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RIGHT WAY - CONSERVATION COMMISSION ---N v E TEC ASSOCIATES ECONSULTIN NGINEERSG RCIE�k 25 May 2005 MAY 3 y 2005 DEPT. OF PLANNING& Conservation Commission COMMUNITY DEVELOPMENT Board of Selectmen Board of Health Re : Railroad Vegetation Management Plan Dear Commission and Board Members : Enclosed is the 2005-2009 Massachusetts Railroad Association VegetationManagement Plan. It has been prepared in accordance with the Department of Agricultural Resources ' Rights-of-Way Management Regulations 333 CMR 11 . 00 and was approved by the Department on 17 May 2005 . The VMP is a companion document to the Yearly Operational Plan you receive each spring and describes the methods of and rationale for railroad vegetation control . Railroads participating in the VMP include : Amtrak, Bay Colony Railroad, CSX Transportation, Fore River Transportation, Housatonic Railroad, Massachusetts Bay Commuter Railroad, MBTA Commuter Rail (Purple Lines) , Massachusetts Central Railroad, New England Central Railroad, Pioneer Valley Railroad, and Providence and Worcester Railroad. Please retain this document in your files as it will remain in effect for the five-year period of 2005-2009 . Very truly yours, MASSACHUSETTS RAILROAD ASSOCIATION V V Wayne . Duffett Enc ure 46 Sawyer Street South Portland, Maine 04106 207/767-6068 FAX 207/767-7125 VEGETATION MANAGEMENT PLAN FOR: Amtrak, National Railroad Passenger Corporation Bay Colony Railroad Corporation CSX Transportation, Incorporated Fore River Transportation Corporation Housatonic Railroad Company, Incorporated Massachusetts Bay Commuter Railroad Company MBTA, Massachusetts Bay Transportation Authority Commuter Rail (Purple Lines) Massachusetts Central Railroad Corporation New England Central Railroad, Incorporated Pioneer Valley Railroad Company, Incorporated Providence and Worcester Railroad Company For railroad rights-of-way in the Commonwealth of Massachusetts 1 JANUARY 2005 - 31 DECEMBER 2009 Prepared by: Massachusetts Railroad Association THE COMMONWEALTH OF MASSACHUSETTS EXECUTIVE OFFICE OF ENVIRONMENTAL AFFAIRS 11 IV F Department of Agricultural Resources 251 Causeway Street, Suite 500,Boston, MA 02114 617-626-1700 fax 617-626-1850 www.Mass.gov/AGR MITT ROMNEY ELLEN ROY HERZFELDER Governor Secretary KERRY HEALEY DOUGLAS P.GILLESPIE Lieutenant Governor Commissioner Mr. Wayne Duffett TEC Associates 46 Sawyer Street South Portland,Maine 04116 May 17, 2005 Dear Mr. Duffett: Pursuant to 333 CMR 11.05 (5)(c)notice of approval of the Massachusetts Railroad Association, Vegetation Management Plan (VMP)as modified and recommended for approval by the attending members of the VMP Panel is hereby given.Copies of the approved VMP should be mailed to the Chief Elected Official, Board of Health and Conservation Commission of each municipality covered by the plan. This approval is subject to all the provisions of(333 CMR 11.00-all). It will remain in effect for the years 2005 through 2009, unless suspended,revoked, or modified. As a condition of this VMP approval the Massachusetts Railroad Association must contact Mr.Tim Simmons of the Massachusetts Fisheries and Wildlife to develop Best Management Practice for vegetation control of non-ballast areas. Mr. Tim Simmons can be reached at 508-792-7270 ext. 126 or at Massachusetts Fisheries and Wildlife, National Heritage&Endangered Species Program,Rte 135,Westborough,MA 01581.The Department believes that the use of herbicides which are listed on Sensitive Area Material List and applied according to label directions applied to railroad ballast areas will not impact rare or endangered species in areas in which, a railroad passes through Significant Habitat. Please be advised,any violations of the Massachusetts Pesticide Control.Act,MGL,Chapter 132 B or the Regulations promulgated thereunder,333 CMR inclusive,may subject the responsible party or parties to agency action and referral of this matter to the Office of the Attorney General,Commonwealth of Massachusetts or the local District Attorney's office for civil or criminal prosecution. Thank you for your time and efforts in this program. Si e ly, Doug ti's Gillespie Commissioner RECEIVED MAY 2 0 2005 TEC ASSOCIATES TABLE OF CONTENTS I. SUMMARY OF RAILROADS COVERED BY THIS PLAN 1 A. Railroads Operating Under This Plan 1 B. Variations From Basic Plan 1 II. INTRODUCTION 1 III. GENERAL STATEMENT OF GOALS AND OBJECTIVES ' 3 IV. INTEGRATED PEST MANAGEMENT/VEGETATION MANAGEMENT 6 V. MANAGEMENT REQUIREMENTS OF RAILROAD RIGHTS-OF-WAY 9 A. Roadbed 9 B. Bridges 10 C. Culverts 10 D. Ditches 10 E. ROW Area Adjacent to the Shoulder 10 1. Grade Level Road Crossings. 11 2. Railroad Signals and Switch Boxes 11 3. Inside Curves 11 F. Railroad Facilities 11 VI. VEGETATION MANAGEMENT TECHNIQUES 12 A. Mechanical Equipment and Techniques 12 B. Herbicide Application 13 1. Weed Control 13 Pre-emergent Herbicide Program 13 Post-emergent Herbicide Program 14 2. Brush Control 14 Foliar 14 Stem 15 Cut surface 15 Summation 15 VII. SENSITIVE AREAS 16 A. Identification and Location of Wells and Surface Water Supplies 17 B. Identification and Delineation of Wetlands 17 C. Field Procedure 20 1. Preparation 20 2. Boundary Establishment 20 3. Approval of Findings 21 D. Operational Strategies and Procedures 21 i TABLE OF CONTENTS (Continued) VIII. OPERATIONAL GUIDELINES FOR APPLICATORS RELATIVE TO HERBICIDE USE 22 A. Guidelines for Sensitive Areas 22 1. Initial Site Review 22 2. Office Procedures 23 B. Preparation for Herbicide Application 23 1. Basic Requirements 23 2. Herbicide Application 25 IX. ALTERNATIVE LAND USE 26 X. REMEDIAL PLAN TO ADDRESS SPILLS AND RELATED ACCIDENTS 26 XI. IDENTIFICATION AND QUALIFICATIONS OF INDIVIDUALS DEVELOPING THE PLAN 27 APPENDICES Appendix A Municipalities affected by this Plan, listed by railroad Appendix B Variations from Basic Plan Appendix C 333 •CMR 11.00: Right of Way Management Appendix D 310 CMR 10.00: Preface to Wetlands Regulations Appendix E Herbicides approved for use on sensitive areas of railroad ROW's as of August 2004, subject to revision. ii RAILROAD VEGETATION MANAGEMENT PLAN I . SUMMARY OF RAILROADS COVERED BY THIS PLAN A. Railroads Operating Under this Plan The railroad companies listed below have agreed to use this Vegetation Management Plan (VMP) for the next 5 years. Municipalities affected by this Plan, listed by railroad, may be found in Appendix A. Amtrak, National Railroad Passenger Corporation Bay Colony Railroad Corporation CSX Transportation, Incorporated Fore River Transportation Corporation Housatonic Railroad Company, Incorporated MBTA, Massachusetts Bay Transportation Authority Commuter Rail (Purple Lines) Massachusetts Bay Commuter Railroad Company Massachusetts Central Railroad Corporation New England Central Railroad, Incorporated Pioneer Valley Railroad Company, Incorporated Providence and Worcester Railroad Company B. Variations From Basic Plan Differences in company size and work procedures require minor variations in the basic plan. These variations occur in two areas; differences in personnel and different types of sensitive area markers. Appendix B provides details of specific variations for each railroad company. II . INTRODUCTION This VMP has been prepared for the participating railroads by the Massachusetts Railroad Association and shall apply to their rights-of- way within the Commonwealth of Massachusetts. It describes a variety of operational practices which include physical, chemical, and natural methods used to manage, control, and eradicate vegetation on railroad Rights-of-Way (ROW'S) . This VMP outlines and interprets the 5-year program for managing vegetation as per 333 CMR 11 . 00 Rights-of-Way Management dated 1 December 1993 (Appendix C) . The VMP addresses the major components of vegetation management including the rationale for the various techniques, the buffering and protection of sensitive areas, the application of Integrated Pest Management (IPM) , and an overview of the railroad ROW system. Appendices include a listing of municipalities affected by the Plan, variations from the basic Plan for each railroad, the Rights-of-Way Management Regulations 333 CMR 11 . 00, the Preface to the Wetlands Protection Regulations 310 CMR -1- 10 . 00 relative to rights-of-way management, and the most recent list of herbicides approved for use on sensitive areas of railroad ROW' s dated August 2004, subject to revision. To understand the complexities of the railroad ROW and the related problems which arise in vegetation management and interfere with the operating railroad system, detailed descriptions and illustrations of the specific areas along the railroad ROW are provided in Section V. Knowledge of the role and function of each area along the ROW is necessary to assess and understand the particular type of vegetation management practice used in those areas. The railroad ROW' s are unique in that they are owned by the various railroad corporations and are constructed as per federal and state laws, regulations, and standards for a specific purpose which benefits the public welfare. Railroad ROW' s are similar to other ROW' s in that they pass through a wide variety of both privately and publicly owned land. Railroad companie's own their ROW' s in fee, whereas electric and pipeline companies usually obtain easements which convey only specific use rights to the easement holder. The railroad ROW connects railroad facilities and can be divided into several distinct areas each of which have different uses and activities and different requirements for vegetation management. A brief historical overview will demonstrate that today' s railroad Vegetation Management Program represents great changes in the approach, techniques, and methods for vegetation management versus vegetation eradication of years past . These advances are the results of research and the progressive attitudes of the railroad companies to adopt an integrated approach to vegetation control . Herbicides have controlled unwanted vegetation on railroad roadbeds and in railroad yards since the 1950 's. These herbicides were often applied several times during the year. The rates for these pre- and post-emergent herbicides were listed as great as 100 lbs active ingredient (A. I. ) per acre. The use of herbicides, however, has steadily declined. For example, in the early 1970 ' s herbicides were applied to the areas adjacent to the roadbeds to control brush and related vegetation at rates of 25-77 lbs A.I . as per label instruction. Today, a mixture of the herbicide Roundup, used commonly for brush control, has been reduced from 6 lbs A. I . per acre in 1983 to 4 lbs A. I . per acre in current use. By 1980, the average rate of herbicides applied to railroad ROW' s had decreased to below 10 lbs A. I . per acre. Harrison (1985) reports in the Generic Environmental Impact Report on Control of Vegetation on Utility and Railroad Rights- of-Way that in 1981, the average rate of herbicide application was 8 . 15 lbs A. I. per acre for the railroad ROW. Today's herbicide label rates for the railroad ROW now averages 3 . 0 lbs A. I . per acre for the most frequently applied herbicides in Massachusetts. -2- We must understand that the 10-fold decrease in herbicide use between 1950 and today was not driven by regulation or economics, but was the combined result of new herbicides, new application techniques, the effectiveness of annual control, and concern over possible adverse effects of chemicals used in our environment. The evolution of this VMP is the direct result of an awareness of our environment, the work of trained professionals, research, development, and implementation of scientifically sound programs based on an integrated approach to vegetation control . This VMP outlines the railroad industry' s 5-year plan to manage the various parts of the railroad ROW with respect to vegetation control. This document will explain in detail the goals and objectives associated with vegetation management on the railroad ROW. The VMP represents careful planning, programming, and decision making by a team of qualified professionals so that the general welfare and safety of railroad employees and the public is ensured, and that no unreasonable effects are caused to our environment. III . GENERAL STATEMENT OF GOALS AND OBJECTIVES The purpose of this VMP is to establish the operations, procedures, and professional guidelines involved in the railroads' vegetation management program to control, eradicate, or manage vegetation which interferes with the ROW. This interference may potentially affect the safety of employees, passengers, the public, and the environment. This VMP provides the necessary information and basic operational procedures to inform municipalities, interested citizens, railroad employees, and contractors about the railroads' vegetation management program. The railroads' goals and objectives associated with vegetation management are to minimize the risk of unreasonable adverse effects on human health and the environment and to protect the safety of people making public passage on, performing work on, or living adjacent to the ROW. Vegetation on railroad rights-of-way affects railroad safety both directly and indirectly. The benefits of proper vegetation control, however, are difficult to quantify because vegetation control is one of many tools railroads use to maintain tracks in a safe condition. There are many ways that vegetation directly affects railroad, and consequently, public safety. The typical railroad roadbed consists of ballast on a graded and compacted earthwork section. The track is supported by the ballast. The earthwork section typically slopes downward to drainage ditches on each side of the track. The entire railroad roadbed and adjacent area are designed to carry water away from the tracks . The ballast is the material between and under the ties . It consists of crushed stone or gravel and is compacted around and under the ties to support them vertically and laterally. Pore space in the ballast allows water to drain away from the ties and into drainage ditches which carry it away from the track. Dirt falling from passing trains or washed or blown in can provide adequate seedbed areas for some plants. Plant seeds carried to the track area by the same mechanisms as the dirt can sprout and begin to -3- develop. During plant development, fibrous root systems appear which expand through the ballast and accumulate additional dirt. The fibrous roots of most plants are continuously dying and renewing themselves adding decaying plant material to the accumulating dirt. This mixture of dirt and plant material holds moisture and provides a seedbed for new plants . The drainage capacity of the ballast is greatly reduced and moisture is retained around the ties contributing to their decay. During rain, the fouled ballast can retain enough moisture to become saturated. This results in a loss of support for the track both vertically and laterally leading to movement under the train. In dry weather, vegetation within the roadbed is easily set on fire by sparks from steel brake shoes on steel wheels . The exhaust from diesel locomotives is another source of sparks, particularly as the throttle position is being increased or decreased. Track maintenance activities such as cutting, grinding, or welding rail are another ignition source. In order to minimize the potential for fires, the Commonwealth of Massachusetts requires by statute (Section 160 Chapter 235A) that railroads keep the full width of their rights-of-way clear of inflammable material including vegetation. An additional problem occurs with the above ground portion of plants growing near the rails . Trains depend on friction between the steel rails and steel wheels for moving and braking. Anything that reduces friction between the wheels and rails can create dangerous problems. A light rain which wets the track can double or triple minimum stopping distances required, depending on the train' s weight, speed, and the slope involved. Most plant tissues are immediately crushed between the wheel and rail, but release water and plant sap which acts as a lubricant just as rain does and may increase stopping distance by the same proportions. Vegetation also creates unsafe footing for railroad employees, particularly train crews which may be at work at any hour and in any weather. The vegetation itself may be the hazard or it may conceal objects or areas of unsafe footing. Visibility is important both for railroad personnel working on or near trains and for motorists crossing railroad tracks . Train engineers and other operating personnel must be able to see all types of railroad signals . These signals indicate the status of the traffic on the track ahead and also indicate when whistles must be sounded as the train approaches a road crossing. Signs also provide other types of safety information as well. Motorists must be able to see trains as they approach railroad crossings and employees must be able to visually inspect moving rail equipment. Locomotive engineers must be able to see around curves and see that switches and derails are in the correct position. Federal laws require vegetation control to ensure proper functioning of signals and communication lines . Trees and plants short out electrical equipment and cause failure of communication systems and signals . Vegetation on railroad rights-of-way indirectly affects railroad safety in a significant way. Vegetation itself is rarely the cause of -4- a railroad accident or incident. Every year, however, an average of 900 accidents nationwide are caused by track and roadbed defects according to Federal Railroad Administration (FRA) statistics . In 2003, the last year for which statistics were available, there were 960 railroad accidents caused by track and roadbed defects . This resulted in 22 injuries to railroad employees and $120, 664, 156 in property damage. In 2003, 221 of the 960 accidents caused by track . and roadbed defects involved trains carrying hazardous material. . In 126 of the accidents cars carrying hazardous material were damaged resulting in 11 releases of hazardous material into the, environment. For the five-year period of - 1999-2003, in the Commonwealth of Massachusetts, there were thirty train accidents caused by track and roadbed defects . Six of these accidents involved trains carrying hazardous material and in two accidents, railroad cars carrying hazardous material were damaged. There were no releases of hazardous material from the damaged cars . Of primary importance to the railroad industry is minimizing the frequency and severity of accidents and incidents . The primary method for controlling those caused by track and roadbed defects is the federally mandated weekly or twice-weekly visual inspections by a qualified track inspector. These inspections are normally done from a by-rail vehicle supplemented when necessary by walking inspections of switches and other complicated trackwork. It is essential that the railroad roadbed be kept weed free to provide the track inspector with unobstructed views of the track structure including rails, ties, and fasteners . Vegetation within the railroad roadbed increases the probability that a track or roadbed defect will go undetected resulting in greater potential for an accident or incident. For this reason, FRA regulations (CFR 49 Part 213. 37) require that vegetation be controlled so as not to interfere with the track inspector' s duties . Vegetation in the roadbed hinders other methods of track inspection as well . Railroads employ electronic . rail testing contractors to periodically test rails for internal defects. This testing is done by special rail cars that establish a magnetic field around the rail. Vegetation adjacent to the rails hinders this process and results in invalid tests . Other special rail cars measure track geometry such as surface, line, and gauge . The gauge measurement is done optically and is adversely affected by vegetation between the rails . The Federal and Massachusetts governments have recognized the importance of safety and have a variety of laws and regulations governing the condition of railroad ROW'S. Federal law requires railroads to control vegetation. Specifically 49 C.F.R. Subsection 213 .37 states: Vegetation on railroad property which is on or immediately adjacent to roadbed, must be controlled so that it does not: (a) Become a fire hazard to track carrying structures (b) Obstruct visibility of railroad signs and signals (c) Interfere with railroad employees performing normal -5- trackside duties (d) Prevent proper functioning of signal and communication lines (e) Prevent railroad employees from visually inspecting moving equipment from their normal duty stations The Massachusetts Department of Telecommunications and Energy has broad regulatory authority over railroads. Railroad Safety Regulations 220 CMR 150 .00 set forth regulations concerning track inspection, track maintenance, and track alterations. The statutory and regulatory intent is specific: the safety of the railroad must be guaranteed through inspection, maintenance, and repair of the ROW. Maintenance and inspection require proper vegetation control. Clearly the Commonwealth has intended each railroad within Massachusetts to maintain their ROW' s, which includes but is not limited to vegetation management, or be in violation of law and regulations, and subject to liability and fines. IV. INTEGRATED PEST MANAGEMENT/VEGETATION MANAGEMENT Integrated Pest Management, as performed by the railroads, involves careful planning, organizing, and implementing an overall program involving all operational departments and personnel, so that all possible techniques of vegetation control will be utilized. By identifying and coordinating the activities of other divisional and operational units such as repair, ballast replacement, construction, communication, and other ROW responsibilities, the railroad can control vegetation as an indirect benefit of their prime goal and function. Thus, unnecessary application of herbicides will be prevented. All non-chemical techniques and methods which remove or control pest vegetation will be identified and integrated into the overall VMP process and the scheduling for all Yearly Operational Plan (YOP) activities. Thus, no sector or area of the ROW will receive herbicide treatment if a routine or operational activity will remove the vegetation during the process. This operational procedure will further reduce the reliance on chemical control and the amount of herbicide applied each year. The purpose of every VMP, railroad or other, is to address the various components of vegetation management. Whenever possible and wherever consistent with the ROW system, the railroad industry will implement an integrated approach to vegetation management by encouraging plant communities which hinder the development of target vegetation. This integrated vegetation management program, utilizes physical and chemical methods to control vegetation. They address public, environmental, and economic concerns by minimizing the applications of herbicides . Due to the unique structure of the railroad ROW, different environmental areas such as road crossings and yards, require different levels of vegetation control and will be selectively -6- managed based on the site and target species . A team of professionals comprised of roadmasters, engineers of track and vegetation control, and herbicide application specialists will develop annual Yearly Operational Plans that select those vegetation control methods which minimize risk for the general public and the environment. Over the 5- year period, the railroad industry will constantly monitor and evaluate the success of their program and integrate appropriate new methods in their YOPs consistent with the VMP. Procedures to monitor and evaluate the IPM program are described in detail in Section VIII, pages 2f through 26 . Federal laws require the maintenance of vegetation located on the roadbed and certain other areas. All vegetation will be eliminated from the following areas : - Ballast section - Ballast shoulder - Yards - Switches, signals, and signs - Highway grade crossings - Bridges, bridge abutments, and buildings - Off-track areas - Inside of curves To date, no environmentally and economically feasible and safe alternatives to herbicides have been developed for use in areas of the right-of-way requiring total vegetation control . The Massachusetts Railroad Association has tested alternatives without success. These tests included a steam application which required 7, 000 gallons of potable water and several hundred gallons of diesel fuel for heating the water per mile. It resulted in partial control lasting about one week. In another test, an application of a fish by-product resulted in approximately ten percent control of target vegetation. No mechanical equipment has been developed that will operate in close proximity to the track components in the roadbed area. In 1996, Consolidated Rail Corporation built and tested a mowing machine for target vegetation growing in the roadbed and ballast. This machine was completely ineffective at removing vegetation below the top-of- rail height and fouled the ballast with clippings creating both drainage problems and a fire hazard. Finally the movement of trains, often at high speeds, would make manual weed control dangerous . As a result, the integrated approach to vegetation management in these areas is limited to the selective application of herbicides to target vegetation along with control obtained through track maintenance activity. The use of herbicides, however, continues to drop as the result of new technologies in application equipment. Spray booms are independently controlled according to left side, center, and right side allowing the operator .to shut off the application to areas lacking target vegetation. Often, target vegetation in the track center is less dense then that on the sides . To control these areas of lighter vegetation, often extending the width of the ties, "half- -7- rate" booms are being added adjacent to the "full-rate" booms and are used whenever possible. Normally, the full-rate booms are used at road crossings and around switches and special track work while the half-rate booms are used in all other areas. In another improvement, herbicide injection equipment is replacing the traditional method of tank mixing multiple herbicides. This allows the applicator to apply a specific herbicide only when that herbicide' s target vegetation is present as opposed to a tank mixed application of all herbicides to all areas . When herbicide use is needed, the type and density of vegetation, site condition, and the time of year will be factors in determining the herbicide type, application rate, adjuvants, and application equipment. These factors will be selected to attain maximum control and minimize any unreasonable adverse effects . In railroad yards and on certain heavily vegetated areas of the ROW pre- emergent herbicides will be applied which may eliminate a post- emergent treatment that same year. Each herbicide treatment will be tailored to the specifics of the site, sensitive area proximity, vegetation, and local environmental factors . The specific details will be included in each YOP. In areas, such as those adjacent to the ROW roadbed, where total vegetation control is not required, various selective vegetation control techniques are practiced. The goal and purpose of this integrated vegetation control approach will be to increase competition for light and growing space with desirable species by selectively eliminating woody species . Shrubs, grasses, and sedges are desirable species (non-target) which can be tolerated on the adjacent area and will be selectively managed. By selectively removing these target species by cutting or herbicide treatments, the non-target species will not be affected. If a target species capable of resprouting, is cut or mowed, a cut stump treatment will be applied to prevent sprouting and the need for further herbicide applications . In the above cases, the target vegetation is eliminated, and the desirable species such as grasses and sedges will rapidly grow and fill the area due to the increased sunlight, water, and nutrients. The selective elimination of woody and brush species is site, species, and density dependent. The selection of technique will also take into consideration the preservation and enhancing of non-target desirable species . In no case would a pre-emergent herbicide be used in these areas. In certain adjacent areas of the ROW, branches and limbs of trees grow into or have the potential to move into the roadbed area striking trains or fouling overhead communication lines. In these cases, the tree will not be eliminated if a selective side trimming of the encroaching limbs can be made from an aerial lift mounted on hi-rail equipment, or on a truck. Selective side trimming, primarily by mechanical and occasionally by herbicidal means, will be done on a site by site basis according to the type and density of target vegetation present and its propensity to invade the roadbed area or foul communication lines . Trees and brush on the ROW which act as a -8- buffer between the adjacent property and ROW will only be managed if they will interfere with the function and safety of the ROW. Selective vegetation management increases desirable vegetation, prevents erosion, and is aesthetically pleasing to adjacent property owners . In summation, railroad' s VMP is an integrated plant management program. The railroad' s vegetation management programs do not rely on a fixed application schedule or eliminate all vegetation with herbicides in all areas. The ROW will receive a Vegetation Site Inspection monitoring the vegetation on the roadbed and adjacent areas . All operational and divisional activities scheduled for that year will be identified for those sites. If those activities will control the vegetation on those sites, no other vegetation management activities will be contracted. On those areas, in which the vegetation will not be controlled by non-VMP activities an assessment will be performed to, determine the most selective vegetation management approach (see Operational Procedure, Section VIII) . V. MANAGEMENT REQUIREMENTS OF RAILROAD RIGHTS-OF-WAY Concern for public and employee welfare, environmental protection, and safety is the primary reason for vegetation maintenance on the railroad ROW. Railroads are unique, among the various type of ROW's in their relationship to interstate commerce. Railroads carry a constant flow of raw material and finished products into, out. of, and through the Commonwealth of Massachusetts. Railroads also provide commuter rail service and high-speed intercity passenger service on some routes. Major track segments have few alternate or duplicate routes and cannot be closed easily or for long periods of time for vegetation maintenance without major service disruptions . Vegetation maintenance must be scheduled around the normal schedule of rail traffic. Detailed planning and scheduling is required to accomplish vegetation maintenance activities within a narrow time window. This document reflects the railroads' continuing efforts to review and evaluate vegetation control practices. This effort has led to practices which allow the development of very low-growing vegetation on many areas adjacent to the shoulder (Figure l) . A. Roadbed Figure 1 depicts a typical railroad ROW. The roadbed is a man-made structure which consists of the rail and ties, ballast, ballast shoulder, and its drainage system. The ballast and ballast shoulder are constructed of hard stone which supports the track. It distributes the load on the track evenly and drains water away from the roadbed. The roadbed drainage system is constructed to carry water draining out of the ballast away from the track. The roadbed portion of the ROW requires total vegetation control . Figure 1 Railroad Areas Requiring Vegetation Control (Line of Road) 9 I(1 I Area Adjacent j Ballast i Ballast i Ballast i Area Adjacent � �e y�✓ 1 to Shoulder I Shoulder I Section I Shoulder I to Shoulder r, �J1 " L-ti 1 I I I I I I I '4 -Litt , M-1111it I I I I I I uu'' j Communication i I 3JJ I Lines I I I I C I I I I I I I I I I I I 20' Roadbed' , (in accordance I f with federal law) 1I I '.`,:i,��;lt}tyin;y.4e '.i:•:?' L.YA.IM!:;R'.: : 10, 40' 40' B. Bridges Open deck bridges, such as some over water, will not be treated. Roadbed approaches to bridges will be treated up to the abutment backwall, reduced as necessary to maintain required setbacks to sensitive areas . Stonework in bridge abutments and similar structures must be treated because plant roots can loosen and destroy mortar in cracks . The area under bridges will be maintained in low growing vegetation. C. Culverts Culverts are generally constructed with steel pipe concrete pipe, or stone and are normally placed at right angles to the track. Culverts which are not of sufficient length to extend beyond the roadbed spray pattern plus required buffer, or which are shallow to the roadbed and constructed of stone and could allow herbicide to enter a watercourse, will not be treated. D. Ditches Drainage ditches must be maintained weed-free to permit the flow of water away from the ballast and track structure and maintain a stable roadbed. Ditches will be maintained by mechanical means and by herbicide applications when no water is present. E. ROW Area Adjacent to the Shoulder Woody vegetation growing in areas adjacent to the shoulder will be managed to promote the growth of low growing shrubs. Targeted woody vegetation will be that which has the potential to block visibility or invade the roadbed and/or overhead communication lines. Target vegetation will include but not be limited to the following: Ailantus Black Walnut Honey Locust American Basswood Buckthorn Maple American Beech Butternut Northern Catalpa American Hornbeam Cherry Oak Apple Eastern Horphornbeam Pine Ash Eastern Redcedar Poplar Aspen Elm Sassafras Birch Flowering Dogwood Shadbrush Black Locust Hawthorn Spruce Black Tupelo Hickory Sumac Vines Figure 1 illustrates typical areas on the railroad ROW area adjacent to the shoulder. These areas are generally between the roadbed and the edges of the ROW on either side. Shrubs in these areas provide a visual screen blocking the view of railroad traffic and serve tb reduce the noise from rail traffic in adjacent areas. These areas may be maintained to include a wide variety of shrubs and herbaceous plants . -10- On the side of the ROW containing overhead signal and communication lines, low growing shrubs and most herbaceous plants will be maintained and encouraged in an effort to reduce the invasion of tall growing trees into these areas. Tall growing trees growing near overheard signal and communication lines must be controlled. Low growing vegetation will be encouraged in areas containing underground communication or signal lines. In areas where above ground 1^ines are present, low growing vegetation will be encouraged on the area opposite the lines . Shrubs in these areas provide a visual screen blocking the view of railroad traffic from adjacent land owners and also reduce the noise from rail traffic in the adjacent land. Vegetation on the area adjacent to the shoulder must be controlled in the following situations. 1. Grade Level Road Crossings At grade level road crossings vegetation must be controlled to provide safe lines of sight between motorists and rail traffic. 2 . Railroad Signals , Signal Cases, and Signs The area around railroad signals, signal cases, and signs will be maintained weed free providing a safe line of sight between the engineer and the signals or signs and to permit maintenance of this equipment . 3 . Inside Curves In the area adjacent to the shoulder, on the inside of curves, low growing vegetation must be maintained to allow railroad employees on the trains to inspect trains as they move around the curves. F. Railroad Facilities Railroad facilities include yards, buildings, fueling facilities, and off-track areas. Yards are areas with multiple tracks and switches where trains are assembled, disassembled, and equipment is stored. Buildings include offices, maintenance and repair buildings, and signal towers, usually within yards. Fueling areas are locations where locomotive fuel is stored and distributed. Off-track areas are locations that are not assessable from rail, such as auto-unloading sites . Railroad facilities must be maintained weed free to allow safe and efficient operation, reduce fire hazards, and permit proper inspection of railroad track. . -11- VI . VEGETATION MANAGEMENT TECHNIQUES The railroads ' Vegetation Management Program is defined and limited by the construction of the privately owned ROW. The individual components of the railroad ROW as described in Section V, have two distinctly different vegetation management requirements. On the ROW roadbed and other specialized areas, no vegetation is permitted as per Federal and Massachusetts laws and regulations. On the adjacent areas of the ROW, certain woody, vine, and brush species must be selectively managed. Therefore, unlike other ROW' s, the methods of railroad ROW management is limited to two basic vegetation control techniques and one indirect method. The two basic vegetation control techniques are herbicide applications and mechanical techniques. The indirect method includes any ROW operational activity which eliminates vegetation as a secondary benefit. . A. Mechanical Equipment and Techniques Mechanical control techniques are limited to woody and brush vegetation ,and will include only those target trees that interfere with the ROW. Mechanical techniques are used in the areas adjacent to the roadbed. Mechanical control will remove unwanted woody vegetation in areas restricted for herbicide application. As stated prior, trees and brush interfere with communication lines, reduce visibility, and intrude into the track zone. Mechanical control is a solution to these problems. Mowing is the mechanical process of cutting a woody target species with cutting heads . The cutting heads are mounted on hydraulic arms that greatly extend the lateral reach of the equipment . These machines can be mounted on off-track, on-track, or hi-rail equipment. Large machines are required for railroad application because of the wide range of conditions found on the ROW. On-track equipment has the advantage of not having to operate over rough terrain. Off-track equipment can work independently of train movement but production may be limited by the difficulty of moving over rough terrain. Off- track equipment also has the advantage of being able to operate under communication and signal lines. However, railroad safety guidelines may restrict the use of brush cutters within developed or recreational areas . Mechanical cutters, such as mowers, present certain safety problems which the railroad personnel must take into consideration. Not only is brush cutting potentially hazardous to the general public, but the laborers are at a higher risk during work. In Massachusetts, the workers compensation rate for workers using cutting techniques is approximately three times that for herbicide applicators. -12- B. Herbicide Application Herbicides are pesticides used to control unwanted vegetation. Herbicides have been extensively applied on ROW's to control vegetation because of their specificity, range of target species, degree of control, economics, and application methods . Herbicides are essential to eliminate vegetation on the ROW roadbed (the ballast/shoulder area) . There is no known mechanical method for adequate vegetation control on the ROW roadbed as required by Federal and Massachusetts laws and regulations. The ballast and shoulder must be free and clear of all vegetation. This requirement necessitates that vegetation be removed down to and including the root system. A herbicide control program can be modified into an integrated vegetation management approach depending on the area to be treated, target species, time of application, and category of herbicide. The two herbicide categories are pre-emergent herbicides, which the plant absorbs through developing roots before emerging from the ground and post-emergent herbicides, which the plant absorbs through foliage and other green portions, or through woody portions of the plant (i.e. bark, stem, roots) Target species will be divided into two categories : weeds and brush. 1. Weed Control The weed control program is designed to eliminate all vegetation located on the roadbed, around signs and signals, and in yards and other railroad facilities . Herbaceous vegetation is the primary cover type with a lesser number of shrubs and tree seedlings also present . A combination of pre- and post-emergent herbicides accomplishes the goal of complete vegetation eradication. Pre-emergent Herbicide Program: The pre-emergent herbicide program is directed primarily to the yards, and incorporates IPM to minimize the amount of herbicide used. This program is especially important with regard to employee safety because most employee activities take place within the yards. The scheduling of a main line or yard track section for a pre-emergent herbicide application will depend on a review of the previous year' s vegetation density and control efforts and an estimate of vegetation density for the upcoming season. Pre-emergent herbicide applications within the yards may be accomplished from a hi-rail spray truck. This on-track vehicle has the advantage of not having to operate over rough terrain. These hi- -13- Figure 2 Typical Spray Pattern Note: Spray can be controlled to selectively treat all portions (Ballast, Shoulder, and -Adjacent Area) or any of the•individual portions alone. I i Area Adjacent I I Area Adjacent to Shoulder I' Roadbt:d I to Shoulder I I . I Dal Iast I Dal last I Ballast Shoulder I Section I Shoulder I . i I I Nozzles (Directed I Downward) AT n I I I I 18" Maximum I ' I I I I i "'i: it :�js '+�asa'p^+rr. `•tt s s`,t•'izJsa s.,S�Sd'�j3x�:'��f5 ,,. I :�!fi•,.5��'�. •'4 :.ti?:��?•rq�i.'-:iS�Set:@.i.:i Y.ti.R.�te ie�;ea��'i" ",F S )'e.tC�+t i. I .:''?' :�l • t�: ! .th't.�n� •H,:� 4;;ti.Y••is.4' ¢ �i'±f.. ,,rte i, N.N':i'�...F`�'1/� l�'i's :ft�C� z„Y.,•',1 Roadbed t.;,ai3=r•'-r+ski •:'�i�;l' .,j�.,}t� .ivuti• J�._.....rijr7,' Y,.Y.��i.`y..•..fJl :;!fh.• '{:�+}}> ..��Jdr . .W tL atl''••:�w„t't/.:'}. ti�.�•:�j�;l�rit? :r{:�„,x4!".ir.i K.I.ri:ii.1'{�rlx111a!}�� '•L�YITS'�.l':.5 M1"'�w �y��''rrA'.ij.��'4:.�Y`. r:*M::li::... [[ q ,•.♦t• :{F',..:;,S„j':p,."��.>YN,tifl';.�,,�>'.nit:...fih,.L.45:1':i^.,: Std....:.:41)yl ..l••EmkT� �t}.''�Y',iL:yrH.iiut'i.:,�4.'.Yi:,'.,y.e . 14' 12' 10' 8' 6' 4' 2' 2' 4' 6' 8' 10' 12' 14 ' rail trucks have a rear mounted boom located approximately 18 inches above the ground (Figure 2) . Spray nozzles are equipped with a spring-loaded shut-off valve to prevent dripping when the pressure is turned off . Herbicide sprayed from hi-rail trucks is applied at low pressure between 30 and 40 PSI . Low pressure as defined by CMR 333 11.02 shall be under 60 PSI . In Massachusetts, pre-emergent herbicide applications to sites needing treatment will be climate dependent and favorable weather conditions are required. Traditionally, with favorable weather conditions, a pre-emergent treatment may begin in March. Post-emergent Herbicide Program: The post-emergent herbicide program is directed primarily toward vegetation eradication on the railroad ROW main lines and branch lines . These areas comprise the bulk of railroad' s rights-of-way and accordingly, account for the greatest proportion of herbicide use. Post-emergent herbicide application may begin in mid-May but is weather and target species dependent . All treated areas are later inspected and the effectiveness of the treatment is evaluated. If necessary, a second treatment is selectively applied to vegetated areas (see CMR 333 11. 03 (8) ) . 2 . Brush Control The brush control program is designed to control vegetation in areas adjacent to the shoulder through the selective use of post-emergent herbicides . The type of herbicide selected will depend on the species of target vegetation present. The application method will depend on the density of target vegetation and previous mechanical control methods . Shrubs and herbaceous vegetation in these areas will be maintained where possible. There are several methods for the application of post-emergent herbicides to the target vegetation. The variety of methods allow the applicator to selectively apply the herbicide directly onto the target vegetation. These applications are described below: Foliar: Selective application of the herbicide to the foliage and or stem by a variety of low-pressure mechanical spray devises. This type of application is useful on busy, high speed rail lines where the work intervals between trains are too short for slower mechanical methods. The herbicides are 'applied under low pressure (30-40 PSI) . Selective foliar application will not be used on vegetation over 12 feet in height, except for side trimming (333 CMR 11.03, (5) ) . Side trimming; -14- when done with herbicides, is the selective application of the herbicide to target portions of a tree and avoids removal of the entire tree. During side trimming operations in residential areas, the railroads will utilize low pressure herbicide application techniques and appropriate adjuvant or agents to minimize the drift of herbicides . Experience indicates minimal drift occurs, usually within 5 feet of side trimming operations, when using low pressure applications and adjuvants. Stem: Selective application of the herbicide in a petroleum or.crop oil base carrier to the lower portion of the main stem (trunk of a tree) . The equipment for basal spraying is often a manual-pump apparatus. Cut surface: Application of a herbicide to the stump immediately after a cutting procedure which may include mowing. Traditionally, the herbicide is manually painted or squirted directly onto the cut stump surface. Summation: Post-emergent herbicides applied to control woody vegetation in the adjacent areas will begin mid-May and may continue throughout the year on selective sections of the ROW as part of the railroads vegetation control program. Stem and cut surface treatments are effective year round. As in weed control, all treated areas are later inspected and evaluated. If further treatment is needed, a post-emergent herbicide is selectively applied to unwanted vegetation. Every consideration will be taken to minimize herbicide use while guaranteeing the overall safety of the ROW system. The beneficial effects of herbicide applications on the ROW system cannot be overlooked for several reasons . The registration of herbicides specifically labeled for use on ROW's by the EPA and Commonwealth of Massachusetts based on risk analysis is further support for their continued use. When applied by a Massachusetts certified applicator (in the category Right-of-Way Pest Control) according to label direction and in accordance with all Federal and State laws and regulations including an approved VMP and YOP, a herbicide selected from the Department of Agricultural Resources (DAR) /Department of Environmental Protection (DEP) recommended list is expected to have no unreasonable adverse effects to the general public and the environment. Many mechanical techniques present real danger and risk to both the general public and workers. As stated before, no adequate mechanical method is available for controlling vegetation found on the ROW roadbed and other areas which must be kept free of all vegetation. Public and employee safety begins with the Federal and state mandated requirements to visually inspect the entire ROW system. Herbicides provide the most reliable and generally safe -15- method to prevent and remove weeds which inhibit said inspections. Worker safety statistics demonstrate that significantly more workers will be injured or killed when using manual or mechanical cutting instead of herbicides . Mechanical cutting also results in property damage to abutters caused by flying limbs and debris. Since herbicides are available in a wide variety of dry and liquid forms, the railroad may select the most efficacious herbicide for that particular site and target vegetation. Thus, the target plant may be selectively eradicated while minimizing impact$ on non-target, desirable species. Limited, selective application of herbicides minimizes the chance of unreasonable adverse effects to the general public and the environment. The applicator controls the pressure, selects the proper nozzle, and has absolute control at which speed the vehicle will travel the ROW. The applicator is constantly monitoring the environment . If the weather conditions change, such as high wind, rain, temperature inversion, etc. , the applicator will stop immediately. Massachusetts Regulation 333 CMR 10.14 requires the applicator to keep daily records of herbicide spraying operations . The records include herbicide/adjuvant mixture components and proportions, equipment, rate of application, the exact location of treated and non-treated track and adjacent areas, date of application, trade name of product and EPA registration number, applicator name, and target pest . In . summation, highly trained licensed professional applicators, assisted by on-site railroad personnel, will apply herbicides chosen from the state recommended list [CMR 333 11. 04 (1) (d) as applicable] specific for the target vegetation and site. By using state-of-the- art equipment and specific adjuvants, the applicator will efficiently and economically manage the vegetation on the ROW. VII. SENSITIVE AREAS Sensitive areas have been defined in the Commonwealth of Massachusetts Regulation 333 CMR 11. 00 . A copy of the regulations is included in Appendix C. Sensitive areas include any areas within the ROW including, but not limited to, the following areas : . a. Within the primary recharge area of a public drinking water supply well b. Within four hundred (400) feet of any surface water used as a public water supply C. Within one hundred (100) feet of any appropriately marked private drinking water supply well d. Within one hundred (100) feet of any standing or flowing water e. Within one hundred (100) feet of any wetland -16- f. within one hundred (100) feet of any agricultural or inhabitated area The most common types of sensitive areas encountered are areas within 100 feet of standing or flowing water or wetlands. Those sensitive areas that have been delineated with permanent markers in the field are a, b, c, d, and e above. Agricultural areas, inhabited areas, and areas of intermittent standing or flowing water such as in drainage ditches, are considered readily identifiable in the field and are not delineated with permanent markers . Within "sensitive areas" only a limited number of herbicides that have been approved for these areas by DAR and DEP can be applied. The current list of sensitive area approved herbicides is provided in Appendix E. Additionally, no herbicides, including those of which are approved for sensitive areas, can be applied within 10 feet of standing or flowing water. A. Identification and Location of Wells and Surface Water. Supplies The Commonwealth of Massachusetts, Department of Environmental Protection, Drinking Water Program has developed data and overlay maps highlighting public water supplies, aquifers and drainage basins for most of the State. Areas not covered are clearly identified. Local sources of specific information included the Conservation Commission, Water Department and Board of Health. Private wells on record with the DAR will be delineated. This information is provided to the railroad through DAR or other State agencies . Prior to field delineations topographic maps were marked identifying the locations of public wells and water supplies . The specific locations were obtained from overlay maps provided by the DEP and the Division of Water Supply. Public water supplies were marked using the symbol and number codes developed by the Division. B. Identification and Delineation of Wetlands The .following definition and description is from the Wetlands Protection Act Regulations 310 CRM 10 . 55 (2) : Definition, Critical Characteristics and Boundary 1 . Bordering Vegetated Wetlands are freshwater wetlands which border on creeks, rivers, streams, ponds, and lakes. The types of freshwater wetlands are wet meadows, marshes, swamps and bogs . Bordering Vegetated Wetlands are areas where the soils are saturated and/or inundated such that they support a predominance of wetland indicator plants . The ground and surface water regime and the vegetational community which occur in each type of fresh water wetland are specific in M.G.L. c. 131, S. 40. -17- 2 . The physical characteristics of Bordering Vegetated Wetlands, as described in 310 CMR 10. 55 (2) (a) , are critical to the protection of the interests specified in 310 CMR 10 . 55 (1) . 3 . The boundary of Bordering Vegetated Wetlands is the line within which 50% or more of the vegetational community consists of wetland indicator plants and saturated or inundated conditions exist. Wetland indicator plants shall include but not necessarily be limited to those plant species identified in the Act. Wetland indicator plants are also those classified in the indicator categories of Facultative, Facultative+, Facultative Wetland-, Facultative Wetland, Facultative Wetland+, or Obligate Wetland in the National List of Plant Species That Occur in Wetlands : Massachusetts (Fish & Wildlife Service, U. S . Department of the Interior, 1988) or plants exhibiting physiological or morphological adaptations to life in saturated or inundated conditions . 9 . Areas containing a predominance of wetland indicator plants are presumed to indicate the presence of saturated or inundated conditions . Therefore, the boundary as determined by 50% or more wetland indicator plants shall be presumed accurate when: a. all dominant species have an indicator status of obligate, facultative wetland+, facultative wetland, or facultative wetland- and the slope is distinct or abrupt between the upland plant community and the wetland plant community; b. the area where the work will occur is clearly limited to the buffer zone; or C. the issuing authority determines that sole reliance on wetland indicator plants will yield an accurate delineation. 5. When the boundary is not presumed accurate as described in 310 CMR 10 . 55 (2) (c) l .a. through c. or to overcome the presumption, credible evidence shall be. submitted by a competent source demonstrating that the boundary of Bordering Vegetated Wetlands is the line within which 50% or more of the vegetational community consists of wetland indicator plants and saturated or inundated conditions exist. The issuing authority must evaluate vegetation and indicators of saturated or inundated conditions if submitted by a credible source, or may require credible evidence of saturated or inundated conditions when determining the boundary. Indicators of saturated or inundated conditions sufficient to support wetland indicator plants shall include one or more of the following: a. groundwater, including the capillary fringe, within a major portion of the root zone; b. observation of prolonged or frequent flowing or standing surface water; C. characteristics of hydric soils. -18- 6. Where an area has been disturbed (e.g. by cutting, filling, or cultivation) , the boundary is the line within which there are indicators of saturated or inundated conditions sufficient to support a predominance of wetland indicator plants, a predominance of wetland indicator plants, or credible evidence from a competent source that the area supported or would support under undisturbed conditions a predominance of wetland indicator plants prior to the disturbance. The following field guides are valuable resources providing lists and descriptions of wetland plants in Massachusetts and the surrounding region. Helpful field guides include: - Field Guide to Wetland Plant Identification - Freshwater Wetlands: A Guide to Common Indicator Plants of the Northeast - Inland Wetland Plants of Connecticut - Massachusetts Wetlands Protection Act (MGL C.131 .s.40) - Guide to Inland vegetated Wetlands in Massachusetts - US EPA New England Plant Identification and Protection Laws - Wetland Plants of the State of Massachusetts Small wetlands, variable wetland situations, and the specific boundary to any wetland must be determined in the field. The wetland maps listed below provide a general guide to the location of wetlands . - US Fish & Wildlife Service National Wetlands Inventory Maps (scales of 1 :24, 000 and 1 :25, 000) ; available from the University of Massachusetts/Amherst, Cartographic Information Research Services . - DEP Wetlands Restriction Maps (scale usually 1 :1, 000) ; about 150 of the state has been mapped; contact the Division of Wetlands and waterways to request maps. - US Soil Conservation Service Maps (scales vary) ; available for most communities: note mulch and peat soils. - US Geological Survey Topographic Maps (scale of 1:25, 000) ; shows major wetland areas; older maps useful for locating small streams; historical flood records also available. McConnell Land-Use Maps, available from the University of Massachusetts/Amherst, Department of Forestry and Wildlife Management; delineates wetlands using aerial photos (scale 1 :25, 000) and quantifies wetland acreage from years 1951, 1971, and, for part of the state, as recently as 1990 . (Caution: some forested swamps not included in wetland classification. ) - Regional Planning Agencies ' 208 Water Quality Survey wetlands -19- maps (scales vary) ; not all planning agencies have copies . - US Army Corps of Engineers wetlands maps (scales vary) ; usually done for a specific program such as Natural Valley Flood Storage Project; historical flood elevation records also available. - Federal Emergency Management Agency (formerly under the U.S. Department of Housing and Urban Development) has delineated 100- year and 500-year floodplain elevations for most of the communities in the Commonwealth (scale 1°-400 ' ) ; small streams often omitted; towns should request more detailed mapping if many flood-prone areas are excluded or if no map ,is yet available. Although the 100-year floodplain boundary rarely coincides with the vegetated wetland boundaries, these wetlands frequently occur within the 100-year floodplain. C. Field Procedure 1. Preparation Prior to doing the field work, appropriate field maps will be consulted to determine the general location of sensitive areas on the railroad ROW. 2 . Boundary Establishment The sensitive area boundaries which are not readily identifiable in the field will be established for these areas . All boundaries use minimum setback distances specified in the regulations. Boundaries are marked on the tracks using the marking system described in Appendix B for each railroad. Boundary markers are placed on the track at a point where the sensitive area intersects with the track plus the required setback distance. In most locations the boundary marker was placed as much as 15 feet beyond the minimum in order to find the best, strongest, and most visible location for the marker. The occurrence of standing water in man-made drainage ditches will not be used as a principal indication of wetlands . The four major indications are vegetation, topography, soils, and hydrology. (Hydrology of a site relates to the distribution and circulation of water on the surface and in the soil) . Vegetation and signs of obvious hydrology will be used to determine wetland boundaries according to the DEP Wetland Protection Act Regulations. Soils are helpful in verifying wetland boundaries, but will not be used as a determining factor in typical situations . Vegetation responds quickly to changes in soil moisture and drainage. Plants are more likely to indicate newly forming wetlands, or wetlands that are in the process of enlarging. Soils are useful as indications of long-term hydrologic conditions . They are especially useful for -20- disturbed sites and drier wetlands lacking typical wetland plants . Topographic depressions where water collects, or where the water table is close to the surface, usually allow the development of wetlands. The boundary of a wetland in a low, flat area surrounded by hilly terrain often corresponds to the "break" in the slope, or the point at which the land begins to flatten. Once the boundary of a wetland has been established distances will be measured to establish appropriate no-spray and buffer zones . Permanent boundary markers will be installed along the ROW and color coded in order to indicate the proper spray status of the area to the herbicide applicator. 