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daminozide (Alar, B-Nine) EPA Preliminary Determination to Cancel 6/89

The EPA has published a preliminary determination regarding the
registrations of pesticide products containing daminozide based on the
Agency's assessment of the risks and benefits associated with the use of
daminozide as a growth regulator (Federal Register, 5/24/89).  This notice
announces the Agency's preliminary determination to cancel all
registrations of daminozide products that are used on food and to retain
the daminozide non-food uses on ornamentals and bedding plants.  A complete
copy of the determination can be obtained from the Chemicals-Pesticides
                                         W. Smith
                                         Chemicals-Pesticides Program
                                         Uniroyal Chemical Company, Inc
                                         World Headquarters
                                         Middlebury, CT  06749
                                         June 13, 1989
Dear Dr. Donald Rutz:
     On June 2, 1989 Uniroyal Chemical Company, Inc. announced that it
was stopping all sales of daminozide food-use products and agreed with
the United States Environmental Protection Agency to conduct a voluntary
recall.  We are writing now to ask your assistance in publicizing this
effort by distributing copies of the enclosed letter to your county
extension service agents.
     Uniroyal has taken this action to quell public concerns and
confusion regarding the safety of food products treated with daminozide.
Although Uniroyal considers this controversy unfounded, we believe our
action was necessary to protect our customers, including many growers
who are served by your extension service.
     The enclosed letter fully explains the basis for Uniroyal's action,
the terms of the stop-sale program, and indicates how growers may go
about returning existing stocks to their distributors and dealers for a
full refund.  We are mailing the letter to over 30,000 addressees, but
wish to ensure the widest possible distribution to affected growers.
Please assist us by distributing the letter to your agents.
Christopher S. Exton
Marketing Manager, PGR's & Herbicides
                                         Uniroyal Chemical Company, Inc
                                         World Headquarters
                                         Middlebury, CT  06749
                                         June 14, 1989
Dear Grower:
     Effective June 2, 1989, Uniroyal Chemical Company, Inc. voluntarily
halted all sales of daminozide food-use products, and agreed with the
United States Environmental Protection Agency to conduct a voluntary
recall.  We are writing now to encourage you to return all ALAR-85, ALAR
for Grapes, and KYLAR-85 stocks to your dealer or distributor for full
reimbursement at the purchase price.
     As you are aware, the examination by the United States
Environmental Protection Agency of the risks and benefits of daminozide
has been under intense scrutiny from the news media since early this
spring. Although we consider this controversy unfounded, we are very
concerned that it has caused terrible losses for you, our customers, who
purchase and use these products.
     In order to protect our customers and put aside the public
controversy concerning the safety of foods you produce, Uniroyal has
decided voluntarily to stop the sales of all daminozide products
registered for food uses, and to recall all existing stocks and
inventories.  To demonstrate our commitment to this effort, Uniroyal
signed an agreement with EPA that will make the stop-sale and recall
arrangements enforceable until the scientific controversy concerning
daminozide is fully and finally resolved.
Terms of Stop-Sale and Recall Programs
     The Stop-Sale Agreement applies to ALAR-85, ALAR for Grapes and
KYLAR-85, and prohibits Uniroyal from selling these products for use in
the United States until EPA's administrative process for determining
whether to maintain or cancel the daminozide food-use registrations,
including any administrative challenges thereto, are complete.  We
anticipate that the Agency's final determination will be issued by March
1990, and that any challenges to that decision, if filed, would be
complete by September 1991.
     The sale of B-NINE for non-food uses remains lawful.  Uniroyal is
amending its B-NINE registration to delete the previously lawful use on
tomato transplants.  We will be distributing amended labels reflecting
that deletion within the next few weeks.  These new labels should be
applied to all B-NINE products within the channels of commerce no later
than August 19, 1989.
     Uniroyal is conducting this recall program on a voluntary basis at
Uniroyal's own expense.  While the agreement between Uniroyal and EPA is
not binding on distributors, dealers or growers, we strongly encourage
anyone holding stocks of these products to return them to Uniroyal
through the distribution system.  Specifically, we are requesting all
growers to return these products to their distributor(s) or dealer(s).
We have requested all dealers to accept product from growers and
reimburse them at their purchase price for returned product. Similarly,
we have requested our distributors to accept product back from dealers
and growers, and likewise reimburse them and return the inventories to
     Specific details regarding the return of product to us and your
reimbursement will be available shortly through distributors and
dealers. Briefly, we are requesting that you return the product back to
your distributor or dealer. If possible, we request that you provide an
invoice for all product returned. Where invoices are not available, we
are asking the dealer to provide reimbursement at the prevailing sales
price at the time of purchase, we are requesting that all product be
returned by growers by September 30, 1989.
The Future of Daminozide
     Uniroyal strongly believes that daminozide is a safe and useful
product. We have taken these extraordinary measures to stop sales and
recall these products while the scientific controversy regarding this
product is being resolved in order to protect you, our customer, and
allay the public's concerns. We ask for your fullest cooperation in this
Christopher S. Exton
Marketing Manager, PGR's & Herbicides