BIOPESTICIDES REGISTRATION ACTION DOCUMENT

Extract of Chenopodium ambrosioides near ambrosioides  (ECANA)

(PC Code 599995)

and

ECANA Mimic (Extract of Chenopodium ambrosioides near ambrosioides
Mimic:  A blend of biochemical ingredients that is substantially similar
to the Extract of Chenopodium ambrosioides near ambrosioides in
composition.)  

(PC Code 179102)

	U.S. Environmental Protection Agency

	Office of Pesticide Programs

	Biopesticides and Pollution Prevention Division

TABLE OF CONTENTS

 TOC \f 

I.	BACKGROUND	4

II.	OVERVIEW 	5

III.  REGULATORY
BACKGROUND..............................................................
................................ 6

	A.	Classification	7

	B.	Food Clearances/Tolerances	7

IV.	RISK ASSESSMANT	7

	A.	Active Ingredient Characterization 	7

	B.	Human Health Assessment 	.8

			1.  Toxicology	8

	2.  Effects on the Endocrine
System………………………………………………………...
..9

	3.  Dose Response Assessment
........................................................................
......................10

			4.  Food Quality Protection Act
Considerations..........................................................
.........10 

	C.	Environmental Assessment	12

			1.  Nontarget Organism Toxicology	12

			2.  Environmental Fate and Ground Water Data	12

			3.  Ecological Exposure and Risk Characterization	13

			4.  Endangered Species Statement	13

	D.	Efficacy Data	14

V.	RISK MANAGEMENT DECISION	14

	A. Determination of Eligibility for Registration 	14

	B. Regulatory Decision 	15

	C. Environmental
Justice………………………………………………………
………………..16

VI.  TERMS AND CONDITIONS OF THE REGISTRATION 	16

  HYPERLINK \l "_Toc200350576"  VII.  APPENDIX A.:  Data Requirements
(40 CFR Part 158)…………………………..1 7

VIII.  APPENDIX B:  PRODUCT SPECIFIC
INFORMATION….......………………………..…24

  HYPERLINK \l "_Toc200350578"  IX.  APPENDIX C: 
References……………………………………………………
…………25 

 

BIOPESTICIDES REGISTRATION ACTION DOCUMENT TEAM

Office of Pesticide Programs:

Biopesticides and Pollution Prevention Division

Biochemical Pesticides Branch (BPB)

Chris Pfeifer	                                 Regulatory Action Leader

Angela Gonzales					Science Reviewer

Kent Carlson, Ph.D.				Biologist

Linda A. Hollis					Branch Chief

Driss Benmhend					Team Leader

Russell S. Jones, Ph.D.			Senior Biologist

I. 	Background:

Extract of Chenopodium ambrosioides near ambrosioides (ECANA) is
classified as a biochemical technical grade of the active ingredient
(TGAI).  The extract is derived from the flowering plant Chenopodium
ambrosioides near ambrosioides, commonly known as American Wormseed. 
ECANA is a mix of constituent terpenes (biochemicals), most of which are
also active ingredients already registered with the Agency.  ECANA is
intended for use as an insecticide and acaricide (mite and tick
pesticide) on food crops and commercial ornamental crops.  The extract
is reported to work through a “nontoxic” mode of action by
temporarily softening an insect’s cuticles, which then leads to a
disruption in respiration.

ECANA Mimic is a blend of individual terpenes that is substantially
similar to the natural extract in composition and effect.  Product
chemistry data confirm the extract’s structural similarity; and
toxicology and efficacy data confirm the equivalency of its effects. 
Based on assessment of the data submitted in support of ECANA and ECANA
Mimic, the two active ingredients are effectively considered to have the
same risk profile, and shall be generally referred to as ECANA, except
in cases where assessment of specific ECANA Mimic data warrants
attention.   

Product chemistry data requirements (product identity, product analysis,
manufacturing process, and physical/chemical properties), mammalian
toxicology data requirements (acute oral, acute dermal, acute
inhalation, dermal irritation, ocular irritation, hypersensitivity,
90-day oral, dermal and inhalation, prenatal development, and
immunotoxicology), and ecological toxicity data requirements (avian
acute oral and dietary, freshwater fish LC50, freshwater invertebrate
LC50, nontarget plant toxicity, nontarget plant toxicity) were fulfilled
by acceptable guideline studies and waiver rationales for both ECANA and
ECANA Mimic.

No significant issues were identified for dietary risk, residential
risk, or ground and surface water contamination from the use of ECANA as
an active ingredient.  Some risks from the use of ECANA and ECANA Mimic
as an active ingredient were identified for occupational professions.
Risks to these populations, however, were acceptably mitigated through
the inclusion of additional personal protective equipment (PPE).

Some risks from the use of ECANA and ECANA Mimic as an active ingredient
were identified for threatened and endangered species. These risks were
acceptably mitigated through label provisions requiring spray buffers
and an application interval for rain events.

The Agency’s risk management decision regarding the registration of
ECANA also notes the following: 1) the active ingredient is naturally
occurring; 2) pesticidal applications of the extract are applied
directly to crops and are limited to 10 applications per year; 3) data
indicate the extract has a very low mammalian toxicity; and 4) pesticide
residues resulting from the intended method of application have been
shown to rapidly degrade in terrestrial environments.

EPA considered ECANA in light of the relevant safety factors in the Food
Quality Protection Act (FQPA) of 1996, and under the Federal
Insecticide, Fungicide, and Rodenticide Act (FIFRA).  The Agency has not
identified any dietary or non-dietary exposure issues that may affect
the U.S. population in general, including infants and children. EPA,
thereby, determined that there is reasonable certainty that no harm will
result from aggregate exposure to ECANA residues, including dietary
exposures and all other sources of exposure.

Consistent with the new policy of making registration actions more
transparent, ECANA Mimic is subject to a 30 day comment period as a
“new active ingredient” whose registration would result in a
“first outdoor use” and a “first food use.”  While a final
decision on registration is contingent upon review and consideration of
public comments, EPA presently believes that based on the risk
assessment and information submitted in support of the registration of
ECANA Mimic that it is in the best interests of the public and the
environment to issue the registration for ECANA Mimic.  The basis for
this preliminary decision can be found in the risk assessment for ECANA
Mimic, which is characterized in this BRAD.  As discussed above, acute
toxicity data for ECANA Mimic indicate a nontoxic profile for acute
toxicity.  ECANA Mimic does not demonstrate subchronic toxicity, and it
is not mutagenic or genotoxic.  The toxicological endpoint for
developmental toxicity for occupational users is not expected to pose a
significant risk as users are required to wear personal protective
equipment and exposures to ECAN Mimic are expected to be virtually
non-existent because of ECANA Mimic’s rapid rate of degradation. EPA
has no concerns for any nontarget organisms exposed to ECANA Mimic in
accordance with approved label directions.  EPA has not identified any
toxic endpoints for nontarget mammals, birds, plants, or soil organisms.
While some aquatic nontarget toxicity has been identified, no risks are
expected because applications are terrestrial, ECANA Mimic biodegrades
rapidly, and label directions further negate the potential for aquatic
exposure.  Because of this lack of exposure, there are no concerns for
any threatened and endangered species.  Thus, given that ECANA Mimic has
very low toxicity, and presents little if any risk to nontarget
organisms, and data confirm its effectiveness as a contact insecticide
and acaricide, EPA concludes that it is in the best interests of the
public and the environment to issue the registration for ECANA Mimic.  

II.	ACTIVE INGREDIENT OVERVIEW

 tc \l2 "ACTIVE INGREDIENT OVERVIEW 

Common Name: 	American Wormseed Oil, Chenopodium Oil, ECANA, and ECANA
Mimic 

Chemical Names: 	Extract of Chenopodium ambrosioides near ambrosioides
and Extract of Chenopodium ambrosioides near ambrosioides Mimic  

Trade & Other Names: 	QRD 406 and QRD 420

CAS Registry Number: 	 CAS# 89997-47-7 for ECANA; No CAS for ECANA Mimic

OPP Chemical Code: 	599995 for ECANA; 179102 for ECANA Mimic 

      Basic Manufacturer:	AgraQuest, Inc. 

	1540 Drew Avenue 

	Davis, CA 95618

	

	Type of Pesticide:		Biochemical insecticide and acaricide (mite and
tick pesticide) for food crops and commercial ornamental crops

Use Sites:  							Applied to food and ornamental crops.  It has outdoor
and greenhouse use sites.

Target Pests:  			Control of aphids, plant-feeding mites, whiteflies,
mealy bugs, leafminers, thrips, fungus gnats, and tarnished plant bugs.

Formulation Type: 		Liquid

 	

Method and Rates 

of Application:  		Applied with commonly used ground equipment,
hose-end, pressurized sprayers and hand-held sprayers. It is diluted
with water to make a sprayable solution.  Upper and lower leaves are
sprayed to the point of saturation.  It is applied on a 7- to 14-day
schedule as necessary.  

Timing: 					Applications should begin at first sign of insect pressure
or plant-feeding mite infestation.

Use Practice 

Limitations: 		Not to be applied more than 10 times per year.  Not to be
used on flowering Cyclamen, Gerbera, Begonia, and Impatiens because it
can cause phytotoxicity in those plants.

III.	  REGULATORY BACKGROUND

 tc \l2 "E.	REGULATORY HISTORY 

On February 25, 2005, the Agency received an application filed by
Codena, Inc., Saint-Charles-sur-Richelieu, Quebec, Canada, JOH 2GO
(submitted by Landis International, Inc., P.O. Box 5126, Valdosta, GA
31603-5126) to register a manufacturing use product containing 100% of
the new biochemical pesticide active ingredient, Extract of Chenopodium
ambrosioides near ambrosioides (PC Code 599995, EPA Reg.# 81978-R) and
two related end use products (EPA Reg.# 81978-E and EPA Reg.# 81978-G). 
A notice of receipt for these applications was published in the Federal
Register May 18, 2005 (Volume 70, Number 95).  Codena, Inc. was
purchased by AgraQuest, Inc. (1520 Drew Ave., Davis, CA, 95618) on
January 9, 2006; EPA Registration Numbers were subsequently transferred
to reflect the new Company Number 69592.  The manufacturing use product
containing 100% Extract of Chenopodium ambrosioides near ambrosioides
was assigned EPA Reg. # 69592-21.   In the course of registration, one
of the end use products was withdrawn.  The remaining use product, which
contains 25% of the active ingredient, was assigned EPA Reg.# 69592-22.

On July 31, 2008, EPA issued a notice (Volume 73, Number 148) announcing
the filing of a pesticide tolerance petition (PP 7F7299) by AgraQuest,
Inc., 1540 Drew Avenue, Davis, CA, 95618.   On January 7, 2009, (Volume
74, Number 4) EPA issued a Final Rule establishing an exemption from the
requirement of a tolerance for the residues of Extract of Chenopodium
ambrosioides near ambrosioides when used as an insecticide/acaricide on
all food commodities (40 CFR Section 180.1287).

On December 18, 2008, the Agency received an application filed by
AgraQuest, Inc., 1520 Drew Ave., Davis, CA, 95618, to register a
manufacturing use product containing 100% of the new biochemical
pesticide active ingredient, ECANA Mimic (PC Code 179102, EPA Reg.#
69592-EU) and a related end use product (EPA Reg.# 69592-EL). 
AgraQuest, Inc. also petitioned the Agency  to amend ECANA’s exemption
from the requirement from tolerance to include ECANA Mimic (Pesticide
Petition (PP) # 9F7551).  A notice of receipt for these applications was
published in the Federal Register on July 22, 2009 (Volume 74, Number
139).  On May 6, 2009, EPA issued a notice (Volume 74, Number 86)
announcing the filing of a pesticide tolerance petition (PP 9F7551) by
AgraQuest, Inc., 1540 Drew Avenue, Davis, CA, 95618.  No comments were
received in response to either notice of ECANA Mimic.  This risk
assessment (BRAD) was posted for comment on April 30, 2010.

A.  Classification	

 tc \l2 "F.	CLASSIFICATION	 

On November 3, 2004, the Biochemical Classification Committee classified
the Extract of Chenopodium ambrosioides near ambrosioides would be
classified as a biochemical pesticide due to its apparent nontoxic mode
of action.  The extract works through a physical mode of action by
softening the cuticles of some insects, resulting in a disruption of
respiration.  In November of 2008, the Biochemical Classification
Committee also classified ECANA Mimic as a biochemical active
ingredient.

B.	Food Clearances/Tolerances

 tc \l2 "G.	FOOD CLEARANCES/TOLERANCES 

An exemption from the requirement of a tolerance is established for the
residues of Extract of Chenopodium ambrosioides near ambrosioides when
used as an insecticide/acaricide on all food commodities (40 CFR Section
180.1287).  This risk assessment supports the amendment of this
exemption to include ECANA Mimic.  In either case, there are no CODEX
maximum residue levels established for these active ingredients.

IV.  RISK ASSESSMENT

A.	Active Ingredient Characterization (40 CFR § 158.2030)

 tc \l4 "a.	Product Identity: 

ECANA is a blended extract product comprised of numerous constituent
compounds.  Three primary constituent compounds (terpenes) have been
identified as product markers.  The balance of the constituents, present
in small percentages and not commonly known to have toxic properties, is
considered as impurities.  The active ingredients are produced via a
distillation process, and the impurities in the product are inherent in
the active ingredient. ECANA Mimic is a proportional blend of the
terpene markers, which is substantially similar to ECANA.  Product
Chemistry data affirm the proportionality, and toxicology and efficacy
data confirm the similar effect. 

Refer to Table 1 in Appendix A for a summary of product chemistry data
requirements for ECANA. Refer to Table 2 in Appendix A for the summary
of physical and chemical characteristics for ECANA; and refer to Table
3, 4, and 5 for the terpene marker in ECANA Mimic.

B.	Human Health Assessment (40 CFR § 158.2050)

 tc \l2 "B.	HUMAN HEALTH ASSESSMENT 

Adequate mammalian toxicology data/information is available to support
registration of ECANA and ECANA Mimic.  All toxicology data requirements
have been satisfied.  Refer to Table 6 in Appendix A for a summary of
the toxicity information on ECANA; refer to Table 7 for the acute
toxicity information associated with ECANA Mimic. 

.

1.	Toxicity tc \l3 "1.	Toxicology Assessment 

For acute toxicity, ECANA is categorized as Toxicity Category III for
acute oral and primary eye.  Acute dermal, acute inhalation and primary
dermal are categorized as Toxicity Category IV.  ECANA is classified as
a dermal sensitizer.  ECANA Mimic showed similar acute toxicity, but had
reduced primary eye toxicity and registered as a Toxicity Category IV;
it was also found not to be a sensitizer.

Genotoxicity studies showed ECANA to be non-mutagenic and to pose no
significant hazard with regard to genotoxicity.  Cited literature also
illustrated common exposure to each of the major marker constituents
without observed teratogenic effect.  Common exposures without observed
effect included: (1) common consumption of the marker constituents in
our fruits and vegetables; (2) regular dermal exposure to the marker
constituents through the use of many cosmetics and generalized contact
with plants; and (3) the natural presence of the marker constituents in
much of the air that we breathe, particularly in spaces rich in
vegetation.	

