(Beyond Pesticides, May 15, 2008) The Environmental Protection Agency (EPA) has announced a plan to distribute pesticide labels electronically, in lieu of a traditional product labeling with use instructions, raising further safety concerns about consumer product choice and label compliance from public health and environmental advocates. The program, which is currently under development, will be an agenda item at the May 21-22 meeting of the Pesticide Program Dialogue Committee (PPDC) in Arlington, VA.
“Benefits from using this system will include faster access to new pesticide uses, quicker implementation of protective measures for public health and the environment, improved compliance with label directions, and lower costs for industry and EPA,” the agency said May 12 in a statement on its pesticides website. The system will rely on users to contact either the pesticide labeling website or a toll-free telephone number to obtain the detailed-use instructions that previously were attached to pesticide containers, EPA said. The program is being discussed by EPA and “stakeholders, generally those that have approached the Agency.” EPA said it would develop a pilot program for the system in 2009. The PPDC, which will be presenting next week, comprises industrial, regulatory, and consumer members who provide feedback to EPA on various pesticide regulatory, policy, and program implementation issues.
Bill Jordan, a senior policy adviser at the Office of Pesticide Programs, told the Bureau of National Affairs that some issues holding up the plan include what information will be listed on pesticide containers themselves as opposed to being available on electronic labels on the website, how long electronic labels will be valid after they are downloaded, whether EPA or an outside entity will maintain the website, and what the website will look like.
While EPA plans for users who do not have internet access by providing a toll-free telephone number to “those without access to the necessary technology,” public health and environmental advocates say electronic labeling as a replacement for current product labels adds an unnecessary extra step for consumers who might already be confused by the relative hazards and uses of products. As Beyond Pesticides argued when EPA allowed Clorox to put the Red Cross symbol on its products, unncessary additions (or, in this case, subtractions) to pesticide labels make usage less clear to consumers, particularly vulnerable populations who now may not have the means or ability to realize a product’s risks. Advocates point out that with limited label information consumers of pesticides will have even more limited information than currently available to make informed decisions when buying pesticides and choosing less hazardous products. Furthermore, advocates argue, with EPA enforcement against non-compliance with the label already limited, this approach will further reduce compliance with the label (online) instructions, as fewer people tracking down computer labels. According to Jay Feldman, executive director of Beyond Pesticides, “EPA knows historically from its label improvement program that it has a difficult time getting people to read labels. Instead of further removing labels from the consumer’s sight, EPA should be enhancing label information and design to ensure better disclosure of product hazards so that consumers can make better decisions regarding pesticide product purchase and use.”
At the October 2007 PPDC meeting, EPA said in its presentation on electronic labeling that it “may replace the Directions for Use on the physical container,” but that the “container label would still have all FIFRA mandated elements, e.g. product name, registration number, net contents, ingredients, etc.” The enforcement of the new system as described last fall involved a number of steps, including that “users would need to have a copy of the labeling from the website at the time of application” and “labeling would be good for a specified duration of time (e.g. six months) from the date of ‘printing.'”
Electronic labeling will be discussed on May 21 at the next PPDC meeting. For a full agenda and address, click here. For more background from EPA on the project, including future updates, visit EPA’s website.