REGISTRATION

85678-5 
11111111111111111111111111 009?A4A~A 1
&EPA Environmental Protection Agency owo. Dr PUtk;Kfec Programt (7505Cf 

WashingtDO, DC 20460 

Notlco of Supplemental Distribution of a Registered Pesticide Product 

After a registrant has obtained final registration for the basic product, the rogi$trant may then suppleffi{!otally 

dislribute hlsihe( product. One form mUst be submitted for each distributor product and must be sioned by the 

dfslriblftQr involved. The basic regislration numb&r and the distributor t:empany number must be shown, 

11:,:~i!,~,~~~':~~~~ a potential distributor who dOes not have a company number aSSigned, she/he should heve Ihe 

II on letterhead stationery, to the Registration Division to have a numb&r assioned prior 10 submittlno 

agency. 

Elheplmn6 

j ,I 

Attn: AnnelieFinSlad 

P.O. Sox 64S89 

SLP,,01,MN 5S 164.()589 

Distribution 

of both 

submitted by the basic registrant. The completed form must have 

the distributor. 

1381 " 

NOlO: Do nol $ubmlt distributor product lebels 

! Botl'd6 

I 

Condltjons 

1. Tho distributor product must have the same compOSition as tha basic product. 

The distributor product must be manufactured and packaged by the same person who manufactures and packages 

the regjstered basic product. 

The labeling for the distributor product must bear the same Claims as Ihe basic product, provided, however, that 

specific claims may be deleled if by doing so, no other changes to the label are necesury. 

The product must remain in the manufacturer's unbroken container. 

The label must bear the EPA registration number of the basic product, followed by a hyphen and the distribulor's 

company number. 

Distributor product labels must bear the name and address of the distributor qualified by such terms as ~packed 

for ... ", "distributed by ... ~i or "sold by ... " to show that the name is not that of Ihe manufacturer. 

All conditions of the basic regislfation apply OQually to disHibutor products. It is the responsibility of the basic 

registrant to see that a1t distributor labeling is kept in compliance wfth requirements placed on the basic product. 

Distributor 

Registrant 

th"t Mil distributo~ named "bOWl m .. y disMbure and .uN til. Distriburo.r Pradwr sp.r:iff.d 4bav4, .$1Jbi.r:t to th. r:andilians sp.r:if,."d 01> pits ) . 

" JJ JJ " , 

Si,"",,,,,", Till. 01 Ragjel,unl 

EPA Form 8510·5 " , 

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2
RedEagle Ethephon 685678-5 Minor Formulation Amendment 

Catherine Byrd 

to: 

John Bazuin 

06114/201003:08 PM 

Show Details 

Hi John, 

Pagelofl 

Currently, Red Eagle's registered end-use Ethephon product has a lower percentage of active ingredient (54.0%) 

than currently registered Ethephon products. This product was registered as substantially similar to Micro Flo 

Ethephon 6 registered by Arysta lifescience North America, LLC under EPA Registration Number 66330-250. 

Micro Flo is registered with 55.4% Ethephon. 

Red Eagle has amended their (SF to m,atch other currently registered Ethephon products induding their "me 

too", Since it is only a slight increase (1.4%) in active ingredient and was already found to be substantially similar 

to Micro Flo Ethephon 6, we submitted it as an amendment requiring no additional data. 

Per our conversation today, you indicated that the CSF should be submitted as a revised basic CSF. lfwe submit 

this amendment as a revised basic and change the checked box from Alternate to Basic on the CSF, is it possible 

to substitute this CSF for the one submitted on April 28 and not have to restart the clock? The CSF will be 

identical to what is on file other than the checked box. 

I look forward to hearing from you. 

Thank you, 

Catherine M. Byrd 

Wagner Regulatory Assodates, InC. 

P.O. Box 640 

7460 Lancaster Pike, Suite 9 

Hockessin, Delaware 19707 

P: 302.234.2780 

F: 302.234.7570 

www.wagnerreg.com 

3
Re: Red Eagle Ethephon 6 (85678-5) Alternate CSF ['j 

Tony Kish to: Catherine Byrd, John Bazuin 06/01/201006:33 PM 

Catherine - we received it and it's scheduled for completion 7/28/10. John Bazuin is working on it. 

Thanks, 

Tony Kish, Product Manager, 

Team 22, Fungicide Branch; 

Registration Division 

703-308-9443 

"Catherine Byrd" 

From: 

To: 

Date: 

Subject: 

"Catherine Byrd" <Calherine@wagnerreg.com> 

Tony KishfDC/USEPAlUS@EPA 

06/0 t120 to 05:06 PM 

RedEagle Ethephon 6 (85678-5) Alternate CSF 

Good afternoon Tony, 

06/01/201005:06:46 PM 

r hope you had a nice Memorial Day weekend. r just wanted to see what the status is of an alternate (SF 

that was submitted on March S, 2010 for the above-referenced product. 

Thank you, 

Catherine M. Byrd 

Regulatory Associate 

'VRA 

Wagner R~ufatory A,50diHe$, Inc 

P.O. Box 640 

7460 Lancaster Pike, Suite 9 

Hockessin, Delaware 19707 

P: 302.234.2780 

F: 302.234.7570 

WWVIf.wagnerreg.com 

4
G/ILJ/IO ~ 

5
RedEagle Ethephon 6 (85678-5) CSF amendment 

Catherine Byrd 

to: 

John Bazuin 

06/08/2010 11 :34 AM 

Cc: 

TonyKish 

Show Details 

Good afternoon John, 

Page 1 of 1 

We submitted an amended CSF in March for the above-referenced product. Red Eagle informed us that the 

density of the product has changed with the increased nominal concentration of Ethephon. We would like to 

update this on the CSF. Can I substitute a revised CSF with the correct density? 

Thank you, 

Catherine M. Byrd 

R'i1U i:otory Associate 

Wagner Regulatory Associates, Inc. 

P.O. Box640 

7460 Lancaster Pike, Suite 9 

Hockessin, Delaware 19707 

P: 302.234.2780 

F: 302.234.7570 

www.wagnerreg.com 

file://C:\Documents and Settings\ibazuin\Local Settino-."\Tp:mn\nt'ltpcP('Rr'RP\-"",,.l .. nl '" 1 1.. 6
7
Fungicide Branch Assignment Sheet 

Date Delivered to PM OI1.9 \ \0 %:&= 

Mary Waller 

PM21 

TonyKish 

PM 22 

Risk Managers 

Tamue @ Lisa 

Tawanda Tracy Rose 

Summer Shaunta 

(date & initial) 

Shaja Joyner 

PM 20 

Bryant 

Janet 

Bob 

Comments to Summer ________________ _ 

Date to summer_----,,·:;;Lj7t.,-'j~0:_D-., __ (date & j~jljal) 

Date to Risk Manager (d""tamp & initial ",ca below) ~4IDII. fI/S1 ~ 0.<\, <1> 'ttY 

MAY 1 3 2010 

0f). 

8
06 

FAST-TRACK AlIilE1~~M~TS-.C.~lplf'terless Screening Checklist 

Exp'erts In-Processb."lg Signature:--L" ,'1= 

EPA Reg: Number: 1 ~ ::t-<6 ~'5 EPA Receipt Date: 

1 

1 

3 

4 

Application Form (EPA Fonn 8570-1) -signed? 

Statement of Formula 

Certification with Respect to Citation of Data (EPA Form 8570-34) 

signed? 

Formulator~s 

owns 

6 Is Label Included? (5 copies) 

Comments: 

9
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 

WASHINGTON, D.C. 20460 

May 3, 2010 

CHERYL WAGNER 

WAGNER REGULATORY ASSOCIATES, INC. 

REDEAGLE INTERNATIONAL LLC 

7460 LANCASTER PIKE, SUITE 9, PO Box 640 

HOCKESSIN, DE 19707-0640 

PRODUCT NAME: ETHEPHON 6 

COMPANY NAME: REDEAGLE INTERNATIONAL LLC 

OPP lDENTIFlCATIONNUMBER: 

EPA FILE SYMBOL: 85678-5 

EPA RECEIPT DATE: 04/29/10 

SUBJECT: RECEIPT OF AMENDMENT 

DEAR REGISTRANT: 

OFFICE OF 

PREVENTION, PESTiCIDES AND 

TOXIC SUBSTANCES 

The Office of Pesticide Programs has received your application for an amendment and it 

has passed an administrative screen for completeness. 

During the initial screen we determined that the application appears to qualify [or fast 

track review. The package will now be forwarded to the Product Manager for review to 

detelTIline its acceptability for fast track status. 

If you have any questions, please contact Registration Division, Risk Management Team 

22, at (703) 308-9443. 

Sincerely. 

j,J~.~ 

Front End Processing Staff 

Information Services Branch 

Infonnation Technology & Resources Management Division 

10
IFee for Servicel ..-

(873547EThis package includes the following 

o New Registration 

@Amendment 

° Studies? ° Fee Waiver? 

°volpay % Reduction: 

for Division 

OAD 

oBPPD 

@RD 

Risk Mgr. []I] 

Receipt No. s-I 873547 

EPA File Symbol/Reg. No. 1 85678-5 

Pin-Punch Date: 1 4/29/2010 

~his item is NOT subject to FFS action. 

Action-eod""e"-: ---I 'I Parent/Child Decisions: 

Requested: I ! 

! Granted: I 

I Amount Due: '--$----' 

~f_rA"=':dA f4'~ 5/LL)LI"O __ ~ '---------

)I Inert Cleared for Intended Use ° Uncleared Inert in Product 

Reviewer: X-~ ~"'~: Date: '=\ -- -30- L G 

Remarks: 

11
April 27, 2010 

Document Processing Desk (AMEND) 

ATTN: Tony Kish 

Registration Division (7504P) 

U.S. Environmental Protection Agency 

Office of Pesticide Programs 

Room S-4900, One Potomac Yard 

2777 South Crystal Drive 

Arlington, Virginia 22202-4501 

Dear Mr. Kish; 

Wagner Regulatory Associates,lnc. 

P.O. Box 640 

7460 Lancaster Pike, Suite 9 

Hockessin, Delaware 19707 

Subject: RedEagle International LLC - Ethephon 6 - EPA Registration Number 85678-5 

Application for Amendment Formulation Change 

Wagner Regulatory Associates, Inc., as agent for RedEagJe International LLC, is submitting an 

amendment for the above-referenced product. This amendment is for a minor change iiI the formulation of 

this product and does not affect the product labeling except for the ingredient statement. The ingredient 

statement has been changed to reflect the small increase in the nominal amount of the active ingredient, as 

shown on the enclosed Confidential Statement of Formula. 

In support ofthis request, the following documents and studies are attached: 

• Letter from RedEagle International LLC, appointing Wagner Regulatory Associates, Inc. as its 

agent; 

• Application for Pesticide Amendment (8570-1); 

• Confidential Statement of Formula (8570-4), 2 copies; and 

• Draft labeling, 5 copies. 

If you have any questions about this submission please contact the undersigned at 

catherine@wagnerreg.com or (302) 234-2780. 

Respectfully submitted, 

Catherine M. Byrd 

Agent for RedEagle International LLC 

Enclosures 

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12
Please read instructions on reverse before como'- 'iQo form. Fonn Approv"'" DMB No. 2070-0060. Approval ex iles 05-3t-98 , _egistration OPP Identifier Number EXPEDITE 

.oEPA United States ry- Environmental Protection Agency Amendment 

Washington, DC 20460 Other 

Application for Pesticide· Section I 

1. Company/Product Number 2. EPA Product Manager 3. Proposed Classification 

RedEagle International LLC/85678-5 Tony Kish 

4. Company/Product (Name) PM. IR] None Restricted 

Red Eagle International LLC/Ethephon 6 22 

5. Name and Address of Applicant (Include Zip Code) 6. Expedited Review. In accordance with FIFRA Section 3{c){3) 

Red Eagle International LLC 

(b)(I), my product is similar or identical in composition and labeling 

to: 

clo Wagner Regulatory Associates, Inc. 

P.O. Box 640 

EPA Reg. No. 66330-250 

Hockessin, DE 19707 Product Name: Micro Flo Ethephon 6 

o Check if this is a new address 

Section · II 

IJg Amendment - Explain below. 0 Final plinted labels in response to 

Agency letter dated 

0 Resubmission in response to Agency letter dated 0 "Me Too" Application. 

0 Notification - Explain below. 0 Othel - Explain below. 

Explanation: Use additional page{s) if necessary. (For Section I and Section II.) 

Amendment requiring no data-fonnulation change. 

Section · III 

1. Material This Product Will Be Packa ed In: 

Child-Resistant Packaging U~ckaging W~ Soluble Packaging 2. Type of Container t8j Yes' Yes Yes Metal 

X No fy- No X No X Plastic 

If "Yes" No. per If "Yes" No. per Glass 

* Certification must Unit Packaging wgt. container Package wgt container Paper 

be submitted I Other (Specify) HOPE lined bags 

3. Location of Net Contents Information 4. Size(s) Retail Container 5. Location of Label Directions 

~ Label D Container 2.5 gallons, 30 gallons, 275 ~ On Label 

gallons 

On Labeling accompanying product 

6. Manner in Which Label is Affixed to Product § Lithograph CJ Other _adhesive backed label 

X Paper glued 

Stenciled 

Section · IV 

1. Contact Point (Comp/ete items directly be/ow for identification of individual to be contacted, if necessary, to process this application. 

Name 1 Title I J3el~~hone No. (Include Area Code) 

Catherine M. Bvrd Aaent for RedEaqle International LLC 302 234 2780 > ••• 

Certification 'fl. : ~.)te Appllc..'&'tion 

I certify that the statemenls I have made on this fOim and all attachments thereto ale true, accurate and complete. 'R~celved • 

I acknowledge that any knowingly false or misleading statement may be punishable by fine or imprisonment or " , both under applicable law. " " , • • • , (Sta.Tiped) , 2. Signature 3. Title · · . " • 

" " , , • > 

Agent for Red Eagle International LLC · ~Yx.&fd-- · • " . · • , , " " 

· ),' , 

· , 4. Typed Name 5. Date ,}, ) 

Catherine M. Byrd April 27, 2010 

ThiS IS a reproduction of EPA Form 8570-1 (Rev. 8·94) PrevIous editions are obsolete. 

13
August 1. 2009 

To Whom It May Concern 

Dear Sir or Madam: 

Phone: (863) 682-6698 

Fax: (863) 682-6690 

This letter serves as notification that RedEagle International LLC. has appointed Wagner 

Regulatory Associates, Inc. (WRA, Inc.) to serve as the Agent on our company's behalf 

regarding all state and federal regulatory matters relative to products that RedEagle 

International LLC. wiU register with the U ,So EPA and the states. Please forward all 

correspondence for RedEagle International LLC. and its products to; 

Wagner Regulatory Associates, Inc. 

P.O. Box 640 

Hockessin, DE 19707-0640 

Thank you for your time and assistance. Please feel free to call me if you have any 

questions. 

Respectfully submitted, 

Yingxue Yu 

Chief Executive Officer 

cc: WRA, Inc. 

, > • > 

• )), , 

, . . " 

----------~~~~~~~~~--~~~~~~~~~o_.~~~----~----~. " Address: 1925 E. Edgewood Drive, Lakeland, Florida 33803 ' ,: >, 

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14
85678-5-v4-26APR 1 0 Ethephon 6 

ETHEPHON6 

FOR COMMERCIAL USE OR 

AGRICULTURAL USE ONLY NOT INTENDED 

FOR RESIDENTIAL USE 

Formula1ion Change 

ACTIVE INGREDIENT: 

Ethephon (2-Chloroethyl) phosphonic acid· .......................... " ...... 55.4% 

OTHER INGREDIENTS: ............................................. . ................ 44.6% 

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

This product contains 6 pounds of ethephon per gallon. 

KEEP OUT OF REACH OF CHILDREN 

DANGER PELIGRO 

Si usted no entiende la etiqueta, D""' "ue se la explique a usted en detalle. {If you do not 

• eye open and rinse and gently water for 15-20 minutes. 

IF IN EYES • Remove contact lenses, if present after the first 5 minutes, then continue rinsing eye 

• 

• Take off 

• Rinse skin i 

IFONSKIN OR of water for 15-20 minutes. CLOTHING: 

• 

• Call a poison control or doctor immediately for 

IF SWALLOWED: • Have person sip a glass of water if able to swallow. 

• Do not induce vomiting unless told to do so by a pOison control center or doctor. 

• 

• 

IF INHALED: • 

You may also contact: 

EMERGENCY NUMBERS: CHEMTREC (transportation and spills) 

Poison Control Center health) 

EPA Reg. No. 85678-5 > • , > 

Establishment No. 69352-CHN:Oq1 

""" " 

NET CONTENTS: 275 gallons, 30 gallons or 2.5 gallons 

Manufactured For. 

RedEagle International LLC 

1925 E. Edgewood Drive 

Lakeland, Florida 33803 

1 

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15
85678-5_v4_26APR 1 0 EthephOn 6 

PRECAUTIONARY STATEMENTS 

DANGER 

HAZARDS TO HUMANS AND DOMESTIC ANIMALS 

Formulation Change 

Corrosive. Causes irreversible eye damage and skin bums. Hannful if swallowed or absorbed through skin. Do not 

get in eyes, on skin or on clothing. Prolonged or frequently repeated skin contact may cause anergic reactions in 

some individuals. 

PERSONAL PROTECTIVE EQUIPMENT (PPE) 

Some materials that are chemically resistant to this product are listed below. If you want more options, follow the 

instructions for Category A on an EPA chemical resistance category selection chart. 

Applicators and other handlers must wear: 

1. Coveralls over long-sleeved shirt and long pants. 

2. Chemical-resistant gloves made of any waterproof materials. 

3. Chemical-resistant footwear plus socks. 

4. Protective eyewear such as goggles, safety glasses or face shield. 

5. Chemical-resistant headgear for overhead exposure. 

6. Chemical-resistant apron when mixing or loading or cleaning equipment. 

Discard clothing and other absorbent materials that have been drenched or heavily contaminated with this product's 

concentrate. Do not reuse them. Follow manufacturer's instructions for cleaning and maintaining PPE. If no such 

instructions for washables exist, use detergent and hot water. Keep and wash PPE separately from other laundry. 

When handlers use closed systems, enclosed cabs, or aircraft in a manner that meets the requirements listed in the 

Worker Protection Standard (WPS) for agricultural pesticides 40 CFR t70.240.(d){4-6), the handler PPE 

requirements may be reduced or modified as speCified in the WPS. 

USER SAFETY RECOMMENDATIONS 

Users should: 

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

2. Remove clothing/PPE immediately if pesticide gets inside. Then wash body thoroughly and put 

on clean clothing. 

3. Remove clothingfPPE immediately after handling this product. Wash the outside of gloves before 

removing. As soon as pOSSible, wash thoroughly and change into clean clothing. 

ENVIRONMENTAL HAZARDS 

Do not apply directly to water, or to areas where surface water is present or to intertidal areas below the mean high 

water mark. Do not contaminate water when disposing of equipment washwaters. Do not contaminate water used 

for irrigation or domestic purposes. 

USE PRECAUTIONS 

Do not apply Ethephon 6 through any type of irrigation system. 

Do not plant another crop within 30 days after treatment. 

Mix only the amount of spray you expect to use each day. Do not anow mixed solution to stand overnight. 

Avoid spray drift to nearby crops as this product will cause modificatlons in plant growth. Plant injury or reduced 

yields will result. 

AVOIDING SPRAY DRIFT AT THE APpLICATION SITE IS THE RESPONSIBILITY OF THE APPLICATOR. 

The interactions of many equipment-and-weather-related factors determine the potential for spray drift. The 

applicator is responsible for considering an these factors when making decisions. 

The fonowing drift management requirements must be followed to avoid off-target movement from aerial 

applications to agricultural field crops. These requirements do not apply to forestry applications, public health 

uses or to appfications using dry formulations. 

1. The distance of the outer most nozzles on the boom must not exceed 3/4 the length of the wingspa;-;'(jJ' 

rotor. ,'»» ,,:, 

2. Nozzles must always pOint backward parallel with the air stream and never be poi0te6;dqwnwards more 

than 45 degrees. " 

Where states have more stringent regulations, they should be observed. ) , ; , , ; , , 

, ) 

AERIAL DRIFT REDUCTION , ; , ' 

ADVISORY Information on droplet size: ' , , , . , 

The most effective way to reduce drift potential is to apply large droplets. The best drift mana£.emolit 'stratep,Y is t9 

apply the largest droplets that provide sufficient coverage and control. Applying larger droplets reduces drift, , , , ) ) 

potential, but will not prevent drift if applications are made improperly, or under unfavorable environmental conqi\i9f)s 

(See Wind, Temperature and Humidity, and Temperature Inversions). ) , , , ' 

2 

16
85678-5-v4-26APR10 Ethephon 6 Formulation Change 

Controlling droplet size: 

Volume - Use high flow rate nozzles to apply the highest practical spray volume. Nozzles with higher rated flows 

produce larger droplets. Pressure - Do not exceed the nozzle manufacturer's recommended pressures. For many 

nozzle types lower pressure produces larger droplets. When higher flow rates are needed, use higher flow rate 

nozzles instead of increasing pressure. 

Number of Nozzles - Use the minimum number of nozzles that provide uniform coverage. 

Nozzle Orientation - Orienting nozzles so that the spray is released parallel to the airstream produces larger 

droplets than other orientations and is the recommended practice. Significant deflection from horizontal will reduce 

droplet size and increase drift potential. 

Nozzle Type - Use a nozzle type that is designed for the intended application. With most nozzle types, narrower 

spray angles produce larger droplets. Consider using low-drift nozzles. Solid stream nozzles oriented straight back 

produces the largest droplets and the lowest drift. 

BOOMLENGTH 

For some use patterns, redudng the effecflve boom length to less than 3/4 of the wingspan or rotor length may 

further reduce drift without reducing swath width. 

APPLICATION HEIGHT 

Applications should not be made at a height greater than 10 feet above the top of the target plants unless a greater 

height is required for aircraft safety. Making applications at the lowest height that is safe reduces exposure of droplets 

to evaporation and wind. 

SWATH ADJUSTMENT 

When applications are made with a crosswind, the swath will be displaced downwind. Therefore, on the up and 

down edges of the field, the applicator should compensate for the displacement by adjusting the path of the aircraft 

upwind. Swath adjustment distance should increase, with the increasing drift potential (higher wind, smaller drops, 

etc.). 

WIND 

Drift potential is lowest between winds speeds of2 -10 mph. However, many factors, including droplet size and 

equipment type determine drift potential at any given speed. Application should be avoided below 2 mph due to 

variable wind direction and high inversion potential. NOTE: Local terrain can influence wind patterns. Every 

applicator should be familiar with local wind patterns and how they affect spray drift. 

TEMPERATURE AND HUMIDITY 

When making applications in low relative humidity, set up equipment to produce larger droplets to compensate for 

evaporation. Droplet evaporation is most severe when conditions are both hot and dry. 

TEMPERATURE INVERSIONS 

Applications should not occur during a temperature inversion because drift potential is high. Temperature inversions 

restrict vertical air mixing, which causes small suspended droplets to remain in a concentrated cloud. This cloud 

can move in unpredictable directions due to light variable winds common during inversions. Temperature 

inversions are characterized by increasing temperatures with altitude and are common on nights with limited cloud 

cover and light to no wind. They begin to form as the sun sets and often Continue into the morning. Their presence 

can be indicated by ground fog; however, if fog is not present, 'Inversions can also be identified by the movement of 

smoke from a ground source or an aircraft smoke generator. Smoke that layers and moves laterally in a 

concentrated cloud (under low wind conditions) indicates an inversion, while smoke that moves upward and rapidly 

dissipates indicates good vertical air mixing. 

SENSITIVE AREAS 

The pesticide should only be applied vklen the potential for drift to adjacent sensitive areas (e.g. residential areas, 

bodies of water, known habitat for threatened or endangered species, non-target crops) is minimal (e.g., whE"J\I1ii

J1d 

is blowing away from the sensitive areas). , ) ; > " , " , DIRECTIONS FOR USE 

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

Do not apply this product in a way that will contact workers or other persons, either directly C'J thrcu8h drift; OnJy, , 

protected handlers may be in the area during application. For any requ'lrements speCific to your:Sta\e or Tribe, 

consult the agency responsible for pesticide regulation. . , ' , , :: 

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17
85678-5-v4-26APR to Ethephon 6 Formulation Change 

AGRICULTURAL USE REQUIREMENTS 

Use this product only in accordance with its labeling and with the Worker Protection Standard, 40 CFR part 170. 

This standard contains requirements for the protection of agricultural workers on farms, forests, nurseries, and 

greenhouses, and handlers of agricultural pesticides. It contains requirements for training, decontamination, 

notification, and emergency assistance. It also contains specific instructions and exceptions pertaining to the 

statements on this label about personal protective equipment, notification to workers, and restricted-entry 

intervals. The requirements in this box only apply to uses of this product that are covered by the Worker 

Protection Standard. 

Do not enter or allow worker entry into treated areas during the restricted-entry interval (REI) of 48 hours. 

The REI increases to 72 hours in outdoor areas where average rainfall is less than 25 inches a year. 

PPE required for early entry to treated areas that is permitted under the Worker Protection Standard and that 

involves contact with anything that has been treated such as plants, soil, or water, is: 

1. Coveralls over short-sleeved shirt and short pants. 

2. Chemical resistant gloves made of any waterproof material. 

3. Chemical-resistant footwear plus socks. 

4. Protective eyewear such as goggles, safety glasses or face shield. 

5. Chemical-resistant headgear for overhead exposure. 

Notify workers of the application by warning them orally and by posting warning signs at entrances to treated 

areas. 

STORAGE AND DISPOSAL 

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

PESTICIDE STORAGE 

If container is broken or contents have spilled, follow all precautions indicated above and clean up immediately. 

Before cleaning up, put on full length trousers, long sleeved shirt, protective gloves, and goggles or face shield. Soak 

up spill with absorbent media such as sand, earth or other suitable material and dispose of waste at an approved 

waste disposal facility. 

PESTICIDE DiSPOSAL 

Pesticide wastes are acutely hazardous. Improper disposal of excess pesticide, spray mixture, 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 

Non refillable container: Equal to or less than 5 gallons: Nonrefillable container. Do not reuse or refill thls 

container. Triple rinse container (or equivalent) promptly after emptying. Triple rinse as follows: Empty the remaining 

contents into application equipment or a mix tank and drain for 10 seconds after the flow begins to drip. Fill the 

container X full with water and recap. Shake for 10 seconds. Pour rinsate into application equipment or a mix tank or 

store rinsate for later use or disposal. Drain for 10 seconds after the flow begins to drip. Repeat this procedure two 

more times. Then offer for recycling, if available or puncture and dispose of in a sanitary landfill, or by inCineration, or, 

if allowed by state and local authorities, by burning. If burned, stay out of smoke. 

Non refillable container: Greater than 5 gallons: Nonrefillable container. Do not reuse or refill this container. Triple 

rinse container (or equivalent) promptly after emptying. Triple rinse as follows: Empty the remaining contents into 

application equipment or a mix tank. Fill the container % full with water. Replace and tighten closures. TIp container 

on its side and roillt back and forth, ensuring at least one complete revolution, for 30 seconds. Stand the container on 

its end and tip it back and forth several times. Tum the container over onto its other end and tip it back and forth 

several times. Empty the rinsate into application eqUipment or a mix tank or store rinsate for later use or disposal. 

Repeat this procedure two more times. Then offer for recycling, if available, or puncture and dispose of in a sanitary 

landfill, or by inCineration, or, if allowed by state and local authorities, by buming. If bumed, stay out of smoke. 

GENERAL INFORMATION , > > , 

COnON ' 

A foliar spray of Ethephon 6 will accelerate opening of mature unopened cotton bolls and enh111t.:";d4foliation which 

can result in earlier harvest with an increased recoverable yield. Ethephon 6 treatment allows \ncrt!a~d efficienCy 

from a once-over harvest. ; " ' , " ' " , 

TOBACCO (FLUE-CURED) , ' , 

A foliar spray of Ethephon 6 promotes early, uniform "yellowing" of mature tobacco. Ethephori0 f~Ju,ces cunh'g' , 

time, allowing more efficient use of curing bam space, and increased control over harvest sche,d,L!~s;' ' 

SPRAY PREPARATION 

Add 1/2 to 3/4 of the required amount of water to the spray tank. Start agitation. Add the required amount of, ' , , , , 

Ethephon 6, and the remaining amount of water. Prepare only as much spray solution as can be used on the (/ay'of 

4 

18
85678-5-v4-26APR10 Ethephon 6 Formulation Change 

mixing. Do not allow spray solution to stand overnight. Do not spill the concentrated product on spray equipment, or 

any airplane parts. 

ANY SPILLS SHOULD BE RINSED IMMEDIATELY WITH PLENTY OF WATER. 

Use of a nurse tank is highly recommended for avoiding possible spills of concentrated fonnulation on spray 

equipment or any airplane parts. 

TANK MIXTURES WITH DEFOUANTS AND INSECTICIDES 

Follow all applicable use precautions and rate per acre recommendations on labels of products applied as tank 

mixtures or in sequence with Ethephon 6. In some cases slight reduction in boll opening response has been 

obseNed when tank mixes with defoliants were used. 

Good agitation in the spray tank is essential and a tank mixture should not be allowed to stand without agitation for 

more than 5 to 10 minutes. Read and obseNe all appropriate label use directions and precautions for the 

defoliants and insectkides used. 

DO NOT MIX WITH DESICCANTS IF COTTON IS TO BE SPINDLE HARVESTED. 

DO NOT TANK MIX ETHEPHON 6 WITH DEFOLIANTS CONTAINING SODIUM CHLORATE BECAUSE THIS 

RESULTS IN THE FORMATION OF HYPOCHLOROUS ACIDS WHICH UPON HEATING EMIT TOXIC CHLORINE 

FUMES. 

EQUIPMENT CLEANING 

Because of the acidic nature of this product, prolonged exposure to spray deposits will damage acrylic plastics, 

certain paints, and metals. 

Rinse thoroughly with a detergent and water all exposed acrylic plastic-type materials (e.g., aircraft windshields), 

and painted surfaces within an hour after exposure to spray deposits. 

At the end of each day, rinse thoroughly with a detergent and water all the metal parts of the aircraft and the 

associated spray equipment exposed to the spray deposits. 

