EPA Registration Jacket 87290‐2
1
UNITED STATES ENVIRONMENTAL PROTECTIC I AGENCY

WASHINGTON, D.C. 20460

January 29, 2010

OFFlCEOF

PREVENTION, PESTICIDES AND

TOXIC SUBSTANCES

OPP Decision Number: D-425895 'l.-

EPA File Symbol or Registration Number: 87290-Ji.

Product Name: WILLOWOOD ETHOFUMESATE TURF

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

PYXlS REGULATORY CONSULTING, INC.

WILLOWOOD, LLC

4110 1136TH STREET, NW

GIG HARBOR, WA 98332-

SUBJECT: Approval of 50% Small Business Waiver Request

DearRegistrant:

The Office of Pesticide Programs has approved yourrequest for 50% waiver ofthe

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

period for this action will begin on the date ofthis 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,

OscarMorales,

~~~~~ Director

Information Technology & ResourcesManagement Division

Office of Pesticide Programs

2
Description:~.--J.-"-"'",",--+'-'-"""-=-=Cl..- _

1. 0 Placement within tile e-Jacket/jacltet:

o Default: (chronological, top e newest)

o file location: (PDF page number.j.e, "before page

46")

2.WSend to Data IElltrlllctioU1 contractors this material:

Newly stamped accepted label

o Notification

NewCSIF

o Other: _

3. Attach this coversheetto the top of the materia! orjacket, it

must be wei! organized and clipped together, NOr STAPLED.

rhen gille the material with this coversheet to staff in the

Information Services Center (Room 8-4900).

~evnewelr's Name: ...@-r ttn!\ll\ 8dD\,Iaz--LL)

Phone: 3Lt'1-~ '60'7:;Z, Dlvislon: ~t0 )Ji6

Created August14, 2008

3
Name ofPeslicide Product:

Willowood Ethofumesate Turf

Term of'lssuance: conditional

EPA Reg. Number: Date crlssuance:

87290-2

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)

U.S. ENVIRONMENTAL PROTECTION

Name and Address ofRegistrant (include ZIP Code):

Willowood, LLC

8690 Lookingglass Road

Roseburg, OR 97471

-:.l'i?le-:-S~!le~iri-I~~§lllig;~iJ:feii~gjri-s~~SPtiC\Jf0in)ll~~A~-F?led\iIil:O~rcti()~\\'ur.t!tis_-§:g:istr_~iori-_11lUsl¥~@"ri1ittedY.i._andal:ce-pted_ ~~ _ --- _, ----.·.. ......--· --Re~istrationDWisio;{;iir-iorio-::U-s~ofthe-.label :incommerce.-:-ln 'anv'cofresnl,mdence onIhiS;:;ioduetaIv:.aVsreferJo the above'EPAr6'~istration number.

On the basis of information furnished by the registrant,the abovc named pesticide is herebyregistered/reregisteredunder the Federal Insecticide,

Fungicideand Rodenticide Acl. Registration is in no way to be construed as an endorsementor recommendationof this product by the Agency. In order

10 protecthealthand the environment,the Administrator,on his motion, mayat any timesuspend or cancel the registrationof a pesticide in accordance

with the Act. The acceptanceof any name inconnectionwith the registrationof a product under this Act is netto be construed as giving the registranta

right to exclusive use of the name or to its use if it has been covered by others,

The 'Basic Formulation' dated 110512010 is acceptable.

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

1. Submit and/or cite all data required for registration review/reregistration ofyour product when the

Agency requires all registrants ofsimilar products to submit data.

2. Submit the data listed below:

a. Within one year ofthe 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. 87209-2"

b. For the statement, "Selective Herbicide For Use By Professional Applicators On Ornamental

Turf Only" add the word, "Intended" after "Selective Herbicide" so that the statement reads:

"Selective Herbicide Intended For Use By Professional Applicators On Ornamental Turf

Only."

Continued on Page 2

Signatureof ApprovingOfficial: , /

Kathryn V, Montag

Project Manager 2?1J! , e J4-!ij/J, t- 'tf![H.i-I/J;) V

I/

' /')flt/y{'I 1,.~.,_., /J;

Herbicide Branch,' _ ! I

Registration Di-Jision (7505P)

Date:

EPAFonn 8570-6

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Page 2

EPA Reg. No. 87290-2

Notice ofRegistration

c. Per the Ethofumesate RED, make the following revisions to the PPE section:

1. Add "All Mixers, Loaders" before "Applicators and other handlers must wear:"

2. Revise "waterproof gloves" with "Chemical-resistant gloves (such as natural rubber),'

d. Per the Ethofumesate RED, add the following Engineering Control Statements:

1. "Engineering Controls for: Enclosed Cabs for Aerial Applicators: Pilots must use an enclosed

cockpit that meets the requirements listed in the Worker Protection Standard (WPS) for

agricultural pesticides [40 CFR 170.240(d)(6)]."

2. "On-Site Closed Mixing and Loading System Engineering Controls for Liquid Formulations:

Mixers and loaders must use a closed system that meets the requirements listed in the

Worker Protection Standard (WPS) for agricultural pesticides [40 CFR 170.240(d)(4)] for

Dermal protection, and must:

-wear the personal protective equipment required in the PPE section ofthis labeling for

mixers and loaders as well as a chemical-resistant apron

-wear protective eyewear, ifthe system operates under pressure, and

-be provided chemical-resistant footwear that is immediately available in an emergency,

such as a broken package, spill or equipment breakdown."

e. Per the Ethofumesate RED, revise the Environmental Hazards statement to read as follows:

"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 runoffmay be

hazardous to aquatic organisms in water adjacent to treated areas. Do not contaminate water

when disposing of equipment wash waters or rinsate."

f. Per the Ethofumesate RED, revise the Agricultural Use Requirements box with the following:

1. Remove the period after"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 a WPS Double Notification statement "Notify workers ofthe application by warning

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

g. Per the Ethofumesate RED, revise the Non-Agricultural Use Requirements box with the following

1. Replace "Keep unprotected persons out ofthe treated area until sprays have dried." with

"Do not enter or allow others to enter until sprays have dried."

2. Add "Professional pesticide applicators applying to residential turf, including home lawns,

parks, and recreation areas must inform their customers that all persons and pets must be kept

offthe treated turf until sprays have dried."

h. Revise the last sentence ofthe first paragraph under 'PRODUCT INFORMATION' so that it

reads: "Willowood Ethofumesate Turfis intended for professional use only."

Continued on Page 3

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Page 3

EPA Reg. No. 87290-2

Notice ofRegistration

l. Per the Ethofumesate RED, the following Spray Drift Management text must be added to the

Directions for Use section:

"SPRAY DRlFT MANAGEMENT

This chemical can contaminate surface water through spray drift. A variety offactors

including weather conditions (e.g., wind direction, wind speed, temperature, relative

humidity) and method of applicationc (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 at wind speeds greater than 15 mph.

Temperature Inversions: Do not make applications into areas oftemperature inversion of stable

atmospheric conditions."

j. Revise the heading, "USE PRECAUTIONS" to "USE PRECAUTIONS and RESTRICTIONS"

k. Per the Ethofumesate RED, add the following restrictions to the "USE PRECAUTIONS and

RESTRICTIONS" section:

1. "Do not apply more than 1.5 lbs ai (48 oz product/A or l.l oz product! 1,000 Sq. ft) per year"

2. "Do not harvest treated sod for 16 days following application."

1. Revise all instances of "recommended rates" to "specified rates" or "listed rates"

(e.g., sixth bullet on pg. 4; title oftable on pg. 5; paragraph under table on pg. 9

In addition, revise the last statement on pg. 4 to read " ... SPECIFIC DIRECTIONS ... " and not

" ... SPECIFIC RECOMMENDATIONS ... "

m. Revise the Rates and Timings table on page 5 to comply with the maximum use rate of 48 oz.

(1.5 lbs product) per acre per year.

1. Ryegrass, St. Augustine grass, and Overseeded (ryegrass) Bermuda grass: Dormant Bermuda

grass use rates must be revised to not exceed 48 oz. ofproduct! Acre or 1.1 oz of product!

1,000 Sq. ft.

2. The "# ofApps" column must be revised so that the single and yearly max. application rate of

48 oz/ Acre is not exceeded. (either a split application of24 oz.lA once in the spring and

once in the fall OR a single application of48 oz/A in either the spring or the fall).

3. The "Application Interval (Days)" column must be revised so that only the turf types that

have instructions for a split application of24 oz/A once in the spring and once in the fall

include an application interval period. (does not apply for those that have only a single

application of48 oz.lA).

n. Revise the first bullet ofthe 'Perennial Ryegrass' section to read as follows:

"For best results, apply Willowood Ethofumesate Turf at 24 oz/A (0.5 oz/IOOO Sq. ft.) once in the

fall and once in the spring."

o. Revise the fifth bullet ofthe 'St. Augustinegrass (Established Turf)' section to read as follows:

"For best results, make two applications ofWillowood Ethofumesate Turf at 24 oz/A (0.5

oz/lOOO Sq. ft.) with the second application being made 21w28 days after the first application."

In addition, delete the sixth bullet, "A third application... " as this would exceed the yearly max.

