2008 Statewide Strategic Plan for Eurasian Watermilfoil in Idaho

Recommendation 3.1: Herbicide residue analysis
• Minimize the number of samples required to be analyzed that will be collected from
treatment sites to those necessary to document contract performance or to ensure
adherence to required residue levels.
• During the 2006 program, the Idaho Department of Environmental Quality required that
residue samples be analyzed from some herbicide applications beyond those required by
the herbicide labels. These data should be compiled and evaluated to determine if this
policy needs to be continued, and if so, how the number of samples can be reduced
significantly.
• Residue analytical costs can be greatly reduced by ISDA placing out to bid annual
contracts for herbicide residue analyses from all the state contractors. This will save
contractors time and the higher number of samples in one performing laboratory may
reduce per sample costs.
ISDA Response: ISDA will work with DEQ to review these requirements and provide clear
recommendations on the number of samples that are required. Additionally, the Aquatic
Plants Program Manager will explore the possibility for annual contracts for herbicide residue
analysis to reduce per sample costs.
Issue 3.2: Use of adjuvants
While there is no doubt that surfactants/adjuvants are important in foliar applications of
herbicides, there is little data to support use of adjuvants to improve efficacy against
submersed aquatic weeds. Granular formulations and fluridone liquid most likely do not
benefit from the addition of adjuvants due to the release rates of granules and the mode of
action of fluridone. The only possible benefits of the addition of adjuvants may be for liquid
herbicides that are absorbed rapidly, such as 2,4-D amine, diquat and endothall. Data
supporting this premise are not available, despite the fact that some applicators are convinced
that improved efficacy results from addition of surfactants for herbicide absorption and sinking
agents for herbicide placement
There is concern by some state agencies that certain surfactants may be toxic to zooplankton
and other invertebrates. Combine this with the fact that EPA does not regulate nor register
surfactants makes regulatory agencies hesitant to allow their use. Washington State has
developed a list of approved adjuvants which seems to be a reasonable approach until
additional studies or data are collected which would either a) show toxicity or lack thereof of
surfactants to invertebrates or b) definitive data are provided which clearly shows significantly
improved efficacy of the addition of adjuvants to herbicides used for submersed weed control.
Adjuvants used in this context includes surfactants, foams, sinking agents or other chemical
spray additives
.
Recommendation 3.2:
Allow applicators to use approved adjuvants from the Washington State list at
http//www.ecy.wa.gov/programs/wq/pesticides/final.pesticide.permits/registered_pesticides.html.
ISDA Response: ISDA will review lists from other states and may adopt them for use in Idaho.
Issue 4.0: Exemption from state water quality standards by temporary water quality
degradation caused by aquatic weed control activities.
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