Raymond S. Brinkmeyer, Ph.D.
State Regulatory Leader
Dow AgroSciences, LLC
9330 Zionsville Road
Indianapolis, Indiana 46268-1054
Dear Dr. Brinkmeyer:
Re: Denial of Application to Register a Major Change in Labeled (MCL) Use Pattern for the Active Ingredient Sulfuryl
Fluoride Contained in the Pesticide Product ProFume™ (EPA Reg. No. 62719-376)
The New York State Department of Environmental Conservation (Department) has reviewed the application
and data package submitted by Dow AgroSciences, LLC (Dow Agro) in support of the application to register ProFumeTM (EPA
Reg. No. 62719-376) containing the active ingredient sulfuryl fluoride.
ProFume™ (99.8% sulfuryl fluoride) is a pressurized fumigant labeled for control of
postharvest insect and rodent pests in or on certain stored commodities. Fumigation sites include nonresidential
structures (for the food commodities listed on the label) such as mills, warehouses, stationary transportation vehicles
(railcars, trucks, etc., excluding aircraft and passenger railcars), temporary and permanent fumigation chambers, and
One product containing sulfuryl fluoride is currently registered in New York State for fumigation of
structures for control of termites under the brand name Vikane™ (EPA Reg. No. 62719-4). The use on stored
food commodities represents a major change in labeled (MCL) use pattern for sulfuryl fluoride. The Department has not
previously conducted a toxicological and health effects evaluation of this active ingredient.
In a letter dated August 12, 2004 (copy enclosed), the Department notified Dow Agro that the major
change in labeled (MCL) use pattern application was incomplete and allowed 45 days from receipt of the letter for
submission of the requested information. Per your request, two extensions of 45 days and 60 days were granted. The
most recent due date was January 25, 2005. As of the date of this letter, the Department has not received the
information required to proceed with a technical review of the subject application.
Since the Department is required to operate under legislatively mandated time frames, and there is no
indication as to when the required information will be available, the review has been terminated and the subject MCL
Please note that the application fee is nonrefundable. If you wish to reapply, a new MCL application, application fee
and information specified in 6 NYCRR Part 326.17 must be submitted. The application should be resubmitted only when
the information requested in the Department's August 12, 2004 incompleteness letter is available.
Please be aware that ProFume™ (EPA Reg. No. 62719-376) may not be sold, offered for sale,
distributed, or used in New York State.
If you have any questions on this matter, please contact me, at (518) 402-8768.
Samuel J. Jackling
Pesticide Product Registration Section
cc: w/enc. - N. Kim/D. Luttinger, NYSDOH
W. Smith, Cornell University, PSUR