use rate of48 oz/A.

Continued on Page 4

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Page 4

EPA Reg. No. 87290-2

Notice ofRegistration

p. Revise the first bullet ofthe 'Overseeded Dormant Bermudagrass' section to read as follows:

"Do not make more than two applications at 24 ozJA (0.5 ozJlOOO Sq. ft.) OR one application at

48 ozJA (1.0 ozJlOOO Sq. ft.) ofWillowood Ethofumesate Turfwhen treating nondonnant

bermudagrass. Treatment to turfthat is not fully domant may cause early injury and/or delayed

spring green-up."

q. Delete the fifth bulleted statement ofthe 'Overseeded Dormant Bermudagrass' section, as this

exceeds the yearly maximum use rate of48 ozJA.

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

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

with FIFRA sec. 6(e). Your release for shipment ofthe product constitutes acceptance ofthese

conditions. A stamped copy ofthe label is enclosed for your records.

Enclosure

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Willowood Ethofumesate Turf

NOT FOR USE ON COMMERCIAL SOD FARMS IN ARIZONA

SUSPENSION CONCENTRATE HERBiCiDE

Selective Herbicide For Use By Professional Applicators On Ornamental Turf Only

ACTIVE INGREDIENT: % by Weight

Ethofumesate (2-ethoxy~2t 3-dihydro-3, 3~dimethyl-5~benzofuranyl methanesulfonate). . ,., 42.0%

OTHER INGREDIENTS: . ,,, " 58.0%

TOTAL: " " H " 100.0%

This product contains 4.0 Ibs. active ingredient per gallon.

KEEP OUT OF REACH OF CHILDREN

CAUTION PRECAUCION

Si usted no entiende la etiqueta, busque a alguien para que S8 la exptlque a usted en detalle.

(If you do not understand this label, find someone to explain it to you In detail)

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 cive anvthfno bv mouth to an unconscious oerson.

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 ooison 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:

Wlilowood, LLC

8690 Lookingglass Road

Roseburg, OR 97471

ACCEPTED

",iln COMMENTS

I. EPALetter Dated:

Under the Federal Jn~-, ,'ficicle,

Fungicide, end RodenucideAct

!ISamended, for the pesticide

registered under EPA Reg. No.

~1-~cIO- a

Net Contents:

EPA Est. No.

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" , , ,

"

, , " , , , ,

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1

8
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 of the 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.

Applicators and other handlers must wear:

• Long-sleeved shirt and long pants

• Waterproof gloves

• Shoes plus socks

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)J, the

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

USER SAFETY REQUIREMENTS

Users should:

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

• Remove clothing 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

Do not apply directly to water, or to areas where surface water is present, or to intertidal areas below the

mean high water mark. Do not apply when wind conditions may cause spray drift from the application

site. Do not contaminate water when disposing of equipment washwaters.

DIRECTIONS FOR USE

It is a violation of Federal law to use this product in a manner inconsistent with its labeling. Do not graze

livestock on treated turf. Do not feed treated grass clippings to livestock, Read entire Use Precautions,

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 in your State responsible for pesticide regulation.

SHAKE CONTAINER WELL BEFORE USING.

AGRICULTURAL USE REQUIREMENTS

Use this product only in accordance with its labellng and with the Worker Protection Standard, 40 CFR

Part 170, Thls 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,

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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

NON-AGRICULTURAL USE REQUIREMENTS

The requirements in this box apply to uses of this product that are not within the scope of the Worker

Protection Standard for agricultural pesticides (40 CFR Part 170). The WPS applies when this product is

used to produce agricultural plants on farms, forests, nurseries, or greenhouses.

Keep unprotected persons out of treated area until sprays have dried.

PRODUCT INFORMAnON

Willowood Ethofumesate Turf is a herbicide intended for use on ornamental turf such as golf courses, sod

farms, parks, cemeteries and homeowner or commercial lawns, and after overseeding specific grasses. It

may be used on established perennial ryeqrass, Kentucky bluegrass, creeping bentgrass, turf-type tall

fescue, St. Auqustlneprass, and dormant bermudagrass for the control and/or suppression of the annual

grasses and broad leaf weeds listed in the tables below. Willowood Ethofumesate Turf is for professional

use only.

Willowood Ethofumesate Turf has both preemergent and early (two-leaf stage) postemergence activity

and works best in programs emphasizing both approaches. WiUowood Ethofumesate Turf application is

most effective on healthy, vigorously growing turf.

WEED SPECIES CONTROLLED

PREEMERGENCE

Annual Grasses

Barnyardgrass (Echinochloa crus-galli)

Bluegrass, annual (Poa annua)

Canarygrass (Phalaris canariensis)

Crabgrass, large (Dlgitaria sanguinalis)

Crabgrass, smooth (Digitaria ischaemum)

Foxtail, green (Setaria viridis)

Foxtail, yellow (Setaria glauca)

Annual Broadleaves

Burclover (Medicago sp.)

Chickweed, common (Ste/laria media)

Purslane, common (Portulaca o/eracea)

Pigweed, redroot (Amaranthus retroflexus)

Willowood Ethofumesate Turf will also reduce competition from:

Nutsedge, purple (Cyperus rotundus)

Nutsedge, yellow (Cyperus esculentus)

POSTEMERGENCE

Annual Grasses

Bluegrass, annual (Poa annua)

Annual Broadleaves

Chickweed, common (Sfe!laria media)

Clover, white (Trifolium repens)

PREEMERGENCE/EARLY POSTEMERGENCE

Annual Grasses

Crabgrass, large (Digitaria sanguinalis)

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Crabgrass, smooth (Digifarla ischaemum)

USE PRECAUTIONS

• Willowood Ethofumesate Turf is not intended for use by homeowners and should be applied to

homeowner lawns by licensed or certified applicators,

• DO NOT OVER APPLY Willowood Ethofumesate Turf. Follow the instructions in this label or

damage to non-target turf may result.

• Spray overlap can cause turf injury due to over application. Use of a spray colorant or indicator is

recommended so that spray overlap can be avoided.

• Do not apply with hand-held or flood jet nozzles because treatments may not be uniform.

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

• When using Wll1owood Ethofumesate Turf, overseed to prevent stand thinning as a result of loss

of annual bluegrass. Use the rate of WiI1owood Ethofumesate Turf recommended for the

overseeded species when overseeding. In mixed stands of established turfgrasses, use the rate

recommended for the feast tolerant species.

• Delay application of Wlllowood Ethofumesate Turf at least 8 weeks after application of a Plant

Growth Regulator although an Wlllowood Ethofumesate Turf program may be initiated on

creeping bentgrass 3 weeks after a single application of PRIMO* has been applied.

• Do not apply Willowood Ethofumesate Turf to putting greens.

• Do not apply Willowood Ethofumesate Turf to zoyslaqrass and hard or fine fescue to avoid

serious injury.

Spray Equipment, Application, and Precautions

Use standard, low-pressure (20 to 50 psi) spray equipment to apply Willowood Ethofumesate Turf.

Calibrate spray equipment prior to use and frequently check the equipment during application. Use a

spray indicator to aid in even application. Prior to and after applying WiI1owood Ethofumesate Turf,

thoroughly clean and rinse the spray tank and line.

Varietal Tolerance

Ethofumesate (the active ingredient in Willowood Ethofumesate TUrf) has been used on the following

turfgrass cultivars. However, Willowood Ethofumesate Turf can be used on other cultivars. Prior to largescale use of Wlllowood Ethofumesate Turf on cultlvars other than those listed below, test a small area for

tolerance.

• CREEPING BENTGRASS~ The following cultivars have shown good to excellent tolerance to

Willowood Ethofumesate Turf: Carmen, Cobra, Highland, Lopez, Mariner, National, Penncross,

Providence, Putter, Southshore, SR1020, and Viper.

Injury has been occasionally noted on Emerald, Penneagle, and Pennilinks cultivars.

Willowood Ethofumesate Turf may cause serious injury to Cohansey, Colonial, south German

vanenes. Egmont, Bardot, Tracenta, Allure, Astoria, and SR7100.

• DORMANT BERMUDAGRASS- Tifgreen, Tldwarf and Common bermudagrass are more

susceptible to Wlllowood Ethotumesate Turf than hybrid bermudaqrass.

• KENTUCKY BLUEGRASS- Adelphi, American, Aspen, Asset, Challanger, Classic, Emundi,

Huntsville, Georgetown, Glade, Haga, June, Liberty, Merit, Midnight, Monopoly, Mystic, Parade,

Rugby, Sydsport, Touchdown. NOTE: DO NOT APPLY to Explorer, Limousine, Northstar, RAN I

and Total Eclipse.

• PERENNIAL RYEGRASS~ Acclaim, Blazer, Dasker, Derby, Elka, Fiesta, Goalie, Hunter, Linn,

Loretta, Manhattan 11, Palmer, Pennfine, Regal, Yorktown.

• ST. AUGUSTINEGRASS- Raleigh

• TURF-TYPE FALL FESCUE- America, Arid, Mustang

Recommendations

• For fall control of annual bluegrass, begin applications of Willowood Ethofumesate Turf during the

