Canarygrass (pha/aris canariensls) Additionally, a tank mix ofWillowood Ethofumesate SC plus Betamix® applied postemergence also controlsthe following annual grass weeds: Green foxtail (Setaria viridis) Pigeon grass (yellowfoxtail) (Setaria g/auca) Mixing the Spray: Add Wi!lowood Ethofumesate SC to the water in the spraytankfollowed by Betamix® or Betanex®while agitating the spray solution thoroughly. Refer to the Betamix® or Betanex® labelsfor additional precautions and information on mixing. Spray Equipment: Applythe mixture using standard low pressure (20·60 psij spray equipment. Ensure thatthe sprayer is thoroughly clean. Spray equipment should be carefully calibrated before use and checked frequently during application to see that it is functioning properly. Uniformlyapply the label·listed rate in 20·60 gallons ofwater per acre on a broadcast basis or 5·10 gallons of waterperacre in a band. Avoid overlaps, since crop injury mayresult. When applying in a band, checkto make certain thatthe band width is accurateforthe dosage rate being applied. Do not use strainer smallerthan 50·mesh. Moisture Following Application/Residual Weed Control: Rainfall orsprinkler irrigation within 6 hours ofspraying may reduce weed control: however, with conventional rates, moisture afterthis period oftime is advantageous for moving Wi!lowood Ethofumesate SC into thetop layer ofsoil where itcan be absorbed by the roots ofsprayed and genninating weeds to provideoptimum control. One·half inchor more ofsprinkler irrigation is required to activateWil!owood Ethofumesate SC on mostsoil types. Residual control ofweeds is dependent upon soil moisture conditions; rate of herbicide used, and soil texture. The activity of Willowood Etho· fumesate SC in the soil is reduced as the soil texture becomesfiner and organic matter increases. Precautions Following a preemergence treatment ofWillowood Ethofumesate SC, do not apply convent'lonal rates ofWillowood Ethofumesate SC poste· mergence where more than 6 pints were applied preplant or preemergence. Do not apply more than 3.75 Ibs. a.i. (7 pints of product) per acre per season for sugar beets. See Use Precautions foradditional information on properuse.

10Split (Low Rate) Applications Split (low rate) applicationsofWillowood Ethofumesate SC + Betamix® or Betnex® Herbicides may be applied to sugar beets to control early geminating weeds (the tank mix ofWi!!owood Ethofumesate SC + Betanex® may be used in all sugar beet areas except California). The first spray must be applied when the earliest emerging weeds have reached cotyledon size. See DosageTable 5 for broadcast rates. See Dosage Table 6 and 7 for equivalent band rates. For band applications, apply in 5-10 gallonsofwater peracre. Anyweedswhich are notcompletely controlled bythefirst treatmentwi!! usually be checked and contro!!ed by repeat applications. The repeat application should be made 5to 7 days afterthe preceding application or when anotherflush ofweeds germinates. Ifsecond application is delayed, conventional applications as described below will be necessary.
DOSAGE TABLE 5 DOSAGE CHART FOR BROADCASTAPPLICATION
Pints/Acre Broadcast SugarBeetStage WILLOWOOD ETHOFUMESATE SC + BETAMIX® WILLOWOOD ETHOFUMESATE SC+ BETANEX® Cotyledon 0.25 + 1.50 0.25 + 1.50
2 Leaf 0.33 +2.00 0.33 + 2.00
4 Leaf 0.50+3.00 0.50 + 3.00

DOSAGETABLE 6 BETAMIX®OR BETANEX® DOSAGE CHART FOR BAND APPLICATION
Broadcast BAND RATE

- ROW SPACING Equivalent Band Width 22" 28" 3ry'
1.5 pints/acre 5" 5,5 fl. oz. 4.3f1. oz. 4.0f1. oz. 7" 7.6 f1. oz. 6.0fl. oz. 5.6 fl. oz. 2.0 pints/acre 5" 7.3 fl. oz. 5.7 fI, oz. 5.3 f1. oz. l" 10.2 f1. oz. B.O f1. oz. 7.5 f1. oz. 3.0 pints/acre 5" 10.9 fl. oz. B.6 fl. oz. 8.0fl. oz. 7" 15.3 fl. oz. 12,0 fl. oz. 11.2 fl. oz. DOSAGETABLE 7 WILLOWOOD ETHOFUMESATE SC DOSAGE CHART FOR BAND APPLICATION
Broadcast BAND RATE

- ROW SPACING Equivalent Band Width 22" 28" 30" 0,25 pints/acre 5" 0.9 fl. oz. 0.7 fl. oz. 0.7 fl. oz. 7" 1,3 fl.oz. 1.0 f1. oz. 0.9fl.oz. 0.33 pints/acre 5" 1.2 fl. oz. 0.9 fl. oz. 0.9 f1. oz. 7" 1.7 fl. oz. 1.3fl. oz. 1.2 fl. oz. 0.5 pints/acre 5" 1.8 fl. oz. 1.4 fl. oz. 1.3 fl. oz. 7" 2.5 fl. oz. 2.0 fl. oz. 1.9 fl. oz.

11Conventional Applications Timing ofApplication;Applythetank mix Willowood Ethofumesate SC + Betanex® orWillowood Ethofumesafe SC + Betamix® when sugar beets have at least 4 fully expanded true leaves. Apply at rates specified in the DosageTables. Use the higher rate ofWiUowood Ethofumesate SC where increased residual weed control is desired. Where Eptam® has been applied preplant (fall orspring applied): do notapplyWillowood Ethofumesate SC + Betamix® or Betanex® tank mix before the sugarbeets have 6 expandedtrue leaves. See Postemergence Use Precautions for additional information on proper use. WILLOWOOD ETHOFUMESATESC + BETAMIX® (TANK MIX) Willowood Ethofumesate SC applied postemergence in a tank mixwith Betamix® Herbicide broadens and enhances the control oftroublesome weeds. Furthermore, preemergence control ofsusceptible weeds which may germinate following treatment can be obtained provided overhead moisture is sufficient to activate WiUowood Ethofumesate SC. WEED SPECIES CONTROLLED Group I: Weeds controlled UP to the 6-leaf stage. Redroot Pigweed (Amaranthus refroflexusj Wild mustard (Brassica kaber) NettJeleaf goosefoot (Chenopodium mura/e) London rocket (Sisymbrium irio) Common lambsquarters (Chenopodium a/bum) Group II: Weeds controlled uptothe 4-leafstage. Common chickweed (Stellaria media) Black n'lghtshade (Solanum nigrum) Common ragweed (Ambrosia artemisiifolia) Shepherdspurse (Capsella bursa-pastorisj Groundcherry (Physalis lanceifolia) Pennsylvania smartweed (Polygonum pennsy/vanicum) Ladysthumb (Polygonum persicaria) Prostrate pigweed (Amaranthus bfifoides) Coast fiddleneck (Amsinckia intermedia) Group III: Weeds controlled up to the2-leafstage Annual sowthistle (Sonchus oleraceus) Kochia' (Kochia scoparia) Common purslane" (portulaca o/eracea) Prostrate knotweed (Polygonum aviculare) Wild buckwheat (polygonum convolvulus) Green foxtaW" (Setaria viridis) Yellow foxtail (pigeongrass)'" (Setaria glauca) Annual bluegrass'" (poa annua) Canarygrass'" (Phalaris canariensis)

• Spray kochia while in the rosette stage, less than 1" in diameter. "Group II weed in California "'For best control, overhead moisture required.

12DOSAGE TABLE 8
Rate ofWillowood Ethofumesate SC PerAcrel Rate of Betamlx® PerAcrel Band2 RowSpacing Broad- Band2 Row Spacing Broadcast Rate Width cast (In.) 22" 28" 30" Rate Width (In.) 22" 28" 30"
2 1/4 - 3 Pints 7 3/4 -1 Pint 1/2

- 3/4 1/2

- 2/3 41/2- 6 7 t t/2 - 2 1 - 1 1/2 t t/3 Pints Pint Pint Pints Pints Pints 

### ,Use the higher rate on largerweeds and sugarbeets,

2 For other band orrowwidths, adiust rates in proportiontothe area actually treated.

WILLOWOOD ETHOFUMESATE SC + BETANEX® (TANK MIX) ALL AREAS EXCEPT CALIFORNIA: Willowood Ethofumesate SC applied postemergence in atank mix with Betanex® Herbicide broadens and enhances control oftroublesome weeds. Furthermore, preemergence control ofsusceptibleweeds which may germinatefollowing treatment can be obtained provided overhead moisture is sufficient to activate Willowood Ethofumesate SC. WEED SPECIES CONTROLLED Group I: Weeds controlled upto the 6·leafstage. Redroot pigweed (Amaranthusretroffexus) Wild mustard (Brassfca kaber) Nettleleafgoosefoot (Chenopodium murale) London rocket (Slsymbrium irro) Common lambsquarters (Chenopodium album) Group11: Weeds controDed upto the4-leafstage Commonchickweed (Stel/aria media) Black nightshade (Solanum nigrum) Common ragweed (Ambrosia artemisiifofia) Shepherdspurse (Capseffa bursa-pastoris) Groundcherry (Physalis lanceifofia) Pennsylvania smartweed (Polygonum pennsylvanfcum) Ladysthumb (polygonum persicaria) Group111: Weeds controlled upto the 2-leaf stage Annual sowthistle (Sonchus oleraceus) Common purslane (portulaca o/eracea) Wild buckwheat (Polygonum convolvulus) Kochia' (Kochia scoparia)

, Spray Kochiawhile in the rosette stage. less than t" in diameter

13DOSAGE TABLE 9 (All areas except California) Rate of Wiflowood Ethofumesate SC PerAcre' Rate of Betanex® Per Acre' Band2 RowSpacing Broad- Band2 Row Spacing BroadcastRate Width cast (in.) 22" 28" 30" Rate Width (in.) 22" 28" 30"
2 1/4 - 3 Pints 7 3/4 -1 Pint 1/2-314 1/2

- 2/3 41/2 - 6 7 1 1/2

- 2 11/8 - 1 - 1 113 Pint Pint Pints Pints 1 1/2 P'lnts Pints

, Use the higher rate on largerweeds and sugar beets
2 For other band or row widths, adjust rates in proportion to the area actuallytreated. Postemergence Use Precautions: Make onlyone conventional application ofWillowood Etholumesate SC + Betanex® or Betamix@tank mix during each growing season. Do not applyWillowood Ethofumesate SC + Betanex® or Betamix@tank mix to sugar beets later than 90 days priorto harvest. Crop Planting Precautions: Ifcrop is lostdue to unfavorablegrowth conditions lollowing treatment, do not replantwith cropS other than sugar beets orryegrass in treated land duringthe same season. Iffields are replanted to sugar beets, reseed into treated band. Do notretreat field with conventional rates ofWillowood Ethofumesate SC in the same season. WILLOWOOD ETHOFUMESATE SC +BETANEX® OR BETAMIX@MAYCAUSESUGAR BEET INJURY OR STAND LOSS IF THE CROP IS UNDER STRESS FROM ONE OR MORE OF THE FOLLOWING CONDITIONS: • Rapid climatic changes from cool, overcast days, to hot (BO°F orovell, brightdays. When the airtemperature is, oris likelyto be above

BO°F on the day of spraying, application should be made in the evening when the temperature is lower. • Frostwithin seven daysfollowing treatment • Windy ordroughtconditions • Use of a preplant or preemergence herbicide or 01her chemicals • Insect ordisease injury • Close cultivation Ifstress conditions are present, delay application until crop has recovered. DO NOT OVERTREAT; The useof higher-than-specified rates maycause beet injuryandlor carry over problems, Do not spraywhile dew is present. Rainfall or sprinkler irrigation within 6 hours of application may reduce weed kill. IfWillowood Ethofumesate SC is applied on fieldswith heavy crop residue, such as from a previous com crop, reduced weed control may occur, Do not allow spray drift to contact adjacent crops which may be injured by spray drift. IMPORTANT: This tank mix may causetemporary growth retardation andlor chlorosis ortip-bum on sugar beets, Sugar beets usually resume normal growth within 10days. WILlOWOOD ETHOFUMESATE SC MIXTURES WITH FERTILIZERS WILlOWOOD ETHOFUMESATESC Impregnation on Dry Bulk Fertilizers Willowood Ethofumesate SC may be impregnated on many dry bulk fertilizers (See "1" below) and applied and incorporated into the soU belore planting for the control of labeled grasses and broadleaf weeds in sugar beets. All Willowood Ethofumesate SC label and supplementary literature instructions and precautions regarding rates peracre, soli type and soil incorporation, application, and otherdirections must befollowed. All individual State regulations relating to dry bulkfert16zer blending, registration, labeling and application are the responsibility of the individual andlor company selling the Willowood Ethofumesate SC/fertiJjzer mixtures. A minimum of200 pounds and a maximum of 700 pounds of approved fertilizer ingredients (See "2" below) impregnated with the appropriate 14amount ofWillowood Ethofumesate SC must be applied per acre. For impregnating the pesticide on dry fertilizers, use a closed**rotary~drum** type mixerequipped with suitable spraying equipment. The spray nozzles should be positioned inside ofthe mixerto provide uniform spray coverage ofthe tumbling fertilizer. The Willowood Ethofumesate SC should be sprayed uniformly onto the fertilizer using a fine spray pattern. The physical properties offertilizers vary, particularly in liquid absorptive capacity. When absorptivity is sufficient, simple spray impregnation of the fertilizer with Willowood Ethofumesate SC provides a satisfactory dry mixture. Ifthe absorptivity IS not adequate, use ofa highly absorptive powder is required to provide a dry,**free~flowing** mixture. Microcel E**(Johns~** Manville Products Corporation) is the recommended absorbent powder. It should be added separately and uniformlyto the prepared pesticide! fertilizer mixture in a quantitythat is sufficient to provide asuitably**free~flowing** mixture. Generally, less than 2% byweight of Microcel Eis required. The amount ofWillowood Ethofumesate SC actually required in theformulation ofspecific fertilizer mixtures should be calibrated carefully for each production operation. This is necessaryto ensure thatthe amount ofWII!owood Ethofumesate SC actually contained in the fertilizer mixture appl"led tothe soil represents the correct dosage rate. Bulkfertilizers impregnated with Willowood Ethofumesate SC should be applied immediately, NOT STORED. WILLOWOOD ETHOFUMESATE SC IMPREGNATION ON DRY BULK FERTILIZERS t. Approved dryfertilizer ingredientsfor usewith Willowood Ethofumesate SC:
N P K Ammonium nitrate 34 0 0 Ammonium sulfate 21 0 0 Ammonium phosphate"sulfate 16 20 0 Diammonium phosphate 18 46 0 Monoammonium phosphate 11 56 0 Potassium chloride 0 0 60 Potassium sulfate 0 0 52 Single superphosphate 0 20 0 Triple superphosphate 0 46 0 Urea 45 0 0
WiUowood Ethofumesate SC Physical Data Density t.15 g/cmJ Pounds/gallon 9.60 Flashpoint Noncombustible

152. Rate Chartforthe Impregnation of Dry Bulk Fertilizers with Willowood Ethofumesate SC: Gallons ofWillowood Ethofumesate SC perTon of DryBulk Fertilizer
FertilzerRate Ib/acre 2.25 pt.lacre Impregnation Rate 3 pt.lacre 4.5 pt./acre 200 2.80 3.75 5.53 250 2.25 3.00 4.50 300 t.88 2.50 3.75 350 t.59 2.t6 3,t9 400 1.4t 1.88 2.8t 450 1.25 t.59 2.50 500 1.13 1.50 2.25 550 t.03 t.38 2.06 600 0.94 t.25 1.88 650 0,87 t.t3 t.75 700 0.80 t.08 t.52 WILLOWOOD ETHOFUMESATE SC with Liquid Fertilizer The following procedure is suggestedforevaluation ofphysical compatibility ofWillowood Ethofumesate SC with liquid fertilizers for spray tank applications. Material Required 1. Willowood Ethofumesate SC- components oftank mixes if intended for use 2. Liquid fertilizer to be used 3. Adjuvant for fertilizer tank mix: Compex' or E-Z Mix", 4. Two (or more) one quart. wide mouth containerswith lids orstoppers 5. Measuring spoons- (25 ml pipette orgraduated cylinder provides more accurate measurement) 6. Measuring cup, 8 fl. oz. (237 ml) • Compex- Kalo Laboratories. Inc" Kansas City, MO •• E-Z Mix- United Agri-Products. Greeley. CO PROCEDURE t. Pour one pint(473 ml) ofthe liquid fertilizer into each ofthe quart containers. 2. Add adjuvant(s) to one or more ofthe containers and mix; follow label directions ofadjuvant. 3. Add the Willowood Ethofumesate SC andtank mix components to the containers (see rate table below), 4. Close the containers with lids orstoppers and mixcontents by inverting the containers ten times. 5. Inspectthesurface and body ofthe mixture: a. immediatelyafter mixing. b. after allowing mixtures to stand quietly for 30 minutes, c. immediately after mixing again (invert thecontainersten more times). Ifa uniform mixture does not occur, the spraytank mixture should not beused. If any ofthe mixtures remain uniform for 30 minutes. that mixture may be used in spraytank applications. Should any ofthe mixturesseparate after 30 minutes but remix readily into a uniform mixture with inversion ofthe container, the mixture may be used provided that adequate agitation is maintained in the spray tank. IfaWillowood Ethofumesate SC +fertilizer mixture utilizing an adjuvant is satisfactory. but the one without the adjuvant is not. be sure to use the adjuvant in the spray tank at the rate specified on the label which was used in this test. If non-dispersible oil, sludge, orclumps of solids form in the mixtures. those combinations should not be used for spraytank application.

16Willowood Ethofumesate SC alone will also reduce competition from these**HARD~TO-CONTROL** weeds: Annual Sowthistle (Sonchus loeraceus) Puncturevine (Tribulus terrestris) Shepherdspurse (Gapsella bursa-pastoris) Purple nutsedge (Cypel1Js rotundus) Yellow nutsedge (Cypel1JS esculenfus) Applytank mixes only in specified regions orStates and in accordancewith directions on label. APPLfCATfON INSTRUCTIONS Table Beets Grown Under Rainfall: ApplyWillowood Ethofumesate SC alone orin a tank mix preemergence attime ofplanting orshortly after, but priorto weed germination. Willowood Ethofumesate SC ortank mix does notrequire mechanical soil incorporation provided that sufficient rainfall occurs shortlyfollowing application to activate the chemical. One-half inch ofrainfall is usually adequate for activation. In areas where rainfall can be marginal for activation, it is recommended that Willowood EthofumesateSC be applied before oratthetime ofplanting and incorporated into the soil. Table Beets Grown Under Furrowfrrigation: ApplyWillowood Ethofumesate SC alone orin atank mix to the soil surface preplant orat time of planting, but priortoweed germination. Where table beets are grown in beds, applyWlllowood Ethofumesate SC or tank mix after bedding and incorporate. Since Willowood Ethofumesate SC must have moisture to controlweeds effectively, irrigate until tops of beds are thoroughly wetted. Table BeetsGrown Under Sprinkler Irrigation:ApplyWillowood Ethofumesate SC alone or intank mix preemergence at time ofplanting or shortlyafter, and irrigate priorto crop and weed germination. Repeat irrigation as necessary to maintain good moisture in uppersoil layer. Apply at least one-half inch ofwaterduring first irrigation. Do not mechanically incorporateWillowood Ethofumesate SC into the soil under sprinkler irrigation. Cultural Practices Following Application:When properly applied, Willowood Ethofumesate SC alone can provide up to 6 weeks control of susceptible speCies. When cultivating fields in which Willowood Ethofumesate SC has been banded, care should be exercised to minimize the movement of untreated soil into the treated band. Where a broadcast application has been made, do not cultivate deeperthan two inches, as this reduces the effectiveness ofWillowood Ethofumesate SC.

WILLOWOOD ETHOFUMESATE SC ALONE DOSAGE FOR BROADCASTAPPLfCATIONS
Table BeetStage WIUOWOOD ETHOFUMESATE SC FLUfD OUNCES/ACRE BROADCAST

Preemergence 60 Postemergence: 2-Leaf 5.25 4-Leaf 5.25 6-Leafto 8-Leaf 10.5 Do not exceed 2.6 Ibs. a.l. (80 ounces of product) peracre perseason.

PREPLANTAND PREEMERGENCE USE PRECAUTIONS Willowood Ethofumesate SC applied alone or in tank mixesaccording to label directions and under normal growing conditions may cause temporary leaffusion, distortion and stunting. Crop injury may occur during early growth when crop is stressed dueto herbicide residue carryover, highly saline oralkaline soils, unusually cold and wet weather or improperly placed fertilizers or soil insecticides. Unusuallydry, windyweather, which driesthe upper soil layer, following application ofWillowood Ethofumesate SC, mayreduce effectiveness. DO NOT OVERTREAT: The use of higher than labeHisted rates maycause beet injury and/orcarryover problems. Crop Planting Precautions: Ifcrop is lost dueto unfavorable growth conditions following treatment, do not replant with crops otherthan 18sugar beets, table beets, garlic, onions, shallots or ryegrass in treated land during the same season. Iffields are replanted to sugar beets, reseed intotreated band. Do not retreat field with preemergence rates ofWillowood Ethofumesate SC in the same season. RATE RESTR!CTION Do not apply more than 1.9 Ibs. a.i. (3 pintsofproduct) per acre per**pre~emergent** application totable beets. See Use Precautions for**ad~** ditional infonnation on proper use. PREPLANTAND PREEMERGENCE APPLICATIONS Soil Preparation: The soil should be prepared according to good agricultural practices. Large clods can reduce the effectiveness ofWillowood Ethofumesate SC and tank mixes. All existing vegetative growth should bethoroughlyworked into the soil beforetreatment. Spray Equipment:Apply Willowood Ethofumesate SC alone orintank m'lxes to the soil using standard low pressure (20 to 50 psi) spray equipment. Spray equipment should be carefully calibrated before use and checked frequently during application to see that it is functioning properly. Do not use smallerthan 50-mesh strainer. Uniformlyapplythe specified rates ofWillowood Ethofumesate SC ortank mixes in 10to 60 gallons ofwater peracre on a broadcast basis. Avoid overlaps since crop injury may result. When applying Willowood Ethofumesate se or tank mixes in a band, checkto make certain that the bandwidth is accurate forthe dosage rate being.app!ied. The spraytankand lines should be thoroughly cleaned and rinsed priorto using WiI!owood Ethofumesate SC. POSTEMERGENCE APPLICATION Product Information Willowood Ethofumesate SC applied postemergence broadens and enhancesthe control ofweeds.**Post~emergent** application Rate Restriction: Do not apply morethan 0.33 lb. a.i. per acre perapplication. Mixing the Spray: Add Willowood Ethofumesate SC to the water in the spraywhile agitating the spray solution thoroughly. Spray Equipment:App!y the mixture using standard low pressure**(20~60** psi) spray equipment. Ensure that the sprayer is thoroughly clean. Spray equipment should be carefully calibrated before use and checked frequently during application to see that it is functioning properly. Uniformlyapplythe specified rate in 10-40 gallons ofwater peracre on a broadcast basis or 5-10 gallons ofwater per acre in a band. Avoid overlaps, since crop injury may result. When applying in a band, check to make certain that the band width is accurate forthe dosage rate being applied. Do not use strainer smallerthan**50~mesh.** Moisture Following Application/Residua! Weed Control: Rainfall orsprinkler irrigation within 6 hours ofspraying may reduce weed control; however, with preemergence rates, moisture after this period oftime is advantageousfor moving Willowood Ethofumesate SC into thetop layer of soil where it can beabsorbed by the roots ofsprayed and germinating weeds to provide optimum control.**One~ha!f** inch or more of sprinkler irrigation is required to activate Willowood Ethofumesate SC on most soi! types. Residua! control ofweeds is dependent upon soil moisture conditions; rate of herbicide used, and soiltexture, Theactivity ofWillowood Ethofumesate SC 'In the soi! is reduced as the soil texture becomes finer and organic matter increases. W!LlOWOOD ETHOFUMESATE SC MAYCAUSE CROPJNJURY OR STAND lOSS!FTHE CROP IS UNDER STRESS FROM ONE OR MORE OFTHE FOLlOW!NG CONDITIONS: • Rapid climatic changesfrom cool, overcast days, to hot(BO°F orover), bright days, When the airtemperature is, or is

likely to be, above BO°F on the day of spraying, application should be made in the evening when the temperature is lower. • Frost within seven daysfollowing treatment • Windyordrought conditions • Use ofa preplant orpreemergence herbicide or other chemicals • Insect or disease injury • Close cultivation Ifstress conditions are present, delay application until crop has recovered. DO NOT OVERTREAT: The use of**higher~than~specifled** rates may cause beet injuryand/orcarry over problems. Do notspraywhile dew is present. Rainfall or sprinkler irrigation within 6 hours of application may reduce weed kil!.

19IfWillowood Ethofumesate SC is applied on fields with heavy crop residue, such as from a previous corn crop, reduced weed control may occur. Do not allowspraydrift to contact adjacent crops which may be injured byspray drift. 

