NAAA eNewsletter - 08/13/2020

NAAA submitted comments to the EPA on Aug. 5 regarding the proposed interim decision for the reregistration of clopyralid. The EPA is required by FIFRA to review the registrations for all crop protection products every 15 years. Interim decisions are being used by the EPA instead of a full reregistration of a product because the biological evaluations and pollinator protection assessments still need to be completed for most products.

Surprisingly, the proposed interim decision for clopyralid proposed requiring applicators to notify all property owners/operators for all properties they have made clopyralid applications to in writing about clopyralid’s persistence and restrictions on plant material and manure. NAAA strongly opposed this requirement, pointing out aerial applicators are frequently not involved in the decision-making process of selecting which pesticides should be used to treat the targeted pests and therefore should not be required to provide such educational materials to the property owners/operators.

NAAA also commented that the requirement would place an undue burden on aerial applicators and could have a significant negative impact on safety. Using its 2019 industry survey to make the case, NAAA detailed how a typical operator/pilot who treats wheat and barley—crops on which clopyralid is used—would need up to three additional hours per day to meet the notification requirements in the proposed interim decision. Forcing a pilot to spend three hours a day notifying landowners about compost contamination would dramatically increase fatigue for that pilot, and thus increase the chances of an accident.

NAAA also submitted comments to the EPA on a new herbicide being registered: pyridate. Aerial application of pyridate is banned, which NAAA opposed. The ecological and human health risk assessments for pyridate provided no evidence to support banning aerial application of this pesticide. The proposed label for pyridate states that it is important to make the application to broad-leafed weeds by the 4-leaf stage, indicating timing is important for an effective application. NAAA pointed out that aerial application is by the far the fastest and most timely way to apply any pesticide.

NAAA will continue to monitor and comment on all relevant pesticide registrations and reregistrations to ensure you have access to the products your growers need to feed the world’s growing population.