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19
85678·5·v4·26APR10 Elhephon 6 Formulation Change 

COTTON 

ETHEPHON 6 ONE GALLON 

EXPECTED RATE ETHEPHON S SPRAY VOLUME 

USE TREATS APPLICATION TIMING CONDtTIONS 

PINTIA LBSAI ACRES GROUND AIR" 

Hoi and dry SO'F or t tl3 1.0 6 higher Apply whenlhe number ot 

Dry and 75 F to 80 F 2 1.5 4 malure unopened bolls is 

sutticient 10 produce Ihe 

ETHEPHON S' t5·50 2-5 desired crop. See below tor 

Cool but above 65 F test ot boll malur~y. 

" 2 213 2 3 Treatm enl unfform Iy opens Rank colton bolls 710 t4 days earlier. 

ETHEPHON 6 High soil moislure Apply 410 7 days prior 10 

Ethephon 6 boll opening 

• " application. To be used as a FOLEX High tertilily tevel 113 .25 24 15·50 5·10 

De/olianl Tank " sequentiallrealmenl with, nol 

Mix Rank colton in place of Ethephon 6 boll 

opening treatment. 

High soil moislure Apply" 10 7 days prior 10 

ETHEPHON 6 Elhephon 6 boll opening 

+ DROPP " application, To be used as a 

Defolianl Tank High terlilily level 1i3 .25 24 to·50 3·tO sequential trealm enl wilh, 

Mix " nol in place ot Ethephon 6 Rank cotton boll opening Ireatment. 

Hoi, dry, above 80 F 213 .5 12 Apply 410 7 days prior 10 

Pre· defoliant. 

Conditioner 15-50 2-5 Enhances lop crop detolialion 

I" Cool, above 65'F reducing delerioration ot 

Detoliation " I tl3 1.0 6 bottom crop and allows tor 

Rank collon earlier harvest. 

• Pretreatment With Defoliants Prior to Ethephon 6 Treatment 

If the cotton is overly rank or laying down in the middles and good spray coverage of the bolls with Ethephon 6 is 

difficult, a pretreatment with defoliants will be useful to improve boll coverage with Ethephon 6. Use dosage rates 

of Ethephon 6 recommended for boll opening. 

Read and observe all appropriate label use directions and precautions for the defoliant used. 

**NOTE: For California and Arizona use a volume of no less than 5 gallons per acre for aerial applications. 

801.1 Maturity 

A boll is mature when it is too hard to be dented when squeezed between thUmb and fingers, too hard to be aHocd 

with a sharp knife, and when the seed coat becomes light brown in color. , , , ' , , ' , : > 

Use Limitations ) > , 

• Do not exceed a maximum of2.0 lb. ai/A for combined uses of Ethephon 6 (or other ethep)n:1 t.Diltainin-) ',,' . - products) per acre per year. , > , 

• Boll Opening: Do not tank mix Ethephon 6 with a desiccant if the cotton is to be spindle harvested. ' > : , , ' 

• Pre·Condition for Defoliation: Do not tank mix Ethephon 6 with desiccants unless plant desi6datlcn is require,d. 

Do not use a defotiant before there is sufficient mature unopened bolls to produce the desired y'£!d (see G~neral 

Information section on how to test for boll maturity). ' ) , ) , , 

)', , 

." " 

6 

20
85678-5-v4-26APR10 Ethephon 6 Formulation Change 

When to Harvest 

Do not harvest cotton sooner than 7 days after a treatment with Ethephon 6. Observe the treated crop and harvest 

when optimum boll opening has been reached. Too early harvest might reduce the full advantage of the treatment 

and too late a harvest may result in reduced quality and loss of lint which will drop from the plant. 

TOBACCO fFlue-Cured Onlvl 

SPRAY 

CROP ETHEPHON 6 VOLUME SPECIFIC DIRECTIONS SITUATION PINTS/ACRE GALLONSI 

ACRE 

Use drop nozzles. Choose TG or OC spray tips designed to apply 50-

Directed 60 gpa at 35- 40 psi and at tractor speed of 2-3 mph. Use 2 nozzles 

Spray 1 1/3 50·60 per row; one on each side of the row dropped low enough to direct 

Applicaton the spray to the leaves to be ripened and harvested. Thorough spray 

coverage is essential. With a directed spray, be sure to harvest all 

leaves with 20% or more yellowing. 

Treat only when leaves remaining on the stalk are mature. To 

ensure remaining leaves are mature, test spray several tobacco 

plants as described under the section "Application Timing." Use the 

lower rate in a normally mature crop when experience indicates that 

minimum ripening inducement is required. Use the higher rate when 

the crop is heavy and has a tendency to be more rank or when 

Over-The- temperatures are lower than normal. Always test spray to determine if 

Top 1 113-2 2/3 40-60 the tobacco is mature enough to respond to treatment with 

Application Ethephon 6. 

Apply over-the-top Ethephon 6 spray as a fine mist using three 

nozzles (one nozzle tip over the center of the plant, and one on each 

side) so all leaves are covered thoroughly, similar to the application 

pattern of systemic sucker control agents. Use a spray pressure of 

40 to 60 pSi. I 

USE LIMITATIONS 

'00 not apply Ethephon 6 to immature leaves as this can result in unsatisfactory coloring, weight loss and 

reduced leaf quality. 

·00 not allow the crop to over ripen in the field after using Ethephon 6, since this may cause some reduction in 

yield and quality. 

·00 nottreat before anticipated major storm which could prevent harvest and result in crop loss. 

'00 not apply Ethephon 6 if rain is expected within 4 hours. 

APPLICATION TIMING 

Successful results with Ethephon 6 call for treatment when leaves are mature, not overly rank green when sprayed. 

To easily determine the proper treatment timing and the number of leaves per stalk ready for harvest, test spray 

several plants in more than one location in each field and observe the response. Mature leaves will begin to yellow 

in 24 to 72 hours. Test leaves that fail to yellow in 72 hours are not mature and are not ready for Ethephon 6 

treatment. Wait a few days to permit further natural maturing, then make another test spray or "maturity" check. 

When you have confirmed the number of leaves per plant that will color, you can determine the number of acres to 

treat in order to fill the bam. 

TEST SPRAY MIXTURE DIRECTIONS 

Prepare your test spray by mixing one teaspoon of Ethephon 6 in 1 quart of water. Spray each test plant with aboyt 

1 oz of this mixture, covering all leaves with a fine mist. Ethephon 6 will not color immature sprayed leaves. ~'~ ", , , " ' , , 

WHEN TO HARVEST ; 

All mature, sprayed leaves will begin to color within 24 to 72 hours after Ethephon 6 application .. Th€'l ~ellowiM, " 

process is weather dependent; cool weather will delay, while hot, sunny weather can speed u'p't\e 'p'rocess: HalVest 

treated tobacco when leaves have reached the desired color intensity. ", ,

" , " '" , 

Do not allow tobacco to become over ripe before starting harvest. Leaf drop can occur when tobac-co is over ripe 

and left on the stalk. If a number of the bottom leaves have yellowed at the time of treatment, 'they Sh.;:I1Jlp, '}"f. 

harvested prior to spraying with Ethephon 6. 

," , , , With an over-the-top application, harvesting can commence 48 hours after Ethephon 6 application dependiny bn 

7 

21
8S678·5·v4·26APR10 Ethephon 6 Formulation Change 

weather conditions or to avoid over ripe tobacco. Tobacco harvested 48 hours after treatment may require more 

time in the coloring phase of the curing process. 

CURING ETHEPHON 6 TREATED TOBACCO 

Curing procedures are as much an art as a science and each cure must be judged on the basis of tobacco condition, 

interval between treatment and harvest, weather and type of curing facility before prescription temperature and 

ventilation schedules can be established. To obtain maximum quality, care must be taken to observe and control the 

curing process closely, especially during the late "coloring" and early "drying" stages of the leaf. 

Ethephon6 treated tobacco will have started the coloring process when harvested, reducing the time required in the 

coloring phase of curing. Treated tobacco should be dried faster. If tobacco leaves are green or contain some green 

when harvested, H may be necessary to color them for a few hours. If the leaves are completely yellow, temperature 

and ventilation must be adjusted in a manner to dry the tobacco as fast as possible without scalding. Once the leaf 

Is dried (3/4 dry), you should follow normal procedures for curing. Since Ethephon 6 treated leaves cure faster, 

treated and untreated leaves should not be cured together In the same barn. 

REDEAGLE INTERNATIONAL LLC WARRANTS THAT THIS PRODUCT CONFORMS TO THE CHEMICAL 

DESCRIPTION ON THE LABEL THEREOF AND IS REASONABLY FIT FOR THE PURPOSE STATED ON SUCH 

LABEL ONLY WHEN USED IN ACCORDANCE WITH THE DIRECTiONS FOR USE. IT IS IMPOSSIBLE TO 

EUMINATE ALL RISKS INHERENTLY ASSOCIATED WITH THE USE OF THIS PRODUCT. CROP INJURY, 

INEFFECTIVENESS, OR OTHER UNINTENDEO CONSEQUENCES MAY RESUL T BECAUSE OF SUCH 

FACTORS AS WEATHER CONDITIONS, PRESENCE OF OTHER MATERIALS, OR THE MANNER OF USE OR 

APPLICATION, ALL OF WHICH ARE BEYOND THE CONTROLOF REDEAGLE INTERNATIONAL LLC. TO THE 

EXTENT CONSISTENT WITH THE APPLICABLE LAW IN NO CASE SHALL REDEAGLE INTERNATIONAL LLC 

BE LIABLE FOR THE CONSEQUENTIAL, SPECIAL OR INDIRECT DAMAGES RESULTING FROM THE USE OR 

HANDLING OF THIS PRODUCT TO THE EXTENT CONSISTENT WITH APPLICABLE LAW ALL SUCH RISKS 

SHALL BE ASSUMED BY THE BUYER. EXCEPT AS EXPRESSLY PROVIDED HEREIN, REOEAGLE 

INTERNATIONAL LLC MAKES NO WARRANTIES, GUARANTEES, OR REPRESENTATIONS OF ANY KIND, 

EITHER EXPRESS OR IMPLIED, OR BY USAGE OF TRADE, STATUTORY OR OTHERWISE, WITH REGARD 

TO THE PRODUCT SOLD, INCLUDING BUT NOT LIMITED TO, MERCHANTABILITY, FITNESS FOR A 

PARTICULAR PURPOSE, USE OR ELIGIBILITY OF THE PRODUCT FOR ANY PARTICULAR TRADE USAGE. 

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22
MATERIAL TO BE ADDED TO JACKET 

REG# 

Description: 

check all that apply 

0 new stamped accepted label ~ ::s .. 

Q, 

0 newCSF .... 

0 

(') 

[Sy notification CI) 

0 

Instructions: 

Attach this sheet to the top of ALL material sent to the file room (both loose paper and 

new material in jackets). This sheet will be imaged; a clear description will aid in 

finding material in the e-jacket. Remove staples from all material. If retuming loose 

paper then hold together with a binder or paper clip. CSFs should be placed in the 

CSF folder (if returning jacket) or covered with a red CBI sheet (if returning loose 

paper). Material to be returned to file room should be place in the appropriate bin. 

Reviewer's 

Name: 

Phone: 

Date: :2 '11-/0 

Division: _...1.gJ~ __ _ 

23
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY. 

WASHINGTON,O.C. 20460 

Ms Catherine M. Byrd 

Red Eagle International LLC 

C/O Wagner Regulatory Associates, Inc 

P.O. BOX 640 

Hockessin, DE 19707 

OFFICE OF 

PREVENTION, PESTICIDES AND 

TQXICSUBSTANCES 

,1M! 2 9 2010 

Subject: Label Notification(s) for Pesticide Registration Notice 2007-4 

Dear Registrant: 

The Agency is in receipt of your Application(s) for Pesticide Notification under 

Pesticide Registration Notice (PRN) 2007-4 dated December 4, 2009 for: 

EPA Registration 85678-5 Ethephon 6 

The Registration Division (RD) has conducted a review of this request for applicability 

under PRN 2007-4 and finds that the label change(s) requested falls within the scope of 

PRN-2007-4. The label has been date-stamped "Notification" and will be placed in our 

records. 

Please be reminded that 40 CFR Part 156.140(a)(4) requires that a batch code, lot 

nwnber, or other code identifying the batch of the pesticide distributed and sold be placed on 

nonrefillable containers. The code may appear either on the label (and can be added by nonnotificationlPR Notice 98-10) or durably marked on the container itself. 

If you have any questions, please contact me directly at 703-305-6249 or Banza 

Djapao of my staff at 703-305-7269. 

Sincerely, 

Linda Arrington 

Notifications & Minor FOffimlations Team Leader 

Registration Division (7505P) 

Office of Pesticide Programs 

24
I 

December 4, 2009 

Wagner Regulalory Associates, Inc. 

p.o. Box 640 

7460 Lancaster Pike, Suite 9 

Hockessin, Delaware 19707 

Document Processing Desk (NOTIF) 

A 1TN: Ms. Linda An'ington 

Registration Division (7504P) 

U.S. Environmental Protection Agency 

Office of Pesticide Programs 

One Potomac Yard 

l200 Pennsylvania Avenue NW 

Washington, D.C. 20460 

Dear Ms. Arrington: 

Re: Red Eagle International LLC - Ethephon 6 

EPA Registration Number 85678-5 

Notice of Revised Storage & Disposal Label Language 

Wagner Regulatory Associates, Inc., on behalf o.fJ,tedEagle lntemational LLC, hereby 

notifies the Agency that the storage and disposal section of the subject label as been 

revised in accordance vvith PR Notice 2007-4 and the EP,,1..\ Notice of Pesticide 

Registration dated November 25, 2009. Enclosed for the Agency's file is: 

Letter from RedEagle International LLC autllOrizing, Wagner Regulatory to 

serve as Agent 

EPA Notification fornl (EPA FornI 8570~ I) 

One copy of revised labeling with the revised text bolded for convenience. 

Please feel free to contact me at (302) 234~2780 if you have any questions or require 

additional infornlation, 

Respectfully submitted, 

Catherine M. Byrd 

Agent for RedEagle International LLC 

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25
Phone: (863) 682-6698 

Fax: (863) 682-6690 

August 1, 2009 

To Whom It May Concern 

Dear Sir or Madam: 

This letter serves as notification that RedEagle International LLC. has appointed Wagner 

Regulatory Associates, Inc. (WRA, Inc.) to serve as the Agent on our company's behalf 

regarding all state and federal regulatory matters relative to products that RedEagle 

International LLC. will register with the U.S. EPA and the states. Please forward all 

correspondence for RedEagle International LLC. and its products to: 

Wagner Regulatory Associates, Inc. 

P.O. Box 640 

Hockessin, DE 19707-0640 

Thank you for your time and assistance. Please feel free to call me if you have any 

questions. 

Respectfully submitted, 

Yingxue Yu 

Chief Executive Officer 

cc: WRA, Inc. 

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, 

__________ -..~==~no~~~====~~~~~~'"_='_~~~--~·~--~J"O Address: 1925 E. Edgewood Drive, Lakeland, Florida 33803 ,J" 

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26
PI"" \fO~ Foem ~BNO I 

".' OPP -

&EPA United states 

Environmental Protection Agency Amendment 

Washington, DC 20460 X Other 

I I for , " I II 

1. 2 EPA 3. 

RedEagle InternationalllC/85678-5 Tony Kish 

4. PM' [RJ None Restricted 

Red Eagle International LLC/Ethephon 6 22 

I 5 "me aOd' ,of. Ii >Zip Code) 

~b)(I), my product is Si~i:~/or identical j~i~~mpOSitiOn andjI3.(C),~,~~ Red Eagle International LLC to: 

do Wagner Regulatory Associates, Inc. EPA Reg. No, 

P.O. Box64Q Product Name: 

Hockessin, DE t9707 

D Check iffhis is a I 

" II 

D . ~pl", b,low. IlSI "":~c'~';'~."bet'." ; Agency tetter dated 

D Resubmission in response to Agency tett81 dated D "Me Too" Application. ... ' .. D Notification - Explain below. D Other - Explain below. JAN 2 9 , , , I p'ge(s) if 'eees"" (Foe beetion I "d Seetion II.) 

~ on " III 

I 

~ -,.'" IL , Yes Yes Metal 

No :xc- No Ix No X Plastic 

I" 'y,," No. per ,,'y,," No. per Glass 

" Certification must Unit Packaging wgt. container Package wgt container Paper 

be submitted I Other (Specify) HOPE lined bags 

3. ;atNet , 4. Size(s Retail 5. lOt Labell 

m Label 0 Container 275 gallons, 30 gallons ~ On Label 

2.5 gallons On Labeling accompanying product 

6. Manner in Which Label is Affixed to Product ~ Lithograph CJ Other _adhesive backed label 

X Paper glued 

Stenciled 

" IV 

I~ I " to, 

~ame 

M. Bytd Ilio2123:2~~0"' I ,Atea Code) 

I I , LLC 

I certify that the statements I have made on this form and all attachments thereto are true, accurate and complete. t ' 6. Received 

acknowledge that any knowingly false or mIsleading statement may be punishable by fine or imprisonment or both 

under applicable law. (Stamped) 

2. , 13. Title 

~Jx&jrzlAgent tor RedEagle International LLC 

4. I yped Name 5. uate 

Catherine M. Byrd December 4, 2009 

I hiSi, a I ; 8570·1 (Rev. 8·' 'J I ,i ate I 

27
oEM 

1 . 

United Stales 

Environmental Protection Agency 

Washington, DC 20460 

2. , Productl 

RedEagle International LLC/85678-5 Tony Kish 

,.. 

RedEagle International LLC/Ethephon 6 

eM> 

22 

x 

Amendment 

Other 

I 

1 3. 

[8] None Restricted 

! 5. Nama ao" 'Zip Coda) 5.'_ i In 8ccordancewith FIFRA 13(c)(3) 

(b)(I), my product is similar or identical in composition and I Ii 

Red Eagle International LLC 

c/o Wagner Regulatory Associates, Inc. 

P.O. Box 640 

Hockessin, DE 19707 -0 Chack iffh,s ,s a naw, 

I in below. 

to: 

EPA Reg. No. 

Product Name: 

1j-. II 

o 

o 

Il<I 

Resubmission in response to Agency letter dated ____ _ 

~~:;~;i~;~~:~~:~~ in ,e"NOTIFle~' 2009 o "Me Too" Application, 

Notification - Explain below. o Other - Explain below. JAN 2 9 2010 

i is consistent With.:~e provisions of PR I . 2007-4 and the requirements of EPA's regulations 40 CFR §§ 156.10, 156.140, 

156.144, 156.146, and 156.156. No other changes have been made to the labeling or the Confidential Statement of Formula for this 

product. I understand that it is a violation of 18 U.S.C. Sec. 1001 to II make any false statements to EPA. I further understand that if 

the amended label is not consistent with the requirements of 40 CFR IlS 1! >.10 156,140. 1 fiR.144,. !56, 146, and 156.156, this product may 

ba i~ , of FIFRA and I >,ubjact i ,,;'d, ;~ ~ndar i ;,. and 14 of FIFRA. 

" This I 

=:J Yas' 

~No 

18, 

, 

Yas Ix No 

i If"Y,," 

lin; 

., Certification must 

be submffted 

Unit Packaging wgt. 

I 3. lol 

ill labal 

I 

D Container 

6. Manner in Which Label is Affixed to Product 

in' 

• 11/ 

Yes 

X No 

No.per IIf'Y"" No. per 

container Package wgt container 

I 

12. i 

Metal 

'-'I Xc--1 Plastic 

Glass 

/---1 Paper 

Other (Specify) HOPE lined bags 

4. "",e(or Retar! , 

bulk 

15 lollabel i i 

Ir1 On Label L.=J On Labeling accompanying product 

§ Lithograph 

X Paper glued 

Stenciled 

c:J Other _adhesive backed label' ____ _ 

• IV 

110 be' 

,I llC , 'Coda) 

I certify that the statements! have made on this fO/m and aU attachments thereto are true, accurate and complete. 

! acknowledge that any knOWingly false or misleading statement may be punishable by fine or imprisonment or , , , > 

, ' both I law. 

2, 

Signature 

4, Typad Name 

Catherine M. Byrd 

3, ntle 

Agent for RedEagle International LLC 

5. Date 

December 4, 2009 

This is a, 1 of EPA Form B570·1 (Rav, B·' 4) are 

(SwMped) 

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28
ETBEPBON6 

FOR COMMERCIAL USE OR 

AGRICULTURAL USE ONLY NOT INTENDED 

FOR RESIDENTIAL USE 

ACTIVE INGREDIENT: 

EPA approved FINAL LABEL 

Rev. 112812010 

NOTIFICATION 

JAN 2 9 2010 

Ethephon (2-Chloroethyl) phosphonlc acid* ... 

OTHER INGREDIENTS: 

. ..................... 54.0% 

TOTAL .. 

............... .46.0% 

........................ 100.0% 

This product contains 6.08 pounds ethephon per gallon. 

KEEP OUT OF REACH OF CHILDREN 

DANGER PELIGRO 

Si usted no entiende la etiqueta, 

I 

q",,,,,,a explique a usted en detalle. (If you do not 

IF IN EYES 

IFON SKIN OR 

CLOTHING: 

IF SWALLOWED: 

IF INHALED: 

You may also contact: 

• eye open 

• Remove contact lenses, if present 5 minutes, then continue rinsing eye 

• 

• i i 

• i immediately with of water for 15-20 minutes. 

· ; • Have person sip a glass of water if able to swallow. 

• 00 not i unless told to do so a poison control center or doctor. 

• person i 

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

p",'e'ably mouth to mouth if possible. 

~E:M:E:R:G:E:N:C:Y;N;U;M~B:E:R:S_, R.W~;~~~C~H~E~M~T~REC Poison Control (transportation Center (human and health) spills) 

I 

EPA Reg. No. 85678-5 EPA Establishment No. ___ _ 

NET CONTENTS: 275 gallons, 30 gallons or 2.5 gallons 

Manufactured For: 

RedEagle International LLC 

1925 E. Edgewood Drive 

Lakeland, Florida 33803 

1 

29
PRECAUTIONARY STATEMENTS 

DANGER 

HAZARDS TO HUMANS AND DOMESTIC ANIMALS 

EPA approved FINAL LABEL 

Rev. 1/28/2010 

Corrosive. Causes irreversible eye damage and skin burns. Harmful if swallowed or absorbed through skin. Do not 

get in eyes, on skin or on clothing. Prolonged or frequently repeated skin contact may cause allergic reactions in 

some individuals. 

PERSONAL PROTECTIVE EQUIPMENT (PPE) 

Some materials that are chemically resistant to this product are listed below. If you want more options, follow the 

instructions for Category A on an EPA chemical resistance category selection chart. 

Applicators and other handlers must wear: 

1. Coveralls over long-sleeved shirt and long pants. 

2. Chemical-resistant gloves made of any waterproof materials. 

3. Chemical~resistant footwear plus socks. 

4. Protective eyewear such as goggles, safety glasses or face shield. 

5. Chemical-resistant headgear for overhead exposure. 

6. Chemical-resistant apron when mixing or loading or cleaning equipment. 

Discard clothing and other absorbent materials that have been drenched or heavily contaminated with this product's 

concentrate. Do not reuse them. Follow manufacturer's instructions for cleaning and maintaining PPE. Ifno such 

instructions for washables exist, use detergent and hot water. Keep and wash PPE separately from other laundry. 

When handlers use closed systems, enclosed cabs, or aircraft in a manner that meets the requirements listed in the 

Worker Protection Standard (WPS) for agricultural pesticides 40 CFR 170.240.(d)(4-6), the handler PPE 

requirements may be reduced or modified as speCified in the WPS. 

USER SAFETY RECOMMENDATIONS 

Users should: 

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

2. Remove clothing/PPE immediately if pesticide gets inside. Then wash body thoroughly and put 

on clean clothing. 

3. Remove clothing/PPE immediately after handling this product. Wash the outside of gloves before 

removing. As soon as possible, wash thoroughly and change into clean clothing. 

ENVIRONMENTAL HAZARDS 

Do not apply directly to water, or to areas where surface water is present or to intertidal areas below the mean high 

water mark. Do not contaminate water when disposing of equipment washwaters. Do not contaminate water used 

for irrigation or domestic purposes. 

USE PRECAUTIONS 

Do not apply Ethephon 6 through any type of irrigation system. 

Do not plant another crop within 30 days after treatment. 

Mix only the amount of spray you expect to use each day. Do not allow mixed solution to stand overnight. 

Avoid spray drift to nearby crops as this product will cause modifications in plant growth. Plant injury or reduced 

yields will result. 

AVOIDING SPRAY DRIFT AT THE APPLICATION SITE IS THE RESPONSIBILITY OF THE APPLICATOR. 

The interactions of many equipment-and-weatheHelated factors determine the potential for spray drift. The 

applicator is responsible for considering all these factors when making decisions. 

The following drift management requirements must be followed to avoid off-target movement from aerial 

applications to agricultural field crops. These requirements do not apply to forestry applications, public health 

uses or to applications using dry formulations. 

1. The distance of the outer most nozzles on the boom must not exceed 3/4 the length of the wingspan or 

rotor. 

2. Nozzles must always point backward parallel with the air stream and never be pointed downwards more 

than 45 degrees. 

Where states have more stringent regulations, they should be observed. 

AERIAL DRIFT REDUCTION 

ADVISORY Information on droplet size: 

The most effective way to reduce drift potential is to apply large droplets. The best drift management strategy is to 

apply the largest droplets that provide sufficient coverage and control. APplying larger droplets reduces drift 

potential, but will not prevent drift if applications are made improperly, or under unfavorable environmental conditions 

2 

30
(See Wind, Temperature and Humidity, and Temperature Inversions). 

Controlling droplet sIze: 

EPA approved FINAL LABEL 

Rev. 112812010 

Volume - Use high flow rate nozzles to apply the highest practical spray volume. Nozzles with higher rated flows 

produce larger droplets. Pressure - Do not exceed the nozzle manufacturer's recommended pressures. For many 

nozzle types lower pressure produces larger droplets. When higher flow rates are needed, use higher flow rate 

nozzles instead of increasing pressure. 

Number of Nozzles - Use the minimum number of nozzles that provide uniform coverage. 

Nozzle Orientation - Orienting nozzles so that the spray is released parallel to the airstream produces larger 

droplets than other orientations and is the recommended practice. Significant deflection from horizontal will reduce 

droplet size and increase drift potential. 

Nozzle Type - Use a nozzle type that is designed for the intended application. With most nozzle types, narrower 

spray angles produce larger droplets. Consider using low-drift nozzles. Solid stream nozzles oriented straight back 

produces the largest droplets and the lowest drift. 

BOOMLENGTH 

For some use pattems, reducing the effective boom length to less than 3/4 of the wingspan or rotor length may 

further reduce drift without reducing swath width. 

APPLICATION HEIGHT 

Applications should not be made at a height greater than 10 feet above the top of the target plants unless a greater 

height is required for aircraft safety. Making applications at the lowest height that is safe reduces exposure of droplets 

to evaporation and wind. 

SWATH ADJUSTMENT 

When applications are made with a crosswind, the swath will be displaced downwind. Therefore, on the up and 

down edges of the field, the applicator should compensate for the displacement by adjusting the path of the aircraft 

upwind. Swath adjustment distance should increase, with the increasing drift potential (higher wird, smaller drops, 

etc.). 

WIND 

Drift potential is lowest between winds speeds of 2 -10 mph. However, many factors, inCluding droplet size and 

equipment type determine drift potential at any given speed. Application should be avoided below 2 mph due to 

variable wind direction and high inversion potential. NOTE: Local terrain can influence wind patterns. Every 

applicator should be familiar with local wind patterns and how they affect spray drift. 

TEMPERATURE AND HUMIDITY 

When making applications in low relative humidity, set up equipment to produce larger droplets to compensate for 

evaporation. Droplet evaporation is most severe when conditions are both hot and dry. 

TEMPERATURE INVERSIONS 

Applications should not occur during a temperature inversion because drift potential is high. Temperature inversions 

restrict vertical air mixing, which causes small suspended droplets to remain in a concentrated cloud. This cloud 

can move in unpredictable directions due to light variable winds common during inversions. Temperature 

inversions are characterized by increasing temperatures with altitude and are common on nights with limited cloud 

cover and light to no wind. They begin to form as the sun sets and often continue into the morning. Their presence 

can be indicated by ground fog; however, if fog is not present, inversions can also be identified by the movement of 

smoke from a ground source or an aircraft smoke generator. Smoke that layers and moves laterally in a 

concentrated cloud (under low wind conditions) indicates an inversion, while smoke that moves upward and rapidly 

dissipates indicates good vertical air mixing. 

SENSITIVE AREAS 

The pesticide should only be applied ...nen the potential for drift to adjacent sensitive areas (e.g. residential areas, 

bodies of water, known habitat for threatened or endangered species, non-target crops) is minimal (e.g., when wind 

is blowing away from the sensitive areas). 

DIRECTIONS FOR USE 

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

Do not apply this product in a way that will contact workers or other persons, either directly or through drift. Only 

protected handlers may be in the area during application. For any requirements speCific to your State or Tribe, 

consult the agency responsible for pesticide regulation. 

3 

31
AGRICULTURAL USE REQUIREMENTS 

EPA approved FINAL LABEL 

Rev. 1/28/2010 

Use this product only in accordance with its labeling and with the Worker Protection Standard, 40 CFR part 170. 

This standard contains requirements for the protection of agricultural workers on farms, forests, nurseries, and 

greenhouses, and handlers of agricultural pesticides. It contains requirements for training, decontamination, 

notification, and emergency assistance. It also contains specific instructions and exceptions pertaining to the 

statements on this label about personal protective equipment, notification to workers, and restricted-entry 

intervals. The requirements in this box only apply to uses of this product that are covered by the Worker 

Protection Standard. 

Do not enter or allow worker entry into treated areas during the restricted-entry interval (REI) of 48 hours. 

The REI increases to 72 hours in outdoor areas where average rainfall is less than 25 inches a year. 

PPE required for early entry to treated areas that is permitted under the Worker Protection Standard and that 

involves contact with anything that has been treated such as plants, soil, or water, is: 

1. Coveralls over short-sleeved shirt and short pants. 

2. Chemical resistant gloves made of any waterproof material. 

3. Chemical-resistant footwear plus socks. 

4. Protective eyewear such as goggles, safety glasses or face shield. 

5. Chemical-resistant headgear for overhead exposure. 

Notify workers of the application by warning them orally and by posting warning signs at entrances to treated 

areas. 

