Label Review Manual
Chapter 3: General Labeling Requirements

• A. Definition of "Label" And "Labeling"
• B. Container Label Contents When Booklets Are Used
• C. Collateral Labeling
• D. Material Safety Data Sheets (MSDSs)

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I. Introduction

This chapter addresses "labels and labeling,” labeling submission requirements, the sample label format, and guidance concerning specific label requirements versus preferred label language.  The sample label format which appears at the end of this chapter is designed to illustrate the typical arrangement of information on a pesticide label.  General labeling requirements can be found in 40 CFR 156.10. Additional examples of sample label formats for Consumer Products, Non-Restricted Use Pesticides, and Restricted Use Pesticides with Worker Protection language can be found at the end of this chapter.

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II. General Information

1. Definition of “Label” And “Labeling”
   
   FIFRA section 2(p) defines the terms as follows:
   1. Label. The term "label" is defined as “the written, printed, or graphic matter on, or attached to, the pesticide or device or any of its containers or wrappers.”
   2. Labeling. The term "labeling" is defined as “all labels and all other written, printed, or graphic matter:
      1. accompanying the pesticide or device at any time; or
      2. to which reference is made on the label or in literature accompanying the pesticide or device, except to current official publications of the Environmental Protection Agency, the United States Departments of Agriculture and Interior, and the Department of Health and Human Services, State experiment stations, State agricultural colleges, and other similar Federal or State institutions or agencies authorized by law to conduct research in the field of pesticides.”
         
         
2. Container Label Contents When Booklets Are Used
   
   Registrants are allowed to provide part of the label text in the form of a booklet or other “pull off” type labeling, when it is not feasible or possible to literally “fit” the entire label on the container.  However, pursuant to the regulations set out at 40 CFR part 156, Subpart A, the following label information must be on the label which is on or “securely attached” to the container.
   
   
   • Name and address of the producer, registrant, or person for whom produced
   • Restricted Use Statement (if required)
   • Product Name, Brand or Trademark
   • Ingredient Statement
   • Signal Word, including Skull & Crossbones, if either are required
   • "Keep Out Of Reach Of Children" (KOOROC)
   • Precautionary Statements, including Hazards to Humans & Domestic Animals and Environmental Hazards
   • EPA Registration Number and EPA Establishment Number
   • Either Directions for Use or a Referral Statement to Directions for Use in booklet, if any
   • Net weight or measure of contents

   “Securely attached” means the label can reasonably be expected to remain affixed during the foreseeable conditions and period of use.  40 CFR 156.10(a)(4).
   
   Other parts of the label may be placed in a booklet or other “pull off” type labeling.  At a minimum, the booklet or “pull off” labeling should include the following:

   • Name and address of the producer, registrant, or person for whom produced
   • Restricted Use Statement (if required)
   • Product Name, Brand or Trademark
   • Signal Word, including Skull & Crossbones, if either are required
   • "Keep Out Of Reach Of Children" (KOOROC)
   • Precautionary Statements, including Hazards to Humans & Domestic Animals and Environmental Hazards
   • EPA Registration Number and EPA Establishment Number

   The Agency’s regulation requires that words, statements, graphic representations, designs or other information that are legally required to appear on a label be clearly legible, and readily understood by the ordinary individual.  In addition, all required label text must be set in 6-point type or larger, appear on a clear contrasting background, and not be obscured or crowded.  40 CFR 156.10(a )(2)

3. Collateral Labeling
   
   Bulletins, leaflets, circulars, brochures, data sheets, flyers or other written, printed or graphic matter which are referred to on the label or which are to accompany the product are known in Agency practice as “collateral labeling.”  Such labeling is subject to applicable requirements of FIFRA and the Agency’s regulations.  Collateral labeling may not bear claims or representations that substantially differ from those accepted in connection with registration of the product. FIFRA 12(a)(1)(B).  Collateral labeling must be submitted along with the application for registration and must be accepted by EPA before it can be distributed.
   
