Illinois Pesticide Review
March / April 2015
In This Issue
Nursery Dealer Certification
Nursery dealers in Illinois must be certified.
Does your company need a Nursery Dealer Certificate? You may be unaware of Section Seven of the Illinois Insect Pest and Plant Disease Act (ILCS505, Act 90, Sections 90/1 et seq.), which requires anyone who sells or offers for sale, delivers and/or installs any nursery stock to hold a Nursery Dealer's Certificate.
This certification/license is renewed annually. This requirement includes landscape companies whose services include the sale, delivery and/or installation/planting of any type of nursery stock (trees, shrubs, perennials, Christmas trees and/or sod).
Simply stated, the Nursery Dealer certification applies to people in the green industry who are buying, selling, transporting and planting nursery stock, not growing nursery stock.
A fine of $300 shall be imposed for anyone selling, offering for sale or delivering any nursery stock without having a current Nursery Dealer's certificate.
The law dates back to 1928 when there were few landscaping companies. Plant material was purchased from a local nursery and that nursery did the delivery and planting. Today, nursery stock comes from all over the United States and even other countries. Beginning in the 1990s there was an explosion of new landscaping companies who were buying plant material from sources outside Illinois and moving it around the state. During that same period there has been an increase in invasive insect pests and infectious diseases.
It is impossible for the Department of Agriculture to inspect all nursery stock that is grown in Illinois or to check all the stock that comes from out of state. There is simply too much plant material moving through the state on a daily basis to visually inspect every plant. When a quarantinable disease or insect pest problem moves into Illinois, the Department of Agriculture needs to be able to locate and identify it quickly and in some instances notify the nursery dealers in a certain area of the problem. The Nursery Dealer certification helps them make those contacts.
If you are an unlicensed nursery dealer, you can download the required Nursery Dealer Certificate application form at: http://www.agr.state.il.us/pdf/nurserydealerregistration.pdf
Or you can request an application form by calling the Illinois Department of Agriculture office in DeKalb at (815) 787-5476 or Springfield (217) 785-2427.
Nanette Kalscheur, Illinois Dept. of Agriculture
Container Recycling and the ACRC
Recently, I participated in The Pesticide Stewardship Alliance's 15th annual conference. The Ag Container Recycling Council (ACRC) had an exhibitor booth there where I spoke with Ron Perkins, ACRC Executive Director.
Ron was eager to share with me what the ACRC does. In their 23 years of service to U.S. growers and custom applicators, they have collected over 150,000,000 pounds of triple-rinsed, one-way rigid HDPE plastic commonly used in plastic agricultural crop protection, animal health, specialty pest control, micronutrient, fertilizer and/or adjuvant product containers.
Containers are typically ground up on site, washed, and then used in a range of end-use products approved by the ACRC, such as agricultural drainpipe. That's a lot of containers that have been saved from landfills and it's great that they have found new uses for these materials!
The ACRC is a nonprofit organization whose mission is to promote and facilitate the collection and recycling of pesticide containers. ACRC is composed of over 50 member and affiliate companies. The ACRC has regional contractors who handle the recycling efforts in their respective regions. For more information about ACRC and a map with contact information for the contractors, visit http://www.acrecycle.org/. The contractor for Illinois is Container Services Network (CSN), located in Greenville SC. CSN can be reached at (866) 225-6629 or by visiting their Web page at http://www.containerservicesnetwork.com/Index.htm. Recycling through CSN is generally available at no cost. Besides serving as a regional contractor for ACRC, CSN also coordinates recycling activities with the Illinois Department of Agriculture and several individual chemical manufacturers. CSN is the ACRC's regional contractor for 14 other states across the Midwest as well.
In addition, The Pesticide Stewardship Alliance is an organization that promotes recycling pesticide containers. TPSA is an organization made of government organizations from local, state, and federal levels; research and education institutions; and corporations. TPSA promotes stewardship of pesticide use for every process involved in their usage, from manufacturing to the recycling of empty containers. For more information of TPSA, visit http://www.tpsalliance.org/. The conference I attended had speaker sessions divided into two primary tracks, one geared more for pesticide safety educators and one geared more for those in the container recycling industry. The agenda was robust with great information. As a pesticide safety educator, you can likely guess what session I stayed in. However, if I could have been in two places at once, I would have loved to have learned more about pesticide disposal issues.
Every year, the Illinois Department of Agriculture offers a free recycling program for agrichemical containers. The schedule has not been posted yet; however, you can learn more about the program at http://www.agr.state.il.us/agrichemical-container-recycling-program.
At the bottom of the page, there is an inspection checklist to aid in preparing containers for recycling.
