of the
   First National Symposium
Pesticide  Labeling
  Part I: Presentations
    June 3-4, 1974




            JUNE 3-4, 1974
            Program Leader
            James J. Bonin
          Presidential Fellow
     Office of Pesticide Programs
U. S. Environmental Protection Agency
          Washington, D. C.
         Program Development
          John B. Ritch, Jr.
    Director, Registration Division
     Office of Pesticide Programs
U. S. Environmental Protection Agency
          Washington, D. C.




    John B. Ritch, Jr	    iv

Introductory Remarks

    John B. Ritch, Jr., Director, Registration
    Division, Office of Pesticide Programs, EPA	     1

    Henry J. Korp, Deputy Assistant Administrator
    for Pes ti ci de Programs, EPA	     2

    James L. Agee, Assistant Administrator
    for Water and Hazardous Materials, EPA	     3

    James J. Bonin, Presidential  Fellow,
    Office of Pesticide Programs, EPA	     4


Pesticide Labeling-A Regulatory Perspective

    Douglas D.  Campt, Pesticide Registration Officer
    Registration Division, Office of Pesticide Programs, EPA...     6

Labeling Requirements-Enforcement

    A. E. Conroy  II, Director, Pesticides Enforcement
    Division, EPA	    12

Labeling Requirements-Functional

    James E. Dewey, Program Leader, Chemicals & Pesticide
    Programs, New York State College of Agriculture,
    Cornell University	    17

Regulatory Requirements-State

    Delvan W. Dean, Pesticide Regulations  Specialist,
    Department  of Agricultural  Chemicals & Feed, State
    of California	    20

Labeling Problems-Federal
    William A. Wells, Chief, Standards and Labeling
    Section, Registration Division, Office of Pesticide
    Programs, EPA	    28
Labeling Problems-State
    William B. Buffaloe, Chief Pesticide Officer,
    Pest Control Division, North Carolina Department
    of Agri cul ture	    33
Labeling Problems-Private Industry
    Channing E. Jones, National Sales Manager,
    Garden and Home Products Division, Ortho
    Division, Chevron Chemical Company	    39
Labeling Problems-User Group
    Richard E. Flowers, Co-Owner, Flowers &
    Parker Farm, Tunica, Mississippi	,	    44
Labeling Problems-Environmental View
    James P. Rod, Assistant to the President
    National Audubon Society	    51
Label ing-Marketing Communication View
    Alvin S. Schechter, President,
    Schecter & Luth, Inc., New York	    61
Improving Label Communications
    Rudy N. Salcedo, Environmental Scientist,
    Department of City Planning, City of Milwaukee	    68
Improving Label Reading Via Motivation
    James F. Evans, Head, Teaching and Research
    Projects, Department of Agricultural Communications,
    University of Illinois	    75

      It was our  intent in holding the first National Symposium on
 Pesticide Labeling to bring together as many parties as possible
 concerned with pesticide labeling and to stimulate their thinking
 on  this subject.  We recognized before the meeting that we would not
 evolve from the  meeting all the answers to develop a new framework
 for labels and the labeling process.  We did feel, however, that such
 a gathering would provide some constructive suggestions upon which we
 could begin building basic guidelines for future labels and labeling.

      We believe  the Symposium was highly successful in accomplishing
 this  objective.  The manuscript herein contains a record of the pre-
 pared statements and much of the discussion of the two-day session.
 Within this record are a number of worthwhile recommendations which
 are now under consideration for adoption as policy or guidelines.
 The new Standards and Labeling Section of the Registration Division
 is  hard at work  evaluating these.  Some of them are controversial
 and worthy of further comment and discussion.  The Standards and
 Labeling Section will welcome any additional comments that your
 review of this document might stimulate.

      This document is divided into two parts:  (1)  the prepared
 presentations offered at the sessions (taken from the Recorder's
 transcript and not from the speakers' notes);  (2)  a portion of
 the questions and answers raised at the meeting.  A number of
 additional questions were asked or submitted at the meeting and
 answers will be  somewhat dependent upon publication of forthcoming
 Regulations and  Registration Guidelines.  Therefore, the answers have
 been  delayed.  In order to reduce any more delay in submitting this
 document we are  sending it without these answers.  An addendum to
 this  document, or Part III, will be published in early 1975 to cover
 the remaining questions.

      It is our hope that those who attended this meeting benefited
 as  we did.  We shall look forward to another Symposium when we have
 had a chance to more completely digest the results of this one.
                               „,,-  ..
                               i   \                            f  I
September 27, 1974             \^ jJohn B. Ritch, Jr.          (I

Featured Addresses

    The Honorable Mark Andrews,  Member of
    Congress, Ranking Member Of  The House
    Subcommittee for Agriculture-Environmental
    and Consumer Protection	   80

    The Honorable Russell  E.  Train, Administrator,
    U.  S. Environmental  Protection  Agency	   89


                        JOHN B.  RITCH,  JR.
                 Director, Registration Division
                  Office of Pesticide Programs
                 Environmental  Protection Agency
     Good morning.   I am John Ritch,  Director  of  the  Registration
Division of the Office of Pesticide Programs,  under the  Office  of
Water and Hazardous Materials in the  Environmental  Protection Agency.
Now that is a label.

     On behalf of the entire Office of Pesticide  Programs,  and  more
particularly on behalf of the Registration  Division,  which  is sponsoring
this Symposium, I formally welcome you to the  First National Symposium
on Pesticide Labeling.

     We appreciate very much your being here.   It is  clear  evidence
to us of your desire to work with the Registration  Division to  improve
pesticide labeling when we see the tremendous  response to such  a
meeting.  As evidence of our own intense interest in  this subject,
we have established a Labeling Section in the  Registration  Division
under Dr. William Wells, who will speak to  you this afternoon.  As
further evidence of our interest, it  is of  course the Registration
Division which is sponsoring this Symposium, and  which has  been working
on it for some time.   A great deal of thought  has gone into the develop-
ment of these meetings.  Yet, in spite of the  great amount  of time and
effort expended in developing this Symposium,  I want  to  inform  you
right now that it is not going to provide us with all  the answers
necessary in order to step out with a new framework for  labels.

     On the other hand, I hope that it is a beginning—a stimulant to
both your and our thinking—so that we may  lay out  a  framework  to
improve the labeling process.  By the time  you leave  here tomorrow
afternoon, I hope you will feel you have been  warned, directed,
certified, classified, packaged, numbered,  motivated, crushed,  incin-
erated, and fully labeled.  We are going to examine the  problem from
the points of view of all involved groups—the Federal Government,
the States, the users, the environmentalists,  and the manufacturers.
If things go the way I think they will, we  may have a fight or  two.
Some of our issues, I think, are so tough that the  old Hatfield-McCoy
feud will seem like a bunch of teddy bears  going  to a picnic.

     This is why we are here.  We hope that these issues will be
freely explored.  We also hope that when you  leave you will continue
your interest and give us your thoughts and ideas for better labeling.
I think this get-together is the initial move  in  the  right  direction.
So let's keep it moving.  The follow-up actions we can pursue will
depend upon this Symposium.

                              HENRY J. KORP
                     Deputy Assistant Administrator
                         for Pesticide Programs
                     Environmental Protection Agency

     I am very pleased to see so many of you here in response to this
call for a labeling symposium.  This initial effort of ours is most
significant in terms of timing, since we are presently in the midst of
developing the regulations that will have more than a passing effect
on the pesticide label for years to come.

     It is because of this fact that I would like to thank all those
who are participating in the Symposium, and particularly impress upon
you as the audience the need to make these two days meaningful ones--
days that will produce results that are considered constructive, as
opposed to destructive.

     Our purpose, after all, is to bring about the improvement of the
label, not its demise.  We would appreciate ideas that will make the
label easier to read and to be understandable to all.  Some might
think that this means an operation by which we would process labels
on  a single day service, or something like that.  This, of course,
is  not the case.  This Symposium is just one step further down the
road to making the regulatory process more efficient, more responsive,
and more understandable.  Any actions we take, however, will always
be  framed with the protection of the environment in mind.

      I didn't intend to make a speech here today, and I won't.  My
purpose is to introduce to you a gentleman that you will all certainly
get to know very well in the near future.  Mr. James L. Agee has
recently been selected Acting Assistant Administrator for Water and
Hazardous Materials, the new title that John Ritch read to you.

      Pesticides, and the Office of Pesticide Programs, come under his
jurisdiction.  Jim Agee was, until accepting this new assignment, the
Regional Administrator for the Environmental Protection Agency's
Region 10, which has Seattle, Washington as its headquarters.  Much of
Jim's background is in water, having served with the Department of
the Interior's  Federal Water Quality Administration.  Jim is no
stranger to pesticide problems, however, since you will remember that
it  was in his Region that we had a few DDT decisions.  I am sure that
Jim doesn't plan to make a speech either, but I would like to prevail
upon  him to say a few words.

                              JAMES L.  AGEE
               Acting Assistant Administrator for Water
                        and Hazardous Materials
     Thank you very much, Henry.   I do want to welcome you all  here.
I know very well  the importance of today's session.

     This is an important session for us and we are  really here to
solicit your advice.  You know, EPA has been faced in the last  couple
of years with promulgating one regulation after another.   People keep
asking us "How do you do all  that?"  Well, the answer is  simple.  We
have a standard outline for regulations that comes out in numbers of
Deuteronomy.  It is called the Ten Commandments.   We go down those
and write everything we can think of that ought to go into the
regulations.  We are very concerned, and I know that Russ Train is
very, very concerned about us doing things right.

     The job we have to do is mammoth in all  EPA areas.   We are
naturally interested in getting our regulations adopted and in  their
being as practical and as reasonable as possible.   Yet at the same
time, we have to be very serious  about their content.   We want  our
regulations to be enforceable; they have to be enforceable.   We want
them, also, to be just and fair.   We have to work  with these regulations,

     Finally, I would like to thank all of you for coming.   We  are
here to listen and to get your ideas about labeling, so that we can
do the best possible job.  You have opened up the  dialogue today. As
a matter of fact, I think that the pesticide users,  the State people,
the environmentalists—all of these-are the people we are serious
about working with as we develop the labeling program, and as we
carry it out in the future.

     Thank you again for coming.

