February 2009
Written plan is key to dealing with neighbors, agencies

The influx of residential developments into predominantly agricultural areas can create friction between growers and their new neighbors. It’s a problem that has long been occurring in California, but is becoming more common even in more rural states.

The chip-producing area around Hastings, Fla., has seen acreage disappear as more houses pop up. In 2007, a group of students tested the air around a local elementary school, and the results prompted the students to call the Pesticide Action Network North America (PANNA), which released the results of its own air quality study in September. The group, which is opposed to the use of pesticides, found endosulfan, diazinon, trifluralin and chlorothalonil in the air and is calling for the area’s farmers to use organic methods, mandatory notification of pesticide use and pesticide-free zones” around schools and other sensitive sites.

The report indicates that the most likely cause of the chemicals in the samples was from volatilization into the air from evaporation although three spikes that corresponded to applications on nearby fields did indicate drift.

Michigan also has seen more residents complaining about chemical applications, said Jeff Zimmer, pesticide and plant pest regional supervisor for the Michigan Department of Agriculture (MDA). Zimmer spoke about the state’s role in investigating drift issues to a group of potato and vegetable growers at the Great Lakes Fruit, Vegetable and Farm Market EXPO in Grand Rapids, Mich., in December.

“We seem to have increasing concern in the potato growing regions near Grand Rapids,” Zimmer said.

In 2007, 34 of 178 MDA investigations (19 percent) were for drift complaints. That’s in line with previous years, with drift complaints making up 18 percent of MDA investigations in 2006 and 23 percent in 2005.

But the state doesn’t investigate every complaint that a resident calls in there has to be some evidence, Zimmer said. The agency receives many calls about odors, noise and airplane flyovers, but those issues usually don’t warrant an investigation. The first question the agency will ask is if the individual saw a droplet. If the answer is no, then they go no further. If there’s a medical or veterinary concern, the agency will ask for evidence from a doctor or veterinarian before proceeding, Zimmer said.

“MDA does know how hard it is to farm, to apply pesticides and keep them on your property, especially if you’re hiring an aerial applicator for your potatoes,” Zimmer said.

In order to manage the responsibilities under Michigan Regulation 637 or any other state’s guidelines on drift Zimmer said a draft management plan would meet the state’s requirements for notification and minimizing drift, and while it’s not required for every application it is a good practice that may be required in the future as more states push for mandatory plans on the label registration. The purpose of a drift management plan is to minimize the occurrence of off-target drift and reduce the adverse affects. A plan is required when off-target drift is likely due to the nature of the product being applied or conducive weather conditions, Zimmer said.

The plan must be in writing and list in detail the precautions being taken on the farm, including a description of how those measures will reduce drift. The plan is annually reviewed by applicators, and a record should be kept of when and where the plan was implemented. Those records should be kept for one year for general use pesticides and three years for restricted use pesticides.

“We access those records in case we do have a complaint,” Zimmer said.

The first component of a drift management plan is the informed consent of the residents who could be affected by an application. This can be written or verbal notification that will include the timing and application, as well as the contact information for the farm. Another benefit to notifying neighbors is the chance to educate residents who might not know how important the chemical applications are. Communicating with neighbors goes a long way toward alleviating some of the concerns and complaints that might otherwise be reported to the state, Zimmer said.

The second part to a drift management plan is the farm’s minimization practices. This portion includes a record of the equipment being used, how the applicator is managing droplet size, what additives and buffer zones are being used, the wind speed and direction and the use of wind shields or wind breaks.

Having a drift management plan doesn’t exempt a grower from complying with regulations, especially label requirements, but having a plan can be taken into account when MDA considers enforcement actions, Zimmer said. The Michigan potato growers who had complaints investigated and then developed a drift management plan haven’t had further complaints filed, which shows that there is a benefit even if it’s not required.

The Environmental Protection Agency is expected to focus on drift mitigation measures in 2009, including greater emphasis on buffer zones, sensitive sites and mitigating practices. If label requirements don’t include drift management plans in the near future, Zimmer said, then EPA may require them from growers.”



75 Applewood Dr. Ste. A
P.O. Box 128
Sparta, MI 49345

616.520.2137

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