January 2014
1 Federal Agency
1 State Agency
16 businesses/consultants
1 private citizen
5 associations/trade organizations
1 university
EPA reviewed the comments from the Federal Agency. Their comments have been considered and addressed as appropriate.
Docket Identifier (EPA-HQ-OPP-2012-0631-XXXX) |
Commenter |
-0005 |
The Andersons, Inc. |
-0006 |
Loveland Products, Inc |
-0007 |
Aerial Service, Inc. |
-0008 |
Oregon Department of Agriculture |
-0009 |
Private citizen |
-0010 |
Central Planes Aviation Inc. |
-0011 |
Greenleaf Technologies |
-0012 |
Medina Flying Service |
-0013 |
Reabe Spraying Service, Inc. |
-0014 |
Wilbur-Ellis Company |
-0015, -0020 |
Pentair - Hypro |
-0016 |
Wolf Consulting & Research LLC |
-0017, -0018, -0019 |
Micron Group |
-0021 |
AgriFlite Services, Inc. |
-0022 |
CP Products Company, Inc. |
-0023 |
National Agricultural Aviation Association (NAAA) |
-0024 |
Agricultural Retailers Association and Certified Crop Advisor Program |
-0025 |
CropLife America |
-0026 |
American Society of Agricultural and Biological Engineers (ASABE) Committee PM 23/6, Application Systems |
-0027 |
Valcore Consulting LLC and Application Insight, LLC |
-0028 |
University of Georgia |
-0029 |
Dow AgroSciences |
-0030 |
Electrostatic Spraying Systems, Inc. |
-0031 |
Council of Producers & Distributors of Agrotechnology |
The comments are divided into two main categories: Comments on the Program and Comments on the Protocol. There are subcategories within each of the main categories.
Structure of the DRT Program |
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Response: During development of the DRT Program, EPA has worked to be consistent with the efforts that other countries (such as Australia, the UK, Germany, and Canada) are undertaking to reduce spray drift. Some nozzles are sold internationally, so consistency in DRT-ratings means manufacturers can perform fewer tests, and less confusion for purchasers in determining the nozzle suitable for their needs. Therefore, to be consistent with these existing programs which do not acknowledge a drift reduction of less than 25 %, and given the uncertainties of these smaller reductions, EPA intends to have at least a drift reduction of 25% to qualify for a DRT-rating. EPA also agrees that the very highest performing products should be distinguished and therefore is using a DRT **** for products achieving a drift reduction of equal to or greater than 90 %.
The 4-star system that EPA will use for the DRT Program is as follows: <25% No rating 25 – 49% DRT* 50 – 74% DRT** 75 – 89% DRT*** ≥90% DRT****
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Response: At this beginning stage, the proposed DRT Program is being deliberately designed for certain technologies that can be verified to significantly reduce the driftable fraction of spray droplets from an application as compared to a reference technology. Using the proposed protocol will provide data to quantify a potential reduction. In addition to the benefits to applicators and the environment from the use of drift reduction technologies, EPA will be able to use the test results in quantifying the potential reduction in spray drift and associated risks for pesticide products labeled for use with DRT-rated technologies. EPA has developed a protocol for testing various application technologies, such as nozzles and nozzle/adjuvant combinations in a wind tunnel to measure their droplet size distributions (DSD) as compared to a reference technology. The protocol also provides guidance for testing these and larger technologies (e.g. shrouds and shields) in the field to measure quantities of downwind deposition of spray drift as compared to a reference technology. EPA can use the test results from wind tunnel or field studies along with other information about a pesticide’s application variables (application rate and method) to estimate potential downwind spray drift deposition for the pesticide when used according to the label and with a DRT-rated technology. The agency uses these deposition estimates, as potential exposures to non-target organisms and sensitive areas, with a pesticide’s toxicity values to characterize its potential risks from spray drift and based on these risks to determine appropriate application restrictions for risk management. These measures can include buffer zones, maximum wind speeds and spray release heights. Thus, pesticides labeled for use with DRT-rated technologies will have the potential to be applied with less spray drift and therefore less risk, allowing a reduction in the application restrictions. Some adjuvant chemicals may be useful for minimizing drift when used in combination with nozzles, and it is very probable that combinations of various nozzles and adjuvants will be tested and qualify for a DRT-rating. However, because a nozzle’s spray characteristics can be affected by an adjuvant being used for drift reduction, a specific adjuvant must be tested with a specific nozzle. Therefore, EPA will not establish DRT-ratings for the use of adjuvants only. EPA agrees that “precision agriculture” such as GPS based geo-synchronization also have tremendous implications for reducing pesticide drift and/or the amount of pesticide applied. The development of even newer technologies such as “intelligent decision spraying systems” with the capability to decide when, where, and how much spray to be applied offers the potential for significantly reduced pesticide use in the future. EPA also agrees that many applicators are currently using many of the technologies mentioned in the comment to improve the accuracy of applications and reduce spray drift. Programs such as PAASS and a variety of other trainings provide the opportunity for applicators to learn of the latest techniques. The newer boom sprayers often combine several of these technologies, and represent significant reductions over boom sprayers of even 10 to 15 years ago. However, the focus of this voluntary program is to quantitatively measure the driftable fraction of spray droplets from application technologies and to calculate percent drift reduction. Some of these technologies assist the applicator in placing the spray on a target crop rather than affect the application’s driftable fraction of the spray. EPA believes this to be desirable, but does not have a method of reliably estimating a reduction in the driftable fraction. Once the DRT Program has gained a certain amount of experience, then it may be possible to develop methods for crediting the use of other types of equipment. |
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Response: The proposed DRT Program does not create categories of “legal” and “illegal” spray nozzles. Under this voluntary program, an equipment manufacturer would test their nozzle(s), or other technologies, and then EPA assigns a rating (based on specific criteria) to the nozzle. During these early stages of program implementation, EPA envisions that a pesticide product label may have application instructions for both non-rated nozzles (as on current labels) and DRT-rated nozzles. The applicator may choose to use any nozzle that has been rated within the rating category specified on the label. |
