EPA Registration Jacket 87290‐1
1
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PYXIS REGULATORY CONSULTING, I'NC. 

4110 136'h St. NW 

Gig Harbor, WA 98332 

COURIER DELIVERY 

Kathryn Montague (PM 23) 

Document Processing Desk (FNL LBL) 

Office of Pesticide Programs (7504P) 

U.S. Environmental Protection Agency 

Room S-4900, One Potomac Yard 

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 of Final Product Labeling per the Agency Letter dated April 22, 20 I 0 

Dear Ms. Montague, 

On behalf of Willowood, 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 of this submission, we submit the following documents: 

I. Completed Application for Registration (EPA Form 8570-1) 

2. One (I) copy of the Willowood Ethofumesate SC final product labeling 

3. Letter of Authorization 

Please feel free to contact me by phone (253) 853-7369 or by email atRoss@PyxisRC.comif you have 

any questions or need any additional infonnation. 

Sincerely, 

Ross Gilbert 

Enclosures 

cc: B. Heinze; Willowood, LLC 

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Pf •• 6. r •• d imtrur.#oM on revtllY. 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 I Willowood 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 

D Chock if this 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 of final printed labeling per the Agency letter dated 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 

Stenci Od 

Section - IV 

1. Contact Point (Compl9t9 it9m$ dir9Ctly b910w for id9ntlfic8tion of individu91 to bo contllct9d. if n9Ce$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 certify that the statements I have made on this form and all attachments thereto are true. accurate end complete. ~R)e~~~8d 

I acknowledge 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 

, , 

Agent ' ,;))-, 

,- .. ~ 

4. Typed Name r 5. Date 

I c> I 'J.1. , -:>-.!)I 0 • ' J ; • 

Ross Gilbert 

,,) ; 

, , . . . EPA Form 8570·1 IRev. 3·941 PreVIous editions ere obsolete . White '. - EPA File Copy (on(linaJ) y.now - AppHcent 

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ID 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: % 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 booklet for First Aid 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 

5
FIRST AID 

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

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

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

• Do not Qive anvthinq by mouth to an unconscious person, 

If inhaled: • Move person to fresh air. 

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

preferably by mouth~to-mouth, if possible. 

• Call a poison control center or doctor for 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. 

If on skin or • Take off contaminated clothing. 

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

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

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. 

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PRECAUTIONARY STATEMENTS 

HAZARDS TO HUMANS AND DOMESTIC ANIMALS 

CAUTION. Harmful if swaJlowed or inhaled. Avoid breathing vapor or 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 must wear: 

• Long-sleeved shirt and long pants 

• Protective 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 

Mixers and loaders 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 if the 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 hot water. 

Keep and wash PPE separately from other laundry. 

ENGINEERING CONTROLS STATEMENT 

When handlers use closed systems, enclosed cabs, or aircraft in a manner that meets the requirements listed in the Worker Protection 

Standard (lNPS) 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 (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 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 adiacent to treated areas, Do not contaminate water when 

disposing of equipment washwaters or rinsate. 

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USE PRECAUTIONS 

Willowood Ethofumesate SC or tank mixes must be used for 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 due to climatic or soil conditions following application of Willowood Ethofumesate se 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 se. If fields are 

replanted to sugar beets, reseed into treated band. 

Do not rotate with any crops other than sugar beets or ryegrass for: 

• t2 months following preplant 'Incorporated, preemergence, conventional postemergence applications, or split (low rate) applications 

totaling more than 12 fl. oz. (0.375 lb. aVacre); 

.6 months following 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 other than sugar beets or ryegrass. Do not use Willowood Ethofumesate se 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 of the user at the time of pesticide application. 

DIRECTIONS FOR USE 

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

Read entire Directions for Use and Condition of Sale and Limitation of Warranty and Liability before using this product. 

Do not apply this product in a way that will contact workers or other persons, either directly or through drift. Only protected handlers may be in 

the area during application. For any requirements specific to your State or Tribe. consult the agency responsible for pesticide regulation. 

SHAKE CONTAINER WELL BEFORE USING, 

AGRICULTURAL USE REQUIREMENTS 

Use this product only in accordance with its labeling and with the Worker Protection Standard, 40 CFR Part t70. This Standard 

contains requirements for the protection of agricultural workers on farms, forests, nurseries, and greenhouses, and handlers of agricultural pesticides. It contains requirements for training, decontamination, notification, and emergency assistance. It also contains 

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 apply to uses of this product that are covered by the Worker Protection 

Standard. 

Do not enter or allow worker entry into treated areas during the restricted entry interval (REI) of t2 hours for all crops, except tun 

grown for sod. 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 or soil-incorporated, the Worker Protection Standard, under certain circumstances, allows 

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

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

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

• Coveralls 

• Chemical-resistant gloves made of any waterproof material 

• Shoes plus socks 

Notify workers of the application by warning them orally and by posting warning signs at entrances to treated areas. 

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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 of application 

(e.g. ground, aerial) can influence pesticide drift. The applicator must evaluate all factors and make appropriate adjustments when applying 

this product. 

Wind Speed ~ 00 not apply when 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 beets for the control of the weed speCies listed below. It provides effective control of these 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 of Wi!!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 more than 1.5 Ibs. a.i. (3 pints of product) per acre with aircraft. 

PRECAUTIONS/RESTRICT/ONS 

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. Do not apply more than 3.75 Ibs. a.i. (7 pints of product) per acre 

per season for sugar beets. See Use Precautions for additional information on proper use, 

WEED SPECIES CONTROLLED 

Annual Broad leaf 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 kali var. 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 reduced with the Willowood Ethofumesate SC + Pyramin® tank mix because of the lower rate of Willowood 

Ethofumesate SC recommended . 

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

WiUowood Ethofumesate SC alone wi!! also reduce competition from these HARD-TO-CONTROL weeds: 

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 or States and in accordance with directions on label. 

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PREPLANT INCORPORATED 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 psij 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 label-listed 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. 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 prior to using Willowood Ethotumesate SC. 

INCORPORATION EQUIPMENT: Where soil incorporation is recommended, use a hooded power- or ground-driven rotary tiller, rOiling cultivator, or similar equipment properly 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 to" across the top of the bed. Apply Willowood Ethofumesate SC in a band 

at the specified 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 of the beds are thoroughly wetted. Irrigate from furrows on both sides 

of the row. 

Fall: This method of application can be used when spring moisture is marginal or where irrigation water is not available at planting time. Fall 

bedding utilizes the winter-accumulated moisture to enhance activation of the herbicide and to aid in germination of the 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 specified 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. 

APPLICATION INSTRUCTIONS 

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 

rainlall 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 River Valley (Minnesota and North Dakota), it is recommended that Willowood Ethofumesate SC or the tank mix be applied before or at 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 gennination, 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 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: When 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 8C 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. 

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WILLOWOOD ETHOFUMESATE SC ALONE 

DOSAGE TABLE 1 

(All Regions Except North Dakota and Minnesota); 

Rate of Willowood Ethofumesute SC per Acre' 

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 33/4 to 6 Pints 1 1/4 to 2 Pints 1 to 1 1/2 Pints 1 to 1 3/4 Pints 

3% organic matter 

Fine Textured Soils: Siltloams, clay 

loams, clays which contain more than 6to 7 1/2 Pints 2to 2 1/2 Pints 1 1/2 to 2 Pints 1 1/2 to t 3/4 Pints 

3% organic matter 

, Use the higher rate within each soil texture category on the finer texture soils andlor where 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 actually treated, 

DOSAGE TABLE 2 

(North Dakota and Minnesota only): 

Willowood Ethofumesate SC per Acre 

Soil Texture 7-inch Band Width' Broadcast 22" Row 

Coarse Textured Soils; Sandy toams only 6 Pints 2 Pints 

Medium Textured Soils: Silt loams and clay loams 6 Pints 2 Pints 

Fine Textured Soils: Heavy clays 7 1/2 Pints 21/2 Pints 

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

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WlllOWOOD ETHOFUMESATE SC + PYRAMIN® (TANK MIX) 

This tank mix will control these additional broad leaf weeds: 

Annual sowthistle (Sonchus oleraceus) 

Black mustard (8rassica nigra) 

Buffalobur (Solanum rostra tum) 

Coast fiddleneck (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 spray tank with PyramJn, fill the spray tank with 1/2 of the total amount 

of water to be used and add Wi!!owood Ethofumesate SC first. Agttate 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 3 for specified rates. 

DOSAGE TABLE 3 

(California, winter-grown sugar beets only): 

Willowood Ethofumesate SC per Acre PYRAMIN DF per Acre 

Soil Texture Broadcast 10-inch Band Width1,2 Broadcast 10-inch Band Width (For calibration 30" Row (For calibration 30" Row 

purposes only) purposes only) 

Coarse Textured Soils: Sands. NOT RECOMMENDED loamy sands and sandy loams 

Medium Textured 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 more than 3% organic 4 to 5 1/4 Pints f 1/3 to t 3/4 Pints 4 t/2 Pounds t 1/2 Pounds 

matter and clays 

, For other brand or row Widths, adlust rates In proportion to the area actually treated. Do not apply thiS mixture broadcast. 

2 Use the higher rate of Willowood Ethofumesate SC within each soil tex1ure category on the finer-textured soils and/or where volunteer barley 

or wheat are expected to be a problem. 

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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 specified rates listed in Dosage Table 4. Do not mechanically incorporate the herbicides into the 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 

Medium Textured Soils: 

Silt loams, clay loams 

which contain less than 

3% organic matter 

Fine Textured Soils: 

Clay loams which contain 

more than 3% organic 

matter and clays 

DOSAGE TABLE 4 

(Central and Eastern States Only): 

Willowood Ethofumesate SC per Acre 

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 or row Widths, adjust the rate In proportion to the area actually being treated. 

Preplant and Preemergence Use Precautions 

PYRAMIN FL per Acre 

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 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 label-listed 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 ryegras$ in treated land during the same season. If fields are replanted to sugar beets, reseed into treated band. Do not retreat 

field with conventional rates of Wiflowood Ethofumesate SC in the same season. 

Paste mergence Application 

Product Information 

The tank mixes of Willowood 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. 

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Tank mixes of Wmowood 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/ygonum persicaria) 

London rocket (Sisymbrium irio) 

Nettleleaf goosefoot (Chenopodium mura/e) 

Pennsylvania smartweed (Polygonum pennsylvanicum) 

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 of Willowood Ethofumesate SC plus Betamix® applied postemergence also controls the following annual grass weeds: 

Green foxtail (Setaria viridis) 

Pigeon grass (yellow foxtail) (Setaria g/auca) 

Mixing the Spray: Add Wi!lowood 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 psij 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 label·listed 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 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 of time is advantageous for moving Wi!lowood Ethofumesate SC into the top layer 

of soil where it can be absorbed by the roots of sprayed and genninating weeds to provide optimum control. One·half inch or more of sprinkler 

irrigation is required to activate Wil!owood 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 of Willowood Etho· 

fumesate 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 convent'lonal rates of Willowood 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 for additional information on proper use. 

10 

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Split (Low Rate) Applications 

Split (low rate) applications of Willowood Ethofumesate SC + Betamix® or Betnex® Herbicides may be applied to sugar beets to control early 

geminating weeds (the tank mix of Wi!!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 Dosage Table 5 for broadcast rates. See Dosage 

Table 6 and 7 for equivalent band rates. For band applications, apply in 5-10 gallons of water per acre. Any weeds which are not completely 

controlled by the first treatment wi!! usually be checked and contro!!ed 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 

Pints/Acre Broadcast 

Sugar Beet 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 

Equivalent Band Width 

22" 28" 3ry' 

1.5 pints/acre 5" 5,5 fl. oz. 4.3 f1. 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. 8.0 fl. oz. 

7" 15.3 fl. 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" 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. 

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Conventional Applications 

Timing of Application; Apply the tank mix Willowood Ethofumesate SC + Betanex® or Willowood Ethofumesafe SC + Betamix® when sugar 

beets have at least 4 fully expanded true leaves. Apply at rates specified in the Dosage Tables. Use the higher rate of WiUowood 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 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 up to the 4-leaf stage. 

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 the 2-leaf stage 

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. 

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DOSAGE TABLE 8 

Rate of Willowood Ethofumesate SC Per Acrel Rate of Betamlx® Per Acrel 

Band2 Row Spacing 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 larger weeds and sugar beets, 

2 For other band or row widths, adiust rates in proportion to the area actually treated. 

WILLOWOOD ETHOFUMESATE SC + BETANEX® (TANK MIX) 

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 up to the 6·leaf stage. 

Redroot pigweed (Amaranthus retroffexus) 

Wild mustard (Brassfca kaber) 

Nettleleaf goosefoot (Chenopodium murale) 

London rocket (Slsymbrium irro) 

Common lambsquarters (Chenopodium album) 

Group 11: Weeds controDed up to the 4-leaf stage 

Common chickweed (Stel/aria media) 

Black nightshade (Solanum nigrum) 

Common ragweed (Ambrosia artemisiifofia) 

Shepherds purse (Capseffa bursa-pastoris) 

Groundcherry (Physalis lanceifofia) 

Pennsylvania smartweed (Polygonum pennsylvanfcum) 

Ladysthumb (polygonum persicaria) 

Group 111: Weeds controlled upto the 2-leaf stage 

Annual sowthistle (Sonchus oleraceus) 

Common purslane (portulaca o/eracea) 

Wild buckwheat (Polygonum convolvulus) 

Kochia' (Kochia scoparia) 

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

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DOSAGE TABLE 9 

(All areas except California) 

Rate of Wiflowood Ethofumesate SC Per Acre' Rate of Betanex® Per Acre' 

Band2 Row Spacing 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 1/2-314 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 larger weeds and sugar beets 

2 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 Etholumesate 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 lollowing treatment, do not replant with cropS other than 

sugar beets 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 conventional rates of Willowood 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 or ovell, bright days. When the air temperature 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 days following treatment 

• Windy or drought conditions 

• Use of a preplant or preemergence herbicide or 01her chemicals 

• Insect or disease injury 

• Close cultivation 

If stress conditions are present, delay application until crop has recovered. 

DO NOT OVERTREAT; The use of higher-than-specified rates may cause beet injury andlor carry over problems, 

Do not spray while dew is present. 

Rainfall or sprinkler irrigation within 6 hours of application may reduce weed kill. 

If Willowood Ethofumesate SC is applied on fields with 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 cause temporary growth retardation andlor chlorosis or tip-bum on sugar beets, Sugar beets usually resume 

normal growth within 10 days. 

WILlOWOOD ETHOFUMESATE SC MIXTURES 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 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 per acre, soli type and soil 

incorporation, application, and other directions must be followed. 

All individual State regulations relating to dry bulk fert16zer blending, registration, labeling and application are the responsibility of the individual 

andlor company selling the Willowood Ethofumesate SC/fertiJjzer mixtures. 

A minimum of 200 pounds and a maximum of 700 pounds of approved fertilizer ingredients (See "2" below) impregnated with the appropriate 

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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 a fine 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, free~flowing 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 WII!owood Ethofumesate SC actually contained in the fertilizer 

mixture appl"led 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 

t. Approved dry fertilizer ingredients for 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 

Urea 45 0 0 

WiUowood Ethofumesate SC Physical Data 

Density t.15 g/cmJ 

Pounds/gallon 9.60 

Flashpoint Noncombustible 

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2. Rate Chart for the Impregnation of Dry Bulk Fertilizers with Willowood Ethofumesate SC: 

Gallons of Willowood Ethofumesate SC per Ton of Dry Bulk Fertilizer 

Fertilzer Rate 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 1.4 t 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 suggested for evaluation of physical compatibility of Willowood Ethofumesate SC with liquid fertilizers for spray 

tank applications. 

Material Required 

1. Willowood Ethofumesate SC- components of tank 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 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 

t. Pour one pint (473 ml) of the liquid fertilizer into each of the quart containers. 

2. Add adjuvant(s) to one or more of the containers and mix; follow label directions of adjuvant. 

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. Inspect the surface and body of the mixture: 

a. immediately after mixing. 

b. after allowing mixtures to stand quietly for 30 minutes, 

c. immediately after mixing again (invert the 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 of the 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 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, or clumps of solids form in the mixtures. those combinations should not be used for spray tank application. 

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Willowood 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) 

Apply tank mixes only in specified regions or States and in accordance with directions on label. 

APPLfCATfON INSTRUCTIONS 

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 frrigation: 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 Wlllowood 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 of water 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 of Willowood Ethofumesate SC. 

WILLOWOOD ETHOFUMESATE SC ALONE 

DOSAGE FOR BROADCAST APPLfCATIONS 

Table Beet Stage WIUOWOOD ETHOFUMESATE SC FLUfD OUNCES/ACRE BROADCAST 

Preemergence 60 

Postemergence: 

2-Leaf 5.25 

4-Leaf 5.25 

6-Leaf to 8-Leaf 10.5 

Do not exceed 2.6 Ibs. a.l. (80 ounces of product) per acre 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 labeHisted 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 

18 

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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 of Willowood Ethofumesate SC in the same season. 

RATE RESTR!CTION 

Do not apply more than 1.9 Ibs. a.i. (3 pints of product) per acre per pre~emergent application to table beets. See Use Precautions for ad~ 

ditional infonnation 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 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 smaller than 50-mesh strainer. Uniformly apply the specified 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. When applying Willowood Ethofumesate se or 

tank mixes in a band, check to make certain that the band width is accurate for the dosage rate being .app!ied. 

The spray tank and lines should be thoroughly cleaned and rinsed prior to using WiI!owood Ethofumesate SC. 

POSTEMERGENCE APPLICATION 

Product Information 

Willowood Ethofumesate SC applied postemergence broadens and enhances the control of weeds. 

Post~emergent application Rate Restriction: Do not apply more than 0.33 lb. a.i. per acre per application. 

Mixing the Spray: Add Willowood Ethofumesate SC to the water in the spray while 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. 

Uniformly apply the specified 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/Residua! 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~ha!f inch or more of 

sprinkler irrigation is required to activate Willowood Ethofumesate SC on most soi! types. 

Residua! control of weeds is dependent upon soil moisture conditions; rate of herbicide used, and soil texture, The activity of Willowood Ethofumesate SC 'In the soi! is reduced as the soil texture becomes finer and organic matter increases. 

W!LlOWOOD ETHOFUMESATE SC MAY CAUSE CROP JNJURY OR STAND lOSS!F THE CROP IS UNDER STRESS FROM ONE OR 

MORE OF THE FOLlOW!NG CONDITIONS: 

• Rapid climatic changes from cool, overcast days, to hot (BO°F or over), bright days, When the air temperature 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 days following treatment 

• Windy or drought conditions 

• Use of a preplant or preemergence herbicide or other chemicals 

• Insect or disease injury 

• Close cultivation 

If stress conditions are present, delay application until crop has recovered. 

DO NOT OVERTREAT: The use of higher~than~specifled rates may cause beet injury and/or carry over problems. 

Do not spray while dew is present. 

Rainfall or sprinkler irrigation within 6 hours of application may reduce weed kil!. 

19 

22
If Willowood 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 

PRODUCT 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 of Willowood Ethofumesate SC in the soil is reduced as the soil texture becomes finer and organic matter increases. 

WEED SPECIES CONTROLLED 

Annual Broadleaf Weeds 

Black nightshade (Solanum nigrum) 

Common chickweed (Stel/aria media) 

Common lambs quarters (Chenopodium album) 

Common purslane (portulaca o/eracea) 

Eastern black nightshade (Solanum ptycanthum) 

Kochia (Kochia scoparia) 

Ladysthumb (Polygonum persicaria) 

Pennsylvania smartweed (polygonum pennsyfvanfcum) 

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 

Volunteer wheat (fn'tlcum sp.) 

Wild oats·· (Avena latua) 

Yellow foxtail (Sefaria glauca) 

··Control of wild oats has been inconsistent in Minnesota and North Dakota 

Wlllowood Ethofumesate SC alone will also reduce competition from these HARD-TO-CONTROL weeds: 

Annual sowthistle (Sonchus o/eraceus) 

Puncturevine (fribu/us terrestris) 

Shepherdspurse (Capsel/a bursa-pastoris) 

Purple nets edge (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. 

APPLICATION INSTRUCTIONS 

Onion, garlic and shallot 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-hall inch of rainfall is usually adequate for activation. In 

20 

23
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 under furrow irrigation: Apply W~lowood 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 se 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. 

