New Rules for Pesticide Certification and Training
By Glenn Nice and Steve Tomasko, UW Pesticide Applicator Training (PAT) Program.

The new rules were posted in the Federal Register on January 4, 2017. It will take time before the new requirements are implemented in Wisconsin. States have three years to modify existing state plans to comply with the new requirements, and an additional two years may be granted by the EPA if requested. The Wisconsin Department of Agriculture, Trade and Consumer Protection (DATCP) is preparing a plan that will have to be accepted by the EPA and then the State Statues will have to be opened and changed to fit the new C&T rules. So, we have some time before these rules kick in.

Be aware that although State law has to meet these new requirements, a State can exceed the requirements and in most cases do. Meaning that a State can require additional requirements beyond those listed in the new rules.

What is this Certification & Training Thing?

As part of the Federal Insecticide, Fungicide and Rodenticide Act (FIFRA) applicators who use restricted-use pesticides (RUPs) have to go through a certification process that requires some form of training. Approximately 5% of pesticides are registered as restricted-use. The basis of this rule is set by the EPA, then each state can add to it as needed. In Wisconsin, an example of an added rule is that commercial applicators that apply any pesticide (RUP or not) have to be certified.

The EPA has recently reviewed its portion of the Certification & Training rule and made revisions. This article will highlight some of the rules and how they relate to Wisconsin pesticide applicators. If you are reading this from another state, please look to the Pesticide Safety Education system or your state regulatory agency within that state for information in your state.

The following information has been mined from various EPA Public Documents, predominantly from the “Detailed Comparison of Revisions to EPA’s Certification of Pesticide Applicators Rule
(40 CFR 171).

General EPA site for the rule

Enhance Private Applicator Competency Standards

There are specific topics that have to be covered in the training. The topics are:

In Wisconsin

Already Compliant.

In Wisconsin, Private applicators have a choice on whether they wish to participate in a live training or not. They can “Self-Train” by studying the training materials and taking the test or they can add a county based training if they wish also. Private applicator training and testing is provided within counties. Contact your local county extension office for details.

The training materials covers what is required by the new rules, so we are essentially doing most of it all ready. Applicators are tested on material every five years. The manual has the bulk of information for training purposes and should be kept as a reference guide for the five years of certification. It contains:

Attending a training through the County based Private Applicator training system is broken down like so:

The tenth topic is a revolving topic. This is a topic that has relevance to the year it is being presented. In 2017 the revolving topic is the Worker Protection Standard, a set of standards that were changed in 2016 and are going into effect in 2017.

Some of the Private Applicator Topics will have to be tweaked to be compliant to EPA Requirements. The test provided by the Wisconsin Department of Agriculture, Trade and Consumer Protection (DATCP) will be adjusted also. The Private Applicator training will be updated for 2018 and will reflect the C&T changes as well as the new Worker Protection Standard changes.

Strengthen Private Applicator Competency Gauge

In the new rules, Private applicators must either attend a training program covering the mandatory competency standards or pass a written exam.

In Wisconsin

Every applicator presently is required to pass a certification exam every five years. Applicators can choose to “self-study” or attend a training; however, all options require taking the State’s certification exam and having the training manual.

Eliminate Non-reader Certification for Private Applicators

The EPA is removing the “non-reader” option for persons who cannot read to obtain certification to use specific RUP’s [171.11(c)(7)(IV)].

In Wisconsin

There will be no change in Wisconsin. State rules require that applicators who seek certification show the ability to read and follow written pesticide labels. Due to the fact that pesticide labels are not mandated in other languages (at this time) other than English (some labels are available in Spanish), applicants who seek certification have to be able to read and follow an English Label.

Establish Additional Categories for Private and Commercial Applicator Certification

The EPA is requiring States to add the categories of a) aerial application; b) soil fumigation; c) and non-soil fumigation.

In Wisconsin

Wisconsin already has these categories. Aerial application (category 9.9 commercial and 111 private); soil fumigation (Category 25 commercial and 107 private) and Space & Commodity Fumigation (Category 7.2 commercial).

