## MSMA Focus Meeting Notes February 13, 2013 ; 2:00

- 4:00 pm Potomac Yards South

, Room 9100



### On February 13, 2013 the EPA MSMA registration review team met with the Organic Arsenicals
Product Task Force ( Luxembou rg

- Pamol and Drexel Chemical Co) and invited st akeholders including representatives from USDA, PBI

- Gordon, the University of Florida, University of Georgia, Mississippi State, the Golf Course Superintendents Association of America, the Georgia Agribusiness Council, the Professional Lawn Care Network, s od grower s, and professional applicators, to discuss the registration review of MSMA.

EPA informed the Task Force that the Environment al Fate and Effects Division (EFED) had expressed interest in having a "focus" meeting to address questi ons that had ari sen as they develop ed their problem formulation for the risk asse ssment
, and that other divisions would also be interested in attending . The registrants were informed that the purpose of this meeting was to clarify any usage uncertainties and other questio ns on label information (e.g., ra tes of application
and timing ) that will be used in the risk assessment , as well as to discuss potential data needs (particularly for ecotoxicity ) and other relevant issues

, such as arsenic speciation modeling, that have ar isen as the science divisions start ed scoping their work.

At the meeting, t he registrants provided background infor mation on MSMA re

- registration and the 2009 Agreement in Principle between the Task Force and EPA . Ongoing work on the carcinogenic mode of action was briefly discussed. The registrants gave EPA an update of their current knowledge regarding the environmental fate of arsenic species and speciation modeling approaches

. The remainder of the meeting , the task force and stakeholders presented be ne fits information for the cotton, sod farm and golf course uses.

The Task F orce does not have thermodynamic data pertaining to the meth ylation/deme thylation of arsenic, or information on speciation modeling in aquatic and soil environments other than what was presented. The registrants and EPA will continue to share information and consult on this issue as a modeling approach is developed

. The Task Force did not provide any additional

e cological toxicity data

, and the use parameters that are not specified on some labels were not provided prior to the mee ting

. During the concluding discussion , some specific usage
information was clarified about the golf course use for the Health Effects Division (HED)

. The Task Force is now working to pr ovide non

- specified use parameters, such as : maximum appli cation rates, frequency of application, application intervals, and maximum number of applications per season. The Agency will work with the Task Force to further clarify MSMA product labels. EPA expects to approximate those parameters that remain unknown in order to conduct a quantitative risk assessment. The need for the information discussed above is indicated in the MSMA Preliminary Work Plan

. At the meeting, EPA also provided the schedule
for t he registration review of MSMA

, which is attached to these notes along with t he meeting agenda, attendees, and questions posed to the registrants

.

## MSMA Focus Meeting Agenda February 13, 2013 ; 2:00

- 4:00 pm



### Introductions

- 10 mins

Science

- 20 mins

- Background

- Questions posed by EPA

- Environmental Fate
Response to EPA Question s

- 30 mins MSMA’s Broad Utility: Current Registered Uses and Tier 3 Uses

- 45 mins

Discussion

- 15 mins

### EPA Registration Review Team in attendance :

BEAD: Bill Phillips, Derek Berwald, Sepehr Haddad HED: Christine Olinger

, Donald Wilbur, Nancy McCarroll Shalu Shelat EFED: Dana Spatz

, James Hetrick

, Melissa Panger , Rosanna Louie

- Juzwiak RD: Kable Davis PRD: Richard Keigwin

, Kevin Costello

, Tom Myers

, Garland Waleko

Guests in attendance :

USDA Harold Coble (call

- in)

Task F orce Michal Eldan , Ph.D., Vice President, Global Regulatory and Scientific Affairs

, Luxembourg

Pamol, Inc.; Charles L. Grizzle, Chairman

, The Grizzle Company ; Scott A. Pace, Di rector of Registration Division

, Drexel Chemical Company; William L. Russ, Luxem bourg

- Pamol, Inc. ; Lynn L. Bergeson, Managing Partner

, Bergeson & Campbell, P.C.

Task Force Guests/Stakeholders Stuart Z. Cohen, Ph.D.

