[Technician Training] Your Guide to Pesticide Labels and SDSs

The familiar phrase “Always read and follow all label directions” contains the most important words you will hear or read regarding the safe and effective use of pesticides. Reading the label is not a one-time event. Labels are frequently amended to add new pests, update regulatory requirements or make other changes that could affect how you use the product. It’s especially helpful to read the label when 1) purchasing a pesticide, 2) before you mix and apply the product and 3) before you store or dispose of the pesticide.

When you read, understand and follow label directions not only will you avoid accidents and be more effective at stopping pests, but you will be compliant with pesticide regulations. Under the Federal Insecticide, Fungicide and Rodenticide Act (FIFRA), it is illegal to use any registered pesticide in a manner inconsistent with its labeling.

Labels are written by pesticide manufacturers. They strive to provide clear label directions while maintaining flexibility so professionals can effectively use the product under their local conditions. Much of the language on labels is mandated by the Environmental Protection Agency. Thus, similar language is seen on the pesticide labels you use.

Pesticide labels and Safety Data Sheets (SDSs), formerly known as Material Safety Data Sheets (MSDSs), are sources of valuable information for professionals. The objective of this article is to help guide you through the key parts of the label and also provide basic information about SDSs. For our discussion, I divide the label into five major areas: product identification, product safety, use directions, storage and disposal, and warranty statement and conditions of sale.

1. Product identification. Product identification is where most professionals begin their review of labels. Pesticides are identified in several ways:

• Product Brand Name. The brand name or trade name is presented prominently on the front panel of the label. These names are selected by the manufacturer or formulator. Examples of brand names include: Suspend, Demand, Termidor, Transport, etc. Often the formulation type is also identified.
• Ingredients Statement. The active ingredient(s) must be listed on the pesticide label in the form of the approved common name and/or chemical name. Also listed are the other ingredients or inert ingredients in the product. The specific inert ingredients are not identified for proprietary reasons. The amount of active and inert ingredients is listed as a percentage by weight and will total 100 percent.
• Net Contents. The package size (pint, gallon, grams, etc.) is identified on the label.
• Name and Address of the Manufacturer. This information is often provided on the first and last pages of the label.
• EPA Registration and Establishment Numbers. An EPA registration number is assigned to an individual product registration. There may be more than one product brand name with the same EPA registration number. The establishment number identifies the facility where the product was produced.

2. Product Safety. Focus on the following three sections of the label for details on pesticide safety.

• Signal Word. A product’s signal word is listed in capital letters on the front panel of the label. Signal words provide the user a quick indication of the toxicity of the product. EPA uses acute toxicity test results to assign pesticides to toxicity categories. Signal words are assigned to each toxicity category (Cat. 1 – DANGER/DANGER POISON, Cat. II – WARNING, Cat. III – CAUTION, and Cat. IV – none required). Most products used by professionals have the CAUTION signal word.
• First Aid. Under this heading you will find first aid instructions for use in the case of accidental poisoning. Information also is given for physicians. If a specific antidote is available for the pesticide it will be listed in this section of the label.
• Precautionary Statements. The hazards to humans and domestic animals, the environment, and physical and chemical hazards are described under the Precautionary Statements heading. Details on personal protective equipment (PPE) required for use with the product are also found in this section of the label.

3. Use directions. The Directions for Use generally make up the largest section of the label. Most questions on label interpretation come from this portion of the label.

• Statement of Use Classification. EPA classifies pesticides as either “general use” or “restricted use.” Every product classified as restricted use must be clearly identified on the top front panel of the label as a Restricted Use Pesticide. General use products are not identified. Restricted use pesticide products only can be purchased by certified applicators.
• Directions for Use. The first words you read in this part of the label are: “It is a violation of federal law to use this product in a manner inconsistent with its labeling.” Under the heading Directions for Use, specific directions on how to best use the product are provided. This is where you find the pests controlled, sites where applications can be made, use rate(s), mixing directions, how to apply, when to apply and use restrictions. Use directions are written in “mandatory” and “advisory language.” One sure way to identify mandatory language is to look for the words “DO NOT” in the sentence.
  An example of a mandatory statement now appearing on pyrethroid labels is “Do not make applications during rain.” This gives clear directions to not apply while it is raining. Other Directions for Use are intended to provide guidance on the safe and effective use of the product. An example of advisory language now appearing on pyrethroid labels is this: “Applying this product in calm weather when rain is not predicted for the next 24 hours will help to ensure that wind or rain does not blow or wash pesticide off the treatment area.” This advisory statement does not prevent the applicator from making an application.

4. Storage and disposal. Important information on proper storage and disposal of the pesticide product and its container are found here.

5. Warranty statement and conditions of sale. This information is usually found on the last page of the product’s label. It provides legal language regarding the use of the product, liabilities and warranties. It’s advisable to read this section before using the product.

Safety Data Sheets. SDSs provide additional information about the pesticides you use. Unlike the label that is regulated by EPA, the SDS is required by the Occupational Safety and Health Administration (OSHA). Under its Hazard Communication Standard, all chemical manufacturers, distributors, and importers are required to provide SDSs to communicate the risks of hazardous chemicals (including pesticides). Recent changes to OSHA’s Hazard Communication Standard add new regulations and bring the U.S. into alignment with the United Nations’ global chemical labeling system (www.osha.gov/dsg/hazcom/HCSFactsheet.html). A change in terminology replaces the MSDS with SDSs. Existing MSDSs may be used until December 2015, but some manufacturers have already converted to the SDS.

Most of the data on SDSs are generated by manufacturers as they complete up to 120 studies required by EPA for registration of a new pesticide. Under OSHA’s new regulations, manufacturers are required to follow a standard format and provide pesticide information under 16 specific sections on the SDS. Many manufacturers were already following these guidelines, so major changes will not be seen on most SDSs. Information on SDSs that are not found on labels include: fire-fighting measures, accidental release measures, physical and chemical properties of the pesticide, toxicology, ecological, and transport information.

Call to action. I encourage you to review labels and SDSs for the products that you use. Make this a team effort. Technicians, more than anyone, must read, understand and follow label directions. Locate the various sections on the label and make sure that you understand the content. Also, become familiar with the information contained on the SDSs. If unclear about the meaning of the label language, contact someone that can help like the manufacturer, distributor or local regulator. Keep current with the latest labels and SDSs. And of course — always read and follow all label directions!

The author is owner of Yosemite Environmental Services, Fresno, Calif. Contact him at gbraness@giemedia.com.