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⚡ CHEAT SHEET

Ch.3: Pesticide Labeling

Pesticide labels are the legal communication between manufacturer and applicator: 4 registration types, 4 signal words, label components, mandatory vs advisory language, REIs, and Safety Data Sheets.

🎯 Top 5 Traps

LABEL and LABELING are NOT the same thing — and applicators are legally bound to ALL of the labeling. The LABEL is what is printed on or attached to the pesticide container. LABELING includes the label PLUS all other information about the product referenced on the label and provided when you buy it: comprehensive product-use manuals, brochures, leaflets, Safety Data Sheets, and any web-distributed labeling. ALL of it is binding. If a label refers you to a website, that web information is part of the labeling — you must seek and follow it.

Signal words rank ACUTE TOXICITY (highest to lowest): DANGER-POISON (skull and crossbones; "POISON" must appear in RED; PELIGRO in Spanish) → DANGER → WARNING (AVISO in Spanish) → CAUTION. DANGER-POISON: highly toxic by ANY route; can cause death in very low doses. DANGER (without POISON/skull): highly toxic by at least one route OR causes severe eye damage/skin irritation. WARNING: moderately toxic. CAUTION: slightly toxic — may be omitted on very low toxicity products but many manufacturers still include it. Section 25(b) minimum-risk products need NO signal word at all.

MANDATORY vs ADVISORY statements — only MANDATORY are legally enforceable. MANDATORY: imperative/directive sentences ("Do not...", "Wear...", "If swallowed, call a doctor"). Failure to follow = legal violation subject to civil/criminal penalty. ADVISORY: descriptive language using "should," "may," "recommend" — not enforceable, conveys best management practices. EPA increasingly directs manufacturers to clearly separate them. If a section heading includes "recommended," everything in that section must be purely advisory.

Section 25(b) MINIMUM-RISK pesticides are EXEMPT from registration and have NO LABEL REQUIREMENT for: EPA registration number, EPA establishment number, signal word, or PPE. Each active ingredient must be on EPA's minimum-risk list, and inert ingredients must be on the minimal-risk inert list. The product CANNOT claim to control any microorganism that poses a threat to human health (the label may list mosquito as a pest, but cannot claim to control any microorganism it transmits). Many states do NOT permit Section 25(b) sale unless the product is first registered in the state.

RESTRICTED-ENTRY INTERVAL (REI) lives under "Agricultural Use Requirements" (only on WPS-covered products). If 2+ pesticides are MIXED, follow the MOST RESTRICTIVE (LONGEST) REI. If NO REI is listed, wait at least until SPRAYS HAVE DRIED or DUSTS HAVE SETTLED before reentry. Multiple REIs on a single label: look in "Directions for Use" for each crop. The "Nonagricultural Use Requirements" section applies to non-WPS uses (lawns, golf courses, ornamental plantings, structures except greenhouses, aquatic areas, rights-of-way) — specific reentry times are typically NOT listed.

🔢 Numbers You Must Know

Number

What It Represents

4 signal word categories

DANGER-POISON (skull and crossbones, POISON in RED, PELIGRO Spanish); DANGER; WARNING (AVISO Spanish); CAUTION. Section 25(b) products carry no signal word.

4 registration types

Section 3 (federal); Section 24(c) (Special Local Need / SLN — must have SLN labeling in possession; legal only in specified state/region); Section 18 (Emergency Exemption — must have approval copy on hand); Section 25(b) (Minimum-Risk — exempt from registration)

16 SDS sections

Identification, Hazard ID, Composition, First Aid, Firefighting, Accidental Release, Handling/Storage, Exposure/PPE, Physical/Chemical Properties, Stability/Reactivity, Toxicological, Ecological, Disposal, Transport, Regulatory (Section 15 — what's on the label), Other

2 sets of EPA reg numbers

Most EPA registration numbers have 2 sets (manufacturer + product). Occasionally a 3rd set appears for distributor products. Required on all labels EXCEPT Section 25(b).

SLN registration number format

EPA SLN No. PA-990005 → "SLN" = special local need; "PA" = state of registration; "99" = year of registration; "0005" = sequential number that year. Legal ONLY in specified state.

