If you haven't heard, Accord concentrate's label is expiring this year and will not be renewed.  (Note: this does not include Accord XRT II.)  DOW Agro has replaced Accord Concentrate with Rodeo, which has the same formulation that Accord had.  However, in doing due diligence, I was surprised to find that beech is not listed on the label as a species controlled by the product.  Looking back at the Accord label, beech is not listed on that label either.  Obviously, we all know it works, but NYS law requires the target species be listed on the label, otherwise a 2ee is required. 

So, what glyphosate concentrate products are folks using for cut stump applications that are actually labeled for use on beech?  Many of the glyphosate products that contain a surfactant will list beech as partially controlled, but since the applications I am prescribing will be cut stump or cut frill (hack and squirt), A surfactant should not be needed, correct?

How do people feel about using an herbicide with a surfactant when doing cut stump or hack n squirt?  Would using one with a surfactant be wasteful, cost effective, and/or not particularly environmentally sensitive?

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Hi Chris:


Good point about Rodeo's label lacking the specific reference to beech.  I don't know what it would take to get a 2(ee) for Rodeo, but it is probably worth investigating given the potential utility of the product.

Round-up Pro Concentrate lists beech on the label.  (EPA #524-529, 50.2% glyphosphate)  It also include 'cut stump" as a method, so this would make the product legitimate.  I haven't recently done a price comparison of Round-Up Pro Concentrate vs. Rodeo, so I can't speak to the cost issue.  Given the controlled nature of treatment via cut-stump, I wouldn't see the extra surfactant as having any significant environmental concerns.

Other labels that list beech include: Razor Pro (41% glyphosate, EPA # 228-366), Ranger Pro (EPA 524-527, 41% glyphosate), and Round-up Pro Max (EPA 524 - 579, 48.7% glyphosphate).  The later does not explicitly list a surfactant although I didn't fully read the label.  Both Razor Pro and Ranger Pro include a surfactant.

Anyone know what it takes to get a 2(ee) in NY?

See my new profile of forest herbicides in the questions section for a link to the pesticide labels.

Peter

I've been in contact with our regional pesticides guy at Cortland DEC.  His opinion is that the loose wording in the stump cut section of the label would allow application of Rodeo to beech (though he would prefer a 2ee); however, a 2ee would be required for any other application of Rodeo to beech, such as hack and squirt or foliar. 


I believe Round-up Pro Concentrate contains 13% surfactant.  In my review of labels last week it looked as though any label that listed beech was for a product that contained surfactant.  It is also strange that the labels usually specified for partial control or suppression of beech, but not full control.


With all that in mind, I've written up recommendations for a 2ee for the control of beech using Rodeo within forestry sites and will be submitting them this week.  Assuming there are no hang-ups, I will post the approved 2ee here when I get it. 

I have obtained a 2ee for application of Rodeo to beech within forestry sites.  I believe this should be flexible enough for most applications.  It is attached below. 

Attachments:

Hi Chris:


This is great news!  On behalf of everyone who is trying to control beech, we appreciate your effort. 

I see that the 2ee requires the use of a non-ionic surfactant for foliar treatments of beech.  Beech is reasonable responsive to Rodeo without the surfactant.  Do you know, or does your herbicide guy, if forestry applications can use the "less than recommended dose" waiver as an agricultural practice and not include the non-ionic surfactant?

Many thanks again,

Peter

Hi Pete,

I received this response to your question from the pesticides guy at DEC in Cortland:

"The surfactant requirement is a label requirement from the manufacturer...As for applying at less than label rate...when applying pesticide for agricultural purposes only, then the application can be made at a dosage, concentration, or frequency less than that on the label (Article 33-0725). That said they cannot exclude the surfactant. If they reduce the dosage rate of the pesticide the surfactant may be reduced proportionately."
.
I can apply to revise the 2ee, but I will need supporting documentation (published research) for use without a surfactant. 
 
Chris

I sent this email to the CCE Forestry e-list, but thought some here might want to see it.

