PRN 97-4: Consumer Access Numbers on Pesticide Labels

Notice To: Manufacturers, Producers, Formulators, and Registrants of Pesticide Products

Attention: Persons Responsible for the Registration of Pesticides

Subject: Consumer Access Numbers on Pesticide Labels

This notice describes EPA policy on including telephone numbers and other access numbers, such as internet addresses, on pesticide product labeling. The notice also explains how the telephone number of the National Pesticide Information Center (NPIC) hotline may be used on the label. (NPIC was previously known as the National Pesticide Telecommunications Network or NPTN.)

Addition of telephone numbers, including the NPIC phone number) and internet addresses may be done at any time without notification to EPA. EPA strongly encourages registrants to include such information when labels are routinely reprinted.

1. Background
2. Consumer Labeling Initiative
3. Policy
4. Procedure
5. For Further Information

1. Background

   Pesticide products are required to be labeled with the name and address of the registrant. EPA does not currently require that the label provide a telephone number so that users and others can contact the registrant directly and immediately. EPA does not require a telephone number because it appreciates that staffing such a number and responding to inquiries can be an expense that some companies may not be able to afford.

   However, a number of registrants, particularly larger companies, have voluntarily included a telephone number on the label as a customer service. Direct access to the registrant allows the company to provide immediate information or answer questions on the pesticide product, its ingredients, and uses, and to gain valuable information about user/consumer concerns and perceptions. Some registrants provide a "hotline" (toll-free) service, while others do not.

   EPA, in conjunction with the Oregon State University, also provides a hotline for public information on pesticides via the NPIC. The NPIC dispenses objective scientific information on a variety of pesticide topics, including pesticide toxicology, health and environmental effects, recognition and management of pesticide poisonings, laboratory analyses, clean-up and disposal of pesticides, and emergency treatment information. The NPIC also receives information from callers about pesticide incidents and directs callers to the appropriate sources for pesticide incident investigations. In cases of human and animal emergencies, callers can be telephone switched directly into a Poison Control Center from NPIC.  NPIC can be accessed via:

   Telephone: 1-800-858-7378
   FAX: 1-541-737-0761
   E-mail: [email protected]
   Internet: National Pesticide Information Center 

    

   A number of registrants have included the NPIC hotline number on labeling, and, in some cases, EPA has required that the number be included on labeling.

   EPA believes that, although the label should be the principal source of user information on a pesticide product, users should have as many sources of information about pesticides as possible. EPA is aware that users may not fully understand labels, or may have additional questions or concerns after reading the label. Being able to call directly to the registrant that makes the product (or reach the registrant electronically) may be a valuable source of information for some consumers.

2. Consumer Labeling Initiative

   In 1996, EPA began a Consumer Labeling Initiative (CLI), which has as its goal the improvement of consumer labeling (focusing on pesticide products). In the first phase of the CLI, one-on-one interviews were conducted with users of household pesticides (both indoor and outdoor) and pesticide and non-pesticide cleaning agents. Consumers in these interviews indicated a desire for telephone numbers on labels to access product and safety information. The CLI Phase I report recommended that EPA also explore other ways of making such information available to consumers. This notice follows through on these recommendations.

3. Policy

   1. Telephone numbers. EPA encourages registrants to include a company telephone number or toll-free hotline number on the pesticide label. If a number is included, it should include a phrase or statement indicating the kinds of information the number should be used for, or if it may be used for all information, a simple lead-in phrase. The explanatory statement may include hours of service. For example:
       

      For information on [product usage, etc.],
      call 1-800-555-0000, Monday through Friday,
      9 am to 5 pm.
      
      or, more simply,
      
      Questions? 1-800-555-0000.

   2. Use of the NPIC hotline number. A registrant may include on his labeling the NPIC hotline number, whether or not he also includes a company number, using the following statement:
       

      For information on this pesticide product (including health concerns, medical emergencies, or pesticide incidents), call the National Pesticide Information Center at 1-800-858-7378.

   3. Internet homepages. EPA also encourages registrants to include on the label an Internet homepage address at which consumers may access information on a product. By making information available electronically, a company may reduce the volume of telephone calls that it receives. Registrants are reminded, however, that individual product claims on a company homepage must not exceed those approved by the Agency in connection with the product's registration. Claims that exceed those approved by EPA in conjunction with registration may result in the product's being misbranded under FIFRA sec. 12.
   4. Adverse effects information. Registrants are reminded of their obligation under FIFRA sec. 6(a)(2) to report to EPA any factual information regarding unreasonable adverse effects they become aware of. Such information may be received through consumer telephone calls or electronic access.

4. Procedure

   A registrant may at any time add or delete a registrant telephone number, explanatory statement about the telephone number, the NPIC hotline statement in III.B. or Internet homepage address on a product label without notifying EPA (a "non-notification" under 40 CFR 152.46).

Daniel M. Barolo, Director
Office of Pesticide Programs