I
                            REREGISTRATION ELIGIBILITY DOCUMENT
                                      ALLIUM SATIVUM
                                          (GARLIC)
                                          LIST D

                                         CASE 400?
                                         JUNE 1992
                              ENVIRONMENTAL PROTECTION AGENCY
                               OFFICE OF PESTICIDE PROGRAMS
                        SPECIAL REVIEW AND REREGISTRATION DIVISION
                                     WASHINGTON, D.C.

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ALLIUM SATIVUM (GARLIC) REREGISTRATION ELIGIBILITY TEAM
Office of Pesticide Programs:
Biological
Steve Jarboe
Paul Guillebeau
G, All
and Economic Analysis Branch
         Biological Analysis Branch
         Biological Analysis Branch
         Economic Analysis Branch
Environmental Fate and Effects Division
Regina Hirsh
Les Touart
Heather Mansfield
David Bays
Harold Day
Bernice Slutsky

Health Effects Division
Tom McClintock
Jim Yowell
              Ecological Effects Branch
              Ecological Effects Branch
              Ecological Effects Branch
              Ecological Effects Branch
              Environmental Fate and Ground Water
              Science Analysis and Coordination Staff
              Science Analysis and Coordination Branch
Program Management and Support  Division
                         Information Services Branch
Registration Division
Pat Critchlow
Dan Peacock
Sarai Malak
Mary Waller
              Registration Support Branch
              Insecticide-Rodenticide Branch
              Registration Support Branch
              Registration Support Branch
Special Review andReregistratipn Division
Bruce Sidwell            Accelerated Reregistration Branch
Margarita Collantes      Accelerated Reregistration Branch

Policy and Special Projects Staff
Kennan Garvey

Office of General counsel:
Alan Carpien

Office of Compliance Monitoring:
Beverly Updike

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                        TABLE OF CONTENTS


                                                            PAGE

GLOSSARY OF TERMS AND ABBREVIATIONS                             i

EXECUTIVE SUMMARY                                               ii


I,   INTRODUCTION                                               1

II.  ACTIVE INGREDIENTS COVERED BY THE REREGISTRATION DECISION  2
     DOCUMENT

     A.   IDENTIFICATION OF ACTIVE INGREDIENT                   2

     B.   USE PROFILE                                           2

     C.   REGULATORY HISTORY                                    4

III. AGENCY ASSESSMENT OF ACTIVE                                4
       INGREDIENT

     A.   DESCRIPTION OF ACTIVE INGREDIENTS AND SUMMARY OF
          PRODUCT CHEMISTRY                                     4

     B.   ENVIRONMENTAL AND HUMAN HEALTH ASSESSMENT             5

IV.  REREGISTRATION DECISION FOR ALLIUM SATIVUM                 7

     A.   DETERMINATION OF ELIGIBILITY                          7

     B.   ADDITIONAL GENERIC DATA REQUIREMENTS                  7

     C.  TOLERANCE ASSESSMENT                                   8

     D.  LABELING REQUREMENTS FOR MANUFACTURING -               8
          USE PRODUCTS OF ALLIUM SATIVUM

V.   PRODUCT REREGISTRATION                                     8

     A.   DETERMINATION OF ELIGIBILITY                          8

     B.   PRODUCT-SPECIFIC DATA REQUIREMENTS                    8

     C.   LABELING REQUIREMENTS                                 8

VI.  APPENDICES

     A.   APPENDIX A - USE PATTERNS SUBJECT TO REREGISTRATION   10

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B.   APPENDIX B - GENERIC DATA REQUIREMENTS FOR
     REREGISTRATION OP ALLIUM SATIVUM (GARLIC) SUPPORTING
     REREGISTRATION                                       34

     1.   GUIDE TO APPENDIX B                             35

     2.   PRODUCT IDENTIFICATION  fALLIUM SATIVUM)         36

     3.   ECOLOGICAL EFFECTS fALLIUM SATIVUM)             37

     4.   TOXICOLOGY fALLIUM SATIVUM)                     37

     5.   ENVIRONMENTAL FATE fALLIUM SATIVUM)             37

     6.   RESIDUE CHEMISTRY fALLIUM SATIVUMJ              37

     7.   OCCUPATIONAL EXPOSURE (ALLIUM SATIVUM}          37

C.   APPENDIX C - BIBLIOGRAPHY

     1.   GUIDE TO APPENDIX C                             38

     2.   BIBLIOGRAPHIC CITATIONS                         42

D.   APPENDIX D - PR NOTICE   91-2                        43

E.   APPENDIX E - DATA CALL-IN                            46

     1.  ATTACHMENT A - CHEMICAL STATUS SHEET             60

     2.  ATTACHMENT B - PRODUCT SPECIFIC DATA CALL-IN     63
                        RESPONSE FORM

     3.  ATTACHMENT C - PRODUCT SPECIFIC REQUIREMENT      68
                        STATUS AND REGISTRANT'S RESPONSE
                        FORM

     4.  ATTACHMENT D - EPA GROUPING OF END-USE PRODUCTS  77
                        FOR MEETING DATA REQUIREMENTS FOR
                        REREGISTRATION

     5.  ATTACHMENT E - EPA ACCEPTANCE CRITERIA           80

     6.  ATTACHMENT F - LIST OF ALL REGISTRANTS SENT     103
                        THIS DATA CALL-IN NOTICE

     7.  ATTACHMENT G - COST SHARE AND                   104
                        DATA COMPENSATION FORMS

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i
                           GLOSSARY  OF TERMS  AND ABBREVIATIONS

            a.i.      Active  Ingredient

            Agency    U.S.  Environmental  Protection Agency

            CAS       Chemical  Abstracts  Service

            CFR       Code  of Federal Regulations

            CSF       Confidential Statement  of Formula

            EP        End-Use Product

            FIFRA     Federal Insecticide,  Fungicide,  and Rodenticide Act

            GRAS      Generally Recognized  As Safe

            MP        Manufacturing  Use Product

            MRID      Master  Record  Identification  (number).  EPA's  system of
                     recording and  tracking  studies  submitted  to the Agency.

            RED       Reregistration Eligibility Document

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Executive Summary

     The U.S. Environmental Protection Agency ("EPA" or "the
Agency") first registered a pesticide product containing Allium
sativum in 1983.  Currently, there are a total of four registered
products for this active ingredient.  Three of these products
also contain capsicum (red pepper) as an active ingredient.  All
currently registered products are repellents against birds and/or
insects.  The end- use products are either soluable concentrates
applied by aerial application or dust formulations applied
directly into furrows or by broadcast with ground applicators.
These products prevent pests from attacking and damaging seeds
and seedlings of vegetables, fruits, grains, ornamental plants
and shrubbery.

     Based on the results from the reregistration review, the EPA
has determined that the data base for Allium sativum is
sufficient to conduct a risk assessment.  All product
identity/chemistry data requirements have been satisfied.  All
applicable toxicology, residue chemistry, worker exposure,
ecological and environmental effect data requirements have been
waived for the subject compound.  The potential risks, if any, to
humans from both nondietary/dietary and occupational exposures
are considered negligible because of the long history of use by
humans as a food additive and or component.   The potenial risks
to the environment are considered negligible due to garlic's non-
toxic mode of action and non-persistence in the environment.

     Accordingly, EPA has determined that the registered uses of
Allium sativum are eligible for reregistration.  The decision to
reregister specific products will be made after appropriate
labeling are submitted and/or cited.  After reviewing these
labels the EPA will determine whether or not the conditions of
FIFRA 3(c)(5) have been met, that is, whether product labeling
are acceptable and their uses will not cause unreasonable adverse
effects to humans or the environment. If these conditions are
met, EPA will reregister the products. Those products which
contain other active ingredients will be eligible for
reregistration only when the other active ingredients are
determined to be eligible for reregistration.

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     INTRODUCTION
     In 1988, the Federal Insecticide, Fungicide, and
Rodenticide Act (FIFRA) was amended to  accelerate the
reregistration of products with active ingredients
registered prior to November 1, 1984.  The amended Act
provides a schedule for the reregistration process to be
completed in nine years.  There are five phases to the
reregistration process.  The first four phases of the
process focus on identification of data requirements to
support the reregistration of an active ingredient and the
generation and submission of data to fulfill the
requirements.  The fifth phase is a review by the U.S.
Environmental Protection Agency (referred to as "the
Agency") of all data submitted to support reregistration.

     Section 4(g)(2)(A) of FIFRA states that in Phase 5 "the
Administrator shall determine whether pesticides containing
such active ingredient are eligible for reregistration"
before calling in data on products, section 4(g)(2)(B),  and
either reregistering products or taking "other appropriate
regulatory action," under section 4(g)(2)(C) and (D). Thus,
reregistration involves a thorough review of the scientific
data base underlying a pesticide's registration.  The
purpose of the Agency's review is to reassess the potential
hazards arising from the currently registered uses of the
pesticide; to determine the need for additional data on
health and environmental effects; and to determine whether
the pesticide meets the "no unreasonable adverse effects"
criterion of FIFRA, section 3(c)(5).

     This document presents the Agency's decision regarding
the reregistration eligibility of the active ingredient
Allium sativum (garlic).  The document consists of five
sections.  Section I is this introduction.  Section II
describes Allium sativuro. its uses and regulatory history.
Section III discusses the human health and environmental
assessments based on the data available to the Agency.
Section IV discusses the reregistration decision for Allium
sativum and  Section V discusses product reregistration.
Additional details concerning the review of available data
are available on request.
     EPA's reviews of specific reports and information on the
     set of registered uses considered for EPA's analyses may
     be obtained from:   EPA,  Freedom of Information,  401  M
     St. S.W., Washington, D.C.  20460.

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I
            II.  ACTIVE INGREDIENTS COVERED BY THIS RER1GISTRATION
                 ELIGIBILITY DECISION DOCUMENT

                 A.   IDENTIFICATION OF ACTIVE INGREDIENT

                  1.  Chemical Name: Allium sativum (Garlic)

                      CAS Number: 8000-78-0

                      Office of Pesticide Programs Chemical Code Number:
                      128827

                      Empirical Formula: Not Applicable


                 B.   USE PROFILE

                      Type of Pesticide: biochemical pesticide, insect and
                      bird repellent

                      Pests Controlled: birds, mites and insects

                           Registered Use Groups: (See Appendix A for
                                                    detailed specific use
                                                    sites).

                           Terrestrial Food/Feed - vegetables, fruits, nuts
                                                    and grains

                           Terrestrial Non-food -  ornamental plants and
                                                    shrubs

                           Indoor Residential - ornamental plants


                      Formulation Types Registered:

                      BIRDS -
                      Dust:  12% ground red pepper (Capsicum  spp.)
                             5% ground garlic (Allium sativum)

                      IKSECTS -
                      Soluble concentrate/liquid:  36% red pepper extract
                                                   24% garlic extract
                      Soluble concentrate/liquid:  100% garlic water

                      Methods and Rates of Applications

                      Dusts are applied as a banded furrow
                      treatment at planting or applied broadcast to

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foliage and fruit of plants.  Product may be
applied aerially or by ground equipment.
There is no maximum rate on the label; a
minimum rate is 20 to 50 Ibs formulated
material per acre (A).  For seedlings,
maturing produce and grains, the product is
applied at a minimum rate of 30 Ibs/A at 7 to
9 days before harvest.

Soluble concentrates are applied broadcast to
foliage by air or ground equipment.  There is
no maximum rate for the 24% garlic: 36%
capsaicin product.

100% garlic water product is applied up to 2 times per
season at one gallon/A.

Use practice limitations:  Application at bloom may
repel pollinators.

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i
                 C.    REGULATORY  HISTORY

                           The Agency  first registered a  product (EPA Reg.
                      No.  47319-1)  with garlic,  on December 29,  1983,  to the
                      Sevana  Company of Fresno,  California.   This product is
                      used in combination  with ground red peppers (Active
                      Ingredient  Code  070701;  Case Name;  Capsaicin;
                      Reregistration Case  No.  4018).   The mode of action is
                      that of a bird repellent.    On  July 2,  1985, the Agency
                      registered  a  similar second bird repellent product (EPA
                      Reg.  No.  47319-2) to the Sevana Company.

                           The Agency  registered a third  repellent product to
                      Sevana  (EPA Reg. No.  47319-4) on November 4, 1988.
                      This product  also contains a combination of garlic and
                      red  pepper, however,  it  is an insect repellent,  rather
                      than bird,  repellent and is a liquid formulation.

                           The most recent product was registered by the
                      Agency  on February 7,  1991 to the Guardian Spray
                      Company of  Lebec, California.   This product contains a
                      single  active ingredient,  garlic, and is a liquid
                      formulation.


                           Until  recently,  Allium sativum was classified by
                      the  Agency  as a  conventional chemical pesticide.   Since
                      these four  formulations  consist of  a food additive
                      and/or  component and cleared inert  ingredients,  the
                      Agency  only required minimal basic  product and chemical
                      identity data.   Now  the  Agency  has  reclassified the
                      subject compound as  a biochemical pesticide because it
                      is a naturally occurring biological substance  and has a
                      non-toxic mode of action.

            III.  AGENCY ASSESSMENT  OF  THE  ACTIVE INGREDIENT

                      EPA  has reviewed the scientific data base for  Allium
                 sativum,  primarily relying on information from published
                 literature submitted  by the registrant.   These are  cited in
                 Appendix  C.

                 A.    DESCRIPTION OF ACTIVE INGREDIENT AND SUMMARY OF PRODUCT
                      CHEMISTRY

                           Garlic,  as  a pesticide active  ingredient,
                      consists of either a powder or  a distilled extract
                      from the fresh or dehydrated bulb or cloves
                      obtained from Allium sativum.   Natural derivatives
                      of garlic include essential oils, oleoresins,  and
                      extracts.  One such  derivative  is finely ground
                      garlic  bulbs  (known  as garlic powder).

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I
                           When fresh garlic cloves are extracted
                      and distilled, a range of color from a light
                      orange to amber liquid color is observed.
                      Fresh garlic has an extremely pungent and
                      highly concentrated aroma and flavor.  Garlic
                      is dispersible in water (polar carriers)  and
                      oil (non-polar carriers) with agitation.

                 B.   ENVIRONMENTAL AND HUMAN HEALTH ASSESSMENT

                           EPA has developed a normative set of data
                      requirements, set forth in the regulations (40 CFR Fart
                      158) and the Agency's Reregistration Phase 2 Technical
                      Guidance Document to be addressed for pesticide
                      reregistration.  These regulations and the guidance
                      document specify the necessary data based on factors
                      including use sites, potential environmental and human
                      (dietary and occupational) exposures, product
                      formulation types, and product application methods.
                      Due to the diverse nature and characteristics of
                      pesticide products and their uses subject to
                      reregistration, the Agency also recognizes the
                      necessity to modify the data requirements for specific
                      pesticides, including waiving certain data requirements
                      because such requirements are inappropriate or
                      unnecessary for reregistration.

                           The case-specific approach to waive individual
                      data requirements has served to identify the
                      appropriate data requirement sets for pesticide
                      products.  Further, the Agency believes there is a
                      category of pesticide active ingredients for which a
                      broadly reduced set of data requirements are
                      appropriate for reregistration.  Specifically, products
                      in this category would be exempt from the generic data
                      requirements for toxicology, residue chemistry, human
                      exposure, ecological effects, and environmental fate on
                      the active ingredient.  The Agency believes there are
                      considerations which, when taken together, can form the
                      basis for a conclusion that such a reduction in data
                      requirements is appropriate for a particular pesticide
                      active ingredient, while not compromising human health
                      or environmental safety.

                           There are, however, certain data requirements
                      which are essential and not likely to be waived.  Basic
                      product identity/chemistry information on the active
                      ingredient and formulated products is required for
                      pesticides in this category so that the Agency has
                      reasonable certainty of the pesticide's identity and
                      chemical and physical characteristics.  Also, acute
                      toxicology studies for formulated and manufacturing-use

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products are required for the Agency to determine
appropriate product labeling for potential hazards to
those who handle or apply such products.  However,
these toxicology studies may be waived if an assessment
of the product formulation, including the inert
ingredients, indicates that such studies are
unnecessary to prescribe appropriate labeling.

     In considering garlic for reregistration
eligibility the Agency believes it is an active
ingredient that should be considered for this broad
waiver of the generic data reguirements.  The
considerations that lead the Agency to this conclusion
are as follows.

     Garlic is widely distributed and commercially
available for flavoring and seasoning throughout the
United States for nonpesticidal uses.  Garlic is
generally recognized as safe (GRAS) under 21 CFR 182.10
(spices and other natural seasonings and flavorings)
and 182.20  (ssential oils, oleoresins [solvent-free]
and natural extractives [including distillates]) as
affirmed in 184.1317 ([garlic and its derivatives]).

     Garlic is formulated as either a powder or a
distilled extract from garlic cloves and is used to
repel birds and insects in certain fruit, nut, and
citrus trees, vegetables, vine crops, berries, grains,
roses, flowers, and shrubs.  This active ingredient has
a non-toxic mode of action for target pests.  Moreover,
garlic can be presumed to be non-persistent based on
knowledge of its composition; e.g., organic material
known to be rapidly degraded in the environment to
elemental constituents by normal biological, physical,
and/or chemical processes that can be reasonably
expected to exist where the pesticide is applied.
     No reports of adverse effects have been submitted
to the Agency for this active ingredient and EPA has
not identified any indication of significant adverse
effects from garlic to humans or the environment
associated with its use as a pesticide.  This includes
consideration of information in the literature, or in
any incident reports by the registrant or the public.

     Based on these factors the Agency does not believe
generic data, beyond those data required to satisfy
basic product identity and chemistry questions (refer
to Appendix B), are necessary to determine whether the
current registered uses of this active ingredient pose
unreasonable risks to humans or the environment.

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i
                      Therefore, the Agency has waived all generic data
                      requirements except basic product identity and
                      chemistry data.  The Agency believes that, based on the
                      above factors, the registered uses of garlic do not
                      pose unreasonable risks to humans or the environment.
            IV.  REREGISTRATION DECISION FOR ALLIUM SATIVPM

                 A.   DETERMINATION OF ELIGIBILITY

                      Section 4(g)(2)(A) of FIFRA requires the Agency to
                 determine, after consideration of relevant data concerning
                 an active ingredient whether products containing the active
                 ingredient are eligible for reregistration.  For products
                 containing garlic as an active ingredient the Agency has
                 waived all generic data requirements except for certain
                 basic product identity and chemistry.  In addition to these
                 data the Agency has considered the factors discussed above
                 in Section III regarding the natural occurrence of garlic,
                 common use as a food item, and the lack of reported adverse
                 effects information.  The Agency has completed its
                 consideration of these data and other factors and has
                 determined this information is sufficient to support
                 reregistration of products containing garlic as an active
                 ingredient.  The reregistration of particular products is
                 addressed in Section V. of this document.

                      Although the Agency has concluded that products
                 containing garlic are eligible for reregistration, the
                 Agency may take regulatory actions in the future that would
                 affect the continued registration of garlic-containing
                 products if new and/or significant information about this
                 active ingredient and/or its products comes to the Agency's
                 attention.  Such regulatory action could include requiring
                 the submission of additional data if the data requirements
                 for registration (or the guidelines for generating such
                 data) change.


                 B.   ADDITIONAL GENERIC DATA REQUIREMENTS

                      The generic data base supporting the reregistration of
                 products containing Allium sativum and the registered use
                 patterns, has been reviewed and determined to be
                 substantially complete for reregistration.

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i
                 C.  TOLERANCE ASSESSMENT

                      End-use products are registered for application to a
                 variety of food crops however, no finite residues for
                 tolerance or exemption from tolerances have been established
                 in 40 CFR Part 180.  As discussed above in Section III, the
                 Agency does not believe any dietary exposure to residues on
                 crop commodities from the application of these products
                 would present a health concern and as such has waived
                 toxicology and residue chemistry data requirements on the
                 active ingredient.  However, to meet tolerance requirements
                 in the regulations, the Agency will propose a tolerance
                 exemption for Allium sativum under 40 CFR Part 180 for all
                 currently registered uses on food/feed crops.
                 D.  LABELLING REQUIREMENTS FOR MANUFACTURING-USE PRODUCTS OF
                      ALLIUM SATI¥UM

                      No manufacturing-use products are registered.
                 V.   PRODUCT REREGISTRATION

                      A.   DETERMINATION OF ELIGIBILITY

                           Based on the reviews of the generic data for the
                      active ingredient, Allium sativum. the products
                      containing them are eligible for reregistration.
                      Section 4(g)(2)(B) of FIFRA calls for the Agency to
                      obtain any needed product-specific data regarding the
                      pesticide after a determination of eligibility has been
                      made.  The Agency will review these data when they have
                      been submitted and/or cited and determine whether to
                      reregister individual products.


                      B.   PRODUCT SPECIFIC DATA REQUIREMENTS

                           The product-specific data requirements are listed
                      in Appendix D, Attachment D.  These requirements
                      include product chemistry, acute toxicology, and
                      efficacy studies.
                      C.   LABELING REQUIREMENTS FOR END-USE PRODUCTS
                           CONTAINING ALLIUM SATIVUM

                           The labels and labeling of all products must
                      comply with EPA's current regulations and requirements,
                      Follow the instructions in the Product Reregistration

                                            8

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Handbook with respect to labels and labeling.

     Based on the lack of toxicological concerns the
Agency has no product precautionary labeling concerns
at this time.

     However, certain products lack directions for
application of maximum rates.  In reponse to this RED,
registrants must submit draft amended product labels in
which minimum and maximum application rates are
proposed.  The Agency will evaluate these proposals and
determine where each label is satisfactory.

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              APPENDIX A

USE PATTERNS SUBJECT TO REREGISTRATION
                  FOR
        ALLIUM  SATIVUM (GARLIC)
                  10

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APPENDIX A- Case 4007, [Allium sativum] Chemical 128827 [Allium sativum]
SITE Application Type, Application Timing, Application
Equipment
r

Form

FOOD/FEED USES
Minimum
Application Rate

Maximum
Application flala

Max.*
Apps,

Max.*
Apps.
@
Max.
Rate

Mln. Interval
Between Apps.
@ Max, Rate
(Days)

Restricted
Entry
Interval
(Days)

Geographic
Limitations
Mowed

Disallowed

Use Limitations


Almond Use Groups: Terrestrial Food Crop and Terrestrial Feed Crop
Low volume spray (concentrate), Foliar, Aircraft
Low volume spray (concentrate), Foliar, Low
volume ground
SC/L
SC/L
na
na
.625 Ib ai/A 2 per
Cycle
,825 ib ai/A 2 per
I Cycle
not
spec
not
spec
not spec
not spec
not spec
not spec






Apple Use Groups: Terrestrial Food Crop and Terrestrial Feed Crop
Broadcast, Foliar, Aircraft
Broadcast, Foliar, Ground
Low volume spray (concentrate), Foliar, Aircraft
Low volume spray (concentrate), Foliar, Low
volume ground
Spray, Foliar, Aircraft
Spray, Petal fall, Aircraft
Spray, Foliar, Ground
Spray, Petal fall, Ground
D
D
SC/L
SC/L
SC/L
SC/L
SC/L
SC/L
2,5 Ib Al per A
2,5 ib Al per A
na
na
na
na
na
na
not spec
not spec
.825 Ib Al per
A
.825 Ib Al per
A
Dose cannot
be calculated
Dose cannot
be calculated
Oose cannot
be calculated
Dose cannot
be calculated
not
spec
not
spec
2 per
Cycle
2 per
Cycle
not
spec
not
spec
not
spec
not
spec
not
spec
not
spec
not
spec
not
spec
not
spec
not
spec
not
spec
not
spec
7
7
not spec
not spec
7
7
7
7
not spec
not spec
not spec
not spec
not spec
not spec
not spec
not spec
















7 days
preharvest
interval.
7 days
preharvest
Interval.


