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flumetsulam (Broadstrike) NYS DEC Letter - Runoff Study 3/98


New York State Department of Environmental Conservation
Division of Solid & Hazardous Materials 
Bureau of Pesticides & Radiation 
Pesticide Product Registration Section
50 Wolf Road, Albany, New York 12233-7257 
Phone 518-457-7446	FAX 518-485-8990
 
March 4, 1998


CERTIFIED MAIL
RETURN RECEIPT REQUESTED


Dr. Robert D. Vatne
State Regulatory Affairs Manager 
Dow AgroSciences LLC
308 Building/3E 9330 
Zionsville Road 
Indianapolis, IN 46268-1054


Dear Dr. Vatne:


Re:  Runoff Study for Flumetsulam


On December 14, 1994, the Department conditionally registered two products, Broadstrike + 
Dual (EPA Reg. No. 62719-239) and Broadstrike + Treflan (EPA Reg. No. 62719-222), 
which contain flumetsulam (Broadstrike). During the review process, the Division of Fish, 
Wildlife & Marine Resources (DFW&MR) expressed concerns regarding the potential toxicity 
of flumetsulam to non-target aquatic plants. Therefore, as a condition of registration, 
Dow AgroSciences LLC, formerly known as DowElanco, was required to perform an acceptable 
controlled mesocosm study to be completed and delivered to the Department by October 31, 
1995. After further negotiations, the Department responded to DowElanco, in a letter 
dated February 15, 1995 (see enclosure l), that a mesocosm study would not be required 
at that time. This letter also requested that DowElanco contact Jim Colquhoun, Chief of 
the Division of Fish and Wildlife's Bureau of Habitat, formerly known as the Bureau of 
Environmental Protection, regarding a runoff study to be conducted by DowElanco with 
flumetsulam.


On March 29, 1996, a third flumetsulam containing product, Scorpion III (EPA Reg. No. 
62719-264) was registered conditionally. As a condition of the Scorpion III registration, 
and the other two registrations which contain flumetsulam, Broadstrike + Treflan (EPA Reg. 
No. 62719-222) and Broadstrike + Dual (EPA Reg. No. 62719-239), DowElanco was required to 
perform an acceptable runoff study to be completed and delivered to this Department by 
October 31, 1997. See enclosure 2 dated March 29, 1996.


The Department conditionally registered a fourth flumetsulam containing product, 
Broadstrike WDG (EPA Reg. No. 62719-277) on January 24, 1997. Broadstrike WDG (EPA 
Reg. No. 62719-277) was registered with the same conditions as the other flumetsulam 
containing products, Broadstrike + Treflan (EPA Reg. No. 62719-222), Broadstrike + Dual 
(EPA Reg. No. 62719-239) and Scorpion III (EPA Reg. No. 62719-264).


The Department received the flumetsulam runoff study on October 30, 1997. The runoff 
study was reviewed by our Division of Fish, Wildlife & Marine Resources, Bureau of 
Habitat (BOH). The technical review and recommendations dated February 9, 1998 are 
enclosed (see enclosure 3).


The runoff study submitted alleviates the Department's concerns at this time regarding 
the impacts to aquatic plants due to runoff from treated fields. However, future 
registration applications for products containing different formulations of flumetsulam 
and/or higher application rates of flumetsulam may pose an unacceptable risk to aquatic 
plants and therefore may be reviewed by the Department. Dow AgroSciences LLC must submit 
any new application for registration of any pesticide product containing a different 
formulation or increased application rate of flumetsulam as a Major Change in Labeling 
and include data which links the potential for runoff to the runoff study submitted to 
the Department on October 30, 1997. An example of the type of data required would be data 
consistent with	DowElanco submission of May 13, 1997 that demonstrated that the WDG 
formulation of flumetsulam was the most available to run off of any product currently 
registered and, therefore, supported the use of WDG for the runoff study.


Additionally, the Department received an application, on January 15, 1998, for registration 
of Python WDG (EPA Reg. No. 62719-277). Python WDG is an alternate brand name for 
Broadstrike WDG, which was registered with the Department on January 24, 1997. Since 
Python WDG is the same formulation as Broadstrike WDG and is used at the same 
application rates, it does not require additional review and has been registered by the 
Department.


Enclosed is a copy of your Certificate of Pesticide Registration which shows the 
unconditional registration of your currently registered flumetsulam containing products, 
including your previously registered products, Broadstrike + Treflan (EPA Reg. No. 62719-222),
Broadstrike + Dual (EPA Reg. No. 62719-239), Scorpion III (EPA Reg. No. 62719-264) and 
Broadstrike WDG (EPA Reg. No. 62719-277), and your new product, Python WDG (EPA Reg. No. 
62719-277). Also enclosed is a copy of your New York State stamped "Accepted for 
Registration" label for Python WDG.


Please contact Ms. Jeanine Broughel, of my staff, at (518) 457-7446, if you have any 
questions.

Sincerely,
 
 
 
Maureen P. Serafini 
Supervisor
Pesticide Product Registration Section