Pesticide Labels Are A Must-Read

You have heard and know that ‘The Label is the Law’, and that we are required to read it before we mix, load or apply products. Well, why should you have to read the label other than the fact that you are told to read them? The label is designed to give you all the information you need to properly and safely use the pesticide. However, the label is not designed to communicate potential long-term health hazards to those who use the products. To fully understand these potential hazards, there is another document that one needs to read, the Safety Data Sheet (SDS). Both the label and SDS document contain extremely valuable information related to the safe use of pesticides. You will look at some of the information available from each of these sources and see how it is beneficial to you.

The Environmental Protection Agency (EPA) defines the pesticide label as “The written, printed, or graphic matter on, or attached to, the pesticide or device or any of its containers or wrappers.”
The EPA  also clearly states: “Pesticide product labels provide critical information about how to safely handle and legally apply pesticide products. Unlike most other types of product labels, pesticide labels are enforceable, and all of them carry the statement: ‘It is a violation of Federal law to use this product in a manner inconsistent with its labeling.’ In other words, the label is the law.” (EPA, July 2011, p. 1-1).

The label directs the safe use of the pesticide. Some of the sections you will find on the label are:

• Signal word
• Active ingredients
• First aid / Statement of practical treatment
• Site information
• Resistance action group
• Personal Protective Equipment (PPE)
• Physical hazards
• Environmental hazards
• Use rate
• Storage information

I will look at each of these sections and point out the value and safety they can provide to you as you use the products.

Signal Word

The signal word is an indicator of the toxicity of the pesticide. In this on-line publication, read the “Acute Toxicity” section and review “Acute toxicity measures and warnings.” (Nesheim, Fishel, & Mossler 2014). Notice that the lower the LD50 value is the greater the toxicity the pesticide has.

The toxicity of a pesticide is divided into 4 categories and each has a signal word assigned to it. Category IV pesticides either don’t carry a signal word, or they may be labeled with the signal word Caution. Category III pesticides must have the signal word Caution, category II must have Warning, and category I must have either Danger or Danger/Poison with the skull and crossbones. From this table you can see that a pesticide product with the signal word Caution is less toxic than a product with the signal word Danger. Within this same publication read the section titled “Toxicity”, “table 2: Types of Toxicity,”and “How Toxicity is Measured” (all are on page 2).

In this section, you will find the term No-Observable-Effect-Level (NOEL). The NOEL is a measure of how much product (based on body weight of lab test animals) can actually be ingested over time without causing adverse health effects. An additional margin of safety (the Acceptable Daily Intake – ADI) is then calculated, usually at 1/100 of the NOEL. The signal word is prominently displayed on the label so that the user is aware of the toxicity level of the pesticide. This is vital information that you as an applicator need to know so that you understand the potential hazards when using the product.

Active Ingredients

The contents area of the label will give the list of active ingredient(s) and the inert ingredient(s) expressed as their percentage of the formulation. Here you should find the common name of the material. There are a few exceptions, if you cannot find a common name then check section 4 of the products SDS. The common name allows you to compare apples to apples since some chemicals (active ingredients) are in a multitude of different brand name products. Many chemicals have limits on the amount that can be used in certain site and/or crop situations. Also, be aware that similar pesticides with different brand names may carry the same active ingredient, but the products are labeled for different target site/crop scenarios. Often these similar pesticides either have slightly different chemistries or the active ingredient is contained at a different concentration. For this reason, just because pesticide X and pesticide Y advertise the same active ingredient, you must not assume that you can use either pesticide interchangeably for your target site/crop.

Similarly, maximum use rates apply to the active ingredient not the brand name product. If you use different brand name products that are labeled for your site/crop there is a chance you could over-apply the active ingredient. These kinds of mistakes can lead to illegal applications and/or an illegal active ingredient application rate. There is a possibility that you could be forced to destroy your crop. You need to be aware of the concentration of active ingredient in each product you use so that you do not accidentally over-apply a pesticide to your crop. The pesticide label will provide all of the specifics as to which site/crop is allowed for that product.

First Aid/Statement Of Practical Treatment

You may see either of these headings on the labels of pesticides you use and they mean the same thing. This is the area that will tell you how to take care of yourself after being exposed to a pesticide. If you have accidentally swallowed some material, do you induce vomiting? Look at this section on the label and follow the directions. For examples of first aid statements, read section 3 titled “Statement of Practical Treatment” (page 2) from this on-line article: http://edis.ifas.ufl.edu/pdffiles/PI/PI07100.pdf (Fishel, 2013).

