Bulk storage — If used correctly, minibulks allow farmers to utilize the benefits of buying in bulk without building costly permanent bulk storage facilities.
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Return for credit — farmers could possibly return any unused product left in minibulks to their retailers if the tank’s seals remain intact and the retailers accept bulk returns.
Reduces plastic — minibulks can replace hundreds of smaller plastic containers, which can save a significant amount of time and money. For instance, one 250-gallon shuttle will replace opening, pouring, rinsing, and disposing of 100 2.5-gallon containers.
Refillable — retailers can fill and refill minibulks many times over their lifespan. Compare this to the cardboard and plastic waste generated from single-use, and 1- and 2.5-gallon containers.
Fewer injuries — applicators can dramatically reduce their pesticide exposure when they can pump product from minibulks directly into their sprayers. Pouring out of containers requires repeated climbs up and down the sprayer, which increases the potential for slips and falls.
Despite these advantages, there are also legitimate concerns when using minibulks. Larger containers can mean bigger problems during transport, storage, and use. In fact, most minibulk spills occur during the loading, transporting, or unloading of the container. A minibulk spill can mean hundreds of gallons on the ground (which can then potentially move to environmentally sensitive sites) instead of just 1 or 2 gallons from a jug.
In addition to transportation concerns, there are rules governing the filling and storage of bulk and minibulk pesticide containers. These rules are administered and enforced by the U.S. Environmental Protection Agency (EPA), U.S. Department of Transportation (DOT), and Office of Indiana State Chemist (OISC).
This publication provides farmers and retailers guidance and best practices for managing, storing, handling, and transporting pesticide minibulks.
We often use terms like “bulk” and “minibulk” without much thought; however, the regulations clearly identify the exact meaning of each.
The OISC and EPA define liquid bulk pesticide as an undivided quantity greater than 55 gallons. This definition is different than the DOT’s, which is 119 gallons for hazardous materials. By default, 55-gallon drums and 2.5-gallon containers are not considered bulk pesticides.
This distinction is more than a little important. Indiana pesticide regulations are based on understanding this definition.
There are two types of bulk pesticide storage tanks: larger stationary storage tanks and smaller minibulks.
Stationary storage tanks are generally constructed of stainless steel for durability and ease of cleaning. They hold between 400 and 5,000 gallons. These tanks require secondary containment — see Bulk Pesticide and Fertilizer Storage on Indiana Farms (Purdue Extension publication PPP-63, available at edustore.purdue.edu and ppp.purdue.edu).
In addition, stationary tanks are usually equipped with dedicated plumbing. The dedicated plumbing is used to fill minibulks and sprayers and helps to significantly reduce cross-contamination by keeping products separate from one another. Stationary pesticide tanks (unlike bulk fertilizer tanks) are usually stored under roof.
State and federal regulations define smaller minibulks as tanks with a capacity of more than 55 gallons but not exceeding 400 gallons. Most minibulks in use today are somewhat standardized and hold roughly 110, 125, or 265 gallons (tank capacities of 120, 135, and 275 gallons, respectively). Minibulks may arrive at the retailer already filled by manufacturers, or they may be refilled from the retailer’s bulk tanks. Retailers often store minibulks in the same heated contained buildings as their stationary bulk tanks.
Minibulks are designed to be mobile, shuttling product to the farm or field where users can transfer the material directly to sprayers. Farmers and retailers also place minibulks on trailers along with water and other supplies. The trailers become mobile mixing sites and can easily follow sprayers from one field to the next.
At one time, minibulks came in dozens of shapes and colors. It was easy to identify a particular pesticide product based on the shape, color, and size of the container.
Today, most manufacturers place their products in caged plastic tanks. Cage tanks are basically nondescript molded plastic tanks that have supporting steel or aluminum shells around them and bladders inside the cage.
Although minibulks are sometimes used for semi-permanent storage, they are really designed to be mobile containers that can be filled, emptied, and refilled quickly. If used the way they are intended (as temporary storage), then the regulations state that minibulks that are stored or used at retailers or farms for 30 days or less do not require secondary containment.
For prefilled minibulks delivered to retailers or farms, the 30-day period starts on the day of delivery. For retailers that refill minibulks, the 30-day period starts on the day the minibulk is filled. If OISC inspects a facility, it is likely the facility that’s being inspected (whether farm or retail) will have to furnish proof of date filled or date delivered.
