# Pesticide Use Survey Report For Agricultural Aviation

A Study Conducted by the National Agricultural Aviation Association

May 2004

National Agricultural Aviation Association 1005 E Street, SE Washington, DC 20003 (202) 546-5722 information@agaviation.org www.agaviation.orgii 

### Table of Contents

Section Page Number

Introduction Background . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .

. . . . . . . . . . . 1

Objectives . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1

Methodology . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1

Report Format . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2

Executive Summary . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3

Detailed Findings

Part 1—Location Question 1: In which State is your aerial applicati on business located? . . . . . . . . . . . . . . . . . . . 5

Question 2: Please list the states in which you perform aerial applications. . . . . . . . . . . . . . . . . . 6

Part 2—Equipment Question 3: How many operating aircraft are used in your aerial application business? . . . . . . . . . . 7 How many planes? . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 7 How many of these planes have a closed cockpit? . . . . . . . . . . . . . . . . . . . . . . . . . 8 How many helicopters? . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 7 How many of these helicopters have a closed cockpit? . . . . . . . . . . . . . . . . . . . . . . . 8

Question 4 (a): Are your aircraft eq uipped with smokers to determi ne wind direction while performing aerial applications? . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 9

Question 4 (b): If you do use a smoker, how often do you engage it? . . . . . . . . . . . . . . . . . . . . .10

Part 3—Mixing/Loading Operations

Question 5: What percent of all spray jobs does the pilot of the aircraft also mix & load pesticides? . . . . 11

Question 6: If the mixer/loader and the pilot are different individuals, on average how many different aircraft are usually support ed by that mixer/loader on an average day? . . . . . . . . . . . . . . 1 2

Question 7: When PPE is required, do you use disposable or reusable equipment? . . . . . . . . . . . . . 13

Question 8: Does the operation utilize a closed mixing/loading system (mechanical pesticide transfer)? . . 14

Question 9: Question related to mixing lo ading practices. . . . . . . . . . . . . . . . . . . . . . . . . . . 15

Question 10: Question pertaining to number of pesticides handled per day by a mixer/loader. . . . . . . . 17

Question 11: Question pertaining to number of days a particular type of pesticide would be applied? . . . 18

Part 4—Application Practices

Question 12: Which of the following do you use to minimize spray drift?

. . . . . . . . . . . . . . . . 20

Question 13: When applying pesticides, wh at percent of applications use specific type of swath marking? . 22

Part 5 – Daily Acres Treated Question 14: Average acres and maximum acreage treated per day according to crop. . . . . . . . . . . . 23

Appendix

Survey & Cover Letter . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1 - 3

Raw survey data can be made available on request from the NAAA.1 Introduction

Background The National Agricultural Aviation Association (NAAA) conducted this study to better understand how aerial pesticide applications are made in the United States today. Specific objectives are outlined below. Similar studies were conducted by NAAA in 1992, 1994, 1998 and 2000. Some questions were new and some questions asked in earlier studies were not repeated here. Copies of earlier survey results are available by calling the NAAA.

Objectives One of the primary objectives of this study was to obtain actual data depicting pesticide use patterns in the aerial application industry to supply to the Environmental Protection Agency (EPA). NAAA worked in conjunction with the EPA in developing questions in this study. The EPA, as part of its pesticide (re) registration process, must determine occupational exposure risks associated with the aerial application of pesticides. NAAA is concerned that the exposure data that EPA uses to make occupational risk assessments pertaining to aerial applicators are theoretical and/or overly estimate exposure risk. For this reason, the Association undertook collecting actual, up-to-date, data reflective of current industry practices. This study provides

that information.

A second objective of the study was to identify drift mitigation techniques used by the aerial application industry and quantify their usage to indicate to the EPA the advanced technologies and methods commonly practiced to make on-target applications and protect the environment. This information can be used to support aerial use on pesticide labels.

Another objective of the study was to develop information to better define the agricultural aviation industry in the United States by better identifying the scope of work conducted; and equipment, products and application techniques used.

Methodology NAAA sent out 1,899 pesticide use surveys in March of 2003 to FAA Part 137 Aerial Application Operators throughout the United States. The mailing list was developed by the NAAA using a list of all FAA Part 137 operators and checking that list with the executive directors of individual state and regional agricultural aviation associations throughout the country to determine which of those operators were still in business. The mailed surveys sent out included a message from the NAAA president with a return envelope. The survey form and the cover letter are in the appendix.

NAAA received 595 surveys. The U.S. Postal Service returned twelve (12) surveys to the NAAA because the addresses were no longer valid. Twelve (12) sent the surveys back with a note that they were no longer in business. Some operators had answered only some of the questions. In these cases the information provided was used. Three (3) completed surveys were received from Canadian operators and while we appreciate their input, the responses were not used in tabulating the results. The return rate for the survey was 31.5%. 1 In 1998 NAAA conducted an industry survey of the aerial application industry with a similar target list and the response rate was 31%.

The returned questionnaires were tabulated on a Microsoft Excel Spreadsheet listing all of the information supplied by the respondents. The data was checked for missing information and

1 595/(1,899-12 returned by the Post Office) = 31.5%2 obvious errors in completion of the survey form. A committee of aerial applicators arrived at a set of reasonable standards to judge the accuracy of the data submitted. Those standards are included in the narrative analyzing each specific question in the Detailed Findings portion of this report. References to individual responses that were questioned by the panel can also be found in the Detailed Findings portion of this report and in the actual survey data.

NAAA has the data generated by this survey in both paper and electronic format. Individuals interested in the data may request it by contacting the NAAA office at (202) 546-5722.

