EPA Registration Jacket 88031‐4
1

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 

WASHINGTON, D.C. 20460 

MR. RUSTY MILLAR 

CPBJO,INC 

4802 MURRIETA ST 

CHINO, CA 91710-

Dear Mr. Millar: 

May 18, 2011 

OFFICE OF 

PREVENTION, PESTICIDES AND 

TOXIC SUBSTANCES 

Subject: Transfer of Pesticide Registrations From Company Number 83028 to Company Number 

88031 

Pursuant to your request in your letter and transfer agreement of January 25, 2011 and 

subsequently received infonnation, we have approved the transfer of the following registrations 

from NCA BIOTECH, INC., company number 83028 to CP BIO, INC, company number 88031. 

The effective date of these changes is the date ofthis letter. 

Registered Products 

TECHNICAL 3-INDOLEBUTYRIC ACID 

TECHNICAL GIBBERELLIC ACID (GA3) 

KINETIN TECHNICAL 

6-BENZYLAMINOPURINE TECHNICAL 

GIBBERELLIN A4+7 TECHNICAL 

MEPIQUAT CHLORIDE TECHNICAL 

GA34% 

ROOTGRO 

HAPPYGRO 

MegaGroL 

GA320% 

Pending Registered Products 

GOLDENGROR 

Old EPA 

Reg. No. 

83028-2 

83028-3 

83028-4 

83028-5 

83028-8 

83028-13 

83028-15 

83028-17 

83028-18 

83028-19 

83028-20 

Old EPA 

File Symbol 

83028-RA 

New EPA 

Reg. No. 

88031-4 

88031-6 

88031-7 

88031-8 

88031-9 

88031-10 

88031-11 

88031-12 

88031-13 

88031-14 

88031-15 

New EPA 

File Symbol 

88031-L 

You should indicate the new company designation, new EPA Registration Number and 

new Establislunent Number (if it has changed) on the labeling at the next printing which should 

occur no later than 18 months after the effective date of this transfer. After 18 months, any 
2

product released for shipment must bear the new Registration Number and Establishment 

Number. If you intend to use the labels which currently appear on the transferor's product after 

the effective date of the transfer, but within the 18 month grace period, you must maintain 

complete and accurate records which identify by batch number, lot number, or other suitable 

description the quantities of such product bearing the transferor'S labeL Each container or 

package bearing the transferor's label which is released after the effective date of pro duct 

registration transfer, must be clearly and accurately marked with the batch number, lot number or 

other descriptive designation used to identifY the product in your records. 

Supplemental distribution agreements of registered products do not transfer with the 

Section 3 registration. It is your responsibility as the registrant to notifY any and all supplemental 

distributors of the transferred product(s) of this transfer agreement. If you wish to enter into 

supplemental distribution agreements of your product(s) under this new registration, the form 

"Notice of Supplemental Distribution of a Registered Pesticide Product," EPA Form 8570~5, 

must be submitted to the Agency for each supplemental distributorship. 

You are required to contact your local EPA Regional Office to detennine what effect this 

transfer of pesticide registrations has on the pesticide production establishment registration. 

It will not be necessary to submit labeling for review if the only changes are in the 

company designation and the EPA Registration Number. Other changes in the product and/or 

labeling may require EPA review and approval prior to distribution or sale of the product 

containing the new registration number. In any correspondence on these products always refer to 

the U.S. EPA Registration Number listed above. 

The transferred registration will have the same status under the Federal Insecticide, 

Fungicide and Rodenticide Act, as amended, 7 USC 136 et seq., as it had prior to the approval of 

this transfer. 

When registrations are transferred from one company to a second company, all 

restrictions, data requirements, conditions (suspensions), and deadlines existing on the 

registrations are transferred with the registrations. The new company is responsible for adhering 

to or complying with all such restrictions, etc. on the acquired products. 

With regard to deadlines, the transferee company is responsible for submitting all 

required data according to the schedules already established for the acquired products. Failure to 

do so will result in the issuance of a Notice ofIntent to Suspend. Requests from transferee 

companies for additional time to submit, because they acquired the registration(s) after the 

3(c)(2)(B) request was issued will not be granted. If a transferee company has other valid 

reasons for delays in the testing which were clearly outside of their control, then such requests for 

time extensions will be considered in accordance with the established procedures. Transfers 

occurring while a 3(c)(2)(B) request is being issued or during the 90~day response time are 

subject to the same conditions expressed above. 

Registration is in no way to be construed as an endorsement or approval of these products 

by the Agency. In order to protect health and the environment, the Administrator, on his motion, 

may at any time suspend or cancel the registration of a pesticide in accordance with FIFRA. 
3

Furthermore, the transfer of the subject registrations is approved under the condition that 

the annual maintenance fee obligation has been fully satisfied. The marginal maintenance fee is 

detennined based solely on the total number of active section 3 and section 24(c) registrations 

held by the transferor. If the annual maintenance fee has not been fully satisfied, the transferee 

and transferor will be notified to comply within a specified time period or the affected 

registrations may be canceled. 

By copy of this letter we are infonning the transeror of these changes. If you have any 

questions, please contact Louis Vaughn at (703) 308-8114. 

Steve Robbins, Chief 

Infonnation Services Branch 

Infonnation Technology & Resource Management Div. (7504P) 

cc: MR. RUSTY MILLAR 

NCA BIOTECH, INC. 

4802 MURRIETA STREET 

CHINO, CA 91710 
4

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Material to be added to an e-Jacket/Jac:ket 

1. l'9 Placement within the e-Jacket/jacket: 

D Default: (chronological, top/newest) 

D Description: (PDF page number, i.e., "before page 

45") 

2. M Send to Data Extraction contractors this materia!: 

D Newly stamped accepted label 

D 

D 

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Notification 

NewCSF 

Other: G.oc", ;S~~ \ Cu,..\::::.. 

3. Attach this coversheet to the top ofthe material or jacket. It 

must be well organized and clipped together, NOT STAPLED. 

Then give the material with this coversheet to staff in the 

Information Services Center (Room S-4900). 

Reviewer's name: Sylvester George 

Phone: 603-0688 Division: BPPD 

Date: 4-\- \\ 

Created January 26, 2009 
5

UNITED STATES ENVIRONMENTAL PROTECTIOI .SENCY 

1, Linda A. Hollis, Chief, Biochemical Pesticides Branch, Biopesticides and Pollution Prevention 

Division, Office of Pesticide Programs, Office of Chemical Safety and Pollution Prevention, United 

States Environmental Protection Agency (EPA), certify that the pesticide product listed below is, as of the 

date of this letter, a registered product under the Federal Insecticide, Fungicide, and Rodenticide Act 

(FIFRA), as amended, and that as such, the product may be sold and marketed in the United States of 

America as authorized and limited by FIFRA. A true and correct copy of the product label approved by 

EPA is attached to accompany this letter. 

Registration of this product with EPA also denotes that the registrant listed below is responsible 

for ensuring full compliance with all laws of the United States of America, or governing jurisdiction, 

regarding the sale, storage and/or disposal of the product. Further, the recipient of this letter is on notice 

that the status of the referenced registration and/or the accompanying label may change subsequent to the 

date of this letter. EPA assumes no responsibility to notify the recipient of this letter of any change in the 

status of the registration and/or the product label for the product listed below. EPA has issued a 

registration number for the product listed below to: 

EPA REGISTRATION NUMBER 

83028-2 

NCA Biotech, Inc. 

4802 Murrieta St., Chino 

California 91768 

NAME OF PRODUCT 

Technical 3-Indolebutyric Acid 

CONCURRENCES 

Linda A. Hollis, Chief 

Biochemical Pesticides Branch 

Biopesticides and Pollution Prevention 

Division (7511P) 

[Date] 

:::::E DATE ~"~"I""""""""'''''I'''''''''''''''''''''I''''''''''''''''''''t .. it~i~ iT" .................................................................................................................................................. .... ··· .. ·· ...... · .. \· ...... · ............. \· ....... · .... ·· ...... \ ................ · ..... .. 

EPA Form 132D-1A (1190) Printed on Recycled Paper OFFICIAL FILE COPY 
6
7

BID1B:l'I INC. NCA Biotech, INC. 

February 28,2011 

Ms. Linda Hollis, Chief PM 91 

BPPD (7511P) Room S-4900 

US Environmental Protection Agency 

One Potomac Yard 

2777 S Crystal Drive 

Arlington, VA 22202 

Subject: Gold Seal Certificates for Technical 3-Indolebutyric Acid, EPA Reg No. 83028-2 

Technical Gibberellic Acid (GA3), EPA Reg. No. 83028-3 

Dear Ms. Hollis: 

NCA Biotech, Inc requests a gold seal certificate for the subject products. If there is a fee for 

this action please let me know and a check will be forwarded immediately, If you have any 

questions, please contact me. Thank you. 

Sincerely, 

Rusty Millar 

Manager Regulatory Affairs 

4802 Murrieta St, Chino, CA91768 

Tel.: 909.348.5133' Fax',909.348.5135 

Email: info@ncabiotech.com 
8

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"oEPA Unit"d Statee W Registration opp Identifier Nllmber 

Environmental Protection Agency Amendment 

W.ehlngton, DC 20460 X Other 

Application for Pesticide - Section I 

1. CompanyJProduct Number 2. EPA Product Manlger 3. Propo.ed CIIIS.ilication 

NCA Biotech, Inc 83028-2,8302B-3 linda Hollis 

4. ComplnylProduct (Nom.) PM' o None o Rutrictod 

NCA Biotech, Inc Technical IBA, Technical GA3 91 

5. Nama and Addr ... of Applicant Ilm::lud. ZIP Cod.} 6. Expedited Review. In accordance with FIFRA Section 3(cj(3) 

(blli). my product is similar or identical in composition and labeling 

NCA Biotech Inc 4802 Murrieta ST, Chino, CA 91710 to: 

EPA Reg. No. 

o Ch.ck if this is /I nllw addr#l$$ Product Name 

Section - II 

0 Amandmant - Explain balow. 0 Finll printed labale in ra.po,.... to 

Agoncy lotter datad 

0 Reaubmluion In rllPonlO to Agoncy lattar d.ted 0 '"Mo Too'" Application. 

0 Notification - Explain below. EJ Other - Explain balow. 

Explanation: U.o additional pegol.1 if necoo.ory. {For .oction I and Section 11.1 

A request for gold seal certificates for two products. 

Section - III 

t. Motorial ThiI: Product Will Be Peckapd In: 

Child·Ro.i.tlnt Packaging Unit Packaging Water Soluble Pack.aging 2. TWI of Container @V ... ~V" ~ V .. X No X No No ~M". X Pleotic 

GI .. e 

II Certiflcation must If ·Yao'" No. per If '"Yos'" No. par Papar 

Unit Packaging wgt. container Package wgt container Other ISpllcify} be subinfttBd 

I 

3. location of Nal Contant. Infonnation 4, Siza{sl Ratall Container 5. locetion of label Directionll 

0 o Container 2.5 gallon ~ Onlebel 

lebel On Ubeling IICcompenying product 

6. Manner in Which label i. Affixed to Product 3:: Uthogrsph U Other 

Poper felled Stonc' ed 

Section - IV - 1. Contllct Point IComp}.r~ ir~fTI$ dir~crly b,low lor idllfltifiClltion of individual ro be conr~t:r~d, if MCfl$$flry, ro proc.u --th'is IIPPIi(:ation,1 ,", - , N_ Tltl. Tajep!1qna No. {lnciud~ Aree Code) 

Rusty Millar Manager 909-348.5133 

-~' - Certification 6. Dete Applicstion 

I cortify that the It.tomentl I have made on W. form and ell attachnlllnls thoreto ar. true, accurate and comploto. R~celvad 

I eoknowledge that .ny knowingly flllee or mislee-dinll .tatamant mlV be punisheble bV fine or impri.onmont or (Stamped) both under applicable law. 

2"S;'"''"''/~, A.C- A;~ 3. Title 

Manager 

4. Typed Name , 5. Data 

Rusty Millar February 28, 2011 

. .. EPA Fgrm 8570 t (ROIl. 8-94) Pr~vious odltlonll er. obsolote. wtltq . EPA ~ CapV lorlglMlI YellOW - ApplicUlt Copy 
9

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Material to be added to an e-Jacket 

1. Placement within the e-Jacket: 

~ Default: chronological top 

<> Other: (PDF page number, i.e., "before page 45") 

2. Is this material: 

<> Newly stamped accepted label l Notification 

<> NewCSF 

<> Other: __________ _ 

3. Attach this notice on top ofthe material. It must 

be clipped all together, NOT STAPLED. Then give the 

material with this coversheet to staff in the Information 

Services Center (Room S-4900). 

Reviewer's Name: Gina Casciano ___ _ 

Phone: 703-605-0513 Division: BPPD 

Date: ___ ~lu~/~I(~e/~D~1 ________________ __ / I 

Created July 18/2008 
10

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 

WASHINGTON, D,C, 20460 

Rusty Millar 

Manager, Regulatory Affairs 

NCA Biotech, Inc. 

3406 Pomona Blvd 

Pomona, CA 91768 

October 16,2009 

SUbject: Notification for Labeling Revision Per PR Notice 07-04 

Product Name: Technica13-Idolebutyric Acid 

EPA Reg, No: 83028-2 

Your Submission Dated September 15,2009 

Dear Mr. Millar: 

OFFICE OF 

PREVENnON, PESnCIDES AND 

TOXIC SUBSTANCES 

The Biopesticides and Pollution Prevention Division is in receipt of your application for 

Notification under Pesticide Registration Notice (PRN) 07-4 dated above. A screen of the 

labeling revision request has been conducted for its applicability under PRN 07-04, and it has 

been determined that the action request falls -within the scope ofPRN 07-04. Our records have 

been duly noted, and the printed label submitted v.rith this application has been stamped 

"Notification, received and reviewed" and \\'ill be placed in our records as current and updated. 

Should you have any questions regarding this action, you may contact Gina Casciano at (703) 

605-0513 or via email at casciano.gina@'epa.gov. 

Sincerely, 

Linda A. Hollis, Chief 

Biochemical Pesticides Branch 

Biopesticides and Pollution 

Prevention Division (7511P) 

Internet.Addre~s (URl) _ http://wv.w,epa.goY 

Recycled/Recyclable _ Prinled wilh Vegelabie OH Based Inks on 100% PoslconslJmer, Process Chlonne Free Recycled Paper 
11

BIOTECH INC. NCA Biotech, INC. 

September IS, 2009 

Ms. Linda Hollis, Chief PM 91 

BPPD (751IP), Room S4900 

US Environmental Protection Agency 

One Potomac Yard 

2777 S Crystal Drive 

Arlington, VA 22202 

Subject: TechnicaI3·IdolebutyricAcid, EPA Reg. No. 83028·2 Container Disposal per PRN 

2007·4, Notification under PRN 98·10 

Dear Ms. Hollis: 

On August 5 we submitted an amendment to the container disposal language required per PR 

Notice 2007-4. At that time we mistakenly removed previously approved container disposal 

language. The label is being resubmitted restoring this language. Changes are highlighted 

in red for your convenience. Please advise us when the label is approved. If you have any 

questions, please contact me. Thank you. 

Sincerely, 

Rusty Millar 

Mgr. Regulatory Affairs 

340(-; F'OiviONf\ BI_VD' i-'OMONA CA 017G8 

Tel _ ~)O~).:'l48 5133 f-;·lX 909 34a51 ::\5 

Emilll Info@nCClbiotecl1,com 

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TECHNICAL 3-INDOLEBUTYRIC ACID 

PLANT GROWTH REGULATOR 

FOR MANUFACTURING PURPOSES ONLY 

FORMULATORS WHO USE THIS PRODUCT ARE RESPONSIBLE 

FOR OBTAINING EPA REGISTRATION FOR THEIR FORMULATED PRODUCTS 

ACTIVE INGREDIENT: 

!ndole-3-Butyric Acid ............................................................................................................................. 98.00/0 

OTHER INGREDIENTS: ........................................................................................................................ 2.0% 

TOTAL: ............................................................................................................................................. 100.0% 

EPA Rag. No. 83028-2 EPA Est. No. 72639-CHN-1 

If swallowed: 

If in eyes: 

If inhaled: 

If on skin or 

KEEP OUT OF REACH OF CHILDREN 

WARNING 

FIRST AID 

• a poison I center or i 

• 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. 