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Response: There are a variety of reasons for growers or applicators to keep records. Under the 1990 Farm Bill, all private applicators are required to keep record(s) of their restricted use pesticide (RUP) applications. Under the Worker Protection Standard, the agricultural employer is required to retain records of applications on the establishment. Recordkeeping may be required because of a pesticide use inspection or required by a state lead agency. Such an agency may require that the applicator keep certain documentation for each application. In addition, it is a good business practice that can supply evidence that the pesticide product was applied in accordance with the label directions. As currently envisioned, this voluntary program will not require the use of a specific nozzle or DRT-rated technology. Instead, a pesticide registrant would have the option of selecting one or more categories of DRT-rated technologies (e.g., one star, two star, etc.) that would also appear on the label. Upon EPA’s approval of that label, the applicator would follow the label directions for the type of nozzle (non-DRT or DRT-rated technology) that they selected for use. At this time, EPA anticipates labels would have a table, similar to the following, to express possible buffer zones, or other key application parameters such as maximum wind speed or release height. |
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Label Directions-- |
Droplet Size |
Buffer Zone (ft) |
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Aquatic |
Terrestrial |
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Non-DRT Rated Technology |
Fine to Medium |
100 |
25 |
DRT* Rated Technology |
--- |
25 |
25 |
DRT** Rated Technology |
--- |
15 |
10 |
The buffer zones for a particular label would be calculated specific to the active ingredients in the product and the use patterns on that label. The buffer zones on any particular label would represent the buffer needed for the most sensitive of the non-target species. Thus, if the applicator did not have a DRT-rated technology, then his record keeping would likely note that the required buffers for a non-DRT technology were maintained. Similarly, if the applicator used a DRT-rated technology for his application, then he would note that fact in his application records. |
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Response: During these early stages of program implementation, EPA envisions that a pesticide product label may have application instructions for both non-rated nozzles (as on current labels) and DRT-rated nozzles. However, in the future, as more technologies are tested and more DRT-ratings are assigned, it is possible, given the specific circumstances needed for a particular pesticide product, that the pesticide registrant could request that his label only specify the use of a DRT-rated technology and not offer the option of using a non-rated technology. If that occurs, then the applicator would be required to use the appropriately rated technology. Even if only DRT-rated technologies are on the label, EPA believes that applicators would still have a variety of options, such as: (1) Applicators could choose to purchase the nozzles needed. Nozzle prices vary with many costing less than $10.00. (2) The applicator in consultation with the grower could determine to use another pesticide product that has use directions for DRT-rated technology already available to the applicator. EPA agrees that some registrants may choose to put use directions on their products that only specify the highest DRT-rated technologies, provided the registrants are confident the use of these technologies are suitable for product performance. It is possible that a registrant will need to label their product with a lower rated DRT category for product performance. As more technologies are tested and receive DRT ratings, EPA envisions there may be a large number of different technologies with the same DRT rating, and registrants will have more options from which to choose which category(ies) of DRT-rated technologies are appropriate for their products. In addition, some registrants may choose to not put use directions for DRT-rated technologies on their labels while other registrants may choose to put use directions for both DRT and non-DRT-rated technologies on their product labels. Overtime, registrants and applicators will have increasing flexibility.
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Response: It is important to remember that a DRT rating is a measure in the reduction of the driftable fraction of spray droplets from an application using a submitted technology as compared to a similar test using a reference technology. So a new technology tested at a certain pressure and wind speed will require the reference technology to be tested at the same pressure and wind speed. It is anticipated that the effect of different pressures on a technology’s driftable fraction will be similar to the effect the changes would have on the reference technology, such that the reduction would not be substantially different. However, this remains to be seen and until a sufficient number of submissions have been received to support this supposition, DRT ratings will be accompanied by the pressure of the submitted study. Since an application system’s pressure affects droplet size from a nozzle, EPA expects manufacturers to ask testing organizations to test their nozzles with different pressures. The results may result in EPA assigning different DRT ratings to the same nozzle with different pressures. It is possible that if the same nozzle were tested using different pressures the DRT-rating could be different for the pressures. The DRT protocol recommends that a nozzle be tested according to a “typical” use condition. Most nozzle manufacturers understand the “typical” pressures that would be used for each of their nozzles in the field. So, if the nozzle or nozzle/adjuvant combination were tested at 30, 40, and 50 psi, then the DRT-rating would be reported for each of the studies. EPA’s protocol does not directly address speed as a variable for testing; however, as explained in the footnotes to Table 1 in the protocol, and the descriptions of the test sites (A6.2.1), two of the three test sites covered under the protocol consider speed as part of the testing parameters. The low speed wind tunnel (LSWT) approximates the application speeds of land-based equipment such as ground booms. The high speed wind tunnel (HSWT) approximates the application speeds that can occur during aerial application. If a drift reduction technology such as a nozzle were to be tested in a LSWT, then the DRT-rating would be specified as for ground application on EPA’s website. Similarly, testing in a HSWT would be specified as for aerial application. Thus, speed is a part of the testing parameters, and thus becomes part of the descriptor of the technology tested. |
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Response: To estimate a DRT rating for a technology, EPA must have adequate test data. EPA’s protocol includes test methods for both wind tunnel and field testing. Application technologies can be tested in either wind tunnels or the field. However, the agency believes companies will more likely choose to use wind tunnels for testing small equipment, such as nozzles, because of the significant cost difference. |
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Response: EPA intends for the DRT Program to continue beyond three years. The commenter is correct that the information collection request (ICR) for the DRT Program would expire three years from the date that it is approved by the Office of Management and Budget. The maximum period for which an ICR can be approved is three years. Since EPA does not intend to stop the voluntary program at the end of three years, EPA would need to begin the ICR renewal approximately a year before the expiration date. At that time, EPA would prepare the needed documentation and publish the request to renew the ICR for the next 3-year period. |
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Another commenter asked if EPA would place the first DRT-rated product on the website all alone. That commenter preferred that EPA release several products at one time, so that there is not an unfair advantage to the first DRT-rated product.
