Label Review Training: Module 4: Applying the Principles of Pesticide Label Review, Page 2
Section 1: How should I use the Label Review Manual to review for consistency?
Purpose and Limitations of the Label Review Manual
The Federal Insecticide, Fungicide and Rodenticide Act (FIFRA) and its implementing regulations include specific requirements for label language and format and, therefore, govern what must (and what cannot) appear on the label. Documents such as the Label Review Manual and pesticide registration (PR) notices provide guidance on how EPA interprets the applicable law.
In addition to considering the guidance provided in this manual, it is the responsibility of the label reviewer or writer to consider all chemical and product specific information affecting labeling such as science reviews, Federal Register Notices, and reregistration eligibility decision (RED) documents.
EPA considers the Label Review Manual to be an instructional aid that does not establish new guidance, but instead compiles interpretations of statutory and regulatory provisions and reiterates EPA policies. The Label Review Manual is also useful in understanding approaches for how labels should generally be drafted. EPA will consider each label on its own merits and will consider deviations from EPA policy in labeling under the appropriate provisions of FIFRA and its implementing regulations.