The EPA has released their proposed interim decision (PID) for malathion - which is the near final step in the pesticide registration review process. While the PID has retained aerial applications for all uses, the National Agricultural Aviation Association (NAAA) sent EPA comments on where there is room for improvement.
The PID requires the use of buffer zones to protect aquatic areas from malathion applications, and NAAA commented to EPA that those buffer zones need to be wind directional. Almost all recent PIDs for other pesticides and the strategies for protecting endangered species from pesticides have required wind-directional buffer zones, and NAAA suggested these would work equally well for malathion.
NAAA did object to a proposed 100-foot buffer zone for ULV aerial applications adjacent to aquatic areas, suggesting the distance was based on EPA’s usage of the Tier 1 AgDRIFT model which overestimates drift from aerial applications. EPA provided an exemption to the 100-foot buffer zone for mosquito control applications overseen by government agencies. NAAA suggested to EPA that if they were unwilling to reduce the distance, they should at least provide that exemption to aerial ULV boll weevil eradication efforts as well.
EPA has already consulted with the U.S. Fish and Wildlife Service and the National Marine Fisheries Service regarding malathion’s potential risks to endangered species and their habitats. Mitigations from the consultation process were part of the PID. The next stage will be for EPA to consider comments on the PID and then issue a final decision on malathion’s registration review.


