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imazapyr, isopropylamine salt
NYS DEC Letter - Notice of Intent to Cancel Registration 4/00


New York State Department of Environmental Conservation 
Division of Solid and Hazardous Materials
Bureau of Pesticides Management, Room 498 
Pesticide Product Registration Section
50 Wolf Road, Albany, New York 12233-7257 
Phone: (518) 457-7446 - FAX: (518) 485-8990 
Website: www.dec.state.ny.us/website/dshm/pesticid/pesticid.htm


April 12, 2000


CERTIFIED MAIL
RETURN RECEIPT REQUESTED


Ms. Michaeleen E. Linahan 
State Registration Manager 
American Cyanamid Company 
P.O. Box 400
Princeton, NJ 08543-0400


Dear Ms. Linahan:


Re:  Notice of Intent to Cancel Registration of ARSENAL® Herbicide Applicators 
     Concentrate (EPA Reg. No. 241-299)


The New York State Department of Environmental Conservation ("The Department") proposes 
to cancel the registration of ARSENAL® Herbicide Applicators Concentrate (EPA Reg. 
No. 241-299) containing the active ingredient isopropylamine salt of imazapyr 
(2-[4,5-dihydro-4-methyl-4-(1-methylethyl)-5-oxo-lH-imidazol-2-yl]-3-pyridinecarboxylic acid).


As a result of the review of your application to register HABITAT' Release Herbicide 
(reference correspondence from M. Serafini to M. Linahan dated March 13, 2000), the 
Department has determined that the following use pattern for isopropylamine salt of imazapyr 
was inadvertently approved on the ARSENAL® Herbicide Applicators Concentrate 
(EPA Reg. No. 241-299) label:

ARSENAL® Herbicide Applicators Concentrate may be applied in forestry sites (land 
managed for timber production) on areas defined as puddles, potholes, berms of ditches, 
drainage ditches, intermittent drainage, intermittently flooded low lying sites, 
seasonally dry flood plains, and transitional areas between upland and lowland sites 
except in the state of California. It is permissible to treat marshes, swamps, and bogs 
after water has receded, as well as seasonally dry flood deltas except in the state of 
California.


This use pattern represents a major change in labeled (MCL) use pattern for isopropylamine 
salt of imazapyr. In order for the Department to assess the potential impacts to nontarget 
organisms and the environment resulting from the use pattern specified above, American 
Cyanamid Company must submit four copies of the following information:
 
o  Items number 4, 5, 6, 7, and 8 listed in Appendix 1.B. of "New York State Pesticide 
Product Registration Procedures" (August 1996).


The required supporting documents must be submitted to this office within 30 days of receipt 
of this letter. Failure to submit the information will result in the cancellation of the 
registration of ARSENAL® Herbicide Applicators Concentrate (EPA Reg. No. 241-299). 
Pursuant to Article 33-0713 of the New York State Environmental Conservation Law (ECL), 
cancellation shall be effective 30 days after service of this notice.


ECL 33-0713 makes available certain options when registration is cancelled. You may 
pursue those options or reapply for registration. To reapply, you must submit a complete 
new application for registration with all supporting documents and applicable application 
fee.


Please be aware that any cancelled (suspended) product may not be sold, offered for sale, 
distributed, or used in New York State. Upon receipt of cancellation notice (Certificate of 
Pesticide Registration listing status of product as suspended "S"), American Cyanamid 
Company should make arrangements to recall the cancelled (suspended) product in order to 
avoid potential enforcement action for the sale, offer for sale, distribution, or use of 
unregistered products in New York State.


If you have any questions on this matter, please contact Michael Radzevich, of my staff, 
at (518) 457-7446.


Sincerely,

Maureen P. Serafini 
Chief
Pesticide Product Registration Section