NAAA eNewsletter - June 30, 2022 | Happy Independence Day from NAAA!

Last week NAAA commented on the proposed interim decisions (PID) for three pesticides: captan, folpet and propiconazole. A PID is the second step in the pesticide registration review process, preceded by risk assessments and followed by the final interim decision and then an endangered species review.

The PIDs for captan and folpet were similar in that the EPA concluded mixing and loading dry formulations for aerial applications presented a risk of concern because of inhalation exposure. Initial exposure estimates for mixers and loaders are the same across all application methods, but they get multiplied by an estimated number of acres treated daily for each method. Because aerial application can treat far more acres daily than other application methods, the EPA assumes it is more likely for aerial application mixers and loaders to have greater exposure risks.

In the case of captan, the EPA proposed allowing only liquid formulations for aerial applications. NAAA countered by suggesting that while liquid formulations are more common, dry formulations may be the only thing available during certain busy parts of the season. To keep dry formulations available for aerial applications, NAAA proposed limiting the maximum daily acres and maximum application rate for aerial applications of dry captan formulations, as well as maximum PPE requirements for mixers and loaders.

Folpet is only available as dry formulations and can only be applied by aerial application on avocados. Like the argument NAAA made for captan, the comments to the EPA focused on limiting the maximum acres of avocados treated daily. The risk assessments completed by the EPA assumed 350 acres treated daily, which is much more than the average size of avocado farms, so restricting the daily acreage would have no real impact on applications treating a single avocado farm in a day and would lower the modeled risk of concern for mixers and loaders to a level acceptable to the EPA.

The PID for propiconazole 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. NAAA commented to the EPA that we agreed with the PID.

NAAA continues to monitor the EPA’s pesticide registration review docket and comment as necessary to ensure aerial application remains on the label.