Onion, 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 of water 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 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 BROADCAST APPLICATIONS TO ONION, GARLIC AND SHALLOT 

Use Pattern 

Preemergence, soil surface 

Coarse Soils (sand, loamy sand, sandy loam)" 

Medium and Fine Soils~' 

Postemergence 

Up to 4 foliar applications at evenly spaced intervals, 

with last application 30 (+/~ 2) days before harvest 

WILLOWOOD ETHOFUMESATE SC FLUID OUNCES/ACRE BROADCAST 

16 

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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 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 infury may occur during early grow1h when crop is stressed due to herbicide residue carryover. high saline or alkaline soils, unusually cold and wet weather or improperly placed fertilizers or soil insecticides. 

Unusually dry, windy weather, which dries the upper soH layer. following application of Willowood Ethofumesate SC, may reduce effectiveness. 

DO NOT OVERTREAT: The use of higher than label~listed rates may cause crop injury and/or carry over problems. 

Crop Planting Precautions; If crop is lost due to unfavorable grow1h 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 of Willowood Ethofumesate SC in the same season. 

PRECAUTIONS 

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 grow1h 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 specified 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. When applying Willowood Ethofumesate SC or 

21 

24
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 prior to using Willowood Ethofumesate SC. 

POSTEMERGENCE APPLtCATION 

Product tnformation 

Willowood Ethofumesate SC applied postemergence broadens and enhances the control of weeds. 

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 specified rate in 10-40 gallons of water per acre on a broadcast basis or 5-tO 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 ApplicationlResidual 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 of 

sprinkler 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 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 

If stress conditions are present, delay application until crop has recovered. 

DO NOT OVERTREAT: The use of higher-than-specified rates may cause beet injury andlor carryover problems. 

Do not spray while dew is present. 

Rainfall or sprinkler irrigation within 6 hours of application may reduce weed kill. 

If Willowood 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) 

PRODUCT tNFORMATION 

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 of Wlilowood Ethotumesate SC in the soil is reduced as the soil texture becomes finer and organic matter increases. 

22 

25
WEED SPECIES CONTROLLED 

Annual Broadleaf Weeds 

Black nightshade (Solanum nigrum) 

Common chickweed (Ste/laria media) 

Common lambs quarters (Chenopodium album) 

Common purslane (Portulaca olemcea) 

Kochia (Kochia scoparia) 

Ladysthumb (Po/ygonum persicaria) 

Pennsylvania smartweed (Polygonum pennsy/vanicum) 

Redroot pigweed (Amaranfhus retroflexus) 

Russian thistle (Sa/sola kali var. tenuifolia) 

Wild buckwheat (Po/ygonum convolvulus) 

Annual Grass Weeds 

Annual bluegrass (Poa annua) 

Barnyardgrass (Echinochloa crus~galli) 

Canarygrass (Phalads canariensis) 

Green foxtail (Setaria viridis) 

Large crabgrass (Dfgifaria sanguinalfs) 

Volunteer barley (Hordeum spJ 

Volunteer wheat (Triticum spJ 

Wild oats (Avena tafua) 

Yellow foxiail (Setaria glauca) 

Willowood Ethofumesate SC alone will also reduce competition from these HARD~ TO~CONTROL weeds: 

Annual Sowthistie (Sonchus oleraceus) 

Puncturevine (Tribulus terresttiS) 

Shepherds purse (Capsel/a bursa~pastoris) 

Purple nutsedge (Cyerus rotundus) 

Volunteer potato (So/anum tuberosum) 

Yellow nutsedge (Cyperus esculentus) 

Apply tank mixes only in specified regions or States and in accordance with directions on label. 

APPLICATION INSTRUCTIONS 

Carrot grown under rainfall: Apply Willowood Ethofumesate SC alone or in a tank rnix preemergence at tirne 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 fOI 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 Ethofurnesate 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 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 preernergence 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 of water during first irrigation, Do not mechanically incorporate Willowood Ethofumesate SC Into the soil under sprinkler 

inigation. 

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 se has been banded, care should be exercised to mini~ 

23 

26
mize 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 

DOSAGE FOR BROAOCAST APPLICATIONS TO CARROT 

Use Pattern WILLOWOOO ETHOFUMESATE SC FLUID OUNCES/ACRE BROADCAST 

Preemergence, soil surface 

Coarse Soils (sand, loamy sand, sandy loam) 

Medium and Fine Soils 

Postemergence 

2~Leaf to 4 Leaf Stage 

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 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 car· 

ryover, 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 label-listed 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. If fields are replanted to sugar 

beets, reseed into treated band. Do not retreat field with preemergence rates of WilJowood 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. 

PREPLANT AND PREEMERGENCE APPLICATIONS 

Soli Preparation: The soil should be prepared according to good agricultural practices. Large clods can reduce the effectiveness of Wlllowood 

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 

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 smaller than 50 mesh strainer. Uniformly apply the specified 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. 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 prior to using Willowood Ethofumesate SC. 

POSTEMERGENCE APPLICATION 

Product Information 

Willowood Ethofumesate SC applied postemergence broadens and enhances the control of weeds, 

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 ps~ 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 specified 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. 

24 

27
Moisture Following ApplicationlResidual Weed Control: Rainfall or sprinkler irrigation within 6 hours of spraying my 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 of 

sprinkler 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 of Willowood Ethofumesate SC in the 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 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 

If stress conditions are present, delay application until crop has recovered. 

DO NOT OVERTREAT: The use of higher~than-specified rates may cause beet injury andlor carry over problems. 

Do not spray while dew is present. 

Rainfall or sprinkler irrigation within 6 hours of application may reduce weed kill. 

If Willowood Ethofumesate SC is applied on fiek:ls 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,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, and Washington. It effectively controls or reduces competition from those weed species listed below. Willowood Ethofumesate SC may 

be applied preemergence to 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. W'lIlowood Ethofumesate SC is less effective when applied to dry soil. Rainfall or overhead 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 of Willowood 

Ethofumesate SC in the soil is reduced as the soil texture becomes finer and organic matter/thatch increases. 

25 

28
WEEDS CONTROLLED 

Annual bluegrass (Poa annua) 

Seedling Rattail fescue (Festuca myuros) 

Seedling volunteer wheat (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) 

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 psQ, 

Soil preparation: A firm, fine and level seedbed free of trash and vegetative mailer 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. 

NEW SEEDINGS OF ANNUAL OR PERENNIAL RYEGRASS 

Before weed emergence: Apply WiIJowood 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 rallail fescue, wild oats, and volunteer 

cereals and other weeds listed, use 2 t/4to 3 pints per acre. 

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 difflcullto control, must be treated no later than the 2-leaf stage. Apply 2 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: Apply WilJowood Ethofumesate SC following crop emergence and after sufficient rainfall andlor 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 of the 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 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 apply Willowood Ethofumesate SC when crop shows diuron injury. 

Crop 

Perennial ryegrass and tall fescue 

DOSAGE TABLE 10 

Rate Per Acre 

1 1/2 to 3 pints 

26 

Remarks 

For effective control, annual bluegrass must be treated before the 4-leaf stage; 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 for control of rattail fescue, wild oats, and 

other weeds listed. 

29
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 later than the 2~leaf stage. Apply 2114 to 3 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 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 se at earliest possible weed growth stage but not later than the 4-Ieaf 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 21/4 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 pints of Willowood Ethofumesate se 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 se 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 se 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 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 of 

Willowood Ethofumesate se per acre 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 may result 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: 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 incorporate Willowood Ethofumesate SC. 

After weed emergence: Apply Willowood Ethofumesate se 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 Wil· 

lowood Ethofumesate se. 

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. 

If vegetative matter or stover from previous crop was burned, sufficient rainfall or overhead irrigation must have occurred to dissipate the 

charcoal residue remaining after buming prior to Willowood Ethofumesate SC treatment. Failure to allow for dissipation 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 herbicide for 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 for the 

control of weed species listed below. Overhead irrigation or rainfall shortly after application is necessary for activation. 

Do not harvest treated sod for 16 days following application. 

27 

30
Residual control of weeds is dependent upon soil moisture conditions; rate of herbicide used, and soil texture. The activity of Willowood 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) 

Volunteer wheat (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 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 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: An 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-Ieaf 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 Wil!owood 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 

1.5 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 newly seeded perennial ryegrass and tall fescue, if the crop is 

planted late in the fall and subiected to adverse climatic conditions or pesticides which restrict normal growth. 

If vegetative matter or stover from previous crop was burned, sufficient rainfall or overhead irrigation must have occurred to dissipate the 

charcoal residue remaining after burning plior to Willowood Ethofumesate SC treatment. Failure to allow for dissipation of charcoal residue 

may result in reduced weed control. 

28 

31
STORAGE AND DISPOSAL 

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

PESTICIDE STORAGE: Protect product from freezing temperatures. 

PESTICIDE DISPOSAL: Pesticide wastes are acutely hazardous. Improper disposal 01 excess pesticide, spray mixture, or rinsate 

is a violation of Federal law. If these wastes cannot be disposed of by use according to label instructlons, contact your State Pesticide or Environmental Control Agency, or the Hazardous waste representative at the nearest EPA Regional Office for guidance. 

CONTAINER OISPOSAL: Nonrefillable container. Do not reuse or refill this container. Triple rinse container (or equivalent) 

promptly after emptying. 

(Nonrefillable container s: 5 gallons): Triple rinse as follows: Empty the remaining contents into application equipment or a mix tank 

and drain for 10 seconds atter the flow begins to drip. Fi!! the container 1/4 full with water and recap. Shake for 10 seconds. Pour 

rinsate into application equipment or a mix tank or store rinsate for later use or disposal. Drain for 10 seconds after the flow begins 

to drip. Repeat this procedure two more times. Then offer for recycling if available or puncture and dispose 01 in a sanitary landfill, 

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

(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 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 of smoke. 

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 this 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 of such 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 REMEOY OF THE USER OR BUYER, ANO THE EXCLUSIVE LIABILITY OF WILLOWOOO, LLC AND 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 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. 

Wil!owood, LLC and Seller offer this product, and Buyer and User accept it, subject to the foregoing Conditions of Sale and Limitation of Warranty and liability, which may not be modified except by written agreement signed by a duly authorized representative of Willowood, LLC. 

