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Desmedipham (Betanex)
NYS DEC Letter - Specific Exemption Request for Use on Red Beets 1/03



New York State Department of Environmental Conservation
Division of Solid and Hazardous Materials

Bureau of Pesticides Management, 9th Floor
625 Broadway, Albany, New York 12233-7254
Phone: (518) 402-8788     FAX: (518) 402-9024
Website: www.dec.state.ny.us

January 15, 2003

Mr. Dan Rosenblatt
Acting Team Leader
USEPA / Office of Pesticide Programs
Emergency Response Team (7505C)
Document Processing Desk
Crystal Mall 2-- 2nd Floor
1921 Jefferson Davis Hwy.
Arlington, Virginia 22202

Dear Mr. Rosenblatt:

Re: Specific Exemption Request for Use of Desmedipham (Betanex 1.3 EC, EPA Reg. No. 45639-86) for Postemergence Control of Broadleaf Weeds in Red Beets in 2003

    The New York State Department of Environmental Conservation (Department), as the State lead agency for pesticide matters, hereby requests approval of the referenced application (see enclosure) under Section 18 of the Federal Insecticide, Fungicide and Rodenticide Act, as amended. The enclosed application includes the information required in 40 CFR, Part 166, Subpart B (166.20). Also enclosed is the use report from the 2002 Section 18 use.

    The one currently registered postemergence herbicide, Spin-Aid, is only effective against early growth of some broadleaf weeds and is not effective against pigweed or hairy galinsoga. Other postemergent herbicides, such as Stinger, are only registered for use on sugar beets. Growers still have no other postemergence herbicide weed control options available to them. Registered pre-emergence herbicides often fail to provide adequate control of troublesome broadleaf weeds due to their dependency on rainfall for activation. The lack of control, coupled with the inability to eliminate in-row weeds with cultivation, results in the majority of beets requiring expensive chopping at harvest to remove weeds.

    Studies have consistently shown that Betanex provides good to excellent control of many important broadleaf weeds (Appendix B). With Betanex, growers are able to control in-row weeds without costly hand weeding or yield losses due to competition. Betanex can be used on an as-needed basis when soil-applied, rainfall-dependent herbicides fail to adequately control weeds. This form of selective application will enable growers to practice integrated pest management to a greater extent than they now do.

    The use of up to three applications of Betanex per season is requested. The first application will be made at 0.125 to 0.25 lbs. ai/acre when the red beets are in the cotyledon to 2-leaf stage (i.e. late cotyledon stage, not fully expanded 2-leaf stage), followed by 0.25 to 0.38 and 0.25 to 0.50 lbs ai/acre in the 2 to 4- and 4 to 6-leaf stages, respectively. The final application will not be made later than 75 days prior to harvest. It is estimated that greater than 50% of the 2500 acres of red beets expected to be grown in New York State in 2003 may need to be treated with the requested material.

    The Department is aware that this is the eighth year that we are requesting desmedipham (Betanex 1.3 EC, EPA Reg. No. 45639-86) for emergency use to control broadleaf weeds in the major red beet production areas of New York State. The 2002 exemption, file # 02-NY-01, discussed the United States Environmental Protection Agency's (USEPA) concerns about progress toward a Section 3 registration, due to the fact that desmedipham is an aryl carbamate. However, the time-limited tolerance originally established in 1998 does not expire until December 31, 2003, well past the end of the next anticipated use season. Because this tolerance is already in place, we are requesting that one more season of the emergency exemption be granted.

    Aventis Crop Science (Bayer), the manufacturer of Betanex 1.3 EC, fully supports our efforts to obtain an emergency exemption for the use of Betanex on red beets in New York State. The National Interregional Research Project No. 4, IR-4, continues to work to establish a tolerance for desmedipham on red beets as soon as possible and needs only for the USEPA to include the project in their work plan (see Appendix C of enclosure).

    Processing red beets are planted from May 1 to June 30, emerging from the soil in 7 to 14 days, and are ready to harvest 90 to 110 days later. The anticipated use season for desmedipham in New York State is from May 15 to August 15.

    Please contact Robin Hackett, of our Pesticide Product Registration Section, at (518) 402-8768 if you require further assistance on this request.

Sincerely,

Maureen P. Serafini
Director, Bureau of Pesticides Management
Division of Solid & Hazardous Materials

Enclosure
cc: w/enc. - A. Enache, EPA Region II
cc: w/o enc. - G. Good\W. Smith, Cornell University, PMEP
R. Zimmerman\R. Mungari, New York State Dept. Of Ag & Mkts.