• 

• 

• 

• 

Hold eye open and rinse 

Remove contact lenses, 

rinsing eye. 

• person to 

and gently with water for 15-20 minutes. 

if present, after the first 5 minutes, then continue 

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

respiration, preferably by mouth-to-mouth, if possible. 

or 

• 

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

f---=----.-J~~~ 

i or you I I or 

For general product information, call NCA , Inc. at (909) 348-5133 between 

Manufactured for: 

NCA Biotech, Inc. 

3406 Pomona Blvd. 

Pomona, CA 91768 

NOTIFICATION 

Date Fleviewed: 10 /1 h /0 1 v .. 

Reviewed By: G. C~''::.Yl'' 

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13

PRECAUTIONARY STATEMENTS 

HAZARDS TO HUMANS AND DOMESTIC ANIMALS 

WARNING. May be fatal if swallowed, absorbed through skin, or inhaled. Causes substantial but 

temporary eye injury. Causes skin irritation. Do not get in eyes, on skin, or on clothing. Do not breathe 

dust. Wash thoroughly with soap and water after handling and before eating, drinking, chewing gum or 

using tobacco. Wear the appropriate PPE: 

Coveralls (over long-sleeved shirt and long pants) 

• Chemical-resistant footwear 

• Chemical-resistant gloves 

• Goggles 

• Dust/mist filtering respirator (MSHNNIOSH approval number prefix TC-21 C), or a NIOSH approved 

respirator with any N, R, P or HE filter. 

Remove and wash contaminated clothing before reuse. 

ENVIRONMENTAL HAZARDS 

Do not discharge effluent containing this product into lakes, streams, ponds, estuaries, oceans, or other 

waters unless in accordance with the requkements of a National Pollutant Discharge Elimination System 

(NPDES) permit and the permitting authority has been notified in writing prior to discharge. Do not 

discharge effluent containing this product to sewer systems without previously notifying the local sewage 

treatment plant authority. For guidance, contact your State Water Board or Regional Office of the EPA. 

Do not contaminate water when disposing of equipment washwaters or rinsate. 

DIRECTIONS FOR USE 

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

FOR MANUFACTURING USE ONLY 

Onty for Formutation into a Plant Growth Regulator for (1) The Follow'lng Uses: Ornamental 

herbaceous plants, ornamental woody shrubs and vines, ornamental and/or shade trees, barley, beans, 

broccoli, Brussels sprouts, cabbage, cauliflower, citrus fruits, corn (field, sweet), cotton, cucumbers, 

lettuce, melons, mustard cabbage, mustard (leafy/stem crop), oats, onions, green onions, peanuts, peas, 

peppers, potatoes, rice, rye, sorghum, soybeans, spinach, squash, strawberries, sugar beets, sugarcane, 

tomato, turnip, wheat, golf course turf, ornamental lawns and turf. (2) Uses for Which US EPA has 

Accepted or Waived the Required Data and/or Citations of Data that the Formulator has Submitted 

in Support of Registration; and (3) Uses for Experimental Purposes that are in Compliance with 

USEPA Requirements. 

STORAGE AND DISPOSAL 

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

PESTICIDE STORAGE: Do not store with foodstuff. 

PESTtCIDE DISPOSAL: Waste resulting from the use of this product may be disposed of on site or at an 

approved waste disposal facility. ; > 0 , 

CONTAINER DISPOSAL: Nonrefillable container. Do no reuse or refill this container:. 'd1e~ for re(;Ydihg, 

if available. Triple rinse (or equivalent). Then offer for recycling or reconditionir:'9, or ;puncture'and 

dispose of in a sanitary landfill or, by other procedures approved by state and local altt:'l~"iiics. :',' • ~r 

LIMITED WARRANTY AND DISCLAIMER 

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The manufacturer warrants that this product conforms to the chemical description Cifl 11 0M 'label; that this 

product is reasonably fit for the purposes set forth in item (1) of the Directions for Use when it is J.(s~b in 

accordance with such Directions; and that the statements under item (1) of the Directions, the y.'arplngs 

and other statements on this label, other than the suggested uses under items (2) and (31 p,f, ~he 

Directions, are based upon responsible experts' evaluation of reasonable tests of effectiveness, of toxicity 

to laboratory animals and to plants, and of residues on food crops and upon reports of field experience. 

2 
14

Tests have not been made on all varieties or in all states or under all condition. THE MANUFACTURER 

NEITHER MAKES NOR INTENDS, NOR DOES IT AUTHORIZE ANY AGENT OR REPRESENTATIVE 

TO MAKE, ANY OTHER WARRANTIES, EXPRESS OR IMPLIED, AND IT EXPRESSLY EXCLUDES 

AND DISCLAIMS ALL IMPLIED WARRANTIES OF MERCHANTABILITY OR FITNESS FOR A 

PARTICULAR PURPOSE. 

THIS WARRANTY DOES NOT EXTEND TO, AND THE BUYER SHALL BE SOLELY RESPONSIBLE 

FOR, ANY AND ALL LOSS OF DAMAGE WHICH RESULTS FROM THE USE OF THIS PRODUCT IN 

ANY MANNER WHICH IS INCONSISTENT WITH THE LABEL DIRECTIONS, WARNINGS, OR 

CAUTIONS. 

TO THE EXTENT CONSISTENT WITH APPLICABLE LAW, BUYER'S EXCLUSIVE REMEDY AND 

MANUFACTURER'S OR SELLER'S EXCLUSIVE LIABILITY FOR ANY AND ALL CLAIMS, LOSSES, 

DAMAGES OR INJURIES RESULTING FROM THE USE OR HANDLING OF THIS PRODUCT, 

WHETHER OR NOT BASED IN CONTRACT, NEGLIGENCE, STRICT LIABILITY IN TORT OR 

OTHERWISE SHALL BE LIMITED, AT THE MANUFACTURER'S OPTION TO REPLACEMENT OF, OR 

THE REPAYMENT OF THE PURCHASE PRICE FOR, THE QUANTITY OF PRODUCT WITH RESPECT 

TO WHICH DAMAGES ARE CLAIMED. IN NO EVENT SHALL MANUFACTURER OR SELLER BE 

LIABLE FOR SPECIAL, INDIRECT OR INCONSEQUENTIAL DAMAGES RESULTING FROM THE USE 

OR HANDLING OF THIS PRODUCT. 

To the extent consistent with applicable law, purchase of this material does not confer any rights under 

patents governing this product or the use thereof in countries outside of the United States. Seller's 

guarantee shall be limited to the terms set out on the label and subject thereto, the buyer assumes the 

risk to persons or property arising from the use or handling of this product on that condition. 

DISCLAIMER AND INDEMNITY FOR FORMULATORS' USES 

The manufacturer expressly disclaims all liability for claims and actions (whether based on contract, tort, 

strict liability, or breach of warranty) arising out of, resulting from or connected with a formulation 

containing this product when used for any purpose other than those uses set forth under item (1) under 

the Directions for Use heading. The manufacturer has not developed scientific data to support, nor has it 

explicitly or implicitly approved, any uses other than those listed under item (1) under the Directions for 

Use heading above. 

Any formulator or buyer who uses this product in formulations for any other than those stated in item (1) 

under the Directions for Use heading above, assumes all liability for claims and actions arising out of, 

connected with or resulting from such use and agrees by so using this product to indemnify and hold 

harmless the manufacturer from such claims and actions. 

This disclaimer and indemnity is in addition to, not in lieu of, the below disclaimer and limitations. 

Revised 8~5~09 

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Malerial to be added to an e-Jacket 

Reg. No. '6 30 ~8 - d.-. 

1. Placement within the e-Jacket: 

~ Default: chronological top 

<> Other: (PDF page number, i.e., "before page 45") 

2. Is this material: 

Newly stamped accepted label 

Notification (~J 

NewCSF 

Other: ___________________ _ 

3. Attach this notice on top ofthe material. It must 

be clipped all together, NOT STAPLED. Then give the 

material with this coversheet to staff in the Information 

Services Center (Room S-4900). 

Rev i ewe r's N am e: __ ----'D"'"'i'-"'a'-'-n"'a'-'H'-'-"'u'-"'d""s~oC!..!n'___ ______ _ 

Phone: 308-8713 Division: BPPD 

SEP 8 2009 

Date: _____________ -------------------

Created July 18/2008 
17

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2009 ~'-

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18

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 

Washington, D.C. 20460 

Rusty Millar 

Mauager Regulatory Affairs 

NCA Biotech, Inc. 

3406 Pomona Blvd. 

Pomona, CA 91768 

September 8, 2009 

RE: Product Name: Technical3-Indolebutyric Acid 

EPA Reg. No: 83028-2 

OFFICE OF 

PREVENTION, PESTICIDES 

AND TOXIC SUBSTANCES 

Application for Label Notification dated August 5, 2009 to Update Storage and Disposal per 

PR Notice 2007-4 

Dear Mr. Millar: 

The Biopesticides and Pollution Prevention Division is in receipt of your application for 

Notification under Pesticide Registration (PR) Notice 98-10 dated above. A preliminary screen ofthls 

request has been conducted for its applicability under PR Notice 98-10 and it has been detennined that 

the action(s) requested falls within the scope ofPR Notice 98-10. Our records have been duly noted, and 

the label submitted with this application has been stamped "Notification, received and reviewed" and 

will be placed accordingly in our records. 

Questions concerning this action should be directed to Ms. Diana Hudson at (703) 308-8713 or 

email at hudson.diana@epa.gov. 

Sincerely, 

Linda Hollis, Chief 

Biochemical Pesticides Branch 

Biopesticides and Pollution Prevention 

Division (751IP) 
19

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BIOTECH INC. NCA Biotech, INC. 

August 5, 2009 

Ms. Linda Hollis, Chief PM 91 

BPPD (751IP), Room S4900 

US Environmental Protection Agency 

One Potomac Yard 

2777 S Crystal Drive 

Arlington, VA 22202 

Subject: Technical 3·lndolebutyric Acidl'~~;~g,;fj;\\~§~O~~,2,,container Disposal per PRN 

2007·4 

Dear Ms. Hollis: 

This submission pertains to the amendments to the container disposal language required per PR 

Notice 2007-4. Per this notice an application fonn and four copies of the label are included 

with this submission. Changes are highlighted in red for your convenience. Please return a 

stamped copy of the label for our files. If you have any questions, please contact me. Thank 

you. 

Sincerely, 

Rusty Millar 

Mgr. Regulatory Affairs 

3,106 POMmJA BLVD- POfAONA CA 91?(ifj 

TeL: 90fU4R 5 t:l3 Fax fJ[)9,348.5135 

Email: info@ncahlo\8ch.com 

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Print Form " .... ~ M. ... ,.,. fonn. F ~ 'OD'.""'. OMS No . 

Unlted Stlta. ~ Registration oPp ldantifi.rNumb,r 

&EPA Environmental Protection Agency x Amendment 

Wuhlnoton. DC 20460 Other 

Application for Pesticide· Section I 

1. CompenylProduct Nv-nb" 2. EPA Product Managar 3. Propond CI •• ,me,tion 

NCA Biotech 83028'!l Linda Hollis 

0 NOM o Rntricted 4. ComplnvlProduct fNamal PM' 

NCA Biotech, Technical3-lndolebutyric Acid 91 

S. Nlma and AddrtJN of Appfic.nt Ilnr:luda ZIP Coda} 6. Expedited Review. In accordance with FIFRA Section 3(c)(3} 

(bIOI. my product is similar or identical in composition and labeling 

NCA Biotech, 3406 Pomona Blvd, Pomona, CA 91768 to: 

EPA Reg. No. 

o Ch,Ir:Jr. if this is • new addrU$ Product Name 

Section· " 

0 Amendnwnt - Explain balow. 0 Final printed label. in rllJPOn .. to 

Agency I,ttar datod 

0 R .. ubmluion In , .. pon .. to Agancylana, dated 0 -Me Too· Application. 

0 Notification - Explein btrlow. 0 Other' Expleln below. 

Explanation: u .. additional pagelellf nac".ary. IFor section lend Section 11.1 NOTifiCATION 

Updated Container Disposal Statement per PRN 2007-4 

Date Reviewed: 9 -8 -0 '1" 

Reviewed BY~ 

Section • III 

1. Meten.1 Thil Product WIlle Peekeoed In: 

Child-R .. i1Itent Peckaging Unit Peckeging Water Soluble Peokeg'lflg 2. Type of Contalnar 

~V'" Et· @ V .. 

~Mo'. Plntlc X N. N. N. Gle .. 

e CttrtiIic.tion must If -V,,- No. per If -Ve.- No. per X Pllpar 

Unit Peckaging wgt. conttrlner Peckllge wgt containar Other ISpecify) IH subtnltt.d 2.21bs I 

3. Location of Nat Contanle Inlormatlen 4. Si:i:elel Ratan Container 5. Locetion of Label [)irectiol'll! 

181 Lob. o Containar 2.21bs ~OnLabtrl On Labe~ng aceompllnying product 

6. Mannar in Whiah Ubel ie Affixed to Produot EtrthOgrSPh o Other 

paperfeUed StancO ed . ~ ~ . Section· IV . . 

. ~ .. 1. Contect Point .. . (Complara if_ diractly bll/ow flU id."tifictltion of individu., ro be t:Ollrecrlld, H nacanlll)', to proCilS$ this appli38tkm.(' 

N._ T", J'",I~:;mr,fMI No.llnclada Aree Codel 

Rusty Millar Mgr. !909:34}3.5133, , ••• > ., 

. ~ , " , Certmcation . 6. orte APplication , . , I cartify that the statemantl I have made on thilil form and l1li anecl'llnentll; thereto lire trua, eccurate and ConlPJlI,~., R?Clt'l\:eih , I aeknowladlJO that any knowingly fal •• or milleading stltamant mev ba punilhlbla bV fina or impriloNTUlnt or) , both uncler applicablllaw. " ) , , (Stamped) 

, , > , 

2. Signature j). ~-r.- ~ 3. Title , , 

, . , , 

Mgr. , 

, , , " 'tT ' ; , , 

4. Typed Nams 5,Oetl 

Rusty Millar August 5, 2009 

.. EPA Form 8570-1 IRav, 8-S41 PreVloul aclltloFII era obsolete . . VaDow . AppDCMt Copy 
21

\L)titicarioll of labd change pCI' P!{\ 200"-4. Tilb llotllic,lIion is Cllnsl~ten! \\ l[h the 

!:luidanee in P RN }()I)7-..:!- and tht.: reqUln-:mcnlS of EP:\ . ~ n.:~ul arion:; at ..J.!J C FR 5S 

156.10. 156.140. 156. J 44. 156.1..J.6, anti J 56.156. '\0 other chunges huvc heen made to 

Ihe labeling or (he Confidential Stulcnh:llI ufFoflllUhl j"tlr Ihis product. I (jlldcr~tand that 

it is a vtolation or 18 L.S.c. S(!C 1001 (l) \'.-Wfully nt,lkc <my false stutell1t:nl \() EPA, 1 

timher undcrsland that if the ant~ndcLilabd is not ctlnS!~!Cl\t \\ith ihe requirements of .. J.l) 

eFR 55 156.10. 156.I..J.O. i 56.144. 156.1..J.6. and) 56. ISh, tlli:> product nl<l~ he in 

\-lOlarion of FIFR.·\ and 1 rna) be subjel·t in L'lliOrCL'iIlCnl. action and pcnuitics under 

.~L'L'tiL)ns 11 unt! I,,), (If FlFR.-\. 

