Files
justin a97107de46
Image rebuild (skip scrape) / build (push) Failing after 1h37m12s
docker: production image + Gitea Actions for monthly refresh
Dockerfile: self-contained image with corpus + Chroma + BM25 baked
in. Drawbar's compose pulls + runs without volume mounts. Built from
sources.json (labels schema), PRODUCT_NAME=crop_chem by default,
HYBRID_SEARCH=true (always-on for production quality). RERANK_URL +
OLLAMA_URL get set at compose time.

.gitea/workflows/refresh.yml: monthly cron (1st @ 06:00 UTC) does
full scrape → reindex → image push. Scrapes Bayer (~30 min) +
EPA PPLS row-crop filtered (~7h). Skips reindex+push if no corpus
diff. Tags pushed: :latest, :<sha12>, :corpus-<YYYY.MM.DD>.

.gitea/workflows/image-only.yml: on-demand or auto on code-only
pushes to main (paths: docs_mcp/, rag/, scrape/, requirements.txt,
Dockerfile, sources.json). Reindexes from committed corpus, builds
image, pushes. ~10 min vs ~9h full refresh.

.gitignore: corpus/ now COMMITTED (4,159 labels, 265 MB of .md +
sidecars). Lets image-only.yml rebuild indexes without re-scraping.
chroma/ + bm25/ still gitignored (regenerable binary indexes).

.dockerignore: drops venv, eval results, PLAN/README/CLAUDE.md,
deploy/, .git/ — keeps the image lean. corpus + chroma + bm25
explicitly NOT in dockerignore (those go INTO the image).

Co-Authored-By: Claude Opus 4.7 (1M context) <noreply@anthropic.com>
2026-05-24 12:32:41 -04:00

22 KiB
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DREXEL 435 OIL 98.8


April 29, 2026

Cancan Huang Registration Manager Drexel Chemical Company P.O. Box 13327 Memphis, TN 38113-0327

Subject: Label Amendment - Registration Review Mitigation for Aliphatic Solvents Product Name: Drexel 435 Oil 98.8 EPA Registration Number: 19713-394 Case Number: 472501 Application Date: April 7, 2020

Dear Cancan Huang:

The Agency, in accordance with the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA), as amended, has completed reviewing all the information submitted with your application to support the Registration Review of the above referenced product in connection with the Aliphatic Solvents Interim Decision, and has concluded that your submission is acceptable. The label referred to above, submitted in connection with registration under FIFRA, as amended, is acceptable.

Should you wish to add/retain a reference to the companys website on your label, then please be aware that the website becomes labeling under the Federal Insecticide, Fungicide, and Rodenticide Act and is subject to review by the Agency. If the website is false or misleading, the product would be misbranded and unlawful to sell or distribute under FIFRA section 12(a)(1)(E). 40 CFR 156.10(a)(5) list examples of statements EPA may consider false or misleading. In addition, regardless of whether a website is referenced on your products label, claims made on the website may not substantially differ from those claims approved through the registration process. Therefore, should the Agency find or if it is brought to our attention that a website contains false or misleading statements or claims substantially differing from the EPA approved registration, the website will be referred to the EPAs Office of Enforcement and Compliance Assurance.

A stamped copy of your labeling is enclosed for your records. This labeling supersedes all previously accepted labeling and must be used at your next label printing. You must submit one copy of the final printed labeling before you release the product for

Page 2 of 2 EPA Reg. No. 19713-394 Case No. 472501

shipment with the new labeling. In accordance with 40 CFR 152.130(c), you may distribute or sell this product under the previously approved labeling for 12 months from the date of this letter. After 12 months, you may only distribute or sell this product if it bears this new revised labeling or subsequently approved labeling. “To distribute or sell” is defined under FIFRA section 2(gg) and its implementing regulation at 40 CFR 152.3.

If you have any questions about this letter, please contact Concepción Rodríguez by phone at 202-566-0820, or via email at rodriguez.concepcion@epa.gov.

