Pesticide Registration (PR) Notice 97-4: Consumer Access Numbers on Pesticide Labels
Notice To: Manufacturers, Producers, Formulators, and Registrants of Pesticide Products
Attention: Persons Responsible for the Registration of Pesticides
Subject: Consumer Access Numbers on Pesticide Labels
This notice describes EPA policy on including telephone
numbers and other access numbers, such as internet addresses, on
pesticide product labeling. The notice also explains how the
telephone number of the National Pesticide Telecommunications
Network (NPTN) hotline may be used on the label.
Addition of telephone numbers, including the NPTN phone
number) and internet addresses may be done at any time without
notification to EPA. EPA strongly encourages registrants to
include such information when labels are routinely reprinted.
Pesticide products are required to be labeled with the name
and address of the registrant. EPA does not currently require
that the label provide a telephone number so that users and
others can contact the registrant directly and immediately. EPA
does not require a telephone number because it appreciates that
staffing such a number and responding to inquiries can be an
expense that some companies may not be able to afford.
However, a number of registrants, particularly larger
companies, have voluntarily included a telephone number on the
label as a customer service. Direct access to the registrant
allows the company to provide immediate information or answer
questions on the pesticide product, its ingredients, and uses,
and to gain valuable information about user/consumer concerns and
perceptions. Some registrants provide a "hotline" (toll-free)
service, while others do not.
EPA, in conjunction with the Oregon State University, also
provides a hotline for public information on pesticides via the
NPTN. The NPTN dispenses objective scientific information on a
variety of pesticide topics, including pesticide toxicology,
health and environmental effects, recognition and management of
pesticide poisonings, laboratory analyses, clean-up and disposal
of pesticides, and emergency treatment information. The NPTN
also receives information from callers about pesticide incidents
and directs callers to the appropriate sources for pesticide
incident investigations. In cases of human and animal
emergencies, callers can be telephone switched directly into a
Poison Control Center from NPTN. Currently the NPTN operates
seven days a week, 6:30 am to 4:30 pm Pacific time. NPTN can be
A number of registrants have included the NPTN hotline
number on labeling, and, in some cases, EPA has required that the
number be included on labeling.
EPA believes that, although the label should be the
principal source of user information on a pesticide product,
users should have as many sources of information about pesticides
as possible. EPA is aware that users may not fully understand
labels, or may have additional questions or concerns after
reading the label. Being able to call directly to the registrant
that makes the product (or reach the registrant electronically)
may be a valuable source of information for some consumers.
II. CONSUMER LABELING INITIATIVE
In 1996, EPA began a Consumer Labeling Initiative (CLI),
which has as its goal the improvement of consumer labeling
(focussing on pesticide products). In the first phase of the
CLI, one-on-one interviews were conducted with users of household
pesticides (both indoor and outdoor) and pesticide and non-pesticide
cleaning agents. Consumers in these interviews indicated a desire
for telephone numbers on labels to access product and safety
information. The CLI Phase I report recommended that EPA also
explore other ways of making such information available to consumers.
This notice follows through on these recommendations.
A. Telephone numbers. EPA encourages registrants to
include a company telephone number or toll-free hotline number on
the pesticide label. If a number is included, it should include
a phrase or statement indicating the kinds of information the
number should be used for, or if it may be used for all
information, a simple lead-in phrase. The explanatory statement
may include hours of service. For example:
For information on [product usage, etc.],
call 1-800-555-0000, Monday through Friday,
9 am to 5 pm.
or, more simply,
B. Use of the NPTN hotline number. A registrant may
include on his labeling the NPTN hotline number, whether or not
he also includes a company number, using the following statement:
For information on this pesticide product
(including health concerns, medical
emergencies, or pesticide incidents), call
the National Pesticide Telecommunications
Network at 1-800-858-7378.
C. Internet homepages. EPA also encourages registrants to
include on the label an Internet homepage address at which
consumers may access information on a product. By making
information available electronically, a company may reduce the
volume of telephone calls that it receives. Registrants are
reminded, however, that individual product claims on a company
homepage must not exceed those approved by the Agency in
connection with the product's registration. Claims that exceed
those approved by EPA in conjunction with registration may result
in the product's being misbranded under FIFRA sec. 12.
D. Adverse effects information. Registrants are reminded
of their obligation under FIFRA sec. 6(a)(2) to report to EPA any
factual information regarding unreasonable adverse effects they
become aware of. Such information may be received through
consumer telephone calls or electronic access.
A registrant may at any time add or delete a registrant
telephone number, explanatory statement about the telephone
number, the NPTN hotline statement in III.B. or Internet
homepage address on a product label without notifying EPA
(a "non-notification" under 40 CFR 152.46).
VI. FOR FURTHER INFORMATION
For information on this notice, contact Jean M. Frane, Field
and External Affairs Division, at 703-305-5944, or by e-mail to
For information on the NPTN, contact Frank Davido,
Information Resources and Services Division, at 703-305-7576 or
by e-mail to Davido.Frank@epamail.epa.gov.
Daniel M. Barolo, Director
Office of Pesticide Programs