By Matt Smith
Editor’s note: This article grants one continuing education unit (CEU) in the Core category toward the renewal of a Florida Department of Agriculture and Consumer Services (FDACS) restricted-use pesticide license when the accompanying test is submitted and approved.
People often wonder, what is the most timeless movie of all? I’ve heard several contenders. You probably have a few in mind yourself. For me, it’s Office Space. Office Space came out in 1999, nearly three decades ago, but office culture hasn’t changed a bit. While the outside world might think growers are immune to paperwork, anyone in a Basin Management Action Plan area knows no one is safe.
So why am I talking about Office Space in a CEU article? Well gang, while you weren’t looking, the pesticide label has gone digital, and with that comes — you guessed it — more paperwork. More importantly, this represents a significant change in how you plan spray operations and has the potential to reshape what products you can use. It’s a lot to take in. This article serves as an introduction to the changes, why they are happening and suggestions on how to incorporate them into your farm business.
Y2K AND THE ESA
The setting for Office Space is a software company that updates computer code in preparation for the year 2000 glitch. Since the dawn of the software era, many computers had used a two-digit system for the year with the assumption that the first two digits would be 19. When the year hit 2000, the computer would read the date as 00 and interpret it as 1900.
There’s a very good reason to do this. In old computer systems, you didn’t have a lot of memory and storage. Dropping to two digits saved a lot of space. Engineers warned about potential future problems, but for several reasons, management put those worries off until the late-1990s. By that point, there were decades of code written with this system, some by people who had long since retired. The problem grew so big that governments had to step in to assist the private sector, and billions of dollars were spent to correct the issue.
What does this have to do with changes to the pesticide label? Well, all these changes come down to multiple U.S. district courts finding that the Environmental Protection Agency (EPA) — which regulates pesticides — did not adequately integrate the requirements of the Endangered Species Act (ESA). The EPA regulates pesticides through a law called the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA). FIFRA does not supersede the ESA, and the EPA must take the ESA into account when approving pesticide registrations. Courts ruled that, over the decades, EPA had not adequately required pesticide manufacturers to add language to their labels to provide applicators with the necessary information to prevent pesticide exposure to endangered species or the habitats that endangered species rely on for survival.
This posed some interesting questions: Since endangered species protection is at times hyper-localized, would you need a different label for every zip code? How would labels deal with species that are only threatened at certain times of the year? Furthermore, how could this policy be rolled out effectively? The EPA calculated that by 2030, they’d only be able to bring 5% of labels into ESA compliance. The federal government wasn’t about to step in with billions of dollars and thousands of contracted workers like the Y2K situation, so EPA proposed a radical solution: The pesticide label was going online, and in more than one way.
A MULTI-STEP SANDWICH
The first way the pesticide label is going online is through a system called Bulletins Live! Two (BLT). To carry along the Office Space metaphor, these are the TPS reports. Here’s how it works:
Step 1: From now on, whenever you buy a pesticide, you need to read the label to see if it now contains language requiring the applicator to visit the Bulletins Live! Two website. There’s no rule about where this language is required to be, but it’s often found in the Environmental Hazards of Directions for Use section in a subsection titled “Endangered Species Protection Requirements.” If the label doesn’t have this language, you don’t need to go any further. However, the labels are constantly changing and being updated to contain this requirement if deemed necessary, so a pesticide you buy in March that doesn’t require visiting BLT may require it on the label you buy in October.
Step 2: If required, visit the Bulletins Live! Two website. Web addresses change, so alternatively just do a web search for Bulletins Live Two and you’ll find it. Bookmark this page.
Step 3: Enter the application site location, the month you expect to make the application (up to six months prior) and the EPA registration number of the product. You can enter multiple products at once but can only do one month at a time.
Step 4: Identify if the application site is in a pesticide use limitation area (PULA). PULAs are geographic regions which have been identified as hosting endangered species, either permanently or seasonally.
Step 5: If the application site is located in a PULA and a pesticide you entered has been identified as creating a risk to endangered species in that PULA during that application month, the website will list additional rules and directions for applying that pesticide. These directions are considered just as much a part of the label as the piece of paper that came attached to the pesticide container. So you must follow online instructions to remain in compliance with the pesticide label.
