Pesticide Labeling

Maggie Scarbrough

Not only is it a requirement by law to read and follow the instructions on pesticide labels, it is also the main form of communication between pesticide manufacturers and pesticide handlers.

Label 101

Pesticide labeling is commonly known as the information that is attached to a pesticide container, but it also includes all information given with the product at the time of purchase (e.g., brochures, Safety Data Sheets (SDSs) or comprehensive product-use manuals). It takes at least six years and millions of dollars for pesticide manufacturers to test and research the information that goes on a pesticide label. Pesticide users are required by law to follow all instructions and use directions found on all pesticide product labeling. Doing so ensures that pesticide handlers are using the product safely and correctly.

Before a product may be sold in the United States, the Environmental Protection Agency (EPA) must review the product and its suggested labeling to determine that the use of the product does not present an unreasonable risk to humans, wildlife or the environment. Part of this process includes the pesticide manufacturer conducting several controlled tests that are conducted to determine the safety of a pesticide under a wide range of environmental conditions. Some of these tests include:

  1. Toxicity and Toxicological Test​ : This test determines how toxic or dangerous a pesticide is to humans, wildlife and plants. It also considers any long term effects it may have on an organism or possible skin reactions.
  2. Efficacy or Performance Test​ : This test is used to prove that the pesticide controls a particular pest (or group of pests) on one or more hosts, including plants, animals, soil and structures while not disturbing non-target pests, crops or animals. The data that comes from this test must show that the pesticide is a useful product when used appropriately.

3. ​Degradation, Mobility and Residue Test​ : The degradation test is a series of studies that shows how long it takes for the compound to break down into a harmless material. Mobility tests show if the pesticide moves through the soil into groundwater or into a plant from treated soil. Lastly, residue studies show how much of a pesticide residue, or its breakdown products, remain on or in a crop or animal at the time of harvest or slaughter. The results from the residue test, help guide the EPA when setting application intervals for a product.

4. ​Effects of Wildlife and the Environment​ : This test determines the effects of field applications of pesticides on wildlife and the environment. By law, manufacturers must provide any potential harmful effects found during this test to the EPA.

Pesticide Registration & Special Labeling

Pesticide handlers are responsible for applying only pesticides registered by the EPA and their state, territory, or tribe. While there are several types of pesticide registrations mandated by ​The

Federal Insecticide, Fungicide, and Rodenticide Act​ (FIFRA) that enable pesticides to be used in the United States, section 3 registrations are most common. When buying a pesticide, it is important to find the official EPA registration number on the label to make sure the product has been approved and registered.

Special local need (SLN) registrations​ are categorized as Section 24(c). This registration allows states to expand or limit the use of a specific registered pesticide in their area due to local concerns. For example, an SLN on a label may allow or limit the use of a pesticide for crops or sites that goes against label instructions. Manufacturers are required to supply supplemental labeling when a SLN registration is needed. To use a product according to its SLN, you must have the SLN labeling in your possession and you must only apply the product in the region, state or local area specified by in the SLN labeling.

The EPA has the power to issue an ​emergency exemption​ at the request of a state, tribe, territory or regulatory agency that assists in a public health concern or pest crisis. This emergency exemption under Section 18 addresses pest problems for which there are no pesticides currently registered for. This exemption allows the sale and use of a registered pesticide product for a specific non-registered purpose. The use of an emergency exemption requires strict recordkeeping and prescribing methods by the state that issued the exemption.

Products that pose minimum risk to humans and the environment and do not require review or approval by the EPA are considered ​minimum-risk pesticides.​ Provided they meet the criteria as a minimum-risk pesticide, these products have no registration number, establishment number, signal word or personal protective equipment (PPE) requirements by the EPA. However, the EPA still has certain label requirements for minimum-risk pesticides. It should be noted that many states do not permit the sale of minimum-risk products unless it is first registered in the state.

Reading the Label

Not only is it important to read and follow the label during every application of a pesticide product, it is the pesticide user’s responsibility to review the label before purchasing, mixing, storing and disposing pesticides. Doing so ensures you are purchasing the correct product for your needs, using the product safely, and disposing of the product in a way that prevents unnecessary hazards.

