Latest 2,4-D use changes

1 October 2020

All you need to know about the latest APVMA 2,4-d use instruction changes in one place. 

Key information sections

Definitions

Nufarm’s recommendations in summary

More information

Introduction

What are the main APVMA requirements for Summer 2020/21?

On 30 September 2020, the APVMA announced that they have re-issued requirements on all 2,4-D products effective from 1 October 2020.

When applying 2,4-D products, the same instructions required by the APVMA in 2018 and 2019 apply, along with additional instructions required by the APVMA on 30 September. These will be in place until the APVMA issue new labels based on their 3 September 2020 final 2,4-D review decision.

These instructions can be found on the labels on all Nufarm 2,4-D products manufactured since 1 Nov 2018. The additional instructions required by the APVMA on 30 September repeat the instructions in the Nufarm 2,4-D product labels, with APVMA added instructions providing additional flexibility for aerial use (which was previously allowed under a permit). This includes:

  • The minimum mandatory droplet size is maintained at VERY COARSE..
  • An advisory statement has been added “Farmers are advised to use a larger droplet size (EXTREMELY COARSE or ULTRA COARSE) until 15th April” (NOTE the APVMA final 2,4-D review decision on 3 September 2020 no longer requires this statement but it does not come into effect until the APVMA issue new labels)
  • Downwind buffer zones have been established from sensitive vegetation and aquatic areas.
  • Boom height is restricted to a maximum of 50cm above apparent target surface (either the crop canopy, average weed height or top of stubble) (NOTE the APVMA final 2,4-D review decision on 3 September 2020 allows boom heights of up to 1.0 metres but it does not come into effect until the APVMA issue new labels unless operating under Nufarm’s permit which can be found on the APVMA website)

It’s important to note that the final 3 September 2020 requirements are not yet in effect and will be phased in over the next 12 months. Nufarm’s plan to do this will be after sowing in 2021.

 

What is the easiest way to find the 2020 additional instructions for my product?

 

To support retailers and users, Nufarm have prepared product specific versions of these instructions which tell you all you need to know about the requirements for our products. These can be accessed by clicking the “Additional APVMA use instructions” button on each product website (see list of products below).

They can also be found on a one-pager with QR codes and hyperlinks which can be downloaded here.

If you require the full version of the instructions that covers all 2,4-D products, then visit the APVMA website.

What is Nufarm doing?

All Nufarm 2,4-D products manufactured from 1 Oct 2020 will have the additional instructions required by APVMA attached to the container. These will initially be in the form of an A4 document in a plastic pouch. Nufarm are investigating a better solution that will be implemented as soon as possible.

Nufarm have notified all channel partners holding our products and will be providing a copy of the additional instructions with all shipments as required by the APVMA.

To provide clarity about the additional 2018/2019 instructions that now apply, Nufarm will focus on supporting channel partners, advisors and farmers on the current requirements for this season’s Summer spraying.

We are planning on introducing updated labels after sowing in 2021 (that include the APVMA final requirements on 3 September 2020 along with proposed improvements to reduce unnecessary and unwarranted restrictions). We will provide a series of extension materials to practically explain these changes at the same time.

 

Which Nufarm products are affected?

AMICIDE ADVANCE 700 – 700 g/L 2,4-D amine
AMINE 625 – 625 g/L 2,4-D amine
BATON LOW – 800 g/kg 2,4-D amine 
COBBER 475 – 475 g/L 2,4-D amine
ESTERCIDE 800 – 800g/L 2,4-D ester
ESTERCIDE XTRA 680 – 680 g/L 2,4-D ester
TROOPER 75-D – 300g/L 2,4-D amine and 75 g/L picloram
ZEPHYR 625 Low Odour – 625 g/L 2,4-D amine

Which users are affected by these changes?

All end users of 2,4-D products in all regions of Australia need to comply with the changes.

All chemical manufacturers and suppliers of 2,4-D need to ensure:

  • 2,4-D products manufactured prior to 1 October 2020 must be supplied (either by manufacturer to retailer or retailer to farmer) with a copy of the APVMA permit issued 30 September 2020 (obtain a copy from the APVMA website)
  • 2,4-D products manufactured from 1 October 2020 must have a copy of the APVMA permit issued 30 September 2020 securely affixed to every container of a 2,4-D product (obtain a copy from the APVMA website). Customers can be assured that Nufarm will be compliant with this immediate requirement.

