EPA’s Web Label Initiative Flawed

For those so inclined, the convenience of doing things electronically that once meant driving across town, waiting in lines, or affixing stamps to envelopes is undeniable. Trading these things for a few mouse clicks saves time, money and hassle. However, in virtually no cases — especially related to regulatory compliance — is engagement in electronic communication an absolute necessity.

So I was quite interested to read that EPA is working toward making the Internet the only means by which one could procure a pesticide label.

The Web-Distributed Label (WDL) project, in the works for the past three years, would require the end-user of a crop protection product to consult the Web and print out a label from a new, government-sponsored electronic label repository before product application.

I got a chance to talk with Daren Coppock, ARA president, about the issue last week and he raised a number of legitimate concerns the association has with such a plan. For starters, reliable Internet service is not ubiquitous in rural America, making mandatory electronic label procurement potentially problematic.

Second, despite EPA’s assurances to the contrary, ARA is concerned about adding liabilities and stress to the retailer-grower relationship. Growers will naturally lean on retailers to provide label information upon purchase of a product, and would expect retailers to be able to inform them of future label changes as they occur. Whether it’s providing a label or training growers to find the information for themselves, the retailer is ultimately liable.

Then there’s the fact that there already are a number of ways for labels to be procured electronically … but it’s optional. And the label’s availability on the container ensures that the information is accessible at the time of use.

There are other objections as well, which are highlighted in the letter. Soon, EPA will be conducting a pilot test of the WDL program, and both ARA and CropLife America are asking the agency to halt the project.

As I said, the Web is an outstanding means of communicating information and adding convenience, but it’s way too soon in its lifespan to consider making it the sole source for label information that’s so critical to proper use and stewardship.

ARA is sending a letter with as many co-signatures as it can gather by end of day Wednesday, November 17.

THE FOLLOWING WAS ADDED BY THE AUTHOR:

There are two links included in the comment below that I wanted to make live links … unfortunately I cannot do it in the actual comment box, so I moved them up here:

Paul, Perhaps it would be a good idea to include a link to the 4 page Summary of the EPA Web Distributed Labeling Pilot from USEPA website so that others not familiar with the project can become acquainted and them voice their disapproval.

Leave a Reply

8 comments on “EPA’s Web Label Initiative Flawed

  1. Paul, Perhaps it would be a good idea to include a link to the 4 page Summary of the EPA Web Distributed Labeling Pilot from USEPA website so that others not familiar with the project can become acquainted and them voice their disapproval.

    Here is the link >> http://epa.gov/pesticides/ppdc/distr-labeling/march09/virtual-pilot.pdf

    And a link to the USEPA site index page for WDL>>
    http://epa.gov/pesticides/ppdc/distr-labeling/march09/virtual-pilot.pdf

    Links to minutes from the years long project(actually conceived as long ago as 2003), lists of WDL Pilot participants, and other items of interest are linked from that page.

  2. I believe the ARA is jumping to conclusions here without understanding the whole story. A major part of the EPA Web Distributed Labeling project is creating a standardized electronic label so submission is easier for manufacturers and the review is easier for the EPA. Does everyone like reading labels that all look different with no standard organization? Just think how inefficient the lack of standardization in labels is for all of us, including the EPA. It makes it harder for them to review and approve labels and for all dealers and end users to read and follow these labels. I agree with ARA, that removing the label from containers and only having them on a website is not a good idea, but my point is this only part of the project. I think the ARA needs to clarify their support of this project: The standardized label with electronic submission and review is good, the removal of labels from containers is bad. Not supporting this is entire project is not good for the industry. Here is a link to the entire story on this project: http://epa.gov/pesticides/ppdc/distr-labeling/

  3. I totally agree with the other commenter, the ARA is not truly grasping what the agenda is with this initiative! We need standards!!! Standards are a must and something that the indsutry has struggled with on many levels. I do agree that digital only with removal from containers is not the way to go but that is only part of the proposed plan. It is a very bad move on behalf of the industry to kill this project or stifle it based on this discrepancy, we need to adjust it and push for change and continue to move the project forward!!

