Check Hay Preservative Products For New Labels ……
the latest from WDATCP

Mike Rankin
Crops and Soils Agent
University of Wisconsin - Extension

What’s the issue?

Some commonly used hay preservatives are slated for a new label that could mean significant changes for custom hay balers and some farmers who bale hay for others.

Manufacturers of propionic acid were asked by the Environmental Protection Agency last July to label their products as a pesticide. This includes regular propionic acid and buffered solutions of propionic acid. Propionic acid used on stored grain is already labeled as a pesticide.

Why is EPA doing this?

A pesticide is defined as something that prevents, destroys, repels or mitigates any pest.  Pests can include plants, insects, rodents, fungus, bacteria or mold.  Because propionic acid prevents mold-growth, it is considered a pesticide. Years ago it was labeled as a pesticide for use on hay but manufacturers were mistakenly told by EPA that they no longer had to register the product.  EPA is now correcting the mistake.

When will propionic acid products for hay have to be relabeled?

EPA has not set a deadline for manufacturers to have their products relabeled. It is possible there will be hay preservatives with pesticide labels in the marketplace this year. However, the product registration and label approval process takes time, so it’s hard to predict how many products will actually carry a pesticide label.

How will I know if the hay preservative has a new pesticide label?

Pesticide labels will contain an EPA registration number, an EPA establishment number and a signal word like ‘Caution’ or ‘Warning’. The new pesticide labels will likely require protective clothing and eye protection because concentrated solutions of propionic acid can harm the skin or eyes.

What happens if I buy product that does not have a new label?

If you purchase a propionic acid-based hay preservative that does not have a pesticide label, then use the product as you always have (certification NOT required).

What if the propionic acid product I buy has a new pesticide label?

If you purchase a propionic acid-based hay preservative that is labeled as a pesticide, and you intend to use it on your own hay crop, there is no change except possibly the types of personal protective equipment required when using this chemical. Propionic acid is considered a general use pesticide so you don’t have to hold private pesticide certification. The exception may be farmers who bale hay for others.

I’m a farmer who bales hay for others.  What’s the impact on me?

Farmers who bale hay for others will likely face some changes. If you (a) are paid to bale hay for more than three people or on more than 500 acres in a calendar year; (b) apply propionic acid to the hay; and (c) the preservative is labeled as a pesticide, then you are acting as a commercial pesticide applicator. You will need to pass a commercial certification exam, obtain a pesticide applicator’s license and obtain a pesticide business license.  (The acreage for each cutting is counted so if you bale three cuttings off 200 acres, then you are over the 500-acre limit for the year.)

I’m a custom hay baler.  How does this affect me?

The same commercial licensing and certification requirements listed above would also apply to custom hay balers using propionic acid that carries a pesticide label (commercial applicator’s certification and license, pesticide application business license).

How do I get the appropriate licenses and certification?

·         Pass a commercial pesticide certification exam in category 1.1, field and vegetable crops: This is a written exam that measures the knowledge to properly use pesticides in Wisconsin.  The University of Wisconsin Extension Pesticide Applicator Training program (PAT) provides the training and certification materials. The cost for training materials is $45.00 per certification category and is good for five years. To order training materials, get information on training sessions and receive a list of testing sites, contact the UW Extension office.

·         Obtain an individual commercial pesticide applicator license: This annual license is required for anyone who must be certified as a commercial pesticide applicator. An individual license costs $30.00 per year and is valid from January 1 – December 31. Once becoming commercially certified, pesticide applicators will receive an application form for an annual license. Commercial pesticide applicators must also follow record keeping requirements.

·         Obtain a pesticide application business location license: This license is needed for any business that applies pesticides for payment. The annual license fee is $70.00 and is valid from January 1-December 31. For an application form, call 608-266-4548 or see the department’s Web site at:

 http://datcp.state.wi.us/static/arm/certs/pesticide/pest_bus.htm

Are there other requirements for handling a pesticide?