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

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label comprehension
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!
label comprehension2
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
label comprehension3
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?
label comprehension4
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
pesticide labels labeling

Pesticide Labels & Labeling

Pat Hipkins

Virginia Tech Pesticide Programs

pesticide labeling
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
pesticide labeling7
Pesticide Labeling
  • EPA sets standards (content, format):

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

required information
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
mandatory statements
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.
mandatory statements10
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.”
advisory statements
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.
advisory statements12
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.”
advisory statements13
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.”
summary parts of a label
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)

parts of a label
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
parts of a label16
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
slide17
???
  • 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
slide18
???
  • What do the three glyphosate products:
    • Accord Concentrate
    • Glypro Plus
    • Rodeo

have in common?

  • How are they different?
slide19
???

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
slide20
???

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
parts of a label21
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)
slide22
???
  • 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?
slide23
???
  • 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?
parts of a label24
Parts of a Label
  • Identifying Information (continued)
    • Restricted Use Designation (if applicable);
      • Reason for RUP classification.
slide28
???
  • True or False: Restricted-Use Products are highly toxic.
    • Give a reason for your answer!
  • What is accomplished by classifying a product as RUP?!
parts of a label29
Parts of a Label
  • Precautionary Statements
    • Child Hazard Warning Statement (KOOROC)
    • SIGNAL WORD
      • Danger-Poison(skull and crossbones symbol)
      • Danger
      • Warning
      • Caution
slide34
???
  • Which product(s) do you think is/are more toxic?
    • Accord Concentrate
    • Glypro Plus
    • Rodeo
    • Garlon 3A
    • Redeem R&P
  • Why?
slide35
???
  • “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?
slide36
???

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?!
parts of a label37
Parts of a Label
  • Precautionary Statements (continued)
    • Emergency Contact(s)
    • PPE Requirements
      • (see also Ag/NonAg Use Directions)
parts of a label39
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...”
parts of a label41
Parts of a Label
  • Precautionary Statements (continued)
    • Environmental Hazards
    • Physical and Chemical Hazards
    • User Safety Recommendations
parts of a label43
Parts of a Label
  • Conditions of Sale and Limitations of Warranty and Liability
    • Name and address of manufacturer
    • Emergency Contacts
parts of a label45
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...
parts of a label46
Parts of a Label
  • Directions for Use (continued)
    • Agricultural Use Requirements* and/or Nonagricultural Use Requirements**
      • REI* **
      • PPE* **
      • Worker Notification* / Field Posting*
parts of a label48
Parts of a Label
  • Directions for Use (continued)
    • “Directions” for Use by Reference
      • WPS Agricultural Use Requirements
      • Groundwater Protection ?
      • Endangered Species ?
      • Other special statements ?!
parts of a label50
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…
parts of a label52
Parts of a Label
  • Directions for Use (continued)
    • other directions / conditions / use precautions
      • Mandatory
      • Advisory
parts of a label54
Parts of a Label
  • Storage and Disposal
the label is the law
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.
the label is the law57
The Label is the LAW!
  • Pesticide product labels provide instructions for proper pesticide use.
  • Applicators must read, understand and follow label directions.
the label is the law58
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.
the label is the law59
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.
the label is the law60
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.
the label is the law61
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.
the label is the law62
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.
the label is the law63
The Label is the LAW!

PESTICIDE LABEL DIRECTIONS:

  • are not advice or suggestions;
  • are legal requirements.
when to read the label
When to READ THE LABEL
  • before purchase;
  • before, during and after each use.
why read the label
Why READ THE LABEL
  • "Familiarity breeds contempt."
  • Label directions change!
label vs msds
Label vs. MSDS
  • FIFRA (EPA) vs. HazCom (OSHA)
    • Legal status
    • Intended use(s)
    • Information Provided
label vs msds67
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!
label vs msds68
Label vs. MSDS
  • FIFRA (EPA) vs. HazCom (OSHA)
    • Intended use(s)
      • Label = applicator/end user
      • MSDS = production through supply chain to end user
label vs msds69
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)
label challenge
Label Challenge
  • Work in groups w/ a set of labels…
  • Evaluate…
    • MOST toxic
    • LEAST toxic
    • Longest half-life
    • Highest ENVIRONMENTAL hazard
    • Highest PERSONAL hazard
slide71
?

THANKS!