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triflumizole (Terraguard, Procure) Major Label Change 3/96

New York State Department of Environmental Conservation
Division of Solid & Hazardous Materials
50 Wolf Road, Albany, New York  12233-7250
Phone 518-457-6934    FAX 518-457-0629

March 26, 1996

Ms. Judith O. Ball
Pesticide Registration
Uniroyal Chemical Company, Inc.
74 Amity Road
Bethany, CT  06524-3402

Dear Ms. Ball:

Re:  Registration of Procure 50WS Fungicide (EPA Reg. No.400-431) a
     Major Change in Label for the Active Ingredient Triflumizole

The New York State Department of Environmental Conservation
(NYSDEC) has accepted your application for the registration of
the pesticide product Procure 50WS Fungicide (EPA Reg. No. 400-431)
containing the active ingredient, triflumizole in New York State.
Procure 50WS is the identical formulation to Terraguard 50W (EPA Reg.
No. 400-433) which is registered in New York State for use on
ornamentals grown in enclosed commercial structures.  Procure 50WS is
labeled to control powdery mildew and scab on apples, pears, and
grapes.  The proposed use on a food crop represents a major change in
labeling for triflumizole.

Procure SOWS (EPA Reg. No. 400-431) is a broad-spectrum foliar fungicide 
used to control diseases on apples, pears, and grapes.  Procure is 
applied by ground to grapes at a single rate of 0 25 lb. ai/acre and a 
seasonal rate of 1 lb. ai/acre.  It is applied to apples and pears by 
ground or air at a single rate of 0.5 lb. ai/acre and a seasonal rate of 
2 lb. ai/acre.  Procure 50WS contains 50h triflumizole.

The data package for this product was reviewed by the Division of Fish & 
Wildlife (DF&W), the Geotechnical Support Section (GTS), and the New 
York State Department of Health (NYSDOH).

The DF&W Bureau of Environmental Protection (BEP), in a memorandum dated 
November 27, 1995, did not object to registration.  Studies conducted 
with triflumizole indicate that it is not toxic to mammals on an acute 
basis, birds on an acute or chronic basis, honeybees and fish on an 
acute basis at the single application rate, or to invertebrates on an 
acute or chronic basis.  The Pesticide Screening System's Aquatox runoff 
model shows exceedence levels for acute and chronic toxicity to rainbow 
trout at the maximum application rate.  However, triflumizole will not 
remain in the water long enough to accumulate to the maximum rate from 
repeat applications.  The Mamtox model shows an exceedence level for 
reproductive toxicity to mammals feeding on short grass.  As the mean 
field dissipation rate for triflumizole is eight days, chronic toxicity 
is not likely to occur.  Labeled uses of Procure 50WS Fungicide should 
not adversely impact the fish and wildlife resources of New York State.

The NYSDOH stated in their review, dated February 27, 1996, that in the 
past they had evaluated triflumizole in the pesticide product Terraguard 
50WS and did not identify any significant toxicological concerns.  A 
current search of the literature did not find any significant new 
information on the toxicity of triflumizole.

Triflumizole has some of the properties of a chemical with leaching 
potential in vulnerable soils.  NYSDOH has stated in a previous review 
that if the registrant seeks outdoor use registration, the potential for 
groundwater contamination must be evaluated.  There are no chemical-
specific federal or State drinking/ground water standards for 
triflumizole.  Based on its chemical structure, triflumizole falls under 
the 50 micrograms/liter New York State drinking water standard for 
"unspecified organic contaminants" (10 NYCRR Part 5 - Public Water 
Systems).

The USEPA established tolerances for triflumizole residues of 0.5 parts 
per million (ppm) in or on apples and pears and 2.5 ppm in or on grapes.  
Tolerances have also been established for milk, eggs, and a number of 
meats, fats and meat by-products.  The USEPA estimated that the 
Theoretical Maximum Residue Contribution (TMRC) from established 
tolerances was 0.0022 mg/kg/day for the general population (15 percent 
of the USEPA reference dose).  The TMRC for the subgroup most highly 
exposed, non-nursing infants less than one year old, utilizes 61 percent 
of the reference dose.  These exposure estimates may be overestimates as 
they assume that all food commodities contain residues at the tolerance 
level.  Residue data submitted with the registration package indicate 
that triflumizole residues in crops treated at the maximum labeled rate 
are considerably less than the tolerances.

Based on their evaluation of the toxicity of triflumizole and the 
residue data for treated crops, NYSDOH did not object to the use of 
Procure 50WS Fungicide (EPA Reg. No. 400-431) on apples, pears and 
grapes in New York State.

The GTS stated in their review, dated February 5, 1995, that the labeled 
use of Procure 50WS should not cause a groundwater impact in New York 
State when used according to label directions because the labeled use is 
a foliar application to grapes, apples, and pears, and results in a 
negligible amount of product reaching the turf.  If the registrant 
should choose to apply to the Department for registration of 
triflumizole for turf, further information would be needed.

Because no groundwater data was submitted, the LEACHM model was run 
using the Riverhead soil type, typical of Long Island soil, with 
application to bare ground.  The model indicated no problems from 
triflumizole associated with the Riverhead type soil, but modeling of 
the degradate indicated that further information is needed before any 
proposed use on turf is registered.  Using Procure 50WS on direct 
application to upstate soils, which are typically much higher in organic 
content, would also require the same information.  However, the GTS does 
not object to the labeled use of Procure 50WS because this registration 
is for foliar applications and not for turf.

Should Uniroyal plan to expand use of this product to turf or crop use, 
the following items must be included with the registration application:

          Environmental fate data for the degradates including
          KoC, KoW, Kd and t1/2 aerobic metabolism for different 
          soil types, aqueous solubility, tl/2 photolysis and tl/2
          hydrolysis.

          Data from a groundwater monitoring study that includes
          degradates.  Locations should include a low-organic soil
          location as well as Untypical" upstate growing conditions.

After consideration of the reviews by NYSDOH, FEW, and by GTS, the 
Department accepted for registration the pesticide product Procure SOWS 
Fungicide (EPA Reg. No. 4000-431) containing triflumizole for use in New 
York State as labeled.

Enclosed for your records are the stamped-accepted label and the 
certificate of registration for the above pesticide product.

If you have any questions on this matter, please contact Maureen 
Serafini, Supervisor of our Pesticide Product Registration Section, at 
(518) 457-7446.

Sincerely,




Norman H. Nosenchuck, P.E.
Director
Division of Solid & Hazardous Materials

Enclosures

cc: w/enc. - D. Rutz/W. Smith, Cornell University
             N. Rudgers, NYS Dept. of Ag. & Mkts.
             N. Kim/A. Grey, NYS Dept. of Health