S i n c e r e l y ,

Julie Javier, Team Leader Risk Mitigation and Implementation Branch 4 Pesticide Re-Evaluation Division Office of Pesticide Programs

ENCLOSURE: Stamped label

Page 1 of 6 435 Oil 98.8 A Superior Horticultural Spray Oil For Insect and Mite pest management. ACTIVE INGREDIENT: Mineral Oil* ....................................................................................................................................... 98.8% OTHER INGREDIENTS..........................................................................................................................1.2% TOTAL.............................................................................................................................................100.0%

  • Unsulfonated Residue of Petroleum Distillate is 92% Min.
  • 50% Distillation Point of Petroleum Distillate is 435°F.
  • Weight per Gallon is 7.2 pounds. Contains petroleum distillates. KEEP OUT OF REACH OF CHILDREN CAUTION [See FIRST AID Below] [See Side Panel for FIRST AID]; [See Back Panel for FIRST AID]; [See Page for FIRST AID] [See Container Labeling for Complete Directions for Use]; [See Container Labeling for FIRST AID and Complete Directions for Use]; [See Booklet for Complete Directions for Use] EPA Reg. No. 19713-394 EPA Est. No. 19713-XX-XXX Net Content: Gals .( L ) FIRST AID IF ON SKIN OR CLOTHING: • Take off contaminated clothing. • Rinse skin immediately with plenty of water for 15 to 20 minutes. • Call a poison control center or doctor for treatment advice. IF SWALLOWED: • Call a poison control center or doctor immediately for treatment advice. • Do not give any liquid to the person. • Do not induce vomiting unless told to do so by a poison control center or doctor. • Do not give anything by mouth to an unconscious or convulsing person. IF IN EYES: • Hold eye open and rinse slowly and gently with water for 15 to 20 minutes. • Remove contact lenses, if present, after the first 5 minutes, then continue rinsing eye. • Call a poison control center or doctor for treatment advice. IF INHALED: • Move person to fresh air. •If person is not breathing, call 911 or an ambulance, then give artificial respiration, preferably mouth- to-mouth, if possible. • Call a poison control center or doctor for further treatment advice. Have the product container or label with you when calling a poison control center or doctor, or going for treatment. You may also call CHEMTREC at 800-424-9300 for emergency medical treatment information. Note to Physician: Contains petroleum distillate. Petroleum distillates may pose an aspiration pneumonia hazard. 394SP-0320*P Apr 29, 2026 19713-394

Page 2 of 6

PRECAUTIONARY STATEMENTS Hazards to Humans and Domestic Animals CAUTION: Harmful if absorbed through skin. Avoid contact with eyes, skin or clothing. Prolonged or frequently repeated skin contact may cause allergic reactions in some individuals. PERSONAL PROTECTIVE EQUIPMENT (PPE) Mixers, loaders, applicators, flaggers, and other handlers must wear: Long-sleeved shirt and long pants, chemical-resistant gloves made of barrier laminate or viton > 14 mils and shoes plus socks. See “ENGINEERING CONTROLS” for additional requirements. Follow manufacturers instructions for cleaning/maintaining PPE. If no such instructions for washables exist, use detergent and hot water. Keep and wash PPE separately from other laundry. Discard clothing and other absorbent materials that have been drenched or heavily contaminated with the products concentrate. Do not reuse them. ENGINEERING CONTROLS Pilots must use an enclosed cockpit that meets the requirements listed in the WPS for agricultural pesticides [40 CFR 170.607(f)].

USER SAFETY RECOMMENDATIONS Users should: 1) Wash hands before eating, drinking, chewing gum, using tobacco or using the toilet. 2) Remove clothing/PPE immediately if pesticide gets inside. Then wash thoroughly and put on clean clothing. 3) Remove PPE immediately after handling this product. Wash the outside of gloves before removing. As soon as possible, wash thoroughly and change into clean clothing. ENVIRONMENTAL HAZARDS This product is toxic to aquatic invertebrates. Do not apply directly to water, or to areas where surface water is present, or to intertidal areas below the mean high water mark. Do not contaminate water when disposing of equipment wash water or rinsate. Drift and runo ff may be hazardous to aquatic organisms in water adjacent to treated areas. Avoid drift or run off into storm drains, drainage ditches, or surface waters. Applying this product in calm weather when rain is not predicted for the next 24 hours will help to maximize the chances that wind, or rain will not blow or wash pesticide off the treatment area. Rinsing application equipment over the treated area will help avoid run off to water bodies or drainage systems.

DIRECTIONS FOR USE It is a violation of Federal law to use this product in a manner inconsistent with its labeling. Do not apply this product through any type of irrigation system. Do not apply this product in a way that will contact workers or other persons, either directly or through drift. Only protected handlers may be in the area during application. For any requirements specific to your state or tribe, consult the agency responsible for pesticide regulation.

