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Label Comprehension

Goals: To teach:» What IS on the label (and where)

Content Format

» What IS NOT on the label

» How to use / follow the label!

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Label Comprehension

How to teach about the label using “active learning” methods for field and classroom:» sample PPT + discussion

w/ audience-appropriate interpretive questions…

» paper and pencil activities» interpretation / application activities

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Label Comprehension

This PPT is NOT “ready to use”! To convert this “plain vanilla” PPT to an

audience-appropriate one, consider:» What do these people do?» What pesticide products do they use?

Do any of these products require special management?

Are any of them similar to other products with different use patterns/requirements?

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Label Comprehension

To convert this “plain vanilla” PPT to an audience-appropriate one (continued):» Write (at least one) appropriate/relevant

question after each section, on the slide w/ ??? in the title bar.

» “Jazz it up” with pictures…?! Use images of local sites and situations…or Check out:

http://pesticidepics.ext.vt.edu = pesticidepics.com

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Pesticide Labels & Pesticide Labels & LabelingLabeling

Pat HipkinsVirginia Tech Pesticide Programs

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Pesticide Labeling

Background:

» Several Types of Registration federal (Sec. 3) special local need (SLN or Sec. 24C) emergency exemption (Sec. 18)

» Classification of Pesticides general use restricted use

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Pesticide Labeling

EPA sets standards (content, format):

http://www.epa.gov/oppfead1/labeling/lrm/

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Required Information Name and address of the producer or registrant Restricted Use Statement (if applicable) Product Name, Brand or Trademark Ingredient Statement and net weight or measure of contents EPA Registration Number and EPA Establishment Number Signal Word, including Skull & Crossbones, if either are required "Keep Out Of Reach Of Children" statement Precautionary Statements, including Hazards to Humans & Domestic

Animals and First Aid (Statement of Practical Treatment), Environmental Hazards, and Physical/Chemical Hazards

Storage and Disposal Statements Directions for Use Warranty Statement

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Mandatory Statements

Relate to actions necessary to:» ensure proper use, and» prevent unreasonable adverse effects on the

environment, which is defined by statute.

They may include:» directions for use,» precautions that direct the user to take or avoid

specific actions,» specify where, when and how a pesticide may be

applied.

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Mandatory Statements

Examples of mandatory statements:

» “Wear chemical resistant gloves.”

» “Do not induce vomiting.”

» “Do not apply within 66 feet of wells.”

» “Do not apply directly to water.”

» “Keep away from heat, sparks and open flame.”

» “Do not enter into treated areas for 12 hours.”

» “Do not apply when wind speed exceeds 15 mph.”

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Advisory Statements

Provide information regarding:» product characteristics, and/or

» how to maximize safety and efficacy.

Must NOT conflict with mandatory statements.

May NOT be false or misleading, or otherwise violate statutory or regulatory provisions.

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Advisory Statements

Examples of advisory statements:

» In the Precautionary Statements section: “Latex gloves provide the best protection.”

» In the Physical and Chemical Hazards section: “Opening aluminum phosphide containers outdoors or indoors

near an exhaust fan or other ventilation ensures that the gas will be rapidly dispersed if the product flashes.”

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Advisory Statements

Examples of advisory statements (continued):

» In the Directions for Use / Mixing section: “Apply this product immediately after preparation to ensure

that it is in suspension. If application is delayed, agitation to re-mix and ensure proper blending.”

» In the Directions for Use / Application section: “Directing the spray mixture around the base of the cotton

plants and using leaf lifters and shields on application equipment will help minimize foliage contact and plant injury.”

