Label Review Training: Module 1: Label Basics, Page 25
Section 7: What are the principles of pesticide label review?
By the end of this section, you will be able to:
- List and describe the four core principles of pesticide label review.
- Compare and contrast mandatory statements and advisory statements.
EPA's decision to register a product is based in part on the assumption that mandatory use directions, restrictions, and precautions will be followed, and that enforcement action can be taken if they are not. Thus, the primary customers for labeling are users and enforcers. In approving any label, the needs of these customers are the essential considerations for EPA staff. To meet these needs, label reviewers must ensure that every label adheres to the four core principles, which are listed below as well as discussed in greater detail in Module 4.
Above all else, labels must be understood. To achieve clarity, use logical organization and avoid jargon and ambiguous terms.
Labels must be accurate. Label reviewers must verify the accuracy of label requirements, product reviews, directions for use, and label rates.
- Consistency with EPA policy
Labels must be consistent with all relevant EPA policies. Labels must not deviate from these policies without management approval. To ensure consistency with EPA policies, refer to the Label Review Manual and to underlying regulations and policy documents.
Labels must be enforceable by OECA, EPA Regions, states, and tribes. In order for a label to be enforceable, there must be no confusion about intention of statements.