The requirements for storing bulk pesticides and fertilizers are different. Regulations for bulk fertilizer storage start when quantities exceed 7,500 gallons or a single tank holds more than 2,500 gallons.
See Bulk Pesticide and Fertilizer Storage on Indiana Farms (Purdue Extension
publication PPP-63), available at edustore.purdue.edu and ppp.purdue.edu.
Minibulks stored at the farm or retailer for more than 30 days must be in secondary containment. There are a few secondary containment options for storing minibulks.
These options can include:
Federal regulations spell out specific requirements that dealers must comply with when they take product from stationary bulk tanks to fill minibulks.
According to the regulations, any facility that “produces” a pesticide product is required to register with EPA as a pesticide-producing establishment. Production can mean that the facility mixes ingredients according to a labeled formula to make a pesticide product. Or, as is usually the case with ag retailers, production can mean simply transferring pesticide product from one container to another for the purpose of resale. All pesticide-producing establishments must report their production (even zero production) to the EPA by March 1 of the following year.
Retailers must have repackaging agreements from each manufacturer to repackage bulk pesticide products. Retailers must make copies of current agreements available for inspection by the OISC at each repackaging location. The written contracts lay out exactly what products ag retailers can repackage, what containers the products can be repackaged in, how and when to clean minibulks, and inspection protocols.
Whenever users refill or repackage minibulks, they must mark each one with a unique ID or serial number.
However, minibulks obtained directly from manufacturers and shipped to customers do not require unique serial numbers. If farmers bring minibulks back to retailers for refilling, all of the repack agreement requirements kick-in,
including assigning the shuttle an ID number.
Do farmers with their own bulk tanks have to follow the same requirements
as ag retailers?
Farmers who store bulk pesticides for their own use, are considered end users.
Under this use, farmers are not subject to EPA’s bulk repacking regulations.
However, if a farmer acts as a retailer and sells minibulks to other growers,
then that farmer now falls within the full scope of the repackaging regulations.
Refillable minibulks must have one-way valves that only allow product to flow out of the tank.
Retailers and manufacturers must place tamper-evident seals on or around openings before they ship minibulks. These external seals provide important visual clues when users return minibulks. The seals help protect the product’s integrity while in service. If the seals are intact, the product in the tank has not been tampered with. If any of the seals are broken, retailers must follow the specific cleaning instructions found in their repackaging agreements before they can refill the minibulks — even if they refill minibulks with the same product.
Attach new labels to minibulks each time you fill them. The labels should include the EPA establishment number and net contents. The establishment number on the minibulk is the same one the EPA assigned to the facility. This holds true even if a facility fills a minibulk for a “sister” facility. The establishment number written on a minibulk is always the number for the location where the container is filled.
It is important to note that the tank’s net contents are not the same as the tank’s capacity. The net contents are the amount of product that was put into the tank at refilling. For example, let’s say a customer brought back a 250-gallon tank to the retailer for refilling. There were 50 gallons remaining in the tank when the customer brought it in. The dealer put 200 gallons in the tank.
The net contents written on the label would be 200 gallons, not 250 gallons. Although not required, some dealers also include the date the minibulk was refilled on each label.
Each time retailers fill containers, they must record the unique ID numbers, dates, and EPA registration numbers for the products. Retailers must keep these production records for three years. If the product is a restricted-use pesticide (RUP), then retailers must keep an additional, more detailed record of sale or application for two years. Each year, retailers must submit a summary of all pesticide production (amounts filled for each bulk pesticide product) to the EPA.
Retailers must determine if minibulks can be refilled by reviewing the tank labels to see if they are marked as refillable or non-refillable. Since most minibulks are meant to be reused, inspecting them is perhaps the most
important part of the refilling process.
Proper inspections can reveal faulty containers, leaking valves, tanks that need to be recertified (pressure-tested), or contamination issues. Failing to inspect returned containers before refilling them can result in contamination issues, which may cause thousands of dollars in unintentional crop damage and ruined reputations.
When you inspect minibulks:
• Ensure that all valves are functioning.
• Examine the outside of the tank for any spills, leaks, or cracks.