=============

There are many owners and foresters who have sought a glyphosate-based product, without a surfactant, to control American beech.  In NY, the pesticide (herbicide) label must explicitly list the pest to comply with the law.  American beech is not listed on the original Rodeo label (Rodeo replace Accord, which also didn’t list beech). Until now, there were no glyphosate based products without a surfactant that listed beech.  Now, the 2(ee) supplemental label (see below) allows for the legal use of Rodeo on beech via foliar, frill/injection, and cut-stump application methods.

 

Rodeo is a “restricted use” pesticide in NY not because of any inherent concerns with the product, but because it is NYS policy (as I understand) to restrict any pesticide that is labeled for use in aquatic systems.  The “restricted use” designation means that purchase of the product is only possible by private or commercial certified applicators.   As noted below, the 2(ee) and full labels must be in the possession of the applicator at the time of treatment.

 

The PIMS web link below contains labels for every pesticide registered for use in NY.  For glyphosate-based products that can be purchased by anyone (i.e., unrestricted) and that list beech, go to the PIMS site and look for labels on Ranger Pro, Razor Pro, Round-up ProMax, and Accord XRT II.

Here is the PIMS link mentioned above (click here)

Hi Chris, thanks for putting in your time to get this 2ee for Rodeo, I wish i was able to utilize it as a "technician". The one question I have is why the need to stick with a glyphosate based herbicide? There are other herbicides that list American beech, Arsenal(for cut stump and hack and squirt) and Pathfinder II(for cut stump and basal bark treatments), niether have surfactants built in and neither are "Restricted Use"

Dan,

We've always preferred to use glyphosate on beech because it is generally considered to be a relatively safe pesticide with very low toxicity in the surrounding environment.  (Perhaps other people could speak more on the relative safety and environmental impact of these three herbicides.)  Also there has been a lot of research showing its effectiveness on beech, particularly its ability to readily translocate to other beech trees.  And in foliar applications, other non-target (desirable timber) species such as sugar maple are not as susceptible to glyphosate and can withstand some accidental overspray.

Through experience we have found Arsenal to be the herbicide of choice for striped maple.  I'm not sure we have used Pathfinder, but we have used Garlon4, which is another triclopyr product made by DowAgro.  Not sure the difference between the two.  Also, the basal bark treatments can be difficult to assess in the time frame of our timber contracts if the contractor does not do the application the first year of the contract.    

Chris

Our contract process sure does throw a wrinkle in our herbicide plans many times.  In an ideal world, we would be able to treat the interferring vegetation one full growing season before letting the contractor cut any trees and creating holes in the canopy which might trigger accellerated growth of the undesirable species.  We both know we will never see dedicated funds set aside for treating interferring vegetation outside of "sale related" work.

Hi Dan:

I agree with Chris on the value of glyphosate as the herbicide that most readily and completely translocates when applied via cut stump, and to some extent via hack and squirt.  Dave Jackson (PSU) has a good publication you've perhaps seen (here) that includes a chapter on herbicide toxicity.  Most of the common forestry herbicides have relative high LD50s (= low acute toxicity); Dave gives some comparison to common chemicals such as caffeine and nicotine that are more toxic.

Pathfinder II is the pre-mix of Garlon 4 and basal oil.  Probably a bit more expensive than buying the components, but it is a general use and thus accessible to everyone.  If you can buy the components, you can adjust the concentration of the Garlon 4, which the label allows for concentrations lower than those in Pathfinder II.  I understand that spring and early summer treatments can be effective with lower concentrations of Garlon 4 as the trees are actively growing.  I'd had to check with Dave for his details.  Garlon 4 is comparatively expensive, thus the value in finding lower but effective concentration rates.

Hopefully for their sake they are using products such as these.

Hi Lewis:


I haven't checked with the NYS label website (here), but as you may know any pesticide needs to have an approved label for NYS.  Also, one of the values of Rodeo is that you can apply it with reduced amounts of surfactant.  Surfactants, typically a type of soap, can have some unfavorable reactions with some species.  For example, using reduced surfactants concentrations, close to zero, reduces the impact on sugar maple seedlings.


Peter

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