REGISTRATION

9468-45 
Material Sent for Data Extraction 

Reg # ~ l{ I.O~~\.{ 5 

Description: Nc,u)WcWd-' 

¥ Material(s) Sent to Data Extraction Contractors: 

lob\ll New Stamped Label Dated ___ _ 

D Notification Dated ____ _ 

D New CSF(s) Dated ____ _ 

D Other: _________ _ 

r2s Decision #: __ "-1_. _Lt,--,iQ.~s_eLJt 1 _____ _ 

D Other ActionjComments: ________ _ 

Attach this coversheet to the top of the material or jacket. It 

must be well organized and clipped together, NOT STAPLED. 

Then give the material with this coversheet to staff in the 

Information Services Center (Room S-4900). 

Reviewer: :::s c~ ~J\Q...-

Ph 0 n e: :p5' ~~0) \ D i vis ion: -,®,-",,-,,-\ -:t1-'..:l3 ___ _ 

Created 

Date: 

February ~=-----~~-'-\~3~\\~\----------------- 3, 2011 

1
EPA Reg. Date of Issuance: 

..1'-«"f.OST4" U.S • ENVIRONMENTAL PROTECTION AGENCY 

<, Office of Pesticide Programs Number-: 

§ ~ \ 

(~W Registration Division (7S0SP) 9468-45 OCT Q 1200 pennsylvania Ave., NW - v 201'i 

"-1-l:j( AAOIe.";# Washington, D.C. 20460 

Ter-m of Issuance: 

NOTICE OF PESTICIDE, 

Registration Conditional x --- Reregistration Name of pesticide Pr-odul:;:t: 

~under FIFRA, as amended) Ritter Dicamba Tecnical 

Name and Address of Registrant (include ZIP Code) : 

Ritter Chemical LLC 

c/o Pyxis Regulatory Consulting, Inc. 

4110 136th ST. NW 

Gig Harbor, WA 98332 

"Note: Changes in labeling differ-ing in substance fr-om that accepted in connection with this registr-ation must 

be submitted to and accepted by the Registration Division pr-ior- to use of the label in commer-ce. In any 

correspondence on this pr-oduct always r-efer- to the above EPA r-egistration number-. 

On the basis of information furnished by the registr-ant, the above named pesticide is hereby 

register-ed/r-er-egistered under- the Feder-al Insecticide, Fungicide and Rodenticide Ac~. Registration is in no 

way to be construed as an endorsement or recommendation of this product by the Agency. In order to pr-otect 

health and the environment, the Administrator, on his motion, may at any time suspend or cancel the 

r-egistration of a pesticide in accordance with the Act. The acceptance of any name in connection with the 

r-egistration of a product under- this Act is not to be construed as giving the registr-ant a r-ight to exclusive 

use of the name or to its use if it has been cover-ed by others. 

This product is conditionally registered in accordance with FIFRA sec. 

3 (c) (7) (A) provided that you: 

1. Submit and/or cite all data required for registration/ 

reregistration of your product when the Agency requires all registrants 

of similar products to submit data. 

2. Add the phrase 11 EPA Reg. No. 9468-45 11 to your label before you 

release the product for shipment. 

Signatur-e of Approving Official: Date: 

:J1u~ v·/rUOb ··C 

~; ·1 

Kathryn V. Montague 

Product Manager 23 

Herbicide Branch 

Registration Division (7S0SP) 

EPA Form 8570 Ii 

2
page 2 

EPA Reg. No. 9468-45 

3. Submit one (1) copy of your final printed labeling before 

you release the product for shipment. 

4. Submit the results of one year storage stability and 

corrosion characteristic studies to EPA within one year of this 

date of registration. Submit a hard copy and an electronic copy 

also. 

If these conditions are not complied with, the registration 

will be subject to cancellation in accordance with FIFRA 

section 6(e). Your release for shipment of the product 

constitutes acceptance of these conditions. 

A stamped copy of the label is enclosed for your records. 

3
Ritter Dicamba Technical 

FOR MANUFACTURING HERBICIDES ONLY 

ACTIVE INGREDIENT: 

Dicamba [3,6-dichloro-o-anisic acid] ....................................................................................... ., .......... 98.90/0 

OTHER INGREDIENTS: ........................................................................................................ n •••••••• 1.1% 

TOTAL: ................................................ " ........................................................................................... 100.0% 

Ifin eyes: 

Ifswaliowed: 

Iron skin or clothing: 

KEEP OUT OF REACH OF CHILDREN 

DANGER 

FIRST AID 

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

• Remove contact lenses, if present, after the firstS minutes, then continue rinsing 

eye. 

• Call a poison control ccnter or doctor for treatment advice. 

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

• Have person sip a glass of water ifable to swallow. 

• Do not induce vomiting unless told to do so by thc poison control cenler or 

doctor. 

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

• 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. 

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

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

treatment. For infonnation on this pesticide product (including health concerns, medical emergencies, or 

pesticide incidents), call Ihe National Pesticide Information Center at 1-800·858·7378, Monday through Friday, 9 

a.m. to 5 p.m. After 5:00 p.m., call your poison control center at 1-800·222-12':12. 

EPA Reg. No. 9468-

EPA Est. No. 

Net Contents: 

See back panel for additional precautionary statements. 

, OCT - 3 I' 

) 17mbr the ~':~":,nl ,::'~~C::h,)!C!l, II i "_d., _,I)Q.',MC1Ju Act, _. fC,l- CD_il pl);;t:c!de I 

'1,·,\,-,· 

i"t)~~.~:'l-<i 

Manufactured for: 

Ritter Chemical, LLC 

P. O. Box 430974 

Houston, TX 77243 

(713) 461-2262 

Batch No.: 

Riner Dicamba Techmcal- (pending us EPA File No q.i~-.:x) 

Label Ve!1lion (I) dalcd March 11,2011 

Page I of2 

4
PRECAUTIONARY STATEMENTS 

HAZARDS TO HUMANS AND DOMESTIC ANIMALS 

DANGER. Corrosive. Causes irreversible eye damage. Harmful if swallowed. Do not get in eyes, on skin or on 

clothing. Wear goggles or face shield when handling. Wash thoroughly with soap and water after handling. Remove 

contaminated clothing and wash before reuse. 

ENVIRONMENTAL HAZARDS 

Do not contaminate water by the cleaning of equipment or disposal of wastes. Do not discharge effluent containing this 

product into lakes, streams, ponds, estuaries, oceans, or other waters unless in accordance with the requirements of a 

National Pollutant Discharge Elimination System (NPDES) permit and the permitting authority has been notified in 

writing prior to discharge. Do not discharge effluent containing this product to sewer systems without previously 

notifying thc local sewage treatment plant authority. For guidance, contact your State Water Soard or Regional Office 

of the EPA. 

DIRECTIONS FOR USE 

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

This product may only be used to formulate herbicide products for the following use(s): 

J. Asparagus, corn, fallow systems, grass forage, fodder and hay (including grasses grown for seed), millet, small 

grains (barley, oats, wheat), sorghum (including sudangrass), soybeans, sugarcane, cotton, pasture and rangeland, 

Conservation Reserve Program Areas, farmsteads, fence rows, lawns, non-irrigation ditchbanks, rights-of-way, 

roadsides, turf and sod farms; 

2. Uses for which EPA has accepted the required data and/or citations of data that the formulator has sltbmitted in 

support of registration. 

3. Uses for experimental purposes that are in compl iance with EPA registration for the fomlUlated products. 

This product may be used to formulate products for specific uses not listed On the label if the formulator, user group, or 

grower has complied with U.S. EPA data submission requirements regarding support ofsltch uses. 

Each formulator is responsible for obtaining EPA registration for their end-use product(s). 

STORAGE AND DISPOSAL 

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

PESTICIDE STORAGE: Store in original container, in a well-ventilated area away from fertilizers, feed and 

foodstuffs. Avoid cross-contamination with other pesticides. Spillage or leakage should be containcd, carefully swept 

up, and collected for disposal. Wash area of spill with detergent and water. 

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: Plastic Bag: Nonrefillable container. Don not reuse or refill this container. Completely 

empty bag into formulation equipment. Then offer for recycling if available, or dispose of empty bag in a sanitary 

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

WARRANTY AND LIABILITY 

Ritter Chemical LLC warrants that this product conforms to the chemical description on the label, and is reasonably fit 

for the purposes set forth in the "Complete Directions for Use" booklet labeling, when used in accordance with those 

Complete Directions for Use, under the conditions described therein. TO THE EXTENT CONSISTENT WITH 

APPLICABLE LAW, NO OTHER EXPRESS WARRANTY OR IMPLIED WARRANTY OF FITNESS FOR 

PARTICULAR PURPOSE OR MERCHANTABILITY IS MADE. This warranty is also subject to the conditions and 

limitation stated herein. 

5
UNITED STATES El'OVIRONMENTAL PROTECTION AGENCV 

WASHINGTON, D.C. 20460 

OFFICE OF CIIE:\I1CAI. SAFETY 

.\:>\0 POLLlTIO:\"I'RF.\'E:\"TIO.\" 

OFFICE OF l'ESTlClllE l'ROG1LUIS 

llEG1STRAT10:\" DlV1S10:,,> (7~{j51'! 

BARCODE: 388021; Reg. No./FILE SYMBOL No.:9468-UL; PRODUCT: Ritter Dicamba Technical 

DATE: August 25, 2011 

SUBJECT: Product Chemistry Review of "Ritter Dicamba Technical" TGAIIMUP 

FROM: Akiva Abramovitch, Ph.D. I 

Technical Review Branch / RD (7505P) X ~ qltl1i 

TO: James Stone,Team Reviewer IKathryne Montague, Risk Manager, RM 23 

Herbicide Branch 1 RD (7505P) 

DP BARCODE: 388021 

DECISION No.: 446591 

REGISTRATION NO./FILE SVMBOL NO.: 9468-UL 

PRODUCT NAME: Ritter Dicamba Technical 

PC CODE: 028801 

REGISTRANT: Ritter Chemicals, LLC 

USE: Herbicide 

FOOD USE: Ves IX 1 No 11 

MRID Numbers: 484205-01 through 484205-04 

INTRODUCTION: 

! 

The registrant is seeking a new product registration for Ritter Dicamba Technical. The product is 

substantially similar (identical?) to a currently registered product (42750-57) and the registrant is using 

the "cite-all" method of support. A basic formulation dated 9/6/11 (replaces the 3/111111 CSF) was 

submitted as well as Group A data .. 

This review has been altered subsequent to the contractor's signatures. 

SUMMARY OF FINDINGS: 

1. The registrant submitted a Confidential Statement of Formula (CSF) for the basic fonnulation 

(3/11/2011). The product chemistry data corresponding to guideline reference 830.1550 (product identity 

& composition) submitted on the CSF satisfy the data requirements of 40CFR§158.155. The data 

corresponding to guideline reference 830.1750 (certified limits) satisfy the requirements of 

40CFR§158.175 [MRID No. 484205-01]. The content of active ingredient given on the CSF for the basic 

formulation matches the label. 

2. The product chemistry data submitted corresponding to guideline reference 830.1600 (description of 

material used to produce the product) satisfy the data requirements of 40CFR§ 158.160 [MRID No. 

484205-011· 

3. The product chemistry data submitted corresponding to guideline reference 830.1620 (description of 

production process) satiSfy the data requirements for 40CFR§158.162 [MRID No. 484205-01]. 

6
BARCODE: 388021; Reg. No./FllE SYMBOL No.:9468-UL; PRODUCT: Ritter Dicamba Technical 

4. The product chemistry data submitted corresponding to guideline reference 830.1670 (discussion of 

the formation of impurities) satisfy the data requirements for 40CFR§158.167 [MRlD No. 484205-01]. 

5. The product chemistry data submitted corresponding to guideline reference 830.1700 (preliminary 

analysis) to support the claims on the CSF satisfy the data requirements of 40CFR§158.170 [MRID No. 

