	

                                

BIOPESTICIDES REGISTRATION ACTION DOCUMENT

Lavandulyl senecioate

PC Code 036005	

	U.S. Environmental Protection Agency

	Office of Pesticide Programs

Biopesticides and Pollution Prevention Division

(Last updated January 20, 2010)

This document is for informational purposes only and is representative
of the Agency’s justification in registering products containing this
active ingredient.  This is not a legal document. TABLE OF CONTENTS

  TOC \o "1-4" \h \z \u    HYPERLINK \l "_Toc200350525"  I.	EXECUTIVE
SUMMARY:	  PAGEREF _Toc200350525 \h  5  

  HYPERLINK \l "_Toc200350526"  II.	ACTIVE INGREDIENT OVERVIEW	  PAGEREF
_Toc200350526 \h  6  

  HYPERLINK \l "_Toc200350527"  III.   REGULATORY BACKGROUND	  PAGEREF
_Toc200350527 \h  6  

  HYPERLINK \l "_Toc200350528"  A.	Classification	 6

  HYPERLINK \l "_Toc200350529"  B.	Food Clearances and Tolerances	 
PAGEREF _Toc200350529 \h  6  

  HYPERLINK \l "_Toc200350531"  IV.   RISK ASSESSMENT	  PAGEREF
_Toc200350531 \h  6  

  HYPERLINK \l "_Toc200350532"  A.	Active Ingredient Characterization	 
PAGEREF _Toc200350532 \h  6  

  HYPERLINK \l "_Toc200350534"  B.	Human Health Assessment	  PAGEREF
_Toc200350534 \h  7  

  HYPERLINK \l "_Toc200350535"  1.	Toxicology	  PAGEREF _Toc200350535 \h
 7  

  HYPERLINK \l "_Toc200350545"  2.	Dose Response Assessment	  PAGEREF
_Toc200350545 \h  8  

  HYPERLINK \l "_Toc200350552"  3.	Food Quality Protection Act (FQPA)
Consideration ………………………….............8

4..	Occupational, Residential, School and Day Care Exposure and Risk
Characterization	  PAGEREF _Toc200350552 \h  8  

  HYPERLINK \l "_Toc200350557"  5	Cumulative Effects	 9

  HYPERLINK \l "_Toc200350559"  6     Risk Characterization	 9

  HYPERLINK \l "_Toc200350561"  C.	ENVIRONMENTAL ASSESSMENT	  PAGEREF
_Toc200350561 \h  9  

  HYPERLINK \l "_Toc200350562"  1.	Ecological Hazards	  PAGEREF
_Toc200350562 \h  9  

  HYPERLINK \l "_Toc200350564"  2.	Environmental Fate and Ground Water
Data	  PAGEREF _Toc200350564 \h  9  

  HYPERLINK \l "_Toc200350566"  3.	Ecological Exposure and Risk
Characterization	  PAGEREF _Toc200350566 \h  9  

    4. 	Endangered Species
Assessment……………………………………………………
….10

  HYPERLINK \l "_Toc200350569"  D.	EFFICACY DATA	  PAGEREF _Toc200350569
\h  10  

  HYPERLINK \l "_Toc200350570"  V.    Risk Management Decision	  PAGEREF
_Toc200350570 \h  10  

  HYPERLINK \l "_Toc200350571"  A.	Determination of Eligibility for
Registration	 10

B.	Regulatory Decision                                                  
                                                      11

C.	Environmental Justice 								        13

  HYPERLINK \l "_Toc200350573"  VI.	ACTIONS REQUIRED BY REGISTRANTS	 
PAGEREF _Toc200350573 \h  11  

  HYPERLINK \l "_Toc200350574"  A.	Reporting Adverce Effects	 13

  HYPERLINK \l "_Toc200350575"  B.	Reporting of Hypersensitivity
Incidents	  PAGEREF _Toc200350575 \h  11  

VII. APPENDIX A. Product Specific
Information………………………………………..…14

VIII. APPENDIX B. Product Specific
Information………………………………………..…15

  HYPERLINK \l "_Toc200350578"  IX. Appendix C. References	  PAGEREF
_Toc200350578 \h  14  

 

BIOPESTICIDES REGISTRATION ACTION DOCUMENT TEAM

Office of Pesticide Programs:

Biopesticides and Pollution Prevention Division

Biochemical Pesticides Branch (BPB)

