Spray drift labelling

In February 2010, the APVMA issued a notice announcing changes to previous label conventions for statements related to spray drift management, and explaining how those changes should be implemented. The changes came into effect on 1 March 2010, and are an extension of the APVMA’s spray drift policy framework (see APVMA operating principles in relation to spray drift risk (PDF, 560kb), published in July 2008), its linked regulatory impact statement and further supporting technical information published in September 2008. View further information on spray drift.

A supplementary notice was issued in November 2010. That notice provided additional information in relation to the APVMA’s spray drift risk management; it does not negate any information or requirements in the previous notice.

The APVMA has now incorporated the requirements relating to labels set out in these notices into this part of the Agricultural Labelling Code.

As new scientific information becomes available the APVMA will revise the Agricultural Labelling Code accordingly.

1.1. Requirement for registration applications to nominate a specific spray droplet size category that must appear on product labels

All registration applications for agricultural chemical products that are subject to spray drift (view further information on spray drift) must include a nominated spray droplet size category for product application on the product label. You must nominate the largest droplet size category that is still consistent with the efficacy of the product. Note this requirement applies only to products with a use pattern for ground or air boom application equipment; it does not apply to use patterns for orchard/vineyard airblast equipment.

The APVMA assesses the risk related to spray drift based on consideration of the nominated spray droplet size category. When protective no-spray zones are required for a product, these zones depend on droplet size—smaller droplet size categories result in larger no-spray zones than do larger droplet size categories. Therefore, it is in the applicant’s interest to nominate the largest possible droplet size category that is consistent with product efficacy.

You must select droplet size categories from the following set of standard categories according to nozzle manufacturer specifications that refer to the ASAE S572 Standard or the British Crop Production Council guideline:

  • very fine
  • fine
  • medium
  • coarse
  • very coarse
  • extremely coarse.

You can only nominate one droplet size category. We will not accept terminology such as ‘fine to medium’ or ‘medium to coarse’.

Also, unless specified otherwise below, we will not accept statements of droplet size or size ranges in microns for use on labels.

1.1.1. How the nominated droplet size category will be used

The APVMA will use the specified droplet size category to complete its spray drift risk assessment. The same category will then be placed on the product label in a spray drift restraint statement that prohibits chemical users from using any smaller droplet size category in spray applications.

1.1.2. Exceptional cases

In most cases there should be only one droplet size category on the label for both ground and aerial application. However, in exceptional cases supported by satisfactory scientific data or argument, we may allow different droplet size categories for aerial and ground application. In such cases, the normal single-label restraint statement for droplet size will need to be presented as two statements—one version for aerial and another for ground application. The wording of the two statements should begin as follows.

DO NOT apply with AIRCRAFT with smaller than …

DO NOT apply with GROUND sprayers with smaller than …

1.2. Requirement for registration applications to inform the APVMA about the use of aerial application

All registration applications for agricultural chemical products that are subject to spray drift (view further information on spray drift) must inform us whether or not the aerial application of the product is intended and, if so, whether it is to be with a fixed-wing aircraft or with a helicopter, or both. Based on this information, we will undertake the appropriate spray drift risk assessments.

If you inform us that the product does not support application by air, or that it does not support application with fixed-wing aircraft or with helicopter, we will require one of the following restraint statements on the label, as appropriate.

DO NOT apply with aircraft

DO NOT apply with fixed-wing aircraft

DO NOT apply with helicopter

Where one of these global restraint statements is needed, it must be located at the beginning of the general ‘Restraints’ section of the label.

2. Required label format and wording for spray drift restraint statements and no-spray zones

2.1. Label placement of spray drift restraints and no-spray zones

Restraint statements for spray drift must be placed near the beginning of the ‘Directions for use’ section of the label, immediately following any existing general ‘Restraints’. They must be placed under the title:

SPRAY DRIFT RESTRAINTS

When a product requires no-spray zones, restraint statements and tables for no-spray zones must be placed immediately following the ‘Spray drift restraints’ section and under the title:

MANDATORY NO-SPRAY ZONES

The general example label below shows how wording should be placed.

2.2. Wording for spray drift restraints and no-spray zones

You must follow the specific wording for statements about spray drift restraints and no-spray zone restraints that are presented in this notice on all relevant labels. These statements have been developed in consultation with state and territory enforcement authorities, and their wording must be maintained exactly to ensure they can be enforced.

All products that require one or more no-spray zones will also require at least four restraint statements on spray drift that specify the required droplet size for application, specify wind speed limits, prohibit spraying during temperature inversion conditions and specify how required application records must be kept. The example label below shows the exact wording to be used for each of these four statements.

Note that the restraint statement on wind speed in the example specifies 3 to 20 kilometres per hour (km/h). Most products will use this restraint, but some (for example, products in the 2,4-D family and other phenoxy herbicides) will have an upper wind speed limit of 15 km/h.