AGRICULTURAL USE REQUIREMENTS Use this product only in accordance with its labeling and with the Worker Protection Standard, (WPS) 40 CFR Part 170. This Standard contains requirements for the protection of agricultural workers on farms, forests, nurseries, and greenhouses, and handlers of agricultural pesticides. It contains requirements for training, decontamination, notification, and emergency assistance. It also contains specific instructions and exceptions pertaining to the statements on this label about personal protective equipment (PPE) and restricted -entry interval (REI). The requirements in this box only apply to uses of this product that are covered by the WPS. Do not enter or allow worker entry into treated areas during the REI of 4 hours. PPE required for early entry to treated areas that is permitted under the WPS and that involves contact with anything that has been treated such as plants, soil, or water is: Coveralls, chemical-resistant gloves made of barrier laminate or viton > 14 mils and shoes plus socks.

NON-AGRICULTURAL USE REQUIREMENTS The requirements in this box apply to uses of this product that are NOT within the scope of the Worker Protection Standard for Agricultural Pesticides (4 0 CFR Part 170). The WPS applies when this product is used to produce agricultural plants on farms, forests, nurseries or greenhouses. Do not enter or allow others to enter until sprays have dried. Do not apply this product in a way that will contact adults, children or pets either directly or through drift.

Page 3 of 6 IMPORTANT: Keep oil container tightly closed in storage to prevent entry of water. Roll drum before use. All horticultural oils interfere with or slow plant transpiration and respiration during the period of evaporation. Phytotoxicity may result if sprayed on plants during periods of prolonged high temperature and high relative humidity. Do not spray plants under moisture stress. Do not use in combination with or immediately before or after spraying with fungicides such as Captan, Folpet or any other product containing Sulfur. If possible, either keep the spray equipment used for these compou nds separate from the equipment used for oil, or make sure that the sprayer is thoroughly cleaned so that no residues from these compounds remain. Do not use with Carbaryl on deciduous fruit trees. Do not use with Dimethoate. TANK-MIXES This product may be used: • As a carrier for Bacillus thuringiensis when it is applied through a mist blower or cold fog machine; • With Permethrin on Cotton only; • With Chlorpyrifos on Apples, Field corn, Sweet corn, Pears, Plums, Prunes and Peaches; • As a spreader or carrier for certain synthetic organic insecticides applied for pest control in or on habitable buildings. All tank-mixes and tank-mix applications must be consistent with the labels for this product and the other pesticide(s) included in the mix. Do not apply this product or mixes made from it via chemigation. TIMING OF THE TREATMENT You must determine the precise timing to fit local growth and climate conditions MIXING DIRECTIONS Add sufficient water to the mixing tank to allow proper agitation. Maintain agitation until solution is used. If other pesticides are to be added, do so after the water and oil have been thoroughly mixed.

METHODS OF APPLICATION Dilute Applications: Apply specified rate of this product in 100 to 800 gallons of water per acre. Higher spray volumes may be used only for applications to Citrus. See specific directions for applications to Citrus. Concentrate Applications: Apply specified rate of this product in 50 to 150 gallons of water per acre. Aerial Applications: Apply the specified rate of this product in 10 to 20 gallons of water per acre.

SPRAY DRIFT ADVISORIES THE APPLICATOR IS RESPONSIBLE FOR AVOIDING OFF-SITE SPRAY DRIFT. BE AWARE OF NEARBY NON-TARGET SITES AND ENVIRONMENTAL CONDITIONS.

IMPORTANCE OF DROPLET SIZE An effective way to reduce spray drift is to apply large droplets. Use the largest droplets that provide target pest control. While applying larger droplets will reduce spray drift, the potential for drift will be greater if applications are made improperly or under unfavorable environmental conditions.

Controlling Droplet Size Ground Boom • Volume - Increasing the spray volume so that larger droplets are produced will reduce spray drift. Use the highest practical spray volume for the application. If a greater spray volume is needed, consider using a nozzle with a higher flow rate. • Pressure - Use the lowest spray pressure recommended for the nozzle to produce the target spray volume and droplet size. • Spray Nozzle - Use a spray nozzle that is designed fo r the intended application. Consider using nozzles designed to reduce drift. Controlling Droplet Size Aircraft • Adjust Nozzles - Follow nozzle manufacturers reco mmendations for setting up nozzles. Generally, to reduce fine droplets, nozzles should be oriented parallel with the airflow in flight.

