Dicamba Post Emergence Use in DT (Dicamba Tolerant) Soybeans
The MDA has kept the June 20th cut-off date for the use of four dicamba products, XtendiMax, Engenia, FeXapan, and Tavium on soybeans in Minnesota for the 2020 growing season (full announcement). The Minnesota specific cut-off date restriction applies to dicamba-tolerant soybeans only. Federal label requirements are applicable to all crops including dicamba-tolerant soybeans listed on the labels of these four products.
Reference to commercial products or trade names here or elsewhere on this site is made with the understanding that no discrimination is intended and no endorsement is implied.
Questions are divided into the following categories:
- General Information
- 2020 Minnesota Specific Requirements
- 2019 Federal Requirements
- Dicamba or Auxin-specific Training
- Buffer Requirements for the Protection of Sensitive Areas and Endangered Species
- Record Keeping/Licensing
What is dicamba herbicide?
Dicamba is a selective, systemic, and plant growth regulator herbicide primarily used for post emergence broadleaf weed (for example, waterhemp, ragweed, horseweed) control in a variety of crops, residential areas, and other sites. Dicamba herbicide belongs to Group 4 site-of-action.
What are the new dicamba products and why are they used?
Dicamba has long been used in agricultural and nonagricultural herbicide products. In 2016, the United States Environmental Protection Agency (EPA) registered three products, XtendiMax® with VaporGrip® Technology (EPA Reg. No. 524-617, Bayer), Engenia® (EPA Reg. No. 7969-345, BASF), and DuPontTM FeXapanTM herbicide Plus VaporGrip® Technology (EPA Reg. No. 352-913, DowDuPont) with a dicamba active ingredient. In 2019, the EPA registered another dicamba product Tavium® plus VaproGrip® Technology (PDA REg.No. 100-1623). Tavium® is a premix of dicamba and S-metolachlor.
Why are manufacturers making DT soybean technology available in Minnesota?
In Minnesota, waterhemp has evolved resistance to several herbicide classes (for example, glyphosate, ALS, PPO herbicides). Growers can use these new tools in DT soybeans to control herbicide-resistant weeds such as waterhemp.
What are the concerns about dicamba use in Minnesota?
Dicamba is a highly volatile chemical that can damage non-target plant species through spray drift and/or volatilization (vapor drift)/misapplication. Misuse of dicamba products may cause serious damage to sensitive plants species such as non-dicamba-tolerant soybeans, grapes, trees, ornamentals, etc.
What steps have been taken to prevent the damage to off-target plants from dicamba use on DT soybeans in the next growing season?
New use restriction has been put into place for dicamba use in 2019. First, there are new requirements and restrictions spelled out on the federal label. Second, the MDA established an additional Minnesota-specific label restriction that limits when dicamba products are used in Minnesota. Finally, all applicators must follow the requirements specified in the Minnesota Pesticide Control Law. A person that applies any of the new dicamba products must adhere to all legal requirements and restrictions.
Where can I report observed dicamba damage in 2020?
The MDA encourages the reporting of all dicamba damage. You can begin the formal complaint process by calling 651-201-6333 between 8:00 AM and 4:00 PM Monday through Friday.
Additional instructions for submitting a complaint can be found using the online complaint form. Use the following contact information to report dicamba damage to manufacturers:
- Bayer (XtendiMax) – 1-844-RRXTEND (779-8363)
- BASF (Engenia) – 1-800-832-HELP (4357)
- DuPont (FeXapan) – 1-888-6-DUPONT (38-7668)
- Syngenta (Tavium) – 1-866-Syngent(a) (866-796-4368)
Are there any new federal label mandated requirements added in 2020?
No, no new federal label requirements are added in 2020.
Are 2019 federal label changes applicable in 2020?
Yes, the 2019 federal mandated label requirements are applicable in 2020.
What are the federal label mandated requirements?
