Pesticide Labeling Questions & Answers - Service Containers
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(Note: Contact your Pesticide Product Registration Ombudsman for specific label issues about a single product).
These answers are not intended to create significant new guidance or require any changes to previously accepted labeling. The Agency will contact registrants directly about how to correct problematic labels as appropriate. Changes to EPA accepted labeling will only be required in accordance with standard agency procedures. These answers are primarily based on federal law, regulations and policies implemented by EPA. States, tribes, territories, and other federal agencies may have additional requirements relevant to their jurisdictions.
- Advertising Claims
- Antimicrobial Claims
- Contract Manufacture
- Use Sites
- Definitions of Terms
- Distributor Product Labeling
- Exception to Use in a Manner Not Permitted (FIFRA Sec 2ee)
- Existing Stocks
- General Labeling
- Labeling from Web Sites
- Multiple Products Packaged Together
- NAFTA Labeling
- Pesticide Exemption (FIFRA 25B)
- Pictures and Logos
- Repacked Products
- Service Containers
- Subject to FIFRA
- Superlative Terms
- Supplemental Labeling (NOT distributor products)
A pool service company would like to purchase bleach in bulk (> 55 gallons), and place the bleach in smaller container for their own use in the servicing of swimming pools. As the smaller containers are NOT for resale, would they be required to have a copy of the pesticide label on the container, or just a label sufficient to meet OSHA requirements? (LC08-0168; 5/15/08)
The Agency does not regulate service containers when they are used by applicators to provide a service of controlling pests without leaving any unapplied pesticide with their customers, and therefore does not require labeling of the service container (FIFRA section 2(gg). EPA recommends that the user identify the material in the container in the event of an accident or spill. The applicator is also responsible for meeting any other labeling requirements that may be required by other statutes. If the applicator leaves a service container with a customer for the customer to apply at a later date the applicator must register the pesticide left behind and the service container must bear full labeling. Please note that the applicator may only use registered sources of bleach in the servicing of swimming pools.
Should the percentage of active ingredient listed be adjusted to reflect the diluted product? If not, could you provide some information as to why the concentrated product ingredient listing should be reflected on the label of the secondary container? LC09-0275 (05/22/09)
A secondary container is a container used by an applicator to transport and store use dilutions of a pesticide for eventual use by the applicator. The percentage of active ingredient listed on the secondary container may be the same as that declared on the pesticide product, or if known, the percentage of active ingredient in the end-use dilution. Listing the percentage of active ingredient as reflected on the product label and indicating the product has been diluted as directed relieves the user from having to calculate the percentage of active in the dilute formulation. Such a calculation can be difficult for the average user when the directions for use call for a ratio of product to diluent, i.e., 1 part product to 64 parts diluent or 5 ounces of product to 128 ounces of water, and does not list the percentage of active ingredient in the finished dilution. Please keep in mind that the secondary container is strictly for the use of the applicator and may not be sold or distributed.