NAAA recently submitted comments on the proposed interim decisions (PID) for two pesticide active ingredients. Proposed interim decisions are the second major step in the registration review process. They are preceded by the risk assessments that describe the modeled impact of the pesticide on human health and ecology. They are followed by the final interim decision. It is considered interim until the pesticide has undergone an evaluation to determine its effect on threatened and endangered species.
The PID for iprodione retained aerial application on the label and included drift mitigation language acceptable to the aerial application industry. It allows aerial applications in winds up to 15 mph, requiring a boom shortened to 65% of wingspan or 75% of rotor diameter for helicopters when wind speeds are above 10 mph. A medium or larger droplet spectrum is required, and applications during inversions are prohibited. These proposed drift mitigations have been seen on many PIDs over the last several years. The PID also proposed banning human flaggers for aerial applications. NAAA commented to the EPA that we agreed with the PID.
The PID for ferbam indicated that aerial applications of products containing it were already prohibited. The PID proposed eliminating most of the remaining crops and application methods, leaving only the use of a mechanically pressurized handgun sprayer on just three crops—peaches, nectarines and cranberries. The prohibitions were based mostly on risks to mixers and loaders. NAAA pointed out that by using the EPA’s occupational exposure data and a ferbam label, it was determined that the mechanically pressurized handgun sprayer would only be treating 3.3 acres a day versus the 350 acres treated by an ag aircraft. This would dramatically reduce the ability to make timely and efficacious applications. NAAA suggested allowing aerial application with the requirement that mixers and loaders supporting these applications be required to wear a double layer of clothing, gloves, eye protection and a half-face elastomeric cartridge respirator.
NAAA continues to monitor the EPA registration review process to ensure the aerial application industry has access to the products our customers need applied.
