The following are frequently asked questions and corresponding answers about the bilingual labeling requirements in PRIA 5. This is a living document and will be updated as questions arise during the implementation of PRIA 5.

This Q&A is intended to be a compliance aid and does not take the place of reading the regulations.

1. Do the requirements for bilingual labeling apply to the entire label, or just certain sections?
   • Registrants may translate an entire label, however, only the health and safety sections of the pesticide product labels are required to be translated. Specifically, PRIA 5 specifies that the following sections of the label included in the Agency’s Spanish Translation Guide for Pesticide Labeling (or Spanish Translation Guide) must be translated for each registered pesticide product released for shipment. Three of these sections below are new additions in the 2024 release of the Spanish Translation Guide:
     • “Keep out of reach of children” statement (KOOROC) statement)
     • Restricted Use Pesticide (RUP)
     • Misuse statements
     • Signal word
     • First Aid statements
     • Precautionary statements
     •  Personal Protective Equipment (PPE) requirements
     • Engineering Controls (NEW in 2024)
     • Environmental Hazards (NEW in 2024)
     • Physical or Chemical Hazards language (NEW in 2024)
     • Storage and disposal instructions and container handling statements
2. Do registrants have to use the language as provided in the Spanish Translation Guide for Pesticide Labeling? For labels already translated into Spanish, do translations need to be updated to correspond with the Spanish Translation Guide?
   • EPA encourages use of the language in the Spanish Translation Guide to assist with the requirement for Spanish labeling to be “true and accurate.” However, use of the specific language from the Spanish Translation Guide is not required. The registrant must ensure that “true and accurate” Spanish translations are included for each section of the label that is included in the Agency’s Spanish Translation Guide. Labels that have been translated to Spanish prior to the passage of PRIA 5 do not need to be updated or retranslated, provided that they meet the PRIA 5 bilingual labeling requirements. As the Spanish Translation Guide is updated in the future, the registrant is responsible for ensuring labels incorporate translations for all sections in the updated guide.
3. When are Spanish translations required to be updated on product labels?
   • PRIA 5 provides a timetable for when labels will be required to be updated with the Spanish translations (or a link to the translation via scannable technology or other electronic methods readily accessible on the product label).

PRIA 5 Bilingual Labeling Requirements

4. As EPA updates the Spanish Translation Guide with additional translations over time, would this automatically change the label language requirements, or would there be a timetable for phasing these in? How will EPA communicate changes/updates to the Spanish Translation Guide?
   • As the Spanish Translation Guide is updated in the future, the registrant is responsible for ensuring labels incorporate translations for all required sections in the updated guide according to the timing outlined in PRIA 5.
   • PRIA 5 provides a timetable outlining when labels will be required to be updated depending on the type of product (agricultural versus non-agricultural).
     • For agricultural use pesticide labels, companies must update their product label with the new information within one year after the date of publication of the updated Spanish Translation Guide for Pesticide Labeling or the latest EPA approved label (whichever is earlier).
     • For antimicrobial and non-agricultural use pesticide labels, companies must update their product label with the new information within two years after the date of publication of the updated Spanish Translation Guide for Pesticide Labeling or the latest EPA approved label (whichever is earlier).
   • PRIA 5 requires the Agency to notify registrants within 10 days of updating the Spanish Translation Guide for Pesticide Labeling. Notification will be given through a Federal Register Notice and an OPP Update within 10 days of the publication date.
5. Does the Spanish translation need to appear on the end use product label? What about technical product labels (manufacturing use products)?
   • The Spanish language translation must appear on the product container or a link to such translation via scannable technology or other electronic methods readily accessible on the product label.
   • The bilingual labeling requirements of PRIA 5 applies specifically to end-use product labels and does not impose bilingual labeling requirements on technical labels (manufacturing use products).
   • For end use product labels, the registrant has the option of either including the Spanish language translation on the product container or a link to such translation via scannable technology or other electronic methods readily accessible on the product label.
   • There are exceptions for antimicrobial pesticide products and non-agricultural/non-RUP pesticide products. For these categories, compliance can be achieved through labeling that includes a link to the safety data sheets (SDS) in Spanish via scannable technology or other electronic methods readily accessible on the product label in lieu of including a translation or a link to the label translation.