                           JAMES J. BONIN
                         Presidential Fellow
                    Office of Pesticide Programs
                   Environmental Protection Agency

     Good morning.  I certainly appreciate the kind words of John Ritch
concerning my role in putting together this particular Symposium.  It
has been a pleasure working with John and the other people in the Office
of Pesticide Programs over the past months.

     Our "ground rules" are few in number.  It is imperative that we
move along as rapidly as possible, since, as you can see from the program,
we have quite a few speakers to listen to over the next two days.  The
real nuts and bolts of the sessions, however, will come during the
question and answer periods.  Keeping that in mind, we should all strive
to move the formal part of the program along as rapidly as possible.

     The major ground rule that must be followed is that we cannot take
the time to answer a multiplicity of questions during the actual,
formal presentations.  For this reason, I suggest you jot down any
questions you have now, plus all those that you think of during the
various talks, and put those questions on the index cards you will find
inside of each registration packet.  In this way you will not have to
interrupt the individual speakers, but will still be able to get an
input immediately.  If we follow this procedure, I am sure that we will
have a more productive Symposium.

     As I said, there is no need for you to hold on to your questions
all day.  Mr. Jerry Moore, of the Registration Division, will circulate
among you and pick up the cards.  In doing so, we can get a headstart
on  sorting the questions out by category.

     One other thing that I would like to point out is that in each
registration packet there is a yellow card that admits one to the
luncheon tomorrow.  As you are aware, we are fortunate to have the
Honorable Russell Train as a speaker at that function.  Anyone who has
registered, but will not attend the luncheon, should turn their yellow
card  in at the registration desk.  The purpose of doing this is to
allow the contractor to estimate the total attendance for the luncheon
This makes it easier for the hotel to set up the tables.

     Without further delay or remarks, I would like to introduce our
first speaker of  the day, a gentleman who has had a long history in
regulations, Mr.  Douglas D. Campt.  Doug is a graduate of East Carolina
University.  He first began his federal career as an inspector at JFK
International Airport in New York, progressed through the ranks and
finally became a  member of the  Pesticide Regulations Division of the

Department of Agriculture.  He has held several positions in the latter
Division, up to and including Acting Deputy Director.  When the
Environmental Protection Agency was formed in 1970, Doug came over
with many other people from the old PRO.  Doug has held several
different positions in the Registration Division, the most current
being the Chief Registration Officer.  His remarks this morning will
deal with the regulatory requirements for labels from the Federal
view.....Doug Campt.



                              By Douglas D.  Campt
                      Pesticide Registration Officer

     Archimedes the great Greek geometrician is quoted as having said,
"Give me a lever long enough and a prop strong enough and I will move
the world."  I recall that this quotation appeared in my seventh grade
geometry text book and at the time I remember turning over in my own
mind the question of whether Archimedes had  in fact concluded that the
world needed to be moved.  We could paraphrase this quotation and apply
it to the pesticide labeling problem.  We might say, "Give me a label
long enough with warnings, cautions and statements of limitations
strong enough and I will assure you that any use of pesticides will be
illegal."  I would, of course, raise the same type of question there as
occurred to me in connection with the Archimedes quotation.  I can in
this case positively tell you that this is not the intent of pesticide
labeling. The purpose of pesticide labeling  is quite simply to aid in
allowing the use of a pesticide product safely and effectively without
unreasonable adverse effect on the environment.

     As a matter of fact, there is a considerable body of opinion that
holds that the pesticide label is becoming too crowded, too complex,
and  too detailed.  The proponents of this theory would simplify labeling
and  hold statements to the bare minimum with the intent of strictly
enforcing  that which would be there.  This idea is based on the theory
that we have reached a point of diminishing  returns on additional "words"
on  the  label.  We will need to give serious  consideration to this thinking
as  we plan to address the labeling problem in the future.

      It is my purpose this morning to discuss with you, Labeling Require-
ments from a Regulatory  Perspective.  In other words, what does the law
require with respect to  labeling for pesticide products?  Perhaps it
might be useful  first to review the statutory tools with which we work
and to  provide  some  background on how we got where we are today.  As we
are aware, we are  in the process of implementing the amendments to the
Federal Insecticide, Fungicide, and Rodenticide Act of 1947 which were
brought about  by the passage of the Federal  Environemntal Pesticide Control
Act of  1972.  The  1947  law was considered to be basically a labeling
statute.   The  regulatory scheme was geared largely to assuring that pesti-
cides were properly  labeled  in the pre-marketing clearance program
 (Registration)  and enforcement of that labeling through a market surveillance
program  (Enforcement).   The  1970 amendments added a number of important tools
to  be used  in  the  regulation of pesticides,  including classification  use of
certified  applicators,  registration of establishments, and others   However
the statutory  requirements relative to labeling have remained essentially  '
the same.  There have been a few new wrinkles and I will highlight these as
we  proceed.  Since we are in a transitory period in moving into the

requirements, we will  be making reference both to the new and to the
existing requirements.

    Now what does the  law require with respect to labeling?  First,  the
law makes a distinction between the terms, "Label" and "Labeling."   Since
these terms are sometimes erroneously used interchangeably, let us
establish the differences between them and hereafter use them in their
proper context:

    1.  LABEL - The term 'label'  means the written, printed,  or
        graphic matter on, or attached to, the pesticide or device
        of any of its  containers or wrappers.

    2.  LABELING - The term 'labeling' means all  labels and all
        other written,  printed, or graphic matter:

        a.  Accompanying the pesticide or device  at any time; or.

        b.  To which reference is made on the label or in litera-
            ture accompanying the pesticide or dev^ice, except to
            current official publications of the  Environmental
            Protection  Agency, the United States  Departments  of
            Agriculture and Interior, the Department of Health,
            Education,  and Welfare, State experiment stations,
            State agricultural colleges,  and other similar
            Federal or State institutions or agencies authorized
            by law to  conduct research in the field of pesticides.

    It is clear that the basic distinction concerns where the written,
printed or graphic matter occurs.  In the case of the "label" it is
''on or attached to the pesticide or device."  In  the case of "labeling"
it may accompany the pesticide or device  or be referred to on the label
or literature accompanying the pesticide  or device.

    The basic labeling requirements are found in  Section 2(q) of the
statute.  This is the  section of the law  which contains definitions  of
terms used in the law.   Section 2(q) specifically defines the term
"Misbranded"  This definition of misbranding identifies a number of
specific items that must be present on a  label to preclude the pesticide
from being misbranded.

    Let us take a moment to review these  required labeling statements:

    Slide I - This is  a skeletal  representation of a label showing
    the basic requirements.  As I stated  previously, we are dealing
    with the 1947 statute and interpretative regulations in addition
    to some new requirements under the 1972 amendment to the 1947
    statute.  The two  items with asterisks are new requirements.
    The present regulations require that  a signal word, such as

     "Caution", "Warning", or "Danger" along with the statement  "Keep
     Out of Reach of Children appear on the front panel of all  pesti-
     cide products.

     These regulations contain specific requirements relating to the
legibility of the required statements.  With respect to the signal word
and the statement,  'Keep Out of Reach of Children1, the type size must
bear a reasonable relationship to the other type on the front  panel.  In
this regard, the signal word must be at least 18 point type and the
statement, "Keep Out of Reach of Children", must be at least 12 point
type.  In cases where the label space is too small, permission is granted
for reduction in type size but in no event smaller than 6 point.

     And now let us dissect this label and discuss specifically the  items
listed on the skeletal label I just showed you:

     Slide II - Name, Brand Name or Trade Mark

     Must not make  false representation

     Must not give  misleading impression as to content

     Slide III - Directions For Use

     Must be adequate to effect intended purpose of product.

     Directions + classification and other restrictions = protection of
     public  health  and environment.

     Slide IV - Warning or Caution Statements

     Must be adequate, if followed, to protect public health and environment
     Pesticides highly toxic to man must bear the skull and cross bones,
     poison  in red  on contrasting background.

     Statement of practical first aid treatment

     Slide V - Ingredient Statement

     Must be on immediate container

     Name and percentage of each active ingredient required

     Arsenic containing pesticides must show percentage of total  and H20
     soluble, arsenic calculated or elemental  arsenic.

     Slide VI - EPA Registration Number

     Must not appear so as to mislead.  Type size consistent with  other
     print.  Parallel to other print.


     Slide VII - Establishment Registration

     Must bear number assigned to  establishment  in  which  pesticide   was

     Slide VIII - Net Weight or Measure of Contents

     Must be accurate as to quantity of contents

     No variations below claimed quantity allowed

     No unreasonable variations above claimed  quantity allowed

     Slide IX - Name and Address of Producer,  Registrant  or  Person  for
                Whom Produced

     Must be that of the manufacturer or qualified  to  show that  name is
     not manufacturer.

     1.  Distributed by...

     2.  Packed for...

     3.  Sold by...

     The Agency's Hearing Examiner rendered  an opinion relative  to  the
purpose and intended direction of labeling in  the Continental Chemists
Case which involved  a canellation  action on  a  lindane  vaporizer  product.
The Examiner stated  and I quote:

            "The labeling of an economic poison  deals  with the
            means by which communication is  established between
            the registrant and the user.  In bulk,  that means a
            communication by language; and sometimes  by symbols.
            The first step to be taken is a  determination of the
            communicatee - must labels be addressed to those of
            all ages; to those of all degrees  of understanding--, etc.
            As I see it, FIFRA requires a labeling  that has  as  its
            communicatee the well-known reasonably-prudent-man.
            If labeling can be readily and clearly  understood
            by the reasonable prudent man it should suffice  to
            meet FIFRA's obligation to provide protection in
            the use  of an economic poison."

     This in my opinion an accurate assessment of the  situation.

     The existing regulations for the enforcement of the law specifically
require that all statements, graphic representations or designs  required
to appear on a pesticide label be  clearly legible and  easy to  read  by a

person of normal vision.  The regulations require use of the English
language on pesticide labeling, although there are provisions for
permitting the use of foreign language text on those labels for
products intended for distribution in areas where a large percentage
of the population does not speak the Englaish language.  In developing
regulations to implement the 1972 statute we are giving serious conside-
ration to requiring bilingual labeling in those situations where the
Administrator considers it is in the public interest.