Driss Benmhend						Biologist / Regulatory Action Leader

Linda Hollis							Branch Chief

Sadaf Shaukat							Biologist

I.	EXECUTIVE SUMMARY:

The new active ingredient Lavandulyl Senecioate, also known as
5-methyl-2-(1-methylethenyl)-4-hexenyl 3-methyl-2-butonate, is a
technical grade synthetic arthropod pheromone.  This pheromone is
structurally similar to and mimics a naturally occurring pheromone
produced by the female vine mealybug (Planococcus ficus) to attract the
males for mating.   Lavandulyl Senecioate is intended for use in
polymeric dispensers to disrupt the normal mating cycle of vine mealybug
on table and wine grapes.   Accordingly, EPA is considering the approval
of a registration for Lavandulyl Senecioate under Section 3(c)(5) of the
Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA).    

The Biopesticides and Pollution Prevention Division (BPPD) has reviewed
the data required to support the registration of this biochemical active
ingredient, under Section 3(c)(5) of the Federal Insecticide, Fungicide
and Rodenticide Act (FIFRA).  Product chemistry data requirements were
satisfied by acceptable guideline studies.  Adequate mammalian
toxicology data/information was submitted to support registration of
Lavandulyl Senecioate. Acceptable acute toxicity guideline studies were
submitted, and data waivers were granted by the Agency for the remaining
toxicity requirements based on the lack of toxicity of the active
ingredient.  Ecological effects data requirements for are waived because
of the use of this pheromone in retrievable, polymeric dispensers. 

Based on the data available to the Agency, it has been determined that
no unreasonable adverse effects to the U.S. population and the
environment will result from the use of the active ingredient when label
instructions are followed and good agricultural practices are employed. 
Laboratory studies indicate that the active ingredient is not toxic
following oral, inhalation or dermal exposure.  Moreover, the pesticidal
usage of this biochemical in polymeric dispensers, will not have any
harmful environmental effects

Due to the negligible risk concerns when used as mating disrupter,
Lavandulyl Senecioate meets the criteria as specified in §3(c)(5) of
the Federal Insecticide, Fungicide and Rodenticide Act (FIFRA), as
amended, and is thus eligible for unconditional registration.  It was
determined that the data/information submitted adequately satisfy
applicable data requirements at 40 C.F.R. Subpart U §158.2000.

II.		ACTIVE INGREDIENT OVERVIEW

Common Name: 			Lavandulyl Senecioate

Chemical Names: 		5-methyl-2-(1-methylethenyl)-4-hexenyl
3-methyl-2-butonate

Trade & Other Names:	Lavandulyl Senecioate

CAS Registry Number: 	23960-07-8

OPP Chemical Code: 	036005

Type of Pesticide: 		Mating disrupter for vine mealybug 

Application rates and methods vary depending on the product.  For
specific information regarding the product(s) refer to Appendix B.

  REGULATORY BACKGROUND

On November 07, 2008, Suterra LLC, submitted an application for the
registration of the end use product (EP) CheckMate® VMB Dispenser
(56336- LA) containing 5.91% Lavandulyl Senecioate, and CheckMate VMB
Technical Pheromone (56336-LL) containing 97.66% Lavandulyl Senecioate. 
A notice of receipt of the application for registration of Lavandulyl
Senecioate as a new active ingredient was published in the Federal
Register on February 18, 2009 (74 FR 7601), with a 30-day comment
period. No comments were received following this publication.

Consistent with the Agency’s new policy for making pesticide
registration actions more transparent, EPA provided a 30-day public
comment period on the decision to register Lavandulyl Senecioate.  No
comments were received during the 30 day public comment period

A.	Classification

The Biochemical Classification Committee determined that Lavandulyl
Senecioate is a biochemical pesticide because this pheromone has a non
toxic mode of action, and is structurally similar to and mimics a
naturally occurring pheromone produced by the female vine mealybug. 

B.	Food Clearances/Tolerances 

Arthropod pheromones are exempt from the requirement of a tolerance in
or on raw agricultural commodities when used in retrievable, polymeric
matrix dispensers, and when the pheromone is applied to growing crops at
a rate not to exceed 150 grams active ingredient per acre per year in
accordance with good agricultural practices (40 CFR §180.1124).