15 days
preharvest
interval.
15 days
preharvest
interval.
15 days
preharvest
interval.
15 day s
preharvest
interval.

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APPENDIX A- Case 4007, [Alllum satlvum] Chemical 128827 [Allium satfvum]
SITE Application Type, Application Timing, Application
Ectulpmerrt
Apricot Use Group: Terrestrial Food Crop
Broadcast, Foliar, Aircraft
Broadcast, Foliar, Ground
Low volume spray (concentrate), Foliar, Aircraft
Low volume spray (concentrate), Foliar, Low
volume ground
Spray, Foliar, Aircraft
Spray, Petal fall, Aircraft
Spray, Foliar, Ground
Spray, Petal fall, Ground
Form

D
D
SC/L
SC/L
SC/L
SC/L
SC/L
SC/L
Minimum
Application Rate

2,5lbAlperA
2.5 Ib Al per A
na
na
na
na
na
na
Maximum
Application Bate

not spec
not spec
.825 Ib Al per
A
.825 Ib Al per
A
Dose cannot
be calculated
Dose cannot
be calculated
Dose cannot
be calculated
Dose cannot
be calculated
Mat*
Apps.

not
spec
not
spec
2 per
Cycle
2 per
Cycle
not
spec
not
spec
not
spec
not
spec
Max.*
Apps.
©
Max.
Rate

not
spec
not
spec
not
spec
not
spec
not
spec
not
spec
not
spec
not
spec
Mln. Interval
Between Apps.
© Max. Rate
(Days)

7
7
not spec
not spec
7
7
7
7
Restricted
Entry
Interval
(Days)

not spec
not spec
not spec
not spec
not spec
not spec
not spec
not spec
Geographic
limitations
Allowed









Disallowed









Use Limitations

7 days
preharvest
Interval,
7 days
preharvest
interval.


15 days
preharvest
interval.
15 days
preharvest
Interval.
15 days
preharvest
interval.
15 days
preharvest
interval.
Beans Use Groups: Terrestrial Food Crop and Terrestrial Feed Crop
High volume spray (dilute), Foliar, Ground
Low volume spray (concentrate), Foliar, Aircraft
Low volume spray (concentrate), Prebloom,
Aircraft
SC/L
SC/L
SC/L
na
na
na
Dose cannot
be calculated
.825 Ib Al per
A
.825 Ib Al per
A
not
spec
2per
Cycle
2 per
Cycle
not
spec
not
spec
not
spec
As needed
not spec
not spec
not spec
not spec
not spec






15 days
preharvest
interval.



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APPENDIX A- Case 4007, [Allium sativum] Chemical 128827 [Allium sativum]
SITE Application Type, Application Timing, Application
Equipment
Low volume spray (concentrate), Foliar, Low
volume ground
Low volume spray (concentrate), Prebloom, Low
volume ground
Spray, Foliar, Aircraft
Spray, Seedling, Aircraft
Spray, Seedling, Ground
Form
SC/L
SC/L
SC/L
SC/L
SC/L
Minimum
Application Rate
na
na
na
na
na
Maximum
Application Rate
.825 Ib Al per
A
.825 Ib Al per
A
Dose cannot
be calculated
Dose cannot
be calculated
Dose cannot
be calculated
Max, #
Apps.
2 per
Cycle
2 per
Cycle
not
spec
not
spec
not
spec
Max.*
Apps.
@
Max.
Rate
not
spec
not
spec
not
spec
not
spec
not
spec
Mln. Interval
Between Appe.
@ Max. Rate
(Days)
not spec
not spec
As needed
As needed
As needed
Restricted
Entry
Interval
Pays)
not spec
not spec
not spec
not spec
not spec
Geographic
Limitations
Allowed





Disallowed





Use limitations


15 days
preharvest
interval.
15 days
preharvest
interval.
15 days
preharvest
interval.
Beets (Unspecified) Use Groups: Terrestrial Food Crop and Terrestrial Feed Crop
Band treatment, At planting, Mechanical granule
applicator
Broadcast, Foliar, Aircraft
Broadcast, Seedling stage. Aircraft
Broadcast, Foliar, Ground
Broadcast, Seedling stage, Ground
Broadcast, Postemergence, Shaker can
Soil band treatment, At planting, Shaker can
D
D
D
D
D
D
D
1 Ib Al per A
1.5lbA!perA
1.5!bAlper A
1,5 Ib per A
1.5 to per A
na
na
not spec
not spec
not spec
not spec
not spec
Dose cannot
be calculated
Dose cannot
be calculated
not
spec
not
spec
not
spec
not
spec
not
spec
not
spec
not
spec
not
spec
not
spec
not
spec
not
spec
not
spec
not
spec
not
spec
not spec
7
7
7
7
not spec
not spec
not spec
not spec
not spec
not spec
not spec
not spec
not spec















7 days
preharvest
interval.
7 days
preharvest
interval.
7 days
preharvest
interval.
7 days
preharvest
interval.



-------
APPENDIX A- Case 4007, [Allium sativum] Chemical 128827 [Allium sativum]
SITE Application Type, Application Timing, Application
Equipment
Soil treatment, At planting, Shaker can
Form
0
Minimum
Application Rate
na
Maximum
Application Rate
Dose cannot
be calculated
Max.*
Apps.
not
spec
Max.*
Apps,
©
Max.
Rate
not
spec
Mln. Interval
Between Apps.
© Max, Rate
(Days)
not spec
Restricted
Entry
Interval
(Days)
not spec
Geographic
Limitations
Allowed

Disallowed

Use Limitations

Broccoli Use Group: Terrestrial Food Crop
High volume spray, Foliar, Ground
Spray, Folwr, Aircraft
Spray, Seedling stage, Aircraft
Spray, Seedling stage. Ground
Cabbage Use Group: Terrestrial Food Crop
Band treatment, At planting, Mechanical granule
applicator
Broadcast, Foliar, Aircraft
Broadcast, Seedling stage, Aircraft
Broadcast, Foliar, Ground
Broadcast, Seedling stage, Ground

SC/L
SC/L
SC/L
SC/L
na
na
na
na
Dose cannot
be calculated
Dose cannot
be calculated
Dose cannot
be calculated
Dose cannot
be calculated
not
spec
not
spec
not
spec
not
spec
not
spec
not
spec
not
spec
not
spec
As needed
As needed
As needed
As needed
not spec
not spec
not
spec
not spec








15 days
preharvest
Interval.
15 days
preharvest
Interval.
15 days
preharvest
interval.
15 days
preharvest
interval.

O
D
D
D
D

1 Ib Al per A
LSIbAlperA
1.5lbAlper A
LSIbAlperA
1 ,5 Ib Al per A

not spec
not spec
not spec
not spec
not spec

not
spec
not
spec
not
spec
not
spec
not
spec

not
spec
not
spec
not
spec
not
spec
not
spec

not spec
7
7
7
7

not spec
not spec
not spec
not spec
not spec














7 days
preharvest
Interval.
7days
preharvest
interval.
7 days
preharvest
interval.
7 days
preharvest
interval.


-------
APPENDIX A- Case 4007, [Allium sativum] Chemical 128827 [Alliutn sativum]
SITE Application Type, Application Timing. Application
Equipment
Broadcast, Postemergence, Shaker can
Low volume spray (concentrate), Foliar, Aircraft
Low volume spray (concentrate), Prebloom,
Aircraft
I ow volume spray (concentrate). Foliar, Low
volume ground
Low volume spray (concentrate), Prebloom, Low
volume ground
Soil band treatment, At planting, Shaker can
Soil treatment. At planting, Shaker can
Form
D
sen
SC/L
SC/L
SC/L
D
D
Minimum
Application Rate
na
na
na
na
na
na
na
Maximum
Application flats
Dose cannot
be calculated
.825 Ib Al per
A
.825 Ib Al per
A
.825 Ib Al per
A
.825 Ib Al per
A
Dose cannot
be calculated
Dose cannot
be calculated
Max. #
Apps.
not
spec
2 per
Cycle
2 per
Cycle
2 per
Cycle
2 per
Cycle
not
spec
not
spec
Max.*
Apps.
e
Max.
Rate
not
spec
not
spec
not
spec
not
spec
not
spec
not
spec
not
spec
Mln. Interval
Between Apps,
@ Max, Rate
(Days)
not spec
not spec
not spec
not spec
not spec
not spec
not spec
Restricted
Entry
Interval
(Days)
not spec
not spec
not spec
not spec
not spec
not spec
not spec
Carrot (including tops) Use Group: Terrestrial Food Crop
Band treatment, At planting, Mechanical granule
applicator
Broadcast, Foliar, Aircraft
Broadcast, Seedling stage, Aircraft
Broadcast, Foliar, Ground

Broadcast, Seedling stage. Ground
D
0
0
D

D
1 Ib Al per A
1.5!bAlperA
1.5lbAlperA
UlbAlperA

1 .5 Ib Al per A
not spec
not spec
not spec
not spec

not spec
not
spec
not
spec
not
spec
not
spec

not
spec
not
spec
not
spec
not
spec
not
spec

not
spec
not spec
7
7
7

7
not spec
not spec
not spec
not spec

not spec
Geographic
Limitations
Allowed







Disallowed







Use limitations





















7 days
preharvest
interval.
7 days
preharvest
interval.
7 days
preharvest
interval.

7 days
preahrvest
Interval.

-------
APPENDIX A - Case 4007, [Allium sativum] Chemical 128827 [Allium sativum]
SITE Application Type, Application Timing, Application
Equipment
Low volume spray (concentrate), Foliar, Aircraft
Low volume spray (concentrate), Prebloom,
Aircraft
Low volume spray (concentrate), Foliar, Low
volume ground
Low volume spray (concentrate), Prebloom, Low
volume ground
Form
SC/L
sen
sen
SC/L
Minimum
Application Rate
na
na
na
na
Maximum
Application Rate
.825 Ib Al per
A
.825 Ib Al per
A
.825 Ib Al per
A
.825 Ib Al per
A
Max. #
Apps.
2 per
Cycle
2 per
Cycle
2 per
Cycle
2 per
Cycle
Max*
Apps.
a
Max.
Rate
not
spec
not
spec
not
spec
not
spec
Mln. Interval
Between Apps.
@ Max, Bate
(Days)
not spec
not spec
not spec
not spec
Restricted
Entry
Interval
(Days)
not spec
not spec
not spec
not spec
Geographic
Limitations
Allowed




Disallowed




Us« Limitations




Cauliflower Use Group: Terrestrial Food Crop
High volume spray (dilute), Foliar, Ground
Spray, Foliar, Aircraft
Spray, Seedling stage, Aircraft
Spray, Seedling stage, Ground
SC/L
SC/L
SC/L
SC/L
na
na
na
na
Dose cannot
be calculated
Dose cannot
be calculated
Dose cannot
be calculated
Dose cannot
be calculated
not
spec
not
spec
not
spec
not
spec
not
spec
not
spec
not
spec
not
spec
As needed
As needed
As needed
As needed
not spec
not spec
not spec
not spec








15 days
preharvest
interval.
15 days
preharvest
interval.
15 days
preharvest
interval.
15 days
preharvest
interval.
Celery Use Group: Terrestrial Food Crop
High volume spray (dilute), Foliar, Ground
Spray, Foliar, Aircraft
Spray, Seedling stage, Aircraft
SC/L
SC/L
SC/L
na
na
na
Dose cannot
be calculated
Dose cannot
be calculated
Dose cannot
be calculated
not
spec
not
spec
not
spec
not
spec
not
spec
not
spec
As needed
As needed
As needed
not spec
not spec
not spec






15 days
preharvest
interval.
15 days
preharvest
interval.
15 days
preharvest
interval.

-------
APPENDIX A- Case 4007, [Allium sativum] Chemical 128827 [Allium sativum]
SITE Application Type, Application Timing, Application
Equipment
Spray, Seeding stage, Ground
Form
SC/L
Minimum
Application Rate
na
Maximum
Application Rate
Dose cannot
be calculated
Max. *
Apps.
not
spec
Man.*
Apps.
@
Max.
Rate
not
spec
Mln. Interval
Between Apps.
@ Wax. Rate
(Days)
As needed
Restricted
Entry
Interval
(Days)
not spec
QtograpNc
Limitations
Allowed

Disallowed

Use limitations
15 days
preharvest
interval.
Cherry Use Group; Terrestrial Food Crop
Broadcast, Foliar, Aircraft
Broadcast, Foliar, Ground
Broadcast, Foliar, Shaker can
Spray, Foliar, Aiorcraft
Spray, Petal 1st, Aircraft
Spray, Foliar, Ground
Spray, Petal (ad, Ground
D
0
D
SC/L
SC/L
SC/L
SC/L
2.5 Ib M per A
2,5 Ib Al per A
na
na
na
na
na
not spec
not spec
Dose cannot
be calculated
Dose cannot
be calculated
Dose cannot
be calculated
Dose cannot
be calculated
Dose cannot
be calculated
not
spec
not
spec
not
spec
not
spec
not
spec
not
spec
not
spec
not
spec
not
spec
not
spec
not
spec
not
spec
not
spec
not
spec
7
7
7
7
7
7
7
not spec
not spec
not spec
not spec
not spec
not spec
not spec














7 days
preharvest
Interval.
7 days
preharvest
interval.
2 days
preharvest
Interval.
15 days
preharvest
interval.
15 days
preharvest
Interval.
15 days
preharvest
interval.
15 days
preharvest
Interval,

Com (Unspecified] Use Groups: Terrestrial Food Crop and Terrestrial Feed Crop
Band treatment, At planting. Mechanical
granule applicator
D
1 Ib Al per A
not spec I not
|| spec
not
spec
not spec
not spec




-------
APPENDIX A- Case 4007, [AIMum sativum] Chemical 128827 [AlHum satlvum]
SITE Application Type, Application Timing, Application
Equipment
Broadcast, Foliar, Aircraft
Broadcast, Seedling stage, Aircraft
Broadcast, Foliar, Ground
Broadcast, Seedling stage, Ground
Broadcast, Shaker can, Postemer gence
Low volume spray (concentrate), Foliar, Aircraft
Low volume spray (concentrate), Prebloom,
Aircraft
Low volume spray (concentrate), Foliar, Low
volume ground
Low volume spray (concentrate), Prebloom, Low
volume ground
Soil band treatment, At planting, Shaker can
Soil treatment. At planting, Shaker can
Form
D
D
0
0
D
SC/L
SC/L
SC/L
SC/L
D
D
Minimum
Application Rate
1.5lbAlperA
1.5 Ib AlperA
1,5lbAlperA
1.5 Ib AlperA
na
na
na
na
na
na
na
Maximum
Application Rate
not spec
not spec
not spec
not spec
Dose cannot
be calculated
.825 Ib Al per
A
.825 Ib Al per
A
.825 Ib Al per
A
.825 to Al per
A
Dose cannot
be calculated
Dose cannot
be calculated
Max. *
AppS.
not
spec
not
spec
not
spec
not
spec
not
spec
2 per
Cycle
2 per
Cycle
2 per
Cycle
2 per
Cycle
not
spec
not
spec
Max.*
AppS.
«
Max.
Rate
not
spec
not
spec
not
spec
not
spec
not
spec
not
spec
not
spec
not
spec
not
spec
not
spec
not
spec
Mln. Interval
Between Apps.
@ Max. Rate
(Days)
7
7
7
7
not spec
not spec
not spec
not spec
not spec
not spec
not spec
Restricted
Entry
Interval
pays)
not spec
not spec
not spec
not spec
not spec
not spec
not spec
not spec
not spec
not spec
not spec
Geographic
Limitations
Allowed











Disallowed











Use Limitations
7 days
preharvest
interval.
7 days
preharvest
interval.
7 days
preharvest
Interval.
7 days
preharvest
interval.







Cucumber Use Group: Terrestrial Food Crop
Spray, Foliar, Aircraft
SC/L
na
Dose cannot
be calculated
not
spec
not
spec
As needed
not spec


15 days
preharvest
interval.

-------
APPENDIX A- Case 4007, [Allium sativum] Chemical 128827 [Allium sativum]
SITE Appllcalton Type, Application Timing, Application
Equipment
Spray, Seedling stage. Aircraft
Spray, Foliar, Ground
Spray, Seedling stage, Ground
Form
SC/L
SC/L
SC/L
Minimum
Application Rate
na
na
na
Maximum
Application Bate
Dose cannot
be calculated
Dose cannot
be calculated
Dose cannot
be calculated
Max. #
Apps.
not
spec
not
spec
not
spec
Max.*
Apps.
@
Max,
Rate
not
spec
not
spec
not
spec
Mln. Interval
Between Apps.
@ Max. Rate
(Days)
As needed
As needed
As needed
Restricted
Entry
Interval
(Days)
not spec
not spec
not spec
Geographic
Limitations
Allowed



Disallowed



Use Limitations
15 days
preharvest
interval.
15 days
preharvest
interval.
15 days
preharvest
interval.
Cereal Grains Use Groups; Terrestrial Food Crop and Terrestrial Feed Crop
Band treatment, At planting, Mechanical granule
applicator
Broadcast, Foliar, Aircraft
Broadcast, Seedling stage, Aircraft
Broadcast, Foliar, Ground
Broadcast, Seedling stage, Ground

D
D
D
D
D

1 IbAlperA
1,5 Ib AlperA
1.5 to Al per A
1.5 Ip AlperA
1.5 IbAlperA

not spec
not spec
not spec
not spec
not spec

not
spec
not
spec
not
spec
not
spec
not
spec

not
spec
not
spec
not
spec
not
spec
not
spec

not spec
7
7
7
7

not spec
not spec
not spec
not spec
not spec










V-
JU.


7 days
preharvest
interval.
7 days
preharvest
interval.
7 days
preharvest
interval.
7 days
preharvest
interval.
7 days
preharvest
interval.

Fig Use Group: Terrestrial Food Crop
Broadcast, Foliar, Aircraft
D
2.5 Ib Al per A
not spec
not
spec
not
spec
7
not spec


7 days
preharvest
interval.

-------
APPENDIX A- Case 4007, [Allium sativum] Chemical 128827 [Allium satlvum]
SITE Application Type. Application Timing, Application
Equipment
Broadcast, FoNar, Ground
Form
D
Minimum
Application Bate
2.S Ib A) per A
Maximum
Application Rate
not spec
Max. *
Apps.
not
spec
Max. #
Apps.
9
Max.
Rate
not
spec
Mln, Interval
Between Apps.
@ Max. Rate
(Days)
7
Restricted
Entry
Interval
(Days)
not spec
Geographic
Limitations
Allowed

Disallowed

Use Limitations
7 days
preharvest
interval.
Grapes Use Groups; Terrestrial Food Crop and Terrestrial Feed Crop
Broadcast, Foliar, Aircraft
Broadcast, Foliar, Ground
Broadcast, Foliar, Shaker can
Low volume spray (concentrate). Foliar, Aircraft
Low volume spray (concentrate), Foliar, Low
volume ground
Spray, Foliar, Ground
Spray, Foliar, Aircraft
Kiwi Use Group: Terrestrial Food Crop
Low volume spray (concentrate), Foliar, Aircraft
Low volume spray, Foliar, Low volume ground
D
D
D
SC/L
SC/L
SC/L
SC/L

SC/L
SC/L
1.5 to At per A
f .5 Ib Al per A
na
na
na
m
na

na
na
not spec
not spec
Dose cannot
be calculated
.625 Ib Al per
A
.825 Ib Al per
A
Dose cannot
be calculated
Dose cannot
be calculated
not
spec
not
spec
not
spec
2 per
Cyde
2 per
Cyde
not
spec
not
spec

.825 Ib Al per
A
.825 Ib Al per
A
2 per
Cyde
2 per
Cycle
not
spec
not
spec
not
spec
not
spec
not
spec
not
spec
not
spec

not
spec
not
spec
7
7
7
not spec
not spec
7
7
not spec
not spec
not spec
not spec
not spec
not spec
not spec

not spec
not spec
not spec
not spec














7 days
preharvest
interval.
7 days
preharvest
Interval.
2 days
preharvest
interval.


15 days
preharvest
interval.
15 days
preharvest
interval.







Lemon Use Groups: Terrestrial Food Crop and Terrestrial Feed Crop
Low volume spray (concentrate), Foliar, Aircraft
SC/L
na
.825 Ib Al per
A
2 per
Cycle
not
spec
not spec
not spec



10

-------
APPENDIX A- Case 4007, [Allium sativum] Chemical 128827 [Allium sativum]
SITE Application Type, Application Timing, Application
Equipment
Low volume spray (concentrate), Foliar, Low
volume ground
Form
sen
Minimum
Application Rate
na
Maximum
Application Rate
.825 Ib Al per
A
Max. *
Apps,
2 per
Cycle
Max.*
Apps.
@
Max.
Rate
not
spec
Mln. Interval
Between Apps.
® Max. Hate
(Days)
not spec
Restricted
Entry
Interval
(Days)
not spec
Geographic
Limitations
Allowed

Disallowed

Use Limitations

Lettuce Use Group: Terrestrial Food Crop
Band treatment, At planting, Mechanical granule
applicator
Broadcast, Foliar, Aircraft
Broadcast, Seedling stage, Aircraft
Broadcast, Foliar, Ground
Broadcast, Seedling stage, Ground
Broadcast, Postemergence, Shaker can
High volume spray (dilute), Foliar, Ground
Low volume spray (concentrate), Foliar, Aircraft
Low volume spray (concentrate), Prebloom,
Aircraft
Low volume spray (concentrate), Foliar, Low
volume ground
Low volume spray (concentrate), Prebloom,
Low volume ground
0
D
D
D
0
D
SC/L
SC/L
SC/L
SC/L
SC/L
1 to Al per A
1,5 Ib AlperA
1.5lbAlperA
1 .5 Ib AlperA
1.5 Ib AlperA
na
na
na
na
na
na
not spec
not spec
not spec
not spec
not spec
Dose cannot
be calculated
Dose cannot
be calculated
.825 Ib Al per
A
.825 Ib Al per
A
.825 Ib Al per
A
.825 Ib Al per
A
not
spec
not
spec
not
spec
not
spec
not
spec
not
spec
not
spec
2 per
Cycle
2 per
Cycle
2 per
Cycle
2 per
Cycle
not
spec
not
spec
not
spec
not
spec
not
spec
not
spec
not
spec
not
spec
not
spec
not
spec
not
spec
not spec
7
7
7
7
not spec
As needed
not spec
not spec
not spec
not spec
not spec
not spec
not spec
not spec
not spec
not spec
not spec
not spec
not spec
not spec
not spec























7 days
pre harvest
interval.
7 days
preharvest
interval.
7 days
preharvest
htervat.
7 days
preharvest
interval.