Report Format The Executive Summary outlines the study makeup and objectives along with providing an overview of the survey findings. The Detailed Findings portion has been divided into 5 parts: Part 1- Location, Part 2 – Equipment, Part 3 – Mixing and Loading, Part 4 – Application Practices, and Part 5 – Daily Acres Treated.3 Executive Summary

The mail survey was sent in March of 2003 to 1,899 FAA Part 137 Aerial Application Operators throughout the United States. The NAAA received 595 surveys in response.

The study results are divided into 5 parts: Part 1- Location, Part 2 – Equipment, Part 3 – Mixing and Loading, Part 4 – Application Practices, and Part 5 – Daily Acres Treated.

Location NAAA’s records show that aerial application operations are located in 47 out of 50 states. Vermont, Hawaii and Rhode Island are the states that do not have an aerial application operation. Responses to this survey were received from application businesses located in 41 of 50 states. This survey is primarily designed to provide the EPA with information to better define the agricultural aviation industry in the United States by identifying the scope of work conducted; and equipment, products and application techniques used.

The largest number of responses to the survey were received from Arkansas (first - 59), Texas (second - 52), Louisiana (third - 40), and Kansas and California (tied for fourth - 31).

A total of 93 operators reported that they worked in 3 states or more. Of this total, 46 operated in only three states, 21 in four states, and the num ber gradually decreased until only 5 operators reported working in more than eight states.

Equipment Based on information collected from the respondents there are an average of 2.2 aircraft per aerial application business. 88% of the aircraft used in the industry are fixed wing aircraft and the other 12% are rotorcraft, or helicopters. 98% of fixed-wing aircraft have a closed cockpit; 90% of the helicopters have closed cockpits. An average of 97% of the combined total of all agricultural aircraft are equipped with closed cockpits.

Approximately 85% of the aircraft operated by these applicators are equipped with smokers to determine wind direction at an application site. Nearly 80% of the applicators that use a smoker do so before applying product next to a sensitive area. 35% of the applicators that use a smoker do so at least once every load. 25% of the respondents that use a smoker do so every 2-4 swaths (a swath is a pass across the field in one direction) and another 25% do so every 5-7 swaths. 9% use their smoker during every swath.

Mixing/Loading Operations From the responses received, 29% of all spray jobs are mixed and loaded by the pilot applying the load. The other 71% percent are mixed and loaded by a separate mixer/loader. In addition, the average number of aircraft a mixer/loader, who is not the pilot, services, is 1.48

When personal protection equipment (PPE) is required for mixing a pesticide, 14% use disposable PPE; 17% use reusable PPE and 69% use both types of PPE.

More than three-quarters (76%) of those aerial application operators surveyed indicated that they use a closed mixing/loading system when preparing crop protection products for application. Just over 24% did not use a closed system. Closed mixing/loading systems, as described in the question, are those systems that contain some sort of mechanical pesticide transfer function that removes one, if not all the steps, involved in mixing and loading a pesticide that may cause exposure to a worker.4 When pesticides are mixed and loaded, 38% of the respondents use product from open pour containers; 36% use product containers with dry break openings; 23% without dry break openings and 3% use other types of containers or methods.

A typical mixer-loader will handle 4.3 different pesticides per day. Results of the survey also indicated that herbicides are applied on average 71 days out of the year; insecticides are applied 69 days out of the year and fungicides are applied 40 days out of the year.

Application Practices The survey asked what types of techniques/tools applicators use to minimize drift. 86% of the respondents indicated that they use drift control additives; 85% of the respondents indicate that they use special nozzles; 82% of the respondents indicated that they use changes in the flight pattern to mitigate drift; 72% use wind detec tors, such as smokers; 59% use changes in nozzle pressure; and 28% use diluting formulations (i.e., increasing the spray volume of water and/or carrier per acre).

The survey also included a question asking operators what type of method they used for swath guidance. 92% use GPS; 28% use automatic flaggers; and 4% use human flaggers. Some operators use more that one method simultaneously.

Daily Acres Treated The top three crops with the largest average number of acres treated per day are cotton (1,080 acres), rice (725 acres), and small grains (597 acres). Operators indicated that they treat small grains, such as wheat and barley more than any other crop; corn/sorghum and soybeans were tied

for second and alfalfa and cotton were tied for fourth.

In terms of the three crops with the largest maximum number of acres treated per day, cotton (2,145 acres) again topped the list followed by forests (1,481 acres) with rice (1,344 acres) in third place.5 DETAILED FINDINGS

PART 1 - LOCATION

Question 1.
In which State is your aerial application business located?

State Responses Percentage State Responses Percentage State Responses Percentage

AK 0 0.0% LA 40 7.0% OH 3 0.5%

AL 6 1.0% MA 0 0.0% OK 16 2.8%

AR 59 10.3% MD 0 0.0% OR 10 1.7%

AZ 6 1.0% ME 2 0.3% PA 6 1.0%

CA 31 5.4% MI 4 0.7% RI 0 0.0%

CO 25 4.4% MN 30 5.2% SC 4 0.7%

CT 0 0.0% MO 11 1.9% SD 12 2.1%

DE 2 0.3% MS 24 4.2% TN 4 0.7%

FL 11 1.9% MT 25 4.4% TX 52 9.1%

GA 12 2.1% NC 9 1.6% UT 2 0.3%

HI 0 0.0% ND 30 5.2% VA 4 0.7%

IA 11 1.9% NE 28 4.9% VT 0 0.0%

ID 11 1.9% NH 1 0.2% WA 24 4.2%

IL 10 1.7% NJ 1 0.2% WI 5 0.9%

IN 3 0.5% NM 2 0.3% WV 1 0.2%

KS 31 5.4% NV 0 0.0% WY 1 0.2%

KY 0 0.0% NY 3 0.5%

The first column, entitled “State,” lists all the states in which surveys were sent to aerial application operators including those that had no reported operators. The second column, entitled “Responses,” lists the number of responses received from aerial application operators that indicated their operation was located in that state. The total of responses to this question was 572. The third column, entitled “Percentage,” calculates the number of responding aerial application operations in that state, as a percentage of the 572 responses received to this question.

