PESTICIDE REGISTRATION (PR) NOTICE 2007-X

NOTICE TO MANUFACTURERS, PRODUCERS, FORMULATORS, AND REGISTRANTS OF
PESTICIDE PRODUCTS

ATTENTION: Persons Responsible for Federal Registration and
Reregistration of Pesticide Products

SUBJECT: Environmental Hazard General Labeling Statements on Outdoor
Residential Use Products

This Notice presents the Agency’s guidance on optional environmental
hazard label language for certain non-restricted use pesticide products
intended for outdoor residential use. EPA undertakes initiatives such as
this in order to improve and clarify pesticide product labeling. The
specific label statements recommended in this Notice are intended to
improve existing labels by clarifying language on what the user should
do to avoid environmental contamination. The Agency believes that
voluntary adoption of these recommendations by pesticide registrants
will help pesticide users to better understand how to use consumer
products to minimize environmental hazards. Registrants who wish to use
these statements should follow the instructions in this notice. No
registrant is required to take any action in response to this notice. 

PRODUCTS POTENTIALLY AFFECTED BY THIS NOTICE

This Notice is applicable only to outdoor residential use products. The
specific product types affected by this Notice are liquid concentrates,
broadcast granulars, dusts, and liquid ready-to-use products registered
for outdoor residential uses. This Notice does not apply to agricultural
products, outdoor aerosol products or outdoor products registered only
for commercial use sites, such as golf courses. If you have questions on
whether or not this Notice applies to your product, please contact the
EPA Product Manager.

EPA prefers a label that is solely for residential use, but if there are
other use sites, the residential directions and precautions should be
clearly segregated on the label under a heading such as  “For
residential lawn use” or “For home and garden use” or a similar
designation as appropriate. These revised environmental hazard
statements may appear only in that section of the label. 

 

BACKGROUND

The consumer use of pesticide products differs significantly from the
use of pesticides in agricultural production. Many of the statements on
labels of residential use products, however, were originally developed
for agricultural users or commercial applicators. These statements may
be irrelevant or confusing to consumers. In an effort to make consumer
labels easier to read and to follow, EPA, along with industry, undertook
the Consumer Labeling Initiative (CLI) in March, 1996. The CLI was a
multi-phased pilot project focusing on various types of consumer
products, including indoor insecticides and outdoor pesticides. 

Of the labels that the CLI focused on, outdoor pesticide labels were
found to be the most confusing because they are more complex and less
frequently used. The CLI also found that consumers want clear, concise,
easy-to-read information that connects consequences with actions.  As a
result of the work of the CLI, the Agency issued several Pesticide
Registration Notices providing for certain label improvements, such as
recommending the use of common names rather than chemical names for
active ingredients, and providing for emergency telephone contact
information on labels.

In May 2004, the Pesticide Program Dialogue Committee (PPDC) recommended
the formation of a work group to explore further improvements to
consumer labeling, continuing activities undertaken in the CLI. The PPDC
is chartered under the Federal Advisory Committee Act to advise EPA on
pesticide issues. Its members represent a broad spectrum of interests,
including the pesticide industry, grower groups, public health agencies,
academic researchers, public interest and advocacy organizations. In
response, EPA established the Consumer Pesticide Label Improvement Work
Group under the auspices of the PPDC to provide advice and
recommendations regarding improvement of label language on pesticide
products intended for consumer use. The group was to focus on ways of
improving consumer understanding of labels in a manner that would be
easy to implement at minimal cost.

The group met from May 2005 to May 2006. The work group focused on basic
environmental hazard statements for consumer products, which are
primarily intended to prevent water contamination.   

The PPDC Consumer Pesticide Label Improvement Work Group presented their
recommendations to EPA after gaining support from the full PPDC in July
2006. The Agency assessed their recommendation, and agreed that the
principles set forth in their recommendations would improve
environmental hazard communication of outdoor residential labels. The
Agency utilizes their communication principles, but modified PPDC
suggested language based on considerations and judgments reached during
the Agency’s internal policy development process. 