Establish Predator Control Categories for Private and Commercial Applicator Certification

This change promotes the creation of categories for specific uses. Examples of these are for the use of sodium fluoroacetate in livestock protection collars and sodium cyanide delivered through M-44 devices. This will be left for the State to adopt or not. If the category is not needed in a State it will not be required.

In Wisconsin

Presently, DATCP requires that applicators obtain a joint DNR-DATCP permit for the use of sodium fluoroacetate and there are no uses labeled for sodium cyanide in Wisconsin. DATCP will consider if this category is necessary in Wisconsin.

Identification of Candidate for Certification and Recertification

The EPA rules will require a government-issued photo identification OR other similar reliable form of identification approved by the certifying authority for initial certification and recertification by exam.

In Wisconsin

Nothing will change with Wisconsin’s current rules. Photo ID is required to take the certification test. Those that don’t have photo ID’s due to religious reasons can contact DATCP for further instructions.

Establish Exam Standards

All exams must be proctored. Only materials approved by DATCP can be provided during the test then collected by the proctor. Meaning no materials used during the test can leave with the applicator taking the test.

In Wisconsin

In Wisconsin, commercial applicators have to take and pass a closed book exam. Private applicators are given an “open book” exam. With each training fee, applicators get a General Farm (or Fruit Crop or Greenhouse & Nursery) manual. In the case of private applicators, they are allowed to use the manual during the test. In the new EPA rules that material could not leave the testing area.

How DATCP and the UW PAT program will comply is yet to be determined. Several options are being weighed. More on this as the implementation period progresses.

Establish a Minimum Age for Certified Applicators.

The EPA has created a minimum age for those who work with restricted-use pesticides. Applicators, mixer and loaders, and people who work with application equipment that apply RUPs will have to be 18 or older. On a side note, the Worker Protection Standard (WPS) has also set a minimum age of 18 for handlers. This only applies to agriculture.

There is an immediate family member exemption. Persons who are being supervised by an immediate family member have to be 16 and over.

In Wisconsin

Wisconsin does not have a minimum age requirement for certifying applicators. Currently, commercial applicators cannot obtain an individual commercial pesticide applicator license until they are 16 years old. The age requirement for applicator certification will be raised to 18. Since Wisconsin has no “supervisory” role in commercial certification any applicator for-hire will have to be at least 18 years of age. Anyone under 18 will more than likely NOT be able to apply or work with.

Keep in mind that the Worker Protection Standard (WPS) has set its minimum age to 18 for handlers. Employees that are handlers are required to be 18 or over.

Establish a National Certification Period

The EPA’s final rule has set a national certification period at 5 years maximum.

In Wisconsin

In compliance. Wisconsin’s certification period is presently at 5 years.

Recertification Requirements

Some States have a continuing education recertification process. Applicators have to attend set hours of continuing education over the certification period. Other states require that an exam be done to recertify. In Wisconsin, we require the latter, a test has to be passed every five years.

The new rules require states to have a process for reviewing and updating as necessary the written examinations.

In Wisconsin

Training materials and exams are updated every 5 years. This is in compliance so no changes are required.

Commercial Applicator Recordkeeping

States must require commercial applicators to maintain specific records about RUP use.

In Wisconsin

Wisconsin requires commercial applicators to keep records of all applications for 2 years, or for 3 years if using atrazine and isoxaflutole. Private applicators are required to keep records of RUPs for 2 years, or 3 years for atrazine and isoxaflutole. Wisconsin recordkeeping requirements can be found in this DATCP factsheet: Recordkeeping.

Rup Dealer Rules

The new rules require businesses that sell RUPs to keep records. The information that these businesses have to keep are:

In Wisconsin

Wisconsin already requires that business that sell RUP must keep records for 2 years [ATCP 29.16]. The following has to be kept:

Businesses that do the above have to keep these records for two years and make the records available to DATCP for inspection. Also, each year dealers report the names and addresses of their pesticide suppliers and the amount of each pesticide sold or distributed in the past 12 months. This has to be submitted every year no later than October 30 [ATCP 29.15(9) ].

Wrap up

There are other rule changes; however, these are for various administrative requirements that the State’s regulatory agency, in our case DATCP, will have to comply with.

