Pesticide Registrations Require You To Read Between The Lines

Pesticide applicators know the importance of reading a pesticide label to see: (a) if it is the right product for the job; (b) mixing directions for the spray tank and how much water or other diluent to use; (c) before applying the product to make sure the product can be used safely and properly; and (d) directions for storage and disposal of both unused product and containers.

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This article aims to help applicators understand the differences among Section 3, Section 24(c), Section 18 and 2(ee) recommendations. Actual pesticide labels for Coragen (rynaxypyr, DuPont Crop Protection) and Lorox (linuron, NovaSource) are included to illustrate points made in the discussion. Where there are differences among these labels, readers will be asked to find these differences on the exam.

Pesticides that most applicators use have a “Federal EPA,” or “Section 3” registration issued by the U.S. Environmental Protection Agency (EPA). Labels for Section 3 registered pesticides are divided into sections with most, if not all, of the following information:

(a) safety information: signal words, statements of practical treatment (first aid), hazards to humans and domestic animals, a child warning statement, and personal protective equipment (PPE);

(b) environmental information: environmental hazards, including potential threats to groundwater;

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(c) product information: use classification (whether the product is restricted use or not), brand or trade name, ingredients statement, net contents, EPA Registration Number, EPA establishment number, the name and address of the manufacturer, the formulation, physical or chemical hazards and a limited warranty and disclaimer;

(d) use information: directions for use, storage and disposal information.

The physical location of each of these sections on the label may be slightly different, depending on the product’s manufacturer. The list above helps explain why the labels for pesticides with Section 3 registrations are sometimes called a “full federal label.” Other types of labels or labeling may or may not contain all of this information, but users are always referred back to the Section 3 label for anything that is not included. All labels require EPA approval. A 2(ee) recommendation does not require approval since that is covered under Section 2(ee) of FIFRA (the Federal Insecticide Fungicide and Rodenticide Act).

•ºClick here to download and view a sample Section 3 label from a product which does not exist.

•ºClick here to download and see portions of a Section 3 Coragen label that correspond to the four sections described above.

There are two additional types of registrations: Special Local Needs (SLN) Registration, also known as Section 24(c) Registration; and Emergency Exemption, usually called a Section 18. These are discussed separately, with examples of each following the discussion.

Section 24(c)s (SLNs) are issued by the EPA for individual states or even for specific counties within a state. They are for specific problems (insect, disease) on a single crop, a crop grouping or several crops or for locally problematic weeds. These problems are not serious or do not affect other areas of the U.S., which is why a Section 24(c) is the appropriate registration. This registration is often permanent (it does not expire). With new pesticides, an SLN may have an expiration date, usually when the Section 24(c) uses are added to the Section 3 label.

•Click here to see a Section 24(c) for Coragen to control corn earworm on corn, soybean, sorghum and sunflower grown for seed production in Puerto Rico. Note that the registration number starts with the letters “SLN No.” and includes the state or territory abbreviation.

•Click here to see a Section 24(c) label for control of cottonwood leaf beetles on hybrid poplar in Oregon. Note the differences between this SLN label and the one for Puerto Rico.

Pointers For Pesticide Registrations

Section 18 registrations are for emergency situations for which there is no effective registered pesticide. A famous example was the emergency registration of fungicides to control soybean rust in Midwestern states. Soybean rust had never been found in the U.S., but university and USDA researchers were very aware of the potentially devastating effects of this disease on soybeans. When soybean rust did reach the U.S. on the winds of Hurricane Ivan, Midwestern states where soybean rust was found were able to implement emergency measures for its control.

For Section 18 (Emergency Exemption) registrations, the state agency in charge of pesticide registrations must submit a petition to the US EPA on behalf of the group which needs the Emergency Exemption. In Florida, this is the Florida Department of Agriculture & Consumer Services. Section 18s are valid for one year or less. They are for an individual state or an area within a state. If the pesticide is needed on a long term basis, the EPA requires that the use will be added to the Section 3 label. Since Section 18s are an emergency exemption to registration, they have an EPA File Number which includes the state’s 2-digit abbreviation.

In some cases, a trade organization such as the Florida Fruit & Vegetable Association (FFVA) may help growers get a Section 18. In that case, you must be an FFVA member to be able to use the pesticide for Section 18 approved situations.

•Click here to view a Section 18 registration for the use of Coragen for control of corn earworm on sweet corn in Pennsylvania.

•Click here to see a Section 18 label for the use of Lorox to control 2 weeds (mayweed chamomile and prickly lettuce) in lentils in specific counties in Idaho.

Remember, since these “special” registrations are associated with specific labeling, the applicator must have a copy of the Section 24(c) or the Section 18 label in addition to the Section 3 label when transporting, mixing or applying the pesticide. 

A fourth type of labeling that maybe used by pesticide applicators is a 2(ee) recommendation. This is the only label that does not require EPA approval since it is permitted under Section 2(ee) of FIFRA. It is issued by the manufacturer and includes more detailed information on how to use the product effectively in specific situations.

The following example of a 2(ee) recommendation is the use of Coragen(c) for control of Colorado potato beetle and cabbage loopers on potatoes in the states of Idaho, Nevada, Oregon and Washington.
•Click here to view it.

In summary, this article has reviewed the four major categories of pesticide registrations: Section 3, Section 24(c), Section 18, and 2(ee) recommendation. Section 3 registrations are what most applicators use in day-to-day operations. They are valid throughout the U.S. Section 24(c) registrations are also known as Special Local Needs (SLN) registrations because they cover uses of a pesticide in a specific state or individual counties within that state. They may apply to a single crop, a crop grouping or to several unrelated crops. Section 18 registrations are for true emergencies where there is no currently registered alternative. In this case the State Lead Agency, the FDACS in Florida, is ultimately responsible for submitting the petition to the EPA. 2(ee) recommendations are not true labels, but can be published by the manufacturer under Section 2(ee) of FIFRA. These give applicators additional instructions for using a pesticide for specific problems that are state or regional in nature.

The applicator is always required to have the Section 3 label and the Material Safety Data Sheet (MSDS) in his or her possession when using a pesticide. If he or she is using a pesticide with a Section 24(c), Section 18 or 2(ee) recommendation, that label must also be in the applicator’s possession.

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