FedEx

November 6. 2009

Ms. Susan Lewis

Document Processing Desk

Office of Pesticide Programs - 750BP

U.S. Environmental Protection Agency

2777 South Crystal Drive

One Potomac Yard, Room 5A900

Arlington, VA 22202

Dear Ms. Lewis:

FTN 86757596 5933

6?l

" I,-Re!JWest

Comp any, u.c

Subject: Scime trics Ltd. Corporation

EPA Company Number: 72500

Revised gO-Day Response to "Risk Mitigation Decision for Ten Rodenticides"

On beha lf of Scimetrics Ltd. Corp.• RegWest Com pany, LLC is submittinq the attached revised forms in

response to the EPA's "Risk Mitigation Decision for Ten Rodenticides" dated May 28. 2008 and in response to

the EPA's letter dated June 18, 2008. RegWest will act as sale agent in this endeavor.

Attached are the following :

1. Revised gO-Day Response Form for the May 2008 Rodenticide Risk Mitigation Decision (Diphacinone)

2. Revised gO-Day Response Form for the May 2008 Rodenticide Risk Mitigation Decision (Warfarin)

To summarize the revisions:

Diphacinone-containing products form:

We intend to cancel the 72500-10 registration when we file the 20 10 Maintenance fee response'

We have added 72500-18

Warfa rin-containing products form:

We have added 72500-14 and 72500-15

·Scimetrics Ltd. Corporation will waive the typical 180-day comme nt period and opt for the shorter 3D-day

com ment period per FIFRA Section 6, if necessary, bearing in mind that the voluntarily cancellation of EPA

Reg. No. 72500-10 will become effective per the Maintenance Fee cancellation poflcy,

Please contact me at (970) 353-06 11 or kim@regwest.com if you have any questions or require additional

information.

Regards,

RegWest Company, LLC

Kim Davis, CC. APC, Manager

ConsultanVAgent

Attachments

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Revised

90-Day Response Form for the Mav 2008 Rodenticide Risk Mitigation Decision

Comp any Name: Scim etrics ltd. Corporation

Active Ingredient: Dipnacmore (PC Code 067701)

Company Number: 72500

In column I , please list the EPA Registration Number for all products registered to your company that contain the active ingredient identified above. Please mark one box

De(row (columns 2-81 indicatina vour comnanv's intended method for comnMna with the Melli 2008 roaeraciae risk mitioafion decision. Please also comDJete items 9-15.

1 8

Intended Method for Complying with the May 2008 Rodenticide Risk Mitigation Decision

2 3 4 5 6 7 I do notintend to

voluntarily bOng this

2. Product isa 7. I wish to product into

technical grade Of 3. Product is labeled 6. I will submit an voluntarily cancel compliance with the

manufacturing use solely foroutdoor, application on or this product under requirements of the

productthat below-ground 4. Product is labeled 5, Product isa before 12104/2009 FIFRA 6(f) (effective May 2008 risk

currentlycomplies controlofmoles and solelyfor outdoor tracking powder to amend this onorbefore mitigationdecision. I

with the pocket gophers, and field uses, and product, and productto comply 06/041201 1), and a understand that

requirements set therefore the May therefore the May therefore the May with the letter requesting EPA may pursue

EPAProduct forth in the May 2008 risk mitigation 2008 risk mitigation 2008 risk mitigation requirementsof the cencenatoo is additional regulatory

Registration 2008 risk mitigation decision does not decision does not decision does not May 2008 risk included with this acton. induding

Number decision apply. ap~y ap~y mitigation decision. 9O-Dav response. cancellation.

72500-9 X

72500-10 X

72500-11 X

72500-12 X

72500-1 6 X

72500-18 X

9. Certification: r certify that the statements made on this form and all attachments are true, accurate and complete.

10. Sj!ln..tur"! ('f Com;>any's Authorized Representative: 11. Phone Number: 970-353-0611

9ks -- 11/06/2009 12. Email: kim@regwest.com

Date

1:. Frtnted Name of Au:hori ..ed Representative: Kim Davis. CC. APC. Manager 14. Title: Consultant/Agent for Scimetrics ltd. Corporation

15. Nameof Company: RegWest Company, l LC for Scimetrics ltd. Corporation

Please reproduce thIS page if additKHIal l,nes are needed foryour companysresponse.
Revised

gO-Day Response Form for the May 2008 Rodenticide Risk Mitigation Decision

Company Name: Scimetrics Ltd. Corporation

Active Ingredient: Warfa rin (PC Code 086002)

Company Number: 72500

In column 1. please Jist the EPA Registration Number for all products regisJered to your company that contain the active ingredient identified above. Please mark one box

nerrow (columns 2-8)indicatinn lIOlJr comnanv's inlended method for complyinq with th8 May 2008 rodenticide risk mitiqation decision. Please also complete items 9-15.

1 8

Intended Method for Complying with the May 2008 Rodenticide Risk Mitigation Decision

2 3 4 5 8 7 I do notilltend to

voluntarily bring this

2. Product isa 7. I wish to product inlo

technical grade or 3.Product is labeled 6. I will submit an voluntarily cancel compliance with the

manufacturing use solely foroutdoor, application onor this product under requirements of the

productthat below-ground 4. Productis labeled 5. Productisa before 12/04/2009 FIFRA 6(f) (effective May 2008 risk

currentlycomplies control ofmoles and solelyforoutdoor tracking powder to amend this on or before mitigation decision. I

with the pocketgophers, and fielduses, and product,and productto comply 06/04/2011),and a understand that

requirements set therefore the May therefore the May therefore theMay with the letter requesting EPA maypursue

EPAProduct forth in the May 2008risk mitigation 2008 risk mitigation 2008 risk mitigation requirementsof the cancellation is additional regulatory

Registration 2008 risk mitigation decision does not decision does not decision does not May 2008 risk induded withthis action. induding

Number decision apply. aDDlv aDW mitigation decision. 9O-Davresponse. cancellation.

72500-2 X

72500-6 X

72500-7 X

72500-13 X

72500-14 X

72500-15 X

9. Certification: I certify that the statements made on this form and all attachments are true, accurate and complete.

10. Signature of Comoany's Authorized Representative: 11 . Phone Number: 970-353-0611

<SK 11/06/2009 12. Email: kim@regwesl.com

Signature D.~

1;-. "'rlntf:l tteme of Au·l.orb·ed Representative: Kim Davis. CC, APC, Manager 14. Title: Consultant/Agent

15. Name of Company: RegWest Company, LLC for Scimetrics ltd. Corporation

Pleasereproduce thIS page if additIOnal Nnes areneeded for yourcompany's response.