EPA 20100422 

29 

32
WiL 

WlllOWOOD usa Your preferred manufacturer of post patent products 

April 12,2010 

To Whom It May Concern: 

RE: Letter of Authorization 

Dear Sir or Madam: 

Please let this letter serve to confInn that Pyxis Regulatory Consulting, Inc. is authorized to act as agent 

for Willowood Clethodim, LLC, before the U.S. Environmental Protection Agency, California 

Department of Pesticide 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''), 7 U.S.C. § 136 et seq. and state law. 

If you have any questions, please do not hesitate to contact me. 

Sincerely, 

~~)LBrian Heinze ~ President/CEO 

Willowood Clethodim, LLC 

cc: Pyxis Regulatory Consulting, Inc. 

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

33
) 

UNITt:O STATES ENVIRONMENTAL PROTECTION AGENCY 

WASHINGTON, D.C. 20460 

May 5, 2010 

OPP Decision Number: D-431976 

EPA File Symbol or Registration Number: 87290-1 

Product Name: WILLOWOOD OXYFLO EC 

EPA Application Receipt Date: 14-Apr-2010 

EPA Waiver Request Receipt Date: 14-Apr-2010 

EPA Company Number: 87290 

Company Name: WILLOWOOD, LLC 

JANELLE KAY 

PYXIS REGULATORY CONSULTING, INC. 

WILLOWOOD, LLC 

4110 1136TH STREET, NW 

GIG HARBOR, W A 98332-

SUBJECT: Approval of 50% Small Business Waiver Request 

Dear Registrant: 

OFFICE OF 

PREVENTION. PESTICIDES AND 

TOXIC SUBSTANCES 

The Office of Pesticide Programs has approved your request for 50% waiver of the 

pesticide registration fee associated with the action referenced above. The decision review 

period for this action will begin on the date of this letter. 

The Action has been identified as Action Code: R300 

NEW PRODUCT;ME-TOO PRODUCT FAST TRACK; 

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

Ombudsman, at (703) 305-6249. 

Sincerely, 

~j~~ Information Technology & Resources Management Division 

Office of Pesticide Programs 

34
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 

WASHINGTON, D.C. 20460 

January 29, 2010 

OPP Decision Number: D-425897 I 

EPA File Symbol or Registration Number: 87290-R 

Product Name: WILLOWOOD ETHOFUMESATE SC 

EPA Application Receipt Date: 08-Jan-2010 

EPA Waiver Request Receipt Date: 08-Jan-2010 

EPA Company Number: 87290 

Company Name: WILLOWOOD, LLC 

JANELLE KAY 

PYXIS REGULATORY CONSULTING, INC. 

WILLOWOOD, LLC 

4110 1136TH STREET, NW 

GIG HARBOR, W A 98332-

SUBJECT: Approval of 50% Small Business Waiver Request 

Dear Registrant: 

OFFICE OF 

PREVENTION, PESTICIDES AND 

TOXIC SUBSTANCES 

The Office of Pesticide Programs has approved your request for 50% waiver of the 

pesticide registration fee associated with the action referenced above. The decision review 

period for this action will begin on the date of this letter. 

The Action has been identified as Action Code: R300 

NEW PRODUCT;ME-TOO PRODUCT FAST TRACK; 

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

Ombudsman, at (703) 305-6249. 

~~fu>y Oscar Morales, Director 

Information Technology & Resources Management Division 

Office of Pesticide Programs 

35
Materia~ to be added to am e=JaciketlJacket 

Reg. NOJ. (f(J:;;jD-1 

Description: ~) \?'fuciDL\-

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

D Default: (chronological, top :Enewest) 

D File Loccdion: (PDIF page number, i.e,., ~'before page 

45") 

2<¥ Send t©! Data /Extraction contractors this materia!: 

- A- New!ystamped accepted ~abel 

D Noii1fication 

~ NewCSIF 

o Olther: ______ ~ ___ --,----

3. AUach this c©!versilerett©! the top oHhe materiai or jac~et It 

must be well ©!rganizedand clipped together, NOll' STAPLED. 

Then give the material w11l:h thiscoversheet to staff in the 

Informati©!n Services Center (Room S-4900), 

lRevuewer's Name: ~~\ , ~JOhcu) 

PhOlne: 3 Ltl-_ '-VD1-~ ICHvusuOln: Ri') i-fib 

Date: ti tdd\rD 

Created August14, 2008 

36
U.S. ENVIRONMENTAL PROTECTION 

AGENCY 

Office of Pesticide Programs 

Registration Division (7505P) 

Ariel Rios Building 

1200 Pennsylvania Ave., NW 

Washington, D.C. 20460 

NOTICE OF PESTICIDE: 

L Registration 

_ Reregistration 

(under FIFRA, as amended) 

EPA Reg. Number: Date ofIssuance: 

87290-1 

Tenn of Issuance: rrYnt1iti,,""l 

Name of Pesticide Product: 

Willowood Ethofumesate SC 

Name and Address of Registrant ZIP Code): 

Willowood, LLC 

8690 Lookingglass Road 

Roseburg, OR 97471 

On the basis of infonnation furnished by the registrant, the above named pesticide is hereby registered/reregistered under the Federal Insecticide, 

Fungicide and Rodenticide Act. Registration is in no way to be construed as an endorsement or recommendation of this product by the Agency. In order 

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

with the Act. The acceptance of any name in connection with the registration of a product under this Act is not to be construed as giving the registrant a 

right to exclusive use of the name or to its use ifit has been covered by others. 

The 'Basic Formulation' dated IIS/2010 is acceptable. 

This product is conditionally registered in accordance with FIFRA provided that you: 

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

Agency requires all registrants of similar products to submit data. 

2. Submit the data listed below: 

a. Within one year of the date on this registration notice, Storage Stability (830.6317) and 

Corrosion Characteristics (830.6320) studies must be submitted. It is recommended that the 

observations be made at 0, 3, 6, 9, and 12 month intervals. 

3. Make the following label revisions: 

a. Revise "EPA REG. NO.87290-" to "EPA REG. NO. 87290-1" 

b. Revise "Handlers ... " to "Mixers and loaders ... " in the first sentence of the engineering 

controls for on-site mixing and loading. 

c. Add "or rinsate" after "washwaters" in the last sentence of the Environmental Hazards 

statement. 

Continued on Page 2 

Signature 

Kathryn V. Monta:¢eiV 

Project Manager 

Herbicide Rr:mchV 

Registration Division (7505P) 

Date: 

37
Page 2 

EPA Reg. No. 87290-1 

Notice of Registration 

d. Revise the first sentence of the 'Use Precautions' section on pg. 2 to read as follows: 

"Willowood Ethofumesate SC or tank mixes must be used for label listed purposes and at labelspecified rates only." 

e. Per the Ethofumesate RED, make the following revisions to the 'Agricultural Use Requirements' 

box on pg. 3: 

1. Remove the period after the sentence "Do not enter or allow ... 12 hours" and add "for all 

crops, except turf grown for sod. The REI for turf is 9 days. The REI for each crop is listed in 

the directions for use associated with each crop." 

2. Add the WPS Double Notification Statement: "NotifY workers of the application by warning 

them orally and by posting warning signs at entrances to treated areas." 

£ Remove the word "General" from all label section headings (e.g. General Information, General 

Application) as this term is an implied safety claim that makes all associated text unenforceable. 

"General" may be replaced with "Product" where applicable. 

g. Replace all instances of "recommended rates" with "label-listed rates" or "specified rates." 

Recommendations are not enforceable. 

See: Last sentence on pg. 7 

Every "DO NOT OVERTREAT ... " sentence throughout the label 

First sentence, second paragraph on pg. 27 

h. Add the following rate restriction above the 'Precautions' section for sugar beets on pg. 4: 

"Aerial Application Rate Restriction: Do not apply more than 1.5 Ib ai (3 pints of product) per 

acre with aircraft." 

i. Replace "No more than a total of 1 gallon ofWillowood Ethofumesate SC should be applied in a 

single growing season." on pages 4 and 10 with the fOllowing: 

"Do not apply more than 3.75 Ibs ai (7 pints of product) per acre per season for sugar beets." 

In addition, revise the heading "Precautions" with "PrecautionslRestrictions." 

j. Replace "96 fluid ounces (0.75 gallon) of product per season" with "2.6 lbs ai (80 ounces of 

product) per acre per season." below the table on page 18. 

k. On page 18, replace the heading "Precautions" with "Rate Restriction" and add, "Do not apply 

more than 1.9 lbs ai (3 pints of product) per acre per pre-emergent application to table beets." 

Delete "No more than a total of 0.75 gallon of ... in a single growing season." 

1. Add the following rate restriction for post-emergent application to table beets on page 19: 

"Post-emergent application Rate Restriction: Do not apply more than 0.33 lb ai per acre per 

application. " 

m. Delete "No more than a total of I gallon ofWillowood Ethofumesate SC should be applied in a 

single growing season." on pg. 21 as it conflicts with the maximum use rates for onion, garlic 

and shallot. 

Continued on page 3 

38
Page 3 

EPA Reg. No. 87290-1 

Notice of Registration 

n. Revise all instances of"3 % pints per acre" to "3 pints per acre" in the 'New Seedlings of Annual 

or Perennial Ryegrass' sections on page 26, the 'New Seedlings of Fall-Planted Perennial 

Ryegrass and Tall fescue treated with Diuron Plus Charcoal' sections on page 27, and the 

'Established Stands of Perennial Ryegrass and Tall Fescue' sections on page 27 since '3 % 

pints' exceeds the maximum use rate of 1.5 Ibs ai/acre/season. 

o. Replace "DO NOT apply more than I gallon of Willowood Ethofumesate SC per acre per 

growing season" on page 29 with the following: 

"Do not apply more than 1.5 Ibs ai (3 pints of product) per acre per season for perennial ryegrass 

and tall fescue sod." 

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

If these conditions are not complied with, the registration will be subject to cancellation in accordance 

with FIFRA sec. 6(e). Your release for shipment of the product constitutes acceptance of these 

conditions. A stamped copy of the label is enclosed for your records. 

Enclosure 

39
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 

FIRST AID 

% by Weight 

. .... 42.0% 

. .... 58.0% 

.100.0% 

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

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

• Do not induce vomiting unless told to do so by 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 doctor for 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. 

