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Module 4: Applying the Principles of Pesticide Label Review

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 4

« Page 18 of 24 »

Module Index
Glossary | Resources

Section 5: How should I review mandatory statements for enforceability?

Problematic Mandatory Language

Mandatory statements should not include terms or phrases that could be interpreted as advisory or ambiguous. The following table includes examples of language that is problematic when it appears in statements that are intended to be mandatory.

Avoid EPA views “avoid” as mandatory; however, some users perceive the term as advisory, or see it as a weaker statement than the clear prohibition of “do not.” Reviewers should strongly discourage the use of the word “avoid” for this reason.

Can

May

Should

These verbs are suggestive, rather than imperative. They cause a statement to be advisory rather than mandatory.

Recommendations for Use

General Directions

When “recommended” appears as a header in directions for use, it causes the information in that section to become advisory, not mandatory.

A heading with “general” can be read to imply that application rates or use directions are advisory, which may not be the intention.

Recommended Rates

General Rates

For Professional Use Only

For Commercial Use Only

User limitations must indicate a legally or objectively defined group (e.g., veterinarians, licensed termiticide users, employees of a mosquito control agency).




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