ECANA and ECANA Mimic Page 1 of 60

Biopesticides Registration Action Document

BIOPESTICIDES REGISTRATION ACTION DOCUMENT



## Extract of Chenopodium ambrosioides near ambrosioides (ECANA) (PC Code 599995) and 

## ECANA Mimic (Extract of Chenopodium ambrosioides near ambrosioides Mimic: A blend of biochemical ingredients that is substantially similar to the Extract of Chenopodium ambrosioides near

ambrosioides in com

position.) (PC Code 179102 )

U.S. Environmental Protection Agency Office of Pesticide Programs Biopesticides and Pollution Prevention DivisionECANA and ECANA Mimic Page 2 of 60

Biopesticides Registration Action Document TAB LE OF CONTENTS I. BACKGROUND
................................ ................................ ................................ .......................... 4 II. OVERVI EW
................................ ................................ ................................ ................................ 5 III. REGULATORY BACKGROUND....................................................................................

...... . ... 6 A. Classification

................................ ................................ ................................ .......................... 7 B. Food Clearances/Tolerances

................................ ................................ ................................ ... 7 IV
. RI SK ASSESSMANT
................................ ................................ ................................ .................. 7 A. Active Ingredient Characterization

................................ ................................ ........................ 7 B. Human Health Assessment

................................ ................................ ................................ ... . 8 1 . Toxicology

................................ ................................ ................................ ......................... 8 2. Effects on the Endocrine System

............................................................ ....... . 9 3. Dose Response Assessment
. ................................................................ .................. . .......... 10 4. Food Quality Protection Act Considerations

..................................... ..............................10 C. Environmental Assessment

................................ ................................ ................................ .. 1 2 1. Nontarget Organism Toxicology

................................ ................................ ..................... 1 2 2. Environmental Fate and Ground W ater Data
................................ ................................ . 12 3. Ecological Exposure and Risk Characterization

................................ ............................ 13 4. Endangered Species Statement

................................ ................................ ........................ 13 D. Efficacy

Data
................................ ................................ ................................ ........................ 1 4 V. RI SK MANAGEMENT DECI SI ON
................................ ................................ .......................... 14 A. Determination of Eligibility for Registration

................................ ................................ ....... 14 B. Regulatory

Decision

................................ ................................ ................................ .............. 1 5 C. Env ironmental Justice.....................................................................

.............. 1 6 VI . TERMS AND CONDI TI ONS OF THE REGI STRATI ON
................................ ..................... 1 6 VI I. APPENDIX A.: DATA REQUIREMENTS (40 CFR PART 158)...........................

..... 1 7 VI II. APPENDIX B: PRODUCT SPECIFIC INFORMATION... .......................................24 IX
. APPENDIX C: REFERENCES.............................. ..........................................25ECANA and ECANA Mimic Page 3 of 60

Biopesticides Registration Action Document BIOPESTICIDES REGISTRATION ACTION DOCUMENT TEAM Office of Pesticide Programs: Biopesticides and Pollution Prevention Division Bioch emical Pesticides Branch (BPB) Chris Pfeifer Regulatory Action L eader Angela Gon z ales Science Reviewer Kent Carlson, Ph.D. Biologist Li nda A. Hollis Branch Chief Driss Benmhend Team Leader Russell S. Jones, Ph.D. Senior BiologistECANA and ECANA Mimic Page 4 of 60

Biopesticides Registration Action Document I. Background: Extract of Chenopodium ambrosioides near ambrosioides (ECANA) is classified as a biochemical technical grade of the active ingredient (TGAI). The extract is derived from the flowering plant Chenopodium ambrosioid es near ambrosioides , commonly known as American Wormseed. ECANA is a mix of constituent terpenes (biochemicals), most of which are also active ingredients already registered with the Agency . ECANA is intended for use as an insecticide and acaricide (mit e and tick pesticide) on food crops and commercial ornamental crops . The extract is reported to work through a “ nontoxic ” mode of action by temporarily

softening an insect’s cuticles, which then leads to a disruption in respiration. ECANA Mimic is a blen d of individual terpenes that is substantially similar to the natural extract in composition and effect. Product chemistry data confirm the extract’s structural similarity ; and toxicology

and efficacy

data confirm the equivalency of its effects. Based on assessment of the data submitted in support of ECANA and ECANA Mimic, the two active ingredients are effectively

considered to have the same risk profile, and shall be generally referred to as ECANA, except in cases where assessment of specific ECANA Mimi c data warrants attention. Product chemistry

data requirements (product identity , product analy sis, manufacturing process, and phy sical/chemical properties) , mammalian toxicology data requirements (acute oral, acute dermal, acute inhalation, dermal irritation, ocular irritation, hy persensitivity , 90
- day

oral, dermal and inhalation, prenatal development, and immunotoxicology ) , and e cological toxicity

data requirements (avian acute oral and dietary , freshwater fish LC 50 , freshwater invertebrate LC 50 , nont arget plant toxicity , nontarget plant toxicity ) were fulfilled by

acceptable guideline studies and waiver rationales for both ECANA and ECANA Mimic. No significant issues were identified for dietary risk, residential risk, or ground and surface water cont amination from the use of ECANA as an active ingredient. Some risks from the use of ECANA and ECANA Mimic as an active ingredient were identified for occ upational professions. R isks to these populations , however, were acceptably mitigated through the inclusion of additional personal protective equipment (PPE). Some risks from the use of ECANA and ECANA Mimic as an active ingredient were identified for threatened and endangered species. These risks were acceptably mitigated through label provisions requiri ng spray

buffers and an application interval for rain events. The Agency ’s risk management decision regarding the registration of ECANA also notes the following: 1) the active ingredient is naturally occurring; 2) pesticidal applications of the extract ar e applied directly

to crops and are limited to 10 applications per year; 3) data indicate the extract has a very

low mamma lian toxicity ; and 4) pesticide residues resulting from the intended method of application have been shown to rapidly degrade in terre strial environments. EPA considered ECANA in light of the relevant safety factors in the Food Quality Protection Act (FQPA) of 1996 , and under the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA). TheECANA and ECANA Mimic Page 5 of 60

Biopesticides Registration Action Document Agency has not identified any

dietary or n on - dietary

exposure issues that may affect the U.S. population in general, including infants and children. EPA, thereby , determined that there is reasonable certainty

that no harm will result from aggregate exposure to ECANA residues, including dietary

exp osures and all other sources of exposure. Consistent with the new policy of making registration actions more transparent, ECANA Mimic is subject to a 30 day

comment period as a “new active ingredient” whose registration would result in a “first outdoor us e” and a “first food use.” While a final decision on registration is contingent upon review and consideration of public comments, EPA presently believes that based on the risk assessment and information submitted in support of the registration of ECANA Mi mic that it is in the best interests of the public and the environment to issue the registration for ECANA Mimic

. The basis for this preliminary decision can be found in the risk assessment for ECANA Mimic, which is characterized in this BRAD. As discuss ed above, acute toxicity data for ECANA Mimic indicate a nontoxic profile for acute toxicity

. ECANA Mimic does not demonstrate subchronic toxicity , and it is not mutagenic or genotoxic. The toxicological endpoint for developmental toxicity for occupation al users is not expected to pose a significant risk as users are required to wear personal protective equipment and exposures to ECAN Mimic are expected to be virtually non - existent because of ECANA Mimic’s rapid rate of degradation. EPA has no concerns fo r any nontarget organisms exposed to ECANA Mimic in accordance with approved label directions. EPA has not identified any toxic endpoints for nontarget mammals, birds, plants, or soil organisms. While some aquatic nontarget toxicity has been identified, n o risks are expected because applications are terrestrial, ECANA Mimic biodegrades rapidly , and label directions further negate the potential for aquatic exposure. Because of this lack of exposure, there are no concerns for any threatened and endangered s pecies. Thus, given that ECANA Mimic has very low toxicity , and presents little if any

risk to nontarget organisms, and data confirm its effectiveness as a contact insecticide and acaricide, EPA concludes that it is in the best interests of the public and the environment to issue the registration for ECANA Mimic

. II. ACTIVE INGREDIENT OVERVIEW Common Name: American Wormseed Oil, Chenopodium Oil, ECANA, and ECANA Mimic Chemical Names: Extract of Chenopodium ambro sioides near ambrosioides and Extract of Chenopodium ambrosioides near ambrosioides Mimic Trade & Other Names: QRD 406 and QRD 420 CAS Registry Number: CAS# 89997
- 47
- 7 for ECANA; No CAS for ECANA Mimic OPP Chemical Code: 599995 for ECANA; 179102 f or ECANA Mimic Basic Manufacturer: AgraQuest, Inc. 1540 Drew AvenueECANA and ECANA Mimic Page 6 of 60

Biopesticides Registration Action Document Davis, CA 95618 Type of Pesticide: Biochemical insecticide and acaricide (mite and tick pesticide) for food crops and commercial ornamental crops Use Sites: Applie d to food and ornamental crops . It has outdoor and greenhouse use sites. Target Pests: Control of aphids, plant

- feeding mites, whiteflies, mealy bugs, leafminers, thrips, fungus gnats, and tarnished plant bugs. Formulation Type: Li quid Method a nd Rates of Application: Applied with commonly used ground equipment, hose

- end, pressurized sprayers and hand

- held sprayers. Itis diluted with water to make a sprayable solution. Upper and lower leaves are sprayed to the point of saturation. It is a pplied on a 7

- to 14
- day

schedule as necessary . Timing: Applications should begin at first sign of insect pressure or plant

feeding mite infestation. Use Practice Limitations: Not to be applied more than 10 times per year. Not to be used on fl owering Cyclamen, Gerbera, Begonia, and Impatiens because it can cause phy totoxicity in those plants.
III. REGULATORY BACKGROUND On February

25, 2005, the Agency

received an application filed by Codena, Inc . , Saint

- Charl es sur - Richelieu, Quebec, Canada, JOH 2GO (submitted by L andis International, Inc., P.O. Box 5126, Valdosta, GA 31603

- 5126) to register a manufacturing use product containing 100% of the new biochemical pesticide active ingredient, Extract of Chenopodium a mbrosioides near ambrosioides (PC Code 599995, EPA Reg.# 81978

- R) and two related end use products (EPA Reg.# 81978

- E and EPA Reg.# 81978

- G). A notice of receipt for these applications was published in the Federal Register May

18, 2005 (Volume 70, Number 95). Codena, Inc. was purchased by AgraQuest, Inc. (1520 Drew Ave., Davis, CA, 95618) on January 9, 2006; EPA Registration Numbers were subsequently

transferred to reflect the new Company Number 69592. The manufacturing use product containing 100% Extrac t of Chenopodium ambrosioides near ambrosioides was assigned EPA Reg. # 69592
- 21. In the course of registration , one of the end use products was withdrawn. The remaining use product , which contain s 25% of the active ingredient , was assigned EPA Reg.# 69 592
- 22.ECANA and ECANA Mimic Page 7 of 60

Biopesticides Registration Action Document On July 31, 2008 , EPA issued a notice (Volume 73, Number 148) announcing the filing of a pesticide tolerance petition (PP 7F7299) by AgraQuest, Inc., 1540 Drew Avenue, Davis, CA, 95618. On January

7, 2009 , (Volume 74, Number 4) EPA issued a Fina l Rule establishing an exemption from the requirement of a tolerance for the residues of Extract of Chenopodium ambrosioides near ambrosioides when used as an insecticide/acaricide on all food commodities (40 CFR Section 180.1287). On December 18, 2008, the Agency received an application filed by AgraQuest, Inc., 1520 Drew Ave., Davis, CA, 95618, to register a manufacturing use product containing 100% of the new biochemical pesticide active ingredient, ECANA Mimic (PC Code 179102 , EPA Reg.# 69592
- EU) and a related end use product (EPA Reg.# 69592

- EL). AgraQuest, Inc. also petitioned the Agency to amend ECANA’s exemption from the requirement from tolerance to include ECANA Mimic (Pesticide Petition (PP) # 9F7551) . A notice of receipt for these application s was published in the Federal Register on July

22, 2009 (Volume 74, Number 139). On May 6, 2009 , EPA issued a notice (Volume 74, Number 86) announcing the filing of a pesticide tolerance petition (PP 9F7551) by

AgraQuest, Inc., 1540 Drew Avenue, Davis, C A, 95618. No comments were received in response to either notice of ECANA Mimic. This risk assessment (BRAD) was posted for comment on April 30, 2010. A. C lassification On November 3, 2004, the Biochemical Classification C ommittee classified the Extract of Chenopodium ambrosioides near ambrosioides would be classified as a biochemical pesticide due to its apparent nontoxic mode of action. The extract works through a phy sical mode of action by softening the cuticles of some insects, resulting in a disruption of respiration. In November of 2008, the Biochemical Classification Committee also classified ECANA Mimic as a biochemical active ingredient. B. F ood Clearances/Tolerances An exe mption from the requirement of a tolerance is established for the residues of Extract of Chenopodium ambrosioides near ambrosioides when used as an insecticide/acaricide on all food commodities (40 CFR Section 180.1287) . This risk assessment supports the amendment of this exemption to include ECANA Mimic. In either case, there are no CODEX maximum residue levels established for these active ingredients

. IV. RISK ASSESSMENT A. Active Ingredient Characterization (40 CFR § 158.2030) ECANA is a blended extract product comprised of numerous constituent compounds. Three primary constituent compounds (terpenes) have been identified as product markers. The balance of the constituents, present in small percentages and not common ly known to have toxic properties, isECANA and ECANA Mimic Page 8 of 60

Biopesticides Registration Action Document considered as impurities. The active ingredients are produced via a distillation process, and the impurities in the product are inherent in the active ingredient. ECANA Mimic is a proportional blend of the terpene mar

kers, which is substantially similar to ECANA. Product Chemistry data affirm the proportionality , and toxicology and efficacy

data confirm the similar effect. Refer to Table 1 in Appendix A for a summary of product chemistry

data requirements for ECANA. Refer to Table 2 in Appendix A for the summary of phy sical and chemical characteristics for ECANA; and refer to Table 3, 4 , and 5 for the terpene marker in ECANA Mimic. B. H uman Health Assessment (4 0 CFR § 158.205 0) A dequate mammalian toxicology data/information is available to support registration of ECANA and ECANA Mimic. All toxicology data requirements have been satisfied . Refer to Table 6 in Appendix A for a summary of the toxicity

information on ECANA; refer to Table 7 for the acute toxicity information associated with ECANA Mimic.

