The Agricultural Retailers Association (ARA) has been in support of extending the registration of dicamba and applauded the Environmental Protection Agency’s (EPA) action to extend the registration through 2020. ARA supports the continued use of this new technology and supports label restrictions to ensure the best possible stewardship and use of the product. Following the announcement, ARA received several questions from members and is seeking clarification from EPA on two elements of the new registration guidelines.
The first question is on the scope of the term “certified applicator.” The EPA states, “The products may only be applied by the certified applicator, not by someone under the supervision of a certified applicator …” This narrow interpretation of who may apply dicamba is a significant departure from past practice and may drastically limit the available applicators.
For example, in the state of Illinois alone, there are approximately 5,000 “licensed commercial operators” who were previously able to apply restricted use pesticides under the supervision of a certified commercial applicator. Every three years these licensed operators are required to pass the 100-question core competency (general standards exam) to be licensed as operators in Illinois. In a letter to EPA, ARA has requested these licensed individuals be included as a certified applicator.
It is for situations such as this that ARA created its DC Help Desk, which seeks to assist members with questions about federal legislation impacting agriculture and regulatory compliance issues. If an ARA member has an advocacy or regulatory question or is interested in assistance with booking meetings with members of Congress, federal agencies, or others, use ARA’s online portal (www.aradc.org/helpdesk) or to call (202) 457-0825. Many questions can be answered or resolved within a few business days.
In addition, ARA is aware of some potential confusion that may be created by information included in the EPA’s “Dicamba Training Requirements – Frequently Asked Questions” under question number seven, which states “Non-certified personnel may not perform any activities with dicamba products, including mixing and loading.”
While the language was noted in the FAQ document, ARA did not find language included in the new dicamba registration label guidance documentation prohibiting employees at an agricultural retail facility from mixing and loading dicamba product into applicator equipment at the retail facility or at a farm location.
There are many states that have differing categories for licensed pesticide applicators that may or may not be considered “certified,” pending this clarification from EPA. States should modify their existing applicator training and testing programs now if thousands of existing applicators—who have passed state core competency exams—now have to be tested and certified in additional technical categories to apply dicamba, in addition to taking required auxin-specific training. These modifications to state training and testing requirements will take substantial time, resources, and management as spring quickly approaches.
ARA has not yet received a response from EPA on this matter.