Attachment_C_-_SOPs_ROD_2016_17_States_Veg_PEIS.pdf

STANDARD OPERATING PROCEDURES AND MITIGATION

BLM Vegetation Treatments Three New Herbicides A-9 August 2016 Final Programmatic EIS Record of Decision

TABLE A-2

Standard Operating Procedures for Applying Herbicides

Resource Element Standard Operating Procedure

Guidance Documents BLM Handbook H-9011-1 (Chemical Pest Control); and manuals 1112 (Safety), 9011 (Chemical Pest Control), 9012 (Expenditure of Rangeland Insect Pest Control Funds), 9015 (Integrated Weed Management), and 9220 (Integrated Pest Management)

General

• Prepare operational and spill contingency plan in advance of treatment.

• Conduct a pretreatment survey before applying herbicides.

• Select herbicide that is least damaging to the environment while providing the desired results.

• Select herbicide products carefully to minimize additional impacts from degradates, adjuvants, inert ingredients, and tank mixtures.

• Apply the least amount of herbicide needed to achieve the desired result.

• Follow herbicide label guidance for use and storage.

• Have licensed applicators apply herbicides.

• Use only USEPA-approved herbicides and follow product label directions and “advisory” statements.

• Review, understand, and conform to the “Environmental Hazards” section on the herbicide product label. This section warns of known pesticide risks to the environment and provides practical ways to avoid harm to organisms or the environment.

• In addition to the information presented in the Environmental Hazards section, follow all additional precautions and restrictions identified on the label, paying particular attention to herbicides that require some form of soil incorporation, either mechanically or through a moisture event, to activate them. Applications to powdery, dry soil or light, sandy soil when there is little likelihood of an incorporation event may result in off-site movement when the treated soil particles area moved by wind.

• Consider surrounding land use before assigning aerial spraying as a treatment method and avoid aerial spraying near agricultural or densely populated areas.

• Consider site characteristics, current and immediate future environmental conditions, and application equipment in order to minimize damage to non-target vegetation.

• Minimize the size of application area, when feasible.

• Comply with herbicide-free buffer zones to ensure that drift will not affect crops or nearby residents/landowners.

• Post treated areas and specify reentry or rest times, if appropriate.

• Notify adjacent landowners prior to treatment.

• Keep a copy of Safety Data Sheets (SDSs)/Material Safety Data Sheets (MSDSs) at work sites.

SDSs/MSDSs are available for review at http://www.cdms.net/.

• Keep records of each application, including the active ingredient, formulation, application rate, date, time, and location.

• Avoid accidental direct spray and spill conditions to minimize risks to resources.

• Turn off applied treatments at the completion of spray runs and during turns to start another spray run.

• Avoid aerial spraying during periods of adverse weather conditions (snow or rain imminent, fog, or air turbulence).

• Make helicopter applications at a target airspeed of 40 to 50 miles per hour (mph), and at about

30 to 45 feet above ground.

• Take precautions to minimize drift by not applying herbicides when winds exceed 10 mph (6 mph for aerial applications), or a heavy rainfall event is imminent.

• Conduct pre-treatment surveys for sensitive habitat and special status species within or adjacent to proposed treatment areas.

• Use drift reduction agents, as directed by the label, and low volatile formulations to reduce the drift hazard to non-target species.

BLM Vegetation Treatments Three New Herbicides A-10 August 2016 Final Programmatic EIS Record of Decision

TABLE A-2 (Cont.)

Standard Operating Procedures for Applying Pesticides

Resource Element Standard Operating Procedure

General (cont.)

• Refer to the herbicide product label when planning revegetation to ensure that subsequent vegetation would not be injured following application of the herbicide.

• Do not use adjuvants that are not approved for use with the selected active ingredients. Review labels of herbicides and adjuvants proposed for use to ensure that the proposed adjuvant(s) are approved for use with the selected active ingredients and in application settings where the selected herbicides are approved for use.

• Clean OHVs to remove seeds.

Air Quality

See Manual 7000 (Soil, Water, and Air Management)

• Consider the effects of wind, humidity, temperature inversions, and heavy rainfall on herbicide effectiveness and risks.

• Apply herbicides in favorable weather conditions to minimize drift. For example, do not treat when winds exceed 10 mph (6 mph for aerial applications) or rainfall is imminent.

• Use drift reduction agents, as appropriate, to reduce the drift hazard.

