The pre-harvest interval (PHI) on a pesticide label is a time period following a pesticide application when a crop must stay in the application site and cannot be removed from there. Brokers, co-ops and other receivers of commodities for processing inspect producer’s pesticide application records to determine if PHIs were observed before they will accept the crop.
The pesticide label’s “Directions for Use” section begins with the statement: “It is a violation of Federal Law to use this product in a manner inconsistent with its labeling.” The label is a legal document and this statement is telling the applicator using a pesticide in a manner not permitted by the label is wrong. Harvesting before a PHI expires is illegal.
The Michigan State University Pesticide Safety Education Program is receiving telephone inquiries about how harvesting before a PHI has expired can be done. The inquirer in one circumstance had applied a fungicide with a label stating the PHI was longer than the anticipated time of harvest. The inquirer reported they needed to harvest in two weeks and the fungicide has a 45-day PHI and asked if there was an antidote for the pesticide.
Another inquirer submitted samples to a lab for residue testing and received a report that the residue was below Food Quality Protection Act (FQPA) tolerances for the commodity. Again, they needed to harvest before the PHI expired and wanted to know if they did not have to observe the PHI. The answer is, in any case, harvesting cannot happen before a PHI expires.
The responsibility for a compliant pesticide application belongs to the applicator. A well-planned pesticide application begins with reading the entire pesticide label to insure the pest is managed and all other mandatory label requirements are met.