    “Progress is impossible without change, and those who cannot change their minds cannot change anything” -George Bernard Shaw-

  4. Dear Anonymous,

    You may be having difficulty separating the EPA’s E-Label Submission (PRISM) from the proposed Web Distributed Labeling (WDL) Pilot.

    One has absolutely nothing to do with the other as it pertains to the ARA/CropLife proposed Letter. EPA’s “PRISM” could be accessed in the future to output a State specific Label for a Crop and Pest and format a uniform Label. But you need the buy-in from each State in order to do so.

    WDL cannot work without PRISM. They are not the same thing, but WDL would become dependent upon PRISM in the future.

    The WDL will never function outside of the Pilot until E-Label is adopted universally by all Registrants and their sub-Registrants and functions without error.

    For the Registrant and EPA, and perhaps the 30 or so States that are integrated into one system or another at this time then E-Label is a Great Concept once every one of them owns current PDF software (they don’t) and complies with a uniform and standardized appearance that most will never be able to agree upon. Or, the development and management of a submission database is complete and live and applied uniformly across the Country.

    Current Statistics (not all Agriculture specific)

    1300+ Product Registrants (inc sub-Registrants)
    16,000+ Currently Registered Pesticides
    68,000+ Currently Registered Distributor Pesticides
    265,431 Product/Pest combinations (currently active)
    529,112 Product/Site combinations (current)

    EPA WDL was proposed in the Pilot to include “one broad spectrum insecticide and one broad spectrum herbicide” and the input from 50 States + possessions. Many but not all with their own Registration facilities. And then the proposal seeks comment from Dealers / Distributors / Regulators / Registration Professionals / End-Users via Surveys. (!?)

    For the servicing Dealer / Distributor and the End-User WDL could create technical problems for years. Enterprise POS and other systems might require upgrades and overhauls costing millions of dollars to access the WDL portal. The system cannot work until we all have bar code readers built into our eyeglasses and microchips implanted in our forearms to decipher the most current version of a Label.

    It took one Chemical industry sponsored project three years to agree upon a barcode schema. Sam Walton had completed his own version of that project ten years earlier AND he mandated RFID in his operations long before the Crop Chemical industry ever began to even consider such a thing. We have some catching up to do.

    WDL proposes the system also be multi-lingual capable?

    And what of the MSDS? This is an important document, perhaps more important in some respects than the Label itself. Oh, that’s right. The MSDS cannot appear with the Container (err WDL) Label without EPA approval because the MSDS is mandated by another government agency. Whatever happened to Global Harmonization of the MSDS anyway?

    What happened Pesticide Registration Notice (PR) Notice 93-3 regarding Labeled Storage and Disposal Statements that couldn’t be fulfilled? That was “easy” compared to WDL. 93-3 deadlines were recently extended another year.

    And possibly just as big a hurdle is the fact that EPA WDL doesn’t even consider the use of non-Registered products. Adjuvants, “water conditioners”, and so forth may in some cases exhibit an even greater hazard to the User. And that was part of the purpose of WDL… to make the Label easier to use and encourage the User to be familiar with the entire contents of the applicable Label that pertain to his location, his crop, and his target pests. WDL only complicates things now because one has to refer to a WDL website and other sources to find information on the non-registered products that are in use as well.

    Versioning, Supplemental Labels, 24(c), 2ee, Section 18 and out-of-date products (those recently cancelled, but still ‘legal to use”) all fall somewhere between the lines in the WDL program and could become a Regulator’s and User’s nightmare should a Pesticide application ever be questioned or an enforcement action be investigated. Questions regarding valid dates, expiration dates, application, end-of-life, etc all need to be addressed.

    And one final thought. Let’s not forget the cost to perhaps re-write Pesticide Use Laws and Enforcement Regulations in each and every State and some political subdivisions in the Union.

  5. DonH,

    Thanks for comments, you bring up some important points. It sounds like you see a clear distinction between WDL and PRISM programs, but does EPA, does the ARA, does the industry? Where has the EPA documented this clear difference? Do you have a source where they have?

