EPA REGISTRATION FILE #74530-37 
\\\\\\\\\\,,\\\\\1\IU,,'\\\1Ir7 74530- 3 ..., 01. \(0 L \ 

1111111111111111111111111111 

009279343 

U.S. Environmental Protection Agency 

Office of Pesticide Programs 

Registration Division (7S0SP) 

1200 Pennsylvania Ave., N.W. 

Washington, D.C. 20460 

NOTICE OF PESTICIDE: 

(under FIFRA, as amended) 

X Registration 

_ Reregistration 

Name and Address of Registrant (include ZIP Code): 

Helm Agro Inc. 

8295 Tournament Drive, Suite 310 

Memphis, TN 38125 

EP. Date of Issuance: 

Number: 

74530-37 1 5 2009 

Term of Issuance: Conditional 

Name of Pesticide Product: 

Paraquat TC (Technical 

Concentrate) 

On the basis of information furnished by the registrant, the 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 with the Act. The 

acceptance of any name in connection with the registration of a product under tltis Act is not to be construed as giving the registrant a right to 

exclusive use of the name or to its use ifit has been covered by others. 

This product is conditionally registered in accordance with FIFRA section 3( c)(7)(A) provided you 

agree in writing to: 

1. Submit the outstanding data requirements 830.6317 Storage Stability and 830.6320 

Corrosion Characteristics within one year from the date of this letter. 

2. Revise the EPA Registration Number from 74530-xx to 74530-37 on the label. 

3. Add an appropriate EPA Establishment Number to the labeL 

4. Add appropriate Net Contents information to the label. 

Date: 

/- /5 - 01 

EPA Form 8570-6 

2 
page 2 

EPA Reg. No. 74530-37 

The basic formulation CSF [dated June 6, 2008] of the product referred to above, submitted 

in connection with registration under the Federal Insecticide, Fungicide, and Rodenticide Act is 

acceptable. The basic CSF will be added to your file. Please see the attached Confidential 

Appendix regarding one ingredient in your formulation. 

You will submit one (1) copy of your final printed labeling before you release the product 

for shipment. If these conditions are not complied with, the registration will be subject to 

cancellation in accordance with FIFRA section 6(e). A stamped copy of labeling is enclosed for 

your records. If you have any questions, please contact Hope Johnson at 703-305-5410. 

J ames Tompkins 

Product 11anager (25) 

Herbicide Branch 

Registration Division (7505P) 
Paraquat TC 

(Technical Concentrate) 

For Fonnulation of Paraquat Herbicide Products Only 

ACTIVE INGREDIENT 

Paraquat dichloride (l,l '-demetbyl, 4,4'-bipyridinium dichloride) 

INERT INGREDIENTS 

TOTAL 

Contains 3 pounds paraquat cation per gallon. 

Contains emetic. 

EPA Reg. No. 74530-xx 

EPA Establishment No. 

KEEP OUT OF REACH OF CHILDREN 

DANGERIPELIGRO 

POISON 

43.8% 

56.2% 

Si usted no entiende la etiqueta, busque a alguien para que se la explique a usted en detalle. (If you do not 

understand the label, fmd someone to explain it to you in detail). 

• NEVER PUT INTO FOOD, DRINK OR OTHER CONTAINERS 

• IF SWALLOWED, TAKE IMMEDIATE ACTION AS PRESCRIBED IN FIRST AID 

STATEMENT. SYMPTOMS ARE PROLONGED AND PAINFUL. 

Net Contents: 

HELM AGRO Inc. 

8295 Tournament Drive 

Memphis, TN, 38125 

info@helmagro.com 

1 

ACCEPTED 

with COMMENTS 

In EPA Letter Dated 

H: 1 5 2009 

Under the Federal Insecticide 

fungicide, !JJ1d Rodenlitide Act 

as . tUnended,. for. !he p.isticide refPst~rod !l11di:r ePA ~. NQ. 

_ i~S~g~~l_ 
FIRST AID ! 

If swallowed • Speed is essential. Immediate attention is required. If available, 

Give an adsorbent such as activated charcoal, bentonite or Fuller's 

Earth. 

• Call a poison control center or doctor immediately for treatment. 

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

Ifin eyes 

I • Hold eye open and rinse slowly and gently with water for 15 to 20 

mins. 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 fresh air. 

! • If person is not breathing, call 911 or an ambulance. 

• Call a poison control center or doctor for further treatment advice. 

If on skin or clothing • Take off contaminated clothing. 

I 

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

• Call poison control center or doctor for treatment advice. 

! NOTE TO PHYSICIAN 

Administer either activated charcoal (100g for adults or 2glkg body weight in children) or Fuller's 

Earth (15% solution: lliter for adults or 15mglkg body weight in children. 

Note: The use of gastric lavage without administration of an adsorbent has not shown any clinical 

benefit. Do not use supplemental oxygen. Eye splashes from concentrated material should be treated by 

an eye specialist after initial treatment. With the possibility of late onset corneal ulceration, it is advised 

that patients with paraquat eye injuries are reviewed by an eye specialist the day after first presentation. 

Use treatment that is appropriate for chemical burns. Intact skin is an effective barrier to paraquat, 

however contact with irritated or cut skin or repeated contact with intact skin may result in poisoning. 

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

for treatment. 

HOTLINE 

For medical emergencies involving this product, call CHEMTREC 1-800-424-9300. For chemical 

emergency: Spill, leak, fire, exposure, or accident, call CHEMTREC 1-800-424-9300 

2 
PRECAUTIONARY STATEMENTS 

HAZARDS TO HUMANS AND DOMESTIC ANIMALS 

DANGERJPELIGRO 

POISON 

:t: 

May be fatal if swallowed. Corrosive. Causes irreversible eye damage. Fatal if inhaled. Do not breathe 

spray mist or inhale contaminated dust. Do not get in eyes or on clothing. Harmful if absorbed through 

skin. Avoid contact with skin. Wear goggles, face shield or safety glasses. Prolonged or frequently 

repeated skin contact may cause allergic reactions in some individuals. Wash thoroughly with soap and 

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

IMPORT ANT: The effect of swallowing paraquat concentrate is far more severe than that which usually 

results from skin contact or inhalation of contaminated plant dust. This product should not cause injury if 

used according to label instructions. 

When handling or mixing concentrate or when exposure to concentrate is possible, wear: 

• Dust/mist filtering NIOSH approved respirator with any R,P or HE filter 

• Protective clothing (disposable suit/coveralls or long-sleeve shirt and long pants) 

• Full face shield 

• Chemical-resistant gloves (Category A) 

• Chemical resistant apron and shoes plus socks 

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

REMOVE contaminated clothing and wash separately from other laundry before reuse. 

ENVIRONMENTAL HAZARDS 

This product is toxic to wildlife. Do not discharge effluent containing this product into lakes, streams, 

ponds, estuaries, oceans, or public waters unless this product is specifically identified and addressed in a 

National Pollutant Discharge Elimination System (NPDES) permit. Do not discharge effluent containing 

this product to sewer systems without previously notifying the sewage treatment plant authority. For 

guidance, contact your State Water Board or Regional Office of EPA. 

PHYSICAL AND CHEMICAL HAZARD 

This product reacts with aluminum to produce hydrogen gas which may form a highly combustible gas 

mixture. Do not mix or store in containers, tanks, or such systems made of aluminum or having aluminum 

fittings. 

EQUIPMENT/CONT AINER 

Flush all equipment with water after use each day. Paraquat is corrosive to aluminum. Aluminum 

equipment and aluminum structures that are exposed to solution or spillage should be flushed thoroughly 

with water immediately after use. 

SPILLAGE DURING TRANSPORT 

3 
Emergency Action: Notify police and fire departments immediately. For any spill, leak, fire, or 

exposure in the United States, call CHEMTREC 1-800-424-9300. 

KEEP PUBLIC AND ANIMALS away from area. MARK ROADS AND WARN OTHER ROAD 

USERS. WEAR face shield, chemical-resistant gloves, chemical-resistant footwear, and long-sleeve shirt 

and long pants during decontamination operations. 

Clean up spills as soon as possible. Cover spill with generous amount of clay or loam soil to absorb 

liquid, using a stiff broom to ensure intimate contact. Sweep onto shovel and transfer to plastic bag or 

other disposable container. Repeat operations until contaminated surfaces are dry. Finally, hose spill site 

with water, if feasible. 

DIRECTIONS FOR USE 

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

READ ENTIRE LABEL. USE STRICTLY IN ACCORDANCE WITH PRECAUTIONARY 

STATEMENTS AND DIRECTIONS, AND WITH APPLICABLE STATE AND FEDERAL 

REGULATIONS. 

Only for formulation into a herbicide for the following uses: 

TERRESTRIAL FOOD CROP 

Acerola (West Indies cherry), apricot, asparagus, avocado, banana, blackberry, blueberry, boysenberry, 

broccoli, cabbage, Chinese, carrot (including tops), cauliflower, cherry, cocoa, coffee, collards, cucumber, 

eggplant, fig, filbert (hazelnut), garlic, groundcherry (strawberry tomato/tomatillo), guava, hops, 

kiwifruit, lettuce, loquat, macadamia nut (bushnut), manioc (cassava), melons, melons, cantaloupe, 

melons, musk, melons, water, mint, nectarine, olive, onion, papaya, passion fruit, peach, pear, pecan, 

pepino (melonpear), pepper, pepper (chili type), pineapple, pistachio, plum, potato, 

whitlIrish, prune, pumpkin, raspberry (black, red), rhubarb, small fruits, squash (all or unspecified), 

strawberry, sugar beet, taro, walnut (Englishlblack), yam, yautia. 

TERRESTRIAL FOOD + FEED CROP 

Almond, apple, barley, beans, asparagus, beans, dried-type, beans, mung; beans-succulent (lima); beanssucculent (snap), citrus fruits, com (unspecified), com, field, com, pop, com, sweet, cotton (unspecified), 

garbanzos (including chickpeas), grapes, guar, hops, legume vegetables, mint, orchards (unspecified), 

peanuts, peanuts (unspecified), soybeans, edible, spearmint, sugar beet, sugar crops, 

sugarcane, sunflower, tomato, turnip, vegetables (unspecified), wheat. 

TERRESTRIAL FEED CROP 

Alfalfa, barley, beans, clover, crownvetch, legume vegetables, lespedeza, lupine, pastures, sainfoin, 

timothy, trefoil, tyfon, vetch, wheat. 

TERRESTRIAL NON-FOOD CROP 

Agricultural fallow/idleland, airports/landing fields, commerciallindustriallawns, 

commercial/institutionallindustrial, premises/equipment (outdoor), fencecrowslhedgerows, grasses grown 

for seed, industrial areas (outdoor), jojoba, nonagricultural outdoor buildings/structures, nonagricultural 

uncultivated areas/soils, ornamental and/or shade trees, peach (non-bearing, seed beds), recreation area 

lawns, tomato (post-harvest)/ wood protection treatment to forest products (seasoned). 

4 
FORESTRY 

Forest planting (reforestation programs), pine (forestlshelterbelt), shelterbelt plantings. 

TERRESTRIAL NON-FOOD 

Ornamental and/or shade trees, ornamental herbaceous plants, ornamental woody shrubs and vines, noncrop areas such as public airports, electric transformer stations and around commercial buildings. 

OTHERS 

Uses for which USEPA has accepted the required data and/or citations of data that the formulator has 

submitted in support of registration; and uses for experimental purposes that are in compliance with 

USEP A requirements. 

STORAGE AND DISPOSAL 

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

PESTICIDE STORAGE; Store at temperatures above 32° F. Do not contaminate food, foodstuffs, or 

drinking water. Do not store next to feed or food, or transport in or on vehicles containing foodstuffs or 

feeds. For help with any spill, leak, fire or exposure involving this material, call CHEMTREC 1-800-424-

9300. 

PESTICIDE DISPOSAL; Pesticide wastes are acutely hazardous. Improper disposal of excess pesticide 

or rinsate is a violation of Federal law. If these wastes cannot be disposed of by use according to label 

instructions, contact your State Pesticide or Environmental Control Agency, or the Hazardous Waste 

representative at the nearest EPA Regional Office for guidance. 

CONTAINER DISPOSAL: Triple rinse (or equivalent). Offer for recycling or recondition, or puncture 

and di.spose of in a sanitary landfill, or dispose of by other procedures allowed by State and local I 

authonhes. . 

CONDITIONS OF SALE 

AND LIMITATION OF WARRANTY AND LIABILITY 

NOTICE: Read the entire Directions for Use and Conditions of Sale and Limitation of Warranty and 

Liability before buying or using this product. If the terms are not acceptable, return the product at once, 

unopened, and the purchase price will be refunded. 

The Directions for Use of this product must be followed carefully. It is impossible to eliminate all risks 

inherently associated with the use of this product. Crop injury, ineffectiveness or other unintended 

consequences may result because of such factors as manner of use or application, weather or crop 

conditions, presence of other materials or other influencing factors in the use of the product, which are 

beyond the control of Helm Agro US, Inc. or Seller. To the extent consistent with applicable law, all such 

risks shall be assumed by Buyer and User, and Buyer and User agree to hold Helm and Seller harmless 

for any claims relating to such factors. 

Helm warrants that this product conforms to the chemical description on the label and is reasonably fit for 

the purposes stated in the Directions for Use, subject to the inherent risks referred to above, when used in 

accordance with directions under normal use conditions. This warranty does not extend to the use of this 

product contrary to label instructions, or under abnormal conditions or under conditions not reasonably 

foreseeable to or beyond the control of Seller or Helm, and Buyer and User assume the risk of any such 

use. TO THE EXTENT CONSISTENT WITH APPLICABLE LAW, HELM MAKES NO 

WARRANTIES OF MERCHANTABILITY OR OF FITNESS FOR A PARTICULAR PURPOSE 

NOR ANY OTHER EXPRESS OR IMPLIED WARRANTY EXCEPT AS STATED ABOVE. 

5 
To the extent consistent with applicable law, in no event shall Helm or Seller be liable for any incidental, 

consequential or special damages resulting from the use or handling of this product. TO THE EXTENT 

CONSISTENT WITH APPLICABLE LAW, THE EXCLUSIVE REMEDY OF THE USER OR 

BUYER, AND THE EXCLUSIVE LIABILITY OF HELM AND SELLER FOR ANY AND ALL 

CLAIMS, LOSSES, INJURIES OR DAMAGES (INCLUDING CLAIMS BASED ON BREACH 

OF WARRANTY, CONTRACT, NEGLIGENCE, TORT, STRICT LIABILITY OR 

OTHERWISE) RESULTING FROM THE USE OR HANDLING OF THIS PRODUCT, SHALL 

BE THE RETURN OF THE PURCHASE PRICE OF THE PRODUCT OR, AT THE ELECTION 

OF HELM OR SELLER, THE REPLACEMENT OF THE PRODUCT. 

Helm and Seller offer this product, and Buyer and User accept it, subject to the foregoing conditions of 

sale and limitations of warranty and of liability, which may not be modified except by written agreement 

signed by a duly authorized representative of Helm. 

DRAFT submitted to EPA: 06-05-2008; revised and resubmitted to EPA on 01-06-09 

6 
CONFIDENTIAL APPENDIX: 

Please note that one inert ingredient in 

than or equal 

.... V.l.VL<UH is limited to less 

ItJ 
"Bert Volger" 

<bertvolger@comcast.net> 

01/13/200904:43 PM 

Please respond to 

<bertvolger@comcastnet> 

Dear Ms. Johnson, 

To Hope Johnson/DC/USEPAJUS@EPA 

cc "'Marshall Wixson'" <mwixson@helmagro.com> 

bcc 

Subject RE: 74530-GT data matrix revisions 

Thanks for your thorough review and the provided comments. 

Attached you will find an updated Data Matrix (Agency and Public Copy) . 

Please let me know, if there are any further questions or information that 

you might need. 

Thanks, 

Bert 

Consultant for Helm 

c/o Ceres International LLC 

1087 Heartsease Drive 

West Chester, PA 19382 

phone 610-793-3222 

fax 610-793-1708 

bertvolger@comcast.net 

-----Original Message-----

From: Johnson.Hope@epamail.epa.gov [mailto:Johnson.Hope@epamail.epa.gov] 

Sent: Tuesday, January 13, 2009 1:36 PM 

To: bertvolger@comcast.net 

Cc: mwixson@helmagro.com 

Subject: 74530-GT data matrix revisions 

Mr. Volger and Mr. Wixson, 

We are nearing completion of this action, however, I found additional 

issues with the data matrix that need to be corrected, and I apologize 

for the late hour. However, please revise the data matrix and send me a 

revised version as soon as possible. 

Revise the company number from 10102 to 10182 for Syngenta Crop 

Protection in your list of Data Submitters 

Revise "own" status to "pay" status for the Guidelines: Enforcement 

Analytical Method, Melting Point, Vapor Pressure, Dissociation Constant 

and Octanol/water partition Coefficient, as the submitter is Syngenta 

and not yourself. 

Thank you, 

Hope A. Johnson 

U.S. Environmental Protection Agency 

Office of Pesticide Programs 

Registration Division 

Herbicide Branch 

phone: 703-305-5410 

Mail Code 7505P 

"Bert Volger" 

<bertvolger@comc 

I 
ast.net> 

01/06/2009 05:24 

PM 

To 

Hope Johnson/DC/USEPA/US@EPA 

cc 

<mwixson@helmagro.com> 

Please respond 

to 

<bertvolger@comc 

ast.net> 

Subject 

RE: 74530-GT required label 

revisions and data matrix 

revisions 

Dear Ms. Johnson, 

In response to your recent e-mail regarding your specific labeling and 

data 

matrix comments, we would like to provide you with the revised label 

(attached as pdf-file)and EPA Form 8570-35 (Agency and Public Copy, 

attached 

as pdf-files) . 

please let me know, if you have any further questions or need additional 

information. We appreciate your timely review of the subject 

application. 

Sincerely, 

Bert Volger 

Consultant for Helm Agro US, Inc. 

c/o Ceres International LLC 

1087 Heartsease Drive 

West Chester, PA 19382 

phone 610-793-3222 

fax 610-793-1708 

bertvolger@comcast.net 

-- -Original Message--

From: Johnson.Hope@epamail.epa.gov [mailto:Johnson.Hope@epamail.epa.gov) 

Sent: Tuesday, January 06, 2009 11:56 AM 

To: bertvolger@comcast.net; mwixson@helmagro.com 

Subject: 74530-GT required label revisions and data matrix revisions 

Mr. Volger, Mr. wixson, 

The following label revisions are required to the pending label for 

74530-GT. Please email me a revised PDF version of the label 

incorporating the following comments as soon as possible. I am still 

awaiting the review from TRB on your recently submitted data: 

Revise the color of the word POISON to RED on pages 1 and 2. 

Add the skull and crossbones symbol near the word POISON on page 2. 

Revise the order of the FIRST AID Statements to: 1) If Swallowed, 2) 

If In Eyes, 3) If Inhaled, 4) If on skin or clothing 
Revise the first paragraph of the precautionary Statements text to 

the following: 

"May be fatal if swallowed. Corrosive. Causes irreversible eye 

damage. Fatal if inhaled. Do not breathe spray mist or inhale 

contaminated dust. Do not get in eyes or on clothing. Harmful if 

absorbed through skin. Avoid contact with skin. Wear goggles, face 

shield or safety glasses. Prolonged or frequently repeated skin contact 

may causes allergic reactions in some individuals. Wash 

thoroughly with soap and water after handling and before eating, 

drinking, chewing gum, or using tobacco." 

Revise "waterproof gloves, waterproof footwear" on page 3 to 

"chemical-resistant gloves, chemical-resistant footwear" 

Remove "oats" from page 4 under Terrestrial Food + Feed Crop section. 

Remove "or clean of equipment" from the statement "Do not contaminate 

water, food, or feed by storage, disposal, or cleaning of equipment." 

On page 5, revise "should" to "must" in the statement "The Directions 

For Use of this product should be followed carefully" 

On page 5, add "To the extent consistent with applicable law before 

the following statements: 

1) All such risks shall be assumed by Buyer and User ..... . 

2) HELM MAKES NO WARRANTIES OF MERCHANTABILITy .... . 

3) In no event shall Helm or Seller be liable for ........ . 

4) THE EXCLUSIVE REMEDY OF THE USER OR BUYER ............. . 

Also, please revise your data matrix to add Company numbers to the 

members of the PDSL that you are citing on pages 3 and 4. Please note 

that Syngenta Crop Protection Inc has 2 separate company numbers and 

needs to have 2 separate listings, and you are missing Sinon 

Corporation. Please resubmit the revised data matrix as soon as 

possible. 

Thank you, 

Hope A. Johnson 

U.S. Environmental Protection Agency 

Office of Pesticide Programs 

Registration Division 

Herbicide Branch 

Phone: 703-305-5410 

Mail Code 7505P 

[attachment "Label Paraquat TC revised per EPA's comments 010609.pdf" 

deleted by Hope Johnson!DC!USEPA!US] [attachment "Paraquat dichloride 

EPA Data Matrix Form 8570-35 Agency Copy 010609.pdf" deleted by Hope 

Johnson!DC!USEPA!US] [attachment "Paraquat dichloride EPA Data Matrix 

Form 8570-35 Public Copy 010609.pdf" deleted by Hope 

Johnson!DC!USEPA!US] 

090113 Paraquat TC EPA Data Matri:>< EPA form 8570·35 revised Agency copy. pdf 

090113 Paraquat TC EPA Data Matrix EPA form 8570-35 revised Public copy. pdf 
UNJTEI) STATES ENVIRONMENTAL· PROTECTION A(!n,:NCY 

4U1 M Street;S.W. 

WASHINGTON, D.C. 20460 

"-_ .. -... '"'-=.--.-'""'-="'--"."~-.. -. .~~.. -.• """,-,,",~ .... --., .. -~-'-~'---'--'...-..;.. 

nATA 

"""""","", .o_,ne 

._..,.--.,..".,....:-:,----,.,---.-, , ...... "'..,.. ,~:;:">;~~~~-."""-. -, 

~~iihfl't1tHi::kr: 
UNJTEOSTAjEseNV1~ONMI:N'tAL PROTeCTION AGE;NCY 

4tH MStraet, $.W:. 

WASHtNGTON, D,C.~0460: 

~.. -= __ .. _ ... _._-=""w~,,,,,,,,,,· 

l·· ~-.-... """ .... ,-.. -.. " .. ~,.~~' .. ~,~ .. ,,-,!: . .. ,.""" ... ~..;.....",.~ 

;$ij~mitl~r 

;.~>._._:....'''',.....,'''.''''''''''.'''''.,_".;,w 

·-"c"'4~--'-·~"-~~· 

.1 -.. --.~--.. - .. ~ 
"~~~"'"~" ........ _ .._ ... -·~---:"C"-~~-~'7~---~--'-----·~---'---,-..-.~·~--_-c'-'--·~;.;;"-"-~------·~Form-;~~rN;jamu:oo~-T 

UNftE()·STATES ENViRONMeNTAL .PROTECTtONAGENCY 

. 40iM Streetl s:w" 

WASHtNGTON. 0,(;.20460· 

;..f>f~;';';"~";:';-"n,:.. ··~""""":-"~--.:.-.-----f'i;""'~~· :...::.:-,-., ~-----~-".-' --"""'~"""!';?:~;"~""""'''''~' ~:",~.-.,.....,.,:..",~.;...., 

--~--~'----~~'-~-' ----

Note 

.---,-+--~ ~-"""""'''''''' ... '''''.: ~ 

'''''~r--'-'''l''''''~----'':'''''"'\~i "":~~~ 

~ .. --• ...;;.~-. _._. ,'.,'-, 4--- I : 

,.;...."'''~" 

-' -' ~i~-'-··,,--·;""';';;~-"---'~-
D~t~; 

UNITEOSTATES ENVIRONMENiALPROTECTION AGENCY 

4lJ1 M Street, S,W. 

WASHINGTON, D.C. 20480 

OATAMATRIX 

a2ifl5'.T()um~mentQti\le, SiJ\te :1 'Hi 

_ .•. ~_, .. ~ _._"". __ "._ Stloftlittet f'klte 

Genef~;;:~~~;;-~~~--~--~--~--~i-~----'~Ol~i~~--~--~~~~~~~~SE~~ir~~~~~~~~~~=:~::~~~:J -~----"""-='~'~-'~'.':::':'. ",. 1_"""·"· __ ",,,,, 

.0>-.......;'--.".,... ,,;.. j 

11 \---"-"'''"'~~'' ,,,,,--«w,,-·,1-· -.-. -.... ~ ..• -. I ."~,,. ~''''''' 

'~"""""""-.-:'7t"'~'~"""""»-r"~ ,-"-~-,,,-·,,·,,;;,"~·f-·-'·"···-"·····"··'-"'·«~-~··-·-·-" -,," --'---'--~-

F-~~ ... -~~-""--· ~.«-~'~-.-' '-".~,,~,-. ..,--_---+-_ .• ~~" ......... "' ... __ ~~..,ry.,- --~.--,-, 

.• """"'i"'., ...... ~., ..... "":""~";..,"':...";;;.;.;;,; ....... ,.,..,,.w.-.v; ..... '.~!'.,,."_. __ .~ .. _",,,, .. ,,,,,, ... ;,.x~~,,,;;; .• :;:"";';"';~"""'.J"'.!i.,;~ .. I"M';"""\·.";'.'_;"':w,."""'''' ....... _''''''' ....... :...._¥.;,.._:. .. _~~ 
EPA File Symbol Number 74530-GT: 

NOTE TO FILE; 

TRB has not concluded that this product is substantially similar to 70552-1, as the 

Registrant has stated in prior documents. TRB concluded it could not be substantially 

similar because the nominal concentration of the active ingredient in the proposed 

product is lower than the lower certified limit of the cited product. However, all data 

requirements for product chemistry, except for storage stability and corrosion 

characteristics have been met, and the acute toxicology data has been reviewed and 

accepted. Therefore, the generic data for paraquat dichloride can be cited, and the 

Registrant has submitted a data matrix with appropriate citations to the Pesticide Data 

Submitters List to pay for the generic data. 

Therefore, HB will conditionally register this product per Section 3(c)7(a) ofFIFRA, as 

approving this application would not significantly increase the risk of any umeasonable 

adverse effect on the environment. 

1113/2009 

Hope Johnson 

PM Team 25 

Herbicide Branch 
Hope 

Johnson/DCIUSEPNUS 

.. 01113/200901:35 PM 

Mr. Volger and Mr. Wixson, 

To <bertvolger@comcast.net> 

cc mwixson@helmagro.com 

bcc 

\ 

Subject 74530-GT data matrix revisions~ 

We are nearing completion of this action, however, I found additional issues with the data matrix that need 

to be corrected, and I apologize for the late hour. However, please revise the data matrix and send me a 

revised version as soon as possible. 

Revise the company number from 10102 to 10182 for Syngenta Crop Protection in your list of Data 

Submitters 

Revise "own" status to "pay" status for the Guidelines: Enforcement Analytical Method, Melting Point, 

Vapor Pressure, Dissociation Constant and OctanollWater Partition Coefficient, as the submitter is 

Syngenta and not yourself. 

Thank you, 

Hope A. Johnson 

U.S. Environmental Protection Agency 

Office of Pesticide Programs 

Registration Division 

Herbicide Branch 

Phone: 703-305-5410 

Mail Code 7505P 

"Bert Volger" <bertvolger@comcast.net> 

"Bert Volger" 

<bertvolger@comcast.net> 

01/06/200905:24 PM 

Please respond to 

<bertvolger@comcast.net> 

Dear Ms. Johnson, 

To Hope Johnson/DC/USEPNUS@EPA 

cc <mwixson@helmagro.com> 

Subject RE: 74530-GT required label revisions and data matrix 

revisions 

In response to your recent e-mail regarding your specific labeling and data 

matrix comments, w.e would like to provide you with the revised label 

(attached as pdf-file)and EPA Form 8570-35 {Agency and Public Copy, attached 

as pdf-files}. 

Please let me know, if you have any further questions or need additional 

information_ We appreciate your timely review of the subject application. 

Sincerely, 

Bert Volger 

Consultant for Helm Agro US, Inc. 

c/o Ceres International LLC 

1087 Heartsease Drive 

West Chester, PA 19382 
phone 610-793-3222 

fax 610-793 1708 

bertvolger@comcast.net 

-----Original Message--

From: Johnson.Hope@epamail.epa.gov [mailto:Johnson.Hope@epamail.epa.gov] 

Sent: Tuesday, January 06, 2009 11:56 AM 

To: bertvolger@comcast.neti mwixson@helmagro.com 

Subject: 74530-GT required label revisions and data matrix revisions 

Mr. Volger, Mr. Wixson, 

The following label revisions are required to the pending label for 

74530-GT. Please email me a revised PDF version of the label 

incorporating the following comments as soon as possible. I am still 

awaiting the review from TRB on your recently submitted data: 

Revise the color of the word POISON to RED on pages 1 and 2. 

Add the skull and crossbones symbol near the word POISON on page 2. 

Revise the order of the FIRST AID Statements to: 1) If Swallowed, 2) 

If In Eyes, 3) If Inhaled, 4) If on skin or clothing 

Revise the first paragraph of the Precautionary Statements text to 

the following: 

"May be fatal if swallowed. Corrosive. Causes irreversible eye 

damage. Fatal if inhaled. Do not breathe spray mist or inhale 

contaminated dust. Do not get in eyes or on clothing. Harmful if 

absorbed through skin. Avoid contact with skin. Wear goggles, face 

shield or safety glasses. Prolonged or frequently repeated skin contact 

may causes allergic reactions in some individuals. Wash 

thoroughly with soap and water after handling and before eating, 

drinking, chewing gum, or using tobacco." 

Revise "waterproof gloves, waterproof footwear" on page 3 to 

"chemical-resistant gloves, chemical-resistant footwear" 

Remove "oats" from page 4 under Terrestrial Food + Feed Crop section. 

Remove "or clean of equipment" from the statement "Do not contaminate 

water, food, or feed by storage, disposal, or cleaning of equipment." 

On page 5, revise "should" to "must" in the statement "The Directions 

For Use of this product should be followed carefully" 

On page 5, add "To the extent consistent with applicable law before 

the following statements: 

i) All such risks shall be assumed by Buyer and User ..... . 

2) HELM MAKES NO WARRANTIES OF MERCHANTABILITy .... . 

3) In no event shall Helm or Seller be liable for ... ..... . 

4) THE EXCLUSIVE REMEDY OF THE USER OR BUYER. " ... ' ....... . 

Also, please revise your data matrix to add Company numbers to the 

members of the PDSL that you are citing on pages 3 and 4. please note 

that Syngenta Crop Protection Inc has 2 separate company numbers and 

needs to have 2 separate listings, and you are missing Sinon 

Corporation. Please resubmit the revised data matrix as soon as 

possible. 

Thank you, 

Hope A. Johnson 

U.S. Environmental Protection Agency 

Office of Pesticide Programs 

Registration Division 

Herbicide Branch 
Phone: 703-305-5410 

Mail Code 7505P 

[attachment "Label Paraquat TC revised per EPA's comments 010609.pdf" deleted 

by Hope Johnson/DC/USEPA/US] [attachment "Paraquat dichloride EPA Data Matrix 

Form 8570-35 Agency Copy 010609.pdf" deleted by Hope Johnson/DC/USEPA/US] 

[attachment "Paraquat dichloride EPA Data Matrix Form 8570-35 Public Copy 010609.pdf' deleted by 

Hope JohnsonlDC/USEPAlUS] 
DATE OUT: 01/09/09 

SUBJECT: FEE PRODUCT CHEMISTRY REVIEW OF MP [ ] 

DP BARCODE No.: D359512 REG. No.lFile Symbol No. 74530-GT 

PRODUCT NAME: PARAQUAT TC 

PCC: 061601 Decision No. 393061 

FOOD USE [X] 

COMPANY: HELM AGRO US, INC. 

FROM: 

. 0~d\ r~ "o\.'\ \~ 0\\ 

lndi Gairola, Chemist 

Ptbduct Chemistry Team 

Technical Review BranchIRD (7505P) 

TO: James Tompkins /Hope Johnson PM 25 

Herbicide BranchIRD (7505P) 

INTRODUCTION: 

EP [X] 

In response to the Agency letter dated 10/28/08 HELM AGRO US, INC. has submitted 

details regarding the unidentified impurities in the subject PARAQUAT TC. 

The submitted package was reviewed and details will be discussed below: 

SUMMARY OF FINDINGS: 

1. Applicant has submitted information regarding toxicological significance of 

unidentified impurities. 

2. Applicant has satisfied requirements of 40 CFR§158.320 (c) and (d). 

For details please refer to the CONFIDENTIAL APPENDIX. 
CONCLUSIONS: 

1. TRB has reviewed for the submitted details regarding the unidentified impurities in 

the subject PARAQUAT TC and has concluded that the identified impurities are of nontoxicological concern. 

2 Applicant has satisfied requirements of 40 CFR§ 158.320 (c) and (d 

Please refer to the Confidential Appendix for details 
EPA Registration File #75430-37 

Page is not included in this copy. 

Pages 24 through 26 are not included in this copy. 

The material not included contains the following type of 

information: 

Identity of product inert ingredients. 

Identity of product impurities. 

x Description of product manufacturing process. 

Description quality control procedures. 

Identity of source of product ingredients. 

Sales or other commercial/financial information. 

A draft product label. 

The product confidential statement of formula. 

Information about a pending registration action. 

FIFRA registrat data. 

The document a duplicate of page(s) 

The document not responsive to the request. 

Internal de information. -------

Attorney-Client work product. 

Claimed Confident by submitter upon submission to the 

Agency. 

Personal Privacy Information 

The information not luded is generally considered confident 

by product registrants. you have any questions, contact 

the individual who prepared the response to your request. 
.. Bert Volger" 

<bertvolger@eomcast.net> 

01/06/200905:24 PM 

Please respond to 

<bertvolger@eomeast.net> 

Dear Ms. Johnson, 

To Hope Johnson/DC/USEPA/US@EPA 

ee <mwixson@helmagro.eom> 

bee 

Subject RE: 74530-GT required label revisions and data matrix 

revisions 

In response to your recent e-mail regarding your specific labeling and data 

matrix comments, we would like to provide you with the revised label 

(attached as pdf-file}and EPA Form 8570-35 (Agency and Public Copy, attached 

as pdf-files) . 

Please let me know, if you have any further questions or need additional 

information. We appreciate your timely review of the subject application. 

Sincerely, 

Bert Volger 

Consultant for Helm Agro US, Inc. 

c/o Ceres International LLC 

1087 Heartsease Drive 

West Chester, PA 19382 

phone 610-793 3222 

fax 610-793-1708 

bertvolger@comcast.net 

- ---Original Message----

From: Johnson.Hope@epamail.epa.gov [mailto:Johnson.Hope@epamail.epa.gov] 

Sent: Tuesday, January 06, 2009 11:56 AM 

To: bertvolger@comcast.neti mwixson@helmagro.com 

Subject: 74530-GT required label revisions and data matrix revisions 

Mr. Volger, Mr. Wixson, 

The following label revisions are required to the pending label for 

74530-GT. Please email me a revised PDF version of the label 

incorporating the following comments as soon as possible. I am still 

awaiting the review from TRB on your recently submitted data: 

Revise the color of the word POISON to RED on pages 1 and 2. 

Add the skull and crossbones symbol near the word POISON· on page 2. 

Revise the order of the FIRST AID Statements to: 1) If Swallowed, 2} 

If In Eyes, 3} If Inhaled, 4) If on skin or clothing 

Revise the first paragraph of the Precautionary Statements text to 

the following: 

"May be fatal if swallowed. Corrosive. Causes irreversible eye 

damage. Fatal if inhaled. Do not breathe spray mist or inhale 

contaminated dust. Do not get in eyes or on clothing. Harmful if 

absorbed through skin. Avoid contact with skin. Wear goggles, face 

shield or safety glasses. Prolonged or frequently repeated skin contact 

may causes allergic reactions in some individuals. Wash 

thoroughly with soap and water after handling and before eating, 

drinking, chewing gum, or using tobacco." 

Revise "waterproof gloves, waterproof footwear" on page 3 to 

"chemical-resistant gloves, chemical-resistant footwear" 
Remove "oats" from page 4 under Terrestrial Food + Feed Crop section. 

Remove "or clean of equipment" from the statement "Do not contaminate 

water, food, or feed by storage, disposal, or cleaning of equipment." 

On page 5, revise "should" to "must" in the statement "The Directions 

For Use of this product should be followed carefully" 

On page 5, add "To the extent consistent with applicable law before 

the following statements: 

1) All such risks shall be assumed by Buyer and User ..... . 

2) HELM MAKES NO WARRANTIES OF MERCHANTABILITy .... . 

3) In no event shall Helm or Seller be liable for ........ . 

4) THE EXCLUSIVE REMEDY OF THE USER OR BUyER ............. . 

Also, please revise your data matrix to add Company numbers to the 

members of the PDSL that you are citing on pages 3 and 4. please note 

that Syngenta Crop Protection Inc has 2 separate company numbers and 

needs to have 2 separate listings, and you are missing Sinon 

Corporation. Please resubmit the revised data matrix as soon as 

possible .. 

Thank you, 

Hope A. Johnson 

U.S. Environmental Protection Agency 

Office of Pesticide Programs 

Registration Division 

Herbicide Branch 

Phone: 703-305-5410 

Mail Code 7505P 

Label Paraquat TC revised per EPA's comments 01 OG09.pdf 

Paraquat dichloride EPA Data M I 8570·35 Agency Copy 010G09.pdf 

Paraquat dichloride EPA Data Matrix Form 8570·35 Public Copy 010G09.pdf 
UNITEOSTATE$ ENVtRONMENTAL PROTECTfON AGENCY 

401 MStreet, S.W. 

WASHINGTON, D.C. 20460 

,," __ ".-i»' ,;.,.~~,~~~. ___ ~_,..,,-,--_. __ ~~'...r""""w;~~»''''''''''_'~' _~~ __ .. _,w;..~ ___ ~:.,_~""_"",~~""""",-,,,,,,_. ----,,.,,"""'---~ 

Pa~f..Re(;\uQtjorl.Ac~ 

tesprmsef9r 

Pthi'!f tisP13d 

A 

~ ..... -~-.. -•.. - ... I Date:: Otj0610$ . 

