Transcript Web-Distributed Labeling

Web-Distributed Labeling
Update for CLA & RISE
William Jordan
Office of Pesticide Programs
April 11, 2014
Web-Distributed Labeling
Overview
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Voluntary system
Complete labeling still on pesticide container
 Reference statement, unique identifier, and “released for
shipment date” on the container or attached labeling
 User has option to download “rendered labeling”
Streamlined use directions can now be available via website
Both container labeling and web-distributed labeling are
legally valid
Overall goals
 Make latest version of approved labeling available to user
quickly
 Improve users’ understanding of and compliance with
pesticide labeling
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Web-Distributed Labeling:
What it is not
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Does not remove any labeling from the container
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Not electronic submission or review of labels by EPA
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Does not require standardized labeling
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Does not diminish legal procedures that EPA must
follow to change labeling
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Does not change process registrants use to change
labeling
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Does not change users’ duty to follow labeling
requirements
 Gives the option to follow either container labeling
or web-distributed labeling
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Web-Distributed Labeling: History
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States presented the topic to OPP’s Office Director, Debbie
Edwards, at the 2007 AAPCO meeting
EPA formed an internal team to discuss web-distributed
labeling later in 2007
 Representation from OPP Divisions (AD, BPPD, FEAD,
ITRMD, RD), OGC, OECA, OC, Regions, as well as 2
state regulators
EPA’s workgroup identified issues and areas for further
consideration, drafted discussion papers, and conducted
stakeholder outreach
Stakeholder engagement through individual meetings,
PPDC subgroup, User Acceptance Pilot, Federal Register
Notice, and draft Pesticide Registration Notice
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Pesticide Registration Notice
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PR Notice 2014-1
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Signed March 2014
Includes goals of WDL, terminology, suggested text for
labeling, WDL content, website functionality
http://www.epa.gov/PR_Notices/
Sample labeling
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Master labeling with WDL statements
Correctly and incorrectly “rendered labeling”
Available on EPA’s website -
http://www.epa.gov/pesticides/regulating/labels/distribution/
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Registrants’ Responsibilities
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Add text referencing WDL to master label
Provide 2 samples of rendered labeling (electronic or
paper)
Submit master label + sample rendered labeling
either as:
 Non-PRIA fast track amendment (only WDL)
 Part of a PRIA action (WDL & additional changes)
May not add WDL to labeling as a notification
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EPA Reviewers’ Responsibilities
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Verify text referencing WDL is on master labeling
Check sample rendered labeling
 Include WDL text
 Include all applicable required sections (front
panel, precautionary statements, directions for
use, etc.)
OPTIONAL - Check URL if available
 Verify website existence
 Verify return of rendered labeling
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End Users’ Responsibilities
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Find “unique identifier” and “released for shipment
date” on container
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Go to website listed on container labeling
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Enter unique identifier, state, intended use site
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Verify that the date the rendered labeling date is
later than the released for shipment date on
container
Follow either container label or WDL – do NOT mix
and match directions from both
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Web-Distributed Labeling:
Enforcement
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Labeling is critical to ensuring that a
pesticide’s use will not cause adverse effects
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Web-distributed labeling must be
enforceable in order to be implemented
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Relies on current enforcement infrastructure,
and specifies potential violations by
registrants, users, and others
Significant interaction with states through
AAPCO & SFIREG to confirm that
enforcement would not be compromised
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Web-Distributed Labeling:
Contact Information
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Nicole Zinn
[email protected]
703-308-7076
William Jordan
[email protected]
703-305-1049
Michelle Arling (on leave until July)
[email protected]
703-308-5891
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