484205-021· 

6. The product chemistry data submitted corresponding to guideline reference 830.1800 (enforcement 

analytical method) satisfy the data requirements of 40CFR§158.180 [MRID 484205-02]. 

7. The data submitted corresponding to guidelines 830 Series Subgroup B (physical-chemical properties) 

satisfy the data reqUirements of 40CFR§158.190 [MRID No. 484205-03 and 484205-04]. Waivers were 

requested for explodability and flammability. Provision of corrosion characteristics and storage stability 

will be conducted if requested by the Agency. 

CONCLUSIONS: 

The TRB has reviewed the product chemistry data submitted for Ritter Dicamba Technical (produced by 

Ritter Chemicals, LLC) and has concluded that: 

1. The product chemistry data submitted for guideline 830 Series group A are acceptable, except for 

impurities of potential concern. 

2. The product chemistry data corresponding to 830 series group B (physical-chemical properties) are 

acceptable. 

3. The proposed CSF for the basic formulation dated September 6, 2011 (replaces the March 11,2011 

CSF) is acceptable. The registrant listed all the known potential impurities of toxicological COncern on 

the CSF. The total amount of unidentified impurities is 

4. This product is substantially similar to product EPA Reg. No. 42750-57. However, this product listed all 

potential toxic impurities on the CSF 

830.1550. Product identity & composition: (MRID No. 484205-01) 

Common Name: Dicamba 

Chemical name (CAS): 3,6-dichloro-2-methoxybenzoic acid 

(IUPAC): 3,6-dichloro-o-anisic acid 

CAS No.: 1918-00-9 

PC Code No.: 028801 

Empirical Formula: CaH60 3Clz 

Molecular Weight: 221.0 

Structural Formula: 

2 

7 *Manufacturing process information may be entitled to confidential treatment*
BARCODE: 388021; Reg. No.IFILE SYMBOL No.:9468-UL; PRODUCT: Ritter Dicamba Technical 

OCHo 

HOOC CI 

CI 

iI 

830.1600 

830.1620 484205-01 A 

830.1670 484205-01 U i 1 

iI 

1 , 

Ii 

484205-02 A 

3 

8
BARCODE: 388021; Reg. No./FILE SYMBOL No.:9468-UL; PRODUCT: Ritter Dicamba Technical 

830 Series Subgroup B (Physical-Chemical Properties) 

Table 2: Physical and Chemical Properties of: Ritter Dicamba Technical TGAI 

GLN Requirement MRID Status Result or Deficiency 

830.6302 Color 484205-03 A Off-white with brown specks 

830.6303 Physical state 484205-03 A Solid crystals 

830.6304 Odor 484205-03 A Odorless 

Stability to normal and 

A Stable to normal and elevated temperatures ror t4 830.6313 elevated temperatures, 484205-03 

metals, and metal ions days 

830.6314 Oxidation/reduction: 484205-03 A Compatible with water, hexane, zinc, NH.H2PO., chemical incompatibility and KMnO •. 

830.6315 Flammability 484205-04, 

CSF W Solid; contains no flammable components 

830.6316 Explodability 484205-04 W Solid; does not contain any explosive components 

830.6317 Storage stability 484205-04 G Win be conducted if requested by Agency 

830.6319 Miscibility 484205-04 NfA Not an emulsifiable liquid 

830.6320 Corrosion characteristics 484205-04 G Will be conducted if requested by Agency 

830.7000 pH 484205-03 A 1.92 ± 0.03 at 25.7·C 

A Wavelength; molar absorption: 

830.7050 UVNisible absorption 484205-03 Acid:'\"'ax=281.0; (rn",,=776 

Neutral: Am ... = 275.2; Em ... = 490.3 

Basic: Amoo< = 275.; £mOJ< = 469.7 

830.7100 Viscosity 484205-04 NfA Solid 

830.7200 Melting point 484205-03 A -114.5-116.1"C 

830.7220 Boiling point 484205-04 NfA Solid 

830.7300 Density 484205-03 A 0.702996 ± 0.000488 gtmL at 19'C 

Dissociation constants in 

830.7370 water pKa = 1.97 (Tomlin, The Pesticide Manual, 13'" (DC) 484205-04 A 

Ed~ion, p. 279, BCPC Publications, Hampshire, 2003) 

830.7550 Partition coefficient (o/w) 484205-04 A Log P '" -0.55 (pH 5); -1.88 (pH 6.8); -1.9 (pH 8.9) 

(Tomlin, The Pesticide Manual, 13"'Ed~ion, p. 279, 

BCPC Publications, Hampshire, 2003) 

830.7840 Water solubility 484205-04 A 6.1 giL at 25·C (fomlin, The Pesticide Manual, 13tl1 

Edition, p. 279, BCPC Publications, Hampshire, 2003) 

1.67 mPa at 25'C (Tomlin, The Pesticide Manual, 

830.7950 Vapor pressure 484205-04 A 13th Editfon, p. 279, BCPC Publications, Hampshre, 

2003) 

A = Acceptable; N = unacceptable (see Deficiency); N/A Not Applicable; G Data gap; I '" In progress; 

U = Up-grade (additional information required); W = waivers 

830.1800 (enforcement analytical method) 

The enforcement analytical method to determine the content of active ingredient is HPLC with UV 

detection. Appropriate validation and precision studies were conducted and sample chromatograms were 

provided. The registrant provided the following details in MRID 484205-01: 

4 

9
BARCODE: 388021; Reg. No. IFILE SYMBOL No.:9468-UL; PRODUCT: Ritter Dicamba Technical 

Ritter Dicamba Technical is dissolved in acetonitrile and separated on a ZORBAX XDB C8 reverse phase 

column. The content of dieamba is measured by an HPLC-UV detector with an external standard. 

Apparatus 

HPLC System: 

Glassware: 

Balance: 

Vials: 

Reagents 

Dicamba standard: 

Phosphoric Acid: 

Acetonitrile: 

Water 

Agilent 1100 HPLC 

volumetric 

Mettler Toledo XS 205 

2ml 

known purity 

analytical grade 

HPLCgmde 

redistilled 

Chromatographic Conditions 

Conditions may be changed to obtain satisfactory performance with other instruments provided adequate 

resolution and sensitivity are achieved. 

Instrument: 

HPLC Column: 

Mobile phase: 

Column temperature: 

Injection volume: 

Stop time: 

Flow Tatc: 

Wavelength: 

Retention time: 

Agilent \lOa HPLC 

ZORBAX XDB C8 150 x 4.6mm, 5 micron 

Acetonitrile/phosphoric acid aqueous solution (pH""3), 35:65 

25°C 

J ~l 

8 minutes 

1.0 mVmin. 

230nm 

dicamba, - 5.3 minutes 

5 

10
DATA EVALUATION RECORD 

DICAMBA 

(RITTER DICAMBA TECHNICAL) 

STUDY TYPES: Product Identity and Composition (OPPTS 830.1550) 

Description of Materials Used to Produce the Product (OPPTS 830.1600) 

Description of the Production Process (OPPTS 830.1620) 

Discussion of Formation of Impurities (OPPTS 830.1670) 

Preliminary Analysis (OPPTS 830.1700) 

Certified Limits (OPPTS 830.1750) 

Enforcement Analytical Method (OPPTS 830.1800) 

Physical and Chemical Characteristics (OPPTS 830.6302-830.7950) 

MRIDs 484205-01 through 484205-04 

Prepared for 

Registration Division 

Office of Pesticide Programs 

U.S. Environmental Protection Agency 

One Potomac Yard 

2777 South Crystal Drive 

Arlington, VA 22202 

Prepared by 

Summitec Corporation 

9724 Kingston Pike, Suite 602 

Knoxville, Tennessee 

Task Order No. 3-A-98 

Primary Reviewer; 

Thomas C. Marshall, Ph.D Signature: IhONY>Jv0 C· !Yllv~" Date: AUG 2 2 2011 

Secondary Reviewers: 

Dennis Opresko, Ph.D Signature: 

Date: /Q,," -_ '~ L - \ ... ~ 

~ It ._'"« \1' Q . s ~ ... '(Qt..~ ~ __ Robert Ross, M.S .. Program Manager Signature: 

Date: AUG 2 2 7~11 Quality Assurance: 

Angie Edmonds, B.S. Signature: 

Date: 

'~ 

~ AU~222011 

Disclaimer 

his review may have been altered subscqucnllo the contractor's signatures above. 

Summilec Corp. for the U.S. Environmental Protection Agency under Contract No.EP-W-II-OI4 

11
EPA File Symbol 9468-UL 

PC Code 029801 (dieamba) 

o IISEP/20 I I 

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 

WASHINGTON, D.C. 20460 

OFFICE OF CHEMICAL SAFETY AND 

POLLUTION PREVENTION 

OFFICE OF PESTICIDE PROGRAMS 

REGISTRATION DIVISION (7505P) 

TECHNICAL REVIEW BRANCH 

SIMILARITY DETERMINATION 

MEMORANDUM 

Subject: 

From: 

To: 

Applicant: 

Name of Pesticide Product: 

EPA Reg. No.lFile Symbol: 

DP Barcode: 

Decision No: 

Action Code: 

PC Code: 

Ritter Dicamba Technical 

9468-UL 

D388022 

446591 

R310 

02980 I (dicamba) 

Eugenia McAndrew, Biologist 

Teclmical Review Branch 

Registration Division (7505P) 

James Stone, RM Team 23 

Herbicide Branch 

Registration Division (7505P) 

Ritter Chemicals, LLC 

P.O. Box 430974 

Houston, TX 77243 

FORMULATION FROM LABEL: 

Active Ingredient(s): 

Dicamba 

Other Ingredient(s): 

Total: 

Page I of3 

% bywt. 

98.9 

1.1 

100.0% 

12
EPA File Symbol 9468-UL 

PC Code 029801 (dicamba) 

ACTION REQUESTED: The Risk Manager requests: For Similarity Clinic: "Under the Cite~ 

All Method is the acute toxicity substantially similar to the cited me too product EPA Reg. No. 

42750-57?" 

BACKGROUND: Ritter Chemicals, LLC has applied for registration of Ritter Dicamba 

Technical, EPA File Symbol 9468-UL, claiming similarity to Albaugh Technical Dicamba Acid, 

EPA Reg. No. 42750-57. Both products are technical grade for manufacturing use only. 

The registrant is using the cite-all method of data support to satisfy the acute toxicity data 

requirements. A basic CSF dated March 11, 2011, a label and company letter are included in the 

submission. 

A search of the OPP electronic databases shows that six acute toxicity studies were submitted to 

support the reregistration of the cited product, 42750-57. They were reviewed and classified as 

acceptable in a Product Reregistration Branch memo (Dupuy; D363560; 16/APRJ2009). 

RECOMMENDATIONS: 

1. TRB compared the fonnulations of the proposed product, 9468-UL and the cited product, 

42750-57, and concluded that the two products are substantially similar. 

2. The acute toxicity profile for the proposed product, Ritter Dicamba Technical, EPA File 

Symbol 9468-UL, is as follows: 

acute oral toxicity III cited EPA Reg. No. 42750-57 

acute dermal toxicity IV cited EPA Reg. No. 42750-57 

acute inhalation toxicity IV cited EPA Reg. No. 42750-57 

primary eye irritation I cited EPA Reg. No. 42750-57 

primary skin irritation IV cited EPA Reg. No. 42750-57 

dermal sensitization negative cited EPA Reg. No. 42750-57 

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 determination of the adequacy of the toxicological data base or 

the precautionary label of the cited product. 

4. The proposed basic CSF submitted for 9468-UL must be accepted by the TRB Product 

Chemistry Team. 