. 1. Toxicity For acute toxicity , ECANA is categorized as Toxicity Category I II for acute oral and primary eye. Acute dermal, acute inhalation and primary dermal are categorized as Toxicity Category IV. ECANA is classified as a dermal sensitizer. ECANA Mimic showed similar acute toxicity , but had reduced primary

eye toxicity

and registered as a Toxicity Category IV; it was also found not to be a s ensitizer. Genotoxicity

studies showed ECANA to be non

- mutagenic and to pose no significant hazard with regard to genotoxicity . Cited literature also illustrated common exposure to each of the major marker constituents without observed teratogenic effect . Common exposures without observed effect included: ( 1) common consumption of the marker constituents in our fruits and vegetables; ( 2) regular dermal exposure to the marker constituents through the use of many cosmetics and generalized contact with plants; and ( 3) the natural presence of the marker constituents in much of the air that we breathe, particularly in spaces rich in vegetation. The Agency

accepted wa iv er rationales for the 90

- Day Feeding Study , the 90

- Day Dermal Study , the 90

- Day

Inhalation Study , and the Immune Response requirement. The waivers were accepted because no repeated or subchronic exposures were expected, given the use patterns for this product. The following points were also considered: ( 1) Repeated human exposure by the oral route is not anticipated for ECANA end

- use products ; ( 2 ) Opportunity for exposure is small, given the limited number of applications and the commercial nature of the use sites ; ( 3) A residue decline study showed that the marker components of the active ingredient were not detectable 10 minutes after application to primrose leaves.; ( 4) A study where ECANA was applied four times at 2X the label rate on tomatoes found that the residues of marker components were below the limit of what can be measured (0.01 mg/kg) at 0 to 24 hrs post

- treatment. ( 5) The marker ingredients have all been approved by

FDA for use as food additives, albeit in limited fashion.ECANA and ECANA Mimic Page 9 of 60

Biopesticides Registration Action Document 2. Effects on the Endocrine System As required under FFDCA s ection 408(p), EPA developed the Endocrine Disruptor Screening Program (EDSP) to determine whether certain substances (including pesticide active and other ingredients) may

have an effect in humans or wildlife similar to an effect produced by a “naturally occurring estrogen or other such endocrine effects as the Administrator may designate.” The EDSP employ s a two - tiered approach to making the statutorily required determinations. Tier 1 consists of a battery

of 11 screening assay s to identify the potential of a chemical substance to interact with the estrogen, androgen, or thy roid (E, A, or T) hormonal sy stems. Chemicals that go through Tier 1 screening and are found to have the potential to interact with E, A, or T hormonal sy stems will proceed to the nex t stage of the EDSP where EPA will determine which, if any , of the Tier 2 tests are necessary

based on the available data. Tier 2 testing is designed to identify any adverse endocrine related effects caused by the substance and establish a dose

- response re lationship between the dose and the E, A, or T effect. Between October 2009 and February 2010, EPA is issuing test orders/data call

- ins for the first group of 67 chemicals, which contains 58 pesticide active ingredients and 9 inert ingredients. This list of chemicals was selected based on the potential for human exposure through pathways such as food and water, residential activity , and certain post

- application agricultural scenarios. This list should not be construed as a list of known or likely endocri ne disruptors. ECANA and its constituent markers are not among the group of 58 pesticide active ingredients on the initial list to be screened under the EDSP. Under FFDCA sec. 408(p) , the Agency must screen all pesticide chemicals. Accordingly , EPA anti cipates issuing future EDSP test orders/data call

- ins for all pesticide active ingredients

. For further information on the status of the EDSP, the policies and procedures, the list of 67 chemicals, the test guidelines and the Tier 1 screening battery , pl ease visit our website: http://www.epa.gov/endo/

. All available information supports the determination that ECANA is not an estrogenic, anti

estrogenic, androgenic , or anti

- androgenic compound. ECANA’s constituent markers are naturally occurring compounds that are present in all of our fruits and vegetables. To date, there is no evidence to suggest that our natural exposure to ECANA’s markers affect the immune system, function in a manner similar to any known hor mone, or that they

act as endocrine disruptors. Moreover, the use of ECANA is not expected to result in any significant exposures, effectively obviating any

opportunity

for negative effects on humans or the environment. Therefore, it is unlikely that ECA NA would have estrogenic or endocrine effects. T he Endocrine Disruption Screening Program (EDSP) has established a protocol, which guides the Agency in selecting suspect ingredients for review; and the Agency reserves the right to require new information, should the program require it. Presently , based on the lack of exposure and the negligible toxicity profile of the extract and its mimic, no adverse effects to the endocrine or immune systems are known or expected.ECANA and ECANA Mimic Page 10 of 60

Biopesticides Registration Action Document 3. Dose Response Assessment A devel opmental toxicity study of ECANA established developmental toxicity endpoints of 0.60 mg/kg

- day

for maternal exposures and 0.30 mg/kg

- day for developmental exposures ( DEEM
FCID  analy ses). The endpoints were derived using data on the constituent marker o f the most toxicological significance, and they are considered conservative. The Lo west Observed Adverse Effect Level ( LOAEL) for maternal exposures was 125 mg/kg

- day , and 60 mg/kg

- day for developmental exposure based on abnormal ossification, increases i n skeletal abnormalities , and kidney weights. The endpoints do not trigger chronic testing , in this case, because significant exposure to ECANA or ECANA Mimic is precluded by its rapid degradation and the requirement for personal protective equipment (PPE ). 4 . Food Quality Protection Act (FQPA) Considerations: Dietary Exposure and Risk Characterization Dietary exposure to the residues of the contact insecticide Extract of Chenopodium ambrosio ides near ambrosioides , through food or water, is expected to be virtually nonexistent. And even in the event of exposure, the information on file with the Agency suggests that any

dietary risks would be negligible. Three residue studies demonstrate that the rapid degradation of ECANA leaves no opportunity for post - application exposure. A residue decline study on primrose demonstrated that , when the extract is sprayed at 4X the proposed application rate, residues of the three major active ingredient compo nents declined to non

- detectable levels within 10 minutes (MRID (Master Record I dentification) 47209101). A second study on tomatoes involving four applications of the extract within a 24

- hour period found no detectable residues on any samples collected immediately

following the final application (MRID 46858903). A third residue study on mustard greens involving three applications at twice the application rate found no detectable residues within the hour after the third application (MRID 47548301). Essentia lly , data demonstrate that , by the time ECANA has dried on the plant , there is no detectable residual product. Accordingly , the dietary

risk assessment of ECANA suggests that the lack of exposure to residues of the extract obviate any

dietary hazard, and i t support s an exemption from the requirement to establish a tolerance. E ven if residues were found, they would not be cause for concern because ECANA has been fully assessed and found not to be of toxicological concern. Humans regularly consume all the co nstituent components in the extract through consumption of fruits and vegetables. This regular dietary exposure has not resulted in any known incidents of toxic effect. Moreover, the three primary terpene constituents, comprising 70% of the active ingredie nt, have been approved by FDA for use in cosmetics and as food additives. Finally , information submitted on the acute toxicity , developmental toxicity , and genotoxicity of ECANA confirm a very low toxicity

profile. Insum, no dietary

exposure is expected; but any potential dietary

exposures would not be expected to pose any

quantifiable risk due to a lack of residues of toxicological concern.ECANA and ECANA Mimic Page 11 of 60

Biopesticides Registration Action Document An assessment of ECANA’s three major terpene constituents

- alpha

- terpinene, p

- cy mene, and d

limonene

- further subs tantiate ECANA’s low toxicity profile. All the constituents occur naturally in fruits, vegetables, herbs, spices, and other foods and beverages, and are defined as marker compounds in the blended active ingredient. These three compounds also are permitted as food and fragrance additives in the U.S. and Europe. Each of the constituents has been fully characterized by

EPA , and each has been reassessed for its use in pesticides for food uses in the October 2008 risk assessment referenced above. Based on the i nformation before the Agency , incidental exposures to these three compounds are without known toxicological incident for humans. The general public is exposed daily to low levels of these compounds via ingestion, dermal contact, inhalation through consumpt ion of foods and beverages , and dermal contact with cosmetics, in excess of any exposure expected to result from the use of this extract as a pesticide

. The per capita daily

consumption of these terpene compounds as food additives alone amounts to 13.325 m illigrams (mg) in the U.S. and 40.397 mg in Europe (WHO. Evaluation of Certain Food Additives . WHO Technical Report Series No. 928. Sixty

- third Report of the Joint FAO/WHO Expert Committee on Food Additives. 2005), amounts far in excess of any potential di etary exposures resulting from exposures to residues from this pesticidal extract, as discussed below. Alpha

- terpinene is found in the essential oils of a variety of plants including citrus, peppermint, thy me, basil, and papaya. Per 21 CFR 172.515, it is p ermitted for direct addition to food for human consumption. D

- limonene is a major component of lemon oil, orange oil, and grapefruit oil, and it is a minor component of other fruits, vegetables, meats, and spices. It is widely used as a flavor and fragranc e , and it is generally recognized as safe (GRAS) by the Food and Drug Administration (FDA) as a food additive or flavoring, and as a fragrance additive (21 CFR 182.60). L imonene is a registered by EPA as an active ingredient in 15 pesticides and is exempt from the requirement of a tolerance per 40 CFR 180.539. Humans regularly consume p - cy

mene through such foods as butter, carrots, nutmeg, orange juice, oregano, raspberries, lemon oil, and spices. P

- cy

mene is permitted by

FDA for direct addition to food a s a flavoring substance (21 CFR 172.515). For the reasons set forth below, EPA conclude s that the terpene exposures identified above will either exceed or be comparable to exposures resulting from the use of this extract as a pesticide. The balance of the constituents, while not expected to be active, is also regularly found in fruits, vegetables , and plant extracts , and determined by EPA not to be of toxicological concern when used in pesticides for food uses (Risk Assessments for Extract of Chenopodium am brosioides near ambrosioides dated February 2008 and October 2008). Overall, a thorough analy sis of the constituent compounds of Extract of Chenopodium ambrosioides near ambrosioides indicate s a low toxicity profile and support s an exemption from the requ irement of a tolerance. ECANA and ECANA Mimic are applied directly to food commodities and degrade extremely rapidly . However, the Agency notes that , in any

event, no health risks are expected from pesticidal exposure to ECANA or ECANA Mimic. The Agency

c onsidered human exposure to ECANA in light of the relevant safety factors in FQPA and FIFRA. A determination has been made that no unreasonable adverse effects to the U.S. population in general, and to infants and children in particular, will result from the use of ECANA when label instructions are followed. The Final Rule for ECANA, which provides a more in depthECANA and ECANA Mimic Page 12 of 60

Biopesticides Registration Action Document characterization of the lack of risk, can be found at: http://www.thefederalregister.com/d.p/2009

- 01
- 07
- E8
- 31408
. C. E nvironmental Assessment ( 4 0 CFR § 158.206 0) All nontarget organism, fate , and expression data requirements for ECANA and ECANA Mimic have been met. They are summarized below in Table 8 of Appendix A. 1. Nontarget Organism Toxicology The avian acute oral study (OPPTS 885.4050) and nontarget insects study (OPPTS 850.4350) show practically

no toxicity

to birds or nontarget insects. A waiver granted for the avian dietary study (OPPTS 850.2200) makes clear the low probability of d ietary

exposure to birds. The freshwater fish study

(OPPTS 850.1075) demonstrated moderate toxicity to fish , and an aquatic invertebrate study

(OPPTS 850.1010) s howed high toxicity to daphnids (water fleas). Li mited use patterns and restrictive labeling language will preclude significant risk. A waiver was granted for nontarget plants (OPPTS 850.4350) primarily on the grounds that the applications of ECANA are directed and nontoxic to most plant species (MRID 47209703). Summary information supporting the nontarget organism data can be found in Table 8 of Appendix A. 2. Environmental Fate and Ground Water Data Environmental fate and groundwater data for ECANA and ECANA Mimic were sufficient for registration. Phy sical chemistry data extracted from MRIDs 46396204
- 46396206, 46858802, 47209701, 47209702 and data extracted from a nontarget fish study ( 47209706) and an aquatic invertebrate study

(MRID 47209707) were used in EPA modeling to help quantify the environmental risks . The Agency estimated aquatic residues using the screening model GENeric Estimated Exposure Concentration

- GENEEC v2.0. Based on the estimated environmental concentrations (EECs) from the GENEEC model ( Table 9 ) and results from aquatic studies risk quotients (RQs) were derived to ev aluate the potential risk to aquatic animals (Table 9). The calculated RQs were below the EPA levels of concern (LOC) for fish and aquatic invertebrates (including endangered species) chronically exposed to a pesticide when applied in accordance with the l abel directions. The GENEEC model uses environmental parameters that are ty pical for a “standard agricultural field

- farm pond” to estimate aqueous residues. The primary assumption with GENEEC is that the fields receive one single large rainfall event (ei ther immediately after application or after a latent period of 2 day s) that washes a certain quantity of pesticides from the fields and into the pond. Degradation and adsorptive processes modify the initial mass of pesticides in both environments. Unlike with foliar residues, the constituent markers of ECANA are not degraded or volatilized quickly in water. (The EPA

- estimated aqueous half

- lives for all the constituent markers from a variety of residue measurements taken during the aquatic daphnid study (MRID 47209707), fish toxicity study (MRID 47209706), and aqueous stability study (MRID 47209707 ) ranged from 35.87 hours to 866.67 hours.)ECANA and ECANA Mimic Page 13 of 60

Biopesticides Registration Action Document Aqueous ECANA residue concentrations were estimated by GENEEC for a wide variety of scenarios using aerial, groundboom , and airblast applications. Applications were either “watered in” with a rain event shortly following application or allowed to dry for 2 day s prior to a rain event. Rain events immediately

following application increased residue concentrations in the far m pond to levels such that Daphnid RQs exceeded the L OCs for every application method. Fish remained below the L OCs for normal and threatened and endangered species, suggesting low relative risk to fish. Daphnid RQs from groundboom and airblast to vineyard s applications also were below the LOCs for normal and threatened and endangered species when residues were allowed to dry for 2 day s. As with fish RQs, this suggested that there is low relative risk to aquatic invertebrates from these application methods. The only aerial application to have Daphnid RQs less than the L OCs was one in which the spray dried for 2 day s and the application had a 370 foot buffer. Similar traits were observed for airblast operations to orchards when using a 14

- foot buffer. LOC ex ceedences for certain application methods and environmental conditions required that restrictions or limitations be added to the proposed label to reduce the potential for “high acute risk” in aquatic invertebrates. Specifically , aerial, airblast, and groundboom outdoor methods of application (and presumably other more manual methods such as handwand , as well) require plant treatment prior to a rain event. Additionally waterbody

spray buffers of 14 feet (groundboom and airblast) and 370 feet (aerial) are re quired to mitigate potential “high acute risk” to aquatic invertebrates. 3. Ecological Exposure and Risk Characterization The proposed uses of ECANA and ECANA Mimic are not likely to result in any

ecological risk. Applications of ECANA and ECANA Mimic are not expected to result in significant ecological exposure. The following factors are expected to address any exposure concerns: ( 1) Applications are terrestrial and targeted at commercial crops, which are not optimal foraging habitat s for most avian, mammalian, and invertebrate species ; ( 2) The foliar half

- life of the extract is very short (estimated half

- life 7.36 minutes) following application. The lack of persistence precludes the opportunity

for significant incidental terrestrial exposures and makes it highly unlikely that residues may

migrate to water in the event of a rain event, effectively precluding any

exposures to aquatic nontarget organisms ; ( 3) Potential spray drift is mitigated through labeling provisions for buffer requirements and appl ications intervals prior to rain events, further obviating both nontarget terrestrial and aquatic exposures ; and ( 4) E ven in the event of terrestrial exposure, data suggest a lack of acute toxicity

to terrestrial nontarget organisms. In short, a lack of e xposure precludes all risk; and data suggest that there is no significant toxicity for terrestrial nontarget organisms for this pesticide, which is limited to terrestrial use. 4. Endangered Species Statement InMarch 2008, an ‘Environmental Risk Assessm ent’ on ECANA found that pesticidal use of the active ingredient would result in negligible ecological exposure and that ECANA was ‘Not L ikely to Adversely

Affect’ (NLAA) threatened and endangered (T&E) species. At that time, an NLAAECANA and ECANA Mimic Page 14 of 60

Biopesticides Registration Action Document finding did not requi re consultation and concurrence with U.S. Fish and Wildlife Service (USFWS). In March of 2010, an ‘Environmental Risk Assessment’ on ECANA Mimic determined that the NLAA finding for ECANA could be extended to ECANA Mimic as it is effectively the same comp ound . Five primary factors limit the potential for threatened and endangered species to be exposed : ( 1) Proposed use patterns are directed at commercial crops and preclude spraying near critical habitat for threatened and endangered species. ( 2) The rap id foliar degradation/volatilization (maximum estimated half

- life 7.36 minutes) precludes endangered species from being exposed. ( 3) The proposed use areas are not optimal foraging habitat for most avian and mammalian species, thereby lessening the potent ial for species to move into these areas following ECANA applications. ( 4) The proposed buffers around water bodies will substantially mitigate spray

drift into water bodies, thereby reducing or eliminating exposures to T&E aquatic organisms. ( 5) The pro posed restriction from application prior to rain events also will substantially mitigate the potential for residues to drift or be washed into water bodies, reducing or eliminating exposures to T&E aquatic organisms. D. Efficacy Data No efficacy

data were submitted in support of label claims and product performance for applications containing ECANA
. While the conduct of product performance studies (Efficacy Trials, OPPTS 810.300) is listed as a requirement for all pesticide pro ducts, the Agency customarily

only requires these data to be submitted for review in connection with the registration of products directly

pertaining to the mitigation of disease bearing human health organisms and certain designated Quarantine Pests, i.e., ticks, mosquitoes, fleas, Mediterranean fruit flies, Gy psy Moths, Japanese Beetles , etc. In this case, the registrant did not make any public health pest claims on the label, and a submission of efficacy data was not requested. Nonetheless, the registra nt claims to have such data on file, and is prepared to submit if requested. The registrant has made claims against plant

