EPA Reg. No. 85678-4 

1
ISB'S Front-end PRIA Completeness Screen 

Draft 3; 10/25107 

r 

I I EPA Receipt Date: AUG - 4 2009 EP A Reg. Number: ,(?!J678. 

Check List Item YeS 

I I Has the PRIA Fee been Paid; is a copy of the check or 

Pay.gov rcccipt included in the Submission Package? >< 

tIs an Application Form (EPA Form 8570-1) Included in the I. ., <;ubmisslon Package, is it completely filled out and signed 

I 

'ncluding package type? 

I 

Is a Confidential Statement of Formula (EPA Form 857 - /., I 3 29) Included in the Submission Package, is it completely 

I fi lled out and signed (boxes 1-21)? I 

f Is a formu lator's Exemption Statement (EPA Form 8570- 4 , 27 ) Included in the Submission Package? -. 

'\ Is a ( 'crtification with Respect to Citation of Data (EPA 

I I orm 8570-34) Included in the Submission Package? f 

j-----r,-

I (: I b a Data M atrix (EPA Form 8570-35) Included in the 

~ X l Submission Package? 

7 Is a La bel Included in the Submission Package? X 

I 

r 

X Arc Data Included in the Submission Package? ~ 

C) Is the Submission an Amendment? 

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-1 

No NIA I 

I 

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2
111111 1111111\

1111111 \1\111 

856 78- U ~IHIIIII~II~IIIIIII~ III 

009284857 

3
Material to be added to an e-Jacket/Jacket 

Reg. No. ?JJ~7?! -1 

-- j 

Description: +. .k jPVk~* 

1.'-EJ"'1ilacement within the e-Jacket/jacket: 

'EJl5efault: (chronological, top = newest) 

D File Location: (PDF page number, i.e., "before page 

45") 

2. ~nd to Data Extraction contractors this material: 

~ .... Newly stamped accepted label 

D Notification 

e.--------N ew CSF 

D Other: ____________ _ 

3. 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 Name: __ 7.I-I;--=L=,/t-/.,h/_cJ~ ____ _ 

Phone: ________ Division: ____ _ 

Date: ___ ~L¥/-=d~~/_/_u _________ _ 

Created November 18, 2008 

4
U.S. ENVIRONMENTAL PROTECTION AGENCY 

Office of Pesticide Programs 

Registration Division (7505P) 

f200 pennsylvania Ave., N.W. 

Washington, D.C. 20460 

NOTICE OF PESTICIDE: 

--X. Registration 

_ Reregistration 

(under FIFRA, as amended) 

EPA Reg. Number: Date oflssuance: 

85678-4 

25 20iO 

Term of Issuance: 

Conditional 

Name oCPestieide Producl: 

Name and Address of Registrant (include ZIP Code): 

RedEagle International LLC 

1925 E. Edgewood Drive 

Lakeland, Florida 33803 

Ethephon 78% MUP 

Mailed to: Agent for RedEagle 

Wagner Regulatory Associates 

7460 Lancaster Pike, Suite 9 

!!<J~~!!z Delaware 19707 

On the basis ofinfonnation furnished by the registrant, the above named pesticide is hereby 

registered under the Federal Insecticide, Fungicide and Rodenticide Act. Registration is in no 

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

order to protect health and the environment, the Administrator, on his motion, may at any time 

suspend or cancel the registration of a pesticide in accordance with the Act. The acceptance of 

any name in connection with the registration of a product under this Act is not to be construed 

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

others. 

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

that you: 

1. Submit and/or cite all data required for registration of your product under FIFRA section 

3(c)(5) when the Agency requires all registrants of similar products to submit such data; 

and submit acceptable responses required for reregistration of your product under 

FIFRA section 4. 

5
El'A Reg. No 85678-4. 

Page 2 of2 

2. You must submit the following GLP conditional data, within 12 months of the date of 

this notice. 

a. Storage Stability (830.6317), and 

b. Corrosion Characteristics (830.6320) studies. 

3. Make the following changes to the label version dated 1119/2010: 

A. Change the product registration number to "EPA Reg. No. 85678-4" 

B. Add the missing EPA Establishment Number and Net Contents to Page 1 

C. On page 3, in "Conditions", change "All such risks ... " to "To the extent consistent 

with applicable law, all suck risks ... ". 

4. Submit one copy of the revised final printed label for the record before the product is 

released for shipment. 

If these conditions are not complied with, the registration \¥ill be subject to cancellation in 

accordance with FIFRA section 6( e). Your release for shipment of the product constitutes 

acceptance of these conditions. 

A copy of the label stamped "Accepted with Comments" is enclosed for your records. 

Signature of Approving Official: // 

(/\ 

~ ~ !~ '\ 

\ I i ! I i 

Tony Kish, Product Manager (22;)) 

FEB 25 2010 

Date: 

Fungicide Branch, Registration Division (7505P) 

EPA Fonn 8570.6 

6
! 

August 20, 2009 

Mr. Tony Kish (PM 22) 

U.S. Environmental Protection Agency 

Office of Pesticide Programs - Registration Division (7505P) 

Ariel Rios Building 

l200 Pennsylvania Avenue, N. W. 

Washington, DC 20460 

Dear Mr. Kish; 

Wagner Regulatory Associates, Inc 

P.O. Box 640 

7460 Lancaster Pike, Suite 9 

Hockessin, Delaware 19707 

Re: Revisions to Data Matrix (EPA Form 8570R35 fo Intet:n.ati roducts 

Ethephon 6 (EPA Reg. No. 85678-) an thep on 78% MUP (EPA Reg. No. 85678-). 

~L .. - -u 9~ 

Wagner Regulatory Associates, Inc., as agent for RedEagle International LLC, is submitting revised Data 

Matrix forms for the above-referenced products. Several data submitters were inadvertently omitted from 

the original submission. This error has been corrected and the corrected fonns are enclosed. 

If you have any questions about these revisions, please contact the undersigned. 

Respectfully submitted, 

Catherine M. Byrd 

Agent for RedEagJe International LLC 

Enclosures 

7
Fonn Ar. roved OMS Nos. 2070-0060; 2070-0057; 2010-010"7;2070-0122; W7t1-trlS4 

,-" UNITED STATES ENVIRONMENTAL PROTECTION AGENCY ~Al ~ 1200 Pennsylvania Avenue, N.W. 

WASHINGTON, D.C. 20460 

Paperwolk Redoction Act Notice: The public reporting burden furthis collection ofinfonnarion is estimated tu avel1lge 125 hoolll per response fll" rcgi!llrntion 

and0.25lDurs per reSj)O!We forreregi!llrntion andspocial review;!.ctivities, including time forreariing the iMructions and compieling the necessilIY forms. Send 

comments regilfding burden estimate or any other aspect of this collection ofinfonnation, including suggestions for relilcing the bwtlen to: Director, Collection 

SlnItegies Division (2822D. U.S. Environrnel1lai Pmte\:tionAgen::y, 1200 PellllSylvi!lliaAvenue, N.W., Washington. DC 20460. Do not send the completed form 

10 this address. 

Certification with Respect to Citation ofDala 

App!icanfsiReQislranrs Name, Address. and Telephone Number EPA Registration NumberfFile svmbol 

RedEagle Inlemalional LLC, P.O. Box 640. Hoc!<essin, DE 19707 85678· 

Active lnllredienl(S) andlorreoresenla\ive lest romoound(s) 0 .. 

Elhephon July 31, 2009 

GenEifal Use Patem(s) (Iisl allhose Claimed for Ihis product using 40 CFR Part t58) Product Name 

Terreslrial food crop use; Terrestrial nonfood crop use Elhephon 78% MUP 

NOTE: If your product is a 100% repad!.aging of anotherpurctJased EPA-registered product labeled for aH lhe same uses on your label, you do nol need 10 

submit this fonn. You must submlt the Fonnulalo~s ExelJ1)tion Stalernenl (EPA Form 8570-27). 

D I am responding kI a Data-Can-In Nolice, and have induded with this fonn a list of rompanJes sent olfelS of rompensation (Itle Data Malrixfonn should 

be ured forlhis pUlpose). 

SECTION I: MEnlOD OF DATASUPPORT (Chad!. one method only) 

D I am uSing the cile-all method of support, and have Induded with ll"'~ fonn 0 I am using the selective method of support (or cite-all option 

a lisl olcompanies senl offelS of rompensaHon (the Dala Matrix ronn underltl!l selective melhod), and have induded with this fonn a 

should be used for this purpose). romple\ed fist of data requirements (the Dala Mafrix fonn must be 

used} 

SECTIONJI: GEfERAL OFFER TO PAY 

[Required if using the cite-all melhod orwhen using the cite-all option uOOer the seledlVe method to safisfy one or more data requrementsl 

0 I hereby offer and agree to pay rompensalion. 10 other persons, with regard to the approval of this applicalion, 10 the e~nl required by FIFRA. 

SECTION JJJ: CERTIFICATION 

I certify thai this applical"lln for registraUon, this fonnfOf rereglslration, alhis Data-CaH-In response is supported by an data submitted or died in Itle 

application tor registration, Itle rorm for reregistration, orlhe Data-Call·ln response. In addition, If the cije-all option or cile-all option under Itle selective melhod is 

indicated in Section I, Ihis applieatiOn is supported by al dala n the AgC!f1cy's fileslhat (t) ronrem Ihe properties oreffecls oflhis product or an identical or 

substantially simllar product, or one Of more oflhe ingredients in this product; and (2) is a type of data Itlal woul:! be required 10 be submitted l.fIder Itle data 

requirements in effect on tie dale of approval Of this application iflhe application SOl1Jht the iniJiUl regislration of a prodUct of Identical or similar CQI11position and 

uses. 

I certify thai for ead"l exdusive use study ciJed n stJpport of this registration or reregistration, that I am the ortginaldata submitter or that I have oblained 

lIle written pennission oflhe original data submitlerlo cije that study. 

I certify thai for each sludy c~ed in support ofthis regislration or reregistration lIlal is not an eXdusive use study. either: (a) I am Ihe original data 

submitter; (b) I ha~ obtained the pemlission of the original data submHterto use the sludy in stJpport of this application; (c) all periods ofeijgibility ror 

rompensation have expred for !he study; (d) the study is in lhe public literature; or (e) I ha~ nDlffied in writing \he rompany lhat submitted lIle study and have 

offered (I) 10 pay rompensation tothe ext."t required by sections 3(c)(1)(F) andtor3(c)(2)(B) ofFIFRA; and Qi) 10 rommence negotiations to determine the 

amount and lerms of rompensation, if any, 10 be paid ror the use of tile study. 

I certify that in all instances where an offer ofrompensatlon is required, ropies of aft 01fe1S to pay rompensation <IDd evidenoo oftheirde6very in 

aCOJrdilncewith ooctlOns 3(c)(t)(F) anGlor 3(c)(2)(B) of FIFRA are aw~able andwiU be submitted to the PGency upon request. ShoiJd I fa~ 10 pfOduce stich 

evidence to tie Agency upon request. I undersJand lIlilt!he Agency may Inillate action to deny, cancel or suspend IhE! regtstration of my product in conformity with 

FIFRA. 

I certify that tho .tat.m.nt. I have made on thiS form and all attachmenm to It aro Iru., accuralD, and complelo. I acknowodg. that any 

knowingly false or mlsleadlru ltatament may bo punishable by fino or Imprisonment or both under applicabl. law. 

Signature 

~ttL 0" Typed or Printed Name and Tdle 

Augusl10,2oo9 Calherine M. Byrd, Agent 

EPA Fonn 8570-34 (12 -2003) ElectronIC and Paper YelSlons available. Submit only Paper velSlon. 

8
.I'" ">" Form Approved OMB No. 2070-0060 (~l UNITED STATES ENVIRONMENTAL PROTECTION AGENCY .""",.'# 401 M Street, S.W. 

WASHINGTON, D.C. 20460 

Paperwork Reduction Act Notice; The public reporting burden for this collection ofinfonnation is estimated to average 025 hours per response for registration activities and 0.25 

hours per response for reregistration and special review activities, including time for reading the instruction and completing the necessary fonns. Send comments regarding the 

burden estimate or any other aspect of this collection ofinfonnation, including suggestions for reducing the burden to; Director, OPPE Infonnation Management Division (2137), 

U.S. Environmental Protection Agencv, 401 M Street, S,W., Washi~l!ton DC 20460. Do not send the fonn to this address. 

DATA MATRIX 

Date: July 31,2009 EPA Reg No.1 File Symbol: ! Page 1 of2 

85678-

App!icanfslRegistranfs Name and Address: RedEagle International LLC Product: 

c/o Wagner Regulatory Associates Inc. 

P.O. Box 640 Ethephon 6 

Hockessin, DE 19707 

Ingredient: Ethephon 

Guideline Number 

Signature Name and Title Date 

Catherine M. Byrd, A ent for RedEa Ie International LLC Jul 31,2009 

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

9
.r '''>. .. ft ~ Form Approved OMB No. 2070-0060 

\~, UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 

",-",1" 

401 M Street, S.W. 

WASHINGTON, D.C. 20460 

Paperwork Reduction Act Notice: The public reporting burden for this col!ection of information is estimated to average 0.25 hours per response for registration activities and 0.25 

hours per response for reregistration and special review activities, including time for reading the instruction and completing the necessary forms. Send comments regarding the 

burden estimate or any other aspect of this colIection of information, including suggestions for reducing the burden to: Director, OPPE Information Management Division (2137), 

U.S. Environmcntal Protection Agency, 40 I M Street, S.W., Washington DC 20460. Do not send the form to this address. 

DATA MATRIX 

Date: July 31, 2009 EPA Reg No.1 File Symbol: I Page 2 of2 

85678· 

Applicant'sJRegistrant's Name and Address: RedEagle International LLC Product: 

c/o Wagner Regulatory Associates Inc. 

p.a. Box 640 Ethephon 6 

Hockessin, DE 19707 

Ingredient: Ethephon 

Signature Name and Title Date 

Catherine M. Byrd, Agent for RedEa Ie International LLC July 31, 2009 

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

10
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 

401 M Street, S.W. 

WASHINGTON, D.C. 20460 

Form Approved OMB No. 2070-0060 

Paperworl, Reduction Act Notice: The public reporting burden for this collection ofinfonnation is estimated to average 0.25 hours per response for registration activities and 0.25 

hours per response for reregistration and special review activities, including time for reading the instruction and completing the necessary fonns. Send comments regarding the 

burden estimate or any other aspect of this collection ofinfonnation, including suggestions for reducing the burden to: Director, OPPE Information Management Division (2137), 

U.S. Environmental Protection Agency, 401 M Street, S.W., Wash~gton DC 20460. Do not send the fonn to this address. 

DATA MATRIX 

Date: July 31, 2009 

Applicant's/Reg'lstrant's Name and Address: RedEagle International LLC 

Ingredient: Ethephon 

Gu'ldcline Referencc Number 

830.1650,830.1670 

Ii 

~ 

clo Wagner Regulatory Associates Inc. 

P.O. Box 640 

Hockessin, DE 19707 

Guidcline Study Name 

iPW'''' Id,"'ii;;,- Composition/Descriptioll of Matcrials 

used to Producc tbc Product/Description 

of Formula~~n Proce:>sJDiscussion of , i i 

0;;;;;-

~: ,I 

,= 

~ 

EPA Reg No.1 File Symbol: 

85678-

Product: 

Ethephon 6 

, J LLC: 

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I Page I of3 

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Signature 

~7'L$IrtJ.- EPA Fonn 8570-35 (9-97) Electrollic and Paper versIOns available. Submit only Paper verSion. 

I 

,ILL 

<ILL 

Name and Title 

Catherine M. Byrd, Agent for RedEagJe International 

LLC 

OW" 

Owo 

)wo 

Date 

July31,2009 

Agency Internal Use COpy 

11
/" ',,>- Form Approved OMS No. 2070·0060 (~l UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 

~-" 401 M Street, S.W. 

WASHINGTON, D.C. 20460 

Paperwork Reduction Act Notice: The public reporting burden for this collection of information is estimated to average 0.25 hours per response for registration activities and 0.25 

hours per response for reregistration and special review activities, including time for reading the instruction and completing the necessary fonns. Send comments regarding the 

burden estimate or any other aspect of this collection of information, including suggestions for reducing the burden to: Director, OPPE Infonnation Management Division (2137), 

U.S. Environmental Protection A<>ency, 401 M Street, S.W., Washington DC 20460. Do not send the fonn to this address. 

DATA MATRIX 

Date: July 31, 2009 EPA Reg No.! File Symbol: I Page 2 of3 

85678~ 

Applicant'slRegistrant's Name and Address: RedEagle International LLC Product: 

c/o Wagner Regulatory Associates Inc. 

P.O. Box 640 Ethephon 6 

Hockessin, DE 19707 

Ingredient: Ethephon 

,~ 

, i MRID, ; Status Note 

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; I 

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= , ~' I 

iwn 

V;;;;;;;C IWH 

I "u," uu;liDO, !, ri,;;;;,~ , I Cit, All I ~FO~'~MC 'oy 

2500,2600 Irritation, Dermal Irritation, Skin I 

Sensitization , , BAsI'S;;;;;"" .Le, I ,NC 

LP, I, P"k, NC 

E.L " ,DE 

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, F"" 

Signature 

~#- Name and Title Date 

Catherine M. Byrd, Agent for RedEagle International July 31, 2009 

LLC 

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

12
/' >'\. Form Approved OMB No. 2070-0060 

(~l UNITED STATES ENVIRONMENTAL PROTECTION AGENCY ".,_"# 40 I M Street, S. W. 

WASHINGTON, D.C. 20460 

Paperwork Reduction Act Notice: The public reporting burden for this co!1ection of information is estimated to average 0.25 hours per response for registration activities and 0.25 

hours per response for reregistration and special review activities, including time for reading the instruction and completing the necessary forms. Send comments regarding the 

burden estimate or any other aspect of this collection of information, including suggestions for reducing the burden to: Director, QPPE Infornlation 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: July 31, 2009 EPA Reg No.1 File Symbol: 1 Page 3 of3 

85678-

AppIicant's/Registrant's Name and Address: RedEagle International LLC Product: 

clo Wagner Regulatory Associates Inc. 

P.O. Box 640 Ethephon 6 

Hockessin, DE 19707 

Ingredient: Ethephon 

_/ 

I) Certification of Limits is provided in the Confidential Statement of Formula EPA form 8574A 

Signature 

~er;rL Name and Title Date 

Catherine M. Byrd, Agent for Red Eagle International luly 31, 2009 

LLC , EPA Form 8570-;.5 (9~97) ElectrOniC and Paper versIOns avrulable. SubmIt only Paper versIOn. Agency Internal Use COpy 

13
Please read instructions on reverse before completin.'-J ,ann. Form Approved. OlYl8 No. 2070-0060. ApPlOval expires 05-31-98 

c2S- Registration OPP Identifier Number 

United States oEPA Environmental Protection Agency Amendment 

Washington, DC 20460 I-- Other 

Application for Pesticide ~ Section I 

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

RedEagle International LLC/85678-U Tony Kish 

4. Company/Product (Name) PM" llil None Restricted 

RedEagle International LLC/Ethephon 78% MUP 22 

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

RedEagle International LLC 

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

to: 

clo Wagner Regulatory Associates, Inc. EPA Reg. No. 264-838 

P.O. Box 640 

Hockessin, DE 19707 Product Name: Ethephon Manufacturing Concentrate 

o Check if this is a new address 

Section · II 

0 Amendment - Explain below. 0 Final printed labels in response to 

Agency letter dated 

0 Resubmission in response to Agency letter dated I&J "Me Too" Applicalion. 

0 Nolification - Explain below. 0 Other - Explain below. 

Explanation: Use additional page(s) it necessary. (For Section I and Section 11.) 

Section · III 

1. Material This Product Will Be Packa ed In: 

Chn~,~:."aCkag;"g U~ckaging W~ Soluble Packaging 2. T pe of Container 

Yeo Ye, Metal 

X No X No X No X Plastic 

It "Yes" No. per It ''Yes'' NO. per Glass 

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

be submitted I Other (Specify) HOPE lined bags 

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

[]] Labe! D Container bulk [g On Label 

On Labeling accompanying product 

6. Manner in Which Label is Affixed to Product § U'hogcaph 0 Other _adhesive backed label 

X Paper glued 

Stenciled 

Section · IV 

1. Contact Point Complete Items directly below for identification of individual to be contacted, if necessary, to process this application.) 

