Understanding Today’s Pesticide Labels

By Danielle S. Williams

Editor’s note: This article grants one continuing education unit (CEU) in the Core category toward the renewal of a Florida Department of Agriculture and Consumer Services restricted-use pesticide license when the accompanying test is submitted and approved. A minimum score of 70% is required to receive credit.

Pesticides are vital tools in agriculture that help protect crops from insects, weeds, diseases and other pests. However, the regulatory landscape surrounding pesticide use continues to evolve. In recent years, pesticide labels have undergone significant changes as the Environmental Protection Agency (EPA) has implemented new requirements aimed at protecting endangered species, reducing off-target movement, improving water quality and minimizing risks to applicators and the environment.

For many growers, pesticide labels have become longer and more complex than ever before. New concepts such as runoff mitigation, spray drift management, endangered species protections and Bulletins Live! Two (BLT) may be unfamiliar to applicators who have used pesticides for decades. Understanding these new requirements is critical because pesticide labels are legally enforceable documents. Failure to follow label directions can result in regulatory violations, crop losses, environmental impacts and potential liability.

As the saying goes, “the label is the law.” Today, that law includes much more than application rates and personal protective equipment (PPE). While many of the basic components of pesticide labels have remained unchanged, recent regulatory requirements have resulted in significant updates to pesticide labels. Many labels now include websites, and a website on a label counts just as much as the label. If the label is the law, then a website on the label is law, too! Understanding both the traditional and emerging components of pesticide labels is essential for today’s applicators.  

PRODUCT IDENTIFICATION

The front panel of a pesticide label contains important information used to identify the product. This section typically includes:

• Product or brand name
• Type of pesticide (fungicide, herbicide, insecticide, etc.)
• Active ingredient(s)
• Percentage of active ingredient(s)
• Inert ingredients
• EPA registration number
• Net contents

The product or brand name identifies the product and is prominently displayed on the front panel of the pesticide label. For example, in Figure 1, the brand name of the pesticide is Zivalgo. Different products may contain the same active ingredient but be marketed under different brand names.

The ingredient statement identifies the name, percentage and weight of each active ingredient. The active ingredients are the chemicals responsible for killing, repelling or controlling the target pest. In Figure 1, isocycloseram is the active ingredient. In addition to the active ingredients, the total percentage of inert or inactive ingredients will also be included on the label and are not generally identified.

USE CLASSIFICATION

The EPA classifies pesticides as either general use product/pesticide (GUP) or restricted-use product/pesticide (RUP). The classification is based on the toxicity of the product, how it will be used and the effect of the pesticide on the environment.

Restricted-use pesticides display the statement “Restricted Use Pesticide” at the top of the front panel in a clearly separated box.In Florida, only certified applicators or individuals under the direct supervision of a certified applicator may purchase and apply RUP pesticides.

CHILD HAZARD WARNING

The front panel of every pesticide label must have the statement “KEEP OUT OF REACH OF CHILDREN.”

SIGNAL WORDS AND SYMBOLS

Signal words indicate the relative toxicity of the product. The signal word is based on the entire contents of the product, not just the active ingredients. Signal words are:

• DANGER: Highly toxic
• WARNING: Moderately toxic
• CAUTION: Slightly toxic

Pesticides that are highly toxic and likely to cause acute illness through oral, dermal or inhalation exposure have DANGER as the signal word. They often include the word POISON printed in red along with the skull and crossbones symbol. In some instances, as seen in Figure 1, there is no signal word, indicating that the relative toxicity of the product is below the caution threshold.

FIRST AID

The first aid section of the label describes what to do if a person is exposed to the pesticide. Applicators should be familiar with this section before using a product, and it should be readily available in case of an emergency.

PRECAUTIONARY STATEMENTS

Figure 2 shows an example of the Precautionary Statements part of the label, and can include the following two sections:

1. Hazards to Humans and Domestic Animals – This section of the label includes precautionary statements indicating specific hazards, routes of pesticide exposure and precautions to avoid human and animal injury. Examples of statements in this section include:

• Harmful if absorbed through skin or swallowed
• Causes moderate eye irritation
• Avoid contact with skin, eyes or clothing

2. Personal Protective Equipment (PPE) – This section of the label contains specific instructions about the type of clothing that must be worn during the handling and mixing process. The required PPE may vary depending on the task. The PPE listed is the minimum protection that should be worn while handling the pesticide.

ENVIRONMENTAL HAZARDS STATEMENTS

This section of the label describes a product’s potential hazards to the environment, including soil, water, air, wildlife, fish and non-target plants. Traditional hazard statements still appear (e.g., “toxic to bees” or “toxic to fish”), but newly registered labels might contain additional environmental protection requirements designed to reduce environmental exposure and to comply with the Endangered Species Act (ESA).

For example, Figure 3 includes separate sections addressing surface water, pollinator protection and protection of non-target organisms. These instructions are enforceable label requirements and must be followed just like application rates and PPE requirements.

DIRECTIONS FOR USE

The bulk of the pesticide label is the directions for use section. It typically begins with the statement: “It is a violation of Federal law to use this product in a manner inconsistent with its labeling.” This section provides detailed instructions on how to correctly apply the pesticide, including application rate, timing, methods and frequency. It specifies the target pests, recommended application rates and the appropriate timing for application. Applying a pesticide to a site not listed on the label is illegal.