IV.			RISK ASSESSMENT

A.	Active Ingredient Characterization

Lavandulyl Senecioate is a synthetic compound that mimics the naturally
occurring pheromone substance produced by female vine mealybug.  This
compound is a yellow liquid with a slightly burnt oily smell. 

 The descriptions of the product formulation and production process, as
well as the formation of impurities, were examined by the Agency and
found to meet current standards.  A preliminary analysis was conducted
to identify Lavandulyl Senecioate in five batches of the product, and
the results were determined to be acceptable by the Agency.  The
analytical method used to determine the content of the active ingredient
is also acceptable.  Physical and chemical properties were submitted for
the active ingredient and are adequate.  Refer to Table 1 in Appendix A
for a summary of product chemistry data requirements.  Refer to Table 2
in Appendix A for the summary of physical and chemical characteristics
for Lavandulyl Senecioatel.  All product chemistry data requirements for
registration of Lavandulyl Senecioate have been satisfied.

	

B.	Human Health Assessment

1.	Toxicology 

Toxicity categories are assigned based on the hazard(s) identified from
studies and/or information on file with the Agency.  An active
ingredient is classified into Toxicity Category I, II, III or IV, in
which Toxicity Category I indicates the highest toxicity and Toxicity
Category IV indicates the lowest toxicity.  

Adequate mammalian toxicology data/information is available to support
registration of Lavandulyl Senecioate.  All toxicology data requirements
for Lavandulyl Senecioate have been satisfied.

Lavandulyl Senecioate is a naturally occurring arthropod pheromone with
a non-toxic mode of action.  Arthropod pheromones are generally
effective at very low rates and are used in point source applications
such as retrievable polymeric dispensers.  The Agency recognizes the low
toxicity, negligible expected exposure, and lack of expected adverse
effects on humans and nontarget organisms of arthropod pheromones when
used in polymeric dispensers.  Moreover, published subchronic studies on
compounds similar in structure to arthropod pheromones have been
submitted indicating these compounds have no significant human health
effects.  As a result only acute mammalian toxicology data were required
for this registration.

	a.	Acute Toxicity

Acute toxicity testing is required to 1) determine systemic toxicity
from acute exposure via the dermal, inhalation and oral routes, 2)
determine irritant effects from exposure to the eyes and 3) determine
the potential for skin sensitization (allergic contact dermatitis).  

Tier I toxicity data submitted and reviewed showed that Lavandulyl
Senecioate is a toxicity category IV (low toxicity) compound via acute
oral, acute dermal, eye irritation, and acute inhalation routes of
exposure.  Lavandulyl Senecioate is in Toxicity Category III (slightly
toxic) for primary dermal irritation.  Lavandulyl Senecioate is not an
eye or skin irritant. No additional toxicity data are required to
support usage of this biochemical. 

For more information regarding the acute toxicity data requirements,
refer to Table 3 in 

Appendix A.

2.	Dose Response Assessment

No meaningful toxicological endpoints were identified on Lavandulyl
Senecioate when used as a pesticide; therefore, a dose response
assessment was not required.  

3.  Food Quality Protection Act (FQPA) Consideration

a.  Dietary Exposure and Risk Characterization

According to 40 CFR 180.1124, arthropod pheromones are exempt from the
requirement of a tolerance, and thus a dietary assessment is not
required.

Moreover, exposure to Lavandulyl Senecioate is expected to be minimal
due to its use in point source dispensers, from which it is released in
very small quantities.  Restricting the use of the Lavandulyl Senecioate
to retrievably sized dispensers will significantly limit the possibility
of dietary exposure to the pheromone.

b.  Drinking Water Exposure and Risk Characterization

No significant drinking water exposure or residues are expected to
result from the pesticidal usage of Lavandulyl Senecioate.  The active
ingredient is intended for use in retrievable dispensers and not to be
applied directly to water.  If used in accordance with EPA-approved
labeling, it is not likely to accumulate in drinking water

As a result, dietary and drinking water exposure to residues of
Lavandulyl Senecioate are expected to be minimal.