Name I Title I T3elePhone No. (Include Area Code) 

Catherine M. Byrd Agent tor RedEagle International LLC 302') 234 2780 

Certification 6. Date Application 

I certify that the statements I have made on this form and all attachments thereto are true, accurate and complete. I Received 

acknolllledge that any knOWingly fatse or misleading statement may be punishable by fine or imprisonment or both 

under applicable law. (Stamped) 

2. Signature 3. Title 

~rrx.&frf.- Agent for RedEagle International LLC 

4. Typed Name 5. Date 

Catherine M. Byrd January 13, 2010 

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

14
• 85678·U 

Janet Whitehurst to: catherine 01/13/201001:06 PM 

Dear Ms. Byrd: 

As per our phone conversation, the subject application, submitted in connection with registration 

under the Federal Insecticide, Fungicide and Rodenticide Act as amended is not acceptable. The 

Agency has evaluated the formulations of the proposed product, 85678-U, and the cited product, 

66330-369,and has detennined that the two products are not substantially similar because the 

percentage of the active ingredient in the proposed product is higher then the cited product. 

Please correct and resubmit your application. If you have any questions, please contact Janet 

Whitehurst by phone at (703) 305-6129 or via email at whitehurst.janet@epa.gov. Thank you. 

Regards, 

Janet 

15
HE: 85678-U 

Catherine Byrd to: Janet Whitehurst 01/19/201004:48 PM 

History: This message has been repJied to and forwarded. 

Hi Janet, 

I have attached a revised label and the "me too" label for Bayer Ethephon 

Manufacturing Concentrate (EPA Reg No. 264-838). I revised the storage and 

disposal language to reflect PR Notice 2007-4. I hope this is okay. Please 

let me know if you need any additional information. 

Thank you, 

Catherine 

Catherine M. Byrd 

Regulatory Associate 

P.O. Box 640 

7460 Lancaster Pike, Suite 9 

Hockessin, Delaware 19707 

P: 302.234.2780 

F; 302.234.7570 

www.wagnerreg.com 

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

From: Whitehurst.Janet@epamail.epa.gov 

[mailto:Whitehurst.Janet@epamail,epa.gov] 

Sent: Tuesday, January 19, 2010 3:03 PM 

TO: Catherine Byrd 

Subject: RE: 85678-U 

Dear Catherine, 

Thank you for your email. The similarity review for toxicity is 

completed pending an acceptable chemistry review. As we discussed on 

the phone, please provide updated labels to match the cited product. 

The due date for the Chemistry review is January 26. 

Once again, thanks for your quick response. 

Best regards, 

Janet 

From: 

To: 

Cc: 

"Catherine Byrd" <Catherine@wagnerreg.com> 

Janet Whitehurst/DC/USEPA/US@EPA 

"'James Wagner'" <james@wagnerreg.com> 

16
Date: 01/19/2010 02:17 PM 

Subject: RE: 85678-U 

Hi Janet, 

I wanted to verify that you have received everything that you need for 

this 

registration. Also, what is the PRIA date for this product? If you need 

any 

additional information, please let me know. 

Thank you, 

catherine 

Catherine M. Byrd 

Regulatory Associate 

P.O. Box 640 

7460 Lancaster Pike, Suite 9 

Hockessin, Delaware 19707 

P: 302.234.2780 

F: 302.234.7570 

www.wagnerreg.com 

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

From: Catherine Byrd [mailto:Catherine@wagnerreg.com] 

sent: wednesday, January 13, 2010 2:09 PM 

To: 'Whitehurst.Janet@epamail.epa.gov' 

cc: 'james@wagnerreg.com' 

Subject: RE: 85678-U 

Good afternoon Janet, 

we would like to "me too" Bayer Cropscience LP - Ethephon Manufacturing 

Concentrate (EPA Registration No. 264-838). I have attached a revised 

cover 

letter and EPA application. Hard copies will be mailed to your 

attention. 

please let me know if you need any additional information. 

Thank you, 

catherine M. Byrd 

Regulatory Associate 

P.O. Box 640 

7460 Lancaster Pike, Suite 9 

17
Hockessin. Delaware 1970-7 

P: 302.234.2780 

F: 302.234.7570 

www.wagnerreg.com 

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

From: Whitehurst.Janet@epamail.epa.gov 

[mailto:Whitehurst.Janet@epamail.epa.gov) 

Sent: Wednesday, January 13, 2010 1:06 PM 

To: catherine@wagnerreg.com 

Cc: Kish.Tony@epamail.epa.gov 

Subject: 85678-U 

Dear Ms. Byrd: 

As per our phone conversation, the subject application, submitted in 

connection with registration under the Federal Insecticide, Fungicide 

and Rodenticide Act as amended is not acceptable. The Agency has 

evaluated the formulations of the proposed product, 85678-U, and the 

cited product, 66330-369, and has determined that the two products are 

not substantially similar because the percentage of the active 

ingredient in the proposed product is higher then the cited product. 

Please correct and resubmit your application. If you have any 

questions, please contact Janet Whitehurst by phone at (703) 305-6129 or 

via email at whitehurst.janet@epa.gov. Thank you. 

Regards, 

Janet 

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Ethephon Manufacturing Concentrate Draft Labell·' 9·lD.pdf Ba~er Label.pdf 

19
( ,.,../ 1.)./ ~007 

U.S. ENVfRONMENTALPROTECfION APENCY 

Office ofPes;icide Programs 

Registntion DIvision (7S0SC) 

1200 Pennsylvania Ave., N.W. 

Washington, D.C. 20460 

NOTICE OF PESTICIDE: 

..x Registration 

. _' Reregistration (tinder FIFRA, as amended) 

Name and Address of Registrant (include ZIP. Code): 

Bayer CropScience 

P,O. Box 12014 

2 T. W. Alexander Drive 

( Il5 

EPA Reg.-Number: DllteofIsstlance: 

264-838 :DEC . J 2 20fJ[ 

Term of issuance: 

Conditional 

Name of Pesticide Product: 

Ethephon Manufacturing 

On the basis ofinfo~tion furnished by the registrant, the above named pesticide is bereby registered/reregistered under the Feder-Ii Insecticide, Fungicide 

and Rodenticide Act. 

Registration is in no way to be construed as an endorsement orrocommeodation of this product by the Agency. In ordcrto protect health and the 

environment, the AdminiSil1ltor, on his motion; may ut any time suspend orcancel the registl-iltion ora pesticide in accordance with the Act The acceptance 

orany name in connection with the registnltion ora product undcrthis Act is not to be construoo as giviog the regiSlT3Ilt a right to exelusive use of the name 

or to its use ifit has been covered by others. 

This product ~s conditionally registered in accordance with FIFRA section 3(cj(7)(A) provided 

that you: 

1. Submit and/or cite all data required for registration of your product under F.IFRA Section 

3( c)( 5) when the Agency requires all registrants of similar products to submit such data; and submit 

'acceptable responses required for reregistration of your product under FIFRA Section 4: 

2. Make the following label changes before you release the product for shipment: 

a. Revise the EPA Registration Number to read, "EPA Reg.No. 264-838." 

Slgtnl.tllre'nr Approving 0 ciaI(' n",te: 

Tony uct Manager (22) 

. Division 

20
1-'- - ------------

l ( 

Pag02 

EPA Reg. No. 264·837 

b. In the "IMPORTANT: READ BEFORE USE" section on page 3, at the start of the last 

sentence in the "DISCLAIMER OF WARRANTIES;" section and the start of the first sentence iIi the 

"LIMITATIONS OF LIABILITY:" section add "To the extent consistent with applicable law," 

3. Submit one copy of the revised final printed label for the Agency's records before you release 

the product for shipment. 

Ifthese conditions are not complied with, the registration wiII'be subject to cancellation, in 

accbrdance with FIFRA section 6(e). Your release for shipment of the product constitutes acceptance of 

these conditions. 

Attachments: Product label stamped "ACCEPTED With COMMENTS" 

Technical Review "BranchJProduct Chemistry and Acute Toxicology reviews 

21
( c 

ETH EPHON . Manufacturing 

Concentrate 

..3jS 

ACTIVE INGREDIENT: Ethephon [(2-chloroethyl) phosphonlc acid) ............... " ......... ,.. ........................ , ..••.•.•.•••. ",.77.5% 

INERT INGREDIENT: ........................ " ............ " ....... " .•...• " ..................... , ...................... ,,, ................. "" ........... , .. 22.5% 

EPA Reg. No. 264-XXX EPA Est. No. 264·PA-01 

KEEP OUT OF REACH OF CHILDREN 

DANGER 

PAECAUCION ,6.L USUARIO:.SI usted no lee Ingles, no usa esto producto hatt. q'ue ia otiqueta Ie haya sldo oxplicada 

ampllamento. • 

PRECAUTION TO THE USER: If you cannot road English, do not use this product until the label has been fully explained to you. 

_ Fo~ MEDICAL And TRANSPORTATION Emergencies.2NJ..Y Call 24 HoulS A Day 1-800-334-7577 

For PROgUCT USE InformaHon CaJI1~B88.99BAveR (1-8fJ6..992·293n 

IFIHEYf&. 

tF SWAI.I.OWED; 

IF ON SKIN OR . 

CLOTHING~ 

DANGER 

• HOld eye open and rinse slOlh1~ and gently v.i!h water for 15-20 minutes. 

• Remolle contact lenses, If present, aflerthe firnt5 minutes, then continue rinsing eye. 

; . 

• Immediately call a poison control center ordoctorfor trealmenl ad.vlce., 

• 00 not Induce vor:nitlng unless told 10 do so by a poison control center or dqctor. 

• Have pornon Sip a glass ot water If able to,swallow. 

• Take olf conlaminaled clothing. 

• Rinse skin Invn~iately with plenty of water for f5-20 minutes. 

For MEDtCAL emergancl&IJ Call 24 H oura A Day 1-800-334--7577. 

Consido'raliol) should be gillen to the po8sibillty that ovorexposure to malerials 

sp'8l;:ific antldote 1$ ava~able. Probable mlJCO$l1l damage may contralndicale the use 

PRECAUTIONARY STATEMENTS 

HAZARDS TO HUMANS AND DOMESTIC ANIMALS 

Corrosive. Caus;f!$ irreversible ~ye demago and skin bums. Harmful if swallow2d or abSOrbed throUgh skin, 00 not get In eyes, on 

skin or on clothing. Wear goggles or face shield. Wear protemlve clol1'llng and rubber glo\lO$. Wash thoroughlY with soap and water 

after handling .. Remova contamlnaled clothing and wash clothing before reuse. 

ENVIRONMENTAL HAZARDS 

Do not discharge emuanl containing this product into lakes, streams, ponds. estuaries, oceans or other waters unless In eccordance 

with the requlr~meill$ 01 a National Pollutant Discharge Eliminallon System (NPDES) pe.mn and the permiWng authority ha$ .been 

notified in writing prior to discharge. Do not discharge effluent containing this product to sewer systams without previOUSly notifying tho 

sewage treatment plant authority. For guidance' contact your State Water Board or Regionel Office ,of the Environmental Protection 

Agency. 

• • ••• .. , • • 

• • • • • 

••• • • • • .. • • • · • • • • • • 

• • • • • • • • • 

• • • • • 

• • • ... • • , ... .. • · • • • • .. • • • • • • .. .. , 

22
I ( 

.DIRECTIONS FOR .USE 

It 1& a VIolation 01 Foderal Law to usa this product In a mannor InCOIUlt.ten1 with ttslabollng. 

Road antlro label before using thla product., 

Elhephon ManufactUring Concentral~ must be slored ,and ,used in'ventilated areas only, 

Only For Form~lallon Into an End-Use Plant Gro~ Regulator, for(1) The Followlng'Uu{a); Terrestrial food uses on: apples, 

barley. blackberrias, canlaloupes, cherries (swao! and tart), coffeo beans, coiton, cucumbon; (hybrid lieDd production). graplis. peppers, 

pineapples, pumpkins (hybrid seed production), squash (hybrid seed produciion). sugarcane, tomatoes, walnuts and \\rtleat. Terrestrial 

non-food uses on: grass&S for sead producJion, ornamentals. tobacco (f1ulHlured) and mlsUoloo. 

2) Uses for Which USEPA has the Data Citations of Data that the Formulator has SubmItted In 

Support of Registration lind (3) In Compliance with USEPARequlrements. 

::~i~;~~:~2~:~:"'~I'~r;.IOOd. or feed by slorage or disposal. If conlainer is broken or conlents have spilled, follow aft precautions Before cleaning Up, ~ on lull.length trousers, long..sleeved shirt, prolectlve gloves and goggles or face 

abaortlent media such as sand, earth or other suitable malerial and dispose of wasle at an approved wasle 

Impropar disposal of excess pesticide, spray mixture, or rinsala Is a violation of Federal law . 

. i accorrling to label directions" or contact your State Pest!clde or Environmental Control 

at U'la nearest EPA Regional Office for guidance. 

DISPOSAL 

Triple , . 

DISCLAIMER AND INDEMNITY FOR FORMULATORS' USES 

THE MANUFACTURER EXPRESSLY DISCLAIMS AlL LIABILITY FOR CLAIMS AND ACTIONS (WHETHER BASED ON 

CONTRACT, TO~T, STRICT LlABIUTY OR BREACH OF WARRANTY) ARISING OUT OF, RESUtTlNG FROM OR CONNECreO 

WITH A FORMULATION CONTAINING THIS PRODUCT WHEN USED FOR ANY PURPOSE OTHER THAN THOSE USES SET 

FORTH IN (1) ABOVE. THE MANUFACTURER HAs NOT. DEVELOPED SCIENTIFIC DATA TO SUPPORT, NOR HAS IT 

EXPLICITLY OR IMPLICITL Y APPROVED~ ANY USES OTHER THAN THOSE IN (1) ABOVE. 

ANY FORMULATOR OR BUYER WHO USES THIS·PRODUCT IN FORMULATIONS FOR ANY USE OTHER THAN THOSE STATED 

IN (t) ABOVE ASSUMES All lIABilITY FOR CLAIMS AND ACTIONS ARISING OUT OF, CONNECTED WITH OR RESULTING 

•

FROM SUCH USE AND AGREES BY SO USING THIS PRODUCT TO INDEMNIFY AND HOLO HARMLESS THE ~NUFACTURER 

FROM SUCH CLAIMS AND ACTIONS. . 

THIS DISCLAIMER AND INDEMNITY fs IN ADDITION TO. NOT IN LIEU OF, THE· BELOW DISCLAIMER~D LIMITATIONS. 

23
( ( SiS 

IMPORTANT: READ BEFORE USE 

Read the e~tire Oir.ectlone for uSe. Conditions. Disclaimer of Wamilfl.1i8s and limitations of Uability before using this product If terms 

are nol acceplable, return the_unopened product conlainar at once, 

By using thi$. producl, useror buyer accepts !he folloWing Conditions, Disclaimer of Warranties and limitations of Uability. 

CONDITIONS: The directions for use of this product are believed to be adequate and shouk! be foRowed carefully. However, it is 

impossible to eliminate all risks associated with the use of this product. crop injury, looftectivenes& or other unintended consequences 

may result because Of such factors as weather conditions, presence of other materials, or the manner of USB Of application, aU of which 

are beyond the contrOl d BayerCropScience. All suCh r'lsks shall be assumed bylhe user or buyer. 

DISClAIMER OF WARRANTIES; BAYER CROPSCIENCE MAKES NO OTHER WARRANTIES, EXPRESS OR IMPliED. OF 

MERCHANTABILITY OR OF FITNESS FOR A I;'~TICULAR PURPOSE' OR OTHERWISE, THAT EXTEND BEYOND THE 

STATEMENTS MADE ON THIS LABEl. No agent of Bayer CropScience Is aulhorized 10 meke any warranties beyond ttlose contained 

herein or 10· modify the warranlies containod horoin. BAYER CROPSCIENCE DISCLAIMS ANY LIABILITY WHATSOEVER FOR 

SPECIAL, INCIDENTAL OR CONSEQUENTIAL DAMAGES RESULTING FROM THE USE OR HANDLING OF THIS PRODUCT. 

LIMITATIONS OF LlABIUTY: THE EXCLUSIVE REMEDY OF THE USER OR BUYER FOR ANY AND ALL LOSSEE!. INJURIES OR 

. DAMAGES RESULTING FROM THE USE OR HANDLING OF TI-IIS PRODUCT, WHETHER IN cqNTRACT, WARRANTY, TORT, 

NEGLIGENCE, STRICT LIABILITY OR OTHERWISE, SHALL NOT EXCEED THE PURCHASE PRICE PAID, OR AT BAYER 

.CROPSCI!=NCE'S ELECTION. THE REPLACEMENT OF PRODliCT . 

• 

• 

EEl Bayer Crop Science 

Bayer CropSclence LP 

P.O, Box 12014, 2 T.W. Alexander Drive 

Resesreh Tnangle Park, North Carolina 2T709 

t-8S6·99BAYER (1-866-992-2937) 

Etllephon Maflufacturlng Concentn:Jte (PENDING) Submitted 09/16104. 

3 

24
Active Ingredient: 

ETHEPHON 78% MUP 

Ethephon Manufacturing Concentrate DRAFT 

Rev.1f1912010 

Ethephon [(2-chloroethyl) phosphonic acid] ........................................... 77.6% 

Other Ingredients: ................................................. " ......................... 22.4% 

TOTAL: 100.00% 

EPA Reg. No. 85678- EPA Est. No. __ 

KEEP OUT OF REACH OF CHILDREN 

DANGER 

PRECAUCION AL USUARIO: Si usted no lee ingles, no use este producto hasta que la 

etiqueta Ie haya sido explicada ampliamente. 

PRECAUTION TO THE USER: If you cannot read English, do not use this product until the 

label has been fully explained to you. 

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 eye. 

• Cal! a poison control center or doc!orfor treatment advice. 

IfSwattowed • Immediately cal! a poison control center or doctor for treatment 

advice. 

• Do not induce vomiting unless told to do so by a poison control 

center or doctor. 

• Have person sip a glass of water if able to swattow. 

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

If on Skin or • Take off contaminated ctothing. 

Clothing: • Rinse skin immediately with plenty of water for 15"20 minutes. 

• Catt a poison control center or doctor for treatment advice. 

For medical emergencies involving this product, catt 1"800"222"1222 

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

qoinq for treatment. 

NOTE TO PHYSICtAN: Treat symptomaticatty. Consideration should be given to the possibility 

that overexposure to materials other than this product may have occurred. No specific antidote is 

avaitable. Probable mucosal damage may contraindicate the use of gastric lava!=le. 

For chemical emergency assistance (spit!, leak, fire, accident) cat! ChemTrec at 1"800424"9300. 

Manufactured for: 

Red Eagle International LLC 

1925 E. Edgewood Drive 

Lakeland, Florida 33803 

25
Ethephon Manufacturing Concentrate DRAFT 

Rev.1f19f2010 

PRECAUTIONARY STATEMENTS 

DANGER 

HAZARDS TO HUMANS AND DOMESTIC ANIMALS 

Corrosive. Causes irreversible eye damage and skin burns. Harmful if swallowed or absorbed through skin. Do 

not get in eyes, on skin or on clothing. Wear goggles or face shield. Wear protective clothing and rubber gloves. 

Wash thoroughly with soap and water after handling. Remove contaminated clothing and wash clothing before 

reuse. 

ENVIRONMENTAL HAZARDS 

Do not discharge effluent containing this product into lakes, streams, ponds, estuaries, oceans, or other waters 

unless in accordance w·lth 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 the sewage treatment plant authority. For guidance, 

contact your State Water Board or Regional Office of the Environmental Protection Agency. 

DIRECTIONS FOR USE 

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

before using this product. 

This product must be stored and used in ventilated areas only. 

Only For Formulation Into an End~Use Plant Growth Regulator, for (1) The Following Use(s): Terrestrial 

food uses on: apples, barley, blackberries, cantaloupes, cherries (sweet and tart), coffee beans, cotton, 

cucumbers (hybrid seed production), grapes, peppers, pineapples, pumpkins, (hybrid seed production), squash 

(hybrid seed production), sugarcane, tomatoes, walnuts and wheat. Terrestrial non~food uses on: grasses 

grown for seed production, ornamentals, tobacco (flu-cured) and mistletoe. 

(2) Uses for which USEPA has Accepted the Required Data andlor Citations of Data that the Formulator 

has Submitted in Support of Registration and (3) Uses for Experimental Purposes that are in Compliance 

with USEPA Requirements. 

STORAGE AND DISPOSAL 

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

PESTtCIDE STORAGE 

IF SPILLED: If container is broken or contents have spilled, follow all precautions indicated above and 

clean up immediately. Before cleaning up, put on full-length trousers, long-sleeved shirt, protective gloves 

and goggles or face shield. Soak up spill with absorbent media such as sand, earth or other suitable 

material and dispose of waste at an approved waste disposal facility. 