1 -

/?~$ /hv~~ 

Rusty.\1iilar 

\,Igr Regulatury i\I'fairs 

LT 8iosY11. Inc. 
22

! NOTIFICATION 

Date R9Vi9W9cta 

TECHNICAL 

PLANT 

3-INDOLEBUTYR'EeA~rD GROWTH REGULA TOR ~ FOR MANUFACTURING PURPOSES ONLY 

FORMULATORS WHO USE THIS PRODUCT ARE RESPONSIBLE 

FOR OBTAINING EPA REGISTRATION FOR THEIR FORMULATED PRODUCTS 

ACTIVE INGREDIENT: 

Indole-3-Butyric Acid ............. " .............................................................................................................. 98.00/0 

OTHER INGREDIENTS: ........................................................................................................................ 2.0% 

TOTAL: ............................................................................................................................................. 100.00/0 

EPA Reg. No. 83028-2 EPA Est. No. 72639-CHN-1 

If swallowed: 

If in eyes: 

If inhaled: 

If on skin or 

clothing: 

Manufactured for: 

NCA Biotech, Inc. 

3406 Pomona Blvd. 

Pomona, CA 91768 

KEEP OUT OF REACH OF CHILDREN 

WARNING 

FIRST AID 

• 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. 

• i 

• if present, after the first 5 minutes, then continue 

• i . 

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

respiration, preferably by mouth-to-mouth, if possible. 

I 

• i i . 

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

• I 

you when Ii a poison control or doctor, or 

information, calf NCA Biotech, Inc. at (909) 348-5133 between th'e' hburs 

, 

, , . 

" ) , , , 

... 

, ,>, " • , 

, , , , 

Net Weight:, 2.2 Lbs. " . '" , 
23

PRECAUTIONARY STATEMENTS 

HAZARDS TO HUMANS AND DOMESTIC ANIMALS 

WARNING. May be fatal jf swallowed, absorbed through skin, or inhaled. Causes substanlial but 

temporary eye injury. Causes skin irritation. Do not get in eyes, on skin, or on clothing. Do not breathe 

dust. Wash thoroughly with soap and water after handling and before eating, drinking, chewing gum or 

using tobacco. Wear the appropriate PPE: 

Coveralls (over long-sleeved shirt and long pants) 

• Chemical-resistant footwear 

• Chemical-res'rstant gloves 

• Goggles 

• DusUmist filtering respirator (MSHAINIOSH approval number prefix TC-21 C), or a NIOSH approved 

respirator with any N, R, P or HE filter. 

Remove and wash contaminated clothing before reuse. 

ENVIRONMENTAL HAZARDS 

Do not discharge effluent containing this product into lakes, streams, ponds, estuaries, oceans, or other 

waters unless in accordance with the requirements of a National Pollutant Discharge Elimination System 

(NPDES) permit and the permitting authority has been notified in writing prior to discharge. Do not 

discharge effluent containing this product to sewer systems without previously notifying the local sewage 

treatment plant authority. For guidance, contact your State Water Board or Regional Office of the EPA. 

Do not contaminate water when disposing of equipment washwaters or rinsate. 

DIRECTIONS FOR USE 

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

FOR MANUFACTURING USE ONLY 

Only for Formulation into a Plant Growth Regulator for (1) The Following Uses: Ornamental 

herbaceous plants, ornamental woody shrubs and vines, ornamental and/or shade trees, barley, beans, 

broccoli, Brussels sprouts, cabbage, cauliflower, citrus fruits, corn (field, sweet), cotton, cucumbers, 

lettuce, melons, mustard cabbage, mustard (leafy/stem crop), oats, onions, green onions, peanuts, peas, 

peppers, potatoes, rice, rye, sorghum, soybeans, spinach, squash, strawberries, sugar beets, sugarcane, 

tomato, turnip, wheat, golf course turf, ornamental lawns and turf. (2) Uses for Which USEPA has 

Accepted or Waived the Required Data and/or Citations of Data that the Formulator has Submitted 

in Support of Registration; and (3) Uses for Experimental Purposes that are in Compliance with 

USEPA Requirements. 

STORAGE AND DISPOSAL 

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

PESTICIDE STORAGE: Do not store with foodstuff. ' , , , 

PESTICIDE DISPOSAL: Waste resulting from the use of this product may be disposed of on site'C.'pat' an 

approved waste disposal facility. ' , , ' , 

CONTAINER DISPOSAL: Offer for recycling, if available. ,> , 

LIMITED WARRANTY AND DISCLAIMER 

" " " , " , 

, , , " ) 

, 

, , 

, '''>'' 

The manufacturer warrants that this product conforms to the chemical description on the label;: that:this 

product is reasonably fit for the purposes set forth in item (1) of the Directions for Us'e; w)-._en it is used in 

accordance with such Directions; and that the statements under item (1) of the Directions, the warnings 

and other statements on this label, other than the suggested uses under items (2) and (31 'cif the 

Direclions, are based upon responsible experts' evaluation of reasonable tests of effectiveness, of toxkity 

to laboratory animals and to plants, and of residues on food crops and upon reports of field exp~~i~rce. 

Tests have not been made on all varieties or in all states or under all condition. THE MANUFACTURER 

NEITHER MAKES NOR INTENDS, NOR DOES IT AUTHORIZE ANY AGENT OR REPRESENTATIVE 

2 
24

TO MAKE, ANY OTHER WARRANTIES, EXPRESS OR IMPLIED, AND IT EXPRESSLY EXCLUDES 

AND DISCLAIMS ALL IMPLIED WARRANTIES OF MERCHANTABILITY OR FITNESS FOR A 

PARTICULAR PURPOSE. 

THIS WARRANTY DOES NOT EXTEND TO, AND THE BUYER SHALL BE SOLELY RESPONSIBLE 

FOR, ANY AND ALL LOSS OF DAMAGE WHICH RESULTS FROM THE USE OF THIS PRODUCT IN 

ANY MANNER WHICH IS INCONSISTENT WITH THE LABEL DIRECTIONS, WARNINGS, OR 

CAUTIONS. 

TO THE EXTENT CONSISTENT WFTH APPLICABLE LAW, BUYER'S EXCLUSIVE REMEDY AND 

MANUFACTURER'S OR SELLER'S EXCLUSIVE LIABILITY FOR ANY AND ALL CLAIMS, LOSSES, 

DAMAGES OR INJURIES RESULTING FROM THE USE OR HANDLING OF THIS PRODUCT, 

WHETHER OR NOT BASED IN CONTRACT, NEGLIGENCE, STRICT LIABILITY IN TORT OR 

OTHERWISE SHALL BE LIMITED, AT THE MANUFACTURER'S OPTION TO REPLACEMENT OF, OR 

THE REPAYMENT OF THE PURCHASE PRICE FOR, THE QUANTITY OF PRODUCT WITH RESPECT 

TO WHICH DAMAGES ARE CLAIMED. IN NO EVENT SHALL MANUFACTURER OR SELLER BE 

LIABLE FOR SPECIAL, INDIRECT OR INCONSEQUENTIAL DAMAGES RESULTING FROM THE USE 

OR HANDLING OF THIS PRODUCT. 

To the extent consistent with applicable law, purchase of this material does not confer any rights under 

patents governing this product or the use thereof in countries outside of the United States. Seller's 

guarantee shall be limited to the terms set out on the label and subject thereto, the buyer assumes the 

risk to persons or property ariSing from the use or handling of this product on that condition. 

DISCLAIMER AND INDEMNITY FOR FORMULATORS' USES 

The manufacturer expressly disC/aims all liability for claims and actions (whether based on contract, tort, 

strict liability, or breach of warranty) arising out of, resulting from or connected wilh a formulation 

containing this product when used for any purpose other than those uses set forth under item (1) under 

the Directions for Use heading. The manufacturer has not developed scientific data to support, nor has it 

explicitly or impliCitly approved, any uses other Ihan those listed under item (1) under the Direclions for 

Use heading above. 

Any fonnulator or buyer who uses this product in formulations for any other than those stated in ilem (1) 

under the DirecJions for Use heading above, assumes all liability for claims and actions arising out of, 

connected with or resulting from such use and agrees by so using this product to indemnify and hold 

harmless the manufacturer from such claims and actions. 

This disclaimer and indemnity is in addition to, not in lieu of, the below disclaimer and limitations. 

Revised 8-5-09 

", J , , 

, " , , 

" " , , , , 

" , " , , " " 

, , > > 

" > > 

, , " , 

", , , , , , 

, " , , 

3 
25

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 

WASHINGTON, D.C. 20460 

February 16, 2007 

opp Decision Number: D~374969 

EPA File Symbol or Registration Number: 83028-~ 

Product Name: TECHNICAL 3-INDOLEBUTYRIC ACID 

EPA Receipt Date: 09-Feb-2007 

EPA Company Number: 83028 

Company Name: NCA BIOTECH, INC. 

DER-IWANG 

NCA BIOTECH, INC. 

3406 POMONA BLVD. 

POMONA, CA 91768-

OFFICE OF 

PREVENTION, PESTICIDES AND 

TOXIC SUBSTANCES 

SUBJECT: Receipt of Registration Application and 100% Small Business Waiver Request 

Dear Registrant: 

The Office of Pesticide Programs has received your application for registration and 100% 

small business waiver request. If you submitted data with this application, the results of the 

PRN-86-5 screen will be communicated separately. During the administrative screen, the Office 

of Pesticide Programs has determined that this Action is subject to a Pesticide Registration 

Service Fee as defined in the Pesticide Registration Improvement Act. 

The Action has been identified as Action Code: B66 

ME-TOO;NEW PRODUCT;MICROBIALIBIOCHEMICAL;F AST-TRACK; 

Your request for waiver has been furwarded for review. You will be notified in writing 

when a detennination is made regarding your request. If the determination indicates that 

payment is due, you will receive instructions, for submitting payment at that time. 

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

Ombudsman, at (703) 308-8260. 

Sincerely, 

ology & Resources Management Division 
26

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 

WASHINGTON, D.C. 20460 

March 13, 2007 

OPP Decision Number: D·374969 . 

EPA File Symbol or Registration Number: 83028·E 

Product Name: TECHNICAL 3·INDOLEBUTYRIC ACID 

EPA Application Receipt Date: 09·Feb·2007 

EPA Waiver Request Receipt date: 09·Feb02997 

EPA Company Number: 83028 

Company Name: NCABIOTECH, INC. 

DER·IWANG 

NCA BIOTECH, INC. 

3406 POMONA BL YD. 

POMONA, CA 91768· 

SUBJECT: Approval of 100% Small Business Waiver Request 

Dear Registrant: 

OFFlCEOF 

PREVENTION, PESTICIDES AND 

TOXIC SUBSTANCES 

The Office of Pesticide Programs has approved your request for 100% waiver of the 

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

period for this action begins on the date of this letter. 

The Action has been identified as Action Code: B66 

ME-TOO;NEW PRODUCT;MICROBIAIJBIOCHEMICAL;FAST· TRACK; 

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

Ombudsman, at (703) 308·8098 

Si~U 

0>( Arnold E. Layne, Director 

Infonnation Technology & Resources Management Division 
27

U.S. ENVIRONMENTAL PROTECTION AGENCY 

Office of Pesticide Programs 

Biopesticides and Pollution Prevention Division (7511C) 

1200 Pennsylvania Avenue NW 

Washington, DC 20460 

NOTICE OF PESTICIDE: 

Name and Mdress ofRegistraOI (include ZIP Code): 

NCA Biotech, Inc. 

c/o Pyxis Regulatory Consulting, Inc. 

4110 136th Street. NW 

Gig Harbor, WA 98332 

..K... Registration 

__ Reregistration 

(under FtFRA. as amended) 

EPA Reg. Number: Oale oftssuance: 

83028-2 

Tenn oftssuance: Unconditional 

Name of Pes lie ide ProduCl: 

Technica13-Indolebutyric Acid 

Note: changes in labeling dif(cii:ng in'substance 'from that accCPtc4'in cpnn\l9t10n '~ih'thls Teiistrilnott inust ·ijCSilbihlttM to:anif accCt'te;j-by ti!;e ',',. ; 

:Biopestlcide.lriind Pollution Prevo;mtioil Division prior to use ofUic' .1abdin eotPID~e.· '1D.' wi.)/p;.~0xlriDce oil thls·proouc.t 3lWilysicfe{k; tJte 'above . EPAregisnatlonoumber. . ;';. .... . " .. ,.... , ,,-:' .,',' < ':"" 

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

Fungicide and Rodenticide Act. 

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

environment, the Administrator, on his motion, may at any time suspend or cancel the registration of a pesticide in accordance witb the Act. The 

acceptance ofany name in connect "ton with the registration of a product under this Act is not to be construed as giving the registrant a right to exclusive 

use of the name orto its use if it bas been covered by others. 

TIlls registration does not eliminate the need for continual reassessment of the pesticide. If EPA detennines at 

any time, that additional data are required to maintain in effect an existing registration, the Agency will require 

submission of such data under section 3(c)(2)(B) ofFIFRA 

TIlls product is registered in accordance with FIFRA section 3(c)(5) and is subject to the following tenns and 

conditions: 

1. Make the following modification to your label before you release your product for shipment: 

Change the EPA File Symbol to read EPA Reg. No. 83028~2. 

2. Submit three (3) copies of the final printed labeling before you release the product for shipment. 

Refer to the A~ 79 enclosure for a further description of final printed labeling. 

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

siSi; ~fAPP»;;J JnC/)sr Dale: 

IN. />I;cJw.eJ f1cV ... ;f I I'ksDC ]),',-

EPA Fonn 8570·{) 
28

TECHNICAL 3-INDOLEBUTYRIC ACID 

PLANT GROWTH REGULATOR 

FOR MANUFACTURING PURPOSES ONLY 

FORMULATORS WHO USE THIS PRODUCT ARE RESPONSIBLE 

FOR OBTAINING EPA REGISTRATION FOR THEIR FORMULATED PRODUCTS 

ACTIVE INGREDIENT' 

tndole-3-Butyric Acid .......................................................... ., ................................................................. 98.0% 

OTHER INGREDIENTS: ......................................................................................................................... 2.00/0 

TOTAL: ............................................................................................................................................... 1 00.00/0 

EPA Reg. No. 83028- -

~ 

EPA Est. No. 

If swallowed: 

Ifin eyes: 

If inhaled: 

Ifon skin or 

clothing: 

KEEP OUT OF REACH OF CHILDREN 

WARNING 

FIRST AID 

• 

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

• Do not induce vomiting unless teld to do so by the poison control center or 

doctor. 

• I eye open i =2cimiinUtes:--1 

• Remove contact lenses, if present, after the first 5 minutes, then continue 

rinsing eye. 

II 

• person 

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

respiration, preferably by mouth-te-mouth, if possible. 

• It I 

• i 

• Rinse skin immediately with for 15-20 minutes. 

• I I 

~~!:::~~::::~o~r;I:~~i ~yo~u~~ It' or ,or f II I product information, call NCA Biotech, Inc. at (909) 348-5133 between the hours 

Manufactured for: 

NCA Biotech, Inc. 

3406 Pomona Blvd. 

Pomona, CA 91768 

, > , , 

> "; 

, , H , 

. . """, 

. 

, , " , , , 

Net Weigh1: 2.2 L6S. 

" . " , , . 

. ~ .... , ., . . 
29

\, 

PRECAUTIONARY STATEMENTS 

HAZARDS TO HUMANS AND DOMESTIC ANIMALS 

WARNING. May be fatal if swallowed, absorbed through skin, or inhaled. Causes substantial but 

temporary eye injury. Causes skin irritation. Do not get in eyes, on skin, or on clothing. Do not breathe 

dust. Wash thoroughly with soap and water after handling and before eating, 'drinking, chewing gum or 

using tobacco. Wear the appropriate PPE: 

Coveralls (over long-sleeved shirt and long pants) 

• Chemical-resistant footwear 

• Chemical-resistant gloves 

• Goggles 

• Dust/mist filtering respirator (MSHAfNIOSH approval number prefix TC-21C), or a NIOSH approved 

respirator with any N, R, P or HE filter. 

