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EPA Updates Pesticide Label Review Manual

On April 24, 2018, the U.S. Environmental Protection Agency (EPA) announced that it has updated Chapters 3, 7, and 17 of the Pesticide Label Review Manual.  The three updated Label Review Manual chapters are:

  • Chapter 3:  General Labeling Requirements;

  • Chapter 7:  Precautionary Statements; and

  • Chapter 17:  Net Contents/Net Weight.

General Labeling Requirements (Chapter 3) changes include:

  • Updating web-distributed labeling by adding an example of container label directions;

  • Updating label submission requirements section to include e-submission methods depending on the type of application package (e.g., paper or electronic);

  • Adding a note that five copies of all draft labeling must be included in paper copy submissions for new registrations and amendments;

  • Updating the final printed labeling section to reflect current practices such as the practice of not requiring final printed labeling to be submitted to EPA until draft label texts have been provisionally accepted by the EPA;

  • Updating the Mode of Action (MOA) classification symbol reference from Pesticide Registration (PR) Notice 2001-5 to the current PR Notice 2017-1; and

  • Updating the first aid statement location per EPA’s February 27, 2018, guidance document “EPA’s Guidance for Pesticide Registrants on Location of the First Aid Statement per 40 CFR 156.68.”

Precautionary Statements (Chapter 7) changes include:

  • Adding dermal sensitization to the acute toxicity categories in Table 1;

  • Reinstating first aid statements per PR Notice 2001-1, and updating location of first aid statements per the Feb. 27, 2018, First Aid Guidance Document “EPA’s Guidance for Pesticide Registrants on Location of the First Aid Statement per 40 CFR 156.68”;

  • Adding “Contains the phosphine-producing active ingredient zinc phosphide. Probable mucosal damage may contraindicate the use of gastric lavage” as a Note to Physician for products containing zinc phosphide;

  • Updating the National Pesticide Information Center (NPIC) information in the first aid statements example in Table 9;

  • Changing “Labeling Options” section title to “Modified precautionary statements for diluted products (aqueous solutions only)”;

  • Removing redundant section on NPIC and referenced Chapter 15 for details; and

  • Removing “Optional Labeling/Deviations” section, as the directions moved to their respective sections.

Net Contents/Net Weight (Chapter 17) changes include:

  • Updating the introduction section to include notes on declaring net contents information on the EPA Application for PR Dorm (EPA Form No. 8570-1) and leaving net contents information blank on draft label for refillable containers; and

  • Updating the U.S. Department of Commerce’s National Institute of Standards and Technology’s (NIST) published “Uniform Laws and Regulations in the Areas of Legal Metrology and Engine Fuel Quality,” otherwise known as “NIST Handbook 130,” reference for Bag on Valve unit measurements.

Each updated chapter includes a new section identifying the changes in the updated version.  EPA states that it “also made editorial changes to all chapters, including updated cover pages; adding a table of contents; adding chapter editorial notes; updating hyperlinks; and reformatting text, style and layout for conciseness and readability.”

©2018 Bergeson & Campbell, P.C.

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About this Author

Healther Collins, Regulatory Consultant, Bergeson and Campbell, health and safety compliance
Regulatory Consultant

Heather F. Collins, M.S., Regulatory Consultant with Bergeson & Campbell, P.C. has nearly two decades of experience developing, implementing, and managing environmental, health, and safety (EH&S) compliance for global chemical and chemical product companies.  Her prodigious skills in developing biocide and pesticide registration and compliance strategies, safety data sheet authoring, and dangerous goods management, coupled with her keen awareness of the financial and temporal pressures of the marketplace make her an excellent resource for clients...

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