Tell EPA To Ban Drift-Prone Herbicides
Comments on proposed new dicamba uses are due by September 6, 2025, at 11:59 PM ET!
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Dicamba is a drift-prone herbicide that has proved to be extremely difficult to control by regulation. In a move to deregulate uses and challenge a court ruling, EPA is now considering three 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 herbicides.
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 adequately 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, with one case 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 the U.S. Environmental Protection Agency's (EPA) 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, with a February 2024 stop sale order and allowances of state-specific end-use through spring and early summer of 2024.
Now, proposed registrations would allow those uses to continue. The docket on these registrations is open for comment until August 22. (See Beyond Pesticides' comments.) The proposed labels allow for application preplant, at-planting, preemergent, and post-emergent (in-crop) for broadleaf weeds. There are label restrictions purporting to reduce drift damage, but they are subject to exceptions. For example, there is a downwind buffer of 240 feet—though “downwind” may change during application as well as post-application when vapor drift is likely. The buffer distance may be reduced by reducing the number of passes when applied to fields, presence of a windbreak, or use of directed spray equipment. The maximum allowed temperature during and following application depends on the concentration of additives to reduce drift and volatilization, but may be as high as 95°F. 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 also need to 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 have 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 post-emergent 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 herbicides.
The target for this Action is the U.S. Environmental Protection Agency via Regulations.gov.
Thank you for your active participation! The Action is a multi-step process, so please click submit below to proceed to step two, where you will be able to personalize comments before final submission. The comment maximum limit is 4,000 characters, so it may be necessary to delete some of our prepared message text if editing.
Proposed comment to the EPA:
Dicamba is a drift-prone herbicide that has proved to be extremely difficult to control by regulation. EPA is now considering three 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 adequately 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, EPA proposes registrations that would allow those uses to continue.
The proposed labels allow for application preplant, at-planting, preemergent, and post-emergent (in-crop) for broadleaf weeds. There are label restrictions purporting to reduce drift damage, but they are subject to exceptions. For example, there is a downwind buffer of 240 feet—though “downwind” may change during application as well as post-application when vapor drift is likely. The buffer distance may be reduced by reducing the number of passes when applied to fields, presence of a windbreak, or use of directed spray equipment. The maximum allowed temperature during and following application depends on the concentration of additives to reduce drift and volatilization, but may be as high as 95°F. 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 have 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 post-emergent 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.
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By submitting a comment on EPA-HQ-OPP-2024-0154-1233, you agree to the terms of participation and privacy notice of Regulations.gov.