All labels are different, but have the same components. Let’s break it down.

Trade, Brand, or Product Name
Every product has a trade name (that is usually trademarked) given by its manufacturer that is clearly shown on the front panel of the label – this is the name commonly used in advertisements. The brand name, however, refers to the type of formulation and the percentage of active ingredient in the product. For example, let’s look at “Tempo 20WP”. Tempo is the trade name, but Tempo 20WP is the brand name because it shows the formulation is a wettable powder containing 20% active ingredient.

Ingredient Statement
All pesticide labels must list each active ingredient and the percentage of inert ingredients found in the product. The active ingredient (or a.i.) is the chemical (or chemicals) in a pesticide formulation that performs the pesticidal activity and controls the pest or performs the desired function. On a label, the active ingredient listed is the chemical name that identifies the chemical components and structure of the active ingredient. For example, the chemical name for Tempo can be found in the picture below under “active ingredient”.

Inert ingredients complete the ingredient statement. Unlike the active ingredient, inert ingredients are not required to be named. The only information needed is the total contents they make up. The example below shows how both ingredients may look on the TEMPO 20WP product label.

Use Classification Statement
The EPA classifies every pesticide product as a restricted-use pesticide, an unclassified-use pesticide, or a general-use pesticide. Pesticides are labeled as restricted use if there is reason to believe they could harm humans, livestock, wildlife or the environment even when used as directed by the label. Because of this, each restricted use pesticide contains the following statement on the top of the front panel of the pesticide label:

Unclassified-use pesticides (also referred to as general-use pesticides) normally have lower toxicity and have less potential to cause harm to humans and the environment. Anyone may purchase and use these products with no special permits or restrictions.

Type of Pesticide
The type of pesticide is a short statement that explains what the product controls and is generally listed on the front panel of a pesticide label. Some examples include: “Insecticide for control of certain insects on fruits, nuts and ornamentals.” and “ Herbicide for control of woody brush and broadleaf weeds”.

Net Contents
The net contents will tell you how much product is in the pesticide container. For dry formulations, the weight is in pounds or ounces. For liquid products, the weight is expressed as gallons, quarts and liquids as well as pounds of active ingredient per gallon of product. Some labels even include metric units as part of the contents information.

Manufacturer Information
The manufacturer or formulator is required by law to put its name and address on the label of a pesticide product it produces. Many manufacturers also list an emergency number on the label so that they may assist a product user during the event of an emergency.

Registration Numbers
An EPA registration number indicates that a pesticide product and its label has been registered and approved by the EPA. Generally, registration numbers contain two sets of numbers, one identifying the manufacturer and the other identifying the specific product. A third set of numbers indicates a distributor’s identification number.. The example below dissects an EPA number with three sets of numbers as well as an EPA number with a Special Local Needs Registration (SLN).

Establishment Numbers
Although they seem similar, establishment numbers are different from registration numbers, but must still appear on pesticide labels. The establishment number identifies the facility that produced the product and is used in the event of a problem or if the product is found to be contaminated. An example establishment number is “EPA Est. No. 5840-AZ-1”. The AZ, along with the numbers, indicates that the product was manufactured in a specific facility in Arizona.

Signal Words and Symbols
Pesticide labels include signal words that indicate toxicity levels to humans and animals. Signal words must appear in large letters on the front panel of the label along with the statement “Keep Out of Reach of Children.” Signal words commonly used on pesticide labels are:

1. DANGER – POISON : These words along with the skull and crossbones symbol are required on all products that are highly toxic by any route of entry into the body, even in small doses. The word “poison” must appear in red and the spanish word for danger “PELIGRO” must also be present.

  1. DANGER : The word danger by itself means that the product is highly toxic by at least one route of entry. Products with the word danger generally cause severe eye damage or skin irritation.
  2. WARNING : Warning signals that the product is moderately toxic orally, dermally or through inhalation. It may also indicate the risk of moderate eye and/or skin irritation. The spanish word for warning, “AVISO”, must also appear on the label.
  3. CAUTION : This word signals a product that is slightly toxic orally, dermally or through inhalation. It may also cause slight eye and/or skin irritation. Some products containing very low toxicity pesticides are not required to display a signal word at all, but most manufacturers still include a caution designation just to be safe.