15 days
preharvest
interval.




11

-------
APPENDIX A- Case 4007, [Allium sativum] Chemical 128827 [Allium sativum]
SITE Application Type, Application Timing, Application
Equipment
Soil band treatment, At planting, Shaker can
Soil treatment. At planting, Shaker can
Spray, Foliar, Aircraft
Spray, Seedling stage, Aircraft
Spray, Seedling stage, Ground
Form
D
D
SC/L
SC/L
SC/L
Minimum
Application Rate
na
na
na
na
na
Maximum
Application Rate
Dose cannot
be calculated
Dose cannot
be calculated
Dose cannot
be calculated
Dose cannot
be calculated
Dose cannot
be calculated
Max. *
Apps.
not
spec
not
spec
not
spec
not
spec
not
spec
Max.*
Apps.
@
Max.
Rate
not
spec
not
spec
not
spec
not
spec
not
spec
Min. Interval
Between Apps.
@ Max. Rate
(Days)
not spec
not spec
As needed
As needed
As needed
Restricted
Entry
Interval
(Pays)
not spec
not spec
not spec
not spec
not spec
Qeographlo
Limitations
Allowed





Disallowed





Use Limitations


15 days
preharvest
interval.
15 days
preharvesl
interval.
15 days
preharvest
interval.
Melons Use Groups: Terrestrial Food Crop
Band treatment, At planting. Mechanical
granule applicator
Broadcast, Foliar, Aircraft
Broadcast, Seedling stage, Aircraft
Broadcast, Foliar, Ground
Broadcast, Seedling stage, Ground
Broadcast, Postemergence, Shaker can
Low volume spray (concentrate), Foliar, Aircraft
D
D
D
D
D
D
SC/L
1 Ib Al per A
1.5lbAlperA
1,5 Ib Al per A
1,5 to A) per A
1.5 to Al per A
na
na
not spec
not spec
not spec
not spec
not spec
Dose cannot
be calculated
.825 Ib Al per
A
not
spec
not
spec
not
spec
not
spec
not
spec
not
spec
2 per
Cycle
not
spec
not
spec
not
spec
not
spec
not
spec
not
spec
not
spec
not spec
7
7
7
7
not spec
not spec
not spec
not spec
not spec
not spec
not spec
not spec
not spec















7 days
preharvest
interval.
7 days
preharvest
interval.
7 days
preharvest
interval.
7 days
preharvest
interval.


12

-------
APPENDIX A- Case 4007, [Allium sativum] Chemical 128827 [Allium sativum]
SITE Application Type, Application Timing, Application
Equipment
Low volume spray (concentrate), Prebloom,
Aircraft
Low volume spray (concentrate), Foliar, Low
volume ground
Low volume spray (concentrate), Prebloom, Low
volume ground
Soil band treatment, At planting. Shaker ran
Soil treatment. At planting, Shaker can
Spray, Foliar, Aircraft
Spray, Seedling stage, Aircraft
Spray, Foliar, Ground
Spray, Seedling stage, Ground
Form
SC/L
SC/L
SC/L
D
0
SC/L
SC/L
SC/L
SC/L
Minimum
Application Rate
na
na
na
r»i
na
na
na
na
na
Maximum
Application Rate
.825 Ib Al per
A
.825 Ib Al per
A
.825 Ib Al per
A
Dose cannot
be calculated
Dose cannot
be calculated
Dose cannot
be calculated
Dose cannot
be calculated
Dose cannot
be calculated
Dose cannot
be calculated
Max. #
Apps.
2 per
Cycle
2 per
Cycle
2 per
Cycle
not
spec
not
spec
not
spec
not
spec
not
spec
not
spec
Max *
Apps.
0
Max.
Rate
not
spec
not
spec
not
spec
not
spec
not
spec
not
spec
not
spec
not
spec
not
spec
Mtn, Interval
Between Apps.
@ Max. Rate
(Days)
not spec
not spec
not spec
not spec
not spec
As needed
As needed
As needed
As needed
Restricted
Entry
Interval
(Days)
not spec
not spec
not spec
not spec
not spec
not spec
not spec
not spec
not spec
Geographic
Limitations
Allowed









Disallowed









Use Limitations





15 days
preharvest
interval.
15 days
preharvest
interval.
15 days
preharvest
interval.
15 days
preharvest
interval.
Melons, Cantaloupe Use Group: Terrestrial Food Crop
Low volume spray (concentrate), Foliar,
Aircraft
Low volume spray (concentrate), Prebloom,
Aircraft
Low volume spray (concentrate), Foliar,
Low volume ground
Low volume spray (concentrate), Prebloom,
Low volume ground
SC/L
SC/L
SC/L
SC/L
na
na
na
na
.825 Ib Al per
A
.825 Ib Al per
A
.825 Ib Al per
A
.825 Ib Al per
A
2 per
Cycle
2 per
Cycle
2 per
Cycle
2 per
Cycle
not
spec
not
spec
not
spec
not
spec
not spec
not spec
not spec
not spec
not spec
not spec
not spec
not spec












13

-------
APPENDIX A- Case 4007, [Allium sativum] Chemical 128827 [Atlium sativum]
SITE Application Type, Application Timing, Application
Equipment
Spray, Foliar, Aircraft
Spray, Seedling stage, Aircraft
Spray, Foliar, Ground
Spray, Seedling stage, Ground
Form
sen
sen
SC/L
SC/L
Minimum
Application Rate
na
na
na
na
Maximum
Application Rate
Dose cannot
be calculated
Dose cannot
be calculated
Dose cannot
be calculated
Dose cannot
be calculated
Max.*
Apps.
not
spec
not
spec
not
spec
not
spec
Max. *
Apps.
a
Max.
Rate
not
spec
not
spec
not
spec
not
spec
Min. Interval
Between Apps.
@ Max. Rate
[Days)
As needed
As needed
As needed
As needed
Restricted
Entry
Interval
(Days)
not spec
not spec
not
spec
not spec
Geographic
Limitations
Allowed




Disallowed




Use Limitations
15 days
preharvest
interval.
15 days
preharvest
interval.
15 days
preharvest
Interval.
15 days
preharvest
Interval.
Nectarine Use Group: Terrestrial Food Crop
Broadcast, Foliar, Aircraft
Broadcast, Foliar, Ground
0
D
2.5 Ib Al per A
2,5 Ib Al per A
not spec
not spec
not
spec
not
spec
not
spec
not
spec
7
7
not spec
not spec




7 days
preharvest
interval.
7 days
preharvest
interval.
Onion Use Group: Terrestrial Food Crop
Low volume spray (concentrate). Foliar, Aircraft
Low volume spray (concentrate), Prebloom,
Aircraft
Low volume spray (concentrate). Foliar, Low
volume ground
Low volume spray (concentrate), Prebloom, Low
volume ground
SC/L
SC/L
SC/L
SC/L
na
na
na
na
.825 Ib Al per
A
,825 to Al per
A
.825 Ib Al per
A
.825 Ib Al per
A
2 per
Cycle
2 per
Cycte
2 per
Cycle
2 per
Cycle
not
spec
not
spec
not
spec
not
spec
not spec
not spec
not spec
not spec
not spec
not spec
not spec
not spec












Orchards (Unspecified) Use Group: Terrestrial Food Crop
14

-------
APPENDIX A- Case 4007, [Allium sativum] Chemical 128827 [Allium sativum]
SITE Application Type, Application Timing, Application
Equipment
Broadcast, Foliar, Aircraft
Broadcast, Foliar, Ground

Broadcast, Foliar, Shaker can
Spray, Foliar, Aircraft
Spray, Petal fall. Aircraft
Spray, Foliar, Ground
Spray, Petal fall, Ground
Form
D
D

D
SC/L
SC/L
SC/L
SC/L
Minimum
Application Rate
2.5 Ib Al per A
2.5 Ib Al per A

na
na
na
na
na
Maximum
Application Rate
not spec
not spec

Dose cannot
be calculated
Dose cannot
be calculated
Dose cannot
be calculated
Dose cannot
be calculated
Dose cannot
be calculated
Max, #
Apps.
not
spec
not
spec

not
spec
not
spec
not
spec
not
spec
not
spec
Max.*
Apps.
©
Max.
Rate
not
spec
not
spec

not
spec
not
spec
not
spec
not
spec
not
spec
Win. Interval
Between Apps.
@ Max. Rate
(Days)
7
7

7
not spec
not spec
not spec
not spec
Restricted
Entry
Interval
(Days)
not spec
not spec

not spec
not spec
not spec
not spec
not spec
Geographic
Limitations
Allowed








Disallowed








Use Limitations
7 days
preharvest
interval.
7 days
preharvest
interval.

2 days
preharvest
Interval.
15 days
preharvest
interval.
15 days
preharvest
interval.
15 days
preharvest
interval.
15 days
preharvest
interval.
Orange Use Groups: Terrestrial Food Crop and Terrestrial Feed Crop
Spray, Foliar, Aircraft
Spray, Petal fall, Aircraft
Spray, Foliar, Ground
SC/L
SC/L
SC/L
na
na
na
Dose cannot
be calculated
Dose cannot
be calculated
Dose cannot
be calculated
not
spec
not
spec
not
spec
not
spec
not
spec
not
spec
7
7
7
not spec
not spec
not spec






15 days
preharvest
Interval.
15 days
preharvest
Interval.
15 days
preharvest
interval.
15

-------
APPENDIX A- Case 4007, [Allium sativum] Chemical 128827 [Allium sativum]
SITE Application Type, Application Timing, Application
Equipment
Spray, Petal fall. Ground
Low volume spray (concentrate), Foliar,
Aircraft
Low volume spray (concentrate), Foliar, Low
volume ground
Form
SC/L
SC/L
SC/L
Minimum
Application Rate
na
na
na
Maximum
Application Ran
Dose cannot
be calculated
,825 Ib Al per
A
.825 Ib Al per
A
Max.*
Apps.
not
spec
2 per
Cycle
2 per
Cycle
Max.*
Apps.
8
Max.
Rate
not
spec
not
spec
not
spec
Mia Interval
Between Apps.
@ Max. Rate
(Days)
7
not spec
not spec
Restricted
Entry
Interval
(Days)
not spec
not spec
not spec
Geographic
UmHatlons
Allowed



Disallowed



Use Limitations
15 days
preharvest
interval.


Peach Use Group; Terrestrial Food Crop
Broadcast, Foliar, Aircraft
Broadcast, Foliar, Ground
Low volume spray (concentrate). Foliar,
Aircraft
Low volume spray (concetrate), Foliar,
Low volume ground
Spray, Foliar, Aircraft
Spray, Petal fat. Aircraft
Spray, Foliar, Ground
Spray, Petal fall, Ground
0
D
SC/L
sen
SC/L
SC/L
SC/L
SC/L
2.5 Ib Al per A
2.5lbAlperA
na
na
na
na
na
na
not spec
not spec
£25 Ib Al per
A
,825 Ib Al per
A
Dose cannot
be calculated
Dose cannot
be calculated
Dose cannot
be calculated
Dose cannot
be calculated
not
spec
not
spec
2 per
Cycle
2 per
Cycle
not
spec
not
spec
not
spec
not
spec
not
spec
not
spec
not
spec
not
spec
not
spec
not
spec
not
spec
not
spec
7
7
not spec
not spec
7
7
7
7
not spec
not spec
not spec
not spec
not spec
not spec
not spec
not spec
















7 days
preharvest
Interval
7 days
preharvest
interval.


15 days
preharvest
interval.
15 days
preharvest
Interval.
15 days
preharvest
interval.
15 days
preharvest
interval.
Pear Use Group: Terrestrial Food Crop
16

-------
APPENDIX A- Case 4007, [Allium sativum] Chemical 128827 [Allium sativum]
SITE Application Type, Applteatlon Timing, Application
equipment
Low volume spray (concentrate), Foliar,
Aircraft
Low volume spray (concentrate), Foliar, Low
volume ground
Form
sen
SC/L
Minimum
Application Rate
na
na
Maximum
Application Rate
.825 Ib Al per
A
.825 to Al per
A
Max.*
Apps.
2 per
Cycle
2 per
Cycle
Max.*
Apps.
@
Max.
Rate
not
spec
not
spec
Mln. Interval
Between Apps.
® Max. Rate
(Days)
not spec
not spec
Restricted
Entry
Interval
Pays)
not spec
not spec
Geographic
Urn ttations
Allowed


Disallowed


Use Limitations


Peas (Unspecified) Use Groups: Terrestrial Food Crop and Terrestrial Feed Crop
Low volume spray (concentrate), Foliar, Aircraft
Low volume spray (concentrate), Prebloom,
Aircraft
Low volume spray (concentrate), Foliar, Low
volume ground
Low volume spray (concentrate), Prebloom,
Low volume ground
SC/L
SC/L
SC/L
SC/L
na
na
na
na
,825 to Al per
A
,825 to Al per
A
.625 Ib Al per
A
.825 Ib Al per
A
2 per
Cycle
2 per
Cycle
2 per
Cycle
2 per
Cycle
not
spec
not
spec
not
spec
not
spec
not spec
not spec
not spec
not spec
not spec
not spec
not spec
not spec












Plum Use Group: Terrestrial Food Crop
Low volume spray (concentrate), Foliar, Aircraft
Broadcast, Foliar, Aircraft
Broadcast, Foliar, Ground
Low volume spray (concentrate), Foliar, Low
volume ground
Spray, Foliar, Aircraft
Spray, Petal fall, Aircraft
SC/L
D
D
SC/L
SC/L
SC/L
na
2,5 Ib Al per A
2,5 Ib At per A
na
na
na
.625 tb Al per
A
not spec
not spec
.825 Ib Al per
A
Dose cannot
be calculated
Dose cannot
be calculated
2 per
Cycle
not
spec
not
spec
2 per
Cycle
not
spec
not
spec
not
spec
not
spec
not
spec
not
spec
not
spec
not
spec
not spec
7
7
not spec
7
7
not spec
not spec
not spec
not spec
not spec
not spec













7 days
preharvest
interval.
7 days
preharvest
interval.

15 days
preharvest
interval.
15 days
preharvest
interval.
17

-------
APPENDIX A- Case 4007, [Allium sativum] Chemical 128827 [Allium sativum]
SITE Application Type. Application Timing, Application
Equipment
Spray, Foliar, Ground
Spray, Petal (all, Ground
Form
SC/L
SC/L
Minimum
Application flate
na
na
Maximum
Application Rate
Dose cannot
be calculated
Dose cannot
be calculated
Max.*
Apps.
not
spec
not
spec
Max.*
Apps.
&
Max.
Rate
not
spec
not
spec
Potato, White/Irish Use Groups; Terrestrial Food Crop and Terrestrial Feed Crop
Low volume spray (concentrate). Polar, Aircraft
Low volume spray (concentrate), Prebloom,
Low volume ground
Low volume spray {concentrate). Foliar, Low
volume ground
Low volume spray (concentrate), Prebloom,
Aircraft
Pumpkin Use Group: Terrestrial Food Crop
Low volume spray (concentrate), Foiar, Aircraft
Low volume spray (concentrate), Prebloom,
Aircraft
Low volume spray (concentrate) .Foliar, Low
volume ground
Low volume spray (concentrate), Prebloom,
Low volume ground
SC/L
SC/L
SC/L
SC/L

SC/L
SC/L
SC/L
SC/L
na
na
na
na

na
na
na
na
J25 to Al per
A
.825 (fa Ai per
A
.825 to Al per
A
.825 to Al per
A
2 per
Cycle
2 per
Cycle
2 per
Cycle
2 per
Cycle
not
spec
not
spec
not
spec
not
spec
Mln, Interval
Between Apps.
@ Max. Rate
(Days)
7
7

not spec
not spec
not spec
not spec
Restricted
Entry
Interval
(Days)
not spec
not spec
Geographic
Limitations
AHowed



not spec
not spec
not spec
not spec




Disallowed







Use limitations
15 days
preharvest
Interval.
15 days
preharvest
Interval.






,825 Ib Al per
A
.825 tb Al per
A
.825 to Al per
A
.825 Ib Al per
A
2 per
Cycle
2 per
Cycle
2 per
Cycle
2 per
Cycle
not
spec
not
spec
not
spec
not
spec
not spec
not spec
not spec
not spec
not spec
not spec
not spec
not spec












Radish Use Group: Terrestrial Food Crop
Broadcast, Postemergence, Shaker can
Soil treatment. At planting, Shaker can
0
0
na
na
Dose cannot not
be calculated | spec
Dose cannot not
be calculated | spec
not
spec
not
spec
not spec
not spec
not spec
not spec






18

-------
APPENDIX A- Case 4007, [Allium sativum] Chemical 128827 [Allium satlvum]
SITE Application Type, Application Timing. Application
Equipment
Soil band treatment, At planting, Shaker can
Form
D
Minimum
Application Rate
na
Maximum
Application Rate
Dose cannot
be calculated
Max.*
Apps.
not
spec
Max.*
Apps.
©
Max.
Rate
not
spec
Mln. Interval
Between Apps.
@ Max. Rate
(Days)
not spec
Restricted
Entry
Interval
(Days)
not spec
Small Fruits Use Group: Terrestrial Food Crop
Broadcast, Foliar, Aircraft
Broadcast, Foliar, Ground
Spray, Foliar, Aircraft
Spray, Foliar, Ground
0
D
SC/L
SC/L
2.5 to Al per A
2.5 fc Al per A
na
na
not spec
not spec
Dose cannot
be calculated
Dose cannot
be calculated
not
spec
not
spec
not
spec
not
spec
not
spec
not
spec
not
spec
not
spec
7
7
7
7
not spec
not spec
not spec
not spec
Geographic
Limitations
Allowed






Disallowed






Use U rotations


7 days
preharvest
Interval.
7 days
preharvest
Interval.
15 days
preharvest
Interval.
15 days
preharvest
Interval.
Spinach Use Group: Terrestrial Food Crop
High volume spray (dilute), Foliar, Ground
Spray, Foliar, Aircraft

Spray, Seedling stage, Aircraft
Spray, Seedling stage, Ground
SC/L
SC/L

SC/L
SC/L
na
na

na
na
Dose cannot
be calculated
Dose cannot
be calculated

Dose cannot
be calculated
Dose cannot
be calculated
not
spec
not

not
spec
not
spec
not
spec
not
spec

not
spec
not
spec
As needed
As needed

As needed
As needed
not spec
not spec

not spec
not spec










15 days
preharvest
interval.
15 days
preharvest
Interval.

15 days
preharvest
interval.
15 days
preharvest
interval.
Sunflower Use Groups: Terrestrial Food Crop and Terrestrial Feed Crop
19

-------
APPENDIX A- Case 4007, [Allium sativum] Chemical 128827 [AMium sativum]
SITE Application Type, Application Timing, Application
Equipment
Band treatment, At planting. Mechanical
granule applicator
Broadcast, Foliar, Aircraft
Broadcast, Seedling stage, Aircraft
Broadcast, Foliar, Ground
Broadcast, Seedling stage, Ground
Form
D
D
D
D
D
Minimum
Application Rate
1 to Al per A
1.5lbAlperA
1.5lbAlperA
1 .5 Ib Al per A
UtbAiperA
Maximum
Application Rate
not spec
not spec
not spec
not spec
not spec
Max.*
Apps.
not
spec
not
spec
not
spec
not
spec
not
spec
Max.*
Apps.
©
Max.
Rate
not
spec
not
spec
not
spec
not
spec
not
spec
Mln. Interval
Between Apps.
@ Max, Rat*
(Days)
not spec
7
r
7
7
Restricted
Entry
Interval
(Days)
not spec
not spec
not spec
not spec
not spec
Geographic
Limitations
Allowed





Disallowed





Use Limitations

7 days
preharvest
interval.
7 days
preharvest
interval.
7 days
preharvest
interval.
/days
preharvest
interval.
Tomato Use Groups: Terrestrial Food Crop and Terrestrial Feed Crop
Broadcast. At planting, Mechanical granule
applicator
Broadcast, Foliar, Aircraft
Broadcast, Seedling stage. Aircraft
Broadcast, Seedling stage, Ground
Broadcast, Postemergence, Shaker can
High volume spray (dilute). Foliar, Ground
D
D
D
D
D
SC/L
1,5lbAlperA
LSIbAlperA
UlbAlperA
1.5lbAlperA
na
na
not spec
not spec
not spec
not spec
Dose cannot
be calculated
Dose cannot
be calculated
not
spec
not
spec
not
spec
not
spec
not
spec
not
spec
not
spec
not
spec
not
spec
not
spec
not
spec
not
spec
7
7
7
7
not spec
As needed
not spec
not spec
not spec
not spec
not spec
not spec












7 days
preharvest
interval.
7 days
preharvest
interval.
7 days
preharvest
interval.
7 days
preharvest
interval.

15 days
preharvest
Interval.
20

-------
APPENDIX A- Case 4007, [AHium sativum] Chemical 12882? [Allium sativum]
SITE Application Type, Application Timing, Application
Equipment
Soil band treatment, At planting, Shaker can
Soil treatment, At planting, Shaker can
Spray, Foliar, Aircraft
Spray, Seedling stage. Aircraft
Spray, Seedling stage. Ground
Form
0
D
SC/L
SC/L
SC/L
Minimum
Application Rate
na
na
na
na
na
Maximum
Application Rate
Dose cannot
be calculated
Dose cannot
be calculated
Dose cannot
be calculated
Dose cannot
be calculated
Dose cannot
be calculated
Max.*
Apps,
not
spec
not
spec
not
spec
not
spec
not
spec
Max. *
Apps.
©
Max.
Rate
not
spec
not
spec
not
spec
not
spec
not
spec
Mln. Interval
Between Apps.
@ Max Rate
(Days)
not spec
not spec
As needed
As needed
As needed
Restricted
Entry
interval
(Days)
not spec
not spec
not spec
not spec
not spec
Geographic
limitations
Allowed





Disallowed





Use Limitations


IS days
preharvest
interval.
15 days
pretiarvest
interval.
15 days
preharvest
interval.
Tree Nuts Use Group: Terrestrial Food Crop
Broadcast, Foliar, Aircraft
Broadcast, Foliar, Ground
D
D
Vegetables (Unspecified) Use Group: Terrestrial Food Crop
Band treatment, At planting, Mechanical granule
applicator
Broadcast, Foliar, Aircraft
Broadcast, Seedling stage, Aircraft
Broadcast, Foliar, Ground
D
D
D
D
2.5 Ib A) per A
2.5 Ib Al per A
not spec
not spec

1 Ib Al per A
UlbAlperA
1.5lbA!perA
1.5lbAlperA
not spec
not spec
not spec
not spec
not
spec
not
spec

not
spec
not
spec
not
spec
not
spec
not
spec
not
spec

not
spec
not
spec
not
spec
not
spec
7
7
not spec
not spec

not spec
7
7
7
not spec
not spec
not spec
not spec













7 days
preharvest
interval.
7 days
preharvest
Interval.


