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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

    Zinn.nicole@epa.gov

    703-308-7076

  • William Jordan

    jordan.william@epa.gov

    703-305-1049

  • Michelle Arling (on leave until July)

    arling.michelle@epa.gov

    703-308-5891