,~----,-'-.,--""""",~~~, ... _;.<W~ __ '",¥,-..",.;.,';" ,;,.;...------.,..,--'--~,.,""'~, 

OATAIlltATRIX 

EPA OJ 

ParaquaiTC 

.... ::.:.: ' 

,.....;...:C-,.....;."---"-"'--' __ -' _____ ~.-.. ,,-,--. -. -----.,,---""'-c--"'--....;..-'--. 

MRIDNtlttlt;et ;Submitter 

us. Inc. 

:~;~9~-+"~~m~--j.~~~~~=1.0wll Own 

~-... - .. -","'.,-------"-1 

.oWn 

-

C~rtff~Uini\s NJA ,4.....,.,,··"-.,.;.4- -I 

Own 

QWll . __ ~~-,-.....".~~,,",',c-.' "4-'-,-'~""""""'-"'''"----~-

Own 

Ag~(Jcy In1emalUsa 
. UNtTEDST.ATES ENViRONMENTAL PROTECTION AGENCY 

401M$treet, S.W, 

WASHINGTON, DyC, 26460 

""~ .. ~- ~ ~";';'--"'~'-.. -~~--"--.-..... -~-, .. --.,,~-.~ . ......,,-,'"----"- ."""''''''--.,;....~~=-, 

'-=::::::~~~::~~~AJ~~~i=~~~I:!r:):~:~:li:'~'~~I:I:g:l:n:;:;n~N:~~i~:n:f~'~13~~~~~::::~::~ OilOslG}l ~ DAtA 

==~~~I~""S~;~;~~;;~'--"~~~-~==~= MATRIX 

. T-' '-,-.....,.»»~..... . S -~'~Nw~.'''_· -.~ .. ~. '~'-'-"'-"-'=-~l' < . "',.~"'''' .... ~-. -' ----""'i 

Number I. Submitter r S!atu~ 

leal 

I~""M' ~ ,,:,_-':-' ~I .. I" 

47:389104 

4~t3a$i'Q4 
lJNJft:OSiATES ENVIRONMENTAL PROTECTION AGENCY 

401 MStreat,S.W. 

WASHINGTON,O.C,20460 

. tfA TAMA!RlX . . r '~~i'.","; .. ,~_,--,,"-~~,--=-

Pmduc{; 

OOneSI'>ClflSO, 

. _,--~",-,-c' _".~ •• ',-~"._<,-",<M."' ··~-;""··.;";';"'·-·=-'·T-'-'·"""'-~-"r' ._-......,...,.,...--,...----_ .•. 

G~(d~ll!1a ShJdy Nam~ MRIDNumoor • Si,lbmitter . Status Nole 

47001. Pl.)y 

47691ttl8 

""""-,,----~.---. 

~'01<>""'.'; 
UNITED STATES E:NVlflONMENTAL PROTECTION AGENCY 

401 MStrest,S. W, 

WASHINGTON, 2046{) 

:';"'''?'"'''~,,*~_. _. _'_. __ ',~.»~., ~~ __ . _~: __ "";". ~ ...... _~.~~w,_,_.,....-,-c..;,..,...;;"-...;.;. __ ~~ 

DATA MATRIX 

""'.";>",'.<;1 310 

Paraqwa~ di~t\lbride 

Status N91e 

, .... 6:~ 

TasK:jZo~, 

L ,,~' '~~-~'"""""~ "--~.~~;;-~ .J 

,1 .~ :ce-~"",-~'-F"+:"--"-' .J 1+ 

1" 'I: ',~.:~ ~~~4 ,~.. 'I ",,-'-,.. '·1 

Inc. 
Form Approved OMB No. 2070-0060 

,~\ UNITED STATES ENVIRONMENTAL PROTECTION AGENCY \.~ ~ll'RJ'.ff'~ 401 M Street, S.W. 

WASHINGTON, D.C. 20460 

Paperwork Reduction Act Notice: The public reporting burden for this collection of information is estimated to average 1.25 hours per response for registration 

and 0.25 hours per response for reregistration and special review activities, including time for reading the instructions and completing the necessary forms. Send 

comments regarding burden estimate or any other aspect of this collection of information, including suggestions for reducing the burden to: Director, OPPE 

Information Management Division (2137), U.S. Environmental Protection Agency, 401 M Street, S.w., Washington, DC 20460. 

Do not send the completed form to this address. 

Certification with Respect to Citation of Data 

Applicant's/ReQistranfs Name, Address, and Telephone Number EPA ReQistration Number/File Symbol 

Helm Agro US, Inc. 8295 Tournament Drive, Suite 310 Memphis, TN 38125 74530 - x 

Active Inqredient(s) and/or reoresentative test comoound(s) Date 

Paraquat dichloride April 30, 2008 

General Use Pattern(s) (list all those claimed for this product usinQ 40 CFR Part 158) Product Name 

Terrestrial Non Food, and Terrestrial Nonfood use sites Paraquat TC 

NOTE: 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 

submit this form. You must submit the Formulator'S Exemption Statement (EPA Form 8570-27). 

D I am responding to a Data-Call-In Notice, and have included with this form a list of companies sent offers of compensation (the Data Matrix form should 

be used for this purpose). 

SECTION I: METHOD OF DATA SUPPORT (Check one method only) 

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

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

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

used). 

SECTION II: GENERAL OFFER TO PAY 

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

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

, o '*' 

, , > 

SECTION III: CERTIFICATION ) " 

, ) ) 

;; '} 3 1> 

I certify that this application for registration, this form for reregistration, or this Data-Call-In response is supported b~ all datoi submitted or cited in the 

application for registration, the form for reregistration, or the Data-Call-In response. In addition, if the cite-all option or cite-all Jliti~,i illJder the selective method is 

indicated in Section I, this application is supported by all data in the Agency's files that (1) concern the properties or effects of thi", pro~uct or an identical or 

substantially similar product, or one or more of the ingredients in this product; and (2) is a type of data that would be required to be~sLbmitted 11n1J'l)r t~f7. data 

requirements in effect on the date of approval of this application if the application sought the initial registration of a product of idil'lt;tal,or simila'r cOI'n~osition and 

uses. } , , ) 

;: ?, 

I certify that for each exclusive use study cited in support of this registration or reregistration, that I am the original data submitter oriha11.have obtained 

the written permission of the original data submitter to cite that study. ' •• , 

3 , > 

I certify that for each study cited in support of this registration or reregistration that is not an exclusive use study, either: (a) I am the o,li!'lincll data 

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

compensation have expired for the study; (d) the study is in the public literature; or (e) I have notified in writing the company that submitted the study and have 

offered (I) to pay compensation to the extent required by sections 3(c)(1)(F) and/or 3(c)(2)(B) of FIFRA; and (ii) to commence negotiations to determine the 

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

I certify that in all instances where an offer of compensation is required, copies of all offers to pay compensation and evidence 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 to the Agency upon request, I understand that the Agency may initiate action to deny, cancel or suspend the registration of my product in conformity with 

FIFRA. 

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

knowingly false or misleading statement may be punishable by fine or imprisonment or both under applicable law. 

Signature~ Date Typed or Printed Name and Title 

April 30, 2008 Marshall Wixson, Manager Product Development 

EPA Form 8570-34 (9-97) ElectrOniC and Paper versions available. Submit only Paper version. 
\ 

) '\ , 

Hope 

JohnsonlDC/USEPAIUS 

To bertvolger@comcast.net, mwixson@helmagro.com 

cc 

... 01/06/200911 :55 AM 

bcc 

Subject 74530-GT required label revisions and data matrix revisions 

Mr. Volger, Mr. Wixson, 

The following label revisions are required to the pending label for 74530-GT. Please email me a revised 

PDF version of the label incorporating the following comments as soon as possible. I am still awaiting the 

review from TRB on your recently submitted data: 

- Revise the color of the word POISON to RED on pages 1 and 2. 

- Add the skull and crossbones symbol nearthe word POISON on page2. 

- Revise the order of the FIRST AID Statements to: 1) If Swallowed, 2) If In Eyes, 3) If Inhaled, 4) If on 

skin or clothing 

- Revise the first paragraph of the Precautionary Statements text to the following: 

"May be fatal if swallowed. Corrosive. Causes irreversible eye damage. Fatal if inhaled. Do not 

breathe spray mist or inhale contaminated dust. Do not get in eyes or on clothing. Harmful if 

absorbed through skin. Avoid contact with skin. Wear goggles, face shield or safety glasses. Prolonged 

or frequently repeated skin contact may causes allergic reactions in some 

individuals. Wash thoroughly with soap and water after handling and before eating, drinking, chewing 

gum, or using tobacco." 

- Revise "waterproof gloves, waterproof footwear" on page 3 to "chemical-resistant gloves, 

chemical-resistant footwear" 

- Remove "oats" from page 4 under Terrestrial Food + Feed Crop section. 

- Remove "or clean of equipmenf' from the statement "Do not contaminate water, food, or feed by 

storage, disposal, or cleaning of equipment." 

- On page 5, revise "should" to "must" in the statement "The Directions For Use of this product should be 

followed carefully" 

- On page 5, add "To the extent consistent with applicable law before the following statements: 

1) All such risks shall be assumed by Buyer and User ..... . 

2) HELM MAKES NO WARRANTIES OF MERCHANTABILITY ..... 

3) In no event shall Helm or Seller be liable for ..... . 

4) THE EXCLUSIVE REMEDY OF THE USER OR BUYER. ..... . 

Also, please revise your data matrix to add Company numbers to the members of the PDSL that you are 

citing on pages 3 and 4. Please note that Syngenta Crop Protection Inc has2 separate company numbers 

and needs to have 2 separate listings, and you are missing Sinon Corporation. Please resubmit the 

revised data matrix as soon as possible. 

Thank you, 

Hope A. Johnson 

U.S. Environmental Protection Agency 

Office of Pesticide Programs 

Registration Division 

Herbicide Branch 

Phone: 703-305-5410 

Mail Code 7505P 
DATA PACKAGE BEAN SHEET 

Date: 09-Dec-2008 

Page 1 of3 

'" '" .. Registration Information"''' 'I\' 

Decision #: 393061 

DP #: (359512) 

PRIA 

Parent DP #: 

Submission #: 8401 

Registration: I1'~~l:fl~~~!J~ _______________ _ 

Company;~~~==~~~~~~ ____________________________________ __ 

Risk Manager: --~~~~~~~~~~~~~~~~~~~-------

Risk Manager Reviewer: ~~~--~~~~~------------------------

Sent Date: ~~'.:::.'.:~_ Edited Due Date: 

Type of Registration: ~~~~~~!!..:.:~~~ 

A~on~c:~~~~~~~~~~~~~~~~~~~~~~~~~~~~~ 

.. -I< .. Data Package Information" '* '* 

Expedite: 0 Yes. No Dale Sent: ~~~~:..- Due Back: 

DP Ingredient: dichloride -~~~~~~~~-----------------------------------

CSF Included: • Yes 0 No I...abellncluded: Yes. No Parent DP II: ______ _ 

---------

------

Organization: ~~~----------- ______ Last Possible Science Due Date: ~~~~:..-

Team Name: 

----------------- Science Due Date: ______ _ 

Reviewer Name: 

------------------ Sub Data Package Due Date: ______ _ 

Contractor Name: 

------------- ... -I< 1r Studies Sent for Review" ...... 

Printed on Page 2 

11 .... Additional Data Package for this Decision" ... '" 

Printed on Page 3 

'" "''' Data Package Instructions'" * 4< 

The registrant has subm itted a rA."lIYln~lA to the October 21. 2008 PC review by Han Mukhoty. An additional PC review was oooducted 

previously dated October i, 2008. review new submission to see if PC data requirements are now mel- Renegotiated PRIA date Is 

Jatluary 19. 2009. 
Page 2 

DP#: (359512) • • • Studies Sent for Review' •• Decision#: (393061) 
Companv 

10772 

Compan 

51311 

Pesticide 

By Active. Chemical Code 

• Company Address 

CHURCH & DWIGHT CO INC 

469 NORTH HARRISON ST 

PRINCETQN,NJ 08543 

t Company Address 

HBC CHEMICAL INC. 

220B QUINQUE LANE 

llfTON,VA 20124 

Companv • Company 

66607 FORCE 

&. ALDRIDGE LLl? 

Submitters List 

30, 2001 Edition 

Company • 

748SS 

Company Address 

RESIDENTIAL EXPOSU 

900 17TH STREET, 

WASHINGTON,DC 2 

VENTURE (RE300 

Company t 

81433 

Company 

83424 

ress 

1MS TRA NG, Ltc 

ST WILSHIRE BOULEVARD, f40 

LOS GtLBS,CA 90036 

Company Address 

OXFORD & HILL HOME PRODUCTS, LLC 

D/B/A OXFORD & HILL KOME PRODUCTS 

1150 18TH ST, N.W., SUITE 1000 

WASHINGTON,DC 20036 

CHltMICAL CHEMICAL !IiANE 

061601 Paraquat dichloride 

Company /I 

lOO 

Company Address 

SYNGENTA CROP PROTECTION, 

ATTN: REGULATORY AFFAIRS 

PO BOX 1B300 

GREENSBORO,Ne 27419 

ComDanv Address 

THE SCOTTS COMPANY 

D/B/A THE ORTHO GROUP 

PO BOX 190 

MARYSVILLE,OH 43040 
} Pesticide Data Submitters 

By Active Chemical Code -Sep 30, 2001 Edition 

Company It Company Address 

524 MONSANTO COMPANY 

1300 I STREET, NW, SUITE 450 EAST 

WASHINGTON,DC 20005 

Company # Company Address 

1471 DOW ELANCO 

9002 PURDUE RD 

__ --~~~A~N~A~P~O~LI.S,IN 46268 

Comoany Ii 

10182 

CODiPany 1# 

24630 

Companv Address 

SYNGENTA CROP PROTECTION 

410 SWING ROAD 

GREENSBORO,NC 27409 

Company Address 

CRYSTAL CHEMICAL COMPANY 

1525 N POST OAK ROAD 

HOUSTON,TX 77055 

Company;; Company Address 

66222 MAKHTESHIM-AGAN OF NORTH AMERICA INC 

4515 FALLS OF NEUSE RD, SUITE 300 

RALEIGH,NC 27609 

Company 

66607 

Company 

68292 

1# Company Address 

SPRAY DRIFT TASK FORCE 

MCKENNA, LONG " ALDRIDG," 

1900 K STREET, NW 

WASHINGTON,DC 20006 

# COt1IPa.IlV Address 

EDM INDUSTRIES INC. 

PO BOX 8552 

I?ORTERVILLE,CA 93258 

* Company Address 

SINON CORP 

1001 G ST., HW, SUITE 

WASHINGTON,DC 20001 

LLP .J 

---

Company II Company Address 

71754 OUTDOOR RESIDENTIAL EXPOSURE TASK FORe 

1350 I STREET, N.W. 

WASHINGTON,DC 20005 

~ COlllPa.IlV # Company Address 

/ 71755 AGRICULTURAL REENTRY TASK FORCE 

1350 I STREET, N.W. 

WASHINGTON/DC 20005 
~any " 

73989 

Companv # 

74eSS 

Company It 

75234 

Company # 

SlB7S 

Com:panv II 

82542 

Compa.nv /I 

82557 

COtlipany 1# 

83558 

COlllPany 1# 

84653 

'Pesticide Data Submitters Ust 

Active Chemical Code -Sep 30, 2001 Edition 

Company Address 

rlrRA ENDANGERED SPECIES TASK FORCE, L 

C/O HAROLD KIMMELMAN (BEVERIDGE :;/DI' ND, 

1350 I STREET, NW 

WASHINGTON,DC 20005 

Companv Addre s s 

RO US, INC. 

NT DRIVE, SUITE 310 

Companv Address 

RESIDENTIAL EXPOSURE JOINT VENTURE ~ 

900 17TH STREET, NW, SUITE 300 

WASHINGTON,DC 20006 

company Addre$8 

AGRICULTURAL HANDLERS EXPOSURE TASK~ 

PO BOX 509 

MACON,MO 63552 

Com:pany Address / GRIFFIN CORPORATION 

PO BOX 5126 

VALDOSTA,GA 31603 

Companv Address 

SOURCE DYNAMICS, LLC 

10039 E. TROON NORTH DRIVE 

SCOTTSDALE,AZ 85262 

COIII'P&nv Address 

SINON USA INC. 

1001 G ST., NW, SUITE 500 

WASHINGTON/DC 20001 

Com:pany Address 

CELSIUS PROPERTY B.V., AMSTERDAM (NL)~ 

NEUHAUSEN A.RHF BRANCH 

4515 FALLS OF NEUSE RD., SUITE 300 

RALEIGH,NC 27609 

Company J\.d.d.ress 

GENERIC ENDANGERED SPECIES TASK FORCE '/ 

500 EIGHTH STREET, NW 

WASHINGTON,DC 20004 

CHEKICAL CSEldlCAL NAMlil 

061602 1,l'-Dimethyl-4,4'-bipyridinium bis(methyl sulfate) 
Paraquat TC 

(Technical Concentrate) 

For Fonnulation of Paraquat Herbicide Products Only 

ACTIVE INGREDIENT 

Paraquat dichloride (l,1 '~demethyl, 4J4'~bjpyridinium dichloride) 

INERT INGREDIENTS 

TOTAL 

Contains 3 pounds paraquat cation per gallon. 

Contains emetic. 

EPA Reg. No. 74530-xx 

EPA Establishment No. 

KEEPOU'~T~~~~~~J 

POISON 

43.8% 

56.2% 

100.0% 

Si usted no entiende la etiqueta, busque a alguien para que se la explique a usted en detaJle, ([fyou do not 

understand the label, find someone to explain it to you in detail). 

.. NEVER PUT INTO FOOD, DRINK OR OTHER CONTAINERS 

.. IF SWALLOWED, TAKE IMMEDIATE ACTION AS PRESCRIBED IN FIRST AID 

STATEMENT. SYMPTOMS ARE PROLONGED AND PAINFUL. 

Net Contents: 

HELM AGRO Inc. 

8295 Tournament Drive 

Memphis, TN, 38125 

info@helmagro.com 

1 

DRAFT submitted to EPA: 06-05-2008 . , , , 
If swallowed 

]I 

If in eyes 

If on skin or clothing 

\ItTfinhaled 

I. 

FIRST AID 

... Speed is essential. Immediate attention is required. If available, 

Give an adsorbent such as activated charcoal, bentonite or Fuller's 

Earth. 

.. Call a poison control center or doctor immediately for treatment. 

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

.. Hold eye open and rinse slowly and gently with water for 15 to 20 

mins. Remove contact lenses, if present, after the first 5 minutes, then 

continue Tinsing eye. 

.. Call a poison control center or doctor for treatment advice. 

.. Take off contaminated clothing. 

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

.. Call poison control center or doctor for treatment advice. 

• Move person to fresh air. 

• If person is not breathing, call 911 or an ambulance. 

• Call a poison control center or doctor for further treatment advice. 

NOTE TO PHYSICIAN 

Administer either activated charcoal (IOOg for adults or 2g1kg body weight in children) or Fuller's 

Earth (15% solution: 1 liter for adults or JSmglkg body weight in children. 

Note: The use of gastric lavage without administration of an adsorbent has not shown any clinical 

benefit. Do not use supplemental oxygen. Eye splashes from concentrated material should be treated by 

an eye specialist after initial treatment. With the possibility of late onset corneal ulceration, it is advised 

that patients with paraquat eye injuries are reviewed by an eye specialist the day after first presentation. 

Use treatment that is appropriate for chemical bums. Intact skin is an effective barrier to paraquat, 

however contact with irritated or cut skin or repeated contact with intact skin may result in poisoning. 

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

for treatment. 

HOTLINE \J For medical emergencies involving this product, call CHETvITREC For chemical 

~V Le_m_e_r..::;:g:..,.en_c..::.y_: _S.:...p_il:....I,_le_a_k_, _fi_re...:,,_e_x.:...p_os_u_f_e,:..,.o_r_a_c_c_id_e_n:..,.t,_c_a_II_C_H_E_M_T_R_E_C_l_-8_0_0_-_4_24_-,,9+-::::-::+ ____ ----..! 

r . ~~ e atal if swallowed. Fatal if inhaled. Do not breathe spray mist. Do not inhale contaminated dust. 

'--D' - Causes sllbstantial bl:lHewPQra~. Do not get in eyes or on clothing. Avoid contact with skin. 

Harmful if absorbed through skin. Wear (goggles, face shieJd, or safety glasses). 

IMPORTANT: The effect of swallowing paraquat concentrate is far more severe than that which usually 

Allu.ftresults from skin contact or inhalation of contaminated plant dust. This product should not cause injury if 

CAI"- DIlsed according to label instructions. 
.. Dust/mist filtering NIOSH respirator with any R,P or HE filter 

• Protective clothing (disposable suit/coveralls or shirt and long pants) 

.. Full shield 

.. (Category A) 

• Chemical resistant apron and shoes plus 

Wash hands before eating, drinking, chewing gum, lIsing tobacco or the 

REMOVE contaminated clothing and wash from other laundry before reuse. 

ENVIRONMENT AL HAZARDS 

product is toxic to wildlife. Do not discharge effluent this product into lakes, 

ponds, oceans, or public waters unless product is specifically identified and addressed in a 

National Pollutant Discharge Elimination System (NPDES) permit. Do not contammg 

this product to sewer without previously the sewage treatment plant authority. For 

guidance, contact your Water Board or Regional of 

PHYSICAL AND CHEMICAL HAZARD 

This product reacts with aluminum to produce hydrogen gas which may a highly combustible gas 

mixture. Do not mix or store in containers, tanks, or such of aluminum or having aluminum 

fittings. 

EQUIPMENT/CONTAINER 

Flush all equipment with water use each day. Paraquat is corrosive to aluminum. Aluminum 

and structures that are to solution or spillage should be flushed thoroughly 

with water immediately after use. 

SPILLAGE DURING TRANSPORT 

Emergency Action: Notify police and departments immediately, For any spill, or 

exposure in the United States, call CHEMTREC 1-800-424-9300. 

PUBLIC AND ANIMALS away from area. MARK ROADS AND WARN OTHER ROAD 

USERS. WEAR shield, V98tel"f3FGOf gloves, foorwear, and long-sleeve and long pants 

during deeontamination operations. /"'01:---- .J (' 

'-"\.€ V"-. -r L- .:::. l S 

up spills as soon as possible. Cover spill with generous amount of clay or loam soil to absorb 

liquid, using a broom to ensure contact. onto shovel and transfer to plastic or 

other disposable container. Repeat operations unt\l contaminated surfaces are dry. Finally. hose spill site 

water, if feasible. 

DIRECTIONS FOR USE 

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

3 
READ LABEL. STRICTLY IN ACCORDANCE WITH PRECAUTIONARY 

STATEMENTS AND DIRECTIONS, AND WITH APPLICABLE STATE AND FEDERAL 

REGULATIONS. 

Only for formulation into a herbicide for the following uses: 

TERRESTRIAL FOOD CROP 

Acerola (West Indies cherry), banana, blackberry, blueberry, boysenberry, 

broccoli, carrot (including cauliflower, cherry, cocoa, coffee, collards, cucumber, 

eggplant, filbert (hazelnut), garlic, grollndcherry tomato/tomatillo), guava, hops, 

kiwifruit, lettuce, loquat, macadamia nut (bushnut), manioc (cassava), cantaloupe, 

musk, melons, olive, onion, papaya, pecan, 

pepino (melonpear), pepper, pineapple. pistachio, 

whitlIrish, prune, pumpkin, (black, rhubarb, small fruits, squash (all or unspecified), 

strawberry. sugar beet, walnut (Englishlhlack), yam, 

TERRESTRIAL FOOD+FEED CROP 

Almond, apple, barley, beans, asparagus, beans, dried-type, mung; (lima); 

succulent (snap), fruits, com (unspecified), com, field, com, pop, com, 

~ garbanzos (including chickpeas), grapes, guar, legume 

(unspecified), peanuts (unspecified), spearmint, sugar 

sugarcane, sunflower, tomato, turnip, vegetables (unspecified), wheat 

(J,' ~. ~ r' TERRESTRIAL FEED CROP 

cotton (unspecified), 

mint, ~ orchards 

sugar crops, 

~ J-I.. Alfalfa, barley, clover, crownvetch, legume vegetables, \espedeza, lupine, 

~tUV- V timothy, trefoil, vetch, 

sainfoin, 

TERRESTRIAL NON~FOOD CROP 

Agricultural fallow/idleland, fields, lawns, 

commercial/institutional/industrial, premises/equipment (outdoor), fencecrowslhedgerows, grasses grown 

for industrial areas (outdoor), jojoba, nonagricultural outdoor 

uncultivated areaS/soils, ornamental and/or shade trees, peach (non-bearing, beds), recreation area 

lawns, tomato wood protection treatment to products (seasoned). 

FORESTRY 

Forest planting (reforestation programs), (forestlshelterbelt), shelterbelt plantings. 

TERRESTRlAL NON-FOOD 

Ornamental and/or shade trees, ornamental herbaceous plants, ornamental woody shrubs and vines, non* 

crop areas as public airports. stations and 

OTHERS 

Uses which has accepted the required and/or citations of data that the formulator has 

submitted in support of registration; and uses for experimental are in compliance with 

USEPA requirements, 

4 
drinking water. Do not store next to feed or or in or on vehicles containing IVVI..I"C'Ui 

help with any leak, or exposure involving this call 

9300. 

PESTICIDE DISPOSAL; wastes are acutely hazardous. Improper disposal of excess 

or is a violation of Federal law. If these wastes cannot be disposed of by use to label 

instructions, contact your State or Environmental or the Hazardous Waste 

representative at the nearest EPA for guidance. 

CONTAINER DISPOSAL: Triple rinse (or equivalent). Offer 

and of in a sanitary landfill, or dispose of by other 

CONDiTIONS OF 

recycling or recondition, or puncture 

allowed by State and local 

LIMITATION OF WARRANTY AND LIABILITY 

NOTICE: Read for Use and Limitation of Warranty and 

retum the at once, 

It is to eliminate all risks 

injury, ineffectiveness or other unintended 

consequences may result because such factors as manner of use or application, weather or crop 

conditions, presence of other materials or other influencing in the use the product, which are 

beyond the control Helm US, [nco or Seller~AII such shall assumed by Buyer and 

Buyer User to hold Helm and Seller harmless for any claims relating to such factors, 

Helm warrants that this product conforms to the chemical description on the label and is reasonably fit for 

the purposes in the Use, to the inherent to when used in 

accordance with directions under normal use conditions. This warranty does not extend to the use of this 

product contTary to instructions, or under abnormal conditions or under conditions not reasonably 

foreseeable to or beyond the control of or Helm, and and assume the risk of any such 

use~LM MAKES NO WARRANTIES OF MERCHANT ABILITY OR OF FITNESS FOR A 

PARTICULAR PURPOSE NOR OrnER EXPRESS OR IMPLIED WARRANTY EXCEPT 

AS STATED ABOVE. 

• In no event shall or be liable for any incidental, consequential or resulting 

the use or handling of this product.'nrn EXCLUSIVE REMEDY OF USER OR BUYER, 

AND THE LIABILITY OF HELM AND SELLER FOR ANY ALL CLAIMS, 

LOSSES, INJURIES OR DAMAGES (INCLUDING CLAIMS BASED ON BREACH OF 

WARRANTY) CONTRACT, NEGLIGENCE, TORT, STRICT LIABILITY OR OTHERWISE) 

RESULTING USE HANDLING TIDS PRODUCT, BE 

RETURN THE PURCHASE PRICE OF PRODUCT A T ELECTION OF 

ORSELLER~ REPLACEMENT OF PRODUCT. 

Helm and Seller offer this product, Buyer and accept it, subject to the conditions of 

sale and limitations of and of liability, which may not be modified except by written agreement 

signed by a duly authorized Helm. 

5 
ACTIVE INGREDIENT 

ParaquatTC 

(Technical Concentrate) 

Formulation Paraquat Products Only 

dichloride (I, I '-demethyl, 4,4' -bipyridinium dichloride) 

3 pounds paraquat cation per 

Contains emetic. 

KEEP OUT OF REACH OF CHILDREN 

DANG ELIGRO 

POlSON 

43.8% 

100.0% 

Si usted no entiende la etiqueta, busque a algulen para que se la explique a listed en detalle. (If you do not 

rI .. ",,'<>nrl the label, find someone to it to you in detail). 

.. NEVER PUT INTO FOOD, DRINK OR OTHER CONTAINERS 

'" IF SW ALLOWED, TAKE IMMEDIATE ACTION AS PRESCRIBED IN FIRST AID 

STATEMENT. SYMPTOMS ARE PROLONGED AND 

Net 

HELM AGRO Inc. 

8295 Tournament Drive 

Memphis, TN, 381 

info@helmagro.com 

DRAFT submitteO.J!l 

1 

" ' 06-05 L21)08 
FIRST AID 

If swallowed .. Speed is essentia.l. Immediate attention is required. If available, 

Give an adsorbent such as a.ctivated charcoal, bentonite or Fuller's 

Earth. 

.. Call a poison control center or doctor immediately for treatment. 

.. 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 to 20 

mins. Remove contact lenses. if present, after the first 5 minutes, then 

continue rinsing eye. 

'" Call a poison control center or doctor for treatment advice. 

If on skin or clothing '" Take off contaminated clothing. 

'" Rinse skin immediately with plenty of water for 15 to 20 minutes. 

• Call poison control center or doctor for treatment advice. 

If inhaled • Move person to fresh air. 

• If person is not breathing, call 911 or an ambulance. 

• Call a poison control center or doctor for further treatment advice. 

NOTE TO PHYSICIAN 

Administer either activated charcoal (JOOg for adults or 2g/kg body weight in children) or Fuller's 

Earth (15% solution: 1 liter for adults or ISmg/kg body weight in children. 

Note: The use of gastric lavage without administration of an adsorbent has not shown any clinical 

benefit. Do not use supplemental oxygen. Eye splashes from concentrated material should be treated by 

an eye specialist after initial treatment. With the possibility of late onset corneal ulceration, it is advised 

that patients with paraquat eye injuries are reviewed by an eye specialist the day after first presentation. 

Use treatment that is appropriate for chemical bums. Intact skin is an effective barrier to paraquat, 

however contact with irritated or cut skin or repeated contact with intact skin may result in poisoning. 

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

'c. 

HOTLINE 

For medical emergencies involving this product, call CHEMTREC 1-800-424-9300. 

emergency: Spi II, leak, fire, exposure, or accident, call CHEMTREC 1-800-424-9300 

PRECAUTIONARY STATEMENTS 

HAZARDS TO HUMANS AND DOMESTIC ANIMALS 

DANGERJPELIG RO 

POISON 

For chemical 

May be fatal if swallowed. Fatal if inhaled. Do not breathe spray mist. Do not inhale contaminated dust. 

Causes substantial but temporary eye injury. Do not get in eyes or on clothing. Avoid contact with skin. 

Harmful if absorbed through skin. Wear (goggles, face shield, or safety glasses). 

IMPORTANT: The effect of swallowing paraquat concentrate is far more severe than that which usually 

results from skin contact or inhalation of contaminated plant dust. This product should not cause injury if 

used according to label instructions. 

When handling or mixing concentrate or when exposure to concentrate is possible, wear: 

2 
III Dust/mist filtering NIOSH approved with any R,P or filter 

III (disposable suit/coveralls or long-sleeve shirt and long pants) 

III Chemical-resistant gloves (Category 

III Chemical resistant apron and shoes plus socks 

Wash hands drinking, gum, using tobacco or using the toilet. 

REMOVE contaminated clothing and wash separately from other laundry reuse. 

ENVIRONMENTAL HAZARDS 

This product is toxic to wildlife. not effluent containing this product Jakes, streams, 

ponds, estuaries, oceans, or public waters unless this product is specifically and addressed in a 

National Pollutant Elimination System (NPDES) permit. Do not discharge effluent containing 

this product to sewer without previously notifying the treatment authority. 

guidance, contact your Water Board or Regional Office of EPA. 

PHYSICAL AND CHEMICAL HAZARD 

This reacts with aluminum to produce hydrogen gas which may form a highly combustible gas 

mixture. Do not mix or store in containers, tanks, or such systems made of aluminum or having aluminum 

fittings. 

EQUIPMENT/CONTAINER 

Flush equipment with water use each day. Paraquat is to aluminum. Aluminum 

equipment and aluminum structures are to solution or spillage should be flushed thoroughly 

with water immediately use. 

SPILLAGE DURING TRANSPORT 

Emergency Action: Notify police and fire departments immediately. For any spill, leak, fire, or 

exposure in the United call 1-800-424-9300. 

KEEP PUBLIC AND ANIMALS away from area. MARK ROADS AND WARN OTHER ROAD 

USERS. WEAR shield, waterproof gloves, waterproof footwear, and shirt and long pants 

during decontamination 

Clean up spills as soon as Cover spill with generous amount of clay or loam soil to absorb 

liquid, a stiff broom to ensure intimate contact. Sweep onto shovel and transfer to plastic bag or 

other disposable container. Repeat until contaminated are dry. Finally, spill site 

with water, if feasible. 

DIRECTIONS FOR USE 

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

3 
READ ENTIRE LABEL. USE STRICTLY IN ACCORDANCE WITH PRECAUTIONARY 

STATEMENTS AND DIRECTIONS, AND WITH APPLICABLE STATE AND FEDERAL 

REGULATIONS. 

Only for formulation into a for the following uses: 

TERRESTRIAL FOOD CROP 

Acerola cherry), asparagus, avocado, banana, blackberry, blueberry, boysenberry, 

broccoli, carrot (including tops), caUliflower, cocoa, collards, cucumber, 

eggplant.. fig, filbert (hazelnut), groundcherry (strawberry tomato/tomatillo), guava, hops, 

kiwifruit, lettuce, loquat, macadamia nut (bushnut), manioc (cassava), melons, melons, 

melons, musk. water, mint, nectarine, olive, onion, papaya, peach, pear, pecan, 

pepino (melonpear), pepper, pepper (chili type), pineapple, plum, potato, 

whit/Irish, prune, pumpkin, (black, red). rhubarb, small fruits, squash (all or unspecified), 

strawberry, sugar beet, taro, walnut (English/black), yam, 

TERRESTRIAL FOOD+FEED CROP 

Almond, apple, barley, asparagus, beans, dried-type, beans, mung; (lima); beanssucculent (snap), citrus corn (unspecified), com, field, corn, pop, corn, sweet, cotton (unspecified), 

garbanzos (including chickpeas), grapes, guar, hops, mint, oats, orchards 

(unspecified), peanuts (unspecified), edible, sugar beet, sugar crops, 

sugarcane, sunflower, tomato, turnip, vegetables (unspecified), wheat. 

TERRESTRIAL FEED CROP 

Alfalfa, barley, clover, crownvetch, legume vegetables, lespedeza, lupine, pastures, sainfoin, 

timothy, trefoil, tyfon, vetch, wheat. 

TERRESTRIAL NON-FOOD CROP 

Agricultural fallow/idleland, airports/landing fields, commercial/industrial lawns, 

commerciallinstitutionallindustrial, premises/equipment (outdoor), fencecrowslhedgerows, grasses grown 

for industrial areas (outdoor), jojoba, Itural outdoor buildings/structures, nonagricultural 

uncultivated areas/soils, ornamental andlor shade peach (non-bearing, seed beds), recreation area 

lawns, tomato (post-harvest)/ wood protection treatment to forest (seasoned). 

FORESTRY 

Forest planting (reforestation programs), (forest/shelterbelt), plantings. 

TERRESTRIAL NON-FOOD 

Ornamental and/or ornamental ornamental woody and vines, 110ncrop areas such as public airports, electric transformer stations and around commeTcial buildings. 

OTHERS 

Uses for which USEPA has 

submitted in support of 

USEPA requirements. 

the data and/or citations data that formulator has 

and uses for experimental purposes that are in compliance with 

4 
drinking water. Do not store next to feed or food, or transport in or on vehicles containing foodstuffs or 

help with any spill, leak, or exposure involving this cal! 1-800-424-

9300. 

PESTICIDE DISPOSAL; Pesticide wastes are hazardous. Improper disposal excess u ... o,uv.ULor rinsate is a violation Federal law. If these wastes cannot disposed of by lise according to label 

instructions, contact your Pesticide or Environmental Control Agency, or the Hazardous Waste 

representative at nearest Regional Office for guidance. 

CONTAINER DISPOSAL: Triple rinse (or equivalent). Offer for recycling or recondition, or puncture 

and dispose of in a landfill, or of by procedures allowed by State and local 

CONDITIONS SALE 

AND LIMIT A TION OF WARRANTY AND LIABILITY 

NOTICE: Read the entire Directions for Use and Conditions of Sale and Limitation of Warranty and 

Liability before buying or using this product. Ifthe terms are not return the at once, 

unopened, the price will refunded. 

The Directions for Use of this product should be followed carefully. It is to eliminate all 

inherently associated with the use of this product. injury, or other unintended 

consequences may such as manner of use or application, weather or crop 

conditions, presence of other materials or other influencing factors in the use of the product, which are 

the control of Helm US, Inc. or Seller. All such shall be assumed by and 

and and User agree to Helm and for any to such 

Helm warrants that this product conforms to the chemical description on the label and is reasonably fit for 

the purposes stated in for Use, to the inherent referred to when used in 

accordance with directions under normal use conditions. warranty not extend to the use of this 

product contrary to label instructions, or under abnormal or under conditions not reasonably 

foreseeable to or beyond the control of Seller or Helm, and Buyer User assume the any such 

use. MAKES NO WARRANTIES OF MERCHANTABILITY OR OF FITNESS FOR A 

PARTICULAR PURPOSE NOR ANY OTHER EXPRESS OR IMPLIED WARRANTY EXCEPT 

STATED ABOVE. 

