r
        I

        0 r
                                    GUIDANCE FOR THE
                          REREGISTRATION OP PESTICIDE PRODUCTS
                                       CONTAINING
                           FORMETANATE HYDROCHLORIDE (097301)
                                AS THE ACTIVE INGREDIENT
                            ENVIRONMENTAL PROTECTION AGENCY
                              OFFICE OF PESTICIDE PROGRAMS
                                WASHINGTON, B.C.  20460

                                     SEPTEMBER 1983
                                         30460

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                        TABLE OF CONTENTS
»

r
      Introduction  .  	  1

I.    Regulatory  Position	4

II.   Requirement for Submission of Generic Data	23

III.  Requirement for Submission of Product-Specific
      Data	;	48

IV.   Submission  of Revised Labeling and Packaging
      Information	49

      A.  Label Contents	49

          1.  Product Name	49
          2.  Company Name and Address  ............49
          3.  Net Contents	49
          4.  Product Registration Number	50
          5.  Producing Establishment
              Registration Number	50
          6A  Ingredient Statement 	 50
          6B  Pounds  Per Gallon Statement	50
          7.  Front Panel Precautionary Statements 	 50
          7A  Child Hazard Warning Statements	51
          7B  Signal  Word	51
          7C  Skull and Crossbones and Word Poison	51
          7D  Statement of Practical Treatment 	 51
          7E  Referral Statement 	 51
          8.  Side/Back Panel Precautionary Labeling 	 51
          8A  Hazard  to Humans and Domestic Animals	51
          8B  Environmental Hazard 	 52
          8C  Physical or Chemical Hazard	52
          9   Misuse  Statement 	 53
          10A Storage and Disposal Block 	 53
          10B Directions for Use	53

      B.  Collateral  Information 	 53

V.    Instructions  for Submission	54
NOTE:  Attached to this document are copies of the letters used
       to transmit the document to registrants and notify them
       of required studies.

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                            APPENDICES


II-l      Bibliography

II-2      FIFRA $3(c)(2)(B) Summary Sheet - EPA Form 8580-1

II-3      Certification of Attempt to Enter Into an Agreement
          With Other Registrants for Development of Data
          EPA Form 8580-6

III-l     Product Specific Data Report (End-Use Products)
          EPA Form 8580-4

IV-2      Table of Labeling Requirements and Sample Labels

IV-3      Physical/Chemical Hazards Labeling Statement

IV-5      Storage and Disposal Statements

Note:     Appendices IV-1, IV-4 and IV-6 are not germane to this
          document and are not included.
                                ii

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                                   INTRODUCTION
!
     The Federal Insecticide, Fungicide, and Rodenticide Act
(FIFRA Section 3(g), as amended in 1978, directs EPA to
reregister all pesticides as expeditiously as possible.  Each
registrant of a manufacturing use product of the active
ingredient who wishes to continue to sell or distribute that
product must apply for reregistration.

     To fulfill this Congressional mandate, we have established
the Registration Standards program which will review all pesti-
cide active ingredients first registered before January 1,
1977. These pesticides will be reviewed in use clusters
which are prioritized on the basis of a ranking scheme giving
preference to pesticides used on food and feed crops.

     The Registration Standards program involves a thorough
review of the scientific data base underlying pesticide
registrations and an identification of essential but missing
studies which, may not have been required when the product
was initially registered or studies that are now considered
insufficient.  Our reassessment results in the development
of a regulatory position, contained in this document, on
each pesticide and its uses. The regulatory position may
require the registrant to modify product labels to provide
additional precautionary statements, restrict the use of the
pesticide to certified applicators, provide reentry intervals,
modify uses or formulation types, specify certain packaging
limitations, or other requirements to assure that proper use
of the pesticide poses no potential adverse effects to human
health or the environment.

     The scientific review, which is not contained herein
but is available upon request, concentrates on the technical
grade of the active ingredient and identifies missing generic
data.  However, during the review of these data we are also
looking for potential hazards that may be associated with
the formulated (end-use) products that contain the active
ingredient. If we find serious concerns, we will bring
formulated products under the provisions of the Registration
Standards program to the extent necessary to protect the
public.

     EPA has the authority under FIFRA §3(c)(2)(B) to require
that certain registrants submit generic data that will answer
our questions regarding the hazard that may result from the
intended use of the pesticide under review.  Further, §3(c)
(2){B) provides that these data are to be submitted by
those registrants who do not qualify for the formulator's
exemption  [FIFRA §3(c)(2)(D)].  Normally, this means that
the registrants who are responsible for filling the data
gaps are the manufacturing-use product producers (basic

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suppliers of the active ingredient).  However, end-use producers
will not qualify for the formulator's exemption if the source
of their active ingredient: (1) is not registered with EPA,
and/or (2) is produced by the registrant's firm, or a firm
which has ownership in common with the registrant's firm.
These end-use producers can qualify for the formulator's
exemption if they change their source of supply to a registered
source, provided the source does not share ownership in
common with the registrant's firm.  If the end-use product
registrant decides to switch sources* a new Confidential
Statement of Formula, EPA Form 8570-4, must_be submitted to
the appropriate Product Manager within 90 da'ys of receipt of
this Guidance Document.  The chart on the following page
shows what is generally required of those who do and do not
qualify for the formulator's exemption in the Registration
Standards program.

     If you decide to request the Agency to discontinue the
registration of any of your products subject to the reregistra-
tion requirements of this Guidance Document, please notify
the Product Manager named in the cover letter, within 90
days from the receipt of this document, that you wish to
voluntarily cancel the registration(s).  If you decide to
maintain your product registration(s), you must provide the
information described in the following pages within the time-
frames outlined. EPA will issue a notice of intent to cancel
or suspend the registration of any currently registered
product if you fail to comply with the requirements set
forth in this Guidance Document.

    This Guidance Document will be supplemented by EPA with
additional information about compliance with data support
requirements.  In Monsanto v. Administrator, EPA was recently
enjoined from implementing in any way the "mandatory'data
licensing" aspects of §3(c)(l)(D) of FIFRA. EPA is assessing
the implications of the injunction for the reregistration
process. Because this situation is currently unresolved, EPA
has decided to proceed with the requirements in this Guidance
Document which do not relate to compliance with the §3(c)(l)(D)
provisions and to supplement the Document with additional
guidance when circumstances permit.  Failure to comply with
the provisions of the subsequent guidance will also result
in issuance by EPA of an intent to cancel the affected product
reg istration(s).

    Registrants are reminded that $6(a)(2) of FIFRA requires
you at any time to submit factual information raising concerns
of possible unreasonable adverse effects of a pesticide. You
should notify the Agency of interim results of studies in •
progress if those results show possible adverse effects.

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I
5 I
            PRODUCTS SUBJECT TO THE
            REGISTRATION STANDARDS PROGRAM
          I. Products That  Do Not Qualify
             For The Formulator's Exemption

             A. Single Active Ingredient
                Products*
             B. Multiple Active  Ingredient
                Products
          II.  Products That Do Qualify  For
               The Formulator's Exemption
  ACTION(S) REQUIRED TO
  MAINTAIN REGISTRATION
These products must be reregis-
tered. To obtain reregistration,
labeling, packaging and data
requirements must be satisfied
in accordance with the Regis*
tration Standards Guidance
Document.
These products will not be
reregistered at this time.
However, generic data required
to continue the registration of
the active ingredient under
review, as described in the
Registration Standards Guidance
Document, will be required and
some labeling precautions may
also be required.
Only when additional restric-
tions or labeling are needed to
protect man or the environment
will these products be subject
to the Registration Standard
requirements. Affected products
will be dealt "with in a variety
of ways, including but not
limited to the Label Improvement
Program and special intent
to cancel notices.
          * End-use products of  registrants who  also  produce  a  manufacturing-
          use product will  not be  required to  be reregistered provided  that
          registrant fulfills the  requirements specified  in the Guidance
          Document for manufacturing-use  product(s).  Such end-use  products
          will be subject to the labeling changes required for  products in "II"
          above. If there are no manufacturing-use products registered  by any
          company end-use products will be required to be reregistered.

          NOTE: If all registrants in  "I" above  fail  to meet  the requirements  in
          I-A and B above,  then  the  registrants  in "II* lose  their right  to
          qualify for the formulator's exemption and  become subject to  the
          requirements in I-A and  B.                            	

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A.  Introduction

This guidance document describes the Agency's regulatory posi-
tion on registered manufacturing-use products (MPs} containing
the miticide/insecticide formetanate hydrochloride (formetanate
RC1).  The position is based on an evaluation of all accepted
uses of pesticide products., under section 3 and 24{c) of the
FIFRA, with formetanate HC1 as the pesticide active ingredient.
Other considerations include the known chemical and toxicologi-
cal characteristics of this pesticide chemical and the
established tolerances for residues in or on food and feed
commodities.  From these considerations the Agency sets
forth the data and labeling requirements that must be met
by registrants and applicants of formetanate HC1 products in
order for the products to be reregistered or registered
under this document.  Only those registration requirements
for current and future substantially similar MPs are addressed
here.  Future MPs that differ appreciably from those described
in this document may require that amendments be made to this
document to reflect the differences.

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B'   Description ofChemicalAnd Use Profile

Formetanate HC1 is the American National Standards Institute
(ANSI) acceptable common name for m-t[(Dimethylamino)methylene]
aminojphenyl methylcarbamate hydrochloride.  The compound is
listed in the 8th Collective Index of the Chemical Abstracts
Service of the American Chemical Society as methylcarbamic
acid ester with N'-(m-hydroxy» phenyl)-N,N-dimethylformamidine
monohydrochloride.  The 9th Collective Index chemical name
is:  N,N-dimethyl-N'-I3-Il(methylamino) carbonyljoxyjphenyl}
methanimidamide monohydrochloride.  Other names and code
designations are:  Schering A.G. 36056, ENT-27566, SN-36056
and Dicarzol (the West German name for Carzol SP).  The
current Chemical Abstract Service (CAS) registry number for
formetanate HC1 is 23422-53-9 and the EPA Shaughnessy number
is 097301.

Formetanate HC1 is a white crystalline solid with a faint
odor.  The empirical formula is CilHi5N3O2.HCl.  The
molecular weight is 257.8.  Formetanate HC1 is more than 50%
soluble in water but only slightly soluble in most organic
solvents.

In addition to the federal registration, Carzol* SP is
registered for intra-state use in Arizona, California, Oregon,
Texas, Washington and Florida.

