Section 4: How should I review for accuracy?

Precautionary Statements

As discussed in Sections 1 and 2 in Module 3, certain precautionary statements depend on the results of toxicity studies performed on the technical grade of the active ingredient(s) in the product's formulation. The label reviewer must ensure that the statement language accurately corresponds to the study results.

For example, fish/aquatic invertebrate statements depend on the results of the fish acute LC₅₀ or aquatic invertebrate (including estuarine species such as oyster and mysid shrimp) EC₅₀ study. The following statement has historically been required when a pesticide intended for outdoor use contains an active ingredient with a fish acute LC₅₀ or aquatic invertebrate EC₅₀ less than or equal to 1 part per million: “This pesticide is toxic to [fish], [fish and aquatic invertebrates], [oysters/shrimp], or [fish, aquatic invertebrates, oysters, and shrimp].”

If field studies or accident history such as FIFRA 6(a)(2) reports indicate that the use of the pesticide may result in fatality to birds, fish, or mammals, the following statement has historically been required: “This pesticide is extremely toxic to [birds], [mammals], [fish], or [birds and mammals and fish].”

Resource

For more information about accurate precautionary statements, see Chapter 7, Chapter 8, and Chapter 9 of the Label Review Manual.

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