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

50 KiB
Raw Permalink Blame History

DREXEL CARBARYL 2% BAIT GRANULE


April 9, 2025 Eliot Harrison Agent for Drexel Chemical Company Drexel Chemical Company 1700 Channel Avenue Memphis, TN 38106 Subject: Registration Review Label Amendments Incorporating Mitigation from the National Marine Fisheries Services (NMFS) Biological Opinions on the Effects of Carbaryl Product Name: Drexel Carbaryl 2% Bait Granule EPA Registration Number: 19713-630 Application Date: 4/19/24 Decision Number: 595683 Dear Eliot Harrison: 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 of the above referenced product in connection with the NMFS Biological Opinion (BiOp) on the effects of carbaryl on federally listed endangered and threatened species and designated critical habitat in accordance with section 7 of the Endangered Species Act (ESA) of 1973, as amended (16 U.S.C. 1531 et seq.). The Agency 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 FIFRA 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

Page 2 of 2 EPA Reg. No. 19713-630 Decision No. 595683 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. You must submit one copy of the final printed labeling before you release the product for 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. The Agency received the U.S. Fish and Wildlife Services (FWS) BiOp on the effects of EPAs national registration of carbaryl and posted it on the website on April 9, 2025. The Agency plans to incorporate and implement this FWS BiOp when issuing the interim decision for carbaryl. EPA will notify the registrants of any need to submit label amendments within 60 days of the issuance of the interim decision. If you have any questions about this letter, please contact Carolyn Smith at smith.carolyn@epa.gov. Sincerely, Jaclyn Pyne, Team Leader Risk Management and Implementation Branch 3 Pesticide Re-evaluation Division Office of Pesticide Programs Enclosure

Drexel Carbaryl 2% Bait/Granule Insecticide, EPA Reg. No. 19713-630, Rev. March 20, 2025, Page 1 of 11 CARBARYL GROUP 1A INSECTICIDE LABEL FOR AG USE For the control of Cutworms, Armyworms, Darkling beetles, Field crickets, Grasshoppers, House crickets, Mole crickets, Sowbugs and Ants (except Carpenter ants, Fire ants, Harvester ants and Pharaoh ants). ACTIVE INGREDIENT: Carbaryl (1-naphthyl N-methylcarbamate).......................................................................................... ........................... 2.0% OTHER INGREDIENTS:............................................................................................................................... ............... 98.0% TOTAL:............................................................................................................................... ............................... 100.0% KEEP OUT OF REACH OF CHILDREN CAUTION See FIRST AID Below EPA Reg. No. 19713-630 Net Contents: EPA Est. No. 19713-XX-X 100 Lbs. (45.36 Kg) FIRST AID This product is an N-methyl carbamate that inhibits cholinesterase. IF SWALLOWED: • Call a poison control center or doctor immediately for treatment advice. • Have person sip a glass of water if able to swallow. • 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 person. 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 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. Have the container or label with you when calling a poison control center or doctor, or going for treatment. For information on this pesticide product (including health concerns, medical emergencies or pesticide incidents), call the National Pesticide Informat ion Center at 1- 800-858-7378. NOTE TO PHYSICIAN: Carbaryl is an N-methyl carbamate that inhibits cholinesterase. Atropine is antidotal. Do not use 2-PAM (pyridine-2- aldoxime methiodide), opiates or cholinesterase inhibiting drugs. Probable mucosal damage may contraindicate the use of gastric lavage. Manufactured By: Drexel Chemical Company P.O. Box 13327, Memphis, TN 38113-0327 The DREXEL logo is a registered trademark of Drexel Chemical Company. CARBARYL 2% BAIT/GRANULE Insecticide 04/09/2025 19713-630

Drexel Carbaryl 2% Bait/Granule Insecticide, EPA Reg. No. 19713-630, Rev. March 20, 2025, Page 2 of 11

PRECAUTIONARY STATEMENTS Hazards to Humans and Domestic Animals CAUTION: Harmful if swallowed or if absorbed through skin. Avoid contact with eyes, skin or clothing. PERSONAL PROTECTIVE EQUIPMENT (PPE) Some materials that are chemical-resistant to this product are natural rubber, polyethylene or neoprene. If you want more optio ns, follow the instructions for Category A on an EPA chemical-resistance category selection chart. Loaders, applicators and other handlers must wear: Long-sleeved shirt and long pants, chemical-resistant gloves and shoes plus socks. In addition, handlers loading baits into airplanes under the auspices of the Animal Plant Health Inspection Service (APHIS) Rangeland Grasshopper and Mormon Cricket Suppression Program, and allied State programs must wear a NIOSH-approved dust/mist filtering respirator with NIOSH/MSHA approval number prefix TC-21C or a NIOSH-approved respirator with any N, R, P or HE filter. Aerial application is prohibited, except for the aerial applications under the auspices of the Animal Plant Health Inspection S ervice (APHIS) Rangeland Grasshopper and Mormon Cricket Suppression Program, and/or allied State programs. See “ENGINEERING CONTROLS” for additional requirements and exceptions. USER SAFETY 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. ENGINEERING CONTROLS Pilots applying applications under the auspices of the Animal Plant Health Inspection Service (APHIS) Rangeland Grasshopper and Mormon Cricket Suppression Program or related State programs must use an enclosed cockpit in a manner that is consistent with the WPS for Agricultural Pesticides [40 CFR 170.240(d)(6)]. In addition, the cockpit air intake must be located above the bait release poin t and the bait bin must be completely separate from the cockpit. Flaggers supporting aerial applications permitted above must use an enclosed cab that meets the definition in the WPS for Agric ultural Pesticides [40 CFR 170.240(d)(5)] for dermal protection. In addition, flaggers must: • wear long-sleeved shirt, long pants, shoes and socks, • either wear a NIOSH-approved dust/mist filtering respirator with NIOSH/MSHA approval number prefix TC-21C or a NIOSH-approved respirator with any N, R, P or HE filter or use an enclosed cab that is declared in writing by the manufacturer or by a governm ent agency to provide at least as much respiratory protection as this type of respirator, • be provided and have immediately available for use in an emergency when they must exit the cab in the treated area: chemical- resistant gloves and chemical-resistant headgear and, if using an enclosed cab that provides respiratory protection, a respirator of the type specified above, • take off any PPE that was worn in the treated area before reentering the cab, and • store all such PPE in a chemical-resistant container such as a plastic bag, to prevent contamination of the inside of the cab . When applicators use enclosed cabs in a manner that meets the requirements listed in the WPS for Agricultural Pesticides [40 CFR 170.240(d) (5)], the handler PPE requirements may be reduced or modified as specified in the WPS.

