Cotton is particularly sensitive to spray drift from Group I herbicides (phenoxy herbicides including 2,4-D). In 2018, while less than 10% of the Australian cotton crop was reported as impacted by spray drift, the financial impact was significant - costing an estimated $18 million in production losses.

Suffering spray drift damage is frustrating and has a detrimental financial impact on our growers, which is why Cotton Australia has continued to invest considerable time and funds into tackling the issue. Off-target spray drift is an issue affecting all of agriculture across a range of pesticides. It is important for all of Australian agriculture that we remain vigilant to protect our farms and the ongoing access to key chemicals.

Each season, Cotton Australia’s policy and communications teams work to devise and implement strategic awareness campaigns around spray drift and best practice for spraying. Cotton Australia works closely with cotton growers, spray applicators, chemical registrants, resellers, regulators and other agricultural industries to develop and deliver the campaigns.

Campaigns include:

• Supporting growers to report spray drift incidents, and keeping an industry log of incidents that have occurred.
• Working collaboratively with stakeholders within the cotton industry and other agricultural sectors to understand, navigate and assist growers through the challenges faced when planning spraying activities.
• Delivering training and workshops on spray application best practice.
• Delivering a targeted media campaign through a range of networks in cropping areas.
• Cotton Australia leading the promotion of SataCrop, a mapping tool informing all stakeholders of the location of potentially sensitive crops.

It is critical that growers report any incident, or suspected incident, as soon as it occurs to their closest Cotton Australia Regional Manager and fill out a Cotton Australia Spray Drift Incident Report. It is essential that incidents are properly logged and investigated, and Cotton Australia has a straightforward process that is simple and confidential. It is important that we know if incidents occur in order to make representations on behalf of the industry. While Cotton Australia cannot take legal action, provide professional advice or submit adverse experience reports to regulatory authorities, we can point growers in the right direction and tailor spray drift awareness initiatives into key areas based on feedback received by growers.

Growers whose crops have been damaged by off-target spray drift should report it to the relevant authorities in their state:

• NSW: EPA Environment Line: 131-555
• Queensland: Biosecurity Queensland: 132-523
• Victoria: Chemical Standards Officer: (03) 5430-4463, or email [email protected]

SataCrop is a tool to mitigate the risk of spray drift by allowing operators to understand where sensitive crops are located in proximity to their spray operation.

The SataCrop tool is an industry initiative developed by Cotton Australia and Precision Cropping Technologies (PCT).

SataCrop has the ability to map all crop types, including cotton, grains and tree crops. Growers can log in and plot the location of fields they have planted with different crops each season. Other farmers and spray contractors can review the site when planning spray applications to see the location of potentially sensitive neighbouring crops. This, coupled with vigilance around spray conditions, wind directions, and application helps to reduce adverse effects of spray drift.

In October 2018, the APVMA suspended the labels of all products containing the active ingredient 2,4-D and replaced them with a permit.

This action was taken in response to widespread damage to sensitive crops over several years, including grapes, other horticultural crops, summer pulses and cotton.

The new instructions for use include:

• A requirement not to spray in inversion conditions and additional information on recognising inversion conditions.
• Downwind mandatory no-spray zones for both aquatic and terrestrial off-target vegetation (including sensitive crops, gardens, landscaping vegetation, protected native vegetation or protected animal habitat).
• A requirement to use nozzles producing droplets no smaller than the very course spray quality category.
• Mandatory record keeping requirements.
• Advisory statements about spray application over summer.

A Summer Weed Control Best Practice Guide is available for growers, employees, contractors and agronomists to provide guidelines for the safe and effective application of herbicides in summer. The guide provides advice on how to recognise a surface temperature inversion and provides recommendations to minimise risk of spray drift by avoiding spraying under inversion or still conditions. Additionally, the guide provides advice on monitoring weather conditions and proper record keeping processes.

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It is important growers and spray applicators understand the risks around spray inversions, how they are formed, and how to avoid them. Visit this website for more tools and publications around spray drift, which includes a handy document produced by Nufarm - the '24 Hour Risk Profile for Summer Spraying' - which can be used for reference.

Cotton Australia remains committed to its current activities aimed at improving best practice spray application and reducing off target drift. These include spray application training, SataCrop, media campaigns inc. radio ads and print stories, and collaboration with other industry groups and stakeholders. However, the current season has seen a significant increase in the number of incidences of spray drift on cotton crops across all regions from the use of Group 4 herbicides (e.g. 2,4D, dicamba, amine, garlon). This has prompted Cotton Australia to advocate for more to be done to reduce the risk of off target spray drift resulting from these products.

Cotton Australia is requesting your feedback on the following options aimed at reducing the risk of spray drift from Group 4 herbicides. Cotton Australia recognises that these herbicides play an important role in weed control, and the proposed options are aimed not only at reducing spray drift risk, but also ensuring access to these products is maintained to be used responsibly when required.

Call for Immediate Action: Mandatory Neighbour Notification

• Neighbour notification must be provided xx hr prior to application. Notification could be via text, email or the use of a web based system where sprays are logged. Include all neighbours up to xx km radius.
• Notification could also be provided to state regulators.

Call for Immediate Action: Permit System

A permit must be obtained for the supply and application of Group 4 herbicides. To obtain a permit the following conditions must be met:

• Proof of completion of approved spray application training course (TBD)
• Record of supply of product at reseller
• Record of application (standardised format provided)
• Neighbour notification must be provided xx hr prior to application. Notification via text message/ email/app up to xx km distance

Permit system should be mandated by inclusion on all labels for Group 4 herbicides by the APVMA. Permit system could apply to specific regions/exclusion zones and specific dates (e.g. Oct- March).

Resellers must be able to provide records of supply as requested by regulator.

Call for Immediate Action: Improved system for reporting spray drift incidents

State regulators should provide the following to enable accurate and timely reporting of spray drift incidents:

• Clear outline of what to do in the event of a suspected spray drift event including what samples to take, sample storage, all other information to be collected
• Standardised reporting template that can be accessed and filled out online, or easily reported via a hotline number
• Increased on the ground follow up of reported incidents.

Call for Medium Term Action: Improved record keeping and accountability for pesticide applications.

Work with the APVMA, state regulators, industry bodies and other stakeholders to improve the current level of record keeping and accountability for all pesticide applications. This could include the following:

• Standardised format for record keeping
• On board recording of all pesticide applications
• Improved follow up and accountability by state regulators to ensure there is a tangible disincentive to not follow label conditions.

Please provide any feedback on these options by email to Sally Ceeney at [email protected]. In particular, please provide feedback on which options (if any) your CGA would be most supportive of.

Cotton Australia needs the support of the industry to advocate for these changes to be introduced. The options listed are not exhaustive, however the options are focussed on what is achievable and likely to have an impact. We also welcome any ideas for additional options that are not included above.