   
4. Material Safety Data Sheets (MSDSs)
   
   The Occupational Safety and Health Administration (OSHA), and not the Agency has direct authority over MSDSs.  However, when an MSDS is distributed with a pesticide it becomes a part of the pesticide labeling FIFRA 2(p)(2)(A).  Because an MSDS becomes part of the labeling, an MSDS could render the pesticide misbranded if the MSDS includes warnings, precautions or any other information that conflict with the FIFRA-approved label. FIFRA 2(q).  The registrant must ensure that the MSDS that accompanies the product is not inconsistent with the approved labeling.  In the event of inconsistency the registrant may need to either seek approval of labeling changes from EPA or change the MSDS (PR Notice 92-4).
   
   Although an MSDS which accompanies a pesticide product is considered to be labeling, EPA required statements cannot be placed solely on the MSDS instead of the label.  The Agency does not review or accept (stamp) MSDSs.  The Agency may refer to a product’s MSDSs to extract certain information such as the product’s physical/chemical properties or composition.

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III. Mandatory and Advisory Statements

1. Mandatory Statements
   
   Mandatory statements generally relate to the actions that are necessary to ensure the proper use of the pesticide and to prevent the occurrence of unreasonable adverse effects on the environment, which is defined by statute.  Mandatory statements include directions for use and precautions that direct the user to take or avoid specific actions.  The directions and precautions specify where, when and how a pesticide is to be applied.  Mandatory statements are generally written in imperative or directive sentences (e.g., “Wash application equipment...,”  “Do not use ...,”  “Users must...,” “Apply to corn at a maximum rate of one to two pounds per acre 30 days prior to harvest.”).  When the intent is to prevent an adverse effect from some action, it is always preferable to use a clearly mandatory phrase such as "do not...", rather than to allow the word "avoid", e.g., “Avoid applying this product…”  This language may be perceived as only advisory (not mandatory) by some users.
   
   Either EPA or the registrant may develop mandatory labeling statements.  When writing mandatory statements, both EPA and the registrant need to ensure that such statements are necessary to ensure proper use of a pesticide and to prevent unreasonable adverse effects.  The following directions and precautions are examples of mandatory statements:
   
   

   “Wear chemical resistant gloves.”

   “If swallowed, call a doctor.”

   “Do not induce vomiting.”

   “Do not apply within 66 feet of wells.”

   “Do not apply directly to water.”

   “Keep away from heat, sparks and open flame.”

   “Do not enter into treated areas for 12 hours.”

   “Apply immediately after mixing.”

   “Do not apply when wind speed exceeds 15 mph.”

   
   
2. Advisory Statements
   
   Advisory statements provide information to the product user on such topics as product characteristics and how to maximize safety and efficacy while using the product.  Such statements are acceptable as long as they do not conflict with mandatory statements, and are not false or misleading, or otherwise violate statutory or regulatory provisions.
   
   

   Advisory statements are best written in descriptive or nondirective terms.  Phrasing advisory statements in straightforward, factual terms minimizes the possibility that they will conflict with mandatory statements.  The use of certain words such as “should,” “may” or “recommend” in advisory statements has the potential to lead the product user to erroneously believe that he/she must comply with such statements, when in fact such statements do not have to be followed.  These words may also give the user the erroneous impression that a use that is not recommended is still somehow permitted (that is, someone could believe that a particular use is permitted because a statement recommending against such use does not have to be followed).  To avoid these potential problems, the best way to express advisory statements is to use descriptive or nondirective language.  Nevertheless, EPA will allow the use of "should," "may," "recommend" or similar terms on a case-by-case basis as long as they do not appear to be misleading or conflict with mandatory language.
   
   Following are hypothetical advisory statements followed by examples of how they can be rewritten using descriptive terms, which is EPA's preference.   The examples are paired.  The first showing the problematic statement and the second showing the preferred statement in accordance with PR Notice 2000-5.

   1. Precautionary Statements
   
   
   

   Problematic	Latex gloves are recommended.
   Preferred	Latex gloves provide the best protection.