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Summary: Parts of a Label Identifying information

» Product name, Ingredient statement, Net contents, EPA registration number and establishment number, Use classification (general/restricted; use pattern and site)…

Precautionary Statements» Signal word, child hazard warning, first aid, hazards to humans and

domestic animals, environmental hazards, physical or chemical hazards, PPE, engineering controls…

Directions for Use» Ag (WPS) vs. non-ag use requirements, where and how to apply,

how much and when to use, how to handle (mix, load, handle, store, and dispose of…)

Conditions of Sale/Limitations of Warranty and Liability(+ name and address of manufacturer, emergency contact info)

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Parts of a Label

Identifying Information

» Brand Name Ex: Garlon® 3A

» Chemical Name Ex: 3, 5, 6-trichloro-2-pyridinylozyacetic acid, triethyamine salt

» common name Ex: triclopyr

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Parts of a Label

Identifying Information (continued)

» Net Contents COMPOSITION

Active Ingredient (% by weight): triclopyr (3, 5, 6-trichloro-2-pyridinylozyacetic acid,

triethyamine salt)…………………………………….44.4% Inert Ingredients:…………………….…………….…55.6%

Acid equivalent: triclopyr - 31.8% - 3 lb/gallon

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???

What does the name Garlon® 3A tell you about the product?!

Which part of the Ingredient Statement is more useful…and why?» chemical name = 3, 5, 6-trichloro-2-

pyridinylozyacetic acid, triethyamine salt» common name = triclopyr

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???

What do the three glyphosate products:» Accord Concentrate» Glypro Plus» Rodeo

have in common?

How are they different?

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???

You’re an NRCS specialist advising a client who wants to control weeds in a forested riparian buffer.

Which glyphosate product would you recommend -- and why?» Accord Concentrate» Glypro Plus» Rodeo

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???You’re an Extension agent advising a client

who wants to control cattails and other emergent vegetation growing in shallow water along the edge of a pond.

Which glyphosate product would you recommend -- and why?» Accord Concentrate» Glypro Plus» Rodeo

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Parts of a Label

Identifying Information (continued)

» EPA Registration and establishment number

EPA Reg. No. (62719-37)

EPA Est. No. (not given on many labels posted on the internet…but required on actual product labels)

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???

Study the EPA registration numbers on the set of 5 labels provided. Do you see a pattern?!

What does the EPA registration number tell you?

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???

Why do you suppose that labels posted on the internet don’t have/show an EPA establishment number?

What does the EPA establishment number tell you?

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Parts of a Label

Identifying Information (continued)

» Restricted Use Designation (if applicable); Reason for RUP classification.

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???

True or False: Restricted-Use Products are highly toxic.

» Give a reason for your answer!

What is accomplished by classifying a product as RUP?!

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Parts of a Label

Precautionary Statements

» Child Hazard Warning Statement (KOOROC)

» SIGNAL WORD Danger-Poison (skull and crossbones symbol)

Danger Warning Caution

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??? Which product(s) do you think is/are more

toxic?» Accord Concentrate» Glypro Plus» Rodeo» Garlon 3A» Redeem R&P

Why?

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???

“Trick Questions”» What is the LD50 of glyphosate, clopyralid, and

triclopyr?» Why do applicators need to be concerned about

more than just the acute toxicity of the active ingredient in the product?

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???LD50 values:

» Glyphosate oral LD50 >5,000 mg/kg

» Clopyralid oral LD50 >5,000 mg/kg

» Triclopyr oral LD50 630 mg/kg

Why do you think Garlon 3A and Redeem R&P have a DANGER signal word?!

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Parts of a Label

Precautionary Statements (continued)

» Emergency Contact(s)

» PPE Requirements (see also Ag/NonAg Use Directions)

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???

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Parts of a Label

Precautionary Statements (continued)

» First Aid (Statement of Practical Treatment)

» Hazards to Humans and Domestic Animals acute effects statements (description of acute

effects, delayed effects, allergic effects...) ex: “Fatal if swallowed...”

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???

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Parts of a Label

Precautionary Statements (continued)

» Environmental Hazards

» Physical and Chemical Hazards

» User Safety Recommendations

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???

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Parts of a Label

Conditions of Sale and Limitations of Warranty and Liability

» Name and address of manufacturer

» Emergency Contacts

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???