STORAGE AND DISPOSAL 

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

PESTICIDE STORAGE 

If container is broken or contents have spilled, follow all precautions indicated above and clean up immediately. 

Before cleaning up, put on full length trousers, long sleeved shirt, protective gloves, and goggles or face shield. Soak 

up spill with absorbent media such as sand, earth or other suitable material and dispose of waste at an approved 

waste disposal facility. 

PESTICIDE DISPOSAL 

Pesticide wastes are acutely hazardouS. Improper disposal of excess pesticide, spray mixture, 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. 

For containers less than 5 gallons 

Container Disposal: Nonrefillable container. Do not reuse or refill this container. Triple rinse container (or 

equivalent) promptly after emptying. Triple rinse as follows: Empty the remaining contents into application equipment 

or a mix tank and drain for 10 seconds after the flow begins to drip. Fill the container Y. full with water and recap. 

Shake for 10 seconds. Pour rinsate into application equipment or a mix tank or store rinsate for later use or disposal. 

Drain for 10 seconds after the flow begins to drip. Repeat this procedure two more times. Then offer for recycling, if 

available or puncture and dispose of in a sanitary landfill, or by incineration, or, if allowed by state and local 

authorities, by burning. If burned, stay out of smoke. 

For containers greater than 5 gallons 

Container Disposal: Nonrefillable container. Do not reuse or refill this container. Triple rinse container (or 

equivalent) promptly after emptying. Triple rinse as follows: Empty the remaining contents into application equipment 

or a mix tank. FiU the container Y4 full with water. Replace and tighten closures. Tip container on its side and roll it 

back and forth, ensuring at least one complete revolution, for 30 seconds. Stand the container on its end and tip it 

back and forth several times. Turn the container over onto its other end and tip it back and forth several times. Empty 

the rinsate into application equipment or a mix tank or store rinsate· for later use or disposal. Repeat this procedure 

two more times. Then offer for recycling, if available, or puncture and dispose of in a sanitary landfill, or by 

incineration, or, if allowed by state and local authorities, by burning. If burned, stay out of smoke. 

GENERAL INFORMATION 

COTTON 

A foliar spray of Ethephon 6 will accelerate opening of mature unopened cotton bolls and enhance defoliation which 

can result in earlier harvest with an increased recoverable yield. Ethephon 6 treatment allows increased efficiency 

from a once-over harvest. 

TOBACCO (FLUE-CURED) 

A foliar spray of Ethephon 6 promotes early, uniform "yellowing" of mature tobacco. Ethephon 6 reduces curing 

time, allowing more efficient use of curing bam space, and increased control over harvest schedules. 

4 

32
SPRAY PREPARATION 

EPA approved FtNAL LABEL 

Rev. 1/28/2010 

Add 1/2 to 3/4 of the required amount of water to the spray tank, Start agitation. Add the required amount of 

Ethephon 6, and the remaining amount of water. Prepare only as much spray solution as can be used on the day of 

mixing. Do not allow spray solution to stand overnight. Do not spill the concentrated product on spray equipment, or 

any airplane parts. 

ANY SPILLS SHOULD BE RINSED IMMEDIATELY WITH PLENTY OF WATER. 

Use of a nurse tank is highly recommended for avoiding possible spills of concentrated formulation on spray 

equipment or any airplane parts. 

TANK MIXTURES WITH DEFOLIANTS AND INSECTICIDES 

Follow all appllcable use precautions and rate per acre recommendations on labels of products applied as tank 

mixtures or in sequence with Ethephon 6. In some cases slight reduction in boll opening response has been 

observed when tank mixes with defoliants were used. 

Good agitation in the spray tank is essential and a tank mixture should not be allowed to stand without agitation for 

more than 5 to 10 minutes, Read and observe all appropriate label use directions and precautions for the 

defoliants and insecticides used. 

DO NOT MIX WITH DESICCANTS IF COnON IS TO BE SPINDLE HARVESTED. 

DO NOT TANK MIX ETHEPHON 6 WITH DEFOLIANTS CONTAINING SODIUM CHLORATE BECAUSE THIS 

RESULTS IN THE FORMATION OF HYPOCHLOROUS ACIDS WHICH UPON HEATING EMIT TOXIC CHLORINE 

FUMES. 

EQUIPMENT CLEANING 

Because of the acidic nature of this product, prolonged exposure to spray deposits will damage acrylic plastics, 

certain paints, and metals, 

Rinse thoroughly with a detergent and water all exposed acrylic plastic-type materials (e.g., aircraft windsh'lelds), 

and painted surfaces within an hour after exposure to spray depOSits. 

At the end of each day, rinse thoroughly with a detergent and water all the metal parts of the aircraft and the 

associated spray equipment exposed to the spray deposits. 

conON 

ETHEPHON 6 ONE GALLON 

EXPECTED RATE ETHEPHON 6 SPRAY VOLUME 

uSE CONDITIONS TREATS APPLICATION TIMING 

PINT/A LBSAI ACRES GROUND AIR" 

Hot and dry BO°F or 1 113 10 6 higher Apply when the number of 

Dry and 75 F to 80 F 2 '.5 4 mature unopened boils is 

sufficient to produce Ihe 

ETHEPHON 6' 15-50 2-5 desired crop, See below for 

Cool but above 65 F test of boll maturity, 

" 22/3 2 3 Treatment uniform Iy opens 

Rank cotton bolls 7 to f4 days earlier 

ETHEPHON 6 High soil moisture Apply 4 to 7 days prior to 

, " Ethephon 6 boll opening 

FOLEX High fertility level '" .25 24 t5-50 5-tO application, To be used as a 

Oetoliant Tank " sequen~al treatm ent w'lth, not 

Mix Rank cotton in place of Ethephon 6 boll 

opening treatment, 

High soil mOisture Apply 4 to 7 days prior to 

ETHEPHON 6 Ethephon 6 boil opening 

+ OROPP " application To be used as a High fertility level 1/3 .25 24 10-50 3-10 Defoliant Tank 

" sequential treatm ent with, 

Mix Rank cotton not in place of Ethephon 6 

boll opening treatment. 

5 

33
Hot, dry, above 80 F 2/3 .5 

PreConditioner 

foe Cool, above 6S'F 

Defoliation oc 1 1/3 1.0 

Rank. cotton 

12 

15-50 2-5 

6 

EPA approved FINAL LABEL 

Rev, 1128/2010 

Apply 4 to 7 days prior to 

defoliant. 

Enhances top crop defolialion 

reducing deterioration of 

bottom crop and allOWS for 

earlier harvest. 

• Pretreatment With Defoliants Pnor to Ethephon 6 Treatment 

If the cotton is overly rank or laying down in the middles and good spray coverage of the bolls with Ethephon 6 is 

difficult, a pretreatment with defoliants will be useful to improve boll coverage with Ethephon 6. Use dosage rates 

of Ethephon 6 recommended for boll opening. 

Read and observe all appropriate label use directions and precautions for the defoliant used. 

**NOTE: For California and Arizona use a volume of no less than 5 gallons per acre for aerial applications. 

Boll Maturity 

A boll is mature when it is too hard to be dented when squeezed between thumb and fingers, too hard to be sliced 

with a sharp knife, and when the seed coat becomes light brown in color. 

Use Limitations 

• Do not exceed a maximum of 2.0 lb. ailA for combined uses of Ethephon 6 (or other ethephon containing 

products) per acre per year. 

• Boll Opening: Do not tank mix Ethephon 6 with a desiccant if the cotton is to be spindle harvested, 

• Pre-Condition for Defoliation: 00 not tank mix Ethephon 6 with desiccants unless plant desiccation is required. 

Do not use a defoliant before there is sufftcient mature unopened bolls to produce the desired yield {see General 

Information section on how to test for boll maturity}. 

When to Harvest 

Do not harvest cotton sooner than 7 days after a treatment with Ethephon 6. Observe the treated crop and harvest 

when optimum boll opening has been reached. Too early harvest might reduce the full advantage of the treatment 

and too late a harvest may result in reduced quality and loss of lint which will drop from the plant. 

TOBACCO (Flue-Cured OnJvJ 

SPRAY 

CROP ETHEPHON 6 VOLUME SPECIFIC DIRECTIONS SITUATION PINTS/ACRE GALLONS! 

ACRE 

Use drop nozzles. Choose TG or OC spray tips designed to apply 50-

Directed 60 gpa at 35- 40 psi and at tractor speed of2-3 mph. Use 2 nozzles 

Spray 1 1/3 50-60 per row; one on each side of the row dropped low enough to direct 

Application the spray to the leaves to be ripened and harvested. Thorough spray 

coverage is essential. With a directed spray, be sure to harvest all 

leaves with 20% or more yellowing. 

Treat only when leaves remaining on the stalk are mature. To 

ensure remaining leaves are mature, test spray several tobacco 

plants as described under the section "Application Timing." Use the 

lower rate in a nonnally mature crop when experience indicates that 

minimum ripening inducement is required. Use the higher rate when 

the crop is heavy and has a tendency to be more rank or when 

Over-The- temperatures are lower than nonnai. Arways test spray to detennine if 

Top 1 1/3-22/3 40-60 the tobacco is mature enough to respond to treatment with 

Application Ethephon 6, 

Apply over-the~top Ethephon 6 spray as a fine mist using three 

nozzles {one nozzle tip over the center of the plant, and one on each 

side} so all leaves are covered thoroughly, similar to the application 

pattern of systemiC sucker control agents. Use a spray pressure of 

40 to 60 pSi. I 

USE LIMITATIONS 

·00 not apply Ethephon 6 to immature leaves as this can result in unsatisfactory coloring, weight loss and 

6 

34
reduced leaf quality. 

EPA approved FINAL LABEL 

Rev. 1128/2010 

·00 not allow the crop to over ripen in the field after using Ethephon 6, since this may cause some reduction in 

yield and quality. 

·00 not treat before anticipated major storm which could prevent harvest and result in crop loss. 

'00 not apply Ethephon 6 if rain is expected within 4 hours. 

APPLICATION TIMING 

Successful results with Ethephon 6 call for treatment when leaves are mature, not overly rank green when sprayed. 

To easily determine the proper treatment timing and the number of leaves per stalk ready for harvest, test spray 

several plants in more than one location in each field and observe the response. Mature leaves will begin to yellow 

in 24 to 72 hours. Test leaves that fail to yellow in 72 hours are not mature and are not ready for Ethephon 6 

treatment. Wait a few days to permit further natural maturing, then make another test spray or "maturity" check. 

When you have confirmed the number of leaves per plant that will color, you can determine the number of acres to 

treat in order to fill the barn. 

TEST SPRAY MIXTURE DIRECTIONS 

Prepare your test spray by mixing one teaspoon of Ethephon 6 in 1 quart of water. Spray each test plant with about 

1 oz of this mixture, covering all leaves with a fine mist. Ethephon 6 will not color immature sprayed leaves. 

WHEN TO HARVEST 

All mature, sprayed leaves will begin to color within 24 to 72 hours after Ethephon 6 application. The yellowing 

process is weather dependent; cool weather will delay, while hot, sunny weather can speed up the process_ Harvest 

treated tobacco when leaves have reached the desired color intensity. 

Do not allow tobacco to become over ripe before starting harvest. Leaf drop can occur when tobacco is over ripe 

and left on the stalk. If a number of the bottom leaves have yellowed at the time of treatment, they should be 

harvested prior to spraying with Ethephon 6. 

With an over-the-top application, harvesting can commence 48 hours after Ethephon 6 application depending on 

weather conditions or to avoid over ripe tobacco. Tobacco harvested 48 hours after treatment may require more 

time in the coloring phase of the curing process. 

CURING ETHEPHON 6 TREATED TOBACCO 

Curing procedures are as much an art as a science and each cure must be judged on the basis of tobacco condition, 

interval between treatment and harvest, weather and type of curing facility before prescription temperature and 

ventilation schedules can be established. To obtain maximum quality, care must be taken to observe and control the 

curing process closely. especially during the late "coloring" and early "drying" stages of the leaf. 

Ethephon 6 treated tobacco will have started the coloring process when harvested, reducing the time required in the 

coloring phase of curing. Treated tobacco should be dried faster. If tobacco leaves are green or contain some green 

when harvested, it may be necessary to color them for a few hours. If the leaves are completely yellow, temperature 

and ventilation must be adiusted in a manner to dry the tobacco as fast as possible without scalding. Once the leaf 

is dried (3f4 dry), you should follow nonnal procedures for curing. Since Ethephon 6 treated leaves cure faster, 

treated and untreated leaves should not be cured together in the same barn. 

REDEAGLE INTERNATIONAL LLC WARRANTS THAT THIS PRODUCT CONFORMS TO THE CHEMICAL 

DESCRIPTION ON THE LABEL THEREOF AND IS REASONABLY FIT FOR THE PURPOSE STATED ON SUCH 

LABEL ONLY WHEN USED IN ACCORDANCE WITH THE DIRECTIONS FOR USE 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 WEATHER CONDITIONS, PRESENCE OF OTHER MATERIALS, OR THE MANNER OF USE OR 

APPLICATION, ALL OF WHICH ARE BEYOND THE CONTROL OF REDEAGLE INTERNATIONAL LLC. TO THE 

EXTENT CONSISTENT WITH THE APPLICABLE LAW IN NO CASE SHALL REDEAGLE INTERNATIONAL LLC 

BE LIABLE FOR THE CONSEQUENTIAL, SPECIAL OR INDIRECT DAMAGES RESULTING FROM THE USE OR 

HANDLING OF THIS PRODUCT TO THE EXTENT CONSISTENT WITH APPLICABLE LAW ALL SUCH RISKS 

SHALL BE ASSUMED BY THE BUYER. EXCEPT AS EXPRESSLY PROVIDED HEREIN, REDEAGLE 

INTERNATIONAL LLC MAKES NO WARRANTIES, GUARANTEES, OR REPRESENTATIONS OF ANY KIND, 

EITHER EXPRESS OR IMPLIED, OR BY USAGE OF TRADE, STATUTORY OR OTHERWISE, WITH REGARD 

TO THE PRODUCT SOLD, INCLUDING BUT NOT UMITED TO, MERCHANTABILITY, FITNESS FOR A 

PARTICULAR PURPOSE, USE OR ELIGIBILITY OF THE PRODUCT FOR ANY PARTICULAR TRADE USAGE. 

7 

35
EPA approved FINAL lABEL 

Rev. 1214/2009 

ETBEPBON6 

FOR COMMERCIAL USE OR 

AGRICULTURAL USE ONLY NOT INTENDED 

FOR RESIDENTIAL USE 

ACTIVE INGREDIENT: 

Ethephon (2-Chloroethyl) phosphonic acid*. . ... ...... ..... . ..... 54.0% 

OTHER INGREDIENTS: .. ........................... ............... . ...... .46.0% 

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

This product contains 6.08 pounds ethephon per gallon. 

KEEP OUT OF REACH OF CHILDREN 

DANGER PELIGRO , busqu,~e "','~"~~~npar',q"C se la explique a usted en detalle. (If you do not 

• 15-20 minutes. 

IF IN EYES • 

open and rinse slowly 

contact lenses, if present 

with 

first 5 then continue rinsing eye 

IFONSKINOR 

CLOTHING: 

• 

• 

• Rinse skin 

" 

of water for 15·20 minutes. 

• i control or doctor i 

• Have person sip a glass of water if able to swallow. IF SWALLOWED: • Do not induce vomiting unless told to do so a poison control center or doctor. 

; , • Move person to fresh air. 

IF INHALED: • If person is not breathing, call 911 or an ambulance, then give artificial respiration, 

preferably mouth to mouth if possible. 

• II I 

You may also contact 

EMERGENCY NUMBERS: W,onspoct,bon and spills) 

(human health) 

oc 

EPA Reg. No. 85678--5 EPA Establishment No. _~,_ 

NET CONTENTS:, _______ _ 

}.'(/I -".' >! !-'."';TJ) 

'. "".'-r'" -(( \·"iih " r!r,lif"'(" f:%-2 Manufactured For: .,.c.c,._ 1/ .'. _ RedEagle Internaltonal LLC 

'?~.C';d on Dr?ft J.8. f ,-li'1p, l . .f::l:ed 1925 E. Edgewood Drive 

/ ... lakeland, Florida 33803 /1- :!j -~ t)~L ___ , ____ ,_ 

1 

'" , 

. '.', 

",,;~ , 

" , 

, ." 

'" . '" , 

" " 

36
, 

c 

EPA approved FINAL LABEL 

Rev. 1214/2009 

PRECAUTIONARY STATEMENTS 

DANGER 

HAZARDS TO HUMANS AND DOMESTIC ANIMALS 

Corrosive. Causes irreversible eye damage and skin burns. Harmful if swallowed or absorbed through skin. Do not 

get in eyes, on skin or on clothing. Prolonged or frequently repeated skin contact may cause allergic reactions in 

some individuals. 

PERSONAL PROTECTiVE EQUIPMENT (PPE) 

Some materials that are chemically resistant to this product are listed below. If you want more options, follow the 

instructions for Category A on an EPA chemical resistance category selection chart. 

Applicators and other handlers must wear; 

1. Coveralls over long-sleeved shirt and long pants. 

2. Chemical·resistant gloves made of any waterproof materials. 

3. Chemical-resistant footwear plus socks. 

4. Protective eyewear such as goggles, safety glasses or face shield. 

5. Chemical·resistant headgear for overhead exposure. 

6. Chemical-resistant apron when mixing or loading or cleaning equipment. 

Discard clothing and other absorbent materials that have been drenched or heavily contaminated with this product's 

concentrate. Do not reuse them. Follow manufacturer's instructions for cleaning and maintaining PPE. If no such 

instructions for washables exist, use detergent and hot water. Keep and wash PPE separately from other laundry. 

When handlers use closed systems, enclosed cabs, or aircraft in a manner that meets the requirements listed in the 

Worker Protection Standard (WPS) for agricultural pesticides 40 CFR 170.240.{d){4-6), the handler PPE 

requirements may be reduced or modified as specified in the WPS. 

USER SAFETY RECOMMENDATIONS 

Users should: 

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

2. Remove clothing/PPE immediately if pestiCide gets inside. Then wash body thoroughly and put 

on clean clothing. 

3. Remove clothing/PPE immediately after handling this product. Wash the outside of gloves before 

removing. As soon as possible, wash thoroughlY and change into clean clothing. 

ENVIRONMENTAL HAZARDS 

Do not apply directly to water, or to areas where surface water is present or to intertidal areas below the mean high 

water mark. Do not contaminate water when dispOSing of equipment washwaters. Do not contaminate water used 

for irrigation or domestic purposes. 

USE PRECAUTIONS 

Do not apply Ethephon 6 through any type of irrigation system. 

Do not plant another crop within 30 days after treatment. 

Mix only the amount of spray you expect to use each day. Do not allow mixed solution to stand overnight. 

Avoid spray drift to nearby crops as this product will cause modifications in plant growth. Plant injury or reduced 

yields will result. 

AVOIDING SPRAY DRIFT AT THE APPLICATION SITE IS THE RESPONSIBILITY OF THE APPLICATOR. 

The interaction of many equipment-and-weatheHelated factors determine the potential for spray drift. The 

applicator is responsible for considering all these factors when making decisions. 

The following drift management requirements must be followed to avoid off-target movement from aerial 

applications to agricultural field crops. These requirements do not apply to forestry applications, public health 

uses or to applications using dry formulations. 

1. The distance of the outer most nozzles on the boom must not exceed 3/4 the length of the wingspan or 

rotor. • • 

2. Nozzles must always point backward parallel with the air stream and never be pointed downward:rMre' 

than 45 degrees. > > 

Where states have more stringent regulaflons, they should be observed. ; . , , j ; 

, , 

AERIAL DRIFT REDUCTION . , , , , , > " , , • , ADVISORY Information on droplet size: , , 

The most effective way to reduce drift potential is to apply large droplets. The best drift management strateqy I$"to > 

apply the largest droplets that provide sufficient coverage and control. Applying larger dropletS r£dubs drift ~ , • , j 

potential, but will not prevent drift if applications are made improperly, or under unfavorable eo;'r~:1mental conditions , , > , 

2 j , , , 

, , " 

37
(See Wind, Temperature and Humidity, and Temperature Inversions). 

Controlling droplet size: 

EPA approved FINAL LABEL 

Rev. 12/412009 

Volume ~ Use high flow rate nozzles to apply the highest practical spray volume. Nozzles with higher rated flows 

produce larger droplets. Pressure ~ Do not exceed the nozzle manufacturer's recommended pressures. For many 

nozzle types lower pressure produces larger droplets. When higher flow rates are needed, use higher flow rate 

nozzles instead of increasing pressure. 

Number of Nozzles ~ Use the minimum number of nozzles that provide uniform coverage. 

Nozzle Orientation ~ Orienting nozzles so that the spray is released parallel to the airstream produces larger 

droplets than other orientations and is the recommended practice. Significant deflection from horizontal will reduce 

droplet size and increase drift potential. 

Nozzle Type - Use a nozzle type that is designed for the intended application. With most nozzle types, narrower 

spray angles produce larger droplets. Consider using low~drift nozzles. Solid stream nozzles oriented straight back 

produces the largest droplets and the lowest drift. 

BOOMLENGTH 

For some use patterns, reducing the effective boom length to less than 3/4 of the wingspan or rotor length may 

further reduce drift without reducing swath width. 

APPLICATION HEIGHT 

Applications should not be made at a height greater than 10 feet above the top of the target plants unless a greater 

height is required for aircraft safety. Making applications at the lowest height that is safe reduces exposure of drople1s 

to evaporation and wind. 

SWATH ADJUSTMENT 

When applications are made with a crosswind, the swath will be displaced downwind. Therefore, on the up and 

down edges of the field, the applicator should compensate for the displacement by adjusting the path of the aircraft 

Upwind. Swath adjustment distance should increase, with the 'Increasing drlft potent"lal (higher wind, smalJer drops, 

etc.). 

WlND 

Drift potential is lowest between winds speeds of2 -10 mph. However, many factors, including droplet size and 

equipment type determine drift potential at any given speed. Application should be avoided below 2 mph due to 

variable wind direction and high inversion potential. NOTE: Local terrain can influence wind pattems. Every 

applicator should be familiar with local wind pattems and how they affect spray drift. 

TEMPERATURE AND HUMIDITY 

When making applications in low relative humidity, set up equipment to produce larger droplets to compensate for 

evaporation. Droplet evaporation is most severe when conditions are both hot and dry. 

TEMPERATURE INVERSIONS 

Applications should not occur during a temperature inversion because drift potential is high. Temperature inversions 

restrict vertical air mixing, which causes small suspended droplets to remain in a concentrated cloud. This cloud 

can move in unpredictable directions due to light variable winds common during inversions. Temperature 

inversions are characterized by increasing temperatures with altitude and are common on nights with limited cloud 

cover and light to no wind. They begin to form as the sun sets and often continue into the morning. Their presence 

can be indicated by ground fog; however, if fog is not present, inversions can also be identified by the movement of 

smoke from a ground source or an aircraft smoke generator. Smoke that layers and moves laterally in a 

concentrated cloud (under low wind conditions) indicates an inversion, while smoke that moves upward and rapidly 

dissipates indicates good vertical air mixing. 

SENSITIVE AREAS 

The pestiCide should only be applied when the potential for drift to adjacent sens"itive areas (e.g. residential areas, 

bodies of water, known habitat for threatened or endangered species, non-target crops) is minimal (e.g., whon wird 

is blowing away from the sensitive areas). : ~ > >, • 

DIRECTIONS FOR USE > > 

It is a violation of Federal law to use this product in a manner inconsistent with its labeling. ',»,) ; >, > 

Do not apply this product in a way that will contact workers or other persons, either directly o~ throuf;h drift. Onl~ 

protected handlers may be in the area during application. For any requirements specific to your State or Tripe, 

consult the agency responsible for pesticide regulation. ' , ) , , ) , 'J , ;" , 

, ) J , 

" , > > , , 

") , 

3 

38
EPA approved FINAL LABEL 

Rev. 1214/2009 

AGRICULTURAL USE REQUIREMENTS 

Use this product only in accordance with its labeling and with the Worker Protection Standard, 40 CFR part 170. 

This standard contains requirements for the protection of agricultural workers on farms, forests, nurseries, and 

greenhouses, and handlers of agricultural pesticides. It contains requirements for training, decontamination, 

notification, and emergency assistance. It also contains specific instructions and exceptions pertaining to the 

statements on this label about personal protective equipment, notification to workers, and restricted-entry 

intervals. The requirements in this box only apply to uses of this p-oduct that are covered by the Worker 

Protection Standard. 

Do not enter or allow worker entry into treated areas during the restricted-entry interval (REI) of 48 hours. 

The REI increases to 72 hours in outdoor areas where average rainfall is less than 25 inches a year. 

PPE required for early entry to treated areas that is permitted under the Worker Protection Standard and that 

involves contact with anything that has been treated such as plants, soil, or water, is: 

1. Coveralls over short-sleeved shirt and short pants. 

2. Chemical resistant gloves made of any waterproof material. 

3. Chemical-resistant footwear plus socks. 

4. Protective eyewear such as goggles, safety glasses or face shield. 

5. Chemical-resistant headgear for overhead exposure. 

Notify workers of the application by waming them orally and by posting warning signs at entrances to treated 

areas. 

STORAGE AND DISPOSAL 

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

PESTICIDE STORAGE 

If container is broken or contents have spilled, follow all precautions indicated above and clean up immediately. 

Before cleaning up, put on full length trousers, long sleeved shirt, protective gloves, and goggles or face shield. Soak 

up spill with absorbent media such as sand, earth or other suitable material and dispose of waste at an approved 

waste disposal facility. 

PESTICIDE DISPOSAL 

Pesticide wastes are acutely hazardoUs. Improper disposal of excess pesticide, spray mixture, 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 

Nonrefillable container: Do not reuse or refill this container. Triple rinse container (or equivalent) promptly after 

emptying. Triple rinse as follows: Empty the remaining contents into application equipment or a mix tank. Fill the 

container Yo full with water. Replace and tighten closures. Tip container on its side and roll it back and forth, ensuring 

at least one complete revolution, for 30 seconds. Stand the container on its end and tip it back and forth several 

times. Tum the container over onto its other end and tip it back and forth several times. Empty the rinsate into 

application equipment or a mix tank or store rinsate for later use or disposal. Repeat this procedure two more times. 

Then offer for recycfing or reconditioning, or puncture and dispose of in a sanitary landfill, or by Incineration or if 

allowed by state and local authorities, by burning. If container is bumed, stay out of smoke. 

GENERAL INFORMATION 

COTTON 

A foliar spray of Ethephon 6 will accelerate opening of mature unopened cotton bolls and enhance defoliation which 

can result in earlier harvest with an 'lncreased recoverable yield. Ethephon 6 treatment allows increased efficiency 

from a once-over harvest. 

TOBACCO (FLUE-CURED) 

A foliar spray of Ethephon 6 promotes early, uniform "yellowing" of mature tobacco. Ethephon 6 reduces curing 

time, allowing more efficient use of curing bam space, and increased control over harvest schedules. 

" , '" 

SPRAY PREPARATION 

Add 1f2 to 3f4 of the required amount of water to the spray tank. Start agitation. Add the requi~ il1Q1Punt of .. 

Ethephon 6, and the remaining amount of water. Prepare only as much spray solution as canePe l,seJ on the day'of 

mixing. Do not allow spray solution to stand overnight. Do not spill the concentrated product on spray- equipment, or 

any airplane parts. .,. ~ "" t'" . " . , • 

ANY SPILLS SHOULD BE RINSED IMMEDIATELY WITH PLENTY OF WATER. ,,' , 

Use of a nurse tank is h!ghly recommended for avoiding possible spills of concentrated forrnuh!iCl"D !"lr. spray 

equipment or any airplane parts. 

4 

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39
EPA approved FINAL LABEL 

Rev. 121412009 

If the cotton is overly rank or laying down in the middles and good spray coverage of the bolls with Ethephon 6 is 

difficult, a pretreatment with defoliants will be useful to improve bOil coverage with Ethephon 6. Use dosage rates 

of Ethephon 6 recommended for boll opening. 

Read and observe all appropriate label use directions and precautions for the defoUant used. 

""NOTE: For California and Arizona use a volume of no less than 5 gallons per acre for aerial applications. 

Boll Maturity 

A boll is mature when it is too hard to be dented when squeezed between thumb and fingers, too hard to be sliced 

with a sharp knife, and when the seed coat becomes light brown in color. 

Use limitations 

• Do not exceed a maximum of 2.0 lb. ailA for combined uses of Ethephon 6 (or other ethephon containing 

products) per acre per year. 

• Boll Opening: Do not tank mix Ethephon 6 with a desiccant if the cotton is to be spindle harvested. 

• Pre-Condition for Defoliation: Do not tank mix Ethephon 6 with desiccants unless plant desiccation is required. 

Do not use a defoliant before there is sufficient mature unopened bolls to produce the desired yield (see General 

Information section on how to test for boll maturity). 

When to Harvest 

Do not harvest cotton sooner than 7 days after a treatment with Ethephon 6. Observe the treated crop and harvest 

when optimum boll opening has been reached. Too early harvest might reduce the full advantage of the treatment 

and too late a harvest may result in reduced quality and loss of flnt which will drop from the plant 

TOBACCO (Flue-Cured Onlv) 

SPRAY 

CROP ETHEPHON6 VOLUME SPECIFIC DIRECTIONS SITUATION PINTS/ACRE GALLONS! 

ACRE 

Use drop nozzles. Choose TG or OC spray tips designed to apply 50-

Directed 60 gpa at 35- 40 psi and at tractor speed of 2-3 mph. Use 2 nozzles 

Spray 1 1/3 50-60 per row; one on each side of the row dropped low enough to direct 

Application the spray to the leaves to be ripened and harvested. Thorough spray 

coverage is essential. With a directed spray, be sure to harvest all 

leaves with 20% or more yellowing. 

Treat only when leaves remaining on the stalk are mature. To 

ensure remaining leaves are mature, test spray several tobacco 

plants as described under the sec~on "Application Timing." Use the 

lower rate in a normally mature crop when experience indicates that 

minimum ripening inducement is required. Use the higher rate when 

the crop is heavy and has a tendency to be more rank or when 

Over-The- temperatures are lower than normal. Always test spray to determine if 

Top 1 1/3-22/3 40-60 the tobacco is mature enough to respond to treatment with 

Application Ethephon 6. 

