Illinois Pesticide Review
March / April 2014
In This Issue
How Are You Measuring Up?
This past summer, members of the University of Illinois Pesticide Safety Education Program attended the Pesticide Applicator Certification and Training Workshop in St. Paul, MN. Fred Whitford of Purdue University and Pat Hipkins of Virginia Tech provided an entertaining and informative session on the various aspects of accurately measuring pesticides.
In the presentation, Whitford and Hipkins identified six equally important steps required to achieve safe and effective pesticide application. Applicators must: 1) Correctly identify the pest, 2) select an appropriate and effective pesticide, 3) calibrate equipment to uniformly apply the correct amount of spray solution, 4) correctly measure and mix the pesticides, 5) review the treatment site before and during the application, and 6) monitor the results for effectiveness.
Of these steps, measuring pesticides is assumed to be the easiest and is often overlooked in importance. However, the errors that occur while measuring potentially impact the rate of pesticide applied, thus affecting cost and effectiveness of the treatment. The need for precise measurements becomes increasingly important as smaller rates are used and as the cost of the pesticide increases. That is, more precision is required when measuring by the dry ounce or fluid ounce than when measuring by the pound or gallon.
Liquid formulations are measured by volume, usually with the aid of a measuring cup or spoon. Measuring the precise amount of liquid formulation needed may seem easy enough; however, errors can occur during this step, often due to the measuring device used. Consider that not all measuring devices are accurate. Some devices may have a printed disclaimer "Measurements are approximate" or "Accuracy ± __%". The graduations (markings) on some measuring devices may be off by as much as 15 percent! Calibration is the only way to be certain that a device is accurate. Check the accuracy of a measuring device by using a graduated cylinder available at science supply stores. Graduated cylinders use metric units. For conversion, 1 cup (8 fluid ounces) is equivalent to 236.6 milliliters.
The design and overall condition of the measuring device will also influence how well measurements can be made. Avoid measuring cups with painted graduations. The paint may wear off resulting in illegible numbers. Containers with difficult-to-read numbers should be replaced. The following were some recommended characteristics to consider when purchasing measuring cups:
• The graduations on the devices should be visible, easy to read, and etched into the container.• Ideally, the measuring device should have one unit of measurement, either English or metric. Having multiple units on the same device may be confusing and could lead to measurement errors.
• Taller and narrower measuring devices tend to be easier to read because they often have more space between the graduations. They also tend to have more graduations allowing for increased precision.
• The device should have a pour spout to help prevent spillage when transferring to spray tank.
Figure 1. Beakers, such as the one pictured, are primarily intended to hold liquids. The graduations provided are approximated (note the "APPROX. VOL." printed on the beaker) and should not be used for measuring unless a very low level of accuracy is needed. The graduations on measuring cups may provide a similar level of accuracy. The accuracy of a measuring device can be determined by calibrating it with a graduated cylinder.
Figure 2. The markings on this graduated cylinder are painted on. Painted marking tend to wear with use. Replace any measuring devices with difficult-to-read markings and graduations. When possible, select a measuring device with etched or raised markings.
Safe and effective pest control requires an attention to detail during every step of the process, including pesticide measurement. Common errors associated with measuring dry formulations will be addressed in the next issue of the Illinois Pesticide Review.
This article was based on the presentation "The Forgotten Art of Mixing and Measuring" given by Fred Whitford of Purdue University and Pat Hipkins of Virginia Tech at the 2013 Pesticide Applicator Certification and Training Workshop. Information from the Purdue Extension Publication "Measuring Pesticides: Overlooked Steps to Getting the Correct Rate" was also used for the production of this article.
All That Extra
When calibrating sprayers, the goal is to have no pesticide product remaining in the tank when all the spraying is done. You hit that last acre or 100 square feet, and the tank is empty.
That's perfect calibration. As much as we'd like to say it happens all the time, it often doesn't.
More times than not, there's some product left in the tank.
What can you do?