Page 2 of3 

13
EPA File Symbol 9468-UL 

PC Code 029801 (dicamba) 

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 #: 009468-00045 

PRODUCT NAME: Ritter Oicamba Technical 

PRECAUTIONARY STATEMENTS 

SIGNAL WORD: DANGER 

Hazards to Humans and Domestic Animals: 

Corrosive. Causes irreversible eye damage. Harmful if swallowed. Do not get in eyes or on clothing. Wear 

protective eyewear (goggles, face shield, or safety glasses). 

First Aid: 

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 Physician: Probable mucosal damage may contraindicate the use of gastric lavage, 

User Safety Recommendations: 

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

tobacco or using the toilet, Remove and wash contaminated clothing before reuse, 

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, 

Pnge 3 of3 

14
DATA PACKAGE BEAN SHEET 

Date: 25-Mar-2011 

Pagetof2 

* * '* Registration Information * * * 

Registration: 94i:)8_-UL - RITTER DICAMBA TECHNICAL 

Company: 9468 - RITTER CHEMICAL, lLC 

Risk Manager: RM 23 - Kalhryn Montague - (703) 305-1243 Room# PY1 5-7332 

Risk Manager Reviewer: James Stone JSTONE 

Calculated Due Date: 29-J.IJ~ Z. \ \ 

Type of Registration: Product Registralion - Section 3 Oc..- \) ) 

Senl Dale: 

Action Oesc: (~.NEW PRODUCT;ME-TOO PRODUCT FAST TRACK; 

Ingredients: 029801, Dicamba(98.9%) 

Expedite: 0 Yes • No 

DP Ingredient: 029801, Dicamba 

DPTitle: 

CSF Included: • Yes 0 No 

'* * '* Data Package Information '* * * 

Date Sen!: 25-Mar-2011 

Label Included: • Yes 0 No Parent DP #: 

Decision #: 446591 

DP #: (388021) 

PRIA 

Parent DP #: 

Submission #: 892170 

Edited Due Dale: 

Due Back: 

Assigned To Date In Date Out .~L 

Organization: RD I TRB Lasl Possible Science Due Da~~~ Team Name: CHEM Science Due Date: 

Reviewer Name: 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 * * * 

Review product chemistry data for new unregistered technical dicamba product 

15
DP#: (388021) 

48420504 

48420504 

48420504 

48420504 

48420504 

48420501 

48420503 

48420501 

48420504 

48420504 

48420501 

48420504 

48420503 

Page 2 

* * * Studies Sent for Review * * * Decision#: (44S591) 

Waiver Requests for 830.75201Particle size, fiber length, 

Certain Phys-Chem Properties. Project Number: RC/201007. and diameter distribulion 

Unpublished study prepared by R~ter Chemicals, LLC. 15 p. 

Tillman, A. (2011) RitJer Dicamba Technical Waiver Requests for 830.6319/Miscibility 

Certain Phys-Chem Properties. Project Number: RC1201007. 

Unpublished study prepared by Ritter Chemicals, LLC. 15 p. 

Tillman, A. (2011) Ritter Dicamba Technical Waiver Requests for 830.6315/Flammability 

Certain Phys-Chem Properties. Project Number: RC1201007. 

Unpublished study prepared by Ritter Chemicals, LLC. 15 p. 

Tillman, A. (2011) Ritter Dicamba Technical Waiver Requests for 

Certain Phys-Chem Properties. Project Number: RC1201007. 

Unpublished sludy prepared by Ritter Chemicals, LLC. 15 p. 

830.75501Partition coefficient 

(n-octanollwater), shake flask 

method 

Tillman, A. (2011) Ritler Dicamba Technical Waiver Requests for 830.7220180iling pointfboiling range 

Certain Phys-Chem Properties. Project Number: RC1201007. 

Unpublished study prepared by Ritter Chemicals, LLC. 15 p. 

Tillman, A. (2011) Product Identity and Composition, Description 

of the Materials Used, Description of the Production Process, 

Discussion of the Formation of Impurities, Certified Limits, and 

Enforcement Analytical Method for Ritter Dicamba Technical. 

Project Number: RC/20100S. Unpublished study prepared by 

Ritter Chemicals, LLC. 155 p. 

830.1S00/Description of materials 

used to produce the product 

Weller, P. (2011) Group B - Product Chemistry Analysis of 830.7200/Melting pointfmening 

Dicamba Technical. Project Number: 311100111001. Unpublished range 

study prepared by MRIGlobal. 37 p. 

Tillman, A. (2011) Product Identity and Composition, Description 

of the Materials Used, Description of the Production Process, 

Discussion of the Formation of Impurities, Certified Limits, and 

Enforcement Analytical Method for Ritter Dicamba Technical. 

Projecl Number: RC1201006. Unpublished study prepared by 

Ritter Chemicals, LLC. 155 p. 

Tillman, A. (2011) Ritter Dicamba Technical Waiver Requests for 

Certain Phys-Chem Properties. Project Number: RC1201007. 

Unpublished study prepared by Ritter Chemicals, LLC. 15 p. 

Tillman, A. (2011) Ritter Dicamba Technical Waiver Requests for 

Certain Phys-Chem Properties. Project Number: RC1201007. 

Unpublished study prepared by Ritter Chemicals. LLC. 15 p. 

Tillman, A. (2011) ProduclldenJity and Composition, Description 

of the Materials Used, Descriplion of the Production Process, 

Discussion of the Formation of Impurities, Certified Limits, and 

Enforcement Analytical Method for Ritter Dicamba Technical. 

Project Number: RC/201 OOS. Unpublished study prepared by 

Ritter Chemicals, LLC. 155 p. 

830.15501Product Identity and 

composition 

830.6313/Stability to normal and 

elevated temperatures, metals, and 

metal ions 

830.7100Niscosily 

830.1620lDescription of production 

process 

Tillman, A. (2011) Ritter Dicamba Technical Waiver Requests for 830.7370lDissociation constants in 

Certain Phys-Chem Properties. Project Number: RC/201007. water 

Unpubllshed study prepared by Ritler Chemicals, LLC. 15 p. 

Weller, P. (2011) Group B - Product Chemistry Analysis of 830.7000/pH 

Dicamba Technical. Project Number: 311100111001. Unpublished 

study prepared by MRIGlobal. 37 p. 

16
DP#: (388021) 

48420503 

48420503 

48420503 

48420504 

48420504 

48420504 

48420504 

48420503 

4842050t 

48420504 

48420503 

48420503 

48420501 

48420504 

48420504 

48420504 

48420504 

48420501 

48420504 

48420503 

Page 2 

* * * Studies Sent for Review··· Decision#: (44659t) 

; ~ 

Ii i 

for the Assay of Active Jngredient and Significant 

Impurities and Subsequent 5~Batch Analysis of Dicamba TGAI. 

Project Number: NC/2007/024. Unpublished study prepared by 

Nutrichem Laboratory Co" Ltd. 91 p. 

Weller, P. (2011) Group B - Product Chemistry Analysis of 830.6313/Stability to normal and 

Dicamba Technical. Project Number: 3 t 1100/1/001. Unpublished elevated temperatures, metals, and 

study prepared by MRIGlobaL 37 p. metal ions 

Weller, P. (2011) Group B - Product Chemistry Analysis of 830.7050/UVNisible absorption 

Dicamba Technical. Project Number: 311100/1/00 I. Unpublished 

study prepared by MRIGlobaL 37 p. 

Weller, P. (201 t) Group B - Product Chemistry Analysis of 830.6304/Ddor 

Dicamba Technical. Project Number: 31 t 1 00/1/001. Unpublished 

study prepared by MRIGlobaL 37 p. 

Tillman, A. (2011) Ritter Dicamba Technical Waiver Requests for 830.7300/Density/relative density 

Certain Phys-Chem Properties. Project Number: RCf201007. 

Unpublished study prepared by Ritter Chemicals, llC. 15 p. 

Tillman, A. (2011) Ritter Dicamba Technical Waiver Requests for 830.7950Napor pressure 

Certain Phys-Chem Properties. Project Number: RC/201007. 

Unpublished study prepared by Ritter Chemicals, lLC. 15 p. 

Tillman, A. (2011) Ritter Dicamba Technical Waiver Requests for 830.7860fWater solubility, generator 

Certain Phys-Chem Properties. Project Number: RC/201007. column method 

Unpublished study prepared by Ritter Chemicals, LLC. 15 p. 

Tillman, A. (20 tl) Ritter Dicamba Technical Waiver Requests for 830.7560/Partition coefficient 

Certain Phys-Chem Properties. Project Number: RC/201007. (n-octanol/water), generator column 

Unpublished study prepared by Ritter Chemicals, llC. t5 p. method 

Weller, P. (20 t t) Group B - Product Chemistry Analysis of 830.6303/Physical state 

Dicamba Technical. Project Number: 311100/1/001. Unpubi'shed 

study prepared by MRIGlobaL 37 p. 

Tillman, A. (2011) Product Identity and Composition, Description 

of the Materials Used. Description of the Production Process, 

Discussion of the Formation of Impurities, Certified Limits, and 

Enforcement Analytical Method for Ritter Dicamba Technical. 

Project Number: RC/201006. Unpublished study prepared by 

Ritter Chemicals, LLC. 155 p. 

830. t750/Certified limits 

Tillman, A. (2011) Ritter Dicamba Technical Waiver Requests for 830.6320/Corrosion characteristics 

Certain Phys-Chem Properties. Project Number: RenOt007. 

Unpublished study prepared by Ritter Chemicals, LLC. 15 p. 

Weller, P. (201 t) Group B - Product Chemistry Analysis of 830.6314/0xidizing or reducing 

Dicamba Technical. Project Number: 311 tOO/1/001. Unpublished action 

study prepared by MRIGlobaL 37 p. 

Weller, P. (2011) Group B - Product Chemistry Analysis of 830.7300/Density/relative density 

Dicamba Technical. Project Number: 311 tOO/l/001. Unpublished 

study prepared by MRIGJobaL 37 p. 

Tillman, A. (2011) Product Identity and Composition, Description 

of the Materials Used, Descn'ption of the Production Process, 

Discussion of the Formation of Jmpurities, Certified limits, and 

Enforcement Analytical Method for Ritter Dicamba Technical. 

Project Number: RC/201006. Unpublished study prepared by 

Ritter Chemicals, LlC. 155 p. 

830.1800/Enforcement analytical 

method 

Tillman, A. (2011) Ritter Dicamba Technical Waiver Requests for 830.6321fDielectric breakdown 

Certain Phys-Chem Properties. Project Number: RC/201 007. 

Unpublished study prepared by Ritter Chemicals, LLC. t5 p. 

voltage 

Tillman, A. (2011) Ritter Dicamba Technical Waiver Requests for 830.6316/Explodability 

Certain Phys-Chem Properties. Project Number: RC/20t007. 

Unpublished study prepared by Ritter Chemicals, LlC. 15 p. 

Tillman, A. (2011) Ritter Dicamba Technical Waiver Requests for 830.6317/Storage stability 

Certain Phys-Chem Properties. Project Number: RC/20to07. 

Unpublished study prepared by Ritter Chemicals, LLC. 15 p. 

Tillman, A. (20t t) Ritter Dicamba Technical Waiver Requests for 

Certain Phys-Chem Properties. Project Number: RCf20t007. 

Unpublished study prepared by Ritter Chemicals, llC. 15 p. 

Tillman, A. (2011) Product Identity and Composition, Description 

of the Materials Used, Description of the Production Process. 

Discussion of the Formation of Impurities, Certified limits, and 

Enforcement Analytical Method for Ritter Dicamba Technical. 

Project Number: RC/201006. Unpublished study prepared by 

Ritter Chemicals, lLC. 155 p. 

830.7570/Partltion coefficient 

(n-octanolfwater), estimation by 

liquid chromatography 

830.1670fDiscussion of formation of 

impurities 

Tillman, A. (2011) Ritter Dicamba Technical Waiver Requests for 830.7840fWater solubility: Column 

Certain Phys-Chem Properties. Project Number: RC/201 007. elution method, shake flask method 

Unpublished study prepared by Ritter Chemicals, llC. t5 p. 