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 the gloves before removing. As soon as possible, wash thoroughly and change into clean clothing. ENVIRONMENTAL HAZARDS This product is extremely toxic to aquatic invertebrates. For terrestrial uses, do not apply directly to water or to areas wher e surface water is present or to intertidal areas below the mean high water mark. Do not apply when weather conditions favor drift from the area t reated. Drift and runoff may be hazardous to aquatic invertebrates in water adjacent to treated areas. Do not contaminate water when disposing of equipment washwater or rinsate. 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 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. x Use on rice is prohibited. x Do not apply during rain. Do not apply when soil in the area to be treated is saturated (if there is standing water on the field or if water can be squeezed from soil) or if NOAA/National Weather Service predicts a total rainfall of 1 inch or greater over the 48 hours following the day of application, only considering a 48-hour period when, at any point during the 48-hour period, the precipitation potential is 50% or greater. Detailed National Weather Service forecasts for local weather conditions should be obtained on-line at: www.weather.gov or by contacting your local National Weather Service Forecasting Office. x Do not apply within 25 feet of aquatic habitats (such as, but not limited to, lakes, reservoirs, rivers, permanent streams or ephemeral streams when water is present, wetlands or natural ponds, estuaries, and commercial fish farm ponds). x Spot treatments must not exceed two square feet in size (for example, 2 ft. by 1 ft. or 4 ft. by 0.5 ft). x Do not spray the product into fish pools, ponds, streams, or lakes. Do not apply directly to sewers or storm drains, or to any area like a drain or gutter where drainage to sewers, storm drains, water bodies, or aquatic habitat can occur. x Do not allow the product to enter any drain during or after application. x Do not apply directly to impervious horizontal surfaces such as sidewalks, driveways, and patios except as a spot or crack-and-crevice treatment. x Do not apply to vertical surfaces directly above pervious or impervious surfaces that drain into ditches, storm drains, gutters, or surface waters. x Do not apply or irrigate to the point of runoff. x Treat surfaces to ensure thorough coverage but avoid runoff. x To treat insects harbored in voids and cracks-and-crevices, applications must be made in such a manner to limit dripping and avoid runoff onto untreated structural surfaces and plants.

Drexel Carbaryl 2% Bait/Granule Insecticide, EPA Reg. No. 19713-630, Rev. March 20, 2025, Page 3 of 11

MANDATORY SPRAY DRIFT MANAGEMENT Aerial Applications (for USDA APHIS and affiliated State grasshopper and Mormon cricket suppression programs only): x Do not release spray at a height greater than 10 ft above the ground or vegetative canopy, unless a greater application height is necessary for pilot safety. x Applicators must select nozzle and pressure that deliver medium or coarser droplets in accordance with American Society of Agricultural & Biological Engineers Standard 641 (ASABE S641). x During application, the Sustained Wind Speed, as defined by the National Weather Service (standard averaging period of 2 minutes) must register between 3 and 10 miles per hour. x Wind speed and direction must be measured on location using a windsock, an anemometer, or an aircraft smoke system. x Wind speed must be measured at the release height or higher, in an area free from obstructions such as trees, buildings, and farm equipment. x Applicators must use a minimum of ½ swath displacement upwind at the downwind edge of the treatment area. The boom length must be 75% or less of the wingspan for fixed-wing aircraft and 90% or less of the rotor diameter for helicopters. x Do not apply during temperature inversions. x Do not apply by ground within 150 feet of aquatic habitats (such as, but not limited to, lakes, reservoirs, rivers, permanent streams or ephemeral streams when water is present, wetlands or natural ponds, estuaries, and commercial fish farm ponds).

ENDANGERED AND THREATENED SPECIES PROTECTION REQUIREMENTS: Before using this product, you must obtain any applicable Endangered Species Protection Bulletins (Bulletins) within six months prior to or on the day of application. To obtain Bullet ins, go to Bulletins Live! Two (BLT) at https://www.epa.gov/pesticides/bulletins. When using this product, you must follow all directions and restri ctions contained in any applicable Bulletin(s) for the area where you are applying the product, including any restrictions on application timing if applicable. It is a violation of Federal law to use this product in a manner inconsistent with its labeling, including this labeling instruction to follow all directions and restrictions contained in any applicable Bulletin(s). For general questions or technical help, call 1-844-447-3813, or emai l ESPP@epa.gov.

REPORTING ECOLOGICAL INCIDENTS: For guidance on reporting ecological incidents, including death, injury, or harm to plants and animals, including bees and other non-target insects, see EPAs Pesticide Incident Reporting website: https://www.epa.gov/pesti cide-incidents or call 901-774-4370.

