Determination for Propionic Acid Will Impact Dealers, Custom Hay Balers

Mike Rankin
Crops and Soils Agent
University of Wisconsin - Extension

        Although the EPA has always considered propionic acid a pesticide, applications to hay, corn, or silage were previously deemed non-pesticidal uses.  That determination has now been reversed.  The Wisconsin Department of Agriculture, Trade, and Consumer Protection is giving a one year (2001) grace period for manufacturers and labelers to get propionic acid products registered as a pesticide.  Some products are already or will soon be registered.  Existing stocks of product may be used as labeled.  Dealers distributing a registered product must adhere to all provisions regarding bulk storage, certification, and licensing. 

        Propionic acid is NOT considered a restricted-use pesticide.  Thus, farmers who apply the product for their own use do not need to obtain private pesticide applicator certification.  However, custom balers and anybody else applying a labeled propionic acid product during an operation for hire will now need to be certified and licensed as a commercial applicator in the Field and Vegetable Crops category.  Contact the UW Extension office for details on how this can be done.

I just bale a few acres for the neighbor.  Will I need a commercial license?

            The same rules will apply for propionic acid as it would for any other pesticide.  Wisconsin law allows pesticide applications for hire by an applicator if it is not performed for more than three different individuals or is less than a total of 500 acres in any one calendar year.  Exceeding either of these two criteria will place you into the category of a commercial applicator.  The change in pesticide status appears as if it will primarily impact dealers and custom balers.