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Take Action: EPA Seeks Feedback on New Pesticide Labeling Guidance

(Beyond Pesticides, September 15, 2010) On September 1, the U.S. Environmental Protection Agency’s (EPA) Office of Pesticide Programs (OPP) unveiled “Enable the Label,” an online discussion forum established to facilitate the exchange of information and ideas related to the labeling of pesticides. EPA will facilitate a monthly discussion focusing on one or two chapters of the Label Review Manual, an educational tool for understanding the pesticide labeling process. Beyond Pesticides has criticized EPA’s pesticide labeling program in the past for not providing full disclosure on potential health and environmental effects, ingredients and breakdown products, data gaps and other missing information.

Each month several questions will be posed for discussion and the public is welcome to post thoughts and ideas on the topics and provide feedback on any other subject covered in that month’s chapter. According to EPA, the goal is to improve the clarity and usefulness of the Label Review Manual for its users – primarily people who draft, review, or enforce labels in the field. Pesticide manufacturers and their representatives, State pesticide regulators, and pesticide users are expected to be interested in participating in EPA’s new “Enable the Label” online discussion forum. The Label Review Manual is a tool for understanding the pesticide labeling process. It is a collection and plain English explanation of existing pesticide labeling policy, regulations, and statutes.

The inaugural “Enable the Label” discussion will solicit ideas related to Chapters 1 and 2 of the Manual. Discussion threads covering these chapters will be open for comment and discussion for 30 days. Subsequently, EPA will move through the manual by individual chapter or small groups of chapters, each open for comment for 30 days. OPP will review comments received and incorporate useful ones into future revisions of the Label Review Manual. However, the agency refuses to allow the forum to be a place to debate or take comment on existing laws, regulations or general discussions on pesticide policy issues.

For this discussion focusing on the Label Review Manual, EPA is seeking comments or suggestions in the following areas:

• Text that can be improved;
• Examples that could be improved or replaced with better ones; and,
• New scientific or policy developments that have occurred since the chapter was last updated.

EPA hopes that “Enable the Label” will provide informal comment opportunities to everyone interested in improving the Label Review Manual, and encourage creative solutions to complex pesticide label challenges. The Manual’s chapters discuss label claims, ingredient statements, labeling requirements, direction for use, etc.

EPA has been exploring and developing ideas to improve the pesticide labels. Currently, as part of a series of initiatives to improve pesticide labeling, EPA is working with external stakeholders to design a new system for delivering product labeling to pesticide users. The new approach, which could largely replace the paper-based system, will rely on users to contact either an official pesticide labeling website or a toll-free telephone number from which they can obtain the detailed use instructions that previously were attached to the product container. EPA is also inviting organizations to work with the agency to conduct a “User Acceptance Pilot” to research the extent to which pesticide users would accept a system requiring them to obtain labeling via the internet. EPA hopes that web-distributed labeling would only provide instructions for the location and intended use that the pesticide user specifies online.

If such a system was ultimately implemented, EPA expects faster access to new pesticide uses, quicker implementation of public health and environmental protective measures, and lower costs for industry and EPA. However, there are many shortcomings of web-distributed labeling such as lack of internet access to many farmers -especially poorer farmers, limited language options and possible increased lack of compliance. Generally, pesticide labels have a low level of compliance, meaning that consumers and pest control operators do not properly follow label directions, leading to increased exposures to toxic chemicals, injury and even death.

In the past, EPA has maintained that pesticide labels should, on the whole, be free from any symbol or claim that might mislead consumers or give a false sense of a product’s safety. Crackdowns concerning the sale and distribution of unregistered, mislabeled pesticides have occurred in the past, with EPA maintaining that this is a serious violation that can result in harm to public health and the environment. However, EPA enforcement against non-compliance is generally very limited. Limited label information, including the non-disclosure of inert ingredients, also provides consumers with little information with which they can make informed decisions when buying pesticides and choosing less hazardous products.

Take Action: Submit your comments and comment on chapters 1 and 2 of the Label Review Manual at blog.epa.gov/enablethelabel. Focus areas for these chapters include:
Products That Are Not Pesticides. This section focuses on products that are not considered pesticides if they are labeled for use only in or on living man or animals (Chapter 2, Section II C 1). What improvements can you suggest?
Plant Nutrients vs. Plant Growth Regulators.This text attempts to clarify the difference between nutrients and growth regulators (Chapter 2, Section II E). How could this section be improved (e.g. better or additional examples)?
Products That Are Exempt from Registration. This section offers a detailed discussion of products exempt from registration (Chapter 2, Section IV).

Source: EPA News Release


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