Talk about soon-to-be registered dicamba and 2,4-D products and the topic of crop injury potential from spray drift and volatility are sure to come up. Concerns from some segments of agriculture are significant enough that the USDA recently required environmental impact statements on crops tolerant to these products. Few have been more outspoken regarding these concerns than Save Our Crops Coalition (SOCC). Associations representing 2,000 commercial fruit and vegetable growers from Pennsylvania to Illinois, as well as processor associations and several individual food processors, are worried about potential damage to their crops and more, according to Steven Smith, SOCC chair.

"These products are a real concern to our industry, but I fear that all of agriculture could get a black eye," said Smith. "The effect of economic injury to a grower is one thing. When you destroy grandma's garden, you've got a real problem. Whether gardens or fields, the community acrimony of suing neighbors is not going to be a good thing."

As the director of agriculture, Red Gold, Inc., Smith is all too familiar with such lawsuits. As the world's largest privately owned tomato processor, Red Gold had six cases of spray drift damage in 2013, estimated to cost $228,750 in losses. Although most such cases are settled out of court, Smith fears losses and lawsuits from drift and volatility caused injury could skyrocket if dicamba products in particular are introduced under their current suggested labels.

SOCC cited a survey of state pesticide control officials listing 2,4-D as the product most involved in spray drift incidents every year the survey has been taken and dicamba as the third most common for two years in a row. SOCC also pointed to Ohio State University research showing simulated spray drift of 2,4-D and dicamba causing significant yield loss in tomatoes at spray drift levels 1/30th of a standard field rate. Smith added concern over volatilization potential from the market projections of 100 million acres of dicamba-treated crops, many of them contiguous.

"Data reviewed by the USDA was largely reflective of past use as a preplant burndown with limited exposure to other crops," he said. "If you get volatilization from multiple fields in an area, concentrations of vapors could get much higher than anyone expects. Post applications will occur in early June and later, the absolute perfect times for problems to occur from atmospheric conditions."

New Formulations Offer Less Volatility

The three companies with the most to gain and lose from problems arising with the new formulations argue that the risk of volatility is extremely low, thanks to new formulations. They suggested that drift potential is reduced with proper equipment and application if labels are followed. However, Dow AgroSciences, Monsanto, and BASF are quick to echo concern over potential misapplication.

"Spray drift is an area where the focus must be if injury to neighboring sensitive plants and crops is to be eliminated," said Luke Bozeman, technical market manager, BASF.

The three companies have significant investments in dicamba and 2,4-D-tolerant crop technology to protect. The success of dicamba and 2,4-D technologies at controlling and stemming the expansion of glyphosate-resistant weeds will also determine the perceived, continued value of existing Roundup-tolerant technology. Farmers and their input and service providers are equally invested in the new technologies. Glyphosate-resistant weeds were estimated to have spread or developed on more than 65 million acres by 2012, although this is a rough estimate that could be higher.

Black Eye or Better Tools Depends on Users"Growers need these additional tools," said Bozeman. "Dicamba and glyphosate offer complementary performance, but they aren't the be-all, end-all of weed control. BASF is looking at a total weed control system using a foundation of residual herbicides that control early, reduce early season weed competition and protect crop yield. You'll never hear BASF say resistance can't develop if the weed control system is abused."

BASF, maker of Banvel and subsequent lower volatility Clarity and Status, plans to introduce Engenia, an ultra-low volatility dicamba formulation once regulatory approval has been received for Monsanto's dicamba-tolerant trait. Monsanto's premix of glyphosate and what is described as a low volatility dicamba, and the dicamba solo product XtendiMax will likely be first to market when dicamba-tolerant traits are introduced by Monsanto. Dow AgroSciences' Enlist Duo herbicide, a premix of an ultra-low volatility and reduced drift and odor formulation of 2,4-D choline with glyphosate, is also scheduled for 2015. Enlist Duo is the herbicide component of the Enlist Weed Control System.

Clear Communication Needed

It is how the new premixes are promoted that has Smith most concerned. He fears that without clear identification of what is and isn't permitted, commercial applicators and grower applicators in particular may assume that any formulation will do. SOCC has discussed this with the companies with, he suggested, mixed results.

"Dow did the right thing," said Smith. "They share our concern that generics are unsafe and are committed to make sure generics are not used with their system. They also agreed application was unsafe if any wind was blowing toward a sensitive crop."

He is more concerned about dicamba product positioning by Monsanto, suggesting that by referring only to low-volatility dicamba, growers may think any newer version is acceptable. He is adamant that even a product similar to Clarity would not be safe around sensitive crops.

Kim Magin, dicamba industry affairs lead, Monsanto, insisted that a farmer's license for the technology would restrict the most volatile formulations of dicamba. The company is coordinating with BASF on the eventual ultra-low rate Engenia. However, she stated the current formulation is safe if used properly. Where Monsanto and SOCC differ is what is proper. While Smith calls for no wind if sensitive crops are near by, she stipulated that lack of wind can signal an inversion, ideal for volatilization, thus the '3 to 10 mph' recommendation on Xtend products.

Magin acknowledged drift and volatility as issues deserving attention. "We've heard similar concerns from traditional row-crop producers, as well as specialty crop growers, and our research and product development groups have been addressing sources of off-site movement," said Magin. "We've focused on reducing the effect of particle drift with equipment, volatility with formulations and insufficient tank cleanout with triple rinsing of tanks. We also are developing a new tank deactivator that looks promising. All of these concerns will be addressed on the label."

Educating About Product Stewardship

All three have invested heavily in grower and dealer applicator education, such as BASF's On-Site Application Academy. Bozeman cites applicator training for part of the success of Status, a current dicamba product used in corn. In addition to training, BASF provided state-of-the-art, low-drift nozzles to applicators. Bozeman indicated this program would be expanded with the introduction of Engenia.

"The right formulation and the right application methods underpinned with education is our approach to stewardship with dicamba," said Bozeman. "When we brought out Clarity, it was an 80 percent improvement over Banvel in terms of volatility, and Engenia is to Clarity as Clarity was to Banvel."

He did acknowledge that misapplication of Engenia (as with any product) could result in spray drift-related damage to non-target plants. "The Ohio State University data (cited by SOCC) reinforces the importance of managing spray drift," said Bozeman. "We are spending a lot of energy developing clear label requirements on type of nozzle, spray particle size, deposition aids, wind speed and direction and identifying temperature inversions. All this is being done with one thing in mind, to control spray drift to sensitive crops."

Damon Palmer, commercial leader for Dow AgroScience's Enlist Weed Control System, said the company has worked with SOCC. While referencing the agreement between Dow AgroSciences and SOCC, Palmer emphasized stewardship is key to the success of these technologies. He pointed to efforts such as the company's Enlist 360 training at five regional technology centers, as well as on-farm trials in eight Midwestern states. He also emphasized the importance of communication within the industry and at the local level.

"When Save Our Crops Coalition raises concerns, it is important for us to understand what their concerns are," he said. "Reach out and talk to neighbors and communicate. Work with initiatives such as Field Watch that list organic and specialty growers."

"We all need to be serious about using these tools responsibly," said Magin. "We have to maintain the full utility of these weed fighting tools."

In the end, it will be the applicator, whether professional or farm-based, who will determine the success of these products and whether the crop protection industry has valuable new tools or a black eye. As Smith noted, the latter could open the door to even more regulation and oversight.

"If activists start questioning everything that goes on in a farmer's field, it could be dangerous," said Smith. "It is short-sighted to risk an entire technology."