Environmental Hazard and General Labeling for Pyrethroid and Synergized Pyrethrins Non-Agricultural Outdoor Products
On this page:
- Overview of Initiative
- Specific "Environmental Hazard Statements" and “Directions for Use” for Pyrethroid and Synergized Pyrethrins Non-Agricultural Outdoor Products
- Timeframe for Labeling
- Guidance for Implementing
Overview of Initiative
January 2013 Optional Revisions to Environmental Hazard and General Labeling for Pyrethroid and Synergized Pyrethrins Non-Agricultural Outdoor Products
On January 10, 2013, in response to feedback from states and stakeholders, EPA approved certain optional modifications to the “Environmental Hazard Statements” and general “Directions for Use” for pyrethroid and pyrethrins non-agricultural outdoor products. Registrants have the option of including the approved label language on their pyrethroid and synergized pyrethrins non-agricultural outdoor products intended for occupational use. These optional revisions are intended to enhance the capability of professional pest control operators (PCOs) to treat for overwintering pests that gather in groups (or “occasional invaders”) such as brown marmorated stink bugs and kudzu bugs. The revisions allow PCO applications that are larger in size than spot or crack and crevice treatments in certain situations. Treatments to large structural areas above impervious surfaces are still prohibited, limiting the potential for runoff or drift to urban surface water.
EPA has also approved a similar set of optional label modifications for non-agricultural outdoor products containing only the active ingredient pyrethrins, formulated without synergists or other pesticides. For synergized pyrethrins products containing MGK-264 or piperonyl butoxide, however, labels may only be revised to include the optional pyrethroid modifications.
The new optional label modifications allow the agency to meet our ecological protection goals while giving occupational applicators needed flexibility to address their pest control needs.
EPA’s January 10, 2013, Letter to Registrants re: Revisions to Environmental Hazard and General Labeling for Pyrethroid Non-Agricultural Outdoor Products, and Revised Label Table
EPA’s 2009 Pyrethroid and Pyrethrins Labeling Initiative
To reduce ecological exposure from residential uses of pyrethroids and pyrethrins products, EPA implemented a labeling initiative to revise the “Environmental Hazard Statements” and general “Directions for Use” for pyrethroid and pyrethrins pesticide products used in non-agricultural outdoor settings. The revised label statements reduce the potential for runoff and drift that can result from applications of pyrethroid and pyrethrins end-use products by both professional pesticide control operators and residential consumers in residential, commercial, institutional, and industrial areas. The label statements spell out good stewardship and best-management practices and clarify how these types of products are intended to be used. As discussed above, we approved minor optional modifications to several labeling statements in January 2013 in response to stakeholder feedback and to specifically address the unique needs of PCOs to treat for overwintering pests.
This labeling initiative affects over 2,000 end-use products. EPA’s analysis demonstrates that these label statements serve to protect aquatic habitats and the environment. While much of the information on this page is designed to help pesticide manufacturers understand the labeling changes, we encourage consumers to follow these common sense measures, described in the box above, to help protect valuable water resources.
During initial implementation of the labeling initiative in 2009, the new “Environmental Hazard Statements” and general “Directions for Use” statements were included in the revised label tables for pyrethroids that were subject to reregistration [allethrins, cypermethrin, permethrin, tau-fluvalinate, resmethrin, sumithrin (d-phenothrin), and tetramethrin] and, due to their many similarities, for pyrethrins products as well. For those pyrethroid active ingredients that were not subject to reregistration, EPA mailed a letter outlining the label changes to all pyrethroid registrants requesting the changes be incorporated onto their appropriate pyrethroid end-use products' labels.
Specific "Environmental Hazard Statements" and “Directions for Use” for Pyrethroid and Synergized Pyrethrins Non-Agricultural Outdoor Products
Current “Environmental Hazard Statements” and “Directions for Use” label language for non-agricultural outdoor products containing pyrethroids and synergized pyrethrins is captured in the Label Table, Environmental Hazard and General Labeling for Pyrethroid Non-Agricultural Outdoor Products – Revised January 10, 2013 included in EPA’s January 10, 2013 letter.
