NAAA is constantly monitoring the Federal Register for
pesticide (re)registration notifications from the EPA. The Federal Insecticide
and Rodenticide Act (FIFRA) requires the EPA to review the registration of each
pesticide every 15 years to ensure that they are still safe to use. Research
conducted between the last registration review and the current one is assessed
to determine if the product should be registered again, and if so, are there any
changes that need to me made to the label, such as uses, personal protective
equipment, or drift mitigation strategies. NAAA works to ensure aerial
application remains an option on the products that are already labeled for
aerial application, and the label requirements remain realistic and not overly
burdensome.
Many of the pesticides up for registration review are
familiar, and NAAA staff are able to offer comments without a great deal of
input from members. On occasion though, a product may be up for review that is
unfamiliar. In some cases, a product may be familiar but certain uses, such as
on specialty crops, may be unknown to NAAA staff. For instance, a (re)registration
review interim decision recently submitted by the EPA recommended that aerial
applications be prohibited by the label. The reasoning from the EPA was that
there was a human hazard risk associated with mixing many loads of the product,
and they had been erroneously told by the manufacturer that the product was
never applied via aerial application. Input from members familiar with its
usage helped respond to the EPA to let them know that the product was applied
by air for certain crops.
In certain situations, such as when a product’s usage by air
might be limited to specialized crops or when the pesticide is unfamiliar to
staff, input from NAAA members is invaluable. NAAA is putting together a list
of members to contact based on crops those people are familiar with making
applications to. These individuals will be contacted by email when necessary to
determine use patterns for pesticides that are up for registration review. The
goal is to create a network of people that can assist NAAA when needed so that
any registration documents warranting comments are handled appropriately. If
you are interested in being on this list, please email Scott Bretthauer at Sbretthauer@agaviation.org with
your name, email address, and the crop for which you wish to provide expertise
on.