MDA Presenter: Kim Kaiser
The presentation focused on the groundwater results from the 2024 monitoring season. Current common detection pesticides were reviewed, and trend maps were presented showing changes in detection frequency and concentration for individual pesticide monitoring regions (PMRs). Highlighted topics included: pesticides detected in PMR 4 (Central Sands), detections of 4-hydroxychlororthalonil and neonicotinoids, and detections of cyanazine degradates in private wells.
Following the main presentation, Kate Hall briefly shared additional background on chlorothalonil and recent EPA actions (e.g., reducing allowable rates). MDA actions being taken to better understand and address detections of the chlorothalonil degradate, 4-hydroxychlorothalonil, in groundwater were also highlighted (e.g., expanding monitoring, developing best management practices).
Discussion focused on:
How pesticide use patterns relate to groundwater detections
When concentrations of parent and degradate compounds should be treated as additive
The ecological effects of atrazine and cyanazine and historical concerns
Historical concerns over atrazine’s effects on frogs were discussed along with the data supporting/not supporting the claims. The MDA noted that it previously conducted a special registration review on atrazine that goes into more detail on its potential ecological effects.
Use of the 90th percentile value in evaluating concentration data and trends
A member asked about the use of the 90th percentile concentration evaluating concentration data. The MDA explained that the 90th percentile concentration was selected for trend analysis due to the variability of the data; maximum concentrations also are evaluated separately along with any individual detections that exceed a reference value.
It was suggested that the MDA evaluate concentration data using the 95th percentile values instead of 90th percentile values, and the MDA agreed to consider this.
The reference value used to evaluate 4-hydroxychlorothalonil concentrations
A member asked if a Health Risk Limit (HRL) could be developed in place of the current Risk Assessment Advice (RAA) for chlorothalonil. The MDA explained that a HRL was requested; however, MDH was only able to develop RAA for the chemical due to limitations with the available toxicity data. The MDH representative further elaborated on the development and use of the RAA value.
Impacts of high rainfall on the groundwater well network
A member commented that we had above average rainfall in much of the state in 2024 and asked how that may have impacted the groundwater well network. The MDA replied that impacts can vary by region and that the groundwater network is relatively stable regardless of precipitation (compared to surface water).
Raj provided an update on treated seeds and MDA’s authority to take action to prevent unreasonable adverse effects. He explained that while MDA now has this authority, treated seeds will not be handled the same as pesticides. The MDA also received money for pollinator research which may be used to study pesticide treated seed.
Discussion focused on:
- Pesticides in precipitation
- A member expressed concerns over the presence of pesticides in rain and requested the report focus more on these results.
- Aquatic life benchmarks and water quality standards for neonicotinoids
- It was explained that MDA does not develop reference values and uses guidance from the MN Pollution Control Agency.
- Currently, there are no promulgated standards for neonics in surface water. The neonics are on the MPCA’s list of standards to develop; however, they have not been prioritized.
Raj provided an update on treated seeds and MDA’s authority to take action to prevent unreasonable adverse effects. He explained that while MDA now has this authority, treated seeds will not be handled the same as pesticides. The MDA also received money for pollinator research which may be used to study pesticide treated seed.
Discussion focused on:
- Pesticides in precipitation
- A member expressed concerns over the presence of pesticides in rain and requested the report focus more on these results.
- Aquatic life benchmarks and water quality standards for neonicotinoids
- It was explained that MDA does not develop reference values and uses guidance from the MN Pollution Control Agency.
- Currently, there are no promulgated standards for neonics in surface water. The neonics are on the MPCA’s list of standards to develop; however, they have not been prioritized.
MDA Presenter: Raj Mann and Dan Stoddard
The following updates from the MDA were provided:
- Pesticide Management Plan (PMP) Revisions - The MDA is in the process of revising the PMP. Significant revisions include developing a process for removal of pesticides from list of "common detection" or "surface water pesticide of concern" status, updating the statutory language referenced, and various other technical changes related to pesticides and agricultural technology. A draft of the revised PMP will be published in the state register for public comment along with a summary of changes (anticipated in late 2021).
