UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON, D.C. 20460
EPA 730-N-01-007
OFFICE OF
PREVENTION, PESTICIDES AND
TOXIC SUBSTANCES
PESTICIDE REGISTRATION (PR) NOTICE 2001-6
NOTICE TO MANUFACTURERS, PRODUCERS, FORMULATORS, AND
REGISTRANTS OF PESTICIDE PRODUCTS
ATTENTION: Persons Responsible for Registration and Reregistration of
Pesticide Products
SUBJECT: Disposal Instructions on Non-Antimicrobial Residential/Household
Use Pesticide Product Labels
This notice provides revised guidance for the development of disposal instructions for
non-antimicrobial, residential/household use pesticide product labels. EPA is now providing
instructions that direct consumers to call their local authorities for specific disposal instructions in
order to provide state and local governments greater latitude in carrying out their responsibilities
for product disposal and waste management programs.
This notice is directed to registrants of non-antimicrobial, residential/household use
products. Registrants using the revised disposal statements provided in this notice may add the
disposal statements to their labels by notification. The Agency will begin to use this guidance
upon the effective date of this PR Notice, and expects that registrants of existing products will
begin to revise their labels accordingly. It is the Agency's goal that all affected product labels
have disposal'statements according to this guidance by October 1, 2003. The statements in this
^otice are not intended for non-residential/non-household use (e.g., agricultural, commercial, or
industrial use) pesticide products where users generally have access to established recycling
and/or disposal procedures and programs.
I. BACKGROUND
A. Prior Guidance Concerning Pesticide and Container Disposal Instructions on
Pesticide Labels
In 1980, EPA excluded household wastes from regulation as hazardous waste "because
the legislative history of the Resource Conservation and Recovery Act (RCRA) indicated an
Internet Address (URL) • http://www.epa.gov
Recycled/Recyclable • Printed with Vegetable Oil Based Inks on Recycled Paper (Minimum 30% Postconsumer)
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intent to exclude such wastes, though not because they necessarily pose no hazard." (49 FR
44978, Nov 13, 1984) In 1983, the Agency required certain products to bear additional
statements such as, "Do not reuse bag. Discard bag in trash." (PR Notice 83-3). Subsequently,
the Office of Pesticide Programs directed that labels on products intended for residential or
household-use-only contain the following, or a similar, disposal instruction: "Securely wrap
original container in several layers of newspaper and discard in trash." (PR Notice 84-1) These
instructions were developed to provide registrants with language for the disposal of household
use pesticide products when the EPA excluded household waste, including household hazardous
waste, from federal regulation as hazardous waste.
B. Findings of the Consumer Labeling Initiative
In 1996, EPA began an effort known as the Consumer Labeling Initiative (CLI) to
improve the readability and consistency of pesticide product labels. One of the CLI's goals was
to improve consumer understanding of safer use, environmental, and health information on house-
hold consumer product labels, including indoor insecticides, outdoor pesticides, and household
hard surface cleaners. To achieve this goal, the CLI conducted consumer research, with its
project Partners, to identify how to provide consumers with clear information on product labels.
During Phase I of the CLI research, the Agency discovered that states and localities often
direct the disposal of residential/household use pesticides to their local household hazardous
waste (HHW) management facilities or programs rather than to landfills. This fact was verified
repeatedly in the many comments EPA received in response to its June 14, 2000, draft of this
notice. Research done by EPA, as well as information provided by commenters, showed that, in
many states, HHW management programs are based on state law that directs liquids of any kind,
as well as HHW, away from landfills. Municipal codes, local practices and educational programs,
in addition to state law, have been developed to tell consumers what to do with these materials.
C. Reason for this Notice
The differences between existing label disposal instructions and local disposal guidance
may, understandably, confuse consumers, complicate local educational efforts, and interfere with
state and local responsibilities. Prior to this notice, disposal instructions did not promote EPA's
pollution prevention and waste management goals of source reduction, reuse, and recycling.
While HHW and other household waste have been excluded from federal regulation as hazardous
waste by EPA for many years, EPA's Office of Solid Waste and EPA's Office of Water have
consistently recommended that consumers who generate HHW dispose of it through local HHW
programs and not in the regular trash. The most frequent advice directs consumers to call their
local authorities. In addition, many EPA offices have created programs encouraging the reuse and
recycling of products, as well as buying only the amount of product needed.
