Currently, the Environmental Protection Agency (EPA) has no definitive policy or guidance addressing pesticide application spray drift. In a draft Pesticide Registration (PR) Notice issued in 2001, EPA proposed generic spray drift label language that would ostensibly prohibit drift, while admitting in the same document that attaining "zero" drift is technically unachievable. The lack of clear guidance regarding spray drift has opened the door for some state regulators and activist groups to pressure the EPA to adopt enforceable language that prohibits pesticide spray drift. Ultimately, the lack of specific guidance by the EPA to address pesticide drift has left a "policy void" that could pose negative economic impacts on agriculture. EPA has acknowledged that some level of off-target movement of pesticides immediately after spray application is unavoidable. The agency considers the risk associated with such drift during the pesticide registration decision process and requires appropriate mitigation measures to protect human health and the environment. A "zero" drift policy is neither achievable nor necessary.



Position
CLA supports the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA) "no unreasonable adverse effect" standard for spray drift. The applicator onsite is best equipped to select products, application methods and equipment in accordance with label directions to manage off-target drift. CLA appreciates EPA for recognizing that applicators already take precautions to control drift, but specific guidance is needed by the EPA to eliminate the need for future policy development influenced by those who do not understand the growers' needs.


  • CLA suggests that any pesticide product labeling regarding spray drift should provide applicators with scientifically-based, consistent, validated and appropriate directions for managing drift.


  • In the 2001 Pesticide Registration (PR) Notice, EPA recognized that some level of drift will occur from most pesticide spray applications. It is inconsistent then, for EPA to require applicators to "not allow" pesticides to drift.


  • Scientific studies have shown that spray drift can be reduced with application conditions or equipment such as spray quality requirements, spray release height requirements, wind speed restrictions, wind direction considerations, buffer zones or no-spray zones and best management practices specific to the application technology.


  • EPA's 2001 PR Notice directed aerial applicators to fly no more than 10 feet above the ground or canopy when applying pesticides. This requirement is not reasonable, is unsafe in many circumstances and should be changed to allow for site-specific variation.