7 days
preharvest
interval.
7 days
preharvest
interval.
7 days
preharvest
interval.
21

-------
APPENDIX A- Case 4007, [Allium sativum] Chemical 128827 [Allium sativum]
SITE Application Type, Application Timing, Application
Equipment
Broadcast, Seeding stage, Ground
Broadcast, Post emergence, Shaker can
High volume spray (dilute), Foliar, Ground
Soil band treatment, At planting, Shaker can
Soil treatment, At planting. Shaker can
Spray, Foliar, Aircraft
Spray, Seedling stage, Aircraft
Spray, Seedling stage, Ground
Foftr*
D
D
SC/L
D
D
SC/L
SC/L
SC/L
Minimum
Application Rate
1 .5 Ib Al per A
na
na
na
na
na
na
na
Maximum
Application Rate
not spec
Dose cannot
be calculated
Dose cannot
be calculated
Dose cannot
be calculated
Dose cannot
be calculated
Dose cannot
be calculated
Dose cannot
be calculated
Dose cannot
be calculated
Max.*
Apps.
not
spec
not
spec
not
spec
not
spec
not
spec
not
spec
not
spec
not
spec
Max.*
Apps.
©
Max.
Rate
not
spec
not
spec
not
spec
not
spec
not
spec
not
spec
not
spec
not
spec
Mln, Interval
Between Apps.
6 Max. Rate
(Days)
7
not spec
As needed
not spec
not spec
As needed
As needed
As needed
Restricted
Entry
Interval
(Days)
not spec
not spec
not spec
not spec
not spec
not spec
not spec
not spec
Geographic
Limitations
Allowed








Disavowed








Use Limitations
7 days
preharvest
interval.

15 days
preharvest
interval.


15 days
preharvest
interval.
15 days
preharvest
Interval.
15 days
preharvest
interval.
Walnut (English/Black) Use Group: Terrestrial Food Crop
Low volume spray (concentrate). Foliar, Aircraft
Low volume spray (concentrate), Foliar, Low
volume ground
SC/L
SC/L
na
na
.825 to Al per
A
.825 Ib Al per
A
2 per
Cycle
2 per
Cycle
not
spec
not
spec
not spec
not spec
not spec
not spec






NONFOOD/NONFEED USES
Ornamental Herbaceous Plants Use Groups; Terrestrial Non-Food Crop and Outdoor Residential
Spray, Foliar, Aircraft
SC/L
na
Dose cannot [I not
be calculated || spec
not
spec
As needed
not spec



22

-------
APPENDIX A- Case 4007, [Allium sativum] Chemical 12882? [Allium satlvum]
SITE Application Type. Application Timing, Application
Equipment
Spray, Foliar, Ground
Form
SC/L
Minimum
Application Rate
na
Maximum
Application Rate
Dose cannot
be calculated
Max.*
Apps.
not
spec
Ma*,*
Apps.
@
Max.
Rate
not
spec
Mln. Interval
Between Apps.
@ Max. Rate
(Days)
As needed
Restricted
Entry
Interval
(Days)
not spec
Gtographlc
Limitations
Allowed

Disallowed

Use Limitations

Ornamental Woody Shrubs and Vfaes Use Groups: Terrestrial Non-Food Crop and Outdoor Residential
Spray, Foliar, Aircraft
Spray, Foliar, Ground
SC/L
SC/L
na
na
Dose cannot not
be calculated || spec
Dose cannot | not
be calculated || spec
not
spec
not
spec
As needed
As needed
not spec
not spec






Abbreviations used
    Header:       max=max!mum; m!n=minlmutTi; apps=app!ications; not spee^ot specified; na=not applicable
    Form:         D=dust; SC/L=soluble coneentratefliquid
    Rate:         ai=active ingredient; A=acre

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i
                                        APPENDIX B



                       Generic Data Requirements for Reregistration



                      of Allium Sativum  (Garlic)  and Data Citations



                                Supporting Reregistration
                                            34

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^^^w
                                   GUIDE TO APPENDIX B

                 Appendix B contains listings of data requirements which
            support the reregistration for the pesticide covered by this
            Reregistration Eligibility Document.

                 Appendix B contains generic data requirements that apply to
            the pesticide in all products, including data requirements for
            which a "typical formulation" is the test substance.

                 The data table are generally organized according to the
            following format:

                 1.   Data Requirements (Column 1).  The data requirements
            are listed in the order in which they appear in 40 CFR Part 158.
            The reference numbers accompanying each test refer to the test
            protocols set out in the Pesticide Assessment Guidelines, which
            are available from the National Technical Information Service,
            5285 Port Royal Road, Springfield, VA  22161.

                 2.   Use Pattern (Column 2).  This column indicates the use
            patterns to which the data requirement applies.  The following
            letter designations are used for use patterns:

                 A    Terrestrial food
                 B    Terrestrial feed
                 C    Terrestrial non-food
                 K    Residential

                 Any other designations will be defined in a footnote to the
            table.

                 3,   Bibliographic citation  (Column 3).  If the Agency has
            acceptable data in its files, this column lists the identifying
            number of each study.  This normally is the Master Record
            Identification (MRID) number, but may be a GS number if no MRID
            number has been assigned.  Refer to the Bibliography Appendices
            for a complete citation of the study.
                                            35

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                           APPENDIX B
GENERIC DATA REQUIREMENTS FOR REREGISTRATION OF ALLIUM SATIVPM
AND DATA CITATIONS SUPPORTING REREGISTRATION
GUIDELINE
CITATION
TITLE OF
STUDY
USE
PATTERNS
BIBLIOGRAPHIC
CITATION
Product Chemistry
61-1
61-2 (a)
61-2 (b)
62-1
62-3
63-2
63-3
63-4
63-5
63-7
63-8
Product Identity
Begin. Mat. and Mfg. Process
Discussion of Impurities
Preliminary Analysis
Analytical Method
Color
Physical State
Odor
Melting Point
Density
Solubility
ABCK
ABCK
ABCK
ABCK
ABCK
ABCK
ABCK
ABCK
ABCK
ABCK
ABCK
470028026
satisfied
satisfied
satisfied
satisfied
satisfied
satisfied
satisfied
satisfied
satisfied
satisfied
                               36

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63-10    Dissociation Constant          ABCK                     satisfied



63-12     pH                            ABCK                     satisfied



63-13     Stability                     ABCK                     satisfied





Ecological Effects;



EPA waived all of these guidelines as discussed in sections III and IV.



Toxicology:



EPA waived all of these guidelines as discussed in sections III and IV.





Environmental Fate;



 EPA waived all of these guidelines as discussed in section III and IV.





Residue Chemistry;



EPA waived all of these guidelines as discussed in section III and IV.





Occupational Exposure;



EPA waived all of these guidelines as discussed in section III and IV.
                                            37

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              APPENDIX C

              SATIVUM  (GARLIC)

Citations Considered to be Part of the
  Data Base Supporting Reregistration
                   38

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                               GUIDE TO APPENDIX C

CONTENT OF BIBLIOGRAPHY.  This bibliography contains citations of all studies
considered relevant by EPA in arriving at the positions and conclusions stated
elsewhere in the Reregistration Eligibility Document,  Primary sources for studies in
this bibliography have been the body of data submitted to EPA and its predecessor
agencies in support of past regulatory decisions.  Selections from other sources
including the published literature, in those instances where they have been
considered, will be included.

UNITS OF ENTRY.  The unit of entry in this bibliography is called a "study".  In the
case of published materials, this corresponds closely to an article.  In the case of
unpublished materials submitted to the Agency the Agency has sought to identify
documents at a level parallel to the published article from within the typically
larger volumes in which they were submitted.  The resulting "studies11 generally have
a distinct title (or at least a single subject), can stand alone for purposes of
review, and can be described with a conventional bibliographic citation.  The Agency
has attempted also to unite basic documents and  commentaries upon them, treating
them as a single study.

IDENTIFICATION OF ENTRIES.  The entries in this bibliography are sorted numerically
by Master Record Identifier, or MRID number.  This number is unique to the citation,
and should be used at any time specific reference is required.  It is not related to
the six-digit "Accession Number" which has been used to identify volumes of submitted
studies; see paragraph 4(d)(4) below for further explanation.  In a few cases,
entries added to the bibliography late in the review may be preceded by a nine-
character temporary identifier.  These entries are listed after all MRID entries.
This temporary identifier number is also to be used whenever specific reference is
needed.

FORM OF ENTRY.  In addition to the Master Record Identifier (MRID), each entry
consists of a citation containing standard elements followed, in the case of material
submitted to EPA, by a description of the earliest known submission.  Bibliographic
conventions used reflect the standards of the American National Standards Institute
(ANSI), expanded to provide for certain special needs.

                                       39

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a.   Author.  Whenever the Agency could confidently identify one, the Agency has
     chosen to show a personal author.  When no individual was identified, the Agency
     has shown an identifiable laboratory or testing facility as author.  As a last
     resort, the Agency has shown the first submitter as author.

b.   Document date.  When the date appears as four digits with no question marks, the
     Agency took it directly from the document.  When a four-digit date is followed
     by a question mark the bibliographer deduced the date from evidence in the
     document.  When the date appears as (19??), the Agency was unable to determine
     or estimate the date of the document.

c.   Title.  In some cases, it has been necessary for Agency
     bibliographers to create or enhance a document title.  Any such editorial
     insertions are contained between square brackets.

d.   Trailing parentheses.  For studies submitted to the Agency in the past, the
     trailing parentheses include (in addition to any self-explanatory text) the
     following elements describing the earliest known submission:

     (1)  Submission date.  The date of the earliest known submission appears
          immediately following the word "received."

     (2)  Administrative number.  The next element, immediately following the word
          "under," is the registration number, experimental use permit number,
          petition number, or other administrative number associated with the
          earliest known submission.

     (3)  Submitter.  The third element is the submitter, following the phrase
          "submitted by."  When authorship is defaulted to the submitter, this
          element is omitted.

     (4)  Volume Identification (Accession Numbers).  The   final element in the
          trailing parentheses identifies the EPA accession number of the volume in
          which the original submission of the study appears.  The six-digit
          accession number follows the symbol "CDL," standing for "Company Data
          Library."  This accession number is in turn followed by an alphabetic
          suffix which shows the relative position of the study within the volume.

                                       40

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For example, within accession number 123456, the first study would be
123456-A; the second, 123456-B; the 26th, 123456-Z; and the 27th, 123456-
AA.
                             41

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                                      OFFICE OF PESTICIDE PROGRAMS
                                  REREGISTRATION  ELIGIBILITY DOCUMENT
                                              BIBLIOGRAPHY
470028026      Supplementary To The List Of Data Requirements.  Unpublished study submitted by Sevana
               Company.
                                                   42

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I
                                       APPENDIX D



                                     PR NOTICE 91-2

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                 UNfTID STATES ENVIRONMENTAL PflOTECTlON AGENCY
                           WASHWOTON.D.C.  IMM
                                                         MAY  2
                                                         SUUTANCfS
             NOTICE TO MANUFACTURERS, PRODUCERS, FORMULATORS ,
                      AND REGISTRANTS OF PESTICIDES
ATTENTION:  Persons Responsible for Federal Registration of
            Pesticide Products.

SUBJBCTt    Accuracy of stated Percentages for Ingredients
            Statement
I.   PURPOSE:

     The  purpose of  this  notice is  to clarify  the Office of
Pesticide  Program's  policy with respect  to  the" statement of
percentages  in   a  pesticide's  label's  ingredient  statement.
Specifically,  the amount  (percent  by weight)  of ingredient(s)
specified in the ingredient statement on the label must be stated
as the nominal concentration of such ingredient (s),  as that term is
defined  in  40  CFR  158.153(1).  Accordingly,  the  Agency  has
established the nominal concentration as the only acceptable label
claim for the amount of active ingredient in the product.

II.  BACKGROUND

     For some time the Agency has accepted two different methods of
identifying  on the  label  what  percentage is claimed  for the
ingredient(s) contained in a pesticide.  Some applicants claimed a
percentage which  represented a  level between  the upper and the
lower  certified limits.   This  was referred  to as  the nominal
concentration.  Other applicants claimed the lower  limit as the
percentage of the  ingredient (s) that would  be expected  to be
present in their  product  at the end of the product's shelf-life.
Unfortunately, this led to a great  deal  of confusion among  the
regulated industry* the regulators, and the consumers as to exactly
how much of a given ingredient was in a given product. The Agency
has established the nominal concentration as the only acceptable
label claim for the amount of active ingredient in the product.

     Current regulations require that the percentage listed in the
active ingredient statement be as precise as possible reflecting
good manufacturing practices 40  CPU 156.10(g) (5). .The certified
limits  required  for  each  active  ingredient  are  intended to
encompass any such "good manufacturing practice11 variations 40 CFR
158.175(0}(3).

                                                       d& Print*} on fiKycto

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i
                    IV.  WfcODUCTl THXT UQOZll EfflCACf DATA

                         All pesticides ara  required to be efficacious.  Therefore,
                    the certified lower limits may net be lower then the minimum
                    level to achieve affleecy.  This is extremely important for
                    products which ere Intended to control peets which threaten the
                    public health, 0.9., certain Antimicrobial and rodentieide
                    products.  Refer to 40 CFR 1SI.€40.

                         In thosa casas vhara  afficacy limits hava baan astablishad,
                    tha Afancy will not aceapt cartifiad lovar limits which ara balov
                    that laval for tha sbalf lifa of tha product,

                    V.  COKPLIAHCZ tCHIDCIX

                         As dascribad aarliar, tha purposa of this Notica is to maka
                    tha ragistration procaas mora uniform and mora manafaabla for
                    both tha aganey and tha  ra^ulatad community.  It is tha Afaney'a
                    intantion to implamant tha raquiramants of this notica as
                    smoothly as poasibla so  as net to disrupt or dalay tha Afancy *s
                    high priority programs,  i.a., raragiatratlonf naw chamical, or
                    fast track (FZFKA aaction  3(c)(3)(B).  Tharafora,
                    applicants/ragistrants ara axpactad to comply with tha
                    raquiraHants of this Notica as fellowss

                              (1)   Beginning July 1, 1991, all nav product
                                   ragistrations submittad to tha Afancy
                                   ara to comply with tha raquirtianta of thi*
                                   Notiea.

                              (2)   Kagistrants having products subjact to
                                   raragistmtion undar FIFRA aaction 4 (a) ara to
                                .   comply with tha raquiramants of tills Notiea whan
                                   spaeif ie  products ara called in by tha Agency
                                   under Phaaa V of tha Haragiatration Program.

                              (3)   All other products/applications that are
                                   not subject to (1) and (2) above will nave until
                                  July 1* 1997, to comply vita this Notice.
                                   Such applications should note "Conversion
                                   to Nominal  Concentration" en the application
                                   fora. These types of amendments will not be
                                   bandied as  "fast Track0 applications but
                                  will be bandied as routine requests.
                   VI.  fOX fDWHDT XNTOJWATION

                        Contact Tyrone Aikan for information or questions concerning
                   this notice  on (703) 337-5024.
                                                   Anno 1. Lindsay, Director
                                                   Ragiatration Division (H-7305

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                 APPENDIX 1
                DATA CALL-IN
Product Specific data call-in and attachments

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I
                        UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
                                   WAKWOTON.D.C.  10460
                                DATA CALL-IN NOTICE
                                                               «mCJD« AND TOXIC
                                                                 •UWWNOES
          Dear Sir or Madam;


          This Notice requires you and other registrant* of pesticide
          products containing the active ingredient identified  in
          Attachment A of this Notice, the Data Call-in Chemical Status
          sheet. to submit certain product specific data as noted herein to
          the U.S. Environmental Protection Agency (EPA, the Agency).
          These data are necessary to maintain the continued registration
          of your product(s) containing this active ingredient.  Within 90
          days after you receive this Notice you must respond as set forth
          in Section III below.  Your response Bust state:

              1. How you will comply with the requirements set forth  in
                 this Notice and its Attachments A through G?  or

              2. Why you believe you are exempt from the requirements
                 listed in this Notice and in Attachment C,
                 Requirements Status and Registrant's Response Form,  (see
                 section III-B); or

              3. Why you believe EPA should not require your submission
                 of product specific data in the manner specified by  this
                 Notice  (see section III-D).

              If you do not respond to this Notice, or if you  do not
          satisfy EPA that you will comply with its requirements or should
          be exempt or excused from doing so, then the registration of your
          product(s) subject to this Notice will be subject to  suspension.
          We have provided a list of all of your products subject to this
          Notice in Attachment B, aata Call-In Responee Form, mm well  as a
          list of all registrants who were sent this Notice  (Attachment F).

              The authority for this Notice is section 3(c)(2)(B) of  the
          Federal Insecticide, Fungicide and Rodenticide Act as amended
          (FIFRA), 7 U.S.C. section 136a(c)(2)(B).  Collection  of this
          information is authorized under the Paperwork Reduction Act  by
          OMB Approval No. 2070-0107 (expiration date 12-31-92).

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i
                 This Notice is divided into mix sections and seven
           Attachments.  The Notic* itself contain* information and
           instructions applicable to all Data Call-In Notices.  The
           Attachments contain specific chemical information and
           instructions.  Toe six sections of the Notice are:

                Section Z   - Why You Are Receiving This Notice
                Section ZI  - Data Required By This Notice
                Section ZZZ - Compliance With Requirements Of This
                              Notice
                Section IV  - Consequences Of Failure To Comply With
                              This Notice
                Section V   - Registrants* Obligation To Report
                              Possible Unreasonable Adverse Effects
                Section VI  - Inquiries And Responses To This Notice

                The Attachments to this Notice are:
                A  — Data Call— In Che^m^ea.! _ States ........... Sfreet
                B  - Da^a,, ..... Cqll-In Response form                    "*    .  .
                C  - Requirements Status and Registrant's Response Fora
                D  - EPA Grouping of End-Use Products for Meeting Acute
                     Toxicology Data Regu^j emenljs for Rerepistration
                E -*  EPA Acceptance Criteria
                F  — List of Registrants Receiving This Notice
                G  *• Cost Share and Data Compensation Forms . and Product
                     Specific Data Report Form
           SECTION I.  WHY YOU ARE RECEIVING THIS NOTICE

              .  The Agency has reviewed existing data for this active
           ingredient and reevaluated the data needed to support continued
           registration of the subject active ingredient.  The Agency has
           concluded that the only additional data necessary are product
           specific data.  No additional generic data requirements are being
           imposed.  You have been sent this Notice because you have '
           product(s) containing the subject active ingredient.

           SECTION II.  DATA REQUIRED BY THIS NOTICE

           II-A.  DATA REQUIRED

                The product specific data required by this Notice are
           specified in Attachment C, Requirements	Status and Registrant's
           Response Form.  Depending on the results of the studies required in
           this Notice, additional testing aay be required.

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II-B.  pCH^PPfiB FPfi SUBMISSION OF DATA

     You are required to submit the data or otherwise satisfy the
data requirements specified in Attachment C, Requirements statue
and Registrant's Response Fora. within the timeframes provided.


II-C.  TESTTNG PROTOCOL

    ., Ml studies required under this notice mist be conducted in
accordance with test standards outlined in the Pesticide Assessment
Guidelines for those studies for which guidelines have been
established.

     These EPA Guidelines are available from the National Technical
Information Service (NTIS), Attn: Order Desk, 5285 Port Royal Road,
Springfield, Va 22161 (tel: 703-487*4650).

     Protocols approved by the Organization for Economic
Cooperation and Development (OECD) are also acceptable if the OECD-
recommended test standards conform to those specified in the
Pesticide Data Requirements regulation (40 CFR S 158.70).  When
using the OECD protocols, they should be modified as appropriate wo
that the data generated by the study vill satisfy the requirements
of 40 CFR f 158.  Normally, the Agency will not extend deadlines
for complying with data requirements when the studies were not
conducted in accordance with acceptable standards.  The OECD
protocols are available from OECD, 1750 Pennsylvania Avenue N.w.,
Washington, D.C. 20006.

     All new studies and proposed protocols submitted in response
to' this Data Call-In Notice must be in accordance with Good
Laboratory Practices [40 CFR Part 160.3(a)(6)3.

II-D.  REGISTRANTS RECEIVING PREVIOUS SECTION 3fcif21fBl NOTICES
       ISSUED BY THE AGENCY

       Unless otherwise noted herein, thisData Call-in doesnotin
any way supersede or change the requirements of any previous Data
Call-lnfsl. or any other agreements entered into with the Agency
pertaining to such prior Notice,  Registrants must comply with the
requirements of all Notices to avoid issuance of a Notice of Intent
to Suspend their affected products.


SECTION III.  COMPLIANCE WITH REQUIREMENTS OP THIS NOTICE.

III-A.  ffCHBEPLB FOB IESPONOING TO THE AGENCY

     The appropriate responses initially required by this Notice
for product specific data oust be submitted to the Agency within 90
days after your receipt of this Notice.  Failure to adequately
respond to this Notice within 90 days of your receipt will be a
basis for issuing a Notice of Intent to Suspend (NOIS) affecting

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i
            your products* This and other bases for issuance of NOXS due to
            failure to comply with this Notice are presented in Section ZV-A
            and ZVHB.

            ZII-B.  fMPTIOKS FOR RESPONDING TO TOE fcCgNCY

                The options for responding to this notice for product specific
            data are: (a) voluntary cancellation, (b) agree to satisfy the
            product specific data requirement* imposed by this Notice or (c)
            request a data waiver (s).  ...

                A discussion of how to respond if you choose the Voluntary
            Cancellation option is presented below.  A discussion of the
            various options available for satisfying the product specific data
            requirements of this Notice is contained in Section III-C.  A
            discussion of options relating to requests for data waivers is
            contained in Section III-D.