At the end of our discussion, Ron insisted that I take a jug opener which really looks like it would be a handy device. One side has teeth for cutting into foil seals. The other side locks tight over the cap to prevent slippage when opening tight caps. Because Ron is a nice guy and because they have a bunch of these in storage, Ron said it would be fine for me to promote these. If you contact Ron at email@example.com he'd be happy to mail you one.
Container Recycling-Saving Money and the Environment, by Scott Bretthauer in the March 2006 issue of this newsletter, http://web.extension.illinois.edu/ipr/i4148_829.html
Spring Cleaning of Pesticide Storage Areas
For many, spring is an opportunity to deep clean and organize homes, offices and other areas that have become cluttered over the winter and previous year. Your pesticide storage areas shouldn't be overlooked. A well-organized and maintained pesticide storage area will help to save time and money during the busy application season.
Start the process by inspecting Personal Protective Equipment (PPE), first aid kits, eye wash stations, fire extinguishers and emergency spill kits. Replace any worn-out, expired or missing items as soon as possible. First aid kits and PPE should be stored separately from pesticides, but in a nearby location easily accessible. Emergency spill kits should include: PPE, a broom, a shovel, heavy duty plastic bags and absorbent material such as clay, pet litter, fine sand, activated charcoal, or vermiculite.
The Safety Data Sheet (SDS, formerly Material Safety Data Sheet/MSDS) of the spilled product will list any additional or specific substances needed to clean up the material. Pesticide storage areas should be used for pesticides and pesticide equipment only. Food, feed, fertilizers, seed, veterinary medicines and other non-pesticide related products should not be stored with pesticides.
Inspect and inventory all pesticides. A well-maintained inventory helps save money and avoid waste by preventing over-purchasing products and loss due to expired products. Check all containers for corrosion, leaks, and loose or broken caps. If containers are damaged, transfer any remaining pesticide to a similar container along with the label. NEVER transfer pesticides to containers meant for food or drinks. All pesticide containers should have an attached complete, clean, and legible label. Contact your pesticide dealer or manufacturer to replace missing or damaged product labels.
Check to see if pesticide is still within its shelf life. Unusable or unwanted products should be stored separately from usable until they can be disposed of accordingly. Avoid waste by writing the date of purchase directly on the pesticide container. Use the oldest inventory first. Update and maintain an easily accessible log of all pesticides including copies of labels and SDS (MSDS).
Organize the storage area by product, container type, and container size. Herbicides, insecticides, fungicides, and other pesticides should be grouped and stored in separate locations within the storage area. This will help to prevent contamination or confusion between products with similar containers. Highly toxic products require additional precautions when handling and should be kept apart. When possible, pesticides should be stored low to the ground, but off the floor. Large drums or heavy bags should be stored on plastic pallets. Other products should be stored on sturdy metal shelving with the heaviest containers and liquid products on the lower shelves.
Finally, check to see that the storage area is safe and secure. Designated storage areas for pesticides should be labeled at every entrance or window with highly visible, weatherproof signs stating Danger- Pesticides- Keep Out! or a similar warning. Storage areas should remain locked at all times and access should be restricted to those who have an active role in the application of pesticides.
Posting Lawn Markers – Are You Up-to-Date?
It's springtime and your company is probably busy performing fertilizer and pesticide treatments to your customers' lawns. Does your company have the correct lawn markers and do you know when to use them?
According to the Lawn Care Products Application and Notice Act and Rules, lawn markers are to be placed immediately following an application of lawn care products. Under the law, both fertilizers and pesticides are considered lawn care products.
If you are under contract to treat the common areas of a townhouse subdivision, you need to post the lawn markers immediately after you treat the main entrance areas (usual points of entry). Do not wait to post until the entire subdivision has been treated. Single-family residences are much simpler, because they have a single point of entry and the placing of lawn markers is done immediately following the treatment.
In Illinois, there are very specific requirements for the size and color of the lawn markers. The marker must be a 4-inch by 5-inch sign attached to a dowel or other support, extending no less than 12 inches above the turf. Regardless of what your company's colors are, the lawn marker must be white with contrasting colored lettering and the lettering height must not be less than 3/8 inch. Each lawn marker must state the following:
"LAWN CARE APPLICATION – STAY OFF GRASS UNTIL DRY – FOR MORE INFORMATION CONTACT:" (your business name and telephone number should be inserted).
If your company is applying lawn care products on golf courses, the requirements are different than those for residential properties. An all-weather, 8 ½ by 11 inch poster or placard with lettering at least ½ inch in size must be present at all times. The poster or placard must read:
"PLANT PROTECTANTS ARE PERIODICALLY APPLIED TO THIS GOLF COURSE. IF DESIRED, YOU MAY CONTACT YOUR GOLF COURSE SUPERINTENDENT FOR FURTHER INFORMATION."
