2 

### Table of Contents

Contents

I. INTRODUCTION

................................ ................................ ................................ .................. 3

A

. Summary of Sulfentrazone Registration Review

................................ .............................. 3

B. Public Comments

................................ ................................ ................................ .............. 4

II. USE AND USAGE

................................ ................................ ................................ .............. 6

III. SCIENTIFIC ASSESSMENTS

................................ ................................ ........................... 7

A. Human Heal th Risk Assessment

................................ ................................ ............................. 7

1. Risk Conclusions

................................ ................................ ................................ .......... 7

2. Human Incidents

................................ ................................ ................................ ........... 8

3. Tolerances

................................ ................................ ................................ ..................... 8
B. Ecological Risk Assessment

................................ ................................ ................................ .. 8

1. Risk Conclusions

................................ ................................ ................................ .......... 9

2. Ecological Incidents

................................ ................................ ................................ ... 11

3. Character ization of Ecological Risk

................................ ................................ ........... 11

C. Benefits Assessment

................................ ................................ ................................ ............. 13
D. Endangered Species Assessment

................................ ................................ .......................... 14

E. Endocrine Disruptor Screening Program

................................ ................................ ............... 15

IV. PR OPOSED INTERIM REGISTRATION REVIEW DECISION

................................ ... 16

A. Risk Mitigation and Regulatory Rationale

................................ ................................ ...... 16

B. Tolerance Amendments

................................ ................................ ................................ ... 18

C. Endangered Species

................................ ................................ ................................ ......... 18

D. Proposed Interim Registration Review Decision

................................ ............................ 18

E. Data Requirements

................................ ................................ ................................ .......... 19

V. NEXT STEPS AND TIMELINE

................................ ................................ .......................... 19

A. Interim Registration Review Decision

................................ ................................ ............ 19

B. Implementation of Mitigation Measures

................................ ................................ ......... 19
Appendix A: SULFENTRAZONE Label Table

................................ ................................ .......... 203



### I. INTRODUCTION

This document is the Environmental Protection Agency’s (EPA or the Agency) Proposed Interim Registration Review Decision for Sulfentrazone ( case 7231 , PC code 129801 ) and is being issued pursuant to 40 CFR sections 155.56 and 155.58

. A registration review decision is the Agency's determination whether a pesticide meets, or does n ot meet, the standard for registration in the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA). The Agency may issue, when it determines it to be appropriate, a n I nterim R egistration R eview D ecision before completing a registration review. Among other things, the I nterim R egistration R eview
D ecision may : 1) require new risk mitigation measures ; 2) impose interim risk mitigation

measures ; 3) identify additional data or other information required to complete the review ; and 4) include schedules fo r submitting the required data, conducting the new risk assessment

, and completing the registration review. For further information on sulfent r azone , additional documents can be found in EPA’s public docket (EPA

- HQ

- OPP

- 200 9

- 0 624 ) at www.regulations.gov

.

FIFRA, as amended by the Food Quality Protection Act (FQPA) of 1996, mandated the continuous review of existing pesticides. All pesticides distributed or sold in the United States generally must be registered by the EPA based on scientific data showing that they will not cause unreasonable risks to human health or to the environment when used as directed on product labeling. The registration review program is intended to make sure that, as the ability to assess

a nd reduce risk evolves and as policies and practices change, all registered pesticides continue to meet the statutory standard of no unreasonable adverse effects. Changes in science, public policy, and pesticide use practices will occur over time. Through the registration review program, the Agency periodically re

- evaluates pesticides to make sure that as these changes occur, products in the marketplace can continue to be used safely. Information on this program is provided a t www.epa.gov/oppsrrd1/registration_review/

. In 2006, the Agency implemented the registration review program pursuant to FIFRA section 3(g) and will review each registered pesticide every 15 years to determine whether it c ontinues to meet the FIFRA standard for registration.

Sulfentra z one is a broad

- spectrum herbicide registered to control broadleaf weeds on a variety of field crops, fruits, vegetables, ornamentals and turf. It is primarily applied as a pre

e mergent herbicide. Because sul f entrazone was first registered in 1997, it was not subject to reregistration.

A. Summary of Sulfentrazone Registration Review

Pursuant to 40 CFR section 155.50, EPA formally initiated registration review for
sulfe n tra z one (c ase 7231 ) in 2009

. The following list highlights significant events that have occurred during the registration review of sulfentrazone. Documentation of these events for
sulfentrazone can be found in EPA’s public docket

, EPA

- HQ

- OPP

- 200 9

- 0 624 , accessed at www.regulations.gov :

 Se p tember 23, 2009

– Publication of Sulfentrazone Preliminary Work Plan (PWP) for a 60

- day public comment period . The P reliminary W ork P lan (PWP) was accompanied by the scoping document and problem formulation.4

 April 5, 2010

– Final Work Plan (FWP) for Sulfentrazone was issued . Three public comments were received during the 60

- day comment period for the sulfe n trazone PWP; however, these comments d id not change the risk assessment or data needs identified in the PWP. Therefore, the FWP did not modify the PWP.

 September 28, 2010

– Generic Data Call

- In (GDCI) for sulfentrazone was issued.

 July 3, 2014

– EPA published the preliminary risk assessments for sulfentrazone for a 60

- day public comment period: Preliminary Ecological Risk Assessment for the Registration Review of Sulfentrazone and Proposed New Uses on Apples and Sulfen t razone

– Preliminary Human Health Risk Asses s ment for R e gistra ti on Review and the Risk Assessment for the Section 3 Registration Request for a New Use on Apples. EPA received comments from the Center for Biological Diversity (CBD) and FMC Corporation (FMC) , the sulfentrazone technical registrant

.

 June 2015

– The Agency is now publishing the Sulfentrazone Proposed Interim Registration Review Decision in the registration review docket (EPA

- HQ

- OPP

- 2009

- 0624) for a 60

- day public comment period. In addition to this document, the Agency is also publishi ng the following supporting documents:

o Response to Comments on the Preliminary Ecological Risk Assessment for the Registration Review of Sulfentrazone ;

o Response to Comments on the Preliminary Human Health Risk Assessment for the Registra t ion Review of Su lfentrazone ;

o Addendum to the Environmental Fate and Ecological Risk Assessment for Sulfentrazone Registration Review ;

o Sulfentrazone Usage Information; and

o Sulfen t razone Qualitative Benefits Assessment.