These requirements apply to all 2,4-D products. These requirements will apply until the APVMA issue full updated labels based on their final decision of 3 September 2020 (product registrants must make applications to the APVMA to update their labels). Nufarm are planning on implementing these changes after winter crop sowing in 2021 to avoid as much further confusion as possible during the peak usage period.

All enquiries regarding this process can be directed to:

Chemical Review

Australian Pesticides and Veterinary Medicines Authority

GPO Box 3262

SYDNEY NSW 2001

Telephone: +61 2 6770 2400

Email: [email protected]

Website: apvma.gov.au

What about the restrictions announced by APVMA on 3 September 2020 in industries such as sugarcane?

The APVMA announcement on 3 September 2020 included restrictions on application rates and times of the year for 2,4-D use in sugarcane, peanuts, pastures and turf.

These restrictions will not be in place until either product registrants update their labels, or for all products on 1 October 2021.

In the case of sugarcane, Nufarm believe that an alternative risk management approach can be taken and are pursuing a registration to limit the 3 September  2020 restrictions required by APVMA. The timeframe for the APVMA’s consideration of this proposal is not yet confirmed. In the meantime, Nufarm will continue to collaborate with CANEGROWERS to keep growers informed.

To ensure growers can continue to use our products safely and legally, Nufarm will not be updating product labels voluntarily until this is resolved.

What are the advisory statements that affect me?

Advisory statements are recommendations and are not enforceable by the regulatory authority. They are provided to reduce the risk of drift and it is strongly recommended they be followed.

Advisory statements for use in cereals, fallow and pasture 1 October to 15 April

In cereals, fallow and pastures during the period 1 October to 15 April, it is advised to:

  • Use 04 or bigger TTI or equivalent nozzles that produce extremely coarse (xc) to ultra coarse (uc) droplets
  • Use higher water rates per ha, to give better efficacy
  • Use slower application speeds to allow operators to lower boom heights

Increasing droplet size and water rates while reducing application speed will assist in mitigating off target inversion drift during summer spraying. Extremely coarse droplets will produce <3% driftable droplets.

(NOTE the APVMA final 2,4-D review decision on 3 September 2020 no longer requires this statement but it does not come into effect until the APVMA issue new labels.)

Will product efficacy be affected with coarser droplets?

Nufarm data indicates equivalent efficacy can be achieved with most target weeds and situations but water volume must be adjusted to minimum of 80 L/ha and speeds reduced to below 20km/hr. Only a slight reduction in efficacy has been seen in Autumn grass species with small vertical targets. With these weeds use the maximum label rate for that crop/situation and reduce speed to a slow as practicable. See Nufarm’s 2,4-D Technical recommendations here.

The latest GRDC information on maintaining efficacy of 2,4-D with larger droplets is available here

A benefit of increasing spray quality is to reduce the percentage of droplets below 150 micron. Droplets at or below 150 micron are unlikely to hit the target, and in warm conditions they evaporate prior to uptake by the leaf surface. These droplets are not effective in obtaining efficacy.

 

What has the APVMA not changed?

The labels did not change the following conditions and they still apply:

  • DO NOT apply in a manner that may cause an unacceptable impact to native vegetation, agricultural crops, landscaped gardens and aquaculture production, or cause contamination of plant or livestock commodities, outside the application site from spray drift
  • DO NOT spray when surface temperature inversion conditions are present (more information is now on label).
How do I predict or monitor inversions?

Surface temperature inversion is likely to be present if:

  • Mist, fog, dew or a frost have occurred
  • Smoke or dust hangs in the air and moves sideways, just above the ground surface
  • Cumulus clouds that have built up during the day collapse towards evening
  • Wind speed is constantly less than 11 km/hr in the evening and overnight
  • Cool off-slope breezes develop during the evening and overnight
  • Distant sounds become clearer and easier to hear
  • Aromas become more distinct during the evening than during the day

Information sourced from GRDC Fact Sheet: ‘Surface Temperature Inversions and Spraying’, Jul 2014

When is the greatest risk of inversions?

