2019 FAQ for RUP Dicamba Herbicides (FeXapan™, Engenia® and XtendiMax®)

2019 FAQ for RUP Dicamba Herbicides (FeXapan™, Engenia® and XtendiMax®)

Where can I get more information about the additional label-required dicamba training, use, and record keeping requirements for these new RUP dicamba products?

  1. Pesticide Safety Education Program Office: 800-627-7216 (toll-free) or 402-472-1632 (Lincoln); RUP Dicamba Resources
  2. Nebraska Department of Agriculture: 800-831-0550 (toll-free) or 402-471-2351 (Lincoln); Dicamba Information for 2019
  3. Individual RUP dicamba chemical company (registrant) manufacturers. (See links listed below.)

What are the RUP dicamba products? Where can I learn more about them?

The RUP dicamba products are FeXapan™, Engenia®, and XtendiMax®. The registration by the EPA was renewed for the 2019 and 2020 growing seasons. Listed are links to the new labels, and tank mix and nozzle requirements when spraying these products:

  1. DuPont™ FeXapan™ herbicide Plus VaporGrip® Technology
  1. BASF Engenia® Herbicide
  1. Monsanto XtendiMax® with VaporGrip® Technology

If I was trained for RUP dicamba in 2018, do I need training in 2019?

Yes. Annual training is required for applying RUP dicamba products.

Must I be licensed as a pesticide applicator to buy and use these RUP dicamba products?

Yes. This is because they are Restricted Use Pesticides (RUP). Anyone buying or applying one of these three RUP products in Nebraska must be licensed as either a private applicator (for personal applications for crop production) or a commercial/noncommercial applicator (with the Ag Plant or Right-of-Way Category).

Do purchase and use of the RUP dicamba labels require extra training?

No to purchase. Yes to use. These are your training options:

Do all dicamba product labels require the additional training? You are required to have additional label-required dicamba training when applying the RUP dicamba products: FeXapan™, Engenia®, or XtendiMax®. The annual additional dicamba training is required for applying any of these three RUP dicamba formulations, whether to dicamba-tolerant soybeans or other crop sites listed on the labels.

How do I know I am approved for use (application) of these three new RUP dicamba herbicides after completing the additional label-required dicamba training? The Nebraska Department of Agriculture will list all applicators who complete a dicamba training in Nebraska on the following website: http://www.nda.nebraska.gov/pesticide/dicamba.html

What has changed on the three dicamba labels since 2018?

Several state requirements for RUP dicamba applications are stricter than those indicated on the product labels. The Nebraska requirements supersede the product label requirements and must be followed. (See more in the sections on Record Keeping and Wind Direction Change When Spraying.)

