Last Friday NAAA submitted three comments to the EPA for the agency’s re-registation review of pesticide active ingredients. The EPA is required by FIFRA to review the registrations for all crop protection products every 15 years to ensure dietary, water, environmental, occupational and endangered/threatened species safety. The active ingredients that NAAA commented on were for the following products: 2,4-DP-p, Clopyralid and Flumioxazin. The documents that EPA had submitted for comment were all risk assessments, conducted for each active ingredient to assess the risk to the environment and human health of the products being evaluated.

In all of the comments NAAA stated that the usage of the Tier 1 model in AgDRIFT for conducting the risk assessments is not an accurate representation of how modern aerial applications are conducted.  The faulty assumptions used in the model include a small droplet size, a non-dropped boom, a short swath offset, near-inversion conditions, and spraying over a bare surface. All of these assumptions result in a higher than realistic risk of drift assessment for aerial applications. NAAA provided more realistic assumptions and sources of data to back up those assumptions.

Additionally, for 2,4-DP-p the manufacturer had proposed banning aerial application. NAAA objected, pointing out that several of the use sites, including forests and rights-of-ways, are often applied to with aerial application. The 2019 NAAA Operators Survey Report was used to provide acreages for these sites. For Flumioxazin, the EPA found a risk of concern for mixing and loading dry flowable formulations for broadcast aerial applications for forestry, but the concern was alleviated with the use of a respirator in addition to baseline PPE. However, another risk of concern with the same formulation for ULV aerial applications for forestry, but using engineering controls for mixing and loading, was not alleviated with the use of a respirator. NAAA pointed out that this does not make sense – the use of engineering controls over baseline PPE should offer greater protection, and if the use of a respirator worked to reduce the risk when used in addition to the baseline PPE, it should certainly do so as well when engineering controls are used for mixing and loading.

NAAA will continue to monitor the pesticide registration review process and comment accordingly to the EPA. We will fight to make sure aerial applicators have access to the pesticides their customers need in order to control insects, diseases, weeds, and other pests.