3 . Aonroval of Findings The Conservation Commission of each municipality was given the opportunity to observe and inspect the wetland boundary markers . A request for a determination of applicability was filed with each conservation commission pursuant to the Wetland Protection Act regulations, 310 CM 10 . 05 (3)a.2 . Form 1 was accompanied by a map of the ROW indicating the location of the boundary markers on the track and type of delineation which was made. These determinations are effective for the duration of the VMP as specified in 310 CMR 10 . 05 (3) (b) (1) . Data relating to the following is submitted to the Conservation Commission in each town as part of the Yearly Operational Plan. - Maps, or updates thereof, locating the ROW and sensitive areas not readily identifiable in the field. - Herbicides proposed including application rates, carriers, adjuvants - Herbicide application techniques and alternative control procedures proposed - The company which will perform any herbicide treatment - Identification of target vegetation - Individual 'representing applicant supervising YOP - Flagging methods to designate sensitive areas on the ROW - Herbicide Fact Sheets as approved by the Department - Procedures and locations for handling, mixing, and loading of herbicide concentrates . D. Operational Strategies and Procedures Vegetation control procedures within the railroad ROW will be made consistent with all state and Federal regulations . .The general vegetation control strategies will exclude the use of -21- herbicides in any application which would result in drift to: 1. Any area within 10 feet of a wetland. 2 . Any area within 10 feet of standing or flowing water. 3 . Any area within 400 feet of a public drinking water supply well . 4 . Any area within 100 feet of any surface water used as a public water supply. 5 .• Any area within 50 feet of a private drinking water well marked in accordance with 333 CMR 11 . 04 (2) (c) (3) . On the railroad roadbed no suitable alternative . to herbicide vegetation control is currently available. On all other areas mechanical methods will be the initial treatment. In the years following mechanical vegetation control, herbicide treatments may be used to control target vegetation regrowth. The selection of the herbicide and method of application will depend on the type and density of target vegetation present . In the area adjacent to the shoulder where herbaceous and some low-growing, woody plants can be encouraged, selective cutting of tall-growing trees will be used as needed. All notification procedures required by State regulations will be followed. Several days prior to scheduled maintenance activities, a railroad track inspector or other person familiar with the boundary marking system, and equipped with boundary maps and/or log sheets, will review the area scheduled for treatment to ensure all boundary markers are in place and visible. All herbicide applicators working on the ROW will be accompanied by a railroad representative, equipped with the maps of the ROW and other required documents, and trained to observe the boundary markers and areas not readily identifiable in the field. A railroad company pilot vehicle will proceed approximately 1/4 mile ahead of the spray vehicle to alert the spray vehicle to the presence of persons on or adjacent to the ROW or any other pertinent conditions. The railroad representative may ride in the pilot vehicle or the spray vehicle in order to best suit operating conditions . When moving into or out of no-spray areas, the worker in control of the spray vehicle, will be signaled by the railroad representative or by the pilot vehicle, to cease or commence spraying. VIII. OPERATIONAL GUIDELINES FOR APPLICATORS RELATIVE TO HERBICIDE USE A. Guidelines for Sensitive Areas 1 . Site Review On sites believed to need vegetation control a review of the -22- vegetation conditions will be made. The review will be made by the track inspector or other person experienced in vegetation management. On the areas adjacent to the shoulder, the need for and type of control will be identified and the treatment required will be determined. The density and type of target species present will be noted in each area for use in developing a control strategy. 2 . Office Procedures All available information will be analyzed in the following way. Areas scheduled for construction or other activity that will relate to or eliminate the need for vegetation maintenance at that time will g , be identified. If the vegetation on these areas will be controlled or eliminated, they will be removed from further consideration in the program now being developed. Next, the sensitive areas delineated will be reviewed to ensure that appropriate measures have been taken to protect these areas. The treatment methods prescribed in each sensitive area buffer zone will be reviewed and, whenever possible, a mechanical or more selective herbicide application prescribed. No- spray areas will be reviewed as to the overall vegetation conditions occurring, and mechanical methods will be used to selectively remove or side trim trees leaning into the roadbed area. New and developing vegetation control techniques will be reviewed to determine whether or not a suitable alternative to herbicide applications has been developed for use on the roadbed in sensitive areas. This analysis will provide the site specific information required in the YOP. The YOP will be developed and submitted to DAR for approval as per 333 CMR 11. 06 (1) . B. Preparation for Herbicide Application At least a 21-day notice prior to the scheduled application date, will be given to the Conservation Commission, Board of Health, and Mayor of each community following Massachusetts State regulations. Prior to the scheduled application . date, a qualified railroad employee will traverse the treatment area with the sensitive area maps and record to ensure that all boundary markers are in place and visible. 1. Basic Reguirements To protect the public welfare and eliminate adverse impacts on the environment, railroad herbicide application crews must have an operator who is licensed and certified in the Commonwealth of Massachusetts . Applicators must also have a licensed and certified Field Supervisor who reports daily to the railroad representative or other qualified railroad employee who is assigned to this task. The -23- railroad is responsible for adherence to this VMP by railroad employees or their contractor. Applicators must follow all railroad safety regulations and all herbicide label directions. a. Daily Field Report of Vegetation Control Activities The daily field report of Vegetation control activities will be filled out each day by operators doing the work. The daily field report will include, but not be limited to: - Date - Vehicle and Equipment Numbers - Track Name, Number, and Designation - Chemical Received - From - Chemical Name - Number of Containers - Quantity lbs. /gals. - Chemical Left or Forwarded - To - Vehicle Number - Number of Containers - Quantity lbs. /gals. - Weather - Wind Velocity at time Gam 9am 12noon 3pm 6pm - Wind direction at time 6am 9am 12noon 3pm 6pm - Temperature at time 6am 9am 12noon 3pm 6pm - Rain (in inches) at time Gam 9am 12noon 3pm 6pm - Acres Treated - Roadbed Area - Area Adjacent to the Shoulder - Mainline - Sidings - Branch - Industrial Track - Bridge - Crossings - Daily Summary - Beginning Time - Ending Time - Hours Treating - Total Hours Reported - Daily Beginning Odometer Reading - Daily Ending odometer Reading -24- - Contractor Person on Job (list each individual) - Railroad Person on Job (list each individual) - Daily Summary of Chemicals Applied - Name - EPA Establishment No. - EPA Registration No. - Concentrate: gals/lbs . Mix Rate and Application Rate per Acre Tank or Mix Number Chemical Name and Amount Added to Tank Water in Gallons or Inches of Depth - Adjustments Names and Amount Location Where Water Taken b. Herbicide Application Loa In addition to a daily Field Report, a Herbicide Application Log will be filled out , the herbicide log will include, but not be limited to: - Time - Mile Post and Location - Spray Type and Meter Reading - Gallons Per Mile - Remarks : Spray Plan, City, Vegetation, Weather, etc. 2 . Herbicide Application The applicator will not handle, mix or load herbicide concentrate on a ROW within 100 feet of a sensitive area. Whenever possible, the applicator will handle, mix, or load herbicide while parked on a non- porous surface such as concrete or asphalt, but not within 100 feet of a sensitive area. At the time of treatment, before the application begins, the herbicide applicator will review the sensitive areas, maps, and records with a qualified railroad employee. A pilot vehicle will proceed through the area approximately 1/, mile ahead of the spray vehicle to alert the spray vehicle of the presence of persons on or adjacent to the ROW or any other pertinent conditions . The railroad representative will alert the operator of the spray vehicle about the location of boundary markers or sensitive areas readily identifiable in the field so that the application can be regulated accordingly. In no-spray areas, as the applicator passes the boundary, he will verify that no herbicide is deposited in the area with the assistance of another employee. -25- Water for mixing of herbicide will be obtained from ponds or streams using DEP approved anti-siphon devices or from public water supplies in accordance with 333 CMR 13 . 03 (15) . IX. ALTERNATIVE LAND USE The railroad will review and evaluate new and innovative alternative land uses on the ROW. Safety considerations preclude most alternative land uses on the railroad ROW. The size, weight, and speed of trains and their cargoes being transported are hazardous to any activity inside the ROW boundary. Even agricultural activities might interfere with the operation of the railroad by reducing visibility to inspect trains and impeding drainage away from the ballast area. Some uses of the ROW that are compatible with railroad uses include construction and maintenance of electric distribution and transmission lines, telephone lines, and cable TV lines . Other uses that may be used on wider railroad ROW's are sewer and water lines and major pipelines. Parties interested may submit alternative land use proposals for the railroad' s consideration. - A list of addresses for railroads participating in this plan maybe found in Appendix B. X. REMEDIAL PLAN TO ADDRESS SPILLS AND RELATED ACCIDENTS This remedial plan is offered as a guide to proper procedures for addressing pesticide accidents . Since every incident is different, applicators must weigh factors specific to the situation and use their own judgment to decide the appropriate course of action. Because applicators normally carry only small amounts of herbicides, the potential for serious accidents is relatively small. Federal and state statutes establish emergency response procedures that must be followed by the companies and their contractors in the event of a spill or related accident. Under the Federal Environmental Pesticide Control Act, it is the applicator' s legal responsibility to clean up pesticide spills resulting from their use and handling of the product. Applicators are liable for damages, subject to penalties, and obligated to clean up and decontaminate areas resulting from pesticide spills . The Comprehensive Environmental Response, Compensation, and Liability Act 1980 (CERCLA) 42 U. S.C. §9601 et. seq. , and the Federal Water Pollution Control Act (CWA) 33 U.S .C. §125 et. seq. are aimed at eliminating the accidental discharge of oil and hazardous substances into the environment, providing for the cleanup of such substances, and establishing responsibility for costs of cleanup. CERCLA and CWA are implemented by the National Oil and Hazardous Substances Pollution Contingency Plan (NCP) 40 CFR §300 et. seq. -26- Massachusetts General Laws Chapter 21E, the Massachusetts Oil and Hazardous Material Release Prevention and Response Act, Section 3 authorizes the Massachusetts Department of Environmental Protection (DEP) to act to secure the benefits of the CWA and CERCLA to the Commonwealth by promulgating and enforcing a Massachusetts Contingency Plan, 310 CMR 40. 000, establishes standards and procedures for the discovery of discharges, notification of DEP, assessment of the problem, and implementation of appropriate remedial response actions, as set forth in 310 CMR 40. 500. The Farm Chemical Handbook (published by Meister Publishing Co. , Willoughby, Ohio) , U. S. Department of Transportation "1987 Emergency Response Guidebook" (available from UNZ and Company, Jersey City, New Jersey) , herbicide labels, and material safety data sheets provide reference information for the chemicals being used. Applicators should carry equipment for emergency action including sand or other absorptive material, broom, shovel, and heavy duty plastic bags or other leak-proof sealable container. XI . IDENTIFICATION AND QUALIFICATIONS OF INDIVIDUALS DEVELOPING THE PLAN This 2005-2009 edition of the Vegetation Management Plan was edited and updated by Mr. Wayne Duffett, President and Co-owner of TEC Associates, a civil engineering firm located in South Portland, Maine. Mr. Duffett has a B.S. in civil engineering and is a registered professional engineer in Maine, Connecticut, New York, and Pennsylvania. He has sixteen years of experience with the Massachusetts Rights-of-Way Management regulations and assists ten railroads with their implementation and adherence. He also serves as chair of the Massachusetts Railroad Association' s Maintenance-of-Way Committee . This Vegetation Management Plan was originally written for Conrail in 1989 by Environmental Consultants, Inc. (ECI) . Mr. Paul A. Johnston was the Project Manager. Mr. Johnston has a B.S. in Forest Resources Management and a M.S. in Silviculture from West Virginia University. Mr. Frank DeVilbiss, Engineer of Vegetation Control for Conrail, assisted Mr. Johnston with preparation of the Plan. Mr. DeVilbiss has a B.S. in Forestry from Pennsylvania State University and has over twenty years of experience in all aspects of vegetation management. With approval from the Department of Agricultural Resources, the Vegetation Management Plan was subsequently adopted for use by other members of the Massachusetts Railroad Association (MRA) including: Amtrak, Bay Colony Railroad, CSX Transportation, Fore River Transportation, Housatonic Railroad, Massachusetts Bay Commuter Railroad, Massachusetts Bay Transportation Authority (Commuter Rail) , Massachusetts Central Railroad, New England Central Railroad, Pioneer Valley Railroad, and the Providence and Worcester Railroad. -27- APPENDIX A MUNICIPALITIES AFFECTED BY THIS PLAN LISTED BY RAILROAD MUNICIPALITIES COVERED BY THIS PLAN LISTED BY RAILROAD AMTRAK Attleborough Dedham Mansfield Westwood Boston Foxborough Sharon Canton Longmeadow Springfield CSX Transportation ' Ashland Dalton Leominster Oxford Warren Attleboro Dedham Mansfield Palmer Washington Auburn E. Brookfield Marlborough Pittsfield Wellesley Becket Everett Medfield Raynham W. Brookfield Berkley Fall River Middleborough Richmond W. Springfield Berlin Fitchburg Middlefield Russell W. Stockbridge Bolton Foxborough Millbury Seekonk Westborough Boston Framingham Monson Sherborn Westfield Brimfield Freetown Montgomery Somerville Weston Brookfield Grafton Natick Southborough Westwood Brookline Hinsdale New Bedford Spencer Wilbraham Cambridge Huntington Newton Springfield Worcester Charlton Lakeville Northborough Sterling Chester Lancaster Norton Taunton Clinton Leicester Norwood Walpole PROVIDENCE AND WORCESTER RAILROAD Auburn Grafton Millville Seekonk Worcester Blackstone Holden Northbridge Sutton Dudley Hubbardston Oxford Uxbridge Gardner Millbury Princeton Webster MASSACHUSETTS CENTRAL RAILROAD Barre Hardwick New Braintree Palmer Ware BAY COLONY RAILROAD Barnstable Dover Millis Rochester Wareham Bourne Falmouth Needham - Sandwich Westport Dartmouth Medfield New Bedford Taunton Yarmouth Dennis Middleborough Newton PIONEER VALLEY RAILROAD Holyoke W. Springfield Westfield FORE RIVER TRANSPORTATION Braintree Quincy NEW ENGLAND CENTRAL RAILROAD Amherst Erving Monson Northfield Sunderland Belchertown Leverett Montague Palmer - HOUSATONIC RAILROAD Great Barrington Lenox Sheffield Stockbridge Lee Pittsfield MASSACHUSETTS BAY COMMUTER RAILROAD (META Purple Lines) Abington Concord Leominster Plymouth Waltham Acton Dedham Lincoln Plympton Wenham Andover E. Bridgewater Littleton Quincy W. Bridgewater Attleboro Easton Lowell Randolph Weston Avon Everett Lunenburg Reading Westwood Ayer Fitchburg Lynn Revere Weymouth Bellingham Franklin Malden Rockport Whitman Belmont Gloucester Manchester Rowley Wilmington Beverly Halifax Medford Salem Winchester Billerica Hamilton Melrose Salisbury Woburn Boston Hanson Middleborough Saugus Boxborough Haverhill Milford Scituate Braintree Hingham Milton Shirley Bridgewater Holbrook Needham Somerville Brockton Hopedale Newbury Stoughton Cambridge Ipswich Newburyport Swampscott Canton Kingston Norfolk Tewksbury Chelsea Lakeville North Andover Wakefield Cohasset Lawrence Norwood Walpole APPENDIX B VARIATIONS FROM BASIC PLAN 1 . Personnel 2 . Sensitive Area Markers 1 . CONTACT PERSON FOR PARTICIPATING RAILROADS 1. MR. CONRAD RUPPERT AMTRAK NATIONAL RAILROAD PASSENGER CORPORATION 2 SOUTH STATION, 2ND FLOOR BOSTON, MA 02110 2 . MR. WAYNE DUFFETT BAY COLONY RAILROAD CORPORATION 420 WASHINGTON STREET BRAINTREE, MA 02184 3 . MR. MICHAEL McMASTER CSX TRANSPORTATION, INC. 4901 BELLFORT ROAD JACKSONVILLE, FL 32256 4 . MR. PAUL RUSCIO FORE RIVER TRANSPORTATION 145 EAST HOWARD STREET QUINCY, MA 02169 5 . MR. MATTHEW BOARDMAN HOUSATONIC RAILROAD COMPANY, INC. P .O. BOX 1146 CANAAN, CT 06018 6 . MR. ROBERT JOHNSON MASSACHUSETTS BAY COMMUTER RAILROAD 32 COBBLE HILL ROAD SOMERVILLE, MA 02143 7 . MASSACHUSETTS BAY TRANSPORTATION AUTHORITY (PURPLE LINES) 500 ARBORWAY JAMAICA PLAIN, MA 02130 8 . MR. PHIL RANDALL MASSACHUSETTS CENTRAL RAILROAD CORP. P.O. BOX 1099 GENEVA, NY 14456 9 . MR. MICHAEL LAWLER NEW ENGLAND CENTRAL RAILROAD TWO FEDERAL STREET ST. ALBANS, VT 05478 10 . MR. LARRY BATES PIONEER VALLEY RAILROAD P .O. BOX 995 ONE DEPOT STREET WESTFIELD, MA 01086 11 . MR. TOM LEWIS PROVIDENCE & WORCESTER RAILROAD COMPANY 75 HAMMOND STREET WORCESTER, MA 01610 2 . SENSITIVE AREA MARKERS Sensitive area markers presently in use may be one or any combination of the following: a. Plates : Color coded metal plates nailed to the railroad ties b. Paint„: Paint applied to the web or base of the rails and ties C . Posts : Color coded posts adjacent to the track Sensitive area markers presently employed by participating railroads are as follows : Amtrak: paint Bay Colony Railroad: plates CSX Transportation: plates Fore River Transportation: plates Housatonic Railroad: plates Massachusetts Bay Commuter Railroad (MBTA Purple Lines) : paint Massachusetts Central Railroad: plates New England Central Railroad: plates and/or paint Pioneer Valley Railroad: plates Providence & Worcester Railroad: plates Additional details concerning sensitive area markers may be found in the Yearly Operational Plans issued by participating railroads . APPENDIX C 333 CMR 11 . 00 Right of Way Management 333 CMR 11.00 : RIGHTS OF WAY MANAGEMENT Section 11.01: Purpose 11.02: Definitions 11 .03: General Provisions 11 .09: Sensitive Area Restrictions 11.05: Vegetation Management Plan (VMP) 11 .06: Yearly Operational Plan (YOP) 11.07: Public Notification 11 . 08 : Notice of Modification and Revocation 11.09: Right-of-Appeal 11 .10: Penalties 11.01: Purpose The purpose of this chapter is to promote the implementation of Integrated Pest Management (IPM) Techniques and to establish those standards, requirements, and procedures necessary to minimize the risk of unreasonable adverse effects on human health and the environment associated with the use of herbicides to maintain rights-of-way and to establish a statewide and uniform regulatory process. These regulations establish procedures which guarantee ample opportunity for public and municipal agency review and input on right-of-way maintenance plans. 11.02: Definitions For the purpose of 333 CMR 11.00, the following definitions shall apply: Agricultural Area shall refer to, but not be limited to, actively cultivated gardens, greenhouses, orchards, fields, pastures, and other areas where herbicides might impact adversely on the vegetation under cultivation or agricultural management. Applicant shall refer to any person representing federal, state, or local governments or agencies, utilities, railroads, pipelines, that intend to maintain a right-of-way by the application of herbicide. Ballast shall refer to the coarse gravel or crushed rock onto which the ties, tracks, and any switching, signaling and communication devices of a railroad are laid. Broadcast shall refer to any non-selective herbicide application technique which results in application to all vegetation within a target area. Department shall refer to the Department of Food and Agriculture. Foliar Treatment shall refer to any technique which applies herbicide to leaves of the target vegetation. -1- Inhabited Area shall refer to, but not be limited to residences, schools, hospitals, parks and recreational facilities or other areas in which humans generally live, work, or gather. Low Pressure shall refer to pressure under 60 psi. Maps shall refer to maps which are of such accuracy and scale, as deteFmined by the Department to provide sufficient detail so that sensitive areas can be delineated or which show bench marks or other permanent structures located on the right-of-way which allow the delineation of sensitive areas. Person shall refer to, but is not limited to, an individual, association, partnership, corporation, company, business organization, trust, estate, the Commonwealth or its political subdivision, administrative agencies, public or quasi-public corporation or body, or any other legal entity or its legal representatives, agent or assignee, or a group of persons. Person aggrieved shall refer to any person who, because of an act or failure to act by the Department, may suffer an injury in fact which is different either in kind or magnitude from that suffered by the general public and which is within the scope of the interests identified in these Regulations. Such person must specify in writing sufficient facts to allow the Department to determine whether or not the person is in fact aggrieved. Primary Recharge Area is that land area delineated by Zone II as defined in 310 CMR 24 .06 or in such cases as when the primary recharge area has not been designated it shall be, in the interim, be defined as a one half mile radius from the public drinking water supply well unless otherwise determined by the Department of Environmental Protection. Right(s) -of-Way (ROW) for the purpose of this regulation shall refer to any roadway, or thoroughfare on which public passage is made and any corridor of land over which facilities such as railroads, powerlines, pipelines, conduits, channels or communication lines are located. Selective Application shall refer to the application of herbicide in such a manner that the delivery to the target vegetation is optimized and delivery to non-target vegetation and the environment is minimized. Sensitive Areas shall refer to any areas within rights-of-way including but not limited to the following in which public health, environmental or agricultural concerns warrant special protection to further minimize risks of unreasonable adverse effects: (a) within the primary recharge area of a public drinking water supply well; (b) within 400 feet of any surface water used as a public water supply; (c) within 100 feet of any identified private drinking water supply well; -2- (d) within 100 feet of any standing or flowing water; (e) within 100 feet of any wetland; (f) within 100 feet of any agricultural or inhabited area. Stem Treatment shall refer to any technique including stump, basal, stem, injection, banding, frill, girdle and any other treatment which delivers herbicide at low pressure to the stump, base, or stem of the target vegetation. _Target Vegetation shall refer to any plant species which has the potential to interfere with the operation of the rights-of-way. Touch-up Application shall refer to limited application of herbicides following an initial treatment, which is' necessary to achieve the desired vegetation control . Vegetation Management Plan (VMP) shall refer to a long term management plan for the applicant' s right-of-way system which describes the intended program for vegetation control over a five year period. VMP Advisory Panel shall refer to the Vegetation Management Plan Advisory Panel as set forth in 333 CMR 11.05 (4) . Yearly Operational Plan (YOP) shall refer to the yearly operational plan which describes the detailed vegetation management operation for the calendar year consistent with the terms of the long term Vegetation Management Plan. water Supply shall refer to any raw or finished water source that is presently used, reserved for future use, or under investigation for future use by a public water system as defined in 310 CMR 22.02, or used as a source of private drinking water by one or more persons. This shall include all land and waters used as, or tributary to, a public water system except those exempted under 310 CMR 22.20. Wetlands with the exception of land subject to flooding shall refer to areas subject to protection under M.G.L. c. 131.s.40 which include the following areas as defined in 301 CMR 10.02 (1) (a) - (c) : (a) Any bank the ocean any freshwater wetland any estuary any coastal wetland any creek any beach bordering any river any dune on any stream any flat any pond any marsh or any lake or any swamp (b) Land under any of the water bodies listed above (c) Land subject to tidal action. 11.03: General Provisions (1) No person shall use an herbicide for the purpose of clearing or maintaining a right-of-way unless appropriately certified by the Department or unless appropriately licensed by the Department and working under the on-site supervision of an appropriately certified applicator. (2) No person shall use an herbicide for the purpose of clearing or maintaining a right-of-way except in accordance with a Vegetation Management Plan (VMP) and a Yearly Operational Plan (YOP) as approved by the Department. Such documents shall be -available at the work site at all times during herbicide applications and be made available to the Department and municipal officials including the Conservation Commission and Board of Health upon reasonable request. (3) No person shall handle, mix, or load an herbicide concentrate on a right-of-way within 100 feet of a sensitive area. (4) The perimeter of any sensitive areas which are not readily identifiable on the ROW shall be appropriately marked prior to any herbicide applications. The precise method used in marking these areas shall be identified in the VMP. (5) No foliar application of herbicides shall be used to control vegetation greater than 12 feet in height except for side trimming. (6) No herbicide shall be applied when the wind velocity is such that there is a high propensity to drift off target and/or during measurable precipitation. (7) No person shall apply herbicides by aircraft for the purpose of clearing or maintaining a right-of-way. (8) No touch-up applications shall be carried out except under the following conditions: (a) Touch-up applications must occur within 12 months of the date of approval of the YOP. (b) The Department, the Conservation Commission, the Board of Health, and the Chief elected official of the municipality shall be notified by certified mail at least 21 days prior to any application. (c) No more than 10% of the initially identified target vegetation on the applicant' s right-of-way in any municipality may be treated and the total amount of herbicide applied in any one year shall not exceed the limits specified by the label or Yearly Operational Plan. (d) The Department may impose such additional restrictions or conditions on the use of herbicides as it deems necessary to protect public health and the environment. (9) The Department will maintain mailing lists of individuals and groups desiring to obtain notices on various aspects of the Program. -4- 11 .04: Sensitive Area Restrictions (1) General (a) No more than the minimum labeled rate of the pesticide product for the appropriate site, pest, and application method shall be applied. (b) Herbicides applied in sensitive areas shall be applied , selectively by low pressure foliar techniques or stern application. (c) No person shall apply herbicides for the purpose of clearing or maintaining a right-of-way in such a manner that results in drift to any area within 10 feet of standing or flowing water in a wetland or area within 400 feet of a public drinking water supply well; or area within 100' feet of any surface water used as a public water supply; or area within 50 feet of a private drinking water supply identified in accordance with 333 CMR 11.04 (2) (c) (3) . (d) The Department, in corporation with the Department of Environmental Protection, and subject to a Memorandum of Understanding will evaluate herbicides currently registered for use on rights-of-way and will distribute a list of herbicides recommended for use in sensitive areas and guidelines for their use. The Memorandum of Understanding will set forth a procedure for this evaluation based on all available data relative to environmental fate and toxicity. Such list, guidelines and procedures will be subject to review and comment by the Department of Public Health provided that such comments are provided to the Department within a reasonable time. The Department, on August 15 of the calendar year, will make available the list and guidelines to applicants and to the VMP Advisory Committee. Applicants proposing to use an herbicide which has been registered for use on rights-of-way but has not yet been evaluated pursuant to the provisions of the Memorandum of Understanding may request that such herbicides be evaluated pursuant to said provisions . For an herbicide which has, been evaluated pursuant to the provisions of the Memorandum of Understanding, applicants proposing to use such herbicide in a manner inconsistent with the terms and conditions of use imposed in the guidelines may request a modification or waiver of such terms or conditions . A request for such modification or waiver shall provide a detailed rationale for use including all relevant data including but not limited to environmental fate, efficacy, and human health effects of the proposed herbicide. Such herbicides and/or uses shall be subject to the evaluation standards adopted by the Departments of Food and Agriculture and Environmental Protection in the Memorandum of Understanding. Commentary Applicants subject to the provisions of the Wetlands Protection Act, who wish to apply pesticides registered for use in Massachusetts to rights-of-way, may choose to apply herbicides determined to be suitable for use in sensitive -5- areas in accordance with the provisions of the Memorandum of Understanding mentioned above or, alternatively, applicants may proceed pursuant to the provisions of 310 CMR 10.00 as authorized by M.G.L. c.131.s .40. (e) The Department may impose such additional restrictions or conditions on the use of herbicides within or adjacent to sensitive areas as it determines necessary to protect human , health or the environment. Such changes may be proposed by a municipal agency or individual during the public comment period. (2) water Supplies (a) Public Ground Water Supplies 1. No herbicides shall be applied within 400 feet of any public ground water supply well. 2. No herbicides shall be applied within the primary recharge area of a public ground water supply well except under the following conditions: a. A minimum of 24 months shall elapse between applications: and b. Herbicides shall be applied selectively by stem application or low pressure foliar techniques. (b) Public Surface Water Supplies 1. No herbicide shall be applied within 100 feet of any surface water used as a public water supply. 2. No herbicide shall be applied between 100 feet and 400 feet of any surface water used as a public water supply except under the following conditions: a. A minimum of 24 months shall elapse between applications: and b. Herbicides shall be applied selectively by stem application or low pressure foliar techniques. (c) Private Drinking Water Supplies 1 . No herbicide shall be applied on or within 50 feet of any private drinking water supply identified in accordance with 333 CMR 11.04 (2) (c) (3) . 2. No herbicide shall be applied between 50 feet and 100 feet of any private drinking water supply identified in accordance with 333 CMR 11.04 (2) (c) (3) except under the following conditions: a. A minimum of 24 months shall elapse between applications: and b. Herbicides shall be applied selectively by stem application or low pressure foliar techniques. 3 . It shall be the responsibility of the applicant to adhere to the sensitive area restrictions around identified private wells. The applicant shall consult with the Department to identify private wells that are located within 100 feet of the rights-of-way. The Department shall request the location of private wells along the right-of-way from the Department of Environmental Management and local Boards of Health. Wells identified to be within 100 feet shall be kept on -6- file by the applicant for delineation on the maps in the YOP and be listed in the YOP. The VMP must include the method of locating identified private wells in the field prior to the application of herbicides. (3) Surface Waters (a) No herbicide shall be applied on or within ten feet of any standing or flowing surface water which is not a public water supply. No herbicides shall be applied between ten feet and 100 feet of any standing or flowing surface water which is not a public water supply except under the following conditions: 1 . A minimum of 12 months shall elapse between applications: and 2 . Herbicides shall be applied selectively by stem application or low pressure foliar techniques. (4) Wetlands (a) No herbicide shall be applied on or within ten feet of a wetland. (b) No herbicide shall be applied between ten feet and 100 feet of a wetland except under the following conditions: 1. A minimum of 12 months shall elapse between applications: and 2. Herbicides shall be applied selectively by stem application or low pressure foliar techniques. (c) Notwithstanding 333 CMR 11.04 (4) (a) , public utilities providing electric, gas, water, telephone, telegraph, and other telecommunication services may apply herbicides on or within ten feet of a wetland in accordance with the following conditions: 1. Submission of a study, the design of which is subject to prior approval by the Departments of Food and Agriculture and Environmental Protection, evaluating impacts of proposed vegetation management programs on wetlands: and 2. A finding by the Department, after consultation with the Advisory Committee, that the proposed vegetation management program will result in less impacts to the wetland than mechanical control. 3. Notwithstanding the above, no herbicides shall be applied on or within ten feet of any standing or flowing water in a wetland. (5) Inhabited and Agricultural Areas (a) No high pressure foliar herbicide applications shall be carried out within 100 feet of any inhabited area or any agricultural area during the growing season. (b) No foliar herbicide shall be applied within 100 feet of any inhabited area or any agricultural area during the growing season except under the following conditions: -7- 1. A minimum of 24 months shall elapse between applications : and 2. Herbicides shall be applied selectively by stem application or low pressure foliar techniques. 11.05: Vegetation Management Plan (VMP) (1) General (a) Unless otherwise specified by the Department, all VMPs should be submitted by the applicant no later than September 1 prior to the calendar year of the proposed first year of maintenance. All approved VMPs shall take effect on January 1 unless otherwise specified by the Department, and shall be effective for a five year period unless otherwise modified, or revoked by the Department. (b) The VMP shall be presented on forms and/or format approved by the Department. (2) Rectuirements The VMP shall include but not be limited to the following: (a) General statement of goals and objectives of the VMP. (b) Identification of target vegetation. (c) Intended methods of vegetation management and rationale for use. (d) Justification of herbicide applications proposed. (e) Methods, references, and sources for identifying sensitive areas and control strategies proposed for sensitive areas . (f) Operational guidelines for applicators relative to herbicide use. (g) Identification and qualifications of individuals developing and submitting a plan. (h) A description of Integrated Pest Management Programs or other techniques/programs to minimize the amount and frequency of herbicide application. (i) Description of alternative land use provisions or agreements that may be established with individuals, state, federal or municipal agencies that would minimize the need for herbicide, including the rationale for accepting or denying any reasonable request made by any individual. (j) Remedial plan to address spills and related accidents . (3) Public Notice, Review, and Comment (a) Upon receipt of the proposed VMP, the Department shall schedule and hold appropriate regional public hearings affording all interested parties the opportunity to comment on the proposed plan. (b) At least 21 days prior to the public hearings, the Department shall publish notice of the hearings in the Environmental Monitor and regionally located newspapers, and send notice to municipalities covered by the plan and to the appropriate mailing list. The notice will include locations where copies of the VMP can be reviewed. -8- (c) The public shall have no less than 45 days, starting from publication of the Environmental Monitor notice, to comment upon proposed VMPs unless the Department extends the comment period for good cause. (d) At least 21 days prior to the end of the public comment period, the applicant shall send a copy of the proposed VMP to the chief elected official, the Board of Health, and the ,Conservation Commission in affected communities upon their request. (4) VMP Advisory Panel (a) There shall be a VMP Advisory Panel• charged with the responsibility of reviewing Vegetation Management Plans and the Accompanying Public comments. The Panel shall recommend approval, denial, or modification to the Department. (b) The Panel shall consist of the Commissioner(s) or designees of the following Departments: Department of Food and Agriculture, non-voting Department of Environmental Protection Department of Public Health Department of Public Works and Division of Fisheries and wildlife, Natural Heritage Program a representative appointed by the Commissioner of DFA from each of the following groups : Massachusetts Association of Conservation Commissions; Massachusetts Association of Health Boards; University of Massachusetts / Extension Service; Railroads; Utilities; Applicator; and an Environmentalist A member shall be appointed for a term of one, two, or three years. Appointed members shall serve at the discretion of the Commissioner. No member shall serve more than six consecutive years. Appointed panel members shall serve . without compensation and shall not be reimbursed. for any expenses incurred by them in the performance of their duties. The Commissioner of the Department or designee shall serve as an ex officio non-voting member to the VMP Advisory Panel. (c) The Department of Food and Agriculture' s Representative shall chair the VMP Advisory Panel. This chairperson shall coordinate efforts of the Department and the Panel to process the VMPs. (d) The VMP Advisory Panel shall review all complete VMPs including all written and public hearing comments. The Advisory Panel may, if necessary, request from the applicant additional information. Within 30 days of the end of the comment and review period, unless extended for good cause, the VMP Advisory Panel shall recommend to the Department in writing approval, denial, or modification of each VMP. (5) Disposition of VMP (a) Thirty copies of the proposed VMP shall be submitted to the Department. The Department shall distribute copies of the proposed VMP to each member of the Advisory Panel. -9- (b) Within 30 days of the end of the public comment period unless extended for good cause, the VMP Advisory Panel shall review the VMPs and recommend in writing to the Department approval, denial, or modification of each VMP; if necessary, the Panel may request from the applicant additional information. (c) Within 21 days of the end of the VMP Advisory Panel review ,period, unless extended by the Department for good cause, the Department will notify the applicant and the Advisory Panel in writing one of the following: 1 . request for additional information or modification; or 2 . denial of VMP; or 3. approval of VMP. (d) The VMP may be modified, withdrawn or amended by the applicant through a written request sent by certified mail to . the Department. (e) Resubmission of a denied VMP, updating of a VMP, or a significant amendment to an approved VMP shall be processed according to 333 CMR 11.05. (f) The applicant must send a copy of the approved VMP to the chief elected official, Board of Health, and Conservation Commission in each municipality covered by the plan. (6) Time for Action Non action on a Vegetation Management Plan within time specified herein does not constitute approval of the submitted plan. In the event that the Department fails to notify the applicant of a decision within the time specified above and upon written request from the applicant, the Commissioner must issue a finding within ten days of receipt stating the reason for the delay and providing an estimated completion date. 11.06: Yearly Operational Plan (YOP) (1) General (a) The applicant is responsible for the accuracy and completeness of all information submitted with the YOP. The YOP shall be consistent with the objectives of the VMP and shall describe the intended operational program for that calendar year. (b) The YOP shall be presented on forms and/or format approved by the Department. (2) Requirements The YOP shall include but not be limited to the following: (a) Maps locating the ROW and Sensitive areas not readily identifiable in the field. (b) Herbicides proposed including application rates, carriers, adjuvants. (c) Herbicide application techniques and alternative control procedures proposed. (d) The company which will perform any herbicide treatment. (e) Identification of target vegetation. (f) Individual representing applicant supervision YOP. -10- (g) Flagging methods to designate sensitive areas on the ROW. (h) Herbicide Fact Sheets as approved by the Department. (i) Procedures and locations for handling, mixing, and loading of herbicide concentrates. (3) Public Notice, Review, and Comment (a) Upon submittal of the YOP for approval, the Department ,will publish a notice in the Environmental Monitor. Said notice shall be provided by the applicant and shall include the information on the municipalities through which the rights-of-way pass, a brief description of the intended program, and the procedure for public review and comment. The Department will distribute copies of the Environmental Monitor notice to the appropriate mailing list and the applicant. (b) The applicant shall provide by certified mail under separate cover to the Board of Health, the Conservation Commission, and the chief elected municipal official a copy of the proposed YOP and the Environmental Monitor notice for the city or town in which the herbicide treatment is proposed. The applicant shall maintain copies of the packet sent to municipalities and certified mail receipts as part of the record keeping requirements. 33 CMR 10.15. (c) The Department shall allow a 45 day comment period on proposed YOPs unless extended for good cause, commencing with the publication of the notice in the Environmental Monitor and receipt of the proposed YOP and Environmental Monitor notice by each municipality. (d) The Department may approve, deny, or modify YOPs after the 45 day comment period has expired. (4) Disposition of YOP (a) The YOP shall be submitted by the applicant to the Department at least 90 days prior to the proposed commencement of application to allow completion of the comment period and review. (b) The Department shall review the YOP to ensure that the YOP is consistent with the approved VMP. Any inconsistencies or deficiencies will be noted by the Department and returned to the applicant. (c) Where practical, the Department shall approve or deny the YOP within 90 days of receipt. The Department will provide notice of the decision to the applicant, municipal agencies, and commentators in writing. (d) The approved YOP in conjunction with the VMP shall govern the application of herbicide for a period not to exceed 12 months in accordance with other laws and regulations of the State and Federal governments and impose such conditions as necessary to minimize the risk of adverse effects on human health and the environment. (5) Time for Action Non action on a Yearly Operational Plan within the time specified herein does not constitute constructive approval of the submitted plan. In the event that the Department fails to notify the applicant of a decision within the time specified -11- above and upon a written request from the applicant the Commissioner must issue a finding with 10 days of receipt stating the reason for the delay and providing an estimated completion date. 11.07: Public Notification The applicant shall provide by certified mail under separate cover at least 21 days in advance of the application of herbicide to the right-of-way, a notice to the Department and to the Mayor, City Manager, or Chairman of the Board of Selectman, the Board of Health, and the Conservation Commission in the municipality where the right- of-way lies. The notice shall include but not be limited to the approximate date on which such spraying shall occur, provided however, that said spraying shall not conclude more than ten days after said approximate date; a copy of a DFA approved Herbicide Fact Sheet on the active ingredients) of the herbicides) used; the name and address of the contractor who will make the application or the name of the certified employee who will make the application. This notice may run concurrently with the public notice and comment period in 333 CMR 11. 06 (3) provided the application is made after the close of the public notice and comment period and all modifications to the YOP are made before the application takes place and approval is granted by the Department. 11.08: Notice of Modification and Revocation (1) The Department may suspend approval of any VMP or YOP by written notice to the applicant and applicator halting the application of herbicide to that right-of-way of the above mentioned YOP. After 21 days if the applicant does not request a hearing, the Department may revoke or modify the VMP and YOP if it finds: (a) that the terms, conditions of restrictions thereof are being violated or are inadequate to avoid unreasonable adverse effects on the environment or on human health; or (b) that the applicant has made a false or misleading statement in the VMP or YOP; or (c) that the applicant has violated any provision of the Massachusetts Pesticide Control Act or FIFRA, or any regulations, standards, orders, or license issued under either. (2) Upon notice of revocation or modification, the applicant may modify the YOP by written request to the Department. Applications to modify the YOP shall be submitted in the Manner set forth in 333 CMR 11.06 and disposed of in the manner set forth in 333 CMR 11.06. The Department may waive all or part of the requirement if it determines that the proposed changes do not significantly change the terms of the approved YOP. 11.09: Richts of Appeal Any person aggrieved by the decision of the Department to approve, deny, modify, or revoke a Vegetation Management Plan or a Yearly -12- Operational Plan may request an adjudicatory hearing. The request for a hearing must be sent to the Department by Certified mail or hand delivered within 21 days after the date of decision or notice by the Department. At the same time the request for a hearing must be sent by Certified mail or hand delivered to the applicant and the Pesticide Board. The request should state clearly and concisely the facts of the proceeding, the reasons the decision is alleged to be inconsistent with 333 CMR 11.00 and the relief sought by the adjudicatory hearing. The adjudicatory hearing before the Pesticide Board shall be conducted as set forth in• M.G.L.c.30A and M.G.L.c. 132B.s.13. 11.10: Penalties Any person who violates any provision of 333 CMR 11.00 shall be subject to the crimianl and civil penalties set forth in M.G.L.c. 132B.s.14. REGULATORY AUTHORITY 333 CMR 11.00: M.G.L.c.132B. -13- APPENDIX D 310 CMR 10 . 00 Preface to Wetlands Regulations Relative to Right-of-Way Management 310 CMR: DEPARTMENT OF ENVIRONMENTAL QUALITY ENGINEERING PREFACE TO WETLANDS REGULATIONS RELATIVE TO RIGHTS OF WAY MANAGEMENT 1987 REGULATORY REVISION In 1983, the Massachusetts Pesticide Control Act, Ch. 132B, was amended to require notification of conservation -commissions prior to application of herbicides on rights of way. Many commissions became aware for the first time that application of herbicides on rights of way may result in alteration of wetlands and, with the exception of exempt utilities, may require action under the Wetlands Protection Act. On July 18, 1986, the Department issued a final decision after adjudicatory hearing in DEQE Hearing Docket Nos. 83- 28 and 83-35 (Clinton and Leverett) finding that the application of specific herbicides by the railroads to track and ballast within 100 feet of wetland areas would alter those wetlands and was therefore subject to jurisdiction under the Act, requiring the filing of Notices of Intent with the local conservation commissions. The Department of Food and Agriculture (DFA) initiated a Generic Environmental Impact Report (GEIR) evaluating alternatives for rights of way management. A technical advisory task force of environmentalists, agencies and rights of way managers assisted in the GEIR preparation and, based on results of the study, recommended to the Secretary of Environmental Affairs a framework for a coherent state-wide rights of way regulatory program. DFA published draft regulations to implement this program in 1986 and received extensive public commentary. Final regulations, 333 CMR 11.00 became effective on July 10, 1987. The DFA regulations require persons proposing to apply herbicides to rights of way to first receive approval of a five year Vegetation Management Plan (VMP) and Yearly Operating Plan (YOP) . These regulations identify certain "sensitive areas", including wetlands and public and private surface and groundwater supplies, where the application of herbicides is, in most instances, prohibited, and areas adjacent to the sensitive areas where use of herbicides is curtailed. DEQE worked closely with DFA to include provisions which give maximum protection for water supplies and provide protection for wetlands at least equal to that provided under the Wetlands Protection Act and regulations. To eliminate duplicate review under the Wetlands Protection Act, DEQE has adopted changes to the wetlands regulations which allow herbicide applications on rights of way in accordance with the DFA regulations without filing a Notice of Intent under the Wetlands Protection Act. However, non- exempt applicants will still be required to file a Request for Determination of Applicability to the appropriate conservation commission to establish boundaries of wetlands on or near the right of way. Specifically, these regulations presume that work performed in accordance with a VMP and YOP, as may be required under DFA regulations, will not alter an area subject to protection under the Wetlands Protection Act. During the public comment period on its proposed regulations, the Department identified several issues of major concern. After consideration of all comments, the Department has determined that, except for minor points of clarification and the addition of an automatic expiration date, no further changes in the regulations are warranted at this time. A discussion of these issues. follows. A. Presumption vs Limited Proiect Several commentators suggested that conservation commissions should retain the authority to review each herbicide application on rights of way through the usual Notice of Intent process . These regulations create a presumption that herbicide application carried out in accordance with an approved VMP and YOP under the DFA regulations will not alter wetlands and that the filing of a Notice of Intent is therefore not required. This procedure was established pursuant to the recommendation of the GEIR task force with states: The regulations which provide for approval of Vegetation Management Plans by the Department of Food and Agriculture should be conditioned on review and approval by the Department of Environmental Quality Engineering (DEQE) of those portions of the Plans that deal with wetlands. The DEQE should be required to certify to the DFA that these portions of the Plans will result in compliance with the substantive and procedural provisions which protect the interests of the Wetlands Protection Act. If the regulations are so drawn, activities under a Plan approved by DEQE would not constitute an alteration of wetlands as defined under the Wetlands Protection Act regulations . Since the DFA regulations provide that DEQE is a member of the VMP advisory panel which reviews and makes recommendations on the approval of VMPs, the GEIR task force recommendations have been fully implemented. Therefore, the Department has determined that it would be duplication to require the filing of individual Notices of Intent in each municipality for each application of herbicides to rights of way. B. Adequacy of Setback from Wetlands The DFA rights of way regulations prohibit application of herbicides on or within ten feet of wetlands and strictly limit herbicide application from ten feet to 100 feet of wetlands. Many commentators questioned the adequacy of these setback requirements and suggested that a 50 or 100 no spray zone would be more appropriate. Several commentators suggested that the proposed setback requirements were inconsistent with the Department' s adjudicatory hearing decision in the Clinton and Leverett cases. The no spray zone surrounding wetlands is necessary for three reasons : to compensate for mapping errors, to compensate for applicator errors, and to assure that herbicides will not migrate into wetlands after application on the adjacent uplands. During the pubic comment period, the Department received no evidence demonstrating that the ten-foot setback established in the DFA regulations will not be adequate. The DFA regulations establish a procedure for selecting a limited number of herbicides that may be applied in the limited spray zone (from 10 to 100 feet from wetlands) which is adjacent to the no spray zone. Herbicides that will be selected for use in these limited spray zones under the DFA regulations are those which available data demonstrate will not migrate further than ten feet. The applicators have argued that they can maintain a level of accuracy in mapping of wetlands and in application of herbicides to assure that herbicides will not be inadvertently applied within ten feet of wetland areas. The Department is not convinced that these claims are unreasonable; however, in order to confirm their accuracy, the Department has included in the final regulations an automatic expiration date two years from the effective date, which is coterminous with the expiration date of the dFA regulations. During the two-year effective period of these regulations, the Department expects applicators to conduct studies monitoring herbicide application operations and to submit a report concerning impacts of herbicide application on wetlands under these new regulations detailing the accuracy of wetlands mapping, the accuracy of herbicide application, and the extent of herbicide migration. The results of this study will provide a basis for recommendations by the Department for amendments to the DFA regulations and a decision on reauthorization of these amendments to the Department' s wetland regulations. Finally, the Department does not find the setbacks requirements established in the DFA regulations to be inconsistent with its decision in the Clinton and Leverett cases. In that decision, the Department assumed a worst-case analysis in terms of an herbicide known to be highly mobile which was applied to the track and ballast areas adjacent to wetlands. The Department found, based on the particular facts of these cases and the particular herbicide proposed for application that there would be a migration of that herbicide into the wetlands from application within the 100-foot buffer zone that would be sufficiently concentrated to cause alterations of the wetlands plants . However, the DFA rights of way management regulations set up a procedure for identification of herbicides which are relatively immobile and which are pre-approved for application on the buffer zone in order to avoid alteration of wetlands plants. Furthermore, guidelines for application of the selected herbicides will also be established. Finally, no herbicides may be applied within ten feet of wetland areas. In light of the strict controls placed on application of herbicides within the 100-foot buffer zone under the DFA regulations, the Department finds that adoptions of the proposed regulatory scheme is fully consistent with its previous adjudicatory hearing decision in the Clinton and Leverett cases. C. Impacts of Herbicides Application on Wildlife Habitat The Department is currently developing regulations under the Act to protect wildlife habitat. The effective date of these regulations One commentator expressed concern regarding is November 1, 1987 p g g the impact of herbicide application on wildlife habitat in wetlands, and particularly on the habitat of rare, "state-listed" wildlife species . As discussed above, the Department has determined that the DFA regulations provide for protection of wetlands from alterations due to herbicide application. However, the DFA regulations do not include floodplains in their definition of wetlands, although those regulations do prohibit herbicide application within 10 feet of any standing or flowing surface water. Beyond that, there is no specific protection of wildlife habitat, including rare species, in floodplain areas. The Department is concerned that the DFA regulations do not specifically address protection of wildlife habitat in floodplans, in particular those rare, "state-listed" wildlife species . Therefore, as a member of the VMP advisory panel, the Department will review VMPs for potential effect on wildlife habitat and specifically will recommend disapproval of any VMP that will have an adverse effect in areas mapped by the Natural Heritage and Endangered Species Program as habitat of any rare, "state-listed" wildlife species . Furthermore, the Department expects applicators to incorporate into the previously discussed two-year monitoring study a section detailing the effects of herbicide application on wildlife habitat in floodplains and on the habitat of rare, "state- listed" wildlife species. The Department will use the results of this study as the basis for recommending any amendments to the DFA regulations and a decision on reauthorization of these amendments to the Department' s wetlands regulations . APPENDIX E Herbicides approved for use on sensitive areas of railroad ROWs as of August 2004, subject to revision. Massachusetts Department of Agricultural Resources Page 1 of G d55 mass ryovhoma • oniinesewites • 3Wa��ireyy �k t � �1gMj, � { y.. �1 .!V 5t � I��FJ �.i.