Response: The agency has reviewed the United Kingdom’s (http://www.pesticides.gov.uk/guidance/industries/pesticides/topics/using-pesticides/spray-drift) and Canadian websites (http://www.omafra.gov.on.ca/english/crops/resource/spraydrift.htm) and has considered those websites in developing EPA’s website. EPA intends to get its website up and running closer to the implementation date of the voluntary program. EPA agrees that incorporating state-of-the-art information technology on the website is an excellent idea, and we will pursue this as a future activity. We understand the commenter’s concern about an “unfair advantage to the first DRT-rated product.” However, EPA intends to post the results of its review and analysis of each DRT study as soon as reasonably possible after completion. Pesticide registrants will determine their time frame for submitting an application to EPA for including DRT claims on their labels. It is possible that registrants could wait until EPA has rated multiple technologies. |
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Translation of wind tunnel data to DRT star-rating for use in an Agency risk assessment |
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Response: To obtain a DRT rating, a manufacturer would need to provide appropriate data to EPA for review and evaluation. The DRT data can be generated using the test methods described in the DRT protocol. EPA would evaluate the study and, based on a comparison of the results from the test technology and the tested reference, EPA would assign a DRT rating. For wind tunnel testing the DSDs of the test technology and the reference technology are measured. The percent reduction of driftable fraction (<141 µm) of the DRT technology compared to the reference will determine the DRT rating. Depending on the percentage difference, EPA will assign the appropriate rating (see response to comment 1). According to the proposed protocol, field studies use the same reference nozzle as wind tunnel studies but measure deposition rather than DSD. EPA intends to compare the reduction in deposition at the edge of the field to determine a DRT rating.
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Response: If a technology manufacturer submits a DRT report of a wind tunnel study conducted according to the proposed protocol, EPA’s goal is to review, evaluate, and post on the website the DRT rating within 120 days from receipt of the report. Field studies are more complicated to review and therefore EPA’s goal for review of a field study is within 180 days from receipt. These stated review times are goals as other factors, including availability of EPA’s resources, may influence the timeframes. It is important to note that the submission and evaluation of a study that is independent of an application for pesticide registration is not an action under the Pesticide Registration Improvement Act (PRIA), which has fees and specific review schedules. However, if a pesticide registrant were to include a DRT study report as part of a submission package for a registration action, then the registration action is a PRIA action. EPA’s review and evaluation of the DRT data would be according to the mandated review timeframe for the particular type of PRIA action. |
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Response: EPA’s review and evaluation of a submitted study begins with a determination of the scientific validity of the study, i.e., can the study be used for its intended purpose? Scientifically valid, well-conducted studies then undergo data analysis. In general, EPA’s risk assessment for the use of a pesticide is quantitative, in that the agency estimates the potential amount of pesticide that could drift from the target site based available spray drift data and/or assumptions and application directions and restrictions specified on a pesticide’s label. That amount is compared to the pesticide’s toxicity values to estimate potential risks and therefore the need for risk management measures, such as buffer zones. EPA intends to use results from wind tunnel studies in the following manner to assign DRT ratings to verified DRT technologies as described in the response to comment 10. For risk assessment of a pesticide whose product label specifies application with a technology bearing a specific DRT rating (e.g., DRT***), EPA intends to use the following method to credit the use of a DRT technology in the risk assessment and risk management measures or restrictions, such as a buffer zone, for the product label. The agency will follow its current methods for risk assessment and risk management decisions. The primary difference will be that the agency will have data from validated DRT technologies for estimating potential risks rather than relying on the default assumptions currently used. EPA typically uses certain groundboom and aerial scenarios of the AgDRIFT model in risk assessments of pesticides when the labels are silent on requirements for spray quality (e.g., DSD). EPA uses default scenarios of the AgDRIFT model to estimate the potential fraction of the application rate that will be deposited downwind from the edge of the application site. The model then estimates the downwind deposition profile on non-target sites at varied distances from the edge of the application site. The agency uses this deposition profile for a pesticide along with the appropriate toxicity endpoint values (terrestrial and aquatic animals and plants and humans) of the pesticide to estimate potential risks from spray drift from the pesticide’s uses. These risks are actually the downwind areas where the amount of pesticide deposition is equal to or greater than the pesticide’s toxicity endpoints. EPA uses this comparison of deposition exposures and toxicity values to determine the need for buffer zones and if so, then the appropriate size or any other appropriate risk mitigation measures to protect human health, non-target organisms and sensitive areas. So, for pesticides labeled for use with a DRT-rated technology(ies), EPA will continue to use a similar approach for conducting its risk assessments, but will replace the default DSD usually used in AgDRIFT (aerial only)/AGDISP model with a different default DSD. This default would be selected to match the DRT claim on the label. However, the current groundboom module in AGDISP has some limitations and the developer of the AGDISP model is working to improve the predictability of the model. For a field study, a deposition profile will be developed based on the deposition data, and the distance to the appropriate endpoint of concern used in risk assessment. Deposition profiles will be categorized by application method (e.g., aerial or ground) and used specifically for buffer zone reductions for those application methods. EPA has used the above approach for estimating downwind spray drift, using the AgDRIFT/AgDISP models for many years. The models, as well as the risk assessment approach, have been scientifically peer reviewed and are well established. Improvements are being investigated, as discussed in response to comment 58. The only new aspect of this approach is to use a low end of the DSD for each DRT category for risk assessment purposes.
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Bundling/Adding two or more DRTs |
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Response: EPA is aware that applicators may use a variety of application technologies and methods to manage their applications and manage spray drift. However, the agency is not aware of a valid method to credit a combination of DRTs or application methods without testing the combination. Combinations are not necessarily additive and in some cases, published studies have demonstrated antagonistic effects, i.e., increasing spray drift. As discussed in response to comment 2, bundling is not appropriate for a nozzle/adjuvant combination. Since a nozzle’s spray characteristics can be affected by an adjuvant being used for drift reduction, a specific adjuvant must be tested with a specific nozzle. When considering other combinations, EPA has not been able to identify a practical and accurate methodology to bundle or add DRT-rated technologies to give a higher DRT-rating to a combination of two or more technologies without testing that combination. EPA expects manufacturers will focus their testing on nozzles, nozzle/adjuvant combinations, and perhaps certain larger technologies such as shields or shrouds, and electrostatic sprayers. EPA believes that the most practical combination of these technologies is a DRT-rated nozzle (or nozzle/adjuvant combination) and a DRT-rated shroud. Discussions with members of the technical panel indicate that shrouds have the potential to significantly reduce most spray drift. Therefore, the use of a DRT-rated nozzle with the shroud is unlikely to have any significant additive effect. |
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Costs |
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Response: The most likely scenario is that the equipment manufacturer or other interested party will pay to have their technology tested, and then submit that study to EPA. EPA will absorb the cost of reviewing and evaluating the study, determining the DRT rating, and then posting the rating on the website. Once a registrant decides to have a DRT technology on their label, then the registrant will pay a PRIA fee for amending the label to add the DRT-ratings to the label. |
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Commenters also expressed concern that at this time there is only one US wind testing facility, and that facility is not a commercial facility. Thus, there is a lack of competition to help hold costs down.
