crop-chem-docs/corpus/epa_ppls/2935-552.md

VENDETTA

• EPA Reg No: 2935-552
• Registrant: WILBUR-ELLIS COMPANY LLC
• Signal word: Warning
• Active ingredients: MCPA, 2-ethylhexyl ester (34%); Bromoxynil octanoate (31.7%)
• Label accepted: 2022-12-19
• Source PDF: https://www3.epa.gov/pesticides/chem_search/ppls/002935-00552-20221219.pdf

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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY WASHINGTON, DC 20460

OFFICE OF CHEMICAL SAFETY AND POLLUTION PREVENTION

December 19, 2022

Anne Downs Senior Registration Specialist Wilbur-Ellis Company LLC 2903 S. Cedar Avenue Fresno, CA 93725

Subject: Registration Review Label Amendments Incorporating Mitigation Measures from the Interim Decisions for Bromoxynil and MCPA and the National Marine Fisheries Services’ (NMFS) Biological Opinion on the Effects of Bromoxynil on Pacific Salmonids Product Name: VENDETTA EPA Registration Number: 2935-552 Application Date: 5/19/2020, 5/23/2022, and 12/12/2022 Decision Number: 563063, 584994, and 589127

Dear Anne Downs:

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 Bromoxynil and MCPA Interim Decisions. The Agency has concluded that your submission is acceptable.

This letter also addresses the label mitigation resulting from the NMFS’ Biological Opinion on the effects of Bromoxynil on Pacific salmonids. The Agency has concluded that your submission is also 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 company’s 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 product’s 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 EPA’s Office of Enforcement and Compliance.

Page 2 of 2 EPA Reg. No. 2935-552 Decision No. 563063, 584994, and 589127

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.

If you have any questions about this letter, please contact Quinn Gavin at gavin.quinn@epa.gov.

Sincerely,

Linda Arrington, Branch Chief Risk Management and Implementation Branch 4 Pesticide Re-Evaluation Division Office of Pesticide Programs

Enclosure

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FOR CONTROL OF CERTAIN BROADLEAF WEEDS IN SMALL GRAINS (WHEAT, BARLEY, OATS AND RYE), CONSERVATION RESERVE PROGRAM (CRP) AREAS, GRASSES GROWN FOR SEED OR SOD PRODUCTION AND FLAX ACTIVE INGREDIENTS: % By Wt. Octanoic acid ester of bromoxynil (3,5-dibromo-4-Hydroxybenzonitrile)........................................31.7% 2-Ethylhexyl ester of 2-methyl-chlorophenoxyacetic acid**..............................................................34.0% OTHER INGREDIENTS**................................................................................................................ 34.3% TOTAL: ............................................................................................................................................100.0%

• Bromoxynil octanoate equivalent to 21.8% of bromoxynil or not less than 2.0 pounds of bromoxynil per gallon. ** Equivalent to 21.8% 2-methyl-chlorophenoxyacetic acid or not less than 2.0 pounds MCPA acid per gallon. ***Contains petroleum distillates EPA Reg. No. 2935-552 EPA Est. No. 228-IL-1

KEEP OUT OF REACH OF CHILDREN WARNING – AVISO Si usted no entiende la etiqueta, busque a alguien para que se la explique a usted en detalle. (If you do not understand the label, find someone to explain it to you in detail.) See inside booklet for First Aid and Additional Precautionary Statements. FIRST AID If swallowed: • Immediately call a poison control center or doctor for treatment advice. • Do not give any liquid to the person. • Do not induce vomiting unless told to do so by the poison control center or doctor. • Do not give anything to an unconscious person. If in eyes: • Hold eye open and rinse slowly and gently with water for 15-20 minutes. • Remove contact lenses, if present, after the first 5 minutes, then continue rinsing. • Call a poison control center or doctor for treatment advice. If on skin: • Take off contaminated clothing. • Rinse skin immediately with plenty of water for 15-20 minutes. • Call a poison control center or doctor for treatment advice. If inhaled: • Move person to fresh air. • If person is not breathing, call 911 or an ambulance, then give artificial respiration, preferably by 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 contact EMERGENCY TELEPHONE NUMBERS. (800) 424-9300 CHEMTREC (transportation and spills) (800) 222-1222 POISON CONTROL CENTER (human health) (888) 426-4435 ASPCA (animal health) NOTE TO PHYSICIAN: Contains petroleum distillate, vomiting may cause aspiration pneumonia. Bromoxynil GROUP 6 HERBICIDE MCPA GROUP 4 HERBICIDE Dec 19, 2022 2935-552

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PRECAUTIONARY STATEMENTS HAZARDS TO HUMANS AND DOMESTIC ANIMALS WARNING: May be fatal if swallowed. Harmful if absorbed through skin or inhaled. Causes moderate eye irritation. Avoid contact with skin, eyes or clothing. Prolonged or frequently repeated skin contact may cause allergic reactions in some individuals. Avoid breathing spray mist.

PERSONAL PROTECTIVE EQUIPMENT (PPE)

Mixers, loaders, applicators, flaggers, equipment cleaners, and other handlers must wear: • Coveralls over a long-sleeved shirt and long pants, • Chemical-resistant gloves made of barrier laminate, neoprene rubber >14 mils, nitrile rubber >14 mils, or viton > 14 mils, • Chemical-resistant apron when cleaning equipment, mixing, and loading, • Protective eyewear, • Chemical-resistant headgear for overhead exposure, • Chemical-resistant footwear plus socks.

