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INSPECTOR MEETING. October 27-29 2008. REGISTRATION UPDATE. Topics for today. Products Without Signal Words Minimum Risk Pesticides VBFieldApps System Pheromone Registration Odds and Ends. SIGNAL WORD. LABELS WITH NO SIGNAL WORD.
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INSPECTOR MEETING October 27-29 2008
REGISTRATION UPDATE Topics for today. . . • Products Without Signal Words • Minimum Risk Pesticides • VBFieldApps System • Pheromone Registration • Odds and Ends
SIGNAL WORD LABELS WITH NO SIGNAL WORD • Certain pesticides no longer required to have a signal word. • Final Rule issued December 14, 2001. • Toxicity Category IV for all routes of exposure. • Registrant has option to use “CAUTION”.
LABELS WITH NO SIGNAL WORD Oral LD50 >5000 mg/kg TOX IV Dermal LD50 >20,000 mg/kg Inhalation LC50 >20 mg/liter Eye Irritation No Irritation Skin Irritation Mild or Slight at 72 Hours
RISK MINIMUM RISK PESTICIDES Factoids: • Also known as “25(b)” pesticides. • Federal registration not required. • Only 31 possible active ingredients. • Only “List 4A” inert ingredients or “commonly consumed foods”. • Pesticide claim = Registration in NC
MINIMUM RISK PESTICIDES VBFieldApps Lookup: • No EPA registration number • Search by Brand Name and/or Company Name • System searches exactly as entered
VBFIELDAPPS SYSTEM VBFieldApps Lookup: • Search for Reg# 498-179. • Results will also include sub-registered products. • State Wide Stop Sale banner misleading. • A product with Reg# under stop sale. • Might not be the one currently displayed on results form.
VBFIELDAPPS SYSTEM VBFieldApps Lookup: • Status field currently displays “Not on file” for new registrations. • Should display “New”. • “Number of Samples Taken” field name is misleading. • Will change to “Times Sampled During Year Shown Above”.
VBFIELDAPPS SYSTEM VBFieldApps Lookup: • Product was found to be not registered, due to inspector’s “Check Reg.” request. • Stop Sale letter was then sent by Registration Unit. • Product name was also added to statewide Stop Sales list. • Product name pulls up when entered into VbFieldApps “Stop Sales field” (as it should)
VBFIELDAPPS SYSTEM VBFieldApps Lookup: • Product name typed into Product Registration Field • “No Record Found” • This field should also be showing that the product is on statewide Stop Sale list currently; therefore.... Double-check name in the Stop Sale side of system.
PHEROMONE PRODUCTS • 40 CFR 152.25(b) “Pheromones and identical or substantially similar compounds labeled for use only in pheromone traps” are not required to be registered. • Nonetheless, some are federally registered. • Do they need to be registered in North Carolina?
PHEROMONE PRODUCTS • Definition of a pesticide: A. Any substance or mixture of substances intended for preventing, destroying, repelling or mitigating any pest, and B. Any substance or mixture of substances intended for use as a plant regulator, defoliant or desiccant. Do they need to be registered in NC? • Pheromones used in traps attract the pest to the trap.
PHEROMONE PRODUCTS Our policy: • Attracting a pest to a trap ≠ Pesticidal activity. • Attraction ≠ Demise of the pest. • Glue, holding bag, electrical current, pesticide ingredient, etc. mitigates the pest. • Not EPA registered = Not NC registered. Do they need to be registered in NC? • EPA Registered = NC Registered • Pheromone + Pesticide = Registration in NC
PHEROMONE PRODUCTS • Mating disruptants: • They do, on their own, act as the mitigating substance. • Do meet the definition of a pesticide. • NC registration required. Do they need to be registered in NC?
ODDS AND ENDS • Multiple transcripts: - Different sizes or batch numbers. - Only one transcript is needed for registration purposes. • Recommendation: - Product not found in VBFieldApps. - Don’t place under immediate stop sale. - Send in Check Reg transcript OR call us.
ODDS AND ENDS • Emergency Exemptions (Sec. 18): - Alto (cyproconazole) - Quadris Xtra (cyproconazole + azoxystrobin) - Caramba (metconazole) - Punch (flusilazole) - Topguard (flutriafol) • Special Local Need Registrations: - Two pending for use on hemlocks to control hemlock woolly adelgid. - CoreTect (imidacloprid) - Safari (dinotefuran)
REGISTRATION UPDATE QUESTIONS?
THANK YOU I’m Lee Davis and I approved this message…