The Agency accepted waiver rationales for the 90-Day Feeding Study, the
90-Day Dermal Study, the 90-Day Inhalation Study, and the Immune
Response requirement.  The waivers were accepted because no repeated or
subchronic exposures were expected, given the use patterns for this
product.  The following points were also considered:  (1) Repeated human
exposure by the oral route is not anticipated for ECANA end-use
products; (2) Opportunity for exposure is small, given the limited
number of applications and the commercial nature of the use sites; (3) A
residue decline study showed that the marker components of the active
ingredient were not detectable 10 minutes after application to primrose
leaves.; (4) A study where ECANA was applied four times at 2X the label
rate on tomatoes found that the residues of marker components were below
the limit of what can be measured (0.01 mg/kg) at 0 to 24 hrs
post-treatment.  (5) The marker ingredients have all been approved by
FDA for use as food additives, albeit in limited fashion.  

2.	Effects on the Endocrine System tc \l4 "e.	Effects on the Endocrine
System 

As required under FFDCA section 408(p), EPA developed the Endocrine
Disruptor Screening Program (EDSP) to determine whether certain
substances (including pesticide active and other ingredients) may have
an effect in humans or wildlife similar to an effect produced by a
“naturally occurring estrogen or other such endocrine effects as the
Administrator may designate.”  The EDSP employs a two-tiered approach
to making the statutorily required determinations. Tier 1 consists of a
battery of 11 screening assays to identify the potential of a chemical
substance to interact with the estrogen, androgen, or thyroid (E, A, or
T) hormonal systems.  Chemicals that go through Tier 1 screening and are
found to have the potential to interact with E, A, or T hormonal systems
will proceed to the next stage of the EDSP where EPA will determine
which, if any, of the Tier 2 tests are necessary based on the available
data. Tier 2 testing is designed to identify any adverse endocrine
related effects caused by the substance and establish a dose-response
relationship between the dose and the E, A, or T effect.

Between October 2009 and February 2010, EPA is issuing test orders/data
call-ins for the first group of 67 chemicals, which contains 58
pesticide active ingredients and 9 inert ingredients.  This list of
chemicals was selected based on the potential for human exposure through
pathways such as food and water, residential activity, and certain
post-application agricultural scenarios.  This list should not be
construed as a list of known or likely endocrine disruptors.

ECANA and its constituent markers are not among the group of 58
pesticide active ingredients on the initial list to be screened under
the EDSP.  Under FFDCA sec. 408(p), the Agency must screen all pesticide
chemicals.  Accordingly, EPA anticipates issuing future EDSP test
orders/data call-ins for all pesticide active ingredients. 

For further information on the status of the EDSP, the policies and
procedures, the list of 67 chemicals, the test guidelines and the Tier 1
screening battery, please visit our website:    HYPERLINK
"http://www.epa.gov/endo/"  http://www.epa.gov/endo/ .

All available information supports the determination that ECANA is not
an estrogenic, anti-estrogenic, androgenic, or anti-androgenic compound.
ECANA’s constituent markers are naturally occurring compounds that are
present in all of our fruits and vegetables.  To date, there is no
evidence to suggest that our natural exposure to ECANA’s markers
affect the immune system, function in a manner similar to any known
hormone, or that they act as endocrine disruptors.  Moreover, the use of
ECANA is not expected to result in any significant exposures,
effectively obviating any opportunity for negative effects on humans or
the environment.  Therefore, it is unlikely that ECANA would have
estrogenic or endocrine effects.  The Endocrine Disruption Screening
Program (EDSP) has established a protocol, which guides the Agency in
selecting suspect ingredients for review; and the Agency reserves the
right to require new information, should the program require it. 
Presently, based on the lack of exposure and the negligible toxicity
profile of the extract and its mimic, no adverse effects to the
endocrine or immune systems are known or expected.  

3.	Dose Response Assessment

A developmental toxicity study of ECANA established developmental
toxicity endpoints of 0.60 mg/kg-day for maternal exposures and 0.30
mg/kg-day for developmental exposures (DEEM-FCID( analyses).   The
endpoints were derived using data on the constituent marker of the most
toxicological significance, and they are considered conservative.  The
Lowest Observed Adverse Effect Level (LOAEL) for maternal exposures was
125 mg/kg-day, and 60 mg/kg-day for developmental exposure based on
abnormal ossification, increases in skeletal abnormalities, and kidney
weights.  The endpoints do not trigger chronic testing, in this case,
because significant exposure to ECANA or ECANA Mimic is precluded by its
rapid degradation and the requirement for personal protective equipment
(PPE).   

				

4.	Food Quality Protection Act (FQPA) Considerations:  Dietary Exposure
and Risk Characterization

 tc \l3 "3.	Dietary Exposure and Risk Characterization 

Dietary exposure to the residues of the contact insecticide Extract of
Chenopodium ambrosioides near ambrosioides, through food or water, is
expected to be virtually nonexistent.  And even in the event of
exposure, the information on file with the Agency suggests that any
dietary risks would be negligible.

 Three residue studies demonstrate that the rapid degradation of ECANA
leaves no opportunity for post-application exposure. A residue decline
study on primrose demonstrated that, when the extract is sprayed at 4X
the proposed application rate, residues of the three major active
ingredient components declined to non-detectable levels within 10
minutes (MRID (Master Record Identification) 47209101). A second study
on tomatoes involving four applications of the extract within a 24-hour
period found no detectable residues on any samples collected immediately
following the final application (MRID 46858903). A third residue study
on mustard greens involving three applications at twice the application
rate found no detectable residues within the hour after the third
application (MRID 47548301). Essentially, data demonstrate that, by the
time ECANA has dried on the plant, there is no detectable residual
product. Accordingly, the dietary risk assessment of ECANA suggests that
the lack of exposure to residues of the extract obviate any dietary
hazard, and it supports an exemption from the requirement to establish a
tolerance.

Even if residues were found, they would not be cause for concern because
ECANA has been fully assessed and found not to be of toxicological
concern. Humans regularly consume all the constituent components in the
extract through consumption of fruits and vegetables. This regular
dietary exposure has not resulted in any known incidents of toxic
effect. Moreover, the three primary terpene constituents, comprising 70%
of the active ingredient, have been approved by FDA for use in cosmetics
and as food additives. Finally, information submitted on the acute
toxicity, developmental toxicity, and genotoxicity of ECANA confirm a
very low toxicity profile. In sum, no dietary exposure is expected; but
any potential dietary exposures would not be expected to pose any
quantifiable risk due to a lack of residues of toxicological concern.

An assessment of ECANA’s three major terpene constituents-
alpha-terpinene, p-cymene, and d-limonene - further substantiate
ECANA’s low toxicity profile.  All the constituents occur naturally in
fruits, vegetables, herbs, spices, and other foods and beverages, and
are defined as marker compounds in the blended active ingredient. These
three compounds also are permitted as food and fragrance additives in
the U.S. and Europe. Each of the constituents has been fully
characterized by EPA, and each has been reassessed for its use in
pesticides for food uses in the October 2008 risk assessment referenced
above. Based on the information before the Agency, incidental exposures
to these three compounds are without known toxicological incident for
humans. The general public is exposed daily to low levels of these
compounds via ingestion, dermal contact, inhalation through consumption
of foods and beverages, and dermal contact with cosmetics, in excess of
any exposure expected to result from the use of this extract as a
pesticide. The per capita daily consumption of these terpene compounds
as food additives alone amounts to 13.325 milligrams (mg) in the U.S.
and 40.397 mg in Europe (WHO. Evaluation of Certain Food Additives. WHO
Technical Report Series No. 928. Sixty-third Report of the Joint FAO/WHO
Expert Committee on Food Additives. 2005), amounts far in excess of any
potential dietary exposures resulting from exposures to residues from
this pesticidal extract, as discussed below. Alpha-terpinene is found in
the essential oils of a variety of plants including citrus, peppermint,
thyme, basil, and papaya. Per 21 CFR 172.515, it is permitted for direct
addition to food for human consumption. D-limonene is a major component
of lemon oil, orange oil, and grapefruit oil, and it is a minor
component of other fruits, vegetables, meats, and spices. It is widely
used as a flavor and fragrance, and it is generally recognized as safe
(GRAS) by the Food and Drug Administration (FDA) as a food additive or
flavoring, and as a fragrance additive (21 CFR 182.60).  Limonene is a
registered by EPA as an active ingredient in 15 pesticides and is exempt
from the requirement of a tolerance per 40 CFR 180.539. Humans regularly
consume p-cymene through such foods as butter, carrots, nutmeg, orange
juice, oregano, raspberries, lemon oil, and spices.  P-cymene is
permitted by FDA for direct addition to food as a flavoring substance
(21 CFR 172.515). For the reasons set forth below, EPA concludes that
the terpene exposures identified above will either exceed or be
comparable to exposures resulting from the use of this extract as a
pesticide. The balance of the constituents, while not expected to be
active, is also regularly found in fruits, vegetables, and plant
extracts, and determined by EPA not to be of toxicological concern when
used in pesticides for food uses (Risk Assessments for Extract of
Chenopodium ambrosioides near ambrosioides dated February 2008 and
October 2008).  Overall, a thorough analysis of the constituent
compounds of Extract of Chenopodium ambrosioides near ambrosioides
indicates a low toxicity profile and supports an exemption from the
requirement of a tolerance.

ECANA and ECANA Mimic are applied directly to food commodities and
degrade extremely rapidly. However, the Agency notes that, in any event,
no health risks are expected from pesticidal exposure to ECANA or ECANA
Mimic. 

The Agency considered human exposure to ECANA 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 ECANA
when label instructions are followed.  The Final Rule for ECANA, which
provides a more in depth characterization of the lack of risk, can be
found at: http://www.thefederalregister.com/d.p/2009-01-07-E8-31408.

C.	Environmental Assessment (40 CFR § 158.2060)

All nontarget organism, fate, and expression data requirements for ECANA
and ECANA Mimic have been met.  They are summarized below in Table 8 of
Appendix A.

1.	  Nontarget Organism Toxicology tc \l3 "1.	Ecological Effects Hazard
Assessment 

The avian acute oral study (OPPTS 885.4050) and nontarget insects study
(OPPTS 850.4350) show practically no toxicity to birds or nontarget
insects.   A waiver granted for the avian dietary study (OPPTS 850.2200)
makes clear the low probability of dietary exposure to birds.  The
freshwater fish study (OPPTS 850.1075) demonstrated moderate toxicity to
fish, and an aquatic invertebrate study (OPPTS 850.1010) showed high
toxicity to daphnids (water fleas).  Limited use patterns and
restrictive labeling language will preclude significant risk. A waiver
was granted for nontarget plants (OPPTS 850.4350) primarily on the
grounds that the applications of ECANA are directed and nontoxic to most
plant species (MRID 47209703).  Summary information supporting the
nontarget organism data can be found in Table 8 of Appendix A. 

2.  Environmental Fate and Ground Water Data 

Environmental fate and groundwater data for ECANA and ECANA Mimic were
sufficient for registration.  Physical chemistry data extracted from
MRIDs 46396204-46396206, 46858802, 47209701, 47209702 and data extracted
from a nontarget fish study (47209706) and an aquatic invertebrate study
(MRID 47209707) were used in EPA modeling to help quantify the
environmental risks.  The Agency estimated aquatic residues using the
screening model GENeric Estimated Exposure Concentration - GENEEC v2.0. 
Based on the estimated environmental concentrations (EECs) from the
GENEEC model (Table 9) and results from aquatic studies risk quotients
(RQs) were derived to evaluate the potential risk to aquatic animals
(Table 9). The calculated RQs were below the EPA levels of concern (LOC)
for fish and aquatic invertebrates (including endangered species)
chronically exposed to a pesticide when applied in accordance with the
label directions. 

The GENEEC model uses environmental parameters that are typical for a
“standard agricultural field-farm pond” to estimate aqueous
residues. The primary assumption with GENEEC is that the fields receive
one single large rainfall event (either immediately after application or
after a latent period of 2 days) that washes a certain quantity of
pesticides from the fields and into the pond. Degradation and adsorptive
processes modify the initial mass of pesticides in both environments. 
Unlike with foliar residues, the constituent markers of ECANA are not
degraded or volatilized quickly in water. (The EPA-estimated aqueous
half-lives for all the constituent markers from a variety of residue
measurements taken during the aquatic daphnid study (MRID 47209707),
fish toxicity study (MRID 47209706), and aqueous stability study (MRID
47209707) ranged from 35.87 hours to 866.67 hours.)

Aqueous ECANA residue concentrations were estimated by GENEEC for a wide
variety of scenarios using aerial, groundboom, and airblast
applications. Applications were either “watered in” with a rain
event shortly following application or allowed to dry for 2 days prior
to a rain event. Rain events immediately following application increased
residue concentrations in the farm pond to levels such that Daphnid RQs
exceeded the LOCs for every application method. Fish remained below the
LOCs for normal and threatened and endangered species, suggesting low
relative risk to fish. Daphnid RQs from groundboom and airblast to
vineyards applications also were below the LOCs for normal and
threatened and endangered species when residues were allowed to dry for
2 days. As with fish RQs, this suggested that there is low relative risk
to aquatic invertebrates from these application methods. The only aerial
application to have Daphnid RQs less than the LOCs was one in which the
spray dried for 2 days and the application had a 370 foot buffer.
Similar traits were observed for airblast operations to orchards when
using a 14-foot buffer.

LOC exceedences for certain application methods and environmental
conditions required that restrictions or limitations be added to the
proposed label to reduce the potential for “high acute risk” in
aquatic invertebrates. Specifically, aerial, airblast, and groundboom
outdoor methods of application (and presumably other more manual methods
such as handwand, as well) require plant treatment prior to a rain
event. Additionally waterbody spray buffers of 14 feet (groundboom and
airblast) and 370 feet (aerial) are required to mitigate potential
“high acute risk” to aquatic invertebrates.

3.	Ecological Exposure and Risk Characterization

The proposed uses of ECANA and ECANA Mimic are not likely to result in
any ecological risk.  Applications of ECANA and ECANA Mimic are not
expected to result in significant ecological exposure.  The following
factors are expected to address any exposure concerns:  (1) Applications
are terrestrial and targeted at commercial crops, which are not optimal
foraging habitats for most avian, mammalian, and invertebrate species; 
(2) The foliar half-life of the extract is very short (estimated
half-life 7.36 minutes) following application.  The lack of persistence
precludes the opportunity for significant incidental terrestrial
exposures and makes it highly unlikely that residues may migrate to
water in the event of a rain event, effectively precluding any exposures
to aquatic nontarget organisms; (3) Potential spray drift is mitigated
through labeling provisions for buffer requirements and applications
intervals prior to rain events, further obviating both nontarget
terrestrial and aquatic exposures; and (4) Even in the event of
terrestrial exposure, data suggest a lack of acute toxicity to
terrestrial nontarget organisms.  In short, a lack of exposure precludes
all risk; and data suggest that there is no significant toxicity for
terrestrial nontarget organisms for this pesticide, which is limited to
terrestrial use. 