- Chlorpyrifos Update - Several lawsuits have been filed for chlorpyrifos’s potential adverse effects on human health. Of particular interest is lawsuit filed in 2007 to revoke all chlorpyrifos tolerances and cancel all registrations based on adverse human health effects. The EPA denied this petition in 2019; however, in a ruling issued on April 29, 2021, the Ninth Circuit Court of Appeals vacated the 2019 denial of the petition and instructed the EPA to either modify chlorpyrifos’s tolerances and publish findings to show they are safe or to revoke all chlorpyrifos tolerances within 60 days. The decision on this from the EPA or 9th circuit court is awaited.
The MDA has an ongoing special registration review focused on chlorpyrifos in Minnesota (scoping document is available on the Pesticide Special Registration Reviews page.
- Legislative Report Recommendations - In 2020, there was an audit of the MDA’s pesticide programs. The audit report supported the continued monitoring of pesticides in water and recommended three additional analytes be added to the program (triphenyltin hydroxide, glufosinate-ammonium and ethylenethiourea [ETU]). Unfortunately, analysis of these chemicals by the MDA Lab is not feasible at this time based on available instrumentation and methodology. The MDA will continue to seek funding for lab equipment and explore analytical options.
- MDA Laboratory Funding - The MDA had a legislative proposal to increase pesticide registration fees that would generate approx. $2,251,000 per year from pesticide gross sales. These funds would have been used to (1) replace analytical equipment required to maintain critical laboratory services, (2) replace Clean Water funding, (3) create two new urban pesticide positions, and (4) provide the necessary resources for the MDA Lab to expand pesticide monitoring and include specific analytes recommended by the audit. Ultimately, the Lab received $600,000 in general funds through the agricultural budget bill in 2021. These funds will be used to update/replace existing equipment, but they are not sufficient to purchase additional new equipment.
MDA Presenter: Raj Mann and Dan Stoddard
The following updates from the MDA were provided:
- Pesticide Management Plan (PMP) Revisions - The MDA is in the process of revising the PMP. Significant revisions include developing a process for removal of pesticides from list of "common detection" or "surface water pesticide of concern" status, updating the statutory language referenced, and various other technical changes related to pesticides and agricultural technology. A draft of the revised PMP will be published in the state register for public comment along with a summary of changes (anticipated in late 2021).
- Chlorpyrifos Update - Several lawsuits have been filed for chlorpyrifos’s potential adverse effects on human health. Of particular interest is lawsuit filed in 2007 to revoke all chlorpyrifos tolerances and cancel all registrations based on adverse human health effects. The EPA denied this petition in 2019; however, in a ruling issued on April 29, 2021, the Ninth Circuit Court of Appeals vacated the 2019 denial of the petition and instructed the EPA to either modify chlorpyrifos’s tolerances and publish findings to show they are safe or to revoke all chlorpyrifos tolerances within 60 days. The decision on this from the EPA or 9th circuit court is awaited.
The MDA has an ongoing special registration review focused on chlorpyrifos in Minnesota (scoping document is available on the Pesticide Special Registration Reviews page.
- Legislative Report Recommendations - In 2020, there was an audit of the MDA’s pesticide programs. The audit report supported the continued monitoring of pesticides in water and recommended three additional analytes be added to the program (triphenyltin hydroxide, glufosinate-ammonium and ethylenethiourea [ETU]). Unfortunately, analysis of these chemicals by the MDA Lab is not feasible at this time based on available instrumentation and methodology. The MDA will continue to seek funding for lab equipment and explore analytical options.