## ONION, DRY BULB; GARLIC, BULB; SHALLOT, BULB
PRODUCT INFORMATION Willowood EthofumesateSC is a selective herbicidefor use in onion, garlic and shallotforthe control ofthe weed species listed below. Residual control ofweeds is dependent upon soil moisture conditions; rate ofherbicide used, and soil texture. The activity ofWillowood Ethofumesate SC in the soil is reduced as the soil texture becomes finer and organic matter increases. WEED SPECIES CONTROLLED Annual BroadleafWeeds Black nightshade (Solanum nigrum) Common chickweed (Stel/aria media) Common lambsquarters (Chenopodium album) Common purslane (portulaca o/eracea) Eastern black nightshade (Solanum ptycanthum) Kochia (Kochia scoparia) Ladysthumb (Polygonum persicaria) Pennsylvania smartweed (polygonumpennsyfvanfcum) Redroot pigweed (Amaranthus retroflexus) Russian thistle (Salsola kali var. tenuifolia) Wild buckwheat (Polygonum convolvulus) Annual Grass Weeds Annual bluegrass (Poa annua) Barnyardgrass (Echinochloa crus-galll) Canarygrass (Phalaris canariensis) Green foxtail (Setaria viridis) Large crabgrass (Digitaria sanguinalis) Volunteer barley (Hordeum spJ Volunteerwheat (fn'tlcum sp.) Wild oats··(Avena latua) Yellow foxtail (Sefaria glauca) ··Control ofwild oats has been inconsistent in Minnesota and North Dakota Wlllowood Ethofumesate SC alone will also reduce competition from these HARD-TO-CONTROLweeds: Annual sowthistle (Sonchus o/eraceus) Puncturevine (fribu/us terrestris) Shepherdspurse (Capsel/a bursa-pastoris) Purple netsedge (Cyperus rotundus) Volunteer potato (Solanum tuberosum) Yellow nutsedge (Cyperus esculentus) Apply tank mixes only in specified regions orStates and in accordance with directions on label. APPLICATION INSTRUCTIONS Onion, garlic and shallotgrown under rainfall: ApplyWillowood Ethofumesate SC alone or in atank mix preemergence at time of planting or shortly after, but priorto weed germination. Willowood Ethofumesate SC or tank mix does not require mechanical soil incorporation provided that sufficient rainfall occursshortlyfollowing application to activate the chemical. One-hall inch of rainfall is usually adequateforactivation. In 20areas where rainfall can be marginalfor activation, it is recommended thatWillowood Ethofumesate SC be applied before or at time ofplanting and incorporated intothesoil. Onion, garlic and shallot grown underfurrow irrigation:Apply**W~lowood** Ethofumesate SC alone or in a tank mix to the soil surface preplant or at time ofplanting, but prior toweed germination. Where these crops are grown in beds, applyWillowood Ethofumesate

### se ortank mix after bedding and incorporate. SinceWillowood Ethofumesate SC must have moisture to control weeds effectively, irrigate until tops of beds are thoroughlywetted. Onion, garlic and shallot grown undersprinkler irrigation:ApplyWillowood Ethofumesate SC alone or in tank mix preemergence at time of planting orshortly after, and irrigate priorto crop and weed germination. Repeat irrigation as necessary to maintain good moisture in upper soil layer. Apply at least**one~half** inch ofwater during first irrigation. Do not mechanically incorporate Willowood Ethofumesate SC into the soil under sprinkler irrigation. CULTURAL PRACTICES FOLLOWING APPLICATION: When properly applied, Willowood EthofumesateSC alone can provide upto 6 weeks ofcontrol ofsusceptibleweed species. When cultivating fields in which Willowood Ethofumesate SC has been banded, care should be exercised to minimize the movement ofuntreated soil into thetreated band. Where a broadcast application has been made, do not cultivate deeper than two inches, as this reduces the effectiveness ofWillowood Ethofumesate SC. WILLOWOOD ETHOFUMESATE SC ALONE DOSAGE FOR BROADCASTAPPLICATIONS TO ONION, GARLIC AND SHALLOT
Use Pattern Preemergence, soil surface Coarse Soils (sand, loamysand, sandy loam)" Medium and Fine**Soils~'** Postemergence Upto 4 foliar applications at evenly spaced intervals, with last application 30**(+/~** 2) days before harvest WILLOWOOD ETHOFUMESATE SC FLUID OUNCES/ACRE BROADCAST

16 32

16

• On coarse SOils: Do not exceed 48 fluid ounces (0.375 gallon) of product per season

. •• On medium and fine textured soils: Do not exceed 96 fluid ounces (0.75 gallon) of product perseason. PREPLANT AND PREEMERGENCE USE PRECAUTIONS Willowood Ethofumesate SC applied alone or in tank mixes according to label directions and under normal growing conditions maycause temporary leaf fusion, distortion and stunting. Crop infury mayoccurduring early grow1h when crop is stressed due to herbicide residue carryover. high saline or alkaline soils, unusually cold and wetweather or improperly placed fertilizers or soil insecticides. Unusuallydry, windyweather, which driesthe uppersoH layer. following application ofWillowood Ethofumesate SC, may reduce effectiveness. DO NOT OVERTREAT: The useofhigher than**label~listed** rates may cause crop injury and/or carry over problems. Crop Planting Precautions; If crop is lost dueto unfavorable grow1h conditions following treatment, do not replant with crops otherthan sugar beets, table beets, garlic, onions, shallots orryegrass in treated land during the sameseason. Iffields are replanted to sugar beets, reseed into treated band. Do not retreat field with preemergence rates ofWillowood Ethofumesate SC in thesame season. PRECAUTIONS See Use Precautions for additional information on proper use. PREPLANTAND PREEMERGENCE APPLICATIONS Soil Preparation: The soil should be prepared according to good agricultural practices. Large clods can reduce the effectiveness ofWillowood Ethofumesate SC and tank mixes. All existing vegetative grow1h should be thoroughlyworked into the soil beforetreatment. Spray Equipment: ApplyWillowood Ethofumesate SC alone or in tank mixes tothe soil using standard low pressure (20 to 50 psi) spray equipment. Spray equipment should be carefully calibrated before use and checked frequently during application to see that itis functioning properly. Do not use smaller than 50-mesh strainer. Uniformly applythe specified rates of Willowood Ethofumesate SC ortank mixes in 10 to 60 gallons of water peracre on a broadcast basis. Avoid overlaps since crop injury may result. When applying Willowood Ethofumesate SC or
21tank mixes in a band, check to make certain that the band width is accurateforthe dosage rate being applied. The spraytankand lines should bethoroughly cleaned and rinsed prior to using Willowood Ethofumesate SC. POSTEMERGENCE APPLtCATION Producttnformation Willowood Ethofumesate SC applied postemergence broadens and enhances the control of weeds. Mixing the spray: Add Willowood Ethofumesate SC to the water inthespraytankwhile agitating the spray solution thoroughly. Spray Equipment:Applythe mixture using standard low pressure**(20~60** psi) spray equipment. Ensure that the sprayer is thoroughly clean. Spray equipment should be carefully calibrated before use and checkedfrequently during application to see that it isfunctioning properly. Uniformly apply the specified rate in 10-40 gallons ofwater per acre on a broadcast basisor 5-tO gallons ofwater peracre in a band. Avoid overlaps, since crop injury may result. When applying in a band, check to make certain thatthe band width is accurateforthedosage rate being applied. Do not usestrainer smallerthan 50-mesh. Moisturefollowing ApplicationlResidualWeed Control: Rainfall orsprinkler irrigation within 6 hours ofspraying mayreduce weed control; however, with preemergence rates, moistureafterthis period oftime is advantageous for moving Willowood Ethofumesate SC into the top layer of soilwhere it can be absorbed bythe roots ofsprayed and germinating weeds to provide optimum control. One-half inch or more of sprinkler irrigation is required to activateWillowood Ethofumesate SC on mostsoil types. Residual control ofweeds is dependent upon soil moisture conditions, rate of herbicide used, and texture. The activity ofWillowood Ethofumesate SC in the soil is reduced as the soil texture becomesfiner and organic matter increases. WILLOWOOD ETHOFUMESATE SC MAY CAUSE CROP INJURY OR STAND LOSS IF THE CROP IS UNDER STRESS FROM ONE OR MORE OF THE FOLLOWING CONDITIONS: • Rapid climatic changes from cool, overcast days, to hot (80'F orover), brightdays. When the airtemperature is, or is likely to be,

above 80'F on the dayofspraying, application should be made in the evening when the temperature is lower. • Frostwithin seven daysfOllowing treatment • Windy or drought conditions • Use ofpreplant or preemergence herbicideorother chemicals • Insect or disease injury • Close cultivation Ifstress conditions are present, delayapplication untilcrop has recovered. DO NOT OVERTREAT: The use of higher-than-specified rates may cause beet injuryandlor carryover problems. Do notspraywhile dew is present. Rainfall or sprinkler irrigation within 6 hours of application may reduce weed kill. IfWillowood Ethofumesate SC is applied on fields with heavy crop residue, such as from a previous corn crop, reduced weed control may occur. Do not allowspray driftto contact adjacent cropswhich may be injured byspray drift. 

## CARROT (For Use in Washington and Oregon Only) PRODUCT tNFORMATION Willowood Ethofumesate SC is a selective herbicidefor use in carrot forthe control of volunteer potatoesand the weed species listed below. Residual controlofweeds is dependent upon soil moisture conditions; rate ofherbicide used, and soil texture. The activity ofWlilowood Ethotumesate SC in the soil is reduced as the soiltexture becomes finer and organic matter increases.

22WEED SPECIES CONTROLLED Annual Broadleaf Weeds Black nightshade (Solanum nigrum) Common chickweed (Ste/laria media) Common lambsquarters (Chenopodium album) Common purslane (Portulaca olemcea) Kochia (Kochia scoparia) Ladysthumb (Po/ygonum persicaria) Pennsylvania smartweed (Polygonumpennsy/vanicum) Redroot pigweed (Amaranfhus retroflexus) Russian thistle (Sa/sola kali var. tenuifolia) Wild buckwheat (Po/ygonum convolvulus) Annual GrassWeeds Annual bluegrass (Poa annua) Barnyardgrass (Echinochloa**crus~galli)** Canarygrass (Phalads canariensis) Green foxtail (Setaria viridis) Large crabgrass (Dfgifaria sanguinalfs) Volunteer barley (Hordeum spJ Volunteerwheat (Triticum spJ Wild oats (Avena tafua) Yellow foxiail (Setaria glauca) Willowood EthofumesateSC alone will also reduce competitionfrom these**HARD~ TO~CONTROL**  weeds: Annual Sowthistie (Sonchus oleraceus) Puncturevine (Tribulus terresttiS) Shepherdspurse (Capsel/a**bursa~pastoris)** Purple nutsedge (Cyerus rotundus) Volunteer potato (So/anum tuberosum) Yellow nutsedge (Cyperus esculentus) Apply tank mixes only in specified regions orStates and in accordance with directions on label.

APPLICATION INSTRUCTIONS Carrotgrown under rainfall:ApplyWillowood Ethofumesate SC alone or in atank rnix preemergence at tirne of planting or shortly after, but prior to weed germination. Willowood Ethofumesate SC or tank mix does not require mechanicalsoil Incorporation provided thatsufficient rainfall occurs shortlyfollowing application to activate the chemical.**One~half** inch ofrainfall Is usually adequatefor activation. In areas where rainfall can be marginalfOI activation, it is recommended that Willowood Ethofumesate SC be applied before orat the time of planting and incorporated into the soil. Carrot grown underfurrow irrigation:ApplyWillowood Ethofurnesate SC alone or in a tank mix to the soilsurface preplant or at time of planting, but priorto weed germination. Where carrots are grown in beds, applyWillowood Ethofumesate SC ortank mix after bedding and incorporate. Since Willowood Ethofumesate SC must have moisture to controlweeds effectively, irrigate until tops of beds are thoroughly wetted. Carrotgrown under sprinkler irrigation:ApplyWillowood Ethofumesate SC alone or in tank mix preernergence at time of planting or shortly after, and irrigate priorto crop and weed germination, Repeat irrigation as necessaryto maintain good moisture in upper soil layer. Apply at least**one~half** inch ofwaterduring first irrigation, Do not mechanically incorporate Willowood Ethofumesate SC Into the soil undersprinkler inigation. Cultural practicesfollowing application: When properly applied, Willowood Ethofumesate SC alone can provide up to 6 weeks control of susceptible weed species. When cultivating fields in whichwillowood Ethofumesate se has been banded, care should be exercised to**mini~** 23mize the movement of untreated soil into the treated band. Where a broadcast application has been made, do not cultivate deeperthan two Inches, as this reduces the effectiveness ofWillowood Ethofumesate SC. WILLOWOOD ETHOFUMESATE SC DOSAGE FOR BROAOCASTAPPLICATIONSTO CARROT
UsePattern WILLOWOOO ETHOFUMESATE SC FLUID OUNCES/ACRE BROADCAST Preemergence, soilsurface Coarse Soils (sand, loamysand, sandy loam) Medium and Fine Soils Postemergence**2~Leaf**to 4 LeafStage Do not exceed 128 flUId ounces (1 gallon) of product per season. PREPLANT ANO PREEMERGENCE USE PRECAUTIONS 48 64
64

Willowood Ethofumesate SC applied alone or in tank mixes according to label directions and undernormal growing conditions may cause temporary leaffusion, distortion and stunting. Crop injury may occurduring early growth when crop is stressed due to herbicide residue car· ryover, highly saline oralkaline soils, unusually cold andwet weather or improperly placed fertilizers or soil insecticides. Unusually dry, windy weather, which dries the uppersoil layer, following application of Willowood Ethofumesate SC, may reduce effectiveness. DO NOT OVERTREAT: The useof higherthan label-listed rates may cause crop injury and/orcarry over problems. Crop Planting Precautions: Ifcrop is lost due to unfavorable growth conditionsfollowing treatment, do not replant with crops otherthan sugar beets, table beets, carrots, garlic, onions, shallots, orryegrass in treated land during the same season. Iffields are replanted to sugar beets, reseed into treated band. Do notretreat fieldwith preemergence rates ofWilJowood Ethofumesate SC in the same season. PRECAUTIONS No more than atotal of 1 gallon ofWillowood Ethofumesate SC should be applied in a single growing season. See Use Precautions for additional information on proper use. PREPLANTAND PREEMERGENCEAPPLICATIONS Soli Preparation: The soil should be prepared according to good agricultural practices. Large clods can reduce the effectiveness ofWlllowood Ethofumesate SC and tank mixes. All existing vegetative growthshould be thoroughlyworked Into the soil before treatment. Spray Equipment:ApplyWillowood Ethofumesate SC alone or in tank mixes to the soil using standard low pressure (20 to 50 psi) spray equ·lpment. Spray equipment should be carefully calibrated before use and checked frequently during application to see that 'It is functioning properly. Do not use smallerthan 50 mesh strainer. Uniformly applythe specified rates ofWillowood EthofumesateSC ortank mixes in 10 to 60 gallons ofwater peracre on a broadcast basis. Avoid overlaps since crop injury may result. When applying Willowood Ethofumesate SC or tank mixes in a band, checkto make certain that the band width is accurate for the dosage rate being applied. The spraytank and lines should bethoroughly cleaned and rinsed priorto using Willowood Ethofumesate SC. POSTEMERGENCE APPLICATION Product Information Willowood Ethofumesate SC applied postemergence broadens and enhances the control ofweeds, Mixing the Spray: Add Willowood Ethofumesate SC to the water in the spraywhile agitating the spray solution thoroughly. Spray Equipment:Applythe mixture using standard low pressure**{20~60 ps~**  spray equipment. Ensure that the sprayer is thoroughly clean. Spray equipmentshould be carefully calibrated before use and checkedfrequently during application to see that itisfunctioning properly. Uniformly applythe specified rate in 10-40gallons ofwater peracre on a broadcast basis or**5~10** gallons ofwater peracre in a band. Avoid overlaps. since crop injury may result. When applying in a band, checkto make certain thatthe band width is accurateforthe dosage rate being applied. Do not usestrainersmaller than**50~mesh.**

24Moisture Following ApplicationlResidual Weed Control: Rainfall orsprinkler irrigation within 6 hours ofspraying my reduce weed control, however, with preemergence rates, moisture afterthis period of time is advantageous for moving Willowood Ethofumesate SC Into the top layer ofsoil where it can be absorbed by the roots of sprayed and germinating weeds to provide optimum control.**One~half** inch or more of sprinkler irrigation is required to activate Willowood Ethofumesate SC on most soiltypes. Residual control ofweeds is dependent upon soil moisture conditions; rate of herbicide used, and soil texture. The activityofWillowood Ethofumesate SC inthe soil is reduced as the soU texture becomes finer and organic matter ·Increases. WILLOWOOD ETHOFUMESATE SC MAY CAUSE CROP INJURY OR STAND LOSS IF THE CROP IS UNDER STRESS FROM ONE OR MORE OF THE FOLLOWING CONDITIONS: • Rapid climatic changes from cool, overcast days, to hot (80°F or over), bright days. When the airtemperature is, or is likely to be,

above 80'F on the dayofspraying, application should be made in the evening when the temperature is lower. • Frostwithin seven daysfOllowing treatment • Windy ordrought conditions • Use of preplant or preemergence herbicide or other chemicals • Insect ordisease injury • Close cultivation Ifstress conditions are present, delay application until crop has recovered. DO NOT OVERTREAT: The useof**higher~than-specified** rates may cause beet injuryandlorcarry over problems. Do not spraywhile dew is present. Rainfall orsprinkler irrigation within 6 hours of application may reduce weed kill. IfWillowood Ethofumesate SC is applied on fiek:ls with heavy crop residue, such as from a previous corn crop, reduced weed control may occur. Do notallow spray driftto contact adjacent crops which maybe injured byspray drift. 

# RYEGRASS,TALLFESCUE,BENTGRASS,AND KENTUCKY BLUEGRASS SEED CROPS (For use in California, Idaho, Nevada, Oregon, and Washington only) PRODUCT INFORMATION Willowood Ethofumesate SC is a selective herbicide for use in ryegrass, tall fescue, and bentgrass seed crops in California, Idaho, Nevada, Oregon, andWashington. It effectively controls orreduces competition from thoseweed species listed below. Willowood Ethofumesate SC may be applied preemergence to new seedings of annual orperennial ryegrass orpostemergenceto perennial ryegrass, tall fescue, orbentgrass. Application to bentgrass is restricted to plantings which have been established forone year or longer. Soil should be moistat time of application. W'lIlowood Ethofumesate SC is less effective when applied to dry soil. Rainfall or overhead irrigation shortly afterapplication is necessary for activation. Residual controlof weeds is dependent upon soil moisture conditions; rates of herbicide used, and soil texture. The activity ofWillowood Ethofumesate SC in the soil is reduced as the soil texture becomes finer and organic matter/thatch increases.

25WEEDS CONTROLLED Annual bluegrass (Poa annua) Seedling Rattail fescue (Festuca myuros) Seedling volunteerwheat (Triticum spp.) Seedling volunteer barley (Hordeum sPpJ Solt chess (Bromus mollls) Seedling Wild oats (Avena fafua) Downy brome (Bromus tectorum) Common chickweed (Stel/aria media) Common vetch (Vida sativa) Common velvetgrass (Holcus lanatus) Mannagrass (Glyceria spp.) Barnyardgrass (Echinochloa**crus~gal/i)** Canarygrass (Phalan's canan'ensis) Green foxtail (Sefarla viridis) Large crabgrass (Digifan'a sanguinalis) Yellow foxtail (Sefan'a glauca) Sprayequipment: Use a**fixed~boom** powersprayer properly calibrated to a constant speed and rate of delivery. Do not use smallerthan 50-mesh strainer. Avoid overlapping ofspray swath, Shutoff boom while starting, turning or stopping to avoid overlapping, Apply in 10 to 50 gallons ofwater per acre at low pressure {20 to 50 psQ, Soil preparation: Afirm, fine and level seedbed free oftrash andvegetative mailerwill provide best results from preemergence applications. Large clods can reduce effectiveness of Willowood Ethofumesate SC. All existing vegetative growth should be thoroughlyworked into the soil before treatment. NEW SEEDINGS OF ANNUAL OR PERENNIAL RYEGRASS Before weed emergence: Apply WiIJowood Ethofumesate SC afterseeding and priorto weed emergence. For best results apply to moist soil. Apply 1 1/2 to 3 pints per acre. Use the lower rate for control of common chickweed. For control of rallail fescue, wild oats, and volunteer cereals and otherweeds listed, use 2 t/4to 3 pints per acre. Afterweed emergence:ApplyWillowood Ethofumesate SC at earliest possibleweed growth stage but not later than the4-leafstage. Rattail fescue, wild oats, and volunteer cereals which are more difflcullto control, must be treated no later than the 2-leafstage. Apply2 1/4 to 3 pints per acre. Use the highest rate where rallail fescue, wild oats, and volunteer cereals are present and where weed infestation is heavy. NEW SEEDINGS OF**FALL~PLANTED** PERENNIAL RYEGRASS AND TALL FESCUE TREATED WITH DlURDN PLUS CHARCOAL Timing of application:ApplyWilJowood Ethofumesate SC following crop emergence and aftersufficient rainfall andloroverhead irrigation has occurred to dissipate the charcoal band (approximately4 inches). Use dosage rates listed in Dosage Table 10. Surface debris may result in reduced weed control. Failure to allowforcomplete dissipation ofthe charcoal band may result in reducedweed control within the crop row. For best results, applyWillowood Ethofumesate SC to a moistsoil surface. Before using d'luron, read the diuron label for rate recommendations, timing of applications, directions for use, and precautionary statements. Do not exceed maximum dosage rates foreither herbicide. NOTE: Do not applyWillowood EthofumesateSC when crop shows diuron injury.

Crop

Perennial ryegrass and tall fescue DOSAGETABLE 10
Rate PerAcre

1 1/2 to 3 pints

26 Remarks For effective control, annual bluegrass must be treated before the 4-leafstage; rattail fescue, wild oats, and volunteer wheat must be treated before the**2~leaf** stage. Use the lower rate for control of annual bluegrass and common chlckweed; use the higher rate forcontrol ofrattail fescue, wild oats, and otherweeds listed.After weed emergence: Apply Willowood Ethofumesate se at earliest possible weed growth stage but not later than the**4~leaf** stage. Rattail fescue, wild oats, and volunteer cereals which are more difficult to control, must be treated no laterthan the**2~leaf**stage. Apply2114 to 3 pints peracre. Use the highest rate where rattail fescue, wild oats, and volunteer cereals are present and where weed infestation is heavy. ESTABLISHED STANDS OF PERENNIAL RYEGRASS AND TALL FESCUE Before weed emergence: ApplyWillowood Ethofumesate SC at 2 1/4 to 3 pints peracre priorto weed emergence. Use higher rate where rattail fescue, wild oats, and volunteer cereals are expected to be a problem. For best results, apply to moist soil. Crop residue and debriswill reduce effectiveness oftreatment and should be removedor destroyed. Afterweed emergence:ApplyWillowood Ethofumesate se atearliest possible weed growth stage but not later than the 4-Ieafstage. Rattail fescue, wild oats, and volunteer cereals which are more difficultto control, must be treated no laterthan the**2~leaf** stage.Apply21/4 to 3 pints per acre. Use the higher rate where rattail fescue, wild oats, and volunteer cereals are present. Where weed pressure is very heavyand rattail fescue is atthe maximum stage ofgrowth fortreating, a rate of3 pints ofWillowood Ethofumesate se is recommended. ESTABLISHED STANDS OF BENTGRASS Apply onlyto**well~established** standswhich have been seededfor notless than 12 months. Strawfrom previous crop must be removed or destroyed. Failure to do so may result in reduced weed control. Before weed emergence: Apply Willowood Ethofumesate se at 1 1/2 to3 pints peracre prior to weed emergence. Use higher rate where rattail fescue, wild oats, and volunteercereals are expected to be a problem. For best results, apply to moist soil. Afterweed emergence:ApplyWillowood Ethofumesate se at earliest possible weed growth stage, butno laterthan the 4·leafstage. Rattail fescue, wild oats, and volunteer cereals which are more difficultto control, must be treated no laterthan the**2~leaf** stage. Apply atthe rate of 1 1/2to 3 pints peracre. Use higher rate when rattail fescue, wild oats, and volunteer cereals are a problem. Do not apply more than 3 pints of Willowood Ethofumesate se peracre on bentgrass, ESTABLISHED STANDS OF KENTUCKY BLUEGRASS (UNDER IRRIGATION ONLy) Apply only to established stands which have been seeded for at least 12 months. Crop residues, carbon, and debris should be removed. Failure to do so mayresult in reduced weed control. Willowood Ethofumesate se is compatible with currently labeled grass seed herbicides. Consult your local fieldman for recommended uses. Before weed emergence: ApplyWillowood Ethofumesate SC at 2 pints per acre priorto weed emergence. For best results, applyto moist soil. Apply at least 1/2 inch irrigationwithin 2 to 3 days aftertreatment to incorporateWillowood Ethofumesate SC. Afterweed emergence: ApplyWillowood Ethofumesate se at 2 pints peracre atthe earliest possible weed growth stage, but no laterthan the 4·leafstage. For best results, apply to moistsoil. Apply at least 1/2 inch irrigation within 2 to 3 days after treatment to incorporateWil· lowood Ethofumesate se. USE PRECAUTIONS Willowood Ethofumesate SC may cause stunting and stand reduction of newlyseeded perennial ryegrass and tall fescue if the crop is planted late in thefall and subjected to adverse climatic conditions orpesticideswhich restrict normal growth. Ifvegetative matterorstoverfrom previous crop was burned, sufficient rainfall oroverhead irrigation must haveoccurredto dissipate the charcoal residue remaining after buming priortoWillowood Ethofumesate SC treatment. Failure to allowfordissipation of charcoal residue may result in reduced weed control. 