Responses were received from application businesses located in 41 of 50 states. NAAA records indicate aerial application businesses located in 47 of the 50 states. These surveys were sent to all applicators shown in NAAA records in these states. Vermont, Hawaii, and Rhode Island, according to NAAA records, have no aerial application operations based there.

As indicated by the table above, the most responses to the survey were received from Arkansas (first - 59), Texas (second - 52), Louisiana (third - 40), and Kansas and California (tied for fourth - 31).6 Question 2.
Please list the states in which you perform aerial applications.

State Responses Percentage State Responses Percentage State Responses Percentage

AK 1 0.1% LA 48 4.7% OH 10 1.0%

AL 15 1.5% MA 1 0.1% OK 35 3.4%

AR 76 7.4% MD 9 0.9% OR 16 1.6%

AZ 9 0.9% ME 3 0.3% PA 9 0.9%

CA 35 3.4% MI 11 1.1% RI 0 0.0%

CO 39 3.8% MN 44 4.3% SC 11 1.1%

CT 1 0.1% MO 31 3.0% SD 26 2.5%

DE 5 0.5% MS 32 3.1% TN 17 1.7%

FL 15 1.5% MT 29 2.8% TX 83 8.1%

GA 22 2.1% NC 20 2.0% UT 6 0.6%

HI 0 0.0% ND 56 5.5% VA 18 1.8%

IA 27 2.6% NE 45 4.4% VT 4 0.4%

ID 29 2.8% NH 1 0.1% WA 32 3.1%

IL 21 2.0% NJ 5 0.5% WI 11 1.1%

IN 9 0.9% NM 15 1.5% WV 9 0.9%

KS 56 5.5% NV 4 0.4% WY 9 0.9%

KY 6 0.6% NY 9 0.9%

The first column, entitled “State,” lists all the states in which surveys were sent to aerial application operators including those that had no reported operators. The second column, entitled “Responses” lists the number of responses received from operators that indicated they performed aerial applications in that state. The third column, entitled “Percentage,” calculates the percentage of aerial application operators responding that perform aerial applications in that state compared to the total responses.

All respondents indicated the states in which they worked but four (4) respondents failed to indicate the state in which the operation is located.

A total of 93 operators reported that they worked in 3 states or more. Of this total, 46 operated in only three states, 21 in four states, and the number gradually reduced until only 5 operators reported working in more than eight states. These 5 operators reported working in 10, 12, 14, 16 and 18 states, respectively.7 PART 2 - EQUIPMENT

Question 3.
How many operating aircraft are used in your aerial application business? ________How many planes? ________ How many of these planes have a closed cockpit?________How many helicopters? _ _______ How many of these helicopters have a cl osed cockpit?________

This is a five-part question. The first part of the question was to determine the average number of aircraft used in an aerial application business.

How many operating aircraft are used in your aerial application business?

Responses were received from 572 operators indicating that they used 1,262 aircraft in their aerial application business. This is an average of 2.2 aircraft per operation.

This question asks for the number of operating aircraft that are used. The responses received indicate that six operators listed fewer aircraf t in the first part of the question than the number of aircraft listed after adding together the number of airplanes and helicopters they had in their business. The reason for this is some of aircraft were in operation and some were not. The breakdown totals were adjusted to remove the non-operating aircraft. Changes were made to one operator’s response (response # 47) who had miscalculated the total and a second (response # 573) was dropped from the total data because the breakdown was not shown.

How many planes? _______ How many helicopters? _______



### TYPE OF AIRCRAFT USED

Airplanes

88% Helicopters

12%

Respondents to the second part of the question provided data indicating that they use 1,108 airplanes and the fourth part of the questions indicates that respondents use 154 helicopters. Based on these figures, fixed wing aircraft account for 88% of the fleet and helicopters make up the remaining 12%.

Other findings from the data show that of the 572 respondents, 19 employ both airplanes and helicopters. The remaining operators use only one type of aircraft - 516 use airplanes and 37 use helicopters exclusively.8 How many of these planes have a closed cockpit? The third part of this question indicates that 1,083 of the 1,108 fixed-wing aircraft have a closed cockpit. This amounts to an average of 98% of the agricultural airplanes having a closed cockpit.

How many of these helicopters have a closed cockpit? The fifth part of this question indicates that 138 of the reported 154 rotorcraft, or helicopters have closed cockpits. This amounts to an average of 90% of the helicopters having a closed cockpit.



### COMBINED AIRPLANE & HELICOPTER COCKPIT

DESIGN OF SURVEYED AIRCRAFT

Closed Cockpits

97% Open Cockpits

3%

Other data that can be gleaned from the responses to this multi-part question indicate that 97%, or 1,221 of the 1,262 combined agricultural aircraft covered by this survey are equipped with closed cockpits.9 Question 4 (a).
Are your aircraft equipped with smokers to determine wind direction while performing aerial applications? (Please check one of the following) Yes No



### SMOKER EQUIPPED AIRCRAFT

Smoker Equipped

85% No Smoker

15%

Total Total Percentage Total Percentage
Aircraft Airplanes Airplanes Helicopters Helicopters
Smoker Equipped 1066 1034 94% 32 21% Not Equipped 189 68 6% 121 79%
Total Surveyed 1255 1102 153

A total of 572 operators responded to this question – 509 said that their aircraft are equipped with a smoker while 63 did not have their aircraft so equipped. The graph and data indicate that 85% percent of the aircraft are equipped with smokers. The survey data show that 1,066 of the reported 1,255 aircraft are so equipped.

