EPA steps into the Spray Business ???

[ECIN]

I VERY good read from the Indiana Prairie Farmer ! 

I figured that something like this would happen --- sooner or later - They ( EPA ) do'e have some good points in this - yet - some are asking a lot to do - One thing that jumped out was the 10 mph rule - Here - in Indiana - that will be a hard to to do - I try to spray at lower wind mph - but I do have a few farm's that I can cheat - a little on -

Another thing - was the cost factor ! 50 nozzles at 10 apeice = $500  ? Mine takes 73 across -even at 73 , that equals $ 730 -  A good guess is that as of today - I probably have close to 8 to 9 thousand in nozzles for my sprayer - I didn't buy these all at one time - over the years - it was what I needed for the app I was applying , Yet around here - I see that most farmers with there own rig's have ???? Maybe 2 sets -  You just can't make that work most times - this is where poor weed control - drift , come from - then it affect's us all - all in the name of cost savings - Ken Say's B. S. ! I have my commercial license - and we are held to a higher standard - yet !!!!   There are area farmers running the same type equipment as I OR - bigger and better - running on a - what they call here - a privite license = for farmers . What give's ??? With todays farmimg and equipment - And yes - I will P.O some - but everybody should be held to the same standard !! IF you can afford a 300 -- 500 hundred thousand dollar sprayer - then 730 dollars for the RIGHT type nozzles is just pennies in the big picture .

You guys and gals know what promotes these kind of actions in the first plae don't yeah ? One of 2  things - JUST one guy that miss applyies OR a guy that needs to prove he really needs his job there - lol

Anyway - Have a great day !

Proposed EPA changes to sulfonylurea labels to force sprayer nozzle upgrades
Will these proposed sulfonylurea label changes force too costly sprayer changes? EPA extends comment period to gather testimony.
Published on: Nov 10, 2016

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EPA has extended the comment period until Nov. 14 on a proposed label change for sulfonylurea herbicides currently used on millions of U.S. crop acres. The label changes proposed by the agency could impact how and if you use any product containing the active ingredient, notes Richard Gupton, senior vice president of the Agricultural Retailers Association.
That would cover a long list of herbicides and premixes including Accent, Basis, Classic, Canopy, Finesse, Harmony Steadfast, Synchrony and many more. Using the most conservative models and endpoints to predict exposures of concern, EPA has determined that risks to non-target plants warrant additional label restrictions when products are applied either by ground or air, says Gupton.

GOT A COARSE-SPRAY NOZZLE? Proposed EPA label change would require it for applying any herbicide containing sulfonylurea.
Label restrictions under consideration
To protect against that predicted potential damage, EPA proposes that labels require:
• All applications of products containing a sulfonylurea must be made using equipment delivering an extremely coarse droplet size.
• All applications would be prohibited when site wind speeds exceed 10 miles per hour.
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• When making aerial applications, maximum boom lengths, swath displacement and nozzle orientation must be defined and mandatory.
• In ground spraying, distance between the spray nozzle and the ground or crop canopy would be restricted to no more than 2 feet.
• Tankmixes with different mode-of-action and herbicides such as glyphosate would be prohibited if the extremely coarse droplet size is required as these applications generally require small droplet size to be efficacious.
To comply with the law, many weed control claims would need to be taken off product labels until new supporting data could be developed. Most SU herbicides are also applied in tank mixtures with different mode-of-action and herbicides such as glyphosate. 
The take-home message
While the agricultural industry generally supports for spray drift advisory language, placing specific restrictions on equipment types, configurations and operating parameters may discourage applicators from investing in newer technologies designed to better manage drift, contends Gupton. “The investment required to continue to apply sulfonylureas appears to have been overlooked.”
EPA requires that all performance claims on a label be supported by data. However, little if any performance data exists when products are applied in extremely coarse droplets. Requiring extremely coarse spray droplets may, in effect, remove some SU products from the marketplace.
Then there’s the conversion cost to ultra-coarse droplet nozzles. ARA suggests the cost could be in excess of $2 million for the commercial applicator industry of about 4,000 rigs. That’s putting the cost at $10 per nozzle x 50 nozzles, or $500 per applicator. That does not include farm-owned applicators.
EPA also proposes that labels instruct users to scout for resistant weeds before and after an application, and report any lack of performance. Labels would also be required to list confirmed resistant weeds and provide separate use-rate instructions for treating them. 
ARA asks that you take the time to submit your concerns and comments to the EPA. To add to the confusion, EPA has established a different Public Docket for each of the 22 sulfonylureas currently registered for use. The complete proposed interim decision may be found in any of the dockets. Comments applicable to any sulfonylurea may be submitted to any one of the dockets.
For more details on filing comments, click the link below to log in and send your message: votervoice.net/BroadcastLinks/Ifza7ubyM7b6GrvzQ9sSeQ

[JimMeade]

How do you measure the 10mph?  Where do you get your data?

[ECIN]

The Indiana State Chemist office - will take info from the closest reporting station Jim - For me that's Shelbyville Airport - ( KGEZ ) -  14 mies SW of us .

I have there automated weather - TX number in my phone and call it to check the weather - I then write down the wind speed and degree's on my paper work for that job - if there's a question - like it's getting windy - I may make 2 or 3 calls - That way - I'm covered IF I was to get reported OR somebody else has a problem , I like to cover my rear - lol    - my numbers  must match Shelbyville  

[sw363535]

Next question on 10mph is at what elevation?

[ECIN]

It's reported at ground level for ground rigs and 10 feet up for High clearence machines - lol

Good question though - May have to call KGEZ and ask them -