Pesticide Label Comprehension and Compliance
The label is a legal document
The label is the printed material on or attached to the container; labeling is broader and includes supplemental literature, brochures, and directions that accompany the product. Read the entire label, including fine print, before buying or applying.
Components you must be able to locate
- Product name, EPA registration number, and establishment number - identifies the product and the manufacturing site.
- Ingredient statement - active ingredients (with amounts) and inert ingredients.
- Signal word, symbol, and precautionary statements - human hazard, environmental hazard, physical/chemical hazard.
- Directions for use - site, pest, rate, timing, application method, equipment, and tank-mix restrictions.
- Restricted-entry interval (REI) - how long workers stay out after application.
- Preharvest interval (PHI) - minimum days between application and harvest.
- Storage and disposal directions, and reentry/PPE statements.
Traps that appear in questions
REI and PHI are frequently swapped: REI protects workers entering the treated area; PHI protects the food supply at harvest. "Must" is mandatory; "should" is advisory, but both appear in enforceable labeling. A Section 2(ee) recommendation allows a use within the labeled site but outside labeled rates, frequencies, or methods - it never permits a new site or a higher rate than the label allows. Tank-mixing a product with anything not permitted by the label is a violation. Note that "use" includes mixing, loading, application, storage, and disposal.
Worked example
A label reads: "Do not apply within 14 days of harvest. Do not enter treated area without PPE for 12 hours." A grower applies July 1 and wants to harvest July 12 and have workers hand-weed July 3. Harvest is not legal (14-day PHI); entry on July 3 is not legal (12-hour REI has not elapsed only if 12 hours passed - it has, so entry with PPE is fine, but harvest timing fails).