There are many things you legally CANNOT do, which can and do result in some large 5-figure fines if caught by the various regulatory agencies.
You CANNOT dump the excess down the drain or into the sewer or storm sewer system. That's a big legal no-no, even if you dilute the product.
You CANNOT go behind the storage building, barn or shed and open up the nozzles and empty the material on the ground.
You CANNOT go down a country road in the middle of the night and clear out all the materials on the gravel road or ditch.
Legally, you have only two choices, which is why calibrating how much you need is extremely important.
First, you can apply the pesticide on another area listed on the product's label. Let's say you are spraying a corn field or a golf course, finish up the spraying and notice you have 5 gallons left. Check the label and see if there is another crop/location where you can legally apply the product, even if that wasn't your intent as you started out the day. Maybe the label says you could spray ditches or fence rows, or the parking lot of the golf course. In this case, those are legal areas you could spray the excess product.
The second option is to dilute the product with more water and spray the previous covered area provided you are not exceeding the labeled rate and not washing off your first application. This may be a yearly application maximum rate for many agronomic crops; it could be a reapplication if you opted for the lower labeled recommended rate if one was provided.
It is possible some product could be stored for future application provided the pesticide doesn't break down or bind with the spray application equipment including the tank, pump, hoses and nozzles. However, once mixed, products can lose their effectiveness.
Some companies may collect the excess and store it for later legal disposal at collection sites. Make sure to avoid mixing various excess products to avoid any physical incompatibilities.
Mixing and Loading
As the spring spraying season starts, it's important to remember most pesticide poisonings occur during the mixing and loading stage, when you're putting the pesticide in the tank and adding the water.
Below are a quick few things to remember during this process:
• Never work alone. Make sure someone else is present in case a serious problem occurs, especially with fumes.
• Make sure there is good ventilation. Open up all doors to get cross ventilation. Turn on fans to circulate the air. If possible mix and load outdoors on a concrete apron to catch any spills.
• Wear the correct personal protection equipment (PPE.) These include the basic long-sleeved shirt, long pants, hat, socks, and shoes. Additionally, put on chemical-resistant gloves and boots/overshoes to protect the hand and feet. Have a tight-fitting pair of goggles to shield your eyes. A chemical-resistant apron is also recommended to protect your midsection, including the crotch where pesticides are readily absorbed.
• After mixing and loading, wash the gloves, goggles, boots and aprons to avoid potential cross contamination in the future. Store the PPE away from the pesticides.
• If clothing becomes contaminated with pesticides during mixing and loading, remove the clothing. It doesn't make sense to wear pesticide-contaminated clothing for the rest of day while applying the chemicals.
• ALWAYS read and follow the label instructions.
Oregon Bumblebee Incidents Results
The Oregon Department of Agriculture has completed its investigations into four separate incidents that resulted in bumblebee deaths last summer in Wilsonville, Hillsboro, West Linn, and downtown Portland.
Investigations performed by ODA's Pesticides Program centered on the use of pesticide products containing two active ingredients, dinotefuran and imidacloprid. ODA's findings identified violations of the Oregon Pesticide Control Law.
ODA has issued six civil penalties totaling $2,886 in connection with the incidents. Three civil penalties being issued are connected to the largest of the bumblebee incidents, which took place in Wilsonville in June. In that incident, an estimated 50,000 bumblebees died following the application of dinotefuran on European linden trees. The other three civil penalties are connected to a smaller bumblebee incident on a landscaped business property in downtown Portland following the application of a pesticide product containing imidacloprid, also on linden trees.
For its role in the Wilsonville incident, an arborist company, which is licensed commercial pesticide application company, has been issued a civil penalty in the amount of $555 for performing a pesticide application in a faulty, careless, or negligent manner. The two pesticide applicators in the incident were each issued civil penalties also in the amount of $555.
ODA's investigation determined that the linden trees were clearly in bloom at the time of the pesticide application. The product label states that the pesticide is known to be hazardous to bees when applied onto flowering trees in bloom and should not be used under those conditions.
The same company has also been issued a civil penalty in the amount of $407 for applying a pesticide product inconsistent with its labeling in connection to the downtown Portland incident. ODA's investigation determined that the application rate of the pesticide product was in violation of the label instructions. The two pesticide applicators in the incident were each issued civil penalties also in the amount of $407.
ODA also investigated bumblebee incidents in Hillsboro and at the Oregon Golf Club in West Linn. ODA has issued notices of violation to the same arborist company for incomplete pesticide application records and employing a pesticide applicator that did not have the appropriate license. The applicator has also received a notice of violation.
These notices are connected to the incidents in Wilsonville and at the Oregon Golf Club. No monetary fine is associated with these notices. However, the violations remain on the company's and applicator's enforcement record for three years. ODA found no evidence of wrongdoing in the Hillsboro incident.
In addition to enforcement action, ODA has taken several measures to protect bumblebees and other pollinators from exposure to pesticide products containing dinotefuran and imidacloprid, the two active ingredients implicated in the bumblebee deaths.
The temporary rule adopted by ODA in June that restricted use of 18 pesticide products containing dinotefuran expired December 24. In its place, ODA has adopted permanent restrictions on the use of certain pesticide products containing dinotefuran and imidacloprid. As a condition of annual registration for 2014, ODA is requiring an Oregon-specific label statement on dinotefuran and imidacloprid products for use on plants. Labels on these products being distributed into Oregon beginning January 1, 2014 will prohibit the application on linden, basswood, or Tilia species. It appears the tree species' natural toxicity to bumblebees in combination with the pesticide contributed to the bumblebee deaths.
ODA is also expanding its educational efforts on pollinator protection to licensed pesticide applicators and the general public. For applicators, additional emphasis on pollinator protection will be included in the required testing and re-certification process to become licensed. Outreach to the general public will include information on ODA's website as well as brochures and other materials distributed through master gardener programs and retail outlets.
In addition, ODA sent a letter last month to the US Environmental Protection Agency (EPA) requesting additional evaluation of these pesticide active ingredients and other neonicotinoids to determine if use limitations on a national basis should be considered.
Phil Nixon, slightly modified ODA news release.
Comment Period Now Open for Proposed Changes to the Worker Protection Standard
The comment period for the long-awaited proposed rule changes to the Worker Protection Standard (WPS) has opened and will be available until June 17, 2014. Bear in mind that this will be the only opportunity for public comments before the revised WPS becomes final. There will not be another public comment period on another proposed version of the WPS changes. EPA OPP anticipates that the final published rule will be released in the summer of 2015.
The federal register notice, which contains links for commenting, is available at: http://www.regulations.gov/#!documentDetail;D=EPA-HQ-OPP-2011-0184-0119
EPA has an information page about the proposed rule changes at: http://www.epa.gov/oppfead1/safety/workers/proposed/index.html Also at this link (and provided below) is a brief summary for the major proposed changes. However, this summary does not include all variable options and other smaller changes as in the preamble.
For an even more detailed comparison of the existing rule to the proposed changes, check out the 10-page document created by Carol Black, Extension Pesticide Safety Education Specialist at Washington State University. It can be found at: http://pep.wsu.edu/pdf/factsheets/WPS_Rule_Revision_Matrix_WSU_V3.pdf.
This is not an EPA publication, but is instead based on her summary of the EPA proposed Rule. This additional tool can be used to help formulate comments to the proposed Rule. Please note, page number references are aligned with the pre-publication version, which is no longer available. However, the "Unit" references are still accurate.
A brief summary of some of the major new proposed rule changes, compared with the current rule, follows.
Pesticide Safety Training
Current–Train workers and handlers every 5 years.
Proposed–Train workers and handlers every year. Stricter qualifications will be added for trainers of workers.
Current–Current training includes hazards from residues on clothing and includes warnings not to take containers home.
Proposed–Expand training content to include information on reducing take-home exposure.
