1. Label Comprehension Goals: To teach: What IS on the label (and where)
Content
Format
What IS NOT on the label
How to use / follow the label!

2. Label Comprehension
How to teach about the label using “active learning” methods for field and classroom:
sample PPT + discussion
w/ audience-appropriate interpretive questions…
paper and pencil activities
interpretation / application activities

3. Label Comprehension This PPT is NOT “ready to use”!
To convert this “plain vanilla” PPT to an audience-appropriate one, consider:
What do these people do?
What pesticide products do they use?
Do any of these products require special management?
Are any of them similar to other products with different use patterns/requirements?
This PPT -- or at least parts of it -- uses and refers to the following product labels, which were copied and distributed to the class participants:
Accord Concentrate (glyphosate)
Glypro Plus (gyphosate)
Rodeo (glyphosate)
Garlon 3A (triclopyr)
Redeem R&P (triclopyr and clopyralid)

4. Label Comprehension
To convert this “plain vanilla” PPT to an audience-appropriate one (continued):
Write (at least one) appropriate/relevant question after each section, on the slide w/ ??? in the title bar.
“Jazz it up” with pictures…?!
Use images of local sites and situations…or
Check out:
= pesticidepics.com
This PPT -- or at least parts of it -- uses and refers to the following product labels, which were copied and distributed to the class participants:
Accord Concentrate (glyphosate)
Glypro Plus (gyphosate)
Rodeo (glyphosate)
Garlon 3A (triclopyr)
Redeem R&P (triclopyr and clopyralid)

5. Pesticide Labels & Labeling
Edit this slide to use your name and County…
Pat Hipkins
Virginia Tech Pesticide Programs

6. Pesticide Labeling Background: Several Types of Registration
federal (Sec. 3)
special local need (SLN or Sec. 24C)
emergency exemption (Sec. 18)
Classification of Pesticides
general use
restricted use

7. Pesticide Labeling EPA sets standards (content, format):

8. Required Information Name and address of the producer or registrant
Restricted Use Statement (if applicable)
Product Name, Brand or Trademark
Ingredient Statement and net weight or measure of contents
EPA Registration Number and EPA Establishment Number
Signal Word, including Skull & Crossbones, if either are required
"Keep Out Of Reach Of Children" statement
Precautionary Statements, including Hazards to Humans & Domestic Animals and First Aid (Statement of Practical Treatment), Environmental Hazards, and Physical/Chemical Hazards
Storage and Disposal Statements
Directions for Use
Warranty Statement
Listed below are the EPA-required sections of the label:
- Restricted Use Pesticide Statement - if applicable
This section of the label if applicable, includes the references to “restricted use”, which under FIFRA Section 3 (d)(1)(c) describes those pesticides that require “additional regulatory restrictions” to avoid potential unreasonable adverse effects on the environment.
- Product Name, Brand or Trademark
- Ingredient Statement and Net Contents/Net Weight
The IS section of the label identifies the name and the percentage by weight of each active ingredient and the percentage by weight of other/inert ingredients. If the size or form of the product package makes it impracticable to place the ingredient statement on the front panel of the label, permission may be granted for the ingredient statement to appear elsewhere.
The NC/NW section identifies the weight or volume of pesticide in the container.
- "Keep Out of Reach of Children" (KOOROC) Statement
This specific statement, which is commonly referred to as the KOOROC statement ("child hazard warning"), appears on almost all end use pesticide products except those pesticides that are intended for use on children or where it is demonstrated that children will not come in contact with the product. In these cases, a modified statement is allowed.
- Signal Word
Signal words which correspond to the toxicity categories for product hazards (e.g., oral,dermal) appear on the front panel of the label.
- EPA Registration Number & Establishment Number
The EPA Registration Number is the single most important piece of information for tracking pesticide products. The EPA Registration Number must appear on the label of the product.
The EPA Establishment Number identifies the final physical location where the pesticide product was produced or labeled. The EPA Establishment Number may appear on any suitable location on the label or immediate container, however it must appear on the wrapper or outside container of the package if the number cannot be clearly read through the wrapper or container.
- Company Name & Address
This section of the label identifies the name and address of the producer, registrant or person for whom the product is produced.
- Precautionary Statements
1. Hazards to Humans and Domestic Animals
Where a hazard exists to humans or domestic animals precautionary statements that describe the particular hazard, route of exposure and precautions to be taken must appear on the label.
2. First Aid (Statement of Practical Treatment)
This section of the label provides information to the pesticide user concerning appropriate first aid for the various routes of exposure associated with accidental exposure. A first aid statement must appear on the front panel of all Toxicity Category I pesticides. (The front panel must include a reference such as “See statement of practical treatment on back panel” near the word “poison” and the skull and crossbones if EPA allows the first aid information to appear on the back panel.)
3. Environmental Hazards
Where a hazard exists to non-target organisms precautionary statements that identify the hazards and necessary precautions must appear on the label.
4. Physical or Chemical Hazards
Hazards such as flammability, explosive potential or dielectric breakdown and the various precautions to be taken must be identified, as applicable.
- Directions for Use
This section of the label provides instructions to the user on how to use the product, and identifies the pest(s) to be controlled, the application sites, application rates and any required application equipment. This section may also include certain worker protection issues such as a reentry statement which identifies the specific time period following treatment during which entry into a treated area is restricted. WPS ag/non-ag use requirements are usually placed at the beginning of this section.
- Storage and Disposal
This section of the label provides instructions for storing the pesticide product and for disposing of any unused pesticide and the pesticide container.
- Warranty Statement
This is a disclaimer statement included voluntarily on most pesticide products by the registrant.