	

4.	Occupational, Residential, School and Day Care Exposure and Risk
Characterization

	a.	Occupational Exposure and Risk Characterization

Lavandulyl Senecioate is a synthetic compound that is structurally
identical to, and mimics, the naturally occurring pheromone of the
female vine mealybug moth, and acts via a non-toxic mode of action to
specific target pests.  Low oral, dermal, and inhalation toxicity have
been demonstrated by the data summarized above.  The end-use product
will be applied via polymeric-matrix dispensers placed in trees.  The
potential for dermal, eye, and inhalation exposure to Lavandulyl
Senecioate for handlers is minimal and will be mitigated as long as
products are used according to label directions. The Agency will require
labels to include the appropriate signal word, re-entry interval, and
precautionary statements. 

	b.	Residential, School and Day Care Exposure and Risk Characterization

No indoor residential, school, or day care uses are currently approved
for products containing Lavandulyl Senecioate.  The Agency has concluded
that the potential for pheromone residues is not a dietary hazard to the
general population, including infants and children.  This decision was
based on the following criteria: 1) low acute and subchronic mammalian
toxicity, 2) the known metabolism; and 3) the history of safe use of
similar arthropod pheromones.  Also, for food uses of pheromones, the
toxicity and residue data support the conclusion that an exemption from
the requirement of a tolerance is appropriate and adequate to protect
human health, including that of infants and children (40 CFR 180.1124)

5.	Cumulative Effects

EPA has considered the potential for cumulative effects of Lavandulyl
Senecioate and other substances in relation to a common mechanism of
toxicity.  Because of its low toxicity to mammalian systems, the Agency
does not expect any cumulative or incremental effects from exposure to
residues of Lavandulyl Senecioate when applied/used as directed on the
label and in accordance with good agricultural practices.

6.   Risk Characterization

The Agency considered human exposure to Lavandulyl Senecioate in light
of the relevant safety factors in FQPA and FIFRA.  A determination has
been made that no unreasonable adverse effects to the U.S. population in
general, and to infants and children in particular, will result from the
use of Lavandulyl Senecioate when label instructions are followed. 

C.	ENVIRONMENTAL ASSESSMENT

1.	Ecological Hazards

According to 40 CFR 158.2060 (a) (2), arthropod pheromones when applied
at up to a maximum use rate of 150 grams active ingredient/acre/year,
and that are not expected to available to avian species, are not
required to provide non-target toxicity data.  Lavandulyl Senecioate is
a synthetic arthropod pheromone that is structurally similar to and
mimics the pheromone produced by the female vine mealybug.   This
compound acts on a select group of insects and has a non-toxic mode of
action.  Lavandulyl Senecioate will be used in retrievably sized
polymeric dispensers within traps at a rate not exceeding 150 gr / acre
/ year.  

 

2.	Environmental Fate and Ground Water Data 

Environmental fate data are not required for this active ingredient
because it is an arthropod pheromone applied at a maximum use rate of
150 grams active ingredient/acre/year, and that is not expected to
available to avian species,. (40 CFR 158.2060)

3.	Ecological Exposure and Risk Characterization

Lavandulyl Senecioate is a synthetic arthropod pheromone that is
structurally identical to and  mimics a naturally occurring pheromone
produced by the female vine mealybybug moth.  It acts on a select group
of insects and has a non-toxic mode of action.  Lavandulyl Senecioate is
intended for use in retrievably sized polymeric dispensers within traps,
which significantly limits the possibility of adverse effects on
non-target avian, aquatic, or insect species.  As a result, no
toxicology or environmental fate and effects data were deemed necessary
for registration.

4.   Endangered Species Assessment

Based on the fact that Lavandulyl Senecioate is not toxic to non-target
organisms and on its use pattern in retrievable dispensers, EPA has
determined it will have "No Effect" on any currently listed threatened
or endangered species or any designated critical habitat

D.	PRODUCT PERFORMANCE DATA (EFFICACY)

Submission of product performance data (OPPTS 810.3000) is listed as a
requirement for all pesticide products. Customarily, the Agency requires
efficacy data to be submitted for review only in connection with the
registration of products directly pertaining to the mitigation of
disease bearing human health organisms and certain designated quarantine
pests, i.g., ticks, mosquitoes, fleas, Mediterranean fruit flies, gypsy
moths, Japanese beetles.  For a list of organisms considered by the
Agency as “public health pests”, please refer to Pesticide
Registration Notice 2002-1 (  HYPERLINK
"http://www.epa.gov/PR_Notices/pr2002-1.pdf" 
http://www.epa.gov/PR_Notices/pr2002-1.pdf ).  