## COMMERCIAL SOD PRODUCTION (For use in California, Idaho, Nevada, Oregon, and Washington only) PRODUCT INFORMATION Willowood Ethofumesate SC is a selective herbicidefor use in established and newly planted tall fescue and perennial ryegrass grown for sod in ealifomia, Idaho, Nevada, Oregon, and Washington. Willowood Ethofumesate se may be applied preemergence or postemergence forthe control ofweed species listed below. Overhead irrigation or rainfall shortly afterapplication is necessaryfor activation. Do not harvest treated sod for 16 daysfollowing application.
27Residual control ofweeds is dependent upon soil moisture conditions; rate ofherbicide used, and soil texture. The activityofWillowood Ethofumesate SC in the soil is reduced as soil texture becomes finer and organic matter/thatch increases. WEEDS CONTROLLED Annual bluegrass (Poa annua) Large crabgrass (Digitaria sanguinalis) Green foxtail (Setaria viridis) Yellow foxtail (Setaria glauca) Canarygrass (Pha/ans canariensis) Volunteer barley (Hordeum sp) Volunteerwheat (7fiticum sPJ Wild oats (Avena fatua) Rattail fescue (Festuca myuros) Common velvetgrass (Ho/cus /anatus) Mannagrass (Glyceria sp.) Downy brome (Bromus fectorum) Soft chess (Bromus mollis) Spray equipment: Use afixed-boom powersprayer properly calibrated to a constant speed and rate ofdelivery. Do not usesmaller than a 50-mesh strainer. Avoid overlapping ofsprayswath. Shut offboom while starting, turning, or stopping to avoid over-application. Make applications in 10 to 50 gallons ofwater per acre at low pressure (20 to 50 psi). Soil preparation: An existing vegetative mattershould be thoroughlyworked into the soil surface before planting. Large clods, trash, orvegetative matter left on the soil surface will reduce effectiveness ofthe Willowood Ethofumesate SC treatment. NEWLY PLANTED PERENNIAL RYEGRASS AND TALL FESCUE GROWN FOR SOD ApplyWillowood Ethofumesate SC to newly planted areas when crop reaches the 2-to 3-Ieafstage ofgrowth. For best results, applyto moist soils. Before weed emergence:ApplyWillowood Ethofumesate SC at 2 1/4to 3 pints per acre prior to weed emergence. Use the higher rate where rattail fescue, wild oats, and volunteer cereals are expected to be a problem. After weed emergence:ApplyWil!owood Ethofumesate SC at earliest possibleweed growth stage but no laterthan the 4-leafstage. Rattail fescue, wild oats, and Volunteer cereals which are more difficult to control, must be treated no later than the 2-leafstage. ApplyWillowood Ethofumesate SC at 2 1/4to 3 pints per acre. ESTABLISHED PERENNIAL RYEGRASS ANDTALL FESCUE SOD For preemergence and/or postemergence control ofsusceptible weeds. applyWillowood Ethofumesate SC prior to weed emergence or at the earliest possibleweed growth stage, but not laterthan the4-leafstage. For best results, apply to moist soils. ApplyWillowood Ethofumesate SC at 2 1/4to 3 pints peracre. Repeat applications at 4 to 8 week intervals may be needed to maintain weed control. Do not apply more than 1.5 Ibs. aJ. (3 pints of product) per acre per season for perennial ryegrass and tall fescue sod. USE PRECAUTIONS Willowood Ethofumesate SC may cause stunting, and stand reduction of newlyseeded perennial ryegrass and tall fescue, ifthe crop is planted late in the fall and subiectedto adverse climatic conditions or pesticides which restrict normal growth. Ifvegetative matterorstover from previous crop was burned, sufficient rainfall oroverhead irrigation must have occurred to dissipate the charcoal residue remaining after burning pliorto Willowood Ethofumesate SC treatment. Failure to allow for dissipation of charcoal residue may result in reduced weed control.

28

### STORAGE AND DISPOSAL Do not contaminate water, food, orfeed by storage or disposal. PESTICIDE STORAGE: Protect product from freezing temperatures. PESTICIDE DISPOSAL: Pesticide wastes are acutely hazardous. Improperdisposal 01 excess pesticide, spray mixture, orrinsate is aviolation of Federal law. Ifthese wastes cannot be disposed ofby use accordingto label instructlons, contact your State Pesticide or Environmental ControlAgency, orthe Hazardouswaste representative at the nearest EPA Regional Office for guidance. CONTAINER OISPOSAL: Nonrefillable container. Do not reuse orrefill this container. Triple rinse container (or equivalent) promptlyafter emptying. (Nonrefillable containers: 5 gallons): Triple rinse as follows: Empty the remaining contents into application equipment ora mixtank and drain for 10 seconds atterthe flow begins to drip. Fi!! the container 1/4 full with water and recap. Shakefor 10seconds. Pour rinsate into application equipment or a mix tank orstore rinsate for later use ordisposal. Drain for 10 seconds after the flow begins to drip. Repeat this procedure two more times. Then offer for recycling ifavailableor punctureand dispose 01 in a sanitary landfill, orby incineration, or, ifallowed bystate and local authorities, by burning. If burned, stay outofsmoke. (Nonrefillable> 5 gallons): Triple rinse as follows: Empty the remaining contents into application equipment ora mix tank. Fill the container 1/4full with water. Replace and tighten closures. Tip container on its side and roll itbackand forth, ensuring at least one complete revolution, for 30 seconds. Stand the container on its end and tip it backand forth several times. Turn the container overonto its otherend and tip it back and forth several times. Empty the rinsate into application equipmentor a mixtankor store rinsate for later use or disposal. Repeatthis proceduretwo more times. Then offer for recycling ifavailable or puncture and dispose of in a sanitary landfill, or by incineration, or, ifallowed by state and local authorities, by burning. Ifburned, stay out ofsmoke.

CONDITION OF SALE AND LIMITATION OF WARRANTYAND LIABILITY NOTICE: Read the entire Directions for Use and Conditions ofSale and limitation ofWarranty and liability before buying orusing this product. Ifthe terms are not acceptable, return the product atonce, unopened, and the purchase price will be refunded. The Directionsfor Use of this product must be followed carefully. It is impossible to eliminate all risks inherently associated with the useof this product. Ineffectiveness or otherunintended consequences may result because ofsuch factors as mannerof use orapplication, weather, presence ofother materials or other influencing factors in the use of the product, which are beyond the control ofWillowood, LLC or Seller, To the extentconsistentwith applicable law, allsuch risks shall be assumed by Buyerand User, and Buyer and Useragree to hold Willowood, LLC and Seller harmless forany claims relating to such factors. Willowood, LLC warrantsthat this product conformsto the chemical description on the label and is reasonably fitfor the purposes stated in the Directionsfor Use, subjectto the inherent risks referred to above, when used in accordance with directions under normal use conditions. Thiswarranty does not extend to the use ofthis product contrary to label instructions, orunderabnormal conditions or under conditions not reasonably foreseeable to or beyondthecontrol ofSeller orWillowood, LLC, and Buyer and Userassume the risk of any such use. TO THE EXTENT CONSISTENTWITH APPLICABLE LAW, WILLOWOOD, LLC MAKES NO WARRANTIES OF MERCHANTABILITY OR OF FITNESS FOR A PARTICULAR PURPOSE NOR ANY OTHER EXPRESS OR IMPLIED WARRANTY EXCEPTAS STATED ABOVE. To the extent consistentwith applicable law, neitherWillowood, LLC norSeller shall beliable forany incidental, consequential orspecial damages resulting from the use orhandling ofthis product. TO THE EXTENT CONSISTENTWITH APPLICABLE LAW, THE EXCLUSIVE REMEOYOFTHE USER OR BUYER, ANOTHE EXCLUSIVE LIABILITY OFWILLOWOOO, LLCAND SELLER FOR ANY AND ALL CLAIMS, LOSSES, INJURIES OR OAMAGES (INCLUOING CLAIMS BASED ON BREACH OF WARRANTY, CONTRACT, NEGLIGENCE, TORT, STRICT LIABILITY OR OTHERWISE) RESULTING FROM THE USE OR HANDLING OFTHIS PRODUCT, SHALL BE THE RETURN OFTHE PURCHASE PRICE OF THE PRODUCT OR, AT THE ELECTION OF WILLOWOOD, LLC OR SELLER, THE REPLACEMENT OF THE PRODUCT. Wil!owood, LLC and Sellerofferthis product, and Buyerand User accept it, subject to the foregoing Conditions ofSale and Limitation ofWarranty and liability, which may not be modified except by written agreement signed by a duly authorized representative ofWillowood, LLC. EPA 20100422
29

# WiL
WlllOWOOD

# usa Your preferred manufacturerofpost patent products

April 12,2010

To Whom ItMayConcern:
RE: Letterof Authorization
Dear SirorMadam: Please letthis letter serve to confInnthat Pyxis Regulatory Consulting, Inc. is authorized to act as agent for Willowood Clethodim, LLC, before the U.S. Environmental Protection Agency, California Department ofPesticide Regulation Pesticide Registration Branch and other state governmental agencies in all matters regarding our pesticide registrations pursuant to the Federal Insecticide, Fungicide and Rodenticide Act(''FIFRA''), 7U.S.C. § 

### 136 et seq. and state law. Ifyouhave anyquestions, please donothesitateto contactme.
Sincerely,

# ~~)LBrianHeinze

# ~ President/CEO Willowood Clethodim, LLC

cc: Pyxis Regulatory Consulting, Inc.

1600 NWGarden Valley Blvd. Suite 130· Roseburg, OR 97471 ·541.679.9963· FAX541.679.4650.wwwWiliowoodUSA.com

### ) UNITt:O STATES ENVIRONMENTAL PROTECTION AGENCY WASHINGTON, D.C. 20460



### May 5, 2010

OPP DecisionNumber: D-431976 EPAFile Symbol orRegistrationNumber: 87290-1 ProductName: WILLOWOOD OXYFLO EC EPAApplicationReceiptDate: 14-Apr-2010 EPA WaiverRequestReceiptDate: 14-Apr-2010 EPA CompanyNumber: 87290 CompanyName: WILLOWOOD, LLC
JANELLE KAY PYXIS REGULATORYCONSULTING, INC. WILLOWOOD, LLC 4110 1136TH STREET,NW GIG HARBOR, W A 98332-
SUBJECT: Approval of50% Small Business WaiverRequest
DearRegistrant: OFFICE OF PREVENTION. PESTICIDES AND TOXIC SUBSTANCES



### The Office ofPesticidePrograms has approvedyourrequest for 50%waiver ofthe pesticideregistration fee associated withthe actionreferenced above. The decisionreview period for this actionwill beginonthe date ofthis letter.
TheActionhas been identified as Action Code: R300
NEWPRODUCT;ME-TOO PRODUCTFASTTRACK;
Ifyouhave any questions, please contactthe PesticideRegistration ServiceFee Ombudsman, at(703) 305-6249.

Sincerely,

# ~j~~ InformationTechnology & 

### Resources ManagementDivision OfficeofPesticideProgramsUNITED STATES ENVIRONMENTAL PROTECTION AGENCY WASHINGTON, D.C. 20460



### January 29, 2010

OPP DecisionNumber: D-425897 I 

### EPAFile Symbol orRegistrationNumber: 87290-R ProductName: WILLOWOOD ETHOFUMESATE SC EPAApplicationReceiptDate: 08-Jan-2010 EPAWaiverRequestReceiptDate: 08-Jan-2010 EPA CompanyNumber: 87290 CompanyName: WILLOWOOD, LLC
JANELLE KAY PYXIS REGULATORYCONSULTING,INC. WILLOWOOD, LLC 4110 1136TH STREET,NW GIG HARBOR, W A 98332-
SUBJECT: Approval of50% SmallBusiness WaiverRequest
DearRegistrant: OFFICE OF PREVENTION, PESTICIDES AND TOXIC SUBSTANCES



### The Office ofPesticideProgramshas approvedyourrequestfor 50%waiver ofthe pesticideregistration fee associatedwiththe actionreferenced above. The decisionreview period for this actionwillbegin onthe date ofthis letter.
TheActionhas been identified as Action Code: R300
NEWPRODUCT;ME-TOO PRODUCTFASTTRACK;
If

### youhave any questions, pleasecontactthe Pesticide Registration ServiceFee Ombudsman, at (703) 305-6249.

# ~~fu>y OscarMorales, Director InformationTechnology & 

### Resources Management Division Office ofPesticide Programs

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Created August14,2008

### U.S. ENVIRONMENTAL PROTECTION AGENCY Office ofPesticidePrograms Registration Division (7505P) Ariel Rios Building 1200 PennsylvaniaAve., NW

Washington, D.C. 20460 NOTICE OF PESTICIDE: L 

### Registration

_ Reregistration (underFIFRA, as amended) EPA Reg. Number: Date ofIssuance: 

### 87290-1

Tenn ofIssuance: rrYnt1iti,,""l

Name ofPesticide Product: 

### Willowood Ethofumesate SC Name andAddress ofRegistrant ZIP Code): Willowood,LLC 8690 Lookingglass Road Roseburg, OR97471

On the basis ofinfonnation furnished bythe registrant, the above namedpesticide is herebyregistered/reregisteredunderthe Federal Insecticide, Fungicide and Rodenticide Act. Registration is inno way to be construed as an endorsement orrecommendation ofthis productbythe Agency. In order to protecthealth andthe environment, the Administrator, on his motion, may at anytime suspend or cancel the registration ofa pesticide in accordance with the Act. The acceptance ofany name in connectionwith the registration ofaproduct underthis Act is notto be construed as giving the registrant a rightto exclusive use ofthe name orto its use ifithas been covered by others.


### The 'BasicFormulation' dated 

### IIS/2010 is acceptable. This product is conditionallyregistered in accordance with FIFRAprovided thatyou:
I. Submitand/orcite all datarequired forregistration review/reregistration ofyourproductwhenthe Agencyrequires allregistrants ofsimilar productsto submit data.
2. Submitthe data listed below:

a. Within one year ofthe date onthis registration notice, Storage Stability(830.6317) and Corrosion Characteristics (830.6320) studies mustbe submitted. It

### is recommended thatthe observations be made at 0, 3, 6, 9, and 12 month intervals.
3. Make the following labelrevisions: a. Revise "EPAREG. NO.87290-"to "EPAREG. NO. 87290-1"
b. Revise "Handlers

..." to "Mixers and loaders

..." inthe first sentence ofthe engineering controls for on-site mixing and loading.

c. Add "orrinsate" after "washwaters" in the last sentence ofthe Environmental Hazards statement.

Continuedon Page 2
Signature 

### KathrynV. Monta:¢eiV ProjectManager Herbicide Rr:mchV 

### RegistrationDivision

### (7505P) Date:

### Page 2 EPAReg. No. 87290-1 Notice ofRegistration

d. Revise the first sentence ofthe 'UsePrecautions' section onpg. 2to read as follows: "WillowoodEthofumesate SC ortankmixes mustbe used for label listed purposes and at labelspecified rates only."

e. Perthe Ethofumesate RED, makethe following revisions tothe 'AgriculturalUse Requirements' box on pg. 3: 1. Removethe period afterthe sentence "Donot enter or allow

...12 hours" and add "forall crops, exceptturfgrown for sod. The REI for turfis 9 days. TheREI for each crop is listed in the directions for use associated with each crop." 2. Addthe WPS DoubleNotification Statement: "NotifYworkers ofthe applicationbywarning them orallyand bypostingwarning signs at entrances totreated areas."
£ Removethe word "General" from all label sectionheadings (e.g. General Information, General Application) as this term is an implied safety claimthatmakes all associated textunenforceable. "General"may be replaced with "Product"where applicable.
g. Replace all instances of"recommendedrates" with "label-listedrates" or "specifiedrates." Recommendations arenot enforceable. See: Last sentence onpg. 7 Every "DONOTOVERTREAT

..." sentence throughoutthe label First sentence, second paragraph on pg. 27
h. Addthe followingrate restriction abovethe 'Precautions' section for sugarbeets on pg. 4: "AerialApplication Rate Restriction: Donot applymorethan 1.5 

### Ib ai 

### (3 pints ofproduct) per



### acre with 

### aircraft."
i. Replace "Nomore than atotal of1 gallon ofWillowoodEthofumesate SC shouldbe applied in a single growing season." onpages 4 and 10 withthefOllowing: "Donotapplymorethan 3.75 Ibs ai (7 pints ofproduct) per acre per season for sugarbeets." In addition, revise the heading "Precautions"with "PrecautionslRestrictions." j. 

### Replace "96 fluid ounces (0.75 gallon) ofproductperseason" with "2.6 lbs ai (80 ounces of product) per acre per season." belowthetable onpage 18.
k. On page 18, replacethe heading "Precautions"with "RateRestriction" and add, "Donot apply more than 1.9 lbs ai (3 pints ofproduct) per acreperpre-emergentapplicationtotable beets." Delete "Nomorethan atotal of0.75 gallon of

...in a single growing season."


### 1. Addthe following rate restriction for post-emergent application totable beets on page 19: "Post-emergentapplication Rate Restriction: Donot apply more than 0.33 lb ai 

### peracreper

application."

m. Delete "Nomorethan atotal ofI gallon ofWillowoodEthofumesate SC should be applied in a single growing season." onpg. 21 as it conflicts withthe maximum use rates for onion, garlic and shallot.

Continuedonpage 3

### Page 3 EPAReg. No. 87290-1 Notice ofRegistration

n. Revise all instances of"3 %

### pints peracre"to "3 pints peracre" in the 'New Seedlings ofAnnual orPerennialRyegrass' sections on page26, the 'New Seedlings ofFall-Planted Perennial Ryegrass and Tallfescue treated with Diuron Plus Charcoal' sections on page 27, and the 'Established Stands ofPerennial Ryegrass and Tall Fescue' sections onpage 27 since '3 % 

### pints' exceedsthe maximumuserate of1.5 Ibs ai/acre/season.

o. Replace "DONOT applymore than I gallon ofWillowood Ethofumesate SC per acre per growing season" on page 29 withthe following: "Donotapplymorethan 1.5 Ibs ai (3 pints ofproduct) peracreper season for perennial ryegrass and tall fescue sod."
4. Submitone (1) copy ofthe revised final printed label forthe record.

Ifthese conditions are not complied with, theregistrationwill be subjectto cancellation in accordance with FIFRA sec. 6(e). Yourrelease for shipmentoftheproductconstitutes acceptance ofthese conditions. A stamped copy ofthe label is enclosed for yourrecords.

Enclosure

# Willowood Ethofumesate SC Suspension Concentrate BROAD SPECTRUM HERBICIDE for selective control of weeds in sugar beets, garden beets, onions, garlic, shallots (in all states) and carrots in Washington and Oregon only. GRASS SEED HERBICIDE for selective control of weeds in certain grass seed crops and commercial sod production in California, Idaho, Nevada, Oregon and Washington.
ACTIVE INGREDIENT: Ethofumesate (2-ethoxy-2. 3-dihydro-3. 3-dimethyl-5-benzofuranyl methanesulfonate)

.. 

### OTHER INGREDIENTS:

.................................. TOTAL:..................

......................... ....................... This product contains 4.0 Ibs. active ingredient per gallon. 

## KEEP OUT OF REACH OF CHILDREN 

# CAUTION

FIRSTAID % by Weight

..... 42.0%

..... 58.0%

.100.0%



### Ifswallowed: 

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

## • Have person sip a glass ofwater ifable to swallow. 

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

## • Do not Qive anythinQ by mouth to an unconscious person. 

### In inhaled: 

## • Move person to fresh air. 

## • If person is not breathing, call 911 or an ambulance, then give artificial respiration, preferably by mouth-to-mouth, if possible. 

## • Call a poison control center or doctorfor further 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. 

### Ifon skin or 

## • Take offcontaminated clothing. 

### clothing: 

## • Rinse skin immediately with plenty ofwater for 15-20 minutes. 

## • Call a poison control center or doctorfor treatment advice. HOT LINE NUMBER 

### Have the product container or label with you when calling a poison control center or doctor, or going for treatment. For emergency information concerning this product, call the National Pesticides Information Center (NPIC) at 1-800-858-7378 seven days a week, 6:30 am to 4:30 pm Pacific Time or your poison control center at 1-800-222-1222.


### EPA Reg. No. 

### 87290- Manufactured for: Willowood, LLC 8690 Lookingglass Road 

## ACCEPTE"" Roseburg, OR 97471 

### u 

### witbCOMMENTS hn EPA**Lette~**

### Daterll:

Underthe federall" ·,icide, 

### Fungicide,and 

### Roder,;;cideActNet 

### Contents: as

### amended, forthepesticide registeredunder

### EPAReg.No. 

### EPA Est. No.

) r j >

### PRECAUTIONARY STATEMENTS HAZARDS TO HUMANS AND DOMESTIC ANIMALS CAUTION Harmful ifswallowed or inhaled. Avoid breathing vaporor spray mist. PERSONAL PROTECTIVE EQUIPMENT (PPE) Some materials that are chemical-resistant to this product are polyethylene or polyvinyl chloride. If you want more options, follow the instructions for category A on an EPA chemical-resistance category selection chart. All mixers, loaders, applicators and other handlers mustwear: • Long-sleeved shirt and long pants • Chemical-resistant gloves (except flaggers, or applicator in cockpits, and enclosed cabs) • Shoes plus socks See Engineering Controls for additional requirements. On-Site Closed Mixing and Loading System Engineering Controls for Liquid Formulations for Commercial Dry Bulk Fertilizer Impregnation Handlers must use a closed system designed by the manufacturer to provide dermal and inhalation protection to enclose the pesticide to prevent it from contacting handlers or other people AND the system is functioning properly and is used and maintained in accordance with the manufacturer's written operating instructions. The handlers:

• Must wear PPE listed on this label • Must wear protective eyewear ifthe system operates under pressure • Must have immediately available for use in an emergency, such as a spill, or equipment breakdown, chemical resistant footwear and chemical resistant apron Follow manufacturer's instructions for cleaning/maintaining PPE. If no such instructions for washables exist, use detergent and hotwater. Keep and wash PPE separately from other laundry. ENGINEERING CONTROLS STATEMENT When handlers use closed systems, enclosed cabs, or aircraft in a manner that meets the requirements listed in the Worker Protection Standard (WPS) for agricultural pesticides [40 CFR 170.240 (d) (4-6)], the handler PPE requirements may be reduced or modified as specified in the WPS. 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)]. USER SAFETY REQUIREMENTS 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 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. Do not apply directly to water, or to areas where surface water is present, or to intertidal areas below the mean high water mark. Drift and runoff may be hazardous to aquatic organisms in water adjacent to treated areas. Do not contaminate water when disposing of equipment washwaters. USE PRECAUTIONS Willowood Ethofumesate SC or tank mixes should be used for recommended purposes and at recommended rates only. (DO NOT OVERTREAT). Do not graze livestock on treated crops.



### 2

### Do not apply this product through any type of irrigation system. Ifcrop is lost due to climatic or soil conditions following application ofWillowood Ethofumesate SC or tank mixes, do not plant crops other than sugar beets or ryegrass in treated land during the same season. Do not retreat field with Willowood Ethofumesate SC. If fields are replanted to sugar beets, reseed into treated band. Do not rotate with any crops other than sugar beets or ryegrass for:

• 12 months following preplant incorporated, preemergence, conventional postemergence applications, or split (low rate) applications totaling more than 12 fl. oz. (0.375 lb. ai/acre); • 6 months following split (low rate) postemergence applications totaling 12 fl. oz. (0.375 lb. ai/acre) or less. Thorough tillage, including moldboard plowing, should precede the planting of crops other than sugar beets or ryegrass. Do not use Willowood Ethofumesate SC on muck or peat soils. Do not allow spray mixture to stand in tank overnight. Flush and drain spray equipment after each day's use. Store unused spray mixture in tightly-sealed containers and protect from frost. This label must be in the possession ofthe user at the time ofpesticide application. 

### DIRECTIONS FOR USE It is aviolation of Federal law to use this product in a manner inconsistentwith its labeling. Read entire Directions for Use and Condition of Sale and Limitation ofWarranty and Liability before using this product. Do not apply this product in a way that will contact workers or other persons, e'lther directly or through drift. Only protected handlers may be in the area during application. For any requirements specific to your State or Tribe, consult the agency responsible for pesticide regulation. SHAKE CONTAINERWELL BEFORE USING. 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 ofagricultural workers on farms, forests, nurseries, and greenhouses, and handlers of agricultural pesticides. It contains requirements for training, decontamination, notification, and emergency assistance. It also contains specific instructions and exceptions pertaining to the statements on this label about personal protective equipment (PPE), and restricted-entry interval. The requirements in this box only apply to uses of this product that are covered by the Worker Protection Standard. Do not enter or allowworker entry into treated areas during the restricted entry interval (REI) of 12 hours. Exception: If the product is soil-injected or soil-incorporated, the Worker Protection Standard, under certain circumstances, allows workers to enter the treated area if there will be no contact with anything that has been treated. PPE required for early entry to treated areas that is permitted under the Worker Protection Standard and that involves contact with anything that has been treated, such as plants, soil, orwater, is:
• Coveralls • Chemical-resistant gloves made ofanywaterproof material • Shoes plus socks SPRAY DRIFT MANAGEMENT This chemical can contaminate surface water through spray drift. A variety of factors including weather conditions (e.g. wind direction, wind speed, temperature, relative humidity) and method ofapplication (e.g. ground, aerial) can influence pesticide drift. The applicator must evaluate all factors and make appropriate adjustments when applying this product. Wind Speed

- 

### Do not apply when wind speeds are greaterthan 15 mph.


### 3Temperature Inversions - 

### Do not make applications into areas of temperature inversion or stable atmospheric conditions.


### SUGAR BEETS
GENERAL INFORMATION Willowood. Ethofumesate SC is a selective herbicide for use in sugar beets for the control of the weed species listed below. It provides effective control ofthese weeds for up to 10 weeks following application. Residual control of weeds is dependent upon soil moisture conditions; rate of herbicide used, and soil texture. The 

### activity ofWillowood Ethofumesate SC in the soil is reduced as the soil texture becomes finer and organic matter increases. PRECAUTIONS 

### Following a preemergence treatment ofWillowood Ethofumesate SC, do not apply conventional rates of Willowood Ethofumesate SC postemergence where more than 6 pints were applied preplant or preemergence. No more than a total of 1 gallon of Willowood Ethofumesate SC should be applied in a single growing season. See Use Precautions 

### for additional information on proper use. WEED SPECIES CONTROLLED Annual BroadleafWeeds Annual Grass Weeds 

### Black nightshade Solanum nigrum 

### Annual bluegrass Poa annua 

### Common Stellaria media 

### Barnyardgrass' Echinochloa crus-galli 

### chickweed Common Chenopodium album 

### Canarygrass Pha/aris canariensis 

### lambsquarters Common purslane Portulaca oleracea 

### Green foxtail Setaria viridis 

### Kochia Kochia scoparia 

### Large crabgrass Digitaria sanguinalis 

### Ladysthumb Polygonum persicaria 

### Volunteer barley Hordeumsp. 

### Pennsylvania Polygonumpennsylvanicum 

### Volunteer wheat Triticum sp. 

### smartweed Redroot pigweed Amaranthus retroflexus 

### Wild oats" Avena fatua 

### Russian thistle Sa/so/a kali var. tenuifolia 

### Yellow foxtail Setaria glauca 

### Wild buckwheat Polygonum convolvulus



### • Control of barnyardgrass may be reduced with the Willowood Ethofumesate SC + 

### Pyramln® tank mix because ofthe lower rate of

### Willowood Ethofumesate SC recommended

. •• Control ofwild oats has been inconsistent in Minnesota and North Dakota. Willowood Ethofumesate SC alone will also reduce competition from these HARD-TO-CONTROLweeds: 

