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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 • 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 • w/ audience-appropriate interpretive questions… • paper and pencil activities • interpretation / application activities
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 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 Pat Hipkins Virginia Tech Pesticide Programs
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 Labeling • EPA sets standards (content, format): http://www.epa.gov/oppfead1/labeling/lrm/
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 • 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 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 • 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 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 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 • 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 • 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 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
??? • 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
??? • What do the three glyphosate products: • Accord Concentrate • Glypro Plus • Rodeo have in common? • How are they different?
??? 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
??? 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 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)
??? • 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?
??? • 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 Label • Identifying Information (continued) • Restricted Use Designation (if applicable); • Reason for RUP classification.
??? • 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 Label • Precautionary Statements • Child Hazard Warning Statement (KOOROC) • SIGNAL WORD • Danger-Poison(skull and crossbones symbol) • Danger • Warning • Caution
??? • Which product(s) do you think is/are more toxic? • Accord Concentrate • Glypro Plus • Rodeo • Garlon 3A • Redeem R&P • Why?
??? • “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?
??? 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 Label • Precautionary Statements (continued) • Emergency Contact(s) • PPE Requirements • (see also Ag/NonAg Use Directions)
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 Label • Precautionary Statements (continued) • Environmental Hazards • Physical and Chemical Hazards • User Safety Recommendations
Parts of a Label • Conditions of Sale and Limitations of Warranty and Liability • Name and address of manufacturer • Emergency Contacts
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 Label • Directions for Use (continued) • Agricultural Use Requirements* and/or Nonagricultural Use Requirements** • REI* ** • PPE* ** • Worker Notification* / Field Posting*
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 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…