• Examine the pesticide label on the outside of the tank and all tamper-evident seals to ensure they are intact. If the tank labels do not match the product about to be put into them, or if any seal is cut or broken, then retailers must clean the minibulks according to the instructions in the repack agreement. They must clean the tanks over a wash pad where they can collect the rinse water.
EPA regulations defer to the United States Department of Transportation (DOT) when it comes to testing the integrity of minibulks. DOT requires pesticide manufacturers to build their shuttles to specific standards that depend on the classification of the pesticides they will transport. DOT regulations require that some, but not all, minibulks used to transport pesticides must be pressure tested every 2.5 years or 30 months.
For the purpose of this publication we have arbitrarily sorted minibulks into four major categories under DOT rules:
2. Single use, nonrefillable tanks. These tanks are more commonly used for adjuvants. Pesticides are seldom packaged in one-way shuttles. Since these are one-way, disposable tanks, they do not require pressure testing. Check labels to confirm tanks are non-refillable.
3. Limited refillable and reusable minibulk tanks. Refillable minibulk tanks (or cage tanks) are containers that the retailer will dispose of at the end of 2.5 years. Consequently, these tanks do not require pressure testing.
4. Long-term, refillable, and reusable minibulk tanks. These are the tanks that require pressure testing every 2.5 years. Check labels to confirm tanks are refillable.
One of the quickest ways to determine if a minibulk requires pressure testing is to look at the UN code assigned and affixed to the minibulk. The testing requirements for any tank are based on the UN specification mark on the
tank itself.
The specifications include the UN symbol:
UN containers have an X, Y, or Z marked on the tank. Refillable UN containers require pressure testing every 2.5 years.
At a minimum, employees who pressure-test minibulks should wear eye protection, but be sure to follow label directions relative to personal protective equipment.
To begin the pressure test, make sure that all openings (like caps, one-way valves, and vents) are completely closed. Pressurize the container to 3 psi and wait 5 minutes to see if the tank maintains pressure. The pressure added to the tank may cause the container to slightly bulge out. Do not apply too much pressure — that can permanently damage the container and/or injure the tester.
If a tank does not maintain the pressure, it means there is a leak. Take either soapy water or glass cleaner and spray it around the lids, valves, and other areas to pinpoint the leak’s source. The solution will bubble up, revealing the exact location of the leak. Repairing leaks is often as easy as replacing an O-ring in a cap or tightening a loose valve.
These photos show a tank with almost 2 psi. “We stopped the test, because the two metal straps on top were about to break,” the operator said. Always use caution when pressure testing cages!
If the container holds 3 psi for 5 minutes with no signs of leaks, then it has passed the pressure test. Permanently mark the month and year of the inspection on the container near the UN marking.
In addition, you must create a record to document the testing protocols. These documents must be kept for three years.
That documentation must include:
There are times when tanks fail pressure tests and must be taken out of service. When that happens, permanently and prominently mark the minibulk as “Out of Service” or “Failed Pressure Test.” Make sure to note in your records when you took a container out of service, and then destroyed or recycled it. The Pesticide Stewardship Alliance lists minibulk recyclers on their website: tpsalliance.org/mini-bulk-ibcmgmt/container-collection-and-recycling-resources.
As end users, farmers are not required to follow the same production rules as ag retailers. This means you can transfer material for your own use from a retailer’s minibulk into your own minibulk without worrying about production reports, UN codes, or even pressure testing.
However, just because you don’t have to do something doesn’t mean you shouldn’t do it! Consider the following problems that can be caused by ignoring industry requirements, common sense, and a few best-management practices.
If you never inspect your own minibulks, you almost guarantee a tank failure in the future. In addition, insurance policies do not normally cover spills along highways or ditches unless you added special coverage. The potential economic losses (not to mention environmental impact) from a pesticide spill could force a farm out of business.
Failing to dedicate minibulks to a single product or failing to properly clean minibulks can cause product contamination. Contamination usually results in sizeable crop damage and injury, which your insurance may not cover.
A nonscientific survey found few problems with farmers breaking seals or tampering with minibulks owned by retailers. If farmers return any tank to their dealers with any indication that seals, tags, or one-way valves have been damaged, the ag dealers are required to thoroughly clean the tanks according to the manufacturer’s directions as spelled out in the repackaging
agreement.