6. Are FIFRA 25(b) products subject to the PRIA 5 bilingual labeling requirements?
   • Minimum risk pesticides (40 CFR 152.25(f)) are exempt from registration requirements of FIFRA (apart from meeting the conditions for the exemption itself). Therefore, they are not under obligation to meet the PRIA 5 bilingual labeling requirements in FIFRA.
7. Are devices subject to the PRIA 5 bilingual labeling ?
   • Devices (40 CFR 152.500) are not required to be registered under FIFRA Section 3. Therefore, they are not under obligation to meet the PRIA 5 bilingual labeling requirements in FIFRA.
8. Since internet access may be a problem for some pesticide users, can the translated text be placed on the label?
   • Yes, the Spanish translation can be included on the label if the registrant chooses to do so. Physical labels would be helpful to facilitate the availability of Spanish labeling in areas that do not have access to the internet or cell phone service.
9. Label changes will be done through non-notification. What does this mean?
   • Non-notification means that changes may be made to a pesticide label without notifying EPA. Label submissions requesting approval of Spanish labels or including placeholder notes to the reviewer referring to the allowance for future Spanish translation will not be reviewed or acknowledged as notifications or amendments by EPA.
10. Is a full label translation still done through non-notification? Would a full label translation require a PRIA action and label review by EPA?
    • Registrants can choose to translate the full label, though only the sections of the label included in the Spanish Translation Guide are required to be translated by PRIA 5. Label changes involving only the incorporation of translations, irrespective of scope, can be made without notifying EPA.
11. If labels are being updated through non-notification, who is responsible for ensuring the accuracy in the translation/labeling?
    • The registrant is responsible for ensuring that the translation is true and accurate. However, in the context of supplemental distribution, the distributor is considered an agent of the registrant for all intents and purposes under FIFRA, and both the registrant and the distributor may be held liable for violations pertaining to the distributor product.
12. Could states expedite reviews of bilingual label revisions if a registrant provides an affidavit that certifies the sole modification made to the label was the translation of the existing label text into Spanish?
    • It is up to the individual state if will accept an affidavit or self-certification.
13. How will the implementation of bilingual labeling requirements in PRIA 5 be a collaborative process?
    • The Agency has conducted various meetings, webinars and focus groups with a variety of stakeholders. The Agency is planning to continue to work with states, industry and the public on developing implementation plans for the various bilingual labeling requirements of PRIA 5. These implementation plans include a process to help make pesticide product labels accessible to farmworkers and other pesticide users and tracking labels translated into Spanish.
14. Why are only the health and safety sections of the label included for translation?
    • PRIA 5 requires the translation of the parts of the labeling included in the Spanish Translation Guide for Pesticide Labeling. The Spanish Translation Guide contains the health and safety sections of pesticide labels. The Spanish translations ensure that workers have access to important information to protect themselves and others from pesticide exposure, protect the environment, and to get appropriate help if exposed to a pesticide product. The remaining sections on the pesticide label can be translated if the registrant choses to do so.
15. If a non-RUP pesticide product has both agricultural and non-agricultural uses, should this product follow the timeline for Spanish translation as an agricultural product?
    • Yes, if more than one pesticide product type for bilingual labeling could apply to a specific product, the earliest deadline would apply to the product.
16. Will bilingual language be required on the state pesticide applicator certification plans? Will states be required to have applicator certification training material in Spanish and Spanish speaking trainers?
    • There’s no requirement for states to have Spanish versions (bilingual language) in their pesticide applicator certification plans and states are not required to provide training material in Spanish.
    • States can choose to develop materials and deliver in other languages, as long as the requirements of the applicable regulation (Certification of Pesticide Applicators [40 CFR §171]) are met in full.
17. What is the acceptable web site configuration and the requirements for posting Spanish label translations electronically?
    • There are no requirements for the configuration, format, or layout of the website where the Spanish translation is available, so long as the Spanish translation is readily accessible electronically through scannable technology or other electronic methods.
18. According to PRIA 5 the Spanish translation can be available via scannable technology or other electronic methods readily accessible on the product label. On pesticide labels, can registrants add a QR code or website link to the Spanish translation via non-notification?
    • Yes, the QR code or website link can be added to the label via non-notification if it includes only the Spanish translation. Any other QR code information must be submitted to the Agency for review.