Do not apply this product for agricultural use in Hawaii. Do not apply by air for all uses except for USDA APHIS and affiliated State grasshopper and Mormon cricket suppression programs .

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 the 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 instru ctions and exceptions pertaining to the statements on this label about Personal Protective Equipment (PPE), Restricted-Entry Interval (REI ) and notification to workers. The requirements in this box only apply to uses of this product that are covered in the WPS. Do not enter or allow worker entry into treated areas during the REI. The REI for Carbaryl is 12 hours unless otherwise specifi ed in the directions for use associated with each crop. 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 over long-sleeved shirt and short pants, chemical-resistant gloves made of any wate rproof material, chemical-resistant footwear plus socks, chemical-resistant headgear if overhead exposure. When the REI for a crop is 7 days or longer, you must notify workers of the application by warning them orally and by posting w arning signs at entrances to treated area. USE INFORMATION CARBARYL 2% BAIT/GRANULE is used for the control of Cutworms, Armyworms, Darkling beetles, Field crickets, Grasshoppers, House crickets, Mole crickets, Sowbugs and Ants (except Carpenter ants, Fire ants, Harvester ants and Pharaoh ants). RESISTANCE MANAGEMENT CARBARYL GROUP 1A INSECTICIDE Carbaryl 2% Bait/Granule contains a Group 1A insecticide. Insect biotypes with acquired resistance to Group 1A may eventually d ominate the insect population if Group 1A insecticides are used repeatedly in the same field or in successive years as the primary method o f control for targeted species. This may result is partial or total loss of control of those species by this product other Group 1A insectici des. To delay insecticide resistance, consider: • Avoiding the consecutive use of this product or other Group 1A insecticides that have similar target site of action on the sa me insect species. • Using tank-mixtures or pre-mixes with insecticides from a different target site action Group as long as the involved products are all registered for the same use and have different sites of action. • Basing insecticide use on a comprehensive IPM program. • Monitoring treated insect populations for loss of field efficacy. Contacting your local extension specialist, certified crop advisors, and/or manufacturer for insecticide resistance management and/or IPM recommendations for specific site and resistant pest problems. IMPORTANT PRE-HARVEST AND GRAZING INFORMATION Tolerances established under the Federal Food, Drug and Cosmetic Act permit the sale of crops bearing probable Carbaryl residue s when Carbaryl is used in accordance with the label directions. If Carbaryl is used in accordance with label directions, Carrot tops, Corn forage and Sugar beet tops may be grazed or harvested for use as feed for dairy and meat animals without resulting in illegal residues in milk or meat. METHOD OF APPLICATION This product may be applied only by ground using a mechanical spreader or underground shank applicator. DO NOT apply by hand, s poon or belly grinder. EXCEPTION: Aerial applications only to Rangeland are allowed only under the auspices of the Animal Plant Health Inspection Service (APHIS) Rangeland Grasshopper and Mormon Cricket Suppression Program and/or allied State programs.

Drexel Carbaryl 2% Bait/Granule Insecticide, EPA Reg. No. 19713-630, Rev. March 20, 2025, Page 4 of 11

CROP SPECIFIC USE INSTRUCTIONS/RESTRICTIONS Asparagus Application to Spears: Apply 50 lbs. per acre per application (1 lb a.i./acre). Maximum yearly usage is 150 lbs. per acre (3 lbs. ai/acre/year). Application to Ferns (after harvest of spears): Apply 100 lbs. per acre per application (2 lbs a.i./acre). Maximum yearly usage is 100 lbs. per acre (2 lbs a.i./acre). Use Restrictions: Total combined maximum application for spears and ferns is 250 lbs. per acre per year (5 lbs/ai/acre/year). Minimum retreatment interval is 7 days. Do not apply within 1 day of harvest. The total number of applications per season is 4. Make 2-3 applications before harvest and 1-2 additional applications only to ferns. Do not exceed 4 total applications per year. Carrots, Garden beets (roots), Horseradish, Parsnips, Radish, Rutabaga, Salsify, Turnips (roots) Apply 100 lbs. per acre per application (2 lbs a.i./acre). Maximum yearly usage is 300 lbs. per acre (6 lbs/ai/acre/year). Use Restrictions: Minimum retreatment interval is 7 days. Do not apply within 7 days of harvest. Do not apply more than 3 times per year. Garden beets (tops), Turnips (tops) Apply 100 lbs. per acre per application. Maximum yearly usage is 300 lbs. per acre. Use Restrictions: Minimum retreatment interval is 7 days. Do not apply within 14 days of harvest. Do not apply more than 3 times per year. All members of the Head and Stem Brassica vegetables Subgroup 5A including: Broccoli, Brussels sprouts, Cabbage, Cauliflower, Cavalo broccolo, Chinese broccoli (Gai lon), Chinese cabbage (Napa), Chinese mustard cabbage (Gai choy), Kohlrabi Apply 100 lbs. per acre per application (2 lbs a.i./acre). Maximum yearly usage is 300 lbs. per acre (6 lbs/ai/acre/year).. Use Restrictions: Apply only within 30 days of crop emergence or transplanting. Minimum retreatment interval is 7 days. Do not apply within 3 days of harvest. Do not apply more than 3 times per year. All members of the Brassica leafy vegetables Subgroup 5B: Chinese cabbage (Bok choy), Collards, Kale, Mizuna, Mustard greens, Mustard spinach, Rape greens, Turnip greens Apply 100 lbs. per acre per application. Maximum yearly usage is 200 lbs. per acre. (4 lbs/ai/acre/year). Use Restrictions: Apply only within 30 days of crop emergence or transplanting. Minimum retreatment interval is 7 days. Do not apply within 14 days of harvest. Do not apply more than 3 times per year. Corn (Field, Pop) (REI* = 24 hrs.) Apply 100 lbs. per acre per application (2 lbs a.i./acre). Maximum yearly usage is 400 lbs. per acre (8 lbs/ai/acre/year). Use Restrictions: Minimum retreatment interval is 14 days. Do not apply within 14 days of harvest of forage or silage. Do not apply more than 48 days of harvest of grain or fodder. Do not apply more than 4 times per year. REI is 24 hours. Exception: the REI is 21 days for workers detasselling corn. Hand harvesting is prohibited. Corn (Sweet) (REI = 24 hrs.) Apply 100 lbs. per acre per application (2 lbs a.i./acre). Maximum yearly usage is 800 lbs. per acre (8 lbs/ai/acre/year). Use Restrictions: Minimum retreatment interval is 3 days. Do not apply within 2 days of harvest of ears. Do not apply within 14 days of harvest of forage. Do not apply more than 48 days of harvest of fodder. Do not apply more than 4 times per year. *REI is 24 hours. Exception: the REI is 21 days for workers detasselling corn. Hand harvesting is prohibited.

