Aquatic Weed Control Near a Crawfish Pond and Whooping Crane Habitat

Using the non-aquatic 2,4-D amine in or over water would violate its label and the federal insecticide law, because a product must be used only for sites on its labeling. The glyphosate label limits treatment to one-third of the water body surface area at one time, and spraying the entire canal would exceed that restriction. The applicator must also check whether the product has an endangered species restriction for the whooping crane; a listed species in the area triggers the need to consult EPA's Bulletins Live! Two and to follow any pesticide use limitation area requirements. The wind forecast is toward the crawfish pond, so drift could injure crawfish and other aquatic life. Mixing two products without a compatibility check and without confirming both are labeled for aquatic use adds further risk. The plan should not proceed as proposed.

Before applying, the applicator should confirm that the product is labeled for aquatic use, read the entire label, and check EPA's Bulletins Live! Two for the field location and the whooping crane. The applicator should contact the appropriate state and federal wildlife or agriculture offices if the label or bulletin requires consultation, and should tell the crawfish producer what is planned. To protect the pond, the applicator should treat only a labeled portion of the canal, spot-treat instead of broadcasting, maintain a buffer at the culvert, use low-drift nozzles at lower pressure, and avoid spraying when wind is above the label limit or blowing toward the pond. Inversions and gusty conditions should be avoided. If cranes are present in or near the treatment area, the applicator should stop and reschedule. A spill kit and a plan to block the culvert should be ready.

The applicator should stop work, prevent further product from entering the water, and contain any spill or runoff if possible. The incident should be reported promptly to the Louisiana Department of Agriculture and Forestry and to the state wildlife agency, and the applicator should cooperate with investigators. The applicator should record the time, location, product, rate, weather, and observations, and should retain the label, application records, and tank-mix information. Dead crawfish or other aquatic organisms should not be handled carelessly; photographs and notes are better than moving evidence unless authorities direct otherwise. The applicator should notify the crawfish producer and the landowner. Attempting to hide the kill or apply more product would compound the violation and could lead to enforcement action and loss of certification.