In the early 1980's, when EPA wrote its exclusion for household waste and when PR
Notice 83-3 was written, reuse and recycling programs were scarce for both agricultural and
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consumer products, and HHW programs were even less well established. In 1983, few states had
landfill restrictions and only 30 local HHW programs existed around the country. However, in
the almost 20 years since RCRA regulations, EPA's household waste exclusion, and PR Notices
83-3 and 84-1 were written, the disposal environment has significantly changed. States have
passed laws limiting the types of waste that can be put in their landfills, sometimes excluding all
liquids and hazardous waste, regardless of source. Programs for the; collection of agricultural
pesticides and their containers can be found nationwide. In addition, states and municipalities
across the country have created over 4,000 HHW collection events and facilities for HHW, and
that number continues to" grow. Supporting use of local collection events by revising
residential/household use pesticide product labeling has the potential to reduce, inadvertent
exposure of consumers and sanitation workers, and accidental releases to the environment
resulting from these products.
H. REVISED DISPOSAL INSTRUCTIONS. FOR NON-ANTIMICROBIAL,
RESIDENTIAL/HOUSEHOLD USE PESTICIDE PRODUCTS
A. Scope
In this notice, EPA is presenting disposal instructions for empty and partly filled non-
antimicrobial, residential/household use pesticide products.
B. Applicability
For purposes of this notice, the Agency considers a non-antimicrobial pesticide product to
be a residential/household use pesticide product, regardless of the size of the container, if either of
the following criteria are met:
1) the intended end use of the product is in or around a household or residence by a
resident; or,
2) the product is regularly available to household consumers for purchase, and of a size
and type practicable for household use, regardless of whether it is also marketed for agricultural
use.
Previously, such products were partially defined in PR Notice 84-1 as those marketed in
containers of 1 gallon or less for liquids and 5 pounds or less for dry material (except for lawn
fertilizer-herbicide products that could weigh up to 25 pounds). It is common for some products,
such as fertilizer/herbicide combinations intended for residential/household use, to be packaged in
larger sizes (economy size/bonus packs, etc.). However, the limits described by PRN 84-1 are no
longer representative of the residential/household market, and no longer apply with respect to
defining residential/household use products subject to this notice.
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C. Disposal Instructions
1. Products in Pressurized Containers
Do Not Puncture or Incinerate!
If empty: Place in trash or offer for recycling if available.
If partly filled: Call your local solid waste agency or [toll free number which meets the
criteria in paragraph HE.] for disposal instructions.
2. Products in Non-Pressurized Containers
This would include all other types of product forms (including, but not limited to
liquids; solids—tablets, dusts; gels; pet products; etc.) in all other types of product
containers (including, but not limited to bags, boxes, bottles, cans, bait stations,
squeeze tubes, etc.)
If empty: Do not reuse this container. Place in trash or offer for recycling if available.
If partly filled: Call your local solid waste agency or [toll free number which meets the
criteria in paragraph HE.] for disposal instructions. Never place unused product down
any indoor or outdoor drain.
D. Antimicrobial Products
EPA may in the future issue guidance for residential/household use antimicrobial products.
Until that happens, antimicrobial products may use the new recommended statements or continue
to use the old statements.
E. Toll-Free Phone Number
The authorities that manage household waste programs are designated in many different
ways and usually operate only during normal business hours. A toll-free number, alone or with a
web site address, can help consumers locate their local authorities conveniently, or immediately
obtain the appropriate disposal instructions for their area. The Agency's intent is that consumers
have easy access to locally accurate disposal information, when they need it. EPA considers
several toll-free information numbers, including 1-800-CLEANUP which is managed as a public-
private partnership, and the toll free numbers some individual companies often provide on their
labels, to be likely to meet these criteria. EPA does not expect registrants to create a new toll-
free number to meet this need, but to use any of the numbers that already exist, as long as they
meet the criteria listed below.
The criteria are that the number:
(1) provide 18-24 hour service to callers;
(2) be cost free to the caller;
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(3) be nationally viable; i.e., have the same phone number available in all states;
(4) provide disposal instructions that reflect the advice of the local solid waste authority
for the caller's location, or provide a direct phone number for the caller's appropriate local or
state authority, or both; and, .
(5) be reasonably assured of reliable, long-term funding to ensure the number's continued
existence at an operating level sufficient to meet caller demand.
If you need assistance in determining what toll-free number to use, please contact the
person listed in Section Vin of this notice.