According to a different commenter, companies already pay for tests to determine the size classification of their nozzles. Smaller companies may not have the resources for additional DRT testing for this Program. Yet another commenter indicated that the cost estimates were accurate enough for how testing is conducted today, but expected costs to rise significantly since the protocol will add additional requirements and create new compliance costs. The same commenter indicated their belief that costs for wind tunnel testing could easily double or triple. Response: EPA agrees that there are some uncertainties associated with the cost estimates for the DRT tests. In the U.S., EPA has identified two commercial wind tunnels that could conduct testing according to the EPA’s protocol. The potential testing facilities include Battelle in Ohio and University of Nebraska. Other facilities in the U.S. that have the capability of conducting this testing are also likely to exist.
EPA believes that in the future, competition means that other wind tunnel testing facilities will also be able to conduct such studies in the U.S. It is possible that equipment manufacturers or adjuvant manufacturers have in-house facilities. Additionally, there is no requirement that the studies must be conducted in the U.S. Because, similar drift reduction programs are already exist in Europe and Australia, testing facilities are also available there. Two potential testing facilities are Queensland University in Australia and Silso in England. At this time, EPA will not require testing of nozzles under multiple combinations of pressure/angle/flow rate/airspeed. Testing nozzles or nozzle/adjuvant combinations in low and high speed wind tunnels will include using the typical pressures that would be used for each nozzle in the field. Pressure is an important variable in DSD, which can vary according to the application. EPA’s original protocol for low speed wind tunnels offered the option of measuring flux with monofilament lines or measuring droplet size distribution (DSD) with a laser diffraction. Based on comments received, EPA is modifying its protocol to standardize on the laser approach. The laser method can provide the information needed by EPA for DRT-rating and risk assessments. Additionally, use of results from the flux measurement would require the use of modeling which is not sufficiently developed for use. However, if a manufacturer wishes to conduct a study to measure flux, the agency recommends the testing facility and manufacturer consult with agency prior to the initiation of such a study. EPA acknowledges that most nozzle manufactures already pay to have their nozzles tested to determine droplet size classification. However, this test and classification does not identify the driftable fraction of the droplets as compared to a reference nozzle. A goal of the DRT Program is to identify through verification those nozzles and other technologies that have the potential to significantly reduce spray drift, including nozzles in the various size classifications. The most recent cost estimates available to EPA reverified that to test a single nozzle in a wind tunnel according to the revised protocol (i.e., the laser approach) at three typical pressures could vary up to $6000. For field studies, the agency agrees that costs for conducting field studies will be significantly more than wind tunnel studies due to the increased complexity of conducting such studies. These costs are estimated to vary up to $100,000.
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Legal Issues |
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Response: Placement of a DRT star rating on the agency’s DRT website is not considered an agency endorsement. EPA is developing a criteria-based program. The DRT-rating does not mean that EPA endorses a particular technology, such as a particular nozzle, shroud or shield, or nozzle/adjuvant combination, but rather that the product has been reviewed by EPA and found to meet the criteria required for the DRT-rating. When a DRT-rated technology is offered on a pesticide label, this means that EPA’s risk assessment (conducted according to proper procedures) has estimated the appropriate spray drift risk management measures, such as buffer zones, based on the available, reviewed data. There are many factors to consider when making a pesticide application. The grower or applicator continues to bear the responsibility as the person making or supervising the application to make sure that all labeling requirements are followed, including instructions related to spray drift. The use of DRT-rated technologies is one of a number of tools applicators can use to reduce and manage spray drift to meet federal and state pesticide application requirements. The use of a DRT-rated technology does not alter the grower or applicator’s liability when making a pesticide application.
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Response: The DRT Program does not have a data compensation component for DRT study reports (data) submitted to EPA directly by an equipment manufacturer and independent of an application for pesticide registration, rather than by an applicant or registrant to support or maintain registration. When submitted independent of a registration action, the information in these studies is not evaluated as part of a PRIA submission, do not require payment of a fee, and are not subject to data compensation. The technology manufacturer submits a study to obtain a DRT-rating for his technology. As explained in response to comment 12, EPA will “credit” the DRT-rated technology in the risk assessment-management decision (i.e., use a drift reduction factor in the risk assessment) instead of using a conservative default assumption that does not assume any spray drift reduction. Pesticide labels that include use directions that specify use of a DRT-rated technology(ies) would also specify spray drift risk management measures, such as buffer zones if necessary, maximum wind speed or release height. Under these circumstances pesticide product labels will only specify, for example, to use a technology with a particular DRT rating, never a specific technology, so, as the program develops, applicators will have a variety of technologies from which to choose. It is also possible that a pesticide applicant or registrant to support or maintain a product registration could submit a DRT study for a particular technology, for example, a nozzle/adjuvant combination to EPA. EPA would review and evaluate the study, determine the percent drift reduction, and then assign the technology to a DRT category. The DRT-rating for the nozzle/adjuvant combination would be posted on EPA’s website as part of that category. There is not a data compensation component to posting the DRT-rating on the website, because EPA would not be using the submitted data in the risk assessment to determine the spray drift risk mitigation measures for other registrants. Instead, as described in response to comment 12, EPA would use the DSD for the DRT-rating claimed on the label, a default DSD for that DRT category, for developing the risk assessment.
There is only one possible circumstance for the DRT Program to have a data compensation component. If the DRT study were to be conducted with a specific pesticide product/technology combination and the circumstances were so unique that the pesticide product/technology combination would need to be claimed on the label, then there would be a data compensation component. However, it is extremely unlikely that EPA would find this data useful for evaluating any other product. Therefore, there would be very few circumstances of DRT data being cited.
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Response: For studies submitted to EPA directly by an equipment manufacturer, rather than by an applicant or registrant to support or maintain registration, EPA would “archive” the submission using our internal system of issuing an “MRID” (master record identification) number. For DRT data submitted to support a registration, EPA would also issue an MRID for the data submitted to EPA. However, the commenter is correct that under FIFRA, the data submitted by a registrant to support a product registration must be retained as long as the product is registered. To account for these differences, EPA will change the statement in the protocol to read “the testing organization will retain all test-specific documentation and records for at least 7 years (or longer as needed) after the final payment of the funding agreement between the technology manufacturer and testing organization.”
