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.

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;

(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.

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