desmedipham (Betanex) NYS DEC Letter - Specific Exemption Request for Use on Red Beets 12/03
NYS DEC Letter - Specific Exemption Request for Use on Red Beets 12/03
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
December 10, 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 2004
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 2003 Section 18 use.
Currently registered postemergent herbicides for use against select broadleaf weeds in Red Beets include
Spin Aid and Stinger. Spin Aid controls very small stages of lambsquarters and ragweed. Stinger can control later
growth stages of ragweed and various nightshades. Neither of these products can provide adequate control of other
broadleaf weeds found increasingly in beet fields, such as hairy galinsoga, redroot pigweed, wild mustard and
velvetleaf. A preemergent herbicide which can control hairy galinsoga and redroot pigweed, Dual Magnum, is not
currently registered for use in garden beets and is being submitted as a companion specific exemption request, as
another tool for Integrated Pest Management. Currently registered preemergence herbicides, Ro-Neet and Pyramin, 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 two-leaf stage (i.e., late cotyledon
stage, not fully expanded two-leaf stage), followed by 0.25 to 0.38 and 0.25 to 0.50 lbs ai/acre in the two- to four-
and four- to six-leaf stages, respectively. The final application will not be made later than 50 days prior to harvest.
It is estimated that greater than 50% of the 2,500 acres of red beets expected to be grown in New York State in 2004
may need to be treated with the requested material.
The Department is aware that this is the ninth year that we are requesting desmedipham (Betanex 1.3 EC,
EPA Reg. No. 45639-86 or 264-620) for emergency use to control broadleaf weeds in the major red beet production areas
of New York State. The 2003 exemption, file #03-NY-04, discussed USEPA's 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 was recently extended until June 30, 2005 (Federal Register, Volume 68, Number 122, copy enclosed),
well past the end of the next anticipated use season. Because this tolerance was extended specifically for red beets
grown in New York, we are requesting that the emergency exemption be granted for the 2004 growing season.
Bayer Crop Science, 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 D of enclosure).
Processing red beets are planted from May 1 to June 30, emerging from the soil in seven 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
Bureau of Pesticides Management
cc: w/enc. - A. Enache, USEPA Region II
cc: w/o enc. - W. Smith, Cornell University, PSUR
R. Zimmerman\R. Mungari, New York State Dept. Of Ag. & Mkts.