Establishment number format

EPA Est. No. 5840-AZ-1 → identifies facility producing the product. State code (AZ) shows where it was manufactured. Required for traceability if adulteration arises.

6+ years / millions of dollars

Time and cost to develop a single pesticide label — thousands of compounds screened for every successful product

2012

SDS naming + formatting radically changed to adhere to international treaties (formerly MSDS = Material Safety Data Sheet)

Before BUYING; before MIXING/APPLYING; when STORING; before DISPOSING of unused pesticides + empty containers

Most restrictive REI rule

If 2+ pesticides are mixed, the LONGEST REI of all products applies. If no REI listed at all, wait until sprays DRIED or dusts SETTLED.

🔀 Easily Confused

Pair / Group

Distinguishing Feature

Label vs Labeling

Label: information PRINTED ON or ATTACHED TO the pesticide container. Labeling: the label PLUS all other information referenced on the label and given when you buy the product (product-use manuals, brochures, leaflets, SDSs, websites referenced on the label, web-distributed labeling). All of labeling is binding — failure to follow any of it can result in legal action.

Trade/Brand vs Common vs Chemical name

Trade/Brand name: manufacturer's registered trademark — appears on front panel, used in advertisements (e.g., "Tempo 20WP"). Common name: shorter, simplified name officially accepted by EPA (e.g., "cyfluthrin"). Chemical name: complex name identifying chemical components and structure (e.g., "ß-Cyfluthrin, cyano(4-fluoro-3-phenoxyphenyl)methyl 3-(2,2-dichloroethenyl)-2,2-dimethylcyclopropanecarboxylate"). All must appear in ingredient statement; buying by common/chemical name guarantees the right active ingredient.

Active vs Inert ingredients

Active ingredient (a.i.): chemical(s) responsible for the product's pesticidal activity — must be listed by official chemical and/or common name with percentage. Inert ingredients: usually NOT named, but the label must show what percentage of total contents they make up. For example, Tempo 20WP = 20% active + 80% inert.

Section 3 vs 24(c) vs 18 vs 25(b)

Section 3: standard federal registration — most common. Section 24(c) SLN: state-level registration to expand or limit uses; legal ONLY in specified state; SLN labeling MUST be in your possession to use. Section 18 Emergency Exemption: temporary use of registered product for non-registered purpose during a crisis; must have approval copy on hand. Section 25(b) Minimum-Risk: exempt from registration; no EPA reg/establishment number, no signal word, no PPE required; cannot claim to control human-health-threatening microorganisms.

DANGER-POISON vs DANGER (alone)

DANGER-POISON (with skull and crossbones; POISON in RED; PELIGRO Spanish): highly toxic by ANY route of entry; can cause death at very low doses. DANGER (without POISON/skull): highly toxic by AT LEAST ONE route OR causes severe eye damage/skin irritation. The skull-and-crossbones symbol distinguishes the two.

WARNING vs CAUTION

WARNING (AVISO Spanish): MODERATELY toxic orally, dermally, or through inhalation, OR causes moderate eye/skin irritation. CAUTION: SLIGHTLY toxic in any route OR causes slight eye/skin irritation. Very low toxicity products may have NO signal word, but many manufacturers still include CAUTION.

Mandatory vs Advisory statements

Mandatory: imperative/directive ("Do not...", "Wear...", "If swallowed, call a doctor", "Apply immediately after mixing"). Legally binding — failure subject to civil/criminal penalty. Advisory: descriptive ("should," "may," "recommend" — e.g., "Latex gloves provide the best protection"). Not enforceable. Manufacturers must clearly separate them; if a heading includes "recommended," everything in that section must be advisory.

Routes of Entry vs Specific Action statements

Routes of Entry: indicates which route(s) of entry are particularly hazardous ("Extremely hazardous by skin contact — rapidly absorbed through the skin"). Specific Action: precautions and PPE to reduce exposure ("Do not breathe vapors or spray mist," "Avoid contact with skin or clothing"). Specific action statements typically follow routes of entry statements.