Weller, P. (2011) Group B - Product Chemistry Analysis of 830.6302!Color 

Dicamba Technical. Project Number: 311100/1/001. Unpublished 

study prepared by MRJGlobaL 37 p. 

17
DATA PACKAGE BEAN SHEET 

Date: 25-Mar-2011 

Page! of 1 

* * * Registration Information * * * 

Registration: 9468-UL - RITTER DICAMBA TECHNICAL 

Company: 9468 - RITTER CHEMICAL. LLC 

Risk Manager: RM 23 - Kathryn Montague - (703) 305-1243 Room# PY1 5-7332 

Risk Manager Reviewer: James Stone JSTONE 

Sen! Dale: Calculated Due Date: ~M1:e-rr 

Type of Registration: Product Registration - Section 3 br:-'\.. 1.., ) \ \ 

Action Desc: (~) NEW PRODUCT;ME-TOO PRODUCT FAST TRACK; 

Ingredients: 029801, Oicamba(98.9%) 

Expedite: 0 Yes. No 

DP Ingredient: 029801, Dicamba 

DP Title: 

CSF Included: • Yes 0 No 

Assigned To 

* * * Data Package Information * * * 

Dale Sent: 25-Mar-2011 

Label Included: • Yes 0 No Parent DP#: 

Date In Date Out 

Decision #: 446591 

DP #: (388022) 

PRIA ' 

~Vc jl 'z 

Parent DP #: '""Ii to'" , r) ~( ). 

Submission #: 892170 

Edited Due Dale: 

Due Sack: 

Organization: RD f TRB 

>~G/ I( 

Last Possible Science Due Date: ~~ 

Team Name: TOX 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 * * * 

For Similarity Clinic 

Under the Cite-All Method is the acute toxicity substnatially similar to the cited me too product EPA Reg. No. 42750-577 

/ 

18
PYXIS REGULATORY CONSULTING, INC. 

4110 136th St. NW 

Gig Harbor, WA 98332 

OVERNIGHT DELIVERY 

Kathryn Montague (PM 23) 

Document Processing Desk (REGFEE) 

Office of Pesticide Programs (7504P) 

U.S. Environmental Protection Agency 

Room S-4900, One Potomac Yard 

2777 S. Crystal Drive 

Arlington, VA 22202 

RE: Ritter Chemical, LLC 

March 11,2011 

Ritter Dicamba Technical (EPA File Symbol 9468- ) 

Application for New Pesticide Registration 

PRIA category R3 I 0 (46: New manufacturing use product) 

Dear Ms. Montague, 

484206-00 

Phone: 253-853-7369 

Fax: 253-853-5516 

www.PyxisRC.com 

On behalf of Ritter Chemical, LLC, we are submitting an application for registration of Ritter Dicamba 

Technical. In support of this application, we submit the following documents: 

I. Application for a New Pesticide Registration (EPA Ponn 8570-1) 

2. Confidential Statement of Formula (EPA Fonn 8570-4) 

3. Three (3) Copies of the Proposed Labeling 

4. A CD containing an electronic version of the proposed labeling 

5. Certification with Respect to Label Integrity 

6. Certification with Respect to Citation of Data (EPA Fonn 8570-34) 

7. Agency Internal Use Copy of the Data Matrix 

8. Public File Copy of the Data Matrix 

9. Copy ofPRlA payment 

10. Letter of Authorization 

11. Product Specific Data (3 copies of each report): 

Volume I 830.1550,830.1600, Tillman, A. M. Product Identity and Composition, Description of 

48420601 830.1620,830.1650, th, Materials Used, Description of the Production Process, 

1830.1670,830.1750, Description of the Formulation Process, Discussion of the Formation 

830.1800 of Impurities, Certified Limits, and Enforcement Analytical Method 

for Ritter Dicamba Technical. Contains Confidential Business 

InformatiOIl. 

48420602 Volume 2 830.1700, 830.1800 Li, H. Preliminary Analysis and Enforcement Analytical Method of 

Dicamba TGAI. Contains Confidential Business lIiformation. 

19
Volume 3 830.6302, 830.6303, 

830.6304,830.6313, 

48420503 

830.6314,830.7000, 

830.7050,830.7200, 

830.7300 

48420504 Volume 4 830.6313,830.6315, 

830.6316,830.6317, 

830.6319,830.6320, 

830.6321,830.7100, 

830.7220,830.7300, 

830.7370,830.7520, 

830.7550-7570, 

830.7840-7860, 

830.7950 

K. Montague 

March 11,2011 

Page 2 of2 

Weller, P. J. Group B Product Chemistry Analysis of Dicamba 

Technical. 

Tillman, A. M. Ritter Dicamba Technical Waiver Requests for 

Certain Phys-Chem Properties. 

We would like to note that Ritter Chemical, LLC is using the cite-all method of support. As per EPA's 

interpretations of 40 CFR Parts l52.86(b)(2)(i) and 152.93(b)(2)(i), Ritter Chemical, LLC submitted 

notices of intent to apply and offers to pay to all companies on the September 30, 2010 Data Submitter's 

List. This action falls under PRlA category R310 (46: New manufacturing use product) because it is an 

application for registration for a manufacturing use product identical to a currently registered product. 

The PRIA fee for this action is $4,807 and has been paid. The decision timeline is 6 months. 

We trust you will find this application complete. However, please feel free to contact me «253) 853· 

7369, Ann@PyxisRC.com) ifyOl1 have any questions or need any additional information. 

Sincerely, 

Ann M. Tillman 

Enclosures 

20
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY / (i !L 

WASHINGTON, D.C. 20460 1~ 

March 28, 2011 

OPP Decision Number: D-44659l 

EPA File Symbol or Registration Number: 9468-UL 

Product Name: RITTER DICAMBA TECHNICAL 

EPA Receipt Date: l6-Mar-2011 

EPA Company Number: 9468 

Company Name: RITTER CHEMICAL, LLC 

Ann Tilhuan 

PYXIS REGULATORY CONSULTING, INC. 

RITTER CHEMICAL, LLC 

4110 136TH STREET, N.W, 

GIG HARBOR, WA 98332-

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 determined that this Action is subject to a Pesticide Registration Service Fee as defined in 

the Pesticide Registration Improvement Act. 

The Action previously identified as R300 has been reclassified identified as Action Code: R310 

NEW PRODUCT;NON-F AST TRACK (INCLUDES REVIEWS OF PRODUCT 

CHEMISTRY;ACUTE TOXICITY;PUBLIC HEALTH PEST EFFICACy); 

No additional payment is due at this time. 

If you have any questions, please contact the Pesticide Registration Service Fee 

Ombudsman at (703) 308-9362. 

! 

I 

21
JJ, 

Fw: Ritter Dicamba Technical 9468-UL PRIA Category 

Stephen Schaible to: John Jamula, Teresa Downs 

Please recade this action as an R310. Thanks! Steve 

Stephen A. Schaible 

U.S. Environmental Protection Agency 

Office of Pesticide Programs 

Registration Division (7505P) 

1200 Pennsylvania Avenue, NW 

Washington, DC 20460 

ph: (703)308~9362 

fax: (703)305·6920 

~"-. FOIwarded by Stephen Schaible/DC/USEPAfUS on 03/25/2011 04:39 PM ~---~ 

From: 

To; 

Cc: 

Date: 

Subject: 

Ann Tillman <Ann@PyxisRC.com> 

Stephen Schaible/DC/USEPAlUS@EPA 

Teresa Downs/DC/USEPAlUS@EPA 

03/24/2011 10:38 AM 

RE: Ritter Dicamba Technical 9468~UL PR1A Category 

Thanks, Steve. This application is not a 100% repack. 

Ann 

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

From: Schaible.Stephen@epamail.epa.gov 

mailto:Schaible.Stephen@epamail.epa.gov] 

Sent: Thursday, March 24, 2011 10:32 AM 

To: Ann Tillman 

Cc: Downs.Teresa@epamail.epa.gov 

Subject: Re: Ritter Dicamba Technical 946B-UL PRIA Category 

Hi Ann, 

03/25/2011 04:40 PM 

At face value, I would absolutely agree. The only situation where a technical 

would qualify as a R300 would be if it is a 100% repack. It sounds like this 

was a coding error on our end, and I'll follow up with· Teresa and JJ to make 

sure this is the case. 

Thanks for bringing 

been caught once it 

process this way. 

Regards, Steve 

Stephen A. Schaible 

this to my attention! 

got to the PM, but you 

U.S. Environmental Protection Agency 

Office of Pesticide Programs 

Registration Division (7505P) 

1200 Pennsylvania Avenue, NW 

washington, DC 20460 

ph: {703]30B-9362 

fax: [703}305-6920 

In all likelihood this would have 

are getting clarity earlier in the 

22
From: 

To: 

Date: 

Subject: 

Hi, Steve, 

Ann Tillman <Ann@PyxisRC.com> 

Stephen Schaible/DC/USEPA/US@EPA 

03/24/2011 06:53 AM 

Ritter Dicamba Technical 9468-UL PRIA Category 

I received this letter (attached) in the mail but I really don't believe that 

the PRIA category should be R300. Every application for 

registration of a me-too technical has typically been R310. Is there 

something different about this application that makes it an R300? 

Ann 

Ann M. Tillman, Ph.D. 

Pyxis Regulatory Consulting, Inc. 

4110 136th St. NW 

Gig Harbor, WA 98332 

Office (253) 853-7369 

Fax (253) 853-5516 

Email Ann@PyxisRC.com 

[attachment "20110317 9468-UL PRIA reclassification. pdf" deleted by Stephen 

Schaible/DC/USEPA/US] 

23
, 

.. ... .2-28-" 

United Stot •• Registration opp Idontifi,r Number 

&EPA Environmental Protection Agency f-'- Amendment 

WOIhinlllon, DC 20450 f- Other 

for . II 

9468:t2i" Number , ~.EP" Product Melnegor 3. Propo.od Ct ... ifie.tio" 

0 NOMI o R •• trictocl 

4. ~omp.nYIP.roduct IN::nOI PM' 

, " , , 23 

5. Nlfmo end Addr ... ,f Applicant Ilnclude ZIP Code' 6. Expedited Reveiw. In accordance with FIFRA Section 3(c1(31 

Riller Chemicals, LLC (bW), mV product Is similar or Identical in composition and labeling 

clo Pyxis Regulatory Consulting, Inc. to· 

4110 136thSI. NW EPA Reg, No, 42750-57 

Gig Harbor, WA 98332 

.. [~] Ch.ck H thi$ is • new address Product Name Albaugh Technical Dicamba Acid 

, . II 

g Amondment· Expillin below. U Fine! printod lob,I' In repeon .. to 

Agency toner deted 

Relubml •• ion in rOlpon.o to Agoncy letter dotod 0 -M. Too· Application. 

:= Notlficotlon - Explain balow. D Othar· EXplain balow. 

Explanation: Usa eddltlonel pagelsllt nacallery. {For .actlon I and Sectlon II.} 

This application falls under Category R310 (46: New manufacturing use product) because ~ is an application for registration for 

a new technical product identical in composition to a currently registered product. The fee which is due is $4,807.00 and has 

been paid. The decision tTiTie'ifne is 6 months. 

t71 

'Th"~w"''' .-;;;;-

P"kaging u~ Peckeging , Packaging Z. Type of Container 

tZj ~. ~ V .. gM". Vo. 1'7 N, tz Plntic N, 

1 ~!;: ,;" C~tIon must I~;,:'" No. per , 'v,,' N~.:.per I 

wgt. conteiner w,' eontGiner , e(fbmittfKI , 13. ,,' N .. I 14,5;"", 15l j_;: ,'.!,~ob" [,t' Lebel I I 800 k, ~.~ ,-,~ 

6. Menner in Which Label is Affixed to Product o Othar 

J~ 

1 - IV 

", c,,,,,, p,,", Uob. 

