Dicamba Over-the-top Use in Cotton and Soybeans Update
May 8-9, 2019 Pesticide Program Dialogue Committee Meeting
Background:
	Registrations of dicamba for over-the-top (OTT) use on dicamba-tolerant (DT) varieties of
cotton and soybeans are available for the 2019 growing season.
	As compared to the 2018 season, the labels have been updated with new regulatory
requirements and strengthened user access and training requirements.
	In the past, the states and EPA received many incident complaints citing crop injury from the
off-field movement.
	Extensive data-sharing and dialogue with the pesticide manufacturers, farmers, state
regulators, and other stakeholders informed EPA's recent decision.
	Dicamba OTT uses help growers protect cotton and soybean crops from Palmer amaranth,
waterhemp, and other weeds that can be very difficult to control.
EPA Regulatory Actions for the 2019 Growing Season:
	In October 2018, EPA extended the registration for OTT use of dicamba in cotton and
soybeans for two years. The registration requires label modifications that add protective
measures to further minimize the potential for off-site plant damage.
	EPA has evaluated this use in the context of the Endangered Species Protection Act and users
must adopt any location-specific requirements.
Details of Use Requirements for the New Labels:
	Only certified applicators may apply dicamba over the top. (Those working under the
supervision of a certified applicator may no longer make applications.)
	Over-the-top application of dicamba on soybeans 45 days after planting and cotton 60 days
after planting is prohibited.
	For cotton, EPA reduced the number of over-the-top applications allowed from four to two
(soybeans remain at two over-the-top applications).
	Application will be allowed only from one hour after sunrise to two hours before sunset.
	In counties where endangered species protections are needed, users must observe an
omnidirectional buffer zone. The information and limitations are communicated via the
Bulletins Live system available on EPA's web site.
	The tank clean-out instructions have been strengthened.
	The labels added information and discussion about the importance of managing against low
pH of the spray mixture to protect against potential volatility of dicamba.
	Labels have been cleaned up and made more consistent to improve compliance and
enforceability
Next Steps:

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	EPA is continuing to collect input from partners and experts, such as state regulatory
authorities, grower groups, specialty crop growers, industry, non-government organizations,
and other affected stakeholders on this important use. The registrants are generating new data
on dicamba including special studies on sensitive soybean plants and woody plant species.
The deadline for receipt of the new required studies is January 2020. The registrants are also
required to provide expanded monitoring and incident data they receive.
	The registration for all dicamba products registered for over-the-top use on genetically
engineered cotton and soybeans will expire on Dec. 20, 2020, unless EPA acts to extend it.

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