     It is necessary that labeling for pesticide products be understandable
to the user.  Pesticide products are used by a wide range of people for a
wide range of purposes.  These purposes vary from the "housewife" who
uses a moth proofing chemical for her woolens to very complex applications
of chemicals by highly trained pest control operators.  Thus, labeling
must range from the simple to the very complex.  There is at times the
criticism that labeling for pesticides is not consistent.  Everyone would
agree that products with the same composition for the same uses should
bear essentially the same type of labeling.  We cannot, however, conclude
that all pesticides of the same composition should bear the same label
in spite of the patterns of use.  To put it simply, a pesticide product
must be labeled to reflect its specific composition, pattern of use,
possible hazards and characteristics.

     Any discussion of labeling from the Regulatory Perspective would not
be complete without some treatment of advertisement.  As a matter of fact,
as I have stated before, the definition of labeling under law includes,
"any written or graphic matter accompanying a pesticide or device or to
which reference is made in labeling or literature accompanying the pesti-
cide or device."  So you can see that quite a lot of the material that
we commonly refer to as advertising is in fact also labeling as defined
in the  law.

     Section 3  of the law requires that in applying for registration, the
applicant must  submit, among other things, a complete copy of the labeling
and a statement of all claims to be made for the pesticide.

     Now, Section 12 of the law makes it "unlawful to sell, offer for sale,
hold for  sale,  ship	any pesticide if any claims made as a part of its
distribution or sale substantially differ from any claims made as a part
of the  statement required in connection with registration."  Previous
interpretations in this connection have held that this means simply that
claims  made  in  advertising must not exceed claims accepted in connection
with registration of the product.  This means, for example, if we refuse
to accept safety claims as a part of the registration - and we do refuse
such claims - they are equally unacceptable in advertising.

      It is  our  policy to cooperate with the Federal Trade Commission in
regulating  pesticide advertising since both Agencies have responsibility
in this area.   Generally, the policy is for advertising other than labeling


to be handled by the F.T..C., however, both Agencies reserve the right to
exercise their respective regulatory powers to protect the public interest.

     The Office of Pesticide Programs, EPA, is now taking a fresh look at
its role in the regulation of pesticide advertising as a part of the total
pesticide strategy.  It is quite possible that this review will result
in some new initiatives into this area.

     In closing, I would hope that we have been able to lay something
of a foundation for addressing the problems that we will consider in
sessions this afternoon and tomorrow.  I think it can be safely said
that we have the regulatory tools to do the job.  We now must get on
with improving pesticide labeling within this framework.


                           A. E. CONROY II
                    Pesticide Enforcement Division
                    Environmental Protection Agency

     Good morning.  I have two messages this morning.  Number one, I
am not a lawyer, and number two, I am not here to read the ACT to you
as law.  I do want to discuss with you two programs that we have - the
Inspection Program, through which we determine if a producer is in
compliance with the statute regarding labeling, and a few words about
the misuse provisions of the Statute.

     The general requirements for acceptable pesticide labeling have
been outlined by Doug Campt.  These requirements are eventually used
by the Agency in reviewing your company's application for registration.
When your specific application is found to be acceptable, that is, to
be safe and effective when used as directed, the agency stamps the
label accepted and puts a date on it.  A copy of that label is forwarded
to the inspector in the field - the EPA region where your company is
located.  There are ten such regional EPA offices throughout the
United States.

     The total EPA Pesticides Enforcement Program, including inspectors,
case proceeding officers, and attorneys, is 150 persons, nearly three
times the number of persons we had prior to the 1972 amendments to the
Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA).  Our
operating budget for the Pesticides Enforcement Division is about
$3.5 million  dollars.  At headquarters, the Pesticide Enforcement
Division plans, directs, and supervises pesticide enforcement programs
of the Agency.  The national program is planned at headquarters, and
forwarded to  the regions for review and for targeting commitments and
objectives for that program.  Those objectives are returned to
headquarters, and, after a complicated review, are eventually approved
by the  EPA Administrator, Mr. Train.  Headquarters, then measures the
results obtained by the regions against the objectives and the commit-

     The responsibility for the day-to-day Pesticides Enforcement
Program has been delegated to the regional staff.  To facilitate this
delegation, standard policy guidelines and procedures have been
established for handling Enforcement actions.  This transfer has cut
down the flow of paperwork and placed operating control  in the hands of
regional officers, who, being closer to the facts, can respond to them
with more sensitivity and speed.

     There are three 1975 program objectives to be met by the regions.
The first is the number of producer establishments to be inspected by
the regions; the second is the number of intrastate pesticide producing
plants to be registered; the third is the number of use and reentry
investigations to be conducted.   The objectives for 1975 have not yet
been approved by Mr. Train.  However, the 1974 objectives were in the
neighborhood of some 2,000 producer establishments to be inspected.
It is anticipated that the 1975 objectives will be in the same

     Section 7 of the Statute requires that each establishment producing
pesticides subject to this ACT be registered with EPA and that they file
annual reports concerning the types and quantities of pesticides produced
at that establishment.  This procedure will provide the EPA with critical
information not presently available on the establishments producing the
pesticides, and the types and quantities of pesticides now being produced.

     A computer system has been developed that will allow us to use the
data to develop statistically sound establishment inspection programs,
to trace shipments of pesticides between establishments in order to
effectively recall or stop sale authority, and to cross-check to assure
that only registered pesticides are being produced.  Manufacturers will
receive an establishment registration number which they will be required
to place on the label of the pesticide produced in that establishment.
Failure to register an establishment, failure to use the establishment
number on the label of the pesticide produced there, failure to provide
the required reports, are all prohibited acts.  Regulations required by
this section of the Statute were promulgated and published in the
Federal Register in November of 1973.  To date, the Agency has
registered 3,507 establishments.

     Section 9 of the Statute provides authority for the EPA to inspect
establishments where pesticides are produced and held for shipment or
sale, and allows for the collection of samples of pesticides packaged,
labeled and released for shipment.  It is through the inspection of
establishments that EPA can best detect violations of product labeling
and chemical composition requirements.  To a large extent, an adequate
inspection program can bring about the type of quality control that
ultimately is necessary for optimal environmental protection against
the hazards of misbranding pesticides.  Inspection of the product
establishments allows for discovering violations before they can reach
the market place, and, if necessary, the new stop sale authority can be
used.  The regions select the producers to be inspected, based on the
guidelines put out by headquarters for the regions.  These guidelines
set the criteria for inspection in the following sequence:

     1.  Producers of pesticides whose products this agency has

         never sampled.

     2.   Producers of pesticides whose products were recently
         found to be in  violation of the Statute.

     3.   Producers of pesticides whose products have been
         found consistently to be in compliance.

     The inspections include a review of the manufacturers records as
required by Section 8 of the ACT, a check of the registered labels to
assure that the collection of samples are done, and that registration
requirements are met.  Also, time is spent to educate the producers
concerning the law, the  regulations, the registration of establishment
requirements, and to provide them with any forms necessary to
accomplish this.  The timing of the inspections should not signifi-
cantly disrupt normal business operations.  Our inspectors have been
informed of national guidelines for regions and that greater industry
cooperation will be obtained through courteous persuasion and tact
rather than by stressing the force of the law.

     National guidelines for inspectors direct the Inspector to first
present his credentials  to the producer.  He, then, must present the
producer with a written  notice of inspection explaining the reasons for
the inspection, what violations have been committed, and, that he, the
inspector, has access to all pesticide products packaged, labeled,
and/or ready for shipment.

     The inspector is also required to inform the  producer that he is
entitled to a duplicate sample of the pesticide.  It is interesting to
note that out of the 1,500 inspections that have been conducted in the
past, only 25% of the producers have requested duplicate samples.   As
you know, these samples can be used in court cases by both EPA and the
producer.  So, it is important that you, the producer, ask for a
duplicate sample of the pesticide.

     The National Guidelines also direct our inspectors to explain the
results of their inspections.  What, then, can the producer do to  comply
with the law?  He can become familiar with the laws by attending meetings
such as this.  He can register his product.  He can register his produc-
ing establishment.  He can practice good quality control  - not only in
the formulation of the product but also in the labeling of the product
A great number of misbranding violations are caused by use of an old  *
label that is no longer acceptable or by using a new label prior to

     fly next subject concerns Use and Misuse of Pesticide Products

     Section 12 of the ACT prohibits the use of any pesticide in a
manner inconsistent with its Tabeling.  This is a new requirement
of the Statute.  Due to the millions of pesticide users, it is
extremely difficult to detect and enforce the law in terms of mis-
use.  Obviously, any programs in this area will have to be directed
to those misuses which are likely to create serious damage to human
health and the environment.

     The first part of the EPA Use Investigation Program involves
obtaining needs from currently existing sources such as food and drug
residues, citizen and trade complaints, and EPA accident investiga-
tions.  These leads will be reviewed by EPA and, when appropriate,
will be followed up by further investigations, inspections, and
prosecution if it is warranted.  The program detects misuse only
after the fact and only if the misuse has resulted in some detect-
able residue or in an incident.

     The second part of EPA's use investigation program is a limited
supplemental program of surveillance, which is undertaken by EPA on
its own initiative.  The program provides for an increased effort
related to products and user groups, selected periodically by Enforce-
ment and the Program, as posed in especially serious danger to the
public health and environment.  Again, I emphasize, it is unlawful for
any person to use any registered pesticide in a manner inconsistent
with its labeling.  Any use of a registered pesticide not in accordance
with the directions for use that are included on the labeling is in
violation of the ACT.

     Doug Campt has explained to you the difference between the label
and labeling.  If the registrant desires to allow certain qualified
applicators to vary from the normal  directions for use of a certain
pesticide, and if this Agency, the Registration Division, and
John Ritch are in agreement, such allowance could be explained in
accompanying labeling.  Under these conditions, such use would not be
in violation of the law.

     Discretion remains to the Agency to determine whether a violation
has occurred, and if so, what level  of enforcement action is necessary
in terms of prosecution - criminal or civil.  Bear in mind, however,
that Section 9(c)(3) of the Statute states in part, "Nothing in this
ACT shall be construed as requiring the Administrator to institute
proceedings for prosecution of minor violations of the ACT."

     In 1968 the GAO published a report to the Congress entitled "Need
to Improve Regulatory Enforcement Procedures Involving Pesticides."
Many of the deficiencies pointed out by that report were admitted and
predecessor agency initiated changes in policy and procedures to correct

those deficiencies.