   
   
   
   2. Physical and Chemical Hazards
   
   
   

   Problematic	It is preferable to open containers of aluminum phosphide products in open air as under certain conditions they may flash upon opening.   Containers may also be opened near a fan or other appropriate ventilation which will rapidly exhaust contaminated air.
   Preferred	Opening aluminum phosphide containers outdoors or indoors near an exhaust fan or other ventilation ensures that the gas will be rapidly dispersed if the product flashes.

   
   
   
   3. Directions for Use

   Mixing

   Problematic	Tank mixtures should be applied immediately after preparation.  If for any reason this is not possible, ensure that sufficient agitation has been provided to re-mix all products and check for complete resuspension prior to application.
   Preferred	Applying the product immediately after preparation ensures that it is in suspension.  If application is delayed, agitation to re-mix the products and checking for resuspension ensures proper blending.

   Application

   Problematic	Factors such as depth to the drain system, soil type, and degree of compaction should be taken into account in determining the depth of treatment.
   Preferred	The depth of treatment depends on the depth of the drain system, soil type, and degree of soil compaction.
   Problematic	It may be necessary to treat along one side of interior partition walls if there are cracks in the slab, plumbing entry points, existing termite infestations, or other conditions which would make treatment appropriate.
   Preferred	Treatment along one side of interior partition walls where there are cracks in the slab, plumbing entry points, existing termite infestations, or evidence of other means of access prevents further infestation.
   Problematic	Rotary hoeing is recommended for preemergence applications which do not receive adequate rainfall or sprinkler irrigation to wet the top 2 inches of soil or to the depth of germinating weeds within about 10 days after application.
   Preferred	If  rainfall or sprinkler irrigation does not wet the top 2 inches of soil or depth of germinating weeds within 10 days of a preemergence application, rotary hoeing will ensure soil incorporation.
   Problematic	The spray mixture should be directed to the soil around the base of the cotton plants. Care should be taken to prevent the spray from striking the cotton leaves as injury will occur.  The use of leaf lifters or shields on application equipment is recommended to avoid spraying the cotton foliage.
   Preferred	Directing the spray mixture around the base of the cotton plants and using leaf lifters and shields on application equipment will help minimize foliage contact and plant injury.

   Cleaning

   Problematic	It is recommended that the sprayer be thoroughly cleaned by flushing with a detergent solution at the end of each work day when any emulsifiable oil, oil concentrate, or other emulsifiable formulation has been used either alone or in tank mix combinations with other pesticide formulations, even if no obvious problems have been encountered.  This precaution will ensure a clean sprayer and continued trouble-free operation.
   Preferred	If an emulsifiable oil, oil concentrate, or other emulsifiable formulation has been used, flushing the sprayer with a detergent solution at the end of the workday will ensure a clean sprayer and trouble-free operation.

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IV. Types of Labels and Labeling

1. Master Label
   
   The "Master Label" (reference label) is the label that contains all of the approved uses for a given product and all associated required labeling. All other labeling for a given product must not contain any text beyond that which is approved in the Master label. This label goes on file with the Agency once it is stamped “accepted”.



2. Sub-Label or Split-Label
   
    A "Sub-Label" or “Split-Label” is a label that bears claims and directions for only a portion of the approved uses under a given Master label, but is a complete label in itself, containing all of the required labeling elements.  Agency regulations allow a registrant to distribute or sell a product under a “Sub-Label” or “Split-Label” provided that in limiting the uses identified on the label, no changes would be necessary to the precautionary statements, use classification, or packaging of the product. 40 CFR. 152.130(b).  Since Sub or Split labels only contain labeling text contained in the Master label, the Sub or Split labels are not stamped “accepted” separately. Final printed labeling must be submitted according to 40 CFR 156.10(a)(6).  If these labels are intended to be distributed under a different product name, the Agency must approve the alternate brand name according to 40 CFR 156.10(b)(2)(ii).
   
