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.

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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.

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