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Deltamethrin - Registration of RUC 161 Insecticide 8/96

New York State Department of Environmental Conservation
Division of Solid & Hazardous Materials
Bureau of Pesticides & Radiation
Pesticide Product Registration Section
50 Wolf Road, Albany, New York 12233-7257
Phone 518-457-7446 FAX 518-485-8990

                                         August 5, 1996

Ms. Jennifer C. Stern
Registration Specialist
AgrEvo Environmental Health
95 Chestnut Ridge Road
Montvale, NJ 07645

Dear Ms. Stern:

Re:  Registration of RUC 161 Insecticide (EPA Reg. No. 432-763) and DeltaTech
     (432-762), Containing the New Active Ingredient Deltamethrin

     We have reviewed and accepted for registration the application received
on May 22, 1995 to register the referenced new pesticide products in New York
State. These products are classified as general use pesticides in New York
State.

     RUC 161 Insecticide contains 4.75% deltamethrin and is labeled to control
various insect pests in and around residential, industrial and institutional
structures and their immediate surroundings and on various modes of
transportation. DeltaTech contains 98% deltamethrin and is labeled for
formulation into insecticides for these uses and other uses approved by the
United States Environmental Protection Agency (USEPA). Both products contain
the new active ingredient deltamethrin.

     We have concluded that use of the products as labeled is not likely to
result in significant adverse impacts to human health or the environment in
New York State.

     Technical deltamethrin and RUC 161 were not very toxic to laboratory
animals by the dermal and inhalation exposure routes. Following oral exposure,
technical deltamethrin and RUC 161 were moderately toxic and not very toxic to
laboratory animals, respectively. Technical deltamethrin and RUC 161 were not
very irritating to animal eyes and skin and were not sensitizers.

     The data on technical deltamethrin indicate that it is not very toxic in
chronic feeding and reproductive/developmental toxicity studies. Deltamethrin
did produce some fetotoxicity (delayed skeletal ossification in one rat and
one rabbit study, and fetal losses and decreased pup body weights in a second
rabbit study) at doses that generally caused maternal toxicity. Deltamethrin
was not oncogenic in rats and mice and was negative in several genotoxicity
tests. The USEPA's Office of Pesticide Programs derived an oral reference dose
of 0.01 mg/kg/day based on the no-observed-effect level from the chronic rat
study (1 mg/kg/day) and an uncertainty factor of 100.

     Significant impacts to indoor air would not be expected from use of the
products as labeled. RUC 161 does not use an organic solvent system and
deltamethrin has a low vapor pressure (1.5 x 10-8 mm Hg at 25 degrees C). The
product is mixed with water and applied as a 0.03-0.06% deltamethrin spray and
used primarily as a spot and crack and crevice treatment. In addition, the RUC
161 label states that the product should be used in well- ventilated areas and
treated surfaces should be dry before allowing children and pets to contact
them.

     There are no chemical-specific federal or State drinking
water/groundwater standards for deltamethrin. Based on its chemical structure,
deltamethrin falls under the 50 microgram per liter general New York State
drinking water standard for an "unspecified organic contaminant" (10 NYCRR
Part 5 - Public Water Systems). The USEPA Environmental Fate and Groundwater
Branch review, dated February 3, 1994, indicates that deltamethrin is not very
persistent or mobile in soils, but two of its metabolites (decamethrinic acid
and 3-phenoxybenzoic acid) were mobile in leaching and adsorption/desorption
tests. Based on their chemical structures, these metabolites also fall under
the 50 microgram per liter drinking water standard for "unspecified organic
contaminants."

     With regard to ecological impacts, deltamethrin is potentially toxic, on
an acute and chronic basis, to fish and invertebrates in both fresh and
saltwater, as supported by the environmental hazard warning on the product
label. Submitted studies also indicate that deltamethrin may be toxic to
mammals feeding on treated foliage. However, we have concluded that the
current use pattern for RUC 161 as an outside perimeter treatment for
buildings does not pose a threat to fish and wildlife resources in New York
State.

     Any additional outdoor uses for deltamethrin, at or above the current
maximum application rate for RUC 161, will be reviewed by this Department in
light of the concerns regarding potential toxicity to fish, invertebrates and
mammals.

     If you intend to apply for registration of expanded uses for
deltamethrin, you should consider the following items:

     1.  To address aquatic toxicity concerns, you may submit a runoff study
that quantifies the amount of bioavailable deltamethrin expected in runoff
waters.

     2.  A mesocosm study conducted with tralomethrin and previously accepted
by the USEPA may also be submitted to address aquatic toxicity concerns.

     3.  Actual residue data from the application of deltamethrin to various
vegetative forage may be submitted to address concerns regarding
mammalian toxicity.

     The New York State Certificate of Pesticide Registration and a copy of
the stamped "ACCEPTED" label for RUC 161 Insecticide and DeltaTech are
enclosed for your records.

     If you have any questions regarding this registration, please contact
Maureen Serefini, Supervisor of our Pesticide Product Registration Section, at
(518) 457-7446.

                                      Sincerely,

                                      Norman H. Nosenchuck, P.E.
                                      Director
                                      Division of Solid & Hazardous Materials

Enclosures
cc: w/enc. - W. Smith, Cornell University PMEP
             N. Kim/T. Grey, NYS Dept. of Health