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4 Suggestions for Improving 2019 Dicamba Label

Illinois industry and government officials made the following four suggestions for 2019 label changes regarding dicamba on dicamba-tolerant soybeans.  

Reports of off-target dicamba decreased in some states in 2018. In Illinois, though, they increased in 2018. The Illinois Department of Agriculture has so far recorded 330 dicamba complaints in 2018. That’s up from 246 in 2017. With no temperature and/or date cutoffs, complaints continued to come in through July and August, says Jean Payne, president of the Illinois Fertilizer and Chemical Association (IFCA).

With that in mind, the IFCA hosted a meeting last August that included: 

  • IFCA Board Members (all of whom are retailers who custom-apply dicamba to soybeans)
  • Illinois Department of Ag (IDA Bureau of Environmental Programs)
  • Representatives from the state’s largest farm organization
  • A University of Illinois weed science Extension representative

The group made the following four suggestions for 2019 label changes regarding dicamba on dicamba-tolerant soybeans.  

1. Add an additional record-keeping requirement to the label to follow the “Sensitive Crop Awareness” record-keeping requirement. Prior to application, an applicator needs to obtain a signed document from the grower identifying the trait of any soybean crop planted adjacent to the field (next to, but not necessarily touching) on any side of the field intended for postemergence application.

Explanation: It’s been difficult for applicators to determine where sensitive soybeans are during a hectic application season. The Illinois group notes this places an additional requirement on the applicator. However, the applicator can also take a firm stand well ahead of the season that they need this document in order to perform a custom application.

2. Under the “Sensitive Crops” section of the label, revise the current “Do Not Apply.…” to read: DO NOT APPLY if there is a sensitive crop adjacent to (next to, but not necessarily touching) on any side of the field.

Explanation: In 2017 and 2018, most commercial applicators noted symptoms in sensitive soybeans regardless of the wind speed direction at the time of application. The debate continues as to the cause. Still, it’s certain that symptomology in sensitive soybeans—whether upwind, downwind, or crosswind at the time of application – does occur.

Given the necessity to coexist with sensitive soybeans, and the fact that the most complaints registered with IDA are from farmers with symptoms in their sensitive soybeans, the Illinois group believes the “do not apply” restriction needs to apply to more than just downwind sensitive crops. It needs to apply for all adjacent sensitive crops. 

The Illinois group has also attempted to define “adjacent” for the reader of the label. This label change coincides with the requirement that the applicator obtain from the grower the trait of all soybeans adjacent to the intended application field. This way, the applicator can make a clearer determination of when to apply, following all the other label requirements. 

Shifting winds that occur during application are frequent in Illinois, making compliance with the current “downwind” do-not-spray requirement nearly impossible to manage effectively. Farmers who understand this requirement well ahead of planting season can also strategically plant Xtend soybeans in areas where they know that dicamba application will be more likely, or choose to rotate their crop to corn to avoid being adjacent to sensitive soybeans in 2019 and in years to come.

3. Under the “DT Soybean Restrictions” it should state: DO NOT APPLY this product after V6 growth stage (soybean plants are 12 to 14 inches tall).

Explanation: It is the experience of the Illinois applicators that R1 and R2 (flowering) are often difficult for both growers and applicators to determine. A V6 stage is more easily identifiable and also moves dicamba application earlier in the season. Early application and not applying near sensitive soybeans were the top two conditions that Illinois applicators noted that led to a successful soybean dicamba application.

4. Under the “DT Soybean Restrictions” it should state: DO NOT APPLY after June 30 of each calendar year.

Explanation: This cutoff date will assist the industry and the IDA in taking an enforcement stance that beyond this date – no matter what the circumstances – dicamba application is no longer feasible. This is based on the application industry’s decades-long experience with dicamba and its propensity under later applications to react undesirably and impact sensitive crops.

Late application is also counterproductive to effective weed resistance management. This date takes into consideration the possibility of weather delays in Illinois that could impact planting or growth of the soybean. States may need some flexibility in setting a cutoff date depending on geography and soybean planting dates, but not applying much beyond the summer solstice can be a reasonable guideline.

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