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desmedipham (Betanex) Specific Exemption Request 2/96

February 8, 1996

Mr. Teung Chin
Acting Team Leader (H7505W)
Emergency Response and Minor Use Section
Registration Support Branch
Registration Division/OPP
U.S. Environmental Protection Agency
401 M. Street, S.W.
Washington, D. C. 20460

Dear Mr. Chin:

Re:  Specific Exemption Request for the Use of Desmedipham
     (Betanex 1.3 EC) for Postemergence Control of Broadleaf
     Weeds in Red Beets

The New York State Department of Environmental Conservation, as the
State lead agency for pesticide matters, hereby requests consideration
of the enclosed request from Cornell University for emergency exemption
under Section 18 of FIFRA, as amended.  The request includes the
information required in t0 CFR Part 166.20.

This is the first request for emergency use of this material in New York
State. AgrEvo USA Company, the manufacturer of Betanex, supports this
request and the efforts of the IR-4 Group at Rutgers University to
obtain a tolerance and develop a residue package for desmedipham in red
beets (Appendix F).

Desmedipham is requested for use in the major red beet agricultural
production areas in New York State to control hairy galinsoga, common
ragweed, redroot pigweed, common lambsquarters, velvetleaf, nightshade
spp., and wild mustard during the 1996 growing season.  Growers whose
fields are infested with these weeds may suffer economic losses from
three sources:  decreased yields from broadleaf weed competition, field
abandonment, and decreased harvester efficiency.

Red beet growers in New York State who have traditionally relied upon
only two or three herbicides (Ro-Neet, Pyramin and Antor) for broadleaf
and grass weed control are without effective alternatives.  Ro-Neet and
Pyramin, the only two currently registered herbicides for use in red
beets, do not control hairy galinsoga or common ragweed, and only give
partial control of lambsquarters and redroot pigweed.  Antor, which
helped to suppress hairy galinsoga populations, is no longer available
to most growers due to cancellation of the federal registration.  Over
the years, especially since the loss of Antor, there has been a critical
need to identify a safe and cost-effective alternative for growers.

Betanex is the first herbicide with postemergence potential for highly-
selective weed control in red beets.  Use of Betanex will allow growers
the option to reduce the use of soil-applied, rainfall-dependent
herbicides like Ro-Neet and Pyramin, and/or it can be used on an as-
needed basis when soil-applied herbicides fail to adequately control
weeds.  The use of Betanex on an as-needed basis will enable growers to
practice integrated pest management (IPM) to a greater extent than they
do now.

A decision on this request is needed as soon as possible.  The
anticipated use season is from May 15 to July 21.  Thank you in advance
for your attention to this matter.

Please contact Maureen Serafini, of our Pesticide Product Registration
Section, at (518) 457-7446 if you need additional information or
assistance.

Thank you.

Sincerely,

Norman H. Nosenchuck, P.E.
Director
Division of Solid & Hazardous Materials

Enclosure
cc: w/enc.:  F. Kozak, EPA Region II
cc: w/o enc.:  W. Smith, Cornell University, PMEP
               R. Mungari, NYS Dept. of Ag & Mkts