Wisconsin aerial application operator and NAAA Government Relations Chairman Damon Reabe was in Washington, D.C., last week to represent aerial applicators on the EPA’s Pesticide Program Dialogue Committee (PPDC).

The PPDC is an important federal advisory committee and a forum consisting of diverse stakeholders to provide feedback to the EPA’s Office of Pesticide Programs on various pesticide regulatory, policy and program implementation issues. Stakeholders include academia, state and local regulatory officials, environmental activists, grower groups and crop protection product manufacturers.

Having an NAAA representative on the PPDC is important to the aerial application industry, particularly in light of efforts to push: 1) unnecessary and burdensome language on pesticide labels; 2) drift reduction technology protocols; 3) water permits; 4) proposed regulatory changes to the Worker Protection Standards for pesticide applicators and certification for pesticide applicators; 5) endangered and threatened species criteria involved in the registration of crop protection products; 6) protective measures for pollinators that the agency is considering; and 7) a variety of other regulatory proposals related to pesticides that the Agency expects to release soon.

A major topic of discussion was the minimum age requirement for pesticide applicators. An ag labor representative on the PPDC expressed shame on the EPA for stating that it is planning to take comments on potentially lowering age requirements from 18 to 16. The Obama Administration raised the requirement two years ago resulting in labor shortages. “One point of clarification on this particular rule is that there is a current exemption for family members of farmers to get trained to handle restricted use pesticides at the age of 16,” said Reabe at the meeting and addressing the labor representative’s statement. “At the last meeting I pointed out that aerial application companies are typically small family owned companies, and we were interested in having the provision of family members that applies to farms be applied to our small business because they operate much like farms.”

A notice of proposed rule making on minimum age requirements is expected in August or September for formal comments to be submitted to the agency.

During a discussion on pesticide resistance, Reabe was able to explain to members the link between preventing resistance and aerial application, saying, “I just want to make sure there is a broader look during the registration process at the speed at which resistance develops when you cannot make an application to control a pest in a timely manner, and how that relates to aerial application, we want to make sure the Office of Pesticide Programs is keenly aware that that’s a tool that is used by integrated pest management practitioners and it’s an important tool because obviously there are going to be scenarios where soil conditions aren’t going to allow for ground application, and if the producer does not have the opportunity to control that particular pest at that critical time, the likelihood of there being resistant survivors increases.”

Reabe also drew connections between buffer zones and pest resistance. “The use of buffer zones in and of itself is one of the most effective ways to speed up pesticide resistance because you are going to expose pests to low doses of the pesticide, which is in fact how pesticide resistance is developed. So that needs to be a major consideration when making these applications,” said Reabe.

The PPDC also discussed the registration process for biopesticides, and Reabe stressed the importance of label uniformity across both conventional and biopesticide products. “The aerial application industry is very interested in biopesticides, and we think that our industry is going to play a very critical role in getting those products out in a timely manner so that they are effective.... Having these labels be of a format that is extremely similar to the conventional products that we are using, it will simply make them easier for us to find the information so we can handle the products appropriately,” Reabe said.

The next PPDC meeting will be held in October. Many participants expressed interest in further discussion of biopesticides.

Damon Reabe, Wisconsin aerial applicator (middle), sits at the table with other stakeholders involved in pesticide policy at the most recent EPA Pesticide Program Dialogue Committee meeting.