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fipronil
Incomplete Registration Application 12/00


New York State Department of Environmental Conservation
Division of Solid and Hazardous Materials
Bureau of Pesticides Management Room 498
Pesticide Product Registration Section
50 Wolf Road, Albany, New York 12233-7257
Phone: (518) 457-7446 - FAX: (518) 485-8990
Website: www.dec.state.ny.us/website/dshm/pesticid/pesticid.htm
E-Mail: ppr@gw.dec.state.ny.us

December 29, 2000

CERTIFIED MAIL
RETURN RECEIPT REQUESTED 

Mr. Adrian Krygsman
Aventis Environmental Science USA LP
95 Chestnut Ridge Road
Montvale, NJ 07645

Dear Mr. Krygsman:

Re: Incomplete Application To Register Termidor 80 WG (EPA Reg. No. 432-900) & Termidor SC
    (EPA Reg. No. 432-901) containing the active ingredient Fipronil.

The New York State Department of Environmental Conservation (The Department) has evaluated
completeness of the application and data package (received on 10/5/00) submitted in support
of the registration of the above referenced products. These two products are labeled for
use as a termiticide/insecticide for pre- and post construction treatment to prevent
structural damage from termite infestation. The products are applied as a curtain treatment
intended to be lethal to termites by contact and ingestion. The Termidor products are
required to be applied by trained applicators and are intended as a one time treatment
to resolve termite infestation and damage.

The data package submitted in support of the referenced active ingredient application(s)
has been determined to be incomplete for purposes of review. Four copies of the following
information must be submitted in order for the Department to proceed with the technical
review:

1.  An approvable work plan for a groundwater monitoring study for use of these products
    at maximum labeled use rates for homes on Long Island. Details of this plan were discussed
    with Kenneth Kurokowski of Aventis during a conference call with the Department on
    December 15, 2000.

2.  Submittal of a USEPA review or Data Evaluation Record report of the column leaching
    study identified with the MRID # of 42918664.

3.  Page 41 of the USEPA Environmental Fate and Effects Division memorandum dated
    November 20, 1997 from James A. Hetrick, et. al. To Arnet Jones.

Failure to submit the requested information within 45 calendar days of receipt of this
letter will result in termination of the review process and denial of the application.
Please note that, after the specified 45-day deadline, Aventis Environmental Science USA
LP may re-submit applications to register Termidor 80 WG (EPA Reg. No. 432-900) & Termidor
SC (EPA Reg. No. 432-901) containing the active ingredient Fipronil. The applications must
be accompanied by a new application fee and meet the requirements listed in Appendix I .A.
of "New York State Pesticide Product Registration Procedures" (August 1996). Such information
as well as forms can be accessed at our website as listed in our letterhead.

If you have any questions on this matter, please contact Ms. Paula McBath, of my
staff, at (518) 457-7446.

Sincerely,

Francis X. Hegener
Chief
Pesticide Product Registration Section