- feeding mites. While an unqualified claim against mites or a species

- specific claim against a public health pest mite would trigger an efficacy submission, the registrant has submitted information showing that plant

- feeding mites as a class are fundamentally

different than any

species of mite listed as a public health pest in Pesticide Registration Notice 2002

- 1.
V. RISK MANAGEMENT D ECISION A. Determination of Eligibility for Registration Section 3(c)5) of FIFRA provides for the registration of new active ingredients if it is determined that : (A) its composition is such as to warrant the propose d claims for it; (B) its labeling and other materials required to be submitted comply with the requirements of FIFRA; (C) it will perform its intended function without unreasonable adverse effects on the environment; and (D) when used in accordance with wi despread and commonly recognized practice , it will not generally cause unreasonable adverse effects on the environment.ECANA and ECANA Mimic Page 15 of 60

Biopesticides Registration Action Document To satisfy criteria “A” above, ECANA products are not expected to cause unreasonable adverse effects when used according to label ins tructions. Criteria “B” is satisfied by the current label and the data presented in this document. The Agency believes that this pesticidal active ingredient will not cause any

unreasonable adverse effects, as an insecticide and acaricide, and does provid e protection as claimed satisfying Criteria “C.” Criteria “D” was satisfied by the data presented in the initial registration of this biochemical. Therefore, ECANA meets the standard for registration. B. Regulatory Decision The data submitted fulfill the requirements of registration for use of ECANA as a bi o chemical insecticide and acaricide for use on food and ornamental crops. Refer to Appendix B for product

specific information. On October 1, 2009, EPA announced a new policy to provide a more meani ngful opportunity for the public to participate on major registration decisions before they occur. According to this new policy , EPA intends to provide a public comment period prior to making a registration decision for, at minimum, the following ty pes of applications: new active ingredients; first f ood use; first outdoor use; first residential use ; and actions for which the Agency anticipates substantial public interest. A ccordingly , ECANA Mimic i s subject to a 30

- day comment period as a new active ingr edient with both food uses and outdoor uses. At this time, EPA believes, the data submitted fulfill the requirements of registration for products containing ECANA Mimic as an insecticide and acaricide. Acute toxicity data for ECANA Mimic demonstrate that it is toxicity category I II and IV for all routes of exposure. (No toxicological endpoints were established.) Data confirm that ECANA Mimic does not demonstrate subchronic toxicity , and it is not mutagenic or genotoxic. While a developmental toxicity endpoint was established for occupational workers, EPA concludes that a lack of exposure precludes any potential risk. EPA has no concerns for any terrestrial nontarget organisms exposed to ECANA Mimic in accordance with its approved uses. EPA has not id entified any toxic endpoints for nontarget mammals, birds, plants, or soil organisms; and while ECANA Mimic demonstrates some aquatic toxicity , no aquatic exposure is expected. Because of a lack of exposure and the virtual nontoxic ity

of ECANA Mimic to te rrestrial nontarget organisms, EPA there are no concerns for any

threatened and endangered species. Given, the nontoxic character of ECANA Mimic , EPA supports its registration under Section 3(c)(5) of the Federal Insecticide, Fungicide, and Rodenticide Ac t (FIFRA). Refer to Appendix B for product

- specific information. 1. Conditional/Unconditional Registration All data requirements are fulfilled , and EPA has determined that unconditional registration of ECANA is appropriate. All data requirements are fu lfilled and EPA has preliminarily determined that an unconditional registration for ECANA Mimic is warranted under Section 3(c)(5) of FIFRA.ECANA and ECANA Mimic Page 16 of 60

Biopesticides Registration Action Document C. Environmental Justice EPA seeks t o achieve environmental justice

-- the fair treatment and meaningful involve ment of all people, regardless of race, color, national origin, or income

- - in the development, implementation, and enforcement of environmental laws, regulations, and policies. At this time , EPA does not believe that use of pesticide products containing this active ingredient will cause harm or a disproportionate impact on at

- risk communities. For additional information regarding environmental justice issues, please visit EPA’s website at: http://www.epa.gov/compliance/environmentaljustice/index.html

. VI. Terms and Conditions of the Registrations While EPA supports the unconditional registrations of ECANA and ECANA Mimic, applications of these active ingredients are qualifi ed to provide further protection for human health and the environment. The qualifications follow: 1. ECANA and ECANA Mimic are commercial pesticides, and are presently not labeled for residential use. 2. Aerial ap plications and chemigation ( injecting a chemical into irrigation water and apply ing it through the sy stem to the crop or field ) are presently prohibited. 3. ECANA and ECANA Mimic registrations presently require 15 foot spray

buffers around water bodies 4. ECA NA and ECANA Mimic registrations prohibit groundboom and airblast application s when winds exceed 10 mph. 5. ECANA and ECANA Mimic registrations prohibit application within 2 hours of an expected rain event. 6. ECANA and ECANA Mimic cannot be applied to a cro p more than 10 t imes per year. 7. ECANA and ECANA Mimic are prohibited for use on the following ornamentals: flowering Cyclamen, Gerbera, Begonia, and Impatiens.ECANA and ECANA Mimic Page 17 of 60

Biopesticides Registration Action Document VI. Appendix A TABLE 1. Product Chemistry for ECANA ( 40 CFR § 158.2030) TABLE 1. Product Che mistry for ECANA Guideline Reference No. /Property ECANA Citation 830.1550 Product Identity Active Ingredient

- 100.0% by w eight (extract of Chenopodium ambrosioides var. ambrosioides ). Impurities identified. ECANA Mimic does not have ECANA’s impuri ties. ACCEPTABLE MRID 46396201 47209701 47209702

830.1620 Manufacturing Process ECANA is manufactured by a distillation process. ECANA Mimic is produced by blending terpenes. ACCEPTABLE MRID 46396201 47209701 47209702 830.1670 Formation of Unintentional Ingredients Impurities present in the product have been described quantitatively. Ascaridole has been eliminated in the ECANA product. ECANA Mimic does not carry the same degree of impurities. ACCEPTABLE MRID 46396201 47209701 47209702

830.1700 Analysis of Samples The three main constituents of ECANA are analyzed. A number of individual samples are outside proposed certified limits. Blending brings batches within limits. ECANA Mimic is within Agency recommended limits. ACCEPTABLE MRID 463 96202

830.1750 Certification of Limits Considering the variability of plant extracts, the certified limits of ECANA are ACCEPTABLE MRID 46396202 47209701 47209702 830.1800 Analytical Methods The enforcement analytical method is GC

- MS for the thre e central constituents of the active ingredient. Samples are diluted into acetonitrile, analyzed, and quantified against known standards on a Varian 3900 GC system with a Saturn 2100T ion trap mass selective detector. ACCEPTABLE MRID 46396202 47209701 4720 9702

TABLE 2. Physical and Chemical Properties for ECANA ( 40 CFR § 158.2030) TABLE 2. Physical and Chem ical Properties for ECANA ( MRIDs 46396204

- 46396206, 46858802, 47209701, 47209702 ) Guideline Reference No. /Property ECANA 830.6302 Color Pale am ber, light brow

n. Color code 136. Color composition is red=252, green=191, blue=73. 830.6303 Physical State Semi

- volatile liquid 830.6304 Odor Fruity, woodsy, aromatic, characteristic of monoterpene blend. 830.6313 Stability Stability during 14

- day expo sure to iron chips, aluminum wire pieces, iron citrate, or aluminum acetate @ room temperature or 54  C 830.6314 Oxidation/Reduction: Chemical Incompatibility Does not contain oxidizers or reducing agents 830.6315 Flammability Flash point = 118°F 830.63 16 Explodability Non
- explosive 830.6317 Storage Stability Submitted and acceptable 830.6319 Miscibility Not applicable, not intended to be diluted with oil or non

- polar solvents 830.6320 Corrosion Characteristics Submitted and acceptableECANA and ECANA Mimic Page 18 of 60

Biopesticides Registration Action Document 830.6321 Die lectric Breakdow n Voltage Not required for MP or TGAI 830.7000 pH 5.30
- 5.68, mean of 5.46±0.20 (1% dispersion in deionized w ater) 830.7050 UV/Visible Not applicable 830.7100 Viscosity 1.79 mPa.s. (Std Dev = 0.16) 830.7200 Melting Range Not applicabl e 830.7220 Boiling Range 170
- 188  C 830.7300 Bulk Density 0.875
- 0.914, mean of 0.895±0.020 g/mL 830.7370 Dissociation Constant in Water Not applicable 830.7520 Particle Size/Distribution Not applicable 830.7550 Partition Coefficient Marker# 1 = 5.09 Marker# 2 = 5.08 Marker# 3 = 4.85 830.7840 Water Solubility Marker# 1 = 390

- 511 mg/L, mean of 436±54 mg/L Marker# 2 = 138

- 188 mg/L, mean of 160±21 mg/L Marker# 3 = 145

- 212 mg/L, mean of 183±25 mg/L 830.7950 Vapor Pressure 2613 Pa (0.38 psig) @ 20  C 3157 Pa (0.46 psig)@ 25  C T able 3: Physicochemical Properties of α - Terpinene (40 CFR § 158.2030)

Param eter OPPTS # Value (active ingredient) Color 830.6302 Clear, nearly colorless Physical State 830.6303 Liquid Odor 830.6304 Citrus Stability 830.6313 Refer to ECANA Mimic data F lammability 830.6315 117 °F (Tag Closed Cup) Storage Stability 830.6317 Not Applicable Miscibility 830.6319 Not Applicable Corrosion Characteristics 830.6320 Not Applicable Melting point 830.7200 Not Applicable Boiling point 830.7220 173
- 175° C pH 830.7000 Not Applicable Density (20° C) 830.7300 0.840 g/cm3 Water solubility (25° C) 830.7840 5.6 mg/L Solvent solubility (20° C) Soluble in alcohol (100 w t%) Vapor pressure at 20° C 830.7950 0.8 mm HgECANA and ECANA Mimic Page 19 of 60

Biopesticides Registration Action Document Octanol/water partition coefficient, log (K ow ) 830.7570 5.09 UV/visible absorbance maxima 830.7050 265 nm Viscosity 830.7100 Not Determined

– like water Log Koc (Kow

method) 3.688 Koc (Kow

method) 4877 L/kg Henry’s Law Constant 5.250 E
- 2 atm
- m3 /mole Surface Tension (dyne/cm) 26.8 ± 3.0 Ta ble 4: Physicochemical Properties of d - limonene (40 CFR § 158.2030)

Param eter OPPTS # Value (active ingredient) Color 830.6302 Clear, nearly colorless Physical State 830.6303 Liquid Odor 830.6304 Citrus Stability 830.6313 Refer to ECANA Mimic data Fl ammability 830.6315 122 °F (Tag Closed Cup) Storage Stability 830.6317 Not Applicable Miscibility 830.6319 Not Applicable Corrosion Characteristics 830.6320 Not Applicable Melting point 830.7200 Not Applicable Boiling Point 830.7220 178° C pH 830.700 0 Not Applicable Density (20° C) 830.7300 0.841 g/cm3 Water solubility (25° C) 830.7840 14 mg/L Solvent solubility Soluble in alcohol (100 w t%) Vapor pressure at 20° C 830.7950 1.0 mm Hg Octanol/water partition coefficient, log (K ow ) 830.7570 4.85 U V/visible absorbance maxima 830.7050 No absorbance 190

– 800 nm Viscosity 830.7100 Not Determined

– like water Log Koc (Kow

method) 3.801 Koc (Kow

method) 6324 L/kg Henry’s Law Constant 2.535 E
- 2 atm
- m3 /mole Surface Tension (dyne/cm) 25.8 ± 3.0ECANA and ECANA Mimic Page 20 of 60

Biopesticides Registration Action Document Table 5: Physicochemical Properties of p - cymene (40 CFR § 158.2030)

Param eter OPPTS # Value (active ingredient) Color 830.6302 Clear, nearly colorless Physical State 830.6303 Liquid Odor 830.6304 Lemon Stability 830.6313 Refer to ECANA Mimic data Fl ammability 830.6315 125 °F (Tag Closed Cup) Storage Stability 830.6317 Not Applicable Miscibility 830.6319 Not Applicable Corrosion Characteristics 830.6320 Not Applicable Melting point 830.7200 Not Applicable Boiling point 830.7220 177° C pH 830.70 00 NA Density (20° C) 830.7300 0.855 g/cm3 Water solubility (25° C) 830.7840 23 mg/L Solvent solubility Soluble in alcohol (100 w t%) Vapor pressure at 25° C 830.7950 1.46
- 2.0 mm Hg Octanol/water partition coefficient, log (K ow ) 830.7570 5.08 UV/visible absorbance maxima 830.7050 198 nm Viscosity 830.7100 Not Determined

– like water Log Koc (Kow

method) 3.558 Koc (Kow

method) 3614 L/kg Henry’s Law Constant 1.121 E
- 2 atm
- m3 /mole Surface Tension (dyne/cm) 28.5 ± 3.0 TABLE 6. Toxicology Data for ECANA (4 0 CFR § 158.205 0) TABLE 6. Toxicology Data for ECANA Guideline Reference No. /Property Description of Result Methods 870.1100 Acute Oral Toxicity Oral LD50 between 2000 and 5000mg/kg, Toxicity Category III; ACCEPTABLE MRID 4 6396207
870.1200 Acute Dermal Toxicity Dermal LD50>5000mg/kg, Toxicity Category IV; ACCEPTABLE MRID 46396208ECANA and ECANA Mimic Page 21 of 60

Biopesticides Registration Action Document 870.1300 Acute Inhalation Toxicity Inhalation LC50>2.03mg/L, Toxicity Category IV; ACCEPTABLE MRID 46396209 870.2400 Primary Eye Irritation No corneal opacity or iritis noted. Conjunctival irritation resolving by day 4, Toxicity Category III; ACCEPTABLE MRID 46396210 870.2500 Primary Dermal Irritation Very slight erythema persisting through day 14. Very slight edema cle aring by day 7, Toxicity Category IV; ACCEPTABLE MRID 46396211
870.2600 Hypersensitivity Sensitizer; ACCEPTABLE MRID 46396212 Hypersensitivity Incidents Incidents must be reported Incidents must be reported 870.5000 Genotoxicity Not mut agenic to bacterial strains TA98, TA100, TA1535, TA1537 and E coli strain WP2 uvrA W, ACCEPTABLE No chromosome aberrations in human lymphocytes, ACCEPTABLE No induction of DNA repair response in rat hepatocytes, ACCEPTABLE MRID 46456301 MRID 46396214 MRID 46396215
880.3550 Immune Response ACCEPTABLE lim ited exposure waiver rationale MRID 47209703
870.3100 90
- day Feeding (1 spp) ACCEPTABLE lim ited exposure waiver rationale MRID 47209703
870.3250 90
- day Dermal (1 spp) ACCEPTABLE lim ited exposure waiver rationale MRID 47209703
870.3465 90
- day Inhalation (1 spp) ACCEPTABLE lim ited exposure waiver rationale MRID 47209703 870.3700 Prenatal Development (1 spp) ACCEPTABLE lim ited exposure waiver rationale; also Toxicity

endpoint b ased on Marker study in rats: Maternal NOAEL=60 m g/kg - day LOAEL=125 mg/kg

- day; based on decreased w hole body weight and body weight minus uterine weights during pregnancy Developm ental NOAEL=30 m g/kg - day LOAEL=60 mg/kg

- day based on abnormal ossification, i ncreases in skeletal abnormalities and kidney weights MRID 47209703