                There are two fonts that accompany this Notice of which,
            depending upon your response, one or both Bust be used in your
            response to the Agency.  These forms are the Data-Call-in Response
            Fora, and the Requirements Status and Registrant'sResponse Form.
            Attachment B ar.*i Attachment C.  The Data Sail-In Response Form must
            be submitted as part of every response to this Notice.  In
            addition, one copy of the Requirements status and Registrant' s
            Response Fora  must be submitted for each product listed on the
            Da^a Call-inResponse Form unless the voluntary cancellation option
            is selected or unless the product is identical to another (refer to
            the instructions for completing the Data Call-In Response Form in
            Attachment B}.  Please note that the company' s authorized
            representative is required to sign the first page of the pat a Call-
            in ResponseForm and Requirements Status and Registrant's Response
            yona (if this form is required) and initial any subsequent pages.
            The forms contain separate detailed instructions on the response
            options.  Do not alter the printed material,  if you have questions
            or need assistance in preparing your response, call or write the
            contact person (s) identified in Attachment A.

                1.'Voluntary Cancellation - You may avoid the requirements of
            this Notice by requesting voluntary cancellation of your product(s)
            containing the active ingredient that is the subject of this
            Notice.  Zf you wish to voluntarily cancel your product, you must
            submit a completed Data Call-In ResponseForm, indicating your
            election of this option.  Voluntary cancellation is item number 5
            on the gata Call-In Response Form. Zf you choose this option, this
            is the only form that you are required to complete.

                Zf you choose to voluntarily cancel your product, further sale
            and distribution of your product after the effective date of
            cancellation must be in accordance with the Existing Stocks
            provisions of this Notice which are contained in Section iv-c.

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    2. Satisfying the Product: Specific Data Requirements of this
notice.  There ara various options available to satisfy the product
•pacific data requirements of this Notica.  Tbasa options ara
diseussad in Saction III-C of this Notica and comprise options l
through 6 on tha Raauirajifnfrf Status and Registrant's Response Form
and item numbers 7a and 7b on tha Data call-in Ra§pon«* Form.
Dalation of a use(s) and tha low volume/minor use option ara not
valid options for fulfilling product spacific data raquiraments.

    3. Request for Product Specific Data Waivers.  Waivars for
product specific data ara diseussad in Saction III-D of this notice
and ara covarad by option 7 on tha BtMlrtBants status and
Registrant's Response Fora.  If you choose this option, you Bust
submit both forms as vail as any other inforaation/data pertaining
to. tha option chosen to address tha data raquireaent.

III-C  SATJtSFVINS TOE DATA REQUIREMENTS OF THIS HQflCE

     If you acknowledge on tha Data Call-In Response Fora that you
agree to satisfy tha product apecific data requirements (i.e. you
select option 7a or 7b), than you aust select one of tha six
options on tha Requirements Status and Registrant*s Response Form
related to data production for each data requirement.  Your option
selection should be entered under itaa number 9, "Registrant
Response."  The six options related to data production ara the
first six options discussed under itaa 9 in tha instructions for
completing the Requirements status and Registrant'sResponse Form.
These six options ara listed immediately below with information in
parentheses to guide registrants to additional instructions  :
provided in this Saction.  Tha options ara:

     (X-)  I will generate and submit data within tha specified
          timeframe (Developing Data)
     (2)  I have entered into an agreement with ona or aore
          registrants to develop data jointly (Cost Sharing)
     (3)  I have aada offers to cost-share (Offers to Cost Share)
     (4)  I am submitting an existing study that has not been
          submitted previously to tha Agency by anyone (Submitting
          an Existing Study)
     (5)  I am submitting or citing data to upgrade a study
          classified by EPA as partially acceptable and upgradeable
          (Upgrading a Study)
     (€)  I am citing an existing study that EPA has classified as
          acceptable or an existing study that has been submitted
          but not reviewed by tha Agency (Citing an Existing Study)

     Option 1. Developing Pata —  If you choose to develop tha
required data it aust be in conformance with Agency deadlines and
with other Agency requirements as rafarancad herein and in tha
attachments.  All data generated and submitted aust comply with the
Good Laboratory Practice (GLP) rule (40 CFR Part 160), be conducted
according to tha Pesticide Assessment Guidelines (PAG), and be in
conformance with tha requirements of PR Notice 86-5.

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    The time trames in the Requirements Status a,n.d Registrant. * s
Response Form are the time frames that the Agency is allowing for
the submission of completed study reports.  The noted deadlines run
from the date of the receipt of this Notice by the registrant.  If
the data are not submitted by the deadline, each registrant is
subject to receipt of a Notice of Intent to Suspend the affected
registration (s).

    Zf you cannot submit the data/reports to the Agency in the time
required by this Notice and intend to seek additional tine to meet
the requirement* (»), you must submit a request to the Agency which
includes: (i) a detailed description of the expected difficulty and
 (2) a proposed schedule including alternative dates for meeting
such requirements on a step-by-step basis.  You must explain any
technical or laboratory difficulties and provide documentation from
the laboratory performing the testing.  While EPA is considering
your request, the original deadline remains.  The Agency vill
respond to your request in writing.  Zf EPA does not grant your
request, the original deadline remains.  Normally, extensions can
be requested only in eases of extraordinary testing problems beyond
the expectation or control of the registrant.  Extensions will not
be given in submitting the 90-day responses.  Extensions will not
be considered if the request for extension is not made in a timely
fashion i in no event shall an extension request be considered if it
is submitted at or after the lapse of the subject deadline.

     Option 2. Acnree to Share in Cost to Develop Data --Registrants
nay JBUlX choose this option for acute toxicity data and certain
efficacy data and only if EPA has indicated in the attached data
.tables that your product and at least one other product are similar
for purposes of depending on the same data.  Zf this is the case,
data may be generated for just one of the products in the group.
The registration pmifter of the product for which data will be
submitted pust be noted in the agreement to cost share by the
registrant selecting this option.  Zf you choose to enter into an
agreement to share in the cost of producing the required data but
will not be submitting the data yourself, you must provide the name
of the registrant who will be submitting the data.  You must also
provide EPA with documentary evidence that an agreement has been
formed.  Such evidence may be your letter offering to join in an
agreement and the other registrant's acceptance of your offer, or a
written statement by the parties that an agreement exists.  The
agreement to produce the data need not specify all of the terms of
the final arrangement between the parties or the mechanism to
resolve the terms.  Section 3(c}(2)(B) provides that if the parties
cannot resolve the terms of the agreement they may resolve their
differences through binding arbitration.


    Option 3. Offer to Share in the Cost of Data Development  —
This option only applies to acute toxicity and certain efficacy
data as described in option 2 above.  Zf you have made an offer to
pay in an attempt to enter into an agreement or amend an existing
agreement to meet the requirements of this Notice and have been

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unsuccessful, you may request SPA (by selecting this option)  to
exercise its discretion not to suspend your registration ( s) ,
although you do not comply with the data submission requirements of
this Notice.  EPA has determined that as a general policy, absent
other relevant considerations, it vill not suspend the registration
of a product of a registrant who has in good faith sought and
continues to seek to enter into a joint data development/cost
sharing program, but the other registrant's) developing the data
has refused to accept your offer.  To qualify for this option, you
must' submit documentation to the Agency proving that you have made
an offer to another registrant (who has an obligation to submit
data) to share in the burden of developing that data.  You must
also submit to the Agency a completed EPA Form 8570-32,
Certification of Offer to Cost Share in the Development of Data,
Attachment 6.  In addition, you must demonstrate that the other
registrant to whom the offer was made has not accepted your offer
to enter into a costsharing agreement by including a copy of your
offer -and proof of the other registrant's receipt of that ofi*r
(such as a certified mail receipt) .  Your offer must, in addition
to anything else, offer to share in the burden of producing the .
data upon terms to be agreed or failing agreement to be bound by
bidding arbitration as provided by FIFRA section 3 (c) (2) (B) (iii)
ana must not qualify this offer.   The other registrant must also
inform EPA of its election of an option to develop and submit the
data required by this Notice by submitting a Data Call -In Response
form and a Requirements Status and Registrant's Response Form
committing to develop and submit the data required by this Notice.
     t ' '" *'

    In order for you to avoid suspension under this option,  you may
not -withdraw your offer to share in the burdens of developing the
data.  In addition, the other registrant must fulfill its
commitment to develop and submit the data as required by this
Notice.  If the other registrant fails to develop the data or for
some other reason is subject to suspension, your registration as
well as that of the other registrant will normally be subject to
initiation of suspension proceedings, unless you commit to submit,
and do submit the required data in the specified time frame.  In
such cases, the Agency generally will not grant a time extension
for submitting the data.
    Option 4. SybjBllttinff an Existing Study — If you choose to
submit an existing study in response to this Notice, you must
determine that the study satisfies the requirements imposed by this
Notice.  You may only submit a study that has not been previously
submitted to the Agency or previously cited by anyone.  Existing
studies are studies which predate issuance of this Notice*  Do not
use this option if you are submitting data to upgrade a study. (See
Option 5) .

    You should be aware that if the Agency determines that the
study is not acceptable, the Agency will require you to comply with
this Notice, normally without an extension of the required date of
submission.  The Agency may determine at any time that a study is
not valid and needs to be repeated.

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I
                                             8

                To meet the requirements of the DCI Notice for submitting an
            existing study, all of the tollowiny three criteria must be clearly
               *

                a. You must certify at the time that the existing study is
                submitted that the raw data and specimens from the study are
                available for audit and review and you must identify where they
                are available.  This must be clone in accordance with
                the requirements of the Good Laboratory Practice (CLP)
                regulation, 40 CFR Part 160. As stated in 40 CFR 160.3(j)
                * '[r]aw data* Miens any laboratory worksheets, records,
                memoranda, notes, or exact copies thereof, that are the result
                of original observations and activities of a study and  are
                necessary for the reconstruction and evaluation of the  report
                of that study.  Zn the event that exact transcripts of  raw data
                have been prepared (e.g., tapes which have been transcribed
                verbatim, dated, and verified accurate by signature), the exact
                copy o~ exact transcript Bay be substituted for the original
                source as raw data.  'Raw data* may include photographs,
                microfilm or microfiche copies, computer printouts, magnetic
                media, including dictated observations, and recorded data from
                automated instruments.**  The term "specimens*1, according to 40
                CFR 160.3(k), means "any material derived from a test system
                for examination or analysis.1*

                b. Health and safety studies completed after May 1984 must also
                contain all GLP-required quality assurance and quality  control
                .information, pursuant to the requirements of 40 CFR Part 160.
                Registrants must also certify at the time of submitting the
                existing study that such GLP information is available for post-
                May 1984 studies by including an appropriate statement  on or
                attached to the study signed by an authorized official  or
                representative of the registrant.

                c. You must certify that each study fulfills the acceptance
                criteria for the Guideline relevant to the study provided in
                the FIFRA Accelerated Reregistration Phase 3 Technical  Guidance
                and that the study has been conducted according to the
                Pesticide Assessment Guidelines (PAG) or meets the purpose of
                the PAG (both available from NTIS).  A study not conducted
                according to the PAG may be submitted to the Agency for
                consideration if the registrant believes that the study clearly
                meets the purpose of the PAG.  The registrant is referred to 40
                CFR 158.70 which states the Agency's policy regarding
                acceptable protocols. If you wish to submit the study,  you
                must, in addition to certifying that the purposes of the PAG
                are met by the study, clearly articulate the rationale  why you
                believe the study meets the purpose of the PAG, including
                copies of any supporting information or data.  Zt has been the
                Agency's experience that studies completed prior to January
                1970 rarely satisfied the purpose of the PAG and that necessary
                raw data are usually not available for such studies.

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    If you submit an existing study,  you must certify that the
study meets all requirements of the criteria outlined above.

    If you know of a study partaining to any requirement In this
notice which does not meet tha criteria outlinad above but doas
contain factual information ragarding unraasonabla advarsa affacts,
you vust notify tha Agency of such a study.   If such  study is in
tha Agancy'• filas, you naad only cita it along with tha
notification. If not in tha Agancy'a filas,  you Bust submit a
summary and copias as required by PR Notica  86-5.
                            v

    Option S, Upgrading m. study — If a study has baan classifiad
as partially accaptabla and upgradeable, you may submit data  to
upgrada that study.  Tha Agancy will raviaw  tha data submittad and
determine if tha requirement is satisfiad.  If tha Agancy dacidas
the requirement is not satisfiad, you may still be raguirad to
submit naw data normally without any tima extension.  Deficient,
but upgradaable studias will normally ba clasjified as
supplamantal.  However, it is important to nota that not all
studias classifiad as supplamantal ara upgradaabla.  If you have
questions ragarding tha classification of a  study or whathar  a
 tudy may ba upgraded, call or write tha contact parson listed in
Attachment A*  If you submit data to upgrada an existing study you
must satisfy or supply information to correct all deficiencies in
the study identified by EPA.  You must provide a clearly
articulated rationale of how the deficiencies have bean remedied or
corrected and why the study should ba rated  as acceptable to  IPA.
Your submission must also specify the MRID number(s) of the study
which you are attempting to upgrade and must be in conformance with
PR Notice 86-5.

    Do not submit additional data for the purpose of upgrading a
study classified as unacceptable and determined by the Agency as
not capable of being upgraded.

    This option should also be used to cite  data that has been
previously submitted to upgrade a study, but has not yet been
reviewed by the Agency*  You must provide the MRID number of  the
data submission as well as the KRID number of the study being
upgraded.

    The criteria for submitting an existing  study, as specified in
Option 4 above, apply to all data submissions intended to upgrade
studies.  Additionally your submission of data intended to upgrade
studies must be accompanied by a certification that you comply with
each of those criteria as well as a certification regarding
protocol compliance with Agency requirements.


    Option 6. citing ExistingStudies — If  you choose to cite a
study that has been previously submitted to  EPA, that study must
have been previously classified by EPA as acceptable or it must be
a study which has not yet been reviewed by the Agency.  Acceptable

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                                 10

 toxicology studies generally vill have been classified as "core-
 guideline" or "core minimum."  For all other disciplines the
 classification would be "acceptable."  With respect to any studies
 for which you vlsb to select this option you wist provide the MRID
 number of the study you are citing and, if the study has been
 reviewed by the Agency, you Must provide the Agency's
 classification of the study.

    If you are citing a study of which you are not the original
 data submitter, you must submit a completed copy of EPA Form
"8570-31, Certification with 'Respect to Data Compensation
 Requirements.

    Registrants who select one of the above 6 options must meet all
 of the requirements described in the instructions for completing
 the Data Call-In Response Form and the Requirementsstatus and
 Registrant's Response Form, as appropriate.

 III-D  REQUESTS FOR DATA WAIVERS

    If you request a waiver for product specific data because you
 believe it is inappropriate, you must attach a complete
 justification for the request, Including technical reasons, data
 and references to relevant EPA regulations, guidelines or policies.
 (Note: any supplemental data must be submitted in the format
 required by PR Notice 86-5).  This will be the onlv opportunity to
 state the reasons or provide information in support of your
 request.  Zf the Agency approves your waiver request, you will not
 be required to supply the data pursuant to section 3(c)(2)(B) of
 FIFRA.  Zf the Agency denies your waiver request, you must choose
 an option for meeting the data requirements of this Notice within
 30 days of the receipt of the Agency's decision.  You must indicate
 and submit the option chosen on the Requirements status and
 Registrant*s Response Form.  Product specific data requirements for
 product chemistry, acute toxicity and efficacy (where appropriate)
 are required for all products and the Agency will grant a waiver
 only under extraordinary circumstances.  You should also be aware
 that submitting a waiver request will not automatically extend the
 due date for the study in question.  Waiver requests submitted
 without adequate supporting rationale will be denied and the
 original due date will remain in force.

 IV* CONSEQUENCES OF FAILURE TO COMPLY WITH THIS NOTICE

 TV-A NOTICE OP INTENT TO StTSPlND

    The Agency say issue a Notice of Intent to Suspend products
 subject to this Notice due to failure by a registrant to comply
 with the requirements of this Data Call-In Notice, pursuant to
 FIFRA section 3(c) (2) (B).  Events which may be the basis for
 issuance of a Notice of Intent to Suspend include, but are not
 limited to, the following:

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I
                                          11

              1.  Failure to respond mm required by this Notice within 90
              day* of your receipt of this Notice.

              2.  Failure to submit on the required schedule en acceptable
              proposed or final protocol if such is required to be submitted
              to the Agency for review.

              3.  Failure to submit on the required, schedule an adequate
              progress report on a study if required by this Notice.

              4.  Failure to submit on the required schedule acceptable
              data as required by this Notice.

              S.  Failure to take a required action or submit adequate
              information pertaining to any option chosen to address  the data
              requirements (e.g., any required action or information
              pertaining to submission or citation of existing studies or
              offers, arrangements, or arbitration on the sharing of  costs or
              the formation of Task Forces,  failure to comply with the terms
              of an agreement or arbitration concerning joint data
              development or failure to comply with any terms of a data
              waiver) .

              6.  Failure to submit supportable certifications as to  the
              conditions of submitted studies,  as required by Section Ili-c
              of this Notice.

              7. Withdrawal of an offer to share in the cost of developing
              required data.

              8. Failure of the registrant to whom, you have tendered  an offer
              to share in the cost of developing data and provided proof of
              the registrant's receipt of such offer either to:

               a. Inform EPA of intent to develop and submit the data
               required by this Notice on a Data Call-In Response Form and a
               Requirements Status and Registrant's Response Form;

               b. Fulfill the commitment to develop and submit the data as
               required by this Notice; or

              c. Otherwise take appropriate steps to meet the requirements
              stated in this Notice, unless you commit to submit and  do
              submit the required data in the specified time frame.

              9.  Failure to take any required or appropriate steps,  not
              mentioned above, at any time following the issuance of  this
              Notice.                   :
          XV— B.  BASIS FOR DETERMINATION THAfy SUBMITTED STUDY IS
              The Agency may determine that a study (avan if submitted within
          the required time) is unacceptable and constitutes a basis for

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i
                                            12

            issuance of a Notice of Intent to suspend.  The grounds for
            suspension include, but are not limited to, failure to meet any of
            the following:

               1.  EPA requirement* specified in the Data Call-In notice or
               other documents incorporated toy reference (including, as
               applicable, EPA Pesticide Assessment Guidelines, Data Reporting
               Guidelines, and GeneTox Health Effects Test Guidelines)
               regarding the design, conduct, and reporting of required
               studies.  Such requirements include, but are not limited to,
              ' those relating to test material, test procedures, selection of
               species, number of animals, sex and distribution of animals,
               dose and effect levels to be tested or attained, duration of
               test, and,-as applicable. Good Laboratory Practices.

               2.  EPA requirements regarding the submission of protocols (if
               applicable), including the incorporation of any changes
               required by the Agency following review.

               3.  EPA requirements regarding the reporting of data, including
               the manner of reporting, the completeness of results, and the
               adequacy of any required supporting (or raw) data, including,
               but not limited to, requirements referenced or included in this
               Notice or contained in PR 86-5.  All studies must be submitted
               in the form of a final reporti a preliminary report will not be
               considered to fulfill the submission requirement.

            JV-C  EXISTING STOCKS OF SUSPENDED OR CAJFgSIiIfFp PRODUCTS
                - .->
               EPA has statutory authority to permit continued sale,
            distribution and use of existing stocks of a pesticide product
            which has been suspended or cancelled if doing so would be
            consistent with the purposes of the Act.

               The Agency has determined that such disposition by registrants
            of existing stocks for a suspended registration when a section
            3(c)(2)(B) data request is outstanding would generally not be
            consistent with the Act's purposes.  Accordingly, the Agency
            anticipates granting registrants permission to sell, distribute, or
            use existing stocks of suspended product(s) only in exceptional
            circumstances.  If you believe such disposition of existing stocks
            of your product(s) which may be suspended for failure to comply
            with this Notice should be permitted, you have the burden of
            clearly demonstrating to EPA that granting such permission would be
            consistent with the Act. You must also explain why an "existing
            stocks" provision is necessary, including a statement of the
            quantity of existing stocks and your estimate of the time required
            for their sale, distribution, and use.  Unless you meet this burden
            the Agency will not consider any request pertaining to the
            continued sale, distribution, or use of your existing stocks after
            suspension.

               If you request a-voluntary cancellation of your product(s) as a
            response to this Notice and your product is in full compliance with

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                                 13

all Agency requirements, you vill have, under most circumstances,
on« year from the date .your 90 day response to this Notice is .due,
to Mil, distribute, or use existing stocks.  Normally, the Agency
vill allow persons other than the registrant such a» independent
distributors # retailers and end users to sell, distribute or use
such existing stocks until the stocks are exhausted.  Any sale,
distribution or use of stocks of voluntarily cancelled products
containing an active ingredient for which the Agency has particular
risk concerns vill be determined on a case-by-case basis.
  .  Requests for voluntary cancellation received Af&lE the 90 day
response period required by .this notice vill not result in the
Agency granting any additional time to sell, distribute, or use
existing stocks beyond a year from the date the 90 day response was
due unless you demonstrate to the Agency that you are in full
compliance with all Agency requirements, Including the requirements
of this Notice.  For example, if you decide to voluntarily cancel
your registration six months before a 3 year study is scheduled to
be submitted, all progress reports and other information necessary
to establish that you have been conducting the study in an
acceptable and good faith manner must have been submitted to the
Agency, before EPA vill consider granting an existing stocks
provision.


SECTION V.  REGISTRANTS* OBLIGATION TO REPORT
                         ADVERSE EFFECTS
    Registrants are reminded that FIFRA section 6 (a) (2) states that
if at any time after a pesticide is registered a registrant has
additional factual information regarding unreasonable adverse
effects on the environment by the pesticide, the registrant shall
submit the Information to the Agency.  Registrants must notify the
Agency of any factual information they have, from whatever source,
including but not limited to interim or preliminary results of
studies, regarding unreasonable adverse effects on man or the
environment.  This requirement continues as long as the products
are registered by the Agency.


SECTION VI.  INQUIRIES AND RESPONSES TO THIS NOTICE

    If you have any questions regarding the requirements and
procedures established by this Notice, call the contact person (s)
listed in Attachment A, the Data Call-In Chemical Status Sheet.

    All responses to this Notice (other than voluntary cancellation
requests) must Include a completed Data Call -In Response Form and a
completed Requirements Status apd Registrant's Response Form
(Attachment B and Attachment C) and any other documents required by
this Notice, and should be submitted to the contact person (s)
identified in Attachment A. If the voluntary cancellation option is
chosen, only the Pata Call-in Respqnse Form need be submitted.

