Label Review Training: Module 1: Label Basics, Page 26
Section 7: What are the principles of pesticide label review?
Mandatory Statements Versus Advisory Statements
Mandatory statements are intended to be enforceable. They generally relate to the actions that are necessary to ensure the proper use of the pesticide and to prevent the occurrence of “unreasonable adverse effects on the environment”, which is defined by statute (FIFRA sec. 2).
Mandatory statements include directions for use and precautions that direct the user to take or avoid specific actions. The directions and precautions specify where, when, and how a pesticide is to be applied. Mandatory statements are generally written in imperative or directive sentences. For example:
- Wash application equipment...
- Do not use ...
- Users must...
- Apply to corn at a maximum rate of two pounds per acre at least 30 days prior to harvest.
When the intent is to prevent an adverse effect from some action, use a clearly mandatory phrase such as “do not...,” rather than the word “avoid.” “Avoid” may be seen as only advisory by some users.
Either EPA or the registrant may develop mandatory labeling statements. When writing mandatory statements, both EPA and the registrant need to ensure that such statements are necessary to ensure proper use of a pesticide and to prevent unreasonable adverse effects.
Advisory statements are intended to be informational. They provide information to the product user on such topics as product characteristics and how to reduce risk and maximize efficacy while using the product. Such statements are acceptable as long as they do not conflict with mandatory statements, and are not false or misleading, or otherwise violate statutory or regulatory provisions.
Advisory statements are best written in factual or nondirective terms. Effective advisory statements give the user a positive reason for performing or not performing an action, rather than simply saying they “should” or “may” do something. Terms such as “should,” “may,” and “recommend” are not forbidden, and might be appropriate in some situations, but EPA and the registrant need to be sure that the intent to be non-enforceable and purely informational is clear.