4.	Endangered Species Statement

In March 2008, an ‘Environmental Risk Assessment’ on ECANA found
that pesticidal use of the active ingredient would result in negligible
ecological exposure and that ECANA was ‘Not Likely to Adversely
Affect’ (NLAA) threatened and endangered (T&E) species.  At that time,
an NLAA finding did not require consultation and concurrence with U.S.
Fish and Wildlife Service (USFWS).  In March of 2010, an
‘Environmental Risk Assessment’ on ECANA Mimic determined that the
NLAA finding for ECANA could be extended to ECANA Mimic as it is
effectively the same compound.  Five primary factors limit the potential
for threatened and endangered species to be exposed:  (1) Proposed use
patterns are directed at commercial crops and preclude spraying near
critical habitat for threatened and endangered species.  (2) The rapid
foliar degradation/volatilization (maximum estimated half-life 7.36
minutes) precludes endangered species from being exposed.  (3) The
proposed use areas are not optimal foraging habitat for most avian and
mammalian species, thereby lessening the potential for species to move
into these areas following ECANA applications.  (4) The proposed buffers
around water bodies will substantially mitigate spray drift into water
bodies, thereby reducing or eliminating exposures to T&E aquatic
organisms.  (5) The proposed restriction from application prior to rain
events also will substantially mitigate the potential for residues to
drift or be washed into water bodies, reducing or eliminating exposures
to T&E aquatic organisms.

D.	Efficacy Data

 tc \l2 "D.	EFFICACY DATA 

No efficacy data were submitted in support of label claims and product
performance for applications containing ECANA.  While the conduct of
product performance studies (Efficacy Trials, OPPTS 810.300) is listed
as a requirement for all pesticide products, the Agency customarily only
requires these data to be submitted for review in connection with the
registration of products directly pertaining to the mitigation of
disease bearing human health organisms and certain designated Quarantine
Pests, i.e., ticks, mosquitoes, fleas, Mediterranean fruit flies, Gypsy
Moths, Japanese Beetles, etc.  In this case, the registrant did not make
any public health pest claims on the label, and a submission of efficacy
data was not requested.  Nonetheless, the registrant claims to have such
data on file, and is prepared to submit if requested.

The registrant has made claims against plant-feeding mites.  While an
unqualified claim against mites or a species-specific claim against a
public health pest mite would trigger an efficacy submission, the
registrant has submitted information showing that plant-feeding mites as
a class are fundamentally different than any species of mite listed as a
public health pest in Pesticide Registration Notice 2002-1.

V.	RISK MANAGEMENT DECISION

 tc \l1 "IV.	Risk Management Decision 

A.	Determination of Eligibility for Registration

Section 3(c)5) of FIFRA provides for the registration of new active
ingredients 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. 

To satisfy criteria “A” above, ECANA products are not expected to
cause unreasonable adverse effects when used according to label
instructions. Criteria “B” is satisfied by the current label and the
data presented in this document.  The Agency believes that this
pesticidal active ingredient will not cause any unreasonable adverse
effects, as an insecticide and acaricide, and does provide protection as
claimed satisfying Criteria “C.”  Criteria “D” was satisfied by
the data presented in the initial registration of this biochemical.
Therefore, ECANA meets the standard for registration.

B.	Regulatory Decision 

The data submitted fulfill the requirements of registration for use of
ECANA as a biochemical insecticide and acaricide for use on food and
ornamental crops.  Refer to Appendix B for product-specific information.

On October 1, 2009, EPA announced a new policy to provide a more
meaningful opportunity for the public to participate on major
registration decisions before they occur.  According to this new policy,
EPA intends to provide a public comment period prior to making a
registration decision for, at minimum, the following types of
applications:  new active ingredients; first food use; first outdoor
use; first residential use; and actions for which the Agency anticipates
substantial public interest.  Accordingly, ECANA Mimic is subject to a
30-day comment period as a new active ingredient with both food uses and
outdoor uses.  

At this time, EPA believes, the data submitted fulfill the requirements
of registration for products containing ECANA Mimic as an insecticide
and acaricide. Acute toxicity data for ECANA Mimic demonstrate that it
is toxicity category III and IV for all routes of exposure.  (No
toxicological endpoints were established.)  Data confirm that ECANA
Mimic does not demonstrate subchronic toxicity, and it is not mutagenic
or genotoxic.  While a developmental toxicity endpoint was established
for occupational workers, EPA concludes that a lack of exposure
precludes any potential risk.  EPA has no concerns for any terrestrial
nontarget organisms exposed to ECANA Mimic in accordance with its
approved uses.  EPA has not identified any toxic endpoints for nontarget
mammals, birds, plants, or soil organisms; and while ECANA Mimic
demonstrates some aquatic toxicity, no aquatic exposure is expected. 
Because of a lack of exposure and the virtual nontoxicity of ECANA Mimic
to terrestrial nontarget organisms, EPA there are no concerns for any
threatened and endangered species.  Given, the nontoxic character of
ECANA Mimic, EPA supports its registration under Section 3(c)(5) of the
Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA).  Refer to
Appendix B for product-specific information.

1.	Conditional/Unconditional Registration

All data requirements are fulfilled, and EPA has determined that
unconditional registration of ECANA is appropriate.

All data requirements are fulfilled and EPA has preliminarily determined
that an unconditional registration for ECANA Mimic is warranted under
Section 3(c)(5) of FIFRA.

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.  At this
time, EPA does not believe that use of pesticide products containing
this active ingredient will cause harm or a disproportionate impact on
at-risk communities.

For additional information regarding environmental justice issues,
please visit EPA’s website at:   HYPERLINK
"http://www.epa.gov/compliance/environmentaljustice/index.html" 
http://www.epa.gov/compliance/environmentaljustice/index.html .

VI.  Terms and Conditions of the Registrations

While EPA supports the unconditional registrations of ECANA and ECANA
Mimic, applications of these active ingredients are qualified to provide
further protection for human health and the environment.  The
qualifications follow:

  tc \l2 "V.	Actions Required by Registrants 

ECANA and ECANA Mimic are commercial pesticides, and are presently not
labeled for residential use. 

Aerial applications and chemigation (injecting a chemical into
irrigation water and applying it through the system to the crop or
field) are presently prohibited. 

ECANA and ECANA Mimic registrations presently require 15 foot spray
buffers around water bodies

ECANA and ECANA Mimic registrations prohibit groundboom and airblast
applications when winds exceed 10 mph.

ECANA and ECANA Mimic registrations prohibit application within 2 hours
of an expected rain event.

  

ECANA and ECANA Mimic cannot be applied to a crop more than 10 times per
year. 

ECANA and ECANA Mimic are prohibited for use on the following
ornamentals:  flowering Cyclamen, Gerbera, Begonia, and Impatiens. 

Appendix A

TABLE 1.  Product Chemistry for ECANA (40 CFR § 158.2030)

TABLE 1.  Product Chemistry for ECANA

Guideline Reference No. /Property	ECANA	Citation

830.1550     Product Identity	Active Ingredient - 100.0% by weight 
(extract of Chenopodium ambrosioides var. ambrosioides). Impurities
identified. ECANA Mimic does not have ECANA’s impurities.  ACCEPTABLE
MRID 46396201

47209701 47209702

830.1620     Manufacturing Process	ECANA is manufactured by a
distillation process.  ECANA Mimic is produced by blending terpenes.
ACCEPTABLE	MRID 46396201

47209701 47209702

830.1670     Formation of Unintentional Ingredients	Impurities present
in the product have been described quantitatively. Ascaridole has been
eliminated in the ECANA product. ECANA Mimic does not carry the same
degree of impurities.  ACCEPTABLE	MRID 46396201

47209701 47209702

830.1700     Analysis of Samples	The three main constituents of ECANA
are analyzed. A number of individual samples are outside proposed
certified limits.  Blending brings batches within limits.  ECANA Mimic
is within Agency recommended limits.  ACCEPTABLE	MRID 46396202

830.1750     Certification of Limits	Considering the variability of
plant extracts, the certified limits of ECANA are ACCEPTABLE	MRID
46396202

47209701 47209702

830.1800     Analytical Methods	The enforcement analytical method is
GC-MS for the three central constituents of the active ingredient.
Samples are diluted into acetonitrile, analyzed, and quantified against
known standards on a Varian 3900 GC system with a Saturn 2100T ion trap
mass selective detector. ACCEPTABLE	MRID 46396202

47209701 47209702



TABLE 2.  Physical and Chemical Properties for ECANA (40 CFR §
158.2030)

TABLE 2.  Physical and Chemical Properties for ECANA ( MRIDs
46396204-46396206, 46858802, 47209701, 47209702)  

Guideline Reference No. /Property	ECANA

830.6302	Color	Pale amber, light brown. Color code 136. Color
composition is red=252, green=191, blue=73.

830.6303	Physical State	Semi-volatile liquid

830.6304	Odor	Fruity, woodsy, aromatic, characteristic of monoterpene
blend.

830.6313	Stability	Stability during 14-day exposure to iron chips,
aluminum wire pieces, iron citrate, or aluminum acetate @ room
temperature or 54(C

830.6314	Oxidation/Reduction: 

Chemical Incompatibility	Does not contain oxidizers or reducing agents

830.6315	Flammability	Flash point = 118°F

830.6316	Explodability	Non-explosive

830.6317	Storage Stability	Submitted and acceptable 

830.6319	Miscibility	Not applicable, not intended to be diluted with oil
or non-polar solvents

830.6320	Corrosion Characteristics	Submitted and acceptable



830.6321	Dielectric Breakdown Voltage	Not required for MP or TGAI

830.7000	pH	5.30-5.68, mean of 5.46±0.20 (1% dispersion in deionized
water)



830.7050	UV/Visible 	Not applicable



830.7100	Viscosity	1.79 mPa.s. (Std Dev = 0.16)

830.7200	Melting Range	Not applicable

830.7220	Boiling Range	170-188(C

830.7300	Bulk Density	0.875 - 0.914, mean of 0.895±0.020 g/mL

830.7370	Dissociation Constant in Water	Not applicable

830.7520	Particle Size/Distribution	Not applicable

830.7550	Partition Coefficient	Marker# 1 = 5.09

Marker# 2 = 5.08

Marker# 3 = 4.85

830.7840	Water Solubility	Marker# 1 = 390-511 mg/L, mean of 436±54 mg/L

Marker# 2 = 138-188 mg/L, mean of 160±21 mg/L

Marker# 3 = 145-212 mg/L, mean of 183±25 mg/L

830.7950	Vapor Pressure	2613 Pa (0.38 psig) @ 20(C

3157 Pa (0.46 psig)@ 25(C



able 3: Physicochemical Properties of α-Terpinene (40 CFR § 158.2030)

Parameter	OPPTS #	Value (active ingredient)

Color	830.6302	Clear, nearly colorless

Physical State	830.6303	Liquid

Odor	830.6304	Citrus

Stability	830.6313	Refer to ECANA Mimic data

Flammability	830.6315	117 °F (Tag Closed Cup)

Storage Stability	830.6317	Not Applicable

Miscibility	830.6319	Not Applicable

Corrosion Characteristics	830.6320	Not Applicable

Melting point	830.7200	Not Applicable

Boiling point	830.7220	173 - 175° C

pH	830.7000	Not Applicable

Density (20° C)	830.7300	0.840 g/cm3

Water solubility (25° C)	830.7840	5.6 mg/L

Solvent solubility (20° C)

Soluble in alcohol (100 wt%)

Vapor pressure at 20° C	830.7950	0.8 mm Hg

Octanol/water partition coefficient, log (Kow)	830.7570	5.09

UV/visible absorbance maxima	830.7050	265 nm

Viscosity	830.7100	Not Determined – like water

Log Koc  (Kow method)

3.688

Koc (Kow method)

4877  L/kg

Henry’s Law Constant

5.250 E-2 atm-m3/mole

Surface Tension (dyne/cm)

26.8 ± 3.0



Table 4: Physicochemical Properties of d-limonene (40 CFR § 158.2030) 

Parameter	OPPTS #	Value (active ingredient)

Color	830.6302	Clear, nearly colorless

Physical State	830.6303	Liquid

Odor	830.6304	Citrus

Stability	830.6313	Refer to ECANA Mimic data

Flammability	830.6315	122 °F (Tag Closed Cup)

Storage Stability	830.6317	Not Applicable

Miscibility	830.6319	Not Applicable

Corrosion Characteristics	830.6320	Not Applicable

Melting point	830.7200	Not Applicable

Boiling Point	830.7220	178° C

pH	830.7000	Not Applicable

Density (20° C)	830.7300	0.841 g/cm3

Water solubility (25° C)	830.7840	14 mg/L

Solvent solubility

Soluble in alcohol (100 wt%)

Vapor pressure at 20° C	830.7950	1.0 mm Hg

Octanol/water partition coefficient, log (Kow)	830.7570	4.85

UV/visible absorbance maxima	830.7050	No absorbance 190 – 800 nm

Viscosity	830.7100	Not Determined – like water

Log Koc  (Kow method)

3.801

Koc (Kow method)

6324  L/kg

Henry’s Law Constant

2.535 E-2 atm-m3/mole

Surface Tension (dyne/cm)

25.8 ± 3.0



Table 5: Physicochemical Properties of p-cymene (40 CFR § 158.2030)

Parameter	OPPTS #	Value (active ingredient)

Color	830.6302	Clear, nearly colorless

Physical State	830.6303	Liquid

Odor	830.6304	Lemon

Stability	830.6313	Refer to ECANA Mimic data

Flammability	830.6315	125 °F (Tag Closed Cup)

Storage Stability	830.6317	Not Applicable

Miscibility	830.6319	Not Applicable

Corrosion Characteristics	830.6320	Not Applicable

Melting point	830.7200	Not Applicable

Boiling point 	830.7220	177° C

pH	830.7000	NA

Density (20° C)	830.7300	0.855  g/cm3

Water solubility (25° C)	830.7840	23 mg/L

Solvent solubility 

Soluble in alcohol (100 wt%)

Vapor pressure at 25° C	830.7950	1.46 - 2.0 mm Hg

Octanol/water partition coefficient, log (Kow)	830.7570	5.08

UV/visible absorbance maxima	830.7050	198 nm

Viscosity	830.7100	Not Determined – like water

Log Koc  (Kow method)

3.558

Koc (Kow method)

3614  L/kg

Henry’s Law Constant

1.121 E-2 atm-m3/mole

Surface Tension (dyne/cm)

28.5 ± 3.0



TABLE 6.  Toxicology Data for ECANA (40 CFR § 158.2050)

TABLE 6.  Toxicology Data for ECANA



Guideline Reference No. /Property	

Description of Result	

Methods



870.1100     Acute Oral Toxicity	

Oral LD50 between 2000 and 5000mg/kg, Toxicity Category III; ACCEPTABLE	

MRID 46396207



870.1200     Acute Dermal Toxicity	

Dermal LD50>5000mg/kg, Toxicity Category IV; ACCEPTABLE	

MRID 46396208



870.1300     Acute Inhalation Toxicity	

Inhalation LC50>2.03mg/L, Toxicity Category IV; ACCEPTABLE	

MRID 46396209



870.2400     Primary Eye Irritation	

No corneal opacity or iritis noted. Conjunctival irritation resolving by
day 4, Toxicity Category III; ACCEPTABLE	