This pesticide is not produced domestically and is imported
into the U.S. only from West Germany, where it is manufactured
by the Schering A.G. Chemical Company.   In the United States,
the sole importer and distributor of the chemical is NOR-AM
Agricultural Products, Inc. of Naperville, IL, a subsidiary of
Schering A.G.  Chemical Company.  Formetanate HC1 is formulated
and registered as a 92% watersoluble powder for both-the HP and
EP registrations.  The MP is registered for the use of reformulat-
ing into an EP, and this is registered for use to control mites,
thrips and other insect pests on citrus, pome and stone fruit
crops, and alfalfa grown-for-seed.

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         D.   Regulatory  Rationale

         The Agency has determined  that  it  should  continue  to allow  the
         registration of  formetanate HC1  after considering  the following:

              1.   Adequate  studies  are available to  assess  the acute toxi-
                   cological effects of formetanate HC1  to humans.  Formet-
                   anate HC1 is  assigned Toxicity Category I on the basis of
                   acute oral and  eye effects.  The eye  irritation study
                   triggers  one  of the criteria  [40 CFR  162.11(c)(1)(ii)]
                   used to classify  pesticides.  However, the classification
                   regulations also  state  [40 CFR 162:il(c)(3)] that  if the
                   criteria  are  met, labeling precautions and directions must
                   be evaluated  to determine if the potential hazard  will
                   be mitigated.   The use  requirement to wear goggles, face
I                   shield  or safety  glasses  as required  by this guidance
1                   document  is adequate to protect  a  person  from eye  injury
f                  if exposed to this chemical.  Therefore,  formetanate HC1
.                   is not  being  classified as a Restricted Use Pesticide.
|                  The above precautionary statement  along with other
                   human hazard  precaution statements associated with
                   Toxicity  Category I labeling  [40 CFR  162.10(h)(2)(i)]
                   should  minimize the acute hazards  associated with  these
                   routes  of exposure.

              2.   Formetanate HC1 may potentially  yield both aromatic and
                   alkyl amines.   These amines may  be converted to reactive
                   electrophilic species  (such as nitroso species) with
                   possible  oncogenic effects.  The Agency will assess the
                   need for  further  characterization  of  the  postulated
                   electrophilic species when the results of the required
                   chronic feeding and oncogenic studies are submitted and
                   reviewed.   No other human toxicological hazards of
                   concern to the  Agency have been  identified.- It is
                   noted however,  that a number of  multiple  dose toxicology
                   studies submitted in support of  this  pesticide were
                   conducted by  Industrial Bio-Test Laboratories  (IBT) and
                   have been determined to be invalid.

              3.   The tolerance reassessment and TMRC/ADI ratio must be
**                   completed. However, based on residue chemistry and
                   toxicological considerations, there is no evidence to
                   suggest that  the  current  tolerances are likely to  expose
                   the public to unreasonable adverse effects.

              4.   There is  no record of any incident involving formetanate
                   HC1 having been reported  to the  Pesticide Incident
                   Monitoring System (PINS).

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Available data are insufficient to fully assess the
environmental fate of formetanate HC1.  Formetanate HC1
appears to leach in soil and, therefore, has a potential
for contamination of groundwater.  The additional studies
requested in this Guidance Document should allow us to im-
prove our assessment of the environmental fate of formetanate
HC1.  Upon receipt and analysis of these data the Agency may
require additional studies such as groundwater monitoring.

Based on acceptable ecological effects studies, formeta-
nate HC1 is characterized as highly toxic to birds.  It
is slightly toxic to warmwater fish and moderately
toxic to estuarine and marine organisms.  It is moderately
toxic to honey bees with direct contact spray, but it has
very low toxicity to bees when they are exposed to residues
on plants.  Label precautions required by this Guidance
Document should reduce the hazard to wildlife.  Once data
gaps are filled, additional labeling precautions may be
required.

Under FIFRA, the Agency cannot cancel or withhold regis-
tration simply because data are missing or are inadequate
(see Sections 3(c)(2)(B) and 3(c){7) of the FIFRA).
Rather, issuance of this Guidance Document provides a
mechanism for identifying data needs.  These data will be
reviewed and evaluated when they are received and the
Agency will determine at that time whether they will
affect the registration(s) of formetanate HC1.
                       8

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£.  Criteria for Products Subject to the Guidance Document

This Guidance Document covers products that contain formetanate
RC1 as a pesticide active ingredient, and the chart in the Intro-
duction describes the extent to which such products are subject
to this Document.  Applicants for registration or reregistration
of such products must comply with all terms and conditions
described herein.  This includes making a commitment to fill
data gaps on a schedule specified by the Agency.  Also, applicants
for reregistration must follow the instructions contained in
the Guidance Document and complete and submit the appropriate
forms within the specified times.  End-use products must be in
compliance with the label changes specified in this Document.

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iff
               Acceptable Ranges and  Limits

               !•    Product Composition Standards

               To  be fully covered under this Guidance  Document,  manufac-
               turing-use products must contain formetanate HC1 as  the
               sole active ingredient.   Each MP formulation proposed  for
               registration must be fully described  with  an appropriate
               certification of limits.

               2.    AcuteToxicity Limits

               The Agency will consider for  registration  any MP whose acute
               toxicity category (I,  II, III or IV)  is  supported  by adequate
               acute toxicity data and  labeling,  including  appropriate
               precautionary statements.
               3.
     Use Patterns
To be registered under this Guidance Document, HP's may be
labeled for formulation only into end-use products for: 1)
terrestrial, nondomestic food crop uses on citrus (oranges,
lemons, tangerines, tangelos, limes and grapefruit), pome
fruits (apples and pears), stone fruits (peaches, nectarines,
plums, and prunes) and alfalfa grown-for-seed.
                                          10

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G.  Required Labeling

All manufacturing-use products and end-use products containing
formetanate HC1 roust bear appropriate labeling as specified in
40 CFR 162.10.

     1.  Label Requirements for Manufacturing-Use Products
          a.
Ingredient Statements
          The ingredient statement for HP's must list the active
          ingredient as formetanate hydrochtoride (N,N-dimethyl-
          N'-[3-1l(methylamino)carbonyl]oxy]phenyl]methanimida-
          mide monohydrochloride)		 % or formetanate
          hydrochloride (m-[[(Dimethylamino)methylene]amino]phenyl
          methylcarbamate hydrochloride)....     %.

         b.  Use Pattern Statement

             1.  All MPs must state that they are intended only
                 for formulation into end-use products for any
                 of the use patterns listed above (F-3).  A
                 limiting factor will be the data that supports
                 these use patterns.  No use may be included in
                 the labeling where the registrant fails to
                 agree to comply with the data requirements in
                 either Table A or Table B for that use pattern.

         c.  Precautionary Statements

         Labels for all MP products containing formetanate HC1
         must bear statements reflecting the acute human toxicity
         of the compound.  The following hazard statements must
         appear on HP labels.

             1.  Statement for human hazards.

             •HAZARDS TO HUMANS AND DOMESTIC ANIMALS"

           "DANGER.  Fatal if swallowed.  Do not breathe spray
           mist.  Can cause irreversible eye damage.  May cause
           skin sensitization.  Do not get in eyes, on skin or
           on clothing.  Wear goggles, face shield or safety
           glasses.  Wear a pesticide respirator approved jointly
           by the Mining Enforcement and Safety Administration
           (formerly U.S. Bureau of Mines) and by the National
           Institute for Occupational Safety and Health under
           the provisions of 30 CFR Part II.  Wash thoroughly
           with soap and water after handling and before eating
           or smoking.  Remove contaminated clothing and wash
           before reuse."
                                11

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fe
                         Safety Administration (formerly U.S. Bureau of
                         Mines) and by the National Institute for Occupational
                         Safety and Health under the provisions of 30 CFR
                         Part II.  Wash thoroughly with soap and water
                         after handling and before eating or smoking.
                         Remove contaminated clothing and wash before reuse.*

                         2.  Statement for environmental hazard.

                               "ENVIRONMENTAL HAZARDS'

                         "This pesticide is toxic to wildlife.  Do not apply
                         directly to water or wetlands.  Do not contaminate
                         water by cleaning of equipment or disposal of
                         wastes.  Cover or incorporate spills.  This product
                         is toxic to bees exposed to direct treatment or
                         residues on blooming crops or weeds.  Do not apply
                         this product if bees are visiting the treatment area.
*-.
                                          13

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H.   Tolerance Reassessment

Based on the established tolerances published in 40 CFR 180.276,
the theoretical maximum residue contribution (TMRC) from forme-
tanate HC1 residues to the human diet is calculated to be 0.41
ing/day from a 1.5 kg food diet for a 60 kg person.

The Agency considers the current values for the acceptable daily
intake (ADI) of 0.025 ingAg/day and the maximum permissible
intake (MFI) of 1.5 mg/day/60 kg (MPI = ADI x 60 kg) as provisional.
This is because a number of multiple dose toxicity studies submitted
to establish the ADI/MPI were conducted by IfeT and have been
determined to be invalid.  Another reassessment and recalculation
of the ADI/MPI will be made when studies required to fill the
toxicology data gaps have been submitted and validated.

If different values are determined for the ADI and MPI then the
ratio between the MPI and TMRC will be reviewed.  It is possible
at that time, that the established tolerances may be affected.

The Agency notes that formetanate HC1 is very unstable in rat
diets.  The protocol of any feeding study should specify a daily
dietary preparation.  In addition, we suggest that with the
protocol of any formetanate HC1 chronic or subchronic study,
adequate data or citations should be included to show that the
determination of cholinesterase inhibition, stipulated by the
protocol, is optimal for carbamates.

A petition for a tolerance for residues in or on alfalfa forage
and alfalfa hay must be submitted to support the alfalfa grown-
for-seed use or the use must be deleted from the label.  No
residue data are available.  A registration was granted when
this use was regarded as a non-food use.  The Agency now considers
the use on alfalfa grown-for-seed to be a food use. -Alfalfa
sprouts are used as a human food item.  Also, there is a likeli-
hood that the label restrictions will not be followed, with
the possibility of subsequent cuttings being fed to livestock
and poultry.

A new petition for a food additive tolerance for residues in or
on dried apple pomace must be submitted.  A food additive petition
for dried apple pomace had been previously submitted but was
subsequently withdrawn.

If there is evidence to show a transfer of pesticide residues to
meat, poultry, milk or eggs, petitions for tolerances for the
residues in these commodities must also be submitted.