The purpose of this question was to determine what percentage of applicators use smokers to inform them of wind direction and atmospheric conditions at the time and place of application and how they use this technology. A smoker injects a small amount of oil into the aircraft engine exhaust creating smoke that is released into the air. This smoke aids the applicator in determining wind direction and velocity in order to make the necessary application adjustments to ensure that the chemical application is to the target area. One (1) responder specifically stated that he did not have smoke equipment on the aircraft but he sends a person to the field to light a fire on the ground to determine air movement.

Another use of the smoker is to help mark the location of the spray run in order to ascertain the

location of the next swath 2 . This method is sometimes used in conjunction with the automatic flagger. With the advent of the GPS for swath marking, the auto-flagger and smoker are not depended on as much as they were in the past.

2 A swath is a spray pass across the field in one direction.10 Question 4 (b).
If you do use a smoker, how often do you engage it? (Please check all that apply) Before an application next to a sensitive area Every swath run Every 2-4 swath runs Every 5-7 swath runs Every load Other (please explain) __________________

22% 9% 25% 25% 35% 80%

0% 20% 40% 60% 80% 100% Near a sensitive area
Every load
Every 2-4 swaths
Every 5-7 swaths
Every swath

Other 

### FREQUENCY OF SMOKER USE

Of the total 509 responders that have aircraft equipped with smokers, 407 or 80% indicated that they use the equipment before applying product next to a sensitive area. 177 or 35% of the applicators said that they use a smoker at least every load. The same amount of respondents, 126 or 25% indicated that they use the smoker every 2-4 or every 5-7 swath runs. 44 or 9% of the respondents said that they use the smoker on every swath run. Another 113 or 22% of the applicators that use a smoker selected “other”. In the remarks, 100 of those 113 described “other” as using a smoker “as required” or “as needed”.

The second part of the question was designed to allow respondents to check any combination of smoker use frequency that applied to them and many did, as is indicated. Therefore, the responses need not total 100%.11 PART 3—MIXING/LOADING OPERATIONS

Question 5.
What percent of all spray jobs does the pilot of the aircraft also mix and load pesticides?



### LOADS MIXED BY PILOT

Pilot mixed

29%

Mixer/loader mixed

71%

Percentage of Loads Mixed/Loaded
by the Pilot Performing the Application

0% 181 51-60% 8

1-10% 164 61-70% 4

11-20% 21 71-80% 21

21-30% 25 81-90% 17

31-40% 2 91-100% 83
41-50% 43 Responses 569

Respondents were asked to estimate the percentage of the loads in which an individual mixed and loaded the chemical and then served as pilot of the aircraft. A total of 569 operators responded to this question. The responses varied from 0% to 100% with an average of 29% . The table above shows the number of responses registered in each percentage range as estimated by the operators.

Some aerial application operations are operated by a single person. The owner does the mixing/loading, piloting of the aircraft and the bookkeeping. In other operations, the pilot is only the pilot and all loads are mixed and loaded by a separate individual. However, in actual practice, the pilot occasionally mixes his own load if the mixer/loader is not at the facility or is busy with another task.12 Question 6.
If the mixer/loader and the pilot are different individuals, on average how many different aircraft are usually supported by that mixer/loader on an average day?

Number of Aircraft Serviced

by a Single Mixer/Loader

0.5 3 3.0 12

1.0 280 3.5 1

1.1 1 4.0 4

1.5 13 5.0 1

2.0 159 10.0 2
2.5 2 Responses 478

We had 478 responses that met the criteria explained below. The results indicate that each mixer/loader supports between .5 and 10 aircraft per person. From the data received, 1.48 is the average number of aircraft that a mixer/loader services. The above table illustrates the breakdown of responses received for this question.

This question on the average number of aircraft loaded by a mixer-loader assumes that the pilot

of the aircraft is not the mixer/loader. Therefore, any responses of 100% to Question # 5 should not have a response to Question #6. Any response listing 100% for Question #5 was removed from the data used to calculate the responses to Question #6.

Our review panel removed three (3) survey responses that did not follow this criterion (responses 242, 334, and 482). Our panel concluded that these figures were entered in error because the respondent did not understand the question.13 Question 7.
When Personal Protection Equipment (PPE) is required, do you use disposable or reusable equipment? (Please circle one) Disposable Reusable Both



### TYPE OF PERSONAL PROTECTIVE EQUIPMENT
(PPE) USED

Disposable

14%

Reusable

17%

Both

69%

Total Disposable Reu sable Both
Responses Number Percentage Number Percentage Number Percentage

572 78 14% 97 17% 397 69%

A total of 572 operators responded to this question that asked if they preferred to utilize disposable or reusable Personal Protective Equipment (PPE) when required for mixing/loading crop protection products. The most common response was “Both” which 397 respondents chose, or 69%. 97 respondents chose “Reusable” or 17%, and 78 respondents chose “Disposable” or

14% of the total.14 Question 8.
Does the operation utilize a closed mixing/loading system (mechanical pesticide transfer)? Please circle one of the following: Yes No



## CLOSED LOADING SYSTEMS

Closed

76% Non-closed

24%

The NAAA received 561 responses of which 427 or 76% said that they utilize a mixing system to lessen worker exposure while mixing. 134 responders or 24% do not utilize a closed mixing/loading system.

