2,4-D (Dacamine, Weed-B-Gon) WPS Labeling Revisions 9/93
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON, D.C. 20460
PREVENTION, PESTICIDES AND
BY CERTIFIED MAIL: RETURN RECEIPT REQUESTED
September 14, 1993
SUBJECT: Additional Guidance about Worker Protection Standard
Labeling Revisions to 2,4-D Labels
Registrants of 2,4-D end-use products have made several inquiries
about the relationship between:
-- PR Notice 93-7 (issued April, 1993) that contains instructions
for revising labels to comply with the Worker Protection
Standard for Agricultural Pesticides (WPS), and
-- the letters (issued October 30, 1992 and January 14, 1993) to
2,4-D registrants with instructions for revising 2,4-D labels to
comply with the 1992 agreement on exposure reduction measures
for 2,4-D Labels.
EPA is issuing the enclosed additional guidance to registrants of 2,4-D
products about revisions that must be made to the labels of end-use
products containing 2,4-dichlorophenoxyacetic acid or any derivative of
2,4-dichlorophenoxyacetic acid (collectively referred to as "2,4-D" in
the remainder of this letter) in order to comply with both PR Notice-93-
7 and the 2,4-D agreement. If, after following the instructions in this
additional guidance and in Supplement Three of PR Notice 93-7, you have
questions or concerns about the required labeling revision for a 2,4-D
end-use product, call the WPS Label Information Line (1-800-777-2185)
for further assistance.
NOTE: The enclosed guidance does NOT apply to those 2,4-D products that
are outside the scope of the Worker Protection Standard, e.g. products
primarily intended for home use, and products with uses only on noncrop
areas, such as pastures and rangeland, rights-of-way, and industrial
sites). Such products must, however, comply with the 2,4-D agreement.
The deadlines for completing these labeling revisions that are
established by the 2,4-D agreement and by PR Notices 93-7 and 93-11
remain in effect. In addition, any requests to amend your product
labeling in accordance with PR Notice 93-7 submitted after receipt of
this additional guidance, must comply with the instructions in this
However, if you have already self-verified (in accordance with
instructions in PR Notice 93-11) and printed revised 2,4-D labeling that
complies with the 2,4-D agreement and PR Notice 93-7, and that newly
printed labeling contains personal protective equipment requirements,
engineering control statements, or user safety statements that differ
from the statements this additional guidance would require, you:
-- may sell or distribute the product with those revised labels,
-- must submit to EPA in accordance with the instructions in PR
Notices 93-7 and 93-11, a request to amend your product labeling
in accordance with this additional guidance, and
-- must revise your end-use product labeling to comply with this
additional guidance at the next label printing
Registrants who, at time of receipt of this additional guidance,
have already submitted to EPA an acceptable WPS reflecting this
additional guidance) generally will receive from EPA their 2,4-D
labeling stamped "accepted with comments." The comments will indicate
that, by the next printing, the labeling must be further revised in
accordance with this additional guidance.
T.E. Adamczyk, Head,
Worker Protection Standard Implementation
Deviant Response Evaluation Group
Registration Division (H7505C)
Office of Pesticide Programs
CC: All registrants of manufacturing-use products containing
2,4-dichlorophenoxyacetic acid or any derivative of 2,4-
WPS GUIDANCE FOR 2,4-D
ADDITIONAL WPS GUIDANCE FOR REGISTRANTS OF 2, 4-D
This guidance is for registrants of end-use products that:
-- contain 2,4-dichlorophenoxyacetic acid or any derivative of 2,4-
dichlorophenoxyacetic acid (collectively referred to as "2,4-D"
in the remainder of this guidance) and are, therefore, amending
the end-use product labeling to comply with the 1992 agreement
on exposure reduction measures for 2,4-D labels (2,4-D
-- are within the scope of PR Notice 93-7 and are, therefore,
amending the end-use product labeling to comply with PR Notices
93-7 and 93-11.