Many of the rules that the EPA have changed are designed to bring all states up to the same base level. However, each state is allowed to tailor their details to their objectives as long as they are within the requirements of the EPA’s rules. This is an attempt to standardize things nationally, but a high degree of variability still exists. Luckily or unluckily, depending on how you feel, Wisconsin already had rules in place that met or exceeded these changes.

Audio (MP3)

A Great Question - “Is there a list of hazardous pesticides?”
By Glenn Nice and Steve Tomasko, UW Pesticide Applicator Training (PAT) Program.

This is a great question and one that definitely deserves some addressing. It also comes in other ways, which pesticides are seen more hazardous than others.

First, I just want to say that all pesticides or chemicals can become hazardous if used incorrectly and there are inherent risks to using ANY pesticide or tool. Just as any person's vehicle can be a hazard if used incorrectly and there are risks to operating a vehicle. There are clarifications of the question itself that have to be addressed.

The first problem is the regulatory world deems certain chemicals or wastes as ‘hazardous.’ The Environmental Protection Agency (EPA) can determine if a specific chemical is a hazardous material. This will dictate how it can be used or discarded. There are several criteria involved in this designation. The Department of Transportation (DOT) also keeps lists and classifies specific chemicals that are hazardous materials. In the case of the DOT, it is the transport of chemicals that they are most concerned with. So, there are official lists of 'hazardous' chemicals that have some pesticides on them.

The second problem is there are many types of pesticide products out there and this changes every year as companies market new products and new formulations and get rid of old ones. The best way to identify the level of risk or hazard is to a) read the label, b) read the Safety Data Sheet. These documents are designed to provide information regarding any risks of use. Each pesticide will have both these documents available.

Now this brings us to the question, ‘are there any lists of the pesticides determined to be hazardous materials'. There are lists of hazardous materials but they are not made specifically for pesticides. The answer is yes. There are lists of hazardous chemicals, but few of these lists tease out just pesticides.

There are a few options to turn to that may help:

  1. Pesticide Waste Versus Hazardous Waste, put out by the Cornell University Corporative Extension Service Pesticide Safety Education Program. This provides a list from the Resource Conservation and Recovery Act (RCRA), Identification and Listing of Hazardous Waste (Title 40 261.31 to 33). Be aware that this list has pesticides no longer available in the market. See link below.
  2. Restricted use Pesticides (RUPs) are pesticides that the EPA has identified higher risk of use. This risk may be to people as in toxicity or to the environment (toxic to aquatic critters). To use these pesticides, you have to be a certified applicator. Labels will identify these pesticides and the person selling them is not supposed to sell them to you if you are not certified. The Department of Agriculture, Trade and Consumer Protection keeps a list of RUPs by company. See link below.
  3. Every pesticide has a Signal Word that identifies its relative acute toxicity to people. This can be found on all pesticide labels. Caution is the lowest toxicity on the scale, then Warning, then Danger and finally Danger Poison. The signal word does not have any impact on how the pesticide controls the pest, so if one product is Caution and another is Danger and they both control the pest and they both are labeled for what you want to do, then use the Caution one. However, a Caution signal word does not mean that it can be slung around like water, you still have to wear the correct PPE and follow the label.
  4. The Safety Data Sheet (SDS). Although the label is an EPA requirement document, the Safety Data Sheet is an Occupational Safety and Health Administration (OSHA) document. The SDS will have the LD50's for the product. It will also provide environmental data and other valuable characters of the product in question. The higher the LD50 the lower the toxicity. For example, an LD50 of 300 mg/kg is a lot more toxic than an LD50 of >5,000 mg/kg. The SDS will also give the DOT classification if there is one. The SDS will also provide various regulatory information regarding transportation and Emergency Planning reporting quantities.
  5. The EPA keeps a list, they call "the list of lists", haha. [ ] . This is a composite list of many chemicals, pesticides just part of it. It lists the amounts and chemicals that fall under the Emergency Planning Laws. This list is made up of chemicals that the EPA requires reporting if a specific quantity is reached in storage over a calendar year.