Mixers and loaders supporting aerial application must also wear: • A Chemical-resistant apron, and • A NIOSH-approved particulate respirator with any N, R, or P filter with NIOSH approval number prefix TC-84A; or a NIOSH-approved powered air purifying respirator with HE filter with NIOSH approval number prefix TC-21C. It is recommended the respirator wearer be fit tested, and trained in the use, maintenance, and limitations of the respirator.

See “Engineering Controls” for additional requirements.

Discard clothing and other absorbent materials that have been drenched or heavily contaminated with this product’s concentrate. Do not reuse them. Follow manufacturer’s 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 Handlers must use closed mixing loading systems during mixing/loading liquids for aerial applications to fallow land and high-acreage field crops.

Handlers must use closed mixing loading systems during mixing and loading liquids for aerial application to barley, flax, oats, pasture and rangeland grass, rye, triticale, wheat, and grass grown for seed.

When handlers use closed systems, enclosed cabs, or aircraft in a manner that meets the requirements listed in the Worker Protection Standard (WPS) for agricultural pesticides [40CFR 170.240(d)4-6)], the handler PPE requirements may be reduced or modified as specified in the WPS. IMPORTANT: When reduced PPE is worn because a closed system is being used, handlers must be provided all PPE specified above for “applicators and other handlers” and have such PPE immediately available for use in an emergency, such as a spill or equipment breakdown.

Pilots must use an enclosed cockpit that meets the requirements listed in the WPS for agricultural pesticides [40 CFR 170.240(d) (4-6)].

If you will handle a total of 60 gallons or more of this product per day, you must use a mechanical transfer system for all mixing and loading operations. If this product is packaged in a 30-gallon drum, you must use a mechanical transfer system which terminates in a drip-free hard coupling which may be used only with a spray or mix tank which has been fitted with a compatible coupling. If you do not presently own or have access to a mechanical transfer system with this type of coupling, contact your dealer for information on how to obtain such a system or to modify your present system .

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When using a mechanical transfer system, do not remove or disconnect the pump or probe from the container until the container has been emptied and rinsed. The pump or probe system must be used to rinse the empty container and to transfer the rinsate directly to the mixing or spray tank.

Application from a tractor with a completely enclosed cab or aerial application is required whenever this product is applied to 360 or more acres in a day. The closed systems and enclosed cabs must be used in a manner that meets the requirements listed in the Worker Protection Standard (WPS) for agricultural pesticides [40 CFR 170.240 (d) (4-6)]. The handler PPE requirements may be reduced or modified as specified in the WPS.

To reduce exposure to residues, wash the spray rig, tractor, and all other equipment used to handle or apply this product with water daily or before using the equipment for any other purpose.

USER SAFETY RECOMMENDATIONS Users should: • Wash hands before eating, drinking, chewing gum, using tobacco, or using the toilet. • Remove clothing/PPE immediately if pesticide gets inside. Then wash thoroughly and put on clean clothing. • Remove PPE immediately after handling this product. Wash the outside of gloves before removing. As soon as possible, wash thoroughly and change into clean clothing.

ENVIRONMENTAL HAZARDS This pesticide is toxic to fish, aquatic invertebrates, and aquatic plants. 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 washwaters or rinsate. Drift and runoff may be hazardous to aquatic organisms in water adjacent to treated areas. Runoff of this product will be reduced by avoiding applications when rainfall is forecasted to occur within 48 hours. This pesticide has properties and characteristics associated with chemicals detected in groundwater. The use of this product in areas where soils are permeable, particularly where the water table is shallow, may result in groundwater contamination. MCPA is known to leach through soil into groundwater under certain conditions as a result of label use. This chemical may leach into groundwater if used in areas where soils are permeable, particularly where the water table is shallow.

SURFACE WATER ADVISORY STATEMENT: This product may impact surface water quality due to runoff of rainwater. This is especially true for poorly draining soils and soils with shallow ground water. This product is classified as having high potential for reaching surface water via runoff for several months or more after application.

A level, well-maintained vegetative buffer strip between areas to which this product is applied and surface water features such as ponds, streams, and springs will reduce the potential loading of MCPA from runoff water and sediment. Runoff of this product will be reduced by avoiding applications when rainfall or irrigation is expected to occur within 48 hours.

NON-TARGET ORGANISM ADVISORY STATEMENT: This product is toxic to plants and may adversely impact the forage and habitat of non-target organisms, including pollinators, in areas adjacent to the treated site. Protect the forage and habitat of non-target organisms by following label directions intended to minimize spray drift.

Reporting Ecological Incidents: Report ecological incidents, including mortality, injury, or harm to plants and animals, to your local Wilbur-Ellis Company LLC representative or call (720) 306-6340.

PHYSICAL AND CHEMICAL HAZARDS Combustible. Do not use or store near heat or open flame.

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DIRECTIONS FOR USE ENDANGERED SPECIES PROTECTION REQUIREMENTS: It is a Federal offense to use any pesticide in a manner that results in an unauthorized “take” (e.g., kill or otherwise harm) of an endangered species and certain threatened species, under the Endangered Species Act section 9. When using this product, you must follow the measures contained in the Endangered Species Protection Bulletin for the area which you are applying the product. You must obtain a Bulletin no earlier than six months before using this product. To obtain Bulletins, consult http://www.epa.gov/espp, call 1-844-447-3813, or email ESPP@epa.gov. You must use the Bulletin valid for the month in which you will apply the product.

It is a violation of federal law to use this product in a manner inconsistent with its labeling. Read entire label before using this product.

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.

Use of this product in certain portions of California, Oregon and Washington is subject to the January 22, 2004 Order for injunctive relief with Washington Toxics Coalition, et. al. v. EPA C01-0132C, (W.D. WA). For further information, please refer to http://www.epa.gov/espp/litstatus/wtc/index.htm.