From this information, you should see how it is important to your health to know where to look for help.

Site Information

This is the information that will let you know where the product can be used. It is illegal to use a pesticide product on a target site that it is not listed on the label (it is not registered for). Below is a question/answer discussion from the EPA website (EPA. 2014) that seeks to clarify interpretations for the site information found on the pesticide label:
Client question: Can a fungicide be applied to an ornamental species not listed on the label to control a target disease listed on the label?
EPA answer: If the product label lists only specific ornamental species, then only those species are the labeled use sites (crops). If however, a label should state: “For use on ornamentals, such as [listing of several specific species].”, then the product could be used on all ornamentals.

Client question: Can a fungicide be applied to a food crop species not listed on the label to control a target disease listed on the label?
EPA answer: Regarding food crops, we must consider established tolerances for the active ingredient pesticide. A pesticide label will only list food crops for which a tolerance or an exemption from the requirement of a tolerance has been established. Sometimes, if a crop grouping has an established tolerance or exemption from tolerance, the label might list the crop group, for example, “For use on stone fruits, such as cherries, nectarines, peaches and plums.” This would allow for the product’s use on all crops in the stone fruit crop group for which a tolerance or exemption had been established. Therefore, if the label does not list a crop group, then application of the pesticide product is limited to only those food crop species listed on the label.

Based on these EPA responses to client questions, it is important to pay close attention to the site information from the pesticide label and make sure you are correctly interpreting the provided information. Once again, misapplying a pesticide to your crop could result in your crop being destroyed.

Resistance Action Group

This number is included on some labels and EPA encourages that it be included but does not make it mandatory. If placed on a label, it will be in the upper right corner on the front of the label. Committees of scientists have studied pesticide modes of actions in order to organize them into active ingredient groups that have similar modes of actions. A Resistance Action Group number is then assigned to each pesticide based on mode of action. You need this information so that when you have to use multiple pesticides in a growing season, you can simply look at the group number and make sure that the next pesticide that you use has a different number. During the seasonal control of pests, switching between different modes of action is extremely important to the agriculture community in order to prevent the build-up of pest populations that are resistant to a specific active ingredient. Since the EPA does not require the numbers to be on a label, I have included the websites for the different resistance action committees in the Additional Information section at the end of this article. I have also included the link for the insecticide resistance action committee’s poster with the different insecticides grouped by their mode of actions.

Personal Protective Equipment (PPE)

The section that covers PPE is vital to you as you prepare to use a pesticide. The signal word has communicated the relative toxicity of the product, and now the PPE is listed so you will know what you need to wear as you use the pesticide. Be aware that the specific materials used in the construction of PPE, especially gloves, vary in their ability to resist the chemicals in different pesticides. The material that protects you while using one pesticide may offer no protection when using another pesticide. With this in mind you should pay very close attention to the labels on the pesticide you are using. The label will list the materials the PPE is made from that are resistant to the pesticide and are acceptable for use. You should make sure the gloves you are using are made from one of the materials listed on the product label. Please see EPAs chemical resistant chart to understand more about why you should not use some materials for PPE, such as gloves, with some pesticides. Make sure you see their definitions for high, moderate, slight and none as they relate to resistance in the chart. Click here for a link to the chart. (Cornell, n.d.).

Physical Hazards

If a pesticide has an unusual physical hazard such as it is flammable, an oxidizer, or some other chemical hazard, the label will let you know. You need this information so that you will be properly prepared to handle the pesticide safely. If you don’t know that the product is flammable and you smoke or have other another ignition sources nearby, you could cause a fire resulting in personal or property damage. Later in this article when we cover the SDS, you will see that the SDS will give you much more information on the physical properties of a pesticide.