F. Providing a Rationale for Proper Disposal
Registrants may want to consider providing a reason why consumers should call their local
authorities for disposal instructions. For example, "Your local government may forbid liquids and
pesticides in their landfills," or "Many local governments collect these products." Research has
shown that consumers tend to follow directions more readily when they understand why they are
being told to do something. If a reason is included, EPA's preference is for the statement to be
placed after the disposal heading and before the actual disposal instructions.
G. Recycling Statements
If registrants wish to use a different recycling statement than the one provided in this
notice, they should refer to the guidance on the Federal Trade Commission (FTC) web site.
Registrants can locate the FTC web site at •"www.ftc.gov/''-; then select 1) "Consumer
Protection"; 2) "Environment"; 3) "Guides"; and, 4) "Guides for the Use of Environmental
Marketing Claims (Green Guides)." These Guides contain FTC guidance for developing
appropriate recycling statements on various types of products and containers. Registrants are
reminded that using a different recycling statement will require the submission of an amendment.
HL WHAT CHANGES ARE BEING MADE TO THE CURRENT DISPOSAL
STATEMENTS
A. Addition of Phrase "Call your Local Solid Waste Agency"
The phrase "call your local solid waste agency" is intended to direct consumers to contact
their local government agency responsible for waste management in order to receive instructions
on how to properly dispose of the product in their area. It provides municipalities with the
opportunity to remove products from the solid waste stream by obtaining them for reuse or
recycling and to reduce the potential for accidental exposures to sanitation workers, materials
recovery facility workers, landfill workers, and the environment.
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B. Removal of Phrase "Wrap in Paper"
Consumers were previously instructed to securely wrap containers in paper to reduce
potential exposures to sanitation workers. However, wrapping containers prior to disposal in the
trash does not appear to provide reliable protection to sanitation workers and may result in
accidental or unknown exposures. Consequently, we expect this instruction to be deleted from
the disposal statements.
C. Deletion of Rinse Instructions
Specific instructions to consumers to rinse their empty containers have been left out of
these revised instructions. Experience has shown that many consumers are confused by rinsing
procedures and often incorrectly dispose of the rinse water down the drain or down sewers.
States have reported some detections of pesticides in drinking water that appear, in some cases, to
be linked to disposal or rinsing in residential waste water systems. In addition, storage of rinsate
is highly discouraged because of the absence of adequate labeling or packaging. There is also the
potential risk of adverse chemical reactions occurring when products are poured down drains,
singly, or in combination with other products.
IV. WHAT REGISTRANTS AND APPLICANTS SHOULD DO
EPA generally expects registrants and applicants for registration to use the standard label
statements in Section II of this PR notice. It is the registrant's responsibility to ensure that each
product label bears EPA-approved text in its disposal instructions. If a registrant believes that an
alternate text is more appropriate, the company should submit an amendment to the Agency with
the proposed text. If the amendment is approved, the company may then use the alternate text.
In order for registrants to remain in compliance with FIFRA and its implementing
regulations, registrants and supplemental distributors must ensure their products, labeling, and
packaging distributed in association with the sale or distribution of the pesticide product comply
wifhFIFRA Sections 12(a)(l)(e) and 40 CFR 156.10(i)(l)(ix). Registrants are reminded that
they are responsible for informing their supplemental distributors when they change their labeling,
and for monitoring the labeling of their supplemental distributors to assure that they make the
necessary changes.
As of the effective date of this notice, EPA will review all applications for new pesticide
product registrations, amendments to registered products, and reregistration of registered pro-
ducts using this guidance. As of October 1, 2003, the Agency will monitor registered products
using this guidance to determine whether their labeling is consistent with 40 CFR 156.10(a)(5),
40 CFR 156.10(b)(2) and FIFRA. Residential/Household use pesticide products, with the
exception of antimicrobial products, which are released for shipment by registrants on or after that
date and which have inappropriate disposal statements may be considered in violation of FIFRA.
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To give sufficient time for pesticide products in the channels of trade to be distributed or
sold to users or otherwise disposed of, the Agency is providing a period of time for companies to
make changes to their labeling, if necessary. Therefore, pesticide products released for shipment
prior to October 1, 2003 will be considered existing stocks in the channels of trade which may be
sold, used or otherwise disposed of until exhausted.