Current–Grace period of 5 days before full WPS training is required.
Proposed–Grace period reduced to 2 days with added requirement of distributing an information sheet with the training points. Additional training also added to the pre-grace period content.
Current–No requirement for record keeping of training.
Proposed–Records of training required to be kept for 2 years.
Mandatory Posting of No-Entry Signs
Current–Either oral or posted notification is acceptable for Restricted Entry Interval (REI) unless the pesticide labeling requires both.
Proposed–Required posting of treated areas when REI is greater than 48 hours.
Current–No age requirements.
Proposed–Pesticide handlers and early-entry workers must be at least 16 years old. Members of owner's immediate family are exempt from this requirement.
Entry Buffer Areas
Current–Only nurseries and greenhouses require a no-entry buffer area adjacent to area being treated.
Proposed–Entry will be prohibited to 25–100 foot buffer areas during pesticide applications on farms, forests, nurseries and greenhouses. The buffer size will depend on the type of application.
Current–Employer must provide the respirator listed on the pesticide labeling and ensure fit. No record keeping is required.
Proposed–Adopt the OSHA standard for respirators, which includes a fit test, medical evaluation, and training. Record keeping will be required to document completion of these requirements.
Current–The closed system definition does not provide specific criteria for PPE exception.
Proposed–Specific performance standard requirements will be added for closed systems based on the California standard to permit PPE exceptions. (Does not include the California requirement to use closed systems for certain types of pesticides.)
Current–Application-specific information must be posted at a central display until 30 days after the REI expires. There is no requirement to make safety information available to authorized representatives for workers and/or handlers.
Proposed–Require employers to maintain application-specific information, labeling and Safety Data Sheets (SDS) and make available to workers, handlers, or their authorized representatives. This information must be retained for two years.
Proposed–Remove requirement to post application-specific information at central display.
Notification for Early-Entry Workers
Current–Early-entry workers (entering before REI has expired) must be informed on hazards listed on pesticide labeling.
Proposed–Notification expanded to also include the pesticide application (what was applied, when and where), specific task to be performed, and amount of time the worker is allowed to remain in the treated area.
Current–No record keeping required of early-entry notifications.
Proposed–Records kept for 2 years of the notifications provided to early-entry workers.
Definition of Immediate Family
Current–Does not include grandparents, grandchildren, or in-laws as immediate family.
Proposed–Expand to include those listed above.
Again, comments must be received on or before June 17, 2014. Comments must be submitted to http://www.regulations.gov identified by docket number EPA-HQ-OPP-2011-0184. Your comments will help EPA determine the final version of this regulation.
Slightly revised by Michelle Wiesbrook from Ohio Pesticide Safety Education Program newsletter, PEP-Talk, March, 2014 and EPA Office of Pesticide Programs emails.
How to Use EPA’s Bulletins Live! System
By now, you may have seen language on the newer pesticide labels concerning EPA's Endangered Species Protection Program. We have written about this bulletin retrieval system in past issues of this newsletter. You can learn more about the program at these links:
EPA's Endangered Species Protection Program (ESPP):
EPA Updates Endangered Species Protection Program Web Site:
Update on Protecting Endangered Species:
Essentially, if you see the language on the label, simply follow the directions, which will lead you to either calling EPA or going to their website to see if further application restrictions exist. These restrictions are presented in the form of a "Bulletin". For a quick and easy way to learn how to use the system, the University of Nebraska-Lincoln Pesticide Safety Education Program has created a 4-minute video that walks you through the process. Watch it on YouTube at this link: https://www.youtube.com/watch?v=PM5JDX4Cjbs&list=UUuCAmiE--vWiWtha51VKbWg&feature=c4-overview
While another state is given in the video's example, the same steps would apply for use in Illinois. However, currently, no Bulletins exist for the state of Illinois. Keep in mind that Bulletins are continually being added and they do exist for neighboring states. In addition, they are enforceable just as the label is. Please do read and follow all label directions carefully.