All members of the Cucurbit Vegetable Group 9 including: Chayote (fruit), Chinese waxgourd, Citron melon, Cucumber, Gherkin, Gourd (edible), Momordica spp. (includes Balsam apple, Balsam pear, Bitter melon, Chinese cucumber), Melons, Pumpkin, Squash (includes Summer types such as Crookneck, Scallop, Straightneck, Vegetable marrow, Zucchini and Winter types such as Acorn, Butternut, Calabaza, Cushaw, Hubbard, Spaghetti Squash) Apply 50 lbs. per acre per application (1 lb a.i./acre). Maximum yearly usage is 200 lbs. per acre (4 lbs/ai/acre/year). Use Restrictions: Minimum retreatment interval is 7 days. Do not apply within 3 days of harvest. Do not apply more than 4 times per year. Grain Sorghum Apply 100 pounds per acre per application (2 lbs a.i./acre). Maximum yearly usage is 300 lbs. per acre. (6 lbs/ai/acre/year). Use Restrictions: Minimum retreatment interval is 7 days. Do not apply more than 4 times per year. Continued…

Drexel Carbaryl 2% Bait/Granule Insecticide, EPA Reg. No. 19713-630, Rev. March 20, 2025, Page 5 of 11

SPECIFIC USE INSTRUCTIONS/RESTRICTIONS continued… Pistachios (non-bearing trees only) Apply 100 lbs. per acre per application (2 lbs a.i./acre). Maximum yearly usage is 500 lbs. per acre (10 lbs/ai/acre/year). If weeds or cover crops bloom is present, mow orchard or between rows prior to applying this product. Use Restrictions: Minimum retreatment interval is 7 days. Use only on trees that will not bear fruit for 1 year from date of application. Potatoes Apply 100 lbs. per acre per application (2 lbs a.i./acre). Maximum yearly usage is 300 lbs. per acre (6 lbs/ai/acre/year).. Use Restrictions: Minimum retreatment interval is 7 days. Do not apply within 7 days of harvest. Do not apply more than 3 times per year. Sugarbeets Apply 30 lbs. per acre per application (0.6 lbs/ai/acre/year).. Maximum yearly usage is 60 lbs. per acre (1.2 lbs a.i./acre). Use Restrictions: Minimum retreatment interval is 14 days. Do not apply within 28 days of harvest of roots or forage. Do not apply more than 2 times per year. All members of the Fruiting Vegetable Group 8 including: Eggplant, Groundcherry, Pepinos, Peppers, Tomatillo, Tomato Apply 100 lbs. per acre per application (2 lbs a.i./acre). Maximum yearly usage is 400 lbs. per acre (8 lbs/ai/acre/year).. Use Restrictions: Minimum retreatment interval is 7 days. Do not apply within 3 days of harvest. Do not apply more than 4 times per year. Pasture and Grasses grown for hay or seed Apply up to maximum of 75 lbs. per acre per application (1.5 lbs a.i./acre). Maximum yearly usage is 150 lbs. per acre (3 lbs. ai/acre/year). Use Restrictions: Minimum retreatment interval is 14 days. Do not apply within 7 days of harvest or grazing. Do not apply more than 2 times per year. Rangeland Ground Application Only: Apply up to a maximum of 50 lbs. per acre (1 lb a.i./acre). Use Restrictions: Do not apply more than once per year. USDA Aphis Program for Mormon Cricket and Grasshopper Suppression: Apply 10 lbs. per acre per application (0.2 lbs a.i./acre). Maximum yearly usage is 20 lbs. per acre (0.4 lbs/ai/acre/year). Use Restrictions: Minimum retreatment interval is 14 days. Do not apply more than 2 times per year. Use of flaky bran bait for aerial application is prohibited. Aerial application is allowed ONLY through USDA Aphis and affiliated State Grasshopper and Mormon Cricket suppression programs. USDA APHIS REDUCED AREA AND AGENT TREATMENTS (RAATS): The RAATs approach takes advantage of grasshopper movement to allow [ insert product name] to be applied at reduced rates on a reduced treated area while maintaining acceptable protection against grasshopper. Under this program, Drexel Carbaryl 2% Bait-Granule may be applied to as little as 50% of the infested area (treating a 100 ft swath, skipping a 100 ft swath), up to 100% of infested area. The amount of area treated will depend on grasshopper age, density and plant can opy. By leaving untreated swaths, the RAATs program provides reserves for natural biological control agents. This strategy fully utilizes an Integrated Pest Management approach for grasshopper. Apply 10 lbs. per acre per application (0.2 lbs a.i./acre) on 50 100% of infested area for grasshopper nymphs between the 2nd and 5th instar. The rate to use per acre will depend on grasshopper age, population density, and plant canopy. Use the higher rates on more mature grasshoppers, severe infestations and dense vegetation. Use the lower rates on younger grasshoppers, light to moderate infestations and sparse vegetation. Consult with the local grasshopper control experts in your area for the proper rate and swath width to use under your conditions.

