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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
WASH INGTON, DC 20460
OFFICE OF CHEMICAL SAFETY
A ND POLLU110N PREVENTION

October I 2. 20 17
Thomas Marvin
Director. Federal Regulatory Affairs
Monsanto Company
1300 I (Eye) Street. NW - Suite -lSO East
Washington. DC 20005
S u~j cct:

Registration Amendment - Labc:l Amendment to Change Directions for llsl! and
additional Tenns and Conditions to the Registration as Registered on November
9. 2016 lor Usc on Dicamba-tolerant Colton and Dicamba-tolcrant Soybeans
Product Name: M 1768 I IERBICIDE (Xtcndimax with Vaporgrip Technology)
EPA Registration Number: 524-617
Application Date: Octobc:r 41h. 2017
Decision Number: 534662

Dear Mr. Man·in.
In response to the high number of crop damage incidents reported to EPA since June:
2017. Monsanto submitted a labc:l amendment to change the directions for usc on its product as
well as a request to amend its registration to include additional terms and conditions. EPA
approves the labeling proposed by Monsanto as well as the additional terms and conditions of
registration. EPA has determined that theM 1768 llerbicidc: (EPA reg. no. 524-617. Xtc:ndimax
\\'ith Vaporgrip Technology) labeling and registration continue to meet the standard of
registration with the requested amendment as it did on November 9. 2016 ,,·hen EPA registered
these new uses. ll1c: amendment approved through this letter includes additional rc:strictions
further minimizing off-lield movement of the: active ingredient dicamba and do not all'ect the
conclusions in the supporting assessment of risk. EPA accordingly continues to rely on all the
assessments that supported the new uses. and therdore does not require a revised endangered
species e llccts detl!rmination , nor any other new risk assessment. This approval contains
registration terms and conditions that arc in addition to the conditions set fo1th in the new usc
approval granted on November 9. 2016. These terms and conditions do not supersede any
conditions that were pre,·iously imposed on this registration and supported by risk assessments
found in the: following docket .EPA-IIQ-OPP-20 16-0187. Therelore. Monsanto cont inues to be
subject to existing conditions on its registration and any deadlines connected with them.
including but not limited to the automatic expiration date of November 9. 2018. The amended
label referred to above. submilted in connection with registration under the federal lnscctic ide.
Fungicide and Rodenticide Act. as amended. is acceptable under FIFRA Section 3(c)(7)(8)
subject to the follo,,·ing additional terms and conditions to ensure that the new labc:ling is
provided at the: point of sale for the 2018 usc season:
A stamped copy o f your labc:ling is enclosed for your records. ll1is labeling supersedes all
previously accepted labeling including all supplemental labels.

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Page 2 of3
EPA Reg. No. 524-61 7
Decision No. 534662

I. Immediately. for product currently in retail inventories. in the distribution cha in
(packaged and released for sh ipment). and product that wi II be manufactured before new
glossy label booklets are available will be relabe led \·Vith a Sticker and a New Label.
•

•

Sticker will contain the fo llo.,ving information:
o .. Restricted Use Pesticide'·:
o .. Product cannot be used if user does not possess new labe l(ing) that can
be round at www.xtcndimaxapplicationrequirements.com: and
o
·'User must comply in all respects with new label( ing). regardless of any
contrary language on existing label.''
New label will be provided to accompany each stickcred product as well as
pub Iication to Monsanto· s website 'vV\vw.:-:tendimaxapplicationrequirements.com.

2. The nex t label printing of this product, which shou ld occur as soon as practicable. must
use this approved labeling unless subsequent changes have been approved. You must
submit one copy of the final printed labeling before you release the product for shipment
with lhe new labeling. After the next printing, you may only distribute or sell this
product if it bears thi s nev.' revised labe ling or subsequently approved labeling ...To
distribute or sell" is defined under FIFRA section 2(gg) and its implementing regulation
at 40 CfR 152.3. In order to assure the new labeling is implemented for usc in the 2018
application season, the appended terms and conditions (listed here) have been added to
the existing terms and conditions of this registration. Monsanto, the registrant. wil l:

•
•

•

•

•

As soon as new labeling (glossy booklets) become available. affix the new label
to XtendiMax products at the time of manufacture in registered facilit ies.
Notify EPA, \·Vi thin one \-veek of the booklet becoming available. of the date the
booklet became available. All product manufactured after the booklet is available
must contain the new glossy labe l.
For other XtendiMax products- whether in retail inventories, in the distribution
chain, or for which manufacturing will occur before new glossy label booklets
become available- produce and distribute sufficient quantities of stickers and
new paper labels to update product (recogniz ing that stickering must occur in a
registered establishment).
Inform retai lers of the need to sticker and supply new labels tor products currently
in inventory and products received with the former label as well as provide
specific instructions to the retailers that arc registered establishments on how to
affix the sticker on the label and provide the new paper label at time of purchase.
Inform reta ilers that are not yet EPA registered establ ishments about the
importance of stickering the products currently in their inventory and products
received with the former label and that stickering and providing the nev,: labels
can only occur in an EPA registered establishment; inform retailers of the process
for establishment registration and reporting; and communicate that retailers
should not se ll product until stickering is appropriately conducted.

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Page 3 of 3
EP/\ Reg.

1

o. 524-617

Decision No. 53-1-662
•

•
•

In form retailers who do not intend to become registered establishments the
importance of the nev.: labeling and to contact Monsanto immediate ly. so that
Monsanto can reclaim the retailer inventory and provide replacement product with
labeling updated in a registered establishment. Commun icate that reta ilers should
not se ll product until stickering is appropriately conducted.
Prov ide a copy to EPA ofthc communications used to inform retailers and others
as described above.
Provide access to new label through an internet webpagc located at
wwv.:.xtendimaxapplicationrequirements.com.

Please be aware that by adding/retaining a reference to the company· s website on your
label. the w·ebsite becomes labeling under the Federal Insecticide Fungic ide and Rodenticide Act
and is subject to review by the Agency. If the website is false or misleading. the prod uct vvould
be misbranded and unlawful to sell or distribute under FlfR!\ section 12(a)( I)(E). 40 CFR
156.1 0(a)(5) li st examples of statements EPA may consider false or misleading. In addition.
regard less of whether a website is referenced on your product's label. cla ims made on the
webs ite may not substantially differ from those claims approved through the registration process.
Therefore, shou ld the Agency find or if it is brought to our attention that a website contains false
or misleading statements or claims substantially di ffe ring from the EPA approved registration.
the website will be referred to the EPA's Office of Enforcement and Compliance.
A stamped copy of your labeling is enclosed for your records. This labeling supersedes
all previously accepted labeling including all supplemental labels. The new labeling and term s
:md conditions of registration are hereby granted. /\s with the November 9, 20 16 new use
approva ls for use of Xtendimax with VaporGripTM Technology on dicamba-tolerant cotton and
dicamba-tolcrant soybeans, if these conditions are not complied with. the registration \:viii be
subjec t to cance llation in accordance with FIFRA section 6.
If you have any questions, please contact me by phone at 703-305- 1243. or via email at
monlauuc .kathryn!cvcpa.!.!ov,
Sincerely.

~v.~
Kathryn Montague. Product Manager 23
Herbicide Branch
Registration Division (7505P)
Office of Pesticide Programs

Enc losure( s)

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MASTER LABEL FOR EPA REG. NO. 524-617

RESTRICTED USE PESTICIDE
For retail sale to and use only by Certified Applicators or persons under their direct supervision and
only for those uses covered by the Certified Applicator's certification

This labeling expires on 11 /09/2018, unless the U.S. EPA determines before that date that
off-site incidents are not occurring at unacceptable frequencies or levels. Do not use or
distribute this product after 11/09/2018, unless you visit
www.xtendimaxapplicationrequirements.com and can verify that EPA has amended this
expiration date.

ACCEP TED
Primary Brand Name:

10/ 12/2017

M1768 Herbicide

Under the Fede,..llr tSCIChC;M1r: Fun!)l<:ldt-

and Rodenlld<fc ACI os arntHidcd lor thu

Alternate Brand Name:

pesltdde registered under
EPAReg No.

Xtendimax® With VaporGrip® Technology

_
524 61 7

I HERBICIDE

I GROUP
ACTIVE INGREDIENT:

Diglycolamine salt of dicamba (3,6-dichloro-o-anisic acid)* ........................................ .. 42.8%
OTHER INGREDIENTS: ................................. .. ............... ................................ .. ........... 57.2o/o
TOTAL: ............................... .. ...................................... .. .......................... ..................... 100.0°/o
• contains 29.0%, 3,6-dichloro-o-anisic acid (2.9 pounds acid equivalent per U.S. gallon or 350 grams per
liter).

EPA Reg. No. 524-617

Master Label October 2017

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RESTRICTED USE PESTICIDE
For retail sale to and use only by Certified Applicators or persons under their direct supervision
and only for those uses covered by the Certified Applicator's certification

XtendiMax® With VaporGrip® Technology
Complete Directions for Use
This labeling expires on 11 /09/2018, unless the U.S. EPA determines before that date that off-site
incidents are not occurring at unacceptable frequencies or levels. Do not use or distribute this product
after 11 /09/20 18, unless you visit www.xtendimaxapplicationrequirements.com and can verify that EPA
has amended this expiration date.
EPA Reg. Number: 524-617

For weed control in asparagus, conservation reserve programs, corn, cotton, fallow croplands,
general farmstead (noncropland), sorghum, grass grown for seed, hay, proso millet, pasture,
rangeland, small grains, sod farms and farmstead turf, soybean, sugarcane, cotton with XtendFiex
Technology, and Roundup Ready 2 Xtend Soybean.

IGROUP

I HERBICIDE

This label supersedes any previously issued labeling for this product, including previously issued
supplemental labeling.
XtendiMax® With VaporGrip® Technology is approved by U.S. EPA for all uses specified on this label
in the following states, subject to county restriction as noted: Alabama, Arkansas, Arizona, Colorado,
Delaware, Florida (excluding Palm Beach County), Georgia, Illinois, Indiana, Iowa, Kansas, Kentucky,
Louisiana, Maryland, Michigan, Minnesota, Mississippi, Missouri, Nebraska, New Jersey, New Mexico,
New York, North Carolina, North Dakota, Oklahoma, Ohio, Pennsylvania, South Carolina, South Dakota,
Tennessee (excluding Wilson County) , Texas, Virginia, West Virginia, Wisconsin.
Check the registration status of each product in each state before using.
READ THE ENTIRE LABEL FOR XTENDIMAX® WITH VAPORGRI P® TECHNOLOGY
BEFORE PROCEEDING WITH THE USE DIRECTIONS CONTAINED IN TH IS LABEL
READ AND FOLLOW ALL APPLICABLE DIRECTIONS, RESTRICTIONS, AND PRECAUTIONS ON THE
CONTAINER LABEL AND BOOKLET AND WWW.XTENDIMAXAPPLICATIONREQUIREMENTS.COM.
Read the "LIMIT OF WARRANTY AND LIABILITY" statement at the end of the label before buying or
using . If terms are not acceptable, return at once unopened .

Net contents :
EPA Establishment No.:

EPA Reg. No. 524-617

Master Label October 2017

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CONTENTS
1.0
INGREDIENTS......................................................................................................................... 5
2.0
IMPORTANT PHONE NUMBERS .................................................................. ......................... 5
3.0
PRECAUTIONARY STATEMENTS ........................................................................................ 5
3. 1
Hazards to Humans and Domestic Animals ............................................................................ 5
3.2
Environmental Hazards ............................................................................................................ 6
3.3
Physical or Chemical Hazards ................................................................................................. 7
4.0
DIRECTIONS FOR USE .......................................................................................................... 7
4.1
Training .................................................................................................................................... 7
4.2
Record Keeping ....................................................................................................................... 8
5.0
STORAGE AND DISPOSAL ................................................................................................... 9
5.1
Pesticide Storage ..................................................................................................................... 9
5.2
Pesticide Disposal .................................................................................................................... 9
5.3
Container Handling and Disposal ............................................................................. ........... .. 10
PRODUCT INFORMATION .................................................................................................. 12
6.0
6.1
Restrictions ............................................................................................................................ 13
7.0
WEED RESISTANCE MANAGEMENT .................................................................................14
7.1
Weed Management Practices ................................................................................................ 14
7.2
Management of Dicamba-Resistant Biotypes ........................................................................ 15
8.0
TANK MIXING INSTRUCTIONS ........................................................................................... 15
8.1
Compatibility Test for Mix Components ................................................................................. 16
8.2
Mixing Order ........................................................................................................................... 16
8.3
Adjuvants, Drift Reducing Adjuvants, Surfactants, and Other Tank Mixed Products ............ 17
9.0
APPLICATION EQUIPMENT AND TECHNIQUES ...............................................................17
9.1
Spray Drift Management ........................................................................................................ 18
9.1.1 Sprayer Setup ........................................................................................................................ 18
9.1.2 Temperature and Humidity ... ................................................................................................. 18
9. 1.3 Temperature lnversions ......................................................................................................... 18
9.1.4 Buffer Requirements and Protection of Susceptible Crops ................................................... 19
9.1.4.a. Buffer Requirement ................................................................................................................ 19
9.1.4.b. Susceptible Crops .................................................................................................................. 20
9.1.5 Application Awareness ........................................................................................................... 20
9.2
Ground Application (Banding) ............................................................................................... 20
9.3
Ground Application (Broadcast) ............................................................................................. 21
9.4
Ground Application (Wipers) .................................................................................................. 21
9.5
Proper Spray System Equipment Cleanout ........................................................................... 21
10.0
ADDITIONAL RESTRICTIONS ............................................................................................. 22
11.0
CROP-SPECIFIC INFORMATION ......... ............................................................................... 24
11.1
Asparagus .............................................................................................................................. 24
11 .2
Between Crop Applications ........................................................................................... ......... 24
11.3
Conservation Reserve Program (CRP).................................................................................. 25
11.4
Corn (Field, Pop, Seed, And Silage) ......................................................................................25
11 .5
Cotton ..................................................................................................................................... 27
11.6
Grass Grown For Seed .......................................................................................................... 27
11.7
Pro so Millet ............................................................................................................................ 27
11 .8
Pasture, Hay, Rangeland, And General Farmstead (Noncropland) ...................................... 28
11 .9
SMALL GRAINS ..................................................................................................................... 29
11 .9.1 Small Grains Not Underseeded To Legumes (fall- and spring-seeded barley, oat, triticale and
wheat) ............................................................................. ....................................................... ........... 29
11 .9.2 Small Grains: Barley (fall- and spring-seeded) ..................................................................... 30
11.9.3 Small Grains: Oats (fall- and spring-seeded) ........................................................................ 30
11 .9.4 Small Grains: Triticale (fall- and spring-seeded) .................................................................... 30
11 .9.5 Small Grains : Wheat (fall- and spring-seeded) ...................................................................... 31
11 .10 Sorghum ............................................................................... .................................................. 31
11 .11 Soybean ................................................................................................................................. 32
11 .12 Sugarcane .............................................................................................................................. 33

EPA Reg. No. 524·617

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11 .13
12.0
12.1
12.2
13.0
14.0

Farmstead Turf (noncropland) and Sod Farms ........................................... ... ............ ... .. ...... 33
CROPS WITH XTENo®TECHNOLOGV............................................................................... 33
Cotton with Xtend Flex® Technology ....................................................... .. ............................. 34
Roundup Ready 2 Xtend® Soybean .................... .. ................................................................. 36
WEEDS CONTROLLED ........................................................................................................ 37
LIMIT OF WARRANTY AND LIABILITY ............................................................................... 39

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1.0 INGREDIENTS
ACTIVE INGREDIENT:
Diglycolamine salt of dicamba (3,6-dichloro-o-anisic acidf .......................................... 42.8%
OTHER INGREDIENTS: ............................................................................................... 57.2°/o

TOTAL: ............................................................................................................ .. .......... 100.0°/o
• contains 29.0%, 3,6-dichloro-o-anisic acid (2.9 pounds acid equivalent per U.S. gallon or 350 grams per
liter).

I HERBICIDE

I GROUP
2.0 IMPORTANT PHONE NUMBERS

1. FOR PRODUCT INFORMATION OR ASSISTANCE IN USING THIS PRODUCT, CALL TOLL-FREE,
1-800-332-3111 .
2. IN CASE OF AN EMERGENCY INVOLVING THIS HERBICIDE PRODUCT, OR FOR MEDICAL
ASSISTANCE, CALL COLLECT, DAY OR NIGHT, (314)-694-4000.

IN CASE OF SPILL:

Steps to be taken in case material is released or spilled:
Dike and contain the spill with inert material (sand, earth, etc.) and transfer liquid and solid diking material
to separate containers for disposal. Remove contaminated clothing, and wash affected skin areas with
soap and water. Wash clothing before re-use. Keep the spill out of all sewers and open bodies of water.

3.0 PRECAUTIONARY STATEMENTS

3.1
Hazards to Humans and Domestic Animals
Keep out of reach of children.
CAUTION !
Causes moderate eye irritation . Avoid contact with eyes or clothing. Wash thoroughly with soap and
water after handling and before eating, drinking, chewing gum, using tobacco or using the toilet.

IF IN EYES

•
•

•
IF SWALLOWED :

•
•
•

IF ON SKIN OR
CLOTHING:

EPA Reg. No. 524-617

•
•
•

FIRST AID
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.
Call a poison control center or doctor immediately for treatment advice.
Have person sip a glass of water if able to swallow.
Do not induce vomiting unless told to do so by a poison control center or
doctor.
Do not give anything by mouth to an unconscious person .
Take off contaminated clothing.
Rinse skin immediately with plenty of water for 15 to 20 minutes.

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•
•
•

I • Call a poison control center or doctor for treatment advice.
Have the product container or label with you when calling a poison control center or doctor, or going
for treatment.
You can call (314) 694-4000, collect day or night, for emergency medical treatment information.
This product is identified as XtendiMax® With VaporGrip®Technology, EPA Registration No. 524617.

PERSONAL PROTECTIVE EQUIPMENT (PPE)
All mixers, loaders, applicators and other handlers must wear:
• Long-sleeved shirt and long pants
• Waterproof gloves
• Shoes plus socks
See "Engineering Controls Statement" for additional requirements.
Follow the manufacturer's instructions for cleaning and maintaining PPE. If no such instructions for
washables exist, use detergent and hot water. Keep and wash PPE separately from other laundry.

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

Wash hands before eating, drinking, chewing gum , using tobacco or using the toilet.

•

Remove clothing/PPE immediately if pesticide gets inside. Then wash thoroughly and put on clean
clothing.

•

Remove PPE immediately after handling this product. Wash the outside of gloves before removing . As
soon as possible, wash thoroughly and change into clean clothing.

3.2

Environmental Hazards

Do not apply directly to water, or to areas where surface water is present or to intertidal areas below the
mean high water mark. Do not contaminate water when disposing of equipment washwaters or rinsate.
Apply this product only as directed on the label.
This chemical is known to leach through soil into ground water under certain conditions as a result of
agricultural use. Use of this chemical in areas where soils are permeable, particularly where the water
table is shallow, may result in ground water contamination.
Ground and Surface Water Protection
Point source contamination - To prevent point source contamination, do not mix or load this pesticide
product within 50 feet of wells (including abandoned wells and drainage wells) , sink holes, perennial or
intermittent streams and rivers, and natural or impounded lakes and reservoirs. Do not apply pesticide

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product within 50 feet of wells. This setback does not apply to properly capped or plugged abandoned
wells and does not apply to impervious pad or properly diked mixing/loading areas as described below.
Mixing, loading, rinsing, or washing operations performed within 50 feet of a well are allowed only when
conducted on an impervious pad constructed to withstand the weight of the heaviest load that may be on
or move across the pad. The pad must be self-contained to prevent surface water flow over or from the
pad. The pad capacity must be maintained at 110% that of the largest pesticide container or application
equipment used on the pad and have sufficient capacity to contain all product spills, equipment or
container leaks, equipment wash waters, and rainwater that may fall on the pad. The containment
capacity does not apply to vehicles delivering pesticide shipments to the mixing/loading site. States may
have in effect additional requirements regarding wellhead setbacks and operational containment.
Care must be taken when using this product to prevent: a) back siphoning into wells , b) spills or c)
improper disposal of excess pesticide, spray mixtures or rinsates. Check valves or anti-siphoning devices
must be used on all mixing equipment.
Movement by surface runoff or through soil - Do not apply under conditions which favor runoff. Do not
apply to impervious substrates such as paved or highly compacted surfaces in areas with high potential
for ground water contamination. Ground water contamination may occur in areas where soils are
permeable or coarse and ground water is near the surface. Do not apply to soils classified as sand with
less than 3% organic matter and where ground water depth is shallow. To minimize the possibility of
ground water contamination, carefully follow application rate recommendations as affected by soil type in
the Crop Specific Information section of this label.
Movement by water erosion of treated soil - Do not apply or incorporate this product through any type
of irrigation equipment nor by flood or furrow irrigation . Ensure treated areas have received at least onehalf inch rainfall (or irrigation) before using tailwater for subsequent irrigation of other fields.
Endangered Species Concerns
The use of any pesticide in a manner that may kill or otherwise harm an endangered species or adversely
modify their habitat is a violation of federal law.

3.3

Physical or Chemical Hazards

Do not store or heat near oxidizing agents, hazardous chemical reaction may occur.

4.0 DIRECTIONS FOR USE

It is a violation of Federal law to use this product in any manner inconsistent with its labeling. This product
can only be used in accordance with the Directions for Use on this label. This labeling must be in the
user's possession during application.
Do not apply this product in a way that will contact workers or other persons, either directly or through
drift. Only protected handlers may be in the area during application. For any requirements specific to your
State or Tribe, consult the agency responsible for pesticide regulations.
This is a restricted use pesticide.

4.1

Training

Prior to applying this product in the 2018 growing season and each growing season thereafter,
applicator(s) must complete dicamba or auxin-specific training . If training is available and required by the
state where the applicator intends to apply this product, the applicator must complete that training. If the
state where the application is intended does not require auxin or dicamba-specific training, then the
applicator must complete dicamba or auxin-specific training provided by one of the following sources: a) a

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registrant of a dicamba product approved for in-crop use with dicamba-tolerant crops, or b) a state or
state-authorized provider.

4.2

Record Keeping

Record keeping is required for applications of this product. The certified applicator must keep the
following records for a period of two years; records must be generated as soon as practical but no
later than 14 days after application and a record must be kept for each application of Xtendimax with
VaporGrip Technology. Records must be made available to State Pesticide Control Otficial(s), USDA, and
EPA upon request. An example form summarizing record keeping requirements can be found on
www.xtendimaxapplicationrequirements.com.
1.

2.
3.
4.
5.
6.

7.
8.
9.
10.

11 .

12.

13.

All Items required by 7 CFR Part 110 (RECORDKEEPING ON RESTRICTED USE PESTICIDES
BY CERTIFIED APPLICATORS) including:
a. The brand or product name
b. The EPA registration number
c . The total amount applied
d. The month, day, and year
e. The location of the application
f. The crop, commodity, stored product, or site
g. The size of treated area
h. The name of the certified applicator
i. The certification number of the certified applicator
Training: Date and provider of required training completed and proof of completion.
Receipts of Purchase: Receipts or copies for the purchase of this product.
Product Label: A copy of this product label, and any state special local needs label that
supplements this label.
Buffer Requirement: Record of the buffer distance calculation and any areas included within the
buffer distance calculations as allowed in Section 9.1.4.a.
Susceptible Crops Awareness: Record that a sensitive crop registry was consulted; or document
surveying neighboring fields for any susceptible crops prior to application. At a minimum, records
must include the name of the sensitive crop registry and the date it was consulted or the survey of
neighboring fields and the date conducted (read Section 9.1.4.b for additional information).
Start and Finish Times of Each Application: Record of the time at which the application started
and the time when the application finished.
Application Timing: Record of the type of application (for example: pre-emergence, postemergence) and number of days after planting if post-emergence.
Air Temperature: Record of the air temperature in degrees Fahrenheit at the start and completion
of each application.
Wind Speed and Direction: Record of the wind speed and direction (the direction from which the
wind is blowing) at boom height at the start and completion of each application of this product
(Read Section 9.1.1 for information on wind speed).
Nozzle and Pressure: Record of the spray nozzle manufacturer/brand, type, orifice size, and
operating pressure used during each application of this product (Read Section 9.1.1 for
information on nozzles and pressures.)
Tank Mix Products: Record of the brand names and EPA registration numbers (if available) for all
products (pesticides, adjuvants, and other products) that were tank mixed with this product for
each application (Read Section 8.0 for more information on tank mixing.)
Spray System Cleanout: Record of compliance with the section of this label titled Section 9.5:
Proper Spray System Equipment Cleanout. At a minimum, records must include the confirmation
that the spray system was clean before using this product and that the post-application cleanout
was completed in accordance with Section 9.5.

EPA Reg. No. 524-617

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AGRICULTURAL USE REQUIREMENTS
Use this product only in accordance with its labeling and with the Worker Protection Standard, 40 CFR
Part 170. This standard contains requirements for the protection of agricultural workers on farms, forests,
nurseries, and greenhouses, and handlers of agricultural pesticides. It contains requirements for training ,
decontamination, notification, and emergency assistance. It also contains specific instructions and
exceptions pertaining to the statements on this label about Personal Protective Equipment (PPE), and
restricted-entry intervals. The requirements in this box only apply to uses of this product that are covered
by the WPS.
Do not enter or allow worker entry into treated areas during the restricted-entry interval (REI) of 24 hours.
PPE required for early entry to treated areas that is permitted under the Worker Protection Standard and
that involves contact with anything that has been treated, such as, plants, soil , or water is:
•
Coveralls worn over short-sleeved shirt and short pants
•
Chemical-resistant footwear plus socks
•
Waterproof gloves
•
Chemical-resistant headgear for overhead exposure
•
Protective eyewear

NON-AGRICULTURAL USE REQUIREMENTS
The requirements in this box apply to uses of this product that are NOT within the scope of the Worker
Protection Standard for agricultural pesticides (40 CFR Part 170). The WPS applies when this product is
used to produce agricultural plants on farms, forests, nurseries, or greenhouses.
Do not enter or allow people (or pets) to enter the treated area until sprays have dried. Do not apply this
product in a way that will contact workers or other persons, either directly or through drift. Do not enter or
allow other people or pets to enter until sprays have dried.

5.0 STORAGE AND DISPOSAL
Proper pesticide storage and disposal are essential to protect against exposure to people and the
environment due to leaks and spills, excess product or waste, and vandalism. Do not allow this product to
contaminate water, foodstuffs, feed or seed by storage and disposal. Open dumping is prohibited. This
product may not be mixed, loaded, or used within 50 feet of all wells including abandoned wells, drainage
wells, and sinkholes. This setback does not apply to properly capped or plugged abandoned wells and
does not apply to impervious pad or properly diked mixing/loading areas as described above

5.1

Pesticide Storage

Groundwater contamination may be reduced by diking and flooring of permanent liquid bulk storage sites
with an impermeable material. Spillage or leakage should be contained and absorbed with clay granules,
sawdust, or equivalent material for disposal.
Store in original container in a well-ventilated and away from food, pet food, feed, seed, fertilizers, and
veterinary supplies. Avoid cross-contamination with other pesticides. Keep container closed to prevent
spills and contamination.

5.2

Pesticide Disposal

To avoid wastes, use all material in this container, including rinsate, by application according to label
directions. If wastes cannot be avoided, offer remaining product to a waste disposal facility or pesticide

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disposal program. Such programs are often run by state or local governments or by industry. All disposal
must be in accordance with applicable federal, state and local regulations and procedures.
[Alternate PESTICIDE DISPOSAL statement for transport vehicles only.· To avoid wastes, empty as much
product from this transport vehicle as possible for repackaging or use in accordance with label directions.
If wastes cannot be avoided, offer remaining product or rinsate to a waste disposal facility or pesticide
disposal program . All disposal must be in accordance with applicable federal, state and local regulations
and procedures.)

5.3

Container Handling and Disposal

[Optional/abel statement if applicable: See container label for container handling and disposal
instructions and refilling limitations.)
[CONTAINER HANDLING AND DISPOSAL STATEMENTS AND REFILLING LIMITATIONS FOR
CONTAINER LABELS]
[ CONTA/NER HANDLING AND DISPOSAL STATEMENT AND REFILLING LIMITATION FOR
NONREFILLABLE RIGID CONTAINERS OF LESS THAN 1-GALLON CAPACITY]

Nonrefillable container. Do not reuse or refill this container.
[Alternate container statement: Nonrefillable container. Do not reuse this container to hold materials
other than pesticides or dilute pesticides (rinsate). After emptying and cleaning , it may be allowable to
temporarily hold rinsate or other pesticide-related materials in the container. Contact your state
regulatory agency to determine allowable practices in your state.]

Triple rinse this container promptly after emptying .
Triple rinse as follows : Empty the remaining contents into application equipment or a mix tank and drain
for 10 seconds after the flow begins to drip. Fill the container 1/4 full with water and recap. Shake for 10
seconds. Pour rinsate into application equipment or a mix tank or store rinsate for later use or disposal.
Drain for 10 seconds after the flow begins to drip. Repeat this procedure two more times.
Then offer this container for recycling , if available. If recycling is not available, dispose of in accordance
with federal, state and local regulations and procedures, which may include puncturing the properly rinsed
container and disposing in a sanitary landfill.
[Alternate container disposal statement: Once properly rinsed, some agricultural plastic pesticide
containers can be taken to a container collection site or picked up for recycling. To find the nearest site,
contact your chemical dealer or Monsanto at 1-800-ROUNDUP (1-800-768-6387). If recycling is not
available, dispose of in accordance with federal, state and local regulations and procedures, which may
include puncturing the properly rinsed container and disposing in a sanitary landfill.]
(CONTAINER HANDLING AND DISPOSAL STATEMENT AND REFILLING LIMITATION FOR
NONREFILLABLE RIGID PLASTIC 2.5-GALLON CONTAINERS AND OTHER NONREFILLABLE
CONTAINERS OF GREATER THAN 1-GALLON BUT EQUAL TO OR LESS THAN 5-GALLON
CAPACITY]

Nonrefillable container. Do not reuse this container to hold materials other than pesticides or dilute
pesticides {rinsate). After emptying and cleaning, it may be allowable to temporarily hold rinsate or other
pesticide-related materials in the container. Contact your state regulatory agency to determine allowable
practices in your state.
[Alternate container statement: Nonrefillable container. Do not reuse or refill this container.]

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Triple rinse or pressure rinse (or equivalent) this container promptly after emptying.
Triple rinse as follows: Empty the remaining contents into application equipment or a mix tank and drain
for 10 seconds after the flow begins to drip. Fill the container '/4 full with water and recap. Shake for 10
seconds. Pour rinsate into application equipment or a mix tank or store rinsate for later use or disposal.
Drain for 10 seconds after the flow begins to drip. Repeat this procedure two more times.
Pressure rinse as follows: Empty the remaining contents into application equipment or a mix tank and
continue to drain for 10 seconds after the flow begins to drip. Hold container upside down over
application equipment or mix tank or collect rinsate for later use or disposal. Insert pressure rinsing
nozzle in the side of the container, and rinse at about 40 PSI for at least 30 seconds. Drain for 10
seconds after the flow begins to drip.
Once properly rinsed, some agricultural plastic pesticide containers can be taken to a container collection
site or picked up for recycling. [Optional container disposal statement: To find the nearest site, contact
your chemical dealer or Monsanto at 1-800-ROUNDUP (1-800-768-6387)]. If recycling is not available,
dispose of in accordance with federal, state and local regulations and procedures, which may include
puncturing the properly rinsed container and disposing in a sanitary landfill.
[Alternate container disposal statement: Then oHer this container for recycling, if available. If recycling is
not available, dispose of in accordance with federal, state and local regulations and procedures, which
may include puncturing the properly rinsed container and disposing in a sanitary landfill.]

[CONTAINER HANDLING AND DISPOSAL STATEMENT AND REFILLING LIMITATION FOR
NONREFILLABLE RIGID PLASTIC 30-GALLON CONTAINERS AND OTHER NONREFILLABLE
CONTAINERS OF GREATER THAN 5-GALLON CAPACITY)

Nonrefillable container. Do not reuse or refill this container.
[Alternate container statement: Nonrefillable container. Do not reuse this container to hold materials other
than pesticides or dilute pesticides (rinsate). After emptying and cleaning, it may be allowable to
temporarily hold rinsate or other pesticide-related materials in the container. Contact your state
regulatory agency to determine allowable practices in your state.]

Triple rinse or pressure rinse (or equivalent) this container promptly after emptying.
Triple rinse as follows: Empty the remaining contents into application equipment or a mix tank. Fill the
container '14 full with water. Replace and tighten closures. Tip container on its side and roll it back and
forth, ensuring at least one revolution, for 30 seconds. Stand the container on its end and tip it back and
forth several times. Turn the container over onto its other end and tip it back and forth several times.
Empty the rinsate into application equipment or a mix tank or store rinsate for later use or disposal.
Repeat this procedure two more times.
Pressure rinse as follows: Empty the remaining contents into application equipment or a mix tank and
continue to drain for 10 seconds after the flow begins to drip. Hold container upside down over
application equipment or mix tank or collect rinsate for later use or disposal. Insert pressure rinsing
nozzle in the side of the container, and rinse at about 40 PSI for at least 30 seconds. Drain for 10
seconds after the flow begins to drip.
Once properly rinsed, some agricultural plastic pesticide containers can be taken to a container collection
site or picked up for recycling. (Alternate container disposal statement: To find the nearest site, contact
your chemical dealer or Monsanto at 1-800-ROUNDUP (1-800-768-6387)]. If recycling is not available,
dispose of in accordance with federal , state and local regulations and procedures, which may include
puncturing the properly rinsed container and disposing in a sanitary landfill.

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[Alternate container disposal statement: Then offer the container for recycling, if available. If recycling is
not available, dispose of in accordance with federal, state and local regulations and procedures, which
may include puncturing the properly rinsed container and disposing in a sanitary landfill.]
[Optional container label statement: Return Properly Rinsed Container to Monsanto for Recycling
Contact: 1-800-ROUNDUP (1-800-768-6387)]

[CONTAINER HANDLING AND DISPOSAL STATEMENT AND REFILLING LIMITATION FOR ALL
REFILLABLE CONTAINERS, EXCEPT TRANSPORT VEHICLES]

Refillable container. Refill this container with pesticide only. Do not reuse this container for any other
purpose.
Cleaning this container before refilling is the responsibility of the refiller. Cleaning this container before
final disposal is the responsibility of the person disposing of the container.
To clean this container before final disposal, empty the remaining contents from this container into
application equipment or a mix tank. Fill the container about 10 percent full with water. Agitate vigorously
or recirculate water with the pump for 2 minutes. Pour or pump rinsate into application equipment or
rinsate collection system . Repeat this rinsing procedure two more times. Then offer this container for
recycling, if available.
[Optional container disposal statement: To obtain information about recycling refillable containers,
contact Monsanto Company at 1-800-ROUNDUP (1 -800-768-6387))
[Optional container label statement: Return Properly Rinsed Container to Monsanto for Recycling, Call 1800-ROUNDUP (1-800-768-6387))

[CONTAINER HANDLING AND DISPOSAL STATEMENT FOR ALL TRANSPORT VEHICLES AS
DEFINED IN 40 CFR 156.3} .
THIS LABEL FOR USE WITH TRANSPORT VEHICLES ONLY

Emptied container retains vapor and product residue. Observe all precautions stated on this label until
the container is cleaned, reconditioned or destroyed. Prior to refilling, inspect carefully for damage such
as cracks, punctures, abrasions, and worn-out threads and closures. Clean thoroughly before reuse for
transportation of a material of different composition or before retiring this transport vehicle from service.
[Alternative label statement: NET CONTENTS: See Bill of Lading)
[Alternative label statement: LOT: See Bill of Lading)
[Alternative label statement: For Net Contents and Lot Number, see Bill of Lading]

6.0 PRODUCT INFORMATION

XtendiMax® With VaporGrip® Technology is approved by U.S. EPA for all uses specified on this label in
the following states, subject to county restriction as noted: Alabama, Arkansas, Arizona, Colorado,
Delaware, Florida (excluding Palm Beach County), Georgia, Illinois, Indiana, Iowa, Kansas, Kentucky,
Louisiana, Maryland, Michigan, Minnesota, Mississippi , Missouri, Nebraska, New Jersey, New Mexico,

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New York, North Carolina, North Dakota, Oklahoma, Ohio, Pennsylvania, South Carolina, South Dakota,
Tennessee (excluding Wilson County) , Texas, Virginia, West Virginia, Wisconsin.
Additional state restrictions and requirements may apply. The applicator must comply with any additional
state requirements and restrictions.
This product is a water-soluble formulation intended for control and suppression of many annual ,
biennials, and perennial broadleaf weeds, as well as woody brush and vines listed in the WEEDS
CONTROLLED section of this label. This product may be used for control of these weeds in asparagus,
corn , cotton, conservation reserve programs, fallow cropland, grass grown for seed, hay, proso millet,
pasture, rangeland, general farmstead (noncropland), small grains, sod farms and farmstead turf,
sorghum , soybean , sugarcane, Cotton with XtendFiex Technology and Roundup Ready 2 Xtend
Soybean.
XtendiMax® With VaporGrip® Technology is a contact, systemic herbicide which can have moderate
residual control on small seeded broadleaf weeds, including waterhemp, lambsquarters and Palmer
pigweed, depending on rainfall and soil type.
XtendiMax® With VaporGrip® Technology is readily absorbed by plants through shoot and root uptake,
translocates throughout the plant's system, and accumulates in areas of active growth. XtendiMax® With
VaporGrip® Technology interferes with the plant's growth hormones (auxins) resulting in death of many
broadleaf weeds.
Failure to properly clean the entire spray system can result in inadvertent contamination of the spray
system. You must ensure that the spray system used to apply this product is clean before using this
product.

Rainfast period: Rainfall or irrigation occurring within 4 hours after postemergence applications may
reduce the effectiveness of this product.
Refer to the CROP-SPECIFIC INFORMATION and CROPS WITH XTEND TECHNOLOGY sections for
application timing and other crop-specific details.

6.1

Restrictions

The applicator must read the entire label, including product labeling and follow all restrictions for
XtendiMax® With VaporGrip® Technology. Restrictions included, but are not limited to:
•
•

•

•

•

DO NOT APPLY THIS PRODUCT AERIALLY.
DO NOT TANK MIX WITH PRODUCTS CONTAINING AMMONIUM SALTS SUCH AS
AMMONIUM SULFATE (AMS) AND UREA AMMONIUM NITRATE. Small quantities of AMS can
greatly increase the volatility potential of dicamba. Read the TANK MIXING INSTRUCTIONS of
this label (Section 8.0) for instructions regarding other tank mix products.
DO NOT APPLY TO CROPS UNDER STRESS DUE TO LACK OF MOISTURE, HAIL DAMAGE,
FLOODING, HERBICIDE INJURY, MECHANICAL INJURY, INSECTS, OR WIDELY
FLUCTUATING TEMPERATURES AS INJURY MAY RESULT.
DO NOT APPLY THROUGH ANY TYPE OF IRRIGATION EQUIPMENT. DO NOT TREAT
IRRIGATION DITCHES OR WATER USED FOR CROP IRRIGATION OR DOMESTIC
PURPOSES.
DO NOT MAKE APPLICATION OF THIS PRODUCT IF RAIN IS EXPECTED IN THE NEXT 24
HOURS.

Review the entire label including, specific crop use direction sections for additional restrictions.

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7.0 WEED RESISTANCE MANAGEMENT

I

I GROUP

HERBICIDE

Dicamba mimics auxin (a plant hormone) resulting in a hormone imbalance in susceptible plants that
interferes with normal cell division, cell enlargement, and protein synthesis. Dicamba active ingredient is
a Group 4 herbicide based on the mode of action classification system of the Weed Science Society of
America. Any weed population can contain plants naturally resistant to Group 4 herbicides. Weed
species resistant to Group 4 herbicides can be effectively managed utilizing another herbicide from a
different Group, or by using other cultural or mechanical practices.

7.1

Weed Management Practices

Certain agronomic practices can delay or reduce the likelihood that resistant weed populations will
develop and can be utilized to manage weed resistance once it occurs.
Do not use less than the labeled rate of this product in a single application. Using the appropriate
application rate can minimize the selection for resistant weeds.
Proactively implementing diversified weed control strategies to minimize selection for weed populations
resistant to one or more herbicides is a best practice. A diversified weed management program may
include the use of multiple herbicides with different sites of action and overlapping weed spectrum with or
without tillage operations and/or other cultural practices. Research has demonstrated that using the
labeled rate and directions for use is important to delay the selection for resistance.
The continued effectiveness of this product depends on the successful implementation of a weed
resistance management program.
To aid in the prevention of developing weeds resistant to this product:
•
•
•
•
•

•
•
•
•

Scout fields before application to ensure herbicides and rates will be appropriate for the weed
species and weed sizes present.
Start with a clean field, using either a burndown herbicide application or tillage.
Control weeds early when they are relatively small (less than 4 inches).
Apply full rates of XtendiMax® With VaporGrip® Technology for the most difficult to control weed
in the field at the specified time (correct weed size) to minimize weed escapes.
Avoid tank mixtures with other herbicides that reduce the efficacy of this product (through
antagonism), or with ones that encourage application rates of this product below those specified
on this label.
Scout fields after application to detect weed escapes or shifts in weed species.
Control weed escapes before they reproduce by seed or proliferate vegetatively.
Report any incidence of non-performance of this product against a particular weed species to
your Monsanto retailer or representative or call 1-844-RRXTEND (1-844-779-8363).
If resistance is suspected, treat weed escapes with an herbicide having a site of action other than
Group 4 and/or use non-chemical methods to remove escapes, as practical, with the goal of
preventing further seed production.

Additionally, users should follow as many of the following herbicide resistance management practices as
is practical :
•
Use a broad spectrum soil-applied herbicide with other sites of action as a foundation in a weed
control program.
•
Utilize sequential applications of herbicides with alternative sites of action.

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•
•

•
•
•
•

Rotate the use of this product with non-Group 4 herbicides.
Avoid making more than two applications of dicamba and any other Group 4 herbicides within a
single growing season unless mixed with an herbicide with a different mechanism of action with
an overlapping spectrum for the difficult to control weeds.
Incorporate non-chemical weed control practices, such as mechanical cultivation, crop rotation ,
cover crops and weed-free crop seeds, as part of an integrated weed control program.
Use good agronomic principles that enhance crop development and crop competitiveness.
Thoroughly clean plant residues from equipment before leaving fields suspected to contain
resistant weeds.
Manage weeds in and around fields, during and after harvest to reduce weed seed production .

Contact the local agricultural extension service, Monsanto representative, agricultural retailer or crop
consultant for further guidance on weed control practices as needed.

7.2

Management of Dicamba-Resistant Biotypes

Appropriate testing is critical in order to determine if a weed is resistant to dicamba. Contact your
Monsanto representative to determine if resistance in any particular weed biotype has been confirmed in
your area, or visit on the Internet www.weedresistancemanagement.com or www.weedscience.org.
Monsanto Company is not responsible for any losses that result from the failure of this product to control
dicamba-resistant weed biotypes.
The following good agronomic practices can reduce the spread of confirmed dicamba-resistant biotypes :
•
If a naturally occurring resistant biotype is present in your field, this product may be tank-mixed or
applied sequentially with an appropriately labeled herbicide with a different mode of action to achieve
control (read Section 8.0 for more information on tank mixing) .
• Cultural and mechanical control practices (e.g. , crop rotation or tillage) can also be used as
appropriate.
Scout treated fields after herbicide application and control weed escapes, including resistant biotypes,
before they set seed.
Thoroughly clean equipment, as practical, for all weed seeds before leaving fields known to contain
resistant biotypes.

8.0 TANK MIXING INSTRUCTIONS

XtendiMax® With VaporGrip® Technology may only be tank-mixed with products that have been tested
and found not to adversely affect the offsite movement potential of XtendiMax® With VaporGrip®
Technology. A list of those products may be found at www.xtendimaxapplicationrequirements.com.
The applicator must check the list of tested products found not to adversely affect the offsite movement
potential of XtendiMax® With VaporGrip® Technology at www.xtendimaxapplicationrequirements.com no
more than 7 days before applying XtendiMax® With VaporGrip® Technology.
DO NOT tank mix any product with XtendiMax® With VaporGrip® Technology unless :
The intended tank-mix product is identified on the list of tested products;
The intended products are not prohibited on either this label or the label of the tank mix product:
and
3. All requirements and restrictions on www.xtendimaxapplicationrequirments.com are followed.
1.
2.

TO THE EXTENT CONSISTENT WITH APPLICABLE LAW, MONSANTO MAKES NO
RECOMMENDATION OR WARRANTY HEREIN REGARDING THE USE OF ANY PRODUCT THAT

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MAY APPEAR ON THE WEBSITE REFERENCED ABOVE, REGARDLESS OF WHETHER SUCH
PRODUCT IS USED ALONE OR IN A TANK MIX WITH. XTENDIMAX® WITH VAPORGRIP®
TECHNOLOGY. BUYER AND ALL USERS ARE SOLELY RESPONSIBLE FOR ANY LACK OF
PERFORMANCE, LOSS, OR DAMAGE IN CONNECTION WITH THE USE OR HANDLING OF ANY
SUCH PRODUCT ALONE OR IN A TANK MIX WITH XTENDIMAX® WITH VAPORGRIP®
TECHNOLOGY. See the section titled "LIMIT OF WARRANTY AND LIABILITY" herein for more
information.

8.1

Compatibility Test for Mix Components

Before mixing components, always perform a compatibility jar test.
•

•
•
•
•

For 15 gallons per acre spray volume, use 2.5 cups (591.5 mL) of water. For other spray
volumes, adjust rates accordingly. Only use water from the intended source at the source
temperature.
Add components in the sequence indicated in the Mixing Order section below using 2 teaspoons
for each pound or 1 teaspoon for each pint of labeled use rate per acre.
Cap the jar and invert 10 cycles between component additions.
When the components have all been added to the jar, let the solution stand for 15 minutes.
Evaluate the solution for uniformity and stability. The spray solution should not have free oil on
the surface; fine particles that precipitate to the bottom ; or thick (clabbered) texture. If the spray
solution is not compatible. repeat the compatibility test with the addition of a suitable compatibility
agent. If the solution is then compatible, use the compatibility agent as directed on its label. If the
solution is still incompatible, then do not mix the ingredients in the same tank.

8.2

Mixing Order

Only use approved tank mix products as directed on
www.xtendimaxapplicationrequirements.com . Always read and follow label directions for all products in
the tank mixture. It is the pesticide user's responsibility to ensure that all products in the listed mixtures
are registered for the intended use. Users must follow the most restrictive directions for use and
precautionary statements of each product in the tank mixture. See section 8.0 for additional restrictions
on tank mixing.
1.
2.
3.
4.
5.
6.

7.
8.
9.
10.
11 .

Ensure application and mixing equipment are clean and in proper working order
Water - Begin by agitating a thoroughly clean sprayer tank three-quarters full of clean water.
Agitation - Maintain constant agitation throughout mixing and application.
Drift Reducing Adjuvants (DRA)-(when applicable)
Inductor - If an inductor is used, rinse it thoroughly after each component has been added.
Products in PVA bags - Place any product contained in water-soluble PVA bags into the mixing
tank. Wait until all water-soluble PVA bags have fully dissolved and the product is evenly mixed in
the spray tank before continuing.
Water-dispersible products (dry flowables, wettable powders, suspension concentrates, or suspoemulsions)
Water-soluble products (such as XtendiMax® With VaporGrip® Technology)
Emulsifiable concentrates (such as oil concentrate when applicable)
Water-soluble additives (when applicable)
Add remaining quantity of water.

Maintain constant agitation during application

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8.3

Adjuvants, Drift Reducing Adjuvants, Surfactants, and Other Tank Mixed
Products

See Section 8.0 TANK MIXING INSTRUCTIONS for tank mixing instructions for adjuvants, drift
reducing adjuvants, surfactants, and other tank mixed products.

9.0 APPLICATION EQUIPMENT AND TECHNIQUES
DO NOT APPLY THIS PRODUCT USING AERIAL SPRAY EQUIPMENT.
XtendiMax® With VaporGrip® Technology can be applied to actively growing weeds as broadcast, band ,
or spot spray applications using water as a carrier. For best results, treat weeds early when they are
relatively small (less than 4 inches). Timely application to small weeds early in the season will improve
control and reduce weed competition. Refer to Table 1 for XtendiMax® With VaporGrip® Technology
application rates for control or suppression by weed type and growth stage.
For crop-specific
application timing and other details, refer to the CROP-SPECIFIC INFORMATION section of this label.
APPLY THIS PRODUCT USING PROPERLY MAINTAINED AND CALIBRATED EQUIPMENT CAPABLE
OF DELIVER ING THE REQUIRED VOLUMES.
Using a hooded sprayer or other drift reduction technology in combination with approved nozzles may
further reduce drift potential.
Cultivation: Do not cultivate within 7 days after applying this product.
Table 1. XtendiMax® With VaporGrip® Technology Application Rates for Control or Suppression
by Weed Type and Growth Stage
Use rate limitations are given in sections 10 (RESTRICTIONS), 11 (CROP-SPECIFIC INFORMATION),
and 12 (CROPS WITH XTEND TECHNOLOGY)
Rate Per Acre
Weed Type and Stage
Rate Per Acre
Weed Type and
Stage
Annual'
Perennial
11 - 22 fluid ounces
Top growth suppression
Small, actively growing 11-22 fluid
22 - 44 fluid ounces
Top growth control and
ounces
22 - 33 fluid
root suppression
Established weed
Noted perennials
44 fluid ounces
growth
ounces
(footnote 1 in Section

13.0).

Biennial
Rosette diameter 1 -

11 -22 fluid

3"

ounces

Rosette diameter 3" or
more

22-44 fluid
ounces

Other perennials (without
footnote 1 in Section
13.0)3
Wood:i Brush & Vines
Top growth suppression
Top growth control2.3
Stems and stem
suppression3

44 fluid ounces

22 - 44 fluid ounces
44 fluid ounces

44 fluid ounces

Bolting
44 fluid ounces
1 Rates below 11 fluid ounces per acre may provide control or suppression but should typically be
applied with other herbicides that are effective on the same species and biotype.
2 Woody Species listed in section 13.0 may require tank mixes for adequate top growth control.
3 DO NOT broadcast apply more than 44 ounces per acre for a single application and DO NOT
exceed broadcast applications of more than 88 ounces per acre within the growing season when
a sequential application is needed for control. Use the higher rate when treating dense

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vegetation or perennial weeds with established root growth. Perennials and Woody Species are
defined as those listed in Section 13.0.

9.1

Spray Drift Management

Do not allow herbicide solution to mist, drip, drift or splash onto desirable vegetation because severe
injury or destruction to desirable broadleaf plants could result.
The most effective way to reduce drift potential is to apply large droplets that provide sufficient coverage
and control. Applying larger droplets reduces drift potential, but will not prevent drift if the application is
made improperly, or under unfavorable environmental conditions (see the " Temperature and Humidity"
and "Temperature Inversions" sections of this label).

9.1.1

Sprayer Setup

The following sprayer setup requirements for drift management must be followed:
•

Nozzle type. The applicator must use an approved noz.zle within a specified pressure range as
found at www.xtendimaxapplicationrequirements.com when applying XtendiMax® With
VaporGrip® Technology. Do not use any other nozzle and pressure combination not specifically
listed on this website.

•

Spray Volume. The applicator must apply this product in a minimum of 15 gallons of spray
solution per acre. See Section 8.0 for information on approved tank mix products.

•

Equipment Ground Speed. Do not exceed a ground speed of 15 miles per hour. Select a
ground speed that will deliver the desired spray volume while maintaining the desired spray
pressure, but slower speeds generally result in better spray coverage and deposition on the
target area. Provided the applicator can maintain the required nozzle pressure, it is
recommended that tractor speed is reduced to 5 miles per hour at field edges.

•

Spray boom Height. Do not exceed a boom height of 24 inches above target pest or crop
canopy. Excessive boom height will increase the drift potential.

•

Wind Speed . Do not apply when wind speeds are Jess than 3 MPH or greater than 10 MPH.
Only apply when wind speed at boom height is between 3 and 10 mph.

9.1.2

Temperature and Humidity

When making applications in low relative humidity or temperatures above 91 degrees Fahrenheit, set up
equipment to produce larger droplets to compensate for evaporation (for example: increase orifice size
and/or increase spray volume as directed on www.xtendimaxapplicationrequirements.com). Larger
droplets have a lower surface to volume ratio and can be impacted less by temperature and humidity.
Droplet evaporation is most severe when conditions are both hot and dry.

9.1.3

Temperature Inversions

Do not apply this product during a temperature inversion as the off-target movement potential is high.
Do not apply this product between sunset and sunrise. In general, temperature inversions are more likely
during night time hours.

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•

9.1.4

During a temperature inversion, the atmosphere is very stable and vertical air mixing is restricted,
which can cause small, suspended droplets to remain in a concentrated cloud. This cloud can
move in unpredictable directions due to the light, variable winds common during inversions.
• Temperature inversions can be characterized by increasing temperatures with altitude and can be
common on evenings and nights with limited cloud cover and light to no wind. Cooling of air at
the earth's surface takes place and warmer air is trapped above it. Temperature inversions can
begin to form as the sun sets and often continue into the morning.
• Their presence can be indicated by ground fog; however, if fog is not present, inversions can also
be identified by the movement of smoke from a ground source or an aircraft smoke generator.
Smoke that layers and moves laterally in a concentrated cloud (under low wind conditions)
indicates an inversion, while smoke that moves upward and rapidly dissipates indicates good
vertical air mixing.
• The inversion will typically dissipate with increased winds (above 3 miles per hour) or at sunrise
when the surface air begins to warm (generally 3"F from morning low).
Buffer Requirements and Protection of Susceptible Crops

Do not apply under circumstances where drift may occur to food, forage, or other plantings that
might be damaged or the crops rendered unfit for sale, use, or consumption.

9.1.4.a. Buffer Requirement
The applicator must always maintain a 11 0 foot downwind buffer (when applying up to 22 fluid ounces
of this product per acre) or a 220 foot downwind buHer (when applying greater than 22 up to 44 fluid
ounces of this product per acre) between the last treated row and the nearest downwind field edge (in
the direction the wind is blowing).

Dicamba Tolerant
Crop

Downwind
Buffer

The following areas may be included in the buHer distance calculation when directly adjacent to the
treated field edges:
• Roads, paved or gravel surfaces.
• Planted agricultural fields containing: corn, dicamba tolerant cotton, dicamba tolerant soybean.
sorghum , proso millet, small grains and sugarcane. If the applicator intends to include such crops
as dicamba tolerant cotton and/or dicamba tolerant soybeans in the buHer distance calculation ,
the applicator must confirm the crops are in fact dicamba tolerant.
• Agricultural fields that have been prepared for planting.
• Areas covered by the footprint of a building, silo, or other man made structure with walls and or
roof.

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9.1.4.b. Susceptible Crops
DO NOT APPLY this product when the wind is blowing toward adjacent non-dicamba tolerant susceptible
crops; this includes NON-DICAMBA TOLERANT SOYBEAN AND COTTON.

DICAMBA TOL.ERANT

CROP

SUSCEPTIBLE

CROP

Before making an application, the applicator must survey the application site for adjacent nontarget susceptible crops. The applicator must also consult applicable sensitive crop registries to
identify any commercial specialty or certified organic crops that may be located near the
application site.
Susceptible crops include, but are not limited to non-dicamba tolerant soybeans and cotton,
tomatoes and ot her fruiting vegetables (EPA crop group 8}, fruit trees, cucurbits (EPA crop
group 9}, grapes, beans, flowers, ornamentals, peas, potatoes, sunflower, tobacco, other
broadleaf plants, and including plants in a greenhouse. Severe injury or destruction could occur
it any contact between this product and these plants occurs.

9.1.5

Application Awareness

AVOIDING SPRAY DRIFT AT THE APPLICATION SITE IS THE RESPONSIBILITY OF THE
APPLICATOR.

The interaction of equipment and weather related factors must be monitored to maximize performance
and on-target spray deposition. The applicator is responsible for considering all of these factors when
making a spray decision. The applicator is responsible for compliance with state and local pesticide
regulations, including any state or local pesticide drift regulations.

9.2

Ground Application (Banding}

When applying XtendiMax® With VaporGrip® Technology by banding, determine the amount of herbicide
and water volume needed using the following formula:
Bandwidth in inches
Row width in inches

X

Broadcast rate
per acre

Bandwidth in inches
Row width in inches

X

Broadcast volume
per acre

EPA Reg. No. 524-617

Banding herbicide
rate per acre

=

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Banding water
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9.3

Ground Application (Broadcast)

Water Volume: Use a minimum of 15 gallons of spray solution per broadcast acre for optimal
performance. Use 20 gallons per acre when treating dense or tall vegetation.
Application Equipment: Select nozzles (refer to section 9.1.1 Nozzle type of this product label) designed
to produce minimal amounts of fine spray particles. Spray with nozzles as close to the weeds as practical
for good weed coverage.
Using a hooded sprayer or other drift reduction technology in combination with approved nozzles may
further reduce drift potential.

9.4

Ground Application (Wipers)

XtendiMax® With VaporGrip® Technology may be applied through wiper application equipment to control
or suppress actively growing broadleaf weeds, brush and vines. Use a solution containing 1 part
XtendiMax® With VaporGrip® Technology to 1 part water. Do not apply greater than 1 lb dicamba acid
equivalent (1 quart of this product) per acre per application. Do not contact desirable vegetation with
herbicide solution. Wiper application may be made to crops (including pastures) and non-cropland areas
described in this label except for non-dicamba-tolerant cotton, sorghum , and non-dicamba-tolerant
soybean.

9.5

Proper Spray System Equipment Cleanout

You must ensure that the spray system used to apply this product is clean before using this product.
Failure to properly clean the entire spray system can result in inadvertent contamination of the spray
system.
Small quantities of dicamba may cause injury to non-dicamba tolerant soybeans and other susceptible
crops (see Section 9.1.4 of this label for more information).

Clean equipment immediately after using this product, using a triple rinse procedure as follows:
1.
2.
3.
4.
5.

6.
7.
8.
9.
10.
11.

After spraying, drain the sprayer (including boom and lines) immediately. Do not allow the spray
solution to remain in the spray boom lines overnight prior to flushing.
Flush tank, hoses, boom and nozzles with clean water. If equipped, open boom ends and flush.
Inspect and clean all strainers, screens and filters.
Prepare a cleaning solution with a commercial detergent or sprayer cleaner or ammonia
according to the manufacturer's directions.
Take care to wash all parts of the tank, including the inside top surface. Start agitation in the
sprayer and thoroughly recirculate the cleaning solution for at least 15 minutes. All visible
deposits must be removed from the spraying system.
Flush hoses, spray lines and nozzles for at least 1 minute with the cleaning solution.
Remove nozzles, screens and strainers and clean separately in the cleaning solution after
completing the above procedures.
Drain pump, filter and lines.
Rinse the complete spraying system with clean water.
Clean and wash off the outside of the entire sprayer and boom .
All rinse water must be disposed of in compliance with local, state, and federal guidelines.

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10.0

ADDITIONAL RESTRICTIONS

Maximum Application Rates: The maximum application or use rates stated throughout this label are
given in units of volume (fluid ounces or quarts) of this product per acre. However, the maximum allowed
application rates apply to this product combined with the use of any and all other herbicides containing
the active ingredients dicamba, whether applied separately or as a tank mixture, on a basis of total
pounds of dicamba (acid equivalents) per acre. If more than one dicamba-containing product is applied to
the same site within the same year, you must ensure that the total use of dicamba (pounds acid
equivalents) does not exceed 2 pounds/A per year from all applications. See the INGREDIENTS section
of this label for necessary product information.
Maximum seasonal use rate: Refer to Table 2. Crop-Specific Restrictions for crop-specific maximum
seasonal use rates. Do not exceed 88 fluid ounces of XtendiMax® With VaporGrip® Technology (2
pounds acid equivalent) per acre, per year.
Preharvest Interval (PHI) : Refer to the CROP-SPECIFIC INFORMATION section for preharvest
intervals.
Restricted Entry Interval (REI): 24 hours
Crop Rotational Restrictions
No rotational cropping restrictions apply when rotating to Roundup Ready 2 Xtend~ Soybeans or cotton
seed with XtendFiex® Technology (including Bollgard~ 3 XtendFiex3 Cotton, Bollgard II~ XtendFiex3
Cotton, or XtendFiex~ Cotton). For other crops the interval between application and planting rotational
crop is given below. When counting days from the application of this product, do not count days when the
ground is frozen. Planting at intervals less than specified below may result in crop injury. Moisture is
essential for the degradation of this herbicide in soil. If dry weather prevails, use cultivation to allow
herbicide contact with moist soil.
Planting/replanting restrictions at application rates of 33 fluid ounces of this product per acre per
season or less: Follow the planting restrictions in the directions for use for Preplan! application in the
Crop Specific Information section of this label. For corn, cotton (except cotton seed with XtendFiex®
Technology), sorghum, and soybean (except Roundup Ready 2 Xten~ Soybean), follow the planting
restrictions in the directions for use for preplan! application in Section 11. Crop-Specific Information of
this label. Do not plant barley, oat, wheat, and other grass seedings for 15 days for every 11 fluid ounces
of this product applied per acre east of the Mississippi River and 22 days for every 11 fluid ounces per
acre applied west of the Mississippi River. No planting restrictions apply beyond 120 days after
application of this product.
Planting/replanting restrictions at application rates of more than 33 fluid ounces and up to 88 fluid
ounces of this product per acre per season: Wait a minimum of 120 days after application of this
product before planting corn, sorghum and cotton (except cotton seed with XtendFiex® Technology) east
of the Rocky Mountains and before planting all other crops (except Roundup Ready 2 Xten~ Soybean)
grown in areas receiving 30 inches or more rainfall annually. Wait a minimum of 180 days before planting
crops in areas with less than 30 inches of annual rainfall. Wait a minimum of 30 days for every 22 fluid
ounces of this product applied per acre before planting barley, oat, wheat, and other grass seedings east
of the Mississippi River and 45 days for every 22 fluid ounces of this product applied per acre west of the
Mississippi River.
Table 2. Crop-Specific Restrictions 1
Crop

EPA Reg. No. 524·617

Maximum Rate
Per Acre Per
Application

Maximum In-Crop
Rate Pre Acre Per
Season

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(fl oz)

(fl oz}

Asparagus

22

22

Yes

Barley; Fall
Spring

11
11

16.5
15

Yes

Conservation
Reserve Program
(CAP)

44

88

Yes

Corn

22

33

Yes 2

Cotton

11

11

Yes

Cotton with
Xtend Flex
Technology

44

88

Yes

Fallow Ground

44

88

Yes

Grass grown for
seed

44

88

Yes

Oats

5.5

5.5

Yes

Pastureland

44

44

Yes

Proso Millet

5.5

5.5

Yes

Small grains
grown for grass,
forage, fodder, hay
and/or pasture

22

22

Yes

Sorghum

11

22

Yes

Soybean

44

44

Yes

Roundup Ready 2
Xtend Soybean

44

88

Yes

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Sugarcane

44

88

Yes

Triticale

5.5

5.5

Yes

Sod farms and
farmstead turf

44

44

Yes

Wheat

11

22

Yes

Refer to section 11 . CROP-SPECIFIC INFORMATION and section 12.
CROPS WITH XTEND TECHNOLOGY for more details.
2 0nce the crop reaches the ensilage (milk) stage or later in maturity
1

11 .0

CROP-SPECIFIC INFORMATION

Read Sections : 8.0 for Tank Mixing Instructions and 9.1.4 for Buffer Requirements and Susceptible Crops
for information on tank mixing , buffer requirements, and susceptible crops.

