Dicamba: Importance of accurate recordkeeping

Federal labels approved by the U.S. Environmental Protection Agency (EPA) in 2018 stated that applicators must keep a list of records for a period of two years, the records must be generated within 72 hours after application and a record must be kept for every individual application.

The list of required records is included on each label, such as:

  • Full name of the certified applicator;
  • Certification number of the certified applicator;
  • Product name;
  • EPA registration number;
  • Total amount applied;
  • Application month, day and year;
  • Crop planting date;
  • Start and finish times;
  • Location of the application;
  • Crop or site receiving the application, and more.

If a misuse investigation is done by Illinois Department of Agriculture (IDOA) staff, they will ask to review the records that are to be kept pursuant to the federal label.

Many record deficiencies found in 2019 investigations involved situations where blanks or omissions were found in the recordkeeping sheets or otherwise incomplete data was furnished upon request of IDOA staff.

Therefore, applicators are urged to address every required record – do not neglect to keep a record or leave it blank. Prioritizing recordkeeping – documenting information while it is still fresh – can help ensure each record is addressed.

IDOA has advised that, prior to application, an applicator take time to review the recordkeeping requirements and develop a plan to address each of them. Registrants each have sample forms that can be used for assistance in recordkeeping.

Here are a few examples:

  • On the subject of buffers, if the applicator can show that buffers were in fact considered, they will be given credit in a record review.
  • If a dedicated tank system was used for system cleanout purposes, that should be stated in the records.
  • Finally, all proof of weather data should be included in the records.

This story was provided by FarmWeekNow.com.