Applyover -the-top Ethephon 6 spray as a fine mist using three 

nozzles (one nozzle tip over the center of the plant, and one on each 

side) so all leaves are covered thoroughly, similar to the application 

pattern of systemic sucker control agents. Use a spray pressure of 

40 to 60 psi. I 

USE LIMITATIONS , > 

·00 not apply Ethephon 6 to immature leaves as this can result in unsatisfactory coloring, weight loss and :., j , , 

reduced leaf quality. • • 

'00 not allow the crop to over ripen in the field after using Ethephon 6, since this may cause m';l"',E', rfo!puctiort in> ~ ~ 

yield and quality. ) 

·00 not treat before anticipated major storm which could prevent harvest and result in crop lo~s. 

'00 not apply Ethephon 6 if rain is expected within 4 hours. ) J , ) ) ) 

APPLICATION TIMING . ' , J, 

Successful results with Ethephon 6 call for treatment when leaves are mature, not overly rank g~eeh)when swayod. 

To easily determine the proper treatment timing and the number of leaves per stalk ready for J'.<'f'f'1~I, test spra,) 

several plants in more than one location in each field and observe the response. Mature leaves will begin tCjj-.ell?w 

, , 6 ' j j" 

, , 

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40
EPA approved FINAL LABEL 

Rev. 12f412009 

in 24 to 72 hours. Test leaves that fail to yellow in 72 hours are not mature and are not ready for Ethephon 6 

treatment. Wait a few days to permit further natural maturing, then make another test spray or "maturity" check. 

When you have confinned the number of leaves per plant that will color, you can determine the number of acres to 

treat in order to fill the barn. 

TEST SPRAY MIXTURE DIRECTIONS 

Prepare your test spray by mixing one teaspoon of Ethephon 6 in 1 quart of water. Spray each test plant with about 

1 oz of this mixture, covering all leaves with a fine mist. Ethephon 6 will not color immature sprayed leaves. 

WHEN TO HARVEST 

All mature, sprayed leaves will begin to color within 24 to 72 hours after Ethephon 6 application. The yellowing 

process is weather dependent; cool weather will delay, while hot, sunny weather can speed up the process. Harvest 

treated tobacco when leaves have reached the desjred color intensity. 

Do not allow tobacco to become over ripe before starting halVest. Leaf drop can occur when tobacco is over ripe 

and left on the stalk. If a number of the bottom leaves have yellowed at the time of treatment, they should be 

halVested prior to spraying with Ethephon 6. 

With an over-the-top application, haIV8stlng can commence 48 hours after Ethephon 6 application depending on 

weather conditions or to avoid over ripe tobacco. Tobacco harvested 48 hours after treatment may require more 

time in the coloring phase of the curing process. 

CURING ETHEPHON 6 TREATED TOBACCO 

Curing procedures are as much an art as a science and each cure must be judged on the basis of tobaGCo condition, 

intelVal between treatment and harvest, weather and type of curing facility before prescription temperature and 

ventilation schedules can be established. To obtain maximum quality, care must be taken to observe and control the 

curing process closely, especially during the late "coloring" and early "drying" stages of the leaf. 

Ethephon 6 treated tobacco will have started the coloring process when halVested, reducing the time required in the 

coloring phase of curing. Treated tobacco should be dried faster. If tobacco leaves are green or contain some green 

when harvested, it may be necessary to color them for a few hours. If the leaves are completely yellow, temperature 

and ventilation must be adjusted in a manner to dry the tobacco as fast as possible without scalding. Once the leaf 

is dried (3/4 dry), you should follow nonnal procedures for curing. Since Ethephon 6 treated leaves cure faster, 

treated and untreated leaves should not be cured together in the same barn. 

REDEAGLE INTERNATIONAL LLC WARRANTS THAT THIS PRODUCT CONFORMS TO THE CHEMICAL 

DESCRIPTION ON THE LABEL THEREOF AND IS REASONABLY FIT FOR THE PURPOSE STATED ON SUCH 

LABEL ONLY WHEN USED IN ACCORDANCE WiTH THE DIRECTIONS FOR USE. 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 WEATHER CONDITIONS, PRESENCE OF OTHER MATERIALS, OR THE MANNER OF USE OR 

APPLICATION, ALL OF WHICH ARE BEYOND THE CONTROL OF REDEAGLE INTERNATIONAL LLC. TO THE 

EXTENT CONSISTENT WiTH THE APPLICABLE LAW IN NO CASE SHALL REDEAGLE INTERNATIONAL LLC 

BE LIABLE FOR THE CONSEQUENTIAL, SPECIAL OR INDIRECT DAMAGES RESULTING FROM THE USE OR 

HANDLING OF THIS PRODUCT TO THE EXTENT CONSISTENT WITH APPLICABLE LAW. ALL SUCH RISKS 

SHALL BE ASSUMED BY THE BUYER. EXCEPT AS EXPRESSLY PROVIDED HEREIN, RED EAGLE 

INTERNATIONAL LLC MAKES NO WARRANTIES, GUARANTEES, OR REPRESENTATIONS OF ANY KIND, 

EITHER EXPRESS OR IMPLIED, OR BY USAGE OF TRADE, STATUTORY OR OTHERWISE, WiTH REGARD 

TO THE PRODUCT SOLD, INCLUDING BUT NOT LIMITED TO, MERCHANTABILITY, FITNESS FOR A 

PARTICULAR PURPOSE, USE OR ELIGIBILITY OF THE PRODUCT FOR ANY PARTICULAR TRADE USAGE. 

" , " ) 

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41
NEW APPLICATIONS 

DATE: AUG - 4 2009 

FILE NUMBER: 9567'6- L 

FEP (OPPIN ENTRY) t.J AUG -42009 

(Initial & date) .. 

FILE ROOM: _____ _ 

(Initial & date) 

SIG: 

(Initial & date) 

FILE ROOM: ___ ---

(Initial & date) 

I ASSIGN TO PM .,;!.;).. (NO DATA) 

__ JACKET TO SHELF (DATA) 

42
1&" EPA Reg. Date of 

Number: Issuance: - , 85678-5 ~ , 

" ff NOV 2 0 2009 'I:>;;,(""O'Ii.~ 

Terms of Issuance: 

U.s. ENVIRONMENTAL PROTECTION AGENCY Conditional 

Office of Pesticide Programs 

Registration Division (750SP) 

1200 pennsylvania Ave., N.W. Name of Pesticide Product: 

Washington, D.C. 20460 Ethephon 6 

NOTICE OF PESTICIDE: 

____ x_ Registration 

---- Reregistration 

(under FIFRA, as amended) 

Name and Address of Registrant (include ZIP Code): 

RedEagle International LLC 

2651 Woodwind Hills Lane 

Lakeland, FL 33812 Attn.: Catherine M. Byrd 

Note: Changes in labeling differing in substance from that accepted in connection with this registration 

must be submitted to and accepted by the Registration Division prior to use of the label in commerce. 

In any correspondence on this product always refer to the above EPA registration number. 

On the basis of information furnished by the reg'lstrant, the above named pesticide is hereby registered 

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 this Act is not to be construed as giving 

the registrant a right to exclusive use of the name or to its use if it has been covered by others. 

You must make the following label revisions: 

1. The EPA Reg. No. must be changed to 85678~5. 

Signature of Approving Official: Date: 

(!. dJ 7&' -1«,Ju.,... {i,,-

Tony Kish f ( I fLS J " 1 

Product Manager Team 22 

Fungicide Branch 

Registration Division (7505P) 

EPA Form 8570-6 

43
2 

EPA Reg. No. 85678-5 

2. In the First Aid section, add a period to the last sentence in the IF SWALLOWED section. 

3. On page 1, delete the number 1 from "46.01 %, and change "6 pounds" to "6.08 pounds to match 

the product density. 

4. On page 1, the sentence directly after the product name must read as follows: "FOR 

COMMERCIAL USE OR AGRICULTURAL USE ONLY NOT INTENDED FOR RESIDENTIAL 

USE." 

5. On page 2, in the Personal Protective Equipment section, add "(PPE)" after the heading. 

6. On page 2, in the Personal Protective Equipment section, number 2 must read "Chemicalresistant gloves made of any waterproof materials and number 4 must read "Protective eyewear 

such as goggles, safety glasses or face shield". 

7. On page 2, immediately following the subheading "PERSONAL PROTECTIVE EQUIPMENT 

insert the following text: "Some material that are chemically resistant to this product are listed 

below. If you want more options, follow the instructions for category A on an EPA chemical 

resistance category selection chart." 

8. On page 2 in the paragraph after the PPE statement, the fourth sentence must read "If no such 

instructions for washables exist, ....... and hot water. 

9. On page 2 in the User Safety Recommendations section, number 2 must read as follows: 

"Remove 910thing/PPE immediately after handling.. . ............. as possible,". 

10. On page 3 in the SWATH ADJUSTMENT section change "displace windward" to "displaced 

downwind." 

11. On page 3, in the Agricultural Use Requirements box, number 2, change "waterproof gloves" to 

"Chemical resistant gloves made of any waterproof material." 

12. On page 3, in the Agricultural Use Requirements box, number 4 must read as follows: 

"Protective Eyewear such as goggles, safety glasses or face shield. n 

13. On page 3, you must add the missing container cleaning directions for use per PR 2007-4 by 

separate amendment or notification as appropriate. 

14. On page 5, the subheading "Storage" must be Changed to "Pesticide Storage". 

15. On page 5, move the sentence "Do not contaminate water, food or feed by storage and 

disposal." up, so that it immediately follows the "STORAGE AND DISPOSAL" section heading 

16. On page 5, in the Use Limitations section, first bullet, the word "this" is misspelled. 

44
3 

EPA Reg. No. 85678~5 

17. On page 5, add the following heading (UTest Spray Mixture DirectionsIT

) to the beginning of the 

sentence "Prepare your test spray by mixing .......... covering all." 

18. On page 6, the third line must read "The control of RedEagle International LLC, "to the extent 

consistent with applicable law," in no case ..... " ......... ", ....... liable for the", 

19. On page 6, the fourth line must read" consequential, special or indirect damages resulting from 

the use or handling of this product "to the extent consistent with applicable law" ", ... 

You must submit the results of the storage stability (GRN 830.6217) and corrosion characteristics 

(GRN 830.6320), by 11/1/2010. The results must be submitted to the Agency in electronic and hard copy 

format. You must also revise your CSF to include the correct name and address of the producer in block 

2 of the CSF by December 9, 2009. 

Submit one (1) copy of final printed labeling incorporating the above changes before you release 

the product for shipment. A copy of your label stamped "Accepted with Comments" is enclosed for your 

records. 

If you have any questions concerning this letter, please contact Rose Kearns of my staff by phone 

at 703~305~5611 or via email at kearns.rosemarv@epa.gov or myself at 703-308-9443 or via email at 

kish.tony@epa.gov. 

Enclosure 

45
ACCEPTlI1J 

_COMMENTs 

Iu EPA r.._ Dated ETHEPHON 6 

rt~ .. ~__ NOV 2 5 2DD9 FOR COMMERCIAL USE OR AGRICULTURAL USE ONLY 

_the Ped.oN.l In.teetwde NOT FOR RESIDENTIAL USE 

Bi 

""""'-. Dt@adN. .... t~ ~Mi. tbe ~vE INGREDIENT: 

~ght0i"erl wrd,».\ R N.._ Ethephon (2-Chloroethyl) phosphonic acid',..... . .. " ............. " .. 54.0% 

0'-r: 1"10'_ rtlg.(flflER INGREDIENTS: -.-.................. _.- ....................... , ...................... , ..................... .46.01'1'0 

-. (Jb \C' 'I 1 :_~ ,__ TOTAL .................................... 100_0% 

This product contains 6 pounds ethephon per gallon. 

KEEP OUT OF REACH OF CHILDREN 

DANGER PELIGRO 

para que se la explique a usted en detalle. (If you do not understand this label, 

IF IN EYES 

IF ON SKIN OR 

CLOTHING: 

IF SWALLOWED; 

Ii 

" 

" 

FIRST AID 

i 

• then continue rinsing eye 

for 15-20 minutes. 

i 

I j treatment 

of water if able to swallow. 

unless told to do so by a poison control center or doctor. 

IF INHALED: If person is not breathing, call 911 or an ambulance, then give artificial respiration, preferably 

mouth to mouth if possible. 

" I 

EMERGENCY TELEPHONE NUMBERS: 

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

You may also contact: 

EMERGENCY NUMBERS: and spills) 

health) 

Refer to side panel for additional precautionary statements. 

EPA Reg. No. 85678-

EPA Est. No. 

NET CONTENTS: _______ _ 

RedEagle International LLC 

2651 Woodwind Hills Lane 

Lakeland, Florida 33812 

1 

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46
PRECAUTIONARY STATEMENTS 

DANGER 

HAZARDS TO HUMANS AND DOMESTIC ANIMALS 

Corrosive Causes irreversible eye damage and skin burns, HarmfUl if swallowed or absorbed through skin. Do not get in eyes, on skin oron 

clothing. Prolonged or frequently repeated skin contact may cause allergic reactions in some indiViduals. 

PERSONAL PROTECTIVE EQUIPMENT 

Applicators and olher handlers must wear: 

1. Coveralls over long-sleeved shirt and long pants. 

2. Chemical-fesistant gloves. 

3, Chemical-resistant footwear plus socks. 

4_ Protective eyewear. 

5. Chemical-resistant headgear for overhead exposure. 

5. Chemical-resistant apron when mixing or 10ad'lIlg orciean'lng equ·lpmen!. 

Discard clothing and other absorbent matalials that have been drenched or heavily contaminated with this product's concentrate. Do nol reuse them, 

Fallow manufacturer's instructions for cleaning and maintaining PPE. If no such instructions for washables. use detergent and hot water. Keep and 

wash PPE separately from other laundry. 

When handlers use closed systems. enclosed cabs, or aircraft In a manner thaI meets the requirements listed in the Worker Proteclion Standard 

(WPS) for agricultural pesticides 40 CFR 170.240.(d)(4·5), the handler PPE requirements may be reduced or modified as specified in the WPS, 

USER SAFETY RECOMMENDATIONS 

Users ShOUld: 

1. Wash hands before eating. drinking, chewing gum, using tobacco or USing the tOilet. 

2. Remove clolhing immediately if pesticide gets inside. Then wash body thoroughly and put on crean clothing. 

3, Remove PPE immed'iately after handling this product Wash the outside of gloves before rerooving. AS soon as possible, 

wash thoroughly and change into clean clothing. 

ENVIRONMENTAL HAZARDS 

Do not apply directly to water, or to areas where surface waler is present or to intertidal areas below the mean high water mark. DO not contaminale 

water when disposing of equipment washwaters. Do not contaminate water used for irTigation or domestic purposes. 

USE PRECAUTIONS 

Do nol apply Ethephon 5 through any type of irrigation system. 

Do not plant another crop wilhin 30 days after treatment 

Mix only the amount of spray you expect to use each day. Do not allow mixed solution to stand overnight. 

AVOid spray drift to nearby crops as this product will cause modifications in plant growth. Plant injury or reduced yieldS will reSUlt. 

AVOIDING SPRAY DRtFT AT THE APPLICATION SITE tS THE RESPONSIBtLlTY Of THE APPLICATOR. 

The interaction of many equipment-and-weather-related factors determine the potential for spray drift. The applicalor is responsible for considering 

all lhese factors when making decisions, 

The followi1g drift manil{lement requirements must befallowed to avoid off-larget movement from aerial applh;ations to agr'lCultural ~eld crops, 

These requirements do not apply to forestry applications, public health uses or to applications using dry formulations. 

!. The distance of the outer most nozzles on the boom must not exceed 3/4 the length of the wingspan or rotor. 

2. Nozzles must always point backward parallel with the air stream and never be pOinted downwards more than 45 degrees, 

Where states have more stringent regulations, they should be observed. 

" , AERtAL DRtfT REDUCTION ADVISORY , , tnformation on droplet size; , , , , j , ,>. 

The most effective way to reduce drift POlentlal '15 to apply large droplets. The best drift management strategy is to apPI~ the -arg,estdroplets t~al 

provide sufficient coverage and control. Apptying larger droplets reduces drift potential, but will not prevent drin ff applica/,lms are Inade improperlY, or 

under unfavorable environmental conditions (See Wind, Temperature and Humidity. and Temperature Inversions). 'J j > , ; > ~ > 

Controlling droplet size: " ~'> > 

Volume· Use high flow rate nozzles to apply the highest practical spray VOlume. Nozzles with higher rated nows produSf",I'W]'lr droplets.flrcs~ureDo not exceed the nozzle manuracturer's recommended pressures. For many nozzle types lower pressure produces larger~ropi~tS. When hlgjler 

flow rates are needed, use higher flow rate nozzles Instead of increaSing pressure, , j , j j 

Number of Nozzles - Use the minimum number of nozzles that provide uniform coverage. , > , , , j 

Nozzle Orientation _ Orienting nOZZles so that the spray is released parallel to the airstream produces larger droplets than other orientationUl.'J-,-d-ls 

lhe recommended praclice. Significant deflection from hOrizontal will reduce droplet size and increase drift potential. , , 

Nozzle Type _ Use a nOllle type that ts designed for the intended application. With mostnollie types, narrower spray angles prodU~ lalll';l~ j , ' 

droplets. Consider using low-drift nozzles. Solid stream nozzles oriented straight back produces the largest droplets and the lowest drift, 

2 

47
BOOMlENGTH 

For some use patterns, reducing the effective boom length to less than 3f4 of the wingspan or rotor length may further reduce drift without reducing 

swath width, 

APPLICATION HEIGHT 

Applk:a~ons should not be made at a height greater than 10 feet abOlle the top of the target plants unless a greater height is required for aiR:raft safety. 

Making applications at the lowest height that is safe reduces exposure of droplets to euaporation and wind. 

SWATH AOJUSTMENT 

When applications are made with a crosswind, the swath will be displaced Windward. Therefore, on the up and down edges of the field, the applicator 

should compensate for the displacement by adjusting the path of the aircraft upwind, SUrath adjUstment distance should increase, with the increasing 

dr;r'\ potential (higher wind, smaller drops, etc.). 

"'NO 

Orift potential is lowest between winds speeds of 2 -to mph. However, many factors, including droplet size and equipment type determine drift 

potential at any given speed. Application should be aVOided below 2 mph due to uariable wind direction and high inversion potential. NOTE: Local 

terrain can influence wind patterns. Every applicator Should be familiar with local wind patterns and how they affect spray drift. 

TEMPERATURE AND HUMIOITY 

When making applications in low relal'11le hum'lolty, set up equ'lpment to produce larger droplets to compensate for euaporation, Droplet euaporation is 

most seuere when conditions are both hot and dry. 

TEMPERATURE tNVERSIONS 

Applications should not occur during a temperature inuerslon because drill potential is high. Temperature inversklns restrict vertical air mixing, which 

causes small suspended droplets to remain in a concentrated Cloud, This cloud can move in unpredictable directions due to light variable winds 

common during inllersions, Temperature inversions are charactertzed by increa~'lng temperatures with attitude and are common on nights with 

lim~ed cloud cover and light to no wind, They begin to form as the sun sets and often conMue into the morning. Their presence can be indicated by 

ground fog: however, iffog is not present, inuersions can also be Identified by the mOllement of smoke from a ground source or an aircraft smoke 

generator. Smoke that layers and moves laterally in a concentrated clovd (under low wind cond~iollS) indicates an inllersion, while smoke that 

moues upward and rapidly dissipates indicates good vertical air mixing. 

SENSITIVE AREAS 

The pesticide Should onty be applied when the potential for drift to adjacent sensitiue areas (e,g, residential areas, bOdies of water, known habitat for 

threatened or endangered species, non-target crops) is minimal (e.g., when wind Is blowing away from the sensitive areas). 

DIRECTIONS FOR USE 

It is a violatkln of Federal law to use this product in a manner Inconsistent with Its labeling. 

00 not apply this product in a way that will contact workers or other persons, either directly or through drift, Only protected handlers may be in the 

area during application. For any requirements specific to your State or Tribe, consult the agency responsible for pesticide regulation. 

AGRICULTURAL USE REQUIREMENTS 

Use this product onty in accordance with its labeling and w~h the Worker Protection Standard, 40 CFR part 170. This standard rontains 

requirements for the protection of agncultural wOrkers on farms, forests, nur5eries, and greenhouses, and handlers of agricultural pesticides. It 

contains requirements for training, decontamination, notification, and emergency assistance. It also contains specifIC instructions and exceptions 

pertaining to the statements on this label about personal protectiUe equipment, notiftcation to workers, and restricted-entry intervals, The 

requirements in this box only apply to uses of this product that are cOllered by the Worker Protection Standard. 

00 not enter or allow worker entry Into treated areas during the rE!!;tricted-6ntry interval (REI) of 48 hours. 

The REI increases to 72 hours in outdoor areas where average rainfall Is tess than 25 inches a year. 

PPE required for earty entry to treated areas that is permitted under the Worker Protection Standard and that invotves contact with anything that has 

