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Web-Distributed Labeling Update for CLA & RISE. William Jordan Office of Pesticide Programs April 11, 2014. Web-Distributed Labeling Overview. Voluntary system Complete labeling still on pesticide container

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web distributed labeling update for cla rise

Web-Distributed Labeling Update for CLA & RISE

William Jordan

Office of Pesticide Programs

April 11, 2014

web distributed labeling overview
Web-Distributed Labeling Overview
  • Voluntary system
  • Complete labeling still on pesticide container
    • Reference statement, unique identifier, and “released for shipment date” on the container or attached labeling
    • User has option to download “rendered labeling”
  • Streamlined use directions can now be available via website
  • Both container labeling and web-distributed labeling are legally valid
  • Overall goals
    • Make latest version of approved labeling available to user quickly
    • Improve users’ understanding of and compliance with pesticide labeling
web distributed labeling what it is not
Web-Distributed Labeling:What it is not
  • Does not remove any labeling from the container
  • Not electronic submission or review of labels by EPA
  • Does not require standardized labeling
  • Does not diminish legal procedures that EPA must follow to change labeling
  • Does not change process registrants use to change labeling
  • Does not change users’ duty to follow labeling requirements
    • Gives the option to follow either container labeling or web-distributed labeling
web distributed labeling history
Web-Distributed Labeling: History
  • States presented the topic to OPP’s Office Director, Debbie Edwards, at the 2007 AAPCO meeting
  • EPA formed an internal team to discuss web-distributed labeling later in 2007
    • Representation from OPP Divisions (AD, BPPD, FEAD, ITRMD, RD), OGC, OECA, OC, Regions, as well as 2 state regulators
  • EPA’s workgroup identified issues and areas for further consideration, drafted discussion papers, and conducted stakeholder outreach
  • Stakeholder engagement through individual meetings, PPDC subgroup, User Acceptance Pilot, Federal Register Notice, and draft Pesticide Registration Notice
pesticide registration notice
Pesticide Registration Notice
  • PR Notice 2014-1
    • Signed March 2014
    • Includes goals of WDL, terminology, suggested text for labeling, WDL content, website functionality
    • http://www.epa.gov/PR_Notices/
  • Sample labeling
    • Master labeling with WDL statements
    • Correctly and incorrectly “rendered labeling”
    • Available on EPA’s website - http://www.epa.gov/pesticides/regulating/labels/distribution/
registrants responsibilities
Registrants’ Responsibilities
  • Add text referencing WDL to master label
  • Provide 2 samples of rendered labeling (electronic or paper)
  • Submit master label + sample rendered labeling either as:
    • Non-PRIA fast track amendment (only WDL)
    • Part of a PRIA action (WDL & additional changes)
  • Maynotadd WDL to labeling as a notification
epa reviewers responsibilities
EPA Reviewers’ Responsibilities
  • Verify text referencing WDL is on master labeling
  • Check sample rendered labeling
    • Include WDL text
    • Include all applicable required sections (front panel, precautionary statements, directions for use, etc.)
  • OPTIONAL - Check URL if available
    • Verify website existence
    • Verify return of rendered labeling
end users responsibilities
End Users’ Responsibilities
  • Find “unique identifier” and “released for shipment date” on container
  • Go to website listed on container labeling
  • Enter unique identifier, state, intended use site
  • Verify that the date the rendered labeling date is later than the released for shipment date on container
  • Follow either container label or WDL– do NOT mix and match directions from both
web distributed labeling enforcement
Web-Distributed Labeling: Enforcement
  • Labeling is critical to ensuring that a pesticide’s use will not cause adverse effects
  • Web-distributed labeling must be enforceable in order to be implemented
  • Relies on current enforcement infrastructure, and specifies potential violations by registrants, users, and others
  • Significant interaction with states through AAPCO & SFIREG to confirm that enforcement would not be compromised
web distributed labeling contact information
Web-Distributed Labeling:Contact Information
  • Nicole Zinn

[email protected]

703-308-7076

  • William Jordan

[email protected]

703-305-1049

  • Michelle Arling (on leave until July)

[email protected]

703-308-5891

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