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Response: EPA acknowledges that DRT-rated technologies may perform somewhat different under actual use in the field for a variety of reasons, such as use of worn DRT nozzles, physical-chemical characteristics of tank mixes, and applicator behavior. There are multiple factors that can affect pesticide application whether it is DRT-rated or not. If EPA determines that a DRT-rated technology is, in fact, not providing appropriate drift reduction in practice, EPA may remove the technology from the listing of DRT-rated technologies on the website. To the extent the commenter is speaking to manufacturer tort liability for harm caused by potentially defective products, EPA suggests that such questions be directed to the manufacturer’s own legal counsel.
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Use of Existing Data |
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Response: EPA understands that numerous published and unpublished studies have been conducted to characterize potential spray drift due to a number of variables. The studies most applicable to the DRT Program would be those concerning the use of drift reduction technologies. EPA believes that some of the published and unpublished studies may be acceptable provided these studies are well-conducted, scientifically-sound, provide a comparable baseline or reference so that it is possible to calculate the percent reduction, and the raw data would be available to EPA for review. EPA’s protocol was specifically designed to include a reference nozzle. By requiring the use of a specific reference nozzle EPA can compare technologies and make sure that, for example, a 25 percent reduction for one technology is consistent with the same 25 percent reduction for another technology. Therefore, if a study has a comparable baseline, then EPA may be able to calculate a drift reduction percentage that would be consistent with the results of studies conducted using the EPA protocol. EPA also understands that some of these studies have been assigned DRT ratings under the programs in the U.K. and Germany. There are differences in application techniques in the US as compared to Europe, such as fewer aerial applications in Europe. Some of the testing in the U.K. or Germany was performed using monofilament string method. However, as discussed in response to comment 15, EPA is standardizing its protocol based on laser diffraction droplet size analyzer for wind tunnel studies. One of the most substantial reasons for standardizing on laser testing is the lack of a model for using flux measurements. The U.K. does have such a model; however, their model is not publicly available, and EPA’s policy is that the models used for EPA risk assessment should be publicly available. EPA has no basis for translating these assigned ratings to an EPA-assigned rating without some comparison studies. EPA encourages equipment manufacturers or testing facilities to conduct wind tunnel studies, using EPA’s protocol, of some of those technologies with DRT ratings from the U.K. and/or Germany to provide EPA with a basis for comparability. It may be possible for EPA to adopt/translate the U.K. and/or Germany rated technologies if the studies performed using EPA’s protocol provide the basis for translating the test results. |
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General/Miscellaneous Comments |
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Response: For the agency’s DRT program to be a success, technology manufacturers and pesticide registrants must be willing to voluntarily participate. It is likely that the voluntary program will start slowly until the first technologies are tested, the website begins to be populated with DRT-rated application technologies, and the first labels are amended to include DRT claims. After this early adopters/transition stage, it is likely that more manufacturers would test their technologies. Once products with DRT-rated technologies on the label are more common, EPA believes that benefits would also accrue to applicators. Applicators will be able to make applications with legally reduced buffer zones or other less restrictive applications. Additionally, it is likely that many of the existing DRT technologies currently in use will qualify for a rating, and there would be no need for all applicators to buy new DRTs. The agency believes that in addition to the benefits of reduced application restrictions there would be benefits of economics, pesticide application efficacy, and reduced liability. Application technologies and methods that lessen spray drift are likely to reduce the loss of pesticide product to off-target areas, as well as increase pesticide deposition on the target crop or site. This improves product efficacy. Additionally, applicators that significantly reduce spray drift are less likely to cause off-target drift problems and become subject to liability issues and insurance claims. |
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According to the Wisconsin Agriculture, Trade and Consumer Protection (ACTP): ATCP 29.01 (29) “Pesticide drift” means pesticide deposited outside a target application site as a result of pesticide movement caused by air currents or diffusion. Note: See s. ATCP 29.50 (2), which prohibits any person from using a pesticide in a manner that results in significant pesticide drift. (30) “Pesticide overspray” means pesticide deposited outside a target application site as a result of an applicator’s failure to control the direct flow or application of pesticide from the application equipment so as to confine it to the target application site. Note: See s. ATCP 29.50 (2), which prohibits any person from using a pesticide in a manner that results in significant pesticide drift. ATCP 29.50 Pesticide use; general. (2) OVERSPRAY AND DRIFT. (a) No person may use or direct the use of a pesticide in a manner that results in pesticide overspray or significant pesticide drift. Response: EPA presumes the commenter is referring to the following regulations by the Wisconsin Agriculture, Trade and Consumer Protection – ATCP 29.10 (29 and 30) and ATCP 29.50. These regulations define pesticide drift and pesticide overspray and prohibit “a person from using a pesticide in a manner that results in significant pesticide drift” and “that results in pesticide overspray”. EPA has considered performance standards for spray drift in a variety of internal and external discussions, but has not yet been able to reach a consensus position. On November 4, 2009, EPA published a notice in the Federal Register (74 FR 57166) seeking comment on a draft Pesticide Registration Notice entitled “Pesticide Drift Labeling.” The documents are available at http://www.regulations.gov using docket identifier EPA-HQ-OPP-2009-0628.
However, even if EPA were to adopt some form of performance standards to prevent drift, EPA believes applicators need readily available information on potential drift reduction technologies. Labels, of course, would provide the specific measures for that particular pesticide product. EPA believes that it is important to identify drift reduction technologies, quantify the percent reduction, and then make this information available to applicators. |
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Response: The commenter raises a good point. EPA limited the protocol to technologies for application to row and field crops because a large majority of agricultural pesticides are applied to these crops by groundboom and aerial equipment. Thus, a focus on encouraging the use of DRTs for row and field crop uses should have an overall greater benefit to drift reduction.
Orchard and vineyard crops may require the use of significantly different application equipment. The Agency believes that certain ground spraying applications (i.e., technologies having the nozzle directed at the ground) in orchards and vineyards could be conducted using EPA’s protocol. However, at this time, EPA believes that the test protocol for spraying orchards and vineyards with the nozzle directed upwards as in some air blast applications is different from the current draft protocol for row and field crops. The reasons for these differences include significantly different crop geometries, and a diversity of sprayer configurations for orchard and vineyard crops. For example, application equipment used for orchard tree and vine crops typically direct sprays horizontally and upwards into the foliage, although some equipment, such as tower sprayers direct sprays in a downward angle. These methods of applications are quite different to those for row and field crops that are directed downward to the ground or crop canopy. There is also significant diversity of sprayer configurations for orchard and vineyard crops. In consideration of the above variations, EPA may consider expanding this voluntary program to application technologies specific to orchard and vineyard crops in the future.