, Environ mental & Tur f Services, Inc.; Chava McKeel

, Senior Manager

, Information and Public Policy

, GCSAA ; Mark Esoda

, Golf Course Superintendent

, Atlanta Athletic Club; Greg Pheneger

, Golf Course Superintendent , J ohn’s Island Club

, Vero Beach, FL ; Jaimie Allen

, Pine Creek Turf Farms ; Dr. John Byrd, Extension/Resea r ch Professor

, Mississippi State University ; Dr. Cl int Wal tz, University of Georgia ; Barry Brecke, University of Florida; Tom Delaney, Professional Lawn Care Network; Kenny Crenshaw

, Herbi

- Systems

, Memphis, TN; Bryan Tolar, Executive Director

, Georgia Agribusiness Council; Jim Kuntsman, Ph.D.

, Director of Regulat ory Services

, PBI/Gordon Corporation; W. Martin Williams, Vice President

- Principal Engineer

, Waterborne Environmental, Inc.

### Schedule for MSMA Registration Review

Docket opening March 2013 End comment period May 2013
Final Work Plan August 2013
Is sue DCI approx. April

- June 2014* Data Submission April

- June 2016
Draft Risk Assessments October

- December 2017 Proposed Registration Review Decision 2019

* Timing after this point depends on the nature of the data requirements

### Qu estions Provided to the Task Force

S peci fic information requested by EFED :

1. EFED is interested in obtaining any th ermo dynamic data pertaining to the methylation/demethylation of Arsenic . Additionally, EFED is interested in any information on speciation modeli ng on the methylation/demethylation of A r s enic in water and soil environments.

2. For the currently registered products and uses, there are several things that EFED will need for modeling that are not specified on the labels and these are noted as 'NS' (a nd highlighted in yellow) in the attached use table. Any clarification on these 'NSs' would be very helpful (and would minimize the need to make conservative assumptions regarding use patterns):

CURRENTLY REGISTERED MSMA USES (Table)(NSs Highlighted).doc x (see attached

, next page of these notes )

3. EFED is interested in any additional data the registrant might have that would help inform the ecological risk assessment, specifically the following ecotoxicology data:

For Methylated Arsenics (+5):

Aqua tic invertebrate (freshwater and estuarine/marine) life

- cycle Freshwater fish life cycle Passerine acute oral Avian reproduction

For Methylated and Inorganic Arsenics (+3):

Whole sediment acute and chronic (freshwater)

### CURRENTLY REGISTERED MSMA USES:

LA BEL/EPA REG. NO. A.I.(S) APP METHOD USE(S) SINGLE MAX. APPL. RATE MAX. NO.

APP. /SEASON MIN. APP.

INTERVAL MAX.

SEASONAL APP.RATE SPECIFIC

COMMENTS GENERAL COMMENTS

QUADMEC ®
TURF HERBICIDE/ 2217

- 709 Monosodium

acid methanearsonate (18% a.i.) [total Arseni c (as elemental) all in water soluble form 8.33%] Ground Newly constructed golf courses (broadcast) 3 lb a.i./acre 1 Not applicable (N/A) 3 lb a.i./acre

(does not include additional spot treatments) None

- Do not apply through any type of irrigation system

- Do not apply to newly seeded turfgrass until after the third mowing

- Do not apply in FL

- Aerial application is prohibited

- After Dec. 31, 2013, applications to golf courses and sod farms are prohibited

- Use only Medium (or coarser) spray nozzles

acc ording to ASABE

- Do not apply at wind speeds > 10 mph

- Do not apply with a nozzle height > 4 ft above the crop
canopy Dimethylamine salt of 2,4

- dichlorophenoxy acetic acid (5.83%) Other golf

courses (spot
treatments only) 1.8 lb

a.i./acre (3 fl oz of product/ 1,000 ft 2 ) NS NS NS 100 ft 2 max per spot; not to exceed 25% of total golf course acreage/yr

Dimethylamine salt of (+)

- (R)

- 2

- (2

- methyl

- 4

- chlorophenoxy)p ropionic acid (2.93%) Sod farms (broadcast) 3 lb a.i./acre 2 30