been treated such as plants, $oil, or water, is', 

1. Coveralls over short-sleeued shirt and short pants. 

2, Waterproof gloves, 

3. Chemical-resistant footwear plus socks. 

4. Protectille eyewear. 

5. Chemical-resistant headgear for overhead exposure. 

~~~~~~~~~~~~~~~~~==~~--~,~.~~ Nctify we<1<.ers of the appflca~on by waming them orally and by posting warning s'rgns at entrances to treated areas. 

STORAGEANO OISPOSAL 

STORAGE 

) , , " , , , 

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

If container is broken or contents halle spilled, follOW all precautions indicated aboue and clean up immediately. BeforudE.a.ll,ly up, put on fuilllmgth 

trousers, long sleeued shirt, protectiue glOlles, and goggles or face shield. Soak up spill with absorbent media such as sand~eart~or other suitable 

material and dispose of waste at an approued waste disposal faCility. ' , , , 

, > ) , 

PESTtCIOE DISPOSAL ,> , 

Pesticide wastes ale acutely hazardous. Improper disposal of excess pesticide, spray mixture. or rinsate is a uiolation rJ f2c-erallaw. tfthese wastes 

cannot be disposed of by use according to label instructions, contact your State Pesticide or Environmental ConlfOIAgency orthe Hazardou~,IiMste~ ~ 

representative at the nearest EPA Regional Office for guidance. j , , ) 

" CONTAINER OtSPOSAl , ) , ~ 

Triple rinse (or equivalent) the empty containers. Then offer for recycling or re<::ooditioning, or puncture and dispose of in a sanitary landfli. or by 

inoneratlon or if allowed by state and local authorities, by burning. If container i5 bumed, stay out of smoke, 

3 

48
GENERAL INFORMATION 

COTTON 

A foliar spray of Ethephon 6 wi! accelerate opening of mature unopened cotton bolls and enhance defoliation which can result in ea~ier harvest with 

an increased recoverable yield. Ethephon 6 treatment allows increased effICiency from a once·over harvest 

TOBACCO (FLUE-CURED) 

A fo~ar spray of Ethephon 6 promotes eMy, uniform "yellowing" of mature tobacco. Ethephon 6 reduces curing time, allowing more efficient use of 

curing bam space, and Increased control over harvest schedules. 

SPRAYPREPARATlON 

Add 1/2 to 3f4 of the required amount of water to the spray tank. Start agitabon. Add the required amount of Ethephon 6, and the remaining amount 

otwater, Prepare only as much spray solution as can be used on the day of mixing. 00 not allow spray solution to stand overnight. 00 not spill the 

concentrated product on spray equipment, or any airplane parts, 

ANY SPILLS SHOULD BE RINSED IMMEOtATEL Y WITH PLENTY OF WATER. 

useof a nurse tank is highly recommended for avoiding possible spills of concentrated formulation on spray equipment or any airplane parts. 

TANK MIXTURES WITH DEFOLIANTS AND INSECTICIDES 

Follow all applicable use precautions and rate per acre recommendations on labels of products appfled as tank m'lxtures orin sequence with 

Ethephon 6, In some cases slight reduction in boll opening response has been observed when tank mixes with defoliants were used. 

Good agitation in the spray tank is essential and a tank mixture should not be allowed to stand without agitation for more than 5 to 10 minutes, 

Read and Observe all appropriate label use directions and precautions for the defoliants and insecticides used. 

DO NOT MIX WlTI--l DESICCANTS IF COTTON IS TO BE SPINDLE HARVESTED. 

00 NOT TANK MIX ETHEPHON 6 WITH DEFOLIANTS CONTAtNING SODtUM CHLORATE BECAUSE THIS RESULTS IN THE 

FORMATION OF HYPOCHLOROUS ACIDS WHICH UPON HEATING EMIT TOXIC CHLORINE FUMES, 

EQUIPMENT CLEANING 

Because of the acidic nature of this product. prolonged exposure to spray depos~s will damage acrylic plastics, certain paints, and metals, 

Rinse thoroughly with a detergent and water all exposed acrylic plastic.type materials (e.g., aircraft windshields), and painted surfaces within an hour 

after exposure to spray deposits. 

At the end of each day, rinse thoroughly with a detergent and water all the metal parts of the aircraft and the associated spray equipment exposed to 

the spray depoSits, 

COTTON 

ONEGALLON 

EXPECTED ETHEPHON 6 RATE ETHEPHON6 SPRAY VOLUME 

USE CONDtTIONS TREATS APPLICATION TIMING 

PINT/A LBSAI ACRES GROUND AIR" 

Hotand dry 80"F or t 1/3 LO , higher Apply when the number of 

mature unopened bolls is 

ETHEPHONS' Dryand75FtoSOF , " , 15-50 ,., sulfident to produce the desired 

crop. See below fO( test of boll 

Cool but above 65 F maturity. Treatment unifonnly 

oc n3 2 3 opens bolls 7 to t4 days ea~ier. 

Rank cotton 

ETHEPHONS+ High soil moisture Apply4 to 7 days prior to Ethephon 

FOLEX oc 6 boll opening application. To be 

oefoliant Tank High fertility level "3 ." " t5-50 5-tO used as a sequential treatment With, 

Mix oc not in place of EthBphon 6 boll 

Rankcollon opening treatment 

Apply 4 to 7 days prior to 

ETHEPHON6+ H'l\lh So'it moisture Ethephon 6 boll opening, , > 

DROPP or High application, To be used,as , , fertility level ,~ " " 10-50 3-10 a seqJ~tla~1 irtratment ~, , Defofrant Tank or Rank with, rtot inJllade of > M" cotton Ethep~on 6 bo:t opening , treatm;qt, ,J , " > , . . Hot, dry, above 80 F V3 ., " Apply 4 to'7 daps prior to , , J > 

Pre- defoliant. " , Cond~ioner fo( Cool, above 65"F 15·50 ,., Enhanas.op Crop defolia!km' $ 

Detollation oc 11/3 LO , reducing c',eteri-Jration of bottcm 

Rank cotton crop aolU <.:11",\,5 for e~~ierJh§lI},'lst 

. > J , , -' 

'Pretreatment With Defoliants Prior to Ethephon 6 Treatment 

• 

If the cotton ls ove~y rank or laying down in the middles and good spray coverage of the bolls with Ethephon 6 is diffICult, a pretreatment wi'IH 1 1 

delollants will be useful to Improve boll coverage w~h Ethephon 6. Use dosage rates of Ethephon 6 recommended for boll opening. 

Read and observe all appropriate label use directions and precautions forthe defoliant used, 

4 

49
"NOTE: For Califomia and Arizona u~e a uOlume of no less than 5 gallons per acre for aerial applications, 

Bott Maturity 

A boll is mature when it is too hard to be dented when squeezed between thumb and fingers, too hard to be sliced with a sharp knlfe, and when the 

seed coat becomes light brown in color. 

Use lImttatlons 

00 not exceed a maximum of 2,0 Ib, aUA for combined uses of Ethephon 6 (or other ethephon containing products) per acre per year. 

• Boll Opening: 00 not tank mix Ethephon 6 with a desiccant if the cotton is to be spindle harvested, 

• Pre-Condition for OefoliaUon: 00 not tank mix Ethephon 6 with desiccants unless plant deSiccation is required. 00 not use a defOliant before 

there is suffICient mature unopened bolls to produce the deSired yield (see General Information section on how to test for boll maturity). 

When to Harvest 

00 not harvest cotton sooner than 7 days after a treatment with Ethephon 6. Observe the treated crop and harvest when optimum boll opening has 

been reached. Too early harvest might reduce the full aduantage of the treatment and too late a harvest may result in reduced quality and lOSS of lint 

which will drop from the plant. 

TOBACCO 

Ftue.Cured Onl 

CROP SfTUA TlON ETHEPHON6 SPRAYVOLUME SPECIFIC OIRECTtONS PINTSIACRE GALLONS/ACRE 

Usedrop n=les. Choose TG orOC spray lips designed to apply S0-60gpa at35· 40 

Directed Spray psi and attractorspeed Of 2-3 mph. Use 2 nozzles per row; one on each side of the 

t fl3 50-60 rOWdropped lOW enough to direct the spraytothe leaves to be ripened and harvested. Applica~on Thorough spray coverage is essential. W~h a directed spray, be sure to halVest all 

lealleS with 20% or more yellowing, 

Treat only when feaves remain'lIlg on the stalk are mature. To ensure remaining 

leaves are mruure, lest spray several tobacco plants as described under the sectiCfl 

"Application Tming." Use the lower rate in a normally mature crop when experience 

indicates that minimum ripening inducement is required. Use the higher rate when 

the crop is heavy and has a tendency to be more rnnk or when temperatures are 

QlJer-The·Top 1 113-2213 40_60 lower than normal. Always test spray to determine if the tobacco is mature enough to 

Application respond to treatment w'rth Ethephon 6. 

APPly over·the-top Ethephon 6 spray as a fine mist using three nozzles (one nozzle tip 

over the center of the plant, and oneon each side) so ailleaues are COIJered 

thoroughly, similar to the appflCation pattern ofsysternic sucker control agents, Use a 

spray pressure of40 to 60 psi, I 

" U LIMITATIONS 

·00 not apply EthephCfl 6 to immature leaves as theis can result in unsatisfactory coloring, weight loss and reduced leaf quality. 

·00 notalbw the crop to over ripen in the field after using Ethephon 6, since this may cause some redlJCtion in yield and quality. 

-DO not treat before anticipated major storm which could preuent harvest and result in crop loss, 

·00 not apply Ethephon 6 ff rain is expected within 4 hours. 

APPLICATION TIMING 

Successful results with Ethephon 6 call for treatment when leaves are mature, not overly rank green when sprayed, To easily determine the proper 

treatment timing and the number of leaves per stalk ready for harvest, test spray seueral plants in more than Cfle location in each field and observe 

th~ response, Mature leaves will begin to yellOw in 24 to n hours. Test leaues that fail to yellow in n hours are not mature and are not ready for 

Ethephon 6 treatment. Wait a few days to permit further natural maturing, then make another test spray or "maturity" cheCk. 

When youhave confirmed the number of leaues per plant that Will COlor, you can determ'lne the number of acres to treat in order to fill the bam, 

Prepare your test spray by mixing one teaspoon of EthephCfl 6 in 1 quart of water, Spray each test plant with about 1 OZ of this mixlllre, covering all 

leaves with a fine mist. Ethephon 6 will not color immature sprayed leaues. 

WHEN TO HARVEST 

All mature, sprayed !eaves wHI begin to COlor with'ln 24 to 72 hours after Ethephon 6 application, The yellowing process is weather dependent: cool 

weather will delay, while hot, sunny weather can sPeed up the process. Harvest treated lObacco when leaves haue reached the desired color 

intensity, 

00 not allow tobacco to become over ripe before starting harvest. leaf drop can occur when tobacco is over lipe and left on the stalk. If a number of 

the bottom leaves haue yellowed at the time of treatment, they should be harvested prior to spraying with Ethephon 6. 

" , With an OIIer-the·top application, harvesting can commence 48 hours after Ethephon 6 applicaUon depending on weather coroitions or lb,aydilj iluer 

ope tobacco. Tobacco-harvested 48 hours after treatment may require more time in the coloring phase of the curing PJocih'J>' ~ , , 

CURtNG ETHEPHON 6 TREATED TOBACCO > 

Curing procedures are as much an art as a science and each cure must be judged on the baSis of tobacco condition, int.ln/~ 6e'hYeen treatme'nj ~nd 

harvest, weather and type of cUling facility before prescription temperature and ventilation schedules can be established. Toobta:n maximum~l\iality, 

care must be taken to observe and control the curing process closely, especially during the late "coloring" and early "drying" siagesof the leaf, 

" , " , ~, , 

Ethephon 6 treated tobacco will haIlS started the coloring process when harvested, reducing the time required In the cOlorin~~pha~ of curing. TrEated 

tobacco should be dried faster. If tobacco teaues are green or contain some green when harvested, itmay be necessary /U<.b;b,'them for a f~"i '}l1urs. 

If the leaves are completely yellow, temperature and ventilation must be adjusted ill a manner to dry the tobacco as fast as pOSSible withaut scall:!mg, 

Once the leaf is dried (314 dry), you shOUld follow normal procedures for curing, Since Ethephon 6 treated leaues cure faster, treated and iiri\r~~ted 

leaves shOUld not be cured together in the same barn. ' , 

, , 0 , 

REDEAGLE INTERNATIONAL LLC WARRANTS THAT THIS PRODUCT CONFORMS TO THE CHEMICAL DESCRIPTION ON THE LABEL 

THEREOF AND IS REASONABLY FIT FOR THE PURPOSE STATED ON SUCH LABEL ONLY WHEN USED IN ACCORDANCE WlTH THE 

DIRECTIONS FOR USE. IT IS IMPOSSIBLE TO ELIMINATE ALL RISKS tNHERENTLY ASSOCIATED WITH THE USE OFTHIS PRODUCT. 

5 

50
CROP INJURY, INEFFECTIVENESS, OR OTHER UNINTENDED CONSEQUENCES MAY RESULT BECAUSE OF SUCH FACTORS AS 

WEATHER CONDITIONS, PRESENCE OF OTHER MATERIALS, OR THE MANNER OF USE OR APPLICATlON, ALL OF WHICH ARE BEYONO 

THE CONTROL OF REDEAGLE INTERNATIONAL LLC. IN NO CASE SHALL REDEAGLE INTERNATIONAL LLC BE LIABLE FORTHE 

CONSEQUENTIAL, SPECIAL OR INDIRECT OAMAGES RESULTING FROM THE USE OR HANDLING OF THIS PRODUCT. ALL SUCH RISKS 

SHALL BE ASSUMED BY THE BUYER. EXCEPT AS EXPRESSLY PROVIDED HEREIN, REDEAGLE INTERNATIONAL LLC MAKES NO 

WARRANTIES, GUARANTEES, OR REPRESENTATIONS OF ANY KIND, EITHER EXPRESS OR IMPLIED, OR BY USAGE OF TRADE, 

STATlJTORY OR OTHERWISE, WITH REGARD TO THE PRODUCT SOLD, INCLUDING BUT NOT LlMITEOTO, MERCHANTABILITY, FITNESS 

FOR A PARTlCUlAR PURPOSE, USE OR ELIGIBILITY OF THE PRODUCT FOR ANY PARTICUlAR TRADE USAGE. 

" , 

, , , , , ) ) , " , , , , , 

, 

, , , " , " , , , , , , . , , , , , ' > > , 

, 

" , , , ) 0' > 

> j , ) 

, , " , ) ) > 

6 

51
) 

DATE OUT: OS/SEPIZ009 

FEE: PRODUCT CHEMISTRY REVIEW OF: AN End-Use Product [Xl 

DP BARCODE:D368231 MRIDs: 478205-01 to -03 FILE SYMBOL:85678-L 

RODUCT NAME: Ethephon 6 FOODINON-FOOD USES[Xl ACTION CODE:R300 

COMPANY NAME: RedEagle Intewmational, LLC DECISION NO,: 418042 

PPCOF THE TGAI IN THIS PRODUCT: 099801 

FROM: Sami Malak, ChemistQ-;ilhf'~ S;~ <i 12:16lf 

Technical Review BranchiRD (7505P) 

TO: RM 22 Tony KishlRosemary Keams 

Fungicide BranchIRD (7505P) 

INTRODUCTION: 

In a letter dated 03/AUG/2009, Wagner Regulatory Associates, Inc., an agent for the 

applicant requested a "me~too" registration of subject product claiming its similarity to 

Micro Flo Ethephon 6, Reg. No. 66330-250, transferred from Reg. No. 51036-218. In 

support of this application, the applicant includedlreferenced product chemistry data, a 

basic CSF dated 311JUL12009, a proposed label, Formulators Exemption Statement, 

Certificate With Respect to Citation of Data, and Data Matrix. 

FINDINGS: 

1. The subject product was produced by a non~integrated formulation system, 

meaning that the active ingredient in the product is registered. The product 

contains 54% Ethephon, formulated in China. 

2. The subject product is substantially similar in labeling and composition to Micro 

Flo Ethephon 6, Reg. No. 66330-250, transferred from Reg. No. 51036-218. Both 

products contain the same active ingredient at the same nominal concentration, 

upperllower certified limits, and physical/chemical properties. 

3. The subject product, a fungicide, is intended for control of fungal diseases in 

crops and non~crop areas. 

4. The applicant should be advised to submit the results ofproduct's storage stability 

(GRN 830.6317) and corrosion characteristics (GRN 830.6320), when complete. 

5. Except for the data gaps in Finding 4 above, the submittedlreferenced product 

chemistry data is adequate and support a "me-too" registration of subject product. 

6. Adequate analytical method is available for enforcement. The method was 

previously submitted and reviewed in connection with the registered technical 

sources, . A titration method was included with 

52 *Product ingredient source information may be entitled to confidential treatment*
2 

this submission, MRID #478205~Ol, entitled "Quantitation of the Active 

Ingredient in Five Batches of 54% Ethephon Using Functional Group Titration." 

The method is reviewed in this memorandum .. 

7. The label claim nominal concentrations of 54% Ethephoin is consistent vvith the 

same in the basic CSF dated 311JULl2009, both are in compliance with the 

regulations of PR Notice 91-2. Further, the storage and disposal statement and 

the physical or chemical hazards statement are in compliance with the regulations 

of40CFR§156.78. 

8. The proposed basic CSF dated 31/JULl2009, were filled out correctly and 

completely and agree with the label claim nominal concentration as per the 

regulations of PR Notice 91-2. Further, the upper and lower certified limits are 

within the standard limits of 40CFR§158.350(b)(2). All ingredients claimed in the 

CSFs have been approved for use in pesticide formulations intended for food and 

non-food uses. 

9. The applicant should be advised to corrects the name and address of the producer 

in China in lie of the applicant's name in box 2 of the CSF. 

CONCLUSIONS: 

1. From the product chemiStry view point, the subject product is substantially similar 

in labeling and composition to :Micro Flo Ethephon 6, Reg. No. 66330-250, 

transferred from Reg. No. 51036-218 (Finding 2 above). 

2 After resolving Finding 4 above, the TRB vvill have no objections for a "metoo" registration of subject product. The proposed label and basic CSF dated 

31!JULl2009 are acceptable as per Findings 7 & 8 above. 

NOTETORM: 

Please note Finding 9 above. 

REVIEW OF PRODUCT CHEMISTRY DATA: 

1. A statement of data confidentiality dated 31!JULl2009 was included with this 

submission claiming confidentiality of some of the submitted data on the basis of 

its falling within the scope of FIFRA§10(d)(l)(A), (B), or (C). Review of this 

data was moved to Confidential Appendix A. 

2. A GLP statement dated 16/JULl2009 was included vvith this submission to the 

effect that some of the studies were conducted in compliance vvith the GLP 

requirements of 40CFR§ 160. 

53
3 

830-1800 Enforcement Analytical Method: 

Adequate analytical method is available for enforcement. The method was previously 

submitted and reviewed in connection with the registered technical sources, 

A titration method was included with this submission, MRID 

#478205-01, entitled "Quantitation of the Active Ingredient in Five Batches of 54% 

Ethephon Using Functional Group titration." 

In this method triplicate samples of the test substance were diluted with water then 

titrated with O.lN sodium hydroxide to a pH 9.3. Samples were then heated to 90°C for 

45 minutes and allowed to cool to room temperature then titrated again using O.IN 

sodium hydroxide. Determination of the amount of the active ingredient was 

accomplished by comparison against blank samples. A sample calculation was included 

with this submission. 

Group A, Series 830-Product Identity, Composition, and Analysis (40 CFR§158.320 

to 355) 

830-1550 Product Identity and Composition 

This product contains one registered technical grade of an active ingredients plus 

intentionally added inert ingredients approved for use in pesticide formulations intended 

for food and non-food uses (refer to the proposed basic CSF dated 311JULl2009). 

830-1600 Description of Materials Used to Produce the Product: 

Refer to Confidential appendix A. 

830-1650 Description of Fonnulation Process: 

Refer to Confidential appendix A. 

830-1670 Discussion of Formation ofImpurities: 

Refer to Confidential appendix A. 

830-1700 Preliminary Analysis: 

Refer to Confidential appendix A. 

830-1750 Certified Limits: 

Refer to Confidential appendix A. 

54 *Product ingredient source information may be entitled to confidential treatment*
4 

Identity, Composition, Formulation, and Analysis, Subgroup A, Series 830.1550 to 

830.1800 (40 CFR 158.158.300 to 158.355) 

Guideline Reference NO.(GRN 830.)/Title Data Fulfilled MRlDNo. 

.1550 Product identity and composition Y 478205·02 

.1600 Description of materials used to produce the Y 478205-02 

product 

.1620 Description of production process NA 

.1650 Description of formulation process Y 478205-02 

.1670 Discussion of formation of impurities Y 478205-02 

.1700 Preliminary analysis NA 478205-01 

.1750 Certified limits Y 478205-01 

1800 Enforcement analytical method Y 478205-01 

ExpJ3I\3tions: Y"'The requirements were fulfilled; N '" The requirements not fulfilled; N/A ~ Not applicable; G "" Data gap; U '" Requires 

upgrading; I '" Incomplete or in progress; W "" Waived. 

Physical and Chemical Properties of The Product; 40CFR158.190 

Except for product's storage stability (GRN 830.6317) and corrosion characteristics 

(GRN 830.6320), the remaining physicalfchemical properties included with this 

submission, MRID #478205-01 & -03 are acceptable. 

55
5 

Confidential Appendix A 

830 M 1600 Description of Materials Used to Produce the Product (Source: MRID 

#478205-02) 

830-1650 Description of Formulation Process (Source: MRlD #478205-02) 

830-1670 Discussion of Formation of Impurities: 

The applicant reported no impurities ~O.l% by weight were known to be fonned during 

formulation and storage of the product. There was no chemical reaction in the process. 

830-1700 Preliminary Analysis: 

Using the analytical method described in this memorandum the results of triplicated 

analysis offive samples showed ethephon concentration in the range of 52.75% to 

54.67%, averaging 54.31 %. 

830-1750 Certified Limits: 

The applicant reported the same certified limits as those in the submitted basic CSF dated 

311JULl2009. 

cc::s. Malak and DataBaseFile (Reg. No. 85678·L). 

7505P:RD;TRB:PYS-7347:s.m.:08/SEPI2009:703·308·9365:<85678OL>. 

56 *Inert ingredient information may be entitled to confidential treatment*
DATE OUT: OS/SEP/2009 

FEE: PRODUCT CHEMISTRY REVIEW OF: AN End-Use Product [Xl 

DP BARCODE:D368231 MRIDs: 478205-01 to -03 FILE SYMBOL:85678-L 

RODUCT NAl~E: Ethephon 6 FOODINON-FOOD USES[Xl ACTION CODE:R300 

COMPANY NAME: RedEagle Intewrnational, LLC DECISION NO,: 418042 

PPCOF THE TGAI IN THIS PRODUCT: 099801 

FROM: 

TO: 

Sami Malak, Chemist 

Technical Review BranchiRD (7505P) 

RM 22 Tony KishlRosemary Kearns 

Fungicide BranchiRD (7505P) 

INTRODUCTION: 

In a letter dated 03/AUG/2009, Wagner Regulatory Associates, Inc., an agent for the 

applicant requested a "me-too" registration of subject product claiming its similarity to 

Micro Flo Ethephon 6, Reg, No, 66330-250, transferred from Reg, No, 51036-218, In 

support of this application, the applicant included/referenced product chemistry data, a 

basic CSF dated 31/JULl2009, a proposed label, Formulators Exemption Statement, 

Certificate With Respect to Citation of Data, and Data Matrix. 

FINDINGS: 

1. The subject product was produced by a non-integrated fonnulation system, 

meaning that the active ingredient in the product is registered. The product 

contains 54% Ethephon, formulated in China. 

2. The subject product is substantially similar in labeling and composition to Micro 

Flo Ethephon 6, Reg, No, 66330-250, transferred from Reg, No, 51036-218, Both 

products contain the same active ingredient at the same nominal concentration, 

upper/lower certified limits, and physical/chemical properties. 

3. The subject product, a fungicide, is intended for control of fungal diseases in 

crops and nonMcrop areas. 

4. The applicant should be advised to submit the results of product's storage stability 

(GRN 830,6317) and corrosion characteristics (GRN 830.6320), when complete, 

5. Except for the data gaps in Finding 4 above, the submitted/referenced product 

chemistry data is adequate and support a "meMtoo" registration of subject product. 

6. Adequate analytical method is available for enforcement. The method was 

previously submitted and reviewed in connection with the registered technical 

sources, . A titration method was included with 

57 *Product ingredient source information may be entitled to confidential treatment*
2 

this submission, MRID #478205-01, entitled "Quantitation of the Active 

Ingredient in Five Batches of 54% Ethephon Using Fu~ctional Group Titration." 

The method is reviewed in this memorandum .. 

7. The label claim nominal concentrations of 54% Ethephoin is consistent with the 

same in the basic CSF dated 311JULl2009, both are in compliance with the 

regulations of PR Notice 91-2. Further, the storage and disposal statement and 

the physical or chemical hazards statement are in compliance with the regulations 

of40CFR§156.78. 

8. The proposed basic CSF dated 31/JULl2009, were filled out correctly and 

completely and agree with the label claim nominal concentration as per the 

regulations of PR Notice 91-2. Further, the upper and lower certified limits are 

witlrin the standard limits of 40CFR§ 158.350(b )(2). All ingredients claimed in the 

CSFs have been approved for use in pesticide formulations intended for food and 

non-food uses. 

9. The applicant should be advised to corrects the name ana address of the producer 

in China in lie of the applicant's name in box 2 of the CSF. 

CONCLUSIONS: 

1. From the product chemistry view point, the subject product is substantially similar 

in labeling and composition to Micro Flo Ethephon 6, Reg. No. 66330-250, 

transferred from Reg. No. 51036-218 (Finding 2 above) .. 

2 After resolving Finding 4 above, the TRE will have no objections for a "metoo" registration of subject product. The proposed label and basic CSF dated 

31/JUL/2009 are acceptable as per Findings 7 & 8 above. 

NOTE TORM: 

Please note Finding 9 above. 

REVIEW OF PRODUCT CHEMISTRY DATA: 

1. A statement of data confidentiality dated 311mLl2009 was included with this 

submission claiming confidentiality of some of the submitted data on the basis of 

its falling within the scope of FIFRA§IO(d)(l)(A), (B), or (C). Review of this 

data was moved to Confidential Appendix A. 

2. A GLP statement dated 16/JULl2009 was included with this submission to the 

effect that some of the studies were conducted in compliance with the GLP 

requirements of 40CFR§160. 

58
3 

830-1800 Enforcement Analytical Method: 

Adequate analytical method is available for enforcement. The method was previously 

submitted and reviewed in connection with the registered technical sources, 

A titration method was included with this submission, MRID 

#478205-01, entitled "Quantitation of the Active Ingredient in Five Batches of 54% 

Ethephon Using Functional Group titration." 

In this method triplicate samples of the test substance were diluted with water then 

titrated 'With O.lN sodium hydroxide to a pH 93. Samples were then heated to 90°C for 

45 minutes and allowed to cool to room temperature then titrated again using O.lN 

sodium hydroxide. Detemlination of the amount of the active ingredient was 

accomplished by comparison against blank samples. A sample calculation was included 

with this submission. 

Group A, Series 830-Product Identity, Composition, and Analysis (40 CFR§158.320 

to 355) 

830-1550 Product Identity and Composition 

This product contains one registered technical grade of an active ingredients plus 

intentionally added inert ingredients approved for use in pesticide formulations intended 

for food and non-food uses (refer to the proposed basic CSF dated 31!JULf2009). 

830-1600 Description of Materials Used to Produce the Product: 

Refer to Confidential appendix A. 

830-1650 Description of Formulation Process: 

Refer to Confidential appendix A. 

830-1670 Discussion of Formation of Impurities: 

Refer to Confidential appendix A. 

830-1700 Preliminary Analysis: 

Refer to Confidential appendix A. 

830-1750 Certified Limits: 

Refer to Confidential appendix A. 

59 *Product ingredient source information may be entitled to confidential treatment*
4 

Identity, Composition, Formulation. and Analysis, Subgroup A, Series 830.1550 to 

830.1800 (40 CFR 158.158.300 10 158.355) 

Guideline Reference NO.(GRN 830.)/Tille Data Fulfilled MRlDNo. 

.1550 Product identity and composition Y 478205·02 

.1600 Description of materials used to produce the Y 478205-02 

product 

.1620 Description of production process NA 

.1650 Description of formulation process Y 478205-02 

.1670 Discussion of formation of impurities Y 478205-02 

.1700 Preliminary analysis NA 478205-01 

.1750 Certified limits Y 478205-01 

1800 Enforcement analytical method Y 478205-01 

Explanations: Y "'The requirements were fulfilled; N = The requirements not fulfilled; N/A'" No! applicable; G '" Data gap; U '" Requires 

upgrading; I '" Incomplete or in progress; W "" Waived. 

Physical and Chemical Properties of The Product; 40CFR158.190 

Except for product's storage stability (GRN 830.6317) and corrosion characteristics 

(GRN 830.6320), the remaining physicaVchemical properties included with this 

submission, MRlD #478205-01 & -03 are acceptable. 

60
5 

Confidential Appendix A 

830~1600 Description of Materials Used to Produce the Product (Source: MRlD 

#478205-02) 

1. Ethephon 

830-1650 Description of Formulation Process (Source: MRlD #478205-02) 

830-1670 Discussion of Formation ofImpurities: 

The applicant reported no impurities 2':0.1 % by weight were known to be formed during 

formulation and storage of the product. There was no chemical reaction in the process. 

830-1700 Preliminary Analysis: 

Using the analytical method described in this memorandum the results of triplicated 

analysis of five samples showed ethephon concentration in the range of 52.75% to 

54.67%, averaging 54.31 %. 

830-1750 Certified Limits: 

The applicant reported the same certified limits as those in the submitted basic CSF dated 

311JULl2009. 

cc::S. Malak and DataBaseFile (Reg. No, 85678-L). 

750SP:RD:TRB:PYS-7347:s.m.:08/SEPI2009:703-308-9365:<856780L>. 

61 *Inert ingredient information may be entitled to confidential treatment*
EPA File Symbol 85678~L 

PC Code 099801 (ethephon) 

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 

WASHINGTON, D.C. 20460 

OFFICE OF PREVENTION, PESTICIDES 

AND TOXIC SUBSTANCES 

TECHNICAL REVIEW BRANCH 

SIMILARITY CLINIC DETERMINATION 

07/0CT/2009 

MEMORANDUM 

Subject: Name of Pesticide Product Ethephon 6 

EPA Reg. No. IFile Symbol: 85678-L 

DP Barcode: 0368234 

Decision No: 418042 

Action Code: R300 

From: 

PC Code: 099801 ~) 

Eugenia McAndrew, Biologist '0\1\\.' -i ,..P.' , . D U( 

Technical Review Branch t(~ ~L.> ,'loti t oj,.. 

Registration Division (7505P) 

To: 

Applicant: 

Rosemary Kearns, RM Team 22 

Fungicide Branch 

Registration Division (7505P) 

RedEagle International LLC 

c/o Wagner Regulatory Associates 

P.O. Box 640 

Hockessin, DE 19707 

FORMULATION FROM LABEL: 

Active Ingredient(s}: 

Ethephon 

Inert Ingredient(s): 

Total: 

% bywt. 

54.0 

46.01 

100.01% (should be 100%) 

ACTION REQUESTED: The Risk Manager requests: "Registrant has submitted an application 

to register a new product. They are claiming similarity to 66330-250." 

Page 1 of3 

62
EPA File Symbol 85678*L 

PC Code 099801 (ethephon) 

BACKGROUND: RedEagle International LLC has applied for registration ofEthephon 6, 

EPA File Symbol 85678-L, claiming similarity to Micro Flo Ethephon 6, EPA Reg. No. 66330-

250. Ethephon is the active ingredient in both products. The Registrant is using the cite*all 

method of data support to satisfy the acute toxicity data requirements. 

A search of the OPP electronic databases shows that the Precautionary Review 

SectionlRegistration Support Branch assigned an acute toxicity profile to the cited product, 

