N-\^ *x^      US Environmental Protection Agency
  ^^ ^r    Office of Pesticide Programs

isSBzJ
 %.    ^N    Petition for Fluazinam
              October 15, 2010

-------
                                          ;>V BIOSCIENCES
 October 15, 2010                           "
Nicole Williams
Registration Division
EPA-Gffiee of Pesticide Programs
1200 Pennsylvania Ave,, NW, 7505P
Washington, DC 20460
Phone number: 703-308-5551

Robert Perlis
EPA- Office of General Counsel
1200 Pennsylvania Avc., NW, 2333 A
Washington, DC 20460
Phone number: 202-564-5636

Pat Cimino - Specialty Crops Advisor
EPA  Office of Pesticide Programs
!200 Pennsylvania Ave., NW, 7503P
Washington, DC 20460
Phone number: 703-308-9357

SUBJECT:         ATTENTION: MINOR USE - EXCLUSIVE USE REQUEST
                   FLUAZINAM TECHNICAL (EPA REGISTRATION NUMBER 71512-8)
                   OMEGA 500F (EPA REGISTRATION          715I2-I)
Dear Ms. Williams, Mr. Perlis, and Ms, Cimino,

ISK Biosciences Corporation (ISKBC, EPA Company Number 71512) is submitting this petition
for the extension of the exclusive use period for Fluazinam under FIFRA section 3(c)(l)(F)(ii),
and requests that EPA grant a 3 year extension for the Fluazinam data. Please find enclosed with
this letter three (3) copies of the following:

      Petition: Application for Extension of the Exclusive Use Period for Fluazinam; and
      Compact Disc containing copies of all  references reviewed  for and cited in the above
      petition.

FIFRA section 3(c)(l)(F)(ii) provides for up to a 3 year extension of the exclusive use period fbi
an active ingredient if it meets the qualifying criteria for 9 minor use crop registrations, obtained
within the specified 7 year period following the initial registration. Omega 500? end use p.-oduct
(EPA Reg, No, 71512-1) containing fluarinam was registered on August 10, 2001, ard Technical
Fluazinam  (EPA Reg. No. 71512-8) on March 5,  2003. On March 27, 20085 EPA amended the
Omega 500F registration to  add the following uses: Brassica  (Cole) Leafy  Vegetables (Crop
Group 5), including Turnip Greens (Crop Group 2); Edible-podded legume vegetables subgroup
(Crop Subgroup 6A except peas); Succulent shelled pea and bean  subgroup (Crop Subgroup 6B

                          ISK  Biosciences Corporation
               7470 Auburn Road, Suite A, Concord, Ohio 440??,  U.S.A.
                       tel: 440/357-4640 - fax: 440/357-4661

-------
 Ms. Williams, Mr, Perils, and Ms, Cimino
 October 15,2010
 Page 2
except peas); Dried shelled pea and bean (except soybean) subgroup (Crop Subgroup 6C except
peas); Bushberry subgroup (Crop Subgroup 13-07B); and Ginseng,

With this petition, TSKBC provides justification and evidence for more than 60 minor use crops in
the above crop groups, approved during the 7 year period following the Initial registration, and
meeting at least one of the FIFRA criteria. The available data on these crops and crop groups were
reviewed and analyzed and the eligibility of many more than 9 minor use crops were determined.
The evidence  and justification are detailed  in the enclosed petition, and ISKBC believes that
Pluazinam fully meets the statutory criteria to qualify for a 3  year exclusive use extension. The
current exclusive use period for Fluazinam expires August 10, 2011. If EPA grants the requested
extension, the new exclusive use period will expire August 10, 2014,

We appreciate BPA's efforts to implement this provision of FIFRA,    hope that the information
provided in this petition is helpful to EPA's evaluation of the extension request. We look forward
to working with the agency.

Please let us know if we can provide any further information and if you have any questions. I can
be contacted by phone at (440)-357-4653, by fax at (440)-357-4661, or by e-mail at
peplowskim@iskbc.com.
Sincerely,


ISK BIOSCIENCES CORPORATION
                           /

Michael A, Peplowski
Manager, Product Registrations
Enclosures

Cc:   Lois Rossi, Director, Registration Division
      Rick Tinsworth, Exponent
                           ISK Btoselences Corporation

-------