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Label Review Manual
Chapter 19: The Consumer Labeling Initiative and Pesticide
Labels
Table of Contents
Chapters:
- Purpose of Manual
- What is a Pesticide?
- General Labeling Requirements
- Types of Label Reviews
- Ingredient Statement
- Use Classification
- Precautionary Labeling
- Environmental Hazards
- Physical or Chemical Hazards
- Worker Protection Labeling
- Directions for Use
- Labeling Claims
- Storage and Disposal
- Identification Numbers
- Company Name and Address
- Graphic & Symbols on Labels
- Content/Net Weight Statement
- Unique Product Labeling
- The Consumer Labeling Initiative and Pesticide Labels
I. Background
Pesticide product labels contain valuable information including what the product is intended to control, how to use the product safely, how to dispose of it, and what to do in case of emergencies. However, for a variety of reasons, many people do not receive the full benefit of the information on the label. Potential reasons could be because some labels are too difficult to read, or because people assume they know how to use the product, or because they aren’t aware of the types of information on the label. The Consumer Labeling Initiative addressed these issues.
- What is the CLI? In 1996, the Office of Prevention, Pesticides and Toxic Substances (OPPTS), in cooperation with pesticide registrants and other interested parties, began the Consumer Labeling Initiative (CLI). The CLI is a voluntary, cooperative partnership among federal, state, and local government agencies, industry, and other interested parties working to improve product labels on residential outdoor pesticides, indoor insecticides, and household hard surface cleaners in order to improve consumer understanding of the health and safety and environmental, information contained on household consumer product labels. The objectives of the CLI were to: 1) learn directly from consumers how to provide the label information they want and need; 2) make essential safety and appropriate use, environmental, and health information easier to find, read, understand, and use; 3) help consumers make informed product choices–based on their own needs and values; and, 4) help consumers use, store, and dispose of products safely.
- CLI, Phases I and II. Phase I occurred in 1996 and consisted of three components: 1) qualitative consumer research, consisting of over 135 one-on-one interviews with people in five cities around the country; 2) a literature review of relevant studies and publications; and, 3) a review of the information and comments solicited by the March 1996 Federal Register notice that initiated the effort. Phase II began in early 1997 and encompassed the remaining research done under the CLI. It included quantitative and qualitative research with consumers, as well as several CLI workgroups, made up of several CLI participants each, which addressed complex topics not easily addressed by the quantitative research alone. The workgroups addressed how to present health and safety and ingredient information meaningfully; how to revise the disposal instructions so they are useful to everyone; and how to standardize messages on product labels (e.g., format, elements of the message).
- Quantitative Research. The quantitative survey results were projectable to the entire population and the respondents were statistically representative of the United States; this means the survey data are considered to reliably represent the whole population. The survey, conducted in the Spring of 1998, had two parts: a phone survey to test people’s ability to locate and understand specific information on labels; and, a written survey which collected information on how and when people read labels, what they read, what they understand, what they like and dislike about labels, and what changes they would like to see made. The phone and written surveys were conducted for each of the three residential product categories: outdoor, indoor, and hard surface cleaner products.
- Qualitative Research. Unlike quantitative research, qualitative research results cannot be projected to a larger group. This type of research, done with interviews, focus groups, etc., is used to provide insights into what the participants think or feel. The Phase II qualitative research had two parts. There were interviews held in 1997 to determine consumer understanding of the first aid statements on labels. The information from those interviews led to revised statements which are clearer to consumers. The research also included 27 mini focus groups, with three to five people each, which were held in three cities. The purpose of the focus groups was to try to verify, learn more about, and test the information acquired from the written and phone surveys. CLI participants designed numerous sample labels incorporating a variety of language and layout changes based on the survey data. Focus group participants were asked to compare the various label revisions against each other and with a standard sample label, representative of current label designs, and explain their preferences to the moderator.
II. Research Findings
- Overall comprehension is high (except for ingredient names; environmental hazard information for outdoor uses; and some first aid information).
- Consumers asked for clear, concise, easy-to-read information that connects consequences with actions. Consumers prefer directions to provide specific time references where appropriate. For example,”do not reapply for 1 week”; “do not re-enter treated area for 4 hours.”
- Label comprehension can be improved by using standardized formats; this increases ease of use and encourages more frequent label reading.
- Consumers preferred important information be set off, boxed, highlighted, or somehow made to look different from the rest of the text.
- Outdoor pesticide users read labels more often and more completely than do indoor insecticide users who in turn read labels more completely than household cleaner users. This often seems to be related to the reader’s familiarity with the product, and or how complex the product is to use.
- For the three product categories, the label information read in the store and before use include: brand name, directions for use, a description of what the product does, a description of where not to use the product, and precautions concerning the effects on personal health/kids. G. For the three product categories, respondents indicated that the following information is important, and they would like to locate it easily: 1) Directions for use; 2) Description of what the product does; 3) Description where not to use the product; 4) Precaution concerning the effect on personal health/kids; and 5) Emergency information.
- The information respondents found most difficult to locate is as follows:
- For all three product categories - where the product should not be used.