66330-250 (transferred from 51036-218), in two prior memos (Perry; 21/JUNI1996 and Perry; 

D224656; 16/0CTI1996). 

RECOMMENDATIONS: 

1. TRB has evaluated the fonnulations of the proposed product, 85678-L, and the cited product, 

66330*250, and has determined that the two products are substantia~ly similar. 

2. The acute toxicity profile for the proposed product, Ethephon 6, EPA File Symbol 85678-L, is 

as follows: 

acute oral toxicity III cited EPA Reg. No. 66330-250 

acute dennal toxicity III cited EPA Reg. No. 66330-250 

acute inhalation toxicity IV cited EPA Reg. No. 66330-250 

primary eye irritation I cited EPA Reg. No. 66330-250 

primary skin irritation I cited EPA Reg. No. 66330-250 

dennal sensitization negative cited EPA Reg. No. 66330-250 

3. This memorandum pertains only to the decision concerning whether the subject product is 

similar to the cited product from an acute toxicological view point. For the purposes of this 

action, TRB has made no further detennination of the adequacy of the toxicological data base or 

the precautionary label of the cited product. 

4. The proposed basic CSF dated July 31, 2009 should be approved by the TRB Product 

Chemistry Team. 

LABELING: Based on the toxicity profile above, the following are the precautionary and first 

aid statements for this product as obtained from the Label Review System: 

PRODUCT ID #: 085678-00005 

PRODUCT NAME: Ethephon 6 

PRECAUTIONARY STATEMENTS 

SIGNAL WORD: DANGER 

SPANISH SIGNAL WORD: PELIGRO 

Page 2 of3 

63
EPA File Symbol 85678·L 

PC Code 099801 (ethephon) 

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.) 

Hazards to Humans and Domestic Animals: 

Restricted Use Pesticide due to toxicity categories. For reta~ sale to and use only by Certified Applicators 

or persons under their direct supervision and only for those uses covered by the Certified Applicator's 

certification. 

Corrosive. Causes skin burns. Causes irreversible eye damage. Harmful if absorbed through skin. Harmful 

if swallowed. Do not get in eyes, on skin, or on dothing. Wear coverals worn over long-sleeved shirt and 

long pants, socks, chemical-reSistant footwear, and chemical-resistant gloves. Wear protective eyewear 

(goggles, face shield, or safety ~asses). Wash thoroughly with soap and water after handling and before 

eating, drinking, chewing gum, or using tobacco. Remove and wash contaminated clothing before reuse. 

Follow the manufacturer\'s instructions for deaning/maintaining PPE. If no such instructions for 

washables, use detergent and hot water. Keep and wash PPE separately from other laundry. When 

mixing and loading wear a chemical resistant apron. 

First Aid~ 

If on skin: 

-Take 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 in eyes: 

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

-Remove contact lenses, if present, after the first 5 minutes, then continue rinsing. 

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

If swallowed: 

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

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

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

-Do not give anything to an unconscious person. 

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

Note to RM/Registrant: The proposed label should contain a Note to Physician which addresses the 

category I Primary Skin Irritant toxicity and Primary Eye Irritant toxicity. The following statements are 

suggested types of information that may be included, if applicable: 

- technical information on symptomatology; 

- use of supportive treatments to maintain life functions; 

- medicine that wil counteract the specific physiological effects of the pesticide; 

- company telephone number to specific medical personnel who can provide specialized 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 1-800-xxx-xxxx for emergency medical treatment Information. 

Page 3 of3 

64
/ 

DATA PACKAGE BEAN SHEET 

Date: 18-Aug-2009 

Page1of2 

* * * Registration Information * * * 

Registration: 85678-L - ETHEPHON 6 

Company: 85678 - REDEAGLE INTERNATIONAL LLC 

Risk Manager: RM 22 - Tony Kish - (703) 308-9443 Room# PY1 5-7318 

Risk Manager Reviewer: Rosemary Kearns RKEARN02 

Sent Date: ____ _ Calculated Due Date: 2S-Nov-2009 

Type of Registration: Product Registration - Section 3 

Action Desc: (R300) NEW PRODUCT;ME-TDO pRODUCT FAST TRACK; 

Ingredients: 099801, Ethephon(54%) 

* * * Data Package Information * * * 

Expedite: 0 Yes • No Date Sent: 18-Aug-2009 

DP Ingredient 099801, Ethephon 

DP Title: Application to Register a New Product 

Decision #: 418042 

DP #: (368231) 

PRIA 

Parent DP #: 

Submission #: 855085 

Edited Due Date: ____ _ 

Due Back: ____ _ 

CSF Included: 0 Yes. No Label Included: 0 Yes. No Parent DP #: ____ _ 

Assigned To Date In _~D~at~.~D~u~t_ / 

Organization: ~R~D~I~T~R;;B _______ _ Last Possible Science Due Date: 11·0ct·2009 

Team Name: C \; ~ 

Reviewer Name: SP??1A ~ ,;;~Q '1/2-/01 

Science Due Date: ____ _ 

Sub Data Package Due Date: ____ _ 

Contractor Name: __________ _ 

* * * Studies Sent for Review * * * 

Printed on Page 2 

* * * Additional Data Package for this Decision * * * 

No Additional Data Packages 

* * * Data Package Instructions * * * 

TRB· PRODUCT CHEMISTRY· Registrant has submitted an application to register a new product. They are claiming similarity to 66330·250. 

Attached for your review and comment are the following: Letter from RedEagle Intemafional LLC appointing Wagner Regulatory Associates, 

Inc. as ils agent, application for pesticide registration, confidential statement of formula, certification with respect to citation of data, formulator's 

exemption statement, data matrix, data transmittal document, MRID 478205·01 end use product chemistry for 54% ethephon, 478205·02 

product chemistry· product identity and composition, description of materials used to produce the product, description of the formulation 

process, and discussion of fomation of impurities and478205-03 Ethephon 6 Product Chemistry Data Waivers, the proposed draft label, CSF 

and a copy of the me-too labeling. If further information is required, please let me know. Thanks for your continued support. 

65
pP#: (368231) 

47820501 

47820501 

47820503 

47820503 

47820503 

47820501 

47820502 

47820503 

47820503 

47820501 

47820503 

47820502 

4782050t 

47820503 

47820503 

47820503 

47820502 

47820503 

47820503 

47820503 

47820503 

47820503 

47820502 

47820503 

47820501 

Page 2 

* * * Studies Sent for Review * * * 

4 p. 

Weller, p, (2008) Product Chemistry for 54% Ethephon: 

Final Report Project Number: 310810111004, Unpublished study 

prepared by Midwest Research Institute. t6 p. 

Weller, P. (2008) End-Use Product Chemistry for 54% Ethephon: 

Final Report. Project Number: 310810111004. Unpublished study 

prepared by Midwest Research Instftute. 16 p. 

Byrd, C. (2009) Ethephon 6: Product Chemistry Data Waivers. 

Unpublished study prepared by Redeagle Intemational, LLC. 4 p. 

Byrd, C. (2009) Ethephon 6: Product Chemistry Data Waivers. 

Unpublished study prepared by Redeagle Intemational, LLC. 4 p. 

Byrd, C. (2009) Ethephon 6: Product Chemistry Data Waivers. 

Unpublished study prepared by Redeagle International, LLC. 4 p. 

Weller, P. (2008) End-Use Product Chemistry for 54% Ethephon: 

Final Report. Proiect Number: 310810/11004. Unpublished study 

prepared by Midwest Research Institute. 16 p. 

Byrd, C. (2009) Product Chemistry - Product Identity and 

Composition, Description of Materials Used to Produce the 

Product, Description of the Formulation Process, and Discussion 

of Formation of Impurities. Unpublished study prepared by 

RedEagle International, LLC. 17 p. 

Byrd, C. (2009) Ethephon 6: Product Chemistry Data Waivers. 

Unpublished study prepared by Redeagle International, LLC. 4 p. 

Byrd, c, (2009) Ethephon 6: Product Chemistry Data Waivers. 

Unpublished study prepared by Redeagle International, LLC. 4 p. 

Weller, P. (2008) End-Use Product Chemistry for 54% Ethephon: 

Final Report. Project Number: 310810111004. Unpublished study 

prepared by Midwest Research Institute. 16 p. 

Byrd, C, (2009) Ethephon 6: Product Chemistry Data Waivers. 

Unpublished study prepared by Redeagle International, LLC. 4 p. 

Byrd, C. (2009) Product Chemistry - Product Identity and 

Composition, Description of Materials Used to Produce the 

Product, Description of the Formulation Process, and Discussion 

of Formation of Impurities. UnpUblished studY prepared by 

RedEagle International, LLC, t7 p. 

Weller, P. (2008) End-Use Product Chemistry for 54% Ethephon: 

Final Report, Proiect Number: 310810/1/004. Unpublished study 

prepared by Midwest Research Institute. 16 p. 

Byrd, C. (2009) Ethephon 6: Product Chemistry Data Waivers. 

Unpublished study prepared by Redea91e International, LLC. 4 p. 

Byrd, C. (2009) Ethephon 6: Product Chemistry Data Waivers. 

Unpublished study prepared by Redeagle International, LLC. 4 p. 

Byrd, C. (2009) Ethephon 6: Product Chemistry Data Waivers. 

Unpublished study prepared by Redeagle Intemational, LLC. 4 p. 

Byrd, C. (2009) Product Chemistry - Product Identity and 

Composition, Description of Materials Used to Produce the 

Product, Description of the Formulation Process, and Discussion 

of Formation of Impurities. Unpublished study prepared by 

RedEagle International, LLC. 17 p. 

Byrd, C. (2009) Ethephon 6: Product Chemistry Data Waivers. 

Unpublished study prepared by Redeagle International, LLC. 4 p. 

Byrd, C. (2009) Ethephon 6: Product Chemistry Data Waivers. 

Unpublished study prepared by Redeagle International, LLC. 4 p, 

Byrd, C. (2009) Ethephon 6: Product Chemistry Data Waivers. 

Unpublished study prepared by Redeagle International, LLC. 4 p. 

Byrd, C. (2009) Ethephon 6: Product Chemistry Data Waivers. 

Unpublished study prepared by Redeagle International, LLC, 4 p. 

Byrd, C. (2009) Ethephon 6: Product Chemistry Data Waivers. 

Unpublished study prepared by Redeagle International, LLC. 4 p. 

Byrd, C. (2009) Product Chemistry - Product Identity and 

Composftion, Description of Materials Used to Produce the 

Product, Description of the Formulation Process, and Discussion 

of Formation of Impurities. Unpublished study prepared by 

RedEagle International, LLC. 17 p. 

Byrd, C. (2009) Ethephon 6: Product Chemistry Data Waivers. 

Unpublished study prepared by Redeagle International, LLC. 4 p. 

Weller, P. (2008) End-Use Product Chemistry for 54% Ethephon: 

Final Report. Project Number: 310810/1/004. Unpublished study 

prepared by Midwest Research Institute. 16 p. 

Decision#: (418042) 

I 

830.7100Niscosity 

830.6303/Physical state 

830.78401Water solubility: Column 

elution method, shake 11ask method 

830.6319/Miscibility 

830.7050/UVNisible absorption 

830.6314/0xidizing or reducing 

action 

830.1550/Product Identity and 

composition 

830.7550/Partition coefficient 

(n-octanol/water), shake flask 

method 

830.7220/Boiling point/boiling range 

830.7000/pH of water solutions or 

suspensions 

830.6320/Corrosion characteristics 

830.1670lDiscussion offormation of 

impurities 

830.6302/Color 

830.7520/Particle size, fiber length, 

and diameter distribution 

830,7950Napor pressure 

830.7570/Partition coefficient 

(n-octanol/water), estimation by 

liquid chromatography 

830.1650/Description of formulation 

process 

830.6321IDielectric breakdown 

voltage 

830.78601Water solubility, generator 

column method 

830.75601Partftion coefficient 

(n-octanol/water), generator column 

method 

830.6313/Stabirlty to sunlight, 

normal and elevated temperatures, 

metals, and metal ions 

111-2221 

830.1600IDescription of materials 

used to produce the product 

830.7370lDissociation constant in 

water 

830,6304/0dor 

66
DP#: (368231) 

47820503 

47820503 

Page 2 

* * * Studies Sent for Review * * * 

16 p. 

: Product Chemistry Data Waivers. 

by Redeagle International, LLC. 4 p. 

6: Product Chemistry Data Waivers. 

prepared by Redeagle International, LLC. 4 p. 

Decislon#: (418042) 

830.7200/Melting poinUmelting 

range 

830.6315lFlamrnability 

67
, Dp#: (368231) 

1< 

47820503 

47820503 

Page 2 

* * * Studies Sent for Review * * * 

Number: 3108~'~~~'f1:~~~ '""'''; by Research Institute. 16 p. 

Byrd, C. (2009) Ethephon 6: Product Chemistry Data Waivers. 

Unpublished study prepared by Redeagle International, LLC. 4 p. 

Byrd, C. (2009) Ethephon 6: Product Chemistry Data Waivers. 

Unpublished study prepared by Redeagle International, LLC. 4 p. 

Decision#: (418042) 

830.72001Melting pointlme~ing 

range 

830.63151Flammability 

68
69
\ 

DATA TRANSMITTAL DOCUMENT 

1. Name and Address of Submitter 

RedEagle International LLC 

c/o Wagner Regulalory Associales 

PO Box 640 

Hp,c!\essin, DE 19707 

2.. Ri>gutatory Action In Support Of Which This Package Is Submitted . , 

b!h."phon 6 

EI;'A :,<egislralion Number: 85678-

~, Transmittal Date 

August 3, 2009 

4. List of Submitted Studies 

Vol. 1: Weller, Paul J. (2008) "End Use Product Chemistry for 54% 

Ethephon, Physical and Chemical Properties Testing" Midwest 

Research Institute, Kansas City, Missouri. Project Number 

3108to.1.004. 13 pages. 

Vol. 2: Red Eagle International LLC. (2009) "Ethephon 6 Product Identity 

and Composition, Description of Materials Used to Produce the 

Product, Description of the Formulation Process, and Discussion of 

Formation of Impurities" Non-confidential portion 6 pages, 

Confidential portion 1 t pages. 

Vol. 3: Byrd, Catherine M. (2009) "Ethephon 6 Product Chemistry Data 

Waiver" 4 pages. 

Company Official: 

Catherine M. Byrd ~/1${d/ Name Signature 

Company Name: Wagner Regulatory Associates, Inc. 

Agent for Red Eagle International LLC 

Company Contact: 

Catherine M. Byrd (302) 234-2780 

Name Phone 

70
RED EAGLE INTERNATIONAL LLC. 

A Chemical Manufacture 

August 15, 2008 

To Whom it May Concern 

Dear Sir or Madam: 

Phone: (863) 648-5448 

Fax: (863) 648-1606 

This letter serves as notification that RedEagle International LLC. has appointed Wagner 

Regulatory Associates, Inc. (WRA, Inc.) to serve as the Agent on our company's behalf 

regarding all state and federal regulatory matters relative to products that RedEagle 

International LLC. win register with the U.S. EPA and the states. Please forward all 

correspondence for RedEagle International LLC. and its products to: 

Wagner Regulatory Associates, Inc. 

P.O. Box 640 

Hockessin, DE 19707-0640 

Thank you for your time and assistance. Please feel free to call me if you have any 

questions. 

Respectfully submitted, 

Yingxue Yu 

Chief Executive Officer 

cc: WRA, Inc. 

Address: 2651 Woodwind Hills Lane, Lakewood, FL 33812, U'dt71
ease rea rnstruc Ions on reverse , recor-~,-' 'ngl rm. Form PO" ". MB No. 2070-00 O. Approval expires 05-3 t-98 

) X egistration OPP Identifier Number 

PI d bfo ,. ". fa A o 6 

oEPA United States 

Environmental Protection Agency Amendment 

Washington, DC 20460 Other 

Application for Pesticide - Section I 

1. Company/Product Number 2. EPA Product Manager 3. proposed Class'ification 

RedEagle International LLC/85678- i- Tony Kish 

4, Company/Product (Name) PM# [8] None Restricted 

RedEagle International LLC/Elhephon 6 22 

5. Name and Address of Applicant (Include Zip Code) 6. Expedited Review. In accordance with FIFRA Section 3(c)(3) 

RedEagle International LLC 

(b){I), my product is similar or identical in compOSition and labeling 

to: 

clo Wagner Regulatory Associates, Inc. EPA Reg. No. 66330-250 

P.O. Box 640 

Hockessin, DE 19707 Product Name: Micro Flo Ethephon 6 

D Check if fhis is a new address 

Section - II 

D Amendment - Explain below. D Final printed labels in response to 

Agency letter dated 

D Resubmission in response to Agency letter dated lEI "Me Too" Application. 

D Notification - Explain below. D Olher - Explain below. 

Explanation: Use additional page{s) if necessary. (For Section I and Section 11.) 

Section - III 

1. Material This Product WiIJ Be Packaged In: 

Ch;I'~r~;;:aCkag;"g U~ckaging W~Soluble Packaging 2. T pe of Container 

Ya, Ya, Melal 

X No ex No X No X Plastic 

If "Yes" No. per If "Yes" No. per Glass 

* Certification must Unit Packaging wgt. container Package wgt container Paper 

be submitted I Other (Specify) HOPE lined bags 

3. Location of Net Contents Information 4. Size(s) Relail Container 5. Location of Label Directions 

m Label o Container bulk ~onLabel On Labeling accompanying product 

6. Manner in Which Label is Affixed to Product § Lithograph c:::::J Other _adhesive backed label 

X Paper glued 

Stenciled 

Section - IV 

1. Contact Point Com lete ifems directly below for identiflcatfon of individual to be contacted, if necessa , fo process thIs application.) 

Name ! Title I Telephone No. (Include Area Code) 

Catherine M. Byrd Agent for Red Eagle International LLC (302) 234 2780 

Certification 6. Date Appl'ication 

I certify that Ihe stalements I have made on this form and all attachments the/eto are true, accurate and complete. Received, 

I acknowledge that any knowingly false or misleading statement may be punishable by fine or imprisonment or 

both under applicable law. • (StaMped) 

2. s~:a;~.re 

I/JIL1X&/rlL/ 

3. Title I Agent for RedEagle International LLC 

4. Typed Name v 5. Date 

Catherine M. Byrd July 31,2009 i i .. ThiS IS a reproduction of EPA Form 8570-1 (Rev. 8-94) PrevIous edilions are obsolete. 

72
Form approved. OMS No. 2070-0060. 2070-0057, ~U70-0t07. 2070-0t22, 2070-0t64. 

,sEPA 

United States 

Environmental Protection Agency 

Washington, DC 20460 

Formulator's Exemption Statement 

(40 CFR 152.85) 

Applicant's Name and Address EPA File Symbol/Registration Number 

85678-

RedEagle International LLC Product Name 

clo Wagner Regulatory Associates, Inc. Ethephon 6 

P.O. Box 640 

Hockessin, DE 19707 

Date of Confidential Statement of Formula (EPA Form 8570-4) 

0713112009 

As an authorized representative of the applicant for registration of the product identified above, I certify that: 

(1) This product contains the following active ingredient(s): 

Ethephon 

(2) Ofthese, each active ingredient tisted in paragraph (4) is present solely as the result ofthe use of that active ingredient in the manufacturing, 

formulation or repackaging another product which contains that active ingredient which is registered under FIFRA Section 3. is purchased by 

us from another person and meets the requirements of 40 CFR section 158.50{e){2) or (3). 

(3) Indicate by checking (A) or (B) below which paragraph applies: 

71 (A) An accurate Confidential Statement of Formula (EPA FORM 8570-4) for the above identified product is attached to this statement. 

That formuta statement indicates, by company name, registration number, and product name, the source of the active ingredient(s) listed in 

paragraph (1). 

OR 

-, (B) The Confidential Statement of Formula (CSF)(EPA Form 8570-4) referenced above and on file with the EPA is complete, current, an 

accurate and contains the information required on the current CSF. 

(4) The following active ingredients in this product qualify for the formulators exemption. 

Source 

Active Ingredient Product Name Registration Number 

Ethephon 

" Signature 

"'RlJ~ Name and Title Oate 

-fJJJJ1)Jr I Catherine M. Byrd, Agent 07/3112009 II 

EPA Form 8570 . 27 . (Rev. 06 2004) CpY 0 1 ;:::p;;' 

Copy 2 - Applicant copy 

73 *Product ingredient source information may be entitled to confidential treatment*
- , '~ 

(51 Form Approved OMS No. 2070-0060 

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 

401 M Street, S.W. 

WASHINGTON, D.C. 20460 

Paperwork Reduction Act Notice: The public reporting burden for this collection of infonnation 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 instruction 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 lnfonnation Management Division (2137), 

U.s. Environmental Protection Ap"ency, 40I M Street, S.W., Washinl!ton DC 20460. Do not send the fonn to this address. 

DATA MATRIX 

Date: July 3 I, 2009 EPA Reg No.! File Symbol: ! Page I 00 

85678· 

Applicant's/Registrant's Name and Address: RedEagle International LLC Product: 

c/o Wagner Regulatory Associates Inc. 

P.O. Box 640 Ethephon 6 

Hockessin, DE 19707 - Ingredient: Ethephon I 

Guideline Reference Number Guideline Study Name MRID Number Submitter Status Note 

PRODUCT SPECIFIC 

830.1550, 830.1600, 830.1620, Product Identity, Red Eagle International LLC OW" 

830.1650,830.1670 CompositioniDescription of Materials 

used to Produce the Product/Description 

of Formulation ProcessfDiscussion of 

Formation of Impurities 

830.1700 Preliminary analysis RedEagle International LLC OW" 

830.1750 Certification of Limits RedEa Ic Illiernational LLC OW" I 

830.1800 Enforcement Anal tical Method RcdEa Ie International LLC OW" 

830.1900 Submittal of Samples Red Eagle International LLC OW" 

830.6302 Color RedEa/Z:le International LLC OW" 

830.6303 Physical State RedEa Ie International LLC OW" 

830.6304 Odor Red Eagle International LLC OW" 

830.6313 Stability to Normal & Elevated RedEagle International LLC OW" 

Temperatures 

830.6314 Oxidation/Reduction Red Eagle International LLC OW" 

830.6315 -- Flammability RedEagle International LLC OW" 

830.6316 ' ... ' , ~6xpiod~;:'ili RedEa Ie International LLC OW" 

830.6317 --0 :;:tora6:': :3tability Red Eagle International LLC OW" 

830.6319 ~I-ri~-.:;t;ir;ty RedEa Ie International LLC OW" 

830.6320 Corrosion characteristics RedEaglc International LLC OW" 

830.6321 Dielectric breakdown volta e RedEa Ie International LLC OW" - 830.7000 pH RedEagle International LLC OW" - -- 830.7050 . rlWiVisibie-li ht RedEa Ie International LLC OW" 

830.7100 Viseosjty~ RedEa Ie International LLC OW" 

Signat." ~J1L!j{j~ Name and Title Date 

Catherine M. Byrd, Agent for RedEagle International July 31, 2009 

LLC 

'EPA Fnrm R'i70.1'i rQ.(7) Fle.drnni", r.nn Pr.n .. r " .. r~inn~ "v";l,,hl .. <;!"h",;t nnl" p"",,-.- ""'~~"'" 74
. , ." Form Approved OMB No. 2070~OO60 

(~l UNITED STATES ENVIRONMENTAL PROTECTION AGENCY ,,~,-,'# 

401 M Street, S.W. 

WASHINGTON, D.C. 20460 

Paperwork Reduction Act Notice: The public reporting burden for this collection of infonnation 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 instruction and completing the necessary fOlms. Send comments regarding the 

burden estimate or any other aspect of this collection of information, including suggestions for reducing the burden to: Director, OPPE lnfonnation Management Division (2137), 

U.S. Environmental Protection Agency, 40 I M Street, S.W., Washington DC 20460. Do not send the fonn to this address. 

DATA MATRIX 

Date: July 31, 2009 EPA Reg No.1 File Symbol: \ Page 2 of3 

85678-

Applicant's/Registrant's Name and Address: Red Eagle International LLC Product: 

clo Wagner Regulatory Associates Inc. 

P.O. Box 640 Ethephon 6 

Hockessin, DE' 19707 -

Ingredient: Ethephon I 

Guideline Reference Number Guideline Study Name MRID Number Submitter Status Note 

830.7200 Meltin intlmeltin ran e RedEa Ie International LLC Own 

830.7220 Boiling ointlboiling range Red Eagle International LLC Own 

830.7300 DensitylRelative Density RedEagle International LLC Own 

830.7370 Dissociation constants in water RedEa Ie International LLC Own 

830.7520 Particle size, fiber len th, and diameter RedEa Ie International LLC Own 

830.7550 Partition coefficient (n-octanollwater) RedEagle International LLC Own 

830.7840 Water solubility Red Eagle International LLC Own 

830.7950 Vapor pressure RedEa Ie International LLC Own 

870.llOO, 1200, 1300,2400, Acute Oral, Dermal, Inhalation, Eye Cite An A ricultural Handlers Ex sure Task Force, Macon, MO p'Y 

2500,2600 Irritation, Dermal Irritation, Skin Agricultural Reentry TaskForce, WashinglOn, DC 

Sensilization Albaugh, Inc., Valdosta, GA 

Axss USA, LLC, Brookfield, cr 

BASF S arks LLC, Research Trian Ie Park, NC .. - Celsius Pro erty B.V., Amsterdam, Raleigh, NC 

Chemical Products Technologies, Cartersville, GA 

Chemin ova, Arlington, VA 

Dow Agrosciences, Indianapolis, IN 

Drexel Chemical Com any, Mcm his, TN 

I E.1. DuPont de Nemours & Co., Newark, DE 

FIFRA Endangered Species Task Force,LLC, Washington, DC 

FMC Corporation, Philadelphia, PA 

Generic Endan ered S ecies Task Force GESTF), Washin on, DC 

Helena Cbemical Co., Collierville, TN 

Helm Agro, Inc., Memphis, TN 

Industria Prodolti Chimici, Washin Ion, DC 

Signature 

~?1CU!~ Name and Title Date 

Catherine M. Byrd, Agent for RedEagle International July 31, 2009 

LLC 

FPA Fnrm ~'i7f1_1"i (Q.Q7\ P1p('tr"n;,. <lnrl P"npr \If'r~inn~ :lv~il:lh1p S."hm;t "nh' P<lnpr "pr~.("m . .. . " ~ 

75
" , Form Approved OMB No, 2070-0060 ; lit. ) \Sl'l!'l ' UNITED STATES ENVIRONMENTAL PROTECTION AGENCY ,,~_.;,t 

401 M Street, S.W. 

WASHINGTON, D.C. 20460 

Paperwork Reduction Act Notice: The public reporting burden for this collection of infonnation 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 instruction and completing the necessary forms. Send conunents regarding the 

burden estimate or any other aspect of this collection of information, including suggestions for reducing the burden to: Director, OPPE Infonnation Management Division (2137), 

U.S. Environmental Protection Agency, 401 M Street, S.W., Washington DC 20460. Do not send the fann to this address. 

DATAMAlRIX 

Date: July 31, 2009 EPA Reg No.1 File Symbol: ! Page 3 of3 

85678~ 

Applicant'siRegistrant's Name and Address: RedEagle International LLC Product: 

c/o Wagner Regulatory Associates Inc. 

P.O. Box 640 Ethephon 6 

Hockessin, DE 19707 " 

Ingredient: Ethephon I 

Guideline Refercnce Number Guideline Study Name MRID Numbcr Submitter Status Notc 

Makhteshim-A an of North America, Inc., Raid h, NC 

Mey Corporation, Chapel Hill, NC 

Monsanto Co., Washington, DC 

Nations Ag II, Raleigh, NC 

Nufarrn Americas, Inc., Burr Rid e, IL 

Nufann, Inc., Burr Ridge, IL 

Nufarm Ltd., Research Trian),;le Park, NC 

Outdoor Residential Exposure Task Force, LLC, Washing!on, DC 

RedE.(igle Chemicals Cor ., Hockessin, DE 

RedEa Ie International LLC, Hockessin, DE 

Residential Ex osure Joint Vcnture (RElV , Washington, DC 

Rittcr Chemical, Washington, DC 

Spray Drift Task Force Washington, DC r-- SyJ.lgenta Crop Protection, Greensboro, NC 

The Ortho Com any, Marysville, OH 

Valent USA Corp., Walnut Creek, CA 

L, __ Zhejiang Xinan Chemical Industrial Group, Brookfield, CT ._ .. 

I) Certification of Limi:s is:proyjG,ed in we Confidential Statement of Formula EPA fonn 8574-4 

Signature 

~~L Name and Title Date 

Catherine M. Byrd, Agent for RedEag!e International July 31, 2009 

LLC 

EPA Form R'i70-1 'i (Q_Q7) P.l~tTlmi('. flnn Pfln~r v~r"inm rlVl'libhl" "llhm;t nnl" Prlnpr "f'r~"''' , . . •• TT ~ 

76
Form AI roved OMS Nos. 2070-0060; 2070-0057' 2070-0107; 2070.{J122· 2070-0164 

~'"' UNITED STATES ENVIRONMENTAL PROTECTION AGENCY ~ft 1 '3 1200 Pennsylvania Avenue, N.W. 

WASHINGTON, D.C. 20460 

PapelWOIk Red,.;!ion Act Notice: The po,lbl ic reponing burden for this C<lllecoon of infonnation is e$timated to ave/llge t .25 hours per response for regjslralion 

and 0.25 hours per response for reregistration andspe.::;aj revi;:wactivities. including time for reading the inslructions and C<lmpleting the necewuy WllIlS. S<:nd 

comments regarding burden estimate or any other :!SpeC! of this collection of infOlTIliltion, including lIUggestions for reducing the burden to: Director, Collection 

Str1iItegiesOivision (28221'), US. Environmental Protection Agency, 1200 PennsylvaniaAvenue, NW" Washington, DC 20460. Do not serxl theC<lmpletedfonn 

to this address. 

Certification with Respect to Citation of Data 

ApplicanfSJReQiSlranfs Name. Address, and Telephone I\AJmber EPA ReQistrabon NumberlFile Symbol 

RedEa91e Intemational LLC, P.O. Box 640, Hockessin, DE 19707 85678-

Active InQredientfsl andfor representative test comooundfst Dol, 

Ethephon July31,2009 

General Use Patem(s) Oisl at those claimed forthis product usin!J40 CFR Part f58) Product Name 

Terrestrial food crop use; Terrestrial nonfood crop use Ethephon 6 

NOTE: lfyourproduct is a 100% repackaging of anotherplXChased EPA·registered product labeled for all the same uses on yOlll" label. you 00 not need to 

submit this form. You must submit the Formulalo(s Exefllltion Statement (EPA Form 8570-27). 

0 I am responding to a Data-Call·ln Notice. and have induded with this form a lisl of companies sent offers of compensalion (Ihe Dala Matrix form should 

be used for Ihis purpose). 

SECTION I: METHOD OF DATASUPPORT (Check one method only) 

0 I am using the cile-all method of support, and have iilduded with !his form 0 I am using the selective method of $Upport (or cile-aU option 

a ist 01 companies sent offers of compensation (the Data Matrix form under the se!eclive method). and have induded Wilh this form a 

shoul:l be u:l.!d lOr this purpose). completed fist of data requirements (the Dilla Matrix IOrm must be 

used), 

SECTION II: GENERAl OFFER TO PAY 

[Required if USing thecile-all method or when using the cite-all opbon under the selective method to sa~sfy one or more data requrnments) 

0 I hereby offer and agree 10 pay compensation, to olher pemons, with regard to the approval ofthfs application, to the eX1enl required by FIFRA. 

SECTION III: CERTIFICATION 

I certify that this application for registration, this form 10r reregistration, or this Data-call-In response is supported by aU data submitted or dted in the 

appijeDfion for regislraOon, the form for reregistration, or Ihe Data-CaU-ln response. In addUion. lfthe cile-all oplion or cite-all opion under the seleclive method is 

indicated in Section I, this app~cation is supported by all data n the Agency's files that (1) conrem the properties or effects of this product oran iderrt~1 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 submHted Lflderthe data 

requirements in effect on the date of approval oflhis applicabon if the applieDtion sought the initial registration of a product of io'entieDl Of similar composition and 

uses, 

I certify thai foreadl exdusive use study cited h support of this regislration orreregislration, that I am the original data submitter or thai I have obtained 

the vmtten permi!1Sion of the original data submltterto cHe that study. 

I certify that for each study cHed in support of this registration or reregislration that is not an exdusive use study, eRher: (a) I am the original data 

submitter; (b) I haw obtained the pe1T1isSion of the original data submitter to use the study in support of this applicaOon: (c) all periods ofeligibtlity for 

compefl!;ation have expired10r the study: (d) the study is In the publlcfiterature; or (e) I have notified in writing !he company that submilted the study and have 

offered 0) to pay compensation to the extenl required by sedions 3(c){t)(F) andfor 3(c)(2)(B) ofFIFRA: and M to commence negotiationS to determine the 

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

I eertify that in all instances where an clfer 01 compensation is required. copies of al offers to pay compensation and eWlence of their delivery in 