If a farmer breaks the seals, then the farmer may have to purchase the minibulk, pay to have it cleaned, or not receive credit for product remaining in the minibulk.
Because retailers are required to follow repackaging agreements, they will not fill minibulks that do not meet the standards set out in their contracts. Farmer-owned tanks that don’t have one-way valves, have no tamper-evident seals, or worse, still contain product, represent huge liability risks for retailers. Likewise, retailer-owned minibulks that are returned with broken seals and leftover product also represent, at the very least, a dilemma for retailers — do they take a chance by taking the product back? Or do they possibly lose customers by telling them they will not accept the return?
The simplest way to avoid all of these possible problems is to use only retailer-maintained tanks that are returned in good working order with seals intact.
The most serious of the issues is the retailer’s response to material left in a shuttle when an inspection shows that the seals have been broken. The farmer may be asked to take the product home, since the retailer cannot know for certain whether the product has been adulterated.
There is no doubt that agriculture has embraced minibulk use as a very cost-effective and efficient way of moving pesticides from retailers to farms. The convenience of bypassing many smaller containers and the lower price
of bulk products makes minibulk use an important part of agricultural production.
Farmers and retailers know the benefits of minibulks well, but they also need to know about the concerns of spills and tank contamination. Retailers and farmers agree that the added cost of secondary containment and following repackaging agreements is significant. However, they also agree that following the regulations helps prevent spills, lower the frequency of tank cross-contaminations, and improve environmental quality. When farmers and retailers work together as part of a “minibulk system,” they both can reap the benefits of lower product cost and liability and increased safety and profit.
Thanks to Dawn Minns for graphic design. Thanks also to the following individuals who provided valuable comments and suggestions that improved this publication.
Brandon Bowser, Harvest Land Co-op
Chuck Croy, CERES Solutions
Patricia Dunn, Office of Indiana State Chemist
Ronald Hellenthal, Emeritus Professor, Notre Dame University
Patrick Hickner, Co-Alliance
Jeff Jeffries, Winfield Solutions
If you want to learn more, please visit our website Pesticide Intermediates.
Matthew Pearson, Office of Indiana State Chemist
Brad Peas, AgroChem
David Peters, Bayer Crop Science
Doug Whicker, Co-Alliance
This publication is intended for educational purposes only. The authors’ views have not been approved by any government agency, business, or individual and cannot be construed as representing a perspective other than that of the authors. The publication is distributed with the understanding that the authors are not rendering legal or other professional advice to the reader, and that the information contained herein should not be regarded or relied upon as a substitute for professional consultation. The use of information contained herein constitutes an agreement to hold the authors, companies or reviewers harmless for liability, damage, or expense incurred as a result of reference to or reliance upon the information provided. Mention of a proprietary product or service does not constitute an endorsement by the authors or their employers. Descriptions of specific situations are included only as hypothetical case studies to assist readers, and they are not intended to represent any actual person, business entity, or situation.
Reference in this publication to any specific commercial product, process, or service, or the use of any trade, firm, or corporation name is for general informational purposes only and does not constitute an endorsement, recommendation, or certification of any kind by Purdue University. Individuals using such products assume responsibility that the product is used in a way intended by the manufacturer and misuse is neither endorsed nor condoned by the authors nor the manufacturer.
Reference in this publication to any specific commercial product, process, or service, or the use of any trade, firm, or corporation name is for general informational purposes only and does not constitute an endorsement, recommendation, or certification of any kind by Purdue Extension. Individuals using such products assume responsibility for their use in accordance with current directions of the manufacturer.
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October
Most organisms are not considered pests. However, certain situations may occur that prompt an organism to be labeled a pest. Organisms are considered pests when they
A pest can be an invertebrate (e.g., insect, mite, tick, slug), pathogen (e.g., bacteria, fungi, virus), plant (weed), vertebrate (e.g., deer, rodent), or other unwanted organism. It is important to correctly define an organism as a pest, and verify the identity of a pest, before making any pest management decisions.