This document is organized in f ive sections: the Introduction, which includes this summary and a summary of public comments and EPA’s response; Use and Usage, which describes how and why sulfentrazone is used and summarizes data on its use; Scientific Assessments, which summarizes EPA’s risk assessm ent, any revisions, and risk conclusions; Proposed Interim Registration Review Decision, which describes the mitigation measures proposed to address risks of concern and the regulatory rationale for EPA’s registration review decision; and, last, the N ext S teps and T imeline for completion of this registration review.

B. Public Comments

During the 60

- day public comment period on the Sulfentrazone Preliminary Risk Assessments, which opened on July 3, 2014 and closed on September 3, 2014, the Agency
recei ved two public comments. Comments were submitted by the sulfentrazone technical registrant, FMC, and by CBD, an environmental and public interest group. T he public comments, and EPA’s response, are summarized below and in the Re sponse to Comments on the Preliminary Ecological Risk Assessment for the Registration Review of Sulfentrazone and the Response to Comments on the Preliminary Human Health Risk Assessment for the Registra t ion5

Review of Sulfentrazone

. Public comments in their entirety are located in the docket, EPA

- HQ

OPP

- 20 09

- 0624

.

C OMMENTS SUBMITTED BY CBD IN EPA

- HQ

- 2009

- 0624

- 0018

Comment : CBD’s comments focus on EPA’s duty to consult with the Services on the registration review of sulfentrazone in accordance with the Endangered Species Act ( ES A ) . The CBD comments mention various aspects of the risk assessment process, including use of the best available data to develop endangered species risk assessments, and evaluation of effects on endangered and threatened (listed) species and their design ated critical habitat. CBD also expresses concern regarding the rigor of the Agency’s preliminary determinations regarding the effects of sulfentrazone on listed species, and their designated critical habitat, for the sulfentrazone registration review.

Response : EPA has reviewed the comments from CBD on the preliminary risk assessment for the sulfentrazone registration review and plans to address many of the concerns raised by CBD as part of the implementation plan for assessing the risks of pesticides to listed species based on the recommendations of the April 2013 National Academy of Sciences (NAS) report 1 . EPA will address concerns specific to sulfentrazone in connection with the development of its final registration review decision fo r this pesticide.

C OMMENTS SUBMITTED BY FMC IN EPA

- HQ

- OPP

- 2009

- 0019 AND 0020

Comment : FMC’s comments focused on various technical aspects of the preliminary risk

assessment

s , including various underlying assumptions. In particular, FMC noted a calcula tion error in determining the No Adverse Effect Concentration (NOAEC) used to estimate risk to

n ontarget plants. FMC also noted discrepancies between assumptions in the risk assessment and actual use of sulfentrazone. For example, although the risk assessm ent assumed that sulfentrazone is applied by air, FMC cited data showing that over 99% of sulfentrazone is applied by ground equipment, using a low boom

.

Response: EPA re analyzed the data from the tier II vegetative vigor study for sulfentrazone, and recalculated the plant endpoint for sulfentrazone

. Because the recalculated plant endpoint was significantly differen t than the endpoint used in the preliminary risk assessment, the Agency revised the ecological risk assessment for sulfentrazone.

To a ddress discrepancies between the assumptions in the risk assessment and actual use of sulfentrazone, the Agency EPA reviewed available agricultural survey data for additional information on application rates, methods, and timing

. The Agency found that sulf entrazone is indeed applied mostly by ground equipment, using a low boom, to ensure maximum contact with
soil. EPA’s summary of agricultural survey data for sulfentrazone is summarized in an April 5, 2015 memo, Sulfentrazone Usage Information and in Sectio n II of this document.

1 National Acadamy of Science. 2013. As s essing Risks to Endangered and Threatened Species from Pesticides.
Available at http://www.epa.gov/espp/2013/nas.html

.6

The Agency revised the risk assessment for sulfentrazone to incorporate information from the public comments and the agricultural survey data . Risk quotients were revised for terrestrial plants, and spray drift effects distances we re recalculated using the Ag

- Drift model

. Revisions to the ecological risk assessment are summarized in Section IIIB of this document.

For EPA’s detailed response to comments please see the June 9, 2015 memo

, Response to Comments on the Preliminary Ecological Risk Assessment for the Registration Review of Sulfentrazone and the June 12, 2015 memo, Response to Comments on the Preliminary Human Health Risk Assessment for the Registra t ion Review of Sulfentrazone

.



### II

. USE AND USAGE

Sulfentrazone is a soil

- applied, pre

- emergent herbicide which can be applied either preplant incorporated or preemergence to the weeds. Sulfentrazone is a p roto p orphyrinogen Oxidase (PPO) Inhibitor , classified by the W eed Science So ciety of America (WSSA) as a Group 14 herbicide

. WSSA Group 14 herbicide s inhibit the protoporphyrinogen oxidase enzyme ( important in the production of chlorophyll ), causing a p eroxidation of lipids in the cell membrane leading to cell leakage. Therefore, first symptoms are water

- soaked lesions followed by necrosis of these lesions. Sulfentrazone is absorbed primarily by the roots and leads to rapid foliar desiccation (WSSA, 2014) 2

. Because sulfentrazone inhibits seed and propagule germination

, it needs to be applied as close to the soil surface as possible with the lowest possible amount of pesticide remaining on any leaf surfaces and the minimum amount of exposure to evaporation or the wind.

Sulfentrazone is registered for use to control a broad spectrum of broadleaf, grass, and sedge weed species on a wide variety of field crops, fruits, ornamentals, turfgrass, and vegetable

crops

. The g reatest use of sulfentrazone between 2004 and 2013, in terms of pounds applied, was on soybeans and sunf lowers, followed by dry beans and peas and tobacco. In terms of percent crop treated, the greatest use was on tobacco (45

- 65 percent crop treated) , followed by asparagus (15

- 30%) and dry beans and peas (15

- 25%)

.

To supplement the summary information pro vided above, EPA reviewed national usage data for sulfentrazone for individual crops to provide information for potential refinements to the preliminary risk assessment. EPA compiled summary data on average annual acres grown for major agricultural crops treated w i th sulfentrazone; average annual acres treated with sulfentrazone; the maximum single application rate (from product labels), average application rate, and the high

- end application rate (between the 80 th and 100 th percentile). The Agency also reviewed data on application timing.

In general, the Agency found that sulfentrazone is usually applied at rates below the maximum registered application rate, primarily by ground application in either the early spring (bef ore planting) or late fall (after harvest). Proprietary usage data show that a erial application of sulfentrazone is limited to a few crops: soybeans in four states, sugarcane in two states, and
sunflowers in three states

. In addition, EPA found that sulf entrazone is often used to control

2 Weed Science Society of America. 2014. Herbicide Handbook, 10 th Edition. Dale L. Shaner Ed. Herbicide
Handbook Committee.7

weeds that have become resistant to other herbicides. Please see the April 6, 2015 memo, Sulf entrazone Usage Information

, and the June 4, 2015 memo, Sulfentrazone Qualitative Benefits Assessment

, for details.



