Making sense of 2,4-D changesA reasoned review of the AVPMA's action on 2,4-D chemicals
Spreading fear and confusion about 2,4-D may help sell newspapers and snake oil – but the facts are actually quite simple...
At the start of October, the AVPMA suspended the label approvals of all herbicides containing 2,4-D and replaced them with a new set of guidelines for in the form of a Special Gazette followed by a replacement Permit (PER87174).
On the surface, it sounded like a sudden, urgent action by the regulator that could have thrown farmers’ summer spraying plans into chaos. Indeed, at least one company (that we won’t name) tried to generate a degree of uncertainty for short-term gain. However most growers weren’t fooled, weren’t surprised, and took the changes in their stride.
15 years in the making
The 2,4-D changes did come in the middle of a media flurry about glyphosphates, which had been subject to a court ruling in the US, a ban in Brazil and a TV expose in Australia – all at about the same time. So media and industry players may have been betting on another ‘big story’.
What they missed was the fact that the AVPMA had been reviewing 2,4-D compounds since January 2003 and had already suspended approvals for
spray, fixed wing aircraft or helicopter). Tables in the AVPMA Permit (PER87174< http://permits.apvma.gov.au/PER87174.PDF>) specify the required distances in each case.
In addition, the AVPMA recommends using Extremely Coarse (XC) or Ultra Coarse (UC) droplets on cereals, fallow fields and pasture during the Spring/Summer period (3 October to 15 April), coupled with a higher per hectare water rate and slower forward speed to maintain product efficacy.
A good guide to suitable nozzles is included in the GRDC’s ‘Maintaining efficacy with larger droplets’ although it’s vital to remember drift control and spray efficacy takes a combination droplet size, boom height, water rate and forward speed – not just nozzle selection.
Finally, 2,4-D products shouldn’t be sprayed if plants are stressed by dry conditions or are excessively moist, or if rain is forecast within the following 6 hours.
The record-keeping regime
More complicated are the mandatory record-keeping requirements for every use of 2,4-D products. These have to be met within 24 hours after
“...the AVPMA’s blanket approach to drift reduction affects all farmers – from those who don’t feel they were ever part of the problem, to those who have lost valuable crops before.”
selected high volatile ester (HVE) products back in 2006, with a final ban on their use from August 2014.
So even with steadily accumulating stories of crop losses caused by 2,4-D spray drift incidents, the closest the AVPMA ever came to ‘urgency’ was their decision to publish new guidelines in time for the 2018 Spring/Summer spraying season.
It’s worth remembering that all 2,4-D compounds are still under review. The ‘human health, occupational health and safety and environmental assessments of 2,4-D’ are still being prepared and an initial report isn’t due until early next near.
After that will come a fairly lengthy regulatory drafting process, public consultation, final decision and implementation process which is estimated to take almost four more years.
Meanwhile, the AVPMA’s blanket approach to drift reduction for 2,4-D affects all farmers – from those who don’t feel they were ever part of the problem, to those who have lost valuable crops before.
The spraying regulations
The rules themselves are fairly straight-forward and apply basic drift-reduction best practice:
- Spray droplets must be not smaller than Very Coarse (VC)
- Maintain a boom height not more than 0.5 metres above the plant canopy (crop or target weeds – whichever is taller).
- Maintain mandatory downwind no-spray distances between the target and any water/wetlands, sensitive crops, gardens, landscaped vegetation, protected vegetation or protected animal habitats.
Those downwind distances vary depending on the 2,4-D product being sprayed, along with surface wind speed and the spraying method (boom
spraying and kept for 2 years, with details of:
- Spray start and finish times
- Location (including address and specific paddocks)
- Product name
- Spray rate and the number of hectares sprayed
- The situation, crop or commodity sprayed
- Wind speed and direction during spraying
- Air temperature and relative humidity while spraying
- The nozzle brand, model, size, type, and spray system pressure used
- Height of the spray boom from the ground (it would be sensible to record crop height too)
- The name and contact details of the person applying the chemical
- Plus any other details that need to be recorded under local or state laws
On balance, it seems like the record-keeping might be more work than the actual spraying!
Still, a best-practice approach could be to create and maintain a log of all these required details on every spray job… The information can be useful – and who knows when the same regime might be applied to other chemicals as well?
Not worth the risk
It all seems more sensible than risking the penalties for breaching the new Permit – up to $189,000 for an individual and up to $319,000 for a body corporate. And that’s for each contravention, so a fool-proof system of compliance is a good investment.
Then there’s the almost-inevitable legal and financial costs of wiping out someone’s valuable crop – not to mention damaging neighbourly and community relationships.
On the land, that could prove the greatest cost of all. Which is why stopping 2,4-D drift is more than just a new set of regulations… It’s also a good idea.