9. Mandatory Statements Relate to actions necessary to: They may include:
ensure proper use, and
prevent unreasonable adverse effects on the environment, which is defined by statute.
They may include:
directions for use,
precautions that direct the user to take or avoid specific actions,
specify where, when and how a pesticide may be applied.

10. Mandatory Statements Examples of mandatory statements:
“Wear chemical resistant gloves.”
“Do not induce vomiting.”
“Do not apply within 66 feet of wells.”
“Do not apply directly to water.”
“Keep away from heat, sparks and open flame.”
“Do not enter into treated areas for 12 hours.”
“Do not apply when wind speed exceeds 15 mph.”

11. Advisory Statements Provide information regarding:
product characteristics, and/or
how to maximize safety and efficacy.
Must NOT conflict with mandatory statements.
May NOT be false or misleading, or otherwise violate statutory or regulatory provisions.

12. Advisory Statements Examples of advisory statements:
In the Precautionary Statements section:
“Latex gloves provide the best protection.”
In the Physical and Chemical Hazards section:
“Opening aluminum phosphide containers outdoors or indoors near an exhaust fan or other ventilation ensures that the gas will be rapidly dispersed if the product flashes.”

13. Advisory Statements Examples of advisory statements (continued):
In the Directions for Use / Mixing section:
“Apply this product immediately after preparation to ensure that it is in suspension. If application is delayed, agitation to re-mix and ensure proper blending.”
In the Directions for Use / Application section:
“Directing the spray mixture around the base of the cotton plants and using leaf lifters and shields on application equipment will help minimize foliage contact and plant injury.”

14. Summary: Parts of a Label
Identifying information
Product name, Ingredient statement, Net contents, EPA registration number and establishment number, Use classification (general/restricted; use pattern and site)…
Precautionary Statements
Signal word, child hazard warning, first aid, hazards to humans and domestic animals, environmental hazards, physical or chemical hazards, PPE, engineering controls…
Directions for Use
Ag (WPS) vs. non-ag use requirements, where and how to apply, how much and when to use, how to handle (mix, load, handle, store, and dispose of…)
Conditions of Sale/Limitations of Warranty and Liability
(+ name and address of manufacturer, emergency contact info)

