Chapter 3: Pesticide Labeling

Learning Objectives

• Distinguish between the various types of pesticide registrations.
• Explain when to read the pesticide label.
• State who may use a pesticide.
• Accurately identify the common, chemical, and brand/trade name of a pesticide.
• Determine the percentage of active ingredient(s) in a formulation.
• Interpret the meaning of label signal words and their relative hazard levels.
• Identify the types of statements on a label (precautionary, first aid, PPE, hazards, mixing/storage, REI).
• Interpret documents and online resources referenced on the label.
• Distinguish between advisory and mandatory statements.
• Discuss how to use information on a Safety Data Sheet.

Label vs. Labeling

By law, pesticide users must comply with all instructions in the labeling — not just what's printed on the bottle. This includes websites, supplemental labels, and manuals.

EPA Approval & Label Background

No pesticide may be sold in the U.S. until EPA has reviewed the registration application and determined the product does not present an unreasonable risk. EPA must approve all language on the labeling, and changes to an approved label must also be EPA-approved.

Getting a pesticide label costs millions and takes at least 6 years of research. Manufacturers must submit:

• Toxicological tests — effects on humans, wildlife, other organisms; acute and chronic (long-term) effects; skin (dermal) reactions. Usually done on rats and mice; some newer methods use mathematical models.
• Efficacy / performance tests — proof the product controls the pest, on the listed host/site, without injuring the crop, and with a measurable benefit.
• Degradation, mobility, and residue tests — how long the chemical lasts, whether it moves into groundwater or into plants from soil, and how much residue is left at harvest.
• Environmental impact data — effects on wildlife and the environment.

Preharvest / Preslaughter Intervals

Specific tolerances are NOT listed on labels, but preharvest intervals (PHIs) — days to harvest — and preslaughter intervals — days to slaughter — are. These set the minimum days between the last application and harvest/slaughter so the pesticide can break down. Violating the interval risks residues exceeding the EPA tolerance, which can cause the commodity to be condemned and destroyed.

Types of Pesticide Registration

Section 3 — Federal Registration

The most common. Look for an EPA registration number on the label (required on all products except minimum-risk). This confirms you have an approved, registered product.

Section 24(c) — Special Local Need (SLN)

Allows states to expand OR limit uses of certain registered pesticides within their jurisdiction. Example: an SLN can authorize use on a crop or site not on the federal label, or restrict a product due to local concerns.

• Manufacturers must provide supplemental labeling for each SLN registration.
• You must have the SLN labeling in your possession to use the product for that purpose.
• SLNs are only legal in the state/region specified — using an out-of-state SLN product for that purpose is illegal.
• SLN numbers include a state code and registration number (e.g., EPA SLN No. PA-990005).

Section 18 — Emergency Exemptions

Addresses pest problems where no pesticide is currently registered. Allows sale and use of a registered product for a specific NON-registered purpose for a specified time period.

• Issued at the request of the state, tribe, or territory regulatory agency.
• Only for public health concerns or pest crises with no other feasible alternative.
• Strict controls and recordkeeping required.
• The state agency prescribes rates, safety precautions, and other instructions.
• Applicators must have a copy of the Section 18 approval on hand to use the product legally.

Section 25(b) — Minimum-Risk Pesticides

Products exempt from registration because they pose minimal risk to humans and the environment. These products:

• Do NOT require EPA label approval.
• Do NOT get reviewed by EPA.
• Do NOT need an EPA registration number, EPA establishment number, signal word, or PPE label requirements.
• Must contain only active ingredients on EPA's list of minimum-risk active ingredients.
• All inert ingredients must also be on the minimum-risk inert list.
• Cannot claim to control microorganisms that pose a threat to human health — may list the pest (e.g., mosquito) but not pathogens it carries.
• Many states still require these products to be registered at the state level before sale.

When to Read the Label

You are responsible for reading and understanding all labeling BEFORE buying, using, storing, or disposing of a pesticide. Read:

• Before buying — Make sure the product is registered for your intended use. Check for restrictions that prohibit use at your site. Identify needed PPE and special equipment.
• Before mixing and applying — Determine precautions, first aid, medical treatments, weather suitability, and target life stage.
• When storing — Learn proper storage, fire hazards, and special precautions.
• Before disposing — Learn how to prevent environmental contamination. Check with your state agency for disposal rules and container recycling programs.

Parts of the Pesticide Label

Trade / Brand / Product Name

Every manufacturer has a trade name — usually trademarked. Different manufacturers may sell products with the same active ingredient under different brand names. The brand name often indicates both the formulation type AND the percentage of active ingredient.

Example: Tempo 20WP — "Tempo" is the registered trade name; "20" is 20% active ingredient; "WP" means wettable powder.

Ingredient Statement

Every label must list the active ingredients and the percentage of each.

Three Names for One Pesticide

• Chemical name — The complex scientific name identifying the chemical structure. Must be listed in the ingredient statement. Example for Tempo: ß-Cyfluthrin, cyano(4-fluoro-3-phenoxyphenyl)methyl 3-(2,2-dichloroethenyl)-2,2-dimethylcyclopropanecarboxylate.
• Common name — A shorter name for the active ingredient. Only those officially accepted by EPA may be used on the label. Example for Tempo: cyfluthrin.
• Trade / brand name — The manufacturer's marketed name, shown on the front panel. Example: Tempo 20WP.