The U.S. and Canada have the same tolerances for residues in
citrus, apples and pears.  Tolerances for peaches and plums
differ between the U.S. and Canada.  In the U.S., the residue
limit for peaches is 5 ppm and for plums is 2 ppm, while the
Canadian residue limits are 3 ppm and 0.5 ppm, respectively.  At
present, lowering the U.S. tolerances to meet the Canadian level

                                14

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is not desirable because the registered pesticide use rate and
the pre-harvest interval would be affected.  All remaining
U.S. and Canadian tolerances are in agreement.  There are no
listing for this pesticide by Mexico or in the Codex Alimentarius.
                                15

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 I  »
              Site and Pest
                   EPA  Index  to Pesticide Chemicals

                       FORMETANATE HYDROCHLORZDE

                      Dosages and   To1erance, Use, Limitations
                      Formulation(s)
                Alfalfa (seed crop) (continued)
  IQAMARA
  Lygus bugs
  ILAVBEA
                t
  Twospotted spider
   mite
 /04001AA
Apple
If
I
  ITAPABA
*••

f. ITAPABA

ij
  IRAFBAA
                  European red mite
                  Twospotted spider
                   mite
                  Tentiform leaf-
                   miners

                  Tentiform leaf-
                   miners
                  White apple leaf-
                   hopper
0.46-0.92
 Ib/A
(92* .SC/S)
0.46-0.92
 Ib/A
(922 SC/S)
                                                    Foliar application.   Apply when
                                                    lygus bugs reach damaging numbers
                                                    and repeat as needed.  Consult State
                                                    Agricultural Experiment Station or
                                                    Agricultural Extension Service for
                                                    proper timing information.

                                                    Foliar application.   Apply by air-
                                                    craft in a minimum of 10 gallons of
                                                    water per acre or by ground equip-
                                                    ment in a minimum of 20 gallons of
                                                    water per acre.

                                                    3 ppm
                                                    7 day preharvest interval through
                                                    3.68 pounds per acre for foliar ap-
                                                    plication.  Do not apply more than
                                                    3.68 pounds per acre in the growing
                                                    season.
                      0.23-0.46 lb/ Foliar application.  Dosage used de-
                        100 gal      pends on the size of the trees and
                        [400-900     the severity of the infestation.
                        gal/A]
                      (92% SC/S)
                      0.92-3.68
                       Ib/A
                      (92* SC/S)

                      0.115-0.23
                       lb/100 gal
                       [400 gal/A]
                        or
                      0.46-0.92
                       Ib/A
                      (92Z SC/S)
              Foliar application.  Apply as a con-
              centrate spray in a minimum of 50
              gallons of water per"acre.

              Foliar application.  Per acre rates
              are to be applied as a concentrate
              spray application in a minimum of 50
              gallons of water per acre.
              Issued:   8-31-81
                             III-097301-2

                                  17

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   702002AA
Site and Pest


  Grapefruit
EPA Index to Pesticide Chemicals

   FORKETANATE HYDROCHLORIDE

   Dosages and   To 1er ance, Use, Limi tat ions
   Fonnulation(s)

                4 ppm
                7 day preharvest interval through
                4.6 pounds per acre for foliar ap-
                plication.  Allow 30 days between
                applications.  Do not apply more
                than 4.6 pounds per acre in a 12
                month period.
 : ILAJBCA
    Citrus rust mite
' IMOAAAA
I
   Thrips
fi /02004AA
If /02006AA
;•! /02008AA
 Lemon
 Orange
 Tangerine
  ILAVARA
   Citrus red mite
 ILASBCA
   Citrus rust mite
  0.0575-0.115
   lb/100 gal
   (500-1500
   gal/A]
  (92Z SC/S)

  0.115-0.23
   lb/100 gal
   {500 gal/A]
  (92Z SC/S)

  0.46 lb/
   100 gal
   [100-300
   gal/A]
    or
  0.46-1.38
   Ib/A
  (922 SC/S)
 0.46  lb/
   100  gal
   [700-1,000
   gal/A]
 (92%  SC/S)

 0.0575-0.115
   lb/100 gal
   [500-1,500
  gal/A]
 (92%  SC/S)
                                                     Use  limited  to FL.
                                                     Foliar application.
                                                    Use  limited to TX.
                                                    Foliar application.
 Use  limited  to AZ  and. CA.
 Foliar  application.  Apply per acre
 rate by aircraft in a minimum of  10
 gallons of water per acre.
4 ppm
7 day preharverst interval through
4.6 pounds per acre for foliar ap-
plication.  Allow 30 days between
applications.  Do not apply more
than 4.6 pounds per acre in a 12
month period.

Use limited to AZ and CA.
Foliar application.
                                                    Use  limited  to FL*
                                                    Foliar  application.
             Issued:  8-31-81
                              III-097301-3
                                  18

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I
 if

 I
                Site and Pest
                   EPA  Index  to Pesticide Chemicals

                       FORMETANATE HYDROCHLDR1DE

                      Dosages and   Tolerance, Use. Limitations
                      Formulation(s)
                  Lemon cluster (continued)
  •  IMOAAAA
  Thrips
    /05003AA
Nectarine
0.115-0.23
 lb/100 gal
 [500 gal/A]
(922 SC/S)

0.46 lb/
 100 gal
 [100-300
 gal/A]
  or
0.46-1.38
 Ib/A
(92Z SC/S)
                                                      Use limited to TX.
                                                      Foliar application.
Use limited to AZ and CA.
Foliar application.  Apply per acre
rate by aircraft in a minimum of 10
gallons of water per acre.
              4 ppm
              14 day preharvest interval  through
              1.84 pounds per acre for  foliar  ap-
              plication.   Do not apply  more  than
              3.68 pounds per acre in a growing
              season.
 I
    ILAVASA
    ILAVAYA

    ILAVBEA
  European red mite
  HcDaniel spider
   mite
  Twospotted spider
   mite
    IMOAAAA
  Thrips
                  Orange
                Issued:  8-31-81
0.23 lb/
 100 gal
 [400-500
 gal/A]
  or
0.92-1.15
 Ib/A
(922 SC/S)

0.23-0.345
 lb/100 gal
 [400-500
 gal/Aj
  or
0.92-1.84
 Ib/A
(92Z SC/S)
Foliar application.  Apply per acre
rate as a concentrate spray in a
minimum of 50 gallons of water per
acre.
Foliar application.  Apply when
thrlps infest blossoms through petal
fall.  Apply at night or when bees
are not working in blooms.  Apply
per acre rate as a concentrate or
aerial application.
                      See Lemon cluster.
                             II1-097301-4
                                   19

-------
 05004AA
 LAVASA
 QAMARA
 LAVAYA

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JLAJAOA
'05005AA
'05006AA
[LAVASA
LLABAYA
ILAVBE/
            Site and Pest
Peach
EPA Index to Pesticide Chemicals

   FORMETANATE HYDROCHIORIDE

  Dosages and   Tolerance, Use. Limitations
  Formulaeion(s)

                5 ppm
                21 day preharvest interval through
                1.15 pounds per acre for foliar ap-
                plication.  Do not apply more than
                2.3 pounds per acre in a growing
                season.
  European red mite
  Lygus bugs
  McDaniel spider
   mite
  Stink bugs
  Twospotted spider
   mite
Pear
  European red mite
  Twospotted spider
   mite
  Pear rust mite
  European red mite
  McDaniel spider
   mite
  Twospotted spider
   mite
  0.23  lb/
    100  gal
    (400-500
    gal/A]
    or
  0.92-1.15
    Ib/A
  (92X  SC/S)
  0.23-0.46
   lb/100 gal
   [400-800
   gal/A]
  (92Z SC/S)

  0.23 lb/
   100 gal
   [400-800
   gal/A)
  (922 SC/S)
0.23 lb/
 100 gal
 [400-600
 gal/A]
  or
0.92-1.38
 Ib/A
(92% SC/S)
              Foliar application.  Apply per acre
              rate as a concentrate spray in a
              minimum of 50 gallons of vater per
              acre.
              3 ppm
              7 day preharvest interval through
              3.68 pounds per acre for foliar ap-
              plication.  Do not apply more than
              3.68 pounds per acre in a growing
              season.

              Foliar application.  Dosage used de-
              pends on the sice of the trees and
              the severity of the infestation.
              Foliar application.  Apply from
              postbloom to harvest beginning
              application at first sign of mite
              infestation.
                2 ppm (plums, fresh prunes)
                7 day preharvest interval through
                1.38 pounds per acre for foliar ap-
                plication.  Do not apply more than
                2.76 pounds per acre in a growing
                season.

                Use limited to the West Coast.
                Foliar application*  Apply per acre
                rate as a concentrate spray in a
                minimum of 50 gallons of water per
                acre.
            Issued:   8-31-81
                             III-097301-5
                                   20

-------
/02007AA
            Site and Pest
  Tangelo
1MOAAAA
    Thrips
EPA Index to Pesticide Chemicals

   FORMETANATE HYDROCHLORIDE

  Dosages and   Tolerance, Use, Limitations
  Formulations)

                4 ppm  (tangerines)
                7 day  preharvest interval through
                1.38 pounds per acre for foliar ap-
                plication.  Allow 30 days between
                applications.  Do not apply more
                than 4.6 pounds per acre in a 12
                month  period.
              Tangerine
   0.46  lb/
    100  gal
    (100-300
    gal/A]
    or
   0.46-1.38
    Ib/A
   (92%  SC/S)
                        See Lemon cluster.
Use limi'ted to AZ and CA.
Foliar application.  Apply per acre
rate as an aerial application in a
minimum of 10 gallons of water per
acre.
  01500
AERIAL. MOTHPROOFING AND TANK MIX APPLICATIONS

  Aerial Application

                        Refer to
                        AGRICULTURAL CROPS
                                                  Alfalfa,  Grapefruit,  Lemon, Orange,
                                                  Tangelo,  Tangerine
            Issued:   8-31-81
                               III-097301-6
                                     21

-------
                      EPA Index to Pesticide Chemicals

                         FORtCTANATE HYDROCHLOR1DE

 Listing of Registered  Pesticide Products by Formulation

 921 technical  chemical
   formetanate  hydrochloride  (097301)
     002139-00114

 92% soluble concentrate/solid
   formetanate  hydrochloride  (097301)
     002139-00099
State Label Registrations

  AZ Reg. No.
    002139-04325

  CA Reg. No.
    002139-04324

  FL Reg. No.
    002139-04326

  OR Reg. No.
    002139-04322

  TX Reg. No.
    002139-04327

  WA Reg. No.
    002139-04359
Issued:  8-31-81
III-097301-7
      22

-------
II.   REQUIREMENT FOR SUBMISSION OF GENERIC DATA

    A.  This portion of the guidance document is a Notice
        issued under the authority of FIFRA Section 3(c)(2)(B)
        and describes, in table format, the data required
        for maintaining the registrability of each product.
        Additionally, a bibliography (Appendix II-l) is
        included that identifies that data considered as
        part of the data base supporting this standard.  EPA
        has determined that additional generic data described
        in this Notice must be submitted to EPA for evaluation
        in order to maintain in effect the registration^)
        of your product(s) identified as an attachment to
        the cover letter accompanying this guidance document.
        As required by FIFRA Section 3(c)(2)(B), you are
        required to take appropriate steps to comply with
        this Notice.