19. Does the QR Code need to be linked to the registrant’s website or can the website be maintained by a third party?
    • There is no requirement under PRIA 5 for where the QR code links to as long as the Spanish translation is readily accessible; therefore, the Spanish translation can be linked to the registrant’s website or a website maintained by a third party. However, the registrant and distributor engaged in supplemental distribution of the pesticide product, are responsible for ensuring the translation is true and accurate regardless of whether the website containing the translation is maintained by a third party.
20. Can one QR code or website address be created for one company where the user can search across multiple products, or does it need to be one unique QR code or website per product?
    • Although PRIA 5 does not specifically address whether one QR code or website address can contain multiple product translations, the statute requires a link to a translation via scannable technology or other electronic methods be “readily accessible”. The Agency’s preferred approach is for there to be one unique QR code or website linked to the Spanish translation per product.
21. Pesticide users are unlikely to know to utilize a QR code for Spanish labeling without label language explaining what the QR code will show. Can brief explanatory and pointer statements regarding the QR code also be added to the label by non-notification?
    • Yes. Near the QR code, text (pointer language) can be provided that explains the purpose of the QR code as long as the text is only for the Spanish translation. For example: “Scan QR Code for Spanish Label” translated to “Escanee el código QR para la etiqueta en español” or other similar phrases explaining the purpose of the QR code. Such pointer language can be added to the label via non-notification, as long as the QR code is only for the Spanish translation.
22. What happens if a label does not have the Spanish translation?
    • The registrant must ensure that the labels include Spanish translations of the required elements, or a link to such translation via scannable technology or other electronic methods, and that they are readily accessible. If the label does not include the translations, the product will be considered misbranded pursuant to section 2(q) of FIFRA. 
23. What do state lead agencies (SLAs) do if they find issues with the translation and scannable codes, or lack thereof? Does EPA have a plan to address issues with translations and codes when states bring problematic labels to EPA’s attention? 
    • SLAs should share concerns and findings with EPA through existing communication channels. Regional offices typically designate points of contact as a function of roles in administering state/EPA cooperative agreements. First points of contact are often called project officers or technical contacts. However, titles and communication protocols may vary from one office to another. If uncertain about who the designated contacts for your SLA are, please reach out to the manager of the organizational unit within the relevant regional office with whom you most frequently interact on issues involving your cooperative agreement. In cases involving widespread circumstances, EPA will engage the broader SLA community through established forums. 
24. How will misuse be handled when misuse could have been the result of not having Spanish translations on end use labels or possibly due to those translations being inaccurate? 
    • Misuse will be handled using the existing mechanisms. Use related enforcement in states and territories is governed by the primacy framework established under sections 26 and 27 of FIFRA (7 USC 136w-1 and 2). Tribes are not eligible for primacy. In Indian Country, tribes can enforce applicable tribal code. However, EPA enforces FIFRA. 
25. How will compliance with the bilingual labeling provisions of PRIA 5 be monitored, and if the provisions are not followed, how will they be enforced? 
    • EPA and state enforcement agencies will continue to follow their existing compliance monitoring and enforcement processes. The agency has developed a plan to track the adoption of bilingual labeling. EPA intends to make this information publicly available via a website or other means. 
26. Can supplemental distributors include bilingual label language and other label elements necessary to comply with PRIA 5 via non-notification (QR codes, etc.) even if it varies from the master label? 
    • No, there have been no changes to supplemental distributor labeling regulations (40 CFR 152.132). Registrants and supplemental distributors should work together to ensure compliance with PRIA 5 and the regulations. 
27. Can the registrant of the master label and the sub-registrants of supplemental distributor labels use different methods for placing their Spanish translations on their products? For example, if one uses a QR code, can the other place the translation directly on to the product container? 
    • No, there have been no changes to supplemental distributor labeling regulations (40 CFR 152.132). Registrants and supplemental distributors should work together to ensure compliance with PRIA 5 and the regulations. If the master label uses a QR code, the supplemental distributor label must use a QR code. Supplemental distributor labels may only vary from master labels in 5 specific ways as listed at 40 CFR 152.132. 
28. Can a registrant submit a label with Spanish language text through notification to be reviewed? 
    • PRIA 5 specifies that bilingual labeling be implemented via non-notification and as such, registrants should not submit Spanish translations as a notification for EPA review. For additional information on what qualifies as a notification refer to PRN 98-10. 