As mentioned above there is no simple list that says, "this is hazardous and this is not". Each pesticide will have risks of use Like any tool, some smaller than others, but those risks are based on the specific pesticide you are using, how and where it is being used. If you are looking to identify risks, read the label and SDS for the product in question.

To get Labels you can go to DATCP's Kelly Solutions site or labels and SDS at CDMS. Those two documents are designed to inform users of the risks of use.

Cornell Hazardous Pesticide List


EPA Lists of lists

DATCP Kelly Solutions site

CDMS Label Search

Audio (MP3)

Pest Management in Wisconsin Field Crops, A3646
By P.J. Liesch, Glenn Nice, Mark Renz, Damon Smith and Bryan Jensen.

There have been changes in location and distribution of UW Extension’s, Pest Management in Wisconsin Field Crops Bulletin (A3646). This publication can now be purchased ($30, plus $1.65 third party credit card acceptance fee) or downloaded at the Pesticide Applicators Training Program’s Store below.

Pest Management in Wisconsin Field Crops is updated annually and contains general and specific pest management recommendations for corn, soybean, forages, small grains and stored grain. Including rates, remarks and performance data for pesticides.

The PAT Store

Audio (MP3)

Four New Pesticide Safety Training Manuals in 2017
By Steve Tomasko, UW Pesticide Appliator Training (PAT) Program

Every year we here at the UW-Pesticide Applicator Training program (PAT) update and revise some of our manuals. We have 14 unique commercial category manuals, one private category manual, two manuals that can be used for private or commercial and 3 sub-category manuals. We update each manual every 5 years. Besides rules and regulations that may change and need updating we are always striving to make the manuals more readable and understandable and a better tool for learning how to use pesticides safely and legally.

In our latest round of revisions we have added more pictures and graphics to hopefully better illustrate the learning objectives. We have also done a format change that we think will make the information easier to read and follow. The manuals we revised for 2017 are: category 7.1, Structural Pest Control (8th Edition); category 7.2, Space & Commodity Fumigation (8th Edition); Category 7.3, Termite Control (6th Edition); and category 7.4, Wood Preservation (6th Edition).

images of the new manual covers

We are always interested in feedback on the manuals (good or bad!). Let us know if you find anything you think is wrong or not understandable. All input is appreciated so we can make the manuals better for you, our applicators.

Email Steve Tomasko and/or Glenn Nice with comments at:

Audio (MP3)

Recycle your Empty Pesticide Containers — For Free!
By Steve Tomasko, UW Pesticide Applicator Training (PAT) Program

Every year farms, coops, lawn care, structural pest control operators and other businesses purchase and empty millions of plastic containers containing pesticides. A large percentage of those empty containers end up in landfills. But there’s a better option: most containers can be recycled into other useful products, and for many businesses, recycling won’t cost a dime.

The Ag Container Recycling Council (ACRC)—an industry funded not-for-profit organization— funds and administers used pesticide container recycling programs across the United States. In 2015, ACRC through its contractors collected and recycled over 10 million pounds of used pesticide containers.

What Can You Recycle?

Farms and companies can recycle #2 rigid high density polyethylene (HDPE) containers up to 55 gallons in size that held products used in the following markets: Crop Protection: Containers that held EPA-registered crop protection products labeled for agricultural uses. Adjuvant, crop oil and surfactant containers also eligible for recycling. Specialty Pesticides and Fertilizers: Containers that held EPA-registered products labeled for professional structural pest control, animal health, turf, nursery, greenhouse, forestry, and aquatics are eligible for recycling.

Not Acceptable: Containers that originally held consumer products, or home and garden pesticides cannot be recycled through this program.

Rinse, Rinse, Rinse!

You MUST rinse containers of all residues after use. Only dry, residue-free rinsed containers are accepted at collection sites. You must triple-rinse your containers or use a jet spray to make sure they are clean and residue-free. Why is rinsing important?

How do you make sure your containers are properly rinsed? Read the product label and follow the procedures for rinsing containers (jugs and drums).

Where Do I Recycle my Containers?

The ACRC contracts out its recycling work to different contractors around the country. For the Midwest, that company is G. Phillips & Sons, LLC. You can schedule a pickup of your clean, empty containers by calling the company at 563-942-0391. They will pick up containers at both farms and other businesses.