Page 4 of 6 BOOM HEIGHT Ground Boom For ground equipment, the boom should remain level with the crop and have minimal bounce.

RELEASE HEIGHT - Aircraft Higher release heights increase the potential for spray drift. When applying aerially to crops, do not release spray at a height greater than 10 ft above the crop canopy, unless a greater application height is necessary for pilot safety. SHIELDED SPRAYERS Shielding the boom or individual nozzles can reduce spray drift. Consider using shielded sprayers. Verify that the shields are not interfering with the uniform deposition of the spray on the target area. TEMPERATURE AND HUMIDITY When making applications in hot and dry conditions, use larger droplets to reduce effects of evaporation.

TEMPERATURE INVERSIONS Drift potential is high during a temperature invers ion. Temperature inversions are characterized by increasing temperature with altitude and are common on nights with limited cloud cover and light to no wind. The presence of an inversion can be indicated by ground fog or by the movement of smoke from a ground source or an aircraft smoke generator. Smoke that layers and moves laterally in a concentrated cloud (under low wind conditions) indicates an inversion, while smoke that moves upward and rapidly dissipates indicates good vertical air mixing. Avoid applications during temperature inversions.

WIND Drift potential generally increases with wind speed. AVOID APPLICATIONS DURING GUSTY WIND CONDITIONS. Applicators need to be familiar with local wind patterns and terrain that could affect spray drift.

SPRAY DRIFT Boomless Ground Applications: x Setting nozzles at the lowest effective height will help to reduce the potential for spray drift.

SPRAY DRIFT Handheld Technology Applications: Take precautions to minimize spray drift.

PESTS CONTROLLED This product can control mite and insect pests in the egg stage including: Adelgids, Aphids, Armored scales, Cankerworms, Eriophyid mites, Leafhoppers, Leafrollers, Mealybugs, Plant bugs, Psyllids, Soft scales, Spider mites, Webworms, and Whiteflies. This product also will kill other immature forms if the spray covers the insect.

Crop Pest(s) This Product (Gals. per 100 Gals. of Dilute Spray) Time of Application/ Stage of Development Apples Apple red bugs 2 Dormant European fruit lecanium scales 2 Dormant Fruit tree leafrollers 3 Dormant European red spider mites 2 Green tip to Delayed dormant 1/2” Green San Jose scales 2 Delayed dormant 1/2” Green Scurfy scale 3 Delayed dormant 1/2” green

Page 5 of 6

Corn (Field and Sweet) Corn rootworms 2 Early Spring Earworms 2 Summer Fall armyworms 2 Early Spring Peaches Cottony peach scale 3 Dormant Pears Fruittree leafroller 3 Dormant Pear leaf blister mites 3 Dormant Pear psylla 2 Late dormant Pecans Obscure scale 3 Dormant Sugar beets Leafminers 2 gals./Ac. As needed Mites 2 gals./Ac. As needed

CITRUS Crop Pest / Disease Dilute Application Concentrate Application* This Product (Gals./100 Gals. of Water This Product (Gals./Ac.) Citrus Citrus rust mite; Scale insects; Greasy spot disease 1.5 15.0 Sooty mold (to loosen); Spider mites; Whitefly 0.75 7.5 *Apply in sufficient water and manner to assure thorough distribution. USE PRECAUTIONS: Oils applied after October may increase cold damage to trees. Oils applied in August and September may affect solid contents and retard color. USE RESTRICTIONS: Do not apply more than 22.1 gals. of this product (157 Ibs. a.i.) per acre (maximum 1,500 gals. of spray mix per acre) in Texas and Florida, and 29.4 gals. of this product (209 Ibs. a.i.) per acre (maximum 2,000 gallons of spray mix per acre) in California (based on thorough coverage spray, with 1.5 gals. of product mixed in 100 gals. of water). ORNAMENTAL PLANTS Oil might remove the glaucus (blue) bloom from such Evergreens as Colorado blue spruce and Koster spruce. Use with precaution and reduce dosage for Summer application on Japanese red maple, Amur maple and Black walnut. Use with precaution and redu ce dosage for dormant application on Sugar maple and Redbud.