15. Parts of a Label Identifying Information Brand Name Chemical Name
Ex: Garlon® 3A
Chemical Name
Ex: 3, 5, 6-trichloro-2-pyridinylozyacetic acid, triethyamine salt
common name
Ex: triclopyr

16. Parts of a Label Identifying Information (continued)
Net Contents COMPOSITION
Active Ingredient (% by weight):
triclopyr (3, 5, 6-trichloro-2-pyridinylozyacetic acid, triethyamine salt)…………………………………….44.4%
Inert Ingredients:…………………….…………….…55.6%
Acid equivalent: triclopyr % - 3 lb/gallon

17. ??? What does the name Garlon® 3A tell you about the product?!
Which part of the Ingredient Statement is more useful…and why?
chemical name = 3, 5, 6-trichloro-2-pyridinylozyacetic acid, triethyamine salt
common name = triclopyr
3A = amine (vs. ester) formulation; 3-pound gallon!
Of the NRCS set, another example is Redeem R&P; the name indicates the site = range and pasture.
Often, product names indicate amount of a.i., formulation, and/or site = Pendulum® 2G (2% granule), Bayleton® 50 T&O WSP (50% water-soluble powder).
Many product names indicate pesticide class and use pattern. Examples include:
Confirm 2F Agricultural Insecticide
Fore Turf and Ornamental Fungicide
Dichlobenil Weed and Grass Killer
Plateau herbicide for weed control and turf suppression on roadsides and other noncrop areas
Common name vs. “official” chemical name is much more useful…knowing it will allow applicators to:
learn a.i. properties…ex. glyphosate is non-selective and triclopyr controls only dicot/broadleaf plants,
compare products…ex. knowing glyphosate vs. Roundup is very useful now that RU is off patent and there are many “generics” on the market.
compare legal use of products that contain the same a.I!!

18. ??? What do the three glyphosate products: have in common?
Accord Concentrate
Glypro Plus
Rodeo
have in common?
How are they different?

19. ???
You’re an NRCS specialist advising a client who wants to control weeds in a forested riparian buffer.
Which glyphosate product would you recommend -- and why?
Accord Concentrate
Glypro Plus
Rodeo
Riparian = on the bank of a river, creek, pond, or small lake.
Glypro Plus is NOT labeled for application in or around water or aquatic sites.
Accord C allows incidental water contact. Rodeo may be applied directly to water.
In this situation, either Accord or Rodeo would be good choices. Glypro Plus would be a poor choice because of the sensitivity of the site and its proximity to water.

20. ???
You’re an Extension agent advising a client who wants to control cattails and other emergent vegetation growing in shallow water along the edge of a pond.
Which glyphosate product would you recommend -- and why?
Accord Concentrate
Glypro Plus
Rodeo
Riparian = on the bank of a river, creek, pond, or small lake.
Glypro Plus is NOT labeled for application in or around water or aquatic sites.
Accord C allows incidental water contact, but CANNOT be applied directly to water. Moreover, it’s labeled for forested sites and rights-of-way. If this pond is in an urban area or on a farm, using Accord would be illegal/off label.
Rodeo is the only option.

21. Parts of a Label Identifying Information (continued)
EPA Registration and establishment number
EPA Reg. No. ( )
EPA Est. No. (not given on many labels posted on the internet…but required on actual product labels)

22. ???
Study the EPA registration numbers on the set of 5 labels provided. Do you see a pattern?!
What does the EPA registration number tell you?
The first part of the number indicates the registrant…ex. Syngenta is 100-XXX, Bayer is 264-XXX (and this includes the old R-P products -- but the old Chipco products are 432-XXX), Monsanto is 524-XXX, etc.
The EPA Registration Number is the single most important piece of information for identifying and tracking pesticide products. The EPA Registration Number must appear on the label of the product. It’s like the product’s “fingerprint”!

