HPIPM:Pesticide Labeling
Author: Michael J. Brewer
Several sources were used in compiling this information, including materials from the Environmental Protection Agency and State Departments of Agriculture.
A primary source of information was:
McDonald, S.A. 1992. Applying Pesticides Correctly. Bulletin 825. Ohio State University, Columbus OH.
Pesticide product labeling is the principal communication between a pesticide manufacturer and pesticide user. The U.S. Environmental Protection Agency (EPA) reviews and approves the label and sets minimal labeling requirements to ensure adequate, consistent, and necessary information is provided to the user. Labeling includes the label printed on the pesticide container and all other supplemental labeling attached to the product or received from the manufacturer at the time that the product is purchased. The label provides information on how to use the product safely and correctly and how to avoid personal and environmental hazards associated with the product's use. Pesticide users are required by law to comply with all the label instructions.
EPA Approval of Pesticide Labeling
No pesticide may be sold in the United States until the U.S. Environmental Protection Agency (EPA) has approved the manufacturer's application for registration. The EPA has certain labeling information requirements, and must approve all statements that the manufacturer proposes to include on the label.
EPA reviews the labeling to make sure that it contains sufficient information needed for the safe and effective use of the pesticide on the commodity on which the pesticide is to be applied. The EPA does not require a list of target pests that can be controlled, but the manufacturer commonly provides this information on the label. The EPA requires submission of data by the manufacturer to verify label information and claims. The EPA may require that the labeling include other information about laws or regulations that have been adopted to protect humans or the environment. Changes in labeling after registration must be approved by the EPA. Proposed changes may be initiated by the manufacturer or the EPA.
There are three major types of registration: federal registration, special local needs registration, and emergency exemptions from standard registration.
Most pesticides are registered with federal EPA registrations. An official EPA registration number on the label indicates this type of registration. This type of registration is the preferred method of registration when special circumstances do not exist.
Special local needs registrations (known as SLN or section 24c registrations) allow states to register additional uses or add limitations for a federally registered pesticide. These registrations often involve adding application sites and alternate control techniques, such as changes in application rate, to those listed on the federally registered labeling. Special local needs registrations must be initiated by the state and the application must document the special need for use, or limitation of use, of the product. Supplemental labeling must be provided for each 24c registration. Applicators must have a copy of the 24c labeling in their possession in order to apply the pesticide for the special need. These registrations are legal only in the state or local area specified in the labeling. State Departments of Agriculture, pesticide dealers, and other professionals may assist in identifying situations where special local needs requests are appropriate and in confirming the existence of special local needs registrations for your locality.
Emergency exemptions from registration are used when an emergency pest situation arises for which no pesticide is registered and other methods of registration cannot occur in time to limit pest damage. These registrations are known as "Section 18 exemptions" and their application is initiated by a high governing official because of the emergency need for a pesticide not registered. This provision allows a pesticide product to be sold and used for a specified period of time and specific purpose. Strict controls and record keeping are required for all these emergency uses. The EPA must approve the application and, working with the requesting agency, will supply necessary application rates, safety precautions, and other vital information.
Classification of Pesticide Uses
EPA categorizes pesticide usage as either "unclassified" or "restricted use." A particular formulation of a pesticide may be classified in one category for all uses, or may be classified differently for different uses. Different packaging and labeling are used when the same pesticide is classified in different categories.
A pesticide is classified as restricted use if harm to humans (pesticide handlers or other persons) or to the environment is possible, unless it is applied by a certified applicator who has the knowledge to use these pesticides safely and effectively. A certified applicator must be the user of the product or directly supervise the use of the product. Product usage includes applications, mixing, loading, transporting, storing, handling, and applying the product after the manufacturer's seal is broken. Care and maintenance of application and handling equipment, and disposal of pesticides and their containers is also classified as pesticide usage.
An unclassified pesticide (not labeled restricted use) typically has high safety characteristics, resulting in reduced need of special handling, application equipment and disposal. Nonetheless, these good safety attributes are conditional upon proper use as instructed by the label. All users are responsible for following label instructions and precautions.
