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2,4-D (Dacamine, Weed-B-Gon) WPS Labeling Revisions 9/93

             UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
                     WASHINGTON, D.C. 20460
                                                     OFFICE OF
                                              PREVENTION, PESTICIDES AND
                                                   TOXIC SUBSTANCES
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 
guidance.
     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,
        and 
     -- 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.
                               Sincerely,
                               T.E. Adamczyk, Head,
                               Worker Protection Standard Implementation
                               Deviant Response Evaluation Group
                               Registration Division (H7505C)
                               Office of Pesticide Programs
Enclosure
CC: All registrants of manufacturing-use products containing
    2,4-dichlorophenoxyacetic acid or any derivative of 2,4-
    dichlorophenoxyacetic acid
                                                  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
        agreement), and
     -- 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
   eyewear."
-- 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 
labeling:
     "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 
Three-A.
_____________________________________
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 
DANGER):
     "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 
agreement:
     "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:
________________________
     Users should:
     -- 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.