NAAA Comments on EPA’s Proposal for Structured Digital Labels, a Necessary Step to Move Forward with Site-Specific Risk Assessments

NAAA submitted comments this week in response to EPA’s proposal to move forward with digitizing pesticide labels. EPA’s plan includes not just digitizing pesticide labels, but also structuring the content. This means all labels, regardless of manufacturer or active ingredient, would have uniform sections available electronically and order. EPA also wants to improve label language consistency across all pesticide labels.

There are numerous benefits to the EPA plan for structured digital labels. For applicators, it would mean they will always know where to look on a label for a particular piece of information they are searching for. Consistent language among all labels will reduce confusion as well. EPA proposes to create a library of approved label language that registrants can use when they write their labels. Structured digital labels will also increase the speed and accuracy of the pesticide registration and registration review process.

Another benefit would be allowing applicators to access only parts of the label relevant to the application they are going to make. For instance, the applicator would enter the crop, pest, and application method. The label they download would contain only the information they need to make that application – instructions for other crops, pests, and application methods would be left off. This feature will be especially useful for products with incredibly long and complicated labels. Instead of needing to sort through the entire label, applicators will be able to use a label customized with just the content they need.

The ability to access labels over the internet also benefits two of NAAA’s ongoing projects to increase the accuracy and safety of aerial applications – site specific risk assessments and an autonomous spray system. Both of these developing technologies require information from the label, which can easily be provided by a digital label.

NAAA’s comments recommended EPA ensure digital labels can be easily accessed in rural area with reduced internet speed. EPA will also need to establish guidelines to ensure applicators are not violated during an enforcement action for not following a label that came out shortly before they made an application. Click here to read NAAA’s full comments.