- day 6 lb a.i./acre (total fo r product) 25 ft buffer from

permanent water or aquatic habitat

Dimethylamine salt of dicamba: 3,6

- dichloro

- o

anisic acid (1.46%) Sod farms (spot treatments) 1.8 lb

a.i./acre (3 fl oz of product/ 1,000 ft 2 ) NS NS 6 lb a.i./acre (total for product) 100 ft 2 max per spot

DrexarTM 530 Herbicide/ 19713

- 40 Monosodium

acid methanearsonate (35.78%) [Total arsenic (as elemental), all in
water

- soluble form is 16.55%) Ground

Aerial Cotton 2 lb a.i./acre 2 (the second application is allowed for a salvage operatio n) 7

- day 4 lb a.i./acre

- Postemergence (do not apply preplant)

- In FL, applications should be confined to band treatments

- 50 ft buffer from permanent water bodies or aquatic habitat

- Do not apply post

- - Do not apply this product

in FL, except fo r cotton in the following counties: Calhoun, Columbia, Escambia, Gadsden, Hamilton, Holmes, Jackson, Jefferson, Okaloosa, Santa Rosa, Suwannee, Walton, and Washington

- The distance of the nozzlesLA BEL/EPA REG. NO. A.I.(S) APP METHOD USE(S) SINGLE MAX. APPL. RATE MAX. NO.

APP. /SEASON MIN. APP.

INTERVAL MAX.

SEASONAL APP.RATE SPECIFIC

COMMENTS GENERAL COMMENTS

bloom must not exceed 3⁄4 the length

of the wingspan or rotor

- App lications must not be made at a height > 10 ft above the top of the largest plants Ground Highway

rights

- of

way NS 2/yr (broadcast) NS NS

- 100 ft buffer from permanent water bodies or aquatic habitat

- Use is prohibited after Dec. 31, 2013 Ground G olf courses

(newly constructed) (broadcast) 2.75 lb

a.i./acre (2 fl oz of product to 1,000 ft 2 ) 1 N/A 2.75 lb a.i./acre (does not include additional spot treatments) - Use is prohibited

after Dec. 31, 2013

Ground Other golf

courses (spot
treatments onl y) 2.75 lb

a.i./acre (2 fl oz of product to 1,000 ft 2 ) NS NS NS

- 100 ft 2 per spot

- Not to exceed 25% of the total golf
course acreage per yr

- Use is prohibited after Dec. 31, 2013 Ground Sod farms

(broadcast) 2.75 lb

a.i./acre (2 fl oz of product to 1,000 ft 2 ) 2 NS 5.5 lb a.i./acre (based on 2 x the max single rate) - 25 ft buffer from

permanent water bodies or aquatic habitat

- Use is prohibited after Dec. 31, 2013

MSMA 6.6 MSMA Liquid/ 19713

- 41 Monosodium

acid methanearsonate (51.3%) [total Arsen ic as elemental) all in water soluble form is 23.61%] Ground

Aerial Cotton 2 lb a.i./acre 2 (the second application is allowed for a salvage operation) 7

- day 4 lb a.i./acre

- Postemergence (do not apply preplant)

- In FL, applications should be confined to band treatments

- 50 ft buffer from permanent water bodies or aquatic habitat

- Do not apply after - Do not apply through any

type of irrigation system

- Do not apply this product in FL, except for cotton in the following counties: Calhoun, Co lumbia, Escambia, Gadsden, Hamilton, Holmes, Jackson, Jefferson, Okaloosa, Santa Rosa, Suwannee, Walton,LA BEL/EPA REG. NO. A.I.(S) APP METHOD USE(S) SINGLE MAX. APPL. RATE MAX. NO.

APP. /SEASON MIN. APP.

INTERVAL MAX.