MRID 46396210



870.2500     Primary Dermal Irritation	

Very slight erythema persisting through day 14. Very slight edema
clearing by day 7, Toxicity Category IV; ACCEPTABLE	

MRID 46396211



870.2600     Hypersensitivity	

Sensitizer; ACCEPTABLE	

MRID 46396212



Hypersensitivity Incidents	

Incidents must be reported	

Incidents must be reported



870.5000     Genotoxicity	

Not mutagenic to bacterial strains TA98, TA100, TA1535, TA1537 and E
coli strain WP2 uvrA W, ACCEPTABLE

No chromosome aberrations in human lymphocytes, ACCEPTABLE

No induction of DNA repair response in rat hepatocytes, ACCEPTABLE	

MRID 46456301

MRID 46396214

MRID 46396215



880.3550     Immune Response	

ACCEPTABLE limited exposure waiver rationale	

MRID 47209703



870.3100     90-day Feeding (1 spp)	ACCEPTABLE limited exposure waiver
rationale	

MRID 47209703



870.3250     90-day Dermal (1 spp)	ACCEPTABLE limited exposure waiver
rationale	

MRID 47209703



870.3465     90-day Inhalation (1 spp)	ACCEPTABLE limited exposure
waiver rationale	

MRID 47209703



870.3700     Prenatal Development (1 spp)	ACCEPTABLE limited exposure
waiver rationale; also Toxicity endpoint based on Marker study in rats:

Maternal NOAEL=60 mg/kg-day

LOAEL=125 mg/kg-day; based on decreased whole body weight and body
weight minus uterine weights during pregnancy

Developmental NOAEL=30 mg/kg-day

LOAEL=60 mg/kg-day based on abnormal ossification, increases in skeletal
abnormalities and kidney weights	

MRID 47209703



Table 7.  ECANA Mimic Acute Toxicity Results (40 CFR § 158.2050)

Study Type/OPPTS Guideline	

LD50/LC50/Results	

Toxicity Category	MRID



Acute Inhalation Toxicity/OPPTS 870.1300	> 5.14 mg/L	IV	48064501



Acute Eye Irritation/OPPTS 870.2400	

Minimally irritating	IV	48064502



Acute Dermal Irritation/OPPTS 870.2500	Non-irritating	IV	48064503



Skin Sensitization/OPPTS 870.2600	Not a sensitizer	N/A	48064504



Table 8. Nontarget Toxicity of QRD 406 or its Marker Components (40 CFR
§ 158.2060)

Table 8. Nontarget Toxicity of QRD 406 or its Marker Components



Study Type/OPPTS Guideline	LD50/LC50/Results	

Toxicity Category	MRID



Avian Acute Oral

Colinus virginianus

(OPPTS 885.4050)	Acute oral LD50 for northern bobwhites >2250 mg/kg.
ACCEPTABLE.	Practically Nontoxic	47209704



Avian Dietary

(OPPTS 850.2200) 	Waiver rationale based on low probability of exposure,
low acute avian toxicity. ACCEPTABLE.	N/A	47209703



Freshwater Fish LC50 

Pimephales promelas

(OPPTS 850.1075) 	96 hr Nominal conc; 20 mg/L

96 hr Modified for aqueous degradation; 2.2 mg/L (C.I. 1.65-3.3)
ACCEPTABLE.	

Moderately Toxic	47209706



Freshwater Invertebrate

Daphnia magna

(OPPTS 850.1010) 	24, 48 hr Nominal conc; 3.3, 1.3 mg/L

24, 48 hr Modified for aqueous degradation; 0.594, 0.234 mg/L (C.I.
0.414-0.864 and 0.164-0.306).  ACCEPTABLE.	Highly Toxic	47209705



Nontarget Plants (OPPTS 850.4100) 	Salvia, Cosmos, Sweet Allysum NOEC
1%, LOEC based on increased height at 2% and 4%.

Begonia NOEC, not determined; LOEC 2% based on foliar burn and flower
discoloration at 14-21 days.

Vinca (strong varietal response) NOEC, not determined; LOEC 2% based on
dose-dependent increase in foliar black spots.

Impatiens, Petunias NOEC, not determined; LOEC 2% based on
dose-dependent decrease in the number of flowers and open flowers at 21
days

Marigold, Tomato, Zinnias NOEC 2%

Fury, Ingrid, Grandina Gerbera NOEC, not determined; LOEC 2% based on
increase in mature flower necrosis at 7 days, 4% based on increase in
bud necrosis at 7 days

Jack Frost, Sabrina, Sonia Rose NOEC, not determined; LOEC 4% based on
various endpoints such as increased film, increased necrosis on new and
old growth foliage by 7 days, increased necrosis on mature flowers and
flower buds by 7 days. ACCEPTABLE.	N/A	47209703



Nontarget Insects 

Orius insidiosus

Aphidius colemani 

Bombus impatiens (OPPTS 850.4350)	Orius insidiosus; 48 h; contact
toxicity; nymph 29.15 g/L (C.I. 23.33-36.14), adult 11.28 g/L (C.I.
7.32-15.31) 

Aphidius colemani; 48 h; contact toxicity; females 13.23 g/L (C.I.
7.50-18.90), males 7.70 g/L (C.I. 1.57-16.57) 

Bombus impatiens; 7, 14 day; contact toxicity; 0.1458 mg/cm2 (C.I.
0.1180-0.2043), 0.0771 mg/cm2 (C.I. 0.0475-0.1723)

Bombus impatiens; 7, 14 day; contact toxicity; 0.1076 mg/bee, 0.0569
mg/bee; 7, 14 day LC50 (95% C.I.); 15.4% (7.68-101.19), 8.75%
(5.69-17.67) ACCEPTABLE.

Green peach aphid; 24 h; 0.63% (C.I. 0.47-0.79%)

Western flower thrip; 24 h; 0.0034 mg/cm2 (C.I. 0.0027-0.0039 mg/cm2) 

Greenhouse whitefly; 24 h; 0.0066 mg/cm2 (C.I. 0.0054-0.0076 mg/cm2)
ACCEPTABLE.	III

Practically

Nontoxic	47209703



Table 9. Aqueous Concentrations of ECANA Modeled from GENEEC

Table 9. Aqueous Concentrations of ECANA Modeled from GENEEC Following
Various Outdoor Application Methods

Application Method	Spray Buffer (ft)	Wet In from Rain Event	Peak EEC
Concentration

(μg/L)	1 Daphnid RQ	2 Fish RQ	Max 4 Day Average (μg/L)	Max 21 Day
Average (μg/L)	Max 60 Day Average (μg/L)	Max 90 Day Average (μg/L)

Airblast - orchards	100 (14)	No	3.92	0.02 (0.05)	<0.01	3.69	2.09	0.88
0.59

Airblast - vineyards	None	No	2.67	0.01	<0.01	2.52	1.42	0.60	0.40

Airblast - vineyards	100	No	0.382	<0.01	<0.01	0.359	0.204	0.086	0.058

Groundboom - high boom - fine spray	100	No	2.13	0.01	<0.01	2.00	1.13
0.48	0.32

Groundboom - low boom - fine spray	None	No	4.95	0.02	<0.01	4.67	2.64
1.12	0.75

Groundboom - low boom - fine spray	100	No	0.863	<0.01	<0.01	0.813	0.460
0.194	0.130



1 Daphnid RQs = Peak EEC concentration (mg/L)/0.234 mg/L

2 Fish RQs = Maximum 4 day Average EEC concentration (mg/L)/2.2 mg/L

VII.	Appendix B

REFERENCES

he embryofoetotoxicity of α-terpinene in the rat. Food and Chemical
Toxicology. 34: 477-482.

	El-Mofty, M.M., Khudoley, V.V., Sakr, S.A., and N.F. Ganem. 1992.
Induction of neoplasms in Egyptian toads Bufo regularis by oil of
Chenopodium. Oncology. 49: 253-255.

	EPA. 1994. Reregistration eligibility document (RED): Limonene. EPA
738-R-94-034.

	EPA. 1997. Standard operating procedures (SOPs) for residential
exposure assessments. Contract No. 68-W6-0030.

	EPA. 1998. PHED surrogate exposure guide. Estimates of worker exposure
from the Pesticide Handler Exposure Database version 1.1. Scenario 32,
34-36.

	Kapadia, G.J., Chung, E.G., Ghosh, B., Shukla, Y.N., Basak, S.P.,
Morton, J.F., and S.N. Pradhan. 1978. Carcinogenicity of some folk
medicinal herbs in rats. J. Natl Cancer Inst. 60: 683-686. 

	NPIC. 2006. Biopesticide incidents: Reporting period April 1, 1995 to
August 21, 2006. National Pesticide Information Center. Environmental
and Molecular Toxicology, Oregon State University. Report Number
EPAKCa09/12/2006. 6pp.

	World Health Organization. 2005. Evaluation of certain food additives.
WHO Technical Report Series 928. 63rd report of the Joint FAO/WHO Expert
Com. on Food Additives. 157 pp.

VIII.	Appendix C

Product Labels

ECANA Manufacturing Use Product Label

ECANA End Use Product Label

ECANA Mimic Manufacturing Use Product Label

ECANA Mimic End Use Product Label

		

A.  Manufacturing Use Product

QRD 406

FOR FORMULATION INTO INSECTICIDE AND ACARICIDE PRODUCTS

FOR MANUFACTURING OR FORMULATION USE ONLY

Active Ingredient:

Extract of Chenopodium ambrosioides near ambrosioides	100.0%

Total:	100.0%

KEEP OUT OF REACH OF CHILDREN

CAUTION

FIRST AID

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 eye.

Call a poison control center or doctor for further treatment advice.

If Swallowed	

Call poison control center or doctor for treatment advice.

Have person sip a glass of water if able to swallow.

Do not induce vomiting unless told to do so by the 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 15-20 minutes. 

Call a poison control center or doctor for treatment advice. 

HOT LINE NUMBER

CHEMTREC (800) 424-9300  (24 hours)

Have the product container or label with you when calling a poison
control center or doctor or going for treatment.



See side/back panels for additional precautionary statements

EPA Reg No. 69592-21	EPA Establishment No. 69592-MEX-1

Net Contents:  2.5 gallon (320 fl. oz.) (9.5 L)

   [4 gallon  (15.2 L)]



Manufactured By:

AgraQuest, Inc.

1540 Drew Avenue

Davis, California   95618

(530) 750-0150

PRECAUTIONARY STATEMENTS

HAZARD TO HUMANS AND DOMESTIC ANIMALS

CAUTION:  Harmful if swallowed.  Causes moderate eye irritation.  Avoid
contact with eyes or clothing.  Wash thoroughly with soap and water
after handling and before eating, drinking, chewing gum or using
tobacco.  Prolonged or frequently repeated skin contact may cause
allergic reactions in some individuals.  Mixers, loaders and handlers
must wear the appropriate personal protective equipment (PPE):
coveralls, chemical-resistant gloves and protective eyewear.  Remove and
wash contaminated clothing before reuse.

ENVIRONMENTAL HAZARDS 

Do not discharge effluent containing this product into lakes, streams,
ponds, estuaries, oceans or other waters unless in accordance with the
requirements of a National Pollutant Discharge Elimination System
(NPDES) permit and the permitting authority has been notified in writing
prior to discharge. Do not discharge effluent containing this product to
sewer systems without previously notifying the local sewage treatment
plant authority. For guidance contact your State Water Board or Regional
Office of the EPA.  Do not contaminate water when disposing of equipment
washwaters or rinsate. 

This pesticide is toxic to aquatic invertebrates.

PHYSICAL OR CHEMICAL HAZARDS

Combustible.  Do not use or store near heat or open flame.

DIRECTIONS FOR USE

It is a violation of Federal law to use this product in a manner
inconsistent with its labeling.	

QRD 406 is intended for use in the formulation of insecticides and
acaricides to be applied to field and container-grown non-food
ornamental plants in commercial nurseries, greenhouses, and lath- and
shade houses. 

This product may be used to formulate products for any additional uses
not listed on the MP label if the formulator, user group, or grower has
complied with U.S. EPA data submission requirements regarding the
support of such uses.  Products formulated from this technical material
will require registration with the U.S. Environmental Protection Agency
(EPA).

STORAGE AND DISPOSAL

Do not contaminate water, food or feed by storage or disposal.

Pesticide Storage:  Store in a cool dry place.  Avoid freezing.  

Pesticide Disposal:  To avoid wastes, use all material in this container
by application according to label directions.  If wastes cannot be
avoided, offer remaining product to a waste disposal facility or
pesticide disposal program (often such programs are run by state or
local governments or by industry).

Do not contaminate water when disposing of equipment washwater or
rinsate.  Pesticide wastes may be toxic.  Improper disposal of unused
pesticide, washwater or rinse water is a violation of federal law.  

Container Disposal:  Nonrefillable container.  Do not reuse or refill
this container.

Triple rinse container (or equivalent) promptly after emptying.  Triple
rinse as follows:  Empty the remaining contents into application
equipment or a mix tank and drain for 10 seconds after the flow begins
to drip.  Fill the container ¼ 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. Then offer for
recycling if available, or puncture and dispose of in a sanitary
landfill or by incineration.  Do not burn unless allowed by state and
local ordinances.

B.  End Use Product Label

QRD 400

Insecticide and Acaricide

For Use on Non-Food Ornamentals (Trees, Shrubs, and Bedding plants)

Not For Residential Use

	

Active Ingredient:

Extract of Chenopodium ambrosioides near ambrosioides	25.0%

Other Ingredients	75.0%

Total:	100.0%

KEEP OUT OF REACH OF CHILDREN

CAUTION

FIRST AID

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 eye.

Call a poison control center or doctor for further treatment advice.

In On Skin Or Clothing

	

Take off contaminated clothing.

Rinse skin immediately with plenty of water for 15-20 minutes.

Call a poison control center or doctor for further treatment advice.



HOT LINE NUMBER 



CHEMTREC (800) 424-9300 (24 hours)

Have the product container or label with you when calling a poison
control center or doctor or going for treatment.



See side/back panels for additional precautionary statements

EPA Reg No. 69592-22	  EPA Establishment No. 69592-MEX-1

Net Contents:  1 gallon (128 fl. oz.) (3.8 L)

    		 [ 2.5 gallon  (320 fl. oz.) (9.5 L)]

Manufactured By:

AgraQuest, Inc.

1540 Drew Avenue

Davis, California   95618

(530) 750-0150

PRECAUTIONARY STATEMENTS

HAZARD TO HUMANS AND DOMESTIC ANIMALS

CAUTION:  Causes moderate eye irritation.  Avoid contact with skin, eyes
or clothing.  Wash thoroughly with soap and water after handling and
before eating, drinking, chewing gum or using tobacco. Remove and wash
contaminated clothing before reuse.  Prolonged or frequently repeated
skin contact may cause allergic reactions in some individuals.  Wear the
appropriate Personal Protective Equipment (PPE).

PERSONAL PROTECTIVE EQUIPMENT

Applicators mixers, loaders and other handlers must wear:

Long-sleeved shirt and long pants

Chemical-resistant gloves made of any waterproof material

Shoes plus socks

Protective eyewear

Coveralls for high-pressure handwand and groundboom applicators.