23. ???
Why do you suppose that labels posted on the internet don’t have/show an EPA establishment number?
What does the EPA establishment number tell you?
The EPA Establishment Number identifies the final physical location where the pesticide product was produced or labeled. The EPA Establishment Number may appear on any suitable location on the label or immediate container, however it must appear on the wrapper or outside container of the package if the number cannot be clearly read through the wrapper or container. It is used in cases of product problems, recalls, etc. to ID production sites and batches.

24. Parts of a Label Identifying Information (continued)
Restricted Use Designation (if applicable);
Reason for RUP classification.

28. ??? True or False: Restricted-Use Products are highly toxic.
Give a reason for your answer!
What is accomplished by classifying a product as RUP?!
There are LOTS of reasons for classifying a product as RUP!
RUP classification ensures that only trained / certified people can purchase and use the product…which makes it much more likely that it will be used correctly/carefully! EPA uses RUP classification as a risk-reduction measure. It’s important that educators and professional applicators do a good job of training and take pesticide safety education seriously!

29. Parts of a Label Precautionary Statements
Child Hazard Warning Statement (KOOROC)
SIGNAL WORD
Danger-Poison  (skull and crossbones symbol)
Danger
Warning
Caution

34. ??? Which product(s) do you think is/are more toxic? Why?
Accord Concentrate
Glypro Plus
Rodeo
Garlon 3A
Redeem R&P
Why?
Garlon 3A and Redeem R&P have DANGER signal words. The others have CAUTION signal words.
The term “LD50” expresses the level of toxicity of a chemical. “LD” means lethal dose. LD50 is the dose, based on weight, that will kill 50% of a population of test animals. The higher the LD50 value, the less acutely toxic the chemical. This value is usually expressed as milligrams/kilogram of body weight. A chemical with an LD50 of 5,000 mg/kg requires about 0.1 ounce of the chemical per pound of body weight to reach the LD50 value. For a 150-pound person, this would be about 15 ounces.
Acute oral exposure refers to a single dose taken by mouth (ingested). Acute dermal exposure means a single dose touching the skin or eyes (skin absorption). Acute inhalation exposure is an intake of a breath of contaminated air.
The labels on pesticide products have “signal words” to convey the degree of toxicity of the product. Signal words also may tell you whether the product is caustic (burns) or is an environmental hazard. They are as follows:
CAUTION: Slightly toxic.
WARNING: Moderately toxic.
DANGER: Highly toxic or hazardous in some manner. A DANGER signal word indicates that the product may cause acute illness from oral, dermal, or inhalation exposure OR cause severe eye or skin irritation:
Acute Oral - Up to and including an LD50 of 50 mg/kg.
Acute Dermal - Up to and including 200 mg/kg.
Acute Inhalation - Up to and including 0.05 mg/liter (4 hr exposure).
Primary Eye Irritation - Corrosive (irreversible destruction of ocular tissue) or corneal involvement or irritation persisting for more than 21 days.
Primary Skin Irritation - Corrosive (tissue destruction into the dermis and/or scarring)
In addition to the DANGER signal word, the word POISON and the SKULL and CROSSBONES symbol must be displayed on labels of products that are acutely toxic via oral, dermal, or inhalation exposure. In addition, it is recommended if the inert ingredient methanol is present at 4% or more in the subject product.

35. ???
“Trick Questions”
What is the LD50 of glyphosate, clopyralid, and triclopyr?
Why do applicators need to be concerned about more than just the acute toxicity of the active ingredient in the product?
The LD50 is NOT on the label. You can find it on the MSDS.
The active ingredient may not be the only hazardous component of the formulated product!
Also, the active ingredient is only one of many considerations in risk assessment -- for example:
Does the formulation and the packaging require a lot of handling to measure, mix, and load?
What is the concentration of the active ingredient in the formulated product?