This notification is to be prominently displayed in the pro shop, locker rooms and first tee at each golf course.
Now that you know the requirements for lawn markers you can focus your efforts on providing a quality service to your residential and commercial customers.
Nanette Kalscheur, Illinois Dept. of Agriculture
EPA Rolls Out Drift Reduction Technology Program
In October of 2014, the EPA finally introduced its Drift Reduction Technology Program. A drift reduction technology, or DRT, is a technology designed to reduce the risk of pesticides moving off target during an application.
The DRT program was started in 2006 and many different organizations, including the USDA-ARS, spray technology manufacturers, pesticide regulatory agencies, and universities were involved in developing the program. The purpose of the program is to verify the effectiveness of various DRTs at reducing drift and to encourage their usage by pesticide applicators.
Reducing drift has a magnitude of benefits to the environment, owners of adjacent crops, the public, and the applicators themselves. The direct benefit the applicator receives from the EPA via the usage of a DRT is reduced application restrictions when applying a pesticide.
For the purposes of their program, the EPA defines five classes of drift reduction technologies:
1. Nozzles – nozzle types that reduce the amount of fine droplets
2. Sprayer modifications – devices like hoods or screens
3. Spray delivery assistance – things like air-assisted sprayers
4. Spray property modifiers – spray components such as drift reduction adjuvants
5. Landscape modifications – hedges or shelter belts that reduce drift
One of the major goals of the DRT program is to provide a process for verifying that DRTs work and how well they work to reduce drift. Another major goal is to provide encouragement for the use of DRTs by applicators. According to the EPA, the DRT program is voluntary. Drift reduction technology manufacturers, pesticide registrants, and applicators will not be required to participate in the program.
The DRT process begins with a manufacturer of some type of technology that reduces spray drift who desires their technology to be registered as a DRT. They conduct tests to compare their product with a reference system. The tests are conducted using a strict protocol developed by the EPA.
The reference system is also determined by the EPA, and will vary depending on the type of DRT being tested and the type of tests used in the verification process. The data from the tests are compiled in a verification report that is then sent to the EPA. The EPA analyzes the report and data and decides if the technology does indeed reduce drift, and if so by how much.
The DRT is then assigned a * rating that signifies how much it reduces drift. The following is how the stars are assigned:
< 25% drift reduction: no DRT rating
25 to 49% drift reduction: DRT * rating
50 to 74% drift reduction: DRT ** rating
75 to 89% drift reduction: DRT *** rating
>=90% drift reduction: DRT **** rating
The EPA will post all DRTs and their * rating on the DRT website.
There will be three types of testing that can be used to evaluate the effectiveness of a DRT compared to the appropriate reference system. The first option is to use a low-speed wind tunnel. While it might sound like a low-speed wind tunnel test is intended to measure the amount of spray that drifts downwind, this is actually not what it is designed to do. A low-speed wind tunnel is used to measure the spray droplet spectrum of the DRT.
A laser diffraction instrument is used to measure the spray droplets from the DRT. The low-speed air movement created by the fan in the wind tunnel ensures that very small droplets are adequately sampled by the laser by pushing them down from the DRT and across the path of the laser. The low-speed wind tunnel test is designed to test nozzle and adjuvant types of DRTs for use on ground application equipment.
The second option is a high-speed wind tunnel. As with the low-speed wind tunnel, the high-speed air is not used to push spray downwind so that drift can be measured. Instead, the goal is the same as with the low-speed wind tunnel – to measure the spray droplet spectrum of the DRT.
The high-speed wind tunnel, however, is for testing nozzle and adjuvant types of DRTs for use on aerial application equipment. The high speed is needed to mimic the high-speed air encountered during an aerial application. This high-speed air is a strong determining factor in the spray droplet spectrum for aerial application. Figure 1 shows a rotary atomizer being tested in the high-speed wind tunnel.
For both the high- and low-speed wind tunnel testing options, the reference system to which the DRT will be compared is a specific nozzle. The wind tunnel, with a laser diffraction instrument, will measure the spray droplet spectrum for both the DRT and the reference nozzle. These data will be sent to the EPA, who will enter the data in a software program that models drift from pesticide applications. It is the results of this modeling analysis that will be used to decide the percentage reduction in drift that the DRT offers compared to the reference system.
The low- and high-speed wind tunnel tests are designed to measure droplet size for nozzle and adjuvant DRTs and are prohibited or limited in their ability to evaluate acceptability for the remaining three classes of DRTs. These DRT types will need to be tested using the third option, field testing.