PESTICIDE DISPOSAL 

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

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

contact your State Pesticide or Environmental Control Agency or the Hazardous Waste representative at 

the nearest EPA Regional Office for guidance. 

CONTAINER DISPOSAL 

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

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

tank. Fill the container % full with water. Replace and tighten closures. Tip container on its side and roll it 

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

2 

26
Ethephon Manufacturing Concentrate DRAFT 

Rev. t/19/2010 

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

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

disposal. Repeat this procedure two more times. Offer for recyclina, if available. 

DISCLAIMER AND INDEMNITY FOR FORMULATORS' USES 

THE MANUFACTURER EXPRESSLY DISCLAIMS ALL LIABILITY FOR CLAIMS AND ACTIONS (WHETHER 

BASED ON CONTRACT, TORT, STRICT LIABILITY OR BREACH OF WARRANTY) ARISING OUT OF, 

RESULTING FROM OR CONNECTED WITH A FORMULATION CONTAINING THIS PRODUCT WHEN USED 

FOR ANY PURPOSE OTHER THAN THOSE USES SET FORTH IN (1) ABOVE. THE MANUFACTURER HAS 

NOT DEVELOPED SCIENTIFIC DATA TO SUPPORT, NOR HAS IT EXPLICITLY OR IMPLICITLY APPROVED, 

ANY USES OTHER THAN THOSE IN (1) ABOVE. 

ANY FORMULATOR OR BUYER WHO USES THIS PRODUCT IN FORMULATIONS FOR ANY USE OTHER 

THAN THOSE STATED IN (1) ABOVE ASSUMES ALL LIABILITY FOR CLAIMS AND ACTIONS ARISING OUT 

OF, CONNECTED WITH OR RESULTING FROM SUCH USE AND AGREES BY SO USING THIS PRODUCT 

TO INDEMNIFY AND HOLD HARMLESS THE MANUFACTURER FROM SUCH CLAIMS AND ACTIONS. 

THIS DISCLAIMER AND INDEMNITY IS IN ADDITION TO, NOT IN LIEU OF, THE BELOW DISCLAIMER AND 

LIMITATIONS. 

IMPORTANT: READ BEFORE USE 

Read the entire Directions for Use, Conditions, Disclaimer of Warranties and Limitations of Liability before using 

this product. If terms are not acceptable, return the unopened container at once. 

By using this product, user or buyer accepts the following Conditions, Disclaimer of Warranties and Limitations of 

Liability. 

CONDITIONS: The directions for use of this product are believed to be adequate and should be followed 

carefully. However, it is impossible to eliminate all risks associated with the use of this product. Crop injury, 

ineffectiveness or other unintended consequences may result because of such factors as weather conditions, 

presence of other materials, or the manner of use or application, all of which are beyond the control of RedEagle 

International LLC. All such risks shall be assumed by the user or buyer. 

DISCLAIMER OF WARRANTIES: RED EAGLE INTERNATIONAL LLC MAKES NO OTHER WARRANTIES, 

EXPRESS OR IMPLIED, OR MERCHANTABILITY OR OF FITNESS FOR A PARTICULAR PURPOSE OR 

OTHERWISE, THAT EXTEND BEYOND THE STATEMENTS MADE ON THIS LABEL. No agent of RedEagle 

International LLC is authorized to make any warranties beyond those contained herein or to modify the warranties 

contained herein. TO THE EXTENT CONSISTENT WITH APPLICABLE LAW, REDEAGLE INTERNATIONAL 

LLC DISCLAIMS ANY LIABILITY WHATSOEVER FOR SPECIAL, INCIDENTAL OR CONSEQUENTIAL 

DAMAGES RESULTING FROM THE USE OR HANDLING OF THIS PRODUCT. 

LIMITATIONS OF LIABILITY: TO THE EXTENT CONSISTENT WITH APPLICABLE LAW, RED EAGLE 

INTERNATIONAL LLC THE EXCLUSIVE REMEDY OF THE USER OR BUYER FOR ANY AND ALL LOSSES, 

INJURIES OR DAMAGES RESULTING FROM THE USE OR HANDLING OF THIS PRODUCT, WHETHER IN 

CONTRACT, WARRANTY, TORT, NEGLIGENCE, STRICT LIABILITY OR OTHERWISE, SHALL NOT EXCEED 

THE PURCHASE PRICE PAID, ORAT REDEAGLE INTERNATIONAL LLC ELECTION, THE REPLACEMENT 

OF PRODUCT. 

3 

27
to Janet 

Jeanne Kasai to: JanetWhitehurst 

Hi JanetBelow are the correct comments for EPA Reg. #85678-U (Ethephon 78% MUP). 

Sorry again for the confusion. 

Jeanne Kasai 

EPA - Office of Pesticide Programs 

tel. 703-308-3240 fax 703-308-2962 

http://www.epa.gov/pesticidesiregulating/containers.htm 

AAAAAAAAAAAAAAAAAAAAAAAAAAAAAAAAAAAAAAAAAAAAAAAAAA 

--- Forwarded by Jeanne Kasai/DC/USEPA/US on 02/16/2010 04:22 PM ----

From: 

To: 

Cc: 

Date: 

Subject 

Hi JanetJeanne Kasai/DC/USEPA/US 

Janet WhitehurstiDClUSEPA/US@EPA 

Nancy FitzlDC/USEPA/US@EPA 

01/201201002:28 PM 

EPA Reg. No. 85678 - (Ethephon 78% MUP) 

02/16/20 to 04:23 PM 

Here are my comments on the Pesticide Storage & Disposal section of the label for EPA Reg. 

#85678 - ? (Ethephon 78% MUP) 

1) PESTICIDE STORAGE 

It appears that this label lacks instructions on pesticide storage. I am not sure which ones you 

would want to choose from Chapter 13 of the Label Review Manual (LRM). Maybe you could 

discuss this & choose with the registrant? 

2) IF SPILLED 

I cannot comment on that. It is not in the purview of the container-containment regulations, and 

I don't know where to find those instructions! 

3) PESTICIDE DISPOSAL 

The language used is acceptable as it is taken from Chapter 13 of the LRM. 

4) CONTAINER DISPOSAL 

This is an MUP - so it is probably NOT dilutable. Is that correct? "Dilutable" means that the 

product is to be mixed with water (by the applicator or end user) or a diluent prior to use. 

28
40 CFR 156.146 requires residue removal instructions for dilutable pesticides in rigid, 

nonrefillable containers. Therefore - if it is NOT dilutable and it is in a rigid, nonrefillable 

container, residue removal instructions are NOT required, and the text under this section would 

read: 

"Nonrefillable container. Do not reuse or refill this container. Offer for recycling, if available." 

If it IS dilutable, then the text they have is acceptable for containers too large to shake. 

(Please note that residue removal instructions are required on all refillable containers whether 

or not the product is dilutable.) 

Hope this is helpful! Let me know if you have any questions! 

THANKS! 

Jeanne 

Jeanne Kasai 

EPA - Office of Pesticide Programs 

teL 703-308-3240 fax 703-308-2962 

http://www.epa.gov/pesticides/regulating/containers.htm 

AAAAAAAAAAAAAAAAAAAAAAAAAAAAAAAAAAAAAAAAAAAAAAAAAA 

29
FEDERAL EXPRESS 

August 3, 2009 

Document Processing Desk (REG FEE) 

A TIN: Tony Kish PM 22 

Registration Division (7504P) 

u.s. Environmental Protection Agency 

Room' S-4900, One Potomac Yard 

2777 South Crystal Drive 

Arlington, Virginia 22202-4501 

Dear Mr. Kish; 

47820S-00 

Wagner Regulatory Associates, Inc. 

P.O. Box 640 

7460 Lancaster Pike, Suite 9 

Hockessin, Delaware 19707 

Re: Application to register a new product containing a currently registered active ingredient-

"Ethephon 78% MUP" 

Wagner Regulatory Associates, Inc., as agent for RedEagJe International LLC, is requesting registration 

of the above referenced product. This product is substantially similar to the ethephon product registered 

by Arysta LifeScience North America, LLC under EPA Registration Number 66330-369. 

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

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

agent 

• Application for Pesticide Registration (8570-1) 

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

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

• Data Matrix (8570~35) 

• Data Transmittal Document 

• Product Identity and Composition data (3 copies) as outlined in the transmittal document 

• Physical and Chemical Properties data (3 copies) as outlined in the transmittal document 

• Preliminary Analysis data (3 copies) as outlined in the transmittal document 

• Draft labeling, 5 copies 

• For "rne:.too" product labeling, please refer to the EPA approved label for Registration Number 

66330-369. 

• A copy of the receipt confirming payment of the required registration fees. 

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

Respectfully submitted, 

~71L&;nL Catherine M. Byrd 

Agent for RedEagle International LLC 

Enclosures 

30
DATA TRANSMITTAL DOCUMENT 

1. Name and Address of Submitter 

Red Eagle International LLC 

c/o Wagner Regulatory Associates 

PO Box 640 

Hockessin. DE 19707 

2. Regulatory Action In Support Of Which This Package Is Submitted 

Ethephon 78% MUP 

EPA Registration Number: 85678-

3. Transmittal Date 

July 31.2009 

4. List of Submitted Studies 

47820801 

47820802 

47820803 

47820804 

Vol. 1: Weiler, Paul J. (2008) "Group B Product Chemistry for 75% 

Ethephon, Physical and Chemical Properties Testing~ Midwest 

Research Institute, Kansas City, Missouri. Project Number 

310810.1.002.13 pages. 

Vol. 2: Sun, Gang. (2009) "Preliminary Analysis of Ethephon Technical 

Grade Active Ingredient" Southwest Research Institute, San 

Antonio, Texas, Project Number 01.12763.02.001. Non-confidential 

port'icns 20 pages, Confidential portions 20 pages. 

Vol. 3: RedEagle International LLC. (2009) "Ethephon 78% MUP Product 

Identity and Composition, Description of Materials Used to Produce 

the Product, Description of the Production Process, Description of 

the Formulation Process and Discussion of Formation of 

Impurities~ Non~confidential portion 6 pages, Confidential portion 

43 pages. 

Vol. 4: Wagner, James M. (2009) "Ethephon 78% MUP Product Chemistry 

Data Waiver~ 4 pages. 

Company Official: 

Company Name: 

Catherine M. Byrd 

Name 

Wagner Regulatory AssOCiates, Inc. 

Agent for RedEagle International LLC 

Company Contact: 

Catherine M. Byrd (302) 234-2780 

Name Phone 

31
• To: 

Cc: 

Bee: 

Akiva Abramovilch/DC/USEPAlUS, 

Subject: Your Application for EPA Registration 85678-U 

Dear Catherine, 

In the process of reviewing the chemistry data for the subject registration request we have determined that 

you need to correct and resubmit the CSF. To correct your CSF, please list on the CSF the following 

impurities of toxicological significance: You may resubmit your 

CSF electronically to me and copy Akiva Abramovitch above. 

If you have any questions or need further information, please do not hesitate to contact me or Akiva. 

Thank you. 

Regards, 

Janet 

--. Forwarded by Janet WhitehurstlDC/USEPA/US on 01/21/2010 03:58 PM .----

From: 

To: 

Cc: 

Date: 

Subject: 

"Catherine Byrd" <Cather'lne@wagnerreg.com> 

Janet WhitehurstlDC/USEPAlUS@EPA 

<iames@wagnerreg.com> 

01/131201002:09 PM 

RE: 85678-U 

Good afternoon Janet, 

We would like to "me too" Bayer Cropscience LP - Ethephon Manufacturing 

Concentrate (EPA Registration No. 264-838). I have attached a revised cover 

letter and EPA application. Hard copies will be mailed to your attention. 

please let me know if you need any additional information. 

Thank you, 

catherine M. Byrd 

Regulatory Associate 

P.O. Box 640 

7460 Lancaster Pike, Suite 9 

Hockessin, Delaware 19707 

P: 302.234.2780 

F: 302.234.7570 

www.wagnerreg.com 

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

From: Whitehurst.Janet@epamail.epa.gov 

[mailto:Whitehurst.Janet@epamail.epa.gov] 

Sent: Wednesday, January 13, 2010 1:06 PM 

To: catherine@wagnerreg.com 

Cc: Kish.Tony@epamail.epa.gov 

subject: 85678-U 

Dear Ms. Byrd: 

32 *Manufacturing process information may be entitled to confidential treatment*
As per our phone conversation, the subject application, submitted in 

connection with registration under the Federal Insecticide, Fungicide 

and Rodenticide Act as amended is not acceptable. The Agency has 

evaluated the formulations of the proposed product, 85678-U, and the 

cited product, 66330-369, and has determined that the two products are 

not substantially similar because the percentage of the active 

ingredient in the proposed product is higher then the cited product. 

please correct and resubmit your application. If you have any 

questions, please contact Janet Whitehurst by phone at (703) 305-6129 or 

via email at whitehurst.janet@epa.gov. Thank you. 

Regards, 

Janet 

"it 

Ethephon 78% MUP Letter 1·12·10.pdf 

33
Southwest Research Institute 

Final Report: 

Preliminary Analysis ofEfuephon TGAI 

31of40pages 

Project Number 01.12763.02.001 

GLP-SP-OS8 

Table 4. PuritylImpurity Test Results from Five Lots of Ethephon TGAI 

34

*Manufacturing process information may be entitled to confidential treatment*
Hi Jeanne, 

Storage and Disposal: Fw: 85678-U 

Janet Whitehurst to: Jeanne Kasai 

Cc: Nancy Fitz 

Attached please find the attached label amendment per PR Notice 2007~4. 

Your comments would be very much appreciated. 

Thanks! 

Janet 

~ Elhephon Manufacturing Concentrate Draft label 1·19·' O.pdf 

~".- Forwarded by Janel WhitehurstfDC/USEPAJUS on 01/19/2010 05:07 PM ----

From: 

To; 

Dale: 

Subject: 

Hi Janet, 

"Catherine Byrd" <Catherine@wagnerreg.com> 

Janet WhitehurstfDC/USEPNUS@EPA 

01/19/201004:48 PM 

RE: 85678-U 

01/19/201005:15 PM 

I have attached a revised label and the "me too" label for Bayer Ethephon 

Manufacturing Concentrate (EPA Reg No. 264-838). I revised the storage and 

disposal language to ref-lect PR Notice 2007-4. I hope this is okay. Please 

let me know if you need any additional information. 

Thank you, 

Catherine 

Catherine M. Byrd 

Regulatory Associate 

P.O. Box 640 

7460 Lancaster Pike, Suite 9 

Hockessin, Delaware 19707 

P: 302.234.2780 

F; 302.234.7570 

www.wagnerreg.com 

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

From: Whitehurst.Janet@epamail.epa.gov 

[mailto:Whitehurst.Janet@epamail.epa.gov] 

Sent: Tuesday, January 19, 2010 3;03 PM 

To: Catherine Byrd 

Subject: RE: 85678-U 

Dear Catherine, 

35
Thank you for your email. The similarity review for toxicity is 

completed pending an acceptable chemistry review. As we discussed on 

the phone, please provide updated labels to match the cited product. 

The due date for the Chemistry review is January 26. 

Once again, thanks for your quick response. 

Best regards, 

Janet 

From: 

To: 

Cc: 

Date: 

Subject: 

Hi Janet, 

"Catherine Byrd" <Catherine@wagnerreg.com> 

Janet Whitehurst/DC/USEPA/US@EPA 

"'James Wagner'" <james@wagnerreg.com> 

01/19/2010 02:17 PM 

RE: 85678-U 

I wanted to verify that you have received everything that you need for 

this 

registration. Also, what is the PRIA date for this product? If you need 

any 

additional information, please let me know. 

Thank you, 

Catherine 

Catherine M. Byrd 

Regulatory Associate 

P.O. Box 640 

7460 Lancaster Pike, Suite 9 

Hockessin, Delaware 19707 

P: 302.234.2780 

F: 302.234.7570 

www.wagnerreg.com 

36
-----original Message-----

From: catherine Byrd [mailto:Catherine@wagnerreg.com] 

Sent: wednesday, January 13, 2010 2:09 PM 

To: 'whitehurst.Janet@epamail.epa.gov' 

Cc: 'james@wagnerreg.com' 

Subject: RE: 85678-U 

Good afternoon Janet, 

We would like to "me too" Bayer Cropscience LP - Ethephon Manufacturing 

Concentrate (EPA Registration No. 264~838). I have attached a revised 

cover 

letter and EPA application. Hard copies will be mailed to your 

attentiori. 

Please let me know if you need any additional information. 

Thank you, 

Catherine M. Byrd 

Regulatory Associate 

P.O. Box 640 

7460 Lancaster Pike, Suite 9 

Hockessin, Delaware 19707 

P: 302.234.2780 

F: 302.234.7570 

www.wagnerreg.com 

-----original Message-----

From: whitehurst.Janet@epamail.epa.gov 

[mailto:Whitehurst.Janet@epamail.epa.gov] 

Sent: wednesday, January 13, 2010 1:06 PM 

To: catherine@wagnerreg.com 

Cc: Kish.Tony@epamail.epa.gov 

Subject: 85678-U 

Dear Ms. Byrd: 

As per our phone conversation, the subject application, submitted in 

connection with registration under the Federal Insecticide, Fungicide 

and Rodenticide Act as amended is not acceptable. The Agency has 

evaluated the formulations of the proposed product, 85678-U, and the 

cited product, 66330-369, and has determined that the two products are 

not substantially similar because the percentage of the active 

ingredient in the proposed product is higher then the cited product. 

please correct and resubmit your application. If you have any 

questions, please contact Janet Whitehurst by phone at (703) 305-6129 or 

via email at whitehurst.janet@epa.gov. Thank you. 

Regards, 

Janet 

signature 

Information from ESET NOD32 Antivirus, version of virus 

database 4768 (20100113) 

The message was checked by ESET NOD32 Antivirus. 

37
) 

http://www.eset.com 

Information from ESET NOD32 Antivirus, version of virus 

signature 

database 4772 (20100114) 

The message was checked by ESET NOD32 Antivirus. 

http://www.eset.com 

Information from ESET NOD32 Antivirus, version of virus 

signature 

database 4784 (20100118) 

The message was checked by ESET NOD32 Antivirus. 

http://www.eset.com 

Information from ESET NOD32 Antivirus, version of virus 

signature 

database 4784 (20100118) 

The message was checked by ESET NOD32 Antivirus. 

http://www.eset.com 

Information from ESET NOD32 Antivirus, version of virus signature 

database 4787 (20100119) 

The message was checked by ESET NOD32 Antivirus. 

http://www.eset.com 

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database 4787 (20100119) 

The message was checked by ESET NOD32 Antivirus. 

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Ethephon Manufacturing Concentrate Draft Labell-19-10.pdf Bayer Label.pdf 

38
Hi Janet, 

RE: 85678-U 

Catherine to', Janet Whitehurst 01/19/201004',48 PM 

I have attached a revised label and the "me too" label for Bayer Ethephon 

Manufacturing Concentrate (EPA Reg No. 264-838). I revised the storage and 

disposal language to reflect PR Notice 2007-4. I hope this is okay. please 

let me know if you need any additional information. 

Thank you, 

Catherine 

Catherine M. Byrd 

Regulatory Associate 

P.O. Box 640 

7460 Lancaster Pike, Suite 9 

Hockessin, Delaware 19707 

P: 302.234.2780 

F: 302.234.7570 

www.wagnerreg.com 

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

From: Whitehurst.Janet@epamail.epa.gov 

[mailto:Whitehurst.Janet@epamail.epa.gov) 

Sent: Tuesday, January 19, 2010 3:03 PM 

To: Catherine Byrd 

Subject: RE: 85678-U 

Dear Catherine, 

Thank you for your email. The similarity review for toxicity is 

completed pending an acceptable chemistry review. As we discussed on 

the phone, please provide updated labels to match the cited product. 

The due date for the Chemistry review is January 26. 

Once again, thanks for your quick response. 

Best regards, 

Janet 

From: 

To: 

Cc: 

"Catherine Byrd" <Catherine@wagnerreg.com> 

Janet Whitehurst/DC/USEPA/US@EPA 

"'James Wagner'" <james@wagnerreg.com> 

39
Date; 01/19/2010 02;17 PM 

Subject; RE: 85678~U 

Hi Janet, 

I wanted to verify that you have received everything that you need for 

this 

registration. Also, what is the PRIA date for this product? If you need 

any 

additional information, please let me know. 