Remove and wash contaminated clothing before reuse. 

ENVIRONMENTAL HAZARDS 

Do not discharge effluent containing th'IS product into lakes, streams, ponds, estuaries, oceans, or other 

waters unless in accordance with the requirements of a National Pollutant Discharge Elimination System 

(NPDES) pennit and the permitting authority has been notified in writing prior to discharge. Do not 

discharge effluent containing this product to sewer systems without previously notifying the local sewage 

treatment plant authority. For gUidance, contact your State Water Board or Regional Office of the EPA. 

Do not contaminate water when disposing of equipment washwaters or rinsate. 

DIRECTIONS FOR USE 

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

FOR MANUFACTURING USE ONLY 

Only for Formulation into a Plant Growth Regulator for (1) The Following Uses: Ornamental 

herbaceous plants, ornamental woody shrubs and vines, ornamental and/or shade trees, barley, beans, 

broccoli, Brussels sprouts, cabbage, cauliflower, citrus fruits, com (field, sweet), cotton, cucumbers, 

lettuce, melons, mustard cabbage, mustard (leafy/stem crop), oats, onions, green onions, peanuts, peas, 

peppers, potatoes, rice, rye, sorghum, soybeans, spinach, squash, strawberries, sugar beets, sugarcane, 

tomato, turnip, wheat, golf course tuli, ornamental lawns and tuli. (2) Uses for Which USEPA has 

Accepted or Waived the Required Data and/or Citations of Data that the Formulator has Submitted 

in Support of Registration; and (3) Uses for Experimental Purposes that are in Compliance with 

USEPA Requirements. 

STORAGE AND DISPOSAL 

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

PESTICIDE STORAGE: Do not store with foodstuff. 

PESTICIDE DISPOSAL: Waste resulting from the use of this product may be disposed of on site or at an 

approved waste disposal facility. 

CONTAINER DISPOSAL: Triple rinse (or equivalent). Then offer for recycling or reconditioning, or 

puncture and dispose of in a sanitary landfill or, by other procedures approved by state and local 

authorities. 

LIMITED WARRANTY AND DISCLAIMER 

The manufacturer warrants that this product conforms to the chemical description on the label; that this 

product is reasonably fit for the purposes set forth in item (1) of the Directions for Use when it is used in 

accordance with such Directions; and that the statements under item (1) of the Directions, the wamings 

and other statements on this label, other than the suggested uses under items (2) and (3) of the 

Directions, are based upon responsible experts' evaluation of reasonable tests of effectiveness, of toxicity 

to laboratory animals and to plants, and of residues on food crops and upon reports of field experience. 

2 
30

Tests have not been made on all varieties or in all states or under all condition. THE MANUFACTURER 

NEITHER MAKES NOR INTENDS, NOR DOES IT AUTHORIZE ANY AGENT OR REPRESENTATIVE 

TO MAKE, ANY OTHER WARRANTIES, EXPRESS OR IMPLIED, AND IT EXPRESSLY EXCLUDES 

AND DISCLAIMS ALL IMPLIED WARRANTIES OF MERCHANTABILITY OR FITNESS FOR A 

PARTICULAR PURPOSE. 

THIS WARRANTY DOES NOT EXTEND TO, AND THE BUYER SHALL BE SOLELY RESPONSIBLE 

FOR, ANY AND ALL LOSS OF DAMAGE WHICH RESULTS FROM THE USE OF THIS PRODUCT IN 

ANY MANNER WHICH IS INCONSISTENT WITH THE LABEL DIRECTIONS, WARNINGS, OR 

CAUTIONS. 

TO THE EXTENT CONSISTENT WITH APPLICABLE LAW, BUYER'S EXCLUSIVE REMEDY AND 

MANUFACTURER'S OR SELLER'S EXCLUSIVE LIABILITY FOR ANY AND ALL CLAIMS, LOSSES, 

DAMAGES OR INJURIES RESULTING FROM THE USE OR HANDLING OF THIS PRODUCT, 

WHETHER OR NOT BASED IN CONTRACT, NEGLIGENCE, STRICT LIABILITY IN TORT OR 

OTHERWISE SHALL BE LIMITED, AT THE MANUFACTURER'S OPTION TO REPLACEMENT OF, OR 

THE REPAYMENT OF THE PURCHASE PRICE FOR, THE QUANTITY OF PRODUCT WITH RESPECT 

TO WHICH DAMAGES ARE CLAIMED. IN NO EVENT SHALL MANUFACTURER OR SELLER BE 

LIABLE FOR SPECIAL, INDIRECT OR INCONSEQUENTIAL DAMAGES RESULTING FROM THE USE 

OR HANDLING OF THIS PRODUCT. 

To the extent consistent with applicable law, purchase of this material does not confer any rights under 

patents governing this product or the use thereof in countries outside of the United States. Seller'S 

guarantee shall be limited to the terms set out on the label and subject thereto, the buyer assumes the 

risk to persons or property arising from the use or handling of this product on that condition. 

DISCLAIMER AND INDEMNITY FOR FORMULATORS' USES 

The manufacturer expressly disclaims all liability for claims and actions (whether based on contract, tort, 

strict liability, or breach of warranty) arising out of, resulting from or connected with a formulation 

containing this product when used for any purpose other than those uses set forth under item (1) under 

the Directions for Use heading. The manufacturer has not developed scientific data to support, nor has it 

explicitly or implicitly approved, any uses other than those listed under item (1) under the Directions for 

Use heading above. 

Any formulator or buyer who uses this product in formulations for any other than those stated in item (1) 

under the Directions for Use heading above, assumes all liability for claims and actions arising out of, 

connected with or resulting from such use and agrees by so using this product to indemnify and hold 

harmless the manufacturer from such claims and actions. 

This disclaimer and indemnity is in addition to, not in lieu of, the below disclaimer and limitations. 

3 
31

Hi Mike, 

\ 

Chris pfeifer/DClUSEPAIUS 

05/t4/2007 03:28 PM 

To "Mike Kellogg H <Mike@PyxisRC.com> 

cc 

bee 

Subject Re; Revised labeling for Technical 3·lndolebutyric Acid[g] 

I've attached a Word copy of your label containing a label review below. You'll find the nature of the label 

issues in the comment box. Many of the comments are in shorthand, but I believe they are 

understandable. To the degree they are no~ Please call or write. I think you'D find, for the most part, 

these smaD corrections are easily made. Once we have these issues ironed ou~ I'll be ready to pass your 

application on to an Administrator for signature. 

TECHNICAL 3.doc 

Regards, 

Chris 

EPA BPPD 

703-308-0031 
32

TECHNICAL 3-INDOLEBUTYRIC ACID 

Plant Growth rFr-""liilitot, ... 119 ..•.•.. , FOR MANUFACTURING PURPOSES ONLY 

FORMULATORS WHO USE THIS PRODUCT ARE RESPONSIBLE 

FOR OBTAINING EPA REGISTAAnON FOR THEIR FORMULATED PRODUCTS 

ACTIVE INGREDIENT: 

Indole·S·Butyric 

Acid ......................................................................................................................... 98.0% 

OTHER 

INGREDIENTS: ........................................................................................................................ 2.J!L§ 

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

100.0% 

EPA Reg. No. 83028- EPA Est. No. 

KEEP OUT OF REACH OF CHILDREN 

" W(~NING' .J/ 

FIRST AID 

If swallowed: 

• Call a poison control center or doctor immediatelyfor 

treatment advice. 

• Have person sip a glass ot water it able to swallow. 

• Do not Induce vomiting unless told to do so by the poison 

control center or doctor. 

• Do not give anything by mouth to an unconscious person. 

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 inhaled: 

• Move person to tresh air. 

• 1\ person Is not breathing, call 91t or an ambulance, then 

give artificial respiration, preferably by mouth-to-mouth, if possible. 

• Call a poison control center or doctor tor further treatment 

advice. 

If on skin or 

clothing: • Take off contaminated clothing. 

• Rinse skin immediately with plenty of water tor t5-20 

minutes. 

• Cali a poison control center or doctorfor treatment advice. 

HOT LINE NUMBER 

Have the product container or label with you when calling a poison control center or doctor, 

or going tor treatment. For general product information, call NCA Biotech, Inc. at (909) 348-

5t33 between the hours of 9 a.m. - 4 p.m. Pacific Time. 
33

PRECAUTIONARY slf4\11feI\l!Etliliis 

HAZARDS TO HUMANS AND DOMESficANIMA[S~ Warning. May be fatal jf swallowed, absorbed through skin or inhaled. Causes 

substantial but temporary eye injury. Causes skin irritation. Do not get in eyes, 

on skin, or on clothing. Do not breathe dust. Wash thoroughly with soap and 

water after handling and before eating, drinking, chewing gum or using tobacco. 

Wear the appropriate PPE: . 

• Coveralls (over long sleeved shit and long pants) 

• Chemical-resistant footwear 

• Chemical-resistant gloves 

• Goggles 

• DusVmlst fflteringrespirator (MSHAINIOSH approval number prefix Te- 21 C), 

or a NIOSH approved respirator with any N, R, P or HE filter 

Remove and wash contaminated clothing before reuse:. 

Manufactured for: Net Weight: 

NCA Biotech, Inc. Lbs. 

3406 Pomona B!vd. 

Pomona, 

2 

CA 

ENVIRONMENTAL HAZARDS 

91768 

Do not discharge effluent containing this product into lakes, streams, ponds, estuaries, oceans, or 

other waters unless in accordance with the requirements of a National Pollutant Discharge 

Elimination System (NPDES) permit and the permitting authority has been notified in writing prior 

to discharge. Do not discharge effluent containing this product to sewer systems without 

previously notifying the local sewage treatment plant authority. For guidance, contact your State 

Water Board 0r Regional Omce of the :E"pl( P9 not cPrltal:ninate YI'.ate.r Vl'.he!", clis'po~ing .. of 

equipment washwaters or rinsate. 

BlRECTIONS FOR lisE 

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

FOR MANUFACTURING USE ONLY 

Only for Formulation tnto a Plant Growth Regulator for (1) The Following Uses: Ornamental 

herbaceous plants, ornamental woody shrubs and vines, ornamental and/or shade trees, barley, 

beans, broccoli, Brussels sprouts, cabbage, cauliflower, citrus fruits, corn (field, sweet), cotton, 

cucumbers, lettuce, melons, mustard cabbage, mustard (leafy/stem crop), oats, onions, green 

onions, peanuts, peas, peppers, potatoes, rice, rye, sorghum, soybeans, spinach, squash, 

strawberries, sugar beets, sugarcane, tomato, turnip, wheat, golf cOUrse tuti, ornamental lawns 

and tuti. (2) Uses for Which USEPA has Accepted or Watved the Required Data and/or 

Citations of Data that the Formulator has Submitted In Support of Registration; and (3) 

Uses for Experimental Purposes that are fn Compliance with USEPA Requirements. 

STORAGE AND DISPOSAL 

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

PESTtCIDE STORAGE: Do not store with foodstuff. 

"Com!M:!j:t·t}41: .Edited "I~ rictUee ·"ii::Dte~midJor.orde( ". ,. " 

::"~o~:~t" U!il::diaii~" ilrdii"nnlL.; ..... j. 

·~·AlittlebOikrplitle";::,·"';,'·>" .->;. " . 

{~mm;mt fj71:Jtelative:piomm;;n6e:" .J 
34

PESTICIDE DISPOSAL: Waste resulting from the use of this product may be disposed of on site 

or at an approved waste disposal facility. 

CONTAINER DISPOSAL: Triple rinse (or equivalent). Then offer for recycling or reconditioning, 

or puncture and dispose of in a sanitary landtill or, by other procedures approved by state and 

local·aJJfho·riii~.' 

DISCLAIMER AND INDEMNITY FOR FORMULATORS' ,!ltt;~§" __________ _ 

The manufacturer expressly disclaims all liability for claims and actions (whether based on 

contract, tort, strict Hability, or breach of warranty) arising out of, resulting from or connected with 

a formulation containing this product when used tor any purpose other than those uses set forth 

in (t) above. The manufacturer has not developed scient'lflc data to support, nor has it explicitly or 

implicitly approved, any uses other than those in (t) above. 

Any formulator or buyer who uses this product in formulations tor any other than those stated in 

(t) above assumes all liability for claims and actions ariSing out of, connected with or resulting 

from such use and agrees by so using this product to indemnify and hold harmless the 

manufacturer from such claims and actions. 

This disclaimer and indemnity is in addition to, not in lieu of, the below dlsdaimer arK! limitations. 

UMITED WARRANTY AND DISCLAIMER 

The manutacturer warrants that this product conforms to the chemical description on the label; 

that this product is reasonably fit tor the purposes set forth in item (1) of the Directions for Use 

when it is used in accordance with such Directions; and that the statements under item (t) of the 

Directions, the warnings and other statements on this label, other than the suggested uses under 

items (2) and (3) of the Directions, are based upon responsible experts' evaluation of reasonable 

tests of etfectiveness, of toxicity to laboratory animals and to plants, and of residues on food 

crops and upon reports of field experience. Tests have not been made on all varieties or in all 

states or under all condition. THE MANUFACTURER NEITHER MAKES NOR INTENDS, NOR 

DOES IT AUTHORIZE ANY AGENT OR REPRESENTATIVE TO MAKE, ANY OTHER 

WARRANTIES, EXPRESS OR IMPLIED, AND IT EXPRESSLY EXCLUDES AND DISCLAIMS 

ALL IMPLIED WARRANTIES OF MERCHANTABILITY OR FITNESS FOR A PARTICULAR 

PURPOSE. 

THIS WARRANTY DOES NOT EXTEND TO, AND THE BUYER SHALL BE SOLELY 

RESPONSIBLE FOR, ANY AND ALL LOSS OF DAMAGE WHICH RESULTS FROM THE USE 

OF THIS PRODUCT IN ANY MANNER WHICH IS INCONSISTENT WITH THE LABEL 

DIRECTIONS, WARNINGS, OR CAUTIONS. 

TO THE EXTENT CONSISTENT WITH APPLICABLE LAW, BUYER'S EXCLUSIVE REMEDY 

AND MANUFACTURER'S OR SELLER'S EXCLUSIVE LIABILITY FOR ANY AND ALL CLAIMS, 

LOSSES, DAMAGES OR INJURIES RESULTING FROM THE USE OR HANDLING OF THIS 

PRODUCT, WHETHER OR NOT BASED IN CONTRACT, NEGLIGENCE, STRICT LIABILITY IN 

TORT OR OTHERWISE SHALL BE LIMITED, AT THE MANUFACTURER'S OPTION TO 

REPLACEMENT OF, OR THE REPAYMENT OF THE PURCHASE PRICE FOR, THE 

QUANTITY OF PRODUCT WITH RESPECT TO WHICH DAMAGES ARE CLAIMED. IN NO 

EVENT SHALL MANUFACTURER OR SELLER BE LIABLE 

3 

FOR SPECIAL, INDIRECT OR INCONSEQUENTIAL DAMAGES RESULTING FROM THE USE 

OR HANDLING OF THIS PRODUCT. 