- For outdoor - first aid information and precautions for pets and the
environmental effects for wildlife.
- For indoor - precautions on personal health.
- For all three product categories - where the product should not be used.
- In all three product categories, consumers always indicated that the least important of the current label information are the environmental claims (e.g., contains no CFCs, contains no phosphates), and the name of the manufacturer. In all three product categories, consumers ranked disposal, storage, ingredients, and a phone number as a grouping of the next least important label information to them.
- In all three product categories, given a description of different formats, consumers preferred a box format on the label, like the nutrition facts box that presents information consistently among products in the category.
- The most frequent reasons given for not reading storage and disposal information in the store was that it is “information they already know,” followed by “just don’t read it.”
- Besides the packaging, respondents identified the top sources to which
they refer for product information to be:
- Indoor insecticides - store displays, TV ads, friends/family/co-workers, product brochures, and magazine ads.
- Outdoor pesticides - store displays, product brochures, friends/family/co-workers, store salespersons, and TV ads.
- Household cleaners - TV ads, friends/family/co-workers, store displays, magazine ads, product brochures.
- Consumers don’t understand the real purpose of the signal word (Danger, Warning, Caution) that appears on every product and conveys the level of hazard of the product. All three words do convey some level of concern to readers, but most readers thought the manufacturer chose whatever word they wanted, they didn’t realize the words are assigned based on science.
- Less than half of consumers look for ingredient information; only 3% of consumers voiced a need for a complete listing of ingredients. When presented with a variety of ingredient statement formats, options listing functional categories of the ingredients and their purpose were preferred.
III. Major Recommendations from CLI
The CLI participants used the findings from the data to develop a set of recommendations for label changes and label education. The major recommendations addressed three categories: label changes; educational activities; and the workgroup issues. All the recommendations were approved by EPA. Some recommendations have already been incorporated into the Label Review Manual, as well as other Pesticide Registration Notices. Note: Other recommendations remain to be implemented.
- Label Changes. The major label recommendations follow.
- Recommended the use of more bulleted text rather than long narrative formats; the use of simpler, less technical language; the inclusion of more white space; the use of more tables and graphics as appropriate; and, where a recognizable sequence of events occurs, that the steps be numbered.
- Recommended that manufacturers be allowed more flexibility regarding the content and location of the ingredient statement;
- Recommended the addition of short phrases describing just the major hazards under the signal word on the front label.
- Recommended that the Federal misuse statement be revised to something simpler and easier to understand. The statement currently reads “It is a violation of Federal Law to use this product in a manner inconsistent with its labeling.”
- Recommended that registrants be allowed to delete the signal word from Toxicity Category 4 products. EPA proposed this change in a 1999 Federal Register Notice concerning anti-microbial products. The change was finalized on December 14, 2001 in 66FR 64759-64768.
- Educational Changes. The recommendation was made to encourage and continue the consumer education campaign. The education has been undertaken under the Read the Label First! campaign and the campaign is continuing.
- Workgroup Issues. Additional work by OPP on the ingredients statement and storage and disposal issues was recommended. The completed work on disposal is reflected in PR Notice 2001-6, September 7, 2001. The work on the ingredients statement continues.
IV. Format Suggestions Based on CLI Research
- Labels should be presented so they are easy to read and understand by the user. The CLI research, as well as other label research done around the world, shows that in many cases, charts, graphs, symbols, or pictures can be used to help convey information. However, care needs to be taken that the graphics actually do convey the message intended.
- Subheadings, like paragraph headings in a book, help to organize the information and also make it easier to find. The data also showed that information presented in a “bulleted” format is easier to read and understand than longer narrative paragraphs, even when the same type size is used. When more lengthy and complicated information is required, a tabular format may be easier to follow.
- Due to the variety in size and shapes of labels, not all the CLI format recommendations may work on all labels; however, consideration should be given to them whenever feasible. Products labels must remain consistent with applicable statutory and regulatory requirements.
- The following is an example of a typical narrative format which has
been used on labels in the past.
Precautionary Statement Hazards to Humans and Domestic Animals
Danger: Fatal if swallowed or absorbed through the skin. Do not get in eyes, on skin or on clothing. Wear protective clothing and rubber gloves. Avoid breathing spray mist. Wash thoroughly with soap and water after handling and before eating, drinking or using tobacco. Remove contaminated clothing and wash clothing before use. Provide adequate ventilation of area being treated. Do not apply to humans, pets, plants or contaminate feed, foodstuffs, dishes or utensils. Cover and avoid spraying fish aquariums. Cover or remove exposed food, dishes, utensils and food handling equipment.
- The following are some suggested formats, based on the CLI data and
recommendations.
- Bulleted Format. When using the bulleted approach,
the intent is not to leave information out, but to make it visually
easier to follow. Either partial, or complete, sentences can be
used. Any type of character could be used as the “bullet.”
Precautionary Statements Hazards to Humans and Domestic Animals
CAUTION:
- Harmful if swallowed or absorbed through the skin.
- Avoid breathing spray mist.
- Avoid contact with skin or clothing.
- Wash thoroughly with soap and water after handling and before eating, drinking or using tobacco.