Certified Pesticide Applicators
Under Federal law, there are two types of certified pesticide applicators: private applicators and commercial applicators. Private applicators may use or supervise the use of restricted use pesticides to produce an agricultural commodity on property owned or rented by themselves or their employer, or on the property of another person with whom they trade services. Commercial applicators use or supervise the use of restricted use pesticides on any property or for any purpose other than that listed for private applicators.
Certification requires training or testing for competency in the safe and effective handling and use of restricted use pesticides. State, tribal, or Federal entities conduct training and testing for certification. In some areas, stricter standards are imposed than those required by Federal law. In moving across authorized boundaries of your certification, check with the State Department of Agriculture or EPA in the new area to determine if recertification is necessary.
Information provided on a Pesticide Label
The information on pesticide labeling usually is grouped under headings. Some information is required by law to appear on a label under certain headings and in certain locations on the label. Other information, including information not required, may be placed wherever the manufacturer chooses.
Pesticide labeling contains basic required label information that helps users clearly identify the product and the manner of use to ensure safety and effectiveness. Some of this information must appear on the front panel of the label. Other items may also appear on the front panel but may be located elsewhere on the label. The brand name appears on the front panel and is owned by the manufacturer if it is trademark registered. Different manufacturers may use different brand names for the same pesticide active ingredient. The active ingredient (ai) is the chemical in the product that has pesticide activity. Some precautions should be used when choosing a pesticide product by brand name, because some companies use the same basic name with only minor variations to designate entirely different active ingredients. Safety precautions may differ considerably for different active ingredients. Always read the ingredient statement to determine the active ingredients that a product contains.
The active ingredient(s) may be found in the ingredient statement, which is required to be listed on the front panel. The active ingredients and the amount of each ingredient (as a percentage of the total product) are listed. The ingredient statement must list the official chemical name and/or common name for each active ingredient. Inert ingredients need not be named, but the label must show their percentage of the total contents. Often, the general characteristics of the inert ingredients are listed, because they may have possible unintended environmental (such as oils with potential plant toxicity) or human health effects. The chemical name is almost always listed in the ingredient statement on the label. Because pesticides have complex chemical names, many are given a shorter common name. Only common names that are officially accepted by the EPA may be used in the ingredient statement on the pesticide label. For example, the chemical name of diazinon (a common name) is O, O-Diethyl O-(2-isopropyl-4-methyl-6-pyrimidinyl) phosphorothioate.
The common name is typically recognized within the U.S. but not necessarily in other countries. The chemical name has broad recognition. The official common name may be followed by the chemical name in the list of active ingredients. For example, a label with the brand name Sevin 50% WP would read:
Active ingredient:
Carbaryl(1_naphthyl N_methyl carbamate) …50%
Inert ingredient……………………………...50%
By purchasing pesticides according to the common or chemical names, you will ensure purchase of the intended product. Usually public agencies will provide pesticide information using the common name to ensure consistency with time (i.e., common names do not change, but brand names may change) and lack of bias among products with the same active ingredients.
Registration and establishment numbers are on the label in case of poisoning, claims of misuse, or liability claims. An EPA registration number (for example, EPA Reg. No. 3120-280-AA) indicates that the pesticide label has been approved by the EPA. Most products will contain only two sets of numbers; for example, EPA Reg. No. 3120-280. The first set of numbers, 3120, identifies the manufacturer or company. The second set, 280, identifies the product. Additional letters and numbers are sometimes part of the EPA registration number; for example, EPA Reg. No. 3120-280-AA-0850. The letters AA might be required by a particular state to appear on that label. The 0850 is the distributor's identification number and appears on labels of distributor products.
Another example is EPA SLN No. KS-770009. In this case, SLN indicates "special local need" and KS means that the product is registered for use in Kansas. If the SLN registration is for only a few of the registered uses in the pesticide labeling, the SLN number may not be on the front panel of the pesticide label. Instead, it may be located in the supplementary labeling.
