Label Review Training: Module 3: Special Issues, Page 35
Section 7: What other label areas require special attention?
- A storage and disposal statement should include a general storage and disposal statement, a pesticide storage statement, a pesticide disposal statement, and a container handling/disposal statement.
- Resources for determining storage and disposal language include: Chapter 13 of the Label Review Manual, PR Notices, 40 CFR 156, and RED documents.
- Inappropriate warranty statements negate or detract from the directions for use or other label language, asserts that the buyer has accepted the manufacturer's statement of his/her rights, and imply that the buyer has no legal right to recover damages from the manufacturer.
- The ingredient statement includes the name and percentage by weight of each active ingredient, the total percentages by weight of all other (inert) ingredients, and sub-statements including, but not limited to: the acid equivalent, elemental equivalent, toxic ingredients, petroleum distillates, sodium nitrite, and corrosivity.
- Which products must bear the following general storage and disposal statement?: “Do not contaminate water, food, or feed by storage and disposal.”
All products except for residential/household-use products.
- Which PR Notices provide chemical-specific storage and disposal statements?
PR Notices 84-1 and 84-5.
- What phrases can the label reviewer use in the disclaimer statement to clarify that the disclaimer language comes from the registrant or manufacturer, and not EPA?
“To the extent consistent with applicable law, the manufacturer shall not be liable...” or “It is the manufacturer's intention that...”
- What is an “other ingredient”?
Any substance other than an active ingredient that is intentionally included in a pesticide product.