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Response: EPA fully supports the use of application methods, technologies and integrated pest management that offer the benefit of fewer pesticide applications and/or reduced application rates, which can reduce the pesticide load on the environment. For example, current pesticide label rates are stated as maximums as recommended by pesticide registrants. The construct of the federal pesticide law, the Federal Insecticide, Fungicide and Rodenticide Act, requires EPA to determine whether or not a pesticide’s risks from the maximum labeled rates and other use restrictions meet safety standards. If the risks are acceptable the pesticide is eligible for registration. FIFRA also allows applicators to apply less than the maximum, as circumstances allow, as long as all other label requirements are followed. GPS and other automated technologies when used with application equipment offer the option of turning off the spraying equipment for areas that do not need the pesticide application, or in circumstances such as turning-around at the end of a row. EPA agrees with one of the commenters, that the competing factors of biological control efficacy, airborne spray drift, and spray losses on the ground must be carefully balanced to reduce the total amount of pesticide use. Similarly, EPA believes that the DRT Program can work to reduce the pesticide load on the environment. By increasing the use of technologies that decrease pesticide drift, applicators can reduce the off-target drift and deposition of pesticides. Thus, this works to decrease the pesticide load to the environment. |
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Response: EPA believes that the DRT Program will inform and educate applicators, registrants, and the public on the advancements in pesticide application equipment and techniques. The continued education of applicators on application techniques and best management practices, including the use of DRTs, is a very important component of managing spray drift. Applicators will have readily-available and up-to-date information on which application technologies have the potential to provide superior spray drift reduction. The program is also a way of giving credit to those applicators who purchase and use these newer techniques. EPA financially supports applicator education and training programs, including the Professional Aerial Applicators’ Support System program. EPA believes that use of DRT technologies offers the potential for (1) fewer/reduced application restrictions needed to mitigate spray drift from the intended application site(s), (2) application of more of the spray on the target site or crop which can improve efficacy, (3) a potential reduction in the associated potential risks, and (4) a reduction in costs to the applicator and grower (reduced potential for insurance claims and enforcement penalties). Thus, applicators and growers will have incentives to use these drift reduction technologies. As applicators and growers use DRTs on a more routine basis, benefits will accrue. Whether or not the costs of the program will exceed the benefits will be determined by the degree of participation in the program.
Another important aspect of the DRT Program is that the results of DRT studies on a variety of technologies will provide EPA with high quality science to improve our quantification of spray drift from a variety of applications. This enables EPA to make its decisions on managing risks, such as calculating buffer zones, with greater precision and that reflect the use of specific application equipment and the underlying scientific data. As a result of the voluntary program, EPA hopes that industry will test their existing technologies/equipment. The DRT Program could also lead to the development of application technologies with far superior drift reduction capabilities. Such information would eventually be incorporated into training programs and education materials for applicators. |
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In responding to these Technical Comments EPA consulted with several members of the technical panel EPA established in 2006 to develop test methods to verify the potential effectiveness of drift reduction technologies. At a later date, their comments were evaluated in internal EPA discussions to determine how to respond to these Technical Comments.
General Comments |
With regards to conducting DRT field studies, other commenters advocated for a FIFRA-type guidance document for these studies and asked for “the option for registrants or manufacturers to conduct these studies to support regulatory approval under GLPs should they choose to do so.” Additionally, one commenter asked if manufacturers and producers would be able to conduct their own testing. Would EPA provide for certification of in-house labs?
Response: Although the protocol for DRT studies has guidance on reporting results of studies, EPA agrees that additional information would be helpful, and intends to develop a template type of format for reporting DRT data to EPA. This format would be posted on EPA’s DRT webpage. While providing information to equipment manufacturers and testing facilities that wish to submit study results to EPA for evaluation, the format would also standardize submissions, thus potentially decreasing costs and time for preparing study reports and the agency’s review of those reports.
EPA requires the submission of raw data for all studies to enable our scientists to determine the quality of the study. The raw data is needed to ensure that any submitted analyses or computations were done correctly and can be transparently reproduced during EPA’s review and evaluation. The DRT protocol includes general guidance for the conduct of field studies. EPA encourages companies who wish to conduct a field study to consult with EPA about the proposed study protocol prior to the conduct of the study. Because the conduct of field studies can be complex and expensive, companies would benefit from having a mutual agreement of the protocol with the agency. Also, companies may choose to conduct these studies with GLP standards which are higher standards than those included in the agency’s DRT protocol. |
Response: The American Society of Agricultural and Biological Engineers (ASABE) provides a standardized test method to classify the spray from nozzles into six spray categories under static conditions (no wind). The testing needed for a DRT rating is not performed under static conditions. As discussed in response to comment 6 wind speed is a parameter that does become part of the testing parameters for the LSWT and HSWT. |
Response: EPA agrees that, at some time in the future, submission of the DRT protocol to a standard setting organization would be appropriate. At the present time, EPA will use the existing protocol to implement the DRT Program. |
Response: All of these factors, as well as applicator behavior, can impact the DSD of a spray application in the field. Certain variables can be controlled by the applicator, including nozzle, use of a drift reduction adjuvant, and system pressure, while other factors are environmental, including temperature and humidity. Studies provided to EPA and in the published literature demonstrate the relative importance each of these variables can have on DSD and spray drift. Certain variables, such as nozzle characteristics, system pressure, applicator speed, effective drift reduction adjuvants and application rate, are primary variables while temperature and humidity are secondary. For this reason, and in consideration of practicality and costs, the agency developed the DRT protocol for wind tunnel tests to focus on nozzles, nozzle/drift reduction adjuvant combinations, and system pressures. Temperature and humidity are to be at typical application levels and should be recorded and reported with the study. Field studies will also measure these and other variables. |
