Label Review Training: Module 4: Applying the Principles of Pesticide Label Review, Page 18
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. |
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Can May Should |
These verbs are suggestive, rather than imperative. They cause a statement to be advisory rather than mandatory. |
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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. |
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Recommended Rates General Rates |
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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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