     In May of 1974, the GAO published a report to Congress entitled
"Pesticide Actions Needed to Protect the Consumer from Defective
Products."  During the time frame upon which the GAO report is based,
(January, 1968 through June, 1972, a period of some 54 months), this
Agency conducted its own investigation, and had noted many of the same
findings specified in the GAO report.  In late 1971 this Agency
established the Pesticide Enforcement Division (under the control of
the Assistant Administrator for Enforcement), specifically to correct
the discrepancies specified in the GAO report.

     The 1972 amendments, a change in the Agency's philosophy toward
pesticide enforcement, and substantial increases in resources,have
corrected many of the discrepancies reported by GAO.  During the 54
months covered by the report, the Agency conducted no establishment
inspections.  The Agency sampled 7,000 of the registered products and
initiated some 52 major enforcement actions. During the past nine
months of our present program, from July, 1973 through March, 1974,
the Agency has conducted some 1,500 inspections of establishments,
has sampled 3,000 of the registered products, and has initiated 378
enforcement actions.

     While this Agency, our predecessor agency, and the industry have
been severely criticized concerning compliance with the law, it should
also be noted that the great majority of the industry is now producing
pesticides that are in compliance with the law in all respects, and
that those firms that are not doing the same are quickly brought
around via education through our inspection program and the use of the
civil penalties provisions.

     The  industry has acted responsibly in the recall of products, a
sanction  that is not specifically provided for in the Statute.   In
over 500  Agency requests to the industry to recall  products potentially
hazardous when used as directed, all but two firms fully cooperated
with the  Agency.

     Industry has taken the time and made the effort to comment upon
Section 7, the Establishment Regulations, and Section 8, the Books and
Records Regulations - the two regulations for which the Pesticides
Enforcement Division has lead responsibility.  We feel  we have better
regulations, because of your concern, your efforts, and your time.


                              James E.  Dewey
                              Program Leader
                      Chemicals & Pesticide Programs
                  New York State College of Agriculture
                            Cornell University

     I always approach talks of this sort with foreboding, because being
the only state person on a program presented by agencies, I suspect they
may be pulling one of our old tricks.  We'd put an extension man on, tell
him what he was supposed to say, get him behind the podium, and then follow
him with someone else who would tell what he should ha«e said.

     This morning, however, I want to talk with you about labels from a
point of view we haven't considered yet.  We must recognize that labels
are useful tools, and that most people know very little about pesticides.
We must also recognize that in spite of our efforts, not enough people
read pesticide labels carefully,  Finally, we must recognize that most
pesticide accidents occur in the home or non-agriculture settings.  For
instance, in Illinois, which probably has better records in this than most
states, nine out of ten pesticide accidents happen in homes.  Furthermore
they happen to an age group that does not read labels, because  another
group also does not read labels.

     Mr. Conroy has already pointed out that enforcement of pesticide
misuse provisions is almost impossible, unless it is after the  fact.
Therefore, we must establish priorities to be considered in lebel regulat-
ion.  Do we want the label to become more and more of a legal document?
I know what happens to the fine print on my insurance policy; it doesn't
get read.  Do we want the label to replace the recommendation of the
agricultural colleges and cooperative extension services?  Do we want one
label to apply everywhere in the United States?

     Mr. Campt expressed my view of the label clearly when he said that
the label should aid in allowing the use of a pesticide without adverse
effects on the environment.  With this I agree, and to this end we should
direct our efforts.

     To do this, we must make the label more attractive to the  user, to
make him want to read it.  It is therefore important to keep the label
simple.  The ideal'label should contain, first, the common name, for
instance, "Product X, Garden Fungicide."  Then listed should be which
diseases on which crops the product may be used.  It should have a state-
ment of the active ingredients and the amount.  The caution statement
appears at the bottom and all should be legible.  In addition,  directions
for use regarding timing, crops, diseases and amounts should be clearly

     I will now proceed to specific problems; unfortunately, regulation
of labels has not been consistent, and so we have many different diffi-
culties to examine.  For instance consider common names.  I urge you
that whenever possible, a common name for a material be established when
that material is first registered; thereafter, that common name will
always be used for that product.  This step would aid pesticide users gen^
erally, and medical personnel in accident cases.  Usually a chemical
name is not recognized by users.  This step would guard against product
line names such as "Raid" or "Orthocide"; These generalized line  names cover
numerous unrelated products, and cause confusion.  Another problem  on
these lines is the change of product formula without corresponding  change
in name; "Isotox" is an example.  Enlarging the print size of the ingred-
ient statement would also be helpful.

     Another major problem area is the confusion of toxicity signal words.
The four toxicity categories and their signal words are; highly toxic,-
skull and  crossbones,  "danger", moderately toxic,-"warning," slightly
toxic,-"caution," and  relatively non toxic,-with no signal word.  These
terms are  not all used consistently for various formulations of the same
pesticide.  One reason is that the warning, "Keep Out Of The Reach  Of
Children"  is placed close to the signal words.  The user sees the child-
ren warning, says  "Oh  hell,  I knew that", and reads no further.   He
doesn't  read the caution and warning statements because we are telling
him something he thinks he already knows.  As an example we have  the
repellent  "Off  ."  Here is a material that you rub on your hands, your
face, your neck, and yet you have the same cautions printed on the
container  "keep Out Of Reach Of Children" which is supposed to mean
something  else on  a pesticide container label.

      A related  problem is the close placement of flammability and other
 caution statements.   I think, then, that the "Keep Out Of Reach Of
 Children", the  signal  word,  and the flammability statement should be
 divorced from  each other.  In addition, it might be helpful to design new
 symbols, like  the  skull and  crossbones, for the other toxicity categories.

      I'll  reiterate what  I consider to be the characteristics of  a  good
 pesticide label.   The  common relatively simple name and the chemical
 name  appear in  the ingredient statement.  The common name and directions
 for use appear  in  a systematic  format.  The various cautions and warnings
 are distributed  so that they will all be read.  All of this is legible,
 and when possible  completely in one area.

      I am about five  minutes overtime, but I have two more concerns that
 cannot be overlooked  at this time.  One of the problems of labeling is
 how the consumer is going  to know what labeling covers.  This is agg-
 ravated by the problem of  October 1974, when many state registrations
 will  no longer be  in  effect, and when we have the problem of minor  and spec-
 iality crop uses.

     In New York we have about 2,000 which are not officially registered
at the EPA level.  I don't know who is going to do it, but it is going
to be chaotic. Many of our recommendations probably will  be withdrawn
unless something is done about it.

     One other problem worries me more than a little and  that is that
there is a growing breech within the EPA as to the interpretation that
a label had when it was originally accepted by the Office of Pesticide
Programs and that interpretation some of the enforcement  offices give
the situation.  It makes it extremely difficult for us to work and train
people and to get them to follow certain procedures as a  matter of
training, then they find out, "Well, so and so says that  really isn't so."
Soon they say, "Oh, what does it mean?"  I am willing to  give up.

     I think we have to be very careful about this sort of thing in
the matter of labels and dosages.  I understand Mr. Myrack and Mr. Kirk
have been exchanging letters.  I have always been under the impression
that the label carried the maximum dosage, especially on  food crops,  that
could be used to keep you within the tolerance level.  Certainly we in
the New York area frequently have not used maximum levels nor do we
intend to begin to do so; and that would only add more pesticides to  the

     We have to reappraise what we are going to use the label for, what
value it has, and then set out doing it.  Hopefully, we will  make the
label a useful tool and a tool that will be used.

     Thank you.

                            DELVAN  W.  DEAN
                    Pesticide  Regulation Specialist
              Department of Agricultural Chemicals & Feed
                    State Department of Agriculture
                          State  of  California
     Ladies and gentlemen,  one of the previous speakers said that he
hoped that the environmentalists  would be here.

     There is one here.   I  am an  environmentalist.   I believe that
everybody in this room is an environmentalist.  We  may have a little
different philosophy and a  little different background, but I believe
all of us do want a good, clean and safe environment.

     Also, there is a member of the Sierra Club  here.  I am a member
of the Sierra Club and have been  for a long time.   We have people in
the Sierra Club who look at things in black, we  have people who look
at things in white, and all shades in between.

     I have to admit that I am one of the shades in between.

     It is a great pleasure for me to be here today to discuss one of
my hobbies - pesticide labeling.

     I retired from the Federal Government about five years ago, and
then, after painting the house and few other things, I inadvertently
went by the Department of the Bureau of Chemistry in Sacramento, and
in three  days I was back working  at about the same  job I held with the
Federal Government.  Now I am with the State of  California Department
of Food and Agriculture.

     One  of the reasons  I wanted  to get back into this type of work,
especially with the California Department of Agriculture, is because
they had  at that time what I considered to be a  complete program of
pesticide regulation.  Their law did cover usage; it did have what we
have now  adopted in the  federal law regarding usage; it did have a
number of restricted materials.  I think California has a complete
system for controlling products of this kind.  It has had for many years.

     I am not as sure now as I was then that these  things were needed
that they will bring about all the fine benefits of pesticides and have
a good effect on the environment.  It is harder  once you get into these
things to find the answers.

     My part of the California program deals with registration itself
It deals  with environmental protection, and it deals with workers'

     Other parts of the California program, of course, involve the
things that Gus Conroy has already talked about - the sampling of
pesticides, their evaluations to determine whether or not they are
up to claim and are labeled correctly.

     Another phase of the program is the sampling in the field on the
raw agricultural products to determine if they have violative residues
on them.  We quarantine production if we find residues.   We analyze
about 10,000 samples a year, which is far above the number sampled by
the Food and Drug Administration in our area.  We have a fairly good
idea of what is being used and how it is being used by sampling the
products as they come from the field.

     The usage enforcement involves still licensing examinations of
pilots of aircraft who apply these pesticide products, as well as
ground applicators and what we call pesticide advisers.

     Most of the advisers are also salesmen, but there are many advisers
in the state of California who do not sell pesticides.  They make recom-
mendations to farmers.  These recommendations are made in writing.   The
farmer is advised as to what product to use and whether or not there
are limitations on the use, such as not to harvest within 10 days of
application, or, not to permit workers to go in the fields within 15
days of harvest.  There, of course, may be contradictions of this.   The
directions must be on the recommendation.

     The overall programs are directed by people at the state level  in
Sacramento, although we do have people in Los Angeles and San Francisco.
Most of the programs are directed by persons in Sacramento.

