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10
Jan

EPA Extends Public Comment Period on Cause-Marketing Pesticide Labels

(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, “The 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.” 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, “Dedicated to a Healthier World,” 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, “Studies 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.”  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, “The 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’s opinion and position that inclusion of such a symbol and organization name on a pesticide label would constitute misbranding.”

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 jfeldman@beyondpesticides.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.

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One Response to “EPA Extends Public Comment Period on Cause-Marketing Pesticide Labels”

  1. 1
    Barbara Kiernan Says:

    Based on my personal experience… and the current experience of my 93yo Mom… Clorox is one of THE most toxic cleaning agents in use. Rather than putting the American Red Cross symbol on their toxic product, they should be forced to put a LARGE skull and crossbones on the label. Clorox is so toxic to me that it is impossible for me to remain in the same room with someone who used bleach on their clothes… or in the room. As for my Mom, the heavy use of Clorox Bleach in the nursing home where she resides, has resulted in a sore throat, nasal drip and cough for 3 months… which the doctor is an allergy, NOT a cold. It is a disgrace for the American Red Cross to support such a toxic product… and the fact that they have a partnership w/ Clorox leads me to lose all faith in them.

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