The U.S. Environmental Protection Agency engaged state lead agencies, such as the Minnesota Department of Agriculture, U.S. Department of Agriculture, Cooperative Extension Service, and the pesticide manufacturers to find fixes that address the underlying causes leading to dicamba-related incidents of crop damage. The additional requirements and restrictions included on the federal label for the new dicamba products in 2019 are:
Classification as Restricted Use Pesticides and permitted use only by certified applicators
Prohibit over-the-top application of dicamba on soybeans 45 days after planting
Application will be allowed only from 1 hour after sunrise to 2 hours before sunset
In counties where endangered species may exist, the downwind buffer will remain at 110 feet and there will be a new 57 feet buffer around the other sides of the field (the 110 feet downwind buffer applies to all applications)
All applicators applying new dicamba products must complete dicamba or auxin-specific training
Additional spray equipment clean-out instructions
Additional advisory to stress the importance of pH in dicamba volatility
General label edits for clarity
Applicators must always read and follow all label directions. It is a violation of federal and state law to use any new dicamba product in a manner inconsistent with the label.
Can I use product with the 2019 version of the label on the container? Where do I obtain the new 2019 labels?
Applicators must obtain and comply with the new 2019 federal label. Visit the registrant’s website or contact the registrant for instructions on obtaining the new label.
What is the additional label restriction added by the MDA for new dicamba product use to prevent off-target damage in the 2020 growing season?
Cutoff date: Do not apply after June 20
The Commissioner established the June 20 cut-off date for the 2020 growing season after the review of survey results and peer reviewed literature, and input from the Minnesota Soybean Growers Association Drift Task Forces and University of Minnesota Extension weed scientists.
Is the Minnesota restriction on the federal label? Where do I find the Minnesota labels?
No; the Minnesota cutoff date of June 20, 2020 is not on the federal labels. It is on a Section 24(c) special local need (SLN) label for each new dicamba product. You can obtain the Minnesota labels online.
What do applicators need to do to comply with the Minnesota restriction?
Applicators need to:
- Obtain the 2020 Minnesota Section 24(c) label for each new dicamba product they are applying in 2020.
- Comply with the June 20, 2020 cutoff date restriction.
- Have the appropriate 2020 Minnesota Section 24(c) label in their possession at the time of application.
- Comply with the record keeping requirements on the federal label.
Can I still use the 2019 Minnesota Section 24(c) label for the dicamba product I want to use in 2020?
No; the 2019 Minnesota-specific Section 24(c) label is no longer valid and cannot be used in 2020. The 2019 24(c) label expired on December 31, 2019. Applicators will need to obtain, comply with, and have in their possession at the time of application, the 2020 label. Record keeping requirements are a component of the label and state law.
Are there any additional federal application timing restrictions on the use of these products?
The 2019 federal labels for XtendiMax, Engenia, and FeXapan prohibits application 45 days after planting or R1 growth stage (beginning bloom), whichever comes first for the target soybean crop. This means that these products cannot be applied once the R1 stage has initiated. R1 stage is when at least 1 flower appears on the plant on any node on the main stem. In other words, these products cannot be applied even if one soybean plant has developed a flower. The 2019 federal label of Tavium prohibits application 45 days after planting or after V4 growth stage, whichever comes first for the target soybean crop.
I planted DT soybeans early and it has reached V5 or R1 stage prior to June 20th, can I apply dicamba in-crop application?
Dicamba in-crop application varies with product. XtendiMax, Engenia, and FeXapan federal labels prohibit application at the onset of R1 growth stage. Tavium label is more restrictive and prohibits application after V4 stage of soybeans.
Can I apply dicamba after June 20th if DT soybeans are still in vegetative stage?
The Minnesota Section 24(c) special local need (SLN) label prohibits application after June 20 regardless of soybeans growth stage.
How is the 2020 Minnesota specific restriction different from the 2019 restrictions?
The 2020 Minnesota specific restrictions are the same as the 2019 restrictions.
Why did the MDA choose June 20 as the cutoff date for dicamba post emergence application?
