Enable the Label - MN Pesticide Information and Education (PIE)

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Enable the Label - MN Pesticide Information and Education (PIE)
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

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