The pesticide world is so full of acronyms it’s not even funny, and we use them all the time. I did in this title, and you probably thought “where do I find it? heck I don’t even know what it is”. Well hopefully I can help you navigate these important tools and help you answer Do you know where to find a PULA?
Lets just define this thing right up front, Pesticide Use Limitation Area (PULA), is a defined area with restrictions NOT listed on the label. Long time readers will know that the Label is the Law and ALL your instructions are on the label. So how can there be restrictions that aren’t listed on the label, doesn’t that defeat the purpose?
Where do I find it?
You are correct, restrictions must be on the label and a PULA is listed on the label. Particularly newer labels, and more to come in the future, will have a stipulation that you must check for a PULA. It can be found where endangered species are discussed on the label and will direct to a website. This is typically found in the Directions for Use, NOT in the Environmental Hazard section where you might initially look. That the website is listed on the label it is considered part of the label, so the website IS the label too. Any restrictions or guidance provided there must be followed.
You can find all of the PULAs on the Bulletins Live Two system. Read their how to use it section and start poking around to see where you fall. If you are outside of a PULA, you have to follow the label, but the restrictions of the PULA do not apply to you. If you are inside the PULA you MUST follow the additional restrictions. Labels that direct you to look for a PULA will also state you must look no sooner than 6 months before a treatment. So you don’t have to check day of, but you can’t check for a PULA 7 months before and stay in compliance. This is because PULAs can be redrawn and it is a living document.
How do I use it?
Simply looking at the map can be overwhelming, but once you learn the system it is not too bad. You can search by location (city, county, or precise latitude and longitude coordinates), select the date you intend to treat AND search by EPA registration number. That will ensure ONLY that product, at that time, and in that location will pull up. This is important as some restrictions are time sensitive and may not apply when you are looking to treat.
Like all the records you keep related to pesticides you must keep proof that you abided by and checked for PULAs in your area if directed to by the label. Luckily the bulletins they provide can be printed and stored with all your other training and spray records.
Currently in Florida there are only a few PULAs for a small number of products BUT the EPA will very likely increase the usage of this mechanism. It’s a good idea to work with the system now and become familiar with it so that you can be in compliance when the time comes.
Why do we need it?
This may seem like one more hurdle to jump through, but it doesn’t come from a terrible place. This is an attempt to communicate very complicated information, particularly as it relates to endangered species. The goal is to protect these vulnerable species (remember Rachel Carson) while also speeding up the process. We wrote how cumbersome that was when we discussed Biological Evaluations and Biological Opinions. This is an improvement of sorts, it will just take getting used to.
The label is the law, and so is a PULA. Make yourself comfortable and familiar with the Bulletins Live Two system. This will ensure you are ready for any changes in the future. So now you know that a PULA is part of the label. This will be important in the future and you can answer “Do you know where to find a PULA?”.
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