Alexander B. Grannis 

 Commissioner 

New York State Department of Environmental Conservation 

Division of Solid and Hazardous Materials 

Bureau of Pesticides Management, 11th Floor 

625 Broadway, Albany, New York 12233-7254 

Phone: (518) 402-8788 • Fax: (518) 402-9024 Website: http://www.dec.ny.gov

January 14, 2009 

CERTIFIED MAIL

RETURN RECEIPT REQUESTED

Ms. Teresa McMullin 

State Registration Specialist 

Arysta LifeScience North America, LLC 

15401 Weston Parkway, Suite 150 

Cary, North Carolina 27513 

Dear Ms. McMullin: 

Re: Withdrawal of Applications to Register the New Active Ingredient (NAI) 

Iodomethane Contained in the Pesticide Products: 

Iodomethane Technical (EPA Reg. No. 66330-44) 

Midas7 98:2 (EPA Reg. No. 66330-43) 

Midas7 25:75 (EPA Reg. No. 66330-42) 

Midas7 33:67 (EPA Reg. No. 66330-59) 

Midas7 50:50 (EPA Reg. No. 66330-57) 

Midas7 EC Bronze (EPA Reg. No. 66330-58) 

Midas7 EC Gold (EPA Reg. No. 66330-60) 

The New York State Department of Environmental Conservation (Department) accepts 

your request for withdrawal of the applications to register Iodomethane Technical and six enduse Midas7

 products containing the new active ingredient iodomethane (Chemical Code 11). 

The Department reviewed the applications and data package, received November 16, 

2007, submitted by Technology Sciences Group on behalf of Arysta LifeScience North America, 

LLC (Arysta) regarding registration of the referenced products in New York State. The 

applications were deemed complete for purposes of technical review on January 15, 2008. 

Pursuant to the time frames specified in Environmental Conservation Law (ECL) '33-0704.2, 

registration decisions were due by June 13, 2008. The registration decision date was waived in 

order to allow Arysta to address the questions/issues noted in the Department=s technical issues 

letter, dated June 20, 2008. Due to a lack of response to the concerns noted in the technical 

issues letter, the Department issued a notice of intent to deny letter on November 20, 2008. On 

December 19, 2008 the Department received your request to withdraw the subject applications. 

Iodomethane Technical (99.8% iodomethane) is labeled for formulation or repackaging 

purposes only. 
Ms. Teresa McMullin 

 

2.

The end-use Midas7

 products contain various mixtures of iodomethane (Chemical Code 

11) and chloropicrin (Chemical Code 81501) and are labeled for preplant fumigations of fields 

intended for commercial production of certain listed crops and field-grown ornamentals to 

control soil-borne pests including weed seeds, nematodes, insects, and diseases. Chloropicrin is 

a component of products currently registered in the State for the preplant fumigation use pattern. 

Midas7

 98:2 (97.8% iodomethane:2% chloropicrin), Midas7 25:75 (24.95% 

iodomethane:74.63% chloropicrin), Midas7 33:67 (32.93% iodomethane:66.67% chloropicrin) 

and Midas7 50:50 (49.90% iodomethane:49.75% chloropicrin) are labeled for application via 

three preplant soil fumigation techniques: 1) raised bed soil fumigation for field-grown 

ornamentals, peppers, strawberries and tomatoes, 2) broadcast/flat fume soil fumigation for fieldgrown ornamentals, peppers, strawberries, tomatoes, turf, stone fruits, tree nuts, vines (table, 

raisin and wine grapes) and nurseries, 3) deep injection auger probe for stone fruits, tree nuts, 

vines, and field grown ornamental trees and shrubs. 

Midas7 EC Bronze (49.90% iodomethane:44.78% chloropicrin), Midas7 EC Gold

(32.93% iodomethane:61.69% chloropicrin) are labeled for preplant raised bed drip irrigation 

(chemigation) for field-grown ornamentals, peppers, strawberries and tomatoes. 

The Department conducted human health and environmental fate risk assessments for 

iodomethane and the Midas7

 products. An ecological effects risk assessment was not produced 

for this review. 