  1. Record Keeping: New labels allow 72 hours for all applicators to complete records; however, in Nebraska, commercial applicators must complete records in 48 hours. Labels require that records be kept for two years, but in Nebraska, they must be kept for three years. Chemical companies (registrants) may provide their own RUP record forms, but their components must include all items in the NDA RUP record form.
  2. Planting Date: Planting date must now be recorded and should be communicated to the person applying RUP dicamba. No applications can be made later than 45 days after planting or the R1 stage of the target crop, whichever occurs first. You may start by counting day 1 as the day after the field planting date.
  3. Wind Direction Change When Spraying: Applicators must stop the application if the wind changes during the application to blow toward sensitive crops/areas, but the labels do not require this to be recorded. However, if an application is delayed such that the remainder of the field must be sprayed at a later date, there must be separate records made for each date as if each part of the field is a separate field. (This is in the Nebraska state regulations, not the dicamba labels.)
  4. DriftWatch™: Applicators must record whether they consulted a sensitive crops registry and which registry. (In Nebraska use DriftWatch.) If no sensitive crops registry was consulted, applicators must survey the area around the target field and record any sensitive crops, sites, or residential areas1, when the survey occurred, and who conducted the survey.
    1Only the Engenia label requires protection and record keeping for “residential areas.”
  5. Sunrise/Sunset Restriction: Applications cannot be made earlier than one hour after sunrise, and no later than two hours before sunset. (View the official time for sunrise and sunset by location at https://www.esrl.noaa.gov/gmd/grad/solcalc/.)
  6. Endangered Species Language: The labels now have expanded language for applicators to protect endangered species habitat. To identify restrictions in your area, use the Bulletins Live! Two menu on the web at http://www.epa.gov/espp/. You must follow the measures contained in the endangered species bulletin for the area where you are applying the product. Consult this website or call 1-844-447-3813 no more than six months before application.
    Buffer: The bulletins require all applications of dicamba to labeled sites within the Endangered Species Protection Zones to maintain a 57-foot buffer around all borders of the field or target site. This is required whether or not the field is actually close to a known habitat for an endangered species.
    Location in Nebraska: As of December 2018, four areas of Nebraska had required endangered species protection listed. These included:
    — all of Lincoln County,
    — all of Custer County,
    — areas of northern Lancaster and southern Saunders counties, and
    — areas along the southern bow of the Platte River, including parts of Phelps, Kearney, and Buffalo counties.
  7. Bottom Line: NDA recommends checking the bulletins on the EPA website one month before planned applications. Even if there are no apparent endangered species nearby, all fields in the Endangered Species Protection Zone must adhere to the 57-foot setback on all sides of the field. The 57-foot buffer may be extended outside of the field border under certain circumstances.
  8. Minimum Sprayer Volume: All labels require a minimum of 15 GPA. Extension weed specialists have found better efficacy and coverage with at least 20 GPA.
  9. Field Water Runoff: There is revised language regarding runoff due to rainfall: “Do not apply if rainfall is expected in the next 24 hours that would result in soil runoff.”
  10. Applicator Training Requirements: Mandatory annual applicator training.
  11. Dicamba-Resistant Weed Language: There is expanded language to address weed resistance management. Suspected resistant weeds should be reported to a chemical company representative.
  12. NDA Clarification on Retail Purchase: Uncertified applicators cannot buy or use RUP dicamba unless they are acting as a representative of the certified applicator. The way the labels have been revised, the sale and use are only to and by certified applicators. NDA officials have always followed federal private applicator record-keeping regulations that stipulate if a dealer keeps a written document on file for the customer of whom he/she designates as their agent to pick up RUPs on behalf of the customer, and the dealer can assure the applicator is properly certified, NDA allows uncertified applicators to pick up RUPs for the certified applicator. This is because they are not buying it, but acting as a third party for the certified applicator. It has to be documented at the time of sale. You do not need the extra dicamba training certification to buy at the retail level; however, you do need dicamba training to apply RUP dicamba products.
  13. NDA Clarification on Buffer Requirement: Roads and maintained/managed roadside ditches can be included in the buffer requirement. An unmanaged roadside area would be one that has tree or brush overgrowth that would reclassify the area as a sensitive site or one which the Nebraska Game and Parks Commission has specifically designated as potential habitat for threatened and endangered species.

Do other states accept Nebraska’s state-approved RUP dicamba training? Kansas is the only state that recognizes Nebraska training without requiring additional training. Nebraska accepts all other states’ training so long as the applicator also receives the Nebraska Department of Agriculture Module, which is the Nebraska-specific information.

My hired hand and I both hold private applicators licenses. He will be doing all my spraying. I am taking the dicamba training, but does he also have to take the dicamba training? Yes, anyone who applies one of the RUP dicamba products must complete an approved dicamba training and hold either a private or commercial/noncommercial (Ag Plant or Right-of-Way Category) applicator license.

What is the difference between susceptible crop and sensitive site, as referenced on these RUP dicamba product labels? Susceptible crops are commercial crops listed on the label and being sold for commercial purposes. They are crops such as non-dicamba tolerant soybeans, grapes, hops, sunflowers, and fruit trees. Sensitive sites are also listed on the labels; examples include residential areas, surface water (ponds, lakes, streams), and habitat for threatened or endangered species.

How far do I need to look across the fence and inquire with neighbors if there is a susceptible crop near where I want to spray? At least 110 to 220 feet adjacent to your dicamba tolerant (DT) soybean field. Review the DriftWatch section in this FAQ under “What has Changed.”

What is the requirement for "scouting" sensitive sites? Part of the record-keeping requirements for these RUP dicamba products is to document the location of sensitive sites near the application area. This can be done by using Driftwatch.org to first identify the sensitive sites near the application area, and then printing the results or transferring them to a plat map or similar resource. Another way to document the sites is to drive around the application area, note all sensitive sites, and transfer the information to a plat map or similar resource.

What is the requirement for applying one of the RUP dicamba products followed by irrigation or predicted rain? The labels prohibit application if rainfall is predicted to allow for runoff within 24 hours. Rainfall and irrigation are essentially considered the same, so irrigation should not occur until 24 hours after the application. The intent is to avoid runoff of the chemical that could result in uptake by non-target species.