accoroaoce with sections 3(c)(1)(F) and/or 3(c)(2)(B) of FIFRA are awilable andwill be submitted to the Agency upon request, Sholld I fail 10 produce such 

evidence to the Agency upon request, I understand 111m the Agency may iniliate action 10 deny, aimeel orsu$pend the registralion of my product in amformity With 

FIFRA. 

I CClrtify thlltthlJ statemlJnts I haYe made On this fann and ali attachments to it IIro true, IIccuratt, and complete. I acknoVolodge thllt any 

knowlngly fal.e or mi.leadirv .tatamontmay be punlshabllJ bf flne or Imprisonment or both under applicable law. 

Signillure 

~~r?L D,. Typed or Printed Name and TIlle August 10, 2009 Catherine M. Byrd, Agenl 

EPA Form 857{).34 (t2 -2003) ElectroniC and Paper ve~lons al/allable. SUbmit only Paper version. 

77
FEDERAL EXPRESS 

August 3, 2009 

Document Processing Desk (REGFEE) 

ATTN: Tony Kish 

Registration Division (7504P) 

U.S. Environmental Protection Agency 

Room S-4900, One Potomac Yard 

2777 South Crystal Drive 

Arlington, Virginia 22202-4501 

Dear :tv1r. Kish; 

Wagner Regulatory Associates, Inc. 

P.O. Box 640 

7460 Lancaster Pike, Suite 9 

Hockessin, Delaware 19707 

Re: Application to register a new product containing a currently registered active ingredient-

"Ethephon 6" 

Wagner Regulatory Associates, Inc., as agent for RedEagle International LLC, is requesting registration 

of the above referenced product. This product is substantially similar to the ethephon product registered 

by Arysta Lifescience North America, LLC. (Micro Flo Ethephon 6), under EPA Registration Number 

66330-250. 

In support of this request, the following documents and studies are attached: 

• Letter from RedEagle International LLC, appointing Wagner Regulatory Associates, Inc. as its 

agent 

• Application for Pesticide Registration (8570-1) 

• Confidential Statement of Formula (8570-4), 2 copies 

• Certification with Respect to Citation of Data (8570-34) 

6 Formulator's Exemption Statement (8570-27) 

• Data Matrix (8570-35) 

II Data Transmittal Document 

• Product Identity and Composition data (3 copies) as outlined in the transmittal document 

• Physical and Chemical Properties data (3 copies) as outlined in the transmittal document 

• Draft labeling, 5 copies 

• For "me-too" product labeling, please refer to the EPA approved label for Registration Number 

66330-250. 

• A copy of the receipt confirming payment of the required registration fees. 

If you have any questions about this submission please contact the undersigned. 

Respectfully submitted, 

Catherine M. Byrd 

Agent for RedEagle International LLC 

Enclosures 

78
FEDERAL EXPRESS 

August 3, 2009 

Document Processing Desk (REGFEE) 

A TIN: Tony Kish 

Registration Division (7504P) 

U.S. Environmental Protection Agency 

Room S-4900, One Potomac Yard 

2777 South Crystal Drive 

Arlington, Virginia 22202-4501 

Dear Mr. Kish; 

Wagner Regulatory Associates,lnc. 

P.O. Box 640 

7460 lancaster Pike, Suite 9 

Hockessin, Delaware 19707 

Re: Application to register a new product containing a currently registered active ingredient ~ 

"Ethephon 6" 

Wagner Regulatory Associates, Inc., as agent for RedEagle International LLC, is requesting registration 

of the above referenced product. This product is substantially similar to the ethephon product registered 

by Arysta Lifescience North America, LLC. (Micro Flo Ethephon 6), under EPA Registration Number 

66330-250. 

In support of this request, the following documents and studies are attached: 

• Letter from RedEagle International LLC, appointing Wagner Regulatory Associates, Inc. as its 

agent 

• Application for Pesticide Registration (8570~1) 

• Confidential Statement of Formula (8570~4), 2 copies 

• Certification with Respect to Citation of Data (8570·34) 

• Formulator's Exemption Statement (8570~27) 

• Data Matrix (8570~35) 

• Data Transmittal Document 

• Product Identity and Composition data (3 copies) as outlined in the transmittal document 

• Physical and Chemical Properties data (3 copies) as outlined in the transmittal document 

• Draft labeling, 5 copies 

• For "me..too" product labeling, please refer to the EPA approved label for Registration Number 

66330-250. 

• A copy of the receipt confinning payment of the required registration fees. 

If you have any questions about this submission please contact the undersigned. 

Respectfully submitted, 

Catherine M. Byrd 

Agent for RedEagle International LLC 

Enclosures 

79
DATA TRANSMITTAL DOCUMENT 

1. Name and Address of Submitter 

Red Eagle International LLC 

c/o Wagner Regulatory Associates 

PO Box 640 Ho,q~essin, DE 19707 

2,., Rllgu(atory Action In Support Of Which This Package Is Submitted 

" 

b!h'Ophon 6 

,EPA :,<egistration Number: 85678-

~, Transmittal Date 

August 3, 2009 

4. List of Submitted Studies 

Vol. 1: Weiler, Paul J, (2008) "End Use Product Chemistry for 54% 

Ethephon, Physical and Chemical Properties Testing" Midwest 

Research Institute, Kansas City, Missouri. Project Number 

310810,1,004,13 pages, 

Vol. 2: RedEagJe International LLC, (2009) "Ethephon 6 Product Identity 

and Composition, Description of Materials Used to Produce the 

Product, Description of the Formulation Process, and Discussion of 

Fonnation of Impurities" Non-confidential portion 6 pages, 

Confidential portion 11 pages. 

Vol. 3: Byrd, Catherine M, (2009) "Ethephon 6 Product Chemistry Data 

Waiver" 4 pages. 

Company Official: 

Catherine M, Byrd (/ffj!iJJf;;xyli$(;i ./ 

Name Signature 

Company Name: Wagner Regulatory Associates, Inc. 

Agent for Red Eagle International LLC 

Company Contact: 

Catherine M, Byrd (302) 234-2780 

Name Phone 

80
RED EAGLE INTERNATIONAL LLC. 

A Chemical Manufacture 

August 15.2008 

To Whom it May Concern 

Dear Sir or Madam: 

Phone: (863) 648-5448 

Fax: (863) 648-1606 

This letter serves as notification that RedEagle International LLC. has appointed Wagner 

Regulatory Associates, Inc. (VIRA, Inc.) to serve as the Agent on our company's behalf 

regarding all state and federal regulatory matters relative to products that RedEagle 

International LLC. will register with the U.S. EPA and the states. Please forward all 

correspondence for RedEagle International LLC. and its products to: 

Wagner Regulatory Associates, Inc. 

P.O. Box 640 

Hockessin. DE 19707-0640 

Thank you for your time and assistance. Please feel free to call me if you have any 

questions. 

Respectfully submitted, 

Yingxue Yu 

Chief Executive Officer 

cc: WRA, Inc. 

Address: 2651 Woodwind Hills Lane, Lakewood, FL 33812, U;5P , 

81
21-Day Screen Completed by 

Contractor 

21-Day Expires on :3 -:<5-0 1 

Jacket # S5k 7f-L 

MRID# Lf7'? :205 

Content Screen: Recommended to 

~Fail 

86-5 Review:-rassedlFailed/NA 

Transfer This Jacket to: 

82
) 

To the Document Center (ITRMD) 

*Please transfer jacket /mini-jacket to Product 

Manager Team circled below: 

Minor Use Section PM-S 

Insecticide Branch PM-iO PM-13 

Herbicide Branch PM-23 PM-25 

Fungicide Branch PM-2i 

Insect /Rodent Br. PM-i PM-7 

*Reminder to PM ~ If applicable pick-up date 

from Screening Room. 

Proces ed by RD's Completeness Check Team 

- ~11)rB Date) 

83
) 

DATA PACKAGE BEAN SHEET 

Date: 18~Aug-2009 

Page1of2 

* '* '* Registration Information '* * * 

Registration: 85678-L - ETHEPHON 6 

Company: 85678 - REDEAGLE INTERNATIONAL LLC 

Risk Manager: RM 22 - Tony Kish - (703) 308-9443 Room# pyt S-7318 

Risk ManagerReviewer. Rosemary Kearns RKEARN02 

Senl Dale: ____ _ Calculaled Due Date: 25-Nov-2009 

Type of Regislration: Product Regislration - SectIon 3 

Action Dese: (R300) NEW PRODUCT;ME-TOO PRODUCT FAST TRACK; 

Ingredienls: Oe9ao I, Elhephon(S4%) 

'* * * Data Package Information '* '* '* 

Expedile: 0 Yes. No 

DP Ingredient: 099801, Elhephon 

DP Tille: Application to Register a New Product 

Date Senl: 18-Aug-2009 

Decision #: 418042 

DP #: (368231) 

PRIA 

Parent DP #: 

Submission #: 855085 

Edited Due Dale: ---

Due Back: ____ _ 

CSF Included: 0 Yes. No Label Included: 0 Yes • No Parenl DP #: ____ _ 

Assigned To Date In Date Out 

Organizalion: cR~D~I~TcR~B _______ _ _ ____ Lasl Possible Science Due Dale: 11·0ct·2009 

Team Name: __________ _ Science Due Dale: ____ _ 

Reviewer Name: __________ _ Sub Dala Package Due Dale: ____ _ 

Conlractor Name: __________ _ 

'* * '* Studies Sent for Review * * * 

Prinled on Page 2 

* * * Additional Data Package for this Decision * * * 

No Addilional Data Packages 

* * * Data Package Instructions * * * 

TRS· PRODUCT CHEMISTRY· Registrant has submitted an application to register a new producl. They are cla"lming similanty 10 66330·250. 

Atlached for your review and comment are Ihe following: Letter from RedEagle Internalional LLC appoinlJng Wagner Regulatory Associates, 

Inc. as ils agenl, application for pesllcide registralion, confidenllal stalement of formula, certification with respect 10 citation of dala, forrnulalor'S 

exemplion slalemenl, data matrix, dala Iransmitlal documenl, MRID 478205·01 end use producl chemistry for 54% elhephon, 478205-02 

producl chemistry- producl i.denlity and composition, description of-malerials use,d 10 produce the product, description ofthe forrnulalion 

process, and discussion of fomalion of impurilies and478205·03 Elhephon 6 Product Chemislry Dala Waivers, Ihe proposed draft label, CSF 

and a copy of Ihe me-too labeling. If further inforrnafion is required, please let me know. Thanks for your continued support. 

84
DP#: (36823 t) 

47820501 

47820501 

47820503 

47820503 

47820503 

47820501 

47820502 

47820503 

47820503 

47820501 

47820503 

47820502 

47820501 

47820503 

47820503 

47820503 

47820502 

47820503 

47820503 

47820503 

47820503 

47820503 

47820502 

47820503 

4782050t 

) Page 2 

••• Studies Sent for Review·· * 

prepared i lLC. 4 p. 

Weller, P. (2008) End-Use Product Chemistry for 54% Ethephon: 

Final Report. Project Number: 3108 to/t/004. Unpublished study 

prepared by Midwest Research Institute. 16 p. 

Weller, P. (2008) End-Use Product Chemistry for 54% Ethephon: 

Final Report. Project Number: 310810fUQQ4. Unpublished study 

prepared by MidWest Research Institute. 16 p. 

Byrd, C. (2009) Ethephon 6: Product Chemistry Data Waivers. 

Unpublished study prepared by Redeagle International, LLC. 4 p. 

Byrd, C. (2009) Ethephon 6: Product Chemistry Data Waivers. 

Unpublished study prepared by Redeagle International, LLC. 4 p. 

Byrd, C. (2009) Ethephon 6: Product Chemistry Data Waivers. 

Unpublished study prepared by Redeagle International, LLC. 4 p. 

Weller, P. (2008) End-Use Product Chemistry for 54% Ethephon: 

Final Report. Project Number: 31 08 1O/t/004. Unpublished study 

prepared by Midwest Research Institute. 16 p. 

Byrd, C. (2009) Product Chemistry - Product Identity and 

Composition, DeSCription of Materials Used to Produce the 

Product, Description of the Formulation Process, and Discussion 

of Formation of Impurities. Unpublished study prepared by 

RedEagle International, LLC. 17 p. 

Byrd, C. (2009) Ethephon 6: Product Chemistry Data Waivers. 

Unpubtished study prepared by Redeagte tnternationat, LLC. 4 p. 

Byrd, C. (2009) Ethephon 6: Product Chemistry Data Waivers. 

Unpubtished study prepared by Redeagte tnternationat, LLC. 4 p. 

Wetter, P. (2008) End-Use Product Chemistry for 54% Ethephon: 

Final Report. Project Number: 3!O8 to/1/004. Unpublished study 

prepared by Midwest Research tnstitute. t6 p. 

Byrd, C. (2009) Ethephon 6: Product Chemistry Data Waivers. 

Unpublished study prepared by Redeagte tnternational, LLC. 4 p. 

Byrd, C. (2009) Product Chemistry - Product tdentity and 

Composition, Description of Materials Used to Produce the 

Product, Description of the Formutation Process, and Discussion 

of Formation of tmpurities. Unpublished study prepared by 

RedEagte International, LLC. 17 p. 

Wetter, P. (2008) End-Use Product Chemistry for 54% Ethephon: 

Final Report. Project Number: 310810/1/004. Unpublished study 

prepared by Midwest Research tnstitute. t6 p. 

Byrd, C. (2009) Ethephon 6: Product Chemistry Data Waivers. 

Unpubtished study prepared by Redeagte Internationat, LLC. 4 p. 

Byrd, C. (2009) Ethephon 6: Product Chemistry Data Waivers. 

Unpublished study prepared by Redeagte tnternational, LLC. 4 p. 

Byrd, C. (2009) Ethephon 6: Product Chemistry Data Waivers. 

Unpubtished study prepared by Redeagte Internationat, LLC. 4 p. 

Byrd, C. (2009) Product Chemistry - Product tdentity and 

Composition, Description of Materiats Used to Produce the 

Product, Description of the Formulation Process, and Discussion 

of Formation of tmpurities. Unpublished study prepared by 

RedEagte tntemationat, LLC. 17 p. 

Byrd, C. (2009) Ethephon 6: Product Chemistry Data Waivers. 

Unpublished study prepared by Redeagle International, LLC. 4 p. 

Byrd, C. (2009) Ethephon 6: Product Chemistry Data Waivers. 

Unpubtished study prepared by Redeagle Internationat, LLC. 4 p. 

Byrd, C. (2009) Ethephon 6: Product Chemistry Data Waivers. 

Unpublished study prepared by Redeagte tntemational, LLC. 4 p. 

Byrd, C. (2009) Ethephon 6: Product Chemistry Data Waivers. 

Unpublished study prepared by Redeagle International, LLC. 4 p. 

Byrd, C. (2009) Ethephon 6: Product Chemistry Data Waivers. 

Unpublished study prepared by Redeagle tntemational, LLC. 4 p. 

Byrd, C. (2009) Product Chemistry - Product tdentity and 

Composition, Description of Materiats Used to Produce the 

Product, Description of the Formulation Process, and Discussion 

of Formation of Impurities. Unpublished study prepared by 

RedEagte International, LlC. 17 p. 

Byrd, C. (2009) Ethephon 6: Product Chemistry Data Waivers. 

Unpubtished study prepared by Redeagle International, LLC. 4 p. 

Wetter, P. (2008) End-Use Product Chemistry for 54% Ethephon: 

Final Report. Project Number: 31081 01t/004. Unpublished stUdy 

prepared by Midwest Research Institute. 16 p. 

Decision#: (418042) 

830.7100Niscosity 

830.6303/Physical state 

830.7840IWater sotubitity: Column 

elution method, shake flask method 

830.6319/Misclbility 

830.7050/UVNisible absorption 

830.6314/Dxidizing or reducing 

action 

830. t550/Product tdentity and 

composition 

830.7550/Partition coeffiCient 

(n-octanol/water), shake flask 

method 

830.7220/Boiling pointlboiting range 

830.7000/pH of water sotutions or 

suspensions 

830.6320/Corrosion characteristics 

830.1670!Discussion of formarlon of 

impurities 

830.6302lColor 

830.75201Particte size, fiber tength, 

and diameter distribution 

830. 7950Napor pressure 

830.75701Partition coefficient 

(n-octanollwater), estimation by 

liquid chromatography 

830.1650lDescription of formulation 

precess 

830.6321/Dielectric breakdown 

vottage 

830.78601Water solubility, generator 

cotumn method 

830.7560/Partition coefficient 

(n-octanot/water), generator cotumn 

method 

830.6313/Stabitity to sun fight, 

normal and elevated temperatures, 

metats, and metat ions 

111-222/ 

830.1600/Description of materiats 

used to produce the product 

830.7370/Dissociation constant in 

water 

830.6304/Odor 

85
) 

DATA PACKAGE BEAN SHEET 

Date: 18-Aug-2009 

Page 1 of 1 

* * * Registration Information * * * 

Registration: 85678-L - ETHEPHON 6 

Company: 85678 - REDEAGLE INTERNATIONAL LLC 

Risk Manager: RM 22 - Tony Kish - (703) 308-9443 Room# PY1 8-7318 

Risk Manager Reviewer: Rosemary Kearns RKEARN02 

Sent Date: ____ _ Calculated Due Dale: 2S-Nov-2009 

Type of Registration: Product Registration - Section 3 

Action Desc: (R300) NEW PRODUCT;ME-TOO PRODUCT FAST TRACK; 

Ingredients: 099801, E1hephon(S4%) 

* * * Data Package Information * * * 

Expedite: 0 Yes • No 

DP Ingredient: 099801, Elhephon 

DP Title: Application to Register a new product 

Date Sent: 18..Aug-2009 

Decision #: 418042 

DP #: (368234) 

PRIA 

Parent DP #: 

Submission #: 855085 

Edited Due Date: ____ _ 

Due Back: ____ _ 

CSF Included: 0 Yes. No Label Included: 0 Yes. No Parent DP #: ____ _ 

Assigned To Date In Da1e Out 

Organization: cR~D~/~TR=B,-______ _ _ ____ Last Possible Science Due Dale: 11·00t-2009 

Team Name: __________ _ Science Due Date: 

Reviewer Name: __________ _ Sub Data Package Due Date: ____ _ 

Contractor Name: __________ _ 

* * * Studies Sent for Review * * * 

No Studies 

* * * Additional Data Package for this Decision * * * 

Can be printed on its own page 

* * * Data Package Instructions * * * 

TRS-Acute Tox - Registrant has submitted an application to register a new product. The are claiming similarity to 66330-250, Attached for 

review and comment are the following: Leifer from RedEagle International LLC appointing Wagoner Regulatory Associates, Inc. as its agent, 

application for pesticide registration, condidential statement of formula, certification with respect to citation of data, formulator's exemption fo rm, 

data matrix, data transmittal document and proposed label and copy of me too label and CSf. Registrant went cite all for the acute data. If 

1urther information is required, please let me know. Thanks for your continued support. 

86
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 

WASHINGTON, D.C. 20460 

August 7, 2009 

REDEAGLE INTERNATIONAL LLC 

7460 LANCASTER PIKE, SUITE 9, PO Box 640 

HOCKESSIN, DE 19707-0640 

Report of Analysis for Compliance with PR Notice 86-5 

OFFICE OF 

PREVENTION, PESTICIDES AND 

TOXIC SUBSTANCES 

Thank you for your submittal of04-AUG-09. Our staff has completed a preliminary 

analysis of the material. The results are provided as follows: 

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

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

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

all future references to these documents. Thank you for your cooperation. If you have any 

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

Manager, to whom the data have been released. 

87
88
, 

! 

FEDERAL EXPRESS 

August 3, 2009 

Document Processing Desk (REGFEE) 

A TIN: Tony Kish 

Registration Division (7504P) 

U.S. Environmental Protection Agency 

Room SA900, One Potomac Yard 

2777 South Crystal Drive 

Arlington, Virginia 22202-4501 

Dear Mr. Kish; 

478205-00 

Wagner Regulatory Associates, Inc. 

P.O. Box 640 

7460 Lancaster Pike, Suite 9 

Hockessin, Delaware 19707 

Re: Application to register a new product containing a currently registered active ingredient ~ 

"Ethephon 6" 

Wagner Regulatory Associates, Inc., as agent for RedEagle International LLC, is requesting registration 

of the above referenced product. This product is substantially similar to the ethephon product registered 

by Arysta Lifescience North America, LLC. (Micro Flo Ethephon 6), under EPA Registration Number 

66330-250. 

In support of this request, the following documents and studies are attached: 

• Letter from RedEagle International LLC, appointing Wagner Regulatory Associates, Inc. as its 

agent 

• Application for Pesticide Registration (8570-1) 

• Confidential Statement ofForrnula (8570-4),2 copies 

• Certification with Respect to Citation of Data (8570-34) 

• Formulator's Exemption Statement (8570-27) 

• Data Matrix (8570-35) 

• Data Transmittal Document 

• Product Identity and Composition data (3 copies) as outlined in the transmittal document 

• Physical and Chemical Properties data (3 copies) as outlined in the transmittal document 

• Draft labeling, 5 copies 

• For "me-too" product labeling, please refer to the EPA approved label for Registration Number 

66330-250. 

• A copy of the receipt confirming payment of the required registration fees. 

If you have any questions about this submission please contact the undersigned. 

Respectfully submitted, 

Catherine M. Byrd 

Agent for RedEagle International LLC 

Enclosures 

89
DATA TRANSMITTAL DOCUMENT 

1. Name and Address of Submitter 

RedEagle International LLC 

clo Wagner Regulatory Associates 

PO Box 640 

Hockessin. DE 19707 

2. Regulatory Action In Support Of Which This Package Is Submitted 

Ethephon 6 

EPA Registration Number: 85678-

3. Transmittal Date 

August 3. 2009 

4. List of Submitted Studies 

Vol. 1: 

47820501 

Vol. 2: 

47820502 

47820503 Vol. 3; 

Company Official: 

Weiler, Paul J. (2008) "End Use Product Chemistry for 54% 

Ethephon, Physical and Chemical Properties Testing" Midwest 

Research Institute, Kansas City, Missouri. Project Number 

310810.1.004. 13 pages. 

RedEagle International LLC. (2009) "Ethephon 6 Product Identity 

and Composition, Description of Materials Used to Produce the 

Product. Description of the Formulation Process, and Discussion of 

Formation of Impurities" Non-confidential portion 6 pages, 

Confidential portion 11 pages. 

Byrd, Catherine M. (2009) "Ethephon 6 Product Chemistry Data 

Waiver" 4 page$. 

Catherine M. Byrd ~/IDjd/ 

Company Name: 

Name 

Wagner Regulatory Associates, Inc. 

Agent for Red Eagle International LLC 

Signature 

Company Contact: 

Catherine M. Byrd (302) 234-2780 

Name Phone 

90
, 

iJn,[IC S:i!rt l '~""II ~'Olr:I''''~ "'"I":' Ollr~1 o! F'rIIICiC, 'JOQ'li'rq 

11';1 <),rr,l 110'- .G.'10Ur:.1 If">' S • .'Y'~' r :''''1.'')(1 

lnlorm.lror, S.r~r~rt e,,,.,(~· 

BEPA 

AD~1:I:N1S1RATlVE No(s\: 

• 

gS612-L 

Pl\I: ~:;)9-____ --;--____ ~_ 

C:rIEf"l1CiJ~ No.: _____ --'--_--:--__ 

The jacket for this action can be 

requCoSted through the JACKETS S)'stem, 

91
'·11 Data Requirements 

8 ~ 0: ~f)dif){}; 418042; "'''S.L;''30'O;'',"" PRe,o, 

Iiii .,. .. _ liiillllll 

AUG 1 3 2OG9 

92
\ 

Completion of 21-Day Content Screen 

PM- C);;{ 

EPA Reg. #(File SymbOI)55S(QT~-L 

Decision # 0 41 ??t!JD 

Thank you, 

Data package delivered to 

you on Z/II/D1 .. r (date) 

Jacket/Mini-jacket will be 

transferred to you today. 

(Pick up from Document Center) 

Registration Division's 21-Day Content Team 

93
.fj;t253o- 0 

Memorandum 

Date: 0- / /0 / 0 '1 

To: __ --I-P-LI-"-'VJ~-"'l=_+ ____ , Regulatory Manager 

From: Information Services Branch, ITRMD 

Your receipt of this data submission is not an 

indication that MRIDs 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. 

If you have any questions about this process, 

please contact Teresa Downs (305-5363). 

This is a: ~ fully accepted submission 

o partially accepted submission 

o rejected submission 

94
PRIA 2 - 21 Day Content Screen Review Worksheet 

(EP AlOPP Use Only) 

3/23/09 

21 Day Screen Start Date: _-<'6<---_'-f-';o-_O----''1 _______ -,--. 

Experts In-Processing Signature: _~~"'-'-'L~=-':"---____ Date? -(p- 0/ Fee Paid: Yes /' 

D· IVlSlon . . managemen t t t d con ac e on Issues N 0 Yes Dat e 

EPA Reg. Number: 3' 5& 7~ - L EPA Receipt Date: "i - <f - 09 

Items for Review Yes No 

1 Application Form (EPA Form 8570-1)(link to foml) signed & complete X including package type 

2 

Confidential 

dated (EPA Form 

Statement of 

I (Link 

Formula 

to form) 

all boxes completed, fonn signed, and ~ a) All inerts (link to "up.'" ". yes no 

including fragrances, approved for the proposed uses (see 

Footnot;A) X -, 

3 Certification with Respect to Citation of Data (EPA Form 8570~34) (Link to 

form) completed and signed (N/A iflOO% repack) >Z.. 

Certificate and data matrix consistent x: . 

If applicant is relying on data that are compensable, is the offer yes no 

to pay statement included. (see Footnote B) I. . . 

1...1- is there a letter ,f A for exclusive use only. 

Formulator's Exemption Statement (EPA Fonn 8570-27) (Link to fonn) X 4 completed and signed (N! A if source is unregistered or applicant owns the 

Data Matrix (EPA Form 8570-35) (Link to fonn) both internal and external 

copies (PR 98-5) (Link to PR 98-5) completed and signed (N/A if 100% X 

5 yes no 

a) Selective Method (Fee ; use) X 

b) Cite-AIl (Fee category experts use) 

c) Applicant owns all data (Fee category experts use) 

5 Copies of Label (link to httg://www.eQa.gov!oQQfeadlllabelinmrmf) 

6 (Electronic labels on CD are encouraged and guidance is available)( link to 

http://www.epa.gov/pesticides/regulating/registering/submissions/index.htm#Jabels ~ ) 

I 

N/A* 

;;c 

••••••• 

95
7 Is the data package consistent with PR Notice 86-5 (link to PRN 86-5) X 

Notice of Filing (link to 

8 httD://www.ena.gov/nesticides/regulatinf!!tolerance getitions.htm) included 

with petitions (link to 

htto:iiwww.eoa.govioesticidesiregulatim!ltolerances.html ~ 

9 If applicable for conventional applications, reduced risk rationale (link to 

http://www.epa.gov/opprdOOl!workplanJreducedrisk.html) ><--

Required Data Oink to 

httg://www.ena.gov/gesticides/regulatingLdata reguirements.htm) and/or 

data waivers. See Footnote C. 

a) List study (or studies) not included with application 

10 

2 

96
Comments: 

* N/A - Not Applicable 

Footnotes 

A. During the 21 day initial content review, all CSFs will be reviewed to determine 

whether all inerts listed, including fragrances, are approved for the proposed uses. If an 

unapproved inert is identified, the applicant must either 1) resolve the inert issue by, for 

example, removing the inert, substituting it with an approved inert, submitting 

documentation that EPA approved the inert for the proposed pesticidal uses, correcting 

mistakes on the CSF, etc. or 2) provide the data to support opp approval of the inert or 3) 

withdraw the application. Removing or substituting an inert ingredient will require a new 

CSF and may require submission of data. All information, forms. data and 

documentation resolving the inert issue must have been received by the Agency or the 

application withdravm within the 21 day period. otherwise, the Agency will reject the 

application as described below. 

To successfully complete this aspect of the 21 day initial content screen, applicants are 

strongly encouraged to verify that all inert ingredients have been approved for the 

application's uses even if a product is currently registered by consulting the inert Web 

3 

97
site [link to http://www.epa.gov/opprdOOllinerts/lists.html] and if the inert is not 

approved, to obtain the necessary inert approval prior to submitting an application 

to register a pesticide product containing that inert ingredient. Some inert 

ingredients are no longer approved for food uses or certain types of uses. The name 

and/or CAS number on a CSF must match the name and CAS number on this web site. 

Simple typographical errors in the name or CAS number have resulted in processing 

delays. 

If an inert is not listed on the inert ingredient web site and the applicant believes that the 

inert has been approved, the applicant should contact the Inert Ingredient Assessment 

Branch (IIAB) at inertsbranch@epa.gov and resolve the issue. Copies of the 

correspondence with IIAB resolving the issue should accompany the application. All 

new inerts except PIP inerts are reviewed by IIAB. The DAB should also be contacted 

for any questions on what supporting data needs to be submitted for and the Agency's 

inert review process. Questions on PIP inerts should be directed to the Chief of 

Microbial Pesticides Branch [Link to 

http://www.epa.gov/oppbppdllbiopesticides/contacts bppd.htmJ. 

When a brand, trade, or proprietary name of an inert ingredient is listed on a CSF, 

additional information such as an alternate name of the inert, CAS number or other 

information [link to http://www.epa.gov/opurdOOl/inerts/tips.pdf] must also be included 

to enable the Agency to determine if it has been approved. Each component of an inert 

mixture (including a fragrance) must be identified. In some cases, the supplier of the 

mixture or fragrance may need to provide this information to the Agency. Prior to the 

Agency's receipt of an application, applicants must arrange with a proprietary mixture or 

fragrance supplier to provide the component information to the Agency or promptly upon 

EPA's request. If the inert ingredients in a proprietary blend (including fragrances) 

cannot or are not identified or provided within the 2l-day content review period, the 

Agency will reject the application. 

During the 21 day content review, applicants should submit information to the individual 

identified by the Agency when the applicant is informed of an unapproved inert. 

Unapproved Inerts Identified on CSFs 

All applications except conventional new products and PIPs 

Once an unapproved inert is identified on a CSF, the Agency will contact the 

applicant with the following options: 

1. Correct the application by, for instance, correcting the inert's identity or CAS 

number, providing documentation that the inert has been approved, or 

removing the unapproved inert from the CSF or replacing it with one that is 

approved for the application's uses; or 

2. Submit the information and data needed for the Agency to approve the 

unapproved inert. If this option is selected and implemented, the Agency may 

request an extension in the PRIA decision review timeframe to accommodate 

the inert review/approval process; 

4 

98
3. Withdraw the application (the Agency retains 25% of the full fee for the fee 

category estimated); or 

If none of these options is selected and implemented by the applicant within the 

21 day content review period, the Agency will reject the application and retain 

25% of the full fee of the category identified. 

Conventional New Product Applications 

When the Registration Division identifies an unapproved inert on a CSF with an 

application for a new product that the applicant has not identified as requiring an 

inert approval (R311, R3l2 or R3l3), it wiIl contact the applicant with the 

following-options: 

I. Correct the application by, for instance, correcting the inert's identity or CAS 

number, providing documentation that the inert has been approved, or 

removing the unapproved inert from the CSF or replacing it with one that is 

approved for the application's uses; or 

2. Submit the infonnation and data needed for the Agency to approve the 

unapproved inert, including any required petition to establish or amend a 

tolerance or exemption from a tolerance. (This option may change the PRIA 

category for the application, which could require a longer decision review 

time and a larger fee. If additional fees are due, they must be received by the 

Agency within the 21 day content review period.) 

3. Withdraw the application (the Agency retains 25% of the full fee for the fee 

category estimated); or 

If none of the above options is selected and implemented during the 21-day 

content-review period, the Agency will reject the application and retain 25% of 

the appropriate fee for the new product-inert approval category. 

PIP Applications 

When the Biopesticide and Pollution Prevention Division identifies an 

unapproved inert on a PIP CSF and a request to approve the inert does not 

accompany the application, it will contact the applicant with the following 

options: 

1. Correct the application by, for instance, correcting the spelling or name of the 

inert to that in 40 CFR 174, or providing documentation that the inert has been 

