Ch.2: The Pesticide Label

2. Two types of label statements

• Mandatory — enforceable; written as imperative/directive sentences ("Do not apply within 66 feet of wells"). Purpose: ensure proper use and prevent unreasonable environmental harm.
• Advisory — not legally enforceable; descriptive recommendations that help maximize safety and efficacy ("Neoprene gloves provide the best protection").
• Tell them apart by wording: imperative = mandatory; descriptive = advisory.

3. Label vs. labeling

• Label = information printed on or physically attached to the container.
• Labeling = the label plus other referenced material (applicator manuals, brochures, state-specific labeling, referenced websites like the WPS or EPA Bulletins Live!).
• Directions the label refers you to (even off the container) are legally binding, exactly like text on the label.

4. When to read the label — before you:

1. Buy (right site? best choice for the pest?)
2. Store
3. Mix and use (safe, effective, proper rate and time)
4. Clean application equipment
5. Dispose of leftover product/container

• Only exception to following a direction: it does not apply to your specific application (e.g., agricultural directions during a non-agricultural job).

5. Product names (first page)

• Labels list two or three names:
  • Trade / brand name — large letters at the top; for marketing/brand recognition.
  • Common name — shorter, easier name for an active ingredient (e.g., metalaxyl). Every product lists a common name for each a.i.; same a.i. = same common name across all companies.
  • Chemical name — precise name following chemists' guidelines; long and hard to pronounce; not all labels list it.
• Same a.i. ≠ same uses — different products with the same active ingredient are not necessarily labeled for the same uses. Always read the label.

6. Ingredients & contents

• Active ingredient (a.i.) — the chemical with the pesticidal activity (controls a pest).
• Other (inert) ingredients — manufacturers don't have to name them, but must state the total percentage by weight.
• Net contents — pounds/ounces (dry) or gallons/quarts/pints (liquid); liquids may also list lbs a.i. per gallon; metric may appear.

7. EPA registration number

• Documents that the EPA has reviewed and licensed the product for sale/use in the U.S.
• Unique to each formulation — same a.i. but different formulation → different registration numbers (registered for different uses).

8. Safety information

• Restricted Use Statement — if a product is a RUP, this appears prominently on the front, top of the label. Only certified applicators (or those under their direct supervision) may purchase, mix, load, or apply it.
• Signal word — indicates relative acute toxicity to humans (a comparison, not an exact measure). Must appear in large letters on the front panel with "Keep Out of Reach of Children."
  • Decreasing toxicity: DANGER-POISON (skull & crossbones) → DANGER → WARNING → CAUTION.
  • Every pesticide needs care regardless of signal word.
• Responding to exposure — first aid measures, exposures needing medical attention, and instructions for the physician. Always give the label to emergency medical personnel — it can save a life.
• Precautionary statements — note possible acute toxicity to humans and domestic animals (often near first aid info).
• PPE — labels list the minimum; it is illegal to wear less than required. Requirements can differ by activity (mixing may need more than applying).
• Environmental hazards — warn if a product is especially hazardous to wildlife (e.g., "highly toxic to bees," "may leach into groundwater").

9. Directions for Use

• Normally the longest section: registered sites, pests controlled, rates/methods, and restrictions.
• Directly under the heading, every label states: it is a violation of federal law to use the product in a manner inconsistent with its labeling.

10. Agricultural Use Requirements box

• On labels covered by the WPS; applies only to WPS uses (producing ag plants on a farm, forest, enclosed space, or nursery).
• Lists: application restrictions, a WPS-compliance statement, the restricted-entry interval (REI), PPE for early-entry workers, and posting/oral worker notification requirements.
• Dual-labeled product used in a non-ag setting → follow the Non-agricultural Use Requirements box instead.

11. Notification

• Notification = giving info about an application orally, on paper, or by posting a sign.
• May be directed to: other workers, the general public, and residents/users of the site.
• Ignoring a notification requirement is a violation of the label, like any other statement.
• Agricultural notification requirements live in the Agricultural Use Requirements box.

12. Safety Data Sheet (SDS)

• Regulated by OSHA (the label is regulated by the EPA).
• Designed for multiple professions (manufacturers, transporters, medical personnel, firefighters…).
• More detailed/technical; covers many activities besides application; PPE may differ from the label.
• Never use the SDS in place of the product label for mixing, loading, and applying.

Key Vocabulary