29. How will EPA handle subsequent label changes after Spanish was added to labels through non-notification? 
    • FIFRA Section 3, PRIA 5 bilingual labeling requirements specify that the addition of Spanish to the labels be implemented via non-notification. PRIA 5 does not require any change to the process for amendments and notifications. The Office of Pesticide Programs will not review the bilingual labeling text as part of the routine registration process. 
30. If the QR code is placed on the master label, does a specific webpage need to be listed, or can a placeholder be included on the label to submit the label to EPA for review? 
    • No, the agency neither requires that the master label identify a webpage for a QR code nor include a placeholder for a QR code when submitted for review. QR codes or webpages that only link to the bilingual labeling can be placed on a label via non-notification. EPA’s Office of Pesticide Programs (OPP) will not review the bilingual sections of labels if submitted to the agency for review as part of the routine registration process. 
31. Are QR codes and webpage links on the product label considered labeling? 
    • Yes, everything on the product label and the linked webpages are considered labeling, as defined under FIFRA § 136(p)(2). 
32. Once a QR code is added to the label via non-notification, is there any issue with the QR code being on the subsequent master label submission? 
    • Since PRIA 5 states Spanish translation updates should be done via non-notification, QR codes leading to Spanish translations should only be included on the final printed label. 
33. A label may already have an existing QR code or website address that is used for a reason other than bilingual labeling. Can the required Spanish translation be posted as a prominent link on that existing website versus adding an additional QR code or website address to the label? 
    • PRIA 5 does not require that the QR code or web address only link to the Spanish translation. However, it does require that the translation be “readily accessible.” For this reason, EPA prefers that registrants use a separate QR code for the required Spanish labeling. If a registrant chooses to use an existing website or QR code for all labeling – including Spanish labeling – the required Spanish translations should appear on the first page of the linked website, be clearly labeled, identifiable as the Spanish labeling required under PRIA 5 and separated from all other website labeling, to ensure that it is “readily accessible”. Note that, a QR code (or other electronic method) containing the Spanish translation is to be submitted via non-notification. 
34. Is there a requirement for the size of the QR code on the label? 
    • There is no requirement for the size of the QR code, however, it should be legible and accessible. The pointer statement (the posted text explaining the purpose of the QR code) has a minimum size requirement of at least 6-point type (40 CFR 156.60). 
35. Must the pointer statement, specific to bilingual labeling, be near the QR code to be a non-notification? 
    • Pointer statement refers to text or pointer language that explains the purpose of the QR code. Although PRIA 5 does not specifically address where the location of the pointer statement should be in relation to the QR code, the agency prefers for the pointer statement to be near the QR code, to facilitate access and understanding. 
36. Can pointer language be used to assist the reader in finding Spanish text on a label? 
    • Pointer language can be added at the discretion of the registrant to direct the user to Spanish translations on a different part of the pesticide product label.
    • For QR codes with Spanish translations, pointer language should be near the QR code. 
37. When new language is added to labels in English that coincides with the sections that need to be translated, should these changes be added to the Spanish translations via non-notification? 
    • Yes, if a registrant updates or revises their English label text, they should add the corresponding Spanish translations to their label via non-notification after the English text is approved. 
38. When referring to the PRIA 5 deadlines for bilingual labeling, what is an agricultural product? What is the difference between non-agricultural products versus ‘all other pesticide products’? Are animal products, considered to be non-agricultural or an ‘all other pesticide product’? 
    • An “agricultural product,” for the purpose of PRIA 5 bilingual labeling requirements, is a product that includes an “Agricultural Use Requirements” statement. Pesticide products may be labeled with either an “Agricultural Use Requirements” statement and/or a “Non-Agricultural Use Requirements” statement in the “Directions for Use” section of the label. Whenever a pesticide product bears "Agricultural Use Requirements" statements on a label, it requires compliance with the Agricultural Worker Protection Standard (40 CFR 170) -- that is, employers and handlers must follow certain requirements when the product is used in the production of agricultural plants on an agricultural establishment. (Agricultural plant means any plant grown or maintained for commercial or research purposes and includes, but is not limited to, food, feed, and fiber plants; trees; turfgrass; flowers, shrubs; ornamentals; and seedlings). An agricultural establishment means any farm, forest operation, or nursery engaged in the outdoor or enclosed space (e.g., greenhouse) production of agricultural plants (See 40 CFR 170.305.). Even if the product in question is not exclusively used in the production of agricultural plants on agricultural establishments, it is still considered an agricultural product if the label includes an agricultural use statement.
