In October 2020, the Environmental Protection Agency put in place new restrictions on the use of dicamba to help reduce potential drift and incidents of the herbicide used more widely to manage herbicide-resistant weed populations. New data released by the EPA on December 21 reveals that reports of dicamba incidents from 2021 show little change in the number, severity or geographic extent of dicamba incidents compared to reports that the agency received before the 2020 controls were required.

Will the EPA make any changes to the registration and application requirements for dicamba? This report brings together information on what this could mean for farmers and industry.

Based on new information from the 2021 growing season, the EPA says it is examining whether excess dicamba can be used in a way that does not pose unreasonable risks to crops and other non-target plants, or to listed species and their designated species. critical habitats. The EPA is also evaluating all of its options for dealing with future dicamba-related incidents.

In 2020, the EPA compared incidents reported to the EPA to incidents reported in the USDA’s 2018 Soybean Agricultural Resource Management Surveys and estimated that approximately one incident is reported to the EPA per 25 incidents reported to USDA.

Additionally, a survey of Midwestern specialty crop growers found that 45% of those surveyed had crops affected by some level of herbicide drift in 2020. However, the survey indicated that only 6% of growers reported incidents when herbicide damage was detected in 2019 and 2020. Respondents did not distinguish herbicide damage, but reported dicamba, 2,4-D or glyphosate as the most common herbicide. likely to cause damage.

Nationally, about three-quarters of the cotton area and about two-thirds of the soybean area is planted with dicamba tolerant (DT) seed. Based on market research data and aggregate sales data, approximately half of DT cotton and DT soybeans were treated one or more times with an over-the-top (OTT) dicamba product (OTT) in 2020 (the 2021 data is not yet available).

Based on data from the 2020 Pesticide Use Survey, misuse of unregistered dicamba products for overuse may have occurred on a small percentage of DT soybean and cotton acres, note the EPA report.

In 2021, the EPA continued to receive reports of off-target movement of dicamba. EPA has received nearly 3,500 reports alleging the effects of off-target movement of dicamba on various non-target vegetation, including cotton and soybean varieties that are not tolerant to dicamba, ornamentals, other crops. (sugar beet, rice, sweet potato, peanuts, grapes, cucurbits, vegetables, cranberry fruit trees) and natural spaces. Food crop incidents have reportedly occurred in Arkansas, Illinois, Kansas, Missouri, North Dakota, Nebraska, Ohio, South Dakota, Tennessee and Texas. Incidents have also been reported in uncultivated areas of Arkansas, such as state parks and wildlife refuges.

Underreported dicamba incidents?

The EPA expects dicamba OTT incidents to continue to be “under-observed and under-reported,” according to its latest report. The number of reported incidents varies by state. The EPA has received few reports of incidents from states such as Georgia, Louisiana, and Mississippi, where dicamba OTT is widely used.

In other states, such as Arkansas, Illinois and Minnesota, the reported incidents are numerous and widespread. “The reported effects vary in severity and include damage to the landscape and reductions in crop quality and yield,” the EPA said. Additionally, reports indicate that some growers’ crops (or uncultivated land) suffered several years of exposure to dicamba and subsequent damage.

According to some stakeholders, off-target movement can occur even with full compliance with the labeling parameters of OTT dicamba products. “Officials in many states postulate that secondary movement, or volatility, is the cause of the majority of off-target incidents. Additionally, while a small number of reported dicamba-type incidents may be the result of environmental stress or exposure to other pesticides, the agency considers the preponderance of incidents to be the result of exposure to dicamba, ”the EPA report says.

Clarity of EPA data questioned

However, in a joint statement from producer groups, including the American Soybean Association, the National Cotton Council and the American Farm Bureau Federation, they raise questions about the data included in the report and expressed concerns about the potential for significant gaps in the data provided.

Producer groups note that it is not clear whether complaints were submitted to multiple sources / regulators and therefore were double-counted. Additionally, it is not clear whether the EPA, state regulators, or others have investigated the complaints to verify injuries or assess potential causes.

“It’s about published information that provides an incomplete picture. Data that is not in this EPA release may tell as much or more about the story than what the agency included, ”says Alan Meadows, a soybean grower from Halls, Tennessee, and director of the ASA.

NCC President Kent Fountain, a Georgian cotton producer, adds: “The EPA report does not match what the US cotton industry has seen and heard on the ground. Data must be carefully analyzed to ensure accuracy, as dicamba is too important to our industry to make decisions on incomplete or erroneous data.

AFBF President Zippy Duvall says decisions made by the EPA on herbicides have far-reaching consequences for American farmers and ranchers. “The stakes are simply too high to make major label changes without due diligence on the part of the EPA to know all of the facts surrounding the reported incidents. American farmers deserve a fair process as they strive to use climate-smart practices to produce food, fuel and fiber for our country, ”said Duvall.

Persistent dicamba problems

Given the widespread use of dicamba-based herbicides on soybeans and cotton in the United States, the EPA expects more cases of dicamba resistance to be confirmed and dicamba resistance in Problematic broadleaf weeds like Palmer’s pigweed and water hemp continue to spread.

As some registrants report growers are making a second application of dicamba to remedy the initial failure, the EPA is concerned that growers are not implementing strong herbicide resistance management plans. , specifically using two effective modes of action.

“Therefore, the agency questions whether or not the registrants are implementing effective herbicide resistance management plans (for example, providing sufficient recommendations that encourage the use of a method of different action or other method of control following dicamba failure) as required by the terms and conditions, ”says the EPA.

Producers who currently use an OTT dicamba system for cotton and soybeans could upgrade to the OTT 2,4-D system. However, in the short term, growers may not be able to acquire seeds tolerant to 2,4-D and the OTT 2,4-D herbicide as an alternative to the dicamba system. Seedmakers may not have time to plant, grow, and distribute 2,4-D tolerant seed for the 2022 cotton and soybean growing seasons, and chemical manufacturers may not have time to. produce and distribute sufficient OTT 2,4-D herbicide. Producers who are unable to acquire OTT 2,4-D due to supply constraints will likely face increased control costs and may experience yield losses due to less effective control of bad ones. problematic broadleaf grasses.

The 2021 incident summary showed 3,461 incidents and over one million acres of soybeans affected as of November 17, 2021.

Incidents have been reported in 29 of 34 states where the use of dicamba on DT crops is permitted. There were nine states that had more than 100 incidents (Arkansas, Illinois, Indiana, Iowa, Kansas, Minnesota, Missouri, Nebraska, and South Dakota); six states that had more than 10 but less than 100 incidents (Kentucky, North Dakota, Ohio, Tennessee, Texas, Wisconsin); 14 states with less than 10 incidents (Delaware, Florida, Georgia, Louisiana, Maryland, Michigan, Mississippi, New Jersey, New York, North and South Carolina, Oklahoma, Pennsylvania, Virginia); and five states that have not had any incidents or have not reported to the agency (Alabama, Arizona, West Virginia, New Mexico and Colorado). There is a disagreement between state regulators that see this technology causing widespread damage at the landscape level versus states that have few incidents and wish to preserve, and potentially expand, the use of dicamba OTT, the report adds. .

To view the report and supporting documents, visit file EPA-HQ-OPP-2020-0492 at