    My worry with ARA’s letter and comments against the WDL program is the fact they make no mention of supporting the PRISM project. Does the ARA support the PRISM program? I also worry by going against the WDL program and slowing down or stopping EPA’s adoption it of it could also do the same with the PRISM program.

    This needs to be clarified by the ARA or they could be killing or delaying the PRISM program that I think we all all agree is for the better of the industry.

  6. As to the comments regarding standards – yes, standards would certainly benefit the users, the dealers, the EPA, and regulators alike. What is that standard? Where is it written? And how can registrants be held to a standard when there is none? If we can’t do it on paper labels, how can we do it on electronic labels?

  7. It is written here. This is a link to details on the PRISM structured e-label initiative:

    http://www.epa.gov/pesticides/ppdc/distr-labeling/june09/elabel-overview.pdf

    If this PRISM initiative is approved and implemented, then there would be a standard the registrants would be held to.

    So we always need to live in the past? If we don’t have standardized labels today, we can’t in the future? If we always had that attitude, how would we get any improvement or progress in this industry?

  8. I’m not sure anyone will really come back to the comments of this now old article but the WDL committee had a meeting on Nov. 30 and several documents from that are now on the following site under the new section:
    http://epa.gov/pesticides/ppdc/distr-labeling/

    Their presentation gives a much brighter picture of this program than the ARA letter message. Here is a link to the presentation slides:
    http://epa.gov/pesticides/ppdc/distr-labeling/nov2010/ppt-outreach-final.pdf

    I think we all agree that removing the full label from containers is a bad idea, but this program has some very good features as well such as the improved label standardization and compliance. ARA needs to be clearer in their message that they support that part of this, just not the full label removal option on containers. Otherwise, we all lose in these efforts.

