Label Review Training: Module 4: Applying the Principles of Pesticide Label Review, Page 19
Section 5: How should I review mandatory statements for enforceability?
Learning Activity
Read the case below and decide whether enforcement action can be taken based on the application rate information on the label. Once you have reviewed the case, click “Answer” to reveal the correct response.
Answer
Even though EPA argued the use rates listed on the label were mandatory, Regional legal counsel felt that because the label contained the word “recommended,” and because PR Notice 2000–5 specifically identifies statements containing this word as optional in nature, no enforcement action could be taken.
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