HUMAN HEALTH RISK ASSESSMENT: Iodomethane technical is labeled for formulation 

or repackaging purposes only. The six end-use products contain various mixtures of 

iodomethane and chloropicrin and are labeled as preplant fumigants to control soil-borne pests 

including weed seeds, nematodes, insects, and diseases in certain field crops, fruit and nut trees 

and field-grown ornamentals. Iodomethane is considered a replacement for methyl bromide and 

the above-listed pesticide products are federal ARestricted Use Pesticides@ due to acute toxicity 

concerns. Chloropicrin is a component of products currently registered in the State for use in 

preplant fumigation. 

On an acute basis, iodomethane technical was moderately toxic to laboratory animals via 

the oral route of exposure, slightly toxic via the dermal route of exposure, but not very toxic via 

the inhalation route of exposure. This active ingredient was corrosive to the eyes and a severe 

skin irritant (tested on rabbits), but not a skin sensitizer (tested on guinea pigs). 

Acute toxicity studies conducted on the Midas7

 98:2 and Midas7 25:75 formulated 

products were used by the United States Environmental Protection Agency (USEPA) as 

representatives of the other four formulated products. In these acute studies, Midas7

 98:2 was 

moderately toxic to laboratory animals via the oral route of exposure, but not very toxic via the 

dermal and inhalation routes of exposure. Midas7

 25:75 was moderately toxic via the oral and 

inhalation routes of exposure and slightly toxic via the dermal route of exposure. Both 

formulated end-use products were corrosive to the eyes, severe skin irritants, and dermal 
Ms. Teresa McMullin 

 

3.

sensitizers. 

Iodomethane caused some effects in an acute inhalation neurotoxicity study and a 

subchronic inhalation toxicity study in rats. In the neurotoxicity study, iodomethane caused 

clonic convulsions, decreased body temperatures, and decreased motor activity in rats exposed 

via whole-body inhalation (single exposure for a duration of six hours) to a concentration of 

93 parts-per-million (ppm) iodomethane; the no-observed-effect-level (NOEL) was 27 ppm. In 

the subchronic study, decreases in body weights, body weight gains and food consumption (in 

males) were observed at a concentration of 70 ppm; the NOEL was 21 ppm. Port-of-entry 

effects characterized by degeneration of the olfactory epithelium also occurred at 70 ppm; the 

NOEL was 21 ppm. 

Iodomethane caused some developmental toxicity in the offspring of pregnant rabbits, 

but not pregnant rats, exposed via inhalation to this chemical during organogenesis. In rabbits, 

increased fetal losses and decreased fetal weights were reported at maternal exposures to 20 

ppm; the NOEL was 10 ppm. Maternal toxicity was not observed at concentrations up to 20 

ppm (the highest level tested). In rats, maternal toxicity consisting of decreased body weight 

gain occurred at a concentration of 60 ppm; the NOEL was 20 ppm. No developmental toxicity 

was observed at concentrations up to 60 ppm (the highest level tested). In a two-generation 

reproduction study in rats, decreases in body weight gain, body weight and thymus weights in 

offspring as well as delays in vaginal patency were reported at 20 ppm; the NOEL was 5 ppm. 

Parental toxicity consisting of decreased body weight gain and body weight, organ weight 

changes, gross pathology and histopathology findings occurred at 50 ppm; the NOEL was 20 

ppm. 

The genotoxic and oncogenic potential of iodomethane were evaluated. While 

iodomethane was negative in a number of genotoxicity studies, it induced structural 

chromosomal aberrations in a Chinese hamster ovary cell assay. Chronic inhalation exposure of 

iodomethane was associated with an increased incidence of salivary gland squamous cell 

metaplasia in rats at 20 ppm; the NOEL was 5 ppm. In addition, degeneration of the olfactory 

epithelium, as well as perturbations of the thyroid-pituitary axis and thyroid histopathology 

findings, were reported at 60 ppm. Although the chronic inhalation/carcinogenicity study in rats 

demonstrated an increased incidence of follicular cell tumors, the USEPA determined that the 

operative mode of action for this response is the sustained perturbation of thyroid hormone 

homeostasis. Based on evidence that rats are more sensitive than humans to development of 

thyroid follicular cell tumors (in response to thyroid hormone imbalance), the USEPA classified 

iodomethane as Anot likely to be carcinogenic to humans in the absence of altered thyroid 

hormone homeostasis.@ 

The USEPA considered toxicity data and information to develop a physiologically-based 

pharmacokinetic (PBPK) model to better characterize the exposures associated with the critical 

effects of iodomethane. For this purpose, a human study of comparative fetal cord blood and 

maternal blood iodide levels was conducted. The USEPA concluded from this study that human 

fetuses do not concentrate iodide relative to maternal iodide concentration. These chemical 
Ms. Teresa McMullin 

 

4.

specific data were used to better estimate human equivalent concentrations (HECs) for the 

aforementioned critical effects from the appropriate toxicity study. The HECs were then used in 

the USEPA=s bystander and occupational risk assessments. 