   Applicants if submitting a Sub-label or Split-label should clearly:
   
   
   • Indicate when the Sub or Split-labels do not contain the entire use profile for the product.
   • Annotate specific label changes in the Sub/Split labels.
   • If proposed changes to a Sub/Split label require changes to the Master label, the registrant must submit a new “Master Label” incorporating and annotating any additions or changes.
   • Indicate at the top of the label whether it is a “Sub-Label” or “Split-Label”, For example:
     
     
   UB/ SPLIT LABEL - Revises Master Label dated XX-XX-XX
   
   

   A new "Master Label" containing all the uses currently approved under the product’s registration is required when a sub-label is submitted with additions not on the “accepted” Master label.  Only the “Master Label” will be stamped “accepted”.  Note: the previously approved labeling may be distributed or sold for a period of 18 months after approval of the revision, conditions set forth in 40 CFR 152.130(c).

3. Supplemental Distributor Labeling
   
   Supplemental distributor labeling are labels for a product that is registered to one company, but distributed by another company (sometimes referred to as a “sub registrant”).  These labels must be the same as that of the registered product except for product name, name and address, registration number (EPA Reg. No. xxxx-xx-xxxx, where the third set of numbers refers to the distributor’s company number), establishment number and that claims may be deleted.  40 CFR 152.132(d)(3). The Agency must be notified before distribution by submission of a notice of Supplemental Distribution (Chapter 4).  Supplemental distributor labels are not submitted to the Agency.
   
   
4. Supplemental labeling
   
   “Supplemental labeling” is a term used by the Agency to describe labeling which includes newly approved uses, use directions, or other instructions which have been added since the last accepted Master label.  These are partial labels distributed with the product by the registrant or distributors.  Since these are partial labels, they must bear a statement referring the user to the product label for complete directions, precautions and a statement that the labeling must be in the possession of the user.  Both the product label and the supplemental labeling are required to safely and effectively apply the product.
   
   The supplemental labeling must be submitted and stamped “accepted” by the Agency.  The Agency requires that these labels bear the following information:
   
   
   • Misuse statement:"It is a violation of Federal law to use this product in a manner inconsistent with its labeling."
   • The labeling must be in possession of the user at the time of application.
   • Read the label affixed to the container for [pesticide X] before applying.
   • Use of [pesticide X] according to this labeling is subject to the use precautions and limitations imposed by the label affixed to the container for [pesticide X].
   • Product Name
   • EPA Registration Number
   • Restricted Use Statement (if required)
   
   
   Normally, supplemental labeling will be incorporated into the affixed label at the next printing of the product label (final printed label) or within 18 months, whichever comes first.  However, there are circumstances when this might not be done, for example if the directions for use on the supplemental labeling are subject to continual, frequent change, e.g., California aerial application county restrictions can change every six months or so.  Note that just like other labels, supplemental labels must be accepted prior to distribution.
   
   Supplemental labeling is also used for state registration of special local needs (SLN) under section 24(c) of FIFRA.  For labeling requirements for supplemental labeling for State registrations, refer to 40 CFR 162.153(e).

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V. Non‑FIFRA Labeling

Some labels submitted to the Agency have information devoted to non-FIFRA issues, e.g., Department of Transportation (DOT) shipping rules, New York City fire code symbols, Hazardous Materials Identification System (HMIS) and National Paints and Coatings Association (NPCA) and National Fire Protection Association (NFPA) hazard codes and rating systems, Food and Drug Administration or State Department of Agriculture numbers, and bar codes.  A registrant may choose to place such text on the label but may not replace, obscure, conflict with, or supersede the FIFRA required text.

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VI. Label Submission Requirements

Reviewers should only accept draft labeling for review that meets the regulatory requirements including those set out in 40 CFR 152.50. Agency preference has been to ask registrants to follow some of the other steps outlined below, that are not required by law.

Submissions for new registrations or amendments must include five copies of all draft labeling (typescript or mock-up).  40 CFR 152.50(e). For all amendments, the Agency prefers that one copy of the draft proposed label be marked up or annotated in some way, such as Redline/Strikeout, to indicate what has been changed.  The other four copies should be “clean” or not annotated in any way, but include all label changes for which the amendment is submitted.

All copies must be legible [40 CFR 152.50(e)] and should be of suitable quality for making legible photocopies.  OPP’s practice has been to request that draft labeling have print size of at least 12 characters per inch to aid in label review and to ensure that additional photocopies will be legible.