36. ???
LD50 values:
Glyphosate
oral LD50 >5,000 mg/kg
Clopyralid
Triclopyr
oral LD mg/kg
Why do you think Garlon 3A and Redeem R&P have a DANGER signal word?!
One would be safe to assume it’s because of something OTHER than acute oral toxicity.
If you read the MSDSs for these products, you’ll learn that Redeem (triclopyr) can cause severe eye irritation and moderate corneal injury, which may be slow to heal.
Garlon, because of the triclopyr and the formulation ingredients, can cause severe eye irritation with corneal injury which may result in permanent impairment of vision or blindness -- and repeated skin exposure can cause irritation or a chemical burn.
In fact,The term “LD50” expresses the level of toxicity of a chemical. “LD” means lethal dose. LD50 is the dose, based on weight, that will kill 50% of a population of test animals. The higher the LD50 value, the less acutely toxic the chemical. This value is usually expressed as milligrams/kilogram of body weight. A chemical with an LD50 of 5,000 mg/kg requires about 0.1 ounce of the chemical per pound of body weight to reach the LD50 value. For a 150-pound person, this would be about 15 ounces.
Acute oral exposure refers to a single dose taken by mouth (ingested). Acute dermal exposure means a single dose touching the skin or eyes (skin absorption). Acute inhalation exposure is an intake of a breath of contaminated air.
The labels on pesticide products have “signal words” to convey the degree of toxicity of the product. Signal words also may tell you whether the product is caustic (burns) or is an environmental hazard. They are as follows:
CAUTION: Slightly toxic.
WARNING: Moderately toxic.
DANGER: Highly toxic or hazardous in some manner. A DANGER signal word indicates that the product may cause acute illness from oral, dermal, or inhalation exposure OR cause severe eye or skin irritation:
Acute Oral - Up to and including an LD50 of 50 mg/kg.
Acute Dermal - Up to and including 200 mg/kg.
Acute Inhalation - Up to and including 0.05 mg/liter (4 hr exposure).
Primary Eye Irritation - Corrosive (irreversible destruction of ocular tissue) or corneal involvement or irritation persisting for more than 21 days.
Primary Skin Irritation - Corrosive (tissue destruction into the dermis and/or scarring)
In addition to the DANGER signal word, the word POISON and the SKULL and CROSSBONES symbol must be displayed on labels of products that are acutely toxic via oral, dermal, or inhalation exposure. In addition, it is recommended if the inert ingredient methanol is present at 4% or more in the subject product.

37. Parts of a Label Precautionary Statements (continued)
Emergency Contact(s)
PPE Requirements
(see also Ag/NonAg Use Directions)

38. ???

39. Parts of a Label Precautionary Statements (continued)
First Aid (Statement of Practical Treatment)
Hazards to Humans and Domestic Animals
acute effects statements (description of acute effects, delayed effects, allergic effects...)
ex: “Fatal if swallowed...”

40. ???

41. Parts of a Label Precautionary Statements (continued)
Environmental Hazards
Physical and Chemical Hazards
User Safety Recommendations

42. ???

43. Parts of a Label
Conditions of Sale and Limitations of Warranty and Liability
Name and address of manufacturer
Emergency Contacts

44. ???

45. Parts of a Label Directions for Use
Standard language: misuse statement:
THE LABEL IS THE LAW!
“It is a violation of Federal Law to use this product in a manner inconsistent with its labeling.”
other statements, do’s, do not’s...

46. Parts of a Label Directions for Use (continued)
Agricultural Use Requirements* and/or Nonagricultural Use Requirements**
REI* **
PPE* **
Worker Notification* / Field Posting*

47. ???

48. Parts of a Label Directions for Use (continued)
“Directions” for Use by Reference
WPS Agricultural Use Requirements
Groundwater Protection ?
Endangered Species ?
Other special statements ?!

49. ???

50. Parts of a Label Directions for Use (continued)
Application Directions:
sites, rates, application intervals, application equipment and methods, mixing directions, pests controlled, days to harvest, +/-adjuvant use, tank mix directions, chemigation statement, aerial application statement…

51. ???