In no event Helm or be for any incidental, consequential or special resulting 

from the use or handling of this product. EXCLUSIVE REMEDY OF THE USER OR BUYER, 

AND EXCLUSIVE LIABILITY OF HELM AND SELLER FOR ANY AND ALL CLAIMS, 

LOSSRS+ INJURIES OR DAMAGES (INCLUDING CLAIMS BASED ON BREACH OF 

WARRANTY, CONTRACT, NEGLIGENCE, TORT, STRICT LIABILITY OTHERWISE) 

RESULTING FROM USE HANDLING OF PRODUCT, BE 

RETURN OF THE PURCHASE OF THE PRODUCT OR, AT THE ELECTION OF 

THE REPLACEMENT OF PRODUCT. 

Helm and product, and Buyer User it, to the conditions of 

and limitations of warranty and of liability, which may not be modified except by written agreement 

by a duly authorized representative of Helm. 

5 
Memorandum 

Date: 

To: Regulatory Manager 

From: Infonnation Services Branch, ITRMD 

Your receipt of this data submission is not an 

indication that MRlDs for the enclosed studies have 

been posted to OPPIN. 

We expect that it will be approximately 5 days 

from the above date before the study-level data is 

available in OPPIN. 

you have any questions about this process, 

please contact Teresa Downs (305-5363). 

. . 

IS a: W' fully accepted submission 

partially accepted submission 

o rejected submission 
UNITED ENVIRONMENTAL PROTECTION AGENCY 

WASHINGTON, D.C. 20460 

November 17, 2008 

HELM AGRO US, INC. 

8295 TOURNAMENT DRNE, SUITE 310 

MEMPHIS, TN 38 

Report of Analysis for Compliance with PR Notice 

OfFICE OF 

PREVENTION, PESTICIDES AND 

TOXIC SUBSTANCES 

Thank you for your submittal of 17-NOV-08. Our staff has completed a 

the materiaL The are provided as follows: 

Your submittal was found to be full compliance with the standards for submission of 

data contained in PR Notice 86-5. A copy your bibliography is enclosed, annotated with 

Master Record ID's (MRIDs) assigned to each document submitted. Please use numbers 

all future to these documents. Thank you your If you any 

questions concerning this data submission, please raise them the cognizant Product 

Manager, to whom the data have 
Application Date: 

Front End Date: 

FFS Due Date: 

" OPP Target Date: 

Fa~Tr8ck: r 

6-i; 

~ 3.Nov.2008 J fuJ] ' ~ 7-N~~ 20 08 "-' l!rJ I 

f " '" " 

r 

'. 

OPP Rec'vd Date: ~ , 

Risk Manager send .Dat,e: 

Receipt DeSt:ription: I • 

r---~~~~----~~--~-------------------- ' esponse to EPA product chemistry review 

..... 

F orrn ;.1.; r '· SlgntrtureDme: 'J r ---"-""'-.~,..,..,.,! I Ferrm 8: I 

",. 
471878-00 

HELm RO us, INC .. 8295 Tournament Drive, Suire 310 

Memphis, Tennessee 38125 

Phone: (901j312·1525 

Fax: (901 J 312·1535 

Document Processing Desk (RD ) 

Office of Pesticide Programs (7504P) 

Environmental Protection Agency 

One Potomac Yard, Room 8-4900 

S, Crystal Drive 

Arlington, VA 22202-4501 

Attention: Ms. Hope A Johnson 

Registration Division 

TC (EPA-Reg.No.74530 -

Response to EPA's Product Chemistry Review, 

of information 

Ms. 

Agro US Inc. herewith submits a response to your 

and the Agency's Product Chemistry Review (Decision No. 393061). As indicated 

application is for the "me-too" registration of the active ingredient, 

as a Manufacturing Use Product (MUP) in formulating registered End-Use Products. 

product is very similar in its composition and labeling to the existing product, 

Concentrate {EPA Reg. No. 82542-3}. 

The submitted document (see also attached bibliography of submitted studies) 

in more detail the issues raised in your letter (item #1) and within 

Review dated October 21,2008 (item #3 and 4) related to the toxicological 

the potential impurities. Concerning the outstanding data requirements (Ref.# 

stability. and #830.6320 -corrosion characteristics), are 

generated. 

As indicated in earlier e-mail correspondence, we understand that the review 

should be completed by January 19, 2009 (revised PRIA due date). do 

contact me at 610·793·3222 or Marshall Wixson at 901·312·1525, if you have any or 

cc: 

any additional information regarding this submission. 

Wixson - Helm 

Sincerely, 

~~f-r~0- Bert Volger, Ph.D. 

Consultant for 

HELM. Agro US, Inc. 
1 of 2 

BIBLIOGRAPHY OF SUBMITTED STUDIES 

Helm US, Inc. 

8295 Drive,Suite310 

Memphis, TN 38125 

Product(s): Paraquat (Technical) 

74S30-GT 

Submission of data in response to EPA's Product Chemistry Review 

(Decision No. 393061) October 21,2008 

November 13, 2008 

OPPTS EPAMRID 

Volume Study Title Laboratory, Guideline Number 

Number IDNumber Reference (Reserved for EPA 

Number Use) 

loft Paraquat TC HELM, N/A 47617101 

Helm Agro Inc. #081110 

Response to EPA's Product 

Chemistry Review 

File Symbol No. 

DP Barcode No. 357479; 

Decision No. 393061) 
Decision#: 393061 

Fee Category: R310 

Submitted by: Hope Johnson 

Company: Helm Agro Inc 

Recommendation of Division Directors 

Negotiated Due Dates 

Registration#: 74S30-GT 

PRIA Decision 

Branch: HB 

6 months 

Original Due Date: 11119/2008 Proposed New Due 111912009 

Previous Ne onated Due Dates: nJa 

the "Fix" in-house? Yes received 11/17/2008 If not, date "Fix" ex feted: 

Issue (describe in detail): 

On October 28, 2008, the Agency sent the Registrant a day deficiency letter stating product 

contains unidentified impurities, and data of toxicological significance must be submitted. 

Summary of Deficiency Type(s): Not Submitted (N) Deficiencies (D) 

Product ChemiStry: _ D _ Acute Tox: _ Efficacy: __ Labeling: __ Other (describe): _ 

Describe Interactions with Company (describe when contacted and company's response including 

response to previous negotiated due dates): 

The day deficiency letter was sent on October 28, 2008. The consultant for the Registrant, Bert 

Volger contacted Hope Johnson by phone November, and Jim Tompkins on November 12,2008. 

He later sent an email on 11/12/2008 to a 60 day renegotiation and stated they would be 

submitting additional data later that week. The Agency this new data on 11/17/2008 (front 

end. 

Yes No and reason for none? 

Rationale for Proposed Due Date: 

The Technical Review Branch is only missing toxicological information on unidentified impuritiesother data has been received and reviewed. 60 days will be adequate for TRB to reassess this 

product's cbemistry with the new impurity information and to determine if all chemistry data 

re uirements have been fulfilled. 

If disapproved, action to be taken: 

ODor 
Hi Jim, 

"Bert Volger" 

<bertvolger@comcast.net> 

To Jim TompkinsJDC/USEPAlUS@EPA 

co Hope Johnson/DC/USEPAlUS@EPA, -Marshall Wixson" 

<mwixson@helmagro.com> 

bee 

Subject Paraquat TC • File Symbol #74530-GT 

This e-mail is in reference to the recent PC review regarding the subject application for 

a for Agro US I am presently the to a 

response providing you with the additional requested information related to the toxicological 

signi ficance of impurities. Helm is planning to submit this information by the end of this week. 

In your cover letter dated October 28, 2008 to (Marshall Wixson), it was stated that the 

current PRIA date of 11119/2008 needs to be extended in order to review the additional data. In 

our phone conversation today, you mentioned that a 60-day review is necessary to 

complete this action. In of the upcoming season, Helm is keen to have this additional 

review process completed by mid January 2009 (1119/09). We appreciate your consideration in 

this matter. 

Please let me know about final PRIA date, or if you have any further 

Bert Volger 

Consultant for Helm Agro Inc. 

elo Ceres International LLC 

1087 Heartsease Drive 

West Chester, PA 19382 

phone 610-793-3222 

fax 610-793-1708 

bertvolger@comcast.net 
'-

Or. WIXon, 

Hope 

JohnsonlDCIUSEPAlUS 

1012812008 PM 

To "Marshall Wixson" <mwixson@helmagro.com> 

CC Jim TompkinsJDCIUSEPAlUS@EPA 

bee 

Subject 74530-GT 75 day deficiency tetter 

",n",I"""O::'1'I below the letter for EPA File Symbol 74530-GT. A hard copy is being 

mailed to you along with the reviews from the Review Branch. forward on to your 

consultant Bert Volger if you wish. 

Thank you. 

Hope A. Johnson 

U.S. Environmental Protection Agency 

Office of Pesticide Programs 

Registration Division 

Herbicide Branch 

Phone: 703-305·5410 

Mail Code 7505P 

scanpdl 

-- Forwarded by Hope JohnsonJDC/U$EPAlUS on 101281200B 12:34 PM-

~Marshatl Wixson" 

<mwixson@helmagro.com> To JohnsonIDC/uSEPAlUS@EPA 

101271200812:19 PM CC '''Volker Heide'" <vheide@helmagro.com> 

Subject Helm's TC submission 

Hope, I was very disappointed to hear om our regula10ry consultant, Bert Volger; that our Paraquat Te 

submission was being questioned f each listed below 0.1% on our I am not familiar 

with EPA requesting information in on anything listed below 0.1%. Is this a new trend 

intends to follow? If so, we need to adjust the way we do our 5 batch. Is there for such a 

request? Thank you for your time. 

Regards, 

Dr. Marshall B. Wixson 

Manager Product Development 

Helm Agro US, Inc. 

8295 Tournament Suite 310 

MemphiS, TN 

901/312-1525 

901/312-1535 (Fax) 

901/216-7530 (Cell) 
',,-,,' 

"-

-Marshall Wix80nM 

<mwixson@helmagro.com> 

10127/200812:19 PM 

To Hope JohnsonIDC/USEPAJUS@EPA 

cc "'Volker Heide"' <vl1eide@helmagro.com> 

bee 

Subject Helm's Paraquat TC submission 

Hope, I was very to from our regulatory consultant, Bert Volger; that our Paraquat TC 

submission was being questioned les each listed below'0.1% on our CSF. I am not familiar 

woh EPA requesting information in t on anything listed below 0.1%. Is this a new trend EPA 

to follow? It so, we need to adjust the way we do our 5 batch. Is there precedence for such a 

request? Thank you tor your time. 

Regards, 

Or. Marshall B. Wixson 

Manager Product Development 

Helm Agro Inc. 

Tournament Dr.. 310 

Memphis. TN 38125 

901/312-1 

901/312-1535 (Fax) 

901/216·7530 (Cell) 
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 

WASHINGTON, D.C. 204(10 

(;C': 2 ;.:, :j~~~ 

Dr. Marshall B. Wixson 

Helm US, Inc. 

8295 Tournament Dr., Suite 310 

Memphis, TN 38125 

Subject: 

EPA File Symbol No. 74530-GT 

dated April 2008 

OFFICE OF 

PREVENTlON,PESTICIOES AND 

TOXIC SUBSTANCES 

The application to above has determined, pursuant to 40 CPR 152.105, not to be SUIIlCl,enl:rj 

to process; therefore, the application is considered deficient Additional as specified below 

the the application can be completed. If such deficiencies cannot 

r.l1fTPrIP,{I within 75 days, you must notify the within those 75 days of the date you expect to 

complete the 75 you do not or you fail to complete the 

application the scheduled times of completion., the Agency will terminate any action on the 

application, and will treat the application as if it withdrawn by applicant. Any 

submission to application must be submitted as a new application. 

1. product cannot be determined "substantially similat" from the product chemistry point of 

view to the cited product No. 70552-1 for the following reasons: 

a. product contains Wlidentified impurities. 40 CFR 158/320 (4)(0) and (d) requires 

you to submit data on toxicological of See attached Technical 

Review memos, 

2. The following guideline data requirements are outstanding; 

a. Guidelines 830.63 year stability) and &30.6320 

are outstanding. It is understood that these are currently ongoing, but please note 

that these studies are still outstaJnding. 

Additional science review will be required if you resubmit any additional data.. An additional four 

months of review time will be once additional is submitted, and an extension 

current date of 11/19/2008 is required. Please contact Hope Johnson as soon as possible at 703-305-

5410 with an expected submittal date of required data listed above. 

Branch 

istration Division (7505P) 

Cc: Bert Consultant 
------:r. 

\J 

~ 

.......: \--

: -...-; 

L,' 

~ 

-t 

~ \3 

d 

-.D 

I 

s;:. 

,Y 

'J) 

o 

~ 

d 

u 

~ 

i 

DATE OUT: 

SUBJEC'f: 

f ,ROM: 

TO: 

') ) ; 

) 

. ~."

21 J OCTOBER I 2008 

PRODUCT CHEMISTRY REVIEW OF MP f X') EP f ) 

DP BARCODE No.: 357479 EPA Ftle Symbol No.: 74530-Gr 

PRODUCT NAME: Paraquat IC 

COMPANY: Helm Aqro US, Inc. 

FOOD US,£; ( X] ,INTEGRATED FORMULATION [X] 

PCC: 061601 Decision No. 393061 

ACTION CODt=; R310 ' 

ftaoMokhoty \. \ ~. Product Chemistry Team ~ ~'" Technical Review Branch / IROo (1505P) 

Hope Johnson / James Tompkins, RM 2'5 

Herbicide Branch / RD (7505P) 

,INTRODUCTION: 

This is in reference to product chemistry review for the proposed prodlJct submitted under EPA 

File Symbol 77453O-GT, Product name: 'Paraquat TC. The p~odl:lct chemistry data submitted 

were reviewed ,on October 1, 2008'. 

TRB tlas been requested to re-evaluate the product chemistry data with respect to the information 

pertaining to toxicological significance of impurities present in ,the submitted CSF (dated 

0610612008) for reg'istration of the aforesaid proposed product. 

SUMMARy OF FINDINGS AND CONCLUS ONS: 

. 1. The two impurities that will be discussed here are: 

(Unknown impurities, each 0.1 % w/w). 

nd Others 

3. Discussion on presence of other unknown impurities, each at 0.1 % w/w Jevel: With respect to 

these impurities the PM should request the registrant to clarify their toxicological significance, if 

any, at the level they are present in the product prior to the registration of the product. 

4. The registrant did not submit the toxicological significance of the impurities present in the final 

product. It is required under 40 CFR § 158.320 (4) (c) and (d). 

1 
is not included s 

Pages 61 through 62 are not luded in s 

The not the following type of 

ion: 

Identi of 

ties. 

x of product process. 

Description of ty procedures. 

ty of the source t 

Sales or other If ial 

A product label. 

product idential statement 

about a trat 

FIFRA regi data. 

document is a of (s) 

The to 

Internal del information. ----

At torney- work product. 

by tter upon 

Informat 

The not included 

who 

ion. 

action. 

ss to the 

conf 

f please contact 

request. 
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 

WASHINGTON, D.C. 20460 

14/0CT/2008 

MEMORANDUM 

Name of Pesticide Product: 

EP A File Symbol: 

DP Barcode: 

Decision No,: 

Action Code: 

Paraquat 

74530-GT 

0353730 

393061 

R310 

OF PREVENTION, 

nr-'''"..T,,..,T ...... ,.., AND TOXIC 

Cade: 061601 (paraquat dichloride) 

From: 

Applicant: 

Eugenia McAndrew, Biologist 

Technical Review Branch 

Registration (7505P) 

Johnson, RM Team 23 

Branch 

Registration Division (7505P) 

Helm Agro US, Inc. 

8295 Tournament Drive, Suite 310 

Memphis, TN 38125 

FORMULATION FROM ...... ru_' ............ 

Paraquat dichloride 43.8 

56,2 

Total: 100.0% 

ACTION REQUESTED: The 

74S30-GT. 

Manager requests review of the acute toxicity data 
BACKGROUND: Helm Agro US, Inc. has submitted a six pack acute toxicity studies to 

support the proposed product, Paraquat Te, File Symbol 74530-GT. Five of the studies 

were conducted at EurofinslProduct Safety Laboratories, Inc., Dayton, New The primary 

eye irritation study was conducted at Inveresk Research, Tranent Eh33 2NE, Scotland. 

MRID numbers are 470911-07 to -11 and 46098805. A dated June 6, 2008 for a basic 

formulation is included in the submission. An Agency contractor, Oak Ridge National 

Laboratory, conducted the primary review of the studies. TRB performed the secondary review 

and changes as necessary, 

RECOMMENDATIONS: 

1. The acute oral, acute dennal, acute inhalation, primary skin and dennal sensitization studies 

are classified as acceptable. 

The primary eye irritation study is as unacceptable because the three animals tested 

had to be killed on humane grounds prior to the end of the study. The study author concludes 

that "Following an ocular instillation of Paraquat Technical, it has been found to be systemically 

to rabbits ... Due to the early termination of the study the results are inconclusive with 

regard to irritation." agrees with this conclusion and is assigning Toxicity Category I for 

irritation based on an examination of labels ten currently registered products 

containing 30.1 % to 45.6% paraquat dichloride which are all in Category I or II for eye 

irritation. animal welfare reasons, is against any further testing of this product. 

3. The acute toxicity profile for Paraquat TC, EPA File Symbol 74530-GT, is as follows: 

Acute oral toxicity II Acceptable MRID 47091107 

Acute dermal toxicity Acceptable MRID 47091108 

Acute inhalation toxicity I Acceptable MRID 47091109 

Primary eye irritation I Unacceptable MRID 46098805 

skin irritation IV Acceptable MRID 47091110 

Dennal sensitization Positive Acceptable MRID 47091111 

LABELING: Based on the toxicity profile ab'ove, the following are the precautionary 

aid statements the proposed product as obtained from the Label System: 

PRODUCT ID #: 074530-00037 

PRODUCT NAME: Paraquat {Technical Concentrate} 

2 
PRECAUnONARY STATEMENTS 

SIGNAL WORD: DANGER POISON :l 

Hazards to Humans and Domestic Animals: 

Restricted Use due to toxicity For to and use only by Certified Applicators 

or persons under their direct supervision and only for those uses covered by the Applicators 

certification. 

Fatal If Inhaled. Corrosive. causes irreversible eye damage. May be fatal if swallowed. Harmful If 

absorbed through skin. Do not spray mist. Do not get in eyes or on Avoid contact with 

skin. Prolonged or frequently skin contact may cause allergic reactions in some individuals. 

Remove and wash contaminated clothing before reuse. Wear protective eyewear (goggles, faoe shield, or 

safety glasses). Handlers must wear a NIOSH approved respirator with any R, P or HE filter. Wash 

thoroughly with soap and water after handling and before eating, drinking, chewing gum, or using 

tobacco. Wear long-sleeved shirt and long pants, socics, and gloves. 

First Aid: 

If inhaled: 

-Move the person to fresh air. 

-If person is not breathing, call 911 or an ambulance, then give artificial respiration, preferably mouth-tomouth if poSsible. 

,~Call a poison control center or doctor for further treatment advice. 

open and rinse slowly and gently with water for 15-20 minutes. 

contact if 5 minutes, then continue rinsing. 

a poison control center or for treatment advice. 

If on skin; 

off contaminated clothing. 

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

-Call a poison control center or doctor for treatment advice. 

If swallowed: 

a poison control center or doctor immediately treatment advice. 

-Have person sip a glass of water If able to swallow. 

-Do not induce vomiting unless told to by a poison control center or doctor. 

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

NOTE TO PHYSIaAN: Probable mucosal damage may contraindicate the use of gastric lavage. 

3 
h" .. .,.tl,,~t dichloride) 

Note to RMJRegistrant: 

The proposed label should contain a Note to Physician which addresses category I Acute Inhalation 

Toxicity, Primary toxicity. The following statements are of Information 

may be Included, If applicable: 

- technical information on symptomatologYi 

• use of supportive treatments to maintain life functions; 

• medidne that witl counteract specific nm/SlCIllOO 

- company telephone number to "1-'~'''''''''''L'''l..I medical advice. 

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

treatment. You may also contact 1-80Q·xxx-xxxx for emergency medical treatment information. 

4 
DATA EVALUATION RECORD 

PARAQUAT DICHLORIDE 

(PARAQUAT 43.8% TECH) 

STUDY TYPE: ACUTE ORAL TOXICITY - RAT [OPPTS 870.1100; OECD 425] 

ACUTE DERMAL TOXICITY - RAT [OPPTS 870.1200; OECD 402J 

ACUTE INHALATION TOXICITY - RAT [OPPTS 870.1300; OECD 403] 

ACUTE IRRITATION - RABBIT [OPPTS 870.2400; OECD 405] 

ACUTE DERMAL IRRITATION - RABBIT [OPPTS 870.2500; OECD 404] 

DERMAL SENSITIZATION - GUINEA PIG [OPPTS 870.2600; OECD 406] 

~D47091107,47091108,47091109,46098805,47091110,and47091111 

Quality Assurance: 

Prepared for 

Registration Division 

Office of Pesticide Programs 

U.S. Environmental Protection Agency 

One Potomac Yard 

2777 South Crystal Drive 

Arlington, V A 22202 

... rl""n"',.."'11 by 

Toxicology and Hazard Assessment Group 

Environmental Sciences Division 

Oak Ridge National Laboratory 

1 

Task Order No. 1-28 

Date: 

Date: 

Date: 

Disclaimer 

This review may have been altered subsequent to the contractor's 

Oak National Laboratory managed and operated by DT-Battelle, 

of Energy under Contract No. DE-AC05-000R2272S. 

above. 

for the u.s. Department 
Reviewer: ___ --'==..l..!::::. _______ _ Date: July 15,2008 

Manager (EPA): 25 

STUDY TYPE: Acute Oral Toxicity- Rat; OPPTS 870.1100; OECD 425 

TEST MATERIAL: Paraquat 43.8% Tech (-48% paraquat dichloride; Lot No. not reported, 

PSL Reference No. 061026-40; dark green liquid, pH 3.98 as a 1 % w/w solution, 

gravity t .157 g/mL, soluble in water) 

CITATION: Durando, J. (2007) Paraquat 43.8% Tech Acute Oral Toxicity Up and Down 

Procedure in Rats. Study Number 21077. EurofinslProduct Safety Laboratories, 2394 US 

Highway 130, Dayto~ NJ 08810. March 15,2007. MRID 47091107. 

SPONSOR: Source Dynamics 10039 Troon North Drive, Scottsdale, AZ 85262 

~~~u...!.~~~~~. In an acute oral toxicity study (MRID 47091107), eight fasted, 

young adult female Sprague-Dawley rats (age: 10-12 weeks; body weight: 185-230 

Ace Animals, Inc., Boyertown, PA) were given a single dose of Paraquat 43.8% Tech (-48% 

paraquat dichloride; Lot No. not reported) as received. Based on the estimated LDso supplied by 

the Sponsor (550 mglkg), a Main Study was conducted using a default starting dose 174 

mglkg which was administered t one female rat by oral gavage. Following the Up and Down 

procedure, seven additional animals were dosed at levels of 174,550, or 1750 mglkg bw and 

observed for 14 days. 

An animals dosed at 174 mglkg survived, gained weight, and were and healthy during the 

study. An animals dosed at 550 died within eight days dosing and the animal dosed at 

1750 mglkg died within one day of dosing. Hypoactivity, reduced fecal vo]wne, feces, 

hunched posture, and/or piloerection were noted from all 550 mglkg decedents prior to death. 

1750 mglkg animal was hypoactive prior to death. Discoloration of intestines andlor 

liver was noted from the decedents at necropsy. 

uu,' ...... , .... Females LDso = 254 mglkg bw (Approximate 95% confidence interval is 174 mglkg 

(lower) to 550 (upper) mglkg.) 

Paraquat 43.8% Tech is in EPA Toxicity Category II. 

This study is classified as acceptable. It does satisfy the guidehne requirements for an acute oral 

study (OPPTS 870.1 100; OEeD 425) in the rat. 

.;::::..;;;=~=~=. Signed and dated GLP, Quality 

statements were provided. 

6 

Data Confidentiality 
RESULTS DISCUSSION: 

AOT425statpgm (Version: 1.0) Test Results and Recommendations 

Acute Oral Toxicity (OECD Test Guideline 425) Statistical Program 

DatelTime: Tuesday, July 15,2008,2:29:45 PM 

Data file name: work.dat 

modified: 7/1512008 PM 

Test/Substance: Paraquat 43.8% 

Main 

(mglkg): 2000 

LDso Default 

Assumed 0.5 

Recommended dose 2000,550,175,55,17.5, 

DATA: 

Animal Dose Short-tenn Long-term 

Seq. ID (mg/kg) Result Result 

1 3101 174 

2 3102 550 

3 3103 1750 

4 31 550 

5 3105 174 

6 3106 550 

7 3107 174 

8 3108 

eX Died, 0 = Survived) 

0 

0 

X 

X 

0 

0 

X 

o 

X 

o 

o 

Dose Recommendation: main test is complete. 

Stopping criteria met: criterion. 

7 

1 
SUMMARY OF LONG-TERM RESULTS: 

Dose 0 X Total 

174 3 0 3 

0 4 4 

1750 0 1 1 

All Doses 3 5 8 

Statistical Estimate based on long tenn outcomes: 

Estimated LDso = 254 (Based on an assumed sigma of 0.5). 

Approximate 95% confidence interval is 174 to 550. 

Animals were dosed as follows: 

Animal 

3101 

Number Sex 

F 

~ 

174 

3102 F 550 

3103 F 1750 

3104 F 550 

3105 F 174 

3106 F 550 

3107 F 174 

3108 F 550 

S = Survival, D = Death 

Long-Term 

Outcome 

S 

D 

D 

D 

S 

D 

S 

D 

===..... AU animals dosed at 550 mglkg died within 

dosed at 1750 mglkg died within one day Of .... V3UIJ;;. 

days of dosing and the animal 

!:d!l!lli~Q!2li£!:rn!2!lll: Hypoactivity, reduced fecal volume, soft hunched posture, 

and/or piloerection were all 550 to death. 1750 

animal was hypoactive prior to death. AU 1 P'o .... J"""" weight and were active 

healthy during 

C. No abnonnalities were noted from any 1 

Discoloration of the intestines was noted 

D. Deviations: Due to a technician Animal Number 3107 was weighed on 10 instead 

of 7. 

8 
dichloride) 

E. This reviewer agrees with the study author regarding the acute oral 

9 
Reviewer: ___ -...;::=..:..::::. _______ _ Date: July 15,2008 

Risk Manager (EPA): 

STUDY TYPE: Acute Dennal Toxicity - Rat; OPPTS 870.1200; OECD 402 

TEST MATERIAL: Paraquat 43.8% Tech (-48% paraquat dichloride; Lot No. not reported, 

PSL Reference No. 061026-40; dark green liquid, pH 3.98 as a 1 % w/w solution, specific 

gravity 1.157 g/mL, soluble in water) 

CITATION: Lowe, (2007) Paraquat 43.8% Tech - Acute Toxicity in Rats -Limit 

Study Number 21078. EurofinslProduct Safety Laboratories, 2394 US Highway 130, 

Dayton. NJ 08810. February 20,2007. MRID 47091108. 

Source Dynamics 10039 North Scottsdale, 85262 

In an acute dermal toxicity study (MRID 47091108), five male 

rats 0 weeks; body weight: 307-

316 g and females: 209-218 source: Ace Animals, Inc., Boyertown, PA) were dermally 

exposed for 24 hours on an area of approximately 10% of the total body area on 

clipped dorsal trunk to 2000 mglkg bw Paraquat 43.8% Tech (-48% paraquat dichloride; Lot No. 

not reported; pH 3 as a 1 % w/w solution) as test material was applied evenly 

over the area and covered with a pad. gauze the trunk were wrapped with 

Durapore tape. The animals were observed for 14 days. 

All animals survived and weight during the study. Irregular respiration was noted. from 

one male and three females on day 1. All other appeared active and healthy throughout 

the study. Erythema and were noted on two males and on 1 to 4 or 1 

...... .., ... ",,;.« was noted on on days 5 to or No gross abnormalities were noted at 

LD50 Males > 2000 mglkg bw 

LD50 > 2000 bw 

LD.so Combined. > 2000 bw 

Paraquat 43.8'Vo Tech is EPA Toxicity Category HI. 

This is classified as acceptable. It does satisfy guideline lrernenrs for an acute 

dermal study (OPPTS 870.1200; OECD 402) in the rat. 

COMPLIANCE: Signed and dated GLP, Quality Assurance and Data Confidentiality 

statements were provided. 

10 
RESULTS and DISCUSSION: 

Mortality: All animals survived the study. 

B. Clinical observations: Irregular respiration was noted from one male and three females on 

day 1. All other animals appeared active and healthy throughout the study. Erythema and 

edema were noted on two males and four females on days 1 to 4 or 1 . Eschar was noted on 

four females on days 5 to 12 or 5-14. All animals gained weight throughout the study. 

C. !:!!.2!I!~:£r!m!l::: No gross abnormalities were noted at necropsy. 

D. ~~~~~~~l¥;I!ol!.' This reviewer agrees with the study author regarding the acute 

dermal LDso. 

11 
"''''''''''''1[ dichloride) 

Reviewer: ORNL Date: July 15,2008 

Risk Manager (EPA): 25 

STUDY TYPE: Acute Inhalation Toxicity Rat; OPPTS 870.1300; DECD 403 

Paraquat 43.8% 

PSL Reference No. 061026-4G; dark 

water) 

(-48% paraquat dichloride; Lot No. not reported, 

liquid, pH 3.98 as a 1 % w/w solution, soluble in 

Lowe, (2007) Paraquat .8% Tech Acute Inhalation Toxicity Study in Rats 

- Limit Test. Study Number 21079. EurofinsfProduct Safety Laboratories, 2394 US Highway 

130, Dayton, NJ 08810. March 14,2007. MRlD 47091109. 

SPONSOR: Source Dynamics 10039 Troon North Drive, Scottsdale, AZ 85262 

In an acute inhalation toxicity study (MRID 47091109), five male 

and five female young adult Sprague-Dawley rats (age: 9~10 weeks; body weight: males: 297-

g and females: source: Ace Animals, Boyertown, PA) were exposed noseonly inhalation to Paraquat .8% (-48% paraquat dichloride; Lot No. not reported) for 4 

hours and 1 minute at a concentration of 0.051 mglL. The were observed for 14 days. 

The MMAD was 2.1 and 2.2 !lIn and the GSD 2.14 and 2.02 at 1.5 and 3 hours, respectively. 

All males and four females died within 2-4 days following exposure and one female was 

emaciated and euthanized on day 7. All animals exhibited abnonnal respiration, 

hypoactivity, piloerection., and reduced fecal volume within one day of exposure. All animals 

had discolored lungs, liver, and/or intestines; edematous lungs~ intestines distended with 

and/or at n .. '· .... " ... ;;,'11 

LC50 Males < 0,051 mglL 

LCso Females < 0.051 mglL 

Combined < 0,051 mglL 

Paraquat 43.8% Tech is in EPA Toxicity Category I. 

This study is classified as acceptable, It does satisfy the guideline 

inhalation study (DPPTS 870.1300; DECD 403) in the rat. 

for an acute 

COMPLIANCE: Signed and dated GLP, Quality Assurance and Data Confidentiality 

statements were provided. 

12 
RESULTS and DISCUSSION: 

Nominal 

Cone. MMAD 

~ 

GSD 

2.1,2.2 2.14,2.02 

MortalltylNumber Tested 

Test Atmosphere / Chamber Description: The exposure atmosphere was generated a 114 

inch JeO atomizer (Spraying Systems Co.), fluid cap (Robert Miller and 70 

air cap (Spraying Systems The test was metered to the atomization through 

a pump with a 60 mL plastic air was supplied by an air compressor 

connected to the spray atomization nozzle. Additional compressed mixing air was supplied from 

a compressed air tank. Animals were individually housed in polycarbonate holding which 

were to chamber during exposure. The exposure chamber was a Mini Nose-Only 

Chamber (ADG Developments Ltd.). 

Gravimetric Cone. (mg/L): 0.051 

I.,. .. 

! U.I 

Total Airflow (L/min): 25.7 

Temperature 21-23°C 

Relative Humidity 

Time to equilibrium: 1 minute 

Test atmosphere concentration: exposure, samples were collected five 

from the breathing zone of the animals, glass filters. papers were 

weighed before and collection to determine the mass collected. The value was divided by 

the total volume of air sampled to determine the chamber concentration. 

Particle size determination: Particle was determined twice using an eight-stage Andersen 

"""",,",u,",,,,, impactor. The test material concentration coHected at was aet:errrurle<1 

gravimetrically. The mass median diameter geometric standard were 

determined graphically using two-cycle logarithmic probit axes. 

A. MortaliD:.': All males and four females died within 2-4 following exposure and one 

female was emaciated and euthanized on day 7 for humane reasons. 

B. All animals exhibited abnonnal respiration, facial staining, 

hypoactivity, piloerection, and reduced fecal volume within one day of exposure. 

13 
C. All animals had discolored lungs~ liver, and/or 

distended intestines with and/or at necropsy. 

This reviewer with the study author the acute 

14 
1l'lMl!IQuat dichloride) 

Re~ewer: ______ ~~~ ______________ _ Date: July 15,2008 

Risk Manager (EPA): 25 

=~::;....:;......::....:~::::;. Primary - Rabbit; OPPTS 870.2400; OECD 405 

~~~~~~~. Paraquat Technical (a minimum of 45% paraquat; Batch No. OFE0016; 

green liquid, pH -5.5) 

CITATION: (2002) Paraquat Technica!- hritation Test in Rabbits. 

Project Number 501218. Inveresk Research, Tranent Eh33 2NE, Scotland. February 12, 2002. 

MRID 46098805. 

SPONSOR: Source Dynamics LLC, 10039 Troon North Drive, Scottsdale, AZ 85262 

EXECUTIVE SUMMARY: In a primary irritation study (MRID 46098805), 0.1 of 

undiluted Paraquat Technical (a minimum of 45% paraquat; Batch No. OFE0016; pH -5.5) was 

instilled into the conjunctival sac of the right eye of three young adult New Zealand White 

rabbits Charles River UK Limited, Marston Road, Margate, Kent). The untreated 

served as a controL One rabbit was treated first and observed for signs irritation for 24 

none were noted, the remaining two rabbits were treated. The animals were observed 

hours. 

Corneal opacity and were not noted in any rabbit eye during the study. Positive 

conjunctival irritation was noted in eyes at 24 hours and in eyes at 72 hours after test 

material instillation. to systemic toxicity including salivation, inappetence, and reddening 

of gums, one animal was killed on day 6 (five days after test material instillation) and two 

animals were killed on day 5 (four days after test material instillation). 

In this study, the Toxicity Category cannot be assigned due to early termination of the 

study. TRB is assigning Toxicity Category I. 

is classified as unacceptable. It not satisfy guideline for a 

irritation study (OPPTS 870.2400; OECD 405) in the rabbit, but due to extreme 

toxicity of the test material, is assigning a Toxicity Category 1. The study should not be 

repeated, 

Signed and dated 

statements were provided. 

Quality Assurance and Data Confidentiality 

15 
RESULTS and DISCUSSION: 

Number" ositive"lNumber treated 

Hours 

1 24 48 72 

0/3 0/3 0/3 0/3 

0/3 0/3 0/3 0/3 0/3 

0/3 2/3 3/3 2/3 

0/3 0/3 0/3 0/3 0/3 

Dischar e** 0/3 0/3 3/3 3/3 3/3 

'" Score of2 or more required to be considered "positive" 

** Discharge is not a positive effect according to the grading scale 

A. Observations: Corneal opacity and iritis were not noted in any rabbit eye during the study. 

Positive conjunctival irritation was noted in 2/3 eyes at 24 hours and in 3/3 eyes at 72 hours 

after test material instillation. Due to systemic toxicity including salivation, inappetence, and 

reddening gums, one animal was killed on day 6 (five days after test material instillation) 

and two animals were killed on day 5 (four days test material instillation). No corneal 

opacity, iritis, or conjunctival irritation were noted from the control 

B. Results: highest maximum mean total score was 1 O.O~ recorded 48 and 72 hours after 

test material instillation (calculated by the reviewer). 

C. study author concludes that "Following an ocular instillation 

of Paraquat Technical, it has been found to be systemically toxic to rabbits; ... Due to 

early termination study the are inconclusive with to irritation." TRB 

agrees with this conclusion and is assigning Toxicity I primary eye irritation 

based on an examination of the labels often currently products containing 30.1 % 

to 45.6% paraquat dichloride which are all in lor II for irritation. For animal 

welfare reasons} is against any further testing of this product. 

16 
(plmlquat dichloride) 

Reviewer: ------~~~--------------- Date: July 2008 

Risk Manager (EPA): 

STUDY TYPE: Primary Dennal Irritation - Rabbit; OPPTS 870.2500; 404 

TEST MATERIAL: Paraquat 43.8% (-48% paraquat dichloride; Lot No. not reported, 

PSL Reference No. 061026-4G; dark green liquid, pH 3.98 as a 1 % w/w solution, specific 

gravity 1.157 glmL, soluble water) 

CITATION: Lowe, C. (2007) Paraquat 43.8% Tech - Primary Skin Irritation Study in Rabbits. 