For greenhouse uses, applicators and other handlers must wear a
NIOSH-approved respirator with an organic vapor (OV) cartridge or
canister with any R, P or HE filter. 

Follow the manufacturer’s instructions for cleaning/maintaining PPE.
If no such instructions for washables, use detergent and hot water. 
Keep and wash PPE separately from other laundry.

USER SAFETY RECOMMENDATIONS

Users should: 

● Remove clothing 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 product is toxic to aquatic invertebrates.  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.  

Drift and runoff may be hazardous to aquatic organisms in water adjacent
to treated areas. Do not apply when weather conditions favor drift or
runoff from treated areas. Do not apply when a rain event is expected
within 2 hours. Air blast applications must maintain a spray buffer of
15 feet from any waterbody.  See the Directions for Use for details.

  

PHYSICAL OR CHEMICAL HAZARDS

Combustible.  Do not use or store near heat or open flame.  

DIRECTIONS FOR USE

It is a violation of Federal law to use this product in a manner
inconsistent with its labeling. 

READ THE ENTIRE LABEL.  USE STRICTLY IN ACCORDANCE WITH THE LABEL.
Failure to follow directions and precautions on this label may result in
crop injury, poor insect control, and/or illegal residues. 

	

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 State or Tribal agency responsible for
pesticide regulation.

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, greenhouses and handlers of agricultural
insecticides.  It contains requirements for training, decontamination,
notification and emergency assistance.  It also contains specific
instructions and exceptions pertaining to the statements on this label
about personal protective equipment (PPE) and restricted-entry interval.
 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) of 4 hours.

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:

Long-sleeved shirt and long pants

Chemical-resistant gloves made of any waterproof material

Shoes plus socks 

NON-AGRICULTURAL USE REQUIREMENTS

The requirements in this box apply to uses that are NOT within the scope
of the Worker Protection Standard for agricultural pesticides (40 CFR
Part 170).  The WPS applies when this product is used to produce
agricultural plants on farms, nurseries or green houses. 

Do not enter treated areas without protective clothing until spray has
dried.  Refer to Personal Protective Equipment section under the
Precautionary Statements section.

GENERAL INFORMATION

QRD 400 is an Emulsifiable Concentrate (EC) Insecticide and Acaricide
for Use on Field and Container-grown Non-Food Ornamental Plants in
Commercial Nurseries, Greenhouses, and Lath- and Shade-houses. Not For
Residential Use.

QRD 400 is a contact insecticide/acaricide for use in the control of
aphids, plant-feeding mites, whiteflies, mealy bugs, leafminers, thrips,
fungus gnats, and tarnished plant bugs. QRD 400 can be applied to field
and container-grown non-food ornamentals – trees, Christmas trees,
shrubs, flowers, annual and perennial bedding plants, potted flowers,
and tropical plants.

MIXING AND APPLICATION INSTRUCTIONS

Do not apply this product by aerial application or through any type of
irrigation system. 

QRD 400 is toxic to aquatic invertebrates.  Users must maintain the
following buffer zones:  Airblast spray applicators must not apply
within 15 feet of aquatic habitats (such as, but not limited to, lakes,
reservoirs, rivers, streams, marshes, ponds, estuaries, and commercial
fish ponds).  Groundboom and airblast applicators must also account for
wind direction and speed.  Only apply this product if the wind direction
favors on-target deposition.  Do not apply when the wind velocity
exceeds 10 mph. Do not apply when a rain event is expected within 2
hours. 

Shake container well before use. QRD 400 must be diluted with water for
spray applications. Partially fill the spray tank with clean water, add
the specified amount of QRD 400 to the tank (see table below), and
finish filling the tank to the desired volume to obtain the proper spray
concentration for the desired application rate per acre.

Gallons Water per Acre	QRD 400 gallons

0.5% solution	QRD 400 gallons

1% solution

25	0.12  (16 fl oz)	0.25  (32 fl oz)

50	0.25  (32 fl oz)	0.5  (64 fl oz)

75	0.37  (48 fl oz)	0.75  (96 fl oz)

100	0.5	1

   For smaller quantities, mix at a rate of 0.65 – 1.3 fl.  oz. QRD
400 per 1 gallon of water.



Apply on a 7- to 14-day schedule as necessary.  Apply QRD 400 at first
sign of insect pressure or plant-feeding mite infestation.  Use higher
application rate under conditions of heavy pest pressure.  Uniform
coverage of both upper and lower leaves is critical for effective pest
control.  Avoid over spraying to the point of excessive runoff. Do not
apply QRD 400 more than 10 times per year. 

QRD 400 can be applied with commonly used ground equipment, hose-end,
pressurized, greenhouse, and hand-held sprayers. 

Biological Control Agents: This product is compatible with the following
biological control agents: Encarsia formosa, Amblyseius fallacis,
Phytoseiulus persimilis, Orius insidiosus,  Aphidius colemani, 
Zetzellia mali, Neoseiulus fallacies, Typhlodromus pyri, Stethorus
punctum,  lacewings, syrphid fly larvae, phytoseiid mite predators,
aphid midges, lady beetles, and other predacious mites.  Wait at least 2
hours after application before introducing new biological agents, or
spray the evening before the day of introduction of new biological
control agents. 

AgraQuest is committed to the practice of sound resistance management
programs that include rotation and tank mixing with other treatments
having a variety of modes of actions. 

Compatibility: Do not combine QRD 400 in the spray tank with other
pesticides, surfactants, adjuvants, or fertilizers if there has been no
previous experience or use of the combination to show it is physically
compatible, effective and non-injurious under your use conditions. 

To ensure compatibility of tank-mix combinations they must be evaluated
prior to use. To determine the physical compatibility of this product
with other products, use a jar test. Using a quart jar, add the
proportionate amounts of the products to approximately one quart of
water with agitation. Add dry formulations first, then flowables, then
emulsifiable concentrates last. After thorough mixing, allow this
mixture to stand for 5 minutes. If the combination remains mixed or can
be readily remixed, it is physically compatible. Once compatibility has
been proven, use the same procedure for adding required ingredients to
the spray tank. Test the combination on a small number of plants to
check for phytotoxicity before treating large areas. Do not use the
combination if adverse effects are observed. 

PLANTS EVALUATED FOR PHYTOTOXICITY

QRD 400 has been evaluated alone in a wide range of crops and
ornamentals. However, since testing on all varieties of all ornamentals
is not feasible, testing a small portion of the area to be treated for
phytotoxicity is required before treating the entire area. Further, all
possible combinations or sequences of pesticide sprays, including other
fertilizers, surfactants, adjuvants and other pesticides, have not been
tested; thus, testing for compatibility and phytotoxicity of spray
mixtures is required. Use the product in accordance with all label use
directions. It is further required that spray equipment used to apply
QRD 400 be thoroughly cleaned before use. 

Phytotoxicity has occasionally been observed following the use of this
product on flowers of Cyclamen, Gerbera, Begonia, and Impatiens. Do not
use QRD 400 on flowering Cyclamen, Gerbera, Begonia, and Impatiens. 

STORAGE AND DISPOSAL

Do not contaminate water, food or feed by storage or disposal.

Pesticide Storage:  Store in a cool dry place.  Avoid freezing.  

Pesticide Disposal:  To avoid wastes, use all material in this container
by application according to label directions.  If wastes cannot be
avoided, offer remaining product to a waste disposal facility or
pesticide disposal program (often such programs are run by state or
local governments or by industry).

Do not contaminate water when disposing of equipment washwater or
rinsate.  Pesticide wastes may be toxic.  Improper disposal of unused
pesticide, washwater or rinse water is a violation of federal law.  

Container Disposal: Non-refillable container.  Do not reuse or refill
this container

Triple rinse container (or equivalent) promptly after emptying.  Triple
rinse as follows:  Empty the remaining contents into application
equipment or a mix tank and drain for 10 seconds after the flow begins
to drip.  Fill the container ¼ 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. Then offer for
recycling if available, or puncture and dispose of in a sanitary
landfill or by incineration.  Do not burn unless allowed by state and
local ordinances.

WARRANTY AND DISCLAIMER STATEMENT

AgraQuest warrants to those persons lawfully purchasing this product
that at the time of the first sale of this product by Seller that this
product conformed to its description and was reasonably fit for the
purposes stated on the label when used in accordance with Seller’s
directions.  Buyers and users of this product assume the risk of any use
contrary to such directions. EXCEPT AS PROVIDED ELSEWHERE IN WRITING
CONTAINING AN EXPRESS REFERENCE TO THIS WARRANTY AND LIMITATION OF
DAMAGES, SELLER MAKES NO OTHER EXPRESS OR IMPLIED WARRANTY OR GUARANTY,
INCLUDING ANY OTHER EXPRESS OR IMPLIED WARRANTY OF FITNESS OR OF
MERCHANTABILITY AND NO AGENT OF SELLER IS AUTHORIZED TO DO SO.  Except
to the extent prohibited by applicable law, AgraQuest offers this
product with the following conditions: 1) buyers and users of this
product assume the risk of any storage, handling or use contrary to
AgraQuest’s label and directions and 2) AgraQuest’s liability shall
in no case exceed the purchase price of the applicable AgraQuest
product.

ECANA Mimic Manufacturing Use Product Label

QRD 420

FOR FORMULATION INTO INSECTICIDE AND ACARICIDE PRODUCTS

FOR MANUFACTURING OR FORMULATION USE ONLY

Active Ingredient:

ECANA Mimic*	67.0%

Other Ingredients	33.0%

Total:	100.0%

* ECANA mimic is a blend of nature-identical components that
substantially replicate the composition and activity of plant-produced
Extract of Chenopodium ambrosioides near ambrosioides (ECANA).  

KEEP OUT OF REACH OF CHILDREN

CAUTION

FIRST AID

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 eye.

Call a poison control center or doctor for further treatment advice.

If Swallowed	

Call poison control center or doctor for treatment advice.

Have person sip a glass of water if able to swallow.

Do not induce vomiting unless told to do so by the 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 15-20 minutes. 

Call a poison control center or doctor for treatment advice. 

HOT LINE NUMBER

CHEMTREC (800) 424-9300  (24 hours)

Have the product container or label with you when calling a poison
control center or doctor or going for treatment.

See side/back panels for additional precautionary statements

EPA Reg No. 69592-EU	EPA Establishment No. 69592-MEX-1

Net Contents:  2.5 gallon (320 fl. oz.) (9.5 L)

   [4 gallon  (15.2 L)]

Manufactured By:

AgraQuest, Inc.

1540 Drew Avenue

Davis, California   95618

(530) 750-0150

PRECAUTIONARY STATEMENTS

HAZARD TO HUMANS AND DOMESTIC ANIMALS

CAUTION:  Harmful if swallowed.  Causes moderate eye irritation.  Avoid
contact with eyes or clothing.  Wash thoroughly with soap and water
after handling and before eating, drinking, chewing gum or using
tobacco.  Prolonged or frequently repeated skin contact may cause
allergic reactions in some individuals.  Mixers, loaders and handlers
must wear the appropriate personal protective equipment (PPE):
coveralls, chemical-resistant gloves and protective eyewear.  Remove and
wash contaminated clothing before reuse.

ENVIRONMENTAL HAZARDS 

Do not discharge effluent containing this product into lakes, streams,
ponds, estuaries, oceans or other waters unless in accordance with the
requirements of a National Pollutant Discharge Elimination System
(NPDES) permit and the permitting authority has been notified in writing
prior to discharge. Do not discharge effluent containing this product to
sewer systems without previously notifying the local sewage treatment
plant authority. For guidance contact your State Water Board or Regional
Office of the EPA.  Do not contaminate water when disposing of equipment
washwaters or rinsate. 

This pesticide is toxic to aquatic invertebrates.

PHYSICAL OR CHEMICAL HAZARDS

Combustible.  Do not use or store near heat or open flame.

DIRECTIONS FOR USE

It is a violation of Federal law to use this product in a manner
inconsistent with its labeling.	

QRD 420 is intended for use in the formulation of insecticides and
acaricides to be applied to field and container-grown plants in
commercial nurseries, greenhouses, and lath- and shade houses, and
labeled agricultural crops. 

This product may be used to formulate products for any additional uses
not listed on the MP label if the formulator, user group, or grower has
complied with U.S. EPA data submission requirements regarding the
support of such uses.  Products formulated from this technical material
will require registration with the U.S. Environmental Protection Agency
(EPA).

STORAGE AND DISPOSAL

Do not contaminate water, food or feed by storage or disposal.

Pesticide Storage:  Store in a cool dry place.  Avoid freezing.  

Pesticide Disposal:  To avoid wastes, use all material in this container
by application according to label directions.  If wastes cannot be
avoided, offer remaining product to a waste disposal facility or
pesticide disposal program (often such programs are run by state or
local governments or by industry).

Do not contaminate water when disposing of equipment washwater or
rinsate.  Pesticide wastes may be toxic.  Improper disposal of unused
pesticide, washwater or rinse water is a violation of federal law.  

Container Disposal:  Nonrefillable container.  Do not reuse or refill
this container

Triple rinse container (or equivalent) promptly after emptying.  Triple
rinse as follows:  Empty the remaining contents into application
equipment or a mix tank and drain for 10 seconds after the flow begins
to drip.  Fill the container ¼ 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. Then offer for
recycling if available, or puncture and dispose of in a sanitary
landfill or by incineration.  Do not burn unless allowed by state and
local ordinances.

ECANA Mimic End Use Product Label

QRD 452

™ II]

Master Label

Sub-Label A: Agricultural/Commercial Use

Sub-Label B: Greenhouse & Nursery/Commercial Use

Active Ingredient:

ECANA Mimic*	16.75%

Other Ingredients	83.25%

Total:	100.0%

* ECANA mimic is a blend of nature-identical components that
substantially replicate the composition and activity of plant-produced
Extract of Chenopodium ambrosioides near ambrosioides (ECANA).  

KEEP OUT OF REACH OF CHILDREN

CAUTION

EPA Reg No.: 69592- EL	EPA Establishment No.:  69592-MEX-1

    		 

Manufactured By:

AgraQuest, Inc.

1540 Drew Avenue

Davis, California   95618

(530) 750-0150

QRD 452

(Alternate Brand Name: REQUIEM® 16.75EC)

Sub-Label A

For Agricultural / Commercial Use Only

Not For Residential Use

REQUIEM® 16.75EC

Insecticide and Acaricide for control or suppression of aphids, thrips,
whiteflies, plant-feeding mites, mealy bugs, leafminers, lygus bugs,
scale, leaf hoppers, and lepidopterous insects in agricultural crops.

Not For Residential Use

Active Ingredient:

ECANA Mimic*	16.75%

Other Ingredients	83.25%

Total:	100.0%

* ECANA mimic is a blend of nature-identical components that
substantially replicate the composition and activity of plant-produced
Extract of Chenopodium ambrosioides near ambrosioides (ECANA).  

KEEP OUT OF REACH OF CHILDREN

CAUTION

FIRST AID

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 eye.

Call a poison control center or doctor for further treatment advice.

In On Skin Or Clothing

	

Take off contaminated clothing.