• Select proper application equipment (e.g., spray equipment that produces 200- to 800-micron diameter droplets [spray droplets of 100 microns and less are most prone to drift]).

• Select proper application methods (e.g., set maximum spray heights, use appropriate buffer distances between spray sites and non-target resources).

Soil

See Manual 7000 (Soil, Water, and Air Management)

• Minimize treatments in areas where herbicide runoff is likely, such as steep slopes under conditions when heavy rainfall is expected.

• Minimize use of herbicides that have high soil mobility, particularly in areas where soil properties increase the potential for mobility.

• Do not apply granular herbicides on slopes of more than 15 percent where there is the possibility of runoff carrying the granules into non-target areas.

Water Resources

See Manual 7000 (Soil, Water, and Air Management)

• Consider climate, soil type, slope, and vegetation type when developing herbicide treatment programs.

• Select herbicide products to minimize impacts to water. This is especially important for application scenarios that involve risk from active ingredients in a particular herbicide, as predicted by risk assessments.

• Use local historical weather data to choose the month of treatment. Considering the phenology of the target species, schedule treatments based on the condition of the water body and existing water quality conditions.

• Plan to treat between weather fronts (calms) and at the appropriate time of day to avoid high winds that increase water movements, and to avoid potential stormwater runoff and water turbidity.

• Review hydrogeologic maps of proposed treatment areas. Note depths to groundwater and areas of shallow groundwater and areas of surface water and groundwater interaction.

Minimize treating areas with high risk for groundwater contamination.

• Conduct mixing and loading operations in an area where an accidental spill would not contaminate an aquatic body.

• Do not rinse spray tanks in or near water bodies. Do not broadcast pellets where there is danger of contaminating water supplies.

• As needed, maintain buffers between treatment areas and water bodies. Buffer widths should be developed based on herbicide- and site-specific criteria to minimize impacts to water bodies.

• Minimize the potential effects to surface water quality and quantity by stabilizing terrestrial areas as quickly as possible following treatment.

Wetlands and Riparian Areas

• Use a selective herbicide and a wick or backpack sprayer.

• Use appropriate herbicide-free buffer zones for herbicides not labeled for aquatic use based on risk assessment guidance, with minimum widths of 100 feet for aerial, 25 feet for vehicle, and 10 feet for hand spray applications.

Vegetation • Refer to the herbicide label when planning revegetation to ensure that subsequent vegetation would not be injured following application of the herbicide.

BLM Vegetation Treatments Three New Herbicides A-11 August 2016 Final Programmatic EIS Record of Decision

TABLE A-2 (Cont.)

Standard Operating Procedures for Applying Pesticides

Resource Element Standard Operating Procedure

Vegetation (cont.)

See Manuals 5000 (Forest Management) and 9015 (Integrated Weed Management)

• Consider site characteristics, environmental conditions, and application equipment in order to minimize damage to non-target vegetation.

• Review, understand, and incorporate application information identified in the environmental hazards section of the herbicide label, along with all additional precautions and restrictions identified on the label.

• Use weed seed-free feed for horses and pack animals. Use weed seed-free straw and mulch for revegetation and other activities.

• Identify and implement any temporary domestic livestock grazing and/or supplemental feeding restrictions needed to enhance desirable vegetation recovery following treatment. Consider adjustments in the existing grazing permit to maintain desirable vegetation on the treatment site.

Pollinators

• Ensure proper identification of pollinator plants, as some native species that attract and support many pollinators may be easily misidentified as invasive/noxious weed species.

• Complete vegetation treatments seasonally before pollinator foraging plants bloom.

• Time vegetation treatments to take place when foraging pollinators are least active both seasonally and daily.

• Apply herbicides at the stage of growth when the weed is most vulnerable, when application will be most successful.

• Design vegetation treatment projects so that nectar and pollen sources for important pollinators and resources are treated in patches rather than in one single treatment, or conduct spot treatments on individual invasive/noxious weed species, using the appropriate application equipment.

• Minimize herbicide application rates. Use typical rather than maximum rates where there are important pollinator resources.

• Maintain herbicide free buffer zones around patches of important pollinator nectar and pollen sources.

• Maintain herbicide free buffer zones around patches of important pollinator nesting habitat and hibernacula.

• Make special note of pollinators that have single host plant species, and minimize herbicide spraying on those plants (if invasive species) and in their habitats.