Integrated pest management (IPM) is an ecosystem-based strategy that focuses on long-term prevention of pests or their damage through a combination of appropriate control tactics. These tactics can be preventative, curative, or both and are often combined to provide the best possible results. An IPM program proactively seeks to determine and correct the cause of a pest problem while also minimizing risks to human health and the environment. In short, IPM can be thought of as best practices for managing pests. IPM plans can be developed for virtually any setting where pests occur such as gardens, farms, natural areas, homes, or schools.
When dealing with any pest issue, there are important questions to ask and decisions to make. Start by identifying or describing the problem. Ask yourself these questions:
The process of answering these questions will help you begin implementing an integrated pest management plan.
The purpose of IPM is to provide practical, cost-effective solutions for managing pests while protecting people, animals, and the environment. A major goal of IPM is to reduce reliance on pesticides by using a variety of control methods. Integrating multiple control methods has the added benefit of helping to avoid or delay development of resistance to any one pest control technique or tactic. However, before focusing on the methods for managing pests, it is important to first think about your pest control goals.
The objective of IPM in most outdoor situations is not to eliminate the pest population, but to suppress pest numbers or damage to a tolerable level. In many cases, a certain level of pest presence can be tolerated because the complete eradication of a pest species may be prohibitively expensive or technically impossible. In indoor areas, eradication of a pest population is often more feasible because the environment is smaller, less complex, and more easily controlled than outdoor areas. In either case, determining what a tolerable level is for your situation is essential during the goal setting process. When establishing tolerance levels, a number of factors can be considered such as the potential damage (economic, aesthetics, health, etc.) from the pest’s activities and the cost and/or time involved to control the pest.
Once pest control goals have been established, you can begin developing your IPM plan. Although IPM plans can vary with each situation, they all follow a similar process:
Together, these actions enable informed and intelligent decision-making regarding pest control.
Prevention strategies can help limit the factors that contribute to pest issues in our gardens, homes, lawns, and other areas. Preventative measures taken before a pest appears can result in fewer rescue treatments, and should be used first if practical and available. It may be easier and more effective to remove the reason why the pest is present in the first place, as opposed to controlling the pest after the fact. Prevention strategies are used to create a healthy, growing environment that limits the introduction of pests and their ability to reproduce, develop, and/or spread. Preventative tactics can include:
Correct identification of the pest or problem is the foundation of any IPM plan and can be considered the most important step. It starts with asking yourself if what you are seeing is actually a pest. Do not treat an organism as a pest until it has proven to be one. Make sure the damage observed is due to the pest and not another cause.
Proper identification will provide you with important information about the pest. This can include its preferred habitat, life cycle, and the factors that influence its spread and development. The more information that can be gathered about a pest, the greater the opportunity for cost-effective and successful pest control. Although identifying a pest can sometimes be difficult, there are several Virginia Cooperative Extension resources that can help.
Another key component to a successful IPM plan is regular monitoring of pest populations or their damage. Monitoring can answer several important questions:
To aid monitoring efforts, it is important to learn about the preferences and common problems relevant to the system being managed. For example, in a vegetable garden it is important to know what healthy plants look like, so you can quickly notice if something is abnormal or does not quite look right. Pest management guides can be used to familiarize yourself with some of the common pests and problems in the systems being managed.
Regular monitoring of a garden, lawn, home, or other site will allow for early detection of pests, which can help prevent or minimize a pest outbreak. Specifics on how often monitoring should be conducted depends on the system being managed and the pest. Regardless, it is often easier to control a pest problem in the early stages before populations have increased in size and spread.
Pest populations can vary from one location to another and from year to year. For this reason, it is important to consider keeping records of your monitoring activities. Records can help you manage pests during the current growing season, evaluate current control methods, and predict problems in the future.
If preventative measures fail to control a pest population, you will need to assess their damage and set a threshold for when to initiate a control measure or rescue treatment. A threshold can be thought of as a tolerance level. In other words, is the pest population and its damage tolerable in your garden, lawn, or home? Or is it causing economic, aesthetic, or other losses? Remember, finding a single pest or low levels of a pest may not indicate you should take action for its control. Only when the pest and/or its harm surpass a set level of tolerable damage should controls be implemented. Determining a threshold for each pest you are assessing will help you move forward with implementing control tactics only when necessary.
