The Training manual for the those that audit labels discloses that they can play it pretty loose regarding submission of printed (production) labels for review.
Text in their manual suggests that in certain instances printed (production) labels may not need to be submitted. The manual does not readily disclose what those instances are.
Years ago they used to add a copy of the "production labels" to the online labels database and they were stamped "Specimen".
I have found no such labels post the 90s for even popular herbicides ie Crossbow and Roundup.
There are archive sites for "production" labels at WSU and elsewhere.
List of crops
Crop groups are established when residue data for certain representative crops are
used to establish pesticide tolerances for a group of crops that are botanically or
taxonomically related. Representatives of a crop group or subgroup are those crops
whose residue data can be used to
establish a tolerance on the entire crop group or subgroup.
The Master Label for Callisto references crop group 13b when is states that not all cultivars in that group were tested for tolerance. Raspberry (crop group 13a subgoup 13-07A s not included in that group.
The production label makes no reference to cultivars not tested, Printed labels are not required to contain all information found on the Master Label save it interferes with the safe use of the product.
There are no cultivars ie "Meeker" disclosed in the crop listings. Typically the crop groupings only break plants down taxonomically to the level of varieties but not cultivars.
By interpretation of the reason crop groups are established, it could be inferred that all red rapberry should have tolerance.
However various studies have shown that various varieties of red raspberry do not have tolerance. The underlying factors can be many ranging from
weather conditions, field conditions, presence of disease in the soil, stage of growth cycle at time of testing...
Several Universities have disclosed various degrees of damage caused by Callisto to Raspberry especially at higher application rates but even at 3 ozs per treated acre which is the lower limit advised damage has been noted in the 20 pct region.
Locally per Bagwell's suggestion the growers applied Callisto at 5 ozs per treated acre.
Raspberry is listed under 13-07A and is not a member of 13B
Screenshot from epa Crop Groups.
Bagwell's Suggestion for whatever reason led to the growers experiencing the damage experienced.
Bagwell also knew they were using tank mixes.
Whether he directly addressed that they should add Callisto to a tank mix is unclear to me at this time. Callisto is used in tank mixes for other crops but by the letter of the label law one is not in conformance if you use a chemical not in conformance with the label for that specific crop in which case Bagwell may be responsible for them not using Callisto in conformance with the label law.
According to pesticide label law, a pesticide can only be used in a tank mix with another product if the label explicitly allows for such a combination, meaning it must specifically list the compatible tank mix partners or state that the product can be tank mixed with other registered pesticides that also permit tank mixing on their labels; essentially, "the label is the law" when it comes to tank mixing pesticides.
However....
EPA will usually approve tank mix label claims without supporting compatibility and residue data if the following conditions are met: The site(s) or crop(s) for which tank mix claims are made are registered crops or sites for all pesticides recommended in the mix.
It can be construed from training and seminar videos that using Callisto alone or in tank mixes on red raspberry should be approached with caution.
Tank mix training videos suggest that Field Men are not to be relied upon and that growers should do their own tests before applying new chemicals to mixes.
Those tests include minimally a jar test. (in the case of such a "hot chemical" a jar test probably would not have disclosed much. Beyond that a test on a smaller area is more than warranted before administrating it to a whole field. Various tests conducted in the region with tank mixes showed that there was cause for concern. Some plantings experienced little or no damage while others lost 20 pcof the crop. Those experiences were not confined to just the PNW.