( h � ��✓�� }Jr��V uti(t rJ� ; a Y ,. *^ �s t6 • y Rights-of-Way Sensitive Area Materials List (August 2004) DAR home> pesticides> rights-of-way> sensitive area materials list Contact: Gerard Kennedy 617-626-1773 Trade Active Ingredient Use Restrictions Name, EPA Registration Registrant Number Accord 524-326 Glyphosate Lowest Labeled Rate Monsanto Accord Concentrate 524-343 Glyphosate Lowest Labeled Rate Monsanto Rodeo 524-343 Glyphosate Lowest Labeled Rate Monsanto Round-Up Pro 524-475 Glyphosate Lowest Labeled Rate Monsanto Accord SP Dow 62719-322 Glyphosate 1E Lowest Labeled Rate roSciences Glypro Plus Dow 62719-322 Glyphosate Lowest Labeled Rate groSciences IF M 62719-324 Glyphosate Lowest Labeled Rate Glyphosate VMF 352-609 Glyphosate Lowest Labeled Rate El DuPont 11 Escort 352-439 Metsulfuron-methyl Lowest Labeled Rate EI DuPont Escort XP EI DuPont 352-439 Metsulfuron-methyl Lowest Labeled Rate Krenite S Ammonium Salt El DuPont 352-395 offosamine Lowest Labeled Rate Oust EI DuPontIF 352-601 Sulfometuron methyl IF Lowest Labeled Rate Massachusetts Department of Agricultural Resources Page 2 of 2 Oust 352-401 Sulfometuron methyl Lowest Labeled Rate ] EI DuPont Sulfometuron methyl (56.25%) Oust Extra 352-622 Lowest Labeled Rate EI Dupont Metsulfuron Methyl (15%) Arsenal 3 pints/acre every 3rd year OR BASF 241-346 Imazapyr 2 pintslacre every other year Arsenal Railroad 3 pints/acre every 3rd year OR 2 Herbicide 241-273 Imazapyr pints/acre every other year BASF The lowest of the following rates: Garton 4 Lowest Labeled Rate or Dow 6271940 Triclopyr, butoxyethyl ester 0.5 pints per acre within 10 feet; groSciences Lowest labeled rate or 3.0 pints within 50 feet Disclaimer: The Massachusetts Department of Agricultural Resources makes no endorsement of any compani organizations, persons, products, trade or brand names referenced in this Rights of Way Sensitive Area Material: ("the list"). Active Ingredients on the list are reviewed pursuant to a Cooperative Agreement between the Massachusetts Department of Agricultural Resources and the Massachusetts Department of Environmental Protection. Only environmental fate and toxicological data, including eco-toxicological data, are reviewed whe evaluating an active ingredient's suitability for inclusion on the list. Inclusion on the list does not represent an, endorsement by the Massachusetts Department of Agricultural Resources as to the efficacy of the active ingredie rights-of-way vegetation management. Disclaimer l Privacy Statement This Page Last Reviewed and Updated August 2004. Massachusetts Department of Agricultural Resources Suite 500,251 Causeway Street Boston,MA 02114-2151 Telephone:617-626-1700 Fax:617-626-1850 i TEC ASSOCIA1 ES CONSULTI NGINEERS 21 April 2005 RECEIVED Salem Conservation Comm. 120 Washington Street APR 2 6 2005 Salem, MA 01970 DEPT. OF PL,; NINu& RE : Massachusetts Bay Commuter Railroad' s COMMONITVDEVELOPMENT 2005 Vegetation Control Program Dear Commission Members : Enclosed is Massachusetts Bay Commuter Railroad' s 2005 Yearly Operational Plan prepared in accordance with the Massachusetts Rights-of-Way Management Regulations (333 CMR 11 . 00) . Maps provided with this Plan remain in effect for the period 2005-2009 unless modified and . should be retained in your files . The indication on the maps of private drinking water supply wells remains an ongoing process . Please notify TEC Associates and the Department of Agricultural Resources of any omissions . Please also review your mailing address and the ten digit police department emergency telephone number listed in the Plan and notify us of any revisions . The herbicide application as proposed in the 2005 Yearly Operational Plan is scheduled as follows . Rights-of-way 2-17 July 2005 Touch-up application 5-16 September 2005 Brush application (non-sensitive areas) 5-16 September 2005 The location of signs marking the limited and no-spray zones will be verified prior to the application. Please call TEC Associates with any questions about this Plan. Very truly yours., TEC ASSOCIATES i14�1-F-- Wayne W. Duffett Enclosure CC : Board of Health Board of Selectmen DAR Rights-of-Way Program Robert Johnson, MBCR 46 Sawyer Street South Portland, Maine 04106 207/767-6068 FAX 207/767-7125 r., f THE COMMONWEALTH OF MASSACHUSETTS S EXECUTIVE OFFICE OF ENVIRONMENTAL AFFAIRS Department of Agricultural Resources 251 Causeway Street, Suite 500, Boston, MA 02114 617-626-1700 fax 617-626-1850 www.Mass.gov/AGR MITT ROMNEY ELLEN ROY HERZFELDER Governor Secretary KERRY HEALEY DOUGLAS P.GILLESPIE Lieutenant Governor Commissioner NOTICE Pursuant to the provisions of the Rights-of-Way Management Regulation, 333 CMR 11.00, in order to apply herbicides to control vegetation along railroad rights-of-way, a five-year Vegetation Management Plan (VMP) and a Yearly Operational Plan (YOP) must be approved by the Department of Agricultural Resources. Therefore, notice of receipt of a YOP and procedures for public review are hereby given as required by Section 11.06 (3). A Yearly Operational Plan has been submitted for: Massachusetts Bay Commuter Railroad Company(MBCR). This plan has been prepared and submitted to the Department of Agricultural Resources by: TEC Associates of South Portland, Maine. Municipalities identified in the MBCR YOP as locations where the rights-of-way will be treated with herbicides during the 2005 calendar year are: Abington, Acton, Andover, Attleboro, Avon, Ayer, Bellingham, Belmont, Beverly, Billerica, Boston, Boxborough, Braintree, Bridgewater, Brockton, Cambridge, Canton, Chelsea, Concord, Dedham, East Bridgewater, Everett, Fitchburg, Franklin, Gloucester, Halifax, Hamilton, Hanson, Haverhill, Holbrook, Hopedale, Ipswich, Kingston, Lakeville, Lawrence, Leominster, Lincoln, Littleton, Lowell, Lunenburg, Lynn, Malden, Manchester, Medford, Melrose, Middleborough, Milford, Milton, Needham, Newbury, Newburyport, Norfolk, North Andover, Norwood, Plymouth, Plympton, Quincy, Randolph, Reading, Revere, Rockport, Rowley, Salem, Saugus, Shirley, Somerville, Stoughton, Swampscott, Tewksbury, Wakefield, Walpole, Waltham, Wenham, West Bridgewater, Weston, Westwood, Weymouth, Whitman, Wilmington, Winchester, and Woburn. MBCWs vegetation control program for 2005 will be consistent with the VMP as approved by the DAR and involves an Integrated Pest Management (IPM) approach. In the 2005 program, brush control will be limited to manual or mechanical cutting in sensitive areas and sensitive area buffer zones. In non-sensitive areas, one foliar application will be conducted to selectively treat brush adjacent to the shoulder using a DAR approved herbicide mixture. One selective herbicide application will take place in the non-sensitive and sensitive area buffer zones along the roadbed portion of the right-of-way using a DAR approved herbicide mixture. This post-emergent program is targeted toward the eradication of woody and herbaceous plant species germinating within the roadbed and around other fixtures including but not limited to: switches, signals, signs, and highway grade crossings. This application will be followed by a late summer touch-up application in areas of heavy vegetation growth. Hi-rail vehicles equipped with herbicide application equipment will be used to treat the rights-of-way. Public notification (by registered mail) will be provided to the chief elected official, Board of Health, and Conservation Commission in each affected municipality at least twenty-one days prior to any herbicide application. "Sensitive" areas as defined by the Rights-of-way Management Regulations will receive the full protection afforded by those Regulations. All herbicide applications will be done by an applicator properly licensed by the Department j . of Agricultural Resources Pesticide Bureau and fully trained in herbicide mixing, handling, and application methods. The applicant has described the following rights-of-way as sites that have been scheduled for herbicide treatment in 2005. EASTERN ROUTE MAIN LINE Newburyport to Boston Newburyport Beverly Revere Newbury Salem Chelsea Rowley Swampscott Everett Ipswich Lynn Somerville Hamilton Saugus Boston Wenham GLOUCESTER BRANCH Gloucester to Beverly Rockport Manchester Gloucester Beverly WESTERN ROUTE MAIN LINE Haverhill to Boston Haverhill Tewksbury Melrose North Andover Wilmington Malden Lawrence Reading Medford Andover Wakefield Somerville NEW HAMPSHIRE ROUTE MAIN LINE Lowell to Boston Lowell Wilmington Medford Tewksbury Woburn Somerville Billerica Winchester WILDCAT BRANCH Wilmington to Wilmington Junction Wilmington FITCHBURG MAIN LINE Fitchburg to Boston Fitchburg Boxborough Waltham Leominster Acton Belmont Lunenburg Concord Cambridge Shirley Lincoln Somerville Ayer Weston Boston Littleton Page 2 of 5 } STOUG14TON BRANCH Stoughton to Canton Stoughton Canton DORCHESTER BRANCH Readville to Boston Boston Milton FRANKLIN BRANCH Milford to Boston Milford Norfolk Westwood Hopedale Walpole Dedham Bellingham Norwood Boston Franklin NEEDHAM BRANCH Needham to Boston Needham Dedham Boston RANDOLPH INDUSTRIAL TRACK Braintree to Randolph Braintree Randolph WEYMOUTH INDUSTRIAL TRACK Braintree Braintree MIDDLEBOROUGH MAIN LINE Boston to Middleborough Boston Holbrook East Bridgewater Quincy Avon Bridgewater Braintree Brockton Middleborough Randolph West Bridgewater Lakeville PLYMOUTH BRANCH Braintree to Plymouth Braintree Whitman Plympton Weymouth Hanson Kingston Abington Halifax Plymouth Page 3 of 5 PUBLIC REVIEW The Department of Agricultural Resources (DAR) in particular seeks the verification of sensitive area locations reported in the Yearly Operational Plan (YOP). The Department itself has a limited ability to survey the geography, land use, and the water supplies, in all the communities through which the rights-of-way are located. Municipalities, however, have most of this information readily available, and the particular knowledge with which to better certify the sensitive areas in their communities. Therefore, the Department requests, and urges, the assistance of the affected municipalities, in reviewing the completeness and accuracy of the maps contained in the submitted document. The DAR has established the following procedures for this review. Yearly Operational Plans (YOP) and a copy of this notice will be sent by the applicant to the Conservation Commission, Board of Health (or designated health agent), and to the Head of Government (Mayor, City Manager, Chair of the Board of Selectman) of each municipality where herbicides are to be applied along the Rights-of-Way during the calendar year. Municipal agencies and officials will have (45) forty-five days, following receipt of the Yearly Operational Plan to review the maps contained in the document that indicate the location of"sensitive areas not readily identifiable in the filed" for inaccuracies and omissions. "Sensitive Areas" will be defined as in Section 11.01 a-f. Municipal agencies and officials are requested to forward the YOP to the appropriate officials(s) in their municipality qualified to certify the accuracy of sensitive area locations as indicated on the maps. The maps should be "corrected" and returned to the applicant, also a copy of the maps with these corrections indicated should be sent to the Department of Agricultural Resources at the address listed below within the forty-five day review period. if a city or town needs more time to carry out this review, it should send a written request for an extension to the DAR and cite why there is a "good cause" for requesting additional time. All corrections will be required to be made by the applicant, and corrected maps sent back to the city/town before the YOP can be considered "approved" by the Department for vegetation maintenance in that municipality. Any dispute on the part of the applicant regarding corrections made by the municipal authorities, should be indicated in writing to the Department and to the city/town which requested the disputed changes within(15) fifteen days of receipt of the request. The Department will decide whether or not the YOP should be approved without the requested changes. The DAR will consider the "final approval" of a YOP individually for each municipality. The final (21)twenty one days of the public review period may serve concurrently to provide public notification as required by section 11.07 of the Rights-of-Way Management regulation, if the applicant has an approved VMP and if all the requisite city/town offices which have received copies of the YOP have completed their review and corrections have been duly made by the applicant and approved by the Department. A failure by the city/town to respond to the applicants submission of the YOP within the forty five (45) day public review period, will automatically be considered by the DAR to indicate agreement by municipal officials with the sensitive area demarcations as provided by the applicant in their YOP. Any questions or comments on the information provided in this Notice and the procedures established for the municipal review as outlined above, should be addressed to: Rights-of-Way Program Massachusetts Pesticide Bureau 251 Causeway Street, Suite 500 Boston, Massachusetts 02114-2151 Any additional questions or comments on any information provided as part of the proposed YOP should be addressed in writing to: Wayne Duffett President Page 4 of 5 TEC Associates 46 Sawyer Street South Portland, Maine 04106 A copy should also be sent to the ROW program at the above address. COMMENT PERIOD ENDS AT THE CLOSE OF BUSINESS,FRIDAY,NNE 24, 2005. Page 5 of 5 Yearly Operational Plan 2005 MASSACHUSETTS BAY COMMUTER RAILROAD CO. COMMUTER RAIL SYSTEM 32 COBBLE HILL ROAD SOMMERVILLE,MA 02143 Prepared by: TEC ASSOCIATES 46 SAWYER STREET SSOUTH PORTLAND,MAINE 04106 ABSTRACT: This Yearly Operational Plan (YOP)describes the vegetation management operations for the Railroad's rights-of-way scheduled for vegetation maintenance during this calendar year in compliance with the Commonwealth of Massachusetts Rights-of-Way Management Regulations 333 CMR 11.00. This YOP is a companion document to the Vegetation Management Plan (VMP) which has been approved by the Department of Agricultural Resources. INTRODUCTION Both Federal and State laws require railroads to manage vegetation to help insure the safe passage of people, material, and goods. The Code of Federal Regulations mandates the safety of the railroad must be guaranteed by regular inspection and maintenance. Vegetation must be controlled so that it does not become a fire hazard, does not interfere with visibility, or impede direct visual inspections of the track structure. Vegetation must also be managed to allow for proper drainage of the track and ballast structure,to prevent tree and branch damage to cargo, and to provide safe footing and working conditions for trackside personnel. Vegetation growing along side the rails can prevent effective and adequate braking, especially in emergency situations. The purpose of 333 CMR 11.00, Rights of Way Management, is to promote the implementation of Integrated Pest management techniques and to establish standards,requirements, and procedures necessary to minimize the risk of unreasonable adverse effects on human heath and the environment associated with the use of herbicides to maintain rights-of-way. These regulations establish procedures which guarantee ample opportunity for public and municipal agency review and input on rights-of-way maintenance plans. A Yearly Operational Plan or YOP must be submitted to the Department of Agricultural Resources every year herbicides are intended for use to maintain Rights-of-Way. The YOP provides a detailed program for vegetation management for the year. This YOP is a companion document to the Vegetation Management Plan (VMP) approved by the Department. The VMP is the long term management plan for the railroad which describes the intended program for vegetation control over a five year period. Upon receipt of this YOP,the Department publishes a notice in the Environmental Monitor. The applicant has provided a copy of the YOP and Environmental Monitor notice to the Board of Health, Conservation Commission, and the chief elected municipal official for the city or town in which the herbicide treatment is proposed. The Department allows a 45 day comment period on the proposed YOP beginning with publication of the notice in the Environmental Monitor and receipt of the YOP and Environmental Monitor notice by each municipality. Public notification of herbicide application to the right of way is made by certified mail under separate cover at least 21 days in advance of the treatment. Notice is made to the Department of Agricultural Resources;the Mayor,City Manager or chairman of the Board of Selectman;the Board of Heath; and the Conservation Commission of the municipality where the right-of-way lies. Any comments on this YOP should be directed to the railroad contact person listed on page 1. MUNICIPALITIES WHERE TREATMENT DESCRIBED IN THIS YOP WILL BE MADE Abington Lawrence Tewksbury Acton Leominster Wakefield Andover Lincoln Walpole Attleboro Littleton Waltham Avon Lunenburg Wenham Ayer Lynn West Bridgewater Bellingham Lowell Weston Belmont Malden Westwood Beverly Manchester Weymouth Billerica Medford Whitman Boston Melrose Wilmington Boxborough Middleborough Winchester Braintree Milford Woburn Bridgewater Milton Brockton Needham Cambridge Newbury Canton Newburyport Chelsea Norfolk Concord North Andover Dedham Norwood East Bridgewater Plymouth Everett Plympton Fitchburg Quincy Franklin Randolph Gloucester Reading Halifax Revere Hamilton Rockport Hanson Rowley Haverhill Salem Holbrook Saugus Hopedale Shirley Ipswich Somerville Kingston Stoughton Lakeville Swampscott YOP REQUIREMENTS AND TABLE OF CONTENTS Page I. The Company which will perform any herbicide treatment 1 II. Individual representing applicant and supervising the YOP 1 III. Herbicides proposed including application rates, carriers, and adjuvants 2 IV. Herbicide application techniques and alternative control procedures 3 V. Identification of target vegetation 4 VI. Flagging methods to designate sensitive areas on the ROW 5 VII. Procedures and locations for handling, mixing and loading of 6 herbicide concentrates VIII. Emergency contacts 7 APPENDICES A. Herbicide Fact Sheets as approved by the Department of Agricultural resources,herbicide labels, and MSDS. B. Maps locating the ROW and Sensitive areas not readily identifiable in the field. I. THE COMPANY WHICH WILL PERFORM ANY HERBICIDE TREATMENT This company or contractor will perform the herbicide treatment. Applicators are certified by the Department of Agricultural Resources in the applicator category Right-of-Way Pest Control. Company Name RWC, Inc Address Lockhouse Road P.O. Box 876 . Westfield, MA 01086 Telephone # (413) 562-5681 Contact Person(s) Brian Chateauvert II. INDIVIDUAL REPRESENTING APPLICANT AND SUPERVISING THE YOP Individual supervising execution of the YOP and representing the railroad. Name & Title Robert Johnson Deputy Chief Engineer Address Massachusetts Bay Commuter Railroad 32 Cobble Hill Road Somerville, MA 02143 Telephone # (617) 222-3619 -1- III. HERBICIDES PROPOSED INCLUDING APPLICATION RATES, CARRIERS, ADJUVANTS, AND APPLICATION TECHNIQUES Weed Control Herbicide Program for the Roadbed The post-emergent herbicide program is aimed primarily toward keeping the ballast section and shoulder, yards, switches, signals, and highway grade crossings weed free. Areas scheduled for weed control treatments have been inspected for density of target vegetation to determine appropriate control methods. Herbicide Fact Sheets for the herbicides proposed are found in Appendix A. Location Herbicide(s) Carriers or Adjuvants Application Application Technique Rate Razor-Pro(prop.) Foliar 2 qts/acre Sensitive area Roundup-Pro(alt.) Foliar 2 qts/acre buffer zone Oust Extra Foliar 3 oz/acre More Foliar 2-5 oz/100 gal Incite 80 Foliar 2-5 oz/100 gal Razor-Pro(prop.) Foliar 2 qts/acre Non-sensitive Roundup-Pro(alt.) Foliar 2 qts/acre areas Oust Extra Foliar 3 oz/acre More Foliar 2-5 oz/100 gal Incite 80 Foliar 2-5 oz/100 gal Razor-Pro (prop.) Foliar 2 qts/acre Touch-up Roundup-Pro(alt.) Foliar 2 qts/acre applications Oust Extra Foliar 3 oz/acre More Foliar 2-5 oz/100 gal Incite 80 Foliar 2-5 oz/100 gal Brush Control Program for Areas Adjacent to the Roadbed The brush control program is designed to prevent the regrowth of trees and other woody vegetation in areas adjacent to the roadbed. Areas scheduled for brush control treatments are limited to target vegetation which obscures visibility or interferes with railroad signs, signals, or communication wires. Herbicide Fact Sheets for herbicides proposed may be found in Appendix A. Location Herbicide(s) Carriers or Adjuvants Application Application Technique Rate Razor-Pro(prop.) Foliar 4 qts/acre Non-sensitive Roundup-Pro(alt.) Foliar 4 qts/acre areas Escort Foliar 1 oz/acre More Foliar 2-5 oz/100 gal Incite 80 Foliar 2-5 oz/100 gal Touch-up None applications 2- IV. HERBICIDE APPLICATION TECHNIQUES AND ALTERNATIVE CONTROL PROCEDURES Herbicide application within the Railroad ROW will be preformed using low pressure application from a specialized by-rail truck equipped with a spray boom. This method is suitable for application within the buffer zone, or restricted application zone, of sensitive areas, as defined in 333 CMR 11.04. The spray vehicle is equipped with spray nozzles and controls to allow for treatment of the entire roadbed, or to selectively treat individual sections of the ballast and ballast shoulders. Within sensitive areas, a "container" will be used to catch any accidental dripping of herbicide. It is a trough-shaped apparatus mounted just behind and above the boom, and will be hydraulically lowered to sit underneath the spray nozzles while the vehicle is traveling through areas where herbicide spraying is prohibited. In order to assist in rapid identification of sensitive areas in the field, a pilot vehicle will proceed approximately 1/4 mile ahead of the applicator vehicle in order to signal ahead the location of sensitive areas. In order to provide greater mobility and decrease the amount of time required to apply the herbicide mixture in the railroad yard areas, a vehicle equipped with hoses will be used in these areas. In compliance with the Regulations for herbicide application in sensitive areas, the spray pressure from the hoses will not exceed 60 psi. ALTERNATIVE CONTROL PROCEDURES No alternative vegetation control methods are feasible within the track areas of the ROW. No vegetation control is proposed in ballast areas where herbicide use is prohibited. Touch-up techniques controls any target vegetation within the ballast that may have been missed or not treated during the initial phase. Control of vines and other vegetation that might creep onto the ballast from roots growing outside the original treatment boundaries can be managed as a selective, foliage, or spot spray. No more than 10% of the initially identified target vegetation on the ROW in any municipality may be treated during a touch-up application and the total amount of herbicide applied in any one year shall not exceed the limits specified by the label or YOP [per 11.03(8)(C)]. 3 V. IDENTIFICATION OF TARGET VEGETATION Whenever and wherever possible an integrated approach to vegetation management will be implemented by encouraging plant communities that hinder the growth of target vegetation. Prior to a herbicide application, a review will be made noting location, density, and type of vegetation present. This information will be used to develop a herbicide application program that will be effective against target vegetation and minimize the amount of herbicide used. In accordance with the Code of Federal Regulations, 49 Part 213 - Track Safety Standards, all vegetation growing in the ballast and ballast shoulder; in yards; and around switches, signals, signs and highway grade crossings is considered target vegetation and must be controlled so that it does not: a) become a fire hazard to track-carrying structures; b) obstruct visibility of railroad signs and signals; c) interfere with railroad employees preforming normal trackside duties; d) prevent proper functioning of signal and communication lines; and e) prevent railroad employees from visually inspecting moving equipment form their normal duty stations. Woody vegetation growing in areas adjacent to the shoulder will be managed to promote the growth of low growing shrubs. Targeted woody vegetation will be that which has the potential to block visibility or invade th roadbed and/or overhead communication lines. Target vegetation will include by not be limited to the following: Ailantus Black Walnut Honey Locust American Basswood Buckthorn Maple American Beech Butternut Northern Catalpa American Hornbeam Cherry Oak Apple Eastern Horphonbeam Pine Ash Eastern Redcedar Poplar Aspen Elm Sassafras Birch Flowering Dogwood Shadbrush Black Locust Hawthorn Spruce Black Tupelo Hickory Sumac -4- VI. FLAGGING METHODS TO DESIGNATE SENSITIVE AREAS ON THE ROW Sensitive areas are defined in the Rights-Of-Way Management Regulations (333 CMR 11.02) as those areas within the ROW in which public health, environmental , or agricultural concerns warrant special protection to further minimize risks of unreasonable adverse effects. These include but are not limited to the following: • Within the primary recharge area of public drinking water supply well. • Within 400 feet of any surface water used as a public water supply. • Within 100 feet of any identified private drinking water supply. • Within 100 feet of any standing or flowing water. • Within 100 feet of any inhabited or agricultural area. • Within 100 feet of any wetlands. No-spray areas are those in which herbicide spraying is prohibited. It includes track within 400 feet of a public water supply wellhead, 100 feet from a public surface water supply, a 50 foot radius around a private well, and 10 feet from the edge of standing or flowing water or wetlands. Limited-spray areas are those in which spraying is restricted to one annual application of a herbicide through low pressure foliar techniques. This includes track between 10 and 100 feet from the edge of standing or flowing water or wetlands. In lengths of track within the primary recharge area around a public water supply wellhead, between 100-400 feet from the edge of a public surface water supply, and between 50 and 100 foot radius around a public well, spraying is restricted to one application every other year of a herbicide though low pressure foliar techniques. Non-sensitive areas which are upland areas and/or lengths of track without proximate sensitive areas do not require specific precautions or herbicide restrictions. Sensitive areas, no-spray areas, limited-spray areas, and non-sensitive areas will be marked at their boundaries with permanent color-coded markers. Sensitive areas considered to be readily identifiable in the field (i.e. agricultural and inhabited areas)will not be marked. The markers will be one or any combination of the following: • color-coded signs attached to posts color-coded signs attached to the railroad ties • color-coded painted rail sections Sensitive and non-sensitive areas will be designated by the following color-codes: • white non-sensitive areas • blue sensitive area in which a minimum of 12 months shall elapse between herbicide applications • double blue sensitive areas in which a minimum of 24 months shall elapse between herbicide applications. • yellow no spray zone -5- VII. PROCEDURES AND LOCATIONS FOR HANDLING, MIXING, AND LOADING OF HERBICIDE CONCENTRATES The herbicide application crew will wear protective clothing and personal safety equipment when mixing, handling, loading, or applying herbicide, including standard work clothing or coveralls, work gloves, and work boots. Latex or nitrile robber gloves, as well as eye goggles are recommended to be worn during mixing of herbicide concentrate as some herbicides may cause mild eye and skin irritations. Mixing and use of herbicide shall be consistent with the labeling instructions included on the packaging. The herbicide mix will be prepared from herbicide concentrate and water. In compliance with the regulations, the handling, mixing and/or loading if this material will not occur within 100 feet of any sensitive area. Wherever and whenever possible, the herbicide applicator will prepare the herbicide mix on non-porous surfaces, such as pavement or concrete. Sources of Water and Safeeuards to Prevent Contamination Water use for herbicide mix will be obtained from hydrants and freshwater sources. During the herbicide mix preparations and during herbicide application, strict adherence to the following safeguards will be maintained: 1) Water will be obtained using hoses equipped with anti-siphon devices to eliminate herbicide backflow. a) Hoses used to extract water from water bodies will be equipped with two such devices: one will be found directly behind the mouth of the hose and another will be at the coupling which joins the hose to the mix tank. b) Hoses used to extract water from the hydrant will utilize the same setup as described above, except that a third anti-siphon device will be found within the coupling joiiung the hose to the hydrant. 2) The herbicide concentrate will not be added to the tank until the water has been obtained and the application apparatus is at least 100 feet outside a sensitive area. Disposal of Herbicidal Wastes Disposal of all herbicidal wastes will be the responsibility of the licensed applicator. It is the applicator's responsibility to ensure that such disposal will be carried out in an environmentally sensitive manner, in compliance with all Federal and State regulations and guidelines. -6- VIII. EMERGENCY CONTACTS In the event of a spill or emergency, information on safety precautions and cleanup procedures may be gathered from the following sources: Herbicide Label Herbicide Fact Sheet Herbicide Material Safety Data Sheet Herbicide Manufacturer Dupont (800) 441-3637 Monsanto (314) - (3 ) 694 4000 Massachusetts Pesticide Bureau (617) 626-1782 Massachusetts Department of Environmental Protection (617) 292-5500 Chemtrec (800) 424-9300 EPA Pesticide Hotline (800) 858-7378 Massachusetts Poison Control Center (800) 682-9211 Local Community Chief of Police and/or Fire Chief Abington (781) 878-3232 Acton (978) 263-2911 Andover (978) 475-0411 Attleboro (508) 222-1212 Avon (508) 587-4207 Ayer (978) 772-8200 Bellingham (508) 966-1515 Belmont (617) 484-1212 Beverly (978) 922-1212 Billerica (978) 667-1212 Boston (617) 247-4200 Boxborough (978) 263-3000 Braintree (781) 843-1212 Bridgewater (508) 697-0914 Brockton (508) 941-0200 Cambridge (617) 349-3300 Canton (781) 828-1212 Chelsea (617) 884-1212 Concord (978) 369-7400 Dedham (781) 326-1212 -7- East Bridgewater (508) 378-7223 Everett (617) 389-2120 Fitchburg (978) 345-4355 Franklin (508) 528-1212 Gloucester (978) 283-1212 Halifax (781) 293-5761 Hamilton. (978) 468-1212 Hanson (781) 293-4625 Haverhill (978) 373-1212 Holbrook. (781) 767-1212 Hopedale (508) 473-8444 Ipswich (978) 356-4343 Kingston (781) 585-0523 Lakeville (508) 947-4425 Lawrence (978) 686-6163 Leominster (978) 534-4383 Lincoln (781) 259-8113 Littleton (978) 952-2316 Lowell (978) 937-3200 Lunenburg (978) 582-4531 Lynn (781) 595-2000 Malden (781) 322-1212 Manchester (978) 526-1212 Medford (781) 395-1212 Melrose (781) 665-1212 Middleborough (508) 947-1212 Milford (508) 473-1113 Milton (617) 698-3800 Needham (781) 444-1212 Newbury (987)499-3907 Newburyport (978) 462-4411 Norfolk (508) 528-3232 North Andover (978) 683-3168 Norwood (781) 762-6888 Plymouth (508) 830-4218 Plympton (781) 585-3339 Quincy (617) 479-1212 Randolph (781) 963-1212 Reading (781) 944-1212 Revere (781) 284-1212 Rockport (978) 546-3444 Rowley (978) 948-7644 Salem (978) 744-1212 8 Saugus (781) 233-1212 Shirley (978) 425-4377 Somerville (617) 625-1600 Stoughton (781) 344-2424 Swampscott (781) 595-1111 Tewksbury (978) 851-7373 Wakefield (781) 245-1212 Walpole (508) 668-1095 Waltham (781) 893-3700 Wenham (978) 468-4000 West Bridgewater. (508) 586-2528 Weston (781) 893-4803 Westwood (781) 326-1903 Weymouth (781) 335-1212 Whitman (781) 447-7666 Wilmington (978) 658-3331 Winchester (781) 729-1214 Woburn (781) 933-1212 -9- APPENDICES A. Herbicide Fact Sheets as approved by the Department, herbicide labels, and MSDS. B. Maps locating the ROW and Sensitive areas on readily identifiable in the field. Maps provided with the Yearly Operational Plan shall remain effective for the duration of the YOP unless modified. Subsequent YOPs will contain any modifications to the maps made during the previous year. -10- APPENDIX A HERBICIDE FACT SHEETS HERBICIDE LABELS HERBICIDE MSDS THE COMMONWEALTH OF MASSACHUSETTS EXECUTIVE OFFICE OF ENVIRONMENTAL AFFAIRS R Department of Agricultural Resources 251 Causeway Street, Suite 500, Boston, MA 02114 617-626-1700 fax 61.7-626-1850 www.Mass.gov/DFA MITT ROMNEY ELLEN ROY HERZFELDER Governor Secretary KERRY HEALEY DOUGLAS P.GILLESPIE Lieutenant Governor Commissioner GLYPHOSATE Common Trade Name(s): Roundup, Glyphosate VMF Round Up Pro, Rodeo,Accord,Accord Concentrate, Chemical Name: N—(phosphonomethyl)glycine—isopropylamine salt CAS No.: 1071-83-6 GENERAL INFORMATION Glyphosate,n-phosphonomethyl glycine, is a systemic,broad spectrum herbicide effective against most plant species, including deep rooted perennial species,annual and biennial species of grasses, sedges, and broadleafed weeds.The major pathway for uptake in plants is through the foliage,however, some root uptake may occur. The presence of surfactants and humidity increases the rate of absorption of glyphosate by plants(15). Foliarly applied glyphosate is readily absorbed and translocated from treated areas to untreated shoot regions. The mechanism of herbicidal action for glyphosate is believed to be inhibition of amino acid biosynthesis resulting in a reduction of protein synthesis and inhibition of growth(10, 15, 101). Glyphosate is generally formulated as the isopropylamine salt in aqueous solution(122).Of the three products containing glyphosate considered here, Roundup is sold with a surfactant and Rodeo and Accord are mixed with surfactants prior to use(15). Glyphosate has been reviewed by US Forest Service(15),FAO(122),and EPA OOW(51). ENVIRONMENTAL FATE Mobility Glyphosate is relatively immobile in most soil environments as a result of its strong adsorption to soil particles.Adsorption to soil particles and organic matter begins almost immediately after application. Binding occurs with particular rapidity to clays and organic matter(15). Clays and organic matter saturated with iron and aluminum(such as in the Northeast)tend to absorb more glyphosate than those saturated with sodium or calcium. The soil phosphate level is the main determinant of the amount of glyphosate adsorbed to soil particles. Soils which are low in phosphates will adsorb higher levels of glyphosate(14, 15). Glyphosate is classified as immobile by the Helling and Turner classification system. In soil column leaching studies using aged(1 month)Glyphosate, leaching of glyphosate was said to be insignificant after 0.5 inches of water per day for 45 days(14). November 26, 2003 Page 1 of 5 Persistence It has been reported that glyphosate dissipates relatively rapidly when applied to most soils(14). However, studies indicate that the soil half-life is variable and dependent upon soil factors.The half-life of glyphosate in greenhouse studies when applied to silty clay loam, silt loam, and sandy loam at rates of 4 and 8 ppm waq 3,27 and 130 days respectively, independent of application rate(14).An average half-life of 2 months has been reported in field studies for 1 I soils(15). Glyphosate is mainly degraded biologically by soil micro-organisms and has a minimal effect on soil . microflora(15).In the soil environment, glyphosate is resistant to chemical degradation such as hydrolysis and is stable to sunlight(15).The primary metabolite of glyphosate is aminomethyl phosphonic acid(AMPA)which has a slower degradation rate than glyphosate(15).The persistence of AMPA is reported to be longer than glyphosate, possibly due to tighter binding to soil(14).No data are available on the toxicity of this compound. Glyphosate degradation by microorganisms has been widely tested in a variety of field and laboratory studies. Soil characteristics used in these studies have included organic contents, soil types and pHs similar to those that occur in Massachusetts(117). Glyphosate degradation rates vary considerably across a wide variety of soil types.The rate of degradation is correlated with microbial activity of the soils and does not appear to be largely dependent on soil pH or organic content(117). While degradation rates are likely temperature dependent,most reviews of studies do not report or discuss the dependence of degradation rate on temperature. Mueller et al. (1981 cited in 117) noted that glyphosate degraded in Finnish agricultural soils(loam and fine silt soils)over the winter months; a fact which indicates that degradation would likely take place in similar soils in the cool Massachusetts climate. Glyphosate halflives for laboratory experiments on sandy loam and loamy sand,which are common in Massachusetts,range up to 175 days(117).The generalizations noted for the body of available results are sufficiently robust to incorporate conditions and results applicable to glyphosate use in Massachusetts. TOXICITY REVIEW Acute(Mammalian) Glyphosate has reported oral LD5Os of 4,320 and 5,600 mg/kg in male and female rats(15,4).The oral LD5Os of the two major glyphosate products Rodeo and Roundup are 5,000 and 5,400 mg/kg in the rat (15)• A dermal LD50 of 7,940 mg/kg has been determined in rabbits(15,4). There are reports of mild dermal irritation in rabbits(6), moderate eye irritation in rabbits(7),and possible phototoxicity in humans (9). The product involved in the phototoxicity study was Tumbleweed marketed by Murphys Limited UK(9). Maibach(1986) investigated the irritant and the photo irritant responses in individuals exposed to Roundup (41%glyphosate,water,and surfactant);Pinesol liquid,Johnson Baby Shampoo, and Ivory Liquid dishwashing detergent.The conclusion drawn was that glyphosate has less irritant potential than the Pinesol or the Ivory dishwashing liquid(120). Metabolism Elimination of glyphosate is rapid and very little of the material is metabolized(6,106). Subchronic/Chronic Studies (Mammalian) In subchronic tests, glyphosate was administered in the diet to dogs and rats at 200, 600, and 2,000 ppm for 90 days. A variety of toxicological endpoints were evaluated with no significant abnormalities reported(15,10). In other subchronic tests; rats received 0, 1,000, 5,000,or 20,000 ppm (57,286, 1143 mg/kg) in the diet for 3 months. The no observable adverse effect level(NOAEL).was 20,000 ppm(1,143 mg/kg)(115). In the one year oral dog study, dogs received 20, 100,and 500 mg/kg/day. The no observable effect level (NOEL)was 500 mg/kg(116). Onco eg nicity Studies November 26, 2003 Page 2 of 5 Several chronic carcinogenicity studies have been reported for glyphosate including an 18 month, mouse study; and a two year rat study. In the rat study,the animals received 0,30, 100 or 300 ppm in their diet for 2 years. EPA has determined that the doses in the rat study do not reach the maximum tolerated dose(112)and replacement studies are underway with a high dose of 20,000 ppm (123).The mice received 1000„ 5000 or 30,000 ppm for 18 months in their diets.These studies were non-positive (112,109).There was a non-statistically significant increase in a rare renal tumor(renal tubular adenoma(benign) in male mice(109).The rat chronic study needs to be redone with a high dose to fill a partial data gap(112). The EPA weight of evidence classification would be D: not classified(51). Muta eg nicity Testing Glyphosate has been tested in many short term mutagenicity tests. These include 7 bacterial (including Salmonella Whimurim and B. subtilis) and I yeast strain Sacchomyces cerevisiae as well as a mouse dominant lethal test and sister chromatid exchange.The microbial tests were negative up to 2,000 mg/plate(15), as were the mouse dominant lethal and the Chinese hamster ovary cell tests. EPA considers the mutagenicity requirements for glyphosate to be complete in the Guidance for the Registration of Pesticide Products containing glyphosate(112). The developmental studies that have been done using glyphosate include teratogenicity studies in the rat and rabbit,three generation reproduction studies in the rat,and a reproduction study in the deer mouse. (15) Rats were exposed to levels of up to 3,500 mg/kg/d in one rat teratology study.There were no teratogenic effects at 3,500 mg/kg/d and the fetotoxicity NOEL was 1,000 mg/kg/d. In the rabbit study a fetotoxicity NOEL was determined at 175 mg/kg/d and no teratogenic effects were observed at 10 or 30 mg/kg/d in one study and 350 mg/kg/d in the other study(15).No effects were observed in the deer mouse collected from conifer forest sprayed at 2 lbs active ingredient per acre(15). Tolerances & Guidelines EPA has established tolerances for glyphosate residues in at least 75 agricultural products ranging from 0.1 ppm (Most vegetables)to 200 ppm for animal feed commodities such as alfalfa(8). U:S. EPA Office of Drinking Water has released draft Health Advisories for Glyphosate of 17.50 mg/L (ten day)and 0.70 mg/L(Lifetime)(51). Avian Two types of avian toxicity studies have been done with glyphosate: ingestion in adults and exposure of the eggs. The species used in the ingestion studies were the mallard duck, bobwhite quail,and the adult . hen (chickens).The 8 day feeding LC50s in the mallard and bobwhite are both greater than 4,640 ppm. In the hen study, 1,250 mg/kg was administered twice daily for 3 days resulting in a total dose of 15,000 mg/kg.No behavioral or microscopic changes were observed(15). Invertebrates A variety of invertebrates (mostly arthropods)and microorganisms from freshwater, marine,and terrestrial ecosystems have been studied for acute toxic effects of technical glyphosate as well as formulated Roundup. The increased toxicity of Roundup compared with technical glyphosate in some studies indicates that it is the surfactant(MONO 818)in Roundup that is the primary toxic agent(117). Acute toxicity information may be summarized as follows: Glyphosate(technical): Acute toxicity ranges from a 48 hr EC50 for midge larvae of 55 mg/L to a 96 hr TL50 for the fiddler crab of 934 mg/L(15). Roundup: Acute toxicity ranges from a 48 hr EC50 for Daphnia of 3 mg/L to a 95 hr LC50 for crayfish of 1000 mg/L(15). Among the insects tested,the LD50 for honeybees was 100 mg/bee 48 hours after either ingestion,or topical application of technical glyphosate and Roundup. This level of experimental exposure is considerably in excess of exposure levels that would occur during normal field applications(15). November 26, 2003 Page 3 of 5 Aquatic Speci-s Fish Technical glyphosate and the formulation Roundup have been tested on various fish species. Roundup is more toxic than glyphosate, and it is the surfactant that is considered to be the primary toxic agent in Roundup: Glyphosate(technical): Acute 96 hr LC5Os range from 24 mg/L for bluegill(Dynamic test)to 168 mg/L for the harlequin fish(15). Roundup: Acute lethal toxicity values range from a 96 hr LC5O for the fathead minnow of 2.3 mg/L to a 96 hr TLSO for rainbow trout of 48 mg/L,(15). Tests with Roundup show that the egg stage is the least sensitive fish life stage. The toxicity increases as the fish enter the sac fry and early swim up stages. Higher test temperatures increased the toxicity of Roundup to fish, as did higher pH(up to pH 7.5). Above pH 7.5,no change in toxicity is observed. Glyphosate alone is considered to be only slightly acutely toxic to fish species(LC5Os greater than 10 mg/L),whereas Roundup is considered to be toxic to some species of fish, having LC5Os generally lower than 10mg/L(15,118). SUMMARY Glyphosate when used as recommended by the manufacturer, is unlikely to enter watercourses through run- off or leaching following terrestrial application(117). Toxic levels are therefore unlikely to occur in water bodies with normal application rates and practices (118). Glyphosate has oral LD5Os of 4,320 and 5,600 in male and female rats respectively. The elimination is rapid and very little of it is metabolized.The NOAEL in rats was 20,000 ppm and 500 mg/kg/d in dogs.No teratogenic effect was observed at doses up to 3,500 mg/kg/d and the fetotoxicity NOELS were 1,000 mg/kg/d in the rat and 175 mg/kg/d in the rabbit. The evidence of oncogenicity in animals is judged as insufficient at this time to permit classification of the carcinogenic potential of glyphosate:The compound is not mutagenic. REFERENCE S 1. The Agrochemicals Handbook: 1983 Reference manual to chemical pesticides Pub. by the Royal Society of Chemistry The University,Nottingham NG7 2RD, England 4. RTECS Registry of Toxic Effects of Chemical Substances: 1982 NIOSH, US Dept. of Health and Human Services Ref QV 605 T755 Vol. I, 2,&3 1981-1982 6. The FDA Surveillance Index and Memorandum: Aug. 1981 and up Review and recommendations of the US Food&Drug Admin. Pub. by NTIS, US Dept. of Commerce November 26, 2003 Page 4 of 5 7. NTP Technical Report Series U.S. Dept. of Health and Human Services Pub. by The National Institute of Health 8. BNA Chemical Regulation Reporter: starts 1977 A weekly view of activity affecting chemical users and manufacturers. Pub. by The Bureau of National Affairs,Inc. 0148-7973 9. Dept. of Justice- Drug Enforcement Administration Memo dated September 26, 1985 10. The Herbicide Handbook: 1983 Fifth Ed. Handbook of the Weed Science Society of America Pub. by the Weed Science Society of America, Champaign, III. 14. GEIR Generic Environmental Impact Report: 1985 Control of Vegetation of Utilities&Railroad Rights of Way. Pub. by Harrison Biotec,Cambridge, MA 15. Pesticide Background Statements: Aug. 1984 USDA Forest Service Agriculture Handbook#633 Vol. I 51. Office of Drinking Water Health Advisories, USEPA 101. IUPAC Advances In Pesticide Science(1978)V-2 p. 139. 106. Hietanen, E.,Linnainma.a,K. and Vainco, H. (1983)Effects of Phenoxyherbicides and Glyphosate on the Hepatic and Intestinal Biotransformation Activities in the Rat Acta Pharmacol et Tox 53 p. 103-112. 109. Dept. of Justice- Drug Enforcement Administration Memo dated September 26, 1985. 112. Guidance for the Re-regjstration of Pesticide Products Containing Glyphosate,June 1986 115. Monsanto-Memo-Rat Feeding Study 3 Month. 116. Monsanto-Memo-RE: Day 1 year oral 117. The Herbicide Glyphosate Grossbard E. and Atkinson,D. (19) 118. Non:Target Impacts of the Herbicide Glyphosate Mammal Pest Management, LTD. 120. Maibach, H.I. (1986)Irritation, Sensitization, Photo Irritation and Photosensitic assays with Glyphosate Herbicide. Contact Dermititis 15 152-156. 122. Pesticide Residues in Food- 1986 FAQ Plant Production and Protection Paper 77. 123. Personal communication with Bill Heydens of Monsanto 2/16/89. November 26, 2003 Page 5 of 5 ? Re soil AwriT weeds most be emerged at me note 0 In amplegNlis a.' of as at August 25,1995.Ills product descriptions and recommendations provided In this ample lane are lar back �.5'' -^ - a0otarraffobe comrollldWIn.prolacl.WeMsgelmiw- gmun0 ineormddan only AlwdrX refer to me label an me product before usilm Monsanto or art,other agrnnemiw pIMwL ft coq Ilam sem after appltOtion will not N controlled Unemngm FMnM dnynq from uNMenm millror und M 0 aama30r real stocks of pemnnulx Wel of N antelm or me PRECAUTIONARY nmmtme. 00, STATEMENTS ' Tape Mwpq:Thot plmwn does not praise mid"wentundupn Hazards to Humans and [antral wswuem; it N ter amnlrm lallpwa coal- .1 ppra a herbicide program it turf.1i me DOTBSIIC AOIMBIS auNnary swem.k.d an anterA..too Wproriaw In ducts a ll ice ba9 each pr sea ditto t0.A e NeeDoutaltacha![n'Mr<n. syenyt a"directions eIca eaznprolan nmem"C Buyer IDD all users do espOMiMe lot II bis a Nmapt N CAUTION! do.[it here kes w umermmaerlaof ah MW Us of OXDM* rwB.u�Mpsalm CAUSES EYE IRRITATION. warmcXMed n m3 both,Mnind fns pro wmr her Avoid[anta[I win eyes Or(IMMIX, 1I, bifid.Or Other mainah.1 rc[Omm<Med M MI hM The complete broadepectrum RRST NO:IF IN EYES,Bush waA Deeny al wnm.Gill m.- It T may result in reduced performance, int...Uon it IrmOM pmish. Anneal Manmum Un AN.:The cambmed low al M trat- postemergmm profeBsienal herbicide DOMESTIC ANIMALS:Mi'w."is cwsidend to N,M- marts must nm Mum ID 6 Ma.01 MIX m.uct par acre for industrial,turf and ommnental direly overarm 1.it,,dM olirn domeiN dM :A...,, per year. Weed control, maeaipnw mis pr.un Or arse dmowk att,mN,,%W ATTENTION rowed.mer rnult'm terrom"wslwnuRiw'ImRNan ' Ivourifinq, durthM, co1N. etc.), II wed Wool.,Are AVOID CONTACT OF HERBICIDE WITH FOLIAGE.GREEN Complete Directions for Use oburved.provide the one vilhperry Of HUM W prevent reSTEMS EXPOSED NON-WOODY ROOTS OR FRUIT OF daryd2liw.Two armNNa.it sy ,p wn,Her mon I I ra CRDP5 DESIRABLE PLANTS AND TREES. BECAUSE EPA Req.Na.52447S than 24 hours.. I �, SEVERE all OR DESTRUCTION IS LIKELY TO RESULT. Personal Pmleaire Equipment(PPE) AVOID DRIFT. EXTREME WE MUST BE USED WHEN AVOID CONTACT OF HERBICIDE WITH APPLYING THIS PRODUCT TO PREVENT INJURY TO DESIR FOLIAGE.GREEN STEMS,EXPOSED NON. Applicators and after fandlers must weer lolgskerm shed ABLE PUNTS AND CROPS. WOODY ROOTS OR FRUIT OF CROPS, and long pane.shoes plus sMo.Fallow manufacturers instructions for cleanmgymaintaining PPE (Persona Da net allow Ilia herbicide solution Ia mist drop,Orn w DESIRABLE PLANTS AND TREES, Pran[NYe Eewit.wi T II mere are no such mzwniw3 ipe s,IaIh Onto dtmable ngeutian sin.mnule pI.tM a BECAUSE SEVERE INJURY OR DESTRUC- washmas.use detergent and nal water.Keep and wash PPE His orMum can cause swere damage or dmrvmon W ted TION MAY RESULT, sepaniey from Omer Incei mop,putts ar whet I,..an Fhnn tnalnum was at Wpen handle«axe[nosed im,rded,Tire Imeliirool of Injury accurmla hoot me use of mtems.erWwd cabs.or air this p=ut is greatest when winds are gusty or in excess a 'Roundup is a redildred trademark of Monsanto Competernn in a memoir iMi meek me navinmmis ago in 5 miss oar hour or when other conditions.Hirai 1.11 Worker Protection Standard(al far rMoomld pe3dcid. 0 STORAGE AND DISPOSAL ..no veto[i0a.wiUallOwsOrNdnDlOaWr.Wnensprry- TAO LfR 179 240(it)11-611,me Amsler PPE r.uirlments ing.avoid oombimaMw of pressure and mime OFF that Aid lest ttl]BISLCG may 0e reduced Or mMeOed So spe NW'in N2 WpS. De mI mnuminate pea or. foMxmns, few or seed by rlsull in sManer w Me pani[Ms(mrsp wn'cir are tikeh W slanpe or d'sposdl don.ArI010 APPLYING AT EXCESSIVE SPEED OR PRES- Read the Y label before ASH,this prMan. OW -11 i See[Mill tabes la STORAGE ANO OISMUL mbtib . SURE a - NOTE.Use oflns ca l' airy manner nm cons sleniuseO Iy az[ d g1ol Nr nmtlWns { 0 GENERAL INFORMATION ths label mw resp rel ry to dersoms aMIIEI3 or crops or itisa Bate aFde I Yw W ase m6 prMuellio am not 1 5 anter umnitndea oRoences Keep mntnner closedto nM inc n:stent w in IS labeling. R Prouty 0..IMar. no p M ct s a p«u rgem SW prwem:oes anePad lire'LIMIT OF WAggANTV AHD LIABILITY'Nlemenl ,��IM Nmi[herbicide \n no Wil r E n N.11 Owes OmaO - AcedthdmmeuNlNlgebupporusinq.Darman not '- spectrum Mntml Of many annual weeds.perennial Ands, C.O MIXING a lobble.roam a once uwwred, 3.2 En Vironmenta!Hazards - Away rush and Ire..n is formulated a3 a watnsduble v Iimad conwnma 1a.5 percent sudazlanl and no mOmwal Clean sprayer path immediatey,after using mis wodu l q PEFOgMUGTION IS PROHIBITED.SEE INDIVIDUAL CON. Do nal appy directly t0 site,to of.vol Sud.wa,or sumutlnl is na0ed or recommended. Iwrougnh Miming nilh weer. INNER LABEL FOR REPACKAGING LIMRATIONS. is oreuni or Ila intenian ars NWn me mem AWn wale Emimpmtnlal Pole: Wire.this DrMuct comes in[onNct mark.Do at Im lam water when dkpming al rouip. wit;the soil it is bound to mil paNtlet When used in MOTE REDUCED RESULTS MY OCCUR IF WATER CON 1-0 INGREDIENTS men,waslma,ez darn Firm label directions.once this proud is NUM Art TAINING SOIL IS USED.SUCH AS VISIBLY MUDDY WATER /� not dva le for plant uptake and Fill not farm addled viae OR WATER FROM PONDS AND DITCHES THAT IS NOT ACTIVE INGREDIENT {.3 Physical or Chemical urian where Cols grow into me treatment area or if prc oil CLEM. •cwh..W.H{pnwpnwonMlmllalyrine. v Hazards is nansponea Off Site.me slmna affinity aI this prdeun 1p 1 Me sM wnelai prw.n cols prMan from uacnm our a Me 6• Mixing with Water In INERT INGREDIENTS TSImidYldmentsed-. _59 Mdl Ov. sol pmlde aM entering ground wafer.The anindy btNem TNxpWdun mines«MIN wind want.Mu spm.,..n,.1 INERT INGREDIENTS(iMluOenpsMazWtl: ..0GG% Spray using o Of InKWMutl alum NnuW,stormaM INS pradu[t me WII padkle3«momi imul this M10q IW 0 applied p uxmq inM Steel tws dluminlnr.fiwpass,Me pr His OrMW as Id owes FIII me midi Wk wM the •Combos aea 9nms per 4th pr d Nor plu,ulinM steel conlainm. aepveea,when n pnrwriry a biolopiW degradation prrcess ry w spray Me Ui ingredient weM3 pm u 5. .d nares out under both aerobic and anaOMbiC Conditions by required amount M wane[.Me Ir n,oln.shat a pt to 356.in me For a or 3aprapY- 00 NOT MIX STORE DR APPLY THIS PRODUCT OR EL OR sou mumoi mei Or A near the eM a me Iran,paMe53 YA to wm. imine son.E Of Me 110.Me prams Dec Wen]p.nds UNLINED SOF THIS EPT IN STAINLESS STEEL) TEE)C STEEL OR Time le SYmpleme Thn product mows through me pant Remove nose Irom me lmmedweh aver Male li ry std per LL5.ga.S oiii w d 4IT S Pa , UNLINED STEEL(E%Civet rSTEEgimmus 0 e, nwaninq track iota 1 O toner murte.DUNq Minna r. patswnduning.NO edw1Manornl No Olde Any Haft"iti OR SPRAY TANKS Tors Containers spray WNNws Mm13 Vammepnts al foliage ens,any..Wand Into, met"band,2to , v.MOr ural it of Hold the we oMmayo¢ub TYDre Plasma ranging.Na IIRIN! led WIDm hydrogen react With men eta Cwwnm NW Will Id Freddie Visible enecis an mail ant Wl w.as petal wirnf 21st d van irate O pass and avoid the M boom O alar, q gram aW nw-U.S. Drod W' Dalemtlsl. lure,gmgas wnitureo Wrmaor ex Mmbusalleaazltnu scar Nl onmriterPlor wells mdyth I.H.ccur r]rm and If. ad,uaniASreturnpplines ormebMom ameum lure.IDrsysy,it i W O a MMM.,nusil AM,I - w mare.Ed<mey Coal f clovity weamm ldelay de Intl-' ." ii nemta.fru N dDprwM No-Iwo w del0arnirp 2.0 IMPORTANT PHONE Mi Bel iniac d pmltd W own home spud rmmns mol may stow ankiry m mis or.u[I dna arae develop agtm. Ia«n.lightea a9areN Or Omer pni4on soma. man[aowml symptoms Nsime effects ane art.c mpete NUMBERS dna ymgsHng al e g pam glom stand me m compete Tank Mixing Procedure DIRECTIONS FOR USE ordAwe of mwagmuod growth omit denrmnuan a 62 9 1.FOR(NSWIILTIligIWTIoIOR ASSiSiANCF IN USING undnpmuna pam paM. THIS PRODUCT.OAU TOLLFREE. nHis a almorlaiOn Of Fin<ry MA to usemixprMou in offer man- When Wk raning. ate LW well 0 IlMtna ma la06 1-BW�d114 r InConxi3len,with Ik Neelin0 Por mY repm«mtn13 ipe- Cu1N«I[On310s«Uen3:PMUCM Cannot Cry result Aha CNIm3.nuNdwry Statements aM N imfomeWn M m1 arid lO your Sped or Tribe.COpxW me addiry aswnvba lar apOli[anons are made to annual or wrenrial'Adds that Nw lapels.1..orad..us,.Md cot Wt ovist prMlM a me 2.IN DISE OF MI EMERGENCY I1M1LV THIS PRODUCT.OR di regulations. 0<en mowedgrazed.or cut,and him not been allowed to Wa M d mo he me do,MnA.aai.."Oil ml TOR 3®L'1LA961bTAI( MUCT.MYDI NIGHT, region in ipe re[omirmile swge fo,trenmem. mend.amount 0l nes prMan J-.04jpµ40 Rainlasloi Heavy rostra soon after application may Faroam h Ma good ag,wage at MMa topes used UH etmas me MIX Prmi on of the foliage and a repeal apDliwn o man be 4nY are sprayed.N me sows,mlelure i3 alkw.W lame. Immi lar ad"..,.m mr01, IMWYgh mJNlion rwy be«QYiree to re3YswM Vee mature bolo,sprWN is Fri And W-Wss line m Me near lM WHOM of me MN to more, SIBLE FAILURE OF THE PAST. TM rmintmaree m an - Mia only me amount of solulan ro Mused dung A 144 8.2 General Noncrop Areas Mo.passing Scram Viae in mate me line sminele should o,Ma[When,tPa.)which..eels....s pace spmMaMn Wooed,as reduced a[tMy toam ry result to=use of lmaver and Industrial Sites M no rmer Me 50 mesh. SOL C38,O may prevent corrasion.To prevem corrosion of sdiumme Clean Per oars immediately after along Ns Always predeldmere me Madfi WBly M labeled bank mit. .[posed pads.Nami wash MrCQft after each May of product M hero oday hushed wm nor. Use is area,each as airp ins. apartment Madhaes. - tures at too produce Mm water Wm;.1 by Mixing me pro- spnPng to remme residues of this produd accumulated Far Rope as Spark.Wick Adelvlm—Mia t galeal Of mk Chmlmas Nee liths.Into mond.dry mlchn.dry..hats. w..1.1.1;..in advance. dune,Voneo a Irom spilt, imMes,pear ate most hallow in 2 Fanms dwalvldpeprn,GTMmentiolul;an: Minicamera.gall countsilwasieal spin.Number yeads.man. Refer WOne'Tank Mixing'section of GIENERAL INFORMA. month, ApON Nb Kronen A wards listed in mu u[tipn, ul ...a silosam[e carr s.orWr eW nuruMs. TION-for pdstwW Oreamum; Ground Broadcast Far Pam st cApplluN pdp f.ed IPU v Maks.panting aha,.MNDWum Wk hums and pumWng 7.2 SaNnons r m Ira.]J to too WaM a this prom in iasullmarm nNdads.naea!rpWl areas,residential areas 6.3 Equipment water tory M used roadsides.WhOOK storage area utility wpsutianx,ware. Mixing for Hand-held nous.areas.am.,Worn ane.and NWm,indmiml and Sprayers Use me IVddmmded rates of his prrdu[l in0 to 40 WMm iMT.�nPpkd Wrecdnmeldrd.lhis OrpMI CONTROLS the amemp M. of nlel p wteda' ad AT Moue Me spray solMmiusl No Carr.volunteer SNlnam Genesi est May Me usd.opOtedgeompropan It Ramrt ON he O whose at spray solution by main,.g III...sedmvin m weeds m[rm lid amd, whim.Seoul M Pmkum.ions Stable MUDS IDT,apupo tory M used in genuil nancrde cribs.i may amount ut his pmdua in water as shown lift Ne tplla.nng increased C min the oint Proper tarp.l0 mime compka Rye.[outman Starpur.Dnztry - be applied with alry May he used d to Mrs and-odge, described in his Imre'. Me Oust or beef helm OO gr pme,10 avoid q iry enb Sam Selodan line mist For ontrnsuChose ground appBtatipn equipment. When appl Pubje piss ncrop toryorusedto Ientt of Up around use Ant ion mates.Cntth for even drurioufian dl spray When naso az razammended.finis Product SUPPflESSES nition mmn[em sites,un wtthea ds of umr I- v o. d(aplels. the IDI pXing w!!m' nation aro Na dIs or mI talM pangs 9lhis Pr du t may e d.Raba Ragweed.Wmman IimrdsnmoboMarpmanlmlaloNnlinpz.wiis Product may e,garwee a ran(anon 1a pknaTy M area 1D armmenpH.noweR.Par g tGil xa 1xp zW zxW SHE 1121._ 3 Hand-Held and Bttmldmrux Bammd.giant - High-Volume Equipment Dogbane.hemp Shaine,, cauv(raft aseed�or p,mnn kprp a,pnan Or Mgimmg 1000ed 2W toil INWI 2gal 5; r0 yah DaglennN - Sunni AODM la le 0 m ve,evNm N Ce t pray ed.Fa aSamed Gumngrass "NO.Pink ..INS..app M. al ma DrWucl nay M helm,u wens Hans made an aspraytd.Do basis.spray In tepve.g<mauW Jild"em us Teiedemug de.mntmambreVn- m mire Fwuvi mans Of Sporeftthisan.nN be Mind net Me man Ms.Nrmand....ampiele.0o not spray In the point alrvmn. MnkwnO Vasdgms This rira 11.11 nMIS fa wr1110 trearmomag apron mended..aunt at this pMda[I be m with Watt!N a Uu[Writ sprays my. Ni,MSmoL 4Ntneal V<Ivetleal Reler to Imu p'oau[IS NMI,IM aoDrovM nonwD vin dna krper CCmtnec Fin sprryer with the rr4ted,dation. PlgwaO.redmd dpapnppn nen. 6 4 Colorants or Dyes 4 Selective Equipment ARSEN0. sIM/ZINE y 7 7.5 Injection Systems BX L sIAm2 NF,L AVOI.N.lryapPm mlonnH me ma rine dye,nal be This pmdutt may mappom muted sar re,pnpxpny m' omRON sM NE BOW r lemx.xnalava appl;Wlprs.hobo..sprrym,w,pe,aooMt mrs praau[t mar M ash m aerkl Cr gmpM ini.[lian spm RgWAR-l SURMN^a5W added N MIS product COlarMtS of More Bud in Sony ped- Mrs or sponge bars after Iduten and Mommi mmg MINI rystems.II may Me used u a liquid cmunarale as a2mil KROVAR r SURFINI AS pons of this pmdm may reamn pperm o.nmeWl,at wade Io listed weds Malang in ala mnua,silo sPe[mp poor I.iniec oa colo me spmsterml Do nm mi,this Pont- OUST TEmA^ Iawer nen a,IMP....Use CDlamM ar dyes a[Camimi Me ..this WaL M e with taxCOMtmm�at amen paCducB Mem II lnR[' - PHINCEP'C0.18ER'-N 2.-0 mmulXNnrs ee[PTmmmtipm. A rKn[ulalinto spray s)Slem dirKls m.,pm smMdm Wm - I;O.systema. RONi Shim ESCORT �7.0 APPLICATION EQUIPMENT wards gmwin,Mr.dninble vmemtoo.venae sor,SIN. 6CDA Equlpmertt Oust mrMmand zea are mmwn may not M accrued M soon • don not lnarcepled by wards is conened am mounted to and 7• eanorn§. AND TECHNIQUES sprat bank For raMs<. The rate of Mrs MMm applied Per acre by Contwlln do-Plea TM dream s mat all morm Me MAnew m pass'-.n Do not alDM Ws andun mmmn am yM of Vaginae M' A,hided or handed APPli[alaraind lee hiSolution mMlbapan mupmenl(MAI nndsmil hued nM M rev Wes de.hw. I. and wens.wNle Ouldb,dismiss vegeamn Irom me me amount n[anmendM in Me OW when applied by Cm- lenn WnenappSMas alen...ork .0 11 .,ad,10 AiMo.'.1 A']- AtNPNe, equiienal M Sites 3t equipment15rioe,par for Mepai, LDA race Mand her in NnNpeO annual Meeai]N..mepl pr Wmwl APPLY ANDCAURAYSOLUTIPMEONS INPROPERLYELIN Ato tin yraeapplimtapralAds themmmb.p m.1 edui0mml.appy Jlo lSgWons al rater Mr azre ..nom of.mea a tramew weeds.woody birsn ala Ven. TMNEO AND CADBRAl E EQUIPMENT CAPABLE OF OELIq- d. pnld mus by a mind tht wRd with m abxaemnt makMl LDA epuipmem prWMtes a spray wnem wnrcn is nal..Vila ERING DESIRFO VOLUMES. Far meNd m WWI[mhd pl me ldlawinq Mnenrval weg5. ..horned me nerbicbe solution. vwi0le.Ezheme dar<muaoe enrnsp to awb SpnY ar drift 7.1 Aerial Equipment AVOIOCONTACT OF HERBICIDE WITH DESIRABLE VEGETA- command me toned or any Omer erten had of dpmble ;ppN npiaWnsal vas educt plus 2i,mnrtimOust oar TION AS SERIOUS INJURY OR DEATH IS LIKELY TO OCCUR. vegetation.as damage of dmVmdm is likely to result ate mnrapwv JamuWaus DO NOT APPLY THIS PRODUCT USING AERIAL SPRAY Applicators used above diamond .,our,.. should a 0 SITE AND USE MrmuW,rn, Pwrpe EQUIPMENT EXCEPT UNDER CONDITIONS AS SPECIFIED nexted so that Int rowel spray dmm a wiper Wnfazt 8 5.......antal OWdmm WITHIN MIS LABEL Most is il east 2 inches eco..me desirable RECOMMENDATIONS Droplets misllmm.ars vmeuean. 