More than three-quarters (76%) of those aerial application operators surveyed indicated that they use a closed mixing/loading system to prepare crop protection products for application. Closed mixing/loading systems, as described in the question, are those systems that contain some sort of mechanical pesticide transfer that removes one, if not all, of the steps involved in mixing and loading a pesticide that may cause exposure to a worker.15 Question 9.
When pesticides are mixed and loaded, what percentage of the total mixing/loading jobs use the following practices? Please estimate a percentage at the end of each of the following bullets (Total should equal 100%):

Percentage of mixing/loading jobs spent opening product containers and pouring the pesticide formulations into the mixing/loading tank (also known as open pour) ________%

Percentage of mixing/loading jobs spent transferring pesticides to the mix tank from product containers with dry break openings? ________%

Percentage of mixing/loading jobs spent transferring pesticides to the mix tank from product containers without dry break openings? ________%

Other ________% Please explain ________________________________________________________



## MIXING/LOADING METHOD USED

Containers with
dry break

36%

Open pour

38% Other

3% Containers
without dry

break

23%

479 responses were recorded for this question to calculate the percentages. The question requires respondents to assign percentages to mixing loading practices used at their operation and the cumulated total must equal 100%

Open pour is assumed to mean that the contents of the chemical product container are physically poured into the mix tank or aircraft dispersal tank. This method is reportedly used at least part of the time by 458 respondents for an average of 38% of the pesticide mixing.

Containers with dry break openings are designed to allow coupling and uncoupling a hose to the fitting on the container without spilling any of the contents. This is usually accomplished by the use of a check valve. 369 respondents reported using this type of container in an average of 36% of the loading situations.

Product containers without dry break openings are not equipped with an automatically activated leak prevention device, such as a check valve. This type of container was used at least part of the time by 352 responders. They reported using this type of loading in an average of 24% of loading operations.

There were 83 responses rejected because the percentages submitted did not equal 100%. Twenty six (26) of these indicated by either a notation or by the answer that they considered “open pour” and “without dry break” to be referring to the same type container since an open pour container probably does not have a dry break. Six (6) additional responses were eliminated because in their explanation for “other”, they broke down the percentage of loader duty time to include “waiting for airplane” and “fueling airplane”.16 Additional explanations such as “mix in hopper,” “don’t disconnect,” “all loaded through closed system” and “pump directly to hopper” were accepted if the percentage break down totaled 100%. The question was asked to determine the method a liquid material was handled in the mixing loading process. A total of nine (9) responders stated that liquids were mixed/loaded using water-soluble bags or dry materials. Seven (7) of these responses were accepted in the percentage calculation. Two (2) of these were rejected because they responded in the manner listed above detailing why responses were rejected.

We believe that it is important to note some of the respondents added comments to this question that manufacturers should standardize the openings of product containers so one system could handle all, or at a minimum, many of the crop protection products.17 Question 10.
On average, how many pesticides are typically handled per day by a mixer-loader at your aerial application operation? Please provide an actual nu mber in the following space: ________

Data results for Question 10

Chemicals Number of Chemicals Number of Chemicals Number of Handled Responders Handled Responders H andled Responders

0 3 5 76 15 6

1 21 5.5 1 16 1

1.5 5 6 25 17.5 2

2 86 6.5 1 20 13

2.5 12 7 12 21 1

3 100 7.5 3 25 4

3.3 1 8 20 40 2

3.5 8 9 5 50 1

4 57 10 39 55 1

4.5 1 12 5 100 1

Based on 473 responses using an allowable maximum of 10 pesticides handled per day to perform the calculation (see explanation below), the daily average of pesticides handled per day by a mixer-loader is 4.3 pesticides. Additional calculations based on 500 responses using an allowable maximum of 20 different pesticides handled per day to perform the calculation, the daily average of pesticides handled per day by a mixer-loader is 5.0

.

Those responses that were not included in the calculations were those that included information on the number of gallons of pesticide handled or percentage of pesticides handled, rather than what was asked for—the number of pesticides handled per day. Three (3) individual responses that showed zero (0) as the number of pesticides handled daily were also not considered.

Due to questionable responses submitted by a few respondents regarding this question, our survey review panel felt it necessary to determine a realistic data range of reported responses to this question. The panel determined that a reasonable limit for the maximum number of pesticides handled per day was 20. This resulted is discarding from the calculation the following responses: one response listing 21, one responses listing 25, two responses listing 40, one response listing 50, one response listing 55 and one response listing 100 pesticides handled on a typical day by a mixer-loader.

We also calculated the average number of pesticides handled per day by a mixer-loader using 10 as the maximum allowable number of pesticides handled per day to perform the calculation. Using this range, 473 responses were accepted into the calculation resulting in an average of 4.3 pesticides being handled per day by a mixer-loader. The panel believes that 10 is a more reasonable maximum number of pesticides handled on a typical day.18 Question 11.
In a given year, what is the maximum number of days th at a particular type of pesticide would be applied? Please provide a number in the space following each classification of pesticide.

Insecticide: ________ Herbicide: ________ Fung icide: ________

40 69 71

0 10 20 30 40 50 60 70 80

Number of Days Applied Herbicides

Insecticides

Fungicides 

## DAYS OF APPLICATION BY PESTICIDE TYPE

Number of Days Applied by Pesticide Type
Insecticide Herbicide Fungicide

0-29 132 88 197

30-59 129 150 138

60-89 99 114 61

90-119 63 69 30

120-149 45 38 7

150-179 25 24 7

180-209 19 27 6

210-239 5 5 2

240-269 9 6 0

270-300 4 2 1

530 523 449

As indicated in the bar chart above, herbicides are applied more often, on a daily basis, than any other type of crop protection product. Insecticides run a close second. Respondents indicate that herbicides are applied, on average, 71 days out of the year. Insecticides are applied, on average, 69 days out of the year, and fungicides are applied, on average, 40 days out of the year. These averages were obtained from the data supplied by 543 responders.

