Raymond S. Brinkmeyer, Ph.D.
State Regulatory Leader
Regulatory Success - Americas
Dow AgroSciences LLC
9330 Zionsville Road
Indianapolis, Indiana 46268-1054
Dear Dr. Brinkmeyer:
Re: Registration of Special Local Need Labeling for Stinger (EPA Reg.
No. 62719-73) Assigned SLN No. NY-040004
The Department has reviewed your application, received June 17, 2004, to register Special Local Need
(SLN) labeling for Stinger (EPA Reg. No. 62719-73) in New York State. The product contains the active ingredient
clopyralid, monoethanolamine salt (chemical code 117401).
Clopyralid is in the pyridinecarboxylic acid family of chemicals, and is a systemic, auxin type of
growth regulator, disrupting in-plant growth processes by binding receptor sites normally used by the plant's natural
growth hormones. Uptake occurs through both the roots and the leaves.
The Stinger SLN labeling is for postemergence broadleaf weed control in strawberry. The SLN label
specifies one or two applications per year, not to exceed 2/3 pint per acre per year.
Stinger was federally registered in October of 2002 for use on strawberries, however a Section 3
registration has not been sought from state regulatory agencies. Due to the potential for minor and transient crop
injury, Dow AgroSciences has requested a Special Local Need registration with "Special Conditions of Use."
Users are directed to read and accept the "Special Conditions of Use" before opening and using the
product. The user is warned of potential phytotoxicity when the product is used as directed by the SLN labeling.
The Department has received numerous letters of support for the use of Stinger on strawberries.
According to Professor Marvin Pritts of Cornell University's College of Agriculture and Life Sciences' Department of
Horticulture, strawberry growers have very few herbicides available to them, and weed management is the most
significant problem for every grower of matted row berries. Studies have shown that weed management accounts for 50%
of labor costs. Only two preemergent herbicides are available for use in the planting year, and these are mostly
effective against grasses. Since strawberries are grown as perennials in northern climates, broadleaf perennial weeds
rapidly become a problem in many fields. Growers have relied on 2,4-D for management of some of these broadleaf weeds,
but using this product is tricky because of its tendency to interfere with flower bud development, and its limited
scope of activity. Glyphosate is not labeled for use in strawberries as either directed application or as a wipe.
Thistles, in particular, are a serious problem in strawberry fields. Seeds are often introduced on
straw mulch, and thistles are a serious threat to people who frequent U-Pick operations. In field trials conducted by
Cornell University staff, clopyralid was shown to be very effective in controlling thistles and certain other broadleaf
weeds common in strawberry fields, particularly weeds that are tolerant of 2,4-D. Strawberries are tolerant of
clopyralid, and in Canada, it has been used on strawberries for many years. The use of this material would fill an
important niche for strawberry growers.
Due to concerns regarding the potential for groundwater contamination, all currently registered
clopyralid containing products are "Not for sale, use, or distribution in Nassau and Suffolk counties in the state of
The Stinger SLN label also bears the New York State specific language requirement which prohibits the
sale, use, or distribution in Nassau and Suffolk counties in the state of New York.
The maximum application rate of the acid equivalent of clopyralid in New York State is 0.25 lb. per acre
per crop year. The following New York State specific application rate language appears on the main Stinger label: "In
New York State, the maximum application rate for Stinger is 2/3 pint (0.25 lb. acid equivalent of clopyralid) per acre
per growing season. Do not exceed a total cumulative amount of 0.25 lb. acid equivalent of the active ingredient
clopyralid per acre per crop year."
Therefore, under the authority of Section 24(c) of FIFRA, the Department hereby grants a Special Local
Need registration for Stinger (EPA Reg. No. 62719-73) on strawberries. The Special Local Need labeling is assigned SLN
Since Stinger is classified as a "Restricted Use" pesticide in New York State pursuant to 6 NYCRR
326.23(e), the Special Local Need registration is also classified as "Restricted Use." Please note the "YES" under the
"restriction" column on the enclosed Certificate of Pesticide Registration and the "classified for restricted use in
New York State" stamp on the enclosed product label.
As such this product is restricted in its purchase, distribution, sale, use and possession in New York
State. Furthermore, this product may only be purchased and used by a certified applicator in New York State.
According to New York State Department of Environmental Conservation Regulations 6NYCRR 326.3(a): "It
shall be unlawful for any person to distribute, sell, offer for sale, purchase for the purpose of resale, or possess
for the purpose of resale, any restricted pesticide unless said person shall have applied for, and been issued a
Should you require information to obtain a commercial permit, please contact the Pesticide Certification
Section at (518) 402-8748.
The Pesticide Reporting Law (PRL) in the Environmental Conservation Law Article 33 Title 12 requires all
certified commercial pesticide applicators to report information annually to the Department regarding each pesticide
application they make. Commercial pesticide retailers are required to report all sales of restricted pesticide
products and sales of general use pesticide products to private applicators for use in agricultural crop protection.
If no sales are made within New York State, a report still must be filed with the Department indicating this is the
If you need information relating to the Pesticide Reporting Law, or annual report forms, please visit
the Department's website or contact the Pesticide Reporting Section at (518) 402-8765.
The Certificate of Pesticide Registration and a copy of the New York State stamped "ACCEPTED" SLN
labeling for Stinger (SLN No. NY-040004) are enclosed for your records.
The SLN labeling specifies use on strawberries only. All precautionary statements, applicable use
directions, use precautions and limitations of the labeling affixed to the Stinger product container must be followed.
Please be reminded that a copy of the accepted SLN label must be in the possession of the user at the
time of pesticide application.
Please contact Ms. Jeanine Broughel, of my staff, at (518) 402-8768, if you have any questions.
Samuel J. Jackling
Pesticide Product Registration Section
cc: w/enc. - N. Kim/D. Luttinger - NYS Dept. of Health
R. Zimmerman/ R. Mungari - NYS Dept. of Ag. & Markets
G. Good/W. Smith - Cornell University, PMEP