    • ‘All other pesticide products’ (for purposes of PRIA 5 deadlines for Bilingual Labeling categorization) are agricultural, antimicrobial, and non-agricultural pesticide products, classified as acute Toxicity Categories III and IV as well as any other pesticide products not described above.
    • Animal products are either products used on domestic animals (pets) or livestock. Because the definition of “agricultural use product” generally aligns with the Worker Protection Standard, animal products, regardless of species or use, are not agricultural products. Animal products’ PRIA 5 deadlines for bilingual labeling are dependent on their Toxicity Category, found in 7 U.S.C. § 136a(f)(5)(B)(ii)(II). 
39. Does the registrant need a dedicated link for each product that goes directly to that specific product’s safety data sheet (SDS), or can the link be to an SDS landing page that contains all the registrant’s SDSs? 
    • PRIA 5 does not specifically address whether one QR code or website address can contain multiple product translations. However, the statute does require that the link to the translation (whether via scannable technology or other electronic methods) be “readily accessible.” The agency’s preferred approach is for there to be one unique QR code or website linked to the Spanish translation per product, to ensure that the label translations are “readily accessible.” This would also apply to QR codes or website addresses for the SDS in Spanish. 
40. Which pesticide products may provide SDSs in Spanish? Do specific SDS statements need to be included on the EPA master label?
    • Antimicrobial pesticide products and non-agricultural pesticide products that are not classified as restricted use may, in lieu of including a translation, provide a link to the SDS in Spanish (PRIA Section 702.5 (B.ii) (I &II)). SDSs are viewed as labeling pursuant to PR Notice 92-4 (pursuant to 7 USC 136(p))).
    • No, PRIA 5 does not require that specific SDS statements appear on the master label. Rather, PRIA 5 requires that implementation be via non-notification with a link to a Spanish translation via scannable technology or other electronic methods “readily accessible” on the end use product label. 
41. On all Toxicity Category 1 (DANGER) products (agricultural and antimicrobial), where do the Spanish First Aid label statements need to appear on the product container in relation to the English version of the First Aid labelOf  statements? 
    • Pursuant to 40 CFR 156.60, First Aid and other precautionary statements have placement requirements. The Spanish translation of these statements should follow the same placement requirements as the English version of the First Aid label statements, per 40 CFR 156.10(a)(3). For example, according to 40 CFR 156.68, the first aid statement must appear on the front panel of the label of all products assigned to Toxicity Category 1 products. Variance of the First Aid Statement placement on the label may be permitted upon review of the English version of the statements. Unless a variance in placement is approved, the English and Spanish First Aid Category 1 products must appear on the front panel of the label. Both English and Spanish versions of the First Aid statement must appear on the label through text. All remaining translated portions of the label may appear through text or a link to such translation via scannable technology or other electronic methods readily accessible, provided compliance with location/placement requirements outlined in 40 CFR 156.
    • As noted in the 40 CFR 156.60, the Agency may permit reasonable variations in the placement of the first aid statement if a reference such as “See first aid statement on back panel” appears on the front panel. All proposals for variances to First Aid Statements must be submitted and approved as an amendment for the English version of the statements prior to translating into Spanish. The Spanish translation may be added via non-notification following the approval of the English version of the statement. 
42. Can the registrant request a variance in the location of the Spanish translation of the First Aid label statement? 
    • As noted in the 40 CFR 156.60, the Agency may permit reasonable variations in the placement of the first aid statement if a reference such as “See first aid statement on back panel” appears on the front panel. All proposals for variances to First Aid Statements must be submitted and approved as an amendment for the English version of the statements prior to translating into Spanish. The Spanish translation may be added via non-notification following the approval of the English version of the statement. 
43. For registrants who elect to provide the Spanish translation through QR codes or electronic links, must the First Aid label statement on a Category 1 (DANGER) product appear on the front panel of the container label? Or is the translated First Aid label statement allowed to only appear within the linked translation? 
    • Under PRIA 5, bilingual translations may appear on the product label or via a scannable technology or electronic link. However, the First Aid statement on Category 1 (DANGER) products needs to follow the regulations under 40 CFR 156.68. Therefore, the First Aid label statement on Category 1 (DANGER) products must appear on the front panel of the container label as text, unless a placement variance is granted. All other required translated sections of the label may be included via a QR code, provided compliance with location/placement requirements outlined in 40 CFR 156. 