- Provide adequate ventilation of area being treated.
- Do not apply to humans, pets, plants, or contaminate feed, food stuffs, dishes or utensils.
- Cover and avoid spraying fish aquariums.
- Cover or remove exposed food, dishes, utensils and food handling equipment.
DIRECTIONS FOR USE
It is a violation of Federal law to use this product in a manner inconsistent with its labeling.
General Precautions/restrictions
- Use may damage marble surfaces.
Application Instructions
- Turn nozzle to “Spray” or “Stream.”
For General Cleaning: To Control Mildew: 1. Hold nozzle 6-8 inches from surface. 1. Pre-clean surface 2. Spray soiled area. 2. Spray until thoroughly 3. Wipe clean wet. 3. Let air dry 4. For surfaces in direct contact with food, a rinse is required. 4. Repeat weekly or when new growth appears. To Disinfect:
1. For heavily soiled surfaces, pre-clean according to General Cleaning Directions.
2. Spray until thoroughly wet.
3. Let stand 10 minutes before wiping or rinsing.
- Modified Paragraph Format. The modified paragraph
format presents text in a series of full sentences, like the old
standard narrative format, but includes subheadings, numbering,
etc. to make it easier to locate information. If a paragraph format
must be used, try to help your reader out by including either subheadings,
or highlighting key words/phrases, etc. Also, the language should
be simple and use correct grammar and punctuation.
Application Instructions:
BROCCOLI(PHI): Pests; Application Method( Spray, Broadcast, etc.); Dose (amount per unit area); Type of Equipment (Sprayer, Aircraft, Spreader, etc.); Timing (e.g., Spring, Foliar, Pre-plant, Pre-plant Incorporated, etc.); Application Intervals; Phytotoxicity concerns as it applies to timing and method of application; Restrictions (Grazing, haying, maximum dose per application, maximum dose per crop cycle or per year, maximum number of application per year, etc.). Other comments which apply to this site. CAULIFLOWER.....
FOR HOUSEHOLD USE: SHAKE WELL BEFORE EACH USE. Apply to surfaces only. Hold container upright 12" from surface and spray. Spray until surfaces are wet. Avoid over wetting asphalt tile, rubber and plastic materials. Repeat treatment as necessary, but no more than once a week.
ROACHES, CRICKETS, SILVERFISH, SPIDERS: Spray directly on insects when possible. Thoroughly spray cracks, baseboards, underneath kitchen shelves, and other places where insects live. ANTS, EARWIGS: Spray door sills, wood frames, outside foundations and porches. Spray directly on ant hills. FLIES, MOSQUITOES, GNATS, WASPS: Apply on screens, walls, door and window frames, and other surfaces where insects congregate.
- Tabular Format. When using a tabular format make sure that all the appropriate information is included; that it is easy to follow; that types of information are clearly divided or discernible; etc.
FIRST AID If inhaled - Move person to fresh air.
- If person is not breathing, call 911 or an ambulance, then give artificial respiration, preferably by mouth-to-mouth, if possible.
- Call a poison control center or doctor for further treatment advice.
If on skin or clothing - Take off contaminated clothing.
- Rinse skin immediately with plenty of water for 15-20 minutes.
- Call a poison control center or doctor for treatment advice.
If in eyes - Hold eye open and rinse slowly and gently with water for 15-20 minutes.
- Remove contact lenses, if present, after the first 5 minutes, then continue rinsing eye.
- Call a poison control center or doctor for treatment advice.
If swallowed - Call poison control center or doctor immediately for treatment advice.
- Have person sip a glass of water if able to swallow.
- Do not induce vomiting unless told to do so by the poison control center or doctor.
- Do not give anything by mouth to an unconscious person.
CROP PHI TARGET PESTS RATE SPECIAL DIRECTIONS Broccoli
For use only in California, Oregon, and WashintonDo not apply within 5 days of harvest Aphids Flea beetles Leafhoppers
Whitefilesfl. oz in gal of water (diluent) by ground or ______ gal of water
(diluent) by aircraftMethod of Application Spray, Broadcast, Chemigation, Ultra Low Volume, etc.
Equipment Sprayer, Sprinkler Irrigation, Mist Sprayer, Spreader etc.
Timing Foliar, Pre-plant, Post-plant, Post-harvest, Dormant, etc.
Application Interval
Can be __-__ days as needed or can be __-__ days or as needed.
Notes: (applying to a specific pest)Armyworms Lygus bugs Higher dosage than above withs ame amount of diluent Same as above but with different timing, e.g., pre-plant incorporated including a different type of equipment, e.g., tiller. Limitations:
1. Do not apply more than___ fl. oz. of Product per acre per application.
2. No more than gallons per acre per season or year.
3. Make no more than applications per season or year.
Grazing Restrictions: Can apply to Grazing, Harvesting of Hay or Green Forage.
NOTES: Can give information on phytotoxicity, pest resistance, other general comments that apply to the site, etc. - Bulleted Format. When using the bulleted approach,
the intent is not to leave information out, but to make it visually
easier to follow. Either partial, or complete, sentences can be
used. Any type of character could be used as the “bullet.”