Tank Mixing: It is the pesticide user’s responsibility to ensure that all products tank-mixed with VENDETTA® are registered for the intended use. Users must follow the most restrictive directions and precautionary language of the products in the mixture.

USE RESTRICTIONS x Handlers must use closed mixing loading systems during mixing/loading liquids for aerial applications to fallow land and high-acreage field crops. x Aerial application to fallow land is restricted within 25 feet of residential areas (e.g., homes, schools, playgrounds, shopping areas, hospitals, etc.). x Do not apply this product to golf course turf.

AGRICULTURAL USE REQUIREMENTS Use this product only in accordance with its labeling and with the Worker Protection Standard, 40 CFR part 170. This standard contains requirements for the protection of agricultural 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 intervals. The requirements in this box only apply to uses of this product that are covered by the Worker Protection Standard. Do not enter or allow worker entry into treated areas during the restricted-entry interval (REI). For all crops, except grass grown for seed, the REI is 24 hours. The REI for grass grown for seed is 2 days. For uses on turf grown for transplanting (e.g. on sod farms), notify workers of the application by warning them orally and by posting warning signs at entrances to treated areas. PPE required for early entry to treated areas that is permitted under the Worker Protection Standard and that involves contact with anything that has been treated, such as plants, soil, or water, is chemical-resistant gloves made of barrier laminate, neoprene rubber > 14 mils, nitrile rubber > 14 mils, or viton > 14 mils, coveralls, shoes plus socks and protective eyewear.

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NON-AGRICULTURAL USE REQUIREMENTS The requirements in this box apply to the use of this product on areas that are NOT within the scope of the Worker Protection Standard (WPS) for agricultural pesticides (40 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 the treated area until sprays have dried.

USE INFORMATION VENDETTA is formulated as an emulsifiable concentrate containing the equivalent of 2 pounds per gallon of bromoxynil and 2 pounds per gallon of 2-ethylhexyl ester of MCPA.

VENDETTA is a selective postemergence herbicide for control of important broadleaf weeds infesting small grains (wheat, barley, oats, rye), flax, conservation reserve program areas, and grass grown for seed or sod production. Optimum weed control is obtained when VENDETTA is applied to actively growing weed seedlings. VENDETTA is primarily a contact herbicide; therefore, thorough coverage of the weed seedlings is essential for optimum control.

VENDETTA has little residual activity. Therefore, subsequent flushes of weeds will not be controlled by the initial treatment. Generally, crops that form a good canopy will help shade subsequent weed flushes. However, certain crops or short-straw varieties, for example Yecora Rojo wheat, may not develop the crop canopy fast enough to shade the subsequent flushes of weeds.

Occasional transitory leaf burn may occur. The temporary leaf burn is similar to that seen with liquid fertilizer. Because the activity of VENDETTA is mainly contact, recovery of the crop is generally rapid with no lasting effect. Frequency and amount of leaf burn may be greater when crops are stressed by abrasive winds, cool to cold evening temperatures or mechanical injury, such as that caused by hail, sleet or insect feeding. To reduce the potential for temporary leaf burn, applications should be made to dry foliage in the recommended spray volumes per acre when weather conditions are not extreme.

IMPORTANT: VENDETTA contains low volatile 2-ethylhexyl ester of MCPA. At high air or ground surface temperatures, vapors from VENDETTA may cause injury to susceptible plants. This fact should be considered when applying VENDETTA.

MIXING, LOADING AND HANDLING INSTRUCTIONS 2.5 Gallon Containers Special care must be taken in mixing and loading VENDETTA. Hands should be placed on the container in such a way as to avoid possible drip or splash.

30 Gallon and Bulk Containers If you will handle a total of 60 gallons or more of VENDETTA per day, you must use a mechanical transfer system for all mixing and loading operations. If VENDETTA is packaged in a 30 gallon drum, you must use a mechanical transfer system which terminates in a drip-free hard coupling which may be used only with a spray or mix tank which has been fitted with a compatible coupling. If you do not presently own or have access to a mechanical transfer system with this type of coupling, contact your dealer for information on how to obtain such a system or to modify your present system.

When using a mechanical transfer system, do not remove or disconnect the pump or probe from the container until the container has been emptied and rinsed. The pump or probe system must be used to rinse the empty container and to transfer the rinsate directly to the mixing or spray tank.

VENDETTA ALONE: Fill the spray tank 1/2 to 3/4 full with clean water. Begin agitation and add the recommended amount of VENDETTA. Add water to the spray tank to the desired level. Maintain sufficient agitation to ensure a uniform spray mixture during application.

TANK MIXTURES: VENDETTA can be applied in tank mixture with many other herbicides and insecticides registered for use on approved crops. It is the pesticide user’s responsibility to ensure that all products tank-

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mixed with VENDETTA, are registered for the intended use. Users must follow the most restrictive directions and precautionary language of the products in the mixture. Refer to the specific crop section for rate recommendations and other restrictions.

To apply VENDETTA in mixture with another product, fill the spray tank 1/2 to 3/4 full with clean water and begin agitation. If tank mixing with wettable powder, soluble powder, flowable or dry flowable products, add the powder or flowable product first. After the other herbicide is thoroughly mixed with water, add the specified amount of VENDETTA, and add water to the spray tank to the desired level. If tank mixing with other product types, add VENDETTA first before adding the other product. Always mix one product in water thoroughly before adding another product or compatibility problems may occur. Never mix two products together without first mixing in water.

Maintain sufficient agitation while mixing and during application to ensure a uniform spray mixture. If spray mixture is allowed to remain without agitation for short periods of time, be sure to agitate until uniformly mixed before application.