The USEPA estimated HECs for a number of toxicity endpoints for acute-, 

short/intermediate-, and long-term occupational and bystander inhalation exposures. For acuteterm occupational and bystander exposures, toxicity endpoints included nasal histopathology in 

the subchronic rat study, fetal losses in the rabbit developmental toxicity study, and 

neurotoxicity in rats. Respective HECs for these endpoints were estimated to be 4.5 ppm, 7.4 

ppm, and 

10 ppm for bystander exposures and 5.8 ppm, 23 ppm, and 10 ppm for occupational exposures 

(the difference in HECs between these two groups is in part due to different assumptions for 

duration of exposure). For short/intermediate-term exposures, an estimated HEC of 1.25 ppm 

from the rat multigeneration reproduction study (decreased pup weight, weight gain and thymus 

weights and delays in vaginal patency) was selected for bystander exposures and an estimated 

HEC of 3.7 ppm from the rat subchronic toxicity study (nasal histopathology) was selected for 

occupational exposures. Estimated HECs of 0.89 ppm and 3.75 ppm from the rat chronic 

toxicity/carcinogenicity study (increased incidence of salivary gland squamous cell metaplasia) 

were selected for long-term bystander and occupational exposures, respectively. For 

determining margins of exposure (MOEs), the USEPA compared acute-, short/intermediate-, and 

long-term occupational and bystander estimated inhalation exposures to these estimated HECs. 

The USEPA reported the results of an extensive bystander and occupational risk 

assessment for inhalation exposures to iodomethane from its labeled use on fields. A range of 

MOEs and buffer zone distances were estimated in the risk assessment by analyzing a range of 

input factors. These factors included field size, application rate, emission rates from three 

different application types (flat fume, raised bed and drip irrigation), environmental factors at 

five different sites in California, Michigan, and Florida, and three toxicity endpoints (nasal 

lesions, fetal loss and neurotoxicity). Overall, the MOEs estimated for bystander exposure 

indicated that iodomethane exposures did not exceed USEPA=s level of concern at certain buffer 

zone distances. Occupational exposures and risks exceeded the USEPA =s level of concern for 

some workers (tractor drivers, copilots, tarp monitors and shovelers) when no respiratory 

protection is used. Consequently, an air purifying respirator, as well as loose fitting or well 

ventilated long-sleeved shirt and long pants, shoes plus socks, and a full-face shield are required 

on the labels for all workers. A five-day restricted entry interval after application was estimated 

to be adequate to not exceed the USEPA=s level of concern, even without respiratory protection. 

For this risk assessment, the USEPA considered a target MOE of 30-fold or greater to provide 

adequate bystander and worker protection. The 30-fold value is comprised of a 10-fold 

uncertainty factor to account for intra-species differences and a 3-fold uncertainty factor to 

account for pharmacodynamic differences between species (pharmacokinetic differences were 

accounted for in the PBPK modeling). 

There are no chemical specific federal or State drinking water/groundwater standards for 
Ms. Teresa McMullin 

 

5.

iodomethane. Based on its chemical structure, iodomethane falls under the 5 microgram per liter 

New York State drinking water standard for Aprincipal organic contaminants@ (10 NYCRR 

Part 5, Public Water Systems). 

The available information on iodomethane and the Midas7 end products indicates that 

they caused some toxicity following acute exposures in laboratory animals and are severe skin 

and eye irritants. In addition, iodomethane was shown to cause nasal degeneration, 

developmental/reproductive toxicity, neurotoxicity and thyroid perturbations leading to tumor 

development. Based on their modeled air impacts and estimated HECs, the USEPA determined 

that the proposed uses of these products should not pose significant risks to workers or the 

general public when used according to the strict provisions of the product labels. Despite the 

toxicity concerns and the need for extensive use requirements, iodomethane was federally 

registered (conditionally for a period of one year, to expire on October 5, 2008) as a potential 

replacement for methyl bromide. 