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Parts of a Label

Directions for Use

» Standard language: misuse statement:

THE LABEL IS THE LAW!

“It is a violation of Federal Law to use this product in a manner inconsistent with its labeling.”

other statements, do’s, do not’s...

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Parts of a Label

Directions for Use (continued)

» Agricultural Use Requirements* and/or Nonagricultural Use Requirements** REI* ** PPE* ** Worker Notification* / Field Posting*

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???

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Parts of a Label

Directions for Use (continued)

» “Directions” for Use by Reference

WPS Agricultural Use Requirements Groundwater Protection ? Endangered Species ? Other special statements ?!

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???

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Parts of a Label

Directions for Use (continued)» Application Directions:

sites, rates, application intervals, application equipment and methods, mixing directions, pests controlled, days to harvest, +/-adjuvant use, tank mix directions, chemigation statement, aerial application statement…

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???

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Parts of a Label

Directions for Use (continued)

» other directions / conditions / use precautions

Mandatory Advisory

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Parts of a Label

Storage and Disposal

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The Label is the LAW!

The pesticide product label is a binding legal agreement between three parties:

» the US Environmental Protection Agency,» the product registrant, and» the product user.

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The Label is the LAW!

Pesticide product labels provide instructions for proper pesticide use.

Applicators must read, understand and follow label directions.

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The Label is the LAW!

Pesticides may not be applied to any plant, animal or site not listed on the product label.

Materials may not be applied at higher rates or more frequently than the label directs.

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The Label is the LAW!

Pesticide applicators are bound to follow label directions for transport, mixing, loading, application, storage and disposal of pesticides and pesticide containers.

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The Label is the LAW!

Federal law (FIFRA) does allow use of some pesticides in ways not specifically mentioned in the labeling. Unless state law prohibits, applicators may:

» apply a pesticide at a rate or frequency less than the label directs.

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The Label is the LAW!

Unless state law prohibits, applicators may:

» apply a pesticide to control a target pest not listed on the label.

(However, the site, plant or animal treated must be listed, and the application must be in accordance with all label directions.)

» use any appropriate equipment or method of application not specifically prohibited by the label.

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The Label is the LAW!

Unless state law prohibits, applicators may:

» mix pesticide with fertilizer, if the mixture is not prohibited by the pesticide product label.

» mix two or more pesticides, if all of the dosages are at or below the label rate for each separate component of the mixture, and if not prohibited by one of the product labels.

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The Label is the LAW!

PESTICIDE LABEL DIRECTIONS:

» are not advice or suggestions;

» are legal requirements.

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When to READ THE LABEL

before purchase;

before, during and after each use.

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Why READ THE LABEL

"Familiarity breeds contempt."

Label directions change!

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Label vs. MSDS

FIFRA (EPA) vs. HazCom (OSHA)

» Legal status» Intended use(s)» Information Provided

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Label vs. MSDS

FIFRA (EPA) vs. HazCom (OSHA)

» Legal status Label = FIFRA MSDS = OSHA

IF there are differences between the MSDS and the label…for example, in PPE requirements … applicators follow the LABEL!

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Label vs. MSDS

FIFRA (EPA) vs. HazCom (OSHA)

» Intended use(s) Label = applicator/end user MSDS = production through supply chain to

end user

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Label vs. MSDS

FIFRA (EPA) vs. HazCom (OSHA)

» Information Provided Label = Identifying Information (active ingredient

mfgr.), Precautions, Use Directions… MSDS = Information about all hazardous ingredients and

properties of the formulated product, including detailed information about health effects and toxicology, environmental hazards, etc. … handling, transport, and storage … accident procedures (first aid, firefighting, spills)

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Label Challenge

Work in groups w/ a set of labels… Evaluate…

» MOST toxic» LEAST toxic» Longest half-life» Highest ENVIRONMENTAL hazard» Highest PERSONAL hazard

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?

THANKS!