Thank you, 

Catherine 

Catherine M. Byrd 

Regulatory Associate 

P.O. Box 640 

7460 Lancaster Pike, Suite 9 

Hockessin, Delaware 19707 

P; 302.234.2780 

F; 302.234.7570 

www.wagnerreg.com 

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

From: Catherine Byrd [mailto:Catherine@wagnerreg.com] 

Sent: wednesday, January 13, 2010 2:09 PM 

To; 'Whitehurst.Janet@epamail.epa.gov' 

Cc: 'james@wagnerreg.com' 

Subject: RE£ 85678-U 

Good afternoon Janet, 

We would like to "me too" Bayer Cropscience LP - Ethephon Manufacturing 

Concentrate (EPA Registration No. 264-838). I have attached a revised 

cover 

letter and EPA application. Hard copies will be mailed to your 

attention. 

Please let me know if you need any additional information. 

Thank you, 

Catherine M. Byrd 

Regulatory Associate 

P.O. Box 640 

7460 Lancaster Pike, Suite 9 

Hockessin, Delaware 19707 

P: 302.234.2780 

40
F: 302.234.7570 

www.wagnerreg.com 

-----original Message-----

From: whitehurst.Janet@epamail.epa.gov 

[mailto:Whitehurst.Janet@epamail.epa.gov] 

Sent; wednesday, January 13, 2010 1:06 PM' 

To: catherine@wagnerreg.com 

Cc: Kish.Tony@epamail.epa.gov 

Subject: 85678-U 

Dear Ms. Byrd: 

As per our phone conversation, the subject application, submitted in 

connection with registration under the Federal Insecticide, Fungicide 

and Rodenticide Act as amended is not acceptable. The Agency has 

evaluated the formulations of the proposed product, 85678-U, and the 

cited product, 66330-369, and has determined that the two products are 

not substantially similar because the percentage of the active 

ingredient in the proposed product is higher then the cited product. 

Please correct and resubmit your application. If you have any 

questions, please contact Janet Whitehurst by phone at (703) 305-6129 or 

via email at whitehurst.janet@epa.gov. Thank you. 

Regards, 

Janet 

signaturE! 

Information from ESET NOD32 Antivirus, version of virus 

database 4768 (20100113) 

The message was checked by ESET NOD32 Antivirus. 

http://www.eset.com 

Information from ESET NOD32 Antivirus, version of virus 

signature 

database 4772 (20100114) 

The message was checked by ESET NOD32 Antivirus. 

http://www.eset.com 

Information from ESET NOD32 Antivirus, version of virus 

signature 

database 4784 [20100118) 

The message was checked by ESET NOD32 Antivirus. 

http://www.eset.com 

Information from ESET NOD32 Antivirus, version of virus 

signature 

41
database 4784 (20100118) 

The message was checked by ESET NOD32 Antivirus. 

http;//www.eset.com 

Information from ESET NOD32 Antivirus, version of virus signature 

database 4787 (20100119) 

The message was checked by ESET NOD32 Antivirus. 

http;//www.eset.com 

Information from ESET NOD32 Antivirus, version of virus signature 

database 4787 (20100119) 

The message was checked by ESET NOD32 Antivirus. 

http;//www.eset.com 

Ethe,ctlon M amiacturing Concentrate Draft Label 1·19·1 O.pdf Bs),er Labei.pdf 

42
Active Ingredient: 

ETHEPHON 78% MUP 

Ethephon Manufacturing Concentrate DRAFT 

Rev, 1/19/2010 

Ethephon [(2-chloroethyl) phosphonic acid] ........................................... 77.6% 

Other Ingredients: ................................................. " ......................... 22.4% 

TOTAL: 100.00% 

EPA Reg. No. 85678- EPA Est. No .. __ 

KEEP OUT OF REACH OF CHILDREN 

DANGER 

PRECAUCION AL USUARIO: Si usled no lee ingles, no use este producto hasta que la 

etiqueta Ie haya side explicada ampliamente. 

PRECAUTION TO THE USER: If you cannot read English, do not use this product until the 

label has been fully explained to you. 

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 eye. 

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

If Swallowed • Immediately call a poison control center or doctor for treatment 

advice. 

• Do not induce vomiting unless told to do so by a poison control 

cenler or doctor. 

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

• Do not Qive anvthing by mouth to an unconscious person, 

If on Skin or • Take off contaminated clothing. 

Clothing: • Rinse skin immediately with plenty of water for 15-20 minutes. 

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

For medical emergencies involving this product, call 1-800-222-1222 

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

qoinq for treatment. 

NOTE TO PHYSICIAN: Treat symptomatically. Consideration should be given to the possibilny 

that overexposure to materials other than this product may have occurred. No speCific antidote is 

available. Probable mucosal damage may contraindicate the use of gastric lava!=le. 

For chemical emergency assistance (spill, leak, fire, aCCident) call ChemTrec at 1-800-424-9300. 

Manufactured for: 

Red Eagle International LLC 

1925 E. Edgewood Drive 

Lakeland, Florida 33803 

I 

43
Ethephon Manufacturing Concentrate DRAFT 

Rev, 1/19/2010 

PRECAUTIONARY STATEMENTS 

DANGER 

HAZARDS TO HUMANS AND DOMESTIC ANIMALS 

Corrosive. Causes irreversible eye damage and skin burns. Harmful if swallowed or absorbed through skin. Do 

not get in eyes, on skin or on clothing. Wear goggles or face shield. Wear protective clothing and rubber gloves. 

Wash thoroughly with soap and water after handling. Remove contaminated clothing and wash clothing before 

reuse. 

ENVIRONMENTAL HAZARDS 

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 the sewage treatment plant authority. For guidance, 

contact your State Water Board or Regional Office of the Environmental Protection Agency. 

DIRECTIONS FOR USE 

It 'IS a violation of Federal law to use this product in a manner inconsistent with its labeling. Read entire label 

before using this product. 

This product must be stored and used in ventilated areas only. 

Only For Formulation Into an End·Use Plant Growth Regulator, for (1) The Following Use(s): Terrestrial 

food uses on: apples, barley, blackberries, cantaloupes, cherries (sweet and tart), coffee beans, cotton, 

cucumbers (hybrid seed production), grapes, peppers, pineapples, pumpkins, (hybrid seed production), squash 

(hybrid seed production), sugarcane, tomatoes, walnuts and wheat. Terrestriat non·food uses on: grasses 

grown for seed production, ornamentals, tobacco (flu-cured) and mistletoe. 

(2) Uses for which USEPA has Accepted the Required Data and/or Citations of Data that the Formulator 

has Submitted in Support of Registration and (3) Uses for Experimental Purposes that are in Compliance 

with USEPA Requirements. 

STORAGE AND DISPOSAL 

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

PESTICIDE STORAGE 

IF SPtLLED: If container is broken or contents have spilled, follow all precautions indicated above and 

clean up immediately. Before cleaning up, put on full·length trousers, long·sleeved shirt, proteCtive gloves 

and goggles or face shield. Soak up spill with absorbent media such as sand, earth or other suitable 

material and dispose of waste at an approved waste disposal facility. 

PESTICIDE DISPOSAL 

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

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

contact your State Pesticide or Environmental Control Agency or the Hazardous Waste representative at 

the nearest EPA Regional Office for guidance. 

CONTAINER DISPOSAL 

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

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

tank. Fill the container X full with water. Replace and tighten closures. Tip container on its side and roll it 

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

2 

44
Ethephon Manufacturing Concentrate DRAFT 

Rev. 111912010 

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

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

disposal. Repeat th'ls procedure two more times. Offer for recyciinQ, if available. 

DISCLAIMER AND INDEMNITY FOR FORMULATORS' USES 

THE MANUFACTURER EXPRESSLY DISCLAIMS ALL LIABILITY FOR CLAIMS AND ACTIONS (WHETHER 

BASED ON CONTRACT, TORT, STRICT LIABILITY OR BREACH OF WARRANTY) ARISING OUT OF, 

RESULTING FROM OR CONNECTED WITH A FORMULATION CONTAINING THIS PRODUCT WHEN USED 

FOR ANY PURPOSE OTHER THAN THOSE USES SET FORTH IN (1) ABOVE. THE MANUFACTURER HAS 

NOT DEVELOPED SCIENTIFIC DATA TO SUPPORT, NOR HAS IT EXPLICITLY OR IMPLICITLY APPROVED, 

ANY USES OTHER THAN THOSE IN (1) ABOVE. 

ANY FORMULATOR OR BUYER WHO USES THIS PRODUCT IN FORMULATIONS FOR ANY USE OTHER 

THAN THOSE STATED IN (1) ABOVE ASSUMES ALL LIABILITY FOR CLAIMS AND ACTIONS ARISING OUT 

OF, CONNECTED WITH OR RESULTING FROM SUCH USE AND AGREES BY SO USING THIS PRODUCT 

TO INDEMNIFY AND HOLD HARMLESS THE MANUFACTURER FROM SUCH CLAIMS AND ACTIONS. 

THIS DISCLAIMER AND INDEMNITY IS IN ADDITION TO, NOT IN liEU OF, THE BELOW DISCLAIMER AND 

LIMITATIONS. 

IMPORTANT: READ BEFORE USE 

Read the entire Directions for Use, Conditions, Disclaimer of Warranties and Limitations of Liability before using 

this product. If terms are not acceptable, return the unopened container at once. 

By using this product, user or buyer accepts the following Conditions, Disclaimer of Warranties and Limitations of 

Liability. 

CONDITIONS: The directions for use of this product are believed to be adequate and should be followed 

carefully. However, it is impossible to eliminate all risks associated with the use of this product. Crop injury, 

ineffectiveness or other unintended consequences may result because of such factors as weather conditions, 

presence of other materials, or the manner of use or application, all of which are beyond the control of RedEagle 

International LLC. All such risks shall be assumed by the user or buyer. 

DISCLAIMER OF WARRANTIES: REDEAGLE INTERNATIONAL LLC MAKES NO OTHER WARRANTIES, 

EXPRESS OR IMPLIED, OR MERCHANTABiliTY OR OF FITNESS FOR A PARTICULAR PURPOSE OR 

OTHERWISE, THAT EXTEND BEYOND THE STATEMENTS MADE ON THIS LABEL. No agent of RedEagle 

International LLC is authorized to make any warranties beyond those contained herein or to modify the warranties 

contained herein. TO THE EXTENT CONSISTENT WITH APPLICABLE LAW, REDEAGLE INTERNATIONAL 

LLC DISCLAIMS ANY LIABILITY WHATSOEVER FOR SPECIAL, INCIDENTAL OR CONSEQUENTIAL 

DAMAGES RESULTING FROM THE USE OR HANDLING OF THIS PRODUCT. 

LIMITATIONS OF LIABILITY: TO THE EXTENT CONSISTENT WITH APPLICABLE LAW, REDEAGLE 

INTERNATIONAL LLC THE EXCLUSIVE REMEDY OF THE USER OR BUYER FOR ANY AND ALL LOSSES, 

INJURIES OR DAMAGES RESULTING FROM THE USE OR HANDliNG OF THIS PRODUCT, WHETHER IN 

CONTRACT, WARRANTY, TORT, NEGLIGENCE, STRICT LIABILITY OR OTHERWISE, SHALL NOT EXCEED 

THE PURCHASE PRICE PAID, OR AT RED EAGLE INTERNATIONAL LLC ELECTION, THE REPLACEMENT 

OF PRODUCT. 

3 

45
( /,;../ /.)--/ .l.007 

U.S. ENVIRONMENTAL PROTECTION AGENCY 

Office ofP~icide Programs 

Registmtion Division (7S05C) 

1200 PennsyJvmia Ave., N.W. 

Washington, D.C. 20460 

NOTICE OF PESTICIDE: 

..x Registration 

. . _' Reregistration (under FTFRA, as amended)· . 

Nunc and Address of Registrant (include ZIP Code): 

Bayer CropScience 

p,o. Box 12014 

2 T. W. Alexander Drive 

( Il5 

EPA Reg,"Number: DateofIssuance: 

264·838 DEC 1 2 201J! 

Termorissuance: 

Conditional 

Nameof Pesticide Product: 

Ethephon Manufacturing 

On the basis of infonJ¥lfion furnished by the registrant, the above named pesticide is hereby registerOOfreregistered undertbe Federal inse<::ucide, Fungicide 

and Rodenticide Act. 

Registration is in no way to be construed as an endolSo::ment orrccommendation of this product by the Agency. In ordcrto protect health and the 

environment, theAdministn.tor, on his motioll, nmy at any time suspend oreaned the registration ora pesticid.e in accordauce with the Act The acceptance 

orany name in connection with the registration ofa product under this Act is not to be constnlOO as giving the regiSll'lInt a right 10 exclusive usc ofthe name 

or to its use ifit has beeo covered by others. 

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

that you: 

1. Submit and/or cite all data required for registration of your product under F.rFRA Section 

3(c)(5) when the Agency requires all registrants of similar products to submit such data; and submit 

.·acceptable responses required for reregistration of your product under FIFRA Section 4: 

2. Make the following label changes before you release the product for shipment: 

a. Revise the EPA Registration Number to read, "EPA Reg.No. 264·838." 

Date: 

Tony 

46
- ------------

) ( '( 

Page 2 

EPA Reg. No. 264-837 

h. In the "IMPORTANT: READ BEFORE USE" section on page 3, at the start of the last 

sentence in the "DISCLAIMER OF WARRANTIES:" section and the start of the first sentence in the 

"LIMITATIONS OF LIABILITY:" section add "To the extent consistent with applicable law," 

3. Submit one copy of the revised fmal printed label for the Agency's records before you release 

the product for shipment. 

If these conditions -are not complied with, the registration will be subject to cancellation, in 

accordance with FIFRA section 6(e). Your release for shipment of the product constitutes acceptance of 

these conditions. 

Attachments: Product label stamped "ACCEPTED with COMMENTS" 

Technical Review -BranchIProduct Chemistry and Acute Toxicology reviews 

47
( ( 

ETHEPHON. Manufacturing 

Concentrate 

3jS 

ACTIVE IttGREDIENT: Eth~phon [(2~chloroelhyl) phosphonlcacidJ ." ................................................................. , .• 77.5% 

. . . . .. .... .. 

KEEP OUT OF REACH OF CHILDREN 

DANGER 

PRECAUCION AL USUARIO: Si lISted no lee Ingles, no use este producto haste qua la otlqueta Ie haya sido explicada 

ampllamente. 

PRECAUT10N TO TME USER: If you cannot read English, do not us. thIs product until lhe label has; been fully explained to you. e FO~ MEDICAL And TBANSPQRTADO.N Emergencies miLY Call z4 Hou~ A Day 1·800-334~7577 

For PRODUCT USE Infonnatlon CalI1~868.99BAYER (1 ~86a..992~293n 

~AID 

IFIN EYES: • Hold eye open and rinso SIoW!~ and gently....nth waler for 15-~ minutes. 

• Remove contact tenses, If present. ofter tna flmt 5 mInutes, then continue rinsing eye. 

C.II, . , ""'''0' ""nle" 

IF SWAI..1.0WEO: • Immediately call a poison control center or doctor for tteabnent advice .. 

• 00 not Induce vomiting unless told to do so by a poison control center or dqctor. 

• H.we person sip a glass of water If able to.swaRow. 

I. 0o nol 0;" , , , o"oon. 

IF ON SKIN OR . • Take off contaminated clothing. 

CLOtHING: 

• Rinse skin ImmedlatelyWith plenty of water for 15-20 minutes. 

C ••• 00;'0. • ".00 .. For MEDICAl. Emetgoncleo Call 24 HouraA Day 1-80Q..334..7577. 

• th, " WIth .III~' , "",,,,,, , 0<>1 • 

, , r",al , to the possibility that overexpCI$um to materials . Probable mucosal damage may contraindicate the use 

·;"""a, 

PRECAUTIONARY STATEMENTS 

DANGER 

fjAZARDS TO HUMANS AND DOMESTIC ANIMALS 

Corrosive. Causes irreversible ~YII demage end skin bums. Harmful if swallowed or sbsorbed through skin, Do not get In eyes, on 

skin Of on clothing. Wear goggll$ or face shiold. Wear protective clothing end rubber gloves. Wash thoroughly with soap and water 

after handling. Remove contaminaled clothing and wash dothing bafore reuse. 

ENVIRONMENTAL HAZARDS 

Do not discharge effluent containIng this product into lakes, streams, ponds, estuaries, oceal\$ or other waters unless in accordance 

with the requirements of a National Pollutant Dlscha.1'JB Eliminalion System (NPOES) permit and the perrniWng aulhority has .been 

notified in writing prior to discharge. Do not discharge effluent contaIning this product to aewer systems without previously notifying the 

sewage treatment plant authority. For guidance· contact your Stale Water Board or Regional Offico .of the Environmental Protection 

Agency. 

ACCEPtED _ COIIIMENTS 

In EPA ~ Dated 

DEC 1 2 2007 

• • ••• • • 

• • 

• • • • • • • • • 

U ............... "nsrthHs, 

I'm#! l"'adBaa :! 'hAc 

.. _l1li." lor tIM ,rrthillo 

~""".EPA"No. 

~-.--- J,M- 83 !' 

••• 

• • 

• • • • • 

• • • • ••• • • • 

• • • • 

••• • • • • 

• • • • • • • 

• • • • • • 

• 

, ••• • •• • •• · 

• • •• ••• 

48
I. 

, i ( l( 

.DIRECTIONS FOR .uSE 

It's a VIolation, of Federal Law to utle this pntduct In" manner InCO!'lllli1ltont: WIth ita labeling. 

Road entire la!)el beforellalng this product., 

Ethe!tloh ManufactiJritig Concontral~ must be stored ,andusoo in'ventilated areas only. 

Only For Formulation Into an End-Use Plant Gr~ Regulator, for (1) The Following Usels): Terrestrial foad.us8$ on: apples. 

barley, blackberries, canlaloupes, Cherries (sweet and tart), coffee bean::;, colton, cucumbers (hybrid Beed production). grapes, peppers, 

pineapPles, pumpkins (hybrid seed production). squa5h (hybrid seed produciion). sugarcane, tomatoas, walnuts and wheal. Terrestrial 

non~food USGS on: grassQ5 for seed produ~on. ornamentals, tobacco (fIu«ured) and mistletoe. 

,I USEPA has Accepted the Re"qulrad Data andlor Citations of Data that the Formulator has Submitted In 

and (3) Uses for Experimental Purposes that. Compliance with U~EPAR.qulrements. 

not contaminate water, food, or foed by storage or disposal. If conlainor is broken or co"tonls have spilled, follow aU precautions I'''. ,',.,,'". Immediately. Before cloanlng up, Pu.t on futl.length trousers, long-sleeved shirt. protective gloves and goggles or race 

up spill wilh absorbent media such as sand, earth or other suitable material and dispose of waste ,t an approved wasle 

DtSPOSAL 

wastes are acuiely hazardous. Improper dlSpclsal of excess peslicide, spray mixture, or rinsate Is a violetion of Federal taw. 

excess or waste PestiCide by use aCCOrding to label dlreetlons" or contact your Slate Pesticide or Environmental Control 

Hazardous Waste representative at the nearest EPA Regional Office forguldanCll. 

iCCINT,<I.'," DISPOSAL 

rinse (or Th.n i • 

DISCLAIMER AND INDEMNITY FOR FORM.uLATORS' .uSES 

THE MANUFACTURER EXPRESSLY DISClAIMS ALL LIABILITY FOR CLAIMS AND ACTIONS (WHETHER BASED ON 

CONTRACT, TO~T. STRICT LIABILITY OR BREACH OF WARRANTY) ARISING OUT OF, RESULTIN~ FROM OR CONNECTED 

WITH A FORMULATION CONTAINING THIS PRODUCT WHEN USED FOR MY PURPOSE OTHER THAN THOSE USES SET 

FORTH IN (1) ABOVE. THE MANUfACTURER HAs NOT. DEVELOPED SCIENTIFIC DATA TO SUPPORT. NOR HAS IT 

EXPltCITL y OR IMPLICiTlY APPROVED: ANY USES OTHER THM THOSE IN (1) ABOVE. 

ANY FORMULATOR OR BUYER WHO USES THIS· PRODUCT IN FORMULATIONS FOR ANY USE OTHER THAN THOSE STATED 

IN (1) ABOVE ASSUMES ALL LIABILITY FOR CLAIMS AND ACTIONS ARISING OUT OF • CONNECTED WITH OR RESULTING 

•

FROM SUCH USE AND AGREES BY SO USING nilS PRODUCT TO INDEMNIFY AND HOLD HARMLESS THE MANUFACTURER 

FROM SUCH CLAIMS AND ACTIONS. . 

THIS DISCLAIMER AND INDEMNITY fs IN ADDITION TO. NOT IN LIEU Of, THE.BEI:OW DISCLAIMER ~O LIMITATIONS. 

49
( ( 

IMPORTANT: READ BEFORE USE 

Read the e~lire Oir.eaUons for Use. Conditions, Disclaimer of Warraf1ties and limitations of liability before using this product. If terms 

are not acceptable, retum thaynopened' product container at once. 

