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prodiamine (Barricade) NYSDEC Registration 5/94

New York State Department of Environmental Conservation
50 Wolf Road, Albany, New York 12233-7250
51857-6934 FAX 51857-0629

CERTIFIED MAIL
RETURN RECEIPT REOUESTED                        May 11, 1994

Ms. Catherine A. Elmi
Supervisor, State Registrations
Sandoz Agro, Inc.
1300 East Touhy Avenue
Des Plaines, IL 60018

Dear Ms. Elmi:

Langdon Marsh
Acting Commissioner

Re: Barricade 65WG Herbicide (EPA Reg. No. 55947-43)
Barricade 65WG in Water Soluble Packs (EPA Reg. No.
55947-143)

The New York State Department of Environmental Conservation
(Department) has approved your application to register the
referenced pesticide product for use in New York State as
described on the submitted label. This product is classified as
a restricted use pesticide.

The active ingredient prodiamine is a new active ingredient
in New York State. This Department and the New York State
Department of Health have reviewed all of the information
submitted in support of the registration. The Department has
determined that use of this product according to the directions
on the currently submitted label is not likely to result in
significant health or environmental risks. As required by the
product label, the use of personal protective equipment when
applying this product is imperative to limit exposure to
Barricade.

Exposure estimates indicate that the risks of noncancer
effects from exposure are minimal, however, since prodiamine is
classified as a possible human carcinogen by the United States
Environmental Protection Agency, (USEPA), Barricade will be
registered in New York State subject to the following conditions:

     1.  Barricade will be registered as a restricted use
pesticide, with its distribution, sale and use limited
to commercial permit holders/or certified applicators.

     2. Sandoz Agro must revise their Material Safety Data
Sheets in the following manner:


     A.  State that the USEPA lists prodiamine as a possible human   
     carcinogen based on limited evidence from animal studies.

     B.  The statement that "prodiamine is not listed as a
     potential carcinogen by IARC, NCI/NTP, OSHA, or
     ACGIH" is also misleading since prodiamine has not
     been evaluated by IARC, NCI/NTP, OSHA, or ACGIH.
     This statement must be revised to state that the
     ingredient has not been reviewed or the statement
     must be omitted.

     C. The Toxicological Information Section of the MSDS
should be revised to either incorporate this information under a 
separate CANCER heading or into the CHRONIC TOXICITY heading, 
rather than under the OTHER heading.

     D.  Sandoz Agro, Inc. must provide to this office a
revised Material Safety Data Sheet within sixty (60) days from the day 
of receipt of this letter.

Since this product is classified as a restricted use
pesticide, please note that New York State Environmental
Conservation Law (ECL) 33-0901.1 states that: "A commercial
permit is required for the distribution, sale, offer for sale,
purchase for the purpose of resale or possession for the purpose
of resale of a restricted use pesticide."

If Sandoz Agro proposes to sell or offer for sale any
restricted use pesticide to any person within New York State, a
commercial permit is required for both Sandoz Agro and the
purchaser. ECL 33-0905.1 further states that: "Any person who
engages in...the sale of restricted use pesticides shall be
certified by the commissioner..." Commercial permit holders must
employ or retain under contract at least one person who is
certified in New York State for the application of restricted use
pesticides.

The approved label is the federally registered label as submitted.   
Enclosed is the Certificate of Pesticide Registration and a copy of the stamp-accepted label for your records.

Please call Ms. Maureen Serafini, of my staff, at (518) 457-7446, if 
you have any questions.

Sincerely,

 

Norman H. Nosenchuck, P.E.
Director
Division of Hazardous Substances
Regulation

Enclosures

cc: N. Kim - N.Y.S. DOH - w/encls.
    D. Rutz - Cornell - w/encls. 
    D. Rapp - N.Y.S. Dept. of Ag. and Mrkts. - w/encls.