Audio (MP3)

EPA Calls for Stronger Safety Measures for Paraquat Use
By Steve Tomasko, UW Pesticide Applicator Training (PAT) Program.

The herbicide paraquat dichloride (commonly called simply paraquat), is one of the most widely used herbicides registered in the United States. It also happens to be highly toxic to humans—one small sip can be fatal. There is no antidote. Because of its wide use and potential danger, the U.S. Environmental Protection Agency has introduced new restrictions on paraquat’s use.

People often refer to paraquat by one of its popular brand names: Gramoxone. People use the herbicide to control weeds in many agricultural and non-agricultural sites. Growers also used it as a defoliant on crops, like cotton, prior to harvest. It has no registered residential or homeowner uses. All paraquat products registered for use in the U.S. are Restricted Use Pesticides (RUPs), which can only be sold to, and used by, certified applicators.

Fatalities and Injuries

Since 2000, 17 people—including three children—have died after accidental ingestion of paraquat. These fatalities resulted after someone illegally transferred paraquat to beverage containers and later someone mistook them for a drink and ingested some.

In addition to the deaths by accidental ingestion, since 2000 three people have died and many people have experienced severe injuries when workers handling the chemical got the herbicide onto their skin or into their eyes.

EPA Actions

To help prevent the fatalities and injuries noted above EPA is requiring:

More Information

Learn more about paraquat and the new measures to reduce risk

More information about paraquat’s health effects

Audio (MP3)

Sulfoxaflor is back on the Market with Limited Uses
By Steve Tomasko, UW Pesticide Applicator Training (PAT) Program

Over the past four years, the insecticide sufoxaflor has been registered for use, had its use cancelled and is now back on the market although with more limited uses and increased pollinator protections on its label.

The U.S. Environmental Protection Agency originally registered sulfoxaflor in 2013. However, after appeals for more study, a court vacated that registration, and EPA cancelled its use in 2015. Following that court order, the EPA reevaluated data supporting the use of the pesticide and once again registered its use as of late 2016. Sulfoxaflor is manufactured by Dow AgroSciences.

Sulfoxaflor is in a relatively new insecticide class that specifically targets piercing/sucking insects such as aphids, mealybugs, psyllids, plant bugs and whiteflies. Sulfoxaflor works against pests that are becoming resistant to carbamate, neonicotinoid, organophosphate, and pyrethroid insecticides. However, because of concerns about possible harmful effects on bees and other pollinators, the EPA has placed more restrictions on its use to protect bees.

Some of those restrictions include prohibiting applications to post-bloom for crops that are attractive to bees. Also, use of the insecticide on some crops that were allowed under the original registration are now not allowed. Because some plants bloom indeterminately (meaning not all at once) it’s harder to protect pollinators. As a result, the new registration does not allow use of sulfoxaflor on citrus, cotton, cucurbits, soybeans and strawberries. It also cannot be applied on crops grown for seed production, including turf.

In addition, the EPA has required label restrictions to minimize spray drift, which has the potential to harm bees foraging on plants near treated fields. The labels will state that applications must be made with medium to coarse spray nozzles and are prohibited when wind speed is over 10 mph. Also, applicators must maintain a 12 foot on-field down-wind buffer if there is any blooming vegetation bordering the treated field.

The EPA says that, overall, sulfoxaflor presents a low risk to aquatic and terrestrial organisms and low residual toxicity to pollinators and the new restrictions will further protect pollinators.

For more information, see the EPA’s website on sulfoxaflor

Audio (MP3)

New Technology and New Things to Think About
By Glenn Nice, UW Pesticide Applicator Training (PAT) Program.

Update 2/20/2017: The XtendiMax and Engenia websites now have listed several tank mix partners. The XtendiMax web site has listed several nozzles.

Agriculture has to be an adapting industry because it exists in a changing world. The challenges keep changing and shifting as new pests shift position from being a nuisance to being serious issues. Pesticide resistance is not new, those who control pests have been dealing with resistance for some time now. However, some pests have taken this to new levels. The success and dependency on some of our tools and has led to feeling this pain at greater levels. However, new tools are available and are going to be available in the world of weed control that are designed to help in the management of resistant weeds.