Registrants are asked to submit draft labeling on 8 1/2"x 11" paper.

If the draft labeling submitted by the applicant does not meet the required criteria above, the reviewer shall send a letter to the applicant describing the submission deficiencies and request the applicant revise its draft labeling.

The Agency is moving toward electronic submission of labeling.  While not currently required, if the registrant chooses to submit labels electronically, paper copies are required to be submitted as well.  For more information on electronic submission of labels see:  http://www.epa.gov/oppfead1/eds/esr_guidance.htm#pilots

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VII. Label Format

Listed below are the various sections of the label in the approximate order they should appear on a label. Several sample label formats appear at the end of this chapter.  Each section below corresponds to the chapter in this manual which discusses that particular part of the label in more detail.  Note that somewhat different formats are used for certain classes of products (e.g., rodenticide baits).

1. Front Panel
   1. Restricted Use Pesticide Statement (Chapter 6) if applicable
      This section of the label, if applicable, includes the references to “restricted use,” which under FIFRA Section 3 (d)(1)(C) describes those pesticides that require “additional regulatory restrictions” to avoid potential unreasonable adverse effects on the environment.
   
   
   
   2. Product Name, Brand or Trademark (Chapter 12)
   
   
   
   3. Ingredient Statement (Chapter 5)
      This section of the label identifies the name and the percentage by weight of each active ingredient and the percentage by weight of other/inert ingredients. If the size or form of the product package makes it impracticable to place the ingredient statement on the front panel of the label, permission may be granted for the ingredient statement to appear elsewhere. See 40 CFR. 156.10(g)(2).
   
   
   
   4. "Keep Out of Reach of Children" (KOOROC) Statement (Chapter 7)
      This specific statement, which is commonly referred to as the KOOROC statement ("child hazard warning"), appears on almost all end use pesticide products except those pesticides that are intended for use on children or where it is demonstrated that children will not come in contact with the product.  In these cases, a modified statement is allowed.  See 40 CFR 156.66.
   
   
   
   5. Signal Word (Chapter 7)
      Signal words that correspond to the toxicity categories for product hazards (e.g., oral, dermal) appear on the front panel of the label.  40 CFR 156.60(a)(1).
   
   
   
   6. First Aid (Chapter 7)
      A first aid statement must appear on the front panel of all pesticides assigned to Toxicity Category I by any route of exposure, but the agency may allow reasonable variations in the placement of the statement.  40 CFR 156.68(d). The front panel must include a reference such as “See First Aid statement on back panel” near the word “poison” and the skull and crossbones if the Agency allows the first aid information to appear on the back panel.  40 CFR 156.68(d).  First Aid statements for pesticides of other Toxicity Categories may appear on any panel of the label.  40 CFR 156.68(d).
   
   
   
   7. "Skull & Crossbones" Symbol and the word "POISON" (Chapter 7)
      FIFRA 2(q)(2)(D) requires labels of pesticides that contain substances in quantities highly toxic to man to include a skull and crossbones and the word “poison” prominently in red on a background of distinctly contrasting color.  This requirement is further defined in 40 CFR 156.64(a)(1) as applying to pesticides in Toxicity Category I where such toxicity determination is based on oral, inhalation or dermal toxicity as opposed to skin or eye irritation.
   
   
   
   8. Net Contents/Net Weight (Chapter 17)
      This section identifies the weight or volume of pesticide in the container.  See FIFRA 2(q)(2)(C)(iii); 40 CFR 156.10(a)(1)(iii).



2. Front or Back Panel
   1. EPA Registration Number & Establishment Number (Chapter 14)
      The EPA Registration Number is the single most important piece of information for tracking pesticide products. The EPA Registration Number must appear on the label of the product. 40 CFR 156.10(a)(1)(iv).  The EPA Establishment Number identifies the final physical location where the pesticide product was produced or labeled.   The EPA Establishment Number may appear on any suitable location on the label or immediate container, however, it must appear on the wrapper or outside container of the package if the number cannot be clearly read through the wrapper or container.  [40 CFR 156.10(f)] .
   
