Chp 1.-Pesticide Registration and the Label

Question 1

Pesticide Use Classification: General Use, Restricted Use, and Restricted Materials

Any pesticide product for sale, possession, or use, must first register the pesticide product with U.S. EPA and DPR.

Persons or companies
that register pesticide products, referred to as “registrants”

A pesticide may be unclassified or classified

Classified are either~restricted or general use.

Answer 1

A pesticide is labeled “restricted materials” when there are known hazards that cannot be mitigated through labeling or directions.

Because of the higher potential to cause harm to public health, farm workers, domestic animals, honeybees, environment, wildlife, or other crops; persons using or supervising restricted materials, will possess a commercial or private QAL (qualified applicator license).

Question 2

State Pesticide Product Registrations and Accepted Labeling

Answer 2

US EPA and DPR evaluate large volumes of scientific data for each pesticide active ingredient and product. A label is then accepted whereby any pesticide container sold or used in California must contain an identical label to that one on file with DPR.

Question 3

Product That Is No Longer Registered
(Q1.2, Q1.3)

• Registrant allows the registration to lapse by not renewing it, or
• DPR or U.S. EPA suspends or cancels the pesticide product registration.

Answer 3

If the registrant allows a product registration to lapse, a pest control dealer who acquires the pesticide product while it was still registered may sell and deliver it for two years after the last date of registration.

When US EPA or DPR cancel or suspend the registration of a pesticide product, they often impose specific restrictions on the sale and use of existing stocks. All person possessing these products must comply with all sales and use provisions of suspension.

Question 4

Amending the Registered Label

Answer 4

Any changes made to a registered label, must be reviewed and accepted by US EPA and DPR before the product can be sold or used in California.

Question 5

Types of Pesticide Registration

The Federal Insecticide Fungicide, Rodenticide Act (FIFRA) is the federal law that outline the various types of pesticide product registrations and exemptions.

Three most common type of registrations are

Answer 5

Most commonly referred to

• are section 3 (general pesticide product registration)
• section 18 (emergency exemptions from registration) and
• section 24c (special local need registrations)

Question 6

(Section 3.) Registration of General Pesticides

Answer 6

FIFRA section 3 grants U.S. EPA the authority to register pesticide products with the corresponding label.
often referred to as the section 3 label
containing basic registered uses, use
directions, requirements, and prohibitions.

Question 7

(Section 18.) Exemption of Federal and State Agencies

FIFRA authorizes US EPA to allow an unregistered use of a pesticide for a limited time if it determines that emergency conditions exist~

Defines “Emergency Condition” as an urgent, non-routine situation that requires the use of a pesticide.

There must be no other alternative and upon approval the EPA will issue the emergency exemption registration

Answer 7

There are 4 types of emergency exemptions:

1. ) specific
2. )public health
3. ) Quarantine
4. ) Crisis
   * All require a valid restricted materials permit, and strict record keeping.

Question 8

(Section 24.) State Authority
(Q1.4)

FIFRA grants states pesticide regulatory authority in 3 areas.

Answer 8

a. )Sales and Use of federal pesticides so long as not prohibited by FIFRA
b. ) Cannot impose labeling/packaging requirements different than FIFRA.

c.) “Special Local Need”-SLN-Allows states to issue a use registration not previously issued by the US EPA. This allows states to expand the uses of certain registered pesticides within their jurisdictions. For example, some SLN’s allow uses of a registered pesticide for crops or sites not listed on the section 3 label. The 24(c) registration label will contain a registration number that
includes the letters, “SLN” and the code for the state issuing registration.

*These registrations are legal only in the region, state, or local area specified on the label. Application of SLN pesticide from another state or region may lead to civil or criminal penalties.

Question 9

Research Authorizations

Answer 9

California has specific laws regarding experimental, unregistered uses of pesticide products.

Typically established for University programs “research authorizations” are issued only to allow research for unregistered uses on limited acreage or use sites-Sometimes requiring the research crop to be destroyed.

Not to be confused with Federal Experimental Use Permits that must be registered by the US EPA.

Question 10

Pesticide Labeling-pages.
(Q1.5)

The Information Provided in Pesticide Labeling Refer to the corresponding numbers on the sample pesticide label (Figure 1-3) for examples of the following pesticide label sections:

Answer 10

A“supplemental label” is any that is not part of the pesticide container but is otherwise attached to or accompanies the pesticide product container or device. Some labels refer to other documents, such as a Material Safety Data Sheet (MSDS) or a commodity treatment schedule. Agricultural use pesticide labels also refer to the Worker Protection Standard Provisions of 40 CFR part 170.