V.	RISK MANAGEMENT DECISION

A.	DETERMINATION OF ELIGIBILITY FOR REGISTRATION 

Section 3(c)(5) of FIFRA provides for the registration of a new active
ingredient if it is determined that (A) its composition is such as to
warrant the proposed claims for it; (B) its labeling and other materials
required to be submitted comply with the requirements of FIFRA; (C) it
will perform its intended function without unreasonable adverse effects
on the environment; and (D) when used in accordance with widespread and
commonly recognized practice it will not generally cause unreasonable
adverse effects on the environment. 

The four criteria of the Eligibility Determination for Pesticidal Active
Ingredients are satisfied by the science assessments evaluating the
subject registration application for products containing Lavandulyl
Senecioate.  Such products are not expected to cause unreasonable
adverse effects on the environment, and are likely to provide protection
as claimed when used according to label instructions. Therefore,
Lavandulyl Senecioate is eligible for registration for the labeled uses.
 

B. REGULATORY DECISION

EPA has determined that Lavandulyl Senecioate presents no issues of
toxicological, ecological, or environmental concern.  As discussed
above, acute toxicity data for Lavandulyl Senecioate demonstrate that it
is either toxicity category IV or III.  Lavandulyl Senecioate does not
demonstrate subchronic or developmental toxicity, and it is not
mutagenic or genotixic.  EPA has no concerns for any non-target
organisms exposed to Lavandulyl Senecioate in accordance with approved
label directions.  EPA has not identified any toxic endpoints for
non-target mammals, birds, plants, aquatic, or soil organisms. Nor are
there concerns for any threatened and endangered species.  Thus, given
that Lavandulyl Senecioate has very low toxicity and presents little if
any risk to non-target organisms, EPA concludes that it is in the best
interests of the public and the environment to issue the registration
for Lavandulyl Senecioate.

Consistent with the Agency’s new policy for making these registration
actions more transparent, EPA has provided a 30-day public comment
period on the decision to register Lavandulyl Senecioate.  No comments
were received during the 30 day public comment period.

The data submitted fulfill the requirements of registration of
Lavandulyl Senecioate as a mating disrupter of mealybug moth on table
and wine grapes, using retrievable polymeric dispensers, and at a rate
not exceeding 150 grams / acre / year.  Refer to Appendix B for
product-specific information.

C. ENVIRONMENTAL JUSTICE  

EPA seeks to achieve environmental justice, the fair treatment and
meaningful involvement of all people, regardless of race, color,
national origin, or income, in the development, implementation, and
enforcement of environmental laws, regulations, and policies. To help
address potential environmental justice issues, the Agency seeks
information on any groups or segments of the population who, as a result
of their location, cultural practices, or other factors, may have
atypical, unusually high exposure to Lavandulyl Senecioate, compared to
the general population. Please comment if you are aware of any
sub-populations that may have atypical, unusually high exposure compared
to the general population.

VI. 	ACTIONS REQUIRED BY REGISTRANTS

The Agency evaluated all of the data submitted in connection with the
initial registration of Lavandulyl Senecioate and determined that these
data are sufficient to satisfy current registration data requirements. 
No additional data are required to be submitted to the Agency at this
time.  For new uses and/or changes to existing uses, additional data may
be required.  

Not withstanding the information stated in the previous paragraph, it
should be clearly understood that certain, specific, data are required
to be reported to the Agency as a requirement for maintaining the
Federal registration for a pesticide product. A brief summary of these
types of data are listed below.   

A.  Reporting of Adverse Effects

Reports of all incidents of adverse effects to the environment must be
submitted to the Agency under the provisions stated in FIFRA, Section
6(a)(2).

B.	Reporting of Hypersensitivity Incidents

Additionally, all incidents of hypersensitivity (including both
suspected and confirmed incidents) must be reported to the Agency under
the provisions of 40 CFR Part 158.2050(d).

VII.	 APPENDIX A. DATA REQUIRMENTS (40 CFR Part 158-Subpart U)

*NOTE:  MRID numbers listed in the following tables are representative
of supporting data for the original registration of the product
containing this active ingredient.  Subsequent to this registration,
there may be additional MRIDs that support registration of other
products containing this active ingredient.   

