Spray Drift Labeling Language

The Need for Simple and Flexible Labeling Language

  • Click Here to Read NAAA's 2011 Comments to EPA on Revised Spray Drift Labeling Language
  • Click Here to Read NAAA's 2010 Comments on Draft PR Notice 2009-X

In an effort to move forward with a uniform spray drift statement for all pesticide labels, EPA held a stakeholder meeting in February to gather input from individuals on the palatability of its new version of pesticide drift label language.  The revised drift language reads: “Do not apply this product in a manner that results in spray [or dust] drift that harms people or any other non-target organism or site.” It replaces language the EPA proposed in November of 2009 that reads: “Do not apply this product in a manner that results in spray [or dust] drift that could cause an adverse effect to people or any other non-target organism or site.”  NAAA participated in the February meeting and submitted written comments on the revised statement to the Agency this week. Click here to read NAAA’s comments.

While NAAA acknowledged the positive language changes since the original 2009 draft, the Association indicated the tentative revised statement is not entirely consistent with the FIFRA standard.  FIFRA language details that pesticides be registered by EPA to ensure they do not cause “unreasonable adverse effects.” The tentative revised statement by EPA does not contain parallel terminology.  NAAA argues that the new term, “do not…harm,” that EPA is proposing may be interpreted by some enforcement officials as harm to an individual, off-target, beneficial insect, and hence, open the door to frivolous and/or unsubstantiated drift claims.  While NAAA supports the Agency’s efforts in trying to clarify the proposed labeling language with the tentative revised statement, it requested the Agency fine-tune the tentative revised statement and include the FIFRA standards’ "unreasonable adverse effects” language. 

EPA has stated they would like to have the language finalized by mid-2011. NAAA will continue to monitor the issue and advocate for simple and flexible labeling language.