### Annual Sowthistle Sonchus oleraceus 

### Puncturevine Tribulus terrestris 

### Shepherdspurse Capsella bursa-pastoris 

### Purple nutsedge Cyperus rotundus 

### Yellow nutsedge Cyperus esculentus 

### Apply tank mixes only in specific regions orStates and in accordance with directions on label. PREPLANT INCORPORATED AND PREEMERGENCE APPLICATIONS



### 4

### SOIL PREPARATION: 

### The soil should be prepared according to good agricultural practices. Large clods can reduce the effectiveness of Willowood Ethofumesate SC and tank mixes. All existing vegetative growth should be thoroughly worked into the soil before treatment. SPRAY EQUIPMENT: 

### Apply Willowood Ethofumesate SC alone or in tank mixes to the soil using standard low pressure (20 to 50 psi) spray equipment. Spray equipment should be carefully calibrated before use and checked frequently during application to see that it is functioning properly. Do not use smaller than 50-mesh strainer. Uniformly apply the recommended rates ofWillowood Ethofumesate SC or tank mixes in 10 to 60 gallons of water per acre on a broadcast basis. Avoid overlaps since crop injury may result. When applying Willowood Ethofumesate SC or tank mixes in a band; check to make certain that the band width is accurate forthe dosage rate being applied. The spray tank and lines should be thoroughly cleaned and rinsed priorto using Willowood Ethofumesate SC. INCORPORATION EQUIPMENT: 

### Where soil incorporation is recommended, use a hooded power- or ground-driven rotary tiller, rolling cultivator, or similar equipment property adjusted to uniformly incorporate Willowood Ethofumesate SC or tank mixes to a depth of 1 to 2 inches. Deeper incorporation may reduce effectiveness. Do not apply Willowood Ethofumesate SC or tank mixes through soil injector shanks. Incorporation should be accomplished prior to planting. If done after planting, proper precautions should be taken to avoid damaging or moving the crop seed. See below for Layering Application. LAYERING APPLICATION: 

### Spring: Form beds with appropriate bedding equipment. Pre-irrigate field if necessary. Remove bed top with suitable de-ridging machinery to provide a minimum width of 10" across the top ofthe bed. Apply Willowood Ethofumesate SC in a band at the recommended rate indicated in the appropriate regional dosage table and cover the treated band with 1 inch of soil using ditchers or discs equipment. Shape the bed with roller shaper and irrigate until the tops ofthe beds are thoroughly wetted. Irrigate from furrows on both sides ofthe row. Fall: This method ofapplication can be used when spring moisture is marginal orwhere irrigation water is not available at planting time. Fall bedding utilizes the winter-accumulated moisture to enhance activation ofthe herbicide and to aid in germination ofthe sugar beet crop. Prepare the field (as for planting; plow; pack, and float, etc.), in the fall, usually late September or October. Apply Willowood Ethofumesate SC in a band to the soil surface at the recommended rate indicated in the appropriate regional dosage table. Be sure that the soil surface to be treated is free of trash and vegetation. Cover the treated bands with soil and form beds or ridges using ditchers or discs. In the spring when the soil is sufficiently dry to be worked, de-ridge the beds down to within 1/2" 

### to 1" of the treated layer using suitable equipment such as the Kirchner bedder or Oregon Northslope harrow. When de-ridging, maintain the original bedding guidance system by using a bull tongue chisel, slide guides or similar equipment. This will ensure that the planter will follow in the treated band. Plant sugar beets in the de-ridged area when the soil conditions allow. GENERAL APPLICATION Sugar 

### beets grown under 

### rainfall: Apply Willowood Ethofumesate SC alone or in a tank mix preemergence at time of planting or shortly after, but prior to weed germination. Willowood Ethofumesate SC or tank mix does not require mechanical soil incorporation provided that sufficient rainfall occurs shortly following application to activate the chemical. One-half inch of rainfall is usually adequate for activation. In areas where rainfall can be marginal for activation, such as the Red RiverValley (Minnesota and North Dakota), It is recommended that Willowood Ethofumesate SC or the tank mix be applied before orat the time of planting and incorporated into the soil. Sugar 

### beets grown under 

### furrow irrigation: Apply Willowood Ethofumesate SC alone or in a tank mix to the soil surface preplant or at time of planting, but prior to weed germination, and incorporate into the soil. Where sugar beets are grown in beds, apply Willowood Ethofumesate SC or tank mix after bedding and incorporate. Since Willowood Ethofumesate SC or tank mix must have moisture to control weeds effectively, irrigate until tops of beds are thoroughly wetted. Sugar 

### beets grown under sprinkler 

### irrigation: Apply Willowood Ethofumesate SC alone or in a tank mix preemergence at time of planting or shortly after, and irrigate prior to crop and weed germination. Repeat irrigation as necessary to maintain good moisture in upper soil layer. Apply at least one-half inch
5

### of water during first irrigation. Do not mechanically incorporate Willowood Ethofumesate SC or tank mix into the soil under sprinkler irrigation. Cultural Practices Following Application: 

### Wihen properly applied, Willowood Ethofumesate SC alone or in a tank mix will provide up to ten weeks control of susceptible weed species. When cultivating fields in which Willowood Ethofumesate SC or tank mixes have been banded, care should be exercised to minimize the movement of untreated soil into the treated band. Where a broadcast application has been made, do not CUltivate deeper than two inches, as this reduces the effectiveness of Willowood Ethofumesate SC or tank mixes.

Soil Texture
Coarse Textured Soils: 

### Sands, loamy sands and sandy loams Medium Textured Soils: 

### Silt loams, clay loams which contain less than 3% organic matter

Fine Textured Soils: 

### Silt loams, clay loams, clays which contain more than 3% organic matter WILLOWOOD ETHOFUMESATE SC ALONE DOSAGE TABLE 1 (All Regions Except North Dakota and Minnesota): Rate ofWillowood Ethofumesate SC perAcre
7-inch Band Width' Broadcast 22" Row 28" Row 30" Row



### 2 1/4 

### to 3 3/4 3/4 

### to 1 1/4 2/3 

### to 1 1/2 

### to 1 Pints Pints Pint Pint

3314 

### to 6 1 1/4 

### to 2 1to 1 1/2 

### 1to 1 3/4



### Pints Pints Pints Pints

6 to 7 1/2 2t021/2 11/2t02 11/2t013/4 

### Pints Pints Pints Pints



## , Use the higher rate Within each SOil texture category on the finer texture SOils andlor where Kochla, barnyardgrass or black nightshade are expected to be a problem.

2 

### For other band or row widths, adjust the rate in proportion to the area actually treated. DOSAGE TABLE 2 (North Dakota and Minnesota only): Willowood Ethofumesate SC perAcre Soil Texture Broadcast 7-inch Band Width' 22" Row
Coarse Textured Soils: 

### Sandy 6 Pints 2 Pints loams only Medium Textured Soils: 

### Silt 6 Pints 2 Pints loams and clay loams Fine Textured Soils: 

### Heavy 7 1/2 

### Pints 2 1/2 

### Pints clays

For other band or row Widths, adjust the rate In proportion to the area actually treated.



### 6

### WILLOWOOD ETHOFUMESATE SC 

### + PYRAMIN® (TANK MIX) This tank mix control these additional broadleafweeds: Annual sowthistle Sonchus oleraceus 

### Black mustard Brassica nigra 

### Buffalobur Solanum rostratum 

### Coast fiddleneck Amsinckia intermedia 

### Common groundsel Senecio vulgaris 

### Common ragweed Ambrosia artemisiifolia 

### Cutleaf nightshade Solanum triflorum 

### Groundcherry Physalis spp. 

### Henbit Lamium amplexicaule 

### Nettleleafgoosefoot Chenopodium murale 

### Prickly lettuce Lactuca serriola 

### Prostrate knotweed Polygonum aviculare 

### Shepardspurse Capsella bursa-pastoris 

### Mixing Directions: When mixing Willowood Ethofumesate SC in the spray tank with Pyramin, fill the spray tank with 1/2 

### of the total amount of water to be used and add Willowood Ethofumesate SC first. Agitate spray solution thoroughly and continuously. See Pyramin label for additional mixing directions. CALIFORNIA (winter-grown sugar beets only): 

### Under sprinkler irrigation or where natural rainfall is adequate, apply this tank mix preemergence. See Pyramin label for precautions regarding application of sprinkler irrigation. Where furrow irrigation is to be used, apply preplant incorporated. Prepare seedbed or form beds for planting. Then use rotary tiller type of incorporation and incorporate not more than 2 inches deep. Plant sugar beets and irrigate. Sub-irrigate until tops of beds are thoroughly wetted. Refer to Dosage Table 

### 3for recommended rates. DOSAGE TABLE 3 (California, winter-grown sugar beets only): Willowood Ethofumesate SC per PYRAMIN DF per Acre Acre Soil Texture Broadcast 10-inch Band Broadcast 10-inch Band (For calibration Width'" (For calibration Width purposes only) 30" Row purposes only) 30" Row Coarse Textured SoilS: Sands, loamy NOT RECOMMENDED sands and sandy loams Medium Textured 3t031/4 

### 1to 1 1/4 4 1/2 

### 1 1/2 

### Soils: Silt loams, clay Pints Pints Pounds Pounds loams which contain less than 3% organic matter Fine Textured Soils: 4to 5 1/4 

### 1 1/3 

### to 1 3/4 4 1/2 

### 1 1/2 

### Clay loamswith contain Pints Pints Pounds Pounds more than 3% organic matter and clays

71 

### For other brand or row widths, adjust rates in proportion to the area actually treated. Do not apply this mixture broadcasl.

2 

### Use the higher rate of Willowood Ethofumesate SC within each soil texture category on the finertextured soils andlorwhere volunteer barley orwheat are expected to be a problem. Precautions: Do not exceed 3/4 

### inch of sprinkler irrigation per set until the beets have two true leaves. Do not use the tank mix under conditions where Pyramin alone is not recommended. Before use, read the Pyamin label for additional information and precautions. CENTRAL AND EASTERN STATES, INCLUDING MICHIGAN AND OHIO: This tank mix controls the additional weed, common ragweed, and other broadleaf weeds speCified in the weed table. Apply preemergence at the time of planting or shortly after, but before weed germination, using recommended rates listed in Dosage Table 

### 4. Do not mechanically incorporate the herbicides into the soil as crop injury may resull. Do not use this tank mix where Pyramin alone is not recommended. Before use, read Pyramin label for additional information and precautions. DOSAGE TABLE 4 (Central and Eastern States Only): Willowood Ethofumesate SCI

### Acre PYRAMIN FLlAcre Soil Texture Broadcast 7-inch Band Width Broadcast 7-inch Band Width' 22" Row 28" Row 22" Row 28" Row

Coarse Textured 

### 3 1 3/4 

### 2 1/4 3/4 1/2 

### Soils: Sandy loams Pints Pint Pint Qts. QI. QI. only Medium Textured 

### 4 1 1/4 

### 1 3 1 3/4 

### Soils: Silt loams, clay Pints Pints Pint Qts. QI. QI. loams which contain less than 3% organic matter Fine Textured Soils: 

### 5 1 1/2 

### 1 1/4 

### 3 

### 1 3/4 

### Clay loams which Pints Pints Pints Qts. QI. Qt 

### contain more than 3% organic matter and clays



## ,For other band or row wIdths, adjust the rate In 

### proportIon to the area actually being treated. Preplant and Preemergence Use Precautions Willowood Ethofumesate SC applied alone or in tank mixes according to label directions and under normal growing conditions may cause temporary leaf fusion, distortion and stunting. Crop injury may occur during early growth when crop is stressed due to herbicide residue carryover, highly saline or alkaline soils, unusually cold and wet weather or improperly placed fertilizers or soil insecticides. Unusually dry, windy weather, which dries the upper soil layer, following application of Willowood Ethofumesate SC, may reduce effectiveness. DO NOT OVERTREAT: The use of higher than recommended rates may cause beet injury and/or carry over problems. Crop Planting Precautions: If crop is lost due to unfavorable growth conditions following treatment, do not replant with crops other than sugar beets or ryegrass in treated land during the same season. Iffields are replanted to sugar beets, reseed into treated band. Do not retreat field with conventional rates of Willowood Ethofumesate SC in the same season. Postemergence Application General Information


### 8

### The tank mixes of Willowood Ethofumesate SC plus Betamix® or Betanex® Herbicides applied postemergence broaden and enhance the control of weeds. The choice of tank mixes is dependent upon weed species present. Wllowood Ethofumesate SC alone is not recommended for postemergent use. Tank mixes of Willowood Ethofumesate SC plus Betamix® or Betanex® applied postemergence control the following weeds: Annual BroadleafWeeds 

### Annual sowthistle Sonchus o/eraceus 

### Black nightshade Solanum nigrum 

### Hairy nightshade Solanum sarrachoides 

### Coast fiddleneck Amsinckia intermedia 

### Common chickweed Stellaria media 

### Common lambsquarters Chenopodium album 

### Common ragweed Ambrosia artemislifolia 

### Groundcherry Physalis lanceifolia 

### Kochia* Kochia scoparia 

### Ladysthumb Polygonum persicaria 

### London rocket Sisymbrium irio 

### Nettleleafgoosefoot Chenopodium murale 

### Pennsylvania smartweed Polygonum pennsylvanicum 

### Prostrate pigweed Amaranthus gracizans 

### Redroot pigweed Amaranthus retroflexus 

### Purslane Portulaca oleraceus 

### Shepherdspurse Capsella bursa-pastoris 

### Wild buckwheat Polygonurn convolvulus 

### Wild mustard Brassica kaber 

### *Spray kochla while In 

### the rosette stage, less than one Inch in diameter. Annual Grass Weeds 

### Annual bluegrass Poa annua 

### Canarygrass Pha/aris canariensis 

### Additionally, atank mix ofWillowood Etholumesate SC plus Betamix® applied postemergence also controls the following annual grass weeds: Green foxtail Setaria viridis 

### Pigeon grass (Yellow foxtail) Setaria glauca Mixing the Spray: 

### Add Willowood Ethofumesate SC to the water in the spray tank followed by Betamix® or Betanex® while agitating the spray solution thoroughly. Refer to the Betamix® or Betanex® labels for additional precautions and information on mixing. Spray Equipment: 

### Apply the mixture using standard low pressure (20-60 psi) spray equipment. Ensure that the sprayer is thoroughly clean. Spray equipment should be carefully calibrated before use and checked frequently during application to see that it is functioning properly. Uniformly apply the recommended rate in 20-60 gallons of water per acre on a broadcast basis or 5-10 gallons of water per acre in a band. Avoid overlaps, since crop injury may result. When applying in a band, check to make


### 9

### certain that the band width is accurate for the dosage rate being applied. Do not use strainer smaller than 50-mesh. Moisture Following Application/Residual Weed Control: 

### Rainfall or sprinkler irrigation within 6 hours of spraying may reduce weed control; however, with conventional rates, moisture after this period oftime is advantageous for moving Willowood Ethofumesate SC into the top layer of soil where it can be absorbed by the roots of sprayed and germinating weeds to provide optimum control. One-half inch or more ofsprinkler irrigation is required to activate Willowood Ethofumesate SC on most soil types. Residual control of weeds is dependent upon soil moisture conditions; rate of herbicide used, and soil texture. The activity ofWillowood Ethofumesate SC in the soil is reduced as the soil texture becomes finer and organic matter increases. Precautions 

### Following a preemergence treatment of Willowood Ethofumesate SC, do not apply conventional rates of Willowood Ethofumesate SC postemergence where more than 6 pints were applied preplant or preemergence. No more than a total of 1 gallon of Willowood Ethofumesate SC should be applied in a single growing season. See Use Precautions 

### foradditional information on proper use. Split (Low Rate) Applications 

### Split (low rate) applications ofWillowood Ethofumesate SC + 

### Betamix® or Betnex® Herbicides may be applied to sugar beets to control early geminating weeds (the tank mix of Willowood Ethofumesate SC 

### + Betanex® may be used in all sugar beet areas except California). The first spray must be applied when the earliest emerging weeds have reached cotyledon size. See Dosage Table 5 for broadcast rates. See Dosage Table 6 and 7 for equivalent band rates. For band applications, apply in 5-10 gallons ofwater per acre. Any weeds which are not completely controlled by the first treatment will usually be checked and controlled by repeat applications. The repeat application should be made 5 to 7 days after the preceding application or when another flush of weeds germinates. If second application is delayed, conventional applications as described below will be necessary. DOSAGE TABLE 5 DOSAGE CHART FOR BROADCAST APPLICATION Sugar Beet Pints/Acre Broadcast Stage WILLOWOOD ETHOFUMESATE SC + BETAMIX® WILLOWOOD ETHOFUMESATE SC + BETANEX® 

### Cotyledon 0.25 + 

### 1.50 0.25 + 

### 1.50 2 Leaf 0.33 + 

### 2.00 0.33 + 

### 2.00 4 Leaf 0.50 + 

### 3.00 0.50 + 

### 3.00
DOSAGE TABLE 6 BETAMIX® OR BETANEX® DOSAGE CHART FOR BAND APPLICATION Broadcast BAND RATE - ROW SPACING Band Width Equivalent 

### 22" 28" 30"


### 1.5 pints/acre 5" 5.5 fl.oz. 4.3 fl. oz. 4.0 ft. oz. 

### 7" 7.6 fl.oz. 6.0 fl oz. 5.6 fl. oz. 2.0 pints/acre 5" 7.3 fl.oz. 5.7 fl.oz. 5.3 fl.oz. 

### 7" 10.2 fl.oz. 8.0 fl.oz. 7.5 fl.oz. 3.0 pints/acre 5" 10.9 fl.oz. 8.6 fl.oz. 8.0 fl.oz. 

### 7" 15.3 ft.oz. 12.0 fl.oz. 11.2 fl.oz. DOSAGE TABLE 7 WILLOWOOD ETHOFUMESATE SC DOSAGE CHART FOR BAND APPLICATION
Broadcast BAND RATE - ROW SPACING Equivalent Band Width 

### 22" 

# I 28" 

# I 30"



### 10Broadcast BAND RATE - ROW SPACING Equivalent BandWidth 

### 22" 

### 28" 

### 30"
0.25 pints/acre 5" 0.9 fl.oz. 0.7fl.oz. 0.7 fl. oz. 

### 7" 1.3 ft.oz. 1.0 fl oz. 0.9 fl. oz. 0.33 pints/acre 5" 1.2 fl.oz. 0.9 fl.oz. 0.9 fl.oz. 

### 7" 1.7fl.oz. 1.3 fl.oz. 1.2 fl.oz. 0.5 pints/acre 5" 1.8 fl.oz. 1.4 fl.oz. 1.3 fl.oz. 

### 7" 2.5 fl.oz. 2.0 fl.oz. 1.9 fl.oz. Conventional Applications Timing of Application: 

### Apply the tank mix Willowood Ethofumesate SC 

### + Betanex® or Willowood Ethofumesate SC + 

### Betamix® when sugar beets have 

### at least 4 fully expanded true leaves. 

### Apply at rates recommended in the Dosage Tables. Use the higher rate of Willowood Ethofumesate SC where increased residual weed control is desired. Where Eptam® has been applied preplant (fall or spring applied); do not apply Willowood Ethofumesate SC 

### + Betamix® or Betanex® tank mix before the sugar beets have 

### 6 expanded true leaves. 

### See Postemergence Use Precautions 

### for additional information on proper use. WILLOWOOD ETHOFUMESATE SC + BETAMIX® (TANK MIX) 

### Willowood Ethofumesate SC applied postemergence in a tank mix with Betamix® Herbicide broadens and enhances the control of troublesome weeds. Furthermore, preemergence control of susceptible weeds which may germinate following treatment can be obtained provided overhead moisture is sufficient to activate 

### Willowood Ethofumesate SC. WEED SPECIES CONTROLLED Group I: Weeds controlled up to the 6-leafstage. 

### Redroot Pigweed Amaranthus retroflexus 

### Wild mustard Brassica kaber 

### Nettleleafgoosefoot Chenopodium murale 

### London rocket Sisymbrium irio 

### Common lambsquarters Chenopodium album Group II: Weeds controlled up to the 4-leaf stage. 

### Common chickweed Stel/aria media 

### Black nightshade Solanum nigrum 

### Common ragweed Ambrosia artemisiifolia 

### Shepherdspurse Capsel/a bursa-pastoris 

### Groundcherry Physalis lanceifolia 

### Pennsylvania smartweed Polygonum pennsylvanicum 

### Ladysthumb Polygonum persicaria 

### Prostrate pigweed Amaranthus blitoides 

### Coast fiddleneck Amsinckia intermedia Group III: Weeds controlled up to the 2-leaf stage 

### Annual sowthistle Sonchus oleraceus 

### Kochia* Kochia scoparia 

### Common purslane** Portulaca oleracea



### 11

### WEED SPECIES CONTROLLED Prostrate knotweed Polygonum aviculare 

### Wild buckwheat Polygonum convolvulus 

### Green foxtail*** Setaria viridis 

### Yellow foxtail (pigeongrass)*** Setaria glauca 

### Annual bluegrass*** Poa annua 

### Canarygrass*** Phalaris canariensis 

### "

. * Spray kochla while In the rosette stage, less than 1 In diameter. **Group II weed in California ***For best control, overhead moisture required. DOSAGE TABLE 8 Rate ofWillowood Ethofumesate SC Per Acre' Rate of Betamix® PerAcre'

Broadcast Band' Row Spacing Broadcast Band' Row Spacing Rate Width Rate Width (in.) 22" 

### 28" 30" 

### (in.) 22" 28"

2 114

- 

### 3 3/4-1 1/2- 1/2-2/3 4 1/2

- 

### 6 1 1/2-2 1-1 1/2



### Pints 

### 7 Pint 3/4 

### Pint Pints 

### 7 Pints Pints Pint Use the higher rate on largerweeds and sugar beets. 2 

### For other band or row widths, adjust rates in proportion to the area actually treated. WILLOWOOD ETHOFUMESATE SC 

### + BETANEX® (TANK MIX) 30"

1 1/3 

### Pints

ALL AREAS EXCEPT CALIFORNIA: Willowood Ethofumesate SC applied postemergence in a tank mix with Betanex® Herbicide broadens and enhances control of troublesome weeds. Furthermore, preemergence control of susceptible weeds which may germinate following treatment can be obtained provided overhead moisture is sufficient to activate Willowood Ethofumesate SC. WEED SPECIES CONTROLLED Group I: Weeds controlled upto the 6-leafstage. Redroot pigweed Amaranthus retroflexus 

### Wild mustard Brassica kaber 

### Net!leleafgoosefoot Chenopodium murale 

### London rocket Sisymbrium irio 

### Common lambsquarters Chenopodium album 

### Group II: Weeds controlled upto the 4-leafstage Common chickweed Stellaria media 

### Black nightshade Solanum nigrum 

### Common ragweed Ambrosia artemisiifolia 

### Shepherdspurse Capsefla bursa-pastoris 

### Groundcherry Physalis lanceifolia 

### Pennsylvania smartweed Polygonum pennsylvanicum 

### Ladysthumb Polygonum persicaria



### 12WEED SPECIES CONTROLLED Group III: Weeds controlled upto the 2-leafstage Annual sowthistle Sonchus oleraceus Common purslane Portulaca oleracea Wild buckwheat Polygonum convolvulus Kochia* Kochia scoparia "



### . * Spray Kochla while In the rosette stage, less than 1 In diameter DOSAGE TABLE 9 (All areas except California) Rate ofWillowood Ethofumesate SC Per Acre Rate of Betanex® PerAcre

Broadcast Band' Row Spacing Broadcast Band' Row Spacing Rate Width Rate Width (in.) 

### 22" 28" 30" (in.) 22" 

### 28" 30"

2 1/4

- 

### 3 3/4-1 1/2-3/4 1/2-2/3 4112

- 

### 6 1 1/2-2 1 1/8-1 1-11/3

Pints 

### 7 Pint Pint Pint Pints 

### 7 Pints 1/2 Pints Pints Use the higher rate on largerweeds and sugar beets

, For other band or row widths, adjust rates in proportion to the area actually treated. Postemergence Use Precautions: Make only one conventional application of Willowood Ethofumesate SC + Betanex® or Betamix®tank mix during each growing season. Do not apply Willowood Ethofumesate SC + Betanex® or Betamix® tank mix to sugar beets later than 90 days prior to harvest. Crop Planting Precautions: If crop is lost due to unfavorable growth conditions following treatment, do not replant with crops other than sugar beets or ryegrass in treated land during the same season. Iffields are replanted to sugar beets, reseed into treated band. Do not retreat field with conventional rates of Willowood Ethofumesate SC in the same season. WILLOWOOD ETHOFUMESATE SC + BETANEX® OR BETAMIX® MAY CAUSE SUGAR BEET INJURY OR STAND LOSS IF THE CROP IS UNDER STRESS FROM ONE OR MORE OF THE FOLLOWING CONDITIONS:

• Rapid climatic changes from cool, overcast days, to hot (80°F or over), bright days. When the air temperature is, or is likely to be above 80°F on the day ofspraying, application should be made in the evening when the temperature is lower. • Frostwithin seven daysfollowing treatment • Windy or drought conditions • Use ofa preplant or preemergence herbicide orother chemicals • Insect ordisease injury • Close cultivation Ifstress conditions are present, delay application until crop has recovered. DO NOT OVERTREAT: The use of higher-than-recommended rates may cause beet injury andlor carry over problems. Do not spray while dew is present. Rainfall or sprinkler irrigation within 6 hours ofapplication may reduce weed kill. IfWillowood Ethofumesate SC is applied on fields with heavy crop residue, such as from a previous corn crop, reduced weed control may occur. Do not allow spray drift to contact adjacent crops which may be injured by spray drift.