PERSONAL PROTECTIVE EQUIPMENT STATEMENTS
Use the instructions in PR Notice 93-7, Supplement Three, "Main Labeling
Guidance," to determine the appropriate personal protective equipment
(PPE) for your product, EXCEPT each 2,4-D product must contain a
requirement for "protective eyewear." The PPE statements must be located
under the subheading "Personal Protective Equipment:" in the
Precautionary Statements section of the revised labeling as directed in
PR Notice 93-7 Supplement Three and as shown on the "Product Worksheet"
in Supplement Three-A.
Changes from 2,4-D agreement language:
-- Do not use "eye protection (face shield or safety glasses)" as
required by the 2,4-D agreement. Use the phrase "protective
-- Do not use "When mixing, loading, or applying this product or
repairing or cleaning equipment used with this product, as required
by the 2,4-D agreement. Use the phrase required in PR Notice 93-7,
Supplement Three. Usually the correct phrase will be "Applicators
and other handlers must wear."
-- Do not use "chemical-resistant gloves" as required by the 2,4-D
agreement. Follow the instructions in PR Notice 93-7, Supplement
Three which will guide you in selecting either "chemical-resistant
gloves, such as ____________, _________, or ___________" and the
appropriate chemical-resistance category letter (B, C, D, E, F, G, or
H) or "waterproof gloves."
-- Do not use "long sleeved shirt, long pants, socks, and shoes" as
required by the 2,4-D agreement, unless you are directed to by the
instructions in PR Notice 93-7, Supplement Three. For example, most
end-use products that are toxicity category II for acute dermal
toxicity or skin irritation potential will be directed to use
"coveralls over short-sleeved shirt and short pants, chemical-
resistant footwear plus socks, chemical-resistant headgear for
overhead exposure, and chemical-resistant apron when cleaning
equipment, mixing, or loading."
-- If your end-use product contains both uses within the scope of PR
Notice 93-7 AND uses not within the scope of PR Notice 93-7, you have
the option (described in Supplement Three of that notice) of
splitting the personal protective equipment requirements into WPS PPE
requirements and nonWPS PPE requirements. If you choose this option,
the nonWPS PPE requirements on your revised labeling must be the PPE
language required by the 2,4-D agreement for that nonWPS use.
ADDITIONAL PPE STATEMENT FOR 1-5 GALLON CONTAINERS
If the end-use product is packaged in a container that is greater than 1
gallon, but less than 5 gallons, capacity AND the PPE statements
established through the instructions in PR Notice 93-7 do not require
mixers and loaders to wear a chemical-resistant apron AND do not require
"applicators and other handlers" to wear coveralls, add the following
statement directly below the other PPE requirements:
"Mixers and loaders who do not use a closed mechanical system
(probe and pump) to transfer the contents of this container must
wear coveralls or a chemical-resistance apron in addition to the
other required PPE."
MECHANICAL TRANSFER FOR CONTAINERS OF 5 OR MORE GALLONS
If the end-use product is packaged in a container that is 5 gallons or
more in capacity, the following statements must be placed on the product
"A closed mechanical system (probe and pump) must be used for
transferring the contents of this container. If the contents of a
non-refillable pesticide container are emptied, the probe must be
rinsed before removal. The mechanical system must be used in a
manner that meets the requirements listed in the Worker Protection
Standard (WPS) for agricultural pesticides [40 CFR 170.240(d)(4)].
The handler PPE requirements may be reduced or modified as
specified in the WPS."
These statements about mechanical transfer must be located under the
subheading "Engineering controls statements:" in the Precautionary
Statements section of the revised labeling as directed in PR Notice 93-7
Supplement Three and as shown on the "Product Worksheet" in Supplement
OTHER ENGINEERING CONTROLS STATEMENTS
Do not add the statement "For aerial applicators in enclosed cockpits
and applicators applying this product from a tractor that has a
completely enclosed cab, eye protection is not required" as required by
the 2,4-D agreement. Instead add the following statement:
"When handlers use closed systems, enclosed cabs, or aircraft in a
manner that meets the requirements listed in the Worker Protection
Standard (WPS) for agricultural pesticides [40 CFR 170.240 (d)(4-
6)], the handler PPE requirements may be reduced or modified as
specified in the WPS."