### III. SCIENTIFIC ASSESSMENTS

A. Human Health Risk Asses s ment

A summary of the Agency’s human health risk assessment is presented below. The Agency used the most updated Agency science policies and risk assessment methodologies to

prepare a qua nti tative risk assessment in support of the sulfentrazone registration review

. For a detailed discussion of the human health assessment for sulfentrazone

, see Sulfen t razone

– Preliminary Human Health Risk Asses s ment for R e gistrat i on Review and the Risk Asses sment for the Section 3 Registration Request for a New Use on Apples dated June 5, 2014, available i n the public docket EPA

- HQ

- OPP

- 2009

- 0624

, at http://www.regulations.gov/

.

1. Risk Conclusions

EPA has no dietary risks of concern for sulfentrazone from exposure to residues in either food or drinking water . The Agency has no risk concerns f or residential use of sulfentrazone on residential turf or golf courses or for use on ornamentals. Furthermore, EPA
has no ri sk concern from aggregate exposure to sulfentrazone from food, drinking water, and residential/bystander exposure.

S ulfentrazone does not appear to share a common mechanism o f toxicity with other
substances . In add i tion, sulfentrazone does not appear to produce any toxic metabolite or degradate also produced by other sub s tances. Therefore, EPA has not made a com mon mechanism of toxicity finding for sulfentrazone and any other substance. For more information on EPA’s efforts to determine which pes t icides share a common mechanism of toxicity and to evaluate cumulative effects, see http://www.epa.gov/pesticides/cumulative

.

For pesticide handlers receiving occupational exposure to sulfentrazone, EPA has no risk

concerns associated with inhalation exposure

. However, handlers who are mixing and loading liquid and dry flowable formulations of sulfentrazone have dermal exposures and risks of concern (for high acreage crops) unless chemical

- resistant glove s are worn. Most sulfentrazone labels require chemical

- resistant gloves , and EPA is proposing that the remaining labels be amended to require chemical

- resistant gloves . (See Section IVA1 of this document).

The Agency also evaluated exposure and risk t o agricultural workers who enter areas treated with sulfentrazone after application. EPA determined that postapplication exposures and risks were not of concern on the day of application. Therefore, the sulfentrazone re

- entry interval
is based on its acut e toxicity

, Category III and the restricted entry interval (REI) is 12 hours in accordance with 40 CFR 156.208c(2)(iii).8

2. Human Incidents

EPA consulted the Office of Pesticide Programs Incident Data System (IDS) for potential human poisonings related t o sulfentrazone

. Between 2002 and 2009, f our incidents were found, with generic symptoms not confirmed to be related to sulfentrazone exposure. In addition, there was no clear evidence of a trend or exposure pattern. At this time, there is no evidence

s uggesting a plausible association between exposure to sulfentrazone and a moderate or severe
health outcome. Therefore, the Agency believes that no further investigation of human incidents
is warranted

.

3. Tolerances

EPA has determined that there are no adverse human health effects from use of
sulfentrazone . T he Agency will pursue changes to the tolerances for sulfentrazone to correct the commodity definition for flax , update crop tolerances for tree nuts , and correct the tolerance
values for indirect or inadvertent residues. Specific changes are described in the June 5, 2014 document, Preliminary Human Health Risk Asse s sment for R e gistra ti on Review and the Risk Assessment for the Section 3 Registration Request for a New Use on Apples

, and in Section IVB
of this document.

Although a n adequate analytical method exists for sulfentrazone

, registrants must submit additional analytical reference standards to replenish supplies.

B. Ecological Risk Assessment

A summary of the Agency’s ecological risk assessment is presented below. EPA used the most up

- to

- date Agency science policies and risk assessment methodologies to prepare a

qua nt itative ecological risk assessment in support of the regist ration review of sulfentrazone

. When EPA published the preliminary ecological risk assessment for sulfentrazone in July 2014, the Agency received extensive comments from FMC on the assessment. These comments prompted revisions to the preliminary ecologic al risk assessment for sulfentrazone. For a detailed discussion of the ecological assessment for sulfentrazone , see the following documents,
all available in the public docket EPA

- HQ

- OPP

- 2009

- 0624, which can be accessed at http://www.regulations.gov/ :

 Preliminary Ecological Risk Assessment for the Registration Review of Sulfentrazone and Proposed New Uses on Apples , dated June 11, 2014

,

 Addendum to the Environmental Fate and Ecological Risk Assessment for Sulfentrazone Registration Review, dated June 9 , 2015, and

 R esponse to Comments on the Preliminary Ecological Risk Assessment for the Registration Review of Sulfentrazone

, dated June 9

, 2015.

EPA is currently working with its federal partners and other stakeholders to implement an interim approach for assessing potential risk to listed species and their designated critical
habitats. Once the scientific methods necessary to complete ris k assessments for listed species and their designated critical habitats are finalized, the Agency will complete its endangered9

species assessment for sulfentrazone. As such, potential risks to listed species will not be
described further in this document. The risk concerns for nonlisted species only are described
further below.

1. Risk Conclusions

In 2014, the Agency conducted a preliminary e cological risk assessment for
sulfentrazone. This conservative assessment show ed that b oth acute and chronic risk estimates
for mammals, freshwater and estuarine/marine fish, and freshwater invertebrates were below
EPA’s level of concern. 3 This assessment also show ed that acute risk estimates for birds, reptiles, amphibians, and estuarine/ma rine invertebrates w ere below the level of concern

. Therefore,
EPA does not have risk concerns for nonlisted species in these taxa for these exposure durations.

When initially scoping the registration review for sulfentrazone, EPA did not identify the

n eed for any additional studies to evaluate potential effects on pollinators. However, since the
i ssuance of the June 2014 Guidance for Assessing Pesticide Risks to Bees

, 4 EPA has begun to require these data where applicable. EPA is currently determining whether additional pollinator data are needed for active ingredients in registration review whose dockets opened prior to June 2014. For those active ingredients where EPA determines that additional pollinator exposure and effects data are necessary to help make a final registration review decision, EPA
intends to issue a DCI to obtain these data. In the near future, EPA will provide further
information and guidance on this effort. The pollinator studies that could be required are
included in Table 1 below

. The Agency will require data it believes are needed to help inform the pollinator risk assessment.

