NCDA&CS will again submit 24(c) labeling for all products containing 2,4-D or dicamba intended to be used postemergnce in conjuction with 2,4-D or dicamba tolerant crops (cotton and soybeans). The 24(c) label will require specific mandatory training for all applicators of these products, even applicators who attended training in 2017. Specific restrictions will also include wind speed restrictions not to exceed 10 mph and additional NC sensitive crops which could be injured unless care is taken when applying dicamba or 2, 4-D in their vicinity.
The dicamba products (Xtendimax, Fexapan, and Engenia) will all be classified as Federal Restricted Use Pesticides. Of course, they can only be sold by Licensed Pesticide Dealers and purchased only by licensed/certified (commercial and private) applicators. These products will also require extensive record keeping for each application (see below for further details).
This mandatory training titled Auxin Herbicides - Best Management Practices, presented by Dr. Alan York, Dr. David Jordan, or other Cooperative Extension Specialists, is intended to assist applicators in reducing incidents of herbicide drift to susceptible crops. Again, each applicator will need to complete the training prior to use of these products.
Applicators and dealers will receive 1.5 hours of pesticde recertification credit in categories N, O, D, and X upon completion.
When using these products, applicators must have in their possession a copy of the 24(c) labeling for the product being applied. Applicators are responsible for obtaining all necessary labeling and for adhering to all of the directions, restrictions, and precautions found on the labeling
Auxin Record Keeping Requirements
The dicamba labels require extensive record keeping, including all USDA Record Keeping components as required by 7 CFR Part 110, plus many more elements. USDA Record Keeping rules only require the location of the treated area – so NCDA&CS has clarified on the 24(c) labels that a separate record must be written for each “field” to include the wind speed, wind direction, temperature, consultation of a sensitive crop registry or properly document surveying neighboring fields for any susceptible crops prior to application, and other elements listed below. The registrant training for the dicamba products states that if you spray 10 fields – you should have 10 records. So, NCDA&CS’s 24(c) language clarifies that point. NCDA&CS’s 24(c) labels also require that the application records must be completed within 72 hours and add the requirement that each applicator be listed on the record. A full list of record keeping elements include:
Enlist Products Containing 2,4-D Choline
The Enlist Duo and Enlist One product labels do not require record keeping, but we do suggest that accurate records of those applications be made as well. The Enlist Product Use Guide contains record keeping requirements that should be followed to maintain compliance with the purchase agreements.
Auxin 24(c) Labels (click image to view)
For additional resources and compliance assistance please contact the Structural Pest Control and Pesticides Division at (919) 733-3556 or at http://www.ncagr.gov/spcap/pesticides