Plant Pest(s) Application Rate of This Product as (Gals. per 100 Gals. of Dilute Spray) Time of Application/ Stage of Development Azalea Azalea bark scales, European red spider mites 2 Dormant to budbreak Flowering crabapple Azalea bark scales, European red spider mites 2 Dormant to budbreak Flowering cherry Azalea bark scales, European red spider mites 2 Dormant to budbreak Dogwood Dogwood scales, San Jose scales 2 Dormant to budbreak Euonymus San Jose scales 2 Dormant to budbreak Holly Holly scales 2 Dormant to budbreak Hawthorn San Jose scales 2 Dormant to budbreak Juniper Juniper scales 2 Dormant to budbreak Lilac San Jose scales 2 Dormant to budbreak

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Pines Pine needle scales 2 Dormant to budbreak Privet White peach scales 2 Dormant to budbreak Rhododendron Azalea bark scales 2 Dormant to budbreak Rose Rose scales 2 Dormant Spirea San Jose scales 2 Dormant to budbreak STORAGE AND DISPOSAL Do not contaminate water, food or feed by storage or disposal. PESTICIDE STORAGE: Store in a cool, dry, locked area out of reac h of children. Keep oil container tightly closed in storage to prevent entry of water. PESTICIDE DISPOSAL: To avoid waste, use all materials in this container by application according to label directions. If wastes cannot be avoided, offer remaining product to a waste disposal facility or pesticide disposal program (often, such programs are run by State or local governments or by industry). CONTAINER HANDLING: Nonrefillable Container (rigid material; < 5 gallons): Nonrefillable container. Do not reuse or refill this container. Clean container promptly after emptying. Triple rinse as follows: Empty the remaining contents into application equipment or a mix tank and drain for 10 seconds after the fl ow begins to drip. Fill the container one-fourth full with water and recap. Shake for 10 seconds. Pour rinsate into application equipment or a mix tank or store rinsate for later use or disposal. Drain for 10 seconds after the flow begins to drip. Repeat this procedure two more times. Offer for recycling, if available, or dispose of empty container in a sanitary landfill or by or by other procedures allowed by state and local authorities. Nonrefillable Containers (rigid material; > 5 gallons up to < 250 gallons): Nonrefillable container. Do not reuse or refill this container. Clean container promptly after emptying. Triple rinse as follows: Empty the remaining contents into application equipment or a mix tank. Fill the container one-fourth full with water. Replace and tighten closures. Tip container on its side and roll it back and forth, ensuring at least one complete revolution, for 30 seconds. Stand the container on its end and tip it back and forth several times. Turn the container over onto its other end and tip it back and forth several times. Empty the rinsate into application equipment or a mix tank or store rinsate for later use or disposal. Repeat this procedure two more times. Offer for recycling, if available, or dispose of empty container in a sanitary landfill or by or by other procedures allowed by state and local authorities. Refillable Container (> 250 gallons & Bulk): Refillable container. Refill this co ntainer with pesticide only. Do not reuse this container for any other purpose. Cleaning the cont ainer before final disposal is the responsibility of the person disposing of the container. Cleaning before refilling is the responsibility of the refiller. To clean the container before final disposal, empty the remaining contents from this container into application equipment or mix tank. Fill the container about 10% full with water. Agitate vigorously or recirculate water with the pump for 2 minutes. Pour or pump rinsate into application equipment or rinsate collection system. Repeat this rinsing procedure two more times. Offer for recycling, if available, or dispose of empty container in a sanitary landfill or by or by other procedures allowed by state and local authorities.

WARRANTY—CONDITIONS OF SALE THE DIRECTIONS FOR USE of this product are based upon tests believed reliable. Follow directions carefully. Timing and method of application, weathe r and crop conditions, mixtures with other chemicals not specifically indicated, and other influencing factor s in the use of this product are beyond the control of the Seller. To the extent consistent with applicable law, Buyer assumes all risks of use, storage and handling of this material not in strict accordance with directions given herewith. To the extent consistent with applicable law, in no ca se shall the Manufacturer or the Seller be liable for consequential, special or indirect damages resulting from the use or handling of this product when such use and/or handling is not in strict accordance with directions given herewith. The foregoing is a condition of sale by the Seller and is accepted as such by the Buyer. Manufactured By:

The Drexel logo is a registered trademark of Drexel Chemical Company.