Rinse skin immediately with plenty of water for 15-20 minutes.

Call a poison control center or doctor for further treatment advice.



HOT LINE NUMBER 



CHEMTREC (800) 424-9300 (24 hours)

Have the product container or label with you when calling a poison
control center or doctor or going for treatment.

See side/back panels for additional precautionary statements

EPA Reg No.: 69592- EL	EPA Establishment No.:  69592-MEX-1

Net Contents:  2.5 gallon (320 fl. oz.) (9.46 L)

    		 

Manufactured By:

AgraQuest, Inc.

1540 Drew Avenue

Davis, California   95618

(530) 750-0150

PRECAUTIONARY STATEMENTS

HAZARD TO HUMANS AND DOMESTIC ANIMALS

CAUTION:  Causes moderate eye irritation.  Avoid contact with skin, eyes
or clothing.  Wash thoroughly with soap and water after handling and
before eating, drinking, chewing gum or using tobacco. Remove and wash
contaminated clothing before reuse.  Prolonged or frequently repeated
skin contact may cause allergic reactions in some individuals.  Wear the
appropriate Personal Protective Equipment (PPE).

PERSONAL PROTECTIVE EQUIPMENT

Applicators mixers, loaders and other handlers must wear:

Long-sleeved shirt and long pants

Chemical-resistant gloves made of any waterproof material such as
polyethylene or polyvinyl chloride

Shoes plus socks

Protective eyewear

Coveralls for high-pressure handwand and groundboom applicators.

For overhead exposure wear chemical resistant headgear.

For greenhouse uses, applicators and other handlers must wear a
NIOSH-approved respirator with an organic vapor (OV) cartridge or
canister with any R, P or HE filter. 

Follow the manufacturer’s instructions for cleaning/maintaining PPE.
If no such instructions for washables, use detergent and hot water. 
Keep and wash PPE separately from other laundry.

Engineering Controls: When handlers use enclosed cabs in a manner that
meets 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.

USER SAFETY RECOMMENDATIONS

Users should: 

● Remove clothing 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 product is toxic to aquatic invertebrates.  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.  

Drift and runoff may be hazardous to aquatic organisms in water adjacent
to treated areas. Do not apply when weather conditions favor drift or
runoff from treated areas. Do not apply when a rain event is expected
within 2 hours. Groundboom and air-blast applications must maintain a
spray buffer of 15 feet from any water body. See the Directions for Use
for details.

DIRECTIONS FOR USE

It is a violation of Federal law to use this product in a manner
inconsistent with its labeling. 

READ THE ENTIRE LABEL.  USE STRICTLY IN ACCORDANCE WITH THE LABEL.
Failure to follow directions and precautions on this label may result in
crop injury, poor insect control, and/or illegal residues. 

	

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 State or Tribal agency responsible for
pesticide regulation.

 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, greenhouses and handlers of agricultural
insecticides. It contains requirements for training, decontamination,
notification and emergency assistance. It also contains specific
instructions and exceptions pertaining to the statements on this label
about personal protective equipment (PPE) and restricted-entry interval.
 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) of 4 hours.

 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:

Long-sleeved shirt and long pants

Chemical-resistant gloves made of any waterproof material such as
polyethylene or polyvinyl chloride

Shoes plus socks 

SHAKE WELL BEFORE USE 

GENERAL INFORMATION

REQUIEM® is a contact insecticide/acaricide for use in the control or
suppression of many foliage feeding plants including aphids, thrips,
plant-feeding mites, whiteflies, mealy bugs, leafminers, lygus bugs,
scale, leaf hoppers, and lepidopterous insects infesting labeled crops.
The emulsifiable concentrate of REQUIEM must be mixed with water and
applied as a foliar spray with ground equipment equipped for
conventional insecticide spraying.  

MIXING AND APPLICATION INSTRUCTIONS

Do not apply this product by aerial application or through any type of
irrigation system. 

REQUIEM is toxic to aquatic invertebrates.  Users must maintain the
following buffer zones:  Groundboom and air-blast spray applicators must
not apply within 15 feet of aquatic habitats (such as, but not limited
to, lakes, reservoirs, rivers, streams, marshes, ponds, estuaries, and
commercial fish ponds).  Groundboom and air-blast applicators must also
account for wind direction and speed.  Only apply this product if the
wind direction favors on-target deposition.  Do not apply when the wind
velocity exceeds 10 mph. Do not apply when a rain event is expected
within 2 hours. 

Shake container well before use. REQUIEM must be diluted with water for
spray applications. Partially fill the spray tank with clean water, add
the specified amount of REQUIEM to the tank, and finish filling the tank
to the proper volume to obtain the desired application rate per acre as
specified in the crop and pest tables listed below. Use at dilutions no
more concentrated than 2% v/v.  

Compatibility: Do not combine REQUIEM in the spray tank with other
pesticides, surfactants, adjuvants, or fertilizers if there has been no
previous experience or use of the combination to show it is physically
compatible, and non-injurious under your use conditions. 

Do not use REQUIEM in tank mixes or in a program or in rotation with
products containing captan (with REQUIEM either preceding or following
captan applications) in any crop. Use of REQUIEM with captan-containing
products may result in phytotoxicity. 

Do not use REQUIEM in tank mixture combinations or in rotation with any
product containing a label warning against using surfactants, methylated
seed oils, oils or other adjuvants. 

As with many Emulsifiable Concentrate (EC) formulations, certain
combinations can exacerbate phytotoxicity problems. Products which are
phytotoxic when used alone may be more phytotoxic when used with an EC
formulation such as REQUIEM. AgraQuest has not tested all varieties and
cultivars of all crops and potential tank-mix or rotational
combinations. 

To ensure crop safety, test REQUIEM in combination and in rotation with
other products on a small portion of the crop. Wait at least 24-72 hours
to evaluate results before applying to the entire field.  If
phytotoxicity is noted, and if it is determined that the level of
phytotoxicity will result in economic losses to the crop, do not make
the application to the crop.

To ensure physical compatibility of tank-mix combinations they must be
evaluated prior to use. When products are physically compatible, a
homogeneous solution is formed.  To determine the physical
compatibility of this product with other products, use a jar test. Using
a quart jar, add the proportionate amounts of the products to
approximately one quart of water with agitation. Add dry formulations
first, then flowables, then emulsifiable concentrates last. After
thorough mixing, allow this mixture to stand for 15 minutes. If the
mixture in the test jar remains uniform for 15 minutes, the combination
is compatible and can be used.  If separation occurs (e.g. oils float
to top, clumps of solids form, etc.), the combination is incompatible
and do not use the mixture. Once compatibility has been proven, use the
same procedure for adding required ingredients to the spray tank.

Use of Adjuvants: The use of adjuvants with REQUIEM is not required.  

Biological Control Agents: This product is compatible with the following
biological control agents: Encarsia formosa, Amblyseius fallacis,
Phytoseiulus persimilis, Orius insidiosus, Aphidius colemani, Zetzellia
mali, Neoseiulus fallacies, Typhlodromus pyri, Stethorus punctum,
lacewings, syrphid fly larvae, phytoseiid mite predators, aphid midges,
lady beetles, and other predacious mites.  Wait at least 2 hours after
application before introducing new biological agents, or spray the
evening before the day of introduction of new biological control agents.


AgraQuest is committed to the practice of sound resistance management
programs that include rotation and tank mixing with other treatments
having a variety of modes of actions.

APPLICATION

Use REQUIEM early in the pest cycle when local thresholds are reached or
before insects reach damaging levels. REQUIEM is a contact insecticide
and thorough coverage is necessary for optimum control.  Use appropriate
nozzles and nozzle configurations, along with sufficient spray volume to
achieve thorough coverage.  Rates of REQUIEM may need to increase with
increased insect populations and/or large plant canopies.  It is not
necessary to use a surfactant with REQUIEM.

REQUIEM can be applied with commonly used ground equipment. Use of
air-blast spray equipment may result in overhead exposure and requires
the use of chemical-resistant headgear.  

When using REQUIEM with a new crop, test on a small area before applying
to the entire field. Do not apply REQUIEM more than 10 times per crop
production cycle. 

PREHARVEST INTERVAL

REQUIEM can be applied up to and including the day of harvest. However,
note that the restricted entry interval (REI) is 4 hours.

SPRAY DRIFT PRECAUTIONS

Avoiding spray drift at the application site is the responsibility of
the applicator. The interaction of many equipment- and weather–related
factors determine the potential for spray drift. The applicator and the
grower/treatment coordinator are responsible for considering all of
these factors when making decisions. Where states have more stringent
regulations, they should be observed. Note: This section is advisory in
nature and does not supersede the mandatory label requirements.

All ground application equipment must be properly maintained and
calibrated using appropriate carriers.

Make ground applications when the wind velocity favors on target product
deposition (approximately 3 to 10 mph). Do not apply when wind velocity
exceeds 10 mph. Avoid applications when wind gusts approach 10 mph.

Risk of exposure to sensitive areas can be reduced by avoiding
applications when wind direction is toward the area.

Low humidity and high temperatures increase the evaporation rate of
spray droplets and therefore the likelihood of increased spray drift.
Avoid spraying during conditions of low humidity and/or high
temperature.

Do not make ground applications during temperature inversions.
Inversions are characterized by stable air and increasing temperatures
with height above the ground. Mist or fog may indicate the presence of
an inversion in humid areas. The applicator may detect the presence of
an inversion by producing smoke and observing a smoke layer near the
ground surface.

FOR USE ON THE FOLLOWING CROPS

(REQUIEM has a 0-Day PreHarvest Interval (PHI) for all crops contained
on this label. However, note that the restricted entry interval (REI) is
4 hours.)

Asparagus  

Pests and Application Rates:

Pests	REQUIEM

(qts/acre)	Remarks

Aphids

Thrips	2 - 4	Begin applications when thresholds have been reached. The
rate of REQUIEM will depend on plant size and pest pressure. Use a lower
rate for light infestation and/or small plant canopy and a higher rate
for heavy infestations and/or large plants.  



Brassica (Cole) Leafy Vegetables

Including Broccoli, Broccoli Raab, Brussels Sprouts, Cabbage, Chinese
Cabbage (Bok Choy and Napa), Cauliflower, Cavalo, Collards, Kale,
Kohlrabi, Mustard Greens, Rape Greens, and other Brassica leafy
vegetable crops.

Pests and Application Rates:

Pests	REQUIEM

(qts/acre)	Remarks

Aphids:

Cabbage aphid

Green peach aphid

Turnip aphid	2 - 4	Begin treatments when thresholds have been reached. 



Thrips



Begin applications as soon as thrips are seen in the crop. Continue
applications as needed. Thrips will seek shelter in hard-to-reach parts
of the plant. Use insecticide nozzles with sufficient water volume and
spray pressure for thorough coverage.  

Whiteflies:

Silverleaf whitefly

Apply before pests reach damaging levels. Repeat applications as needed
to maintain control. Do not wait until heavy populations have become
established.  Use the high rate when conditions are favorable for heavy
pressure.  

Leafminers

For Suppression: Begin treatments before thresholds have been reached.  



Bulb Vegetables

Including Garlic, Leek, Onion (dry bulb, green, and Welch), and Shallot
and other bulb vegetable crops.

Pests and Application Rates:

Pests	REQUIEM

(qts/acre)	Remarks

Leafminer

Maggots

Mites	1.5 - 4	Apply before pests reach damaging levels. Repeat
applications as needed to maintain control. The amount of REQUIEM per
acre will depend on plant size, leaf canopy and pest pressure. Choose
lower rates for light infestations and/or small plants and higher rates
for heavy infestations and/or larger plants. 

Thrips:

Onion thrips

Western flower thrips

Tobacco  thrips



Begin applications as soon as thrips are seen in the crop. Continue
applications as needed. Thrips will seek shelter hard-to-reach parts of
the plant. Use insecticide nozzles with sufficient water volume and
spray pressure for thorough coverage.    

Bush Berries 

Including  Blueberry, Currant, Gooseberry, Huckleberry, Elderberry, and
other bush berry crops.

Pests and Application Rates:

Pests	REQUIEM

(qts/acre)	Remarks

Aphids

Leafhoppers

Leafrollers

Loopers

Lygus Maggots

Mites

Plum curculio

Thrips

Western flower thrips	2 - 4	Apply before pests reach damaging levels.  
Repeat applications as needed to maintain control The amount of REQUIEM
per acre will depend on plant size, leaf canopy and pest pressure. 
Choose lower rates for light infestations and/or small plants and higher
rates for heavy infestations and/or larger plants.  Adjust equipment,
water volume, and spray pressure to ensure thorough coverage of infested
parts of the crop.



Cranberry

Do not apply to flooded fields.

Pests and Application Rates:

Pests	REQUIEM

(qts/acre)	Remarks

Aphids

Leafhoppers

Leafrollers

Loopers

Thrips 

Wireworms	2 - 4	Begin applications when thresholds have been reached. 
The rate of REQUIEM will depend on plant size and pest pressure.  Use a
lower rate for light infestation and/or small plant canopy and a higher
rate for heavy infestations and/or large plants.  



Cane Berries

Including Blackberry (including varieties, cultivars, and/or hybrids),
Loganberry, Raspberry, and other cane berry crops.

Pests and Application Rates:

Pests	REQUIEM

(qts/acre)	Remarks

Aphids

Leafhoppers

Leafrollers

Loopers

Sawfly

Whiteflies

Thrips

Western flower thrips	2 - 4	Apply before pests reach damaging levels.
Repeat applications as needed to maintain control. The amount of REQUIEM
per acre will depend on plant size, leaf canopy and pest pressure.
Choose lower rates for light infestations and/or small plants and higher
rates for heavy infestations and/or larger plants.  Adjust equipment,
water volume, and spray pressure to ensure thorough coverage of infested
parts of the crop.



Citrus Fruits

Including Grapefruit, Lemon, Lime, Orange, Tangerine, Citrus hybrids,
Pummelo, and other citrus fruit crops. 

Pests and Application Rates:  

Pests	REQUIEM

(qts/acre)	Remarks

Asian citrus psyllid

Lepidoptera larvae:

Avocado leafroller

Citrus peelminer

Citrus Leafminer

Cutworms

Fruit tree leafroller

Orange tortrix

Mites:

Broad mite

Citrus flat mite

Citrus bud mite

Citrus red mite

Citrus rust mite

Six-spotted spider mite

Texas citrus mite

Yuma spider mite

Two-spotted spider mite

Rust mite

Thrips:

Citrus thrips

Frankliniella spp. 

Bean thrips	2 - 4	Treat when pests appear or in accordance with local
economic thresholds. Repeat applications as needed to maintain control. 
The rate of REQUIEM will depend on tree size and pest pressure. Use a
lower rate for light infestation and/or small trees and a higher rate
for heavy infestations and/or large trees. When applying to large trees,
use higher water volumes to ensure thorough coverage. Do not exceed 2%
v/v solution.  



Scale

    

Begin applications when thresholds are reached.  Treat for scale when
crawlers are present in the spring and fall.   



Cucurbit Vegetables

Including Cucumber, Citron melon, Edible Gourds, Gherkin, Muskmelons
(including hybrids and/or cultivars of Cucumis melo), Pumpkin, Summer
and Winter Squash, Watermelon, Cantaloupe, and other cucurbit vegetable
crops. 