Response: The VMD is often referred to as Dv 0.5. A Dv 0.5 = 200 microns means that the diameter of half the spray droplets are greater than 200 microns, and half are less than 200 microns. In a similar manner, Dv 0.1 means that 10% of the droplets are smaller, and Dv 0.9 means that 90% or the droplets are smaller. The DRT rating represents the percent reduction between the driftable fraction of the reference nozzle as compared to that of the nozzle being tested. To calculate the percent reduction, the protocol illustrates in Appendix B a suggested table format for providing to EPA, the droplet diameters, including descriptive statistics such as the diameter (volumes) for the 10th, 50th, and 90th percentiles (Dv 0.1, Dv 0.5, and Dv 0.9 ) including the volume of driftable fraction described in response to comment 10. |
Response: EPA acknowledges that some of the calculated percent reductions will be very close to one side or the other of the “boundary lines” that will define the DRT-rating categories. EPA also understands that all data points have an inherent “plus or minus” that is part of the consideration of the quality of the data. However, considerations for program implementability mean that the star rating categories will need to operate as “hard-lines.” This means that a percent reduction of 24% will not have a DRT rating and that a reduction of 26% will be DRT*. As discussed in response to comment 12, EPA’s process for including the DRT rating in its risk assessment means that an assumption of droplet size distribution from the lower end of each DRT category, (e.g., 25% reduction of driftable fraction) will be used when estimating a pesticide’s potential off-target spray drift deposition for risk assessment and risk management measures. |
Response: EPA does not consider this a practical approach for determining appropriate buffer zones for aircraft (fixed or rotary wing) or for ground boom sprayers for multiple reasons. Buffer zones and other use restrictions are a function of each pesticide’s toxicity, the amount of applied pesticide, the application methods and the DSD of the spray. This is discussed in more detail in response to comment 12. Additionally, having a baseline standard of driftable fractions (fines) for aerial applications, and presumably for groundboom applications, would constitute a requirement for all aircraft and groundboom systems to be tested to determine whether their spray systems do not exceed the baseline. As applicators change/modify their systems (e.g., different nozzles, tank mixes, etc.) they would need to retest. |
Low speed wind tunnel protocol |
• Quantifying load on the line such that it is not saturated. • Translation of the line to a meaningful area. • Appropriate distance per applied spray energy.” Given their concerns, the commenter believes that the use of lines (or strings) should not be a standardized procedure. Response: As discussed in response to comment 15, EPA has decided to revise the protocol to limit the low speed wind tunnel study to measuring DSD with laser diffraction equipment. EPA recognizes the WTDISP model that would be needed for the evaluation of flux data from use of monofilament lines, is not yet fully developed. The laser methodology will provide the needed information to calculate the percent drift reduction. Therefore EPA will standardize our testing protocol on the laser methodology. |
Response: This comment pertains to the use and height of monofilament stings. As explained previously in responses to comments 15 and 33, EPA revised its protocol to standardize the use of lasers to measure DSDs. |
Response: As previously noted, EPA’s protocol was developed using a technical panel composed of technical experts external to the agency. The protocol is considered to be guidance, not a mandatory requirement that must be met in order to submit a DRT study to EPA for evaluation. However, use of EPA’s protocol means that such a study is likely to meet the needs of EPA for high-quality information. EPA readily acknowledges that other protocols exist. Data generators are free to use a protocol of their choosing as long as the submitted data supplies the information needed by EPA. Regarding the commenter’s suggestion the protocol give the dimensions for wind tunnels as minimum dimensions, the protocol for the low speed wind tunnel does give the dimensions as minimums: “… dimensions at least 1.75 meter (m) wide ....” Without being too prescriptive on the dimensions, this provides some flexibility and accommodation for wind tunnel setups. However, it is important as noted in the protocol “The tunnel must be of sufficient width so that the spray pattern does not impinge on the walls of the tunnel.” to avoid wall effects affecting the DSD. EPA recommends technology manufacturers and testing organizations consult with the agency prior to testing if there are questions about these or any other test parameters. |
Response: In EPA’s protocol both sections B1 and C1 provide a description of the nozzle reference system, which is described as “ASABE S572.1 fine/medium boundary reference nozzle [Flat fan 110° at 300 kPa (43.5 psi)].” A single reference nozzle is appropriate to allow consistent comparisons across different technologies for assigning DRT ratings and for risk assessments as described in response to comment 12. |
Response: Published literature suggests that a collection distance of 20 to 60 cm downward from the tip of the nozzle represents the range where the test substance is fully atomized and is therefore the “optimal sampling distance.” The comment regarding flux measurement is now moot since EPA has revised the protocol to measure only DSD in wind tunnels. |
Response: EPA agrees that one of the most important aspects of data collection is the use of a standard reference nozzle as described in prior responses to comments and in the protocol. The use of a single reference nozzle by all testing facilities will provide a consistent standard for making comparisons of DSDs, DRT ratings and the agency’s risk assessment and risk management decisions for pesticide product registration. |
Response: EPA notes that the protocol specifies air speed for low speed wind tunnel testing as “Between 2 m/s and 10 m/s”. This is equivalent to 4.5 mph and 22.4 mph” (see Table 3. DQIGs for Low Speed Wind Tunnel Testing). This air speed range simulates typical speeds of ground boom sprayers while applying pesticides. EPA believes this upper range of air speed and suggested tunnel dimensions and laser measure will allow proper measurements of DSDs. The testing speed is important; however, EPA believes that small changes in a variety of testing variables due to the “set-ups” in different testing facilities are evened-out by the use of a single reference nozzle. As previously discussed, the use of a reference nozzle provides a consistent standard for measuring percent drift reduction. |
Response: EPA believes that testing the impact of a canopy is more complex than a LWST can accommodate. Before initiating a drift reduction study for a canopy, EPA suggests the technology manufacture and testing organization consult with EPA. |
Response: As explained in responses to comments 15, 33 and 34, EPA revised its protocol to standardize the use of lasers to measure DSDs. However, if an equipment manufacturer prefers to measure flux, then EPA suggests the manufacturer and testing organization consult with EPA before testing begins. |
Response: As discussed in response to comment 39, the protocol specifies an air speed from 2 m/s (4.5 mph) up to 10 m/s (22.4 mph) in low speed wind tunnels for testing nozzles or other technologies. As discussed in various responses, the agency believes a single reference nozzle is critical for the reasons provided. However, the agency supports and expects technology manufacturers will want to conduct tests with multiple pressures. |
High speed wind tunnel protocol |
Response: The 165 mph is not a maximum; testing can be conducted at higher speeds. We recognize that fixed wing aircraft often apply the pesticide product at speeds greater than 165 mph. |
Field studies protocol |
