UAV PESTICIDE APPLICATION WORK GROUP:

PROGRESS UPDATE
March 23rd, 2022 CLA Drones Working Group Update

Trilateral Stakeholder Workshop

Co-Chairs:
Becca Haynie, Syngenta
Sarah Hovinga, Bayer Crop Science

Drone specialized for crop input application

UAVs used in agriculture and for public health
are primarily used for sensing or input
application
 In the context of the evolution of digital technologies to improve the
future of farming, UAVs/drones are part of the solution towards
practices that have the potential to positively affect climate and
sustainability goals.
 Pesticide applications made by UAVs/drones are an emerging practice
that current regulatory frameworks should work to fully incorporate.
 CLA supports the EPA’s position to enable these technologies’
commercial use for products registered for manned aerial application.
 In general, the anticipated UAV use pattern is covered by existing risk
assessments.
Drone used for vector control in a
 Potential further data generation (e.g., spray drift, operator exposure, and hard-to-access location. (2)
crop residue) will facilitate their fit into the regulatory risk assessment drones are shown: one for
process. application, one for visualization.
(Courtesy of Clarke)
Potential benefits of drone technology in the
U.S.
• Amenable technology for hard-to access locations
Flexibility
• Larger areas can be treated precisely with multiple drones (e.g., swarms)
• Relatively less expensive technology compared to more expensive equipment (e.g.,
ground sprayers)
Cost
• Decreased application costs due to optimized applications
• Decreased crop damage due to minimizing field passes
Worker Exposure • Potential decreased operator exposure
• Enabling future of digital and precision tools including targeted and optimized
applications
Innovation • Positive industry disruption (e.g., attracting a diverse work force, creating possibilities
for spray-as-a-service business models, further attracting technology partners not
traditionally associated with agriculture [e.g., Google and Microsoft])
• Input reduction via customized rates, optimal timing, and placement
• Emissions reduction
Environment & • Reduced water consumption
Sustainability • Soil health
• Enables specialty crop care to contribute to a diverse food supply (e.g., small acreage,
minor crop uses, orchards and vineyards)
 Global regulatory landscape of drone
application technology
Europe, Middle East, Africa
North America
EU: Mostly aerial application
USA: EPA defers to states provided banned except with
aerial application is allowed on the derogations. DEU, CHE Drone
federal label. application allowed for
CAN: No registered labels for specific applications.
drones. HUN: local regulation under
construction.
Burkina Faso, Ghana, Kenya,
Zambia, South Africa: strong
interest in the drone Asia Pacific
Latin America application
JPN, KOR: Most advanced countries for drone
BRA, CRI, URY: Drone application is allowed once regulation
aerial application is already approved on the MYS, PHL, IND: Regulations in place.
label. CHN, THA, IDN: Commercial use permitted
GTL, COL, MEX: Some drone application while guidance is developed in parallel
permitted. Regulation under discussion. PAK, VNM, MMR: Regulations under
ECU, PER: Drone application not allowed. development
Regulation under discussion.
Active Stakeholder Groups Involved in Drones
for Application of Plant Protection Products
* Organization Geographic Scope
EPA (Environmental Protection Agency) USA
OECD (Organization for Economic Co-operation
and Development) Working Party on Pesticides Global
(WPP) UAV/Drone Subgroup
Industry-sponsored Task Force (Forming) Global
RPAAS (Remotely Piloted Aerial Application
North America
System)
NC State CERSA USA, CAN - some representation from Brazil (MAPA,
IBAMA)
ISO (International Organization for
Global
Standardization)
AAPCO (Association of American Pesticide
USA
Control Officials)
CLI (CropLife International) Global
CLA (CropLife America) USA
CLC (CropLife Canada) CAN
CLA (CropLife Asia) Asia Pacific
*List not exhaustive
CLA Drones Working Group

 The Working Group’s mission is to evaluate existing data used to assess or generated
by aerial and/or traditional pesticide application methods within a regulatory
context to identify equivalencies and gaps for UAV/drone applications.
 Group focused on (4) distinct areas: Registration/label, Spray Drift, Crop Residue,
and Operator Exposure
 Developed white paper entitled:

