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Subpoenas Being Issued to Aerial Applicators and Other Entities Regarding Paraquat Use

The multi district court litigation being filed by plaintiffs (Paraquat Products Liability Litigation) in various states against Syngenta Crop Protection over the pesticide paraquat has resulted in plaintiffs broadly issuing subpoenas throughout the country to possible users of the restricted use herbicide. Generally speaking, the subpoenas ask for the submission of paraquat use, purchases and certification of the restricted use herbicide. NAAA was presented with a subpoena and responded to the environmental law firm issuing it on behalf of the plaintiffs that the association does not apply pesticides, hence has no data to submit.

The case is currently in the United States District Court for the Southern District of Illinois. The Court told the plaintiffs that proof of harm must be shown and it set a date for information requests to be issued by March 11, 2024. Many of the subpoenas issued by mail have postage dated on or around this date. The NAAA subpoena was issued by the Law Offices of Environmental Litigation Group, P.C. located in Birmingham, Alabama. 

Recipients of the subpoena should respond to the subpoena. The subpoenas differ somewhat from one another and the determination of what to provide or not provide is an individualized determination. Neither NAAA nor Syngenta can provide legal advice in how to respond to the subpoenas. If you have no records pertinent to the subpoena after conducting a reasonable inquiry, communicate accordingly to the plaintiff’s attorney. If the request for information is unreasonable, communicate with the plaintiff’s attorney listed on the subpoena that the request is unreasonable. In other words, make a good faith effort to see if a reasonable information can be provided.  
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EPA Provides Update on Existing Stock for Three Chlorpyrifos Products

In 2024 chlorpyrifos can be legally applied to all crops it was formally labeled for use on. This follows the U.S. Court of Appeals for the Eighth Circuit overturning EPA’s 2021 ban on chlorpyrifos at the end of 2023.

When the 2021 ban went into effect, pesticide manufacturers began canceling their registrations for products containing chlorpyrifos. Now that chlorpyrifos is legal again, registrants are working with EPA to ensure existing stocks of those chlorpyrifos products can be used even if the manufacturer had previously canceled the registrations. 

Last week EPA issued an update on existing stock provisions for three chlorpyrifos products from Adama:

  • Sale and distribution of existing stocks of Pyrinex Chlorpyrifos Insecticide (EPA Reg. No. 11678-58) is permitted until June 30, 2024.
  • Sale and distribution of existing stocks of Chlorpyrifos 4E AG/Quali-Pro Chlorpyrifos 4E (EPA Reg. No. 66222-19) and Vulcan (EPA Reg. Nos. 66222-233) is permitted until April 30, 2025.
  • Use of existing stocks of Chlorpyrifos 4E AG/Quali-Pro Chlorpyrifos 4E, and Vulcan on food, food processing sites, and food manufacturing sites must be consistent with the product labeling. Such use is permitted until June 30, 2025.
  • Use of existing stocks Chlorpyrifos 4E AG/Quali-Pro Chlorpyrifos 4E, and Vulcan for non-food purposes is permitted until existing stocks are exhausted, as long as such use is in accordance with the labeling.

In 2025, chlorpyrifos will be restricted to only the following crops: alfalfa, apple, asparagus, cherry (tart), citrus, cotton, peach, soybean, strawberry, sugar beet, spring wheat, and winter wheat. This will be based on an amended proposed interim decision EPA is currently working on and expects to release in early 2025. NAAA is in communication with grower groups and registrants working on making sure aerial application is on the label for all of those crop and will continue to monitor all developments related to chlorpyrifos. 


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Flying in the Wire and Obstruction Environment Course will be held Saturday, Nov. 16

After two years of popularity, NAAA and NAAREF are bringing back the Flying in the Wire and Obstruction Environment Course on Saturday, November 16 beginning at 7:30 a.m. in Fort Worth, Texas. This course will be taught on the Saturday before the start of the 2024 Ag Aviation Expo, Nov. 18-21. Registration will open in July, but if you plan to attend the course, please book your hotel room to arrive on Friday, Nov. 15. For hotel booking details, click here; contact Lindsay Barber with any questions or hotel booking issues.

Flying in the Wire and Obstruction Environment Course, acclaimed by professional airplane and helicopter operators worldwide. This year’s course will be a full-day course again. The instructors give low-altitude aviators the essential skills needed to safely operate an aircraft in wire and obstruction environments. This course is for both aircraft and helicopter pilots. Learn how to identify signs of wires and why ag aviators hit wires they already knew were there. This course may very well save your life – wire strike accidents continue to harm the ag aviation industry. The most common cause of accidents in 2023 were wire strikes. They accounted for 28% of the total accidents and 67% of the fatal accidents.

The course will be taught by Utilities / Aviation Specialists Inc. (UAS), a unique group of aviation safety practitioners who provide safety auditing, specialized training, installation of safety management systems, and technical aviation consulting. They provide mission-specific expertise in specialized applications that require skill sets above those found in most routine transport operations. Sponsored by Old Republic Aerospace.
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