     In California we have what we call the County Agricultural
Commissioner System.  Each county (there are about 50 to 55 counties)
have Agricultural Commissioners, if they so desire, who  are hired by
the county supervisors.  The Commissioners are hired from a list that
is certified by the Director of Food and Agriculture.  They must submit
to an examination.  This examination is very similar to  the Civil Service
Examination.  A county supervisor cannot hire just anyone for the Agricul-
tural Commissioner's job.

     The Agricultural Commissioners supervise many enforcement activities,
such as egg inspection, food and vegetable inspection, and meat inspection.
The inspection of pesticides is also one of their functions.  The
Commissioners also have access to an employ some 700 people who are on
call and can join in the enforcement activity at any time.  They supervise
the applications of pesticides, watch for violations in  the field and
issue citations if they see violations.  This is done is much the same
way that an officer would give a citation for a highway violation.

     In California this use enforcement is estimated to cost the Agri-
cultural Commissioners at the county level about $1-1/2 million.
At the State level these programs cost about $1-1 1/2 million, so
that there is about $3 million going into pesticide enforcement control.
I believe that the Federal government which might get into usage control
must allocate funds in about the same amounts for registration and
other pesticide activities.  If they have $30 million devoted to these
then it would take between $60 million and $100 million to expand into
usage control.  This may not be necessary.

     After working with both Federal and State systems I do not advocate
this expansion of Federal pesticide activities just as I would not advo-
cate other States adopting the county agricultural commissioners system.
Each State and organization must, based on its own findings and needs,
decide  where  to put its money.  For instance, in California, the
pesticide regulatory program would fail without the Agricultural
Commissioner  system.  But I do not recommend that this system
be  adopted in other places.

     Let's go back in history.  The first California law was adopted
about  the same time the first federal law was, about 1911 or 1912.  The
first  law did prescribe analyzing products.  It did call for registra-
tion,  a perfunctory listing of what the agricultural stations used.

     There was a  gimmick  in this law that only those products need to
be  registered that cost more than one half cent a pound.  I cannot
 imagine any  pesticide selling for less than a half a cent a pound new,
 but apparently at that time they may have, for instance sulfur or
perhaps tobacco dust.

     The California revised law was passed in 1921.  By that time they
found  registration didn't mean much, when it was simply a listing of
 products.  The new law called for the denial of registration for
worthless products and products not proven to be of pesticidal value.

     At that time, too, the California department was authorized to do
 about  the same things that are now encompassed in the amended Federal
 Insecticide,  Fungicide and Rodenticide Act.  Actually, from the earliest
 days in pesticide work  in California, it's been a consistent policy of
 the California authorities to work with manufacturers and all other-
 interested  parties, hold  meetings, conventions, and conferences  to try
 to  outline  to them the new developments in pesticides.          '

      In 1923, Director Hecht pointed out the danger of selling from
bulk into unlabeled containers, and shortly thereafter this was made

illegal in California.  Also he complained about tree doctors who were
injecting trees for the control of insects, were killing the trees
rather than the insects.  In this case, of course, he denied

     Also, he complained about poultrymen who were being offered a
product that would forever after keep insects off poultry.  In this
case, too, he denied registration, and shortly thereafter he was
taken to court for denying registration.  About 2 years later, an
Appellate Court decision in the State Court upheld his right to
deny registration for worthless products or those that caused damage
to the environment.

     An important decision was made later by regulatory people, pro-
ducers and legitimate merchandisers.  Allen Cox, as the forerunner of
modern-day pesticide regulations, in 1937 stated to the industry that
claims such as "improved, activated, stabilized" must be proven before
they could go on the labels.  He commented that used pesticide con-
tainers could cause trouble, and he specifically mentioned a product
that was advertised as "to make a dandy bird bath when empty."

     He denied registration to poisons sold in bottle caps as being
a hazard to children.  He placed thallium sulfate in 1937 under
strict control of the Agricultural Commissioners, so that it could be
used only by official people.

     An interesting sidelight to this is that just last month, a farmer-
rancher, in moving some old stocks, found a bag of what appeared to
be grain.  Then he noticed there was a tag attached to the bag, a
skull  and crossbones.  No other wording was legible.  The skull and
crossbones alerted him and he sent the product in to our lab.  It
was thallium sal fate-treated grain.  As a consequence, this was
disposed of  in what we call a class one disposal site.

     This points up the very great difficulty, of removing from the
market, from the home, and from all places where they may be stored,
pesticides that should not be around.

     Dr. Cox, at a national meeting, also talked about the coloration of
pesticide products to avoid having them mistaken for sugar or flour.
He mentioned the off-color paints for calcium and lead arsenate.

     He pointed out that labels often become illegible or detached,
and advocated that pesticides be labeled "Keep Package Away From
Children."  He also proposed the label warning, "Do Not Store
Near Foodstuffs."  These are now practical Federal requirements.

     Dr. Cox warned against transferring pesticides into unlabeled
containers.  In the past 2 months, by the way, there have been
deaths consequent to pesticides being transferred to unlabeled


containers.  We do not know how to prevent people from pouring pesticides
from the original container into unmarked containers.

     Dr. Cox also recommended that a repulsive odor be built into the
pesticides, and he denied registration to products in collapsible tubes
similar to toothpaste tubes, mainly because when the tube is rolled up,
the caution or warning statement then disappears.

     My purpose in going over the history of this is to point out that
over the years we have faced aalmost the same labeling problems we are
facing today.  Actually, there have been improvements in labels, and we
should not be discouraged when we face new problems.  From this conference,
we hope, will come new suggestions to improve pesticide labels and labeling,

     The new generation of synthetic pesticides came into use in the late
1940s.  In California, we immediately ran into trouble.  There was serious
injury to non-target crops of grapes and cotton due to 2,4-D drifting for
miles from the site of application.

     Shortly thereafter, hearings were held in Sacramento to decide what
to do about the 2,4-D.  The grape and cotton people brought in their
damaged plants.  The grain growers, who could increase their grain pro-
duction by using 2,4-D defended vociferously their right — "right,"
so they said—to use 2,4-D, in the culture of their crops.   Fortunately,
Mr. Lanham, the Bureau Chief at that time, headed off bloodshed in the
hearings.  It came close to that.

     From these hearings was developed the restricted materials regula-
tions that are in use today in California, which involve a permit system.
Before a grower can use a product on the restricted list, he must go to
his Agricultural  Commissioner for a permit.  This permit, its limitations
on use, and the areas in which 2,4-D can be used are discussed by the
Agricultural  Commissioner with the user.  The permit number must appear
on the invoice that he purchases; thus, his right to use the product is
involved in his possessing the material.

     Since the time this permit system was developed, we have placed
about 30 to 40 other products on the restricted list.  Since last
year, for example 21 additional products were added to it.

     There are many reasons for putting names on the list but generally
it is due to a problem that has developed over the years in the field
for instance toxicity to other crops, or human toxicity, as in the case
of parathion, which has long been on the list.  A third reason is
exampled by the recent listing of mercury-contaminated seed.  We
placed the treated seed on the permit list; in order to plant mercury-
treated seed, the grower had to get a permit from the Agricultural
Commissioner.  The problem was that pheasants were eating the treated
grain, and the mercury was turning up in the pheasants.  But it is a
moot question since mercury-treated seed has been suspended in California

     We have a computer system in California which revolves around reports
to the Deaprtment of the use of certain pesticides.  All  restricted
materials used by the applicators must be reported.  We think we have a
report rate of 80 percent.  As data comes in, we compile and publish a
list of these reports.

     Ancillary to the use reporting which we started out to do, is the
registration information that goes into our computers.   We issue re-regis-
trations by machine in California.  This computer programming is a big
headache, and is very expensive.  We have had it about 5 years and I
would not recommend its use to other States unless these States can put
the people and money into it.

     In the present day, our law authorizes control at the user level and
has done so for several years.  This applies as the Federal law does, to
the householder as well as to the agriculturist.  We think most of the
pesticides are used by the agriculturist and so that is where most of
our effort goes.

     Our law prohibits use of a pesticide in conflict with its label, but
we do not know exactly how this squares with the "use inconsistent with
labeling" provision in the Federal law.  We think the words mean about
the same, but we are not sure.  It will probably take a court decision
or an agreement between our state attorneys and the Federal attorneys
to settle the issue.  We say that any use that does not appear on the
label is in conflict with that label.

     However, when legislators included this conflict with usage provision
in the law, they also authorized the director, and in certain circumstances
the Agricultural Commissioners, to authorize useage.  We have a special
form for these usage authorizations.  For instance, if one wanted to use
an insecticide on cyclamen in the greenhouse for commercial production,
the nurseryman could obtain an authorization from us, after consideration
was given to the effectiveness of the pesticide, the possibility of
injury to workers in the usage, and whether or not there might be a
pre-harvest or worker harvest needed.  We write a specific authorization
and put on it a date at which it no longer is effective.  We have been
doing this for about 5 years.

     This may be a violation of the law and inconsistent with Federal
law.  Gus Conroy may throw me or my director in the hoosegow but we
are continuing with these authorizations as a satisfactory way of
handling minor crop usage.  This authorization program does not apply
to the myriad of minor crop usages we will have to think about in the

      On May 9, a little less than a month ago, our worker safety regula-
tions, enforced by the Department of Agriculture went into effect.   These
regulations are constructed to fit in with OSHA and with CAL OSHA programs.
CAL OSHA may take over the worker safety program.  Until then, to continue
the program, we passed these regulations.  I am not going to discuss the
worker re-entry time limits, which were the center of much controversy
both state and federal.   We incidentally think we may have different
conditions in California than in other states, and we would not advise
other states, nor the Federal government to pick up our worker re-entry
time limitations.

     In the few years that we have had specific worker re-entry periods,
we have looked for, but not found violations.  We think these worker
re-entry periods do not interfere with cultural practices.  We do not
have worker injuries from re-entry in those specific locations, for the
specific crops, where these worker re-entry periods are in effect.

     We know from doctors' reports which must be furnished to our de-
partment and to the health department that the workers exposed to most
pesticide risks are those who use the concentrate materials, those that
handle them, those that pour them into the mixing tank to make the dilute
materials and those that spill them on themselves.

     Consequently, in our worker safety regulations, we are providing
for the adoption of closed system handling of the concentrates.  In
other words, they will not be handled, they will not be opened.  They
will be placed in machinery that can open the containers or mix it so
that no person is exposed to them in the mixing.  This is a long-term
project which involves a construction of new agricultural equipment.
We probably will grant the University of California money to work on
this.  However, we are also involved.