Table 7. ECANA Mimic Acute Toxicity Results (40 CFR § 158.2050) Study Type/OPPTS Guideline LD 50 /LC 50 /Results Toxicity Category MRID Acute Inhalation Toxicity/OPPTS 870.1300 > 5.14 mg/L IV 48064501 Acute Eye Irritation/OPPTS 870.2400 Minimally irritating IV 4806450 2 Acute Dermal Irritation/OPPTS 870.2500 Non
- irritating IV 4806450 3 Skin Sensitization/OPPTS 870.2600 Not a sensitizer N/A 4806450 4 Table 8. Nontarget Toxicity o f QRD 406 or its Marker Components (40 CFR § 158.2060)

Table 8. Nontarget Toxicity of QRD 406 or its Marker Components Study Type/OPPTS Guideline LD 50 /LC 50 /Results Toxicity Category MRIDECANA and ECANA Mimic Page 22 of 60

Biopesticides Registration Action Document
Avian Acute Oral Colinus virginianus (OPPTS 885.4050) Acute oral LD 50 for northern bobw hites >2250 mg/kg. ACCEPTABLE
. Practically Nontoxic 47209704 Avian Dietary (OPPTS 850.2200) Waiver rationale based on low probability of exposure, low acute avian toxicity. ACCEPTABLE
. N/A 47209703 Freshwater Fish LC 50 Pimephales promelas (OPPTS 850.1075) 96 hr Nominal conc; 20 mg/L 96 hr Modified for aqueous degradation; 2.2 mg/L (C.I. 1.65
- 3.3) ACCEPTABLE
. Moderately Toxic 47209706
Freshwater Invertebrate Daphnia magna (OPPTS 850.1010) 24, 48 hr Nominal conc; 3.3, 1.3 mg/L 24, 48 hr Modified for aqueous degradation; 0.594, 0.234 mg/L (C.I. 0.414
- 0.864 and 0.164

- 0.306). ACCEPTABLE
. Highly Toxic 47209705
Nontarget Plants (OPPTS 850.4100) Salvia, Cosmos, Sweet Allysum NOEC 1%, LOEC based on increased height at 2% and 4%. Begonia NOEC, not determined; LOEC 2% based on foliar burn and flower discoloration at 14

- 21 days. Vinca (strong varietal response) NOEC, not determined; LOEC 2% based on dose

- dependent increase in foliar black spots. Impatiens, Petunias NOEC, not determin ed; LOEC 2% based on dose

- dependent decrease in the number of flowers and open flowers at 21 days Marigold, Tomato, Zinnias NOEC 2% Fury, Ingrid, Grandina Gerbera NOEC, not determined; LOEC 2% based on increase in mature flower necrosis at 7 days, 4% based on increase in bud necrosis at 7 days Jack Frost, Sabrina, Sonia Rose NOEC, not determined; LOEC 4% based on various endpoints such as increased film, increased necrosis on new and old growth foliage by 7 days, increased necrosis on mature flowers and flo we r buds by 7 days. ACCEPTABLE
. N/A 47209703

Nontarget Insects Orius insidiosus Aphidius colemani Bombus impatiens (OPPTS 850.4350) Orius insidiosus ; 48 h; contact toxicity; nymph 29.15 g/L (C.I. 23.33

- 36.14), adult 11.28 g/L (C.I. 7.32

- 15.31) Aphidiu s colemani ; 48 h; contact toxicity; females 13.23 g/L (C.I. 7.50

- 18.90), males 7.70 g/L (C.I. 1.57

- 16.57) Bombus impatiens ; 7, 14 day; contact toxicity; 0.1458 mg/cm

2 (C.I. 0.1180

- 0.2043), 0.0771 mg/cm2 (C.I. 0.0475
- 0.1723) Bombus impatiens ; 7, 14 day; co ntact toxicity; 0.1076 mg/bee, 0.0569 mg/bee; 7, 14 day LC 50 (95% C.I.); 15.4% (7.68

- 101.19), 8.75% (5.69

- 17.67) ACCEPTABLE
. Green peach aphid; 24 h; 0.63% (C.I. 0.47

- 0.79%) Western flower thrip; 24 h; 0.0034 mg/cm 2 (C.I. 0.0027

- 0.0039 mg/cm

2 ) Greenhouse whitefly; 24 h; 0.0066 mg/cm 2 (C.I. 0.0054

- 0.0076 mg/cm

2 ) ACCEPTABLE
. III Practically Nontoxic 47209703ECANA and ECANA Mimic Page 23 of 60

Biopesticides Registration Action Document Table 9. Aqueous Concentrations of ECANA Modeled from GENEEC

1 Daphnid RQs = Peak EEC concentration (mg/L)/0.234 mg/L 2 Fish RQs = Max imum 4 day Average EEC concentration (mg/L)/2.2 mg/L Table 9. Aqueous Concentrations of ECANA Modeled from GENEEC Following Various Outdoor Ap plication Methods Application Method Spray

Buffe r (ft) Wet

In from Rain Event Peak EEC

Concentratio n (μg/L) 1

Daphnid RQ 2 Fish

RQ Max 4

Day Averag e (μg/L) Max

21 Day Averag e (μg/L) Max

60 Day Averag e (μg/L) Max 90

Day Average (μg/L) Airblast

- orchards 100

(14) No 3.92 0.02 (0.05) <0.0

1 3.69 2.09 0.88 0.59 Airblast

- vineyards Non

e No 2.67 0.01 <0.0 1 2.52 1.42 0.60 0.40 Airblast

- vineyards 100 No 0.382 <0.01 <0.0 1 0.359 0.204 0.086 0.058 Groundboom

- high boom

- fine spray 100 No 2.13 0.01 <0.0 1 2.00 1.13 0.48 0.32 Groundboom

- low boom

- fine spray Non

e No 4.95 0.02 <0.0 1 4.67 2.64 1.12 0.75 Groundboom

- low boom

- fine spray 100 No 0.863 <0.01 <0.0 1 0.813 0.460 0.194 0.130ECANA and ECANA Mimic Page 24 of 60

Biopesticides Registration Action Document VII. Appendix B REFERENCES Araujo, I .B., Souza, C.A.M., De
- Carvalho, R.R., Kuriyama, S.N., Rodrigues, R.P., Vollmer, R.S., Alves, E.N., and F.J.R. Paumgartten. 1996. Study of the embryofoetotoxicity of α

- terpinene in the rat. Food and Chemical Toxicology . 34: 477
- 482. El

- Mofty , M.M., Khudoley , V.V., Sakr, S.A., and N.F. Ganem. 1992. Induction of neoplasms in Egy ptian toads Bufo regularis by oil of Chenopodium. Oncology . 49: 25 3
- 255. EPA. 1994. Reregistration eligibility document (RED): L imonene. EPA 738

- R
- 94
- 034. EPA. 1997. Standard operating procedures (SOPs) for residential exposure assessments. Contract No. 68
- W6
- 0030. EPA. 1998. PHED surrogate exposure guide. Estimate s of worker exposure from the Pesticide Handler Exposure Database version 1.1. Scenario 32, 34

- 36. Kapadia, G.J., Chung, E.G., Ghosh, B., Shukla, Y.N., Basak, S.P., Morton, J.F., and S.N. Pradhan. 1978. Carcinogenicity of some folk medicinal herbs in rat s. J. Natl Cancer Inst. 60: 683
- 686. NPI C. 2006. Biopesticide incidents: Reporting period April 1, 1995 to August 21, 2006. National Pesticide Information Center. Environmental and Molecular Toxicology , Oregon State University

. Report Number EPAKCa09/12 /2006. 6pp. World Health Organization. 2005. Evaluation of certain food additives. WHO Technical Report Series 928. 63 rd report of the Joint FAO/WHO Expert Com. on Food Additives. 157 pp.ECANA and ECANA Mimic Page 25 of 60

Biopesticides Registration Action Document VIII. Appendix C Product Labels A. ECANA Manufacturing Use Produ ct Label B. ECANA End Use Product Label C. ECANA Mimic Manufacturing Use Product Label D. ECANA Mimic End Use Product LabelECANA and ECANA Mimic Page 26 of 60

Biopesticides Registration Action Document A. Manufacturing Use Product 

# QRD 406

FOR FORMULATI ON I

NTO I NSECTI CIDE AND ACARI CIDE PRODUCTS FOR M ANUFACTURI

NG OR FORMULATI ON USE ONLY Active Ingredient: Extract of Chenopodium ambrosioides near ambrosioides

................................ ................. 100.0% Total: 100.0%
KEEP OUT OF REACH OF CHILDREN



## CAUTION

FIRST AID If In Eyes  Hold eye open and rinse slowly and gently

with water for 1 5
- 20 minutes. Remove contact lenses, if present, after the first 5 minutes, then continue rinsing eye.  Call a poison control center or doctor for further treatment advice.
If Swallowed  Call poison control center or doctor for treatment advice.

 Have pers on sip a glass of water if able to swallow.  Do not induce vomiting unless told to do so by the poison control center or doctor.  Do not give any

thing by mouth to an unconscious person. If on Skin or Clothing:  Take off contaminated clothing.

 Rinse skin imm ediately with plenty

of water for 15

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

HOT LINE NUMBER CHEMTREC (800) 424 - 9300 (24 hours) Have the product container or label with you when calling a poison control center or docto r or going for treatment. See side/back panels for additional precautionary statements EPA Reg No. 69592
- 21 EPA Establishment No. 69592
- MEX
- 1 Net Contents : 2.5 gallon (320 fl. oz.) (9.5 L )

[4 gallon (15.2 L )] Manufactured By : AgraQuest, Inc. 154 0 Drew Avenue Davis, California 95618 (530) 750

- 0150

### PRECAUTIONARY STATEMENTS

HAZARD TO HUMANS AND DOMESTIC ANIMALS CAUTI ON: Harmful if swallowed. Causes moderate eye irritation. Avoid contact with eyes or clothing. Wash thoroughly with soap and water after handling and before eating, drinking, chewing gum or using tobacco. Prolonged or frequently repeated skin contact may cause allergic reactions in some individuals. Mixers, loaders and handlers must wear the appropriate personal protective equip ment (PPE): coveralls, chemical

- resistant gloves and protective eyewear. Remove and wash contaminated clothing before reuse. ENVIRONMENTAL HAZARDS Do not discharge effluent containing this product into lakes, streams, ponds, estuaries, oceans or other w aters unless in accordance with the requirements of a National Pollutant Discharge Elimination Sy stem (NPDES) permit and the permitting authority h as been notified in writing prior to discharge. Do not discharge effluent containing this product to sewer systems without previously notifying the local sewage treatment plant authority

. For guidance contact yo ur State Water Board or Regional Office of the EPA
. D o not contaminate water when disposing of equipment washwaters or rinsate. This pesticide is toxic to aquatic invertebrates. PHYSICAL OR CHEMICAL HAZARDS Combustible. Do not use or store near heat or open flame. 

### DIRECTIONS FOR USE Itis a violation of Federal law to use this product in a manner inconsistent with its labeling. QRD 406 is intended for use in the formulation of insecticides and acaricides to be applied to field and container

- grown non - food ornamental plants in commercial nurseries, greenhouses, and lath

- and shade houses

. This product may

be used to formulate products for any addit ional uses not listed on the MP label if the formulator, user group, or grower has complied with U.S. EPA data submission requirements regarding the support of such uses. Products formulated from this technical material will require registration with the U.S. Environmental Protection Agency (EPA). STORAGE AND DISPOSAL Do not contaminate water, food or feed by storage or disposal. Pesticide Storage: Store in a cool dry place. Avoid freezing. Pesticide Disposal: To avoid wastes, use all material in thi s container by a pplication according to label directions. I f wastes cannot be avoided, offer remaining product to a waste disposal facility o r pesticide disposal program (often such programs are run by state or local governments or by industry). Do not co ntaminate water when disposing of equipment washwater or rinsate. P esticide wastes may be toxic. Improper disposal of unused pesticide, washwater or rinse water is a violation of federal law. Container Disposal: Nonrefillable container. Do not reuse or refill this container

. Triple rinse container (or equivalent) promptly a fter emptying. Triple rinse as follows: E mpty t he remaining contents into application equipment or a mix tank and drain for 10 seconds after the flow begins to drip. F ill the container 1⁄4 full with water and recap. S hake for 10 seconds. P our rinsate into application equipment or a mix tank or store rinsate for later use or disposal. D rain for 10 seconds after the flow begins to drip. R epeat this procedure two more times. Then o ffer for recycling if available, or puncture and dispose of in a sanitary landfill or by

incineration. Do not burn unless allowed by state and local ordinances.ECANA and ECANA Mimic Page 28 of 60

Biopesticides Registration Action Document B. End Use Product Label 

# QRD 400 Insecticide and Acaricide F OR U SE ON N ON - F OOD O RNAMENTALS (T REES , S HRUBS , AND B EDDING PLANTS ) N OT F OR RESIDENTIAL U SE Active Ingredient: Extract of Chenopodium ambrosioides near ambrosioides

................................ ................................ .................. 25.0% Other Ingredients

................................ ................................ ................................ ................................ ................. 75.0% Total: 100.0% KEEP OUT OF REACH OF CHILDREN



## CAUTION
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 further treatment advice. In On Skin Or Clothing  Take off contaminated clothing.  Rinse skin immediately with plenty of water for 15

- 20 minutes.  Call a poison control center or doctor for further treatment advice.

HOT LINE NUMBER CHEMTREC (800) 424 - 9300 (24 hours) Have the product container or label with you when calling a poison control center or doctor or going for treatment.

See side/back panels for additional precautionary statements EPA Reg No. 69592
- 22 EPA Establishment No. 69592

- MEX
- 1 Net Contents: 1 gallon (128 fl. oz.) (3.8 L)

[ 2.5 g allon (320 fl. oz.) (9.5 L)] Manufactured By : AgraQuest, Inc. 1540 Drew Avenue Davis, California 95618 (530) 750

- 0150 

### PRECAUTIONARY STATEMENTS HAZARD TO HUMANS AND DOMESTIC ANIMALS CAUTI ON : Causes moderate eye irritation. Avoid contact with skin, eyes or clothing. Wash thoroughly

with soap and water after handling and before eating, drinking, chewing gum orECANA and ECANA Mimic Page 29 of 60

Biopesticides Registration Action Document using tobacco. Remove and wash contaminated clothing before reuse. Prolonged or frequently repeated skin contact may cause allergic reactions i n some individuals. Wear the appropriate Personal Protective Equipment (PPE). PERSONAL PROTECTIVE EQUIPMENT Applicators mixers, loaders and other handlers must wear:  Lo ng - sleeved shirt and long pants  Chemical

- resistant gloves made of any waterproof material  Shoes plus socks  Protective eyewear  Coveralls for high

- pressure handwand and groundboom applicators.  For greenhouse uses, applicators and other handlers must wear a NI OSH
- approved respirator with an organic vapor (OV) cartridge or canister with any R, P or HE filter. Follow the manufacturer’s instructions for cleaning/maintaining PPE. I f no such instructions for washables, use detergent and hot water. Keep and wash PPE separately from other laundry

. USER SAFETY RECOMMENDATIONS Users should: ● Remove clothing immediately if pesticide gets inside. Then wash thoroughly and put on clean clothing. ● Remove PPE immediately a fter handling this product. Wash the outside of gloves before removing. As soon as possible, wash thoroughly and change into clean cl othing. ENVIRONMENTAL HAZARDS This product is toxic to aquatic invertebrates. For terrestrial uses: Do not apply directly to water or to areas where surface water is present, or to intertidal areas below the mean high water mark. Do not contaminate water when disposing of equipment washwater or rinsate. Drift and runoff may

be hazardous to aquatic organisms in water adjacent to treated areas. Do not apply when weather conditions favor drift or runoff from treated areas. Do not apply when a rain event is expected within 2 hours. Air blast applications must maintain a spray buffer of 15 feet from any

waterbody . See the Directions for Use for details. PHYSICAL OR CHEMICAL HAZARDS Combustible. Do not use or store near heat or open flame. 