Question 11

1.] Brand Name.

Answer 11

A brand name is the name the manufacturer gives to the product. This is the name found in the DPR database and used to advertise and promote the product.

Question 12

2.]Chemical Name.

Answer 12

Chemical names describe the chemical structure of a pesticide active ingredient.
Chemists follow international rules for naming chemicals.

Question 13

3.]Common Name.

Answer 13

Chemical names of pesticide active ingredients are often complicated. Therefore, manufactures give most pesticides common or generic names. For example,
0,0-diethyl 0(2-isopropyl-6methyl-4-pyrimidinyl), has the common name diazinon. Common names and brand names are not the same, and not all labels list common names for the active ingredient(s).

Question 14

4.] Formulation.

Answer 14

Labels usually list the formulation type, such as emulsifiable concentrate, wettable powder, or soluble powder. Manufacturers may include this information as a suffix in the brand name of the pesticide. For example, in the name Princep 80W, the “W” indicates a wettable powder formulation.

Question 15

5.] Ingredients.

Answer 15

Pesticide labels list the percentage of each active ingredient and total percentage of the inert ingredients by weight. Inert ingredients are all components of the formulation that do not have pesticidal action, therefore are not considered active ingredients but are intentionally included in the product. Examples include solvents, preservatives, stabilizers, etc. However, these may be toxic, flammable, or pose other safety or environmental problems. Some, however, may be harmless, such as clay. If this were a liquid formulation, the label would also indicate how many pounds of active ingredient there
are in 1 gallon.

Question 16

6.] Contents.

Answer 16

Labels list the net contents, by weight or liquid volume, contained in the package.

Question 17

7.] Manufacturer/Producer.

Answer 17

Pesticide labels will contain the name and address of the manufacturer/producer of the product. Use the contact information if you need to contact the manufacturer for any reason. In some cases a company manufactures/produces a pesticide for another company or person who is the registrant, and whose name appears on the label. The label will then qualify that the manufacturer is not the registrant with wording such as, “Manufactured for…”
or “Produced for…”

Question 18

8.] Registration and Establishment Numbers.

Answer 18

U.S. EPA assigns registration numbers to each pesticide. You need this EPA number if you are reporting the use of the pesticide. In addition, an establishment number identifies the site of manufacture or repackaging.

Question 19

9.] Signal Word.

Q1.6

Answer 19

An important part of every label is the signal word. The signal word indicates to the user the pesticide product’s toxicity level. It is determined by the acute (short term) toxicity data conducted on the pesticide product. Part of the registration process assigns each pesticide to a toxicity category, based on acute toxicity to humans and noted by the signal word. The words
“DANGER” and “DANGER/POISON” with a skull and crossbones indicate that the pesticide is highly toxic. The word “DANGER” used alone indicates that the pesticide poses a dangerous health hazard. “WARNING” indicates moderate toxicity, and “CAUTION” means low toxicity.

Question 20

10.] Precautionary Statements.

Q1.7

Answer 20

The precautionary statements are designed to provide the pesticide user with information regarding the toxicity, irritation and sensitization hazards associated with the use of a pesticide, as well as treatment instructions and information to reduce exposure potential. It includes information on potential hazards to people and domestic animals and the type of protective equipment to wear while handling packages, mixing and applying the product.
In addition, it includes information on environmental hazards, such as the product’s toxicity to non-target organisms such as honeybees, fish, birds, and other wildlife. The third part of the precautionary statement explains special physical and chemical hazards. These include risks of fire or explosion and hazards from fumes.

Question 21

11.] First Aid Statement.

Answer 21

The first aid statements provide emergency first aid information. They describe the emergency first aid procedures for swallowing, skin and eye exposure, and inhalation of dust or vapors. This section tells you when to seek medical attention.

Question 22

12.]Statement of Use Classification.

Answer 22

As described above, U.S. EPA classifies pesticides as either general use, unclassified or restricted use. U.S. EPA restricted use pesticides have a special statement printed on the front page of the label. Pesticides that do not contain this statement are either unclassified or general use pesticides, except where special state restrictions apply. Some labels have restrictive statements indicating that they are for agricultural or commercial use only. A restrictive statement is different from a statement of use classification.

Question 23

13.]Directions for Use. (Q1.8)

Answer 23

The directions for use are an important part of the pesticide label that must be followed to keep from violating the law. It is illegal to use a product in a manner inconsistent with the directions for use except where federal or state laws specify acceptable deviations from the label (see the section titled, “Deviations from Label Directions”).

The directions for use, list all the target pests that manufacturers claim their pesticides control. They also include the crops, plant species, animals, or other sites where the pesticide can be used. Here is where you find special restrictions that you must observe. These include crops that you may or may not plant in the treated area (plant back restrictions). They also include restrictions on feeding crop residues to livestock or grazing livestock on treated plants.

These instructions tell you how to apply the pesticide. They specify how much to use, where to use the material, and when to apply it. The directions also include the pre-harvest intervals for all crops whenever appropriate. Some labels refer to a “harvest interval” or “interval before harvest.” This interval is the time, in days, required after application before you may harvest an agricultural crop.

Question 24

14.] Agricultural Use Requirements. (Q1.1)

Answer 24

This special statement appears in the Directions for Use section on labels of pesticides approved for use in production agriculture, commercial greenhouses and nurseries, and forests. It refers to the federal Worker Protection Standard (Code of Federal Regulations, Title 40, part 170), which has been incorporated into the 3 CCR. It provides information on the personal protective equipment required for early-entry workers. It also gives the restricted-entry Interval for workers. The agricultural use requirement section may differ from other requirements on the label or those listed in 3 CCR. You must use the pesticide in accordance with the most restrictive requirements.

Question 25

15.] Restricted-Entry Statement.

Answer 25

A Restricted-Entry Interval (REI) is the time period immediately following a pesticide application during which entry into the treated area is restricted, REIs vary according to the toxicity and special hazards associated with the pesticide. The crop or site being treated and its geographic location also influence the length of the interval. Some pesticide uses in California require longer REIs than those listed on the pesticide label. Check with the local County Agricultural Commissioner for this information.

Question 26

16.] Misuse Statement.

Answer 26

The misuse statement reminds users to apply pesticides according to label directions.

Question 27

17.] Storage and Disposal.

Answer 27

Directions for properly storing and disposing of the pesticide and empty pesticide containers are another important part of the label. Proper disposal of unused pesticides and pesticide containers can reduce human and environmental hazards. Some pesticides have special storage requirements because improper storage causes them to lose their effectiveness. Improper storage can cause explosions or fires.

Question 28

18.]Warranty.

Answer 28

Manufacturers usually include a warranty and disclaimer on their pesticide labels. This information informs you of your rights as a purchaser and limits the liability of the manufacturer. Note: Companies are not required to include a warranty statement on their label. However, exclusion of a warranty statement is not common.

Question 29

Deviations from Label Directions
(Q1.9, Q1.10)

One can sometimes use pesticides in a manner that conflicts with or deviates from label directions. Generally involve safer or less disruptive practices. Federal law and California regulations allow eight deviations from label directions; each under limited circumstances. They include:

Answer 29

1. ) Application at a frequency lower than specified,
2. )Application at a frequency higher than specified,if the label does not limit the # of applications.
3. ) Increase concentration as long as it corresponds with published recommendation of the University of California. (decreasing carrier)
4. )Decrease in the concentration of the mixture applied.(adding more carrier)
5. ) Decrease rate/ unit treated (without changing volume of the carrier)
6. ) If the control of a target pest is not expressly prohibited on the label, then it maybe used.
7. ) If the label does not specify exactly how to apply the pesticide, it is allowed to use other methods so long as they are practical.
8. ) It is possible to mix pesticides so long as it is not specifically prohibited.

• Note: Ensure proper research of pest and consideration from professionals before deviating from the label directions as it may result in overconsumption or inadequate treatment.
• Under no circumstance can you legally increase the amount of pesticide you apply beyond the maximum label rates.

Question 30

Exceptions to or substitutions for personal protective equipment (PPE) requirements.

Answer 30

1. ) When used in a closed system that meets DPR closed system criteria to handle pesticide products with the signal word “Danger/Poison” or “Warning”.
   - If it does not operate under positive pressure, handlers may substitute PPE for that listed on the label.
   - If does operate under positive pressure handlers must wear eye protection, though may replace other PPE with that of the label.
2. ) When used in a closed system that meets DPR closed system criteria to handle pesticide products with the signal word “Caution”.
   - If it does not operate under positive pressure, handlers may substitute PPE for that listed on the label.
   - If does operate under positive pressure handlers must wear eye protection, though may replace other PPE with that of the label.