Table 1

. Potential Pollinator Data Requirements

Guideline # Study

850.3020 * † Acute Contact Toxicity with Adult Honey Bees

850.3030 * † Honey bee toxicity of residues on foliage

850.3040 ‡ Full

- Field testing for pollinators

Non

- guideline (OECD 213) *† Honey bee adult acute oral toxicity

Non

- Guideline (OECD 237) * Honey bee larvae acute oral toxicity

Non

- Guideline * Honey bee adult chronic oral toxicity

Non

- Guideline * Honey bee larvae chronic oral toxicity

Non

- Guideline ‡ Field trial of residues in pollen and nectar

Non

- Guideline (OECD 75) ‡ Semi

- field testing for pollinators (tunnel or colony feeding studies)

* Tier 1, laboratory studies.
† Acceptable data have already been submitted for sulfentrazone or are waived based on available data

. ‡ Tier 2 and 3
S emi

- field and full

- field colony level studies. The need for a higher tier test for pollinators will be determined based upon lower tiered tests and/or other lines of data and the need for a refined pollinator risk assessment.

3 For non listed species, the Level of Concern (LOC) is 1; RQs > 1 exceed the LOC.

4 http://www2.epa.gov/sites/production/files/2014

- 06/do cuments/pollinator_risk_assessment_guidance_06_19_14.pdf10

The preliminary ecological risk assessment showed potential chronic risks of concern to birds and to estuarine/marine invertebrates. In addition, the assessment showed risks of concern
for terrestrial and semi

- aquatic n ontarget plants. In these instances, EPA refined the preliminary risk assessment by re analyzing the plant toxicity data

, incorporating a new plant endpoint, and considering additional usage data for sulfentrazone . In addition , information on typical agricultural practices was considered in order to provide additional context and perspective for
these risk concerns

.

B irds

. I n the preliminary risk assessment for sulfentrazone, t he Agency estimated acute and c hronic risks to birds, expressed as risk quotients (RQs) , using a NOAEC from an avian reproductive toxicity st u dy and maximum environmental effects concentrations (EECs) of
sulfentrazone on v arious avian food items, grouped together into five generic diets. These
maximum EECs were derived from the Kenaga Nomogram. The r esulting a cute RQs ranged
from 0 to 0.02, and were below the Agency’s level of concern for all generic avian diets. However, chronic RQs ranged from 1.18 to 9, for all avian diets except for one (fruits/pods/seeds) , and exceeded the Agency’s level of concern (1.0)

.

EPA revised the avian RQs using average application rates representative of actual
sulfentrazone use

. 5 These application rates varied from 0.05 to 0.3 lb a.i./A. The resulti ng RQs ranged from 0.2 to 7.2 with all application rates exceeding the LOC for a t least one dietary item. RQs derived from mea n K enag a values ranged from <0. 1 to 2.6 with RQs exceeding the LOC for at least one dietary item for all application rates with the exception of the lowest application rate modeled (0.05 lb a

. i

. /A. )

Aquatic I nvertebrates

. In the preliminary risk assessment, EPA estimated acute and
chronic RQs for freshwater and estuarine/marine aquatic invertebrates. EPA provided bounding
estimate s of exposure and risk to invertebrates in both clear and turbid waters because photolysis contributes to the degradation of sulfentrazone in aquatic environments

. 6 Although the preliminary risk assessment indicated that the chronic RQs for estuarine/marine invertebrates
exceeded the level of concern , the RQs are based on both the wo rst

- case exposure scenario and a
chronic NOAEC of 0.003 mg a

. i

. /L derived from an acute

- to

- chronic ratio

. EPA has no chronic toxicity data for the mysid shrim p

. There is inherent uncertainty in the use of an acute

- to

chronic ratio because it represents an unbounded measure of risk. Therefore, the Agen c y has low confidence in the chronic risk estimates for mysid

.

Terrestrial and Semi

- aquatic Plants. Initial Find ings

. I n the preliminary risk assessment for sulfentrazone, t he Agency used the TerrPlant model to calculate RQs for n ontarget terrestrial and semiaquatic plant s exposed to sulfentrazone from spray drift alone and for spray drift and runoff combined, in bo th dry upland and semi

- aquatic wetland habitats. In addition, EPA examined the effect of spray drift to nontarget plants using the AgDrift model. The preliminary
risk assessment showed risk concerns for n ontarget plants from use of sulfentrazone. For gr ound applications, nontarget p lant RQs ranged from 0.17 to 10 for monocots and from 1.1 to 31.9 for
dicots. For aerial application s , RQs ranged from 1.6 to 11 for monocots and from 3.4 to 43 for

5 The application rates were taken from proprietary agricultural survey data.

6 EPA adjusted EECs for clear water and turbid water by using different rates of photolysis.11

dicots. Initial spray drift effects distances ranged from 5 6 to > 1000 feet from the edge of treated
fields.

Revised Risk Estimates

. In response to public comments submitted by FMC, EPA revisited the Tier II Vegetative Vigor data for cucumber 7 , reviewed all of the raw data, and
recalculated the IC 25 value using current statistical models. The new cucumber IC 25 value is
0.0016 lbs a

. i

. /A. Previously, EPA used an IC 25 of 0.00052 lbs a

. i

. /A from the cucumber study to calculate terrestrial plant RQs and effects distances for dicots. EPA recalculated ris k quotients (RQs) for dicots using the cucumber endpoint to determine the reasonable worst case risk to non

target broadleaf plants. Revised RQs for a range of application rates

, bracketing both labeled
rates and use rates from agricultural survey data

, r ange from 0.19 to 17.39 for both ground and aerial application of sulfentrazone

. Please see the June 9

, 2015 memo, Addendum to the Environmental Fate and Ecological Risk As sessment for Sulfentrazone Registration Review

, for
additional details.

Revised S pray Drift Analysis

. EPA ran the Ag

- Drift model using the new cucumber endpoint to calculate effects distances for sulfentrazone. The effects distance is the off

- field area of potential adverse effects to non

- target plants. Beyond this distance, there w ould be low potential to adversely affect non

- target plants. The revised Ag

- Drift runs provide the effects distances at a range of application rates, for both ground and aerial application, for different boom heights and droplet sizes. For ground applica tion of sulfentrazone, using a low boom, and fine to medium coarse droplets , the effects distance ranged from 40 to 105 feet for agricultural crops. For aerial application, using an application height 10 feet above the crop canopy, the
effects distance ra nged from 220 to 640 feet for coarse to very coarse droplets and 335 to >1000 feet for medium to coarse droplets.