The establishment number (for example, EPA Est. No. 5840_AZ_I) appears on either the pesticide label or container. It identifies the facility where the product was made. In case there are questions or concerns about the pesticide product, the facility that made the product can be determined.
The name and address of the manufacturer of a product is required to be placed on the label. The front panel of the pesticide label also provides the net contents. This can be expressed as pounds or ounces of dry formulations and as gallons, quarts, pints, or fluid ounces for liquids. Liquid formulations also may list the pounds of active ingredient (ai) per gallon of product. The type of pesticide usually is listed on the front panel of the label. This short statement indicates in general terms what the product will control. Examples of short statements of general use include "insecticide for control of certain insects on fruits, nuts, and ornamentals" and "herbicide for the control of trees, brush, and broadleaf weeds."
The type of formulation is also listed on the front panel of some pesticide labels. The formulation may be named or the label may show only an abbreviation, such as "WP" for wettable powder, "D" for dust, "EC" for emulsifiable concentrate and "L" for liquid. Formulation abbreviations are commonly consistent, but standardization is not required. For this reason, formulation abbreviations can be confusing. For example, the abbreviation "EC" indicates an emulsifiable concentration which is a good description of the formulation, but the abbreviation "TC" has been used to indicate termite control which provides no information on the type of formulation of the product.
When a pesticide is classified as restricted use, the label will state "Restricted Use Pesticide" in a box at the top of the front panel. Below the restricted use heading may be a statement describing the reason for this classification. The category of certified applicator who can purchase and use the product may also be listed. Pesticides that are listed as restricted use due to acute toxicity and toxicity to birds and mammals are for retail sale and use only by certified applicators or persons under their direct supervision and only for those uses covered by the certified applicators' certifications. The use of this product may be hazardous to your health. Pesticides that are listed as restricted use due to very high acute toxicity to humans and birds are 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. The use of this product may be hazardous to your health. Pesticides that are listed as restricted use due to oncogenicity (cancer_causing) are for retail sale and use only by certified applicators or persons under their direct supervision and only for those uses covered by the certified applicator's certification. The use of this product may be hazardous to your health. This product contains active ingredient(s) which has been determined to cause tumors in laboratory animals. Pesticides which are listed as restricted use due to ground water concern are 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 applicators' certification. Users must read and follow all precautionary statements and instructions for use in order to minimize potential of the active ingredient(s) to reach ground water. Direct supervision for these products is defined as the certified applicator being physically present during application, mixing, loading, repair, and cleaning of application equipment. Commercial certified applicators must also ensure that all persons involved in theses activities are informed of the precautionary statements.
Precautionary statements are listed on the front panel of the label. The statement, "Keep out of reach of children," must appear on every label.
Signal words and symbols indicate the risk of acute toxicity to humans if exposure occurs and must appear in large letters. The signal word is based on the toxicity of the active ingredient and other formulation ingredients in the product. It reflects the hazard of any active ingredients, carriers, solvents, or inert ingredients. The four routes of exposure to a pesticide are orally, dermally, through inhalation, and through eye contact. The signal word reflects the exposure route associated with greatest human risk. The signal word does not indicate the risk of delayed (chronic) effects or allergic effects. The following are EPA signal words and symbols that confer specific meaning:
DANGER—This word indicates that the pesticide is highly toxic. The product is very likely to cause acute illness from oral, dermal, or inhalation exposure, or to cause severe eye or skin irritation. The POISON/SKULL AND CROSSBONES signal word and symbols may accompany the DANGER signal word if the pesticide is very likely to cause acute illness through oral, dermal, or inhalation exposure. Products that have the signal word DANGER due to skin and eye irritation potential will not carry the word POISON or the skull and crossbones symbol. Examples of pesticides that may be placed in this category are parathion, aldicarb, monocrotophos, carbofuran, and terbufos. Toxicity and therefore signal words may change depending on the formulation of the product.
