Have you heard of the term PULA yet? If not and you apply pesticides on your farm, now is the time to get up to speed on pesticide use limitation areas (PULAs).
This topic was covered during the Florida Citrus Growers’ Institute, held at South Florida College in Avon Park in April. Matt Smith, University of Florida Institute of Food and Agricultural Sciences Extension commercial crop production and food systems agent, spoke about new regulations related to the Endangered Species Act (ESA) and the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA).
The new rules were triggered by lawsuits against the Environmental Protection Agency (EPA) in the early 2000s that alleged the agency was not taking the ESA into account when registering and labeling pesticides under FIFRA. EPA lost those lawsuits and was forced to come up with a solution, which is now being rolled out.
Smith told the Institute attendees the regulations were a long time coming. We all know the common refrain, “The label is the law.” What you may not know is that these new rules are now part of the label.
WHAT IS THE REGULATION?
Smith laid out some major concepts growers need to get acquainted with right away. These new rules apply to herbicides and insecticides. Fungicide regulations will be coming soon.
After these rulings, the EPA said that based on the way it currently does things, by 2030 it could only revise 5% of labels into compliance. The courts deemed that unacceptable and told the EPA to find a way to make it work. These new rules are how the EPA has responded.
“So, we are going to be hearing a lot about PULAs,” said Smith. “These are areas where those endangered species or their habitats have been identified. If you are spraying in these PULAs, you will need to be aware of the additional regulatory steps you need to take to be in compliance with the law.”
Pesticide labels will have new ESA language on them, either when they are first registered or when they are being reviewed for re-registration. Now, part of the label will be online, in addition to the paper document applicators are accustomed to using.
Smith said the paper label will have a section on Endangered Species Information. It is often in the proximity of the Environmental Hazards section. It will instruct you whether you need to visit the Bulletins Live! Two website for more information.
“If you are in a PULA or there are some further regulations related to that product, the website will give instructions on what you need to do,” he said. “And you will print that bulletin for your records to show you are in compliance with regulations.”
This record can be printed six months in advance of a pesticide application. Smith recommended taking action in advance because the regulations can change at any time.
“When you go online and check the label, you will need to enter your farm location and the month you expect to apply the material,” Smith said. “If you have a good sense of when you typically spray certain materials, you can print out the documentation six months in advance. You want to do that since these rules can change online. So, if you print it out for a spray in October six months in advance, and in September EPA changes something, you don’t have to worry about it for your October application. That’s because you’ve printed for your records the document before the change was made. The next time you apply the material you probably will have to abide by the changes.”
The Bulletins Live! Two website also provides a map where you can determine if your field or farm is located in a PULA. How much citrus land will be covered by this? Smith said most of the Central Ridge of Florida is in a PULA.
MITIGATION POINTS
Another concept that will be rolled out with these rules is mitigation points. To apply certain insecticides, growers will need to score their farm. These points will dictate if a pesticide can be applied. Smith said this can apply whether the farm is in a PULA or not.
“The points focus primarily on drift and erosion control,” Smith said. “This helps us a lot here in Florida. None of these regulations have anything to do with leaching, so our sandy soils will not affect us. In some ways, it will help us out. These are points you earn for either the structure of your farm or the practices you already have in place.”
The EPA website will walk you through how to score the field or farm. Things like buffer strips and level field terrain will give you points.
“It is not particularly hard to get mitigation points in Florida,” Smith said. “It is pretty hard to get less than 12 points on a typical Florida citrus farm. And right now, nine points is what is required to be able to apply the pesticide.”
The critical point Smith emphasized is that this is now law and part of labels for key insecticides and herbicides being applied on all farms, not just citrus. There will be multiple training sessions hosted in the coming months. Smith encouraged growers and applicators to take advantage of those learning opportunities.
Hear more from Smith on this topic in episode 92 of the All In For Citrus podcast.
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