There definitely is going to be new spray drift language on product labels in the foreseeable future as required by the Environmental Protection Agency (EPA), and the outlook is that labels could also include suggested or required use of “validated technology” to reduce drift.
“In some form, wording would be on the label that your adjuvant or nozzle was a validated drift reduction technology (DRT),” said Susan Ferenc, Ph.D., president of the Chemical Producers and Distributors Association, during the recent CropWorld North America conference. Most of the audience was crop protection company representatives.
“EPA is already looking at having label language on drift, although they aren’t exactly sure how they are going to do that, but now they are trying to figure out how they can use the label to encourage innovation in this area,” Ferenc said.
If it was left to the general public, wording on product labels would require “zero spray drift;” the public doesn’t understand that zero is impossible because drift can be one foot away from the targeted plant or 10 feet away. The first rumblings in 2011 about new spray drift language being added to crop protection product labels was because some in the industry were worried that the EPA wording appeared headed toward a no-drift/zero-drift policy.
Ferenc said the latest draft wording from EPA is rational and has major points something like this: “Do not apply this product in a way that will contact workers or other persons, either directly or through drift. In addition, do not apply this product in a manner that results in spray (or dust) drift that harms a person or any other non-target organism or site.” And additional references could be a warning about “spray (or dust drift) that could cause an adverse effect to people.”
Ferenc further explained how innovations to reduce drift could also be part of the label language. “On a product basis, it could be terminology around wind velocity or application height or droplet size and the dreaded buffer zone,” Ferenc said. “They don’t really want to move into setting buffer zones on labels [for every product], but they are under some pressure to do that. They are trying to see if industry is going to step up to the plate or whether ultimately they are going to have to do that.”
Private industry has stepped up in trying to determine validated technologies that will reduce spray drift, but it is an expensive and time-consuming process that is still being developed and tested.
“The problem has been validation of these technologies. How do you validate and what standard do you use to validate these technologies against. You are reducing drift as opposed to what?,” Ferenc asked. “It has to be so much better than the standard, but what is the standard? What is the standard nozzle? What is the standard adjuvant? What is the baseline to work from?”
EPA has been trying to come up with an approved protocol to answer these questions for years and some progress has been made in working with the agricultural industry.
The one necessity to help in setting standards and rating nozzles and adjuvants is being able to test final solutions containing the water and active ingredient product, but such testing has not been performed in the U.S. because it is unlawful to do so in the environment. It is known by all in the industry that water sprayed through nozzles does not normally have the same drift characteristics as when actual product is in the solution being sprayed.
Some research for establishing U.S. protocol with field-type solutions containing various actives and adjuvants and applied with different nozzles has been done in Australia in a wind tunnel. Now that type of wind tunnel testing with field-type solutions is going to proceed in the U.S. Ferenc reported that Winfield Solutions “has just built a low-speed wind tunnel” where active ingredient and adjuvant effect on spray drift can be tested. She also said Winfield Solutions, Wilbur Ellis and BASF have contributed to the University of Nebraska for the construction of both a low-speed wind tunnel, for ground application testing, and high-speed wind tunnel, for aerial application testing. Each of these tunnels will be available for contracting to test products.
The payback to companies investing large sums of money into working with the EPA is that their brand of validated technology might actually be listed on pesticide labels as an accepted DRT.