"Not for Research Use" Labels

The PIO received feedback regarding labels which have statements similar to: “Not for use on plants being grown for sale or other commercial use, or for commercial seed production, or for research purposes.”  One commenter stated that this was a Worker Protection Standard (WPS) issue - which is true.  It stems from the labeling language of the EPA’s Label Review Manual, although in this case it is slightly modified - stating plants rather than turf - as it exists in EPA’s manual.

Most pesticides intended for agricultural use have WPS statements on the labels that exist to protect workers who may come into contact with residues.  However, specialty products such as ornamental pesticides and household pest control materials may often carry this statement to remove the product from the scope of the WPS.  A license holder would be out of compliance if they used a product with this statement on the label for research purposes. 

Another comment was that the registrant of the material that has this label language can supply the product under an experimental use permit (EUP) so it can be used in research.  This is in fact not the case because the material is not being used experimentally but rather for maintenance of the research. 

One reply contained a list of over twenty specialty products containing nearly a dozen active ingredients of which the laboratory is aware.  Consequently, the PIO is endeavoring to determine if this labeling has reduced the amount of pest control options for certain sites to the point that research cannot be reliably conducted.  Please contact Mark Mossler if you have concerns about this labeling language.