Nufarm has developed a tool – our 24 hour SprayWise diagram – to show those high risk periods. You can download the tool here 24 hour spraywise wheel

My sprayer does not go below 75 cm, can I still use this to spray 2,4-D products?
  • On 20 December 2018, Nufarm and Croplands in conjunction with industry worked with the APVMA to obtain a permit to use Nufarm’s 2,4-D products through spray equipment that can’t set a boom height of 50cm from the ground (such as RoGators).  The APVMA has issued a permit (PER87338) which allows growers and contractors to spray if the boom is no higher than 85 cm above the ground provided the spray quality is ULTRA COARSE 
  • Permit only applies to Amicide Advance 700, Trooper 75-D, Cobber 475, Estercide Xtra 680, Zephyr 625, Amine 625, Baton Low and Estercide 800.
  • Note that in situations where the target height is above 35 cm, the existing label requirements apply as this permit is not needed. For example, if the target height was 40 cm and the boom is set at 50 cm above the target (90 cm from the ground) then application could occur with a VERY COARSE droplet size (noting the advisory recommendation for EXTREMELY COARSE or ULTRA COARSE droplets during certain times of the year).
  • Click here for a copy of the APVMA permit and ensure you fully read and understand it prior to use as different record keeping requirements apply in addition to the boom height and droplet size requirement.
  • NOTE – this permit is due to expire on 1 October 2020, but Nufarm applied for an extension on 30 September 2020. An extension was not sought earlier as it was expected APVMA would adopt the label instructions proposed on 24 October 2019 (which allow boom heights of up to 1 metre with a VERY COARSE droplet size). These label instructions were confirmed by the APVMA on 3 September 2020, but instead of requiring these instructions the APVMA elected to re-issue the instructions from 2018 and 2019 which contained the 50 cm maximum boom height. Refer to this section of this webpage for further information.
Sprayers with OSST (Optical Spot Spray Technology) (such as WEED-IT) only deliver COARSE spray quality and have to be used with a 75 cm boom height above the ground.  Can I spray 2,4-D products with OSST?
  • On 20 December 2018, Nufarm and Croplands in conjunction with industry worked with the APVMA to obtain permits to use Amicide Advance 700 and Trooper 75-D products through OSST units such as the WEED-IT technology. The reason this permit was needed was because OSST sprayers could not comply with the APVMA requirements announced on 24 October 2018 as the technology requires a higher boom than APVMA allowed and, at the time, required a COARSE droplet size.
  • The APVMA originally issued a permit (PER87570) to use OSST technology which delivers only a COARSE spray quality with a 75 cm boom height above the ground if only 10% of the application area is treated. This permit was updated on 22 May 2020 to recognise further development undertaken by CropLands to allow the use of a new nozzle that produces an EXTREMELY COARSE droplet size and is compatible with WEED-it technology. This nozzle – the Agrotop Spot Fan nozzle (part # TDSF-4003) – allows Amicide Advance 700 and Trooper 75-D to be used for weed cover no greater than 15%.
  • Click here for a copy of the APVMA permit and ensure you fully read and understand it prior to use as different record keeping requirements apply in addition to the boom height and droplet size requirement. The current permit is available on the APVMA website and is valid to 31 May 2021. Note that Nufarm are planning on incorporating this into product labels as soon as possible.
My Spray equipment is not a standard Boom as it uses droppers or directed spray. Am I affected by buffer zones?

Nufarm has been instrumental in working with the Technical Working Group of the National Working Party on Pesticide Application (NWPPA) and the APVMA to amend the definition of a “boom sprayer” in relation to downwind buffer zones with application of products such as 2,4-D.

The aim has been for the legislation to take into consideration the use of specialist equipment which can void the requirement for spray drift risk assessments and adherence to spray buffer zones for products such as 2,4-D applied via a boom sprayer.

As a result, Section 2.2 of the recently updated Spray Drift Risk Assessment Manual lists the following as NOT requiring a spray drift risk assessment:

application with specialised equipment in cropping situations where the nozzles are orientated below the horizontal of the top of the crop canopy and spray is released at a height below the top of the crop canopy (eg drop nozzles used to direct the spray to the furrows between emerged crops, or small booms used to spray inter-row areas in tree and vine crops), but excluding sprayers where air is used to aid in the spray penetrating the canopy as these are defined as ‘vertical sprayers’ (eg air blast sprayers in orchards)”

Therefore, the boom spray buffer zones listed on labels do NOT apply if droppers, such as Irvin Legs, are utilised in the application of sugarcane pesticides, (when used in accordance with the exemption above).

Refer link  https://apvma.gov.au/sites/default/files/publication/51826-spray_drift_risk_assessment_manual.pdf

Can I apply 2,4-D products through a plane or helicopter?