The New York State Department of Health (NYSDOH) has concerns for the use of the 

Midas7

 products. The directions for use of these products are extremely complicated and 

restrictive. The level of complexity and the use restrictions on the label (e.g., no use within a 

quarter of a mile of any occupied sensitive site, buffer zone calculations) could make it difficult 

to use these products in a manner that is compliant with the label. In addition, iodomethane 

poses several toxicity concerns and the four application methods listed on the product labels 

(raised bed-shank injection, raised bed-drip application, broadcast/flat fume-shank injection and 

auger probe-deep injection) allow for significant worker exposure potential to the active 

ingredient. Also, NYSDOH has concerns for exposure to bystanders and nearby residents from 

both routine applications and mishaps associated with the application of these products. While 

the label restriction states not to use the products within a quarter of a mile of any occupied 

sensitive site (e.g., schools, daycare centers, nursing homes etc.), the labels do not require such a 

buffer zone for residential properties. Given the potential exposure of nearby residents, some of 

who may be children, pregnant women, elderly or those with preexisting medical conditions, 

such a restriction seems warranted. This could be a particular problem if an accidental release 

were to occur as iodomethane is very volatile and hundreds of pounds of product are needed to 

treat even relatively small fields. Although NYSDOH did not review the properties of the 

coactive ingredient in the Midas7

 products, chloropicrin, they note that this compound has 

significant toxicity and irritant properties of its own, and has a very strong pungent odor. In 

addition, USEPA has registered these iodomethane products conditionally for a short term while 

it reviews soil fumigants categorically. Depending on the outcome of their evaluation, the 

registration status and/or restrictions on iodomethane products may change. 

ENVIRONMENTAL FATE RISK ASSESSMENT: Iodomethane Technical (99.8% 

iodomethane) is labeled for formulation or repackaging purposes only. 

The six end-use products contain various mixtures of iodomethane and chloropicrin 

(Chemical Code 081501) and are labeled for preplant fumigations of fields intended for 
Ms. Teresa McMullin 

 

6.

commercial production of certain listed crops and field-grown ornamentals to control soil-borne 

pests including weed seeds, nematodes, insets and diseases. Chloropicrin is a component of 

products currently registered in the State for the preplant fumigation use pattern. All of the 

products are classified as restricted use pesticides by the USEPA due to acute toxicity. 

Midas7 98:2 (97.8% iodomethane:2% chloropicrin), Midas7 25:75 (24.95% iodomethane: 

74.63 chloropicrin), Midas7 33:67 (32.93% iodomethane 66.67% chloropicrin), Midas7 50:50 

(49.90% iodomethane:49.75% chloropicrin) are labeled for application via three preplant soil 

fumigation techniques: 1) raised bed soil fumigation for field-grown ornamentals, peppers, 

strawberries and tomatoes; 2) broadcast/flat fume soil fumigation for field-grown ornamentals 

peppers, strawberries, tomatoes, turf, stone fruits, tree nuts, vines (table, raisin and wine grapes) 

and nurseries; and 3) deep injection auger-probe for stone fruits, tree nuts, vines and field-grown 

ornamental trees and shrubs. 

Midas7

 EC Bronze (49.90% iodomethane:44.78% chloropicrin) and Midas EC Gold 

(32.93% iodomethane:61.69% chloropicrin) are labeled for preplant raised bed drip irrigation 

(chemigation) for field-grown ornamentals, peppers, strawberries and tomatoes. 

Midas7

 98:2--One gallon contains 18.5 lbs iodomethane and 0.4 lbs chloropicrin and the 

maximum broadcast/flat fume application rate is 9.3 gallons/acre. The maximum application 

rate is 172 lbs iodomethane/acre. The maximum application rate for preplant deep injection 

auger-probe application is 450 lbs ai/a/day. There are no inerts. 

Midas7

 25:75--One gallon contains 3.8 lbs iodomethane and 11 lbs chloropicrin and the 

maximum broadcast/flat fume application rate is 46.4 gallons/acre. The maximum application 

rate is 176 lbs iodomethane/acre. The maximum application rate for preplant deep injection 

auger-probe application is 118 lbs ai/a/day. There are no inerts. 

Midas7

 33:67--One gallon contains 5 lbs iodomethane and 10.1 lbs chloropicrin and the 

maximum broadcast/flat fume application rate is 35.1 gallons/acre. The maximum application 

rate is 176 lbs iodomethane/acre. The maximum application rate for preplant deep injection 

auger-probe application is 152 lbs ai/a/day. There are no inerts. 