### DIRECTIO NS FOR USE It is a violation of Federal law to use this product in a manner inconsistent with its labeling
. READ THE ENTIRE LABEL. USE STRI CTLY I N ACCORDANCE WI TH THE LABEL. FAILURE TO FOLLOW DIRECTI ONS AND PRECAUT IO NS ON THI S LABEL M AY RESUL T I

N CROP IN JURY, POOR I NSECT CONTROL , AND/OR I LLE GAL RESIDUES. Do not apply

this product in a way

that will contact workers or other persons, either directly o r through drift. O nly

p rotected handlers may

b e in the area during application. For any requirements specific to yo ur state or tribe, consult the State or Tribal agency r esponsible for pesticide regulation.ECANA and ECANA Mimic Page 30 of 60

Biopesticides Registration Action Document AGRICULTURAL USE REQUIREMENTS Use this product only

i n accordance with its labeling and with the Worker Protection Standard, 40 CFR Part 170. This S tandard contains requirements for the protection of agricultural workers on farms, forests, nurseries, greenhouses and handlers of agricultural insecticides. It contains requirements for training, decontamination, notification and emergency a ssistance. It also contains specific instructions and exceptions pertaining to the statements on this label about personal protective equipment (PPE) and restricted

- entry i nterval. The requirements in this box only a pply t o uses of this product that are covered by th e Worker Protection Standard. Do not enter or allow worker entry into treated areas during the restricted entry interval (REI) of 4 hours. PPE required for early

e ntry t o treated areas that is permitted under the Worker Protection Standard and that invol ves contact with any thing that has been treated, such as plants, soil or water is:  Lo ng - sleeved shirt and long pants  Chemical

- resistant gloves made of any waterproof material  Shoes plus socks NON - AGRICULTURAL USE REQUIREMENTS The requirements in this box apply to uses that are NOT within the scope of the Worker Protection Standard for agricultural pesticides (40 CFR Part 170). The WPS applies when this product is used to produce agricultural plants on farms, nurseries or green houses. Do not enter trea ted areas without protective clothing until spray has dried. Refer to Personal Protective Equipment section under the Precautionary Statements section. GENERAL INFORMATION QRD 400 is an Emulsifiable Concentrate (EC) Insecticide and Acaricide for Use on F ield and Container

- grown Non
- Food Ornamental Plants in Commercial Nurseries, Greenhouses, and Lath

- and Shade

- houses. Not For Residential Use. QRD 400 is a c ontact insecticide/acaricide for use in the control of aphids, plant

- feeding mites, whiteflies, me aly

bugs, leafminers, thrips, fungus gnats, and tarnished plant bugs. QRD 400 can be applied to field and container

- grown non - food ornamentals

– trees, Christmas trees, shrubs, flowers, annual and perennial bedding plants, potted flowers, and tropical plants. MIXING AND APPLICATION INSTRUCTIONS Do not apply

this product by

aerial application or through any ty pe of irrigation sy stem. QRD 400 is toxic to aquatic invertebrates. Users must maintain the following buffer zones: Airblast spray

applicators mu st not apply within 15 feet of aquatic habitats (such as, but not limited to, lakes, reservoirs, rivers, streams, marshes, ponds, estuaries, and commercial fish ponds). Groundboom and airblast applicators must also account for wind direction and speed. O nly apply this product if the wind direction favors on

- target deposition. Do not apply when the wind velocity

exceeds 10 mph. Do not apply when a rain event is expected within 2 hours.ECANA and ECANA Mimic Page 31 of 60

Biopesticides Registration Action Document Shake container well before use. QRD 400 must be diluted with water for spray applications. Partially fill the spray

tank with clean water, add the specified amount of QRD 400 to the tank (see table below), and finish filling the tank to the desired volume to obtain the proper spray concentration for the desired applicatio n rate per acre.

Gallons Water per Acre QRD 400 gallons

0.5% solution QRD 400 gallons 1% solution 25 0.12 (16 fl oz) 0.25 (32 fl oz) 50 0.25 (32 fl oz) 0.5 (64 fl oz) 75 0.37 (48 fl oz) 0.75 (96 fl oz) 100 0.5 1 For smaller quantities, mix at a rate of 0.65

– 1.3 fl. oz. QRD 400 per 1 gallon of water. Apply on a 7
- to 14
- day

schedule as necessary . Apply QRD 400 at first sign of insect pressure or plant

- feeding mite infestation. Use higher application rate under conditions of heavy pest pressure. Uniform coverage of both upper and lower leaves is critical for effective pest control. Avoid over spraying to the point of excessive runoff. Do not apply QRD 400 more than 10 t imes per year. QRD 400 can be applied with commonly used ground e quipment, hose

- end, pressurized, greenhouse, and hand

- held sprayers. Biological Control Agents: This product is compatible with the following biological control agents: Encarsia formosa , Amblyseius fallacis , Phytoseiulus persimilis , Orius insidiosus, Ap hidius colemani, Zetzellia mali, Neoseiulus fallacies, Typhlodromus pyri, Stethorus punctum, lacewings, sy

rphid fly larvae, phy

toseiid mite predators, aphid midges, lady beetles, and other predacious mites. Wait at least 2 hours after application before introducing new biological agents, or spray

the evening before the day of introduction of new biological control agents. AgraQuest is committed to the practice of sound resistance management programs that include rotation and tank mixing with other treatments having a variety of modes of actions. Compatibility: Do not combine QRD 400 in the spray tank with other pesticides, surfactants, adjuvants, or fertilizers if there has been no previous experience or use of the combination to show it is phy sically compatible, effective and non

- injurious under your use conditions. To ensure compatibility

of tank

- mix combinations they must be evaluated prior to use. To determine the phy sical compatibility of this product with other products, use a jar test. Using a quart jar, add the proportionate amounts of the products to approximately one quart of water with agitation. Add dry

formulations first, then flowables, then emulsifiable concentrates last. After thorough mixing, allow this mixture to stand for 5 minutes. If the combination remains mixed or can be readily

remixed, it is phy sically

compatible. Once compatibility has been proven, use the same procedure for adding required ingredients to the spray tank. Test the combination on a small number of plants to chec k for phy totoxicity before treating large areas. Do not use the combination if adverse effects are observed.ECANA and ECANA Mimic Page 32 of 60

Biopesticides Registration Action Document PLANTS EVALUATED FOR PHYTOTOXICITY QRD 400 has been evaluated alone in a wide range of crops and ornamentals. However, since testing on all varie ties of all ornamentals is not feasible, testing a small portion of the area to be treated for phy

totoxicity is required before treating the entire area. Further, all possible combinations or sequences of pesticide sprays, including other fertilizers, surf actants, adjuvants and other pesticides, have not been tested ; thus , testing for compatibility and phy totoxicity of spray mixtures is required. Use the product in accordance with all label use directions. Itis further required that spray equipment used to apply QRD 400 be thoroughly cleaned before use. Phy totoxicity has occasionally

been observed following the use of this product on flowers of Cyclamen, Gerbera, Begonia, and Impatiens. Do not use QRD 400 on flowering Cyclamen, Gerbera, Begonia, and Impat iens. STORAGE AND DISPOSAL Do not contaminate water, food or feed by storage or disposal. Pesticide Storage: Store in a cool dry place. Avoid freezing. Pesticide Disposal: To avoid wa stes, use all material in this container by application according to label directions. I f wa stes cannot be avoided, offer remaining product to a wa ste disposal facility or pesticide disposal program (often such programs are run by state or local governments or by industry). Do not contaminate water when disposing of equ ipment wa shwater or rinsate. P esticide wa stes may be toxic. I mp roper disposal of unused pesticide, w ashwater or rinse water is a violation of federal law. Container Disposal: Non
- refillable container. Do not reuse or refill this container Triple rinse container (or equivalent) prom ptly after emptying. Triple rinse as follows: E mp ty the remaining contents into application equipment or a mix tank and drain for 10 seconds after the flow begins to drip. F ill the container 1⁄4 full with water and recap. S hake for 10 seconds. P our rinsate into application equipment or a mix tank or store rinsate for later use or disposal. Drain for 10 seconds after the flow begins to drip. Repeat this procedure two more times. Then offer for recycling if available, or pu ncture and dispose of in a sanitary landfill or by incineration. D o not burn unless allow ed by state and local ordinances. WARRANTY AND DISCLAIMER STATEMENT AgraQuest warrants to those persons lawfully purchasing this product that at the time of the firs t sale of this product by

Seller that this product conformed to its description and was reasonably fit for the purposes stated on the label when used in accordance with Seller’s directions. Buyers and users of this product assume the risk of any use contr ary

to such directions. EXCEPT AS PROVIDED ELSEWHERE I N WRI TI NG CONTAI

NI NG AN EXPRESS REFERENCE TO THI S WARRANTY AND L IM IT ATI ON OF DAMAGES, SELLER MAKES NO OTHER EXPRESS OR IMPL IE D WARRANTY OR GUARANTY, I NCLUDI NG ANY OTHER EXPRESS OR IMPL IE D WARRANTY OF FI TNESS OR OF MERCHANTABILIT Y AND NO AGENT OF SELLER IS AUTHORIZED TO DO SO. Except to the extent prohibited by applicable law, AgraQuest offers this product with the following conditions: 1) buyers and users of this product assume the risk of any storage, handling or use contrary to AgraQuest’s label and directions and 2) AgraQuest’s liability shall in no case exceed the purchase price of the applicable AgraQuest product.ECANA and ECANA Mimic Page 33 of 60

Biopesticides Registration Action Document C. ECANA Mimic Manufacturing Use Product Label



# QRD 420
FOR FORMULATION INTO INSECTICID E AND ACARICIDE PRODUCTS FOR MANUFACTURING OR FORMULATION USE ONLY Active Ingredient: ECANA Mimic*

................................ ................................ ................................ ................................ ............ 67 .0% Other Ingredients

................................ ................................ ................................ ................................ ........... 33 .0% Total: 100.0% * ECANA mimic is a blend of nature

- identical components that substantially replicate the composition and activ ity of plant

- produced Extract of Chenopodium ambrosioides near ambrosioides (ECANA). KEEP OUT OF REACH OF CHILDREN



## CAUTION
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 further treatment advice.
If Swallowed  Call poison control center or doctor for treatment advice.

 Have person sip a glass of water if able to swallow.  Do n ot induce vomiting unless told to do so by the poison control center or doctor.  Do not give anything by mouth to an unconscious person. If on Skin or Clothing:  Take off contaminated clothing.

 Rinse skin immediately with plenty of water for 15

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

HOT LINE NUMBER CHEMTREC (800) 424 - 9300 (24 hours) Have the product container or label with you when calling a poison control center or doctor or going for treatment.

See side/back panels for additional precautionary statements EPA Reg No. 69592
- EU EPA Establishment No. 69592
- MEX
- 1 Net Contents: 2.5 gallon (320 fl. oz.) (9.5 L)

[4 gallon (15.2 L)] Manufactured By : AgraQuest, Inc. 1540 Drew Avenue Davis, California 95618 (530) 750

- 0150ECANA and ECANA Mimic Page 3 4 of 60

Biopesticides Registration Action Document



### PRECAUTIONARY STATEMENTS HAZARD TO HUMANS AND DOMESTIC ANIMALS CAUTION: Harmful if swallowed. Causes moderate eye irritation. Avoid contact with eyes or clothing. Wash thoroughly

with soap and water after handling and before eating, drinking, c hewing gum or using tobacco. Prolonged or frequently repeated skin contact may cause allergic reactions in some individuals. Mixers, loaders and handlers must wear the appropriate personal protective equipment (PPE): coveralls, chemical

- resistant gloves and protective eyewear. Remove and wash contaminated 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 Sy stem (NPDES) permit and the permitting authority h as been notified in writing prior to discharge. Do not discharge effluent containing this product to sewer sy stems without previously n otifying the local sewa ge treatment plant authority . For guidance contact your State Water Board or Regional Office of the EPA . Do not contaminate water when disposing of equipment washwaters or rinsate
. This pesticide is toxic to aquatic invertebrates. PHYSICAL OR CHEMICAL HAZARDS Combustible. Do not use or store near heat or open flame. 

### DIRECTIONS FOR USE It is a violation of Federal law to use this product in a manner inconsistent with its labeling. QRD 420 is intended for use in the formulation of insecticides and ac aricides to be applied to field and container

- grown plants in commercial nurseries, greenhouses, and lath

- and shade houses, and labeled agricultural crops

. This product may

be used to formulate products for any additional uses not listed on the MP label if the formulator, user group, or grower has complied with U.S. EPA data submission requirements regarding the support of such uses. Products formulated from this technical material will require registration with the U.S. Environmental Protection Agency (EPA). STORAGE AND DISPOSAL Do not contaminate water, food or feed by storage or disposal. Pesticide Storage: Store in a cool dry place. Avoid freezing. Pesticide Disposal: To avoid wastes, use all material in this container by a pplication according to label directions. I f wastes cannot be avoided, offer remaining product to a waste disposal facility o r pesticide disposal program (often such programs are run by state or local governments or by industry). Do not contaminate water when disposing of equ ipment washwater or rinsate. P esticide wastes may be toxic. Improper disposal of unused pesticide, washwater or rinse water is a violation of federal law
. Container Disposal: Nonrefillable container. Do not reuse or refill this container Triple rinse container (or equivalent) promptly a fter emptying. Triple rinse as follows: E mpty the remaining contents into application equipment or a mix tank and drain for 10 seconds after the flow begins to drip. F ill the container 1⁄4 full with water and recap. S hake for 10 seconds. P our rinsate into application equipment or a mix tank or store rinsate for later use or disposal. Drain for 10 seconds after the flow begins to drip. Repeat this procedure two more times. Then offer for recycling if available, or puncture and dispose of in a sanitary landfill or by

incineration. Do not burn unless allowed by state and local ordinances.ECANA and ECANA Mimic Page 35 of 60

Biopesticides Registration Action Document D. ECANA Mimic End Use Product Label



# QRD 452 [Alternate Brand Names: REQUIEM ® 

### 16.75 EC , METRONOME TM 

### II ] Master Label Sub

- Label A: Agricultural/Commercial Use Sub

- Label B: Greenhouse & Nursery/Commercial Use

Active Ingredient: ECANA Mimic*

................................ ................................ ................................ ................................ .......... 16.75 % Other Ingredients

................................ ................................ ................................ ................................ ......... 83.25 % Total: 100.0% * ECANA mimic is a blend of nature

- identical components that substantially replicate the composition and activity of plant

- produced Extract of Chenopodium ambrosioides near ambrosioides (ECANA). KEEP OUT OF REACH OF CHILDREN



## CAUTION

EPA Reg No. : 69592
- EL EPA Establishment No. : 69592
- MEX
- 1 Manufa ctured By : AgraQuest, Inc. 1540 Drew Avenue Davis, California 95618 (530) 750

- 0150ECANA and ECANA Mimic Page 36 of 60

Biopesticides Registration Action Document



# QRD 452 (Alternate Brand Name: REQUIEM ® 

# 16.75 EC )

Sub - Label A For Agricultural / Commercial Use Only Not For Residential UseECANA and ECANA Mimic Page 37 of 60

Biopesticides Registration Action Document 

# REQUIEM ® 

# 16.75 EC

I NSECTICIDE AND A CARICIDE FOR CONTROL OR SUPPRESSION OF AP HIDS , THRIPS , WHITEFLIES , PLANT - FEEDING MITES , MEALY BUGS , LEAFMINERS , LYGUS BUGS , SCALE , LEAF HOPPERS , AND LEPIDOPTEROUS INSECT S IN AGRICULTURAL CR OPS .

N OT F OR RESIDENTIAL U S E Active Ingredient: ECANA Mimic*

................................ ................................ ................................ ................................ .................. 16.75 % Other Ingredients

................................ ................................ ................................ ................................ ................. 83.25 % Total: 100.0% * ECANA mimic is a blend of nature

- identical components that substantially replicate the composition and activity of plant

- produced Extract of Chenopodium ambrosioides near ambrosioides (ECANA). KEEP OUT OF REACH OF CHILDREN



## CAUTION

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 l a poison control center or doctor for further treatment advice. In On Skin Or Clothing  Take off contaminated clothing.  Rinse skin immediately with plenty of water for 15

- 20 minutes.  Call a poison control center or doctor for further treatment advice.