Yes, where aerial is specifically approved on label, 2,4-D products can be applied aerially if you adhere to the directions on the relevant Nufarm product label. Nufarm labels provide more flexibility for aerial users than the initial APVMA changes, these appear in the “Instructions for Mandatory VERY COARSE or Larger Droplet Size Categories” section of the GENERAL INSTRUCTIONS of the label.  Alternatively, additional situations can be found in the additional instructions on the APVMA website which will also be affixed to any 2,4-D product manufactured after 1 October 2020 as required by APVMA on 30 September 2020.

Which nozzle should I use?

Please consult your nozzle suppliers for full details to obtain the most up to date information on which nozzles to use to obtain very coarse droplets.

Changing to a high pressure air induction nozzles, such as the Hardi Injet™, Teejet™ TTI, or the Agrotop™ TD-XL-D is likely required, as low-pressure air induction nozzles Teejet™ AIXR or Hardi Minidrift™ are not able to produce Very Coarse, Xtra Coarse or Ultra Course droplets in sizes or pressure that suit most spray operations.

High pressure air induction nozzles should be operated above 4 bar and offer best performance at 5-6 bar.

If using Pulse Width Modulation Systems – a good choice would be Wilger™ MR-04 or Wilger™ SR-06 nozzles at pressures below 2.4 Bar.  

Here are some useful links on nozzles:

 

How do I know if my nozzle meets the new requirements *UPDATED APVMA NOZZLE CLASSIFICATION*?

For Nufarm products containing 2,4-D, the label states under Section 1 Instructions for Ground Application:

USE ONLY nozzles that the nozzles’ manufacturer has rated to deliver a VERY COARSE or larger droplet size category as referenced to ASAE S572 Standard (including all newer versions such as S572.1) or BCPC or ISO 25358. Choose a nozzle specified to provide the droplet size category required in the label Spray Drift Restraints.

DO NOT use a higher spray system pressure than the maximum the manufacturer specifies for the selected nozzle to deliver the droplet size category required in the label Spray Drift Restraint.

The APVMA has recently clarified its stance nozzle droplet size classification and now accepts five standards. 

Further details can be found here: APVMA Droplet Size Classification

Full details can be found here: technical note on standards for the classification of nozzles in Australia

 

Will adjuvants increase droplet size?

Nozzle choice and operating pressure have the greatest influence on spray quality.
If a 2,4-D product is being applied, nozzles that provide the specified spray quality must be used.  Tank mixes do not change this requirement

Use only recommended adjuvants for the product.

Buffer zone definition

A ‘buffer zone’ is an area where pesticide application does not occur between the application site and an identified sensitive area which is downwind from the application site. For boom and aerial spraying, a buffer zone is measured from the edge of the sprayer swath closest to the downwind sensitive area; for vertical spraying, a buffer zone is measured from half a row width (i.e. trees, vines, other plants) outside the application site closest to the downwind sensitive area.

DO NOT apply in a manner that may cause an unacceptable impact to native vegetation, agricultural crops, landscaped gardens and aquaculture production, or cause contamination of plant or livestock commodities, outside the application site from spray drift. Wherever possible, correctly use application equipment designed to reduce spray drift and apply when the wind direction is away from these sensitive areas.

Watercourse definition

For the purpose of ‘natural aquatic areas’, the current definition of ‘watercourse’ under the Commonwealth Water Act 2007 is a river, creek or other natural watercourse (whether modified or not) in which water is contained or flows (whether permanently or from time to time); and includes:

  • A dam or reservoir that collects water flowing in a watercourse
  • A lake or ‘wetland’ through which water flows
  • A channel into which the water of a watercourse has been diverted
  • Part of a watercourse
  • An estuary through which water flows

A ‘wetland’ is an area of land where water covers the soil – all year or just at certain times of the year. They include:

  • Swamps, marshes
  • Billabongs, lakes, lagoons
  • Saltmarshes, mudflats
  • Mangroves, coral reefs
  • Bogs, fens, and peatlands.

A ‘wetland’ may be natural or artificial and its water may be static or flowing, fresh, brackish or saline.