period of maximum weed germination and end as close to the first killing freeze as possible.

• Spring appllcatlons should be made during the period of maximum weed germination. Consult

your weed science specialist or university extension service for the recommended application

timing in your area. Spring applications are most effective following fall applications.

SEE CHART BELOW FOR USE RATES AND TIMINGS AND READ TEXT BELOW FOR SPECIFIC

RECOMMENDATIONS FOR EACH TYPE OF GRASS.

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Recommended Rates and Timin s

Use Rate Overseeding Application

Primary Application #of Application Safety Interval3 Safety

Turf Type Targets Timing OZ.lAcre OzJ1,OOO Apps Interval (Weeks After Interval4

Sq. Ft. (Days) (Weeks After Treatment) Emeruence)

Creeping Annual Fall 24 9/16 2-3 2 t-28 4 4 Bentcrass Blueorass Sorina2 24 9/16 1-2 21-28

Kentucky Annual Fall 24 9/16 2-3 21-28 6 8 Bluearass Bluearass

Ryegrass Annual FaU 32-64 314-1 1/2 2-3 21-28 1-2 1-2 Bluearass serine 1-2 21-28

SI. Bermudagrass 1 1/8- Augustinegrass Spring 48-64 2-3 21-28 NfA NlA

(Est.Turf) Suppression 2 114

Tun-Type Tall Annual Fall 24-48 3/4-11/2 2-3 21-28 0 2-3 Fescue Bluearass

Overseeded

(ryegrass) Annual 9/16 - Bennudagrass: Bluegrass Fall 24-64 1 1/2 2-3 21-28 NfA NfA

Dormant

aermuoacrass

'Nondormant Annual Fall 32-36 3/4-7/8 2 21-28 NfA NfA Bermudaoraes alueorass

NlA= Not applicable.

1Apply Willowood Ethofumesate Tun in 20 to 60 gal10ns of water per acre or 1to 3 gallons of water per 1000 sq. ft.

20 nly make spring applications after previousfall treatments.

3After the last treatment ofWiliowood Ethofumesate Tun, the Intervalprovided appliesto overseeding of the specificgrasson sametype of

~ss to whichWillowood EthofumesateTun was applied.

'illowood Ethofumesate Tun may be appliedto specificcrass fotlowino seed erneroence after the recommended timeinterval.

INSTRUCTIONS FOR SPECIFIC GRASS TYPES

COOL SEASON TURFGRASSES

Creeping Bentgrass

Apply Willowood Ethofumesate Turf to bentgrass as long as the turf is at a length typicatly found on

fairways (or longer). When applying to bent-grass, use the following guidelines.

• Avoid using Wi!!owood Ethofumesate Turf in areas that are heavily shaded and/or poorly drained.

• Creeping bentgrass tolerance to WiI!owood Ethofumesate Turf may be improved by tank mixing

Wi!!owood Ethofumesate Turf with nitrogen fertilizer (controlled release or soluble) at a rate of 0.1

to 0.25 lb N per 10,000 ff This may also improve creeping bentgrass conversion in the areas

treated.

• Control of annual bluegrass is best achieved by making two applications of Willowood

Ethofumesate TUrf; one in the fall followed by one in the spring.

• WfUowood Ethofumesate Turf works best in the spring if applied after creeping bentqrass has

resumed active growth and '15 fUfly green.

When overseeding with creeping bentgrass, use the foflowing gUidelines;

• After applying Willowood Ethofumesate Turf, wait a minimum of 3-4 weeks before overseeding

with bentgrass.

• When an area has been renovated or overseeded with bentqrass. do not apply Willowood

Ethofumesate Turf until 3-4 weeks after seedling emergence,

Kentucky Bluegrass

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• Delay application of WiUowood Ethofumesate Turf to bluegrass until at least 8 weeks after

emergence.

• Bluegrass overseeded with ryegrass may be treated with Willowood Ethofumesate Turf 1-2

weeks after ryegrass emergence.

When overseeding with Kentucky Bluegrass use the following guidelines:

• Wait at least six weeks after the last Willowood Ethofumesate Turf application before reseeding

with Kentucky bluegrass.

• Note that sod quality during the spring may be diminished following the fall applications of

Willowood Ethofumesate TUrf. Alternatives to fall application of Willowood Ethofumesate Turf

include seeding with dormant bluegrass in the late faU or to delay reseeding until the spring.

Perennial Ryegrass

Control of annual bluegrass in perennial ryegrass is easiest when it is newly emerged, and application of

Willowood Ethofumesate Turf is made during the primary period of annual bluegrass germination (and up

to 30 days after annual bluegrass emergence) in the fall and/or spring. Consult your local Extension

Service or university weed specialist for the date(s) that annual bluegrass germinates in your area.

• For best results, apply Willowood Ethofumesate Turf in both the fall and spring.

• Application in the fall or spring will also reduce competition from selected broadleaf weeds and

crabgrass.

When overseeding with perennial ryegrass, use the foJJowing guidelines:

• Walt 1-2 weeks (or until the seedlings are approximately 1" tall) before applying Willowood

Ethofumesate Turf to the seeded area.

• To the extent possible, thatch should be removed from the area being seeded as it can diminish

the effectiveness of the Willowood Ethofumesate Turf treatment.

• Do not apply mulch or straw to the seeded areas until after Willowood Ethofumesate Turf has

been applied.

Turf-Type Tall Fescue

Make Willowood Ethofumesate Turf applications to turf-type tall fescue in the fall. If overseeding with turftype tall fescue, application of Willowood Ethofumesate Turf may be done at the same time as seeding.

WARM SEASON TURFGRASSES

St. Augustinegrass (Established Turf)

WiUowood Ethofumesate Turf suppresses the development of actively growing Bermudagrass in

established St. Augustine sod. Apply Willowood Ethofumesate Turf to 81. Augustinegrass in the spring

and early summer to suppress Bermudagrass and Bermudagrass seedhead formation and/or for control

of annual bluegrass.

Notes regarding applications to St. Augustinegrass:

• Do not treat 81. Augustinegrass in the first six months after germination.

• Do not treat 81. Augustinegrass that is under stress or injury to the turf may result.

• Temporary stunting and minor discoloration of 81. Augustinegrass may occur after application. If

the St. Augustinegrass shows signs of severe yeJJowing or stunting, discontinue applications.

Use the following guidelines when applying Willowood Ethofumesate Turf to St. Augustinegrass:

• Begin Willowood Ethofumesate Turf applications when Bermudagrass first breaks dormancy in

the spring. Application timing is critical to achieve optimum results and will vary depending on

location and temperature.

• For best results, make multiple applications of Willowood Ethofumesate Turf with the second

application being made 21-28 days after the first application.

• A third application made 21-28 days after the second application may be necessary for maximum

suppression of bermudagrass or annual bluegrass.

• To improve suppression, each application of WiJlowood Ethofumesate Turf may be tank-mixed

with (Atrizine at up to 2 lb ailA for first application and 0.75 Ib-1 lb ailA triazine for second or third

application).

Overseeded Dormant Bermudagrass

6

13
Notes regarding applications to Bermudagrass:

• Do not make more than two applications of Willowood Ethofumesate Turf when treating

nondormant bermudagrass. Treatment to turf that is not fully dormant may cause early injury

and/or delayed spring green-up.

• Application of Willowood Ethofurnesate Turf to bermudagrass that is stressed due to shade,

poorly drained soils, and high traffic may result in increased turf injury. Avoid use of Willowood

Ethofumesate Turf or use lower rates under these conditions.

Use the following guidelines when applying Willowood Ethofumesate Turf to Bermudagrass:

• To control annual bluegrass, make applications of Willowood Ethofumesate Turf in late fall

(ideally 1M2 weeks after emergence of overseeded perennial ryegrass) on overseeded

bermudaqrass.

• When Willowood Ethofumesate Turf is applied ln late November or early December, applications

of 32M36 oz. per acre have shown acceptable control of annual bluegrass with minimum injury to

nondormant (or predormant) bermudaqrass. If lower rated are used, reduced annual bluegrass

control should be expected. If higher rates are used, increased injury to Berrrnrdaqrass may

occur.

• One or two supplemental applications made through the winter (at 21-28 day intervals) may

assist in controlling annual bluegrass,

• Willowood Ethofumesate Turf should not be applied to Bermudagrass in the 4 weeks prior to

breaking winter dormancy. Applications made to Bermudagrass in the 4 weeks prior to breaking

dormancy may temporarily delay the normal start of active growth.

When overseeding bermudagrass, use the following quidelines:

• corrsnon bermudagrass in fairways or roughs may be more susceptible to herbicide injury than

hybrid bermudagrass.

• When making applications to nondormant bermudagrass, Willowood Ethofumesate Turf should

be kept within areas that are overseeded so that the ryegrass will mask any early injury or late

transition in the spring that my occur.

• Using a higher than normal seeding rate may be desirable in order to minimize the appearance of

thin turf.

Willowood Ethofumesate Turf Mixtures with Fertilizers

Wi!lowood Ethofumesate Turf Impregnation on Dry Bulk Fertlllzers

Willowood Ethofumesate Turf may be impregnated on many dry bulk fertilizers (See "1" below) and

