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pyridate (Lentagran, Tough) 2(ee) for use on Cabbage 6/94

                                          JUNE. 1, 1994
Dr. Donald Rutz
Associate Professor of Veterinary
  Entomology and Director	
Pesticide Management Education Program
Cornell Cooperative Extension
5123 Comstock Hall
Ithaca, New York 14853-0901
Dear Dr. Rutz:
     Re:  FIFRA 2(ee) Recommendation for Tough 45WP (EPA Reg. No. 42545-53)
          and Lentagran 45WSB (EPA Reg. No. 42545-53-10163) at Lower than
          Labeled Rates for Control of Weeds in Cabbage
     The New York State Department of Environmental Conservation has 
approved your request (copy enclosed) for a FIFRA 2(ee) recommendation for 
use of Tough 45WP (EPA Reg. No. 42545-53) and Lentagran 45WSB (EPA Reg. No. 
42545-53-10163) at less than labeled rates for control of weeds in cabbage.
     Tough 45WP and Lentagran 45WSB are currently labeled for a single 
application at 2.0 pounds per acre (0.9 lb. active ingredient per acre). 
The recommendation proposes application at 1.0 pound per acre (0.45 lb. 
active ingredient per acre) when weeds are small and a second application, 
also at the half rate, 10 days later or when the second flush of weeds 
emerge. In no case may the first application be made earlier than the 
growth stages on the product label nor may the second application fall 
within the 45 day preharvest interval required by the federal registration. 
Enclosed is a copy of the approved recommendation.
     Please call Ms. Maureen Serafini, of my staff, at (518) 457-7446, if 
you have any questions.
                                 Sincerely,
                                 Robert J. Haggerty, Jr.
                                 Chief
                                 Bureau of Technical Support
                                 Division of Hazardous Substances
                                   Regulation
Enclosure
cc:  D. Rapp - NYS Dept. of Agriculture and Markets
Proposed FIFRA 2(ee) Recommendation
Researcher and Title: Robin R. Bellinder, Associate Professor, Department 
of Fruit and Vegetable Science, Cornell University, Ithaca, NY 14853
Pesticide Name and EPA Registration No.: Lentagran 45 WSB (EPA Reg. No. 
42545-53-10163) Tough 45 WP (EPA Reg. No. 42545-53)
Target Crop: Cabbage (Brassica oleracea L. var. capitata F. alba)
Nature of 2(ee) variation from product label: The herbicide is currently 
labeled for a single application of 0.9 Ib ai/A (2.0 Ib product)when direct 
seeded crops have at least 3 fully developed true leaves or when 
transplanted crops have become well established (approximately 14 days 
after transplanting). This 2(ee) recommendation is for the use of half 
rates (0.45 Ib ai/A, 1.0 Ib product) applied on two occasions or as-needed, 
after the minimum growth stage for the full rate application has been 
reached. In no case, shall the second application occur within the 45 day 
preharvest interval stated on the federal registration.
Complete Recommendation: Effective in controlling escaped common 
lambsquarters, redroot pigweed, and hairy galinsoga and in suppressing 
nightshade, postemergence, pyridate has been observed to cause early season 
injury (chlorosis) in both direct-seeded and transplanted cabbage. Research 
has shown that 0.45 Ib ai/A, half the labeled rate, will effectively 
control small weed seedlings (cotyledons to 2-true leaves) with less crop 
injury. If weeds have grown beyond the 3-leaf stage control will be 
reduced. For those cases where timely applications can be made, when weeds 
are small, pyridate at 0.45 Ib ai/A may be applied and followed with a 
second application, at the same rate, approximately 10 days later, or when 
the second flush of weeds emerges. In no case may the first application be 
made earlier than the growth stages on the product label nor may the second 
application fall within the 45 day preharvest interval required by the 
federal registration. This double, low-rate application program may be most 
applicable for direct-seeded crops and late-maturing cabbage varieties.