Use of REQUIEM in tank mixes with some products including, but not
limited to, those containing strobilurins or chlorothalonil may result
in phytotoxicity. Do not apply products containing chlorothalonil within
4 days after application of REQUIEM. Do not apply REQUIEM for 30 days
following an application of chlorothalonil.

Pests and Application Rates:

Pests	REQUIEM

(qts/acre)	Remarks

Aphids

Green peach aphid

Melon aphid

Leafminers

Mites	2 - 4	Begin treatments when thresholds have been reached. 

Thrips

Melon thrips

Western flower thrips



Begin applications as soon as thrips are seen in the crop. Continue
applications as needed. Thrips will seek shelter in hard-to-reach parts
of the plant.  Use appropriate nozzles with sufficient water volume and
spray pressure for thorough coverage.

Whiteflies:

Greenhouse whitefly

Sweetpotato whitefly

Silverleaf whitefly



Apply before pests reach damaging levels. Repeat applications as needed
to maintain control. Do not wait until heavy populations have become
established. Use the high rate when conditions are favorable for heavy
pressure. 



Figs  

Pests and Application Rates:

Pests	REQUIEM

(qts/acre)	Remarks

Mites

Navel orangeworm

Scale

Vinegar flies	2 - 4	Begin applications when thresholds have been
reached. The rate of REQUIEM will depend on plant size and pest
pressure. Use a lower rate for light infestation and/or small plant
canopy and a higher rate for heavy infestations and/or large plants.  



Globe Artichoke  

Pests and Application Rates:

Pests	REQUIEM

(qts/acre)	Remarks

Aphids

Leafhoppers

Plume moth	2 - 4	Begin applications when thresholds have been reached.
The rate of REQUIEM will depend on plant size and pest pressure. Use a
lower rate for light infestation and/or small plant canopy and a higher
rate for heavy infestations and/or large plants.  



Fruiting Vegetables 

Including Eggplant, Ground Cherry, Pepino, Pepper, Tomatillo, Tomato,
and other fruiting vegetable crops.

Pests and Application Rates:

Pests	REQUIEM

(qts/acre)	Remarks

Aphids:

Green peach aphid

Potato aphid

Leafhoppers

Mites

Tomato  pinworm	2 - 4	Begin treatments when thresholds have been
reached. 

Thrips:

Western flower thrips

Onion thrips

Chili thrips

Melon thrips

Florida flower thrips

Eastern flower thrips

Begin applications as soon as thrips are seen in the crop. Continue
applications as needed. Thrips will seek shelter in hard-to-reach parts
of the plant. Use appropriate nozzles with sufficient water volume and
spray pressure for thorough coverage.

Whiteflies:

Silverleaf whitefly

Greenhouse whitefly

Bandedwinged whitefly

Sweetpotato whitefly



Apply before pests reach damaging levels. Repeat applications as needed
to maintain control. Do not wait until heavy populations have become
established.  Use the high rate when conditions are favorable for heavy
pressure.  

Leafminers (Liriomyza spp.)

	3-4	For Suppression: Begin treatments before thresholds have been
reached.  



Grape

Do not use REQUIEM on grapes east of the Rockies. Use of REQUIEM on
grapes after fruit set can diminish waxy bloom.

Pests and Application Rates:

Pests	REQUIEM

(qts/acre)	Remarks

Leafhoppers:

Grape leafhopper

Variegated leafhopper 	2 - 4	For Suppression: Begin treatments before
thresholds have been reached.  



Grape berry moth

Western grape skeletonizer

Mealy bug

Mites:

Pacific spider mites

Willamette spider mite

Two-spotted spider mite

Begin applications when thresholds have been reached.  The rate of
REQUIEM will depend on plant size and pest pressure. Use a lower rate
for light infestation and/or small plant canopy and a higher rate for
heavy infestations and/or large plants. Adjust equipment, spray volume,
and spray pressure to ensure thorough coverage of infested parts of the
crop.  



Herbs and Spices

Including Allspice, Anise, Basil, Borage, Cardamom, Chive, Dill, Fennel
(common),  Juniper berry, Marjoram, Nutmeg, Pepper, Saffron, Sage,
Tarragon, Vanilla, and other herb and spice crops. 

Pests and Application Rates:

Pests	REQUIEM

(qts/acre)	Remarks

Aphids

Fleahoppers

Leafhoppers

Grasshoppers	2 - 4	Begin applications when thresholds have been reached.
The rate of REQUIEM will depend on plant size and pest pressure. Use a
lower rate for light infestation and/or small plant canopy and a higher
rate for heavy infestations and/or large plants.  

Leafminers (Liriomyza spp.)



For Suppression: Begin treatments before thresholds have been reached.  



Hops

Pests and Application Rates:

Pests	REQUIEM

(qts/acre)	Remarks

Mites

Aphids

	2 - 4	Begin applications when thresholds have been reached. The rate of
REQUIEM will depend on plant size and pest pressure. Use a lower rate
for light infestation and/or small plant canopy and a higher rate for
heavy infestations and/or large plants.  



Legume Vegetables (Succulent or Dried)

Including Beans, Green beans, Snap beans, Shell beans, Garbanzo beans,
Lima beans, Peas, Chick peas, Split peas, Lentils and other legume
vegetable crops.

Pests and Application Rates:

Pests	REQUIEM

(qts./acre)	Remarks

Aphids

Leafhoppers

Lygus bugs

Mites	2 – 4	Begin applications when thresholds have been reached.  The
rate of REQUIEM will depend on plant size and pest pressure. Use a lower
rate for light infestation and/or small plant canopy and a higher rate
for heavy infestations and/or large plant canopy.

Thrips:

Western Flower Thrips

Melon Thrips  

   

Begin applications as soon as thrips are seen in the crop. Continue
applications as needed. Thrips will seek shelter in hard-to-reach parts
of the plant. Use insecticide nozzles with sufficient water volume and
spray pressure for thorough coverage.

Whiteflies

Apply before pests reach damaging levels.  Repeat applications as needed
to maintain control. Do not wait until heavy populations have become
established. Use the high rate when conditions are favorable for heavy
pressure.

Leafminers (Liriomyza spp.)



For suppression: Begin treatments when leafminers are seen in the crop.
Continue applications as needed.



Mint

Pests and Application Rates:

Pests	REQUIEM

(qts/acre)	Remarks

 Mites 

 Aphids

 Thrips

	2 - 4	Begin applications when thresholds have been reached. The rate of
REQUIEM will depend on plant size and pest pressure. Use a lower rate
for light infestation and/or small plant canopy and a higher rate for
heavy infestations and/or large plants.  



Leafy Vegetables

Including Lettuce, Arugula, Celery, Spinach, Parsley, Radicchio,
Florence Fennel, Romaine, Swiss Chard, and other leafy vegetable crops. 


Pests and Application Rates:

Pests	REQUIEM

(qts/acre)	Remarks

Aphids:

Foxglove aphid

Lettuce aphid

Lettuce root aphid

Cabbage aphid

Turnip aphid

Potato aphid

Green peach aphid 

Leafhoppers

Lygus bugs

Mites (except bulb mite)

Psyllid	2 - 4	Begin treatments when thresholds have been reached. 

Thrips



Begin applications as soon as thrips are seen in the crop. Continue
applications as needed. Thrips will seek shelter in hard-to-reach parts
of the plant. Use appropriate nozzles with sufficient water volume and
spray pressure for thorough coverage.

Whiteflies:

Silverleaf whitefly

Apply before pests reach damaging levels. Repeat applications as needed
to maintain control. Do not wait until heavy populations have become
established. Use the high rate when conditions are favorable for heavy
pressure.  

Leafminers (Liriomyza spp.)

	3-4	For Suppression: Begin treatments before thresholds have been
reached.  



Olives

Pests and Application Rates:

Pests	REQUIEM

(qts/acre)	Remarks

Mites

Scale

Thrips	2 - 4	Begin applications when thresholds have been reached.  The
rate of REQUIEM will depend on plant size and pest pressure. Use a
lower rate for light infestation and/or small plant canopy and a higher
rate for heavy infestations and/or large plants. 



Okra

Pests and Application Rates:

Pests	REQUIEM

(qts/acre)	Remarks

Aphids

Leafhoppers

Mites

Tomato pinworm	2 - 4	Begin treatments when thresholds have been reached.


Thrips:

Melon thrips

Western Flower thrips

Chili thrips

Florida Flower thrips 

Begin applications as soon as thrips are seen in the crop. Continue
applications as needed. Thrips will seek shelter in hard-to-reach parts
of the plant. Use insecticide nozzles with sufficient water volume and
spray pressure for thorough coverage.   

Whiteflies

Apply before pests reach damaging levels. Repeat applications as needed
to maintain control. Do not wait until heavy populations have become
established. Use the high rate when conditions are favorable for heavy
pressure.  

Leafminers (Liriomyza spp.)

	3-4	For Suppression: Begin treatments before thresholds have been
reached.  



Leaves of Root and Tuber Vegetables

Including Carrot, Sweet Potato, Cassava, Beets, Celeriac, Radish,
Turnip, Parsnip, and other leaves of root and tuber crops.

Pests and Application Rates:

Pests	REQUIEM

(qts/acre)	Remarks

Aphids

Leafhoppers

Mites

Psylla 	2 - 4	Begin treatments when thresholds have been reached. 

Thrips



Begin applications as soon as thrips are seen in the crop. Continue
applications as needed. Thrips will seek shelter in hard-to-reach parts
of the plant. Use appropriate nozzles with sufficient water volume and
spray pressure for thorough coverage.

Whiteflies

Apply before pests reach damaging levels. Repeat applications as needed
to maintain control. Do not wait until heavy populations have become
established. Use the high rate when conditions are favorable for heavy
pressure.  

Leafminers (Liriomyza spp.)



For Suppression: Begin treatments before thresholds have been reached.  

Pome Fruits

Including Apple, Crabapple, Loquat, Mayhaw, Pear, Quince, and other pome
fruit crops. 

Pests and Application Rates:

Pests	REQUIEM

(qts/acre)	Remarks

Aphids:

Green apple aphid

Wooly apple aphid

Cotton aphid

Bean aphid

Rosy apple aphid

Spirea aphid

Green peach aphid

Mites:

Brown mite

Pear rust mite

Pear leaf blister mite

European red mite

Two-spotted spider mite

Pacific spider mite

McDaniel spider mite  

Leafhoppers

Mealy bugs

Pear psyllid

Plum curculio

Scale

Thrips	2 - 4	Begin applications when thresholds have been reached.  The
rate of REQUIEM will depend on plant size and pest pressure. Use a lower
rate for light infestation and/or small plant canopy and a higher rate
for heavy infestations and/or large plant canopy.

Codling moth 

Oriental fruit moth

Tufted apple moth Leafminers (lepidopteran):

Spotted tentiform

Western tentiform

Leafrollers:

Oblique-banded

Pandernis 

Monitor the moth flights and the infestation densities of the larval
stages. Repeat applications as necessary to maintain control.  



Root / Tuber and Corm Vegetables

Including Carrot, Potato, Sweet Potato, Cassava, Beets, Ginger,
Horseradish, Radish, Ginseng, Turnip, True Yam, and other root/tuber and
corm crops.

Pests and Application Rates:

Pests	REQUIEM

(qts/acre)	Remarks

Aphids:

Potato aphid

Green peach aphid

Leafhoppers

Mites

Psylla:

Potato psyllid	2 - 4	Begin treatments when thresholds have been reached.
 

Thrips



Begin applications as soon as thrips are seen in the crop. Continue
applications as needed. Thrips will seek shelter in hard-to-reach parts
of the plant. Use appropriate nozzles with sufficient water volume and
spray pressure for thorough coverage.

Whiteflies:

Silverleaf whitefly

Apply before pests reach damaging levels. Repeat applications as needed
to maintain control. Do not wait until heavy populations have become
established. Use the high rate when conditions are favorable for heavy
pressure.  

Leafminers (Liriomyza spp.)



For Suppression: Begin treatments before thresholds have been reached.  



Stone Fruits

Including Apricot, Cherry, Nectarine, Peach, Plum, Plumcot, Prune, and
other stone fruit crops

Pests and Application Rates:

Pests	REQUIEM

(qts/acre)	Remarks

Aphids

Cherry fruit fly

Leafhoppers

Leafminers

Mites

Plum curculio

Scale

Western cherry fruit fly Thrips	2 - 4	Begin applications when thresholds
have been reached.  The rate of REQUIEM will depend on plant size and
pest pressure. Use a lower rate for light infestation and/or small plant
canopy and a higher rate for heavy infestations and/or large plant
canopy. 

Leafrollers  

Leafminers

Peach twig borer

Monitor the moth flights and the infestation densities of the larval
stages. Repeat applications as necessary to maintain control.  

Strawberry

Pests and Application Rates:

Pests	REQUIEM

(qts/acre)	Remarks

Aphids:

Green peach aphid

Melon aphid

Potato aphid

Strawberry aphid

Leafhoppers

Lygus bug 

Mites:

Two-spotted spider mite

Carmine spider mite

Cyclamen mite

Pacific spider mite 

Thrips:

Western flower thrips	1 - 4	Begin applications when thresholds have been
reached.  The rate of REQUIEM will depend on plant size and pest
pressure. Use a lower rate for light infestation and/or small plant
canopy and a higher rate for heavy infestations and/or large plants. 

Whiteflies:

Silverleaf whitefly

Greenhouse whitefly

Strawberry whitefly

Apply before pests reach damaging levels. Repeat applications as needed
to maintain control. Do not wait until heavy populations have become
established. Use the high rate when conditions are favorable for heavy
pressure.  



Tropical Fruits

Including Avocado, Banana, Kiwi, Mango, Papaya, Plantains, Pineapple,
and other tropical fruits. 

Pests and Application Rates:

Pests	REQUIEM

(qts/acre)	Remarks

Avocado leafroller

Citrus peelminer 

Cutworms

Fruit tree leafroller

Naval orange worm 

Orange tortrix

Western tussock moth

Mites

Thrips

Scale	2 - 4	Begin applications when thresholds have been reached.  The
rate of REQUIEM will depend on plant size and pest pressure. Use a lower
rate for light infestation and/or small plant canopy and a higher rate
for heavy infestations and/or large plants. 



Tree Nuts 

Including  Almond, Beech nut, Cashew, Chestnut, Filbert, Hickory nut,
Pecan, Walnut, and other tree nut crops.

Do not use of REQUIEM in tank mixes with chlorothalonil.  Do not apply
products containing chlorothalonil within 30 days after application of
REQUIEM. Do not apply REQUIEM for 30 days following an application of
chlorothalonil.

Pests and Application Rates:

Pests	REQUIEM

(qts/acre)	Remarks

Aphids:

Walnut aphid

Dusky-veined aphid

Rosy apple aphid

Green peach aphid

Spirea aphid

Yellow aphid

Black pecan aphid

Black-margined aphid

Yellow pecan aphid

Fall webworm

Scale

Walnut husk fly 

Mites:

Brown mite

Peach silver mite

Citrus flat mite

Pacific spider mite

European  red mite

Two-spotted spider mite

Strawberry spider mite	2 - 4	Begin applications when thresholds have
been reached.  The rate of REQUIEM will depend on plant size and pest
pressure. Use a lower rate for light infestation and/or small plant
canopy and a higher rate for heavy infestations and/or large plant
canopy. 