SEASONAL APP.RATE SPECIFIC

COMMENTS GENERAL COMMENTS

first bloom and Washington

- The distance of the nozzles must not exceed 3⁄4 the length of the wingspan or rotor

- Applications must not be made at a height > 10 ft above the top of the largest plants Ground Highway

rights

- of

way NS 2/yr (broadcast) NS NS

- 100 ft buffer from permanent water bodies or aquatic habitat

- Use is prohibited after Dec. 31, 2013 Ground Golf courses

(newly constructed) (broadcast) 4 l b a.i./acre

(1.8 fl oz of product/ 1,000 ft 2 ) 1 N/A 4 lb a.i./acre

- Use is prohibited after Dec. 31, 2013

Ground Other golf

courses (spot
treatments only) 4 lb a.i./acre

(1.8 fl oz of product/ 1,000 ft 2 ) NS NS NS

- 100 ft 2 per spot

- Not to exceed 25% of the total golf
course acreage per yr

- Use is prohibited after Dec. 31, 2013 Ground Sod farms

(broadcast) 4 lb a.i./acre

(1.8 fl oz of product/ 1,000 ft 2 ) 2 NS 8 lb a.i./acre (based on 2 x max single rate) - 25 ft buffer from

permanent water bodies or aquatic habitat

- Use is prohibited after Dec. 31, 2013 MSMA 6 Plus MSMA Liquid Plus Surfactant/ 19713

- 42 Monosodium

acid methanearsonate (47.6%) [total Arsenic (as elemental), all in
water

- soluble form, is 22%] Aerial

Ground Cotton 2 lb a.i./acre 2 (the second application is allowed for a salvage operation) 7

- day 4 lb a.i./acre

- Postplant (before cotton emergence) and postemergence

- Applications in FL should be confined to band treatments

- Do not apply after first bloom - Do not apply this product

in FL, except for cotton in the following counties: Calhoun, Columbia, Escambia, Gadsden, Hamilton, Holmes, Jackson, Jefferson, Okaloosa, Santa Rosa, Suwannee, Walton, and Washington

- The distance of the nozzles must not exceed 3⁄4 the length of the wingsp an or rotor

- Applications must not be Ground Highway

rights

- of

way 4.5 lb

a.i./acre (broadcast) [4.1 lb a.i./acre for 2/yr

(broadcast) NS 9.0 lb a.i./acre (broadcast) (based on 2 x max single - 100 ft buffer from

permanent water bodies or aquatic habitat

- Use is prohibitedLA BEL/EPA REG. NO. A.I.(S) APP METHOD USE(S) SINGLE MAX. APPL. RATE MAX. NO.

APP. /SEASON MIN. APP.

INTERVAL MAX.

SEASONAL APP.RATE SPECIFIC

COMMENTS GENERAL COMMENTS

‘small areas’] rate) after Dec. 31, 2013 made at a height > 10 ft above the top of the largest plants Ground Golf courses

(newly constructed) (broadcast) 4.0 lb

a.i./acre (2 fl oz of product/ 1,000 ft 2 ) 1 N/A 4.0 lb a.i./acre (do es not include additional spot treatments) - Use is prohibited

after Dec. 31, 2013

Ground Other golf

courses (spot
treatments only) 4.0 lb

a.i./acre (2 fl oz of product/ 1,000 ft 2 ) NS NS NS

- 100 ft 2 per spot

- Not to exceed 25% of the total golf

cours e acreage per yr

- Use is prohibited after Dec. 31, 2013 Ground Sod farms

(broadcast) 4.0 lb

a.i./acre (2 fl oz of product/ 1,000 ft 2 ) 2 NS 8.0 lb a.i./acre (broadcast) (based on 2 x max single rate) - 25 ft buffer from

permanent water bodies or aquati c habitat

- Use is prohibited after Dec. 31, 2013 MSMA 6.6 Liquid/ 19713

- 269 51.0% a.i. [Total

Arsenic (as elemental) all in water soluble form is 23.61%) Aerial

Ground Cotton 2 lb a.i./acre 2 (the second application is allowed for a salvage operation) 7

- day 4.0 lb a.i./acre - Postplant and

postemergence

- Application in FL should be confined to band treatments

- 50 ft buffer from permanent water bodies and aquatic habitats - Do not apply through any

type of irrigation system

- Do not apply this product i n FL, except for cotton in the following counties: Calhoun, Columbia, Escambia, Gadsden, Hamilton, Holmes, Jackson, Jefferson, Okaloosa, Santa Rosa, Suwannee, Walton, and Washington Ground Golf courses

(newly constructed) (broadcast) 4.0 lb

a.i./acre (1 .8 fl oz of product/ 1,000 ft 2 ) 1 N/A 4.0 lb a.i./acre (does not include additional spot treatments) - Use is prohibited

after Dec. 31, 2013

Ground Other golf 4.0 lb NS NS NS

- 100 ft 2 per spotLA BEL/EPA REG. NO. A.I.(S) APP METHOD USE(S) SINGLE MAX. APPL. RATE MAX. NO.