STORAGE AND DISPOSAL Do not contaminate water, food or feed by storage or disposal. STORAGE: Store in original container only and keep sealed. Store in a cool, dry and closed storage area. Keep container tightly closed when not in use. Reduce stacking height where local conditions such as humidity or pallet overhang can affect package strength. Observe precautions when moving, opening, pouring or closing. PESTICIDE DISPOSAL: Wastes resulting from the use of this product may be disposed of on site or at an approved waste disposal facility. CONTAINER HANDLING: Nonrefillable container. Do not reuse or refill this container. Offer for recycling, if available. Dispose of empty container in a sanitary landfill, by incineration or, if allowed by State and local authorities, by burning. If burned, stay ou t of smoke. WARRANTY—CONDITIONS OF SALE Our DIRECTIONS FOR USE of this product are based upon tests believed reliable. Follow directions carefully. Timing and method of application, weather and crop conditions, mixtures with other chemicals not specifically directed and other influencing factors in the use o f 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 the directions given herewith. To the extent consistent with applicable law, in no case shall the Manufacturer or the Seller be liable for consequential, spec ial or indirect damages resulting from the use or handling of this product when such use and/or handling is not in strict accordance with the d irections given herewith. The foregoing is a condition of sale by the Seller and is accepted as such by the Buyer.

The DREXEL logo is a registered trademark of Drexel Chemical Company. All other brand names, product names or trademarks belong to their respective holders.

Drexel Carbaryl 2% Bait/Granule Insecticide, EPA Reg. No. 19713-630, Rev. March 20, 2025, Page 6 of 11

CARBARYL GROUP 1A INSECTICIDE

LABEL FOR OUTDOOR RESIDENTIAL USE

FOR OUTDOOR RESIDENTIAL USE ONLY ACTIVE INGREDIENT: Carbaryl (1-naphthyl N-methylcarbamate) ....................................................................................... .............................. 2.0% OTHER INGREDIENTS: .............................................................................................................................. ................ 98.0% TOTAL: .............................................................................................................................. ................................ 100.0% KEEP OUT OF REACH OF CHILDREN CAUTION See FIRST AID Below EPA Reg. No. 19713-630 Net Contents: EPA Est. No. 19713-XX-X 10 Lbs. (4.54 Kg) FIRST AID This product is an N-methyl carbamate that inhibits cholinesterase. IF SWALLOWED: • Call a poison control center or doctor immediately for treatment advice. • Have person sip a glass of water if able to swallow. • 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 person. 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 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. Have the container or label with you when calling a poison control center or doctor, or going for treatment. For information on this pesticide product (including health concerns, medical emergencies or pesticide incidents), call the National Pesticide Informat ion Center at 1- 800-858-7378. NOTE TO PHYSICIAN: Carbaryl is an N-methyl carbamate that inhibits cholinesterase. Atropine is antidotal. Do not use 2-PAM (pyridine- 2-aldoxime methiodide), opiates or cholinesterase inhibiting drugs. Probable mucosal damage may contraindicate the use of gastr ic lavage.

PRECAUTIONARY STATEMENTS Hazards to Humans and Domestic Animals CAUTION: Harmful if swallowed or if absorbed through skin. Avoid contact with eyes, skin or clothing. Wear long-sleeved shirt and long pants, shoes plus socks and chemical-resistant gloves (household or latex rubber gloves) when handling this product. Remove clothing i mmediately if pesticide gets inside. Then wash thoroughly and put on clean clothing. Wash hands before eating, drinking, chewing gum, usin g tobacco or using the toilet. Remove contaminated clothing and wash before reuse. ENVIRONMENTAL HAZARDS This product is extremely toxic to aquatic invertebrates. Do not apply directly to water or allow drift to water. Drift and runoff may be hazardous to aquatic organisms in water adjacent to treated areas. To protect the environment, do not allow pesticide to enter or run off into storm drains, drainage ditches, gutters or surface waters. Applying this product in calm weather when rain is not predicted for the next 48 hours will help to ensure that wind or rain does not blow or wash pesticide off the treatment area. Sweeping any product that lands on a driveway, sidewalk or street back onto the treated area of the lawn or garden will help to prevent runoff to water bodies or drainage systems. Manufactured By: Drexel Chemical Company P.O. Box 13327, Memphis, TN 38113-0327

The DREXEL logo is a registered trademark of Drexel Chemical Company. All other brand names, product names or trademarks belong to their respective holders. CARBARYL 2% BAIT/GRANULE Insecticide

Drexel Carbaryl 2% Bait/Granule Insecticide, EPA Reg. No. 19713-630, Rev. March 20, 2025, Page 7 of 11

Read the entire label before using this product. DIRECTIONS FOR USE It is a violation of Federal law to use this product in a manner inconsistent with its labeling. Do not allow people or pets to enter the treated area until dusts have settled. Do not allow people except those involved in the watering-in or pets to enter the treated area until the watering-in is completed and the area has dried. Do not apply this product in a way that will contact any person or pet either directly or through drift. Keep people and pets o ut of the area during application. For outdoor use only. Do not apply by hand, spoon or belly grinder. Product must be watered-in immediately following application. Not for use on plants grown for sale or commercial use, research or commercial seed production. For terrestrial uses: Do not apply directly to water, or to areas where surface water is present or to intertidal areas below the mean high water mark. Do not contaminate water when disposing of equipment washwater or rinsate.

