1

COMPILED CONSULTATION RESPONSES 

for

Drift Reduction Technology (DRT) Information 

Collection Request (ICR)

As described in the supporting 2012 Supporting Statement for this proposed ICR, EPA contacted 

five stakeholders to seek specific feedback on the practical utility of the voluntary information 

requested, the burdens or costs estimated by EPA, clarity of guidance provided, and collections 

methods. A fill-in-the-blank questionnaire was sent to all five stakeholders. Three of these 

stakeholders returned responses to EPA. Their responses are compiled in this document which is 

Attachment D. EPA merely compiled the responses, no changes were made.
2

Consultation Questions for Drift Reduction Technology (DRT) Information 

Collection Request (ICR)

Name of Respondent: [William E. Bagley]

Respondent’s Affiliation: [Manager – Application Technology, Wilbur-Ellis Company]

(1) Publicly Available Data/Avoiding Duplication

 EPA is seeking data that will verify the effectiveness of drift reduction application 

technologies for agricultural pesticide sprays. The Agency and others have 

developed a protocol for testing of DRT technologies. Use of a standard protocol 

will allow for comparisons across technologies and products. Are similar data 

suitable for comparison available from any other source that is publicly-available, 

or already collected by another office at EPA or by another Federal agency?

Response [No]

 If yes, where can you find the data? Is this data a true (total) duplication, or given 

the data elements that are available, would they only partially meet our data 

needs? 

Response [ ]

(2) Clarity of Instructions 

 The DRT protocol specifies the specific data to submit and how to format the data 

for submission. The ICR asks respondents to voluntarily provide specific data so 

that the Agency can use these data in a risk assessment. Do you understand the 

types of data that could be acceptable to EPA, and how to format and submit these 

data to EPA?

Response [ No. There is no clear set of instructions of actual data needed and format for 

submission. This is probably the most concerning and confusing issue of the program.]

 The Agency is developing a webpage for the voluntary program. What 

information do you want on that webpage? 

Response [A listing of the required data documents and the format that EPA would like to 

receive them in. ]

(3) Electronic Reporting and Record keeping 

The Government Paperwork Elimination Act requires agencies make available to 

the public electronic reporting alternatives to paper-based submissions by 2003, unless 

there is a strong reason for not doing so. One such reason is that, at the present time, the 

Agency is unable to ensure the security of CBI that might be transmitted over the 
3

Internet. EPA has posted information on its website entitled, “Electronic Submissions 

(via formatted CD/DVD) to the Pesticide Program.” 

(http://www.epa.gov/pesticides/regulating/registering/submissions/#studies)

 What do you think about electronic alternatives to paper-based records and data 

submissions? Would you be interested in pursuing electronic reporting? 

Response [Yes, but this requires a clear understanding of data needed and a precise set of 

guidelines for data collection and submission formatting.]

 Is the information on the website sufficient so that you understand the process for 

submitting these studies electronically to EPA for review and evaluation?

Response [ No]

 Are you keeping your records electronically? If yes, in what format?

Response [ Both, because we do not completely understand what format will be acceptable by 

EPA. It is also confusing as to the requirements of quality control of data and the precise format 

needed by EPA.]

At this time, if the DRT study were submitted as part of an application for 

registration or amended registration of a pesticide product, then EPA would accept an 

electronic application. 

 Would you be more inclined to submit your application as a CD/DVD rather than 

on paper? 

Response [ Not at this time, but would certainly adopt this practice if beneficial.]

 What benefits would electronic submission bring you in terms of burden 

reduction or greater efficiency in compiling the information? 

Response [ Greater ease in handling and sharing information. But security of the data is of the 

utmost importance.]

(4) Burden and Costs

 The Agency has assumed that respondents would not conduct the DRT studies 

themselves, but would pay a contractor to conduct the studies. Is that correct?

Response [ Yes. The correct operational procedures and chain of custody are important. But to 

generate ethical and unbiased data it is essential to have a certified facility set up to handle test 

materials, operate equipment correctly and summarize the data in a standard format for 

submission.]
4

 Are the cost estimates for conducting the studies accurate? 

Response [ No. Since there is not a minimum set of operating procedures for collecting data and 

formatting information, there cannot be a true understanding of cost associated with this 

process.]

 The Agency assumes that once the respondent has paid the contractor to conduct 

the study(ies) that the respondent has no capital expenditures, or operation and 

maintenance costs associated with this activity. Is that correct? 

Response [ Yes. If there can be a clear understanding of data collection procedures, scope of 

needed data and required submission format.]