III. DISCUSSION OF ISSUES AND RECOMMENDATIONS

Currently, the environmental hazard statements on consumer outdoor
products are similar or identical for all forms of the end-use product
whether it is a concentrate for broadcast application, a ready to use
granular for broadcast application, a liquid spray spot treatment
product or a garden dust.  However, product forms available to the
consumer can vary considerably and the potential environmental risks
associated with use of these products vary as well. Statements should be
specific to the product form and succinctly give instructions to avoid
environmental, particularly water, contamination. Accordingly, the
Agency is recommending slightly different environmental hazard
statements for each of the following categories:

Liquid Concentrate (e.g., liquids mixed with water by the user for a
tank sprayer or hose-end attachment);

Broadcast Granular (e.g., ready-to-use granular products which may be 
combined with fertilizers and broadcast applied with a drop or rotary
spreader);

Dusts (e.g., for garden or ornamental insect or fungus control
products);

Liquid Ready-to-Use (e.g., products for spot-treatment of weeds or
insects).

A. Statements to be Replaced

The Agency agrees with the PPDC recommendation that a set of simplified
environmental contamination statements be developed for each of these
outdoor residential use product categories. The revised environmental
hazard statements are intended to replace either of the following
statements, whichever one appears on the pesticide label, typically
found on products registered for an outdoor use.  The first statement is
found on many products intended for outdoor residential use.  The second
statement is found on virtually all products for outdoor agricultural
use as well as most turf and lawn-care products.

“Do not apply directly to water. Do not contaminate water when
disposing of equipment washwaters or rinsate.”

“For terrestrial uses:  Do not apply directly to water, or to areas
where surface water is present or to intertidal areas below the mean
high water mark.  Do not contaminate water when disposing of equipment
washwater or rinsate.”

B. New Statements

The Agency is recommending the following environmental hazard statements
be used on products registered for outdoor residential use in lieu of
those listed above. The revised statements will eliminate unfamiliar
agricultural terms and/or hard to interpret language. The statements are
specific to outdoor residential uses and should be easier for the user
to understand compared to the current standard language.

Products in each formulation category should have the corresponding
environmental hazard statement on the product label as follows: 

Liquid Concentrate	To prevent contamination of the environment, do not
apply near water, storm drains, gutters or ditches. Do not apply when
rain is predicted for that day or when wind is strong enough to carry
spray away from treatment area. Rinse applicator equipment over the lawn
or garden area that was treated, and away from water, storm drains,
gutters or ditches.



Broadcast Granular 	To prevent contamination of the environment, do not
apply near water, storm drains, gutters or ditches. Do not apply when
rain is predicted for that day. Apply this product only to your lawn or
garden, and sweep any product that lands on the driveway, sidewalk, or
street, back onto the treated area of your lawn or garden.





Dust	To prevent contamination of the environment, do not apply near
water, storm drains, gutters or ditches. Do not apply when rain is
predicted for that day or when wind is strong enough to carry dust away
from treatment area.

Liquid Ready-to-Use (RTU)  	To prevent contamination of the environment,
do not apply near water, storm drains, gutters or ditches. Do not apply
when rain is predicted for that day or when wind is strong enough to
carry spray away from treatment area.



These revised statements provide the basic use instructions for avoiding
water and other environmental contamination. Other required
environmental statements must be left on the label, such as wildlife
hazard statements as toxicology data dictate (e.g., specific
precautionary statements concerning bees, fish or aquatic organisms).