        EPA may suspend the registration of each of those products
        unless, within the specified time, you have informed EPA
        how you will satisfy the requirements of this Notice.
        Any such suspension will remain in effect until you have
        complied with the terms of this Notice.

    B.  What Generic Data */ Must Be Submitted.  You may ascertain
        which generic data you must submit by consulting Table A
        at the end of this chapter.  That table shows all the
        generic data needed to evaluate the continued registrability
        of all products, and the dates by which the data must be
        submitted.  The required data must be submitted and any
        necessary studies must be conducted in accordance with
        EPA-approved protocols, the Pesticide Registration
        Guidelines 2/, or data collected under the approved
        protocols o? the Organization for Economic Cooperation
        and Development (OECD).  If you wish not to develop data
        which are necessary to support the registration or
        reregistration of certain uses appearing in your labeling,
        you may delete those uses at the time you submit your
        revised labeling.

        Also for certain kinds of testing (generally ecological
        effects), EPA requires the test substance to be a "typical
        formulation," and in those cases EPA needs data of that
    I/ Generic data pertain to the properties or effects of a
particular ingredient, and thus are relevant to an evaluation of
the risks of all products containing that ingredient (or all such
products having a certain use pattern), regardless of any such
product's unique composition or use.  Product-specific data relate
only to the properties or effects of a product with a particular
composition (or a group of products with closely similar composition)

    2/ The Pesticide Registration Guidelines were reproposed on
November 24, 1982 in 47 Federal Register 53192.

                              23

-------
    c.
type for each major formulation category (e.g.* emulsifiable
concentrates, wettable powders, granulars,  etc.)  These
are classified as generic data and when needed are
specified in Table A.  EPA may possess data on certain
"typical formulations" but not others.  Note:  The "typical
formulation" data should not be confused with product-
specific data (Table B) which are required  on each
formulation.  Product-specific data are further explained
in Chapter IV of this document.

Options Available for Complying With Requirements
to Submit Data
        Within 90 days of your receipt of this Notice you must
    submit to EPA a completed copy of the form entitled "FIFRA
    Section 3(c)(2)(B) Summary Sheet" [EPA Form 8580-1, Appendix
    I1-2] for each of your products.  On that form you must
    state which of the following methods you will use to comply
    with the requirements of this Notice:

    1.  (a) Notify EPA that you will submit the data, and

        (b) either submit the existing data you believe
            will satisfy the requirement, or state that
            you will generate the data by conducting
            testing.  If the test procedures you will
            use deviate from (or are not specified in)
            the Registration Guidelines or protocols
            contained in the Reports of Expert Groups
            to the Chemicals Group, Organization for
            Economic Cooperation and Development (OECD)
            Chemicals Testing Programme, you must enclose
            the protocols you will use.
                                                     4V
    2.  Notify EPA that you have entered into an agreement
        with one or more other registrants to jointly
        develop (or share in the cost of developing) the
        data.  If you elect this option, you must notify EPA
        which registrant(s) are parties to the agreement.

    3.  File with EPA a completed "Certification of Attempt to
        Enter Into an Agreement With Other Registrants for
        Development of Data* (EPA Form 8580-6, Appendix II-3)V

    4.  Request that EPA amend your registration by deleting the
        uses for which the data are needed.  (This option is not
        available to applicants for new products.)
     */ FIFRA Section 3(c)(2)(B) authorizes joint development of
data Ey two or more registrants, and provides a mechanism by
which parties can obtain an arbitrator's decision if they agree
to jointly develop data but fail to agree on all the terms of
the agreement.  The statute does not compel any registrant to
agree to develop data jointly.
(Footnote continued at bottom of next page)

                                24

-------
        Request voluntary cancellation of the registration(s)
        of your products for which the data are needed.  (This
        option is not available to applicants for new products.)

        Procedures for Requesting Changesin TestingMethodology
        and Extensions of Time

        EPA recognizes that you may disagree with our conclusions
        regarding the appropriate ways to develop the required
        data or how quickly the data roust be submitted.  If the
        test procedures you plan to use deviate from (or are not
        specified in) the registration guidelines or protocols
        contained in the reports of the Expert Groups to the
        Chemical Groups, Organization for Economic Cooperation
        and Development (OECD) Chemicals Testing Programme, you
        must submit the protocol for Agency review prior to the
        initiation of the test.

        If you think that you will need more time to generate the
        required data than is allowed by EPA's schedule, you may
        submit a request for an extension of time.  The extension
        request must be submitted in writing to the Product
        Manager.  The extension request should state the reasons
        why you conclude that an extension is appropriate.  While
        EPA considers your request, you must strive to meet the
        deadline for submitting the required data.
(Footnote continued from previous page)
     In EPA's opinion, joint data development by all registrants
who are subject to the requirements to submit a pertinent item
of data or a cost-sharing agreement among all such registrants
is clearly in the public interest.  Duplication of testing could
increase costs, tie up testing facilities, and subject an unneces-
sarily large number of animals to testing.
      As noted earlier, EPA has discretion not to suspend the
registration of a product when a registrant fails to submit data
required under FIPRA Section 3(c)(2)(B).  EPA has concluded that
it is appropriate to exercise its discretion not to suspend in
ways which will discourage duplicative testing.  Accordingly, if
(1) a registrant has informed us of his intent to develop and
submit data required by this Notice; and (2) a second regis-
trant informs EPA that it has made a bona fide offer to the
first registrant to share in the expenses of the testing [on
terms to be agreed upon or determined by arbitration under FIFRA
Section 3(c)(2)(B)(iii)]; and (3) the first registrant has declined
to agree to enter into a cost-sharing agreement, EPA will not
suspend the second firm's registration.  While the first firm is
not required to agree to jointly develop data, EPA is not required
to force the second firm to engage in economically inefficient
duplicative testing in order to maintain its registration.

                                25

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III.  REQUIREMENT FOR SUBMISSION OF PRODUCT-SPECIFIC DATA

    Note:  This chapter applies only to manufacturing-use products,
not end-use products.

    A necessary first step in determining which statements must
appear on your product's label is the completion and submission
to EPA of product-specific data* listed on the form entitled
"Product Specific Data Report" (EPA Form 8580-4, Appendix III-l)
to fill "gaps" identified by EPA concerning your product.  Under
the authority of FIFRA Section 3(c)(2)(B), EPA has determined
that you must submit these data to EPA in order to register or
reregister your product(s).  All of these data must be submitted
not later than six months after you receive this guidance document.

    "Product-Specific Data Requirements for Manufacturing-Use
Products" appearing in Table B permit you to determine which
product-specific data you must submit.  This can be done by
examining the entries in the column of those tables entitled
"Must Data Be Submitted Under S3(c)(2)(B)."
     */ Product specific data pertains to data that support the
formulation which is marketed; it usually includes product
chemistry data and acute toxicology data.

                                48

-------
t

ir:
IV.  SUBMISSION OF REVISED LABELING AND PACKAGING INFORMATION

    Note:  This chapter applies only to manufacturing-use products,
not end-use products.

    The Agency requires applicants for registration or reregistra-
tion to ensure that each label (1) contains accurate, complete,
and sufficient instructions and precautions, reflecting the
results of data concerning the product and its ingredients, and
(2) incorporates labeling format and terminology which are suffi-
ciently standardized to avoid user confusion.

    As part of your application, you will be required to submit
draft labeling consistent with:  applicable product-specific
data; the precautionary statements and use directions; and the
regulations concerning classification [40 CFR S162.11(c)], pack-
aging [40 CFR $162.16], and labeling [40 CFR $162.10], as indicated
by the following paragraphs of this chapter of the guidance
document.

    You will Jae informed later when you must submit the revised
labeling set forth in this guidance package.

    A.  Label Contents

        40 CFR $162.10 requires that certain specific labeling
    statements must appear at certain locations on the label.
    This is referred to as format labeling.  Specific label
    items listed below are keyed to Tables D, E, and F (Appendix
    IV-2).

        Item 1.  PRODUCT NAME - The name, brand, or trademark is
    required to be located on the front panel, preferably centered
    in the upper part of the panel.  The name of a product will
    not be accepted if it is false or misleading.  [40 CFR
    $162.10(b)]

        Item 2.  COMPANY NAME AND ADDRESS - The name and address
    of the registrant or distributor is required on the label.
    The name and address should preferably be located at the
    bottom of the front panel or at the end of the label text.
    [40 CFR §162.10(c)J

        Item 3.  NET CONTENTS - A net content statement is required
    on all labels.  The preferred location is the bottom of the
    front panel immediately above the company name and address,
    or at the end of the label text.  The net contents must be
    stated in terms of weight, expressed as avoirdupois pounds
                                           49

-------
.
it
and ounces, and stated in terms of the largest suitable unit,
i.e., "1 pound 10 ounces" rather than "26 ounces."  In
addition to the required units specified, net contents may be
expressed in metric units.   [40 CFR $162.10(d)]

    Item 4.  EPA REGISTRATION NUMBER - The registration
number assigned to the pesticide product must appear on the
label, preceded by the phrase "EPA Registration No.," or "EPA
Reg. Ho."  The registration number must be set in type of a
size and style similar to other print on that part of the
label on which it appears and must run parallel to it.  The
registration number and the required identifying phrase must
not appear in such a manner as to suggest or imply recommendation
or endorsement of the product by the Agency.
[40 CFR Sl62.10(e)]

    Item 5.  EPA ESTABLISHMENT NUMBER - The EPA establishment
number, preceded by the phrase "EPA Est." is the final estab-
lishment at which the product was produced, and may appear
in any suitable location on the label or immediate container.
It must also appear on the wrapper or outside container of
the package if the EPA establishment registration number on
the immediate container cannot be clearly read through such
wrapper or container.  [40 CFR §162.10(f)]

    Item 6.  INGREDIENT STATEMENT - An ingredient statement
is required on the front panel and must contain the name and
percentage by weight of each active ingredient and the total
percentage by weight of all inert ingredients.  The preferred
location is immediately below the product name.  The ingredient
statement must run parallel with, and be clearly distinguished
from, other text on the panel.  It must not be placed in the
body of other text.  [40 CFR 162.10(g)J

    Item 6A.  POUNDS PER GALLON STATEMENT - For'liquid
agricultural formulations, the pounds per gallon of active
ingredient must be indicated on the label.

