In reading through this draft PR Notice it appears the only thing being accomplished is creating busy work for registrants -this notice only add words to labels. There is no meaning to the words or any feasible way at this time to accomplish what is being told to the consumer. Pesticide labels are so long and convoluted already that people do their best to AVOID READING them. After drift reduction technologies have been researched and there are viable ways to accomplish drift reduction then the language would make more sense. There is a lot of work being done at this time to develop appropriate and quantifiable testing methods for drift reduction tank mix products but until a method is approved there is no point in moving forward with label language changes. Based on the overall number of pesticide applications each year the amount of spray drift issues that arise happens in less than 1% of the total applications; I am not saying we shouldn't work to keep reducing that number just saying it has to be done correctly or you end up with more confusion in the application process and probably more errors being made. PLEASE continue to work with industry and academia as some of the writings in this docket suggest and get things done the right way.
Comment submitted by Scott Baker, Lighthouse Product Services
This is comment on Notice
Pesticides; Draft Guidance for Pesticide Registrants on Pesticide Drift Labeling
View Comment
Related Comments
View AllPublic Submission Posted: 11/12/2009 ID: EPA-HQ-OPP-2009-0628-0005
Jan 04,2010 11:59 PM ET
Public Submission Posted: 11/12/2009 ID: EPA-HQ-OPP-2009-0628-0006
Jan 04,2010 11:59 PM ET
Public Submission Posted: 11/13/2009 ID: EPA-HQ-OPP-2009-0628-0007
Jan 04,2010 11:59 PM ET
Public Submission Posted: 11/13/2009 ID: EPA-HQ-OPP-2009-0628-0009
Jan 04,2010 11:59 PM ET
Public Submission Posted: 11/16/2009 ID: EPA-HQ-OPP-2009-0628-0010
Jan 04,2010 11:59 PM ET