Use Classification Statement

EPA classifies every pesticide as either restricted use or unclassified/general use. Every restricted-use pesticide must carry this statement at the TOP of the FRONT panel:

Type of Pesticide

A short front-panel statement indicating in general terms what the product controls (e.g., "Insecticide for control of certain insects on fruits, nuts, and ornamentals").

Net Contents

How much product is in the container. Pounds or ounces for dry formulations; gallons, quarts, or pints for liquids. Many labels also include metric units. Liquid formulations may list pounds of active ingredient per gallon.

Name and Address of Manufacturer

Required by law so you know who made or sold the product.

Emergency Telephone Number

Not required, but many manufacturers list one so you can get emergency assistance for poisoning, spills, or fires.

EPA Registration Number

Required on all labels except Section 25(b) minimum-risk products. Indicates the product and label are EPA-approved.

• Most have two number sets: manufacturer-product (e.g., EPA Reg. No. 3120-280).
• Distributor products add a third set: manufacturer-product-distributor (e.g., EPA Reg. No. 3120-280-1492).
• SLN format: EPA SLN No. PA-990005 means Pennsylvania, registered in 1999, 5th SLN that year.

EPA Establishment Number

Identifies the facility that produced the product — important if the product is ever found to be adulterated or contaminated. Example: EPA Est. No. 5840-AZ-1 (Arizona facility).

Signal Words & Symbols

The signal word indicates the relative acute toxicity of the product to humans and animals. Required on most labels in large letters on the front panel, along with "Keep Out of Reach of Children."

Precautionary Statements

Help you decide what precautions to take to protect people and animals. Often under the heading "Hazards to Humans and Domestic Animals."

Routes of Entry Statements

Indicate which routes of entry into the human body are hazardous. Study carefully — many pesticides are hazardous by more than one route. Typical language by signal word:

• DANGER: "Fatal if swallowed." "Poisonous if inhaled." "Extremely hazardous by skin contact — rapidly absorbed." "Corrosive — causes eye damage and severe skin burns."
• WARNING: "Harmful or fatal if swallowed/absorbed/inhaled." "Causes skin and eye irritation."
• CAUTION: "Harmful if swallowed." "May be harmful if inhaled." "May irritate eyes, nose, throat, and skin."

Specific Action Statements

Tell you what to do or avoid. Examples:

• DANGER: "Do not breathe vapors or spray mist." "Do not get on skin or clothing." "Do not get in eyes."
• CAUTION: "Avoid contact with skin or clothing." "Avoid breathing dust, vapors, or spray mists." "Avoid getting in eyes."

Protective Clothing & Equipment Statements

Vary by label. Some describe PPE fully; some don't. When absent, consider the signal word, routes of entry, and specific action statements. Follow basic guidelines from Chapters 5 and 6.

Other Precautionary Statements

Common-sense rules often listed:

• Do not contaminate food or feed.
• Remove and wash contaminated clothing before reuse.
• Wash thoroughly after handling and before eating or smoking.
• Wear clean clothes daily.
• Not for use or storage in and around a house.
• Do not allow children or domestic animals into the treated area.

First Aid Statements

Formerly called "Statement of Practical Treatment." List emergency treatments for poisoning or accidental exposure. Typical statements cover what to do "If in eyes," "If on skin," "If swallowed," and "If inhaled."

All DANGER labels — and some WARNING and CAUTION labels — include a note to physicians with appropriate medical procedures and antidotes. Always have the label available in an emergency.

Environmental Hazards

Special Toxicity Statements

Alert you to specific wildlife hazards:

• "This product is highly toxic to bees."
• "This product is extremely toxic to fish and aquatic invertebrates."
• "This product is toxic to birds and other wildlife."

General Environmental Statements

Common-sense reminders. Absence of a statement does NOT mean you don't need to take the precaution:

• "Do not apply when runoff is likely."
• "Do not apply when weather conditions favor drift."
• "Do not contaminate water by improperly disposing of rinse water and pesticide wastes."
• "Do not apply when bees are likely to be in the area."
• "Do not apply directly to water or areas where surface water is present."
• "Use in permeable soils with a shallow water table may result in groundwater contamination."

Physical or Chemical Hazards

Describes possible fire, explosion, or chemical hazards. Examples:

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

Agricultural Use Requirements & Restricted-Entry Intervals

The "Agricultural Use Requirements" section appears ONLY on labels of agricultural products covered by the EPA Worker Protection Standard (WPS, 40 CFR Part 170). This section links the product to WPS rules — the user must follow both the label AND WPS requirements.

WPS requirements include training, decontamination, notification, emergency assistance, PPE, and restricted-entry intervals (REIs).

Restricted-Entry Interval (REI)

Key REI rules:

• If no REI appears on the label, wait at least until sprays have dried or dusts have settled before reentry.
• If the label has multiple REIs for different crops, look in the "Directions for Use" section for each crop.
• If you mix two or more pesticides, you must follow the most restrictive (longest) REI.