approved; or 

2. Submit the infonnation and data needed for the Agency to approve the 

unapproved inert. If an inert ingredient tolerance exemption petition is 

required, the petition must be received by the Agency and the B903 fee paid 

within the 21 day period. If this option is selected and implemented, the 

Agency will discuss harmonizing the timeframe for both actions. 

5 

99
3. Withdraw the application (the Agency retains 25% of the full fee for the fee 

category estimated); or 

If none of the above options is selected and implemented during the 21 day 

content review period, the Agency will reject the application and retain 25% of 

the fee. 

B. A policy on documentation of offers to pay is still being developed, however, for a 

me-too or fast track (similar/identical) new product, R300 or A530, an application 

without the necessary authorizations of offers to pay will be placed into either R30 I or 

A531. The Agency recommends that authorizations of offers to pay be submitted with 

other PRIA applications to avoid delays in the Agency's decision. 

C. Biopesticide applicants are advised to contact the Agency and discuss study waivers 

prior to submitting their application to the Agency. Documentation of such discussions 

should be submitted with the study waiver. 

6 

100
Script for Rejection Phone calls 

Contact Name: CA..J.P.,-Et-;<"\~ -gird. 

Phone #: 002 -",3 { -0) 7[;0 

Email: ca.f.f.-f. ...... ~Qt<)CiS1-e<"".r.€.j e-lrI-.. 

First Calliinitials: Second Calliinitials: 

Date: ..?:55?~ 

Time: gilD 

Date: 

Time: 

, EPA contractor. 

I'm calling regarding your submission in support of 

A-;->]OI."*,,,, c'r "'ZJ's-h-<b,," of FierI-."" ~ 

We have found the following deficiencies regarding: 

PR Notice 86.5: Yes or No 

Volume/Study Title: 

Volume/Study Title: 

Volume/Study Title: 

Additional volumes continued on back of page: Yes or No 

Application Package: ~or No 

("rl< ~c~j--;", ; """"s,~k----+ "J '])d<- ~"'tro" 

These deficiencies have been approved by EPA. 

The corrections can be faxed to 703-30S-S060/Attn: _______ _ 

Second Call1Email: 

If we do not receive the corrections by , we will process 

your submission, accordingly. Please direct all future calls and 

correspondence to the appropriate EPA Risk Manager. 

101
RE: Application for Registration of Ethephon 6 

Catherine Byrd to: Jennifer Drobish 

Hi Jennifer, 

I have attached the revised form for Ethephon 6. 

Thanks, 

Catherine 

Catherine M. Byrd 

Regulatory Associate 

Wagner Regulatory Associates 

P.O. Box 640 

7460 Lancaster Pike, Suite 9 

Hockessin, Delaware 19707 

P: 302.234.2780 

F: 302.234.7570 

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

From: DrObish.Jennifer@epamail.epa.gov 

[mailto;Drobish.Jennifer@epamail.epa.gov] 

Sent: Monday, August 10, 2009 2:56 PM 

To: Catherine Byrd 

Subject: RE: Application for Registration of Ethephon 78% MUP 

Hi Ms Byrd 

08/10/2009 03: 17 PM 

I have another application package, this one is for Ethephon 6, with the 

same discrepancy. If you could please do the same thing for this 

application, I would appreciate it. 

Thank you 

Jennifer Drobish 

EPA Contractor 

703-305-1671 

From: "Catherine Byrd" <Catherine@wagnerreg.com> 

To: Jennifer Drobish/DC/USEPA/US@EPA 

Date: 08/10/2009 01:05 PM 

Subject: RE: Application for Registration of Ethephon 78% MUP 

102
Jennifer. 

please find the attached corrected Form 8570-34. I apologize for the 

discrepancy. 

If you need anything else, please do not hesitate to contact me. 

Thank you, 

catherine M. Byrd 

Regulatory Associate 

Wagner Regulatory Associates 

P.O. Box 640 

7460 Lancaster Pike, Suite 9 

Hockessin, Delaware 19707 

P: 302.234.2780 

F: 302.234.7570 

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

From: Drobish.Jennifer@epamail.epa.gov 

[mailto:Drobish.Jennifer@epamail.epa.gov] 

Sent: Monday, August 10, 2009 12:54 PM 

To: catherine@wagnerreg.com 

Subject: Application for Registration of Ethephon 78% MUP 

Ms Byrd 

This is Jennifer Drobish, EPA contractor. I am writing in regards to 

your submission in support of the application for registration of 

Ethephon 78% MUP. We have found a deficiency regarding the application 

package. The Certification with Respect to Citation of Data (EPA form 

8570-34) is inconsistent with the Data Matrix (EPA form 8570-35). The 

data matrix indicates that data is owned, therefore the "Selective 

Method" should be selected on the Certification. There is a cite-all 

option under the selective method. The corrected form can either be 

faxed to me at 703-305-5060/Attn: Jennifer Drobish or emailed to me at 

drobish.jennifer@epa.gov 

Thank you 

Jennifer Drobish 

EPA Contractor 

703-305-1671 

[attachment "EPA Form 8570-34 revised 8-10-09.pdf" deleted by Jennifer 

Drobish/DC/USEPA/US] 

F olm 8570·34 

~ levised 8·' 0·09.pdf 

103
, 

UNI1 cD STATES ENVIRONMENTAL PROTECTION AGENCY 

WASHINGTON, D.C. 20460 

August 5, 2009 

OPP Decision Number: D-418042 

EPA File Symbol or Registration Number: 85678~L 

Product Name: ETHEPHON 6 

EPA Receipt Date: 04-Aug-2009 

EPA Company Number: 85678 

Company Name: REDEAGLE INTERNATIONAL LLC 

CHERYL WAGNER 

WAGNER REGULATORY ASSOCIATES, INC. 

REDEAGLE INTERNATIONAL LLC 

7460 LANCASTER PIKE, SUITE 9, PO Box 640 

HOCKESSIN, DE 19707-0640 

OFFICE OF 

PREVENTION, PESTICIDES 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 detennined 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: R300 

NEW PRODUCT;ME-TOO PRODUCT FAST TRACK; 

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'~~ Front End Processing Staff 

Infonnation Technology & Resources Management Division 

104
IFee for Servicel 

This package includes the following 

I (!J New Registration 

i 0 Amendment 

I 

for Division 

OAD 

oBPPD 

(!J RD 

A 

{855085;-

I dStudies? 

I 

o Fee Waiver? 

v 

volpay % Reduction: 

Risk Mgr. [][J 

Receipt No. s-I 855085 

EPA File Symbol/Reg. No. I 85678-L 

Pin-Punch Date: 1 8/4/2009 

This item is NOT subject to FFS action. 

'--~~--Action Code"--: ~~~II Parent/Child Decisions: I , I i 

i Requested: I Q.-:j()Q I I 

, I I i Granted: e· ~VD I II 

I Amount Due: $ 1?Jlo5· U\) II T~~ ,~Jt. Wk~ LI ~~~~~~~~~~

~ Inert Cleared for Intended Use Ii!: 

Reviewer: ~M,Q lSwle 

Remarks: ~ 

Uncleared Inert in Product 

Date: ~s/~ 

105 *Inert ingredient information may be entitled to confidential treatment*
106
FEE FOR SERVICE 

107
108
Catherine Byrd 

From: 

Sent: 

To: 

Subject: 

paygovadmin@mail.doc.twai.gov 

Monday, August 03,20092:39 PM 

Catherine@wagnerreg.com 

Pay.Gov Payment Confirmation 

THIS IS AN AUTOMATED MESSAGE. PLEASE 00 NOT REPLY, 

Your transaction has been successfully completed. 

Payment Summary 

Application Name: PRIA Service Fees 

Pay.gov Tracking 1D: 24VLQF4L 

Agency Tracking ID: 74077518998 

Account Holder Name: James M. Wagner 

Transaction Type: Sale 

Billing Address: 25 Gates Circle 

City: Hockessin 

State/Province: DE 

Zip/postal Code: 19787 

Country: USA 

Card Type: American Express 

Card Number: ***********1013 

Payment Amount: $1,365.00 

Transaction Date: Aug 3, 2089 2:39:23 PM 

Decision Number: 

Registration Number: 

1 

, , " '" 

" , " , 

, 

) , ; " 

, 

, " , 

" , , , , " > , 

») , 

, 

, , 

, ; , , 

109
Please read instructions on reverse before corr:~" !iflgJonn. Form Approv"r!._ OMS No. 2070·0060. Approvai expires 05-31-98 

I X egistration OPP Identifier Number 

oEPA United States 

Environmental Protection Agency Amendment 

Washington, DC 20460 Other 

Application for Pesticide· Section I 

1. CompanylProduct Number 2. EPA Product Manager 3, Proposed Classification 

Red Eagle International LLC/85678- L. Tony Kish 

4. Company/Product (Name) PM. [g] None Restricted 

RedEagle International LLC/Ethephon 6 22 

5. Name and Address of Applicant (Include Zip Code) 6. Expedited Review. In accordance with FIFRA Section 3(c)(3) 

Red Eagle International LLC 

(b)(I), my product is similar or identical in composition and labeling 

to: 

clo Wagner Regulatory Associates, Inc. EPA Reg. No. 66330-250 

P.O. Box 640 

Hockessin, DE 19707 Product Name: Micro Flo Ethephon 6 

0 Check if this is a new address 

Section · II 

D Amendment - Expiain beiow. D Final printed labels in response 10 

Agency letter dated 

0 Resubmission in response to Agency ietter dated lEI "Me Too" Appiication. 

D Notification - Explain beiow. D Other - EXplain below. 

Explanation: Use additional page(s) if necessary. (For Section I and Section 11.) 

Section · III 

1. Material This ProductWlII Be Packaged In: 

Child-Resistant Packaging U~ckaging W~ Soluble Packaging 2. Type of Container fij Yes' Yes Yes Metal 

X No ex No ex No X Plastic 

if "Yes" No. per if "Yes" No. per Glass 

* Certitrcatron must Unit Packaging wgl. container Package wgt container Paper 

be submrtted I Other (Specify) HOPE lined bags 

3. Location of Net Contents Information 4. Size(s) Retail Container 5. Location of Label Directions 

m Label D Container bulk a On Label 

On Labeling accompanying product 

6. Manner in Which Label is Affixed to Product § Lithograph C1 Other _adhesive backed label 

X Paper glued 

Stenciled 

Section · IV 

1. Contact Point (Complete items directly below for idenfificafion of individual fo be confacted, if necessary, fo process fhis application. 

Name I Title 

Catherine M. BYrd Aqent for RedEaqle International LLC 

I Telephone No. (Include Area Code) 

(302i 234 2780 

Certification 

i certify that the slatements I have made on this form and aii attachments thereto are true, accurate and compiete, 

i acknowledge that any knowingly mise or misieading statement may be punishable by fine or imprisonment or 

both under appiicabie iaw. 

2, s~:a;~~e 

'iJI/:J x& ,d -' 

3. Title 

Agent for RedEagle International LLC 

4. Typed Name 5. Date 

Catherine M. Byrd July 31, 2009 

ThiS IS a reproduction of EPA Form 8570 -1 (Rev. 8 -94) PrevIous edtllons are obsolete. 

6. Date Application 

Received> , • 

" " ) 

. . 

) , " ) 

. . 

" 

f' i" ; . ' 

• ,. . , • 

(Stamped) 

, 

, " , 

' > , , , ,~, , 

. 

, 

• , ~ > 

'" , 

, ", , 

110
FEDERAL EXPRESS 

August 3, 2009 

Document Processing Desk (REGFEE) 

ATTN: Tony Kish 

Registration Division (7504P) 

U.S. Environmental Protection Agency 

Room S-4900, One Potomac Yard 

2777 South Crystal Drive 

Arlington, Virginia 22202-4501 

Dear Mr. Kish; 

Wagner Regulatory Associates, Inc. 

P.O. Box 640 

7460 Lancaster Pike, Suite 9 

Hockessin, Delaware 19707 

Re: Application to register a new product containing a currently registered active ingredient-

"Ethephon 6" 

Wagner Regulatory Associates, Inc., as agent for RedEagle International LLC, is requesting registration 

of the above referenced product. This product is substantially similar to the ethephon product registered 

by Arysta Lifescience North America, LLC. (Micro Flo Ethephon 6), under EPA Registration Number 

66330-250. 

In support of this request, the following documents and studies are attached: 

• Letter from RedEagle International LLC, appointing Wagner Regulatory Associates, Inc. as its 

agent 

• Application for Pesticide Registration (8570-1) 

• Confidential Statement of Formula (8570w4), 2 copies 

• Certification with Respect to Citation of Data (8570w34) 

• Formulator's Exemption Statement (8570w27) 

• Data Matrix (8570w35) 

• Data Transmittal Document 

• Product Identity and Composition data (3 copies) as outlined in the transmittal document 

• Physical and Chemical Properties data (3 copies) as outlined in the transmittal document 

• Draft labeling, 5 copies 

• For "mewtoo" product labeling, please refer to the EPA approved label for Registration Number 

66330-250. 

• A copy of the receipt confirming payment of the required registration fees. 

If you have any questions about this submission please contact the undersigned. 

Respectfully submitted, 

Catherine M. Byrd 

Agent for RedEagle International LLC 

Enclosures 

111
1. 

" " 

, ' , " 

'" , 

. , " 

, 

DATA TRANSMITTAL DOCUMENT 

Name and Address of Submitter 

Red Eagle International LLC 

cia Wagner Regulatory Associates 

PO Box 640 

Hockessin, DE 19707 , ";' 

Reg'ulatory Action In Support Of Which This Package Is Submitted , " . Ift"",,,hon 6 

o:PA Registration Number: 85678- '. , " . t'ra'nsmittal Date 

August 3, 2009 

4. List of Submitted Studies 

Vol. 1: Weiler, Paul J. (2008) "End Use Product Chemistry for 54% 

Ethephon, Physical and Chemical Properties Testing" Midwest 

Research Institute, Kansas City, Missouri. Project Number 

310810.1.004.13 pages. 

Vol. 2: Red Eagle International LLC. (2009) "Ethephon 6 Product Identity 

and Composition, Description of Materials Used to Produce the 

Product, Description of the Formulation Process, and Discussion of 

Formation of Impurities" Non-confidential portion 6 pages, 

Confidential portion 11 pages. 

Vol. 3: Byrd, Catherine M. (2009) "Ethephon 6 Product Chemistry Data 

Waiver' 4 pages. 

Company Official: 

Catherine M. Byrd ~libiri/ Name Signature 

Company Name: Wagner Regulatory Associates, Inc. 

Agent for Red Eagle International LLC 

Company Contact: 

Catherine M. Byrd (302) 234-2780 

Name Phone 

112
RED EAGLE INTERNATIONAL LLC. 

A Chemical Manufacture 

August 15,2008 

To Whom it May Concern 

Dear Sir or Madam: 

Phone: (863) 648-5448 

Fax: (863) 648-1606 

This letter serves as notification that RedEagle International LLC. has appointed Wagner 

Regulatory Associates, Inc. (WRA, Inc.) to serve as the Agent on our company's behalf 

regarding all state and federal regulatory matters relative to products that RedEagle 

International LLC. will register with the U.S. EPA and the states. Please forward all 

correspondence for RedEagle International LLC. and its products to: 

Wagner Regulatory Associates, Inc. 

P.O. Box 640 

Hockessin, DE 19707-0640 

Thank you for your time and assistance. Please feel free to call me if yOll have any 

questions. 

Respectfully submitted, 

Yingxue Yu 

Chief Executive Officer 

cc: WRA, Inc. 

" , , , ,,,,,, " , . , ",,', '>J , 

Address: 2651 Woodwind Hills Lane, Lakewood, FL 33812, US~: ' , ~ 

", , 

", , 

, " , , 

,J J' 

113
Form approved. OMB No, 2070-0060, 2070-0057, <:U70-0107, 2070-0122, 2070-0164. 

&EPA 

United States 

Environmental Protection Agency 

Washington, DC 20460 

Formulator's Exemption Statement 

(40 CFR 152.85) 

Appflcanfs Name and Address EPA File SymbOl/Registration Number 

85678-

RedEagle International LLC Product Name 

clo Wagner Regulatory Associates, Inc. Ethephon 6 

P.O. Box 640 

Hockessin, DE 19707 

Date of ConfJdential Statement of Fonnula (EPA Fonn 8570-4) 

07/3I12009 

As an authorized representative of the applicant for registration of the product identified above, I certify that: 

(1) This product contains the following active ingredient{s): 

Ethephon 

(2) Of these, each active ingredient listed in paragraph (4) is present solely as the result of the use of that active ingredient in the manufacturing, 

formulation or repackaging another product which contains that active ingredient Which is registered under FIFRA Section 3, 'IS purchased by 

us from another person and meets the requirements of 40 CFR section 158.50{e){2) or (3). 

(3) Indicate by checking (A) or (8) below which pal"<lgraph applies: 

71 (A) An accurate Confidential Statement of Formuta (EPA FORM 8570-4) for the above identified product is attached to this statement. 

That formula statement indicates, by company name, registration number, and product name. the source of the active ingredient{s) listed in 

paragraph (l). 

OR 

f (81 The ConIidential Statement of Formula (CSF){EPA Form 8570-4) referenced above and on file with the EPA is complete, current. an 

accurate and contains the information required on the current CSF. 

(4) The following active ingredients in this product qualify for the formulator's exemption. 

Source 

AcUve Ingredient Product Name Registration Number 

Ethephon 

) 

, , , " , , , , , , • ,')') , , , ' , " , . , , , , " , , , ,,-' ' > , , 

. , . • , '-'-'-. 

Sig~11I !?U~ Name and Title Date ' , . , ,,-', , 

Catherine M. Byrd, Agent " 07/31/2009 , .. EPA Form 8570-27 (Rev. 06-2004) Copy ,7" , 1 ~,r1 

Copy 2 - Applicant copy 

114 *Product ingredient source information may be entitled to confidential treatment*
Foon AI roved OM3 Nos. 2071).{)060; 2070{J057' 2070{Jl07; 207Q.()t22; 2070{J164 

..... '" UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 

\~ 1200 Pennsylvania Avenue, N.W. 

WASHINGTON, D.C. 20460 

Pape:rwcrk Redu:tionActNotice: The public reporting burden forthiscollection of information is estimated to avemgc t25 ltJurs per respo= for registration 

and 0.25 hours per responre for ren::giSll1ttiOll and special review activities, including time for reading the inslruooons and completing the nece.'lSW)' mnns. Send 

comments regarding blmlen estimate or any other aspect of this collection ofinfoonation, including suggestions for reducing the bUfden to: Director, CoHection 

Str1II.tegiesDivi5ion (2822T~ U.S. Environmental Protection Agency, 1200 Pennsylvania Avenue, N.W., Washington, DC 20460. Do not send the completedfonn 

to tIIis addre$s. 

Certification with Respect to Citation of Data 

AppliCilnrsJRenislfanfs Name, Address, and Telephone Number EPA Registration NumbertFile SymbOl 

RedEagle IntemationallLC, P.O. Box 640, Hockessin, DE 19707 85678-

Active Inllre<iient(s) andil:lr reoresentative test comoound(sl Dot, 

Ethephon July31,2009 

General Use PalEm(sl (list allhose claimed for this product using 40 CFR Part 1581 Product Name 

Terrestrial food crop use; Terrestrial nonfood crop use Ethephon 6 

NOTE: If your product is a 100% repackaging of another ptxehased EPA-regislered product labeled for a~ the same uses on your 1a~I, you do not need 10 

submil this foon. You musl submit tile Foonulalors ExefTlltion Stalemenl (EPA Foon 8570-27). 

D I am responding k.I a Data-Gall-In Notice, and have Induded with this fonT! a list of companies senl offers of compensation (the Data Matrix foon shoulj 

be used for thls purpose). 

SEC110N I: METHOO OF DATA SUPPORf (Check one method only) 

D I am using the cite-all method of support, and have induded with this fonT! [2] I am using the selective method of support (or cite-all option 

a Hst of companies sent offers of compensation (the Data Matrix foon under the selective method), and have included With this fonT! a 

shoulj be used iJr Ihis purpose). completed fist of data requirements (the Data Matrix iJon musl be 

used). 

SECTION II: GENERAL OFFER TO PAY 

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

[2] I herebyolfer and agree to pay compensaUon, to otller perwns. with regard to the approval of this application, to the extenl required by FIFRA 

SECTION III: CERTIFICATION 

I certify that this apprlcation for registration, thls foon for reregistration, Cf this Data-Call-In response is supported by aN data suhmitted orcited in the 

applicafion for registr.tUon, the iJon for rereglstratilln, or the Oata-Call-In response. In actdrtion, if the cite-all option Cf cite-all option under the selective method is 

indicated in Section 1,Ihis application Is supported by aU data lTthe Agency's files that(1) concem the properties or effeclll of this product or an identical or 

substantially similar product, Cf one Of more of the ingredients in this product; and (2) is a type of data that wou\:! be required to be submilted IJ1derthe data 

requirements in effect on tie dale of approval of this appijcation if the application sought the initial registration of a product of identical Of similar composition and 

uses. 

I certify that foreach exdusive use study ciled in support of this registration or reregistration, that I am the original data subrritter or that I have obtained 

the Mitten pl:!nT!ission of the original data submitter 10 cite that study. 

I certffy that for each study cKed in support of thls registration or reregislration that is not an exdusive use study, eHher: (a) I am the original data 

subrritter; (b) I haw obtained the pEmiission at the original data submitter to use the study in support oflhis application; (c) all periods ofe~gibility for 

compensation have expired for the study; (d) the 51udy is in the public literature; or(e) I haYe notified in writing !he company that submitted the studyand haYe 

offered (I) to pay compensation to theextoot required by sections 3(c)(I)(F) andlor 3(c)(2)(B) ofFIFRA; and OQ to commence negotiations to determine the 

amourt and terms of compensation, ~ any, to be paid for the use of the study. 

I certify that in all instances where an offer of compensalion is required, copies of ai offers to pay compensation and eW:lence of theirdelJvery in 

accordance with sections 3(c)(I)(F) ancVor 3(c)(2)(B) of FIFRA are available and will be suhmllled to tle I\len<:y upon reql.ll:!st. Shotld I ail to produce such 

evidence to the Agency upon requesl, I undersland tIlat the Agency may initiate action to deny, cancel or suspend the registrnlion of my product in conformity with 

FIFRA. 

I certify that the statements I have made onthls fonn and all attachments to It are true, accuratl, and complete. I ackno ..... edge that any 

knowingly false or mlsloadil'Q sllltlllmentmay be punlshablo by fino or Imprlsonmont or both under appllcahle IIIW_ 

Signature 

~~wL 0.. Typed Of Printed Name ard Title August 10, 2009 Calheline M. Byrd, Agenl 

EPA FQrrn 6570-34 (12 -2003) Electronlc and Paper versions available. Submit only Paper version. 

115
#' "- Form Approved OMB No. 2070-0060 ("'1 =. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 

, .... ,"/ 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 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 instruction and completing the necessary forms. Send comments regarding the 

burden estimate or any other aspect of this collection of infonnation, including suggestions for reducing the burden to: Director, OPPE Infonnation Management Division (2137), 

U.S. Environmental Protection Agency, 401 M Street, S.W., Washi~l!ton DC 20460. Do not send the fonn to this address. 

DATA MATRIX 

Date: July 31, 2009 EPA Reg No.1 File Symbol: lpage I of3 

85678-

Applicant'slRegistrant's Name and Address: RedEagle International LLC Product: 

c/o Wagner Regulatory Associates Inc. 

P.O.Box640 Ethephon 6 

Hockessin, DE 19707 

Ingredient: Ethephon 

yName I MRID' I Status I Note 

PRODUCT SPECIFIC 

830.1550,830.1600,830.1620, Product Identity, RedEagle International LLC 

--30.6302 

--30.6303 

1830. 

.1670 Composition/Description of Materials 

used to Produce thc ProduetiDescription 

ofFofITmlation ProeesslDiscussion of 

ofl 

Odor 

co 

J.! State 

yto 

:.~ 

aiJility 

~ 

-,..-. I Die·-_ .. ·_w_·· 

--:: __ ---:.....:~ RH. ~: 

-"~"'~~~" 

Signature ~11LBII~ 

RedEag 

.edl 

.ed] 

"edE" 

RedEa 

RedEa 

RedEa 

RedE 

RedI 

RedEa 

RedEa 

DN"::~ 

edEa 

edEa 

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

II L 

LL' 

11 LV 

,I L 

~I LLC 

Name and Title 

Catherine M. Byrd, Agent for RedEagle International 

LLC 

Ow, 

Own 

Ow, 

Ow, 

Ow, 

Ow, 

I Own 

Ow, 

Ow, 

I O\~rl 

)w, 

Date 

July 31, 2009 

Al!ency Internal Use Cony 

116
/" ">;. Form Approved OMB No. 2070-0060 ( .... \ Sl!i2; UNITED STATES ENVIRONMENTAL PROTECTION AGENCY '>.,-,¢ 

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 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 instruction 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., Washin!!ton DC 20460. Do not send the form to this address. 

DATA MATRIX 

Date: July 31, 2009 EPA Reg No.!FHe Symbol: I Page 2 00 

85678-

AppIicant's/Registrant's Name and Address: RedEagle International LLC Product: 

c/o Wagner Regulatory Associates Inc. 

P.O. Box 640 Ethephon 6 

Hockessin, DE' 19707 

Ingredient: Ethephon 

Guideline Reference Number Guideline Study Name MRID Number Submitter Status Note 

830.7200 Mellin ~ pointimelling rangc RedEaglc International LLC OW" 

830.7220 Boiling pointJboiling range RedEa Ie International LLC OW" 

830.7300 DensitylRelative Densi RedEa Ie International LLC Own 

830.7370 Dissociation constants in water Red Eagle International LLC Own 

830.7520 Particle size, fiber length, and diameter RedEa Ie International LLC Own 

830.7550 Partition coefficient n-octanollwater) RcdEagle International LLC O~ 

830.7840 Water solubilit RcdEa Ie International LLC Own 

830.7950 Vapor pressure RcdEaglc International LLC Own 

870.1100,1200,1300,2400, Acute Oral, Dennal, Inhalation, Eye Cite All Agricultural Handlers Exposure Task Force, Macon, MO p'Y 

2500,2600 Irritation, Dennal Irritation, Skin Agricultural Reentry Task Force, Washin ton, DC 

Sensitization Albau h, Inc., Valdosta, GA 

Axss USA, LLC, Brookfield, CT 

BASF Sparks LLC, Research Triangle Park, NC 

Celsius Property B. V., Amsterdam, Raleigh, NC -.~ .. 

Chemical Products Tcchnologies, Cartersville, GA 

Chcminova, Arlin on, VA 

. "- -- Dow Agroscienees, Indianapolis, IN 

· · · · " .. Drexel Chemical Company, Memphis, TN --... · " I" " E.!. DuPont de Nemours & Co., Newark, DE 

· " .' . .. ____ "c 

FIFRA Endan ered Species Task Force, LLC, Washington, DC 

FMC Co oration, PhiJadel hia, PA 

.. . · . Generic Endangered Species Task Force (GESTF), Washington, DC . " " . . Helena Chemical Co., Collierville, TN .. " " · " . " " " 

" . " " . " " ~~~ ~ " Helm A ro, Inc., Mem his, TN 

" " c' ., • " " " 

" " . " IndustriaProdotti Chimici, Washington, DC 

Signature 

&J1jlJ)(MIJ-:;JlH!~ Name and Title Date 

Catherine M. Byrd, Agent for RedEagle International July 31, 2009 

LLC 

EPA Form 8570-35 (9-97) Electronic and Paper versions available. Submit only Paper versIOn. AIJenl'v Intf'rn<ll It.,,, r ... n" 

117
F ., Form Approved QMB No. 2070-0060 ;' ft "- l,Slft , UNITED STATES ENVIRONMENTAL PROTECTION AGENCY "~-'';/ 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 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 instruction and completing the necessary fonns. Send conunents regarding the 

burden estimate or any other aspect of this coUection of information, including suggestions for reducing the burden to: Director, OPPE Infonnation Management Division (2137), 

U.S. Environmental Protection Agency, 401 M Street, S.W., Washington DC 20460. Do not send the fonn to this address. 

DATA MATRIX 

Date: July 31, 2009 

Applicant'slRegistranfs Name and Address: RedEagle International LLC 

c/o Wagner Regulatory Associates Inc. 

P.O. Box 640 

Hockessin, DE 19707 

Ingredient: Ethephon 

Guideline Rcference Number Guideline Study Name I MRID Number 

EPA Reg No.! File Symbol: 

85678· 

Product: 

Ethephon 6 

Co .. 

~orth Ameri 

lei Hill, NC 

'~,DC 

,J~C 

e Task Force, LLC 

DE 

:essin, DE 

I,NC 

Reside 

Ritter ( 

.§pray Drift_ 

Josun 

I, Wa 

\Fc 

ashington, DC 

1) of Limt:s ~ied' in t31e ( c. ~c. 

~" 

" " 

Signature 

t 01 a EPA fonn 8574-4 

I,DC 

.,Ne 

:tho Company, Marysville, OH 

USA Corp., Walmn Creek, CA 

~gXin 

Name and Title 

I Page 3 of3 

! Status ! Note 

DC 

~ 

Date 

~11L${rL Catherine M. Byrd, Agent for RedEagle International July 31, 2009 

J.LC 

EPA Form 8570-35 (9-97) Electronic and Paper versions available. Submit only Paper version. Agency Internal Use CODY 

118
;;.;'''',,-

'A, 

l~) UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 

401 M Street, S.W. 

WASHINGTON, D.C. 20460 

Form Approved OMB No. 2070·0060 

Paperwork Reduction Act Notice: TIle public reporting burden for this collection ofinfonnation 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 instruction and completing the.,rl'<:.ccssa~ fOIJI1s. Se~d comments regarding the 

burden estimate or any other aspect ofthis coIlection of information, including suggestions for reducing the burden to: Directok, t;)PPE 'iJjf-orLtta$iotl r:f1atIa§eIiient Division (2137), 

U.S. Environmental Protection Agency, 401 M Street, S.W., Washington DC 20460. Do not send the fonn to this address. '" ~ - ~_-'-~~~~~~~~--I 

DATA MATRIX 

Date: July 31,2009 

Applicanfs/Registranfs Name and Address: 

Ingredient: Ethephon 

RedEagle International LLC 

C/o Wagner Regulatory Associates Inc. 

P.O. Box 640 

Hockessin, DE 19707 

EPA Reg No.1 File Symbo~·.~" ~ 

85678- ~ ~ ~ 

Product: ~ ~ 0 ~ 

Ethephon 6 

~~" Page Iof3 

Signature Date /JhI-J,-lJ.J1 AI I /}1 J t} hAl ./ I Name and Title 

{]J../JlP l)/JV-" l~' ~ Catherine M. Byrd, Agent for RedEa .Ie International LLC I July 31 > 2009 

EPA Form 8570-35 (9-97) Electronic and Paper versions available. Submit only Paper version. Agency Internal Use COpy 

T 

119
".." l=) ,,",,-, UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 

401 M Street, S.W. 

WASHINGTON, D.C. 20460 

Form Approved OMB No. 2070-0060 

Paperwork 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 instruction and completing th&nccessar,/ fo~ms. Se9-dvco!lngents regarding the 

burden estimate or any other aspect of this col!ection ofinfonnation, including suggestions for reducing the burden to: Directo~ ~@pPE16for5r.,,:iioiI ~a!lag~l~lent Division (2137), 

U.S. Environmental Protection ~g!::ncy, 401} .. 1 StreetJ.S.W., Washington DC 20460. Do not send the [onn to this address. v v ~ ~ 

DATA MATRIX 

Date: July 31, 2009 EPA Reg No.1 File Symbof-~-""-:~--- ~ I Page 2 of3 

85678~ v 

Applicant's/Registrant's Name and Address: RedEagle International LLC Product 

Ingredient: Ethephon 

Signature 

~?lL&t 

clo Wagner Regulatory Associates Inc. 

P.O. Box 640 

Hockessin, DE 19707 

Ethephon 6 

Name and Tide I Date 

Catherine M. Byrd, Agent for RedEagle International LLC July 31, 2009 -_..... -_ ...... . 

EPA Fonn 8570-35 (9-97) Electronic and Paper versions available. Submit only Paper version. Agency Internal Use COpy 

1 

120
""'''' .. t~l ~~-~ UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 

401 M Street, S.W. 

WASHINGTON. D.C. 20460 

Form Approved OMB No. 2070-0060 

Paperwork 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 instruction and completing the"lt~Cessary fO"IDS. Send cOfl1~ments regarding the 

burden estimate or any other aspect ofthis collection of information, including suggestions for reducing the burden to: Directot" 'QPPE'I~(illr~mrtic:a Ha9.arte~el1t Division (2137), 

U.S. Environmental Protection Agency, 40 I M Street, S.W., Washington DC 20460. Do not send the fonn to this address. ~ ~ "- ~ ~ _c_c~ _________ ~ 

DATA MATRIX - .. 

Date: July 31, 2009 

Applicant'slRcgistrant's Name and Address: 

Ingredient: Ethephon 

RedEagle International LLC 

clo Wagncr Regulatory Associates Inc. 

P.O. Box 640 

Hockessin, DE 19707 

EPA Reg No.! File Symbo}:~" ~ 

85678- ~"~ 

Product: " _' ~ u 

Ethcphon 6 

! Page 3 oD 

Note 

Signature /J1J.J....J4-.rtt'1ll g·-;MI Iflf I,A I Name and Title I Date 

(!J).lI!!!f!/~ I1.A::J-Ir~ Catherine M. Byrd, Agent for RedEagle Inlernational LLC July 31, 2009 

EPA Form 8570-35 (9~97) Electronic and Paper versions available. Submit only Paper version. Al!cncv Intern:llll~f' rnnv 

T 

121
122
Pages 123-126 - *Confidential Statements of Formula may be entitled to confidential treatment*