Environmental Hazard Statements
The consumer use of pesticide products differs significantly from the use of pesticides in agricultural production. However, many of the label statements on residential use products were originally developed for agricultural users or professional applicators. EPA believes these statements may be irrelevant or confusing to consumers.
In an effort to make consumer labels easier to understand and follow, the agency developed Pesticide Registration (PR) Notice 2008-1, "Environmental Hazard General Labeling Statements on Outdoor Residential Use Products." PR Notice 2008-1 provides guidance on environmental hazard label language for certain non-restricted use pesticide products intended for outdoor residential use. The agency’s pyrethroid and pyrethrins labeling initiative incorporates the environmental hazard label language established in PR Notice 2008-1.
The specific label statements recommended in PR Notice 2008-1 are intended to improve existing labels by clarifying language on what the user should do to avoid potential environmental contamination. The agency believes that adoption of these recommendations by all registrants, including pyrethroid and pyrethrins registrants, helps pesticide users better understand how to use consumer products and minimize environmental hazards.
One example of an “Environmental Hazard Statement” implemented through this labeling initiative is:
"To protect the environment, do not allow pesticide to enter or run off into storm drains, drainage ditches, gutters or surface waters. Applying this product in calm weather when rain is not predicted for the next 24 hours will help to ensure that wind or rain does not blow or wash pesticide off the treatment area. Sweeping any product that lands on a driveway, sidewalk, or street, back onto the treated area of the lawn or garden will help to prevent runoff to water bodies or drainage systems."
The PR Notice 2008-1 environmental hazard statements are formulation-specific, which means appropriate best management practices are specified for the application of liquid, dust, granular, and ready-to-use products. For example, the environmental hazard statement above applies specifically to granular end-use products.
Directions for Use
The general “Directions for Use” included in this labeling initiative are considered to be best management and good stewardship practices, which, like the “Environmental Hazard Statements” discussed above, minimize ecological exposure. Some of the “Directions for Use” labeling applies solely to preconstruction termiticide applications, which are applied only by professional pesticide control operators.
One example of a “Directions for Use” statement implemented through this labeling initiative is:
"Apply this product directly to the lawn or garden area. Water treated area as directed on this label. Do not water to the point of runoff."
Timeframe for Labeling
On June 4, 2009, EPA notified all pyrethroid registrants by letter, requesting that they adopt these label statements on their products containing pyrethroid active ingredients with registered uses on non-agricultural outdoor areas by June 4, 2010. Updated product labels were submitted to EPA throughout 2010 and 2011, and products containing the new language started reaching the market shortly thereafter.
The agency’s January 10, 2013 Letter to Registrants made only minor, optional revisions to the 2009 label statements, and for that reason, no timeframe for implementation was specified in that letter.
Guidance for Implementing
Since 2009, EPA has received inquiries from various stakeholders requesting clarification on language used in the agency's pyrethroid and pyrethrins non-agricultural outdoor products labeling initiative. In response to these questions, EPA provided interpretive guidance which could apply more generally and may be of interest to other states and stakeholders. The inquiries, in part, prompted the optional updates to labeling included in the agency’s January 10, 2013 Letter to Registrants and Revised Label Table.
- EPA’s January 10, 2013 Letter to Registrants re: Revisions to Environmental Hazard and General Labeling for Pyrethroid Non-Agricultural Outdoor Products, and Revised Label Table
- EPA's June 28, 2012 response to ASPCRO
- ASPCRO's June 13, 2012 inquiry
- EPA's May 22, 2012 response to OPMA
- OPMA's April 9, 2012 inquiry
- EPA's May 21, 2012 response to NPMA
- NPMA's April 13, 2012 inquiry
- EPA's October 25, 2011 response to CDPR
- CDPR's August 4, 2011 inquiry