11 .1

Asparagus

Apply XtendiMax® With VaporGrip® Technology to emerged and actively growing weeds in 40 - 60
gallons of diluted spray per treated acre immediately after cutting the field, but at least 24 hours before
the next cutting. Multiple applications may be made per growing season.
If spray contacts emerged spears, crooking (twisting) of some spears may result. If such crooking occurs,
discard affected spears.
Rates: Apply 11 -22 fluid ounces of XtendiMax® With VaporGrip® Technology to control annual
sowthistle, black mustard, Canada and Russian thistle, and redroot pigweed (carelessweed).
Apply 22 fluid ounces of XtendiMax® With VaporGrip® Technology to control common chickweed, field
bindweed, nettleleaf goosefoot, and wild radish. Up to 2 applications may be made per growing season.
Do not exceed a total of 22 fluid ounces of XtendiMax® With VaporGrip® Technology per treated acre,
per crop year.
Do not harvest prior to 24 hours after treatment.
[Optional: Do not use in the Coachella Valley of California]

11 .2 Between Crop Applications
Preplant Directions (Postharvest, Fallow, Crop Stubble, Set-Aside) for Broadleaf Weed Control:
XtendiMax® With VaporGrip® Technology can be applied either postharvest in the fall, spring, or summer
during the fallow period or to crop stubble/set-aside acres. Apply XtendiMax® With VaporGrip®
Technology as a broadcast or spot treatment to emerged and actively growing weeds after crop harvest
(postharvest) and before a killing frost or in the fallow cropland or crop stubble the following spring or
summer.
See the "Crop Rotational Restrictions" in Section 10 of this label for the recommended interval between
application and planting to prevent crop injury.

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Rates and Timings:
Apply 5.5- 44 fluid ounces of XtendiMax® With VaporGrip® Technology per acre. Refer to Table 1 to
determine use rates for specific targeted weed species. For best performance, apply XtendiMax® With
VaporGrip® Technology when annual weeds are less than 4" tall, when biennial weeds are in the rosette
stage and to perennial weed regrowth in late summer or fall following a mowing or tillage treatment. The
most effective control of upright perennial broadleaf weeds such as Canada thistle and Jerusalem
artichoke occurs if XtendiMax® With VaporGrip® Technology is applied when the majority of weeds have
at least 4 - 6" of regrowth or for weeds such as field bindweed and hedge bindweed that are in or beyond
the full bloom stage.
Avoid disturbing treated areas following application. Treatments may not kill weeds that develop from
seed or underground plant parts such as rhizomes or bulblets, after the effective period for XtendiMax®
With VaporGrip® Technology. For seedling control, a follow-up program or other cultural practices could
be instituted. For small grain in-crop uses of XtendiMax® With VaporGrip® Technology, refer to the small
grain section for details.

11 .3 Conservation Reserve Program (CRP)
XtendiMax® With VaporGrip® Technology is recommended for use on both newly seeded and
established grasses grown in Conservation Reserve or federal Set-Aside Programs. Treatments of
XtendiMax® With VaporGrip® Technology will injure or may kill alfalfa, clovers, lespedeza, wild winter
peas, vetch, and other legumes.

Newly Seeded Areas
XtendiMax® With VaporGrip® Technology may be applied either preplan! or postemergence to newly
seeded grasses or small grains such as barley, oats, rye, sudanqrass, wheat, or other grain species
grown as a cover crop. Postemergence applications may be made after seedling grasses exceed the 3leaf stage. Rates of XtendiMax® With VaporGrip® Technology greater than 22 fluid ounces per treated
acre may severely injure newly seeded grasses .
Preplan! applications may injure new seedlings if the interval between application and grass planting is
less than 45 days per 22 fluid ounces of XtendiMax® With VaporGrip® Technology applied per treated
acre west of the Mississippi River or 20 days per 22 fluid ounces applied east of the Mississippi River.

Established Grass Stands
Established grass stands are perennial grasses planted one or more seasons prior to treatment. Certain
species (bentgrass, carpetgrass, smooth brome, buffalograss, or St. Augustinegrass) may be injured
when treated with more than 22 fluid ounces of XtendiMax® With VaporGrip® Technology per treated
acre.
When applied at recommended rates, XtendiMax® With VaporGrip® Technology will control many annual
and biennial weeds and provide control or suppression of many perennial weeds.
Rates and Timings
Apply 5.5 - 44 fluid ounces of XtendiMax® With VaporGrip® Technology per acre. Refer to Table 1 for
rates based on target weed species. Retreatments may be made as needed; however, do not exceed a
total of 88 fluid ounces (4 pints) of XtendiMax® With VaporGrip® Technology per acre per year.

11 .4 Corn (Field, Pop, Seed, And Silage)
Direct contact of XtendiMax® With VaporGrip® Technology with corn seed must be avoided. If corn
seeds are less than 1.5" inches below the surface, delay application until corn has emerged.

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Applications of XtendiMax® With VaporGrip® Technology to corn during periods of rapid growth may
result in temporary leaning. Corn will usually become erect within 3 to 7 days. Cultivation should be
delayed until after corn is growing normally to avoid breakage.
Corn may be harvested or grazed for feed once the crop has reached the ensilage (milk) stage or later in
maturity.
Up to 2 applications of XtendiMax® With VaporGrip® Technology may be made during a growing season.
Sequential applications must be separated by 2 weeks or more.
Do not apply XtendiMax® With VaporGrip® Technology to seed corn or popcorn without first verifying
with your local seed corn company (supplier) the selectivity of XtendiMax® With VaporGrip® Technology
on your inbred line or variety of popcorn. This precaution will help avoid potential injury of sensitive
varieties.
Avoid using crop oil concentrates after crop emergence as crop injury may result. Use crop oil
concentrates only in dry conditions when corn is less than 5" tall when applying XtendiMax® With
VaporGrip® Technology.
Use of sprayable fluid fertilizer as the carrier is not recommended for applications of XtendiMax® With
VaporGrip® Technology made after corn emergence.
XtendiMax® With VaporGrip® Technology is not registered for use on sweet corn.

Preplant and Preemergence Application in No-Tillage Corn:
Rates: Apply 22 fluid ounces of XtendiMax® With VaporGrip® Technology per acre on medium- or finetextured soils containing 2.5% or greater organic matter. Use 11 fluid ounces per acre on coarse soils
(sand, loamy sand, and sandy loam) or medium- and fine-textured soils with less than 2.5% organic
matter.

Timing : XtendiMax® With VaporGrip® Technology can be applied to emerging weeds before, during, or
after planting a corn crop. When planting into a legume sod (e.g., alfalfa or clover), apply XtendiMax®
With VaporGrip® Technology after 4- 6" of regrowth has occurred

Preemergence Application in Conventional or Reduced Tillage Corn:
Rates: Apply 22 fluid ounces of XtendiMax® With VaporGrip® Technology per treated acre on mediumor fine-textured soils containing 2.5% organic matter or more. Do not apply to coarse textured soils
(sand, loamy sand, or sandy loam) of any soil with less than 2.5% organic matter until after corn
emergence (See Early Postemergence uses below).

Timing : XtendiMax® With VaporGrip® Technology may be applied after planting and prior to corn
emergence. Pre-emergence application of XtendiMax® With VaporGrip® Technology does not require
mechanical incorporation to become active. A shallow mechanical incorporation is recommended if
application is not followed by adequate rainfall or sprinkler irrigation. Avoid tillage equipment (e.g., drags,
harrows) which concentrates treated soil over seed furrow as seed damage could result.
Preemergence control of cocklebur, jimsonweed, and velvetleaf may be reduced if conditions such as low
temperature or lack of soil moisture cause delayed or deep germination of weeds.

Early Postemergence Application in All Tillage Systems:
Rates : Apply 22 fluid ounces of XtendiMax® With VaporGrip® Technology per treated acre. Reduce the
rate to 11 fluid ounces per treated acre if corn is growing on coarse textured soils (sand, loamy sand, and
sandy loam).

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Timing: Apply between corn emergence and the 5-leaf stage or 8" tall, whichever occurs first. Refer to
Late Postemergence Applications if the sixth true leaf is emerging from whorl or corn is greater than 8"
tall.

Late Postemerqence Application:
Rate: Apply 11 fluid ounces of XtendiMax® With VaporGrip® Technology per treated acre.
Timing: Apply XtendiMax® With VaporGrip® Technology from 8 · 36" tall corn or 15 days before tassel
emergence, whichever comes first. For best performance, apply when weeds are less than 3" tall.
Apply directed spray when corn leaves prevent proper spray.

11.5 Cotton
For directions for use with crops with Xtend Technology see the "CROPS WITH XTEND TECHNOLOGY"
section of this label.

Preplant Application:
Apply up to 11 fluid ounces of XtendiMax® With VaporGrip® Technology per acre to control emerged
broadleaf weeds prior to planting cotton in conventional or conservation tillage systems .
For best performance, apply XtendiMax® With VaporGrip® Technology when weeds are in the 2 • 4 leaf
stage and rosettes are less than 2" across.
Following application of XtendiMax® With VaporGrip® Technology and a minimum accumulation of 1" of
rainfall or overhead irrigation, allow a minimum of 21 days between treatment and planting per application
of 11 fluid ounces per acre or less. This plant back interval must be observed prior to planting cotton.
Do not apply preplant to cotton west of the Rockies.
Do not make XtendiMax® With VaporGrip® Technology preplan! applications to cotton in geographic
areas with average annual rainfall less than 25".
If applying a spring preplant treatment following application of a fall preplan! (postharvest) treatment, then
the combination of both treatments may not exceed 2 pounds acid equivalent per acre.

11.6 Grass Grown For Seed
Apply 11 • 22 fluid ounces of XtendiMax® With VaporGrip® Technology per treated acre on seedling
grass after the crop reaches the 3 -5 leaf stage. Apply up to 44 fluid ounces of XtendiMax® With
VaporGrip® Technology on well-established perennial grass. For best performance, apply XtendiMax®
With VaporGrip® Technology when weeds are in the 2 · 4 leaf stage and rosettes are less than 2" across.
Use the higher level of listed rate ranges when treating more mature weeds or dense vegetative growth.
To suppress annual grasses such as brome (downy and ripgut). rattail fescue, and windgrass , apply up to
44 fluid ounces of XtendiMax® With VaporGrip® Technology per treated acre in the fall or late summer
after harvest and burning of established grass seed crops. Applications should be made immediately
following the first irrigation when the soil is moist and before weeds have more than 2 leaves.
Do not apply XtendiMax® With VaporGrip® Technology after the grass seed crop begins to joint.
Refer to the Pasture, Hay, Rangeland, and General Farmstead section for grazing and feeding
restrictions.

11.7 Proso Millet

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For use only within Colorado, Nebraska, North Dakota, South Dakota, [Optional: and Wyoming].

XtendiMax® With VaporGrip® Technology combined with an appropriate tank-mix partner will provide
control or suppression of the annual broadleaf weeds listed in Section 13.

11 .8

Pasture, Hay, Rangeland, And General Farmstead (Noncropland)

XtendiMax® With VaporGrip® Technology is recommended for use on pasture, hay, rangeland, and
general farmstead (non-cropland) (including fencerows and non-irrigation ditch banks) for control or
suppression of broadleaf weed and brush species listed in Section 12.
XtendiMax® With VaporGrip® Technology may also be applied to non-cropland areas to control broadleaf
weeds in noxious weed control programs, districts, or areas including broadcast or spot treatment of
roadsides and highways, utilities, railroad, and pipeline rights-of-way. Noxious weeds must be recognized
at the state level , but programs may be administered at state. county, or other level.
XtendiMax® With VaporGrip® Technology uses described in this section also pertain to grasses and
small grains (forage sorghum , rye, sudangrass, or wheat) grown for grass, forage, fodder, hay and/or
pasture use only. Grasses and small grains not grown for grass, forage, fodder, hay and/or pasture must
comply with crop-specific uses in this label. Some perennial weeds may be controlled with lower rates of
XtendiMax® With VaporGrip® Technology (refer to Table 1).

Rates and Timings

Refer to Table 1 for rate selection based on targeted weed or brush species.
Rates above 44 fluid ounces of XtendiMax® With VaporGrip® Technology per acre are for spot
treatments only. Spot treatment is defined as no more than a total of 1000 square feet of treated area per
acre. Do not broadcast apply more than 44 fluid ounces per acre.
Retreatments may be made as needed; however, do not exceed a total of 44 fluid ounces of XtendiMax®
With VaporGrip® Technology per treated acre during a growing season.
Grass grown for hay requires a minimum of 7-days between treatment and harvest.

Crop-Specific Restrictions

Do not apply more than 22 fluid ounces of XtendiMax® With VaporGrip® Technology per acre to small
grains grown for pasture.
Newly seeded areas may be severely injured if more than 22 fluid ounces of XtendiMax® With
VaporGrip® Technology is applied per acre.
Established grass crops growing under stress can exhibit various injury symptoms that may be more
pronounced if herbicides are applied. Bentgrass, carpetgrass, buffalograss, and St. Augustin grass may
be injured if more than 22 fluid ounces of XtendiMax® With VaporGrip® Technology is applied per acre.
Usually colonial bent grasses are more tolerant than creeping types. Velvet grasses are most easily
injured. Treatments will kill or injure alfalfa, clovers, lespedeza, wild winter peas, vetch, and other
legumes.
Table 3 lists the timing restrictions for grazing or harvesting hay from treated fields. There are no grazing
restrictions for animals other than lactating dairy animals.

Before

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I

Acre ounces)
(fluid
u~ to 22

U to44

• Spot Treatments: XtendiMax® With VaporGrip<® Technology may be applied to individual clumps or
small areas of undesirable vegetation using handgun or similar types of application equipment. Apply
diluted sprays to allow complete wetting (up to runoff) of foliage and stems.
Cut Surface Treatments:
XtendiMax® With VaporGrip<® Technology may be applied as a cut surface treatment for control of
unwanted trees and prevention of sprouts of cut trees.
Rate: Mix 1 part XtendiMax® With VaporGrip<® Technology with 1 - 3 parts water to create the
application solution. Use the lower dilution rate when treating difficult-to-control species.
• For Frill or Girdle Treatments: Make a continuous cut or a series of overlapping cuts using an axe to
girdle tree trunk. Spray or paint the cut surface with the solution.
• For Stump Treatments: Spray or paint freshly cut surface with the water mix. The area adjacent to the
bark should be thoroughly wet.

Applications For Control of Dormant Multiflora Rose:
XtendiMax® With VaporGrip<® Technology can be applied when plants are dormant as an undiluted spot
treatment directly to the soil or as a Lo-Oil basal bark treatment using an oil-water emulsion solution.
• Spot treatments: Spot treatment applications of XtendiMax® With VaporGrip<® Technology should be
applied directly to the soil as close as possible to the root crown but within 6 - 8" of the crown. On
sloping terrain, apply XtendiMax® With VaporGrip<® Technology to the uphill side of the crown. Do not
apply when snow or water prevents applying XtendiMax® With VaporGrip<® Technology directly to the
soil. The use rate of XtendiMax® With VaporGrip<® Technology depends on the canopy diameter of the
multiflora rose.
Examples: Use 0.34, 1.38, or 3.23 fluid ounces of XtendiMax® With VaporGrip<® Technology
respectively, for 5, 10, or 15 feet canopy diameters.
• Lo-Oil basal bark treatments: For Lo-Oil basal bark treatments, apply XtendiMax® With VaporGrip®
Technology to the basal stem region from the ground line to a height of 12 - 18". Spray until runoff, with
special emphasis on covering the root crown. For best results, apply XtendiMax® With VaporGrip<®
Technology when plants are dormant. Do not apply after bud break or when plants are showing signs of
active growth. Do not apply when snow or water prevents applying XtendiMax® With VaporGrip<®
Technology to the ground line.
To prepare approximately 2 gallons of a Lo-Oil spray solution:
1)

Combine 1.5 gallons of water, 1 ounce of emulsifier, 22 fluid ounces of XtendiMax® With
VaporGrip<® Technology, and 2.5 pints of No. 2 diesel fuel.

2) Adjust the amounts of materials used proportionately to the amount of final spray solution desired.
Do not exceed 8 gallons of spray solution mix applied per acre, per year.
11.9 SMALL GRAINS
11 .9.1

Small Grains Not Underseeded To Legumes (fall- and spring-seeded barley, oat, triticale
and wheat)

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Refer to the specific crop sections below for use rates. When treating difficult to control weeds such as
kochia, wild buckwheat, cow cockle, prostrate knotweed, Russian thistle, and prickly lettuce or when
dense vegetative growth occurs, use the 4.12 - 5.5 fluid ounces of XtendiMax® With VaporGrip®
Technology per acre.
Timings: Apply XtendiMax® With VaporGrip® Technology before, during, or after planting small grains.
See specific small grain crop uses below for maximum crop stage. For best performance, apply
XtendiMax® With VaporGrip® Technology when weeds are in the 2- 3 leaf stage and rosettes are less
than 2" across. Applying XtendiMax® With VaporGrip® Technology to small grains during periods of rapid
growth may result in crop leaning. This condition is temporary and will not reduce crop yields.
Restrictions for small grain areas that are grazed or cut tor hay are indicated in Table 3 in Pasture, Hay,
Rangeland, and General Farmstead section of this label.

11.9.2 Small Grains: Barley (fall- and spring-seeded)
Early season applications:
Apply 2.75-5.5 fluid ounces of XtendiMax® With VaporGrip® Technology to fall-seeded barley prior to
the jointing stage. Apply 2. 75 - 4.12 fluid ounces of XtendiMax® With VaporGrip® Technology before
spring-seeded barley exceeds the 4-leaf stage.
Note: For spring barley varieties that are seeded during the winter months or later, follow the rates and
timings given for spring-seeded barley.

Preharvest applications:
XtendiMax® With VaporGrip® Technology can be used to control weeds that may interfere with harvest
of fall and spring-seeded barley. Apply 11 fluid ounces of XtendiMax® With VaporGrip® Technology per
acre as a broadcast or spot treatment to annual broadleaf weeds when barley is in the hard dough stage
and the green color is gone from the nodes Uoints) of the stern. Best results will be obtained if application
can be made when weeds are actively growing, but before weeds canopy.
Allow a minimum of 7 days between treatment and harvest. Do not use preharvest-treated barley for seed
unless a germination test is performed on the seed with an acceptable result of 95% germination or
better.
[Optional: Do not make preharvest applications in California.]

11.9.3 Small Grains: Oats (fall- and spring-seeded)
Early season applications:
Apply 2.75 - 5.5 fluid ounces of XtendiMax® With VaporGrip® Technology per acre to fall-seeded oat
prior to the jointing stage. Apply 2.75 - 5.5 fluid ounces of XtendiMax® With VaporGrip® Technology
before spring-seeded oat exceed the 5-leat stage.
Do not tank mix XtendiMax® With VaporGrip® Technology with 2,4-D in oat.
Allow a minimum of 7 days between treatment and harvest.
11.9.4 Small Grains: Triticale (fall- and spring-seeded)
Early season applications:
Apply 2.75 -5.5 fluid ounces of XtendiMax® With VaporGrip® Technology to triticale.

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Early season applications to fall-seeded triticale must be made prior to the jointing stage.
Early season applications to spring-seeded triticale must be made before triticale reaches the 6-leaf
stage.

11.9.5 Small Grains: Wheat (fall- and spring-seeded)
Early Season Applications:

Apply 2.75 - 5.5 fluid ounces of XtendiMax® With VaporGrip® Technology to wheat unless using one of
the fall-seeded wheat specific programs below.
Early season applications to fall-seeded wheat must be made prior to the jointing stage.
Early season applications to spring-seeded wheat must be made before wheat exceeds the 6-leaf stage.
Early developing wheat varieties such as TAM 107, Madison, or Wakefield must receive application
between early tillering and the jointing stage. Care should be taken in staging these varieties to be certain
that the application occurs prior to the jointing stage.

Specific use programs for fall-seeded wheat only:

(Optional: XtendiMax® With VaporGrip® Technology may be used at 8.25 fluid ounces on fall-seeded
wheat in Western Oregon as a spring application only.] In Colorado, Kansas , New Mexico, Oklahoma,
and Texas, up to 11 fluid ounces of XtendiMax® With VaporGrip® Technology may be applied on fall seeded wheat after it exceeds the 3-leaf stage for suppression of perennial weeds, such as field
bindweed. Applications may be made in the fall following a frost but before a killing freeze.

Preharvest applications:

XtendiMax® With VaporGrip® Technology can be used to control weeds that may interfere with harvest
of wheat. Apply 11 fluid ounces XtendiMax® With VaporGrip® Technology per acre as a broadcast or
spot treatment to annual broadleaf weeds when wheat is in the hard dough stage and the green color is
gone from the nodes (joints) of the stem. Best results will be obtained if application can be made when
weeds are actively growing but before weeds canopy.
Allow a minimum of 7 days between treatment and harvest. Do not use preharvest-treated wheat for seed
unless a germination test is performed on the seed with an acceptable result of 95% germination or
better.
(Optional: Do not make preharvest applications in California.]

11.10 Sorghum

XtendiMax® With VaporGrip® Technology may be applied preplant, postemergence, or preharvest in
sorghum to control many annual broadleaf weeds and to reduce competition from established perennial
broadleaf weeds, as well as control their seedlings.
Do not graze or feed treated sorghum forage or silage prior to mature grain stage. If sorghum is grown for
pasture or hay, refer to Pasture, Hay, Rangeland, and General Farmstead section of this label for specific
grazing and feeding restrictions.
Do not apply XtendiMax® With VaporGrip® Technology to sorghum grown for seed production.
Preplant Application :

Up to 11 fluid ounces of XtendiMax® With VaporGrip® Technology may be applied per acre if applied at
least 15 days before sorghum planting .

