PRN 83-3: Label Improvement Program - Storage and Disposal Label Statements

Notice To: Manufactures, Formulators, and Registrants of Pesticides

Attention: Persons Responsible for Federal Registrations of Pesticides

Subject: LABEL IMPROVEMENT PROGRAM - Storage and Disposal Label Statements

This Notice is to inform all registrants that the label of all products must include updated storage and disposal statements. No application for amended registration is required if you use the exact wording contained in this Notice.

Registrants wishing to propose alternate language for disposal statements, or wishing to make changes not specified in this Notice, must submit an application for amended registration (EPA Form 8570-1).

Background:

40 CFR 162.10 requires that pesticides bear appropriate storage and disposal label statements. However, many products bear statements that are inadequate or inconsistent with current disposal registrations under the Resource Conservation and Recovery Act. Since February 1951, the Office of Pesticide Programs has applied a uniform set of storage and disposal label instructions for new product registrations on a case-by-case basis. This notice is intended to assure that all products are consistent in meeting current storage and disposal requirements.

1. Label Revisions
2. Time Frame For Compliance
3. Modifications To Statements
4. Further Information

1. Label Revisions

   All products are required to bear specific label instructions about storage and disposal. Storage and disposal instructions must be grouped together in the directions for use portion of the label under the heading STORAGE AND DISPOSAL. Products intended solely for household use need not include the heading "STORAGE AND DISPOSAL". The STORAGE AND DISPOSAL heading must appear in the minimum type size listed below.

   Size Of Label Front Panel In Square Inches	Required Type Size For The Heading STORAGE AND DISPOSAL; All Capitals
   10 and under	6 point
   Above 10 to 15	8 point
   Above 15 to 30	10 point
   Over 30	12 point

   Storage and disposal instructions must be set apart and clearly distinguishable from other directions for use. Blocking storage and disposal statements with a solid line is suggested as a means of increasing their prominence. Refer to the attached sample label for proper placement for these statements.

   1. Storage Instructions:

      All product labels are required to have appropriate storage instructions. Specific storage instructions are not prescribed. Each registrant must develop his own storage instructions considering, when applicable, the following factors:

      1. Conditions of storage that might alter the composition or usefulness of the pesticide. Examples could be temperature extremes, excessive moisture or humidity, heat, sunlight, friction, or contaminating substances or media.
      
      
      2. Physical requirements of storage which might adversely affect the container of the product and its ability to continue to function properly. Requirements might include positioning of the container in storage, storage temperature, potential for breakage of glass, crushing or damage due to stacking, penetration of moisture, and ability to withstand shock or friction.
      
      
      3. Specifications for handling the pesticide container, including movement of container within the storage area, proper opening and closing procedures (particularly for opened containers), and measures to minimize exposure while opening or closing container.
      
      
      4. Instructions on what to do if the container is damaged in any way, or if the pesticide is leaking or has been spilled, and precautions to minimize exposure if damage occurs.
      
      
      5. General precautions concerning locked storage, storage in original container only, and separation of pesticides during storage to prevent cross-contamination of other pesticides, fertilizer, food, and feed.
      
      
      6. General storage instructions for household products should emphasize storage in original container and placement in locked storage areas.
      
      
      
      
       
      7.  
      8.  
   2. Pesticide Disposal Instructions:

      The label of all products, except those intended solely for household use, must bear explicit instructions about pesticide disposal. The statements listed below contain the exact wording that must appear on the label of these products.

      Products intended for household use only must bear the following disposal statement: "Securely wrap original container in several layers of newspaper and discard in trash."

      1. The labels of all products, except household use, must contain the statement, "Do not contaminate water, food, or feed by storage of disposal."
      
      
      2. Except those products intended solely for household use, the labels of all products that contain active ingredients appearing on the "Acutely Hazardous" Commercial Pesticide Products List (RCRA E List) in Appendix B or are assigned to Toxicity Category I on the basis of oral or dermal toxicity, skin or eye irritation potential, or Toxicity Category I or II on the basis of acute inhalation toxicity must bear the following pesticide disposal statement:
          

         "Pesticide wastes are acutely hazardous. Improper disposal of excess pesticide, spray mixture, or rinsate is a violation of Federal Law. If these wastes cannot be disposed of by use according to label instructions, contact your State Pesticide or Environmental Control Agency, or the Hazardous Waste representative at the nearest EPA Regional Office for guidance."

          

         The labels of all products, except those intended for household use, containing active or inert ingredients that appear on the "Toxic" Commercial Pesticide Products List (RCRA F List) in Appendix B or presently meet any of the criteria in Subpart C, 40 CFR 261 for a hazardous waste must bear the following pesticide disposal statement:

         "Pesticide wastes are toxic. Improper disposal of excess pesticide, spray mixture, or rinsate is a violation of Federal Law. If these wastes cannot be disposed of by use according to label instructions, contact your State Pesticide or Environmental Control Agency, of the Hazardous Waste representative at the nearest EPA Regional Office for guidance."

          

         Labels for all other products, except those intended for household use, must bear the following pesticide disposal statement:

         "Wastes resulting from the use of this product maybe disposed of on site or at an approved waste disposal facility."

      
      
      3. Products intended for household use only must bear the following disposal statement: "Securely wrap original container in several layers of newspaper and discard in trash."
   
   
   3. Container Disposal Instructions

      The label of each product must bear container disposal instructions appropriate to the type of container.

      1. All products intended for household use must bear one of the following container disposal statements.

         Container Type	Statement
         Non-aerosol Products (bottles, cans, jars)	Do not reuse container (bottle, can, jars). Rinse thoroughly before discarding in trash.
         Non-aerosol Products (bags)	Do not reuse bag. Discard bag in trash.
         Aerosol Products	Replace cap and discard container in trash. Do not incinerate or puncture.

      2. The labels for all other products must bear container disposal instructions, based on container type, listed in Appendix A.



2. Time Frame For Compliance

   It is the responsibility of the registrant to ensure that the labels of their products, including distributor products, contain specific instructions pertaining to storage and disposal practices. Existing stocks of products in channels of trade prior to December 31, 1984, need not be relabeled. All products released for shipment on or after December 31, 1984, must meet the requirements of this Notice, or they will be deemed to be misbranded under FIFRA Section 2(q)(1)(G). Failure to revise product labeling in accordance with this Notice may result in the initiation of cancellation proceedings.

3. Modifications To Statements

   Registrants wishing to propose alternate language for statements, or to make and disposal label statements, or to make additional changes in the label text or format, must submit an application for amended registration (EPA Form #8570-1) to the appropriate product manager in the Registration Division.

4. Further Information

   Questions on this Notice may be directed to the appropriate Product Manager.

   Douglas D. Campt,
   Director
   Registration Division (TS-767)

¹Manufacturer may replace this phrase with one indicating whether and how fiber drum may be reused.