Environmental Hazards

As we learn more and more about how important and interrelated the environment is we also learn more about the dangers pesticides can pose to the environment. Labels will have a section that will list the hazards to the environment if the product is not used carefully. One of the main issues that we have heard a lot about lately is that the populations of bees and other pollinators are declining. Labels carry a small bee icon to indicate when certain products are hazardous to pollinators. In the “Additional Information” section, I have included the EPA best management practices (BMPs) for pollinator protection and the Florida Department of Agriculture and Consumer Services information for growers to help protect bee populations. Along with pollinators water is an area of critical concern. Florida thrives due to the water we have in and around our state. Misuse of a pesticide can impact the water quality in an area and should be avoided. Labels will indicate if a product is likely to leach through the soil. EPA requires this statement to be on products that may leach: “This chemical has properties and characteristics associated with chemicals detected in groundwater. This chemical may leach into ground water if used in areas where soils are permeable, particularly where the water table is shallow.” (EPA, 2012, p. 8-6) By being armed with this information you can make good sound application decisions. Included in the Additional Information is a link from EPA on protecting the environment.

Application Rate

The chemical manufacturer spent a lot of time and research calculating the correct application rates of the product in certain situations and use sites. The label prohibits uses greater than allowed on the label. It however does allow lower rates. You must be careful to use the correct rates. If you use incorrect rates, you could jeopardize your crop and possibly that of future crops. Rates are sometimes given in ranges depending on the site characteristics. If your product does have different rates, make sure you understand the correct rate for your specific location. Your chemical representative or the Extension service should be able to help you if you have questions about your specific situation. A paper from the Institute of Food and Agricultural Sciences (UF/IFAS) by Fishel is included in the Additional Information for more information on how rates are set.

Storage Information

This section of a label usually carries a generic statement similar to this “Do not contaminate water, food, or feed by storage or disposal.” Your storage of a product could affect the ability of the material to work properly when you use it. Florida does not get too cold too often, but a lot of pesticides indicate that they should be protected from freezing. If your storage area might freeze, you should give these products some extra protection. You will see a statement about storing the pesticide in the original container.

Although this may sound simple enough, if you do have to use another container due to an emergency, it should be clearly labeled. Attach the old label or a copy of a label to the temporary container. Use this material as soon as you can. Never store any pesticide in a beverage or food container, or any container that looks like it was designed for food or beverages. Many people have accidently drank pesticides because the color of some pesticides can easily be mistaken for a beverage.

Many of you are familiar with the Material Safety Data Sheet (MSDS) associated with different pesticide and chemical products. Be aware that these MSDS documents are undergoing revisions and now SDS is the preferred term. These SDS documents still contain the same information but they are designed to be more consistent with the newly adopted Globally Harmonized System (GHS). The GHS revision is designed to let those who encounter the materials to know the true hazards and how to be able to deal with them. All hazardous chemicals are required to have an SDS. GHS is a process many countries are going through to make sure the information on the SDS is understood the same way by chemical and pesticide users in different countries. Employers were required to have trained their employees on the new GHS by Dec. 1, 2013.

An SDS document for a specific pesticide will likely repeat some pesticide label information but also contains expanded information that pesticide handlers and applicators need to know. In the Additional Information section is an OSHA web page with information on its hazard communication standard and safety data sheets as well as a paper from IFAS on the SDS. Along with some of the same information found on a label look for extra information on the SDS such as:

• Physical hazards
• Toxicological information
• Long-term health information
• Transportation information
• Regulatory information
• Product contents

Physical hazards

The SDS will have a lot more information than the label on physical hazards the product may have. Sections 5, Fire-Fighting Measures, and 9, Physical and Chemical Properties, of an SDS should provide some information that will give you a good indication of the flammability hazard of the chemical. In Section 5 you will find what should be used to fight a fire along with the National Fire Protection Association (NFPA) ratings, a rating of overall hazards. If you want to know more about the NFPA rating system see the website in Additional Information below. It does a good job of explaining the colors and what the numbers mean in this rating system. Section 15, Regulatory Information, may also contain the NFPA information. Section 9 provides you with the pH of the product, the auto ignition temperature, lower and upper explosive limits (if conditions are inside these limits you are in extreme danger), and many more descriptors of the product.

Toxicological Information

This is one section that every employee that uses a pesticide should make sure he/she reads. It provides the information of what can happen to them after a major exposure event or after a long career of small exposures. In section 11, Toxicological Information, you are given the information that is used to determine how toxic the pesticide is. You can get a better idea from the SDS what toxicity is per route of exposure. We know that the skin is the part of the body that is most likely to be exposed, but the toxicity from different routes of exposure is rarely the same.