APP. /SEASON MIN. APP.

INTERVAL MAX.

SEASONAL APP.RATE SPECIFIC

COMMENTS GENERAL COMMENTS

courses (spot
treatments only) a.i./acre (1.8

fl oz of product/ 1,000 ft 2 ) - Not to exceed 25% of the total golf
course acreage per yr

- Use is prohibited after Dec. 31, 2013 Ground Sod farms

(broadcast) 4.0 lb

a.i./acre (1.8 fl oz of product/ 1,000 ft 2 ) 2 NS 8.0 lb a.i./acre (broadcast) (based on 2 x max sin gle rate) - 25 ft buffer from

permanent water bodies or aquatic habitat

- Use is prohibited after Dec. 31, 2013 Ground Highway

rights

- of

way NS 2/yr (broadcast) NS NS

- 100 ft buffer from permanent water bodies and aquatic habitats

- Use is prohibited after Dec. 31, 2013 Diumate Herbicide/ 19713

- 528 Monosodium

acid methanearsonate (34.6% a.i.) [Total Arsenic (as elemental) all in water soluble form is 16.00% Aerial

Ground Cotton 2 lb a.i./acre 2/yr (the second application is allowed for a salvage
oper ation) 21

- day 4.0 lb a.i./acre - Do not apply after

first bloom

- Applications in FL should be limited to band treatments

- 50 ft buffer from permanent water bodies and aquatic habitats - Do not apply through any

type of irrigation system

- Use of this pro duct in certain portions of CA, OR, and WA is subject to the Jan. 22, 2004, Order for injunctive relief in Washington Toxics Coalition et al. v EPA C01

- 0143C

- Do not apply this product in FL, except for cotton in the following counties: Calhoun, Columbia, Escambia, Gadsden, Hamilton, Holmes, Jackson, Jefferson, Okaloosa, Santa Rosa, Suwannee, Walton, and Washington

- Make applications when Diuron (5.18% a.i.i) Ground Highway rights

- of

way 5 lb a.i./acre

(1.25 gallon of product/ acre) 2/yr 90

- day 10 lb a.i/acr e (based on 2 x max. single rate) - 100 ft buffer from

permanent water bodies and aquatic habitats

- Use is prohibited after Dec. 31, 2013LA BEL/EPA REG. NO. A.I.(S) APP METHOD USE(S) SINGLE MAX. APPL. RATE MAX. NO.

APP. /SEASON MIN. APP.

INTERVAL MAX.

SEASONAL APP.RATE SPECIFIC

COMMENTS GENERAL COMMENTS

winds ≤ 10 mph

- Apply with medium or coarser spray (ASABE)

- When making ground applications, apply at a height no mo re than 2 ft above the ground or crop
canopy

- For aerial, do not apply at height greater than 10 ft above the ground or crop
canopy MSMA 660 Herbicide/ 19713

- 531 Monosodium

acid methanearsonate (51.3% a.i.) [Total Arsenic (as elemental) all in wat er soluble form is 23.61%) Aerial

Ground Cotton 2 lb a.i./acre 2/yr (the second application is allowed for a salvage operation) 7

- day 4.0 lb a.i./acre - Postemergence

applications

- Applications in FL confined to band
treatments

- 50 ft buffer from
permane nt water bodies and aquatic habitats - Do not apply through any

type of irrigation system

- Do not apply this product in FL, except for cotton in the following counties: Calhoun, Columbia, Escambia, Gadsden, Hamilton, Holmes, Jackson, Jefferson, Okaloosa, Santa Rosa, Suwannee, Walton, and Washington

