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Module 3: Special Issues
Table Of Contents
Modules
- Label Basics
- Parts of the Label
- Special Issues
- Applying the Principles of Pesticide Label Review
- Emerging Issues and Course Completion
Section 4: How should I review directions for use?
Key Points
- When reviewing directions for use, it is critical to distinguish between statements that are intended to be enforceable and those that are included for informational purposes.
- Suggested formats for directions for use include bulleted format, tabular format, and modified paragraph format.
- The Directions for Use Checklist includes questions to ask when conducting a label review.
- Label reviewers should use policy documents along with the applicable laws to make case-by-case determinations on the acceptability of label language.
Progress Check
- When is it appropriate to use the phrase “For Use Only by”?
When referring to a group that can be clearly defined by FIFRA, an applicable regulation, or an EPA policy. - What features of the modified paragraph format help to organize information?
Subheadings and highlighted key words and phrases. - Where can the label reviewer find questions to ask when conducting a review of directions for use?
The Directions for Use Checklist in Chapter 11 of the Label Review Manual. - Name three additional resources label reviewers can consult when reviewing directions for use.
Registration review decision documents; RED documents; BRADs; science assessments; product–specific data evaluation records and assessments; labels of substantially similar products (for me–too registrations); available science/technical reviews; the efficacy reviewer; PR notices; 40 CFR, Part 180; and subject matter experts.