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                                14

    The Offie* of Compliance Monitoring (OCM)  of the Office of
Pesticides and Toxic Substances (OPTS), EPA, will be monitoring the
data being generated in response to this Notice.
                             Sincerely yours.
    *
    B
    C
    £
    F
    6
                    Daniel N. Barolo, Director
                  . • Special Review and
                      Reregistration Division

               Attachments

Data Call-In Chemical Status Sheet
Data Call-InResponse Form
Requirements Status and Feqriytrant * s Response Form
EPA Grouping of End-Use Products for Meeting Acute
Toxicology Data Requirements for Reregistration
1PA Acceptance Criteria
List of Registrants Receiving This Notice
Cost Share and Data Compensation Forms, and Product
Specific Data Report Form

-------
           ATTACHMENT A



DATA CALL-IN CHEMICAL STATUS SHEET

-------
                           ATTACHMENT A

       ALLIUM SATIVTJM;  DATA CALL-IN CHEMICAL STATUS SHEET
INTRODUCTION

     You have been sent this Data Call-in Notice because you have
products containing Allium sativuiiu

     This  attachment,  the  Data Call-in  Chemical  Status  Sheet.
contains a point of contact for inquiries.  This attachment is to
be  used in  conjunction  with  (1)  the  Data Call-in  Notice.   (2)
Attachment B, the Data Call-in Response Form. (3) Attachment C, the
Requirement  Status andRegistrant's Response  Form  for product
specific data, (4)  Attachment D, EPA Grouping of End-Use Products
for Meeting Acute Toxicology Data Requirements for Rereqistration,
(5) Attachment E, EPA Acceptance Criteria,  (6) Attachment F, List
of  All Registrantfs)  sent this   Data  Call-in  Notice,  and   (7)
Attachment  G,  the  Cost  Share  and  Data  Compensation Forms  for
product specific data, and  Product Specific Data Report  Form for
use in replying to  this All JUKI sativum Data  Call-in.  Instructions
and guidance accompany each form.


DATA REQUIRED BY THIS NOTICE

     The  additional data  requirements  needed  to complete  the
database for Allium sativuro are listed in the Requirements Status
and Registrant's Response Form.  Attachment  C.

     The Agency has concluded that product specific data are needed
for Allium  sativum.   The required additional data are listed in
Attachment C.

     Depending  on  the results  of the  studies  required  in this
Notice, additional testing may be required.


INQUIRES AND RESPONSES TO THIS NOTICE

     If you have any questions regarding the product specific data
requirements  and procedures established  by this  Notice,  please
contact Rob Forrest at  (703)  305-6600.   All responses  to this
Notice should be submitted to:

          Document Processing Desk (RED/RD/PM-14)
          Office of Pesticide Programs
          U.S. Environmental Protection Agency
          401 M Street S.W.
          Washington, D.C.  20460

          RE:  Allium sativum

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     If  you-  have  any  questions  regarding  the  generic  data
requirements and  procedures established  by this Notice,  please
contact Margarita Collantes at  (703)  308-8583.   All responses to
this Notice should be submitted to:


          Chemical Review Manager Margarita Collantes
          Accelerated Reregistration Branch (H7508W)
          Special Review and Reregistration Division
          Office of Pesticide Programs
          U.S.  Environmental Protection Agency
          401 M Street S.W.
          Washington, D.C.  20460


          RE:  Allium sativum

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I
                                      ATTACHMENT B



                      PRODUCT SPECIFIC DATA vALL-IN RESPONSE FORM

-------
i
         § „ «.
                           SPECIFIC INSTRUCTIONS FOR COMPLETING
                               TUB DATA CALL-IN  RESPONSE FORM

                                   product gpeeif-fe Pat*


                  This font is designed to be need to respond to call-ins for
             generic and product specific data for the purpose of
             reregistering pesticides under the Federal insecticide Fungicide
             and Rodenticide Act.  Fill out this font each time you are
             responding to a data call-in for which EPA has sent you the fora
             entitled "Requirements Status and Registrant's Response.*1

                  Items 1-4 will have been preprinted on the form.  Items 5
             through 7 must be completed by the registrant as appropriate.
             Items 8 through 11 must be completed by the registrant before
             submitting a response to the Agency.

                  Public reporting burden for this collection of information
             is estimated to average IS minutes per response, including time
             for reviewing instructions, searching existing data sources,
             gathering and maintaining the data needed, and completing and
             reviewing the collection of information.  Send comments regarding
             the burden estimate or any other aspect of this collection of
             information, including suggesting for reducing this burden, to
             Chief, Information Policy"Branch, PM-223, U.S. Environmental
             Protection Agency, 401 M St., S.w., Washington, D.C. 20460; and
             to the Office of Management and Budget, Paperwork Reduction
             Project 2070-0107, Washington, D.C. 20503.

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f
              INSTRUCTIONS FOR COMPUTING THE "DAtA CALL-IN RESPONSE" FORM FOR
              PRODUCT SPECIFIC DATA

              Item 1-4. Already completed by EPA.

              Item 5.   If you wish to voluntarily cancel your product, answer
                       "yes." If you choose this option, you will not have to
                       provide the data required by the Data Call-In Notice
                       and you will not have to complete any other forms.
                       Further sale and distribution of your product after the
                       effective date of cancellation must be in accordance
                       with the Existing Stocks provision of the Data Call-in
                       Notice (Section IV-C).

              Item 6.   Not applicable since this fora calls in product
                       specific data only.  However, If your product Is
                       identical to another product and you qualify for a data
                       exemption, you must respond with "yes*1 to Item 7a  (MP)
                       or 7b  (EP) on this form, provide the EPA registration
                       numbers of your source(s) and complete and submit the
                       "Generic Data Exemption*1 form; you would not complete
                       the "Requirements Status and Registrant's Response"
                       form.  Examples of such products include repackaged
                       products and Special Local Needs (Section 24c) products
                       which  are identical to federally registered products.

              Item 7a.  For each manufacturing use product (HP) for which you
                       wish to maintain registration, you must agree to.
                       satisfy the data requirements by-responding "yes."

              Item ?b.  For each end use product (EP) for which you wish to
                       maintain registration, you must agree to satisfy the
                       data requirements by responding "yes."  If you are
                 -     requesting a data waiver, answer "yes" here; in
                       addition, on the "Requirements Status and Registrant's
                       Response" form under Item 9, you must respond with
                       Option 7 (Waiver Request) for each study for which you
                       are requesting a waiver.  See Item 6 with regard to
                       identical products and data exemptions.

              Items 8-11.  Self-explanatory.

              H22SS     You may provide additional information that does not
                       fit on this form In a signed letter that accompanies
                       this form.  For example, you may wish to report that
                       your product has already been transferred to another
                       company or that you have already voluntarily cancelled
                       this product.  For these cases, please supply all
                       relevant details so that EPA can ensure that Its
                       records are correct.                . ,           •

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DRAFT  COPY
Page  1 of
United States Environmental Protection Agency Form Approved
Washington, D. C. 20460 OHB NO. 2070-0107
DATA CALL-IN RESPONSE
Approval Expires 12-31-92
INSTRUCTIONS: Please type or print in ink. Please read carefully the attached instructions and supply the information requested on this form.
Use additional sheet(s) if necessary, • '
1. Company name and Address 2. Case # and Name 3, Date and Type of BC1
SAMPLE COMPANY 4007 Alliuni sativum PRODUCT SPECIFIC
MO STREET ADDRESS
NO CITY, XX 00000
4. EPA Product
Registration
6 2998- 1
5. I wish to
cancel this
product regis-
tration volun-
tarily.

6. Generic Data
6a. 1 am claiming a Generic
Data Exemption because I
obtain the active ingredient
from the source EPA regis-
tration number listed below.
N.A.

6b. I agree to satisfy Generic
Data requirements as indicated
on the attached form entitled
"Requirements Status and
Registrant's Response."
N.A.
7. Product Specific Data
7a. My product is a HUP and
I agree to satisfy the HUP
requirements on the attached
form entitled "Requirements
Status and Registrant's
Response."


7b. My product is an EUP and
I agree to satisfy the EUP
requirements on the. attached
form entitled "Requirements
Status and Registrant's
Response,"

8. Certification 9. Date
I certify that the statements made on this form and all attachments are true, accurate, and complete.
I acknowledge that any knowingly false or misleading statement may be punishable by fine, imprisonment
or both under applicable lay.
* i ' • ' i
Signature and Title of Company's Authorized Representative
10. Name of Company Contact 11. Phone Number

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          DRAFT    COPY
                                                                                                             Page    1  of
                            United States  Environmental  Protection Agency
                                              Washington,  D. C.  20460

                                              DATA CALL-IN  RESPONSE
                                                                                                          Form Approved

                                                                                                          OMB No. 2070-0107

                                                                                                          Approval Expires 12-31-92
INSTRUCTIONS:  Please type or print in ink.  Please read carefully the attached instructions and supply the information requested on this form.
Use additional sheet(s) if necessary.
1,  Company name and Address
   SAMPLE COMPANY
   NO  STREET  ADDRESS
   NO  CITY,    XX   00000
                                      2.  Case # and Name
                                         4007   Allium  sativum
                                                                              3. Date and Type of DCI
                                                                                PRODUCT SPECIFIC
4. EPA Product
Registration
5. I wish to
cancel this
product regis-
tration volun-
tari ly.
6.  Generic Data
                                     6a.  I am claiming a Generic
                                     Data Exemption because  I
                                     obtain the active ingredient
                                     from the source EPA regis-
                                     tration number listed below.
                             6b. I agree to satisfy Generic
                             Data requirements as indicated
                             on the attached form entitled
                             "Requirements Status and
                             Registrant's Response,"
7, Product Specific Data
7a. My product is a NUP and
I  agree to satisfy the MUP
requirements on the attached
form entitled "Requirements
Status and Registrant's
Response,"
?b. My product is an EUP and
I  agree to satisfy the EUP
requirements on the attached
form entitled "Requirements
Status and Registrant's
Response."
47319-4
47319-2
                                            N.A.
                                                 N.A.
8. Certification
1 certify that the statements made on this form and all attachments are true, accurate,  and complete.
I acknowledge that any knowingly false or misleading statement may be punishable by fine,  imprisonment
or both under applicable law.

Signature and Title of Company's Authorized Representative	
                                                                                         9.  Date
10.  Name of Company Contact
                                                                                         11. Phone Number

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                           ATTACHMENT C




PRODUCT SPECIFIC REQUIREMENT STATUS AND REGISTRANT'S RESPONSE FORM

-------
               •ticzrie INSTRUCTIONS roil COM*LZTIMO
      TKl llQQllZXtireA STATUS XKD IBOXITIIMT'* &E8POHSB VOKX

                        roduct
      This form i« designed to b* used for registrant* to respond
,to call-in* for generic and product-specific data as part of
 EPA's reregistratien program under th* Federal Insecticide
 Fungicide and Rodenticide Act.  Although the fern is the same for
 both product specif ic and generic data, instructions for
 completing the forms differ slightly.  Specifically/ options for
 satisfying product specif ic data requirements do not include (1)
 deletion of uses or  (2) request for a lev volume/minor use
 waiver.   These Instructions are for completion of product
 specific dg^a requirements.
      EPA has developed this  fora individually for each data call-
 in addressed to  each  registrant,  and has preprinted this form
 with a  number of items.   PQ  NOT  use this form for any other
 active  ingredient.

      Items  1 through  • (inclusive) will have been preprinted on
 the form.   You must complete all other itlms on this form by
 typing  or printing  legibly.

     ' Public reporting burden for this  collection of information
 is estimated to  average  30 minutes per response, including tine
 for reviewing instructions,  searching  existing data sources,
 gathering and maintaining the data needed,  and completing and
 reviewing the collection of  information.  Send comments regarding
 the burden  estimate or any other aspect of  this collection of
 information,  including suggesting for  reducing this burden, to
 Chief,  Information  Policy Branch, PM-223, U.S. Environmental
 Protection  Agency,  401 M St., S.w., Washington, D.C. 20460; and
 to the  Office of Management  and  Budget, Paperwork Reduction
 Project 2070-0107,  Washington, D.C. 20503.

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i
                  INSTRUCTZOHS   fOR  COMPLETING  THE   "1EQOIREMENTS   STATUS  AND
                  REGISTRANT'S RESPONSE" FORM FOR PRODOCT SPECIFIC
           Itea 1-3  Completed by EPA.   Vote the unique  identifier  number
                     assigned by EPA in Item 3.  This number must fee uaed in
                     the transmittal document  for  anj data  subaisaiona  in
V_                   response to this Data Call-In Notice.

           Item 4.   The guideline reference numbers of studies required to
                     support  the   product's   continued   registration  ara
                     identified.    These  guidelines,  in  addition  to  tha
                     requirements specified in the Notice,  govern the conduct
                     of the required studies.   Note  that series  61 and 62 in
                     product chemistry are new listed  under  40 CFR 158.155
                     through 158.180, subpart C.

           Ztea S.   The study title associated with the guideline reference
                     number is identified.

           Itam €*   The use pattern(a)  of the  pesticide as«ociatad with tha
                     product specific requirements is (are) identified.  For
.*!              .     most product specific data  requirements, all use patterns
                     are covered by th* data requirement*.   In the case of
                     efficacy data,  the  required  studies?- only pertain to
                     products which have the use sites and/or pests indicated.

           Ztea 7.   The substance to be  tested is  identified by EPA.  For
                     product specific data, the product as formulated for sale
                     and distribution is the test substance, except in rare
                     cases.

           Ztea t.   Th* due date for submission of each study is identified.
                     Zt is  normally based on •  month*, after  iaauance  of the
~| ,           •        Feregiatration Eligibility Document unless EPA .determines
                     that a longer tine period  is necessary.

           Ztea 9.   later  only one of  the following response codes  for each
                     flafa_	requirement to ahow how you intend to eoaply with
                     the data requirements listed  in this  table*    Fuller
                  '-   descriptions of each option ar* contained in the  Data
                     Call-In Notice.

                1.   Z will generate and submit data by the specified due date
                     (Developing Data).  By indicating that Z have chosen this
                     option,  Z  certify  that  Z will  eoaply with  all  the
                     requirements pertaining to the conditions for submittal
                     of this study as outlined in the Data Call-In Notice.
•*»
                2*   Z have  entered  into an   agreement  with  one  or  more
                     registrants to develop data jointly  (Cost Sharing).  I
                     aa submitting a copy of this agreement  and a completed
                     "Certification  With Respect  To   Data  Compensation
                     Requirements" fora.  Z  understand that  this  option is
                     available only  for acute  toxiclty or certain efficary
       •8

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                     data and only if IPX indicates in an attachment to this
                     Notice  that my product  is similar  enough to anothtr
                     product  to qualify for  this  option.   X certify that
                     anothar party in tha agreement is committing to submit
                     or  provida tha required  data; if tha required study is
 ;              •     not submitted  on time,  my product  may ba subject to
 / - '•               suspension.

                i*   1 hava made offars to shara in tha cost to davalop data
                     (Offers to Cost ihara).   I understand that this  option
                     is  available only for acute toxicity or certain efficacy
                     data and only if EPA indicates in an attachment to this
                     Data Call-in Notice that ay product is similar enough to
                     another  product to qualify  for this  option.    I aa
                     submitting evidence that Z have Bade  aa offer to another
                     registrant (who  has an  obligation  to submit data) to
 v                   share in the cost of that data.  Z am also-submitting  a
                     completed  "Certification of Offer to Cost Share  in  the
                     Development Data1*  form.    Z am  including * copy of cy
 -                    offer and proof of the other registrant's receipt of that
                     offer.  Z  em identifying the  party which is committing
                     to  submit  ;*r provide the required data; if the. required
                     study '.- not submitted on time, my product may be subject
                     to  suspension.    Z understand that ether  terms  under
                     Option 3 in the Data Call-in  notice (Section III-c.l.)
                     apply as veil.

 ;              4.   By  the  specified due date, Z will  submit an existing
                     study that has net been  submitted previously to  the
                     Agency  by anyone  (Submitting aa Existing Study).    I
                     certify that this  study  vill  meet all the requireaents
                     for submittal of existing d*f-*  outlined in Option 4 in
&                   the Data Call-In Notice (Section III-C.l.) and vill seat
                     the attached acceptance, criteria (for acute toxicity and
                     product  chemistry  data).   Z vill  attach the  needed
                     supporting information along with this response.  I also
                     certify that Z have determined that this study vill fill
                     the data  requirement for which Z have indicated this
                     choice.

                5*   By  the specified due date, Z vill submit or cite data to
                     upgrade a  study classified by tha  Agency as partially
                     acceptable and upgradable (Upgrading a Study).   Z will
                     submit evidence ef the Agency's reviev  indicating that
                     the study  may  be upgraded  and  what  information  is
 '-.                    required to do so.  Z will provide the MRXD or Accession
%                   number of  the study at the due date.   Z understand that
 •                    the conditions for  this  option outlined Option 5 in the
                     Data Call-In Notice (Section  III-c.l.)  apply.

                §.   By  the specified due date, Z vill cite an existing study
                     that  the  Agency  has  classified  as acceptable  or ar.
                     •xisting study that has  been  submitted but net reviev«i
                     by the Agency (Citing an Existing Study). Zf Z am citir.z

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          another registrant's study, Z understand that this option
          is available only for acute toxicity or certain efficacy
          data  and only if the cited study  was conducted on ay
          product, an identical product or a product which  EPA has
          "grouped" with one  or acre other products  for purposes
          of depending on the came data.  I nay also choose this
          option if I  am  citing ay own  data.  Zn either case, I
          will  provide the NXIO or  accession auaberU) for the
          cited data on a  "Product Specific Data Report*  fora or
          in a  similar format.   If  Z cite another  registrant'*
          data,  Z  will  submit  a  completed  "Certification with
          lespaet To Data Compensation Requirements" fora.

     7.   Z  request  a waiver  for  this  study  because  it   is
          inappropriate for ay  product  (Waiver Request).   I  an
          attaching a  complete justification  for this request,
          including technical reasons,  data  and  references  to
          relevant EPA regulations, guidelines or policies.  [Note:
          any supplemental  data must be submitted in the format
          required by P.R.  Notice t€~S|.  Z  understand  that this
          is my only opportunity to  state the reasons or  provide
          information  in  support  of my.request.   If the Agency
     •  '"   approves ay  waiver request, X; will not be required to
          supply the data pursuant to Section 3(c)(2) (B)  of FIFRA.
          Zf the Agency denies ay waiver request,  Z must choose a
          method of meeting the data requirements  of this notice
          by the due date stated by this Notice.  Zn this ease, I
          aust,  within 30  days  of  ay  receipt of  the Agency's
          written decision, submit a revised "Requirements Status
          and Registrant's  Response11 Fora indicating the option
          chosen.   1  also  understand  that  the  deadline  for
          submission of  data as specified  by the  original  data
          call-in notice will not change.

Items 10*13.  Self-explanatory.                         *

          You may provide additional  information that does not fit
          on this  font in a signed  letter that accompanies  this
          fora.  For  example, you aay  wish to report  that  your
          product has already been transferred to another company
       -  or that  you  have already voluntarily cancelled  this
          product.   For these cases, pleas*  supply all relevant
          detail*  00  that  EPA  can ensure  that its records  are
          correct.

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DRAFT  COPY
Page  1 of  2
United States Environmental Protection Agency
Washington, D. C. 20460
REQUIREMENTS STATUS AND REGISTRANT'S RESPONSE
INSTRUCTIONS: Please type or print in ink. Please read carefully
Use additional sheet(s) if necessary.
1. Company name and Address
SAMPLE COMPANY
NO STREET ADDRESS
NO CITY, XX 00000
4. Guideline
Requirement
Number



151B-10
151B-11
151B-12

151B-15
151B-16
151B-17(b)
151B-17(f)
151B-17(i)
151B-17{ltt)

152B-13
152B-14
the attached instructions and supply the information requested on this form.

2. Case # and Name 3. Date and
Form Approved
OMB No. 2070-0107
Approval Expires 12-31-92


Type of OCI
4007 Alliurn sativum PRODUCT SPECIFIC
ID# NNNNNN-RD-NNNN
EPA Reg. No. NNNNNN-NNNNN
5. Study Title
Prod Chan - Biochemical
Product identity
Manufacturing process (50}
Discussion of formation of (51)
unintentional ingrdients
Certification of limits
Analytical methods (52)
Physical state
Density
pH (6)
Viscosity (8)
Acute Toxic -Biochemical
Primary eye irritation (53)
Primary dermal irritation (53)
10. Certification














R
0


0
I














Progress
Reports


1
















2
















3















6. Use
Pattern




ABC O
ABC 0
ABC 0

ABC O
ABC O
ABC O
ABC 0
ABC O
ABC O

ABC O
ABC 0
7. Test
Substance




EP
EP
EP

EP
IP
EP
EP
EP
EP

EP
EP

8, Time
Frame








8 mos.
8 »OS.
8 mos.


8 mos.
8 mos.
8 mos.
8 mos.
8 mos.
8 mos.


8 mos.
8 mos.
11. Date
9. Registrant
Response


















1 certify that the statements made on this form and all attachments are true, accurate, and complete.
1 acknowledge that any knowingly false or misleading statement may be punishable by fine, imprisonment
or both under applicable law.
Signature and Title of Company's Authorized Representative
12. Name of Company Contact


13. Phone Number




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DRAFT
O P Y
Page  2 of  2
United States Environmental Protection Agency
Washington, D. C, 20460
REQUIREMENTS STATUS AND REGISTRANT'S RESPONSE
INSTRUCTIONS; Please type or print in ink. Please read carefully
Use additional sheet(s) if necessary.
1 . Company name and Address
SAMPLE COMPANY
NO STREET ADDRESS
NO CITY, XX 00000
4. Guideline
Requi retnent
Number
96-6
5. Study Title
!ifMca^:5-5^t^a^:c^tFSl;;*aeWs:-::^^
Avian repellents (1,54)
the attached instructions and supply the information requested
2. Case i and Name
4007 Allium sativum
EPA Reg. No. NNNNNN-NNNNN


R
0
0

Progress
Reports
1

2

3

6. Use
Pattern
ABC
Initial to indicate certification as to information on this page
(full text of certification is on page one).
0
7. Test
Substance
on this form.
Form Approved
OMB No. 2070-0107
Approval Expires 12-31-92

3. Date and Type of DCI
PRODUCT SPECIFIC
ID# NNNNNN-RD-NNNN

EP
8. Time
Frame
8 BIOS.
9. Registrant
Response

Date

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           DRAFT   COPY                                                                                     	        Page   1  of   1
                                          United  States  Environmental Protection Agency
                                                           Washington,   D.  C.  20460
                                  FOOTNOTES  AND KEY  DEFINATIONS  FOR GUIDELINE  REQUIREMENTS
                                                Case # and Name:   4007    Allium sativum
Key: MP = manufacturing-use product;  EP = end-use product; provided formulators  purchase their active ingredient(s) from a registered  source, they need not submit or cite
data pertaining to the purchased product.[NOTE: If a product is a 100 percent repackage of another registered product that is purchased, and any use for the product does
not differ from those of the purchased and registered source, users are not subject to any data requirements identified in the tables.]; TEP = typical end-use product;
TGAI = technical grade of the active  ingredient; PAl = "pure" active ingredient; PAIRA = "pure" active ingredient, radiotabeled.
Use Categories Key:
  A - Terrestrial food crop        B  - Terrestrial food feed crop    C - Terrestrial nonfood crop     D - Aquatic food crop           E - Aquatic nonfood outdoor
  F - Aquatic nonfood Industrial   G  - Aquatic nonfood residential    H - Greenhouse food crop         I - Greenhouse nonfood crop     J - Forestry
  K - Residential outdoor         L  - Indoor food                  H - Indoor nonfood              N - Indoor Medical              0 - Indoor residential

Footnotes:  [The following notes are referenced in column two (5. Study Title) of the REQUIREMENTS STATUS AND REGISTRANT'S RESPONSE form.]


