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3-Chloro-4-Methylbenzenamine Hydrochloride (Starlicide)
NYS DEC Letter - Product Registration 1/04

New York State Department of Environmental Conservation
Division of Solid & Hazardous Materials

Bureau of Pesticides Management
Pesticide Product Registration Section
625 Broadway, Albany, New York 12233-7257
Phone 518-402-8768     FAX 518-402-9024
Website: http://www.dec.state.ny.us/website/dshm
E-Mail: ppr@gw.dec.state.ny.us

January 12, 2004

CERTIFIED MAIL
RETURN RECEIPT REOUESTED


Mr. Richard B. Chipman
New York State Director
United States Department of Agriculture
Animal & Plant Health Inspection Service
Wildlife Services
1930 Route 9
Castleton, New York 12033

Dear Mr. Chipman:

Re: Registration of Compound DRC-1339 Concentrate - Feedlots (EPA Reg. No. 56228-10), Which Contains the Active Ingredient 3-Chloro-4-methylbenzenamine Hydrochloride

    The New York State Department of Environmental Conservation (Department) has reviewed your application, received June 26, 2003, to register one new pesticide product, Compound DRC-1339 Concentrate - Feedlots (EPA Reg. No. 56228-10), in New York State. The product contains the active ingredient 3-chloro-4-methylbenzenamine hydrochloride.

    Compound DRC-1339 Concentrate - Feedlots (EPA Reg. No. 56228-10) is a slow acting avicide for the control of blackbirds, cowbirds, grackles, and starlings.

    The product is classified as a "Restricted Use Pesticide" and is for use only by USDA personnel trained in bird control or persons under their direct supervision.

    Richard Chipman, New York State Director, USDA, APHIS, Wildlife Services, held a meeting on February 13, 2003 at the Department of Agriculture and Markets on Wolf Road. Several employees of the Pesticide Product Registration Section and the Division of Fish, Wildlife and Marine Resources attended. The meeting was very informational and quite graphically showed the problems caused by large flocks of starlings and the real need for pesticidal control of starlings.

    Mr. Chipman's presentation outlined the problems associated with starlings at farms and feedlots. The primary concerns presented were:
  1. Disease Transmission (to animals and humans)
  2. Feed Consumption
  3. Feed Contamination
  4. Droppings (property)
  5. Droppings (clean-up costs)
    Starlings are attracted to dairy farms where food and shelter are readily available. Populations usually increase around dairy barns during winter months when snow cover limits access to food and water. Barns provide warm shelter on cold days, and feed troughs and bunkers provide an easy source of food. During winter, starlings often consume and contaminate large quantities of feed intended for livestock. A flock of 200 starlings may consume 175 pounds of grain per week and contaminate even more with their droppings. In addition, birds may create fire hazards by nesting on light fixtures and wiring in barns, and their droppings may contaminate bedding material and water intended for livestock.

    The use of DRC-1339 is only one small part of "Integrated Bird Control." The following methods are routinely used for control: barn design; exclusion; cultural practices; nest destruction; frightening; repellents; trapping; shooting. The combination of several methods is the key to a successful "Integrated Bird Control" management plan.

    The USDA applies DRC-1339 in a highly controlled process.

    The program participants usually are referred to APHIS through the New York Farm Bureau or the Cornell Cooperative Extension Service. Farms will most likely be hand picked based on severity of problem, location, and willingness to pay a nominal fee to cover the cost of bait and DRC-1339. Usually it takes 10 to 14 days at each farm to administer the following steps of the program:
  1. Generally there is an initial site visit (1/2 to 1 day) to count birds and assess the situation for approximate amounts of necessary pre-bait and treated bait that will be needed. Species and quantities of non-targets will also be recorded.
  2. Seven to ten days of pre-baiting with the recording of bait consumption and non-targets present.
  3. One day for application of treated bait.
  4. One day to assess the effectiveness, and search for and collect dead birds.
    DRC-1339 causes death in 1 to 3 days. It is relatively species specific and will not kill pigeons or house sparrows when used according to label directions. For effective control, untreated grain or other suitable bait is placed near areas where the birds are feeding. These "pre-baiting" areas are inaccessible to livestock, since DRC-1339 should not be consumed by livestock. The pre-baiting period should continue for at least 3 to 4 days, or until the bait is being readily consumed by the starlings. The clean grain or bait is then replaced by the treated bait for one day. An extensive effort is made to find and properly dispose of any dead birds.

