Pesticide and Insecticide Label Changes
Synthetic Pyrethroids – Label Changes in 2012
Changes to Label Wording –2011-2012
EPA PR Notice 2008-1 – for“non-fogging” pyrethroid products
Overview and Reasons for Label changes:
In 2011 the EPA began to implement the requirement for new wording and instructions for use on all Product Labels of Synthetic Pyrethroids. These insecticides constitute a large number of the most often-used products in pest management, including such common active ingredients as permethrin, deltamethrin, bifenthrin, cypermethrin, cyfluthrin, and many others. The ruling also affects any products with multiple active ingredients where at least one of them is a synthetic pyrethroid.
The timeline for compliance with this new labeling is confusing, but some product Labels began to show these changes in December 2011 and all others will be expected to comply within the first few months of 2012. It is imperative that end users of pyrethroid products carefully read the Label of the material they purchase from suppliers to be certain of the specific wording on that Label and the new restrictions that may be in place on its use.
The overall intent of these changes is to minimize movement of these active ingredients into sensitive environmental areas, such as waterways or habitats of protected wildlife. Studies initiated in California, testing water in storm drains and nearby creeks, suggested that contamination with levels of pyrethroids sufficient to affect test organisms in those waters was occurring routinely. Synthetic pyrethroids, while very low in toxicity to warm blooded animals, can be very toxic to cold blooded animals (fish, frogs, reptiles) and to invertebrate animals. One aquatic invertebrate used as the test organism is Hyalella azteca, a small fresh water shrimp or amphipod.
Where will the new wording be found?
Much of the new wording on Pyrethroid Labels will be found in the sections on “Environmental Hazards Statements” and general “Directions for Use”, and they replace current wording with stronger wording to users of the products to avoid any application that would allow that product to move off of the intended site of use. However, there are now new limitations on the use of pyrethroid products outside of structures, and these will be extremely important to the Pest Management Professional.
Environmental Hazards –
intended to clarify the steps the applicator can take to avoid potential contamination. They will vary depending on the formulation –granules, liquid sprays, dust
♦ For Liquid Concentrates labeled for Outdoor uses:
- To protect the environment, do not allow pesticide to enter or run off into storm drains, drainage ditches, gutters or surface waters. Applying this product in calm weather when rain is not predicted for the next 24 hours will help to ensure that wind or rain does not blow or wash pesticide off the treatment area. Rinsing application equipment over the treated area will help avoid run off to water bodies or drainage systems.
♦ For Granular formulations labeled for Outdoor uses:
- To protect the environment, do not allow pesticide to enter or run off into storm drains, drainage ditches, gutters or surface waters. Applying this product in calm weather when rain is not predicted for the next 24 hours will help to ensure that wind or rain does not blow or wash pesticide off the treatment area. Sweeping any product that lands on a driveway, sidewalk, or street, back onto the treated area of the lawn or garden will help to prevent run off to water bodies or drainage systems.
♦ For Dust products labeled for Garden or Ornamental uses:
- To protect the environment, do not allow pesticide to enter or run off into storm drains, drainage ditches, gutters or surface waters. Applying this product in calm weather when rain is not predicted for the next 24 hours will help to ensure that wind or rain does not blow or wash pesticide off the treatment area.
♦ For Liquid Ready-to-Use products other than Aerosols:
- To protect the environment, do not allow pesticide to enter or run off into storm drains, drainage ditches, gutters or surface waters. Applying this product in calm weather when rain is not predicted for the next 24 hours will help to ensure that wind or rain does not blow or wash pesticide off the treatment area.
“Directions for Use –Application Restrictions” – new wording to be added:
♦ For Granular formulations labeled for Outdoor uses:
- Apply this product directly to the lawn or garden area. Water treated area as directed on this label. Do not water to the point of run-off.
- Do not make applications during rain.
♦ For Liquid, Dust, and Ready-to-Use formulations labeled for Outdoor uses:
- Do not water the treated area to the point of run-off.
