When you think about the word "label," you probably think of eye-catching packaging with a healthy dose of advertising. Pesticide labels are different: they are legally mandated by our national pesticide law, the Federal Insecticide, Fungicide and Rodenticide Act. The information that is found on a pesticide label is defined by law, and it is illegal to use a pesticide in a manner not permitted by its labeling.(1)

A few pesticide uses have additional regulations under state or local laws requiring, for example, permits for aquatic applications. But for the vast majority of pesticide applications, the restrictions on the label are the only legal requirements. Therefore, they can be useful if you are trying to stop or modify an application.

How Do I Get a Label?

If you are concerned about a pesticide that is being used by a commercial pest control operator or a public agency, start by asking the business or agency that is spraying to give you a copy of the label. Many users are happy to provide labels. If such a request is not possible,try to obtain the name of the product that is being used. Get the complete name, and the U.S. Environmental Protection Agency (EPA) registration number if possible, because the names of many products are similar.

With the registration number, you can use EPA's label database to get an electronic version of the EPA-approved label. These labels are not in their final format, but the text is accurate. For labels in final format, a good place to start looking is Crop Data Management Systems (CDMS). This collection of current, downloadable labels is organized by manufacturer, but searchable by product. CDMS focuses on agricultural pesticides, but some residential and commercial products are also included.

If your pesticide is not in the CDMS collection, you will need to determine the manufacturer of your product. On the web, the best way to do this is to use a database maintained by the California Department of Pesticide Regulation for EPA. Using this database you can enter either the product name or the EPA registration number and identify the manufacturer. To get this information by phone, call the National Pesticide Telecommunications Network (NPTN) at 1- 800-858-7378. A product can be sold under a name that is different than its registered name; if you have trouble, call NPTN. If you talk to NPTN, also ask them for the name of the active ingredient in the product and a toll-free number for the manufacturer.

Next, call the manufacturer of your pesticide, and request a faxed or mailed specimen label. Or, download a label from the manufacturer's website. See "Labels on the Web," below, for a list of manufacturer websites that offer labels for downloading as of July 2003.

If a container of pesticide was registered and sold in the past, but never used, in most cases it can be used according to the label that is on the product, even if that label is now out-of-date. If you are concerned about an application using an old product, you need the label that is on the product, not a current label. EPA's database contains both old and new labels which can be useful in this situation.

What Information on the Label is Useful?

If a label requirement contradicts the procedures used in the application you're concerned about, pesticide users may stop or modify their applications in order to avoid the sanctions or fines that can result from using a pesticide "in a manner inconsistent with its labeling." NCAP suggests asking the following questions:

1. Is the product registered for this use? The label will list uses which have been registered by EPA. Check to see that the use you're concerned about is listed on the label. Be aware that uses for a pest that is not listed on the label are legal, as long as the site where the pesticide is being used is listed on the label.(2) For example, the Daconil Zn label identifies two plant diseases for which Daconil Zn can be sprayed on golf courses.(3) However, it would be legal to use Daconil Zn for any golf course pest. Some uses are permitted under supplemental labels that are specific to a state or crop, so check to see if your product has them.

2. Is the product being applied at the label rate? Applying a pesticide at rates greater than those specified on the label is not permitted.(2) For example, the Tempo 20 WP label states that 10 grams per 1000 square feet should be used for general indoor surface applications.(4) It would not be legal to apply Tempo at 20 grams per 1000 square feet. However, reduced application rates are legal: 5 grams per 1000 square feet would be permitted by this label.

3. Is the application method acceptable? Any application method is legal, as long as it is not specifically prohibited on the label.(2) For example, the Roundup Pro label states, "Do not apply this product through any type of irrigation system."(5) Thus, applying this product through irrigation sprinklers would be a legal violation. However, using an application method that is not mentioned on the label is permitted.

4. Does the application contaminate water? Many labels require the user to avoid water contamination. For example, the Tempo 20 WP label prohibits applications "to areas where surface water is present."(4) If this restriction is violated, the application is illegal. Notice that this requirement is less straightforward than those involving application rates or methods. If data from an analytical laboratory are necessary to prove that water has been contaminated, it will often be expensive.

5. Does the application expose neighbors or other people? Some applications have quite specific language prohibiting human exposure. For example, the Daconil Zn label requires that applicators "NOT apply this product in a way that will contact workers or other persons." (3) If you can demonstrate that these conditions are not being followed, the application is illegal. Again, this is less straightforward than conditions involving application rates or methods.

6. Does the application follow worker protection guidelines? Required procedures to protect agricultural workers will be specified on the label in a box labeled "Agricultural Use Requirements." The requirements generally include a reentry interval, the minimum amount of time that must elapse between the application and workers entering the treated area. For example, the Daconil Zn label required that workers not enter treated areas for 48 hours after treatment.(2)

7. Are applicators required to prevent drift? Some herbicide labels prohibit drift on to desirable crops. For example, the Roundup Pro label states "Avoid contact of herbicide with ... desirable plants and trees."(5) Applications which damage such vegetation would therefore be illegal. As before, this is less straightforward than conditions involving application rates or methods.

One final caution: Not all label statements are mandatory. Some are simply "advisory" and are not enforceable. EPA is currently asking manufacturers to reword labels to make this distinction clear.(6)

Conclusion

The goal of pesticide reform is to replace pesticide use with sustainable management practices. Progress towards this goal can come just from making sure that pesticide applications follow the law, a task for which careful and imaginative study of pesticide labels is essential.

-- Caroline Cox

References

1. FIFRA § 3(c)(5) and § 12(a)(2).
2. FIFRA § 2(ee).
3. Zeneca Professional Products. 2000. Daconil Zn Flowable Fungicide. Specimen label. Wilmington DE. www.cdms.net.
4. Bayer Corporation. 1996. TempoŽ 20 WP. Specimen label. Kansas City MO. www.cdms.net.
5. Monsanto Co. 2000. Roundup Pro. Specimen label. St. Louis MO. www.cdms.net.
6. U.S. EPA. 2000. Guidance for mandatory and advisory labeling statements. PR Notice 2000- 5. Washington, DC, May 10. www.epa.gov/ PR_Notices.

Labels on the Web