Pesticide Registration (PR) Notice 2005-1: Labeling Statements on Products Used for Adult Mosquito Control
Labeling Statements on Products Used for Adult Mosquito Control
- What does this Notice announce, and what pesticides are affected?
- Why did EPA develop these recommendations?
- What are the recommendations?
- How will these recommendations improve the safe use of pesticides to control mosquitoes?
- When will these changes be implemented?
A. The Notice sets out seven Agency recommendations for label language on products used for control of adult mosquitos. Pesticide manufacturers are being asked to incorporate these recommendations in the labeling of any new products seeking registration for adult mosquito control use, or to request amendments of existing labels. .
These recommendations apply only to products labeled for wide-area application as Ultra Low Volume (ULV) sprays or fogs, and not to home and garden use products which list mosquitoes on the label, or to coarse non-ULV sprays intended for residual treatment of vegetation or other surfaces. Control of mosquito larvae in water is a wholly different use pattern from adult mosquito control, and are not included in the scope of this Notice.
A. In recent years state pesticide regulators and mosquito/vector control agencies have raised concerns about consistency and clarity of the labeling of pesticides used for adult mosquito control, and asked the Agency to address these concerns. In April 2003, an advisory committee representing a broad spectrum of interests, including the pesticide industry, grower groups, public health agencies, academic researchers, public interest and advocacy organizations recommended that EPA develop formal recommendations for label improvements. Draft recommendations were published for comment in April 2004.
A. In brief form the recommendations are:
1. Adult mosquito control applications should be limited to trained personnel.
2. Mosquito control directions and precautions should be clearly distinguished from any other use directions allowed on the label, such as agricultural crops.
3. Label precautions and directions should be revised as needed to make hazards to aquatic life as clear as possible, and also to allow the application of these products over or near a body of water allowable under some circumstances.
4. Users should consult with the State or Tribal agency for pesticide regulation to determine if permits or other regulatory requirements exist.
5. Labels should specify a spectrum of spray/fog droplet sizes, and indicate that droplet size should be determined according to directions from equipment manufacturers or other appropriate sources.
6. Precautionary language to protect bees should have a provision to allow mosquito control applications in order to respond to threats to public health which are identified by health or vector control agencies on the basis of evidence of disease organisms or diseases cases in animals or humans.
7. Mosquito adulticide labels should include limits on timing and number of applications to the same location. Exceptions to these limits may be allowed in order to respond to threats to public health which are identified by health or vector control agencies on the basis of evidence of disease organisms or diseases cases in animals or humans.
A. Each recommendation offers a benefit. Use by appropriately trained personnel (Rec. 1) and clearly identified directions for mosquito control (Rec. 2) both help to avoid misapplications. Recommendation 3 is intended to allow applications over or near water when that is necessary in order to reach a population of mosquitoes. Although this is common practice and allowed by many labels, some current labels do not, which may hinder timely applications. Recommendation #4 is advisory, but intended to make applicators aware that some states have additional requirements that must be complied with. Recommendation 5 on droplet size is important to achieving proper Ultra Low Volume applications which pose minimal risks to people, wildlife and bodies of water. Recommendations 6 and 7 are intended to ensure that pesticides will be available for use when public health is at risk.
A. EPA expects any applications to register new mosquito adulticides that come in after April 15, 2005 to reflect these recommendations. EPA is encouraging registrants of existing products to apply for amendments to reflect the recommendations by October 15, 2005. However, the Notice is guidance and not a regulation. Some registrants may choose to wait, for example, until their chemical completes the Agency's reregistration process. Several pesticides which are used in mosquito control products will be completing that process in 2006. Registrants are also free to propose alternatives to the recommendations.