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vinclozolin (Ronilan) NYSDEC Concerns Section 18 for Ronilan 1/94

New York State Department of Environmental Conservation
50 Wolf Road, Albany, New York 12233
                                    January 26, 1994
TRANSMITTED VIA FAX
____________________
Mr. William G. Smith
Senior Extension Associate
Cornell Cooperative Extension
Pesticide Management Education Program
5123 Comstock Hall
Ithaca, NY  14853-0901
Dear Mr. Smith:
Re:       Request for Section 18 Emergency Exemption for Use of
          Vinclozolin (Ronilan) to Control White and Gray Mold on
          Snap Beans in 1994
     This letter is to confirm the content of your telephone 
conversation with Teresa Foster, of my staff, regarding the referenced 
subject matter. Based on our review of the Section 18 request received 
from Cornell University, we have the following additional questions and 
recommendations.
     Researchers at Cornell University must address the steps that are 
being taken to delay the buildup of resistance to Ronilan. Are growers 
using a spray program which alternates Ronilan use with other registered 
fungicides? Are there use patterns by growers which encourage 
development of resistance? The need to address these issues was one of 
the original requirements from this Department transmitted in a letter 
dated July 9, 1993.
     This is the twelfth year that this use of Ronilan has been 
requested; resistant strains of Botrytis gray mold (BGM) and Sclerotinia 
white mold (SWM) have already been detected. We feel, therefore, that 
information on resistance is pertinent to our decision to forward this 
request to EPA.
     The requirement, too, is based on one of the conditions in the EPA 
document dated January 26, 1993 (copy enclosed). In this document, EPA 
indicates that for consideration of future requests for vinclozolin for 
this use, States must address, to the fullest extent possible, "a plan 
to manage the potential development of BGM and or SWM resistance to 
Ronilan."
     In a related issue, the individual grower records for Ronilan for 
the 1993 growing season have not been received by this office as of 
today. The requirement to submit these records by December 31, 1993 was 
included in the July 9, 1993 letter. Please submit these records as soon 
as possible, if you have not already done so.
     If you have any questions on these matters, please contact Teresa 
Foster, of my staff, at (518) 457-7446.
                                    Sincerely,
                                    Maureen P. Serafini
                                    Supervisor
                                    Pesticide Product Reg. Section
                                    Division of Hazardous
                                    Substances Regulation
Enclosure
cc:  T. Foster