    DRC-1339 is rapidly metabolized and excreted in birds and other species and is not accumulated in plant or animal tissues.

    DRC-1339 is highly toxic to starlings, blackbirds, and magpies, with reported LD50 values ranging from 1 to 5 mg/kg. Doves, pigeons, quails, chickens, ducks, and geese are slightly less sensitive and have acute toxicity values occurring in the range of 11 to 100 mg/kg. Most of the target species are adversely affected at low levels. Few birds and most mammals experience toxicity at higher levels ranging from 100 to more than 1,000 ppm.

    Based on the comparative toxicity of oral and intravenous doses, DRC-1339 is absorbed readily into the starling circulatory system. The compound is readily metabolized in the liver into related compounds, possibly including glucuronides and mercapturides. The compound is completely metabolized within three to 24 hours, with the target species dying as soon as three hours after consuming the bait. Uric acid deposits build up in the kidney and blood vessels causing necrosis and circulatory impairment, and resulting in death from uremic poisoning and congestion of major organs.

    There is little potential for secondary hazards to non-target animals with DRC-1339, primarily due to the rapid metabolism of the compound. The only report of secondary toxicity occurred when crows consumed the gut contents of pigeons killed with Starlicide. Cunningham et al. (1979) estimated that a sensitive species (i.e., cat, owl, and magpie) could be at risk only if its diet consisted wholly of DRC-1339-poisoned starlings for more than 30 continuous days.

    The Department concludes that Compound DRC-1339 Concentrate - Feedlots will not have an adverse effect on the health of workers or the general public, the non-target fish and wildlife resources, or the ground and surface water of New York State when used as labeled and all additional protective measures are followed.

    Therefore, the Department hereby accepts for restricted use registration the product Compound DRC-1339 Concentrate - Feedlots (EPA Reg. No. 56228-10).

    The pesticide product is classified as "restricted use" in New York State according to rules and regulations 6NYCRR 326.23(e). Please note the "YES" under the "restriction" column on the enclosed Certificate of Pesticide Registration and the "classified for restricted use in New York State" stamp on the enclosed product label.

    As such this product is restricted in its purchase, distribution, sale, use and possession in New York State. Furthermore, this product may only be used by a certified applicator in New York State.

    The Pesticide Reporting Law (PRL) in the Environmental Conservation Law Article 33 Title 12 requires all certified commercial pesticide applicators to report information annually to the Department regarding each pesticide application they make.

    If you need information relating to the Pesticide Reporting Law, or annual report forms, please visit the Department's website or contact the Pesticide Reporting Section at (518) 402-8765.

    Also, the current product label contains the following statement: "Other bait materials (French fries, raisins, etc.) may only be used if it is demonstrated that they are preferred by the target species and the nontarget risks are equal to or less than those for cracked or rolled corn, whole or rolled milo, or poultry pellets." The USDA, APHIS, Wildlife Services, stated that CU Bird Carrier (Fat Pellets) have been shown to be preferred by the target species and effective when used as a part of their program. As requested by the USDA, APHIS, Wildlife Services, permission is hereby granted to use CU Bird Carrier (Fat Pellets) as the primary bait used in the program.

    Enclosed are your New York State stamped "ACCEPTED" label and a copy of the Certificate of Registration.

    If you have any questions, please contact Mr. Samuel Jackling, Chief of our Pesticide Product Registration Section, at (518) 402-8768.

Sincerely,

Maureen P. Serafini
Director
Bureau of Pesticides Management

Enclosures
cc: w/enc. - R. Zimmerman/ R. Mungari - NYS Dept. of Ag. & Markets
G. Good/W. Smith - Cornell University, PMEP