“Every situation is unique and numerous factors must be considered when evaluating whether an application is appropriate. The Department interprets this label provision (“adjacent” or “neighboring”) to go beyond “side by side” but we do not have a specific distance limitation. If an inspector’s interpretation of adjacent or neighboring is different from the applicator’s interpretation, penalties and fines against the applicator could result.Ī request was made of the IDOA to define how agency personnel will interpret adjacent and neighboring with respect to distance. The following paragraph, reproduced in its entirety and with permission, is the response from IDOA: However, inspectors with the Illinois Department of Agriculture (IDOA) ultimately will have the final determination of distance to adjacent and neighboring sensitive crops during investigations. Registrants of dicamba-containing products labeled for use in dicamba-resistant soybean varieties have indicated they have no intention to include distances that define adjacent and neighboring on the labels. Rather, manufacturers intend to leave the decision to spray or not to spray at the discretion of the applicator. Is a sensitive soybean crop adjacent or neighboring if it is less than 10 feet from the treated field? What about 100 feet from the treated field? What if the sensitive soybean field is one mile from the treated field? “Adjacent” and “neighboring” can be defined by a dictionary, but no dictionary can provide the distance(s) considered adjacent or neighboring for these products. In instances where no downwind areas can be included in a buffer (corn field, paved road, building, etc.), there always will be some sensitive crop at some distance downwind. The labels clearly specify that applications may be made only when wind speed is between 3 and 10 miles per hour, meaning there always will be a downwind side(s). Problematically, however, neither product label defines “adjacent” or “neighboring” with respect to distance from the treated field. “Do not apply when wind is blowing in the direction of neighboring sensitive crops.” “Do not apply this product when the wind is blowing toward adjacent non-dicamba tolerant susceptible crops this includes non-dicamba tolerant soybean and cotton.”
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