Pesticide strategies set registration framework

BLOOMINGTON, Ill. — With the U.S. Environmental Protection Agency’s final herbicide and insecticide strategies now in place, those guidelines will now be used on labels for both new products and those due for reregistration.

The strategies, along with the yet to be finalized Rodenticide Strategy, are aimed at meeting EPA’s Endangered Species Act responsibilities.

Corey Lacey, Illinois Soybean Association policy manager, and Kevin Johnson, Illinois Fertilizer and Chemical Association president, addressed the strategies in a recent ISA Field Advisor podcast with Kelsey Litchfield, ISA agronomic outreach manager.

Regarding the EPA’s latest final ruling, Johnson believes “we’re in a better spot with the Insecticide Strategy.”

“A couple years ago, when the proposed Herbicide Strategy first came out, that was pretty rocky. EPA came out with a better version that I think us as retailers and farmers can probably live with a little more, but there’s still some more to be done with that,” he said.

“The new administration put out the Insecticide Strategy. I think most people think it’s kind of a good offset of what the Herbicide Strategy is, and there’s gonna be some changes in that, but I think we’re in a better place.”

Lacey has posted blogs on ISA’s Field Advisor website regarding the herbicide and insecticide final strategies.

“The herbicide and insecticide strategies are frameworks that the EPA is going to use when they create their labels for any new product going forward,” he said.

“We got to see the first herbicide strategy product with Liberty Ultra this year and, I think, a lot of interest in how that is applied. Liberty Ultra in a lot of ways was kind of an easy compliance situation, but it is a good learning curve to help guys start thinking about this.

“Basically, the strategies are designed to keep your products on your field and mitigate runoff or drift. There’s mitigation practices that you have to adopt to help that in order to use the products — and, whether or not you agree with it, it’s going to be what’s on the label, so you have to do it.

“So, the house is not on fire at this point or anything like that, but we need to start planning. We need to start thinking about it.”

Learning Opportunities

There are going to be numerous opportunities going forward for farmers to learn more about these strategies at ISA events, and many articles have been published on the topic.

Lacey suggested a good starting point is viewing a Field Advisor webinar posted a few months ago that featured Aaron Hager, University of Illinois Extension weed science specialist.

“The biggest challenge is not so much compliance for growers as they’re going to have to stop and look at every one of their fields and make some decisions that they’ve never had to think about on each of those fields,” Lacey said.

“It takes some time, and there’s a recordkeeping component that for a lot of guys, I’m going to be honest, it’s going to feel silly. They’re going to be like, well, I don’t have to do this, but I recommend people do it because you want to be able to prove that you’re innocent. You want to be able to prove that you did the right thing or at least follow the label.”

As the new labels under reregistration hit the market over the next many years before the strategy comes into play, Lacey was asked how farmers can use this time to reduce any future burden of the new regulations.

“The first thing I tell guys to do, because I know there are a lot of them using Liberty Ultra, is look at the Liberty Ultra label or talk to your retailer, whoever does your applications. Make sure you’re doing what you need to do there,” he said.

“Start to think about how do I control my spray drift. A lot of it is around hedgerows and things like that. We don’t have a lot of windbreaks hedgerows, maybe down south, maybe up north a little bit, but not in most of Illinois.

“But there is a lot of things when it comes to runoff. Where is my field located? Is it on a slope? Is it on less than 2% slope? These are the kind of things you just have to start thinking about it.”

Down the Road

Johnson reiterated Lacey’s comments regarding the long-term transition via label reregistrations before the strategies become fully binding.

“EPA did come out and say that it’s just not all chemicals all at once. It’s when they are rereviewed. All pesticides and insecticides get reviewed every 12 years.” Johnson said.

“What the industry is going to do is work together and put out a list of, for example, 26 of these chemicals are going to be up for review this year, then 27 of these are going to be up the next year and just keep going down the road.

“I feel pretty confident in Illinois, if you’re on some pretty flat ground, if you’re not up against a river, creek or something like that, you can manage it. Now, everybody’s different and manages differently.

“I think you’re definitely going to be more effected if you’re up against the Wabash, Illinois or Mississippi rivers, or you’re maybe that very northwest corner of Illinois. How you do recordkeeping and what product you use are going to change.

“The other thing I want to make sure that everyone is aware of, and I’ve heard it a thousand times, is ‘the new administration is going to come out and they’re just going to stop it all.’ No, this is by court order. It was by lawsuits.

“We had the Herbicide Strategy came out during Biden’s administration, and the Insecticide Strategy came out April 29 under the Trump administration. They didn’t stop it because they were under court order. This is slowly going to keep coming down the tracks. There’s going to be more information coming out about that.

“I wish I could tell you it’s all going away. It is not, but I think we are getting better at what we need to manage. I also know that there are updated maps coming on the Endangered Species Act that will make a ton of difference.”

When the initial Insecticide Strategy proposal was released last fall, basically the entire state fell under application guidelines under the Endangered Species Act.

Those Pesticide Usage Limitation Area maps are key components to the strategies. The new pesticide, insecticide and herbicide strategies have three basic Endangered Species Act components.

“They’re going to have a runoff mitigation, a drift mitigation and then they’re going to have this geolocation specific mitigation — PULA. The PULA is an area where for some special reason, maybe there’s a specific endangered species there, maybe it’s a breeding area for an insect or something that’s protected. If you’re inside those PULAs, then the requirements to comply increase. The PULAs are this add-on,” Lacey said.

“The fact that a lot of Illinois came out of these PULAs is actually a really big deal because it helps our guys that apply. The PULAs can be found on EPA’s ‘Bulletins Live! Two’ website. It’s not the easiest managed website, but you can do it.”