applied for the control of labeled grasses and broadleaf weeds. All Willowood Ethofumesate Turf label

and supplementary literature instructions and precautions regarding rates per acre, soil type, 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 Turf fertilizer mixtures. A minimum of 200 pounds and a maximum of

700 pounds of approved fertilizer ingredients impregnated with the appropriate amount of WHlowood

Ethofumesate Turf 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 Turf 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 Turf provides a

satisfactory dry mixture. If the absorptivity is not adequate, use of a highly absorptive powder is required

to provide a dry, free-ftowlnq 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 Microce! E is required.

The amount of wmowcoo Ethofumesate Turf 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 WHlowood Ethofumesate Turf actually contained in the fertilizer mixture applied to the soil

represents the correct dosage rate.

7

14
Bulk fertilizers impregnated with Willowood Ethofumesate Turf should be applied immediately, NOT

STORED.

1. Approved dry fertilizer ingredients for use with WilJowood Ethofumesate Turf.

Willowood Ethofumesate Turf Impregnation on Dry Bulk Fertilizers

N P K

Ammonium nitrate 34 0 0

Ammonium sulfate 21 0 0

Ammonium phosphate- 16 20 0 sulfate

Diammonium 18 46 0 I ohosohate

Monoammonium 11 56 0 I chosohate

Potassium chloride 0 0 60

Potassium sulfate 0 0 52

Single su erohosphate 0 20 0

Tr! Ie su erohos hate 0 46 0

Urea 45 0 0

Willowood Ethofumesate Turf Phvsloal Data

Densit 1.15 q/cm"

Pounds! allon 9.60

Flashooint Non-combustible

Wlliowood Ethofumesate Turf with Liquid Fertilizer

The following procedure is suggested for evaluation of physical compatibility of WilJowood Ethofumesate

Turf in mixtures with liquid fertilizers for spray tank applications.

Material Required

1. Willowood Ethofurnesate Turf- components of tank sizes 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, Kala Baloratorles, Inc., Kansas City, MO

**E·Z Mix, United Aqri-Products, Greeley, CO

Procedure

1. Pour one plnt (473 ml) of the llquid fertlllzer into each of the quart containers.

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

3. Add the Willowood Ethofumesate Turf 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 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 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 the adequate agitation is maintained in the spray tank. If a

Willowood Ethofumesate Turf plus fertilizer mixture utilizing an adjuvant is satisfactory, but the one

8

15
without adjuvant is not, be sure to use the adjuvant in the spray tank at the rate recommended on the

label which was used in the 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 Turf Mixtures with Liquid Fertilizers

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

Willowood Ethofumesate Turf added proportionately to correspond with intended field use rate

recommended on Willowood Ethofumesate Turf label. Add the proportionate amount of tank mix

component.

Gal. of Liquid Fertilizer to be ml or tsp of Willowood Ethofurnesate Turf to be added to 1 pint

applied per acre of fertilizer

oal ml tSD.

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 •

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 S 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 buming. 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

9

16
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.

Wiflowood, 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,

WILLOWOOO, LLC MAKES NO WARRANTIES OF MERCHANTABILITY OR OF FITNESS FOR A

PARTICULAR PURPOSE NOR ANY OTHER EXPRESS OR IMPLlEO 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, 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 Seifer 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]

10

17
NOTE FOR RECORD

EPA Reg. No.! File Symbol: 87290-E

Product Name: Willowood Ethofumesate Turf

Application Dated: January 5, 2010

Due Date: lIliiilllllllQlllllli

Action Description: New End Use Product (Ethofumesate) for residential turf and sod farms

Comments:

PRODUCT CHEMISTRY:

-Basic CSF dated 115/2010 is found acceptable

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

own submitted studies (MRIDs 47864101-02). (also used for Ethofurnesate SC)

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

ACUTE TOXICITY REVIEW:

-Registrant in using the CITE ALL option for acute tax.

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

CAUTION labeling

DATA COMPENSATION:

-Cite all under the selective method for the generic studies supporting Ethofumesate

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

CSF to cover generic data compensation requirements.

-Certiflcation with Respect to Citation ofData: Selective Method with Offer to Pay

Ethofumesate data submitters

LABEL REVIEW:

Many revisions required in order to comply with Ethofumesate RED

-revise PPE, add Engineering Control Statements, revise Environmental Hazards

Statements, add and revise Ag and Non-Ag Use Requirements box statements, add Spray

Drift Mng., Revise Application rate and add PHI restrictions for sod harvest.

Note: the Ethofumesate RED includes the following statement in the label tablet'For sale

and use by professional applicators only. Not for sale or use by homeowners/consumers."

As this text is unenforceable (not RU product), I spoke with Dan Kenny and he suggested

that the labeling read something like "intended for professional use." (see comments "b"

and "h" in the registration letter.

DATA GAPS:

Storage Stability (830.6317)

Corrosion Characteristics (830.6320)

18

*Commercial/financial information may be entitled to confidential treatment*
21-Day Screen Completed by

Contractor

21-Day Expires on __!-Z'I-/() -:;;....c,--,-=-_

Jacket # ~71 'TCl- £

MRID# L!714~(

Content Scre~\Recommended to

~/Fail

86-5 Review: asse /Failed/NA

Transfer This Jacket to:

19
Fee Paid: Yes~ 21 Day Screen Start Date: -'--''::---';-''''- _

Experts In-Processing Signature:

D' . . rvision management co t cted na 0 ssu s

EPA Reg. Number: '(,71'10 - E EPA Receipt Date: 1- - 10

Items for Review Yes No N/A'

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

including package type k

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

dated (EPA Form 8570-4) (Link to form) X

2 a) All inerts (link to http://www.epa.gov/opprdOOllinertsl), yes no

including fragrances, approved for the proposed uses (see

Footnote A) X

3

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

X- 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 yes no

to pay statement included. (see Footnote B) \<

If applicable, is there a letter ofAuthorization for exclusive use only.

Formulator's Exemption Statement (EPA Form 8570~27) (Link to form)

4

technical)

completed and signed (N/A ifsource is unregistered or applicant owns the K

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

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

repack)

5 yes no 1:[';:(' C· "

a) Selective Method (Fee category experts use) X

b) Cite-All (Fee category experts use) 1\/ "

I,;;'i '

c) Applicant owns all data (Fee category experts use) ".}i:!' .

, ,

5 Copies ofLabel Oink to http;//www.epa.gov/oppfeadlilabelingllrm£)

6

htlp;//www.epa.gov/pesticides/regulating/registerjng/submissjons/index.htm#labels

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

)

I

20
7 Is the data package consistent with PR Notice 86~5 (link to PRN 86-5) X

Notice of Filing (link to

8 http://www.epa.gov/pesticides/regulatingltolerance petitions.htm) included

with petitions (link to X http://www.epa.~ov/pesticides/re~ulating/tolerances.htm)

9 If applicable for conventional applications, reduced risk rationale Oink to

http:II"'ww.ep a.govlopprd00Lworkplan/reducedrlsk.html) -;x

Required Data (link to

http://Tttt'\'w.epa.govfpesticides/regulatingidata requirements.htm) and/or

data waivers. See Footnote C.

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

10

2

21
Comments:

8 x:

* N/A - Not Applicable

Footnotes

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

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

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

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

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

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

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

eSF and may require submission of data. All infonnatioll_ forms, data and

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

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

application as described below.

To successfully complete this aspect ofthe 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

22
site [link to http://www.epa.gov/opprdOOI/inertsilists.html) and Ifthe 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 ofuses. 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 (IIAB) at inertsbranch@epa.govandresolve the issue. Copies ofthe

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

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

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

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

Microbial Pesticides Branch [Link to