- MDA Laboratory Funding - The MDA had a legislative proposal to increase pesticide registration fees that would generate approx. $2,251,000 per year from pesticide gross sales. These funds would have been used to (1) replace analytical equipment required to maintain critical laboratory services, (2) replace Clean Water funding, (3) create two new urban pesticide positions, and (4) provide the necessary resources for the MDA Lab to expand pesticide monitoring and include specific analytes recommended by the audit. Ultimately, the Lab received $600,000 in general funds through the agricultural budget bill in 2021. These funds will be used to update/replace existing equipment, but they are not sufficient to purchase additional new equipment.
Discussion topics included:
- The MDA’s investigation into potential propazine sources.
- Detections in surface water are likely the result of impurities in atrazine products. Propazine has not been sold in MN in over 30 years and detections correlated well with atrazine detections.
- This relationship between atrazine and propazine is unique and similar trends with other chemicals (particularly triazines) have not been observed.
- Sources of metribuzin detections outside of PMR 4 and method reporting limits (MRLs) for its main degradates.
- Detections have been limited and occur in different areas throughout the state. Because detections are erratic, the source has not been fully investigated by the MDA.
- Metribuzin has been making a reappearance as part of pre-emergence tank mixes to address resistant weeds in soybean.
- The MDA is not able to lower the MRLs for metribuzin and its degradates at this time.
- Availability of raw data for 4-hydroxychlorothalonil (report table only shows a single maximum concentration).
- Requested data was sent after the meeting. Raw data is also available through the Water Quality Portal.
- The MDA’s actions regarding increasing metolachlor trends in groundwater.
- The MDA is continuing to promote Water Quality Best Management Practices for Metolachlor (PDF).
- While some PMRs do show increasing trends, concentrations remain well below human health reference values in groundwater. The MDA will continue to carefully monitor metolachlor and its degradates.
- Increased metolachlor use is anticipated due to resistance issues with glyphosate and other herbicides.
- The continued use of Roundup-Ready crops despite the development of glyphosate-resistance.
- Growers are continuing to use Roundup-Ready crops and glyphosate is still an important part of weed management programs from corn and soybean.
- The new addition of piperonyl butoxide to the monitoring list and the lack of detections.
- Piperonyl butoxide is a synergist often used with pyrethroid insecticides. It has been detected by other monitoring programs, but it was not detected in 2020 by the MDA.
Discussion topics included:
- The MDA’s investigation into potential propazine sources.
- Detections in surface water are likely the result of impurities in atrazine products. Propazine has not been sold in MN in over 30 years and detections correlated well with atrazine detections.
- This relationship between atrazine and propazine is unique and similar trends with other chemicals (particularly triazines) have not been observed.
- Sources of metribuzin detections outside of PMR 4 and method reporting limits (MRLs) for its main degradates.
- Detections have been limited and occur in different areas throughout the state. Because detections are erratic, the source has not been fully investigated by the MDA.
- Metribuzin has been making a reappearance as part of pre-emergence tank mixes to address resistant weeds in soybean.
- The MDA is not able to lower the MRLs for metribuzin and its degradates at this time.
- Availability of raw data for 4-hydroxychlorothalonil (report table only shows a single maximum concentration).
- Requested data was sent after the meeting. Raw data is also available through the Water Quality Portal.
- The MDA’s actions regarding increasing metolachlor trends in groundwater.
- The MDA is continuing to promote Water Quality Best Management Practices for Metolachlor (PDF).
- While some PMRs do show increasing trends, concentrations remain well below human health reference values in groundwater. The MDA will continue to carefully monitor metolachlor and its degradates.
- Increased metolachlor use is anticipated due to resistance issues with glyphosate and other herbicides.
- The continued use of Roundup-Ready crops despite the development of glyphosate-resistance.
- Growers are continuing to use Roundup-Ready crops and glyphosate is still an important part of weed management programs from corn and soybean.
- The new addition of piperonyl butoxide to the monitoring list and the lack of detections.
