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Module 3: Special Issues

Table Of Contents

Introduction

Modules

  1. Label Basics
  2. Parts of the Label
  3. Special Issues
  4. Applying the Principles of Pesticide Label Review
  5. Emerging Issues and Course Completion


Module 3

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Module Index
Glossary | Resources

Section 5: What is worker protection labeling?

Learning Objectives
By the end of this section, you will be able to:
  • Define the Worker Protection Standard.
  • Categorize products as either subject to the Worker Protection Standard or not.

Worker Protection Standard

The Worker Protection Standard (WPS) establishes standards and labeling requirements for worker protection. Pesticide Registration (PR) Notices 93-7 and 93-11 provide EPA guidance for complying with WPS. The correct product-specific WPS labeling can be found in the toxicology review memo which summarizes the Acute Toxicity Data Evaluation Record (DER) for any given product.

As part of the pesticide registration, reregistration, and registration review processes, EPA performs a comprehensive worker risk assessment. The worker risk assessment is based on toxicological criteria and potential for dermal, ocular, oral, or inhalation exposure. Based on that risk assessment, worker protection labeling specific to the active ingredient is established. When necessary to address risk to non-WPS workers, the regulatory assessment document goes beyond WPS to provide labeling protection for those workers not subject to the WPS. Chemical-specific worker protection labeling requirements can be found in the regulatory assessment documents (e.g., reregistration eligibility decision [RED] documents).

To determine the correct worker protection labeling for a given product, the label reviewer must consider the chemical-specific worker protection labeling defined by the RED, the most current regulatory risk assessment document, and the product-specific labeling defined in the acute toxicity review and/or guidance contained in the Label Review Manual. In most cases, the correct worker protection labeling is determined by taking the most restrictive statements from each source.

Resources

For more information about WPS, see Chapter 10 of the Label Review Manual (PDF) (27 pp, 908.04k, About PDF).
For EPA guidance on complying with WPS, see PR Notice 93-7 (PDF) (7 pp, 2.9MB, About PDF) and PR Notice 93-11 (PDF) (6 pp, 2.3MB, About PDF).





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