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The Pesticide Label in the Era of Dicamba Tolerant Crops (05/17/18)

Considerable ink and terabytes of information has been published about the new dicamba formulations. But I want to share with you the competing needs or perspectives various entities have with regards to pesticide labels.

The Pesticide Label in the Era of Dicamba Tolerant Crops

Considerable ink and terabytes of information has been published about the new dicamba formulations. But I want to share with you the competing needs or perspectives various entities have with regards to pesticide labels.

The other day I was stunned when a spokesman for a pesticide manufacturer suggested that applicators really, until NOW, don’t read anything more than the “Directions for Use” section of the label. In part, it was a true statement. I think about spraying dandelions in my yard and since I have extensive experience with products registered for that use, my tendency is to go straight to the rate section, etc. It is human nature. But something fundamental changed since the widespread off target movement of dicamba in the summer of 2017. See Figure 1.

Andrew Thostenson

Before 2017, pesticide registrants developed labels primarily to convey information to their users in order to explain how to get the maximum benefit or profit from using the pesticide. In the process of developing the label, the registrant secondarily needed to incorporate risk mitigation measures into the label so EPA would actually allow the product to be sold.

Which brings us to EPA. When they evaluate a label, their primary goal is to minimize or mitigate risks to an acceptable level. The label is the critical tool to accomplish this. Efficacy, with some notable exceptions, is not terribly important. They want the label to protect the applicator, sensitive plants, water resources, bystanders, etc. If the instructions on the label do that, then their tendency is to register the product and approve the manufacturer’s label.

Users of pesticides first and foremost are interested in controlling the pest to avoid loss or protect their crop. Their interest mostly aligns with the manufacturer, not necessarily with EPA’s view. Though they too do not want to hurt themselves or others, that is not the prime consideration.

If you are a state pesticide regulatory agency, you want a label that makes sense to the user. It needs to be clear and enforceable because enforcement is their primary interest, mitigating risk and the user making a profit is not their focus.

Finally, if you are the general public or an environmental advocate, your highest concern is getting a plentiful and safe food supply without worrying about getting cancer, having your children harmed, and/or having your garden destroyed by spray drift. Environmentalists also place enormous emphasis on protecting endangered species, water quality, and the air. For both entities, the label does not impact them directly, but indirectly it does by reducing risk to an acceptable level. So they align mostly with EPA.

Until 2017, all these groups had their very own narrow areas of emphasis. That changed this past summer. EVERYONE is now focused squarely on the label to accomplish all these goals simultaneously and seamlessly. Which means ultimately it is now in the hands of the person operating the sprayer. As the label so frankly reminds us:

“AVOIDING SPRAY DRIFT AT THE APPLICATION SITE IS THE RESPONSIBILITY OF THE APPLICATOR. The interaction of equipment and weather related factors must be monitored to maximize performance and on-target spray deposition. The applicator is responsible for considering all of these factors when making a spray decision. The applicator is responsible for compliance with state and local pesticide regulations, including any state or local pesticide drift regulations.”

Andrew A. Thostenson

Pesticide Program Specialist


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