2. Ecological Incidents

Between 2002 and 2005, EPA received reports of 1 9 incidents involving injury to non

target plants associated with he rbicide products containing sulfentrazone. Most of these
incidents were the result of legal registered use of herbicides containing sulfentrazone

, although some of the products contained more than one herbicide active ingredient. A total of 7,707 acres

w ere affected. According to the last search of EPA’s environmental incident database performed on June 1, 2015, n o incidents have been reported since 2005 . H owever, a lack of reports does

not necessa r i l y mean that there were no inc i dents.

3. Characterizati on of Ecological Risk

The preliminary risk assessment and risk assessment addendum f or sulfentrazone identified some RQs that exceeded EPA’s level of concern (LOC) for nonlisted species. The Agency uses the LOC as an indicator of potential adverse effects to nontarget organisms. LOC exceedances are only one line of evidence used by EPA to describe the risks posed by a pesticide

to n ontarget organisms. This risk characterization section describe s other lines of evidence for sulfentrazone, put s the LOC exceedances into a broader context , and provides additional perspective on the exceedences

.

7 The cucumber is the m ost sensitive species in the vegetative vigor study for sulfentrazone.12

Birds. For sulfentrazone, a lthough the chronic RQs for birds exceed the LOC

, EPA does

no t expect risk to birds for the following reasons. RQ exceedances were seen for birds eating a diet of arthropods or short grass, exposed to sulfentrazone at a rate of 0.3 lb a

. i

. /A, with RQs of
2.8 and 7.2 , respectively. In addition, the avian RQs are ba sed on a N OAEC from a n avian reproductive toxicity study in the bobwhite quail , which showed an 8% reduction in body weight of 14 day old hatchlings , relative to the control group. No adverse effects were seen in an avian reproductive study in the mallard duck. In addition, the chronic assessment conservatively
assumes that 100% of a bird ’s diet comes from one food source (i.e., a treated field)

. Thus, EPA
has a low level of concern and does not expect sulfentrazone to pose chronic risks to birds.

Aquatic Invertebrates. Although the preliminary risk assessment for sulfentrazone
indicated chronic RQs of concern for estuarine/marine inverteb rates, the Agency has low confidence in these RQ values. These RQs are based on both the worst

- case exposure scenario and a chronic NOAEC with high uncertainty. The mysid NOAEC of 0.003 mg a

. i

. /L was derived
from an acute

- to

- chronic ratio because EPA has n o chronic toxicity data for the mysid shrimp. Given the above uncertainty and the fact that the Agency ’s chronic risk estimates for fish (freshwater and estuarine/marine) and freshwater invertebrates do not exceed the level of

concern, EPA does not expect risks to estuarine/marine invertebrates associated with use of
sulfentrazone

.

Terrestrial Plants

. The RQs for nonta rget terrestrial plants range from 0.19 to 17.9 following exposure to sulfentrazone at both labeled rates and actual use rates. These RQs are based on the vegetative vigor endpoint for cucumber (the most sensitive species) , which is within
the same order of magnitude of the soybean endpoint

. These data indicate that sulfentrazone can harm nontarget plants exposed during the vegetative growth phase. However, the timing of sulfentrazone application may partially mitigate adverse effects to nontarget plants

. Sulfentrazone is most typically applied in early spring or late fall. In addition , available usage data show that sulfentrazone is typically applied a t rates below the maximum label led application rate, resulting in lower exposure and risk than in dicated by the RQs.

Although the modeled spray drift effects distances for sulfentrazone are as high as 105 feet from edge of field for ground application and >1000 feet for aerial application at the maximum labeled application rate, these calculated ef fects distances are proportional to the application rate . Sulfentrazone is seldom applied at the maximum label rate. The c alcul ated

e ffects distances do not consider many of the drift reduction measures on some current sulfentrazone product labels due to model limitati ons. Furthermore, aerial application of sulfentrazone is limited to three crops; of these, sulfentrazone is aerially applied to 2% of all soybeans and 5% of all sunflowers grown in the US. Application to sugarcane is limited to two
states in accordance wi th FIFRA 24(c) special local need registrations. To address concerns for
off

- target spray drift, especially from aerial application, EPA is proposing additional mitigation
measures to reduce drift. FMC, the technical registrant for sulfentrazone, has agreed to these
drift reduction measures.

See the April 4, 2015 memo, Sulfentrazone Usage Information

, and the June 9 , 2015

memo, Addendum to the Environmental Fate and Ecological Risk As sessment for Sulfentrazone Registration Review

, for details.13

C. Benefits Assessment

Sulfentrazone has been shown to provide cost

- effective weed control in several field and

row crop s including corn, dry beans and peas, soybeans, sunflowers, and tobacco. It is used in certain crops to control weeds that are resis tant to glyphosate or sulfonyl urea herbicides

, such

as Palmer amaranth and kochia. The major benefits of sulfentrazone are summarized below; additional details may be found in the June 4 , 2015 memo, Sulfentrazone Qualitative Benefits
Assessment

.

Co rn. Sulfentrazone is applied to corn at an average application rate of 0.06 lb/A to approximately 28,700 total acres annually, or less than one percent of the corn crop

. Although
sulfentrazone is only applied to a limited number of acres, EPA considered this crop in the qualitative benefits an alysis because of the overall importance of this crop in U.S. agriculture.
S ulfentrazone is recommended for the control of a number of difficult to control weeds such as common waterhemp, giant ragweed, and marestai l . Overall, sulfentrazone controls several difficult to control weeds and is slightly less expensive than several of the competing herbicides.

Dry beans/peas

. Sulfentrazone is applied at an average application rate of 0.09 lb/A to approximately 415,000 total acres annually, or 15 % of the total crop of dry beans and peas grown in the US. S ulfentrazone is used in North and South Dakota for the control of acetolactate synthase ( ALS ) 8 herbicide

- resistant kochia, an emerging problem weed, w here it provides 6 to 8
weeks of residual control

. According to 2009

- 2013 p roprietary d ata available to EPA

,
s ulfentrazone is the second most used herbicide for the control of kochia and other resistant
weeds. In dry beans/peas, sulfentrazone effectively controls ALS

- resi stant kochia and is comparable in price to available herbicides.

Soybeans

. Sulfentrazone is applied at an average application rate of 0.15 lb/A to over 3
million acres of soybeans annually, or 5 % of the soybean crop

. In soybeans, sulfentrazone is

recomm ended as part of a resistance management program for control of glyphosate

- resistant
Palmer amaranth

, which can cause extensive crop loss

. Of the herbicides used to control Palmer amaranth on soybeans, on average, sulfentrazone was the sixth most used act ive ingredient and accounted for 9% of total acre applications. Sulfentrazone is applied aerially to 2% of total soybean acres nationally

. In soybeans

, sulfentrazone effectively controls glyphosate

- resistant Palmer amaranth and is comparable in price to other available herbicides.

