EPA reviewed the Section 18 request for the use of Kerb 3.3 SC to control dodder and determined our petition did not provide information that establishes an "emergency condition". In order to use a pesticide not labeled for use, a non-routine event must be described and substantiated to confirm that the pest problem rises to the level of an "emergency". EPA acknowledged that while dodder may be a difficult pest to manage, it is a routine condition.
Thus, Kerb CANNOT be applied to cranberry bogs! It is an illegal application. Any questions, please call me.
Hilary Sandler, x 21