Fish and Other Aquatic Organisms

See Manuals 6500 (Wildlife and Fisheries Management) and 6780 (Habitat Management Plans)

• Use appropriate buffer zones based on label and risk assessment guidance.

• Minimize treatments near fish-bearing water bodies during periods when fish are in life stages most sensitive to the herbicide(s) used, and use spot rather than broadcast or aerial treatments.

• Use appropriate application equipment/method near water bodies if the potential for off-site drift exists.

• For treatment of aquatic vegetation, 1) treat only that portion of the aquatic system necessary to achieve acceptable vegetation management, 2) use the appropriate application method to minimize the potential for injury to desirable vegetation and aquatic organisms, and 3) follow water use restrictions presented on the herbicide label.

Wildlife

See Manuals 6500 (Wildlife and Fisheries Management) and 6780 (Habitat Management Plans)

• Use herbicides of low toxicity to wildlife, where feasible.

• Use spot applications or low-boom broadcast operations where possible to limit the probability of contaminating non-target food and water sources, especially non-target vegetation over areas larger than the treatment area.

• Use timing restrictions (e.g., do not treat during critical wildlife breeding or staging periods) to minimize impacts to wildlife.

Threatened, Endangered, and Sensitive Species

See Manual 6840 (Special Status Species)

• Survey for special status species before treating an area, at a time when the species can be found. Consider effects to special status species when designing herbicide treatment programs.

• Where feasible, use a selective herbicide and a wick or backpack sprayer to minimize risks to special status plants.

• Avoid treating vegetation during time-sensitive periods (e.g., nesting and migration, sensitive life stages) for special status species in area to be treated.

BLM Vegetation Treatments Three New Herbicides A-12 August 2016 Final Programmatic EIS Record of Decision

TABLE A-2 (Cont.)

Standard Operating Procedures for Applying Pesticides

Resource Element Standard Operating Procedure

Livestock

• Whenever possible and whenever needed, schedule treatments when livestock are not present in the treatment area. Design treatments to take advantage of normal livestock grazing rest periods, when possible.

• As directed by the herbicide product label, remove livestock from treatment sites prior to herbicide application, where applicable.

• Use herbicides of low toxicity to livestock, where feasible.

• Take into account the different types of application equipment and methods, where possible, to reduce the probability of contamination of non-target food and water sources.

• Notify permittees of the herbicide treatment project to improve coordination and avoid potential conflicts and safety concerns during implementation of the treatment.

• Notify permittees of livestock grazing, feeding, or slaughter restrictions, if necessary.

• Provide alternative forage sites for livestock, if possible.

Wild Horses and Burros

• Minimize use of herbicides in areas grazed by wild horses and burros.

• Use herbicides of low toxicity to wild horses and burros, where feasible.

• Remove wild horses and burros from identified treatment areas prior to herbicide application, in accordance with herbicide product label directions for livestock.

• Take into account the different types of application equipment and methods, where possible, to reduce the probability of contaminating non-target food and water sources.

Cultural Resources and Paleontological Resources

See Handbooks H-8120-1 (Guidelines for Conducting Tribal Consultation) and H- 8270-1 (General Procedural Guidance for Paleontological Resource Management), and Manuals 8100 (The Foundations for Managing Cultural Resources), 8120 (Tribal Consultation Under Cultural Resource Authorities), and 8270 (Paleontological Resource Management)

See also: Programmatic Agreement among the Bureau of Land Management, the Advisory Council on Historic Preservation, and the National Conference of State Historic Preservation Officers Regarding the Manner in Which BLM Will Meet Its Responsibilities Under the National Historic Preservation Act.

• Follow standard procedures for compliance with Section 106 of the National Historic Preservation Act as implemented through the Programmatic Agreement among the Bureau of Land Management, the Advisory Council on Historic Preservation, and the National Conference of State Historic Preservation Officers Regarding the Manner in Which BLM Will Meet Its Responsibilities Under the National Historic Preservation Act and state protocols or 36 Code of Federal Regulations Part 800, including necessary consultations with State Historic Preservation Officers and interested tribes.

• Follow BLM Handbook H-8270-1 (General Procedural Guidance for Paleontological Resource Management) to determine known Condition I and Condition 2 paleontological areas, or collect information through inventory to establish Condition 1 and Condition 2 areas, determine resource types at risk from the proposed treatment, and develop appropriate measures to minimize or mitigate adverse impacts.