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Postemergence Application:

Up to 11 fluid ounces of XtendiMax® With VaporGrip® Technology per acre may be applied after
sorghum is in the spike stage (all sorghum emerged) but before sorghum is 15" tall. For best
performance, apply XtendiMax® With VaporGrip® Technology when the sorghum crop is in the 3- 5 leaf
stage and weeds are small (less than 3" tall). Use drop pipes (drop nozzles) if sorghum is taller than 8".
Keep the spray off the sorghum leaves and out of the whorl to reduce the likelihood of crop injury and to
improve spray coverage of weed foliage. Applying XtendiMax® With VaporGrip® Technology to sorghum
during periods of rapid growth may result in temporary leaning of plants or rolling of leaves. These effects
are usually outgrown within 10 - 14 days. Delay harvest until 30 days after a preharvest treatment.
Preharvest uses in Texas and Oklahoma only: Up to 11 fluid ounces of XtendiMax® With VaporGrip®
Technology per acre may be applied for weed suppression any time after the sorghum has reached the
soft dough stage. An agriculturally approved surfactant may be used to improve performance (read
Section 8.0 for tank mixing instructions). Delay harvest until 30 days after a preharvest treatment.
Split Application:

XtendiMax® With VaporGrip® Technology may be applied in split applications : preplan! followed by
postemergence or preharvest; or postemergence followed by preharvest. Do not exceed 11 fluid ounces
per acre, per application or a total of 22 ounces per acre, per season.

11 .11 Soybean

For directions for use with crops with Xtend Technology see the "CROPS WITH XTEND TECHNOLOGY"
section of this label.
Preplant Applications:

Apply 5.5 -22 fluid ounces of XtendiMax® With VaporGrip® Technology per acre to control emerged
broadleaf weeds prior to planting soybeans. Do not exceed 22 fluid ounces of XtendiMax® With
VaporGrip® Technology per acre in a spring application prior to planting soybeans.
Following application of XtendiMax® With VaporGrip® Technology and a minimum accumulation of 1"
rainfall or overhead irrigation, allow a minimum of 14 days between treatment and planting for
applications of 11 fluid ounces per acre or less, and allow a minimum of 28 days between treatment and
planting for applications of 22 fluid ounces per acre. These plant back intervals must be observed prior to
planting soybeans or crop injury may occur.
Do not make XtendiMax® With VaporGrip® Technology preplant applications to soybeans in geographic
areas with average annual rainfall less than 25".
Preharvest Applications:

XtendiMax® With VaporGrip® Technology can be used to control many annual and perennial broadleaf
weeds and control or suppress many biennial and perennial broadleaf weeds in soybean prior to harvest
(refer to Section 10). Apply 11 - 44 fluid ounces of XtendiMax® With VaporGrip® Technology per acre as
a broadcast or spot treatment to emerged and actively growing weeds after soybean pods have reached
mature brown color and at least 75% leaf drop has occurred.
Do not harvest soybeans until 7 days after application.
Treatments may not kill weeds that develop from seed or underground plant parts, such as rhizomes or
bulblets, after the effective period for XtendiMax® With VaporGrip® Technology. For seedling control, a
follow-up program or other cultural practice could be instituted.
Do not use preharvest-treated soybean for seed unless a germination test is performed on the seed with
an acceptable result of 95% germination or better.
Do not feed soybean fodder or hay following a preharvest application of XtendiMax® With VaporGrip®
Technology.

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[Optional : Do not make preharvest applications in California.]

11 .12 Sugarcane
Apply XtendiMax® With VaporGrip® Technology for control of annual, biennial, or perennial broadleaf
weeds listed in Section 11. Apply 11 - 33 fluid ounces of XtendiMax® With VaporGrip® Technology per
acre for control of annual weeds, 22 - 44 fluid ounces for control of biennial weeds, and 44 flui d ounces
for control or suppression of perennial weeds.
Use the higher level of listed rate ranges when treating dense vegetative growth.
A single retreatment may be made as needed, however, do not exceed a total of 88 fluid ounces of
XtendiMax® With VaporGrip® Technology per treated acre during a growing season .
Timing: XtendiMax® With VaporGrip® Technology may be applied to sugarcane any time after weeds
have emerged, but before the close-in stage of sugarcane. Applications of 44 fluid ounces of XtendiMax®
With VaporGrip® Technology per acre made over the top of actively growing sugarcane may result in
crop injury.
When possible, direct the spray beneath the sugarcane canopy to minimize the likelihood of crop injury.
Using directed sprays will also help maximize the spray coverage of weed foliage.
Allow a minimum of 87 days between treatment and harvest.

11 .13 Farmstead Turf (noncropland) and Sod Farms
Do not use on residential sites.
For use in general farmstead (noncropland) and sod farms, apply 4.12 - 44 fluid ounces of XtendiMax®
With VaporGrip® Technology per acre to control or suppress growth of many annual , biennial, and some
perennial broadleaf weeds commonly found in turf. XtendiMax® With VaporGrip® Technology will also
suppress many other listed perennial broadleaf weeds and woody brush and vine species. Refer to Table
1 for rate recommendations based on targeted weed or brush species and growth stage.
Repeat treatments may be made as needed; however, do not exceed 44 fluid ounces of XtendiMax®
With VaporGrip® Technology per acre, per growing season.
Apply 30 - 200 gallons of diluted spray per treated acre (3 - 17 quarts of water per 1,000 square feet),
depending on density or height of weeds treated and on the type of equipment used.
To avoid injury to newly seeded grasses, delay application of XtendiMax® With VaporGrip® Technology
until after the second mowing . Furthermore, applying more than 16 fluid ounces of XtendiMax® With
VaporGrip® Technology per treated acre may cause noticeable stunting or discoloration of sensitive
grass species such as bentgrass , carpetgrass, buffalograss, and St. Augustinegrass.
In areas where roots of sensitive plants extend, do not apply more than 5.5 fluid ounces of XtendiMax®
With VaporGrip® Technology per treated acre on coarse-textured (sandy-type) soils, or in excess of 8
fluid ounces per treated acre on fine-textured soils. Do not make repeat applications in these areas for 30
days and until previous applications of XtendiMax® With VaporGrip® Technology have been activated in
the soil by rain or irrigation.

12.0

CROPS WITH XTEND~ TECHNOLOG Y

COTION WITH XTENDFLEX~ TECHNOLOGY (INCLUDING BOLLGARD II~ XTENDFL EX~ COTTON,
BOLLGARD® 3 XTENDFLEX~ COTTON, OR XTENDFLEX~ COTION) AND ROUNDUP READY 2
XTEND~ SOYBEAN CONTAIN A PATENTED GENE THAT PROVIDES TOLERANCE TO DICAMBA,
THE ACTIVE INGREDIENT IN THIS PRODUCT. THIS PRODUCT WILL CAUSE SEVERE CROP

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INJURY OR DESTRUCTION AND YIELD LOSS IF APPLIED TO COTION AND SOYBEAN THAT ARE
NOT DICAMBA TOLERANT, INCLUDING COTTON AND SOYBEAN WITH A TRAIT ENGINEERED TO
CONFER TOLERANCE TO AUXIN HERBICIDES OTHER THAN DICAMBA.
FOLLOW THE
REQUIREMENTS SET FORTH HEREIN TO PREVENT SEVERE CROP INJURY OR DESTRUCTION
AND YIELD LOSS. CONTACT WITH FOLIAGE, GREEN STEMS, OR FRUIT OF CROPS, OR ANY
DESIRABLE PLANTS THAT DO NOT CONTAIN A DICAMBA TOLERANCE GENE OR ARE NOT
NATURALLY TOLERANT TO DICAMBA, COULD RESULT IN SEVERE PLANT INJURY OR
DESTRUCTION.
Information on cotton with XtendFiex3 Technology and Roundup Ready 2 Xtend3 Soybean can be
obtained from your seed supplier or Monsanto representative. Cotton with XtendFiexe Technology and
Roundup Ready 2 Xtend® Soybean must be purchased from an authorized licensed seed supplier.
Note: Cotton with XtendFiex® Technology and Roundup Ready 2 Xtend® Soybean and methods of
controlling weeds and applying dicamba in a Cotton with XtendFiex® Technology and Roundup Ready 2
Xtend® Soybean crop are protected under U.S. patent law. No license to use Cotton with XtendFiex®
Technology and Roundup Ready 2 Xtend® Soybean is granted or implied with the purchase of this
herbicide product. Cotton with XtendFiex® Technology and Roundup Ready 2 Xtend3 Soybean are
owned by Monsanto and a license must be obtained from Monsanto before using it. Contact your
Authorized Monsanto Retailer for information on obtaining a license to Cotton with XtendFiex&
Technology and Roundup Ready 2 Xtend® Soybean.
12.1 Cotton with XtendFiex® Technology

DO NOT combine these instructions with other instructions in the "COTTON" Section of this label for use
over crops that do not contain the dicamba tolerance trait.
TYPES OF APPLICATIONS:
Postemergence (In-crop)

Burndown/Early Preplant; Preplan!; At-Planting;

Preemergence;

USE INSTRUCTIONS
Apply this product in a minimum of 15 gallons of spray solution per acre as a broadcast application. For
best performance, control weeds early when they are less than 4 inches. Timely application will improve
control and reduce weed competition. Refer to the following table for maximum application rates of this
product with cotton with XtendFiex® Technology.

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Maximum Application Rates

88 fluid ounces per acre

Combined total per year for all applications

(2.0 lb. a.e. dicamba per acre)

Total of all Burndown/Early Preplan!, Preplan!, AtPlanting, and Preemergence applications

{1.0 lb. a.e. dicamba per acre)

Total of all In-crop applications from emergence up to
7 days pre-harvest

(2.0 lb. a.e. dicamba per acre)

44 fluid ounces per acre

88 fluid ounces per acre

22 fluid ounces per acre
(0.5 lb. a.e. dicamba per acre)

Maximum In-crop, single application
a.e. - ac1d equivalent

Refer to Table 1 for application rates for weed type and growth stage controlled by this product.
Maximum in-crop application rate should be used when treating tough to control weeds, dense vegetative
growth or weeds with a well-established root system.
Preplant, At-Planting, Preemergence
USE INSTRUCTIONS: This product may be used to control broadleaf weeds and may be applied before,
during or immediately after planting cotton with XtendFiex® Technology. Refer to the "WEEDS
CONTROLLED" section of this label for XtendiMax® With VaporGrip® Technology for specific weeds
controlled.

RESTRICTIONS:
• The maximum combined quantity of this product that may be applied for all burndown/early
preplant, preplan!, at-planting, and preemergence applications is 44 fluid ounces (1.0 lb a.e.
dicamba) per acre per season.
• The maximum application rate for a single, burndown/early preplan!, preplan!, at-planting, or
preemergence application must not exceed 44 fluid ounces (1.0 lb a.e. dicamba) per acre.
•
Do not apply less than 22 fluid ounces (0.5 lb a.e. dicamba) per acre.
Postemergence (In-crop)
USE INSTRUCTIONS: This product may be used to control broadleaf weeds in cotton with XtendFiex®
Technology. In-crop applications of this product can be made from emergence up to 7 days prior to
harvest. The maximum and minimum rate for any single, in-crop application is 22 fluid ounces (0.5 lb a.e.
dicamba) per acre. Using the appropriate application rate may reduce the selection for resistant weeds.
For best performance, control weeds early when they are less than 4 inches. To the extent permitted by
applicable law, Monsanto Company does not warrant product performance of applications to labeled
weeds greater than 4 inches in height. Sequential applications of this product may be necessary to
control new flushes of weeds or on tough-to-control weeds. Allow at least 7 days between applications. A
pre-harvest application of this product may be made up to 7 days before harvest.

Postemergence applications of this product mixed with adjuvants may cause a leaf response to
cotton with XtendFiex® Technology. The symptoms usually appear as necrotic spots on fully expanded
leaves. EC-based products that are tank mixed with products containing dicamba may increase the
severity of the leaf damage.
RESTRICTIONS:
• The combined total applied from crop emergence up to 7 days prior to harvest must not exceed
88 fluid ounces (2.0 lb a.e. dicamba) per acre.

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•
•

•

The maximum single, in-crop application rate must not exceed 22 fluid ounces (O.Sib a.e.
dicamba) .
The combined total per year for all applications must not exceed 88 fluid ounces (2.0 lb a.e.
dicamba) per acre. For example, if a preplant application of 44 fluid ounces (1.0 lb a.e. dicamba)
per acre was made, then the combined total in-crop applications must not exceed 44 fluid ounces
(1.0 lb a.e. dicamba) per acre.
Allow at least 7 days between applications and allow at least 7 days between final application and
harvest or feeding of cottonseed and cotton gin by-products.

12.2 Roundup Ready 2 Xtend& Soybean

DO NOT combine these instructions with other instructions in the ''SOYBEAN" Section of this label for
use over crops that do not contain the dicamba tolerance trait.
TYPES OF APPLICATIONS:
Postemergence (In-crop)

Burndown/Early Preplan!; Preplan!; At-Planting;

Preemergence;

USE INSTRUCTIONS
Apply this product in a minimum of 15 gallons of spray solution per acre as a broadcast application. For
best performance, control weeds early when they are less than 4 inches. Timely application will improve
control and reduce weed competition. Refer to the following table for maximum application rates of this
product with Roundup Ready 2 Xtencf® Soybean.
Maximum Application Rates

Combined total per year for all applications

88 fluid ounces per acre
(2.0 lb. a.e. dicamba per acre)

Total of all Burndown/Early Preplan!, Preplant, AtPlanting, and Preemergence applications

44 fluid ounces per acre
(1.0 lb. a.e. dicamba per acre)

Total of all In-crop applications from emergence up to
and including beginning bloom (R1 stage soybeans)

44 fluid ounces per acre
(1.0 lb. a.e. dicamba per acre)

Maximum In-crop, single application

22 fluid ounces per acre
(0.5 lb. a.e. dicamba per acre)

a.e. - ac1d equ1valent
Refer to Table 1 for application rates for weed type and growth stage controlled by this product.
Maximum in-crop application rate should be used when treating tough to control weeds, dense vegetative
growth or weeds with a well-established root system.
Preplant, At-Planting, Preemergence
USE INSTRUCTIONS: This product may be used to control broadleaf weeds and may be applied before,
during or immediately after planting Roundup Ready 2 Xtenci® Soybean. Refer to the "WEEDS
CONTROLLED" section of this label for specific weeds controlled.

RESTRICTIONS:
• The maximum combined quantity of this product that may be applied for all burndown/early
preplan!, preplan!, at-planting, and preemergence applications is 44 fluid ounces (1.0 lb a.e.
dicamba) per acre per season.
• The maximum application rate for a single, burndown/early preplan!, preplan!, at-planting, or
preemergence application must not exceed 44 fluid ounces (1 .0 lb a.e. dicamba) per acre.
•
Do not apply less than 22 fluid ounces (0.5 lb a.e. dicamba) per acre.

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Postemergence (In-crop)
USE INSTRUCTIONS: This product may be used to control broadleaf weeds in Roundup Ready 2
Xtend® Soybean. In-crop applications of this product can be made from emergence (cracking) up to and
including beginning bloom (R1 growth stage of soybeans). Do not make in-crop applications of this
product after beginning bloom (R1 growth stage of soybeans). The maximum and minimum rate for any
single, in-crop application is 22 fluid ounces (0.5 lb a.e. dicamba) per acre. Using the appropriate
application rate may reduce the selection for resistant weeds. For best performance, control weeds early
when they are less than 4 inches. To the extent permitted by applicable law, Monsanto Company does
not warrant product performance of applications to labeled weeds greater than 4 inches in height.

A second application of this product up to the R1 crop growth stage may be necessary to control new
flushes of weeds. Allow at least 7 days between applications. For best results, apply XtendiMax® With
VaporGrip® Technology after some weed re-growth has occurred.
Application of this product postemergence and under stressful environments may cause temporary loss of
turgor, a response commonly described as leaf droop in Roundup Ready 2 Xtend® Soybean. Typically,
aHected plants recover in 1-3 days depending on the level of droop and environmental conditions.
RESTRICTIONS:
• The combined total application rate from crop emergence up to and including R1 must not exceed
44 fluid ounces (1 .0 lb. a.e. dicamba) per acre.
• Do not make in-crop applications of this product after beginning bloom (R1 growth stage of
soybeans).
• The maximum single, in-crop application rate must not exceed 22 fluid ounces (0.5 lb. a.e.
dicamba) per acre.The combined total per year for all applications must not exceed 88 fluid
ounces (2.0 lb. a.e. dicamba) per acre.
• Allow at least 7 days between final application and harvest or feeding of soybean forage.
• Allow at least 14 days between final application and harvest or feeding of soybean hay.

13.0

WEEDS CONTROLLED

General Weed List, Including ALS-, Glyphosate, and Triazine-Resistant Biotypes
Annuals
Alkanet
Amaranth, Palmer, Powell,
Spiny
Aster, Slender
Bedstraw, Catchweed
Beggarweed, Florida
Broomweed, Common
Buckwheat, Tartary, Wild
BuHalobur
Burclover, California
Burcucumber
Buttercup, Corn, Creeping ,
Roughseed, Western
Field
Carpetweed
Catchfly, Nightflowering
Chamomile, Corn
Chevil, Bur
Chickweed, Common

EPA Reg. No. 524-617

Clovers
Cockle, Corn, Cow, White
Cocklebur, Common
Copperleaf, Hophornbeam
Cornflower
(Bachelor
Button)
Croton, Tropic, Woolly
Daisy, English
Dragonhead, American
Eveningprimrose, Cutleaf
Falseflax, Smallseed
Fleabane, Annual
Flixweed
Fumitory
Goosefoot, Nettleleaf
Hempnettle
Hen bit
Jacobs-Ladder
Jimsonweed

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Knawel (German Moss)
Knotweed, Prostrate
Kochia
Ladysthumb
Lambsquarters Common
Lettuce, Miners, Prickly
Mallow, Common, Venice
Marestail (Horseweed)
Mayweed
Momingglory, lvyleaf, Tall
Mustard,
Black,
Blue,
Tansy, Treacle, Tumble,
Wild, Yellowtops
Nightshade, Black, Cutleaf
Pennycress, Field
(Fanweed, Frenchweed,
Stinkweed)
Pepperweed, Virginia
(Peppergrass)

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Pigweed, Prostrate,
Redroot (Carelessweed) ,
Rough, Smooth, Tumble
Pineappleweed
Poorjoe
Poppy, Red-horned
Puncturevine
Purslane, Common
Pusley, Florida
Radish , Wild
Ragweed, Common, Giant
(Buffaloweed), LanceLeaf
Rocket, London, Yellow

Rubberweed, Bitter
(Bitterweed)
Salsify
Senna, Coffee
Sesbania , Hemp
Shepherdpurse
Sicklepod
Sida, Prickly (Teaweed)
Smartweed, Green,
Pennsylvania
Sneezeweed, Bitter
Sowthistle, Annual, Spiny
Spanish Needles
Spikeweed, Common

Spurge, Prostrate, Leafy
Spurry, Corn
Starbur, Bristly
Starwort, Little
Sumpweed, Rough
Sunflower, Common (Wild) ,
Volunteer
Thistle, Russian
Velvetleaf
Waterhemp, Common , Tall
Waterprimrose, Winged
Wormwood

Biennials
Burdock, Common
Carrot, Wild (Queen Anne's
Lace)
Cockle, White
Eveningprimrose, Common
Geranium, Carolina

Gromwell
Knapweed, Diffuse, Spotted
Mallow, Dwarf
Plantain , Bracted
Ragwort, Tansy
Starthistle, Yellow

Sweetclover
Teasel
Thistle, Bull, Milk, Musk,
Plumeless

Perennials
Alfalfa 1
Artichoke, Jerusalem
Aster, Spiny, Whiteheath
Bedstraw, Smooth
Bindweed, Field, Hedge
Blueweed, Texas
Bursage, Woollyleaf 1 (Bur
Ragweed, Povertyweed)
Buttercup, Tall
Campion, Bladder
Chickweed,
Field,
Mouseear
Chicory1
Clover1 • Hop
Dandelion 1 , Common
Dock 1 Broadleaf
(Bitterdock), Curly
Dogbane, Hemp
DogfenneP (Cypressweed)
Fern, Bracken
Garlic, Wild

Goldenrod, Canada,
Missouri
Goldenweed, Common
Hawkweed
Henbane, Black1
Horsenettle, Carolina
Ironweed
Knapweed, Black, Diffuse,
Russian 1 , Spotted
Milkweed, Climbing,
Common, Honeyvine,
Western Whorled
Nettle, Stinging
Nightshade, Silverleaf
(White Horsenettle)
Onion, Wild
Plaintain, Broadleaf,
Buckhorn
Pokeweed
Ragweed, Western
Redvine

Sericia Lespedeza
Smartweed, Swamp
Snakeweed, Broom
Sorrell, Red (Sheep Sorrel)
Sowthistle1 , Perennial
Spurge, Leafy
Sundrops
Thistle, Canada, Scotch
Toadflex, Dalmatian
Tropical Soda Apple
Trumpetcreeper (Buckvine)
Vetch
Waterhemlock, Spotted
Waterprimrose, Creeping
WoodsorreJl , Creeping,
Yellow
Wormwood, Absinth,
Louisiana
Yankeeweed
Yarrow, Common 1

1
Noted perennials may be controlled using lower rates of XtendiMax® With VaporGrip®
Technology than those recommended for other listed perennial weeds.