A compatibility test is recommended to ensure satisfactory spray preparation. To test for compatibility, use a small container and mix a small amount (0.5 to 1 quart) of spray, combining all ingredients in the same ratio as the anticipated use. If any indications of physical incompatibility develop, do not use this mixture for spraying. Indications of incompatibility usually will appear within 5 to 15 minutes after mixing.

To ensure maximum crop safety and weed control, follow the most restrictive of the labeling limitations and precautions of all the products used in the tank mixture with VENDETTA.

SPRAYABLE LIQUID FERTILIZERS AND SPRAY ADDITIVES VENDETTA can be applied in combination with sprayable liquid fertilizer or spray additives such as surfactants or crop oil concentrate. When tank mixing with liquid fertilizer always add the fertilizer to the spray tank first and agitate thoroughly before adding VENDETTA. Always predetermine the compatibility with liquid fertilizer by mixing small proportional quantities in advance. Agitation must be maintained during filling and application operations to ensure that VENDETTA is evenly mixed with the fertilizer. Leaf burn may occur when VENDETTA is applied with liquid fertilizer, but new leaves are not adversely affected.

IMPORTANT: Fertilizers and spray additives can increase foliage leaf burn when applied with VENDETTA. Do not apply fertilizers or spray additives with VENDETTA if leaf burn is a major concern due to environmental conditions, crop or variety sensitivity to VENDETTA.

APPLICATION PROCEDURES APPLICATION BY CHEMIGATION must be done by fixed pipe, overhead sprinkler systems or hand-moved pipe. If hand-moved pipe is used for chemigation, the pipe must not be handled in any way until 24 hours after chemigation has been completed and residues have been flushed from the system. When applying by chemigation, no person may enter the application site unless in an enclosed vehicle.

VENDETTA can be applied to registered use areas by ground, aerial and sprinkler irrigation equipment.

GROUND APPLICATION • Use a standard herbicide boom sprayer that provides uniform and accurate application. Sprayer must be equipped with screens no finer than 50 mesh in the nozzle tips and in-line strainers.

• Select a spray volume and delivery system that will ensure thorough and uniform spray coverage. For optimum spray distribution and thorough coverage use of flat fan nozzles (maximum tip size 8008) with a spray pressure of 40-60 psi are recommended.

• Other nozzle types and lower spray pressures that produce coarse spray droplets may not provide adequate coverage of the weeds to ensure optimum control. Raindrop ® nozzles and flood nozzles are not recommended as weed control with VENDETTA may be reduced.

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• A spray volume of 10 to 20 gallons per acre (GPA) is recommended for optimum spray coverage. A minimum of 5 GPA with a minimum spray pressure of 50 psi and a maximum ground speed of 10 mph may be used with higher speed, low volume ground application if ground terrain, crop and weed density allow effective spray distribution. When using higher speed equipment, a maximum ground speed of 10 mph is suggested if field conditions cause excessive boom movement during application which results in poor spray coverage. Ground applications made when dry, dusty field conditions exist may provide reduced weed control in wheel track areas. Applications using less than 10 gallons per acre may result in reduced weed control.

• When weed infestations are heavy, use of higher spray volumes and spray pressure will be helpful in obtaining uniform weed coverage. If you are unsure of the infestation level or size of crop, consult your local extension service.

AERIAL APPLICATION • Use orifice discs, cores and nozzle types and arrangements that will provide for optimum spray distribution and maximum coverage. A minimum spray volume of 5 GPA and a maximum pressure of 40 psi are recommended. A minimum spray volume of 3 gallons per acre may be used if crop canopy and weed density allow adequate spray coverage. Aerial applications using less than 5 gallons of spray volume per acre may result in reduced weed control.

CHEMIGATION APPLICATION • VENDETTA can be applied through chemigation systems to small grains and grasses grown for seed or sod production.

• Apply VENDETTA through center pivot, lateral move, side (wheel) roll, solid set or hand move irrigation systems only. If hand moved pipe is used for chemigation, the pipe must not be handled in any way until 24 hours after chemigation have been completed and residues have been flushed from the system. When applying by chemigation, no person may enter the application site unless in an enclosed vehicle. Do not apply VENDETTA through any other type of chemigation system.

SPECIFIC REQUIREMENTS FOR CHEMIGATION APPLICATION

1. The system must contain a functional check valve, vacuum relief valve, and low pressure drain appropriately located on the irrigation pipeline to prevent water source contamination from backflow.

2. The pesticide injection pipeline must contain a functional, automatic, quick-closing check valve to prevent the flow of fluid back toward the injection pump.

3. The pesticide injection pipeline must also contain a functional, normally closed, solenoid-operated valve located on the intake side of the injection pump and connected to the system interlock to prevent fluid from being withdrawn from the supply tank when the irrigation system is either automatically or manually shut down.

4. The system must contain functional interlocking controls to automatically shut off the pesticide injection pump when the water pump motor stops.

5. The irrigation line or water pump must include a functional pressure switch which will stop the water pump motor when the water pressure decreases to the point where pesticide distribution is adversely affected.

6. Systems must use a metering pump, such as a positive displacement injection pump (e.g., diaphragm pump) effectively designed and constructed of materials that are compatible with pesticides and capable of being fitted with a system interlock.

7. Do not apply when wind speed favors drift beyond the area intended for treatment.

8. Agitation is recommended in the pesticide supply tank when applying VENDETTA.

9. VENDETTA should be applied continuously for the duration of the water application with center pivot and continuous lateral move systems. Application of VENDETTA should be made during the last 30-45 minutes of the irrigation set with other overhead sprinkler systems.

10. For best performance, set the sprinkler system to deliver approximately 0.5 inch or less of water per acre.

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11. Remove scale, pesticide residues and other foreign matter from the supply tank and entire injector system. Flush with clean water.

