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imazapyr, isopropylamine salt
NYS DEC Letter - Arsenal Herbicide Applicator Concentrate 8/00


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

August 18, 2000

CERTIFIED MAIL
RETURN RECEIPT REQUESTED


Ms. Michaeleen E. Linahan 
State Registration Manager 
BASF Corporation
P.O. Box 400
Princeton, NJ 08543-0400


Dear Ms. Linahan:


Re: ARSENAL® Herbicide Applicators Concentrate (EPA Reg. No. 241-299)


The Department has completed review of your response to the request for additional data to 
support continued registration status of the subject product. ARSENAL® Herbicide 
Applicators Concentrate (EPA Reg. No. 241-299) contains 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).


Use of ARSENAL® in intermittently flooded forestry sites and marshes, swamps, and bogs 
after water has receded was approved without review as a major change in labeled (MCL) use 
pattern. Additional data was required to assess the potential impacts of to nontarget 
organisms and the environment resulting from these use patterns.


American Cyanamid Company (now known as BASF Corporation) modified the federal label via 
notification (05/05/00) to the United States Environmental Protection Agency regarding 
addition of New York as another state in which applications to occasionally wet forested 
area is not allowed. The addition of the underlined text to the following "General 
Information" statement removes the subject product from the scope of a MCL in New York 
State:

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 states 
of California and New York. It is permissible to treat marshes, swamps, and bogs after water 
has receded, as well as seasonally dry flood deltas except in the states of California and 
New York.


Enclosed for your records is a copy of the New York stamped "Accepted" label. You must submit 
three (3) copies of final printed labeling prior to sale, offer for sale, distribution or use 
of product in New York State.


Please note that, a proposal by BASF Corporation or any other registrant, to register a 
product containing imazapyr or any of its salts, whose labeled uses are likely to increase 
the potential for significant impact to humans, property, or the environment, would 
constitute a major change in labeled (MCL) use pattern. Such an application must be 
accompanied by a new application fee and meet the requirements listed in Appendix 1.B. of 
"New York State Pesticide Product Registration Procedures" (August 1996).


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


Sincerely,

Francis X. Hegener 
Chief
Pesticide Product Registration Section


Enclosure