Products intended for use in agriculture will have an Agricultural Use Requirements box included in this section that will contain information related to the Worker Protection Standard (Figure 4). 

ENDANGERED SPECIES PROTECTION AND BULLETINS LIVE! TWO

One of the most significant changes to pesticide labeling is the integration of the ESA protections through the EPA’s Bulletins Live! Two (BLT) system. Many pesticide labels now contain directions requiring applicators to consult the system before making an application (Figure 5).

The BLT system is a web-based mapping tool that provides geographically specific pesticide use limitations designed to protect federally listed threatened and endangered species and their designated critical habitat. These bulletins may contain additional restrictions beyond those found directly on the pesticide label.

When a pesticide label references BLT, applicators must search using the product’s EPA registration number, identify the intended application area and select the month of application. The system then determines whether any additional restrictions apply within a designated Pesticide Use Limitation Area (PULA). These restrictions may include spray drift mitigation measures, timing limitations or prohibitions on use in specific locations.

Bulletins may be obtained up to six months before an application is made. When a pesticide label directs users to consult BLT, the resulting bulletin becomes enforceable labeling.

MANDATORY RUNOFF MITIGATION

Another new addition to many pesticide labels is the requirement for runoff mitigation. These requirements are part of EPA’s strategy to reduce pesticide movement intro streams, rivers, lakes, wetlands and other sensitive aquatic habitats. Many herbicide, insecticide and fungicide labels now contain mandatory runoff mitigation requirements. Rather than requiring the same practices on every field, EPA has adopted a point-based mitigation system for many products. Applicators must accumulate a minimum number of mitigation points before applying the pesticide.

Mitigation points can be earned through a combination of field characteristics and conservation practices already implemented on the farm. Examples include:

• Enrollment in the Florida Department of Agriculture and Consumer Services Best Management Practices program
• Maintaining vegetative filter strips or field borders
• Using cover crops

The pesticide label will specify the number of points required. Applicators can use EPA’s runoff/erosion mitigation calculator to determine which practices qualify and how many points each practice provides.

Because runoff mitigation requirements are enforceable labeling, applicators should document the mitigation measures used and maintain records demonstrating compliance. This tool will walk you through step-by-step regarding what points you can achieve based on your field location, field characteristics and growing practices. Once you are familiar and comfortable with this process, the EPA mitigation menu also has an Excel spreadsheet that might be more efficient.

SPRAY DRIFT MANAGEMENT

Spray drift has long been addressed on pesticide labels, but EPA has recently expanded and standardized spray drift language on many products. Spray drift occurs when pesticide droplets move off-target during application and are deposited outside the intended treatment area.

A new addition to the label is a dedicated “Spray Drift Management” section that includes mandatory requirements designed to minimize off-target movement. Depending on the product, these requirements may include:

• Restrictions on wind speed during application
• Required droplet size classifications
• Maximum boom heights
• Buffer distances from sensitive areas

Spray drift management requirements found on the label may be supplemented by additional restrictions obtained through BLT.

STORAGE AND DISPOSAL

Most pesticide labels will contain a general statement to the effect of “do not contaminate water, food, or feed by storage, disposal, or cleaning of equipment” and “store in original containers only.” This section of the label provides guidance on how to store the product safely, including temperature requirements, shelf-life and precautions to prevent contamination. It also outlines requirements for disposing of unused pesticides or empty containers to prevent environmental harm.

FINDING LABELS ONLINE

Before purchasing or applying a pesticide, applicators should review the most current version of the product label. While a label is always attached to the pesticide container, electronic copies are often easier to access and search.

One of the most widely used online pesticide label databases is the Crop Data Management Systems (CDMS) Label database. This free resource allows users to search for pesticide labels and safety data sheets by product name, active ingredient, manufacturer, crop, pest or state. Applicators can also access supplemental labels.

In addition to CDMS, the EPA maintains the Pesticide Product Label System, a searchable database of federally registered pesticide labels that can be searched by product name, company name, active ingredient or EPA registration number.

Many pesticide manufacturers will also host labels on their own websites.

BEST PRACTICES FOR GROWERS

To remain compliant with today’s pesticide labels, growers should adopt several routine practices:

• Read the label before every application.
• Verify the crop and pest are listed on the label.
• Review spray drift requirements.
• Review runoff mitigation requirements.
• Check for endangered species language.
• Determine whether BLT consultation is required.
• Verify PPE requirements.
• Document mitigation practices used.
• Maintain application and bulletin records.

Pesticide labels will likely continue to evolve. Regardless of how labels evolve, one principle remains unchanged: The pesticide label is the law. Taking the time to read, understand and follow label directions remains one of the most important responsibilities of every pesticide applicator.

Reference: “Applying Pesticides Correctly, 7^th Edition” by F. Fishel

Danielle S. Williams is a commercial horticulture agent with the University of Florida Institute of Food and Agricultural Sciences Extension in Quincy.

To request a hard copy of the article and test, or if you have questions regarding this article, test or CEUs, contact the author at dsprague@ufl.edu or 850-875-7255. Please allow two weeks to process your CEU request.