By using this product, usor"ar buysr Scctpls the following Conditions, Olsclaimerof Warranties and Umitations of Liability. 

CONDInONS; The directions for use of thIS product are believed to be adequate and should be followed carefully. HOWIlV8r, it is 

impossible 10 eliminate all risks associated with the uso of this product. Crop injury, Ineffectiveness or other unintended consequences 

may result because of such factors as waather conditions, presence of other materials, or the manner of use or appncaUon. all of which 

are beyond the control of Bayer CropSdonce, All such risks shall be assumed by the user or buyer . 

. DISCLAIMER OF WARRANTIES: B~YER CROPSCIENCE MAKES NO O:THER WARRANTIES, EXPRESS OR IMPliED. OF 

MERCHANTABILITY OR OF FITNESS FOR A PA~TICULAR PURPOSE OR OTHERWISE, THAT EXTEND BEYOND THE 

STATEMENTS MADE ON THI~ LABEL No agent of Bayer CropSclence Is authorized to make any warranties beyond ttlose contained 

herein Of 10· modify the warranties contained horein. BAYER CROPSCIENCE DISCLAIMS ANY LIABILITY WHATSOEVER FOR 

SPECIAL, INCIDENTAL OR CONSEQUENTIAL DAMAGES RESULTING FROM THE USE OR HANDLING OF THIS PRODUCT, 

LIMITATIONS OF LlABIUTY: THE EXCLUSIVE REMEDY OF THE USER OR BUYER FOR ANY AND ALl LOSSES, INJURIES OR 

. DAMAGES RESULTING FROM THE USE OR HANDLING O~ THIS PRPDUCT, WHETHER IN cqNTRACT, WARRANTY, TORT. 

NEGLIGENCE. STRICT LIABILITY DR OTHERWISE, SHALL NOT EXCEED THE PURCHASE PRICE PAID. OR AT BAYER 

.CROPSCI~NCE·S ELECTION. THE REPLACEMENT OF PROoOCT . 

• 

• 

EEl Bayer CropScience 

Sayer CropSclerico LP 

P.O·, Box 12014, 2 T.W, Alexander Drive 

Rosaarch Triangle Park, North Carolina 27109 

1.ft66-99BAYER (1-866-992.2937) 

Etl1ephon Manulacturlng Concentrate (PENDING) Submitted 09f16/D4. 

3 

50
....... 

---lIP 

To: "Catherine Byrd" <:Catherine@wagnerreg.com> 

Cc: 

Bee: 

Subject: RE: 85678·U 

Dear Catherine, 

Thank you for your email. The similarity review for toxicity is completed pending an acceptable chemistry 

review. As we discussed on the phone, please provide updated labels to match the cited product. The 

due date for the Chemistry review is January 26. 

Once again, thanks for your quick response. 

Best regards, 

Janet 

"Catherine Byrd" 

From: 

To: 

Cc: 

Dale: 

Subject'. 

Hi Janet, 

"Catherine Byrd" <Calherine@wagnerreg.com> 

Janet WhitehursVDC/USEPAlUS@EPA 

"'James Wagner''' <:james@wagnerreg.com> 

01/t9/2010 02:17 PM 

RE: 85678·U 

,:,QJllW20joP2:F:28 PM 

I wanted to verify that you have received everything that you need for this 

registration. Also, what is the PRIA date for this product? If you need any 

additional information, please let me know. 

Thank you, 

Catherine 

Catherine M. Byrd 

Regulatory Associate 

P.O. Box 640 

7460 Lancaster Pike, Suite 9 

Hockessin, Delaware 19707 

P: 302.234.2780 

F: 302.234.7570 

www.wagnerreg.com 

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

From: Catherine Byrd [mailto:Catherine@wagnerreg.coml 

Sent: Wednesday, January 13, 2010 2:09 PM 

To: 'Whitehurst.Janet@epamail.epa.gov' 

Cc: 'james@wagnerreg.com' 

subject: RE: 85678-U 

Good afternoon Janet, 

We would like to "me too" Bayer Crop science LP - Ethephon Manufacturing 

Concentrate (EPA Registration No. 264-838). I have attached a revised cover 

letter and EPA application. Hard copies will be mailed to your attention. 

please let me know if you need any additional information. 

51
Thank you, 

Catherine M. Byrd 

Regulatory Associate 

P.O. Box 640 

7460 Lancaster Pike, Suite 9 

Hockessin, Delaware 19707 

P: 302.234.2780 

F: 302.234.7570 

www.wagnerreg.com 

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

From: whitehurst.Janet@epamail.epa.gov 

[mailto:Whitehurst.Janet@epamail.epa.gov] 

Sent: Wednesday, January 13, 2010 1:06 PM 

To: catherine@wagnerreg.com 

Cc: Kish.Tony@epamail.epa.gov 

Subject: 85678-U 

Dear Ms. Byrd: 

As per our phone conversation, the subject application, submitted in 

connection with registration under the Federal Insecticide, Fungicide 

and Rodenticide Act as amended is not acceptable. The Agency has 

evaluated the formulations of the proposed product, 85678-U, and the 

cited product, 66330-369, and has determined that the two products are 

not substantially similar because the percentage of the active 

ingredient in the proposed .product is higher then the cited product. 

Please correct and resubmit your application. If you have any 

questions, please contact Janet Whitehurst by phone at (703) 305-6129 or 

via email at whitehurst.janet@epa.gov. Thank you. 

Regards, 

Janet 

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52
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53
FEDERAL EXPRESS 

January 13, 2010 

Document Processing Desk (REGFEE) 

ATTN: Tony Kish PM 22 

Registration Division (7504P) 

U.S. Environmental Protection Agency 

Room SA900, One Potomac Yard 

2777 South Crystal Drive 

Arlington, Virginia 22202~4501 

Dear Mr. Kish; 

PO Box 640 

7460 Lancaster Pike, Suite 9 

Hockessin, DE 19707 

Re: Application to register a new product containing a currently registered active ingredient-

"Ethephon 78% MUP" (EPA File Symbol 85678-U) 

Wagner Regulatory Associates, Inc., as agent for RedEagJe International LLC, was contacted by Ms. 

Janet Whitehurst regarding the registration of the above-referenced product. Per our conversation, we 

would like to "me too" the Ethephon product registered by Bayer Cropscience LP under EPA Registration 

Number 264-838. 

In support of this request, the following documents are attached: 

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

agent 

• Application for Pesticide Registration (8570-1) 

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

Respectfully submitted, 

Catherine M. Byrd 

Agent for RedEagle International LLC 

Enclosures 

54
RED EAGLE INTERNATIONAL LLC. 

A Chemical Manufacture 

August 15, 2008 

To Whom it May Concern 

Dear Sir or Madam: 

Phone: (863) 648-5448 

Fax: (863) 648-1606 

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

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

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

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

correspondence for RedEagle International LLC. and its products to: 

Wagner Regulatory Associates, Inc. 

P.O. Box 640 

Hockessin, DE 19707-0640 

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

questions. 

Respectfully submitted, 

Yingxue Yu 

Chief Executive Officer 

cc: WRA., Inc. 

Address: 2651 Woodwind Hills Lane, Lakewood, FL 33812, USA 

55
RE: 85S78-U 

Catherine Byrd to: Janet Whitehurst 

Cc: james 

Good afternoon Janet, 

01/13/201002:09 PM 

We would like to "me too" Bayer cropscience LP ~ Ethephon Manufacturing 

Concentrate (EPA Registration No. 264~838). I have attached a revised cover 

letter and EPA application. Hard copies will be mailed to your attention. 

please let me know if you need any additional information. 