12. If VENDETTA is diluted in the supply tank, fill the tank with half of the water amount desired, add VENDETTA and then add remaining water amount with agitation. Always dilute with at least 4 parts water to 1-part VENDETTA.

13. Start the sprinklers and then inject VENDETTA into the irrigation line. VENDETTA should be injected with a positive displacement pump into the main line at least 8 feet ahead of a right angle turn to insure adequate mixing. Refer to VENDETTA label for detailed information on application rates and timings.

CHEMIGATION USER PRECAUTIONS Application of more than 0.5 inch/acre of irrigation water may result in decreased product performance on certain soils. Do not apply when conditions favor drift, when system connections or fittings leak, or when nozzles do not provide uniform distribution. Allow sufficient time for pesticide to be flushed through all the lines and nozzles before turning off irrigation water. Crop injury, lack of effectiveness, or illegal pesticide residues in the crop can result from non-uniform distribution of treated water. Do not connect an irrigation system used for pesticide application to a public water system. If you have questions about calibration, you should contact State Extension Service specialists, equipment manufacturers or other experts. A person knowledgeable of the chemigation system and responsible for its operations, or under the supervision of the responsible person, shall shut the system down and make necessary adjustments should the need arise.

MANDATORY SPRAY DRIFT MANAGEMENT Aerial Applications: x Do not release spray at a height greater than 10 feet above the vegetative canopy unless a greater application height is necessary for pilot safety. x Applicators are required to use a coarse or coarser droplet size (ASABE S572.1). x The boom length must not exceed 65% of the wingspan for airplanes or 75% of the rotor blade diameter for helicopters. x Applicators must use ½ swath displacement upwind at the downwind edge of the field. x Nozzles must be oriented, so the spray is directed toward the back of the aircraft. x Do not apply when wind speeds exceed 10 miles per hour at the application site. x Do not apply during temperature inversions. Ground Boom Applications: x Apply with the nozzle height recommended by the manufacturer, but no more than 3 feet above the ground or crop canopy. For all other ground applications, the nozzle must be no more than 3 feet above the ground or crop canopy. x Applicators are required to select the nozzle and pressure that deliver a medium or coarser droplet size (ASABE S572). x Do not apply when wind speeds exceed 10 miles per hour at the application site. x Do not apply during temperature inversions. Boomless Ground Applications: x Applicators are required to select the nozzle and pressure that deliver a medium or coarser droplet size (ASABE S572) for all applications. x Do not apply when wind speeds exceed 15 miles per hour at the application site. x Do not apply during temperature inversions.

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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 x 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. x Pressure – Use the lowest spray pressure recommended for the nozzle to produce the target spray volume and droplet size. x Spray Nozzle – Use a spray nozzle that is designed for the intended application. Consider using nozzles designed to reduce drift.

Controlling Droplet Size – Aircraft x Adjust Nozzles – Follow nozzle manufacturers recommendations for setting up nozzles. Generally, to reduce fine droplets, nozzles should be oriented parallel with the airflow in flight.

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.

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 inversion. 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.

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.

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

Handheld Technology Applications: Take precautions to minimize spray drift.

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PLANT BACK INTERVAL For crops on this label, or crops with an established MCPA tolerance, there is a 30-day plant back interval (PBI). For crops not listed on a MCPA label, or on crops for which no residue tolerances for MCPA have been established, a 60-day plant back interval must be observed.

WEED RESISTANCE MANAGEMENT Some weeds are known to develop resistance to herbicides that have been used repeatedly. While the development of herbicide resistance is well understood, it is not easily predicted. Therefore, herbicides should be used in conjunction with the resistance management strategies in the area.

VENDETTA contains a Group 4 and a Group 6 herbicide. Any weed population may contain or develop plants naturally resistant to Group 4 and Group 6 herbicides. Weed species with acquired resistance to Group 4 and Group 6 herbicides may eventually dominate the weed population if other Group 4 and Group 6 herbicides are repeatedly used in successive years or in the same field as the primary method of control for targeted species. VENDETTA should be rotated with products that do not contain MCPA or bromoxynil to minimize selection pressure.

To delay herbicide resistance, take one or more of the following steps: x Rotate the use of VENDETTA or other Group 4 and Group 6 herbicides within a growing season sequence or among growing seasons with different herbicide groups that control the same weeds in a field. x Apply VENDETTA at the correct timing and rate needed to control the most difficult weed in the field. x Use tank mixtures with herbicides from a different group if such use is permitted; where information on resistance in target weed species is available, us e the less resistance-prone partner at a rate that will control the target weed(s) equally, as well as the more resistance-prone partner. Consult your local extension service or certified crop advisor if you are unsure as to which active ingredient is currently less prone to resistance. x Adopt an integrated weed-management program for herbicide use that includes scouting and uses historical information related to herbicide use and crop rotation, and that considers tillage (or other mechanical control methods), cultural (e.g., higher crop seeding rates, precision fertilizer application method and timing to favor the crop and not the weeds), biological (weed-competitive crops or varieties) and other management practices. x Scout fields prior to herbicide application to identify the weed species present and their growth stage to determine if the intended application will be effective. x Scout fields after herbicide application to monitor weed populations for early signs of resistance development. Indicators of possible herbicide resistance include: (1) failure to control a weed species normally controlled by the herbicide at the dose applied, especially if control is achieved on adjacent weeds; (2) a spreading patch of non-controlled plants of a particular weed species; and (3) surviving plants mixed with controlled individuals of the same species. If resistance is suspected, prevent weed seed production in the affected area by an alternative herbicide from a different group or by a mechanical method such as hoeing or tillage. Prevent movement of resistant weed seeds to other fields by cleaning harvesting and tillage equipment when moving between fields and planting clean seed. x If a weed pest population continues to progress after treatment with this product, discontinue use of this product, and switch to another management strategy or herbicide with a different mode of action, if available, and/or use non-chemical means to remove escapes, as practical, with the goal of preventing further seed production.

