NAAA Submits Comments to EPA to Ensure Aerial Application Allowed for Two Pesticides

The PID for dicrotophos recommended the maximum application rate be reduced for aerial applications due to a risk of concern to mixers and loaders. NAAA recommended instead of reducing the rate, EPA instead require full PPE and a respirator when mixing and loading dicrotophos. Read NAAA comments on the PIDs for dicrotophos and dimethoate for additional details.

NAAA submitted comments last week to the EPA in response to the proposed interim decisions (PID) for two pesticides, dicrotophos and dimethoate. Both PIDs were based on risk assessments conducted using aerial drift estimates from the outdated and inaccurate Tier 1 model in AgDRIFT. Even though EPA has acknowledged they intend to move forward with NAAA’s recommendations to use the more accurate Tier 3 AgDRIFT model, older risk assessments are not being updated given EPA’s timeline to complete the current round of pesticide registration reviews.

The PIDs for both pesticides also require the use of wind-directional buffer zones to protect aquatic habitats and conservation areas. NAAA supported the use of wind-directional buffers instead of buffers zone that can never be sprayed but reminded EPA that the proposed buffer distances are based on the Tier 1 model and thus are unnecessarily long. Also, similar between the PIDs, was a 10-mph maximum wind speed limit. NAAA objected, pointing out numerous other pesticides that are allowed to be applied in a 15-mph wind. NAAA recommended EPA allow dicrotophos and dimethoate to be applied in winds up to 15 mph with the same mitigations used on many recent PIDs, such as a shorter boom length and greater upwind swath displacement when winds exceed 10 mph.