NAWG submitted comments this week on a cluster of guidance documents issued by the Environmental Protection Agency related to spray-drift.
The documents, issued in November, cover labeling requirements, interpretation and restrictions on spray-drift that most in the agriculture community see as not practicable on real-world farm operations.
In part, they would modify the current Worker Protection Standard, which currently prohibits application “in a way that will contact workers or other persons, either directly or through drift” to read “do not apply this product in a manner that results in spray [or dust] drift that could cause an adverse effect to people or any other non-target organism or site”.
CropLife says spray-drift occurs when wind gusts unexpectedly blow small droplets of chemical crop protection products into the air and take them away from their anticipated settling points. A variety of technology is employed to prevent this from happening, but it is largely accepted, including by EPA, that some drift will occur during chemical applications.
The November guidance documents would go beyond laws already in place to regulate chemical crop protection products and empower EPA enforcement officials to impose fines on those found in violation.
Effectively, these guidelines would reduce growers’ access to crop protection products that protect yields and prevent disease and insect infestation, which is particularly disturbing since production will have to increase by an estimated 70 percent by 2050 to feed the world’s growing population.
The comments said, in part:
“We strictly oppose removing the scientifically-based standard of risk assessment in the Federal Insecticide, Fungicide and Rodenticide Act (FIFRA) and replacing with it with a speculative, nonscientific and theoretical standard of zero tolerance. Unlike the FIFRA risk standard set and repeatedly confirmed by Congress, EPA’s proposed spray drift policy adopts a precautionary principle approach and effectively replaces FIFRA’s risk-benefit standard with a new zero-risk standard…
“EPA’s enforcement guidance for the new spray drift FIFRA label language would force states to become assessors of theoretical risks, and applicators to risk lawsuits every time they work. State agencies generally do not have the toxicology endpoints or risk assessments at their fingertips to make these decisions. Major private-sector advances have been made in drift-reduction technology including GPS guided shutoff nozzles, low drift spray tips and product formulations, foaming agents and adjuvants.”
Concern about the spray-drift restrictions is widespread through the agriculture community, and CropLife America, the crop protection product’s trade association, has established an online petition for growers and others to sign regarding the proposals.
The CropLife petition urges EPA to maintain FIFRA’s risk-based standard of “no unreasonable adverse effects” and remove vague and unenforceable terminology from their proposals. The petition also urged EPA to not impose unnecessary buffers and develop risk-based tolerances for non-target areas.
The complete petition and a variety of background information on the spray-drift issue can be found and online on CropLife’s spray drift Web page at http://www.croplifeamerica.org/pesticide-issues/spray-drift. There will also be opportunities to learn more about and sign the petition at the upcoming Commodity Classic.
NAWG’s comments are available online at www.wheatworld.org/environmentalissues.