US EPA - Label Review Manual - Chapter 13: …

1 Label Review ManualChapter 13: Storage and Disposal , National Biological Information Infrastructure, Library of Images From the Environment, Elizabeth A. Sellers Label Review Manual 13-1 I. Introduction This Chapter discusses the storage and disposal instructions for pesticides and pesticide containers. Label reviewers should us e this Chapter as well as information presented in PR Notices 83-3, 84-1, 84-5, 94-2, 2007-1, and 2007-4; in the regulations at 40 CFR (i)(2)(ix) and ; an d in Rer egistra tion Eli gibilit y Decision (RED) documents or Registra tion R evi ew D ecisions for acti ve ingredients. In addition, chemical-specific storage and dispos al statem ents have been provided by the Agency for certain pestici des, as stated i n PR No tice 84- 1 (and an errat a she et dated April 12, 1984), an d in PR No tice 84-5.

2 The se chemical-specific statem ents are desc ribed in detail in this Chapter . Accordin g to 40 CFR (i)(2 )(ix), pesticide products must have Label instructions f or the storage, residue removal and d isposal of pesticides and pesticide containers. F or many years , the content of these Storage and D isposal instr uctions has been established in PR No tices. The labels of pesticide products released for shipment 1 after August 16, 2011 must bear Storage and Dispos al instructions that also conform with the requirem ents in Subpart H Container Labeling, 40 CFR 40 1 However, registr ants may submit t o the appropriat e E PA Product Manager team a request for a waiver or m odifi cation (with a justificati on) from E PA f or a ny of the requirem ents in Subpart H.

3 [If EPA requires a d ifferent statement or approves a modifi cation or waiver , lab el changes would be made by ame ndm ent. R egistr ants can use notification if the exact wording is used from the regulations in 40 CFR or if otherw ise a llowed by E PA.(See PR Notice 2007-4) This Chapter is organized so that general information is provided in section II follow ed by instr uctions for a general storage and dispos al stat e in section III; pesticide storage in section IV; pesticide disposal i n section V; and container hand ling ( , container cleaning instructions, reuse limita tions, and container recycling or disposal ) in section VI . Next, section VII desc ribes how to present information on one Label for mu ltipl e uses, container types and/or sizes.]

4 Attachments fo llow wit h information on (A) pesticide storage statem ents for products with certain active i ngredien ts; (B ) storage statem ents suggested by EPA; (C) container handling instructions by container type; and (D) sample storage and dispos al statements for antimicrobial pesticides. II. Reviewing the statements A. Det ermining Storage and D isposal Labeling The Storage and Dispos al sec tion of the Label must have instr uctions on how to: Store a product D ispose of leftov er pesticides Clean an empty container (for certai n types of pesticides and containers) D ispose of an empty container if recyc ling or reconditioning is not an option. In add ition, the Storage and Disposal s ection of a Label may have instructions on how t o: D ispose of pesticide rinsa te Return the c ontainer for refilling (for sale or distribution), if it can be reused.

5 1 The definition of released for shipment in 40 CFR is: ..A product b ecom es released for shipment when the p roducer has packaged and labeled it in the manner in which it will be distributed or sold, or has stor ed it in an ar ea where finished products are ordinarily held for shipment. Products stored in an ar ea where products are ordinarily held for shipment, but which are not in tended to be released for shipment must be physically separated and marked as not y et released for shipment. On ce a product b ecom es released for shipment, th e pr oduct rem ains in the condition of being released for shipment until subsequent activities, such as relabeling or repackaging, constitute product ion.

6 Label Review Manual 13-2 B. Statement Location Storage and Dispos al instructions (except for batch codes) must be grouped together under the heading Storage and Disposal and should be withi n the Directions for Use s ecti on at the end, wh ile cl early set apart (as blocked or in a box) from the rest of the Directions for Us e . (S ee (i)(2)(ix) and PR Notice 83- 3) EXCEPTION: All but one of the container statements requ ired by 40 CFR can be placed on the actual container (not on the closure) itself. Specifically, the container type, container reuse and container recyc ling or reconditioning statem ents can be on the container, but not the cleaning instructions. Cl eaning instructions must always be on the Label itself.

7 When statem ents are on a container the Label must have an appropriat e statement under Storage and Disposal that direct s the user w here t o find the information. Examples ar e: S ee container for r ecyc ling [or other descriptive word] information or Refilling limitations are on the container. Any container statement required by 40 CFR and put directly on the actual container itself must be durably marked such as by (but not limited to) etching, embossing, ink jetting, stamping, heat stamping, mechanically attaching a plate, molding, or marking with durable ink. (See ) C. Format If it is a nonrefillable container and the container hand ling statem ents ar e placed on the Label (or labe ling), registr ants must use an appropriat e subheading under the heading Storage and D isposal.

8 (See (a)) Alter natively , for refill able contai ners the Agency suggests (does not require) a subheading Subheadings comm only used are Contain er Handling or Container Disposal . However, when making Label revisions EPA recommends that registr ants transiti on to u sing Containe r Hand ling . The example below s hows the order and subheadings of a typical stor age and disposal s ecti on of a Label for a non-residen tial2 use product. DIRECTIONS FOR USE Storage and Disposal Do not contaminate water, f ood, or feed by storage or disposal. Storage3: [Where and how to store the product.] Pesticide Disposal4: [What to do with product that is left over and no t going to be used.]

9 ] Container Handling5: [Whether the container is nonrefillable or refillable; if it can be reused, recycled or reconditioned; how to dispose of it if recycling or reconditioning is not an option; and how to clean i t if cleaning is required.] 2 In this version of Chapter 13, EPA has simplified the phrase residen tial/household use from PR Notic e 20 07-1 for clarity, particularly when desc ribing the opposite set of products. The phrase non-residential use is more clear than non-residen tial/household use or non- residen tial/non-household us e . Se e footnote 10 for more details. 3 Reg istrants may use alterna tiv e subheadings such as Pesticide Storage or Product Storage , with the appro val of the EPA reviewer and/or EPA Product Manager.

10 4 Reg istrants may use alterna tiv e subheadings such as Product Disposa l or Disposal with the a pproval of the EPA reviewer and/or EPA Product Manager. 5 Reg istrant may use alterna tiv e subheadings such as Con tainer Disposa l with the app roval of the EPA Reviewer and/or EPA Product Manager. When making Label revisions, EPA recommends that registran ts transition to Container Handling. Label Review Manual 13-3 D. Type Size Requirem ents The heading Storage and D isposal must be in type of the same minimum sizes as required for the child hazard warning by 40 CFR (b). (See (i)(2)(ix)) III. General storage and disposal statements The Agency historically has required all productsexcept f or re siden tial6 us e products to bear the following statement for risk management purposes: Do not contaminate water , food, or feed by storage or disposal.