### 13

### IMPORTANT: This tank mix may cause temporary growth retardation and/or chlorosis or tip-burn on sugar beets. Sugar beets usually resume normal growth within 10 days. WILLOWOOD ETHOFUMESATE SC MIXTUES WITH FERTILIZERS WILLOWOOD ETHOFUMESATE SC Impregnation on Dry Bulk Fertilizers Willowood Ethofumesate SC may be impregnated on many dry bulk fertilizers (See "1" below.) and applied and incorporated into the soil before planting for the control of labeled grasses and broadleaf weeds in sugar beets. All Willowood Ethofumesate SC label and supplementary literature instructions and precautions regarding rates per acre, soil type and soil incorporation, application, and other directions must be followed. All individual State regulations relating to dry bulk fertilizer blending, registration, labeling and application are the responsibility of the individual and/or company selling the Willowood Ethofumesate SC/fertilizer mixtures. A minimum of 200 pounds and a maximum of 700 pounds of approved fertilizer ingredients (See "2" below.) impregnated with the appropriate amount of Willowood Ethofumesate SC must be applied per acre. For impregnating the pesticide on dry fertilizers, use a closed rotary-drum type mixer equipped with suitable spraying equipment. The spray nozzles should be positioned inside of the mixer to provide uniform spray coverage of the tumbling fertilizer. The Willowood Ethofumesate SC should be sprayed uniformly onto the fertilizer using afine spray pattern. The physical properties of fertilizers vary, particularly in liquid absorptive capacity. When absorptivity is sufficient, simple spray impregnation of the fertilizer with Willowood Ethofumesate SC provides a satisfactory dry mixture. If the absorptivity is not adequate, use of a highly absorptive powder is required to provide a dry, freefiowing mixture. Microcel E (Johns-Manville Products Corporation) is the recommended absorbent powder. It should be added separately and uniformly to the prepared pesticide/fertilizer mixture in a quantity that is sufficient to provide a suitably free-flowing mixture. Generally, less than 2% by weight of Microcel E is required. The amount of Willowood Ethofumesate SC actually required in the formulation of specific fertilizer mixtures should be calibrated carefully for each production operation. This is necessary to ensure that the amount of Willowood Ethofumesate SC actually contained in the fertilizer mixture applied to the soil represents the correct dosage rate. Bulk fertilizers impregnated with Willowood Ethofumesate SC should be applied immediately, NOT STORED. WILLOWOOD ETHOFUMESATE SC IMPREGNATION ON DRY BULK FERTILIZERS 1. Approved dryfertilizer ingredientsfor use with Willowood Ethofumesate SC: N P K Ammonium nitrate 34 0 0 Ammonium sulfate 21 0 0 Ammonium phosphate-sulfate 16 20 0 Diammonium phosphate 18 46 0 Monoammonium phosphate 11 56 0 Potassium chloride 0 0 60 Potassium sulfate 0 0 52 Single superphosphate 0 20 0 Triple superphosphate 0 46 0

14

### N 

### P K 

# I Urea 45 

# o 

# o

Willowood Ethofumesate SC Physical Data Density 1.15 

## g/cm' Pounds/gallon 9.60 Flashpoint Noncombustible 2. Rate Chartforthe Impregnation of Dry Bulk Fertilizers with Willowood Ethofumesate SC: Gallons ofWillowood Ethofumesate SC perTon of Dry Bulk Fertilizer Fertilizer Rate 2.25 pt.lacre Impregnation Rate 4.5 pt./acre Ib/acre 

### 3 pt.lacre

200 2.80 3.75 5.63 250 2.25 3.00 4.50 300 1.88 2.50 3.75 350 1.59 2.16 3.19 400 1.41 1.88 2.81 450 1.25 1.69 2.50 500 1.13 1.50 2.25 550 1.03 1.38 2.06 600 0.94 1.25 1.88 650 0.87 1.13 1.75 700 0.80 1.08 1.62
WILLOWOOD ETHOFUMESATE SC with Liquid Fertilizer The following procedure is suggested for evaluation of physical compatibility of Willowood Ethofumesate SC with liquid fertilizers forspray tank applications. Material Required 1. Willowood Ethofumesate SC- components oftank mixes if intended for use 2. Liquid fertilizerto be used 3. Adjuvant forfertilizer tank mix: Compex' or E-Z Mix". 4. Two (or more) one quart, wide mouth containers with lids or stoppers 5. Measuring spoons- (25 ml pipette or graduated cylinder provides more accurate measurement) 6. Measuring cup, 8 fl. oz. (237 ml)

, Compex- Kalo Laboratories, Inc., Kansas City, MO " E-Z Mix- United Agri-Products, Greeley, CO PROCEDURE 1. Pour one pint (473 ml) ofthe liquid fertilizer into each ofthe quart containers. 2. Add adjuvant(s) to one or more ofthe containers and mix; follow label directions ofadjuvant 3. Add the Willowood Ethofumesate SC and tank mix components to the containers (see rate table below). 4. Close the containers with lids or stoppers and mix contents by inverting the containers ten times. 5. Inspectthe surface and body ofthe mixture: a. immediately after mixing, b. after allowing mixtures to stand quietly for 30 minutes, c. immediately after mixing again (invertthe containers ten more times). If a uniform mixture does not occur, the spray tank mixture should not be used. If any of the mixtures remain uniform for 30 minutes, that mixture may be used in spray tank applications. Should any of the mixtures separate after 30 minutes but remix readily into a uniform mixture with inversion ofthe container, the mixture may be used provided that adequate agitation is maintained in the spray tank. If a Willowood Ethofumesate SC 

### + fertilizer mixture utilizing an adjuvant is satisfactory, but the one without the adjuvant

15

### is not, be sure to use the adjuvant in the spray tank at the rate recommended on the label which was used in this test. If non-dispersible oil, sludge, or clumps of solids form in the mixtures, those combinations should not be used forspray tank application.

RATE TABLE FORWILLOWOOD ETHOFUMESATE SC MIXTURES WITH LIQUID FERTILIZERS Gal. of Liquid Fertilizerto be 

### *ml ortsp. ofWillowood Ethofumesate SC to be added to 1 pint applied per acre offertilizer ml tsp. 

### 20 17.6 3.6 30 12.0 2.4 40 9.0 1.9 50 7.1 1.5 60 6.0 1.2 *

### Based on field use rate of 3.0 lb. ai/acre (3/4 gal/acre) In the fertilizer volumes indicated. Adjust amount of 

### Willowood Ethofumesate SC added proportionately to correspond with intended field use rate recommended on Willowood Ethofumesate SC label for soil type. Add the proportionate amount of tank mix component (e.g., Pyramin) if intended for use, based on volume ofWillowood Ethofumesate SC used in the test. BEETS, TABLE (GARDEN) GENERAL INFORMATION 

### Willowood Ethofumesate SC is a selective herbicide for use in table beets for the control of the weed species listed below. Residual control of weeds is dependent upon soil moisture conditions; rate of herbicide used, and soil texture. The activity ofWillowood Ethofumesate SC in the soil is reduced as the soil texture becomes finer and organic matter increases. WEED SPECIES CONTROLLED Annual BroadleafWeeds 

### Black nightshade Solanum nigrum 

### Common chickweed Stellaria media 

### Common lambsquarters Chenopodium album 

### Common purslane Portulaca o/eracea 

### Eastern black nightshade So/arnum ptycanthum 

### Kochia Koehia seoparia 

### Ladysthumb Polygonumpersicaria 

### Pennsylvania smartweed Polygonum pennsy/vanicum 

### Redroot pigweed Amaranthus retroflexus 

### Russian thistle Salso/a kali var. tenuifolia 

### Wild buckwheat Polygonum convolvulus 

# IAnnual Grass Weeds



### 16

### Annual Grass Weeds 

### Annual bluegrass Poa annua 

### Barnyardgrass Echinoch/oa crus-galli 

### Canarygrass Phaiaris canariensis 

### Green foxtail Setaria viridis Large 

### crabgrass Oigitaria sanguina/is 

### Volunteer barley Hordeum 

### sp. Volunteerwheat Triticum 

### sp. Wild oats" Avena fatua 

### Yellow foxtail Setaria g/auca



### •• Control ofwild oats has been inconsistent in Minnesota and North Dakota Willowood Ethofumesate SC alone will also reduce competition from these HARD-TO-CONTROL weeds: 

### Annual Sowthistle Sonchus /oeraceus 

### Puncturevine Tribu/us terrestris 

### Shepherdspurse Capsel/a bursa-pastoris 

### Purple nutsedge Cyperus rotundus 

### Yellow nutsedge Cyperus escu/entus 

### Apply tank mixes only in specified regions or States and in accordance with directions on label. GENERAL APPLICATION Table Beets Grown Under Rainfall: 

### Apply Willowood Ethofumesate SC alone or in a tank mix preemergence at time of planting or shortly after, but prior to weed germination. Willowood Ethofumesate SC or tank mix does 

### not require mechanical soil incorporation provided that sufficient rainfall occurs shortly following application to activate the chemical. One-half inch of rainfall is usually adequate for activation. In areas where rainfall can be marginal for activation, it is recommended that Willowood Ethofumesate SC be applied before or at the time of planting and incorporated into the soil. Table Beets Grown Under Furrow Irrigation: 

### Apply Willowood Ethofumesate SC alone or in a tank mix to the soil surface preplant or at time of planting, but prior to weed germination. Where table beets are grown in beds, apply Willowood Ethofumesate SC or tank mix after bedding and incorporate. Since Willowood Ethofumesate SC must have moisture to control weeds effectively, irrigate until tops of beds are thoroughly wetted. Table Beets Grown Under Sprinkler Irrigation: 

### Apply Willowood Ethofumesate SC alone or in tank mix preemergence at time of planting or shortly after, and irrigate prior to crop and weed germination. Repeat irrigation as necessary to maintain good moisture in upper soil layer. Apply at least one-half inch ofwater during first irrigation. Do not mechanically incorporate Willowood Ethofumesate SC into the soil under sprinkler irrigation. Cultural Practices Following Application: 

### When properly applied, Willowood Ethofumesate SC alone can provide up to 6 weeks control of susceptible species. When cultivating fields in which Willowood Ethofumesate SC has been banded, care should be exercised to minimize the movement of untreated soil into the treated band. Where a broadcast application has been made, do not cultivate deeper than two inches, as this reduces the effectiveness ofWillowood Ethofumesate SC.



### 17

### WILLOWOOD ETHOFUMESATE SC ALONE DOSAGE FOR BROADCASTAPPLICATIONS
Table Beet Stage WILLOWOOD ETHOFUMESATE SC FLUID OUNCES/ACRE BROADCAST Preemergence Postemergence: 2-Leaf 4-Leaf 6-Leafto 8-Leaf
Do not exceed 96 fluid ounces (0.75 gallon) of product per season. PREPLANT AND PREEMERGENCE USE PRECAUTIONS 60

5.25 5.25 10.5

Willowood Ethofumesate SC applied alone or in tank mixes according to label directions and under normal growing conditions may cause temporary leaf fusion, distortion and stunting. Crop injury may occur during early growth when crop is stressed due to herbicide residue carryover, highly saline or alkaline soils, unusually cold and wet weather or improperly placed fertilizers or soil insecticides. Unusually dry, windy weather, which dries the upper soil layer, following application of Willowood Ethofumesate SC, may reduce effectiveness. DO NOT OVERTREAT: The use of higher than recommended rates may cause beet injury and/or carry over problems. Crop Planting Precautions: If crop is lost due to unfavorable growth conditions following treatment, do not replant with crops other than sugar beets, table beets, garlic, onions, shallots or ryegrass in treated land during the same season. If fields are replanted to sugar beets, reseed into treated band. Do not retreat field with preemergence rates ofWillowood Ethofumesate SC in the same season. PRECAUTIONS No more than a total of 0.75 gallon ofWillowood Ethofumesate SC should be applied in a single growing season. See Use Precautions

### foradditional information on proper use. PREPLANTAND PREEMERGENCE APPLICATIONS Soil Preparation: The soil should be prepared according to good agricultural practices. Large clods can reduce the effectiveness of Willowood Ethofumesate SC and tank mixes. All existing vegetative growth should be thoroughly worked into the soil before treatment. Spray Equipment: Apply Willowood Ethofumesate SC alone or in tank mixes to the soil using standard low pressure (20 to 50 psi) spray equipment. Spray equipment should be carefully calibrated before use and checked frequently during application to see that it is functioning properly. Do not use smaller than 50-mesh strainer. Uniformly apply the recommended rates ofWillowood Ethofumesate SC or tank mixes in 10 to 60 gallons of water per acre on a broadcast basis. Avoid overlaps since crop injury may result. When applying Willowood Ethofumesate SC or tank mixes in a band, check to make certain that the band width is accurate forthe dosage rate being applied. The spray tank and lines should be thoroughly cleaned and rinsed prior to using Willowood Ethofumesate SC. POSTEMERGENCE APPLICATION General Information Willowood Ethofumesate SC applied postemergence broadens and enhances the control ofweeds. Mixing the Spray: Add Willowood Ethofumesate SC to the water in the spray while agitating the spray solution thoroughly.

18

### Spray Equipment: 

### Apply the mixture using standard low pressure (20-60 psi) spray equipment. Ensure that the sprayer is thoroughly clean. Spray equipment should be carefully calibrated before use and checked frequently during application to see that it is functioning properly. Uniformly apply the recommended rate in 10-40 gallons ofwater per acre on a broadcast basis or 5-10 gallons of water per acre in a band. Avoid overlaps, since crop injury may result. When applying in a band, check to make certain that the band width is accurate for the dosage rate being applied. Do not use strainer smaller than 50-mesh. Moisture Following Application/Residual Weed Control: 

### Rainfall or sprinkler irrigation within 6 hours of spraying may reduce weed control; however, with preemergence rates, moisture after this period of time is advantageous for moving Willowood Ethofumesate SC into the top layer of soil where it can be absorbed by the roots of sprayed and germinating weeds to provide optimum control. One-half inch or more ofsprinkler irrigation is required to activate Willowood Ethofumesate SC on most soil types. Residual control of weeds is dependent upon soil moisture conditions; rate of herbicide used, and soil texture. The activity ofWillowood Ethofumesate SC in the soil is reduced as the soil texture becomes finer and organic matter increases. WILLOWOOD ETHOFUMESATE SC MAY CAUSE CROP INJURY OR STAND LOSS IF THE CROP 

### IS UNDER STRESS FROM ONE OR MORE OF THE FOLLOWING CONDITIONS:



### • Rapid climatic changes from cool, overcast days, to hot (80°F or over), bright days. When the air temperature is, or is likely to be, above 80°F on the day of spraying, application should be made in the evening when the temperature is lower. • Frost within seven days following treatment • Windy or drought conditions • Use ofa preplant or preemergence herbicide or other chemicals • Insect or disease injury • Close cultivation Ifstress conditions are present, delay application until crop has recovered. DO NOT OVERTREAT: The use of higher-than-recommended rates may cause beet injury and/or carry over problems. Do not spray while dew is present. Rainfall or sprinkler irrigation within 6 hours ofapplication may reduce weed kill. IfWillowood Ethofumesate SC is applied on fields with heavy crop residue, such as from a previous corn crop, reduced weed control may occur. Do not allow spray drift to contact adjacent crops which may be injured by spray drift. ONION, DRY BULB; GARLIC, BULB; SHALLOT, BULB GENERAL INFORMATION 

### Willowood Ethofumesate SC is a selective herbicide for use in onion, garlic and shallot for the control of the weed species listed below. Residual control of weeds is dependent upon soil moisture conditions; rate of herbicide used, and soil texture. The activity ofWillowood Ethofumesate SC in the soil is reduced as the soil texture becomes finer and organic matter increases. WEED SPECIES CONTROLLED Annual 

### BroadleafWeeds 

### Black nightshade So/anum nigrum 

### Common chickweed Stelfaria media 

### Common lambsquarters Chenopodium album 

### Common purslane Portulaca o/eracea



### 19

### Annual BroadleafWeeds Eastern black nightshade Solanum ptycanthum 

### Kochia Kochia scoparia 

### Ladysthumb Polygonum persicaria 

### Pennsylvania smartweed Polygonum pennsylvanicum 

### Redroot pigweed Amaranthus retroflex

### us Russian thistle Sa/so/a kali var. tenuifolia 

### Wild buckwheat Polygonum convolvulus



### Annual Grass Weeds Annual bluegrass Poa annua 

### Barnyardgrass Echinochloa crus-gal/i 

### Canarygrass Pha/aris canariensis 

### Green foxtail Setaria viridis 

### Large crabgrass Digitaria sanguinalis 

### Volunteer barley Hordeum 

### sp. Volunteer wheat Triticum 

### sp. Wild oats·· Avena fatua 

### Yellow foxtail Setaria glauca 

### ··Control ofwild oats has been Inconsistent in Minnesota and North Dakota Willowood Ethofumesate SC alone will also reduce competition from these HARD-TO-CONTROL weeds: Annual sowthistle Sonchus oleraceus 

### Puncturevine Tribulus terrestris 

### Shepherdspurse Capsel/a bursa-pastoris 

### Purple netsedge Cyperus rotundus 

### Volunteer potato Solanum tuberosum 

### Yellow nutsedge Cyperus esculentus 

### Apply tank mixes only in specified regions or States and in accordance with directions on label. GENERAL APPLICATION Onion, garlic and shallot growth under rainfall: Apply Willowood Ethofumesate SC alone or in a tank mix preemergence at time of planting or shortly after, but prior to weed germination. Willowood Ethofumesate SC or tank mix does not require mechanical soil incorporation provided that sufficient rainfall occurs shortly following application to activate the chemical. One-half inch of rainfall is usually adequate for activation. In areas where rainfall can be marginal for activation, it is recommended that Willowood Ethofumesate SC be applied before or at time of planting and incorporated into the soil. Onion, garlic and shallot grown underfurrow irrigation: Apply Willowood Ethofumesate SC alone or in a tank mix to the soil surface preplant or at time of planting, but prior to weed germination. Where these crops are grown in beds, apply Willowood Ethofumesate SC or tank mix after bedding and incorporate. Since Willowood Ethofumesate SC must have moisture to control weeds effectively, irrigate until tops of beds are thoroughly wetted.


### 20Onion, garlic and shallot grown under sprinkler irrigation: Apply Willowood Ethofumesate SC alone or in tank mix preemergence at time of planting or shortly after, and irrigate prior to crop and weed germination. Repeat irrigation as necessary to maintain good moisture in upper soil layer. Apply at least one-half inch ofwater during first irrigation. Do not mechanically incorporate Willowood Ethofumesate SC into the soil undersprinkler irrigation. CULTURAL PRACTICES FOLLOWING APPLICATION: When properly applied, Willowood Ethofumesate SC alone can provide up to 6 weeks of control of susceptible weed species. When cultivating fields in which Willowood Ethofumesate SC has been banded, care should be exercised to minimize the movement of untreated soil into the treated band. Where a broadcast application has been made, do not cultivate deeper than two inches, as this reduces the effectiveness of Willowood Ethofumesate SC. WILLOWOOD ETHOFUMESATE SC ALONE DOSAGE FOR BROADCASTAPPLICATIONS TO ONION, GARLIC AND SHALLOT
Use Pattern WILLOWOOD ETHOFUMESATE SC FLUID OUNCES/ACRE BROADCAST Preemergence, soil surface Coarse Soils (sand, loamy sand, sandy loam)' 16 Medium and Fine Soils" 32 Postemergence Up to 4 foliar applications at evenly spaced 16 intervals, with last application 30 (+/- 2) days before harvest 

## • On coarse SOils. Do not exceed 

### 48 flUid ounces (0.375 gallon) of product per season

. •• On medium and fine textured soils: Do not exceed 96 fluid ounces (0.75 gallon) of product perseason. PREPLANT AND PREEMERGENCE USE PRECAUTIONS Willowood Ethofumesate SC applied alone or in tank mixes according to label directions and under normal growing conditions may cause temporary leaf fusion, distortion and stunting. Crop injury may occur during early growth when crop is stressed due to herbicide residue carryover, high saline oralkaline soils, unusually cold and wet weather or improperly placed fertilizers orsoil insecticides. Unusually dry, windy weather, which dries the upper soil layer, following application of Willowood Ethofumesate SC, may reduce effectiveness. DO NOT OVERTREAT: The use of higher than recommended rates may cause crop injury and/or carry over problems. Crop Planting Precautions: If crop is lost due to unfavorable growth conditions following treatment, do not replant with crops other than sugar beets, table beets, garlic, onions, shallots or ryegrass in treated land during the same season. If fields are replanted to sugar beets, reseed into treated band. Do not retreat field with preemergence rates ofWillowood Ethofumesate SC in the same season. PRECAUTIONS No more than a total of 0.75 gallon ofWillowood Ethofumesate SC should be applied in a single growing season. See Use Precautions for additional information on proper use. PREPLANT AND PREEMERGENCE APPLICATIONS Soil Preparation: The soil should be prepared according to good agricultural practices. Large clods can reduce the effectiveness of Willowood Ethofumesate SC and tank mixes. All existing vegetative growth should be thoroughly worked into the soil before treatment. Spray Equipment: Apply Willowood Ethofumesate SC alone or in tank mixes to the soil using standard low pressure (20 to 50 psi) spray equipment. Spray equipment should be carefully calibrated before use and checked frequently during application to see that it is functioning properly. Do not use smaller than 50-mesh strainer. Uniformly apply the recommended rates ofWillowood Ethofumesate SC ortank mixes in 10 to 60 gallons of water per acre on a broadcast basis. Avoid overlaps since crop injury may result. When applying Willowood Ethofumesate SC ortank mixes in a band, check to make certain that the band width is accurate for the dosage rafe being applied.

21

### The spray tank and lines should be thoroughly cleaned and rinsed prior to using Willowood Ethofumesate SC. POSTEMERGENCE APPLICATION 

### General Information Willowood Ethofumesate SC applied postemergence broadens and enhances the control ofweeds. Mixing the spray: 

### Add Willowood Ethofumesate SC to the water in the spray tank while agitating the spray solution thoroughly. Spray Equipment: 

### Apply the mixture using standard low pressure (20-60 psi) spray equipment. Ensure that the sprayer is thoroughly clean. Spray equipment should be carefully calibrated before use and checked frequently during application to see that it is functioning properly. Uniformly apply the recommended rate in 10-40 gallons of water per acre on a broadcast basis or 5-10 gallons of water per acre in a band. Avoid overlaps, since crop injury may result. When applying in a band, check to make certain that the band width is accurate for the dosage rate being applied. Do not use strainer smaller than 50-mesh. Moisture following Application/Residual Weed Control: 

### Rainfall orsprinkler irrigation within 6 hours of spraying may reduce weed control; however, with preemergence rates, moisture after this period of time is advantageous for moving Willowood Ethofumesate SC into the top layer of soil where it can be absorbed by the roots of sprayed and germinating weeds to provide optimum control. One-half inch or more ofsprinkler irrigation is required to activate Willowood Ethofumesate SC on most soil types. Residual control ofweeds is dependent upon soil moisture conditions, rate of herbicide used, and texture. The activity of Willowood Ethofumesate SC in the soil is reduced as the soil texture becomes finer and organic matter increases. WILLOWOOD ETHOFUMESATE SC MAY CAUSE CROP 

### INJURY OR STAND LOSS IF THE CROP IS UNDER STRESS FROM 

### ONE OR MORE 

### OF THE FOLLOWING CONDITIONS:

• Rapid climatic changes from cool, overcast days, to hot (80'F or over), bright days. When the air temperature is, or is likely to be, above 80'F on the day of spraying, application should be made in the evening when the temperature is lower. • Frost within seven days following treatment • Windy or drought conditions • Use of preplant or preemergence herbicide or other chemicals • Insect or disease injury • Close cultivation Ifstress conditions are present, delay application until crop has recovered. DO NOT OVERTREAT: The use of higher-than-recommended rates may cause beet injury and/or carry over problems. Do not spray while dew is present. Rainfall or sprinkler irrigation within 6 hours ofapplication may reduce weed kill. IfWillowood Ethofumesate SC is applied on fields with heavy crop residue, such as from a previous corn crop, reduced weed control may occur. Do not allow spray drift to contact adjacent crops which may be injured by spray drift. CARROT (For Use in Washington and Oregon Only) GENERAL INFORMATION 

### Willowood Ethofumesate SC is a selective herbicide for use in carrot for the control of volunteer potatoes and the weed species listed below. Residual control of weeds is dependent upon soil moisture conditions; rate of herbicide used, and soil texture. The activity ofWillowood Ethofumesate SC in the soil is reduced as the soil texture becomes finer and organic matter increases.
22WEED SPECIES CONTROLLED Annual BroadleafWeeds 

### Black nightshade Solanum nigrum 

### Common chickweed Stellaria media 

### Common lambsquarters Chenopodium album 

### Common purslane Portulaca oleracea 

### Kochia Kochia scoparia 

### Ladysthumb Polygonum persicaria 

### Pennsylvania smartweed Polygonum pennsylvanicum 

### Redroot pigweed Amaranthus retroflexus 

### Russian thistle Salsola kali var. tenuifolia 

### Wild buckwheat Polygonum convolvulus Annual Grass Weeds 

### Annual bluegrass Poa annua 

### Barnyardgrass Echinochloa crus-gal/i 

### Canarygrass Phalaris canariensis 

### Green foxtail Setaria viridis 

### Large crabgrass Digitaria sanguinalis 

### Volunteer barley Hordeum 

### sp. Volunteerwheat Triticum 

### sp. Wild oats Avena fatua 

### Yellow foxtail Setaria glauca Willowood Ethofumesate SC alone will also reduce competition from these HARD-TO-CONTROLweeds: 

### Annual Sowthistle Sonchus oleraceus 

### Puncturevine TribU/us terrestris 

### Shepherdspurse Capsella bursa-pastoris 

### Purple nutsedge Cyerus rotundus 

### Volunteer potato Solanum tuberosum 

### Yellow nutsedge Cyperus esculentus 

### Apply tank mixes only In specified regions or States and In accordance with directions on label. GENERAL APPLICATION Carrot grown under rainfall: 

### Apply Willowood Ethofumesate SC alone or in a tank mix preemergence at time of planting or shortly after, but prior to weed germination. Willowood Ethofumesate SC or tank mix does not require mechanical soil incorporation provided that sufficient rainfall occurs shortly following application to activate the chemical. One-half inch of rainfall is usually adequate for activation. In areas where rainfall can be marginal for activation, it is recommended that Willowood Ethofumesate SC be applied before or at the time of planting and incorporated into the soil. Carrot grown under furrow irrigation: 

### Apply Willowood Ethofumesate SC alone or in a tank mix to the soil surface preplant or at time of planting, but prior to weed germination. Where carrots are grown in beds, apply Willowood Ethofumesate SC or tank mix after bedding and incorporate. Since Willowood


### 23

### Ethofumesate SC must have moisture to control weeds effectively, irrigate until tops of beds are thoroughly wetted. Carrot grown under sprinkler irrigation: Apply Willowood Ethofumesate SC alone or in tank mix preemergence at time of planting or shortly after, and irrigate prior to crop and weed germination. Repeat irrigation as necessary to maintain good moisture in upper soil layer. Apply at least one-half inch ofwater during first irrigation. Do not mechanically incorporate Willowood Ethofumesate SC into the soil under sprinkler irrigation. Cultural practices following application: When properly applied, Willowood Ethofumesate SC alone can provide up to 6 weeks control of susceptible weed species. When cultivating fields in which Willowood Ethofumesate SC has been banded, care should be exercised to minimize the movement of untreated soil into the treated band. Where a broadcast application has been made, do not cultivate deeperthan two inches, as this reduces the effectiveness ofWillowood Ethofumesate SC. WILLOWOOD ETHOFUMESATE SC DOSAGE FOR BROADCAST APPLICATIONS TO CARROT Use Pattern WILLOWOOD ETHOFUMESATE SC FLUID OUNCES/ACRE BROADCAST Preemergence, soil surface Coarse Soils (sand, loamy sand, sandy loam) 48 Medium and Fine soils 64 Postemergence 2-Leafto 4 LeafStage 64
Do not exceed 128 fluid ounces (1 gallon) ofproduct per season. PREPLANT AND PREEMERGENCE USE PRECAUTIONS Willowood Ethofumesate SC applied alone or in tank mixes according to label directions and under normal growing conditions may cause temporary leaf fusion, distortion and stunting. Crop injury may occur during early growth when crop is stressed due to herbicide residue carryover, highly saline or alkaline soils, unusually cold and wet weather or improperly placed fertilizers or soil insecticides. Unusually dry, windy weather, which dries the upper soil layer, following application of Willowood Ethofumesate SC, may reduce effectiveness. DO NOT OVERTREAT: The use of higher than recommended rates may cause crop injury and/or carry over problems. Crop Planting Precautions: If crop is lost due to unfavorable growth conditions following treatment, do not replant with crops other than sugar beets, table beets, carrots, garlic, onions, shallots, or ryegrass in treated land during the same season. Iffields are replanted to sugar beets, reseed into treated band. Do not retreat field with preemergence rates ofWillowood Ethofumesate SC in the same season. PRECAUTIONS No more than a total of 1 gallon of Willowood Ethofumesate SC should be applied in a single growing season. See Use Precautions 

### for additional information on proper use. PREPLANTAND PREEMERGENCE APPLICATIONS Soil Preparation: The soil should be prepared according to good agricultural practices. Large clods can reduce the effectiveness of Willowood Ethofumesate SC and tank mixes. All existing vegetative growth should be thoroughly worked into the soil before treatment. Spray Equipment: Apply Willowood Ethofumesate SC alone or in tank mixes to the soil using standard low pressure (20 to 50 psi) spray equipment. Spray equipment should be carefully calibrated before use and checked frequently during application to see that it is functioning properly. Do not use smaller than 50 mesh strainer. Uniformly apply the recommended rates of Willowood Ethofumesate SC or tank mixes in 10 to 60 gallons of water per acre on a broadcast basis. Avoid overlaps since crop injury may result.