The development of Enlist™ and Xtend™ technologies are in part a response to the development of glyphosate resistance in Palmer amaranth, tall waterhemp, giant ragweed, horseweed and others. In some cases, these weeds have shown resistance across multiple modes of action that typically have controlled them in the past. The products for these technologies contain growth regulators as their active ingredient. Both these technologies are unique in that they are crops that have been genetically engineered to tolerate the herbicide 2,4-D and dicamba post-emergence (or over-the-top) applications.

The three products that are in the market, or are going to be in the market are Engenia™ from BASF, Enlist Duo with Colex-D™ technology from Dow AgroSciences and XtendiMax with Vapor Grip™ technology from Monsanto. Enlist Duo with Colex-D is a combination of glyphosate and 2,4-D and was available in the market last year. XtendiMax™ and Engenia™ are dicamba products that will be available this growing season.

At this point, it should be stressed that these new products can only be used on soybean, corn and cotton that have been genetically engineered to tolerate their active ingredient. Furthermore, these herbicides being labeled for use in these technologies are formulated to increase safety. Other 2,4-D and dicamba products typically are not and may not be labeled for use in these technologies. As always, follow label directions at all times, otherwise you are breaking the law.

Additionally, the labels are designed with additional precautions and instructions to further reduce the probability of particle drift, vapor drift and tank contamination. Many of these precautions and instructions are setting precedent for possible labels in the future.

Bob Wolf of Wolf Consulting and Research LLC has created a comparison of the labels of the three products mentioned above in “Sorting out the Application Requirements for Enlist Duo™, XtendiMax w/VGT™, and Engenia™.” The following is information taken from that comparison and the labels themselves.

Tank Mixes

In the past, labels might have information about some tank mixes, but many tank mixes were not listed. The Federal Fungicide, Insecticide and Rodenticide Act (FIFRA) allows any tank mix not prohibited on the label. However, in many cases you took your own chances tank mixing two products that was not explicitly mentioned on the label. Hence all the history behind “the small jar” test.

However, in the case of these new products, no unapproved tank mixes are allowed. This is in part due to chemistry. Some tank mixes might have the potential of changing the chemistry of the herbicide’s active ingredients increasing their potential to volatilize. Another concern is if tank mixing causes synergy or not between the tank mix partners. All three of these products are going to require you to go to web sites to determine if the tank mix you want to make is allowed or not.

The Enlist Duo™ web site lists several products that can be tank mixed. The Engenia™ web site has several tank mixes listed. The Xtendimax™ does not have any tank mix partners listed at the time of writing this article.

Ammonium Salts

Do not use ammonium salts with either Xtendimax™ or Engenia™. The Enlist Duo™ product will not allow you to substitute water with a nitrogen source.

Aerial Applications

None of the above products will allow aerial applications.

Specified Nozzle Type(s)

The Enlist Duo™ product has several nozzles listed on the label giving pressure ranges for each one. Both the XtendiMax™ and Engenia™ have one nozzle listed at the moment— the Turbo TeeJet™ TTI1004. Applicators will have to go to the products' website to get other nozzle listings. At time of releasing this article, Monsanto did have a list of nozzles and recommendations on the provided web site. See web site below.

Pressure Requirements

XtendiMax™ has a “Do Not exceed 63 PSI” requirement. The Engenia™ label states that applicators cannot exceed the nozzle manufacture’s recommended PSI range and Enlist Duo provides pressure ranges for the nozzles they have listed. There is no minimum PSI, but going below the recommended ranges can lead to loss of spray pattern.

Spray Volume

Enlist Duo™ requires a spray volume of 10-15 Gallon Per Acre (GPA). Both XtendiMax™ and Engenia™ require spray volumes of 10 GPA.

Applicator Speed

Both Engenia™ and XtendiMax™ list maximum speeds of 15 MPH. It should be noted that depending on the equipment you are using, pressure may direct what speed you may have to travel at. The Enlist Duo™ label does not specify speed.