Response: The correct text from the protocol is “Note, the applicability of the site characteristics to verification data generation and acquisition have not been evaluated.” (A6.2.1 Test Site Description, Field testing.) EPA acknowledges this sentence is unclear and is unnecessary therefore, the agency has deleted it. The text of this section includes some parameters for field study design and measurement. The intent of the sentence was to convey that, because field studies are complex to design and conduct (e.g., test site variability and changes in metrological conditions) and are unique, the specific parameters mentioned may not be applicable to all field studies. The protocol recommends that the testing organization collect many measurements of the study. These measurements are typical of well-conducted and published field studies and they can be critical for interpretation of the study results and reaching sound conclusions. |
Response: The purpose of a field study for DRT verification is to measure deposition of spray drift downwind from the treatment site. For this reason, measuring downwind samples of airborne spray drift at multiple heights is not necessary. |
Response: Test guidance in ASABE S561.1 provides sufficient information on wind speed and direction. |
Response: The focus of the testing is to achieve a comparison, i.e., the reference nozzle versus the technology being tested. There is no need for additional data on turbulence. |
Response: Yes, vegetation height is listed in Table 8 as a consideration for conduct of a field study. EPA does not believe that such a consideration is needed for a wind tunnel study to measure DSDs. |
Response: EPA agrees the tank mix and ambient temperatures do not need to be the same. Temperatures of both, however, should be recorded and reported. EPA will revise the protocol to reflect this. |
Testing of Adjuvants |
Response: As previously discussed, EPA believes that combinations of various nozzles and adjuvants will be tested and may qualify for a DRT-rating. However, it is more problematic to test a percent reduction for just an adjuvant because adjuvants are used with nozzles, and therefore EPA will not establish DRT-ratings for adjuvants only. This means that there will not be specific information for testing of adjuvants only in the protocol. |
Response: EPA developed the protocol for many types of application technologies; this is described in section A6.1. The agency expects a variety of small technologies can be and will be tested in wind tunnels. EPA expects nozzles will be the most commonly tested technology for the following reasons: (1) all spraying requires nozzles; (2) the large number and variety of nozzles manufactured and available in the market; (3) compared to some other technologies, nozzles are easy and relatively inexpensive to replace; and (4) nozzle testing can be performed in wind tunnels and is less expensive than field testing. For these reasons, much of the protocol does focus on testing of nozzles. However, the protocol can also be used for testing other drift reduction technologies such as nozzle/adjuvant combinations, and other, larger technologies. If the commenter is suggesting that registered pesticide formulations per se be included in the DRT Program, EPA is not planning to include pesticide formulations in the program for a DRT rating. While some pesticide formulations may have inherent drift reduction potential when used under certain conditions, EPA does not plan to assign DRT ratings to pesticide formulations. EPA views this approach as impractical given the almost infinite combinations of tank mixes, tank mixes change over time as new pesticides enter the market while others leave the market, and registrants often revise their product formulations which could affect DSDs. A pesticide registrant may submit data supporting a pesticide formulation’s drift reduction potential and, EPA will consider those data in conducting its assessments of potential spray drift risk and risk management for the registration decision. |
Response: Under the DRT Program, EPA is not requiring the use of a particular protocol. Equipment manufacturers can use a protocol such as ASTM E2798-11 as stated in the DRT protocol, or develop their own protocol. EPA would likely accept a study that is conducted according to ASTM E2798-11, providing that the data is of appropriate quality and that the percent reduction in the driftable fraction can be calculated. If the equipment manufacturer wishes to develop their own protocol, then EPA suggests that they consult with EPA to make sure that the protocol will provide the data needed by EPA. Including specific pesticide active ingredients as a variable in the DRT test protocol would greatly complicate the testing program and rating system. Data submitted to EPA by the Spray Drift Task Force suggest that the active ingredient plays a relatively minor role in affecting drop size distribution and spray drift. |
General/Misc. Comments on Testing |
Response: EPA believes that there can be only one reference nozzle, since this nozzle must be the standard used across the testing, to provide for comparable data. The reference nozzle selected for EPA’s DRT Program is the same nozzle recognized by the ASABE. This same nozzle was the standard nozzle used by the Spray Drift Task Force. The UK, Netherlands, and Germany also use the same reference nozzle. Given the nozzle’s wide acceptance, there has been a significant amount of data generation with the reference nozzle. This significant data generation forms the basis for the AgDrift Model, which has undergone multiple peer-reviews. Similarly, the data forms the baseline for EPA’s quantification of spray drift in its environmental risk assessments. |
Response: There are a number of reasons for not adopting the commenter’s suggestion: (1) the primary purpose of this program and test protocol is to compare technologies to a standard; (2) the increased number of combinations of multiple pesticide formulations with nozzles and with nozzle/adjuvant combinations; (3) pesticide active ingredients and their formulations marketed to applicators vary of time; (4) greatly increase costs to industry to conducting many more studies; and (5) some wind tunnel testing facilities may not be set-up to process any solution other than the test solution of distilled water plus a small amount of surfactant. EPA believes that the proposed test solution of water and surfactant will provide a reasonable basis for making decisions on DRT ratings. |
Response: As previously discussed, EPA’s protocol will standardize on the laser methodology to measure DSDs. |
Response: Using design specifications only, EPA believes that it would be a challenge to prove that two nozzles are exactly the same. Small differences in manufacturing and production could lead to small differences in droplet size, which can result in different percent drift reduction. The proof that the two nozzles operate exactly the same is the DRT testing. |
Response: EPA would encourage equipment manufacturers and others to discuss these suitable peer-reviewed methods with EPA as part of a protocol review before initiation of the study to assure that the study will provide the information needed by EPA. |
Response: AgDISP and AgDRIFT (for aerial application) are mechanistic models and have flexibility to incorporate DSD and many other variables required to predict spray drift. However, the groundboom scenario in AGDISP has some limitations and the developer of AGDISP model is working on improving the predictability of the model. Since the groundboom scenarios of AgDRIFT are based on empirical curves, which may not be suitable for DSD generated by DRT nozzles, the AGDISP model will be used to assess the relative differences in deposition between the reference nozzle and that of the respective DRT categories. |
Response: EPA does not recommend laboratories or testing facilities. As discussed in the protocol, the submitted report should contain information on the facility’s Quality Assurance/Quality Control activities. The protocol states that EPA may conduct assessments of test facilities.. The company wishing to contract with the testing facility should carefully review and judge the suitability of the laboratory. |
| File Type | application/vnd.openxmlformats-officedocument.wordprocessingml.document |
| Author | jellenbe |
| File Modified | 0000-00-00 |
| File Created | 2021-01-27 |