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Weed Science Societies’ Comments on EPA’s Proposed Herbicide Resistance Management Plan and Tank Mix Prohibitions


The Weed Science Society of America (WSSA) and its affiliates, the Aquatic Plant Management Society, the Northeastern Weed Science Society, the North Central Weed Science Society, the Southern Weed Science Society, and the Western Society of Weed Science recently commented on certain aspects of two proposed herbicide registrations that have broad implications for weed management. The following three documents were submitted to EPA in May 2016.

  • 1) Comments on a Proposed New Herbicide Resistance Management Plan
    The proposal presents a significant change in how resistance is monitored, mitigated and communicated to weed management stakeholders. While the National and Regional Weed Science Societies compliment EPA on these proactive resistance management measures, we provide many suggestions and recommendations on how to improve the plan.  It will be important for EPA to communicate to the agricultural community what their expectations are for the plan, how much it will cost to implement, and how will success (and failure) be measured.  In addition, we consider the plan a first iteration that will need adaptation and evolution with our experience with it.
  • 2) Comments on the Tank Mix Prohibitions, In-field Buffer Requirements, and Use of Only a Single Nozzle in the Proposed Registration for Dicamba-Tolerant Cotton and Soybean
    The National and Regional Weed Science Societies are especially concerned about the proposed tank mix prohibition due to EPA uncertainty on synergism effects on non-target organisms.  We urge EPA to reconsider this prohibition, as it is counterproductive for herbicide resistance management, will result in significant economic costs to growers, will increase the carbon-footprint associated with weed management, and could be, frankly, ignored by many practitioners.
  • 3) Comments on the Tank Mix Prohibition for the Proposed Registration for Halauxifen-methyl
    Again, the National and Regional Weed Science Societies highlight their concerns and objections to the proposed tank mix prohibition for the proposed registration for halauxifen-methyl.