Precautionary Statements
Precautionary statements are added to labels to help you decide what precautions to take to protect yourself, other people and/or animals from pesticide exposure. Normally, these statements are listed under the heading “Hazards to Humans and Domestic Animals”, and may be found in several different sections of the label.

  1. Routes of Entry Statements ​: These statements indicate which route (or routes) of entry into the human body are particularly hazardous. It is important to pay close attention to this statement, because many pesticides have more than one hazardous route of entry. Examples of routes of entry statements are: “DANGER – Fatal if swallowed.”, “WARNING – Harmful or fatal if absorbed through the skin.” or “CAUTION – May irritate eyes, nose, throat and skin.” It is not abnormal for a label to contain more than one precaution.
  2. Specific Action Statements​ : Specific action statements are directly related to the toxicity of the signal word and routes of entry. These statements give users precautions and PPE necessary to help reduce exposure to the pesticide. Specific Action Statement examples for DANGER labels could be “Do not breathe vapors or spray mist”. For WARNING and CAUTION labels, less alarming statements such as “Avoid contact with skin or clothing” are used.
  3. Protective Clothing and Equipment Statements​ : It is important to pay attention to this statement, because not all labels have them! While more hazardous pesticides fully describe the appropriate PPE, some expect the pesticide user to consider the signal word, routes of entry statements and specific actions statements when determining the proper PPE.
  4. Other Precautionary Statements​ : Although most precautionary statements are commonsense, most labels still include them. Examples include: “Do not contaminate food or feed” or “Wear clean clothes daily”. We suggest you do the last one whether or not you are applying pesticides!!!

First Aid Statements
In the case of a poisoning or an accidental exposure, first aid statements can be used as a guide on how to treat the issue. All DANGER labels and some WARNING and CAUTION labels even have a note to physicians describing the appropriate medical procedures and antidotes for poison emergencies. An example of this statement is: “In case of inhalation exposure, remove victim from contaminated area and give artificial respiration, if necessary.” Labels must always be readily available in case of emergencies.

Environmental Hazards
Environmental hazard statements explain the harm a pesticide could possibly cause and how to avoid potential for harm on the environment.

  1. Special Toxicity Statements​ : These statements indicate that a pesticide is especially hazardous to wildlife and help you choose the safest product for your particular job. An example is: “This product is highly toxic to bees”.
  2. General Environmental Statements​ : While these statements may seem to be common sense, they will help remind you to take extra precautions when applying the pesticide. An example is: “Do not contaminate water by improperly disposing of rinse water or other pesticide wastes”.

Physical or Chemical Hazards
This section of the label contains words like “Flammable” and/or “Corrosive” if there is a possibility that the product could cause a fire, explosion or chemical hazard. An example is: “​Corrosive​ – Store only in a corrosion-resistant tank.”

Agricultural Use Requirements
This section is only found on the label of an agricultural product covered by the EPA Worker Protection Standard (WPS). Through proper training, decontamination, emergency assistance and PPE, these requirements are set to protect agricultural workers on farms and in forests, nurseries and greenhouses. To abide by these requirements, the pesticide user must follow the pesticide label as well as the specific WPS requirements.

Most pesticide labels with an agricultural use requirement have a statement about restricted-entry intervals (REIs). This statement specifies how much time must pass before the treated area is safe to re-enter. If there is no statement on REIs, pesticide users should wait to re-enter a treated area until sprays have dried or dusts have settled.

Non Agricultural Use Requirements
This section is found on the label of pesticides that are not within the scope of protection of the WPS. This section cautions users not to let people or pets enter a treated area until spray has dried or dust has settled. This is generally found on labels of pesticides used to treat lawns, golf courses, aquatic areas and rights-of-way.

Storage and Disposal
No matter the classification, all pesticide labels include information of how to properly store and dispose of the pesticide, its rinsate and its container. Although all products contain this information, it is very general and does not always coincide with state and local laws. It is important to know the best disposal procedures for your location!

