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E-Label: Registration, Label Identifiers & NPIRS Pilot Project. Steve L. Foss Washington State Dept. of Agriculture Victoria Cassens Purdue University. eLabel State Registration Issues. SLAs are receiving a greater number of labels in electronic PDF format. Label exchange methods with states
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Steve L. FossWashington State Dept. of Agriculture
SLAs are receiving a greater number of labels in electronic PDF format.
Label exchange methods with states
CD, email, or upload
Email / elabel issues
Version/date code or label identifiers
~ 20 states (~39%) accept Elabels on CD
AL, AZ, AR, CT, IL, LA, MD, MN, MO*, MT, ND, OH, PA, RI, SD, TN, UT, VT, WI, WY
~14 states (~27%) accept Elabels via email
AZ, GA, HI, LA, MN, MO*, MS, ND, NV, OK, SC, SD, UT, VT
* Require elabels be submitted in PDF format.
Source: RegWest Company LLC
Need to be able to print a legible eLabel (corrupted file?)
eLabel acceptable for viewing
Submit Pesticide Documentation On Line
WSDA started exchanging electronic copies of SLN labels in early 1997 to improve services.
Advantage:Quicker turnaround timecompared to handling and marking up paper copies and sending documents back/forth to registrants.
CLA’s Vision of the e-Label Process
Ray McAllister, CropLife America – NPIRS Elabeling Forum
number / date code
System Generated Document ID
Standard Label Version Identifier (VIN)
Mathematically Calculated Global Unique IDentifier (GUID)
WSDA Registration Specialists will look for company identifiers on labels and enter this code into our state pesticide registration database (if we can find it!)
~ 17% of the 11,200+ labels reviewed have no unique label identifier.
SFIREG has recommended to EPA’s Label Review Committee that a “standardized label version code needs to be developed that will identify a specific label by brand name and whether it’s the latest version.
Many label ID’s are non-standarddates or include a date
Codes appear in various areas on a label, but are usually found on the front or last page of product labeling.
Label Id = SCP 817A-L1M 1104
The identifier used by many registrants might not be ‘unique' for the purpose of document management and exchange with state agencies.
However, registrant generated codes (e.g. revision dates) on certain types of labels, such as SLN’s, may be adequate because the SLN number is unique to the state label unlike section 3 products, which may have multiple brand names using the same EPA Reg. Number.
Document ID = 503307
Same label registered in Hawaii has a different Document ID
Document ID = 9226.249
Strengths: Unique, Standard, Useable
Weakness: The same label is stored in NPIRS under two different Product ID Numbers:
A structured VIN or GUID (Global Unique Identifier) could be based upon EPA’s Specification for Text PDF Product Labels and used as the file name for the label in PDF format.
Product Trade NameEPA Reg. No. Version
Bicep II Magnum 100-817 01
Bicep II Magnum FC Herbicide 100-817 02
DuPont Cinch ATZ Herbicide 100-817-352 01
<000100 00817 000352><20021002> <dl> <01>
The GUID could be printed on labels to facilitate the linking of labels to state registration data.
EPA Reg. No.Verdate
VIN / GUID = 8033-23-82695 (051205-1529)
GUID (Globally Unique Identifier)
Pseudo-random 128-bit values that is statistically likely to be different from any other generated code using freely available software programs.
Unique across both, space and time.
Consists of five groups of hexadecimal digits.
8 digits 4 4 4 12 digits
(Select Document Properties / Description / Advanced)
GUID - UUID
CLA’s Vision for e-Label Process (Ray McAllister, NPIRS Elabel Forum)
Registrant prepares labels in standardized electronic format.
Structured Product Labeling (SPL) is a standard adopted by FDA
XML details: The identifying information is in the form:
The <id root> is a GUID for the specific document SPL instance and will differ for every regulatory submission.