• Consult with tribes to locate any areas of vegetation that are of significance to the tribe and that might be affected by herbicide treatments.

• Work with tribes to minimize impacts to these resources.

• Follow guidance under Human Health and Safety in the PEIS in areas that may be visited by

Native peoples after treatments.

Visual Resources

See Handbooks H-8410-1 (Visual Resource Inventory) and H-8431-1 (Visual Resource Contrast Rating), and Manual 8400 (Visual Resource Management)

• Minimize the use of broadcast foliar applications in sensitive watersheds to avoid creating large areas of browned vegetation.

• Consider the surrounding land use before assigning aerial spraying as an application method.

BLM Vegetation Treatments Three New Herbicides A-13 August 2016 Final Programmatic EIS Record of Decision

TABLE A-2 (Cont.)

Standard Operating Procedures for Applying Pesticides

Resource Element Standard Operating Procedure

Visual Resources (cont.)

• Minimize off-site drift and mobility of herbicides (e.g., do not treat when winds exceed 10 mph; minimize treatment in areas where herbicide runoff is likely; establish appropriate buffer widths between treatment areas and residences) to contain visual changes to the intended treatment area.

• If the area is a Class I or II visual resource, ensure that the change to the characteristic landscape is low and does not attract attention (Class I), or if seen, does not attract the attention of the casual viewer (Class II).

• Lessen visual impacts by: 1) designing projects to blend in with topographic forms; 2) leaving some low-growing trees or planting some low-growing tree seedlings adjacent to the treatment area to screen short-term effects; and 3) revegetating the site following treatment.

• When restoring treated areas, design activities to repeat the form, line, color, and texture of the natural landscape character conditions to meet established Visual Resource Management objectives.

Wilderness and Other Special Areas

See Handbooks H-8550-1 (Management of Wilderness Study Areas (WSAs)), and H- 8560-1 (Management of Designated Wilderness Study Areas), and Manual 8351 (Wild and Scenic Rivers)

• Encourage backcountry pack and saddle stock users to feed their livestock only weed seed-free feed for several days before entering a wilderness area.

• Encourage stock users to tie and/or hold stock in such a way as to minimize soil disturbance and loss of native vegetation.

• Revegetate disturbed sites with native species if there is no reasonable expectation of natural regeneration.

• Provide educational materials at trailheads and other wilderness entry points to educate the public on the need to prevent the spread of weeds.

• Use the “minimum tool” to treat noxious and invasive vegetation, relying primarily on the use of ground-based tools, including backpack pumps, hand sprayers, and pumps mounted on pack and saddle stock.

• Use chemicals only when they are the minimum method necessary to control weeds that are spreading within the wilderness or threaten lands outside the wilderness.

• Give preference to herbicides that have the least impact on non-target species and the wilderness environment.

• Implement herbicide treatments during periods of low human use, where feasible.

• Address wilderness and special areas in management plans.

• Maintain adequate buffers for Wild and Scenic Rivers (¼ mile on either side of river, ½ mile in

Alaska).

Recreation

See Handbook H-1601-1 (Land Use Planning Handbook, Appendix C)

• Schedule treatments to avoid peak recreational use times, while taking into account the optimum management period for the targeted species.

• Notify the public of treatment methods, hazards, times, and nearby alternative recreation areas.

• Adhere to entry restrictions identified on the herbicide product label for public and worker access.

• Post signs noting exclusion areas and the duration of exclusion, if necessary.

• Use herbicides during periods of low human use, where feasible.

Social and Economic Values

• Consider surrounding land use before selecting aerial spraying as a method, and avoid aerial spraying near agricultural or densely-populated areas.

• Post treated areas and specify reentry or rest times, if appropriate.

• Notify grazing permittees of livestock feeding restrictions in treated areas, if necessary, as per herbicide product label instructions.

• Notify the public of the project to improve coordination and avoid potential conflicts and safety concerns during implementation of the treatment.

• Control public access until potential treatment hazards no longer exist, per herbicide product label instructions.

• Observe restricted entry intervals specified by the herbicide product label.

BLM Vegetation Treatments Three New Herbicides A-14 August 2016 Final Programmatic EIS Record of Decision

TABLE A-2 (Cont.)