http://www.epa.gov/oppbppdl/biopesticides/contactsbppd.htm].

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

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

information [link to http://www.epa.gov/opprdOOI/inerts/tins.pdf] must also be included

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

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

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. Ifthe inert ingredients in a proprietary blend (including fragrances)

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

Agency will reject the application.

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

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

Unapproved Inerts Identified on CSFs

All applications except conventional new products and PIPs

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

applicant with the following options:

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

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

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

approved for the application's uses; or

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

unapproved inert. Ifthis 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

23
3. Withdraw the application (the Agency retains 25% ot the full fee for the fee

category estimated); or

Ifnone ofthese options is selected and implemented by the applicant within the

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

25% ofthe full fee ofthe 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 (R3l1, R312 or R313), it will contact the applicant with the

following-options:

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

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

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

approved for the application's uses; or

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

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

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

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

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

Agency within the 21 day content review period.)

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

category estimated); or

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

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

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

PIP Applications

"When the Biopesticide and Pollution Prevention Division identifies an

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

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

options:

1. Correct the application by, for instance, correcting the spelling or name ofthe

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. Ifthis option is selected and implemented, the

Agency will discuss harmonizing the timefrarne for both actions.

5

24
3. Withdraw the application (the Agency retains 25% ofthe full fee for the fee

category estimated); or

If none ofthe 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 R301 or

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

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

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

prior to submitting their application to the Agency. Documentation ofsuch discussions

should be submitted with the study waiver.

6

25
IFee for Servicel

)i

(8652870-

This package includes the foHowing for Division

(!J New Registration

°Amendment

I

I

I St~dies? 0 Fee Waiver? I

I 0 volpay % Reduction: __

°AD

°BPPD

(!J RD

Risk Mgr.

865287

87290-E

1/8/2010

Receipt No. S-!=====

EPA File Symbol/Reg. No. 1==============

Pin-Punch Date: 1 _

D This item is NOT subject to FFS action.

1--~:!illJ~~~=~- I Parent/Child Decisions: I

Requested: I R3iJ'V I

Granted: I R'3 ()V [

Amount Due: $ I 3Sb

Uncleared Inert in Product

Date: /-lll- /D

;;;-&iJiYl[ ell. 0cb iiluffd If}.-b

o Inert Cleared for Intended Use

Reviewer: . ,

&K.Ji\f''-~

Remarks: Ctc$/;v2JYvr! 01.9~

'6'1JJ..q{J - K I

26
FEE FOR SERVICE

27
P1AIS REGULATORY CONSULTIi, J, INC.

4110 136th sr. NW

Gig Harbor, WA 98332

Phone: 253-853-7369

Fax: 253-853-5516

www.PyxisRC.com

CONTAINS CONFIDENTIAL BUSINESS INFORMATION

January 5, 2010

COURIER DELIVERY

Kathryn Montague (PM 23)

Document Processing Desk (REGFEE)

Office of Pesticide Programs (7504P)

U.S. Environmental Protection Agency

Room 8-4900, One Potomac Yard

2777 S. Crystal Drive

Arlington, VA 22202-4501

RE, Willowood, LLC - Willowood Bthofumesate Turf (EPA Reg. No. 87290-

Application for New Pesticide Registration

)

Dear Ms. Miller,

, , " , " ,

, , > ,

, , " , , , , .

, , " , , , ,

, . ,

" , " , •

,,» . .

" " ,

On behalf of Willowood, LLC please find the enclosed application for registration of Willowood

Ethofumesate Turf, an end-use product containing ethofumesate as the active ingredient. In support of

this application, we submit the following documents:

1. Copy of the cover letter with confidential business information redacted

2. Application for Registration (EPA Form 8570-1)

3. Receipt ofPRIA pre-payment from pay.gov

4. Confidential Statement of Formula

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

6. Five (5) copies ofthe proposed labeling

7. Certification with Respect to Label Integrity

8. Electronic copy ofthe Willowood Ethofumesate Turf label on CD

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

lO. Agency Internal Use Copy ofthe Data Matrix (EPA Form 8570-35)

I I. Public File Copy ofthe Data Matrix (EPA Form 8570-35)

12. Letter of Authorization '" , Concurrent with this application for registration, Willowood, LLC is submitting an application for

registration ofWillowood Ethofumesate SC (EPA File Symbol No. 87290-PENDING).

Willowood, LLC requests data submitted to support the registration of

Willowood Ethofumesate SC (MRID No.'s PENDING) be used to support the registration ofthis product,

Willowood Ethofumesate Turf. These data include:

Volume No. from Willowood Ethofumesate Willowood Ethofumesate SC Study Title

SC Submission

ranottcanon dated Januarv 5, 2010)

Volume I Kellogg, M. ProductIdentity andComposition, Description

of the Materials Used, Descriotion of the Formulation

28

*Commercial/financial information may be entitled to confidential treatment*
K Montague

January 5, 2010

Page2 of2

Process, Discussion of the Formation oflmpurities,

Certified Limits, and Analytical Methods to Verify

CertifiedLimits for Wil1owood Ethofumesate S'C,

Volume 2 Sinning, D. Physicaland Chemical Characteristics of

Ethofumesate SC: Physical State,OxidationlReduction,

Flammability, nH, Viscosityand Relative Density.

Volume 3 Kellogg, M. WaiverRequestfor Certain Data Requirements

for Wil1owood Ethofumesate SC.

Willowood, LLC believes its product, Willowood Ethofumesate Turf, is substantially similar to a

currently registered product (EPA Reg. No. 70506 M107). Willowood, LLC believes this application falls

under Category R300 (44) since Willowood Ethofumesate Turf 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 registered source(s) of supply and therefore, Willowood Ethofumesate Turf qualifies for

Pormulators Exemption for ethofumesate generic data requirements.

With the Willowood Ethofumesate SC application for registration, Willowood, LLC has requested a 50%

small business fee waiver. Therefore, a receipt of PRlA prepayment for 50% of the R300 PRIA fee, or

$682.50 is enclosed with this application.

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.

Sincerely,

/td42~)"" , , "

" , , , , ,

Michael Kellogg , ,

,

" , , , , ,

, " , , ,

Enclosures

cc: B. Heinze; Willowood, LLC

," " " ,

, " , , "

, 0 • ,

, , > ,

29
Whit•• EPA File Copy (onglnel' v,now • Appllcent Copy

'" .., . . n . L_~_,.~ _, )1ep'OY form. form Appr. nMR NO, • ,.,a-ss

Unitod States BRegistration opp Idontiflor Numbor

&EPA Environmental Protection Agency Amendment

Wushington, DC 20460 Other

Application for Pesticide - Section I

18~;~;~nYfgoduct Numbor 2. EPA Product Mano:gor 3. PropoSlld Classification

K. Montague 0 Nono D Hcatricted

4. Company/Produot (Namol PM.

Willowood, LLC / Willowood Erhofumesale Turf 23

5. Name and Address of Applicent !Include ZIP Codtl/ 6. Expedited Reveiw. In accordance with FIFRA Section 3/el/3)

Willowood, LLC (bJ(iI, my product is similar or identical in composition and labeling clo Pyxis Regulatory Consulling, Inc. to: 4110 1361h st NW 70506·107

Gig Harbor, WA 98332 EPA Reg. No.

DChock ff this is. now add"s$ Poaconstrtctcr Herbicide

Product Name

Section II

D Amcndment . Explllin below. U Flnal printed label' In repllonso to

Agency 11Ittlfrdated

D Rosubmission in rllsponse to Agoncy letter dated 0 "Mit ree- Appliclltion.

D Nctificetlcn - Explain below. D Other - Explain ecrew.

Explanation: Use odditionlll pllgoisl if necesserv. IFor section I and Sacticn II.}

This application falls under Category R3DD (44) as ills a new product substantially similar in composition and use to a registered product and

the cite-all method of data support is being used 10 support product specific acute toxicity data requirements. The fee due is $1365.00 and the

decision timeline is 3 months. However, wlnowooo. llC is requesting a 50% fee waiver. A receipt of PRIA pre-payment from pay.qov for 50%