The Commissioner set this cutoff date based on the review. The majority of Minnesota soybeans will still be in the vegetative growth stage by June 20. Research shows that non-DT (dicamba tolerant) soybeans in the vegetative stage are less affected by dicamba than those in the reproductive stage.
Can the new dicamba products be applied to DT soybean on June 20?
Yes, new dicamba products can be applied on June 20 if other federal requirements are met (for example, wind speed is 3-10 mph).
What are the label mandated dicamba or auxin-specific training and recordkeeping requirements?
Each label for the new dicamba products specifies that applicators must attend training. Manufacturers will provide training that meets the requirements of the label. Information about dicamba use and training is available on the Minnesota Crop Production Retailers web page.
Each label for the new dicamba products also specifies content and a format for records that applicators must maintain for each application. Manufacturers may provide record-keeping templates that meet the requirements of the label.
Complying with each of these federal label requirements is mandatory.
Is the training one-time or do I need training every year?
MANDATORY dicamba or auxin-specific training is needed every year you plan to choose new dicamba products. Even if you received MANDATORY dicamba or auxin-specific training last year, you must complete it again this year and next year to be able to legally purchase and use these three products.
Do I need mandated dicamba or auxin-specific training if I plant DT (dicamba tolerant) soybeans but do not plan to use dicamba products?
No, dicamba or auxin-specific training is mandated only for those who use one of the new dicamba products.
Do I need to attend training put-on by the manufacturer of the product I purchase? What if I buy two or three different dicamba products?
No, a person only needs to attend one training session provided by any of the manufacturers of the new dicamba products, i.e. BASF, DowDuPont, Syngenta, or Bayer. One annual training satisfies the training requirement for all four products.
Who will conduct dicamba training mandated by the new dicamba labels?
Dicamba registrants (BASF, DowDuPont, Syngenta, and Bayer) have prepared training materials and they, or their designees, will conduct training for dicamba applicators that meets the label requirements for 2020 season.
How long does the registrant training last?
The training takes approximately 2 hours.
What does the training cover?
The training will cover the product label requirements, recordkeeping requirements, weed management practices, buffer requirements and protection of sensitive crops, sensitive areas, and endangered species, spray drift management, chemistry, mixing and handling, window of application, equipment preparation and special considerations.
Do I have to pass an exam?
No, the class consists of instruction, review and open question-and-answer sessions. Online training may have quiz components.
Will I receive a certificate after completing the training?
Once the training is completed, the applicator should obtain a certificate to keep as a record. (One of the recordkeeping elements for these registrations requires the certified applicator to show proof of completing dicamba-specific training.)
The instructor will also maintain a record of those attending the class and will collect the applicator’s name, address, email, and other information.
Will my applicator credential be amended to show that I’ve received training?
No, it will not be amended. Pesticide dealers are not required to see the proof of training to sell the dicamba products to certified applicators.
Where do I find a list of training sessions provided by the registrants?
Can I attend the training online for 2020 season?
Yes, the MDA has started accepting online training on new dicamba products from January 1, 2020.
Can I attend the registrant training in another state?
The MDA will recognize dicamba training that is based on material prepared by any of the three registrants (BASF, DowDupont, Syngenta, or Bayer) if the training is provided in Minnesota or a neighboring state (North Dakota, South Dakota, Iowa, or Wisconsin). The registrant will be responsible for maintaining a database of attendees. Applicators must follow MN specific restrictions even if they are not covered in the dicamba training.
Do I need certification and special training if I am using new dicamba products on crops other than DT (dicamba tolerant) soybeans listed on the label?
Yes, the new dicamba products are classified as RUP. A state credential is required to use these products. Additionally, the use of these new dicamba products requires training as mandated by the label for use on all crops listed on the label. These requirements only apply to the new dicamba products described in this document.
Where can I find more information about dicamba training requirements?
The EPA website has additional information on dicamba training requirements or contact the MDA.
What are non-sensitive crops and areas?
