Tell EPA To Ban Drift-Prone Pesticides
Dicamba is a drift-prone herbicide that has proved to be extremely difficult to control by regulation. EPA is now considering two new dicamba registrations that continue use of the chemical in its most drift-prone application uses.
>>Tell EPA to ban use of dicamba and other drift-prone pesticides.
Pesticide drift harms people, crops, and wildlife. The term “drift” applies to airborne movement off the target site—though pesticides may also move as runoff and in soil carried by water or wind. Drift may consist of particles or droplets of pesticide as it is applied or vapors that evaporate and are carried in the air. Farmers and applicators may take steps to avoid drift—including buffer zones, thickening agents, and attention to wind direction—but drift-prone pesticides like dicamba are not always controlled by these actions. Those harmed by the drift are generally not those whose crops are sprayed, so the risk-benefit analysis pits farmer against farmer, neighbor against neighbor, even resulting in a murder.
The manufacturers of dicamba-based herbicides—who also sell seeds of crops engineered to tolerate dicamba—benefit from this conflict, as farmers buy the engineered seeds in an effort to defend themselves against drift damage, a strategy encouraged by pesticide manufacturers.
Despite a finding of dicamba's harm and EPA's failure to comply with standards, the continued use of the weed killer through the 2024 growing season is effectively authorized in a decision of the U.S. District Court of Arizona, which vacates the EPA's 2021 authorization of the use of three over-the-top (OTT) uses of dicamba-based herbicide products. In response, EPA issued an existing stocks order. And now proposed registrations would allow those uses to continue. The comment period on the Bayer application has closed, but comments on the virtually-identical application for BASF's Engenia® are open until July 5. ➡️ Click here to see Beyond Pesticides' comments.
The proposed label for Engenia® allows for application preplant, at-planting, preemergent, and postemergent (in-crop) for broadleaf weeds. In dicamba-tolerant soybeans, there is a June 12 cutoff date with applications allowed before, during, and after planting, including over-the-top. In dicamba-tolerant cotton, similar conditions apply but with a cutoff date of July 30. This is different from the Bayer CropScience proposal where no over-the-top application was specified for soybeans. The new proposed uses, since they increase use of dicamba and subsequent harm from pesticide drift, should be denied for failure to meet the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA) requirement of no unreasonable adverse effects on the environment.
Increasing global temperatures need to also be factored into the decision-making process. All dicamba formulations have the potential to volatilize since dicamba has a high vapor pressure. Increases in air temperature can cause dicamba to turn into a gas even after successful application on target surfaces. Since volatilization increases as temperatures increase, this is more and more concerning as temperatures are rising higher each year. The length, intensity, and onset of seasons has changed, which can be attributed to climate change. The longer and hotter summers will exacerbate dicamba volatilization, therefore any proposal that allows dicamba application in late spring and summer will lead to more drift--especially for postemergent and over-the-top applications.
Although pesticides are by definition harmful, what makes these adverse effects “unreasonable” is the existence of an alternative—an organic production system—that does not harm human health, other species, or ecosystems and, in addition, helps to mitigate climate change. In its registration decisions, EPA must use organic production as a yardstick, denying any use for which organic production is successful. This includes the proposed uses.
>>Tell EPA to ban use of dicamba and other drift-prone pesticides.
The targets for this Action are the U.S. Environmental Protection Agency and the U.S. Congress.
Thank you for your active participation and engagement!
Document ID: EPA-HQ-OPP-2024-0154-0236
Proposed submission to EPA (please submit by 5 PM ET on July 5, 2024)
Dicamba is a drift-prone herbicide that has proved to be extremely difficult to control by regulation. EPA is now considering two new dicamba registrations that continue use of the chemical in its most drift-prone application uses.
Pesticide drift harms people, crops, and wildlife. The term “drift” applies to airborne movement off the target site—though pesticides may also move as runoff and in soil carried by water or wind. Drift may consist of particles or droplets of pesticide as it is applied or vapors that evaporate and are carried in the air. Farmers and applicators may take steps to avoid drift—including buffer zones, thickening agents, and attention to wind direction—but drift-prone pesticides like dicamba are not always controlled by these actions. Those harmed by the drift are generally not those whose crops are sprayed, so the risk-benefit analysis pits farmer against farmer, neighbor against neighbor, even resulting in a murder.
The manufacturers of dicamba-based herbicides—who also sell seeds of crops engineered to tolerate dicamba—benefit from this conflict, as farmers buy the engineered seeds in an effort to defend themselves against drift damage, a strategy encouraged by pesticide manufacturers.
Despite a finding of dicamba’s harm and EPA’s failure to comply with standards, the continued use of the weed killer through the 2024 growing season is effectively authorized in a decision of the U.S. District Court of Arizona, which vacates the EPA’s 2021 authorization of the use of three over-the-top (OTT) uses of dicamba-based herbicide products. In response, EPA issued an existing stocks order. And now proposed registrations would allow those uses to continue.
The proposed label for Engenia® allows for application preplant, at-planting, preemergent, and postemergent (in-crop) for broadleaf weeds. In dicamba-tolerant soybeans, there is a June 12 cutoff date with applications allowed before, during, and after planting, including over-the-top. In dicamba-tolerant cotton, similar conditions apply but with a cutoff date of July 30. This is different from the Bayer CropScience proposal where no over-the-top application was specified for soybeans. The new proposed uses, since they increase use of dicamba and subsequent harm from pesticide drift, should be denied for failure to meet the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA) requirement of no unreasonable adverse effects on the environment.
Although pesticides are by definition harmful, what makes these adverse effects “unreasonable” is the existence of an alternative—an organic production system—that does not harm human health, other species, or ecosystems and, in addition, helps to mitigate climate change. In its registration decisions, EPA must use organic production as a yardstick, denying any use for which organic production is successful. This includes the proposed uses.
Increasing global temperatures also need to be considered. All dicamba formulations have the potential to volatilize since dicamba has a high vapor pressure. Increases in air temperature can cause dicamba to turn into a gas even after successful application on target surfaces. Since volatilization increases as temperatures increase, this is more and more concerning as temperatures are rising higher each year. The length, intensity, and onset of seasons has changed, which can be attributed to climate change. The longer and hotter summers will exacerbate dicamba volatilization, therefore any proposal that allows dicamba application in late Spring and Summer will lead to more drift--especially for postemergent and over-the-top applications.
EPA must not approve the proposed expanded use of dicamba and must cancel uses of all drift-prone pesticides.
Thank you.