0.1.Mrs Tmmp,.,, tr FOR AERIAL APFLICATION IN CALIFORNIA.REFER TO THE Din polar al the Mro;c;dd mluhon set- pen;lm bnlm[oonx lallpx tpAaoaiMlly.o/sale. OWkmN V. .,a FEDERAL SUPFLEMENFAL LABEL MR Pot APPLICA- omdnlnolevmamionislikeytornullindMobramn. III ala VIM.,WW LIONS IN THAT STATE FOR SPECIFIC INSTRUCTIONS. :hooting a Msaue.m. UnlnsomersommU eiDed.applimlim,mryMmademcan- RESTRICTIONS AND REOUIREMENTS.This DrWua of., Be.,,adults may M abrin..when mord W IM wem O tou ala MCNe listed In me..neat Mrenhal And Mal m.mlW mixing MSP,mmrl^or 2A,D tank measures mar nor be applied Deposed to the huWcMe salmi...Welds not c.nWed by beam MVI..Refer atv to the'SELECTIVE EQUIPMENT- no pmdm'WA suaaes,Mmmal onnn.dtld in me smrdn WAhU".O;A W ammocoe solution win not Me affected.This tory motor In ucaonto nrve u,Vain..,lar rmmnq.Use a Hua prom hnNP.- AVOID DRIFT-00 NOT APPLY OVRING LOW-LEVEL dmse clump,.Wo inluMmm or MMn the nightact Mrs a[n'iden bond W trscn.find MOM..m[wdaaa,a Cut stumps 01x4.,[earn Use 5 rums..Dead m mm proem pro az,. INVERSION COTHEROCO WHEN WINDS ARE GUSTY OR weeds nrrcs w mal real all weeds We mnaard.in mea 8-1 P ..1,aldp 0.4.11 mo....Pro 10w20 W. UNDER ANYLY TOCAUSEO DHW TO My AWAS DRIFT. Shielded repeldedapplmrybe necesvry. Cm stump wommnts tory M Mae.on ala Sit.Imrd an Ms ions m Vary..Mr.to CRIFTONT 15 ED TO i0 CAUSE AAM It TOOT I VE INTENDED. TO SMaaa am hooded appll[tlon aoel.This or.m.11 cpnlml many ryM,al waber omen CONTACTED iD YMCA ADJACENT DE IS NOT 1NTENOEO.TO Uu nntln IMI proaNe miNrm cove a wnn;n IM u.,w and area ,air.sons,al wNO ve Aslm Allow.ADDy this Use wy in rreu where Mme Memponry iNMrY dr diupl- ARPVENT INNBU FE ZONE MUST VEGETAOON. rag prnrpn al MrennW gnsus Wn 0e 1plented. APPROPRIATE BUFFER M my MUST re MAINTAINED. at.a bap iniatio m tone semen MUST XE WMm M,odun me suiaale evil..,dMWO ensure cmnrtpe pl as And dire.applkatimm TO AVOID CONTACT OFErREME HERBICAREMUSTBEEXERCISED ft.rt..mean..t Nenaresar.gastro tMMil Map- TO r- gormandudgmv Ly lady dl girt. TOAVOIO CONTACT Of HERBICIDE WITX OESIRABLEVEG freshly cut a5010 Im Mrcenl SalerrPmlgRDmdMa loan - W,prowl tory Mused lOc a, pesumrms mind,Ne rmommmdM nits of the heM[IEe in]to$B WF Eipm,U dium.ml suNu imme no after[onro,paM;n result. - ler mobil Meads and tau Sam lar ene[Irv.rotas.al dV Ver Choi nla are 1.1 WlPereiallmusthe dapmgeom [allonmry rami meNM[Nurng Paw.For Ma rgr l m cel Mrmudagnsx ala mhrel. wa. Rein do les. CWm,pm,,re Ins.h N dnR menton,da ml uv Equiell Me moil M dnpne4 om lam..MW d need 10 amid full mx NauM M made dbnp MXam of aaiva gravM -ROADSIDES ep am al WS alai.MriN pilon nen IW o0r- rwRln arnoadl Wnfi mnm3 wfliN d'd - M and luU kit etWm'rM. mini Mrmudapnu and mn4,rav VWDmm�.stmt Or'ry n pMsdspma,Me Mmme.(ha Mrsdq mdn Wad Ore..lMe no no Me, So wnm NO is do,..[and p,iOr la mug C.P Lower dmSaid d M dangle ndall.s Idr by into me gram$.OMnle INV mance a al prop ends no grad , EuraryDns Senrosm T.,M.lS A tuns at 16 MN tone,W And My than urslream ma da nal'utcreue spm vmume by iweuino man$man Performance Way,nW tory ta imp tov<a oY rmu[inp mak ansur.. samdwaeu al Mavy,wapinleslalio wra ensue ldndal- IfiOak Ties Dela .,injury mu.anpm m NOT Mill, Rcross.such Door or ..pdinesmry Mustd..ft.drift f..,to w.a vWnoCn&annulieor,Mooainp illippliM- Rea W;Ilaw dad anda Mae OwtMns.DO NOTTmad ank Vxy .a liven anal.Nad and nf., p , tly .WWIry Wim - Denimr�der dripping Rate ms. Rep.prmd Inn'..atop Main nwlw maimumd N,lgnn dna:. Wenn lob m.,her inlpema.pn mMannp m pro eddiave AvoN ka4pe a dripping anld dnirabl.vmeu.on.AOlml RO NOT MASE CUT STUMP BRUSH OR TR MEN THE This"nn ommin laML might W apPk.Ml N ensure adequate cmtul wrm weed, GROOTSRAFT OF OE THE ROOTS WOODY THE OR TREES MAY BE IDH aedm[..hots mm heists,ummnm poor 10limo- Keep arming,Mmcd dean. Be aware mal. m sip GRAFTED i0 THE ROOTS OF TME CUi STUMP.INJURY Nn areas.Fa mabmum[antra.1.-SPIN rm- Ensury unibrm Am M.pa1—ip awE." unrvm a mm rep, gen [vrMpprd appg[alidn,uv appr ground.dw INrb;[i0e saurian le.Wus 0 RESULTING MOM DY BRUSH OR T IS USELY i0 OCCUR ..PRO PRODUCT TO UNCOATED man mora Nq nppvp Mind dray Wmong to dnermine U ury regrowue M1am STEEL SURFACES MAY ROF ESULT P CORROSIO AND on.....MaMe wo and drying of ire wrctrmthe uDMr nb of IN ADJACENT WOODY BRUSH OR iRFES. .scam Pro.11 11 ,Pddraais mqurs where rto'V-d STEEL SUSFACEB MAY RESULT IH CORROSION ANp POS- Do at 1..ml1 mems Ne m[asvry.wMn.nl rcgrawln mud M aHapl<0 M nm use v.Mr nbipmem Moen wap,are war. pew to appliwwh.For wamleeudn ghaads wml a GmnMdswLad.E . dant Poe ere UH Me older taus d Holl induct N con wont. Julnsagam DedmmHms,summa!ec la appfidMws poosMe w 0M mil Poland was H MM to mwd W i gr.M N all will annual wells Ins pun 6 ilbAn N Mapco(or amu Bluntem,oder TMMWUu clmrd.vvi.$to,Uwuw is glaMng.nd mwM a.no q,.no.all shaddhooday OdslMle room "in)Nat an lRtM in Nis fall it Me 0M1 kMl Use Ne FRa.W V.HrgraH IWg.H maapwcoL.PM in.PM W Net.Mom a must hd H imam dun appfKallpll dna M dincin i t nyhef nm IS.anMI Wnde In�HH N AS xYJ apDIDYII mND1.YLt maYD[Wk-m4M NMGML I1Lal'llm[d.UH told Ushon"Nl Awing to aide wNd[nlpmNlA lw good hg M'ROM,ors w Nape.Tame a aW l�W aw'ranot Ad Mo ton l ro p Aims of ft PIM=wily1 W10untn inlercpold d Ne Story, lei noel IN WmM ON partat Mhow d Ne rolown,PoIMnGI MMS' II Oval par xn.UH W boo MR d with prould W[ln wnnaMunewn Ma[1pMmdam DMlIM«eDmla0. O.6 Parks,Recreational and B '.S FeeM°'W IMI aw"d"`este Nast Nan 6 NMR b Mynd(«Mnner OAape«nlwatm txMipllR SunaroM.mwMy.M v BndDem JMMoryw Who)too an llaW in NN NOtl all ON WN NEN.UH dN NE .or nMSRfan,shout!MotlNM MT am all Mdkwmb Residential Areas Blunnm.SAW PMdn no.hands a an UM wells W .k Sw all sardi UNaw MNSkphou iH IiNNynor Dda Pwla Brouffird a Rawelry w 6o.0 w=shied.TMH)Wei wW aw prpride mal photo holy HnM in Polk.IwRkrnal alld lalaen OewEerry TMmprnrtem IVNd."dw tcUp,PoralnM MMI 8.3 Habitat Management W. ."may hN Eaviddlo "a°°BHMn eNam w Dn" d`Sony Yaeymaa Bancprue Juts . 9 dm[wM in Nis bDM.This podudmry M osM N wlrMl Ilopnnnn VeMln.that aluatem,N , PMR. Mg.wMnd ton.Ards,pads,wound to Me,side- M.DIM nadntla.nd mall/.m.a TnUggoUUwffUAr Moa,all d doods;in Ned an.Tris pound IMY to U wry m I muM1 Iromonly on Wlhe trdmNwm,W IepMxN&r WI oxw B01 Mw Toney ow Tris Pnduct mry Mush roMmld adiPWONec undo used lorspdvnNwm 0YmwMIWUgMa .Tani prang Mdu wM[MOwM.RepmapAwkwnlllwsailatsm OrpWntl MwvWMDIM conk mmkon In MOM nlalla0enunl aIle ndi SUR. Ilny M used to Mmwb umW W wells plowlly N ewb an,our mommrnd R.since saroae angry lay Dour. FdwM.W Ruud,rM«IMd all.polio hunign.Apel CMM InhM SMro OMs«awmmm pWdlyl.TIM p1MUR Ivy made to Korn arasery of name PM speck.SM«ro P"- M MM Phan Ir pNMM Mam to..on dDw'w.M- ^ 5 UH MN on wellatsuElluled b... ghaa.BMndogras ll ad.ntk Miro sane.and l«MmW awhPoRMm tons hold w HMI.« a on.n*ft a" Regarding • Roadsides Ipury may noun Ionto tr I'd lewd wW dawn dM'talpn control ruuiMnem.SMI treannelln on M coraswfEM pnpm, At of w wWdkna in the'GENERAL NONCROP ARFAS .Wer nest condition.Rendu applkmvm d."dabs IaH to selecYivey lnlmn lwrantM pWn for Now man Ad dw institutional In NC'GENERAL NONREAS CROP AANO INDUSTRIAL SITES'setlkh appy lD nationals. kwHm Hasan.leMmponmwWM.suM seron kgury agement all enhanewnt ANO INOUSTRIAL Sar a don apply of pwk told 1wn 6nMmar treawenb on,)cur. 10I1111.And plan aaohdtom. Amory Omwlnp willing." This producl And,M uses a.AS DaeOaWm Mmmehl mos pIMMI IS,M Med an MM shaman.M may M For suppillf.Dl rogdathe gmth and seeaheM iMiEi6Dn 7 Railroads SigliM With mom swam,shiemM Dorm apmm.hyo- Porro plMand to lou this.roryxibfilerou specks $' rdumeon-umer nrnlm Mind Mal epuipmaM and Sinar of tMuwas lw apto 2S galkid,0data.espy 6 Enid nmMs may m aidplantedaver MPNMe Nn pamutt Ore Us speed 1 Nntoluol S10 to2SMAnns dwnhr Per we.ADpyt AA of RA amMwmm in w'GENEML NONCROP AREAS nuipmMt Illry to allaMdlO aepoplMew ands.If kingeisneMuro pN01NOIISINIAL SITFS's[aior aPNroeeilloMs. 6amnlf.and dE.I dOu.daromoMH heyNMalm3b rlxlhR.Tris�pplbtlM MmMe alb trepans onions wM)daysrgro Mwmth Mom triage WolMheM throw e. ro woes.mnskaMn aro Underground pilot pvN. ban"mall.Hllap and 6Dvulden.C1Pouna.>m Spec min plmud do,r M usM to a it wads OMdM under 8.4InectionandFrill nil pr guwdaulsand wOMasynwinMOawruwMo,w Ed,wwmsbnupro120 wardbyaappryl6uWo A4had M'I man PIMUR mar,M wall b mU�Mn ,0 this M no- m°sme drandy ,ere,mdwM by t n.Make DI z e 1 loo `..00dy Brush and Trees) aad.nN and sad.01 Repro to indM9 d Nis puna. and w.enam f,fli Por due atom Is day nV+.MW oo Pro tlIM z uhi Ills/Ile Uad R MMS<o cont of mehlnln Dwe NMnd, A tlk hood PoIYHi. Trisynbod orMg bonds N copal And pr dull tom Meds This D1mud 1-%b hau to Amin NII Tris phisroof w eMr De uhi as a spot trawem ro cOMld 9mMM wmM ro ulmmM roPohmn pIOMIy M«y IPodMads. A Wt nwun of this plyducl dues Oust mry M usM.bPy DYNIMMmdlt whothiroud now .w.in DMaYRMkIpwal. I"pddwy nowi,Annige pU,A- , Fir dMdlM«ede mor anode Moots 11 Dtlldwir, Pin OM MneMol. pw aw a111.lut whkJl mud of Add and tlpe O.ing 2 A 3 lost o N Ri alwUS ansdlwry.Far do tint,ll Mud.This Tall mlmm tore l ID g Metra roper' M inMal sptop Ilawnly.Make Angryinn hale MUlvalent d i w al Nh wMud(D Por Tam S ro l UP produd yMSo m spm solution Por f l g MM.This hob hproof.ewn,mry,M n.itW www ldbwNp Panum nay one ap0laHOM Po1Ym. adurni MNppIYdela O souAIS Mym(n6N).hob's cost paMUflmryM Wkmdseound iDllwdnI,uu for ma Mrumea,puamrMl.spot vWbad pmmMa&tgEA WEEDS CONTROLLED INSonODra ,Aa50b1110 Pomace Ud Rod"or US WNst,MMNV,scot Dan found Md uoniM lmlwm: 9.0 dis pMdud'pound AS M i the ho pW anund whew a ARSENAL XURINAR OIURON PRINCFP CAt1BEfl 90 can and spew wound.I Mea color M.aamMs.k NROVAR SIMAZINE 51 ores OiamNdr in«eam in sues.DeMrlmM we xhierou tri gMrvEL NROVAR II IWOVAR II 51ANZINE 60W AIea TM°�Mhw rue of Nn°I°dd pr ave PAM IM apPlylM cued nWMat ora Mntlnuous Moi or..,No* OnORT OUST OUST SURFLW]SW god dun well plwmnrunna Salinas US Sign cu".Awad ipplkakrn Nadnilun IM atow, ESCORT. SPIRE^ weMsan growing in MumisNmM lMxWwaMJ dna WLON^OA TAW RONSTAR SOVIP SUPFIAN AS _ runoff M own tom ukd«m um in spe[ks M allow, GARLOR4 2.4.0 SIMAZINE E.10 vM MNm FReffand no or SgW�mg�gMg�« Hp Moody.I.,andel HM a f,Ina Ne trW or Mn a M MAI Saw GFNERal NONo10PAREANAAU INg51RVESOFT long.Pyle W prmuna[MObp anw and..100 pts- al d Nis NM lir genual iSAMdidmw Wk mwnp, Mallow mamNA lr aauawwbtream 111 fort cohanlaakM d Nn pol For Wrawly,epold, mil pmuN N oot inward lw m WAR Marshall,Eaton« RMecrowfdMnkpNDtlswbmWncomnwmMruRM- if.andwIn,had.dwnp Muds as Sene pMMa h volMTOmon in California. Rekm of Bewuapna m dahlin" wcdnbdllanmMaW puwAalwvWa wW'aduy DMNI«Il MR IHS eePons This porOw MU dool art speck'. Bmh tote I Oewad.,11.11pa pm.n,a.ft HfprNd OerMlaal Mend and Huy null show d onto AS land DWdn mil around Any H uaa ro comld wordy Mo and Mees y��pmy�uy�g�jp old lm�cMwelx�elNrovlw Ml°w�al «�rM im�'Bart pMxe�tla 0naud llpM LODlrpl 00RlSURMI M ndlaoM lipnn aDway.Appy 1 to io pmts of this.D0. Ali dowip�w ordwlmnl MllnuOaprm wEanWlaa.ilmmNMlM luhR m 10 pwM W xMM enMMu rmWi Oa BNapum leis nd.n VP to SO Plant,0 spry sW pw xn mry drmnm and par m splits greawp.Tw wuutt mry Asr Sawfuload.gual OWMM M rHd appy a v1 M z«r[enl sdMbn d dk«Muds M Wk-MW woo God Ito hotrod MnDK Took waWr. 9.1 Annual Weeds SMmore wN.s. whM usiM hiOh'ddww spaar-rowel agkakMe.copy a 5 U,M product with OMA mry Mur gndrup. Sycamore Main loo UH 1 M1uwd Por ere a wells w W tlW 6'vches N IHSH to lO PormasduMnal ftPrmudwMn Ming Who Hume For and ldsuMm Murder MIIUMs.trmwM pWnwlna or harder wad Md 1.5 town Yea xn B w say Mv6 8.5 Ornamentals and Plant dlaevM spray W aid M.men hon wmmt Icor D. M growN nq(Hbw 6IMMshh y N n« dN nm Nurseries,Christmas n°[nd wnh Ne MMMIIg wMUw l«enMMM WnMd d 'ewimlM.for Mel mull w W leSCM,Incl tondo 1. EknMnduld«Mnkorl. pl«.nM wlMa w+aaDwElp woody Enatll all trm: all«Erylhd w 4 ro Mat Nap'. .mea HeHM[«mtlilns. Trees mum GARLON4 Mo"to 6a num Mnm of els pww floor wemM or k F«Spm-l>Mlappokaum.MON.NS pwRn sdmknd ESCORT TOROON A a Wk mwuwool 114 w111101 Sino'per wad Oul Appy w dm Poona ro wads las Mad 6 DNMdsS MSM«MnMr Pmdlnehd TmwandnlH WRLON 3A re[wnwnded ntnk10roz5Mlbnsd Mb NM.APpyon.tousuneMlMMDonNOnas«dblrr- mis"mud mar M MM a a Pal-0dMM spry wMM MN In ana5 Mlle EN toxin.«Wllynp owe 0ndlh W.A an w°a°Nal wells. in Mad Mora wan a i«MS esNEfmMa wordy rmamamN sPocim sUM a aHdnake. mnpdm«1NMnpisWMlw ate wily AReM.Escdlw sok ynrnd omen and when some Ulundi in W.M.wOddwothar.growing undo slanud fpllaDbm. TrmM intafhania Iunw and IRe.lPommsdulron. able. Andurs, f,agk,euolrymus, n,odMkS Po, crb.ioo coo..I ..To)old darya b pramM and opt.MPla ASK,wwnpw mina,as AS pun. pewMa«aa yN IlMwue ahlgry.add M ton ld n l Mm.0 Por xn HE odd.ECIES optic and am row,no transit hon ado to usM ro lm vW Thais«muds may Now dy Wdro'll UK lly Mohd awry oo MwmapaaH am M mote and 05 Mime d OMt pR Mnoda spurrM Cora' Mpe wmM notedstaut.r.NataOd tom fMda pdnM grrh all.adobe Waal Ito to 3pli IO HH dPMAn w'm uftn rteindonmpallmnN N11MNRo pR49R BM%' rJWd1' wenn am owl Mry4p a nary HMP. p1rA1q Mmlmanaf.bpd 1 la]pion Of MUS"M N m a HmEwmMl condition. OesuaDbpWn mry HpwMMsrom de swrysdutlonM wild 60pangawn m ,W 6xn.in We ARNaNglwbpNwuaema B�e1«ehp Cppost!' Mang Mkma«meellm mead IS NOT REMh RDED "ad Muffing alMusMw6ktlman MSM hw nm BNanyltNude' C.PPM ,Vk&4 m Fmain OR DAiOV PROWCT ISNOT RECOMMENOEN nestlMgd.UHwNgMf Me U wendsandid- aye« Annual RlhnMWoos for panWly[onpdw* WMpm.flmull' fawd. M.VWinN FON USE A6 ply OVER-AM-Allo BTREES, i$illy IN a Nry appMaM INwea«HMMad br W..k lllp hands ground W PonnnM weeds Ito to 3An ukase ol a US Ali Mhook Cori' ORNAMEMAL6 ANp dof seri TREES,GatMud M sliil MSl pomi°e PomM<Mtrd alwbOw'np prWniM grown drmuaann.IAoot to S Sons.deo p1MMl'n Ali IonaReDwtl• PelNlMroadoid[ooNdolSpfry.dull of sMN toed lenge ipetki: 10 b OMAR,ssdspld Hllroa pat xn.Uww Mm rale BmM,00why' Gitpam' Marvin hand RndisllM MuMmulnosed Barial. ,NMloowad o oMMDry.ft wee.al So akMSlm USoff rvn Brode,Japan.' O'waMvtlebn' an......MA Blu...'per TMmpeklap« u Nry apadxh owe ar uMMM trmukoli meH otos BrwnlM patron' FaNrn nlnnapnu' Tris prmuN may H vud poor b DWI'ulp all olluran., Fesm.W Vatrypnsa oda- n aim PamWe parol MnMO d w M.*, to ndM GAU1uAg wi Fg ppwanml' nursery or ChlNNus tad spMR, man PrmMl lay M WYmuM war OUR.If WkmuM,Me am.: 6un6wpaMfin iMHdatlWa' co mm,dm to 3 don 0 No pill.wool l to 2 nuKe! WEE ID SPECIES(cassa eM Ween Spsea Rate Had-Heb - Baaeaat Hatld,Heb Me lime wdpd„nch Me productk aware,states. Faiwean.snblNeed' WI,/tkLseed esus' (OTIA)%Salado, Wad Spepm Pao Spnry tnWd weaMa nedbe wnNs ae cunei ON appliCitiin rape, (OLA) %Sddbn ad IgM in the Onecfms Wanness Pr VAN bMa[e Hpnenem 3-5 2 .apprkanon n an,slams M R wnllatrW RiplYled•mmlMn• HaneMim 1 2 CatSCYw' 1,15 aplailly ad tats in W Dia[4am,m0ieNn nastiness Wl• Rhee WPMed,w Mpbn 2 352 CsanaMue- 2-5 1.2 vee Me meant range specified b W DNec6ee..Me Massive,annul• Re ache eraewe al deepen Omer Man Matt 0 IDM b sm kneN,ress; 2-5 2 One, 2-5 1 Reanae,easy AT,sen MIe knnsmgsa 2-] 1 Cnerry,sister,pbck pan 2-] f-35 OarMim,in a Dn Use sol.app sir trine Wwlne (Cns. dpenMlsk/' Rye' gwytai aM 23 2 C%de boat - 153 THE EXCLUSIVE REMEDY OF ME USER GP BUYER.MO Fame way WpnM• Nlapwed 1 2 Dageens- 2.5 I.z Roddy ptnM SMSw•SGS Lain 1.1.25 Ester THE LIMIT OF ME LIABIdTY OF THIS COMPANY OR INR F°GaY• Smtmaa LeswMa 3.5 2 Etm' 2-5 1.2 DTAMMGHER E PESUL NG AER MR MOM MEUSEUSE GP XRNNUM Ci GwUmse, e' Sbdowspuw' IniMaes.common 3 2 Enc."Ua - 3 (INCLUDING CLAIMS BASED IN COIImACT. THIS P ENCS. G.r!ftK Smanare Men ,wiashm 2 2 On.- 2.5 Pmadnel'2.5 1.2 NEGLIGENCE.BTRICT MEIURCHAY,OTHERTORTORE1MR Gab smpnum lmGpl' Immanent. - Mdkn.cammm 3.5 2 Gane' - 1-2 OR B YER FOR PVRCHASEPRICEPMOS PRODUCT Gmeegad.mm�dn' Smamned l%seumsi' I, Herne,:masa $manseedantand nl• NsResmi 35 2 Handl• 2. 1-2 IM BUYER OR, THE QUANTITY OF THIS PPDOIICR Wnsip $Dweetmeats Ne,wine Min. 3 2 Hareems, 2.3 1-I$ INVOLVED,OP,AT THE ELECTION MJ THIS COMPANY N- None s,"Unn Y SDaniamapa Oneness:pwpb.Wlbw 3 12 NHeaelM 2 1 ANYO OR. SELLEP,UNEPSPIACEMENt OF FUNOLLW- ECarYa wnahnshl s«aMlag punytN• Oneepnn I 2 Hbery' 3-5 1-2 TTY SUCH O NOTACOIN NO EV NT SH L NIS COMPANT - Ndprm• Seem.ai n Paints. 3.5 1.52 Hinman. 2-e 1.2 OF SUCH QUARTTY.IN NO EVENT SHALL THIS COMPANY ]dnakince tteBe Sperw,Peen Pap nes 3.5 2 Homneam,Avenins' 2.5 IQ OR ANY DTHEP SELLER BE UABaE FOP ANY INCIDENTAL ]UswasiJ Stype,wUffes WDpeewW.weans 1 2 Nldm t 2 CONSUens. UFITIM OPSPECLea DAMAGES. Keenan SPere.a odes Resswa- - 1.2 LanronsneL' - tQ UwnpwdM WnanNedsasal tlsgreat dryer udaUa %WUR- Nwnl Sputry,umbma' Pakan emla45 2. 1.2 Merbm raprDW' 2. 2 deems b have angle Me hems . e LI d be y Nr- StAkma.ye0w• Rastsm' 2.3 2 MiHH! x5 1-2 RAN iMO nitne misses resin lampsOlWers' RedrMe' 2 3 M,Pk.Rd 2-s, 1-1.5 el.wMM1n my wt be need%a%err and pansy StintprafF' ,erammt 11 tame are nd aaephsiM ree,m Logonrapl' Smllowea• Reese, 2. 1 Aeaple,sued - 1-1.5 acme uRien.as Syed Teaxad Pew sena RmatIne. w 3-5 1 Mon Ref Meer• - 1-3 - "fssrl Hyrar.Wdv.Oud W Rata ue trademaN a EI. Meesanad' Teas dynein' Smznaee,s' 3-5 2 O,ICp1uk WNIM1' 34 1-2 duPtftsna roue as CanwM. Yehesd Spuw.haN' - 2 Onk pert- 3.1 t-IS NomMppbry "'Wmsub Pained an bawmaNdCkaGdpy Carwspm. (aemass. Wpml wOwnWe' Swed.a" Mb' - 2 One:Inertiaunto- ,pin 2.1 1-I5 Sanm,Spurn.Seen,a Tarim ve tMaman,W Fbwa Muslad.nbe' VAM. Mean.IMchap 2. 2 Oak scum 24 1-IS Rees.asamwM. Mu,ae.Usay,w.ft 'MM asst' Timmy N 2.3 2 Partn.. rcd 23 1.1.5 "Bmadris am aad5aepa.lw. Mustud.,eild' ' WMlpnb• TampW 2.3 2 Ponimmw' 2.5 1.2 ^RmsarW a tadmanuf PhdKPama.lw. Mustud,wM' Wary dmglma' Tenm1s;m' 4-5 2 Pine 2.5 1-2 ^stetted ha Wemaa alAmnim ryaanb Canpvry P* Ymw rased vassyn nepeY 2 2 Poban'Iff.-w Was 4-5 $ Mswae• Vasryaaass 3.5 2 Pdpbgttllpa' 2-5 1-2 'Wen Usie Bea bed ed epufpmemlwrbl mpMaMns VMeN. 3-5 2 A..Imhm 2-5 1.2 min araut is protected%U.S.Weal Na.a,e5.53t. .naan"win l-p- ilp eft fes,ne"Bameal I p"d ,will Wnasbae.ueakm R3 2 qui tiaW 23 1-2 Na liens gene]utarna iner aMemnUS wlentls) pemmesl«puelNnntraOp uUimin to t 3I 'PafN tmtrd _ paoewd wren.Aps.w murine ma0eumq 3 b10 ••Md reabMed M Gammen laruttm Mh wee Spe,�• 2.5 1-2 pavans,h asnw,0In et ase.Use sense sweet; emus VA Reap.ft.S2eJ25 anessy ,Gsah samfafupe and tree Wlan Wada Nin Sags Wash.WdomO - 1 a asdy OrpMh ripe. Wmonerry x l 9.3 Woody Brush and Trees SaRM.. 25 1-2 2-5 In gaze at anemerwnaV i."Mh prnsud 25 1.2 fill Colhd dry«nee.lin)6BaJOD3. 9.2 Perennial Weeds Appl,Me,wadial aft Me led assassin,m unbdMMuswwd' rwlae Samonnal. vwoM,Wbpe' 21 1.2 OMONSWTI COMPANY 1945 directs.Uu f neer ole Ipr bet passe,any.dens Bea sad"ae entMnW wen wannbl sees art anal ata d saoeM.On win.Us Me higher Me Lar mss tlp Savanna. 2.3 2-5 1-2S MONAMI STG COMPANY an.they Hach ftmindlmme alae d gmM ItteyWp eH name ftWordy Gane d gn .Bed mase m - S.W..Cnbtea - 1 AGRICULTURAL PRODUCTS baud.b passe and Md lwmatlm In neaekaswl�For adelwd wh kw titin MaNINNINe I..W aft TamrdDmne' 2 ST.LOUIS.MISSOURI.0I67 USA. en-Ilen eEnp phmd beat neatens Un asitllne efts ft RUN hnwfm Names" 2 1 2fu6T3.1AX1 phelblrech a msuae,aae N".weamaryedMla. In and um.Oea sense osiatradwbn app«Mdn an Taiwan,tree' - 1-2 BUM constituents. ue I.Law, eel a Meat awB dna.Det Made b dtl slip b SIN SYmma ellen man Swnk,we TNmwlaetwa 2.3 1.1.5 Mtn<pnOaWe,as Me neer mplNalidn rate wlMm Me G nee RWI6ne name and an fpamp. We mm' 2-5. 1-2 .mea ed nes. Emvn Mawpn a ee]e when"sang arry-toeaa sed. VVaania aawr 2-5 1-2 MOW l w mrs drys aftapplafpn alma MINN. Iwnb stip hated-feed pnemmt Wen uvp htd-Intl Waxei einem• 2.5 1-2 Wad Swde Fab Had-Wb nuiinsi br be wbme ditl say sed nemeses, Waw 3 1 (OTIA)I,Saeid, UHI 5 in 10 wweM mothers d we'sn p. ,1'adcwya BYlndaw m,e1 new pd.b sent«aenettM ants ,ulz"'"'HamWeed• i 1..5 ml veawnn. 10.0 LIMIT OF WARRANTY Ams(f.1) - 1-2 Maw2alnbedndeapersanpd MW"U-W AND LIABILITY Min.. 3-5 2 rnnvra.ReCedbmtmm east Gemerybmmd penin, B.N.- IS x tearvNlp line mdtmeRb was w seed Saw maim Monenb CwnwM svranb OW Mb pease amlbmt to Bamucams; 5 2 npsmudeWe dam.podawaaeWde Pa dm rWncia detcriptlm an NN Ind ae is saonaW Mew emeepae,arner Ilmtgaaal'• 15 2 ride a me,kd dam m aw«eed.Podnd peH«man as wtPwea m NM b Me Campkb Dnatlwt M Uas BMdweed.Rab 4.5 2 arq' iub mmlb anmafabMpa6ert find haoebl l-Waliwnl sen weban«tlanu Wtlh MuprmXenlw% 2 2 Btatasst Had-Ne10 Mow Ohldlala oder me taedXlaw a,aied Martin.NO Tensed.Teen 4.5 2 Was Swan RW Branham. 3J 1.1,5 Spry-ao-WG OTHERFMAPA WARRANFYRF IMPLIED WAPRAHIY OF BHmegnes,ancen 2 2 IQT/AI %Sdufan MTNE56FOR Man Na RAR PUPPOSEOPMEPCIWaTMIL MrSase.Waeeh-wf 2 Abu N 1.15 and11Y ISMAOEIbsed Wine Iselin susiNd le,gu cOndiUona Caarywwsrae 2.3 2 Ann. 2.5 1 3 and BmMMw stile spree. Was 3.5 2 station.0aalm 2.3 1.1.5 Ism'and asp Uses,ams V.P%rowdy Mh ca dam Cb,aHwan Wena 32 BealB Teatime oedonn' L5 1-2 senses Wedsr sided b atVM,wstlwnd,smt Means. Coos3-5S 2 ENI 2-5 IQ der bn«dnuwhe. [Unless. 35 2 Bann z 1 U. W dl sen ere neves M e m Iwo is flame Ou and 25 2 Blawpenn N 1.1.5 Nam utt a nvdlp nope sanen hem"HeUnionistMynd Dat aprp e 4 2 SwcWam 2-5 1-2 tlw rnbd a ash CaalwM•.'vplbtrp,std led Mee Is, F.I. a 2 Bruns 2-5 f.2 mrameass, :M wades wet Ma Mow«IMMkae Faaae(used blD 3-5 2 Baron;irmch,te ds. - 1 2 U1rtcUdn,mpaa«t m a wmct xie,wands Wsda- Ttanue:a5. 1-3 2 BuaWMHL CdiOmia' 1.2 Uan,ammWseems.seen".1 ft wanness ere w a n, Gudeppru,� 3 1 - Casmra' 2.5 1.2 Me rang[an,i0ere narmd al da aDdkalhn N4 ase fa ' _ MONSANTO Material Safety Data ROUNDUP®PRO Herbicide Page 2 of 6 MONSANTO MSDS No:SOOO12732 526/99 SKIN CONTACT: this product is no more than slightly toxic and no more than slightly irritating based on toxicity MATERIAL SAFETY DATA studies. INHALATION: this product is no mom than slightly toxic if inhaled based on toxicity studies. I. CHEMICAL PRODUCT AND COMPANY IDENTIFICATION INGESTION:this product is no more than slightly toxic based on toxicity studies.No significant adverse health effects are expected to develop if only small amounts(leu than a mouthful)are swallowed. Ingestion of similar formulations has been reported to produce gastrointestinal discomfort with irritation of the mouth,nausea,vomiting PRODUCT NAME: ROUNDUPS PRO Herbicide and diarrhea. Oral ingestion of large quantities of one similar product has been reported to result in hypotension and lung edema MSDS NUMBER: 500012732 DATE: 5261" MEDICAL CONDITIONS AGGRAVATED BY EXPOSURE: None known CHEMICAL FAMILY: Glyphosate EPA Reg.No.: 524475 Refer to Section 11 for toxicological information. CHEMICAL NAME: Mixture MONSANTO COMPANY,SOON.LINDBERGH BLVD.,ST.LOUIS,MO 63167 4. FIRSTAIDMEASURES FOR CHEMICAL EMERGENCY,SPILL LEAK FIRE,EXPOSURE,OR ACCIDENT IF M EYES: immediately flush with plenty of water for az least IS minutes. If eery to do,remove any contact Call CHEMTREC-Day or Night-1-800-4249300 Toll Bee in the continental U.S.,Hawaii,Puerto Rico,Canada, lenses. Go medical attention. Remove material from skin and clothing. Alaska,or Virgin Islands. For calls originating elsewhere:703-527-3887(callect calls accepted) For additional non-emergenry,infomration,call:1-800-332.3111. IF ON SKIN: immediate fust aid is not likely to be requited. However,this material can be removed with water. Wish heavily contaminated clothing before reuse. 2. COMPOSITIONIINFORMATION ON INGREDIENTS IF INHALED: immediate fust aid is not likely to be required. However,if symptoms occur,remove to fresh air. IF SWALLOWED: immediate that aid is not likely to be required.A physician or Poison Control center can be COMPONENT CAS NO. - %BY WEIGHT contacted for advice. Wuh heavily contaminated clothing before reuse. Active Ingredient-. Glyphosate,N-(phosphonomethyl)glycine, 5. FIRE FIGHTING MEASURES in the form of its isbproplyamine salt 38641-940 41.0 Inert Ingredients: + 59.0 +The specific chemical id<ntiry,is ping withheld because it is trade secants Informntion of Monsanto Company. FLASH POINT: None METHOD: N/A HAZARDOUS PRODUCTS OF COMBUSTION: CO,CO2,N. 3. HAZARDS IDENTIFICATION EXTINGUISHING MEDIA: In case of Inc.use water(flood with water),dry chemical,CO2,or alcohol foam. EMERGENCY O VERVIE UNUSUAL FIRE AND EXPLOSION HAZARDS: None APPEARANCE AND ODOR Clear,visomu amber-colored liquid FIRE FIGHTING EQUIPMENT: Fire fighters and others exposed to products of combustion should weer self- contained breathing apparatus. Equipment should be thoroughly decontaminated after we. Keep out of reach of children. CAUTION! - 6. ACCIDENTAL RELEASE MEASURES CAUSES EYE IRRITATION Observe all protection and safety precautions when clewing up spills-See Exposure Controls/Personal Protection, Avoid contact with eyes or clothing. Section S. POTENTIAL HEALTH EFFECTS Small Spills: For a spill less than one gallon on floor or other impervious surface,soak up with towels or other absorbent material and discard in the truh. Clean the spill area with soap and water and rinse the area thoroughly. LIKELY ROUTES OF EXPOSURE: Skin contact and inhalation Large Liquid Spills on the floor or other impervious surface should be contained or diked and then absorbed with EYE CONTACT: this product may cause pain,redness and testing based on toxicity studies. amapulgite,bentonite or other absorbent clays.Collect the contaminated absorbent place in a meal drum and MONSANTO Material Safety Data MONSANTO Material Safety Dale ROUNDUPD PRO Herbicide Page 3 o1`6 - ROUNDUPS PRO Herbicide Page4of6 MSDS No:500012732 526/99 MSDS No:500012732 526199 dispose of in accordance with the instructions provided under Disposal,Swim 13 of this MSDS. Thoroughly semb AIRBORNE EXPOSURE LIMITS: Flom or other impervious surface with a strong industrial detergent and rinse with water. Large spills that soak into the ground should be dug up,placed in most drums and disposed of in accordance with instructions provided under PRODUCT/COMPONENT OSHA PEL ACGIH TLV DISPOSAL.Section 13 of this MSDS. Contain appropriate state agency when considering a land spreading di poral - ROUNDUPS PRO Herbicide _ Not established —Not established option. OSHA and ACGIH have nm established specific exposure limits far this material. However,OSHA and ACGIH Leaking containers should be separated from non-leakers and either the container or its contents transferred on a have established linin for particulates not otherwise regulated(PNOR)and particulates not otherwise classified drum or other non-leaking container and disposed of in accordance with instructions provided under DISPOSAL, (PNOC)respectively,which are the least stringent exposure limits applicable to dusts. Section 13 of this MSDS.Any recovered spilled liquid should be similarly collected for disposal. OSHA PEL ACGIH TLV Refer to Scotian 13 far disposal information and Sections 14 and 15 for reportable quantity information. 15 mg/m3(total dust)8-1tr TWA 10 mg/m3(inhalable)8-N TWA 5 my/m3(respirable)8-hr TWA 3 mP/m3(resphmble)8-hr TWA 7. HANDLING AND STORAGE 9. PHYSICAL AND CHEMICAL PROPERTIES Handling: Avoid contact with eyes or clothing. Appearance: clear,viscousamber-colored solution Wash hands before eating,drinking,chewing gum,using tobacco,or using the toiler Odor. practically odorless to slight amine-like odor Remove clothing immediately if pesticide gen inside. Then wash thoroughly and put on clean clothing. pH: 4.99(1%solution) Do not apply directly to water to area where surface water is present or to intartidn arca below the mean high Specific Gravity: 1.17(Watera 1) watermark. Do not contaminate water when disposing of equipment washwsters. NOTE:Thesc physical data are typical values baud on material tested but may vary form sample to samp,c.Typical values Storage: Do not contaminate water,foodstuffs,feed or seed by storage or disposal. should not be coammed as a guaranteed analysis otter specific lot or as spaifmcariom for the predud Emptied container retains vapor and product residue. Observe all labeled safeguards until container is cloned, reconditioned,ordestroyed. DO NOT REUSE THIS CONTAINER 10. STABILITY AND REACTIVITY 8. EXPOSURE CONTROLSTERSONAL PROTECTION STABILITY: Product is stable under narmal conditions ofs mage and handling. Store in a cosi,well ventilated place away from foodsnfTs,reducing agents and acids. EYE PROTECTION: Workers handling the packaged concentrate should wear chemical safety goggles m prevent - MATERIALS TO AVOID:Spray solutions of this product should be mixed,armed or applied ming only stainlea rye contact during mixinp/aamfer operations or other activitiu where then is potential for eye cannot with the steel,aluminum,fiberglass,plastic or plastic-lined containers. concentrated producL The wearing of goggles is not required during use of this product in accordance with label instruction. DO NOT MIX,STORE OR APPLY THIS PRODUCT OR SPRAY SOLUTIONS OF THIS PRODUCT M GALVANIZED OR UNLINED STEEL(EXCEPT STAINLESS STEEL)CONTAINERS OR SPRAY TANKS. SKIN PROTECTION: Wear appropriate protective clothing to prevent skin contact Applicator and other headless This product or spray solutions of this product react with such containea and tanks to produce hydrogen ger which most weer long-sleeved shirt,long pants,shots plus socks. Follow manufacturers insauctiaa,for may form a highly combustible ger mixture.This gas mixture could Bash or explode,ceasing serious personal cleaning/manteming PPE. If no such instructions for washables,usednergent and hot water. Keep and wash PPE injury,if ignited by open Benre,spark,welders troch,lighted cigarette moth"ignition source. separately from other laundry. - - HAZARDOUS DECOMPOSITION PRODUCTS: None RESPIRATORY PROTECTION:For Homilop the Conceruramd Product Avoid breathing vapor or mist This product concentrate is not likely to pass an airborne exposure concem during manufacture or packaging, In the HAZARDOUS POLYMERIZATION: Does not occur. This product can react with caustic(basic)materiels to event of abnormal exposure conditions,use NIOSH/MSHA approved equipment. In work Situations where an ab liberate heat. This is not a polymerization but rather a chemical neutralization in an acid base reaction. purifying respirator is appropriate to be used,use of a full face respirator equipped with purifying elements for protection against organic vapor and dust/mist approved for pesticides is recommended. Use cartridges with NIOSH/MSHA approval number TC-23C or canister with NIOSH/MSHA approval number TC-14G. Full Il. TOXICOLOGICAL INFORMATION facepiece replaces the need for chemical goggles. Observe respirator use limitations specified by the manufacturers. Respinnry protection programa must comply with 29 CER 1910.134. Dara from laboratory stadia condoned by Monsanto with ROUNDIJPD PRO herbicide are summarized below: Fo,Use mrP odu t in imeerdaecewith label instrudimirz Respirators are not required foruse of ROUNDUPS PRO Herbicide in accordance with label instructions. Single exposure(acute)studies indicate: Oral- FIFRA Category IV VENTILATION: No special precautions are recommended. Consult NFPA Standard 91 for design ofexhwn Dermal- FIFRA Category IV systems. Inhalation- FIFRA Category IV;Not DOT poisonous Eye Irritation.. FIFRA Category 111 MONSANTO Material Safety Data MONSANTO Material Safety Dau ROUNDUP®PRO Herbicide Page 5 of6 ROUNDUPD PRO Herbicide Page 6 of 6 MSDS No:500012732 526/99 MSDS No:S00012732 52699 Skin irritation- FIFRA Category IV DOT Proper Shipping Name: Not Applicable No skin allergy was observed in guinea pigs following repealed skin exposure. DOT Hazard Class(LD.No.: Not Applicable DOT Label: Not Applicable COMPOUNDS:. U.S.Surface Freight Classification: Weed killing compound.N.O.I.B.N. Dam from laboratory studies conducted by Monsanto and from the scientific literature on components of ROUNDUPD PRO herbicide: 15. REGULATORY INFORMATION - isopropylamine Salt of Glyphosate: Dam from studies with a formulation comprised of62%uopropylaminesalt of - glyphocate(MON 0139)indicate the following: SARA Haard Notification: Haard Categories Under Criteria of SARA Title III Rules(40 CFR Part 370): Immediate In repeat dosing studies(6-month),dogs fed MON 0139 exhibited slight body weight changes. Following repeated Section 313 Toxic Chemical(s): Not Applicable skin exposure(3-week)to MON 0139,skin irritating was the primary effect in rabbits. Hazardous Chemicals Under OSHA Hazard Communicating Standard(29 CFR§1910.1200): Sormcunt Reportable Quantity(RQ)under U.S.CERCLA: Not Applicable Additional toxicity information is available on glyphosate,the active herbicidal ingredient of MON 0139. Following TSCA Inventory: All components arc on the US EPAY TSCA Inventory List repeated exposures(90-days)to glyphosate in their feed,decreased weight gains were noted at the highest test level in mice,while notreatment-related effects occurred in rats. Following repeated skin exposure Cl weeks)to _ glyphosate,slight skin irritation was the primary effect observed in rabbits. No skin allergy was observed in guinea 16.OTHER INFORMATION pigs following repeated skin exposure. There was no evidence of effects on the nervous system,including delayed effects in chickens(repeat oral doses)or cholinestemse inhibition in rest(single oral doses). Reduced body weight gain aid effects on liver tissues were observed with long-firm(2-year)finding ofglyphosate to mice a high-dose REASON FOR REVISION: Connected non-emergency phone number. Supersedes MSDS dated 2112199. levels. Reduced body weight gain and eye changes were observed at the high-dose level in one long-lens(2 year) ROUNDUP is a reiste ed trademark of Monsanto Company feeding study with rats,while no treatment-related effects occurred in a second study. No adverse effects were This Material Safely Data Shat(MSDS)caves different purposes than and DOES NOT REPLACE OR MODIFY THE EPA- observed in feeding studies with dogs. Glyphosate did not produce rumors in any of mese studies.Based on the APPROVED PRODUCT LABELING(attached to and accompanying Ne protium container).This MSDS provides important results from the chronic studies,EPA has classified glyphosate in category E("Idea"of ooa-nMoogenielty - health.safety.and environmental information for empleyen,empbyss,anagcncy responders arul others handing large for humans). No birth defects were noted in rats and rabbits;given glyphosate orally during pregnancy,even at quantities of the product in activities generally ether than product use while the labeling provides that uformating specifically amounts which produced adverse effects on the mothers. Glyphosate was fed continuously to rats at very high dose fm product use in the ordinary coupe. levels for 2 successive generations. Toxicity was reported in offspring from the high dose,a level which also Use,gonge and disposal of pesticide products arc regulated by the EPA under the authority of dm Federal Insecticide, produced adverse effects on the mothers. In a 3 generation study conducted at lower dose levels,no effects were Fungicide,and Rodeaticide Act(FTFRA)through the prothat labeling,and all necessary and appropriate pmcaus lorury,use. seen on Ne ability of male or female rob to reproduce. Glyphosate has produced no genetic changes in a variety of storage,and disposed information is set fond ng Na labeling. It h a violation of federal law to use a pesticide product in any standard tests using animals and animal or bacterial cells. mama not Mscribed on the EPA- wed label. 12. ECOLOGICAL INFORMATION Although the information and recommendations f set faith herein(hereinaer-Information•)am presented in good faith and believed in be correct as of Ne date hertuf,Montague Cumpany makes m repmentstions as to the eomplcnmess m accuracy thereof Inforearion is supplied upon nhc condition that the persons receiving mate will make their own determination at to its suitability fm their purposes prior to oae in an event will MonsmuCompany be responsible for damages ofany nmwe This product has been tested for toxicity to aquatic invertebrates,fah and birds. The mulls indicate that this wlutsoevtt meshing from Ne esu o[w mliance upon Infomutim NO REPRESENTATIONS OR WARRANTIES,EfUffR product is slightly to moderately toxic to D.magma moderately toxic to wastewater and Coldwater fuh,and EXPRESS OR IMPLIED,OF MERCHANTABILITY,FITNESS FOR A PARTICULAR PURPOSE OR OF ANY OTHER practically non-toxic W bobwhite quail and the mallard duck.No data is available regarding algal toxicity far this NATURE ARE MADE HEREUNDER WITH RESPECT TO INFORMATION OR THE PRODUCT TO WHICH product. INFORMATION REFERS, ROUNDUPPR0399.DOC U. DISPOSAL CONSIDERATIONS Wastes resulting from the use of this product that cannot be used or chemically reprocessed should be disposed of in a landfill approved for pesticide disposal or in accordance with applicable Federal,state or local procedures. Emptied container muNs vapor and product maidue.Observe all labeled safeguards until conuiner is 0=4 reconditioned or destroyed. This product should am be dumped,spilled,rinsed or washed into sewers or public waterways. 14. TRANSPORT INFORMATION Follow the precautions indicated in the Handling and Stooge Section,Section 7 of this MSDS. Razor-Pro Herbicide The Department of Agricultural Resources has not developed a Herbicide Fact Sheet for Razor- Pro. The active ingredient in Razor-Pro is glyphosate, identical to that found in Roundup Pro. Please consult the Herbicide Fact Sheet for Roundup Pro (attached) or call Mr. Gerald Kennedy at The Department of Agricultural Resources, telephone 617-626-1773. MATERIAL SAFETY DATA SHEET Riverdale Razor Pro For Chemical Emergency, Spill, Leak, Fire, Exposure, or Accident, I01% Call CHEMTREC Day or Night: 1-800-424-9300. Nufarm For Medical Emergencies Only,Call 1-877-325.1840. 1. CHEMICAL PRODUCT AND COMPANY IDENTIFICATION Product Name: Riverdale®Razor®Pro Synonyms: Isopropylamine Salt of Glyphosate; Glyphosate IPA Salt EPA Reg. No.: 228-366 Company Name: Nufarm Americas Inc. 1333 Burr Ridge Parkway, Suite 125A Burr Ridge, IL 60527 Date of Issue: March 23, 2005 Supersedes: June 13, 2002 Sections Revised: All - new ANSI format 2. HAZARDS IDENTIFICATION Emergency Overview: Appearance and Odor: Clear, viscous greenish/yellow solution with little odor. Warning Statements: Keep out or reach of children. CAUTION. Causes moderate eye irritation. Harmful if swallowed or inhaled. Do not get in eyes or on clothing. Avoid breathing vapor or spray mist. Potential Health Effects: Likely Routes of Exposure: Skin contact and inhalation. Eye Contact:The undiluted product may cause pain, redness and tearing based on toxicity studies. Skin Contact: This product is no more than slightly toxic and no more than slightly irritating based on toxicity studies. Ingestion: This product is no more than slightly toxic based on toxicity studies. No significant adverse health effects are expected to develop if only small amounts(less than a mouthful) are swallowed. Inhalation:This product is no more than slightly toxic if inhaled based on toxicity studies. Medical Conditions Aggravated by Exposure: None known See Section 11: TOXICOLOGICAL INFORMATION for more information Potential Environmental Effects: Available data on similar formulations suggest that this product would be slightly to moderately toxic to aquatic organisms and practically non-toxic to avian species, honeybees and earthworms. See Section 12: ECOLOGICAL INFORMATION for more information 3. COMPOSITION/INFORMATION ON INGREDIENTS COMPONENT CAS NO. %BY WEIGHT Glyphosate, N-(phosphonomethyl)glycine, in the form of its isopropylamine salt 38641-94-0 41.0 Other Ingredients Including: 59.0 Ethoxylated Tallowamines 61791-26-2 Page 1 of 6 March 23, 2005 MATERIAL SAFETY DATA SHEET Riverdale Razor Pro 4. FIRST AID MEASURES If in Eyes: Hold,eye open and rinse slowly and gently with water for 15 to 20 minutes. Remove contact lenses, if present, after the first 5 minutes, then continue rinsing eye. Call a poison control center or doctor for treatment advice. If Swallowed: Call a poison control center or doctor immediately for treatment advice. Have person sip a glass of water if able to swallow. Do not induce vomiting unless told to do so by the poison control center or doctor. Do not give anything by mouth to an unconscious person. If Inhaled: Move person to fresh air. If person is not breathing, call 911 or an ambulance, then give artificial respiration, preferably by mouth-to-mouth, if possible. Call a poison control center or doctor for further treatment advice. If on Skin: Take off contaminated clothing. Rinse skin immediately with plenty of water for 15 to 20 minutes. Call a poison control center or doctor for treatment advice 5. FIRE FIGHTING MEASURES Flash Point: None Autoignition Temperature: Not determined Flammability Limits: Not determined Extinguishing Media: In case of fire, use water(flood with water), dry chemical, CO2, or alcohol foam. Special Fire Fighting Procedures: Firefighters should wear NIOSH/MSHA approved self-contained breathing apparatus and full fire-fighting turn out gear. Dike area to prevent runoff and contamination of water sources. Dispose of fire control water later. Unusual Fire and Explosion Hazards: Containers will burst from internal pressure under extreme fire conditions. If water is used to fight fire or cool containers, dike to prevent runoff contamination of municipal sewers and waterways. Hazardous Decomposition Materials (Under Fire Conditions): Under fire conditions, may produce gases such as nitrogen oxides, carbon oxides and phosphorous oxides. National Fire Protection Association (NFPA) Hazard Rating: Rating for this product: Health: 1 Flammability: 1 Reactivity: 0 Hazards Scale: 0 = Minimal 1 = Slight 2= Moderate 3=Serious 4= Severe 6. ACCIDENTIAL RELEASE MEASURES Personal Precautions: Wear appropriate protective gear for the situation. See Personal Protection information in Section 8. Environmental Precautions: Prevent material from entering public sewer systems or any waterways. Do not flush to drain. Large spills to soil or similar surfaces may necessitate removal of topsoil. The affected area should be removed and placed in an appropriate container for disposal. Methods for Containment: Dike spill using absorbent or impervious materials such as earth, sand or clay. Collect and contain contaminated absorbent and dike material for disposal. Methods for Clean-Up and Disposal: Thoroughly scrub floor or other impervious surface with a strong industrial detergent and rinse with water. See Section 13: DISPOSAL CONSIDERATIONS for more information. Other Information: Large spills may be reportable to the National Response Center(800-424-8802) and to state and/or local agencies. 7. HANDLING AND STORAGE Handling: Do not get in eyes or on clothing. Avoid breathing vapor or spray mist. Wash hands before eating, drinking, chewing gum, using tobacco or using the toilet. Remove clothing immediately if pesticide gets inside. Then wash thoroughly and put on clean clothing. Page 2 of 6 March 23, 2005 MATERIAL SAFETY DATA SHEET Riverdale Razor Pro Spray solutions of this product should be mixed, stored and applied using only stainless steel, aluminum, fiberglass, plastic or plastic-lined containers. DO NOT MIX, STORE OR APPLY THIS PRODUCT OR SPRAY SOLUTIONS OF THIS PRODUCT IN GALVANIZED STEEL OR UNLINED STEEL (EXCEPT STAINLESS STEEL) CONTAINERS OR SPRAY TANKS. This product or spray solutions of this product react with such containers and tanks to produce hydrogen gas which may form a highly combustible gas mixture. This gas mixture could flash or explode, causing serious personal injury, if ignited by open flame, spark, welder's torch, lighted cigarette or other ignition source. Storage: Do not contaminate water, foodstuff, feed or seed by storage or disposal. STORE ABOVE 10°F (-12°C) TO KEEP PRODUCT FROM CRYSTALLIZING. Crystals will settle to the bottom. If allowed to crystallize, place in a warm room 68°F (20°C) for several days to redissolve and shake, roll or agitate to mix well before using. 8. EXPOSURE CONTROLS/PERSONAL PROTECTION Engineering Controls: Where engineering controls are indicated by specific use conditions or a potential for excessive exposure, use local exhaust ventilation at the point of generation. When handlers use closed systems, enclosed cabs, or aircraft in a manner that meets the requirements listed in the Worker Protection Standard (WPS) for agricultural pesticides 140 CFR 170.240(d)(4-6)], then handler PPE requirements may be reduced or modified as specified in the WPS. Personal Protective Equipment: Eye/Face Protection: To avoid contact with eyes, wear chemical goggles or shielded safety glasses.An emergency eyewash should be readily accessible to the work area. Skin Protection: To avoid contact with skin, wear long pants, long-sleeved shirt, socks and shoes. An emergency shower should be readily accessible to the work area. Respiratory Protection: Not normally required. If vapors or mists exceed acceptable levels, wear NIOSH approved air-purifying respirator with cartridges/canisters approved for use against pesticides. General Hygiene Considerations: Personal hygiene is an important work practice exposure control measure and the following general measures should be taken when working with or handling this material: 1) Do not store, use and/or consume foods, beverages, tobacco products, or cosmetics in areas where this material is stored. 2) Wash hands and face carefully before eating, drinking, using tobacco, applying cosmetics or using the toilet. Exposure Guidelines: OSHA ACGIH Component TWA STEL TWA STEL Unit Isopropylamine Salt of Glyphosate NE NE NE NE Ethox lated Tallowamines NE NE NE NE NE = Not Established 9. PHYSICAL AND CHEMICAL PROPERTIES Appearance and Odor: Clear, viscous greenish/yellow solution with little odor. Boiling Point: Not determined Solubility in Water: Soluble Density: 9.67 pounds/gallon Specific Gravity: 1.16 @ 20°C Evaporation Rate: Not determined Vapor Density: Not determined Freezing Point: 10°F (-12°C) Vapor Pressure: Not determined Page 3 of 6 March 23, 2005 MATERIAL SAFETY DATA SHEET Riverdale Razor Pro pH: 4.84 (1% solution) Viscosity: 29.5 cPs @ 20°C Note: Physical data are typical values, but may vary from sample to sample. A typical value should not be construed as a guaranteed analysis or as a specification. 10. STABILITY AND REACTIVITY Chemical Stability: This material is stable under normal handling and storage conditions. Conditions to Avoid: Excessive heat. Do not store near heat or flame. Incompatible Materials: Strong oxidizing agents: bases and acids. This product reacts with galvanized steel or unlined steel (except stainless steel) to produce hydrogen gas that may form a highly combustible gas mixture which could flash or explode. Hazardous Decomposition Products: Under fire conditions, may produce gases such as nitrogen oxides, carbon oxides and phosphorous oxides. Hazardous Reactions: Hazardous polymerization will not occur. 11. TOXICOLOGICAL INFORMATION Toxicological Data: Data from laboratory studies conducted on a similar, but not identical, formulation: Oral: Rat LDS,: >5,000 mg/kg; FIFRA Category IV Dermal: Rat LD,,: >5,000 mg/kg; FIFRA Category IV Inhalation: Rat 4-hr LC50: >2.05 mg/L; FIFRA Category IV Eye Irritation: Rabbits (6): Moderately irritating (including transient corneal opacity) to unrinsed eyes. Mildly irritating to rinsed eyes. Unrinsed eyes cleared by day 7 and rinsed eyes cleared by 72 hours; FIFRA Category III Skin Irritation: Rabbits(3); Slightly irritating. Cleared in all animals within 72 hours; FIFRA Category IV Skin Sensitization: Not a contact sensitizer in guinea pigs following repeated skin exposure. Toxicity of Isopropylamine Salt of GlVphosate: In repeat dosing studies (6 month), dogs fed a more concentrated form of this product exhibited slight body weight changes. Following repeated skin exposure (3 weeks) to this product, skin irritation was the primary effect in rabbits. No skin allergy was observed in guinea pigs following repeated skin exposure. Additional toxicity information is available on glyphosate, the active herbicidal ingredient of this product. Following repeated exposures (90 days) to glyphosate in their feed, decreased weight gains were noted at the highest test level in mice, while no treatment-related effects occurred in rats. Following repeated skin exposure (3 weeks) to glyphosate, slight skin irritation was the primary effect observed in rabbits.No skin allergy was observed in guinea pigs following repeated skin exposure. There was no evidence of effects on the nervous system, including delayed effects in chickens (repeat oral doses)or cholinesterase inhibition in rats (single oral doses). Reduced body weight gain and effects on liver tissues were observed with long-term (2 year) feeding of glyphosate to mice at high-dose levels. Reduced body weight gain and eye changes were observed at the high-dose level in one long-term (2 year) feeding study with rats, while no treatment related effects occurred in a second study. No adverse effects were observed in feeding studies with dogs. Glyphosate did not produce tumors in any of these studies. Based on the results from the chronic studies, EPA has classified glyphosate in category E (evidence of non-carcinogenicity for humans). No birth defects were noted in rats and rabbits given glyphosate orally during pregnancy, even at amounts which produced adverse effects on the mothers. Glyphosate was fed continuously to rats at very high dose levels for 2 successive generations. Toxicity was reported in offspring from the high dose, a level which also produced adverse effects on the mothers. In a 3 generation study conducted at lower dose levels, no effects were seen on the ability of male or female rats to reproduce. Glyphosate has produced no genetic changes in a variety of standard tests using animals and animal or bacterial cells. Page 4 of 6 March 23, 2005 MATERIAL SAFETY DATA SHEET Riverdale Razor Pro Toxicity of Ethoxylated Tallowamine: The surfactant component of this product is reported to cause irritation to the eyes and skin and may contribute to the irritation potential reported for this herbicide. Ingestion may product gastrointestinal irritation, nauseA, vomiting and diarrhea. Assessment Carcinogenicity: None listed with ACGIH, IARC, NTP or OSHA. See Section 2: HAZARDOUS IDENTIFICATION for more information. 12. ECOLOGICAL INFORMATION Do not apply directly to water, to areas where surface water is present or to intertidal areas below the mean high water mark. Do not contaminate water when disposing of equipment washwaters. Available data on similar formulations suggest that this product would be slightly to moderately toxic to aquatic organisms and practically non-toxic to avian species, honey bees and earthworms. Ecotoxicity: Data from laboratory studies conducted on a similar, but not identical, formulation: Rainbow Trout 96-hr LC50: 22 mg/L(static) Fathead minnow 96-hr LCs,: 9.4 mg/L Rainbow Trout 96-hr LCso: 8.2 mg/L(dynamic) Channel Catfish 96-hr LC50: 16 mg/L Daphnia Magna 48-hr LC50: 37 mg/L (aeration) Chinook Salmon 96-hr LCso: 20 mg/L Daphnia Magna 48-hr LCso: 24 mg/L (without aeration) Coho Salmon 96-hr LC50: 22 mg/L Bluegill Sunfish 96-hr LCso: 5.8 mg/L(dynamic) Bobwhite Quail 8-day LC50: >6,300 ppm Bluegill Sunfish 96-hr LCso 14 mg/L(static) Mallard Duck 8-day LCso: >6,300 ppm Gammarus pseudolimnaeus 48-hr EC50: 42 mg/L Algae S. Capricornutum 72-hr EC5o: 2.1 mg/L Environmental Fate: In the environment, salts of glyphosate rapidly dissociate to glyphosate, which adsorbs strongly to soil and is expected to be immobile in soil. Glyphosate is readily degraded by soil microbes to AMPA (aminomethyl phosphonic acid) that is further degraded to carbon dioxide. Glyphosate and AMPA are unlikely to enter ground water due to their strong adsorptive characteristics. Terrestrially-applied glyphosate has the potential to move into surface waters through soil erosion because it may be adsorbed to soil particles suspended in the runoff.Aquatic applications registered for certain formulations may also result in glyphosate entering surface waters. Complete degradation is slow, but dissipation in water is rapid because glyphosate is bound in sediments and has low biological availability to aquatic organisms. These characteristics suggest a low potential for bioconcentration in aquatic organisms and this has been verified by laboratory investigations of glyphosate bioconcentration in numerous marine and freshwater organisms with and without soil. The maximum whole body bioconcentration factors for fish were observed to be less than 1X. Bioconcentration factors for sediment dwelling mollusks and crayfish tended to be slightly higher, but were always less than 10X. In addition, any residues accumulated in organism were rapidly eliminated. 13. DISPOSAL CONSIDERATIONS Do not contaminate water,foodstuffs, feed or seed by storage or disposal. Waste Disposal Method: Wastes resulting from the use of this product that cannot be used or chemically reprocessed should be disposed of in a landfill approved for pesticide disposal or in accordance with applicable Federal, state or local procedures. Emptied container retains vapor and product residue. Observe all label safeguards until container is destroyed. Container Handling and Disposal: Plastic Bottles and Non-Returnable Plastic Drums: Do not reuse container. Triple rinse container. Then puncture and dispose of in a sanitary landfill, or by incineration, or, if allowed by state and local authorities, by burning. If burned, stay out of smoke. Page 5 of 6 March 23, 2005 MATERIAL SAFETY DATA SHEET Riverdale Razor Pro Returnable/Refillable Containers: Close all openings and replace all caps. Contact Nufarm Customer Service at 1-800-345-3330, to arrange for return of the empty refillable container. 14. TRANSPORATION INFORMATION Follow the precautions indicated in Section 7: HANDLING AND STORAGE of this MSDS. For Department of Transportation (DOT) regulatory information, if required, consult transportation regulations, product-shipping papers or call Nufarm's DOT Manager at 708-755-2104, Monday through Friday, 8:00 AM to 5:00 PM Central Time. 15. REGULATORY INFORMATION U.S. Federal Regulations: TSCA Inventory: This product is exempted from TSCA because it is solely for FIFRA regulated use. SARA Hazard Notification/Reporting: Hazard Categories Under Criteria of SARA Title III Rules (40 CFR Part 370): Immediate Section 313 Toxic Chemical(s): None Reportable Quantity (RQ) under U.S. CERCLA: None RCRA Waste Code: None State Information: Other state regulations may apply. Check individual state requirements. California Proposition 66: Not listed 16. OTHER INFORMATION This Material Safety Data Sheet (MSDS) serves different purposes than and DOES NOT REPLACE OR MODIFY THE EPA-ACCEPTED PRODUCT LABELING (attached to and accompanying the product container). This MSDS provides important health, safety and environmental information for employers, employees, emergency responders and others handling large quantities of the product in activities generally other than product use, while the labeling provides that information specifically for product use in the ordinary course. Use, storage and disposal of pesticide products are regulated by the EPA under the authority of the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA) through the product labeling, and all necessary and appropriate precautionary, use, storage, and disposal information is set forth on that labeling. It is a violation of federal law to use a pesticide product in any manner not prescribed on the EPA-accepted label. Although the information and recommendations set forth herein (hereinafter"Information") are presented in good faith and believed to be correct as of the date hereof, Nufarm Americas Inc. makes no representations as to the completeness or accuracy thereof. Information is supplied upon the condition that the persons receiving same will make their own determination as to its suitability for their purposes prior to use. In no event will Nufarm Americas Inc. be responsible for damages of any nature whatsoever resulting from the use or of reliance upon Information. NO REPRESENTATIONS OR WARRANTIES, EITHER EXPRESS OR IMPLIED, OF MERCHANTABILITY, FITNESS FOR A PARTICULAR PURPOSE OR OF ANY OTHER NATURE ARE MADE HEREUNDER WITH RESPECT TO INFORMATION OR THE PRODUCT TO WHICH INFORMATION REFERS. Razor and Riverdale are registered trademarks of Nufarm Americas Inc. Page 6 of 6 March 23, 2005 SPECIMEN LABEL UPDATES AVAILABLE AT WWW.(;REENBOOB.NET I � Nufarm Turf & Specialty DO NOT MIX,STORE OR APPLY THIS PRODUCT OR SPRAY SOLUTIONS OF THIS PRODUCT 1N GALVANIZED STEEL RUNLINED 'L O S STEEL Razo r° Pro EX- CEPT STAINLESS STEEL)CONTAINERS OR SPRAY TANKS This product or spray solutions of this product react with such le gas containers and tanks to produce hydrogen gas which may form a highly combustible gas mixture. This gas mixture THIS FULLY LOADED FORMULATION CONTAINS 14.0% could flash or explode,causing serious personal injury,if ignited by open flame, SURFACTANT.ELIMINATEt4 THE NEED FOR ADDITIONAL spark,welder's torch,lighted cigarette or other ignition source. SURFACTANT AND IT'S RAINFAST WITHIN 2 HOURS OF DIRECTIONS FOR USE APPLICATION. THE COMPLETE BROAD SPECTRUM POSTEMERGF-NCE It is a violation of Federal law to use(his product in a manncr inconsistent with PROFESSIONAL HERBICIDE FOR INDUSTRIAL, FORESTRY, its labeling. READ ENTIRE LABEL BEFORE USING THIS PRODUCT. Do TURF,VEGETATION MANAGEMENT AND ORNAMENTAL WEED not apply this product in a way that will contact workers or other persons,either CONTROL directly or through drill. Only protected handlers may be in the arca during ACTIVE INGREDIENT: application. For any requirements specific to your State or Tribe, consult the Glyphosate,N-(phosphnnonrethyl)glycine, agency responsible for pesticide regulations. in the form of its isopropylantine sell` .......................... 41.Onr. AGRICULTURAL USE REQUIREMENTS INERT INGREDIENTS: ....................................... 59.0 Use this product only in accordance with its labeling and with the Worker Pro- TOTAL.................................................... 