24

### When applying Willowood Ethofumesate SC or tank mixes in a band, check to make certain that the band width is accurate for the dosage rate being applied. The spray tank and lines should be thoroughly cleaned and rinsed priorto using Willowood Ethofumesate SC. POSTEMERGENCE APPLICATION General Information Willowood Ethofumesate SC applied postemergence broadens and enhances the control ofweeds. Mixing the Spray: Add Willowood Ethofumesate SC to the water in the spray while agitating the spray solution thoroughly. Spray Equipment: Apply the mixture using standard low pressure (20-60 psi) spray equipment. Ensure that the sprayer is thoroughly clean. Spray equipment should be carefully calibrated before use and checked frequently during application to see that it is functioning properly. Uniformly apply the recommended rate in 10-40 gallons of water per acre on a broadcast basis or 5-10 gallons of water per acre in a band. Avoid overlaps, since crop injury may result. When applying in a band, check to make certain that the band width is accurate for the dosage rate being applied. Do not use strainer smaller than 50-mesh. Moisture Following Application/Residual Weed Control: Rainfall or sprinkler irrigation within 6 hours ofspraying my reduce weed control, however, with preemergence rates, moisture after this period oftime is advantageous for moving Willowood Ethofumesate SC into the top layer of soil where it can be absorbed by the roots of sprayed and germinating weeds to provide optimum control. One-half inch or more ofsprinkler irrigation is required to activate Willowood Ethofumesate SC on most soil types. Residual control of weeds is dependent upon soil moisture conditions; rate of herbicide used, and soil texture. The activity ofWillowood Ethofumesate SC in the soil is reduced as the soil texture becomes finer and organic matter increases. WILLOWOOD ETHOFUMESATE SC MAY CAUSE CROP INJURY OR STAND LOSS IF THE CROP IS UNDER STRESS FROM ONE OR MORE OF THE FOLLOWING CONDITIONS:

• Rapid climatic changes from cool, overcast days, to hot (80°F or over), bright days. When the air temperature is, or is likely to be, above 80°F on the day of spraying, application should be made in the evening when the temperature is lower. • Frost within seven days following treatment • Windy or drought conditions • Use of preplant or preemergence herbicide or other chemicals • Insect or disease injury • Close cultivation Ifstress conditions are present, delay application until crop has recovered. DO NOT OVERTREAT: The use of higher-than-recommended rates may cause beet injury and/or carry over problems. Do not spray while dew is present. Rainfall or sprinkler irrigation within 6 hours ofapplication may reduce weed kill. IfWillowood Ethofumesate SC is applied on fields with heavy crop residue, such as from a previous corn crop, reduced weed control may occur. Do not allow spray drift to contact adjacent crops which may be injured by spray drift. RYEGRASS, TALL FESCUE, BENTGRASS, AND KENTUCKY BLUEGRASS SEED CROPS (For use in California, Idaho, Nevada, Oregon, and Washington only) GENERAL INFORMATION Willowood Ethofumesate SC is a selective herbicide for use in ryegrass, tall fescue, and bentgrass seed crops in California, Idaho, Nevada, Oregon, and Washington. It effectively controls orreduces competition from those weed species listed below. Willowood Ethofumesate SC may be applied preemergence to
25

### new seedings of annual or perennial ryegrass or postemergence to perennial ryegrass, tall fescue, or bentgrass. Application to bentgrass is restricted to plantings which have been established for one year or longer. Soil should be moist at time of application. Willowood Ethofumesate SC is less effective when applied to dry soil. Rainfall oroverhead irrigation shortly after application is necessary for activation. Residual control of weeds is dependent upon soil moisture conditions; rates of herbicide used, and soil texture. The activity ofWillowood Ethofumesate SC in the soil is reduced as the soil texture becomes finer and organic malter/thatch increases. WEEDS CONTROLLED 

### Annual bluegrass Poa annua 

### Seedling Rattail fescue Festuca myuros 

### Seedling volunteerwheat Triticum 

### spp. Seedling volunteer barley Hordeum 

### spp. Soft chess Bromus 

### mol/is Seedling Wild oats Avena fatua 

### Downy brome Bromus tectarum 

### Common chickweed Stellaria media 

### Common vetch Vicia 

### sativa Common velvetgrass Holcus lanatus 

### Mannagrass Glyceria 

### spp. 8arnyardgrass Echinochloa crus-gal/i 

### Canarygrass Phalaris canariensis 

### Green foxtail Setaria viridis 

### Large crabgrass Digitaria sanguinalis 

### Yellow foxtail Setaria glauca Spray equipment: 

### Use a fixed-boom power sprayer properly calibrated to a constant speed and rate of delivery. Do not use smaller than 50-mesh strainer. Avoid overlapping of spray swath. Shut off boom while starting, turning or stopping to avoid overlapping. Apply in 10 to 50 gallons of water per acre at low pressure (20 to 50 psi). Soil preparation: 

### A firm, fine and level seedbed free of trash and vegetative matter will provide best results from preemergence applications. Large clods can reduce effectiveness of Willowood Ethofumesate SC. All existing vegetative growth should be thoroughly worked into the soil before treatment. NEWSEEDINGS OF ANNUAL OR PERENNIAL RYEGRASS Before weed emergence: 

### Apply Willowood Ethofumesate SC after seeding and prior to weed emergence. For best results apply to moist soil. Apply 1 1/2 

### to 3 pints per acre. Use the lower rate for control of common chickweed. For control of raltail fescue, wild oats, and volunteer cereals and other weeds listed, use 2 1/4 

### to 3 3/4 

### pints per acre. After weed emergence: 

### Apply Willowood Ethofumesate SC at earliest possible weed growth stage but not laterthan the 4-leaf stage. Raltail fescue, wild oats, and volunteer cereals which are more difficult to control, must be treated no laterthan the 2-leafstage. Apply 2 1/4 

### to 3 3/4 

### pints per acre. Use the highest rate where rattail fescue, wild oats, and volunteer cereals are present and where weed infestation is heavy. NEW SEEDINGS OF FALL-PLANTED PERENNIAL RYEGRASS AND TALL FESCUE TREATED WITH DIURON PLUS CHARCOAL



### 26Timing of application: 

### Apply Willowood Ethofumesate SC following crop emergence and after sufficient rainfall and/or overhead irrigation has occurred to dissipate the charcoal band (approximately 4 inches). Use dosage rates listed in Dosage Table 10. 

### Surface debris may result in reduced weed control. Failure to allow for complete dissipation ofthe charcoal band may result in reduced weed control within the crop row. For best results, apply Willowood Ethofumesate SC to a moist soil surface. Before using diuron, read the diuron label for rate recommendations, timing of applications, directions for use, and precautionary statements. Do not exceed maximum dosage rates for either herbicide. NOTE: Do not apply Willowood Ethofumesate SC when crop shows diuron injury. DOSAGE TABLE 10 Crop Rate PerAcre Remarks 

### Perennial ryegrass and tall 1 1/2 to 3 pints For effective control, annual fescue bluegrass must be treated before the 4-leafstage; rattail fescue, wild oats, and volunteerwheat must be treated before the 2-leaf stage. Use the lower rate for control of

### annual bluegrass and common chickweed; use the higher rate for control of rattail fescue, wild oats, and other weeds listed.
After weed emergence: 

### Apply Willowood Ethofumesate SC at earliest possible weed growth stage but not later than the 4-leaf stage. Rattail fescue, wild oats, and volunteer cereals which are more difficult to control, must be treated no laterthan the 2-leaf stage. Apply 2 1/4 to 3 3/4 pints per acre. Use the highest rate where rattail fescue, wild oats, and volunteer cereals are present and where weed infestation is heavy. ESTABLISHED STANDS OF PERENNIAL RYEGRASS AND TALL FESCUE Before weed emergence: 

### Apply Willowood Ethofumesate SC at 2 1/4 to 3 3/4 pints per acre prior to weed emergence. Use higher rate where rattail fescue, wild oats, and volunteer cereals are expected to be a problem. For best results, apply to moist soil. Crop residue and debris will reduce effectiveness of treatment and should be removed or destroyed. After weed emergence: 

### Apply Willowood Ethofumesate SC at earliest possible weed growth stage but not later than the 4-leaf stage. Rattail fescue, wild oats, and volunteer cereals which are more difficult to control, must be treated no laterthan the 2-leaf stage. Apply 2 1/4 to 3 pints per acre. Use the higher rate where rattail fescue, wild oats, and volunteer cereals are present. Where weed pressure is very heavy and rattail fescue is at the maximum stage of growth for treating, a rate of 3 3/4 pints of Willowood Ethofumesate SC is recommended. ESTABLISHED STANDS OF BENTGRASS 

### Apply only to well-established stands which have been seeded for not less than 12 months. Straw from previous crop must be removed or destroyed. Failure to do so may result in reduced weed control. Before weed emergence: 

### Apply Willowood Ethofumesate SC at 1 

### 1/2 to 3 pints per acre prior to weed emergence. Use higher rate where rattail fescue, wild oats, and volunteer cereals are expected to be a problem. For best results, apply to moist soil. After weed emergence: 

### Apply Willowood Ethofumesate SC at earliest possible weed growth stage, but no later than the 4-leaf stage. Rattail fescue, wild oats, and volunteer cereals which are more difficult to control, must be treated no later than the 2-leafstage. Apply at the rate of 1 1/2 to 3 pints per acre. Use higher rate when rattail fescue, wild oats, and volunteer cereals are a problem. Do not apply more than 3 pints ofWillowood Ethofumesate SC per acre on bentgrass. ESTABLISHED STANDS OF KENTUCKY BLUEGRASS (UNDER IRRIGATION ONLY)



### 27

### Apply only to established stands which have been seeded for at least 12 months. Crop residues, carbon, and debris should be removed. Failure to do so may result in reduced weed control. Willowood Ethofumesate SC is compatible with currently labeled grass seed herbicides. Consult your local fieldman for recommended uses. Before weed emergence: 

### Apply Willowood Ethofumesate SC at 2 pints per acre prior to weed emergence. For best results, apply to moist soil. Apply at least 1/2 inch irrigation within 2 to 3 days after treatment to incorporateWillowood Ethofumesate SC. After weed emergence: 

### Apply Willowood Ethofumesate SC at 2 pints per acre at the earliest possible weed growth stage, but no later than the 4-leaf stage. For best results, apply to moist soil. Apply at least 1/2 

### inch irrigation within 2 to 3 days after treatment to incorporate Willowood Ethofumesate SC. USE PRECAUTIONS 

### Willowood Ethofumesate SC may cause stunting and stand reduction of newly seeded perennial ryegrass and tall fescue if the crop is planted late in the fall and subjected to adverse climatic conditions or pesticides which restrict nonmal growth. Ifvegetative matter or stoverfrom previous crop was burned, sufficient rainfall or overhead irrigation must have occurred to diss·lpate the charcoal residue remaining after burning p(lor to Willowood Ethofumesate SC treatment. Failure to allow for dissipation ofcharcoal residue may result in reduced weed control. COMMERCIAL SOD PRODUCTION (For use in California, Idaho, Nevada, Oregon, and Washington only) GENERAL INFORMATION 

### Willowood Ethofumesate SC is a selective herbicide for use in established and newly planted tall fescue and perennial ryegrass grown for sod in California, Idaho, Nevada, Oregon, and Washington. Willowood Ethofumesate SC may be applied preemergence or postemergence for the control of weed 

### species listed below. Overhead irrigation or rainfall shortly afterapplication is necessaryfor activation. Do not harvesttreated sod for 16 days following application. Residual control of weeds is dependent upon soil moisture conditions; rate of herbide used, and soil texture. The activity of Willowood Ethofumesate SC in the soil texture becomes finer and organic matter/thatch increases. WEEDS CONTROLLED 

### Annual bluegrass Poa annua 

### Large crabgrass Digitaria sanguinalis 

### Green foxtail Setaria viridis 

### Yellow foxtail Setaria glauea 

### Canarygrass Phalaris eanariensis 

### Volunteer barley Hordeum 

### sp. Volunteer wheat Triticum 

### sp. Wild oats Avena fatua 

### Ratta

### iI fescue Festuea myuros 

### Common velvetgrass Holcus lanatus 

### Mannagrass Glycer/a 

### sp. Downy brome Bromus teetorum 

### Soft chess Bromus mollis 

### Spray equipment: 

### Use a fixed-boom power sprayer properly calibrated to a constant speed and rate of delivery. Do not use smaller than a 50-mesh strainer. Avoid overlapping of spray swath. Shut 

### off boom


### 28

### while starting, turning, or stopping to avoid over-application. Make applications in 10 to 50 gallons of water per acre at low pressure (20 to 50 psi). Soil preparation: All existing vegetative matter should be thoroughly worked into the soil surface before planting. Large clods, trash, or vegetative matter left on the soil surface will reduce effectiveness of the Willowood Ethofumesate SC treatment. NEWLY PLANTED PERENNIAL RYEGRASS AND TALL FESCUE GROWN FOR SOD Apply Willowood Ethofumesate SC to newly planted areas when crop reaches the 2-to 3-leaf stage of growth. For best results, apply to moist soils. Before weed emergence: Apply Willowood Ethofumesate SC at 2 1/4 to 3 pints per acre prior to weed emergence. Use the higher rate where rattail fescue, wild oats, and volunteer cereals are expected to be a problem. After weed emergence: Apply Willowood Ethofumesate SC at earliest possible weed growth stage but no later than the 4-leaf stage. Rattail fescue, wild oats, and volunteer cereals which are more difficult to control, must be treated no later than the 2-leaf stage. Apply Willowood Ethofumesate SC at 2 1/4 to 3 pints per acre. ESTABLISHED PERENNIAL RYEGRASS AND TALL FESCUE SOD For preemergence and/or postemergence control of susceptible weeds, apply Willowood Ethofumesate SC prior to weed emergence or at the earliest possible weed growth stage, but not later than the 4-leaf stage. For best results, apply to moist soils. Apply Willowood Ethofumesate SC at 2 1/4 to 3 pints per acre. Repeat applications at 4 to 8 week intervals may be needed to maintain weed control. DO NOT apply more than 1 gallon ofWillowood Ethofumesate SC per acre per growing season. USE PRECAUTIONS Willowood Ethofumesate SC may cause stunting, and stand reduction of newly seeded perennial ryegrass and tall fescue, if the crop is planted late in the fall and subjected to adverse climatic conditions or pesticides which restrict normal growth. Ifvegetative matter or stoverfrom previous crop was burned, sufficient rainfall oroverhead irrigation must have occurred to dissipate the charcoal residue remaining after burning prior to Willowood Ethofumesate SC treatment. Failure to allow for dissipation ofcharcoal residue may result in reduced weed control. STORAGE AND DISPOSAL Do not contaminate water, food, orfeed by storage or disposal. PESTICIDE STORAGE: Protect product from freezing temperatures. PESTICIDE DISPOSAL: Pesticide wastes are acutely hazardous. Improper disposal of excess pesticide, spray mixture, or rinsate is aviolation of Federal law. Ifthese 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 Regional Office for guidance. CONTAINER DISPOSAL: Nonrefillable container. Do not reuse or refill this container. Triple rinse container (or equivalent) promptly after emptying. (Nonrefillable container,; 5 gallons): 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 1/4full with water and recap. Shake for 10 seconds. Pour rinsate into application equipment or a mix tank or store rinsate for later use or disposal. Drain for 10 seconds after the flow begins to drip. Repeat this procedure two more times. Then offerfor recycling ifavailable or puncture and dispose of in a sanitary landfill, or by incineration, or, ifallowed by state and local authorities, by burning. If burned, stay out ofsmoke. (Nonrefillable > 

### 5 gallons): Triple rinse as follows: Empty the remaining contents into application eqUipment or a mix tank. Fill the container 1/4 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



### 29

### tank or store rinsate for later use or disposal. Repeat this procedure two more times. Then offer for recycling if available or puncture and dispose of in a sanitary landfill, or by incineration, or, if allowed by state and local authorities, by burning. If burned, stay out ofsmoke.

CONDITION OF SALE AND LIMITATION OF WARRANTY AND LIABILITY NOTICE: 

### Read the entire Directions for Use and Conditions of Sale and Limitation of Warranty and Liability before buying or using this product. If the terms are not acceptable, return the product at once, unopened, and the purchase price will be refunded. The Directions for Use of th'ls product must be followed carefully. It is impossible to eliminate all risks inherently associated with the use of this product. Ineffectiveness or other unintended consequences may result because ofsuch factors as manner of use or application, weather, presence of other materials or other influencing factors in the use of the product, which are beyond the control of Willowood, LLC or Seller. To the extent consistent with applicable law, all such risks shall be assumed by Buyer and User, and Buyer and User agree to hold Willowood, LLC and Seller harmless for any claims relating to such factors. Willowood, LLC warrants that this product conforms to the chemical description on the label and is reasonably fit for the purposes stated in the Directions for Use, subject to the inherent risks referred to above, when used in accordance with directions under normal use conditions. This warranty does not extend to the use of this product contrary to label instructions, or under abnormal conditions or under conditions not reasonably foreseeable to or beyond the control of Seller or Willowood, LLC, and Buyer and User assume the risk of any such use. TO THE EXTENT CONSISTENT WITH APPLICABLE LAW, WILLOWOOD, LLC MAKES NO WARRANTIES OF MERCHANTABILITY OR OF FITNESS FOR A PARTICULAR PURPOSE NOR ANY OTHER EXPRESS OR IMPLIED WARRANTY EXCEPT AS STATED ABOVE. To the extent consistent with applicable law, neither Willowood, LLC nor Seller shall be liable for any incidental, consequential or special damages resulting from the use or handling of this product. TO THE EXTENT CONSISTENT WITH APPLICABLE LAW, THE EXCLUSIVE REMEDY OF THE USER OR BUYER, AND THE EXCLUSIVE LIABILITY OF WILLOWOOD, LLC AND SELLER FOR ANY AND ALL CLAIMS, LOSSES, INJURIES OR DAMAGES (INCLUDING CLAIMS BASED ON BREACH OF WARRANTY, CONTRACT, NEGLIGENCE, TORT, STRICT LIABILITY OR OTHERWISE) RESULTING FROM THE USE OR HANDLING OF THIS PRODUCT, SHALL BE THE RETURN OF THE PURCHASE PRICE OF THE PRODUCT OR, AT THE ELECTION OF WILLOWOOD, LLC OR SELLER, THE REPLACEMENT OF THE PRODUCT. 

### Willowood, LLC and Seller offer this product, and Buyer and User accept it, subject to the foregoing Conditions of Sale and Limitation ofWarranty and Liability, which may not be modified except by written agreement signed by a duly authorized representative ofWillowood, LLC.
[EPA approval date]



### 30

# NOTE FORRECORD

EPAReg.

## No.1 File Symbol: 87290-R
ProductName: Willowood Ethofumesate SC ApplicationDated: January 5, 2010

ActionDescription: New EndUse Product(Ethofumesate)for commercial turfproduction, sugarbeets, carrots, gardenbeets, onions, garlic and shallots
Comments:
PRODUCT CHEMISTRY: -Basic CSF dated 11512010 was found acceptable by TRB. -ProductChemistry datarequirements for GroupA and Group B are satisfiedwiththeir

own submitted studies (MRlDs 479487-01 and 479487-02). -The oneyear storage stability and corrosioncharacteristics datamust stillbe satisfied. -TRB finds thisproposedproductto be substantially similarto EPA Reg. No. 70506-106
ACUTE TOXICITYREVIEW: -Registrantisusingthe CITEALL option for acute tox. -Signal Word: not required as all aretox. cat. IV, howeverregistrant is optingto use CAUTION labeling
DATA COMPENSATION: -Cite all underthe selectivemethod forthe acute tox. studies supportingEthofumesate -Formulator's Exemptionlistingtechnical sources ofEthofumesate onthebasic CSF to covergeneric data compensationrequirements. -Certificationwith Respect to CitationofData: Selective Methodwith Offerto Pay Ethofumesate data submitters
LABELREVIEW: 1. Minortechnical revisions of'General' and "recommendedrates" 2. Rate changesto matchthe EthofumesateRED 3. Ag. Use Requirements box changesto matchRED 4. Addaerial applicationuseraterestriction for sugarbeetsperthe RED 

# ** NOTE: The cited**prod~~t** 

### (70506-106) label thatwas accep

.ted. May22,2009needs**~ese** 

# J

same label reVISIOns./, 11

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### DATA GAPS: Storage Stability(830.6317) Corrosion Characteristics (830.6320)

### DATE OUT: 09 Mar2010 SUBJECT: PRODUCT CHEMISTRY REVIEW DP BARCODE No.: 

### D373563 Reg. File Symbol No.: 

### 87290-R MP 

## [1 EP 

### [x

## 1

PRODUCT NAME: 

### Willow60d Ethofumesate SC COMPANY: 

### Willowood LLC Decision No.: 

### 425897 FOOD USE: [

### x

## 1 PC CODE: 

### 110601 Integrated Formulation [ 

## 1
FROM: 

### Bruce F. Kitchens, Chemist Technical Review Branch Registration Division (7505P) 

# 13't<tt1&'1

# ~~ 01 0fp/At. UfO r
TO: 

### RM #23, Kathryn Montague/Bethany Benbow Herbicide Branch (7505P) Registration Division (7505P INTRODUCTION:

# ~ ){1' 

# o)llJ

The registrant, Willowood LLC, is submitting an application to registerthe proposed enduse product, Willowood Ethofumesate SC. The active ingredient in this product is Ethofumesate (97.7% pail at a label nominal concentration of42.0% a.i. In addition, the registrant states that the proposed product is substantially similar to EPA Reg. No. 70506-106 Etho SC This product is intended for use as a food use herbicide. In support ofthis request, the registrant has submitted a basic Confidential Statement of Formula (CSF) dated 05 Jan 2010, a draft label, and product chemistry data contained in MRID#s 479487-01,479487-02 and 479487-03. The Technical Review Branch (TRB) has been asked to review this submission.

SUMMARY OF FINDINGS 

### TRB has reviewed this submission and reports the following findings: 1. This product is produced from registered sources ofthe active ingredient. 2. All inert ingredients are approved for use in formulated pesticide products. In addition, all inert ingredients are exemptfrom the requirement ofa food tolerance when applied preplant. 3. The nominal concentration ofthe active ingredient listed on the proposed basic CSF and the draft label are the same. 4. The draft label contains the appropriate storage and disposal statements. 5. The active ingredient's certified limits as proposed on the basic CSF are acceptable. 6. The comparison ofthe cited and proposed products reveals that both products have the same active ingredient, the same active ingredient nominal concentration, and similar inert ingredients.
7. The registrant has requested awaiver (MRID# 479487-03) for several physical and chemical properties data requirements. Several ofthe data requirements are not applicable to the proposed end-use product and several ofthe data requirements are only applicable to technical grade active ingredients (TGAI).CONCLUSIONS:
TRB has reviewed this submission and concludes the following:
1. The basic formula CSF for the proposed end-use product, Willowood Ethofumesate dated 05 Jan 2010 is acceptable.
2. This submission (MRID# 479487-01) satisfies the data requirements as specified in 40 CFR 158.320, 158.325, 158.335, 158.340, 158.350, and 158.355with respect to product identity and composition, description of materials used to produce the product, description offormulation process, discussion offormation of impurities, certified limits, and enforcement analytical method.
3. Except for storage stability/corrosion characteristics studies, the remaining product chemistry Group B data (MRID#479487-02) adequately fulfill the data requirements specified in 40 CFR 158.310with respect to physical and chemical properties. Inform the registrant that 1-year studies are required to satisfy the storage stability and corrosion characteristics data requirements.
TRB has reviewed the requests forwaiver ofseveral physical and chemical properties data requirements and determined that a request for waiver ofthese data requirements is not necessary because in most instances the data requirement is not applicable (e.g.) viscosity would not be applicable to a solid material. In addition, several physical and chemical properties data requirements apply only to TGAls. Please consult the 40 CFR for the table of physical and chemical properties data requirements which provides a list offootnotes which further detail a data requirement's applicability. Ifquestions arise do not hesitate to contact the product chemistry team.
4. The proposed product is substantially similar in composition to EPA Reg. No. 70506-106 Etho SC from a product chemistry standpoint.