I Pyxis Regulatory Consulting, Inc. 

I nfl, Telephone No. IlrKllude Area Codel 

Agent 

Certification 

I certify that the etetemants I heve made on this form end ell attochmllnts therato are true, eccurets end compl"e . 

• ...j t!;:knowledge thet any knowllnglly fal.e or mi.leading etetemant may ba punisheble by fina or impMOnment er 

both ul1der eppliceblelew. 

r-z.-Signeture (J. 

I". Typ...J N ........ 

Ann M. TIllman 

EPA ''''''-85'O·t ,""" 3,941 

" 

, 

Jv/I~ 

, 

3. TIlle 

Agent 

S.Dar .. 3 /1/ J I( 

White - EPA file Copy 

6. Oate Applioation 

Aecol'.lId 

(SUll'TitUdl . 

i Yer;ow·~Copy 

24
FonnA ~dO MB N , 2070-0060 

'ft"' UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 

~ 401 M Street, S.W. 

WASHINGTON, D.C. 20460 

Paperwork Reductlon Act Notlco: The public reporting burden for this collection of infonnatlon Is es~mated to average t.25 hours per response lor registrntion 

and 0.25 hours per response for rerellislration and special review activities. Inctudlng time lor reading the instructions and completing the necessary Ionns. Send 

comments regarding burden estimate Of any other aspect of this collection of Information, Including suggestions for redudng the burden to: Direclor, OPPE 

Information Management Division (2t37), U,S. Environmental Protection Agency, 40t M Slreet, S.w., Washington, DC 20460. 

Do not send the completed form to this address. 

Certification with Respect to Citation of Data 

ApplicanfslRenislmnfs Name, Address, and Telephone Number EPA Renislraflon NumberlFileSymbol 

Rltter Chemicals, LLC clo Pyxis Regulatory 4ttO t36th SI. NW Gig Harbor, WA 253- 853-7369 9468-

t>..dive Inaredientfs) and/or representatNetest comooundfs) Date 3/11 Iii oicamba 

General Use Pattem(s) (list aU those claimed for this proo'ucl uslna-40 CFR Part t58) Producl Name 

Terrestrial food/feed, Terres\lial Non-food, Residential Ouldoor Ritter Dicamba Technical 

NOTE: If your produclls a 100% repackaging of another purchased EPA-registered producllabeled for all the same uses on your label, yOU do not need to 

subm~ this fonn. You must submit the Fonnulator's Exemption Statement (EPA Fonn 6570-27). 

0 t am responding to a Data-Call-In Notice, and have included wHh this fonn a list of companies senl offers of compensation (lhe Data Matrix form should 

be used forthls purpose). 

SECTION I: METHOOOF DATA SUPPORT (Check one method only) 

0 I am using the die-ali method of support, and have included with this tonn [2] I am using the selective method of support (or dte-all option 

a tist of companies sent offers ot compensation (the Data Matrix fonn under the selective method), aJld have inctuded with this form a 

Should be used forthis purpose). completed list of data requirements (the Dala Matrix fonn must be 

used). 

SECTION H: GENERAL OFFER TO PAY 

IRcqo!red If USing the ctte·all method or when using the cite-all option under the selective method to satisfy one or more data requlrementsl 

[2] I hereby offar and agree to pay compensation. to other persons, w~h regard to the approvat of this application, to the extent required by FIFRA. 

SECTION ttl: CERTIFtCATlON 

I certify that this application for registration, this fonn for reregistration, or this Data·Call-ln response is supported by atl data submttted or died in the 

apptication for registration, the fonn for reregistration, or the Oata·Call·ln response. In addition, Uthe cile-all option or cite-all option under Ihe oolectlve method is 

indicated In section I, this application Is supported by 011 data in the Aijency's flies that (1) concem the properties or effm;ts of this product or an Identical or 

substantially simi!ar product, or one or more of the ingredients in this producl; and (2) is a type of data that would be required to be submitted under the data 

requirements In elfecl on the date of approval of this appllcaUon if the application sought the initial registration of a producl of IdenUcal or similar composition and 

uses. 

I certlfy that for each exclusive use study cited In support of this reglstraton or rerejjisiTlltion, that I am the Original data submtuer or that I have obtained 

the written permissfon oflhe OIiginal data submitter to cite that study. 

I certify that for each study ctted In support of this registration orreregls/ration th3tls not an exclusive use study, either: (a) t am the original data 

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

comPensation have expired for the study; (d) the study Is In the public literature; or (e) I have notified in writing the company that subnitted the study and have 

offered (I) to pay compensation to the extent required by sections 3(c)(t)(F) andfor 3(0)(2)(9) of FIFRA; and (ii) to commence negotiations to detennine the 

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

I certify that In all Instances where an offer of compensation Is required, copies of all offers to pay compens3tion and evidence of their delivery In 

accordance with sections 3(c)(1)(F) andfor 3(c)(2)(B) ofFIFRA are available and will be submitted to the Agency upon request. Should I faltto produce such 

evidence to the Agency upon request, I understand that the Agency may in~iato action to deny, cancet or suspend Ihe registration of my producl in conformity with 

FtFRA. 

t certify that the stlternonts t have made on this form and alt attachments to It are true, OIccurato, and comprote, t acknowtedge thOit OIny 

knowlngty ht" or mlstlladtng statemant may bs pUnlshOlbto by fino or tmprlsonmont or both undor applicable taw, 

,-::-,--

'~ilnature 

r:L-Jv,~ "',. Typed or Prinled Name ard Title 

3/11 1'1 Ann M. Tillman, Agenl .. EPA Fonn 8570·34 (9·97) ElectroniC and Paper versions available. Submit only Paper version. 

25
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 information is estimated to average 0.25 hours per response for registration 

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

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

Director, OPPE Information Management Division (2137), U.S. Environmental Protection Agency, 401 M Street, S.W., Washington, DC 20460. Do not send the 

form to this address. 

DATA MATRIX 

Date March 7, 2011 EPA Reg. No.lFile Symbol 9468- I Paoe I of7 

Applicant's/Registrant's Name & Address Product 

Ritter Chemical, LLC Ritter Dicamba Technical 

P.O.80x430974 

Houston, TX 77243 

lnqredient Dicamba (CAS No. 19 t8-00-9) 

Guideline Reference Number I Guideline Study Name MRID Number Submitter Status Note 

Product Specific Data Requirements 

830.1550 Product Identity and Composition Volume 1 Ritter Chemical, LLC OWN 

830.1600 Description of Materials Used to Produce the Volume 1 Ritter Chemical, LLC OWN 

Product 

830.1620 Description of Production Process Volume 1 Ritter Chemical LLC OWN 

830.1650 Description of Formulation Process Not required1 

830.1670 Discussion of Formation of Impurities Volume 1 Ritter Chemical, LLC OWN 

830.1700 Preliminary Analvsis Volume 2 Ritter Chemical, LLC OWN 

830.1750 Certified Limits Volume 1 Ritter Chemical, LLC OWN . 

830.1800 Enforcement Analytical Method Volume 1 Ritter Chemical, LLC OWN 

----"- Volume 2 Ritter Chemical, LLC OWN 

830.6302 Color --;-- Volume 3 Ritter Chemical, LLC OWN 

830.6303 Physical State Volume 3 Ritter Chemical, LLC OWN 

830.6304 Odor Volume 3 Ritter Chemical, LLC OWN 

Signature Name and Title Oate 

~)I<~ Ann M. Tillman, Consultant March 7, 2011 

EPA Fonn 8570-35 (9-97) Electronic and Paper versions available. Submit only Paper version. Agency Internal Use Copy 

26
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 information is estimated to average 0.25 hours per response for registration 

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

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

Director, OPPE Information Management Division (2137), U,S. Environmental Protection Agency, 401 M Street, S.W., Washington, DC 20460. Do not send the 

form to this address. 

DATA MATRIX 

Date March 7, 2011 EPA Reg. No.lFile Symbol 9468- I Page 2-of 7 

Applicant's/Registrant's Name & Address Product 

Ritter Chemical, LLC Ritter Dicamba Technical 

P.O. Sox 430974 

Houston, TX 77243 

In!."lredient Dicamba (CAS No. 1918-00-9) 

Guideline Reference Number Guideline Study Name MR1D Number Submitter Status Note 

830.6313 Stability to Normal and Elevated Temperatures, Volume 3 Ritter Chemical, LLC OWN Data 

Metals, and Metal Ions Volume 4 Ritter Chemical, LLC OWN Waive~ 

830.6314 Oxidation/Reduction: Chemical Incompatibility Volume 3 Ritter Chemical, LLC OWN 

830.6315 Flammability Volume 4 Ritter Chemical, LLC OWN Waiver3 

830.6316 Explodability Volume 4 Ritter Chemical, LLC OWN Waiver4 

830.6317 Storage Stability Volume 4 Ritter Chemical, LLC OWN PRN 92_55 

830.6319 Miscibility Volume 4 Ritter Chemical, LLC OWN Waiver6 

830.6320 Corrosion Characteristics Volume 4 Ritter Chemical, LLC OWN PRN 92_55 

830.6321 Dielectric Breakdown Voltaqe Volume 4 Ritter Chemical, LLC OWN Not required7 

830.7000 pH Volume 3 Ritter Chemical, LLC OWN 

830.7050 UVNisible Absorption Volume 3 Ritter Chemical, LLC OWN 

830.7100 Viscosity Volume 4 Ritter Chemical, LLC OWN Not required7 

830.7200 Melting PoinUMelting Range Volume 3 Ritter Chemical, LLC OWN 

830.7220 Boiling PoinUBoilina Ranae Volume 4 Ritter Chemical, LLC OWN Not reauired8 

Signalure Name and TiUe Date 

4L1,~ Ann M. Tillman, Consultant March 7, 2011 

EPA Fonn 8570·35 (9-97) Electronic and Paper versions available. Submit only Paper version. Agency Internal Use Copy 

27
Form Approved OMB 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 information is estimated to average 0.25 hours per response for registration 

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

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

Director, OPPE Information Management Division (2137), U.S. Environmental Protection Agency, 401 M Street, S.W., Washington, DC 20460. Do not send the 

form to this address. 

DATA MATRIX 

Date March 7, 2011 EPA Reg. No.lFile Symbol 9468- I Page:; of 7 

Applicant'SlRegistrant's Name & Address Product 

Ritter Chemical, LLC Ritter Dicamba Technical 

P.O. Box 430974 

Houston, TX 77243 

ingredient Dicamba (CAS No. 1918-00-9) 

Guideline Reference Number Guideline Studv Name MRID Number Submitter Slalus Nole 

830.7300 Density/Relative Density/Bulk Density Volume 3 Ritter Chemical. LLC OWN See endnote9 

830.7370 Dissociation Constants in Water Volume 4 Ritter Chemical, LLC PL 

830.7520 Particle Size, Fiber Length, and Diameter Volume 4 Ritter Chemical, LLC OWN Waiver10 

Distribution 

830.7550 Partition Coefficient (n-octanol/water), Shake Volume 4 Ritter Chemical, LLC PL 

Flask Method 

830.7560 Partition Coefficient (n-octanol/water), See 830.7550 

Generator Column Method 

830.7570 Partition Coefficient (n-octanol/water), See 830.7550 

Estimation by liquid Chromatography 

830.7840 Water Solubility: Column Elution Method; Volume 4 Ritter Chemical, LLC PL 

Shake Flask Method 

830.7860 Water Solubility, Generator Column Method See 830.7840 

830.7950 Vapor Pressure Volume 4 Ritter Chemical, LLC PL 

Signalure Name and TiUe Date 

t1..h,~ Ann M. Tillman, Consultant March 7, 2011 

EPA Form 8570·35 (9-97) Eleclronic and Paper versions available. Submit only Paper version. Agency Internal Use Copy 

28
Form Approved OM8 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 information is estimated to average 0.25 hours per response for registration 

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

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

Director, OPPE Information Management Division (2137), U.S. Environmental Protection Agency, 401 M Street, S.W., Washington, DC 20460. Do not send the 

form to this address. 