NonCE TO BUYER 

Purchase of this material does not confer any rights under patents governing this product or the 

use thereat in countries outside of the United States. Seller's guarantee shall be limited to the 

terms set out on the label and subject thereto, the buyer assumes the risk to persons or property 

arising from the use or handling of this product on that condition. 
35

N on Fa~ )(';JC;)c kaM C )J'. 66 

J; 

SJ::Z-1 c>1 

~ 
36

JACKETS (Fileroom Document Tracking System) 

Requested Jackets Report (New Requests) 

Requested by : Hollis, Linda 

Agency: EPA Office: OPPTS Program: OPP 

Division: BPPD Branch: BPB 

Requested on 21-Feb-2007 at 08:44 AM 

Jacket Regulatory 

Barcode Case File # 

9272339 83028-E 

Volffot Location 

1 / 1 File Rm: 67/ A / 01 / 1 

Total # of jackets requested: 1 

21-Feb-2007 

8:47 AM 

Collins, Lillie 

Barcode: 21097 

Page 1 of 1 

Group Num: 134147 

Status 

Under Review (13-Feb-2007) 

Completed: ~ Date: 

g~7 Time: ___ _ 

Hollis, Linda 
37

BPPD SCREEN PACKAGE 

BPPD FRONT END: BPB/MPB: TRader: 1· 6/0 ' 

Pria CodelAction Code: J?:~,(P" TearnlRAL:. __ 

~ I~., .. ~ ---r"" I J / Jr, ,/I ,) ProductName:~'=:.,Vhn,c.-;3.-' '.:;7"'-d-tJ£]olel9u, lYiG /VC-t 

EPA ID No.: -&,30.zg:" Ii' . . Active In dient(S):/C'k;JL,"-3.- . I M. __ . _____ _ Food New Submission 

Non Food Reseubmission 

Dale In BPPD: 3/1 Cc/t'-1t:_· __ 

Date To Screen: ( / 

Date Expected From Scree~: (10 days from date in): I ~1jo 1 WA#!J~ .~ Ztr . Nmin Begllm N ~ ?J~jMnAct. HOll" -/ Ret',rc. '0 BPPD: t] {zr;/6 '1 

Received Date from Contactor: 3Pr.e/OZ ~ 

SCREEN PACKAGE NOTES: 

Pre~ Reg Meetings attached? Yes -'-- No 

Submission co~p.li~s with. all applicable areas of checklists? Indicate in detail on checklists 

forms when returned. 

Additional Comments per Team Leader or Screener: 

SCREEN STATUS 

Administrative:. ; Fail -- Scientl fic: ___ Fail 

_______ Conditionally Pass 

... -_._--------
38

ATTACHMENT 1 

Administrative Material Screening Checklist 

Date: 3123/07 

EPA Reg. No. : 83028-E ; Priority COde: B-66 

Active ingredient name: IBA 

Division RAL assigned (if any): 

PASS 

Admin MaterialS Signed Date· . . 

Yes N 

0 

Form 8570-1 X 2/8/07 

CSF . Completely filled out & X 2/8/07 

original signature (EPA form 

8570-4) Y 

· inerts cleared? y 

· conventional or 

antimicrobial actives Y 

present in formulation? 

· accurate information y 

provided for 

suppliers/source? 

CSF accurately reflects 

label? 

Additional brand name 

listed in CSF 

· note all comments 

Method of Support, if so state X 2/8/07 

Which 

Label 

legible product label? 

· label accurately reflects 

csf? 

note all comments 

Physical address of manufacturer 

on label 

Abs Comments 

ent 

·Application is for a TGAI 

registration using one 

registered AI (IBAl. The 

registered product is 72639· 

1 (by Lt Bioscience) 

·requested to be me·too 

product 

. There is no inert listed in 

the CSF 

. listed as 

impurities in the "purpose of 

formulation" list 

·yes 

·no additional brand name 

present in the CSF 

selective 

Yes 

Yes 

yes 

Yes 

*Manufacturing process information may be entitled to confidential treatment*
39

.. .. . 

Admin MaterialS Signed Date Abs Comments ... ent 

Data Matrix, Tw%ne for jacket; X 2/8/07 Yes 

one for FOIA (EPA Form 8570-35) 

supports methOd of 

support? 

· reflects information 

reported in transmittal 

document and company 

cover letter? 

· note a II comments 

Formulator's exemption fOrm 

(EPA form 8570-27) 

Transmittal letters X 2/8/07 

accurately reflects what is 

reported on data matrix? 

· note all comments 

Petition/amended petition if IBA has exemption of 

food tolerance or requirement for tOlerance 

exemption/amended food 

tolerance or exemption 

· petition# assigned? 

· petition jacket included? 

· petition complete with 

sections A-G? 

· note all comments - if 

there is not evidence Of a 

petition # assigned and 

sect A-G not present, 

package fails. 

FR template iffoOd tolerance or 40 CFR180.1058 (fOr IBA) 

exemption/amended food 

tolerance or exemption 

notice Of filing template 

(disk) included? 

· note all comments - a NOF 

must be present to 

establish a new tolerance 

exemption. Amendments 

to an existing tOL petition 

may be Agency initiated in 

which case a NOF wOUld 

not expected to be 

present (If unsure, Check 
40

Admin Materials • Signed Date Abs 

ent 

with branch team leader) 

component in the 

formulation not cleared 

food use 

Certification With Respect to X 2/8/07 

citation of Data Form (EPA Form 

8570-34) - if required 

Minutes on data requirements 

(pre-registration meeting) 

Active ingredient # (i.e. Chemical 

PC code) 

· more than one active? 

· are all actives housed in 

BPPD? 

Jacketfrom EPA Identifying 

Symbol 

Are MRIDS assigned? (state 

YeslNo in comments) 

Background Experimental Use 

Permit information, if applicable 

· request for temporary tol. 

exempt, tol. exemption or 

numeric tolerance? 

note all comments - refer 

to petition and fr section 

for Critera_ 

CHECKLIST FOR DATA PACKAGE SCIENCE SCREEN 

Active Ingredients: 3-ffiA 

PC code: 46701 

Product Name: Technical3-IBA 

EPA Reg. NolFile Symbol: 83028-E 

Petition # (if applicable): 

(Circle or Check Appropriate Boxes) 

Comments 

Selective. Willing to pay 

compensation to data 

owner 

PC Codes: IBA; 46701; single 

active ingredient housed in 

BPPD 

83028-E 

Y 

NA 
41

ochemical, or PIP 

Jod Use 

L~,idop'''nm pheromone 

,:-w Active Ingredient 

~c. 3 Registration 

<:perimental Use Pennit 

.-4 Submission 

ethyl Bromide Alternative 

:duced Risk Product 

lta Requirement 

oduct Label 

;F 

millct 

Process 

~scription of the Fonnation of 

Ipurities 

eliminary Analysis 

:rtified Limits 

Methods 

lYSicallChemical Properties (as shown 

40 CFR 158.190Table) 

B M 

y 

N 

N 

y 

N 

N 

N 

y 

Product Specific htfonnation 

TGAI MP EP 

Product Chemistry 

y 

y 

y 

y 

y 

y 

Tier I Toxicity (If no study, indicate in Comments if waiver submitted) 

:;ute Oral Study 

~ute Dermal Study 

~ute Inhalation 

~., I.P., I.V. Injection (Microbial 

Data Matrix 
42

imary Dermal Irritation Study cited in MRID#4S4S34~OS in the Data Matrix 

imary Eye Irritation Study cited in MRID#4S4S34~04 in the Data Matrix 

ypersensitivity 

:onditionally required) 

ypersensitivity Incidents Study cited in MRID#4S4S34~06 in the Data Matrix 

:onditionally required) 

~notoxicity Studies (Biochemical 

uy) 

mlUne Response Claimed "The RED does not list this data requirement 

,according to NPIRS iIrumme response data or 

subcmonic data have been submitted on the teclmical 

product, therefore the requirement is considered 

waived" 

ssue Culture 

ficrobial only) 

I~day Feeding Claimed "The RED does not list this data requirement 

,iochemicalonly) ,according to NPIRS immune response data or 

subcbronic data have been submitted on the teclmical 

product, therefore the requirement is considered 

waived" 

I-day Dermal 

:iochemical only) 

I-day Inhalation Claimed "The RED does not list this data requirement 

,iochemical only) ,according to NPIRS immune response data or 

subcmonic data have been submitted on the technical 

product, therefore the requirement is considered 

waived" 

:ratogenicity/developmental toxicity Generic data req.is waived, Claimed "The RED does 

not list this data requirement ,according to NPIRS :iochemical only) inuntme response data or subcbronic data have been 

submitted on the technical product, therefore the 

requirement is considered waived" 

Tier I Non-Target Organisms (If no study, indicate in Comments if waiver submitted) 

vian Acute Oral 430267-01 submitted in response to data call-in for 

RED 

"ian Acute Dietary 430267-03, and -04 are submitted in response to data 

call-in for RED 

eshwater Fish LCSO Study cited in MRID#460S44-01 in the data matrix 

eshwater Invertebrate LCSO Study cited in MRID#460S44-02 in the data matrix 

)n-target Plants 

m-Target Insects 
43

)neybee Testing 

ficrobials only) 

Other Studies [As required by product specific data requirements(e.g. efficacy, residues) 
44

Science Screen Comment Form 

Active Ingredient and PC code: 3-IBA: 46701 

Product Name: Technica13-Indolebutyric acid 

RAL: 

Status: PASS 

THIS FORM DOES NOT CONTAIN CONFIDENTIAL BUSINESS INFORMATION 

Product Chemistry: 

Data requirement is addressed by cited studies appears to be adequate. For details please see above fonn. 

Toxicity: 

Data requirement is not addressed by cited studies seems to be adequate 

Non-target Organisms! Environmental Fate: 

Data requirement is not addressed. by cited studies seems to be adequate. 

Product Performance (Efficacy): 

Not required. 

Residue 

Exemption of requirement of tolerance exist for IBA 

Other non guideline or supplemental information: 

CommentslRecommendations: 
45

NEW APPLICATIONS 

DATE: FEB -9 20l 

FILE NUMBER: _---=g..::....3(.;.....~ 9._. g~-_t: __ 

FEP (OPPIN ENTRY)' ,(v vF3( 01 , 

(Initial & date) 

FILE ROOM: _--'-'"_---

(Initial & date) 

SIG: ""~ 

(Initial & date. 

(! FILE ROOM: --1-7'<.,-:-------1.4=-"--

. Initial & date) 

v ASSIGN TO PM .' 91. (NO DATA) 

__ JACKET TO SHELF (DATA) 
46

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 

WASHINGTON, D.C. 20460 

February 16, 2007 

Opp Decision Number: D-374969 

EPA File Symbol or Registration Number: 83028-E 

Product Name: TECHNICAL 3-INDOLEBUTYRIC ACID 

EPA Receipt Date: 09-Feb-2007 

EPA Company Number: 83028 

Company Name: NCA BIOTECH, INC. 

DER-IWANG 

NCA BIOTECH, INC. 

3406 POMONA BLVD. 

POMONA, CA 91768-

OFFICE Of 

PREVENTION, PESTICIDES AND 

TOXIC SUBSTANCES 

SUBJECT: Receipt of Registration Application and 100% Small Business Waiver Request 

Dear Registrant: 

The Office of Pesticide Programs has received your application for registration and 100% 

small business waiver request. If you submitted data with this application, the results of the 

PRN-86-5 screen will be communicated separately. During the administrative screen, the Office 

of Pesticide Programs has determined that this Action is subject to a Pesticide Registration 

Service Fee as defined in the Pesticide Registration Improvement Act. 

The Action has been identified as Action Code: B66 

ME-TOO;NEW PRODUCT;MICROBIALlBJOCHEMICAL;FAST-TRACK; 

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

when a detennination is made regarding your request. If the detennination indicates that 

payment is due, you will receive instructions for submitting payment at that time. 

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

Ombudsman, at (703) 308-8260. 

Sincerely, 
47

Chris, 

Nina 

Simeonova/DC/USEPAJUS 

04/25/200712:16 PM 

To Chris Pfeifer/DC/USEPAlUS@EPA 

ee 

bee 

Subject 83028-E 

The application for registration of the product TechnicaI3-lndole-Butyric Acid, EPA File Symbol 83028-E 

is 100 % Me-Too. Comparison of the CSFs shows that the product is completely identical to Technical 

3-lndole-Butyric Acid, EPA 72639-1. No studies, all the information about the data is in the data matrix. 

Only CSF and label are submitted. The Chinese producer is registered for LT Biosyn in 72639-1, now 

NCA Biotech requests registration of exactly the same quarrty from the same producer as 83028-E. 

Nina 
48

IFee for Servicel {S054463-

This package includes the following for Division 

Co) New Registration ClAD 

o Amendment ~BPPD 

oRO 

reStudies? ,,: Fee Waiver? 

, [ill 'volpay % Reduction: 

Risk Mgr. 

Receipt No. s-I 805446 I 

EPA File Symbol/Reg. No. I 83028-E I 

Pin-Punch Date: I:: 2/9/2007 I 

o This item is NOT subject to FFS action. 

Action Code: 

Requested: 18~b Granted: I 

Amount Due: $ ),&£() 

, 

Reviewer: tei9?)?,IJ Qe 

Remarks: W:vto/ 4//6+eJ 

ParenVChild Decisions: 

I 

I 
49

Chris, 

Nina 

Simeonova/DC/USEPNUS 

04/25/200712:16 PM 

To Chris Pfeifer/DC/USEPNUS@EPA 

ee 

bee 

Subject 83028-E 

The application for registration of the product TechnicaI3-lndole-Butyric Acid, EPA File Symbol 83028-E 

is 100 % Me-Too. Comparison of the CSFs shows that the product is comple1ely identical to Technical 

3-lndole-Butyric Acid, EPA 72639-1. No S1udies, all the information about the data is in the data matrix. 

Only CSF and label are submitted. The Chinese producer is registered for L T Biosyn in 72639-1, now 

NCA Biotech requests registration of exactly the same quality from the same producer as 83028-E. 

Nina 
50

Internal BBPD Guidance Document ~ Other Items May be Required RAL: Chris Pfeifer 

OLD ACTIVE INGREDIENT 

NEW PRODUCT REGISTRATIONIEXISTING PRODUCT AMENDMENT CHECKLIST 

EPA File SymbollReg. No.: 83028-E Application Date: 3/27/07 

If amendment, indicate type: label, CSF or both: Registration 

If amendment, is change covered by PR Notice 98-10 (Notifications)? YES 0 NO 0 NA li'I 

If Yes, STOP. Call applicant and infonn them that this submission will be converted to a notification. 

1. Application Fonn (EPA Fonn 8570-1) signed and complete includiugpackage. YES 0 NO 0 NA &1 

1a. Fast-Track: YES 0 NO li'I 

2. Final printed labeling received for labels approved after 10/1l99? YES 0 NO 0 NA &1 

If NO, Stop! E-mail applicant and request final printed labeling (FPL). Let them know that FPL from the last accepted 

label is needed to support the current application. File copy of your e-mail as record of notification. Log out of PRATS (label 

deficiency). Exceptions to this practice can occur. 

3. Confidential Statement ofFonnula (EPA Fonn 8570-4) 

a) Completely filled out including pH, flashpoint, flammability, etc. if applicable. 

b) Totals are accurate. 

c) Certified limits agree with 40 CFR 158.175 or 5 batch analysis. 

d) PC codes assigned on CSF for inerts and 40 CFR 180.910,.920,.930 codes noted for products 

that have food or feed uses. 

e) List 1 inert ingredient present? 

f) Alternate fonnula(s) do not require different labeling from other fonnulas? 

g) CSF is signed and dated. 

YES li'INO 0 

YES li'INO 0 

YES li'I NO 0 

YES li'I NO 0 

YES 0 NO li'I 

YES li'I NO 0 

YES li'INO 0 

h) Registered source for aj. YES 0 NO 0 NA li'I 

4. Data Matrix (EPA Fonn 8570-35) and Data 

a) Using selective method? (If NO, data matrix not required, skip to item 5.) 

1) Complete data matrix. Minimum data matrix for registration would include product specific 

acute toxicology and product chemistry data and efficacy for public health pests. Minor CSF 

and labeling amendments may not require a data matrix. 

b) Adequate product specific data. 

YES li'I NO 0 

YES li'INO 0 

YES li'INO 0 

c) Registered source used for a.i.. If YES, aj. is from a registered source and generic data YES 0 NO 0 NA iii 

should be satisfied by registered source, skip to item 4. If NO, generic data needed. 