IV.  WHAT REGISTRANTS AND APPLICANTS SHOULD DO 

A. Adoption of Exact Language through Notification

Registrants who adopt the exact wording set forth in this notice should
submit a notification (according to PR Notice 98-10) for each product.
EPA may review the notification to ensure that the wording is identical
to that contained in this notice. The registrant should submit one copy
of the label (with changes clearly marked in a way that can be
photocopied) along with a completed Application for Registration form
(EPA Form 8570-1) which is available for downloading at
http://www.epa.gov/opprd001/forms/. The application form must bear the
following statements:

	"Notification of label change relative to PR Notice 2007-x. This
notification is consistent with the guidance in PR Notice 2007-x and the
requirements of EPA's regulations at 40 CFR 156.10, 40 CFR 156.80 and 40
CFR 152.46, and no other changes have been made to the labeling or the
confidential statement of formula of this product. I understand that it
is a violation of 18 U.S.C. Sec. 1001 to willfully make any false
statement to EPA. I further understand that if this notification is not
consistent with the guidance of PR Notice 2007-x and the requirements of
40 CFR 156.10, 40 CFR 156.80 and 40 CFR 152.46, this product may be in
violation of FIFRA and I may be subject to enforcement action and
penalties under sections 12 and 14 of FIFRA." 

B. Adoption of Altered Language through Amendment

Altered versions of the statements listed in Section III B may be
appropriate for some outdoor residential products.  For example,
registrants with products that direct the user to water in a product
immediately after application or products with approved label claims of
being  rain resistant within a given period of time, may wish to alter
or remove the environmental hazard statement regarding rain. Any
alterations of the complete statements listed in this Notice should be
submitted by normal amendment procedure

V.  EFFECTIVE DATES 

Effective immediately, EPA will begin accepting notifications of revised
product labels that meet the criteria set forth in this Notice. EPA will
also begin accepting applications for new product labels bearing the
environmental hazard statements as written in Section III of this Notice
at that time. 

VI.  ADDRESSES TO USE 

Registrants should send notifications and amendments to one of the
following addresses: 

	U.S. Postal Service Deliveries 

The following official mailing address should be used for all
correspondence or data submissions sent to OPP by U.S. mail:

Document Processing Desk (AMEND) or (NOTIF) [as applicable]
(Distribution Code as identified in PR Notice 2006-1)

Office of Pesticide Programs (7504P)

U.S. Environmental Protection Agency

Ariel Rios Building1200 Pennsylvania Ave., NW

Washington, D.C. 20460-0001

Personal/Courier Service Deliveries

The following address should be used for all correspondence or data
submissions that are hand-carried or sent by courier service Monday
through Friday, from 8:00 AM to 4:30 PM, excluding Federal holidays:

Document Processing Desk (Distribution Code as identified in PR Notice
2006-1) (AMEND) or (NOTIF) [as applicable]

Office of Pesticide Programs (7504P)

U.S. Environmental Protection Agency

Room S-4900, One Potomac Yard

2777 South Crystal Drive

Arlington, Virginia 22202-4501

VII.  SCOPE OF POLICY 

This PR Notice provides guidance to EPA and to pesticide registrants.
Although EPA encourages registrants to adopt these revised environmental
hazard statements for outdoor residential products, this notice is not
binding on either EPA or pesticide registrants, and EPA may depart from
this guidance in individual circumstances. Likewise, pesticide
registrants may assert that the guidance is not appropriate for a
specific pesticide or situation. 

VIII.  FOR FURTHER INFORMATION 

If you wish to obtain further information on this notice, please contact
the appropriate division ombudsman for your product. Division contacts,
including ombudsmen, can be found by visiting   HYPERLINK
"http://www.epa.gov/pesticides/contacts/index.htm" 
http://www.epa.gov/pesticides/contacts/index.htm .  At the release date
of this Notice, the ombudsmen are:

Biopesticides and Pollution Prevention Division (BPPD): 

Brian Steinwand    HYPERLINK "mailto:steinwand.brian@epa.gov" 
steinwand.brian@epa.gov    703-305-7973		

Registration Division (RD):

Linda Arrington    HYPERLINK "mailto:arrington.linda@epa.gov" 
arrington.linda@epa.gov      703-305-6249

Antimicrobials Division (AD):

Michael Hardy      HYPERLINK "mailto:hardy.michael@epa.gov" 
hardy.michael@epa.gov       703-308-6432

Debra Edwards, Ph. D., Director

Office of Pesticide Programs

 