Sunflower. Sulfentrazone is applied at an average application rate of 0.11 lb/A to over 1.2 million acres annually, or 50 % of the sunflower crop

. In terms of percent crop treated, sulfentrazone appears to be an important chemical control in sunflower production. In sunflowers, sulfentrazone is recommended in Montana for control of ALS

- resistant kochia, a
difficult to control weed

. Across the Unit ed States, sulfentrazone is the most used active ingredient for controlling kochia on sunflower s

. Sulfentrazone is applied aerially to 5% of sunflower fields, effectively controls ALS

- resistant kochia on sunflowers, and is comparable in price to other ava ilable herbicides.

8 Herbicide group number 2, sulfonylureas.14

Tobacco

. Sulfentrazone is applied at an average application rate of 0.18 lb/A to 174,000 acres annually, or 45 % of the tobacco crop , and appears to be an important chemical control for tobacco production. For tobacco grown in North Carolina

, sulfentrazone is one of the few herbicides recommended for control of yellow nutsedge

, an aggressive and difficult to control perennial weed

. According to p roprietary d ata available to EPA , sulfentrazone is primarily used against morning glory, redroot pigweed, and nutsedge species. In tobacco

, sulfentrazone effectively controls yellow nutsedge and is comparable in price to available herbicides.

Please see the April 6, 2015 memo, Sulf entrazone Usage Information

, and the June 4,
2015 mem o, Sulfentrazone Qualitative Benefits Assessment

, for details.

D. Endangered Species Assessment

In November 2013, the EPA, along with the Services and the USDA, released a summary of their joint Interim Approaches for assessing risks to endangered and thr eatened (listed) species from pesticides. The Interim Approaches 9 were developed jointly by the agencies in response to the National Academy of Sciences’ (NAS) recommendations and reflect a common approach to risk assessment shared by the agencies as a way of addressing scientific differences between the
EPA and the Ser vices. The NAS report 10 outlines recommendations on specific scientific and technical issues related to the development of pesticide risk assessments that EPA and the Services must conduct in connection with their obligations under the ESA and FIFRA.

The joint Interim Approaches were released prior to a stakeholder workshop held on November 15, 2013. In addition, the EPA presented the joint Interim Approaches at the
December 2013 Pesticide Program Dialogue Committee (PPDC) and State

- FIFRA Issues
Research and Evaluation Group ( SFIREG) meetings

. The agencies also held stakeholder workshop s

- in April and October 2014, and in April 2015

- allowing additional opportunities for stakeholders to comment on the Interim Approaches. Additional workshops are planne d to
enhance stakeholder involvement. As part of a phased, iterative process for developing the Interim Approaches, the agencies will also consider public comments on the Interim Approaches in connection with the development of upcoming Registration Revie w decisions. The details of the joint Interim Approaches are contained in the white paper Interim Approaches for National

Level Pesticide Endangered Species Act (ESA) Assessments Based on the Recommendations of the National Academy of Sciences April 2013 Report 11 , dated November 1, 2013.

Given that the agencies are continuing to develop and work toward implementation of the Interim Approaches to assess the potential risks of pesticides to listed species and their designated critical habitat, the ecologica l risk assessment supporting this Proposed Interim
Decision for Sulfentrazone does not contain a complete ESA analysis that includes effects determinations for specific listed species or designated critical habitat. Although EPA has not

9 Interim Approaches for National

- Level Pesticide Endangered Species Act (ESA) Assessments Based on the Recommendations of the National Academy of Sciences April 2013 Report

. Available at http://www.epa.gov/espp/2013/interagency.pdf

. 10 As s essing Risks to Endangered and Threatened Species from Pesticides . National Acadamy of Sciences. 1983.
Available from http://www.nap.edu/catalog.php?record_id=18344

11 Available at http://www.epa.gov/espp/2013/nas.html15

yet completed effe cts determinations for specific species or habitats, for this preliminary
assessment EPA ’s evaluation assumed, for all taxa of non

- target wildlife and plants

, that listed species and designated critical habitats may be present in the vicinity of the applic ation of
sulfentrazone . This assessment will allow EPA to focus its future evaluations on the types of species where the potential for effects exists once the scientific methods being developed by the agencies have been fully vetted. While the agencies continue to develop a common method for
ESA analysis

, the regulatory section o f the Proposed Interim Registration Review Decision document will describe the level of ESA analysis completed for this particular registration review case. Once the agencies have fully developed and implemented the scientific
method ology for evaluating ri sks for listed species and their designated critical habitats, these methods will be applied to subsequent analyses for sulfentrazone as part of completing this registration review.

E

. Endocrine Disruptor Screening Program

As required by FIFRA and FFDCA, EPA reviews numerous studies to assess potential adverse outcomes from exposure to chemicals. Collectively, these studies include acute, subchronic and chronic toxicity, including assessments of carcinogenicity, neurotoxici ty, developmental, reproductive, and general or systemic toxicity. These studies include endpoints which may be susceptible to endocrine influence, including effects on endocrine target organ histopathology, organ weights, estrus cyclicity, sexual maturati on, fertility, pregnancy rates, reproductive loss, and sex ratios in offspring. For ecological hazard assessments, EPA evaluates acute tests and chronic studies that assess growth, developmental and reproductive effects in different taxonomic groups. As part of its most recent registration decision for sulfentrazone

, EPA reviewed these data and selected the most sensitive endpoints for relevant risk assessment scenarios from the existing hazard database. However, as required by FFDCA section 408(p),
sulf entrazone is subject to the endocrine screening part of the Endocrine Disruptor Screening Program (EDSP).

EPA has developed the EDSP to determine whether certain substances (including pesticide active and other ingredients) may have an effect in humans o r wildlife similar to an effect produced by a “naturally occurring estrogen, or other such endocrine effects as the Administrator may designate.” The EDSP employs a two

- tiered approach to making the statutorily required determinations. Tier 1 consists of a battery of 11 screening assays to identify the potential of a chemical substance to interact with the estrogen, androgen, or thyroid (E, A, or T) hormonal systems. Chemicals that go through Tier 1 screening and are found to have the potential to interac t with E, A, or T hormonal systems will proceed to the next stage of the EDSP where EPA will determine which, if any, of the Tier 2 tests are necessary based on the available data. Tier 2 testing is designed to identify any adverse endocrine

- related effect s caused by the substance, and establish a dose

- response relationship between the dose and the E, A, or T effect.