TABLE 1. Product Chemistry Data Requirements for Lavandulyl Senecioate
(40 CFR § 158.2030)



OPPTS Guideline No.	Study (MRID 475387-01)	Results 

830.1550

to

830.1670	Product identity;

Manufacturing process;

Discussion of formation of unintentional ingredients	Submitted data
satisfy the requirements for product identity, manufacturing process,
and discussion of formation of impurities. 

830.1700	Analysis of samples	Submitted data satisfy the requirements for
analysis of samples.

830.1750	Certification of limits	Limits listed in the CSF are adequate /
acceptable.

830.1800	Analytical method	Acceptable.



TABLE 2.  Physical and Chemical Properties for CheckMate VMB Technical
Pheromonea 



Guideline Reference No./Property	

Description of Result	

Methods



830.6302	Color	Yellow	Visual inspection



830.6303	Physical State	Liquid	Visual inspection 



830.6304	Odor	Slightly burnt, oily	Olfactory inspection



830.6313	Stability	To be conducted

	

830.6314	Oxidation/Reduction: 

Chemical Incompatibility	N/A, the product does not contain any
oxidizing/reducing agents	Product knowledge



830.6315	Flammability	134°C	JIS K 2265



830.6316	Explodability	N/A, product does not contain explosive
ingredients	Product knowledge



830.6317	Storage Stability	To be conducted

	

830.6319	Miscibility	N/A, the product is not an emulsifiable liquid.

	

830.6320	Corrosion Characteristics	To be conducted

	

830.6321	Dielectric Breakdown Voltage	Not required for TGAI/MP

	

830.7000	pH	N/A, the product is not an aqueous solution or suspension

	

830.7100	Viscosity	4.722 mPa at 20°C	JIS K 2283



830.7200	Melting Range	N/A, the product is a liquid

	

830.7220	Boiling Range	106°C at 0.8 mm Hg	Distillation



830.7300	Density/Relative Density/Bulk Density	Density = 0.913 g/cm3 at
20°C	JIS K 2249



830.7370	Dissociation Constant in Water	N/A 

	

830.7550	Partition Coefficient	5.57	OECD 117



830.7840	Water Solubility	8.0 µg/mL	OECD 105



830.7950	Vapor Pressure	0.000515 mmhg at25°C 

	

Table 3. Human Toxicology Data Requirements for Lavandulyl Senecioate
(40 CFR § 158.2050)

Study Type/OPPTS Guideline	

LD50/LC50/Results	

Toxicity Category	MRID



Acute Oral Toxicity/OPPTS 870.1100	>5,000 mg/kg	

IV	47595804



Acute Dermal Toxicity/OPPTS 870.1200	> 5,000 mg/kg	

IV	47595804



Acute Inhalation Toxicity/OPPTS 870.1300	Info. to support tox data
requirements submitted	Waived*

	

Acute Eye Irritation/OPPTS 870.2400	

Minimal effects clearing in less than 24 hours	IV	47595804



Acute Dermal Irritation/OPPTS 870.2500	Moderate irritation at 72 hours	

III	47595804



Skin Sensitization/OPPTS 870.2600	Info. to support tox data requirements
submitted	Waived*

	

Bacterial Reverse Mutation Testing/OPPTS 870.5100	Must be addressed
Waived*

	

In vitro Mammalian Cell Assay/OPPTS 870.5300	Must be addressed	Waived

	

 Acute Inhalation Toxicity (OPPTS 870.1300)/ Skin Sensitization (OPPTS
870.2600)/ Bacterial Reverse Mutation Testing (OPPTS 870.5100)/ In vitro
Mammalian Cell Assay (OPPTS 870.5300):  To address this data
requirement, the applicant submitted a waiver request supported by
credible rationale that shows minimal exposure to active ingredient.  In
fact the product is used a very dose and is enclosed in dispensers which
precludes any significant exposure to the active ingredient. 

VIII. APPENDIX B.

For product specific information, please refer to
http://oaspub.epa.gov/pestlabl/ppls.home.

IX.	APPENDIX C.

REFERENCES

1.  Hinkens, D., McElfresh, J., Millar, J. 2001.  Identification and
synthesis of the sex pheromone of the vine mealybug, Planococcus ficus. 
Tetrahedron Letters, Vol. 42, Issue 9.  Departments of Entomology and
Chemistry, University of California, Riverside, CA. 

Lavandulyl Senecioate	Page   PAGE  14  of   NUMPAGES  14 

Biopesticides Registration Action Document

 PAGE   