of the R3DD PRIA fee ($682.50) is included with lhis application. Should you have any ques1ions, please cornact me at (email)

Mike@PyxisRC.comor(phone)253-853-7369.

Section - III

1. Meteriel Th.. Product Will Be Packeged In:

Child-Rasilltllnt Packaging Unit Packaging Water Soluble Packaging 2. Type of Contlliner , , " , , , ,

~y" ~MO;dl; ,

Er' yO'

,/ < Plastio ,

.f No .f No No E!(.!I:) ,

" C",tifiC8tionmust If "Yos" No. per If ·Yos" No. per P'apllr;

Unit Packaging wgt. containsr PlIckago wgt contelner OtHlI'r (Spo:cifyf~~, be submitted ,-" ,, " , . ,

3. Location of Net Contonts Information 4. Sizo(sl Rotall Container I5. Location of Lab3:'Dirt'Ctions ~..

[{J U Conteiner

--':L.' On Lab.1 ; , , , :,

Lobel 2.5, 5 gallon f:=:J On Lab.lin~ accompanying pr<>~u<:l

S. Mennor in Which Lebel i$ Affixod to Product lJUthograph 0 Othar ' , , , , . J paper.~IUOd ,-" , StenO! ed

Section - IV

1. Contact Point (Comp/oto I/oms dUtlctly be/ow for Idenrificorion of fndivfdull! to btl contacttld, ifnscQuary, ro process this lIPp/icstion./

Name Title Telephone No. (lncludo Aroa Codel

Michael Kellogg Agent (253) 853·7369

Certification s. cete Application

I ccmtv that the stetementa I hevc made on this form lind ell ettechments thereto ere true, accurate o:nd ccrnptete. Received

I 8cknowledga that any knowlinglly tetse or misleading statement may bll pUniShable by fino or impnsorvnent or (Stamped)

both undor IIpPUcllble law.

2~::;~:~i7J 3. TItle

. Agent

4. Typod Neme / 5. Oete

Michael Kellogg

I 1,/:::::0/0 .. EPA Form 8570-1 (R,v. 3-941 PreVIous edillons are obsolete.

30
Form approved, OMS No, 2070-0060, 2070·00"" 2070"0107, 2070-0122, 2070-0t64.

Copy 2 Apprtcent copy

aEPA

unneo stares

Environmental Protection Agency

Washinglon, DC 20460

Formulator's Exemption Statement

(40 CFR 152.85)

Applicant's Name and Address EPA File Symbol/Regislration Number

Wlllowood,LLC 87290-

8690 Lookingglass Road Product Name

Roseburg, OR 97471 Willowood Ethofumesate Turf .. Dale of conncennat Statement of Formula (EPA Fonn 857fH)

01105/2010

As an authorized representative of the applicanl for registralion of lhe product idenlified above, I certify thai:

(1) This product contains uie following active ingredienl(s):

Ethofumesate

(2) Of lhese, each aclive ingredient listed in paragraph (4) is present solely as the resull of the use of mar active Ingredienl in lhe rnanuracturinq.

romunancn or repackaging anomer product which conrems that acuve ingredient whidl is regislered under FIFRA sscnon 3, is purchased by

us from another person and meers the requirements of 40 CFR secuon 158.50{e)(2) or (3),

(3) Indicate by checking (A) or {B} below which paragraph applies:

71 {A} An accurate ccnnoennat statement of Formula (EPA FORM 8571J-4) for lhe above identified product is attached 10this statement.

Thai formula statement tootcares. by company name, reqtsrrenon number, and product name, lhe source of the active ingredienl(s) listed in

paragraph (1).

DR

"l (S) The ccnnoeonar staiemenr of Formula {CSF)(EPA Form 8570-4} referenced above and on file wilh lhe EPA is complete. curren, an

accurate and conrams lhe mrormanon required on the ccrrenr CSF.

(4) The following active lnqredlenls in lhls product qualify for the rormurarcrs exempli on.

Source

Active lngredienl Product Name Regislralion Number

Bthofumesate

,"". " ,

,

,

, ,

,- " ::;~ l.')Af1t Name and Title Date ,

1!~kJ(J;a ,

Michael Kellogg / Agent .. ,

EPA Form 8570· 7 (Rev. 06-200 r Copy t :..EPA

,

31

*Product ingredient source information may be entitled to confidential treatment*
4110136· St. NW

Gig Harbor, WA 98332

November 9, 2009

WILLOWOOD, LLC

Phone: 253-853-7369

Fax: 253-853-5516

Document Processing Desk(COADR)

OfficeofPesticidePrograms (7504P)

U.S. Environmental Protection Agency

Room 8-4900. OnePotomac Yard

2777 S. Crystal Drive

Arlington, VA 22202

ToWhom It MayConcern:

RE: Letter of Authorization

Please let this letter serve to notify you that Pyxis Regulatory Consulting, Inc. (contact

information below) is authorized to represent Willowood U.S.A.. LLC (Co. No. pending) as

authorized agent before the U.S. Environmental Protection Agency in all matters regarding

our pesticide registrations and applications for registrations pursuant to the Federal Insecticide,

Fungicide and Rodenticide Act (FIFRA), 7 USC Section 136 et seq. Direct all official

correspondence from EPAto:

•

Agent:

Pyxis Regulatory Consulting, Inc.

4110 136· St NW

Gig Harbor, WA 98332

T: (253) 853-7369

F: (253) 853-5516

info@PyxisRC.com

If you have anyquestions, please do nothesitate to contact me.

, ." 0, ,

• •

•

• "'" , • •

, ,• " , ., , , " .> , " ,

"., ,

Sincerely, " , 0

Brian Heinze

President

Willowood, LLC

cc: PyxisRegulatory Consulting, Inc.

32
Form ecoroveo OMS No. 2070-0060

...."

.; on. 1 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY \,':Il!'/ 401 M Street, S.W.

WASHINGTON, D.C. 20460

Paperwork Reduction Act Notice: Thepubic reporting burden for this collection of information is estimated to average1.25 hoursper response for registration

and 0.25 hoursper response for reregistration and specialreviewactivities, including time for reading the instructions and completing the necessary forms. Send

comments regarding buden estimate or any otheraspect ofthls COllection of information, ncluding suggestions for reducing the burden to: Director, OPPE

Information Management Division (2137), U.S. Envronrrental Protection Agency, 401 M Street,S.w., washington, DC20460.

Do notsend Ille completed formto thisaddress.

Certification with Respect to Citation of Data

ApplicanfsJRe!=listranfs Name,Address, and Telephone Number EPA Registration Number/File Symbol

Willowood, LLC clo Pyxis Regulatory Consulting, Inc,: 4110 136lh 51. NWGig Harbor, WA 98332, (253) 853-7369 87290-

ActiveInQredienl(S) andlorrepresentative test conccunorsi Date

Ethofumesate January 5,2010

GeneralUse Patllm(s) (list al those Claimed forthis productusin!=l 40 CFR Part 158) ProductName

Terrestrial Nonfood Willowood ethorumesate Turf

NOTE: If your productis a 100%repackaging of anotherpurchased EPA-registered productlabeledfor all the same useson your label,youdo not needto

submitthisform. Youmust submitthe rcrmuators ExemptionStatement (EPAForm8570-27).

D I am responding toa Data-Call-In Notice,and haveinduded withIllis form a list of companies sent offersof compensation (the DataMatrixform should

be used furthis purpose).

SECTIONI: METHOD OF DATA SUPPORT(Checkone method only)

D I am usingthe cite-allmethodctsuppcrt, and haveinduded with thisform [2] I am usingee selective methodof support(or cite-all option

a ret of companies sent offersof compensation (the Data Matrixform underthe selective method), and haveindudedwith thisforma

should be used forthis purpose). completed list of data requirements (the Data Ma1Jix form trust be

used).

SECTION It: GENERAL OFFERTO PAY

[Required if usingthecite-all method or whenusingthe cite-alloptionunderthe selective method tosatisfyone or moredata requirementsl

[2] I herebyofferand agreeto pay compensation, to other persons, withregardto the approvalof thisapplication, to the extentrequired by FIFRA.

SECTION tit: CERTIFICATtON

t certffythat this application for registration, thisform for reregistration, or this Data-Call-In response is supported by all data submitted or dted in the

application for registration, the form for reregistration, or the jjata-Caj-tn response. In addition, if the cite-alloptionor cite-alloptionunderthe selective methodis

indicated inSection I, this application is supported by alldata in the Agel1cy's files that (t) concern the properties or effectsof this productor an identical or

substantially Similar product, or one or more of the Ingredients in this product: and(2) is a typeof data thatwould berequired tobe submitted underthe data

requirements in effecton the dale of approval of thisapplicaton if the application soughtthe initialregistration of a product of identical or similarcomposition and

uses

I certifythat for earn exdusive use studycitedin supportof this registration orreregistration, that I am the original data submitteror that I have obtained

the writtenpermission of the original datasubmitterto cnethat study.

I certffy thatfor each studyceeoIn supportof this registration or reregistration thatis not anexcusve usestudy,eane: (a) I am the original data

SUbmitter: [b) I have obtained the permission of the originat data submitterto use the studyin supportof this application: (c) all periodsot eligibility for

compensation haveexpired for the study; (d) the studyis in the publicuerenre: or (e) I havenotifiedin writing the company tIlat submitted the studyand have

offered(I) to pay compensation to the extentrequired by sections3(c)(1)(F) and/or3(c)[2)(B) of FIFRA; and ~i) to commence negotiations to ~t.rP1i'll?>the

amountandtermsof compensation, if any,to be paidfor the use of the study, ,,) , " , , , I certifythatin all instanceswherean offerof compensation is required, copiesof all offersto pay compensation an~ evicien6e of theirdeliveryin

accordance with sections 3(c)[1 )(F) enoor 3(c)(2)(B) of FIFRAare availableand will be submitted to the i\{Iency upon request ,8,hP',ftjl filii to produce such