To protect the environment, do not allow pesticide to enter or run off into storm drains, drainage ditches, gutters or surface waters. Applying this product in calm weather when rain is not predicted for the next 48 hours will help to ensure that wind or rain does not blow or wash pesticide off the treatment area. Sweeping any product that lands on a driveway, sidewalk, or street, back onto the treated area of the lawn or garden will help to prevent run off to water bodies or drainage systems.

REPORTING ECOLOGICAL INCIDENTS: For guidance on reporting ecological incidents, including death, injury, or harm to plants and animals, including bees and other non-target insects, see EPAs Pesticide Incident Reporting website: https://www.epa.gov/pesticide-inci dents or call 901-774-4370.

Do not apply within 25 feet of aquatic habitats (such as, but not limited to, lakes, reservoirs, rivers, permanent streams or e phemeral streams when water is present, wetlands or natural ponds, estuaries, and commercial fish farm ponds).

All outdoor applications, unless permitted elsewhere on this label, must be limited to spot or crack-and-crevice treatments onl y, except for the following permitted uses:

  1. Applications to soil, lawn, turf, or vegetation;
  2. Perimeter band treatments of 6 ft wide or less from the base of a man-made structure to pervious surfaces (e.g., soil, mulch , or lawn);
  3. Applications around potential exterior pest entry points into man-made structures such as doorways and windows, when limited to a band not to exceed one inch;
  4. Applications to vertical surfaces directly above pervious surfaces, such as bare soil, lawn, turf, mulch or other vegetation , that do not drain into ditches, storm drains, gutters, or surface waters.

Spot treatments must not exceed two square feet in size (for example, 2 ft. by 1 ft. or 4 ft. by 0.5 ft).

Do not spray the product into fish pools, ponds, streams, or lakes. Do not apply directly to sewers or storm drains, or to any area like a drain or gutter where drainage to sewers, storm drains, water bodies, or aquatic habitat can occur.

Do not allow the product to enter any drain during or after application.

Do not apply directly to impervious horizontal surfaces such as sidewalks, driveways, and patios except as a spot or crack-and- crevice treatment.

Do not apply to vertical surfaces directly above pervious or impervious surfaces that drain into ditches, storm drains, gutters , or surface waters.

Do not apply or irrigate to the point of runoff.

Treat surfaces to ensure thorough coverage but avoid runoff.

To treat insects harbored in voids and cracks-and-crevices, applications must be made in such a manner to limit dripping and av oid runoff onto untreated structural surfaces and plants.

Drexel Carbaryl 2% Bait/Granule Insecticide, EPA Reg. No. 19713-630, Rev. March 20, 2025, Page 8 of 11

LAWNS, ORNAMENTAL AND RECREATIONAL TURF Use this product when insect pests first appear and/or plant damage is imminent. For best results, first mow the lawn and then apply this product uniformly to dry Turfgrass with a spreader. Repeat applications as necessary but not to exceed 4 times per year at minimum 7 da y intervals. Will kill target pests that are present only at the time of application. Pests must be directly contacted for this product to b e effective. DO NOT Apply more than 10 lbs/ai/acre/year.

PEST This Product per 1000 sq. ft. (Lbs.)

Use Instructions Ants (excluding Harvester, Carpenter and Pharaoh ants); Armyworms; Centipedes; Chiggers; Chinch bugs; Cutworms; Earwigs; Essex skipper; European chafer; Fall armyworm; Fiery skipper; Grasshoppers; Green June beetle larvae; Leafhoppers; Leafrollers; Lucerne moth; Millipedes; Scarab beetles (adults): such as Green June beetles, May beetles, Japanese beetles, June beetles; Sod webworms (Lawn moths); Sowbugs; Spittlebugs; Springtails; Yellowstriped armyworms 2.25 (0.045 lb/ai/1000 sq. ft.) Immediately water-in the product following application. For heavy infestations of Chinch bugs, increase the rate of this product to 5 pounds per 1000 square feet. Treat the entire area. To kill subsurface pests effectively, apply when they are actively feeding near the soil surface, usually during late March through May, or July through early September or as guided by local agricultural extension service agents. Billbug larvae; European crane fly larvae; Fleas; White grubs such as Japanese beetle larvae, Chafer beetle larvae, Phyllophaga spp. larvae, annual White grubs, Black turfgrass ataenius beetle larvae, Hyperodes weevil (Bluegrass weevil larvae) 9 (0.18 lb/ai/1000 sq. ft.) Scorpions 5 (0.1 lb/ai/100 sq. ft.) Fleas 7 to 9 (0.14 to 0.18 lb.ai/1000 sq. ft.) Ticks 1.15 (0.023 lb ai/1000 sq. ft.) TICKS THAT MAY VECTOR LYME DISEASE To kill juvenile and adult Ixodes spp. Ticks (Deer ticks, Black legged ticks) and Lone star ticks which may vector Lyme disease , apply 1.15 pounds of this product per 1000 square feet (0.023 lb ai/1000 sq. ft.) with a spreader to ensure uniform coverage. Target applications to kill juvenile Ticks (larvae and nymphs) in late Spring or early Summer (May/June). Adult Ticks can be killed with late Summer and Fall applic ations (August/September). Apply to lawns, ornamental plantings, shrub beds, wooded areas and around outside perimeters of home and ot her buildings. Treat entire lawn and perimeter wooded areas and property boundaries where exposure to Ticks may occur. Irrigate tre ated areas thoroughly after application to move the chemical down into the thatch. Ticks may be reintroduced from surrounding areas or hos t animals. Repeat applications as necessary up to a maximum of 4 times per year at minimum 7 day intervals. Will kill target pests that ar e present only at the time of application. Ticks must be directly contacted for this product to be effective. FLOWERS AND SHRUBS (ORNAMENTAL PLANTINGS) IN LANDSCAPE AND FOUNDATION PLANTINGS

PEST* This Product per 1000 sq. ft. (Lbs.)