It was also interesting to note that although herbicides were applied on average, more days out of the year, insecticides were applied by a slightly greater percent of operators responding. Calculations show that based on 543 responses, 98% applied insecticides, 96% applied herbicides and 83% applied fungicides.

Some responders stated that they applied a certain pesticide type 365 days out of the year. The survey review panel determined that this is completely unrealistic and that the respondents misinterpreted the question to read “the number of days that a certain type of chemical is on hand,” similar to what is asked on a Tier II report. The panel determined that a realistic range of19 days a pesticide was used a year was between 10 days to 300 days out of the year. Any response outside of this range was not considered. As a result, thirteen (13) responses were not considered because the combined total of days of application was less than 10 days. Three (3) responses were eliminated because they indicated that they applied a certain type of pesticide more than 300 days per year. Responses # 14, 17, 472 and 485 were eliminated because the responses were labeled as a percent (%) instead of number of days.20 PART 4—APPLICATION PRACTICES

Question 12.
Which of the following do you use to minimize spray drift? (Please check all that apply) Drift Control Additives Wind detectors Changes in pressure Special nozzles Changes in flight patterns Diluting formulations

28% 59% 72% 82% 85% 86%

0% 20% 40% 60% 80% 100%

Percentage of Operators Using Each Method Drift control additive
Special nozzles
Changes in flight pattern

Wind Detectors
Changes in pressure
Diluting formulations 

## METHODS USED FOR DRIFT REDUCTION

569 responses were accepted to calculate percentages for this question. As shown in the question stated above the graph, the percentages need not total 100%.

Drift control additives are products that can be mixed with the chemical to eliminate the breakup of droplets into fine particles resulting in decreased drift. This type of drift minimization practice was used by 86% of our responders and was the leading method used.

Special nozzles can be selected to produce a droplet size that is larger and more uniform in size and less susceptible to drifting. Selecting special nozzles for drift control was a close second with 85% choosing this as a drift reduction method.

Changes in flight patterns was footnoted in the survey to mean leaving buffer zones on the downwind side of a field during the time of the initial application and returning to complete that portion of the field once the wind has shifted. This procedure, with an 82% response rate was in third place.

Wind detectors range from utilizing combustible materials at the application site or smokers installed on the aircraft to generate smoke in order to determine wind direction, to using anemometers to obtain this information. 72% of the responders reported that they use some sort of wind detector as a form of reducing movement of the chemical away from the target area.

Changes in nozzle pressure will alter the droplet size, thereby it can be used to mitigate the creation of fine particles that are more prone to drifting. 59% of the responders reported that they use changes in nozzle pressure to reduce drift.

Diluting formulations means increasing the total volume of liquid per acre so that there is a smaller amount of active ingredient in each droplet that is applied. This method was selected by 28% of the responders.21 The survey review panel was unable to fully explain the reason that 89% 3 of the operators have smoke generating equipment installed on their aircraft but only 72% said that they used wind detectors for controlling drift. One possible explanation is that some operators responding to the survey considered smoker use as a tool for identifying wind direction and velocity, yet they do not put this into the context of mitigating drift.

3 89% of operators responded that they had smoke genera ting equipment installed. When analyzed as a percentage of the aircraft covered in the report, 85% are equipped with smokers.22 Question 13.
When applying pesticides by air, what percent of your applications use:

Human flaggers ________% Automatic flaggers ______ __% GPS ________% Other ________%

4% 4% 28% 92%

0% 20% 40% 60% 80% 100%

Percent of Operators Using Each Method GPS

Automatic Flaggers

Human Flaggers

Other 

### METHOD USED FOR SWATH GUIDANCE

568 responses to this question were used for completion of the data. This question was constructed with the understanding that more than one type of guidance can be used simultaneously; as a result the percentages need not total 100%.

The above table shows that approximately 92% of the information for swath guidance is being provided by GPS 4 equipment installed in the aircraft. An NAAA 1998 survey indicated that 60% of agricultural airplanes were equipped with GPS as compared to 25% in 1994.

The use of GPS and the Automatic Flagman 5 has virtually eliminated the need for and use of human flaggers in the aerial application industry and thereby has reduced occupational exposure from the aerial use of pesticides. Slightly less than 4% of those responding to the survey said that they used human flaggers compared to 15% in 1998 and 38% in 1994.

The increased use of GPS equipment has also resulted in a decrease in the use of the automatic flaggers from 73% in 1994 to 58% in 1998, to its lowest level of 28% in 2003.

The survey panel decided to not consider two responses. Response # 236 was not included because the respondent, after answering that 90% of his/her applications use “human flaggers” remarked that the human flaggers are to check wind and temperature at the application site and therefore shouldn’t be considered as an exposure risk. Response # 503 was determined to be incomplete.

4 Global Position Satellite system. GPS uses satellite technology en abling the ag pilot to make a swath run directly next to the previous one. The accuracy of the GPS unit provides the opportunity for exceptional positioning control.

