Label Review Training: Module 3: Special Issues, Page 7
Section 2: How should I review precautionary statements?
Determining Environmental Hazards Statements
The use pattern of a pesticide helps determine the need for and the specific text of the environmental hazards statement. The label reviewer may assume that any pesticide product used outdoors must include the environmental hazards statement on the label. The reviewer should also look at the proposed statement with a critical eye toward its applicability. Does it make sense for the product? For example, a granular herbicide would not generally need a statement warning of potential spray drift problems because granular formulations are not sprayed and are seldom associated with any drift.
Exclusively indoor–use products
Products that are intended for use exclusively indoors may omit the environmental hazards statement. Products applied to domestic animals, such as flea collars or ear tags, may in most cases omit the statement; however, the statement may be required for a domestic–use product such as a dog dip because of the potential for contamination of water by the use of such a product. It is therefore important for reviewers to carefully evaluate the use pattern of the product to determine whether potential risk from the transport, use, storage, or disposal of the product should be mitigated by the environmental hazards statement.
Although used indoors to formulate other products, manufacturing–use products may require some environmental hazard statement text because manufacturing–use products may be highly concentrated and could pose a serious hazard if a spill occurred. If any pesticide may be discharged from the manufacturing use site, a statement may also be required referring to the possible need for a discharge permit under the Clean Water Act.
EPA historically has required products labeled for use outdoors to have environmental hazards statements on their labels. If the reviewer determines that the use pattern triggers the need for environmental hazards labeling, the proposed draft labeling must be reviewed according to the requirements outlined in the regulations and the policy described in Chapter 8 of the Label Review Manual.
To determine environmental hazards statements, review the guidance in Chapter 8 of the Label Review Manual.