The APVMA may require additional spray drift restraints for higher-risk products or products with special properties. These will be dealt with on a case-by-case basis.

Products that do not require any no-spray zones may have a reduced set of spray drift restraints, depending on the risk assessment. Such products will be considered on a case-by-case basis.

2.3. Additional information for the droplet size restraint statement

There are two label versions of the statement about spray drift restraints that require a specific droplet size category.

One version is for coarse, very coarse and extremely coarse droplet size categories (see Example 1). This version always requires a separate instruction module to accompany it on the label, but that module must be located elsewhere under the ‘general instructions’ section of the label. This separate instruction module explains to users how they must comply with the ‘coarse’ or larger droplet size requirement. This instruction module is presented below, and its wording must be exactly preserved on product labels.

The second version of the droplet size restraint statement is for products that require a ‘medium’, ‘fine’ or ‘very fine’ droplet size category. This version of the statement is simpler and does not require an additional set of instructions to accompany it elsewhere on the label.

An example of each version is presented below. For both examples, wording must be preserved exactly as shown, apart from variation of the category itself.

2.3.1. Example 1: Wording for coarse or larger droplet size categories—this example for coarse

DO NOT apply with spray droplets smaller than a COARSE spray droplet size category according to ‘APVMA Compliance Instructions for Mandatory COARSE or Larger Droplet Size Categories’ located under this title in the GENERAL INSTRUCTIONS section of this label.

2.3.2. Example 2: Wording for medium or smaller droplet size categories—this example for medium

DO NOT apply with spray droplets smaller than a MEDIUM spray droplet size category according to nozzle manufacturer specifications that refer to the ASAE S572 Standard or the British Crop Production Council guideline.

Note: For products that have labels that provide for both ground or air boom spraying and for orchard/vineyard airblast applications, the following phrase should appear at the beginning of the statement on spray drift restraint for droplet size:

Except when applying with orchard/vineyard airblast equipment

If there is no use pattern for ground or air boom application equipment then there should be no statement in the spray drift restraints section of the label related to mandatory droplet size requirements. For use patterns for orchard/vineyard airblast equipment, any information about droplet size (i.e. where a certain droplet size is required or recommended for efficacy reasons) should appear in the critical comments section of the Directions for Use table or the application section of the general instructions, not in the spray drift restraints section.

2.4. Additional information for mandatory no-spray zones

Whether a product requires a no-spray zone, and whether it requires one or several zones, depends on its individual risk assessment. A no-spray zone might be required to protect human health, the aquatic environment, the terrestrial environment, or Australia’s international trade (due to residue issues). The wording of no-spray zone restraint statements must exactly follow the wording in Example 3 below.

Each of the no-spray zone restraint statements exists in two versions—one for labels that allow aerial application (Example 3) and the other for labels that allow only ground application (Example 4).

The wording in the tables in Example 3 (for aerial applications) must be followed exactly, apart from the various no-spray zone distances that will differ from product to product.

The APVMA’s spray drift deposition data sources provide validated spray drift deposition information to a downwind distance of approximately 300 metres for ground applications and 800 metres for aerial applications. These distances are the maximum that the APVMA will set on labels as no-spray zones.

For products and uses where spray drift risk assessment shows that no-spray zones greater than 300 metres for ground and 800 metres for aerial application would be necessary to meet acceptable risk thresholds for the APVMA to be satisfied, then the application will be refused in accordance with the Agvet Code. An applicant may make a new application at any time that addresses the deficiencies that resulted in the APVMA not being satisfied and refusing the original application.

2.4.1. Example 3: Label excerpt showing formatting and wording of restraint statements—example with aerial application

This example shows some ordinary restraint statements, tailored to a particular product and deal with efficacy issues or other global restraints. These statements are immediately followed by spray drift restraints.

BOOKLET (cont’d)

DIRECTIONS FOR USE
RESTRAINTS

DO NOT xxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxx
DO NOT xxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxx
DO NOT xxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxx
DO NOT xxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxx

SPRAY DRIFT RESTRAINTS
Except when applying with orchard/vineyard airblast equipment, DO NOT apply with spray droplets smaller than a COARSE spray droplet size category according to APVMA compliance instructions for mandatory COARSE or larger droplet size categories’ located under this title in the GENERAL INSTRUCTIONS section of this label.
DO NOT apply when wind speed is less than 3 or more than 20 kilometres per hour, as measured at the application site.
DO NOT apply during surface temperature inversion conditions at the application site.

Users of this product MUST make an accurate written record of the details of each spray application within 24 hours following application, and must KEEP this record for at least 2 years. The spray application details that must be recorded are:
1 date with start and finish times of application 2 location address and paddock(s) sprayed 3 full name of this product 4 amount of product used per hectare and number of hectares applied to 5 crop or situation and weed or pest 6 wind speed and direction during application 7 air temperature and relative humidity during application 8 nozzle brand, type, spray angle, nozzle capacity and spray system pressure measured during application 9 name and address of person applying this product. (Additional record details may be required by the state or territory where this product is used.)

