Diflubenzuron - Major Change in Label Application 8/99
Diflubenzuron - Application for Registration of a Major Change in Label 8/99
New York State Department of Environmental Conservation
Division of Solid & Hazardous Materials
50 Wolf Road, Albany, New York 12233-7250
Phone 518-457-6934 FAX 518-457-0629
RETURN RECEIPT REQUESTED
Mr. Ken Kendall, MBA;
BCE Technical Director;
Urban Entomologist Ensystex, Inc.
P.O. Box 2587 Fayetteville, NC 28302
Dear Mr. Kendall:
Re: Application for Registration of a Major Change in Label for the Active Ingredient - Diflubenzuron Contained in
the Pesticide Product Labyrinth Termite Bait (EPA Reg. No. 68850-2)
The New York State Department of Environmental Conservation (NYSDEC) has reviewed your application, received on March
25, 1999, to register the pesticide product Labyrinth Termite Bait (EPA Reg. No. 68850-2) for use as a termite bait
placed in bait stations or fabric mesh bags around and under foundations of structures. Diflubenzuron is currently
registered in New York State for agricultural use (including greenhouse) as an insect growth regulator. Use as a
termiticide was determined to be a major change in label because use on termites in and around structures could cause
public health concerns.
The application was determined complete on May 21, 1999 with the registration decision date set at October 18, 1999.
The formulated product was not very acutely toxic to laboratory animals via the oral, dermal or inhalation routes of
exposure. It was also neither very irritating to animal eyes or skin, nor was ita skin sensitizer.
The United States Environmental Protection Agency (USEPA) in its recently issued Reregistration Eligibility Decision
(RED) for diflubenzuron, presented toxicological information that indicated that this compound does not cause
oncogenic, teratogenic or reproductive effects and was negative in several genotoxicity studies. However, in subchronic
and chronic toxicity studies, diflubenzuron caused increased methemoglobin and sulfhemoglobin formation. The USEPA
established a reference dose of 0.02 milligrams per kilogram body weight per day (mg/kg/day) based on a
no-observed-effect level of 2.0 mg/kg/day in a one-year dog feeding study (increased methemoglobin and sulfhemoglobin
formation at 10 mg/kg/day) and an uncertainty factor of 100.
There are no chemical specific federal or State drinking water/groundwater standards for diflubenzuron. Based on its
chemical structure, diflubenzuron falls under the 50 micrograms per liter general New York State drinking water
standard for "unspecified organic contaminants" (10 NYCRR Part 5, Public Water Systems).
For the treatment of structures, the formulated product is placed either in a rigid box or in a bait bag made of
flexible mesh fabric. The bags are intended for placement in voids or under concrete slabs which are not accessible to
children. These bags have openings that allow termites free access to the bait placed within. For aboveground
installation, the bait is placed in tamper-resistant stations (rigid boxes) which are held shut with four
tamper-resistant screws. Ensystex, Inc. submitted a copy of the training manual which contains pictures of these
containers and instructions for their placement and maintenance.
The Labyrinth Termite Bait system does not appear to pose any significant exposure potential or risks to public health.
However, proper use of Labyrinth Termite Bait requires professional training and expertise. The directions for use
indicate that specialized tools and equipment will be needed to successfully install and monitor these bait stations as
well as an understanding of the effect of temperature on the feeding habits of termites. Additionally, improper storage
of the fabric mesh bags in a home could make this product accessible to children.
Therefore, the Departments accepts Labyrinth Termite Bait (EPA Reg. No. 68850-2) for registration in New
York State as a "restricted use" product. As such this product is restricted in its purchase, distribution,
sale, use and possession in
New York State. Furthermore, this product may only be purchased and used by a certified applicator in New York
According to New York State Environmental Conservation Regulations 6NYCRR 326.3(a): "It shall be unlawful for any
person to distribute, sell, offer for sale, purchase for the purpose of resale, or possess for the purpose of resale,
any restricted pesticide
unless said person shall have applied for, and been issued a commercial permit." Should you require information to
obtain a commercial permit, please contact the Pesticide Management Section at (518) 457-7482.
Enclosed for your records are the Certificate of Registration and the stamped accepted product label.
If you have any questions on this matter, please contact Maureen Serafini, Chief of our Pesticide Product Registration
Section, at (518) 457-7446.
Division of Solid & Hazardous Materials
cc: w/enc. - N. Kim/D. Luttinger - NYS Dept. of Health
E. Biel/ R. Mungari - NYS Dept. of Ag. & Markets
G. Good/W. Smith - Cornell University, PMEP