WARNING—This word indicates that the product is moderately toxic. The product has moderate potential to cause acute illness from oral, dermal, or inhalation exposure, or to cause severe eye or skin irritation. Examples of pesticides that may be placed in this category are chlorpyrifos and diazinon. Toxicity and therefore signal words may change depending on the formulation of the product.
CAUTION—This word indicates that the product is slightly toxic or relatively nontoxic. The product has only slight potential to cause acute illness from oral, dermal, or inhalation exposure. The skin or eye irritation it would cause, if any, is likely to be slight. Examples of pesticides that may be placed in this category are malathion, carbaryl, permethrin, and glyphosate. Toxicity and therefore signal words may change depending on the formulation of the product.
Also on the label
Also on the label, but not necessarily on the front panel, is the statement of practical treatment (first aid). For most pesticide products this statement is required. The instructions usually include first aid measures and may include instructions to seek medical help. If the "Statement of Practical Treatment" is not located on the front panel, a statement on the front panel must refer the user to the appropriate section of the label where this information may be found.
Acute effects statements also appear on the label and specifically indicate which route of entry (mouth, skin, eyes, lungs) pose risk to human and/or animal health. These statements may be located anywhere on the label. Many pesticides can cause acute effects by more than one route. These precautionary statements indicate what parts of your body will need the most protection. For example "DANGER: Fatal if swallowed or inhaled" and "DANGER: Corrosive—causes eye damage and severe skin burns" have the same signal word but the attached acute effect statement provides important information on the body parts which are essential to protect from pesticide exposure.
In addition, if the Environmental Protection Agency considers that the product has potential to cause delayed effects, the label must provide a delayed effect statement(s). These statements will tell you whether the product has been shown to cause tumors, chronic respiratory disease, reproductive problems, or other chronic effects in laboratory animals. If data indicate that the pesticide product has potential to cause allergic effects, such as skin irritation or asthma, the EPA requires an allergic effects statement appear on the label.
Personal protective equipment requirements immediately follow acute, delayed, and allergic effects information. Stated is the required minimum personal protective equipment that must be worn when using the pesticide. Sometimes personal protective equipment differ for different pesticide handling activities. For example, a respirator, gloves, and coveralls may be required for application of the product, but when safety systems are used, such as closed systems or enclosed cabs, the requirements may be reduced.
Environmental hazards statements on the label will provide precautions for protecting the environment. Some general statements appear. For example, do not contaminate water when applying the pesticide or when cleaning equipment or disposing of pesticide wastes. Specific precautionary statements are given if the pesticide poses a specific hazard to the environment. For example, "the product is highly toxic to bees or other wildlife." The label may state methods to reduce environmental hazards. For example, the statement "do not apply to crops in bloom" is given in order to avoid honeybee kill.
The physical or chemical hazards section of the label indicates if there are any special fire, explosion, or chemical hazards. For example, a flammable hazard statement alerts the user to keep the product away from heat or open flame, and a corrosive hazard statement alerts the user to store the product in a corrosion-resistant container. When pesticides are flammable, smoking while handling the product is extremely hazardous. For all uses of any pesticide, smoking and eating should be avoided during handling of the product. The physical or chemical hazard statements are not required to be placed in a special location on the label. Places to look for this information are under such headings as "Physical or Chemical Hazards," "Note," "Important," or under the signal word. If there are no unusual physical or chemical hazards, there may be no statement in the labeling.
Directions for use section contains one statement that is common to all pesticide labels:
"It is a violation of Federal law to use this product in a manner inconsistent with its labeling."
This section will also contain the specific directions for using the product, and information on storage, disposal and entry into a treated area after pesticide application. The label must be readily available to the applicator when using the product. Certain usages or localities may require the possession of MSDS (material safety data sheet) information for the product.
It is illegal to use a pesticide not permitted by the labeling. A pesticide may be used for pest control only to protect the plants, animals, or sites named in the directions for use. Higher dosages, higher concentrations, or more frequent applications than stated on the label may not be used. All directions for use, including directions concerning safety, mixing, diluting, storage, disposal, and specified personal protective equipment, must be followed. These are not advisory statements; they are legal requirements for product use.