For some pests and commodities, thresholds have been developed based on economic or other considerations and are often based on monitoring data. For example, in tree fruit, if captures of codling moth in pheromone baited traps exceeds five moths per trap per week, control is necessary to prevent economic losses from this pest. For other pests, thresholds may involve some other assessment such as percent defoliation, leaf wetness duration, or population numbers per unit area.
In some situations, thresholds cannot be developed or have limited value. This is particularly true for many plant diseases, disease vectors (e.g., mosquitoes, ticks, fleas), or newly invasive species, which essentially have a threshold of zero. Controls for these pests are often initiated preventively or immediately upon detection.
When pest populations and/or their damage exceed established thresholds, it is time to initiate a control measure or rescue treatment. In an IPM program there are nonchemical and chemical control methods available. Nonchemical control methods should be used first if available and feasible. The techniques or tactics you choose will depend on the target pest and the kind and amount of control needed. IPM promotes the use of four basic pest control methods, as explained below.
Cultural Control: Controlling a pest with cultural methods involves modifying or disrupting the pest environment to make it less habitable. Many cultural control tactics can be thought of as preventative because they keep pest populations from developing or delay their impact. Examples of cultural control tactics include:
Mechanical/Physical Control: This method involves the use of hands-on techniques or simple equipment/devices to reduce or prevent the spread of pest populations. This is often achieved through activities that directly remove or exclude the pest from the system. Examples of removal include the use of traps to remove rodents from a structure, or hand removal of weeds from a garden bed. Techniques that focus on removal can be particularly effective if pest populations have not already reached high levels. Exclusionary tactics limit pest access into the system. Examples of exclusion include the use of row covers or fencing to prevent pests from feeding on plants in a garden, or the use of tight-fitting screens on windows and doors to prevent pest entry into a home.
Biological Control: This method involves the use of living organisms (i.e., natural enemies) to reduce pest populations (typically insects and weeds). Introducing or encouraging natural enemies can reduce the severity of potential pest outbreaks. Natural enemies can typically be grouped as predators, parasitoids, or pathogens. Predators feed on multiple prey throughout their life (e.g., insects, spiders, birds, fish). Parasitoids feed and develop on or within another invertebrate host, eventually killing it (e.g., parasitic wasps and flies). Pathogens are microorganisms that cause disease in their host (e.g., bacteria, fungi, nematodes, viruses).
Conservation of natural enemies (i.e., protecting and maintaining existing populations) is a readily available form of biological control for gardeners. Common conservation practices include limiting the use of broad-spectrum pesticides that kill a wide range of organisms, and providing habitat that promotes the establishment and survival of natural enemies.
Chemical Control: This method involves the use of pesticides to reduce pest populations. A pesticide is any substance that is used to prevent, destroy, repel, or mitigate any pest. Pesticides can be synthetic (man-made), or natural products derived from plants, microorganisms, or inorganic elements. Although a major goal of IPM is to reduce reliance on pesticides, they are sometimes necessary to control pests and their damage. When selecting a pesticide, it is important to choose a product that is compatible with any nonchemical control methods that may already be in place. Safe use and other considerations regarding pesticides will be discussed in further detail later in this chapter.
An important, but often overlooked, step is to evaluate the results of your control efforts. Because of the variability present in any biological system, the effectiveness of an IPM plan may change over time or between sites. Understand that IPM plans are not static, but constantly evolve as more information is collected and new control tactics are developed. There is seldom a single correct solution to a pest problem. Regular monitoring will help you to determine how well you are meeting your pest management goals and if changes are needed. Be aware that some control tactics may be slow to show noticeable results. It is also important to evaluate any potential negative impacts your control efforts may have on the target treated, natural enemies present, and the environment before deciding to continue using them in the future.
If you decide to include chemical control in your pest management plan, do so safely. Proper selection and proper use of pesticides is key for not only controlling the pest, but protecting yourself, others, and the environment. Following safety precautions and using common sense can prevent pesticides from causing unintended and unnecessary harm. Always read the pesticide product label before purchasing, using, storing, or disposing of a pesticide product or its container.