Step 6: Click “Printable Bulletin” to generate a report. Save this report for your records even if you aren’t in a PULA or have additional requirements for use. Having a record of regularly doing this earns you one mitigation point (We’ll get to that).
Step 7: Spray your pesticide according to all directions on the original label and the online label language.
Step 8: You’re allowed to print reports up to six months out. If pesticide application requirements change on the BLT website between the time you print the label and the time of application, you do not need to alter your spray plans. The label you printed months ago for that application month is what you use. This buffer period helps growers not be caught off guard by sudden changes to the online portion of the label. If you have products that you know you regularly spray in certain months throughout the year, generate those BLT printable bulletins as soon as you’re able to six months before the planned application.
WE NEED TO TALK ABOUT YOUR FLAIR
So, what if you’re not in a PULA? Well, you may not be out of the woods yet. Some pesticide labels now include printed runoff and erosion mitigation point requirements. If you remember, in Office Space Jennifer Anniston’s character needed 15 pieces of flair on her outfit to keep her job waiting tables at Chotskie’s. Well, there are already pesticides on the market that require a certain number of mitigation points to keep spraying that product.
To find out how many points your farm is eligible for, you must head to the EPA Mitigation Menu website. On this site, you’ll find three ways to calculate points: the Spray Drift and Runoff Mitigation Calculator (Excel spreadsheet), the Runoff Calculator Worksheet Sept. 2025 (PDF) and the PALM Tool (web-based). If you wish to apply products that require mitigation points, you need to calculate your farm’s points at least every year.
Some points you can acquire automatically based on factors like your county’s susceptibility to widespread runoff and your farm’s soil type and slope. Most of the interior Florida counties get an automatic three points. Predominantly sandy soils (HSG A type) get three points, while fields with moderately sandy soils (HSG B type) get two points. If your field has an overall slope of less than 3%, you get three points. While fields of this sort may be more likely to experience off-target pesticide movement via leeching, that’s not what the mitigation point system currently cares about. It cares about runoff potential.
Some points can be earned by enrolling in qualifying conservation programs. For example, you earn two points for being enrolled in the FDACS Best Management Practices Program.
You also get one point for having documented evidence of using the BLT system and generating BLT reports, even if you aren’t spraying any products that have additional BLT requirements. Note that some BLT requirements may include an increase in required mitigation points to use the product. In this case, the BLT website is Jennifer Anniston’s manager who insists on more than the bare minimum pieces of flair.
Other mitigation points can be earned by using on-farm practices that limit pesticide residue runoff. These include cover crops (more points if no-till and long-term), mulching, vegetated ditches or filter strips surrounding the farm, riparian forest buffers and water-retention systems. The mitigation menu website lists all qualifying mitigation practices as well as detailed definitions of each.
If you need to spray a product but do not have enough mitigation points, you will need to take the necessary steps to acquire enough. Once you do, document them by filling out a new mitigation point report using one of the mitigation calculators and save it in your records. Only then can you spray the product.
NO REASON TO SET THE BUILDING ON FIRE
These aren’t the only changes happening to pesticide labels. As time goes on, you’ll start to see more printed pesticide labels with a section on Ecological Spray Drift Buffers. There’s enough there for an article all by itself, but you can read more about it at the EPA Mitigation Menu website. Here, you’ll learn how much your application practices and application site will influence how much you can reduce the distance between where you’re spraying and neighboring property, especially if that property may contain endangered species habitats.
So where does this leave us? The hybrid print-digital pesticide label is a compromise, one that trades additional recordkeeping for being able to keep spraying more than 5% of pesticides. It also strengthens protections for vulnerable species and habitats, so in the future our kids can still go fishing and spot a manatee or go hiking and hear a scrub jay singing. It’s an additional hassle, yes, and you’re going to probably need to find someone with basic spreadsheet skills to track the mitigation points, but it’ll prove manageable enough.
Sources:
Matt Smith is a University of Florida Institute of Food and Agricultural Sciences Extension commercial crop production and food systems agent for Lake and Orange counties.
To request a hard copy of the article and test, or if you have questions regarding this article, test or CEUs, email Matt Smith at smith197@ufl.edu or call 352-343-4101 ext. 2729. Please allow two weeks to process your CEU request.
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