Thank you, 

catherine M. Byrd 

Regulatory Associate 

P.O. Box 640 

7460 Lancaster Pike, Suite 9 

Hockessin, Delaware 19707 

P: 302.234.2780 

F: 302.234.7570 

www.wagnerreg.com 

~~~~~Original Message~~~~~ 

From: Whitehurst.Janet@epamail.epa.gov 

[mailto:Whitehurst.Janet@epamail.epa.gov] 

Sent: Wednesday, January 13, 2010 1:06 PM 

To: catherine@wagnerreg.com 

Cc: Kish.Tony@epamail.epa.gov 

sUbject: 85678~U 

Dear Ms. Byrd: 

As per our phone conversation, the subject application, submitted in 

connection with registration under the Federal Insecticide, Fungicide 

and Rodenticide Act as amended is not acceptable. The Agency has 

evaluated the formulations of the proposed product, 85678~U, and the 

cited product, 66330~369, and has determined that the two products are 

not substantially similar because the percentage of the active 

ingredient in the proposed product is higher then the cited product. 

please correct and resubmit your application. If you have any 

questions, please contact Janet Whitehurst by phone at (703) 305~6129 or 

via email at whitehurst.janet@epa.gov. Thank you. 

Regards, 

Janet 

"ft' 

Ethephon 78% MUP Letter 1-12-10.pdf 

56
PRIA 2 - 21 Day Content Screen Review Worksheet 

(EPA/OPP Use Only) 

g tf 3/23/09 --Oc, 21 Day Screen Start Date: __ <L=---'_-=--..J.L'--_____ ~ 

Experts In-Processing Signature: ii, "'--- Date g -c; -°7 Fee Paid: Yes~ 

Division management contacted on issues No Yes Date ______ _ 

EPA Reg. Number: g5? 7 g - U EPA Receipt Date: ?~ "/-6 '7 

Items for Review Yes No N/A* 

1 Application Form (EPA Fonn 8570-1)(link to fonn) signed & complete X including package type 

Confidential Statement of Formula all boxes completed, fonn signed, and )( dated (EPA Fonn 8570-4) (Link to fonn) 2 a) All inerts (link to http://www.epa.gov/opprdOOllinertsl), yes no 

including fragrances, approved for the proposed uses (see )<. Footnote A) 

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

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

Certificate and data matrix consistent 'f-. 

If applicant is relying on data that are compensable, is the offer yes no 

to pay statement included. (see Footnote B) 

If applicable, is there a letter of Authorization for exclusive use only. 

Formulator's Exemption Statement (EPA Ponn 8570-27) (Link to fonn) 

4 completed and signed (NIA if source is unregistered or applicant owns the l( technical) 

Data Matrix (EPA Fonn 8570-35) (Link to fonn) both internal and external 

X copies (PR 98-5) (Link to PR 98-5) completed and signed (N/A iflOO% 

repack) 

yes no ITl:~!';j·" .. ··· c; ,-, 

S a) Selective Method (Fee category experts use) '< " ,'.' '; ; 

b) Cite-AIl (Fee category experts use) 

1;;i~;:;D: .. , ..•..••...•... 

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

5 Copies of Label (link to http://www.eQa.gov/om~feadJllabelin2lIrmD X 6 (Electronic labels on CD are encouraged and guidance is available)( link to 

http://www.epa.gov/pesticides/regulating/registering/submissions/index.htm#Jabels 

) 

1 

57
7 Is the data pack~ge consistent with PR Notice 86-5 Jlink to PRN 86-5) X 

Notice of Filing (link to 

8 httQ:llwww.e)2a.gov/l!esticides/regulatin2itolerance Qetitions.htm) included 

with petitions (link to 

http://www.eoa.20v/oesticides/re2uiatin2itoierances.htm) r9 If applicable for conventional applications, reduced risk rationale (link to 

http://w"'\vw.epa.gov/opprdOOllworkplanireducedrisk.html) rRequired Data (link to 

htto:llwwyv.eua.gov/uesticides/regylatingLdata reguirements.htm) and/or 

data waivers. See Footnote C. 

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

10 

2 

58
Comments: 

* NlA - 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, fOnTIs, 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 

59
site [link to http://www.epa.gov/opprdOOl/inertsilists.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 IIAB. The lIAB 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/oppbppdllbiopesticideslcontacts bood.hun]. 

Wben a brand, trade, or proprietary name ofan inert ingredient is listed on a CSF, 

additional information such as an alternate name ofthe inert, CAS number or other 

information [link to http://www.epa.gov/opprdOOllinerts/tips.pdfl must also be included 

to enable the Agency to determine ifit has been approved. Each component of an inert 

mixture (including a fragrance) must be identified. In some cases, the supplier of the 

mixture or fragrance may need to provide this information to the Agency. Prior to the 

Agency's receipt of an application, applicants must arrange with a proprietary mixture or 

fragrance supplier to provide the component information to the Agency or promptly upon 

EPA's request. If the inert ingredients in a proprietary blend (including fragrances) 

cannot or are not identified or provided within the 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 

60
! 

3. Withdraw the application (the Agency retains 25% of the full fee for the fee 

category estimated); or 

If none of these options is selected and implemented by the applicant within the 

21 day content review period, the Agency will reject the application and retain 

25% of the full fee of the category identified. 

Conventional New Product Applications 

When the Registration Division identifies an unapproved inert on a CSF with an 

application for a new product that the applicant has not identified as requiring an 

inert approval (R311, 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 infonnation and data needed for the Agency to approve the 

unapproved inert, including any required petition to establish or amend a 

tolerance or exemption from a tolerance. (This option may change the PRIA 

category for the application, which could require a longer decision review 

time and a larger fee. If additional fees are due, they must be received by the 

Agency within the 21 day content review period.) 

3. Withdraw the application (the Agency retains 25% of the full fee for the fee 

category estimated); or 

Ifnone 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 

61
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 

62
Script for Rejection Phone calls 

Contact Name: ('4-i!.c: o~ bye.L 

Phone#: 30;'-~3~-2nO 

Email: G,~ .... .,.;'"1t.~ w":j'1'tn -t.j.COh 

First CalIlInitials: Second Call1Initials: 

Date: .-;" 

Time: /d. ~s-5(oJ.-

Date: 

Time: 

, EPA contractor. 

I'm calling regarding yonr suhmission in support of 

Al'pl:,.i-;H. Q,~ K~J:"fr6+;'" ,f Ethe,""'" 2f:;}I'\vi'! 

We have found the following deficiencies regarding: 

PR Notice 86.5: Ves or No 

Volume/Study Title: 

Volume/Study Title: 

Volume/Study Title: 

Additional volumes continued on back of page: Ves or No 

Application Package: &r No 

C";';j';C4f,',",, ;n"-""S:s-k-..-I- w/ }",41~nh-',x 

These deficiencies have been approved by EPA. 

The corrections can be faxed to 703-305-5060/Attn: _______ _ 

Second Call1Email: 

If we do not receive the corrections by , we will process 

yonr submission, accordingly. Please direct all fnture calls and 

correspondence to the appropriate EPA Risk Manager. 

63
RE: Application for Registration of Ethephon 78% MUP 

Catherine Byrd to: Jennifer Drobish ------

Jennifer, 

08/10/200901:05 PM 

please find the attached corrected Form 8570-34. I apologize for the 

discrepancy. 

If you need anything else, please do not hesitate to contact me. 

Thank you, 

catherine M. Byrd 

Regulatory Associate 

Wagner Regulatory Associates 

P.O. Box 640 

7460 Lancaster Pike, Suite 9 

Hockessin, Delaware 19707 

P: 302.234.2780 

F: 302.234.7570 

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

From: Drobish.Jennifer@epamail.epa.gov 

[mailto:Drohish.Jennifer@epamail.epa.gov] 

Sent: Monday, August 10, 2009 12:54 PM 

To: catherine@wagnerreg.com 

subject: Application for Registration of Ethephon 78% MUP 

MS Byrd 

This is Jennifer Drohish, EPA contractor. I am writing in regards to 

your submission in support of the application for registration of 

Ethephon 78~ MUP. We have found a deficiency regarding the application 

package. The Certification with Respect to Citation of Data (EPA form 

8570-34) is inconsistent with the Data Matrix [EPA form 8570-35J. The 

data matrix indicates that data is owned, therefore the "Selective 

Method" should be selected on the Certification. There is a cite-all 

option under the selective method. The corrected form can either be 

faxed to me at 703-305-5060/Attn: Jennifer Drobish or emailed to me at 

drobish.jennifer@epa.gov 

Thank you 

Jennifer Drohish 

EPA Contractor 

703-305-1671 

"f.t 

EPA Form 8570·34 revised 8·1 0·09.pdf 

64
1 

UNITed STATES ENVIRONMENTAL PROTECTION AGENCY 

WASHINGTON, D.C. 20460 

August 5, 2009 

OPP Decision Number: D-418024 

EPA File Symbol or Registration Number: 85678-U 

Product Name: ETHEPHON 78% MUP 

EPA Receipt Date: 04-Aug-2009 

EPA Company Number: 85678 

Company Name: REDEAGLE INTERNATIONAL LLC 

CHERYL WAGNER 

WAGNER REGULATORY ASSOCIATES, INC. 

REDEAGLE INTERNATIONAL LLC 

7460 LANCASTER PIKE, SUITE 9, PO Box 640 

HOCKESSIN, DE 19707-0640 

OFFICE OF 

PREVENTION, PESTICIDES AND 

TOXIC SUBSTANCES 

SUBJECT: Receipt of Registration Application Subject to Registration Service Fee 

Dear Registrant: 

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

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

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

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

the Pesticide Registration Improvement Act. 

The Action has been identified as Action Code: R31 0 

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

CHEMISTRY;ACUTE TOXICITY;PUBLIC HEALTH PEST EFFICACY); 

No additional payment is due at this time. 

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

Ombudsman at (703) 305-6249. 

Sincerely, 

(7.JU/_.M>.JJ'O-w~ 

Front End Processing Staff 

Information Technology & Resources Management Division 

65
IFee for Servicel (855083/-

This package includes the following I. 

(!J New Registration 

°Amendment 

I ~Studies? I ./ 

n Fee Waiver? 

i 0 vol pay % Reduction: 

for Division 

Risk Mgr. []I] 

Receipt No. s-I 855083 

EPA File Symbol/Reg. No. I 85678-U 

Pin-Punch Date: 1 8/4/2009 

This item is NOT subject to FFS action. 

j 

,----A-crinn-Cnde: II ParentiChil-d-D-e-c-is-ions: I 

Requested: lIZ '3\'0 I: i 

Granted: I i2 3\ 0 II 

i Amount Due: $ 4'5 i'Y; -: j i i 

. . M~/cfD'J . I 

1< Inert c~e1red for Intended Use I- Uncleared Inert In Product 

Reviewer: VMM\;2 2a.s A Date: ~,jc;; i D') 

Remarks: 

66 *Manufacturing process information may be entitled to confidential treatment*
67
FEE FOR SERVICE 

68
Catherine Byrd 

From: 

Sent: 

To: 

Subject: 

paygovadmin@mail.doc.twai.gov 

Monday, August 03, 20092:49 PM 

catherine@wagnerreg.com 

Pay.Gov Payment Confirmation 

THIS IS AN AUTOMATED MESSAGE. PLEASE DO NOT REPLY. 

Your transaction has been successfully completed. 

Payment summary 

Application Name: PRIA Service Fees 

Pay.gov Tracking ID: 24VLQGBJ 

Agency Tracking 1D: 74977528246 

Account Holder Name: James M. Wagner 

Transaction Type: Sale 

Billing Address: 2S Gates Circle 

City: Hockessin 

State/Province: DE 

Zip/Postal Code: 19707 

Country: USA 

Card Type: American Express 

Card Number: ***********1013 

Payment Amount: $4J 578.0e 

Transaction Date: Aug 3J 2889 2:48:59 PM 

Decision Number: 

Registration Number: 

1 

" , 

""", '" 

, , " , 

" , " 

) ) , , , 

')' , 

')' , 

, ,', , 

69
Please read instructions on reverse bfo , re comr:'''ting form. Form ApproV"l'L OMS No. 2070-0060. Approval expires 05-31-98 , X egistration opp Identifier Number 

oEPA United States 

Environmental Protection Agency Amendment 

Washington, DC 20460 Other 

Application for Pesticide" Section I 

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

Red Eagle International LlC/85678- U. Tony Kish 

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

RedEagle InlernationalllC/Ethephon 78% MUP 22 

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

RedEagle International LlC 

(b)(1). my product is similar or identical in composition and labeling 

to: 

c/o Wagner Regulatory Associates, Inc. 

P.O. Box 640 

EPA Reg. No. 66330-369 

Hockessin, DE 19707 Product Name: Ethephon Technical 

0 Check if this is a new address 

Section " II 

0 Amendment - Explain below. 0 Final printed labels in response to 

Agency letter dated 

0 Resubmission in response to Agency letter daled Il9 "Me Too" Application. 

0 Notificalion - Explain below. 0 other - Explain below. 

Explanation: Use additional page(s) if necessary. (For Section I and Section 11.) 

Section " III 

1, Material This Product Will Be Packa ed In: 

Child-Resistant Packaging U~ckaging W~ Soluble Packaging 2 Iype of Container Iij V,,' Yes y" Metal 

X No T No T No X Plasilc 

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

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

be submitted I Other (Specify) HOPE lined bags 

3. location of Net Contents Information 4. Size(s) Retail Container 5. location of label Directions 

[2J Lab" D Container bulk ~ On label 

On labeling accompanying product 

6. Manner in Which label is Affixed to Product ~ Uthograph 0 Other - adhesive backed label 

X Paper glued 

Stenciled 

Section " IV 

1. Contact Point (Complete items directly below for identification of individual to be contacted, if necessary, to process this a Iication.) 

Name I Title I Telephone No. (Include Area Code) 

Catherine M. Bvrd Aqent for RedEaqle InternationalllC (302) 234 2780 

Certification 6. Date Application 

I certify Ihat the statements I have made on this torm and all attachments thereto are true, accurate and complete. Received 

I acknowledge that any knowingly false or misleading statement may be punishable by fine or imprisonment or 

both under applicable law. t~t::UT'ped) 

2. Signature 3. Title 

~11flAr( Agent for RedEagle InternationalllC 

4. Typed Name 5, Date 

Catherine M. Byrd July 31,2009 

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

70
) 

DATA TRANSMITTAL DOCUMENT 

1. Name and Address of Submitter 

Red Eagle International LLC 

c/o Wagner Regulatory Associates 

PO Box 640 

Hockessin, DE 19707 

2. Regulatory Action In Support Of Which This Package Is Submitted 

Ethephon 78% MUP 

EPA Registration Number: 85678-

3. Transmittal Date 

July 31,2009 

4. List of Submitted Studies 

Vol. 1: Weller, Paul J. (2008) "Group B Product Chemistry for 75% 

Ethephon, Physical and Chemical Properties Testing" Midwest 

Research Institute, Kansas City, Missouri. Project Number 

310810.1.002.13 pages. 

Vol. 2: Sun, Gang. (2009) "Preliminary Analysis of Ethephon Technical 

Grade Active Ingredient" Southwest Research Institute, San 

Antonio, Texas, Project Number 01.12763.02.001. Non-confidential 

portions 20 pages, Confidential portions 20 pages. 

Vol. 3: RedEagle International LLC. (2009) "Ethephon 78% MUP Product 

Identity and Composition, Description of Materials Used to Produce 

the Product, Description of the Production Process, Description of 

the Formulation Process and Discussion of Formation of 

Impurities" Non-confidential portion 6 pages, Confidential portion 

43 pages. 

Vol. 4: Wagner, James M. (2009) "Ethephon 78% MUP Product Chemistry 

Data Waiver" 4 pages. 

Company Official: 

Catherine M. Byrd fttftwrvu?1i!rJ71-- Name Signature 

Company Name: Wagner Regulatory Associates, Inc. 

Agent for RedEagle International LLC 

Company Contact: 

Catherine M. Byrd (302) 234-2780 

Name Phone 

71
RED EAGLE INTERNATIONAL LLC. 

A Chemical Manufacture 

August 15, 2008 

To VVhom it May Concern 

Dear Sir or Madam: 

Phone: (863) 648-5448 

Fax: (863) 648-1606 

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

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

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

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

correspondence for RedEagle International LLC. and its products to: 

Wagner Regulatory Associates, Inc. 

P.O. Box 640 

Hockessin, DE 19707-0640 

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

questions. 

Yingxue Yu 

Chief Executive Officer 

cc: WRA, Inc. 

" , ",,,,, " , , .. , 

, " -' " , 

. Address: 2651 Woodwind Hills Lane, Lakewood, FL 33812, USA ' ~ , -' -' j 

, 

, 

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, , 

".' j 72
Fo~, 'OMB' ... ~' ..... 

~a UNITED STATES ENVIRONMENTAL PROTECTION AGENCY , SZ' 1200 Pennsy(vania Avenue, N.W. ,-/ 

WASHINGTON, D.C. 20460 

ReductionAcl Notice: Til:: public i , i e _~_2_~h_~~_per response for registration ,," :r ~po~e for reregistration i i Ule necessary forms. Send 

t ~ burden to: Director, Collection 

, ,(2822T), ' , Protection Agency, 1200 PeMsylvania Avenue, N.W., Washington, OC 20460. Do not send the completed fonn 

Certification with Citation of Data 

Ii , Name, Address, and Telephone Number EPA Registration Number/File Symbol 

I i LLC, • Hockessin, DE 19707 85678 

Active Inaredien\fs\ and/or relJresenla~ve test compoundfs\ Dale 

July31, 2009 

I Use Palem(s) (list allhooo claimed for this product uSin!l 40 CFR Part 158) Product Name 

i , crop use 78% MUP 

NOTE: If your product is a 100% repackaging of another purchased EPA-registered product labeled for all the same uses on yOll" label. you do not need to 

subm~ this form. You must submit the Formulators EXel1lltion Statement (EPA Form 8570-27). 

0 I am responding to a Data-Gall-In Notice, and have included with this form a list of rompanies sent offers of rompensation (the 0a1a Matrix torm should 

be used forthis purpose), 

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

0 I am using1he dte-all method of support, and have included with this form 0 I am using the selective method of support (or dte-all option 

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

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

used). 

SECTtON II: GEflERAL OFFER TO PAY 

(Required if using the cite-ali method or when using the dte-all opUOn under the selective method to satisfy one or more data requirements] 

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

SECTtON III: CERTIFICATtON 

I cert'ify that this apprlcaflon tor registration, this form for reregistrabon, or this Data-Call-In response is supported by all data submitted or dted in the 

application for registration, the form for reregistration, or llle Data-Gall-In response. In addaion, if the cite-all option or dte-all option under the selective method is 

indicated In Section I, this application is supported by all data in the Agency's files that (1) ronoom the properties or effects of this product or an identical or 

substantially similar product, or one or more ot the ingredients in this product; and (2) is a type ot data that WOuld be required to be submitted under the data 

requirements in effect on the date of approval ot this applica~on if the application sought the in~ial registration of a product of identical or similar composition and 

uses. 

I oortify that for each exduslve use study cited in support of this registration or reregistration. that I am the original data sub miller or thatt have obtained 

the written permission oflhe original data submilterto cae lllat study. 

I certify that for each study caed in support of this registration or reregistration that is not an exdusJve use study, either: (a) I am llle original data 

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

Ii have expired for the study; (d) the study is in 100 public literature; or (e) I have notified in writing the rompany that submitted the study and have 

off"" to the exle'lt required by sections 3(c)(1](F) and/or 3(c){2)(8) ofFIFRA; and Qi) to rommenoo r.egoMtions to determine the 

i , if any. to be paid for the use ofthe study. ., , , " I certify that in all instances where an offer of rompeflSation is required, ropies of al offers to pay compensation anO&'I .. ;o'l:1Ge of their d€ilivoy in 

accordance with sections 3(c)(1)(F) and/or 3(c)(2)(8) ot FIFRA are available andwill be submitted to the Agency upon requesi SI'bu11 fail to prod:,lce such 

evidence to the Agency upon request I understand that the Agency may initiate action to deny, canool or suspend the registrallon of mJ product in ~nformity with 

, ' , , 

"J , , " , , , , I certify that the statements t have made on this form and all attachmonts to it are true, accurale, and complotv. 't acknowed.p 1t..at any 

knowtngty fatseor mlsleadirg statemontmay be pUnishabte bj fino or imprisonment or both under applicable law." ) ., , ,.~ , , , 

Signature I'J-..tJ../U J Date Typed or Printed Name and Trtle .u, , 

~, 

, , 

Catherine M. Byrd, Agent " .. '" 

~ July 31,2009 

, ,. '"bmil , .. , "" 

73
~ ., Form Approved OMB No. 2070-0060 . "'1 

\.~. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY _.:;< 

401 M Street, S.W. 

WASHINGTON, D.C. 20460 

Papenvork Reduction Act Notice: The public reporting burden for this collection of information is estimated to average 0.25 hours per response for registration activities and 0.25 

, hours per response for reregistration and special review activities, including time for reading the instruction and completing the necessary forms. Send comments regarding the 

burden estimate or any other aspect of this collection of information, including suggestions for reducing the burden to: Director, OPPE Information Management Division (2137), 

U.S. Environmental Protection Agency, 40 I M Street, S.W., Washington DC 20460. Do not send the fonn to this address. 

DATA MAIRIX 

Date: July 31, 2009 EPA Reg No.1 File Symbol: j Page I of3 

85678-

Applicant'sJRegistrant's Name and Address: RedEagle International LLC Product: 

c/o Wagner Regulatory Associates Inc. 

P.O. Box 640 Ethephon 78% MUP 

Hockessin, DE 19707 

Ingredient: Ethephon -

Guideline Reference Number Guideline Study Name MRID Number Submitter Status Note 

PRODUCT SPECIFIC 

830.1550, 830.1600, 830.1620, Product Identity, RedEaglc International LLC OW" 

830. I650,830.1670 CompositioniDeseription of Materials 

used to Produce the Produet/Description 

of Formulation ProecssJDiseussion of 

Formation of Impurities 

830.1700 Prclimina analysis RedEagle International LLC OW" 

830.1750 Certification of Limits RedEaglc International LLC OW" I 

830.1800 Enforcement Analytical Method RedEa Ie Internatiollal LLC OW" 

830.1900 Submittal of Samples RedEagie International LLC OW" 

830.6302 Color RedEa Ie International LLC OW" 

830.6303 Physical State RedEagle International LLC OW" 

830.6304 Odor RedEa Ie International LLC OW" 

830.6313 Stability to Normal & Elevated RedEagle International LLC OW" 

Temperatures 

830.6314 Oxidation/Reduction RedEagle International LLC O~ 

830.6315 Flammability RedEagle International LLC OW" 

830.6316 , , - , , 'L'iolodabilit RedEa Ie International LLC OW" 

83Q.6317 ~ -~- , , , .. vSJljrage Stability RedEagle International LLC OW" , ' , 

830.6319 , - , - <r~1tseibility RedEa Ie International LLC OW" -- 830.6320 Corrosion characteristics Red Eagle International LLC OW" 

830.6321 Dielectric breakdown vo!t3l,ge RedEagle International LLC OW" 

830.7000~ -" , - , - , I,l ~ " RedEa Ie International LLC OW" 

830.7050: ~ ~ - v " _ ~ ~ 

~Utr.N'isible light RedEagle International LLC OW" , -- ~ ~ ~~~ 

830.7100- .. ~ , , . , . Viscosity RedEagle International LLC OW" , 

Sig""tu~~tJL Name and Title D,te 

Catherine M. Byrd, Agent for RedEagle International July 31, 2009 

LLC 

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

74
#' ""- l A 'l. Form Approved OMB No. 2070-0060 

\?Z' UNITED STATES ENVIRONMENTAL PROTECTION AGENCY _:<' 401 M Street, S.W. 

WASHINGTON, D.C. 20460 