Directions for Use
Most of the instructions you need for a pesticide product can be found under “Directions for Use”. The directions for use on a label include but are not limited to:

  • ●  The pests, crop, animal or site that the manufacturer claims the product will control and/or protect
  • ●  Mixing instructions (including the rate and time intervals)
  • ●  How close to harvest the product may be applied
  • ●  Phytotoxicity (damage to plants) and other possible injuries
  • ●  How to minimize drift

Information Resources
Many technical terms are used on pesticide labels and in the information pertaining to them. If the directions on a label do not make sense to you, it is your responsibility to seek other resources in order to better understand them. Some labels even refer you to a website for additional instructions or precautions. The EPA, some regulatory agencies, registrants and consulting companies contain sample or specimen pesticide labels. While information found on a website may be useful and convenient, it is important to remember that you are still bound by the labeling found on and with your pesticide container

Mandatory Vs. Advisory Statements
Statements made on pesticide labels may be marked “mandatory” or “advisory”. Legally, the pesticide user must abide by mandatory statements. These precautionary statements specify where, when and how a pesticide should be applied and ensure proper use of a pesticide product. An example of a mandatory statement is: “Keep away from heat, sparks and open flame”. Advisory statements are recommendations that manufacturers provide that may result in better product performance or improved safety. An example of an advisory statement is: “Latex gloves provide the best protection”.

Safety Data Sheets (SDS)
Pesticide manufacturers are required to develop and provide an SDS that gives even more details about a pesticide product than the product’s label does. Businesses that use or supply pesticides to their employees are required to keep SDSs and make them available to all employees. The SDS is different than the label on a pesticide product, because the information given is designed for use by multiple professionals, not just the pesticide users. The SDS contains valuable information about the pesticide’s chemical and physical properties, toxicology, first aid procedures, emergency response and more to be use by medical personnel, firefighters, transporters, etc. The SDS is never to be used in place of a product’s label!

Summary

  • ●  Pesticide labeling is commonly known as the information that is attached to a pesticide container, but it also includes all information given with the product at the time of purchase (e.g., brochures, Safety Data Sheets (SDSs) or comprehensive product-use manuals).
  • ●  Before a product may be sold in the United States, the EPA must review the product and its suggested labeling to determine that the use of the product does not present an unreasonable risk to humans, wildlife or the environment. This is done by conducting a series of tests that include: Efficacy or performance tests, toxic and toxicology tests, effect of wildlife and the environment tests and degradation, mobility and residue tests.
  • ●  When buying a pesticide, it is important to find the official EPA registration number on the label to make sure the product has been approved and registered.
  • ●  A pesticides active ingredient must be listed on the label. However, inert ingredients are not required to be named. The only information needed is the total contents they make up.
  • ●  EPA registration numbers contain two or three sets of numbers, the first identifies the manufacturer, the second identifies the specific product, and the third set of numbers indicates a distributor’s identification number.
  • ●  Pesticide labels include signal words that indicate toxicity levels to humans and animals. Signal words must appear in large letters on the front panel of the label along with the statement “Keep Out of Reach of Children.” Signal words include: DANGER – POISON, DANGER, WARNING and CAUTION
  • ●  Products that pose minimum risk to humans and the environment and do not require review or approval by the EPA are considered minimum-risk pesticides.
  • ●  A special local needs registration allows states to expand or limit the use of a specific registered pesticide in their area due to local concerns.
  • ●  Every product has a trade name given by its manufacturer that is clearly shown on the front panel of the label – this is the name commonly used in advertisements. The brand name, however, refers to the type of formulation and the percentage of active ingredient in the product. Example: Tempo is the trade name and Tempo 20WP is the brand name.
  • ●  The SDS is different than the label on a pesticide product. The SDS contains valuable information about the pesticide’s chemical and physical properties, toxicology, first aid procedures, emergency response and more to be use by medical personnel, firefighters, transporters, etc.
  • ●  First aid statements can be used as a guide on how to treat an emergency. All DANGER labels and some WARNING and CAUTION labels even have a note to physicians describing the appropriate medical procedures and antidotes for poison emergencies. An example of this statement is: “In case of inhalation exposure, remove victim from contaminated area and give artificial respiration, if necessary.”