Study Number 21081. Eurofins/Product Safety Laboratories, 2394 US Highway 130, Dayton, 

NJ 08810. February 20, 2007. MRID 47091110. 

SPONSOR: Source Dynamics LLC, 10039 Troon North Drive, Scottsdale, AZ 85262 

In a primary dennal irritation study (MRlD 47091110), one male 

young adult New Zealand White rabbit (source: Robinson Services, Inc., Clemmons, NC) was 

dermally to 0.5 mL of undiluted Paraquat 43.8% (-48% paraquat dichloride; Lot 

No. not reported; pH 3.98 as a 1 % w/w solution) for 3 1 hour, and 4 hours, respectively, 

on three 6 cm

2 

areas the clipped dorsal skin that were covered with patches. The 

patches and trunk were wrapped with semi~occlusive Micropore tape. The animal was observed 

and irritation was scored at 1, 24, 48, and 72 hours after patch removaL Two additional rabbits 

were for four hours using the same procedure as the rabbit. 

Very slight erythema was noted on 3/3 rabbits 30-60 minutes after patch removal with clearance 

72 hours. Very slight edema was noted on rabbits 30-60 minutes after patch removal with 

with clearance by 24 hours. In addition, the first animal tested "exhibited an unthrifty 

appearance, nasal discharge, yellowlbrown in color and excessive salivation with no apparent 

abscess at hours." 

In this study, the formulation was slightly irritating based on the Primary Irritation Index 

(PH) of 1.0. Paraquat 43.8% Tech is in EPA Toxicity Category IV for primary dermal 

irritation. 

This study is classified as acceptable. It does satisfy the guideline requirements a primary 

dermal irritation study (OPPTS 870.2500; OECD 404) in the rabbit. 

~~~~~~. Signed and dated 

statements were provided. 

Quality Assurance and Data Confidentiality 

17 
tpantquat dichloride) 

RESULTS and DISCUSSION: 

Animal Sex Hours 

Number 1 24 48 72 

3501 M' lila 1/0 110 0/0 

3502 M 111 110 110 0/0 

3503 M 111 110 1/0 010 

Severity of Irritation 2.0 LO 1.0 0.0 

- Mean Score 

a ErytItvloaiedem. 

A. Observations: Very slight erythema was noted on 3/3 rabbits (treated for 4 hours) 30-60 

minutes patch removal with clearance by 72 hours. Very slight edema was noted on 3/3 

rabbits 30-60 minutes after patch removal with clearance by 24 hours. The test site on the 

rabbit for 3 minutes had no dennal irritation. test site on the first rabbit 

for one hour had slight erythema 30-60 minutes after patch removal with 

clearance by 24 hours. In addition, the first animal tested "exhibited an unthrifty appearance, 

nasal discharge, yeIlowlbrown in and excessive salivation with no apparent abscess at 

hours." 

B. === 43.8% Tech was slightly irritating. The Primary Irritation Index (PIl) is 

1.0. 

with the author the test material 

18 
Reviewer: ORNL Date: July 16,2008 

Risk Manager (EPA): 

STUDY TYPE: Dennal Sensitization guinea pig; OPPTS 870.2600; OECD 406 

TEST MATERIAL: Paraquat 43.8% Tech (-48% paraquat dichloride; Lot No. not reported, 

PSL Reference No. 061026-40; dark liquid, pH 3 as a 1 % w/w solution, soluble in 

water) 

Lowe, C. (2007) Paraquat 43.8% - Dermal Sensitization Study 

pigs (Buehler Method). Study Number 21082. EurofinslProduct Safety .......... 'VL ... VL ....... > 2394 US 

Highway 130, Dayto~ NJ 08810. 12,2007. Amended 1,2007. MRID 

47091111 

~~=;.;::;.::;' Source Dynamics 10039 E. North Scottsdale, 

In a dennal study (MRID 47091111) with Paraquat 

43.8% (-48% paraquat dichloride; No. not reported; pH 3.98 as 1 % w/w solution), 30 

male young adu)t albino guinea pigs (body Hill Breeding 

Labs, Chehnsford, MA) were using Buehler Method. test were induced 

with 0.4 of undiluted test material for six 25 rom Hill Chambers that were . 

secured and wrapped with non-allergenic adhesive tape. The was repeated once 

week for three consecutive weeks. to the of irritation noted after the first induction, 

mL of an 80% w/w test material distilled water was used for the second and third 

inductions. Twenty ... seven days after the first induction, the test animals were challenged with 

0.4 roL of a 12% w/w test material in distilled water under occlusion to naive sites. naive 

control animals were with 0.4 mL of a 12%1 test material in distilled water under 

occlusion at challenge. Reactions were scored 24 and 48 hours after test material applications. 

animals were found dead during the induction phase and three animals were found 

prior to chaIIenge. After consecutive weekly inductions~ 5114 animals and 4114 anUnals 

had reactions at and 48 hours after challenge. 

Based on the results of this study, Paraqu.at 43.8% Tech was a dermal sensitizer. The 

mean Challenge scores were 0.30 and 0.54 for naive control and test animals, respectively, 

at 24 hours and 0.15 and 0.50 for naive control and test animals, respectively, at 48 hours. 

This study is classified as acceptable. It does satisfy guideline requirements for a dermal 

sensitization study (OPPTS 870.2600; 406) in the guinea pig. 

and dated Quality Assurance and Data Confidentiality 

statements were provided. 

19 

<{;\ 
1",,,,£11\""" dichloride) 

PROCEDURE: 

A. Induction: The animals were induced and challenged according to the Buehler method. The 

dorsal and flank areas of 20 test guinea pigs were clipped prior to each treatment. For 

induction, 0.4 mL of undiluted test material was applied to the animal using a rom Hill 

Top Chamber and secured with non-allergenic adhesive tape. The chamber was removed 

after six hours and excess test material removed. The procedure was repeated once each 

week three consecutive weeks. Due to the severity of irritation noted after the first 

:induction, 0.4 mL of an 80% wlw test material in distilled water was used for the second and 

third inductions. Reactions were scored and 48 hours after the induction applications. 

B. Challenge: Twenty-seven days after the first induction, the test animals were challenged 

with 0.4 mL of a 12% wlw test in distilled water under occlusion to naive for 6 

hours. Reactions were scored 24 and 48 hours after challenge application. 

C. Naive control: dorsal and flank areas of 10 naive control animals were dipped prior to 

treatment challenge, the control group was treated with 0.4 mL of a 12% wlw test 

in distilled water for 6 hours. Reactions were scored 24 and 48 hours following 

challenge application. 

RESULTS and DISCUSSION: 

A. Three animals were found dead the induction phase and 

three animals were found dead prior to challenge. Prior to death, three test animals were 

hypoactive and exhibited irregular respiration andlor unthrifty appearance. the 

surviving test animals also exhibited hypoactivity after the induction phase. The application 

dose were relocated for the third induction due to previous desquamation/eschar. 

faint to moderate erythema (0.5-2) was noted on 17/17 test animals over the course three 

inductions. Very faint erythema was noted on 6/10 naive control animals 24 hours after 

challenge with clearance on 3/6 control animals 48 hours after challenge. of 

fourteen test animals exhibited of a sensitization response (faint erythema [1 J) at 24 

hours and four of fourteen at 48 hours after chaHenge. Very faint erythema (0.5) was noted 

for most other sites after challenge. Therefore, the test was a dermal sensitizer. 

B. The report included the of a positive control (alphahexylcinnamaldehyde) study #20608 conducted within months ofllie current study; the 

results were appropriate. 

reviewer with the study author that the test material was 

D. There was an error Table 6 on 22 the challenge phase skin 

reaction scores. This error was corrected and the study was amended on September 11,2007. 

20 
(~"~.n"" dichloride) 

1. DP BARCODE: DP353730 

PC CODE: 061601 

CURRENT DATE: July 15, 2008 

4. TEST MATERIAL: Paraquat .8% Tech (-.-48% paraquat dichloride; Lot No. not reported, 

fPrpnf'P No. 061026-4G; dark liquid) pH 3.98 as a 1 % w/w solution, 

soluble in water 

Study/SpecieslLab 

Stud '# / Date 

Acute toxicitylrat 

Eurofins/Product Safety 

Laboratories 

21077/March 15,2007 

dennal toxicity/rat 

EurofinsIProduct Safety 

Laboratories 

21 078/F ebru 2007 

Acute inhalation toxicity/rat 

EurofinslProduct Safety 

Laboratories 

21079/March 14, 2007 

Primary irritation/rabbit 

Inveresk Research, Scotland 

S012lS/February 12, 

MRID 

47091107 

47091108 

47091109 

46098805 

Primary deonal irritation/rabbit 4709111 0 

EurofinslProduct Safety 

Laboratories 

Laboratories 

21082/Februa 12,2007 

47091111 

Results Tox. Core 

Cat. 

LDso 254 roglkg bw II A 

LDso > 2000 mglkg bw III 

males, females combined 

A 

LCso < 0.051 mgIL I 

H ...... ~ ... , females combined 

U 

Slightly irritating IV A 

Sensitizing A 

Core Grade Key: A = Acceptable, S == Supplementary, U = Unacceptable, W = Waived 

21 
DATE OUT: 

SUBJECT: 

FROM: 

TO: 

01[ OCTOBER [2008 

PRODUCT CHEMISTRY REVIEW OF MP [ X] EP [ ] 

DP No.; EPA FUe Symbol No.: 

PRODUCT NAME: ~==~~ 

COMPANY: Helm Acro US, Inc. 

FOOD USE [ X] INTEGRATED FORMULATION [X] 

PCC: Q61601 Decision No. 393061 

ACTION CODE: R310 

Hari Mukhoty DVM. PHD 

Product Team 

~. Review Branch / RD (7505P) 

Hope Johnson / James Tompkins, RM 25 

Herbicide Branch / RD (7505P) 

The Registrant has submitted one 06/06/2008, a product proposed label dated 

06/05/2008 under File symbol 74530-GT (or '''',..,'''''1''<:1'''' .... of the proposed product The product chemistry 

data have been submitted under MRIDs: 473897-01, 03, and -04. 

The applicant claims that the proposed product is substantially similar (me-too) to another product 

under EPA No, 70552-1 (Product name: Paraquat Technicel Concentrate). The cited product was 

conditionally registered on 05/19/2005 and the label was found 08/21/2008. The product chemistry 

data for the cited product were reviewed and were found on 05/16/2005. 

The MUP is manufactured by Helm Shanghai in China. 

Label text indicates that this OreJIDO!300 MUP can be formulated into products with food uses, 

TRB has been requested to evaluate the product chemistry data required the registration of the proposed 

basic MUP, and to determine if the proposed basic product is substantially similar to the cHad basic product. 

SUMMARY OF FINDINGS: 

1, The proposed MUP contains one active ingredient: Paraquat dichloride (43.8%). 

2. The overall mean of the active ingredient from the five batch analysis is 43.78% [MRID 473897-02, Page 4 of 

126]. 

3. The nominal concentration of the active ingredient used in this formulation is 43.8%. The nominal 

concentration of the active ingredient matches with the label claim. This is in compliance with PR Notice 91-2. 

The certified limits for active and inert ingredients, and the impuritIes <Xlmply with 40 158.350 (b) (2). 

4. The CSF of the proposed MUP (dated 06/06/2008) is filled out completely and correctly. This CSF has been 

reviewed and the inert ingredients are approved for food use by I.IA Branch on 9/30/2008. Inert branch 

mentioned a note to the PM with respect to the restrictions on the use of ona inert used in this product last 

page of this review]. 

1 
DP BAI~C()De No.: 353729 File sVlln"'n No.: 74530~GT PRODUCT NAME: Paraquat TC. 

to guidelines 830.1550 (product identity and 

830.1650 (description of 

(certified limits) the 

158.335, 158.340, and 158.350 

6. 

GC-MS was used to determine 

analytical techniques can also be aDDlled for Fnt'nrr.p.m,.,.nt Analytical Method [830.1800 - see Page 18 of 

appendix]. 

",,,,<:.m,·o:.Tru Group A and 

I':nrTf'l«:l:lnn characteristics 1'''' .... '" ..... '''"''''''' J il:>1.UU"';;;:>. were 

<::rn .. ",n"" stability (830.6317) 

two studies are in 

473897-01, 

8. The proposed product is not SUI)Sllimually similar the cited The concentration of the 

active used in the is lower than the lower certified limit of the cited product. The 

propo~)ed product contains additional to the cited product table of comparison of 

impurities, Pages 21-22 of 

CONCLUSIONS: 

1, TRB has reviewed the the MUP. and has found it to be acc:aPltable. 

2. The propo!:.ea product is not 11'1 .. ,nTlT"'l'" to the cited product [see item # 8 above]. 

3. Product data 

stability and corrosion Ch~lra(~teristi(::s ""'uu:,,"<>. 

4. The N'>I'lI«:ltr~r'" 

data an 

The results must 

exc;epl:lon of ane year storage 

(830.6317) corrOSion (830.6320) 

nn<,,,,n/<:l .. ,,,,,,,,, be made at 0, 3,6, 9, and 12 month intervals. 

and hard copy 

2 
BARCODE No.: 353729 EPA File Symbol No.: 74530-GT PRODUCT NAME: TC. 

PRODUCT CHEMISTRY DATA 830 Group A) 

Group A Data Required MRIDNo. 

Fulfilled 

830.1550. Chemical Identity (same as in Product CSF A 473897-01 

dated 06/06/2008) 

830.1600. Beginning Materials A 473897-01 

830.1620. Production process I A 473897-01 

830.1650. Formulation process NIA 

830.1670. Discussion of Impurities A 473897-01 

830.1700. Preliminary Analysis A 413897-02, -03 

830.1 Certified Limits CSF dated 06/06/2008) A 473987 

·01 

830.1800. Enforcement Analytical Method A 7-02, -03 

A = AC(:eotable 

3 
DP BARCODE No.: EPA File Symbol No.: 74530-GT PRODUCT NAME: Paraquat TC, 

Group B 

A 

A Liquid 

830,6304. Odor A 47389701 

mild 

odor,stench 

830.6313. Stability to normal and elevated A Hygroscopic, 47389701 

temp, metals and metal ions Corrosive to 

metals, 

hydrolyzes 

under alkaline 

conditions, & 

photochemical! 

830-6314. Oxidation/Reduction action- A with 47389701 

Chemical incompatibility AI, slightly 

corrosive with 

Zn & but 

non-corrosive 

with 

polyethylene 

830.6316. Explodability A Not explosive 47389701 

in nQrmal 

and 

use conditions 

830.6317. Storage stability G One year long 

study data 

830.6319. Miscibility A Miscible 47389701 

4 ® 
830.6320. Corrosion Characteristics G One year long 

study data 

required 

830.7200. Melting pOint A ! 340Q C 47389701 

830.7220. Boiling point A 170-180Q C 47389701 

830.7050. UV/visible light absorption N/A Formulated 

MUP 

830.7370. Dissociation Constant N/A Formulated 

MUP 

830.7550. Partition Coefficient A Kow logP = -4.5 47389701 

at20Q C 

S30.7950. Vapor Pressure A sO.0001 Pa at 47389701 

20QC 

830.7840. Solubility (Cited for water) A Not soluble in 47389701 

acetone & 

hexane, freely 

soluble in 

water 620 gil 

830.7000. pH A 4.9 (1% aq) 47389701 

830.7300. DensitylTrue Density A 1.146 g/mL at 47389701 

20QC 

Explanations: A = The Requirements Were Fulfilled; N = The Requirements Were Not Fulfilled; NA = Not 

Applicable; G = Data Gap; U = Requires Upgrading; I = Incomplete or In Progress; W = Waived. 

5 
Page is not included s copy. 

Pages 90 through 107 are not luded in this copy. 

The material not included contains the following type of 

information: 

Identity of product ingredients. 

Identity of product 

X Description of the product manufacturing process. 

Description of qual control procedures. 

Identity of the source of product ingredients. 

Sales or other commercial/f information. 

A draft product 

The product confident statement of formula. 

Information about a registration action. 

FIFRA registration 

The document is a dupl of page(s) 

The document is not to the request. 

Internal deliberat ormation. ----

Attorney-Client work product. 

Claimed Confident by submitter upon submission to the 

Agency. 

Personal Privacy Information 

The information not included is ly considered confidential 

by product registrants. If you have any questions, please contact 

the individual who prepared the to your request. 
Document Processing Desk (RD ) 

Office of Pesticide Programs (7504P) 

U.S. Environmental Protection Agency 

One Potomac Yard, Room S-4900 

2777 S. Crystal Drive 

Arlington, VA 22202-4501 

Attention: Ms. Hope A. Johnson 

Registration Division 

HELm FlGRO US, INC. 

8295 Tournament Drive, Suite 310 

Memphis, Tennessee 38125 

Phone: (901) 312-1525 

Fax: (901) 312-1535 

Via Courier Delivery 

June 13, 2008 

Subject: Paraquat TC (EPA-Reg.No.74530 - GT), 

OPP Decision No.: 0-391789 

Resubmission of Application for "me-too" registration 

Dear Ms. Johnson: 

This submission is in response to your recent e-mail dated June 5th 2008 to 

Marshall Wixson and our discussion over the phone. Herewith, HELM Agro US'lnc. 

is withdrawing all previously submitted material regarding the subject application, and 

we request replacing all the materials with the enclosed information. 

As indicated earlier, this is an application for a new "me-too" registration of the 

active ingredient, Paraquat Dichloride, being used as a Manufacturing Use Product 

(MUP) in formulating registered End-Use Products. The product is very similar in its 

composition and labeling to existing products, such as Paraquat Dichloride Technical 

(EPA Reg. No. 83558-5), and Paraquat Technical Concentrate (EPA Reg. No. 

70552-1). 

Enclosed you will find the following information/administrative materials in support 

of the subject application: 

1. EPA Form 8570-1: 

An executed "Application for Pesticide Registration" (OPP Identifier # 

259593). 

2. Bibliography of Submitted Studies , J. 

One copy of the Bibliography of the previously submitted studies witH 

assigned IVIRID numbers. 

J, • 
3. Proposed Label 

Five copies of the proposed Paraquat TC label. 

5. Confidential Statement of Formula 

One copy of the Confidential Statement of Formula (CSF) dated June 6, 

2008, and the appropriate MSDS of the emetic and colorant as listed on the 

CSF. 

6. Certification with Respect to Citation of Generic Data 

Helm is using the cite-all option under the selective method to satisfy the 

data requirements for this product application as indicated on the executed 

EPA form 8570-34 with respect to Citation of Generic Data. 

7. Data Matrix (EPA form 8570-35) 

One copy of a data matrix of all previously submitted data (including the 

generic data submitters) in support of the proposed registration is enclosed 

(one copy for Agency Internal Use, and one copy for Public Use). Helm is 

offering to pay data compensation to those registrants appearing on the most 

recent, published Data Submitters List for Paraquat Dichloride dated March 

31,2008. 

7. Registration Service Fee 

The PRIA II registration fee ($4,360) has been paid. Payment was received 

by the Agency as confirmed on April 3, 2008. 

Please do not hesitate to contact me at 610-793-3222 or at bertvolger@comcast.net, if 

you need any additional information or assistance regarding this application. 

Cc: Marshall Wixson - Helm 

Sincerely, 

:r~r 1G1r-J 

Bert Volger, Ph.D. 

Consultant for 

HELM Agro US, Inc. 
,'7" 

BIBLIOGRAPHY OF SUBMITTED STUDIES 

Name and Address of Submitter: Helm Agro US, Inc. 

8295 Tournament Drive, Suite 310 

Memphis, TN 38125 

Product(s): Paraquat TC (Technical) 

EPA Registration No: 74530-to be assigned 

Page 1 of 2 

Purpose of Submissiou: Submission of data in support of the application for a "me-too" 

registration of Paraquat TC (Technical) 

Date of Submission: March 31> 2008 

Volume Study Title Laboratory, 

Number ID Number 

10f4 Paraquat TC HELM, 

Product Identity and Composition #080328 

Description of Materials Used 

Description of Production Process 

Discussion of the Formation of 

Impurities 

Certified Limits 

Submittal of Sample 

20f4 Paraquat TC Inveresk, 

5 - Batch Analysis of Paraquat #22220 

Dichloride (Preliminary analysis, 

amended report) 

30f4 Paraquat TC Inveresk, 

5 - Batch Analysis of Paraquat #25044 

Dichloride: Supplementary Study to 

Measure Total Terpyridine Content 

of Paraquat Dichloride I I 

OPPTS 

Guideline 

Reference 

Number 

830.1550, 

830.1600, 

830.1620, 

830.1670, 

830.1750, & 

830.1900 

830.1700, 

830.1750, 

830.1800 

830.1700 

~.' l~ l..' i,' t,} C, 

.... (.. C. 

(;, {.I 

(: i. (. 1.. .. C· (; 

t.- (: 

'.J ..... :,,'l" .. : 

'... \., 

.... \i,;\,;Ot.l 

EPAMRID 

Number 

(Reserved for EPA 

C' 

Use) 

47389701 

47389702 

47389703 

t;(, 

<, 1', ;, 

c.\ i.-v 

c· 

o 

",i'" '.' b ,,; 

ce,c G t: 

" 
,. 

", 

Volume Study Title Laboratory, 

Number IDNumber 

4 of4 Paraquat TC Microquim, 

Physicochemical Analysis of Fa - 25158/03 

Technical Grade Products (Color, 

Physical State, Odor, Flammability, 

Stability, Corrosion Characteristics, 

pH, Absorption Spectrum, Boiling 

Point, Density, Solubility) 

OPPTS 

Guideline 

Reference 

Number 

830.6302, 

830.6303, 

830.6304, 

830.6315, 

830.6317, 

830.6320, 

830.7000, 

830,7050, 

830.7220, 

830.7300, 

830.7840 

(, (,.. (,J c.' (1 ... 

~ 0 <> 

" 

L r. ,-, l't/ 

t' (. 

l"'" :.....~v 

Page 2 of 2 

EPAMRID 

Number 

(Reserved for EPA 

Use) 

47389704 

, ~~ (, 1...' (I 

o c C. (: 

2 
Please read instructions on reverse before completing for" Form ApproVf QMB No. 2070-0060. Approval expires 05-31-98 

) 

&EPA United States 

Environmental Protection Agency 

Washington, DC 20460 

[R] 

D 

D 

Regis[ration 

Amendment 

Other 

OPP Identifier Number 

259593 

Application for Pesticide - Section I 

1. Company/Product Number 

74530-GT 

4. Company/Product (Name) 

Paraquat TC 

5. Name and Address of Application (Include ZIP Code) 

Helm Agro US, Inc. 

8295 Tournament Drive, Suite 310 

Memphis, TN 38125 

D 

D 

D Check If this is a new address 

Amendment - Explain below. 

Resubmission in response to Agency letter dated 

D Notification - Explain below. 

2. EPA Product Manager 

Hope Johnson 

3. Proposed Classification 

PM# 

PM 01 Ix I None D Restricted 

6. Expedited Review. In accordance with FIFRA Section 3(c)(3) 

(b)(i), my product is similar or identical in composition and labeling 

to: 

EPA Reg. No. 70552-1 

Product Name: Paraquat Technical Concentrate 

Section -II 

D Final printed labels in response to 

Agency lelter dated ______ _ 

D "Me Too" Application. 

ffi Explain below. 

Explanation: Use additional page(s) if necessary. (For Section I and Section 11,) 

Subject: OPP Decision Number: 0-391789 

Resubmission of application for a "me-too" registration of a new manufacturing use product, Paraquat TC, that 

requires reviews of product chemistry data (Non-fast track; PRIA EPA # R310, EPA decision review time of 6 months, 

fee = $4,360); this application replaces the one of April 30, 2008. 

Contact by EMAIL: bertvolger@comcast.net 

1. Material This Product Will Be Packaged In: 

Child-Resistant Packaging 

DYes 

D No 

* Certification must be 

submitted 

Unit Packaging 

DYes 

D No 

If "Yes", Unit 

Packaging wgt. 

3. Location of Net Contents Information 

D Label D Container 

6. Manner in Which Label is Affixed to Product 

No. per 

container 

Section - III 

Water Soluble Packaging 

DYes 

D No 

If "Yes" 

Package wgt 

No. per 

container 

4. Size(s) Retail Container 

~I ==::1 Lithograph 

~I ==~I Paper glued 

1 I Stenciled 

Section -IV 

2. ype of c10ntainer 

Metal 

D Plastic 

~I =~I Glass 

I I Paper 

:=1 ====:1 Other (Specify) 

5. Location of Label Directions 

1 I On Label 

1 I On Labeling accompanying product 

D Other __________ _ 

1. Contact Point (Complete items directly below for identification of individual to be contacted, if necessary, to process this application.) 

Name Title Telephone No. (Include Area Code) 

Bert Volger Consultant for Phone: 610-793-3222 

~ _______________________________ ~~~ ____ ~~H~E~L~M~A~\g~lr~o~U~S~,~ln~c~ ______ ~~F~a~x:+p7)~P~?~Q.3-1703~~_' _r3 ____ ~ 

Certification ~ 6. ,)at~ Application $ 

I certil\t that the statements I have made on this form and all attachments thereto are true, accurate and complete. i' Rec~ived I acknowledge that any knowingly false or misleading statement may be punishable by fine or imprisonment or ,( ~Stampl~PJ)" 

both under applicable law. 

2. Signature "'\1'7""' _ ,1_ rh'~ r 3. Title ' ;, } ly I '-.-<. " v''f--''V Consultant for HELM Agro US, Inc. j , ' 

4. Typed Name 5. Date 

~~B~e~rt~V~o~lg~e~r ___ ~~~ __ ~ _____ ~~ __________ ~~06~/~13~/~20~0~8~~~~~~~~~ ____ ~~~. EPA Form 8570-1 (Rev. 8-94) PrevIous editions are obsolete. White - EPA FIle Copy (original) Yellow"- Ap,lllicant Copy 
Form Approved OMB No. 2070-0060 

~;~,.,\ UNITED STATES ENVIRONMENTAL PROTECTION AGENCY \,~~ "O«fI'i.L"#' 401 M Street, S.w. 

WASHINGTON, D.C. 20460 

Paperwork Reduction Act Notice: The public reporting burden for this collection of information is estimated to average 1.25 hours per response for registration 

and 0.25 hours per response for reregistration and special review activities, including time for reading the instructions and completing the necessary forms. Send 

comments regarding burden estimate or any other aspect of this collection of information, including suggestions for reducing the burden to: Director, OPPE 

Information Management Division (2137), U.S. Environmental Protection Agency, 401 M Street, S.w., Washington, DC 20460. 

Do not send the completed form to this address. 

Certification with Respect to Citation of Data 

Applicant's/ReQistrant's Name, Address, and Telephone Number EPA ReQistration Number/File Symbol 

Helm Agro US, Inc. 8295 Tournament Drive, Suite 310 Memphis, TN 38125 74530 - x 

Active Inqredient(s) and/or representative test compound(s) Date 

Paraquat dichloride June 6, 2008 

General Use Pattern(s) (list all those claimed for this product usinQ 40 CFR Part 158) Product Name 

Terrestrial Non Food, and Terrestrial Nonfood use sites Paraquat TC 

NOTE: 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 

submit this form. You must submit the Formulator'S Exemption Statement (EPA Form 8570-27). 

0 I am responding to a Data-Call-In Notice, and have included with this form a list of companies sent offers of compensation (the Data Matrix form should 

be used for this purpose). 

SECTION I: METHOD OF DATA SUPPORT (Check one method only) 

0 I am using the cite-all method of support, 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 (the Data Matrix form under the selective method), and have included with this form a 

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

used). 

SECTION II: GENERAL OFFER TO PAY 

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

[2] I hereby offer and agree to pay compensation, to other persons, with regard to the approval of this application, to the extent required by FIFRA. 

SECTION III: CERTIFICATION 

I certify that this application for registration, this form for reregistration, or this Data-Call-In response is supported by all data submitted or cited in the 

application for registration, the form for reregistration, or the Data-Call-In response. In addition, if the cite-all option or cite-all option under the selective method is 

indicated in Section I. this application is supported by all data in the Agency's files that (1) concern the properties or effects of this product or an identical or 

substantially similar product, or one or more of the ingredients in this product; and (2) is a type of data that would be required to be submitted under the data 

requirements in effect on the date of approval of this application if the application sought the initial registration of a product of identical or similar composition and 

uses. 

I certify that for each exclusive use study cited in support of this registration or reregistration, that I am the original data submitter or that I have obtained 

the written permiSSion of the original data submitter to cite that study. 

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

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

compensation have expired for the study; (d) the study is in the public literature; or (e) I have notified in writing the company that submitted the ''It'oId,y.and have 

offered (I) to pay compensation to the extent required by sections 3(c)(1 )(F) and/or 3(c)(2)(B) of FIFRA; and (ii) to commenCG 1J~~jJti?Jions to d'tt~11nin,e the 

amount and terms of compensation, if any, to be paid for the use of the study. ; ) 

I certify that in all instances where an offer of compensation is required, copies of all offers to pay compensation a:Jd 'ill!idepce of It!ejr d~lgvrry 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 requestt' Shq~ld I fail.to produce such 

evidence to the Agency upon request, I understand that the Agency may initiate action to deny, cancel or suspend the registration of my produ,Ur, sonformity with 

FIFRA. " ; 

" , ; 

I certify that the statements I have made on this form and all attachments to it are true, accurate, and cOI1lJ,.'latJ.) I acknowleage that any 

knowingly false or misleading statement may be punishable by fine or imprisonment or both under applicable law. > " 

-

~.~-{- rJ:=;~ ( ) 

Signature Date Typed or Printed Name and Title' j c , 

June 6, 2008 Bert Volger, Consultant for Helm Agro Inc. 

EPA Form 8570-34 (9-97) Electronic and Paper versions available. Submit only Paper version. I 

! j I I 
Form Approved OMB No. 2070-0060 

/,{on~,.,..,. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 

(~) 401 M Street, S.W. 

~~LPA(J'I\.C. WASHINGTON, D.C. 20460 

Paper Reduction Act Notice: The public reporting burden for this collection of information is estimated to average 0.25 hours per response for registration activities and 0.25 hours per 

response for reregistration and special review activities, including time for reading the instructions and completing the necessary forms. Send comments regarding the burden estimate or any 

other aspect of this collection of information, including suggestions for reducing the burden to: Director, OPPE Information Management Division (2137) U.S. Environmental Protection 

AgencY,401 M Street, S. W., Washington, D.C. 20460. Do not send the form to this address. 

DATA MATRIX 

Date: 06/13/08 EPA Reg No'/File Symbol: Page 1 of 4 74530-to be assigned 

Applicant's/Registrant's Name & Address: Helm Agro US, Inc. 

8295 Tournement Drive, Suite 310 Product: Paraquat TC 

Memphis, TN 38125 

Ingredient: Paraquat dichloride 

Guideline Reference 

Numbers, Guideline Study Name MRID Number Submitter Status Note 

OPP/OPPTS 

61-1/ Product Identity and Composition 47389701 Helm Agro US, Inc. Own 830.1550 

61-2/ Beginning Materials and Manufacturing 47389701 Helm Agro US, Inc. Own 830.1600 & 830.1620 Process 

61-3/ Discussion of the Formation of Impurities 47389701 Helm Agro US, Inc. Own 830.1670 

62-1/ Preliminary Analysis 47389702, 47389703 Helm Agro US, Inc. Own 830.1700 

62-2/ Certified Limits N/A Helm Agro US, Inc. Own 830.1750 See submitted CSF 

62-3/ Enforcement Analytical Method 47389702 Helm Agro US, Inc. Own 

830.1800 44568901 Syngenta Crop Protection, Inc. 

63-2/ Color -Technical 47389704 Helm Agro US, Inc. Own 830.6302 

63-3/ Physical State -Technical 47389704 Helm Agro US, Inc. Own 830.6303 

63-4/ Odor-Technical 47389704 Helm Agro US, Inc. Own 830.6304 

63-5/ Melting Point-Technical 40479001 Syngenta Crop Protection, Inc. Own 83G:.72(~0 \. '" "" w 

E3:n~ , , 

t1ensity-Technical 47389704 Helm Agro US, Inc. .. Own 83\:).7380·. ' , 

EPA Form 857b~3'5 \9~~"F) Electronic and Paper versions available. Submit only Paper version. Agency Internal Use Copy 
Form Approved OMB No. 

,,"I«1$r~ .... UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 2070-0060 

f ftra ~~~ 401 M Street, S.W. 

'"'''''''tl''ll(1lt.''':# WASHINGTON, D.C. 20460 

Paper Reduction Act Notice: The public reporting burden for this collection of information is estimated to average 0.25 hours per response for registration activities and 0.25 hours per 

response for reregistration and special review activities, including time for reading the instructions and completing the necessary forms. Send comments regarding the burden estimate or 

any other aspect of this collection of information, including suggestions for reducing the burden to: Director, OPPE Information Management Division (2137) U.S. Environmental Protection 

AgencY,401 M Street, S. W., Washington, D.C. 20460. Do not send the form to this address. 

DATA MATRIX 

Date: 06/13/08 EPA Reg No'/File Symbol: 74530-to be assigned Page 2 of4 

Applicant's/Registrant's Name & Address: Helm Agro US, Inc. 

8295 Toumement Drive, Suite 310 Product: Paraquat TC 

Memphis, TN 38125 

Ingredient: Paraquat dichloride 

Guideline Reference 

Numbers, Guideline Study Name MRID Number Submitter Status Note 

OPPIOPPTS --------

63-81 Solubility-Technical 47389704 Helm Agro US, Inc. Own 830.7840 --

63-91 Vapor Pressure-Technical 40479001 Syngenta Crop Protection, Inc. Own 830.7950 --- 63-101 Dissociation Constant 40479001 Syngenta Crop Protection, Inc. Own 830.7370 

63-111 Octanol/Water Partition Coefficient-Technical 40479001 Syngenta Crop Protection, Inc. Own 830.7550 

63-12/ pH-', ecnmca, 47389704 Helm Agro US, Inc. Own 830.7000 

63-131 Stability-Technical 40479001 Helm Agro Inc. Own 830.6313 

63-14/ Oxidation/reduction: Chemical incompatibility 47389704 Helm Agro US, Inc. Own 830.6314 --

63.151 Flammability-Technical 47389704 Helm Agro US, Inc. Own 830.6315 

63-16/ Explodability-Technical 47389704 Helm Agro US, Inc. Own 830.6316 

63-171 Storage Stability -Technical 47389704 Helm Agro US, Inc. Own 830.6317 

~3-~?f "Corrosion Characteristics-Technical 47389704 Helm Agro US, Inc. Own .. - Y-l/A/:. ., 

, ·iJV visible light absorption 47389704 Helm Agro US, Own 830.7050 - - EPA Form 8570-35 (9-97) Electronic and Paper versions available. Submit only Paper version. Agency Internal Use Copy 
Form Approved OMB No. 2070-0060 

;tJ)Kt,,1'100 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY ( A'l 

~, 401 M Street, S.W. 

+I~( f'fM1\'i,-":.I WASHINGTON, D.C. 20460 

Paper Reduction Act Notice: The public reporting burden for this collection of information is estimated to average 0.25 hours per response for registration activities and 0.25 hours per response i 

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

of this collection of information, including "'"':'''' "., for reducing the burden to: Director, OPPE Information Management Division (2137) U.S. Environmental Protection Agency, 401 M Street, S. 

VV.,VVashington, D.C. 20460. [)o not send the form to this address. 

DATA MATRIX 

• 

-------

Date: 06/13/08 EPA Reg No.lFile Symbol: 74530-to be Page 3 of 4 assigned 

Applicant's/Registrant's Name & Address: Helm Agro US, Inc. Product: Paraquat TC 8295 Tournement Drive, Suite 310 

Memphis, TN 38125 ----------

Ingredient: Paraquat dichloride 

Guideline Reference 

Numbers, Guideline Study Name MRID Number Submitter Status Note 

OPPIOPPTS ......... _ ......... 

81-11 Acute Oral Toxicity - Rat 47091107 Source Dynamics LLC Pay 

870.1100 .. 

81-2/ Acute Dermal Toxicity-Rabbit 47091108 Source Dynamics LLC p, 

870.1200 I 

- Acute Inhalation Toxicity-Rat 47091109 Source Dynamics LLC Pay 

870.1300 ....... _ ... ------- -------

81-41 Primary Eye Irritation-Rabbit 46098805 Sinon Corp. Pay 

870.2400 , .. ---------

1-5/ Primary Dermal Irritation-Rabbit 47091110 Source Dynamics LLC Pay 

870.2500 - ... 

81-61 Dermal Sensitization in Guinea Pigs 47091111 Source Dynamics LLC Pay 

870.2600 

Generic Paraquat Data Syngenta Crop Protection Pay 

Generic Paraquat Data The Ortho Business Group Pay 

---------- Genf~.ric Paraquat Data Monsanto Company Pay 

Generic Paraquat Data Dow Elanco Pay 

Generic Paraquat Data Crystal Chemical Company Pay .. 

Generic Paraquat Data Makhteshim Agan of North Pay 

America Inc . ------- ... -

Generic Paraquat Data Spray Drift Task Force Pay 

Generic Paraquat Data EDM Industries Inc. Pay 

Generic Paraquat Data Outdoor Residential Exposure Pay 

Task Force LLC 

Generic Paraquat Data ........ ------- Agricultural Reentry Task Force PayGeneric Paraquat Data FIFRA Endangered Species Task Pay 

Force 

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

.§','I."DII1"~ UNITED STATES ENVIRONMENTAL PROTECTION AGENCY No. 2070-0060 . ft" 

t~l 401 M Street, S.W. 

"""<~ WASHINGTON, D.C. 20460 

Paper Reduction Act Notice: The public reporting burden for this collection of information is estimated to average 0.25 hours per response for registration activities and 0.25 hours per response for 

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

collection of information, including suggestions for reducing the burden to: Director, OPPE Information Management Division (2137) U.S. Environmental Protection Agency, 401 M Street, S. W., 

Washington, D.C. 20460. Do not send the form to this address. 

DATA MATRIX 

Date: 06/13/08 EPA Reg No.lFile Symbol: 74530-to be Page 4 of 4 I 

assigned , 

Applicant'S/Registrant's Name & Address: Helm Agro US, Inc. 

8295 Tournement Drive, Suite 310 Product: Paraquat TC 

Memphis, TN 38125 ---------

Ingredient: Paraquat dichloride 

Guideline 

Reference Guideline Study Name MRID Number Submitter Status Note Numbers, 

OPP/OPPTS ........ -

Generic Paraquat Data Residential Exposure Joint Pay 

Venture ---------

Generic Paraquat Data Agricultural Handlers Exposure Pay 

Task Force 

(~eneric Paraquat Data Griffin Corporation Pay 

Generic Paraquat Data Source Dynamics Pay 

Generic Paraquat Data Sinon USA Inc. Pay 

GenericJ=>araquat Data Celsius Property, BV Pay 

Generic Paraquat Data Generic Endangered Species Pay 

Task Force 

Generic Paraquat Data Residential Exposure Joint Pay 

Venture -------

Generic Paraquat Data Agricultural Handlers Exposure Pay 

Task Force 

-----

Signature: 

.~+ [rt:;r:-=: Name and Title: Bert Volger, Ph.D. 

Consultant for HELM AGRO US Inc. Date: 6/13/2008 

. .. p y t-'ap 
/,o-ft.t1), 

(~.) 

1?--1l~r,,"'" 

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 

401 M Street, S.W. 

WASHINGTON, D.C. 20460 

Form Approved 

Paper Reduction Act Notice: The public reporting burden for this collection of information is estimated to average 0.25 hours per response for registration activities and 0.25 hours per 

response for reregistration and special review activities, including time for reading the instructions and completing the necessary forms. Send comments regarding the burden estimate or any 

other aspect of this collection of information, including suggestions for reducing the burden to: Director, OPPE Information Management Division (2137) U.S. Environmental Protection 

401 M Street. S. W .. Washinoton. D.C. 20460. Do not send the form to this address. 

Date: 06/13/08 

Applicant's/Registrant's Name & Address: Helm Agro US, Inc. 

8295 Tournement Drive, Suite 310 

Memphis, TN 38125 

Ingredient: Paraquat dichloride 

Guideline Reference 

Numbers, 

OPP/OPPTS 

Guideline Study Name 

DATA MATRIX 

MRID NUmber 

EPA Reg 

74530-to 

Product: Paraquat TC 

Submitter 

Helm Agro US, Inc. 

Helm Agro nco 

Helm Agro US, Inc. 

Helm Agro US, Inc. 

,C:I&>r'trf'lnif' and Paper versions available. Submit Paper version. 

t:>(J 

o 

~ " 

• "" . , 

.. ~ ~ 

~~ 

Page 1 of 4 

Status Note 

Own 

Own 

Own 

Own 

Own See 

Own 

Own 

Own 

Own 

Own 

Public Use Copy 
Form Approved~OMB No~ 

'""''> UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 2070·0060 

"111.\ 

~~) 401 M Street, S.W. 

WASHINGTON, D.C. 20460 

Paper Reduction Act Notice: The public reporting burden for this collection of information is estimated to average 0.25 hours per response for registration activities and 0.25 hours per 

response for reregistration and special review activities, including time for reading the instructions and completing the necessary forms. Send comments regarding the burden estimate or 

any other aspect of this collection of information, including suggestions for reducing the burden to: Director, OPPE Information Management Division (2137) U.S. Environmental Protection 

Agency, 401 M Street, S. W., Washington, D.C. 20460. Do not send the form to this address. 

DATA MATRIX 

Date: 06/13/08 EPA Reg No./File Symbol: 74530-to be assigned Page 2 of4 ---------------

Applicant's/Registrant's Name & Address: Helm Agro US, Inc. 

8295 Tournement Drive, Suite 310 Product: Paraquat TC 

Memphis, TN 38125 

Ingredient: Paraquat dichloride 

Guideline Reference 

Numbers, Guideline Study Name MRID Number Submitter Status Note 

OPPIOPPTS 

Helm Agro US, Inc. Own 

Syngenta Crop Protection, Inc. Own 

Syngenta Crop Protection, Inc. Own 

Syngenta Crop Protection, Inc. Own 

Helm Agro US, Inc. Own ---------------

Helm Agro US, Inc. Own 

Helm Agro US, Inc. Own 

Helm Agro US, Inc. Own 

Helm Agro US, Inc. Own 

Helm Agro US, Inc. Own 

Helm Agro US, Inc. Own 

Helm Agro US, Inc. Own 

-_ .. - -- - -. - .-

--C) 
r---------------------------------------------------------------------------------------------------------~F~0-rm~A-o-or-o-ve-d-O--M~B-N-o-.-2-0-70---0-06-0--1 ~ ----

/'fllJT~~, 

... -\ 1 , 

'# -< 

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 

401 M Street, S.W. 

WASHINGTON, D.C. 20460 

Paper Reduction Act Notice: The public reporting burden for this collection of information is estimated to average 0.25 hours per response for registration activities and 0.25 hours per response 

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

of this collection of information, including suggestions for reducing the burden to: Director, OPPE Information Management Division (2137) U.S. Environmental Protection Agency, 401 M Street, S. 

WashinQton. D.C. 20460. Do not send the form to this address. 

Date: 06/13/08 

Applicant's/Registrant's Name & Address: Helm Agro US, Inc. 

Ingredient: Paraquat dichloride 

8295 Tournement Drive, Suite 310 

Memphis, TN 38125 

Guideline Study Name 

DATA MATRIX 

MRID Number 

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

74530-to be 

Product: Paraquat TC 

Submitter Status 

Source Dynamics LLC 

Source Dynamics LLC 

Pay 

FIFRA Endangered Species Task I Pay 

Force 

Page 3 of4 

Note 

Public Use Copy 
/1StItT~~, 

t~l \~ .. (~(,:# 

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 

401 M Street, S.W. 

WASHINGTON, D.C. 20460 

Form Approved OMB 

No. 2070-0060 

Paper Reduction Act Notice: The public reporting burden for this collection of information is estimated to average 0.25 hours per response for registration activities and 0.25 hours per response for 

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

collection of information, including suggestions for reducing the burden to: Director, OPPE Information Management Division (2137) U.S. Environmental Protection Agency, 401 M Street, S. W., 

Washinaton. D,C, 20460, Do not send the form to this address. 

Date: 06/13/08 

Applicant's/Registrant's Name & Address: Helm Agro US, Inc. 

Ingredient: 

Guideline 

Reference 

Numbers, 

OPP/OPPTS 

Signature: 

Paraquat dichloride 

Guideline Study Name 

~f 

8295 Toumement Drive, Suite 310 

Memphis, TN 38125 

TH 

DATA MATRIX 

MRID Number 

EPA Form 8570-35 Electronic and Paper versions available. Submit only Paper version. 

Page 4 of 4 

Product: Paraquat TC 

Submitter Status Note 

Residential Exposure Joint I Pay 

Venture 

Agricultural Handlers Exposure I Pay 

Task Force 

Pay 

Pay 

Pay 

Name and Title: Bert Ph.D. 

Consultant for AGRO US Inc. I Date: 6/13/2008 

Public Use 

-

~ 

-
Paraquat TC 

(Technical Concentrate) 

For Formulation of Paraquat Herbicide Products Only 

ACTIVE INGREDIENT 

Paraquat dichloride (1,1' -demethyl, 4,4' -bipyridinium dichloride) 

INERT INGREDIENTS 

Contains 3 pounds paraquat cation per gallon. 

Contains emetic. 

EPA Reg. No. 74530-xx 

EPA Establishment No. 

KEEP OUT OF REACH OF CHILDREN 

DANGERJPELIGRO 

POISON 

43.8% 

56.2% 

100.0% 

Si usted no entiende la etiqueta, busque a alguien para que se la explique a usted en detalle. (If you do not 

understand the label, find someone to explain it to you in detail). 

• NEVER PUT INTO FOOD, DRINK OR OTHER CONTAINERS 

• IF SWALLOWED, TAKE IMMEDIATE ACTION AS PRESCRIBED IN FIRST AID 

STATEMENT. SYMPTOMS ARE PROLONGED AND PAINFUL. 

Net Contents: 

HELM AGRO Inc. 

8295 Tournament Drive 

Memphis, TN, 38125 

info@helmagro.com 

DRAFT submitted to EPA: 06-05;-201)8 

1 
FIRST AID 

• If swallowed • Speed is essential. Immediate attention is required. If available, 

Give an adsorbent such as activated charcoal, bentonite or Fuller's 

Earth. 

• Call a poison control center or doctor immediately for treatment. 

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

If in eyes • Hold eye open and rinse slowly and gently with water for IS to 20 

mins. Remove contact lenses, if present, after the first S minutes, then 

continue rinsing eye. 

• Call a poison control center or doctor for treatment advice. 

If on skin or clothing • Take off contaminated clothing. 

• Rinse skin immediately with plenty of water for IS to 20 minutes. 

• Call poison control center or doctor for treatment advice. 

If inhaled • Move person to fresh air. 

• If person is not breathing, call 911 or an ambulance. 

• Call a poison control center or doctor for further treatment advice. 

NOTE TO PHYSICIAN 

Administer either activated charcoal (1 OOg for adults or 2g1kg body weight in children) or Fuller's 

Earth (1S% solution: 1 liter for adults or ISmglkg body weight in children. 

Note: The use of gastric lavage without administration of an adsorbent has not shown any clinical 

benefit. Do not use supplemental oxygen. Eye splashes from concentrated material should be treated by 

an eye specialist after initial treatment. With the possibility of late onset corneal ulceration, it is advised 

that patients with paraquat eye injuries are reviewed by an eye specialist the day after first presentation. 

Use treatment that is appropriate for chemical bums. Intact skin is an effective barrier to paraquat, 

however contact with irritated or cut skin or repeated contact with intact skin may result in poisoning . 

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

for treatment. 

HOTLINE 

For medical emergencies involving this product, call CHEMTREC 1-800-424-9300. 

emergency: ;p II, leak, fire, exposure, or accident, call CHEMTREC 1-800-424-9300 

PRECAUTIONARY STATEMENTS 

HAZARDS TO HUMANS AND DOMESTIC ANIMALS 

DANGERJPELIGRO 

POISON 

For chemical 

May be fatal if swallowed. Fatal if inhaled. Do not breathe spray mist. Do not inhale contaminated dust. 

Causes substantial but temporary eye injury. Do not get in eyes or on clothing. A void contact with skin. 

Harmful if absorbed through skin. Wear (goggles, face shield, or safety glasses). , 

IMPORTANT: The effect of swallowing paraquat concentrate is far more severe thstn tba~ which usually 

results from skin contact or inhalation of contaminated plant dust. This product shoJJ1.d 1)Q~ cause} inj~rY if 

used according to label instructions. J • 

When handling or mixing concentrate or when exposure to concentrate is possible, ~e1r: J 

) I 

2 
• Dust/mist filtering NIOSH approved respirator with any R,P or HE filter 

• Protective clothing (disposable suit/coveralls or long-sleeve shirt and long pants) 

• Full face shield 

• Chemical-resistant gloves (Category A) 

• Chemical resistant apron and shoes plus socks 

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

REMOVE contaminated clothing and wash separately from other laundry before reuse. 

ENVIRONMENTAL HAZARDS 

This product is toxic to wildlife. Do not discharge effluent containing this product into lakes, streams, 

ponds, estuaries, oceans, or public waters unless this product is specifically identified and addressed in a 

National Pollutant Discharge Elimination System (NPDES) permit. Do not discharge effluent containing 

this product to sewer systems without previously notifying the sewage treatment plant authority. For 

guidance, contact your State Water Board or Regional Office of EPA. 

PHYSICAL AND CHEMICAL HAZARD 

This product reacts with aluminum to produce hydrogen gas which may form a highly combustible gas 

mixture. Do not mix or store in containers, tanks, or such systems made of aluminum or having aluminum 

fittings. 

EQUIPMENT/CONT AINER 

Flush all equipment with water after use each day. Paraquat is corrosive to aluminum. Aluminum 

equipment and aluminum structures that are exposed to solution or spillage should be flushed thoroughly 

with water immediately after use. 

SPILLAGE DURING TRANSPORT 

Emergency Action: Notify police and fire departments immediately. For any spill, leak, fire, or 

exposure in the United States, call CHEMTREC 1-800-424-9300. 

KEEP PUBLIC AND ANIMALS away from area. MARK ROADS AND WARN OTHER ROAD 

USERS. WEAR face shield, waterproof gloves, waterproof footwear, and long-sleeve shirt and long pants 

during decontamination operations. 

Clean up spills as soon as possible. Cover spill with generous amount of clay or loam soil to absorb 

liquid, using a stiff broom to ensure intimate contact. Sweep onto shovel and transfer to plastic bag or 

other disposable container. Repeat operations until contaminated surfaces are dry. Finally, hose spill site 

with water, iffeasible. 

DIRECTIONS FOR USE 

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

3 
READ ENTIRE LABEL. USE STRICTLY IN ACCORDANCE WITH PRECAUTIONARY 

STATEMENTS AND DIRECTIONS, AND WITH APPLICABLE STATE AND FEDERAL 

REGULATIONS. 

Only for formulation into a herbicide for the following uses: 

TERRESTRIAL FOOD CROP 

Acerola (West Indies cherry), apricot, asparagus, avocado, banana, blackberry, blueberry, boysenberry, 

broccoli, cabbage, Chinese, carrot (including tops), cauliflower, cherry, cocoa, coffee, collards, cucumber, 

eggplant, fig, filbert (hazelnut), garlic, groundcherry (strawberry tomato/tomatillo), guava, hops, 

kiwifruit, lettuce, loquat, macadamia nut (bushnut), manioc (cassava), melons, melons, cantaloupe, 

melons, musk, melons, water, mint, nectarine, olive, onion, papaya, passion fruit, peach, pear, pecan, 

pepino (melonpear), pepper, pepper (chili type), pineapple, pistachio, plum, potato, 

whitlIrish, prune, pumpkin, raspberry (black, red), rhubarb, small fruits, squash (all or unspecified), 

strawberry, sugar beet, taro, walnut (English/black), yam, yautia. 

TERRESTRIAL FOOD+FEED CROP 

Almond, apple, barley, beans, asparagus, beans, dried-type, beans, mung; beans-succulent (lima); beanssucculent (snap), citrus fruits, corn (unspecified), corn, field, corn, pop, corn, sweet, cotton (unspecified), 

garbanzos (including chickpeas), grapes, guar, hops, legume vegetables, mint, oats, orchards 

(unspecified), peanuts, peanuts (unspecified), soybeans, edible, spearmint, sugar beet, sugar crops, 

sugarcane, sunflower, tomato, turnip, vegetables (unspecified), wheat. 

TERRESTRIAL FEED CROP 

Alfalfa, barley, beans, clover, crown v etch, legume vegetables, lespedeza, lupine, pastures, sainfoin, 

timothy, trefoil, tyfon, vetch, wheat. 

TERRESTRIAL NON-FOOD CROP 

Agricultural fallow/idleland, airports/landing fields, commercial/industrial lawns, 

commercial/institutional/industrial, premises/equipment (outdoor), fencecrows/hedgerows, grasses grown 

for seed, industrial areas (outdoor), jojoba, nonagricultural outdoor buildings/structures, nonagricultural 

uncultivated areas/soils, ornamental and/or shade trees, peach (non-bearing, seed beds), recreation area 

lawns, tomato (post-harvest)/ wood protection treatment to forest products (seasoned). 

FORESTRY 

Forest planting (reforestation programs), pine (forestlshelterbelt), shelterbelt plantings. 

TERRESTRIAL NON-FOOD 

Ornamental and/or shade trees, ornamental herbaceous plants, ornamental woody shrubs and vines, noncrop areas such as public airports, electric transformer stations and around commercial bUildings. 

OTHERS 

Uses for which USEPA has accepted the required data and/or citations of data that the formulator has 

submitted in support of registration; and uses for experimental purposes that are in compliance with 

USEPA requirements. 

STORAGE AND DISPOSAL 

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

PESTICIDE STORAGE; Store at temperatures above 32· F. Do not contaminate food, foodstuffs, or 

4 
drinking water. Do not store next to feed or food, or transport in or on vehicles containing foodstuffs or 

feeds. For help with any spill, leak, fire or exposure involving this material, call CHEMTREC 1-800-424-

9300. 

PESTICIDE DISPOSAL; Pesticide wastes are acutely hazardous. Improper disposal of excess pesticide 

or rinsate is a violation of Federal law. If these wastes cannot be disposed of by use according to label 

instructions, contact your State Pesticide or Environmental Control Agency, or the Hazardous Waste 

representative at the nearest EPA Regional Office for guidance. 

CONTAINER DISPOSAL: Triple rinse (or equivalent). Offer for recycling or recondition, or puncture 

and dispose of in a sanitary landfill, or dispose of by other procedures allowed by State and local 

authorities. 

CONDITIONS OF SALE 

AND LIMITATION OF WARRANTY AND LIABILITY 

NOTICE: Read the entire Directions for Use and Conditions of Sale and Limitation of Warranty and I 

Liability before buying or using this product. lfthe terms are not acceptable, return the product at once, . 

I 

unopened, and the purchase price will be refunded. . 

The Directions for Use of this product should be followed carefully. It is impossible to eliminate all risks 

inherently associated with the use of this product. Crop injury, ineffectiveness or other unintended 

consequences may result because of such factors as manner of use or application, weather or crop 

conditions, presence of other materials or other influencing factors in the use of the product, which are 

beyond the control of Helm Agro US, Inc. or Seller. All such risks shall be assumed by Buyer and User, 

and Buyer and User agree to hold Helm and Seller harmless for any claims relating to such factors. 

Helm warrants that this product conforms to the chemical description on the label and is reasonably fit for 

the purposes stated in the Directions for Use, subject to the inherent risks referred to above, when used in 

accordance with directions under normal use conditions. This warranty does not extend to the use of this 

product contrary to label instructions, or under abnormal conditions or under conditions not reasonably 

foreseeable to or beyond the control of Seller or Helm, and Buyer and User assume the risk of any such 

use. HELM MAKES NO WARRANTIES OF MERCHANT ABILITY OR OF FITNESS FOR A 

PARTICULAR PURPOSE NOR ANY OTHER EXPRESS OR IMPLIED WARRANTY EXCEPT 

AS STATED ABOVE. 

In no event shall Helm or Seller be liable for any incidental, consequential or special damages resulting 

from the use or handling of this product. THE EXCLUSIVE REMEDY OF THE USER OR BUYER, 

AND THE EXCLUSIVE LIABILITY OF HELM AND SELLER FOR ANY AND ALL CLAIMS, 

LOSSES, INJURlES OR DAMAGES (INCLUDING CLAIMS BASED ON BREACH OF 

WARRANTY, CONTRACT, NEGLIGENCE, TORT, STRlCT LIABILITY OR OTHERWISE) 

RESULTING FROM THE USE OR HANDLING OF THIS PRODUCT, SHALL BE THE 

RETURN OF THE PURCHASE PRlCE OF THE PRODUCT OR, AT THE ELECTION OF 

HELM OR SELLER, THE REPLACEMENT OF THE PRODUCT. 

Helm and Seller offer this product, and Buyer and User accept it, subject to the foregoing conditions of 

sale and limitations of warranty and of liability, which may not be modified except by written agreement 

signed by a duly authorized representative of Helm. 

5 

I 
Hope: 

.. Marshall Wixson" 

<mwixson@helmagro.com> 

06/05/200802:19 PM 

Thanks for your explanation. 

within the required deadline. 

regulatory consultant and has 

be. Thanks for you time. 

Regards, 

Dr. Marshall B. Wixson 

Manager Product Development 

Helm Agro US, Inc. 

8295 Tournament Dr., Suite 310 

Memphis, TN 38125 

9011312-1525 

901/312 1535 (Fax) 

901/216-7530 (Cell) 

--- -Original Message--

To Hope Johnson/OC/USEPNUS@EPA 

ec <bertvolger@eomeast.net>. "'Dr. Renate Bastl-Borrmann'" 

<r.bastl-borrmann@helmag.eom> 

bee 

Subject RE: Pending File Symbol # 74530-GT 

We will take this under advisement and respond 

Dr. Bert Volger of Ceres Inc. acts as our 

full authority to speak on our behalf if need 

From: Johnson.Hope@epamail.epa.gov [mailto:Johnson.Hope@epamail.epa.govl 

Sent: 2008-06-05 13:04 

To: mwixson@helmagro.com 

Cc: Tompkins.Jim@epamail.epa.gov 

Subject: pending File Symbol # 74530-GT 

Importance: High 

Mr. Wixson, 

In your application for registration for Paraquat TC, you have stated it 

is a me-too application with Syngenta Crop Protection product 100-1067. 

In addition you are citing the acute toxicity 6-pack of Syngenta's 

product as well. However, the pending label submitted is missing the 

required text from the Syngenta label accepted on May 19, 2005: 

"This product is to be used only for formulation into herbicides 

with an acute oral toxicity to dogs (lethal effects) that exceeds 128 mg 

paraquat ion/kg body weight (602 mg of formulation/kg body weight 

for a 240 g paraquat ion/L formulation) and that contain an effective 

emetic that meets FAO specifications, a dye, and an olfactory alerting 

agent that have been cleared under FIFRA for use in pesticides 

registered for food use." 

If you cite Reg.100-1067 as your me-too product and cite acute toxicity 

data for that product, this language must appear on your label. In 

addition, if approved; Paraquat TC would not be able to be used for 

formulation into an herbicide with an acute oral toxicity in dogs that 

is less than 128 mg paraquat ion/kg body weight, and any end-use product 

using Paraquat TC as the technical source would have to demonstrate that 

this requirement is met. 

We assume that it is not your intention to add this language to the 
label, and therefore you must withdraw this application, or within 10 

business days (June 18, 2008) submit revised documentation (data matrix, 

certification with respect to citation of data, EPA form 8570-1, and a 

letter explaining the revisions) citing a new me-too product. 

Please contact me if you have any questions, and respond back with your 

intentions as soon as possible. 

Hope A. Johnson 

U.S. Environmental Protection Agency 

Office of Pesticide Programs 

Registration Division 

Herbicide Branch 

phone: 703-305-5410 

Mail Code 7505P 
Mr. Wixson, 

Hope 

Johnson/DC/USEPAIUS 

06/05/200802:03 PM 

/ 

To mwixson@helmagro.com 

cc Jim Tompkins/DC/USEPAlUS@EPA 

bcc 

Subject Pending File Symbol # 74530-GT 

In your application for registration for Paraquat TC, you have stated it is a me-too application with 

Syngenta Crop Protection product 100-1067. In addition you are citing the acute toxicity 6-pack of 

Syngenta's product as well. However, the pending label submitted is missing the required text from the 

Syngenta label accepted on May 19, 2005: 

"This product is to be used only for formulation into herbicides with an acute oral toxicity to dogs 

(lethal effects) that exceeds 128 mg paraquat ionlkg body weight (602 mg of formulation/kg body 

weight for a 240 g paraquat ioniL formulation) and that contain an effective emetic that meets FAO 

specifications, a dye, and an olfactory alerting agent that have been cleared under FIFRA for use in 

pesticides registered for food use." 

If you cite Reg.1 00-1 067 as your me-too product and cite acute toxicity data for that produc~ this language 

must appear on your label. In addition, if approved, Paraquat TC would not be able to be used for 

formulation into an herbicide with an acute oral toxicity in dogs that is less than 128 mg paraquat ion/kg 

body weight, and any end-use product using Paraquat TC as the technical source would have to 

demonstrate that this requirement is met. 

We assume that it is not your intention to add this language to the labe~ and therefore you must withdraw 

this application, or within 10 business days (June 18, 2008) submit revised documentation (data matrix, 

certification with respect to citation of data, EPA form 8570-1, and a letter explaining the revisions) citing a 

new me-too product. 

Please contact me if you have any questions, and respond back with your intentions as soon as possible. 

Hope A. Johnson 

U.S. Environmental Protection Agency 

Office of Pesticide Programs 

Registration Division 

Herbicide Branch 

Phone: 703-305-5410 

Mail Code 7505P 

,ril 
Relay Report 

Your 

docliment: Pending File Symbol # 74530-GT 

addressed to: mwixson@helmagro.com 

has the 250 OK. sent 48482A76_19841_103088_1 E881 F4435B 

following 

delivery 

status: 

What should you do? 

This message is an informational Delivery Status Notification and does not require any further action. 

• Your message was routed to a server which does not accept responsibility for generating Delivery Status 

Notifications upon successful delivery. You may assume that the message was successfully delivered if no 

failure message is received. Do not expect a delivery confirmation notice. 

EPAHUB111USEPAlUS, DCCMMAIL 11IDC/USEPAIUS 

To: mwixson@helmagro.com 

cc: Jim Tompkins/DC/USEPAlUS@EPA 

Date: 02:03:34 PM AST Today 

Subject: Pending File Symbol # 74530-GT 
Rita: 

.. Marshall Wixson" 

<mwixson@helmagro.com 

> 

05/12/2008 10:34 AM 

To Rita Kumar/DC/USEPA/US@EPA 

cc <bertvolger@comcast.net> 

bec 

Subject RE: Deficiencies in your application for Paraquat TC, 

File Symbol 74530-GT 

Please see attached data citation form to correct the deficiencies your 

listed. 

Regards, 

Dr. Marshall B. Wixson 

Manager Product Development 

Helm Agro US, Inc. 

8295 Tournament Dr., Suite 310 

Memphis, TN 38125 

901/312 1525 

901/312-1535 (Fax) 

901/216-7530 (Cell) 

-- --Original Message-----

From: Kumar.Rita@epamail.epa.gov [mailto:Kumar.Rita@epamail.epa.gov] 

Sent: 2008-05-09 09:28 

To: mwixson@helmagro.com 

Subject: Deficiencies in your application for Paraquat TC, File Symbol 

74530-GT 

Importance: High 

Dear Mr. Wixson: Please see attached letter and screening checklist 

regarding the deficiencies in your application referenced above. A 

response to correct these deficiencies must be received from you as soon 

as possible. 

(See attached file: scan.pdf) 

Sincerely, 

Rita Kumar 

EPA citation of data form. pdf 
Form 8Qproved OMS No. 2070"()060 

,~~ .. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY (=l 4.,-;::7 401 M Street, S.W. 

WASHINGTON, D.C. 20460 

PapelWork Reduction Act Notice: The public reporting burden for this collection of information is estimated to average 1.25 hours per response for registration 

and 0.25 hours per response for reregistration and special review activities, including time for reading the instructions and completing the necessary fonms. Send 

comments regarding burden estimate or any other aspect ofthis collection of information, including suggestions for reducing the burden to: Director, OPPE 

Information Management Division (2137), U.S. Environmental Protection Agency, 401 M Street, S.W., Washington, DC 20460. 

Do not send the completed form to this address. 

Certification with Respect to Citation of Data 

Applicant'sJRegistrant's Name, Address, and Telephone Number EPA Registration Number/File Symbol 

Helm Agro US. Inc. 8295 Toumament Drive, Suite 310 Memphis. TN 38125 74530 -x 

Active Inaredient(sl and/or representative test comoound(sl Date 

Paraquat dichloride April 30, 2008 

General Use Pattem(s) (list all those claimed for this product using 40 CFR Part 158) Product Name 

Terrestlial Non Food, and Terrestrial Nonfood use sites ParaquatTC 

NOTE: 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 

submit this form. You must submit the Formulator's Exemption Statement (EPA Fonm 8570-27). 

0 I am responding to a Data-Call-In Notica, and have included with this form a list of companies sent offers of compensation (the Data Matrix form should 

be used for this purpose). 

SECTION I: METHOD OF DATA SUPPORT (Check one method only) 

0 I am using the cite-all method of support, and have included with this fonm [2] I am using the selective method of support (or cite-all option 

a list of companies sent offers of compensation (the Data Matrix fonm under the selective method). and have included with this form a 

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

used). 

SECTION II: GENERAL OFFERTO PAY 

[Required if using the cite-all method or when using the cite-all option under the .selective method to satisfy one or more data requirements] 

[2] I hereby offer and agree to pay compensation. to other persons, with regard to the approval of this application, to the extent required by FIFRA. 

SECTION III: CERTIFICATION 

I certify that this application for registration, this fonm for reregistration, or this Data-Call-In response is supported by all data submitted or cited in the 

application for registration, the form for reregistration, or the Data-Cal/-In response. In addition, if the clte-all option or clte-all option under the selective method is 

indicated in Section I, this application is supported by all data in the Agency's files that (1) concem the properties or effecls of this product or an identical or 

substantially slmHar product, or one or more of the ingredients in this product; and (2) is a type of data that would be required to be submitted under the data 

requirements in effecl on the date of approval of this application if the application sought the initial registration of a product of identical or similar composition and 

uses. 

I certify that for each exclusive use study cited in support of this registration or reregistration, that I am the Original data submitter or that I have obtained 

the written permission of the original data submitter to cite that study. 

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

submitter; (b) I have obtained the permission of the original data submltterto use the study in support of this application; (c) all periods of eligibility for 

compensation have expired for the study; (d) the study is in the public literature; or (e) I have notified in writing the company that submitted the study and have 

offered (I) to pay compensation to the extent reqUired by sections 3(c)(1)(F) and/or 3(c)(2)(8) of FIFRA; and (ii) to commence negotiations to determine the 

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

I certify that in all instances where an offer of compensation is required. copies of all offers to pay compensation and evidence of their delivery in 

accordance with sections 3(c)(1)(F) and/or 3(c)(2)(8) of FIFRA are available and will be submitted to the Agency upon request. Should I fail to produce such 

evidence to the Agency upon request, I understand that the Agency may initiate action to deny, cancel or suspend the registration of my product in confonmity with 

FIFRA. 

I certify that the statements I have made on this fonm and all attachments to It are true, accurate, and complete. I acknowledge that any 

knowingly false or misleading statement may be punishable by fine or imprisonment or both under applicable law. 

Signature ~ Date Typed or Printed Name and Title 

May 9. 2008 Marshall Wixson, Manager Product Development 

EPA Form 8570-34 (9-97) Eleclromc and Paper versIons avaIlable. SubmIt only Paper version .. 
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 

WASHINGTON, D.C. 20460 

OFFlCEOF 

PREVENTION, PESTICIDES 

. AND TOXIC SUBSTANCES 

,wI (f1AAsh wi{ t,tJ{X~t7h Date: J 1~/2008 

y.uVh Dptn (1$.,1 IYl L ' 

Zgq~ 704LM..411A ~ VI. Ju/Ie '5/l:J 

d1eJ1A:of"i~L TN 33 L££' I 

Your email: mlAJ1XStnt @2 he1t1A.a!JYI9 I Cant 

Plurrte;' qO) - 31;A - Ip;ip 

Subject: File SymbollRegistration No. 7'f £30 - a T 

Dear Mr./Ms: IAJIx. s. 6/4 

The above referenced PRIA application was screened by the Registration Division's 

Completeness Check Team and determined to be deficient. Please see the enclosed copy of our 

screening checklist for the specific deficiency. 

You must submit corrections within 7 days of the date of this notice, to the Completeness 

Check Team. Include the following Decision Number on your cover letter with the words 

"Resubmission For RD's Completeness Check Team" to identify your package. 

Decision #D 3 q 3 () 6 ( 

RESUBMISSION For RD's Completeness Check Team 

You may send in corrections via fax or e-mail, provided that the material is not 

Confidential BusinessInformation. Our fax number is (703) 347-8932. Our e-mail address is: 

OPP _RD _Completenesss_Screening@epa.gov. 

If you cannot meet this time frame, please contact us for further discusSions on this 

matter. My telephone number is (703) '31}ft- U q 1 . 

Attachment 

Sincerely, 

Kit;; Ku~ Completeness Check Team 

Registration Division (7505P) 

U.S. EPA, One Potomac Yard 

2777 S. Crystal Drive 

Arlington, VA 22202 
(EPAlOPPUse Only) 

4/9/08 

·' 