HOT LINE NUMBER CHEMTREC (800) 424 - 9300 (24 hours) Have the product container or label with you when calling a poison control center or doctor or going for treatment. See side/back panels for additional precautionary statements EPA Reg No. : 69592
- E L EPA Establishment No. : 69592
- MEX
- 1 Net Contents: 2.5 gallon (320 fl. oz .) (9.46 L)

Manufactured By : AgraQuest, Inc. 1540 Drew Avenue Davis, California 95618 (530) 750

- 0150ECANA and ECANA Mimic Page 38 of 60

Biopesticides Registration Action Document



### PRECAUTIONARY STATEMENTS HAZARD TO HUMANS AND DOMESTIC ANIMALS CAUTI ON : Causes moderate eye irritation. Avoid contact with skin, eyes or clothing. Wash thoroughly

with soap and water after handling and before eating, drinking, chewing gum or using tobacco. Remove and wash contaminated clothing before reuse. Prolonge d or frequently repeated skin contact may

cause allergic reactions in some individuals. Wear the appropriate Personal Protective Equipment (PPE). PERSONAL PROTECTIVE EQUIPMENT Applicators mixers, loaders and other handlers must wear:  Lo ng - sleeved shirt and long pants  Chemical

- resistant gloves made of any waterproof material such as polyethylene or poly vinyl chloride  Shoes plus socks  Protective eyewear  Coveralls for high

- pressure handwand and groundboom applicators.  For overhead exposure wear chemical resi stant headgear.  For greenhouse uses, applicators and other handlers must wear a NI OSH
- approved respirator with an organic vapor (OV) cartridge or canister with any R, P or HE filter. Follow the manufacturer’s instructions for cleaning/maintaining P PE. I f no such instructions for washables, use detergent and hot water. Keep and wash PPE separately from other laundry

. Engineering Controls: When handlers use enclosed cabs in a manner that meets requirements listed in the Worker Protection Standard (WPS) for agricultural pesticides [40 CFR 170.240 (d) (4

- 6)], the handler PPE requirements may

be reduced or modified as specified in the WPS. USER SAFETY RECOMMENDATIONS Users should: ● Remove clothing immediately if pesticide gets inside. Then wash thoroughly and put on clean clothing. ● Remove PPE immediately after handling this product. Wash the outside of gloves before removing. As soon as possible, wash thoroughly and change into clean clothing. ENVIRONMENTAL HAZARDS This product is toxic to aquatic invertebrates. For terrestrial uses: Do not apply directly to water or to areas where surface water is present, or to intertidal areas below the mean high water mark. Do not contam inate water when disposing of equipment washwater or rinsate. Drift and runoff may

be hazardous to aquatic organisms in water adjacent to treated areas. Do not apply when weather conditions favor drift or runoff from treated areas. Do not apply when a r ain event is expected within 2 hours. Groundboom and air

- blast applications must maintain a spray buffer of 15 feet from any

water body

. See the Directions for Use for details.



### DIRECTIONS FOR USE It is a violation of Federal law to use this product in a manner inconsistent with its labeling
. READ THE ENTIRE LABEL. USE STRI CTLY I N ACCORDANCE WI TH THE LABEL
.ECANA and ECANA Mimic Page 39 of 60

Biopesticides Registration Action Document FAILURE TO FOLLOW DIRECTI ONS AND PRECAUT IO NS ON THI S LABEL M AY RESUL T INCROP I

NJURY, POOR IN SECT CONTROL , AND/ OR I LLEGAL RESIDUES. Do not apply this product in a way that will contact workers or other persons, either directly or through drift. Only

protected handlers may

be in the area during application. For any requirements specific to your state or tribe, consult the State or Tribal agency r esponsible for pesticide regulation. AGRICULTURAL USE REQUIREMENTS Use this product only

in accordance with its labeling and with the Worker Protection Standard, 40 CFR Part 170. This Standard contains requirements for the protection of agricultural wo rkers on farms, forests, nurseries, greenhouses and handler s of agricultural insecticides. Itcontains requirements for training, decontamination, notific ation and emergency assistance. Italso contains specific instructions and exceptions pertaining to th e statements on this label about personal protective equipment (PPE) and restricted

- entry interval. The requirements in this box only apply to uses of this product that are covered by the Worker Protection Standard. Do not enter or allow worker entry in to treated areas during the restricted entry interval (REI) of 4 hours. PPE required for early

entry to treated areas that is permitted under the Worker Protection Standard and that involves contact with any thing that has been treated, such as plants, so il or water is:  Lo ng - sleeved shirt and long pants  Chemical

- resistant gloves made of any waterproof material such as polyethylene or poly vinyl chloride  Shoes plus socks
SHAKE WELL BEFORE USE GENERAL INFORMATION REQUI EM ® is a c ontact insecticide/acaric ide for use in the control or suppression of many foliage feeding plants including aphids, thrips, plant

- feeding mites, whiteflies, mealy bugs, leafminers, lygus bugs, scale, leaf hoppers, and lepidopterous insects infesting labeled crops. The emulsifiable concentrate of REQUI EM must be mixed with water and applied as a foliar spray with ground equipment equipped for conventional insecticide spray ing. MIXING AND APPLICATION INSTRUCTIONS Do not apply

this product by

aerial application or through any ty pe of irrigation sy stem. REQUI EM is toxic to aquatic invertebrates. Users must maintain the following buffer zones: Groundboom and air

- blast spray applicators must not apply within 15 feet of aquatic habitats (such as, but not limited to, lakes, reservoir s, rivers, streams, marshes, ponds, estuaries, and commercial fish ponds). Groundboom and air

- blast applicators must also account for wind direction and speed. Only apply this product if the wind direction favors on

- target deposition. Do not apply

when th e wind velocity

exceeds 10 mph. Do not apply when a rain event is expected within 2 hours.ECANA and ECANA Mimic Page 40 of 60

Biopesticides Registration Action Document Shake container well before use. REQUI EM must be diluted with water for spray applications. Partially fill the spray

tank with clean water, add the specified amo unt of REQUI EM to the tank, and finish filling the tank to the proper volume to obtain the desired application rate per acre as specified in the crop and pest tables listed below . Use at dilutions no more concentrated than 2% v/v. Compatibility : Do not combine REQUI EM in the spray tank with other pesticides, surfactants, adjuvants, or fertilizers if there has been no previous experience or use of the combination to show it is phy sically

compatible, and non

- injurious under your use conditions. Do not us e REQUI EM in tank mixes or in a program or in rotation with products containing captan (with REQUI EM either preceding or following captan applications) in any crop. Use of REQUI EM with captan

- containing products may result in phy

totoxicity

. Do not use RE QUI EM in tank mixture combinations or in rotation with any product containing a label warning against using surfactants, methylated seed oils, oils or other adjuvants. As with many

Emulsifiable Concentrate (EC) formulations, certain combinations can exac erbate phy totoxicity problems. Products which are phy totoxic when used alone may be more phy

totoxic when used with an EC formulation such as REQUIEM. AgraQuest has not tested all varieties and cultivars of all crops and potential tank

- mix or rotational combinations. To ensure crop safety , test REQUI EM in combination and in rotation with other products on a small portion of the crop. Wait at least 24

- 72 hours to evaluate results before applying to the entire field. If phy

totoxicity is noted, and if it is determined that the level of phy totoxicity will result in economic losses to the crop, do not make the application to the crop. To ensure phy sical compatibility of tank

- mix combinations they must be evaluated prior to use. When products are phy sically compatible, a homogeneous solution is formed. To determine the phy sical compatibility

of this product with other products, use a jar test. Using a quart jar, add the proportionate amounts of the products to approximately one quart of water with agitation. Ad d dry formulations first, then flowables, then emulsifiable concentrates last. After thorough mixing, allow this mixture to stand for 15 minutes. I f the mixture in the test jar remains uniform for 15 minutes, the combination is compatible and can be used. If separation occurs (e.g. oils float to top, clumps of solids form, etc.), the combination is incompatible and do not use the mixture. Once compatibility has been proven, use the same procedure for adding required ingredients to the spray

tank. Use of A djuvants: The use of adjuvants with REQUIEM is not required. Biological Control Agents: This product is compatible with the following biological control agents: Encarsia formosa , Amblyseius fallacis , Phytoseiulus persimilis , Orius insidiosus, Aphidius co lemani, Zetzellia mali, Neoseiulus fallacies, Typhlodromus pyri, Stethorus punctum, lacewings, sy rphid fly larvae, phy

toseiid mite predators, aphid midges, lady beetles, and other predacious mites. W ait at least 2 hours after application before introducin g new biological agents , or spray the evening before the day

of introduction of new biological control agents. AgraQuest is committed to the practice of sound resistance management programs that include rotation and tank mixing with other treatments havi ng a variety of modes of actions.ECANA and ECANA Mimic Page 41 of 60

Biopesticides Registration Action Document APPLICATION Use REQUI EM early

in the pest cycle when local thresholds are reached or before insects reach damaging levels

. REQUI EM is a contact insecticide and thorough coverage is necessary for optimum control. Use appr opriate nozzles and nozzle configurations, along with sufficient spray volume to achieve thorough coverage. Rates of REQUIEM may need to increase with increased insect populations and/or large plant canopies. It is not necessary to use a surfactant with REQUI EM. REQUI EM can be applied with commonly used ground equipment . Use of air

- blast spray equipment may

result in overhead exposure and requires the use of chemical

- resistant headgear. When using REQUI EM with a new crop, test on a small area before a pplying to the entire field. Do not apply REQUI EM more than 10 times per crop production cycle. PREHARVEST INTERVAL REQUI EM can be applied up to and including the day of harvest. However, note that the restricted entry interval (REI ) is 4 hours. SPRAY DRIFT PRECAUTIONS Avoiding spray

drift at the application site is the responsibility of the applicator. The interaction of many equipment

- and weather

– related factors determine the potential for spray drift. The applicator and the grower/treatment coordin ator are responsible for considering all of these factors when making decisions. Where states have more stringent regulations, they should be observed. Note: This section is advisory

in nature and does not supersede the mandatory label requirements. All ground application equipment must be properly maintained and calibrated using appropriate carriers. Make ground applications when the wind velocity favors on target product deposition (approximately

3 to 10 mph). Do not apply when wind velocity

exceeds 1 0 mph. Avoid applications when wind gusts approach 1 0 mph. Risk of exposure to sensitive areas can be reduced by avoiding applications when wind direction is toward the area. Lo w humidity

and high temperatures increase the evaporation rate of spray droplet s and therefore the likelihood of increased spray drift. Avoid spraying during conditions of low humidity and/or high temperature. Do not make ground applications during temperature inversions. Inversions are characterized by stable air and increasing temperatures with height above the ground. Mist or fog may indicate the presence of an inversion in humid areas. The applicator may detect the presence of an inversion by producing smoke and observing a smoke layer near the ground surface. FOR USE ON THE FOL LOWING CROPS (REQUIEM has a 0 - Day PreHarvest Interval (PHI) for all crops contained on this label. However, note that the restricted entry interval (REI) is 4 hours.)ECANA and ECANA Mimic Page 42 of 60

Biopesticides Registration Action Document Asparagus Pests and Application Rates: Pests REQUIEM (qts/acre) Remarks Aphids Thri ps 2
- 4 Begin applications when thresholds have been reached. The rate of REQUIEM will depend on plant size and pest pressure. Use a lower rate for light infestation and/or small plant canopy and a higher rate for heavy

infestations and/or large plants. Brassica (Cole) Leafy Vegetables Including Broccoli, Broccoli Raab, Brussels Sprouts, Cabbage, Chinese Cabbage (Bok Choy and Napa ), Cauliflower, Cavalo, Collards, Kale, Kohlrabi, Mustard Greens, Rape Greens, and other Brassica leafy vegetable crops. Pe sts and Application Rates: Pests REQUIEM (qts/acre) Remarks Aphids:  Cabbage aphid  Green peach aphid  Turnip aphid 2
- 4 Begin treatments when thresholds have been reached. Thrips Begin applications as soon as thrips are seen in the crop. Continue appl ications as needed. Thrips will seek shelter in hard

- to - reach parts of the plant. Use insecticide nozzles with sufficient water volume and spray

pressure for thorough coverage. Whiteflies:  Silverleaf whitefly Apply before pests reach damaging levels. R epeat applications as needed to maintain control. Do not wait until heavy populations have become established. Use the high rate when conditions are favorable for heavy pressure. Leafminers For Suppression: Begin treatments before thresholds have been reached. Bulb Vegetables Including Garlic, Leek, Onion (dry bulb, green, and Welch), and Shallot and other bulb vegetable crops. Pests and Application Rates: Pests REQUIEM (qts/acre) Remarks Leafminer Maggots 1.5
- 4 Apply before pests reach d amaging levels. Repeat applications as needed to maintain control. TheECANA and ECANA Mimic Page 43 of 60

Biopesticides Registration Action Document Mites amount of REQUI EM per acre will depend on plant size, leaf canopy

and pest pressure. Choose lower rates for light infestations and/or small plants and higher rates for heavy infestation s and/or larger plants. Thrips :  Onion thrips  Western flower thrips  Tobacco thrips Begin applications as soon as thrips are seen in the crop. Continue applications as needed. Thrips will seek shelter hard

- to - reach parts of the plant. Use insecticide no zzles with sufficient water volume and spray

pressure for thorough coverage. Bush Berries Including Blueberry, Currant, Gooseberry, Huckleberry, Elderberry, and other bush berry crops. Pests and Application Rates: Pests REQUIEM (qts/acre) Remarks Aphids Leafhoppers Leafrollers Lo opers Lygu s Maggots Mites Plum curculio Thrips  Western flower thrips 2
- 4 Apply before pests reach damaging levels. Repeat applications as needed to maintain control The amount of REQUI EM per acre will depend on plant si ze, leaf canopy and pest pressure. Choose lower rates for light infestations and/or small plants and higher rates for heavy infestations and/or larger plants. Adjust equipment, water volume, and spray pressure to ensure thorough coverage of infested part s of the crop. Cranberry Do not apply to flooded fields. Pests and Application Rates: Pests REQUIEM (qts/acre) Remarks Aphids Leafhoppers Leafrollers Lo opers Thrips Wireworms 2
- 4 Begin applications when thresholds have been reached. The rate of REQ UI EM will depend on plant size and pest pressure. Use a lower rate for light infestation and/or small plant canopy and a higher rate for heavy

infestations and/or large plants. Cane Berries Including Blackberry (including varieties, cultivars, and/or hybrids) , Loganberry, Raspberry, and other cane berry crops. Pests and Application Rates: Pests REQUIEM RemarksECANA and ECANA Mimic Page 44 of 60

Biopesticides Registration Action Document (qts/acre) Aphids Leafhoppers Leafrollers Lo opers Sawfly Whiteflies Thrips  Western flower thrips 2
- 4 Apply before pests reach damaging level s. Repeat applications as needed to maintain control. The amount of REQUI EM per acre will depend on plant size, leaf canopy

and pest pressure. Choose lower rates for light infestations and/or small plants and higher rates for heavy infestations and/or larg er plants. Adjust equipment, water volume, and spray

pressure to ensure thorough coverage of infested parts of the crop. Citrus Fruits Including Grapefruit, Lemon, Lime, Orange, Tangerine, Citrus hybrids, Pummelo, and other citrus fruit crops. Pests a nd Application Rates: Pests REQUIEM (qts/acre) Remarks Asian citrus psyllid Lepidoptera larvae:  Avocado leafroller  Citrus peelminer  Citrus L eafminer  Cutworms  Fruit tree leafroller  Orange tortrix Mites :  Broad mite  Citrus flat mite  Citrus bud mite  Citrus red mite  Citrus rust mite  Six

- spotted spider mite  Texas citrus mite  Yuma spider mite  Two
- spotted spider mite  Rust mite Thrips:  Citrus thrips  Frankliniella spp

.  Bean thrips 2
- 4 Treat when pests appear or in accordance with local economic thresholds. Repe at applications as needed to maintain control. The rate of REQUI EM will depend on tree size and pest pressure. Use a lower rate for light infestation and/or small trees and a higher rate for heavy infestations and/or large trees. When apply ing to large tr ees, use higher water volumes to ensure thorough coverage. Do not exceed 2% v/v solution.

