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Desmedipham (Betanex) Specific Exemption Request 1/97

New York State Department of Environmental Conservation
Division of Solid & Hazardous Materials
50 Wolf Road, Albany, New York  12233-7250
518-457-6934     FAX 518-457-0629

CERTIFIED MAIL
RETURN RECEIPT REQUESTED

January 10, 1997

Mr. Rob Forrest
Section Chief (H7505W)
Emergency Response and Minor Use Section
Registration Support Branch
United States Environmental Protection Agency
401 M Street, S.W.
Washington, D. C. 20460

Dear Mr. Forrest:

Re:  Specific Exemption Request for Use of Desmedipham (Betanex Herbicide) for
Postemergence Control of Broadleaf Weeds in Red Beets in 1997

The New York State Department of Environmental Conservation, as the State lead
agency for pesticide matters, requests approval of the enclosed application
under Section 18 of the Federal Insecticide, Fungicide, and Rodenticide Act,
as amended.  The enclosed application includes the information required in 40
CFR Part 166.20.

This request is for the use of Betanex (EPA Reg. No. 45639-86) on red beets
for control of hairy galinsoga, common ragweed, redroot pigweed, and common
lambsquarter, velvetleaf, nightshade spp., and wild mustard in the major red
beet production areas of New York State.  At present, there are no effective,
economical alternative control measures available to red beet growers in.New
York State.

New York State red beet growers have been very concerned with broadleaf weed
control, especially since the registration of Antor was cancelled in 1983, and
the increase in galinsoga and common ragweed populations throughout the State.
Ro-Neet and Pyramin, the only two currently registered herbicides in red
beets, do not control hairy galinsoga or common ragweed, and only give partial
control of common lambsquarter and redroot pigweed.

Additionally, their reliance on adequate moisture conditions for activation
creates a risk for growers, who have few, if any, alternatives for salvaging
weed control when failure occurs.  When broadleaf weed infestations occur,
growers suffer economic losses due to decreased yields from weed competition,
field abandonment, and decreased harvester efficiency.

There is a critical need for growers in New York State to have a safe and
cost-effective alternative control measure for use in red beets in 1997.

The data support that Betanex used on an as-needed basis improves control of
many problematic broadleaf weeds in red beets, particularly hairy galinsoga
and common ragweed.  Also, Betanex gives growers the capability to control in-
the-row weeds on an as-needed basis without having to rely on handweeding,
which is costly, or chopping weeds just prior to harvest, which results in
yield losses due to competition and can be costly as well.

This is the second year that we are requesting Betanex for emergency use in
New York State.  AgrEvo USA Company, manufacturer of Betanex, is in full
support of this Section 18 request and is willing to assist in the development
of a package for Betanex on red beets under the IR-4 process.  Several residue
field trials were conducted in 1996 and are in the process of being analyzed.
IR-4 anticipates the analysis of the samples to be completed by early 1997.
IR-4 is working to establish a tolerance for desmedipham on red beets as soon
as possible (Appendix F).

As a point of clarification to Section 3.v. of the enclosed application, it is
estimated that approximately 2,000 acres of red beets will need to be treated
with Betanex in New York State in 1997.  Three applications of Betanex at the
highest requested rates will result in 1,625 gallons of product or 2,260 lbs
of active ingredient to be applied in New York State during the 1997 growing
season.

The anticipated use season is from May 15 to July 21.

Please contact Frank Hegener, of our Pesticide Product Registration Section,
at (518) 457-7446 if you need additional information or assistance regarding
this request.

Thank you for your attention to this matter.

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