160.0%. Use Standard,40 CFR part 170. This Standard contains requirements for die F Contains 480 grams per litre or 4 pounds per U.S.gallon of the active ingredient protection of agricultural workers on farts,forests,nurseries,and greenhouses. glyphosate,in the form of its isopropylaminc salt. rquivalent to 356 grams per and handlers of agricultural pesticides. - litre or 3 pounds per U.S.gallon of the acid,glyphosate. It containsrequirementsfor training, decontamination,notification, and etticr- EPA REG.NO.228-366 EPA EST.NO.228-IL-I ocncy assistance. It also contains specific instructions and exceptions pertaining MANUFACTURED BY NUFARM AMERICAS INC.,BURR RIDGE,ILLINOIS to the statements on this label about Personal Protective PPE Equipment and PPE) 60527-0866 - restricted-entry interval. The requirements in this box only apply to uses of this KEEP OUT OF REACH OF CHILDREN product that are covered by the Worker Protection Standard. Do not enter or allow worker entry into treated areas during the restricted entry CAUTION/CAUCION interval(REI)of 12 hours. Si listed no cnticndc Is ctiqucta,busque a alguien para que sc in explique a noted PPE required for early entry to treated areas that is permitted under the Worker en detalle. (If you do.not understand the label,find someone to explain it to you Protection Standard and that involves contact with anything that has been treated, in detail. - such as plants, soil, or water, is: coveralls,chemical-resistant gloves made of SEE INSIDE BOOKLET FOR FIRST AID AND ADDITIONAL PRECAUTION- any waterproof material such as barrier laminate or viten>13,shoes plus socks, ARY STATEMENTS and protective cycwcar. PRECAUTIONARY STATEMENTS NON-AGRICULTURAL USE REQUIREMENTS - HAZARDS TO HUMANS AND DOMESTIC ANIMALS The requirements in this box apply to uses of this product that arc NOT within KEEP OUT OF REACH OF CHILDREN the scope of the Worker Protection Standard for agricultural pesticides(40 CFR CAUTION part 170). The WPS applies when this product is used to produce agricultural plants on farms,forests,nurseries,or greenhouses. Causes moderate eye irritation. Harmful if swallowed or inhaled Du not get in - Keep people and pets off treated areas until spray solution has dried to prevent eyes or on clothing. Avoid breathing vapor or spray mist. transfer of this product onto desirable vegetation. FIRST-AID STATEMENT Have the product container or label with you when calling a poison control center GENERAL INFORMATION or doctor,or going for Imminent. Do not apply this product using aerial spray equipment except under conditions as specified within this label. IF IN EYES: Holt(eye open and rinse slowly and gently with water for 15 to This product,a water-soluble liquid,mixes readily with water'to be applied as a 20 minuses. Remove comae[lenses,if present,:Rei the lint S foliar spray for the control or destruction of most herbaceous plants. It may be mimaes,then continue rinsing eye. Coll a poison control center applied through most standard industrial or field-type sprayers after dilution and lir donor for treatment advice. through mixing with water in accordance with label instructions. IF SIYALLOW ED: Call a poison co lml center ar doclor immediately for treatment advice. Have person sip a glass of water if able to swallow. This product moves through the plant from the point of foliage conflict to and Do not induce vomiting unless told to do so by a poison into the root system. Visible effects on most annual weeds occur within 2 to 4 control center or doctor. Do not give anything by mmrth to an days,but on most perennial weeds may not occur for 7 days or more. Extremely unconscious person. cool or cloudy weather following treatment may slow activity of this product and IF INHALED: Move person to fresh air. If person is not breathing,call 911 delay visual¢Reek of control. Visible effects are a gradual wilting and yellowing of the plant which advances to complete browning o£above-ground growth and lir ut ambulance then give.Call al respiration,preferably P P g g mouth-ter-mouth if possible.Call a poison control center or deterioration of underground plant parts. doctor for further treatment advice. Unless otherwise specified on this label, delay application until vegetation has PERSONAL PROTECTIVE EQUIPMENT(PPE) emerged and reached the stages described for control of such vegetation under For uses covered under the Worker Protection Standard (WPS), 40 CFR Pan the"WEEDS CONTROLLED" section of this label. Unemerged plants arising 170—in general,only agriculklad plant uses are covered by the WPS:applicators from unattached underground rhizomes or root stocks of perennials will not be and other handlers must wear long-sleeved shirt and long pants,shoes plus socks' affected by the herbicide and will continue to grow. For(his reason,best control and protective cycwcar. Discard clothing and other absorbent materials that have of most perennial weeds is obtained when treatment is made at laze growth stages been drenched or heavily contaminated with this product's concentrate. Do not approaching maturity. reuse(hem. Follow manufacturer's instruction for cleaning/maintaining PPE. If Always use the higher ram of this product per acre within the recommended no such instructions for washables,use detergent and hot water. Keep and wash range when(1) weed growth is heavy or dense,or(2)weeds arc growing in an PPE separately from other laundry. undisturbed(non-cultivated)arca. ENGINEERING CONTROL STATEMENTS Do not treat weeds under poor growing conditions such as drought stress,disease When handlers use closed systems, enclosed cabs, or aircraft in a manner that or insectdamage,as reduced weed control may insult. Reduced results may also nmetsthc requirements listed in WorkcrProtection Standard(WPS)foragiicultural occur when treating weeds heavily covered with dust. pesticides (40 CFR 170.240(d) (4-6)], the handler PPE requirements may be Reduced control may result when applications are made to annual or perennial reduced or modified as specified in the WPS. weeds that have been mowed,grazed,or cul,and have not been allowed to regrow [o(he recommended stage for treatment. USER SAFETY RECOMMENDATIONS Rainfall or irrigation occurring within 6 hours after application may reduce cffec- USERS SHOULD: Wash hands before eating, drinking,chewing guns, using liveness. Heavy rainfall or irrigation within 2 hours after application may wash tobacco or using the toilet. Remove clothing immediately if pesticide gets inside, the chemical off the foliage and a repeat treatment may be required. Then wash thoroughly and put on clean clotting. - This product does not provide residual weed control.For subsequent residual weed ENVIRONMENTAL HAZARDS control,follow a Iabc1-approved herbicide program. Read and carefully observe the cautionary statements and all other information appearing on die labels of all Do not apply directly to water, to areas where surface water is present or to herbicides used. intertidal areas below the mean high water mark. Do not contaminate water when Buyer and all users arc responsible for all lass or damage in connection with disposing of equipment washwalas' the use or handling of mixtures of this product with herbicides or other materials PHYSICAL OR CHEMICAL HAZARDS that ire not expressly recommended in this labeling. Mixing this product with Spray solutions of this product should be mixed,stored and applied using only herbicides or other material not recommended on this label may result in reduced stainless steel,aluminum,fiberglass,plastic or plastic-lined steel containers. performance. Database and format copyright rj hp Vance Communication Corporation. All rights reserved. SPECIMEN LABEI- L'i'DATIiS A\r;SILABLts AT VVWW.GREENI3001<.NEI' 2 ' For best results, spray coverage should be unifrmn and complete. Do not spray tank. If ammonium sulfate is added directly to the spray tank,add slowly with weed foliage to the point of runoff. agitation. Adding too quickly may clog outlet line. Ensure that ammonium sulfate DOMESTIC ANIMALS-This product is considered to be rulatively nontoxic to is completely dissolved in the spray tank before adding herbicides. Thoroughly dogs' and other domestic animals; however, ingestion of this.prodrinse the sprayuct or large system with clean water after use to reduce corrosion. amounts of freshly sprayed vegetation may result in temporary gastrointestinal NOTE:When using ammonium sulfate as an additive,do not use herbicide rates irritation(vomiting,diarrhea,coliF,etc.). If such symptoms are observed,provide Inver than recommended in this.label. the animal with plenty of fluids to prevent dehydration. Call a veterinarian if COLORANTS.OR DYES symptoms persist for more than 24 hours. Agriculturalisorly-approved used i colorants or marking dyes may be added to this product. Remove domestic livestock before pasture application and wait R weeks after Colorants or dyes used in spray solutions of this productmay reduce performance, application before grazing or harvesting. especially at lower rates or dilutions. Use colorams or dyes according to the ATTENTION manufacturer's recommendations. AVOID DRIFT.EXTREME CARE MUST BE USED WHEN APPLYING THIS APPLICATION EQUIPMENT AND TECHNIQUES PRODUCT TO PREVENT INJURY TO DESIRABLE PLANTS AND CROPS. Do not apply this productthrough any type of irrigation system. Do not allow the herbicide solution to mist, drip, drift or splash onto desirable This product may be applied with the following application equipment: vegetation since minute quantities of this product can cause severe damage or Aerial—Fixed Wing and Helicopter m the crop,plant or other areas on which treatment was not intended. The likelihood of injury occurring from the use of this product is greatest when Broadcast Spray winds are gusty or in excess of 5 miles per hour or when other conditions, Controlled Droplet Applicator(CDA)—Eland-held orboom-mouneclapplicators including lesser wind velocities,will allow spray drift to occur. When spraying, which produce a spray consisting of a narrow range of droplet sizes. avoid combinations of pressure and nozzle type that will result in splatter or fine Hand-Held and Hi hA'olume Spray Equipment—Knapsack and back ack particles(mist)which are likely to drift. AVOID SPRAYING AT EXCESSIVE- g P Yp SPEED OR PRESSURE. sprayers,pump-up pressure sprayers,handguns,hardwoods,mistblowcrs';lances NOTE: Use of this Induct in an manner not consistent with This label may and other hand-held and motorized spray equipment used to direct the spray unto P Y ) weed foliage result in injury to persons,animals or crops, or other unintended consequences. Keep container closed to prevent spills and contamination. 'This product is not registered in California or Arizona for rise in mistblowcrs. MIXING,ADDITIVES AND APPLICATION INSTRUCTIONS Selective equipment—Recirculating sprayers,shielded sprayers and wiper appli- APPLY THESE SPRAY SOLUTIONS IN PROPERLY MAINTAINED AND calm's. CALIBRATED EQUIPMENT CAPABLE OF DELIVERING DESIRED VOL- Sec the appropriate part of this section for specific instructions and rates of UMES. DO NOT APPLY WHEN WIND OR OTHER CONDITIONS FAVOR application. DRIFT. HAND-GUN APPLICATIONS SHOULD BE PROPERLY DIRECTED AF,RIAI,EQUIPMENT TO AVOID SPRAYING DESIRABLE PLANTS. Use lbe recommended rates of this herbicide in 3 to 15 gallons of water per acre NOTE:REDUCED RESULTS MAY OCCUR IF WATER CONTAINING SOIL unless otherwise specified on this label. See the "WEEDS CONTROLLED" IS USED,SUCH AS WATER FROM PONDS AND UNLINED DITCHES, section of this label for specific rates. Unless otherwise specified,do not exceed MIXING I quart per acre. Aerial applications of this product may be in annual cropping This product mixes readily with water. Mix spray solutions of this product as conventional tillage systems,fallow and reduced tillasesystems and preharccstap- follows: fill the mixing or spray tank with the required amount of water. Add plications. Reform the individual use arca sections of this label for recommended clic recommended amount of this product(sec the "DIRECTIONS FOR USE" volumes and application rates. FOR AERIAL APPLICATION IN CALIFORNIA, and"WEEDS CONTROLLED"sections of this label)near the end of the filling sec below. process and mix well. Use caution to avoid siphoning back into The carrier Avoid direct application to any body of water. source. Use approved anti-back-siphoning devices where required by state or AVOID DRIFT—DO NOT APPLY DURING LOW-LEVEL INVERSION CON- local regulations. During mixing and application,foaming of the spmy solution DITIONS, WHEN WINDS ARE GUSTY OR UNDER ANY OTHER CONDI- may occur. To prevent or minimize foam,avoid the use of mechanical aggtlators, TION WHICH FAVORS DRIFT. DRIFT MAY CAUSE DAMAGE TO ANY termnatc by-pass and return lines at the bottom of the tank and, if needed,use VEGETATION CONTACTED TO WHICH TREATMENT ISNOT INTENDED, an approved anti-foam or dcfoaming agent. TO PREVENT INJURY TO ADJACENT DESIRABLE VEGETATION,APPRO- TANK MIXTURES PRIATE BUFFER ZONES MUST BE MAINTAINED. Always predetermine the compatibility of labeled tank mixtures of this product Coarse sprays arc less likely to drift; therefore, do not use nozzles or nozzle with water carrier by mixing small proportional quantities in advance. Mix labeled configurations which dispense spray as fine spray droplets. Do not angle nozzles tank mixtures of this product with water as follows: forward into the airstream and do not increase spray volume by increasing nozzle 1. Place a 20 to 35 mesh screen or wetting basket over filling port. pressure. 2. Through the screen, fill die spray tank one-half full with water and start Drift control additives may be used. When a drift control additive is used,read and agitation. carefully observe the cautionary statements and all other information appearing 3. if a wettable powder is used,make a sl any with the water carrier,and add it on the additive label. SLOWLY through the screen into the tank. Continue agitation. Ensure uniform application—To avoid streaked,uneven oroverlappcd application, 4. if a flowablc formulation is used,premix one part flowablc with one part water, use appropriate marking devices. Add diluted mixture SLOWLY through the screen into the tank. Continue Thoroughly wash aircraft, especially landing gear, after each day of spraying agitation. to remove residues of this product accumulated during spraying or from spills. S. If an emulsifiable concentrate formulation is used,premix onepart emulsifiable PROLONGED EXPOSURE OFTHIS PRODUCI'TOUNCOATED STEEL SUR- concentrate with two pans water. Add diluted mixture slowly through the screen FACES MAY RESULT IN CORROSION AND POSSIBLE FAILURE OF THE into circ tank. Continue agitation. PART. LANDING GEAR ARE MOST SUSCEPTIBLE. The maintenance of an fi. Continue filling the spray Lank with water and add the required amount of Orris organic coating(paint),which meets aerospace specification MIL-C-38413,rimy product near the end of the filling Process. be used to prevent corrosion. 7. Add individual fommlations to the spray Lank as follows: wettable powder, This product plus Oust,Dicamba or 2.4-D lank mixtures may not be applied by flowablc, emulsifiable concentrate, drift control additive, followed by water air in California. soluble liquid. SPRAY DRIFT MANAGEMENT Maintain good agitation at all times until the contents of the tank are sprayed. If Avoiding spray drift at the application site is the responsibility of the applies- the spray mixture is allowed to settle,thorough agitation is required to resuspend tor. The interaction of many cquipnnent-and-weather-related factors dctcnmin, the mixture before spraying is resumed. the potential for spray drift. The applicator and the grower arc responsible for Keep by-pass line on or near bottom of tank to minimize foaming. Screen considering all (hese factors when making decisions. The following drift man- size to nozzle or line nozzle or line strainers should be no finer than 50 mesh. agcnrcnt requirements must be followed to avoid off-target drift movement from Carefully select proper nozzle to avoid spraying a fine mist. For best results with aerial applications to agricultural field crops. These requirements do not apply to conventional ground application equipment, use flat fan nozzles. Clean sprayer forestry applications,public health uses or to applications using dry formulations. and parts immediately after using Orris product by thoroughly flushing with water. I The distance of the outer most nozzles on the boom must not exceed Va the ADDITIVES length of the wingspan or rotor. AMMONIUM SUCRATE 2 Nozzles must always point backward,parallel with the air stream and never be The addition of I to 2 percent dryammonium sulfate by weight or 8.5 to 17 Pounds pointed downwards more than 45 degrees. Where states have more stringent per 100 gallons of water may Increase the performance of this product and this regulations,they should be observed. product plus 2,4-D, Dicamba1a or residual herbicide tank mixtures on annual The applicator should be familiar with and take into account the information and perennial weeds. The improvement in performance may be apparent where covered in the Aerial Drift Reduction Advisory Information. environmental stress is a concern. Low-quality ammonium sulfate may contain Importance of Droplet Size material that will not readily dissolve,which could result in nozzle lip plugging. P p To determine quality;perfomn ajar test by adding Un cup of ammonium sulfate to The most effective way to reduce drill potential is to apply large droplets.The best I llo gan of water and agitate for I minute. If undissolved sediment is observed, drill management strategy is to apply the largest droplets that provide sufficientpredissolve the ammonium sulfate in water and filter prior to addition to the spray coverage and control. Applying largodroplets reduces drill potential, but will Database and format copyright C1 by Vance Communication Corporation. All rights reserved. SPECIMEN LABEL LII'DATES .AN'AII,ABI,E A'I'�YWW'.(;REN;NBOOK.NF I' 3 not prevent drift il'applications are made improperly,or under unfavorable cn- 2. If wind up to 5 miles per hour is blowing toward desirable vegetation of crop(s). vironmental conditions(sec Wind,Temperature and Humidity,and Tcmpcmtuic do not apply within 500 feet of the desirable vcgdation or crop(s). Inversion section of this label). 3. Winds blowing front 5 to 10 miles per hour toward desirable vegetation or Controlling Droplet Size crop(s)may require buffer zones in excess of 500 feet. Volume—Use high flow rate nozzles to apply the highest practical spray volume. 4. Do not apply when winds arc in excess of 10 miles per hour or when inversion Nozzles with higher rated flows produce larger droplets. conditions exist. Coarse sprays are less likely to drift; therefore, do not use nozzles or nozzle Pressure reduces Use lilt. Inver spray pressures recommended for the tectio Higher configurations which dispense spray as fine spray droplets. Do not angle nozzles prossurcwrat droplet size and docs not improve canopy protection. When forward into the airstream and do not increase spray volume by increasing nozzle higher flow rates are needed,use higher flow rate nozzles instead of increasing pressure above the manufacturer's recommendation, pressure Drift control additives may be used.When a drift control additive is used,mad and Number of nozzles—Use the minimum number of nozzles that provide uniform carefully observe die cautionary slstements and all other information appearing coverage. oil the additive label. Nozzle Oricnmtion--Orienting nozzles so that the spray is released backwards, Ensure uniform application—to avoid streaked uneven or overly parallel to the airstream will produce larger droplets than other orientations. VF overlapped application, Significant deflection from the horizontal will reduce droplet size and increase use appropriate marking devices drift potential. Thoroughly wash aircraft, especially landing gear, after each day of spraying Nozzle Type—Use a nozzle type that is designed for the intended application. to remove residues of this product accumulated during spraying or from spills. With most norzle types,nan'ower spray angles produce larger droplets. Consider PROLONGED EXPOSURE OFTHIS PRODUCT TO UNCOATED STEEL SUR- using low-drift nozzles.Solid stream nozzles oriented straight back produce larger FACES MAY RESULT IN CORROSION AND POSSIBLE FAILURE OF THE droplets than other nozzle types. PART. LANDING GEAR IS MOST SUSCEPTIBLE. The maintenance of an organic coating(paint)which meets aerospace specification MIL-C-38413 may Boom Length—Por sonic use patterns,reducing the effective boom length to less prevent corrosion. ' than 34 of the wingspan or rotor length may further reduce drift without reducing FOR AERIAL APPLICATION IN FRESNO COUNTY,CALIFORNIA ONLY swath width. Application—Applications should not be made at a height greater than 10 feet From February 15 through March 31 only. For aerial application outside of these above the lop of the largest plants unless a greater height is required for aircraft dates,refer to tlm "FOR AERIAL APPLICATION IN CALIFORNIA ONLY" safely. Making applications at the lowest height that is safe reduces exposure of section printed above. droplets to evaporation and wind. APPLICABLE AREA - Swath Adjustment This supplementonly applies to the arca contained inside the following boundaries Mien applications arc made with a cross-wind the swath will be displaced within Fresno County,California only. downwind Therefom,on die rip and downwind edges of the field,the applicator North: Fresno County line mustconipcnsate forihis displacententby adjusting the path of file aircraft upwind. South: Fresno County line Swath adjustment distance should increase,with increasing drift potential(higher Faso: State Highway 99 wind,smaller drops,etc.), west. Fresno County line Wind GENERAL INFORMATION Drift potential is lowest between wind speeds of 2 to 10 mph. I lowever, many Always read and follow Elie label directions and precautionary statements far all factors,including droplet size and equipment type determine drift potential at any products used in the aerial application. given speed Application should be avoided below 2 mph due to variable wind Observe the following directions to minimize off-site movement during aerial ap- direclion and high inversion potential. Note: Local terrain can influence wind plication til this hcrbicidc. Minimizationof mize osile tc movement n the resduring aerial up- patterns. Every applicator should he familiar with local wind patterns and how they offset drift. of the grower,Pest Control Advisor,and aerial applicator. Temperature And Humidity WRITTEN RECOMMENDATIONS When making applications in low relative humidity,set up equipment to produce A written recommendation MUST be submitted by or on behalf of the applicator .larger droplcLs to compensate for evaporation. Droplet evaporation is ilhcar severe to the Fresno County Agricultural Commissioner 24 hours prior to the application. when conditions are both hot and dry. This written recommendation MUST state the proximity of surrounding crops,and [flat conditions of each manufacturer's applicable product labcl(s)and this label Temperature Inversions have been satisfied. Applications should not occur during a temperature inversion,because drift Po- AERIAL APPLICATOR TRAINING AND EQUIPMENT tential is high. Temperature inversions restrict vertical air mixing which causes Aerial application of this herbicide is limited to pilots who have successfully small suspended droplets to remain in a concentrated cloud. This cloud can move completed a Fresno County Agricultural Commissioner and California Depart- in unpredictable directions due to die light variable winds common during inver- mens of Pesticide Regulation approved training program for aerial application of Siong, Temperature inversions am characterized by increasing temperatures with herbicides. All aircraft must be inspected, critiqued in flight, and certified at altitude and are common on nights with limited cloud cover and light to no wind. a Fresno County Agricultural Commissioner approved fly-in. Test and calibrate They begin to form as the sun sets and often continue into the morning. Their spray equipment at intervals sufficient to insure that properrates of herbicides and presence can be indicated by ground fog;however,if fog is not present,inversions adjuvants are being applied during commercial use. Applicator must document can also be identified by the movement or smoke from a ground source or an such calibrations and mstine. Demonstration of performance at Fresno County aircraft smoke generator. Smoke that layers and proves laterally in a connected Agricultural Commissioner approved "fly-ins" constitutes such documentation, cloud(under low wind conditions)indicates an inversion,while smoke that moves or other written records showing calculations and measurements of flight and upwards and rapidly dis's'ipates indicates good vertical air mixing. spray parameters acceptable to due Fresno County Agricultural Commissioncr. Sensitive Areas Application at night—Do not apply this product by air earlier than 30 minutes The pesticide should only be applied when the potential for drift to adjacent prior to sunrise and/or later than 30 minutes after sunset without prior permission sensitive areas(e.g.,residential areas,bodies of water,known habitat for threatened from the Fresno County Agricultural Commissioner. or endangered species.non-target crops) is minimal(e.g. when wind is blowing To report known or suspected misuse of this product or for additional information away from the sensitive areas). on the proper aerial application of this product,call 1-800-852-5234. FOR AERIAL APPLICATION IN CALIFORNIA ONLY Read the"WARRANTY"section in this label booklet before using this product. EXTREME CARE MUST BE EXERCISED TO AVOID CONTACT OF SPRAT' BROADCAST EQUIPMENT WITH FOLIAGE, GREEN STEMS. OR FRUIT OF DESIRABLE CROPS, For control of annual or perennial weeds listed on [his label using broadcast PLANTS, TREES,OR OTHER DESIRABLE VEGETATION SINCE SEVERE equipment—Use the recommended rates of this product in 3 to 40 gallons of water DAMAGE OR DESTRUCTION MAY RESULT. per acre as n broadcast spray unless otherwise.specified on this label. Sec the Nonerop Sites "WEEDS CONTROLLED"section of this label for specific rates. As density of When applied as directed and under die conditions describedin the "Weeds weeds increases,spray volume should be increased within the recommended range Controlled" section of the label booklet for this product, this herbicide will to ensurecomplete coverage. Carefully select proper nozzle to avoid spraying a control or partially control the libeled weeds growing in the following industrial, fine mist For best results with ground application equipment,use flat fan nozzles. recreational and public areas,or miler similar sites. Check for even distribution of spray droplets. AVOID DRIFT--DO NOT APPLY WHEN WINDS ARE GUSTY OR UN- CONTROLLED DROPLET APPLICATION(CDA) DER ANY OTHER CONDITION WIIIC14 WILL ALLOW DRIFT. DRIFT The rate of this product applied per acre by vchicic-mounted CDA equipment MAY CAUSE DAMAGE TO ANY VEGETATION CONTACTED TO WHICH must not be less than Elie amount recon mendcof in this label when applied by TREATMENT IS NOT INTENDED. TO PREVENT INJURY TO ADJACENT conventional broadcast equipment. For vchicic-ntmuhicd CDA equipment apply 3 DESIRABLE VEGETATION, APPROPRIATE BUFFER ZONES MUST BE to conventional 5 gallons of water per acre. Use the MED, For the control of labeled annual weeds with hand-held CDA units, apply a 20 Use the following guidelines when aerial applications are made near crops or percent solution of this product at a flow rate of 2 fluid ounces per minute and a desirable perennial vegetation atter bud break and before total ]car drop,and/or walking speed of 1.5 MPH(I quart per acre). For the control of labeled perennial near other desirable vegetation or annual crops. weeds,apply a 20[0 40 percent solution of this product at a now rate of 2 fluid I. Do not apply within 100 feet of all desirable vegemtion or crop(s). ounces per minute and a walking speed of 0.75 mph(2 to 4 quarts per acre). Database and format copyright CD by Vance Communication Corporation. All rights reserved. SPE'CIME.N LABEL - UPDA'T'ES ANrAILABt,E A'f WW'RCGl2EENBOOK.Nh:T- 4 - Controlled droplet application equipment produces a spray patten which is not WIPER APPLICATORS casilyvisible. Extreme care must be exercised to avoid spray ordrift contacting the Wiper applicators ate devices that physically wipe appropriate amounts of this foliage or any other green tissue of desirable vegetation,as damage or destruction product directly onto the weed. may result - Equipment must be designed,maintained and operated to prevent the herbicide HAND-HELD and HIGH-VOLUME EQUIPMENT solution from contacting desirable vegetation. Operate this equipment at ground USE COARSE SPRAYS ONLY) speeds no greater than 5 mph. Performance may be improved by reducing speed Mix this product in clean water and apply to foliage of vegetation to be controlicd. in areas of heavy weed infestations to ensure adequate wiper saturation. Better For applications made on a spray-to-wet basis,spray covemgc should be uniform results may be obtained if 2 applications arc made in opposite directions. and complete. Do spray to the point of mmof.. Avoid leakage or dripping onto desirable vegetation. Adjust height of applicator For control of annual weeds listed on this label,apply a 0.5 percent solution of to ensure adequate contact with weeds. Keep wiping surfaces clean. Be aware this product los nonionic surfactant to weeds less than 6 inches in height or that,on sloping ground,the herbicide solution niay migrate,causing dripping on P P g the lower end and drying of the wicks on the upper end of a wiper applicator. runner length. Apply prior to sccdhcad formation in grass or bud fornmtion in broadlcaf weeds. Allow three or more days before tillage or mowing. Do not use wiper equipment when weeds are wet. For annual weeds over 6 inches tall, or unless otherwise specified, use a I Mix only the amount of solution to be used during a I-day period,as reduced percent solution. Far best results, use a 2erocnt solution on harder-to-control activity may result from use of Iellover Solutions. Clean wiper parts immediately perennials,such as Bcrmudagrass,dock,field bindweed,hemp dogbane,milkweed after using this product by thoroughly flushing with water. and Canada thistle. Do not add surfactant to the herbicide solution. When using application methods which result in less(ban complete coverage,use For Rope or Sponge Wick-Applicators—Mix I gallon of this product in 2 a 5 percent solution for annual and perennial weeds and a 5 to 10 percent solution gallons of water to prepare a 33 percent solution. Apply this solution to weeds for woody brush and trues. listed in this "WIPER APPLICATORS" section. Prepare the desired volume of spray solution by mixing the amountof this product For Porous-Plastic ApplicatorsSolutions ranging from 33-to 100 pement of in water as shown in the following table: this product in water may be used in porous-plastic wiper applicators. SPRAY SOLUTION - When applied as recommended under to conditions described for"WIPER AP- PLICATORS", this product CONTROLS the following weals: AMOUNT OF RAZOR PRO HERBICIDE ANNUAL GRASSES- DESIRED VOLUME rh% 1% 1'4% 2% 57 10% Corn Rye,common Zen mnvs Secale cerculc I Gal. '!,nz. I Lo oz. 2 mz. 2Y,oz. 6 Lj ex. 13 ox. Panicum,Texas Shattercane 25 Gal. I pt. I qt. I!}qt. 2 qr. 5 qt. 10 qt Panicum texnnum Sorglmm bicolor 100 Gal. 2 qt. I I gal. 10.gal. 2 at. s gal. 10 gal. ANNUAL.BROADLEAVES 2 tablespoons=1 fluid ounce Sicklepod Bidens bipirmalu P Cassia obursifolia Starbur,bristly For use in knapsack sprayers,it is suggested that the recommended amount of this Spanishneedles Acundmspernrum hispidum product be mixed with water in a larger container. Fill sprayer with the nixed solution. When applied as recommended under the conditions described for"WIPER AP- SELECTIVE, EQUIPMENT PLICATORS", this product SUPPRESSES the following weeds: This product may be applied through a recirculating spray system, a shielded ANNUAL BROADLEAVES applicator,or a wiper a4cr dilution and thorough mixing with water to listed weeds Begganveed,Florida Ragweed,giant growing in any noncrop site specified on this label and only when specifically Desniodiunr lorluosnm Arohrosin o'ifidu recommended in cropping systems. Dogfennel Sunflower A recirculating spray system directs the spray solution onto weeds growing above L•upalorium capilliJlorhon HelianUms nunuus desirable vegetation,while spray solution not intercepted by weeds is collected Pigweed,redroat Thistle,musk and returned to the spray tank for reuse. Anmranthus retrgllexus Curduus nulans A Shielded applicator directs the herbicide solution onto weeds,while shielding Ragweed,common Velvedeof desirable vegetation fioni the hcrbicidc. Ambrosia artemot/olia Abundou dreophrasli A wiper applicator applies the herbicide solution onto weeds by rubbing the weed PERENNIAL GRASSES with an absorbent material containing the herbicide solution. Bermudagrass .Sorghum haleperrse AVOID CONTACT WITH DESIRABLE VEGETATION. Cynodmr darNlon Smutgrass Contact of the herbicide solution with the desirable vegetation may result in Guineagrass Sporobohr.rpoirelii damage or destruction. Applicators used above desired vegetation should be Ponimmr marimuur Vaseygrass adjusted so that the lowest spray stream or wiper contact pointis at(cast 2 inches Juhnsongrass Parpnhmr ,,villei above the desirable vegetation. Droplets,mist,foam,or splatter of the herbicide PERENNIAL BROADLEAVES solution settling on desirable vegetation may result in discoloration,stunting or Do bane,hem Nightshade,silverleaf destruction. Apoeynuna conribinum Solunum elaeugnifolium Applications made abovclhc props should be made when the wccds arcaminimum Milkweed Thistle,Canada of 6 inches above the desirable vegetation. Better results may be obtained when Ascelepias syriuca Cicsium urvense more of the weed is exposed to the herbicide solution. Weeds not contacted by the herbicide solution will not be affected. This may occur in dense clumps, WEEDS CONTROLLED severe infestations or when the height of the weeds varies so that not all weeds This herbicide controls many annual and perennial grasses and broadlcaf weeds. arc contacted In these instances,repeat treatment may be necessary. SHIELDED APPLICATORS ANNUAL WEEDS • Apply in actively growing grass and broadlcaf weeds. When applied as directed under conditions described for shielded applicators,this . Allow at least 3 days after treatment before tillage. product will control those weeds listed in the"WEEDS CONTROLLED"section For maximum agronomic benefit,apply when weeds arc G inches or less in of this label. Use the following equation to convert from a broadcast rale per acre height to a band rate per acre. . To prevent seed production, applications should be made prior to sccdhcad formation. •This product docs not provide residual control;therefore,delay applicauon until Band width in inches >< Herbicide Broadcast = Flerbicide Band maximum weed emergence.Repeat treatments may be necessary to control later Row width in inches RATE per acre RATE per acre germinating weeds, LOW-VOLUME BROADCAST APPLICATION (LOW-RATE TECIINOL: Band width in inches Broadcast VOLUME _ Band VOLUME OGY) x of solution per acro of solution per acre When applied as directed under the conditions described,this product Will control Row width in inches P ' the weeds listed below when water cortico volwnac of 3 l0 10 gallons per acre for ground applications and 3 to 5 gallons per acre for aerial applications arc Use nozzles that provide uniform coverage within the treated arca. Keep shields recommended. (Sec the "AERIAL APPLICATION" section of this label for on shielded sprayers adjusted to protect desirable vegetation. approved sites.) EXTREME CARE MUST BE EXERCISED TO AVOID CONTACT WITH DE- NOTE SIRABLE VEGETATION. r The addition of 2 percent dry ammonium sulfate by weight or 17 pounds per For specific rales of application and instructions for control of various annual and 100 gallons of water may increase the performance of this product on annual perennial wccds,sec the"WEEDS CONTROLLED" section of this label. weeds.The improvement in performance may be apparent where environmental Database and format copyright'©Ile Vance Communication Corporacion. All rights reserved. SPECIMEN LABEL UPDATES AVAILABLE AT WWW.GREFNBOOK.NET 5 stress is a concern. Refer to the"MIXING,ADDITIVES and APPLICATION MAXIMUM HEIGHT/ RATE PER ACRE- INSTRUCTIONS" section of this label. WEED SPECIES LENGTH (Fluid Ounces) • Do not tank-mix with soil residual herbicides when using these rales unless Jolmmm,rass.seedling otherwise specified. ,Sorghum halcpease • For weeds that have been mowed,grazed or cut,allow regrowth to occur prior Outs,wild to treatment I Awso.fuma • Refer to the "TANK MIXTURES" portion of this section for control of Ponicum,fall additional broadlcafwceds. P m madwhmomiijlmam Femme.,Tessa Panimm lesaanr MAXIMUM HEIGHT/ RATE PER ACRE- Pigsveed,redrout WEED SPECIES LENGTH (Fluid Ounces) Amarnnllnummillexue' Foxtail 12" g oz Gruundsel,common Serono spp. Senecio vuls,"a Pigweed,smooth 12" - 16 oz Barnyardgrass 6" 12 oz Amaranlhas hy'b,kh. - Ecmm,hloncros-gulli (0 to 4" 16 oz.') Witchgrass (4 to 6" 24 oz') pam ma caPillmm Bluegrass,annual - Sicklepod 3 la 4" 24 oz. 1'oa.,roue Broom,downy-- Cassia mvesifnlia !,mous rccrarum Signalgrass broadleaf 4" Mustard,blue Brarhioda planpbylln Charispnra(cue//a HarseweedlMarestail I to 12" Mustard,tansy _ C'onym ccm.dana, Descwninia planta Lambsquarters,common Mustard,tumble Chenopodunu.1bum Shymbrimn nhissluma, Spurge,annual Mustard,wild Enphmbia app. Sinapis ravens's Rice,red 4" 32 oz. Sperry,umbrella - Orymsmiva Holow,ma um a lla ma Teaweed Barley 12" Sida spinosa I/oMeum vulgure Sprangletop (i' Rye Leptochloaspp. - Sccale cereale Shattemmm, 12" - Geranium,Carolina 12" SorgIron basalar. Geranium cmvlinlau. Stinkgross Goomgmss Erng,.nr cilmaeo is. Elcusine indica Primrose,cutleaf evening Wheat IS" Cenntheru luetawle D bias aertivun' Pusley,Florida Morningglary 2" 16 oz. Richardiascahra 1parnoeo.spl, - Sicklepod 5 to 12" Sicklepod - Cassia obnaeifolia Cassia obnaifoli. Spanishneedles [Bluegrass,bulbous 6" Bidcus bimmn ars pas lahmsa Filaree 12" 48 oz. Cheat E Bur .mus mngle spp. romsec Chickweed,common Spngletop Sreliaria media Leplodrlaa spp. Chickweed,mouseear 'Use these mics to control hamyanlgmss in Alabama,Arkansas, Mississippi, Missouri, Cemsrium vulgamm Corn Louisiana and Texas for preplant treatments. Zen mala 'For those rates less than 32 fluid ounces per acre,this product at rates up to 32 fluid' Coatgrass,jointed ounces per acro may he used where heavy weed densities exist. Aegilaps ylmdrio. Sandbur,Beld ^'Far contnd in no-till systems,use 16 fluid ounces per acre. Cemloos.s/'/'' TANK MIXTURES Ilenbit 6" 16 oz. I,umium umplmicm 1" Razor Pro I Icrbicidc plus DICAMBA ItorseweM/Marsstail Razor Pro Herbicide plus 2,4-D Come.canadenra DO NOT APPLY DICAMBA OR 2,4-D TANK MIXTURES BY AIR IN CAL- Lambsquartem,common - IFORNIA. Chenopodium album Pennyeress,field 'these lank mixtures are recommended for use in fallow and reduced tillage areas b'mrmeed Thlaspi or., only. Follow use directions as given in the."LOW-VOLUME BROADCAST Rocket,london APPLICATION" section. - Sirymhrinm me This product plus DICAMBA or 2.4-D will control the annual grosses and Ryegrass,Italian broadlcaf weeds listed for this product alone at the indicated heights (except Loh rnuaiflma. S fluid ounces per acre applications), plus the following broadleaf weeds. For Shepherdapurse (hose weeds previously listed at R fluid ounces of this product alone per acre,use Capsella ba.-pastoris 12 fluid ounces in these tank mixtures. Spuplmr* sp, NOTE: Refer to flre specific product labels for crop rotation restrictions and oual fterc p spp. cautions statements of all products used in tank mixtures. Some crop injury Buttercup 12" may occur if Dicamba is applied within 45 days of planting. The addition of ocklebulru app, Y Pp R. P' g. Cocklebur Dicamba in a mixture with this product may provide short-icon residual control Xambiam snunmriurn of selected weed species. - Crabgrass Apply 12 to 16 fluid ounces of this product plus 0.25 pound a.i. of Dicamba or Digma,w epp. 0.5 pound a.i. of 2,4-D per acre to control dense populations of the following Domrfdandelion annual broadicaf wccds when less than the height indicated: Krigia cmpiw. Cocklebur(12") Lambsquarters(12") Falseflax,smallseed Xanlhlum slrumurium Chenopodium album Camelia macrocarpa Kochiaa(6") Lettuce,prickly(61') Foxtail,Carolina Alapecurrrs comlin...... - Knchia scaparia Lacmn+serrinfa Database and format Copyright CO by Vance Communication Corporation. All rights resetwed. SPECIMEN L.ABEI., UPDATES AVAILABLE: AT\VWW.GRF-.ENBOOK.NET 6 - MaresfaiiMorseweed(6") Amaanlurs rargflerns Ice Plant Canium maculalum Caq¢a canadensis Pigweed,smooth(12") d4esembrymNhemmn mysia/limon Quackgrass Morningglory(6") .amrranrhus hybridns Johnsongrass Agropyron repen.s Ipomoea spp. Thistle,Russian(12") Sorghum halepense Redvine- Pigweed,redrool(12") Salsola kali Kikuyugrass Brunnichia ovau Pennisetrrrm clandestinum Reed,ggiant *Controlled with Dicamba auk mizlure only. Knapweed - Arunda donux Cntana areperrr Ryeg...ipperennial Apply 16 fluid ounces of this product plus 0.5 pound a.i. of 2.4-D per acre to Lantana Lolimu perenne control the following annual broadleaf weeds when less than 6 inches in height Lantana camera Smartweed,swamp Ragweed,common Smarbveed,Pennsylvania Lespedeza Polygonum coccineum Ambrosia artenrisi folia Polygonum pensylvpnicum Lespedeza spp. Spurge,leafy* Ragweed,giant Velvetleaf Milkweed F,uphorbia esula Ambrosia Irifrda Abundant theophrasli Asclepias spp. Starthistle,yellow Mohly,wirestem Centmvea solsinalis HIGH-VOLUME BROADCAST APPLICATIONS Muhlenbergiaftondonsa Sweet potato,wild- When applied as directed under die conditions described,this product will control Mullein,common Ipomoea pmnhrrala Napiergras the weeds listed below when water carrier volumes arc 10 to 40 gallons per re acterbascIhapsus Thistle,Canada s Casino;arvnrse for ground applications. P¢nniselum purpureum Thistle,artichoke. Apply I to 1.5 quarts of this product per acre. Use 1 quart per acre if weeds Nightshade,silverlcaf Cynara cardunculus are less than 6 inches tall and 1.5 quarts per acre if weeds arc over 6 inches tall. Solamon elaeagnifolium Timothy If weeds have been mowed,grazed or cut,allow adequate time for new growth Nutsedge;purple,yellow Phleum prateuse to reach recommended stages prior to treatment. These rates will also provide Cyperus rohmdus Torpedograss- control of weeds listed in the"LOW-VOLUME BROADCAST APPLICATION" Cyperus esculenas Panicum repens section. Orchardgrass Trumpetereeper* WEED SPECIES Ductyiis glomeram Campsis radicans Balsamapple* Panicum Pampasgrass Vaseygrass Afomordica charantia Panicum spp. Cortaderia spp. Paspalum urvillei Bassin,fivehookRagweed,common Paragrass Velvetgrass Barsia hyssopifolia Ambrosia arlemaiifalia Brachiarin nalica Halcut spp. Brame Ragweed,giant Phragmites° Wheatgrass,western Bromus spp. Ambrosia mi/idn Phragmites spp. Agropvron smilhii Fiddleneck Smartweed,Pennsylvania Poison hemlock Amsinckia spp. Polygonum pensylvmricum "Partial Cannot Fleabanrrige o Sowlhtss O annual This product is not registered in California for use on water Bcrinuda rays. Fealig e,spp. unflosonchwsoleracmrs P g' S Fleabane,hairy Sunflower See "DIRECTIONS FOR USE" and "MIXING, ADDITIVES and APPLICA- Conyza bonariensis Heliout6as amrms TION INSTRUCTIONS" sections of(bis label for labeled uses and specific Kochia Thistle,Russian application instructions. Kochia xenparia Sn6»lo kali Alfalfa—Apply I quart of this product per acre in 3 to 10 gallons of water per Lettuce,prickly Velvedeaf acre. Make application alter the last hay cutting in the Fall. Allow alfalfa to Lacluca serriola Abutilon lheophrrrsli regrow to a height of 6 to g inches or inure prior to licatnicnt. Applications should be followed with deep tillage at least 7 days after treahncnt.but before "Apply with hand-held equipment onlysoil freeze-up. PERENNIAL WEEDS Alligafonveed—Apply 4 quarts of this product per acre or apply a 1.5 percent solution with hand-held equipment to provide partial control. Apply when most Apply this product as follows to control or destroy most perennial weeds: of the plants arc in bloom. Repeat applications will be required to maintain such NOTE:If weeds have been mowed or tilled,do not treat until plants have resumed control. active growth and have reached the recommended stages. Repeat treatments may Anise(fennel) Poison hemlock—Apply a I to 2 percent solution of this product be necessary to control weeds regenerating from undergroundparts or seed.Repeat as a spray-to-wet treatment. Optimum results are obtained when plants arc treated treatments must be made prior to crop emergence.Ilic addition of I to 2 percent at the bud to full-bloom stage of growth. Repeat applications may be needed in dry ammonium sulfate by weightor 8.5 to 17 pounds per 100 gallons of water may succeeding years to control plants arising from seeds increase the performance of this product on perennial weeds. The improvement Bentgrass—For suppression in grass seed production areas. For ground appli- in performance may be apparent where environmental stress is a concern, cations only, apply 1.5 quarts of this product in 10 to 20 gallons of water per Refer to the "MIXING, ADDITIVES and APPLICATION INSTRUCTIONS" acre. Ensure entire crown arca has resumed growth prior to a Fall application. section of this label. Bengrass should be actively growing and have at(cast 3 inches of growth.Tillage When applied as recommended under the conditions described,this product WILL prior to treatment should be avoided. Tillage 7 to 10 days after application is CONTROL the following PERENNIAL WEEDS: recommended for best results. Failure to use tillage after treatment may result in Alfalfunacceptable control. Aledi CansPhoto,is a, ,recd Bermudagrass—For control,apply 5 quarts of this product per acre. For partial Me atiorw sauna Cattail urwrdinrrccn Alligatarwced' Cattail cannot,apply 3 quarts per acre. Trial when Bermudagrass is actively growing Allernanthera philareroides TiTha spp. and-seedhcads are present. Retreatment may be necessary to maintain control.- Anise(fennel) Clover,red Allow 7 or more days after application before tillage. Fomricuiculumum vulgar: Trifnlium proteose Bermudagrass,water(kno[grass)—Apply 1.5 quarts of this product in s to 10 Artichoke,Jerusalem Clover,white gallons of water per acre. Apply when water Berionalagrass is actively growing Helix thus tuberosus Tr'ifolium repens and 12 in 18 incites in Icngth. Allow 7 or more days before tilling, Rushing or Bahiagrass Cogmngross flooding the field. Paspalum nolalum Imperala cy'liedr'ica Fall applications only Apply I quart of this product in 5 to 10 gallons of water Bentgrass Dallisgrass per acre. Fallow fields should be tilled prior to application. Apply prior to frost Ag,ovis spp. Pospahuu dilutor.. on water Bermudagrass that is actively growing and 12 to 19 inches in Icngth. Bermudagrass Dandelion Allow 7 or more days before tillage. Cvnodon daclylon Taraxacum gjrcinale Bindweed, field—For control,apply 4 to 5 quarts of this product per acre west Bermudagrass,seater(knotgrass) Dock,curly of the Mississippi River and 3 to 4 quarts cast of the Mississippi River. Apply Paspahmr dirtichuor Rumex crisp°'° when the weeds arc actively growing and arc at or beyond full bloom. Do not Bindweed,field Dogbane,hemp treat when weed is under drought sh'ess as good soil moisture is necessary for Cornmlvulus arvensis Apncynum cannabinunr active growth. For best results, apply in late Summer or Fall. Fall treatments Bluegrass,Kentucky rescues must be applied before a killing frost Allow 7 or mon days after application POU Spin, T eshrca spp. before tillage. Blueweed,Texas rescue,tali Helianhus ciliaris Festuca arundinacea Also for control,apply 2 quarts of this product plus 0.5 pound a.i. of Dicamba in Brackenfern Guineagrass 10 to 20 gallons of water per acre. At these rates,apply using ground application Pleridium aquilimmr Panicum mannan only. Bromegrass,smooth Horsenettle The following lank mixtures with 2,4-D may be applied using aerial application Bromus inermis Solanum carolinarse equipment(except in California)in fallow and reduced tillage systems only. Bursage,woollyleaf Horseradish For suppression on irrigated agricultural land,apply I to 2 quarts of this product Frimseria lommnmsa Armoracia ruslicaao plus I pound a.i. of 2,4-D in 10 to 20 gallons of water per acre with ground Database and format copyright(D by Vance Communication Corporation. All rights reserved. SPECIMEN LABEL LPDA•I'GS AVAII.ABI.,P,AT Ni!W i.GREENBOOK.NET' 7 equipment only. Applications should be made following harvest or in Fall fallow areas where annual tillage(no-till) is not perforated,apply 2 to 3 quarts of this ground when the bindweed is actively growing and the majority of runners arc 12 product in 10 to 40 gallons of water per acre. For bestresults,apply to actively inches or more in length. The use of at least one irrigation will promote active growing plants when most have reached.0te boot-to-head stage of growth or in bindweed growth. the Fall prior to frost. Allow 7 or more days after application before tillage. Do For suppression,apply 16 fluid ounces of this product plus 0.5 pound a.i. of 2,4-D not tank-mix with residual herbicides when using the I quart per acre rate. in 3 to 10 gallons of water per aim for ground applications and 3 to 5 gallons of For burndown of Johnsongrass,apply I pint per acre in 3 to 10 gallons of water water per acre for aerial applicat ons. per acre before the plants reach a height of 12 inches. For this use,allow at]cast Applications should be delayed until maximum emergence has occurred and when 3 days after treatment before tillage. vines are between 6 to 18 inches in length. Spot treatment (partial control or suppression)—Apply a I percent solution of In California only, apply I to 5 quarts of this product per acre. Actual into this product when Johnsongrass is 12 to 18 inches in height. Coverage should be needed for suppression or control will vary within this range depending on local uniform and complete. conditions. For suppression on irrigated land where annual tillage is performed, Kikuyugrass—Apply 2 to 3 quarts of this product per acre. Spray when most apply I quart of this product in 3 to 10 gallons of water per acre. Apply to kikuyugrass is at least 8 inches in hcight(3 or 4-1eaf stage of growth)and actively actively growing bindweed that has retched a length of 12 inches or greater. growing. Allow 3 or more days after application before tillage. Allow maximum weed emergence and numer growth. Do not treat when weeds Knapweed/Horseradish—Apply 4 quarts of this product per acre. Apply when are under drought stress as good soil moisture is necessary for active growth. actively growing and when most weeds have reached the late bud to flower stage Allow 3 or more days after application before tillage. of growth. Following crop harvest or mowing,allow weeds to regrow to a mature Bluegrass, KentuckyBromegrass, smooth/Orchardgrass—Apply 2 quarts of stage prior in treatment. For best results,apply in late Summer or Fall. Allow 7 this product in 10 to 40 gallons of water per acre when the grasses are actively or more days after application before tillage. growing and most plants have reached boot-to-early scedhcad stage of develop- Lantana—Apply this product as a I.to 1.25 percent solution using hand-held meal. For partial control in pasture or hay crop renovation,apply I to 1.5 quarts equipment only. Apply to actively growing lantana a[or beyond the bloom stage of this product in 3 t.0 10 gallons of water per acre. Apply to actively growing of growth. Use the higher application rate for plants that have reached the woody plants when most have reached 4 m 12 inches in hcight. Allow 7 or more days stage of growth. Allow 7 or more days after application before tillage. after application before tillage. - Orchardgrass(sods going to no-till cam)—Apply I to 1.5 quarts of this product Milkweed, common—Apply 3 quarts of this product per acre. Apply when in 3 to 10 gallons of water per acre. Apply to orchardgras's that is a minimum of actively growing and most of the milkweed has reached the late bud to flower 12 inches tall for Spring applications and 6 inches tall for Fall applications. Allow stage of growth. Following small grain harvest or mowing• allow milkweed to at (cast 3 days following application before planting. A sequential application of regrow"a mature stage prior to treatment. Allow 7 or more days alter application atrazine will be necessary for optimum results. before tillage. Blueweed, Texas—Apply 4 to 5 quarts of this product per acre west of the Mutely,wirestenm—Apply I to 2 quarts of this product per acre. Use I quail of Mississippi River and 3 to 4 quarts per acre cast on the Mississippi River. (]its product in 3 to 10 gallons of water per acre. Use 2 quarts of this product Apply when weed is actively growing and is at or beyond full bloom. Do not when applying 10 m 40 gallons of water per acre or in pasture,sod,or noncrop treat when weed is under drought stress as good soil moisture is necessary for areas. Spray when the wircstem mutely is 8 inches or more in height and actively active growth. Nov Icaf development indicates active growth. For best results, growing. Do not till between harvest and Fall applications or in the Fall or apply in Into Summer or Fall. Fall treatments must be applied before a killing Spring prior to Spring applications. Allow 3 or more days after application before frost Allow 7 or more days after application before tillage. tillage. This product will not provide residual control of wirestem muhly from Brackenfern—Apply 3 to 4 quarts of this productper acre as a broadcast spray or seeds which germinate after application of this product Do not tank mix with. as a I to 1.5 percent solution with hand-held equipment. Apply to filly expanded residual herbicides when using the I quart per acre rate. fronds which arc at(cast 18 inches long. Nightshade, silverleaf—For control, apply 2 quarts of this product in 3 to 10 Bursagge,woollyleaf—Por control,apply 2 quarts of this product plus I pint of gallons of water per acre. Applications should be made when at(cast 60 percent mb Dicaa per sell. For partial control,apply I quart of this product plus I pint of the plants have banes. Fall treatments must be applied before a killing frost. Allow 7 or more days after application before tillage. Do not treat when weed is of Dicamba per acre. Apply iJ m 20 gallons of water per acre. Apply when under drought stress as good soil moisture is necessary for active growth. plants are producing new activee growth which has been initiated by moisture for at least 2 weeks and when plants am at or beyond flowering. Nntsedge;purple,yellow—Apply 3 quarts of this productper acre as a broadcast Canarygrass,reed/rimothy/Wheatgrass,western—Apply 2 to 3 quarts of this spray' or apply a 1 to 2 percent solution from hand-held equipment to control productperacre. For best results,apply to actively growing plants when most have existing nuisedge plants and immature outlets attached to treated plants. Treat ached the boot-to-head stage of growth. Allow 7 or more days a0cr application when plants arc in flower or when new outlets can be found at rhizome tips. reached theore tillage. Nndets which have not genminated will not be controlled and may germinate following treatment. Repeat treatments will be required for long term control of Cagongrass—Apply 3 to 5 quarts of this product in 10 to 40 gallons of water ungerminated tubers. per acre. Apply when Cogongrass is at lead 18 inches tall and actively growing Sequential applications of I to 2 courts of this product in 3 to 10 gallons of water In late Summer or Fall. Allow 7 or atoll days after application before tillage per acre will provide control. Make applications when a majority of the plants or mowing. Due to uneven stages of growth and the dense nature of vegetation preventing good spray coverage,repeat treatments may be necessary to maintain are in the 3 t.0 5-1eaf stage Qess than 6 inches tall). Repeat this application,as - control. necessary,when newly emerging plants reach the 3 to 5-Icaf stage. Subsequent Dandelion/Dock,curly—Apply 3 to 5 quarts of this productper acre when plants applications will be necessary for long-term control, are actively growing and most have reached the early bud stage of growth. AIIow For suppression to partial control of existing plants, apply I pint to 2 quarts of 7 or more days after application before tillage. this product per acre, in 3 to 40 gallons of water per acre. Treat when plants have 3 to 5 leaves and most arc less than 6 inches tall. Repeat treatments will Also for control,apply fluid ounces of this product plus 0.5 pound a.i. 2,4-D be required to control subsequent emerging plants or regrowth of existing plants. in 3 [0 10 gallons of water per acre. Wait 7 days after trcatnwnt before tillage or mowing. Dogbane,hemp—Apply 4 quarts of this product per acre. Apply when actively Pompasgrass/Ice plant—Apply this product as a 1.5 to 2 percent solution using growing and when most weeds have reached the late bud to flowerstage of hand-held equipment Apply to plant%that am actively growing. Panmpasgrass growth. Following crop harvest or mowing, allow weeds to regrow to a mature should be at m'beyond lire boot stage of growth. Thorough coverage is necessary stage prior to treatment. For best results,apply in late Summer or Full. Allow 7 for best control. or more days after application before tillage. Phrngmites—For partial control of phragmites in Florida and the counties of 2,4-D in 3 t.0 10 gallons of water per eco for ground applications For suppression. apply 16 fluid ounces of this product plus 0.5 pound of other states bordering the Gulf of Mexico,apply 5 quarts per acre as a broadcast and 3 3 to 5 spray or apply a 2 percent solution from hand-held equipment. In other areas of gallons of water per acre for aerial applications. Delay applications until maximum the U.S.,apply 3 quarts per acre as a broadcast spray or apply a I percent solution emergence of dogbane has occurred. from hand-held equipment for partial control. For best results, treat during late Fescue,talc—Apply 3 quarts of this product in 10 to 40 gallons of water per acre Summer or Fall months or when plants are actively growing and in full bloom. to actively growing plants when most have reached boot-to-early secdhcad stage Treatment before crafter this stage may lead(o reduced control. Due to the dense of development. nature of the vegetation,which may prevent good spray coverage or uneven stages Fall applications only—Apply I quart of this product in 3 to 10 gallons of water of growth,repeat treatments may be necessary to maintain control. Visual control per acre. Apply to fescue in the Fall when actively growing and plants have 6 to symptoms will be slow to develop. 