Pesticide Labeling Questions & Answers - Chemigation
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These answers are not intended to create significant new guidance or require any changes to previously accepted labeling. The Agency will contact registrants directly about how to correct problematic labels as appropriate. Changes to EPA accepted labeling will only be required in accordance with standard agency procedures. These answers are primarily based on federal law, regulations and policies implemented by EPA. States, tribes, territories, and other federal agencies may have additional requirements relevant to their jurisdictions.
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- Is an apparatus of a pump connected to a bottle of concentrated pesticide, which in turn is hooked into a residential lawn irrigation system (sprinkler system) considered a chemigation device? Can chemigation be referred to in a residential setting? The pesticide used in this case is a 25(b) exempt product. Could other registered conventional pesticides be used? (LC06-0064)
The apparatus in question is application equipment that turns a residential lawn irrigation system into a chemigation system by introducing the pesticide into the irrigation system. Chemigation is defined in 40 CFR 170.3 as “the application of pesticides through irrigation systems.” While this regulatory definition is exclusive to agricultural settings, it is reasonable for the Agency to apply it to similar situations outside of agricultural settings such as in residential lawn irrigation systems. Thus the Agency would consider use of the apparatus described above as a chemigation application. To the extent that a label prohibits the use of a product in a chemigation system, the label prohibition must be followed.
Chemigation has also been addressed in the agricultural setting through PR Notice 87.1, but this notice specially states that it does not apply to any pesticide product intended solely for residential setting. However, the scope of the PR Notice was limited based on the information the Agency had on the extent of chemigation as a practice at the time. The agency is currently reviewing PR Notice 87.1 to update in accordance with changing practices and will be putting a draft out for public comment.