Federal law does allow pesticide use in some ways not specifically mentioned in the label. Though not specifically mentioned on the label, certain practices may be followed unless they violate state or tribal laws. A pesticide may be applied at any dosage, concentration, or frequency less than that listed on the label. A pesticide may be applied against any target pest not listed on the label if the application is to a plant, animal, or site that is listed. It should be known whether the product is effective on a pest not listed on the label. Spectrum of activity of products is particularly important for some newer products that are highly effective at low rates of application for specific pests but have reduced to no activity on other organisms, including other pests. Any appropriate equipment or method of application may be used if it is not prohibited by the label. Mixing pesticides or a pesticide with a fertilizer is allowed if the labeling does not prohibit the mixture. If two or more pesticides are mixed, the dosages of all the products must be at or below the recommended rate. It should be noted that using any non-labeled procedures may reduce or eliminate any stated or implied warranty of performance provided by the manufacturer of the product.
Reentry statements contain precautions about entering a treated area after application. This statement indicates how much time must pass before people can enter a treated area except under special circumstances. These reentry intervals are set by the EPA and some states. State-issued reentry intervals are not always listed on the label, but may be legally binding based on state regulation. The reentry statement may be printed anywhere on the label and may be listed under various headings such as "Entry," "Worker Protections," " Important," "Note," "General Information," and "Agricultural Use Restrictions."
All pesticide labels contain instructions for storing and disposing of the pesticide. This information may relate to safety, such as the statement "Keep out of reach of children and pets" or may relate to product viability, such as "Do not store in temperatures below 32°F." Disposing of excess pesticide and the pesticide container in a specific manner may be required by the label or local regulation. Minimally, the container should be triple-rinsed and made unusable (punctured) unless it is to be returned to the manufacturer for reuse. If other containers have been used for mixing, they must be appropriately marked as to contents, label information must be attached, and the container must be disposed of in the same manner as the original container. Food containers should never be used as supplemental mixing containers in order to avoid accidental poisoning, particularly of children who may not read the label but recognize the container as a food container. The user must also be aware of additional state or local laws that may not be listed on the label. This information typically appears under the heading titled "Storage and Disposal."
Related to efficacy of the product toward pests, the label will commonly provide a list of the pests that the manufacturer claims the product will control; the plant, animal, or site the product is intended to protect; the manner in which the product should be applied, including use of the correct equipment, how much pesticide to use, mixing directions, where the material should be applied, and when and how often it should be applied. Also included may be information on whether the product can be mixed with other products and whether the product is likely to cause unwanted injuries or stains to the commodity that it is designed to protect.
Some special directions for use that pesticide users must obey are contained in documents that may be referred to on the label but not actually placed on the label. The decision by the EPA not to require all of the applicable directions for use to be distributed with each pesticide product places greater responsibility on the pesticide user. It is preferable that the label warn the user of the existence of special rules and regulations, but this may not occur in all cases. A warning related to endangered species protection is one example of such special directions. For example, the following statement on the label warns the user that endangered species may be harmed by this product, but it is the user's responsibility to determine if the warning is applicable to the area and what special directions are applicable:
"Use of this product in a manner inconsistent with the PESTICIDE USE BULLETIN FOR PROTECTION OF ENDANGERED SPECIES is a violation of Federal laws. Restrictions for the protection of endangered species apply to this product. 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."
If the warning is applicable, you must comply with all the specific directions in the bulletin. These directions do not always accompany the pesticide product when it is sold. Additional directions and requirements may be obtained from various local sources, such as pesticide dealers or company representatives, industry or commodity organizations, county pest control offices, and land-grant universities' county offices. Because of the heightened responsibilities of the user, any uncertainties about proper and legal use should be clarified by contacting the federal or state regulatory agencies: the EPA and State Departments of Agriculture.