Use Instructions Ants (except Carpenter, Harvester and Pharaoh ants); Armyworms; Centipedes; Crickets; Cutworms; Earwigs; Firebrats; Silverfish; Spiders 2.25 to 5 (0.045 to 0.1 lb/ai/100 sq. ft.) Application to wet foliage during periods of high humidity may cause injury to tender foliage. Apply this product using a spreader in a 6 foot band around the home, flowerbeds and shrubs, foundations, ornamental plantings and lawn or soil areas immediately adjacent to the home. Thoroughly water treated areas after application. Repeat as necessary but not to exceed 3 times per year at minimum 7 day intervals. Do not use on plants above chest height. Fleas 7 to 9 (0.14 to 0.18 lb.ai/1000 sq. ft.) Scorpions 5 (0.1 lb/ai/100 sq. ft.) Ticks 1.15 (0.023 lb ai/1000 sq. ft.)

  • Will kill target pests that are present only at the time of application. Pests must be directly contacted for this product to be effective.

Drexel Carbaryl 2% Bait/Granule Insecticide, EPA Reg. No. 19713-630, Rev. March 20, 2025, Page 9 of 11

NUISANCE PESTS AROUND THE OUTSIDE OF HOMES, PATIOS, PORCHES AND BUILDINGS To kill the following pests:

PEST* This Product per 1000 sq. ft. (Lbs.)

Use Instructions Ants (except Carpenter, Harvester and Pharaoh ants); Armyworms; Centipedes; Crickets; Cutworms; Earwigs; Firebrats; Millipedes; Silverfish; Sowbugs (Pillbugs); Spiders 2.3 (0.046 lb ai/1000 sq. ft.) Apply this product uniformly using a spreader in an 8-foot band around the outside perimeter of home. Apply this product to shrub and flower beds, foundations, ornamental plantings and lawn or soil areas immediately adjacent to the home. Thoroughly water treated areas after application. Repeat as necessary but not to exceed 4 times per year at minimum 7 day intervals. Fleas 4 to 9 ((0.08 to 0.18 lb/ai/1000 sq. ft.) Ticks 1.15 (0.023 lb ai/1000 sq. ft.) Scorpions 5 (0.1 lb/ai/100 sq. ft.)

  • Will kill target pests that are present only at the time of application. Pests must be directly contacted for this product to be effective. NUISANCE PESTS IN STRAWBERRIES AND LISTED GARDEN VEGETABLES To kill Ants (except Carpenter, Harvester and Pharaoh ants); Centipedes; Crickets; Cutworms; Earwigs; Grasshoppers; Millipedes; Sowbugs (Pillbugs) and Springtails, apply this product with a spreader at the rates given in the following table. Begin applications wh en pest or damage is observed and repeat as directed below. Water lightly after application to release the chemical from the granules. Retreatment intervals (days between treatments) and other restrictions are found listed in the following table. Observe the listed Pre-Harvest Intervals (PHI) which is the number of days between last application and harvest, for application during the growing season.

Crop This Product per 1000 sq. ft. (Lbs.) Maximum Yearly Application (Lbs./1000 sq. ft.) Retreatment Interval (Days)

PHI (days)

Remarks Asparagus (Ferns*) 2.3 (0.046 lb ai/1000 sq. ft.) 4.6 (0.092 lb ai/1000 sq. ft./year) 7 1 Total maximum seasonal application rate is 11.5 lbs. per 1000 sq. ft. per crop. The total number of applications is 4. Make 2-3 applications before harvest and 1-2 additional applications only to ferns. Do not exceed 4 total applications per year. *After harvest of spears. Asparagus (Spears) 2.3 (0.046 lb ai/1000 sq. ft.) 6.9 (0.138 lb. ai/1000 sq. ft./year) 7 1 Broccoli, Brussels sprouts, Cabbage, Cauliflower, Chinese cabbage, Collards, Kale, Kohlrabi, Mustard greens 1.7 to 2.3 (0.034 to 0.046 lb ai/1000 sq. ft.) 6.9 (0.138 lb. ai/1000 sq. ft./year) 7 3 (Broccoli, Brussels sprouts, Cabbage, Cauliflower, Kohlrabi) 14 (Chinese cabbage, Collards, Kale, Mustard greens) Total number of applications per crop can be 4 (some of which must be lower than the maximum single application rate). Application is only permitted within 30 days of crop emergence or the date of planting. Carrots, Garden beets (roots), Horseradish, Parsnips, Radishes, Rutabaga, Salsify, Turnips (roots) 1.2 to 2.3 (0.024 to 0.046 lb ai/1000 sq. ft.) 6.9 (0.138 lb. ai/1000 sq. ft./year) 7 7 Total number of applications per crop can be 6 (some of which must be lower than the maximum single application rate). Cucumber, Melons, Squash 1.2 (0.024 lb ai/1000 sq. ft.) 6.9 (0.138 lb. ai/1000 sq. ft./year) 7 3 Total number of applications per crop can be 4. Edible-podded legume vegetables including Jack beans, Snap beans, Wax beans, Yardlong beans, Edible pod pea, Snow pea, Sugar snap pea; Dried- shelled beans and peas including Adzuki beans, Field beans, Kidney beans, Lima beans (dry), Mung beans, Navy beans, Pinto beans, Blackeyed peas, Cowpeas, Southern peas, Lentils (dry) 1.7 6.9 (0.138 lb. ai/1000 sq. ft./year) 7 3 (Edible-podded) 21 (Dried-shelled) Total number of applications per crop can be 4. Use on succulent Beans or Peas is prohibited. Eggplant, Pepper, Tomato 2.3 (0.046 lb ai/1000 sq. ft.) 9.2 (0.18 lb ai/1000 sq. ft./year) 7 3 Total number of applications per crop can be 4.

