Pesticides

Propionic Acid Hay Preservative

Hay Preservative Product Use - Fast Facts for Distributors, Farmers & Custom Hay Balers

The Issue

Propionic acid, commonly used as hay preservative, is also used as a food and feed ingredient. The two products are not one and the same. Only the pesticide product can be used by custom applicators or distributed with a claim of pest control such as mold. Registered pesticides must have a label affixed to the container in which the product is distributed.

Food and feed-grade products cannot legally be distributed for pest control unless they are also labeled and registered by EPA for that use.

Pesticide Product Labels

Pesticide labels will contain an EPA registration number, an EPA establishment number and a signal word like ‘Caution’ or ‘Warning.’ The label will have use directions that must be followed, including require protective clothing and eye protection because concentrated solutions of propionic acid can harm the skin or eyes.

Persons who distribute pesticides must be licensed by the Wisconsin Department of Agriculture, Trade and Consumer Protection. Persons who apply pesticides commercially must be both licensed and certified by WDATCP.

Use of Unlabeled Products on Your Own Property

If you purchase a propionic acid-based chemical product that is not registered and does not have a pesticide label, you may use it only on your own hay, but you cannot legally distribute or apply it to the property of others. Be careful though, when using these products on your property, since they will not have use directions and may not meet the guarantees listed on the labeled products.

Bulk storage Requirements

Application businesses or commercial businesses that store pesticide-labeled product in containers that exceed 55 gallons in capacity (such as a mini-bulk), must follow bulk storage requirements. The primary requirements of the rules are that bulk pesticide containers must be stored within a secondary containment structure and that any transfer of bulk pesticide between storage containers must be performed over a containment surface/mixing and loading pad.

Requirements for Labeled Products

If you purchase a propionic acid-based hay preservative that is labeled as a pesticide, and you will use it on your own hay crop, you may do that. Propionic acid is considered a general use pesticide, so you don’t have to have a private pesticide applicator certification. The exceptions are farmers who bale hay for others and custom balers.

Farmers Who Bale Hay for Others

Farmers who (a) are paid to bale hay or (b) who bale hay for more than three people or on more than 500 acres in a calendar year and (c) apply propionic acid to the hay, are acting as a commercial pesticide applicator-for-hire. You will need to pass a commercial certification exam in category 1.1, field and vegetable crops, obtain an annual pesticide applicator’s license and an annual pesticide business license. (The acreage for each cutting is counted so if you bale three cuttings of 200 acres, then you are over the 500-acre limit for the year.)

Custom Hay Balers

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

Custom applicators of propionic acid pesticides are required to hold a current DATCP pesticide certification under the 1.1-Field and Vegetable Pest Control category and have licenses as an individual applicator and a pesticide business license. They must also make and retain for two years, a record of each application in accordance with the commercial applicator requirements under Ch. ATCP 29, Wis. Adm. Code, and provide records of product and application events to their customers at the time of each application.

For More Information

• Pesticide use and control (ATCP 29, Wis. Adm. Code)- 608/224-4547
• Bulk storage requirements (Ch. ATCP 33, Wis. Adm. Code) - 608/224-4518
• Applicator certification training materials & sessions - 608/262-7588
• Applicator certification examinations - 608/224-4548

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