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PPDC Consumer Pesticide Label Improvement Workgroup
Mission Statement
EPA is establishing the Consumer Pesticide Label
Improvement Work Group, under the auspices of the Pesticide Program Dialogue Committee,
to provide advice and recommendations regarding improvement of label language on
pesticide products intended for consumer use. The goals of the Consumer Pesticide Label
Improvement Program are two-fold. First, we want to improve consumer understanding of
safe use, storage, disposal and environmental and health information on household
pesticide product labels. Second, we want to design a Label Improvement Program that can
be easily implemented by EPA and the registrant community to ensure that the registration
transaction costs associated with label improvements is minimized.
This Labeling Improvement Program continues activities undertaken in the Consumer
Labeling Initiative (CLI) which began in March 1996. Under the Consumer Labeling
Initiative several recommendations were made. Many of those recommendations including the
“Read the Label FIRST” education program, presenting first aid information in
simplified formats, including a toll-free number, and using new revised First Aid statements
on consumer pesticide labels have been implemented.
However, there is still room for considerable improvement in label language for consumer
products. One of the CLI research conclusions was that improvements to the labels would
encourage more reading and use of product labels. The CLI recommended that “manufacturers
and the EPA, where possible, use simple language, avoiding jargon; ..... and eliminate needless
words.” In the Pesticides Program, much of the boilerplate label language has been
developed with the agricultural audience in mind. The technical nature of that language may be
essentially meaningless to consumers. An example would be: “Do not contaminate water when
disposing of equipment washwaters.” The technical aspect of such language may discourage
consumers from reading the entire label.
The charge to the workgroup is:
- Working with EPA and other stakeholders, identify problematic language used on consumer
pesticide product labels. The identified language may be boilerplate language suggested in
REDs for inclusion on labels or other standardized, frequently used phases.
- Prepare a menu of standardized alternative language and graphics, as appropriate, that
registrants may use on consumer products as an alternative to current technical
instructions. The new language/graphics should be easy-to-read information that connects
consequences with actions. The objective is to develop label directions that consumers
will read, understand, and follow, resulting in improved human and environmental safety.
The objective is not to make safety claims about any particular product.
- Recommend pesticide product criteria that can be used to limit use of proposed label
language to products sold exclusively/principally to consumers. Criteria could include
package size or other appropriate “consumer distinguishing”factors.
- Consider whether further consumer education initiatives should be designed to
increase the percentage of consumers who read pesticide product labels and follow the
use directions. Following the CLI recommendation, EPA has developed and implemented
the “Read the Label FIRST” campaign. However, we are aware that most
consumers do not read pesticide labels. For example, the Green Gauge Report indicates
that only 23% of Americans say they read pesticide product labels, down 4 points from
the previous year. The workgroup is encouraged to develop education materials, as
appropriate.
Advice and recommendations from the Consumer Pesticide Label Improvement Work Group will be provided to
the Pesticide Program Dialogue Committee for its review and deliberation prior to being given to the
Agency.
TIMING
A solicitation of workgroup members will be made before the October 2004 PPDC meeting. A
short presentation of the PPDC Consumer Pesticide Label Workgroup mission and identification
of workgroup members will be made at the October meeting. The Workgroup is requested to
complete its deliverables and present their findings at the next PPDC meeting which is
being scheduled tentatively for next Spring.
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