Report any incidence of non-performance of this product against a particular weed species to your local Wilbur- Ellis Company representative or call (720) 306-6340.

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WEED LIST Postemergence application of VENDETTA will control the following weeds when sprayed in the seedling stage. Maximum weed stage of growth is listed under the VENDETTA Directions tables.

MOST SUSCEPTIBLE BROADLEAF WEED SPECIES Annual sowthistle (Sonchus oleraceus) Black mustard (Brassica nigra) Black nightshade (Solanum nigrum) Common cocklebur (Xanthium strumarium) Common lambsquarters (Chenopodium album) Common tarweed (Hemizonia congesta) Cow cockle (Saponaria vaccaria) Cutleaf nightshade (Solanum triflorum) Eastern black nightshade (Solanum ptycanthum) Coast fiddleneck (Amsinckia intermedia) Field pennycress (Thlaspi arvense) Green smartweed (Polygonum scabrum) Hairy nightshade (Solanum sarachoides) Horned Poppy (Glaucium corniculatum) Jimsonweed (Datura stramonium) Ladysthumb (Polygonum persicaria) Lanceleaf sage (Salvia reflexa) London rocket (Sisymbrium irio) Marshelder (Iva xanthifolia) Pennsylvania smartweed (Polygonum strumarium) Pepperweed spp. (Lepidium app.) Redroot pigweed (Amaranthus retroflexus) Russian thistle (Salsola kali) Shepherdspurse (Capsella bursa-pastoris) Silverleaf nightshade (Solanum elaeagnifolium) Smooth pigweed (Amaranthus hybridus) Spiny pigweed (Amaranthus spinosus) Sunflower 1 (Helianthus annuus) Tall Waterhemp (Amaranthus tuberculatus) Tartary buckwheat (Fagopyrum tataricum) Tumble mustard (Sisymbrium altissimum) Wild buckwheat (Polygonum convolvulus) Wild mustard (Sinapis arvensis) Yellow rocket (Barbarea vulgaris)

1 For control of sunflower, delay application until first sunflower seedlings emerging are 4 inches in height.

SUSCEPTIBLE BROADLEAF WEED SPECIES Blue (purple) mustard (Chlorispora tenella) Common groundsel (Senecio vulgaris) Common ragweed (Ambrosia artemisiifolia) Corn chamomile (Anthemis arvensis) Corn gromwel (Lithospermum arvense) Fumitory (Fumaria officinalis) Giant ragweed (Ambrosia trifida) Hemp sesbania (Sesbania exaltata) H e n b i t (Lamium amplexicaule) Ivyleaf morningglory (Ipomoea hederacea) K n a w e l (Scleranthus annuus) K o c h i a (Kochia scoparia) Mayweed (Anthemis cotula) Prostrate knotweed (Polygonum aviculare) Puncture vine (Tribulus terrestris) Tall morningglory (Ipomoea purpurea)

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SUSCEPTIBLE BROADLEAF WEED SPECIES (continued) Tansy mustard (Descurainia pinnata) Tarweed (Hemizonia spp.) Velvetleaf (Abutilon theophrasti) Wild radish (Raphanus raphanistrum)

Weeds germinating after spraying will not be controlled.

WEED SUPPRESSION Canada Thistle (Cirsium arvense)

VENDETTA applied at 1-1/2 pints per acre provides burn down of top growth. Regrowth may occur. Make applications when Canada thistle is 8 inches tall to the bud stage.

BARLEY, OATS, RYE, WHEAT NOTES RATE WEEDS Apply to fall seeded barley, oats, rye and wheat throughout the United States and spring seeded barley, oats, rye, and wheat in Idaho, Oregon, Washington, Colorado, Wyoming and Montana. Apply to barley, oats, rye, and wheat from the 3-leaf stage but before the crop reaches the boot stage. 1 pint/A MOST SUSCEPTIBLE BROADLEAF WEEDS: Apply to weeds up to the 8-leaf stage or 4 inches in height, whichever comes first. If weed forms rosette, apply before weeds exceed 2 inches in diameter. 1.5 – 2 pints/A SUSCEPTIBLE BROADLEAF WEEDS: Apply to weeds up to the 4-leaf stage or 2 inches in height, whichever comes first. If weed forms rosette, apply before weeds exceed 1 inch in diameter.

2 pints/A Apply to henbit, knawel and mayweed up to the 4- leaf stage or 2 inches in height, whichever comes first. Apply to kochia and tansy mustard for improved control when these weeds exceed the recommended stage of growth or are growing under cool, dry conditions.

Spring seeded barley and wheat except Idaho, Oregon, Washington, Colorado, Montana, and Wyoming. Apply to barley, oats, rye and wheat from the 3-leaf stage but before the crop reaches the boot stage.