 Are there other costs that should be accounted for that may have been missed?

Response [ Yes. The true cost can only be established once the required record keeping, 

operational parameters of data collection, scope of data needed and required submission format 

be established by EPA.]
5

Consultation Questions for Drift Reduction Technology (DRT) Information 

Collection Request (ICR)

Name of Respondent: John Jachetta, Ph.D.

Respondent’s Affiliation: Dow AgroSciences LLC

(1) Publicly Available Data/Avoiding Duplication

 EPA is seeking data that will verify the effectiveness of drift reduction application 

technologies for agricultural pesticide sprays. The Agency and others have 

developed a protocol for testing of DRT technologies. Use of a standard protocol 

will allow for comparisons across technologies and products. Are similar data 

suitable for comparison available from any other source that is publicly-available

or already collected by another office at EPA or by another Federal agency?

Response: There are numerous wind tunnel and drift studies available in the public literature. 

However, these data have been collected with a variety of methods, many of which do not fulfill 

the protocol and may not be useful for risk management decisions. In some instances, field drift 

studies are performed to support registration and submitted to the EPA as operational validation

information; this information is often unique to the particular product and its labeled mitigation. 

 If yes, where can you find the data? Is this data a true (total) duplication, or given 

the data elements that are available, would they only partially meet our data 

needs? 

Response: The publically available droplet spectra data for almost all nozzles is developed by 

spraying water. While this information is useful in assessing equipment, many of these studies 

do not take into account formulation effects on droplet spectrum and therefore additional 

opportunities to reduce drift are lost. In this way, nozzle droplet spectra data can only partially 

meet the Agency’s goals for drift reduction. As currently written, the scope of the protocol for 

testing of DRT technologies is overly narrow and should incorporate more than physically-based 

technology. The DRT program should allow the assessment of chemistry-based drift reduction 

as part of a complete DRT system. Nozzles and other physical means can reduce drift by

creating very coarse to ultra coarse droplets; however, there is a trade off with reductions in 

spray coverage and potentially efficacy. Formulations which are specifically optimized for drift 

reduction can overcome the loss in efficacy by allowing applicators to select an appropriate 

nozzle for efficient pesticide delivery and pair it with the appropriate chemistry to achieve higher 

amounts of drift reduction. To account for both the physical equipment and chemistry-based 

drift reduction technology, the DRT program could use a tiered approach. The first tier could list 

physical equipment DRT star ratings, while the second tier would allow manufactures to 

optimize and test their formulation technology to determine the additional decrease in driftable 

fines and setback reductions. The reduction in droplets below a cut off (such as <141 μm) could 

thus be compared to a benchmark and used in risk assessments to determine reductions in buffer 

distances versus a reference. Manufacturers could list the equivalent technologies and 

combinations on the label with the DRT star rating and buffer distances as suggested by the 

Supporting Statement for an Information Collection Request (ICR). Allowing registrants to 

demonstrate their drift reduction technology will allow them to invest in technology that 

maximizes the benefit to the grower and the environment while receiving credit for the latest 

advances in formulation technology. The tiered approach would also give the industry flexibility
6

to encourage the adoption of drift reduction technology by providing incentives to implement 

and develop new formulation-based technologies to minimize drift.

(2) Clarity of Instructions 

 The DRT protocol specifies the specific data to submit and how to format the data 

for submission. The ICR asks respondents to voluntarily provide specific data so 

that the Agency can use these data in a risk assessment. Do you understand the 

types of data that could be acceptable to EPA, and how to format and submit these 

data to EPA?

Response: The generation and formatting of the data is clear. However, it remains uncertain how 

the data will be used in risk assessments. The current Agency drift assessments make quite 

selective use of this information and quickly default to conservative assumptions. For example, 

when both wind tunnel data and field research are submitted to the Agency, only the nozzle 

employed in that single field study is credited for drift reduction even though many nozzles may

have been tested and found useful in the wind tunnel work. As a consequence, though the 

benefit and incentives to nozzle manufactures for participating in the DRT program are apparent; 

it is far less clear how plant protection companies can contribute to the Agency’s goals by

submitting data to the program. Many publically available articles demonstrated that spray

solution has an effect on the droplet spectra. Because nozzles are combined with formulations 

and adjuvants, the program should give incentive to companies to optimize their label, 

formulation, and best use practices so that the greatest environmental benefit of the program can 

be achieved. As the DRT program exists today, there are no incentives to advance formulation 

science in the area of drift reduction and full advantages of the DRT opportunity cannot be 

realized.

