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Imidacloprid - Application for Major Change in Labeling 12/96

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

December 10, 1996


Ms. Karen Cain
State Regulatory Affairs Specialist
Registrations Department
Bayer Corporation
P.O. Box 4913
Kansas City, MO 64120-0013

Dear Ms. Cain:

Re: Application for Major Change of Labeling of Imidacloprid, Contained in the Pesticide Product Premise 75 Insecticide (EPA Reg. No. 3125-455)

   The Department received your letter, dated December 4, 1996, requesting the withdrawal of the application for Premise 75 Insecticide (EPA Reg. No. 3125-455). Premise 75 Insecticide represents a major change in labeling for the active ingredient imidacloprid.

   The Department acknowledges Bayer Corporation's decision to withdraw the application for New York State registration of Premise 75 Insecticide.

   The Department has concerns regarding the outdoor termiticide uses of Premise 75 Insecticide. There is a potential of groundwater impacts if the product is used in sandy areas of New York State. After consideration of the reviews by the New York State Department of Health, and our Technical Support & Laboratory Services Section, we recommended that Bayer Corporation consider registration of Premise 75 Insecticide (EPA Reg. No. 3125-455) by a Special Local Need label in New York State limiting use to indoor applications, and application to the interior of foundation walls and under slabs.

   Bayer Corporation is not willing to concede the outdoor uses of Premise 75 Insecticide and therefore has requested the withdrawal of the application.