5 Automatic Flagman, also known as automatic or auto flaggers, dispense a biodegradable tissue at the end of a swath run to enable the ag pilot to estimate the position of the next swath to be made.23 PART 5 – DAILY ACRES TREATED Question 14.
Please complete the following table. For each crop, please indicate the usual and the maximum number of
acres that you treat on average during a single day, with a single aircraft using a single pesticide. 6

Usual Number of Acres Treated Per Day, Using a Single Aircraft Using a Single Pesticide Maximum Number of Acres Treated Per Day, Using a Single Aircraft Using a Single Pesticide

Alfalfa Corn, Sorghum

Cotton

Forests Orchards (Fruit and Nut Trees) Pastures and Rangeland

Rice Small grains (Wheat, Barley) Soybeans Leafy vegetables

Roots and tubers Small fruits (Grapes and Berries) Other: _____________________

Usual Acres Treated per Day Maximum Acres Treated per Day Crop Treated Number of Percent of Usual Number of Percent of Maximum (567 Operators responded) Responses Responders Acres Responses Responders Acres

Alfalfa 194 34% 322 197 35% 785
Corn, Sorgum 249 44% 541 248 44% 1281

Cotton 191 34% 1080 180 32% 2145

Forests 43 8% 587 43 8% 1481 Orchards (Fruit & Nut Trees) 54 10% 277 53 9% 598
Pastures & Rangeland 177 31% 549 173 31% 1238

Rice 139 25% 725 136 24% 1344 Small grains (Wheat, Barley) 34 8 61% 597 341 60% 1307 Soybeans 249 44 % 591 237 42% 1282 Leafy vegetables 75 13% 389 72 13% 811

Roots & Tubers 102 18% 593 98 17% 1191 Small fruits (Grapes, Berries) 27 5% 339 24 4% 514

Other 42 7% 483 42 7% 1324

The top three crops with the largest average number of acres treated per day, as indicated from the table above are cotton (1,080 acres), rice (725 acres), and small grains (597 acres). More operators indicated that they treat small grains, such as wheat and barley, more than any other crop; corn/sorghum and soybeans were tied for second and alfalfa and cotton were tied for

fourth.

In terms of the top three crops with the largest maximum number of acres treated per day, cotton (2,145 acres) again topped the list with forests (1,481 acres) and rice (1,344 acres).

A breakdown of “Other Crops” treated by survey respondents is on the following page.

6 NAAA realizes that when making app lications to some crops, more than one pesticide will be used. Yet, for purposes of documenting exposure data as outlined by the EPA, we need you to answer these questions as if you use a single pesticide in each application load.24 Break down of Number of Percent of Usual Number of Percent of Maximum "Other" Crops Responses Responders Acres Responses Responders Acres Aquatic 1 0.2% 100 1 0.2% 200

Christmas trees 2 0.4% 165 2 0.4% 375
CRP (Gov't non-crop land) 1 0.2% 350 1 0.2% 1500
Fallow (Idle - out of production) 3 0.5% 220 3 0.5% 1500

Gladiolas 1 0.2% 50 1 0.2% 250
Misc. minor crops 1 0.2% 100 1 0.2% 300
Mosquito 2 0.4% 1624 2 0.4% 2724
Peppermint 1 0.2% 600 1 0.2% 900

Public Health 2 0.4% 1375 2 0.4% 3225
Pulp 1 0.2% 400 1 0.2% 2400
Right-of-way (powerlines, etc.) 3 0.5% 100 3 0.5% 300
Sugar cane 6 1.1% 633 6 1.1% 1700

Sod 2 0.4% 250 2 0.4% 1300

Sunflower 13 2.3% 476 14 2.5% 1229

Tobacco 2 0.4% 213 2 0.4% 413

Not surprisingly, the largest average number of acres treated per day by responding applicators that treat “other crops” were for mosquito/public health spraying. This is typically low-volume application work. It should also be noted that only four individuals responded that they perform mosquito/public health spraying. Similarly, the number of applicators that treat “Other” specific crops was few compared to some of the major crops listed on the previous page. Hence, this could raise some questions as to whether it is a true and accurate average to what is normally conducted in the industry.

The survey review panel reviewed the information submitted for question # 14 and removed the following responses from the calculations because evidence existed that certain respondents did not completely understand the question as explained below:

Response #11 Responder stated that on most crops he never treats with one chemical alone Response #14 Shows a daily application of 40,000 acres with one (1) aircraft in (1) day. This is not possible with any aircraft in the agricultural aviation fleet. Response #49 Canadian operator’s survey responses removed. Response #93 answered in yearly not daily terms Response #108 placed an “X” next to the crops rather than listing the number of acres treated pre day Response #227 placed an “X” next to the crops rather than listing the number of acres treated pre day. Response #261 Canadian operator’s survey responses removed. Response #423 Canadian operator’s survey responses removed. Response #459 placed an “X” next to the crops rather than listing the number of acres treated pre day. Response #460 placed an “X” next to the crops rather than listing the number of acres treated pre day. Response #528 indicated potato as an entry under “Other Crops” and that he/she could treat more acres on an “Average” day than on a “Maximum” day.

The survey panel moved some crops listed by responders as “Other” to the proper crop category whenever possible. Otherwise, these were broken down in the “other” crops chart.25 The survey review panel also set an upper limit on the amount of acres that can be treated in a single day with a single aircraft when calculating the average acres on the chart. Because some responses were exceptionally high the panel believed that respondents were answering the question with multiple planes in mind. The maximum range the panel established was 8,000 acres per day per aircraft. This is based on a realistic assessment of what the larger planes in the agricultural aviation fleet can apply on a daily basis.

