PR NOTICE -- Improving Labels for Adult Mosquito Control Products Jim Roelofs Office of Pesticide Programs US EPA
Origin(s) of Projects • SFIREG Issue Paper - 1999 • WNV conference in Region 2 - 2001 • Ad hoc EPA-State group developed initial recommendations • PPDC (April 03) advised EPA to do PRN
Trained applicators, or Restricted Use Separate directions for mosquito control Qualify “terrestrial use” on mixed labels Allow application “over water” if needed to target mosquitoes Make hazard language specific as possible Consult with State lead agency Improve calibration instructions Recommendations at April ’03 PPDC
Current Draft Recommendations • Retains the original 7, but merged some of them • Adds 2 new ones concerning -- modified bee precaution language (#6); and specify timing and frequency (#7)
Rec. #1 – Trained personnel • Broad support for general concept • Different views on how to do it • Proposal language tries to accommodate various forms of existing training
Rec. #2 -- Separate mosquito labels • Mosquito-only labels easiest to deal with for users and regulators • Avoid confusion over “terrestrial use” statement
Rec. #3 Improve Hazard Statements • Make application over water allowable • Make aquatic species hazards more specific (if data support). • Raises NPDES issue
Rec. #4 Consult with State Lead Agency • We think SLA is most reliable source of info about possible state requirements. • Some commenters doubted value, thought it would be burden • We still think SLA is best, but make it advisory only.
Rec. #5 Appropriate Calibration Instructions • Labels are all over the board in this area. • We try to present a consistent approach; registrant identify droplet spectrum; user refers to equipment maker’s instructions to achieve it.
Rec. #6 – Modify bee precaution • “Hurricane Floyd” raised issue • Current language has no exceptions • Adds public health need as an exception – issue is who determines?
Rec. #7 -- Frequency and timing • “Repeat as needed” appears on most m. c. labels • Problems – (1) does not comply with label regulations (specify timing and frequency); (2) users, regulators and public may perceive “as needed” differently; (3) does not help EPA do risk assessment • However – public health protection may require unpredictable retreatments.
Next Steps • Send comments to docket – e-mail or hard copy -- (OPP2004-0018) • Closes July 27 • Questions? firstname.lastname@example.org