1.5 pints/A MOST SUSCEPTIBLE AND SUSCEPTIBLE BROADLEAF WEEDS: Apply to weeds that do not exceed the 8-leaf stage or 4 inches in height, whichever comes first. If weed forms rosette, apply before weeds exceed 2 inches in diameter. Apply to kochia up to 2 inches in height. 1.5 – 2 pints/A OTHER WEEDS: Apply to kochia that is 2-4 inches height. Apply to barley, oats, rye, and wheat from the 3-leaf stage but before the boot stage. Apply through automated chemigation systems with mechanical transfer loading system only. See MIXING, LOADING AND HANDLING INSTRUCTIONS section for complete details. Chemigation Only

2 pints/A MOST SUSCEPTIBLE AND SUSCEPTIBLE BROADLEAF WEEDS: Apply up to the 4-leaf stage, 2 inches in height or 1 inch in diameter, whichever comes first. Make applications following harvest of barley, oats, rye, and wheat in the states of North Dakota, South Dakota, Minnesota, and Montana. Do not plant any rotational crop until the following use season. Post-harvest

0.75 – 2 pints/A MOST SUSCEPTIBLE BROADLEAF WEEDS: Apply .75 to 1 pint/A to up to the 8-leaf stage or 4 inches in height, whichever comes first.

SUSCEPTIBLE BROADLEAF WEEDS: Apply 1.5 to 2 pints/A to up to the 4-leaf stage or 2 inches in height, whichever comes first.

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BARLEY, OATS, RYE, WHEAT (continued) RESTRICTIONS: • Do not graze treated fields within 45 days after application. • Do not apply when crops are under moisture stress. • Do not apply when crop canopy covers the weeds as poor control will result. • Apply up to Boot stage. • Do not apply more than 2 pints of VENDETTA (0.5 lb. MCPA acid equivalent) / (0.5 lb. bromoxynil) per acre per year. • For crops on this label, or crops with an established MCPA tolerance, there is a 30-day PBI. For crops not listed on a MCPA label, or on crops for which no residue tolerances for MCPA have been established, a

60-day plant back interval must be observed. • Do not apply more than 0.75 lb. of MCPA acid equivalent per acre per year from all combined sources. PRECAUTIONS: • Reduced weed control may occur when weeds are stressed from lack of moisture or cold temperatures. • Refer to labels of products used in tank mixture for additional restrictions and precautions.

CONSERVATION RESERVE PROGRAM AREAS (CRP) NOTES RATE WEEDS Apply to grasses from the 3-leaf stage.

1 pint/A MOST SUSCEPTIBLE BROADLEAF WEEDS: Apply to weeds up to the 8-leaf stage, 4 inches in height or 2 inches in diameter, whichever comes first. 1.5 – 2 pints/A SUSCEPTIBLE BROADLEAF WEEDS: Apply to weeds up to the 8-leaf stage, 4 inches in height or 2 inches in diameter, whichever comes first. RESTRICTIONS: • Do not allow livestock to graze in treated areas or feed treated grass to livestock. • Do not apply VENDETTA to CRP areas planted with alfalfa if temperatures are expected to exceed 80 o F or severe crop injury may occur. If legumes other than alfalfa have been planted, severe crop injury may occur at any application temperature. • Do not apply more than 2 pints/A of VENDETTA to CRP areas that are under seeded with alfalfa. • Do not apply more than 0.5 lb. bromoxynil per acre per year.

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GRASSES GROWN FOR SEED PRODUCTION OR SOD PRODUCTION (Seedling and established grasses) Apply to established and newly seeded grasses grown for seed or sod production before the boot stage. Established grasses tolerant to VENDETTA include bentgrasses, Kentucky Bluegrass, Fescues, Ryegrass Bermudagrass, St. Augustinegrass and Zoysiagrass. VENDETTA may also be used on seedling grasses such as Merion, Park, Delta, or common Kentucky Bluegrasses, Pennlawn, Chewings, Illahee or Alta Fescues, Orchard grass, Highland, Seaside or Astoria Bentgrasses, perennial Ryegrasses, Bahiagrass and Zoysiagrass. 1 – 2 pints/A OR

0.375 – 0.73 fl. oz./1000 sq. ft. Refer to the WEED LIST for a listing of susceptible broadleaf weeds.

Optimal control will be attained when weeds are treated in the seedling stage (less than 4 leaf stage, 2 inches in height, or 1 inch in diameter.) Apply to established and newly seeded grasses grown for seed or sod production before the boot stage. Apply through automated sprinkler irrigation systems with mechanical transfer loading system only. See MIXING, LOADING AND HANDLING INSTRUCTIONS section for complete details. Refer to the list of established grasses that are tolerant to VENDETTA.

Chemigation only:

2 pints/A

OR 0.73 fl. oz. /1000 sq. ft Refer to the WEED LIST for a listing of susceptible broadleaf weeds.

Optimal control will be attained when weeds are treated in the seedling stage (less than 4 leaf stage, 2 inches in height, or 1 inch in diameter.)

RESTRICTIONS: • Not for use on residential turf. • Do not apply with backpack or handheld application equipment. • Do not allow livestock to graze in treated areas or feed treated grasses to livestock. • Do not apply more than 2 pints of VENDETTA (0.5 lb. MCPA acid equivalent) / (0.5 lb. bromoxynil) per acre per year. • Do not apply more than 2 applications per year with a minimum retreatment interval of 21 days. • Do not apply more than 1.5 lb. acid equivalent MCPA per acre per year from all combined sources

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FLAX (Linum usitatissimum only) NOTES RATE WEEDS Apply to flax that is 2 to 8 inches in height. Do not apply VENDETTA to flax during or after the bud stage

0.5 – 0.9 pints/A

Apply to MOST SUSCEPTIBLE weeds that do not exceed the 4-leaf stage, 2 inches in height or 1 inch in diameter, whichever comes first. RESTRICTIONS: • Do not apply if temperatures are expected to exceed 85º F at application or 3 days following application or

crop injury may occur. • Unless otherwise instructed, do not apply VENDETTA to flax with crop oil concentrate, surfactants or nitrogen solutions. • Do not use on ornamental flax. • Do not apply more than 0.9 pints of VENDETTA (0.225 lb. MCPA acid equivalent) per acre in a single growing season. • For crops on this label, or crops with an established MCPA tolerance, there is a 30-day PBI. For crops not listed on a MCPA label, or on crops for which no residue tolerances for MCPA have been established, a 60-day plant back interval must be observed. • Do not exceed 0.25 lb. acid equivalent of MCPA per acre per year. PRECAUTIONS: • Unacceptable crop injury may occur following VENDETTA application to flax grown on high organic, peat type soils. • Application under high humidity conditions can injure flax.

