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Commercial Fruit and Vegetable Growers

Let your voice be heard! Public comment period on proposed rate changes to chlorothalonil

Cab tractor spraying in peach orchard

The active ingredient chlorothalonil (e.g. Bravo, Daconil) is undergoing the registration review process, and the public comment period is now open through January 17 for the EPA’s Chlorothalonil, Proposed Interim Registration Review Decision, Case Number 0097, September 2023 (click the link to download). This is a long read (108 pages) but well worth your time because there are some significant proposed rate changes to several crops. After reading through all the supporting information for which the proposed decision was based, the proposed changes to the label begin on page 77. For example, the max annual rate (lbai/A) for peach is currently 15.4 lbai/A, with a proposed reduction to 6.5 lbai/A if you are on sandy or coarse-textured soils (i.e. vulnerable soils); 12.4 lbai/A if you are on non-vulnerable soils. What this means for peach growers is, trees on non-vulnerable soils will be allowed roughly one less spray per year and those on vulnerable soils will have 3 less sprays.

The proposed label changes also include an emphasis on the protection of Endangered Species. Current chlorothalonil labels mention endangered species under “Sensitive Areas.” The proposed label change includes a new heading at the beginning of the Directions for Use entitled “ENDANGERED AND THREATENED SPECIES PROTECTION REQUIREMENTS.” Though the final rule on how the EPA will better comply with the Endangered Species Act has not been released, this is the first real tangible evidence through the proposed label changes that growers at the very least may be required to access an Endangered Species Protection Bulletin within six months prior to or on the day of application to ensure the application is allowed or if special restrictions/considerations are required. Again, this is just a proposed change, but I have accessed the Bulletins Live! Two (BLT) website and it is fairly straightforward and easy to use.  One comment I would make if this becomes an across the board requirement, some operations may need to develop a method for always having an up-to-date bulletin for every product and location, so stayed tuned for any updates on EPA compliance with the Endangered Species Act.

For the proposed changes to the chlorothalonil label, you can submit your comments, identified by the appropriate docket ID number through this link to the Federal Register. Click the green highlighted “Submit a Formal Comment,” then select “EPA Chlorothalonil Registration Review EPA-HQ-OPP-2011-0840.” Comments must be received by January 17.

Photo credit: E. Wahle, Illinois Extension 2023