12 inches of new growth. Allow 7 or more days offer application before tillage. Quackgrass—In Annual Cropping Systems,or in Pastures and Sods Followed A sequential application of I pint per acre of his product will improve long-term by Deep Tillage: Apply 1 to 2 quarts of this product per acre. For(he I quart control and control seedlings germinating after Fall treatments or the following rite,apply in 3 to 10 gallons of water per acro. For the 2 quart rate,apply in 10 Spring. to 40 gallons of water per acre. Do not tank mix with residual herbicides when Guineagrass—Apply 3 quarts of this product per acre or use a I percent solution using the I quart rate. Slimy when quackgrass is 6 to 8 inches in height and with hand-held equipment Apply to actively growing guincagrass when most has actively growing. Do not till between harvest and Fall applications or in Fall or reached at(cast the 7-Icaf stage of growth. Ensure thorough coverage when using Spring prior to Spring application. Allow 3 or more days after application before hand-held equipment. Allow 7 or more days after application before tillage. tillage. In pastures or sods,for best results use a moldboard plow. Johnsongrass/Ryegracs,perennial—Apply I to quarts of this product per acre. Quackgrass—Pasture or Sod or Other Noncrop Areas Where Deep Tillage In annual cropping systems apply I to 2 quarts of this product per acre. Apply is Not Planed Following Application: Apply 2 to 3 quarts in 10 to 40 gallons I quart of this product in 3 to 10 gallons of water per acre. Use 2 quarts of of water per acre. Spray when the quackgtass is greater than 8 inches tall and this product when applying t.0 to 40 gallons of water per acre. In noncrop,or actively growing. Do not till between harvest and Fall application or in Fail or Database and format copyright(9 by Vance Communication Corporation. Alrights reserved. SPECIMEN LABEL UPDATES AVAILABLE AT AVWW.GREENBOOK.NET R Spring prior to Spring application. Allow 3 or more days after application before Bearmat(Bearclover) Sugar tillage. Clunnaebuliafoliolosa Acer sacchanam Redvine—For suppression,apply 24 fluid ounces of this product per acre at each Beech - Vine of two applications 7 to 14 days apart or a single application of 2 quarts per Fugus,grardiiolia Acer Flor ern acre. Apply recommended rates in 5 to 10 gallons of water per acre. Apply in Birch Monkey Flower* late September or early October o actively growing plants,which arc at(cast IR Blackberry spp. Afia,uhs gulmlus Oak: inches tall and have been growing 45 m W since sec the last tillage operation. Rubus spp. Black* Make applications at]cast I week before a killing frost. Blockgum Quercus velulinn Reed,giant—Por control of giant reed,apply a 2 perccnt solution of this product Nyssa s'pie. Northern Pin when plants arc actively growing. Best results are obtained when applications am Bracken Quercus poluslris made in late Summer to Fall. Peridium.spp. Post Smartweed,swamp—Apply 3 to 5 quarts of this product per acre when plants Broom: Quercus stellala arc actively growing and most have roachcd the early bud stage of growth. Allow French Red 7 or more days after application before tillage. Cvlisus namspessula as Ouercus rubra Also for control, apply 16 fluid ounces of this product plus 0.5 pound active Scotch Southern Red ingredient of 2,4-D in 3 to 10 gallons of water her acre in the late Summer or Cywhe t,California' Quercus iu/auto g g 1 Buckwheat'ClifoWhite* Pa . Apply when plants actively growing and most have moaned dm curly Cascara- isciculnlum Quercus alba buddstage of growth. Alloww 7 or more days after application before tillage. Cascarsra* Persimmon* Spurge,leafy—For suppression,apply 16 fluid ounces of this product plus 0.5 Rhunums purstouna Dinspyros spp. pound active Ingredient 2,4-D in 3 to 10 gallons of water per acre in die late Catsclaw* Pine - Summer or Fall. Apply when plants am actively growing. If mowing has occurred Acacia gieggi Pinus,spp. prior to trcahnenl,apply when most of the plants are 12 inches tall. Allow 7 or Cennothus* Poison Ivy more days after application before tillage. Ceanodn s spp. Rhus radicars Sti rthistle,yellow—Rest results am obtained when applications arc made during Chamise Poison Oah periods of active growth, including the rosette, bolting and early Hower stages. ' Adenosnr ogias,ndNm uRhus toxicodendron For spray-to-wel applications, apply this product as a 2 percent solution. For Cherry: Poplar,yellow* broadcast applications, apply 2 quarts per acre in 10 to 40 gallons per acre of Bitter Lblodendron avlipliera water carrier. Prunus ernarginat'a Raspberry Sweet Potato,wildffhislle;arHBlack Rubus spp. chnke—Apply this product as solution Pruurs,serotinu Redbud,eastern using hand-held equipment.Apply to actively growingweeds that arcatorbeyond Pin cercis caadensis the bloom stage of growth. Repeat applications may be required. Allow the plant Prunus pensylivinica Rose,multiflora to reach the recommended stage of growth before rctrcarmcm. Allow 7 or more Coyote brush Rosa nwltylor'a days before tillage. Rarcharis canangainea Russian-alive... Thistle,Canada—Apply 2 to 3 quarts of this product per acre. Apply to actively Creeper,Virginia* Elaeagnu.s anguslifolia growing thistles when most arc at or beyond the bud stage of growth. After Parthermcissus quinquefolia Sage;black,white harvest,mowing or tillage in the late Summer or Fall,allow at least 4 weeks for Dewberry .Salvia spp. initiation of active growth and rosette development prior to the application of this Rubus to Molts Sagebrush, California product. Fall treatments must be applied before a killing frost. Allow 3 or more Dagwoud* Arlemisia calijornicd days after application before tillage. Comas spp. Salmonberry For suppression of Canada thistle,apply I quart per acre of this product or I pint Elderberry Rubus,speclabilis of this product plus 0.5 pound a.i. 2,4-D in 3 to 10 gallons of water per acre in sambucus spp. Sall cedar the late Summer or Fall after harvest,mowing or tillage. Allow rosette regrowth Flat* Tamara.,spp. to a minimum of 6 inches in diameter before treating. Applications can be made Ulmus.spp. Sassafras as long as loaves are.still green and plants are actively growing at the time of Eucalyptus Sassafras mbirhnu application. Allow 3 or more days after application before tillage. Eucalyptus spp. Sourwood Gorse Qxidenrlranu arborcurri - Torpedograss—Apply 4 to 5 quarts of this product per acre to provide partial Wax europaeus Sumac control oftorpedograss.Apply to actively growing to incdogmss when most plants Hasardia* Poison* are at or beyond(he scedhcad stage of growth. Repeat application will be required llop/opappus squarrosus Rhus vera]] to maintain control. Fall tremmenls must be applied bcforc frost. Allow 7 or more Hawthorn Smooth* days after application before tillage. Crataegus spp. Rhus glabra Tnnnpetereeper—Por control,apply 2 quarts of this product per acre in 5 to 10 Hazel Winged* gallons of water per acre. Apply to actively growing plants in late September or Cory/us spp. Rhus copallina October,which are at(cast 18 inches Lill and have been growing 45 to 60 days Hickory* Sweetgum since die last tillage operation. Make applications at lead I week before a killing Curyo.app. Lignidambnr styr,ciflaa frost. Holly,FloridafBrazilian Peppertree* Swordfern* Other perennials listed on this label—Apply 3 to 5 quarts of this product per Scbinut terebinlhifolius Poivsrichum nanilunr acre. Apply when actively growing and most have reached early head or early Honeysuckle Tallmvtree,Chinese bud stage of growth. Allow 7 as more days after application before tillage. Lonicern spp. Supana s&b!1crum WOODY BRUSH AND TREES Hornbeam,American* Tan Oak Carpinus curolini,na Labocarpus densi/lonrs When applied as recommended underthe conditions described.this product CON- Kudzu ThintMeberry TROLS or PARTIALLY CONTROLS die following woody brush, plants and Pueraria lobar, Rubus parvdlorus trees: Locust,black* Tobacco,tree* Application Rales: Robina pseudoacacia Nicotiaia glaueu Madrone Trumpelcreeper Method of Application Application Rate Spray Volume(gal/acre) Arbutus menziesd Cnmpsis rcidicans Manzanita Waxnryrtle,southern Broadcast Arelostapliy(os spp. Afvrica cerfera Acrial 2 to 10 gVacse 51,00 Maple: Willow Ground 2 to 10 gUacm 10 to 60 Red** salla spp. Spray-to-Wet Acer rubrum Handgun,Backpack I to 2% spray-to-wet `Partial control Misiblower by volume **See below for control or partial control instructions. Low Volume Directed Spraytt --*This product w not registered in California for use on Russian-oliva. Handgun 5%to 10% P.riml Backpack by volume coverage NOTE: If brush has been mowed or tilled or[rtes have been cul,do not treat until regrowth has reached the recommended stages of growth. ttFor law volume dimehedspray applications,coverege should be uniform with at]cast 5ll Applythis pruductwhenplants are actively growing and,unless otherwise directed, percemoflhemlisgeconmaed. Porbest result,,covemgcuf the Lip one-hslfuf the plant is after full leafexpansion.UsethchighcrmteforlargerplanLsand/ordcnscarcasof imporant. growth.On vines,use the higher rate for plants that have reached the woody slags Aider - Fraxinum spp. of growth. Best results are obtained when application is made in late Summer or Abuts spp. Aspen,quaking Pall after fmit formation. Ash Papulas Iremuloides In and areas,best results arc obtained when application is made in the Spring to early Summer when brush species are at high moisture content and arc flowering. Database and format copyright O by Vance Communication Corporation. All rights reserved. SPECIMEN LABEL. LIPOATES AVAIL,ABI.,E;A'f'\VWW.GIZEENBOOIC.NRT 9 Ensure thorough coverage when using hand-held equipment. Symptoms may not EXTREME CARE MUST BE EXERCISED TO AVOID CONTACT OF SPRAY - appear prior to frost or senescence with Fall trcahnents. WITH FOLIAGE, GREEN STEMS, EXPOSED NON-WOODY ROOTS OR Allow 7 or more days after application before tillage,mowing or removal. Repeat FRUIT OF CROPS, DESIRABLE TURFGRASSES, TREES, SHRUBS OR Ircatmenls may be necessary to control plants regenerating from underground parts OTHER DESIRABLE VEGETATION SINCE SEVERE DAMAGE OR DE- or seed. Some autumn colors on undesirable deciduous species arc acceptable STRUCTION MAY RESULT. provided no major leaf drop has occurred. Reduced performance may result if Repeat treatments may be necessary to control weeds regenerating from under. Fall treatments are made fallowitig a frost. - ground parts or seeds. See "DIRECTIONS FOR USE" and "MIXING,ADDITIVES and APPLICA. Do not exceed 10.6 quails of Otis product per acre per year. 'TION INSTRUCTIONS" sections of this label for labeled uses and specific This product does not provide residual wood control. For subsequent weed control, application instructions. follow a label-approved herbicide program. Apply this product as follows to control or partially control the following woody Read and carefully observe the cautionary statements and all other inlommtion brush and trees. appearing on the labels of all herbicides used Alder/Dewberry/Honeysuckle/Post Oak/Raspberry—For central,apply 3 to 4 INDUSTRIAL,RECREATIONAL AND PUBLIC AREAS quarts per acre of this product as a broadcast spray or as a 1 to 1.5 percent solution When applied as directed for"NONCROP USES under conditions described, with hand-held quaequking/Cherry: this product controls annual and perennial weeds listed on this label growing Aspen, mfTrumpeteree bitter, black, apply 2 thorn/Oak, f this p red/ in areas such as airports, ditch banks,dry ditches dry canals, fencerows, golf SweetgumlFrumpetcredper—For control, apply 2 to 3 quarts of this product courses,highways,industrial plant sites,lumber yards,manufacturing sites,office per acre as a broadcast spray or as a I to 1.5 percent solution with hand-held complexes,parking areas,parks•petroleum tank farms and pumping installations, equipment. pipelines,power and telephone rights-oGway,railmads,roadsides,schools.storage Birch/Elderberry/Hazel/Salmonberry/Thimbleberry—For control, apply 2 areas,utility substations,warehouse areas.other public areas and similar industrial quarts per acre of this product as a broadcast spray or as a I percent Solution or non-crop areas. with hand-held equipment. For specific rates of application and instructions for control of various annual and Blackberry—For control, apply 3 to 4 quarts per acre of this product as a perennial weeds and woody brush and trees,sec the"WEEDS CONTROLLED" broadcast spray, or I to 1.5 percent solution with hand-held equipment. Make section of this label. application after plants have reached full leaf maturity. Best results arc obtained This product may be applied with recirculating sprayers,shielded applicators,or when applications are made in late Sumpter or Fall. After berries have set or wiper applicators in any noncrop site specified on this label. See the Selective dropped in late Fall,blackberrycan bccontrolled by applyinca3/,pereentsolulion Equipmentpart of"APPLICATION EQUIPMENT and TECHNIQUES"section of this product with hand-held equipment. For control of blackberries after leaf of this label for information on proper use and calibration of this equipment. drop and until killing frost or as long as stems arc given,apply 3 to 4 quarts of this product in 10 to 40 gallons of water per acre. Chemical mowing—Perennials Broom: French, Scotch—For control, apply a 1.5 to 2 percent solution with This product will suppress perennial grasses listed in this section to serve as a hand-held equipment. substitute for mowing. Use 8 fluid ounces of this product per acre when treating tall fescue,fine fcscuc,orchardgrass or quackgrass covers. Use 6 fluid ounces of Buckwheat, se pedes,apply a I[Monkey Flmlutio not thisbacca, trod—Por partial this product per acre when treating Kentucky bluegrass. Apply treatments in l0 control of these-petits,apply n I l0 2 percent solution of this product es a foliar to 40 gallons of spray solution per acre. -only with hand-held equipment. Thorough coverage of foliage is necessary for - best results. Use only in arms where some temporary ryinJa D' or discoloration of perennial Catsclaw—For partial control,apply as a I to 1.5 pereentsolution with hand-held grasses can be tolerated equipment. Chemical mowing—Annuals Coyote Brush—For control, apply a 1.5 to 2 percent solution with hand-held For growth suppression of some annual grasses, such as annual ryegrass, wild equipment when at least 50percentof the new leaves arc fully developed, barley and wild oats growing in coarse turf on roadsides or other industrial areas, Eucalyptus—For control of eucalyptus resprouts,apply a 2 percent solution of apply 4 to 5 fluid ounces of this product in 10 to 40 gallons of spray solution this productwith hand-held equipment when resprouls arc 6 to 12 feet tall. Ensure per acre. Applications should be made when annual grasses arc actively growing and bcfom the scedlicads arc in the boot stage of development. Treatments may complete coverage. Apply when plants are growing actively. Avoid application cause injury to the desired grasses. to drought-sircssed plants. Kudzu—For control,apply 4 quarts of this product per acre as a broadcast spray RAILROADS or as a 2 percent solution with hand-held equipment, Repeat applications will be Bare ground, Ballast and Shoulders, Crossings,and Spot h eatmenl - required to maintain control. This product may be used to maintain bare ground on railroad ballast and shoulders. Madrone resprouts—For suppression orpartial central,apply a2 perccntsolution Repeat applications of this product may be used,as weeds emerge,to maintain of this product to respmuts less than 3 to (i feet tall. Best results are obtained bare ground. This product may be used to control W11-growing weeds to improve with Spring/carly Summer treatments. fine-of-sight at railroad crossings and reduce the need for mowing along rights- Ma Ir; red—For control, apply as a I to I S of-way, wayside structures, and other similar areas. For crossing applications, Maple, pp y percent solution with hand-held up to 80 gallons of spray solution per acre may be used. This product may be equipment when at least 50 percent of the new leaves are fully developed. For tank mixed with the following products for ballast, shoulder,spot, bare ground partial control,apply 2 to 4 quarts of this product per acre as a broadcast spray. crossing treatments and other similar areas: Maple, sugar/Oak, northern pin/Oak, red—For control. apply as a I m I.5 ARSENAL GARLON 4 SPIKE°' percent solution with hand-held equipment when at]cast 50 percent of Ilio new DICAMBA HYVAR®X leaves are fully developed. TELAR Poison Ivy/Poison Oak—For control,apply 4 to 5 quarts ofthis product per acre DIURON KROVAR I OF VANQUISHESCORT OUST 2,4-D as a broadcast spray or as a 2 percent solution with hand-held equipment. Repeal GARLOW 3A SAHARA applications may be required to maintain control. Fall treatments must be applied before leaves lose green color. Brush control Rose, multiDora—Por control, apply 2 quarts of this product per acre as a This product may be used to control woody brush and trees on railroad rights-uf- broadcast spray or as a I percent solution with hand-held equipment. Treatments way. Apply 4 to 10 quarts of this product per acre as a broadcast spray, using should be made print to leaf deterioration by leaf-feeding insects. boom-type or boom-less nozzles.Up to 80 gallons of spray solutions per acre may Sage,black/Sagebrush, Califirnin/Chamise/Tallowlree,Chinese—For control be used. Apply a us to 2 percent solution of this product when using high-volume of these species,apply a I percent solution of this product as a foliar spray with spray-to-wet applications. Apply a 5 to 10 percent solution of this product when hand-held equipment. Thorough coverage of foliage is necessary for best results. using low volume directed sprays for spot treatment. This product may be mixed with the following products for enhanced control of woody brush and trees: Tan oink rc product to—For suppression 3 partial control,apply e2 lis are solution withthis product le rnsprouls less than 3 m 6 fed tall. Best results are obmined ARSENAL OARLON 3A TORDONs' K with Fall applications. - ESCORT CARLON 4 Willow—For control.apply 3 quarts of this product per acre as a broadcast spray Bennudagrass release or as a I percent solution with hand-held equipment. This productmay be used to control or partially control many.annual and perennial Other Woody Brush and Trees listed on this label—For partial control,apply weeds for effective release of actively growing Bc niudagrass. Apply I to 3 pints 2 to 5 quarts of this product per acre as a broadcast spray or as a I to 2 percent of this product in up to 80 gallons of spray solutions per acre. Use the lower solution with hand-held equipment. For difficult to control perennial weeds and rate when treating annual weeds below 6 inches in height(or runner length). Use woody brush and trees, where plants arc growing under stressed conditions or the higher rate as weeds increase in size or as they approach Bower or se:dhcad where infestations are dense,Razor Pro may be used at 5 to 10 quarts per acre formation. Tbcsc rates will also provide partial control of the following perennial for enhanced results. The annual maximum use rate for Razor Pro is 10.6 quarts species: per acre per year. Bahiagrass Fescue,WIT Tmmpelcrecper NONCROP USES Bluestein,silver Johnsongrass Vascygmss See "GENERAL INFORMATION" and "MIXING,ADDITIVES and APPLI- CATION INSTRUCTIONS" PPLI-CATION-INSTRUCTIONS" sections of this label for essential product perfor- This product may be tank-mixed with Oust. If tank-mixed,use no more than I to mance information and the fallowing"NONCROP"sections for specific recom- 3 pints of this-product with I to 2 ounces of Oust per acre. Use the lower rates mended uses. of each product to control annual weeds less than 6 inches in height(or runner Database and format copyright r3 by Vance Communication CYrrporaffmn. Alt rights reserved. SPfi,CIAIEN LABEL UPDATES AVAILABLE AT WWNN.(;REENBOOK.NL'-r IB length) that arc listed in this label and the Oust label. Use the higher rates as uniform height of 3 to 4 inches. This application must be made prior to sccdhcad annual weeds increase in size and approach the flower or sccdhcad stages. Theac emergence, rates will also provide partial control of the fallowing perennial weeds: For suppression up to 120 days, apply 4 fluid ounces of this product per acre, Bahiagmss Dewberry -Poorjoc followed by an application of 2 in 4 fluid ounces per acre about 45 days later. Blackberry Dock,Curly Raspberry Make no more than 2 applications per year. Bluestein,silver Dog Fcnnel TmmpCe1ecpc1 TANK MIXTURES FOR INDUSTRIAL SITES AND FORESTRY SITE Brooneedge Fescue,fall Vaseygrass PREPARATIONS - - Dallisgrass lohnsongrass Vervaru,blue _ Razor Pro Herbicide plus OUST Use only on well-established Bcrmudagrass.Bcrmudagrass injury may result from Usc on industrial sites including airports,industrial plants,lumberyards,petroleum the treatment,but regrowth will occur tinder moist conditions. Repeat applications tank farms,pumping stations,railroads,roadsides,storage areas or other similar in the same season arc not recommended,since severe injury may occur. sites where bare ground is desired. ROADSIDES This tank mixture may also be used as a site preparation treatment for sites to be Shoulder treatments planted to jack pine.loblolly pine,red pine,slash pine and Virginia pint. When This product may be used on road shoulder s. It may be applied with boom spra-vers, applied as directed for "NONCROP USES" under Ore conditions described, shielded boom sprayers,high-volume off-center nozzles,handheld equipment,and this product plus Oust provides control of annual weeds listed in the "WEEDS similar equipment. CONTROLLED" section of the label for this product and Oust, and control or partial control of the perennial weeds listed below. Guardrails and other obstacles to mowing Apply I to 2 quarts of Otis product with 2 to 4 ounces of Oust in 10 to 40 gallons This product may be used to control weeds growing under guardrails and around of spray solution per acre as a broadcast spray to actively growing weeds. signposts and other objects along the roadside. . This mixmrc may be applied by aerial equipment in site prop operations. When Spot treatment applied by air, use the rcv:onuncndcd mics in 5 to 15 gallons of spray solution This product may be used as a spot treatment to control unwanted vegetation per acre. growing along roadsides. This product plus Oust tank mixtures may not be applied by air in California. Tank mixtures For control of annual weeds,use the lower rates of these products. This product may be tank-mixed with the following products for shoulder. For control of the listed perennial weeds,use the higlmcr mtes of both products. guardmil,spot and bare ground treatments: For partial control,use the lower rates. DICAMBA OUST SAHARA Bahiagrass lohnsongrass** .DIURON PENDULUM 3.3-EC SIMAZINE ENDURANCE PENDULUM WDG SURFLAN Bpbspalucrmudamgrass* Poorjoc nomlum Sorghum hulepense ESCORT PRINCEP OF TELAR Bermuda lady/ar Dladia teres KROVAR 1 DF PRINCEP LIQUID VANQUISH IMAZAPYR RONSTAR 50 WP 2,4-D Broomsedge Quackgrass Andropogon virginicas Agmpvron repens See the"GENERAL NONCROP AREAS AND INDUSTRIAL SITES" section Dock,curly Trumpetcrecper* of this label for general instructions for tank mixing. Runner crispier Campsis rudicars Dogf Auld Vaseygrass Release of Bermudagrass or Bahiagrass Enpalorium cupilliforium paspalunr umillei Dormant applications Fescue,tail Vervain,blue This product may be used to control or partially control many winter annual weeds Fesnrea art..oinama Verbena hasiam and tall fescue for effective release of dormant Bemmudagrass or bahiagrass. Treat only when turf is dormant and prior to Spring grccnup. This product may also 'Suppression ar the higher ares only. be rank-mixed with Oust for residual control. Tank mixtures of this product with Oust may delay grccnup. "Control at the lower races. - For best results on winter annuals,treat when plants arc in an early growth stage Read and carefully observe the cautionary statements and all other information (below 6 inches in height)after most have germinated. For best results on tall appearing on the labels of all herbicides used. fescue,treat when fescue is at or beyond the 4-to 6-leaf stage. TANK MIXTURES NONCROP SITES Apply 8 to 64 fluid ounces of this product per acre alone or in a tank mixture When applied as a tank mixture, this product provides control of the emerged with 1144 to I ounce per acre of Oust Apply the recommended rates in 10 to 40 annual weeds and partial control of the emerged perennial weeds listed in this gallons of water per acre. Use only in areas where Bemmdagrass or bahiagrass label. When applied as a tank mixture. the following residual herbicides will are desirable ground covers and where sonic temporary injury or discoloration can provide prccmcrgcncc control of the weeds listed in the individual product labels. be tolerated. To avoid delays in grccnup and minimize injury,add no more than I ounce of Oust per acre on Bcrmudagrass and no more than 0.5 ounce of Oust per Riverdale Razor Pro plus DIURON acre on bahiagrass and avoid treatments when these grasses are in semi-dormant Riverdale Razor Pro plus KROVAR I condition. Rivcrdalc Razor Pro plus KROVAR 11 Actively growing Bcrmudagrass Riverdale Razor Pro plus RONSTAR 50WP This product may be used to control or partially control many annual and perennial Riverdale Razor Pro plus SIMAZME,PRINCEP CALIBER 90 . weeds for effective release of actively growing Bcrmudagrass. Apply I to 3 pints Riverdale Razor Pro plus SIMAZINF 4L of this product in 10 to 40 gallons of spray solution per acre. Use the Iowarate Riverdale Razor Pro plus SIMAZINE 80W when treating annual weeds below 6 inches in height(or matter length). Use Riverdale Razor Pro plus SURFLAN 75W the higher rate as weeds increase in size or as they approach flower or sccdhcad Riverdale Razor Pro plus SURFLAN AS r fomation. These rates will also provide partial control of the following perennial species: When tank mixing with residual herbicides,sec the"MIXING,ADDITIVES and Bahiagmss Fescue,tall Trumpetcrecper APPLICATION INSTRUCTIONS" section of this label before preparing these Bluestein,silver lohnsongrass Vaseygrass tank mixtures. Read and carefully observe the label claims,cautionary statements, recommended use mics and all other information on.the labels of all products used in these rank mixtures. Use according to the most restrictive label directions This product may be tank-mixed with Oust. f to st per cr use Use more than I to for each product in the mixture. 2 pints of this product with I to 2 ounces o(Oust per acre. Usc the lower rates of each product to control annual weeds less than 6 inches in height(or retina CONTROL OF EMERGED WEEDS length) that am listed in this label and the Oust label. Use the higher rates as Note: For backpack sprayer and handgun applications,see the"I-IAND-HELD annual weeds increase in size and approach the flower or sccdhcad stages. Tlmse AND HIGH VOLUME EQUIPMENT"section for recommended rates. macs will also provide partial control of the following perennial weeds: Annual Weeds—Apply I quart per acre of this product in these tank mixtures - Bahiagrass Dock,curly Poorjoc when weeds arc less than 6 inches tall and 1.5 quarts per acre when weeds arc Blucstem,silver Dogfennel Tmmpclereeper mom than 6 inches tall Brooc rescue,tall Vaseygrass Perennial Weeds—For partial control of perennial weeds rising these tank mix- fares,apply 2 to 5 quarts per acre of this product. Follow the recommendations Use only on well-established Bcrmudagrass. Bcrmudagrass injury may result from in the"WEEDS CONTROLLED" section of this label for stage of growth and the hcamsnt,but regrowth will occur tinder moist conditions. Repeat applications rate of application for specific perennial weeds. of the tank mix in the same season arc not recommended,since severe injury may PREEMERGENCE WEED CONTROL occur. For prccmcrgcncc weed control,refer to the individual product labels f'or specific Actively growing bahiagrass noncrop sites,rates,carrier volumes and precautionary statements. For suppression of vegetative growth and sccdhcad inhibition of bahiagrass for Mix only the quantity of spray solution which can be used during the some day. approximately 45 days,apply 6 fluid ounces of this product in 10 to 40 gallons Do not alloy these tank mixtures to stand ovcmight as this may result in reduced of water per acre. Apply I to 2 weeks after full grccnup or after mowing to a weed control. - Database and format copyright©by Vance CommuniCrifinm Cerpmratimn. All rights reserved. SPE.CIME,N LABEL UPDA"I'ES AVAII,ABIi: AT'WR`\\CG12EE:NBOOK.NFI' 11 FARMSTEAD WEED CONTROL Postdirected Spray—Use as a postdircctcd spray around established woody or- When applied as directed for"NONCROP USES", under conditions described, namcnt:d species,nursery species or Christmas trees such as those listed below. this product controls undesirable vegetation listed on this label around farmstead Care must be exercised to avoid contact of spray,drift or mist with foliage or building foundations,along and in fences,shelterbclts and for general nonselective green bark of established ornamental species. fammsicad weed control. - Arborvitae Lilac For specific rates of application Paid instructions for control of various annual and Thuja spp. Svrioga spn. perennial weeds,sec the "WEEDS CONTROLLED"section of this label. Azalea Magnolia FARM DITCHES - Rhododendron spp. Magnolia spp. Boxwood Maple This product will suppress perennial grasses along farm ditches. Apply this Buxns spp. Acer spp. product at a rate of 6 in 8 fluid ounces per acro. Use 8 Fluid ounces per acre when Crabapple Oak treating tall (coarse)fescue.fine fescue,orchardgrass or quackgrass covers. For Malus spp. Quercus spp. best suppression of these species,add ammonium sulfate at a rate of 1.7 pounds Euonymus Pine per 10 gallons of spray solution. Use 6 fluid ounces per acre without ammonium F.uwrvmus,spp. _ Pinus spp. sulfate when treating Kentucky bluegrass. Fir Privet - Apply treatments in 10 to 20 gallons of spray solution per acre to actively Alries spp. Liguslrum spp. growing perennial grass covers. For best spray distribution and coverage,use Bat P.mudoLeago.spp. Spruce fan nozzles. Hollies Picea spp. Where broadlcaf wood control or suppression is desired,tank mix this product //er.spP. Yew with an appropriate,labeled broadleaf weed herbicide. Jojoba Tusus spp. Simmardsio cdinens4, - CONSERVATION RESERVE PROGRAM(CRP ACRES) SILVICULTURAL SITES and RIGHTS-OF-WAY This product can be used to control undesirable vegetation when rotating out of CRP acres or to suppress competitive growth and seed production of undesirable NOTE:NOT RECOMMENDED FOR USE AS AN OVER-THE-TOP BROAD- vegetation in CRP acres. CAST SPRAY IN SILVICULTURAL NURSERIES For specific rates of application for various annual and percnnial wccds,sec the When applied as directed for"NONCROP USES" under conditions described, "WEEDS CONTROLLED" section of this label. this product controls undesirable vegetation listed on this label.This product also suppresses or controls undesirable vegetation listed on this label when applied CRP applications may be made with wiper applicators or conventional spray at recommended rates for release of established coniferous species listed oft this equipment. label. For selective applications with broadcast spray equipment,apply 12 to 16 ounces For specific rales of application and insmictions for control of various brash, per acre of this product in early Spring before desirable CRI' grasses, such as annual and perennial weeds,sec the "WEEDS CONTROLLED" section of this crested and tall wheatgrass,break dormancy and initiate green growth. Late Fall label. For specific rates of application for release of listed coniferous species,sec applications can be made alter desirable perennial grasses have reached dormancy. the"CONIFER RELEASE" part of this section of the label. Some stunting of CRP percnnial grasses will occur if applications are made when plants arc not dominant. Do not exceed 10.6 quarts of this product per acre per year. DORMANT RANGELAND Aerial Application—This product may be applied using aerial spray equipment for silviculmral site preparation,conifer release and rights-of-way treatments. See This product will control or suppress many weeds,including downy brume,cheat the"APPLICATION EQUIPMENT and TECHNIQUES"pan of the"MIXING, grass,cereal ryc,mcdusahcad rye and jointed goatgrass in dormant rangeland. ADDITIVES and APPLICATION INSTRUCTIONS" section of this label for Apply 8 to 16 ounces per acre of this product in the early Spring when the wccds information on how to apply this product by air. have greened up,but desirable grasses,such as crested and tall whcatgmss are DO NOT APPLY THIS PRODUCT BY AIR TO RIGHTS-OF-WAY SITES IN still truly dormant. THE STATE OF CALIFORNIA. Slight discoloration of lire desirable grasses may occur,but they will regrccn and SITE PREPARATION regrow under moist soil conditions as effect%of this product wear off. Following preplan applications of this product,any silvicultual species may be Do not use additional surfactunt or ammonium sulfate when spraying dormant planted. rangeland grasses with Riverdale Razor Pro. POSTDIRECfED SPRAY HABITAT MANAGEMENT In established silvicultural sites, use as a spray on the foliage of undesirable This product is recommended for the restoration and/or maintenance of native vegetation. Care must be exercised to avoid contact of spray,drift or mist with habitats and in wildlife managemenlarcas. Apply as recommended in the"NON- foliage or green bark of desirable species. CROP USES" section of this label. CONIFER RELEASE Habitat Restoration and Maintenance When applied as directed,exotic and For releaseapply at the end of the first growing season, except in California. , other undesirable vegetation may be controlled in habitat management areas. Ap- Vegetation should not be disturbed prior to treatment or until visual symptoms plications can be made to allow recovery of native plant species,prior to planting appear after treatment. Symptoms of ticatnhcnt arc slow to appear, especially desirable native species,and for similar broadspectrum vegetation control require- in woody species tn:ned in late Fall. Injury may occur to conifers heated for ments in habitat management areas. Spot trcamments can be made to selectively release,especially where spray patterns overlap or the higher rates arc applied or remove unwanted plants for habitat maintenance and enhancement For spot %hen applications are made during periods of active conifer growth. Do not use treatments,care should be exercised to keep spray off of desirable plants. additional surfactant with conifer release applications. Wildlife Food Plots—This product may be used as a site preparation treatment Applications must be made after formation of final conifer resting buds in the prior to planting wildlife food plots. Any wildlife food species may be planted Fall or prior to initial bud swelling in Spring. Some atimnm colors on undesirable after applying this product,or native species may be allowed to repopulate the deciduous species are acceptable provided no major leaf drop has occured. Use arca. If tillage is needed to prepare a seedbed,wait 7 days atter applying this the following rates for conifer release to control or partially control the weeds product before tilling. - listed in the"WEEDS CONTROLLED"section of this label. ORNAMENTALS, NURSERIES (PLANTS AND TREES) AND CHRIST- For release of the following conifer species: MAS TREES Douglas fir T.sugu spp. TIdIS PRODUCT IS NOT RECOMMENDED FOR USE AS AN OVER-THF- Pseudolsuga mermesi( Pinesv TOP BROADCAST SPRAY IN ORNAMENTALS AND CHRISTMAS TREES. Fir Pinus sPp. Note: Desirable plants may be protected from the spray,solution by using shields Able.,spp. Spruce or coverings made of cardboard or other impermeable material. Hemlock Picea spp. When applied as instructed for the conditions described for"NONCROP USES", this product controls undesirable vegetation listed on this label prior to planting, 'Includes all species except eaacm wine,pine,luhlelly pine or slash pine. within and around greenhouses and shadchouses, and as a postdircctcd spray Apply 1.5 to 2 quarts of this product per acre except in Washington and Oregon, around established ornamentals and Christmas trees. This product may also be west of the asst of the Cascade Mountains. FmSpring treatments west of the used to trim and edge around frees,buildings,sidewalks,roads,potted plants and crest of the Cascade Mountains, apply I quart of this product per acre before other objects in a nmscry setting. conifer bud swell for control of annual weeds. For Fall treatment%in Washington For specific rates of application and instructions for control of various annual and and Oregon,west of the crest of the Cascade Mountains,apply I to 1.5 quarts of perennial weeds,see the "WEEDS CONTROLLED" section of this label. this product per acre before any major leaf drop of deciduous species. Where repeat applications are necessary,do not exceed 10.6 quarts of this product For release of western hemlock,apply I quart of this product per acre. - per acre per year. For release of the following conifer species: Site Preparation—Following preplan applications of this product,any oraamcn- Loblolly pine Pines slrohrrs tal,nursery species or Christmas tree species may be planted. Precautions should Pinus Tueda Slash pine be taken to protect nontarget plants during site preparation applications. Eastern white pine Piers effiavi Greenhouse/Shadehouse Use-77mis product may be used to control weeds listed on this label which are growing in greenhouses. Desirable vegetation must not Late Season Application—Apply 1.5 to 2 quarts of this product in a minimum be present during application and air circulation fans must be turned off. of 5 gallons of spray solution per acre during early eastern. Applications'made Database and format copyright(0 by Vance Communication Corporation. All rights reserved. SPECIMEN LABEL, UPDATES AVAILABLE AT W\V\V.GREENBOOK.NET 12 prior to September I or when conditions are conducive to rapid growth of conifers Alder Aruudo dower will create the potential for increased injury in the form of lip and/or needle burn. Alnus spp. - Snitcedar Injury may decrease with later applications. Some autumn colors arc acceptable Eucalyptus Tarnarisk spp. at time of application. Apply prior to frost or leaf drop of undesirable plants. Eucalypts spp. Sweetgum Applications made according to label directions will release loblolly pine,eastern Madrone Liquidenibar s(vrocijlu, white pine and slash pine by reducing competition train the following species: Arbutus menziesii Tan Oak 1 Oak Lithncarpus densia'ur Ash _ Quercersfalcata Quercus.spp. Willow Fraxinus SPP. White Reed,giant Saler spp. Cherry: - Quercus alba Black Persimmon INJECTION AND FRILL APPLICATIONS Praus serotina Dlospyros spp. Woody vegetation may be controlled by injection or frill application of this Pin Poplar,yellow product Apply this product using suitable equipment which must penetrate into Prunus penny/Tunica safras endr,n tulipferu the living tissue. Apply the equivalent of I nil of this product per each 2 to 3 Elm Sassafras inches of trunk diameter(DBH).This is best achieved by applying a 50 to 100 Wave;spp. urwood albidem percent concentration of this material either to a continuous frill around the tree Hawthorn Sourwood or as cuts evenly spaced around the tree below all branches. As tree diameter Cust,black sumacOxvd: ar(rormuo increases in size, better results are achieved by applying diluted material to a Locust,black Sumac: continuous frill or more closely spaced cuttings. Avoid application mchniqucs Robina pseudoacacia Poison that allow runoff to occur from frill or cut areas in species that exude sap freely Maple,red Rhus vein& after frills or cutting. In species such as this,make frill or cut at an oblique angle Acer rubra Smooth so as to produce a cupping effect and use undiluted material. For best results, Oak: Rhus glahrn Black Winged application should be made during periods of active growth and after full leaf Quercus ve'lulinu Rhus rnpallina expansion. Post Sweetgum This Imahnent WILL CONTROL the following woody species: Quercus stellata Liquidambarsryruciva OakSweetgum Southern Red Quercus spp _ Liquidambar sryracijiva Apply only to those sites where woody brush and Imes listed in this level constitute Poplar Sycamore the majority of the undesirable species. P,puha spp. Platanus occidentalis RIVERDALE RAZOR PRO PLUS OUST TANK MIXTURES FOR This treatment WILL SUPPRESS the following woody species: CONIFER RELEASE FROM HERBACEOUS WEEDS Black guts Hickory To release loblolly pines from herbaceous weeds,tank mixtures of this product A5ase sylvatic, Curva.spp. with Oust will provide control of annual weeds listed in the "WEEDS CON- Dagwoad Maple,red TROLLED"section of this and the Oust label,and partial control of the perennial Cornus spp. Acer r,,b,,,m weeds listed below. Apply 16 to 24 fluid ounces of this product with 2 to 4 ounces of Oust in 10 to 30 TURFGRASSES AND GRASSES FOR SEED PRODUCTION gallons of spray solution per acre. Make application to actively growing weeds PREPLANT AND RENOVATION as a broadcast spray over the top of the young loblolly pines. When applied as directed for"NONCROP USES", under conditions described, This product plus Oust tank mixtures may not be applied by air in California this product controls most existing vegetation prior to the planting or renovation This tank mixture may be applied using aerial equipment. When applying by air, of either mrlgrasscs m grass seed production areas. use the recommended rale inn 5 5 to 15 gallons of spray solution per acre. For specific mics of application and instructions for control of various annual and perennial weeds,and woody bosh and trees,sec the"WEEDS CONTROLLED" Fm control of annual weeds below 12 inches in height(origh runner of bot on annual section of this label, vines),use the lower mics of both products. Use the higher rates of both products Fur maximum control of existing vegetation,delay planting m determine if any when annual weeds arc in more advanced stages of growth and approaching Bawer regrowth from escaped underground plant parts occurs. Where repeat treatments or recd(onnali°O' are necessary,sufficient regrowth must be attained prior to application. For warm- Use the higher rates of both products for partial control of the following perennial season grasses,such as Bermudagmss,Summcr or Fall applications provide bat weeds. Use the lower rates for suppression of growth. control Bahiagross Johnsongross* DO NOT DISTURB SOIL OR UNDERGROUND PLANT PARTS BEFORE Paspolunr naKaum Sagmm halepense TREATMENT. Tillage or renovation techniques such as vertical mowing, cor- Broomsedge Poorjoe* ing or slicing should be delayed for 7 days after application to allow proper And,opogar virginicus Diodiq teres It into underground plant parts. Dock,curly Trumpetcreeper** TURFGRASSES Rumex carpus Campsiv radicans Where existing vegetation is growing in a field or narrowed situation,apply this DogfiaEupat ri Vmseygr m product actively growing weeds at the stages of growth listed in the"WEEDS Fescue, tall nrpil/jforium Prvain,m urvi!!ei CONTROLLED"section of this label. Fescue,tall Vervain,blue Festuc,arundinaceu Verhena hasturu Where existing vegetation is growing under mowed turfgrass management in such sites as apartment complexes,residential areas and sod fames,apply this product •Cdnuol at the higher rams. after omitting at least one regular mowing to allow sufficient growth for good interception of the spray. **Suppression at the higher rains only. Desirable turfgersses may be planted following the above procedures. Pine damage may occur or can be accentuated if tmannent takes place when young GRASSES FOR SEED PRODUCTION trees arc under stress from drought,flood water,insects or disease. Apply this productto actively gmwmgwecds at the stages ofgrowth recommended Read and observe the cautionary statements and all other information appearing in the "WEEDS CONTROLLED" section of this label prior to planting or on the labels of all herbicides used. renovation of turf or forage grass areas grown for seed,production. NOTE TO USER: DO NOT feed or graze treated areas within 8 weeks aficr application. This product must notbe used in areas where adverse impact on federally desig. ANNUAL WEED CONTROL IN DORMANT BERMUDAGRASS AND noted endangered/threatened plant or aquatic species is likely. BAHIAGRASS TURF Prior to making applications,the user of this product must determine that no such When applied as directed for"NONCROP USES"under the conditions described, species are located in or immediately adjacent to the arca to be noted. this product will provide control or suppression of many Winter annual weeds CUT STOMP TREATMENTS turf. tall fescue for effective release of dormant Benmu lagmss and bahiagmss turf. Refer to the rate table for Riverdale Razor alone under the"RELEASE OF Woody vegetation may be controlled by treating freshly cut stumps of trees and BERMUDAGRASS and BAHIAGRASS" sectionof this label for recommended resprouts with this product. Apply this productusing suitable equipment to ensure rates and volumes on the species to be suppressed or controlled Treat only coverage of the entire cambium. Cut vegetation close to the soil surface. Apply a when turf is dormant and prior to Spring grecnup., Spot treatments or broadcast 50 to 100 percent solution of this product to the freshly-cut surface immediately applications of this product in excess of 16 fluid ounces per acre may result in after cutting. Delays in application may result in reduced pedommanec. For best injury or delayed greenup in highly maintained turfgrass areas;i.e.,golf courses, results,applications should be made during periods of active growth and fill leaf lawns,etc. DO NOT APPLY TANK MIXTURES of this product plus Oust in expansion. highly maintained turfgmss areas. When used according to directions for cut stump application, this product will RELEASE OF BERMUDAGRASS OR BAHIAGRASS CONTROL,PARTIALLY CONTROL or SUPPRESS many types of woody brash NOTE:Use only in areas where Bcmedagrass m'bahiagiass are desirable ground and tree species,some of which arc listed below: covers and where some temporary injury or discoloration can be tolerated. Use Database and lot mat copyright(D be Vance Communication Corporation. All rights reserved. SPE AM N L.,ABE.L. L1PDA-I'EB AVAILABLI,? AT WWW'.Glll?ENBOOK.Ni"r 13 tank mixtures of this product plus Oust only on railroads,highways,utility plant Riverdale Razor Pro+OUST sites,or other right-of-way areas. When a lied as directed for USES"underlhe conditions described, Riverdale FP Razor Pro this product will provide control or suppression many Winter annual.chis (FL.OVA) S 12 12 16 16 12 I6 and tall fescue for effective release of dormant Bcrmrmudagrass or bahingress:This + + + + + + + + product may be tank-mixed with Dust as recommended for residual control.Make WEED SPECIES OUST(O7IA) Va yn 4y v4 a, I I applications to dormant Bcnnudagmss or bahiagrass.Tank mixtures of this product plus Oust may delay grccnup. To avoid delays in grccnup and minimize injury. Fescue,tall • • • S- S do not add more than I ounce per acre of Oust on Bcrmudagrass or more than 0.5 Fovea anard7oaceae ounce per acre on bahiagrass,or treat when these grasses arc in a semi-dumant Geranium,Carolina • S S C C C C condition. Geraniena c.rofiahoa m For best results on Winter annuals,treatwhen plants are in an early growth stage Henbit • S C C C C C (below 6 inches in height)after most have germinated. For best results on tall Laoshor rs pl.,icaule fescue,treat when fescue Is in or beyond die 4 to 6-leaf stage. Ryegrass,Italian • S S C C C C Wham moll flown, WEEDS CONTROLLED Speedwell,corn S C C C C C C Rate recommendations for control or suppression of Winter annuals and tall fescue I'mvnim arvensis are listed below: Vetch,common C C'. C C C C C Apply the recommended rates of this product alone or as a tank mixture in 10 to Kris solum 25 gallons of water. Flaw rates or mistures of rates apply only to sites where as established competitive turf is For the best recommendation for the mixture of weeds within your geographic present. arca,contact your Nufamn sales rcpmsenmtive. RELEASE OF ACTIVELY GROWING BERMUDAGRASS WEEDS CONTROLLED OR SUPPRESSED WITH RIVERDALE RAZOR When applied as directed, tris product will aid in the release of Bcrmudagrass PRO ALONE* by providing control of annual species listed in the"WEEDS CONTROLLED" NOTE:C=Control section of this and the Oust label, and suppression or partial control of certain perennial weeds. S=Suppression For control or suppression of those annual species listed on this label,use I to 3 pints of this product as a broadcast spray in 10 to 25 gallons of spray solution per RIVERDALE RAZOR PRO FLUID OZIACRE acre. Use the lower rate when Veating annual weeds below 6 inches In height(or WEED SPECIES S i'_ 16 24 32 64 length of turner in annual vines). Use lite higher tate as;weeds increase in size or as they approach flower or sccdhcad formation. Barley,little S C C C '.C C Use the higher rate of this product for partial control of the following perennial Iloedstlrum purli atcherr species. Use the lower rates for suppression of growth. For best results,sec the Bedstraw,nols, eetl $ C C C C C "WEEDS CONTROLLED" section of this label for proper stage of growth. ' Galium aparine Bluegrass,annual S C C C C C Bahiagrass Johnsongrass- Poo aan'. Paspalum nora(um .So,glr.nr halepense Chervil S C C C C C Bluestein,silver Trumpetereeper^" C'hr..rsphy!lrrrn mimmirri Andropogon sarchavoides Campsie rodicmrs Chickweed,common S C C C C C Fescue,tall Vaseygrass stell.d.media - Fes uca anindinac'ea Pasant...nrvillei Clave,,crimson • S S C C C TrJolium iocaroarum "Control at the higher rales. Cl.,.,,large hop • S S C C C T,jolivm eea,crtrr *"Suppression at higher rates only. Fescue,tan • • • S S This product may be tank-mixed with Oust. If tank-mixed,use no more than I Feslum armrdinacrae to 2 pints per acre of this product with 1 to 2 ounces of Oust per acre. Geranium,Carolina • • S S C C Use the lower rates of both mixtures to control annual weeds below 6 inches Geraurnn corollnian.nr in height (or tunncr length in annual vines) that are listed in the "WEEDS Henbit • S C C C C CONTROLLED"section of this booklet and the Oust label. Use the higher rates Lacon nr amplech aule as annual weeds increase in size and approach the flower or secdhead stages. Rs Use the higher rates of this product to provide partial control of the following Ita.lianli.. • • 5 C C - C Lolivm perennial weeds, Use the lower rates for suppression of growth. mnlriJlorvrn Speedevell,corn S C C C C C Bahiagrass Festuca arundinacea Verona.arvensis Paspalum notnlum Johnsongrass- Vetch,common •. • S C C C Bluestein,silver .Sorghum halepense Vida avtivo Andropogon.socchoroides Poorjoe•- Broc msedge Diodia teres *Thew rates apply only to.sites where an established competitive turf is present. Andropogon virginicus Trumpetcreeperak _ WEEDS CONTROLLED OR SUPPRESSED WITH RIVERDALE RAZOR Dock,early Canrpsh,rodicans PRO PLUS OUST" R...x crisp., Vascygross NOTE:C=Control Dogfennel Paspalum urvillei Cupatorium capilll/brium Vervain,blue S=Suppression - Fescue,tall Verbena haslala Riverdale Razor Pro+OUST 'Suppression at higher rales only. Riverdale "'Control at the higher rates. Razor Pro COOL SEASON TURF GROWTH REGULATION (FL.DZ/A) S 12 12 l6 16 12 16 When applied as directed,this product will suppress growth and sccdhcad dcvcl- + + + + + + + + opment of listed turf species in industrial sites. WEED SPECIES OUST(07VA) 114 t/a Is Ea $ 1 1 This product is recommended for management of clause turf on roadside ri-bts- Buriey,little - C C C C C C C of-way or other industrial areas. Do not use on high-quality turf or other altos Hordemn pvsilir or where some turf color changes cannot be tolerated. Slight turf discoloration may Bedstraw,calchweed C C C C C C C occur but turf will ragmen and regrow under moist conditions as effects of Ibis Golinivm oparinr product wear off. Bluegrass,annual S C C C C. C C Applv 4 to 6 fluid ounces of this product per acre alone or in a recommended Pon nano. lank mixture. Spray volumes of 10 to 40 gallons per acre are recommended. Chervil C C C C C C C This product can be used for growth and sccdhcad suppression of: Ch—rilkl4lum raiano-04 Tall FescndSmooth Brune Chickweed,common S C C C C C C Slellaria media For best results,apply this product in a recommended lank mixture to actively Clover,crimson S SS S C C C growing turfgrasses after grccnup in the Spring of the year. For suppression of Tri(ollum Incmrrnrmn scedhcads,applications must be made before boot-to-sccdhcad stage of develop- Clover,large hop • • S S C C C mens. Applications made from sccdhcad emergence until maturity may result in Tifolhoo rmnpano, turf discoloration or injury. Database and lormat copyright CO by Vance Communication Corporation. All rights reserved. SPECIMEN LABEL UPILITES AVAII.,ARL[: A'r WWW.GREENBOOK.NE'r 14 - After mowing or removal of sccdhcads, this product in a recommended tank mixture may also be used to suppress the growth of certain turfgmsses. Allow turf to recover from stress caused by heat, drought or mowing before making applications. Applications made to turf under stress may increase the potential for discoloration or injury. ANNUAL GRASSES For growth suppression of some annual grasses such as annual rycgrass, wild barley and wild oats, apply 3 to 4 fluid ounces of this product in 10 to 40 gallons of spray solution per acre. Applications should be made when annual .grasses an actively growing and before the seedheads arc in the boot stage of development.Treatments made after scedlhcad emergence may cause injury to the desired grasses. TANK MIXTURES For the following tank mixtures,consult each product label for weeds controlled and the correct stage of application. Do not treat turf under stress. TANK MIXTURES PLUS 2,4-D AMINE For additional weed control benefits,up to 1 pound a.i. per acre of 2,4-D amine may be added to the following tank mixtures. Consult the label for 2,4-D amine for weeds controlled. TALL FESCUE Riverdale Razor Pro plus Telar For suppression of tall fescue growth and sccdhcads,and control or partial control of some annual weeds,apply this tank mixture atter grcenup and prior to boot- to-sccdhcad stage of development. Use up to 0.5 ounce of Tclar per acre. - This tank mixture can also be applied after mowing or removal of tall fescue sccdhcads for turf growth suppression. Make only one of the above applications per growing season. - Riverdale Razor Pro plus Oust For suppression of tall fescue growth and seedheads,and control or partial control of sonic annual weeds,apply this tank mixture atter grcenup and prior to boot- to-sccdhcad stage of development. Use up to 0.25 ounce of Oust per acre. Riverdale Razor Pro plus Escort This tank mixture can be applied slice mowing or removal of tall fescue sccdhcads for to,f growth suppression and control m partial control of sonic annual weeds. Use up to 1/3 ounce of Escort per acre. SMOOTH BROME Riverdale Razor Pro plus Oust For suppression of smooth brome growth and seedheads and control or partial control of sonic annual weeds,apply this tank mixture atter grcenup and prior to boot-to-sccdhcad stage of development. Use up to 0.25 ounce Of Oust per acre. STORAGE AND DISPOSAL Do not contaminate water,foodstuffs,feed or seed by storage or disposal. STORAGE: STORE ABOVE 10'F (-12') TO KEEP PRODUCTS FROM CRYSTALLIZING. Crystals will settle to the bottom. If allowed to crystallize, place in a warm room 68°F(20'C)for several days to redissolve and shake,roll or agitate to mix well before using. PESTICIDE DISPOSAL: Wastes resulting from the use of this product that cannot be used or chemically reprocessed should be disposed of in a landfill approved for pesticide disposal or in accordancewith applicable Federal,slate or - local procedures. Emptied container matins vapor and product residue. Observe all label safeguards until container is destroyed. CONTAINER DISPOSAL: Do not reuse container. Triple rinse container. Then puncture and dispose of in a sanitary landfill, or by incineration, or, if allowed by state and local aulhorifics,by burning. if burned,stay out of smoke. CONTAINER DISPOSAL FOR REFILLABLE CONTAINERS: Close all - openings which have been opened during use and replace all caps. Contact Nolan" Americas Ine.'s Customer Scrvice Department at I-708/754-3330, to arrange for return of the empty refillable container. WARRANTY Seller warrants that the product conforms to its chemical description and is rca- sonably fit for the purpose stated on the label when used in accordance with directions under no anal conditions of use,but neither this warranty nor any other warranty of merchantability or fitness for a particular purpose,expressed or im- plied,extends to the use of this product contrary to label instructions,or under abnormal conditions or under conditions not reasonably foreseeable to seller,and buyer and the limit of liability of any such use. The exclusive remedy of user or buyer and the limit of liability of seller is the purchase In paid for the quantity of product involved. ®Razor and Riverdale at Registen'ed Trademarks of Nufarm Americas Inc. ®Oust,Krovar, Escort and Tclar are trademarks of E.I. duPont de Nemours and Company. OPrincep and Caliber arc trademarks of Syngenm Group Cu. r Surflan is a trademark of Dow AgroScicnces,LLC Products Company. ®Ronstar is a trademark of Aventis Group This product is protected by U.S. Patent No. 4,405,531. Other patents pending. No license granted under any non-U.S.patent(s).- VID 8.6.04 Database and format copyright©by Vance Communication Corporation. All rights reserve �ed. HERBICIDE FACT SHEET MASSACHUSETTS DEPARTMENT.OF FOOD & AGRICULTURE 100 Cambridge Street,Boston MA 02202 (617)727-7712 August Schumacherfr., Commissioner @L�EL B�'n..wdfrrsher! METSULFURON METHYL Common Trade Names: Escort, Ally (2) Chemical Name: Methyl 2 [[[[(4-Methoxy-6-methyl-1,3,5-Triazin-2-yl) aminocarbonyl] amino] sulfonyl benzoate] (9) CAS NO. : 74223-64-6 GENERAL INFORMATION Metsulfuron methyl is a sulfonyl urea herbicide initially registered by E.I. duPont deNemours in 1986. It is a foliar herbicide registered for use on wheat and barley and non-cropland sites such as Right of Way (9). ENVIRONMENTAL FATE Mobility Metsulfuron methyl is a relatively new herbicide. The studies reviewed here have been provided by the registrant, E.I . duPont. The soil water partion coefficients (kd) of Metsulfuron Methyl have been deter- mined in four different soils: Cecil sand, Flanagan silt loam, Fallsington silt loam, and keyport silt loam. The Kd values range from 0.36 for Cecil sand to 1 .40 for Flanagan silt loam, and Kom values ranged from 29 for Fallsington silt loam to 120 for Cecil sand (100). The values for Kd and Kom indicate that Metsulfuron methyl is not adsorbed well to soil and that the organic content of the soil is not the only adsorption component. The silt and clay contents appear to influence adsorption, but there are probably other factors also involved. The previous study also determined the Rf values for soil . Thin layer chroma- tography was performed on four soils for metsulfuron methyl . The Rf values ranged from 0.64 to 1 .00; only one value was less than 0.90 (100) . This result confirms the validity of the Kd values, indicating that metsulfuron methyl is mobile and that the organic matter content of the soil is a significant com- ponent of adsorption. Metsulfuron r„ethyl was applied to tops of 12 inch columns [containing four dif- ferent soils], and eluted with 20 inches of water in 20 hours. Following the percolation of the total volume of water, 106% of the Metsulfuron methyl was eluted from the Fallsington sandy loam, 96% from the Flanagan silt loam, 87% for Keyport silt loam and 93% for Myakka sand (100). The breakthrough volumes for the Fallsington, Flangan, Keyport and Myakka soils were 6.5, 4.5, 6.9 and 5.8 inches of water respectively (101) . PUBLICATION //16,073-7-75-10-89-C.R. APPROVED BY: RIC :MURPHY, PURCHASING AGENT - Metsulfuron methyl is relatively mobile in most soils, but will be retained longer in soils with higher percentages of organic matter. Persistence There arettwo .studies which have reviewed the persistence of Metsulfuron methyl in the soil . One study was conducted in the southern United States and the second was in the northern United States and Canada. The results of the studies indicate a somewhat contradictory picture of the persistence of Metsulfuron methyl . The soil half-lives in Delaware, North Carolina, Mississippi and Florida were 1 Week, 4 weeks, 3 weeks and 1 week respectively following an application in mid to late summer (102). The results are varied and indicate that either climatic or soil factors determine the persistence. The climate is sufficiently similar to be able to discount that as a factor. However, both of the locations where the shortest half-lives were observed had the highest organic matter content in the soils. Furthermore, the half-lives correspond with the organic matter con- tent. The half-lives following spring applications were 4 and 56 weeks for two sites in Colorado, 6 weeks in North DaKOta and 28 weeks in Idaho (103). In contrast to the southern United States study there does not appear to be any correlation with climatic or soil characteristics. There appears to be a slightly shorter half-life in acidic soils in the same location. Metsulfuron methyl was also applied in the fall and the half-lives determined in two sites in Colorado, North Dakota and Idaho. These half-lives were 8 weeks, 12 weeks, 42 weeks and 28 weeks respectively. As was expected there were longer half-lives following fall applications in North Dakota (6 weeks vs. 42 weeks) however, in Idaho there was no change at all, which is unexpected. In Canada following spring applications the reported half-life were 10 weeks, 4 weeks, 4 weeks and 6 weeks for Alberta, 2 locations in Saskatchewan and Manitoba ( 103). One would expect longer half lives in Northern locations due to the efeects of temperature on degradation rates. The results from Canada are generally shorter than those in the U.S. locations, which is unexpected. Therefore, the half-live of Metsulfuron methyl in the soil is variable and dependent on the location. It is shorter when applied in the spring but appears independent of other environmental factors in most locations. TOXICITY REVIEW Acute (Mammalian) The toxicology database for Metsulfuron methyl has been reviewed and accepted by the EPA (9). DuPont supplied excerpts from their monograph on ally herbicide (?12). Summaries of studies were supplied by DuPont for subchronic, chronic and reproductive studies. Technical Metsulfuron methyl has been tested in two acute oral LD50 studies in Crl :CD Rats. In the first study the LD50 was greater than 5,000 mg/kg and in the second it was greater than 25,000 mg/kg (the maximum feasible dose) (112). Clinical signs included salivation, chromodacryorrhea, stained face, stained perineal area and weight loss (112). In a 10-dole subacute study using male rats, a singe repeated dose of 3,400 mg/kg/day .for. 10 days over a 2 week period was administered. This was followed by a two week recovery period. No deaths occurred and slight weight loss was the only clinical sign observed. In addition, no gross or microscopic changes were observed (112). The dermal LD50 is greater than 2,000 mg/kg in male and female rabbits (112) . Technical Metsulfuron methyl caused mild erythema as a 40% solution in guinea pigs. There was no reaction observed at the 4% con- centration. No response occurred when treated animals were challenged (112) . In rabbits, moderate area of slight corneal clouding and severe to moderate con- junctivitis were observed in both washed and unwashed eyes following treatment with technical Metsulfuron methyl . The unwashed eyes were normal in 3 days and the washed eyes in 14 days (112). Metabolism Elimination of Metsulfuron Methyl in the rat is rapid, with 91% of a radioactive dose excreted over 96 hours (9). The routes of elimination were not specified. Within report Subchronic/Chronic (Mammalian) Ninety day feeding studies have been done with Metsulfuron methyl in rats and mice. The rat study was done in conjunction with a one generation reproduction study (see Developmental Study Section). In this 'study rats received 0, 100, 1000, or 7500 ppm (0, 5.7, 57, 428 mg/kg/d) (a) in their diets. Effects observed at the high dose were: a decrease in body weight and an increase in total serum protein in the females, and a decrease in liver weight and a decrease in cytoplasmic clearing of hepatocytes in the males the NOEL in this study was 1000 ppm (104) . The 90 day mouse study was done in conjunction with the 18 month mouse study. Groups of 90 mice per sex per dose received 0, 5, 25, 500, 2500 or 5000 ppm (0, 0.66, 3.3, 66.6, 333.3, 666.6 mg/kg/d) in their diets. Clinical evaluations were made at 1, 2, 3, 6, 12 and 18 months. Ten animals per group were sacri- ficed at the 90 day time point for pathological evaluation. The 2500 ppm group was sacrificed at 12 months. Sporadic effects were observed on the body weight, food. consumption, and organ weights. These were not dose related, resulting in a NOEL of 5000 ppm in diet for mice (111 ) . In the twenty-one day dermal rabbit study, the intact skin of male and female New Zealand White .Rabbits received doses of 0, 125, 500 and 2,000 mg/kg for 6 hrs/day for 21 days. Clinical signs observed were sporadic weight loss and diarrhea in a few rabbits. These effects were not dose related. Non dose related histological effects were observed in male rabbits. This effect was charac- terized as mild testicular atrophy occurring sporadically at all doses (112, 108). Feeding studies in dogs have been done with purebred beagles. The animals received Metsulfuron methyl in diets at dose levels of 0, 50, 500 and 5000 ppm (0, 0.2, 2, 20 mg/kg/d) for one year. There was a decrease in food consumption in the high dose males. There was a decrease in serum lactate dehydrogenase in all groups, of. both sexes at two or more doses these values were within the historical controls. The NOEL was 500 ppm in the males and 5000 ppm in females ,.