Nonagricultural Use Requirements

Applies to uses outside WPS scope: lawns, golf courses, ornamental plantings, structures (except greenhouses), aquatic areas, rights-of-way. Specific reentry times are usually not given — but the label often cautions people and pets not to enter treated areas until sprays have dried or dusts have settled.

Storage and Disposal

All pesticide labels contain storage and disposal instructions for the pesticide, its rinsate, and its container. State and local laws vary, so labels may not include state-specific rules. Common statements:

• Store herbicides away from fertilizers, insecticides, fungicides, seeds, and feed.
• Store above 32°F (0°C).
• Nonrefillable container — do not reuse or refill.
• Do not contaminate water, food, or feed.
• Triple rinse container promptly after emptying.
• Offer for recycling or reconditioning, or puncture and dispose in a sanitary landfill.

Directions for Use

Instructions on how to use the product. Include:

• The pests the manufacturer claims the product will control.
• The crop, animal, or site the product is intended to protect.
• Proper mixing instructions.
• How much to use (rate) and how often.
• How close to harvest the product can be applied (PHI).
• Phytotoxicity (damage to plants) and other possible injury.
• Where and when the material should be applied.
• Plant-back, composting, grazing, and other restrictions.
• How to minimize drift.

Other Label Resources

Web References

A label may refer you to a website for additional instructions or precautions. All web-referenced information is binding. If the site has changed or is unavailable, contact the manufacturer for the material before making an application.

Digital Pesticide Specimen Labels

Available from EPA, state agencies, Cooperative Extension, registrants, and others. Useful for clarification — but you are still legally bound by the labeling found on and with YOUR pesticide container.

Electronic / Web-Distributed Labeling

An evolving area where the legally binding label refers the user to an "official" online site for up-to-date directions. Follow both the container instructions AND the EPA-approved website instructions.

Mandatory vs. Advisory Statements

A core testable distinction.

Advisory statements cannot conflict with mandatory statements, be false or misleading, or violate regulations. EPA directs manufacturers to clearly separate advisory and mandatory language. When older labels mix them confusingly, consult your state lead agency.

Safety Data Sheets (SDSs)

Key facts:

• Manufacturers are required to develop and provide an SDS upon request for each product.
• Commercial establishments must keep SDSs and make them available to workers and others who may contact the substance, diluted product, or residues.
• Unlike the FIFRA label (designed for end users/applicators), the SDS is designed for multiple professionals: manufacturers, transporters, medical personnel, firefighters.
• Use SDS IN CONJUNCTION with the label — NEVER in place of the label.
• In 2012, SDS naming and formatting were changed to comply with international treaties. SDSs may now have different signal words and include pictograms not on the label. Section 15 (regulatory information) specifies what is on the label.

The 16 SDS Sections

1. Identification
2. Hazard(s) identification
3. Composition / information on ingredients
4. First aid measures
5. Firefighting measures
6. Accidental release measures
7. Handling and storage
8. Exposure controls / personal protection
9. Physical and chemical properties
10. Stability and reactivity
11. Toxicological information
12. Ecological information
13. Disposal considerations
14. Transport information
15. Regulatory information
16. Other information

Key Terms & Acronyms Cheat Sheet

• Label — Information printed on and attached to the container.
• Labeling — The label PLUS all referenced documents (manuals, brochures, websites, SDSs).
• Active ingredient (a.i.) — The chemical responsible for the pesticidal activity.
• Inert ingredients — Everything else in the formulation; listed only as a percentage.
• Chemical name — Complex scientific name identifying the structure.
• Common name — Short name for the a.i.; must be EPA-approved.
• Trade / brand name — Manufacturer's marketed name.
• Formulation — Physical form (WP = wettable powder; EC = emulsifiable concentrate; G = granular, etc.).
• Signal word — Indicates relative acute toxicity: DANGER-POISON, DANGER, WARNING, CAUTION.
• PELIGRO — Spanish for DANGER. Required on DANGER labels.
• AVISO — Spanish for WARNING. Required on WARNING labels.
• Routes of entry — Oral, dermal, inhalation, ocular.
• Specific action statement — Tells the applicator what to do or avoid.
• First aid statement — Emergency treatment (formerly "Statement of Practical Treatment").
• REI — Restricted-entry interval. Time before unprotected workers can reenter.
• PHI — Preharvest interval. Minimum days between last application and harvest.
• Phytotoxicity — Damage to plants from the pesticide.
• WPS — Worker Protection Standard (40 CFR Part 170).
• Mandatory statement — Legally required; uses imperative language.
• Advisory statement — Recommended only; uses "should," "may," "recommend."
• EPA Registration Number — Identifies the registered product.
• EPA Establishment Number — Identifies the facility that produced the product.
• SLN — Special Local Need registration under FIFRA 24(c).
• Section 18 Emergency Exemption — Temporary allowance for unregistered uses.
• Section 25(b) — Minimum-risk pesticide exemption.
• SDS — Safety Data Sheet. OSHA-regulated; 16 sections; developed by manufacturer.