Special Toxicity vs General Environmental statements

Special Toxicity: pesticide is especially hazardous to specific wildlife ("This product is highly toxic to bees", "extremely toxic to fish and aquatic invertebrates"). General Environmental: commonsense procedures to avoid environmental contamination ("Do not apply when runoff is likely to occur", "Do not apply when bees are likely to be in area"). Absence of general statements does NOT relieve the applicator of taking adequate precautions.

Agricultural Use vs Nonagricultural Use Requirements

Agricultural Use Requirements: only on WPS-covered products (farms, forests, nurseries, greenhouses); links to 40 CFR Part 170; includes REI. Nonagricultural Use Requirements: lawns, golf courses, ornamental plantings, structures (except greenhouses), aquatic areas, rights-of-way. Specific reentry times typically NOT listed — wait until spray dried/dust settled.

EPA Reg # vs SLN # vs Establishment #

EPA Reg No. 3120-280-1492: 3120 = manufacturer; 280 = product; 1492 = distributor (when present). EPA SLN No. PA-990005: SLN = special local need; PA = state; 99 = year; 0005 = sequential number. EPA Est. No. 5840-AZ-1: identifies the FACILITY producing the product (for traceability if adulteration arises).

SDS vs Label

SDS (Safety Data Sheet, formerly MSDS): OSHA-regulated; designed for multiple professionals (manufacturers, transporters, medical personnel, firefighters); 16 sections; more chemical/physical/toxicological/ecological detail than the label; may have a different signal word than the label and includes pictograms not on label. Label: FIFRA-regulated; designed specifically for the END USER (applicator). NEVER use SDS in place of the label — use them together.

Multiple REIs / No REI

Multiple REIs on one label: look in "Directions for Use" for each crop. 2+ pesticides mixed: follow the MOST RESTRICTIVE (LONGEST) REI. No REI listed at all: wait until sprays HAVE DRIED or dusts HAVE SETTLED before reentering treated area.

📋 Pesticide Registration Types Quick Reference

Type

What It Is

Key Requirements / Specifics

Section 3
Federal registration

Standard federal pesticide registration. Most common type. Manufacturer submits application package to EPA; review may take several years.

EPA registration number required on label. Look for it to confirm the product is approved. Once registered, may not be used in any way inconsistent with approved labeling.

Section 24(c)
Special Local Need (SLN)

State-issued registration to expand or limit uses of certain registered pesticides within state jurisdictions (e.g., add a crop/site not on label, or limit certain uses to address local concerns).

Manufacturer must provide supplemental SLN labeling. APPLICATOR MUST HAVE SLN LABELING IN POSSESSION to legally use the pesticide for that purpose. Legal ONLY in the specified state/region. Format: EPA SLN No. PA-990005 (state, year, sequential number).

Section 18
Emergency Exemption

Allows sale and use of a registered pesticide for a SPECIFIC NON-REGISTERED PURPOSE during a SPECIFIED PERIOD. Requested by state/tribal/territorial regulatory agency for a public health concern or other pest crisis.

Must be no other feasible pesticide alternative. Strict controls + recordkeeping. State/tribal/territorial agency prescribes application rates, safety precautions, other vital information. APPLICATOR MUST HAVE COPY OF SECTION 18 APPROVAL ON HAND to legally use.

Section 25(b)
Minimum-Risk Exemption

Exempt from registration provided the products satisfy certain conditions: pose minimal risk to humans and environment; do not require EPA label approval; do not undergo EPA review.

Each active ingredient must be on EPA's minimum-risk active ingredient list; inerts must be on minimal-risk inert list. NO LABEL REQUIREMENT for EPA registration number, EPA establishment number, signal word, or PPE. Cannot claim to control microorganisms posing threat to human health. Many states require state registration before sale.

🏷️ Label Sections Quick Reference

Section

Purpose

Key Contents

Trade / Brand / Product Name

Manufacturer's registered trademark — front panel

Often indicates formulation type and percentage of active ingredient (e.g., "Tempo 20WP" = 20% wettable powder)

Ingredient Statement

Active and inert ingredients with percentages

Active ingredients listed by official chemical name and/or common name. Inert ingredients show only percentage of total contents (not named).