MANDATORY NO-SPRAY ZONES
DO NOT apply the product if there are people, structures that people occupy, or parks and recreation areas downwind from the application area and within the mandatory no-spray zones shown in Table 1 below.

Table 1: No-spray zones for protection of human health
For aerial application
Wind speed range at time of application Downwind mandatory no-spray zone
Fixed-wing Helicopter
from 3 to 8 kilometres per hour [x] metres [m] metres
from 8 to 14 kilometres per hour [y] metres [p] metres
from 14 to 20 kilometres per hour [z] metres [q] metres
For ground application

from 3 to 20 kilometres per hour

[w] metres

DO NOT apply if there are aquatic and wetland areas including aquacultural ponds, surface streams and rivers downwind from the application area and within the mandatory no-spray zones shown in Table 2 below.

Table 2: No-spray zones for protection of the aquatic environment
For aerial application
Wind speed range at time of application Downwind mandatory no-spray zone
Fixed-wing Helicopter
from 3 to 8 kilometres per hour [x] metres [m] metres
from 8 to 14 kilometres per hour [y] metres [p] metres
from 14 to 20 kilometres per hour [z] metres [q] metres
For ground application
from 3 to 20 kilometres per hour [w] metres

DO NOT apply if there are sensitive crops, gardens, landscaping vegetation, protected native vegetation or protected animal habitat downwind from the application area and within the mandatory no-spray zones shown in Table 3 below.

Table 3: No-spray zones for protection of the terrestrial environment
For aerial application
Wind speed range at time of application Downwind mandatory no-spray zone
Fixed-wing Helicopter
from 3 to 8 kilometres per hour [x]metres [m] metres
from 8 to 14 kilometres per hour [y] metres [p] metres
from 14 to 20 kilometres per hour [z] metres [q] metres
For ground application
from 3 to 20 kilometres per hour [w] metres

DO NOT apply if there are livestock, pasture or any land that is producing feed for livestock downwind from the application area and within the mandatory no-spray zones shown in Table 4 below.

Table 4: No-spray Zones for Protection of International Trade
For aerial application
Wind speed range at time of application Downwind mandatory no-spray zone
Fixed-wing Helicopter
from 3 to 8 kilometres per hour [x] metres [m] metres
from 8 to 14 kilometres per hour [y] metres [p] metres
from 14 to 20 kilometres per hour [z] metres [q] metres
For ground application
from 3 to 20 kilometres per hour [w] metres

2.4.2. Example 4: Mandatory no-spray zone statements for products that cannot be used for aerial application

MANDATORY NO-SPRAY ZONES
DO NOT apply if there are people, structures that people occupy, or parks and recreation areas within [x] metres downwind from the application area.
DO NOT apply if there are aquatic and wetland areas including aquacultural ponds, surface streams and rivers within [y] metres downwind from the application area.
DO NOT apply if there are sensitive crops, gardens, landscaping vegetation, protected native vegetation or protected animal habitat within [z] metres downwind from the application area.
DO NOT apply if there are livestock, pasture or any land that is producing feed for livestock within [u] metres downwind from the application area.
NOTE: following the ‘Mandatory no-spray zone’ section, the normal crop directions begin.

2.5. Additional module of instructions—spray drift restraint that requires a coarse or larger droplet size category

The module of instructions set out in Example 5 must appear on all labels that also carry a spray drift restraint that requires a coarse or larger droplet size category. It must be located under the ‘General instructions’ section of the label, as indicated by the spray drift restraint for ‘coarse’ or larger droplet size categories that also appears on the label. It must appear with its full title as shown below and in a form that is consistent with the wording in its linked spray drift restraint statement.

2.5.1. Example 5: Instructions for spray drift restraint that requires a ‘coarse' or larger droplet size category

You must use wording on the label exactly as shown here.

APVMA compliance instructions for mandatory COARSE or larger droplet size categories

Important information

These instructions inform those using this chemical product how to lawfully comply with the requirement of a COARSE or larger spray droplet size category for spray application.

Spray droplet size categories are defined in the ASAE S572 Standard (newer name may also be shown as ASABE) or the BCPC guideline. Nozzle manufacturers may refer to one or both of these documents, to identify droplet size categories; however, for a nozzle to comply with this requirement, the manufacturer must refer to at least one.

Complying with the label requirement to use a specific droplet size category means using the correct nozzle that will deliver that droplet size category under the spray operation conditions being used. The APVMA has approved only the following specific methods for choosing the correct nozzle. Use one of the methods specified in these instructions to select a correct nozzle to deliver a COARSE or larger droplet size category.