Woody Species
Alder
Ash
Aspen
Basswood
Beech
Birch

Blackberry2
Blackgum 2
Cedar2
Cherry
Chinquapin
Cottonwood

EPA Reg . No. 524-617

Master Label October 2017

ER 112

Creosotebush2
Cucumbertree
Dewberry2
Dogwood2
Elm
Grape

Page 38 of 40

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Hawthorn (Thornapple)2
Hemlock
Hickory
Honeylocust
Honeysuckle
Hornbeam
Huckleberry
Huisache
Ivy, Poison
Kudzu
Locust, Black
Maple

Mesquite
Oak
Oak, Poison
Olive, Russian
Persimmon, Eastern
Pine
Plum, Sand (Wild Plum)2
Poplar
Rabbitbrush
Redcedar, Eastern2
Rose 2, McCartney, Multiflora
Sagebrush, Fringed2

Sassafras
Serviceberry
Spicebush
Spruce
Sumac
Sweetgum2
Sycamore
Tarbush
Willow
Witchhazel
Yaupon 2
Yucca 2

2Growth suppression only

14.0

LIMIT OF WARRANTY AND LIABILITY

Monsanto Company warrants that this product conforms to the chemical description on the label and is
reasonably fit for the purposes set forth in the Complete Directions for Use label booklet ("Directions")
when used in accordance with those Directions under the conditions described therein. TO THE EXTENT
CONSISTENT WITH APPLICABLE LAW , NO OTHER EXPRESS WARRANTY OR IMPLIED
WARRANTY OF FITNESS FOR PARTICULAR PURPOSE OR MERCHANTABILITY IS MADE. This
warranty is also subject to the conditions and limitations stated herein. Specifically, and without limiting
the foregoing, MONSANTO MAKES NO RECOMMENDATION OR WARRANTY HEREIN REGARDING
THE USE OF ANY PRODUCTS THAT MAY APPEAR ON THE WEBSITE REFERENCED IN THE TANKMIXING INSTRUCTIONS HEREIN, REGARDLESS OF WHETHER SUCH PRODUCT IS USED ALONE
OR IN A TANK MIX WITH XTENDIMAX® WITH VAPORGRIP® TECHNOLOGY. BUYER AND ALL
USERS ARE SOLELY RESPONSIBLE FOR ANY LACK OF PERFORMANCE, LOSS, OR DAMAGE IN
CONNECTION WITH THE USE OR HANDLING OF ANY SUCH PRODUCT ALONE OR IN A TANK MIX
WITH XTENDIMAX® WITH VAPORGRIP®TECHNOLOGY.
Buyer and all users shall promptly notify this Company of any claims whether based in contract,
negligence, strict liability, other tort or otherwise.
To the extent consistent with applicable law, buyer and all users are responsible for all loss or damage
from use or handling which results from conditions beyond the control of this Company, including, but not
limited to, incompatibility with products other than those set forth in the Directions, application to or
contact with desirable vegetation, failure of this product to control weed biotypes which develop
resistance to dicamba, unusual weather, weather conditions which are outside the range considered
normal at the application site and for the time period when the product is applied, as well as weather
conditions which are outside the application ranges set forth in the Directions, application in any manner
not explicitly set forth in the Directions, moisture conditions outside the moisture range specified in the
Directions, or the presence of products other than those set forth in the Directions in or on the soil, crop or
treated vegetation.
This Company does not warrant any product reformulated or repackaged from this product except in
accordance with this Company's stewardship requirements and with express written permission from this
Company.
For in-crop (over-the-top) uses on crops with XtencJ® Technology, crop safety and weed control
performance are not warranted by Monsanto when this product is used in conjunction with "brown bag" or
"bin run" seed saved from previous year's production and replanted.
TO THE EXTENT CONSISTENT WITH APPLICABLE LAW, THE EXCLUSIVE REMEDY OF THE USER
OR BUYER, AND THE LIMIT OF THE LIABILITY OF THIS COMPANY OR ANY OTHER SELLER FOR
ANY AND ALL LOSSES, INJURIES OR DAMAGES RESULTING FROM THE USE OR HANDLING OF
THIS PRODUCT (INCLUDING CLAIMS BASED IN CONTRACT, NEGLIGENCE, STRICT LIABILITY,

EPA Reg. No. 524·617

Master Label October 2017

ER 113

Page 39 of 40

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OTHER TORT OR OTHERWISE) SHALL BE THE PURCHASE PRICE PAID BY THE USER OR BUYER
FOR THE QUANTITY OF THIS PRODUCT INVOLVED, OR, AT THE ELECTION OF THIS COMPANY
OR ANY OTHER SELLER , THE REPLACEMENT OF SUCH QUANTITY, OR, IF NOT ACQUIRED BY
PURCHASE, REPLACEMENT OF SUCH QUANTITY. TO THE EXTENT CONSISTENT WITH
APPLICABLE LAW, IN NO EVENT SHALL THIS COMPANY OR ANY OTHER SELLER BE LIABLE FOR
ANY INCIDENTAL, CONSEQUENTIAL OR SPECIAL DAMAGES.
Upon opening and using this product, buyer and all users are deemed to have accepted the terms of this
LIMIT OF WARRANTY AND LIABILITY which may not be varied by any verbal or written agreement. If
terms are not acceptable, return at once unopened.
Bollgard Jl®, Bollgard®, Degree Xtra®, Field Master®, Harness®, Roundup Ready®, Roundup Ready 2
Xtend®. Roundup PowerMAX®, RT 3®, Roundup WeatherMAX®, XtendiMax®, XtendFiex® and
VaporGrip® are registered trademarks of Monsanto Technology LLC. All other trademarks are the
property of their respective owners.
EPA Reg. No. 524-617
EPA Establishment No. [insert appropriate est. no.]
Lot number (insert appropriate lot number]
Net contents [insert net contents]
Packed for:
MONSANTO COMPANY
800 N. Lindbergh Blvd.
ST. LOUIS, MISSOURI, 63167 U.S.A.
~~ [DATE)

EPA Reg. No. 524-617

Master Label October 2017

ER 114

Page 40 of 40

  

Registration Decision for the Continuation of
Uses of Dicamba on Dicamba Tolerant
Cotton and Soybean

Approved by: 

1/
Ti; 

Michael Goodis, Director
Registration Division
Of?ce of Pesticide Programs

October 31, 2018

Table of Contents
Contents

I. Summary...................................................................................................................................... 3
II. Chemical Information ................................................................................................................ 4
III. Background ............................................................................................................................... 5
IV. Stakeholder Feedback ............................................................................................................... 6
V. Risk Assessments ....................................................................................................................... 7
A. Human Health ........................................................................................................................ 7
B. Ecological .............................................................................................................................. 8
1.

Dicamba Use During 2017 and 2018 ......................................................................... 10

2.

Summary of Effects Determination for Endangered Species ..................................... 12

VI. Benefits and Impacts Assessments ......................................................................................... 13
A.

Benefits of the Registration of Dicamba OTT Uses Cotton and Soybeans ................... 13

B.

Impacts Assessment ....................................................................................................... 16

VII. Registration Decision ............................................................................................................ 16
A.

Confirmatory Data.......................................................................................................... 19

B.

Required Label Changes ................................................................................................ 19

C.

Terms and Conditions of Registration ........................................................................... 23

D.

Registration Expiration .................................................................................................. 24

E.

Geographic Limitation of the Registration ..................................................................... 24

2

I. Summary
This document announces that the U.S. Environmental Protection Agency (the EPA or the
Agency) will be granting requests by Bayer CropScience (formerly Monsanto Company),
Corteva (formerly DuPont), and BASF to amend their existing conditional registrations that
contain expiration dates of November 9, 2018, and December 20, 2018, respectively. The
existing registrations are for pesticide products containing the herbicide dicamba for use on
cotton and soybeans that have been genetically modified to be tolerant to dicamba in the
following states: Alabama, Arizona, Arkansas, Colorado, Delaware, Florida, Georgia, Illinois,
Iowa, Indiana, Kansas, Kentucky, Louisiana, Maryland, Michigan, Minnesota, Mississippi,
Missouri, Nebraska, New Jersey, New Mexico, New York, North Carolina, North Dakota, Ohio,
Oklahoma, Pennsylvania, South Carolina, South Dakota, Tennessee, Texas, Virginia, West
Virginia, and Wisconsin. Three registrations, EPA Registration Number 352-913, 524-617, and
7969-345, are impacted by this decision. The amendment applications include requests that the
expiration dates be extended to December 20, 2020 along with requests to amend the terms and
conditions of the registration as well as labeling restrictions to further minimize the potential for
off-site movement of dicamba from the treated fields. As of the publication of this decision
document, EPA has reviewed these applications as well as new information and data, and has
decided to extend these registrations until December 20, 2020 adding changes to the registrations
and labeling.
EPA first registered dicamba for applications post-emergent over-the-top (OTT) for soybean and
cotton in 2016, as described in the document Final Registration of Dicamba on Dicamba-Tolerant
Cotton and Soybean (available on regulations.gov, document ID: EPA-HQ-OPP-2016-01870959). EPA Registration Number 524-617 (M1768 Herbicide) was the only registration included
in the 2016 decision; two additional OTT dicamba use registrations were approved after the
publication of the 2016 decision (EPA Registration Numbers 352-913 and 7969-345). The
restrictions for all OTT registrations of dicamba were amended in 2017 to include labeling
restrictions to further minimize the potential for off-site movement of dicamba. The approved
amendments in 2017 continued to include the 2018 automatic expiration dates. These registrations
would have automatically expired, unless EPA acted to extend these dates on all three
registrations for the use of dicamba for OTT applications to dicamba-tolerant soybean and
dicamba-tolerant cotton. As noted above, as of the publication of this decision document, OTT
registrations of dicamba are being extended by approximately two years.
During 2016-2018, EPA received numerous reports of crop injury alleged to be related to offtarget movement of dicamba. EPA's examination of this issue included collaborating with a wide
range of stakeholders. As part of this effort, EPA also made field visits to Arkansas, Iowa,
Nebraska, Georgia, Mississippi, Missouri, and Tennessee to meet with growers, researchers, and
state regulators. After considering all of this information, EPA and the registrants have agreed to
additional label changes intended to further minimize the potential for off-site movement from the
use of these registered products. Further details regarding the Agency's registration extension
decision, required label updates, and the rationale for those mitigation measures can be found in
this decision document.

3

II. Chemical Information
This registration decision refers to all current dicamba registrations for OTT uses on dicambatolerant soybean and dicamba-tolerant cotton. This includes three pesticide products (EPA
Registration Numbers 352-913, 524-617, and 7969-345), as described below.
Chemical Names:
The three pesticide products covered by this decision contain a total of two forms of dicamba, as
seen in Table 1 below:
Table 1. Chemical Name Identification for Dicamba
Chemical Name
Alternate Chemical
Common Name Chemical Abstract
Name
Service (CAS)
Number
Dicamba (benzoic acid,
Diglycolamine salt of Dicamba DGA
104040-79-1
3,6-dichloro-2-methoxy-, dicamba (3,6salt
aka 3,6-dichloro-o-anisic dichloro-o-anisic acid)
acid)
Dicamba: N,N-Bis-(3None
Dicamba
1286239-22-2
aminopropyl)
BAPMA salt
methylamine salt of 3,6dichloro-o-anisic acid
Mode of Action: Dicamba is in the Benzoic Acid family that is used post-emergence for
selective control of broadleaf weeds. Like the phenoxy herbicides, dicamba mimics auxins, a type
of plant hormone and causes abnormal cell growth by affecting cell division.
Registrants: BASF; Bayer CropScience (formerly Monsanto Company); and Corteva
Agriscience (formerly E.I. du Pont de Nemours & Company, aka DuPont)
Product Numbers:
1. EPA Reg. #352-913: FeXapan herbicide Plus VaporGrip Technology
2. EPA Reg. #524-617: M1768 Herbicide (Xtendimax with VaporGrip Technology)
3. EPA Reg. #7969-345: Engenia Herbicide
Summary of Product Information:
The information from this chemical information section is summarized in Table 2 below:
Table 2. Master Table of Dicamba Products Registered for OTT Use
EPA Reg. # Product Name
Registrant Form of Dicamba
352-913
FeXapan herbicide Plus VaporGrip Corteva
DGA salt
Technology
524-617
M1768 Herbicide (Xtendimax
Bayer
DGA salt
with VaporGrip Technology)
4

7969-345

Engenia Herbicide

BASF

BAPMA salt

III. Background
In January 2015, under the Plant Protection Act, the United States Department of Agriculture
(USDA) deregulated the genetically modified dicamba-tolerant cotton and dicamba-tolerant
soybean seeds. This seed was sold commercially in late 2015 and 2016 prior to the pesticide
product registration. In late 2016, following a public comment period, 1 EPA registered dicamba
for use with the dicamba-tolerant trait in soybean and cotton (see Final Registration of Dicamba
on Dicamba-Tolerant Cotton and Soybean, on regulations.gov as EPA-HQ-OPP-2016-01870959). These registrations were time-limited with an automatic expiration date of either
November 9 or December 20, 2018, depending on the registration, unless EPA granted an
extension of this time limitation (EPA Reg. #352-913, 524-617, and 7969-345).
Prior to the 2016 registration actions for dicamba, dicamba uses on soybeans and cotton was
limited to use on preplant and preharvest soybeans and on preplant and postharvest cotton. The
new uses registered in 2016 under FIFRA section 3(c)(7)(B) expanded the current timing of
dicamba applications to post-emergence OTT applications to dicamba-tolerant cotton and
dicamba-tolerant soybean crops. Registrations for the OTT uses were granted only for the three
formulations discussed in this document because the agency has data to show that these
formulations demonstrate lower volatility when compared to other dicamba formulations. It is
important to note that using registered dicamba products on dicamba-tolerant cotton or dicambatolerant soybean crops that are not registered specifically for post-emergence use on dicambatolerant cotton or dicamba-tolerant soybean crops is inconsistent with the pesticide's labeling and
a violation of the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA).
2017 crop injury and label updates for the 2018 season: In 2016, EPA began receiving reports of
crop injury alleged to be caused by off-target movement from the use of dicamba on dicambatolerant cotton and soybeans. Because the registrations for OTT use had not yet been issued,
these incidents were related to illegal use of previously registered dicamba pesticide products. In
2017, over 2,700 official cases of crop damage were reported to state departments of agriculture,
estimated to be over 3.6 million acres of soybeans. 2 There is a lack of scientific consensus
regarding the cause of these reported incidents. Input from state agencies, farm bureaus,
associations, industry, farmers, and non-governmental organizations indicate that causes could
include poor adherence to the label (e.g., not following the label or use of an older more volatile
formulation), physical drift, tank contamination, temperature inversions, and/or volatility. In
response, the EPA worked with the pesticide registrants to strengthen the pesticide label
application directions for the 2018 season to further minimize the potential for off-target
movement.
FIFRA does not require a public comment opportunity for any proposed decision to register a pesticide. EPA took
public comment on its proposed dicamba decision under its public participation policy (see:
https://www.epa.gov/pesticide-registration/public-participation-process-registration-actions). The action taken under
this decision document did not include a public comment opportunity, but EPA did receive over 120 comments from
stakeholders and EPA considered the content of these submissions.
2
Dr. Kevin Bradley Univ. of Missouri,
IPM, https://ipm.missouri.edu/IPCM/2017/10/final_report_dicamba_injured_soybean/
1

5

2018 incidents of crop injury: Information for the 2018 growing season provided by state
agencies and others also included reports of crop injury alleged to be related to off-site
movement of dicamba. All three registrants also submitted adverse effects aggregated reports to
EPA as required by FIFRA section 6(a)(2). The Association of American Pesticide Control
Officials (AAPCO) reported that approximately 1,400 official complaints of alleged dicamba
injury were reported to the state regulatory authorities. Of the 34 states where OTT dicamba use
is registered, only 16 states consistently reported incident information to AAPCO and EPA.
Damage alleged to be related to OTT dicamba applications was reported not only for nontolerant soybeans but also for neighboring trees, orchards, vineyards, berries, orchards, melons,
tomatoes and other vegetable crops. As to reporting of crop injury in general, AAPCO,
university researchers, and some growers believe that these complaints alleged of crop damage
tend to be underreported. These reasons include: fear of losing crop insurance; a desire to
maintain good relationships with neighbors; fear that a damaged crop will be considered
adulterated and cannot be sold; fear that the grower will lose their organic certification; and
grower perception that no action will be taken in response to filing a report. 3 Others believe that
there may be issues of overreporting. These reasons include: damage blamed on dicamba but
actually caused by other chemistries; and damage reports given in terms of acreage that reflects
the size of an entire crop field and not just the portion of the crop field that is actually damaged. 4

IV. Stakeholder Feedback
EPA did not provide a formal public comment period prior to the current decision, but did
receive a variety of comments from the public in the form of calls, emails, and letters concerning
the registered uses for dicamba OTT on dicamba-tolerant cotton and soybeans. The feedback
EPA received included comments both in favor of and opposed to the continued registration of
dicamba OTT uses on dicamba-tolerant cotton and soybeans.
Included in these comments was correspondence from a variety of stakeholders seeking to share
their experience with dicamba, including state agencies (nine commenters), farm bureaus (five
commenters), trade associations and coalitions (42 commenters), industry (62 commenters,
including farmers, seed companies, crop consultants, etc.), non-governmental organizations (888
commenters, including 9 organizations and 879 signatures included as part of a mass comment
campaign), one written comment from academia, and five comments from individual concerned
citizens. These correspondences can be found on regulations.gov (Docket ID: EPA-HQ-OPP2016-0187). The information provided allowed the agency to consider different viewpoints from
their unique perspectives, and EPA reviewed this feedback prior to issuing this regulatory
decision.
Some of the topics that emerged from stakeholder comments and calls, in no particular order,
included the following:
General Comments in favor of OTT registrations of dicamba:

Ford Baldwin, Practical Weed Consultants, LLC, Letter dated 2018
Monsanto. 2018a. The Scientific Basis for Understanding the Off-Target Movement Potential of Xtendimax,
MRID 50642701, received 3 Aug 2018.
3
4

6

-

Requests to extend the registrations but add additional label restrictions in order to decrease
the potential for damage from off-target movement.
Requests to keep the labels as is with no additional restrictions, due to concern that additional
label restrictions for dicamba would increase the regulatory burden for growers.
Growers are experiencing challenges with weed resistance to other herbicides.
Growers have experienced success using dicamba OTT technology in cotton and soybeans to
control weeds with very little off-target movement
Concerns regarding potential crop losses if the decision is made to not continue the
registration.
Claims that mandatory training has been helpful and enable users to follow the existing label
with limited incidents of off-target movement.
An assertion that with proper stewardship, application training, and education, damage from
off-target movement of dicamba can be minimized.
Claims that using a dicamba OTT herbicide system can result in increased yields for
growers.

General Comments expressing concerns and/or opposition to OTT registrations of dicamba:
- Requests to let dicamba OTT registrations of dicamba expire, based on the argument that
although dicamba works well on resistant weeds, the extensive reports of past damage and
potential for future damage from off-target movement is too great to justify continuing the
registrations.
- Other pesticide options are successful at controlling resistant weeds when used properly.
- Claims regarding the limits of training in limiting off-target movement of dicamba.
- Claims that using a dicamba OTT herbicide system does not result in increased yields for
growers.
- Concern that dicamba OTT uses pose a threat to farms growing various non-dicamba-tolerant
crops, and native flora and fauna.
- Some soybean growers report feeling pressured to purchase dicamba-tolerant seed as a
protective measure to avoid dicamba off-target movement from their neighbors.
- They believe that damage from dicamba threatens farmers' right to grow crops of their
choosing, such as specialty and organic crops.
- Concern that off-target movement of dicamba from OTT uses is responsible for injuring
native habitats, forests, aquatic systems, flora, and fauna.
- Two poultry farms stated that reported dicamba damage to non-dicamba-tolerant soybeans
was making it difficult for livestock operations to source non-GMO feed.