    Item 7.  FRONT LABEL PRECAUTIONARY STATEMENTS - All labels
are required to have precautionary statements grouped together
on the front panel, preferably within a block outline.  The
table below shows the minimum type size requirements on
various size labels, as set forth in the Regulations.
                                          50

-------
Size of Label
on Front Panel
in Square Inches

5 and under
above 5 to 10
above 10 to 15
above 15 to 30
over 30
Signal Word as Re-
quired Minimum Type
Size Al1 Capi tals

      6 point
     10 point
     12 point
     14 point
     18 point
"Keep Out of Reach
    of Children"
    asRequired

     € point
     6 point
     8 point
    10 point
    12 point
    Item 7A.  CHILD HAZARD WARNING STATEMENT - All labels are
required to have the statement "Keep Out of Reach of Children"
located on the front panel above the signal word except where
contact with children during distribution or use is unlikely.
[40 CFR Sl62.10(h)(l)(ii)]

    Item 7B.  SIGNAL WORD - The signal word (Caution, Warning,
or Danger) is required on the front panel immediately below
the child hazard warning statement.  [40 CFR §162.10 (h)(l)(i)J

    Item 7C.  SKULL & CROSSBONES AND WORD "POISON" - On products
assigned a toxicity Category I on the basis of oral, inhala-
tion, or dermal toxicity, the word "Poison" shall appear on
the label in red on a background of distinctly contrasting
color and the skull and crossbones shall appear in immediate
proximity to the word poison.  [40 CFR S162.10(h)(1)(i)]

    Item 7D.  STATEMENT OF PRACTICAL TREATMENT - A statement
of practical treatment (first aid or other) shall appear on
the label of pesticide products in toxicity Categories I,
II, and III.  [40 CFR §162.10(h)(1)(iii)]

    Item 7E.  REFERRAL STATEMENT - The statement "See Side
(or Back) Panel for Additional Precautionary Statements" is
required on the front panel for all products, unless all
required precautionary statements appear on the front panel.
[40 CFR S162.10(h)(l)(iii>]

    Item 8.  SIDE/BACK PANEL PRECAUTIONARY LABELING - The
precautionary statements as listed below must appear together
on the label under the heading "PRECAUTIONARY STATEMENTS."
The preferred location is at the top of the side or back
panel preceding the directions for use, and it is preferred
that these statements be surrounded by a block outline.  Each
of the three hazard warning statements must be headed by the
appropriate hazard title.  [40 CFR $162.10 (h)(2)]
                            51

-------
    Item 8A.  HAZARD TO HUMANS AND DOMESTIC ANIMALS - Where a
hazard exists to humans or domestic animals, precautionary
statements are required indicating the particular hazard, the
route(s) of exposure and the precautions taken to avoid
accident, injury or damage.  [40 CFR $162.10 (h)(2)(i)]

    Item 8B.  ENVIRONMENTAL HAZARD - Where a hazard exists to
non-target organisms excluding humans and domestic animals,
precautionary statements are required stating the nature of
the hazard and the appropriate precautions to avoid potential
accident, injury, or damage.  [40 CFR S162.10(h)(2)(ii)]

    Item 8C.  PHYSICAL OR CHEMICAL HAZARD

    1.  Flamntability statement.  Precautionary statements
        relating to flammability of a product are required
        to appear on the label if it meets the. criteria in
        Appendix IV-3.  The requirement is based on the results
        of the flashpoint determinations and flame extension
        tests required to be submitted for all products.
        These statements are to be located in the side/back
        panel precautionary statements section, preceded by
        the heading 'Physical/Chemical Hazards."  Note that
        no signal word is used in conjunction with the flam-
        mability statements.

    2.  Criteria for declaration of non-flammability.  The
        following criteria will be used to determine if a
        product is non-flammable:

        a.  A "non-flammable gas" is a gas (or mixture of
            gases) that will not ignite when a lighted match
            is placed against the open cylinder valve.

        b.  A "non-flammable liquid" is one having a flash-
            point greater than 350°F (177°C) as determined
            by the method specified in 40 CFR Sl63.61-8(c)(13)
            (ii) of Subpart D.

        c.  A "non-flammable aerosol" is one which meets the
            following criteria:

            i.  The flame extension is zero inches, using the
                method specified in 40 CFR Sl63.61-8(c)(13)(ii);

           ii.  There is no flash back; and

          iii.  The flashpoint of the non-volatile liquid
                component is greater than 350°F (177°C),
                determined by the method specified in 40 CFR
                Sl63.61-8(c)(13)(i).

                            52

-------
    3«  Declaration of non-flammability.  Products which meet
        the criteria for non-flammability specified above may
        bear the notation "non-flammable11 or "nonflammable
        (gas, liquid, etc.)* on the label.

        It may appear as a substatement to the ingredients
        statement, or on a back or side panel, but shall not
        be highlighted, or emphasized (as with an inordinately
        large type size) in any way that may detract from
        precaution.

    4.  Other physical/chemical hazard statements.  When
        chemistry data submitted in accordance with 40 CPR
        S163.61-10(c) demonstrate hazards of a physical or
        chemical nature other than flammability, appropriate
        statements of hazard will be prescribed.  Such
        statements may address hazards of explosivity,
        oxidizing or reducing capability, or mixing with
        other substances to produce toxic fumes.

    Item 9.  MISUSE STATEMENT - The following statement is
required on your label:  "It is a violation of Federal law to
use this product in a manner inconsistent with its labeling."
[40 CFR S162.10(l)(2)(ii)]

    Item 10A.  STORAGE AND DISPOSAL BLOCK -  All labels are
required to bear storage and disposal statements.  These
statements are developed for specific containers, sizes, and
chemical content.  Make certain that the statement you use
pertains specifically to your product.  These instructions
must be grouped and appear under the heading "Storage and
Disposal" in the directions for use.  This heading must be
set in the same type sizes as required for the child hazard
warning.  Refer to Appendix IV-5 for the latest specific
storage and disposal product label statements.

    Item 10B.  DIRECTIONS FOR USE - Directions for use must
be stated in terms which can be easily read and understood by
the average person likely to use or to supervise the use of
the pesticide.  When followed, directions must be adequate to
protect the public from fraud and from personal injury and to
prevent unreasonable adverse effects on the environment.
[40 CFR $162.10]

B.  Collateral Information

    Bulletins, leaflets, circulars, brochures, data sheets,
flyers, and other graphic printed matter which is referred to
on the label or which is to accompany the product are termed
collateral labeling.  Such labeling may not bear claims or
representations that differ in substance from those accepted
in connection with registration of the product.  It should be
made part of the response to this notice and submitted for review.

                            53

-------
V.
INSTRUCTIONS FOR SUBMISSION
    All applications prepared in response to this Notice should
be addressed as follows:

    (Product Manager]
    Phone No. (703)
    Registration Division .(TS-767)
    Office of Pesticide Programs
    Environmental Protection Agency
    Washington, D.C.  20460
                                           •
For each product for which continued registration is desired:

    1.  Within 90 days from receipt of this document, you must
        submit the "FIFRA Section 3(c)(2)(B) Summary Sheet" EPA
        Form 8580-1.  Refer to Appendix II-2 with appropriate
        attachments.

    2.  Within 6 months from receipt of this document registrants
        must submit:

        a.  Confidential Statement of Formula, EPA Form 8S70-4.
                  %
        b.  Product Specific Data Report, EPA Form 8580-4 (Appendix
        c.  Two copies of any required product-specific data.

    3.  Within the time set forth in Table A, all generic data
        must be submitted by the affected registrant (s).

Note:  If for any reason any required test is delayed or aborted
       so that meeting the agreed submission time will be delayed,
       notify the Product Manager listed above.

You will be informed at a later date when you must submit your
Application for Amended Pesticide Registration (EPA Form 8570-1)
and the revised labeling set forth in this guidance package.
                                54

-------
                                                                  Appendix II-l
                           OFFICE OF PESTICIDE PROGRAMS
                        REGISTRATION STANDARD BIBLIOGRAPHY
           Citations Considered to be Part of the Data Base Supporting
                         Registration Under the Standard

00006652     Atkins, E.L.; Greywood, E.A.; Macdonald, R.L. (1973) Toxicity of
                Pesticides and Other Agricultural Chemicals to Honey Bees:
                Laboratory Studies.  Rev. By Univ. of California, Dept. of
                Entomology.; Riverside, Calif.: U.C.  (Agricultural Extension
                M-16; also In unpublished submission received Nov. 17, 1975 un-
                der 359-620; submitted by Rhone-Poulenc, Inc., Monmouth Junc-
                tion, MJ; CDL:223344-A)

00077656     Michigan State University (1968?) Residues of C 14 Formetanate-
                hydrochloride in Green Sunfish following a Subacute Exposure.
                (Unpublished study received Nay 18, 1973 under 2139-99; CDL:
                124298-A)

00077658     McCann, J.A. (1970) Carzol SP: Bluegill (Lepomis macrochi-
                rus): Test No. 284.  (U.S. Agricultural Research Service,
                Pesticides Regulation Div., Animal Biology Laboratory; unpub-
                lished study; CDL:108518-A)

00077659     Nor-Am Agricultural Products, Incorporated (19??) Carzol SP: Chem-
                ical and Physical Properties.  (Unpublished study received July
                22, 1968 under 2139-99; CDL:100133-A)

             Schoenig, G. (1967) Report to Morton Chemical Company: Acute Tox-
                icity Studies on EP-332 HC1, Technical: IBT No. A5341.  (Unpub-
                lished study received Sep 11, 1969 under 9G0746; prepared by
               . Industrial Bio-Test Laboratories, Inc., submitted by Morton
                Chemical Co., Woodstock, IL; CDL:091289-B)

00077668     Hathaway, D. (1967) Report to Morton Chemical Company: Acute Dust
                Inhalation Toxicity of EP-332 HC1, Technical: IBT No. N5342.
                (Unpublished study rceived Sep 11, 1969 under 9G0746; prepared
                by  Industrial Bio-Test Laboratories, Inc., submitted by Morton
                Chemical Co., Woodstock, IL.; CDL:091289-D)