Of the three testing options, field testing is the only one that directly measures the amount of drift coming from the application. A field test is conducted with a sprayer making an application along a designated application swath – a predetermined pathway in which the sprayer will travel while spraying. This swath must be oriented perpendicular to the wind direction.
Sampling locations will be located at regular intervals downwind from the application along transects that are parallel with the wind direction (figure 2). A tracer dye will be added to the spray solution. After the application, the samplers from the sampling locations will be measured for the amount of the tracer dye deposited on them. This will result in a direct measurement of the drift as opposed to modeling drift based on a droplet size spectrum.
The drift from the applications of the DRT and the reference spray system are then measured under identical or similar conditions, which include wind speed, wind direction, temperature, humidity, and spray release height.
While it may seem that the field study is the best and most accurate method to test a DRT, it is actually time-consuming, expensive, and fraught with potential problems. Small changes in wind direction or speed during the test can make any comparisons between the DRT and the reference system difficult to interpret.
Once the testing has been completed and evaluated by the EPA and the DRT has received its star rating, the DRT and its rating will be posted on the EPA's Office of Pesticide Program's (OPP) website. The next step in the process is up to the pesticide registrants. They have the option of including the potential use of a DRT when they write their product label.
The label would include optional instructions for using DRTs to apply the registered product; if applicators choose to use a DRT then they would be required to follow those instructions on the label pertaining to the use of DRTs. As part of the label review and approval process, the EPA would then consider the use of DRTs and their rating categories when it conducts its risk assessment and risk management decisions.
The label would include instruction for the use of both non-DRT-rated and DRT-rated application equipment. Pesticide applicatord would read the label and determine which type of equipment to use to make the application. If they choose to use a DRT-rated type of equipment, they would use the OPP's website to select DRTs that have been verified and rated by the EPA.
The applicator would then follow the section of the label corresponding to the use of application with a DRT. The benefit to the applicator is that the use of the DRT would allow the applicator to make the pesticide application with fewer or reduced application restrictions. This could be a reduced buffer zone distance, less restrictive wind speeds, or similar restrictions.
We will use a hypothetical example to show how the DRT program might function for an applicator. Be advised, however, that this program is still in its infancy and subject to change. The exact parameters defined on the label and how those parameters will be adjusted by using a DRT have yet to be fully determined. This example is for illustrative purposes only.
For this example, let's say the applicator is applying a pesticide that is toxic to aquatic organisms. In order to protect aquatic organisms from drift, the label has a 100-foot buffer from all bodies of water. However, the label allows for the use of DRTs in order to reduce the length of the buffer zone. Each star rating from a DRT allows for a 20 foot reduction in the length of the buffer zone. So one star makes the buffer zone 80 feet long, all the way to a four-star rating, which reduces the buffer zone to only 20 feet.
The applicator realizes he will need to apply the pesticide to several sites that are adjacent to streams. His customers wish to have as much of their lands produce viable crops as possible, which means spraying as much of the field as possible. In order to reduce the length of the buffer strip, the applicator visits the DRT webpage to view the various DRTs that have been approved and selects one. He finds a new air induction nozzle available that has received a four star rating. He decides to use this nozzle for applying this pesticide so that the buffer zone is reduced to 20 feet instead of 100 feet.
There are several questions in the mind of this author that still need to be answered about the DRT program and how it will be implemented. For instance, what happens if I use more than one DRT with my application? Perhaps I choose to use a pre-orifice style nozzle that has received a two-star rating with a drift reduction adjuvant that has also received a two-star rating. Do I get to combine the two two-star ratings into a four-star rating? Or will the EPA require the manufacturers to test their products together as well as separately so that each possible combination of DRT receives its own star rating?
Another question revolves around the use of a buffer zone and wind direction. Drift can only move downwind. If the wind is blowing away from a sensitive area, there would be no need for any buffer zone because it would not be possible for drift to move onto the sensitive site. Will onboard weather monitoring systems that allow the applicator to constantly measure wind direction be eligible for a DRT rating? As the program grows, companies begin to submit their DRTs for verification, and registrants begin to write labels that contain instructions for using DRTs, many of these questions will be answered.
The EPA's DRT program was designed to encourage the use of drift reduction technologies and to verify how well they function at reducing drift. The EPA hopes that the DRT program will encourage the use of DRTs and give applicators more confidence in how well the DRTs work at reducing drift. For more information on the Drift Reduction Technology Program, visit http://www.epa.gov/DRT or http://www2.epa.gov/reducing-pesticide-drift.