DIRECTIONS FOR USE AND THE LAW
Pesticides are developed by the manufacturer, registered with EPA, and sold to the public with the assumption that users read, understand, and follow instructions found on the product label. Specific information on use, personal protective equipment, environmental precautions, and storage and disposal are found on
the pesticide label. The purpose of the label is to provide clear directions to allow maximum product benefit while minimizing risks to human health and the environment. All research, testing, and regulatory processes ultimately are reflected through the language on the label.
Every pesticide label includes the statement, "It is a violation of federal law to use this product in a manner inconsistent with its labeling." This language obliges the purchaser or user of any pesticide to assume responsibilities for the use of the product. Further, courts of law and regulators generally recognize the pesticide label is a binding contract which requires the person using the product to do so exactly as directed. Terms such as must, shall, do not, and shall not mean that the user is responsible for specific actions when applying or handling the given product; any departure from such directions is, in the eyes of the law, an illegal use of the pesticide.
"Use" means more than just the application of the pesticide. Federal and state regulations define pesticide use to include handling, mixing, loading, storage, transportation, and disposal, as well as human and environmental exposure. This all-encompassing definition covers every activity that involves a pesticide—from purchase to container disposal.
The pesticide label is more than just a piece of paper. It serves a dual function: The label instructs the user how to use the product safely and effectively, and it serves as a legal measuring stick. Many statements on the label result from rigorous scientific investigation and governmental regulatory decisions. Pesticide users should read, understand, and follow pesticide label directions to ensure effective pest control, personal safety, environmental protection and legal compliance.
TYPES OF PESTICIDE LABELING
A pesticide product can be used only according to the directions on the label accompanying it at the time of sale or according to labeling amended by the registrant through subsequent federal or state approval. The most comprehensive registration is granted under Section 3 of FIFRA. Section 3 registration means that EPA has reviewed and approved all information required to support all uses listed on the product label. Most pesticides bear Section 3 labeling.
Under FIFRA Section 24(c), states can grant registrations for additional uses of a pesticide product to meet special local needs. Section 24(c) labeling applies only to the use pattern for crops, commodities, or sites already listed by the label issued under Section 3. Both Section 3 and 24(c) labels must be in the possession of and followed by the applicator at time of application. Additional uses permitted by Section 24(c) registration are legal only in the state which issued that registration.
Under certain conditions, a state may petition EPA for a Section 18 emergency exemption from full Section 3 registration requirements for a particular product. If granted, the emergency exemption temporarily expands the terms of that specific pesticide label to include an addition (emergency) use of the product. Exemptions under Section18 may be granted by EPA only when certain carefully defined emergency, crisis, or quarantine conditions prevail. Users of products covered under this seldom-used exemption must obtain use directions from their respective state lead agency and may be required to report the amount of product used and/or areas treated.
ORGANIZATION OF THE PESTICIDE LABEL
Becoming familiar with pesticide label content and design is crucial to selecting the most appropriate pesticide products and receiving maximum benefit from their use. While label information may seem overwhelming at first, it takes only a few minutes to understand the entire contents once the general format has been mastered.
FIFRA mandates that every pesticide product bear a label that clearly shows the brand name, name and address of the registrant, net contents, product registration number, establishment number, ingredient statement, warning or precautionary statements, use classification, signal words, and use directions. Although EPA establishes standards for location and content of certain label information, manufacturers control much of the design and layout. Information contained on most labels can be divided into four
major categories: safety information, environmental information, product information, and use information. Thus, before selecting a pesticide product, the potential user should become familiar with the product label.
Labels change! Do not attempt to memorize the pesticide label. Reading the label each time you select and use a pesticide product allows you to recognize changes and achieve effective control while protecting yourself, others, and the environment from the consequences of misuse.
Safety Information
Child hazard warning. The front panel of every pesticide product label must bear the statement, "Keep Out Of Reach Of Children." The EPA may waive this requirement only in cases where the likelihood of contact with children is extremely remote, or when the product is approved for use on children.
A signal word must appear prominently on the front of the pesticide container, providing, in essence, a one word summary of the product’s potential toxicity to humans. The three signal words, in decreasing order of toxicity, are DANGER (highly toxic), WARNING (moderately toxic), and CAUTION (slightly toxic).
A product’s signal word is assigned on the basis of laboratory tests conducted on that particular product Data are compiled from animal studies on exposure through ingestion, inhalation, and dermal (skin and eye) absorption; and the route of exposure which shows the highest human toxicity potential determines the signal word assigned to the label. For example, if laboratory test results indicate Product XYZ to be moderately toxic if ingested, highly toxic if inhaled, and slightly toxic if absorbed through the skin or eyes, the signal word would be danger based on inhalation studies.