Landscaped gardens definition

‘Landscaped gardens’ means any terrestrial plant species grown for ornamental purposes on private or public land, or for domestic food production on private land, with the following exceptions:

  • Species that are declared noxious or invasive to the area of application by local, state or commonwealth legislation
  • Plants which are not part of a garden under management at the time of pesticide application (e.g. flowering plants which have escaped from a home garden and have become weeds in another area)
Native vegetation definition

‘Native vegetation’ means any terrestrial plant species native to Australia as defined under local, state or Commonwealth legislation with the following exceptions:

  • Species that are declared noxious or invasive to the area of application by local, state or Commonwealth legislation
  • Plants that the chemical user, or the person the chemical user is applying agricultural chemical product/s on behalf of, is legally allowed to remove under local, state or Commonwealth legislation
Natural aquatic areas definition

‘Natural aquatic areas’ are where a ‘watercourse’ (as defined by the Commonwealth Water Act 2007) is present, with the following exceptions:

  • Artificial ‘watercourses’ used exclusively for agricultural or ornamental purposes, such as irrigation channels, flood irrigation areas, farm dams, ornamental ponds, golf course dams, those used for aquacultural production, etc.
  • ‘Watercourses’ that are dry at the time of pesticide application
  • ‘Watercourses’ that are commonly identified as ‘puddles’
Nufarm’s advice summary
  • Use minimum of 80L/ha water volume & in heavy stubble increase to 100L/ha
  • Keep speed to below 20km/hr
  • Use robust product rates (the maximum label rate for your crop/situation)
  • Use only recommended adjuvants
  • Avoid spraying at night, use Extra Coarse (XC) or Ultra Coarse (UC) if this is unavoidable (but never spray during surface temperature inversion conditions)
  • Follow the advisory statements (October – April)
Free handy techguide

download the 2,4-D recommendations techguide

More information on Drift Management Strategies
Useful resources to assist spray applicators to reduce the risk of off-target damage

SataCrop is a tool developed by the cotton industry which enables spray operators to see where cotton crops are growing.  This allows applicators to plan spraying and avoiding times when weather conditions place neighbouring crops at high risk of drift. 

Bee connected  is a nation-wide, user-driven smart-phone app that enables collaboration between beekeepers, farmers.  

SprayWise decisions is a web-based tool which provides current weather information at a local level which allows applicators to make spray decisions based on real time information.

Timeline of APVMA 2,4-D use changes over the last 5 years

1 July 2015 – the APVMA requested additional studies from product registrants for their ongoing 2,4-D review and included new registrants of 2,4-D products who had not previously been formally part of the review. The vast majority of this new information was submitted either by Nufarm, or from the Task Forces Nufarm is a member of in the US and Europe.

4 October 2018 – the APVMA announced interim measures from their review of 2,4-D which require new spray drift instructions for the 2018-19 season. The focus of these changes is to reduce the likelihood of spray drift damage which included a minimum VERY COARSE droplet size, maximum boom height of 50 cm above the target canopy and updated restrictions regarding weather conditions. See the APVMA website for more details. Nufarm responded by updating the normal labels for all our 2,4-D products as the APVMA allowed a changeover of 28 days for product about to be manufactured in the middle of the peak time of the year for 2,4-D formulation in Australia to service the needs of Australian farmers summer weed control programs.

1 October 2019 – the APVMA re-issued these interim measures because the 2,4-D review had still not been completed. See the APVMA website for more details. No further changes were required to Nufarm labels due to the actions taken in 2018.

24 October 2019 – the APVMA announced its proposed review decisions and commenced a three month consultation period. This announcement included a summary technical report and proposed changes to use instructions that included timing and/or rate restrictions when 2,4-D products are used in sugarcane, pastures and peanuts, updated spray drift restrictions, updated safety directions and various minor changes. See the APVMA website for more details.

31 January 2020 – the consultation period on the proposed review decision closed.

3 September 2020 – the APVMA announced its final decision. See the APVMA website for more details.

30 September 2020 – the APVMA announced that, until physical product labels are updated with the new instructions from their 3 September 2020 announcement, they re-issued instructions similar to those previously issued in 2018 and 2019 rather than the new instructions from their 3 September 2020 announcement. See the APVMA website for more details. The practical implications of this approach are explained here.

All enquiries regarding this process can be directed to:

Chemical Review

Australian Pesticides and Veterinary Medicines Authority

GPO Box 3262

SYDNEY NSW 2001

Telephone: +61 2 6770 2400

Email: [email protected]

Website: apvma.gov.au

Have a question we haven’t covered? Contact your local Nufarm Business Development Manager for more information.

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