evidence to the Agency upon request, I understand that the Agencymay initiateactionto deny, cancelor suspend ne registration'of m, productin conformity with

FIFRA. ' -' , , , ,

" , t certify that the statements I have made onthls form and all attachments to It are true, accurae, and compte!';,;' 'I-;cknov.ledgE;, that any

knowingly fatse or misleadilll statement may be punlahabte bJ fine or imprisonment or both under applicabte taw, , :0) ,_

s,,,,",, L?~ 0;/,_I Typed orPrinted Nameand Title ," , ,

/?t!/"; 'A . ,\I£Li{) Michael Kellogg; Agent ,,) i

EPA Form8570-34 (9-9 ) Electronica"i'apvversions available. Submitonly Paperversion.

33
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 thesedocuments

included with this submission.

IPROPOSED LABEL

Date Submitted

EPA Registration # to EPA Electronic file name

87290- January 5, 2010 087290-xxxxx.20100105.Willowood

Ethofumesate Turf label.pdf

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

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

punishable by fine or imprisonment or both under applicable law.

/Lrla:vo

Date

Michael Kellogg

Name (typed)

Agent

Title

. J' ,

,. .

• • ,. .

" J

34
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 tne a-tabel is not found in 1/10 eLL tnon it was probably nol named J

correclly Gild could 110/ be entered inlo 1110 eLL, However, /110 file

con be rellif!Yod (rom /110 CD~'!t!icll is ro}afnerLEl fll.tLfJ!?JY/ 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

35
PROCESc;lNG ELECTRONIC' Il.BELS

(rev. 1t5f09,lch)

If e-Iabel submitted via XML e-subrnisslon (not on CD-ROM), you may wish to find e-label in

Documenturn 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)

I ITRMD receives

paper submlsslon

wi e-label on CD

Tracking

record added 10

OPPIN

J ITRMD adds

e-Iabeltc ELL

in-process

4 ITRMD sends

paper submission

10AD/BPPD/RD

connect ELL

record with

OPPIN S#

u Save copy of e·

label from ELL to

My Documents

tu Send annotated

e-labefto registrant

via email

{ Review label

'I File print of

annotated e-Iabel

and email In jackel

uAdd comments

10e-label

I,",a; "ad '\,il~

caln"la"t.'· In f,lm'anla

review

11 Add annotated c.

label to Ell

out-process

\1 Print annotated elabel

Ij Close

submtsston in

OPPIN

Resubmission (via email to statler or PM)

14 Receive email

submission wI elabel attached

lti Save copy of elabels (old & new) from

ELL 10My Documents

," Add tracking

record to

OPPIN

10 Compare old and

new labels with

Acrobat

Ii> Add e-Iaber

to Ell

ill-process

review

11 Connect Ell

record with

OPPIN $#

(if revisions needed repeal steps 8-19)

~u Print e-tabet " Ma'il stamped

stamp,write cover label & cover

letter letter to registrant

(u." "1',"11 ",;11' ril~,,,,m,,"1

'U File stamped

label & cover letter

in jacket

out-process

~J Add cover

letter to Ell

l,on'wcIIOly il "",opi'''1

'~';II, 030'''''0''1')

14 Close

submission in

OPPIN

Qrocess - big pic lure

1- creale OPPlN tracking

2- put label in Ell; link to S#

3- save ELL label to MyDocumenls

4· compare / comment

5- outprocess

technigues 10 know

- filename for e-Iabels

- "print with filename"

- compare I comment

• printing with comments

36
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 information is estimated to average 0.25 hours per response for reqlalralicn activities and 0.25 hours per response for

reregistration and special review actlvilies. including time for reading the inslrucllcna and completing the necessary forms. Send comments regarding the burden estimate or any olher aspect of this colleclion of

informalion, indtJ:ling suggestions for reducing the burden to: Oirector,OPPE Information Managemenl Oivision (2137), U.S. Environmental Proledion Agency, 401 M Sheet, SW., Wash'lnglon,DC 20460. Do not

send the form to this address.

DATA MATRIX

oate January 5, 2010 EPA Reg No.lFile Symbol 87290- Page I of 5

Applicanl'srReqlstrant's Name & Address Product

Willowood, LLC

8690 Lookingglass Road

Roseburg, OR 97471

Willowood Ethofumesate Turf

tncrecent Ethofumesate

Guideline Reference Number I Guideline Study Name MRIO Number Submitter Status Note

Product Specific Data Requirements

830,1550 \ Product Identity and Composition Volume 1 WI!lowood, LLC OWN See endnote'

830.1600 I Description of Materials Used to Produce the

Product

Volume 1 Willowood, LLC OWN See endnote"

830.1620 Description of Production Process Not reoulretf

830.1650

830.1670

830.1700

830.1750

830.1800

830.6302

830.6303

Description of Formulation Process

Discussion of Formation of Impurities

Preliminary Analysis

Certified Limits

Enforcement Analytical Method

Color

Phvslcal State

Volume 1 Willowood, LLC OWN

Volume 1 Willowood, LLC OWN

Volume 1 Willowood, LLC OWN

Volume 1 Willowood, LLC OWN

Volume 2 \ Wdlowood, LLC laWN

See endnote 1

See endnote'

Not required"

See endnote1

See endnote1

Not required"

See endnote"

830.6304 Odor ~~~~

1£5/;;1.0/0

See endnote"

Not required"

OWN

OWN

AgenCYInternal Use Copy

Michael Kellogg, Consultant

Willowood, LLC

Name and Tille

Willowood, LLC

See endnoteS =! ] INot required6

Date

Volume 2

Flammabilit, ,; 0 _~, --C--C "".", I-':""''''''~_ , Volume 2 .,---~- I

Exolodabllltv :~ .. ,,~ I I ,

Stability to Nonnal a~d' Seva(eil Temperatures,

Metalaend Metaflons-" ~~O: ,,,":

Oxidation/Reduction: Chemicallncomoatlbllitv

and Paper versions available. Submit only Paper version.

830.6313

830.6314

830.6315

8306316

EPA Form 8~.35 (9-97) Elel

5',""", / ()

A.I,r.MJ.

37
Form Approved OMB No. 2070-0060

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

401 M Street, S.W.

WASHINGTON, D.C. 20460

Paperwork Reduction Ac1 Notice; The public reporting burden for this collection of nrormaron is estimated to average 0.25 hours per response for registration activities and 0.25 hours per response for

reregistration and special review activities, lncludinq time for reading the instructions and completing the necessary terms. Send comments regarding the burden estimate or any other aspect of this collection of

information, including suggestions for reducing the burden to: Oirector, OPPE mrormason Management Division (2137), U.S. Environmental Protection AgencY, 401 M Street. S.W., Washington, OC 20460. Do not

send the form to this address.

DATA MATRIX

Oale January 5, 2010

Applicant"sIRegislranl's Name & Address

WiUowood, LLC

8690 Lookingglass Road

Roseburg, OR 97471

EPA Reg No.lFile Symbol 87290~

Product

Willowood Ethofumesate Turf

l Page;J.,of 5

lnoredient Ethofumesate

GUideline Reference Number

830.6317

830.6319

830.6320

830.6321

830.7000

830.7050

830.7100

830.7200

830.7220

830.7300

830.7370

830.7520

830.7550

830.7560

830.7570

Si9nature I /l

/7/7'p,' . .td. /

-- GUideline Studv Name

Storace Stabffltv

Miscibititv

Corrosion Characteristics

Dielectric Breakdown Voltaoe

I ol-i

UVNisible Absorption - Viscositv

Meltino Point/Meltinq Rance

Boilinc Point/Boilino Ranoe

Densitv/Relative Density/Bulk Densitv

Dissociation Constants in Water

Particle size, fiber length, diameter distribution

Partition Coefficient (ll~o8tanotlw~tett, Shake

Flask Method :~-~ "'": ~~:

Partition Coefficient {n-octan611wate~,

Generator Column Method

MRID Number

Volume 2

Volume 2

Volume 2

Submilter

Willowood, LLC

wucwcco, LLC

Willowood, LLC

Name and Title

Michael Kellogg, Consultant

Status

OWN

OWN

OWN

Note

PRN 92_57

Not reouired"

See endnote"

Not required"

See endnote"

Not required"

See enoncte'

Not required

Not required"

See endnote"

Not recuired"

Not reouired'"

Not required"

Not required"

Not required"

EPA Fonn 8570-35 (9·97) Electronic ~erversions available. Submit only Paper version Agency tnternat Use Copy

38
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 borden for this coaecuonof information is estimated to average 0.25 hours per response for registration acucnes and 0.25 hours per response for

reregistration and special review actIvities, inclUdingtime for reading the instructions and completing lhe necessary forms. Send comments regarding the burden estimate or any other aspect 01this collection of

information, including suggestions for reducing the burden to: Director, OPPE inrormauonManagement Division (2137), U.S. Environmental Protection Agency, 40t M Street. S.W., Washington, OC 20460. 00 not

send the form to lhis address.

Oate January 5, 2010

Applicanl'sfRegislranl's Name & Address

Ingredient Ethofumeaate

DATA MATRIX

Witlowood, LLC

8690 Lookingglass Road

Roseburg, OR 97471

EPA Reg N()JFile Symbol 87290-

Product

Willowood Ethofumesate Turf

I Page :Sof 5

Guideline Reference Number

830.7840

830.7860

830.7950

870.1100

870.1200

870.1300

870.2400

870.2500

870.2600

Guideline Studv Name

Water Solubility: Column Elution Method;

Shake Flask Method

Water Solubility, Generator Column Method

Vapor Pressure

Acute Oral Toxicitv: Rat

Acute Dermal Toxicitv; Rat

Acute Inhalation Toxicity: Rat

Primary Eye Irritation: Rabbit

Primary Dermal lrrttation

Dermal Sensitization

~u ..

- ~"

MRID Number

Cite-All

CiteMAII

Cite-All

Cite-All

Cite-All

Cite-All

Submilter status

PAY

PAY

PAY

PAY

PAY

PAY

Nole

Not required"

Not required"

Not reoulred"

I '. C_C : -: I I I I I C' '" v

$;'0:._ 1()4 .