   
   
   2. Company Name & Address (Chapter 15)
      This section of the label identifies the name and address of the producer, registrant or person for whom the product is produced.  40 CFR 156.10(a)(1)(ii).



3. Back Panel
   1. Precautionary Statements
      1. Hazards to Humans and Domestic Animals (Chapter 7)
         Where a hazard exists to humans or domestic animals precautionary statements that describe the particular hazard, route of exposure and precautions to be taken must appear on the label. See 40 CFR 156.10(a)(1)(vii).
      
      
      
      2. First Aid (Chapter 7)
         This section of the label provides information to the pesticide user concerning appropriate first aid for the various routes of exposure associated with accidental exposure. See 40 CFR 156.68.
      
      
      
      3. Environmental Hazards (Chapter 8)
         Where a hazard exists to non-target organisms, precautionary statements that identify the hazards and necessary precautions must appear on the label. See 40 CFR 156.10(a)(1)(vii).
      
      
      
      4. Physical or Chemical Hazards (Chapter 9)
         Hazards such as flammability, explosive potential or dielectric breakdown and the various precautions to be taken must be identified, as applicable. 40 CFR 156.78.
   
   
   
   2. Directions for Use (Chapter 11)

      This section of the label provides instructions to the user on how to use the product, and identifies the pest(s) to be controlled, the application sites, application rates and any required application equipment.  This section may also include certain worker protection issues such as a reentry statement that identifies the specific time period following treatment during which entry into a treated area is restricted.  As further described in Chapter 11, other issues must be addressed in the directions for use. See 40 CFR 156.10(i)(2).

   3. Storage and Disposal (Chapter 13)

      This section of the label provides instructions for storing the pesticide product and for disposing of any unused pesticide and the pesticide container.  40 CFR 156.10(i)(2)(ix).

   4. Warranty Statement (Chapter 12)

      This is a disclaimer statement included voluntarily on most pesticide products by the registrant.  When it is included it must conform to requirements discussed in chapter 12.

   5. Worker Protection Labeling (Chapter 10)

   All WPS labeling requirements have been consolidated into this chapter. 40 CFR 156 Subpart K (156.200, et seq.)

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VIII. Final Printed Labels and Labeling

Final printed labels or labeling must be filed and accepted by the Agency prior to product registration, although applicants need not submit final versions until draft labeling has been provisionally accepted by the Agency.  40 CFR 156.10(a)(6)(i).  In some cases, reproductions of unusual labels (e.g., silkscreen) are acceptable.  40 CFR 156.10(a)(6)(ii).  Agency practice is to request two copies of the final printed labeling that will accompany the pesticide product when distributed or sold.  The type size of final printed labels may be checked by using the template on the following page.  Make a copy of the template on a transparency sheet (be sure to copy it using a 1:1 ratio or 100% setting on most photocopies-no enlargement or reductions).  Overlay the template printed on a transparency on the final printed label and compare the type size of the Signal Word, and the "Keep Out of Reach of Children" statement on the printed label with that of the template.   The table at the top of the chart may be used to determine the appropriate type size based on the size of the label for front panel warning statements.

Type Sizes for Front Panel Warning Statements

NOTE: No type on any label can be less than 6 point

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Consumer Product Sample Label Format

1. When First Aid statements appear on the front panel they should be grouped together with the other precautionary statements, preferably appearing first, immediately following the general heading "Precautionary Statements".
2. Content of the Note to Physicians is determined in part by the Acute Toxicity Review.
3. A complete listing of other ingredients may be provided below the ingredient statement.
4. Required except for products intended solely for residential use; direct injection into plants; post harvest application, or application only as a gas or solid (e.g., pellet, tablet, granule, or dust formulations).

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1. When First Aid statements appear on the front panel they should be grouped together with the other precautionary statements, preferably appearing first, immediately following the general heading “Precautionary Statements”.
2. Content of the Note to Physicians is determined in part by the Acute Toxicity Review.
3.  A complete listing of (other) ingredients may be provided below the ingredient statement.
4. Required except for products intended solely for residential use; direct injection into plants; post harvest application, or application only as a gas or solid (e.g., pellet, tablet, granule, or dust formulations).