DATA MATRIX 

Date March 7, 2011 EPA Reg. No.lFile Symbol 9468- I Pagelj of7 

Applicant's/Registrant's Name & Address Product 

Ritter Chemical, LLC Ritter Dicamba Technical 

P.O. Box 430974 

Houston, TX 77243 

Inqredient Dicamba (CAS No. 1918-00-9) 

Guideline Reference Number Guideline Study Name MRID Number Submitter Status Note 

870.1100 Acute Oral Toxicity: Rat Cite-All PAY 

870.1200 Acute Dermal Toxicitv: Rat Cite-All PAY 

870.1300 Acute Inhalation Toxicitv: Rat Cite-All PAY 

870.2400 Primary Eve Irritation: Rabbit Cite-All PAY 

870.2500 Primary Dermal Irritation Cite-All PAY 

870.2600 Dermal Sensitization Cite-All PAY 

Dicamba Product Specific and Generic Data Requirements 

Ritter Chemical, LLC is using the cite-all option to satisfy product specific and generic data 

reqUirements will make offers-to-pay to the following companies on the dicamba data submitters 

list of September 30,2010. 

Cite-All Svnqenta Crop Protection, Inc. PAY 

Cite-All Nufarm Americas Inc. PAY 

Cite-All BASF Corp. PAY 

Si9nature Name and Title Oate 

a..)z,~ Ann M. Tillman, Consultant March 7, 2011 

EPA Fonn 8570·35 (9-97) Electronic and Paper versions available. Submit only Paper version. Agency Internal Use Copy 

29
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 information is estimated to average 0.25 hours per response for registration 

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

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

Director, OPPE Information Management Division (2137), U.S. Environmental Protection Agency, 401 M Street, S.W., Washington, DC 20460. Do not send the 

form to this address. 

DATA MATRIX 

Date March 7, 2011 EPA Rea. No.lFile Svmbol 9468- I PaqeS" of 7 

Applicant's/Registrant's Name & Address Product 

Ritter Chemical, LLC Ritter Dicamba Technical 

P.O. Box 430974 

Houston, TX 77243 

Inaredient DicambalcAS No. 1918-00-9) 

Guideline Reference Number Guideline Studv Name MRID Number Submitter Status Note 

Cite-All E. I. DuPont de Nemours and PAY 

Co., Inc. 

Cite-All Baver Environmental Science PAY 

Cite-All Monsanto Co. PAY 

Cite-All The Scotts Co. PAY 

Cite-All PSI/Gordon Corp. PAY 

Cite-All BASF Coro. PAY 

Cite-All The Andersons Lawn Fertilizer PAY 

Division 

Cite-All Chemisco PAY 

Cite-All Loveland Products, Inc. PAY 

Cite-All AlbauQh, Inc. PAY 

Cite-All Dow Aqrosciences LLC PAY 

Cite-All Spray Drift Task Force PAY 

Cite-All W. Neudorff Gmbh Ka PAY 

Signature Name and Title Date 

a...).,~ Ann M. Tillman, Consultant March 7, 2011 

EPA Form 8570-35 (9-97) Electronic and Paper versions available. Submit only Paper version. Agency Internal Use Copy 

30
Form Approved OMB 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 information is estimated to average 0.25 hours per response for registration 

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

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

Director, OPPE Information Management Division (2137), U.S. Environmental Protection Agency, 401 M Street, S.W., Washington, DC 20460. Do not send the 

form to this address. 

DATA MATRIX 

Date March 7, 2011 EPA Req. No.lFile Svmbol 9468- I PaaeGaf7 

Applicant's/Registrant's Name & Address Product 

Ritter Chemical, LLC Ritter Dicamba Technical 

P.O. Box 430974 

Houston, TX 77243 

Innredient Dicamba (CAS No. 1918-00-9' 

Guideline Reference Number Guideline Studv Name MRID Number Submitter Status Note 

Cite-All Repar Corp. PAY 

Cite-All Petro-Canada Lubricants Inc. PAY 

Cite-All Gharda USA, Inc. PAY 

Cite-All Nufarm, Inc. PAY 

Cite-All Outdoor Residential Exposure PAY 

Task Force 

Cite-All Agricultural Reentry Task PAY 

Force 

Cite-All Baver Advanced PAY 

Cite-All FIFRA Endangered Species PAY 

Task Force LLC 

Cite-All Residential Exposure Joint PAY 

Venture 

Cite-All Agricultural Handlers PAY 

Exposure Task Force 

SignalUre Name and Title Pate 

a..1~ Ann M. Tillman, Consultant March 7, 2011 

EPA FOm1 8570·35 (9·97) Eleclronic and Paper versions available. Submit only Paper version. Agency Internal Use Copy 

31
Form Approved OMB 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 information is estimated to average 0.25 hours per response for registration 

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

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

Director, OPPE Information Management Division (2137), U.S. Environmental Protection Agency, 401 M Street. S.W., Washington, DC 20460. Do not send the 

form to this address. 

DATA MATRIX 

Date March 7, 2011 EPA Rea. NaJFile Svmbol 9468· I Paae/of7 

Applicant's/Registrant's Name & Address Product 

Ritter Chemical, LLC Ritter Dicamba Technical 

P.O. Box 430974 

Houston, TX 77243 

Inoredient Dicamba(CAS No. 1918-00-; 

Guideline Reference Number Guideline Studv Name MRID Number Submitter Status Note 

Cite-All Ubertas Now, Inc. PAY 

Cite-All J. Oliver Products, LLC PAY 

Cite-All Tacoma Aq, LLC PAY 

Cite-All Gharda Generics, Inc. PAY 

Signature Name and Title Dale 

a.-)0~ Ann M. Tillman, Consultant March 7, 2011 

EPA Form 8571)-35 (9-97) Electronic and Paper versions available. Submit only Paper version. Agency Internal Use Copy 

32
Endnotes for Data Matrix for Ritter Dicamba MUP 

1 830.1650 _ These data are not required for the registration of a technical product. See 830.1620 for 

production process information. 

2830.6313 _ Ritter Chemica!, LLC requests a waiver from the stability to metal and metal ion portion of 

this data requirement. Ritter Chemical, LLC does not intend to package Oicamba Technical in metal 

containers, nor is Dicamba Technical expected to come into contact with metals or metal ions during its 

storage or use. Therefore, a waiver from the requirement of these data is requested. Dicamba 

Technical was found to be stable at normal and elevated temperatures (these data are reported 

separately and is part of this submission). 

3830.6315 _ Ritter Chemical, LLC requests a waiver from the requirement of this data requirement since 

Dicamba Technical is a solid and does not contain any ingredients that are flammable. Please refer to 

the Confidential Statement of Formula for Dicamba Technical. 

4830.6316 _ Ritter Chemical, LLC requests a waiver from this data requirement. Dicamba does not have 

the chemical bonds or functional groups associated with explosive chemicals. 

5830.6317, 830.6320 _ Per PR Notice 92-5, storage stability and corrosion characteristics data are not 

required to be submitted unless specifically requested by the Agency. Ritter Chemical, LLC has 

initiated these studies and will submit the final report when available. 

6830.6319 _ This data requirement is required when the MUP is an emulsifiable liquid and to be diluted 

with petroleum solvents. Ritter Dicamba Technical is not an end-use product. Therefore these data 

are not required for Ritter Dicamba Technical. 

7830.6321,830.7100 - Dielectric breakdown data are required if the product is an end-use product. This 

data requirement is not applicable Ritter Dicamba Technical. Viscosity is required for liquid products 

and is not applicable to the solid Ritter Dicamba Technical. 

8830.7220 _ This data requirement is not applicable to Ritter Dicamba Technical because it is a solid. 

Refer to guideline 830.7200 for melting point data. 

9 830.7300 _ Ritter Chemical, LLC conducted bulk density with Ritter Dicamba Technical. The bulk 

density is 0.703 g/mL. The public literature density for dicamba acid is reported to be 1.488 (Ref. 

(Reference: Tomlin. "The Pesticide Manual''. 13th Edition, p. 279. BCPC Publications, Hampshire, 

2003). However, EPA documents (docket EPA-HQ-OPP-2005-0479-005) indicate that the relative 

density is 1.57 which was obtained from a technical material that was only 87% pure. EPA cited data 

from the 6/30/89 Reregistration Standard. The bulk density of the Ritter Dicamba Technical me-too 

technical dicamba acid must be similar to the value obtained for Ritter Dicamba Technical: Tacoma 

Ag, LLC's Dicamba Acid Technical, EPA Reg. No. 83520-8, is also a me-too of the same cited product 

(based on information in the Registration Jacket for 83520-8) and the bulk density of the Tacoma Ag, 

LLC's technical product is 0.608 g/mL (see MSDS in Attachment 1). The bulk density values for Ritter 

Dicamba Technical and Tacoma Ag LLC's technical are similar. Therefore, the bulk density for Ritter 

Dicamba Technical should not be compared to data in the public literature since that data is for relative 

density and from an 87% pure technical material. 

10 830.7520 _ Ritter Chemical. LLC is seeking a waiver for this data requirement. Ritter Dicamba 

Technical is not a fibrous material nor is it water insoluble. 

Page 1 of 1 

33
c§Q9and 301 

100% identical (repack): YES or NO circle one 

{If yes, it's a 100% repack - then pr t chemistry, acute toxicity and efficacy data 

are not required} 

Data on Group and A and 8 must be submitted - Group A and 8 can not be cited. 

Data 

Guideline Group A: Product Chemistry Data 

submitted 

No. Study Title Yes No 

830.1550 Product Identitv & Comoosition X 

Description of materials used to produce the 

830.1600 oroduct X 

830.1650 Description of formulation process X NR 

830.1670 Discussion on the formation of impurities >< 

830.1700 Preliminarv analYsis X 

830.1750 Certified limits (158.345) ~ 

830.1800 Enforcement anaivtical method ><.. 

Data 

Guideline Group B: Product Chemistry Data submitted 

No. Studvntle Yes No 

830.6302 Color X 

830.6303 Physical State x: 

830.6304 Odor X 

Oxidation/Reduction (Chemical )<. 830.6314 incomootibiljty) 

830.6315 Flammabilitv >< 

830.6316 Exolodabilitv )(. 

830.6317 Storage stability X 

830.6319 Miscibilitv X 

830.6320 Corrosion Characteristics x: 

830.6321 Dielectric Breakdown voltaae X 

830.7000 OH x.. 

830.7100 Viscosity X 

830.7300 Density X1 

34
c[3§land 301 

New products must provide a bridging rationale document. The bridging document 

directs OPP to use a currently registered set of 6 acute toxicity data and label: instead 

of submitting product specific data. 

Guideline Acute toxicity (6 pack) Cited 

No. StudvTitle Yes No 

870.1100 Acute Oral (LD50) X 

870.1200 Acute Dermal (LD5Q) X 

870.1300 Acute Inhalation (LC5Q) >Z 

870.2400 Acute Eve Irritation X 

870.2500 Acute Dermal Irritation X 

870.2600 Dermal Sensitization A 

Efficacy - which guideline depends on the proposed label use and they must cite the 

data to be used for the bridging rationale. 