PRODUCT CHEMISTRY DATA (SERIES 830 Subgroup A)

Subgroup A

- Product Identity and Composition Data Reguired MRID No. Fulfilled
830.1550. Chemical Identity Y 479487-01 830.1600. Beginning Materials Y 479487-01 830.1650. Formulation Process 

### Y 479487-01 830.1670. Discussion of Impurities 

### Y 479487-01 830.1700. PreliminaryAnalysis NA 830.1750. Certified Limits 

### Y see csf 1/5/10 830.1800. Enforcement Analy1ical Method 

### Y 479487-01

2PRODUCT CHEMISTRY DATA (SERIES 830 Subgroup B)

Data Required Value or MRID No. Subgroup B - Physical and Chemical Properties Fulfilled Qualitative Descrigtion
830.6302. Color NR
830.6303. Physical State Y Liquid @ 21°C 479487-02
830.6304. Odor NR
830.6314. Oxidation/Reduction Action Y Product did not 479487-02 react when mixed with Fe, H20 ,& monoammoniu m phosphate. Large temperature increase when mixed with potassium permanganate
830.6315. Flammability Y >98oC 479487-02 (flashpoint)
830.6316. Explodability NA Product does not contain explosive components
830.6317. Storage stability G
830.6319. Miscibility NA Product not an EC 

### nor mixed with petroleum solvents
830.6320. Corrosion Characteristics G
830.6321. Dielectric Breakdown Voltage NA Product not used around electrical equipment
830.7000. pH Y 6.98@250C 479487-02
830.7100. Viscosity Y 3480 mPa's@ 479487-02 22'C
830.7000. Density/Bulk Density Y 1.15@22oC 479487-02 (Relative DensityO Explanations: A

## = The Requirements Were Fulfilled; N

## =The Requirements Were Not Fulfilled; NA

## =Not Applicable; G

## =Data Gap; U

## =Requires Upgrading; I

## =Incomplete or In Progress; W

## = Waived.

3Enforcement Analytical Method: (MRID No.479487-01)
The active ingredient, Ethofumesate, was determined by high performance liquid chromatography (HPLC) using ultraviolet detection (UV) at252 nm. Sample is dissolved in a solution ofcitric acid and methanol, filtered, and injected on the HPLC. Samples were analyzed in duplicate. Method validation data not presented. Equipment and Parameters
Instrument: Detector: Wavelength: Column: Sample Size: Mobile Phase: Flow Rate: High Performance Liquid Chromatograph (HPLC) Ultraviolet detector (UV) 252 nm Prodigy ODS(3),**5~m,** 1liD 

### x 4.6 mm 5.0**~I** Acetonitrile:THF:Water 

### 32.5/10/57.5; adjustto pH 

### 4 with citric acid 2.0 mllmin

4EPAFile Symbol 87290-R PC Code 110601 (ethofumesate)



### UNITED STATES ENVIRONMENTALPROTECTIONAGENCY WASHINGTON, D.C. 20460

OFFICE OF PREVENTION,PESTICIDES AND TOXIC SUBSTANCES


### TECHNICAL REVIEWBRANCH SIMILARITYCLINIC DETERMINATION


## 251FEB12010
MEMORANDUM
Subject:

From:

To:

Applicant: Name ofPesticideProduct: EPAReg. No. IFile Symbol: 

## DP Barcode: DecisionNo: Action Code: PC Code: EugeniaMcAndrew, Biologist Technical ReviewBranch Registration Division(7505P) BethanyBenbow, RM Team23 Herbicide Branch Registration Division(7505P) Willowood, LLC 8690 Lookingglass Road Roseburg, OR97470

FORMULATIONFROM LABEL:
Active Ingredient(s): Ethofumesate
Inert Ingredient(s): WillowoodEthofumesate SC 87290-R D373565 425897 R300 110601 (ethofumesate)

Total: % 

### bywt. 42.0
58.0 100.0%



### ACTIONREQUESTED: The RiskManagerrequests: Registrant is claiming substantial similarityto EPAReg. No. 70506-106.
Page 1of3EPAFile Symbol 87290-R PC Code 11060I (ethofumesate)



### BACKGROUND: 

### Willowood, LLC has applied for registration ofWillowoodEthofumesate SC, EPAFile Symbol 87290-R, claiming similarityto Etho SC, EPAReg. No. 70506-106. The active ingredient inbothproducts is 42% ethofumesate. The Registrant is usingthe cite-all method ofdata supportto satisfY the acute toxicity datarequirements.
A search ofthe OPP electronic databases shows that acutetoxicity datawere citedto supportthe reregistrationofthe cited product, 70506-106, in aProductReregistrationBranch memo (Dupuy; D361681; 31!MARl2009). Anacute toxicityprofile was assignedto 70506-106 inthe samememo.

RECOMMENDATIONS:
1. 

### TRB has evaluated the formulations ofthe proposed product, 87290-R, and the cited product, 70506-106, andhas determinedthatthetwo products are substantially similar.
2. The acute toxicity profile for the proposed product, Willowood Ethofumesate SC, EPA File Symbol 87290-R, is as follows:

acute oral toxicity 

## IV cited EPAReg. No. 70506-106 acute dermaltoxicity 

## IV cited EPAReg. No. 70506-106 acute inhalationtoxicity 

## IV cited EPA Reg. No. 70506-106 primary eye irritation 

## IV cited EPAReg. No. 70506-106 primary skin irritation 

## IV cited EPAReg. No. 70506-106 dermal sensitization negative* cited EPAReg. No. 70506-106
*This study was classified as positive in the 31!MARl2009 memo but by today's standards it is classified as negative.
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 ofthis action, TRB has made no further determination ofthe adequacy ofthe toxicological database or theprecautionarylabel ofthe citedproduct.
4. The proposed basic CSF dated January 5, 2010 should be approved by the TRB Product Chemistry Team.

LABELING: 

### Based onthetoxicityprofile above, the following are the precautionary and first aid statements for this productas obtainedfrom the Label ReviewSystem:

PRODUCT ID #: 087290-00001 

### PRODUCT NAME: 

### Willowood Ethofumesate SC

Page2of3EPAFile Symbol 87290-R PC Code 110601 (ethofumesate)



### SIGNAL WORD: (Optional) 

### PRECAUTIONARY STATEMENTS
CAUTION



### Hazards to Humansand DomesticAnimals:
Wear: Long-sleeved shirt and long pants, socks, shoes, and chemical-resistant gloves (such as Natural Rubber, Selection CategoryA).


### FirstAid: No statements are required. Category III statements may be used.

Page 3 of3

## PYXIS REGULATORY CONSULTING, INC. 4110136'" SI. NW Gig Harbor, WA 98332

COURIERDELIVERY Kathryn Montague (PM 23) DocumentProcessing Desk 

### (REGFEE) Office ofPesticidePrograms (7504P) U,S, Environmental Protection Agency Room S-4900, OnePotomacYard 2777 S, Crystal Drive Arlington, VA 22202-4501 January 5, 2010



### RE: Willowood, LLC

- Willowood Ethofumesate SC (EPA Reg, No, 87290- Application forNewPesticide Registration
Dear Ms, Montague, ) 

### Phone: 253-853-7369 Fax: 253-853-5516 www.PyxisRC.com



### 479487·00

On behalf of Willowood, LLC please find the enclosed application for registration of Willowood Ethofumesate SC, an end-use product containing ethofumesate as the active ingredient. In support ofthis application, we submitthe following documents: I, Application for Registration (EPA Form 8570-1) 2, Receipt ofPRIApre-payment from pay,gov 3, Fee Waiver request and supporting documentation 4, Confidential Statement ofFormula(BasicFormulation dated January 5, 20I0) 5, Formulators Exemption Statement (EPAForm 8570-27) 6, Five (5) copies ofthe proposed labeling 7, Certificationwith Respectto Label Integrity 8, Electronic copy ofthe Willowood Ethofumesate SC label on CD 9, Certificationwith Respect to Citation ofData (EPA Form 8570-34) 10, Agency Internal Use Copy ofthe DataMatrix (EPA Form 8570-35) 

### II. Public File Copy ofthe DataMatrix (EPA Form 8570-35) 12, Letter ofAuthorization 13, Product SpecificData: Volume I 830,1550,830,1600, Kellogg, M, Product Identity and Composition, Description ofthe 830,1650,830,1670, Materials Used, Description ofthe Formulation Process, Discussion 

### 47948701 830,1750, 830,1800 ofthe Formation ofImpurities, Certified Limits, and Analytical Methods to Verify Certified Limits for Willowood Ethofumesate SC, Volume 2 830,6303,830,6314, Sinning, D, Physical and Chemical Characteristics ofEthofume·cate 

### 47948702 830,6315, 830,7000, SC: Physical State, Oxidation/Reduction, Flul,l,l,[.tility, 

### pH, 830,7100,830,7300 Viscosity and Relative Density, Volume 3 830,6302, 830,6304, Kellogg, M, Waiver Request for Certain Datdhq,,:rements for 830,6313,830,6316, Willowood Ethofumesate Sc. 830,6319, 830,6321, 

### 47948703 830,7050, 830,7200, 830,7220, 830,7370,

### 830.7520,830.7550- 830.7570,830.7840- 830.7860,830.7950 K. Montague January 5, 2010 Page 2 of2



### Willowood, 

### LLC believes its product, Willowood Ethofumesate SC, is substantially similarto a currently registered product (EPA Reg. No. 70506-106). Willowood, 

### LLC believes this application falls under Category R300 (44) since Willowood Ethofumesate SC is a new product, substantially similar in composition and use to a registered product, only product chemistry data are being submitted to support the application for registration and the cite-all option under the selective method is being used to support product specific acute toxicity data requirements. 

### In addition, the technical source(s) ofactive ingredient are based on a registered source of supply and therefore, Willowood Ethofumesate SC qualifies for Formulators Exemption for ethofumesate generic datarequirements. Willowood, 

### LLC is requesting a 50% small business fee waiver for this action and has paid 50% ofthe R300 fee, or$682.50. We trust you will find this application complete and in compliance with the requirements for registration under FIFRA. Please feel free to call me ifyou have any questions orneed any additional information.

Michael Kellogg

Enclosures
cc: B. Heinze; Willowood, 

### LLC

# &EPA United States 

### Environmental Protection Agency Washington, DC 20460 

### Application for Pesticide

- Section I opp Identifier Number

1, Company/Product Number 

### 87290- 

# R
4, Company/Product (Name) 2. EPA Product Maneger K. Montague PM' 3. Proposed Classification 

# [2] None 

# 0 Restricted
Willowood, LLC I Willowood Ethofumesate SC 

### 23 5. Name and Address of Applicant /Include ZIP Code)

Willowood, LLC c/o Pyxis Regulatory Consulting, Inc. 4110 136th SI. NW 6. 

### Expedited Reveiw. In accordance with FIFRA Section 3(c)(3) (b)(i), my product is similar or identical in composition and labeling to: 

### EPA Reg. No. _70_5_0_6_-1_0_6___________ _ Gig Harbor, WA 98332 Etho SC 

# o Check ifthis is 8 new address 

### Product Name 

# o o o Section

- II
Amendment

- Explain below.
Rasubmission in response to Agency letter dated
______ _ Notification

- Explain below, 

# u [2] 

# o Explanation: Use additional page(s) if nacessary. (For section I and Section IJ.) Final printed labels in repsonse to Agency letter deted "Me Too" Application.
Other**~** Explain below.

This application falls under Category R300 (44) as it is a new product substantially similar in composition and use to a registered product, only product chemistry data are being submitted and the cite-all method ofdata support is being used to support product specific acute toxicity data requirements. The fee due is $1365.00 and the decision timeline is 3 months. However, Willowood, LLC is requesting a 50% fee waiver. A receipt of PRIA pre-payment from pay.govfor 50% ofthe R300 PRIA fee ($682.50) is included with this application. Should you have any questions, please contact me at (email) Mike@PyxisRC.com or (phone) 253-853-7369. 

### Section

- III
1. Matarial Thi. Product Will Be Packaged In: Child-Resistant Packaging Unit Packaging 

# Ej**~:s @~:s**  Water Soluble Packaging 

# o Y.s 2. Type of Container

# ~::~Ic [{] No



### • Certification must be submitttHI If "Yes" No. per If "Yes" Package wgt Unit Packaging wgt. container

3. Locetion of Net Contents Information



## [{J Lab.1 

# U Container 6. Manner in Which Label is Affixed to Product 4. Size(s) Reteil Container 2.5,5 gallon 

# LJ Uthograph

J Paper glued Stanciled I



### Section

- IV No. per container Glass Paper Othar (Specify)
________

### 1

1 5. Location of Label Directions J ,. On Label 

# t:=:3 On Labeling accompanying product 

# o Other

1. Contact Point (Comp/9t(J it(Jms dir9ct/y b(Jlow foridfNItificstion ofindfvidus/to be contact(Jd, ifn8c(Jsssry, to proc(J$S this application.) Nama

Michael Kellogg Titla Agent Telephone No. (Include Area Code) 

### (253) 853-7369 , Certification ) ;. ) ) J ) 

### , ,
J certify that the stetements I have made on this form end all attachments thereto are true, accurate and

### con,iplet~. I acknowledge that any knowlinglly false or misleading stetement may be punishable by fine or imprisonment)u-' ; -' ) both under applicabla lew.**~** ,

### ~------~~-------------------,--------------------------~~ 3, TItle

Agent
4. Typed Name " 5. Data

Michael Kellogg

EPA Form 8570·1 lR.v. 3·94) PreVIOUS editions are obsolete. White

- EPA File Copy (onglnel) 6. O':tta Application RecaioJed 

### (Stampedl 

## " 

# .
;, j

, l J "

v,now - AppHcant Copy

### • 411O 136th 

### St. NW GigHarbor, W A 98332
November9, 2009 

## WILLOWOOD, LLC Phone: 253-853-7369 Fax: 253-853-5516

DocumentProcessingDesk(COADR) OfficeofPesticidePrograms (7504P) 

# u.s. Environmental ProtectionAgency Room S-4900, OnePotomacYard 2777 S. Crystal Drive Arlington, VA 22202
To Wbom It

### May Concern:
RE: LetterofAuthorization
Please let this letter serve to notity you that Pyxis Regulatory Consulting, Inc. (contact information below) is authorized to represent Willowood U.S.A., LLC (Co. No. pending) as authorized agent before the U.S. Environmental Protection Agency in all matters regarding our pesticide registrations and applications for registrations pursuant to the Federal Insecticide, Fungicide and Rodenticide Act (FIFRA), 7 USC Section 136 et seq. Direct all official correspondence from EPAto: 

### Agent: PyxisRegulatory ConSUlting, Inc. 4110 136th 

### St. NW GigHarbor, WA 98332 T: (253) 853-7369 F: (253) 853-5516 info@PyxisRC.com
Ifyouhave any questions, please do nothesitate to contactme
. Sincerely,

# ~ BrianHeinze
President WiIIowood, LLC 

# ...

cc: Pyxis Regulatory Consulting,Inc. l:J.l) J 1

l) i I) 

# . ,

### ) Form approved. OMB No. 2070-0060,**2070-0u~(,** 2070-0107, 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 Symbol/Registration Number 

### Willowood, LLC 87290- 8690 Lookingglass Road Product Name 

### Roseburg, OR 97471 Willowood Ethofumesate SC D
Date of Confidential Sta1ement of Formula (EPA Form 8570-4) 

### 01105/2010 As an authorized representative ofthe applicant for registration ofthe product identified above, I certify that: (1) This product contains the following active ingredient(s): 

### Ethofumesate

(2) Ofthese, each active ingredient listed in paragraph (4) is present solely as the result of1he use ofthat active ingredient in the manufacturing, formulation or repackaging another productwhich contains that active ingredient which is registered under FIFRA Section 3, is purchased by us from another person and meets the requirements of40 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 ofFormula (EPA FORM 8570-4) for the above identified product is attached to this statement. That formula statement indicates, by company name, registration number, and product name, the source of the active ingredient(s) listed in paragraph (1). OR


# ., (B) The Confidential Statement of Formula (CSF)(EPA Form 8570-4) referenced above and on file with the EPA is complete, current, an accurate and contains the information required on the current CSF. (4) The following active ingredients in this product qualifyfor the formulator's exemption.

Source
Active Ingredient Product Name Registration Number 

### Ethofumesate 

### ,**~** 

### ,**~ ~**  a J _ 

### ,

,

,

, 

### , , 

### , 

## , , 

### " ,

, , , 

# ., } ) .) j :.

# ;;;_llJAJ~ Name and Title Date 

### , 

# Ilr/.. }**~** J**~** 

### Michael Kellogg 

### 1Agent D 

### A' 

## "**E~A** Form 85110-27 (Rev.**06-20~**

# V Copy 1 - EPA Copy 2 - Applicant copyForm OMS No.**"""",~** UNITED STATES ENVIRONMENTAL PROTECTION AGENCY



### . ft)

## ~~, 401 M Street, S.W. WASHINGTON, D.C. 20460
PapeIWork Reduction Act Notice: The pubic reporting burden forthis collection ofinformation is estimated to average 1.25 hours perresponse for registration and 0.25 hours per response for reregistration and special review activities, including time for reading the instructions and completing the necessary fonns. Send comments regarding bLCden estimate or any otheraspect ofthis collection ofinfonnation, including suggestions for reducing the burden to: Director, OPPE Infonnation Manag:l:ment Division (2137), U.S. Environmental Protection Agency, 401 M Street. S.w., Washington, DC 20460. Do not send the completed funn to this address. Certificationwith Respectto Citation ofData Applicanfs/Re!=)istranfs Name, Address, and Telephone Number EPA ReQistration Number/File Symbol

ill LLC c/o Pyxis Regulatory**Cons~lting,** Inc.; 4110 136th 81. NW Gig Harbor, WA 98332, (253) 853-7369 87290· Active Inaredient(s) and/orreoresentative test comoound(s) Date Ethofumesate January 5, 2010 General Use Patlem{s) {fist all those claimed forthis productusinQ 40 CFR Part 158} Product Name Terrestrial Food/Nonfood Wiffowood Ethofumesate SC NOTE: Ifyour product is a 100% repackaging ofanotherpurchased EPA-registered product labeled for all the same uses on your label, you do not need to submit this form. You must submit the Formulators Exerrption Statement (EPA Form 8570-27). 

# D I am responding to a Data-CalHn Notice, and have included with this form a list ofcompanies sent offer.; ofcompensation (the Data Matrix form should be used forthis purpose).

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

# D Iam using the ate-all method ofsupport, and have included with this form 

# [2] I am using the selective method ofsupport (or dte-all option a fist ofcompanies sent offer.; ofcompensation (the Data Matrix form underthe selective method), and have included w'lth this form a should be used forthis purpose). completed list ofdata requirements (the Data Matrix form must be used). SECTION II: OFFERTO PAY [Required ifusing the cite-an method orwhen using the dte-an option underthe selective method to satisfy one ormore data requirements] 

# [2] I hereby offer and agree to pay compensation, to other persons, with regard to the approval ofthis application, to the extent required by FIFRA.

SECTION III: CERTIFICATION Icertify thatthis application for registration, this form for reregistration, or this Data-Can-In response is supported by all data submitted ordted in the application for registration, the form for reregistration, orthe Data-Call-In response. In addition, ifthe cite-all option or dte-all option underthe selective method Is indicated in Section I, this application is supported byall data in theAgency's files that (1) concem the properties oreffects ofthis product oran identical or substantially simifar product, or one or more ofthe ingredients in this product; and (2) is a type ofdata thatwould be required to be submitted Llf).der thltdata requirements in effect on the date ofapproval ofthis application ifthe application sought the initial registration ofa product of identical or similarJC0m;oosition and uses.**~** 

### " } 

### , ) } 

### ,
, 

### , , , 

### , , , Icertify that foreach exdusive use study dted in support ofthis registration orreregistration, that Iam the original data**subm~ter** orthat Ihave obtained the written permission ofthe original data submitterto cite that study. " Cj } ) ;;**~** 

### , 

### , , Icertify thatfor each study cited in support ofthis registration orreregistration that is notan exdusive use study, either: (a) I)am the**ogg~rfa~dcla** submitter, (b) Ihave obtained the permission ofthe original data submitterto use the study in support ofthis application; (c) all :mriZldDofefigibifityi!for ) compensation have expired for the study; (d) the study is in the public literature; or(e) Ihave notified in writing the company that**sU9mitt~d** the study c.:nd have offered (I) to pay compensation to the extent required by sections 3(c)(1)(F) and/or 3(c)(2)(S) ofFIFRA; and Qi) to commence**n~'bMtbns** to**det~mine)the** amount and terms ofcompensation, ifany, to be paid for the use ofthe study. } li**~** " 1> ) 

### , Icertify that in all instances where an offer ofcompensation is required, copies ofan offers to pay compensation and evidence oftheir**<teli~e'ij** i$l accordance with sections 3(c)(1)(F) and/or 3(c)(2)(S) of FIFRA are available and will be submitted to the Agency upon request. Shoud Ifaif to**prcJ{H!I~such** evidence to theAgency upon request, Iunderstand that theAgency may initiate action to deny, cancel orsuspend the registration ofmy product in conformity with FIFRA. I certify thatthe statements I have made on this form and alt attachments to it are true, accurae, and complete. I acknowedge that any knowingly fatse or misleadi'l) statement may be punishable bjfine or imprisonment or both under appticable law,

# :;::.(~~ Date 

### /- Typed or Printed Name and Title 

# d" Michael Kellogg; Agent PA Form 8570-34 (9'97) i ••

### ,,,v,,. , . Submit only iFormApproved OMB No, 2070-0060 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 

### 401 M Street, S.W. WASHINGTON, D.C. 

### 20460 Paperwork Reduction Act Notice: The public reporting burdenfor this collection of infonnation is estimated to average 0.25 hours per response for registration activities and 0,25 hours per response for reregistration and special review activities, includingtimefor reading the instructions and completing the necessaryfonns. Send comments regarding the burden estimate orany other aspect ofthis collection of 'Infonnation, incIud'lng suggestionsfor reduc"lng the burden to: Director, OPPE Information Management D'lv'lsion (2137), U,S. Environmental ProtectionAgency, 401 M Street, S.W., Washington, DC 20460. Do not send thefonn tothis address, DATA MATRIX
Date January 

### 5, 2010 EPA Reg No.fFile Symbol 

### 87290- Page 

## I of 5 Applicant'sfRegistrant's Name & Address Product Willowood, LLC Willowood Ethofumesate SC 

# ,- 8690 Lookingglass Road Roseburg, OR 

### 97471 Ingredient Ethofumesate Guideline Reference Number Guideline Study Name MRID Number Submitter Status Note Product Specific Data Requirements 

### 830.1550 Product**Identi~**and Composition Volume 

### 1 Willowood, LLC OWN 

### 830.1600 Description of Materials Used to Produce the Volume 

### 1 Willowood, LLC OWN Product 

### 830.1620 Description of Production Process Not required' 

### 830.1650 Description of Formulation Process Volume 

### 1 Willowood, LLC OWN 

### 830.1670 Discussion of Formation of Impurities Volume 

### 1 Willowood, LLC OWN 

### 830.1700 Preliminary Analysis Not required' 

### 830.1750 Certified Limits Volume 

### 1 Willowood, LLC OWN 

### 830.1800 EnforcementAnalytical Method Volume 

### 1 Willowood, LLC OWN 

### 830.6302 Color Not reguired 3 

### 830.6303 Physical State Volume 

### 2 Willowood, LLC OWN 

### 830.6304 Oder 

### , <I "",,,,, , 

### 830.6313 Stapilil2

### t~**'N~rmClI'~nd** Elevated Temperatures, Metals, and ,,,letalibns Not required3



### 830.6314 Oxidation/Reduction: Chemical Incompatibility Volume 

### 2 Willowood, LLC OWN 

### 830.6315 ," 1",<lmm<lDiMtv 

### ", Volume 

### 2 Willowood, LLC OWN 

# · 830.6316 : :

### Ei<pICld~~iltv , 

# · Not required' 

### , , Signature
_

## j[!~ , 

# · Name and Title Date Michael Kellogg, Consultant

# //S~!d**~l** . 

# YForm Approved OMS No. 2070-0060 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 401 M Street, S.W. WASHINGTON, D.C. 20460 Paperwork Reduction Act Notice: The public reporting burden for this collection ofinformation is estimated to average 0.25 hours per response for registration activities and 025 hours per response for reregistration and special review activities, including time for reading the instructions and completing the necessary forms. Send comments regarding the burden estimate or any other aspect ofthis collection of information, including suggestions for reducing the burden to: Director, OPPE Information Management Division (2137), U.S. Environmental Protection Agency, 40t MStreet, S.W., Washington, DC 20460. Do not send the form to this address. DATA MATRIX
Date January 