Under FFDCA section 408(p), the Agency must screen all pesticide chemicals. Between October 2009 and February 2010, EPA issued test orders/ data call

- ins for the first group of 67 chemicals, which contains 58 pesticide active ingredients and 9 inert ingredients. A second list of16

chemicals identified for EDSP screening was published on June 14, 2013 12 and includes some pesticides scheduled for Registration Review and chemicals found in water. Neither of these lists should be construed as a list of known or likely endocrine disruptors. For further information on the status of the EDSP, the policies and procedures, the lists of chemicals, future lists, the test guidelines and the Tier 1 screening battery, please visit EPA’s EDSP website. 13

In this proposed interim decision , EPA is making no human health or environmental safety findings associated with the EDSP screening of sulfentrazone . Befor e completing this Registration Review, the Agency will make an EDSP FFDCA section 408(p) determination.



### I V

. PROPOSED INTERIM REGISTRATION REVIEW DECISION

A. Risk Mitigation and Regulatory Rationale

1. Occupational Exposure

To address risk concerns associated with occupational exposure , pesticide handlers who are mixing and loading dry flowable and liquid formulations of sulfentrazone must wear
chemical

- resistant gloves. Most , but not all, sulfentrazone dry flowable and liquid product labels

curren tly require either waterproof or chemical

- resistant gloves. Therefore, certain product registrations need to be amended to require use of chemical

- resistant gloves. FMC , the lead technical registrant for sulfentrazone, has agreed to this label amendment.

The re

- entry interval (REI) for sulfentrazone is 12 hours, based on the acute toxicity of
this herbicide (Category III)

. This re

- entry interval is established in accordance with 40 CFR § 156.208c(2)(iii). This REI applies to all pesticide products containing sulfentrazone that do not also contain another pesticide active ingredient with a more restrictive (longer) REI. Therefore, certain product registrations need to be amended to require a 12

- hour REI.

2. Environmental Effects

As discussed in the E cological Risk Assessment section of this document, sulfentrazone has been determined to pose a potential risk concern for nontarget terrestrial plant s, especially dicot spec ies. In addition, there is a lack of consistency among sulfentrazone product labels regarding measures to minimize spray drift

. To address th e s e concern s , the Agency is proposing label changes for sulfentrazone products to reduce off

- target spray drift

. EPA’s intention is to
establish a bas eline level of protection against spray drift that is consistent across all sulfentrazone product s registered for use in agricultural, wide area, or rights

- of

- way settings.
T he Agency is proposing the following label restrictions for sulfentrazone :

12 See http://www.regulations.gov/#!documentDetail;D=EPA

- HQ

- OPPT

- 2009

- 0477

- 0074 for the final second list of
chemicals.

13 ht tp://www.epa.gov/endo/17

 Use of spray nozzles limit ing product droplet size during applications to medium or coarse in
accordance with the American Society of Agricultural and Biological Engineering (ASABE)
standard S

- 572 ;

 For boom spraying, the minimum release height must be 30 inches from the soil for ground applications and 1 0 feet from the top of the crop canopy for aerial applications ( unless a greater application height is required for pilot safety ) ;

 Applicators may spray only when wind speed is between 3 and 10 mph;

 A e rial application is allowed only when local environmental conditions 14 prohibit ground application;

 When aerial application is allowed, the minim u m finished spray volume is 5 gallons per acre ; and

 For ground application, the minimum finished spray volume is 1 0 gallons per acre for pre

emergence use and 15 gallons per acre for use in a tank mix with one or more contact, burn

down herbici d es

.

FMC , the lead technical registrant for sulfentrazone

, has agreed to these label amendments.

3. Herbicide Resistance

To prevent the development of resistance to sulfen t raz o ne among common weeds, the Agency is proposing that all herbicide products containing sulfentrazone (except for those registered solely for homeowner use) contain resistance

- management labeling

. These specifications follow the recommendations of the Weed Science Society of America publication, Reducing the Risks of Herbicide Resistance, Best Management Practices and
Recommendations 15

. The Agency first provided guidance on resistance management labeling in Pesticide Registration (PR) Notice 2001

- 5, Guidance for Pesticide Registrants on Resistance Management Labeling. EPA is proposing the following herbicide

- resistance labeling for

su lfentrazone :

 Mandatory listing of herbicide m echanism of action, and the Weed Science Society of America herbicide group number, at the top of the first page each product label;

 Instructions to alternate use of products containing sulfentrazone with oth er herbicides
with different m echanisms of action;

 Recommendations to scout for weeds before and after sulfentrazone application , to ensure proper identification of weeds and growth stage and to confirm product performance ; and

 Instructions to report herbi cide failure to local extensions specialists, certified crop advisors, and/or sulfentrazone registrants

.

14 Aerial application will be allowed when the field is too wet to safely apply pesticides using ground equipment.

15 Norsworthy et al. 2012. Weed Science 2012. Special Issue: 31

- 62.18

EPA believes that the inclusion of herbicide

- resistance management language on sulfentrazone labels is important to slow the development of resistance to this herbicide while maintaining flexibility for growers. Weed resistance is a complex issue and registrants play an important role in ensuring effective resistance management. Educating all stakeholders on best

prac tices for managing herbicide

- resistance is important and the product label is a critical p art of
this effort.

B. Tolerance Amendments

Although EPA has determined that there are no adverse human health effects from use of sulfentrazone, the Agency will purs ue changes to the tolerances for sulfentrazone to correct commodity definitions, update crop tolerances, and correct tolerance values for indirect or
inadvertent residues. EPA will pursue the following c hanges to the sulfentrazone tolerances
listed in 40 CFR § 180.498 :

 T he t olerance for “ Flax ” (at 0.15 ppm) will be changed to “ Flax, seed ” to correct the

comm o d i ty definition. The tolerance level remains unchanged at 0.15 ppm.

 T he t olerance for “ Nut, tree, group 14 ” will be updated to “ Nut, tree, group 1 4

- 12 .” The tolerance level remains unchanged at 0.15 ppm.

 T he t olerance for “ Pistachio ” will be revoked concomitant with the revision of the tolerance for tree nuts to include pistachio.

 T he t olerances for indirect or inadvertent residues of sulfentrazone established in 40 CFR § 180.498(d) will be corrected to three significant figures, in accordance with curr e nt policy.

EPA will conduct rulemaking to implement these t olerance change s, in accordance with FFDCA

.

C. Endangered Species

As previously mentioned, EPA is currently working with its federal partners and other stakeholders to implement an interim approach for assessing potential risk to listed species and their designated critical habitats in accordance with the ESA. When the Agencies have fully developed and implemented the scientific methodology for evaluating risks for listed species and their designated critical habitats, these methods will be applied to subsequent analyses for sulfentrazone as part of completing this regis tration review.