. -.- Name and Title

Michael Kellogg, Consultant

Date

rld;;lQjf1

EPA Form 8570-35 (9·97) Electronic and Paper versions available. Submit only Paper version. Agency Internal Use Copy

39
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 intormation 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 lime for reading the instruclions and completing the necessary fonns. Send comments regarding the burden estimate or any other aspect ot this COllectionot

information. including suggestions for reducing Ihe burden to: Direclor, OPPE mrormaucn Management Division (2 t37), U.S. Environmental Protection Agency, 40t M sneer. S.W., washington, DC 20460. Do not

send the tonn to this address.

OATA MATRIX

Date January 5, 2010 EPA Reg No.lFile Symbol 87290- I Page lfof 5

Applicant'siRegistranl"s Name & Address Product

Willowood, LLC I Willowood Ethofumesate Turi

8690 Lookingglass Road

Roseburg, OR 97471

In recent Ethofumesate

Guideline Reference Number I Guideline stocv Name MRID Number Submiller sreue Nole

Willowood Ethofumesate SC Product Soecific Data Reauirements

Wlllowood, 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

ethcfumesate.

Ethofumesate Product Specific Data Reauirements

Ethofumesate Product Cite-All Bayer CrcpScience LP PAY

Specific Data Requirements

Ethofumesate Product Cite-All Spray Drift Task Force PAY

Soeciffc Data Reouirernents

Ethofumesate Product Cite-Ali United Phosphorus, Inc. PAY

Soeciftc Data Reouirements

Ethofumesate Product Cite-All Outdoor Residential Exposure PAY

Soeciffc Data Reouirements Task Force

...: "-~-~ "

Ethofumesate Product Cite-All • -'C Agricultural Reentry Task PAY - Soeciflc Data Reauirements ,

- - --- Force ,-,-,. ~"~'w

Ethofumesate Product Cite-All FIFRA Endangered Species PAY

Specific Data Requirements - Task Force, LLC

;;;j"li)~ - - - - - ,. w "

-- - - - - Name and Tille Dale " , - - - - - - -- - - - - Michael Kellogg, Consultant - - - -

-- 1/,'\'/;;0//7

EPA Form 8570·35 (9-97) Electronic and Paper versions available. Submit only Paper version. Agency Internal Use Copy

40
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 ntcrmsuon is estimated 10average 0.25 hours per response for reqlslratlon activities and 0.25 hours per response for

reregistration and special review activities, including time for reading fhe instructions and completing the necessary forms. Send comments regarding the burden estimate or any other aspect of this collection of

information, including suggestions for redudng the burden to: Director, OPPE Information Management Division {2137}, U.S. Environmental Protection Agency. 40 t M Street, S.W., Washington. DC 20460. Do not

send the form to nus address.

DATA MATRIX

Dale January 5, 2010 EPA Reg N~-"!file Symbol 87290~ I Page,5;f 5

Applicanl"slRegistranl's Name & Address Product

Willowood, LLC

8690 Lookingglass Road

Roseburg, OR 97471

Wlllowood Ethofumesate Turf

Ingredient Elhofumesale

Guideline Reference Number

Ethofumesate Produet

Specific Data Requirements

Ethofumesate Product

Specific Data Requirements

Ethofumesate product

Specific Data Reculrements

Ethofumesate Product

Specific Data Requirements

Guideline Study Name

Cite-All

Cite-All

Cite-All

Cite-All

MRID Number Submilter Status I Note

J&S AgChem, Inc. PAY

Agricultural Handlers PAY

Ex osure Task Force

Source Dynamics, LLC PAY

Generic Endangered Species PAY

Task Force

Ethofumesate Generic Data Requirements

Willowood Ethofumesate SC qualifies for Formulator'S~Exemptlcln rcr-ethorumesate generic data

requirements. :w,.~~-.:....:o o,.~ I I I

I w,~ u_~". I

Date

I rid::;;.

Name and Tille

"" , Michael Kellogg, Consultant "

:~ "" "_: I I rlS7ZYO I I~ " " w

EPA Form 8570-35 (9-97) Electronic and Paper versions available. Submit only Paper version. Agency Internal Use Copy

41
Endnotes for Data Matrix for Willowood Ethofumesate Turf

1830.1550,830.1600,830.1650,830.1670,830.1750 and 830.1800 - Willowood, LLC requests that data

submitted to support the registration of their Willowood Ethofumesate SC product (EPA File Symbol

No. 87290~PEND!NG) be used to support this registration, Willowood Ethofumesate Turf.

. Please refer to

Volume 1 (MRfD No. PENDING) of the Willowood Ethofumesate SC application for registration

submission dated January 5, 2010.

.2830.1620 Per OPPTS 830.1000, these data are not required for the registration of an

end-use product See 830.1650 for formulation process information.

3830.1700 _ 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.

, 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.

s 830.6303,830.6314,830.6315,830.7000,830.7100 and 830.7300 - Willowood, LLC requests that data

submitted to support the registration of their Willowood Ethofumesate SC product (EPA File Symbol

No. 87290-PENDING) be used to support this registration, Willowood Ethofumesate Turf.

. Please refer to

Volume 2 (MRID No. PENDING) of the Willowood Ethofumesate SC application for registration

submission dated January 5,2010.

6830.6316 _ 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

WiUowood Ethofumesate TUrf.

7830.6317,830.6320 - Willowood, lLC is currently conducting storage stability and corrosion

characteristic studies to satisfy guidelines 830.6317 and 830.6320, respectively for their Willowood

Ethofumesate SC product. Willowood, LLC requests that data being generated to support the

registration of their Willowood Ethofumesate SC product be used to support this registration,

., P,E~I PR No;;ir,:~>&A5, storage stability data are not required to be submitted unless specifically requestqd blt~e 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 da:ta;u13qn

completion. As these studies take over a year to complete, WHiowood, LLC requests that-a conditional

registration for Willowood Ethofumesate Turf be granted on the submission of these data , >, , • , " .,. 0-

e 830.6319 - Willowood Ethofumesate Turf is not an emulsifiable concentrate. In addltion"the proposed

labeling recommends dilution with water, not oil; therefore, these data are not required. ; '" ;,

9830.6321 - This product is not proposed for use around electrical equipment. Therefore, these data are

not applicable nor are these date required. ' >~, , '

10 830.7520 These data are not required for Willowood Ethofumesate Turf because it is not water

insoluble and is not a fibrous material.

Page 1 of 1

42

*Commercial/financial information may be entitled to confidential treatment*
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

WASHINGTON, D.C. 20460

January 11,2010

OFfiCE OF

PREVENTION, PESTICiDES AND

TOXICSUBSTANCES

OPP Decision Number: D-425895

EPA File Symbol or Registration Number: 87290-E

Product Name: WILLOWOOD ETHOFUMESATE TURF

EPA Receipt Date: 08-Jan-2010

EPA Company Number: 87290

Company Name: WlLLOWOOD, LLCEPA File Symbol or Registration Number:

Michael Kellogg

PYXIS REGULATORY CONSULTING, INC.

WILLOWOOD, LLC

4110 1136TH STREET, NW

GIG HARBOR, WA 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 ofthe PRN-86-5 screen will be communicated separately. During the administrative

screen, the Office ofPesticide 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. Ifyour waiver request is approved, the decision

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

receive an invoice for the outstanding balance.

Ifyou have any questions, please contact the Pesticide Registration Service Fee

Ombudsman at (703) 305-6249. y

43
Mike Kellogg

From:

Sent:

To:

Subject:

paygovadmin@mail.doc.twai.gov

Tuesday, January 05, 2010 1:24 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 1D: 2S0750MH

Agency Tracking 1D: 74095715826

Account Holder Name: Brian Heinze

Transaction Type: Sale

Transaction Amount: $682.58

Billing Address: 869B Lookingglass Road

City: Roseburg

state/Province: OR

Zip/Postal Code: 97471

Country: USA

Card Type: Master Card

Card Number: ************6085

Transaction Date: Jan 5, Z818 4:23:51 PM

Decision Number:

Registration Number: 872gB-xx

Company Name: Willowood, LLC

Company Number: 872ge

Action Code: R3ee

1

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, " , , , , ,

" , , ,

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44
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~(IDOO ®~~~mi~ill~ [ID~rn ®OO~Y! FILE SYMBOL

IlEGISTIIA1'lON NO.

'i7:l9D~.£

CONfiDENTIAL STATEMENT Of fORMULA ENCLOSED

DATE SUBMITTED BY (.I)

SUBMITTED APPLICANT BASICSUPPLIER

JAN 082010 I

I

< <

I

Do Not Write Comments,

Formula, or Parts of Formula

on This Envelope

NOTE

It'shaD~anl.~II~'~)'.,~rSontt.i~se:.forblsown 'ad'f8~

or to reveal, oth~:~~~·~ecretB~::~~offlcIalS oremp!oyees()f

ttleUntted states Dep8rtln8ntotAgficattUre or other Federal8gencle8,

or to the eourtS In resPorise to aiiubpOe~orto phySlCIans/.iNUn

emergenciestoPltanriacl~ 'and0ther:-qUal1fl8dpe~ons~foruseln

the prepmtfon of anUdotes{ InaccordancelwttbsuchdlreCuOnsa.

theSectetary.. inay pntS~. al'l)'lnfOrrrurtlon....rel8ttvetO.fc.rmulas;o,:""

productSacquhed bYliuthiiityOf SeCtIon 401 the "FederalbtaftCtlcfde.

Funglcfde.'l!ind'Roden'tICIcIe,.,ACt,:"

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PR"'.i:~::',

-- USOAo.u

45
Pages 46 through 47 contain the product confidential statement of formula and is not included in this copy.