 The Agency is developing a webpage for the voluntary program. What 

information do you want on that webpage? 

Response: Posting of nozzles and their drift reduction capabilities is obviously useful, but only 

in a limited way, as this information does not reflect the true drift reduction capability in the 

field. We find that programs like LERAP are severely hindered because the spray solution is not 

taken into account; the effectiveness of any nozzle technology is dependent on the formulation 

used. However there is still value in providing nozzle data using baseline chemistry like water to 

provide guidance on the current technologies available. Nonetheless, the product label remains 

the best vehicle to communicate drift reduction technologies that utilized the full range of 

environmental advantages available through both equipment and chemistry-based drift reduction 

technology

(3) Electronic Reporting and Record keeping

The Government Paperwork Elimination Act requires agencies make available to 

the public electronic reporting alternatives to paper-based submissions by 2003, unless 

there is a strong reason for not doing so. One such reason is that, at the present time, the 

Agency is unable to ensure the security of CBI that might be transmitted over the 

Internet. EPA has posted information on its website entitled, “Electronic Submissions 
7

(via formatted CD/DVD) to the Pesticide Program.” 

(http://www.epa.gov/pesticides/regulating/registering/submissions/#studies)

 What do you think about electronic alternatives to paper-based records and data 

submissions? Would you be interested in pursuing electronic reporting? 

Response: Electronic submissions have many advantages in both the delivery and storage of 

information. While the formatted CD/DVD-based submissions have clear advantages over 

paper-based submission in many areas for both the industry and EPA, the Agency may consider 

the additional advantages of a secure server for internet-based submissions. It is difficult to 

believe that this will even be a question ten years from now.

 Is the information on the website sufficient so that you understand the process for 

submitting these studies electronically to EPA for review and evaluation?

Response: Yes, the great majority of our data submissions employ electronic submissions via

the formatted CD/DVD.

 Are you keeping your records electronically? If yes, in what format?

Response: Yes, as pdf-files or in spreadsheet form.

At this time, if the DRT study were submitted as part of an application for 

registration or amended registration of a pesticide product, then EPA would accept an 

electronic application. 

 Would you be more inclined to submit your application as a CD/DVD rather than 

on paper? 

Response: Yes; electronic submissions employing the formatted CD/DVD are standard practice 

at Dow AgroSciences.

 What benefits would electronic submission bring you in terms of burden 

reduction or greater efficiency in compiling the information? 

Response: Electronic submissions facilitate global use of the data or studies to support 

registration actions around the world, therefore the advantages are significant.

(4) Burden and Costs

 The Agency has assumed that respondents would not conduct the DRT studies 

themselves, but would pay a contractor to conduct the studies. Is that correct?

Response: Yes. However, crop protection companies are greatly hindered by the lack of wind 

tunnels in the U.S. that meet the protocol requirements. We have performed tests at the 

University of Nebraska wind tunnel and have had great success demonstrating drift reduction. 
8

The EPA may consider working with wind tunnels in the U.S. and certify them for the DRT 

program. Certifying wind tunnels would add transparency to the process and give companies 

confidence that testing their technology will fulfill the DRT data collect requirements. 

Additionally, data quality should be assured through the use of GLP and not some other QA/QC 

mechanism as currently outlined in the DRT protocols, this simply increases the difficulty and 

expense of the studies with no advantage or gain for any party.

 Are the cost estimates for conducting the studies accurate? 

Response: They are accurate only if the tests can be performed within the U.S. (see response 

below). 

 The Agency assumes that once the respondent has paid the contractor to conduct 

the study(ies) that the respondent has no capital expenditures, or operation and 

maintenance costs associated with this activity. Is that correct? 

Response: No. While the Agency’s assumption is correct for the conduct of a specific drift 

study, these studies do not exist in a vacuum. This assumption does not consider the associated 

tasks and considerable support necessary for the development of risk assessments, the 

implementation of identified mitigation and advances in labeling.

 Are there other costs that should be accounted for that may have been missed?

Response: Additional costs are very likely; however these costs cannot be estimated because the 

end-use product label language and the utility of the data for risk assessments have not been 

made clear. Substantial investments in time and expert personal are expected to be necessary in 

developing new risk assessments and mitigation, this investment is only increased by the absence 

of Agency direction on data utility. Further, if crop protection companies are forced to send 

product out of the country to perform wind tunnel trials because of the lack of suitable facilities 

in the US, then significant additional costs will be accrued for research, permits and shipping. 
9

Consultation Questions for Drift Reduction Technology (DRT) Information 

Collection Request (ICR)

Name of Respondent: [ Greg Kruger ]

Respondent’s Affiliation: [ University of Nebraska-Lincoln ]

(1) Publicly Available Data/Avoiding Duplication

 EPA is seeking data that will verify the effectiveness of drift reduction application 

technologies for agricultural pesticide sprays. The Agency and others have 

developed a protocol for testing of DRT technologies. Use of a standard protocol 

will allow for comparisons across technologies and products. Are similar data 

suitable for comparison available from any other source that is publicly-available, 

or already collected by another office at EPA or by another Federal agency?