Hazards to humans and domestic animals. Precautionary statements indicating specific hazards, routes of exposure, and precautions to be takento avoid human and animal injury are required on the label. Example: "Harmful if swallowed, inhaled, or absorbed through the skin." Precautionary warnings might include the language, "Do not breathe vapors or spray mist"; "Avoid contact with eyes, skin or clothing"; or "Handle concentrate in a ventilated area."
You cannot change the acute toxicity of a product. However, adherence to precautionary warnings and protective clothing and equipment statements will minimize exposure.
The protective clothing and equipment statement directs the applicator to reduce the potential for exposure by using protective clothing or equipment. Most pesticide labels contain very specific instructions concerning the type of clothing that must be worn during the handling and mixing processes.
Potential routes of exposure determine the types of protective clothing designated on the label. Generally, a long-sleeved shirt, long pants, and waterproof footwear are the minimum requirements. The label will state whether specific items such as respirators and chemical-resistant gloves, aprons, goggles, and boots are needed. Common label language includes "Wear full face shield, rubber gloves, apron, and waterproof footwear when pouring concentrate or when exposure to concentrate is possible," and "Eye protection and chemically resistant gloves and footwear, a long-sleeved shirt, and long-legged pants or coveralls are recommended."
The Statement of practical treatment (first aid) provides valuable information to persons at the scene of a pesticide poisoning. Some examples: "In case of contact with skin, wash immediately with plenty of soap and water"; "If swallowed, call a physician or poison control center immediately"; "Immediately wash eyes with water for at least 15 minutes and get medical attention"; "After first aid is given, take victim to clinic or hospital"; or "If inhaled, removed victim to fresh air."
The statement of practical treatment informs physicians and emergency responders of appropriate medical procedures for poisoning victims. For example, the statement might indicate to a physician: "There is no specific antidote"; "If the product is ingested, induce emesis or stomach lavage"; or "The use of an aqueous slurry of activated charcoal may be considered." Products labeled DANGER also bear an 800 number which physicians may call for further treatment advice. Emergency telephone numbers are provided on the Material Safety Data Sheet (MSDS). The pesticide distributor or manufacturer should be contacted for the MSDS.
Environmental Information
Environmental hazard statements are required to state the nature of potential hazards and appropriate precautions to avoid accident, injury, or damage if the product presents risks to nontarget organisms or the environment. Potential hazards are determined by a series of tests which evaluate a pesticide’s toxicity to wildlife such as mammals, fish, birds, aquatic invertebrates, and pollinating insects. Statements might include label language such as, "This product is highly toxic to bees," or "This product is highly toxic to fish," or "…toxic to aquatic invertebrates." To reduce the risks, the label may direct measures such as, "Do not allow drift to contact nontarget
plants," or "Do not apply directly to water or wetlands."
If the pesticide has the potential to harm an endangered or threatened species or its habitat, statements will indicate where not to apply the pesticide or refer the user to an endangered species bulletin for further information. For example, the label might read "Use of this product in a manner inconsistent with the Pesticide Use Bulletin for Protection of Endangered Species is a violation of federal law," "Restrictions for the protection of endangered species apply to this product," or "If restrictions apply to the area in which this product is to be used, you must obtain the Pesticide Use Bulletin for Protection of Endangered Species for that county."
Statements on environmental impact may indicate that the product "…may travel through soil and can enter ground water," or "…has been found in ground water." The label instructions will tell how to reduce the impact on the environment: "This product may not be mixed, loaded, or used within 50 feet of all wells, including abandoned wells, drainage wells, and sink holes’; or "This product has been shown to leach under certain conditions. Do not apply to sand and loamy sand soils where the water table (ground water) is close to the surface."
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Product Information
The brand (trade) name under which a pesticide product is sold always appears on the front panel and often is the most conspicuous part of the label.
The name and address of the producer, registrant, or person for whom the product was produced must be shown on the label. If the registrant’s name appears on the label and the registrant is not the producer, it must be qualified by appropriate wording such as "Packed for…" "Distributed by…" or "Sold by…."
The net weight or volume of the contents of the formulated pesticide product is displayed prominently on the label or stamped on the container.
The product registration number appears on the label, preceded by the phrase "EPA Registration No." or "EPA Reg. No." The registration number identifies a specific pesticide product and signifies that federal registration requirements have been met. At a minimum, registration numbers consist of two sets of digits: e.g., 491-005. The first set of digits identifies the registrant. The second set represents the specific registration issued to the company by EPA. Together, these numbers clearly identify the product.
The establishment number is preceded by the phrase "EPA Est." EPA requires pesticide production sites to be registered with EPA. A pesticide-producing establishment is assigned an EPA establishment number that clearly identifies that location. All pesticides produced at that location must bear its EPA establishment number on the label or container. Farm service centers which repackage bulk pesticides must be registered as pesticide-producing establishments; and, like all pesticide producers, they must keep records of their pesticide production and file annual production reports.
