October 24, 2017
What do you do with 239 dicamba-drift complaints and no real way to tell how they happened?
The short answer: you require better records next time around.
When the Illinois Department of Agriculture received 239 dicamba-related complaints in 2017, they asked questions. Was it drift? Was it tank contamination? Was it an inversion?
In many cases, there wasn’t enough information to determine a cause, says Jean Payne, Illinois Fertilizer and Chemical Association. “IDOA faces a difficult task determining the causes of off-target movement if application records don’t exist,” she says, adding that XtendiMax, Engenia and Fexapan were not restricted-use pesticides in 2017, and recordkeeping was not required.
The recordkeeping rules will be different in 2018.
All certified applicators applying XtendiMax, Engenia and Fexapan are now required to complete dicamba-specific training, Payne says, and extensive recordingkeeping is mandatory.
“The U.S. EPA did an excellent job listening to the applicator community,” she says. “The majority of our members felt from the beginning that [in-season dicamba products] should be restricted-use pesticides.”
Chemical application expert Bob Wolf applauds the parent companies for addressing proper recordkeeping moving forward. “It’s my understanding that was one of the big issues in 2017,” he adds. “There was no way to prove anything.”
The new Engenia recordkeeping guidelines require 20 different pieces of information.
Here are the new recordkeeping requirements from the Engenia label. Payne says XtendiMax and Fexapan labels will be similar.
1. full name of the certified applicator
2. certification number of the certified applicator
3. product name
4. EPA registration number
5. total amount applied
6. application month, day and year
7. location of the application
8. crop or site receiving the application
9. size of area treated
10. training requirement: proof that the applicator completed training described in this section
11. application timing: whether the applicator applied this product preemergence, or the number of days after planting if the applicator applied this product postemergence
12. receipts of purchase: receipts for the purchase of this product
13. product label: a copy of this product’s label(s), and any state special local needs label that supplements this label
14. sensitive crops awareness: documentation that the applicator checked an applicable sensitive crop registry, or that the applicator surveyed neighboring fields for any sensitive areas or sensitive crops prior to application — at a minimum, records must include the date the applicator consulted the specialty crop registry or surveyed neighboring fields, and the name of the specialty crop registry the applicator consulted
15. spray system cleanout: documentation that the applicator complied with the section of this label titled:
“Spray System Equipment Clean-out” — at a minimum, records must include the date the applicator performed the required cleanout and cleanout method that the applicator followed
16. tankmix products: a list of all products (pesticides, adjuvants and other products) that the applicator tank-mixed with this product for each application — include EPA registration numbers in the case of any pesticides
17. start and finish times: the time the applicator begins and the time the applicator completes applications of this product
18. nozzle selection: which spray nozzle the applicator used to apply this product, and the nozzle pressure the applicator set the sprayer to
19. air temperature: the air temperature at boom height at the time the applicator started and finished applications of this product
20. wind speed and direction: the wind speed at boom height at the time the applicator started and finished applications of this product, and the wind direction at the time the applicator started and finished applications of this product
Certified applicators can create their own spray logs or use the tracking software in their sprayers.
Applicators and operators will not be required to submit records, Payne notes, but they do need to keep the records on file for two years if state or federal inspectors ask for them. Certified applicators are already accustomed to keeping records on restricted-use pesticides, but they will need to add the items above to their spray log for in-season dicamba applications.
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