Midas7 50:50--One gallon contains 7.93 lbs iodomethane and 7.91 lbs chloropicrin and 

the maximum broadcast/flat fume application rate is 22 gallons/acre. The maximum application 

rate is 174 lbs iodomethane/acre. The maximum application rate for preplant deep injection 

auger-probe application is 172 lbs ai/a/day. There are no inerts. 

Midas7 EC Bronze--One gallon contains 7.93 lbs iodomethane and 7.12 lbs chloropicrin 

and the maximum raised bed drip irrigation (chemigation) application rate is 22 gallons/acre. 

The maximum application rate is 174 lbs iodomethane/acre. The inert is not a solvent carrier. 

Midas7

 EC Gold--One gallon contains 5 lbs iodomethane and 9.31 lbs chloropicrin and 

the maximum raised bed drip irrigation (chemigation) application rate is 35.1 gallons/acre. The 

maximum application rate is 176 lbs iodomethane/acre. The inert is not a solvent carrier. 
Ms. Teresa McMullin 

 

7.

Solubility: The solubility of iodomethane is 1,420 mg/l. 

Hydrolysis: (MRID 45593705) In a study that USEPA found to be acceptable, the half-life in 

pH 7 buffer at 25 degrees was 93.67 days with methanol as the major transformation product. At 

pH 4, the half-life was 105 days, and at pH 9 it was 108 days. 

Soil Photolysis: (MRID 45593706) In a study that USEPA found supplemental and upgradable, 

the half-life in a radiated soil was determined to be approximately 11.5 days. Methanol and 

fomaldehyde were major transformation products. 

Aqueous Photolysis: (MRID 46332701) Sufficient information was submitted, so together 

with MRID 45593706 (not submitted), USEPA found the studies to be acceptable. The half-life 

is 

13 days (taken from the September 17, 2003 USEPA memorandum on the review of 

environmental fate data). 

Aerobic Soil Metabolism: (MRID 455937070) In a study that USEPA found acceptable, the 

half-life in a sandy loam soil (pH 6.5, %OC 1.48) was 2.1 hours. USEPA indicated that the rapid 

half-life was due to volatilization rather than microbial degradation. However, carbon dioxide 

was detected, so some degree of microbial degradation did take place. 

Anaerobic Aquatic Metabolism: (MRID 45593708) In a 14-day study that USEPA found 

acceptable using a sandy clay loam (pH 8.0, 2.8% OM)/water system (pH 7.94), the half-life in 

the entire system was 40.2 hours, in the water was 38.8 hours and in the sediment 38.1. No 

major degradates were found. 

Adsorption/Desorption: (MRID 45593709; no DER submitted) (MRID 46332702) USEPA 

found this study to be supplemental. %OC ranged from 1.02 to 4.3 and the pH ranged from 

6.2 to 7.9. 

Soil Type %OC 

 

Soil pH 

Adsorption 

Koc 

Desorption 

Koc 

Swiss NA NA 28 144 

California NA NA 61 317 

Ohio NA NA 27 67 

German NA NA 14 74 

Oregon NA NA 43 134 

Terrestrial Field Dissipation: (MRID 45593711) USEPA found this study acceptable. In a 

fine loamy sand (pH 6.4, %OM 2.25), the half-life was 4.8. In a sandy loam (pH 7.0, %OM 

2.02), the half-life was 5.0 days. No major transformation products were found. 
Ms. Teresa McMullin 

 

8.

Modeling: Staff modeled iodomethane on Riverhead soil using a Koc of 34.8, a half-life of 

5 days and the maximum application rate of 176 lbs ai/a/year. The model projected two peaks, 

one at about 110 ppb and one at just over 200 ppb. Modeling half the application rate resulted in 

two peaks, one at about 50 ppb, one at about 90 ppb. No major transformation products were 

found in either the aerobic metabolism or the terrestrial field dissipation study, so there were no 

degradates to model. 

Groundwater Review Summary: Modeling the raised bed or broadcast/flat fume application 

rates for the end-use products projected two large peaks of leachate. 

