Module 3: Special Issues
Table Of Contents
- Label Basics
- Parts of the Label
- Special Issues
- Applying the Principles of Pesticide Label Review
- Emerging Issues and Course Completion
Section 6: How should I review worker protection labeling?
Agricultural Use Requirements Box
For products subject to WPS, there are four types of worker protection statements (described below) that generally appear in the directions for use of a label. Each of these statements is positioned in or around the agricultural use requirements box, as noted below.
- Required statements
The following statements must appear on all WPS labels directly after the “Directions for Use” heading and near the beginning of directions for use, but before the agricultural use requirements box.
“Do not apply this product in a way that will contact workers or other persons, either directly or through drift. Only protected handlers may be in the area during application.”
“For any requirements specific to your state or tribe, consult the state or tribal agency responsible for pesticide regulation.”
- Agricultural use requirements referral statement for supplemental labeling
If you put agricultural use requirements on supplemental labeling, the following statement must appear within the agricultural use requirements box, directly under the heading “Agricultural Use Requirements”:
“Use this product only in accordance with its labeling and with the Worker Protection Standard, 40 CFR Part 170. Refer to supplemental labeling under “AGRICULTURAL USE REQUIREMENTS” in the DIRECTIONS FOR USE section for information about this standard.”
- Agricultural use requirements statements
This section contains required statements, restricted entry interval statements, early entry PPE statements, and notification-to-workers statements.
- Required statements
The following statements must appear within the agricultural use requirements box.
“Use this product only in accordance with its labeling and with the Worker Protection Standard, 40 CFR Part 170.”
“This standard contains requirements for the protection of agricultural workers on farms, forests, nurseries, and greenhouses, and handlers of agricultural pesticides. It contains requirements for training, decontamination, notification, and emergency assistance. It also contains specific instructions and exceptions pertaining to the statements on the label [in this labeling] about [use any of the following that are applicable] personal protective equipment, restricted-entry interval, and notification to workers.”
- Restricted entry interval statements
A restricted entry interval (REI) is the time period immediately following a pesticide application during which entry into the treated area is restricted. Restricted entry statement language can be determined by following the steps described in Chapter 10, Section VII.C.2 of the Label Review Manual. You will learn more about REIs later in this section.
- Early entry PPE statements
All products subject to WPS should bear a statement for workers who re-enter the treated area prior to the expiration of the restricted entry interval. To determine early entry PPE statement language, see Chapter 10, Section VII.C.3 of the Label Review Manual.
- Notification-to-workers statements
These statements specify how workers should be notified when certain products have been used in certain work areas. To determine notification-to-workers language, see Chapter 10, Section VII.C.4 of the Label Review Manual.
- Required statements
- Statements for products with both WPS and non-WPS uses
If the label contains or the regulatory assessment document requires entry restrictions, notification requirements, or other instructions similar to WPS requirements that apply to uses not within the scope of the WPS (i.e., non-agricultural uses), there should be a second box on the label with the heading: “Non-Agricultural Use Requirements.”
This box may be placed anywhere in the directions for use section after the Agricultural Use Requirements box and must contain the following statements:
“The requirements in this box apply to uses of this product that are NOT within the scope of the Worker Protection Standard for agricultural pesticides (40 CFR Part 170). The WPS applies when this product is used to produce agricultural plants on farms, forests, nurseries, or greenhouses.”
The non-agricultural use requirements box should also contain all the entry restrictions, notification requirements, or other statements and instructions (except PPE requirements) that apply to the non-WPS uses on the label.
To determine language for elements that appear in the agricultural use requirements box, see Chapter 10, Section VII.C of the Label Review Manual (PDF) (27 pp, 908.04k, About PDF)