Paperwork Reduction Aet Notice: The public reporting burden for this collection of information is estimated to average 0.25 hours per response for registration activities and 0.25 

hours per response for reregistration and special review activities, including time for reading the instruction and completing the necessary forms. Send comments regarding the 

burden estimate or any other aspect of this collection of information, including suggestions for reducing the burden to: Director, DPPE Information Management Division (2137), 

U.S. Environmental Protection AlJency, 401 M Street, S.W., Washington DC 20460. Do not send the form to this address. 

DATA MATRIX 

Date: July 31, 2009 EPA Reg No.! File Symbol: I Page 2 of3 

85678-

Applicant'sfRegistrant's Name and Address: RedEagle Inlemational LLC Product: 

clo Wagner Regulatory Associates Inc. 

P.O. Box 640 Ethephon 78% MUP 

Hockessin, DE 19707 

Ingredient: Etheplton T 

Guideline Reference Number Guideline Study Name MRID Number Submitter Status Note 

830.7200 Meltin oint/meltin ran c RedEa Ie Internatiollal LLC OW" 

830.7220 Boiling pointiboiling range RedEagle Iuternational LLC OW" 

830.7300 DensityIReiative Density RedEa Ie International LLC Own 

830.7370 Dissociation cOllstants in water RedEagle International LLC OW" 

830.7520 Particle size, fiber len th, and diameter RedEa Ie International LLC OW" 

830.7550 Partition coefficient n-octanol!water) RedEagle International LLC Own 

830.7840 Water solubility RedEa Ie International LLC OW" 

830.7950 Va or ressure RedEa Ie International LLC Own 

870.IIOO, 1200, 1300,2400, Acute Oral, Dermal, Inhalation, Eye Cite All A icultural Handlers Ex osure Task Force, Macon, MO p'Y 

2500,2600 Irritation, Dermal Irritation, Skin Agricultural Reentry Task Force, Washington, DC 

and Generic Data Sensitization and Generic Data Albaugh, Inc., Valdosta, GA 

Axss USA, LLC, Brookfield, CT 

BASF S arks LLC, Rcsearch Trian Ie Park, NC - Celsius Pro erty B.V., Amsterdam, Raleigh, NC 

Chemical Products Technologies, Cartersville, GA 

Cheminova, Arlington, VA 

- - . ~ ~ ~ 

Dow Agrosciences, Indianapolis, IN 

- - c Drexel Chemical Com any, Mem his, TN --- --- - - - - --- E.!. DuPont de Nemours & Co., Newark, DE 

-- - -"-- " ~, -~ FIFRA Endangered Species Task Force, LLC, Washin ton, DC 

FMC Corpora(lon, Philadelp~ia, PA 

-- - - - Generic Endangered S ecies Task Force (GESTF), Washington, DC 

- - - - - Helena Chemical Co., Collierville, TN --- - -

- -

- - --- - -- -- ~ •. ~ 

- - Helm A ro, Inc., Mem his, TN - - - - - -- - --- Industria Prodotti Chimici, Washin ton, DC 

s;gnatufiJJf J", u.,. r~~ Name and Title Date 

Catherine M. Byrd, Agent for RedEagle International July 31, 2009 

LLe 

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

75
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 

401 M Street, S.W. 

n.c. 

per response 

hours per response for reregiSlration and special review activities, including time for reading the instruction and completing the necessary forms. Send comments regarding the 

burden estimate or any other aspect of this collection of information, including suggestions for reducing the burden to: Director, OPPE Infonnation Management Division (2137), 

U.S. Environmental Protection Agency, 401 M Street, S.W., Washington DC 20460. Do not send the fonn to this address . 

Date: July 31, 2009 

Ingredient: Ethephon 

.... A.TA. l\"A.TnTV 

c/o Wagner Regulatory Associates Inc. 

P.O. Box 640 

'Ie Symbol: 

Ethephon 78% MUP 

Guideline Referellce Number Guideline Study Name MRID Number Submitter 

Makhteshim-Agan of North America, Inc., Raleigh, NC 

Mey Corporation, Chapel Hill, NC 

Monsanto Co., Washington, DC 

Nations Ag 11, Ralei h, NC 

Nufarm Americas, Inc., Burr Rid e,IL 

Nufarm, Inc., Burr Ridge, IL 

Nufarm Ltd., Research Triangle Park, NC 

Outdoor ResideJltiai Exposure Task Force, LLC, Washington, DC 

RedEa Ie Chemicals Co ., Hockessin, DE 

RedEa Ie International LLC, Hoekessin, DE 

Residential Exposure Joint Venture RElV), Washington, DC 

Ritter Chemical, Washington, DC 

S ra Drift Task Force Washin ton, DC 

Syn enta Crop Protection, Greensboro, NC 

The Ortho Company, Marysville, OH 

Valent USA Corp., Walnut Creek, CA 

e c , , Zhe'iang Xinan Chemical Industrial Group, Brookfield, CT 

I) Certification uLutnits...is:,rovi~d in the Confidential Statement of Fonnula EPA fonn 8574-4 c ~ ~ ~ 

he 

Signature Name and Title 

Status Note 

-

Date 

~~ Catherine M. Byrd, Agent for RedEagle International July 3 I, 2009 

LLC 

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

76
/' ~->. Form Approved OMB No. 2070-0060 ~""l ll!!'Z ' UNITED STATES ENVlRONMENTAL PROTECTION AGENCY ~,,,~,'"j' 

401 M Street, S.W. 

WASHINGTON, D.C. 20460 

Paperwork Reduction Act Notice: The public reporting burden for this collection of information is estimated to average 0.25 hours per response for registration activities and 0.25 

hours per response for reregistration and special review activities, including time for reading the instruction and completing the necessary forms. Send comments regarding the 

burden estimate or any other aspect of this collection of information, including suggestions for reducing the burden to: Director, OPPE Information Management Division (2137), 

U.S. Environmental Protection Agency, 40 I M Street, S.W., Washington DC 20460. Do not send the form to this address. 

DATA MATRIX 

Date: July 3 I, 2009 EPA Reg No.1 File Symbol: I Page 1 of3 

85678-

Applicant's/Registrant's Name and Address: RedEagle International LLC Product: 

C/o Wagner Regulatory Associates Inc. 

P.O. Box 640 Ethephon 78% MUP 

Hockessin, DE 19707 

Ingredient: Etheplton -

Signat~~ Name and Title Date 

Catherine M. Byrd, Agent for RedEagle International July 31, 2009 

LLC 

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

77
4" ""- ( ... , 

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 col1ection of infonnation is estimated to average 0.25 hours per response for registration activities and 0.25 

hours per response for reregistration and special review activities, including time for reading the instruction and completing the necessary forms. Send comments regarding the 

burden estimate or any other aspect of this coilection of information, including suggestions for reducing the burden to: Director, OPPE Infonnation Management Division (2137), 

U.S. Environmental Protection Agency, 401 M Street, S.W., Washi~Qton DC 20460. Do not send the fonn to this address. 

DATA MATRIX 

Date: July 31, 2009 EPA Reg No.! File Symbol: I Page 2 of} 

85678-

Applicanfs/Registranfs Name and Address: RedEagle International LLC Product: 

clo Wagner Regulatory Associates Inc. 

P.O. Box 640 Ethephon 78% MUP 

Hockessin, DE 19707 

Ingredient: Ethcphon -

Number Submitter 

s;g"atm'~/1Lttj~ Name and Title Date 

Catherine M. Byrd, Agent for RedEagle International July 31, 2009 

LLC 

EPA Form 8570-35 (9-97) Electronic and Paper versions available. Submit only Paper versIOn. A2.encv Internal Use Cony 

78
,/ ,;;.\, 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 instruction and completing the necessary fonns. Send comments regarding the 

burden estimate or any other aspect of this collection of infonnation, including suggestions for reducing the burden to: Director, OPPE Infonnation Management Division (2137), 

U.S. Environmental Protection A<>ency, 401 M Street, S.W.; Washington DC 20460. Do not send the fonn to this address. 

DATA MATRIX 

Date: Iu Iy 3 I, 2009 EPA Reg No.1 File Symbol: I Page 3 of3 

85678-

Applicant's/Registranfs Name and Address: RedEagle International LLC Product: 

c/o Wagner Regulatory Associates Inc. 

P.O. Box 640 Ethephon 78% MUP 

Hockessin, DE 19707 

Ingredient: Ethephon -

Sign,tu" ~?;Igj~ Name and Title Date 

Catherine M. Byrd, Agent for RedEagle International July 31, 2009 

LLC 

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

79
DATA TRANSMITTAL DOCUMENT 

1. Name and Address of Submitter 

RedEagle International LLC 

clo Wagner Regulatory Associates 

PO Box 640 

Hockessin, DE 19707 

2. Regulatory Action In Support Of Which This Package Is Submitted 

Ethephon 78% MUP 

EPA Registration Number: 85678-

3. Transmittal Date 

July 31,2009 

4. List of Submitted Studies 

Vol. 1: Weller, Paul J. (2008) "Group B - Product Chemistry for 75% 

Ethephon, Physical and Chemical Properties Testing" Midwest 

Research Institute, Kansas City, Missouri. Project Number 

310810.1.002.13 pages. 

Vol. 2: Sun, Gang. (2009) "Preliminary Analysis of Ethephon Technical 

Grade Active Ingredient" Southwest Research Institute, San 

Antonio, Texas, Project Number 01.12763.02.001. Non-confidential 

portions 20 pages, Confidential portions 20 pages. 

Vol. 3: RedEagle International LLC. (2009) "Ethephon 78% MUP Product 

Identity and Composition, Description of Materials Used to Produce 

the Product, Description of the Production Process, Description of 

the Fonnulation Process and Discussion of Formation of 

Impuritiesn Non-confidential portion 6 pages, Confidential portion 

43 pages. 

Vol. 4: Wagner, James M. (2009) "Ethephon 78% MUP Product Chemistry 

Data Waiver" 4 pages. 

Company Official: 

Catherine M. Byrd 

Name 

Company Name: Wagner Regulatory Associates, Inc. 

Agent for Red Eagle International LLC 

, 

, " , 

Company Contact: 

Catherine M. Byrd 

Name 

(302) 234-2786 " " --=""=P"'h"'on"-e"'-'-=-~ " " 

" " , )') , 

80
) 

ETHEPHON 78% MUP 

Active Ingredient: 

Ethephon [(2-chloroethyl) phosphonic acid]. ............................................. 77.6% 

Other Ingredients: ............................................................................ 22.40/0 

TOTAL: 100.00% 

EPA Reg. No. 85678- EPA Est. No. __ _ 

KEEP OUT OF REACH OF CHILDREN 

DANGER - PELIGRO 

PRECAUCION AL USUARIO: Si listed no lee ingles, no use este producto hasta que la etiqueta Ie 

haya sido explicada ampliamente. 

PRECAUTION TO THE USER: If you cannot read English, do not use this product until the label has 

been fully explained to you. 

First Aid 

IfIn 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 eye. 

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

IfSwaIIowed • Immediately call a poison control center or doctor for treatment advice. 

• Do not induce vomiting unless told to do so by a poison control center or 

doctor. 

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

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

Ifon Skin or • Take off contaminated clothing. 

Clothing: • Rinse skin immediately with plenty of water for 15-20 minutes. 

For medical emergencies involving this product, caUl-800-222-1222 

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

treatment. 

NOTE TO PHYSICIAN: Treat symptomatically. Consider the possibility that overexposure to materials 

other than this product may have occurred. Probable mucosal damage may contraindicate the use of gastric 

lavarre. 

For chemical emergency assistance (spill, leak, fire, accident) call ChemTrec at 1-800-424-9300. 

Manufactured for: 

RedEagle International LLC 

2651 Woodwind Hills Lane 

Lakeland, Florida 33813 

, , > , ) , , , , , , , , 

~ -' , 

, , " 

, , 

" , , , 

, " , , , 

, 

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, 

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Ethephon ManufaI3tJlir,g' Concentrate 

24July2.o!;l9 Page 1 of 3 " , , > -' 0 

81
PRECAUTIONARY STATEMENTS 

DANGER 

HAZARDS TO HUMANS AND DOMESTIC ANIMALS 

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

eyes, on skin or on clothing. Wear goggles or face shield. Wear protective clothing and rubber gloves. Wash thoroughly 

with soap and water after handling. Remove contaminated clothing and wash clothing before reuse. 

ENVIRONMENTAL HAZARDS 

Do not discharge effluent containing this product into lakes, streams, ponds, estuaries, oceans, or other waters unless in 

accordance with the requirements ofa National Poliutant 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 the sewage treatment plant authority. For guidance, contact your State Water Board or Regional 

Office of the Environmental Protection Agency. 

DIRECTIONS FOR USE 

It is a violation of Federal law to use this product in a manner inconsistent with its labeling. Read entire label before using 

this product. This product must be stored and used in ventilated areas only. 

Only For Formulation Into an End~Use Plant Growth Regulator, for; 

(1) The Foilowing Uses: Terrestrial food uses on: apples, barley, blackberries, cantaloupes, cherries (sweet and tart), 

coffee beans, cotton, cucumbers (hybrid seed production), grapes, peppers, pineapples, pumpkins, (hybrid seed 

production), squash (hybrid seed production), sugarcane, tomatoes, walnuts and wheat. Terrestrial non~food uses 

on: grasses grown for seed production, ornamentals, tobacco (flu~cured) and mistletoe. 

(2) Uses for which USEPA has Accepted tile Required Data and/or Citations of Data that the Formulator has 

Submitted in Support of Registration. 

(3) Uses for Experimental Purposes that are in Compliance with USEPA Requirements. 

STORAGE AND DISPOSAL 

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

PESTICIDE STORAGE 

Store in a cool, dry place and away from food, feed and other pesticides. IF SPILLED: If container is broken or 

contents have spilled, follow all precautions indicated above and clean up immediately. Before cleaning up, put on 

full~length trousers, long-sleeved shirt, protective gloves and goggles or face shield. Soak up spill with absorbent 

media such as sand, earth or other suitable material and dispose of waste at an approved waste disposal facility. 

PESTICIDE DISPOSAL 

Pesticide wastes are acutely hazardous. Improper disposal of excess pesticide, spray mixture, or rinsate is a 

violation of Federal law. If these wastes cannot be disposed of by use according to label instructions, contact your 

State Pesticide or Environmental Control Agency or the Hazardous Waste representative at the nearest EPA 

Regional Office for guidance. 

CONTAINER DISPOSAL 

Triple rinse (or equivalent) the empty containers. Then offer for recycling or reconditioning, or punctpJe ,and 

dispose of in a sanitary landfill or by incineration or, if allowed by state and local authC]rjtjP,s, ;by bUl'n,ir).g., , If 

container is burned, stay out of smoke. > , 

, 

IMPORTANT: Read the entire DIRECTIONS FOR USE and the CONDITIONS OF SALE;j(ND WARltiNTY before 

using this product. If terms are not acceptable, return the unopened product container at once. , , 

" " , , 

, ", , 

, , , , 

Ethephon Manufaol:.uir,g-' Concentrate 

24.\uty2!J',)9 Page 2 of 3 , , , > -' 

82
DISCLAIMER AND INDEMNITY FOR FORMULATORS' USES 

THE MANUFACTURER EXPRESSLY DISCLAIMS ALL LIABILITY FOR CLAIMS AND ACTIONS (WHETHER 

BASED ON CONTRACT, TORT, STRICT LIABILITY OR BREACH OF WARRANTY) ARlSING OUT OF, 

RESULTING FROM OR CONNECTED WITH A FORMULATION CONTAINING THIS PRODUCT WHEN USED FOR 

ANY PURPOSE OTHER THAN THOSE USES SET FORTH IN (1) ABOVE. THE MANUFACTURER HAS NOT 

DEVELOPED SCIENTiFIC DATA TO SUPPORT, NOR HAS IT EXPLICITLY OR IMPLICITLY APPROVED, ANY 

USES OTHER THAN THOSE IN (1) ABOVE. 

ANY FORMULATOR OR BUYER WHO USES THIS PRODUCT IN FORM:ULA nONS FOR ANY USE OTHER THAN 

THOSE STAlED IN (I) ABOVE ASSUMES ALL LIABILITY FOR CLAIMS AND ACTIONS ARISING OUT OF, 

CONNECTED WITH OR RESULTING FROM SUCH USE AND AGREES BY so USING THIS PRODUCT TO 

INDEMNIFY AND HOLD HARMLESS THE MANUFACTURER FROM SUCH CLAIMS AND ACTIONS. 

THIS DISCLAIMER AND INDEMNITY IS IN ADDITION TO, NOT IN LIEU OF, THE BELOW DISCLAIMER AND 

LIMITATIONS. 

IMPORTANT: READ BEFORE USE 

Read the entire Directions for Use, Conditions, Disclaimer of Warranties and Limitations of Liability before using this 

product. If terms are not acceptable, return the unopened container at once. 

By using this product, user or buyer accepts the following Conditions, Disclaimer of Warranties and Limitations of Liability. 

CONDITIONS: The directions for use of this product are believed to be adequate and should be followed carefully. 

However, it is impossible to eliminate all risks associated with the use of this product. Crop injury, ineffectiveness or other 

unintended consequences may result because of such factors as weather conditions, presence of other materials, or the 

manner of use or application, all of which are beyond the control of Red Eagle International LLC. All such risks shall be 

assumed by the user or buyer. 

DISCLAIMER OF WARRANTIES: REDEAGLE INTERNATIONAL LLC MAKES NO OTHER WARRANTIES, 

EXPRESS OR IMPLIED, OR MERCHANT ABILITY OR OF FITNESS FOR A PARTICULAR PURPOSE OR 

OTHERWISE, THAT EXTEND BEYOND THE STATEMENTS MADE ON THIS LABEL. No agent of Red Eagle 

International LLC is authorized to make any warranties beyond those contained herein or to modifY the warranties contained 

herein. TO THE EXTENT CONSISTENT WITH APPLICABLE LAW, REDEAGLE INTERNATIONAL LLC 

DISCLAIMS ANY LIABILITY WHATSOEVER FOR SPECIAL, INCIDENTAL OR CONSEQUENTIAL DAMAGES 

RESULTING FROM THE USE OR HANDLING OF THIS PRODUCT. 

LIMITATIONS OF LIABILITY: TO THE EXTENT CONSISTENT WITH APPLICABLE LAW, REDEAGLE 

INTERNATIONAL LLC THE EXCLUSIVE REMEDY OF THE USER OR BUYER FOR ANY AND ALL LOSSES, 

INJURlES OR DAMAGES RESULTING FROM THE USE OR HANDLING OF THIS PRODUCT, WHETHER IN 

CONlRACT, WARRANTY, TORT, NEGLIGENCE, STRlCT LIABILITY OR OTHERWISE, SHALL NOT EXCEED 

THE PURCHASE PRICE PAID, OR AT REDEAGLE INTERNATIONAL LLC ELECTION, THE REPLACEMENT OF 

PRODUCT. 

Manufactured for: 

RedEagle International LLC 

2651 Woodwind Hills Lane 

Lakeland, Florida 33813 " , " , , " 

, , 

," , , 

, " 

, > > , 

Ethephon Manufa:t:J:ing Concentrate 

24 July?J)P9 Page 3 of 3 

" , " > > > 

83
ETHEPHON 78% MUP 

Active Ingredient: 

Ethephon [(2-chloroethyl) phosphonic acid] .............................................. 77.6% 

Other Ingredients: .......................................................................... 22.4% 

TOTAL: 100.00% 

EPA Reg. No. 85678- EPA Est. No. __ _ 

KEEP OUT OF REACH OF CHILDREN 

DANGER - PELIGRO 

PRECAUCION AL USUARIO: Si usted no lee ingles, no use este'producto hasta que la etiqueta Ie 

haya sido explicada ampliamente. 

PRECAUTION TO THE USER: If you cannot read English, do not use this product until the label has 

been fully explained to you. 

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 eye. 

• Call a 'oolson control center or doctor for treatment advice. 

If Swallowed • Immediately call a poison control center or doctor for treatment advice. 

• Do not induce vomiting unless told to do so by a poison control center or 

doctor. 

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

• Do not l!ive anYthing b mouth to an unconscious person. 

If on Skin or • Take off contaminated clothing. 

Clothing: • Rinse skin immediatelv with nlenty of water for 15-20 minutes. 

For medical emergencies inVOlving this product, call 1-800-222-1222 

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

treatment. 

NOTE TO PHYSICIAN: Treat symptomatically. Consider the possibility that overexposure to materials 

otherthan this product may have occurred. Probable mucosal damage may contraindicate the use of gastric 

lavap"e. 

For chemical emergency assistance (spill, leak, fire, accident) call ChemTrec at 1-800-424-9300. 

Manufactured for: 

RedEagle International LLC 

2651 Woodwind Hills Lane 

Lakeland, Florida 33813 

, 'd . , , . 

" , , " . 

., , , . 

, . " . 

, , " . 

, , > , , 

," , 

. Bhephon Manufacturing"Concentrate 

24Jl.lly.i1:000 :»age t of 3 ., , ", , 

84
PRECAUTIONARY STATEMENTS 

DANGER 

HAZARDS TO HUMANS AND DOMESTIC ANIMALS 

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

eyes, on skin or on clothing. Wear goggles or face shield. Wear protective clothing and rubber gloves. Wash thoroughly 

with soap and water after handling. Remove contaminated clothing and wash clothing before reuse. 

ENVIRONMENTAL HAZARDS 

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) pennit 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 the sewage treatment plant authority. For guidance, contact your State Water Board or Regional 

Office of the Environmental Protection Agency. 

DIRECTIONS FOR USE 

It is a violation of Federal law to use this product in a manner inconsistent with its labeling. Read entire label before using 

this product. This product must be stored and used in ventilated areas only. 

Only For Formulation Into an EndwVse Plant Growth Regulator, for: 

(I) The Following Uses: Terrestrial food uses on : apples, barley, blackberries, cantaloupes, cherries (sweet and tart), 

coffee beans, cotton, cucumbers (hybrid seed production), grapes, peppers, pineapples, pumpkins, (hybrid seed 

production), squash (hybrid seed production), sugarcane, tomatoes, walnuts and wheat. Terrestrial nonwfood uses 

on: grasses grown for seed production, ornamentals, tobacco (flu-cured) and mistletoe. 

(2) Uses for which USEPA has Accepted the Required Data andlor Citations of Data that the Formulator has 

Submitted in Support of Registration. 

(3) Uses for Experimental Purposes that are in Compliance with USEPA Requirements. 

STORAGE AND DISPOSAL 

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

PESTICIDE STORAGE 

Store in a cool, dry place and away from food, feed and other pesticides. IF SPILLED: If container is broken or 

contents have spilled, follow all precautions indicated above and clean up immediately. Before cleaning up, put on 

full-length trousers, long-sleeved shirt, protective gloves and goggles or face shield. Soak up spill with absorbent 

media such as sand, earth or other suitable material and dispose of waste atan approved waste disposal facility. 

PESTICIDE DISPOSAL 

Pesticide wastes are acutely hazardous. Improper disposal of excess pesticide, spray mixture, or rinsate is a 

violation of Federal law. If these wastes cannot be disposed of by use according to label instructions, contact your 

State Pesticide or Environmental Control Agency or the Hazardous Waste representative at the nearest EPA 

Regional Office for guidance. 

CONTAINER DISPOSAL 

Triple rinse (or equivalent) the empty containers. Then offer for recycling or reconditioning, or pllllctur<t ,an .. d 

dispose of in a sanitary landfill or by incineration or, if allowed by state and local authori~i1f~)J~ burning)' JP 

container is burned, stay out of smoke. ' ,; 

, , 

IMPORTANT: Read the entire DIRECTIONS FOR USE and the CONDITIONS OF SALE'ANt) WARRAl';rty before 

using this product. Ifterms are not acceptable, return the unopened product container at once. " ;" " , 

"" ", 

, .,. ,,' , 

Ethephon Manufactu::inf>'Concentrate 

24Jui;12009Page 2 of 3 , ,,' , 

85
DISCLAIMER AND INDEMNITY FOR FORMULATORS' USES 

THE MANUFACTURER EXPRESSLY DISCLAIMS ALL LIABILITY FOR CLAIMS AND ACTIONS (WHETHER 

BASED ON CONTRACT, TORT, STRICT LIABILITY OR BREACH OF WARRANTY) ARISING OUT OF, 

RESULTING FROM OR CONNECTED WITH A FORMULATION CaNT AINING THIS PRODUCT WHEN USED FOR 

ANY PURPOSE OTHER THAN THOSE USES SET FORTH IN (I) ABOVE. THE MANUFACTURER HAS NOT 

DEVELOPED SCIENTIFIC DATA TO SUPPORT, NOR HAS IT EXPLICITLY OR IMPLICITLY APPROVED, ANY 

USES OTHER THAN THOSE IN (I) ABOVE. 

ANY FORMULATOR OR BUYER WHO USES THIS PRODUCT IN FORMULATIONS FOR ANY USE OTHER THAN 

THOSE STATED IN (I) ABOVE ASSUMES ALL LIABILITY FOR CLAIMS AND ACTIONS ARISrNG OUT OF, 

CONNECTED WITH OR RESULTING FROM SUCH USE AND AGREES BY SO USING THIS PRODUCT TO 

INDEMNIFY AND HOLD HARMLESS THE MANUFACTURER FROM SUCH CLAIMS AND ACTIONS. 

THIS DISCLAIMER AND INDEMNITY IS IN ADDITION TO, NOT IN LIEU OF, THE BELOW DISCLAIMER AND 