Boom Height

Enlist Duo™ refers you to the nozzle manufacturer for boom height. However, both the XtendiMax™ and Engenia™ set boom height at a maximum of 24 inches above the target.

Wind Speed

Both the XtendiMax™ and Engenia™ labels restrict applications to between 3 and 15 MPH. They both also warn against temperature inversions. The Enlist Duo™ label sets a maximum wind speed of 15 MPH.

Buffer Zones

There are buffer zones—certain distances from sensitive areas or endangered species where you cannot make applications. Enlist Duo™ sets a 30-foot buffer zone downwind of sensitive areas. XtendiMax™ requires a 110-foot (22 fl.oz.) or 220-foot (44 fl.oz.) buffer to downwind sensitive areas. It should be noted that the 44 fl.oz. rate is for preplant, at planting and preemergence applications only. Engenia™ requires a 110-foot buffer zone between application and downwind sensitive areas.

The labels of these products are different from most of the labels you may have worked with in the past. They tend to be more specific and more restrictive. The manufacturers have formulated these products to reduce the potential for vapor drift and the label directions, all enforceable by regulators, are designed to further reduce the potential for drift.

Anticipation of these products is mixed depending on which side of the debate you are on and if these tools will have value to you or not. There are several crops and many sensitive plants out there. They will be valuable tools in the management of resistant weeds. However, as applicators, it is our responsibility that we use the tools as safely and effectively as possible in the correct legal manner. The alternative is we will lose them.

I would like to thank Bob Wolf of Wolf Consulting and Research LLC for releasing a comparison of the three products; much of the information in this article was guided by that document.


Enlist Duo


Audio (MP3)

EPA Pesticide Registation Test Guidelines.
By Glenn Nice, UW PAT Program.


The Environmental Protection Agency (EPA) registers specific pesticides for specific uses. They use a “Risk Benefit Analysis” to make decisions for pesticide registration. This process evaluates the risks of using a pesticide and weighs it against the benefits of being able to use that pesticide in controlling a pest. For this process to work, risks have to be identified as well as possible at the time of registration. Failure in identifying these risks can lead to a failure in the “Risk Benefit Analysis” and lead to unacceptable results. Companies that are registering new pesticides or chemicals have to go through a complicated and expensive process that includes identifying possible risks. Partially based on the pesticide being registered and where it is being registered for, there are standards and requirements for how this is done. It involves a host of detailed tests that have to be performed and submitted to the EPA. Companies that have the facilities and resources to accomplish these tests do it, but often it is contracted out to various labs that specialize in the required components and tests. The EPA provides guidelines on what tests should be done, how they should be done and what data needs to be provided to the EPA. There are 11 areas, called series, that the guidelines provide. The 11 areas of the guidelines are:

1. Product Performance (810)

Are the claims true? If a product states that it controls pest X, then the tests have to provide support of that claim. This provides guidance on efficacy data for pesticides, disinfectants, control of fire ants, pests of humans, biting pests, insect repellants, etc. Companies have been fined and ordered to remove their products from the market place due to not being able to support claims of performance.

2. Product Properties (830)

What are the properties of the pesticide being sold? This provides descriptions of the materials being used, production process and identification of any impurities that may be encountered. This also describes physical properties of the pesticide itself, such as solubility, boiling points, corrosion characteristics, flammability, and others.

3. Fate, Transport and Transformation (835)

A pesticide manufacture has to report on how the pesticide will act in the environment. This includes studies to investigate how the pesticide might move in the soil; leaching studies. But it also includes studies that look into how the pesticide will break down or degrade. It also looks at how it moves in various environments, such as an aquatic environment. This area of guidelines also provide a guide on performing field volatility studies.

4. Spray Drift (840)

This area looks at particle drift. It includes an aerial drift evaluation, spray droplet size spectrum and a spray drift field deposition study.

5. Residue Chemistry (860)

Understanding how pesticides can remain on harvested products and on materials is a key in identifying risks of use. This area of the guidelines provides information on how studies should be conducted looking at residues in meat, milk, poultry and eggs. It also looks at storage stability and food handling. Guidance on field residue trials is also provided.

