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 linked here. 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. To view the text of the letter, click here. To submit your name and get your organization on the signature list, click here to fill out the form.
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. 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.
Here is the live link from the second comment below:
Here is a link to the entire story on this project: http://epa.gov/pesticides/ppdc/distr-labeling