Label Review Training: Module 3: Special Issues, Page 17

Section 4: How should I review directions for use?

Learning Activity

The following is a poor example of directions for use. What's wrong with the text in terms of enforceabililty, formatting, and application rates? Read the text, then click “Answer” to reveal the correct response.

USE RESTRICTIONS AND PRECAUTIONS

Plant corn at least 1½ inches deep. Corn seed must be completely covered with soil and furrow firmed.
Do not apply more than 2.73 fluid ounces of XX product in one calendar year or exceed the maximum labeled rate for any given soil type in a single application.
Do not apply more than 0.04013 pounds per acre of XX active ingredient from all sources in one calendar year, or exceed the maximum labeled rate for any given soil type in a single application.
XX product also contains 1.88 pounds of the safener XX per gallon. Do not apply more than 0.201 pounds per acre of XX safener from all sources in one calendar year, or exceed 0.141 pounds per acre of XX safener in a single application.
DO NOT apply XX product postemergence (beyond the 2–leaf collar stage, V2) to corn with liquid fertilizers as the primary spray carrier. Only apply postemergence to corn with water as the primary spray carrier plus recommended adjuvants. See spray additives section.
DO NOT apply more than two applications of XX product to a corn crop in one growing season from within 30 days of planting through the V12 growth stage.
Multiple applications of this product must be made a minimum of 14 days apart.
When weeds are stressed due to drought, heat, lack of fertility, flooding, or prolonged cool temperatures control can be reduced or delayed because weeds are not actively growing. To obtain optimum weed control with an application of XX product follow label directions and use when weeds are actively growing.
Weed control may be reduced if the application is made when weeds are dust covered or in the presence of heavy dew, fog, and mist/rain or when weeds are under stress due to drought.
Apply XX product spray mixtures within 24 hours of mixing to avoid product degradation.
DO NOT apply XX product within 45 days of grazing livestock or harvesting corn forage.
Do not apply this product through any type of irrigation system.
DO NOT apply when wind causes drift to off-site vegetation or adjacent crops as injury or residue contamination may occur.
XX product delivered via drift or tank contamination can cause severe damage to other crops. Careful management of spray drift and tank cleanout is required.

Answer

Enforceability: The example mixes mandatory statements, which should be enforceable, and advisory statements, which should be informational, thereby inviting confusion over intent. It also includes statements that are neither enforceable nor necessary. For example: “Careful management of spray drift and tank cleanout is required.” “Careful management” is not enforceable. “Cleanout is necessary to avoid damaging non-target crops” is better because it is advisory rather than mandatory and provides a reason for performing cleanout.

Formatting: The example should use subheadings to organize information. It should also use consistent capitalization, rather than alternating between “DO NOT” and “do not” so as to avoid suggesting that one statement is more important or mandatory than another.

Application rates: The application rates are given in unnecessarily precise quantities, including up to five decimal places. No user can measure with that precision, and such exact precision doesn't serve any purpose.

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