00077680     Sen Gupta, A.K.; Khowles, C.O. (1970) Fate of formetanate- 14C
                acaricide in the rat.  Journal of Economic Entomology 63(1):10-
                14. (Also in unpublished submission received Jun 17, 1971 under
                OF0961; submitted by Nor-Am Agricultural Products, Inc., Naper-
                ville, IL.; CDL.-092155-H)

00077703     Knowles, C.O.; Sen Gupta, A.K. (1970) Metabolism of Formetanate
                Acaricide by Orange Seedlings.  (Unpublished study received Apr
                12, 1970 under OF0961; prepared by Univ. of Missouri, Dept. of
                Entomology, submitted by Nor-Am Agricultural Products, Inc.,
                Naperville, IL.; CDL:091643-E)
VD77666

-------
                                                                    Appendix II-l
                                                                    (continued)
                             OFFICE OF PESTICIDE PROGRAMS
                          REGISTRATION STANDARD BIBLIOGRAPHY
             Citations Considered to be Part of the Data Base Supporting
                           Registration Under the Standard

  0007709      Jenny, N.A. (1969) Decomposition of Formetanate HC1 in United
                  States Soils: 332/47.  (Unpublished study, including published
                  data, received Apr 12, 1970 under OF0961; submitted by Nor-Am
                  Agricultural Products, Inc., Naperville, IL.; CDL:091643-K)

  00077728     Palazzolo, R.J. (1967) Report to Morton Chemical Company: Human
                  Repeated Insult Patch Test on EP-332 HC1: IBT No. 5343. (Unpub-
                  lished study received Apr 15, 1970 under OF0961; prepared by
                  Industrial Bio-Test Laboratories, Inc., submitted by Nor-Am
                  Agricultural Products Inc., Naperville, IL., CDL:091642-J)

  00077730     Nor-Am Agricultural Products, Incorporated (1973) Disappearance of
                  Formetanate Rydrochloride Residues in Soil (Field Studies).  (Un-
                  published study received may 18, 1973 under OF0961; CDL:091934-A)

  00077731     Nor-Am Agricultural Products, Incorporated (1972) Pesticide Fate  and
                  Movement in Soil: Summary of Soil Studies.  (Compilation; unpub-
                  lished study received May 18, 1973 under OF0961; CDL: 091934-B)

' ^tf7732     Nor-Am Agricultural Products, Incorporated (1972) Pesticide Fate
                  and Movement in Soil: Summary of Soil Studies.  (Compilation;
                  unpublished study received May 18, 1973 under OF0961; CDL:
                  091934-C)

  00077733     Nor-Am Agricultural Products, Incorporated (1972) Pesticide Fate
                  and Movement in Soil: Summary of Soil Studies. (Compilation;
                  unpublished study, including published data, received May; 18,
                  1973 under OF0961; CDL:091934-D)

  00077734     Nor-Am Agricultural Products, Incorporated (1973) Pesticide Fate
                  and Movement in Soil: Summary of Soil Studies.  (Compilation;
                  unpublished data, received May 18, 1973 under OF0961; CDL:
                  091934-E)

  00077735     Nor-Am Agricultural Products, Incorporated (1973) Pesticide Fate
                  and Movement in Soil. (Compilation; unpublished study, includ-
                  ing published data, received May 18, 1973 under OF0961; CDL:
                  091934-F)

  00077760     Johansen, C. (19??) Small-scale Bee Poisoning Tests with Honey
                  Bees, Alkali Bees, and Alfalfa Leafcutting Bees.  (Unpublished
                  Study received Mar 16, 1970 underOF0961; submitted by Nor-Am
                  Agricultural Products, Inc., Naperville, IL.; CDL:093272-C)
 ^7
t

-------
                                                                    Appendix II-l
                                                                    (continued)
   GS0091005
  GS0091006
  GS0091009
  GS0091010
  GS0091011
        1012
  GS0091013
  GS0091014
  GS0091015
  GS0091016
,  GS0091017
                OFFICE OF PESTICIDE PROGRAMS
             REGISTRATION STANDARD BIBLIOGRAPHY
Citations Considered to be Part of the Data Base Supporting
              Registration Under the Standard

  Nor-Am Agricultural Products, Inc. (1968) Formetanate HC1:  Chemical
     and Physical Properties Analysis (Unpublished study received
     Sep 7, 1968 under 900746; CDL:RCB-115705)

  Nor-Am Agricultural Products, Inc. (1970) Formetanate HC1;  Name,
     Chemical, Identity and Composition (Unpublished study received
     Mar 12, 1970 under OF0961; CDL:RCB-116585)

  Nor-Am Agricultural Products, Inc. (1970) Metabolism of Formetanate
     HC1 in Animals (Unpublished study received Apr 1, 1970 under
     OF0961yCDLiRCB-116585)

  Zwieg, Gunter, editor. (1974) Analytical Methods for Pesticides and
     Plant Growth Regulators Vol. 7 Academic Press

  Nor-Am Agricultural Products, Inc. (1968) Formetanate HC1:  Residue
     Data (Unpublished study received Aug 7, 1968 under 9G0746;  COL:
     PCB-115708)

  Nor-Am Agricultural Products, Inc. (1970) Results of test on the
     amount of residue remaining including a description of the
     analytical method used (Unpublished study received Apr 1, 1970
     under OF0961; CDL: RCB-116585)

  Nor-Am Agricultural Products, Inc. (1971) Residues in Citrus Fruits
     (Grapefruits and Tangerines) (Unpublished study received. Jan  11,
     1971 under 1F1141; CDL:RCB-117306)

  Nor-Am Agricultural Produts, Inc. (1972) Formetanate HC1: Results
     of Tests on the Amount of Residue Remaining in Peaches,  Plums,
     Prunes, Nectarines and Grapes (Unpublished study received Mar
     1, 1972 under 2F1238; CDL:RCB-117724)

  Nor-Am Agricultural Products, Inc. (1970) Recovery of Formetanate
     (Summary) (Unpublished study received Jun 5, 1970 under  OF0989;
     CDL:RCB-116295)

  Nor-Am Agricultural Products, Inc. (1974) Residues in Grapes and
     Grape By-Products (Unpublished study received Mar 5, 1973 under
     3F1351; CDL:R€B-118095)

  U.S. Department of Health, Education, and Welfare, Food and Drug
     Administration. (1978) Pesticides Analytical Manual Vol. II. U.S.
     Government Printing Office, Washington, D.C.

-------
                                                               Appendix II-l
                                                               (continued)
                           OFFICE OF PESTICIDE PROGRAMS
                        REGISTRATION STANDARD BIBLIOGRAPHY
           Citations Considered to be Part of the Data Base Supporting
                         Registration Under the Standard

GS0091018    Lawrence, J.F. et al (1981) Determination of the Insecticide/
               Acaracide Formetanate in Fresh Fruit by Reversal Phase Liquid
               Chromotography.  Journal Agriculture and Food Chemistry 29:722.

GS0091021    Nor-Am Agricultural  Products, Inc. (1972) Formetanate HC1 in or on
               Raisins and Dried  Prunes (Unpublished study received Mar 1. 1972
               under 2F1238; CDL:RCB-117725)

GS0091022    Nor-Am Agricultural  Products, Inc. (1970) Residues in Apples and
               Pears (Unpublished study received May 22, 1970 under OF0989;
               CDL:RCB-116294)

GS0091030    Fletcher, D.; Jenkins,  D.H.; Keplinger, M.L. (1971) Acute Oral
               Ibxicity Study with Carzol in Mallard Ducks - Report No. J 260
               (Unpublished study received on July 7, 1983 under 2139-99; Pre-
               pared by Industrial Bio-Test Laboratories, Inc.  Submitted by
               Nor-Am Agricultural Products, Inc., Naperville, IL.;  CDL:250683)

             Fletcher, D; Jenkins, D.H.; Keplinger, M.L. (1971) Acute Oral
               Ibxicity Study with Carzol in Bobwhite Quail - Report No. J259
               (Unpublished study received on July 7, 1983 under 2139-99; Pre-
               pared by Industrial Bio-Test Laboratories, Inc. Submitted by
               Nor-Am Agricultural Products, Inc., Naperville, IL.;  CDL:250684)

GS0091032    Jackson, G.L.; Fancher, O.E.; Calandra, J.C. (1967) Bird Wildlife
               Studies EP-332 Ha -  Report No. J5354 (Unpublished study received
               on August 11, 1983 under 2139-99; Prepared by Industrial Bio-Test
               Labs, Inc. Submitted  by Nor-Am Agricultural Products, Inc.,
               Naperville, IL.;   CDL:250995)

GS0091033    Rausina, G. (1975) Four Day Static Aquatic Ibxicity Studies with
               Carzol in Grass Shriirp and Shore Crabs - Report No. 621-06936
               (Unpublished study received on August 11, 1983 under 2139-99;
               Prepared by Industrial Bio-Test Labs, Inc. Submitted by NOR-AM
               Agricultural Products, Inc. CDL:250994)
091031

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                                                                                 OMB Approval No. 20004468 (Expires 12-31-83)
                  FIFHA SECTION 3(C)(2)(B) SUMMARY SHEET
                                                                                          EPA REGISTRATION NO.
PRODUCT NAME
APPLICANT'S NAME
                                                                                          DATE GUIDANCE DOCUMENT ISSUED
  With respect to the requirement to submit "generic" date imposed by the FIFRA section 3{C)(2)(B) notice contained in the referenced
  Guidance Document, I em responding in the following menner:
         . I will submit date in • timely menner to satisfy the following requirements. If the test procedures I will use deviate from (or are not
           specified in) the Registration Guidelines or the Protocols contained in the Reports of Expert Groups to the Chemicals Group, OECD
           Chemicals Testing Programme, I enclose the protocols that I will use:
     D 2.  I have entered into an agreement with one or more other registrants under FIFRA section 3(C)(2)(B){ii) to satisfy the following data
           requirements. The tests, and any required protocols, will be submitted to EPA by:

  NAME OF OTHER REGISTRANT                                                                                        "
     D 3.  I enclose a completed "Certification of Attempt to Enter Into an Agreement with Other Registrants for Development of Data" with
           respect to the following data requirements:
     D 4.  I request that you amend my registration by deleting the following uses (this option is not available to applicants for new products):
     D 5.  I request voluntary cancellation of the registration of this product (This option is not available to applicants for new products.)
REGISTRANT'S AUTHORIZED REPRESENTATIVE
                                                        SIGNATURE
                                                                                                             DATE
iPA Form 8580-1 11042)

-------
                                                          Appendix III-l
EPA Registration No.
 PRODUCT SPECIFIC DATA REPORT
	Guidance Document for_
                           Date
Registration
Guideline No.
SI 58. 20
PRODUCT
CHEMISTRY
61-1
61-2
61-3
62-1
62-2
62-3
63-2
63-3
63-4
63-5
63-6
63-7
63-8
63-9
63-10
63-11
63-12
63-13
63-14
63-15
63-16
63-17
63-18
63-19
Name of Test

Identity of
ingredients
Statement of
composition
Discussion of
formation of
ingredients
Preliminary
analysis
Certification of
'limits
Analytical methods
for enforcement
limits
Color
Physical state
Odor
Melting point
Boiling point
Density, bulk-
density, or
specific gravity
Solubility^
Vapor pressure
Dissociation
constant
Octanol/water
partition
coefficient
PH
Stability
Oxidizing/reducing
reaction
Flammability
Explodability
Storage stability
Viscosity
Miscibility
Test not
required
for my
product
listed
above
(check
below)

























I am complying with
data requirements by
Citing MRIDf

























Submit-
ting
Data
(At-
tached)

























(For EPA Use Only)
Accession Numbers
Assigned


























-------
63-20
63-21
SI 58. 135
TOXICOLOGY
81-1
81-2
81-3
81-4
81-5
81-6
Corrosion
characteristics
Dielectric break-
down voltage

Acute oral LD-50,
rat
Acute dermal
ID-50
Acute inhalation,
LC-50 rat
Primary eye
irritation f rabbit
Primary dermal
irritation
Dermal sensitiza-
tion














.

