Legislation Stories

CPP, glyphosate, dicamba, atrazine,
Crop InputsReport: Congress Pressing EPA On Glyphosate Review Handling
May 16, 2016
Via Reuters.com reporter P.J. Huffstutter: U.S. lawmakers have asked EPA to explain why it published – and then withdrew – Read More
Anhydrous Ammonia tanks
LegislationARA: OSHA Announces PSM Formal Rulemaking Intentions
May 11, 2016
In separate communications earlier this week, the Occupational Safety and Health Administration (OSHA) announced plans to conduct formal rulemaking to Read More
Crop InputsBayer: 5 Reasons We Disagree With Maryland Neonic Ban
April 12, 2016
We’re disappointed that the Maryland legislature chose not to stand up for sound science and the rights of Maryland’s homeowners Read More
Michael Hazzan, Technical Manager at AcuTech, PSM Training
LegislationPreparing For Process Safety Management: What Ag Retailers Need To Do
April 3, 2016
By and large, ag retailers like to use three letter acronyms in their day-to-day operations. Most talk about getting a Read More
Trending Articles
Eric SfiligojPity The Monsanto Haters
May 23, 2016
An old saying goes thus: “Be careful what you wish for. You just might get it.” Given current events, there Read More
Monsanto Luling Plant
Crop InputsReport: Bayer Eyeing Monsanto For Possible Mega-Merger
May 16, 2016
Bayer AG is exploring a potential bid for U.S. competitor Monsanto Co. in a deal that would create the world’s Read More
Aerial Drone
Precision AgA Deeper Dive Into The Future Of Precision Ag
May 9, 2016
For about two decades now, through the good and the bad times, the ups and the downs inherent in agriculture, Read More
Palmer amaranth in soybean stubble
HerbicidesWSSA: Billions In Potential Economic Losses From Uncontrolled Weeds
May 4, 2016
What losses would corn and soybean growers experience if they were forced to eliminate herbicides and other control techniques from Read More
Eric SfiligojReasons For Hope In Commodity Prices
May 2, 2016
For many months now, the doomsayers have ruled the day in agriculture. Too much supply with too little demand would Read More
Eric SfiligojMissing The Family Ties In Agriculture
April 25, 2016
By its nature, the agriculture market is cyclical. Up and down cycles come and go with a regular pattern. For Read More
Latest News
ManagementWashington Visit and Bayer/Monsanto Deal Update
May 26, 2016
Editors Paul Schrimpf and Eric Sfiligoj discusses a recent trip to DC and the latest news on the proposed pairing Read More
Fertilizer closeup in hand
Industry NewsVerdesian: Striking A Balance Between Yield & ROI
May 26, 2016
Finely tuned nutrient management plans are helping farmers throughout the U.S. improve nutrient use efficiency, increase return on investment (ROI) Read More
Crop InputsLand O’Lakes Announces Minnesota Water Quality Pa…
May 25, 2016
Governor Mark Dayton and Land O’Lakes, Inc. President and CEO Chris Policinski today announced a new public-private partnership to protect Read More
Soybean Plant closeup
Industry NewsMonsanto Rejects Bayer Bid; Open To More Talks
May 25, 2016
Monsanto Co, the world’s largest seed company, turned down Bayer AG’s $62 billion acquisition bid as “incomplete and financially inadequate” Read More
Corn close up
Crop InputsArysta LifeScience Establishes Global Headquarters In R…
May 25, 2016
Arysta LifeScience has announced plans to relocate its global headquarters from West Palm Beach, FL, to Cary, NC, over the Read More
fertilizer blending and storage, Top 100
BlendersCHS Dakota Expansion Features AGCO’s GSI InterSys…
May 25, 2016
The continued growth of precision agriculture has increased farmer use of customized fertilizer blends best-suited for their soil conditions. Several Read More
ManagementAgriculture 3.5: A Bumpy Road Ahead
May 24, 2016
You may have read my article a few years ago on Agriculture 3.0, which is a term I coined to Read More
Topcon’s X30 display with CropSpec sensors
EquipmentGPS Autosteer Systems: Product Updates From Precision A…
May 24, 2016
Throughout 2015 GPS Steering solutions continued to evolve from what was once an after-market add on, to today’s cab where Read More
Trimble TMX-2050 In-Cab Display
Eric SfiligojThe Precision Ag Revolution Continues
May 24, 2016
It’s funny how much “the first time” tends to mean to someone as they get older. I sometimes can’t recall Read More
Eric Wintemute, AMVAC
Precision AgAMVAC Ups The Ante With New Precision Ag Technology
May 24, 2016
A potentially industry-changing at-plant soil treatment system from American Vanguard Corp., or AMVAC, is coming soon to large growers in Read More
Dry and Liquid Plant
CropLife 100CropLife 100 Map
May 24, 2016
The new CropLife 100 map shows the locations of each of the headquarters of the 2015 CropLife 100 retailers. The interactive Read More
Southern States Cooperative
Corn Field
Industry NewsTiger-Sul Names Veteran Account Manager To Lead Central…
May 23, 2016
With the continuing growth of the sulphur bentonite and precision crop nutrient industry, global agriculture firm H.J. Baker has announced that Read More
Bayer sign
Industry NewsReuters: Bayer Defies Critics With $62 Billion Monsanto…
May 23, 2016
German drugs and crop chemicals group Bayer has offered to buy U.S. seeds company Monsanto for $62 billion in cash, Read More
Eric SfiligojPity The Monsanto Haters
May 23, 2016
An old saying goes thus: “Be careful what you wish for. You just might get it.” Given current events, there Read More
Industry NewsCompass Minerals Hires Industry Veteran To Lead Plant N…
May 19, 2016
Compass Minerals has hired plant nutrition industry veteran Vatren Jurin to steer the company’s portfolio expansion into specialty liquid micronutrient Read More
ASMARK Retailers LIVE! Tour 2016 Group shot The Andersons
CropLife 100The Andersons Rejects Unsolicited Proposal From HC2
May 19, 2016
The Andersons, Inc. has announced that its Board of Directors has rejected two non-binding, highly conditional, unsolicited proposals from HC2 Read More
glyphosate
Crop InputsWHO: Glyphosate ‘Unlikely’ To Cause Cancer
May 16, 2016
Via Reuters.com reporter Kate Kelland: The weed-killing pesticide glyphosate, made by Monsanto and widely used in agriculture and by gardeners, Read More