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 (Luxembourg-Pamol and Drexel Chemical Co) and invited stakeholders 

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, sod growers, and 

professional applicators, to discuss the registration review of MSMA. 

EPA informed the Task Force that the Environmental Fate and Effects Division (EFED) had

expressed interest in having a "focus" meeting to address questions that had arisen as they 

developed their problem formulation for the risk assessment, 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 questions on label information (e.g., rates 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 arisen as the science divisions started scoping their work.

At the meeting, the registrants provided background information 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 benefits 

information for the cotton, sod farm and golf course uses. 

The Task Force does not have thermodynamic data pertaining to the methylation/demethylation 

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 

ecological toxicity data, and the use parameters that are not specified on some labels were not 

provided prior to the meeting. 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 provide non-specified use parameters, such as: maximum 

application 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 the registration review of MSMA, which is attached to these notes along with the 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 Questions- 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 Force

Michal Eldan, Ph.D.,Vice President, Global Regulatory and Scientific Affairs , LuxembourgPamol, Inc.; Charles L. Grizzle, Chairman, The Grizzle Company; Scott A. Pace, Director of 

Registration Division, Drexel Chemical Company; William L. Russ, Luxembourg-Pamol, Inc.; 

Lynn L. Bergeson, Managing Partner, Bergeson & Campbell, P.C. 

Task Force Guests/Stakeholders

Stuart Z. Cohen, Ph.D., Environmental & Turf Services, Inc.; Chava McKeel, Senior Manager, 

Information and Public Policy, GCSAA; Mark Esoda, Golf Course Superintendent, Atlanta 

Athletic Club; Greg Pheneger, Golf Course Superintendent, John’s Island Club, Vero Beach, FL; 

Jaimie Allen, Pine Creek Turf Farms; Dr. John Byrd, Extension/Research Professor, Mississippi 

State University; Dr. Clint Waltz, 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 Regulatory 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

Issue 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
Questions Provided to the Task Force

Specific information requested by EFED:

1. EFED is interested in obtaining any thermodynamic data pertaining to the 

methylation/demethylation of Arsenic. Additionally, EFED is interested in any information on 

speciation modeling on the methylation/demethylation of Arsenic 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' (and 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).docx (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):

Aquatic 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:

LABEL/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 

Arsenic (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 

according 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 ft2)

NS NS NS 100 ft2 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 for 

product)

25 ft buffer from 

permanent water or 

aquatic habitat

Dimethylamine 

salt of dicamba: 

3,6-dichloro-oanisic acid 

(1.46%)

Sod farms 

(spot 

treatments)

1.8 lb 

a.i./acre (3 fl 

oz of 

product/ 

1,000 ft2)

NS NS 6 lb a.i./acre 

(total for 

product)

100 ft2 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 

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 post-

- 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 
LABEL/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

- Applications must not be 

made at a height > 10 ft 

above the top of the largest 

plants

Ground Highway 

rights-ofway

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)

2.75 lb 

a.i./acre (2 fl 

oz of 

product to 

1,000 ft2)

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 

only)

2.75 lb 

a.i./acre (2 fl 

oz of 

product to 

1,000 ft2)

NS NS NS - 100 ft2per 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 ft2)

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 

Arsenic 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, Columbia, 

Escambia, Gadsden, 

Hamilton, Holmes, Jackson, 

Jefferson, Okaloosa, Santa 

Rosa, Suwannee, Walton, 
LABEL/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-ofway

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 lb a.i./acre 

(1.8 fl oz of 

product/ 

1,000 ft2)

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 ft2)

NS NS NS - 100 ft2per 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 ft2)

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 wingspan or rotor

- Applications must not be 

Ground Highway 

rights-ofway

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 prohibited 
LABEL/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 

Ground Golf courses plants

(newly 

constructed) 

(broadcast)

4.0 lb 

a.i./acre (2 fl 

oz of 

product/ 

1,000 ft2)

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 (2 fl 

oz of 

product/ 

1,000 ft2)

NS NS NS - 100 ft2per 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 (2 fl 

oz of 

product/ 

1,000 ft2)

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, 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 

in 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 ft2)

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 ft2per spot
LABEL/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 ft2)

- 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 ft2)

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, 2013

Ground Highway 

rights-ofway

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 

operation)

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 product 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-ofway

5 lb a.i./acre 

(1.25 gallon 

of product/ 

acre)

2/yr 90-day 10 lb a.i/acre 

(based on 2 x 

max. single 

rate)

- 100 ft buffer from 

permanent water 

bodies and aquatic 

habitats

- Use is prohibited 

after Dec. 31, 2013
LABEL/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 more 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 water 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 

permanent 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 ft2)

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 ft2)

NS NS NS - 100 ft2per 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 

bodies or aquatic 
LABEL/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 ft2)

(based on 2 x 

max single 

rate)

habitat

- Use is prohibited 

after Dec. 31, 2013

Ground Highway 

rights-ofway

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 for 

Postemergence 

Weed Control/ 

19713-550

Monosodium 

acid 

methanearsonate 

(52.8% a.i.) 

[Total Arsenic 

(as elemental), 

all in watersoluble 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, Columbia, 

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 ft2)

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 ft2)

NS NS NS - 100 ft2per 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 ft2)

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, 2013
LABEL/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-ofway

4.5 lb 

a.i./acre [4.0 

lb a.i./acre 

(1.8 fl oz of 

product/ 

1,000 ft2) for 

‘smaller 

areas’]

2/yr 

(broadcast)

NS 9.0 lb a.i/acre 

(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 and 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, Santa 

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 ft2)

1 N/A 2.24 lb 

a.i./acre (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 ft2)

NS NS NS - 100 ft2per spot

- Not to exceed 25% 

of the total golf 

course acreage per yr

- Use is prohibited 

after Dec. 31, 2013

Ground Sod farms 

(broadcast)

2.24 lb 

a.i./acre (1 fl 

oz of 

product/ 

1,000 ft2)

2 10-day 4.5 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-ofway

NS 2/yr 

(broadcast)

NS NS - 100 ft buffer from 

permanent water 

bodies and aquatic 
LABEL/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

Monosodium 

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

- Postemergence 

only

- 50 ft buffer 

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, 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)

4 lb a.i./acre 

(2 fl oz of 

product/ 

1,000 ft2)

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 ft2)

NS NS NS - 100 ft2per 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 ft2)

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-ofway

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