(Beyond Pesticides, January 10, 2007) EPA decided at the end of 2007 to extend the deadline for public comments on its controversial proposal to allow pesticide product labels with third-party endorsements and cause-marketing claims. The new due date is March 27, 2008. The agency extended the public comment period for another 90 days in response to requests from Beyond Pesticides and others. In extending the comment, Debra Edwards, Director, Office of Pesticide Programs, said, ‚ÄúThe Agency is particularly interested in assuring that its State partners in pesticide regulations, as well as organizations such as yours, have adequate opportunity for comments.‚ÄĚ See letter.The issue of cause-marketing on pesticide labels came up last year when Clorox petitioned EPA to allow it to display the Red Cross logo on some of its products, including pine-sol and bleach products.
In letters to all the state pesticide regulatory agencies in March, 2007, Beyond Pesticides urged the states to deny the label changes approved by EPA, saying:
The inherent danger is that misleading the public about pesticides can result in harm to consumers who either do not, unfortunately, take the time to read pesticide labels or who cannot read or comprehend labels (e.g. non-English speaking citizens, visually impaired persons, children). EPA has allowed the use of the phrase, ‚ÄúDedicated to a Healthier World,‚ÄĚ as well as the prominent placement of the Red Cross logo on both the front and back panels, on five Clorox products, which further compounds the false message that such a label communicates.
Consider the significance of allowing the use of a symbol that implies safety. It is important to note that labeling language is a key risk mitigation strategy employed by EPA. An EPA literature review has explored the dynamics that influence whether or not people read pesticide labels. EPA cites multiple studies that find while a certain segment of the population never reads labels, ‚ÄúStudies showed that consumer perception of product hazardousness is the most significant indicator of whether or not they will read the precautionary label, followed in significance by the level of familiarity with a product.‚ÄĚ¬† The bottom line is that misleading information on pesticide labels can contribute to pesticide misuse. Take the example of Ultra Clorox Brand Regular Bleach product. For all product uses, the label requires the dilution of the bleach in water. The dilution rates vary depending on the prescribed use, such as nonporous surfaces, mildew removal or disinfection.
The Minnesota Department of Agriculture in April rejected the Clorox request for the cause-related marketing label, saying, ‚ÄúThe America Red Cross as an organization and the red cross as a symbol are well understood to mean (at least) safety, and it is MDS‚Äôs opinion and position that inclusion of such a symbol and organization name on a pesticide label would constitute misbranding.‚ÄĚ
Beyond Pesticides urges people to contact their state pesticide regulatory agency to urge them to write EPA opposing a label that will make it even more difficult to enforce than the current label. To find your state regulatory authority, go to Beyond Pesticides state pages.
Beyond Pesticides will be submitting comments reiterating earlier communications with the agency. If members of the public or organizations would like to sign on to our comments, please email firstname.lastname@example.org. You can view the docket for comments already submitted on EPA Docket ID # EPA-HQ-OPP-2007-1008. View the Federal Register notice for more information.