- Applications must not be made at a height greater than 10 ft above the largest plants Ground Golf courses

(newly constructed) (broadcast) 4.0 lb

a.i./acre (1.8 fl oz of product/ 1,000 ft 2 ) 1 N/A 4.0 lb a.i. /acre (does not include additional spot treatments) - Use is prohibited

after Dec. 31, 2013

Ground Other golf

courses (spot
treatments only) 4.0 lb

a.i./acre (1.8 fl oz of product/ 1,000 ft 2 ) NS NS NS

- 100 ft 2 per spot

- Not to exceed 25% of the total golf
course acreage per yr

- Use is prohibited after Dec. 31, 2013 Ground Sod farms

(broadcast) 4.0 lb

a.i./acre (1.8 fl oz of 2 NS 8.0 lb a.i./acre (broadcast) - 25 ft buffer from

permanent water bod ies or aquaticLA BEL/EPA REG. NO. A.I.(S) APP METHOD USE(S) SINGLE MAX. APPL. RATE MAX. NO.

APP. /SEASON MIN. APP.

INTERVAL MAX.

SEASONAL APP.RATE SPECIFIC

COMMENTS GENERAL COMMENTS

product/ 1,000 ft 2 ) (based on 2 x max single rate) habitat

- Use is prohibited after Dec. 31, 2013 Ground Highway

rights

- of

way NS 2/yr (broadcast) NS NS

- 100 ft buffer from permanent water bodies and aquatic habitats

- Use is prohibited after Dec. 31, 2013 MSMA 120 Arsonate Liquid fo r Postemergence Weed Control/ 19713

- 550 Monosodium

acid methanearsonate (52.8% a.i.) [Total Arsenic (as elemental), all in water

soluble form, is 23.7%] Aerial

Ground Cotton 2 lb a.i./acre 2/yr (the second application is allowed for a salvage operation) 7

- day 4.0 lb a.i./acre - Postemergence

applications

- Applications in FL confined to band
treatments

- 50 ft buffer from permanent water bodies and aquatic habitats - Do not apply this product

in FL, except for cotton in the following counties: Calhoun, Colu mbia, Escambia, Gadsden, Hamilton, Holmes, Jackson, Jefferson, Okaloosa, Santa Rosa, Suwannee, Walton, and Washington

- Do not use through any type of irrigation system Ground Golf courses

(newly constructed) (broadcast) 4.0 lb

a.i./acre (1.8 fl oz of product/ 1,000 ft 2 ) 1 N/A 4.0 lb a.i./acre (does not include additional spot treatments) - Use is prohibited

after Dec. 31, 2013

Ground Other golf

courses (spot
treatments only) 4.0 lb

a.i./acre (1.8 fl oz of product/ 1,000 ft 2 ) NS NS NS

- 100 ft 2 per spot

- Not to exceed 25% of the total golf
course acreage per yr

- Use is prohibited after Dec. 31, 2013 Ground Sod farms

(broadcast) 4.0 lb

a.i./acre (1.8 fl oz of product/ 1,000 ft 2 ) 2 NS 8.0 lb a.i./acre (broadcast) (based on 2 x max single rate) - 25 ft buffer from

permanent water bodies or aquatic habitat

- Use is prohibited after Dec. 31, 2013LA BEL/EPA REG. NO. A.I.(S) APP METHOD USE(S) SINGLE MAX. APPL. RATE MAX. NO.

APP. /SEASON MIN. APP.

INTERVAL MAX.