- Do not make applications during rain
♦ For Outdoor Liquid applications for Residential outdoor surface and space sprays other than for outdoor fogging devices:
- All outdoor applications must be limited to spot or crack-and-crevice treatments only, except for the following permitted uses:
• Treatment to soil or vegetation around structures;
• Applications to lawns, turf, and other vegetation;
• Applications to building foundations, up to a maximum height of 3 feet.
- Other than applications to building foundations, all outdoor applications to impervious surfaces such as sidewalks, driveways, patios, porches and structural surfaces (such as windows, doors, and eaves) are limited to spot and crack-and-crevice applications, only.
♦ For all products that do not contain directions for use in drains or sewers:
- Application is prohibited directly into sewers or drains, or to any area like a gutter where drainage to sewers, storm drains, water bodies, or aquatic habitat can occur. Do not allow the product to enter any drain during or after application.
♦ For all products that do contain directions for use in drains or sewers:
- Do not apply directly to sewers or drains, or to any area like a gutter where drainage to sewers, storm drains, water bodies, or aquatic habitat can occur, except as directed by this label.”
Important interpretations of the new wording for SPRAY applications:
- Regarding the limitation of Crack and Crevice or Spot treatment only to exterior surfaces of structures:
• A one-inch wide band around doors and windows is considered to be a “spot” or a“crack and crevice” treatment.
- Covered patios outside may not have overall applications, as there is no assurance they will not be washed or subjected to heavy rain and runoff.
- Applications may still be made to building foundations to a maximum height of 3 feet, as well as to soil and vegetation around the structure.
Termite Pre-treatments:
- The treatment site must be covered prior to a rain event in order to prevent run-off of the pesticide into non-target areas.
- The applicator must either cover the soil him/herself or provide written notification of the above requirement to the contractor on site and to the person commissioning the application (if different than the contractor). If notice is provided to the contractor or the person commissioning the application, then they are responsible under FIFRA to ensure that: 1) if the concrete slab cannot be poured over the treated soil within 24 hours of application the treated soil is covered with a waterproof covering (such as polyethylene sheeting), and: 2) the treated soil is covered if precipitation is predicted to occur before the concrete slab is scheduled to be poured.
- Do not treat soil that is water-saturated or frozen.
- Do not treat when raining.
- Do not allow treatment to run off from the target area.
- Do not apply within 10 feet of storm drains. Do not apply within 25 feet of aquatic habitats (such as, but not limited to, lakes, reservoirs, rivers, permanent streams, marshes or ponds, estuaries, and commercial fish farm ponds).
- Do not make on-grade applications when sustained wind speeds are above 10 mph (at application site) at nozzle end height.
Impact on the Pest Management Industry:
♦ For structural general pest uses PMP’s will no longer be permitted to apply broad applications to exterior surfaces of structures, such as might be done for management of cluster flies, ladybirdbeetles, stink bugs, or boxelder bugs.
♦ For turf and ornamental uses there will need to be specific attention to weather conditions, sprinkler schedules, and other factors that may encourage runoff that carries the pyrethroid material.
♦ Attention must be given to soil conditions – frozen or saturated soils – where runoff would be likely to occur.
♦ Extra attention must be given to applications adjacent to sidewalks or drain openings to keep all spray or granules off of these surfaces.
List of Pyrethroid active ingredients:
- Allethrin
- Bifenthrin
- Cyfluthrin
- Cypermethrin
- Deltamethrin
- Esfenvalerate / Fenvalerate
- Etofenprox
- Fenpropathrin
- Fluvalinate / Tau-fluvalinate
- Gamma cyhalothrin
- Lambda cyhalothrin
- Permethrin
- Phenothrin
- Phenpopathrin
- Prallethrin / ETOC
- Resmethrin
- Sumithrin
- Tefluthrin
- Tetramethrin
- Trallomethrin
©2012. Univar USA Inc. Information provided is derived from the U.S. Environmental Protection Agency’s Pesticide Registration (PR) Notice2008-1. It is not meant to constitute legal advice. Please contact your state regulatory officials or the EPA for additional information. Univar makes no representations and warranties as to the information provided. Always read and follow label directions.
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