If on skin or • Take off contaminated clothing. 

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

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

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 

witb COMMENTS 

hn EPA Lette~ Daterll: 

Under the federall" ·,icide, 

Fungicide, and Roder,;;cideActNet Contents: 

as amended, for the pesticide 

registered under EPA Reg. No. 

EPA Est. No. 

) r j > 

40
PRECAUTIONARY STATEMENTS 

HAZARDS TO HUMANS AND DOMESTIC ANIMALS 

CAUTION 

Harmful if swallowed or inhaled. Avoid breathing vapor or 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 must wear: 

• 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 if the 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 hot water. Keep and wash PPE separately from other laundry. 

ENGINEERING CONTROLS STATEMENT 

When handlers use closed systems, enclosed cabs, or aircraft in a manner that meets the requirements 

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

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

41
Do not apply this product through any type of irrigation system. 

If crop is lost due to climatic or soil conditions following application of Willowood 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 of the user at the time of pesticide application. 

DIRECTIONS FOR USE 

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

Read entire Directions for Use and Condition of Sale and Limitation of Warranty 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 CONTAINER WELL 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 of agricultural workers on farms, forests, 

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

decontamination, notification, and emergency assistance. It also contains specific instructions and 

exceptions pertaining to the statements on this label about personal protective equipment (PPE), and 

restricted-entry interval. The requirements in this box only apply to uses of this product that are covered 

by the Worker Protection Standard. 

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

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, or water, is: 

• Coveralls 

• Chemical-resistant gloves made of any waterproof 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 of application (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 greater than 15 mph. 

3 

42
Temperature 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 of these 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 of Willowood 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 pre plant 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 Broadleaf Weeds 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 Polygonum pennsylvanicum 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 of the lower rate of Willowood Ethofumesate SC recommended . 

•• Control of wild 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 Capsella bursa-pastoris 

Purple nutsedge Cyperus rotundus 

Yellow nutsedge Cyperus esculentus 

Apply tank mixes only in specific regions or States and in accordance with directions on label. 

PREPLANT INCORPORATED AND PREEMERGENCE APPLICATIONS 

4 

43
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. 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 prior to 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 of the 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 of the beds are thoroughly wetted. 

Irrigate from furrows on both sides of the row. 

Fall: This method of application can be used when spring moisture is marginal or where irrigation water is 

not available at planting time. Fall bedding utilizes the winter-accumulated moisture to enhance activation 

of the herbicide and to aid in germination of the 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 River Valley (Minnesota 

and North Dakota), It is recommended that Willowood Ethofumesate SC or the tank mix be applied before 

or at 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 

44
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 of Willowood Ethofumesate SC per Acre 

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 1 to 1 1/2 1 to 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 per Acre 

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 

45
WILLOWOOD ETHOFUMESATE SC + PYRAMIN® (TANK MIX) 

This tank mix control these additional broad leaf weeds: 

Annual sowthistle Sonchus oleraceus 

Black mustard Brassica nigra 

Buffalobur Solanum rostra tum 

Coast fiddleneck Amsinckia intermedia 

Common groundsel Senecio vulgaris 

Common ragweed Ambrosia artemisiifolia 

Cutleaf nightshade Solanum triflorum 

Groundcherry Physalis spp. 

Henbit Lamium amplexicaule 

Nettleleaf goosefoot 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 3 for 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 1 to 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: 4 to 5 1/4 1 1/3 to 1 3/4 4 1/2 1 1/2 

Clay loams with contain Pints Pints Pounds Pounds 

more than 3% organic 

matter and clays 

7 

46
1 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 andlor where volunteer barley or wheat 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 broad leaf 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 wh ich 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. If fields 

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 

47
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 Broadleaf Weeds 

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 

Nettleleaf goosefoot Chenopodium murale 

Pennsylvania smartweed Polygonum pennsylvanicum 

Prostrate pigweed Amaranthus gracizans 

Redroot pigweed Amaranthus retroflexus 

Purslane Portulaca oleraceus 

Shepherdspurse Capsella bursa-pastoris 

Wild buckwheat Polygon urn 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, a tank mix of Willowood 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 

48
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 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 of sprinkler 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 of Willowood 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 for additional information on proper use. 

Split (Low Rate) Applications 

Split (low rate) applications of Willowood 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 of water 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" 

10 

49
Broadcast 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-leaf stage. 

Redroot Pigweed Amaranthus retroflex us 

Wild mustard Brassica kaber 

Nettleleaf goosefoot 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 

50
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 of Willowood Ethofumesate SC Per Acre' Rate of Betamix® Per Acre' 

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 larger weeds 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 up to the 6-leaf stage. 

Redroot pigweed Amaranthus retroflexus 

Wild mustard Brassica kaber 

Net!leleaf goosefoot Chenopodium murale 

London rocket Sisymbrium irio 

Common lambsquarters Chenopodium album 

Group II: Weeds controlled up to the 4-leaf stage 

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 

12 

51
WEED SPECIES CONTROLLED 

Group III: Weeds controlled up to the 2-leaf stage 

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 of Willowood Ethofumesate SC Per Acre Rate of Betanex® Per Acre 

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 larger weeds 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. If fields 

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 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 a preplant or preemergence herbicide or other chemicals 

• Insect or disease injury 

• Close cultivation 

If stress 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 of application may reduce weed kill. 

If Willowood 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 

52
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 broad leaf 

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 a fine 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 dry fertilizer ingredients for 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 

53
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 Chart for the Impregnation of Dry Bulk Fertilizers with Willowood Ethofumesate SC: 

Gallons of Willowood Ethofumesate SC per Ton 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 for spray tank applications. 

Material Required 

1. Willowood Ethofumesate SC- components of tank 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 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) of the liquid fertilizer into each of the quart containers. 

2. Add adjuvant(s) to one or more of the containers and mix; follow label directions of adjuvant 

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. Inspect the surface and body of the mixture: 

a. immediately after mixing, 

b. after allowing mixtures to stand quietly for 30 minutes, 

c. immediately after mixing again (invert the 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 of the 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 

54
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 for spray tank application. 

RATE TABLE FOR WILLOWOOD ETHOFUMESATE SC MIXTURES WITH LIQUID FERTILIZERS 

Gal. of Liquid Fertilizer to be *ml or tsp. of Willowood Ethofumesate SC to be added to 1 pint 

applied per acre of fertilizer 

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 of Willowood 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 of Willowood Ethofumesate SC in the soil is reduced as the soil texture becomes finer 

and organic matter increases. 

WEED SPECIES CONTROLLED 

Annual Broadleaf Weeds 

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 Polygonum persicaria 

Pennsylvania smartweed Polygonum pennsy/vanicum 

Redroot pigweed Amaranthus retroflexus 

Russian thistle Salso/a kali var. tenuifolia 

Wild buckwheat Polygonum convolvulus 

I Annual Grass Weeds 

16 

55
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. 

Volunteer wheat Triticum sp. 

Wild oats" Avena fatua 

Yellow foxtail Setaria g/auca 

•• Control of wild 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 of water 

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 of Willowood Ethofumesate SC. 

17 

56
WILLOWOOD ETHOFUMESATE SC ALONE 

DOSAGE FOR BROADCAST APPLICATIONS 

Table Beet Stage WILLOWOOD ETHOFUMESATE SC 

FLUID OUNCES/ACRE BROADCAST 

Preemergence 

Postemergence: 

2-Leaf 

4-Leaf 

6-Leaf to 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 of Willowood Ethofumesate SC in the same season. 

PRECAUTIONS 

No more than a total of 0.75 gallon of Willowood 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 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. 

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 prior to using Willowood Ethofumesate 

SC. 

POSTEMERGENCE APPLICATION 

General Information 

Willowood Ethofumesate SC applied postemergence broadens and enhances the control of weeds. 

Mixing the Spray: Add Willowood Ethofumesate SC to the water in the spray while agitating the spray 

solution thoroughly. 

18 

57
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 

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 of sprinkler 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 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 a preplant or preemergence herbicide or other chemicals 

• Insect or disease injury 

• Close cultivation 

If stress 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 of application may reduce weed kill. 

If Willowood 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 of Willowood Ethofumesate SC in the soil is reduced as the soil texture becomes finer 

and organic matter increases. 

WEED SPECIES CONTROLLED 

Annual Broad leaf Weeds 

Black nightshade So/anum nigrum 

Common chickweed Stelfaria media 

Common lambsquarters Chenopodium album 

Common purslane Portulaca o/eracea 

19 

58
Annual Broadleaf Weeds 

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 of wild 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 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 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. 

20 

59
Onion, 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 of water 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 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 BROADCAST APPLICATIONS 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 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, high 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, 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 of Willowood Ethofumesate SC in the same season. 

PRECAUTIONS 

No more than a total of 0.75 gallon of Willowood 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 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. 

When applying Willowood Ethofumesate SC or tank mixes in a band, check to make certain that the band 

width is accurate for the dosage rafe being applied. 

21 

60
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 of weeds. 

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 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 of sprinkler 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 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 

If stress 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 of application may reduce weed kill. 

If Willowood 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 of Willowood Ethofumesate SC in the soil is reduced as the soil texture becomes finer 

and organic matter increases. 

22 

61
WEED SPECIES CONTROLLED 

Annual Broadleaf Weeds 

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 retroflex us 

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. 

Volunteer wheat Triticum sp. 

Wild oats Avena fatua 

Yellow foxtail Setaria glauca 

Willowood Ethofumesate SC alone will also reduce competition 

from these HARD-TO-CONTROL weeds: 

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 

62
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 of water 

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 

deeper than two inches, as this reduces the effectiveness of Willowood 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-Leaf to 4 Leaf Stage 64 

Do not exceed 128 fluid ounces (1 gallon) of product 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. If fields are replanted to sugar beets, reseed into treated band. Do 

not retreat field with preemergence rates of Willowood 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. 

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 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 

63
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 prior to using Willowood Ethofumesate 

SC. 

POSTEMERGENCE APPLICATION 

General Information 

Willowood Ethofumesate SC applied postemergence broadens and enhances the control of weeds. 

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 

of spraying my 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 of sprinkler 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 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 

If stress 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 of application may reduce weed kill. 

If Willowood 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 or reduces competition 

from those weed species listed below. Willowood Ethofumesate SC may be applied preemergence to 

25 

64
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 or overhead 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 of Willowood 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 volunteer wheat Triticum spp. 