Non-sensitive crops and areas include paved or gravel surfaces; roads; mowed and/or managed areas adjacent to field, such as roadside rights-of-way; areas covered by the footprint of a building, silo, shade house, feed crib, or other manmade structure with walls and a roof; agricultural fields that have been prepared for planting; and planted agricultural fields containing asparagus, corn, dicamba-tolerant cotton, dicamba-tolerant soybeans, sorghum, proso millet, small grains, and sugarcane (the applicator is responsible for ensuring that the crops are dicamba-tolerant).
How do I know if I need a 57 feet omnidirectional buffer or not?
The applicator must follow the measures contained in the Endangered Species Protection Bulletin for the area in which applicator is applying the product. They must obtain Bulletins no more than six months before using this product, consult http://www.epa.gov/espp/ or call 1-844-447-3813. The applicator must use the Bulletin valid for the month in which he will apply the product.
It is a federal offense to use any pesticide in a manner that results in the death of an endangered species.
What are the downwind dicamba buffer requirements?
The applicator must always maintain a 110-feet (or 220-feet) downwind buffer between the last treated row and the nearest downwind field/area edge (in the direction the wind is blowing). Applicators can still use out-of-field non-sensitive crops and areas in the total buffer distance calculation. It should also be noted that the 110-feet downwind buffer is not intended to protect downwind sensitive crops and plants from off-target dicamba exposure. It is intended to protect other sensitive areas, for example, water bodies, non-residential areas, etc. The downwind dicamba application prohibition and the 110-feet downwind buffer requirement should not be confused when the concern is protection of downwind sensitive crops and plants.
Is a buffer required on just one side of a dicamba-treated field?
Sometimes yes, but often times buffers are required on several sides. Applicators should remember that buffers will often be required on two or more downwind sides of a target field if wind direction is not constant and non-target sites are not positioned completely perpendicular to one another. A 45-degree wind direction would require a buffer on two downwind sides. The applicator may have to change the buffer location with the change in wind direction during the application.
Are downwind buffers required next to in-field grass/vegetative waterways?
No, downwind dicamba buffers would not be required next to these in-field areas. The United State Environmental Protection Agency has concluded that grass waterways should be treated the same as Conservation Reserve Program (CRP) areas. Both CRP and grass waterways include voluntary conservation agricultural areas that could be used for cropland production. Therefore, buffers are not required to protect these voluntary conservation practice areas.
If I own a wooded lot downwind of my target field, do I need a downwind buffer?
Yes, regardless of who owns the wooded lot, it is label-defined as a sensitive uncultivated area that may harbor a sensitive plant species or endangered species. Therefore, even an adjacent wooded lot that you own or control is required to have a downwind buffer.
Can I spray dicamba products if the wind is blowing in the direction of sensitive crop species or area?
No, dicamba application should not be made if the wind is blowing in the direction of sensitive crops.
Yes, dicamba application can be made if wind is blowing in the direction of sensitive areas (e.g. water bodies, non-residential areas, etc.) and 110 feet downwind buffer requirement is followed.
What are the record keeping requirements for dicamba application in 2020?
- All dicamba applicators, commercial and noncommercial, must keep the records required on the label for a period of 5 years
- All private applicators must keep the records required on the dicamba label for a period of 2 years
- Records must be generated within 72 hours after dicamba application and a record must be kept for every individual application
- Records must be made available to State Pesticide Control Official(s), USDA, and EPA upon request
Are dicamba applicators required to fulfill additional record keeping requirements?
In addition to the dicamba label recordkeeping requirements, some types of applicators need to record additional information:
- Commercial applicators have to keep the applicator's company name and address AND the name and address of the customer
- For all dicamba applicators, keeping records electronically is acceptable
As per the label, dicamba applications can only be made one hour after sunrise and two hours before sunset. How do I know the sunrise and sunset times if it is cloudy on the day of dicamba application?
The MDA encourages dicamba applicators to visit the National Weather Service website to see the timing of sunrise and sunset on that calendar day. Dicamba applications will be allowed only from 1 hour after sunrise to 2 hours before sunset.