The last two sentences in the Environmental Risks Conclusions (Page 3 of 37) of the 

Environmental Fate and Ecological Risk Assessment for the Registration of Iodomethane 

(undated) state: 

AHowever, since this compound is very soluble in water, there is the possibility of 

leaching to groundwater, if slicing or removal of the tarpaulin coincides with, or is 

followed soon by, a rain event. EFED recommends adding cautionary language to the 

label to prohibit the slicing or removal of the tarpaulin if it is raining or if rain is expected 

within 48 hours.@ 

This cautionary language does not appear on any of the end-use product labels. With a 

terrestrial dissipation (tarp-covered) half-life of 5 days, removal of the tarp shortly after 5 days 

would leave half the applied product available to leach. Should a rain event coincide with tarp 

removal, significant leaching would be possible. Therefore, Engineering Geology staff questions 

the absence of this cautionary text on the end-use products= labeling. 

In addition, prior to making a final determination on the impact to groundwater for the 

products bearing the Preplant Deep Injection Auger-Probe Application method, staff have the 

following questions: 

1. For the Preplant Deep Injection Auger-Probe Applications on Midas7 98:2, Midas7 25.75, 

Midas7 33:67, and Midas7 50:50 labels, the labels all state, under the section 

PROCEDURES PRIOR TO, DURING AND AFTER ALL APPLICATIONS that 

ADuring All Applications: $ Immediately cover treated areas with a plastic tarpaulin for a 

minimum of 5 days.@ Please describe the type of tarpaulin that will be used around the 

trees. 

2. For Midas7 98:2, staff calculated the application rate for Preplant Deep Injection AugerProbe Application to be 450 lbs iodomethane/a/day, because the label states that you can 

treat 230 trees per acre per day at 2 lbs product per tree. Please clarify that this is the 

correct application rate. 

3. For all of the products, what is the maximum number of trees that might be expected to 
Ms. Teresa McMullin 

 

9.

be treated per acre? Our calculations indicated that at a spacing of 10 feet on center, 

there could be 432 trees per acre. Are trees ever planted closer than a 10 foot grid 

pattern? 

Until these questions are answered, there is not enough information in the application 

package to determine impact to groundwater. 

TECHNICAL ISSUES SUMMARY: There are human health concerns for the use of the 

Midas7 products due to the level of complexity of the use directions and potential for exposure to 

bystanders and nearby residents from both routine applications and mishaps associated with the 

application of these products. While the product labels restrict use of the products within a 

quarter of a mile of any occupied sensitive site (e.g., schools, daycare centers, nursing homes 

etc.), the labels do not require such a buffer zone for residential properties. Given the potential 

exposure of nearby residents, some of who may be children, pregnant women, elderly or those 

with preexisting medical conditions, such a restriction seems warranted. This could be a 

particular problem if an accidental release were to occur as iodomethane is very volatile and 

hundreds of pounds of product are needed to treat even relatively small fields. 

Based on the environmental fate data, LEACHP simulations, and lack of cautionary label 

text prohibiting the slicing or removal of the tarpaulin if it is raining or if rain is expected within 

48 hours, the potential for iodomethane to impact groundwater/drinking water resources in 

New York State cannot be discounted. 

Furthermore, there are questions regarding the need for iodomethane use in the State. 

According to data obtained from the New York State Pesticide Sales and Use Reporting 

database, fumigants, including methyl bromide, are not widely used in the State. Although 

iodomethane may have some global benefit as a methyl bromide replacement, the risks 

associated with its use in New York State appear to outweigh the potential benefits. 

The Department accepts your request for withdrawal of the applications to register 

Iodomethane Technical and six end-use Midas7

 products.

Please note that Arysta may resubmit applications to register the subject products. The 

applications must be accompanied by new application fees, meet the additional application 

requirements for products containing a new active ingredient listed in 6 NYCRR Part 326.16, 

and address the human health and environmental fate questions/issues noted above. 

You are reminded that any unregistered pesticide product may not be sold, offered for 

sale, distributed, or used in New York State. 
Ms. Teresa McMullin 

 

10.

Please contact our Pesticide Product Registration Section, at (518) 402-8768, if you have 

any questions. 

Sincerely, 

 Maureen P. Serafini 

Maureen P. Serafini 

Director 

Bureau of Pesticides Management 

ecc: A. Grey/E. Horn, NYS Dept. of Health 

R. Mungari, NYS Dept. of Ag. & Markets 

W. Smith, Cornell University, PSUR