On Monday, NAAA submitted comments to the Environmental Protection Agency (EPA) to argue against aerial restrictions in the agency’s proposed interim decision for paraquat. The proposed interim decision recommended banning all aerial applications of paraquat except for desiccating cotton.
The EPA is required by the Federal Insecticide Fungicide and Rodenticide Act (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. The proposed aerial ban was based on faulty drift modeling and a failure to require combining personal protection measures for pesticide handlers. The multiple-use restriction was proposed with the erroneous belief that the aerial application of paraquat is not critical to any part of U.S. agriculture besides cotton production.
NAAA’s comments referenced and included letters of support and data from several state agricultural aviation associations: Arkansas Agricultural Aviation Association, California Agricultural Aircraft Association, Louisiana Agricultural Aviation Association, Mississippi Agricultural Aviation Association, Association of Montana Aerial Applicators and North Dakota Agricultural Aviation Association. Letters of support were also received and included with NAAA’s comments from the Arkansas Agricultural Consultants Association, University of Arkansas System Division of Agriculture, Southern Ag Consulting and the National Alliance of Independent Crop Consultants.
In addition to NAAA’s comments, NAAA authored and submitted a letter written on behalf of grower groups whose members rely on the aerial application of paraquat. These comments highlighted some of the main points from NAAA’s comments and noted all the crops that depend on aerial applications of paraquat, including soybean, sunflower, potato, rice, wheat, corn and dry bean crops. The letter was signed by the Council of Producers and Distributors of Agrotechnology, National Association of Wheat Growers, National Cotton Council, National Sunflower Association, Washington Friends of Farms & Forests, USA Rice and the Association of Washington Aerial Applicators.
NAAA’s comments addressed and questioned, once again, the EPA’s use of the Tier 1 model in AgDRIFT to estimate drift from aerial applications. This model uses many inaccurate assumptions and substantially overestimates the risk of drift associated with modern aerial applications. These faulty assumptions include a smaller than commonly used droplet size, a swath displacement shorter than industry standards, a slight inversion present during the application despite being prohibited on the label, wind speed measured at a height appropriate for ground applications instead of aerial applications and modeling the application to bare ground instead of a standing crop. NAAA referred the EPA to a letter submitted to the EPA’s Office of Pesticide Programs in June 2020 for a detailed analysis of all the Tier 1 model’s inaccuracies and how to use the Tier 3 AgDRIFT model to improve the accuracy of aerial drift estimates.
NAAA also commented on the EPA’s risks of concern related to pesticide handlers. The proposed interim decision for paraquat noted there were inhalation risks to mixers and loaders (based on EPA models). These risks were higher for aerial applications because of the high number of acres that can be treated daily using agricultural aircraft. NAAA proposed requiring both a closed loading system and an elastomeric half facepiece cartridge respirator when mixing and loading paraquat for aerial applications. The EPA recommended this same combination on the recent proposed interim decision for triphenyltin hydroxide (TPTH), which NAAA referenced. NAAA also proposed banning flaggers for aerial applications of paraquat, which according to its industry surveys are no longer used by the industry.
After addressing these concerns, NAAA’s comments turned to the EPA’s assertion that aerial application only accounts for 3% of the total acres to which paraquat is applied. NAAA used data and letters from the associations listed above and data from the California Department of Pesticide Regulation provided by CAAA to refute this, proving that aerial application of paraquat is critical for, among other things, desiccation of soybeans and control of herbicide-resistant weeds, particularly in the southern U.S.
The full comments NAAA submitted in defense of the safety and importance of aerial applications of paraquat can be read here. NAAA will be commenting on numerous registration review documents in 2021, including a proposed interim decision for chlorpyrifos and endangered species assessments for glyphosate. NAAA remains committed to ensuring your operation has access to the products your customers demand be applied aerially.