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S-metolachlor (Dual Magnum)
NYS DEC Letter - Specific Exemption Request for Use on Red Beets 12/03

New York State Department of Environmental Conservation
Division of Solid and Hazardous Materials

Bureau of Pesticides Management, 9th Floor
625 Broadway, Albany, New York 12233-7254
Phone: (518) 402-8788     FAX: (518) 402-9024
Website: www.dec.state.ny.us

December 10, 2003

Mr. Dan Rosenblatt
Acting Team Leader
USEPA / Office of Pesticide Programs
Emergency Response Team (7505C)
Document Processing Desk
Crystal Mall 2-- 2nd Floor
1921 Jefferson Davis Hwy.
Arlington, Virginia 22202

Dear Mr. Rosenblatt:

Re: Specific Exemption Request for Use of s-metolachlor (Dual Magnum, EPA Reg. No. 100-816) for Preemergence Control of Broadleaf Weeds in Red Beets in 2004

    The New York State Department of Environmental Conservation (Department), as the State lead agency for pesticide matters, hereby requests approval of the referenced application (see enclosure) 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, Subpart B (166.20).

    Currently registered preemergence herbicides, Ro-Neet and Pyramin, often fail to provide adequate control of troublesome broadleaf weeds due to their dependency on rainfall for activation. The lack of control, coupled with the inability to eliminate in-row weeds with cultivation, results in the majority of beets requiring expensive chopping at harvest to remove weeds. Postemergent herbicides like Spin Aid, Stinger and Betanex control select broadleaf weeds, but not annual grasses, yellow nutsedge or common purslane. The sale of Ro-Neet from Zeneca to Tri-Ag has made this important preemergent herbicide unavailable to growers for the 2004 season. The weeds formerly controlled by Ro-Neet include annual grasses and common purslane. While Pyramin will still be able to control purslane, it has no effect on grasses.

    Research has shown that preemergence application of Dual Magnum effectively controls certain annual grasses, yellow nutsedge, hairy galinsoga, redroot pigweed and common purslane. Annual grasses are a concern to the processing beet community and, without Ro-Neet, will not be controlled. If Poast were to be used to control grasses, multiple applications would be required over the 90 day growing season, making its use both prohibitive in cost and in the danger of increasing the potential for resistance. Dual Magnum has been shown to provide adequate suppression of grasses in one application, or a split application of the same rate (see Appendix B). A tolerance has recently been established in sugar beets, and the registrant is pursuing residue studies in other members of the root crop subgroup. With the loss of Ro-Neet, Dual Magnum has become a necessity.

    The requested rate of application is .32 to .641b. ai/acre (.33 to .66 pints product/acre) applied as either one preemergent application at .66 pints or as a split application of .33 pints preemergence after planting and .33 pints applied postemergence when beets have two to four leaves. The maximum application rate is .66 pints/acre. It is estimated that greater than 60% of the 2,500 acres of red beets expected to be grown in New York State in 2004 may need to be treated with Dual Magnum if the companion specific exemption request for Betanex is approved, and 100% of the acres of red beets may need to be treated if Betanex will not be available. Syngenta Crop Protection, the manufacturer of Dual Magnum, fully supports our efforts to obtain an emergency exemption for the use of Dual Magnum on red beets in New York State. The National Interregional Research Project No. 4, IR-4, and Syngenta are working together to complete studies of s-metolachlor residues on radishes. Combined with residue data on carrots and sugar beets, a tolerance petition for vegetable, root subgroup can be submitted. Red beets would be covered by this subgroup (see Appendix D of enclosure).

    Processing red beets are planted from May 1 to June 30, emerging from the soil in seven to 14 days, and are ready to harvest 90 to 110 days later. The anticipated use season for s-metolachlor in New York State is from April 15 to June 30. Due to concerns about s-metolachlor, use of this product will be restricted to the following counties where red beets are grown: Genesee, Wayne, Livingston, Ontario, Orleans, Steuben and Yates counties. Applications will be made by or under the supervision of certified private applicators using their own equipment or by certified commercial applicators. Personal protective equipment will include long-sleeved shirts, long pants, chemical resistant gloves and shoes plus socks. An REI of 24 hours is currently on the section 3 label for Dual Magnum.

    Three copies of this application are enclosed per the February 9, 2000 letter. Please contact Robin Hackett, of our Pesticide Product Registration Section, at (518) 402-8768, if you require further assistance on this request.

Sincerely,

Maureen P. Serafini
Director
Bureau of Pesticides Management

Enclosure
cc: w/enc. - A. Enache, USEPA Region II
cc: w/o enc. - W. Smith, Cornell University, PSUR
R. Zimmerman\R. Mungari, New York State Dept. of Ag. & Mkts.