Scale Begin applications when thresholds are reached. Treat for scale when crawlers are present in the spring and fall.ECANA and ECANA Mimic Page 45 of 60

Biopesticides Registration Action Document Cucurbit Vegetables Includi ng Cucumber, Citron melon, Edible G ourds, Gherkin, Muskmelons ( including hybrids and/or cultivars of Cucumis melo ), Pumpkin, Summer and Winter Squash, Watermelon, Cantaloupe, and other cucurbit vegetable crops. Use of REQUIEM in tank mixes with some prod ucts including, but not limited to, those containing strobilurins or chlorothalonil may result in phytotoxicity. Do not apply products containing chlorothalonil within 4 days after application of REQUIEM. Do not apply REQUIEM for 30 days following an appli cation of chlorothalonil. Pests and Application Rates: Pests REQUIEM (qts/acre) Remarks Aphids  Green peach aphid  Melon aphid Leafminers Mites 2
- 4 Begin treatments when thresholds have been reached.
Thrips  Melon thrips  Western flower thrips Begin ap plications as soon as thrips are seen in the crop. Continue applications as needed. Thrips will seek shelter in hard

- to - reach parts of the plant. Use appropriate nozzles with sufficient water volume and spray

pressure for thorough coverage. Whiteflies:  Greenhouse whitefly  Sweetpotato whitefly  Silverleaf whitefly Apply before pests reach damaging levels. Repeat applications as needed to maintain control. Do not wait until heavy populations have become established. Use the high rate when conditions are favorable for heavy pressure. Fig s Pests and Application Rates: Pests REQUIEM (qts/acre) Remarks Mites Navel orangeworm Scale Vinegar flies 2
- 4 Begin applications when thresholds have been reached. The rate of REQUIEM will depend on plant size and p est pressure. Use a lower rate for light infestation and/or small plant canopy and a higher rate for heavy

infestations and/or large plants. Globe Artichoke Pests and Application Rates: Pests REQUIEM (qts/acre) Remarks Aphids 2
- 4 Begin applications when thresholds have beenECANA and ECANA Mimic Page 46 of 60

Biopesticides Registration Action Document Leafhoppers Plume moth reached. The rate of REQUI EM will depend on plant size and pest pressure. Use a lower rate for light infestation and/or small plant canopy and a higher rate for heavy

infestations and/or large plants. Fruiting Vegetables Including Eggplant, Ground Cherry, Pepino, Pepper, Tomatillo, Tomato , and other fruiting vegetable crops. Pests and Application Rates: Pests REQUIEM (qts/acre) Remarks Aphids :  Green peach aphid  Potato aphid Leafhoppers Mites Tomato pinworm 2
- 4 Begin treatments when thresholds have been reached.

Thrips:  Western flower thrips  Onion thrips  Chili thrips  Melon thrips  Florida flower thrips  Eastern flower thrips Begin applications as soon as thrips are seen in the crop. Continue appli cations as needed. Thrips will seek shelter in hard

- to - reach parts of the plant. Use appropriate nozzles with sufficient water volume and spray

pressure for thorough coverage. Whiteflies:  Silverleaf whitefly  Greenhouse whitefly  Bandedwinged whitefly  Sweet potato whitefly Apply before pests reach damaging levels. Repeat applications as needed to maintain control. Do not wait until heavy populations have become established. Use the high rate when conditions are favorable for heavy pressure. Leafminers (

Liriomyza spp .) For Suppression: Begin treatments before thresholds have been reached. Grape Do not use REQUIEM on grapes east of the Rockies. Use of REQUIEM on grapes after fruit set can diminish waxy bloom. Pests and Application Rates: Pests RE QUIEM (qts/acre) Remarks Leafhoppers :  Grape leafhopper  V ariegated leafhopper 2
- 4 For Suppression: Begin treatments before thresholds have been reached. Grape berry

moth Western grape s keletonizer Begin applications when thresholds have been reached. The rate of REQUIEM will depend onECANA and ECANA Mimic Page 47 of 60

Biopesticides Registration Action Document Mealy bug Mites :  Pacific spider mites  Willamette spi der mite  Two
- spotted spider mite plant size and pest pressure. Use a lower rate for light infestation and/or small plant canopy and a higher rate for heavy

infestati ons and/or large plants. Adjust equipment , spray volume , and spray pressure to ensure thorough covera ge of infested parts of the crop. Herbs and Spices Including Allspice, Anise, Basil, Borage, Cardamom, Chive, Dill, Fennel (common), Juniper berry, Ma rjoram, Nutmeg, Pepper, Saffron, Sage, Tarragon, Vanilla, and other herb and spice crops. Pests and Application Rates: Pests REQUIEM (qts/acre) Remarks Aphids Fleahoppers Leafhoppers Grasshoppers 2
- 4 Begin applications when thresholds have been reache d. The rate of REQUI EM will depend on plant size and pest pressure. Use a lower rate for light infestation and/or small plant canopy and a higher rate for heavy

infestations and/or large plants. Leafminers (

Liriomyza spp .) For Suppression: Begin treatments before thresholds have been reached. Hops Pests and Application Rates: Pests REQUIEM (qts/acre) Remarks Mites Aphids 2
- 4 Begin applications when thresholds have been reached. The rate of REQUI EM will depend on plant size and pest pressure. U se a lower rate for light infestation and/or small plant canopy and a higher rate for heavy

infestations and/or large plants. Legume Vegetables (Succulent or Dried) Including Beans , Green beans , Snap beans , Shell beans , Garbanzo beans , Lima beans , Pea s , Chick peas , Split peas , Lentils and other legume vegetable crops . Pests and Application Rates: Pests REQUIEM (qts./acre) Remarks Aphids Leafhoppers Lygu s bugs Mites 2

– 4 Begin applications when thresholds have been reached. The rate of REQUIEM will depend on plant size and pest pressure. Use a lower rate for light infestation and/or small plant canopy and a higher rate for heavy

infestations and/or largeECANA and ECANA Mimic Page 48 of 60

Biopesticides Registration Action Document plant canopy

. Thrips:  Western Flower Thrips  Melon Thrips Begin applications as soon as thrips are seen in the crop. Continue applications as needed. Thrips will seek shelter in hard

- to - reach parts of the plant. Use insecticide nozzles with sufficient water volume and spray

pressure for thorough coverage. Whiteflies Apply before pests reach d amaging levels. Repeat applications as needed to maintain control. Do not wait until heavy populations have become established. Use the high rate when conditions are favorable for heavy pressure. Leafminers (

Liriomyza spp.) For suppression: Begin treatments when leafminers are seen in the crop. Continue applications as needed. Mint Pests and Application Rates: Pests REQUIEM (qts/acre) Remarks Mites Aphids Thrips 2
- 4 Begin applications when thresholds have been reached. The rate of REQUI EM wil l depend on plant size and pest pressure. Use a lower rate for light infestation and/or small plant canopy and a higher rate for heavy

infestations and/or large plants. Leafy Vegetables Including Lettuce , Arugula, Celery , Spinach , Parsley , Radicchio , F lorence Fennel, Romaine, Swiss Chard, and other leafy vegetable crops . Pests and Application Rates: Pests REQUIEM (qts/acre) Remarks Aphids :  F oxglove aphid  L ettuce aphid  L ettuce root aphid  Cabbage aphid  Turnip aphid  Potato aphid  Green peach aphid Leaf hoppers Lygu s bugs Mites (except bulb mite) Psyllid 2
- 4 Begin treatments when thresholds have been reached.

Thrips Begin applications as soon as thrips are seen inECANA and ECANA Mimic Page 49 of 60

Biopesticides Registration Action Document the crop. Continue applications as needed. Thrips will seek shelter in hard

- to - reach p arts of the plant. Use appropriate nozzles with sufficient water volume and spray

pressure for thorough coverage. Whiteflies:  Silverleaf whitefly Apply before pests reach damaging levels. Repeat applications as needed to maintain control. Do not wait unt il heavy populations have become established. Use the high rate when conditions are favorable for heavy pressure. Leafminers (

Liriomyza spp
. ) For Suppression: Begin treatments before thresholds have been reached. Olives Pests and Application R ates: Pests REQUIEM (qts/acre) Remarks Mites Scale Thrips 2
- 4 Begin applications when thresholds have been reached. The rate of REQUIEM will depend on plant size and pest pressure. Use a lower rate for light infestation and/or small plant canopy and a higher rate for heavy

infestations and/or large plants. Okra Pests and Application Rates: Pests REQUIEM (qts/acre) Remarks Aphids Leafhoppers Mites Tomato pinworm 2
- 4 Begin treatments when thresholds have been reached. Thrips:  Melon thrips  Western Flower thrips  Chili thrips  Florida Flower thrips Begin applications as soon as thrips are seen in the crop. Continue applications as needed. Thrips will seek shelter in hard

- to - reach parts of the plant. Use insecticide nozzles with sufficient water volume and spray

pressure for thorough coverage. Whiteflies Apply before pests reach damaging levels. Repeat applications as needed to maintain control. Do not wait until heavy

populations have become established. Use the high rate when conditions are fav orable for heavy

pressure. Leafminers (

Liriomyza spp
. ) For Suppression: Begin treatments before thresholds have been reached.ECANA and ECANA Mimic Page 50 of 60

Biopesticides Registration Action Document Leaves of Root and Tuber Vegetables Including Carrot, Sweet Potato, Cassava, Beets, Celeriac, Radish, Turnip, Parsnip, and other leaves of root and tuber crops. Pests and Application Rates: Pests REQUIEM (qts/acre) Remarks Aphids Leafhoppers Mites Psylla 2
- 4 Begin treatments when thresholds have been reached. Thrips Begin applications as soon as thrips are seen i n the crop. Continue applications as needed. Thrips will seek shelter in hard

- to - reach parts of the plant. Use appropriate nozzles with sufficient water volume and spray

pressure for thorough coverage. Whiteflies Apply before pests reach damaging levels. Repeat applications as needed to maintain control. Do not wait until heavy populations have become established. Use the high rate when conditions are favorable for heavy pressure. Leafminers (

Liriomyza spp .) For Suppression: Begin treatments before thresholds have been reached. Pome Fruits Including Apple, Crabapple, Loquat, Mayhaw, Pear, Qu i nce , and other pome fruit crops. Pests and Application Rates: Pests REQUIEM (qts/acre) Remarks Aphids :  Green apple aphid  Wooly apple aphid  Cotton aphid  Bean aphid  Rosy apple aphid  Spirea aphid  Green peach aphid Mites :  Brown mite  Pear rust mite  Pear leaf blister mite  European red mite  Two
- spotted spider mite  Pacific spider mite  McDaniel spider mite Leafhoppers 2
- 4 Begin applications when thresholds have been reached. The rate of REQUIEM will depend on plant size and pest pressure. Use a lower rate for light infestation and/or small plant canopy and a higher rate for heavy

infestations and/or large plant canopy .ECANA and ECANA Mimic Page 51 of 60

Biopesticides Registration Action Document Mealy bugs Pear psyllid Plum curculio Scale Thri ps Codling moth Oriental fruit moth Tufted apple moth Leafminers (lepidopteran) :  Spotted tentiform  Western tentiform Leafrollers :  Oblique

- banded  Pandernis Monitor the moth flights and the infestation densities of the larval stages. Repeat applicatio ns as necessary

to maintain control.

Root / Tuber and Corm Vegetables Including Carrot, Potato, Sweet Potato, Cassava, Beets, Ginger, Horseradish, Radish, Ginseng, Turnip, True Yam, and other root/tuber and corm crops. Pests and Application Rates: Pes ts REQUIEM (qts/acre) Remarks Aphids :  Potato aphid  Green peach aphid Leafhoppers Mites Psylla :  Potato psyllid 2
- 4 Begin treatments when thresholds have been reached.

Thrips Begin applications as soon as thrips are seen in the crop. Continue applications as needed. Thrips will seek shelter in hard

- to - reach parts of the plant. Use appropriate nozzles with sufficient water volume and spray

pressure for thorough coverage. Whiteflies:  S ilverleaf whitefly Apply before pests reach damaging levels. Repeat applications as needed to maintain control. Do not wait until heavy populations have become established. Use the high rate when conditions are favorable for heavy pressure. Leafminers (

Liriomyza spp.) For Suppression: Begin treatments before threshol ds have been reached. Stone Fruits Including Apricot , Cherry , Nectarine , Peach , Plum , Plumcot, Prune , and other stone fruit crops Pests and Application Rates: Pests REQUIEM RemarksECANA and ECANA Mimic Page 52 of 60

Biopesticides Registration Action Document (qts/acre) Aphids Cherry fruit fly Leafhoppers Leafminers Mites Plum curculio Scale Western cherry

fruit fly Thrips 2
- 4 Begin applications when thresholds have been reached. The rate of REQUI EM will depend on plant size and pest pressure. Use a lower rate for light infestation and/or small plant canopy and a higher rate for heavy

infestations and/or large plant canopy .

Leafrollers Leafminers Peach twig borer Monitor the moth flights and the infestation densities of the larval stages. Repeat applications as necessary

to maintain control. Strawberry Pests and Appli cation Rates: Pests REQUIEM (qts/acre) Remarks Aphids :  Green peach aphid  Melon aphid  Potato aphid  Strawberry

aphid Leafhoppers Lygu s bug Mites :  T wo - spotted spider mite  Carmine spider mite  Cyclamen mite  Pacific spider mite Thrips :  Western flower thrips 1
- 4 Begin applications when thresholds have been reached. The rate of REQUI EM will depend on plant size and pest pressure. Use a lower rate for light infestation and/or small plant canopy and a higher rate for heavy

infestations and/or large plants.

Wh iteflies :  Silverleaf whitefly  Greenhouse whitefly  Strawberry

whitefly Apply before pests reach damaging levels. Repeat applications as needed to maintain control. Do not wait until heavy populations have become established. Use the high rate when conditio ns are favorable for heavy pressure. Tropical Fruits Including Avocado, Banana, Kiwi, Mango, Papaya , Plantains, Pineapple, and other tropical fruits. Pests and Application Rates: Pests REQUIEM (qts/acre) Remarks Avocado leafroller Citrus peelminer 2
- 4 Begin applications when thresholds have been reached. The rate of REQUI EM will depend onECANA and ECANA Mimic Page 53 of 60

Biopesticides Registration Action Document Cutworms Fruit tree leafroller Naval orange worm Orange tortrix Western tussock moth Mites Thrips Scale plant size and pest pressure. Use a lower rate for light infestation and/or small plant canopy and a higher rate for heavy

infestations and/or large plants.

Tree Nuts Including Almond, Beech nut, Cashew, Chestnut, Filbert, Hickory nut, Pecan, Walnut, and other tree nut crops. Do not use of REQUIEM in tan k mixes with chlorothalonil. Do not apply products containing chlorothalonil within 30 days after application of REQUIEM. Do not apply REQUIEM for 30 days following an application of chlorothalonil. Pests and Application Rates: Pests REQUIEM (qts/acre) R emarks Aphids :  Walnut aphid  Dusky

- veined aphid  Rosy apple aphid  Green peach aphid  Spirea aphid  Yellow aphid  Black pecan aphid  Black

- margined aphid  Yellow pecan aphid Fall webworm Scale Walnut husk fly Mites:  Brown mite  Peach silver mite  Citrus flat mite  Pacific spider mite  European red mite  Two
- spotted spider mite  Strawberry

spider mite 2
- 4 Begin applications when thresholds have been reached. The rate of REQUIEM will depend on plant size and pest pressure. Use a lower rate for light infestation and/o r small plant canopy and a higher rate for heavy

infestations and/or large plant canopy .