- Piperonyl butoxide is a synergist often used with pyrethroid insecticides. It has been detected by other monitoring programs, but it was not detected in 2020 by the MDA.
Josh Stamper, MDA, welcomed participants to the meeting, explained the purpose of the committee, and emphasized the importance of discussion and member feedback. PMPC Members and MDA leadership introduced themselves.
Kate Hall (meeting facilitator), MDA, went through housekeeping items and presented background slides on PMPC. The presentation provided an overview of the MDA’s Pesticide Management Plan, “common detection” and “surface water pesticide of concern” designations, and select comments received from members the previous year. The MDA’s Indigenous Land Acknowledgement statement was read.
MDA Presenter: Dave Tollefson
The presentation provided an overview of the MDA’s monitoring program and introduced the main sections of the 2024 report. Changes to the 2024 analyte list were highlighted along with groundwater and surface water program design elements.
Questions/Comments:
A member asked if the MDA has looked at the effectiveness of reverse osmosis (RO) in removing any other herbicides beyond cyanazine and if it recommended for drinking water wells with elevated concentrations of 4-hydroxychlorothalonil. The MDA noted that RO is effective for many pesticides; however, the MDA does not have data on the effectiveness of RO for 4-hydroxychlorothalonil specifically.
- A member asked whether there was specific guidance for comparing detected concentrations to health-based guidance values when evaluating pesticides for common detection status. The MDA explained that the guidance in the Pesticide Management Plan lists several factors to consider in evaluating a pesticide for common detection status, including concentration. However, no specific thresholds are given (e.g., 50% of a reference value). The member expressed a need for more clear language about considering concentrations with respect to health-based values.
A member noted that the Pesticide Management Plan deals with water but ignores the nonaquatic environment despite the impacts of pesticides on land. The MDA clarified that the Pesticide Management Plan and the PMPC, which was established by the plan, is intentionally focused on water quality and that impacts of pesticides outside this context is beyond the scope of the meeting.
MDA Presenter: Kim Kaiser
The presentation focused on the groundwater results from the 2024 monitoring season. Current common detection pesticides were reviewed, and trend maps were presented showing changes in detection frequency and concentration for individual pesticide monitoring regions (PMRs). Highlighted topics included: pesticides detected in PMR 4 (Central Sands), detections of 4-hydroxychlororthalonil and neonicotinoids, and detections of cyanazine degradates in private wells.
Following the main presentation, Kate Hall briefly shared additional background on chlorothalonil and recent EPA actions (e.g., reducing allowable rates). MDA actions being taken to better understand and address detections of the chlorothalonil degradate, 4-hydroxychlorothalonil, in groundwater were also highlighted (e.g., expanding monitoring, developing best management practices).
Discussion focused on:
How pesticide use patterns relate to groundwater detections
When concentrations of parent and degradate compounds should be treated as additive
The ecological effects of atrazine and cyanazine and historical concerns
Historical concerns over atrazine’s effects on frogs were discussed along with the data supporting/not supporting the claims. The MDA noted that it previously conducted a special registration review on atrazine that goes into more detail on its potential ecological effects.
Use of the 90th percentile value in evaluating concentration data and trends
A member asked about the use of the 90th percentile concentration evaluating concentration data. The MDA explained that the 90th percentile concentration was selected for trend analysis due to the variability of the data; maximum concentrations also are evaluated separately along with any individual detections that exceed a reference value.
It was suggested that the MDA evaluate concentration data using the 95th percentile values instead of 90th percentile values, and the MDA agreed to consider this.
The reference value used to evaluate 4-hydroxychlorothalonil concentrations
A member asked if a Health Risk Limit (HRL) could be developed in place of the current Risk Assessment Advice (RAA) for chlorothalonil. The MDA explained that a HRL was requested; however, MDH was only able to develop RAA for the chemical due to limitations with the available toxicity data. The MDH representative further elaborated on the development and use of the RAA value.