SEASONAL APP.RATE SPECIFIC

COMMENTS GENERAL COMMENTS

Ground Highway

rights

- of

way 4.5 lb

a.i./acre [4.0 lb a.i./acre (1.8 fl oz of product/ 1,000 ft 2 ) for ‘smaller areas’] 2/yr

(broadcast) NS 9.0 lb a.i/ac re (based on 2 x max. single rate) (does not include applications to ‘smaller areas’) - 100 ft buffer from

permanent water bodies and aquatic habitats

- Use is prohibited after Dec. 31, 2013

TARGET ®
6.6/ 42519

- 1 Monosodium

acid methanearsonate (51.0% a.i .) [Total Arsenic (as elemental) all in water soluble form 23.61%] Aerial

Ground Cotton 2 lb a.i./acre 2/yr (the second application is allowed for a salvage operation) 7

- day 4.0 lb a.i./acre - Postemergence only

- 50 ft buffer from permanent water bodies a nd aquatic habitats - Do not apply this product

through any type of irrigation system

- Do not apply this product in FL, except for cotton in the following counties: Calhoun, Columbia, Escambia, Gadsden, Hamilton, Holmes, Jackson, Jefferson, Okaloosa, Sant a Rosa, Suwannee, Walton, and Washington

- Application should not be made at a height > 10 ft above the top of the largest plants Ground Golf courses

(newly constructed) (broadcast) 2.24 lb

a.i./acre (1 fl oz of product/ 1,000 ft 2 ) 1 N/A 2.24 lb a.i./ac re (does not include additional spot treatments) - Use is prohibited

after Dec. 31, 2013

Ground Other golf

courses (spot
treatments only) 2.24 lb

a.i./acre (1 fl oz of product/ 1,000 ft 2 ) NS NS NS

- 100 ft 2 per spot

- Not to exceed 25% of the total gol f
course acreage per yr

- Use is prohibited after Dec. 31, 2013 Ground Sod farms

(broadcast) 2.24 lb

a.i./acre (1 fl oz of product/ 1,000 ft 2 ) 2 10

- day 4.5 lb a.i./acre (broadcast) (based on 2 x max single rate) - 25 ft buffer from

permanent water bodi es or aquatic habitat

- Use is prohibited after Dec. 31, 2013 Ground Highway

rights

- of

way NS 2/yr (broadcast) NS NS

- 100 ft buffer from permanent water bodies and aquaticLA BEL/EPA REG. NO. A.I.(S) APP METHOD USE(S) SINGLE MAX. APPL. RATE MAX. NO.

APP. /SEASON MIN. APP.

INTERVAL MAX.

SEASONAL APP.RATE SPECIFIC

COMMENTS GENERAL COMMENTS

habitats

- Use is prohibited after Dec. 31, 2013 TARGET ® 6 Plus/ 42519

- 3 Mono sodium

acid methanearsonate (48.3% a.i.) [Total arsenic (as elemental) all in water soluble form 22.3%] Aerial

Ground 2 lb a.i./acre 2/yr (the second application is allowed for a salvage operation) 7

- day 4.0 lb a.i./acre - Post

emergence only

- 50 ft buffe r from permanent water bodies and aquatic habitats - Postemergence only

- Do not apply this product in FL, except for cotton in the following counties: Calhoun, Columbia, Escambia, Gadsden, Hamilton, Holmes, Jackson, Jefferson, Okaloosa, Santa Rosa, Suwann ee, Walton, and Washington

- Application should not be made at a height > 10 ft above the top of the largest plants Ground Golf courses

(newly constructed) (broadcast) 4 lb a.i./acre

(2 fl oz of product/ 1,000 ft 2 ) 1 N/A 4 lb a.i./acre (does not include additional spot treatments) - Use is prohibited

after Dec. 31, 2013

Ground Other golf

courses (spot
treatments only) 4 lb a.i./acre

(2 fl oz of product/ 1,000 ft 2 ) NS NS NS

- 100 ft 2 per spot

- Not to exceed 25% of the total golf
course acreage per yr

- Use is prohibited after Dec. 31, 2013 Ground Sod farms

(broadcast) 4lb a.i./acre

(1 fl oz of product/ 1,000 ft 2 ) 2 NS 8 lb a.i./acre (broadcast) (based on 2 x max single rate) - 25 ft buffer from

permanent water bodies or aquatic habitat

- Use is prohibited after Dec. 31, 2013 Ground Highway

rights

- of

way 4.5 lb

a.i./acre 2/yr

(broadcast) 10 9 lb a.i./acre (broadcast) (based on 2 x max single rate) - 100 ft buffer from

permanent water bodies and aquatic habitats

- Use is prohibited after Dec. 31, 2013