Seedling volunteer barley Hordeum spp. 

Soft chess Bromus mol/is 

Seedling Wild oats Avena fatua 

Downy brome Bromus tectarum 

Common chickweed Stella ria 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. 

NEW SEEDINGS 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 later than the 4-leaf stage. Raltail fescue, wild oats, and volunteer cereals which are more difficult to 

control, must be treated no later than 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. 

NEW SEEDINGS OF FALL-PLANTED PERENNIAL RYE GRASS AND TALL FESCUE TREATED WITH 

DIU RON PLUS CHARCOAL 

26 

65
Timing 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 of the 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 diu ron 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 Per Acre Remarks 

Perennial ryegrass and tall 1 1/2 to 3 pints For effective control, annual 

fescue bluegrass must be treated before 

the 4-leaf stage; 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 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 later than 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 later than 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-leaf stage. 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 of Willowood Ethofumesate SC per acre on bentgrass. 

ESTABLISHED STANDS OF KENTUCKY BLUEGRASS (UNDER IRRIGATION ONLY) 

27 

66
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 incorporate Willowood 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. 

If vegetative matter or stover from 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 of charcoal 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 after application is necessary for activation. 

Do not harvest treated 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 

67
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 of Willowood 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. 

If vegetative matter or stover from previous crop was burned, sufficient rainfall or overhead irrigation must 

have occurred to dissipate the charcoal residue remaining after burning prior to Willowood Ethofumesate 

SC treatment. Failure to allow for dissipation of charcoal residue may result in reduced weed control. 

STORAGE AND DISPOSAL 

Do not contaminate water, food, or feed 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 a violation of Federal law. If these wastes cannot be disposed of by 

use according to label instructions, contact your State Pesticide or Environmental Control Agency, or the 

Hazardous Waste representative at the nearest EPA 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 1/4 full with water and recap. Shake for 10 seconds. Pour rinsate into application equipment or 

a mix tank or store rinsate for later use or disposal. Drain for 10 seconds after the flow begins to drip. 

Repeat this procedure two more times. Then offer for recycling 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 of smoke. 

(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 

68
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 of smoke. 

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 of such 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 of Warranty and Liability, which may not be modified except by written 

agreement signed by a duly authorized representative of Willowood, LLC. 

[EPA approval date] 

30 

69
NOTE FOR RECORD 

EPA Reg. No.1 File Symbol: 87290-R 

Product Name: Willowood Ethofumesate SC 

Application Dated: January 5, 2010 

Action Description: New End Use Product (Ethofumesate) for commercial turf production, 

sugar beets, carrots, garden beets, onions, garlic and shallots 

Comments: 

PRODUCT CHEMISTRY: 

-Basic CSF dated 11512010 was found acceptable by TRB. 

-Product Chemistry data requirements for Group A and Group B are satisfied with their 

own submitted studies (MRlDs 479487-01 and 479487-02). 

-The one year storage stability and corrosion characteristics data must still be satisfied. 

-TRB finds this proposed product to be substantially similar to EPA Reg. No. 70506-106 

ACUTE TOXICITY REVIEW: 

-Registrant is using the CITE ALL option for acute tox. 

-Signal Word: not required as all are tox. cat. IV, however registrant is opting to use 

CAUTION labeling 

DATA COMPENSATION: 

-Cite all under the selective method for the acute tox. studies supporting Ethofumesate 

-Formulator's Exemption listing technical sources ofEthofumesate on the basic CSF to 

cover generic data compensation requirements. 

-Certification with Respect to Citation of Data: Selective Method with Offer to Pay 

Ethofumesate data submitters 

LABEL REVIEW: 

1. Minor technical revisions of' General' and "recommended rates" 

2. Rate changes to match the Ethofumesate RED 

3. Ag. Use Requirements box changes to match RED 

4. Add aerial application use rate restriction for sugar beets per the RED 

** NOTE: The cited prod~~t (70506-106) label that was accep. ted. May 22,2009 needs ~ese J 

same label reVISIOns./, 11 'uu""" 1fI.- .. LL\ IJ'" \~~'! C'A kA' J\., 11/0" \ • \ !v 

v<- ! lV~ 'VI -n'"",,~ tY) ~lk:/~' Jt~ .. lj1(1}»~ 'i 1/ 

DATA GAPS: 

Storage Stability (830.6317) 

Corrosion Characteristics (830.6320) 

70
DATE OUT: 09 Mar 2010 

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 register the proposed enduse product, Willowood Ethofumesate SC. The active ingredient in this product is Ethofumesate 

(97.7% pail at a label nominal concentration of 42.0% 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 of this 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 of the active ingredient. 

2. All inert ingredients are approved for use in formulated pesticide products. In addition, all 

inert ingredients are exempt from the requirement of a food tolerance when applied preplant. 

3. The nominal concentration of the 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 of the 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 a waiver (MRID# 479487-03) for several physical and 

chemical properties data requirements. Several of the data requirements are not 

applicable to the proposed end-use product and several of the data requirements are 

only applicable to technical grade active ingredients (TGAI). 

71
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 158.355 with respect to product 

identity and composition, description of materials used to produce the product, 

description of formulation process, discussion of formation 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 158.310 with 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 for waiver of several physical and chemical properties 

data requirements and determined that a request for waiver of these 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 

of footnotes which further detail a data requirement's applicability. If questions 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. Preliminary Analysis NA 

830.1750. Certified Limits Y see csf 1/5/10 

830.1800. Enforcement Analy1ical Method Y 479487-01 

2 

72
PRODUCT 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@250 C 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. 

3 

73
Enforcement Analytical Method: (MRID No.479487 -01) 

The active ingredient, Ethofumesate, was determined by high performance liquid chromatography 

(HPLC) using ultraviolet detection (UV) at 252 nm. Sample is dissolved in a solution of citric 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, 1 liD x 4.6 mm 

5.0 ~I 

Acetonitrile:THF:Water 32.5/10/57.5; adjust to pH 4 with citric 

acid 

2.0 mllmin 

4 

74
EPA File Symbol 87290-R 

PC Code 110601 (ethofumesate) 

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 

WASHINGTON, D.C. 20460 

OFFICE OF PREVENTION, PESTICIDES 

AND TOXIC SUBSTANCES 

TECHNICAL REVIEW BRANCH 

SIMILARITY CLINIC DETERMINATION 

251FEB12010 

MEMORANDUM 

Subject: 

From: 

To: 

Applicant: 

Name of Pesticide Product: 

EPA Reg. No. IFile Symbol: 

DP Barcode: 

Decision No: 

Action Code: 

PC Code: 

Eugenia McAndrew, Biologist 

Technical Review Branch 

Registration Division (7505P) 

Bethany Benbow, RM Team 23 

Herbicide Branch 

Registration Division (7505P) 

Willowood, LLC 

8690 Lookingglass Road 

Roseburg, OR 97470 

FORMULATION FROM LABEL: 

Active Ingredient(s): 

Ethofumesate 

Inert Ingredient(s): 

Willowood Ethofumesate SC 

87290-R 

D373565 

425897 

R300 

110601 (ethofumesate) 

Total: 

% bywt. 

42.0 

58.0 

100.0% 

ACTION REQUESTED: The Risk Manager requests: Registrant is claiming substantial 

similarity to EPA Reg. No. 70506-106. 

Page 1 of3 

75
EPA File Symbol 87290-R 

PC Code 11060 I (ethofumesate) 

BACKGROUND: Willowood, LLC has applied for registration ofWillowood Ethofumesate 

SC, EPA File Symbol 87290-R, claiming similarity to Etho SC, EPA Reg. No. 70506-106. The 

active ingredient in both products is 42% ethofumesate. The Registrant is using the cite-all 

method of data support to satisfY the acute toxicity data requirements. 

A search of the OPP electronic databases shows that acute toxicity data were cited to support the 

reregistration of the cited product, 70506-106, in a Product Reregistration Branch memo 

(Dupuy; D361681; 31!MARl2009). An acute toxicity profile was assigned to 70506-106 in the 

same memo. 

RECOMMENDATIONS: 

1. TRB has evaluated the formulations of the proposed product, 87290-R, and the cited product, 

70506-106, and has determined that the two 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 EPA Reg. No. 70506-106 

acute dermal toxicity IV cited EPA Reg. No. 70506-106 

acute inhalation toxicity IV cited EPA Reg. No. 70506-106 

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

primary skin irritation IV cited EPA Reg. No. 70506-106 

dermal sensitization negative* cited EPA Reg. 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 of this 

action, TRB has made no further determination of the adequacy of the toxicological data base or 

the precautionary label of the cited product. 

4. The proposed basic CSF dated January 5, 2010 should be approved by the TRB Product 

Chemistry Team. 

LABELING: Based on the toxicity profile above, the following are the precautionary and first 

aid statements for this product as obtained from the Label Review System: 

PRODUCT ID #: 087290-00001 

PRODUCT NAME: Willowood Ethofumesate SC 

Page2of3 

76
EPA File Symbol 87290-R 

PC Code 110601 (ethofumesate) 

SIGNAL WORD: 

(Optional) 

PRECAUTIONARY STATEMENTS 

CAUTION 

Hazards to Humans and Domestic Animals: 

Wear: Long-sleeved shirt and long pants, socks, shoes, and chemical-resistant gloves (such as Natural 

Rubber, Selection Category A). 

First Aid: No statements are required. Category III statements may be used. 