D. Proposed Interim Registration Review Decision

In accordance with 40 CFR Sections 155.56 and 155.58, the Agency is issuing this
P roposed I nterim R egistration R eview D ecision. Except for the EDSP and ESA components of this case, the Agency has made the following Proposed Interim Registration Review Decision: (1) no additional data are required at this time; and (2) changes to the affected registrations and their labeling are needed at this time.

In this proposed interim registration review decision, EPA is making no human health or environmental safety findings associated with the EDSP screening of sulfentrazone , nor is it19

making a complete endangered species finding. The Agency’s final registration review decision
for sulfentrazone will d epend upon both the result of an ESA Section 7 consultation with the
Services

, an EDSP FFDCA section 408(p) determination , and an assessment of non

- target exposure to bees.

E. Data Requirements

At this time, no additional data are required as part of this p roposed interim registration
review decision. EPA will request the sulfentrazone registrant to submit analytical reference standards to the EPA analytical chemistry lab in Fort Meade, MD as a separate action.



### V. NEXT STEPS AND TIMELINE

A. Interim Registration Review Decision

In accordance with 40 CFR Sections 155.56 and 155.58, the Agency is issuing this Proposed Interim Registration Review Decision, and placing it in the sulfentrazone reg istration review docket (EPA

- HQ

- OPP

- 2 009

- 0624) for public c omment for 60 days. A Federal Register
N otice will announce the availability of this P roposed I nterim R egistration R eview D ecision for
sulfentrazone and initiate a 60

- day comment period

. If there are no significant comments or additional information submitted to the docket during the comment period that leads the Agency to change its proposed decision, EPA may issue an I nterim R egistration R eview D ecision for
sulfentrazone (case 7231 ). Th e Agency’s final decision on the sulfentrazone registration review
case will depend up o n the results of the EDSP determination, an ESA consultation with the Services, and an assessment of non

- target exposure to bees.

B. Implementation of Mitigation Measures

Registrants must submit amended labels, which implement the label changes summarized in Appendix A , to EPA within 60 days of issuance of the Final Interim Registration Review
Decision for sulfentrazone.20 Appendix A : SULFENTRAZONE Label Table

Summary of Labeling Changes for Sulfentrazone
Description Amended Labeling Language for Sulfentrazone Products Placement on Label
Technical and Manufacturing Use Products
Use Limitations “Only for formulation into a/n [insert pesticide class] for the following use(s) [list only those uses and application methods that are being supported by technical and MP

registrant ].” Directions for Use

Products Labeled for Agricultural Use
HERBICIDE RESISTANCE MANAGEMENT

Herbicide M echanism
of Action “ Group 14 HERBICIDE ” Front Panel, upper right quadrant, surrounded by a black (or suitable color) rectangle

Weed Resistance Management  Instructions to alternate use of products containing
sulfentrazone with other herbicides with different
mechanisms of action;

 Recommendations to scout for weeds before
sulfentrazone application for identification and growth stage and after sulfentrazone application to look for poor performance or likely resistance;

 Instructions to report herbicide failure to local extension specialists, certified crop advisor s , and/or
sulfentrazone registrants. Directions for Use , prior to directions for spe cific crops under the heading” WEED
RESISTANCE
MANAGEMENT”

PERSONAL PROTECTIVE EQUIPMENT AND RE

- ENTRY INTERVAL

P PE Labeling Requireme nt s for all agricultural end

- use products containing
sulfentrazone “PERSONAL PROTECTIVE EQUIPMENT (PPE)

Applicators , mixers, loaders, and other pesticide handlers

must wear:

 C hemical

- resistant gloves ” Precautionary Statements section, under the heading
Hazards to Humans and
Domestic Animals “Personal Protective Equipment (PPE)” REI Requirement

 The REI for sulfentrazone products is 12 hours,
unless the acute toxicity of the product indicates the need for a longer REI. Precautionary Stat ements section, uner the heading “Re

entry Interval”

ENVIRONMENTAL HAZARDS

Environmental Hazard

 Warning that drift and runoff of sulfentrazone products may be hazardous to plants in adjacent

areas. Environmental Hazards

SPRAY DRIFT Spray Drift Language  Select nozzles and pressure that deliver medium or coarser spray droplets as indicated in nozzle manufacturer’s catalogs and in accordance with
ASABE Standard S

- 572.

 Select coarse to very coarse droplet size when
sulfentrazone is used alone and a medium to coarse droplet size when sulfentrazone is tank mixed with a
contact burndown herbicide. Directions for Use, prior to
directions for specific crops under the heading “SPRAY
DR IFT”21 Summary of Labeling Changes for Sulfentrazone
Description Amended Labeling Language for Sulfentrazone Products Placement on Label

 Applicators may spray only when wind speed is between 3 and 10 mph.

Spray D r ift Language

 Ground applicators must use a finished spray volume of 15 gallons per acre. Directions for Use, prior to
directions for specific crops under the heading “SPRAY
DRIFT” Spray Drift Lang ua ge  Aerial application is allowed only when environmental conditions prohibit ground application.

 For aerial applications, the maximum release height must be 10 feet from the top of the crop canopy, unless a greater application height is required for pilot safety.

 “When this product is allowed to be applied by air, applicator must use a minimum finished spray volume of 5 gallons per acre.” Directions for Use, prior to
directions for specific crops under the heading “SPRAY DRIFT” “Aerial Application”

DIRECTIONS FOR USE Language to restrict use to target species only “This product may only be used to control [insert pests and
sites ]...” Directions for Use

Under “Use Restrictions”

Maximum single and annual application rates “The maximum single application rate for [insert product name] is [ inser t amount of product equivalent to the maximum application rate for each crop or crop group,] the equivalent of [insert maximum application rate in units of lb

a

. i

. /A] .”

“ The maximum annual application rate for [insert product name] is [ insert amount of product equivalent to the maximum annual application rate for each crop or crop group,] the equivalent of [insert maximum application rate in units of lb a

. i

. /A] .” Directions for Use for Specific Crops

Aerial Application “Aerial applica tion is allowed only when environmental conditions prohibit ground application.” Directions for Use

Under “Use Restrictions” “Aerial Application” Aerial Application “When this product is allowed to be applied by air, applicator
must use a minimum finish ed spray volume of 5 gallons per
acre.” Directions for Use

Under “Use Restrictions” “Aerial Application” Aerial Application  The maximum release height must be 10 feet from the top of the crop canopy, unless a greater application height is required for pilot safety. Directions for Use

Under “Use Restrictions” “Aerial Application”