Long-Term Health Information

This is also found in Section 11 and lets you know if the material may cause carcinogenicity (cancer), mutagenicity (a mutation), reproductive toxicity (may interfere with male or female reproduction or development of children), neurological effects (may cause problems with the nervous system), or developmental toxicity (may cause problems with your children developing correctly). This is information that anyone that uses chemicals should read for obvious reasons. Careless actions over a career of pesticide use can have life altering consequences.

Transportation Information

Found in Section 14, transportation information is given to determine if you need to mark your load and the markings for those loads that need it. This information is mainly for the first responders in case of an accident. It helps them protect everyone near an accident along with themselves. When you or your company has the correct information displayed you are complying with DOT and helping to protect the environment and those around you.

Regulatory Information

In Section 15, regulatory information is provided. This information lets you know if you need to report that you store or transport certain quantities of chemicals. You will not find this information on the label. The SDS will give you the hazardous chemicals in the pesticide and the chemical abstracts service number (CAS) for that chemical. This is a unique number given to chemicals and greatly aids in searching for certain information. You can take the CAS number from the SDS and see if the product you are using has regulatory reporting requirements. There are several federal regulations that you may be subject to due to your usage of pesticides (Fishel, 2012). Dr. Fishel’s document ‘Federal Regulations Affecting Use of Pesticides’ is included in the Additional Information section.

EPA provides a document called the ‘List of Lists’ that list most all of the chemicals that have reporting requirements. This is a valuable list to have and use to make sure that your company is in compliance with the laws. The link to the ‘List of Lists’, where you can down load either a PDF or Excel format, is included in the Additional Information section.

Product Contents

A very important point is that the SDS will give you all of the chemicals that are considered hazardous even if they are not the active ingredient. Remember that the label only gives you the active ingredient and states the remainder as ‘inert’. This information will be invaluable to as you check to see if there are any federal regulations you may have to comply with because of the pesticide you are storing and using.

Always read and follow the label. It has all of the information that you need to properly use the product. The SDS is produced to make sure those who use hazardous chemicals have all of the hazard information available for a product.

Additional Reading

• http://oeh.cals.cornell.edu/EPAChemRes.html (Cornell, n.d.)
• http://edis.ifas.ufl.edu/pdffiles/PI/PI07100.pdf (Fishel, 2013)
• http://edis.ifas.ufl.edu/pdffiles/PI/PI00800.pdf (Nesheim, Fishel, & Mossler, 2014)
• Prowl H2O Herbicide Label http://www.cdms.net/ldat/ld6CT010.pdf
• Prowl H2O Herbicide SDS http://www.cdms.net/ldat/mp6CT005.pdf

Additional Information

The following links are for informational purposes and are not required reading. If you desire to learn more about these concepts on the label and SDS, review the links below.

Label

• Signal word

Resistance action group

• Fungicides
• Herbicides
• Insecticides
• Rodenticides
• Insecticides grouped by their mode of actions
• Herbicides grouped by their mode of actions

Environmental hazards

• EPA’s website for protection of pollinators
• FDACS growers and bee protection
• EPA’s suggestions for all pesticide users

Use rate

• UF/IFAS document with information on rates

SDS

• OSHA information on the Hazard Communication Standard and SDS
• Information on SDS from UF/IFAS 

Physical hazards

• NFPA ratings

Regulatory information

• EPA’s List of List
• UF/IFAS document on hazardous laws
• UF/IFAS document on hazardous waste

References

• Cornell. (n.d.) EPA Chemical Resistance Category Selection Chart.
• EPA. (2011, July). Label Review Manual. Chapter 1: Purpose of the Manual.
• EPA. (2012, September). Label Review Manual. Chapter 8: Environmental Hazards.
• EPA. (2014, April 7). Pesticides: Regulating Pesticides. Pesticide Labeling Questions & Answers – Miscellaneous.
• Fishel, F. M. (2012, August) Federal Regulations Affecting Use of Pesticides.
• Fishel, F. M. (2013, February) Interpreting Pesticide Label Wording.
• Nesheim, O.N., Fishel, F.M., & Mossler, M. (2014, January). Toxicity of pesticides.

The use of trade names in this article is solely for the purpose of providing specific information. UF/IFAS does not guarantee or warranty the products named, and references to them in this publication do not signify our approval to the exclusion of other products of suitable composition.