UAV Pesticide Application: Benefits and Fit into the Current Regulatory Framework

 In conjunction with stakeholders, CLA looks forward to enhancing stewardship for

this advancement in technology and to clarifying the appropriate scientific
paradigms under FIFRA.
Recommendations: Spray Drift
 It is possible that drift data could be organized and compared to conventional
application methods to be used for regulatory purposes to confirm that
existing risk assessments cover the UAV/drone use pattern. To support this,
there is a need for:
 A standardized protocol for measuring spray drift considering UAV/drone types
 Spray drift data to understand the effect of variables associated with UAV/drone
operation (e.g., horizontal speed, height above the target treatment, nozzle
configuration, and unique UAV/drone aerodynamics) as part of the effort to
develop Best Management Practices and how drift from UAVs/drones generally
compares to other methods
 Development of a new predictive model or, more expediently, adaptation of an
existing model platform, to estimate drift from the most common UAV/drone
platforms (e.g., multi-rotor, fixed-wing, and helicopter) with flexibility to
accommodate future design elements

Team Lead: Naresh Pai (Bayer)

Recommendations: Crop Residue
 Residue level comparisons between UAV/drone applications and conventional
application methods (e.g., ground, handheld, and aerial applications) would
help in understanding potential differences in pesticide deposition of these
systems and whether bridging to existing data would be sufficient.
 We recommend that UAV/drone-specific residue data be generated if needed
to address:
 Ultra-low volume (ULV) applications (e.g., <2 gallons spray per acre for most crops,
or <10 gallons per acre for orchards)
 Change in carrier type (e.g., water versus oil) used in UAV/drone applications
 Applications outside of the existing critical Good Agricultural Practice (GAP) (i.e.,
crop, dose, or pre-harvest interval)

Team Lead: Sheila Flack (Bayer)

Recommendations: Operator Exposure
 The overall process in using a UAV/drone to make pesticide applications can
be summarized in 4 parts:
 Initial mixing and loading, Spraying, Subsequent mixing and loading, and Cleaning
and maintenance
 In many ways, the process to use a UAV/drone for pesticide applications is
similar to currently approved methods, particularly for manned aerial
applications, but there are also several areas which potentially differ and/or
may not be fully understood.
 As the EPA Surrogate Reference Guide contains a wealth of pesticide handler
exposure data, there is potential to estimate drone handler exposure by
bridging to already existing handler scenarios.
 However, unless current data exists, one area of further work would be to collect
data on UAV/drone work practices, possibly in the form of a survey.

Team Lead: Travis Bui (Corteva)

Recommendations: Registration
 As UAV/drone technology continues to evolve, CLA encourages the EPA to
maintain the current approach (i.e., UAV/drone applications for products with
manned aerial uses) and to enable regulation of pesticide application via
UAVs/drones under the current Federal Insecticide, Fungicide, and
Rodenticide Act (FIFRA) framework.
 Following the EPA assessments of emerging technologies, if additional label
language is required for drones, continuous collaboration to streamline the
process of label reviews is imperative. It is suggested that the overall use
pattern be considered, and that label language, as much as possible, be
consistent, standardized, and then added to EPA instructional documents such
as the Label Review Manual.
 CLA additionally encourages EPA to continue efforts on electronic labels and
look ahead to digital labels, that are fit for machine readable and machine
actionable capabilities.