Prod Chea - Biochemical

 6  Required if test substance is dispersible with water.
 8  Required if product is a liquid.
S"0
£i
Acute Toxic - Biochemical
f3


Efficacy - Vertebrate Control Agents

 1  The agency has waived all requirements to submit efficacy data  for vertebrate control agents unless the pesticide product bears a  claim to control vertebrates (such
    as rodents, birds, bats, canids,  and  skunks) that may directly or indirectly transmit diseases to humans.  However, each registrant must ensure through testing that
    his products are efficacious when used in accordance with label directions and commenly accepted pest control practices.  The registrant must develop and maintain
    the relevant data upon which the  determination of efficacy is based.  The Agency reserves the right to require, on a case-by-case  basis (e.g., significant new uses
    or benefits data in cases of special  reviews) submission of efficacy data for any pesticide product, registered or proposed for registration when necessary.

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                  Footnotes for Garlic Product Specific Data Tables   (6/10/92)

    description of the manufacturing process must include the steps taken to insure the integrity
of the starting materials and to limit extraneous contamination during manufacturing.  Also, the
description must include the quality control methods used to insure a uniform product.
    applicant must provide a discussion of the unintentional ingredients that may be present in the
product and why they may be present.  Examples of such ingredients might include residues of
contaminants that remain following the extraction or purification process.  If these contaminants
are not of toxicological significance (e.g., small quantities of dirt retained on garlic bulbs
after washing) , there is no need for further discussion.
    Agency recognizes the difficulty of establishing methods for analysis and verification of the
certified limits of naturally occurring products.  Such methods could include analytical, bio-assay,
microscopic, or any other method that would allow the Agency to verify the limits.
      tests are required for products that combine garlic and red peper (Capsaicin) .  They are not
required for products that contain only garlic,
    data currently available to the Agency on the effectiveness of these products as bird repellents
are either inconclusive or have suggested a lack of effectiveness.  Therefore, registrants of
bird control products must establish those claims during reregistration through citation or
submission of data.  If registrants develop new data, they must submit their protocols to the
Agency with the 90 day response.

If tests suggest that efficacy is highly variable, the registrant will need to develop methods
for quantifying the biological activity of the active ingredients so that consistent results can
be obtained.

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i
                                     ATTACHMENT D

                     EPA GROUPING OF END-US.* PRODUCTS FOR MEETING
                         DATA REQUIREMENTS FOR REREGISTRATION

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EPA'S BATCHING OF MUUM SMTVUM  (GARLIC) HMD-USE ERDDUCTS FOR MEETING ACUTE
•DOXICHY DATA KECJUIKEMEmS FOR REREGZS'mATION

     In an effort to reduce the time,  resources and number of animals needed to
fulfill the acute toxicity data requirements for reregistration  of end-use
products containing the active ingredient Alliumjsativum (Garlic)» the Agency has
batched products which can be considered similar for purposes of acute toxicity.
Factors considered in the sorting process include each product's active and inert
ingredients  (identity, percent composition and biological  activity),  type of
formulation (e.g.,  emilsifiable concentrate, aerosol, wettable powder, granular,
etc.),  and labeling  (e.g.,  signal word,  use classification,  precautionary
labeling, etc.).   Note that the Agency  is  not describing batched products as
"substantially similar" since some products within a batch may not be considered
chemically similar or have identical use patterns.

     Batching has  been accomplished  using the readily  available information
described  above,  and  frequently acute  toxicity data  on  individual  end-use
products has been found to be incomplete. Notwithstanding the batching process,
the Agency reserves the right to require, at any time, acute toxicity data for
an individual end-use product should the need arise.

      Registrants of end-use products within a batch nay choose to cooperatively
generate, submit or cite a single battery of six acute toxicological studies to
represent all the products within that batch. It is the registrants' option to
participate in the process with all other  registrants,  only seme of the other
registrants, or only their own products within a batch, or to generate all the
required acute  toxicological studies  for  each of  their own  products.   If a
registrant chooses to generate the data for a batch, he/she must  use one of the
products within the batch as the test material.  If a registrant chooses to rely
upon previously submitted acute toxicity data, he/she may do so provided that the
data base is complete  and valid by today's standards (see acceptance criteria
attached), the formulation tested is considered by EPA to be similar for acute
toxicity, and the formulation has not been significantly altered since submission
and acceptance of the acute toxicity data.

     In deciding how to meet the product specific data requirements, registrants
must follow the directions given in the Data Call-in Notice and its attachments
appended to the RED.  Ihe DCI Notice contains two response forms which are to be
completed and submitted to the Agency within 90  days of receipt.  The first form,
"Data  Call-in Response," asks  whether the   registrant will  meet the  data
requirements  for each product.   The second  form, "Requirements  Status and
Registrant's  Response,"   lists  the product specific data  required  for  each
product, including the standard six  acute  toxicity tests.  A  registrant who
wishes to participate in a batch must: decide whether he/she will provide the data
or depend on someone  else to do so.  If a registrant supplies the data to support
a batch of products,  he/she must select one of the following options: Developing
Data (Option 1), Submitting an Existing Study  (Option 4), Upgrading an Existing
Study (Option 5)  or Citing an Existing Study (Option 6).  If a registrant depends
on another's data,  he/she must choose among: Cost Sharing (Option 2), Offers to
Cost Share  (Option 3)  or  Citing an  Existing Study (Option 6).  If a registrant
does not want to participate in a batch,  the choices are  Options  1,  4, 5 or 6.
However, a registrant  should know that choosing not to participate in a batch
does not preclude other registrants  in the batch from citing his/her studies and
offering to cost share (Option 3) those studies.

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i
                                                    -2-

                    Table  I shows  one batch  which of  two products.   Table II  shows the
              remaining two products which could not be batched as they were not considered
              similar for purposes of acute toxicity.  The  registrants of these products are
              responsible  for meeting the acute toxicity data requirements specified in the
              data matrix  for end-use products.
              Table I.
EPA REG. NO.
47319-1
47319-2
% of Garlic & Other Active Ingredients
5.0% -
12.0% -
5.0% -
12.0% -
Garlic
Red Pepper
Garlic
Red Pepper
Formulation Type
Dust
Dust
              Table II.
EPA REG. NO.
47319-4
62998-1
% of Garlic & Other Active Ingredients
24.0% - Garlic
36.0% - Red Pepper
5.0% - Garlic
Formulation Type
Liquid
Liquid

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i
                                     ATTACHMENT E
                                              *

                               EPA ACCEPTANCE CRITERIA

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i
*<•
                                                        SUBDIVISION D


                    61 Product Identity and Composition  	«...	  4
                    62 Analysis aad Certification of Product Injredient*	  6
                    & Physical and Chemical Chancteristia	..	  8

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I
                                                                                                      Subdivision D
                                                                                               Guideline Ret No. 61
                                                                                                  December 24,1989


                                                   €1 Product Identity and Qoapoaftfoa .

                                                       ACCEPTANCE CRITERIA

                     Doei jour staff meet the following acceptance criteria?

                     , 1- —   Name of technical material tested (include product name and trade name, if appropriate)
                     ' 2-  _     Name, nominal concentration, and certified limits (upper and lower) for each active
                               ingredient and each intentionally-added inert Ingredient
                      3. __   Name and upper certified limit for each impurity or each group of tapurities present at %
                               0,1% by weight and for certain toricoIogicaUy significant impurities (e.g^ dtadns,
                               nitrosamines) present at <0tl%
                      *• —   Purpose of each active Ingredient and each intentionally-added inert
                      & —   Chemical name from Chemical Abstracts Index of Nomenclature and Chemical Abstracts
                               Service (CAS) Registry Number for each active ingredient and, if available, for each
                               intentionally-added inert
                      & ,  ..   Molecular, structural, and empirical formulas, molecular weight or weight range, and any
                               company assiped experimental or internal code numbers for each active ingredient
                      ?. ___   Description of each beginning material in the manufacturing process
                                __  EPA Registration Number if registered; for othe. beginning materials, the following:
                                .     Name and address of manufacturer or supplier
                                _  Brand name, trade name or commercial designation
                                __  Technical specifications or data sheets by which manufacturer or supplier describes
                                      composition, properties or toriciry
                      8. __jr   Description of manufacturing process
                       ; • *     ___  Statement of whether batch or continuous process
                                __  Relative amounts of beginning materials and order in which they are added
                                ___  Description of equipment
                                  .,    Description of physical conditions  (temperature, pressure, humidity) controlled in
                                      each step and the parameters that are maintained
                                _  Statement of whether process involves intended chemical reactions
                                __  Flow chart with chemical equations for each intended chemical reaction
                                _J::I  Duration of each step of process
                                  ,.  Description of purification procedures
                                  mi  Description of measures taken to assure quality of final product
                      9- _   Discussion of formation of Impurities eased on established chemical theory addressing (I)
                               each Impurity which may be present at i 0.1% or was found at I 0.1% by product analyse*
                               and (2) certain toodcoJogicaUy significant impurities (see if 3)
                     Criteria marked with a * are supplemental and nay not be required for every study.

                                                                   C4

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                                                                                              D
                                                                            Guideline Ret No. 61
                                                                               December 24,1989


                                61 Product Identity and GomposttioB

                           GUIDANCE FDR SUMMARIZING STUDIES


• The following criteria tpply to the technical grade of the active Ingredient being reregistered. Items 1,
 2,3, and 5 an be satisfied tor mott registered product* by submission of the Certified Statement of
 Formula Ingredients Page (EPA Form 8570-4),  Items 7 and 8 can be satisfied for most technical grade
 active ingredients (TGAls) by submission of a flow chart with chemical equations for each intended
 chemical reaction.  The flow chart should include complete chemical structure* and names for each
 reactant and product of all the reactions.

 Items  in summary should indode the hens discussed ID Chapter 2 of this package and the specific hems
 fc'cd  below.

  1. Name  of technical material (include product name and trade name, If appropriate).
  2. Description of each active and intentionally-added inert  ingredient, including name, concentration,
    and certified limits.
  3. Name  and upper limit for all imparities present at 2 0.1% and those tcndcologically signih int
    impurities present at <0.1%.
  4. The purpose of each active and intentionaDy*addad inert ingredient.
  5. Chemical name and Registry Number for each active and intentionally-added inert ingredient (if
    available).
  £ Molecular, structural, and empirical  formulas, molecular weight, and any experimental or internal
    code number for each active Ingredient.
  ?. Description of each beginning material  In the manufacturing process.
  8. Description of manufacturing process.
  9. Discussion of formation of impurities based on established chemical theory.

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I
                                                                                                        Subdivision D
                                                                                                 Guideline Ret No. 62
                                                                                                    December 24,1989


                                             €2 Analysis and Certification of Product Ingredients

                                                        ACCEPTANCE CRITERIA

                     The following criteria apply to ibe technical grade of the active Ingredient being reregistered  U»e •
                     table to present the laforaatlon Is Items 6, 7, and &.

                     Does your study Beet the foOowing amfptance criteria?

                      1* —.   Five or more representative samples (batches In case of batch process) analyzed  for each
                               active Ingredient and ail impurities present at | 0.1%
                      2- __   Degree of accountability at closure | a 98%
                      3. __   Analyses conducted for certain trace toxic impurities at lower than 0.1% (examples,
                               nitrosamines In the ease of products containing dinitroanHines or containing secondary or
                               tertiary aminet/alkanoUmines pins nitrites; potyhalog*nated dibenzodioxtas and
                               dibenzofunns)  (Note that in the case of nitrosamines both fresh and stored samples must be
                               analyzed,]
                      4   ,    Complete and detailed description of each step In analytical method wed  to analyze above
                               samples
                      & .      Statement of precision and accuracy of analytics^ method used to analyze  above  samples
                      & ___   Identities and quantities (including mean and standard deviation) provided for each analyzed
                               ingredient
                      7-.-,     - Upper and lower certified limits proposed for each active ingredient and intentionally added
                               inert along with explanation of how the limits were determined
                      & —   Upper certified limit proposed for each impurity present at 2 0-1* and for certain
                               toxicologically significant impurities at <0.1% along with explanation of bow limit
                               determined
                      9.  r      Analytical methods to verity certified limits of each active ingredient and impurities (latter
                               not required if exempt from requirement of tolerance or if generally recognized  as safe by
                               FDA) are fully  described
                     10- —_   Analytical methods (as discussed in *9) to verify certified limits validated as to their
                               precision and accuracy
                     Criteria marked with a * are supplemental and may not be required for every study.

                                                                   C4

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                                                                                  Subdivision D
                                                                           Guideline Ret Ho. 62
                                                                              December 24,1989


                        G2 Analysil aad Certi&catiOB of Product Ingredients

                          GUIDANCE FOR SUMMARIZING STUDIES


 lie following criteria apply to the technical grade of die active ingredient bein| reregistered.
'*     : v
 Iionf in summary ihouJd tadnde the item discussed n Oupter 2 of tlife pectege aod the specific hems
 feted below.

  L Number of representative samples analyzed for an active Ingredients and an Imparities present at 2
    0.1%.

  2. Degree of accountability or dosore in analyse* In item #1.

 3. Chemical names of toxic impurities which were analyzed for levels <0.1%.

 4 Brief description^) of analytical method(») used to measure aative ingredients and impurities in
    Items *l and *3.

 5. Statement of precision and accuracy of method($) In Item #4.

 & Oiemfca! name and quantities observed (range, mean, standard deviation) for each ingredient
    (actives and impurities) analyzed in Item  #1.
   f. > •
 7. Proposed upper and lower  certified limits for each active ingredient and intentionally added inert
    with brief explanation of how  limits were determined.

 1. Proposed upper certified limit for each imparity present at >»0.1% and certain toxteologicalty
    significant impurities at <
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i
                                                                                                       Subdivision D
                                                                                                Guideline Ret No, 63
                                                                                                   December 24,1989


                                                  63 Physical and Qemieal Characterfctka

                                                        ACCEPTANCE CRITERIA

                     He following criierii apply to tbe technical frade of the active ingredient being reregistered.

                     Duet your study saect the following xrrpfiace criteria?
                                       i                   . - •
                     *W  Color
                                ___   Verbal description of coloration (or lack of It)
                                __   Any intentional coloration also reported la terms of Munsell color system

                     §3-3  Physical State
                                __   Verbal description of physical stale provided  using terms such as "solid, granular,
                                       volatile liquid'
                                __   £«ed on visual inspection at about 20»2fPC

                     B-4  Odor
                                _      Verbal description of odor (or Jack of ft) using terms such as •garUc&ke,
                                       characteristic of aromatic compounds'
                                	   Observed at room temperature

                     63-5  Melting Point
                                __   Reported in "C
                                __   Any observed decomposition reported

                     CM  Boiling Point
                                __   Reported In *C
                                ,   „    Pressure under which BJ». measured reported
                                ___   Any observed decomposition reported

                     63-7  Density, Bulk Density, Specific Gravity
                                __   Measured at about 20»2S*C
                                .„,     Density of lechnkal grade active ingredient reported in g/ml fit the apedfic gravity of
                                       liquids reported with reference to water at £fC [Note: Bulk density of registered
                                       products may be reported In Ibs/ft' or Ibs/gallon.]

                           Solubility
                                __   Determined in distilled water and representative polar and non-polar solvents,
                                       including those used in formulations and analytical methods for the pesticide
                                	   Measured at about 2£>2S*C
                                __   Reported in g/lOOml (other units like ppm acceptable  If sparingly soluble)
                     Ckteria marked with a * are supplemental and may not be required for every study.

                                                                   CS

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i
                                                                                                       Subdivision D
                                                                                                Guideline Ret No. £3
                                                                                                   December 24,1989


                      63-9  Vapor Pressure
                                 __   Measured at «2S*C (or calculated by extrapolation from measurements made at
                                       higher temperature if pressure too tow 10 measure at 2S*Q
                                 __   Experimental procedure described
                                 _   Reported in mm Hg (torr) or other conventional units


                      €3-10  Dissociation Constant
                                 __   Experimental method described
                                 __   Temperature of measurement specified (preferably about 20-2f*Q

                      13-11  Octanol/water Partition  Coefficient
                                 __   Measured at about 20»2S*C
                                 __   Experimentally determined and description of procedure provided (preferred method-
                                       45 Fed. Register 77350)                                     ^          .
                                 __   Data supporting reponed value provided

                      £3-12  pH
                                 _   Measured at about M-25*C
                                  _   Measured following dilution or dispersion in distilled water

                      £3-13  Stability
                                 __   Sensitivity to metal ions and metal determined
                                 .,	    Stability at  normal and elevated temperatures
                                 ___   Sensitivity to sunlight determined
                     Criteria marked with a * are supplemental and nay not be required for ever; study.

                                                                   C-9

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                                                                                    Subdivision D
                                                                            Guideline Ret No. 63
                                                                               December 24, 1989
                              €1 Physical and Chemical Characaeristia

                          GUIDANCE FOR SUMMARIZING STUDIES

tilt following criteria apply to ihe technical gride of the active Ingredient beinf reregistered.
Items in summary should include the items dhcBSfgtf |§ Chapter 2 of this package and the specific items
listed below.
                                        - m

 1.  Deseript ton of eotor.
 2.  Description of physical state.
 3.  Description of odor.
 4.  Indication of melting point (in *C).
 5.  Indication of boiling point (in *C).
 6.  Indication of density, bulk density, and specific gravity.
 ?.  Indication of solubility.
 8.  Indication of vapor pressure.
 9.  Indication of dissociation constant.
10.  Indication of ocunol/witer partition coefficient.
II.  Indication of pH.
12.  Description of stability.
                                              C-10

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                                    SUBDIVISION F
81-1 Acute Oral Toridry in the Rat	  84
81-2 Acute Dermal Toridty in the Rat, lUbbit or Guinea Pig	  86
81-3 Acute Inhalation Tbxidty in the Rat	  88
81-4 Primary Eye Irritation in die Rabbit	.......90
81-5 Primary Dermal Irritation Study	 *	.92
81-6 Dermal Seasiiization in the Guinea  Fig	• • •	94
81-7 Acute Neurotoxidty in the Hea	96
824 Subchronic Feeding fa the Rodent tad Nonrodent	  98
82*2 Repeated Dose Dermal Toridty (21-day) in die Rat, Rabbit or Guinea Pi|	 101
82*3 Repeated Dose Dermal Toridty (90-day) In die Rat, Rabbit or Guinea Kg	 103
82-4 Subchronk Inhalation Toridty (9CMlay) in the Rat	 106
82-5 Subchronic Neurotoxidty (904**) la the Hen	 109
83-1 Chronic Feeding in die Rodeat ace" Noarodent	 Ill
83-2 Oncogenidry in Rats or Mice	 114
83-3 Teratology Studies	 117
83-4 Reproduction	 119
83*5 Chronic Feeding/Oncogenidty is die Rat	 121
84-2 Mutageaidiy Studies	 124
854 Metabolism Studies		 127
                                          C83

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I
                                                                                                          Subdivision F
                                                                                                Guideline Ret NO. SM
                                                                                                              24, 1989
                                                      Sl-1 Ante On! Tmidty la the Hat

                                                          ACCEPTANCE CRITERIA

                       Does joor atodf BOM ike toflowtag acceptance criteria?

                        t _  Technical form of die active ingredient tested, (for reregistnitk>& only)
                        2.*       At least 5 young adult ratsAex/groop
                        3- ___  Doslaf, sickle oral may be administered oner 24 fen.
                        4*       Veh/de control If other tkam water.
                        5. ..... .   ._  Doses tested, snffident u> determine a toxidty catefoiy or a limit dose (5000 mj/kg).
                        & .....   :   lodividual observations at least once a day,
                        ?• —  Observation period to last at least 14 days, or until all test  animals appear normal whichever
                                 is longer.
                        S. __  Individual daily observations,
                        f.» _  Individual body weights,
                       Ml*       Gross necropsy on all animals.
                       Qiteria marked with a * are supplemental and nay not be required for every study.

                                                                    C-84

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i
                                                                                                     Subdivision F
                                                                                            Guideline Ret No. 814
                                                                                                December 24,1989


                                                    S14 Acute Onl Ttcdpity to the Rat

                                               GUIDANCE FOR SUMMARIZING STUDIES


                      Hew to sBminaiy stool* indnde the ttom dbamed la CaafWer 2 of tMs ptctafe i«d the specific items
                      toted below.

                       L The fora of pesticide tested, eg, sciIM, UqoM, percent Al in technical, etc
                       1 He •limber of anlaalsMose/iex teited.
                       3. Dosing route and regimen.
                       4. Vehicle med
                       5. Doses tested and results
                       6. Ifidrvidual observation! OB day of doting.
                       ?. Individual observations on day of doling and for at least 14 days or until all animals appear normal
                         (whichever is longer).
                       8. See items 6 and 7
                       9. Summarization nf body weights
                      10. Summarization 01 pots  necropsy
                      11. Significance of changes from the Acceptance Criteria
                                                                  OSS

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                                                                                    Subdivision F
                                                                           Guideline Ret No. 81-2
                                                                               December 24,1969


                    81-2 Acate Denial Tbridty to the Rat, RabMt or Guinea fig

                                    ACCEPTANCE CRITERIA.

Docs foor study meet the following acceptance criteria?

 1*    .,  Technical form of die active ingredient tested (for reregistntiOB only)
 2.*	  At least 5 animalsAex/group
 3.*	  Rats 200-300 gm» rabbits 10-343 k| or guinea pip 350450 gm.
 4 ___  Dosing, tingle dermal
 5.	   ..   Dosing duration at least 24 noun.
 6.*      Vehicle control, only if toxfcity of vehicle is unknown.
 7.   _  Doses tested, sufficient to determine a toxicity category or • limit dose (2000 mg/kg).
 *•    UL,  Application site clipped or shaved at least 24 hours before dosing
 9- —  Application site at  least 10% of body surface area.
10- —  Application site covered with a porous nonirritatin* cover to retain lest material and :o
          prevent ingestfon.                                                  ^
H-  nnl-    Individua] observations at least once a day.
12. ___  Observation  period to last at least 14 days, or until all test animals appear normal whichever
          is longer.
^  __  Individual daffy ->bservations.
14.»	  Individual body weights.
15.*      Gross  necropsy on  all animals.
Criteria marked with • * are supplemental and may not be required lot every study.

                                               C-S6

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i
                                                                                                       Subdivision F
                                                                                              Guideline Ret No. 81-2
                                                                                                  December 24,1989


                                          81-2 Acute Dermal Tbridty fa the Hal, Rabbit or Guinea Pif

                                                GUIDANCE FOR SUMMARJZINO STUDIES


                       Hen* IB sunnily saoold taKtode the item dbcossed fa Cfcaptet 2 of tnis f«eii§e iad tae specilk flea*
                       feted beJov.