The statement must be located under the subheading "Engineering controls
statements:" in the Precautionary Statements section of the revised
labeling as directed in PR Notice 93-7 Supplement Three and as shown on
the "Product Worksheet" in Supplement Three-A. If the statements
requiring the use of a mechanical transfer system are also to be added
to the labeling:
-- add this statement in a separate paragraph immediately below the
statements requiring the mechanical transfer system, and
-- delete the phrase "closed systems," in this statement.
USER SAFETY REQUIREMENTS
Add the appropriate user safety requirements to each 2,4-D label. These
statements must be located in the Precautionary Statements section of
the revised labeling as directed in PR Notice 93-7 Supplement Three and
as shown on the "Product Worksheet" in Supplement Three-A.
1. Follow the directions in PR Notice 93-7, Supplement Three for whether
to add the following statements (these statements are required if the
end-use product is a concentrate and bears the signal word WARNING or
"Discard clothing and other absorbent materials that have been
drenched or heavily contaminated with this product's concentrate.
Do not reuse them."
2. All 2,4-D labels must add the following statements:
"Follow manufacturer's instructions for cleaning/maintaining PPE.
If no such instructions for washables, use detergent and hot water.
Keep and wash PPE separately from other laundry. After each day of
use, clothing or PPE must not be reused until it has been cleaned."
3. Do NOT add the following statements that were required by the 2,4-D
"Wash hands, face and arms with soap and water as soon as possible
after mixing, loading, or applying this product. Wash hands, face
and arms with soap and water before eating, smoking, or drinking.
Wash hands and arms before using toilet. After work, remove all
clothing and shower using soap and water. Do not reuse clothing
worn during the previous day's mixing and loading or application of
this product without cleaning first. Clothing must be kept and
washed separately from other household laundry. Remove
saturated clothing as soon as possible and shower."
USER SAFETY RECOMMENDATIONS
Create a new labeling box on each 2,4-D label called "User Safety
Recommendations." Place it in the section titled "Precautionary
Statements -- Hazards to Humans & Domestic Animals" below the subsection
titled "Engineering Control Statements" -- as shown on the "Product
Worksheet" in Supplement Three-A of PR Notice 93-7. The User Safety
Recommendations must be located in a clearly separate box -- with lines
or other graphic indicators to separate them from the surrounding text.
Put the following statements in the box:
User Safety Recommendations:
-- Wash hands before eating, drinking, chewing gum, using tobacco,
or using the toilet.
-- Remove clothing immediately if pesticide gets inside. Then wash
thoroughly and put on clean clothing.
-- Remove PPE immediately after handling this product. Wash the
outside of gloves before removing. As soon as possible, wash
thoroughly and change into clean clothing.
ENTRY RESTRICTIONS AND OTHER WPS STATEMENTS
1. Supplement Three-of PR Notice 93-7 contains instructions for adding
restricted-entry statements and other WPS-required statements to labels
of products within the scope of PR Notice 93-7. It also contains
instructions for removing statements from the current labeling that
conflict with the WPS statement. For adding WPS-related statements and
removing WPS-conflicting statements on your 2,4-D label other than those
statements dealt with in this guidance, follow the instructions in
Supplement Three of PR Notice 93-7.
2. The 2,4-D agreement covers certain labeling requirements, such as
statements dealing with maximum application rates, that are not covered
by the WPS but must be incorporated into 2,4-D labels. Follow the
instructions in the 2,4-D agreement for incorporating onto the 2,4-D
label the agreement-related statements not covered by this guidance.