(112). In a chronic feeding study in rats, the animals received Metsulfuron methyl at doses of 0, 5, 25, 500, 2500 or 5000 ppm (0, 0.28, 1 .4, 28.6, 143 or 286 mg/kg/d. Interim sacrifices were done at 13 and 52 weeks (105) . At the 13 week sacrifice there was a decrease in body weight in the 2500 and 5000 ppm groups; there was a decrease in absolute liver weight at 2500 and 5000 ppm males. There was a decrease in the relative liver weights in the 2500 and 5000 ppm females. (a) In these discussions the assumptions made for estimated conversion of ppm (diet) to mg/kg/D were: Species Body weight (kg) Intake (kg) Rat 0.35 0.020 Mouse 0.03 0.004 Dog 10' 0.4 When data were presented as ppm, the dose was estimated in mg/kg and is presented in parenthesis. Findings at the 52 week sacrifice included increase in kidney weight (2500 ppm males) and increase absolute brain weights (at doses of 25, 500, 2500 and 5000 ppm) in males and at doses of 2,500 and 5000 ppm in females. There was an increase in absolute heart weight at 2500 m in males n 9 pp e and at 2500 and 5000 ppm in females. The absolute organ weights were back to normal at termination. Relative brain weights of the 2500 and 5000 ppm groups were increased (105) . Oncogenicity Studies There were no gross or histopathological changes observed in mice receiving up to 5000 ppm metsulfuron methyl in their diets (112, 111). Similar results were obtained in the 104 week rat study; there were no histopathological changes observed which were attributable to metsulfuron methyl (105, 112). EPA concludes that there were e e n o oncogenic effects in rats or mice at the highest dose tested; 5000 ppm in both cases (9). Mutagenicity Testing Metsulfuron methyl was negative in the unscheduled DNA synthesis assay; in vivo bone marrow cytogenic assay in rats (doses were 500, 1,000, and 5,000 mgTkg bw); CHO/HGPRT Assay; Salmonella typhimurium reverse mutation assay four strains with and without S9 metabolic activation; and also in the in vivo mouse micronucleus assay ,doses- of 166, 500, 9666, 3000 and 5000 mg/kg (112). Theonly positive mutageni- city assay was in the in vitro assay for chromosome aberrations in Chinese Hamster Ovary at high doses (greater than 2.63 mM, 1 .0 mg/mL)) . In this assay no increases in structural aberrations were observed at 0. 13 or 1 .32 mM(0.05 or 0.5 mg/mL) (112). Developmental Studies Several studies have been done to investigate the effects of Metsulfuron methyl on reproduction and development in rats and rabbits. Pregnant Crl : COBS CD(SD) BR rats received metsulfuron methyl at doses of 0, 40, 250 or 1000 mg/kg by the oral route on days 5 to 14 of gestation. There were 25 rats per group. Maternal toxicity was. observed at doses of 250 and 1000 mg/kg/d. The maternal toxicity NOEL was 40 mg/kg/d. There was no evidence of "teratogenic" response or embryo fetal toxicity (112). In the rabbit study, New Zealand white rabbits received 0, 25, 100, 300 or 700 mg/kg/d on days 6 to 18 gestation. There was a dose related increase in mater- nal deaths; 1 , 2 and 12 deaths at doses of 100, 300 and 700 mg/kg respectively. The maternal toxicity NOEL was 25 mg/kg/d and there was no evidence of teratoge- nic or embryolethal effects observed in this study (112). Several multigenerational studies have been done with Metsulfuron methyl . A four litter reproduction study was done concurrently with the chronic bioassay. Rats from each treatment were separated from the main study and bred. The doses were 0, 5, 25, 500, 2500, and 5000 ppm (0, 0.28, 1 .4, 28.6, 143 and 286 mg/kg/d). There was a dose dependent decrease in body weight in the parental (P1) generation at doses of 25 ppm and greater in males and females. This effect was not present in dams during gestation or lactation (106) . Overall fertility in the PI and filial (Fl ) matings was low in both control and treated groups with no apparent cause. There was a decrease in pup size in the Fla but not the Flb, F2a, or F2b litters. The gestation index was 100% for all groups in both filial generations with the exception of F2a when it was 90%. On the basis of the lower body weights and lower growth rates, the NOEL was 25 ppm for this study ( 106). In a 90 day, 2 generation 4 litter protocol , rats received 0, 25, 500 or 5000 ppm (0, 1 .4, 28.6, 286 mg/kg/d) Metsulfuron methyl in their diets for 90 days prior to mating. In this protocol the parental generation was bred twice first to produce the Fla and then the FIB. The FIB rats were then fed the appropriate diet for 90 days (after weaning) . There was a decrease in litter size in the 5000 ppm group in the F2a generation, but not in any other genera- tion. The NOEL for this study was 500 ppm ( 107). In a 90 day feeding, one generation rat study, 16 male and 16 female rats received 0, 100, 1000 or 7500 ppm in their diet prior to mating. There were no differences observed in reproduction and lactation performance or litter sur- vival among groups. There was an overall low fertility in the control and treated groups. This result made the effects of metsulfuron methyl on fertility difficult to assess from this study (104). Tolerances and Guidelines Tolerances have been set for Metsulfuron methyl in barley wheat (from 0.05 to 20 ppm, depending on the commodity) and in meat and meat byproducts (0.1 ppm) . The tolerance in milk is 0.05 ppm (8, 9). The acceptable daily intake is 0.0125 mg/kg/d based on a one year dog NOEL of 1 .25 mg/kg/d using a safety factor of 100 (9). Avian Metsulfuron methyl has been tested in two species of birds, the mallard duck and the bobwhite quail . The acute oral LD50 is greater than 2150 mg/kg in the duck. Two, 8 day dietary studies have been done. The 8 day LC50 is greater than 5620 ppm inboth the duck and the quail (9) . Invertebrates The 48 hour LC50 for Daphnia is greater than 150 ppm and the acute toxicity in the honeybee is greater than 25 mg/bee (9). Aquatic Metsulfuron methyl has acute LC50 of greater than 150 ppm in both the rainbow trout and the bluegill sunfish (9). Summary Metsulfuron methyl has a moderate to high mobility in the soil profile and is relatively persistent in the environment, especially when applied in the fall . These factors would be of concern under most circumstances. However, met- sulfuron methyl is applied at very low rates (3-4 ozs./A) and therefore the amounts which reach the soil are quite low. Consequently, Metsulfuron methyl should not impact groundwater as a result of leaching or migrate from the target area. Metsulfuron methyl has low toxicity (EPA Toxicity Category III) for acute dermal exposure and primary eye irritation and is category IV for all other acute expo- sures. The chronic studies indicate no oncogenicity response and the systemic NOEL's are 500 ppm in rats and 5000 ppm in mice. There was no evidence of tera- tological effects in the rat or the rabbit at the highest dose tested in both species. While there was evidence of maternal toxicity at 40 mg/kg/d in the rat and 100 mg/kg/d in the rabbits. REFERENCES 2. Farm Chemicals Handbook: 1985 Dictionary, buyer' s guide to trade names and equipment. Rub. by Meister Pub. Co. 9. EPA Pesticide Fact Sheet Metsulfuron methyl : 1986 Collection of pesticide chemistry Pub. by US Government Printing Office 461-221/24041 100. DuPont Soil Column Leaching Studies with [14C] DPX-T63761 (AMR 82-82) . 101. DuPont Adsorption of 14C DPX-T6376 on Soil (AMR-66-82) . 102. DuPont Field Soil Dissipation Study of DPX-T6376 in Delaware, North Carolina, Florida, and Mississippi (AMR 66-82). 103. DuPont Field Soil Dissipation of [Phenyl (U) - 14C] Metsulfuron Methyl on United States and Canadian Soils (AMR 476-86) . 104. DuPont HL 180-82; 90 day feeding one generation Reproduction Study in Rats. 105. DuPont HLO-61-85; Chronic Feeding Study with Concurrent Two Generation Reproduction Study in Rats - Chronic. 106. DuPont HLO-65-85 Chronic Feeding Reproduction Phase. 107. DuPont HLR-524-84 Two generation, Four Litter Reproductive Study in Rats. 108. DuPont HLR 137-83 Subchronic Dermal Study (21 Days) in Rabbits. 111. DuPont HLR 463-84 Ninety-Day and Long Term Feeding Study in Mice. 112. Ally Herbicide Product Monograph. oU PONT KEEP OUT OF REACH OP CHILDREN GENERAL INFORMATION DIRECTIONS FOR USE Do not use this product in California nor in the following CAUTION counIt is a violation of federal law to use this product in a ties of Colorado: Saguache,Rio Granule.Alamow. manner inconsistent with its labeling. r Costilla and Camillus.tHeDo not apply this product in a way that will contact workers Oc ESCOrtO STATEMENT TICAL DuPontwater nd applied is a dispersiblegranulefor con"Io oderpersam,eiderdireetlywthnoghddft.Onlyproketed TREATMENT - mixed in water and applied as a foliar spray for conmil of handlers may be in the area during applinsioo.For any In case ofcontact with eyes.immediately Rush with plenty unwanied woody plants and annual and Perennial broadleaf requirements specific to your Stam or Tribe.coosull the agency herbicide of water.If onskin,wash with plenty of soap and water. weeds,basal soil trealmem of multiflora ma" for preemer- responsible fo pesticide egulati�n Get medical attention if irritation Persists State and Wsmmergence industrial weed control,and for the growth suppression of certain desirable grasses in roncrop 'Swort"Herbicide should be used only in accordance with For r medical 1411 emergrmc7. Involving this product,call rp rts.highways.roadsides.utilityand recommendations on this label or in separate published Du areas such as ei Pont recommendations available through local suppliers- pipeline free 1-B0044I-J637, pipeline righa. r-ways,petroleum conk farm,storage areas. 6 Pp Dry Flowable PRECAUTIONARY STATEMENTS Pumping installations.plant sites.industrial turf.roadside turf, Do Pont will not be responsible for losses or damages Active lagndirnt By Weight railroad rights-of-way and fence rows. resulting from the use of this product in any manner not MemulNron methyl HAZARDS TO HUMANS AND DOMESTIC Do nm apply to open must(ouch u lakes,reservoirs,rivers, specifically recommended by Du Pont.User assumes all l Methyl 2-(111(4-methoxy-6 methyl- ANIMALS streams,Creeks,salt water bays or examines)nor while wamr risks associated with such ronrecommended use. I -1,3,5-nixiin-2-yI)aminol. CAUTION!Causes eye irritation.Avoid contact with - is present in fresh water wetlands(such as marshes,swamps, Do Pont"Escon"Herbicide is recommended as a postemer. carbonyl)-aminolsulfonyllbenzoate) 60% skin,eyes or clothing.Avoid breathing dust or spray mist. bogs or Potholes)rear to salt water marshes within tidal areas genre application for control of brush and cerin perennial i lnerf ingredients 40% rem ce nor to ass"where the herbicide is likely move into water broadleaf weeds and Pmemergence and pos emergenfor PERSONAL PROTECTIVE EQUIPMENT .(such as insides of ditches.steep banks along waterways or weed control connoneropland."Escon"is 21W'commended- TOTAL 100% Applicators and other handlers must wear: impervious substrates)nor to areas neardtsimble plants for weed control on established.unimproved,industrial turf Long-sleeved shin and long Panni. where roots of these Plana may extend. It is permissible to and native perennial grasses.On fescu ibtuegrass turf, .Shacs plus sacks. btu the bens,of ditches;sanswr dly dry flood plain;,Most. 'Pscon"is recommended for growth suppression and FolluwmanufxturersinswctionsfordeaninpJmain- marshes,swamps,bogs and transitional areas between upland seedhead inhibition. - and lowland rims. EPA Reg.Na.352-439 raining PPE.If no such instructions for washables,use For tank mixes,use the most restrictive limitations from detergent and hot water.Keep and wash PPE sepaxrely Wamx moist conditions following treatment promote the labeling of both produces. U.S.Patent 4.383.113 from other laundry. activityof'Escon",while cold.dry conditions may reduce W Consul)your chemical SupPI ier,applicator.consultant, . delay activity.Weeds and brush hardened off by cold weather appropriate state agricultural extension service representa. USER SAFETY RECOMMENDATIONS ordmughr sows may not be controlled.Degree ofcontrul and live or your local DuPont representatives for specific duration ofetfcst an,dependent on the''used.sensitivity recommendations. Users should:Wath hands before easing,Drinking, and six of target species-u well as soil moisture and soil chewing gum.using tobacco or using the toiler. temperature. AGRICULTURAL USES Following the use of"Escott".some newmlly-attuning ENVIRONMENTAL HAZARDS bimypesorpestspecieslisted onthis label awynot beeftee- AGRICULTURAL USE REQUIREMENTS Do not apply directly to water.or to areas where surface dvetycontrolled. Biotypessm individualsofthe species water is pmsenr,or to intertidal areas below the mean high which have a slightly different genetic makeup. Resistant U'Nis product only in accordance with its labeling and water mark. Do not comamitate water when disposing of biotypes may look exactly the same as susceptible biotypes with the Worker Protection Standard,40 CFR pan 170. i equipment washwaters. but are able to survive a use now several tines higher Nan This Standard contains requirements for the promcdon of needed to commit susceptible biotypes.To delay the Occur. agricultural workers w(arm,(n'sa,nurseries,and gteen- Thissrbtions. injurious toptanmts y be adversely a=ofmatant bion Iwmses.udhandlerso(ariculmral sticides.llcontaim concentrations. Numarga plan's may be adversely wits,use"Figuwred he k cider Wm g pr eRecmJ from drill anJ con-teff. sequential treatments with other¢gisertd herbicides requirements for training,decontamination,ngifipriw, effective on the same broadleaf weed species. Do rot kr and emergency assistance. It also contains specific immic. IMPORTANT weed escapes go reseed;time posmmergeace treatments dons and exceptions pertaining to de stammenm on this berme seed foetation. Respny problem areas in a timely and label about personal pmmctive equipment(PPE)DO NOT USE ON FOOD OR FEED CROPS EXCEPT AS effective manner using a herbicide with a different node of msoicu d<ntry interval.The qu pment(PPE)and RECOMMENDED BY THIS LABEL OR SUPPLE. requirement,in this box only MENTAL LABELING. Injury to or less ofdesimbte trees action' apply to uses of this product that ane covered by de Worker - - Or Other Plana may result from failure to observe the "Escort'is noncorrosive.nonflammable.nonvolatile and does Protection Stardand. following:Do not apply"Escon"Herbicide(except as not f tem. Do nor enter or allow worker"into treated areas during recommended),or drain or flush equipment on or neor MODE OF ACTION the restricted may interval(REI)of 4 hours. desirable Met or other Plants,or on area,where their mots may extend or in locations where the chemical may be however,typicadlyl stops growth is susceptible plant spade; PPE inquired for early entry r treated areas that is Y however,typical eymPmms(discoloration)may not n reatice- pertained under the Worker Protection Standard and that washed s.mated lore Contact with their roots Do not use able for several weeks after eppli ility. depending on involves contact with r.isthat has been treated.such on lawns,walks.driveways,tennis twos,or similar uveas, anything Prevent drift of spray to desirable plant.%. Do not comxmi. Browing conditions and susceptibility.Weeds absorb"Ewan" az plana.soil,or water,is: through both tai foliage and rwa resulting neddi in visual effaa Coveralls. nate any body it water,including iici des.f water. Keep Progressing from growth inhibition di reddishion an sh Shoes plot soaks. from cwtun with fcnilixrs,insecticides.fungicides and colaatiw,chlorosis,retro%;%,vein discoloration and death of sem' terminal.Initial effects tie usually seen 2 or 3 weeks Following an"Etwon"application,do not use sprayer for following application;however,the final effects m weeds are application to emits This is extremely important.as low evident at about 4 to 6 weeks after application.On brash. rates of"Escort"can kill nu severely injure most emirs ultimate effects Occur during the season after treatment. (except small grains). 1 2 WEED AND BRUSH CONTROL For broader spmmum control."Escort"should be tank- RECOMMENDED MINIMUM SPRAY VOLUMES CONIFER PLANTATIONS mixed az follows: PRODUCT VOLUME-GALUACRE RATE SITEPREPARATION "Arxnal"-Apply 1/2 to 1.1/2 ors'Escon"plus l pt SITE PREPARATION SPRAY AERIAL•HELICOPfER NONIONICSURFACTANT "A.sctul"(plus surfactant)per acre. Apply during FOR LOBLOLLY AND SLASH PINES GROUND ONLY- OTV180 GALS Loblolly Pint and Slash PJnr Only summer to lata(all(preferred)as described on the For control at blx�kbcmy and other brodicaf weeds(we "Arsenal"container label. The combination cannot,or "E*z^^" ll) ll) I listing under Noncnsp Weed Control).apply lt2lo 1.1/2 improves control of blackberry,black gum.elm.winged "&con•+'Arsenal' 15 10 1 oes"Escon"per xre(plus surfactant)by air or ground elm,and cherry and controls many weeds as shown on -Swon'+'Velpar"L 25 10 l equipment.Treat blackberry plants after they have reached product labels. --Pww"+'Accod"or Roundup 10 10 2 full leaf,but before leaf tissue has hardened in the fall. Use . "Wipaf'L(or"Velpar")-For brush control and herbs. 'Facet"+'Oust" 15 10 I sufficient spray volume for complete coverage of these mus weed control(see container labels for species PRODUCT VOLUME•GALS/ACRE RATE plants. For control of diffuse knapweed•Japanese honey- controlled).apply I/2 to I-1/2 ass"Exon"plus 1-1/2 to 6 SITE PREPARATION SPRAY AERIAL•HELICOPTER NONIONIC SURFACTANTsuckle.palmetto.black cherry and black locust,apply 3-1/3 gm'Telpar"L for equivalent"Velpar')per acre. Do not oas"Exon"per acre(plus surfactan). use surfactant. FOR DOUGLAS FIR GROUND ONLY- OTS/100 GATS For broader spectrum control,lank mix with: "Oust"at 2 to 3*as per acre for herbaceous weed control. "F+mo" 10 10 1 • "Arsenal"(as registered)for dewberry,greenbrier,honey- Do net use surfactant. Apply late winter through spring "Excess-."Velpae L 25 10 I suckle,maningglory.poison ivy,redvine.wmpet after the mil has settled around the pines. PRODUCT VOLUME-GALS/ACRE RATE creeper,wild grape,sumac.beech,aspen,black gum,box Do nor apply where conikrs are suffering from lou or vigor RELEASE SPRAY AERIAL-HELICOPTER NONIONIC SURFACTANT cider.chinaberry.dogwood•hickory.persimmon,red caused by insects,diseax,drought winter damage.IX other maple,sastafns.somwpod,sweet un.yellow lar and FOR LOBLOLLY OLLY PINE GROUND ONLY- OTS/I00 GALS P B POP townif,az injury may result. Ege from a injury may result "pw�" 10 10 I others(we cbntainer label)- mconifers less than 4 years of age from lransplaming on • 'Telpae'L(az registned)for bracken fem,ash,aspen, ..textured mils,and less dun 3 years of age(rota - Pines established I yr. balsam,blackgum.cherry.poplar.birch,box elder, transplanting on medium and fine-textured mils. Use on "Fzmrt"'Arsenal" 15 10 I brambles.cherry(black and pin).elm.winged elm, gravelly or rocky mils and exposed subsoils may cam Pines established 2 ins. hawfl one,hard,honeysuckle.oaks(red,black and injury IX mortality to conifers. Poor weed and brush control 'Finn'+"Dun' - 10 10 0 white),and willow(.see container label). may occur from application made when the mil is saturated Pines established I yr. • "Accord"(m'Roundup"'both as registered)for with water and min is imminent within 24 hours. Do not 'I.-+WdWL 25 10 0 black um,bmkm fem,the use on poorly drained or marshy sites but it may be used g try.Virginia creeper. Pines established I vr. dewberry,honeysuckle,.black sum c.ewe persimmon,poison '"here pines are planted on beds. A foam-reducing agent ivy,sasta(raz,mmwod,sumac,sweet gum,haw[hom, may be added at the recommended rale,if needed. -Do std apply brat,(helicopter)within 200 fat o(anY homestead•agricultuoi land mdhrdainble plmtings.Extremc care much be taken no prevent drift or ruroR no honwneds.attainable planings.agricultural land many body of waer.Do not apply when weather mel). creeper,wax myrtle and others(see container - Apply az a fullerwrecoverage spray en foliage and stem. Total conditions(...drift from aeud tate.. label). spray volume per acre will depend upon plant height and • "Oust".12 to 3 oazracm(lobloll pine only) man density of growth and the type of equipment used. See" yP y y Recommended Minimum Spray Volumes." NON-AGRICULTURAL USES weeds.may,begresulprapplypste orgencet young. Uus herbaceous horse cad.coleavesandgnsren.such as, wrIXds.berfar wig results.apply thapmem ort-stos)ata fireweed,hblack mustard. ragweed.Annual Loblolly pine may beonslash edit.Uemedantesas NON-AGRICULTURAL USE REQUIREMENTS of the year. (test that i i"tall a2"pmwemanyrime mw.barmy black adcums.n ed cansweet dove(,curly months after ths after application: pine the following the f season.at of dus yeer,aapt.ben ground!is Kossa For posdnnergence dock.bamyadgrass.panicums.reed canarygrazs, leazt6 months after application:Deuglaz fir the fallowing The rtquirtmenD in this box apply awas of this product tratnent and sudactant pokeweed.sigtulgrass and others(we container label). season after treatment of"Escort". dtaz ane NOT within the scope of ft Worker Protection "Swan"should be used during seasons when rainfall normally Apply to seedling weeds. Fm application of"Escort"alone or in combination on Smndand fIX aVkul=l pesikides(40 LTR Pan170).The Douglas Fir loblolly pine and slash pine,follow directions on the WPS applies when this product h used m pndnce agricut- acne o az eedt herurc h required el mane'Escon"into Jus mot zaec.(weeds berm rats coastadevell or ppreestam;bee most sthsystem For control of blackberry and other broadleaf weeds,apply Package label of the companion product in edition m mrd plants m farms,foist;nunmeries.IXgreenlauxs. prtemergenea beaurcnBcontrd a suppers weeds through rod 'Escon"directions above;We labels for additional plants Nonerop Industrial wed eowad std selective weed uptake. merence works throw I/2 gl I oz'may be per acre(plus surfactant)in the spring. poke P B through n.'uptake and controlled. Follow all restrictions on labeling of boot m0tro1 N turf(Industrial,uoMptord only)art not Douglas Nr may be transplanted in treated areas tlrc next foliar uptake.cturr retic rainfall conditions."Exist"may not xasoa products in the tank mixes. � within the cope of the Worker Protection Standard. provide vusfxroy ace Mlrol. "Exon"u not rteommeMd for weed central to facilitate Treated mils should be kfl undisturbed m reduce the potential For broader spectrum control."Exon"should be tank- the harvestin of pin straw. NON-CROP NDUSTRIAL WEED CONTROL mixed with"Velpar"L Herbicide. Use'Tclpae'Laz B P I (a"Exon"movement by or water. directed on the package for gmopd equipment. Livestock may graze treated areas 0 days after application "Escort"is rtommerded fur tax far general weed control on Injury in crops may axur when banned mil is blown or moved RELEASE of up to and including 1 213 oz"Exon"per sent. For nonamp,industrial sites such as airpdn,miliary installatraas, now land used to produce caps. combinations,tax the most restrictive recommendation of - fence taws,madddes ad associated night.(-ways,lumber- Rate selection is based m weed speckd s.wesire and soil Labially Pine(established plantations) - proacrs used. yards.petroleum tank(amu•pipeline and utility rightsof-ways. mxmm.Use to higher ods an established plants and onram For control of blackberry.apply 1/2 to l-1/2 on'Escon" pumping hologram.oilmads,mange areas.plant sites and textured mils.and lower muss on smaller weds and coarse per acre in a minimum of 10 gals water per acre by air or otter similar areas including governmental and private lads textured its. ground equipmem,plus surfactant.Treat plants when they When applied at lower dosage mats(as listed below),•Exort" Since ase degree armed and duration of effect will vary with have reached full leaf but her=leaf tissue has hardened in pwridesshm term consul of weeds listed:usage at higher nes the swear,ofchemical applied.soil teaua,soil PH.mil Organic the fall.Treatment will also consul many annual brodlea( inemaxsk length ofwed caned.Combtneaa.0 with nB Brea mates weed it the dnfallad othercorears. itustaggered .reds(ace Wed Control);best result)occur when annuals Xother and K bicldu such as 2,4-D, a specs E ofweeds Hyvar' that tiers limit dein first tau m small areas an IntaeJ in the walling nage. B are Rrovar•I ad ice.bathe geewm of weds hesorcontrolled. For broadcast spoy.apply. "Escort"in a minimum of 10 gallons Baa grouts abjecava can ompamodwithides. rates of of water per acre.Spray volumes of 20 a 40 gallons per acre and 'Esrnrt"plus residual-type companion heNieides. pressures;of 25 to 35 psi are preferred. Use coarse splay nozzles. 3 4 Application may also be nude wish a hand gun using 100 m 300 SPECIAL WEED PROBLEMS GROWTHSUPPRESSION necessary to spray from both sides to obtain adequate gals war"per acre on,needed fa coverage orweed growth). Since kochia.Russian thistle and prickly ieltme ase known to AND SEEDHEAD INHIBITION('Chemical Mowing') coverage.Use the following amounts of•'Escort"per 100 Use the following rales of"Escorn"(including surfactant at have biotypes resistant to"Escort",tank mixture combinations Fescue/Bluclumes:'Escon"is recommended for use on gallons of water(include surfactant at 1 quart/100 gallons) 0.25%to 0.5%by volume)to control weeds listed: should be used involving herbicides with different modes of unimproved turf in noncropland area for growth suppers. and spay to nnoff for control of. action such as"Kamsex"DF."H ae'X.and'Krovat'1 DF. sion and seedhead inhibition of well-established turf.Apply 1/I 1,1 Ounce• IU fo 1/T ounce'Freon'/acre These weeds should nor be allowed to form mature wed and 114 to 112 ounee'Escon"after at least 2 to 3 inches of new . Annual broomweed Goldenrod should be treated poswmergeree:with herbicides registered growth has emerged until seed stalk(boot)appearance.For Ash Multiffosa rose Annual..thistle Gumweed fncrawl of dose weeds such as 2,4-Dand dicamba. improved performance.apply 1/4 to 1/3 ounce'Escon"plus . Aspen Salmonbeny Astir Henbit 1/8 to 1/4 pint'Embark"2-S'peracm..Addition of a Blackberry SELECTIVE WEED CONTROL IN cry Snowberry Bahialm Larenall tiers provides maximum perfor%byvorumay to per 100 gals) B«balm Maresuii (INDUSTRIAL,UNIMPROVED ONLY) provides maximum performance,but may umponriiy Chem' Thimbleberry Bittererets Maximilian "Escort"is recommended for use or,unimproved industrial increase chlorosis of turf. Elm Wild roses Bitterweimeweed sunflower turf where certain gasses are well-established and desired u SELECTIVE WEED Hawthorn Willow Blazkeyed-suwm Miners latuce ground cover.An application of"Escort"may cause CONTROL IN NATIVE GRASSES - Blue mustard Pennsylvania temporary discoloration of the grasses. I to 2 Ounces* Bur buttercup smart sed BLUE GRAMA.BLUESTEMS(BIG.LITRE.PLAINS, Applications can be made anytime•except when ground is SAND.W W SPAR).BROMEGRASSES(MEADOW Elder Osage orange Cheery Plains corcopsis )• 8 g frown.Apply uniformly with properly calibrated ground BUFFALOGRASS.GREEN SPRANGLETOP,INDIAN- Red maple Clover Plantain Oaks Cocklebur Redbuw pismed Sprayer pressures to to 100gallons ofspay solution per=a. GRASS.SAND.KLEINGRASS. G.WIL ASSES(ATHER- Commanchickweed Redsmm 0larte Sprayer pressures of 2510 JS psi are prtfemd. STONE.SAND.WEEPING.WILMAN),ORCHARD- Ocean spay Cottonwood Common groundwl Rough Oeabvw Avoid overlapping and shut air spay beams while starting. GRASS.SIDEOATS GRAMA.SWITCHGRASS (Holodiscus) Common mullein Shephents purse turning,slowing or stopping when spaying.Extreme cart (BLACKWELL).WHEAT-GRASS(BLUESUNCH. •Whore mixed stands occur•use the higher rate for the Common purslane Smallseed falser. must be taken to prevent drill add a drift control agent to - INTERMEDIATE.PUBESCENT SIBERIAN.SLENDER, most difrcult-to- control species.' Corton yarrow Smooth pigwecd reduce drift use at least 10 gals water per sort. STREAMBANK.TALL.TH ICKSPIKE.WEST ERN), Conical cowboy Swectclover Do rat>.in Iy Macon"to turf that is under suess from AND WILDRYE GRASS(RUSSIAN): For broader spectrum of control,"Escort"may be tank mixed with Du Pont Krenimo S."Arsenal'°,triclo r or Can cackle Treacle ssm drought.My re disease,cold tempenmm or poor fertility, - Apply I/10 or'Ewon"in a y vola a of 10where gals eels have PY Cow cockle Treacle mustard az injury may result. acre:add 0.25%surfactant by volume where weeds have 81YPhosate using labeled use ares for each product. Crownvcwh Tumble mustard "Eumt"at 112 to 1 oz plus"Klemm"S at 1 112 to 3 gals Deadelion Wildcanot Do not apply to orf less than lyear old. emerged. P Dog(cnmel Wild lettuce Do nor use on bahi rass turf,as severe in will result New Seedingt (plus lofblack per100galswaterprovides improved a8 injury controle"black cherry and red maple;do not exceed 6 gals False chamomile Wild mustard Use the lower ares for minimum effeet(chlarosis)of tuK. Apply prtPlmt or prtemergence when soil(wed bed)has "Krcnim"Sper acre. ' Flddleneek tarweed Wooly crmoo particularly fescue and ryegass. been cultivated. Do not neat orchardgrass or Russian Low Volume Foliar Cround Applications:Apply o7 Flpennycress Wood soml Livestock may graze treated taxes 0 days after application of wildrye grass. ounces"Escon"per acre in 25 m 50 gals of water plus FlUixweed Yankecweul u to and including 1 213 oz"Escort" r acre.Do not ase on Eatablithrd Grasses 0.25%surfactant b p g per y volume for control of ash,cherry,elm. 1/2 to I ouare'Ewan'/acre grasses grown for wed Treat when in the seedling stage for control of: winged elm,black locust.red oak,nlliume and mulberry. -FESCUEBLUEGRASS:Apply 1/4 to VI ounce'Swon" For improved control of black cherry and red maple,apply Blackberry Gores per acre. Sequential applications made during the same or Bur buttercup(testiculate) Marestail• IR to 2 on"Escort"plus l-ld to 3 gals"Krenite"S(plus Broom smakeweed Common sunflower consecutive growth periods(spring and fall)may result in Common purslane Pigwetd surfactant)per acre. (apply faiplantain n8) Prosmre ss weed Buckho (thud exttuivx irjury to serf. When a spring appifcation is made a Common wnflowcr• -milmot and tumble Spotgun Baal Sor Treatment: For conmol of multilloa Canada mstle- muhinoHoary row word application may be made during to summer a fur full Cutleafevenin rimose• Snows speedwell caw,prepare a spray suspension of'Ewon"usin Iounce Cmada el, - Motier w lore and seedhead maturation and the beginning of summer damwey.. gP g Curly dock other wild roes Flixweed• Tansymustanl' Product per gallon of water.Mix vigorously until'Eseon"is Dyxea .it Roaring gaillards CRESTED WHEATGRASS AND SMOOTH BROME: lambsquarters•- Tumble mustard(Jim Hill) dispersed and agitate periodically while applying the spay Apply 114 to 1 ounce'Esetm"per acre far weed cannot in -common and slimleaf suspension. I ounrer'Erron'/acn these gasses.Some chlorosis a stunting may occurfollowing Apply these preparation i . Papa delivery hand Perrcnial Pepperweed Teasel the application. - •Weed suppression is population visual reduction in weed compete- gun applicator.This equipment delivers a thin steam of a BERMUD nsul. :Apply i/4 to 2 ountts'Escan"per acn tion(reducod am. Degr fs vigor) i compared to predetermined for volume when triggered.Apply at the are of a Iroi ounnt'Esron'/erre for weed consul. untreated area. Degree of suppression will vary with size 4milliliters foreuh2fact of row canopy diamner.Dicta Some chlorosis or stunting my occur following the applica- of weed and environmental Conditions following the treatment to the soil within 2 feet of the stem union of Bull thistle Scouringashrico treatment. the row to be controlled.When treating large plans and Common tansy —Salsify BRUSH CONTROL more than one delivery of"Fscorl"dispersion is required. Feld bindweed• Snowberry Treatments listed will control the following weeds: liu applications should be made after brash is full make applications on opposite sides rl the plant. Polon hemlock Musk thistle 114 1.1/3Fo ounce'Freon'/ane Pp' y Scotch thistle � leafed until the beginning of fall leaf coloration.Complete Applications should be made form early spring to summer. a of all foliage and stems is required for brush .when the ground is not frozen. g 1 1/1 to I ounces'Etrort'/acrr Bitrercress Chicory coveng- control.Effectiveness may be educed if rainfal l attars Blue mtercup - Fadsucinnycress Durecap larkspur Tali lahsWr Blue weed Wild cannot a within 24 hours Polar Ground n.A Chickweed Wild carrot High Volume FoliarCround Applications:Apply rasa 3104 aunc<a full coverage spay to foliage.stems and limbs using up to I/3 a I ounces'Escort'/acre 400 gallons of total spay per acre depending on plant Kudzu (See listing under"NON-CROP WEED CONfROL'I species•height and density of growth and on the type of spay equipment used. On tall.dense brash.it is often •Suppression 5 6 USE PRECAUTIONS SPRAYER CLEANUP Do not apply to any body of water.including streams.im- Immediately after spraying,thoroughly remove all traces of NOTICE OF WARRANTY gation water or wells. Do not apply where runoff water 'Escort"from mixing and spray equipment as follows: may now onto agricultural land.as injury to crops may L Drain tank.rinse interior surfaces of tank;then flush tank, Du Pont warrants that this product conforms to the result. (room and buses with clean water for a minimum of chemical description on the label thereof and is reaotn Do not apply"&tort"during periods of intense rainfall w minutes. ably fit for purposes stated an such label only when to water-olmlated soils az off-wget movement may occur. 2.Partially fill the unk with clean water.then add cleaning used in accordance with directions under normal use Do not apply to impervious substrates such as paved or solution*.Complete filling of the tank with clean water. conditions.It is impossible to eliminate all risks inher- highly compacted surfaces our to(town and as off- eat ly associated with the use of this product.Crop tararo Flush solution though nozzles, injury,ineffectiveness.orotherunintendedconu- Do et lot flow spray will occur. allow,,sit for IS minutes with agitation running:Nen quences may result because of such(actors as weather Do not allow spray to s drift onto may nt Occrops m other dram. conditions,presence of other materials,or the manner desirable lana or tmesazin' P p ryry may occur• 3.Repeat Step 2. of use or application,all of which are beyond the Do not use on lawns,golf courses.athletic fields,commer. 4.Repeat Step I. - control of Du Pont.In no case shall Du Pont be liable tial sad operation,or other high-maintenance,fine 5.Nozzles,seller,and strains should then be removed for consequential,special or indirect damages resulting mr(g�omaz' and cleaned se Do not I this product through m puafcle from the use or handling of this product.All such risks appy prod g y type of irrigation 6.To remove tetts afcleming solution.rinse the tank thor- shall be assumed by the buyer.DU PONT MAKES system. ou M t NO WARRANTIES OF MERCHANTABILITY OR In meas where sensitive< pp 8 with clean water and Rush through hour and rolls art grown,make a lieations boom.. FITNESS FOR APARTICULAR PURPOSE NOR to soils whoa surface has been sealed by min. Do not treat 7.Flush boom and hoses with clean water for 5 minutes just ANY OTHER EXPRESS OR IMPLIED powdery dry soil or light sandy oils,when there is little prior to using the sprayer for the first time aver the WARRANTY EXCEPT AS STATED ABOVE- likelihood ofrainfall soon aftermeatment,az wind may -swore'application.the sp. eauu off-target movement DI Registered mscmnk or PBl-Gonvon Coop. - Following an"Escort"application,do not use sprayer for •Use any of the following cleaning olutiom: 121 1 Reginertd trademark of Amerimn CYinamiJ Compan, application m sops.This is extremely important.as low 1.One gallon ammonia(containing 3%active ingredient) 131 Registered trademark of Monson,Company rates of'Siscop"can kill or severely injure most crops per 100 gallons of water. (al Sold by Thomas O.Kilfoil except small grains. 2.Nmra-sol'(carefully read and follow Nutla-sol label 151 Registered trademark of Lovehrd Tank Omner SPRAY PREPARATION directions). 161 Manufactured for Cornell,Chemical Company 3.Loveland Spray Tank Cleaner'(carefully mad and SL-534 9017 1?^l16/96 Fill roes adspray he proper amount oof Escon"th ags ad follow Loveland Spray Tank Cleaner label diettions). the riquired thountofater, of"nuousa Finish adding 4,Tank-Aid-(carefully read and follow Tank-Aid label the iced to keep the of duct i suspeu ion.For on a directions). requited pl keep s..mmi Product c morticians of at For rest go er- activeingreients,ononionicsurfactant specified 80% CAUTION: Dono,usechlorinebleachwithammonia active ingredient should beadded(unl<az specified All traces of liquid(ertiliurconaining ammonia, otherwise)to improve welling and"contact activity.To ammonium nitrate or ammonium sulpham must be rinsed minimize drift•a drift conwl agent may be added at the with water from the mixing and application equipment recommended label rate.'Emort"splay preparations may before adding chlorine beach solution. Failure to do so will degrade in acidic solutions below pH 7 if not used in 24 release a gas with a musty chlorine odor which can cause hours;they sue stable in alkaline solutions.Thoroughly eye.note,throat and lung irritation. Do not clean magitate before using.Tank mixes with other registered equipment in an enclosed uea. ' herbicides should be tested for compatibility before full male mixing. STORAGE AND DISPOSAL Sprayer Agitation:Use mechanical or bypass agitation to Storage:Store product in original conmimr only. Do thoroughly mix the spray solution.After initial mixing,do not contaminate water.other pesticides,fertilizer,food not use excessive agitation when using a surfactant az Foaming problems may moll.To avoid foaming problems, or feed in storage. use antifoam agents. — Product Disposal:Do not contaminate water.food or feed by disposal or cleaning of equipment.Wastes ' resulting from the use of this product may be disposed or on site or at an approved waste disposal facility. Container Disposal:Triple rinse(or equivalent)the container and then offer for recycling or recordi- tioning.or puncture and dispose of in a sanitary land fill,or by incineration.or.if allowed by state and local authorities•by burning.If burned.say out of smoke. NOTICE TO BUYER:Purchase of this material does not confer any rights under patents of countries outside of the United States. 7 01997 E.1.du Pont the Nemours and Company,Agricultural Products,Wilmington,Delaware 19898 8... 027 hspJA—.d"-Loom/.4d✓05 05.0000027.hm1 027 hupJA-11-ponuo./.sdU05 OS.0000027. Transfer interrupted! COMPOSITION/INFORMATION ON INGREDIENTS aQ components material CAS Number \ METSULFURON METHYL 74223-64-6 60 (METHYL 2-1111(4-METHOXY-6-METHYL-1,3,5- TRIAZIN-2-YL)AMINOICAABONYLIAMINO)SULFONYLI- BENZOATE) Information in this format is provided as a service to our INERT INGREDIENTS 40 oust niers and is intended only for their use. Otbers may use it at their own discretion and risk. The MODS format adheres to U.S. standards and regulatory requirements and may not meet regulatory requirementa In other HAZARDS IDENTIFICATION locations. This information is based upon technical information DuPont - believes to be reliable. It is subject to revision as additional knowledge and experience are gained. Please return to this Emergency Overview website for the moat current version. CAUTION! Causes eye irritation. Avoid contact with eyes or clothing. Avoid breathing duet or spray mist. F Potential Health Effect$ "Escort"Herbicide - Based on animal data, eye contact with Hetaulfuron Methyl may ' M0000027 Revised 19-DEC-1997 cause eye irritation with tearing, pain or blurred vision. Based on animal date, repeated dermal contact with Metaulfuron •• Methyl may cause akin irritation with itching, burning, redneea, swelling or rash. CHEMICAL PRODUCT/COMPANY IDENTIFICATION Carcinogenicity Information None of the components present in this material at concentrations equal to or greats[ than 0.14 ars listed by IARC, NSP, OSHA or ACGIX as a carcinogen. Material Identification -Escort' is a registered trademark of DuPont. Corporate NEW Number : D0002103 - FIRST AID MEASURES Company Identification MANUFACTURER/DISTRIBUTOR First Aid DuPont 1007 Market Street INHALATION Wilmington, DE 19998 If inhaled, remove to fresh air. I£ not breathing, give PHONE NUMBERS artificial respiration. If breathing is difficult, give oxygen. Product Information 1-000-441-7515 Call a physician. Transport Emergency CHENI'REC 1-900-424-9300 Medical Emergency 1-900-441-3637 SKIN CONTACT loft Ir 12:17 PM 2of$ 1r 12:1'. 027 hapd v .dupsstosNmrd 05 m0000027Aan1 027 bupJhw,.dupontcomlmW:Ni 01 m00000271 In case of contact, wash akin with plenty of soap and water. Get low areas. medical attention if irritation persists. Follow applicable Federal, State/Provincial and Local lava/ - EYE CONTACT regulations. In case of contact, immediately flush eyes with plenty of water Spill Clean Up for at least 15 minutes. Call a physician. INGESTION Shovel or sweep up. No specific intervention is indicated as compound is not likely to be hazardous by ingestion. Consult a physician if necessary. HANDLING AND STORAGE FIRE FIGHTING MEASURES Handling (Personnel) Avoid breathing vapors or mist. Avoid breathing dust. Avoid contact with eyes, skin, or clothing. Mash thoroughly after Flammable Properties handling. Nash clothing after use. Do not store or eona,mv food, drink or tobacco in areas where they may become contaminated with Not a £ire or explosion hazard. this material. Like most organic powders or Crystals, under severe dusting USERS SHOULD: Nash hands before eating, drinking, chewing conditions, this material may form explosive mixtures in air. gum, using tobacco or using the toilet. Extinguishing Media Handling (Physical Aspects) Nater Spray, Foam, Dry Chemical, CO2. Keep away from beat, $parka and flames. 1 Fire Fighting Instructions t Storage Evacuate personnel to a safe area. Near self-contained breathing Store below 140 C (284 F). Store in a well ventilated place. apparatus. Near full protective e,ui,hent. Use water spray. Keep container tightly closed. Do not store or consume food, Runoff from fire control may be a pollution hazard. drink or tobacco In areas where they may become contaminated with this material. Do not contaminate water, other pesticides, If area is exposed to fire and conditions permit, let fire burn fertiliser, food or feed in storage. itself out. Burning cheadcals may produce by-products more toxic than the original material. If product is on fire, weer self-contained breathing apparatus and full protective equipment. Use water spray. Control runoff. EXPOSURE CONTROLS/PERSONAL PROTECTION ACCIDENTAL RELEASE MEASURES - Engineering Controls -' Use only with adequate ventilation. 1 Safeguards (Personnel) Personal Protective Equipment NOTE: Review FIRE FIGHTING MEASURES and HANDLING (PERSONNEL) Always follow the label instructions when handling this product. sections before proceeding with clean-up. Use appropriate PERSONAL PROTECTIVE EQUIPMENT during clean-up. -Applicator. and other handlers must wear: Emergency Response - Chemical resistant coveralls, waterproof Long-sleeved shirt and long pants. gloves, waterproof boots and face/eye protection. If dusting - Shoes plus socks. occurs, a cartridge respirator or SCM should be used. ' Follow manufacturer's instructions for cleaning/,aintaining PPE. 1 Initial Containment If no such instruction. for washables, use detergent and hot Dike spill. Prevent material from entering sowers, waterway., or water. Keep and wash PPE separately from other laundry. 3ofE Itr 12:17 PM 4of& - Ir 12:17 027 hup/Avww.m;pmt Waku"5 Os mBo000273ftm1 07 h:lpJ/wwwdupontwm/mrds/05 OS m000DD2; PPE required for early entry to treated arena that is permitted Polymerisation will not occur. under the Worker Protection Standard and that involve. Contact with anything that has been treated, such as plants, soil, or water le: Coveralls. Shoes plus nocka. TOXICOLOGICAL.INFORMATION The above PPE is for agricultural one. Non-Agricultural Uses: Non-crop industrial weed control and ♦ Animal Data selective used control in turf (industrial, unimproved only) are not within the scope of the Worker Protection Standard. Metaulfuron Methyl Oral LD50: > 5000 mg/kg in rats Exposure Guidelines - (very low toxicity) Skin LD50: > 2000 mg/kg in rabbits Applicable Exposure Limits(WRA (Slight to moderate toxicity) METNULMETHYL Inhalation LC50, 6 he: > 5.3 mg/L in rata PEL (OSHA) - None Established TLV (ACGItl) None Established (Very low toxicity) - AEL • (DuPonty z 10 mg/m3, 9 i 12 He. TWA Metaulfuron Methyl Sa a mild akin irritant, an eye irritant, but aanlmala. ' • AIL is DUPont•a Acceptable Espoaure Limit. Where governmentally not a akin an.itirer in ' imposed occupational exposure limits which are lower than the ALL Application of a single dose of Metsulfuron Methyl to the skin of are in effect, such limits shall take precedence. rabbits resulted in body weight loss. Repeated applict;ions caused akin irritation but no other changes were observed. Ingestion of a single dose of Metsulfuron Methyl by animals caused PHYSICAL AND CHEMICAL PROPERTIES body weight loss and other nonspecific effects. Repeated dosing produced decreased body weight gain and decreased liver weights when compared to the control group. Long term administration on used body weight los.. Single exposures of animals to Metsulfuron Methyl by inhalation Physical Data caused body weight 1033 and other nonspecific effects. solubility in Water Dleperaible Animal testing indicates that Metsulfuron Methyl does not have Odor z Odorless devele carcinogenic, Form Granular 9 pmente 1, or reproductive effects. Color Off-white Thera 13 a report indicating that Metaulfuron Methyl produced Specific Gravity 1.67 genetic damage 1n a mammalian cell culture cast; however, other Bulk Devity (Loose) :'33.9 lb/cu ft tests with Metaulfuron Methyl in bacterial and mammalian cell cultures and in animals did not produce genetic damage. The weight of evidence suggests that Metaulfuron Methyl does not cause 'genetic damage. - STABILITY AND REACTIVITY ECOLOGICAL INFORMATION Chemical Stability Stable at normal temperatures and storage conditions. Incompatibility with Other Materials h Ecocoxicologlcal Information None reasonably foreseeable. AQUATIC TOXICITY: METSULFURON METHYL Decomposition - 96 hour LC50 - Rainbow trout: > 150 ppm. - 96 hour =50 - Bluegill sunfish: > 150 ppm. - Decomposition will not occur. AVIAN TOXICITY: METSULFURON METHYL Polymerization LD50 - Mallard Duck: > 2510 mg/kg. LC50 - Bobwhite Quail: > 5620 mg/kg sop - 1r12.17 PM 6ofE 1/1jbD 12:1' 027 hOpdA w AUP.A om/mdSM5 OS mD000027AW 027 hupJA a sduPmLQm?u dP05 OS m0000027 DISPOSAL CONSIDERATIONS - OTHER INFORMATION waits Disposal NFPA, NPCA-HHIS Do not contaminate water supply, food or feed by storage oz NEPA Rating Health 1 disposal. - Flaomability 1 Wastes resulting from the use of this product may be disposed of Reactivity 0 On site or at an approved waste disposal facility. Treatment, storage, transportation, and disposal "PCA-HMIs Rating g po poral malt be in Health 1 regulwith applicable Federal, State/Provincial, andlocalFla—ability 1 regulations. s: Reactivity 0 Container Disposal Personal Protection rating to be supplied by neer depen 1,-4 on usa Triple rima (or equivalent) the container: Then offer for conditions. - recycling or reconditioning, or puncture and dispose of in a sanitary landfill, or by incineration, or if allowed by state and local authoritfes, by burning. If burned, stay out of smoke. The data in this Haterial Safety Data Sheet relates only to the specific material designated herein and does not relate to use in combination with any other material or in any process. Responsibility for NSDS: Dupont Agricultural Products TRANSPORTATION INFORMATION Address : Wilmington, DE 19699 Telephone : 300-441-7515 3 Indicates updated section. Shipping Information EM of MSDS DOT/IHO Proper Shipping Nam : NOT REGULATED REGULATORY INFORMATION U.S. Federal Regulations TITLE III HAZARD CLASSIFICATIONS SECTIONS 311, 312 Acute Yes Chronic No Fire No 'Reactivity No - Preasure : No In the United States this product Ss regulated by the US- Environmental Protection Agency under the Federal Insecticide, Fungicide and Rodenticide Act. It 1a a violation of federal law to use this product in a manner inconsistent with its labeling. EPA Reg. No. 352-439. 7ofa lfr 12:17 PM / 3gn IrWo3lrc Oust Extra Herbicide The Department of Agricultural Resources has not developed a Herbicide Fact Sheet for Oust Extra. The activ6 ingredients in Oust Extra are sulfometuron methyl and metsulfuron methy, identical to that found in Oust and Escort respectively. Please consult the Herbicide Fact Sheets for Oust and Escort (attached) or call Mr. Gerald Kennedy at The Department of Agricultural Resources, telephone 617-626-1773. HERBICIDE FACT SHEET ��-� MASSACHUSETTS DEPARTMENT.OF FOOD &AGRICULTURE 9 y�e 100 Cambridge Street, Boston MA 02202 (617) 727-7712 August Schumacher Jr., Commissioner Maes�metb g.vwo_odhrdW ! SULFOMETURON METHYL COMMON TRADE NAME(S): Oust CHEMICAL NAME N-[4,6-dimethylpyrimidin-2-yl) amino-carbonyl] -2-methoxycarbonylbenzenesulfonamide CAS NO 74222-97-2 GENERAL INFORMATION Sulfometuron methyl, the active ingredient in herbicide Oust, is a member of the new group of sulfonylurea herbicides. Sulfometuron Methyl is a broad-spectrum selective weed control agent used in non-crop areas. Oust is applied pre- or post-emergence which provides control against many broad-leaf weeds and grasses through contact and residual activity. (15) ENVIRONMENTAL FATE Mobility The mobility of sulfometuron methyl has been reported in literature and the database available is complete. Sulfometuron methyl is a weak acid (pKa 5.2) and consequently, adsorption coefficients were calculated for various soils at pH values of 5, 6, and 7. In a low organic matter soil (1%) the adsorption coefficients were 2.0, 0.8 and 0.3 at the respective pH values. This study indicates that sulfometuron methyl is more strongly adsorbed to soil as the pH decreased, and as organic matter increases. (15) Soil thin layer chromatography and adsorption coefficients were performed and calculated for four standard soils. K(d) values ranged from 0.71 to 2.85 and Rf values ranged from 0.33 to 0.85 indicated a moderate mobility. In addition, soil column studies using the same four soils indicate a moderate to moderately high mobility pesticide. K(oc) values calculated from the soil K(d) values range from 61 to 122 which is lower than the EPA guideline of 400. (101) In a field mobility study, sulfometuron methyl was applied to soil tubes in five locations (delaware, North Carolina, Oregon, Colorado, and Saskatchewan, Canada) at a rate of 1 Ib. a.i./Acre. There was no report of rainfall at these sites. Each application at a different time making it difficult to compare results. Samples were taken for a minimum of a year and at some for two years, and at 8 cm (3 in) intervals to 32 cm (12 inches). Results indicate that sulfometuron methyl is moderately mobile under most conditions. One surprising fact is that immediately after application, all locations had detectable residues in a layer below the top layer of soil, and in two locations (Colorado and Oregon) in the deepest layer sampled. All locations except Delaware also had detectable residues at the 24-32 cm layer at other times during the study. There are also indications that sulfometuron methyl would leach further than the deepest soil layer which was sampled. (102) Persistence Sulfometuron methyl is degraded by microbial action, photo-decomposition and by hydrolysis at acidic pH's. The photolysis half-life on soil is between 1 to 2 weeks and in distilled water, approximately 160 hours. The hydrolysis half-life at pH 2 and 5 is 100 and 475 hours respectively. At neutral or basic pH's, sulfometuron methyl is stable to hydrolysis. (15, 100, 101) Reports indicate that the overall rate of sulfometuron methyl degradation in soil depends on pH and soil moisture content. Half-lives of one week were reported under laboratory conditions, but field studies at neutral pH revealed greater persistence. Increased soil moisture content resulted in increased degradation rates, but only approximately 10%. (15, 101) The soil half-life is reported as four weeks with longer times in colder conditions. A review of available studies, however reveals that the shortest half-life was six weeks in Delaware. In the same study the half-life ranged from six weeks to one year in Oregon. (15, 102) The reported half-life of four weeks is relatively short and would not be cause for concern. However, it seems evident that in most circumstances it may be significantly longer. In all cases reported in this study, the half-life was six weeks or longer and a more realistic estimate may be closer to two months. Another point discussed in the literature is the lack of any significant degradation during the cold periods of the year. Applications in the late fall could lead to longer half-lives and thereby more potential for increased leaching. The field study discusses the faster degradation rates of sulfometuron methyl in a=the east as possibly attributable to the more acidic and moister soils in the east. This is certainly true and may in fact have contributed to shorter half-lives, but a point which is not discussed was the timing of the applications. The two western sites were treated in early to mid-July, whereas the western sites were treated in the fall. Saskatchewan was treated in late July, but the climate at that location is cooler and becomes much colder. TOXICITY REVIEW Acute (Mammalian) SULFOMETURON METHYL FACT SHEET Five animals per sex per group were gavaged with sulfometuron methyl suspended in corn oil at a dosage of 5,000 mg/kg.. Gross pathological examination revealed slight weight increase in the lungs that were pale red with grey foci in males and similar lung effects in one female. In addition, four females had a pink thymus and one had a slight liver weight. The oral LD50 in male and female ChR-CD rats was determined to be greater than 5,000 mg/kg. (110) The inhalation LC50 was tested in groups of five male and five female Crl:CD rats. Rats were exposed to control air or test concentrations of either 6.4 or 11 mg/L. There were no clinical or pathological differences between controls or test groups. The inhalation LC50 was greater than 5.0 mg/L (111) while sulfometuron methyl was tested at 6.4 and 11 mg/L. The EPA cutoff for LC50 concentration is 5 mg/L. Acute skin absorption LD50 tests were performed on five male and five female New Zealand white rabbits. Doses of 2,000 mg/kg of pesticide were applied to abraded skin on the back of the rabbit. Clinical signs in males were sporadic weight loss, slight erythema 1 to 2 days after treatment and diarrhea at 11 days. Gross pathological examination showed no changes due to the test material. The dermal LD50 in rabbits was greater than 2,000 mg/kg. (112) In a separate acute dermal LD50 test, four groups of five adult male and one group of five adult female which New Zealand rabbits were used. Groups of males were dosed at the following levels: 1,500 mg/kg, 2,000 mg/kg, and 8,000 mg/kg and the females were dosed at 2,000 mg/kg. Clinical signs in all the groups of males were moderate to mild redness and sporadic weight loss. The animals in the two highest dose experienced mild swelling, the 2,000 mg/kg group showed moderate swelling while the 1,500 mg/kg group had slight swelling. Clinical signs in the females were severe to mild redness, severe to slight swelling and sporadic weight loss. There were no compound related pathological observations. There was one death in the male 2,000 kg/mg group, but it was not believed to be related to the compound. The LD50 for the acute skin absorption in rabbits was greater than 2,000 mg/kg. (116) Eye irritation studies were performed by placing 10 mg of solid test material in the conjunctival ac of each of two albino rabbits. There were no corneal or iritic effect. However, there was redness (1 hour to 1 day; not washed eyes and mild for 1 hour unwashed eyes); swelling (1 to 4 hours unwashed eyes) and no discharge was observed. Both washed and unwashed eyes were normal within 1 to 2 days. (113) In guinea pigs, both primary skin irritation and sensitization tests were run. Ten animals per group were exposed to 0.05 ml of either a 50% or a 5% suspension of sulfometuron methyl. The 50% suspension showed mild to no skin irritation response in 24 hours and no irritation at 48 hours. The 5% suspension reproduced no skin irritation. There was no sensitization response. (114) AUGUST 1991 3 SULFOMETURON METHYL FACT SHEET The oral LD50 test was conducted with the formulation using young male and female adult Crl:CD rats, five rats per group. 5,000 mg/kg was administered by gavage in a 25% suspension in corn oil. The only clinical finding was alopecia in males. Gross pathological examination showed in both males and females slightly heavy lungs that were pale to pale red with red to dark red foci and white mottling in 1 to 3 animals. The LD50 is greater than 5,000 mg/kg. Additionally in a range finding study, no mortalities were seen in doses from up to 7,500 mg/kg. (115) Nine male albino rabbits were tested for eye irritation studies. The right eyes were treated with 0.1 ml (61.8 mg) of test material. The left eyes served as untreated controls. Results indicated a transient localized area of slight corneal cloudiness in 2 of the 6 unwashed eyes. The eyes returned to normal in 2 to 3 days. Two of the three eyes treated and washed showed a transient localized area slight corneal cloudiness and mild conjunctivitis with no iritic effects. The washed eyes returned to normal within 3 to 4 days. This compound was considered a slight to mild irritant. (117) Skin irritation tests were conducted on six male albino rabbits. Doses of 0.5 g of solid pesticide (moistened with saline) were applied to two intact and two abraded skin areas on each rabbit. Each rabbit serves as its own control; treated areas were compared to adjacent untreated areas. Observations and scoring were done by the method of Draize (118) and at 24 and 72 hours after exposure. The compound was not found to be a primary irritant on either intact or abraded skin of rabbits. (119) Primary skin irritation tests were performed on ten guinea pigs. The procedure was the same as used in testing the technical sulfometuron methyl. Doses of 0.05 ml of a 50% suspension of the pesticide in dimethyl phthalate was used. The 50% suspension caused mild to no irritation in five of the animals. No irritation was caused by the 5% suspension. No sensitization response was observed. (120) Subchronic and Chronic Studies (Mammalian) Male and female CD-1 mice were fed diets to which had been added 0, 100, 1,000, or 7,500 ppm (0, 13.3, 133, or 997 mg/kg) (a) sulfometuron methyl for 90 days. Hematological evaluations were conducted on all mice (tail cut bleeding at approximately 1, 2 and 3 months after study initiation. All mice were sacrificed and necropsied at 90 days. Organs were weighed and examined histologically. Male mice fed the diet containing 7,500 ppm pesticide showed reduced mean body weights and weight gains. Growth of the 100 and 1,000 ppm groups of males and all treated females was the same as that in the control group. No mortalities occurred. (121) Hemolytic effects were seen as a result of dietary exposure to sulfometuron methyl in all groups. Significant increases in leukocyte count were found in the 7,500 ppm (997 mg/kg) males. There AUGUST 1991 4 SULFOMETURON METHYL FACT SHEET were statistically significant changes in other blood parameters that were not does related. Mean absolute and relative liver weights were elevated in all male treatment groups. Histological examination revealed bile stasis in five of ten males in the 7,500 ppm group. In the females, a slight increase in relative liver weight and increased hepatocellular cytoplasmic granularity was observed. Decreases in both mean and relative thymus weights were observed in all treated male groups. Thymic cortical atrophy occurred in three males in the 7,500 ppm group and one male in the 100 ppm group. Because of low frequency of occurrence 7,500 and 100 ppm and absence in the 1,000 ppm group, the thymic cortical atrophy is not considered to be related to the decreased thymus wrights. Based on the observed hemolytic effect, there was no NOEL from this study. In a second mouse study, five groups of 80 males and 80 female Crl:CD-1(1 CR)BR mice were fed diets containing one of the following concentrations of sulfometuron methyl: 0. 