52. Parts of a Label Directions for Use (continued)
other directions / conditions / use precautions
Mandatory
Advisory

54. Parts of a Label
Storage and Disposal

56. The Label is the LAW!
The pesticide product label is a binding legal agreement between three parties:
the US Environmental Protection Agency,
the product registrant, and
the product user.

57. The Label is the LAW!
Pesticide product labels provide instructions for proper pesticide use.
Applicators must read, understand and follow label directions.

58. The Label is the LAW!
Pesticides may not be applied to any plant, animal or site not listed on the product label.
Materials may not be applied at higher rates or more frequently than the label directs.

59. The Label is the LAW!
Pesticide applicators are bound to follow label directions for transport, mixing, loading, application, storage and disposal of pesticides and pesticide containers.

60. The Label is the LAW!
Federal law (FIFRA) does allow use of some pesticides in ways not specifically mentioned in the labeling. Unless state law prohibits, applicators may:
apply a pesticide at a rate or frequency less than the label directs.

61. The Label is the LAW! Unless state law prohibits, applicators may:
apply a pesticide to control a target pest not listed on the label.
(However, the site, plant or animal treated must be listed, and the application must be in accordance with all label directions.)
use any appropriate equipment or method of application not specifically prohibited by the label.

62. The Label is the LAW! Unless state law prohibits, applicators may:
mix pesticide with fertilizer, if the mixture is not prohibited by the pesticide product label.
mix two or more pesticides, if all of the dosages are at or below the label rate for each separate component of the mixture, and if not prohibited by one of the product labels.

63. The Label is the LAW! PESTICIDE LABEL DIRECTIONS:
are not advice or suggestions;
are legal requirements.

64. When to READ THE LABEL before purchase;
before, during and after each use.

65. Why READ THE LABEL "Familiarity breeds contempt."
Label directions change!

66. Label vs. MSDS FIFRA (EPA) vs. HazCom (OSHA) Legal status
Intended use(s)
Information Provided

67. Label vs. MSDS FIFRA (EPA) vs. HazCom (OSHA) Legal status
Label = FIFRA
MSDS = OSHA
IF there are differences between the MSDS and the label…for example, in PPE requirements … applicators follow the LABEL!

68. Label vs. MSDS FIFRA (EPA) vs. HazCom (OSHA) Intended use(s)
Label = applicator/end user
MSDS = production through supply chain to end user

69. Label vs. MSDS FIFRA (EPA) vs. HazCom (OSHA) Information Provided
Label = Identifying Information (active ingredient mfgr.), Precautions, Use Directions…
MSDS = Information about all hazardous ingredients and properties of the formulated product, including detailed information about health effects and toxicology, environmental hazards, etc. … handling, transport, and storage … accident procedures (first aid, firefighting, spills)
Label:
Identifying information
Product name, Ingredient statement, Net contents, EPA registration number and establishment number, Use classification (general/restricted; use pattern and site)…
Precautionary Statements
Signal word, child hazard warning, first aid, hazards to humans and domestic animals, environmental hazards, physical or chemical hazards, PPE, engineering controls…
Directions for Use
Ag (WPS) vs. non-ag use requirements, where and how to apply, how much and when to use, how to handle (mix, load, handle, store, and dispose of…)
Conditions of Sale/Limitations of Warranty and Liability
MSDS:
Product Identification
Composition Information / Ingredients
Hazardous Identifications
First Aid
Fire Fighting Measures
Accidental Release Measures
Handling and Storage
Exposure Controls and Personal Protection
Physical and Chemical Properties
Stability/Reactivity
Toxicological Information
Ecological Information
Disposal
Transport
Regulatory Information
Other

70. Label Challenge Work in groups w/ a set of labels… Evaluate…
MOST toxic
LEAST toxic
Longest half-life
Highest ENVIRONMENTAL hazard
Highest PERSONAL hazard
Choose labels of products the participants do or would be likely to use. Pick ones that are not too long to save paper. Color code. Laminate and reuse.
These are sample criteria -- you may think of more, better… :-)

71. ?
THANKS!