Must I clean out my spray equipment every day when using the RUP dicamba products? No. RUP dicamba labels require applicators to ensure that spray equipment is clean before using the product and after the product is applied. Cleaning equipment prior to loading with dicamba assures that nothing left in the sprayer will negatively impact the performance of the dicamba or the crop being treated.

The RUP dicamba labels require spray systems be cleaned following the procedures listed on the RUP dicamba labels, before using the herbicide after another type of spray mix, and immediately after using dicamba before switching tank mixes. This is to avoid contaminating the RUP dicamba spray mix with other chemicals that might affect the volatility of dicamba and to avoid carrying dicamba over to a sensitive crop in the next load or applications. Note: The NDA also advises applicators that all transportation equipment hauling pre-blended dicamba loads to the field are also potential sources of contamination and should be treated the same as spray equipment when it comes to cleaning before changing product mixes.

Since I must record how and when the spray system cleanout was done, how should I do this when using the same RUP dicamba product on Xtend soybeans for multiple loads and/or over several days? The RUP dicamba labels require you to record how and when the equipment was cleaned every time you clean it. At a minimum, the spray system must be cleaned before the first load of RUP dicamba is applied and after the last continuous RUP dicamba application is completed. Equipment does not need to be cleaned after every application or every load IF your spray mixes are identical and are all made with allowed tank mix partners/products applied to Xtend soybeans. In that case, you could document cleanout dates and procedures of the first and last applications, and include all required pesticide application records for fields sprayed in between.

Must I have a copy of the RUP dicamba label with me during all applications? No, but you do need to have a copy of the label in your possession. It can either be a printed label on file or a digital link that can be shown when requested.

I understand that if the wind is blowing 3-10 mph toward an adjacent susceptible crop I cannot spray. Is that true? Yes, the label prohibits you from spraying when the wind is blowing toward the adjacent dicamba-sensitive crop on the day of application. This is true even when a downwind buffer has been incorporated. The key word here is “adjacent,” which is not defined in the RUP dicamba labels. It would seem logical that any dicamba-sensitive crop within the 110- or 220-foot distance from the downwind edge of the intended target field would be adjacent.

On the day I plan to spray my DT soybeans with one of the RUP dicamba products, the wind is blowing 3-10 mph at boom height, toward my neighbor’s adjacent corn field. Do I need a downwind buffer? No. A downwind buffer is not required when bordering corn.

On the day I plan to spray my DT soybeans with one of the RUP dicamba products, the wind is blowing 3-10 mph at boom height, toward an adjacent pasture. Do I need a downwind buffer of 110 feet or 220 feet depending on my rate? Yes, if the grassy area or pasture has threatened or endangered species habitat that could be harmed.

On the day I plan to spray my DT soybeans with one of the RUP dicamba products, the wind is blowing 3-10 mph at boom height, toward a woodland area. Do I need a downwind buffer of 110 feet or 220 feet, depending on my rate? Yes. Since trees are listed as a potentially sensitive area on the label, and not listed as one of the four sites that can be counted as reducing the buffer distance, the full 110- or 220-foot buffer must be taken in the intended target field.

On the day I plan to spray my DT soybeans with one of the new RUP dicamba products, the wind is blowing 13 mph at boom height, toward my neighbor’s corn field. Can I spray? No. None of the RUP labels allow spraying when wind speeds at boom height are either above 10 mph or less than 3 mph. Calm air conditions early in the morning or late in the evening often indicate air temperature inversions are present. These conditions allow microscopic spray particles to remain suspended in the air and be carried for long distances before settling out onto whatever plants are present.

My neighbor also will be planting DT soybeans. The day I plan to spray my DT soybeans with one of the RUP dicamba products, the wind is blowing toward his DT soybeans. Can the neighbor’s DT soybeans count as part of my downwind buffer? Yes. The RUP dicamba labels allow your neighbor’s DT soybeans to be counted as reducing the buffer distance, effectively making the buffer distance zero feet.

More Information

If you have questions concerning something stated in this FAQ or about RUP dicamba use in Nebraska and/or how a specific clause on the RUP dicamba label will be interpreted, please call the NDA Pesticide Division, Nebraska Department of Agriculture (NDA) at (402) 471-2351 (Lincoln) or 800-831-0550. The NDA website for dicamba information is http://www.nda.nebraska.gov/pesticide/dicamba.html.