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ARA Sends Letter to EPA on Label Decision for Dicamba

Aug 24 2018

ARA sends a letter to Acting Administrator Wheeler of the U.S. Environmental Protection Agency (EPA) on the 2019 label decision for dicamba products. Dicamba technology is an effective tool in dicamba-tolerant cropping systems with a good residual herbicide program. However, the number of damage claims and complaints over the last two years cannot be sustained. Claims need to be fully yet expediently investigated so the legitimate ones can be addressed and any frivolous ones dismissed. Off-target movement due to volatility or temperature inversions remain real concerns even when the product labels are followed to the letter. Continued research and innovation to minimize these risks must be pursued by product manufacturers. Our member companies are highly responsive to the label requirements and have trained their applicators extensively on how to follow the label and best steward these products. Even under the best conditions and perfect label compliance, off-target movement has occurred; manufacturers must seek further improvements to minimize these risks.

Should EPA feel additional label restrictions are necessary for 2019, we prefer those restrictions be based on crop growth stage (such as V stage The Honorable Andrew Wheeler August 24, 2018 Page 2 of 2 soybeans), weed size, temperature or other variables that are tied to the growing season rather than fixed calendar dates. No one growing season is like another – a set of calendar dates may be too early one year and too late the next.

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