### 5, 2010 EPA Reg No.lFile Symbol 

### 87290- 

# IPage;1 of 5 Applicant's/Registrant's Name &Address Product Willowood, LLC Willowood Ethofumesate SC 

### 8690 Lookingglass Road Roseburg, OR 

### 97471 InQredient Ethofumesate GuideHne Reference Number Guideline Study Name MRID Number Submitter Status Note 

### 830.6317 Storage Stability PRN 

### 92-5s 

### 830.6319 Miscibility . Not required 6 

### 830.6320 Corrosion Characteristics See endnoteS 

### 830.6321 Dielectric Breakdown Voltage Not

### r~uired7 

### 830.7000 pH Volume 

### 2 Willowood, LLC OWN 

### 830.7050 UVNisible Absorption Not

### r~uired3 

### 830.7100 Viscosity Volume 

### 2 Willowood, LLC OWN 

### 830.7200 Meltinq Point/Meltinq Ranqe Not**r~uired3** 

### 830.7220 Boiling Point/Boiling Range Not required3 

### 830.7300 Density/Relative Density/Bulk Density Volume

### 2 Willowood, LLC OWN 

### 830.7370 Dissociation Constants in Water Not

### r~quired3 

### 830.7520 Particle size, fiber length, diameter distribution Not required" 

### 830.7550 Pai:titioh Co":;'ficien; (n-octanol/water), Shake Not required3 Fla3K'r\;1e\hod ' ,

### ~**~** " 

### 830.7560 Partition Coefficient(n-octanol/water), Not required 3 Generator Column Method 

### 830.7570 , ",

### "R~rtitio~"Goefficient0r!-octanolfwater), Not required3 : : E:stirnauGn by Liquid :Chromatography

# ~:.j/) "w " " ,--,.,

",""' "- Name and Title Date Michael Kellogg, Consultant 

# t!.s-l ;;:K!J/QForm Approved OMS No. 2070-0060 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 401 M Street, 

### S.W. WASHINGTON, D.C. 20460 Paperwork Reduction Act Notice: The public reporting burden forthis collection of information 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 instructions and completing the necessary forms. Send comments regarding the burden estimate orany other aspect ofthis collection of information, including suggestions for reducing the burden to: Director, OPPE Information Management Division (2137), U.S. Environmental Protection Agency, 401 M Street, S.W., Washington, DC 20460. Do not send the form to this address. DATA MATRIX
Date JanUary 5, 2010 EPA Reg No.lFile Symbol 87290- 

# 1 Page;) of 5 Applicant's/Registrant's Name & Address Product Willowood, LLC Willowood Ethofumesate SC 8690 Lookingglass Road Roseburg, OR 97471 Ingredient Ethofumesate Guideline Reference Number Guideline Study Name MRID Number Submitter status Note 830.7840 Water Solubility: Column Elution Method; Not required3 Shake Flask Method 830.7860 Water Solubility, Generator Column Method Not r"'9,uired 3 830.7950 Vapor Pressure Not required3

870.1100 Acute Oral Toxicity: Rat Cite-All PAY 870.1200 Acute Dermal Toxicity: Rat Cite-All PAY 870.1300 Acute Inhalation Toxicity: Rat Cite-All PAY 870.2400 Primary Eye Irritation: Rabbit Cite-All PAY 870.2500 Primary Dermal Irritation Cite-All PAY 870.2600 Dermal Sensitization Cite-All PAY**~** " " w",," " " '"**~** v**~** "'"" " " 

### , c'
_ '"

- ., " ' _, ,. '- '- C,"_ ¥

# ::;~:14~" Name and Title Date "**""~** Michael Kellogg, Consultant

# ~Ok , " "

, , , 

### , , ,-

EPA Form 8570-35 (9-97) Electronic and Paperversions available. Submit only Paperversion. Agency Internal Use CopyForm Approved OMS No. 2070-0060 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 401 M Street, S.W. WASHINGTON, D.C. 20460 Paperwork Reduction Act Notice: The public reporting burden for this collection ofinformation 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 instructions and completing the necessaryforms. Send comments regarding the burden estimate or any other aspect ofthis collection of information, including suggestions for reducing the burden to: Director, OPPE Information Management Divis'lon (2137), U.S. Environmental Protection Agency, 401 M Street, S.W., Washington, DC 20460. Do not send the form to this address. DATA MATRIX
Date January 5, 2010 EPA Reg No.lFde Symbol 87290- 

# I Page '{Of 5 Applicant'sJRegistrant's Name &Address Product Willowood, LLC Willowood Ethofumesate SC 8690 Lookingglass Road Roseburg, OR 97471 Ingredient Ethofumesate Guideline Reference Number Guideline Study Name MRID Number Submitter Status Note Willowood Ethofumesate SC ProductSpecific Data Requirements Willowood, LLC is using the cite-all option underthe selective method to satisfy acute toxicity data requirements. Willowood, LLC will make offers-to-payto the following companies on the September 30, 2009 Data Submitters List for ethofumesate. Ethofumesate Product Specific Data Requirements Ethofumesate Product Cite-All Bayer CropScience LP PAY Specific Data Requirements Ethofumesate Product Cite-All Spray Drift Task Force PAY Specific Data Requirements Ethofumesate Product Cite-All United Phosphorus, Inc. PAY Specific Data Requ"rrements Ethofumesate Product Cite-All Outdoor Residential Exposure PAY Specific Data Requirements



# . Task Force Ethofumesate Product**Cite::.Al!~** , 

# · Agricultural Reentry Task PAY y "**.~** 

## · Specific Data Requirements 

## . , Force


## . . ·**Y-,.--~o/--<·** Ethofumesate Product Cite-All FIFRA Endangered Species PAY Specific Data Requirements Task Force, LLC
Signature

# ~fJ/~' 

# · Name and Title Date 

# ·**~~.** A- • • • ':: 

# . · Michael Kellogg, Consultant 

# t!1 

# ;':;;'O/u " 

# · \ /./

EPA Form 8570-35 (9-97) Electronic and Paper versions available. Submit only Paper version. Agency Internal Use CopyForm Approved OMS No. 2070-0060 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 401 M Street, S.w. WASHINGTON, D.C. 20460 Paperwork Reduction Act Notice: The public reporting burden forthis collection ofinformation 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 instructions and completing the necessaryforms. Send comments regarding the burden estimate or any other aspect ofthis collection of information, including suggestionsfor reducing the burden to: Director, OPPE Information Management Division (2137), U.S. Environmental Protection Agency, 401 M Street, S.W., Washington, DC 20460. Do not sendthe form to this address.

Date January_5,2010 Applfcant'sJRegistran1's Name &Address

Ingredient Ethofumesate Guideline Reference Number Ethofumesate Product S[lecific Data Requirements Ethofumesate Product Specific Data Requirements Ethofumesate Product**~cific** Data Requirements Ethofumesate Product Specific Data Requirements Willowood, LLC 8690 Lookingglass Road Roseburg, OR 97471

Guideline Study Name Cite-All
Cite-All
Cite-All
Cite-All

Ethofumesate Generic Data Requirements DATA MATRIX

MRID Number

Willowood Ethofumesate SC qualifies fot Formulator\' Exemption for ethofumesate generic data EPAReg NoJFile Symbol 87290- rPage'£Of 5 Product Willowood Ethofumesate SC

Subm"rtter Status \ Note J&S AgChem, Inc. PAY Agricultural Handlers PAY EX[losure Task Force Source Dynamics, LLC PAY
Generic Endangered Species PAY Task Force

requirements. H ". • " : •• ,' :**,--.,-."~.-----------------,---------+------------------~------~--------~**

# ~J~~ Name and Title Michael Kellogg, Consultant Date 

# Ifs-i:zo/C} '"**~** / 

# -

# . .y/"' • 

# ./' 

# .

EPA Form 8570-35 (9-97) Electronic and Paperversions available. Submit only Paperversion. Agency Internal Use Copy

### Endnotes for Data Matrix forWillowood Ethofumesate SC

1

### 830.1620 _Per OPPTS 830.1000, these data are not required for the registration ofan end-use product. See 830.1650 for formulation process information. 

### 2830.1700

- This product does not consist solely ofthe technical grade active ingredient (TGAI) and is not produced by an integrated system, therefore, per OPPTS 830.1700, these data are not required.

3 

### 830.6302, 830.6304, 830.6313, 830.7050, 830.7200, 830.7220, 830.7370, 830.7550, 830.7560, 830.7570,830.7840,830.7860 and 830.7950

- Per OPPTS 830.1000, these data are not required for the registration ofan end-use product. 

### 4830.6316

- This product does not have explosive characteristics; therefore these data are not required. Please refer to the Confidential Statement of Formula for additional information on the composition of Willowood Ethofumesate SC. 

### 5830.6317,830.6320

- Willowood, LLC is currently conducting storage stability and corrosion characteristic studies to satisfy guidelines 830.6317 and 830.6320, respectively. Per PR Notice 92-5, storage stability data are not required to be submitted unless specifically requested by the Agency. OPPTS 830.6317 and 830.6320 guidelines allow the corrosion characteristics study and storage stability study to be conducted simultaneously. Willowood, LLC will submit these data upon completion. As these studies take over a year to complete, Willowood, LLC requests that a conditional registration for Willowood Ethofumesate SC be granted on the submission ofthese data. 

### 6830.6319

- Willowood Ethofumesate SC is not an emulsifiable concentrate. In addition, the proposed labeling recommends dilution with water, not oil; therefore, these data are not required.

7 

### 830.6321

- This product is not proposed for use around electrical equipment. Therefore, these data are not applicable nor are these date required.

8 

### 830.7520

- These data are not required for Willowood Ethofumesate SC because it is not water insoluble and is not a fibrous material.



### , ,

Page 

### 1 of1

# Certification with Respect to Label Integrity
version: **9/11/02**



### I certify thatthe 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 ofthese documents included with this submission.

IPROPOSED LABEL 

### Date Submitted EPA Registration 

## # to EPA Electronicfile name
87290-xx January 5, 2010 087290-xxxxx.20100105.Willowood Ethofumesate SC label



### I certify thatthe 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.

# /,/.~O/O Date Michael Kellogg
Name (typed) Agent
Title

# 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 useAcrobat to mark-up the e-Iabel with your comments.

Ife-Iabel was submitted via 

# CD-ROM with paperapplication
then you will find e-Iabel in 

# Electronic Label Library

Ifthe**e~/abel**is notfoundin the ELL then it was probablyno!named correctlyandcouldnotbe enteredinfo the ELL. However, the file can be retrieved from the CD which isretained bythe Front End. 

## or Ife-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 ofthis sheet. Ifyou have any questions on e-Iabels, please contact one ofyour division e-Iabel experts:

AD Willie Abney 

## 308-1689 Renae Whitaker 

## 308-7003 Tracy Lantz 

## 308-6415 BPPD 

### RD Tom Harris 

## 308-9423

# PROCES~ING 

# ELECTRONIC • 4BELS (rev, 1/5/09, tch) 

### Ife-Iabel submitted via XML e-submission (not on CD-ROM), you may wish to find e-Iabel in Documenlum, save e-Iabel to "My Documents", add e-Iabel to ELL, start below atstep 

## 5,



## Initial E-Label perapplication (on CD-ROM with papervia ITRMD)

1 ITRMD receives paper submission 

### wi e-Iabel on CD

, Save copy ofelabel from ELL to My Documents

1U Send annotated e-Iabel to registrant via email (also send ''HowTo Print") , Tracking record added to OPPIN

I Review label (ifacceptable, skip to slep 20)

11 File print of annotated e-Iabel and email in jacket 'ITRMD adds e-Iabel to ELL

in-process

, Add comments to e-Iabel (save; add ''wilh comments" 10 rilanama review

" Add annotated elabel to ELL

out-process 4 ITRMD sends paper submission to AD/BPPD/RD b Connect ELL record with OPPIN S#

, Print annotated elabel (use "Print with Filen<lme")

1;:1 Close submission in OPPIN



## Resubmission (via email to statter or PM)

14 Receive email submission wI elabel attached 10 Add tracking record to OPPIN 16 Add e.label to ELL

in-process

" Save copy ofelabels (old & new) from ELL to My Documents " Compare old and new labels with Acrobat

" Print e-Iabel, stamp, write cover letter (use "Print with Filename") " Mail stamped label & cover letterto registrant

process - big picture 1- create OPPIN tracking 2- put label in ELL; link to 

### s# 3- save ELL label to MyDocuments 4- compare 

### I comment 5- outprocess review

" File stamped label & cover leiter injacke't

, out-process H Connect ELL record with OPPIN S#

(if revisions needed repeat steps 8-19)

:.1;; Add cover letterto ELL (mandatory ifaccepted with comments)**~4** Close submission in OPPIN

techniques to know

- filename for e-Iabels

- "printwith filename"

- compare / comment

- printing with comments

### Mike Kellogg From: Sent: 

### To: Subject: 

### paygovadmin@mail.doc.twai.gov Tuesday, January 05, 2010 1:21 

### PM Mike Kellogg Pay.Gov Payment Confirmation

THIS IS AN AUTOMATED MESSAGE. PLEASE DO NOT REPLY. Your transaction has been successfully completed. Transaction Summary Application Name: PRIA Service Fees Pay.gov Tracking ID: 256750C8 Agency Tracking ID: 74695714697 Account Holder Name: Brian Heinze Transaction Type: Sale Transaction Amount: $682.56 Billing Address: 8696 Lookingglass Road City: Roseburg State/Province: OR Zip/Postal Code: 97471 Country: USA Card Type: Master Card Card Number: ************6665 Transaction Date: Jan 5, 2616 4:26:35 PM Decision Number: Registration Number: 87296-xx Company Name: Willowood, LLC Company Number: 87296 Action Code: R366



## ., , , ,

1-' '" J :) .,,) ') }

i" ,

# PRlA 2 - 21 DayContent ScreenReviewWorksheet (EPA/OPP Use Only) 3/23/09 21 Day Screen StartDate: __ 

# --'-I _-_]-1L----'-f O,c,,-
______ ---,- Experts In-Processing Signature: 

## ti'1 E r-+"t'l./tIPbrON 

### Date {- I{ - 10 

### FeePaid: Yes / Divisionmanagementcontacted onissues No Yes ___**~Date**

### ______ _
EPA Reg. Number:**~** 

# 7 29(;

- 

# R EPA ReceiptDate:

# l-~-/O

1

2



### 3 ApplicationForm(EPAForm 8570-1)(linkto form) signed & 

### complete includingpackagetype

Confidential Statement ofFormulaall boxes completed, form signed, and dated Form

. to a) All inerts (linkto http://www.epa.gov/opprdOOllinerts/), including fragrances, approved for theproposed uses (see FootnoteA) CertificationwithRespectto Citation ofData (EPA Form 8570-34) (Linkto form) completed and signed (N/A if100%repack) Certificate and datamatrix consistent
Ifapplicant is relying ondatathat are compensable, is the offer to pay statementincluded. (see Footnote B)



### If is there a letter ofAuthorization for exclusive use yes

Exemption Statement(EPA to no

4 completed and signed (N/ A ifsource is unregistered orapplicant ownsthe



### 5

6 DataMatrix (EPAForm 8570-35) (Linkto form) bothinternal and external copies (PR98-5) (Linkto PR 98-5) completed and signed (N/A if 100%

SelectiveMethod b) Cite-All (Fee category experts use) c) Applicant owns all data (Fee category experts use)



### 5 Copies ofLabel (linkto http://www.epa.gov/oppfeadlllabelingllrmO (Electroniclabels on CD are encouraged and guidanceis available)( link

### to http://www.epa.gov/pesticides/regulating/registering/submissions/index.htm#labels

I

### 7 Isthe datapackageconsistentwithPRNotice 86-5 (linkto PRN 86-5)

### ~ Notice ofFiling(linkto 8 httn;//www.ena.gov/nesticides/regulating/tolerance netitions.htm) included 

# X withpetitions (linkto http;//www.epa.gov/pesticides/regulating/tolerances.htm) 9 If

### applicable for conventional applications,reducedriskrationale (linkto 

# ;( http;//www.epa.gov/opprdOOllworkplanireducedrisl{.html) RequiredData(linkto httJ);//www.ena.gov/nesticides/regulating/data reguirements.htm) and/or datawaivers. SeeFootnoteC.

a) List study (or studies) not includedwith application



## 10

2

## D Comments:

\**~';.,:>...** {_ 11: -c..J;**~,-'**



# *NI A - NotApplicable

Footnotes \ . 

### , ,,"<c_ !



# L/7 L(

# n

A. Duringthe 21 dayinitial contentreview, all CSFswill bereviewedto determine whether

### all inerts listed, including fragrances, are approved for theproposeduses. Ifan unapprovedinertis identified, the applicantmusteither 1) resolvethe inert issue by, for example, removingthe inert, substitutingitwith anapprovedinert, submitting documentationthatEPAapprovedthe inertfortheproposedpesticidaluses, correcting mistakes onthe CSF, etc. or 2)providethe datato support OPP approval ofthe inert or 3) withdrawthe application. Removing or substituting aninertingredientwill require a new CSF andmayrequire submission ofdata. All information, forms, data and documentationresolvingthe inertissuemusthavebeenreceivedbytheAgencyorthe application withdrawnwithinthe21 dayperiod, otherwise, the Agencywill rejectthe application as described below.
To successfullycompletethis aspect ofthe 21 dayinitial content screen, applicants are 

### strongly encouraged to verifythat all inertingredients havebeen approved forthe application'suses 

### even ifa product is currently registered byconsulting the inertWeb 3

### site [linkto http://www.epa.gov/opprdOOllinertsllists.html] and ifthe inert is not approved, to obtain the necessary inert approval priorto submitting an application to 

### register a pesticide product containingthat inert ingredient. 

### Some inert ingredients are no longer approved for food uses or certaintypes ofuses. Thename and/or CAS number ona CSF mustmatchthename and CAS number onthis web site. Simpletypographical errors inthename or CAS numberhave resulted inprocessing delays.
Ifan inert is notlisted on the inert ingredientweb site andthe applicantbelieves thatthe inerthas been approved, the applicant should contactthe InertIngredientAssessment Branch (nAB) at inertsbranch@epa.gov and resolvetheissue. Copies ofthe correspondencewithnAB resolving the issue should accompanythe application. All newinerts exceptPIP inerts are reviewedbynAB. ThenAB should also be contacted for any questions on what supporting dataneeds to be submittedfor andtheAgency's inertreviewprocess. Questions onPIP inerts shouldbedirectedto the Chiefof MicrobialPesticides Branch [Linkto http://www.epa.gov/oppbppdllbiopesticides/contactsbppd.htm].
When abrand, trade, orproprietary name ofan inert ingredientis listed ona CSF, additional information such as analternatename ofthe inert, CAS number orother information [linkto http://www.epa.gov/opprdOOl/inerts/tips.pdfl must also be included to enablethe Agencyto determine ifithasbeen approved. Eachcomponent ofaninert mixture (including a fragrance) mustbeidentified. In some cases,the supplier ofthe mixture orfragrance mayneedto providethis informationto the Agency. Priorto the Agency's receipt ofanapplication, applicants must arrangewith aproprietarymixture or fragrance supplierto providethe componentinformationto the Agency orpromptlyupon EPA'srequest. Ifthe inertingredients in aproprietaryblend (including fragrances) cannot or are not identifiedorprovidedwithinthe 2I-day contentreviewperiod, the Agencywill rejectthe application. Duringthe 21 day contentreview, applicants should submitinformationto the individual identifiedbytheAgencywhenthe applicant is informed ofan unapproved inert. UnapprovedInerts Identified on CSFs


### All applications exceptconventionalnewproducts andPIPs
Once an unapproved inertis identified ona CSF, the Agencywill contactthe applicantwiththe following options:
I. Correctthe applicationby, for instance, correctingthe inert's identity or CAS number,providing documentationthatthe inerthasbeen approved, or removingtheunapprovedinert from the CSF orreplacing itwith one that is approved for the application's uses; or 2. Submitthe information and dataneeded for theAgencyto approvethe unapproved inert. Ifthis optionis selected and implemented, the Agencymay request an extensioninthe PRIA decisionreviewtimeframeto accommodate the inertreview/approvalprocess;


### 4

### 3. Withdrawthe application (theAgencyretains 25% ofthe full fee for the fee category estimated); or Ifnone ofthese options is selected and implementedbythe applicantwithinthe 21 day contentreviewperiod,the Agencywillrejectthe application and retain 25% ofthe full fee ofthe category identified.
ConventionalNewProductApplications
Whenthe Registration Division identifies anunapproved inerton a CSF withan application for anewproductthatthe applicanthas not identified as requiring an inert approval (R311, R312 orR313), itwill contactthe applicantwiththe following options:
I. Correcttheapplicationby, for instance, correctingthe inert's identity or CAS number, providing documentation thatthe inerthas been approved, or removingtheunapproved inert from the CSF orreplacing itwith onethat is approved for the application's uses; or 2. Submit the information and dataneeded for the Agencyto approve the unapproved inert, including anyrequiredpetitionto establishor amend a tolerance orexemption from atolerance. (This optionmay changethe PRIA category for the application,which could require alonger decisionreview time and a larger fee. Ifadditional fees are due, they mustbe receivedbythe Agency withinthe 21 day contentreviewperiod.)
3. Withdrawthe application (the Agency retains 25% ofthe full fee for the fee category estimated); or

Ifnone ofthe above options is selected and implemented during the 21-day content-reviewperiod, the Agency will rejectthe application andretain25% of the appropriate fee for thenewproduct-inertapproval category.
PIP Applications
Whenthe Biopesticide and PollutionPreventionDivisionidentifies an unapproved inert on a PIP CSF and arequestto approvethe inert does not accompanythe application, itwill contactthe applicantwiththe following options:
I. Correctthe applicationby, for instance, correctingthe spelling orname ofthe inertto that in40 CFR 174, orprovidingdocumentationthatthe inerthas been approved; or 2. Submitthe informationand dataneeded for the Agencyto approve the unapproved inert. Ifaninert ingredienttolerance exemptionpetitionis required, thepetition mustbereceivedbytheAgency and the B903 fee paid withinthe 21 dayperiod. Ifthis optionis selected and implemented, the Agencywill discussharmonizingthetimeframe for bothactions. 

### 5

### 3. Withdrawthe application (the Agencyretains 25% ofthe full fee for the fee categoryestimated); or Ifnone ofthe above options is selected and implementedduring the 21 day contentreviewperiod, the Agencywill rejectthe application and retain25% of thefee.

B. 

### A policy on documentation ofoffers to pay is still being developed, however, for a me-too orfasttrack (similar/identical)newproduct, R300 orA530, an application withoutthe necessary authorizations ofoffersto paywillbeplacedinto eitherR30I or A531. The Agencyrecommendsthat authorizations ofoffers topaybe submittedwith otherPRIA applicati.ons to avoid delays inthe Agency's decision.
C. Biopesticide applicants are advisedto contacttheAgency and discuss studywaivers priorto submittingtheir applicationto the Agency. Documentation ofsuch discussions shouldbe submittedwiththe studywaiver.

6UNITED STATES ENVIRONMENTAL PROTECTION AGENCY WASHINGTON, D.C. 20460



### January 11,2010

OPP DecisionNumber: D-425897 EPAFile Symbol or RegistrationNumber: 87290-R ProductName: WILLOWOOD ETHOFUMESATE SC EPAReceiptDate: 08-Jan-201 0 EPA CompanyNumber: 87290 OFFICE OF PREVENTION. PESTICIDES AND TOXIC SUBSTANCES



### CompanyName: WILLOWOOD, LLCEPA File Symbol orRegistrationNumber:
JANELLE KAY PYXIS REGULATORY CONSULTING, INC. WILLOWOOD, LLC 4110 1136TH STREET,NW GIG HARBOR, W A 98332-

SUBJECT: Receipt ofApplication and 50% Small Business WaiverRequest
DearRegistrant:
TheOffice ofPesticideProgramshas receivedyour application, 50% small business waiverrequest, and cerification ofpayment. Ifyou submitteddatawiththis application, the results ofthePRN-86-5 screenwill be communicated separately. Duringthe administrative screen, the Office ofPesticide Programshas determinedthatthisAction is subjectto a Pesticide Registration Service Fee as defined inthePesticide Registration ImprovementAct.
TheActionhas been identified as Action Code: R300
NEW PRODUCT;ME-TOO PRODUCTFASTTRACK;
Yourrequest for waiverhas been forwarded for review. Youwill be notified inwritingwhena determination ismaderegardingyourrequest. Ifyourwaiverrequest is approved, the decision reviewtimeperiodwill startonthe date ofapproval. Ifyourwaiver request is denied, youwill receive an invoice for the outstandingbalance.
Ifyouhave any questions, please contactthePesticideRegistration Service Fee Ombudsmanat (703) 305-6249.

### ~**~**

# IFee for Servicel 

# ftf865285EThis package includes the following 

# <!l New Registration
oAmendment**~** 

# Studies?**~** 

# Fee Waiver? 

# v o 

# volpay 

# % Reduction: 

# fj01 for Division 

# OAD oBPPD <!lRD
Risk Mgr. [}[]
Receipt No. 

# s-I 865285 

# :======i EPA File Symbol/Reg. No. 

# I 87290-R**~====~** 

# Pin-Punch Date: 1 

# 1/8/2010 '---------' 

# o This item is NOTsubject to FFS action

.

A 

# - • 

## f\GlIon I 

## .nqe. 

# Requested: 

# I K3CJV 

# I Granted: 

# I K30 0 

# I Amount Due: 

# $ <

# 165' /;<

IYil 

# Inert Cleared for Intended Use 

# iV Reviewer: K

# '!-

# "'-~ , 

## Remarks: 

# Parent/Child Decisions:

Uncleared Inert in Product Date: 

# l-l/{-10

### )



# FEEFOR 

# SERVICEPR.'FORM 9-11 tMARcIt_

# ~®rn**®~~~~~ill~ rnJ~rn** **(IDI~J~Y1** FILE SYMBOL

REGISTRATION NO. 

# R 

# tl7;2**ro~** 

# CONFIDENTIAL STATEMENT OF FORMULA ENCLOSED

DATE·· SUBMITTED 

# JAN 0<8 Z010 

# Do NotWrite Comments, 

# Formula,orParts of Formula on This Envelope

NOTE It shall be unlawlul-forany person 

### to use for his 0

.... advantage
or to reveal, other than 

### to the Secretary, or officials or employees of 

# , the UnitedStates Department ofAgriculture orother Federalagencies,
or to the courts In response 

### to a subpoena, or to physicians, anll In emergencies to pharmacistS and other qualified persons, for use In the preparation of antidotes, In accordance with such directions as. the Secretary may prescribe, any Information relative 

### to.formulas of products 8cqulred 

### byauthorityofSection4 ofthe "FederallnsectlC:lde, fungicide, and Rodenticide.Act..

USDA:AR!