Standard Operating Procedures for Applying Pesticides

Resource Element Standard Operating Procedure

Social and Economic Values (cont.)

• Notify local emergency personnel of proposed treatments.

• Use spot applications or low-boom broadcast applications where possible to limit the probability of contaminating non-target food and water sources, especially vegetation over areas larger than the treatment area.

• Consult with Native American tribes, Alaska Native groups, and Alaska Native Corporations to locate any areas of vegetation that are of significance to tribes, Native groups, or Alaska Native Corporations and that might be affected by herbicide treatments.

• To the degree possible within the law, hire local contractors and workers to assist with herbicide application projects and purchase materials and supplies, including chemicals, for herbicide treatment projects through local suppliers.

• To minimize fears based on lack of information, provide public educational information on the need for vegetation treatments and the use of herbicides in an integrated pest management program for projects proposing local use of herbicides.

Rights-of-way

• Coordinate vegetation management activities where joint or multiple use of a ROW exists.

• Notify other public land users within or adjacent to the ROW proposed for treatment.

• Use only herbicides that are approved for use in ROW areas.

Human Health and Safety

• Establish a buffer between treatment areas and human residences based on guidance given in the human health risk assessment, with a minimum buffer of ¼ mile for aerial applications and 100 feet for ground applications, unless a written waiver is granted.

• Use protective equipment as directed by the herbicide product label.

• Post treated areas with appropriate signs at common public access areas.

• Observe restricted entry intervals specified by the herbicide product label.

• Provide public notification in newspapers or other media where the potential exists for public exposure.

• Have a copy of MSDSs/SDSs at work site.

• Notify local emergency personnel of proposed treatments.

• Contain and clean up spills and request help as needed.

• Secure containers during transport.

• Follow label directions for use and storage.

• Dispose of unwanted herbicides promptly and correctly.

BLM Vegetation Treatments Three New Herbicides A-15 August 2016 Final Programmatic EIS Record of Decision

TABLE A-3

Mitigation Measures From the 2007 PEIS

Resource Mitigation Measures Air Quality None proposed.

Soil Resources None proposed.

Water Resources and Quality

• Establish appropriate (herbicide specific) buffer zones to downstream water bodies, habitats, and species/populations of interest.

Wetland and Riparian Areas • See mitigation for Water Resources and Quality and Vegetation.

Vegetation

• Minimize the use of terrestrial herbicides (especially bromacil, diuron, and sulfometuron methyl) in watersheds with downgradient ponds and streams if potential impacts to aquatic plants are of concern.

• Establish appropriate (herbicide specific) buffer zones around downstream water bodies, habitats, and species/populations of interest. Consult the ecological risk assessments for more specific information on appropriate buffer distances under different soil, moisture, vegetation, and application scenarios.

• To protect special status plant species, implement all conservation measures for plants presented in the Vegetation Treatments on Bureau of Land Management Lands in 17 Western States Programmatic Biological Assessment.

Fish and Other Aquatic Organisms

• Limit the use of diquat in water bodies that have native fish and aquatic resources.

• Limit the use of terrestrial herbicides in watersheds with characteristics suitable for potential surface runoff, that have fish-bearing streams, during periods when fish are in life stages most sensitive to the herbicide(s) used.

• To protect special status fish and other aquatic organisms, implement all conservation measures for aquatic animals presented in the Vegetation Treatments on Bureau of Land Management Lands in 17 Western States Programmatic Biological Assessment.

• Establish appropriate herbicide-specific buffer zones for water bodies, habitats, or fish or other aquatic species of interest (see recommendations in individual ecological risk assessments).

• Avoid using the adjuvant R-11® in aquatic environments, and either avoid using glyphosate formulations containing polyoxyethyleneamine (POEA), or seek to use formulations with the least amount of POEA, to reduce risks to aquatic organisms.

Wildlife

• To minimize risks to terrestrial wildlife, do not exceed the typical application rate for applications of dicamba, diuron, glyphosate, hexazinone, tebuthiuron, or triclopyr, where feasible.

• Minimize the size of application areas, where practical, when applying 2,4-D, bromacil, diuron, and Overdrive® to limit impacts to wildlife, particularly through contamination of food items.

• Where practical, limit glyphosate and hexazinone to spot applications in rangeland and wildlife habitat areas to avoid contamination of wildlife food items.