Team Lead: Nandita Chowdhury (Clarke)

CropLife America Drones Working Group (CLA DWG) Project
Awarded* to Construct a Database to Inform an Interim Drift Model
 Context
 The CLA DWG developed a white paper related to the application of
crop protection products in commercial agriculture using unmanned
aerial vehicles (UAVs, henceforth referred to as drones).
 The white paper focuses on registration/labeling, crop residue,
operator exposure, and spray drift. This project is targeted primarily
to support the spray drift workstreams but will also inform the
activities of other workstreams.
 Project
 Based on expert analysis of the available data in published literature
(https://www.oecd.org/chemicalsafety/pesticides-biocides/literature-
review-on-unmanned-aerial-spray-systems-in-agriculture.pdf), there is
potentially enough information to gain an understanding for where
drones appear regarding drift compared to other conventional
application types.
 When the published information is collected in a systematic and
curated database, it will potentially enable the comparison of the
equivalency of drones, from a spray drift perspective, to other
conventional application types via an interim drift model. Drone specialized for crop input application

*Awarded to Dr. Jane Annelise Sara BONDS (Barber) D.I.C.; Bonds

Consulting Group LLC. [email protected]
Conclusions
 CLA supports the position of EPA to enable these technologies’ commercial use
for products registered for manned aerial application since, in general, the
anticipated UAV/drone use pattern is covered by existing risk assessments,
knowing that potential further data generation (e.g., spray drift, operator
exposure, and crop residue) will facilitate their fit into the regulatory risk
assessment process.

 The industry will continue to further research and innovate to enhance the
competence and responsible use of drones.

 As these efforts progress, the industry is committed to work with

stakeholders, including the EPA, within transparent, science-based, and
flexible regulatory frameworks that can enable these technologies to
continually evolve for the future of sustainable farming.
 Thank you

Becca Haynie (Syngenta) [email protected]

Sarah Hovinga (Bayer) [email protected]
Back-up
OECD recommendations
 Comparator & Protocol Creation
 Establish database to classify UASS into groups to reduce burden of testing each different platform/configuration.
 Survey manufacturers about future trend of UASS design/ use profiles to produce a standard platform as a common
starting point for regulators (others may differ and need bespoke assessment but would cover most common uses).
 Encourage manufacturers to develop improved spray systems including the pump systems, nozzle placement and
closed transfer loading systems.
 Develop set of standard methodologies that will support regulatory decision making.
 Best Management Practices
 Develop and publish a user-friendly summary of best practice (including the essential nature of calibration), pitfalls
and a trouble shooting guide (both for generating trials data and applying pesticides in practice), including
preliminary recommendations for operational parameters (release height, application volumes, forward speed and
spray quality).
 Promote the advice in Annex D recommendations for researchers conducting UASS drift studies.
 A data gathering exercise for operational practices mixing, loading, cleaning and transport scenarios.
 Modelling
 Develop an empirical database and standard drift curve or model to estimate off target exposure.
 Develop a useable publicly available model for predicting spray deposition and drift including parameters for static
hovering, forward speed and spray equipment.
 Report:
https://www.oecd.org/officialdocuments/publicdisplaydocumentpdf/?cote=ENV/CBC/MONO(2021)39&doc
Language=En
PPDC Emerging Agricultural
Technologies Workgroup Outcomes
 Benefits
 Potentially less worker exposure to pesticides and time/labor savings particularly in areas where hand
application is needed
 An opportunity to use this technology in tough and difficult conditions (e.g., cliff sides) where traditional
application methods may not be feasible or present additional hazards
 Potential to reduce environmental loading of pesticide/fertilizer/water as spot or partial field applications
may become more viable
 Depending on equipment type, reduced fuel use / emissions and a lower cost to entry may be realized in many
scenarios
 Challenges
 Benefits may be over-stated early in development and roll-out and therefore quantifying benefits as
technologies evolve is very important
 Safety, implementation, and regulatory compliance (What additional information / data is required)
 Offsite movement that may impact applicators, bystanders, and/or wildlife that may be different than conventional application
methods?
 Are there differences in the applications that may impact pesticide efficacy and/or tolerances or result in crop injury?
 What applicator training will be required and who will certify?
 What label language changes will be required?

 Summary presentation: https://www.epa.gov/system/files/documents/2021-10/presentation-

emerging-viral-pathogens-workgroup-report.pdf
 Report: https://www.epa.gov/system/files/documents/2021-10/emerging-agricultural-technologies-
workgroup-report-and-recommendations-for-ppdc-review.pdf