1) Adequate generic data YES li'I NO 0 NA li'I 
51

d) Data passed 86-5 (Data Fonnatting PR Notice)? YES Itt NO 0 

e) Public copy of matrix present, as required by PR Notice 98-5(Compensation)? YES iii NO 0 

5. Certification with Respect to Citation of Data YES Itt NO 0 

(EPA Fonn 8570-34) (See 40 CFR 152.80-98 and PR Notice 98-5) Ifno data are required or 

submitted, the Certification need not be submitted. This is often true for minor amendments. 

a) Did applicant check a method of support? YES Itt NO 0 

b) General Offer to Pay checked for cite-all method or cite-all option under selective method. YES Itt NO 0 

c) Is the form signed and dated? YES Itt NO 0 

d) Check form and data matrix. Are exclusive use data cited from other sources? YES 0 NO 0" 

1) If YES, is required authorization letter present? YES ONO 0 NA Itt 

6. Formulators Exemption Form (EPA Form 8570-27) filled out and signed if using a registered YESONOONAItf" 

source active ingredient in the formulation. 

7. Exclusive Use Notice Requirement Prior to Registration (Required per 40 CFR152.l16, separate from 

permission of an exclusive use data submitter to rely on exclusive use data) 

Is this an exclusive use aj, or combination of active ingredients (registered within last 10 years)? 

If YES, go to a) or b) below. 

a) Has a notification letter or email been sent to the exclusive use data submitter(s) at least 30 

days before registration? (This notification is required for all methods of data support except 

when the exclusive use data submitter(s)' product is used to fonnulate and the formulator's 

exemption is claimed.) 

1. Has exclusive use data submitter requested during 30 day period the applicants' list of 

data requirements and method of compliance? 

OR: 

YESON00 

YESONOO 

YESONOO 

b) Has registrant submitted certification from exclusive use data submitter that submitter is aware YES 0 NO 0 

of application and does not object to the registration? 

8. Label(s) Date of Label Review: 5/13/07 

a) Label(s) agree with current Label Review Manual and appropriate REDS. YES0NOO 

b) Acute toxicology, product chemistry, and efficacy data examined for labeling, YES0NOO 

c) Nominal concentration of aj. listed in ingredients statement YES0NOO 

d) Storage and disposal instructions agree with container types listed on application form YES0NOO 

e) Unique Product Name for Same Company (Check REFS) YES0NOO 

f) Labeling is acceptable. Corrections or changes are NOT necessary? YES0NOO 

g) Bob Torla Concurrence for OMRI Logo. YESONOONA0 

2 
52

File Symbol: 83028,2 < 

[SITe/Use] 

(J:< -J 

Tox Categories: W::::waWed 

Label Requirement 

Restricted Use Pesticide 

Product Name 

Compny Name and Info 

Identification Numbers 

Net Contents 

Ingredients Statement 

Label Claims 

Alternate Formula 

<,< < < < 

[Res lAg 

Label Review 

Date: 5/11/07 

molh ] [Food 

Reviewer: Chris Pfeifer 

INon-Food $91" ] 

[AcOra!: W IAcDerm: W IAclnhl: W IEyelrr: W2/Skinlrr. W DermSens: No [ 

Acceptable Not Acceptable N/A Comments LRM3 

Recommendations 

---------- ------.--- -._-- Ch6 

" Pg 12-3 

" Pg 15-1 

" Ch14 

" Added Ch17 

" Ch5 

" Pgs 4-5, 5-7 

11-10 & Ch 12 

" 5-12 

«P..eCj"iHo~aly Stati';'.~!" < <.<i;i.~<.<J7 ••• i_2'i' >~<'.';.'" Label Requirement Acceptable Not N/A Comments LRM3 

Acceptable ReCommendations 

KOROC " 3-1 & 9 

7-3 &4 

Signal Word " Changed Ch3Ch7 

Ch 10 

General Heading " Edited Ch 7 

PRECAUTIONARY 

STATEMENTS 

Firsl Aid (PRN 2000 1- I) " Edited Ch3&7 

Hazards to Humans " Added statements. Edited Ch 3, 7-3 

and Domestic Animals 

PPE(WPS) " Ch 7,Pg 7-12 

Engineering Controls Pgs 10-4, IS 

User Safety " Ch 10 

Requirements 

User Safety " Ch to 

Recommendations 

Environmental Hazards " Edited Ch 8 

Physical and Chemical " Pg 3-4 

Hazards Ch 9 
53

. 

Label Requirement 

Header: Directions tor 

Use 

Violation of Federal Law 

text 

WPS Text 

(PPE) 

Non-WPS Text 

Storage and Disposal 

Acceptable Not 

Acceptable 

) 

N/A Comments 

Recommendations 

Enlarged 

Moved 

LRM3 

10-16 

..... ... . 

10-26,11-7 

Ch 10, 7~1 

7-11 

7-12, Ch 10 

.. 

... .• < /. ·1)1"'011005 tOr U"e(~~~.i.iII~stf~Cti~;'s~WinfOr~.li~~) ..••. • <!;;./<k;Z( 

Label Requirement Acceptable 

General Instructions and " Sub-Header 

Chemigation I Prohibition 

REI 

Label Requirement Acceptable 

General Into. ...J 

General Precautions and ...J 

Restrictions 

Direclions for Application ...J 

Consistency with label 

instructions 

Not false or misleading 

Not 

Acceptable 

Not 

Acceptable 

NfA Comments 

Recommendations 

" " 

N/A Comments 

Recommendations 

LRM3 

PRN 

Pg 10-20 

LRM3 

12-6 
54

\, 

BASIC CHECK LIST FOR 

CONFIDENTIAL STATEMENT OF FORMULAS (CSF) 

Please note that if you have any questions at any point, especially with chemical or microbial names, 

consult with a chemist! product characterization scientist. (Freshteh, Paul, Russ, Carl, Michael T. W. 

or Chris). It may be helpful to make a copy of the CSF for marking comments, questions, and needed 

corrections. Upon completion of this fonn, consult the above scientists. And have them check over 

the CSF along with your comments. 

EPA Regll/ File Symbol: 83028-2(E) CSF dated: 2/8107 REVIEW DUE DATE: 5/3/07 

1. Compare CSF with prior CSF(s), and detennine what is different. 

Notes: Nearly Identical: Same Manufacturing Est. Same Percentages. 

2. Examine label. Does this product have food or feed use sites? No 

3. Is each field filled out on CSF? 0 yes D no 

Missing: NA. 

4. Is box 18 signed? 0 yes D no 

5. Are addresses complete, including zipcodes in boxes 1,2, and II? 0yes ono 

Deficiencies: 

6. Have they enclosed a Material Safety Data Sheet (MSDS) for each new ingredient? 

Dyes Dno IiaNA 

Deficiencies: NA. 

Please note that when the PPCV system is functioning again most 0/ this iriformation/or 7-12 can 

be obtained on-line. Some a/the codes may be listed on prior CSFs in product jacket. 

7. In column 10. for each component is the chemical name, trade name and CAS No. listed? Is it 

clear what each component is? (May need to consult Fann Chern Handbook, Chemical Catalogs, or 

other references of Zubkoff or Toghrol) 

For any microbial ingredient, in column 10 - the description should include Colony fonning units per 

gram (CFUig) and cell collection identity number (E.g. ATCC 889-34.) 

o yes 0 no 

Deficiencies: NA. Everything is accounted for. 

8. Using a chemical catalog, or Refs verify the CAS #, and chemical name for each component under 

consideration. Also Note any toxicological infonnation disclosed in catalog. 

Deficiencies: NA. CAS# is correct. 

9. Determine PC codes for each component and write these in "EPA USE ONL yn column. Does 

each component have PC Code? (Notebooks with PC codes are in File room. REFS lists PC codes 

for Active ingredients.) If code(s) are not found, it may be necessary to send request fonn to Linda 

Fan 

PC Codes are written in column. 
55

) 

10. For each inert component determine whetherit is listed under 40 CFR 180.1001 (c)(d) (e). And 

write these codes in "EPA USE ONLYIi column. (Names may be confusing- consult with a chemist if 

needed) lfthis product isfor feed or food use, all inert ingredients MUST have appropriate 

clearance. 

Deficiencies: NA. Cleared for food/feed use. 

11. For each inert component that does not have (c)(d) or (e) clearance detennine whether it is a list 1, 

2,3, 4(a) , or 4(b) inert. Write this infonnation inllEPA USE ONLYu column. References to 

consult: www.epa.gov/opprdOOllinertsandFRVol.63.No. 121 pages 34384-34390. If any of the 

inert ingredients are listed as "No longer usedll in the above FR vo1.63 notice, or are on list 1 or 2, this 

is a problem to bring attention to chemist. 

. Problem inerts? NA. 

12. If product used on food or feed, confir:m active ingredient( s) has an established tolerance or 

exemption from food tolerance. (Consult Alphabetical listing in part 180 of 40 CFR pages 296-300, or 

the pesticide petition file jacket) ~yes Dno Deficiencies: All cleared. 

13. Do certified limits for EACH component agree with 40 CFR 158.175? 

:::;1% N ± 10%N N xl.! NxO.9 

> 1 % but :::;20% N±5%N N x 1.05 N x 0.95 

>20% N±3%N N x 1.03 NxO.97 

N= amount Column 13 b. = nominal concentration 

Calculate upper and lower limits using table above and compare with those listed 

in columns 14 a. and 14 b. of submitted CSF. If they do not agree, identify difference(s): NA 

14. Does the sum of the numbers in colunm 13. a. equal total listed in box 17? 

Ii1I yes Dno 

15 Does column 13. b. add up to 100%? 0 yes ono 

16. If Alternative Fonnulation box is checked in box A- Is there another CSF for a Basic 

Fonnulation on file?? Dyes Dno ~ NA 

17. Other issues? N A 
56

)~.~aII.. _________ -"'F'~=Ill.~A2P~P'~'~V;';~'o\." --1~N~'~~ 'n"'7~o.ooi;!!~60~..IIiII~:IIoIl!l"'L·' ";i ...• " ~8~ .. "~5~ 

O Registration opp Identifior Number 

&EPA Unitad States 

Environmental Protection Agency 

Wash'lngton, DC 20460 

Amendment 

Other 

Application for Pesticide T Section I 

I. CompenyfProduct Number 

83028- c:.. 

4. CompanyfProduct (Name) 

2. EPA Product Maneger 

S. Reilly 

PM' 

3. Proposed Classificetion 

o None 0 Rllstncted 

NCA Biotech, Inc, / Technical 3·lndolebu1yric Acid 91 

5. Nomo ond Addross of Applicant {Include ZIP Codol 

NCA Biolech, (nc. 

c/o Pyxis Regulatory Consulling, Inc. 

4110 1361h 81. NW 

6, Expedited Reveiw. In accordance with FIFRA Section 31c113) 

IbHiI, my product is similar or identical in composition and (abeling 

to: 

EPA Reg. No. _7_2_6_3_9_-1 __________ _ Gio Harbor. WA 98332 o Chock if this is a nllW address Product Name Technical 3-lndolebutyric Acid 

D 

D 

D 

Section - " 

Amendmllnt - EXplain balow. 

Rosubmission in responsa to Agency letter detod ______ _ 

Notification - Explain below. 

u 

2] 

o 

Explanation: Usa odditional pago(sl if necossory, (For soction I and Section ILl 

Final printed label, in ropsonso to 

Agency lottar datad 

~Me Too~ Application, 

Othor - Explain below. 

NCA Biotech, Inc. believes this application falls under B66 (New product, Me-Too, Fas1 track) because it is a new product 

containing already registered active ingredien1s and no formal review of data will be required. The fee due is $1050 and 1he 

decision timeline is 3 months; however, NCA Biotech, Inc. is seeking a fee waiver. Please email any ques1ions to: 

fees@PyxisRC.com. 

Section - III 

1. Material Thi, Product Wdl a. peckagad In: 

Child-Resistont Packoging Unit Packaging Weter Solublo Peckaging 2, Type of Containar 

DV" 

0 NO 

Dy" 

[{JNo 

D y" 

[{] No 

• Certification must 

be submitted 

If "Yes~ No, par If "Vas" 

Unit Peckaging wgt. container Package wgt 

3. Location of Nat Content, Information 

[(,' Lobel U Container 

6, Monner in Which Lobel is Aftixed to Product 

4. Sizels) Retail Contoinor 

2.2 Ibs. (1 kg) 

LJ Uthograph 

Paper gluad J StencHed 

I 

Section· IV 

No. per 

container 

o Other 

t;J ~::~', Glass 

Popar 

./ Othor (SpacifYI __ A_,"_m_'"_"_m_fi_"_m_'1 

5. Location of Lobol Directions 

[A' __ J On LabGI 

c::J On Lobelln9 Gccomp.nylng producl 

1. Contact Point (Comp/ato iloms t/irocrly bolow fDr idontifr'catron of rnd(vidutll rD bo contectod, if nf)Cf/ssury, 10 procass this app(r"Cfltion./ 

Neme 

Michael Kellogg 

Title 

Agent 

Telephone No. IInclude Area Codel 

(253) 853-7369 

Certification 

I certify that the statemants I have made on this form and all attachments theroto are truo, accurate lind completa, 

6. Date Applicetion 

ReceIved 

/. 

(St'emp,d) 

, " I acknowledge that any knowllngUy falsa or mH.loadlng stotamant may be puni,hllble by fine or imprisonment or~' ) 'J , 

both under applicable lew. , ;: 

'~;;;~I jd) /#l)(l 3A~:~1 . ..' ~------4--------------------'-~ 4. Typed Namo 5. Date 

Michael Kellogg 

EPA Farm 6570·1 (Rail. 3-941 PreVIous adltlons era obsolete. White • EPA rife Copy !ongln,U 
57

\ PYX,~ REGULATORY CONSULTING, ~,~C. 

4J JO 1361h St. NW 

Gig Harbor, WA 98332 

COURIER DELIVERY 

Dr. Sheryl Reilly (PM9l) 

Document Processing Desk (REGFEE) 

Office of Pesticide Programs (7504P) 

U.S. Environmental Protection Agency 

Room S-4900, One Potomac Yard 

2777 S. Crystal Drive 

Arlington, V A 22202 

February 8, 2007 

RE: NCA Biotech, Inc. - Technical3-Indolebutyric Acid (EPA Reg. No. 83028-

Application for New P~sticide Registration 

Dear Dr. Reilly, 

Phone: 253-853-7369 

Fax: 253-853-5516 

www.PyxisRC.com 

) 

On behalf of NCA Biotech, Inc. we are submitting an application for registration of Technical 3-

Indolebutyric Acid, a technical product containing Indole-3-butyric acid (IBA) as the active ingredient. 

In support of this application, we submit the following documents: 

1. Application for a New Pesticide Registration (EPA Fonn 8570-1) 

2. Fee Waiver request letter and supporting documentation 

3. Confidential Statement ofFonnula dated February 8, 2007 

4. Five (5) Copies of the Proposed Labeling 

5. Certification with Respect to Citation of Data (EPA Fonn 8570-34) 

6. Agency Internal Use Copy of the Data Matrix 

7. Public File Copy of the Data Matrix 

NCA Biotech, Inc. believes this application falls under B66 (New product, Me-Too, Fast track) because it 

is an application for registration of a new product which is identical to an existing product and no product 

chemistry or acute toxicity data are being submitted for review. NCA Biotech, Inc. is seeking a fee 

waiver. 

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 infonnation. 

Sincerely, 

Michael Kellogg 

Enclosures . " 

, • " 
58

NCA Share holder list and related business of each share holder:* 

*Commercial/financial information may be entitled to confiden
59

" ; OM" N, 

r, UNITED STATES ENVIRONMENTAL PROTECTION AGENCY ( ~, " ; 401 M Street, S.W. ';,,-/ 

WASHINGTON, D.C. 20460 

" Paperwork Reduction Act Nottce; The public reporting burden for this collection of information is esbmated to average 1.25 hrJJ\<',r.er r.esponsL'fo:;registration 

and 0.25 hovrs per response for reregistration and special review activities, including time for reading the instructions and compl,,1ing the necessary forms. Send 

comments regarding bvrden estimate or any other aspect Of this collection of information, including suggestions for reducing the burden 19: Director, D?PE 

Information Management Division (2 t37). U.S. Environmental Protection Agency, 401 M Street, S.w., Washington, DC 20460. 