Registrants who wish to modify their product labels to ensure compliance with FIFRA
should submit revised labeling through the applicable steps described below:
A. To Revise Disposal Instructions According to this Guidance
Registrants who adopt the exact wording set forth in this notice should submit a
notification (according to PR Notice 98-10) for each product. EPA may review the notification
to assure that the wording is identical to that contained in this notice. The registrant should
submit one copy of the label (with changes clearly marked in a way that can be photocopied)
along with a completed Application for Registration form (EPA Form 8570-1). A photocopy of
the EPA application form is acceptable. The application form must bear the following statements:
"Notification of label change relative to PR Notice 2001-6. This notification is consistent
with the guidance in PR Notice 2001-6 and the requirements of EPA's regulations at 40 CFR
156.10 and 40 CFR 152.46, and no other changes have been made to the labeling or the confiden-
tial statement of formula of this product. I understand that it is a violation of 18 U.S.C. Sec. 1001
to willfully make any false statement to EPA. I further understand that if this notification is not
consistent with the guidance of PR Notice 2001-6 and the requirements of 40 CFR 156.10 and 40
CFR 152.46, this product may be in violation of FIFRA and I may be subject to enforcement
action and penalties under sections 12 and 14 of FIFRA."
B. To Propose Alternate Disposal Instructions
Registrants and applicants may propose alternatives to the specific disposal language
described in this notice. To do so, the registrant should submit an amendment consisting of a
completed Application for Registration form (EPA Form 8570-1) and three (3) copies of the
revised labeling. EPA will review the amendment application and determine whether the
proposed instructions are acceptable.
V. ADDRESSES
Registrants should send notifications and amendments to one of the following addresses.
U.S. Postal Service Deliveries
The following official mailing address should be used for all correspondence or
data submissions sent to OPP by mail:
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Document Processing Desk (AMEND) or (NOTEF) [as applicable]
Office of Pesticide Programs (7504-C)
U.S. Environmental Protection Agency
Ariel Rios Building
1200 Pennsylvania Ave., NW
Washington, D.C. 20460-0001
Personal/Courier Service Deliveries
The following address should be used for all correspondence or data submissions
that are hand-carried or sent by courier service Monday through Friday, from
8:00 AM to 4:30 PM, excluding Federal holidays:
Document Processing Desk (AMEND) or (NOTIF) [as applicable]
Office of Pesticide Programs (7504-C)
U.S. Environmental Protection Agency
Room 266A, Crystal Mall 2
1921 Jefferson Davis Highway
Arlington, Virginia 22202
VL EFFECT ON PREVIOUSLY ISSUED PR NOTICES
Several previously issued PR notices contain disposal statements for residential pesticides,
recycling statements with disposal statements, or, like PR Notice 98-10 make references to earlier
disposal statements for other reasons. For non-antimicrobial, residential/household use products,
the statements in this notice should supersede any use or reference to the older disposal
statements in previously published PR notices. For example:
- PR'Notice 83-3, disposal instructions for household products shown in paragraph B.3.
and the container disposal instructions for household products shown in paragraph C. 1. are
superseded.
- The disposal statements in PR Notice 84-1 are superseded entirely for non-antimicrobial
products.
VH. SCOPE OF POLICY
This PR Notice describes the Agency's approach* to implementing the requirements set
forth in Agency regulations and FIFRA, and provides general guidance to EPA and to affected
parties as well. While the requirements in FIFRA and Agency regulations are binding on EPA and
applicants, this notice is intended to provide guidance to EPA personnel, pesticide registrants and
applicants, and the public. As a guidance document, this policy is not binding on either EPA or
any outside parties, and the EPA may depart from the guidance where circumstances warrant and
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without prior notice. Registrants and applicants may propose alternatives to the approach
described in this notice, and the Agency will assess them for appropriateness on a case-by-case
basis and will respond in writing, if requested. If a product does not meet the requirements of 40
CFR Part 156 arid section 2(q) of FIFRA, the Agency may find the product to be misbranded and
may take appropriate enforcement and/or regulatory action. As stated above, the Agency believes
that the guidance described in this notice should enhance the proper disposal of pesticide products
and reduce potential risks to human health and the environment.
VDI. FOR FURTHER INFORMATION
If you wish further information on this notice, you may contact Amy Breedlove, Field and
External Affairs Division, Policy and Regulatory Services Branch, at 703-308-9069, or by e-mail
to breedlove.amy@epa.gov.
Marcia E. Mulkey, Director /
Office of Pesticide Programs L
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