The survey panel also established the following context relate d to what an applicator associates with the “Usual number of acres treated in a day” and the “Maximum number of acres treated in a day:”

Usual number of acres treated in a day – the number of acres that could be treated in a complete day of flying with no interruptions due to weather, mechanical, chemical supplies, lack of work

or other reasons. Maximum number of acres treated in a day - the number of acres that could be treated in a complete day of flying with the conditions listed above being present and if all the fields were large and flat. The likelihood that these conditions are met for an aerial applicator is highly unlikely.1 Appendix A Introductory Letter Accompanying Survey

M E M O R A N D U M

To: United States FAA Part 137 Certificate Holders

From: Dennie Stokes

NAAA President Owner/Operator of Stokes Flying Service, Parkin, Arkansas

Date: March 20, 2003

Subject: 2003 NAAA Pesticide Use Survey

Fellow aerial applicators, I have a very important request of you. Please complete the enclosed 2003 Pesticide Use Survey and mail or fax it back to NAAA Headquarters at the address or number below by April 28, 2003

.
As you know, crop protection product labels are becoming more and more restrictive for aerial use. Also, the number of products available is dwindling. Information collected from this survey will help to address that situation. We have developed the survey in an effort to collect actual use data on pesticides applied via aerial application. Collecting this data will help counter theoretical data used by the EPA and crop protection product manufacturers that can overestimate levels of pesticide exposure.

I know you all are busy either beginning the 2003 spray season or prepping your equipment to start the season, but if you could just take a few minutes to complete the survey it could make a world of difference to both you and the industry by helping increase the number of products labeled for aerial application. Completing the two page survey shouldn’t take long. I did it myself and it took me under 10 minutes.

Remember, the value of this survey is only as strong as the type of information you collect and the number of completed surveys we can collect. I’m sure a large number in the industry are using closed contained mixing loading systems and GPS to minimize worker exposure. I’m sure that a large number in the industry are using smokers to gauge wind direction. This is the type of information we need to show the EPA. Also, EPA will not give much credibility to the data we collect if only 3% of U.S. operators submit a survey; however, if we have a 95% industry response rate it adds significant credibility to the data we collected.

Thanks in advance for completing and submitting your survey back to the NAAA. Believe it or not, your individual response will make a difference.

Enclosure

1005 E Street, S.E., Wa shington, D.C. 20003

Fax: 202/546-57262 Appendix A Actual Pesticide Use Survey



## 2003 NAAA Pesticide Use Survey

Location: In which State is your aerial application business located? ________

Please list the states in which you perform aerial applications. ________________________________

Equipment : How many operating aircraft are used in your aerial application business? ________How many planes? ________ How many of these planes have a closed cockpit? ________How many helicopters? ________ How many of these helicopters have a closed cockpit? ________

Are your aircraft equipped with smokers to determine wind direction while performing aerial applications?

(Please check one of the following) 

##  Yes 

##  No

If you do use a smoker, how often do you engage it? (Please check all that apply)



##  Before an application next to a sensitive area 

##  Every swath run 

##  Every 2-4 swath runs



##  Every 5-7 swath runs 

##  Every load



##  Other (please explain) ____________________________________________________________

____________________________________________________________________________________

Mixing/Loading Operations : What percent of all spray jobs does the pilot of the aircraft also mix and load pesticides? ________%

If the mixer/loader and the pilot are different individuals, on average how many different aircraft are usually supported by that mixer/loader on an average day?_________

When Personal Protection Equipment (PPE) is required, do you use disposable or reusable equipment? (Please circle one) Disposable Reusable Both

Does the operation utilize a closed mixing/loading system (mechanical pesticide transfer)? Please circle one of the following: Yes No

When pesticides are mixed and loaded, what percentage of the total mixing/loading jobs use the following practices? Please estimate a percentage at the end of each of the following bullets (Total should equal 100%):

Percentage of mixing/loading jobs spent opening product containers and pouring the pesticide formulations into the mixing/loading tank (also known as open pour) ________%

Percentage of mixing/loading jobs spent transferring pesticides to the mix tank from product containers with dry break openings? ________%

Percentage of mixing/loading jobs spent transferring pesticides to the mix tank from product containers without dry break openings? ________%

Other ________% Please explain ________________________________________________________3 2003 NAAA Pesticide Use Survey Page 2

On average, how many pesticides are typically handled per day by a mixer-loader at your aerial application operation? Please provide an actual number in the following space:________

In a given year, what is the maximum number of days that a particular type of pesticide would be applied? Please provide a number in the space following each classification of pesticide.

Insecticide: ________ Herbicide: ________ Fungicide: ________

Application Practices : Which of the following do you use to minimize spray drift? (Please check all that apply)



##  Drift Control Additives 

##  Wind detectors 

##  Changes in pressure



##  Special nozzles 

##  Changes in flight patterns 7 

##  Diluting formulations 8

When applying pesticides by air, what percent of your applications use:

Human flaggers ________% Automatic flaggers ________% GPS ________% Other ________%

Please complete the following table. For each crop, please indicate the usual and the maximum number of acres that you treat on average during a single day, with a single aircraft using a single pesticide. 9

Usual Number of Acres Treated Per Day, Using a Single Aircraft Using a Single

Pesticide Maximum Number of Acres Treated Per Day, Using a Single Aircraft Using a Single

Pesticide

Alfalfa Corn, Sorghum

Cotton

Forests Orchards (Fruit and Nut Trees) Pastures and Rangeland

Rice Small grains (Wheat, Barley) Soybeans Leafy vegetables

Roots and tubers Small fruits (Grapes and Berries)

Other:

_____________________ Thank you for completing the 2003 NAAA Pesticide Use Survey. The data you supplied will help NAAA’s efforts to increase the number of crop protection products labeled for aerial use.

Please return your completed survey back to the NAAA by April 28, 2003 at:

2003 NAAA Pesticide Use Survey 1005 E Street, S.E., Washington, D.C. 20003

Fax: 202/546-5726

7 This includes leaving buffer zones on the downwind side of a field during the time of the initial application and returning to complete that portion of the field once the

wind has shifted.

8 Also known as increasing total volume per acre

9 NAAA realizes that when making applications to some crops, more than one pesticide will be used. Yet, for purposes of documen ting exposure data as outlined by the EPA, we need you to answer these questions as if you use a single pesticide in each application load.