When selecting a pesticide, choose a product that is labeled for the site you need to treat and effective against the pest you need to control. Consider only those products you have the equipment and expertise to handle. If there is a choice of several products, select the least hazardous product with the lowest toxicity. For pest management recommendations, contact your local Extension office or consult the Virginia Cooperative Extension “Pest Management Guide: Home Grounds and Animals” 456-018
Some pesticides are specifically intended for home use. These products are packaged in small quantities (i.e., pints, quarts, and ounces) and are often ready-to-use. Their label directions are less technical than those intended for occupational users. Most pesticide products intended for home use are low in toxicity but can still be dangerous if used improperly. It is important to read and follow all label directions to help prevent pesticide related accidents.
Some pesticide products available for purchase are intended for agricultural and professional/commercial use. These products will have statements on the front of the label that indicate the intended user. You should not purchase these products. Often, these products are higher in toxicity because they are highly concentrated or contain higher amounts of active ingredients. They may require special protective clothing and application equipment. They are also sold in larger containers, which means the homeowner will have more material than can be used in a reasonable amount of time. Additionally, application rates are often given on a per-acre basis, making them difficult to mix.
Reading the label before purchasing a pesticide is the only way to be sure you can use the product as directed. Be sure you have the proper handling and measuring devices, application equipment, and protective clothing. Read the mixing instructions and application directions. Note any special handling instructions, specific warnings, and precautions.
The U.S. Environmental Protection Agency (EPA) and the Virginia Department of Agriculture and Consumer Services, Office of Pesticide Services (VDACS-OPS) are the regulatory agencies charged with enforcing pesticide laws and regulations. Under the Federal Insecticide, Fungicide, and Rodenticide Act, it is illegal to use a pesticide on a site unless that site (plant, animal, place) is listed on the label. You may not exceed the application rate or other special use restrictions as directed by the label.
You are liable for misuse of pesticides on your property, which includes applications you may make or the applications of any commercial applicators you hire. Serious misuse may result in drift on to other people’s property, leaching of a pesticide into water supplies, or other problems related to application of a pesticide contrary to label directions.
Some pesticide products are extremely hazardous to humans and/or the environment. The EPA classifies these products as restricted use pesticides (RUPs). A certificate issued by VDACS-OPS is required to purchase and use RUP products. If a person intends to use RUPs to produce agricultural commodities on their farm or land they lease, they are required to have private pesticide applicator certification. Anyone who uses RUPs as a part of their job duties, must obtain a commercial pesticide applicator or registered technician certification. The process of certification and use of RUP products is NOT intended for the home gardener.
The words “insecticides” and “pesticides” are often used interchangeably. However, these two words have different meanings. As you can see in Table 7-1, an insecticide is just one type of pesticide.
Pesticides work in different ways. They can be grouped in any of several ways on the basis of their chemistry, how/when they work, or their site of action (see Table 7-2 for examples).
In order for a pesticide to be sold, purchased, or used in the United States, the pesticide must be registered by the EPA. Registration decisions are based on the agency’s examination of the
The EPA assesses both risks and benefits of a product. They only register pesticide products that the agency has determined will not pose unreasonable adverse effects to humans, the environment, and nontarget species when used according to label directions. A product cannot be legally sold, purchased, or used as a pesticide until it is registered with the EPA’s Office of Pesticide Programs.
Another category of available products is Section 25(b), minimum-risk pesticides. Minimum-risk pesticides are exempt from federal registration by the EPA because they have been determined to pose little to no risk to human health or the environment. Minimum-risk pesticides are often derived from plant and food compounds and therefore are considered relatively benign. Although EPA does not require federal registration of Section 25(b), minimum-risk pesticides, many states require them to be registered with their state pesticide regulatory agency. In Virginia, these products must be registered with the VDACS-OPS if they are to be manufactured, distributed, sold, or used within the state. Be aware that because minimum-risk pesticides are exempt from the federal registration process, their labels may offer limited information on safety and efficacy. Exercise caution and follow all label directions if using minimum-risk pesticides no matter how natural the ingredients appear.
Federal law defines pesticide labeling as all of the print information and graphics (label, booklet) attached to or sold with the product. The pesticide label is a binding legal agreement among three parties: the product registrant (manufacturer), the EPA, and the end user.
The pesticide label must provide the user with all the necessary information on safe and effective use, proper storage, and proper disposal of the pesticide and its container. Pesticide users are required to follow all label directions. Using a pesticide in any manner that is inconsistent with the labeling is against the law.