Response [ While I am not familiar with the data available at the EPA and other federal agencies, 

there is considerable data from good research which exists and should be further investigated 

prior to potential duplication of new data. While the burden of proof on whether the data is 

produced in a manner which is acceptable should be investigated, there is likely a lot of data that 

already exists which could save time, money and other resources from being used if the studies 

were conducted in a sufficient manner to support the needs of the DRT program. We have 

conducted numerous studies and some are likely sufficient to meet the needs of the DRT 

program and I hope that they will be considered without needing to repeat them. I suspect that 

there are other facilities which also have data available which could be used as well. ]

 If yes, where can you find the data? Is this data a true (total) duplication, or given 

the data elements that are available, would they only partially meet our data 

needs? 

Response [ I suspect that data exists that will meet the needs of the DRT program while there is a 

lot of data which is only partial in nature and will need to be repeated. I think that the EPA will 

have a lot of work initially sorting out studies which were conducted in an acceptable manner 

prior to the release of the protocol and there will be some studies which need to be repeated to 

complete the dataset or conducted slightly different to meet the required specifications. ]

(2) Clarity of Instructions 

 The DRT protocol specifies the specific data to submit and how to format the data 

for submission. The ICR asks respondents to voluntarily provide specific data so 

that the Agency can use these data in a risk assessment. Do you understand the 

types of data that could be acceptable to EPA, and how to format and submit these 

data to EPA?

Response [ The data required is specific and clear. If there is a format that would help streamline 

evaluation of DRTs is unclear. As those testing DRTs and submitting data on DRTs become 

more familiar with the process, it will likely become more efficient. ]
10

 The Agency is developing a webpage for the voluntary program. What 

information do you want on that webpage? 

Response [ ]

(3) Electronic Reporting and Record keeping 

The Government Paperwork Elimination Act requires agencies make available to 

the public electronic reporting alternatives to paper-based submissions by 2003, unless 

there is a strong reason for not doing so. One such reason is that, at the present time, the 

Agency is unable to ensure the security of CBI that might be transmitted over the 

Internet. EPA has posted information on its website entitled, “Electronic Submissions 

(via formatted CD/DVD) to the Pesticide Program.” 

(http://www.epa.gov/pesticides/regulating/registering/submissions/#studies)

 What do you think about electronic alternatives to paper-based records and data 

submissions? Would you be interested in pursuing electronic reporting? 

Response [ I think electronic submissions would be great; I am in favor of pursuing electronic 

reporting. ]

 Is the information on the website sufficient so that you understand the process for 

submitting these studies electronically to EPA for review and evaluation?

Response [ ]

 Are you keeping your records electronically? If yes, in what format?

Response [ We keep all of our records in Word, Excel and in Adobe PDF files. ]

At this time, if the DRT study were submitted as part of an application for 

registration or amended registration of a pesticide product, then EPA would accept an 

electronic application. 

 Would you be more inclined to submit your application as a CD/DVD rather than 

on paper? 

Response [ ]

 What benefits would electronic submission bring you in terms of burden 

reduction or greater efficiency in compiling the information? 

Response [ The electronic submission process would make things much more efficient. ]
11

(4) Burden and Costs

 The Agency has assumed that respondents would not conduct the DRT studies 

themselves, but would pay a contractor to conduct the studies. Is that correct?

Response [ I expect most companies that produce DRTs will work with an external contractor, 

but there will likely be some companies that conduct their own studies if possible. ]

 Are the cost estimates for conducting the studies accurate? 

Response [ I believe the cost estimates to be accurate. The costs are likely a minimum for testing 

though. ]

 The Agency assumes that once the respondent has paid the contractor to conduct 

the study(ies) that the respondent has no capital expenditures, or operation and 

maintenance costs associated with this activity. Is that correct? 

Response [ That is probably correct for companies that are working with an external contractor. ]

 Are there other costs that should be accounted for that may have been missed?

Response [ There will be the cost of putting together the data package once the studies are 

conducted. ]