Label Confusion Dean Herzfeld Pesticide Safety & Environmental Education www.extension.edu/pesticides Driven To Discover
It is more than just, Read & follow the label. Pesticide Labeling
Label Provides Applicators: How to minimize risk to themselves, nontarget species & environment Ways to maximize efficacy of product Means to limit your liability Essential for following and enforcing laws
Educational tool Comprehensive use instructions In a perfect world. Registrants would create labeling that EPA
would approve without comment EPA would receive labels for review that would mitigate risks & meet regulatory standards Users would not only read, but also understand, and be willing to follow label instructions State Lead Agencies would never have to take
an enforcement action If that perfect world existed.. ..then this would be
Minnesota in January for at least a couple of days! But this is what it is Recent Progress on Labeling
The Label Review Manual has been revised and updated There has been significant input from stakeholders via the Enable the Label Blog EPA has developed training for it label reviewers
Can we.. Create labels that make sense to the user?
Core Principles for label Quality: Clarity Accuracy Clear Mandatory vs. Advisory statements Consistent with EPA Policy
Above all else, a label must be understood, which means using clear, unambiguous language, and a rational organization of the
information on the label. EPA, OPP Clarity If EPA label requirements are tied
to specific criteria such as toxicity levels or incident history, those criteria must be accurately applied to the product in question. Directions for use also must be accurately and clearly stated.
EPA, OPP Accuracy When a direction or precaution is intended to be mandatory &
enforceable, that intent must be clear..Conversely, advisory information must not be given the appearance of mandatory statements.. EPA, OPP
Mandatory vs. Advisory Mandatory: Shall Must Do this Do not Advisory?
Should May Recommended For best results Mandatory vs. Advisory Label reviewers need to apply all relevant requirements & policies,
and should not accept deviations.. .....the Label Review Manual provide(s) links to underlying regulations and policy documents. EPA, OPP
Consistent with policy 2,4,d Label WPS In Rights-of-Way? In Forestry? What is
gusty? Ground Application: DO NOT apply when winds are gusty or when conditions will favor movement of the spray particles off the desired spray target.
Not an RUP Who can apply it? Spray < 3 MPH with No Inversion? Ultimately labels need: 1.
2. 3. 4.
Clarity Can it make sense to an average person? Accuracy Clear Mandatory vs. Advisory statements Consistent with EPA Policy
Glove Label Statements Roundup Weather Max (2009) Any waterproof material such as polyethyelene or polyvinyl chloride Weedar 64 (2010)
Some materials that are chemical resistant are listed below (NOT). For more options, follow instructions for Category A on an EPA Chemical Resistance Chart. Bonfire Herbicide (2011) Chemical resistant gloves Category A (e.g. barrier laminate, butyl rubber, nitrile rubber, neoprene rubber, natural rubber, polyethylene, polyvinyl chloride (PVC)
or viton) Glove Label Statements Sevin 4F (2010) Some materials that are chemical resistant to this product are made of any waterproof material. . . . For
more options, follow instructions for Category A on an EPA Chemical Resistance Chart. . . . Wear chemical resistant gloves. Lorsban Advance (2012) Materials that are chemical resistant to this product are barrier laminate or viton >14mils . . . . Must wear
chemical resistant gloves Milestone VM Mandatory vs Advisory Core Principles for label Quality: Clarity
Accuracy Clear Mandatory vs. Advisory statements Consistent with EPA Policy Dean Herzfeld
Pesticide Safety & Environmental Education www.extension.edu/pesticides Driven To Discover