Guideline Cited 

No. Efficacy Study mles Yes No Comments 

810.3100 Soil Treatments for Imported Fire Ants NA 

Livestock, Poultry, Fur and Wool-Bearing NA 810.3200 Animal Treatments 

Treatments to Control Pests of Humans 

and NA 

810.3300 Pets 

MosqUito, Black Fly, and Biting Midge fVA 810.3400 I (Sand Flv) Treatments 

810.3500 Premises Treatments IVA 

810.3600 Structural Treatments fJA 

Methods for Efficacy Testing of Termite 10A 810.3800 Baits 

2 

35
21-Day Screen Completed by 

Contractor 

21-Day Expires on _--Ly----->G"-----.:.-Cf(_ 

Jacket # 9 c; {;, $- - U L 

MRID# Lf }L/ Z 0 $' 

Content Screen: Recommend to ~ail 

86-5 Review: ~aillNA 

Overall Status: Recommend to@'an 

Transfer This Jacket to: 

PM 2 ~ 

36
PRIA 2 - 21 Day Content Screen Review Worksheet 

(EPA/OPP Use Only) 

21 Day Screen Start Date: 

3 -/ t;- _ f ( 3/23/09 

Experts In-Processing Signature: B t ~ ~ Date'? - /!? -/ / Fee Paid: Yes ~ 

Division management contacted on issues No ___ Yes ____ Date ______ _ 

EPA Reg. Number: 9 tj{: If - U L EPA Receipt Date: 3 -/ tP - I r 

1 

2 

3 

4 

5 

6 

Items for Review 

Application Form (EPA Form 8570-1)(link to form) signed & complete 

including package type 

Yes No N/A* 

Confidential Statement of Formula all boxes completed, form signed, and .?Z 

dated to 

a) All inerts (link to http://www.epa.gov/opprdOOIlinerts/).no 

including fragrances, approved for the proposed uses (see 

Footnote 

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

form) completed and signed (N/A if 100% repack) 

Certificate and data matrix consistent 

If applicant is relying on data that are compensable, is the offer 

to pay statement included. (see Footnote B) 

yes 

completed and ",,"'"" (NI A if source is unregistered or applicant owns the 

no 

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% 

Selective Method 

b) Cite~All (Fee category experts use) 

c) Applicant owns all data (Fee category experts use) 

5 Copies of Label (link to http://www,epa.gov/oppfeadlllabeling!lrml) 

(Electronic labels on CD are encouraged and guidance is available)( link to 

ht1p:!fwww.epa.gov/pesticidesfregulatingfregis1ering/submissionsfindex.htm#labels 

I 

x 

37
7 Is the data package consistent with PR Notice 86-5 (link to PRN 86-5) X 

Nolice of Filing (link 10 

8 httl!://www.eI!8.gov/QesticideslregulatimYtolerance uetitions.htm) included 

with petitions (link to 

http://www.epa.gov/peslicidesiregulalingllolerances.hlm) 't--

9 If applicable for conventional applications, reduced risk rationale (link to 

http://www.epa.goviopprdOOliworkplanireducedrisk.hlml) ,LRequired Dala (link 10 

hUn :I/www .e~a .gov /Qestici des! regul atin2fd ata reguirements.htm) and/or 

data waivers. See Footnote C. 

a) List study (or studies) not included with application 

10 

2 

38
6~cllu r<-cP 

j a. c k...J.- r «e-cI 

* 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 withdrawn 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 

39
site [link to http://www.epa.gov/opprdOOllinertsllists.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 lIAB resolving the issue should accompany the application. All 

new inerts except PIP inerts are reviewed by lIAB. The IIAB 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/oppbppd1Ibiopesticides/contactsbppd.htm]. 

When a brand, trade, or proprietary name of an inert ingredient is listed on a CSF, 

additional infonnation such as an alternate name of the inert, CAS number or other 

infonnation [link to http://www.epa.gov/opprd001Iinerts/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 infonnation 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 21-day content review period, the 

Agency will reject the application. 

During the 21 day content review, applicants should submit infonnation to the individual 

identified by the Agency when the applicant is infonned 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 

40
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 a., requiring an 

inert approval (R311, R312 or R313), it 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, 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 hannonizing the timeframe for both actions. 

5 

41
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 R301 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 

42
RE: Submission to EPA: Product Ritter Dicamba Technical (EPA Reg# 9468-UL) 

Ann Tillman 10: Aswathy Balan 0312!12011 02:29 PM 

Aswathy, that is fine. I will make a note that you made that change. 

Ann 

--~--Original Message~---~ 

From: Balan.Aswathy@epamai1.epa.gov [mailto:Balan.Aswathy@epamai1.epa.gov] 

Sent: Monday, March 21,2011 2:24 PM 

To: Ann Tillman 

Subject: RE: Submission to EPA: Product Ritter Dicamba Technical (EPA Reg# 9468~UL) 

Ms. Ann, I am putting an "Intentionally left blank" page as page number 

134 and the MSDS you sent me wilI be pages 135-139 so that the page count of your study will not be altered and 

remain as 139 pages in confidential attachment. Let me know whether this is okay with you. 

Aswathy Balan 

Macfadden, EPA Contractor 

2777 S. Crystal Drive, S4810 

Arlington, VA 22202 

Ph: 703-347-8787 

Fax: 703~305-5060 

From: 

To: 

Cc: 

Date: 

Ann Tillman <Ann@PyxisRC.com> 

Aswathy BalanlDCIUSEPNUS@EPA 

Sree Nair/DCfUSEP NUS@EPA 

0312112011 01:58PM 

Subject: RE: Submission to EPA: Product Ritter Dicamba Technical (EPA 

Reg# 9468-UL) 

Aswathy, 

Attached is page 49 from Volume I. I checked pages 134 and 135 and I realized that there must have been an error 

in the copy/paste when I inserted the MSDS into the original Word document and I did not catch that in the final 

version of the report. The information on pages 135 and 136 should have been on page 134 but somehow the 

information was separated. The information forSect"lon I of the MSDS is found on page 

136 beginning with the Company Identification. A copy of the MSDS is attached so you can see that no information 

is missing. 

Ann 

-~~--Original Message-~---

From: Balan.Aswathy@epamail.epa.gov [ 

mailto :Balan.Aswalh y@epamail.epa.gov] 

Sent: Monday, March 21, 20 II I :27 PM 

To: Ann Tillman 

Cc: Nair.Sree@epamail.epa.gov 

Subject: Submission to EPA: Product Ritter Dicamba Technical (EPA Reg# 

43
9468-UL) 

Dear Ms. Tillman, 

This is a follow-up email regarding your Application for Registration of the product Ritter Dicamba Technical (EPA 

Reg# 9468-UL). We have found some issues regarding your application. 

In Study #1: From the confidential attachment page 49 is missing and data is missing from pages 134 and 135(these 

pages look incomplete). 

You can send the corrected pages either by fax to 703-305~5060, Attn: 

Aswathy Balan or email to baian.aswathy@epa.gov. Please call me back at 

703-347-8787 if you have any questions. 

Thanks, 

Aswathy Balan 

Macfadden, EPA Contractor 

2777 S. Crystal Drive, 54810 

Arlington, VA 22202 

Ph: 703-347-8787 

Fax: 703-305-5060 

[attachment "20110311 Ritter Dicamba Tech Application Package Vol. 

I_missing page.pdf' deleted by Aswathy BalanIDCIUSEPNUS] [attachment "MSDS for pdf' 

deleted by Aswathy BalanIDC/uSEPNUS] 

44 *Manufacturing process information may be entitled to confidential treatment*
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 

WASHINGTON, D.C. 20460 

March 17, 2011 

OPP Decision Number: D-446591 

EPA File Symbol or Registration Number: 9468-UL 

Product Name: RITTER DICAMBA TECHNICAL 

EPA Receipt Date: 16-Mar-20 II 

EPA Company Number: 9468 

Company Name: RITTER CHEMICAL, LLC 

JANELLE KAY 

PYXIS REGULATORY CONSULTING, INC. 

RITTER CHEMICAL, LLC 

4110 136TH STREET, N.W, 

GIG HARBOR, W A 98332-

OFFICE OF 

PREVENTION, PESTICIDES AND 

TOXIC SUBST A]\!CES 

SUBJECT: Receipt of Registration Application Subject to Registration Service Fee 

Dear Registrant: 

The Office of Pesticide Programs has received your application and certification of 

payment. If you submitted data with this application, the results of the PRN-86-5 screen will be 

communicated separately. During the administrative screen, the Office of Pesticide Programs 

has determined that this Action is subject to a Pesticide Registration Service Fee as defined in 

the Pesticide Registration Improvement Act. 

The Action has been identified as Action Code: R300 

NEW PRODUCT;ME-TOO PRODUCT FAST TRACK; 

No additional payment is due at this time. We will process a refund of your $3,373 

overpayment as soon as is practicable. 

If you have any questions, please contact the Pesticide Registration Service Fee 

Ombudsman at (703) 308-9362. 

Front 

Sincerely, 

End Processing 

7'~~ Staff 

Information Technology & Resources Management Division 

45
IFee for Servicel 

Ii 

{892170EThis package includes the following 

@ New Registration 

°Amendment 

o Studies? D Fee Waiver? 

Dvolpay % Reduction: __ 

for Division 

°AD 

°BPPD 

@RD 

Risk Mgr. []I] 

Receipt No. s-I 892170 

EPA File Symbol/Reg. No. 1 9468-UL 

Pin-Punch Date: 1 3/16/2011 

This item is NOT subject to FFS action. 

Action Code: 

Requested: 1 'K3tD 

Granted: I R8CO I 

Amount Due: $ I L\; -::'41X2.-

Parent/Child Decisions: 

Uncleared Inert in Product 

Date:3!F}[ If 

46
47
FEE FOR SERVICE 

48
Sarah Greubel 

From: 

Sent: 

To: 

Subject: 

paygovadmin@mail.doc.twaLgov 

Monday, March 14, 20113:06 PM 

Sarah Greubel 

Pay.Gov Payment Confirmation 

THIS IS AN AUTOMATED MESSAGE. PLEASE DO NOT REPLY. 

Your transaction has been successfully completed. 

Transaction Summary 

Application Name: PRIA Service Fees 

Pay.gov Tracking ID: 252R8C4L 

Agency Tracking ID: 74183880854 

Transaction Type: Sale 

Transaction Date: Mar 14) 2011 6:05:31 PM 

Account Holder Name: Ann Tillman 

Transaction Amount: $4)807.00 

Billing Address: 4110 136th St NW 

City: Gig Harbor 

State/Province: WA 

Zip/Postal Code: 98332 

Country: USA 

Card Type: AmericanExpress 

Card Number: ***********1031 

Decision Number: 

Registration Number: 

Company Name: Ritter Chemical LLC 

Company Number: 9468 

Action Code: R310 

1 

49
lit J'w~ I cT') 

50
C[I--L 10 t -UL 

E3{po 

Memorandum Needs , 

Clol yY1 \JYI 

Date: 03 / Ol R. / /1 t(JMJ 

To: ____ P_M_--c::(..:=3'----___ , 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: ~ly accepted submission 

Ii partially accepted submission 

C rejected submission 

2JLC0--

51
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 

WASHINGTON, D.C. 20460 

March 21, 2011 

JANELLE KAY 

PYXIS REGULATORY CONSULTING, INC. 

RITTER CHEMICAL, LLC 

4110 136TH STREET, N.W, 

GIG HARBOR, W A 98332· 

Report of Analysis for Compliance with PR Notice 86-5 

OFFJCEOF 

PREVENTION, PESTICIDES AND 

TOXIC SUBSTANCES 

Thank you for your submittal of 16-MAR-l1. 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. 