Page 3 of3 

77
PYXIS REGULATORY CONSULTING, INC. 

4110136'" SI. NW 

Gig Harbor, WA 98332 

COURIER DELIVERY 

Kathryn Montague (PM 23) 

Document Processing Desk (REGFEE) 

Office of Pesticide Programs (7504P) 

U,S, Environmental Protection Agency 

Room S-4900, One Potomac Yard 

2777 S, Crystal Drive 

Arlington, VA 22202-4501 

January 5, 2010 

RE: Willowood, LLC - Willowood Ethofumesate SC (EPA Reg, No, 87290-

Application for New Pesticide 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 of this 

application, we submit the following documents: 

I, Application for Registration (EPA Form 8570-1) 

2, Receipt of PRIA pre-payment from pay,gov 

3, Fee Waiver request and supporting documentation 

4, Confidential Statement of Formula (Basic Formulation dated January 5, 20 I 0) 

5, Formulators Exemption Statement (EPA Form 8570-27) 

6, Five (5) copies of the proposed labeling 

7, Certification with Respect to Label Integrity 

8, Electronic copy of the Willowood Ethofumesate SC label on CD 

9, Certification with Respect to Citation of Data (EPA Form 8570-34) 

10, Agency Internal Use Copy of the Data Matrix (EPA Form 8570-35) 

II. Public File Copy of the Data Matrix (EPA Form 8570-35) 

12, Letter of Authorization 

13, Product Specific Data: 

Volume I 830,1550,830,1600, Kellogg, M, Product Identity and Composition, Description of the 

830,1650,830,1670, Materials Used, Description of the Formulation Process, Discussion 

47948701 830,1750, 830,1800 of the Formation of Impurities, 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 of Ethofume·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 Datd hq,,:rements for 

830,6313,830,6316, Willowood Ethofumesate Sc. 

830,6319, 830,6321, 47948703 

830,7050, 830,7200, 

830,7220, 830,7370, 

78
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 similar to 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) of active ingredient 

are based on a registered source of supply and therefore, Willowood Ethofumesate SC qualifies for 

Formulators Exemption for ethofumesate generic data requirements. 

Willowood, LLC is requesting a 50% small business fee waiver for this action and has paid 50% of the 

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 if you have any questions or need any additional information. 

Michael Kellogg 

Enclosures 

cc: B. Heinze; Willowood, LLC 

79
&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 

o Etho SC Check if this 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 of data 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.gov for 50% of the 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" 

Unit Packaging wgt. container Package wgt 

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 for idfNItificstion of indfvidus/ to be contact(Jd, if n8c(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 

80- AppHcant Copy 
• 

411O 136th St. NW 

Gig Harbor, W A 98332 

November 9, 2009 

WILLOWOOD, LLC 

Phone: 253-853-7369 

Fax: 253-853-5516 

Document Processing Desk (COADR) 

Office of Pesticide Programs (7504P) 

u.s. Environmental Protection Agency 

Room S-4900, One Potomac Yard 

2777 S. Crystal Drive 

Arlington, VA 22202 

To Wbom It May Concern: 

RE: Letter of Authorization 

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 EPA to: 

Agent: 

Pyxis Regulatory ConSUlting, Inc. 

4110 136th St. NW 

Gig Harbor, WA 98332 

T: (253) 853-7369 

F: (253) 853-5516 

info@PyxisRC.com 

If you have any questions, please do not hesitate to contact me . 

Sincerely, 

~ Brian Heinze 

President 

WiIIowood, LLC 

... 

cc: Pyxis Regulatory Consulting, Inc. 

l:J.l) J 1 

l) i I) 

. , 

81
) 

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 of the applicant for registration of the product identified above, I certify that: 

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

Ethofumesate 

(2) Of these, each active ingredient listed in paragraph (4) is present solely as the result of1he use of that active ingredient in the manufacturing, 

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

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

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

71 (A) An accurate Confidential Statement of Formula (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 qualify for the formulator's exemption. 

Source 

Active Ingredient Product Name Registration Number 

Ethofumesate , 

~ , ~ ~ a J _ 

, 

, 

, 

, , , , , , " , 

, , , ., } ) .) j :. 

;;;_llJAJ~ Name and Title Date , 

Ilr/.. } ~ J ~ 

Michael Kellogg 1 Agent D A' " E~A Form 85110-27 (Rev. 06-20~ V Copy 1 - EPA 

Copy 2 - Applicant copy 

82

*Product ingredient source information may be entitled to confidential treatment*
Form OMS No. 

"""",~ . ft) UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 

~~, 401 M Street, S.W. 

WASHINGTON, D.C. 20460 

PapeIWork Reduction Act Notice: The pubic reporting burden for this collection of information is estimated to average 1.25 hours per response 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 other aspect of this 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. 

Certification with Respect to Citation of Data 

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/or reoresentative test comoound(s) Date 

Ethofumesate January 5, 2010 

General Use Patlem{s) {fist all those claimed for this productusinQ 40 CFR Part 158} Product Name 

Terrestrial Food/Nonfood Wiffowood Ethofumesate SC 

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

submit this form. 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 of companies sent offer.; of compensation (the Data Matrix form should 

be used for this purpose). 

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

D I am using the ate-all method of support, and have included with this form [2] I am using the selective method of support (or dte-all option 

a fist of companies sent offer.; of compensation (the Data Matrix form under the selective method), and have included w'lth this form a 

should be used for this purpose). completed list of data requirements (the Data Matrix form must be 

used). 

SECTION II: OFFER TO PAY 

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

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

SECTION III: CERTIFICATION 

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

application for registration, the form for reregistration, or the Data-Call-In response. In addition, if the cite-all option or dte-all option under the selective method Is 

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

substantially simifar product, or one or more of the ingredients in this product; and (2) is a type of data that would be required to be submitted Llf).der thlt data 

requirements in effect on the date of approval of this application if the application sought the initial registration of a product of identical or similarJC0m;oosition and 

uses. ~ " } , ) } 

, , , , , , , , 

I certify that for each exdusive use study dted in support of this registration or reregistration, that I am the original data subm~ter or that I have obtained 

the written permission of the original data submitter to cite that study. " Cj } ) ;; ~ , 

, , I certify that for each study cited in support of this registration or reregistration that is not an exdusive use study, either: (a) I)am the ogg~rfa~dcla 

submitter, (b) I have obtained the permission of the original data submitter to use the study in support of this application; (c) all :mriZldDof efigibifityi!for ) 

compensation have expired for the study; (d) the study is in the public literature; or (e) I have notified in writing the company that 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) of FIFRA; and Qi) to commence n~'bMtbns to det~mine)the 

amount and terms of compensation, if any, to be paid for the use of the study. } li ~ " 1> ) , 

I certify that in all instances where an offer of compensation is required, copies of an offers to pay compensation and evidence of their <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 I faif to prcJ{H!I~such 

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

FIFRA. 

I certify that the 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 bj fine 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 i 

83
Form Approved 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 burden for 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, including time for reading the instructions and completing the necessary fonns. Send comments regarding the burden estimate or any other aspect of this collection of 

'Infonnation, incIud'lng suggestions for reduc"lng the burden to: Director, OPPE Information Management D'lv'lsion (2137), U,S. Environmental Protection Agency, 401 M Street, S.W., Washington, DC 20460. Do not 

send the fonn to this address, 

DATA MATRIX 

Date 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 Enforcement Analytical Method Volume 1 Willowood, LLC OWN 

830.6302 Color Not reguired3 

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 ~l . Y //S~!d 

84
Form 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 of information 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 of this collection of 

information, including suggestions for reducing the burden to: Director, OPPE Information Management Division (2137), U.S. Environmental Protection Agency, 40t 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- I Page;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 required6 

830.6320 Corrosion Characteristics See endnoteS 

830.6321 Dielectric Breakdown Voltage Not r~uired 7 

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 required3 

Generator Column Method 

830.7570 , ", "R~rtitio~"Goefficient 0r!-octanolfwater), Not required3 

: : E:stirnauGn by Liquid :Chromatography 

~:.j/) 

"w " " ,--,., ",""' "- Name and Title Date 

Michael Kellogg, Consultant t!.s-l ;;:K!J/Q 

85
Form 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 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 or any other aspect of this collection of 

information, including suggestions for reducing the burden to: Director, OPPE Information Management Division (2137), U.S. Environmental Protection Agency, 401 M Street, S.W., Washington, DC 20460. Do not 

send the 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,uired3 

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 Paper versions available. Submit only Paper version. Agency Internal Use Copy 

86
Form 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 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 or any other aspect of this 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 Product Specific Data Requirements 

Willowood, LLC is using the cite-all option under the selective method to satisfy 

acute toxicity data requirements. Willowood, LLC will make offers-to-pay to the 

following companies on the September 30, 2009 Data Submitters List for 

ethofumesate. 

Ethofumesate Product Specific Data Requirements 

Ethofumesate Prod uct 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 Prod uct Cite::.Al!~ , y " .~ · Agricultural Reentry Task PAY · 

Specific Data Requirements . , . . · Force Y-,.--~o/--<· 

Ethofumesate Prod uct 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 Copy 

87
Form 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 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 or any other aspect of this collection of 

information, including suggestions for reducing the burden to: Director, OPPE Information Management Division (2137), U.S. Environmental Protection Agency, 401 M Street, S.W., Washington, DC 20460. Do not 

send the form to this address. 

Date January_5,2010 

Applfcant'sJRegistran1's Name & Address 

Ingredient Ethofumesate 

Guideline Reference Number 

Ethofumesate Prod uct 

S[lecific Data Requirements 

Ethofumesate Prod uct 

Specific Data Requirements 

Ethofumesate Prod uct 

~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 

EPA Reg 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 Paper versions available. Submit only Paper version. Agency Internal Use Copy 

88
Endnotes for Data Matrix for Willowood Ethofumesate SC 

1 830.1620 _ Per OPPTS 830.1000, these data are not required for the registration of an 

end-use product. See 830.1650 for formulation process information. 

2830.1700 - This product does not consist solely of the 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 of an 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 of these 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 of 1 

89
Certification with Respect to Label Integrity 

version: 9/11/02 

I certify that the information (including, but not limited to, text, tables, and graphics) 

contained in the electronic file identified below by file name and submitted with this 

certification is the same information as that on the paper copies of these documents 

included with this submission. 

IPROPOSED LABEL 

Date Submitted 

EPA Registration # to EPA Electronic file name 

87290-xx January 5, 2010 087290-xxxxx.20 1 00 1 05.Willowood 

Ethofumesate SC label 

I certify that the statements that I have made on this form are true, accurate, and 

complete. I acknowledge that any knowingly false or misleading statements may be 

punishable by fine or imprisonment or both under applicable law. 

/,/.~O/O Date 

Michael Kellogg 

Name (typed) 

Agent 

Title 

90
There is an ELECTRONIC LABEL for this action 

You can use Acrobat to compare the e-Iabel to the previous version (and find the 

changes). You can also use Acrobat to mark-up the e-Iabel with your comments. 