~~~:'~:;;~C~::~S\~-atur-e!::..~-~·...:j'!"l?'<--f(,-'-{'::"~!.k:' :.:....;;-4-'",. ---'---D-a~te-' }£-. ~q.,t1f FeePaid: Yes~ 

[)ivi~ibil:m[tnagerii~ntc.Qn41Qte<i~()tl:#~~esN6~ .. '..:...'. ~~Yes~~~_Date "","' ~~-,---_---'-_ 

EPA Reg. Number: 'EPA-Receipt· Date: 

1 Application Fortn (EPA Fenn 857,0'-1) sigrted & complete including package 

type 

..,.,U:UJ.Jlu".uo,ta.o. ~'PH)ell1lell! ()fIrorm~laall bQ)(:.es.complet~d, fonp..signed.~and V 

2 

3 

4 

a)Alliher.t§,~:x.c~ptf.r~gr@(;e$;appt9ve(Lf9r foedancLnoll food .I-....,:~~----'-.'--"--

.prQP()Ef~dtisei'(~¢&.F69br6te:A"). '. . '. '.. . .... . 

CertificatiQnw.itliR~$p~¢ft()(titaijon. o(:Qata(EPA 

completed arid signed (N/A iffOO%..tepack) 

Certi,fiqate Gll1dd~ta1llatrix consistent 

·<IfaPl)licalJ.tisr~tYiD:g()J1Aata.th~t~areC91llpen~~ble, is the offer 

tqp'ay s4!t~ni,¢nt incirl.4~d,~(~eeFO()t:4()te:B) . 

yes 

Formlil~tor~s<Exempiipp~t;it~menf.@p:A;Form 8570.;27) completed and 

signed (N/Aif sourceisunregist¢red or. appl.icGlllt owns the technical) 

Data Matrix (EP AFo:rm 8570-3 . . . . . if . . 

no 

5 Ii:) .·P.vl.vvLl 

l:J} <=ite:}i.l1 {F ee~cat~g;ory,e)(:perts.u~e) 

6 labels on CD are 

7 is the '" ""nil''''' 86-5 

8 Notice: . to ilicluded 

1 

'v 
9 1,lfapPUcabl~ for c()nye1)tionfll~pplicat!ops, redJIced,r1sk ratiopale 

, ,1iequired,Uata;llnd/ordata,:waiyers~See'l1'ootnote' C. , - ,,', ,',.'., ,-,' "'", " .... ' 

a) List study (orsfui:lle~;~9Hnct1l4¢a With.:applicatioll 

10 

Comments: '"$'e. ~ C3~tX+-;~1A. ~' h !l()r ~tYfL9/jf~JrtT tJJ7'ft: 

1Mv ~~ ~X.J)~ ~l)$ ~ KtitJ/ve t,'I-ovI-/0h..9 

/:fl& r;NJM6&-~j~+ .~. h)jr'c-t''tj, flj,£ ~ 

tJ~ ~ ·w.u..trJ,ez,# ~ ~tltLf-; £It bt<x / 
1 

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 

WASHINGTON, D.C. 20460 

May 6,2008 

OPP Decision Number: D-393061 

EPA File Symbol or Registration Number: 74530-GT 

Product Name: PARAQUAT TC 

EP A Receipt Date: 02-May-2008 

EPA Company Number: 74530 

Company Name: HELM AGRO US, INC. 

MR. VOLKER HEIDE 

HELM AGRO US, INC. 

8295 TOURNAMENT DRIVE, SUITE 310 

MEMPHIS, TN 38125-

OFFrCEOF 

PREVENTION, PEST[CIDES AND 

TOXIC SUBSTANCES 

SUBJECT: Receipt of Registration Application Subject to Registration Service Fee 

Dear Registrant: 

The Office of Pesticide Programs has received your application and certification of 

payment. 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: R31 0 

NEW PRODUCT;NON-F AST TRACK (INCLUDES REVIEWS OF PRODUCT 

CHEMISTRY;ACUTE TOXICITY;PUBLIC HEALTH PEST EFFICACY); 

No additional payment is due at this time. 

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

Ombudsman at (703) 305-6249. 

Sincerely, 

1 JVuZQLJL [)~ Front End Processing Staff 

Information Technology & Resources Management Division 
IFee for Servicel {828659 -

This package includes the following 

(!) New Registration 

Amendment 

. Studies? i Fee Waiver? 

[' volpay % Reduction: _ 

for Division 

AD 

BPPD 

(~ RD 

Risk Mgr. [JJ 

Receipt No. s-I 828659 ~========: 

EPA File Symbol/Reg. No. 1 74530-GT 

Pin -Pun c h D ate: 1L--_5_/2_/_2o_o_8-----1 

This item is NOT subject to FFS action. 

Requested: I ~~J D 

Granted: I {, 310 

Amount Due: $ +,3100 

Remarks: 

Parent/Child Decisions: 

Uncleared Inert in Product 

Date: 1i1Jdox 

FEE FOR SERVICE 
004222 

U.S. Environmental May 1, 2008 Check No 4222 

Document 

No. 

042908 

Document 

Date 

04/29/08 

REORDER FORM NO. 802 LB1 (1 PART) 

HELM AGRO US INC 

8295 TOURNAMENT qR""I:.SUITE,319 MEMPHIS; TN 38125 

Amount Discount 

4,360.00 0.00 

Total 

PAY 

TO THE 

ORDER 

OF 

""- FOLIR THOUSAND THREEHUNDRED:$IXTYAND.011QO 

U.S. Environmental 

Protection ~gency 

.DATE 

May 1, 2008 

Net Amount 

4,360.00 

4,360.00 

USE WITH COMPANION ENVELOPE #44-005 

.> ')) 

26-:Y84d ~ 

, I 

}) j ) ) 

. '" 

004222 

} . . 