STORAGE AND DISPOSAL Do not contaminate water, food or feed by storage or disposal. PESTICIDE STORAGE: Always store pesticides in the original closed container in a secure storage area. Store pesticides away from food, pet food, feed, seed, fertilizers, and veterinary supplies. Protect pesticide containers from extreme heat and cold. 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: Non-refillable containers (2.5, 30 & 55 gallons): Do not reuse or refill this container. Offer for recycling, if available. Triple rinse or pressure rinse container (or equivalent) promptly after emptying. Then offer for recycling or reconditioning, or puncture and dispose of in a sanitary landfill, or incineration, or if allowed by State and Local authorities, by burning. If burned, stay out of smoke. (Non-refillable <5 gallons): Triple rinse as follows: Empty the remaining contents into application equipment or mix tank and drain for 10 seconds after the flow begins to drip. Fill the container 1/4 full with water and recap. Shake for 10 seconds. Pour rinsate into application equipment or a mix tank or store rinsate for later use or disposal. Drain for 10 seconds after the flow begins to drip. Repeat this procedure two more times. (Non-refillable >5 gallons): Triple rinse as follows: Empty the remaining contents into application equipment or a mix tank. Fill the container 1/4 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. Pressure rinse as follows: Empty the remaining contents into application equipment or a mix tank and continue to drain for 10 seconds after the flow begins to drip. Hold container upside down over application equipment or mix tank or collect rinsate for later use for disposal. Insert pressure rinsing nozzle in the side of the container, and rinse at about 40 PSI for at least 30 seconds. Drain for 10 seconds after the flow begins to drip. Refillable container (15 gallons, 30 gallons, 120 gallons and greater or bulk): Refill this container with pesticide only. Do not reuse this container for any other purpose. Cleaning the container 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 the container into application equipment or mix tank. Fill the container about 10 percent full with water. Agitate vigorously or recirculate

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water with the pump for 2 minutes. Pour or pump rinsate into application equipment or rinsate collection system. Repeat this rinsing process two more times.

Conditions of Sale and Limitation of Warranty and Liability: NOTICE: Read the entire Directions for Use and Conditions of Sale and Limitation of Warranty and Liability before buying or using the product. If the terms are not acceptable, return the product at once, unopened, and the purchase price will be refunded. ALL STATEMENTS MADE HEREIN ARE SUBJECT TO APPLICABLE LAW, AND TO THE EXTENT THERE IS ANY INCONSISTENCY OR CONTENTION, APPLICABLE LAW SHALL GOVERN. The Directions for Use of the product must be followed carefully. It is impossible to eliminate all risks inherently associated with the use of this product. Crop injury, ineffectiveness, or other unintended consequences may result because of many different factors including, without limitation, manner of use or application, wea ther, combination with other products, or crop conditions. All such risks shall be assumed by Buyer and User, and Buyer and User agree to hold Manufacturer and Seller harmless from any claims relating to such factors. Seller warrants that this product conforms to the chemical description on the label. EXCEPT FOR THIS WARRANTY, THE PRODUCT IS FURNISHED “AS-IS,” AND NEITHER SELLER NOR MANUFACTURER MAKES ANY OTHER WARRANTIES, EXPRESS OR IMPLIED, WITH RESPECT TO THE SELECTION, PURCHASE OR USE OF THIS PRODUCT; SELLER AND MANUFACTURER SPECIFICALLY DISCLAIM ANY WARRANTY OF MERCHANTABILITY OR FITNESS FOR A PARTICULAR PURPOSE BEYOND WHAT IS STATED ON THE LABEL. Buyer and User accept all risks arising from any use of this product, including without limitation, uses contrary to label instructions, or under conditions not reasonably foreseeable to (or beyond the control of) Seller or Manufacturer. Neither Manufacturer nor Seller shall be liable for any incidental, consequential or special damages resulting from the use or handling of this product. THE EXCLUSIVE REMEDY OF THE BUYER OR USER, AND THE EXCLUSIVE LIABILITY OF MANUFACTURER AND SELLER, FOR ANY AND ALL CLAIMS, LOSSES, INJURIES OR DAMAGES (INCLUDING CLAIMS BASED ON BREACH OF WARRANTY, CONTRACT, NEGLIGENCE, TORT, STRICT LIABILITY OR OTHERWISE) RESULTING FROM THE USE OR HANDLING OF THIS PRODUCT, SHALL BE THE RETURN OF THE PURCHASE PRICE OF THIS PRODUCT, OR, AT THE ELECTION OF MANUFACTURER OR SELLER, THE REPLACEMENT OF THE PRODUCT. These Conditions of Sale and Limitation of Warranty and Liability shall be interpreted, unless otherwise required by the law of the state of purchase, in accordance with the laws of the State of California, excluding its conflicts of laws rules, and may not be amended by any oral or written agreement.

WILBUR-ELLIS® logo, HERBICIDE® logo and VENDETTA® are registered trademarks of Wilbur-Ellis Company LLC.

All other registered trademarks are the responsibility of their respective owners.

2022-0517

MANUFACTURED FOR:

WILBUR-ELLIS COMPANY LLC P.O. BOX 16458 FRESNO, CA 93755

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