52
53
PYXIS REGULATORY CONSULTING, INC. 484205-00 

4110 J36th 8t. NW Phone: 253-853-7369 

Gig Harbor, WA 98332 Fax: 253-853-5516 

www.PyxisRC.com 

OVERNIGHT DELIVERY 

Kathryn Montague (PM 23) 

Document Processing Desk (REG FEE) 

Office of Pesticide Programs (7504P) 

U.S. Environmental Protection Agency 

Room S-4900, One Potomac Yard 

2777 S. Crystal Drive 

Arlington, VA 22202 

RE: Ritter Chemical, LLC 

March 11,2011 

Ritter Dicamba Technical (EPA File Symbol 9468- ) 

Application for New Pesticide Registration 

PRIA category R31 0 (46: New manufacturing use product) 

Dear Ms. Montague, 

On behalf of Ritter Chemical, LLC, we are submitting an application for registration of Ritter Dicamba 

Technical. In support of this application, we submit the following documents: 

1. Application for a New Pesticide Registration (EPA FOm1 8570-1) 

2. Confidential Statement of Fonnula (EPA FOm1 8570-4) 

3. Three (3) Copies of the Proposed Labeling 

4. A CD containing an electronic version of the proposed labeling 

5. Certification with Respectto Label Integrity 

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

7. Agency Internal Use Copy of the Data Matrix 

8. Public File Copy of the Data Matrix 

9. Copy ofPRIA payment 

10. Letter of Authorization 

11. Product Specific Data (3 copies of each report): 

Volume I 830.1550,830.1600, TilIman, A. M. Product Identity and Composition, Description of 

48420501 830.1620,830.1650, th' Materials Used, Description of the Production Process, 

830.1670, 830.1750, Description of the Formulation Process, Discussion of the Formation 

830.1800 of Impurities, Certified Limits, and Enforcement Analytical Method 

for Ritter Dicamba Technical. Contains C01lfidential Business 

Information. 

48420502 Volume 2 830.1700, 830.1800 Li, H. Preliminary Analysis and Enforcement Analytical Method of 

Dicamba TGAI. Contains Confidential Business h;!ormation. 

54
K. Montague 

March 11,2011 

Page 2 of2 

48420503 Volume 3 830.6302, 830.6303, Weller, P. J. Group B Product Chemistry Analysis of Dicamba 

830.6304, 830.6313, Technical. 

830.6314,830.7000, 

830.7050, 830.7200, 

830.7300 

48420504 Volume 4 830.6313,830.6315, Tillman, A. M. Ritter Dicamba Technical Waiver Requests 

830.6316, 830.6317, Certain Phys-Chem Properties. 

830.6319, 830.6320, 

830.6321,830.7100, 

830.7220, 830.7300, 

830.7370, 830.7520, 

830.7550-7570, 

830.7840-7860, 

830.7950 

We would like to note that Ritter Chemical, LLC is using the cite-all method of support. As per EPA's 

interpretations of 40 CFR Parts 152.86(b)(2)(i) and 152.93(b)(2)(i), Ritter Chemical, LLC submitted 

notices of intent to apply and offers to pay to all companies on the September 30, 2010 Data Submitter's 

List. This action falls under PRlA category R310 (46: New manufacturing use product) because it is an 

application for registration for a manufacturing use product identical to a currently registered product. 

The PRlA fee for this action is $4,807 and has been paid. The decision timeline is 6 months. 

We trust you will find this application complete. However, please feel free to contact me «253) 853-

7369, Ann@PyxisRC.com) if you have any questions or need any additional infonnation. 

Sincerely, 

Ann M. Tillman 

Enclosures 

foc 

55
Certification with Respect to Label Integrity 

version: 9/11f02 

I certify that the information (including, but not limited to, text, tables, and graphics) 

contained in the electronic file identified below by file name and submitted with this 

certification is the same information as that on the paper copies of these documents 

included with this submission. 

IPROPOSED LABEL 

Date Submitted 

EPA Registration # to EPA Electronic file name 

009468-xxxxx March 11, 2011 009468-xxxxx.2011 0311.Ritter Dicamba 

Technicallabel.v1.pdf 

I certify that the statements that I have made on this form are true, accurate, and 

complete. I acknowledge that any knowingly false or misleading statements may be 

punishable by fine or imprisonment or both under applicable law. 

Signature 

Ann M. Tillman 

Consultant, Ritter Chemical, LLC 

March 11, 2011 

Date 

56
There is an ELECTRONIC LABEL for this action 

You can use Acrobat to compare the e-Iabel to the previous version (and find the 

changes). You can also use Acrobat to mark-up the e-Iabel with your comments. 

If e~label was submitted via 

CD-ROM with paper application 

then you will find e~label in 

Electronic Label Library 

tft/1ft 9-/abtJ/ Is not found in /11ft ELL then It was prabobly not nomed 

c;offfJCtIy and could not be entered info tho ELL. HoweVDr, /ho fifo 

can be retrieved from the CD which Is retainodJ?y IhI1 Fron! End. 

or If e~label was submitted via 

XML E-Submission (no paper) 

then you will find e-Iabel in 

Documentum 

See overview of processing e-Iabels on other side of this sheet. 

If you have any questions on e-Iabels, please contact one of your division e-Iabel experts: 

AD 

BPPD 

RD 

Willie Abney 

Renae Whitaker 

Tracy Lantz 

Tom Harris 

308-1689 

308-7003 

308-6415 

308-9423 

57
Ritter Chern iccl LLe 

October 28, 2009 

To Whom It May Concern: 

RE: Letter of Authorization 

Dear Siror Madam: 

Please let this letter serve to confirm that Pyxis Regulatory Consulting, Inc. is authorized to act as agents 

for Ritter Chemical, LLC (EPA Company Number 9468), before the U.S. Environmental Protection 

Agency and state governmental agencies in all matters regarding our pesticide registrations pursuant to 

the Federal Insecticide, Fungicide and Rodenticide Act ("FIFRA"), 7 U.S.c. § 136 et seq. and state law. 

If you have any questions, please do not hesitate to contact me. 

cc: Pyxis Regulatory Consulting, Inc. 

16099 sw 95,h ;:w"'"U~ 

Ur.r1601 

'Nib",vilie, OR 97070 

kl 5032!S.:2980 

Fe! ,503."293.3-372 

58
59

*Confidential Statement of Formula may be entitled to confidential treatment*
60

*Confidential Statement of Formula may be entitled to confidential treatment*
Rittef Dicamba Technical 

Ann Tillman 

to: 

Akiva Abramovitch 

09/06/2011 01:24PM 

Show Details 

Akiva, 

Page1of1 

Attached is the revised CSF for the Ritter Dicamba Technical. I added the 2 impurities to the CSF (attached). 

The one is based on the results of the 5 batch analysis 

Keep dry! 

Ann 

Ann M. Tflfman, Ph.D. 

Pyxis Regulatory Consulting, Inc. 

4110 136/h St. NW 

Gig Harbor, WA 98332 

Office (253) 853-7369 

Fax (253) 853-5516 

Email Ann@PyxisRG.com 

file:IIC:IDocuments and SettingslaabramovlLoca1 SettingsITemplnotesFCBCEEI-web6225.", 9/6/2011 

61 *Manufacturing process information may be entitled to confidential treatment*
I 

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62

*Confidential Statement of Formula may be entitled to confidential treatment*
63

*Confidential Statement of Formula may be entitled to confidential treatment*
& !f\1R!rn,nn!'r~ "\' /IUi\W)I"U'\~' [ .. ) !.1 if II" Ifl1n (,\ i[ U rl. U U u u\!::/ t..::1 

64

*Confidential Statement of Formula may be entitled to confidential treatment*
SEP 1 9 2011 

NOTE TO FILE 

9468-UL 

Ritter Dicamba Technical is formulated with an unregistered source of technical dicamba. The 

cited me-too registered pesticide product is Albaugh Tecimical Dicamba Acid, EPA Reg. No. 

42750-57. 

The two formulations have been compared. The nominal percentage of Ritter technical dicamba 

acid is 98.9% versus 98.0% for Albaugh's technical. 

In accordance with 

the RD Impurity Assessment SOP, Masih Hashim, Acute Toxicology Team Leader, TRBIRD, 

was consulted. He concluded that the low levels of these impurities in the fonnulation (levels of 

impurities at less than 0.1 % do not have to be reported on the CSF) are at concentrations that are 

not of toxicological concern. 

Ritter Dicamba Technical is Substantially Similar to Albaugh Technical Dicamba Acid. 

65 *Manufacturing process information may be entitled to confidential treatment*
BARCODE: 388021; Reg. No./FILE SYMBOL No.:9468-UL; PRODUCT: Ritter Dicamba Technical 

Confidential appendix 

830.1600 (description of materials used to produce the product) 

The following details were provided in MRID 484205-01: 

66 *Manufacturing process information may be entitled to confidential treatment*
BARCODE: 388021; Reg. No./FILE SYMBOL No.:9468-UL; PRODUCT: Ritter Dicamba Technical 

67 *Manufacturing process information may be entitled to confidential treatment*
BARCODE: 388021; Reg. NO./FILE SYMBOL No.:9468-UL; PRODUCT: Ritter Dicamba Technical 

68 *Manufacturing process information may be entitled to confidential treatment*
BARCODE: 388021; Reg. No./FILE SYMBOL No.:9468-UL; PRODUCT; Ritter Dicamba Technical 

69 *Manufacturing process information may be entitled to confidential treatment*
BARCODE: 388021; Reg. No./FILE SYMBOL No.:9468-UL; PRODUCT: Ritter Dicamba Technical 

70 *Manufacturing process information may be entitled to confidential treatment*
BARCODE: 388021; Reg. No./FILE SYMBOL No.:9468-UL; PRODUCT: Ritter Dicamba Technical 

_~~ .~_n 

71 *Manufacturing process information may be entitled to confidential treatment*
BARCODE: 388021; Reg. No./FILE SYMBOL No.:9468-UL; PRODUCT: Ritter Dicamba Technical 

72 *Manufacturing process information may be entitled to confidential treatment*
BARCODE: 388021; Reg. No. IFILE SYMBOL No.:9468-UL; PRODUCT: Ritter Dicamba Technical 

73 *Manufacturing process information may be entitled to confidential treatment*
BARCODE: 388021; Reg. No.IF!LE SYMBOL No.:9468~UL; PRODUCT: Ritter Dicamba Technica! 

74 *Manufacturing process information may be entitled to confidential treatment*
BARCODE: 388021; Reg. No./FILE SYMBOL No.:9468-UL; PRODUCT: Ritter Dicamba Technical 

75 *Manufacturing process information may be entitled to confidential treatment*
BARCODE: 388021; Reg. No./FILE SYMBOL No.:9468-UL; PRODUCT: Ritter Dicamba Technical 

76 *Manufacturing process information may be entitled to confidential treatment*
BARCODE: 388021; Reg. No. IFILE SYMBOL No.:9468-UL; PRODUCT: Ritter Dicamba Technical 

77 *Manufacturing process information may be entitled to confidential treatment*
BARCODE: 388021; Reg. No./FILE SYMBOL No.:9468-UL; PRODUCT: Ritter Dicamba Technical 

78 *Manufacturing process information may be entitled to confidential treatment*
BARCODE: 388021; Reg. No./FILE SYMBOL No.:9468-UL; PRODUCT: Ritter Dicamba Technical 

79 *Manufacturing process information may be entitled to confidential treatment*
BARCODE: 388021; Reg. No./FILE SYMBOL No.:9468-UL; PRODUCT: Ritter Dicamba Technical 

830.1670 (discussion on the formation of impurities) 

80 *Manufacturing process information may be entitled to confidential treatment*
BARCODE: 388021; Reg. No./FILE SYMBOL No.:9468-UL; PRODUCT: Ritter Dicamba Technical 

81 *Manufacturing process information may be entitled to confidential treatment*
BARCODE: 388021; Reg. No./FILE SYMBOL No.:9468~UL; PRODUCT: Ritter Dicamba Technical 

830.1700 (preliminary analysis) 

The percent Al for the basic formulation (98.9%) is supported by a 5~batch analysis. The registrant 

provided the following details on results of the 5-batch analysis in MRID 484205-02: 

830.1750 (certified limits) 

The certified limits for the active ingredient specified on the CSF and on the product label for the basic 

formulation are within the OPPTS 830.1750 recommended range. The impurities are listed on the CSF. A 

copy of the CSF is attached below. 

22 

82 *Manufacturing process information may be entitled to confidential treatment*