• • .) '> ) 

AMOUNT 

*-*-"4,360.00 
Please read instructions on reverse before completing fqrm, Form A~~rove.(:L OMS No, 2070·0060, Approval expires 05-31-98 " 

\ '"'~'\ 

-- EPA United States [R] ReS:, }ration OPP Identifier Number 

.. 

Environmental Protection Agency D Amendment 259583 

Washington, DC 20460 

D Other 

Application for Pesticide - Section I 

1, Company/Product Number 2, EPA Product Manager 3, Proposed Classification 

74530 Venus Eagle 

4, Company/Product (Name) PM# [R] None D Restricted Helm Agro US, Inc, PMG-r ~( 8295 Tournament Drive, Suite 310 

Memphis, TN 38125 

ILambda-Cyhalothrin TC 

5, Name and Address of Application (/nc/ude ZIP Code) 6, Expedited Review. In accordance with FIFRA Section 3(c)(3) 

Helm Agro US, Inc. (b)(i), my product is similar or identical in composition and labeling 

8295 Tournament Drive, Suite 310 to: 

Memphis, TN 38125 EPA Reg, No. 100-1067 

D Check if this is a new address 

Product Name: Paraquat Concentrate ES 

Section -II 

D Amendment - Explain below. D Final printed labels in response to 

D Agency letter dated 

Resubmission in response to Agency letter dated D "Me Too" Application. 

D Notification - Explain below, ffi Explain below. 

Explanation: Use additional pagers) if necessary. (For Section I and Section II.) 

Application for a "me-too" registration of a new manufacturing use product, Paraquat TC, that requires reviews of 

product chemistry data (Non-fast track; PRIA EPA # R31 0, EPA decision review time of 6 months, fee = $4,360); 

EMAI L: mwixson@helmaqro.com 

Section - III 

1. Material This Product Will Be Packaged In: 

Child-Resistant Packaging Unit Packaging Water Soluble Packaging 2. ype of Ctntainer 

D Yes D Yes D Yes Metal 

D No D No D No D Plastic 

I I Glass 

* Certification must be I I Paper If "Yes", Unit No. per If "Yes" No. per 

submitted Packaging wgt container Package wgt container I I Other (Specify) 

I I 

3. Location of Net Contents Information f4. Size(s) Retail Container 5, Location of Label Directions 

D Label D Container I IOn Label 

I I On Labeling accompanying product 

6. Manner in Which Label is Affixed to Product I I lithograph D Other 

I I Paper glued , I I Stenciled 

Section -IV 

1. Contact Point (Complete items directly below for identification of individual to be contacted, if necessary, to process this applical;joa.k ~ 

Name Title T')I,"()~('n9 No. (InGI\!de 4.rea Code) 

Marshall Wixson Manager Product Development Phore:B01-312-1525 

HELM Agro US, Inc, Fax: 901 -312-1535 ) J '; .; .~ ., 

Certification )6) Date Apeliratio~ 

I certify that the statements I have made on this form and all attachments thereto are true, accurate and complete, Receive1 , 

I acknowledge that any knowingly false or misleading statement may be punishable by fine or imprisonment or l j, 

; (Stamped) both under applicable law. J .' 

2. Signature /'--7 3. Title " 3 -:; "'-

Manager Product Development > .o: J 

4. Typed Name / 5. Date ) 

., Marshall Wixson 04/30/2008 I. J 

.. EPA Form 8570-1 (Rev. 8-94) PrevIous eclillons are obsolete. . . White - EPA File Copy (onglnal) Yellow -Applicant crw 
Form Approved OMB No. 2070~006() 

.,pt'O."..~ UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 

(~) 401 M Street, S. W. , ... ,,::1 WASHINGTON, D.C. 20460 ., c 

.~ ,) ~, .,j 

............. ~" v :;r--:;--,,~-. -~-

"" ~ -,' 

Paper Reduction Act Notice: The public reporting burden for this collection of information is estimated to average 0.25 hours per response fot"reSjistration activities and O:25'h90rs per 

response for reregistration and special review activities, including time for reading the instructions and completing the necessary forms. Send comments regarding the burden estimate or any 

other aspect of this collection of information, including suggestions for reducing the burden to: Director, OPPE Information Management Division (2137) U.S. Environmental Protection 

Agency, 401 M Street, S. w., Washington, D.C. 20460. Do not send the form to this address. 

" I " DATA MATRIX ~ ~~ " , ........... -

EPA Reg No.lFile Symbol: 74530-to Ee" v 

Date: 04128f08 .' Page "1 of 17 assigned 

Applicant'sfRegistrant's Name & Address: Helm Agro US, Inc. 

8295 Tournement Drive, Suite 310 Product: Paraquat TC 

Memphis, TN 38125 

Ingredient: Paraquat dichloride ....... -

Guideline Reference 

Numbers,. Guideline Study Name MRID Number Submitter Status Note 

OPPfOPPTS 

61-1f Product Identity and Composition Helm Agro US, Inc. Own 830.1550 47389701 

61-2f Beginning Materials and Manufacturing Helm Agro US, Inc. Own 830.1600 & 830.1620 Process 47389701 

61-31 Discussion of the Formation of Impurities Helm Agro US, Inc. Own 830.1670 47389701 

62-1f Preliminary Analysis Helm Agro US, Inc. Own 830.1700 47389702,47389703 --------_. 

62-2/ Certified Limits Helm Agro US, Inc. Own 830.1750 NfA See submitted CSF 

62-31 Enforcement Analytical Method Helm Agro US, Inc. Own 

830.1800 47389702 Syngenta Crop Protection, Inc. 

r----' -------------- 44568901 

63-2f Color -Technical Helm Agro US, Inc. Own 830.6302 47389704 • 63-3f Physical State -Technical Helm Agro US, Inc. Own 830.6303 47389704 ---------------

63-4f Odor-Technical 

830.6304 

47389704 Helm Agro US, Inc. Own 

63-5f Melting Point-Technical Syngenta Crop Protection, Inc. Own 830.7200 40479001 

63-7f Density-Technical Helm Agro US, Inc. Own 830.7300 47389704 

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

f 
Form Approved OMB No. 

·,t'A~"'· UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 2070-0060 

f~\ 401 M Street, S. W. ~,_6i WASHINGTON, D.C. 20460 

" 

,,0 'J .~ ,,' J " 

Paper Reduction Act Notice: The public reporting burden for this collection of information is estimated to average 0.25 hours per response fOr rE.~istration ac;livities and G:25' h,ours per 

response for reregistration and special review activities, including time for reading the instructions and completing the necessary forms. Send comments regarCiing the burden estimate or 

any other aspect of this collection 'of information, including suggestions for reducing the burden to: Director, OPPE Information Management Division (2137) U.S. Environmental Protection 

Agency, 401 M Street, S. W., Washington, D.C. 20460. Do not send the form to this address, --.-".-, 

DATA MATRIX : ~ v ~ . , v ... J -' 

Date: 04/28/08 EPA Reg No.lFile Symbol: 74530-to !:Ie'assigned fJage" 2 of 17 

Applicant's/Registrant's Name & Address: Helm Agro US, Inc. 

8295 Tournement Drive, Suite 310 Product: ParaquatTC 

Memphis, TN 38125 

Ingredient: Paraquat dichloride 

Guideline Reference 

Numbers, Guideline Study Name MRID Number Submitter Status Note 

OPPIOPPTS 

63-81 Solubility-Technical Helm Agro Inc. Own 830.7840 47389704 

63-9/ Vapor Pressure-Technical Syngenta Crop Protection, Inc. Own 830.7950 40479001 

63-101 Dissociation Constant Syngenta Crop Protection, Inc. Own 830.7370 40479001 

63-111 OctanollWater Partition Coefficient-Technical Syngenta Crop Protection, Inc. Own 830.7550 40479001 

63-121 pH-Technical Helm Agro US, Inc. Own 830.7000 47389704 

63-131 Stability-Technical Helm Agro US, Inc. Own 830.6313 40479001 

63-14/ Oxidation/reduction: Chemical incompatibility Helm Agro US, Inc, Own 830.6314 47389704 

63.151 Flammability-Technical Helm Agro US, Inc. Own 830.6315 47389704 

63-161 Explodability-Technical Helm Agro US, Inc. 

830.6316 47389704 Own 

63-171 Storage Stability -Technical Helm Agro US, Inc. 

830.6317 47389704 Own 

63-201 Corrosion Characteristics-Technical Helm Agro US, Inc. 

830.6320 47389704 Own 

N/AI UV visible light absorption Helm Agro US, Inc. 

830.7050 47389704 Own 

EPA Form 8570-35 (9-97) Electronic and Paper versions available. Submit only Paper version. Agency Internal Use Copy 
Form Approved OMS No. 2070-

UNITED STATES ENVIRONMENTAL PROTECTION 0060 #"\i.O.T~~ 

(~.) AGENCY 

401 M Street, S.W. 

f,.;,{#1'I.r:Jri.";I" 

WASHINGTON, D.C. 20460 

,-

'.' " ------~ 

., . .' 

Paper Reduction Act Notice: The public reporting burden for this collection of information is estimated to average 0.25 hours per response for registration activities and 0.25 hours per 

response for reregistration and special review activities, including time for reading the instructions and completing the necessary forms. Send comments regarding the burden estimate or any 

other aspect of this collection of information, including suggestions for reducing the burden to: Director, OPPE Information Management Division (?t37> U.,s" .£nvirc;']:;nental Protection 

Agency, 401 M Street, S. W., Washington, D.C. 20460. Do not send the form to this address. " '. .. ' 

DATA MATRIX ::, •••• J .' 

Date: 04/28/08 EPA Reg No.lFile Symbol: 74530-to be Page 3 of 17 assigned 

Applicant's/Registrant's Name & Address: Helm Agro US, Inc. 

8295 Tournement Drive, Suite 310 Product: Paraquat TC 

Memphis, TN 38125 

Ingredient: Paraquat dichloride ------------

Guideline Reference 

Numbers, Guideline Study Name MRID Number Submitter Status Note 

OPP/OPPTS 

71-1(a)/ Avian Acute Oral Toxicity (LDso) 00029001,00102038, Syngenta Crop Protection, Inc. Own 850.2100 - Duck 00160000, 05008363 

71-2(a)/ Avian Dietary LCso Syngenta Crop Protection, Inc. Own 850.2200 - Quail 00022923 

71-2(b)1 Avian Dietary LCso Syngenta Crop Protection, Inc. Own 850.2200 - Duck 00022923 

71-4(a)/ Avian Reproduction 00110453,00110454, Syngenta Crop Protection, Inc. Own 850.2300 - Quail 43942604 

71-4(b)/ Avian Reproduction Syngenta Crop Protection, Inc. Own 850.2300 - Duck 00110455,43942605 ------------

72-1 (a)/ Warmwater Fish Acute Toxicity Syngenta Crop Protection, Inc. 

850.1075 - Bluegill 40098001, 00162737 Own 

72-1 (c)1 Coldwater Fish Acute Toxicity 40098001,00162736, Syngenta Crop Protection, Inc. Own 850.1075 - Rainbow Trout 00182738 

72-2(a)/ Freshwater Invertebrate Toxicity 40098001,00114473, Syngenta Crop Protection, Inc. Own 850.1010 - Daphnia GS0262-028 

72-3(a)/ Estuarine/Marine Fish Acute Toxicity Not required· 

850.1075 - Sheepshead Minnow N/A 

72-3(b)/ Estuarine/Marine Mollusk Acute Toxicity Not required· 

850.102'5 - Eastern Oyster N/A 

72-3(c)/ Estuarine/Marine Acute Toxicity Not required· 

850.1035 - Shrimp N/A 

72-4(a)/ Invertebrate Chronic Toxicity Not required· 

850.1300 - Daphnia N/A 

72-5/ Full Life Stage Fish Not required* 

850.1500 - Fathead Minnow N/A 

• RED dated August 1997 

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

\ 
""",.", 

i A \ 

\~) ~"LI'R~t. 

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 

401 M Street, S.W. 

WASHINGTON, D.C. 20460 

Form Approved OMS No. 2070-0060 

Paper Reduction Act Notice: The public reporting burden for this collection of information is estimated to average 0.25 hours per response for registration activities and 0.25 hours per response 

for reregistration and special review activities, including time for reading the instructions and completing the necessary forms. Send comments regar9i~n2Jhe. bl.\rden ef.;timate or any other aspect 

of this collection of information, including suggestions for reducing the burden to: Director, OPPE Information Management Division (2137) U.S. Environmer'fal Prot~ctio~ Agency, 401 M Street, S. 

w., Washington, D.C. 20460. Do not send the form to this address.~·'" '~--~-:-~~---------1 

Date: 04/28/08 

Applicant's/Registrant's Name & Address: Helm Agro US, Inc. 

8295 Tournement Drive, Suite 310 

Memphis, TN 38125 

Ingredient: Paraquat dichloride 

Guideline Reference 

Numbers, 

OPPIOPPTS 

81-11 

870.1100 

81-21 

870.1200 

81-31 

Guideline Study Name 

Acute Oral Toxicity - Rat 

Acute Dermal Toxicity-Rabbit 

Acute Inhalation Toxicitv-Rat 

DATA MATRIX 

MRID Number 

43685001 

43685002 

EPA Reg No.lFile Symbol: 74530-to be 

assigned 

Product: Paraquat TC 

~ ____ ~87~0~.1~3=00 _~_.~~ __ ~ __ ~~~~~ ___________ .~ ____ ~~~~ ____ ~~ __ ~~~~~~~~ 

