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Labels and Labeling. How to read supporting documents produced by the manufacturer. Labels and Labeling: Labels. The label is an EPA required document describing allowable use of a product To the manufacturer it is a license to sell
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Labels and Labeling How to read supporting documents produced by the manufacturer
Labels and Labeling: Labels • The label is an EPA required document describing allowable use of a product • To the manufacturer it is a license to sell • To governments (state & federal) it is a way to control distribution, sale, use, storage, transport, and disposal of the product • To the buyer it is the main source of information about how to use the product safely and legally • And, to tell the user about any safety measures needed for appropriate use
Name of product, Chemical and common name of the a.i. Ingredient statement including percent of content and type of formulation Name and address of manufacturer EPA registration and establishment numbers Signal words and symbols Pesticide precautionary statement WPS requirements and precautions Statement of practical treatment Directions for use Plus several other items Labels and Labeling: Labels – Required Data
Label Information on the Web • http://www.dupont.com/ag/us/dfo.htm • http://www.dowagro.com/main/ • http://www.helenachemical.com • http://www.basf.com • http://ag.fmc/index2.html • http://www.gowan.com • http://www.riverdalecc.com/
Collateral pesticide info on the web • http://ace.orst.edu/info/extoxnet/ghindex.htm • http://www.epa.gov/opprd001/factsheets • http://www.cdpr.ca.gov/docs/label/labelque.htm
Permissions in FIFRA(Federal Insecticide, Fungicide, and Rodenticide Act) • May use pesticide at a rate lower than listed on label • May use a pesticide on a target not listed on the label -- as long as the site is listed • May apply the pesticide by a method not listed on the label as long as the method is not prohibited on the label
FIFRA REQUIREMENTS • Site of application must be on the label for proposed use to be legal • This leads to some confusion • For most herbicides “site” is described as “Site-preparation”, “Conifer release”, etc. • For insecticides “site” often means the target pest such as “Gypsy moth” or “Bark beetles on conifers”
FIFRA REQUIREMENTS “It is a violation of federal law to use this product in a manner inconsistent with its labeling”
Look at the label at least four times • At the time you prescribe its use • When the shipment arrives onsite • At the tailgate safety session for crews • At the time of disposal Velpar L * Garlon 3A * Garlon 4 * Example chemical?:
Labels and Labeling: The Velpar L Label • We’ll use the Velpar L (hexazinone) label for most of this discussion • Note that herbicide labels are among the easiest to read • (Monsanto’s and the companies which have bought repackaging rights to former Monsanto products are the exception)
Table of Contents
Formulator WPS Precautions Product name Statement of Ingredients EPA Registr # General information Signal words & human health precautions
Not from the example label - this “DANGER - POISON” notice is required when appropriate (LD50 of 50 of or less) Return to Garlon 3A or Garlon 4 label *
Labels and Labeling: The Garlon 3A Label • We’ll use the Garlon 3A (triclopyr) label for most of this discussion • Note that herbicide labels are among the easiest to read • (Monsanto’s and the companies which have bought repackaging rights to former Monsanto products are the exception)
“DANGER – POISON” Example *
Labels and Labeling: The Garlon 4 Label • We’ll use the Garlon 4 (triclopyr) label for most of this discussion • Note that herbicide labels are among the easiest to read • (Monsanto’s and the companies which have bought repackaging rights to former Monsanto products are the exception)
“DANGER – POISON” Example *
Labels and Labeling: Supplemental labels • Additional sites of allowable use • Supplemental labels are easier to generate than a new label • But, information from supplemental labels will be incorporated in the next version of the label issued • If the use is maintained
Labels and Labeling: The MSDS (Material Safety Data Sheet) • Content (specific subjects) is now specified and required by the EPA • Categories of information are defined so the information should be easy to find • Some older MSDSs are still are available and are often hard to interpret
Labels and Labeling: Note about Aquatic Labels • Computation of water volumes often gives applicators trouble • Concept of acre foot (see aquatic label section) is confusing • So, most aquatic labels include a calibration table based on desired application rate and dimensions of the water body
Label revocation • Canceled • A specific use is no longer allowed by newer labeling – but products with that use listed on them may be used • Like a postage stamp – used as originally permitted • Suspended • Specified uses are no longer permitted regardless of package label • Think of a hanging – suspended uses are dead
Labels and Labeling: Labeling • Supporting information • Produced by the manufacturer • Gives technical, environmental, or application (rate or tool) information
Product info: American Cyanamid