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Improving Labels for Adult Mosqu

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					PR NOTICE -- Improving
Labels for Adult Mosquito
   Control Products

          Jim Roelofs
  Office of Pesticide Programs
             US EPA


                                 1
         Origin(s) of Projects
   SFIREG Issue Paper - 1999
   WNV conference in Region 2 - 2001
   Ad hoc EPA-State group developed initial
    recommendations
   PPDC (April 03) advised EPA to do PRN


                                               2
    Recommendations at April ’03 PPDC

   Trained applicators, or      Make hazard language
    Restricted Use                specific as possible
   Separate directions for      Consult with State
    mosquito control              lead agency
   Qualify “terrestrial         Improve calibration
    use” on mixed labels          instructions
   Allow application
    “over water” if needed
    to target mosquitoes
                                                        3
       Current Draft Recommendations

    Retains the original 7, but merged some of
    them

   Adds 2 new ones concerning -- modified
    bee precaution language (#6); and specify
    timing and frequency (#7)


                                                  4
         Rec. #1 – Trained personnel

   Broad support for general concept

   Different views on how to do it

   Proposal language tries to accommodate
    various forms of existing training


                                             5
    Rec. #2 -- Separate mosquito labels

   Mosquito-only labels easiest to deal with
    for users and regulators

   Avoid confusion over “terrestrial use”
    statement



                                                6
     Rec. #3 Improve Hazard Statements

   Make application over water allowable

   Make aquatic species hazards more specific
    (if data support).

   Raises NPDES issue


                                                 7
Rec. #4 Consult with State Lead Agency

   We think SLA is most reliable source of
    info about possible state requirements.
   Some commenters doubted value, thought it
    would be burden
   We still think SLA is best, but make it
    advisory only.

                                              8
       Rec. #5 Appropriate Calibration
                Instructions

   Labels are all over the board in this area.

   We try to present a consistent approach;
    registrant identify droplet spectrum; user
    refers to equipment maker’s instructions to
    achieve it.


                                                  9
        Rec. #6 – Modify bee
             precaution
   “Hurricane Floyd” raised issue

   Current language has no exceptions

   Adds public health need as an exception –
    issue is who determines?


                                                10
       Rec. #7 -- Frequency and timing

   “Repeat as needed” appears on most m. c. labels
    Problems – (1) does not comply with label
    regulations (specify timing and frequency); (2)
    users, regulators and public may perceive “as
    needed” differently; (3) does not help EPA do risk
    assessment
   However – public health protection may require
    unpredictable retreatments.

                                                      11
                Next Steps
   Send comments to docket – e-mail or hard
    copy -- (OPP2004-0018)

   Closes July 27

   Questions? roelofs.jim@epa.gov


                                               12

				
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