EPA issued a press release on April 6 stating that it has sent revised labeling instructions to registrants of pesticide products with water soluble packaging. When used properly, water soluble packaging can significantly reduce handler exposure during the mixing and loading of pesticides. Indeed, EPA has viewed the added safety features of water soluble packaging as supporting its classification as a closed mixing/loading system under the Agricultural Work Protection Standard. However, EPA believes some pesticide handlers are engaging in unintended (and improper) practices that undermine the purported safety features of water soluble packaging. Examples of improper practices include spraying the products with high-pressure water and intentionally breaking water soluble bags.

Accordingly, EPA has worked with state officials and affected pesticide registrants to develop improved label language to eliminate misuse and protect pesticide handlers. The new label language includes detailed, step-by-step instructions specifically designed to correct misuse and protect pesticide handlers from exposure. Because the Federal Insecticide, Fungicide and Rodenticide Act (FIFRA) (which governs the sale and use of pesticides in the United States) requires pesticide users to properly follow a pesticide label’s directions for use, pesticide handlers will be legally required to comply with any new label instructions for pesticide products in water soluble packaging.

Please contact me with any questions regarding FIFRA or the sale, use or handling of pesticide products.