LIMITATIONS. 

IMPORTANT: READ BEFORE USE 

Read the entire Directions for Use, Conditions, Disclaimer of Warranties and Limitations of Liability before using this 

product. If terms are not acceptable, return the unopened container at once. 

By using this product, user or buyer accepts the following Conditions, Disclaimer of Warranties and Limitations of Liability. 

CONDITIONS: The directions for use of this product are believed to be adequate and should be followed carefully. 

However, it is impossible to eliminate all risks associated with the use of this product. Crop injury, ineffectiveness or other 

unintended consequences may result because of such factors as weather conditions, presence of other materials, or the 

manner of use or application, all of which are beyond the control of RedEagle International LLC. AlI such risks shall be 

assumed by the user or buyer. 

DISCLAIMER OF WARRANTIES: REDEAGLE INTERNATIONAL LLC MAKES NO OTHER WARRANTIES, 

EXPRESS OR IMPLIED, OR MERCHANTABILITY OR OF FITNESS FOR A PARTICULAR PURPOSE OR 

OTIIERWISE, THAT EXTEND BEYOND THE STATEMENTS MADE ON THIS LABEL. No agent of Red Eagle 

International LLC is authorized to make any warranties beyond those contained herein or to modify the warranties contained 

herein. TO THE EXTENT CONSISTENT WITH APPLICABLE LAW, REDEAGLE INTERNATIONAL LLC 

DISCLAIMS ANY LIABILITY WHATSOEVER FOR SPECIAL, INCIDENTAL OR CONSEQUENTIAL DAMAGES 

RESULTING FROM THE USE OR HANDLING OF THIS PRODUCT. 

LIMITATIONS OF LIABILITY: TO THE EXTENT CONSISTENT WITH APPLICABLE LAW, REDEAGLE 

INTERNATIONAL LLC THE EXCLUSIVE REMEDY OF THE USER OR BUYER FOR ANY AND ALL LOSSES, 

INJURIES OR DAMAGES RESULTING FROM THE USE OR HANDLING OF THIS PRODUCT, WHETHER IN 

CONTRACT, WARRANTY, TORT, NEGLIGENCE, SlRICT LIABILITY OR OTHERWISE, SHALL NOT EXCEED 

THE PURCHASE PRICE PAID, OR AT REDEAGLE INTERNATIONAL LLC ELECTION, THE REPLACEMENT OF 

PRODUCT. 

Manufactured for: 

RedEagle International LLC 

2651 Woodwind Hills Lane 

Lakeland, Florida 33813 " " " , " 

" , , , " , 

, >, , , .,," "" 

" , , , , , 

Ethephon Manufaclu:;irlf; G6ncentrate 

24Jul'j200£Jpage 3 of 3 

" , , >, , 

86
ETHEPHON 78% MUP 

Active Ingredient: 

Ethephon [(2-chloroethyl) phosphonic acid]. ............................................. 77.6% 

Other Ingredients: ............................................................................ 22.4% 

TOTAL: lOO.OO% 

EPA Reg. No. 85678- EPA Est. No. __ _ 

KEEP OUT OF REACH OF CHILDREN 

DANGER - PELIGRO 

PRECAUCION AL USUARIO: Si usted no lee ingles, no use este producto hasta que la etiqueta Ie 

haya sido explicada ampliamente. 

PRECAUTION TO THE USER: If you cannot read English, do not use this product until the label has 

been fully exphiined to you. 

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 eye. 

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

If Swallowed • Immediately call a poison control center or doctor for treatment advice. 

• Do not induce vomiting unless told to do so by a poison control center or 

doctor. 

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

• Do not e:ive anythi~l!! bv mouth to an unconscious nerson. 

!fon Skin or • Take off contaminated clothing. 

Clothing: • Rinse skin immediately with oientv of water for 15-20 minutes. 

For medical emergencies involving this product, call 1-800-222-1222 

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

treatment. 

NOTE TO PHYSICIAN: Treat symptomatically. Consider the possibility that overexposure to materials 

other than this product may have occurred. Probable mucosal damage may contraindicate the use of gastric 

lavae:e. 

For chemical emergency assistance (spill, leak, fIre, accident) call ChemTrec at 1-800-424-9300. 

Manufactured for: 

RedEagle International LLC 

2651 Woodwind Hills Lane 

Lakeland, Florida 33813 

,,' , 

" , , , " , 

, 

) > j 

, 

, , " , ." , 

, Ethephon Manufactur,'r,g 'Concentrate 

24July200Q 5'age 1 of 3 " , , ~ , 87, 
PRECAUTIONARY STATEMENTS 

DANGER 

HAZARDS TO HUMANS AND DOMESTIC ANIMALS 

Corrosive. Causes in"eversible eye damage and skin bums. Harmful if swaIlowed or absorbed through skin. Do not get in 

eyes, on skin or on clothing. Wear goggles or face shield. Wear protective clothing and rubber gloves. Wash thoroughly 

with soap and water after handling. Remove contaminated clothing and wash clothing before reuse. 

ENVIRONMENTAL HAZARDS 

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) pennit and the pennitting 

authority has been notified in writing prior to discharge. Do not discharge effluent containing this product to sewer systems 

without previously notifying the sewage treatment plant authority. For guidance, contact your State Water Board or Regional 

Office of the Environmental Protection Agency. 

DIRECTIONS FOR USE 

It is a violation of Federal law to use this product in a manner inconsistent with its labeling. Read entire label before using 

this product. This product must be stored and used in ventilated areas only. 

Only For Formulation Into an End-Use Plant Growth Regulator, for: 

(I) The Following Uses: Terrestrial food uses on: apples, barley, blackberries, cantaloupes, cherries (sweet and tart), 

coffee beans, cotton, cucumbers (hybrid seed production), grapes, peppers, pineapples, pumpkins, (hybrid seed 

production), squash (hybrid seed production), sugarcane, tomatoes, walnuts and wheat. Terrestrial non-food uses 

on: grasses grown for seed production, ornamentals, tobacco (flu-cured) and mistletoe. 

(2) Uses for which USEPA has Accepted the Required Data and/or Citations of Data that the Formulator has 

Submitted in Support of Registration. 

(3) Uses for Experimental Purposes that are in Compliance with USEPA Requirements. 

STORAGE AND DISPOSAL 

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

PESTICIDE STORAGE 

Store in a cool, dry place and away from food, feed and other pesticides. IF SPILLED: If container is broken or 

contents have spilled, follow all precautions indicated above and clean up immediately. Before cleaning up, put on 

full-length trousers, long-sleeved shirt, protective gloves and goggles or face shield. Soak up spill with absorbent 

media such as sand, earth or other suitable material and dispose of waste at an approved waste disposal facility. 

PESTICIDE DISPOSAL 

Pesticide wastes are acutely hazardous. Improper disposal of excess pesticide, spray mixture, or rinsate is a 

violation of Fedeml law. If these wastes cannot be disposed of by use according to label instructions, contact your 

State Pesticide or Environmental Control Agency or the Hazardous Waste representative at the nearest EPA 

Regional Office for guidance. 

CONTAINER DISPOSAL 

Triple rinse (or equivalent) the empty containers. Then offer for recycling or reconditioning, or puncture, ~nq 

dispose of in a sanitary landfill or by incineration or, if allowed by state and local authoritLe~, py.bumiQK, 'If' 

conta'mer is bUllled, stay out of smoke. ' , 

IMPORTANT: Read the entire DIRECTIONS FOR USE and the CONDITIONS OF SALE A1'1J'),\WARRA]{I;rV before 

using this product. IftelIDs are not acceptable, return the unopened product container at once. , , 

, '" ' 

Ethephon Manufactuiml),Concewate 

24July,,00!1P.age 2 of 3 

88
ETHEPHON 78% MUP 

Active Ingredient: 

Ethephon [(2-chloroethyl) phosphonic acid] .............................................. 77.6% 

Other Ingredients: ......... ,' ................................................................. 22.4% 

TOTAL: 100.00% 

EPA Reg. No. 85678- EPA Est. No. __ _ 

KEEP OUT OF REACH OF CHILDREN 

DANGER - PELIGRO 

PRECAUCION AL USUARlO: Si usted no lee ingles, no use este producto hasta que la etiqueta Ie 

haya sido explicada ampliamente. 

PRECAUTION TO THE USER: If you cannot read English, do not use this product until the label has 

been fully explained to you. 

First Aid 

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

• Remove contact lenses, jf present, after the first 5 minutes, then continue 

rinsing eye. 

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

If Swallowed • lnunediately caIl a poison control center or doctor for treatment advice. 

• Do not induce vomiting unless told to do so by a poison control center or 

doctor. 

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

• Do not give aIlyfuino-Jij.mouth to an unconscious p~rson. 

Ifon Skin or • Take off contaminated clothing. 

Clothing: • Rinse skin immediately with plenty of water for 15~20 minutes. 

For medical emergencies involving this product, call1-800~222-1222 

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

treatment. 

NOTE TO PHYSICIAN: Treat symptomatically. Consider the possibility that overexposure to materials 

other than this product may have occurred. Probable mucosal damage may contraindicate the use of gastric 

lavage. 

For chemical emergency assistance (spill, leak, fire, accident) call ChemTrec at 1-800424-9300. 

Man ufactured for: 

RedEagle International LLC 

2651 Woodwind Hills Lane 

Lakeland, Florida 33813 

• ., » } 

'" , 

" , 

, 

" , ' 

'}' } 

, , , } , 

Ethephon Manufad<lflr,g"Concentrate 

24JL'Jy2099 Page 1 of 3 '} -I , , -I } 

89
PRECAUTIONARY STATEMENTS 

DANGER 

HAZARDS TO HUMANS AND DOMESTIC ANIMALS 

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

eyes, on skin or on clothing. Wear goggles or face shield. Wear protective clothing and rubber gloves. Wash thoroughly 

with soap and water after handling. Remove contaminated clothing and wash clothing before reuse. 

ENVIRONMENTAL HAZARDS 

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) pelTIlit 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 the sewage treatment plant authority. For guidance, contact your State Water Board or Regional 

Office ofthe Environmental Protection Agency. 

DIRECTIONS FOR USE 

It is a violation of Federal law to use this product in a manner inconsistent with its labeling. Read entire label before using 

this product. This product must be stored and used in ventilated areas only. 

Only For Formulation Into an End-Use Plant Growth Regulator, for: 

(1) The Following Uses: Terrestrial food uses on: apples, barley, blackberries, cantaloupes, cherries (sweet and tart), 

coffee beans, cotton, cucumbers (hybrid seed production), grapes, peppers, pineapples, pumpkins, (hybrid seed 

production), squash (hybrid seed production), sugarcane, tomatoes, walnuts and wheat Terrestrial non-food uses 

on: grasses grown for seed production, ornamentals, tobacco (flu-cured) and mistletoe. 

(2) Uses for which USEPA has Accepted the Required Data and/or Citations of Data that the Formulator has 

Submitted in Support of Registration. 

(3) Uses for Experimental Purposes that are in Compliance with USEPA Requirements. 

STORAGE AND DISPOSAL 

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

PESTICIDE STORAGE 

Store in a cool, dry place and away from food, feed and other pesticides. IF SPILLED: If container is broken or 

contents have spilled, follow all precautions indicated above and clean up immediately. Before cleaning up, put on 

fulI-length trousers, long-sleeved shirt, protective gloves and goggles or fuce shield. Soak up spill with absorbent 

media such as sand, earth or other suitable material and dispose of waste at an approved waste disposal facility. 

PESTICIDE DISPOSAL 

Pesticide wastes are acutely hazardous. Improper disposal of excess pesticide, spray mixture, or rinsate is a 

violation of Federal law. If these wastes cannot be disposed of by use according to label instructions, contact your 

State Pesticide or Environmental Control Agency or the Hazardous Waste representative at the nearest EPA 

Regional Office for guidance. 

CONTAINER DISPOSAL 

Triple rinse (or equivalent) the empty containers. Then offer for recycling or reconditioning, or punctur,e, aIj.d 

dispose of in a sanitary landfill or by incineration or, if allowed by state and local authorjtj~~., 9Y bumitW,.')f 

container is burned, stay out of smoke. ' :: 

, , IMPORTANT: Read the entire DIRECTIONS FOR USE and the CONDITIONS OF SALE .ANi>!WARRANTY before 

using this product. Iftenns are not acceptable, return the unopened product container at once. " , ) " ' " ' 

", , Ethephon ManLlfaclt:r!n:;l Concentrate 

24JLlI~20fJ9, Page 2 of 3 

" , o , " , 

90
DISCLAIMER AND INDEMNITY FOR FORMULATORS' USES 

THE MANUFACTURER EXPRESSLY DISCLAIMS ALL LIABILITY FOR CLAIMS AND ACTIONS (WHETHER 

BASED ON CONTRACT, TORT, STRICT LIABILITY OR BREACH OF WARRANTY) ARISING OUT OF, 

RESULTING FROM OR CONNECTED WITH A FORMULATION CONTAINING THIS PRODUCT WHEN USED FOR 

ANY PURPOSE OTHER THAN THOSE USES SET FORTH IN (I) ABOVE. THE MANUFACTURER HAS NOT 

DEVELOPED SCIENTIFIC DATA TO SUPPORT, NOR HAS IT EXPLICIlL Y OR IMPLICITLY APPROVED, ANY 

USES OTHER THAN THOSE IN (1) ABOVE. 

ANY FORMULATOR QRBUYER WHO USES THIS PRODUCT IN FORMULATIONS FOR ANY USE OTHER THAN 

THOSE STATED IN (I) ABOVE ASSUMES ALL LIABILITY FORCLA[MS AND ACTIONS ARISING OUT OF, 

CONNEClED WITH OR RESULTING FROM SUCH USE AND AGREES BY SO USING THIS PRODUCT TO 

INDElYfNIFY AND HOLD HARMLESS THE MANUFACTURER FROM SUCH CLAIMS AND ACTIONS. 

THIS DISCLAIMER AND INDEMNITY IS IN ADDITION TO, NOT IN LIEU OF, THE BELOW DISCLAIMER AND 

LIMITATIONS. 

IMPORTANT: READ BEFORE USE 

Read the entire Directions for Use, Conditions, Disclaimer of Warranties and Limitations of Liability before using this 

product. If terms are not acceptable, return the unopened container at once. 

By using this product, user or buyer accepts the following Conditions, Disclaimer of Warranties and Limitations of Liability. 

CONDITIONS: The directions for use of this product are believed to be adequate and should be followed carefully. 

However, it is impossible to eliminate all risks associated with the use of this product. Crop injury, ineffectiveness or other 

unintended consequences may result because of such factors as weather conditions, presence of other materials, or the 

manner of use or application, an of which are beyond the control of Red Eagle International LLC. AlI such risks shall be 

assumed by the user or buyer. 

DISCLAIMER OF WARRANTIES: REDEAGLE INTERNATIONAL LLC MAKES NO OTHER WARRANTIES, 

EXPRESS OR IMPLIED, OR I\.1ERCHANTABILITY OR OF FITNESS FOR A PARTICULAR PURPOSE OR 

OTHERWISE, THAT EXTEND BEYOND THE STATEMENTS MADE ON THIS LABEL. No agent of RedEagle 

International LLC is authorized to make any warranties beyond those contained herein or to modifY the warranties contained 

hereiu. TO THE EXTENT CONSISTENT WIlli APPLICABLE LAW, REDEAGLE INTERNATIONAL LLC 

DISCLAIMS ANY LIABILITY WHATSOEVER FOR SPECIAL, INCIDENTAL OR CONSEQUENTIAL DAMAGES 

RESULTING FROM THE USE OR HANDLING OF THIS PRODUCT. 

LIMITATIONS OF LIABILITY: TO THE EXTENT CONSISlENT WITH APPLICABLE LAW, REDEAGLE 

INTERNATIONAL LLC THE EXCLUSIVE REMEDY OF THE USER OR BUYER FOR ANY AND ALL LOSSES, 

INJURIES OR DAiv1AGES RESULTING FROM THE USE OR HANDLING OF THIS PRODUCT, WHETHER IN 

CONTRACT, WARRANTY, TORT, NEGLIGENCE, SlRICTLIABILITY OR OTHERWISE, SHALL NOT EXCEED 

THE PURCHASE PRICE PAID, ORAT REDEAGLE INTERNATIONAL LLC ELECTION, THE REPLACEMENT OF 

PRODUCT. 

Manufactured for: 

RedEagle International LLC 

2651 Woodwind Hills Lane 

Lakeland, Florida 33813 

) , ) " , , , , 

. ) ), 

., . 

Ethephon ManufactL:,i::l;J Concentrate 

24Ju1y20rf1,Page 3 of 3 

" 

91
ETHEPHON 78% MUP 

Active Ingredient: 

Ethephon [(2-chloroethyl) phosphonic acidJ .............................................. 77.6% 

Other Ingredients: ........................................................ ' .............. , .... 22.4% 

TOTAL: 100.00% 

EPA Reg. No. 85678- EPA Est. No. __ _ 

KEEP OUT OF REACH OF CHILDREN 

DANGER - PELIGRO 

PRECAUCION AL USUARIO: Si usted no lee ingles, no use este producto hasta que la etiqueta Ie 

haya sido explicada ampliamente. 

PRECAUTION TO THE USER: If you cannot read English, do not use this product until the label has 

been fully explained to yOll. 

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 eye. 

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

If Swallowed • Immediately call a poison control center or doctor for treatment advice. 

• Do not induce vomiting unless told to do so by a poison control center or 

doctor. 

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

• Do not give any thin):!. by mouth to an unconscious person. 

If on Skin or • Take off contaminated clothing. 

Clothing: • Rinse skin immediately with plenty of water for 15-20 minutes. 

For medical emergencies involving this product, call J-800-222-1222 

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

treatment. 

NOTE TO PHYSICIAN: Treat symptomatically. Consider the possibility that overexposure to materials 

other than this product may have occurred. Probable mucosal damage may contraindicate the use of gastric 

lavage. 

For chemical emergency assistance (spill, leak, fIre, accident) call ChemTrec at 1-800-424-9300. 

Manufactured for: 

RedEagle International LLC 

2651 Woodwind Hills Lane 

Lakeland, Florida 33813 

• , , " > , , 

, , 

, 

" , , " , , 

" , , , " , 

, 

" , , 

.' } , , , ,,,., "J,> 

, , > , 

Ethephon ManufacllJ;i~!J .z:6ncentrate 

24July200.FI,Page 1 of 3 , . , .'> '" 

92
PRECAUTIONARY STATEMENTS 

DANGER 

HAZARDS TO HUMANS AND DOMESTIC ANIMALS 

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

eyes, on skin or on clothing. Wear goggles or face shield. Wear protective clothing and rubber gloves. Wash thoroughly 

with soap and water after handling. Remove contaminated clothing and wash clothing before reuse. 

ENVIRONMENTAL HAZARDS 

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 the sewage treatment plant authority. For guidance, contact your State Water Board or Regional 

Office of the Envirorunental Protection Agency. 

DIRECTIONS FOR USE 

It is a violation of Federal law to use this product in a manner inconsistent with its labeling. Read entire label before using 

this product. This product must be stored and used in ventilated areas only. 

Only For Formulation Into an End-Use Plant Growth Regulator, for: 

(1) The Following Uses: Terrestrial food uses on: apples, barley, blackberries, cantaloupes, cherries (sweet and tart), 

coffee beans, cotton, cucumbers (hybrid seed production), grapes, peppers, pineapples, pumpkins, (hybrid seed 

production), squash (hybrid seed production), sugarcane, tomatoes, walnuts and wheat. Terrestrial non-food uses 

on: grasses grown for seed production, ornamentals, tobacco (flu-cured) and mistletoe. 

(2) UseS for which USEPA has Accepted the Required Data and/or Citations of Data that the Formulator has 

Submitted in Support of Registration. 

(3) UseS for Experimental Purposes that are in Compliance with USEPA Requirements. 

STORAGE AND DISPOSAL 

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

PESTICIDE STORAGE 

Store in a cool, dry place and away from food, feed and other pesticides. IF SPILLED: If container is broken or 

contents have spilled, folIow all precautions indicated above and clean up immediately. Before cleaning up, put on 

fuIl-length trousers, long-sleeved shirt, protective gloves and goggles or face shield. Soak up spill with absorbent 

media such as sand, earth or other suitable material and dispose of waste at an approved waste disposal facility. 

PESTICIDE DISPOSAL 

Pesticide wastes are acutely hazardous. Improper disposal of excess pesticide, spray mixture, or rinsate is a 

violation of Federal law. If these wastes cannot be disposed of by use according to label instructions, contact your 

State Pesticide or Envirorunental Control Agency or the Hazardous Waste representative at the nearest EPA 

Regional Office for guidance. 

CONTAINER DISPOSAL 

Triple rinse (or equivalent) the empty containers. Then offer for recycling or reconditioning, or puncture and 

dispose of in a sanitary landfill or by incineration or, if allowed by state and local authoritj~s! .~y, bumill.~., " ' I ,t' 

container is burned, stay out of smoke. ) :... 

, 

IMPORTANT: Read the entire DIRECTIONS FOR USE and the CONDITIONS OF SALE"AAtV WARRAKi'Y before 

using this product. If terms are not acceptable, return the unopened product container at once. , , , " , , , J)" "" 

, , , , 

Ethephon Manufact~'iir.f) r.6ncenlrate 

24Jul':l200~ page 2 of 3 

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93
, 

! 

DISCLAIMER AND INDEMNITY FOR FORMULATORS' USES 

THE MANUFACTURER EXPRESSLY DISCLAIMS ALL LIABILITY FOR CLAIMS AND ACTIONS (WHETHER 

BASED ON CONTRACT, TORT, STRICT LIABILITY OR BREACH OF WARRANTY) ARISING OUT OF, 

RESULTING FROM OR CONNECTED W1TH A FORJvfULATION CONTAINING THIS PRODUCT WHEN USED FOR 

ANY PURPOSE OTHER THAN TIlOSE USES SET FORTH IN (1) ABOVE. THE MANUFACTURER HAS NOT 

DEVELOPED SCIENTIFIC DATA TO SUPPORT, NOR HAS IT EXPLICITLY OR IMPLICITLY APPROVED, ANY 

USES OTHER THAN THOSE IN (I) ABOVE 

ANY FORlvrULA TOR OR BUYER WHO USES THIS PRODUCT IN FORMULATIONS FOR ANY USE OTHER THAN 

THOSE STATED IN (1) ABOVE ASSUMES ALL LlABnJTY FOR CLAIMS AND ACTIONS ARISING OUT OF, 

CONNECTED WITH OR RESULTING FROM SUCH USE AND AGREES BY SO USING THIS PRODUCT TO 

INDEl\1NIFY AND HOLD HARMLESS THE MANUFACTURER FROM SUCH CLAIMS AND ACTIONS. 

THIS DISCLAIMER AND INDEMNITY IS IN ADDITION TO, NOT IN LIEU OF, THE BELOW DISCLAIMER AND 

LIMITATIONS. 

IMPORTANT: READ BEFORE USE 

Read the entire Directions for Use, Conditions, Disclaimer of Warranties and Limitations of Liability before using this 

product. Iftenns are not acceptable, return the unopened container at once. 

By using this product, user or buyer accepts the following Conditions, Disclaimer of Warranties and Limitations of Liability. 

CONDITIONS: The directions for use of this product are believed to be adequate and should be followed carefully. 

However, it is impossible to eliminate all risks associated with the use of this product. Crop injury, ineffectiveness or other 

unintended consequences may result because of such factors as weather conditions, presence of other materials, or the 

manner of use or application, all of which are beyond the control of Red Eagle International LLC. All such risks shall be 

asswned by the user or buyer. 

DISCLAIMER OF WARRANTIES: REDEAGLE INTERNATIONAL LLC MAKES NO OTHER WARRANTIES, 

EXPRESS OR IMPLIED, OR MERCHANTABILITY OR OF FITNESS FOR A PARTICULAR PURPOSE OR 

OTHERWISE, THAT EXTEND BEYOND THE ST A lEMENTS MADE ON THIS LABEL. No agent of RedEagle 

International LLC is authorized to make any warranties beyond those contained herein or to modify the warranties contained 

herein. TO THE EXTENT CONSISTENT VVITH APPLICABLE LAW, REDEAGLE INTERNATIONAL LLC 

DISCLAIMS ANY LIABILITY WHATSOEVER FOR SPECIAL, INCIDENTAL OR CONSEQUENTIAL DAMAGES 

RESULTING FROM THE USE OR HANDLING OF THIS PRODUCT. 

Ul\1ITATIONS OF LIABILITY: TO THE EXTENT CONSISlENT WITH APPLICABLE LAW, REDEAGLE 

INlERNATIONAL LLC THE EXCLUSIVE REMEDY OF THE USER OR BUYER FOR ANY AND ALL LOSSES, 

INJURIES OR DAMAGES RESULTING FROM THE USE OR HANDLING OF THIS PRODUCT, WHETHER IN 

CONTRACT, WARRANTY, TORT, NEGLIGENCE, STRlCT LIABILITY OR OTHERVVISE, SHALL NOT EXCEED 

THE PURCHASE PRICE PAID, OR ATREDEAGLE INTERNATIONAL LLC ELECTION, THE REPLACEMENT OF 

PRODUCT 

Manufactured for: 

RedEagle International LLC 

2651 Woodwind Hills Lane 

Lakeland, Florida 33813 " , " } , , , " , 

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" ) 1 , " " , , , , I 

, " . , },} } 

, , Ethephon Manufacturir.g,Qoncentrate 

24Ju11'200~ '?age 3 of 3 " , , -' , , 

94
95
96

Pages 96-98 - *Confidential Statements of Formula may be entitled to confidential treatment*