Web-distributed Labeling for Pesticides
As part of a series of initiatives to improve pesticide labeling, EPA has issued a Pesticide Registration Notice on web-distributed labeling. PR Notice 2014-1 outlines a new voluntary process by which registrants can opt to make legally-valid pesticide labeling available online to users.
It is important to note that even after labeling is available online, pesticide containers will continue to bear all required labeling.
Labeling available online - called web-distributed labeling - will allow pesticide applicators to download streamlined labeling, including instructions for the state in which an application will be made and the use site. Labeling accompanying pesticide products in stores can include more than 30 pages of instruction. Web-distributed labeling should improve compliance with the instructions on pesticide labels, by making labels easier to access, read and comprehend. This new process will allow users to access portions of the label such as directions for use, first aid, and environmental statements for certain use sites.
Pesticide Registration Notice 2014-1 provides guidance on how registrants can make legally-valid pesticide labeling available via the internet. The Pesticide Registration Notice includes examples of:
EPA has also developed a Standard Operating Procedure as a companion to the Pesticide Registration Notice. The SOP will guide EPA staff in reviewing applications for products that are intended to include web-distributed labeling.
This "web-distributed labeling system," initially focusing on agricultural and industrial pesticides, will provide simplified container labels and rapid distribution of up-to-date product labeling. We expect to see the following benefits from this system:
- Faster access to new pesticide uses.
- Quicker implementation of public health and environmental protective measures.
- Improved compliance with label directions.
- Lower costs for industry and EPA.
A web-based labeling distribution system is one part of our step-wise approach to improve pesticide product labeling. This approach includes three major components:
- A system that enables EPA to receive labeling submissions from pesticide companies in electronic form and to process them more efficiently and consistently.
- Internal agency procedures to improve clarity and enforceability of labeling content.
- A system for electronic dissemination of the most current approved version of product labeling to users.
How would an applicator know if web-distributed labeling is available for a specific product?
Applicators should consult the labeling for each product they use to determine whether web-distributed labeling is available for the product.
Would web-distributed labeling be for the general public?
Registrants will decide what products will include a web-distributed labeling statement. If the container labeling refers the user to a website where labeling can be downloaded, then the purchasers of that product (including the general public) could download the labeling. We anticipate that registrants initially will include web-distributed labeling references only on labeling for products used by professional applicators.
- How would applicators use web-distributed labeling?
If an applicator has a container that includes a reference to web-distributed labeling and a website, the applicator could visit the website listed on the labeling, input a few pieces of data from the container labeling, and download a legally valid version of the labeling specific to the state and intended use site. This would allow applicators to have a version of the labeling tailored to the intended application. The web-distributed labeling would include all relevant portions of the labeling, such as first aid and precautionary statements, but only the use instructions requested by the applicator.
- How would web-distributed labeling benefit applicators and improve compliance?
Web-distributed labeling will benefit applicators/users by allowing them to download more streamlined versions of the labeling. Shorter labeling, tailored to the specific use site, will be easier to read and follow, increasing compliance. In addition, applicators can access newer versions of the labeling via the website, which may include additional uses, before container labeling incorporating the new use is available for purchase.
- Where will web-distributed labeling be available? Will it appear on registrants’ web pages?
Web-distributed labeling is a voluntary program for registrants. Each registrant will decide whether and how to implement web-distributed labeling for its products. If a registrant chooses to offer web-distributed labeling, the container labeling will reference a specific website where the web-distributed labeling can be downloaded. Some registrants may choose to use their current web pages, while others may opt to create a specific website for their web-distributed labeling pesticide products. The applicator/user must follow the labeling on each container’s labeling in order to access web-distributed labeling for the product, if it is available.
The Agency team began exploring the issues associated with distributing pesticide labeling via the Internet in 2007. EPA engaged in informal discussions about the concept of web-distributed labeling with stakeholders. Team members presented this topic at the Pesticide Program Dialogue Committee (PPDC) meeting in May 2008. In October 2008, a "Web-Distributed Labeling Work Group" was formed under the PPDC. The PPDC Workgroup provided feedback on various issues related to the potential web-distributed labeling system, such as web-distributed labeling’s lifespan, content, eligible products, benefits, website functionality, and enforcement. Go to EPA's Web Archive for more information on the workgroup Search EPA Archive.
In December 2010, EPA requested formal comment on the initiative to distribute labeling electronically through a Federal Register notice.
Based on the input and advice of the PPDC Web-Distributed Labeling Workgroup, EPA conducted a "User Acceptance Pilot" to research the extent to which users would want to use a system enabling them to obtain labeling via the Internet. The specific goal of the pilot was to determine whether the benefits of web-distributed labeling would be sufficiently appealing to make users willing to visit a website to obtain labeling for a pesticide product. The pilot demonstrated how users could access labeling information using the website and did not involve the actual distribution of pesticide product labeling.
On August 18, 2010 EPA published a Federal Register Notice inviting participation in the pilot.
Greenbook, a marketing research company, volunteered to develop a website for users to test aspects of web-distributed labeling without requiring labeling changes in the field and made the website public in December 2010. The American Association of Pesticide Safety Educators (AAPSE), a PPDC workgroup member, developed a survey for pilot website users that was accessible through the pilot website. The pilot ran through April 2011. View the draft results of the survey on the AAPSE website under "Links", bullet 13. Exit
In January 2013, EPA published a draft Pesticide Registration Notice outlining the process by which registrants could make a product’s labeling available via the Internet (web-distributed labeling) and asked for public comment. The comment period closed on April 16, 2013, and comments were considered in the development of the final Pesticide Registration Notice.
For more information on EPA's activities on web-based distribution of pesticide labels and labeling contact: