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Our Right-to-Know: Pesticide Product Labels
Five recommendations for honoring the public's right-to-know about health, safe use, and environmental information on pesticide product labels.
Pesticide product labels lack essential information. Labels should honor consumer's right-to-know each pesticide ingredient and its health and environmental hazards. Such information will enable consumers to make informed decisions about products used in and around the home. Better labeling will also encourage manufacturers to develop and market safer pesticide products.
By design, pesticides harm living organisms. These substances are intentionally broadcast into the environment. By their use, pesticides harm much more than the target organisms. When used in homes and gardens, pesticides come in contact with people who are exceptionally vulnerable to their damaging effects, including children, people who are ill, and pregnant women, as well as pets. Informative and complete labeling of home and garden pesticides is necessary to help protect the health and safety of all Americans.
Below are five specific recommendations for improving pesticide product labels:
1. Honor consumers right-to-know.
Pesticide labels should list all product ingredients by common name and CAS number so consumers can identify what we are buying. Currently, with few exceptions, only active ingredients (and not "inert" ingredients) are named on the product label. This is unacceptable.
The material safety data sheet (MSDS) for the same product will often identify and name other hazardous ingredients that are so-called "inert" ingredients. This misleading term must be removed from all pesticide labels. EPA has encouraged companies to use the term "other" ingredient instead of "inert," but few companies have made the change.
These misbranded "inert" ingredients include many highly toxic chemicals that are known to cause cancer, birth defects, nervous system damage, and other problems. Many of these substances are regulated as toxic or hazardous under Federal laws including the Emergency Planning and Community right to Know Act, Clean Air Act, Clean Water Act, Safe Drinking Water Act, and the Superfund law. Labels on pesticide products should list all ingredients just as labels list ingredients on a can of soup, a package of cookies, or a bottle of shampoo.
In addition, full disclosure must include ingredients that are put into a product to protect the product itself, i.e. fungicides in paint. Keeping these ingredients and their hazards secret undermines consumers' right-to-know what is in the products we purchase.
2. Identify on the label the health and environmental hazards of each ingredient.
Pesticide labels should also identify health and environmental hazards of the pesticide product. Workers have access to material safety data sheets, which contain health hazard information, and are often trained in the potential hazards they may encounter in the workplace. Home and garden product consumers do not have such information and training. Especially since some manufacturers have opted not to prepare MSDSs for home and garden use products, health and environmental information must be on the label.
In California, consumers are informed about ingredients in pesticide products that are known to pose risks of cancer or reproductive harm. Other consumer product labels such as art supplies and contact cement adhesives disclose acute and chronic health hazards. There is every reason to honor consumers' right-to-know about the human health and environmental harm that may result from exposure to home and garden pesticide products.
3. Provide label information in an easily understood format.
A. All labels should provide a matrix that indicates the health and environmental hazard of each product ingredient. For example, ingredients that are known to cause birth defects, cancer, reproductive harm, or leach into ground water would show an "X" in the corresponding space. The matrix should also indicate for each ingredient when hazard data are unknown.
B. Home and garden pesticide product labels need to include easily recognized symbols that convey hazard information such as a skull and crossbones or Mr. Yuk.
C. Accompanying text should provide sufficient hazard information for consumers to make an informed decision. Labels should be written in language geared to a fourth-grade reading level. The public's right-to-know demands that pesticide labels be written so that nearly everyone can easily understand them.
D. EPA needs to ensure labels are readable (i.e., spacing and font size) and enforce those standards.
4. Orient label improvements to identify hazards, not to evaluate product safety.
EPA currently has a Reduced-Risk Pesticide Initiative to promote what are arguably "safer" pesticide products (e.g. the sulfonylurea herbicides). Labels containing evaluative conclusions are no substitute for an objective and informative labeling program. Consumers need informative labels, not marketing propaganda.
5. Provide consumers with key telephone contact numbers.
Labels need to include the phone numbers for EPA's Occupational and Residential Exposure Branch at the Office of Pesticide Programs (for reporting pesticide incidents) and EPA's National Pesticides Telecommunication Network (for providing general information on pesticides to anyone in the United States).
* This issue paper was based on an April 1996 letter sent by over 70 organizations to the EPA that was originally prepared by:
Northwest Coalition for Alternatives to Pesticides, PO Box 1393, Eugene, OR 97440
Working Group on Community Right-to-Know, 218 D Street SE, Washington, DC 20003
Beyond Pesticides, 701 E Street SE, Washington, DC 20003
[Revised September 25, 2003]