" , " Do not send the completed form to thiS address. , 

, , , Certification with Citation of Data , , , ; , 

Applicant's/Registrant's NOIme, Address, and Telephone Number EPA Registration ii' , 

NC'A Biotech, Inc.: 6406 Pomona Blyd., Pomona, CA 91768: (253) 853-7369 83028- " ,,-, 

ActiYe Inllredient(s) and/or representalive test compound(s) Date , " , I . Acid , , 

Genel<ll Use Pattem(s) (lisl all those claimed for this product using 40 CFR Part 158) Product Name 

TGAI Technical I Acid 

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

i this form. You mvst Submit the Formulator's Exemption Stalement (EPA Form 8570-27). 

0 I am responding to a Data-Call-In Notice. and have inclvded with this form a lisl of companies senl offers of compensation (Ihe Data Matrix form should 

be vsed for Ihis pvrpose). 

SECTtON I: METHOD OF DATA 

0 I am using the cite-all method of svpport. and have included with this form 0 I am using the selective method of support (or cite-all option 

a list of companies sent offers of compensation (Iha Data Matrix form under the selective melhod), and have included with this form a 

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

vsed), 

SECTION II: GENERAL OFFER TO PAY 

[Required if using the cite-all method or when vsing the cite-all option under the seleclive method to satisfy one or more data requirements[ 

0 I hereby offer and agree 10 pay compensation, to olher persons, with regard 10 the approval of this application, to the extenl required by FIFRA. 

SECTION lit: CERTtFtCATtON 

I certify that this application for registration. this fonn for reregistl<ltion, or this Data-Call-In response is svpported by all data submitted or cited in the 

application for registralion, the form for reregistration, or the Data-Call-tn response. In addition, if Ihe die-ali option or cite-all option under the seleclive method is 

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

svbslantially similar product, orone or more of the ingredients in this prodvct: and (2) is a type of data thai would be required to be submitted under the dala 

requirements in effect on the date of approval of this applicalion if the application sought the initial registralion of a product of idenlicat or similar composition and 

uses 

I certify Ihal for each exclusive use study Cited in support of Ihis registration or reregistration, that I am the original dsta submitter or that I have obtained 

the wrilten permission of the original dala submilter to cite that study. 

I certify that for eacl1 stvdy cited in support of this registration or reregistration that is not an exclusive use study, either: (a) t am the original data 

subm~ter; (b) I have obtained the permission of Ihe original data submitter to use the study in support of this spplication; (c) all periods of eligibility for 

compensation have expired for the study: (d) the study is in the public literature: or (e) t have notified in wriling the company that subm~led the study and have 

offered (I) to pay compensation to the extent required by sections 3(c)(t)(F) and/or 3(c)(2)(B) of FIFRA; and (ii) to commence negolialions to delermine the 

amount and terms of compensalion, if any, to be paid for the use of the study. 

I certify that in all inslances where an offer of compensation is required, copies of all offers 10 pay compensation and eyidence of their delivery in 

accordance with sections 3(c)(1)(F) and/or 3(c)(2)(B) of FIFRA are available and will be submitted to the Agency upon request Should I fail to produce such 

evidence 10 the Agency upon reqvest, I understand Ihat Ihe Agency may initiate action to deny, cancel or suspend the registralion of my Ffoduct In conformity wah 

FIFRA. 

I cllrtify that the statements t have made on this form and all attachments to it are true, accurate, and complete. I acknowledge that any 

knowingly false or misteading statement may be punishable by fine or imprisonment or both under applicabte taw. 

,:~ ~7 Typed or Printed Name and nle 

Michael Kellogg / Agent 

,'''" , ' 
60

F

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY " " " - 

401 M Street, S.W. " " - - - 

" - " . " "'.' - 

WASHINGTON. D.C. 20460 v _ - -

-

-

Paperwork Reduction Act Notice: The public reporting burden tor this COllection of'lnformation is estimated to average 0.25 hours per response tor regislralion aclivities and 0.25 

reregistration and special review activities, including time for reading the instruclions and completing Ihe necessary forms. Send commenls regarding Ihe or ('!l}Y ot

information, suggestions for reducing the burden to: Director, OPPE Intormation Management Division (2t37), U.S. Environmental Protection Age:!J!]y. 40'SM S.W.

send the form to thiS address. .. " 

.. " .... --- " DATA MATRIX - " 

Date February 8, 2007 EPA Reg No.lFile Symbol 83028- 

Applicant'S/Registranl's Name & Address Product 

NCA Biotech, Inc. Technical 3-lndolebuty

3406 Pomona Blvd. 

Pomona, CA 91768 

1!l9.redient lndole-3-8ulvric Acid 

Guideline Reference Number Guideline Study Name MRIDNumber Submitter S

880.1100 (151-10) Product Identity and Composition 44873201 "if" P880.1200 (151-11) Description of Materials Used to Produce the 44873201 / P

Product, Production and Formulation Process 

880.1400 (151-12) Discussion of Formation of Impurities 44873201 '4"' C-/'ti P

15H3 Preliminary Analvsis 44873202 /)/"" , P

151·15 Certified Limits 44873202 '10,,# " P

151·16 Enforcement Analytical Method 44873202 'L/ P

OWN 44873203 P

151·17(b) Physical State 44873203 P151·17(c) Odor 44873203 P

151·17(d) MeltinQ PointiMeltinQ RanQe 44873203 /" P

151·17(e) Boiling Point/Boiling Range "/1/ "n ... 151·17(0 Density/Relative Density/Bulk Density 44873203 .... ' .0/0", "- P151-17(g) Solubility 44873203 vt.:J,4"" "-.. P151·17(h) Vapor Pressure 41584403 "t..!-' O151·17(i) pH 44873203 P151·1701 Stability 41584403 O

Name and Tille 

Michael Kellogg, Consultant 

EPA Form 8570-35 (9·97) Electronic and Paper versions available, Submil only Paper version. Agency Int
61

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 

401 M Street, S.W. 

WASHINGTON, D.C. 20460 

F

Paperwork Reduct!on Act Notice: The pubflc reporting burden for th·1S colleclion of information is estimaled to average 0.25 hours per response for registration activities and 0.25 

reregistration and special review activities. including time for reading Ihe inslruclions and completing fhe necessary forms. Send commenls regarding the or any otinformation. including suggestions for reducing the burden to: Oirector. OPPE Information Management OiviSion (2137), U.S. Environmental Protection S:rec( S.w.

send the form to this address. 

- " , " 

Oate February 8, 2007 

Applican!'s/Registranl's Name & Address 

Inqredien! Indole-3-Butvric Acid 

Guideline Reference Number 

151-17(0) 

154-6 

154-7 

154-8 154-9 154-10 154-11 

1520 10 

152-11 152-12 152-13 

152-14 

152-15,152-16 

Signature 

/7/U:,.i/l !l "T 

NCA Biotech, Inc. 

3406 Pomona Blvd. 

Pomona, CA 91768 

Guideline Study Name 

OctanolIWater Partition Coefficient 

Acute Avian Oral Toxicity: Quail or Duck 

Acute Avian Dietary Toxicity 

Freshwater Fish LC50: Trout 

Freshwater Invertebrate Toxicity 

NontarQet Plant Studies 

Nontarqet Insect Testina 

Acute Oral Toxicity: Rat Acute Defmal Toxicity: Rat Acute Inhalation T oxicitv: Rat 

-----

Primary Eye Irritation: Rabbit 

Primary Dermal Irritation 

Hvpersensitivity Incidents 

ry 

DATA MATRIX 

MR!O Number 

41584403 

43026701 

43026702 43026703 43026704 

46054401 

46054402 45453401 45453402 45453403 45453404 

45453405 

45453406 

EPA Form 8570-35 (9-97) Electronic and Paper versions available. Submil only Paper version. 

EPA Reg No.lFile Symbol 83028-Product 

Technical 3-lndolebuty

Submitter 

IBA REDTF 

IBA RED TF 

IBA RED TF 

IBA RED TF 

Name and Tille 

Michael Kellogg, Consultant 

S

O

- P

PP

PPPP

P

PP

Agency Inte
62

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 

401 M Street, S.W. 

WASHINGTON, D.C. 20460 

F

Paperwork Reduction Act Notice: The pubflc reporting burden for this collecflon of inFormafion ',S estimated to average 0.25 hours per response for registration activities and 0.25 

reregistration and special review activities, including lime for reading the instructions and completing the necessary forms. Send comments regarding the bcr(:if'J'oeS!il!13te or any oth

information, including suggestions for reducing the burden to: Oirector, OPPE InFormation Management Oivision (2 t37), U.S. EnVironmental Protection Ager19:' 401.M 

send the form to this address. - : _ .' -

Oate ,8.2007 

Applican\'sIRegistran\'s Name & Address 

1152-17 1152-21 

152-22 152-23 

153 series 

e Number 

NCA Biotech, Inc. 

3406 Pomona Blvd. 

Pomona, CA 91768 

v Name 

90-Dc. '''' 

90-Day DE 

on n_ 

Residue Data 

DATA MATRIX 

( EPA Reg NoJFlle Symbol 

Product 

Technical 3-lndolebutyr

--------'------

I MRIO Number I Submitter I St

Name and Tille 

Michael Kellogg, Consultant 

Form 8570-35 (9-97) Electronic and Paper versions available. Submit only Paper version. Agency tnte
63

Endnotes for Data Matrix for Technical 3-lndolebutyric Acid 

1 1S1-17(e) _ BOiling pOint data are only required for liquids, Technical 3-indolebutyric acid is a solid. 

2 1~1-17(h) _ This study was listed in the RED as satisfying guideline requirements for I SA. 

3 'IS4-t>).... The RED required acute avian oral data. According to NPIRS, this study (MRID number 

43G26,701) is the only study submitted in response to this Data Call-In. Therefore, NCA Biotech, Inc. 

assumes tha~ t,h,i~ ,study supports the data requirement 

4 ,1EA~7 _ Th~ )~~() required avian dietary data. According to NPIRS, this study (MRID number 

<,3028702) ard its supporting feed analysis studies (43026703 and 43026704) are the only studies 

submitted in response to this Data Call-In. Therefore, NCA Biotech, Inc. assumes that these studies 

support the 'da'ta 'requirement. , 

5 1p~-1Q, 154;1~: - ,lccording to the RED, these data are not required for the registration of IBA. ., '>' ,., , , " 

6 152;;17, 152-21, 152-23 - The RED states this generic data requirement is waived (for technical 

products). According to NPIRS, no mutagenicity, subchronic, or teratogenicity data have been 

submitted on the technical product, therefore, this requirement is considered waived, 

7152-18,152-20,152-22 - The RED does not iistthis data requirement. In addltion, according to NPIRS, 

immune response data or subchronic data have been submitted on the technical product, therefore, 

this requirement is considered waived. 

8 153 series _ IBA is exempt from tolerances of residues on crops. Therefore, no residue data are 

required. 

Page 1 of 1 
64

TECHNICAL 3-INDOLEBUTYRIC ACID 

FOR MANUFACTURING PURPOSES ONLY 

FORMULATORS WHO USE THIS PRODUCT ARE RESPONSIBLE 

FOR OBTAINING EPA REGISTRATION FOR THEIR FORMULATED PRODUCTS 

ACTIVE INGREDIENT: 

Indole~3-Butyric Acid ........................................... , .............................................................. 98.0% 

OTHER INGREDIENTS: ..................................................................................................... 2.0% 

EPA Reg. No. 83028-

If in eyes: • 

• 

• 

TOTAL 100.0% 

KEEP OUT OF REACH OF CHILDREN 

CAUTION 

FIRST AID 

EPA Est. No. 

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. 

HOT LINE NUMBER 

Have the product container or label with you when calling a poison control center or doctor, or going 

for treatment For general product information, call NCA Biotech, Inc. at (909) 348-5133 between the 

hours of 9 a.m. - 4 p.m. Pacific Time. 

PRECAUTIONARY STATEMENTS 

HAZARDS TO HUMANS AND DOMESTIC ANIMALS 

CAUTION 

Causes moderate eye irritation. Avoid contact with eyes or clothing. Wash thoroughly with soap and water after handling. 

ENVIRONMENTAL HAZARDS 

Keep out of lakes, streams, or ponds. Do not contaminate water by the cleaning of equipment or disposal of wastes. Do 

not discharge effluent containing this product into lakes, streams, ponds, estuaries, oceans, or other waters unless in 

accordance with the requirements of a National Pollutant Discharge Elimination System (NPDES) permit and the 

permitting authority has been notified in writing prior to discharge. Do not discharge effluent containing this product to 

sewer systems without previously notifying the local sewage treatment plant authority. For guidance, contact your State 

Water Board or Regional Office of the EPA 

DIRECTIONS FOR USE 

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

Manufactured for: 

NCA Biotech, Inc. 

3406 Pomona Blvd. 

Pomona, CA 91768 

Net Weight: 

Lbs. 
65

STORAGE AND DISPOSAL 

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

PESTICIDE STORAGE: Do not store with foodstuff. 

PESTICIDE DISPOSAL: Waste resulting from the use of this product may be disposed of on site or at an approved 

waste disposal facility. 

CONTAINER DISPOSAL: Triple rinse (or equivalent). Then offer for recycling or reconditioning, or puncture and dispose 

of in a sanitary landfill or, by other procedures approved by state and local authorit'les. 

FOR MANUFACTURING USE ONLY 

Only for Formulation into a Plant Growth Regulator for (1) The Following Uses: Ornamental herbaceous plants, 

ornamental woody shrubs and vines, ornamental andlor shade trees, barley, beans, broccoli, Brussels sprouts, cabbage, 

cauliflower, citrus fruits, corn (field, sweet), cotton, cucumbers, lettuce, melons, mustard cabbage, mustard (leafy/stem 

crop), oats, onions, green onions, peanuts, peas, peppers, potatoes, rice, rye, sorghum, soybeans, spinach, squash, 

strawberries, sugar beets, sugarcane, tomato, turnip, wheat, golf course turi, ornamental lawns and turi. (2) Uses for 

Which US EPA has Accepted or Waived the Required Data and/or Citations of Data that the Formulator has 

Submitted in Support of Registration; and (3) Uses for Experimental Purposes that are in Compliance with 

USEPA Requirements. 

DISCLAIMER AND INDEMNITY FOR FORMULATORS' USES 

The manufacturer expressly disclaims all liability for claims and actions (whether based on contract, tort, strict liability, or 

breach of warTanty) arising out of, resulting from or connected with a formulation containing this product when used for 

any purpose other than those uses set forth in (1) above. The manufacturer has not developed scientific data to support, 

nor has it explicitly or implicitly approved, any uses other than those in (1) above. 

Any formulator or buyer who uses this product in formulations for any other than those stated in (1) above assumes all 

liability for claims and actions arising out of, connected with or resulting from such use and agrees by so using this 

product to indemnify and hold harmless the manufacturer from such claims and actions. 

This disclaimer and indemnity is in addition to, not in lieu of, the below disclaimer and limitations. 

LIMITED WARRANTY AND DISCLAIMER 

The manufacturer warrants that this product conforms to the chemical description on the label; that this product is 

reasonably fit for the purposes set forth in item (1) of the Directions for Use when it is used in accordance with such 

Directions: and that the statements under item (1) of the Directions, the warnings and other statements on this label, other 

than the suggested uses under items (2) and (3) of the Directions, are based upon responsible experts' evaluation of 

reasonable tests of effectiveness, of toxicity to laboratory animals and to plants, and of residues on food crops and upon 

reports of field experience. Tests have not been made on all varieties or in all states or under all condition. THE 

MANUFACTURER NEITHER MAKES NOR INTENDS, NOR DOES IT AUTHORIZE ANY AGENT OR 

REPRESENTATIVE TO MAKE, ANY OTHER WARRANTIES, EXPRESS OR IMPLIED, AND IT EXPRESSLY 

EXCLUDES AND DISCLAIMS ALL IMPLIED WARRANTIES OF MERCHANTABILITY OR FITNESS FOR A 

PARTICULAR PURPOSE. 