44. If the registrant is choosing to use QR codes for products that have multiple components, such as a bottle, a booklet or leaflet, and an outer packaging (not a shipping container), is the QR code required to be stickered onto all components? 
    • QR codes can be added by sticker. However, the stickering needs to be done in an EPA producing establishment and not at the distributor.
    • The sticker must also follow requirements for label placement—i.e., Spanish labeling may be added through a stickered QR code, provided the labeling statements comply with location/placement requirements outlined in 40 CFR 156.
    • The sticker cannot be removable and must last the lifetime of the label (156.10(a)4).
    • For products that have multiple components, the QR code stickering should be included on all components of the product that include health and safety information. 
45. Could the Spanish translation be given in an audio and/or visual (such as a video with subtitles) translation in addition to the written translation? 
    • Although not specified under PRIA 5, registrants may link to an audio and/or visual translation (as long as the translation is deemed true and accurate) in addition to, but not as a replacement for, the written translation (pursuant to 7 USC 136(p)). The use of audio and/or visual translations is optional. 

46. What format is acceptable for providing multiple languages on a label? For instance, can labels do the following: 

    • Display all sections of the label first in English and then all the required sections in Spanish afterwards or in a separate section?
    • List bilingual text section by section where needed (i.e., all Precautionary Statements provided in English, then Spanish, then all Environmental Hazards in English, then Spanish)?
    • List bilingual text side-by-side (English on left and Spanish on right)? 

    There is no prescribed format in PRIA 5. The registrant should select one of the above options and be consistent within a label with the approach that is selected. However, all translations should comply with location/placement requirements outlined in 40 CFR 156. 

47. What do the PRIA 5 bilingual labeling deadline dates refer to (i.e., date released for shipment, date submitted to states, date that product is out in channels of trade)? 
    • The PRIA 5 deadline for bilingual labeling refers to when a registered product or supplemental distributor product, is released for shipment. A product becomes released for shipment when the producer has packaged and labeled it in the manner in which it will be distributed or sold, or has stored it in an area where finished products are ordinarily held for shipment (40 CFR 152.3). Under FIFRA, only a registrant can amend labels/labeling. 
48. If registrants already submitted Spanish bilingual labeling to their state for the state registration review process, will they have to update their labeling when the Spanish Translation Guide is updated? What is the deadline for registrants to comply with the new updates on the Spanish Translation Guide? 
    • With every updated version of the Spanish Translation Guide that is published, registrants will have one year from that date for agricultural pesticide products, and two years from that date for non-agricultural pesticide products to add Spanish translations for the new required sections of their pesticide labels; in accordance with PRIA 5 (FIFRA section 3(f)(5)(C)(iv), 7 U.S.C. § 136a(f)(5)(C)(iv)). The December 2024 version of the Spanish Translation Guide does not affect or change the implementation deadlines provided in PRIA 5. 
49. Do antifoulant paints qualify for the PRIA 5 antimicrobial exception to provide translated SDSs? 
    • Yes, antifoulant paints that are registered as antimicrobial pesticides fall under a PRIA 5 antimicrobial exception and may, in lieu of including a translation or a link to the translation, provide a link to the SDS in Spanish via scannable technology or other electronic methods readily accessible on the product label. 
50. If an RUP statement is based on environmental hazards (such as toxicity to aquatic organisms) and not on acute toxicity to humans, does that portion of the RUP statement need to be translated into Spanish as well? 
    • Yes, the December 2024 version of the Spanish Translation Guide includes translations of the RUP statement for environmental hazards. Therefore, that section of the label must be translated into Spanish as well. Restricted Use Classification statements (40 CFR 156.10(j)(2)) must be translated into Spanish regardless of the reason for classification. 
51. Do the PRIA 5 bilingual labeling requirements replace the Spanish labeling requirements for foggers? 
    • No, fogger Spanish labeling requirements are mostly for the ‘Directions for Use’ section of the label. Spanish translation requirements under PRIA 5 do not supersede any underlying Spanish labeling requirements deemed necessary to protect the public (40 CFR 156.10(a)(3)), such as those that have been approved for foggers.