V




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-------
                                                   Appendix IV-3
                    PHYSICAL-CHEMICAL HAZARDS
Criteria
I.  Pressurized Containers
    A.
Flashpoint at or below
20°F; or if there is a
flashback at any valve
opening.
    B,
Flashpoint above 20°F
and not over 80°F; or
if the flame extension
is more than 18 inches
long at a distance of
6 inches from the
valve opening.

ALL OTHER PRESSURIZED
CONTAINERS
II.  Non-Pressurized Containers

    A.  Flashpoint at or below
        20°F.
    B.  Flashpoint above 20°F
        and over 80°F.

    C.  Flashpoint over 80°F
        and not over 150°F.

    D.  Flashpoint above
        150°F.
                              Required Label Statement
Extremely flammable.
Contents under pressure.
Keep away from fire, sparks,
and heated surfaces.  Do not
puncture or incinerate
container.  Exposure to
temperatures above 130°F
may cause bursting.

Flammable.  Contents under
pressure.  Keep away from
heat, sparksr and flame.  Do
not puncture or incinerate
container.  Exposure to
temperatures above 130°F
may cause bursting.

Contents under pressure.
Do not use or store near
heat or open flame.  Do not
puncture or incinerate
container.  Exposure to
temperatures above 130°F
may cause bursting.
                              Extremely flammable.  Keep
                              away from fire, sparks, and
                              heated surfaces.

                              Flammable.  Keep away from
                              heat and open flame.

                              Do not use or store near
                              heat and open flame.

                              None required.

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                                               Appendix IV-5

       STORAGE AND DISPOSAL INSTRUCTIONS FOR PESTICIDES

All products are required to bear specific label instructions
about storage and disposal.  Storage and disposal instructions
must be grouped together in the directions for use portion of
the label under the heading STORAGE AND DISPOSAL.  Products
intended solely for domestic use need not include the heading
"STORAGE AND DISPOSAL."  The STORAGE AND DISPOSAL heading
must appear in the minimum type size listed below:
 Size of label
 front panel in
 square inches
 Required  type size
 for the heading
 STORAGE AND DISPOSAL
(all capitals)	
 10 and under	6 point
 Above 10 to 15	8 point
 Above 15 to 30	10 point
 Over 30	12 point
Storage and disposal instructions must be set apart and
clearly distinguishable from other directions for use.
Blocking storage and disposal statements with a solid line is
suggested as a means of increasing their prominence.

A.  Storage Instructions;

All product labels are required to have appropriate storage
instructions.  Specific storage instructions are not prescribed.
Each registrant must develop his own storage instructions,
considering, when applicable, the following factors:*

1.  Conditions of storage that might alter the composition or
    usefulness of the pesticide.  Examples could be temperature
    extremes, excessive moisture or humidity, heat, sunlight,
    friction, or contaminating substances or media.

2.  Physical requirements of storage which might adversely
    affect the container of the product and its ability to
    continue to function properly.  Requirements might include
    positioning of the container in storage, storage or damage
    due to stacking, penetration of moisture, and ability to
    withstand shock or friction.

3.  Specifications for handling the pesticide container,
    including movement of container within the storage area,
    proper opening and closing procedures (particularly for
    opened containers), and measures to minimize exposure
    while opening or closing container.
                                                                        V

-------
                                                           Appendix IV-5
                                                           (continued)

f          4.  Instructions on what to do if the container is damaged in
•              any way, or if the pesticide is leaking or has been
j              spilled, and precautions to minimize exposure if damage occurs.
i
*          5.  General precautions concerning locked storage, storage in
•              original container only, and separation of pesticides
i              during storage to prevent cross-contamination of other
*              pesticides, fertilizer, food, and feed.

I          6.  General storage instructions for household products should          v-
1              emphasize storage in original container and placement in
f              locked storage areas.
i
,          B.  Pesticide Disposal Instructions;

          The label of all products, except those intended solely for
I          domestic use, must bear explicit instructions about pesticide
I          disposal.  The statements listed below contain the exact wording
J.          that must appear on the label of these products:

j          1.  The labels of all products, except domestic use, must
f              contain the statement, "Do not contaminate water, food,
£              or feed by storage or disposal."

          2.  Except those products intended solely for domestic use,
              the labels of all products that contain active ingredients
              appearing on the "Acutely Hazardous" Commercial Pesticide
              Products List (RCRA "E" List) at the end of this appendix
              or are assigned to Toxicity Category I on the basis of
              oral or dermal toxicity, skin or eye irritation potential,
              or Toxicity Category I or II on the basis of acute inhala-
              tion toxicity must bear the following pesticide 'disposal
              statement:

              •Pesticide wastes are acutely hazardous.  Improper dis-
              posal of excess pesticide, spray mixture, or rinsate is
              a violation of Federal Law.  If these wastes cannot be
              disposed of by use according to label instructions,
              contact your State Pesticide or Environmental Control
              Agency, or the Hazardous Waste representative at the
              nearest EPA Regional Office for guidance.*

              The labels of all products, except those intended for
              domestic use, containing active or inert ingredients
              that appear on the "Toxic" Commercial Pesticide Products
              List (RCRA "F" List) at the end of this appendix or
              presently meet any of the criteria in Subpart C, 40 CFR
              261 for a hazardous waste must bear the following pesticide
              disposal statement:

-------
                                                 Appendix IV-5
                                                 (continued)

    "Pesticide wastes are toxic.  Improper disposal of excess
    pesticide, spray mixture, or rinsate is a violation of
    Federal Law.  If these wastes cannot be disposed of by
    use according to label instructions, contact your State
    Pesticide or Environmental Control Agency, or the Hazardous
    Waste representative at the nearest EPA Regional Office
    for guidance."

    Labels for all other products, except those intended for
    domestic use, must bear the following pesticide disposal
    statement:

    "Wastes resulting from the use of this product may be
    disposed of on site or at an approved waste disposal
    facility."

3.  Products intended for domestic use only must bear the
    following disposal statement:  "Securely wrap original
    container in several layers of newspaper and discard in
    trash."

C.  Container Disposal Instructions

    The label of each product must bear container disposal
    instructions appropriate to the type of container.

  ,  1.  All products intended for domestic use must bear one
        of the following container disposal statements:
Container Type
                Statement
Non-aerosol products
(bottles, cans, jars)
Non-aerosol products
(bags)
Aerosol products
Do not reuse container (bottle, can, jar).
Rinse thoroughly before discarding in trash.
Do not reuse bag. Discard bag in trash.
Replace cap and discard containers in
trash. Do not incinerate or puncture.
    2.  The labels for all other products must bear container disposal
        instructions, based on container type, listed below:
 Container Type
                 Statement
 Metal
 containers
 (non-aerosol)
Triple rinse (or equivalent).  Then offer
for recycling or reconditioning, or puncture
and dispose of in a sanitary landfill, or by
other procedures approved by state and local
authorities.
 Plastic containers
Triple rinse (or equivalent).  Then offer
for recycling or reconditioning, or puncture
and dispose of in a sanitary landfill, or
incineration, or, if allowed by state and
local authorities, by burning.  If burned,
stay out of smoke.	
 Glass containers
Triple rinse (or equivalent).  Then dispose
of in a sanitary landfill or by other
approved state and local procedures.	

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Container Type
                                                Appendix IV-5
                                                (continued)
Statement
Fiber drums
with liners
Paper and
plastic bags
Compressed gas
cylinders
Completely empty liner by shaking and
tapping sides and bottom to loosen clinging
particles. Empty residue into application
equipment. Then dispose of liner in a
sanitary landfill or by incineration if
allowed by state and local authorities.
If drum is contaminated and cannot be
reused1, dispose of in the same manner.
Completely empty bag into application
equipment. Then dispose of empty bag in
a sanitary landfill- or by incineration,
or, if allowed by State and local
authorities, by burning. If burned, stay
out of smoke.
Return empty cylinder for reuse {or
similar wording).
    ^Manufacturer may replace this phrase with one indicating whether
    and how fiber drum may be reused.

  2. The labels for all other products must bear container
     disposal instructions, based on container type, listed
     on the first page of this Appendix.

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                                                 Appendix IV-5
                                                 (continued)
Pesticides that are hazardous wastes under 40 CFR 261.33(e) and (£)
when discarded.

