VM Views: Understand grazing restrictions and gain peace of mind
By Scott Wright, IVM product manager, Dow AgroSciences
Rights-of-way and roadsides pass through pastures grazed by livestock more commonly than one might think. Some pastures are established and easily identified; while others are not. They can be somewhat of a moving target because land not used for grazing today might be converted to a pasture six weeks after an application occurs. Landowners aren’t likely to alert you to this change. That’s not their job. In many cases, the right-of-way or roadside is part of an easement through private land. It’s the job of the utility and its application crews to understand the areas they plan to treat, and they need to plan accordingly.
Why is this so important? It’s illegal to apply herbicides on sites not labeled for use. It clearly states as much on the herbicide label when it says, “It is a violation of federal law to use this product in a manner inconsistent with its labeling.” Applying herbicides without grazing tolerances to land used for grazing (even if it is converted after the fact) is considered an off-label application under the Federal Insecticide, Fungicide, and Rodenticide Act. It would be similar to spraying a nonaquatic-use herbicide into water.
Typically, if a situation arises where animals graze forage that has been treated improperly, the first line of recourse is through the state Department of Agriculture. Violations could result in criminal or civil penalties. If we’re talking about beef cattle, these animals could not be sold for human consumption. With beef prices where they are today, settlements can be easily avoided by using the properly labeled herbicides in your spray programs. Liability usually falls on the applicator or the end user of the herbicide, as they are required to read, understand and comprehend the label prior to mixing, handling or applying.
So, why not eliminate the risk all together and just use herbicides that contain grazing tolerances? Price shouldn’t be a factor, because there often is no cost difference or premium for grazing tolerances. All Dow AgroSciences Industrial Vegetation Management (IVM) herbicide products have grazing data packages with no or limited restrictions on use. In fact, all of our active ingredients also are used in the range and pasture market every day.
Even when using herbicides with grazing tolerances, it’s still a good policy to practice proactive landowner communication prior to application, especially in areas where grazing is likely. It helps alleviate landowner concerns, and it can help spur discussion regarding sensitive areas not on your radar.
Here’s another best practice for vegetation managers: When planning for a herbicide bid package, work with applicators to fully assess grazing lands or other sensitive sites that applicators might encounter. It minimizes confusion and reduces the chance for error. For an extra layer of protection, specify in the bid package that only products with grazing labels be used.
It’s easy to overlook this issue by assuming your applicators will just switch tanks when they run into an existing pasture or land that will be converted shortly after an application. At some point, that assumption will likely lead to angry phone calls from landowners — or worse.