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cimectacarb (Primo) NYSDEC Approves Primo Registration 3/94

New York State Department of Environmental Conservation
50 Wolf Road, Albany, New York 12233
                                     MAR 17 1994
Mr. Jerry Harrison, Manager
State Registration and Regulatory Support
Ciba Plant Protection
P.O. Box 18300
Greensboro, North Carolina 27419-8300
Dear Mr. Harrison:
Re:  Registration of Pesticide Product Primo
     (EPA Reg. No. 100-729) in New York State
     The New York State Department of Environmental Conservation (the 
Department) has approved your application to register the referenced 
pesticide product for use as a plant growth regulator on commercial and 
residential turf in New York State. The referenced pesticide product is 
classified as a restricted use pesticide. The restricted use 
registration is due to the complexity of the label directions and our 
concerns about potential impacts on groundwater in New York State.
     The active ingredient in this product, trinexapac ethyl (also known 
as cimectacarb), is a new active ingredient in New York State. This 
Department and the New York State Department of Health reviewed all of 
the information submitted in support of this registration. Our concern 
was for the free acid metabolite CGA-179500 to impact upon groundwater 
quality in New York State, particularly if the product is not used in 
accordance to label directions.
     Primo label directions are written in terms generally 
understandable only to trained pesticide applicators, e.g., ... do not 
exceed a total of 21.4 pints/acre/year. This label limitation would 
require applicators to maintain use records. It is not reasonable to 
expect the public to maintain pesticide use records. The Department, 
therefore, believes that restricted use classification is necessary to 
insure that label directions are met.
     Cimectacarb metabolizes rapidly (< 2 days) to its free acid form 
due to rapid photolysis and microbial activity. The free acid CGA-179500 
appears to be more mobile in soils, and is more persistent than the 
parent compound. Results of a New York field dissipation study showed 
that the rate of dissipation of CGA-179500 slowed substantially over 
time. The slow dissipation results, we believe, were almost certainly 
due to declining air and soil temperatures during late season months, 
and highlight the importance of proper application of Primo during peak 
growing season when microbial activity is high.
     We believe that in New York State Primo will be applied a maximum 
of three times per year, rather than the maximum seven applications 
allowed by the current national label, due to the shorter summer seasons 
in most northern states. Significant leaching of CGA-179500 to 
groundwater appears unlikely if Primo is applied a maximum of three 
times per year at labeled rates.
     It is imperative to the protection of groundwater resources in New 
York State that Primo be applied strictly according to the label 
directions. If used liberally late in the season during cooler 
temperatures when microbial activity is low, the half-life of the parent 
and the free acid may be extended. A longer half-life means that there 
is more available product to impact groundwater resources.
     In view of the above, the Department will approve a restricted use 
registration of Primo. In the event that Ciba Plant Protection does not 
wish to have the product registered for restricted use in New York 
State, the Department is prepared to promulgate a rule reflecting this 
restriction. If this option is pursued, the registration will be issued 
when the final rule becomes effective. The rulemaking process could be 
expected to take from nine months to one year.
     Since this product is classified as a restricted use pesticide, 
please note that New York State Environmental Conservation Law (ECL) 33-
0901.1 states that: ~A commercial permit is required for the 
distribution, sale, offer for sale, purchase for the purpose of resale 
or possession for the purpose of resale of a restricted use pesticide."
     The approved label is the federally registered label as submitted. 
Enclosed are the Certificate of Pesticide Registration and a copy of the 
stamped accepted label for your records.
Please call Ms. Maureen Serafini (518/457-7446), of my staff, if there 
are any questions.
                             Norman H. Nosenchuck, P.E.
                             Division of Hazardous Substances
cc: w/encs. - D. Rutz - Cornell
              D. Rapp - NYS Dept. of Ag. & Mkts.