V. Risk Assessments
A. Human Health
The potential for human health risks from pesticide uses of dicamba was assessed in EPA's
March 2016 document Dicamba and Dicamba BAPMA Salt: Human- Health Risk Assessment for
Proposed Section 3 New Uses on Dicamba-tolerant Cotton and Soybean (available on
regulations.gov, document ID: EPA-HQ-OPP-2016-0187-0009). This document was cited in the
Agency's 2016 Final Registration of Dicamba on Dicamba-Tolerant Cotton and Soybean
(available on regulations.gov, document ID: EPA-HQ-OPP-2016-0187-0959). As noted in these
7

documents, the toxicology database for dicamba is complete and sufficient for assessing the
toxicity and characterizing the hazard of dicamba.
The Agency's human health risk conclusions for dicamba remain unchanged since the publication
of the 2016 registration decision document for OTT uses on dicamba-tolerant cotton and soybean.
The Agency has not identified a reason to update its 2016 health risk assessment for dicamba, and
is, therefore, relying the findings in that 2016 assessment to support this decision. Because no
human health risks of concern have been identified, the Agency is not proposing new humanhealth focused mitigation measures as part of this decision.
B. Ecological
A summary of the environmental fate and ecological effects, and potential environmental risks
from the use of dicamba on dicamba-tolerant cotton and soybeans was previously provided in
EPA's 2016 Final Registration of Dicamba on Dicamba-Tolerant Cotton and Soybean (available
on regulations.gov, document ID: EPA-HQ-OPP-2016-0187-0959).
Additional ecological risk assessment information on dicamba can be found in the following
Agency documents:
o Ecological Risk Assessment for Dicamba and its Degradate, 3,6-dichlorosalicylic acid
(DCSA), for the Proposed New Use on Dicamba-Tolerant Soybean (MON87708) and
o Ecological Risk Assessment for Dicamba DGA Salt and its Degradate, 3,6dichlorosalicylic acid (DCSA), for the Proposed Post-Emergence New Use on
Dicamba-Tolerant Cotton (MON 87701), and its addendums entitled,
o Addendum to the Environmental Fate and Ecological Risk Assessment for the Section 3
New Use of Dicamba on Dicamba-Tolerant Soybean and
o Dicamba DGA; Second Addendum to the Environmental Fate and Ecological Risk
Assessment for Dicamba DGA salt and its Degradate, 3,6-dichlorosalicylic acid
(DCSA) for the Section 3 New Use on Dicamba-Tolerant Soybean and
o M-1691 Herbicide, EPA Reg. No. 524-582 (Active Ingredient: Dicamba Diglycolamine
Salt) and M-1768 herbicide, EPA Reg. No. 524-617 (AI: Diglycolamine Salt with
VaporGrip(TM)) - Review of EFED Actions and Recent Data Submissions Associated with
Spray and Vapor Drift of the Proposed Section 3 New Uses on Dicamba-Tolerant
Soybean and Cotton.
o Summary of New Information on Analysis of Dicamba Use on Dicamba-Tolerant (DT)
Cotton and Soybean Including Updated Effects Determinations for Federally Listed
Threatened and Endangered Species
These documents are in docket number EPA-HQ-OPP-2016-0187, available at regulation.gov.
EPA's 2016 registration action included a screening-level risk assessment for the use of
diglycolamine salt of dicamba (dicamba DGA) on dicamba herbicide-tolerant cotton and an
addendum to the 2011 Section 3 screening-level Risk Assessment for the use of dicamba DGA
on dicamba herbicide-tolerant soybeans. Concurrent with these two actions, the agency issued
three addenda to the risk assessments that refined the screening-level risk assessments to include
species-specific assessments for threatened and endangered (hereafter referred to as "listed")
species present within the 34 states included in the Section 3 registrations on dicamba-tolerant
crops (Alabama, Arizona, Arkansas, Colorado, Delaware, Florida, Georgia, Illinois, Iowa,
8

Indiana, Kansas, Kentucky, Louisiana, Maryland, Michigan, Minnesota, Mississippi, Missouri,
Nebraska, New Mexico, New Jersey, New York, North Carolina, North Dakota, Ohio,
Oklahoma, Pennsylvania, South Carolina, South Dakota, Tennessee, Texas, Virginia, West
Virginia and Wisconsin).
The screening-level risk assessments concluded that potential direct risk concerns could not be
excluded for:
o mammals (chronic, from the soybean use only, due to residues from dicamba's
metabolite, DCSA, rather than from parent dicamba);
o birds (acute from parent dicamba for both soybean and cotton uses; chronic from DCSA
residues only in soybean but not in cotton), considered surrogates for reptiles, and
terrestrial-phase amphibians; and
o terrestrial plants (soybean and cotton uses)
In the screening-level risk assessments, indirect effect risk concerns for all taxa were possible
for any species that have dependencies (e.g., food, shelter, and habitat) on mammals, birds,
reptiles, terrestrial-phase amphibians, or terrestrial plants.
Additionally, the screening-level assessment showed that direct risk levels of concern were not
exceeded for:
o mammals (acute) and (chronic--for the cotton use only);
o birds, reptiles, and terrestrial-phase amphibians (chronic from parent dicamba or DCSA
degradate from use on cotton);
o terrestrial insects (acute and chronic);
o freshwater fish (acute and chronic);
o aquatic-phase amphibians (acute and chronic);
o estuarine/marine fish (acute and chronic);
o freshwater invertebrates (acute and chronic); estuarine/marine invertebrates (acute and
chronic); and
o aquatic plants (except for non-vascular plants, for which there are no listed species)
In the screening-level cotton risk assessment and soybean addendum as part of the earlier public
comment process, the agency concluded that mitigation measures, including the use of rainfast
mitigation to limit runoff exposure, limiting nozzles to those that restrict droplet spectra to extracoarse and ultra-coarse, restricting applications under certain wind conditions (i.e. only apply
when wind speeds are between 3 and 15 mph), and the use of a 110-foot buffer (for a 0.5 lb
a.i./A application) in the direction of wind to account for spray drift and applying that buffer in
every direction to account for potential volatilization (a discussion of the updates to this
assessment is provided below), would limit any exposures beyond the treated field to levels
below thresholds that would trigger any risk concerns for any taxa. These assessments
concluded that by applying the rainfast mitigation and utilizing the spray drift and volatility
buffer as setbacks from the edge of the field ("in-field buffers"), exposures that could potentially
trigger risk concerns would be limited to the treated field. With these labeling restrictions, EPA
determined that the vast majority of listed species would be off-field and therefore would not be
part of the action area and consequently reached a No Effect decision for those species. Species
that were potentially on the treated field or utilizing resources from the treated field and for
9

which the screening-level risk assessment indicated concerns for that taxa underwent further
refinement to determine the potential for risk.
Subsequent to the screening level risk assessments and refined endangered species addenda, EPA
issued several additional addenda including the evaluation of field volatility (flux) studies for
DGA formulations, bridging data and volatility analysis for dicamba BAPMA salt and an
additional refined endangered species addendum that covered listed species that were newly
listed between the Section 3 registrations of dicamba DGA salt on dicamba-tolerant soybeans
and cotton and the Section 3 registration of dicamba BAPMA salt. The evaluation of the flux
studies for DGA and the volatility analysis for both DGA and BAPMA concluded that volatility
buffer setbacks were not needed to limit exposures off the field to below the threshold level.
By limiting the action area to the treated field, the refined endangered species addenda concluded
that all but 27 listed species were outside of the action area. Overall, of the remaining 27 species,
one likely to adversely affect (LAA) determination was made, two not likely to adversely affect
(NLAA) determinations were made, and no effect (NE) determinations were made for the
remaining species. For one species, EPA consulted with U.S. Fish and Wildlife Service and they
concurred with the NLAA Effects Determination, and no further action was needed for that
species. For the remaining species, county prohibitions restricting use in areas where the species
were known to be present addressed the other NLAA and LAA determinations. Therefore, these
species were no longer inside the action area of the dicamba OTT uses on cotton and soybean.
However, since the 2016 registration of dicamba OTT uses on cotton and soybean, reports of
alleged plant injury in 2017 and 2018 of dicamba off-target movement (either from physical
drift, volatility, or a combination thereof) have led EPA to conduct an updated analysis of
information regarding the potential impact of dicamba OTT uses on soybean and cotton on listed
(threatened or endangered) species. An overview of these new reports of off-target movement, as
well as updated information on potential endangered species concerns from the use of dicamba
OTT registrations, appears in the following sections of this decision document.
1. Dicamba Use During 2017 and 2018
Following the registration of dicamba OTT uses, incident reports received in 2017 and 2018
suggest that damage from off-site movement attributed to dicamba has occurred. According to
AAPCO, approximately 1,400 official complaints have been reported to state agencies claiming
that crop injury was caused by off-site movement of dicamba in 2018. These incidents may be
due to misuse (e.g., not following the label or use of an older more volatile formulation), drift to
adjacent crops or sites, tank contamination (e.g., dicamba was not completely removed from the
spray equipment and is sprayed on the next field at a lower concentration), or volatility (the
dicamba was applied and then moved off the treated area after the application process was
completed). Some pesticide products containing earlier formulations of dicamba have been
known to be volatile (e.g., losing nearly half of the applied material due to volatility (Burnside et.
al., 1966)). Newer formulations of dicamba, such as the products being addressed in this decision
approved for OTT uses, show significantly lower volatility.
After the registration of OTT uses of dicamba, reported cases of agricultural pesticide off-target
movement rose substantially after 2016 in many states where OTT dicamba was registered for
10

use (Figure 1). A large proportion of cases of off-site movement reported to state departments of
agriculture were attributed to off-site movement of OTT applications of dicamba to dicambaresistant crops. Alleged damage reported to state agencies included impacts to natural areas and
numerous crops such as non-tolerant soybean, non-tolerant cotton, tobacco, alfalfa, vegetables,
peaches, ornamentals and residential areas. In soybean alone, millions of acres were alleged to be
damaged in both years since the registration of OTT dicamba products (Bradley 2017c, 2018). In
addition, the Agency is aware of literature and investigations indicating that exposure to dicamba
can have effects on soybean offspring from plants exposed to dicamba, such as reductions in
vigor and health (Thompson and Egli, 1973; McCorn et al., 2016). These cross generational
effects may impact breeding programs and occur in other crops, as well. According to the
AAPCO, university researchers, and some growers, the number of cases reported to state
agencies may be substantially lower than the actual incidents (WSSA Survey, 2018; AAPCO
Pers. Comm. August 13, 2018) observed in the field for several reasons. These reasons include:
fear of losing crop insurance; maintaining good relationships with neighbors; fear that the crop
will be considered adulterated and cannot be sold; fear that the grower will lose their organic
certification; and grower perception that no action will be taken. Others believe that there may be
issues of overreporting. These reasons include: damage blamed on dicamba but actually caused
by other chemistries; and damage reports given in terms of acreage that reflects the size of an
entire crop field and not just the portion of the crop field that is actually damaged. 5
Figure 1. Agricultural Herbicide Drift Complaints for Sixteen States

Monsanto. 2018a. The Scientific Basis for Understanding the Off-Target Movement Potential of Xtendimax,
MRID 50642701, received 3 Aug 2018.
5

11

Reported Herbicide Drift Complaints for 16 States
3500

3000

Number of Complaints

2500

2000

1500

1000

500

0

2013

2014

2015

2016

2017

2018

Majority of states reported total agricultural herbicide drift complaints. States included in this figure are: AL, AR,
AZ, IA, IL, IN, ND, MO, OK, GA, SC, MS, NC, NE, TN, and SD. Incidents occurred in other states for these years
but data were incomplete for every year and were not included. Dicamba is registered for OTT use in 34 states. Data
are current as of September 2018.
Sources: AAPCO 2018; Missouri Dept. of Agriculture, 2018

2. Summary of Effects Determination for Endangered Species
New information that is now available appear to show that dicamba emission (through spray
drift, volatility, or a combination) from the use of these registrations on dicamba-tolerant cotton
and dicamba-tolerant soybean fields has resulted in effects to non-target terrestrial plants offsite
from the treated fields. This new information demonstrated the need to reevaluate the 2016
Endangered Species Act (ESA) effects determinations involving Federally listed threatened or
endangered terrestrial plants for any new regulatory decision involving the use of these
registrations on dicamba-tolerant cotton and dicamba-tolerant soybean fields.
EPA evaluated new data, including field volatility and vapor exposure toxicity studies submitted
by the registrants and large field studies conducted by academic researchers. Additionally, much
of the incident and some of the field study data described effects solely in terms of visual signs
of damage, rather than effects to apical endpoints such as plant height and yield, EPA considered
open literature data relating visual signs of damage to these apical endpoints.

12

EPA concluded that the new information supported the need for an additional in-field 57 foot
omnidirectional buffer in areas where listed dicot plant species are present to support the
previous No Effect calls. This buffer determination was based on a distributional approach
combining the direct effects (based on the most sensitive endpoint of plant height) to distance
data for all the available field studies. Accounting for the small number of studies and limited
geographic distribution, EPA decided to evaluate the distribution of the direct measurement
approach distances at the 95%-tile to calculate a reasonable and protective distance to the 5%
apical effects threshold.
EPA established the geographic extent of the potential action area using the for expected
terrestrial plant effects into Use Data Layers (UDL) for all of the 34 labeled states for dicamba
uses on dicamba-tolerant cotton and dicamba-tolerant soybean. The UDL data layer was
extended outwards 30 meters in all directions to incorporate the off-site distance of 57 foot or a
minimum resolution distance for species action area overlap, whichever is greater. This area was
then compared with the geographic area for the known listed terrestrial plant species ranges and
all counties with a species with greater than 1% overlap with the action area in the county were
established as within the action area and identified as "may affect."
Of the 69 listed species co-located with the action area described as treated cotton and soybean
fields with an additional omnidirectional 30 meter boundary;
1. 69 species would be may-affect with no additional mitigation,
2. 1 species (the spring creek bladderpod) would be May Affect and 68 species would be
No Effect with the imposition of a 57 foot omnidirectional in-field buffer and
3. all 69 species would be No Effects with the imposition of the 57 foot buffer and the
continued labeled county prohibition for Wilson County, Tennessee (for the endemic
spring creek bladderpod)
Of the 14 designated critical habitats co-located with the action area described as treated cotton
and soybean fields with an additional omnidirectional 30 meter boundary;
1. 12 critical habitats would be "Modification" with no additional mitigation and 2 critical
habitats would be "No Modification" by virtue of not having primary constituent
elements related to non-monocot plant species
2. 14 critical habitats would be "No Modification" with the imposition of a 57 foot
omnidirectional in-field buffer
These effects determinations, critical habitat modifications, and mitigation measures have
considered the uncertainties in the analysis as noted throughout the document. These included,
but are not limited to interpreting the incident data (largely due to the nature of incident
observations being limited to visual signs of injury), field study limitations (e.g. varying
environmental conditions in field studies, nature of subjectivity in estimates of visual symptoms
of injury between different observers, etc.), and geospatial analysis (e.g. species are presumed to
be distributed throughout their range at all times of the year).

VI. Benefits and Impacts Assessments
A. Benefits of the Registration of Dicamba OTT Uses Cotton and Soybeans
13

In accordance with FIFRA, EPA must consider both risks and benefits when considering the
registration of a given pesticide. A summary of the benefits of dicamba OTT uses on cotton and
soybeans appears in this section. To see EPA's current assessment of the benefits and impacts of
OTT uses of dicamba, as updated since 2016, please refer to Over-the-Top Dicamba Products for
Genetically Modified Cotton and Soybeans: Benefits and Impacts (October 31, 2018).
As noted in the 2016 Final Registration of Dicamba on Dicamba-Tolerant Cotton and Soybean
(available on regulations.gov, document ID: EPA-HQ-OPP-2016-0187-0959), cotton and
soybeans are extremely important agricultural commodities. USDA estimates the gross value of
soybean production at approximately 48 billion dollars in the United States, and the gross value
of cotton production at over 6 billion dollars in the United States. 6 However, growers throughout
the United States have experienced, and continue to face, crop yield and economic losses due to
the prevalence of chemical-resistant weed biotypes (e.g., glyphosate resistance). There is a need
in the agricultural community for additional tools to manage resistant weeds. Herbicide resistance
has become a significant financial, production and pest management issue for many cotton and
soybean growers, and agriculture as an industry.
Historically, most dicamba applications occurred in late winter or early spring for pre-plant or
fallow removal of broadleaf vegetation prior to planting crops. Prior to the registration of OTT
dicamba on soybeans and cotton, about 35 million acres of agricultural land were treated
annually with 6 million pounds of dicamba (5-yr average; MRD 2012-2016). Field corn and
winter and spring wheat were the agricultural use sites with the largest number of acres treated
with dicamba with an average of 19.8 million total acres treated [TAT] per year (MRD, 20122016). Other use sites with substantial use from 2012-2016 include cotton, fallow land, pasture
land, sorghum, and soybeans (pre-plant only).
The agency finds that the registration of OTT dicamba will provide growers of dicamba-tolerant
soybean and cotton with an additional active ingredient to manage difficult to control broadleaf
weeds during the crop growing season. In cases where there are herbicide-resistant weeds, the
agency finds there are few herbicides available for users.
OTT dicamba product labels list preemergence and postemergence control of weeds such as
Palmer amaranth. Palmer amaranth was selected as a case study because it has several
characteristics that have led to Palmer amaranth being one of the most difficult weeds to control
in the United States (Van Wychen, 2016a) and is a primary target weed by dicamba (MRD, 20122016). The agency recognizes that preemergence (residual soil activity) and postemergence
(foliar activity) herbicides are an important component of a season-long weed management
program. Preemergence herbicides (to the weed) prevent the emergence of Palmer amaranth, and
if there are no emerged Palmer amaranth plants, there is no need for postemergence (to the weed)
applications. However, there are circumstances where postemergence herbicides are important.
For example, postemergence herbicides (to the crop and weed) may be needed if preemergence
herbicides are not effective (e.g., insufficient moisture to activate, too much rainfall which moves

These numbers represent data for 2016. These gross value of production values were first reported in EPA's 2016
assessment for dicamba, Final Registration of Dicamba on Dicamba-Tolerant Cotton and Soybean, and remain the
most recent data currently available as of October 2018.

6

14

herbicide away from weed seeds, and resistant biotypes) or if there are Palmer amaranth plants
that escaped earlier control measures and need to be controlled.
OTT uses of dicamba expand growers' options for broadleaf weed control in cotton and soybeans,
including glyphosate-resistant weeds, but are not the only available tool. Pesticide usage data
indicate 9 postemergence herbicides (to the crop and weed, including directed sprays or
applications with hooded sprayers) were used in 2012-2016 in cotton and 14 herbicides in
soybean targeting all broadleaf weeds. Of these postemergence herbicides, 4 and 13 active
ingredients were applied over-the-top without injuring the cotton and soybean, respectively.
Based on pesticide usage data from 2012 to 2016, glufosinate was an herbicide that was
commonly applied, but there were other options (acifluorfen, cloransulam-methyl, imazamox,
and fluthiacet-methyl) recommended in at least one of the extension weed control guides
reviewed for control of Palmer amaranth (U of Ark, 2018, Steckel, 2018; Sprague, 2017). For
both soybean and cotton, there is one other herbicide, 2,4-D, that provides similar control as
dicamba when using a 2,4-D-resistant variety. Of the 13 OTT soybean herbicides, 3 are not
recommended by extension publications; one was recommended as a tank mix partner only (U of
Ark, 2018, Steckel, 2018; Sprague, 2017; Flessner et al., 2016; Jhala, 2014), effectively leaving 9
OTT herbicides for soybean weed control. Over-the-top alternatives are further reduced if a
grower has herbicide-resistant biotypes such as Palmer amaranth.
Resistance Management
The agency recognizes the use of dicamba, when used as part of a season-long weed
management program that includes preemergence (residual) and postemergence (foliar)
herbicides, provides a long-term benefit as a tool to delay resistance of other herbicides. Fifty
years of dicamba use, in rotation with other herbicides, has resulted in only two confirmed
resistant weed species in the United States, kochia and prickly lettuce (Heap, 2018). However,
with the development of dicamba-tolerant crops, the widespread use and multiple in-season
applications will increase selection pressure on weeds to evolve resistance to dicamba.
However, dicamba used on dicamba-tolerant crops is not a stand-alone herbicide program even
though the label states it has preemergence (soil residual) and postemergence (foliar) activity;
other herbicides, especially preemergence herbicides, should be used as registrants and
university researchers recommend (University of Arkansas, 2018; Steckel, 2018; Flessner et al.,
2016; Sprague, 2017; Jhala, 2014, Mississippi State University, 2017; Marshall, 2017; McGinty,
2016; EPA Reg. Nos. 524-617 [Xtendimax]; 524-617 [Engenia]; and 352-913 [Fexapan]).
Because of the complexities involved with controlling multiple weeds (Xtendimax has over 250
weeds labeled for control), the agency considered one of the more difficult-to-control weeds in
cotton and soybean, Palmer amaranth (Van Wychen, 2016a and 2016b). Palmer amaranth is
native to the U.S. and occurs in 28 states (Hensleigh and Pokorny, 2017), and there are over 50
Palmer amaranth biotypes with resistance to at least one herbicide within 6 MOA groups in the
U.S. (Heap, 2018). Additionally, more than 15 of the biotypes exhibit multiple herbicide
resistance with up to three different herbicides within three different MOA (Heap, 2018). The
agency assumes that Palmer amaranth serves as surrogate for other difficult to control broadleaf
weeds.

15

For this benefits analysis, the baseline is the pre-2016 status of dicamba (i.e., when OTT uses
were not registered for dicamba-tolerant soybean and dicamba-tolerant cotton). When comparing
the baseline against an amended registration in which OTT uses are available for dicambatolerant cotton and soybean, the agency finds the following overall benefits for OTT dicamba:
o It provides growers with an additional postemergence active ingredient to manage
difficult to control broadleaf weeds during the crop growing season, particularly for those
situations where herbicide-resistant biotypes, such as Palmer amaranth, may occur (and
few alternatives are available).
o It provides a long-term benefit as a tool to delay resistance of other herbicides when used
as part of a season-long weed management program that includes preemergence
(residual) and postemergence (foliar) herbicides (along with rotations between different
MOA).
Additionally, as in the case of other genetically modified herbicide resistant varieties (i.e.,
glyphosate, glufosinate, and 2,4-D), the use of the OTT herbicide partner may reduce the
management complexity associated with pre-selecting an effective postemergence herbicide with
little to no risk of damage to the treated crop.
B. Impacts Assessment
Impacts to non-dicamba tolerant soybean growers. Monsanto (now Bayer) predicted that 40
million acres of dicamba-tolerant soybeans would be planted in 2018 (Monsanto, 2018b). USDA
(2018c) reported that 89.6 million acres of soybeans were expected to be planted in 2018. This
implies that 49.6 million acres (55 percent) of the 2018 U.S. soybean crop is non-dicambatolerant and may potentially be damaged by very low levels of off-target dicamba. Exposure can
result in damage levels that range from superficial visual symptomology to possible yield loss to
plant death.
Impacts to growers of other dicamba sensitive crops. Many other plants are sensitive to low
levels of dicamba and are listed on the dicamba labels. The OTT dicamba labels mention several
hundred susceptible (e.g., sensitive) crops /crop groups, such as non-dicamba-tolerant soybeans
and cotton, all fruiting vegetables, all fruit trees, all cucurbits, grapes, beans, flowers and
ornamentals, peas, potatoes, sunflower, tobacco and other broadleaf plants. Labels also list about
250 weeds - annual and perennial broadleaf plants and trees - that are controlled, some of which
are desirable in non-crop settings.
Impacts to the landscape. In 2017 and 2018, state agencies received reports from growers about
incidents alleging damage to trees and other non-crop plants (Bradley, 2017c, 2018; AAPCO
2018a). Potential impacts could result in damage to shelterbelts and windbreaks, as well as
desirable plants in public parks and spaces.

