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Label Confusion

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:.

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Label Confusion

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  1. Label Confusion

  2. Dean Herzfeld Pesticide Safety & Environmental Educationwww.extension.edu/pesticidesDriven To Discover

  3. It is more than just, “Read & follow the label.” Pesticide Labeling

  4. Label Provides Applicators: • How to minimize risk to themselves, non-target species & environment • Ways to maximize efficacy of product • Means to limit your liability • Essential for following and enforcing laws • Educational tool • Comprehensive use instructions

  5. 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

  6. If that perfect world existed….. …..then this would be Minnesota in January for at least a couple of days!

  7. But this is what it is

  8. 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

  9. Can we….. • Create labels that make sense to the user?

  10. Core Principles for label Quality: • Clarity • Accuracy • Clear Mandatory vs. Advisory statements • Consistent with EPA Policy

  11. “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

  12. “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

  13. “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

  14. Mandatory: ‘Shall’ ‘Must’ ‘Do this’ ‘Do not’ Advisory? ‘Should’ ‘May’ ‘Recommended’ ‘For best results’ Mandatory vs. Advisory

  15. “Label reviewers need to apply all relevant requirements & policies, and should not accept deviations..… .....the Label Review Manualprovide(s) links to underlying regulations and policy documents.” EPA, OPP Consistent with policy

  16. 2,4,d LabelWPS In Rights-of-Way? In Forestry?

  17. 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….

  18. Not an RUP – Who can apply it?

  19. Spray < 3 MPH with No Inversion?

  20. Ultimately labels need: • Clarity – Can it make sense to an average person? • Accuracy • Clear Mandatory vs. Advisory statements • Consistent with EPA Policy

  21. 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)

  22. 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

  23. Milestone VM Mandatory vs Advisory

  24. Core Principles for label Quality: • Clarity • Accuracy • Clear Mandatory vs. Advisory statements • Consistent with EPA Policy

  25. Dean Herzfeld Pesticide Safety & Environmental Educationwww.extension.edu/pesticidesDriven To Discover

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