• Avoid using the adjuvant R-11® in aquatic environments, and either avoid using glyphosate formulations containing POEA, or seek to use formulations with the least amount of POEA, to reduce risks to amphibians.

• Do not apply bromacil or diuron in rangelands, and use appropriate buffer zones (see Vegetation section in Chapter 4) to limit contamination of off-site vegetation, which may serve as forage for wildlife.

• Do not aerially apply diquat directly to wetlands or riparian areas.

• To protect special status wildlife species, implement all conservation measures for terrestrial animals presented in the Vegetation Treatments on Bureau of Land Management Lands in 17 Western States Programmatic Biological Assessment. Apply these measures to special status species (refer to conservation measures for a similar size and type of species, of the same trophic guild).

BLM Vegetation Treatments Three New Herbicides A-16 August 2016 Final Programmatic EIS Record of Decision

TABLE A-3 (Cont.)

Mitigation Measures From the 2007 PEIS

Resource Mitigation Measures

Livestock

• Minimize potential risks to livestock by applying diuron, glyphosate, hexazinone, tebuthiuron, and triclopyr at the typical application rate, where feasible.

• Do not apply 2,4-D, bromacil, dicamba, diuron, Overdrive®, picloram, or triclopyr across large application areas, where feasible, to limit impacts to livestock, particularly through the contamination of food items.

• Where feasible, limit glyphosate and hexazinone to spot applications in rangeland.

• Do not aerially apply diquat directly to wetlands or riparian areas used by livestock.

• Do not apply bromacil or diuron in rangelands, and use appropriate buffer zones (see

Vegetation section in Chapter 4) to limit contamination of off-site rangeland vegetation.

Wild Horses and Burros

• Minimize potential risks to wild horses and burros by applying diuron, glyphosate, hexazinone, tebuthiuron, and triclopyr at the typical application rate, where feasible.

• Consider the size of the application area when making applications of 2,4-D, bromacil, dicamba, diuron, Overdrive®, picloram, and triclopyr in order to reduce potential impacts to livestock.

• Apply herbicide label grazing restrictions for livestock to herbicide treatment areas that support populations of wild horses and burros.

• Where feasible, limit glyphosate and hexazinone to spot applications in rangeland.

• Do not apply bromacil or diuron in grazing lands within herd management areas, and use appropriate buffer zones (see Vegetation section in Chapter 4) to limit contamination of vegetation in off-site foraging areas.

• Do not apply 2,4-D, bromacil, or diuron in herd management areas during the peak foaling season (March through June, and especially in May and June), and do not exceed the typical application rate of Overdrive® or hexazinone in herd management areas during the peak foaling season.

Paleontological and Cultural Resources

• Do not exceed the typical application rate when applying 2,4-D, bromacil, diquat, diuron, fluridone, hexazinone, tebuthiuron, and triclopyr in known traditional use areas.

• Avoid applying bromacil or tebuthiuron aerially in known traditional use areas.

• Limit diquat applications to areas away from high residential and traditional use areas to reduce risks to Native Americans and Alaska Natives.

Visual Resources None proposed.

Wilderness and Other Special Areas

Mitigation measures that may apply to wilderness and other special area resources are associated with human and ecological health and recreation. Please refer to the Vegetation, Fish and Other Aquatic Resources, Wildlife Resources, Recreation, and Human Health and Safety sections of Chapter 4.

Recreation Mitigation measures that may apply to recreational resources are associated with human and ecological health. Please refer to the Vegetation, Fish and Other Aquatic Resources, Wildlife Resources, and Human Health and Safety sections of Chapter 4.

Social and Economic Values None proposed.

Human Health and Safety

• Use the typical application rate, where feasible, when applying 2,4-D, bromacil, diquat, diuron, fluridone, hexazinone, tebuthiuron, and triclopyr to reduce risk to occupational and public receptors.

• Avoid applying bromacil or diuron aerially.

• Limit application of chlorsulfuron via ground broadcast applications at the maximum application rate.

• Limit diquat application to all-terrain vehicle, truck spraying, and boat applications to reduce risks to occupational receptors; limit diquat applications to areas away from high residential and subsistence use to reduce risks to public receptors.

• Evaluate diuron applications on a site-by-site basis to avoid risks to humans. There appear to be few scenarios where diuron can be applied without risk to occupational receptors.

• Do not apply hexazinone with an over-the-shoulder broadcast applicator.