VII. Registration Decision
In accordance with FIFRA section 3(c)(7)(B), the EPA conditionally amends a registration to
add an additional use when it finds that it has satisfactory data pertaining to the proposed new
use and the amendment will not significantly increase the risk of unreasonable adverse effects on
man or the environment, taking into account the economic, social, and environmental costs and
16

benefits of the use of the pesticide. Under FIFRA, the EPA is charged with balancing the
uncertainties and risks posed by a pesticide against the benefits associated with the use of the
pesticide. The EPA must determine if the benefits, in light of its use, outweigh the risks in order
for the Agency to register a pesticide.
While OTT use of dicamba on dicamba-resistant cotton and soybeans is currently a registered
use, that use will expire before the end of 2018 unless these amendment requests are granted.
Therefore, EPA believes it appropriate to consider the extension of these uses as a "new use"
under section 3(c)(7)(B), and is taking this action under that section. But the risk-benefit related
rationale for this decision would apply equally to an action under sections 3(c)(5) or 3(c)(7)(A).
Based on all the information before it at this time, EPA has determined that extending the OTT
use of dicamba for two years on dicamba-tolerant cotton and dicamba-tolerant soybeans in the
manner authorized under this decision will not cause unreasonable adverse effects on the
environment. The amendment would therefore meet the risk-benefit standard of section 3(c)(5).
The risk-benefit standard for a conditional registration under 3(c)(7)(A) is that the registration
not "significantly increase the risk of unreasonable adverse effects on the environment." EPA
has always considered the standard under 3(c)(7)(A) and 3(c)(7)(B) to be less onerous than the
risk-benefit standard in 3(c)(5); if the agency has determined that a pesticide does not cause
unreasonable adverse effects on the environment, that pesticide cannot significantly increase the
risks of unreasonable adverse effects on the environment.
In the case for the post-emergent uses of dicamba on dicamba-tolerant soybeans and dicambatolerant cotton, the EPA determined that its decision to extend the registration these uses meets
the requirements of FIFRA. The database submitted to support the assessment of human health
risk is sufficient for a full risk evaluation and is considered complete and adequate to evaluate
risks to infants and children. The Agency has not identified any risks of concern in regard to
human health, including all population subgroups, or for occupational handlers.
In 2016, EPA completed screening-level ecological risk assessments for the use of dicamba on
dicamba-tolerant cotton and dicamba-tolerant soybeans. In summary, the screening-level risk
assessments concluded that potential direct risk concerns could not be excluded for specific
exposures to mammals, birds and terrestrial plants. In the screening-level risk assessments, EPA
concluded that mitigation measures, including the use of mitigation to limit runoff exposure,
limiting nozzles to those that restrict droplet spectra to extra-coarse and ultra-coarse, restricting
applications under certain wind conditions, and the use of a 110-foot buffer in the direction of
wind to account for spray drift and potential volatilization, would limit any exposures beyond the
treated field to levels below thresholds that would trigger any risk concerns for any taxa. In a
new Endangered Species Assessment, EPA has considered recent and relevant information and
has concluded that the OTT use on dicamba-tolerant soybeans and dicamba-tolerant cotton is
supported by a No Effects determination.
Over the period in which the OTT uses of dicamba have been available, a significant number of
reports of alleged off-site movement have been received from state agencies and agricultural
researchers. The number of separate incident complaints appears to have been greatest in 2017.
During 2018, and in accordance with the agency's requirements, applicators received specialized
training in the safe use of the OTT label. Growers also received a revised label in 2018, which
considered and helped minimize the potential causes of off-site movement. The overall volume
17

of filed incident complaints for 2018 dropped even as more growers adopted this technology in
2018. In this new decision, EPA is further strengthening the OTT label. Notably, there are new
restrictions on the seasonal amount of treatments that can be made. Moreover, within a given
day, the permitted time window for using an OTT application has been narrowed. Overall, these
changes will add greater clarity and structure for this use pattern and continue to further
minimize potential off-site movement.
On the benefits side of the analysis, use of dicamba on dicamba-tolerant soybeans and dicambatolerant cotton is an important part of a resistance management strategy for these crops.
Soybeans and cotton are extremely important agricultural commodities in the United States and
the world. According to the USDA's National Agricultural Statistics Service, soybeans are
grown on approximately 89.6 million acres and cotton is grown on approximately 13.5 million
acres. USDA's Economic Research Service describes soybeans as the world's largest source of
animal protein feed and the second largest source of vegetable oil, and describes cotton as one of
the most important textile fibers in the world, accounting for around 25 percent of total world
fiber use. The United States is the world's leading soybean producer and second leading
exporter, and comprises about 90% of the United States' oilseed production. The United States is
the world's third-largest cotton producer and the leading cotton exporter, accounting for onethird of global trade in raw cotton. The U.S. cotton industry accounts for more than $21 billion in
products and services annually, generating more than 125,000 jobs in the industry sectors from
farm to textile mill. Weed control experts warn that the problem of glyphosate resistance is
increasing, and that significant economic consequences will continue to increase without
effective alternatives for weed control. In addition, the use of dicamba, when used as part of a
season-long weed management program that includes preemergence (residual) and
postemergence (foliar) herbicides, provides a long-term benefit as a tool to delay resistance of
other herbicides as well.
Use of dicamba on dicamba-tolerant soybeans and dicamba-tolerant cotton is beneficial as it
provides an effective tool to treat especially noxious weeds, such as marestail, giant ragweed,
common waterhemp, and Palmer amaranth, including glyphosate-resistant biotypes that threaten
soybean and cotton production today. By adding an effective tool to combat glyphosate-resistant
and other weeds, dicamba can help reduce this difficult weed pressure and aid significantly in
production, reducing economic losses to dicamba-tolerant soybean and dicamba-tolerant cotton
growers. In addition, effective treatment of glyphosate-resistant weeds can help control the
spread of resistance. EPA finds these benefits significant and important for mitigating
production and economic losses for these growers.
After weighing the risks of concern against the benefits of these uses, the EPA finds that when
the requested mitigation measures for these uses are applied, the benefits of the use of the
pesticide outweigh the risks. Therefore, renewing these registrations will not significantly
increase unreasonable adverse effects on human health or the environment. The EPA believes
that the overall considerations for benefits for weed management in these important crops
support a FIFRA Section 3(c)(7)(B) registration finding for amending the registrations
containing these uses.
Therefore, EPA will be extending the registrations for OTT applications of dicamba on dicambatolerant cotton and soybeans (EPA Registration Numbers 352-913, 524-617, and 7969-345), with
18

an automatic expiration date of December 20, 2020. As part of this registration extension, EPA is
requiring additional label restrictions as described in Section VII C: Required Label Changes.
Because the label changes will further restrict the use of OTT dicamba applications, EPA expects
that this registration action will not significantly increase the risk of unreasonable adverse effects
to either human health or the environment.
A. Confirmatory Data
There is uncertainty associated with the existing database for the OTT uses and how they relate
to reported incidents in terms of species effects, field conditions, and primary and secondary offsite movement. Non-guideline field studies examining primary and secondary drift off-target
reporting direct measurements of height and yield from transects in all four cardinal directions
and effects of dicamba-containing agricultural irrigation water on non-target plants are required
to address this uncertainty. These studies would better represent expanded geographic areas
where high numbers of complaints have been logged and ranges of environmental conditions
(e.g., temperature and humidity).
There is an uncertainty in the current analysis as to how well the soybean-based field studies
adequately represent reasonable responses of non-target plants to dicamba exposure. Dicamba
incidents reported to the agency have indicated alleged plant damage to a broad diversity of
plants in ornamental, agricultural and natural landscape settings, and include species of trees,
shrubs and perennials. These types of plant growth and life histories are not represented by the
data submitted as part of the registrant data for the various dicamba products. Non-guideline
ecological effects data on non-target plants (present off the field), including sensitive nonsoybean species, are required to address this uncertainty.
Uncertainties exist in the nature of the effect of pH on tank mixtures and the role of pH of the
applied tank mix solution to resulting volatility and offsite damage. An analysis of all approved
tank mix partners and how they impact the pH of the product would allow EPA to evaluate if this
is occurring. Testing including a series of waters designed to mimic the variety of water pH
throughout the country, particularly in areas with the largest number of incidents, are necessary
in addressing this uncertainty. Therefore, non-guideline studies examining the effect of lower
pH on secondary movement both in terms of the spray tank mixture are required to address this
uncertainty.
B. Required Label Changes
The Agency and the registrants have agreed to certain mitigation language to be included on all
product labels for dicamba OTT uses on cotton and soybean. This includes both enforceable as
well as advisory statements. This new label language supersedes any existing language already
on product labels covering the same topics. Any product being used during the 2019 and 2020
growing seasons must contain a label that includes the new mitigation language that is being
required in association with the approval of this action. Registrants must ensure that any
preexisting language left on labels does not contradict or modify the new mitigation required by
this Registration Decision. The specific labeling requirements for dicamba labels are outlined
later in this section.
The additional new labeling requirements for dicamba OTT uses includes the following: a
limitation on the maximum number of OTT applications of dicamba (two) permitted per field per
19

year for both cotton and soybeans; a prohibition on OTT spraying of dicamba 60 days or later
after planting cotton and 45 days or later after planting soybeans; a time of day restriction
limiting OTT dicamba applications to between one hour after sunrise and two hours before
sunset; a provision that applications may be made only by certified applicators; equipment cleanout requirements; and an omnidirectional application buffer to protect endangered species from
off-target movement of dicamba. These label changes are anticipated to result in a minimal
reduction of the flexibility of growers to use dicamba as a tool for resistance management. The
required labeling changes are expected to further minimize the potential for off-site movement.
However, EPA recognizes the possibility that there may be additional factors which make it
difficult to eliminate all off-target movement of dicamba.
Certified Applicator Provision:
The new label includes a provision that OTT applications of dicamba to cotton and soybeans
may be made only by certified applicators. All dicamba OTT applications are already restricted
use, but current labels allow for applications to be made either by a certified applicator
themselves or "persons under their direct supervision." This decision removes the allowance for
persons under the direct supervision of a certified applicator to make dicamba OTT applications.
Because the agency believes that the complexity of the chemistry warrants ensuring that only the
most highly trained individuals apply it, individuals who are not themselves a certified applicator
may not make an OTT application of dicamba, even under the direct supervision of a certified
applicator. Given the extensive reports of alleged damage from the off-target movement of
dicamba due to failure to follow the label or use the approved OTT dicamba formulation, the
Agency has decided that if dicamba OTT applications are to be preserved as a tool for growers,
only those individuals with the highest level of pesticide application training may make such
applications 7. Restricting dicamba OTT applications to only certified applicators will increase
compliance with label requirements and, in turn, further minimize the potential for off-target
movement.
Limit on Number of OTT Applications:
Limiting the maximum number of applications permitted of a pesticide will help reduce the
number of opportunities for off-target movement from a field to occur. This change does not
impact the previously registered preplant uses. In addition, in the case of soybeans, limiting
applicators to two OTT dicamba applications represents no change from currently allowed
practices. In the case of cotton, however, a maximum of two OTT dicamba applications reduces
by 50% the previously allowed maximum of four applications. Because the maximum in-crop,
single application amount of dicamba that can be applied OTT to cotton will remain 0.5 lb. a.e.
dicamba per acre, the new limit of two OTT dicamba applications for cotton represents a
reduction of the maximum allowed total of all post-emergent in-crop applications from 2.0 to 1.0
lb. a.e. dicamba per acre. EPA does not have information on the number of cotton growers that
have been making more than two OTT dicamba applications per season. However, with less
dicamba allowed to be applied OTT in cotton fields, off-target movement of dicamba from
cotton field should be further minimized.

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The Indiana State Chemist reported that 94 percent of the 2018 cases of alleged dicamba damage to non-target
areas in Indiana involved OTT applications with documented examples of label violations.

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Days after Planting Spray Prohibition:
Dicamba OTT applications to large weeds provide incomplete control and speed the development
of dicamba-resistant weeds by creating an in-field seedbank born from weeds that have bounced
back from a dicamba application. Repeated sub-lethal doses to herbicides are known to promote
the development of resistance. For this reason, EPA recommends that dicamba OTT uses be used
for early season applications rather than late season rescue treatments. Alternative herbicide tools
other than dicamba are available to assist with late season weed control. This decision document
adds a prohibition on OTT spraying of dicamba 60 days or later after planting cotton and 45 days
or later after planting soybeans. Because the majority of dicamba OTT spraying already occurs
within these timeframes, the additional burden on growers is expected to be minimal. For those
applications that would have occurred outside these timeframes, when plant coverage is
significant and the ability of dicamba to reach the soil is reduced, EPA expects to further
minimize the potential for off-site movement.
Sunrise/Sunset Timing Restriction:
A revised time-of-day restriction now requires applicators to limit OTT applications of dicamba
to at least one hour after sunrise and two hours before sunset. This revision is intended to reduce
the possibility of applications being made at times of day when temperature inversions often
occur. Inversions can contribute to off-target damage from pesticides by suspending pesticide
particles in the air and enabling them to migrate long distances before returning to the ground.
All labels with OTT dicamba uses already include advisory language on avoiding inversions and
language prohibiting applications between sunset and sunrise. The revised restriction reduces the
daily allowed application window by three hours, and is expected to lower the potential for offtarget movement of dicamba from physical spray drift but not from volatility. This is because
physical spray drift occurs during or shortly after an application is made, while volatility is a
secondary transport mechanism that can occur, in the case of dicamba, for days after an
application. The new timing restriction will mitigate the scenario of any immediately volatilized
dicamba particles entering an inversion during an application but will not lower the possibility of
volatilized dicamba particles entering any future inversions occurring over a field after an OTT
dicamba application concludes.
Equipment Clean-out Requirements:
Poor hygiene practices for maintaining pesticide application equipment used to spray dicamba
has the potential to result in cross-contamination. Because even trace amounts of dicamba can
cause crop injury, residues that are accidentally left in application equipment can carry over to
subsequent applications to non-dicamba tolerant crops. Equipment clean-out instructions are
already on dicamba OTT labels. By adding new advisory language on the subject of application
equipment hygiene, however, the Agency intends to raise awareness of this issue among
applicators by reiterating the risks of even trace amounts left in the equipment and by offering
additional techniques to ensure all parts of application equipment are cleaned, thereby reducing
the potential for any dicamba incidents caused by improper cleaning of application equipment.
Endangered Species Buffer:
As mentioned, the list of new label statements in this dicamba decision includes an Endangered
Species Protection Requirement of an omnidirectional infield buffer of 110 feet downwind and
57 feet in the other directions. The previously approved label contains a 110-foot downwind
buffer for 0.5 pound active ingredient per acre (220 feet for 1 pound active ingredient per acre
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rate) that will remain on the new label. The addition of a 57 foot buffer in the three other
directions creates an omni-directional buffer. The purpose of the additional buffer requirements
is to protect endangered species that may be near an application site, and, therefore, susceptible
to off-site movement of dicamba. To determine if a particular area is subject to the 57-foot
omnidirectional buffer restriction, applicators must check Bulletins Live! Two (BLT) prior to
making an application. Instructions on how to access Bulletins Live! Two will be included on
the label.
Advisory Language/Best Management Practices:
In addition to enforceable label language, additional guidance in the form of advisory label
language on factors that can influence the potential for off-target movement of dicamba is
expected to be beneficial to applicators. Therefore, EPA is requiring new advisory statements as
well. The categories of advisory language required for dicamba uses on dicamba-tolerant cotton
and soybean include pH, applicator training, and the identification of sensitive areas. A pH
statement is being required because dicamba is more prone to volatilization in acidic
environments. Factors such as the pH of the soil where dicamba is being applied, the pH water
used as a tank mix, as well as the pH of other herbicides or additives used with OTT applications
of dicamba can increase the likelihood that dicamba will volatilize and possibly cause off-target
damage. The additional label revision is intended to clarify existing dicamba training
requirements. Well-trained applicators are less likely to make application errors. By
strengthening training requirements for dicamba, the Agency hopes to minimize human error as a
cause of potential dicamba off-target movement. Finally, advisory language on the subject of
identifying sensitive areas will assist applicators in complying with sensitive area-based buffer
restrictions.
Labeling Requirements for All Dicamba Products Registered for Uses on Dicamba-Tolerant
Cotton and Dicamba-Tolerant Soybeans
New Labeling Requirements for Dicamba OTT Uses:
(1) A maximum number of two over-the-top applications of dicamba is permitted per field
per year.
(2) In cotton: reduce the maximum allowed total amount of dicamba for all post-emergent incrop applications from 2.0 to 1.0 lb. a.e. dicamba per acre.
(3) In cotton: OTT applications of dicamba may not be applied 60 days or later after
planting.
(4) In soybeans: OTT applications of dicamba may not be applied 45 days or later after
planting.
(5) Applications are limited to at least one hour after sunrise and two hours before sunset.
(6) Applications may be made only by certified applicators.
(7) Additional equipment clean-out instructions.
(8) Add an omnidirectional buffer of 57 feet in addition to the downwind buffer in counties
where endangered species are present.
(9) Additional advisory to stress the importance of pH in product volatility.
(10) Additional clarifications on training requirements.
(11) General label edits for clarity.

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C. Terms and Conditions of Registration
As part of its decision to extend registrations for OTT uses of dicamba on dicamba-tolerant
cotton and soybeans, the Agency will require that registrants meet certain terms as a condition of
the registration. These terms will include collecting various data (monitoring, conducting new
scientific studies, etc.).
EPA has evaluated currently available data from the 2017 and 2018 growing seasons regarding
the use of OTT dicamba registrations, but needs to gather additional information as the basis for
making an informed regulatory decision regarding any future use of dicamba for the OTT uses
on cotton and soybean beyond the 2019 growing season. In addition to new data regarding the
environmental fate and effects of dicamba, the Agency is also specifying various monitoring
requirements that will aid EPA in assessing both the market for dicamba products registered for
OTT uses and the impacts of the new mitigation measures included in this decision. The
Agency's new data and monitoring requirements for dicamba are listed below:
Confirmatory Data:
1. Field studies examining off-site movement of dicamba.
2. Studies to investigate temperature effects on volatility of dicamba.
3. Ecological effects data on non-target plants, related to survival, growth and reproduction
for select sensitive tree/shrub/woody perennial species.
4. Studies examining the effect of lower pH on secondary movement both in terms of the
spray tank mixture.
Monitoring Needs for the 2019 and 2020 Growing Seasons:
1. Enhanced incident reporting that aggregates reports of potential damage to non-target
vegetation.
2. Information concerning dicamba-resistant weeds and cases of weed control failure.
3. Information by state and acres regarding the sales of dicamba tolerant cotton and soybean
seed.
4. Information by state and acres regarding sales of product used for OTT dicamba
applications.
As noted in Section VII of this decision, extending the registration of dicamba OTT uses for until
December 20, 2020 will enable EPA to provide cotton and soybean growers with continued
access for at least a limited time for a tool that is important to control glyphosate resistant weeds,
while simultaneously collecting additional data on the impacts of this tool and positioning the
Agency to be responsive to any new findings. Studying the impact of off-target movement from
dicamba OTT applications on high-value specialty crops, as well as privately-owned gardens,
landscaping, and orchards is of particular interest to the Agency, because unlike cotton and
soybean growers, managers of those types of vegetation do not have the option to purchase
protective dicamba-tolerant seed. Finally, by August 2019, USDA information regarding
soybean yields from 2018 should also be available, though yield loss due to a particular
application's off-target movement will be difficult to determine.

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D. Registration Expiration
Although EPA has determined that the benefits of the continued use outweigh the potential risks,
the Agency is requiring expiration dates on EPA Registration Numbers 352-913, 524-617, and
7969-345 that will ensure that the EPA retains the ability to easily modify the registration or
allow the registration to terminate if necessary.
Specifically, this registration automatically expires on December 20, 2020, unless the EPA takes
further action to amend the registration. It is noted that the original registration also involved a
term of registration that acknowledged an expiration of the registration after a five-year period if
weed resistance to dicamba developed at a level that the Agency considered unacceptable.
Therefore, if this automatic expiration date is amended (in whatever way the EPA determines is
appropriate at the time), it shall not be amended to a date later than November 9, 2021, by which
date this registration will automatically expire unless the EPA determines before that date that
herbicide resistance to dicamba is not occurring at unacceptable frequencies or levels, and also
that off-site incidents are not occurring at unacceptable frequencies or levels.
E. Geographic Limitation of the Registration
The list of states in which dicamba may be used as an OTT application on dicamba-resistant
cotton and soybean remains unchanged since the Agency's original registration of this use.
Products registered for use as an OTT application of dicamba on dicamba-tolerant cotton and/or
soybeans may only to be sold and used in Alabama, Arizona, Arkansas, Colorado, Delaware,
Florida, Georgia, Illinois, Iowa, Indiana, Kansas, Kentucky, Louisiana, Maryland, Michigan,
Minnesota, Mississippi, Missouri, Nebraska, New Jersey, New Mexico, New York, North
Carolina, North Dakota, Ohio, Oklahoma, Pennsylvania, South Carolina, South Dakota,
Tennessee, Texas, Virginia, West Virginia, and Wisconsin.

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