U.S. EPA clarifies pesticide labeling requirements

The U.S. Environmental Protection Agency has published a notice in the Federal Register announcing the availability of Pesticide Registration Notice 2012-1, titled Material Safety Data Sheets as Pesticide Labeling. This notice updates and clarifies PR Notice 92-4, titled Material Safety Data Sheets as Pesticide Labeling and is available at http://www.epa.gov/PR_Notices/.

The notice provides guidance to registrants on the relationship between EPA-approved labels for pesticides registered under the Federal Insecticide, Fungicide, and Rodenticide Act and the Material Safety Data Sheets required by the Occupational Safety and Health Administration (OSHA). Material Safety Data Sheets are also referred to as Safety Data Sheets.

OSHA requires Safety Data Sheets under its Hazard Communication Standard (HCS)(29 CFR 1910.1200) and recently published a final rule (77 Federal Register 17574-17896, March 26, 2012) to align its HCS requirements with the Globally Harmonized System of Classification and Labelling of Chemicals (GHS). The GHS is designed to provide a common and coherent approach to defining and classifying hazards and communicating hazard information on labels and safety data sheets. The system was developed based on major existing systems for industrial chemicals, pesticides, consumer chemicals and chemicals in transport, but implementation of the GHS would require some changes in all existing systems in order to achieve harmonization.

PR notice 2012-1 explains how registrants can ensure their FIFRA labeling and Safety Data Sheets comply with EPA’s requirements.

EPA recommends registrants include in their Safety Data Sheets the hazard information required on FIFRA labeling and a brief explanation for differences between that information and the Safety Data Sheet hazard information. The PR Notice includes sample language that may be used.