Leafminers

Leafrollers

Peach twig borer

Pecan nut case bearer

Monitor the moth flights and the infestation densities of the larval
stages. Repeat applications as necessary to maintain control.  



STORAGE AND DISPOSAL

Do not contaminate water, food or feed by storage or disposal.

  Pesticide Storage:  Store in a cool dry place.  Avoid freezing.  

  Pesticide Disposal:  To avoid wastes, use all material in this
container by application according to label directions.  If wastes
cannot be avoided, offer remaining product to a waste disposal facility
or pesticide disposal program (often such programs are run by state or
local governments or by industry).

  Do not contaminate water when disposing of equipment washwater or
rinsate.  Pesticide wastes may be toxic.  Improper disposal of unused
pesticide, washwater or rinse water is a violation of federal law.  

  Container Disposal:  Non-refillable container.  Do not reuse or refill
this container

  Triple rinse container (or equivalent) promptly after emptying. 
Triple rinse as follows:  Empty the remaining contents into application
equipment or a mix tank and drain for 10 seconds after the flow begins
to drip. Fill the container ¼ 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. Then offer for
recycling if available, or puncture and dispose of in a sanitary
landfill or by incineration. Do not burn unless allowed by state and
local ordinances.

WARRANTY AND DISCLAIMER STATEMENT

AgraQuest warrants to those persons lawfully purchasing this product
that at the time of the first sale of this product by Seller that this
product conformed to its description and was reasonably fit for the
purposes stated on the label when used in accordance with Seller’s
directions.  Buyers and users of this product assume the risk of any use
contrary to such directions. EXCEPT AS PROVIDED ELSEWHERE IN WRITING
CONTAINING AN EXPRESS REFERENCE TO THIS WARRANTY AND LIMITATION OF
DAMAGES, SELLER MAKES NO OTHER EXPRESS OR IMPLIED WARRANTY OR GUARANTY,
INCLUDING ANY OTHER EXPRESS OR IMPLIED WARRANTY OF FITNESS OR OF
MERCHANTABILITY AND NO AGENT OF SELLER IS AUTHORIZED TO DO SO.  Except
to the extent prohibited by applicable law, AgraQuest offers this
product with the following conditions: 1) buyers and users of this
product assume the risk of any storage, handling or use contrary to
AgraQuest’s label and directions and 2) AgraQuest’s liability shall
in no case exceed the purchase price of the applicable AgraQuest
product.

REQUIEM is a registered trademark of AgraQuest.

QRD 452

(Alternate Brand Name: METRONOMETM II)

Sub-Label B:  For Greenhouse & Nursery / Commercial Use Only

METRONOMETM II

Insecticide and Acaricide

For Use on Non-Food Ornamentals (Trees, Shrubs, and Bedding plants)

Not For Residential Use

	

Active Ingredient:

ECANA Mimic*	16.75%

Other Ingredients	83.25%

Total:	100.0%

* ECANA mimic is a blend of nature-identical components that
substantially replicate the composition and activity of plant-produced
Extract of Chenopodium ambrosioides near ambrosioides (ECANA).  

KEEP OUT OF REACH OF CHILDREN

CAUTION

FIRST AID

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 eye.

Call a poison control center or doctor for further treatment advice.

In On Skin Or Clothing

	

Take off contaminated clothing.

Rinse skin immediately with plenty of water for 15-20 minutes.

Call a poison control center or doctor for further treatment advice.



HOT LINE NUMBER 



CHEMTREC (800) 424-9300 (24 hours)

Have the product container or label with you when calling a poison
control center or doctor or going for treatment.



See side/back panels for additional precautionary statements

EPA Reg No. 69592-EL	  EPA Establishment No. 69592-MEX-1

Net Contents:  1 gallon (128 fl. oz.) (3.8 L)

    		 [2.5 gallon (320 fl. oz.) (9.46 L)]

Manufactured By:

AgraQuest, Inc.

1540 Drew Avenue

Davis, California   95618

(530) 750-0150

PRECAUTIONARY STATEMENTS

HAZARD TO HUMANS AND DOMESTIC ANIMALS

CAUTION:  Causes moderate eye irritation.  Avoid contact with skin, eyes
or clothing.  Wash thoroughly with soap and water after handling and
before eating, drinking, chewing gum or using tobacco. Remove and wash
contaminated clothing before reuse.  Prolonged or frequently repeated
skin contact may cause allergic reactions in some individuals.  Wear the
appropriate Personal Protective Equipment (PPE).

PERSONAL PROTECTIVE EQUIPMENT

Applicators mixers, loaders and other handlers must wear:

Long-sleeved shirt and long pants

Chemical-resistant gloves made of any waterproof material

Shoes plus socks

Protective eyewear

Coveralls for high-pressure handwand and groundboom applicators.

For greenhouse uses, applicators and other handlers must wear a
NIOSH-approved respirator with an organic vapor (OV) cartridge or
canister with any R, P or HE filter. 

Follow the manufacturer’s instructions for cleaning/maintaining PPE.
If no such instructions for washables, use detergent and hot water. 
Keep and wash PPE separately from other laundry.

USER SAFETY RECOMMENDATIONS

Users should: 

● Remove clothing 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 product is toxic to aquatic invertebrates.  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.  

Drift and runoff may be hazardous to aquatic organisms in water adjacent
to treated areas. Do not apply when weather conditions favor drift or
runoff from treated areas. Do not apply when a rain event is expected
within 2 hours. Air blast applications must maintain a spray buffer of
15 feet from any waterbody.  See the Directions for Use for details.

DIRECTIONS FOR USE

It is a violation of Federal law to use this product in a manner
inconsistent with its labeling. 

READ THE ENTIRE LABEL.  USE STRICTLY IN ACCORDANCE WITH THE LABEL.
Failure to follow directions and precautions on this label may result in
crop injury, poor insect control, and/or illegal residues. 

	

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 State or Tribal agency responsible for
pesticide regulation.

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, greenhouses and handlers of agricultural
insecticides.  It contains requirements for training, decontamination,
notification and emergency assistance.  It also contains specific
instructions and exceptions pertaining to the statements on this label
about personal protective equipment (PPE) and restricted-entry interval.
 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) of 4 hours.

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:

Long-sleeved shirt and long pants

Chemical-resistant gloves made of any waterproof material

Shoes plus socks 

NON-AGRICULTURAL USE REQUIREMENTS

The requirements in this box apply to uses that are NOT within the scope
of the Worker Protection Standard for agricultural pesticides (40 CFR
Part 170).  The WPS applies when this product is used to produce
agricultural plants on farms, nurseries or green houses. 

Do not enter treated areas without protective clothing until spray has
dried. Refer to Personal Protective Equipment section under the
Precautionary Statements section.

GENERAL INFORMATION

METRONOMETM is an Emulsifiable Concentrate (EC) Insecticide and
Acaricide for Use on Field and Container-grown Non-Food Ornamental
Plants in Commercial Nurseries, Greenhouses, and Lath- and Shade-houses.
Not For Residential Use.

METRONOME is a contact insecticide/acaricide for use in the control of
aphids, plant-feeding mites, whiteflies, mealy bugs, leafminers, thrips,
fungus gnats, and tarnished plant bugs. METRONOME can be applied to
field and container-grown non-food ornamentals – trees, Christmas
trees, shrubs, flowers, annual and perennial bedding plants, potted
flowers, and tropical plants.

MIXING AND APPLICATION INSTRUCTIONS

Do not apply this product by aerial application or through any type of
irrigation system. 

METRONOME is toxic to aquatic invertebrates.  Users must maintain the
following buffer zones:  Airblast spray applicators must not apply
within 15 feet of aquatic habitats (such as, but not limited to, lakes,
reservoirs, rivers, streams, marshes, ponds, estuaries, and commercial
fish ponds).  Groundboom and airblast applicators must also account for
wind direction and speed.  Only apply this product if the wind direction
favors on-target deposition.  Do not apply when the wind velocity
exceeds 10 mph. Do not apply when a rain event is expected within 2
hours. 

Shake container well before use. METRONOME must be diluted with water
for spray applications. Partially fill the spray tank with clean water,
add the specified amount of METRONOME to the tank (see table below), and
finish filling the tank to the desired volume to obtain the proper spray
concentration for the desired application rate per acre.

Gallons Water per Acre	METRONOME  gallons

0.5% solution	METRONOME  gallons

1% solution

25	0.12   (16 fl oz)	0.25  (32 fl oz)

50	0.25  (32 fl oz)	0.5  (64 fl oz)

75	0.37  (48 fl oz)	0.75  (96 fl oz)

100	0.5	1

   For smaller quantities, mix at a rate of 0.65 – 1.3 fl.  oz.
METRONOME  per 1 gallon of water.



Apply on a 7- to 14-day schedule as necessary.  Apply METRONOME at first
sign of insect pressure or plant-feeding mite infestation.  Use higher
application rate under conditions of heavy pest pressure.  Uniform
coverage of both upper and lower leaves is critical for effective pest
control.  Avoid overspraying to the point of excessive runoff. Do not
apply METRONOME more than 10 times per year. 

METRONOME can be applied with commonly used ground equipment, hose-end,
pressurized, greenhouse, and hand-held sprayers. 

Biological Control Agents: This product is compatible with the following
biological control agents: Encarsia formosa, Amblyseius fallacis,
Phytoseiulus persimilis, Orius insidiosus,  Aphidius colemani, 
Zetzellia mali, Neoseiulus fallacies, Typhlodromus pyri, Stethorus
punctum,  lacewings, syrphid fly larvae, phytoseiid mite predators,
aphid midges, lady beetles, and other predacious mites.  Wait at least 2
hours after application before introducing new biological agents, or
spray the evening before the day of introduction of new biological
control agents. 

AgraQuest is committed to the practice of sound resistance management
programs that include rotation and tank mixing with other treatments
having a variety of modes of actions. 

Compatibility: Do not combine METRONOME in the spray tank with other
pesticides, surfactants, adjuvants, or fertilizers if there has been no
previous experience or use of the combination to show it is physically
compatible, and non-injurious under your use conditions. 

Do not use METRONOME in tank mixes or in a program or in rotation with
products containing captan (with METRONOME either preceding or following
captan applications) in any crop. Use of METRONOME with
captan-containing products may result in phytotoxicity. 

Do not use METRONOME in tank mixture combinations or in rotation with
any product containing a label warning against using surfactants,
methylated seed oils, oils or other adjuvants. 

As with many Emulsifiable Concentrate (EC) formulations, certain
combinations can exacerbate phytotoxicity problems. Products which are
phytotoxic when used alone may be more phytotoxic when used with an EC
formulation such as METRONOME. AgraQuest has not tested all varieties
and cultivars of all crops and potential tank-mix or rotational
combinations.

To ensure physical compatibility of tank-mix combinations they must be
evaluated prior to use. When products are physically compatible, a
homogeneous solution is formed.  To determine the physical
compatibility of this product with other products, use a jar test. Using
a quart jar, add the proportionate amounts of the products to
approximately one quart of water with agitation. Add dry formulations
first, then flowables, then emulsifiable concentrates last. After
thorough mixing, allow this mixture to stand for 15 minutes. If the
mixture in the test jar remains uniform for 15 minutes, the combination
is compatible and can be used.  If separation occurs (e.g. oils float
to top, clumps of solids form, etc.), the combination is incompatible
and do not use the mixture. Once compatibility has been proven, use the
same procedure for adding required ingredients to the spray tank. Test
the combination on a small number of plants to check for phytotoxicity
before treating large areas. Do not use the combination if adverse
effects are observed. 

PLANTS EVALUATED FOR PHYTOTOXICITY

METRONOME has been evaluated alone in a wide range of crops and
ornamentals. However, since testing on all varieties of all ornamentals
is not feasible, testing a small portion of the area to be treated for
phytotoxicity is required before treating the entire area. Further, all
possible combinations or sequences of pesticide sprays, including other
fertilizers, surfactants, adjuvants and other pesticides, have not been
tested, thus testing for compatibility and phytotoxicity of spray
mixtures is required. Use the product in accordance with all label use
directions. It is further required that spray equipment used to apply
METRONOME be thoroughly cleaned before use. 

Phytotoxicity has occasionally been observed following the use of this
product on flowers of Cyclamen, Gerbera, Begonia, and Impatiens. Do not
use METRONOME on flowering Cyclamen, Gerbera, Begonia, and Impatiens. 

STORAGE AND DISPOSAL

Do not contaminate water, food or feed by storage or disposal.

Pesticide Storage:  Store in a cool dry place.  Avoid freezing.  

Pesticide Disposal:  To avoid wastes, use all material in this container
by application according to label directions.  If wastes cannot be
avoided, offer remaining product to a waste disposal facility or
pesticide disposal program (often such programs are run by state or
local governments or by industry).

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Do not contaminate water when disposing of equipment washwater or
rinsate.  Pesticide wastes may be toxic.  Improper disposal of unused
pesticide, washwater or rinse water is a violation of federal law.  

Container Disposal:  Non-refillable container.  Do not reuse or refill
this container

Triple rinse container (or equivalent) promptly after emptying.  Triple
rinse as follows:  Empty the remaining contents into application
equipment or a mix tank and drain for 10 seconds after the flow begins
to drip.  Fill the container ¼ 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. Then offer for
recycling if available, or puncture and dispose of in a sanitary
landfill or by incineration.  Do not burn unless allowed by state and
local ordinances.

WARRANTY AND DISCLAIMER STATEMENT

AgraQuest warrants to those persons lawfully purchasing this product
that at the time of the first sale of this product by Seller that this
product conformed to its description and was reasonably fit for the
purposes stated on the label when used in accordance with Seller’s
directions.  Buyers and users of this product assume the risk of any use
contrary to such directions. EXCEPT AS PROVIDED ELSEWHERE IN WRITING
CONTAINING AN EXPRESS REFERENCE TO THIS WARRANTY AND LIMITATION OF
DAMAGES, SELLER MAKES NO OTHER EXPRESS OR IMPLIED WARRANTY OR GUARANTY,
INCLUDING ANY OTHER EXPRESS OR IMPLIED WARRANTY OF FITNESS OR OF
MERCHANTABILITY AND NO AGENT OF SELLER IS AUTHORIZED TO DO SO.  Except
to the extent prohibited by applicable law, AgraQuest offers this
product with the following conditions: 1) buyers and users of this
product assume the risk of any storage, handling or use contrary to
AgraQuest’s label and directions and 2) AgraQuest’s liability shall
in no case exceed the purchase price of the applicable AgraQuest
product.

METRONOME is a registered trademark of AgraQuest.

ECANA and ECANA Mimic                                                   
                                     Page   PAGE  1  of   NUMPAGES  59 

Biopesticides Registration Action Document							

 PAGE   

ECANA and ECANA Mimic                                                   
                                   Page   PAGE  59  of   NUMPAGES  59 

Biopesticides Registration Action Document							

 PAGE   