     Of course, the thing we want to do there is to make the work
place safe.  This is an ultimate ambition, to make the work place safe
for all workers.  In the meantime, however, label instructions must be
followed.  This, as you know, poses serious problems.  It is very
difficult to follow all those label instructions regarding pesticide

     A great burden is placed on the label.  Neither the label nor  the
workers can accept full responsibility.  This brings us to the question
of why labels are in such a confusing condition.  I would say this:
Most  labels were devised according to the old theory that if you tell
a person, through a label, how to use a product effectively and safely
then  he can follow that label and get effectiveness and safety.

      I think our  interpretation of the meaning of the registration
and the new law will lead us to requiring that one must follow the
label.  We will have difficulty trying to decide for the more toxic

categories of products just how much of the label  has to be followed.
The labels are not ready for this yet.  This applies to pre-harvest
intervals as well.  At the time many tolerances were adopted, there
was no point in putting a short harvest interval.   Regulatory people
didn't see any problem if they set an application  limit four weeks
before harvest, because it didn't interfere with the cultural practice.
There was no use making application dates closer to harvest.  Now how-
ever, some field operations after the application  of pesticides would
make it handy to have more exact pre-harvest intervals.

     During the period that we have had usage control, we found it
necessary to institute a toll-free hot line for agricultural commis-
sioners who get questions in the field from experienced field people.
These questions deal with label meaning and usage  patterns.  We have
one full time man answering the telephone and researching the answers
to these questions.  Frequently we don't have the  answers, nor do the
EPA field men know the answers.  They have to go to EPA in Washington
to get background, and this is an expensive process.  I think EPA,
if they expand into usage control, will come up against this more and

     We also get much input from manufacturers.  Once EPA registers
a label, it becomes automatically fixed.  They tell us we can't ask
for a change.  They tell us they have registered with EPA and don't
want to take another year to go in and get a slight change in the
label.  Ordinarily we don't ask for what we consider to be slight
changes.  We ask only for those changes we consider to be major.
We do find that when the EPA and manufacturers, together examine
these problems involving label discrepancy between what EPA wants and
what we want, there are no major problems.

     Of course, we do want worker safety standards and labeling of
time limitations between application and harvest.   We would like to
have these on the labels.  We have asked for it in the labeling or
in bulletins, but we have not yet insisted on that.  We have suggested
from time to time that in this labeling format one special place and
type for cautions and directions would be useful.   We are looking to
new innovations and we will adopt any new labeling that appears satis-
factory.  We know that labels must be improved.

     We have legislated usage control.  Labels must be followed.  What
we need now is to legislate comprehension but I don't know how we are
going to do that.

                          Labeling Problems - Federal

                            William A.  Wells, Ph.D.
                  Section Head,  Standards & Labeling Section
                              Registration Division
                           Office of Pesticide Programs
                          Environmental  Protection Agency

     DR.  WELLS:   Good afternoon, fellow environmentalists.

     One of our speakers this morning made reference to a famous Greek,
Archimedes, the great mathematician.

     I, too, find myself drawing an analogy to a well-known Greek from
mythology.  However, the Greek that comes to my mind was not gifted
with lofty intellect nor was this Greek a man.  The  Greek for whom I
feel empathy at this point is Pandora,  the ill-fated lady of Greek
mythology who opened the box given to her by the God Zeus and in doing
so released all  the ills and evils known to man.

     While it falls my lot to open this box of labeling problems with
this afternoon's session, I do so with the hope that the evils thus
exposed will not escape us as they did Pandora.  I and the speakers
who follow me this afternoon open this box with the  full knowledge of it's
contents.  We expose these problems not to allow their escape through
ignorance, but hopefully to allow their resolution through knowledge and

     For the next few minutes I  would like to explore some of the problems
encountered by the EPA in operating within the framework of requirements
outlined by this morning's speakers.

     As I am sure most of you realize,  the labeling  is the ultimate
vehicle for expression of the laws regulating the registration and use
of pesticides.  The labeling explains,  determines and regulates.  The
labeling is the capsule summation of all the characteristics of a
given pesticide product.  In short, both the purpose and function of
labeling is to communicate in one way or another all of our basic
problems with labeling related to this:  communication.  The labeling
and those accompanying materials which make up the label ings were born
in the first step of this communication:  the communication from the
registrants to the Registration Division of the EPA.  This labeling is
in the form of draft or intended labeling.  It is this draft labeling
which forms the framework of the registration review which follows.

     Unless that labeling contains all  the necessary information
valuable time is often lost in order to either change the labeling
or for the review to begin at all.  I am sure that it is often
difficult for the registrant to ascertain if his labeling does in

fact contain all the required information.  No doubt the registration
guidelines, hopefully to be published in the near future, will help
remedy this problem.

     However, there are certain steps that a registrant can take to
insure his success in providing all the information.  He should insure
that his intended label reflects the results of the data that he has
gathered in support of that labeling.  A registrant should not second-
guess the data nor should he propose labeling which projects hopes
rather than facts.  In label review we are dependent upon the facts
before us and cannot afford ourselves the temptation of claims and
hopes more readily visualized by sales personnel than by pesticide
scientists.  Indeed, it is often the influence of salesmanship which
accounts for many of the problems encountered in this initial step in
labeling development.  We encounter, especially in the case of older
pesticides, a given use for a given pesticide expressed in many different
ways.  The situation that is often caused by sales influence is one which
wants a little different wording here and a little different wording there
in the hope of expanding a market.  Over the years this word manipulation
has been one of the factors which has helped to produce labeling filled
with inconsistencies and excess verbiage.  Many of these examples were
shown to you this morning by Dr. Dewey.

     A possible resolution to this problem may be the development of
standard or master labels.  The master label for a pesticide would
reflect all the registered uses for that pesticide, with standardized,
concise directions for use.

     A registrant might not want nor would he be required to put all of
the uses on his given label, but those uses that he did choose to have
on his label would have to reflect the standard use directions.

     We must start thinking along these lines.  We must stop registered
labels and start registering pesticides.

     Let us now explore the second step in this communication:  the
communication from EPA to the registrant.

     For an application that is received by the Registration Division,
a screen of sorts is given to the application before it starts down the
review chain.  Sometimes this screen detects that the submission is not
complete.  Sometimes it does not.  Often valuable time is lost when
something is lacking which may be required and may not be discovered
until midway or further down the review path.  Thus, time is lost in
communicating this need to and receiving this information from the

     The EPA Registration Division needs to beef up our initial screen
of applications to insure completeness at this initial step.  We are
taking steps to do this in the current reorganization.


     It is impossible to have one person review all  applications; therefore,
there will always be some inconsistencies.   However, the inconsistency in
label review presently far exceeds this minimal acceptable level.  This
inconsistency is due in part to many of our current procedures.   One of
these is in allowing review to proceed along one of several pathways,
which allows many different people to become involved.  This gives room
for inconsistency and for confusion.

     Again the reorganization now underway  will, hopefully, aid in
correcting these procedures.  Products will be assigned to product
managers who will coordinate the application's review and be the contact
men for all applications on a given product.  Review will tend to proceed
down one pathway rather than many pathways.

     Another contributing factor to the inconsistency and confusion in
label review is the fact that often review  is really based more on
tradition and--I hate to use the word, but  it is true—folklore handed
down from reviewer to reviewer.  There are  no--or very few—internal
registration review guidelines available for the reviewers.  Since we
presently have very little to guide the reviewer other than training
and tradition, we have a need  to develop internal  registration review
guidelines.  Work has already begun on such guidelines, and I can assure
you that they will have a high priority during the summer months.

     Unless we have such guidelines--guidelines that tell the reviewer
when he gets an application in front of him what steps that he must take
in review of this application—unless we have guidelines that tell us that
and more, the present problem of inconsistency can grow to chaotic propor-
tions during the upcoming pesticide classification,  the reregistrations,
and  the registration of intrastate  registrations.

     These guidelines will also help to remedy another  problem that we
encounter:  the lack of a uniform approach  to labeling review by the
various disciplines within the Registration Division.  This problem of
differing approaches to the review of labeling becomes especially crucial
in view of the misuse provision of the new  amendment to the FIFRA.  For
example,  insecticide label reviewers currently require that every insect
pest intended to be controlled must be listed on the label.  However,
herbicide label reviewers allow representative broadly leafed weeds to be
listed and then followed by a phrase such as "and similar broad leafed
leaves."  One allows flexibility; one does  not.

     We are all familiar with some of the views which have been expressed
regarding use inconsistent with labeling.  While many of us would hope
that judgment and reason could be employed  in interpreting labeling  we
must be prepared  to meet the demands of a  strict literal interpretation
of labeling with regard to misuse.  However  undesirable this approach
may  be, we may  be forced to follow it.

     The misuse problem highlights a need which is not new.   That need is
for flexibility in labeling, flexibility of the sort which allows for
grouping of similar pests which will be controlled by a similar use
pattern and possibly even grouping of similar crops.  Crop grouping is
one possible approach to solution of the minor crop problem.

     Such an approach would require recognition of long-standing agricul-
tural practices which have enjoyed a long history of use.

     A case in point is that of type mixtures, many of which  are based
on years of experience, but yet are not officially registered uses.  It
may be necessary to include labeling which allows for consultation and
recommendation by extension personnel or other experts to  meet the local
needs without the curse of misuse.  Dosage ranges and scales  may be
employed to a greater degree in the future than they are presently.

     Something has to give with misuse, either the  interpretation of the
label or the label itself.  It would be nice if we could have both.  If
we cannot have both, then we must insure that we have one.  Right now it
looks like that might have to be the label Itself.  We must be aware of
the physical limitations of the label.  It is impossible to put everything
on the label.

     All labeling should follow the same basic design and  highlight the
most important information.  The various portions of the label, such as
the front panel, should be clearly designated and all carry the same sort
of information.  Thus, a user would always look to the same portion of a
label in order to find certain information.  This information should be
as concise and simple as possible.

     The master label concept can possibly offer help.  Standardization
of terminology and language is needed.  Often you can find a  herbicide
label that may have the same weed appearing under two or three different
names on the same label.  We need to have standard terms that are
employed for pests, for use patterns, and so forth.

     The use of symbols rather than words is another approach which is
already being utilized in the case of  warning statements.