Who can use new dicamba products?
New dicamba products are classified as Restricted Use Pesticides (RUPs) and can only be used by applicators that are either certified as Private Pesticide Applicators or licensed as either Commercial or Noncommercial Pesticide Applicators and certified in Categories A (Core) and C (Field Crops) as required by the Minnesota Pesticide Control Law. The Pesticide Control Law and federal label do not allow uncertified applicators to use the new dicamba products or any RUPs under the supervision of certified applicators.
What are other applicator requirements established by the Minnesota Pesticide Control Law?
In addition to licensing requirements, Commercial Noncommercial applicators must meet record keeping requirements specified in the Law. The MDA maintains samples of records on our web page that illustrate these requirements. Finally, Private Pesticide Applicators must meet the federally mandated record keeping requirements for Restricted Use Pesticides.
Is a Pesticide Dealer License needed to sell or offer to sell the new dicamba products?
Yes, the new dicamba products are classified as RUPs and as Agricultural Pesticides because of Worker Protection Standard language included on the product labeling. The MDA issues Agricultural Pesticide Dealer Licenses to businesses that offer for sale or sell agricultural pesticides to an end-user for use in the state of Minnesota.
What are a pesticide dealer’s responsibilities for selling or offering the new dicamba products for sale?
Pesticide dealers selling dicamba must verify each end-user has a valid Commercial or Noncommercial Pesticide Applicator License or a Private Pesticide Applicator Certification awarded by the MDA. Dealers must keep records of their purchase, sale, and distribution of these products for a period of five years. Additional requirements are detailed on the MDA Pesticide Dealer webpage.
What are the indicators for the presence of temperature inversion?
Do not apply dicamba products when inversion conditions exist. The following are the indicators of presence of temperature inversion conditions:
- Calm day with wind speed less than 3 mph;
- Clear night;
- Dust cloud hanging on the side of the road;
- Dew or frost present on the ground;
- Horizontal smoke pattern; and
- Ground fog in low-lying area.
Can I use old dicamba products for preplant application on DT soybeans?
The dicamba label requires at least 30 days rotational crop interval (days after application); and a minimum accumulation of 1 inch of rainfall or overhead irrigation must be observed following application of old dicamba products like Clarity. These requirements may vary from product to product or there may be additional label requirements. Carefully read and follow all label requirements.
What are post emergence broadleaf weed control options after June 20?
The MDA highly encourages growers to use preemergence herbicides with residual control and to follow resistance management strategies, such as:
- Do not rely on a single herbicide site-of-action
- Apply full labeled rates
- Use preemergence herbicides with residual control
- Zero threshold for herbicide resistant weeds (for example: waterhemp) avoid application of herbicides with the same site-of-action more than twice in the season, incorporate non-chemical tactics (such as crop rotation, cover crops, weed free seeds) that are mentioned on the label as part of integrated weed management
For best control, post emergence dicamba applications should be made when broadleaf weeds are less than 4 inches in height. To manage broadleaf weeds, especially herbicide-resistant waterhemp (emerges throughout the growing season) after June 20th, follow University of Minnesota Extension recommendations on layering of residual herbicides such as Dual, Outlook, Warrant, and Valor. Incorporation of layering of residual herbicides in herbicide programs provide residual control of late emerging weeds.
If you do not have herbicide-resistant waterhemp in a field, herbicides from these three sites-of action can be applied:
- Glyphosate (Group 9)
- ALS inhibitors such as Pursuit, Classic, FirstRate (Group 2)
- PPO inhibitors such as Flexstar, Cobra, Cadet, Ultra Blazer (Group 14)
Growers that have glyphosate-resistant waterhemp may consider using tank-mix of glyphosate with an herbicide from Group 2 or Group 14.
In other genetically engineered soybeans, for instance LibertyLink soybeans, applicators can use Liberty (Group 10) herbicide in addition to other labeled herbicides for weed management.