UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
                     WASHINGTON, D.C.  20460

                                                OFFICE OF
                                       PREVENTION, PESTICIDES AND
                                            TOXIC SUBSTANCES

February 11, 1993                   Pesticide Regulation (PR) NOTICE 93-1

NOTICE TO MANUFACTURERS, PRODUCERS, FORMULATORS, DISTRIBUTORS,
AND REGISTRANTS OF PESTICIDE PRODUCTS

ATTENTION:     Persons Responsible for Registration of Pesticide Products

SUBJECT:       Statement of Restricted Use Classification

     This notice explains EPA's policy on the content and placement of the
statement required on the front panel of labeling of pesticides classified for
restricted use (RU).  This notice also describes EPA's policy with respect to
statements on pesticides not classified for restricted use.


I.   BACKGROUND

     EPA regulations specify the statements that must appear on pesticide
products classified for restricted use [40 CFR 156.10 (j)].  However, EPA has
observed that statements on pesticides classified for restricted use may vary
significantly in format and content.  These variations which have led to
confusion and concern generally fall into two areas:  inconsistent placement
of restricted use statements on labels and variations in the wording or meaning
of restricted use statements.

     EPA has also observed that some products not classified for restricted use
bear statements which are similar to statements required for restricted use
products.  Such statements obscure the distinction between restricted use and
unrestricted products, and they may or may not be enforceable, depending on
their wording.


I.   POLICY AND RATIONALE

     To assure consistency in product labeling and to reduce confusion, EPA is
restating and clarifying its requirements at 40 CFR 156.10 (j) for pesticides
classified for restricted use as follows:

     (a)  The statement "Restricted Use Pesticide" must be placed at the very
top of the front panel of the label of a product for which the directions for
use(s) are classified for restricted use [40 CFR 156.10 (j)(2)(i)(A)].  No other
wording or symbols should appear above this statement.

     (b)  The restricted use statement in (a) should be followed by the reason
for the restricted use classification (briefly stated).  In addition, the terms
of the restricted use, for example, the certified applicators statement as
required in 40 CFR 156.10 (j)(2)(i)(B) or other terms imposed by EPA shall
appear below the reason for the restricted use classification.  All of these
statements should be enclosed in a box as shown below.  No statements other
than these should be included in the box.

+-------------------------------------------------------------------+
|                     RESTRICTED  USE  PESTICIDE                    |
|                      DUE TO (insert reason)                       |
|   For retail sale to and use only by Certified Applicators or     |
|   persons under their direct supervision and only for those uses  |
|   covered by the Certified Applicator's certification.            |
+-------------------------------------------------------------------+
                 (For example, "DUE TO HIGH TOXICITY")

     (c)  EPA will usually require the certified applicator's statement just
descried.  However, EPA reserves the right to impose unique certified applicator
statements if necessary to prevent unreasonable adverse effects.  When 40 CFR
171 is amended, additional certified applicator statements may be required.
With respect to products not classified for restricted use, no wording or symbol
should be placed in the space at the top of the front panel above the name of
the product.  This policy will reduce the occurrence of general use products
appearing to be restricted-use products.

     (d)  Restricted-use products are still subject to all other requirements
as specified in 40 CFR 156.10 (j)(2).


III. EFFECTIVE DATE

     Registrants should make the changes specified above and submit revised
labels to EPA via notification in accordance with PR Notice 88-6 or refer to
40 CFR 152.46 (a)(1).  All products distributed or sold by registrants and
distributors (supplemental registrants) should bear labeling which is consistent
with this notice by April 21, 1994.  All products distributed or sold by persons
other than registrants or supplemental registrants after April 21, 1996 should
bear correct labeling.  After these dates, the agency may either issue a Notice
of Intent to Cancel a product or bring enforcement action against products
bearing false or misleading claims covered by this notice.  If you have
questions all Jeff Kempter (703-305-5448).

                             Lawrence E. Culleen, Acting Director
                             Registration Division

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