     Another concept is regionalized labeling.  A number of companies
already employ this approach in order to eliminate multiple listings
of the similar use under differing soil and climatic conditions.

     When we speak of regionalization, one thing coming to my mind is
the question of bilingual labeling.  All of the problems I have been
talking about with English language labeling, of course, are multiplied
when we talk about bilingual labeling.  It is another problem that we
have to consider.

     Another problem as yet unresolved is the question of general versus
restricted labeling and how the restricted uses are to be identified.
The thrust of the FIFRA, as amended, is toward the applicator as the
source of knowledge and expertise rather than the label.  Future labeling
will more than likely reflect this concept.

     This clearly brings us to what the last line of communication is:
the communication to the user, the most crucial communication of all.

     Again, the need for standardization and uniformity becomes all
important.  If a user can expect to see certain information expressed
certain ways in certain places on all pesticide labeling, then he can
be more easily educated to read and understand labeling.  He will not
be forced to hunt and pick through a complexity of words which differ
on every label.  He will become able to quickly locate and read the
important facts governing the use of the pesticide, and we will have
come a long way toward dependence on the user for expertise.  In those
cases where a special knowledge is needed, allowance should be made
for consultation and recommendation by experts.

     We must also consider the problem of container and pesticide disposal.
Many present labels are inadequate in this respect.  In this day of
energy shortages and conservation of raw materials, we may need to
consider  the possibility of recycling some pesticide containers into
less toxic  categories rather than a standard statement which says to
crush and bury.  Most labels have a disposal statement, but most or
many of  the statements  are totally inappropriate.

      I spent the last few minutes sort of bombarding you with a seemingly
endless  series  of  labeling problems and related problems.  I have attempted
to intersperse  some  possible resolutions as I have bombarded you.   I
hope  I have stimulated  you to  do  some thinking, some constructive
thinking.   Think along  the lines  that the  label is a vehicle for com-
munication. As such,  it must  be  streamlined to move the information,
not to obstruct or  to  stop the flow  of communication.   It must be a
simplified, flexible message of  information concentrating on the most
crucial  facts,  not  a bulky compendium of every available piece of
knowledge.   It must  instruct  and  guide, not beguile or  bewilder.

      We  must now be  guided by  facts  and by  reality.  The key words  are
 consistency, standardization,  simplicity,  flexibility,  and conformity
These  are the  keys  that hopefully will  enable  us  to open the Pandora's
 box of  labeling with good  results instead  of disaster.

                            Labeling Problems - State

                             William B.  Buffaloe
                            Chief Pesticide Officer,
                              Pest Control  Division
                   North Carolina Department of Agriculture
     Mr. Chairman, ladies and gentlemen,  I  do consider it a real  honor
to have been asked to speak to you at the first of what maybe should
be an annual Labeling Symposium.

     As you can imagine, with a name like my own,  I don't receive many
straight introductions.   I must tell you  this story.   Recently,  about
2 months ago, we were blessed with the birth of a  baby girl.   Prior to
this time, a good friend of mine by the name of Allen Hodge told me,
"The worst thing in the world to do is have a child born on this earth
without a first name."  I said, "Yes." He said, "I can remember mine
being designated on a card as Baby Hodge."   I said, "Can you  imagine
what it would be if it said Baby Buffaloe?"  We had the name  picked
out, but believe it or not, they had a bracelet around her arm with
the words "Baby Buffaloe."

     For 13 years I have been associated  with pesticide regulatory
activities.  The last 6 of those years I  have been responsible for
seeing  that pesticides registered in North Carolina are properly
labeled.  For 3 years I have personally reviewed approximately 5,000
labels  per year.  During this time I would estimate that approximately
15 percent of the labels reviewed were not in compliance with North
Carolina and/or Federal  requirements.

     As those of you involved in label preparation or review will agree,
the job of detecting errors, omissions, inconsistencies, etc., in
pesticide labeling is one of the most undesirable tasks that could be
required of an individual due to the punishing reviews that must be
made to avoid detrimental consequences.  In other words, I do under-
stand how difficult it is for the pesticide industry, the Environmental
Protection Agency, and the States to assure that only pesticides with
proper  labeling reach the marketplace.

     As you are aware, I have been asked  to speak on labeling problems
from a State viewpoint.   Several  of the points that I wish to make
have already been reviewed by Dr. Dewey and some of the other speakers.
Rather than not mention them, I think it  is important that we indicate
that they are also considered problems in the States.  By calling
attention to areas of concern which in my opinion should be corrected
by the Environmental  Protection Agency, I do not wish to imply that
State pesticide regulatory authorities do not have their own problems.

However, the EPA, as the lead pesticide regulatory body, must initiate
additional procedures and guidelines and acquire adequate experienced
personnel to see that problems existing today are corrected.

     One area of concern to me is that the Environmental Protection
Agency has allowed certain pesticides to carry a signal word which
indicates that they are in a category of toxicity higher than is the

     When a user determines that the degree of hazard for such a product
is not as critical as implied, and as a result uses the product with  less
respect  than he would use with a more toxic pesticide, whose label
reflects the appropriate toxicity category, an increased potential for
human illness and even death does exist.  I would, therefore, strongly
urge that the use of the same signal word or symbol for more than one
toxicity category not be allowed.

     Another area which was referred to by Dr. Dewey, which means many
things  and  needs attention, is the method; that is, the signal words
currently used to designate the different categories of pesticide
toxicity.   I know that many of you will agree that to the occasional
pesticide user,  the  signal words, "Caution," "Warning," and maybe even
"Danger" are not significantly different enough to tell the audience
that a  product showing the signal word, "Warning" is considered more
hazardous than the  product labeled with the word, "Caution."

     I  am sure that  each of you will have your own ideas as how this
could be improved.   In my opinion, a change from our present system
is  badly needed.  However, the change should not be made unless a
system  is devised which clearly distinguishes between categories and
can  be  recognized and  understood by the general public, without
requiring extensive  educational background.

     We have one additional problem associated with the use of the
current signal words.  This,  too, was referred to by Dr. Dewey.  In
addition to using them as  signal words, often one of the same words
 is  used as  a heading above precautionary sections of labels   In
many cases  the word used  in this section is different than a different
 signal  word and  this,  of  course, means  that things become very con-
fusing, and very inconsistent.   It  should be corrected.

      One problem,  if not  our  most serious one, is that we don't have
 a standard  format for  pesticide  labels.  I  realize that it would be
 extremely difficult to develop  a  format that will speak to the problems
 associated  with  marketing the pesticides   in various containers   How-
 ever,  we have  a  responsibility  to all  interested parties to have labels
 designed in such a  manner that they  know in  what general portion of the
 label  they  can  expect  to  find specific  information; that is directions
 for use, precautionary statements,  active  ingredient statements
 statement of practical first  aid  measures,  etc.                 '

     I am not inclined to believe that a user should not read the entire
label, but there are times that a user, physician,  or other interested
party should be able to go as directly as possible  to desired information.

     I believe the development of a standard pesticide label  format is
one of our most challenging jobs.

     I would be remiss if I didn't refer to another area of concern.
At the present time many agricultural  pesticides which do not contain
specific directions for aerial application, and which the Environmental
Protection Agency states are intended  for ground use only, are being
applied aerially in many parts of the  country.   Unless it is  made
perfectly clear to the general public—which it has not been—that a
product can be applied aerially only if it contains specific  directions
for aerial use, such labels should specify whether  the product can be
used for ground and/or aerial application.  I am not saying that some
of the products which now do not specify aerial application should not
be registered for such use.  But when  this is done, in my opinion,
additional labeling specifying equipment, nozzles,  pressures, etc.,
should be established when aerial application equivalent is used in
order to reduce pesticide drift to adjacent crops,  areas of environ-
mental concern, and any area that children or humans could be contacted.

     Of course, with such extended uses, there should also be available
data to insure that significantly increased residues do not occur.
Inconsistencies between labels of essentially identical products and
even  inconsistencies on a specific label are also a very real problem.

      For example, a label in the general section will state that "for
airplane application, approximately 3 to 10 gallons of water should be
used  per acre are consistent with crop growth and good coverage."

     While under the directions for a specific crop, some state, "Apply
one-quarter  pound per acre and sufficient water for thorough coverage."

      Gentlemen, thorough coverage can be obtained without adding any
water to the formulation in the opinion of many growers and applicators.
Therefore, the last quoted statement will be interpreted by many growers
and applicators to mean that LV or ULV application is permissible.

     Again,  I must say that I am not against aerial use of some of these
products where data are available to support its use.

     Probably the areas where we in North Carolina find most errors in
EPA-approved labels are incorrect harvest limitation and maximum rates
of application.

     We often find labels that specify that a product may be used closer
to the harvest date than allowed, or at an excessive application rate.

     In addition, we also see many labels that do not contain various
EPA warnings such as precautions regarding incineration of pressurized
pesticide containers.

     The pesticide industry and label  reviewers through the various
published interpretations and the EPA Compendium should be able to
avoid omissions of this nature.

     One additional very real problem is that certain insecticides are
in our opinion no longer efficacious due to insect resistance, and yet
are still registered by EPA.

     For this reason, there must be a system between the States and
the Environmental Protection Agency through which refusal to register
the uses can be initiated at the Federal rather than State level.

      I am aware that a State's determination of the degree of efficacy
is sometimes challenged.  For this reason, I feel that it is important
to review such uses at the  Federal level with input from various interested

      In my  opinion, efficacy data on certain pesticides should be
required at certain intervals rather than only when registered, if
it is  likely that a resistance is developing.

      There  are many other areas of concern to State pesticide regulatory
authorities which cannot be  thoroughly reviewed due to limited time.
Among  these concerns are attractiveness of certain pesticide baits to
pests; cartoon-type characters used on labels which may result in
children being attracted to  the container when not kept out of their
reach; pull-trigger type dispensers which evidently are a temptation
for children to  play with;  level of education required to read and
understand  pesticide labeling; inconsistent use of trade names, common
names, and  chemical names on pesticide labels; occasional illegal
residues being detected  on  certain crops or a different crop the next
year,  even  when  the pesticide was used according to the directions;
concentrated, wettable or soluble powders which are likely to cause
unnecessary dermal  or  inhalation exposure.  Another area of importance
is the updating  of  Section  18.

