Last week NAAA submitted comments to the EPA as part of the re-registration review process of pesticide active ingredients. The EPA is required by FIFRA to review the registrations for all crop protection products every 15 years. All the comments submitted were on proposed interim decisions. Interim decisions are being used by the EPA instead of a full re-registration of a product because Endangered Species Act and pollinator protection assessments still need to be completed for most products.

The active ingredients commented on were Buprofezin, Diflubenzuron, Oxytetracycline, Prohexadione calcium, Pymetrozine, Streptomycin, Tebuthiuron, and Thiobencarb. The focus of the comments varied depending on the proposed interim decisions. For Buprofezin NAAA suggested a medium droplet size requirement instead of coarse because this active ingredient is a contact insecticide which would work better with a slightly smaller droplet size. Also suggested was a 15 mph wind speed limit instead of 10 mph. Most of the recent interim decisions have used the 15 mph limit, which NAAA pointed out. The proposed interim decision for Thiobencarb also recommended a 10 mph wind speed limit for applications, so NAAA made the same argument in favor of a 15 mph limit instead.

The proposed interim decision for Pymetrozine was more troubling in that the EPA recommended a ban on aerial application because of exposure risk to mixers and loaders. NAAA pointed out flaws in the logic used to model the exposure risks and recommended additional PPE be required instead of banning aerial. The proposed interim decision itself stated that the use of a respirator would reduce exposure risks to an acceptable level, so NAAA recommended they require respirators instead of banning aerial application of the product.

For Tebuthiuron, EPA proposed to eliminate the use of dry flowable and water dispersible granules for aerial application, again because of exposure risk to mixers and loaders. Comments focused again on flaws in the logic used to estimate risk and suggestions for additional PPE. The proposed interim decision for Diflubenzuron included all of the label suggestions made by NAAA in previous communications so comments were limited to a suggestion to improve the language about avoiding applications during temperature inversions.

The final two comments were on products that have not been applied by air: Oxytetracycline and Streptomycin. The proposed interim decisions recommended label language to specifically prohibit the use of aerial application. Even though these products have not been applied by air before, air blast sprayers have been used as an application method. NAAA commented that aerial applications should be on the label as it is a superior application method compared to air blast.