States' past reporting efforts fell on deaf ears

Some US states are saying they might stop reporting dicamba damage incidents to the EPA because it costs them so much in resources and the EPA doesn't take any effective action. See the story below.

Beekeeper Richard Coy commented on the story on Twitter (@honeybeecoy): "The same attitude applies with individuals who see Dicamba symptoms on their property. Eventually the 'complainers' stop reporting because applicators are not held responsible. It’s all part of the registrants and EPA scheme. Outlast the complainers until no one complains again."
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Dicamba battle lines drawn

Emily Unglesbee
DTN Progressive Farmer, 4 Jun 2019
https://www.dtnpf.com/agriculture/web/ag/crops/article/2019/06/04/states-threaten-cut-communication

* Some states threaten to cut off communication with EPA on dicamba

At a state pesticide regulatory meeting this week, some state officials threatened to stop reporting their dicamba damage incidents to the EPA during the 2019 growing season, after their past reporting efforts did not bring about substantial changes to agency's dicamba registrations.

"They felt like they provided a lot of information [in 2018], and it took a lot of their staff time to generate that information, but they don't feel that was reflected in any of the dicamba label statements, so states are kind of questioning whether that was a good use of their time," explained Rose Kachadoorian, president of the Association of American Pesticide Control Officials (AAPCO), who led the meeting of the organization's State FIFRA Research and Evaluation Group (SFIREG) in Arlington, Virginia, on June 3-4.

Last year, state officials participated in weekly phone calls with the EPA and submitted an array of data on dicamba injury reports. This year, EPA is proposing that state regulators continue to collect injury data throughout the growing season and then use it to answer a single, end-of-the-season survey for the federal agency to review.

Brian Verhougstraete, a Michigan pesticide regulator, represented the EPA Region 5 states of Illinois, Indiana, Michigan, Minnesota, Ohio and Wisconsin at the meeting. He said several of those states may not cooperate with the proposed survey at all, based on their experience of reporting injury data in 2018.

"To be quite blunt: What did we get out of it?" he said. "The way most states saw it is we got more...labels with vague and unenforceable terms, and we also now have a bunch of extra work on our certification programs. There will be some serious thoughts by states on whether they will participate -- and they may not even have the time, because they'll be too busy with [dicamba] investigations."

While dropping these communication efforts might save time for states, it will also leave EPA with fewer independent sources of information on off-target dicamba injury. In the past, the agency has relied primarily on Extension scientists, state regulators and dicamba registrants to supply information on injury reports and causes.

Several state pesticide regulators also objected to the questions EPA is asking on a draft version of the 2019 end-of-the-season survey on dicamba injury. Many of the proposed questions are aimed at helping EPA write better labels, but none address the extensive time and resources required to address dicamba injury in some states, Kachadoorian told DTN. Nor do any of the questions evaluate the potential human health impacts of state pesticide regulators neglecting their routine inspections to focus solely on a barrage of dicamba complaints, she said.

"There is a price tag to this registration, and that price tag is not being borne by the pesticide registrants or the EPA, but by the state's budgets," she said. "It is a possibility" that some states will not respond at all to the agency's survey this year if EPA continues to ignore these issues, she added.

"But we hope that if [EPA] adds more questions that will actually benefit states by documenting their efforts and the cost to their state, that they'll be more apt to do it," she said.

2019 DICAMBA APPLICATIONS LOOM OVER DISTRESSED STATE AGENCIES

With only 39% of soybeans planted in the U.S. as of June 3, dicamba applications have been minimal in most states, but some regulators are already a year or more behind any future injury complaints, noted Tim Creger, a Nebraska pesticide regulator who represented the EPA Region 7 states of Iowa, Kansas, Missouri and Nebraska at the meeting.

The Missouri Department of Agriculture, which is still processing dicamba injury complaints from 2016, only recently started processing 2017 cases, and has not touched their 2018 workload of 220 complaints yet, Creger noted in his written notes submitted to the meeting. Regulators in Kansas and Iowa are only halfway through processing their 2018 dicamba injury complaints, he added.

"One of the primary take-home messages we've seen in the last two years on dicamba is it's become extremely difficult to keep field staff employed when they get burned out on dicamba investigations," Creger told the meeting participants. "We had one state that lost nine inspectors in the last 18 months because of dicamba, and now they've had to almost fully restock their entire field staff," he said of the Missouri Department of Agriculture.

Creger said many of the Region 7 states are using a "triage" mindset when it comes to addressing dicamba injury complaints in 2019. The Nebraska Department of Agriculture will now require photographic evidence of 20% leaf damage or greater after the V4 growth stage before regulators respond to most crop injury reports, he said. Non-crop injury reports will be handled on a case-by-case basis.

"You would like to think everyone is treated equally, but resources are limited," he said. "People don't get treated equally, and it's become a very difficult, untenable situation for us."

Verhougstraete also said some Region 5 state officials witnessed companies mismanaging the dicamba training sessions that were required for applicators to use dicamba this year. Some were described as "sales pitches," or only lasted 30 minutes instead of the advertised two hours, with people openly wandering in and out of the sessions.

"Is that not fair when states are being held to a higher standard when it comes to ensuring applicators are getting certification training?" he asked EPA representatives in attendance. "Shouldn't the registrants be held to the same standard?"

See more on the meeting from AAPCO here:
https://aapco.org/2015/07/30/sfireg-3/