> at least PMRA  is going in a proper direction
> it's a start and moving things forward in a  POSITIVE WAY!

I firmly disagree. 
Please consider the viewpoint of the grower, the one who must incur the
additional costs.

While the incremental step of reducing the amount of dust with an additive
may seem a good one,  all this does is raise the wind velocity required at
which the remaining dust does the same damage.  So, the lubricant is not a
true solution, in that it does not eliminate dust, but merely attempts to
reduce it.  Further, it is a expense item, where an equipment mod would be a
capital item, with much more advantageous financials for the grower
(depreciation, investment tax credits and such). 

Worse, it allows a sense of complacency to become established, even though
the problem remains  unsolved.  Asking anything more will be viewed as
"excessive", as you get ONE bite at the apple when you deal with issues of
this type.

The lubricant is a mere band-aid.  When this same problem occurred in
Germany, the Germans went through the same evaluation process, and their
best practices included the following:

- Do not plant treated seeds in case of wind speeds of more than 5 m/s.

- The treated seeds including contained dusts or dusts developing during the
sowing process, have to be worked completely into the soil.

- Treated seeds should not be planted by means of pneumatic seeding machines
(vacuum system), unless the exhaust air is channeled in such a way that the
dusts can be led into the soil.

The above are from this document, dated July 2008
http://tinyurl.com/qce9s8b

             ***********************************************
The BEE-L mailing list is powered by L-Soft's renowned
LISTSERV(R) list management software.  For more information, go to:
http://www.lsoft.com/LISTSERV-powered.html