Use Classification Statement

Restricted-use vs general-use designation

RUP designation (with required statement) appears at TOP of FRONT PANEL. Same active ingredient may be RUP in one formulation and general-use in another.

Net Contents

Quantity in container

Pounds/ounces (dry); gallons/quarts/pints (liquid). Liquid formulations may show pounds active per gallon. Many include metric units.

EPA Reg + Establishment Numbers

Identification of product and producing facility

Reg No. has 2 sets (manufacturer-product) or 3 sets (with distributor). Establishment No. shows facility for traceability. NEITHER required for Section 25(b).

Signal Words + Symbols

Indicate relative ACUTE TOXICITY to humans/animals

Front panel, large letters, with "Keep Out of Reach of Children." DANGER-POISON (skull + crossbones; POISON in red; PELIGRO Spanish), DANGER, WARNING (AVISO Spanish), CAUTION.

Precautionary Statements

What precautions to take to protect people, animals from exposure

Sometimes under "Hazards to Humans and Domestic Animals." Includes Routes of Entry, Specific Action, PPE statements, and other commonsense precautions ("Do not contaminate food or feed", "Wash thoroughly after handling").

First Aid Statements

Emergency treatments for poisoning/exposure (formerly "Statement of Practical Treatment")

Skin contact, eye exposure, inhalation, swallowing instructions. All DANGER labels (and some WARNING/CAUTION) include note to physicians describing antidotes/medical procedures.

Environmental Hazards

Special toxicity statements + general environmental statements

Special Toxicity ("highly toxic to bees", "extremely toxic to fish"); General Environmental ("Do not apply when runoff likely", "Do not apply when bees likely in area"). Groundwater warnings for chemicals with leaching potential.

Physical / Chemical Hazards

Fire, explosion, or chemical hazards

"Flammable — Do not use, pour, spill, or store near heat or open flame"; "Corrosive — Store only in a corrosion-resistant tank"

Agricultural Use Requirements

WPS-covered products only (farms, forests, nurseries, greenhouses)

Links to 40 CFR Part 170. Includes RESTRICTED-ENTRY INTERVAL (REI), early-entry PPE, training/decontamination/notification requirements.

Nonagricultural Use Requirements

Non-WPS uses (lawns, golf courses, ornamental plantings, structures except greenhouses, aquatic areas, rights-of-way)

Specific reentry times typically NOT listed. Default: wait until spray dried or dust settled.

Storage and Disposal

How to store the product, handle rinsate, dispose of containers

State and local laws may vary. May appear under "Important," "Note," or "General Instructions." Examples: store away from fertilizers/seeds; nonrefillable containers; triple rinse; offer for recycling or puncture and dispose.

Directions for Use

How to use the product

Pests controlled; crop/animal/site protected; mixing instructions; rate + frequency; preharvest interval; phytotoxicity warnings; where/when to apply; plant-back/composting/grazing restrictions; how to minimize drift.

💡 Memory Hooks

Label vs Labeling: "Label = container; Labeling = label + everything else." All of labeling is legally binding.

Signal word ladder: "DANGER-POISON, DANGER, WARNING, CAUTION." Acute toxicity from highest to lowest.

POISON in red: "POISON in red; PELIGRO in Spanish." Required formatting on the most toxic products.

Mandatory vs advisory: "Mandatory uses 'Do not'; advisory uses 'should/may/recommend'." Different legal weight.

25(b) exemptions: "No registration, no signal word, no PPE." Minimum-risk products skip the label requirements.

Multiple REIs: "Most restrictive (longest) wins when mixed." Tank mix safety rule.

No REI listed: "Wait until dry or settled." Default reentry rule.

SLN possession: "SLN labeling must be in your possession." Section 24(c) requirement.

Section 18 paperwork: "Approval copy on hand." Emergency exemption documentation requirement.

SDS vs label: "SDS for chemists and firefighters; label for the applicator." Use SDS WITH the label, not in place of it.

16 SDS sections: "Section 15 = the regulatory section showing what's on the label." Connects SDS back to the label.

Read the label 4 times: "Buy, mix, store, dispose." Four moments to consult the label.

6 years and millions: "Six years and millions of dollars to develop a label." Why the label matters.

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