Specific parts of the label identify the product, its hazards and precautions for handlers, and directions for proper use, storage, and disposal. The following section lists the information commonly found in specific parts of the pesticide label.
Brand Name: Each company uses brand names to identify their products. The brand name is displayed prominently on the front panel of the label.
Ingredients Statement: The ingredients statement lists the active ingredients (the chemicals that affect or control the target pest). It must list the chemical name and amount of each active ingredient (as a percentage by weight of the total product). The label must also show what percent of the total contents are other (inert) ingredients.
Pesticides have complex chemical names describing their chemical composition. Many chemical names are shortened into common names to make them easier to identify. A product label may use the chemical name, common name, or both to identify the active ingredient(s).EPA Registration Number: A registration number must be on every pesticide label. This number shows that the product has been registered with the EPA for the uses listed on the label. EPA registration numbers are unique to each individual pesticide product.
EPA Establishment Number: The establishment number identifies the facility where the pesticide was produced.
Name and Address of Manufacturer: The law requires the manufacturer or distributor of a pesticide product to print the name and address of their company on the label.
Net Contents: The front panel of a pesticide states how much product is in the container. This can be listed as pints, pounds, quarts, gallons, or other units of measure.
Type of Pesticide: The front panel usually indicates in general terms what the pesticide will control. This statement might also indicate how the product may be used.
Type of Formulation: A pesticide formulation is the mixture of chemical ingredients (active and inert) that allows the product to be used effectively for the purpose claimed. Pesticide formulations can be sold as ready-to-use (meaning no further mixing is required) or as concentrated formulations, which require mixing and/or application equipment. Sometimes the formulation of a specific product is written on the label or is part of the product name (e.g., bait, dust, granule).
“Restricted Use” Designation: When a pesticide is classified as restricted use, the label will state “Restricted Use Pesticide” in a box at the top of the front panel. There may also be a statement describing the reason for the restricted use classification. Restricted use pesticides are not for home and garden use and should only be used by a certified pesticide applicator.
Precautionary Statements: Precautionary statements identify hazards associated with the use of the product, how to avoid them, and first aid for various exposure situations. The product’s toxicity is described by the signal word. All pesticide products carry the child hazard warning statement “Keep Out of Reach of Children.” The precautionary statements section of a label may also include personal protective equipment (PPE) requirements, user safety requirements and recommendations, environmental hazards, and physical or chemical hazards.
Signal Words and Symbols: You can tell how acutely toxic a pesticide product is by the signal word on the label.
Pesticides with the signal word DANGER are typically not sold in the lawn and garden trade.
First Aid (Statement of Practical Treatment): The label provides emergency first aid instructions and describes the types of exposure requiring medical attention. Four routes of exposure can be harmful: ingestion (swallowing), inhalation (inhaling vapors), ocular (eyes) exposure, and dermal (skin) exposure.
Personal Protective Equipment (PPE): The label lists all protective clothing and equipment you must use when handling the product. At minimum, you should always wear long pants, a long-sleeved shirt, socks, and closed-toed shoes.
Hazards to Humans and Domestic Animals: This section must be included if a product is hazardous to humans or domestic animals. It will tell you if and how a product may harm people and animals. It will also describe any special steps necessary to avoid exposures.
Environmental Hazards: The label tells you how to avoid harm to the environment — including water, soil, air, and beneficial insects, plants, and/or wildlife. Some examples of hazard statements are:
Physical and Chemical Hazards: This section lists any specific fire, explosive, or chemical hazards the product may have.
Directions for Use: This section describes where, when, and how to apply the product, how much to use, and how to handle the product from start to finish. These instructions will:
All pesticide labels have a restricted entry interval (REI). The REI indicates how long to stay out of treated areas. Some products instruct you to keep people or pets out of the treated area for a short period of time, or until certain conditions are met. For example, the label may state, “Do not allow people or pets to enter the treated area until sprays have dried.”
*Pesticides labeled for use on food crops have a pre-harvest interval (PHI). The PHI is a period between the time of application and the time it is safe to pick and use the crop. A pre-harvest interval is usually written as “days to harvest.”
Misuse Statement: This section will remind you that it is a violation of federal law to use a product in a manner that is inconsistent with its labeling.
Reviewed by Elizabeth Brown, Bedford Extension Master Gardener ()
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