Reading the Product Label: Why It’s Critical Cecil Tharp MSU Pesticide Education Program Bozeman, Montana 2016 edition

The pesticide product label is the law!  Requirements not suggestions. Any other reasons to read the product label?

Reading the product label can help you! *It can minimize risk towards yourself or your family.

Where is the label? Labeling Add’l info provided by manufacturer - leaflets - flyers - pamphlets Attached to the container

EPA Approval for Labeling  No pesticide may be sold in the US until the EPA has approved the product. Product will not present unreasonable risk to humans and the environment

 Brand Name Trade Name Ingredient Statement Common name or AI Lists % Active and Inert

Pesticide Classification  Restricted Use Pesticides (Pesticides which may cause potential adverse effects on the environment, non- target animals or applicators)

EPA Registration Number (identifies the manufacturer, product, and distributor)

Precautionary Statements  How to protect: You Others Employees  Hazards (signal word)  Statement of Practical Treatment  PPE  Physical or Chemical Hazards

Signal Word?

Signal Words / LD50  Caution (Category IV)  You can drink the stuff Table 2. Signal words found on pesticide labels.

PPE What Part of the Label Should He Read and Follow?

Practical Treatment (First Aid)

Agricultural Use Requirements Do your workers need to suit up 10 hr after an application?

Maybe. Depends on the restricted entry interval (REI)!! In this instance. They would need the PPE labeled in the agricultural use box.

 The requirements apply to uses within areas such as lawns, golf courses, ornamental plantings, structures, aquatic areas, and rights of way.  Not all labels have non-agricultural use requirements Non-agricultural Use Requirements

Why is Tordon 22K a restricted use pesticide? This relates to the Environmental Hazards

Environmental Hazard Statements

Environmental Hazard Statement  Special Toxicity Statements: Extreme hazards towards bees, fish, invertebrates, birds or wildlife.  General Toxicity Statements: Do not apply when bees are likely to be in areas Do not apply when runoff is likely to occur The use of this chemical in areas where soils are permeable, particularly where the water table is shallow.

Storage and Disposal Statement

Brand Name Ingredients EPA #’s Signal Word First Aid PPE User Precautions Environmental Hazards

Directions for use….  Label will tell you Pests the manufacturer claims the product will control. The crop, animal, or site the product is intended to protect. The proper mixing instructions. How much to use (rate) and how often. Restrictions  Pre-harvest intervals, grazing restrictions, composting restrictions, recropping re

Sites Timing of Application Application Equipment What not to do

Mixing

Scenario’s to Consider when Reading the Label

Pollinator Impacts  Scenario #1: Applicator applies insecticide to early bloom alfalfa (alfalfa weevil). Neighbors honey bee colony is impacted. Q1. Is the applicator liable, or is the honey bee trespassing?

Applicator is Liable!!  Often missed: The Environmental Hazards Statement on the Label.  The Label is the Law. Litigation is common so read the pesticide product label ‘environmental hazard statement’.

Other Non-target Impacts and Restrictions  Scenario #2. Private applicator applies Milestone®VMPLUS (aminopyralid) for management of weeds prior to grazing livestock. Manure was later collected and sold as a soil amendment for gardens, etc. Soil amendment was later implicated in damage in gardens and nurseries at various locations across the state. Is the applicator liable for non-target injury in gardens?

Applicators often skip the Use Restriction Statements  Applicator is liable. Didn’t follow ‘Use Precautions and Restrictions Statements’  This statement includes grazing, cropping, and manure restrictions, etc..

These restrictions can be hard to find. Milestone restrictions now easy to find due to issues. Not the case for other pesticides.  Do not use grasses treated with MilestoneflVM Plus in the preceding 18-months for hay intended for export outside the United States.  Hay from areas treated with MilestoneflVMflPlus in the preceding 18-months CAN NOT be distributed or made available for sale off the farm or ranch where harvested unless allowed by supplemental labeling.  Hay from areas treated with MilestoneflVMflPlus in the preceding 18-months CAN NOT be used for silage, haylage, baylage and green chop unless allowed by supplemental labeling.  Do not move hay made from grass treated with MilestoneflVMflPlus within the preceding 18-months off farm unless allowed by supplemental labeling.  Do not use hay or straw from areas treated with MilestoneflVMflPlus within the preceding 18-months or manure from animals feeding on hay treated with Milestone in compost.  Do not use grasses treated with MilestoneflVM Plus in the preceding 18-months for seed production.

Which is illegal?  You have a pesticide product labeled only for aphids on spring wheat. Scenario #3. Can you use this product to manage aphids on alfalfa?  Yes! Section 2(ee) of FIFRA allow that a pesticide may be applied against any target pest not specified on the label. Often not a good idea but legal.  Written bulletins or recommendations are not required. Scenario #4. Can you use this product to manage grasshoppers on wheat?  No!; Section 2(ee) doesn’t allow the application of a pesticide on a site not written on the label.

Pesticide Labels – do’s and don’ts  You may use lower dosages lower concentrations less frequent applications on different pests  You may not use higher dosages higher concentrations more frequent applications on different site locations

Story Problem

Contact Information Cecil Tharp Pesticide Education Specialist