                       L The fora of pesticide teated, ej, solid, liquid, percent AJ IB technical, esc.
                       2. file oomber of animalsAexAiote
                       3. Weight range of animals
                       4. Verification of single, dermal exposure
                       5. Duration of dermal exposure
                       & Statement of vehicle control
                       7. Doses let ted and results
                       & Preparation of application site
                       9. Area of application site (percent bod; surface)
                       10. Occlusion of test material on application site
                       11. Individual observations OB day of dosing
                       12. b IMdual observations on day of dosing and for at least 14 days or until all animals appear normal
                          (whichever is longer)
                       13. See items 11 and 12
                       14. Summarization of body weights
                       15. Summarization of frost necropsy
                       16. Significance of changes from Acceptance Criteria
                                                                   CS7

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i
                                                                                                         Subdivision f
                                                                                               Guideline Ret Ho. 81-3
                                                                                                    December 24,1989
                                                   91-3 Ante tahitotioa Tteidtj it the Rat
                                                                         V
                                                         ACCEPTANCE CRITERIA

                      Does joor study nee* the following acceptance criteria?

                     >  ** —   Technical form of the active ingredient tasted, (tot reregbtratton only)
                       2,   _    Product is a fas, a tobd which may produce a significant vapor hazard based on tcnddty and
                                expected use or contain* panicles of inhalable size for nan (aerodynamic diameter IS tun or
                                less).
                       3.*    ..   At least 5 younf adult iattAat%roop
                       4.*       Dosinf, at least 4 hours by inhalation.
                       5.*       Chamber air flow dynamic, at least 10 air chinges/hour,  at least 19% oxygen content.
                       &    _    Chamber temperature, 22* C (±2*), relative  humidity 4040%.
                       ?• _»__   Monitor rate of air flow
                       S- —   Monitor actual concentrations of test material in breathing »ne.
                       9. ___   Monitor aerodynamic panicle size for aerosols.
                      10. _  	   Doses tested, sufficient to determine a toricity category or a limit dose (S mj/L actual
                                concentration of respirable suHtance).
                      H-	, ,   Individual observations at least once a day.
                      12. _, :J,   Observation period to last at least 14 days, or until an test animals appear normal whichever
                                is longer.
                      13-  	     Individual daOy observations.
                      14.»	   Individual body weights,
                      IS.*  .     Gross necropsy on  all
                     Criteria marked with a • are supplemental and may not be required tot every study.

                                                                   CSS

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                                                                               Subdivision P
                                                                      Guideline Ret Ho. 81-3
                                                                          December 24, 1989


                           tl-3 Acute Inhalatkx) Itafcfty fa the Eat

                         GUIDANCE FOE SUMMARIZING STUDIES


     fa summary should mdnde the hem dbomed fa Oupter 2 of this  package aad the specific ileus
     below.
               t
 L Tie form of pesticide tested, e.g., solid, Kquld, percent AI fa technical, etc.
 1 Statemeet of the inhalability of tett iubsunoe
 3L He Bomber of
 4 Dundon of tnhiUtion expocure
 & Number of clumber air clwngesAottr and the percent oxyjen conteot of dumber air
 ft. Rinfcs for clumber air temperature and relative humidity
 2. Air flow rate
 & Analytical concentrations of ten material IB breathing raae
 ft Results of aerosol particle-size determination
•L Doses tested (or limit dose of Smg/L or highest attainable)
11 Individual observations on day of dosing
12, Indiviuaal observations oa day of dosing aad for at least 14 days or until all animals appear normal
   (whichever is longer)
n. See items  11 and 12
ML Summarization of body weights
IS. Summarization of gross necropsy
lit Significance of changes from Acceptance Criteria
                                            C49

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I
                                                                                                         Subdivision F
                                                                                                         Ret No. 81-4
                                                                                                              24,1969


                                                   $1-4 Primary Eye Irritation IB Ike Rabbtt

                                                         ACCEPTANCE CRITERIA

                       Does four study meet the foDowug acceptance criteria?

                       t.	  Technical form of die active ingredient tested, (for rcregisuition only)
                       2-...  Study not required if oxiteriil is corroiive, causes severe dermal irritation or has a pH of ,<
                                2 or i 1U.
                       3L»	  6 adult nbbitt
                       *•   ,.   Do»io|, instflUtion feto the oonjunctivil sac of one eye per aoimaL
                       5-*       Dose, ttl ml if a liquid; a 1 ml  or not more than 100 mg If a solid, paste or paniculate
                                substance.
                       & —  SoUd or granular test material ground to a fine dust
                       7.   „   Eyes  not washed for at least 24 hours.
                       S...  	   Eyes  examined and graded for irritation before dosing and at 1, 24,48 sad 72 hi, then dairy
                                until  eyes are normal or 21 days (whichever is shorter).
                       *.•____  Individual observations for the entire day of dosing.
                       Ifl*       Individual daily observations.
                      Qfeerii marked with § * are supplemental and may not be required for every study.

                                                                    C-90

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s
                                                                                                         Subdivision F
                                                                                               Guideline Ret No. 8M
                                                                                                    December 24,1989


                                                   tl-4 Primary Eye Mutton to the Rabbit

                                                GUIDANCE FOR SUMMARIZING STUDIES


                      HOBS in summary shooJd todode tbe items dfacaated to Chapter I of this package and the specific it«n*
                      total beta*.
                                      %                       "
                       S. The form of pesticide tested, «,£, solid, liquid, percent AI in technical, etc
                       2. State of material Is corrosive, came severe derail irritation or has a pH of <2 or »UJ
                       3. Number of adult rabbits tested
                       4, State method of dosinf, Le^ iastfliatk>D iato tbe oonjunctrval sac of oae eye per animal
                       5. Dose administered
                       6. Note whether solid or fraaalar test material lias been ground to t fine dust
                       7, State whether eyes were washed and at what time post instillation ;
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                                                                                   Subdivision P
                                                                          Guideline Ret No. tl-S
                                                                              December 24,1989


                               tl-5 Primary Derma! Irritation Study

                                   ACCEPTANCE OUTCRIA

Does jour atadj neet the following acceptance criteria?

 *• —  Technical form of the active ingredient tested (for ^registration onjy)
 X	  Study not required if material is corrosive or bis t pH of £ 2 or £ IU.
 3.*       6 adult tnlmtte.
 <• —.  Doslnj, siajle demuL
 5,...  Dosing duration 4 bran.
 &   __   Application site thaved or clipped at least 24 bow prior to dotlaf.
 7.   ^	  Application site approximately 6 cm*.
 &   _  Application site covered with a puze patch field in place with ooniniutinf tape
 9.    ..  Material removed, washed with  water, without trauma to application tilt
1°-	-  _-  Application site examined and graded for irritation at i,  24,48 and 72 hr, then daily until
          normal or 14 days (whichever is shorter).
II.*       Individual observations for the entire day of dosing.
11*	  Individual daily observations.
Criteria narked with a * arc supplemental and may not be required for every study.

                                              C-92

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i
                                                                                                       Subdivision F
                                                                                              Guideline Ret No. 81-5
                                                                                                  December 24,1989


                                                    tl-5 Primary Derail frritactaa Study

                                               GUIDANCE FOR SUMMARIZING STUDIES


                      Itctni IB sunnily ibook* fododc tbe item dbenssed ii Chapter 2 of ihfc MCfcafe tad the specific liens
                      toted below.    v

                       L Tbe form of pesticide toned, «.*, »olkl, liquid, percent AI ia tecftalai, etc.
                       2. State If miierUI is corrosive, bu • pH <2 or >11J, or hu a  dermal LD-50 <200 mj/kg
                       3. Number of adult animab tested
                       4 Amount applied
                       S. Duration of dermal exposure
                       6. Preparation  of application site (shaved or dipped at specified tine before dosing)
                       ?. Area of application site
                       8, Method for  occlusion of application site
                       9. Note removal  of test material and if skin was washed with water
                      10. State tines post application when site was graded tor irritation
                      11. Individual observations  for entire ^y of dosing,
                      11 Individual observations  for entire day of dosing and individual  dairy observations thereafter
                      13. Significance  of changes  from Acceptance Criteria.
                                                                   O93

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i
                                                                                                                   F
                                                                                               Guideline Ret No. Sl-6
                                                                                                             24,1989
                                                 §1-6 Dermal Sen-Wadon ia the Guinea Pif

                                                        ACX3JPTANCE CRITERIA

                      Do« jour study meet the toaowtaj acceptane* oiusiaf

                      t —   Technical fonn of the active ingredient tested, (for terefbtntioa only)
                      2. __   Study not required if material is. corrosive or his t pH of S 2 or j»
                      & —.   One of the followtng methods b ntOized;
                                _____   Freund'i complete adjuvmnt test
                                       Ouicei  pic Biixiiniz_tioB tett
                                ____   Split adjuvant technique
                                ____,   Buehler test
                                	_  .   Open epicuttneous test
                                _____   Mtuer optimization ten
                                _____   Footpad techm'que In guinea pif
                                _____   Other test accepted by OECD ftpeciIVY
                      4 ..       Complete description of lest
                      S.*       Reference for test.
                      6. _____   Test followed t :
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i
                                                                                                    Subdivision F
                                                                                           Guideline Ret No. Sl-6
                                                                                               December 24, 1989
                                                SI-6 Dermal SevWatioi.il the Guinea flg

                                              GUIDANCE FOR SUMMARIZING STUDIES
                      hem* in rammaif should include the item* dbomed fa Qapur 1 of lUi netafe and the fpedfic hem*
                      toted below.
                       L Hie font of pesticide tested, c,|^ »IW, liquid, percent AI in technical, esc.
                       2. State If material is corrotive or kas pH <2 or >1SJ).
                       3. State specific method utilized
                       4 Complete description of specific method
                       S. Reference for the specific method employed
                       & Note adherence of the protocol to th~t in the reference for the specific method vtilted
                       7. State the positive control  tested
                       8. Significance of changes from Acceptance Criteria
                                                                 C-95

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i
                                                                                                        tubdMstottF
                                                                                               Guideline Ret No. 81-7
                                                                                                   December 24,1969


                                                     tl-7 Ante Neorworidty b the Hen

                                                         ACCEPTANCE CRITERIA

                      Does yoor nodi Meet fee toflowmg acrrpunce criteria?  .

                       1* ——  Study performed mi «o organophoiphate cholinesterase inhibiting compound,
                       2,  •     Technical font of the active ingredient toted.
                       1*	  Positive control itflted.
                       *> -m.  Spedes utilized, domestic hying ben 8-14 months of age.
                       & —  Dosinj oral by (tvi|e or capsule (dennil or inhalation nay be Mad).
                       &  _    AD acute oral LDn is determined,
                       7. _  Dose tested equal to an acute oral U>M or a limit test of 5000 nf/kf.
                       &*      Dosed animali may be protected with airopine and/or 2-PAM.
                       9-  _    SuOcieet t4tt animals so  that at least 6 survive.
                      10- —_  Negative (vehicle} control froup of at least 6 kens
                      1L*      Positive control of at least 4 bens, (if used)
                      12- —  Test ^o** repeated if no sips of delayed neurotoridty observed by 21 days after dosing.
                      **•,      Observation period 21 days af-j each dose.
                      !*• _.  Individual daily observations.
                      IS.	  Individual body weifnts.
                      *&•      Individual necropsy not required.
                      *7- —  Histopatholo0 performed on all animals. Tissue to be fixed 61 rta preferably using whole
                                animal perfuslon techniques. At least three sections of each of the following tissues:
                                    brain, including medulla oblongau
                       ' '  *    —»P5 cord; upper cervical, mid-thoracic and lumbro-sacral regions
                                    libial nerve; proximal regions and branches
                                    sciatic nerve
                      Criteria narked with a * ate supplemental aid nay aot be required far every study.

                                                                   CM

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i
                                      ATTACHMENT F



                  LIST OF ALL REGISTRANTS SENT THIS DATA CALL-IN NOTICE

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                           ATTACHMENT F

      LIST OF ALL REGISTRANTS SENT THIS DATA CALL-IN NOTICE
Case Number and Name

4007      Allium sativuro (Garlic)
COMPANY
NUMBER
COMPANY
NAME

Sevana
               Guardian  Spray
ADDRESS, CITY
AND STATE ZIP

5336 East Easterby Drive
Fresno, California  93727

900 Lancer Way
Lebec, California  93242

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i
                                      ATTACHMENT 6



                         COST SHARE AND DATA COMPENSATION F^RMS

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i
                r/EPA
                       United States Environmental Protection Agency
                                   Washington, DC 20460
                          CERTIFICATION WITH RESPECT  TO
                       DATA COMPENSATION REQUIREMENTS
Form Approved

OMS N*.  M70-0105

Appr*vsi
             Pubic reporting burden for this collection of information is estimated to average 15 minutes par response, including
             time lor reviewing instmctions, starching txisting data sources, gathtring and maintaining tha data netdtd, and
             completing and reviewing tht coSectton of information.  Send comments regarding the burden estimate or any other
             aspect of tNs collection of information, including suggestions for reducing this burden, to Chief, Information Policy
             Bianch. PU-223, U.S. Environmental Protection Agency, 401 M St., S.W., Washington, DC 20480; and to the Office
             of Management and Budget. Paperwork Reduction Project (2070-0106), Washington, DC 20503.

             Please in In blanks below.
we^ee^pieM*y e^^e^tew
Product Haat

EPA leg. Ho.
            1 Certify thai:

            1.  For each study cited in support of registration or reregistratton under the Federal Insecticide, Fungicide and
               Rodentcide Act (FIFRA) that is an exclusive use study, I am the original data submitter, or I have obtained the
               written permission of the original data submitter to cite that study.
            2.
That for each study died in support of registration or ^registration under FIFRA that is NOT an exclusive use
study, I am the original data submitter, or I have obtained the written permission of the original data submitter, or l
have notr«tf»n writing the company{ies} that submitted data I have cited and have offered to: (a)  Pay
compensation for those data in accordance with sections 3(C)(1)(D) and 3(c)(2)(D) of FIFRA; and (b) Commence
negotiation to determine which data are subject to the compensation requirement of FIFRA and the amount of
compensation due, I any. The companies I have notified are:
                U  Thecompanies who have submitted the studies isted on the back of this form or attached
                   sheets, or indicated on the attached •Requirements Status and Registrants' Response Form,"

            3.  That I haw previously complied wtth section 3(c)(i }(D) of FIFRA for the studies I have cfted in support of
                registration or reregistratton under FIFRA.
Sleutur*
Dal*
NMM Mi Tltte {MM** Typ* *r Print)
> •
            GENERAL OFFER TO PAY: I hereby offer and agree to pay compensation to other persons, wtth regard to the
            registration or reregtetraiton of my products, to the extent required by FIFRA sections 3(c)(l}(D) and 3(c)(2)(D).
Signature
Oat*
Nam* v* fill* (M*M* Ty»* *r Print)
            CPA far* SS7S-S1 (4.M)

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v/EPA
                         United States Environmental  Protection Agency
                                     Washington,  DC  10460
                            CERTIFICATION OF OFFER TO COST
                         SHARE  IN THE  DEVELOPMENT OF DATA
 Furm Approved

 OUB No. M7&41H

 Approval Expiro*
 Pubfc reporting burden for this ooBecHon of information to estimated to average 15 minutes ptr response, including
 ttnt for reviewing instructions. Marching existing data sourots, gathering and maintaining the data needed, and
 completing and reviewing the collection of information. Send comments regarding the burden estimate or any other
 aspect of tMs collection of information, including suggestions for reducing this burden, to Chief, information Policy
 Branch. PM-223, U.S. Environmental Protection Agency, 401 M St., S.W., Washington, DC 20480; and to the Office
 of Management and Budget, Paperwork Reduction Project {20704)106), Washington, DC 20503.

 Please mi in blanks below.
  Company Nun*
  Product Kane
EPA Reg.  No.
 i Certify that:

 My company is willing to develop and submit the data required by EPA under the authority of the Federal
 Insecticide, Fungicide and Rodenticide Act (FIFRA), if necessary. However, my company would prefer to
 enter into an agreement with one or more registrants to develop jointly or share in the cost of developing
 data.

 My firm has offered in writing to enter into such an agreement.  That offer was Irrevocable and included an
 offer to be bound by arbitration decision under section 3(c)(2)(B)(iii) of FIFRA tf final agreement on alt
 terms could not be reached otherwise. This offer  was made to  the following firm(s) on the following
 date(s):
  Mama of nra(a)
 D*t* *f Offer
Certification:
 I certify trial i am duty authored to repttsert ft* c^^                                      have made on
 this form and ai attachments therein are tnie, accurate, and complete. I acknowledge that any knowingly faise or
 misleading statement may be punishable by fine or irnprisorarant or bom under applicable law.
 Signature of Comptny'v Authorlioo* R«prt»onutlvo
 D«t*
 Mamo and TlUo |Piaa»* Typo or MM)
tFA Form M70*32

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US invironrnantai Pwtaetion Agency Atgiatration Standard Ion
tttahingtert. DC 20460
&EPA .Product Specific
OuMoNntNe.
$«€. 158.120
Product
•1-1
fl-3(m)
• ei-2 f bt
82-1
82-2
824
83-2
63-3
63-4
63-3
834
83-?
•34
•34
83-10
63-11
63-12
83-13
63-14
63-15
83-16
83-17
83*18
83-18
63-20
63-21
Sec. 158.135
ToxicoloQY
•1-1
•1-2
•14
•1-4
•14
•14
NamtofTMt

Utntty of tnomdtvrm
StatMfwnt of oompeaKion


Ditotttion el termaflort of tnpjradianta
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DMB #2070X3057

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                          EPA RED FACTS

                     ALLIUM SATIVPM (GARLIC)
PESTICIDE REREGISTRATION

     All pesticides sold or used in the United States must be
registered by EPA, based on scientific studies showing that they
can be used without posing unreasonable risks to people or the
environment.  Because of advances in scientific knowledge, the
law requires that pesticides which were first registered years
ago be reregistered to ensure that they meet today's more
stringent standards.

     In evaluating pesticides for reregistration, EPA obtains and
reviews a complete set of studies from pesticide producers,
showing the human health and environmental effects of each
pesticide.  The Agency imposes any regulatory controls that are
needed to effectively manage each pesticide's risks.  EPA then
reregisters pesticides that can be used without posing undue
hazards to human health or the environment.

     When a pesticide is eligible for reregistration, EPA
announces this and explains why in a Reregistration Eligibility
Document, or RED.  This fact sheet summarizes the information in
the RED for Allium sativum (garlic).

USE PROFILE

     Allium sativum or garlic, formulated as a powder or a
distilled extract from garlic cloves, is an active ingredient in
four registered pesticide products;  three of these products also
contain the active ingredient capsaicin (red pepper).  The garlic
pesticides are applied aerially or by ground equipment, and are
used to repel birds and/or insects and thus prevent them from
damaging seeds and seedlings of vegetable plants, fruit trees,
grain crops, ornamental plants and shrubbery.

REGULATORY HISTORY

     EPA registered the first two pesticide products containing
garlic as an active ingredient in 1983 and 1985.  Both products
also contain red pepper, and are used to repel birds.  A third
garlic and red pepper product, used to repel insects, was
registered in 1988.  The fourth product, which contains garlic as
a single active ingredient, was registered in February 1991, also
to control insects.

     EPA previously classified garlic as a conventional chemical
pesticide.  However, the Agency now is reclassifying garlic as a
biochemical pesticide since it is a naturally-occurring substance
and has a non-toxic mode of action.

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HUMAN HEALTH AND ENVIRONMENTAL ASSESSMENT

     Although EPA has developed a set of data requirements for
reregistration, the Agency believes there is a category of
pesticides for which a greatly reduced set of data requirements
are appropriate.  Such pesticides may be exempt from the usual
generic data requirements for toxicology, residue chemistry,
human exposure, ecological effects and environmental fate,
without compromising human health or environmental safety.
However, some data requirements (such as basic product identity
and product chemistry data and acute toxicology studies) usually
are essential, and generally will not be waived.

     Garlic is in this category of pesticides, and EPA is waiving
most of the generic data requirements for its reregistration.
The bulb of a plant, its primary use in the United States is non-
pesticidal; it is used widely to flavor and season foods.  Garlic
is "generally recognized as safe," or GRAS, as a natural
seasoning or flavoring (see 21 CFR 182.10, 182.20 and 184.1317).

     Used as a pesticide, garlic has a non-toxic mode of action
for repelling target birds and insects.  Garlic is presumed to be
non-persistent since it is material known to rapidly degrade in
the environment.  EPA has received no reports of adverse effects
resulting from its use.  The Agency believes that no significant
adverse effects to humans or the environment are associated with
the use of garlic as a pesticide.

ADDITIONAL DATA REQUIRED

     EPA has waived all generic data requirements for garlic
except basic product identity and product chemistry studies.
These are being required now, through the RED.

PRODUCT LABELING CHANGES REQUIRED

     The labels of the four registered garlic pesticide products
must comply with EPA's current pesticide labeling requirements.
No other labeling changes are being required at this time.

REGULATORY CONCLUSION

     »  The registered bird and insect repellent uses of garlic
are not likely to cause unreasonable adverse effects in people or
the environment, and are eligible for reregistration.

     *  The registered product that contains garlic as its only
active ingredient will be reregistered once product-specific data
and amended labeling are received and accepted by EPA.

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i
                 •  The other three registered products that contain both
            garlic and red pepper as active ingredients will be reregistered
            after red pepper also is determined to be eligible for
            reregistration.

            FOR MORE INFORMATION

                 EPA is requesting public comments on the Reregistration
            Eligibility Document (RED)  for garlic during a 60-day time
            period, as announced in a Notice of Availability published in the
            Federal Register.  To obtain a copy of the RED or to submit
            written comments, please contact the Public Response and Program
            Resources Branch, Field Operations Division (H-7506C), Office of
            Pesticide Programs (OPP), US EPA, Washington,  DC 20460, telephone
            703-305-5805.

                 In the future, the garlic RED will be available from the
            National Technical Information Service (NTIS), 5285 Port Royal
            Road, Springfield, VA 22161, telephone 703-487-4650.

                 For more information about garlic or about EPA's pesticide
            reregistration program, please contact the Special Review and
            Reregistration Division (H-7508W), OPP, US EPA, Washington, DC
            20460, telephone 703-308-8000.  For information about
            reregistration of individual garlic products,  please contact the
            Registration Division (H-7505C), OPP, US EPA,  Washington, DC
            20460, telephone 703-305-5447.

                 For information about the health effects of pesticides, or
            for assistance in recognizing and managing pesticide poisoning
            symptoms, please contact the National Pesticides
            Telecommunications Network (NPTN).  Call toll-free 1-800-858-
            7378, 24 hours a day, seven days a week, or Fax your inquiry to
            806-743-3094.

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