Leafminers Leafrollers Peach twig borer Pecan nut case bearer Monitor the moth flights and the infestation densities of the larval stages. Repeat applications as ne cessary

to maintain control.ECANA and ECANA Mimic Page 54 of 60

Biopesticides Registration Action Document STORAGE AND DISPOSAL Do not contaminate water, food or feed by storage or disposal. Pesticide Storage: Store in a cool dry place. Avoid freezing. Pesticide Disposal: To avoid wastes, use all material in this cont ainer by application according to label directions. I f wastes cannot be avoided, offer remaining product to a waste disposal facility or pesticide disposal program (often such programs are run by state or local governments or by industry ). Do not contam inate water when disposing of equipment washwater or rinsate. Pesticide wastes may be toxic. Improper disposal of unused pesticide , washwater or rinse water is a violation of federal law. Container Disposal: Non
- refillable container. Do not reuse o r refill this container Triple rinse container (or equivalent) promptly after emptying. Triple rinse as follows: Empty the remaining contents into application equipment or a mix tank and drain for 10 seconds after the flow begins to drip. Fill the cont ainer 1⁄4 full with water and recap. Shake for 10 seconds. Pour rinsate into application equipment or a mix tank or store rinsate for later use or disposal. D rain for 10 seconds after the flow begins to drip. Repeat this procedure two more times. Then offe r for recycling if available, or puncture and dispose of in a sanitary landfill or by

incineration. Do not burn unless allowed by

state and local ordinances.

WARRANTY AND DISCLAIMER STATEMENT AgraQuest warrants to those persons lawfully purchasing this product that at the time of the first sale of this product by

Seller that this product conformed to its description and was reasonably fit for the purposes stated on the label when used in accordance with Seller’s directions. Buyers and users of this prod

uct assume the risk of any use contrary

to such directions. EXCEPT AS PROVIDED ELSEWHERE I N WRI TI NG CONTAI

NI NG AN EXPRESS REFERENCE TO THI S WARRANTY AND L IM IT ATI ON OF DAMAGES, SELLER MAKES NO OTHER EXPRESS OR IMPL IE D WARRANTY OR GUARANTY, I NCLUDI NG ANY OTH ER EXPRESS OR IMPL IE D WARRANTY OF FI TNESS OR OF MERCHANTABILIT Y AND NO A GENT OF SELLER IS AUTHORIZED TO DO SO. Except to the extent prohibited by applicable law, AgraQuest offers this product with the following conditions: 1) buyers and users of this prod

uct assume the risk of any storage, handling or use contrary to AgraQuest’s label and directions and 2) AgraQuest’s liability shall in no case exceed the purchase price of the applicable AgraQuest product.

REQUIEM is a registered trademark of AgraQuest.



# QRD 452ECANA and ECANA Mimic Page 55 of 60

Biopesticides Registration Action Document (Alternate Brand Name: METRONOME TM II ) Sub - Label B : For Greenhouse & Nursery / Commercial Use Only



# METRONOME TM 

# II I nsecticide and A caricide F OR U SE ON N ON - F OOD O RNAMENTALS ( T REES , S HRUBS , AND B EDDING PLANTS ) N OT F OR RESIDENTIAL U SE Active Ingredient: ECANA Mimic*

................................ ................................ ................................ ................................ .................. 16.75 % Other Ingredients

................................ ................................ ................................ ................................ ................. 83.25 % Total: 100.0% * ECANA mimic is a blend of nature

- identical components that substantially replicate the composition and activity of plant

- produced Extract of Chenopodium ambrosioides near ambrosioid es (ECANA). KEEP OUT OF REACH OF CHILDREN



## CAUTION
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 further treatment advice. In On Skin Or Clothing  Take off contaminated clothing.  Rinse skin immediately with plenty of water for 15

- 20 minutes.  Call a poison control center or doctor for further treatment advice.

HOT LINE NUMBER CHEMTREC (800) 424 - 9300 (24 hours) Have the product container or label with you when calling a poison control center or doctor or going for treatment. See side/back panels for additional precautionary statements EPA Reg No. 69592
- EL EPA Es tablishment No. 69592

- MEX
- 1 Net Contents: 1 gallon (128 fl. oz.) (3.8 L)

[2.5 gallon (320 fl. oz.) (9. 46 L)] Manufactured By : AgraQuest, Inc. 1540 Drew Avenue Davis, California 95618 (530) 750

- 0150ECANA and ECANA Mimic Page 56 of 60

Biopesticides Registration Action Document



### PRECAUTIONARY STATEMENTS HAZARD TO HUMANS AN D DOMESTIC ANIMALS CAUTI ON : Causes moderate eye irritation. Avoid contact with skin, eyes or clothing. Wash thoroughly

with soap and water after handling and before eating, drinking, chewing gum or using tobacco. Remove and wash contaminated clothing be fore reuse. Prolonged or frequently repeated skin contact may

cause allergic reactions in some individuals. Wear the appropriate Personal Protective Equipment (PPE). PERSONAL PROTECTIVE EQUIPMENT Applicators mixers, loaders and other handlers must wear:  Lo ng - sleeved shirt and long pants  Chemical

- resistant gloves made of any waterproof material  Shoes plus socks  Protective eyewear  Coveralls for high

- pressure handwand and groundboom applicators.  For greenhouse uses, applicators and other handlers must wear a NI OSH
- approved respirator with an organic vapor (OV) cartridge or canister with any R, P or HE filter. Follow the manufacturer’s instructions for cleaning/maintaining PPE. I f no such instructions for washables, use detergent and hot water. Keep and was h PPE separately from other laundry

. USER SAFETY RECOMMENDATIONS Users should: ● Remove clothing immediately if pesticide gets inside. Then wash thoroughly and put on clean clothing. ● Remove PPE immediately after handling this product. Wash the outside of gloves before removing. As soon as possible, wash thoroughly and change into clean clothing. ENVIRONMENTAL HAZARDS This product is toxic to aquatic invertebrates. For terrestrial uses: Do not apply directly to water or to areas where surface water is present, or to intertidal areas below the mean high water mark. Do not contaminate water when disposing of equipment washwater or rinsate. Drift and runoff may

be hazardous to aquatic organisms in water adjacent to treated areas. Do not apply when w eather conditions favor drift or runoff from treated areas. Do not apply when a rain event is expected within 2 hours. Air blast applications must maintain a spray buffer of 15 feet from any waterbody

. See the Directions for Use for details. 

### DIRECTIONS F OR USE It is a violation of Federal law to use this product in a manner inconsistent with its labeling
. READ THE ENTIRE LABEL. USE STRI CTLY I N ACCORDANCE WI TH THE LABEL
. FAILURE TO FOLLOW DIRECTI ONS AND PRECAUT IO NS ON THI S LABEL M AY RESUL T INCROP I

NJU RY, POOR I

NSECT CONT ROL , AND/OR I LLEGAL RESIDUES. Do not apply

this product in a way

that will contact workers or other persons, either directly or through drift. Only

protected handlers may

be in the area during application. For any requirements spec ific toECANA and ECANA Mimic Page 57 of 60

Biopesticides Registration Action Document yo ur state or tribe, consult the State or Tribal agency responsible for pesticide regulation. AGRICULTURAL USE REQUIREMENTS Use this product only

i n accordance with its labeling and with the Worker Protection Standard, 40 CFR Part 170. This Stand ard contains requirements for the protection of agricultural workers on farms, forests, nurseries, greenhouses and handlers of agricultural insecticides. It contains requirements for training, decontamination, notification and emergency a ssistance. It al so contains specific instructions and exceptions pertaining to the statements on this label about personal protective equipment (PPE) and restricted

- entry interval. T he requirements in this box only

apply to uses of this product that are covered by the Wo rker Protection Standard. Do not enter or allow worker entry into treated areas during the restricted entry interval (REI) of 4 hours. PPE required for early

e ntry t o treated areas that is permitted under the Worker Protection Standard and that involves contact with any thing that has been treated, such as plants, soil or water is:  Long
- sleeved shirt and long pants  Chemical

- resistant gloves made of any waterproof material  Shoes plus socks NON - AGRICULTURAL USE REQUIREMENTS The requirements in this box app ly to uses that are NOT within the scope of the Worker Protection Standard for agricultural pesticides (40 CFR Part 170). The WPS applies when this product is used to produce agricultural plants on farms, nurseries or green houses. Do not enter treated areas without protective clothing until spray has dried. Refer to Personal Protective Equipment section under the Precautionary Statements section. GENERAL INFORMATION METRONOME TM is an Emulsifiable Concentrate (EC) In secticide and Acaricide for Use on F ield and Container

- grown Non
- Food Ornamental Plants in Commercial Nurseries, Greenhouses, and L ath

and Shade

- houses. Not For Residential Use. METRONOME is a c ontact insecticide/acaricide for use in the control of aphids, plant

- feeding mites, whiteflies, mealy

bugs, leafminers, thrips, fungus gnats, and tarnished plant bugs. METRONOME can be applied to field and container

- grown non - food ornamentals

– trees, Christmas trees, shrubs, flowers, annual and perennial bedding plants, potted flowers, and tropical plants. MIXING AND APPLICATION INSTRUCTIONS Do not apply

this product by

aerial application or through any ty pe of irrigation sy stem. METRONOME is toxic to aquatic invertebrates. Users must maintain the following buffer zones: Airblast spray

applicat ors must not apply within 15 feet of aquatic habitats (such as, but not limited to, lakes, reservoirs, rivers, streams, marshes, ponds, estuaries, and commercial fish ponds). Groundboom and airblast applicators must also account for wind direction and spe ed. Only apply this product if the wind direction favors on

- target deposition. Do not apply when th e wind velocity exceeds 10 mph. Do not apply when a rain event is expected within 2 hours. Shake container well before use. METRONOME must be diluted with water for spray applications. Partially fill the spray

tank with clean water, add the specified amount of METRONOME to the tankECANA and ECANA Mimic Page 58 of 60

Biopesticides Registration Action Document (see table below), and finish filling the tank to the desired volume to obtain the proper spray concentration for the desired application rate per acre.

Gallons Water per Acre METRONOME gallons

0.5% solution METRONOME gallons 1 % solution 25 0.12 (16 fl oz) 0. 2 5 ( 32 fl oz) 50 0.25 (32 fl oz) 0.5 (64 fl oz) 75 0.37 (48 fl oz) 0.75 (96 fl oz) 100 0.5 1 For smaller quantities, mix at a rate of 0.65

– 1.3 fl. oz. METRONOME per 1 gallon of water. Apply on a 7
- to 14
- day

schedule as necessary . Apply METRONOME at first sign of insect pressure or plant

- feeding mite infestation. Use higher application rate under cond itions of heavy pest pressure. Uniform coverage of both upper and lower leaves is critical for effective pest control. Avoid overspraying to the point of excessive runoff. Do not apply METRONOME more than 10 t imes per ye ar. METRONOME can be applied with commonly used ground equipment, hose

- end, pressurized, greenhouse, and hand

- held sprayers. Biological Control Agents: This product is compatible with the following biological control agents: Encarsia formosa , Amblyseius fallacis , Phytoseiulus persimilis , Orius insidiosus, Aphidius colemani, Zetzellia mali, Neoseiulus fallacies, Typhlodromus pyri, Stethorus punctum, lacewings, sy rphid fly larvae, phy

toseiid mite predators, aphid midges, lady beetles, and other predacious mites. W ait at least 2 hours after application before introducing new biological agents , or spray the evening before the day of introduction of new biological control agents. AgraQuest is committed to the practice of sound resistance management programs that include rotation and tank mixing with other treatments having a variety of modes of actions. Compatibility : Do not combine METRONOME in the spray tank with other pesticides, surfactants , adjuvants, or fertilizers if there has been no previous experience or use of the combinatio n to show it is phy sically

compatible, and non

- injurious under your use conditions. Do not use METRONOME in tank mixes or in a program or in rotation with products containing captan (with METRONOME either preceding or following captan applications) in any crop. Use of METRONOME with captan

- containing products may result in phy

totoxicity

. Do not use METRONOME in tank mixture combinations or in rotation with any product containing a label warning against using surfactants, methylated seed oils, oils or other adjuvants. As with many

Emulsifiable Concentrate (EC) formulations, certain combinations can exacerbate phy totoxicity problems. Products which are phy totoxic when used alone may be more phy

totoxic when used with an EC formulation such as METRONOME. A graQuest has not tested all varieties and cultivars of all crops and potential tank

- mix or rotational combinations. To ensure phy sical compatibility of tank

- mix combinations they must be evaluated prior to use. When products are phy sically

compatible, a h omogeneous solution is formed. To determine the phy sicalECANA and ECANA Mimic Page 59 of 60

Biopesticides Registration Action Document compatibility

of this product with other products, use a jar test. Using a quart jar, add the proportionate amounts of the products to approximately one quart of water with agitation. Add dry formul ations first, then flowables, then emulsifiable concentrates last. After thorough mixing, allow this mixture to stand for 15 minutes. I f the mixture in the test jar remains uniform for 15 minutes, the combination is compatible and can be used. If separati on occurs (e.g. oils float to top, clumps of solids form, etc.), the combination is incompatible and do not use the mixture. Once compatibility has been proven, use the same procedure for adding required ingredients to the spray tank. Test the combination on a small number of plants to check for phy totoxicity before treating large areas. Do not use the combination if adverse effects are observed. PLANTS EVALUATED FOR PHYTOTOXICITY METRONOME has been evaluated alone in a wide range of crops and ornamentals . However, since testing on all varieties of all ornamentals is not feasible, testing a small portion of the area to be treated for phy

totoxicity is required before treating the entire area. Further, all possible combinations or sequences of pesticide sprays , including other fertilizers, surfactants, adjuvants and other pesticides, have not been tested, thus testing for compatibility and phy totoxicity of spray mixtures is require d. Use the product in accordance with all label use directions. Itis further r equired that spray equipment used to apply METRONOME be thoroughly cleaned before use. Phy totoxicity has occasionally

been observed following the use of this product on flowers of Cyclamen, Gerbera, Begonia, and Impatiens. Do not use METRONOME on floweri ng Cyclamen, Gerbera, Begonia, and Impatiens. STORAGE AND DISPOSAL Do not contaminate water, food or feed by storage or disposal. Pesticide Storage: Store in a cool dry place. Avoid freezing. Pesticide Disposal: To avoid wastes, use all material in this container by a pplication according to label directions. If wastes cannot be avoided, offer remaining product to a waste disposal facility o r pesticide disposal program (often such programs are run by state or local governments or by industry). Do not contaminate water when disposing of equipment washwater or rinsate. P esticide wastes may be toxic. Improper disposal of unused pesticide, washwater or rinse water is a violation of federal law. Container Disposal: Non
- refillable container. Do not reuse or refill this container Triple rinse container (or equivalent) promptly a fter emptying. Triple rinse as follows: E mpty the remaining contents into application equipment or a mix tank and drain for 10 seconds after the flow begins to drip. Fil l the container 1⁄4 full with water and recap. S hake for 10 seconds. P our rinsate into application equipment or a mix tank or store rinsate for later use or disposal. Drain for 10 seconds after the flow begins to drip. Repeat this procedure two more time s. Then offer for recycling if available, or puncture and dispose of in a sanitary l andfill or by incineration. Do not burn unless allowed by state and local ordinances. WARRANTY AND DISCLAIMER STATEMENT AgraQuest warrants to those persons lawfully purch asing this product that at the time of the first sale of this product by

Seller that this product conformed to its description and was reasonably fit for the purposes stated on the label when used in accordance with Seller’s directions. Buyers and users o f this product assume the risk of any use contrary

to such directions. EXCEPT AS PROVIDED ELSEWHERE IN WRITING CONTAINING AN EXPRESS REFERENCE TO THIS WARRANTY AND LIMITATION OF DAMAGES, SELLER MAKES NO OTHER EXPRESS OR IMPLIED WARRANTY OR GUARANTY, INCLUD ING ANY OTHER EXPRESS OR IMPLIED WARRANTY OF FITNESS OR OF MERCHANTABILITY AND NO AGENT OF SELLER IS AUTHORIZED TO DO SO. Except to the extent prohibited by applicable law, AgraQuest offers this product with the following conditions: 1) buyers and users o f this product assume the risk of any storage, handling or use contrary to AgraQuest’s label and directions and 2) AgraQuest’s liability shall inECANA and ECANA Mimic Page 60 of 60

Biopesticides Registration Action Document no case exceed the purchase price of the applicable AgraQuest product. METRONOME is a registered trademark of AgraQuest.