The ingredient statement normally is found on the front panel of the label. It identifies the name and percentage of a pesticide product that affects the target pest.Chemical names often are complex; for example, 2-chloro-4-ethylamino-6-isopropylamino-s-triazine is the active ingredient in the product AAtrex. To aid communication, EPA-approved common names may be substituted for chemical names.
Inert ingredients allow active ingredients to be formulated into many different products. As part of the formulation, they determine a product’s handling properties and influence toxicity, release rates, residual activity, persistence, and methods of application. Also, there are no pest controlling claims for inert ingredients; and, because product formulations are confidential, the total percent by weight of inert ingredients usually is the only information about inert ingredients found on the label.
The formulation of the product often appears on the front panel of the label, either near the brand name or in the general information section. Pesticides may be formulated into many products; currently, in the United States, some 450 active ingredients are formulated into 25,000 different products. Information about the type of product formulation—granular, liquid flowable, dry flowable, microencapsulated, emulsifiable concentrate, etc—provides insight about application equipment, handling properties, and performance characteristics.
General-use versus restricted-use classification. EPA may classify a certain pesticide product for restricted use due to the complexity of the designated use, concerns about environmental safety, or potential human toxicities. A restricted-use product may be bought and used only by a certified applicator or persons under the direct supervision of a certified applicator. A restricted-use statement appears conspicuously at the top of the front panel of the label to make oversight unlikely. All restricted-use pesticides are identified by the following language: "For retail sale to and use only by certified applicators or persons under their direct supervision, and only for those uses covered by the certified applicator’s certification."
Pesticides which remain unclassified are referred to as general-use pesticides and may be purchased by the general public; most pesticides used by homeowners aregeneral-use products. It should be noted that there is no such thin as a general-use statement; no general use statement ever will appear on the product label.
The physical and chemical hazard statements identify a given pesticide’s flammability or explosiveness. These statements show specific hazards and state conditions to be avoided. Examples: "Extremely Flammable"; "Contents Under Pressure"; "Keep away from fire, sparks, and heated surfaces"; "Do not puncture or incinerate containers"; "Exposure to temperatures above 130º F cause bursting."
The warranty information is the manufacturer’s assurance that the product conforms to the chemical description on the label and that it is fit for labeled purposes if used according to directions under normal conditions. The warranty does not extend to any use of the product contrary to label instructions, nor does it apply under abnormal conditions such as drought, tornadoes, hurricanes, or excessive rainfall.
Use Information
Misuse statements contain language such as, "It is a violation of federal law to use this product inconsistent with its labeling."
Storage and transportation statements may include the following: "Store at temperatures above 32º F;" "Do not contaminate feed, foodstuffs or drinking water"; "Do not store next to feed or food, or transport in or on vehicles containing foodstuffs or feed"; or "For help with any spill, leak fire or exposure involving this material, call Chem Trek (800-424-9300). Directions for use often comprise the bulk of a pesticide label. They must be adequate to protect the public from fraud and personal injury and to prevent unreasonable adverse effects on the environment. They must provide guidance to the user on the pests controlled, sites of application, compatibility with other pesticides, mixing or dilution rates, application rates, equipment needed for application, timing and frequency of applications, harvest intervals, and general information for successful results.
Directions for use may appear on any portion of the label. Because of the detail required for specific applications, use directions for common sites, pests, and applications may be grouped together under a general heading. Information specific to individual uses may be addressed under specific headings.
Agricultural Use Requirements will contain the statement, "Use this product only in accordance with its labeling and with the Worker Protection Standard, 40 CFR part 170." The standard itself will not appear on the label, so the user will be requested to obtain the standard from the EPA or the Cooperative Extension Service.
Re-entry or restricted entry statements contain reentry precautions and state a time interval during which reentry into a pesticide-treated site is not allowed. The statement indicates the length of time which must elapse after the pesticide application before individuals may enter the treated area without personal protective clothing and equipment. Examples of reentry statements include "Do not enter treated areas without protective clothing until sprays have dried," and "Do not enter or allow worker entry into treated areas during the restricted-entry interval of 24 hours."
Container rinsing and disposal statements list proper procedures for handling pesticide containers and disposing of unused products. Federal, state, and local regulations often must be consulted to determine how to dispose of unused pesticide concentrates or diluted mixtures. Container disposal statements could read "Triple rinse (or equivalent)"; "Do not reuse container"; "Offer for recycling or reconditioning"; "Puncture and dispose of in a sanitary landfill"; "Disposal by other procedures allowed by state and local authorities"; "Improper disposal of excess pesticides, spray mixture, or rinsate is a violation of federal law"; "If these wastes cannot be disposed of by use according to label instructions, contact your state pesticide or environmental control agency, or the hazardous waste representative at the nearest EPA regional office for guidance." While numerous pesticide labels still state that properly rinsed containers may be burned, almost every state has clean air laws which prohibit such disposal.
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