Impacts of high rainfall on the groundwater well network
A member commented that we had above average rainfall in much of the state in 2024 and asked how that may have impacted the groundwater well network. The MDA replied that impacts can vary by region and that the groundwater network is relatively stable regardless of precipitation (compared to surface water).
MDA Presenter: Matt Ribikawskis & Dave Tollefson
The presentation focused on the surface water results from the 2024 monitoring season. Pesticide waterbody impairments were presented along with an overview of how Minnesota water quality standards are used to evaluate data. Current surface water pesticides of concern were reviewed, and trend maps were presented showing changes in detection frequency and concentration for individual PMRs. Comparisons of detected concentrations to relevant standards or guidance values (i.e., reference values) also were presented, focusing on pesticides detected at concentrations >10% and >50% of relevant reference values. Additionally, analyses of 21-day duration concentrations and detection seasonality were presented for the neonicotinoid (neonic) insecticides clothianidin and imidacloprid.
Following the main presentation, Kate Hall briefly reviewed monitoring highlights for acetochlor, clothianidin, and imidacloprid and provided additional background on the MDA’s actions to mitigate detections in surface water.
Discussion focused on:
Development of water quality standards for neonics by the Minnesota Pollution Control Agency (MPCA) and the current use of Environmental Protection Agency (EPA) aquatic life benchmarks as guidance to evaluation detected concentrations
A member asked about the estimated timeline for the MPCA to develop water quality standards that could be used to evaluate neonic concentrations in surface water. It was explained that both clothianidin and imidacloprid were included in the MPCA’s Triennial Standards Review as candidates for rulemaking (i.e., standard development and adoption).
Another member asked if water quality standards create additional regulations. The MDA explained how it uses the EPA aquatic life benchmarks as guidance, but water quality standards are required to list a waterbody as impaired. Waterbody impairments initiate the total maximum daily load process by the MPCA or the development of response plans for targeted inspections, education, and possible restrictions by the MDA.
Status of aquatic insects in neonic-impacted streams and the coordination of aquatic invertebrate monitoring with pesticide monitoring
A member asked about how aquatic insects are doing in neonic-impacted streams and whether there is any data of note. A toxicologist from the MPCA, which conducts aquatic invertebrate monitoring, responded that there is nothing conclusive yet, but there appear to be some trends. The MDA added that not a lot of the pesticide monitoring stations are at the same location as invertebrate monitoring, but they are working on trying to get more coordinated data.
Evaluating the effectiveness of the MDA’s voluntary clothianidin/imidacloprid best management practices (BMPs) and the general timeline for when effects may be measurable
A member asked what the MDA’s plan and timeline is to evaluate the effectiveness of the water quality BMPs for clothianidin and imidacloprid that were published in February 2023. The MDA replied that they do not have a specific timeline but are continuing to track trends and promote the BMPs.
A member asked how long it typically takes to see changes in surface water detections and concentrations after BMPs are published. The MDA explained that it can take years depending on the nature or use and outreach, and impacts can also be site specific.
The contribution of neonic-treated seed to detections of neonics in surface waters
Regulatory authority over neonic-treated seeds and options for regulatory action
The complexity of regulating treated seed at the state level was discussed. It was noted that certain decisions are up to the commissioner, and a recent audit of the MDA’s pesticide programs requested that the legislature address treated seeds.
Monitoring of per- and polyfluoroalkyl substances (PFAS) and Minnesota’s regulation of intentionally added PFAS in pesticide products
- A member asked if the MDA would begin monitoring for PFAS. The MDA noted that a handful of the active ingredients and degradates monitored would be considered PFAS under Minnesota’s definition. Regulations surrounding intentionally added PFAS in pesticide products were explained along with the opportunity for currently unavoidable use exemptions. Additional information is available on the MDA’s PFAS website and in the MDA’s report to the legislature on PFAS in pesticides.