Instructions for ground application—for COARSE droplet size or larger categories
Mandatory instructions for ground applications

USE ONLY nozzles that the nozzles’ manufacturer has rated to deliver a COARSE, a VERY COARSE or an EXTREMELY COARSE droplet size category, as referenced in ASAE S572 or BCPC. Choose a nozzle that is 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.

Instructions for fixed-wing aerial application—for COARSE droplet size or larger categories
Instructions in this section apply to fixed-wing aerial application of products for which the label Spray Drift Restraint requires a COARSE or a VERY COARSE spray droplet category.
Nozzle choices must be made using Option 1, 2 or 3 below. Option 1 nozzles are limited to a maximum aircraft speed of 110 knots and are for COARSE droplets only. Option 2 nozzles are limited to a maximum aircraft speed of 120 knots and are also for COARSE droplets only. Option 3 nozzles have their use conditions (maximum airspeed, nozzle spray angle, product used, orifice size and spray system pressure) specified in the APVMA Approved Aerial Agricultural Association of Australia (AAAA) Nozzle Calculator (described in Option 3). Depending on those use conditions, the calculator can identify a correct nozzle for either a COARSE or a VERY COARSE spray droplet category. (To use Option 3, aerial applicators must contact the AAAA for access to their approved nozzle calculator.)

Mandatory instructions for fixed-wing aerial applications
Option 1

For up to a maximum aircraft speed of 110 knots and a COARSE droplet size category, USE ONLY solid stream 0º nozzles with orifice diameter greater than or equal to 1.5 mm and oriented straight back to the flight direction. USE ONLY a spray system pressure greater than or equal to 3 bar.

Mandatory Instructions for fixed-wing aerial applications (continued)
Option 2

For up to a maximum aircraft speed of 120 knots and a COARSE droplet size category, USE ONLY narrow angle flat fan nozzles with spray angle less than or equal to 40˚ and oriented straight back to the flight direction. USE ONLY a spray system pressure greater than or equal to 4 bar.

Mandatory instructions for fixed-wing aerial applications (continued)
Option 3

USE ONLY nozzles rated by the APVMA Approved AAAA Nozzle Calculator as COARSE or VERY COARSE to comply with a product label’s requirement for a COARSE or a VERY COARSE spray droplet size category. Use the AAAA Nozzle Calculator, and follow the additional instructions below in a), b) and c).
a)   To identify a nozzle to comply with the required spray droplet category, aerial applicators must use only the droplet size category given in the nozzle calculator at the DV(0.1) position. The categories shown at the DV(0.5) and the DV(0.9) positions in the calculator must not be used for making a nozzle selection.
b)   Aerial applicators must not apply the product at airspeeds greater than the speed used to select the nozzle. If an application airspeed that is slower than 100 knots (the minimum speed specified in the nozzle calculator) is planned, a nozzle identified as COARSE or VERY COARSE at 100 knots can also be used at these slower airspeeds, provided that the nozzle angle and system pressure are kept the same.
c)    When a particular pesticide product is chosen within the nozzle calculator as one of the conditions set to select a nozzle, then aerial applicators must use that specific pesticide product with that nozzle. When a pesticide product is planned for use and is not available as a choice within the nozzle calculator, aerial applicators must use the category ‘Other product’ in the calculator to set the condition for selecting a nozzle.

Instructions for helicopter aerial application—for COARSE droplet size or larger categories
Instructions in this section apply to helicopter application of products where the label Spray Drift Restraint requires a COARSE, a VERY COARSE or an EXTREMELY COARSE spray droplet category.
Nozzle choices must be made using Option 1, 2 or 3 below.

Mandatory instructions for helicopter aerial application
Option 1

For helicopter applications requiring a COARSE or a VERY COARSE spray droplet size category, USE ONLY nozzles selected with the methods previously specified for fixed-wing aircraft in Section 2.

Mandatory instructions for helicopter aerial Application (continued)
Option 2

When using Micronair controlled droplet applicators (Micron Sprayers Ltd), USE ONLY nozzles selected with the Micronair Droplet Size Prediction Models designed for Micronair products (and located on the company website) to choose a nozzle to satisfy the label requirement for a COARSE droplet size category. Important: to qualify for the COARSE category, the DV(0.1) value must be greater than 156 microns. Adjust parameters as necessary (eg lower the atomizer rotation rate) in order to achieve a DV(0.1) value greater than 156 microns.

Mandatory instructions for helicopter aerial application (continued)
Option 3

When using Accu-Flo nozzles (Bishop Equipment Mfg Inc), USE ONLY nozzles rated according to the manufacturer’s instructions to select the correct nozzle to apply a COARSE, a VERY COARSE or an EXTREMELY COARSE droplet size category to satisfy the label requirement for one of those specific droplet size categories.

 

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