5, 20, 100, or 1,000 ppm (0, 0.66, 2.66, 13.3, 133 mg/kg) for 18 months. Food consumption was monitored throughout the study, mice were weighted and hematological evaluations were performed at regular intervals. At 18 months, mice were sacrificed and necropsied. Mean body weights and mean body weight gains in all treatment groups except for the 1,000 ppm female group were comparable to control groups. Sporadic changes in weight gain were observed in that group. (a) In these discussions the assumptions made for conversion of ppm (diet) to mg/kg/D were: SPECIES BODYWEIGHT ft) INTAKE ((kq) Rat 0.35 0.020 Mouse 0.03 0.004 Dog 10 0.4 (133) When data was presented as ppm the does was estimated in mg/kg and is presented in parenthesis. Mild anemia was observed in the female 1,000 ppm group as evidenced by statistically significant decreases in erythrocyte count, hemoglobin concentration and hematocrit. There was also a significant increase in mean corpuscular volume and platelet count. While the hematological results appear to differ from those in the 90 day mouse study,the data indicate that there were several statistically significant changes in some blood parameters at the three month (90 day) sampling time which were not apparent at other sampling times. However, although reticulocyte smears were made, they were not evaluated and it cannot be ascertained that a response to a AUGUST 1991 5 SULFOMETURON METHYL FACT SHEET hemolytic effect actually occurred. If it did, a NOEL in this strain of mice for a hemolytic effect at 90 days in the 18 month study would be 5 ppm. There was a non-dose related but, statistically significant increase in the incidence of amyloidosis in the female 1,000 ppm groups, but no specific target organ was identified. The overall NOEL for dietary intake of sulfometuron methyl for male and female mice was 1,000 ppm (133 mg/kg) and 100 ppm (13.3 mg/kg) respectively under the conditions of this study based on body weight, body weight gain, clinical pathology and pathological findings. (124) Groups of 16 male and 16 female CD rats were fed diets containing 0, 100, 1,000, 5,000 ppm (0, 5.7 57, 285 mg/kg) sulfometuron methyl. At 1, 2 and 3 months after the study initiation, hematological, urological and clinical chemistry evaluations were performed. At the end of the study, ten rats from each group were sacrificed and evaluated pathologically. There were no differences between treatments and controls in body weight, weight gain, food consumption and food efficiency. There were no mortalities. The only clinical sign observed was alopecia in three males in the 100 ppm group. The male 5,000 ppm treatment group showed slightly elevated mean leukocyte counts, increased mean relative number of lymphocytes and decreased mean relative number of neutrophils. Due to the effects of white blood cells in male 5,000 ppm group, the NOEL dietary concentration i this study was 1,000 ppm (56 mg/kg/D). (122) Four groups of five male and five female New Zealand white rabbits were dermally exposed to either 1, 125, 500, or 2,000 mg/kg, six hours per day for 21 consecutive days. After the exposure period, three male and three female rabbits per group were sacrificed for pathological evaluation. The remaining two males and two females from each group were sacrificed and evaluated pathologically following a two week recovery period. Clinical signs observed in rabbits from all test groups including controls were sporadic weight loss and diarrhea. Histopathological and clinical pathological examination showed no compound-related effects. One rabbit did after the eighth dose from causes not related to the test substance. (123) Groups of 80 male and 80 female Crl:CD (SD) BR rates were fed diets containing 0, 50, 500 or 5,000 ppm (0, .8, 28.5, or 285 mg/kg) sulfometuron methyl for approximately two years. Hematological, clinical chemistry and urological testing was conducted a 3, 6, 9, 12, 18, and 24 months. After 12 months, ten male and ten female rats per group were randomly selected, sacrificed and pathologically examined. At 24 months, all surviving rats were sacrificed, necropsied, and examined pathologically. In the female 5,000 ppm group, food consumption throughout the study was slightly depressed and overall mean weight gain during the first year and mean body weights during the second year were significantly depressed. There were no abnormalities in appearance or behavior observed during the study. Decreased erythrocyte count and hematocrit in the male 500 and 5,000 ppm groups were AUGUST 1991 6 SULFOMETURON METHYL FACT SHEET observed at the,24 month clinical evaluation suggesting a minimal dose-related hemolytic effect. There were no other compound related hematological, clinical chemistry or urological abnormalities observed. Mean absolute brain weights were significantly lower in the male 5,000 ppm group at both one and two sacrifice times. However, no abnormal gross or histological observation were noted. Mean relative and absolute thymus weight of the 500 and 5,000 ppm males was decreased compared to controls at terminal sacrifice. Man testes weights of rats in the 5600 and 5,000 ppm groups were less than controls. Histological examinations revealed dose-dependent increases in the incidence of bile duct hyperplasia and fibrosis in the female 500 and 5,000 ppm groups at the two year sacrifice. Severity of the lesions were minimal to mild, suggesting a slightly toxic effect of sulfometuron methyl on the livers of these female rats. The NOEL in this strain of rat under these study conditions was 50 ppm (2.8 mg/kg/D). (125) Groups of six male and six female dogs (aged 4 to 5 months) were fed diets containing 1, 200, 1,000, or 5,000 ppm (0, 8, 40, 200 mg/kg) of sulfometuron methyl. Hematological, clinical, chemistry, and urological testing was performed at one and two months prior to and at one, three, six, nine, and twelve months after initiation of the study. At 12 months, the dogs were sacrificed and examined histopathologically. There were no differences between treatments and controls in mean body weight, weight gain, food consumption and food efficiency (kg body weight gained/kg food consumed). There were no abnormalities observed in either appearance or behavior and no deaths occurred during the course of the study. A mild hemolytic anemia was diagnosed in the 5,000 ppm males and the 1,000 and 5,000 ppm females. Statistically significant dose-related decreases in erythrocyte counts, hematocrit and hemoglobin were observed. In the female 1,000 and 5,000 ppm groups, elevated mean corpuscular hemoglobin occurred and increased hemosiderin deposition in the spleens of the 5,000 ppm females was observed. Several statistically significant changes in blood chemistry indices occurred in the 1,000 and 5,000 ppm groups. An increase in serum alkaline phosphatase activity was observed in both the male and female 5,000 ppm groups. The female 5,000 ppm group showed an increase in serum cholesterol levels. Serum albumin levels decreased in the male 1,000 and 5,000 ppm group. These changes were not considered biologically significant due to the relative magnitude of the changes, the absence of alterations in other clinical indices and the absence of compound dependent histomorphological abnormalities. All histological changes were unremarkable. These effects occurred with similar frequencies in treatments and controls and were not considered to be compound related. AUGUST 1991 7 SULFOMETURON METHYL FACT SHEET The NOEL for 'dogs based on the hemolytic effects was 200 ppm (8 mg/kg/D) in this study. (126) Oncogenicity Studies Oncogenic endpoints were evaluated in the chronic mouse and rat studies for sulfometuron methyl. Crl: CD-1 (1 CR) BR mice received 0, 5, 20, 100, or 1,000 ppm sulfometuron in the diet of 18 months. There were no compound related increases in tumor incidence (124). CRL:CD (SD) BR rats received 0, 50, 500, or 5,000 ppm sulfometuron in the diet for two years. There was no increase in frequency of occurrence of tumors in these rats (125). Sulfometuron methyl is not carcinogenic in rats and mice under these conditions. Mutagenicity Testing The Ames Salmonella/microsome assay tested the ability of Sulfometuron methyl to revert four strains of Salmonella typhimurium from histidine dependence to histidine independence. The assay was performed both with and without a rat liver homogenate (S-9) activation system. The test substance was found not to be mutagenic for these strains of bacteria under the test conditions at doses from 2.5 to 1,000 mg/plate. (129) Frequency of chromosome aberrations was tested in CHO cells both with and without metabolic activation (S-9). The doses tested ranged from 300 ug/ml to 10 ng/ml in a half log series. No increase in chromosome aberrations was observed in culture exposed under the test conditions to these concentrations of the test material. (130) The CHO cell line was used to test mutations in the gene coding for the enzyme hypoxanthine- guanine phosphoribosyl transferase (HGPRT) both in the presence and absence of an activation (S-9) system. Concentration of the test material ranged from 0 to .1 mM. No mutagenic activity was detected. (131) The ability of sulfometuron methyl to induce unscheduled DNA (UDS) synthesis in freshly isolated rat hepatocytes was tested. Concentrations of test material ranged for 1 X 10 -5 to 1.0 mM in half log increments. Under these test conditions, no induction of UDS was detected. (132) Developmental Studies Groups of 17 female artificially inseminated rabbits wee gavaged with test material on days 6 to 18 of gestation. Dosage levels were 0, 30, 100, and 300 mg/kg suspended in 0.5% methylcellulose in water. Animals were sacrificed on day 29 of gestation and fetuses wee removed by cesarean section. No treatment-related effects were observed in the maternal clinical observations or gross pathology. There were no statistically significant differences AUGUST 1991 8 SULFOMETURON METHYL FACT SHEET between control and treatment groups in any of the other parameters measured (maternal body weight changes, clinical observations, survival, gross pathology pregnancy rates, numbers and percentages of corpora lutea, implantations, resorptions in each maternal animal, fetal sex, viability and development). Under the conditions of this study, sulfometuron methyl was not considered to be teratogenic in New Zealand white rabbits. (127) A teratology study was conducted using female Crl:CD (SR) BR rats which were fed a diet containing sulfometuron methyl. Concentrations of 0, 50, 1,000, and 5,000 ppm were used. Thirty-five rats were used as controls, 25 rats were assigned to the 50 and 1,000 ppm group and 15 rats were assigned to the 5,000 ppm group. Rats were fed the test diet on days 6 to 15 of gestation and sacrificed on day 21 of gestation for gross and histological examination. (128) Rats on the highest dose level gained significantly less weight and ate significantly less feed than controls. The fetuses of this exposure group weighted significantly less than those of the control dams. No other adverse effects were noted in the lower exposure groups. No teratogenicity was demonstrated in this study. The minimum effect level of maternal toxicity and embryofetal toxicity was 5,000 ppm (286 mg/kg) and the NOEL under these study conditions was 1,000 ppm (57 mg/kg). (128) Reproductive studies were performed in conjunction with the 90 day feeding study in rats and the two year feeding study in rats. In the 90 day feeding study (122), six male and six female rats which had been fed diets obtaining 0, 100, 1,000, and 5,000 ppm of sulfometuron methyl (for 90 days) were mated and delivered litters. No adverse effects were observed as indicated by fertility, gestation, viability and lactation indies. In addition, there wee no differences between treatment and controls in the mean body weights and survival of weaning pups. In the two year feeding study (125), 20 rats per group were used in a two generation, four litter reproduction study, initiated 90 days after the start of the long-term feeding study. Fo rats were mated. Females were allowed to give birth and Fla pups wee followed until weaning (21 days) at which time they were sacrificed. Fo females wee again mated, but to different Fo males. F1 b pups were delivered and observed. At weaning, 20 males and 20 females were selected from each dietary level (0, 50, 500, and 5,000 ppm) and continued on the treatment for 90 days. F1 b rats were bred twice within their respective group, producing F2a and F2b litters. Ten males and ten females from the F2b litters were sacrificed and examined histologically. (125) During the 90 day feeding period for Fib rats, body weight and diet consumption were decreased in the female 5,000 ppm group. The number of pus born and the number of pups born alive to the 5,000 ppm groups was consistently lower in both the Fl and F2 generations and was statistically significant for F2b litters. Decreased pup counts may reflect the general health status of the mother as evidenced by decreased body weight and diet consumption of the Fib 5,000 ppm group. No gross or histopathological changes or effects on organ weights were observed in the weaned F2b rats. The NOEL established, based on this sub-study was AUGUST 1991 g SULFOMETURON METHYL FACT SHEET 500 ppm (28 mg/kg). (125) Avian Toxicity Sulfometuron methyl has been tested in the bobwhite qual and the mallard duck. The 8 day dietary LC50's were greater than 5,620 and 5,000 ppm respectively. The acute oral LD50 in the mallard duck was greater than 5,000 mg/kg. (101) Invertebrate Toxicity The aquatic invertebrate, Daphnia magna was tested ant he 48 hour LC50 was greater than 12.5 ppm sulfometuron methyl. (15) Aquatic Toxicity Species tested on the aquatic toxicity studies include bluegill sunfish (96 hour) and rainbow trout (96 hour). In both cases the LC50 was greater than 12.5 ppm. A life stage study was done using the fathead minnow. There wee no effects observed on embryo hatch, larval survival or growth at concentrations of 1.2 mg/L or less. (15) SUMMARY Sulfometuron methyl is a material both moderately mobile and moderately persistent would be appropriate for use in sensitive areas. A closer look at the material however, reveals that the Oust is applied at the average rate of five ounces of product (3.75 oz a.i.)/acre or 106 grams per acre. These studies were conducted with applications of 1 Ib a.i./acre. The lower application rates both minimize the persistence of sulfometuron methyl in soil and thereby diminish the amount of material which is available to leach through the soil. Therefore, sulfometuron may be used if the application rates are kept sufficiently low. This is because the soil organic material and soil microorganisms are able to absorb and degrade lower rates of pesticides. The oral LD50 in rats for sulfometuron methyl is greater than 5,000 mg/kg and the dermal LD50 is greater than 2,000 mg/kg in rabbits. The sub-chronic and chronic NOELS are 50 ppm (2.8 mg/kg/D) in rates; 200 ppm (i mg/kg/D) in dogs; and 5 ppm (0.66 mg/kg/D) at 90 days for the reversible hemolytic effect and 100 ppm (13.3 mg/kg/D) at two years in the mouse. This makes the mouse at 90 days the most sensitive species with a transient hemolytic effect, to sulfometuron methyl exposure. AUGUST 1991 10 SULFOMETURON METHYL FACT SHEET REFERENCES 15. Pesticide Background Statements August 1984 USDA Forest Service A g r i c u l t u r a l Handbook # 633, Vol. 1. 100. DuPont Technical Data Sheet for Sulfometuron methyl. 101. Properties of Sulfometuron Methyl Affecting Its Environmental Fate: Aqueous Hydrolysis and Photolysis, Mobility and Adsorption on Soils and Bioaccumulation Potential. 1985: J. Agr. Food Chemistry; 33: 590. 102. Environmental Fate of Sulfometuron Methyl in Aerobic Soils. J. Agr. Food Chemistry, 1985, 33: 596. 110. 1980. Oral LD50 Test in Rats: Haskell Laboratory Report No. 870-80 E.I. duPont de Nemours and Company, Inc. Haskell Laboratory for Toxicology and Industrial Medicine, Newark, DE. 111. 1982. Inhalation Median Lethal Concentration (LD50) of INT-5648-18 by EPA Protocol: Haskell Laboratory Report No. 657-82. E.I. duPont de Nemours and Company, Inc. Haskell Laboratory for Toxicology and Industrial Medicine, Newark, DE. 112. 1981. Acute Skin Absorption LD50 Test on Rabbits: Haskell Laboratory Report No. 1978-80. E.I. duPont de Nemours and Company, Inc. Haskell Laboratory for Toxicology and Industrial Medicine, Newark, DE. 113. 1979. Eye Irritation Test in Rabbits: Haskell Laboratory Report No. 230-79. ELdFort de Nemours and Company, Inc. Haskell Laboratory for Toxicology and Industrial Medicine Newark, DE. 114. 1979. Primary Skin Irritation Test and Sensitization Tests on Guinea Pigs: Haskell Laboratory Report No. 232-79. E.I. duPont de Nemours and Company, Inc. Haskell Laboratory for Toxicology and Industrial Medicine, Newark, DE. 115. 1980. Oral LD50 in Rats: Haskell Laboratory Report No. 965-80. E.I. duPont d e Nemours and Company, Inc. Haskell Laboratory for Toxicology and Industrial Medicine, Newark, DE. 116. 1980. Acute Skin Absorption LD50 Test on Rabbits: Haskell Laboratory Report No. 1068-80. E.I. duPont de Nemours and AUGUST 1991 11 SULFOMETURON METHYL FACT SHEET Compahy, Inc. Haskell Laboratory for Toxicology and Industrial Medicine, Newark, DE. 117. 1980. Eye Irritation in Rabbits: Haskell Laboratory Report No. 963-80. E.I. duPont de. Nemours and Company, Inc. Haskell Laboratory for Toxicology and Industrial Medicine, Newark, DE. 118. Draize, J.H. and Kelley, E.A. 1959. The Urinary Excretion of Boric Acid Preparations Following Oral Administration and Topical Applications to Intact and Damaged Skin of Rabbits. Toxicology & Aoolied Pharmacology. 1(3): 267-276. 119. 1980. Skin Irritation Test on Rabbits for EPA Pesticide Registration. (HLR 964-80) E.I. duPont de Nemours and Company, Inc. Haskell Laboratory for Toxicology and Industrial Medicine, Newark, DE. 120. 1980. Primary Skin Irritation and Sensitization Test on Guinea Pigs: (HLR 966-80) Haskell Laboratory Report No. 966-80. E.I. duPont de Nemours and Company, Inc. Haskell Laboratory for Toxicology and Industrial Medicine, Newark, DE. 121. 1981. Ninety-Day Feeding Study with Benzoic Acid, 2-[[(4, 6-Dimethyl-2-pyrimidinyl)- aminocarbonyl], Methyl Ester, INT-5648, in Mice: Haskell Laboratory Report No. 500-81. E.I. duPont de Nemours and Company, Inc. Haskell Laboratory for Toxicology and Industrial Medicine, Newark, DE. 122. 1980. Ninety-Day Feeding and One Generation Reproduction Study with Benzoic Acid, 2-[[4, 6-Dimethyl-2-pyrimidinyl)-aminocarbonyl] aminosulfonyl], Methyl Ester, INT-5648, in Rats: Haskell Laboratory Report No. 928-80. E.I. duPont de Nemours and Company, Inc. Haskell Laboratory for Toxicology and Industrial Medicine, Newark, DE. 123. 1982. Subacute Dermal Toxicity Study (21 days) in Rabbits: Haskell Laboratory Report No. 792-82. E.I. duPont de Nemours and Company, Inc. Haskell Laboratory of Toxicology and Industrial Medicine, Newark, DE. 124. Tobia, A.J. 1987. Oncogenicity Study with INT-5648 Long-Term Feeding Study in Mice: Haskell Laboratory Report No. 355-87. E.I. duPont de Nemours and Company, Inc. Haskell Laboratory for Toxicology and Industrial Medicine, Newark, DE. AUGUST 1991 12 SULFOMETURON METHYL FACT SHEET 125. 1984. Long-Term Feeding Study in Rats with Benzoic Acid, 2-[[[[(4, 6-dimethyl-2- pyrimidinyl) amino]carbonyl]sulfonyl]-,methyl ester (INT-5648): Haskell Laboratory Report No. 367-84. E.I., duPont de Nemours and Company, Inc. Haskell Laboratory for Toxicology and Industrial Medicine, Newark, DE. 126. O'Neal, F.O. 1983. One-Year Feeding Study in Dogs with Benzoic Acid, 2-[[[[(4, 6-dimethyl-2-pyrimidinyl) amino]carbonyl]-amino]sulfonyl]-,methyl ester (INT-5648 Haskell Laboratory Report No. 482-82. E.I. duPont de Nemours and Company, Inc. Haskell Laboratory for Toxicology and Industrial Medicine, Newark, DE. 127. 1981. Teratology Study in Rabbits, HLO-331-81. Hazleton Laboratories America, Inc. 9200 Leesburg Turnpike, Vienna, VA 22180. Submitted to: E.I. duPont de Nemours and Company, Inc. Haskell Laboratory for Toxicology and Industrial Medicine, Newark, DE. 128. 1981. Benzoic Acid 2-[[[[(4, 6-dimethyl-2-pyrimidinyl) amino]carbonyl]amino]sulfonyl]- methyl ester (INT-5648):Teratogencity Study by Diet in the Rat: Haskell Laboratory Report N] 316-81. E.I. duPont de Nemours and Company, Inc. Haskell Laboratory for Toxicology and Industrial Medicine, Newark, DE. 129. 1979. Mutagenic Activity in the Salmonella/Microsome Assay: Haskell Laboratory Report No. 271-79. E.I. duPont de Nemours and Company, Inc. Haskell Laboratory for Toxicology and Industrial Medicine, Newark, DE. 130. 1982. Mutagenicity Evaluation of H#13,647-03 in an In Vitro Cytogenic Assay Measuring Chromosome Aberration Frequencies in Chinese Hamster Ovary (CHO) Cells, HLO-792-81. Litton Bionetics, Inc., 5516 Nidmison Lane, Kensington, MD 290895. Submitted to: E.I. duPont de Nemours and Company, Inc. Haskell Laboratory for Toxicology and Industria Medicine, Newark, DE. 131. 1981. Chinese Hamster Ovary Cell Assay for Mutagenicity: Haskell Laboratory Report No. 1074-80. E.I. duPont de Nemours and Company, Inc. Haskell Laboratory for Toxicology and Industrial Medicine, Newark, DE. 132. 1982. Unscheduled DNA Synthesis/Rat Hepatocytes in Vitro: Haskell Laboratory Report No. 769-82. E.I. duPont de Nemours and Company, Inc. Haskell Laboratory for Toxicology and Industrial Medicine, Newark, DE. 133. Chemical Health Effects Assessment Methodology and Method to Derive Allowable Ambient Levels (1985) Massachusetts Department of Environmental Quality and Engineering. Draft. AUGUST 1991 13 APPENDIX B MAPS Maps provided with this Yearly Operational Plan remain in effect for the life of the Vegetation Management Plan (2005-2009)unless modified. Please retain them in your files. New maps will be provided only as they are updated or modified. KEY 4 SPRAY AREAS AS DELINEATED ON TRACK CHARTS • Upland areas and/or lengths of track without proximate sensitive areas. Sensitive areas that are readily identifiable in the field are not included. This is a "no-spray" area. Herbicide spraying is prohibited. Includes lengths of track within 400 feet of a public water supply wellhead, 100 feet from a public surface water supply„ a 50 foot radius around a private well, and 10 feet from the edge of standing or flowing water or wetlands . This is a "limited-spray" area. Spraying is restricted to one annual application of an herbicide through low-pressure foliar techniques. Includes lengths of track"between 10 and 100 feet from the edge of standing or flowing water or wetlands. This is a "limited" spray area. Spraying is restricted to one application every other year of an herbicide through low-pressure foliar techniques. Includes lengths of track within a 0. 5 mile radius around a public water supply ,wellhead, between 100 - 400 feet from the edge. of. a public surface water supply, and between 50 an8 100 foot radius around a private well . WELL SYMBOLS AS INDICATED ON THE USGS MAPS ®. Public Well ® Private Well PWS Public Water Supply PRA Primary Recharge Area (Zone II) UV;III;I'HI l( V 4lA 1�<<y�� ""`�, /.,, Il n I \ ••/• n / 1 i (� i'.S u r ist 'FT 1 r'� ' �,J\�M�t) I )`� � \] �i '`' [) .C., ��N' � j,F §,(✓_.�, tj3 'r � / / �\� L I "-�� (�r� �` yqgg � - �o ��'i`�\�'�~ � �,� �1�.^. 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RECEIPT (Domestic Mail Only, 41AL LOU -0 N 1. fM1U M «` 'be"Med Free C3 Posbnark !Retum Rede%Fee a p—� C3 (EFW rsemem Requl Her$ -j u.r Fee r=1 (Erdwaement Rpulrre�d)) T nU s � fu Total Posteg6Fewe, j a+e +en4 N p Sent To p TEC— �^--- --`-------5` ^-----r----------------------- :r, Certified Mail Provides: zest w-zo-eeszat ■ A mailing receipt (--ea)Zoo,eunr'OOee ouoj Sd ■ A unique identifier for your mailplece • A record of delivery kept by the Postal Service for two years Important Reminders: ■ Certified Mall may ONLY be combined with First-Class Mail®or Priority Mails. • Certified Mall is not available for any class of international mail. ■ NO INSURANCE COVERAGE IS PROVIDED with Certified Mail. For valuables,please consider Insured or Registered Mail. • For an additional fee,a Return Receippt m%be requested to provide proof of delivery.To obtain Return Receipt seMce,p ease complete and attach a Return Receipt(PS Form 3811)to the article and add applicable postage to cover the fee.Endorse mailpiece"Return Receipt Requested".To receive a fee waiver for a duplicate return receipt,a USPS®postmark on your Certified Mail receipt is required. • For an additional fee, delivery may be restricted to the addressee or addressee's authorized agent.Advise the clerk or mark the mailpiece with the endorsement"Restricted Delivery". ■ If a postmark on the Certified Mall receipt is desired,please present the arti- cle at the post office for postmarking. If a postmark on the Certified Mail receipt is not needed,detach and affix label with postage and mail. IMPORTANT: Save this receipt andpresent it when making an Inquiry. Internet access to delivery information is not available on mail addressed to APOs and FPOs. l iiSENDER: COMPLETE THIS SECTION COMPLETE THIS SECTION . ■ Complete items 1,2,and 3.Also complete A. Signaturq�X1..11 E C E I V E D item 4 if Restricted Delivery is desired. 0 Agdres ent ■ Print your name and address on the reverse X 0 Adente so that we can return the card to you. B. Receiv id by(Printed Name to of Del iv ry ■ Attach this card to the back of the mailpiece, or on the front if space permits. D. Is deliv ry adVffiiff4e,5fnM 11 10 Yes 1. Article Addressed to: If YES,enter delivery address below: 0 No DEP Department of Environmental Protection ONE MAILROOM 4th FL NERO -Wetlands & Waterways BOST 5th Floor, One Winter Street 3. Service Type Boston,MA 02108 l(Certified Mail 0 Express Mail 0 Registered 0 Return Receipt for Merchandise 0 Insured Mail 0 C.O.D. Milli RIM 4. Restricted Delivery?(Extra Fee) ❑Yes 2. Article Number 70.02: 2410 0003 . .2794 5927 . (transfer from service labeq J PS Form 3811, February 2004 Domestic Return Receipt 102595-02-M-1540 UNITED STATES POSTAL SERVICE Cc) • Sender: Please print yeut'ma�je/adclress, 6;6�zlm lot b bux c) uir q\ First-Class Mail CD r,E ,Pl C) Salem Conservation Commission kl- 120 Washington Street,3rd Fl LIJ Sal0m,MA 01970 LUz::3 ccz C) i ij! SENDER: DELIVERY ■ Complete items 1,2,and 3.Also complete A. Signature item 4 if Restricted Delivery is desired. X 0 Agent 1111Print your name and address on the reverse El Addressee so that we can return the card t0 you. B. Received by(Printed Name) Date of Delivery ■ Attach this card to the back of the mailpiece, or on the front if space permits. � D. Is delivery address different from item 1? 0 Yes 1. Article Addressed to: If YES,enter delivery address below: 0 No I I way%e W �. [�6 S`J t/ f�• 3. Service Type 77 / a,�1� /J C' 'a Certified Mail ❑Express Mail 44 M♦ -Ad //C.-• V 7�� 0 Registered ❑Return Receipt for Merchandise �!� 0 Insured Mail 0 C.O.D. 111141W AM 4. Restricted Delivery?(Extra Fee) 0 yes 2. Article Number7002 2410 0003 2794 5934 (Transfer from service IabeQ PS Form 3811, Februpry 2004 Domestic Return Receipt 102595-02-M-1540 UNITED STATES POSTAL SERVICE First-Class Mail Postage&Fees Paid USPS Permit No.G-10 • Sender: Please print your name, address, and ZIP+4 in this box I I 0 F W w I Salem Conservation Commission o = o 120 Washington Street,W R w Salem,MA 01970 o 0 O U Massachusetts Department of Environmental Protection Bureau of Resource Protection - Wetlands WPA Form 2 — Determination of Applicability Massachusetts Wetlands Protection Act M.G.L. c. 131, §40 A. General Information Important: When filling out From: forms on the Salem computer, use Conservation Commission only the tab key to move To: Applicant Property Owner(if different from applicant): your cursor- do not use the TEC Associates Massachusetts Bay Communter Railraod return key. Name Name 46 Sawyer Street 32 Cobble Hill Road VQ Mailing Address Mailing Address S. Portland ME 04106 Somerville S 02143 City/Town State Zip Code City/rown State Zip Code 1. Title and Date(or Revised Date if applicable)of Final Plans and Other Documents: Salem Track Chart Title Date Title Date Title Date 2. Date Request Filed: B. Determination Pursuant to the authority of M.G.L. c. 131, §40, the Conservation Commission considered your Request for Determination of Applicability,with its supporting documentation, and made the following Determination. Project Description (if applicable): Vegetation control along the Massachusetts Ba Commuter Railroad Right-of-Way,will conform to 9 9 Y 9 Y. the guidelines set forth in the Massachusetts Rights-of-Way Management Regulations (333 CMR 11.00) and the preface to the Wetlands Protection Regulations (333 CMR 10.00)relative to the rights-of-way management. Project Location: Massachusetts BAy Commuter Railroad Right-of S21P62 Way Cityfrown Assessors Map/Plat Number Parcel/Lot Number wpaform2.dm•rev.7MM4 Page 1 of 5 Massachusetts Department of Environmental Protection Bureau of Resource Protection - Wetlands WPA Form 2 — Determination of Applicability Massachusetts Wetlands Protection Act M.G.L. c. 131, §40 B. Determination (cont.) The following Determination(s)is/are applicable to the proposed site and/or project relative to the Wetlands Protection Act and regulations: Positive Determination Note: No work within the jurisdiction of the Wetlands Protection Act may proceed until a final Order of Conditions (issued following submittal of a Notice of Intent or Abbreviated Notice of Intent) has been received from the issuing authority(i.e., Conservation Commission or the Department of Environmental Protection). ❑ 1. The area described on the referenced plan(s)is an area subject to protection under the Act. Removing,filling, dredging, or altering of the area requires the filing of a Notice of Intent. ❑ 2a. The boundary delineations of the following resource areas described on the referenced plan(s)are confirmed as accurate. Therefore, the resource area boundaries confirmed in this Determination are binding as to all decisions rendered pursuant to the Wetlands Protection Act and its regulations regarding such boundaries for as long as this Determination is valid. ❑ 2b. The boundaries of resource areas listed below are not confirmed by this Determination, _ regardless of whether such boundaries are contained on the plans attached to this Determination or to the Request for Determination. ❑ 3.The work described on referenced plan(s)and document(s)is within an area subject to r protection under the Act and will remove, fill, dredge, or alter that area. Therefore, said work requires the filing of a Notice of Intent. ❑ 4. The work described on referenced plan(s)and document(s) is within the Buffer Zone and will alter an Area subject to protection under the Act. Therefore, said work requires the filing of a Notice of Intent. ❑ 5. The area and/or work described on referenced plan(s) and document(s) is subject to review and approval by: Name of Municipality Pursuant to the following municipal wetland ordinance or bylaw: Name Ordinance or Bylaw Citation wpafo.2.dm•rev.7/13/04 Page 2 of 5 Massachusetts Department of Environmental Protection Bureau of Resource Protection - Wetlands WPA Form 2 — Determination of Applicability Massachusetts Wetlands Protection Act M.G.L. c. 131, §40 B. Determination (cont.) ❑ 6. The following area and/or work, if any, is subject to a municipal ordinance or bylaw but not subject to the Massachusetts Wetlands Protection Act: ❑ 7. If a Notice of Intent is filed for the work in the Riverfront Area described on referenced plan(s) and document(s),which includes all or part of the work described in the Request, the applicant must consider the following alternatives. (Refer to the wetland regulations at 10.58(4)c. for more information about the scope of alternatives requirements): Alternatives limited to the lot on which the project is located. ❑ P 1 ❑ Alternatives limited to the lot on which the project is located, the subdivided lots, and any adjacent lots formerly or presently owned by the same owner. ❑ Alternatives limited to the original parcel on which the project is located, the subdivided parcels, any adjacent parcels, and any other land which can reasonably be obtained within the municipality. ❑ Alternatives extend to any sites which can reasonably be obtained within the appropriate region of the state. Negative Determination Note: No further action under the Wetlands Protection Act is required by the applicant. However, if the Department is requested to issue a Superseding Determination of Applicability,work may not proceed on this project unless the Department fails to act on such request within 35 days of the date the request is post-marked for certified mail or hand delivered to the Department. Work may then proceed at the owner's risk only upon notice to the Department and to the Conservation Commission. Requirements for requests for Superseding Determinations are listed at the end of this document. ❑ 1. The area described in the Request is not an area subject to protection under the Act or the Buffer Zone. ❑ 2. The work described in the Request is within an area subject to protection under the Act, but will not remove, fill, dredge, or alter that area. Therefore, said work does not require the filing of a Notice of Intent. ❑ 3. The work described in the Request is within the Buffer Zone, as defined in the regulations, but will not alter an Area subject to protection under the Act.Therefore, said work does not require the filing of a Notice of Intent, subject to the following conditions (if any). ❑ 4. The work described in the Request is not within an Area subject to protection under the Act (including the Buffer Zone). Therefore, said work does not require the filing of a Notice of Intent, unless and until said work alters an Area subject to protection under the Act. wpaform2.eoc•rev.7113104 Page 3 of 5 ro Massachusetts Department of Environmental Protection Bureau of Resource Protection - Wetlands WPA Form 2 — Determination of Applicability Massachusetts Wetlands Protection Act M.G.L. c. 131, §40 B. Determination (cont.) ® 5. The area described in the Request is subject to protection under the Act. Since the work described therein meets the requirements for the following exemption, as specified in the Act and the regulations, no Notice of Intent is required: 310 CMR 10.03 (6) (b)Presumption Concerning Application of Herbicides 310 CMR 10.58 (6) (a) Exempted from Requirements for the Riverfront Area Exempt Activity(site applicable staluatory/regulatory provisions) ❑ 6. The area and/or work described in the Request is not subject to review and approval by: Name of Municipality Pursuant to a municipal wetlands ordinance or bylaw. Name Ordinance or Bylaw Citation C. Authorization This Determination is issued to the applicant and delivered as follows: ❑ by hand delivery on by certified mail, return receipt requested on 1 /16105 Date Dates This Determination is valid for three years from the date of issuance (except Determinations for Vegetation Management Plans which are valid for the duration of the Plan). This Determination does not relieve the applicant from complying with all other applicable federal, state, or local statutes, ordinances, bylaws, or regulations. This Determination must be signed by a majority of the Conservation Commission. A copy must be sent to the appropriate DEP Regional Office (see Attachment)and the property owner(if different from the applicant). 7 Signatures: 06 March, 10 2005 Date wpaformldcc•rev.7/13/04 Page 4 of 5 Massachusetts Department of Environmental Protection Bureau of Resource Protection - Wetlands WPA Form 2 — Determination of Applicability Massachusetts Wetlands Protection Act M.G.L. c. 131, §40 D. Appeals The applicant, owner, any person aggrieved by this Determination, any owner of land abutting the land upon which the proposed work is to be done, or any ten residents of the city or town in which such land is located, are hereby notified of their right to request the appropriate Department of Environmental Protection Regional Office (see Attachment)to issue a Superseding Determination of Applicability.The request must be made by certified mail or hand delivery to the Department,with the appropriate filing fee and Fee Transmittal Form (see Request for Departmental Action Fee Transmittal Form)as provided in 310 CMR 10.03(7)within ten business days from the date of issuance of this Determination.A copy of the request shall at the same time be sent by certified mail or hand delivery to the Conservation Commission and to the applicant if he/she is not the appellant. The request shall state clearly and concisely the objections to the Determination which is being appealed. To the extent that the Determination is based on a municipal ordinance or bylaw and not on the Massachusetts Wetlands Protection Act or regulations,the Department of Environmental Protection has no appellate jurisdiction. wpaform2.d=•rev.7/13/04 Page 5 of 5 T Massachusetts Department of Environmental Protection Bureau of Resource Protection - Wetlands WPA Form 2 — Determination of Applicability Massachusetts Wetlands Protection Act M.G.L. c. 131, §40 A. General Information Important: When filling out From: forms on the Salem computer, use Conservation Commission only the tab key to move To: Applicant Property Owner(if different from applicant): your cursor- do not use the TEC Associates Massachusetts Bay Communter Railraod return key. Name Name 46 Sawyer Street 32 Cobble Hill Road VQ Mailing Address Mailing Address S. Portland ME 04106 Somerville MA 02143 ci Cily/Town State Zip Code CitylTown State Zip Code 1. Title and Date (or Revised Date if applicable)of Final Plans and Other Documents: Salem Track Chart Title Date Title Date Title Date 2. Date Request Filed: B. Determination Pursuant to the authority of M.G.L. c. 131, § 40, the Conservation Commission considered your Request for Determination of Applicability,with its supporting documentation, and made the following Determination. Project Description (if applicable): Vegetation control along the Massachusetts Bay Commuter Railroad Right-of-Way, will conform to the guidelines set forth in the Massachusetts Rights-of-Way Management Regulations (333 CMR 11.00) and the preface to the Wetlands Protection Regulations (333 CMR 10.00) relative to the rights-of-way management. Project Location: Massachusetts BAy Commuter Railroad Right-of S2Ie4n Way Cityrrown Assessors Map/Plat Number Parcel/Lot Number wpeform2.doc•rev.7113104 Page 1 of 5 Massachusetts Department of Environmental Protection Bureau of Resource Protection - Wetlands WPA Form 2 — Determination of Applicability Massachusetts Wetlands Protection Act M.G.L. c. 131, §40 B. Determination (cont.) The following Determination(s) is/are applicable to the proposed site and/or project relative to the Wetlands Protection Act and regulations: Positive Determination Note: No work within the jurisdiction of the Wetlands Protection Act may proceed until a final Order of Conditions (issued following submittal of a Notice of Intent or Abbreviated Notice of Intent)has been received from the issuing authority (i.e., Conservation Commission or the Department of Environmental Protection). ❑ 1. The area described on the referenced plan(s)is an area subject to protection under the Act. Removing,filling, dredging, or altering of the area requires the filing of a Notice of Intent. ❑ 2a.The boundary delineations of the following resource areas described on the referenced plan(s)are confirmed as accurate. Therefore,the resource area boundaries confirmed in this Determination are binding as to all decisions rendered pursuant to the Wetlands Protection Act and its regulations regarding such boundaries for as long as this Determination is valid. ❑ 21b. The boundaries of resource areas listed below are not confirmed by this Determination, regardless of whether such boundaries are contained on the plans attached to this Determination or to the Request for Determination. ❑ 3.The work described on referenced plan(s)and document(s) is within an area subject to protection under the Act and will remove, fill, dredge, or alter that area.Therefore, said work requires the filing of a Notice of Intent. ❑ 4. The work described on referenced plan(s)and document(s) is within the Buffer Zone and will alter an Area subject to protection under the Act. Therefore, said work requires the filing of a Notice of Intent. ❑ 5. The area and/or work described on referenced plan(s)and document(s) is subject to review and approval by: Name of Municipality Pursuant to the following municipal wetland ordinance or bylaw: Name Ordinance or Bylaw Citation wpaform2Aw•rev.7/13/04 Page 2 of 5 i Massachusetts Department of Environmental Protection Bureau of Resource Protection - Wetlands WPA Form 2 — Determination of Applicability Massachusetts Wetlands Protection Act M.G.L. c. 131, §40 B. Determination (cont.) ❑ 6. The following area and/or work, if any, is subject to a municipal ordinance or bylaw but not subject to the Massachusetts Wetlands Protection Act: ❑ 7. If a Notice of Intent is filed for the work in the Riverfront Area described on referenced plan(s) and document(s),which includes all or part of the work described in the Request,the applicant must consider the following alternatives. (Refer to the wetland regulations at 10.58(4)c. for more information about the scope of alternatives requirements): ❑ Alternatives limited to the lot on which the project is located. ❑ Alternatives limited to the lot on which the project is located, the subdivided lots, and any adjacent lots formerly or presently owned by the same owner. ❑ Alternatives limited to the original parcel on which the project is located, the subdivided parcels, any adjacent parcels, and any other land which can reasonably be obtained within the municipality. ❑ Alternatives extend to any sites which can reasonably be obtained within the appropriate region of the state. Negative Determination Note: No further action under the Wetlands Protection Act is required by the applicant. However, if the Department is requested to issue a Superseding Determination of Applicability, work may not proceed on this project unless the Department fails to act on such request within 35 days of the date the request is post-marked for certified mail or hand delivered to the Department.Work may then proceed at the owner's risk only upon notice to the Department and to the Conservation Commission. Requirements for requests for Superseding Determinations are listed at the end of this document. ❑ 1. The area described in the Request is not an area subject to protection under the Act or the Buffer Zone. ❑ 2.The work described in the Request is within an area subject to protection under the Act, but will not remove, fill, dredge, or alter that area. Therefore, said work does not require the filing of a Notice of Intent. ❑ 3. The work described in the Request is within the Buffer Zone, as defined in the regulations, but will not alter an Area subject to protection under the Act. Therefore, said work does not require the filing of a Notice of Intent, subject to the following conditions (if any). protection under the Act to❑ subject 4.The work described in the Request is not within an Area subj p (including the Buffer Zone). Therefore, said work does not require the filing of a Notice of Intent, unless and until said work alters an Area subject to protection under the Act. wpafor 2.dw•rev.7113104 Page 3 of 5 Massachusetts Department of Environmental Protection Bureau of Resource Protection - Wetlands WPA Form 2 — Determination of Applicability Massachusetts Wetlands Protection Act M.G.L. c. 131, §40 B. Determination (cont.) ® 5. The area described in the Request is subject to protection under the Act. Since the work described therein meets the requirements for the following exemption, as specified in the Act and the regulations, no Notice of Intent is required: 310 CMR 10.03 (6) (b) Presumption Concerning Application of Herbicides 310 CMR 10.58 (6) (a) Exempted from Requirements for the Riverfront Area Exempt Activity(site applicable statuatory/regulatory provisions) ❑ 6. The area and/or work described in the Request is not subject to review and approval by: Name of Municipality Pursuant to a municipal wetlands ordinance or bylaw. Name Ordinance or Bylaw Citation C. Authorization This Determination is issued to the applicant and delivered as follows: ❑ by hand delivery on by certified mail, return receipt requested on g �riS�uS Date Date This Determination is valid for three years from the date of issuance (except Determinations for Vegetation Management Plans which are valid for the duration of the Plan). This Determination does not relieve the applicant from complying with all other applicable federal, state, or local statutes, ordinances, bylaws, or regulations. This Determination must be signed by a majority of the Conservation Commission. A copy must be sent to the appropriate DEP Regional Office (see Attachment)and the property owner (if different from the applicant). Signatures: March, 10 2005 Date wpaformldcc•rev.7/13104 Page 4 of 5 r'E Massachusetts Department of Environmental Protection Bureau of Resource Protection - Wetlands WPA Form 2 — Determination of Applicability Massachusetts Wetlands Protection Act M.G.L. c. 131, §40 D. Appeals The applicant, owner, any person aggrieved by this Determination, any owner of land abutting the land upon which the proposed work is to be done, or any ten residents of the city or town in which such land is located, are hereby notified of their right to request the appropriate Department of Environmental Protection Regional Office(see Attachment)to issue a Superseding Determination of Applicability. The request must be made by certified mail or hand delivery to the Department,with the appropriate filing fee and Fee Transmittal Form (see Request for Departmental Action Fee Transmittal Form)as provided in 310 CMR 10.03(7)within ten business days from the date of issuance of this Determination.A copy of the request shall at the same time be sent by certified mail or hand delivery to the Conservation Commission and to the applicant if he/she is not the appellant. The request shall state clearly and concisely the objections to the Determination which is being appealed.To the extent that the Determination is based on a municipal ordinance or bylaw and not on the Massachusetts Wetlands Protection Act or regulations, the Department of Environmental Protection has no appellate jurisdiction. vrpafo 2.doc•rev.1113104 Page 5 of 5 3v � <. CITY OF SALEM CONSERVATION COMMISSION City of Salem Conservation Commission Will hold a public hearing for a Request for a Determination of Applicability under the Wetlands Protection Act, Massachusetts General Laws, Chapter 131, Section 40 and Salem's Ordinance Pertaining to General Wetlands at the request of Massachusetts Bay Commuter Railroad, 32 Cobble Hill Road, Somerville, MA 02143. The purpose of the hearing is for a determination of work related to vegetation control along the Massachusetts Bay Commuter Rail right-of-way. This hearing will be held on Thursday, February 24, 2005 at 6:00 p.m. in City Hall Annex, Room 313, 120 Washington Street. Kevin P. Cornacchio Chairman Please print ad on: February 17, 2005 Please send bill to: TEC Associates C/O Wayne W. Duffett 46 Sawyer Street South Portland, ME 04106 (207) 767-6068 120 WASHINGTON STREET, SALEM, MASSACHUSETTS 01970 TEL: 978.745.9595 FAx: 978.740.0404 WWW.SALEM.COM Massachusetts Department of Environmental Protection Bureau of Resource Protection -Wetlands Salem WPA Form 1 - Request for Determination of Applicability city/rown Massachusetts Wetlands Protection Act M.G.L. c. 131, §40 A. General Information Important: When filling out 1. Applicant: forms on the TEC Associates wayne@tecassoc.com computer, use Name E-Mail Address only the tab key to move your 46 Sawyer Street cursor-do not Mailing Address use the return South Portland Maine 04106 key. Cityrrown State Zip Code 207-767-6068 207-767-7125 m Phone Number Fax Number(if applicable) 2. Representative (f any): °R TEC Associates Firm Wayne W. Duffett wayne@tecassoc.com Contact Name E-Mail Address 46 Sawyer Street Mailing Address South Portland Maine 04106 cityrrown State Zip Code 207-767-6068 207-767-7125 Phone Number Fax Number(if applicable) B. Determinations 1. I request the Salem make the following determination(s). Check any that apply: Conservation Commission ❑ a.whether the area depicted on plan(s) and/or map(s) referenced below is an area subject to jurisdiction of the Wetlands Protection Act. ® b.whether the boundaries of resource area(s)depicted on plan(s) and/or map(s) referenced below are accurately delineated. ❑ c.whether the work depicted on plan(s) referenced below is subject to the Wetlands Protection Act. ❑ d.whether the area and/or work depicted on plan(s) referenced below is subject to the jurisdiction of any municipal wetlands ordinance or bylaw of: Name of Municipality ❑ e.whether the following scope of alternatives is adequate for work in the Riverfront Area as depicted on referenced plan(s). wpafoaml.dw•rev.07/14104. Page 7 of 4 Massachusetts Department of Environmental Protection Bureau of Resource Protection -Wetlands Salem WPA Form 1 - Request for Determination of Applicability LI City/Town Massachusetts Wetlands Protection Act M.G.L. c. 131, §40 C. Project Description 1. a. Project Location (use maps and plans to identify the location of the area subject to this request): Street Address City/rows Assessors Map/Plat Number Parcel/Lot Number b. Area Description(use additional paper, if necessary): Massachusetts Bay Commuter Railroad Right-of-Way c. Plan and/or Map Reference(s): USGS Map/MBCR Wetland Delineation Tide Date Track Chart Title Date Title Date 2. a. Work Description (use additional paper and/or provide plan(s) of work, if necessary): No work is proposed within wetland resource areas. Vegetation control will conform to the guidelines set forth in the Massachusetts Rights-of-Way Management Regulations(333 CMR 11.00) and the preface to the Wetlands Protection Regulations(333 CMR 10.00) relative to rights-of-way management. wpafowtdoc•w,07/14104. Page 2 of 4 LFMassachusetts Department of Environmental Protection Bureau of Resource Protection -Wetlands Salem JWPA Form 1 - Request for Determination of Applicability City/rows Massachusetts Wetlands Protection Act M.G.L. c. 131, §40 C. Project Description (cont.) b. Identify provisions of the Wetlands Protection Actor regulations which may exempt the applicant from having to file a Notice of Intent for all or part of the described work(use additional paper, if necessary). 310 CMR 10.03 (6) (b)Presumption Concerning Application of Herbicides. 310 CMR 10.05 (3)(a)(2) Requests for Determination of Applicability. 310 CMR 10.58 (6)(a)Exempted from Requirements for the Riverfront Area. 3. a. If this application is a Request for Determination of Scope of Alternatives for work in the Riverfront Area, indicate the one classification below that best describes the project. ❑ Single family house on a lot recorded on or before 8/1/96 ❑ Single family house on a lot recorded after 8/1/96 ❑ Expansion of an existing structure on a lot recorded after 8/1/96 ❑ Project, other than a single family house or public project,where the applicant owned the lot before 817/96 ❑ New agriculture or aquaculture project ❑ Public project where funds were appropriated prior to 8!7/96 ❑ Project on a lot shown on an approved,definitive subdivision plan where there is a recorded deed restriction limiting total alteration of the Riverfront Area for the entire subdivision ❑ Residential subdivision; institutional, industrial,or commercial project ❑ Municipal project ❑ District,county,state, or federal government project ❑ Project required to evaluate off-site alternatives in more than one municipality in an Environmental Impact Report under MEPA or in an alternatives analysis pursuant to an application for a 404 permit from the U.S.Army Corps of Engineers or 401 Water Quality Certification from the Department of Environmental Protection. b. Provide evidence (e.g., record of date subdivision lot was recorded)supporting the classification above(use additional paper and/or attach appropriate documents, if necessary.) rwmaml.aoc•rev.W/14/0e. Page 3 of 4 Massachusetts Department of Environmental Protection Bureau of Resource Protection -Wetlands Salem WPA Form 1 - Request for Determination of Applicability c4frown Massachusetts Wetlands Protection Act M.G.L. c. 131, §40 D. Signatures and Submittal Requirements I hereby certify under the penalties of perjury that the foregoing Request for Determination of Applicability and accompanying plans, documents, and supporting data are true and complete to the best of my knowledge. I further certify that the property owner, if different from the applicant, and the appropriate DEP Regional Office (see Attachment)were sent a complete copy of this Request(including all appropriate documentation) simultaneously with the submittal of this Request to the Conservation Commission. Failure by the applicant to send copies in a timely manner may result in dismissal of the Request for Determination of Applicability. Name and address of the property owner. 'Massachusetts Bay Commuter Railroad Name 32 Cobble Hill Road Mailing Address Somerville City/town MA 02143 State Zip Code Signatures: I also understand that notification of this Request will be placed in a local newspaper at my expense in accordance ith Section 10.05(3)(b)(1) of @ Wettands Protection Act regulations. i 1/21/2005 Signa ure of IicaM Date Signature of Representative fd any) Date wpafoeal.doc•rev.0711N04. Page 4 of 4 - � J X3.0? 'J/ �•yam. [� '.�I �� —r,7. � '^ems-ja ��,. � a 4 S / �/�// \� �l` /�i+a�1� s c ` 2• Go /.- � - ':. la at>\�• ~�e`"j /'l/� 1 r -i l I 1\. �� /�/ � 1pl � 5�'��,/,/' �s �-:--i- ti� '°� �tr-�� v . r1� 11 ate`" �, l I �' < .�� •�>_ .. \ �v'` •r 'l`�,. a� � .is acrtiv c' F ,,,� l ] a> ./ � � py ,i J^ ��s+l.k \•• ,I. �7 r• If]l1 c'•n - 'J 4. ' Tt SIL VL DEL ` --�✓• T ~ _5'✓ �1" • TED SEMS L w_aPI Mu�eo.. �-.o.�l t��'�s�'1..rr".s'*- i••:.,. \�.� �." -_ `_ �p•�a� /c��,;�1 � 5��-��>.slr'� �\�.[.T �\��/'�� l 1 r•u"• r �-5 - � -- - /CCCOV1yr I\7: 7 f ((J(_�{r'^�\l 1T \'C VanY.i Y ``\S• I �-p ( �J ��a+i i+� �i i'�_ l . E bHiyY aTED SENS171 aR �.>t �1�� s J T j/•"� !\�, t\�... a ��/� , \+ lam, p a � .,�,,;' \. ° < ?vs NS+i 1UhL'�.'JtR<�. ��_"✓' V`~� \L j `'� J,.-3i „ i ��.: - r 4J.0 r� J ,�1. fir. �• O '-'t// „ -�. r( , `. ;�:,�. \ -mss:�� .�•;��'`J�` S�i`.e�� '�7v / /� +i �N>/ �-- J . / ',/� / � �, Wei r � �,✓ '"� `��_ �+ 1.e88 �'- �� ...�jam. �;'' � �r�•.:`�4S— � —I —MUKP7 1_ . ,_ }yy nr�r\� ✓ '{tri r os1 �v'�•. ' J'� M ir/ l`�` ��°L' \"'>< r�\'aa �—�• \� / a� _` �' �,'- [:'vrr \ i.�.._. �.. i/•�r�/� � � max;. �amos<ay."r"';�iA" "' I I I Ieo G ^ is I - 44 4, I i i n I� �.K� �hYl7` > I�I 'I — I I I-•I u( I 'I i I. ul ISI i �I — -'.7 \ / .I e�son i �+e. i I . I i c*25.v I ❑. . 15.i7 �_ I I I B r 14. ' I i I I I ,I Out I t 3-15* li 1 1 .; I S i� • I = � I f INO^C.iic) vyl'l:y � I '1 ! i �_� I � I 1 I I� -5.50at 15 3'- I - IY1 I ice! _ 3r, 15.52 cssex "aunty —JI -'..75 ( Sevcr I Bridge -St. -_ �a q Iz.00 _=15 -I ( I^( \ ��lo I � _• � i l I I ' I 13.50 IZ IUI j I l Ial J I 15.00 I 1 �UFiviUt7 �— i i I IN I 1 ' i I 101< I 7 � I I I Ilf� I i I i IIsINI ' Ia I I G j l i I I I I I I vl v� J 17.50 IS.:L c,,,l 11_ KEY SPRAY AREAS AS DELINEATED ON TRACK CHARTS Upland areas and/or lengths of track without proximate sensitive areas. Sensitive areas that are readily identifiable in the field are not included. This is a "no-spray" area. Herbicide spraying is prohibited. Includes lengths of track within 400 feet of a public water supply wellhead, 100 feet from a public surface water supply, a 50 foot radius around a private well, and 10 feet from the edge of standing or flowing water or wetlands. This is a "limited-spray" area. Spraying is restricted to one annual application of an herbicide through low-pressure foliar techniques. Includes lengths of track between 10 and 100 feet from the edge of standing or flowing water or wetlands. This is a "limited" spray area. Spraying is restricted to one application every other year of an herbicide through low-pressure foliar techniques. Includes lengths of track within a 0. 5 mile radius around a public water supply wellhead, between 100 - 400 feet from the edge. of. , a public surface water. supply, and between 50 and 100 foot radius around a private well . WELL SYMBOLS AS INDICATED ON THE USGS MAPS ®. Public Well ® Private Well PWS Public Water Supply PRA Primary Recharge Area (Zone II) TEC ASSOCIATES ENGINEERS 4"February`2005- Mr. Frank Taormina Salem Conservation Commission 1 Salem Green Salem, MA 01970 Re : RDA for Massachusetts Bay Commuter Railroad Dear Mr. Taormina : Enclosed is the filing fee that you requested. If possible, please schedule the public hearing and act on the request without my presence . Should questions arise, you could continue to the next public hearing and I will attend. It would save me a trip if the Commission is satisfied with the request . There are no changes in the delineation since last approved by the Commission on 10 February 2000 . Thank you for considering this request . Very truly yours, , TEC ASSOCIATES Wayne Du Encl sure cc : Bob Johnson, MBCR RECEIVED FEB 0 7 2005 DEPT.OF PLANNING& COMMUNITY DEVELOPMENT 46 Sawyer Street South Portland, Maine 04106 207/767-6068 FAX 207/767-7125 FlaCONSULTI TEC ASSOCIATES ENGINEERS 21 January 2005 Salem Conservation Comm. 1 Salem Green Salem, MA 01970 RE : Request for Determination along Massachusetts Bay Commuter Railroad Right-of-Way Dear Commission Members : In 2000 your Commission inspected and approved a delineation of wetlands along the Massachusetts Bay Commuter Railroad (MBCR) right-of-way. The determination that was issued has allowed MBCR to conduct vegetation management activities in accordance with the Commonwealth of Massachusetts Rights-of-Way Management Regulations (333 CMR 11 . 00) and MBCR' s Vegetation Management Plan (VMP) . Each year since the determination was issued you have been supplied with MBCR' s Yearly Operational Plan (YOP) and.updates to the delineation as necessary. MBCR' s VMP expired on 31 December 2004 and is now in the process of renewal . In accordance with the Wetlands Protection Act , determinations of applicability issued for work conforming to 333 CMR 11 . 00 are in effect for the life of the VMP and must be renewed with the VMP . Accordingly, I have enclosed a Request for Determination to renew the wetland delineation along MBCR' s right- of-way in Salem. There are no changes proposed in the delineation. You should consider a negative number 5 determination citing 310 CMR 10 . 03 (6) (b) and 310 CMR 10 . 58 (6) (a) as the exemptions . Your earliest consideration of this request would be appreciated. Please advise me of any filing fee we may need to submit . If you have any questions, please do not hesitate to call . Very truly yours, TEC ASSOCIATES Wayn Duffet En sures cc : Regional Office, DEP REFI "®� E® Robert Johnson, MBCR JAN 3 12005 DEPT. OF PLANNING& COMMUNITY DEVELOPMENT 46 Sawyer Street South Portland, Maine 04106 207/767-6068 FAX 207/767-7125 t Up 0 <SS Sr .13.40 Essex St { u ro N 53.0 a Sr. 13.60 Danvers St. _ wm m 0--56' 1 O 131 io SALEM N - 49.0 n4 9.0 13BD SwAMVSCOTT 0 o SALEM SltitLLO S'1AMP� I-OI' O a 11.1 i A �42.0 40.0 ` a W m 39.0 1G'TrA1L'IyAgSH} - m Br. 14.30 Culvert `" _ t 36.0 N N ;x O FORES'...'WVtR W 35.0 -04 34.0 'P4A9LE_\DOEGSIA.IFF} 3 - O CP 04 0 M+AASH 7 _ Z 0 m Jvt - rA 9 m D o w a a 0 27.0 SND uuoeri_ 7�c I �j- o Br 14.98 forest River_ c Icim 1 j - O 26.0 Or. 15.17 Jefferson Ave. ! �CD w •� Sr. 15.26 I Br. 15.39 1 c� T 22.0 is 5E' 7.5 m j 13.5 2 j ! -0.50 N 1 1 V m -2.50 � � D I 1 to r In 1* 4$' m j Out 3-15 ❑ Ir. I , i l -7.25 � v m jI -5.50 � I i I is I m e-15' O N 1 io 3.75 Sr. 16.62 Essex County cr Sewer 4.7 Bridge �St. 12.00 3� \Tower -4 © Danvers u 14.503051' iSec. 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