81-41 Primary Eye Irritation-Rabbit 

870.2400 

81-51 Primary Dermal Irritation-Rabbit 

870.2500 

81-61 

870.2600 

81-71 

870.6100 

81-81 

870.6200 

82-1 (a)I 

870.3100 

82-1 (b)1 

870.3150 

82-21 

870.3200 

82-31 

870.3250 

82-41 

870.3465 

Dermal Sensitization in Guinea Pigs 

Acute Delayed Neurotoxicity 

Hen 

Acute NeurotOxiCity 

Rat 

Subchronic, 90-day Toxicity 

Rat 

Subchronic, 90-day Toxicity 

Dog 

21-Day Dermal Toxicity 

RabbiUrat 

90-Day Dermal Toxicity 

Rat 

90-Day Inhalation Toxicity 

Rat 

43685004 

43685005 

NIA 

NIA 

NIA 

00072416 

00156313 

NIA 

00030788,00113718 

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

Page 4 of 17 
Form Approved OMS No. 2070-0060 

?17",.,." UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 

~~~ 

; ft '" 401 M Street, S.W. -

"'~"l1'J\O'f.i.';;# WASHINGTON, D.C. 20460 .- ~ - - .. 

Paper Reduction Act Notice: The public reporting burden for this collection of information is estimated to average 0.25 hours per response for registration activities and 0.25 hours per response 

for reregistration and special review activities, including time for reading the instructions and completing the necessary forms. Send comments regarcjc!;,tlle.Jx:J.den eoemate or any other aspect of 

this collection of information, including suggestions for reducing the burden to: Director, OPPE Information Management Division (2137) U.S. Environ~.eJltal :?rot~cti~n Abency, 401 M Street, S. W., 

Washington, D.C. 20460. Do not send the form to this address. - -' " 

. 

DATA MATRIX 

Date: 04/28108 EPA Reg No.lFile Symbol: 74530-to be Page 5 of 17 assigned 

Applicant's/Registrant's Name & Address: Helm Agro US, Inc. 

8295 Tournement Drive, Suite 310 Product: Paraquat TC 

Memphis, TN 38125 

Ingredient: Paraquat dichloride 

Guideline Reference 

Numbers, Guideline Study Name MRID Number Submitter Status Note 

OPP/OPPTS 

82-71 90-Day Subchronic Neurotoxicity Not required' 

870.6200 - Rat N/A 

83-3(a)1 Development Toxicity Syngenta Crop Protection, Inc. 

870.3700a - Mouse 43949902 Own 

- Rat 43964701,00113714 

83-3(b)1 Development Toxicity in Rabbits Syngenta Crop Protection, Inc. Own 870.3700b 00096338 

83-41 Reproduction (2-Generation) Toxicity in Rats Syngenta Crop Protection, Inc. 

870.3800 00126783 Own 

83-1 (b)1 Chronic 1-Year Feeding in Dogs Syngenta Crop Protection, Inc. Own 870.4100b 00132474 

83-2(b)1 Oncogenicity in Mice Syngenta Crop Protection, Inc. Own 870.4200 00087924,40202403 

83-51 Chronic Feeding/Oncogenicity in Rats 00138637,00153223, Syngenta Crop Protection, Inc. 

870.4300 40183501,40202401, 

40202402,41317401, Own 

40218001 

83-61 Developmental Neurotoxicity in Rats Not required' 

870.6300 N/A 

84-2(a)1 Gene Mutation Ames test Syngenta Crop Protection 

870.5100 00152690,00152691 Own 

84-2(b)1 Structural Chromosomal Aberration 00073487,00152692, Syngenta Crop Protection Own 870.5300 40202404 

84-41 Other Genotoxic Effects 00152931,00100442, Syngenta Crop Protection, Inc. 

870.5500 00152695,40202405 Own 

• RED dated August 1997 

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

~ 
BIBLIOGRAPHY OF SUBMITTED STUDIES 

Name and Address of Submitter: Helm Agro US, Inc. 

8295 Tournament Drive, Suite 310 

Memphis, TN 38125 

Product{s): Paraquat TC (Technical) 

EPA Registration No: 74530-to be assigned 

Page 1 of 2 

Purpose of Submission: Submission of data in support of the application for a "me-too" 

registration of Paraquat TC (Technical) 

Date of Submission: March 31 , 2008 

Volume Study Title Laboratory, 

Number ID Number 

10f4 Paraquat TC HELM, 

Product Identity and Composition #080328 

Description of MaterialsU sed 

Description of Production Process 

Discussion of the F onnation of 

Impurities 

Certified Limits 

Submittal of Sample 

20f4 Paraquat TC Inveresk, 

5 - Batch Analysis of Paraquat #22220 

Dichloride (Preliminary analysis, 

amended report) 

i 30f4 Paraquat TC Inveresk, 

5 - Batch Analysis of Paraquat #25044 

Dichloride: Supplementary Study to 

Measure Total Terpyridine Content 

of Paraquat Dichloride 

OPPTS 

Guideline 

Reference 

Number 

830.1550, 

830.1600, 

830.1620, 

830.1670, 

830.1750, & 

830.1900 

830.1700, 

830.1750, 

830.1800 

830.1700 

L' L' '.' \,.: \,,, 

'..... .;.. c' 

.~ " ,. 

W0 

(, ... ·J.!_f.· 4.: , 

l.. y" (.;p"'1.o"",,,, 

EPAMRID 

Number 

(Reserved for EPA 

Use) 

47389701 

47389702 

47389703 

vOU (J 

" f·.' ... , 

~J ~ L; .t ~ ) 

(;...::,. '" o ,}' (. fJ l.. •• 

" 
,'. 

Page 2 of 2 

OPPTS EPAMRID 

Volume Study Title Laboratory , Guideline Number 

Number IDNumber Reference (Reserved for EPA 

Number Us~) 

40f4 Paraquat TC Microquirn, 830.6302, 

Physicochemical Analysis of FO 25158/03 830.6303, 

Technical Grade Products (Color, 830.6304, 47388704 

i Physical State, Odor, Flammability, 830.6315, 

Stability, Corrosion Characteristics, 830.6317, 

pH, Absorption Spectrum, Boiling 830.6320, 

Point, Density, Solubility) 830.7000, 

830.7050, 

830.7220, 

830.7300, " 

830.7840 

V (.>(.)(;.0,-, 

~ (.\ 0 

o v 

2 
Document Processing Desk (RD ) 

Office of Pesticide Programs (7504P) 

U.S. Environmental Protection Agency 

One Potomac Yard, Room S-4900 

2777 S. Crystal Drive 

Arlington, VA 22202-4501 

Attention: Ms. Venus Eagle 

HELm ... bRO US, INC. 

8295 Tournament Drive, Suite 310 

Memphis, Tennessee 38125 

Phone: (901] 312-1 525 

Fax: (901]312-1535 

Via Courier Delivery 

April 30, 2008 

Registration Division - Product Manager (01) 

Subject: Paraquat TC (EPA-Reg.No.74530 - to be assigned), 

Resubmission-For RD's Completeness Check Team 

Decision #0391789 

Dear Ms. Eagle: 

HELM Agro US Inc. originally submitted on lVIarch 31,2008 an application for a new 

"me-too" registration of an existing active ingredient, paraquat dichloride, being used 

only as a Manufacturing Use Product (MUP) in formulating registered End-Use 

Products. The Agency's Completeness Check Team indicated certain deficiencies 

(missing Data Matrix, and not acceptable CSF. 

The identified deficiencies have been corrected. Enclosed you will find the following 

information/administrative materials in support of the subject application: 

1. EPA Form 8570-1: 

An executed "Application for Pesticide Registration" (OPP Identifier # 259583). 

2. Bibliography of Submitted Studies 

One copy of the Bibliography of the earlier submitted studies with assigned 

MRID numbers is enclosed. 

3. Proposed Label 

Five copies of the proposed Paraquat TC label are enclosed. , 

4. Acute Toxicity Data 
The results of the acute toxicity studies for Paraquat TC are based on the 

results from the existing studies, and assessments by the Agency regarding 

the reregistration eligibility determination for paraquat dichloride (RED, see 

Table below). The results show that Paraquat TC has moderate acute oral 

and dermal toxicity, and demonstrates severe inhalation toxicity to rats. It 

shows moderate to severe irritation effects to the eye, but only very slight skin 

irritation to the rabbit, and no skin sensitization in the guinea pig. Based on 

these data, Paraquat TC is classified as a Toxicity Category I product (see 

also proposed labeling reflecting these results). 

ACUTE TOXICITY DATA FOR PARAQUAT DICHLORIDE 

EPA-RED, August 1997, p.12) 

Guideline Study Results Category # (MRID) 

L050 Oral* 344 mg/kg -male 

81-1 rat 283 mg/kg -female II 

(43685001) 

81-2 L050 Oermal* >2000 mg/kg III rat (43685002) 

81-3 Le50 1 !Jg/L I 4h Inhalation-rat** (00046105) 

81-4 Eye Irritation* Moderate to severe II rabbit (43685003) 

Skin Irritation* Minimal irritation 

81-5 rabbit PIS = 0.5 IV 

(43685004) 

81-6 Skin Sensitization* Negative N/A Guinea Pig (43685005) 

" The test material used in these studies was paraquat techmcal concentrate, which is 45.6% 

paraquat dichloride (cation content 33% w/w). The L050 values are expressed in terms of paraquat 

dichloride (and not as paraquat cation). 

"" The test material used in this study was crystalline paraquat dichloride. Purity was not specified, but 

crystalline paraquat dichloride used in other studies was 99.9% pure. The Le50 value is expressed as 

paraquat dichloride (and not as paraquat cation). 

5. Confidential Statement of Formula 

One copy of the revised Confidential Statement of Formula (CSF), and the 

appropriate MSDS of the emetic and colorant as listed on CSF. 

6. Certification with Respect to Citation of Generic Data 

An executed EPA form 8570-34 with respect to citation of dat~'I,as;been 

enclosed. . 

I " 

2 
7. Registration Service Fee 

Under PRIA II, the subject application should be assigned EPA's Action Code 

R310: New MUP (me-too); registered active ingredient (old a.i); cite-all method 

of support; 6 months review; $4,360. 

8. CODY of fee payment 

Enclosed is a copy of check in the amount of $4,360 that was sent by USPS 

to: 

USEPA Washington Finance Center 

Pesticide Registration Service Fee 

PO Box 360277 

Pittsburgh, PA 15251 

We appreciate your expeditious processing of this application for registration of the 

subject product and the receipt of the stamped, approved label. 

Please do not hesitate to call on me at 901-312-1525, or contact me bye-mail 

(mwixson@helmagro.com) or our consultant Bert Volger at 610-793-3222 

(bertvolger@comcast.net), if you need any additional information or assistance regarding 

this application. 

Sincerely, 

Marshall Wixson, Ph.D. 

Manager Product Development 

HELM Agro US, Inc. 

3 
Form Approved OMB No. 2070-0060 

,.CIlT.il1j>; UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 

i ft \ 401 M Street, S.W. \~~ ,.' ,~ 

WASHINGTON, D.C. 20460 . '" 't)."'tPfl.(J'I't.~ .' '" . '. . 

- u . 

Paper Reduction Act Notice: The public reporting burden for this collection of information is estimated to average 0.25 hours per response for registration activities and 0.25 hours per response 

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

this collection of information, including suggestions for reducing the burden to: Director, OPPE Information Management Division (2137) U.S. Environ.~.e\l~al5'w.tectio[) .~gency, 401 M Street, S. W., 

Washington, D.C. 20460. Do not send the form to this address. .' 0 ~ 0 

'" DATA MATRIX .. 0.··· - ~ 

Date: 04/28/08 EPA Reg No.lFile Symbol: 74530-to be Page 6 of 17 assigned 

Applicant's/Registrant's Name & Address: Helm Agro US, Inc. 

8295 Tournement Drive, Suite 310 Product: Paraquat TC 

Memphis, TN 38125 

Ingredient: Paraquat dichloride 

Guideline Reference 

Numbers, Guideline Study Name MRID Number Submitter Status Note 

OPP/OPPTS 

85-1/ General Metabolism-Rats Syngenta Crop Protection, Inc. 

870.7485 00028597,00036297, Own 00028598,00055107, 

00028599,00126096 

85-2/ Dermal Adsorption/Penetration Syngenta Crop Protection, Inc. 

870.7600 00126096,00126097, Own 

00126098,00126099 

123-1(a) Seed germination & Seedling Emergence (Tier Syngenta Crop Protection, Inc. 

850.4225 2) 42639601 Own 

123-1(c) Vegetative Vigor (Tier 2) Syngenta Crop Protection, Inc. Own 850.4250 42601001 

122-2 (b) Aquatic Plant Growth (Tier 2) Syngenta Crop Protection, Inc. 

850.5400 42601002,42601003, Own 

42601004,42601005 

132-1 (a)/ Foliar Dislodgeable Residue Dissipation Not required* 

875.2100 N/A 

141-1/ Honey Bee Acute Contact LC50 (Tier 1) Syngenta Crop Protection, Inc. 

885.4380 05001991,00028772, Own 

00111488,43942603 

141-2/ Honey Bee Toxicity - Residues on Foliage Not required* 

850.3030 N/A 

* RED dated August 1997 

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

".O .... i""" UNITED STATES ENVIRONMENTAL PROTECTION AGENCY OMS No. 2070-

i 1ft 1 401 M Street, S.W. 0060 

\ .. ~, ~,-."jt WASHINGTON, D.C. 20460 ~. 

~ . 

~ .," . v ~ • 

Paper Reduction Act Notice: The public reporting burden for this collection of information is estimated to average 0.25 hours per response for registration activities and 0.25 hours per response 

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

this collection of information, including suggestions for reducing the burden to: Director, OPPE Information Management Division (2137) U.S. Environ~~.~tall?[p.tectior:~ 6Io.gency, 401 M Street, S. 

W., Washington, D.C. 20460. Do not send the form to this address. . .. DATA MATRIX . " .- " ., 

Date: 04/28/08 EPA Reg No./File Symbol: 74530-to be assigned Page 7 of 17 

Applicant's/Registrant's Name & Address: Helm Agro US, Inc. 

8295 Tournement Drive, Suite 310 Product: Paraquat TC 

Memphis, TN 38125 

Ingredient: Paraquat dichloride 

Guideline Reference 

Numbers, Guideline Study Name MRIDNumber Submitter Status Note 

OPPIOPPTS 

161-11 Hydrolysis Syngenta Crop No MRID: Upton - ~uideline 'V'''''''''I< Own 835.2120 NIA fulfilled; review 2/14/85· 

161-21 Aqueous Photolysis Syngenta Crop Protection, Inc. Own 835.2240 40562301 

161-31 Soil Photolysis Syngenta Crop 'v'~v"""' Inc. Own No MRID: Pack = guideline 

835.2410 NIA fulfilled; 2/14/85· 

162-11 Aerobic Soil Metabolism Syngenta Crop Protection, Own 835.4100 41319301 

162-21 Anaerobic Soil Metabolism Syngenta Crop Protection, Inc. Own 835.4200 41319302 

162-31 Anaerobic Aquatic Metabolism Not required' 

835.4400 NIA 

162-41 Aerobic Aquatic Metabolism Not required" 

835.4300 NIA 

163-11 Leaching and Adsorption/DesorptIon Syngenta Crop Protection, Inc. Own 835.1240 40762701 

164-11 Field Soil Dissipation 42738701,42738702, Syngenta Crop Protection, Inc. 

835.6100 42802101,42802102, Own 

41352101,41352102 

164-21 Aquatic Field Soil Dissipation NIA ..... 

Not required" 

835.6100 

165-11 Confined Rotational Crops 

860.1850 

41645601 Syngenta Crop Protection, Inc. Own 

165-21 Field Accumulation in Rotational Crops NIA Not required" 

860.1900 

165-41 Sioaccumulation in Fish NIA Not required" 

850.1730 

165-5 Sioaccumulation in Aquatic Non-Target NIA Waived· 

* RED dated August 1997 

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

, 
Form Approved OMS 

~.r..j't.; UNITED STATES ENVIRONMENTAL PROTECTION AGENCY No. 2070-0060 , ft >, 

~~ 401 M Street, S.W. 

WASHINGTON, D.C. 20460 " ~ 

" . , " . . -----

. ~ .' ' : , Paper Reduction Act Notice: The public reporting burden for this collection of information is estimated to average 0.25 hours per response for registration activities and 0.25 hours per response for 

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

collection of information, including suggestions for reducing the burden to: Director, OPPE Information Management Division (2137) U.S. Environment:;JL~r9te;:;tiC'J1 Agel1SY, 401 M Street, S. W., 

Washington, D.C. 20460. Do not send the form to this address. .' '" "," d, d '-J .'" ' '" DATA MATRIX - ---------

Date: 04/28/08 EPA Reg No.lFile Symbol: 74530-to be assigned Page 8 of 17 

Applicant's/Registrant's Name & Address: Helm Agro US, Inc. 

8295 Tournement Drive, Suite 310 Product: Paraquat TC 

Memphis, TN 38125 

Ingredient: Paraquat dichloride ------------

Guideline Reference 

Numbers, Guideline Study Name MRIDNumber Submitter Status Note 

OPPIOPPTS f--'-'-----

171-4(a) Nature of Residues 00065602, 00065604, Syngenta Crop Protection, Inc. 

860,1300 - plants 00091365,00091366 Own 

--------

171-4(b) Nature of Residues 00028596,00028597, Syngenta Crop Protection, Inc. 

860,1300 - Livestock 00028598,00028509, Own 

00089748,00114414, 

00114422,00117783, 

42324302 

171-4(c) Residue Analytical Method - plants 00025269, 00030476, Syngenta Crop Protection, Inc. 

860.1340 00032141,00032240, Own 

00037058,00090400, 

00112663,00114411, 

00114421,00114446, 

00114453,00114465, 

00114466,00138258, 

40048401,40098502, 

41151508,41151514, 

41151519,41151522, 

41151528,42217402, 

42217403,42217404, 

42217405,43492603 

171-4(d) Analytical Method - livestock 00036306,00037058, Syngenta Crop Protection, Inc. Own 

860,1340 00112663,00114421, 

00114422,40943701, 

42217401,43226902, 

43226903,43492601, 

43969101 

\ 
Form Approved OMS 

,/'ft)87.4~ No. 2070-0060 

i .ft ') UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 

\~. 401 M Street, S.W. ,- .. 'tt,.,dI'-~ WASHINGTON, D.C. 20460 '-

" . 

• 0 .J c' J " ,< " 

Paper Reduction Act Notice: The public reporting burden for this collection of information is estimated to average 0.25 hours per response for regisfration activitie~sa'nd 0.25hours0 per response for 

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

collection of information, including suggestions for reducing the burden to: Director, OPPE Information Management Division (2137) U.S. Environment~.1 f~~te<?tL09 AgelJt::y, 401 M Street, S. W., 

Washington, D.C. 20460. Do not send the form to this address. ,,_. ___ . _,_ .. _._. 

DATA MATRIX 

Date: 03/28/07 EPA Reg No.lFile Symbol: 74530-to be assigned Page 9 of 17 

Applicant's/Registrant's Name & Address: Helm Agro US, Inc. 

8295 Toumement Drive, Suite 310 Product: Lambda-Cyhalothrin 

Memphis, TN 38125 

Ingredient: Paraquat dichloride 

Guideline Reference 

Numbers, Guideline Study Name MRID Number Submitter Status Note 

OPP/OPPTS 

171-4(e) Storage Stability 00037057, 00113702, Syngenta Crop Protection, Inc. Own 

860.1380 40943702,40943703, 

41151511,41151535 

- Crops & animal tissues 41151536,41151537, 

41151538,41151539, 

41151540,41151541 

42217401,42217440 

through 42217450, 

43954003,43954004 

171-40) Magnitude of residues in meatlmflklpoultry/eggs 00036305, 00090978, Syngenta Crop Protection, Inc. Own 

860.1480 00114414,00114422, 

00117783,00038503, 

40943704 

171-4(k) Magnitude of Residues - Crop Field Trials Syngenta Crop Protection, Inc. Own 860.1500 Root and Tuber Vegetables Groul;! 

- Carrots 00030476 

- Cassava 00160250 

- Potatoes 00033612,00091376, 

00105060 

- Sugar beet roots 00113709,41151514, 

42217418 

- Taniers 00160250 

- Taro corms 41017901 

- Turnips, roots 00030476 

- Yams 00160250 

Leaves of Root and Tuber 

Vegetables Group 

- Sugar beet tops 00113709,41151514, 

42217418 

- Taro fOliage 45189501 IR-4 

\ 
Form Approved OMB 

,a'r..f't No. 2070-0060 

(,,<1 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 

401 M Street, S. W. """l~";I' WASHINGTON, D.C. 20460 

-, - ~ ~:::: .,. 

Paper Reduction Act Notice: The public reporting burden for this col/ection of information is estimated to average 0.25 hours per response for reg,istation activiti~s and 0.125 ~JOGrs ~er response for 

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

col/ection of information, including suggestions for reducing the burden to: Director, OPPE Information Management Division (2137) U.S. Environmental Protection Agency, 401 M Street, S. W., 

Washington, D.C. 20460. Do not send the form to this address. ~ ..: ~-~~~":"'_-_--.r_ 

DATA MATRIX -

- " . , .. - - - Date: 04/28/08 EPA Reg No.lFile Symbol: 74530-to b€..&Srsig;,ed iPag~ 10 of 17 

Applicant's/Registrant's Name & Address: Helm Agro US, Inc. 

8295 Tournement Drive, Suite 310 Product: Paraquat TC 

Memphis, TN 38125 1 

Ingredient: Paraquat dichloride 

Guideline Reference 

Numbers, Guideline Study Name MRID Number Submitter Status Note 

OPPIOPPTS 

171-4(k) Magnitude of Residues - Crop Field Trials Syngenta Crop Protection, Inc. Own 

860.1500 Bulb Vegetables Group 

- Onions, dry bulb and green 00113680,00136330, 

45419901 IR-4 

Leafy Green Vegetables (excegt 

Brassica veg.) Groug 

- Lettuce 

- Rhubarb 0114474,00139741 

00031863 

Brassica Leafy Vegetables Group 

- Broccoli 

- Cabbage 00103245 

- Cauliflower 00103245 

- Chinese cabbage 00030476 

Collards 00030476 

00030476 

Legume Vegetables Groug 

- Beans (succulent, lima, snap & dry) , 

- Guar 00030476,00033223 

- Peas (succulent) 00114420 

- Pigeon peas 00030476 

- Soybean seed &aspirated grain fractions 00147206 

00015768,00025268, 

00015769 00015771, 

00032427,00015772, 

00015774,00098579, 

00015775, 00030676, 

00015770,00031742 

00033530,00015773, 

00034112,00109728, 

00114446,41151524, 

l,t:J(c 41151530,42217426, 

42217438,43226904, 

43226904 --
Form Approved OMB 

;I.O.'-4~ 

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 

No. 2070-0060 

(~.) 401 M Street, S.W. ~ 

~"{PfII{fI'-"# WASHINGTON, D.C. 20460 'vi .~' " J ---------_. 

y .' ". 

Paper Reduction Act Notice: The public reporting burden for this collection of information is estimated to average 0.25 hours per response for registration activities and hours per response 

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

this collection of infonmation, including suggestions for reducing the burden to: Director, OPPE Infonmation Management Division (2137) U.S. Environ[l1J'!Jt.i31 E'r;p!ectio~,~gency, 401 M Street, S. W., 

Washington, D.C. 20460. Do not send the fonm to this address. .i ,/." 

DATA MATRIX .J J 

,;-".,1...) "'" . ----------------

Date: 04/28/08 EPA Reg No.tFUe Symbol: 74530-to be assigned Page 13 of 17 

Applicant's/Registrant's Name & Address: Helm Agro US, Inc. 

8295 Toumement Drive, Suite 310 Product: Paraquat TC 

Memphis, TN 38125 

Ingredient: Paraquat dichloride 

Guideline Reference 

Numbers, Guideline Study Name MRID Number Submitter Status Note 

OPP/OPPTS 

171-4(k) Magnitude of Residues - Crop Field Trials (cont.) Syngenta Crop Protection, Inc. Own 860.1500 Cereal Grains Group 

Barley grain 00114411 

Corn, field, grain & aspirated grain fractions 00015751,00023512, 

00015752,00015955, 

00030647,00016441, 

00031744,00016442, 

00033223,00016444, 

00093182, 00016445, 

00023131,41151523, 

42217437,43226904 

Corn, sweet 00030683, 00033223, 

41151506 

Oat grain 00114411 

Rice grain 42670801 

Sorghum grain and aspirated 00023131,00026963, 

grain fractions 00027178,00033223, 

00070872,00113709, 

41151531,42217439 

Wheat grain and aspirated grain 00027311,00113693, 

fractions 00114411,00140828, 

41151525,42217439 

Forage, Fodder, Hay, and Straw of 

Cereal Grains Group 

Barley forage, hay, and straw 00114411 
~.r .. ,,*,-

"Al 

~# """". 

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 

401 M Street, S.W. 

WASHINGTON, D.C. 20460 

Form Approved OMB 

No. 2070-0060 

Paper Reduction Act Notice: The public reporting burden for this collection of information is estimated to average 0.25 hours per response for registration activities and 0.25 hours per response for 

reregistration and special review activities, including time for reading the instructions and completing the necessary forms. Send comments regarding t!1t! P1.1rdtlO 8lstim~te or any other aspect of this 

collection of information, including suggestions for reducing the burden to: Director, OPPE Information Management Division (2137) U.S. Environment",1 Protegtion'Ag<mcy; 401 M Street, S. W., 

Washington, D.C. 20460. Do not send the form to this address. ~ ..... , .... '.;-' -------------l 

Date: 04128/08 

Applicant's/Registrant's Name & Address: Helm Agro US, Inc. 

8295 Tournement Drive, Suite 310 

Ingredient: Paraquat dichloride 

Guideline Reference 

Numbers, 

OPP/OPPTS 

171-4(k) 

860.1500 

Guideline Study Name 

Magnitude of Residues - Crop Trials· 

Forage, Fodder, Hay, and Straw of Cereal 

Grains Group (cont.) 

- Corn, field, forage and fodder 

- Corn, sweet, forage, and fodder 

- Oat forage, hay, and straw 

Rice straw 

Sorghum forage and fodder 

- Wheat forage, hay, and straw 

Grass Forage, Fodder, and Hay Group 

DATA MATRIX 

MRID Number 

00015751,00015752, 

00015955,00016441 

00016442,00016444, 

00016445,00023131, 

00023512, 00027972, 

00027973, 00030647, 

00031519,00031744, 

00033208, 00033223, 

00093182,41151523, 

42217437 

00030683, 00033223, 

41151506,42217411 

00114411 

42670801 

00026963,00027178, 

00070872,41151531, 

42217430 

00027311,00114411, 

41151525,42217401, 

42217439,42961401 

00033223,00058773, 

00114424,00114466, 

00117783,00160817, 

41151515,41151516, 

41151526,42217419, 

42217420,42217425 

EPA Reg No.lFile Symbol: 74530-to be assigned Page 14 of 17 

Product: Paraquat TC 

Submitter Status Note 

Syngenta Crop Protection, Inc. Own 
#"'''''>. 

(~l ",,,,,,,, 

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 

401 M Street, S.W. 

WASHINGTON, D.C. 20460 

Form Approved OMS 

No. 2070-0060 

Paper Reduction Act Notice: The public reporting burden for this collection of information is estimated to average 0.25 hours per response for regi.;;tr';'tion activiti&::; and O.:i.~ hou,:s per response for 

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

collection of information, including suggestions for reducing the burden to: Director, OPPE Information Management Division (2137) U.S. Environmental Protection Agency, 401 M Street, S. W., 

I Washington, D.C. 20460. Do not send the form to this address. ~,"""_~4-_-~.-~-----------t 

Date: 04/28/08 

Applicant's/Registrant's Name & Address: Helm Agro US, Inc. 

8295 Tournement Drive, Suite 310 

Memphis, TN 38125 

Ingredient: Paraquat dichloride 

Guideline Reference 

Numbers, I Guideline Study Name 

OPP/OPPTS 

171-4(k) Magnitude of Residues - Crop Field Trials (cont.) 

860.1500 - Alfalfa 

- Sirdsfoot Trefoil 

- Clover 

Miscellaneous Commodities 

- Artichokes 

Acerola 

Asparagus 

Avacodos 

Bananas 

Coffee 

Cotton, seed, and gin byproducts 

- Figs 

- Guava 

- Hops, cones, dried 

- Kiwifruit 

- Mint hay 

- Okra 

- Olives 

- Papaya 

DATA MATRIX 

MRID Number 

00032140,00114464, 

0005877 4 00114465, 

00105061,00114467, 

00114405,00126671, 

00114421 00128624, 

00114424,00165364, 

41151501,42217406 

00114424, 41151542, 

42217434 

00114424, 00117783, 

41151509,42217414 

44125901 

00128221 

00033532,00113675 

GS0262-006 

00113709,00139733 

00139734 

00031739,00033612, 

00091372,42217401 

00139735,41151502~ 

42217407,42961401 

00114419 

00113686,41151521, 

42217435 

00088195 

00137859 

45439901 

00139737 

00033695 

.' 

EPA Reg No.lFile Symbol: 74530-to b19'aS::iigI1ed 'flage 15 of 17 

Product: Paraquat TC 

Submitter Status Note 

Syngenta Crop Protection, Inc. Own 

IR-4 

IR-4 
:\(.OlIt~ 

'/'A\ 

i~~ 

~(""tP~ 

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 

401 M Street, S. W. 

WASHINGTON, D.C. 20460 <v 

~ 

Form Approved OMS 

No. 2070-0060 

Paper Reduction Act Notice: The public reporting burden for this collection of information is estimated to average 0.25 hours per response for resJsteation activi!iCl$ <,lnd 0,25 ';lObr~,.ler response for 

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

collection of information, including suggestions for reducing the burden to: Director, OPPE Information Management Division (2137) U,S, Environmental Protection Agency, 401 M Street, S, W., 

Washington, D,C. 20460. Do not send the form to this address. 

Date: 04/28/08 

Applicant's/Registrant's Name & Address: Helm Agro US, Inc. 

8295 Tournement Drive, Suite 310 

Memphis, TN 38125 

Ingredient: Paraquat dichloride 

Guideline Reference 

Numbers, I Guideline Study Name 

OPP/OPPTS 

171-4(k) I Magnitude of Residues - Crop Field Trials (cont.) 

860.1500 - Passion Fruit 

171-4 <I} 

860.1700 

- Peanut nutmeats, hay, and hulls 

Peas 

- Pineapple 

- Pistachios 

- Safflower seed and forage 

- Strawberries 

- Sugarcane 

- Sunflower seeds and forage 

Magnitude of Residues in Processed Food/Feed 

Citrus fruits 

- Coffee 

- Corn, field 

- Cottonseed 

Figs 

DATA MATRIX 

MRID Number 

00037056 

40098501,40098503 

44315001 

00114411,41151534, 

42217432,42217433 

00027550, 00035666, 

00113699 

00114411 

00138258 

00114411,00114469 

00106570,00114422, 

41151512,42217416 

00033695 

41151529,42217401, 

42217428 

00114426,41151528, 

42217401,42217427 

00091372 

41151502,42217407, 

42961401 

j:,0-;$-<0-V-'0'-'¢"~"-' --.", .. ,. 

EPA Reg No./File Symbol: 74530-to t:6":l&si9~led I~Paa~ 16 of 17 

Product: Paraquat TC 

Submitter Status Note 

Syngenta Crop Protection, Inc. Own 
",'AI'i>.-,\ UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 

401 M Street, S.W . 

Form Approved OMS 

No. 2070-0060 

~~ . ;, ,.{"'~ WASHINGTON, D.C. 20460 

Paper Reduction Act Notice: The public reporting burden for this collection of information is estimated to average 0.25 hours per response for regiStsation activitiE:'<; .. ?':1d 0.25h-oure:.per response for 

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

collection of information, including suggestions for reducing the burden to: Director, OPPE Information Management Division (2137) U.S. Environmental Protection Agency, 401 M Street, S. W., 

Washil1gton, D.C. 20460. Do not send the form to this address. 

" DATA MATRIX 

Date: 04/28/08 EPA Reg No'/File Symbol: 7453:D,t0~De: P 1 1 assi ned age 7 of 7 

Applicant's/Registrant's Name & Address: Helm Agro US, Inc. 

Ingredient: 

Guideline 

Reference 

Numbers, 

OPPIOPPTS 

171-4(1) 

231 and 232 

Signature: 

Paraquat dichloride 

8295 Tournement Drive, Suite 310 

Memphis, TN 38125 

Guideline Studv Name 

Magnitude of Residues in Processed Food/Feed 

(cont.) 

- Grapes 

- Hops 

Mint 

Olives 

- Pineapples 

- Plums 

- Potatoes 

- Sorghum 

- Soybeans 

- Sugar beets 

- Sugarcane 

- Sunflower 

- Tomatoes 

- Wheat 

Estimation of Dermal and Inhalation Exposure 

/,/~ ~ 

MRID Number 

44600601 

41151521,42217435 

00137859,42217401 

41151522,42217401 

41151533,42217432 

41151532,42217401, 

42217431 

41151508,42217401, 

42217413 

00114421,41151520, 

42217424 

00034112 

41151519,42217401, 

42217423 

00114411,00114469, 

41151518,42217422 

00114422 

41151510,42217415 

41151517,42217401, 

42217421 

43618202, 43644201 

43644202 

EPA Form 8570-35 (9-97)tE:lectronic and Paper versions available. Submit only Paper version. 

Product: Paraquat TC 

Submitter Status 

Syngenta Crop Protection, Inc. 

Own 

Syngenta Crop Protection, Inc. Own 

Name and Title: Marshall Wixson, Ph.D. 

Manager Product Development 

HELM AGRO US Inc. 

Note 

Date: 4/28/2008 

Agency Internal Use Copy 

\ 
Paraquat TC 

(Technical Concentrate) 

For Fonnulation ·ofParaquat Herbicide Products Only 

ACTIVE INGREDIENT 

Paraquat dichloride (1,1' -demethyl, 4,4' -bipyridinium dichloride) 

INERT INGREDIENTS 

TOTAL 

Cpntains 3 pounds paraquat cation per gallon. 

Contains emetic. 

EPA Reg. No. 74530-xx 

EPA Establishment No. 

KEEP OUT OF REACH OF CHILDREN 

DANGERIPELIGRO 

POISON 

43.8% 

56.2% 

100.0% 

Si usted no entiende la etiqueta, busque a alguien para que se la explique a usted en detalle. (If you do not 

understand the label, find someone to explain it to you in detail). 

• NEVER PUT INTO FOOD, DRINK OR OTHER CONTAINERS 

• IF SWALLOWED, TAKE IMMEDIATE ACTION AS PRESCRIBED IN FIRST AID 

STATEMENT. SYMPTOMS ARE PROLONGED AND PAINFUL. 

Net Contents: 

HELM AGRO Inc. 

8295 Tournament Drive 

Memphis, TN, 38125 

info@helmagro.com 

DRAFT submitted to EPA: Q.4-jD-2Q08 , j .) 

1 
FIRST AID 

If swallowed • Speed is essential. Immediate attention is required. If 

Give an adsorbent such as activated charcoal, bentonite 

Earth. 

Call a poison control cen.ter or doctor immediately for treatment. 'I 

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

Hold eye open and rinse slowly and gently with water for 15 to 20 • 

• 

• 

• 

mms. R emove con ttl ac enses, I 'f presen, t a ft er th e fi Irs t 5 ' t mmu es, th en 

continue rinsing eye. 

• Call a poison control center or doctor for treatment advice. 

If on skin or clothing • Take off contaminated clothing. 

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

• Call poison control center or doctor for treatment advice. 

If inhaled • Move person to fresh air, 

• If person is not breathing, call 911 or an ambulance. 

• Call a poison control center or doctor for further treatment advice. 

NOTE TO PHYSICIAN 

Administer either activated charcoal (100g for adults or 2g/kg body weight in children) or Fuller's 

Earth (15% solution: 1 liter for adults or 15mg/kg body wight in children(. 

NOTe: The use of gastric lavage without administration of an adsorbent has not shown any clinical 

. benefit. Do not use supplemental oxygen. Eye splashesfrom concentrated material should be treated by 

an eye specialist after initial treatment. With the possibility of late onset corneal ulceration, it is advised 

that patients with paraquat eye injuries are reviewed by an eye specialist the day after first presentation, 

Use treatment that is appropriate for chemical bums. Intact skin is an effective barrier to paraquat, 

however contact with irritated or cut skin or repeated contact with intact skin may result in poisoning. 

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

treatment. 

HOTLINE 

For medical emergencies involving this product, call CHEMTREC 1-800-424-9300. For chemiC'J'l1 

emergency: Spill, leak, fire, exposure, or accident, call CHEMTREC 1-800-424-9300 

PRECAUTIONARY STATEMENTS 

HAZARDS TO HUMANS AND DOMESTIC ANIMALS 

DANGERIPELIGRO 

POISON 

I 

! 

May be fatal if swallowed. Fatal if inhaled. Do not breathe spray mist. Do not inhale contaminated dust. 

Causes substantial but temporary eye injury. Do not get in eyes or on clothing. A void contact with skin. 

Harmful if absorbed through skin. Wear (goggles, face shield, or safety glasses). 

IMPORT ANT: The effect of swallowing paraquat concentrate is far more severe than that which usually 

results from skin contact or inhalation of contaminated plant dust. This product should not cause injury if 

used according to label instructions. 

When handling or mixing concentrate or when exposure to concentrate is possible, wear: 

2 
• Dust/mist filtering NIOSH approved respirator with any R,P or HE filter 

• Protective clothing (disposable suit/coveralls or long-sleeve shirt and long pants) 

• Full face shield 

• Chemical-resistant gloves (Category A) 

• Chemical resistant apron and shoes plus socks 

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

REMOVE contaminated clothing and wash separately from other laundry before reuse. 

ENVIRONMENTAL HAZARDS 

This product is toxic to wildlife. Do not discharge effluent containing this product into lakes, streams, 

ponds, estuaries, oceans, or public waters unless this product is specifically identified and addressed in a 

National Pollutant Discharge Elimination System (NPDES) permit. Do not discharge effluent containing 

this product to sewer systems without previously notifying the sewage treatment plant authority. For 

guidance, contact your State Water Board or Regional Office of EPA. 

PHYSICAL AND CHEMICAL HAZARD 

This product reacts with aluminum to produce hydrogen gas which may form a highly combustible gas 

mixture. Do not mix or store in containers, tanks, or such systems made of aluminum or having aluminum 

fittings. 

EQUIPMENT/CONTAINER 

Flush all equipment with water after use each day. Paraquat is. corrosive to aluminum. Aluminum 

equipment and aluminum structures that are exposed to solution or spillage should be flushed thoroughly 

with water immediately after use. 

SPILLAGE DURING TRANSPORT 

Emergency Action: Notify police and fire departments immediately. For any spill, leak, fire, or 

exposure in the United States, call CHEMTREC 1-800-424-9300. 

KEEP PUBLIC AND ANIMALS away from area. MARK ROADS AND WARN OTHER ROAD 

USERS. WEAR face shield, waterproff gloves, waterproof footwear, and long-sleeve shirt and long pants 

during decontamination operations. 

Clean up spills as soon as possible. Cover spill with generous amount of clay or loam soil to absorb 

liquid, using a stiff broom to ensure intimate contact. Sweep onto shovel and transfer to plastic bag or 

other disposable container. Repeat operations until contaminated surfaces are dry. Finally, hose spill site 

with water, if feasible. 

DIRECTIONS FOR USE 

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

3 
READ ENTIRE LABEL. USE STRICTLY IN ACCORDANCE WITH PRECAUTIONARY 

STATEMENTS AND DIRECTIONS, AND WITH APPLICABLE STATE AND FEDERAL 

REGULATIONS. 

Only for fonnutation into a herbicide for the following uses: 

TERRESTRIAL FOOD CROP 

Acerola (West Indies cherry), apricot, asparagus, avocado, banana, blackberry, blueberry, boysenberry, 

broccoli, cabbage, Chinese, carrot (including tops), cauliflower, cherry, cocoa, coffee, collards, cucumber, 

eggplant, fig, filbert (hazelnut), garlic, groundcherry (strawberry tomato/tomatillo), guava, hops, 

kiwifruit, lettuce, loquat, macadamia nut (bushnut), manioc (cassava), melons, melons, cantaloupe, 

melons, musk, melons, water, mint, nectarine, olive, onion, papaya, passion fruit, peach, pear, pecan, 

pepino (melonpear), pepper, pepper (chilli type), pineapple, pistachio, plum, potato, 

whit/Irish, prune, pumpkin, raspberry (black, red), rhubarb, small fruits, squash (all or unspecified), 

strawberry, sugar beet, taro, walnut (English/black), yarn, yautia. 

TERRESTRIAL FOOD+FEED CROP 

Almond, apple, barley, beans, asparagus, beans, dried-type, beans, mung; beans-succulent (lima); beanssucculent (snap), citrus fruits, com (unspecified), com, field, com, pop, com, sweet, cotton (unspecified), 

garbanzos (including chickpeas), grapes, guar, hops, legume vegetables, mint, oats, orchards 

(unspecified), peanuts, peanuts (unspecified), soybeans, edible, speannint, sugar beet, sugar crops, 

sugarcane, sunflower, tomato, turnip, vegetables (unspecified), wheat. 

TERRESTRIAL FEED CROP 

Alfalfa, barley, beans, clover, crownvetch, legume vegetables, lespedeza, lupine, pastures, sainfoin, 

timothy, trefoil, tyfon, vetch, wheat. 

TERRESTRIAL NON-FOOD CROP 

Agricultural fallow/idleland, airports/landing fields, commercial/industrial lawns, 

commercial/institutionallindustrial, premises/equipment (outdoor), fencecrows/hedgerows, grasses grown 

for seed, industrial areas (outdoor), jojoba, nonagricultural outdoor buildings/structures, nonagricultural 

uncultivated areas/soils, ornamental and/or shade trees, peach (non-bearing, seed beds), recreation area 

lawns, tomato (post-harvest)/ wood protection treatment to forest products (seasoned). 

FORESTRY 

Forest planting (reforestation programs), pine (forest/shelterbelt), shelterbelt plantings . 

. TERRESTRIAL NON-FOOD 

Ornamental andlor shade trees, ornamental herbaceous plants, ornamental woody shrubs and vines, noncrop areas such as public airports, electric transfonner stations and around commercial buildings. 

OTHERS 

Uses for which USEPA has accepted the required data andlor citations of data that the fonnulator has 

submitted in support of registration; and uses for experimental purposes that are in compliance with 

USEPA requirements. 

STORAGE AND DISPOSAL 

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

PESTICIDE STORAGE; Sotre ate t~l'llperatures above 32° F. Do notc:;ontaminate food, foodstuffs, or 

4 
drinking 

Water. Do not store next to feed or food, or transport in or on vehicles containing foodstuffs or feeds. For 

help with any spill, leak, fire or exposure involving this material call CHEMTREC 1-800-424-9300. 

PESTICIDE DISPOSAL; Pesticide wastes are acutly hazardous. Improper disposal of excess pesticide 

or rinsate is a violation of Federal law. If these wastes cannot be disposed of by use according to label 

instructions, contact your State Pesticide or Enviromental Control Agency, or the Hazardous Waste 

representative at the nearest EPA Regional Office for guidance. 

CONTAINER DISPOSAL: Triple rinse (or equivalent). Offer for recycling or recondition, or puncture 

and dispose of in a sanitary landfill, or dispose of by other procedures allowed by State and local 

authorities. 

CONDITIONS OF SALE 

AND LIMITATION OF WARRANTY AND LIABILITY 

NOTICE: Read the entire Directions for Use and Conditions of Sale and Limitation of Warranty and 

Liability before buying or using this product. If the terms are not acceptable, return the product at once, 

unopened, and the purchase price will be refunded. 

The Directions for Use of this product should be followed carefully. It is impossible to eliminate all risks 

inherently associated with the use of this product. Crop injury, ineffectiveness or other unintended 

consequences may result because of such factors as manner of use or application, weather or crop 

conditions, presence of other materials or other influencing factors in the use of the product, which are 

beyond the control of Helm Agro US, Inc. or Seller. All such risks shall be assumed by Buyer and User, 

and Buyer and User agree to hold Helm and Seller harmless for any claims relating to such factors. 

Helm warrants that this product conforms to the chemical description on the label and is reasonably fit for 

the purposes stated in the Directions for Use, subject to the inherent risks referred to above, when used in 

accordance with directions under normal use conditions. This warranty does not extend to the use of this 

product contrary to label instructions, or under abnormal conditions or under conditions not reasonably 

foreseeable to or beyond the control of Seller or Helm, and Buyer and User assume the risk of any such 

use. HELM MAKES NO WARRANTIES OF MERCHANTABILITY OR OF FITNESS FOR A 

PARTICULAR PURPOSE NOR ANY OTHER EXPRESS OR IMPLIED WARRANTY EXCEPT 

AS STATED ABOVE. 

In no event shall Helm or Seller be liable for any incidental, consequential or special damages resulting 

from the use or handling of this product. THE EXCLUSIVE REMEDY OF THE USER OR BUYER, 

AND THE EXCLUSIVE LIABILITY OF HELM AND SELLER FOR ANY AND ALL CLAIMS, 

LOSSES, INJURIES OR DAMAGES (INCLUDING CLAIMS BASED ON BREACH OF 

WARRANTY, CONTRACT, NEGLIGENCE, TORT, STRICT LIABILITY OR OTHERWISE) 

RESULTING FROM THE USE OR HANDLING OF TIDS PRODUCT, SHALL BE THE 

RETURN OF THE PURCHASE PRICE OF THE PRODUCT OR, AT THE ELECTION OF 

HELM OR SELLER, THE REPLACEMENT OF THE PRODUCT. 

Helm and Seller offer this product, and Buyer and User accept it, subject to the foregoing conditions of 

sale and limitations of warranty and of liability, which may not be modified except by written agreement 

signed by a duly authorized representative of Helm. 

5 
Paraquat TC 

(Technical Concentrate) 

For Formulation of Paraquat Herbicide Products Only 

ACTIVE INGREDIENT 

Paraquat dichloride (1,1' -demethyl, 4,4' -bipyridinium dichloride) 

INERT INGREDIENTS 

TOTAL 

Contains 3 pounds paraquat cation per gallon. 

Contains emetic. 

EPA Reg. No. 74530-xx 

EPA Establishment No. 

KEEP OUT OF REACH OF CHILDREN 

DANGERJPELIGRO 

POISON 

43.8% 

56.2% 

100.0% 

Si usted no entiende la etiqueta, busque a alguien para que se la explique a usted en detalle. (If you do not 

understand the label, find someone to explain it to you in detail). 

• NEVER PUT JNTO FOOD, DRJNK OR OTHER CONTAINERS 

• IF SWALLOWED, TAKE IMMEDIATE ACTION AS PRESCRIBED IN FIRST AID 

STATEMENT. SYMPTOMS ARE PROLONGED AND PAINFUL. 

Net Contents: 

HELM AGRO Inc. 

8295 Tournament Drive 

Memphis, TN, 38125 

info@helmagro.com 

DRAFT submitted to EPA: 04-j(P2U08 

1 
FIRST AID 

If swallowed • Speed is essential. Immediate attention is required. If available, 

Give an adsorbent such as activated charcoal, bentonite or Fuller's 

Earth. 

• Call a poison control center or doctor immediately for treatment. 

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

Ifin eyes • Hold eye open and rinse slowly and gently with water for 15 to 20 

mins. Remove contact lenses, if present, after the first 5 minutes, then 

continue rinsing eye. 

• Call a poison control center or doctor for treatment advice. 

If on skin or clothing • Take off contaminated clothing. 

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

• Call poison control center or doctor for treatment advice. 

If inhaled • Move person to fresh air. 

• If person is not breathing, call 911 or an ambulance. 

• Call a poison control center or doctor for further treatment advice. 

NOTE TO PHYSICIAN 

Administer either activated charcoal (lOOg for adults or 2g1kg body weight in children) or Fuller's 

Earth (15% solution: 1 liter for adults or 15mglkg body wight in children(. 

NOTe: The use of gastric lavage without administration of an adsorbent has not shown any clinical 

benefit. Do not use supplemental oxygen. Eye splashesfrom concentrated material should be treated by 

an eye specialist after initial treatment. With the possibility of late onset corneal ulceration, it is advised 

that patients with paraquat eye injuries are reviewed by an eye specialist the day after first presentation. 

Use treatment that is appropriate for chemical burns. Intact skin is an effective barrier to paraquat, 

however contact with irritated or cut skin or repeated contact with intact skin may result in poisoning. 

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

treatment. 

HOTLINE 

For medical emergencies involving this product, call CHEMTREC 1-800-424-9300. 

emergency: Spill, leak, fire, exposure, or accident, call CHEMTREC 1-800-424-9300 

PRECAUTIONARY STATEMENTS 

HAZARDS TO HUMANS AND DOMESTIC ANIMALS 

DANGERIPELIGRO 

POISON 

For chemical 

May be fatal if swallowed. Fatal if inhaled. Do not breathe spray mist. Do not inhale contaminated dust. 

Causes substantial but temporary eye injury. Do not get in eyes or on clothing. A void contact with skin. 

Hannful if absorbed through skin. Wear (goggles, face shield, or safety glasses). 

IMPORT ANT: The effect of swallowing paraquat concentrate is far more severe than that which usually 

results from skin contact or inhalation of contaminated plant dust. This product should not cause injury if 

used according to label instructions. 

When handling or mixing concentrate or when exposure to concentrate is possible, wear: 

2 
• Dust/mist filtering NIOSH approved respirator with any R,P or HE filter 

• Protective clothing (disposable suit/coveralls or long-sleeve shirt and long pants) 

• Full face shield 

• Chemical-resistant gloves (Category A) 

• Chemical resistant apron and shoes plus socks 

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

REMOVE contaminated clothing and wash separately from other laundry before reuse. 

ENVIRONMENTAL HAZARDS 

This product is toxic to wildlife. Do not discharge effluent containing this product into lakes, streams, 

ponds, estuaries, oceans, or public waters unless this product is specifically identified and addressed in a 

National Pollutant Discharge Elimination System (NPDES) permit. Do not discharge effluent containing 

this product to sewer systems without previously notifying the sewage treatment plant authority. For 

guidance, contact your State Water Board or Regional Office of EP A. 

PHYSICAL AND CHEMICAL HAZARD 

This product reacts with aluminum to produce hydrogen gas which may form a highly combustible gas 

mixture. Do not mix or store in containers, tanks, or such systems made of aluminum or having aluminum 

fittings. 

EQUIPMENT/CONTAINER 

Flush all equipment with water after use each day. Paraquat is corrosive to aluminum. Aluminum 

equipment and aluminum structures that are exposed to solution or spillage should be flushed thoroughly 

with water immediately after use. 

SPILLAGE DURING TRANSPORT 

Emergency Action: Notify police and fire departments immediately. For any spill, leak, fire, or 

exposure in the United States, call CHEMTREC 1-800-424-9300. 

KEEP PUBLIC AND ANIMALS away from area. MARK ROADS AND WARN OTHER ROAD 

USERS. WEAR face shield, waterproff gloves, waterproof footwear, and long-sleeve shirt and long pants 

during decontamination operations. 

Clean up spills as soon as possible. Cover spill with generous amount of clay or loam soil to absorb 

liquid, using a stiff broom to ensure intimate contact. Sweep onto shovel and transfer to plastic bag or 

other disposable container. Repeat operations until contaminated surfaces are dry. Finally, hose spill site 

with water, if feasible. 

DIRECTIONS FOR USE 

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

3 
READ ENTIRE LABEL. USE STRICTLY IN ACCORDANCE WITH PRECAUTIONARY 

STATEMENTS AND DIRECTIONS, AND WITH APPLICABLE STATE AND FEDERAL 

REGULATIONS. 

Only for formulation into a herbicide for the following uses: 

