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National Agricultural Aviation Association

NAAA Submits Comments to EPA to Protect Aerial Applications for Two Pesticides

July 11, 2024

Last week NAAA submitted comments to the EPA on amended proposed interim decisions (PID) for the pesticide active ingredients captan and ziram. The amended PID for ziram proposed to ban all conventional uses, keeping only antimicrobials uses. The reason for the proposed ban was human health risks to both bystanders from drift and occupational risks to mixers and loaders and pilots. NAAA’s comments addressed the drift concern by reminding EPA that their current drift model dramatically overestimates the amount of drift from aerial applications. To address the risks to pilots and mixers and loaders NAAA suggested daily acreage and rate limits when making aerial applications of ziram.

The amended PID for captan proposed to ban aerial applications of all the dry formulations, allowing only liquid formulations to be used for aerial applications. The concern driving the proposed ban is inhalation risks for mixers and loaders. As alternative to the ban, NAAA proposed requiring a PF50 respirator when mixing and loading dry formulations as well as a daily limit on the number of acres a mixer and loader can load for in support of aerial applications. The amended PID for captan did increase the maximum wind speed limit allowed for aerial applications from 10 to 15 mph based on NAAA’s prior comments on the original PID.

Click here to read the comments on the ziram PID and here to read the comments on captan. The are several more pesticide registration review activities NAAA will be commenting on in the coming months to continue to ensure aerial applications.

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National Agricultural Aviation Association
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  • About
    • About Ag Aviation
      • Industry Facts, Environmental Benefits and FAQs
      • The Industry’s History
      • Ag Aviation Security
    • Board & Officers
    • NAAA Staff
    • NAAA Member Code of Conduct
    • State and Regional Associations
    • NAAA Professional Operating Guidelines
    • Related Entities (Industry Links)
    • Help – Knowledge Base
  • Ag Aviation Expo
    • Expo Details, Info & Overview
    • Schedule
    • Registration
    • Travel and Hotel
    • Exhibiting
    • Sponsors
    • Wire & Obstruction Course
    • Kickoff Breakfast
    • General Session
    • Live and Silent Auctions
    • Awards
  • Career
    • Become an Ag Pilot / Operator
    • Job Board
    • Flight Schools
    • Scholarships
    • Resources
      • NAAA Professional Operating Guidelines (POG)
      • Agricultural Airman Guidelines (AAG)
      • NAAA’s Guide to Starting a Part 137 Operation
      • National Aerial Applicator’s Manual
      • AC 137-1B Certification Process for Agricultural Aircraft Operators
      • 14 CFR Part 137 Regulations
  • Membership
    • Join NAAA / Renew
    • Member Benefits
    • Membership Categories
    • Health Insurance Benefits
  • Education
    • PAASS
    • CAA (formerly C-PAASS)
    • Fly Safe Messages
    • Operation SAFE
    • Online Courses
    • NAAREF & Donors
    • Ag Aviation Accidents
    • Leadership Training Program
    • Scholarships
    • More
  • Communications
    • Agricultural Aviation Magazine
    • NAAA eNewsletters
    • NAAA 365 App
    • Media Relations Kit
    • Media Center
    • NAAA Headlines
    • Industry Surveys
    • 100th Anniversary
    • NAAA’s 50th Anniversary Video
  • Policy
    • Environmental Issues
    • Tax Issues
    • Transportation Issues
    • Towers
    • Uncrewed Aircraft Systems
    • Wind Turbines
    • AgAv PAC
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  • Find an Aerial Applicator
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