Drexel Carbaryl 2% Bait/Granule Insecticide, EPA Reg. No. 19713-630, Rev. March 20, 2025, Page 10 of 11

Garden beets (tops), Turnips (tops) 2.3 (0.046 lb ai/1000 sq. ft.) 6.9 (0.138 lb. ai/1000 sq. ft./year) 7 14 Total number of applications per crop can be 3. Potatoes 2.3(0.046 lb ai/1000 sq. ft.) 6.9 (0.138 lb. ai/1000 sq. ft./year) 7 7 Total number of applications per crop can be 3. Strawberries 2.3 (0.046 lb ai/1000 sq. ft.) 11.5 (0.23 lb ai/1000 sq. ft./year) 7 7 Total number of applications per crop can be 4.Maximum application rate must not exceed 8 lb/ai/year.

This product is applied using a ground spreader. Spreaders and settings are found below. Do not repeat applications more often than indicated above. [Add/delete or adjust settings as appropriate].

Spreader Spreader Settings Pounds Per 1000 sq. ft. 2.3 Lbs. 4.6 Lbs. Scotts Even Green 18” 15 16* Scotts Speedy Broadcast 14 15* Red Devil Broadcast 12 13* Red Devil Drop 20” 12 13* Republic EZ Drop 18” 8 10 Republic EZ Broadcast 9 13* Republic EZ Tractor Broadcast 9 13* Other Spreaders as appropriate TBD TBD

  • This number indicates a criss-cross application will be required to apply the number of pounds shown for 1000 sq. ft. [Alternative Spreader Settings for Peanut Hulls Formulation] Spreader Type Rate (Lbs./1000 sq. ft.) Setting Agri-Fab 85 Lb. Spreader Model #4503123062 Rotary 2.25 4.6 6.8 9.2 6 7 8 10 Craftsman Model #486-19760 Drop 2.25 2.33 4.6 5 5.25 7 Craftsman Rotary (0195) Rotary 2.25 4.6 6.8 9.2 6 10 15 N/A* Cyclone Rotary Rotary 2.25 4.6 6.8 9.2 5 6 8 N/A* Earthways EV-N-Spred Rotary Rotary 2.25 4.6 6.8 9.2 14 18 27 N/A* Earthway Rotary Rotary 2.25 4.6 6.8 9.2 14 18 27 N/A* Precision EZ Spread SB550 Rotary 2.25 4.6 6.8 9.2 7 9 N/A* N/A* Pursells Sta-Green SB4500 Drop 2.25 2.33 4.6 6.8 9.2 3 3.2 4 N/A* Republic EZ Drop 2.25 4.6 6.8 9.2 9 12 13 13 Scott Accugreen Model AG-3 Drop 2.25 2.33 4.6 8 9 12 Scotts Precision Green P4 Drop 2.25 4.6 6.8 9.2 8 11 14 16.5 Scott Speedygreen Model 1000 Rotary 2.25 2.33 4.6 3.75 4 7 Scotts Speedygreen 3000 Rotary 2.25 4.6 6.8 9.2 8 N/A* N/A* N/A*
  • N/A Not applicable; no setting for this rate.

Drexel Carbaryl 2% Bait/Granule Insecticide, EPA Reg. No. 19713-630, Rev. March 20, 2025, Page 11 of 11

STORAGE AND DISPOSAL Do not contaminate water, food or feed by storage or disposal. STORAGE: Store in original container only and keep sealed. Store in a cool, dry and closed storage area away from children and animals. Keep container tightly closed when not in use. PESTICIDE DISPOSAL: Call your local solid waste agency for disposal instructions. Never place unused product down any indoor or outdoor drain. CONTAINER HANDLING: Nonrefillable container. Do not reuse or refill this container. If empty, place in trash or offer for recycling if available. If partially filled, call your local solid waste agency for disposal instructions. Never place unused product down any indoor or outdoor drain. WARRANTY—CONDITIONS OF SALE OUR DIRECTIONS FOR USE of this product are based upon tests believed reliable. Follow directions carefully. Timing and method of application, weather and crop conditions, mixtures with other chemicals not specifically directed and other influencing factors in the use o f 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 the directions given herewith. To the extent consistent with applicable law, in no case shall the Manufacturer or the Seller be liable for consequential, spec ial or indirect damages resulting from the use or handling of this product when such use and/or handling is not in strict accordance with the d irections given herewith. The foregoing is a condition of sale by the Seller and is accepted as such by the Buyer.

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

Optional Marketing Statements: • Easy to use granules • Kills Japanese beetles • Slow release granules • Kills numerous [Over 30] listed pests on lawns and ornamentals • Covers up to square feet [sq. ft.] • Use on lawns, ornamentals and around home • For home lawns • For use on vegetables and fruits • For outdoor use only • To kill Fire ants, Ticks (including those that may vector Lyme disease)