                                                          List)
      "Acutely Hazardous* Commercial Pesticides (RCRA *E'	
                   Active Ingredients/ (no inerts);~~

Acrolein
Aldicarb
Aldrin
Allyl alcohol
Aluminum phosphide
4-Aminopyridine
Arsenic acid
Arsenic pentoxide
Arsenic trioxide
Calcium cyanide
Carbon disulfide
p-Chloroaniline
Cyanides (soluble cyanide salts, not specified elsewere)
Cyanogen chloride
2-Cyclohexyl-4,6-dinitrophenol
Dieldrin
0,0-Diethyl S-[2-ethylthio)ethyl] phosphorodithioate
      (disulfoton, Di-Syston)
0,0-Diethyl 0-pyrazinyl phosphorothioate (Zinophos)
Dimethoate
0,0-Dimethyl 0-p-nitrophenyl phosphorothioate (methyl parathion)
4,6-Dinitro-o-cresol and salts
4,6-Dinitro-o-cyclohexylphenol
2,4 Dinitrophenol
Dinoseb
Endosulfan
Endothall
Endrin
Famphur
Fluoroacetamide
Heptachlor
Hexanethyl tetraphosphate
Hydrocyanic acid
Hydrogen cyanide
Nethomy1
alpha-Naphthylthiourea (ANTU)
Nicotine and salts
OctamethyIpyrophosphoramide (OMPA, schradan)
Parathion

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                                                 Appendix IV-5
                                                 (continued)
      "Acutely Hazardous* Commercial Pesticides (RCRA "E" List)
                    Active Ingredients continued:

Phenylmercuric acetate (PNA)
Phorate
Potassium cyanide
Propargyl alcohol
Sodium azide
Sodium cyanide
Sodium fluoroacetate
Strychnine and salts
0,0,0,0-Tetraethyl dithiopyrophosphate
Tetraethyl pyrophosphate
Thallium sulfate
Thiofanox
Toxaphene
Warfarin
Zinc phosphide
(sulfotepp)
There are currently no inert ingredients for commercial pesticides
on the "Acutely Hazardous" List (RCRA "E" List).

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                                                 Appendix IV-5
                                                 (continued)
        •Toxic" Commercial Pesticide Products (RCRA "F" List)
                         Active Ingredients•

Acetone
Acrylonitrile
Amitrole
Benzene
Bis(2-ethylhexyl)pthalate
Cacodylic acid
Carbon tetrachloride
Chloral (hydrate)
Chlordane (technical)
Chlorobenzene
4-Chloro-m-cresol
Chloroform
o-Chlorophenol
4-Chloro-o-toluidine hydrochloride
Creosote
Cresylic acid
Cyclohexane
Decachlorooctahydro-1,3,4-metheno-2H-cyclobuta[c,d)-pentalen-2-one
    (kepone, chlordecone)
1t2-Dibromo-3-chloropropane (DBCP)
Dibutyl phthalate
S-3,3-(Dichloroallyl diisopropylthiocarbamate (diallate, Avadex)
o-Dichlorobenzene
p-DiChlorobenzene
Dichlorodifluoromethane  (Freon 12*)
3,5-Dichloro-N-(1,1-d imethyl-2-propynyl) benzamide  (pronamide,Kerb)
Oichloro diphenyl dichloroethane (DDD)
Dichloro diphenyl trichloroethane (DDT)
Dichlorethyl ether
2,4-Dichlorophenoxyacetic, esters and salts  (2,4-D)
1,2-Dichloropropane
1,3-Dichloropropane (Telone)
Dimethyl phthalate
Ethyl acetate
Ethyl 4,4'-dichlorobenzilate (chlorobenzilate)
Ethylene dibromide (EDB)
Ethylene dichloride
Ethylene oxide
Formaldehyde
Furfural
Hexachlorobenzene
Hexachlorocyclopentadiene
Hexachloroethane
Hydrofluoric acid

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                                        Appendix IV-5
                                        (continued)
'Toxic*  Commercial Pesticide Products
                Active Ingredients;
                                                (RCRA *P" List)
 Isobutyl  alcohol
 Lead acetate
 Lindane
 Maleic hydrazide
 Mercury
 Methyl alcohol
 Methyl bromide
 Methyl chloride
 2,2'-Methylenebis  {3,4,6-trichlorophenol)   (hexachlorophene)
 Methylene chloride
 Methyl ethyl ketone
 4-Methyl-2-pentanone  (methyl isobutyl ketone)
 Naphthalene
 Nitrobenzene
 p-Nitrophenol
 Pentachloroethane
 Pentachloronitrobenzene   (PCNB)
 Pentaclorophenol
 Phenol
 Phosphorodithioic acid,
 Propylene dichloride
 Pyridine
 Resorcinol
 Safrole
 Selenium  disulfide
 Silvex
 1,2,4,5-Tetrachlorobenzene
 1,1,2,2-Tetrachloroethane
Tetrachloroethylene
 2,3f4,6-Tetrachlorophenol
Thiram
Toluene
 1,1,1-Trichloroethane
Trichloroethylene
Trichloromonofluoromethane  (Preon 11*)
2,4,5-Trichlorophenol
2,4,6-Trichlorophenol
2,4,5-Triehlorophenoxyacetic acid  (2,4,5-T)
Xylene
               0,0-diethyl, methyl ester

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                                                           Appendix IV-5
                                                           (continued)
             'Toxic" Commercial Pesticide Products (RCRA "F" List)
             Inert Ingredients;
I
•
I
Acetone
Acetonitrile
Ace toph e none
Acrylic acid
Aniline
Benzene
Chlorobenzene
Chloroform
Cyclohexane
Cyclohexanone
Dichlorodifluoromethane (Freon 12*)
Diethyl phthalate
Dimethylamine
Dimethyl phthalate
1,4-Dioxane
Ethylene oxide
Formaldehyde
Formic acid
Isobutyl alcohol
Meleic anhydride
Methyl alcohol (methanol)
Methyl ethyl ketone
Methyl methacrylate
Naphthalene
Saccharin and salts
Thiourea
Toluene
1,1,1-Trichloroethane
1,1,2-Trichloroethane
Trichlorofluoromethane (Freon 11 )
Vinyl chloride
Xylene

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            UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

                        WASHINGTON, O.C. 20460
                                                          OFFICE OF
                                                  PUTICIDCK AND TOXIC SUMTANCBS
CERTIFIED MAIL
SUBJECT:  Initiation of Reregistration Process for Pesticide
          Products Containing Formetanate Rydrochloride as
          the Single Active Ingredient

Dear Registrant:

     In accordance with the Federal Insecticide, Fungicide,
and Rodenticide Act (FIFRA), as amended, EPA's Office of
Pesticide Programs has begun the reregistration process for
pesticide products containing the subject ingredient.  Signifi-
cant changes to the statute were made in 1972, 1975, and
1978; thus, current requirements may be substantially different
from those in effect at the time your product(s) were registered,
The first phase of reregistration requires that you  (1) make
a commitment to the Agency regarding data development and
(2) subsequently submit revised product labeling arid associated
information.

     This mailing contains the Guidance Document for prepara-
tion of submissions, as well as a listing of your affected
product(s) (Attachment A), and a separate list of registrants
with products subject to this standard and which contain
this active ingredient (Attachment B).  The latter list is
for the purpose of cooperative data development.

     The Guidance Document sets out the Agency's evaluation
of all available data pertaining to the subject chemical and
its registered uses, and its rationale for the regulatory
actions being taken at this time.  Additionally, the Guidance
Document contains instructions describing certain of the

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           steps you must take to maintain registration for your product(s).
           Products not brought into compliance with the Guidance Document
           as supplemented by subsequent information from EPA about compliance
           with certain data support requirements will be subject to suspension
           and/or cancellation.
                Specifically,
           following:
                   the enclosed Guidance Document does the
I-
r-
     1.   Introduces the purpose of this document.

     2.   Explains the Agency's policy regarding data submis-
          sion and identifies, in table format, the data
          that must be submitted to complete the Agency's
          evaluation of each product.  In addition, a
          bibliography identifying the data which is considered
          part of the data base supporting the registration
          standard is included.

     3.   Sets out time-frames for submission of required
          data.

     4.   Explains how to revise labeling for maufacturing use
          products.  (As the Guidance Document explains,
          labeling is not required at this time.)

     5.   Provides submission instructions.

     Because of the variety and complexity of the requirements,
and the short statutory time-frames available for certain
actions, it is essential that you understand the specific require-
ments and procedures in order that you may respond in a correct
and timely manner.  Since a part of these requirements is under
Section 3{c)(2)(B) of FIPRA, your first response may be required
within 90 days from receipt of this letter.  Please note that
if you do not respond or do not comply fully with the requirements,
your application may be rejected or your product registration
cancelled or suspended^

     If, after reviewing this material, you do not understand
what you must do or how or when you must respond, please contact
the Product Manager listed below who will assist you in every
reasonable way.  If you wish to discuss the data requirements
or request that certain data be waived, you must write to the
Agency and indicate those data requirements with which you take
issue and your rationale for doing so.  After the Agency has
had a chance to review your submission, the Product Manager will
contact you to set up a meeting for the purpose of resolving all
issues relative to data requirements.

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     Please note that this guidance document will eventually
be supplemented by EPA with additional information about
compliance with data support requirements.  In Monsanto v_,
Adm in is trator, EPA was recently enjoined by the District
Court for the Eastern District of Missouri from implementing
in any way the "mandatory data licensing" aspects of S3(c)(l)(D)
of FIFRA.  EPA is assessing the implications of the injunction
for the reregistration process.  Because of this unresolved
situation, EPA has decided to proceed with the requirements in
this guidance package which do not relate to the "data licensing1*
issue and to supplement the package with -additional guidance
when circumstances permit.

     If you have any questions concerning this Guidance Document,
you may contact the Product Manager listed below:
Product Manager 12
Registration Division  (TS-767)
Office of Pesticide Programs
Environmental Protection Agency
Washington, D.C.  20460
                                 Sincerely,
                                 Douglas D. Campt, Director
                                 Registration Division (TS-767)
Enclosure

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                                                    ATTACHMENT A

                    PRODUCTS AFFECTED BY THIS
                      REREGISTRATION PROCESS .
                                                    *
Following is a list of your products affected by this rereg-
istration process.  If this list is incomplete or inaccurate
in any way, please notify the Product Manager (PM) identified
in the letter.
Product Name

Carzol SP

Formetanate Rydrochloride
EPA Reg. No,

2139-99

2139-114

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                                                ATTACHMENT B
        REGISTRANTS WITH PESTICIDE PRODUCTS CONTAINING
                    THE ACTIVE INGREDIENT
The information attached will allow registrants with pesticide
products containing the above ingredient to contact one
another regarding joint data development or sharing the cost
of data development under section 3(c)(2)(B) of FIFRA.  This
information includes the following:  EPA Reg. No., company
name, company address, active ingredient, percentage of active
ingredient and type of formulation, such as Manufacturing-Use
Product (MUP), Technical Product (TP), Wettable Powder (WP),
and Emulsifiable Concentrate (EC).
EPA Reg. No.

2139-99
2139-114
Co. Name and Address

Nor-Am Agricultural
Products, Inc.
350 West Shuman Blvd.
Naperville, IL  60566

        -do-
Active
Ingredient

  92%
Formulation
Type	

 WP
  92%
 MUP

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