6. Health Effects (870)

In this area all the LD50s are identified. It includes guidelines for identifying acute oral toxicity, dermal toxicity, eye irritation and others. This area also provides guidance on studies looking at longer term exposure, including 90-day toxicity studies, prenatal developmental toxicology and reproduction and fertility effects. This area also includes genetic toxicity test guidelines and neurotoxicity (nerve effects). The Health Effects area has guidelines on the study of the effects on companion animals, looking out for the family pet.

7. Occupational and Residential Exposure (875)

This area provides guidelines for studies looking at applicator exposure and postapplication exposure monitoring. Indoor and outdoor dermal and inhalation exposure to the applicator. It also provides guidelines on studies of soil residue investigation. As part of this area a manufacturer has to identify when and maximum human exposure might occur.

8. Biochemicals (880)

This section of the guidelines provides guidance on studies required for a specific type of pesticide. Biochemical pesticides use byproducts or chemicals found in living organisms. This area of the guidelines provides guidance studying the effects on the immune system and product identity. For example reporting the amounts of the biochemical in the product being used.

9. Microbial Pesticide (885)

Like the area on biochemicals, these guidelines focus on a specific type of pesticide. Microbial pesticides are pesticides that use living microbes to control a pest. For example applying spores of a fungal disease to control aphids. In these guidelines, guidance is given on studies concerning residues, storage, toxicology, nontarget effects and how the living agent acts in different environments.

11. Endocrine Disruptor Screening Program (890)

The endocrine system is the system that produces and distributes hormones in a living thing. It regulates many of the systems in the body that are involved in growth, metabolism, sexual function and many others. This set of guidelines provides guidance on studies that look at the effects the pesticide may have on the endocrine system. It focuses on not only human, but on amphibians, fish, and birds. Finally, the last area of study that the guidelines cover has recently been updated in 2016.

12. Ecological Effects Test Guidelines (850)

The Ecological Effects test guidelines breaks down into four groups. The first, group A, are tests that look at the effects of a specific pesticide on Aquatic and Sediment-Dwelling Fauna and Aquatic Microcosms. This group of tests focuses in on acute toxicity and bioconcentration of the pesticide in question. There are fourteen guidelines for tests. The guidelines for Group A have been recently updated. These guidelines provide instructions on not only what tests have to be carried out, but how they should be carried out. They outline the model species to use, for example rainbow trout (Oncorhynchus mykiss), bluegill sunfish (Lepomis macrochirus) for fresh water and silversides (Menidia sp.) for saltwater environments. The guidelines provide exposure durations and concentrations and test limits that registrants have to follow for registration.

Group B, looks at Terrestrial Wildlife. This provides guidelines on acute oral toxicity, dietary toxicity and reproduction effects for birds. It also provides guidelines for mammal testing and field testing for terrestrial wildlife.

Group C focuses in on test guidelines that identify risks to beneficial insects, invertebrates and soil and water organisms. Guideline 850.3030 - Honey Bee Toxicity of Residues on Foliage are guidelines to test substance residues on the intended target, most likely a crop. Is takes crop foliage that has been sprayed at various times after application and introduces it to a test population for 24-hours. The results provide what is called an RT25. The RT25 stands for Residual Time that brings mortality down 25%. This provides an indication of residual toxicity of substances to pollinators.

Group D provides guidance for tests that look at terrestrial and aquatic plants, cyanobacteria, and terrestrial soil core microcosms. It is a series of tests that look at the effects of substances on algae, terrestrial plants and the microorganisms found in the soil. The test within this group include seedling emergency and seedling growth (850.4100), terrestrial plant field studies (850.4300), algal toxicity (850.4500), plant uptake and translocation (850.4800) and others.

Finally group F provides guidance on field test data reporting. This guideline covers how the data should be presented to the EPA. It covers some of the requirements for data quality. It touches on chemistry methods and required validation. Pesticides are some of the most regulated substances on the market. To be able to do a fair “risks to benefit” analysis risks need to be identified as well as the benefits. To identify those risks we have to rely on science and the tools that science has available. Guidelines and standards have to be created to do this so that the information provided is consistent and accurate.

Test Guidelines for Pesticide and Chemical Substances

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