EPA is seeking public comment by September 12, 2016 on a Proposed Interim Decision (PID) for regulating the class of herbicides known as sulfonylureas.  The sulfonylurea herbicides are currently used on millions of acres in the United States.  Using the most conservative models and endpoints to predict exposures of concern, the EPA has determined that risks to non-target plants warrant additional label restrictions when products are applied either by ground or air.  To protect against the potential damage that these models predict, EPA is proposing that labels would be required to instruct that:

  • All applications of products which include a sulfonylurea must be made using equipment delivering an Extremely Coarse droplet size
  • All applications would be prohibited when wind speeds at the application site exceed 10 miles per hour.
  • When making aerial applications maximum boom lengths, swath displacement and nozzle orientation would be defined and made mandatory.
  • When making ground application the distance between the spray nozzle and the ground or crop canopy would be restricted to no more than two feet.
  • Tank mixes with with different mode-of-action and and contact herbicides such as glyphosate would be prohibited if the extremely course droplet size is required as these applications generally require small droplet size to be efficacious.

There is general support for spray drift advisory language on labels but placing specific restrictions on equipment types, configurations and their operating parameters may discourage applicators from investing in newer technologies designed to better manage drift.  The economic investment that applicators may be required to make in order to continue to apply sulfonylureas appears to have been overlooked.  Please help preserve the utility of the sulfonylureas herbicides in crop protection.  ARA asks that you take the time to submit your concerns and comments to the EPA.  Note that the EPA has established a different Public Docket for each of the 22 sulfonylureas currently registered for use in the USA.  The complete PID may be found in any of the 22 Dockets and comments applicable to any sulfonylurea may be submitted to any one of the dockets.