If e-Iabel was submitted via 

CD-ROM with paper application 

then you will find e-Iabel in 

Electronic Label Library 

If the e~/abel is not found in the ELL then it was probably no! named 

correctly and could not be entered info the ELL. However, the file 

can be retrieved from the CD which is retained by the Front End. 

or If e-Iabel was submitted via 

XML E-Submission (no paper) 

then you will find e-Iabel in 

Documentum 

See overview of processing e-Iabels on other side of this sheet. 

If you have any questions on e-Iabels, please contact one of your division e-Iabel experts: 

AD Willie Abney 308-1689 

Renae Whitaker 308-7003 

Tracy Lantz 308-6415 

BPPD 

RD Tom Harris 308-9423 

91
PROCES~ING ELECTRONIC • 4BELS 

(rev, 1/5/09, tch) 

If e-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 at step 5, 

Initial E-Label per application (on CD-ROM with paper via ITRMD) 

1 ITRMD receives 

paper submission 

wi e-Iabel on CD 

, Save copy of elabel from ELL to 

My Documents 

1U Send annotated 

e-Iabel to registrant 

via email 

(also send ''How To Print") 

, Tracking 

record added to 

OPPIN 

I Review label 

(if acceptable, 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 of elabels (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 

letter to 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 

in jacke't 

, 

out-process 

H Connect ELL 

record with 

OPPIN S# 

(if revisions needed repeat steps 8-19) 

:.1;; Add cover 

letter to ELL 

(mandatory if accepted 

with comments) 

~4 Close 

submission in 

OPPIN 

techniques to know 

- filename for e-Iabels 

- "print with filename" 

- compare / comment 

- printing with comments 

92
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" , 

93
PRlA 2 - 21 Day Content Screen Review Worksheet 

(EPA/OPP Use Only) 

3/23/09 

21 Day Screen Start Date: __ --'-I _-_]-1L----'-f O,c,,-______ ---,-

Experts In-Processing Signature: ti'1 E r-+"t'l./tIP brON Date {- I { - 10 FeePaid: Yes / 

Division management contacted on issues No Yes ___ ~Date ______ _ 

EPA Reg. Number: ~ 7 29(; - R EPA Receipt Date: l-~-/O 

1 

2 

3 

Application Form (EPA Form 8570-1)(link to form) signed & complete 

including package type 

Confidential Statement of Formula all boxes completed, form signed, and 

dated Form . to 

a) All inerts (link to http://www.epa.gov/opprdOOllinerts/), 

including fragrances, approved for the proposed uses (see 

Footnote A) 

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

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

Certificate and data matrix consistent 

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

to pay statement included. (see Footnote B) 

If is there a letter of Authorization for exclusive use 

yes 

Exemption Statement (EPA to 

no 

4 completed and signed (N/ A if source is unregistered or applicant owns the 

5 

6 

Data Matrix (EPA Form 8570-35) (Link to form) both internal and external 

copies (PR 98-5) (Link to PR 98-5) completed and signed (N/A if 100% 

Selective Method 

b) Cite-All (Fee category experts use) 

c) Applicant owns all data (Fee category experts use) 

5 Copies of Label (link to http://www.epa.gov/oppfeadlllabelingllrmO 

(Electronic labels on CD are encouraged and guidance is available)( link to 

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

I 

94
7 Is the data package consistent with PR Notice 86-5 (link to PRN 86-5) ~ 

Notice of Filing (link to 

8 httn;//www.ena.gov/nesticides/regulating/tolerance netitions.htm) included 

with petitions (link to X 

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

9 If applicable for conventional applications, reduced risk rationale (link to ;( http;//www.epa.gov/opprdOOllworkplanireducedrisl{.html) 

Required Data (link to 

httJ);//www.ena.gov/nesticides/regulating/data reguirements.htm) and/or 

data waivers. See Footnote C. 

a) List study (or studies) not included with application 

10 

2 

95
D 

Comments: 

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

* NI A - Not Applicable 

Footnotes 

\ 

. , ,,"<c_ ! 

L/7 L( n 

A. During the 21 day initial content review, all CSFs will be reviewed to determine 

whether all inerts listed, including fragrances, are approved for the proposed uses. If an 

unapproved inert is identified, the applicant must either 1) resolve the inert issue by, for 

example, removing the inert, substituting it with an approved inert, submitting 

documentation that EPA approved the inert for the proposed pesticidal uses, correcting 

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

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

CSF and may require submission of data. All information, forms, data and 

documentation resolving the inert issue must have been received by the Agency or the 

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

application as described below. 

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

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

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

3 

96
site [link to http://www.epa.gov/opprdOOllinertsllists.html] and if the inert is not 

approved, to obtain the necessary inert approval prior to submitting an application 

to register a pesticide product containing that inert ingredient. Some inert 

ingredients are no longer approved for food uses or certain types of uses. The name 

and/or CAS number on a CSF must match the name and CAS number on this web site. 

Simple typographical errors in the name or CAS number have resulted in processing 

delays. 

If an inert is not listed on the inert ingredient web site and the applicant believes that the 

inert has been approved, the applicant should contact the Inert Ingredient Assessment 

Branch (nAB) at inertsbranch@epa.gov and resolve the issue. Copies of the 

correspondence with nAB resolving the issue should accompany the application. All 

new inerts except PIP inerts are reviewed by nAB. The nAB should also be contacted 

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

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

Microbial Pesticides Branch [Link to 

http://www.epa.gov/oppbppdllbiopesticides/contactsbppd.htm ]. 

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

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

information [link to http://www.epa.gov/opprdOOl/inerts/tips.pdfl must also be included 

to enable the Agency to determine if it has been approved. Each component of an inert 

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

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

Agency's receipt of an application, applicants must arrange with a proprietary mixture or 

fragrance supplier to provide the component information to the Agency or promptly upon 

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

cannot or are not identified or provided within the 2 I-day content review period, the 

Agency will reject the application. 

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

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

Unapproved Inerts Identified on CSFs 

All applications except conventional new products and PIPs 

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

applicant with the following options: 

I. Correct the application by, for instance, correcting the inert's identity or CAS 

number, providing documentation that the inert has been approved, or 

removing the unapproved inert from the CSF or replacing it with one that is 

approved for the application's uses; or 

2. Submit the information and data needed for the Agency to approve the 

unapproved inert. If this option is selected and implemented, the Agency may 

request an extension in the PRIA decision review timeframe to accommodate 

the inert review/approval process; 

4 

97
3. Withdraw the application (the Agency retains 25% of the full fee for the fee 

category estimated); or 

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

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

25% of the full fee of the category identified. 

Conventional New Product Applications 

When the Registration Division identifies an unapproved inert on a CSF with an 

application for a new product that the applicant has not identified as requiring an 

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

following options: 

I. Correct the application by, for instance, correcting the inert's identity or CAS 

number, providing documentation that the inert has been approved, or 

removing the unapproved inert from the CSF or replacing it with one that is 

approved for the application's uses; or 

2. Submit the information and data needed for the Agency to approve the 

unapproved inert, including any required petition to establish or amend a 

tolerance or exemption from a tolerance. (This option may change the PRIA 

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

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

Agency within the 21 day content review period.) 

3. Withdraw the application (the Agency retains 25% of the full fee for the fee 

category estimated); or 

If none of the above options is selected and implemented during the 21-day 

content-review period, the Agency will reject the application and retain 25% of 

the appropriate fee for the new product-inert approval category. 

PIP Applications 

When the Biopesticide and Pollution Prevention Division identifies an 

unapproved inert on a PIP CSF and a request to approve the inert does not 

accompany the application, it will contact the applicant with the following 

options: 

I. Correct the application by, for instance, correcting the spelling or name of the 

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

approved; or 

2. Submit the information and data needed for the Agency to approve the 

unapproved inert. If an inert ingredient tolerance exemption petition is 

required, the petition must be received by the Agency and the B903 fee paid 

within the 21 day period. If this option is selected and implemented, the 

Agency will discuss harmonizing the timeframe for both actions. 

5 

98
3. Withdraw the application (the Agency retains 25% of the full fee for the fee 

category estimated); or 

If none of the above options is selected and implemented during the 21 day 

content review period, the Agency will reject the application and retain 25% of 

the fee. 

B. A policy on documentation of offers to pay is still being developed, however, for a 

me-too or fast track (similar/identical) new product, R300 or A530, an application 

without the necessary authorizations of offers to pay will be placed into either R30 I or 

A531. The Agency recommends that authorizations of offers to pay be submitted with 

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

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

prior to submitting their application to the Agency. Documentation of such discussions 

should be submitted with the study waiver. 

6 

99
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 

WASHINGTON, D.C. 20460 

January 11,2010 

OPP Decision Number: D-425897 

EPA File Symbol or Registration Number: 87290-R 

Product Name: WILLOWOOD ETHOFUMESATE SC 

EPA Receipt Date: 08-Jan-20 1 0 

EPA Company Number: 87290 

OFFICE OF 

PREVENTION. PESTICIDES AND 

TOXIC SUBSTANCES 

Company Name: WILLOWOOD, LLCEP A File Symbol or Registration Number: 

JANELLE KAY 

PYXIS REGULATORY CONSULTING, INC. 

WILLOWOOD, LLC 

4110 1136TH STREET, NW 

GIG HARBOR, W A 98332-

SUBJECT: Receipt of Application and 50% Small Business Waiver Request 

Dear Registrant: 

The Office of Pesticide Programs has received your application, 50% small business 

waiver request, and cerification of payment. If you submitted data with this application, the 

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

screen, the Office of Pesticide Programs has determined that this Action is subject to a Pesticide 

Registration Service Fee as defined in the Pesticide Registration Improvement Act. 

The Action has been identified as Action Code: R300 

NEW PRODUCT;ME-TOO PRODUCT FAST TRACK; 

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

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

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

receive an invoice for the outstanding balance. 

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

Ombudsman at (703) 305-6249. ~ ~ 

100
IFee for Servicel 

ft 

f865285EThis package includes the following 

<!l New Registration 

o Amendment 

~ 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 NOT subject 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 

101
102
) 

FEE FOR SERVICE 

103
PR.'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 Not Write 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 United States Department of Agriculture or other Federal agencies, 

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 by authority of Section 4 of the "FederallnsectlC:lde, 

fungicide, and Rodenticide. Act.. 

USDA:AR! 

104
Pages 105 through 106 contain the product confidential statement of formula and is not included in this copy.