TERRESTRIAL FOOD CROP 

Acerola (West Indies cherry), apricot, asparagus, avocado, banana, blackberry, blueberry, boysenberry, 

broccoli, cabbage, Chinese, carrot (including tops), cauliflower, cherry, cocoa, coffee, collards, cucumber, 

eggplant, fig, filbert (hazelnut), garlic, groundcherry (strawberry tomato/tomatillo), guava, hops, 

kiwifruit, lettuce, loquat, macadamia nut (bushnut), manioc (cassava), melons, melons, cantaloupe, 

melons, musk, melons, water, mint, nectarine, olive, onion, papaya, passion fruit, peach, pear, pecan, 

pepino (melonpear), pepper, pepper (chilli type), pineapple, pistachio, plum, potato, 

whitlIrish, prune, pumpkin, raspberry (black, red), rhubarb, small fruits, squash (all or unspecified), 

strawberry, sugar beet, taro, walnut (Englishlblack), yam, yautia. 

TERRESTRIAL FOOD+FEED CROP 

Almond, apple, barley, beans, asparagus, beans, dried-type, beans, mung; beans-succulent (lima); beanssucculent (snap), citrus fruits, corn (unspecified), corn, field, corn, pop, corn, sweet, cotton (unspecified), 

garbanzos (including chickpeas), grapes, guar, hops, legume vegetables, mint, oats, orchards 

(unspecified), peanuts, peanuts (unspecified), soybeans, edible, spearmint, sugar beet, sugar crops, 

sugarcane, sunflower, tomato, turnip, vegetables (unspecified), wheat. 

TERRESTRIAL FEED CROP 

Alfalfa, barley, beans, clover, crownvetch, legume vegetables, lespedeza, lupine, pastures, sainfoin, 

timothy, trefoil, tyfon, vetch, wheat. 

TERRESTRIAL NON-FOOD CROP 

Agricultural fallow/idle land, airports/landing fields, commercial/industrial lawns, 

commercial/institutional/industrial, premises/equipment ( outdoor), fencecrowslhedgerows, grasses grown 

for seed, industrial areas (outdoor), jojoba, nonagricultural outdoor buildings/structures, nonagricultural 

uncultivated areas/soils, ornamental and/or shade trees, peach (non-bearing, seed beds), recreation area 

lawns, tomato (post-harvest)/ wood protection treatment to forest products (seasoned). 

FORESTRY 

Forest planting (reforestation programs), pine (forest/sheiterbelt), shelterbelt plantings. 

TERRESTRIAL NON-FOOD 

Ornamental and/or shade trees, ornamental herbaceous plants, ornamental woody shrubs and vines, noncrop areas such as public airports, electric transformer stations and around commercial buildings. 

OTHERS 

Uses for which USEPA has accepted the required data and/or citations of data that the formulator has 

submitted in support of registration; and uses for experimental purposes that are in compliance with 

USEPA requirements. 

STORAGE AND DISPOSAL 

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

PESTICIDE STORAGE; Sotre ate temperatures above 32° F. Do not contaminate food, foodstuffs, or 

4 
drinking 

Water. Do not store next to feed or food, or transport in or on vehicles containing foodstuffs or feeds. For 

help with any spill, leak, fire or exposure involving this material call CHEMTREC 1-800-424-9300. 

PESTICIDE DISPOSAL; Pesticide wastes are acutly hazardous. Improper disposal of excess pesticide 

or rinsate is a violation of Federal law. If these wastes cannot be disposed of by use according to label 

instructions, contact your State Pesticide or Enviromental Control Agency, or the Hazardous Waste 

representative at the nearest EPA Regional Office for guidance. 

CONTAINER DISPOSAL: Triple rinse (or equivalent). Offer for recycling or recondition, or puncture 

and dispose of in a sanitary landfill, or dispose of by other procedures allowed by State and local 

authorities. 

CONDITIONS OF SALE 

AND LIMITATION OF WARRANTY AND LIABILITY 

NOTICE: Read the entire Directions for Use and Conditions of Sale and Limitation of Warranty and 

Liability before buying or using this product. If the terms are not acceptable, return the product at once, . 

unopened, and the purchase price will be refunded. 

The Directions for Use of this product should be followed carefully. It is impossible to eliminate all risks 

inherently associated with the use of this product. Crop injury, ineffectiveness or other unintended 

consequences may result because of such factors as manner of use or application, weather or crop 

conditions, presence of other materials or other influencing factors in the use of the product, which are 

beyond the control of Helm Agro US, Inc. or Seller. All such risks shall be assumed by Buyer and User, 

and Buyer and User agree to hold Helm and Seller harmless for any claims relating to such factors. 

Helm warrants that this product conforms to the chemical description on the label and is reasonably fit for 

the purposes stated in the Directions for Use, subject to the inherent risks referred to above, when used in 

accordance with directions under normal use conditions. This warranty does not extend to the use of this 

product contrary to label instructions, or under abnormal conditions or under conditions not reasonably 

foreseeable to or beyond the control of Seller or Helm, and Buyer and User assume the risk of any such 

use. HELM MAKES NO WARRANTIES OF MERCHANTABILITY OR OF FITNESS FOR A 

PARTICULAR PURPOSE NOR ANY OTHER EXPRESS OR IMPLIED WARRANTY EXCEPT 

AS STATED ABOVE. 

In no event shall Helm or Seller be liable for any incidental, consequential or special damages resulting 

from the use or handling of this product. THE EXCLUSIVE REMEDY OF THE USER OR BUYER, 

AND THE EXCLUSIVE LIABILITY OF HELM AND SELLER FOR ANY AND ALL CLAIMS, 

LOSSES, INJURIES OR DAMAGES (INCLUDING CLAIMS BASED ON BREACH OF 

WARRANTY, CONTRACT, NEGLIGENCE, TORT, STRICT LIABILITY OR OTHERWISE) 

RESULTING FROM THE USE OR HANDLING OF TIDS PRODUCT, SHALL BE THE 

RETURN OF THE PURCHASE PRICE OF THE PRODUCT OR, AT THE ELECTION OF 

HELM OR SELLER, THE REPLACEMENT OF THE PRODUCT. 

Helm and Seller offer this product, and Buyer and User accept it, subject to the foregoing conditions of 

sale and limitations of warranty and of liability, which may not be modified except by written agreement 

signed by a duly authorized representative of Helm. 

5 
Paraquat TC 

(Technical Concentrate) 

For Fonnulation of Paraquat Herbicide Products Only 

ACTIVE INGREDIENT 

Paraquat dichloride (l, l' -demethyl, 4,4' -bipyridinium dichloride) 

INERT INGREDIENTS 

Contains 3 pounds paraquat cation per gallon. 

Contains emetic. 

EPA Reg. No. 74530-xx 

EPA Establishment No. 

KEEP OUT OF REACH OF CHILDREN 

DANGERIPELIGRO 

POISON 

43.8% 

56.2% 

100.0% 

Si usted no entiende la etiqueta, busque a alguien para que se la explique a usted en detalle. (If you do not 

understand the label, find someone to explain it to you in detail). 

• NEVER PUT INTO FOOD, DRINK OR OTHER CONT AlNERS 

• IF SWALLOWED, TAKE IMMEDIATE ACTION AS PRESCRIBED IN FIRST AID 

STATEMENT. SYMPTOMS ARE PROLONGED AND PAINFUL. 

Net Contents: 

HELM AGRO Inc. 

8295 Tournament Drive 

Memphis, TN, 38125 

info@helmagro.com 

1 

; ) l~ 

DRAFT submitted to EF A: 04-50-200'8 
FIRST AID 

If swallowed • Speed is essential. Immediate attention is required. If available, 

Give an adsorbent such as activated charcoal, bentonite or Fuller's 

Earth. 

• Call a poison control center or doctor immediately for treatment. 

• 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 to 20 

mins. Remove contact lenses, if present, after the first 5 minutes, then 

continue rinsing eye. 

• Call a poison control center or doctor for treatment advice. 

If on skin or clothing • Take off contaminated clothing. 

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

• Call poison control center or doctor for treatment advice. 

If inhaled • Move person to fresh air. 

• If person is not breathing, call 911 or an ambulance. 

• Call a poison control center or doctor for further treatment advice. 

NOTE TO PHYSICIAN 

Administer either activated charcoal (lOOg for adults or 2g1kg body weight in children) or Fuller's 

Earth (15% solution: 1 liter for adults or ISmglkg body wight in children(. 

NOTe: The use of gastric lavage without administration of an adsorbent has not shown any clinical 

benefit. Do not use supplemental oxygen. Eye splashesfrom concentrated material should be treated by 

an eye specialist after initial treatment. With the possibility of late onset corneal ulceration, it is advised 

that patients with paraquat eye injuries are reviewed by an eye specialist the day after first presentation. 

Use treatment that is appropriate for chemical burns. Intact skin is an effective barrier to paraquat, 

however contact with irritated or cut skin or repeated contact with intact skin may result in poisoning . 

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

treatment. 

HOTLINE 

For medical emergencies involving this product, call CHEMTREC 1-800-424-9300. 

emergency: Spill, leak, fire, exposure, or accident, call CHEMTREC 1-800-424-9300 

PRECAUTIONARY STATEMENTS 

HAZARDS TO HUMANS AND DOMESTIC ANIMALS 

DANGERIPELIGRO 

POISON 

For chemical 

May be fatal if swallowed. Fatal if inhaled. Do not breathe spray mist. Do not inhale contaminated dust. 

Causes substantial but temporary eye injury. Do not get in eyes or on clothing. Avoid contact with skin. 

Harmful if absorbed through skin. Wear (goggles, face shield, or safety glasses). 

IMPORTANT: The effect of swallowing paraquat concentrate is far more severe than that which usually 

results from skin contact or inhalation of contaminated plant dust. This product should not cause injury if 

used according to label instructions. 

When handling or mixing concentrate or when exposure to concentrate is possible, wear: 

2 
• Dust/mist filtering NIOSH approved respirator with any R,P or HE filter 

• Protective clothing (disposable suit/coveralls or long-sleeve shirt and long pants) 

• Full face shield 

• Chemical-resistant gloves (Category A) 

• Chemical resistant apron and shoes plus socks 

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

REMOVE contaminated clothing and wash separately from other laundry before reuse. 

ENVIRONMENTAL HAZARDS 

This product is toxic to wildlife. Do not discharge effluent containing this product into lakes, streams, 

ponds, estuaries, oceans, or public waters unless this product is specifically identified and addressed in a 

National Pollutant Discharge Elimination System (NPDES) permit. Do not discharge effluent containing 

this product to sewer systems without previously notifying the sewage treatment plant authority. For 

guidance, contact your State Water Board or Regional Office of EPA. 

PHYSICAL AND CHEMICAL HAZARD 

This product reacts with aluminum to produce hydrogen gas which may form a highly combustible gas 

mixture. Do not mix or store in containers, tanks, or such systems made of aluminum or having aluminum 

fittings. 

EQUIPMENT/CONTAINER 

Flush all equipment with water after use each day. Paraquat is corrosive to aluminum. Aluminum 

equipment and aluminum structures that are exposed to solution or spillage should be flushed thoroughly 

with water immediately after use. 

SPILLAGE DURING TRANSPORT 

Emergency Action: Notify police and fire departments immediately. For any spill, leak, fire, or 

exposure in the United States, call CHEMTREC 1-800-424-9300. 

KEEP PUBLIC AND ANIMALS away from area. MARK ROADS AND WARN OTHER ROAD 

USERS. WEAR face shield, waterproff gloves, waterproof footwear, and long-sleeve shirt and long pants 

during decontamination operations. 

Clean up spills as soon as possible. Cover spill with generous amount of clay or loam soil to absorb 

liquid, using a stiff broom to ensure intimate contact. Sweep onto shovel and transfer to plastic bag or 

other disposable container. Repeat operations until contaminated surfaces are dry. Finally, hose spill site 

with water, iffeasible. 

DIRECTIONS FOR USE 

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

3 
READ ENTIRE LABEL. USE STRICTLY IN ACCORDANCE WITH PRECAUTIONARY 

STATEMENTS AND DIRECTIONS, AND WITH APPLICABLE STATE AND FEDERAL 

REGULATIONS. 

Only for formulation into a herbicide for the following uses: 

TERRESTRIAL FOOD CROP 

Acerola (West Indies cherry), apricot, asparagus, avocado, banana, blackberry, blueberry, boysenberry, 

broccoli, cabbage, Chinese, carrot (including tops), cauliflower, cherry, cocoa, coffee, collards, cucumber, 

eggplant, fig, filbert (hazelnut), garlic, groundcherry (strawberry tomato/tomatillo), guava, hops, 

kiwifruit, lettuce, loquat, macadamia nut (bush nut), manioc (cassava), melons, melons, cantaloupe, 

melons, musk, melons, water, mint, nectarine, olive, onion, papaya, passion fruit, peach, pear, pecan, 

pepino (melonpear), pepper, pepper (chilli type), pineapple, pistachio, plum, potato, 

whitllrish, prune, pumpkin, raspberry (black, red), rhubarb, small fruits, squash (all or unspecified), 

strawberry, sugar beet, taro, walnut (Englishlblack), yam, yautia. 

TERRESTRIAL FOOD+FEED CROP 

Almond, apple, barley, beans, asparagus, beans, dried-type, beans, mung; beans-succulent (lima); beanssucculent (snap), citrus fruits, corn (unspecified), corn, field, corn, pop, corn, sweet, cotton (unspecified), 

garbanzos (including chickpeas), grapes, guar, hops, legume vegetables, mint, oats, orchards 

(unspecified), peanuts, peanuts (unspecified), soybeans, edible, spearmint, sugar beet, sugar crops, 

sugarcane, sunflower, tomato, turnip, vegetables (unspecified), wheat. 

TERRESTRIAL FEED CROP 

Alfalfa, barley, beans, clover, crownvetch, legume vegetables, lespedeza, lupine, pastures, sainfoin, 

timothy, trefoil, tyfon, vetch, wheat. 

TERRESTRIAL NON-FOOD CROP 

Agricultural fallow/idleland, airportsllanding fields, commercial/industrial lawns, 

commercial/institutional/industrial, premises/equipment (outdoor), fencecrowslhedgerows, grasses grown 

for seed, industrial areas (outdoor), jojoba, nonagricultural outdoor bUildings/structures, nonagricultural 

uncultivated areas/soils, ornamental and/or shade trees, peach (non-bearing, seed beds), recreation area 

lawns, tomato (post-harvest)/ wood protection treatment to forest products (seasoned). 

FORESTRY 

Forest planting (reforestation programs), pine (forestlshelterbelt), shelterbelt plantings. 

TERRESTRIAL NON-FOOD 

Ornamental and/or shade trees, ornamental herbaceous plants, ornamental woody shrubs and vines, noncrop areas such as public airports, electric transformer stations and around commercial buildings. 

OTHERS 

Uses for which USEPA has accepted the required data and/or citations of data that the formulator has 

submitted in support of registration; and uses for experimental purposes that are in compliance with 

USEPA requirements. 

STORAGE AND DISPOSAL 

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

PESTICIDE STORAGE; Sotre ate temperatures above 32' F. Do not contaminate food, foodstuffs, or 

4 
drinking 

Water. Do not store next to feed or food, or transport in or on vehicles containing foodstuffs or feeds. For 

help with any spill, leak, fire or exposure involving this material call CHEMTREC 1-800-424-9300. 

PESTICIDE DISPOSAL; Pesticide wastes are acutly hazardous. Improper disposal of excess pesticide 

or rinsate is a violation of Federal law. If these wastes cannot be disposed of by use according to label 

instructions, contact your State Pesticide or Enviromental Control Agency, or the Hazardous Waste 

representative at the nearest EPA Regional Office for guidance. 

'I' CONTAINER DISPOSAL: Triple rinse (or equivalent). Offer for recycling or recondition, or puncture 

and dispose of in a sanitary landfill, or dispose of by other procedures allowed by State and local 

, authorities. 

CONDITIONS OF SALE 

AND LIMITATION OF WARRANTY AND LIABILITY 

NOTICE: Read the entire Directions for Use and Conditions of Sale and Limitation of Warranty and 

Liability before buying or using this product. If the terms are not acceptable, return the product at once, 

unopened, and the purchase price will be refunded. 

The Directions for Use of this product should be followed carefully. It is impossible to eliminate all risks 

inherently associated with the use of this product. Crop injury, ineffectiveness or other unintended 

consequences may result because of such factors as manner of use or application, weather or crop 

conditions, presence of other materials or other influencing factors in the use of the product, which are 

beyond the control of Helm Agro US, Inc. or Seller. All such risks shall be assumed by Buyer and User, 

and Buyer and User agree to hold Helm and Seller harmless for any claims relating to such factors. 

Helm warrants that this product conforms to the chemical description on the label and is reasonably fit for 

the purposes stated in the Directions for Use, subject to the inherent risks referred to above, when used in 

accordance with directions under normal use conditions. This warranty does not extend to the use of this 

product contrary to label instructions, or under abnormal conditions or under conditions not reasonably 

foreseeable to or beyond the control of Seller or Helm, and Buyer and User assume the risk of any such 

use. HELM MAKES NO WARRANTIES OF MERCHANTABILITY OR OF FITNESS FOR A 

PARTICULAR PURPOSE NOR ANY OTHER EXPRESS OR IMPLIED WARRANTY EXCEPT 

AS STATED ABOVE. 

In no event shall Helm or Seller be liable for any incidental, consequential or special damages resulting 

from the use or handling of this product. THE EXCLUSIVE REMEDY OF THE USER OR BUYER, 

AND THE EXCLUSIVE LIABILITY OF HELM AND SELLER FOR ANY AND ALL CLAIMS, 

LOSSES, INJURIES OR DAMAGES (INCLUDING CLAIMS BASED ON BREACH OF 

WARRANTY, CONTRACT, NEGLIGENCE, TORT, STRICT LIABILITY OR OTHERWISE) 

RESULTING FROM THE USE OR HANDLING OF TIDS PRODUCT, SHALL BE THE 

RETURN OF THE PURCHASE PRICE OF THE PRODUCT OR, AT THE ELECTION OF 

HELM OR SELLER, THE REPLACEMENT OF THE PRODUCT. 

Helm and Seller offer this product, and Buyer and User accept it, subject to the foregoing conditions of 

sale and limitations of warranty and of liability, which may not be modified except by written agreement 

signed by a duly authorized representative of Helm. 

5 
Paraquat TC 

(Technical Concentrate) 

For Fonnulation of Paraquat Herbicide Products Only 

ACTIVE INGREDIENT 

Paraquat dichloride (1,1 '-demethyl, 4,4' -bipyridinium dichloride) 

INERT INGREDIENTS 

TOTAL 

Contains 3 pounds paraquat cation per gallon. 

Contains emetic. 

EPA Reg. No. 74530-xx 

EPA Establishment No. 

KEEP OUT OF REACH OF CHILDREN 

DANGERIPELIGRO 

POISON 

43.8% 

56.2% 

100.0% 

Si usted no entiende la etiqueta, busque a alguien para que se la explique a usted en detalle. (If you do not 

understand the label, find someone to explain it to you in detail). 

• NEVER PUT INTO FOOD, DRINK OR OTHER CONTAINERS 

• IF SWALLOWED, TAKE lMMEDIA TE ACTION AS PRESCRIBED IN FIRST AID 

STATEMENT. SYMPTOMS ARE PROLONGED AND PAINFUL. 

Net Contents: 

HELM AGRO Inc. 

8295 Tournament Drive 

Memphis, TN, 38125 

info@helmagro.com 

1 

) 

DRAFT submitted to ¥:PA,: 04-30-2008 , 
FIRST AID 

If swallowed • Speed is essential. Immediate attention is required. If available, 

Give an adsorbent such as activated charcoal, bentonite or Fuller's 

Earth. 

• Call a poison control center or doctor immediately for treatment. 

• 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 to 20 

mins. Remove contact lenses, if present, after the first 5 minutes, then 

continue rinsing eye. 

• Call a poison control center or doctor for treatment advice. 

If on skin or clothing • Take off contaminated clothing. 

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

• Call poison control center or doctor for treatment advice. 

If inhaled • Move person to fresh air. 

• If person is not breathing, call 911 or an ambulance. 

• Call a poison control center or doctor for further treatment advice. 

NOTE TO PHYSICIAN 

Administer either activated charcoal (100g for adults or 2g1kg body weight in children) or Fuller's 

Earth (15% solution: I liter for adults or 15mg/kg body wight in children(. 

NOTe: The use of gastric lavage without administration of an adsorbent has not shown any clinical 

benefit. Do not use supplemental oxygen. Eye splashesfrom concentrated material should be treated by 

an eye specialist after initial treatment. With the possibility of late onset corneal ulceration, it is advised 

that patients with paraquat eye injuries are reviewed by an eye specialist the day after first presentation . 

• Use treatment that is appropriate for chemical bums. Intact skin is an effective barrier to paraquat, 

however contact with irritated or cut skin or repeated contact with intact skin may result in poisoning. 

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

treatment. 

HOTLINE 

For medical emergencies involving this product, call CHEMTREC 1-800-424-9300. For chemical 

emergency: Spill, leak, fire, exposure, or accident, call CHEMTREC 1-800-424-9300 

PRECAUTIONARY STATEMENTS 

HAZARDS TO HUMANS AND DOMESTIC ANIMALS 

DANGERIPELIGRO 

POISON 

May be fatal if swallowed. Fatal if inhaled. Do not breathe spray mist. Do not inhale contaminated dust. 

Causes substantial but temporary eye injury. Do not get in eyes or on clothing. Avoid contact with skin. 

Harmful if absorbed through skin. Wear (goggles, face shield, or safety glasses). 

IMPORTANT: The effect of swallowing paraquat concentrate is far more severe than that which usually 

results from skin contact or inhalation of contaminated plant dust. This product should not cause injury if 

used according to label instructions. 

When handling or mixing concentrate or when exposure to concentrate is possible, wear: 

2 
• Dust/mist filtering NIOSH approved respirator with any R,P or HE filter 

• Protective clothing (disposable suit/coveralls or long-sleeve shirt and long pants) 

• Full face shield 

• Chemical-resistant gloves (Category A) 

• Chemical resistant apron and shoes plus socks 

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

REMOVE contaminated clothing and wash separately from other laundry before reuse. 

ENVIRONMENTAL HAZARDS 

This product is toxic to wildlife. Do not discharge effluent containing this product into lakes, streams, 

ponds, estuaries, oceans, or public waters unless this product is specifically identified and addressed in a 

National Pollutant Discharge Elimination System (NPDES) permit. Do not discharge effluent containing 

this product to sewer systems without previously notifying the sewage treatment plant authority. For 

guidance, contact your State Water Board or Regional Office of EPA. 

PHYSICAL AND CHEMICAL HAZARD 

This product reacts with aluminum to produce hydrogen gas which may form a highly combustible gas 

mixture. Do not mix or store in containers, tanks, or such systems made of aluminum or having aluminum 

fittings. 

EQUIPMENT/CONTAINER 

Flush all equipment with water after use each day. Paraquat is corrosive to aluminum. Aluminum 

equipment and aluminum structures that are exposed to solution or spillage should be flushed thoroughly 

with water immediately after use. 

SPILLAGE DURING TRANSPORT 

Emergency Action: Notify police and fire departments immediately. For any spill, leak, fire, or 

exposure in the United States, call CHEMTREC 1-800-424-9300. 

KEEP PUBLIC AND ANIMALS away from area. MARK ROADS AND WARN OTHER ROAD 

USERS. WEAR face shield, waterproff gloves, waterproof footwear, and long-sleeve shirt and long pants 

during decontamination operations. 

Clean up spills as soon as possible. Cover spill with generous amount of clay or loam soil to absorb 

liquid, using a stiff broom to ensure intimate contact. Sweep onto shovel and transfer to plastic bag or 

other disposable container. Repeat operations until contaminated surfaces are dry. Finally, hose spill site 

with water, if feasible. 

DIRECTIONS FOR USE 

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

( 

3 
READ ENTIRE LABEL. USE STRICTLY IN ACCORDANCE WITH PRECAUTIONARY 

STATEMENTS AND DIRECTIONS, AND WITH APPLICABLE STATE AND FEDERAL 

REGULATIONS. 

Only for formulation into a herbicide for the following uses: 

TERRESTRIAL FOOD CROP 

Acerola (West Indies cherry), apricot, asparagus, avocado, banana, blackberry, blueberry, boysenberry, 

broccoli, cabbage, Chinese, carrot (including tops), cauliflower, cherry, cocoa, coffee, collards, cucumber, 

eggplant, fig, filbert (hazelnut), garlic, groundcherry (strawberry tomato/tomatillo), guava, hops, 

kiwifruit, lettuce, loquat, macadamia nut (bushnut), manioc (cassava), melons, melons, cantaloupe, 

melons, musk, melons, water, mint, nectarine, olive, onion, papaya, passion fruit, peach, pear, pecan, 

pepino (melonpear), pepper, pepper (chilli type), pineapple, pistachio, plum, potato, 

whitlIrish, prune, pumpkin, raspberry (black, red), rhubarb, small fruits, squash (all or unspecified), 

strawberry, sugar beet, taro, walnut (Englishlblack), yam, yautia. 

TERRESTRIAL FOOD+FEED CROP 

Almond, apple, barley, beans, asparagus, beans, dried-type, beans, mung; beans-succulent (lima); beanssucculent (snap), citrus fruits, corn (unspecified), corn, field, corn, pop, corn, sweet, cotton (unspecified), 

garbanzos (including chickpeas), grapes, guar, hops, legume vegetables, mint, oats, orchards 

(unspecified), peanuts, peanuts (unspecified), soybeans, edible, spearmint, sugar beet, sugar crops, 

sugarcane, sunflower, tomato, turnip, vegetables (unspecified), wheat. 

TERRESTRIAL FEED CROP 

Alfalfa, barley, beans, clover, crownvetch, legume vegetables, lespedeza, lupine, pastures, sainfoin, 

timothy, trefoil, tyfon, vetch, wheat. 

TERRESTRIAL NON-FOOD CROP 

Agricultural fallow/idleland, airportsllanding fields, commercial/industrial lawns, 

commercial/institutional/industrial, premises! equipment ( outdoor), fencecrowslhedgerows, grasses grown 

for seed, industrial areas (outdoor), jojoba, nonagricultural outdoor buildings/structures, nonagricultural 

uncultivated areas/soils, ornamental and/or shade trees, peach (non-bearing, seed beds), recreation area 

lawns, tomato (post-harvest)/ wood protection treatment to forest products (seasoned). 

FORESTRY 

Forest planting (reforestation programs), pine (forest/shelterbelt), shelterbelt plantings. 

TERRESTRIAL NON-FOOD 

Ornamental and/or shade trees, ornamental herbaceous plants, ornamental woody shrubs and vines, noncrop areas such as public airports, electric transformer stations and around commercial buildings. 

OTHERS 

Uses for which USEPA has accepted the required data and/or citations of data that the formulator has 

submitted in support of registration; and uses for experimental purposes that are in compliance with 

USEP A requirements. 

STORAGE AND DISPOSAL 

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

PESTICIDE STORAGE; Sotre ate temperatures above 32' F. Do not contaminate food, foodstuffs, or 

4 
drinking 

Water. Do not store next to feed or food, or transport in or on vehicles containing foodstuffs or feeds. For 

help with any spill, leak, fire or exposure involving this material call CHEMTREC 1-800-424-9300. 

PESTICIDE DISPOSAL; Pesticide wastes are acutly hazardous. Improper disposal of excess pesticide 

or rinsate is a violation of Federal law. If these wastes cannot be disposed of by use according to label 

instructions, contact your State Pesticide or Enviromental Control Agency, or the Hazardous Waste 

representative at the nearest EPA Regional Office for guidance. 

CONTAINER DISPOSAL: Triple rinse (or equivalent). Offer for recycling or recondition, or puncture 

and dispose of in a sanitary landfill, or dispose of by other procedures allowed by State and local 

authorities. 

CONDITIONS OF SALE 

AND LIMITATION OF WARRANTY AND LIABILITY 

NOTICE: Read the entire Directions for Use and Conditions of Sale and Limitation of Warranty and 

Liability before buying or using this product. lfthe tenns are not acceptable, return the product at once, 

unopened, and the purchase price will be refunded. 

The Directions for Use of this product should be followed carefully. It is impossible to eliminate all risks 

inherently associated with the use of this product. Crop injury, ineffectiveness or other unintended 

consequences may result because of such factors as manner of use or application, weather or crop 

conditions, presence of other materials or other influencing factors in the use of the product, which are 

beyond the control of Helm Agro US, Inc. or Seller. All such risks shall be assumed by Buyer and User, 

and Buyer and User agree to hold Helm and Seller harmless for any claims relating to such factors. 

Helm warrants that this product confonns to the chemical description on the label and is reasonably fit for 

the purposes stated in the Directions for Use, subject to the inherent risks referred.to above, when used in 

accordance with directions under nonnal use conditions. This warranty does not extend to the use of this 

product contrary to label instructions, or under abnonnal conditions or under conditions not reasonably 

foreseeable to or beyond the control of Seller or Helm, and Buyer and User assume the risk of any such 

use. HELM MAKES NO WARRANTIES OF MERCHANTABILITY OR OF FITNESS FOR A 

PARTICULAR PURPOSE NOR ANY OTHER EXPRESS OR IMPLIED WARRANTY EXCEPT 

AS STATED ABOVE. 

In no event shall Helm or Seller be liable for any incidental, consequential or special damages reSUlting 

from the use or handling of this product. THE EXCLUSIVE REMEDY OF THE USER OR BUYER, 

AND THE EXCLUSIVE LIABILITY OF HELM AND SELLER FOR ANY AND ALL CLAIMS, 

LOSSES, INJURIES OR DAMAGES (INCLUDING CLAIMS BASED ON BREACH OF 

WARRANTY, CONTRACT, NEGLIGENCE, TORT, STRICT LIABILITY OR OTHERWISE) 

RESULTING FROM THE USE OR HANDLING OF TIDS PRODUCT, SHALL BE THE 

RETURN OF THE PURCHASE PRICE OF THE PRODUCT OR, AT THE ELECTION OF 

HELM OR SELLER, THE REPLACEMENT OF THE PRODUCT. 

Helm and Seller offer this product, and Buyer and User accept it, subject to the foregoing conditions of 

sale and limitations of warranty and of liability, which may not be modified except by written agreement 

signed by a duly authorized representative of Helm. 

5 
Paraquat TC 

(Technical Concentrate) 

For Fonnulation of Paraquat Herbicide Products Only 

ACTIVE INGREDIENT 

Paraquat dichloride (1,1' -demethyl, 4,4' -bipyridinium dichloride) 

INERT INGREDIENTS 

TOTAL 

Contains 3 pounds paraquat cation per gallon. 

Contains emetic. 

EPA Reg. No. 74530-xx 

EPA Establishment No. 

KEEP OUT OF REACH OF CHILDREN 

DANGERIPELIGRO 

POISON 

43.8% 

56.2% 

100.0% 

Si usted no entiende la etiqueta, bus que a alguien para que se la explique a usted en detalle. (If you do not 

understand the label, find someone to explain it to you in detail). 

• NEVER PUT INTO FOOD, DRINK OR OTHER CONTAINERS 

• IF SWALLOWED, TAKE IMMEDIATE ACTION AS PRESCRIBED IN FIRST AID 

STATEMENT. SYMPTOMS ARE PROLONGED AND PAINFUL. 

Net Contents: 

HELM AGRO Inc. 

8295 Tournament Drive 

Memphis, TN, 38125 

info@helmagro.com 

1 

• 1" ) 

, 

DRAFT submitted to EPA: 04-3,Or20P8 
FIRST AID 

If swallowed • Speed is essential. Immediate attention is required. If available, 

Give an adsorbent such as activated charcoal, bentonite or Fuller's 

Earth. 

• Call a poison control center or doctor immediately for treatment. 

• 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 to 20 

mins. Remove contact lenses, if present, after the first 5 minutes, then 

continue rinsing eye. 

• Call a poison control center or doctor for treatment advice. 

If on skin or clothing • Take off contaminated clothing. 

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

• Call poison control center or doctor for treatment advice. 

If inhaled • Move person to fresh air. 

• If person is not breathing, call 911 or an ambulance. 

• Call a poison control center or doctor for further treatment advice. 

NOTE TO PHYSICIAN 

Administer either activated charcoal (lOOg for adults or 2g1kg body weight in children) or Fuller's 

Earth (15% solution: 1 liter for adults or 15mglkg body wight in children(. 

NOTe: The use of gastric lavage without administration of an adsorbent has not shown any clinical 

benefit. Do not use supplemental oxygen. Eye splashes from concentrated material should be treated by 

an eye specialist after initial treatment. With the possibility of late onset corneal ulceration, it is advised 

that patients with paraquat eye injuries are reviewed by an eye specialist the day after first presentation. 

Use treatment that is appropriate for chemical burns. Intact skin is an effective barrier to paraquat, 

however contact with irritated or cut skin or repeated contact with intact skin may result in poisoning. 

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

, treatment. 

HOTLINE 

For medical emergencies involving this product, call CHEMTREC 1-800-424-9300. For chemical 

i emergency: Spill, leak, fire, exposure, or accident, call CHEMTREC 1-800-424-9300 

PRECAUTIONARY STATEMENTS 

HAZARDS TO HUMANS AND DOMESTIC ANIMALS 

DANGERIPELIGRO 

POISON 

May be fatal if swallowed. Fatal if inhaled. Do not breathe spray mist. Do not inhale contaminated dust. 

Causes substantial but temporary eye injury. Do not get in eyes or on clothing. Avoid contact with skin. 

Harmful if absorbed through skin. Wear (goggles, face shield, or safety glasses). 

IMPORTANT: The effect of swallowing paraquat concentrate is far more severe than that which usually 

results from skin contact or inhalation of contaminated plant dust. This product should not cause injury if 

used according to label instructions. 

When handling or mixing concentrate or when exposure to concentrate is possible, wear: 

2 
• Dust/mist filtering NIOSH approved respirator with any R,P or HE filter 

• Protective clothing (disposable suit/coveralls or long-sleeve shirt and long pants) 

• Full face shield 

• Chemical-resistant gloves (Category A) 

• Chemical resistant apron and shoes plus socks 

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

REMOVE contaminated clothing and wash separately from other laundry before reuse. 

ENVIRONMENTAL HAZARDS 

This product is toxic to wildlife. Do not discharge effluent containing this product into lakes, streams, 

ponds, estuaries, oceans, or public waters unless this product is specifically identified and addressed in a 

National Pollutant Discharge Elimination System (NPDES) permit. Do not discharge effluent containing 

this product to sewer systems without previously notifying the sewage treatment plant authority. For 

guidance, contact your State Water Board or Regional Office of EPA. 

PHYSICAL AND CHEMICAL HAZARD 

This product reacts with aluminum to produce hydrogen gas which may form a highly combustible gas 

mixture. Do not mix or store in containers, tanks, or such systems made of aluminum or having aluminum 

fittings. 

EQUIPMENT/CONTAINER 

Flush all equipment with water after use each day. Paraquat is corrosive to aluminum. Aluminum 

equipment and aluminum structures that are exposed to solution or spillage should be flushed thoroughly 

with water immediately after use. 

SPILLAGE DURING TRANSPORT 

Emergency Action: Notify police and fITe departments immediately. For any spill, leak, fire, or 

exposure in the United States, call CHEMTREC 1-800-424-9300. 

KEEP PUBLIC AND ANIMALS away from area. MARK. ROADS AND WARN OTHER ROAD 

USERS. WEAR face shield, waterproff gloves, waterproof footwear, and long-sleeve shirt and long pants 

during decontamination operations. 

Clean up spills as soon as possible. Cover spill with generous amount of clay or loam soil to absorb 

liquid, using a stiff broom to ensure intimate contact. Sweep onto shovel and transfer to plastic bag or 

other disposable container. Repeat operations until contaminated surfaces are dry. Finally, hose spill site 

with water, if feasible. 

DIRECTIONS FOR USE 

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

3 
READ ENTIRE LABEL. USE STRICTLY IN ACCORDANCE WITH PRECAUTIONARY 

STATEMENTS AND DIRECTIONS, AND WITH APPLICABLE STATE AND FEDERAL 

REGULATIONS. 

Only for formulation into a herbicide for the following uses: 

TERRESTRIAL FOOD CROP 

Acerola (West Indies cherry), apricot, asparagus, avocado, banana, blackberry, blueberry, boysenberry, 

broccoli, cabbage, Chinese, carrot (including tops), cauliflower, cherry, cocoa, coffee, collards, cucumber, 

eggplant, fig, filbert (hazelnut), garlic, groundcherry (strawberry tomato/tomatillo), guava, hops, 

kiwifruit, lettuce, loquat, macadamia nut (bushnut), manioc (cassava), melons, melons, cantaloupe, 

melons, musk, melons, water, mint, nectarine, olive, onion, papaya, passion fruit, peach, pear, pecan, 

pepino (melonpear), pepper, pepper (chilli type), pineapple, pistachio, plum, potato, 

whitJIrish, prune, pumpkin, raspberry (black, red), rhubarb, small fruits, squash (all or unspecified), 

strawberry, sugar beet, taro, walnut (Englishlblack), yam, yautia. 

TERRESTRIAL FOOD+FEED CROP 

Almond, apple, barley, beans, asparagus, beans, dried~type, beans, mung; beans~succulent (lima); beans~ 

succulent (snap), citrus fruits, com (unspecified), com, field, com, pop, com, sweet, cotton (unspecified), 

garbanzos (including chickpeas), grapes, guar, hops, legume vegetables, mint, oats, orchards 

(unspecified), peanuts, peanuts (unspecified), soybeans, edible, spearmint, sugar beet, sugar crops, 

sugarcane, sunflower, tomato, turnip, vegetables (unspecified), wheat. 

TERRESTRIAL FEED CROP 

Alfalfa, barley, beans, clover, crown vetch, legume vegetables, lespedeza, lupine, pastures, sainfoin, 

timothy, trefoil, tyfon, vetch, wheat. 

TERRESTRIAL NON-FOOD CROP 

Agricultural fallow/idle land, airports/landing fields, commercial/industrial lawns, 

commercial/institutional/industrial, premises/equipment ( outdoor), fencecrowslhedgerows, grasses grown 

for seed, industrial areas (outdoor), jojoba, nonagricultural outdoor buildings/structures, nonagricultural 

uncultivated areaS/soils, ornamental and/or shade trees, peach (non-bearing, seed beds), recreation area 

lawns, tomato (post-harvest)/ wood protection treatment to forest products (seasoned). 

FORESTRY 

Forest planting (reforestation programs), pine (forestlshelterbelt), shelterbelt plantings. 

TERRESTRIAL NON-FOOD 

Ornamental and/or shade trees, ornamental herbaceous plants, ornamental woody shrubs and vines, non~ 

crop areas such as public airports, electric transformer stations and around commercial buildings. 

OTHERS 

Uses for which USEPA has accepted the required data and/or citations of data that the formulator has 

submitted in support of registration; and uses for experimental purposes that are in compliance with 

USEP A requirements. 

STORAGE AND DISPOSAL 

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

PESTICIDE STORAGE; Sotre ate temperatures above 32" F. Do not contaminate food, foodstuffs, or . 

4 
drinking 

Water. Do not store next to feed or food, or transport in or on vehicles containing foodstuffs or feeds. For 

help with any spill, leak, ftre or exposure involving this material call CHEMTREC 1-800-424-9300. 

PESTICIDE DISPOSAL; Pesticide wastes are acutly hazardous. Improper disposal of excess pesticide 

or rinsate is a violation of Federal law. If these wastes cannot be disposed of by use according to label 

instructions, contact your State Pesticide or Enviromental Control Agency, or the Hazardous Waste 

representative at the nearest EPA Regional Office for guidance. ' 

CONTAINER DISPOSAL: Triple rinse (or equivalent). Offer for recycling or recondition, or puncture 

and dispose of in a sanitary landftll, or dispose of by other procedures allowed by State and local 

authorities. 

CONDITIONS OF SALE 

AND LIMITATION OF WARRANTY AND LIABILITY 

NOTICE: Read the entire Directions for Use and Conditions of Sale and Limitation of Warranty an4 

Liability before buying or using this product. If the terms are not acceptable, return the product at once, 

unopened, and the purchase price will be refunded. 

The Directions for Use of this product should be followed carefully. It is impossible to eliminate all risks 

inherently associated with the use of this product. Crop injury, ineffectiveness or other unintended 

consequences may result because of such factors as manner of use or application, weather or crop 

conditions, presence of other materials or other influencing factors in the use of the product, which are 

beyond the control of Helm Agro US, Inc. or Seller. All such risks shall be assumed by Buyer and User, 

and Buyer and User agree to hold Helm and Seller harmless for any claims relating to such factors. 

Helm warrants that this product conforms to the chemical description on the label and is reasonably ftt for 

the purposes stated in the Directions for Use, subject to the inherent risks referred to above, when used in 

accordance with directions under normal use conditions. This warranty does not extend to the use of this 

product contrary to label instructions, or under abnormal conditions or under conditions not reasonably 

foreseeable to or beyond the control of Seller or Helm, and Buyer and User assume the risk of any such 

use. HELM MAKES NO WARRANTIES OF MERCHANTABILITY OR OF FITNESS FOR A 

PARTICULAR PURPOSE NOR ANY OTHER EXPRESS OR IMPLIED WARRANTY EXCEPT 

AS STATED ABOVE. 

In no event shall Helm or Seller be liable for any incidental, consequential or special damages reSUlting 

from the use or handling of this product. THE EXCLUSIVE REMEDY OF THE USER OR BUYER, 

AND THE EXCLUSIVE LIABILITY OF HELM AND SELLER FOR ANY AND ALL CLAIMS, 

LOSSES, INJURIES OR DAMAGES (INCLUDING CLAIMS BASED ON BREACH OF 

WARRANTY, CONTRACT, NEGLIGENCE, TORT, STRICT LIABILITY OR OTHERWISE) 

RESULTING FROM THE USE OR HANDLING OF THIS PRODUCT, SHALL BE THE 

RETURN OF THE PURCHASE PRICE OF THE PRODUCT OR, AT THE ELECTION OF 

HELM OR SELLER, THE REPLACEMENT OF THE PRODUCT. 

Helm and Seller offer this product, and Buyer and User accept it, subject to the foregoing conditions of 

sale and limitations of warranty and of liability, which may not be modifted except by written agreement 

signed by a duly authorized representative of Helm. 

5 
EPA stration File 75430-37 

Page not included in this copy. 

Pages 187 through 196 are not included in this copy. 

The material not included contains the following type of 

information: 

x Identity product ingredients. 

Ident of product impurities. 

Description of the product manufacturing process. 

Description of quality control procedures. 

X Identity of the source of product ingredients. 

Sales or other commercial/financial information. 

A draft product label. 

The product confidential statement of formula. 

Information about a pending registration action. 

FIFRA stration data. 

The document is a duplicate of page(s) 

The document is not responsive to the request. 

Internal deliberative information. ~~~-

Attorney-Client work product. 

Claimed Confidential by submitter upon submission to the 

Agency. 

Personal Privacy Information 

The information not included is generally considered confidential 

by product registrants. If you have any questions, please contact 

the individual who prepared the response to your request. 
lOR FORM 9·11 

MARCH 2006) 

~(IDw lID~~~~~ffi~ ~rn ~~~ FILE SYMBOL 

7Jf'r30-&r 

REGISTRATION NO. 

CONFIDENTIAL STATEMENT OF FORMULA ENCLOSED 

DATE SUBMITTED BY (v') 

SUBMITTED APPLICANT BASIC SUPPLIER 

MAY 02 200B --

Do Not Write Comments, 

Formula, or Parts of Formula 

on This Envelope 

NOTE 

It shall be unlawful-for any person to use for his own advantage 

or to reveal, other than to the Secretary, or officials or employees of 

the United States Department of Agriculture or other Federal agencies, 

or to the courts In response to a subpoena, or to phYSicians, and In 

emergencies to pharmacists and other qualified persons, for use in 

the preparation of antidotes, In accordance with such directions as 

the Secretary may prescribe, any Information relative to formulas of 

products acquired by authority of Section 4 of the "Federal InsectiCide, 

fungicide, and Rodenticide Act." 

USDA·ARS 
( 

\ 

.(, 

Q 

=I-

\,....-1 

1.) )::, 

0J 

F";'! 

p, 

o 

4-

:w 

t 

f\J 

/, 

). 

r' ('I 

----

-, 

~: '" 

~, 

r/" 

-r-

;;;, 

~) 

1i 
Electronic Code of Federal Regulations: Page 1 of22 

Home Page> Executive Branch> Gode of Federal Regulations> Electronic Code of Federal Regulations 

lations 

e-CFR Data is current as of May 5, 2008 

Title 40: Protection of Environment 

PART 18Q-TOLERANCES AND EXEMPTIONS FROM TOLERANCES FOR PESTICIDE CHEMICALS 

IN FOOD 

Subpart D-Exemptions From Tolerances 

Browse Previous I Browse Next 

§ 180.910 Inert ingredients used pre- and post-harvest; exemptions 

from the requirement of a tolerance. 

Unk to an amendment published at 71 FR 45421, August 9, 2006. 

Residues of the following materials are exempted from the requirement of a tolerance when used in 

accordance with good agricultural practice as inert (or occasionally active) ingredients in pesticide 

formulations applied to growing crops or to raw agricultural commodities after harvest: 

Inert ingredients Limits Uses 

Acetic acid I Catalyst 

Acetic anhydride ISOlvent, 

.cosolvent 

Acetone I Do. 

Alkanoic and alkenoic acids, mono- Emulsifiers 

and diesters of a-hydro-w-hydroxypoly 

(oxyethylene) with molecular weight 

(in amu) range of 200 to 6,000 

Alkyl (Ca-C24) benzenesulfonic acid Surfactants, 

and its ammonium, calcium, related adjuvants 

magnesium, potassium, sodium, and of surfactants 

zinc salts 

a-Alkyl (C9-C1a-w,-hydroxypoly Solvent, 

(oxyethylene) with poly( oxyethylene) cosolvent, 

content of 2-30 moles surfactant, and 

related adjuvants 

of surfactants 

I I 

I 

I 

I 

http://ecfr.gpoaccess.gov/cgiltltextltext-idx?c=ecfr&sid=al d63 734 f7d3b0312cb51 al b49059... 5/7/2008 
EPA Registration File #75430-37 

Page is not included in this copy. 

Pages 200 through 201 are not included in this copy. 

The material not included contains the following type of 

information: 

X Identity of product inert ingredients. 

Identity of product impurities. 

Description of the product manufacturing process. 

Description of quality control procedures. 

Identity of the source of product ingredients. 

Sales or other commercial/financial information. 

A draft product label. 

The product confidential statement of formula. 

Information about a pending registration action. 

FIFRA registration data. 

The document is a duplicate of page(s) 

The document is not responsive to the request. 

Internal deliberative information. -------

Attorney-Client work product. 

Claimed Confidential by submitter upon submission to the 

Agency. 

Personal Privacy Information 

The information not included is generally considered confidential 

by product registrants, If you have any questions, please contact 

the individual who prepared the response to your request. 
EPA Registration File #75430-37 

Page 202 is not included in this copy. 

Pages through are not included in s copy. 

The material not included contains the following type of 

information: 

Identi of product inert 

ty of product impuri 

Description of the product manufacturing process. 

Des ion of quality control procedures. 

ty of the source of product ingredients. 

s or other commercial/financ information. 

A t product label. 

X The product confidential statement of formula. 

Information about a pending stration action. 

FIFRA registration data. 

document 1S a duplicate page(s) 

document is not respons to the request. 

deliberative informat 

Attorney-Client work product. 

Claimed Confidential by submitter upon submission to the 

Agency. 

Personal Privacy Information 

The information not included is ly considered confident 

by product registrants. If you have any questions, please contact 

the individual who prepared the response to your request.