Should you buy the name brand surfactant?

[Caustic Burno]

In MO it is a "Pesticide Applicators License", that includes plants and bugs, etc. as pests.

Same here just worded Private Pesticide Applicator License.
Under the TDA Categories
1C is Weed and Brush control.

 

[cow pollinater]

I'm with CB, it's not worth losing my ability to farm over a splash of dish soap instead of using a labeled product and YES, I have had inspectors pull up to my spray site and start taking notes. So far no violations but using anything off label could put the farming side of things out of business.

 

[bball]

Another "is the juice worth the squeeze" deal....

 

[inyati13]

In MO it is a "Pesticide Applicators License", that includes plants and bugs, etc. as pests.

Same here just worded Private Pesticide Applicator License.
Under the TDA Categories
1C is Weed and Brush control.

CB:
I have searched the US EPA web page, I do not believe the US EPA is authorized to "directly" regulate herbicides. As I mentioned, there are "backdoor" approaches under the Clean Water Act, The Resource Conservation and Recovery Act (RCRA), Clean Air Act, etc. For example, the Clean Water Act uses the term "pollutant". Herbicides can be brought in under that definition. Thus, herbicides can be the subject of EPA enforcement authority pursuant to other Acts if herbicides fall into one of those target categories. Nevertheless, I remain of the persuasion that the US congress has not passed an Act to specifically regulate herbicides.

Regarding my question above, my guess is that Texas has its own statutes and regulations to regulate herbicides. My guess is that the authority does not emanate from a federal act for the regulation of herbicides.

The US EPA has about 16,000 employees. The regulatory authority of the EPA is largely delegated to states. 99.999999999 percent of the US population will conduct their businesses and lives and never see a US EPA employee. One could read this forum and come away with the opinion that the EPA is a "police state" and there is an EPA enforcement officer behind every rock and tree. That is false.

The US Congress has seen fit to legislate environment laws (through the passage of "Acts") and has authorized the US EPA to promulgate the pursuant regulations. The US congress has maintained a policy that the "States have souvenir rights" to be the regulatory for those laws and regulations. Thus, when an act is passed, the US EPA goes through a public process of "delegation" to grant the state the right to be the primary Regulatory Authority. Today, it is rare for the US EPA to directly enforce an environmental law.

Candidly, I have wondered why the US EPA needs the 16,000 employees it currently employs. If there was more federal trust of the state to do its job competently, half those EPA employees would not be needed. But that is only opinion on my part. There are some states that refuse to accept delegation, i.e., Montana refused partial delegation of the Superfund program. That resulted in my lead role as a remedial project manager on the Butte – Anaconda Minerals Superfund project which still remains the largest Superfund site in the US. Personally, that is why I enjoyed working in Superfund. I enjoy being directly engaged in the enforcement process not as a "big brother" looking over the state's shoulder. Today, EPA's primary role is as a first responder and for emergency responses. For example, if a nuclear weapon such as a "dirty bomb" were detonated in a city, the US EPA is the most highly trained and prepared agency to deal with such an emergency. Another example, is in the case of biological weapons employed by a terrorist group. The US EPA was the lead agency on the Anthrax Cleanup in Washington DC several years ago.

In summary, I have one last point. Since this thread started on the subject of using detergent as a surfactant, I bet there is not one person on this forum who can post a single credible record of a prosecution that has occurred in the state of Texas during 2014 for using detergent as a surfactant for spraying herbicides. I rest my case.

 

[dieselbeef]

holy crap inya..too early to even read all that much less write it...

 

[Caustic Burno]

Inya they started the crackdown this year with inspections.
Told us it was coming the Label is the Law, get caught violating the label
minimum loose your license and up depending on infraction.
You better have the EPA numbers off those jugs and labels.
The TECQ inspectors are pulling sales records and making spot checks, know of one
in my area already that got checked. IMO that is the warning shot across the bow.

Like I said earlier I don't like it but the Rules Have Changed.
They are already in every area of our life in every product we buy.
We are now having to produce a product under the same guidelines we have just been
insulated from the regs a little longer as they went after the big fish first.