THIS WARRANTY DOES NOT EXTEND TO, AND THE BUYER SHALL BE SOLELY RESPONSIBLE FOR, ANY AND 

ALL LOSS OF DAMAGE WHICH RESULTS FROM THE USE OF THIS PRODUCT IN ANY MANNER WHICH IS 

INCONSISTENT WITH THE LABEL DIRECTIONS, WARNINGS, OR CAUTIONS. 

BUYER'S EXCLUSIVE REMEDY AND MANUFACTURER'S OR SELLER'S EXCLUSIVE LIABILITY FOR ANY AND ALL 

CLAIMS, LOSSES, DAMAGES OR INJURIES RESULTING FROM THE USE OR HANDLING OF THIS PRODUCT, 

WHETHER OR NOT BASED IN CONTRACT, NEGLIGENCE, STRICT LIABILITY IN TORT OR OTHERWISE SHALL BE 

LIMITED, AT THE MANUFACTURER'S OPTION TO REPLACEMENT OF, OR THE REPAYMENT OF THE PURCHASE 

PRICE FOR, THE QUANTITY OF PRODUCT WITH RESPECT TO WHICH DAMAGES ARE CLAIMED. IN NO EVENT 

SHALL MANUFACTURER OR SELLER BE LIABLE FOR SPECIAL, INDIRECT OR INCONSEQUENTIAL DAMAGES 

RESULTING FROM THE USE OR HANDLING OF THIS PRODUCT. 

NOTICE TO BUYER 

Purchase of this material does not confer any rights under patents governing this product or the use thereof in countries 

outside of the United States. Seller's guarantee shall be limited to the terms set out on the label and subject thereto, the 

buyer assumes the risk to persons or property ariSing from the use or handling of this product on that condition. 

2 
66

I 1 

TECHNiCAL 3-INDOLEBUTYRIC ACID 

FOR MANUFACTURING PURPOSES ONLY 

FORMULATORS WHO USE THIS PRODUCT ARE RESPONSIBLE 

FOR OBTAINING EPA REGISTRATION FOR THEIR FORMULATED PRODUCTS 

ACTIVE INGREDIENT: 

Indole-3-Butyric Acid ......................................................................... " ............................... 98.0% 

OTHER INGREDIENTS: ...................................................................................................... 2.0% 

EPA Reg. No. 83028-

If in eyes: • 

• 

• 

TOTAL 100.0% 

KEEP OUT OF REACH OF CHILDREN 

CAUTION 

FIRST AID 

EPA Est. No. 

Hold eye open and rinse slowly and gentry 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. 

HOT LINE NUMBER 

Have the product container or label with you when calling a poison control center or doctor, or going 

for treatment. For general product information, call NCA Biotech, Inc. at (909) 348-5133 between the 

hours of 9 a.m. - 4 p.m. Pacific Time. 

PRECAUTIONARY STATEMENTS 

HAZARDS TO HUMANS AND DOMESTIC ANIMALS 

CAUTION 

Causes moderate eye irritation. Avoid contact with eyes or clothing. Wash thoroughly with soap and water after handling. 

ENVIRONMENTAL HAZARDS 

Keep out of lakes, streams, or ponds. Do not contaminate water by the cleaning of equipment or disposal of wastes. Do 

not discharge effluent containing this product into lakes, streams, ponds, estuaries, oceans, or other waters unless in 

accordance with the requirements of a National Pollutant Discharge Elimination System (NPDES) permit and the 

permitting authority has been notified in writing prior to discharge. Do not discharge effluent containing this product to 

sewer systems without previously notifying the local sewage treatment plant authority. For guidance, contact your State 

Water Board or Regional Office of the EPA. 

DIRECTIONS FOR USE 

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

Manufactured for: 

NCA Biotech, Inc. 

3406 Pomona Blvd. 

Pomona, CA 91768 

Net Weight: 

Lbs. 
67

STORAGE AND DISPOSAL 

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

PESTICIDE STORAGE: Do not store with foodstuff. 

PESTICIDE DISPOSAL: Waste resulting from the use of this product may be disposed of on site or at an approved 

waste disposal facility. 

CONTAINER DISPOSAL: Triple rinse (or equivalent). Then offer for recycling or reconditioning, or puncture and dispose 

of 'In a sanitary landfill or, by other procedures approved by state and local authorities. 

FOR MANUFACTURING USE ONLY 

Only for Formulation into a Plant Growth Regulator for (1) The Following Uses: Ornamental herbaceous plants, 

ornamental woody shrubs and vines, ornamental and/or shade trees, barley, beans, broccoli, Brussels sprouts, cabbage, 

cauliflower, citrus fruits, corn (field, sweet), cotton, cucumbers, lettuce, melons, mustard cabbage, mustard (leafy/stem 

crop), oats, onions, green onions, peanuts, peas, peppers, potatoes, rice, rye, sorghum, soybeans, spinach, squash, 

strawberries, sugar beets, sugarcane, tomato, turnip, wheat, golf course turf, ornamental lawns and turf. (2) Uses for 

Which USEPA has Accepted or Waived the Required Data and/or Citations of Data that the Formulator has 

Submitted in Support of Registration; and (3) Uses for Experimental Purposes that are in Compliance with 

USEPA Requirements. 

DISCLAIMER AND INDEMNITY FOR FORMULATORS' USES 

The manufacturer expressly disclaims all liability for claims and actions (whether based on contract, tort, strict liability, or 

breach of warranty) ariSing out of, resulting from or connected with a formulation containing this product when used for 

any purpose other than those uses set forth in (1) above. The manufacturer has not developed scientific data to support, 

nor has it explicitly or implicitly approved, any uses other than those in (1) above. 

Any formulator or buyer who uses this product in formulations for any other than those stated in (1) above assumes all 

liability for claims and actions ariSing out of, connected with or resulting from such use and agrees by so using this 

product to indemnify and hold harmless the manufacturer from such claims and actions. 

This disclaimer and indemnity is in addition to, not in lieu of, the below disclaimer and limitations. 

LIMITED WARRANTY AND DISCLAIMER 

The manufactUrer warrants that this product conforms to the chemical description on the label; that this product is 

reasonably fit for the purposeS set forth in item (1) of the Directions for Use when it is used in accordance with such 

Directions; and that the statements under item (1) of the Directions, the warnings and other statements on this label, other 

than the suggested uses under items (2) and (3) of the Directions, are based upon responsible experts' evaluation of 

reasonable tests of effectiveness, of toxicity to laboratory animals and to plants, and of residues on food crops and upon 

reports of field experience. Tests have not been made on all varieties or in all states or under all conditbn. THE 

MANUFACTURER NEITHER MAKES NOR INTENDS, NOR DOES IT AUTHORIZE ANY AGENT OR 

REPRESENTATIVE TO MAKE, ANY OTHER WARRANTIES, EXPRESS OR IMPLIED, AND IT EXPRESSLY 

EXCLUDES AND DISCLAIMS ALL IMPLIED WARRANTIES OF MERCHANTABILITY OR FITNESS FOR A 

PARTICULAR PURPOSE. 

THIS WARRANTY DOES NOT EXTEND TO, AND THE BUYER SHALL BE SOLELY RESPONSIBLE FOR, ANY AND 

ALL LOSS OF DAMAGE WHICH RESULTS FROM THE USE OF THIS PRODUCT IN ANY MANNER WHICH IS 

INCONSISTENT WITH THE LABEL DIRECTIONS, WARNINGS, OR CAUTIONS. 

BUYER'S EXCLUSIVE REMEDY AND MANUFACTURER'S OR SELLER'S EXCLUSIVE LIABILITY FOR ANY AND ALL 

CLAIMS, LOSSES, DAMAGES OR INJURIES RESULTING FROM THE USE OR HANDLING OF THIS PRODUCT, 

WHETHER OR NOT BASED IN CONTRACT, NEGLIGENCE, STRICT LIABILITY IN TORT OR OTHERWISE SHALL BE 

LIMITED, AT THE MANUFACTURER'S OPTION TO REPLACEMENT OF, OR THE REPAYMENT OF THE PURCHASE 

PRICE FOR, THE QUANTITY OF PRODUCT WITH RESPECT TO WHICH DAMAGES ARE CLAIMED. IN NO EVENT 

SHALL MANUFACTURER OR SELLER BE LIABLE FOR SPECIAL, INDIRECT OR INCONSEQUENTIAL DAMAGES 

RESULTING FROM THE USE OR HANDLING OF THIS PRODUCT. 

NOTICE TO BUYER 

Purchase of this material does not confer any rights under patents governing this product or the use thereof in countries 

outside of the United States. Seller's guarantee shall be limited to the terms set out on the label and subject thereto, the 

buyer assumes the risk to persons or property arising from the use or handling of this product on that condition. 

2 
68

) ) 

TECHNICAL 3-INDOLEBUTYRIC ACID 

FOR MANUFACTURING PURPOSES ONLY 

FORMULATORS WHO USE THIS PRODUCT ARE RESPONSIBLE 

FOR OBTAINING EPA REGISTRATION FOR THEIR FORMULATED PRODUCTS 

ACTIVE INGREDIENT: 

Indole-3-Butyric Acid .......................................................................................................... 98.0% 

OTHER INGREDIENTS: ..................................................................................................... 2.0% 

EPA Reg. No. 83028-

If in eyes: • 

• 

• 

TOTAL 100.0% 

KEEP OUT OF REACH OF CHILDREN 

CAUTION 

FIRST AID 

EPA Est. No. 

Hold eye open and rinse slowly and gently with water for 15-20 minutes. 

Remove contact lenses, jf present, after the first 5 minutes, then continue rinsing 

eye. 

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 general product information, call NCA Biotech, Inc. at (909) 348-5133 between the 

hours of 9 a.m. -4 p,m. Pacific Time. 

PRECAUTIONARY STATEMENTS 

HAZARDS TO HUMANS AND DOMESTIC ANIMALS 

CAUTION 

Causes moderate eye irritation. Avoid contact with eyes or cfothing. Wash thoroughly with soap and water after handling. 

ENVIRONMENTAL HAZARDS 

Keep out of lakes, streams, or ponds. Do not contaminate water by the cfeaning of equipment or disposal of wastes. Do 

not discharge effluent containing this product into lakes, streams, ponds, estuaries, oceans, or other waters unless in 

accordance with the requirements of a National Pollutant Discharge Elimination System (NPDES) permit and the 

permitting authority has been notified in writing prior to discharge. Do not discharge effluent containing this product to 

sewer systems without previously notifying the local sewage treatment plant authority. For guidance, contact your State 

Water Board or Regional Office of the EPA. 

DIRECTIONS FOR USE 

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

Manufactured for: 

NCA Biotech, Inc. 

3406 Pomona Blvd. 

Pomona, CA 91768 

Net Weight: 

Lbs. 
69

STORAGE AND DISPOSAL 

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

PESTICIDE STORAGE: Do not store with foodstuff. 

PESTICIDE DISPOSAL: Waste resulting from the use of this product may be disposed of on site or at an approved 

waste disposal facility. 

CONTAINER DISPOSAL: Triple rinse (or equivalent). Then offer for recycling or reconditioning, or puncture and dispose 

of in a sanitary landfill or, by other procedures approved by state and local authorities. 

FOR MANUFACTURING USE ONLY 

Only for Formulation into a Plant Growth Regulator for (1) The Following Uses: Ornamental herbaceous plants, 

ornamental woody shrubs and vines, ornamental and/or shade trees, barley, beans, broccoli, Brussels sprouts, cabbage, 

cauliflower, citrus fruits, corn (field, sweet), cotton, cucumbers, lettuce, melons, mustard cabbage, mustard (leafy/stem 

crop), oats, onions, green onions, peanuts, peas, peppers, potatoes, rice, rye, sorghum, soybeans, spinach, squash, 

strawberries, sugar beets, sugarcane, tomato, tumip, wheat, golf course turf, omamental lawns and turf. (2) Uses for 

Which US EPA has Accepted or Waived the Required Data and/or Citations of Data that the Formulator has 

Submitted in Support of Registration; and (3) Uses for Experimental Purposes that are in Compliance with 

USEPA Requirements. 

DISCLAIMER AND INDEMNITY FOR FORMULATORS' USES 

The manufacturer expressly disclaims all liability for claims and actions (whether based on contract, tort, strict liability, or 

breach of warranty) arising out of, resulting from or connected with a formulation containing this product when used for 

any purpose other than those uses set forth in (1) above. The manufacturer has not developed scientific data to support, 

nor has it explicitly or implicitly approved, any uses other than those in (1) above. 

Any formulator or buyer who uses this product in formulations for any other than those stated in (1) above assumes all 

liability for claims and actions arising out of, connected with or resulting from such use and agrees by so using this 

product to indemnify and hold harmless the manufacturer from such claims and actions. 

This disclaimer and indemnity is in addition to, not in lieu of, the below disclaimer and limitations. 

LIMITED WARRANTY AND DISCLAIMER 

The manufacturer warrants that th·ls product conforms to the chemical description on the label; that this product is 

reasonably fit for the purposes set forth in item (1) of the Directions for Use when it is used in accordance with such 

Directions; and that the statements under Item (i) of the Directions, the wamings and other statements on this label, other 

than the suggested uses under items (2) and (3) of the Directions, are based upon responsible experts' evaluation of 

reasonable tests of effectiveness, of toxicity to laboratory animals and to plants, and of residues on food crops and upon 

reports of field experience. Tests have not been made on all varieties or in all states or under all condition. THE 

MANUFACTURER NEITHER MAKES NOR INTENDS, NOR DOES IT AUTHORIZE ANY AGENT OR 

REPRESENTATIVE TO MAKE, ANY OTHER WARRANTIES, EXPRESS OR IMPLIED, AND IT EXPRESSLY 

EXCLUDES AND DISCLAIMS ALL IMPLIED WARRANTIES OF MERCHANTABILITY OR FITNESS FOR A 

PARTICULAR PURPOSE. 

THIS WARRANTY DOES NOT EXTEND TO, AND THE BUYER SHALL BE SOLELY RESPONSIBLE FOR, ANY AND 

ALL LOSS OF DAMAGE WHICH RESULTS FROM THE USE OF THIS PRODUCT IN ANY MANNER WHICH IS 

INCONSISTENT WITH THE LABEL DIRECTIONS, WARNINGS, OR CAUTIONS. 

BUYER'S EXCLUSIVE REMEDY AND MANUFACTURER'S OR SELLER'S EXCLUSIVE LIABILITY FOR ANY AND ALL 

CLAIMS, LOSSES, DAMAGES OR INJURIES RESULTING FROM THE USE OR HANDLING OF THIS PRODUCT, 

WHETHER OR NOT BASED IN CONTRACT, NEGLIGENCE, STRICT LIABILITY IN TORT OR OTHERWISE SHALL BE 

LIMITED, AT THE MANUFACTURER'S OPTION TO REPLACEMENT OF, OR THE REPAYMENT OF THE PURCHASE 

PRICE FOR, THE QUANTITY OF PRODUCT WITH RESPECT TO WHICH DAMAGES ARE CLAIMED. IN NO EVENT 

SHALL MANUFACTURER OR SELLER BE LIABLE FOR SPECIAL, INDIRECT OR INCONSEQUENTIAL DAMAGES 

RESULTING FROM THE USE OR HANDLING OF THIS PRODUCT. 

NOTICE TO BUYER 

Purchase of this material does not confer any rights under patents goveming this product or the use thereof in countries 

outside of the United States. Seller's guarantee shall be limited to the terms set out on the label and SUbject thereto, the 

buyer assumes the risk to persons or property arising from the use or handling of this product on that condition. 

2 
70
Page 71-*Confidential Statement of Formula may be entitled to confid