US Environmental Protection Agency
Office of Pesticide Programs
Petition for Cyazofamid
April 2014
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September 6, 2013
iSK BIOSCIENCES
Nicole Williams. Registration Division
Document Processing Desk (REGFFF i (Sent \ia ; c-1 i \ *
01 lice of Pesticide Programs
U.S. HPA, Room S-4400
One P.)!oni;ic Yard (South Building)
277? South Crystal Drive
Arlington, VA 22202-4501
Phone number: 703-308-5551
SUBJECT: ATTENTION: MINOR USE - EXCEt JSIVH USE REQUEST - PR1A MOOU/"
CYAZOFAM1D TECHNICAL (EPA REGISTRATION NUMBER 71512-2)
RANMAN 400SC (EPA REGISTRATION NUMBER 71512-3)
Dear Ms. Williams,
ISK. Biosciences Corporation (ISKBC. EPA Company Number 71512) is submitting this petition
for the extension of the exclusive use period for Cya/ofamid under F1FRA section 3(c}( 1 >< F)(ii).
and requests that EPA grant a 3 year extension for the Cyazofamid data. Please find enclosed with
this letter three (3) copies of the petition along with one CD and a copy of the payment receipt as
noted below;
Petition; Application for Extension of the Exclusive IJ so Period for Cyazofamid.
One Compact Disc of the complete petition document (fully linked. PDF tl.e).
One copy of the PRIA Code MOO? Fee Payment Email Receipt for $5000.
FI ERA section 3(c)( 1 )(F){ii) provides for up to a 3 year extension of the exclusive use period for
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. Ranman 400SC end use
product (EPA Reg. No. 71512-3} containing Cyazofamid was first registered on November 12.
2004, and Technical Cyazofamid (EPA Reg. No. 71512-2) on November 9. 2004. The initial
registration included Cucurbit Vegetables (Crop Group 9): and potatoes and field tomatoes.
Potatoes and tomatoes are not part of the submission supporting the requested exclusive use
period extension. On August 1, 2008, EPA amended the RANMAN 400SC registration to add
Carrot, On July 29, 2009, EPA amended the RANMAN 400SC registration to add Grapes, fast of
the Rocky Mountains; and Fruiting Vegetables (Crop Group 8) and Okra. Further, on August 13.
2010, EPA amended the RANMAN 400SC registration to add Brassica (Cole) I.eafv Vegetables
(Crop Group 5) and Turnip Greens: Spinach; and flops. Note that these uses were registered
within seven years of the initial Cyazofamid registration. Minor uses included in the 2004, 2008,
2009 and 2010 registration actions are thus eligible for consideration in a request to extend the
exclus ve use period.
On September 14, 2012. EPA further amended the RANMAN 400SC registration to add basil:
succulent-podded and succulent-shelled beans; and expanded label from spinach to leafy greens
(Crop Subgroup 4A) including lettuce: and expanded from potatoes to tuberous and corm
I S K Biosciences Corporation
7470 Auburn Road, Suite A, Concord, Ohio 44077, U.S.A
tel: 440/357-4640 • fax: 440/357-4661
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Ms. W illiams
September 6. 2013
Page 2
vegetables (Crop Subgroup !C) and expanded fruiting vegetables crop Group 8 to Group 3-id.
I fowevcr, the crops added in September 14, 2012 amendment are not within the scope of tins
requested extension of the exclusive use period as the amendment was not within 7 years of the
initial Cyazofamid registration.
With this petition, 1SKBC provides justification and evidence for 4X minor use e.r<«ps in the above
crop groups, approved during the 7 year period following the initial registration, and meeting at
least one of the FIFRA criteria. 1 he available data on these crops and crop groups were reviewed
and analyzed and the eligibility of many more than 9 minor use erops was detennineo. The
evidence and justification are detailed in the enclosed petition, and ISKBC believes that
Cyazofamid fully meets the statutory criteria to qualify for a 3 year exclusive use extension. The
current exclusive use period for Cyazofamid expires in November 2014. If EPA grams the
requested extension, the new exclusive use period will expire November 12, 2017.
We appreciate EPA's efforts to implement this provision of FIFRA, and 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 an}' further information and if you ha\e any questions. I can
be contacted by photic at (440)-357-4653, h\ lax at <440)-357-4661, or by e-maii at
pe p 1 o wsk i m: w i sk be .com.
Michael A. Peplowski
Manager. Product Registrations
Enclosures
Cc: Lois Rossi, Director. Registration Division
Michelle Knorr.. KPA- Office of Genera! Counsel
William Chism. Specialty Crops Advisor
Sincerely,
1SK BIOSCIENCES CORPORATION
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