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Restricted Use Pesticide - Worker Protection Standard Sample Label Format

RESTRICTED USE PESTICIDE (If applicable)1 Due to (insert reason) For retail sale to and use only by Certified Applicators or persons under their direct supervision and only for those uses covered by the Certified Applicator’s certification. PRODUCT NAME Product information: (what is product used for) KEEP OUT OF REACH OF CHILDREN SIGNAL WORD Poison (ENGLISH\SPANISH) "Si usted no entiende la etiqueta, busque a alguien para que se la explique a usted en detalle. (If you do not understand the label, find someone to explain it to you in detail.)" First Aid2 If Swallowed If Inhaled If on Skin If in Eyes Reminder to have label. Emergency phone number. Note to Physician:3 SEE OTHER PANEL FOR PRECAUTIONARY STATEMENTS ACTIVE INGREDIENT(S):....................................90.00% OTHER INGREDIENT(S)4.....................................10.00% TOTAL:................................................................100.00% This product contains_____lbs of [a.i.] per gallon. EPA Registration No. ____ [Registrant Name] EPA Establishment No. ____ [Address] [Telephone Number] Net Contents _________

PRECAUTIONARY STATEMENTS HAZARDS TO HUMAN AND DOMESTIC ANIMALS DANGER Fatal if swallowed.  Wash thoroughly with soap and water after handling and before eating, drinking, chewing gum, using tobacco or using the toilet. Fatal if absorbed through skin.  Do not get in eyes, on skin, or on clothing. Fatal if inhaled.  Do not breathe… etc. User Safety Requirements Follow the manufacturer's instructions for cleaning/maintaining PPE.  If no such instructions for washables, use detergent and hot water.  Keep and wash PPE separately from other laundry. Engineering Controls When handlers use closed systems, enclosed cabs, or aircraft in a manner that meets… ENVIRONMENTAL HAZARDS _______________________ _______________________ PHYSICAL OR CHEMICAL HAZARDS _______________________ _______________________ DIRECTIONS FOR USE RESTRICTED USE PESTICIDE (If applicable)1 It is a violation of Federal law to use this product in a manner inconsistent with it labeling. Do not apply this product in a way that will contact workers or other persons, either directly or through drift. Only protected handlers may be in the area during application. For any requirements specific to your State or Tribe, consult the agency responsible for pesticide regulation. GENERAL INSTRUCTIONS and INFORMATION Do not apply this product in a way that will contact workers or other persons, either directly or through drift. Only protected handlers may be in the area during application. For any requirements specific to your State or Tribe, consult the State or Tribal agency responsible for pesticide regulation. AGRICULTURAL USE REQUIREMENTS Use this product only in accordance with its labeling and with the Worker Protection Standard, 40 CFR Part 170. This standard contains requirements for the protection of agricultural workers on farms, forests, nurseries, and greenhouses, and handlers of … Do not enter or allow worker entry into treated areas during the restricted entry interval (REI) of      hours.  The REI is 72 hours in outdoor areas where average annual rainfall is … PPE required for early entry to treated areas… Notify workers of the application by warning them orally and by posting warning signs at entrances to treated areas.

DIRECTIONS for USE (continued) Non-Agricultural Use Requirements (If applicable) The requirements in this box apply to uses of this product that are NOT within the scope of the Worker Protection Standard for agricultural pesticides (40 CFR Part 170). The WPS applies when this product is used to produce agricultural plants on farms, forests, nurseries, or greenhouses. Keep unprotected persons out of Chemigation Instructions or Prohibition (If required):5 _____________________________ _____________________________ SPRAY DRIFT LABELING (If applicable): _______________________________________ _______________________________________ Non-Crop/Site/Pest: Non- Crop/Site/Pest: Crop/Pest: Crop/Pest: STORAGE AND DISPOSAL PESTICIDE STORAGE PESTICIDE DISPOSAL CONTAINER DISPOSAL WARRANTY STATEMENT __________________________ __________________________ __________________________

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