      There  are many problems which come to light as a result of the
provisions  in  the revised  FIFRA  such as minor crop registration, use
of  pesticides  against  minor crops which are not listed on the pesticide
labels,  and of course, many more.

     Let me say that bringing about proper pesticide labeling is not the
only challenge facing the EPA.  As a result of recent incidents, I
strongly believe that a symposium of this nature is also needed to
discuss pesticide containers, pesticide dispensers, warning agents,
and coloring or discoloring of pesticides.  I can see the same need for
a symposium on mixing and application in that many, if not most, of our
agricultural pesticide incidents or accidents occur during mixing or
application of pesticides.

     At this point, some of you may be saying to yourself that only a
few pesticide incidents or accidents occur in your State each year.
I want to make it perfectly clear that I do not in any way support those
enormous pesticide incident figures we have all seen published so often.

     However, I would challenge each of you to establish an organized
pesticide incident reporting system through physicians in your State.
If reports received are properly investigated, actions can be taken
which are in the best interests of preserving those pesticides so
badly needed.

     I must say that I realize that we at the State level sometimes
create an unnecessary hardship on many manufacturers to market pesticides
in many States.

     For this reason, I feel that the AAPCO should further strengthen
its role in guiding States toward those objectives which are in the
best interests of all concerned.  There should also be even closer
liaison between the States and the Environmental Protection Agency.

     In other words, we at the State level definitely have our short-
comings, but I can honestly say that the action is at the State level
when problems are encountered.  We definitely are much more aware of
local habits, cultural practices, attitudes, abilities, age, education,
and other characteristics of the uses for which each pesticide is intended
and must get involved in the pesticide registration process at the local
level in order to screen out potential problems that cannot be antici-
pated at the Washington or regional level.

     In closing, let me say that I hope my comments today will be taken
only as constructive criticism.  I think that I can truthfully say that
EPA must secure additional experienced manpower if it wishes to correct
currently recognized labeling deficiencies.

     I know that I speak for the States when I say that a vast amount
of experience and assistance is available from the States.  I am also
sure, as a result of my experience with representatives of the pesticide

industry, that they,  too,  are more than willing to share their wealth
of knowledge regarding proper regulatory control of pesticides.

     I have enjoyed speaking  with  you  today, and I do look forward to
the discussion period.

                  Labeling Problems - Private Industry

                           CHANNING E.  JONES
                        National  Sales  Manager
                    Garden and Home Products Division
                 ORTHO Division,  Chevron Chemical  Company

     It is a pleasure for me to participate in this symposium as a member
of private industry.  I guess it is such a pleasure because I am so
involved in the field of garden and home consumer usage and so my remarks
will be mostly directed to that side of the subject.

     Since I am most familiar with my own company and its problems, any
references that I make to ORTHO are not designed as advertising or
promotional activity in this room.

     I am going to mention them to give you some examples of what our
garden and home industry is accomplishing by familiarizing and training
the public in the careful use of pesticides.  Now, ORTHO has no lock on
this activity.  Most companies represented in this room have aggressive
public training programs.  I mention public training  programs because
there simply is not enough room on a label to get the message across.

     Much of today's product label is directed to safety, regulatory,
and industry requirements.  Little room is left to emphasize the facts,
uses, and benefits of the product to the user.  By the fall of this
year our  labels -- and most of the labels of the people represented
in  the room -- will include the following:  the EPA registration number,
the company label number, the product number, the establishment number --
a bad word, establishment — the batch code number, an emergency
telephone number, and a list of chemical ingredients  and technical terms
which the good doctor this morning indicated on one or two of our
labels maybe isn't put on there as clearly as it should be.  There is
an  additional 25 to 30 percent of available space which is used for
sometimes redundant and repetitious warnings and cautions.

     Our  industry has labored diligently to provide product training
and knowledge to all levels in the chain of distribution.  For example,
we put out about eleven million copies of our garden  book a year to
stores all over the country in nine regional editions.  Most of the
companies in here do something similar.  They are full of safety
suggestions, product use information, and articles on environmental

     We have another book -- written by Walter Deedy, a great horti-
culturist.  He used to be the editor of Sunset Magazine, one of the
really beautiful magazines in America.   This book is a classic on how
to grow vegetables; it contains not a thing about ORTHO.  We sold over

700,000 of these.   I  think all  of us  in this room should do more of this.

     We also have  a product manual  which we distribute by the thousands.
All companies put  out one of these, in which they try to get across the
main points that are on our labels.  Every company does that -- for the
clerks in the stores  and for people to take home.  He distribute about
400,000 of these.   In addition  to this, our company has held in excess
of 300 night-time  dealer meetings across the country.  Our guys go out
and work at night  to put these  meetings on.  A hundred or more people
come in.  We buy coffee and donuts  and try to tell them something
about our product.  What we say at these meetings is what is on our labels.
We don't make any  claims beyond that label.

     Anyway, I am just trying to get across to those of you who don't
know that the people dealing with consumers in America, the companies
in this room, are doing a pretty good job of product training to users.
In addition  to the publications, we have about 25 garden films that we
show to garden clubs and anyone else who will let us.  I am sure that
other companies in this room have done the same kind of work.

     What  I  have been leading up to is we have so much important
information  to put on the label that we simply cannot get it on in a
legible way.  Remember, better than 50 percent of all garden and home
pesticide  products are purchased from self-service stores where there
just  aren't  any clerks to tell  you how to use the stuff.

      This,  in itself, indicates that there is not only a need for
additional  educational services, but also simple, clear and concise
language  on  product  labels.  Also  keep in mind that there is a vast
difference between the agricultural consumer and the home gardner.  It
is important that  all of  us  in industry and regulatory officials recognize
the  difference  between agricultural and household pesticides and the
labeling  problems  and the usage.

      First,  let's  consider  the farmer or the agricultural consumer.
 In the  case of  the farmer,  there is no question in his mind as to  the
purpose of his  purchase.  The  use  is  known.  Knowledgeable people  are
 usually available  to assist him  in his selection of the product.   The
reason  for his  purchase  is  economics:  a good crop versus a bad crop or
no crop at all.   There  is  little chance if he reads a pesticide label
that he will use  it  for  a purpose  he  cannot  identify.  For the most part
 he is an  experienced operator.   He knows what results to expect from
 the varying conditions  of use, and the  type of application   The
 agriculturalist,  the farmer, doesn't  have  50 crops in one field    He
 has  one crop as a  rule,  with one or two pest problems.  For example
 he uses guthion for  the  control  of moths on  apples   He uses 2 4 D for
 the control  of  thistle  in his  wheat.   He uses Monitor for the control

of worms in his calves.  He doesn't have the multiplicity of use and
the multiplicity of problems that the average homeowner has.

     Now let's consider the household label.  In many situations, the
homeowners' pest problem is only identified by insect damage such as
holes in leaves.  In an average garden there are often many pest problems
at one time.  As I said before, somewhere in the neighborhood of $300
million is spent annually for pesticides in self-service stores.  In
this case, that label  plus educational material  which we have discussed
become just about everything to the consumer.

     Unlike the agriculturalist whose need is economic, the home gardner
generally purchases a pesticide to satisfy other needs such as cleanli-
ness, freedom from pests, desire for beauty, or just to keep up with the
Joneses.  Certainly no one is anxious to lose plants to pests, but most
important is the appearance of the lawn, the size of the fruit, and the
beauty of the blooms.   That is what the homeowner is after.  Most home
gardners are simply not experts,  detailed technical terminology on
garden home labels cause insecurity — doubt — and a feeling of
aggravation in some cases.  The home and garden user wants and buys
products that cover a multitude of problems.  Many consumers are not
familiar with technical terms and the nature of pest problems.   The
home garden has many different crops, with many different pests.  When
they spray  for aphids on roses, they want to be sure that they
control those aphids.   If there are thrips there, they want to control
thrips and  powdery mildew and the like.  It is appearance and use
that motivate the purchase of a garden chemical.

     There  are distinct differences between the needs of the agri-
culturalist, the farmer, and the homeowner.  Thus, our approach to
labeling must take these differences into consideration.   Instructions
for use must be more general and must be in simple language, in large
type.  Some studies have been undertaken to standardize the colors of
product categories and to regulate print and background color.   Easy
identification and readable instructions should be our goal, but it is
certainly not necessary to destroy or neutralize company and product
identity in order to reach this goal.  What is needed is more room to
work with on the label and greater freedom from the use of words.
Standardized agency language tends to lengthen the copy and discourage
readership of the label.

     To illustrate this, let's consider the warning and caution state-
ments on a popular ornamental spray.  As we go through each point in
this caution statement, it will seem as if it had been passed from one
person to another in the regulatory agencies, each one adding his or
her own thoughts, resulting in the following problems:

     One, repetitious statements and meanings; two, reams of small
print which is hard to read;  and three,  physician information inter-
spersed with consumer information.   This all  results in a discouraging
experience for the user -- if he even takes the time to read the label.

     Many users think cautions are  designed by companies as a protection
against liability; in fact some cautions can  lead to greater exposure.

     Here is a repetitious label:   First:   "May be fatal if swallowed,
inhaled, or absorbed through  the skin."   Second:   "Do not breath the
spray mist."  Third:  "Do not take  internally."  Fourth:  "Hazardous
by skin absorption."  Fifth:   "Do not get in  eyes, on skin, or on

     One label says:  "Use waterproof gloves  and face shield or goggles
when handling concentrate."  This isn't  practical; homeowners don't
possess such equipment.  Further, this label  presents a legal complica-
tion by instructing people to do something which, in fact, is very
difficult to do.  This brings up a  legal complication which falls to
some degree within this category.   First:   "In case of eye contact, flush
immediately with	."  This is an excellent suggestion and should be
there.  Second:  "Wash thoroughly with warm water after using."  This is
an excessive statement in light of  the previous instruction.  Third:
"Wash hands and face before eating."  This is redundant.  Fourth:  "Food
utensils such as tablespoons  should not  be used for food purposes after
use with pesticides."  Fifth:  "Wash clothing with soap and hot water
before  reuse."  This  is excessive unless a spill  occurs.  Such statements
create  doubt and credibility  gap between the company and the user.

     One caution on the label I have never understood is the one that
says:   "Protective information may  be obtained from your cooperative
agriculture extension service."  Protection against what?  Is he going
to give  recommendations that  are not on  the label?  This label is a real
problem.  There is not enough space on the label  for all the registered
uses.   Thus, the statement seems to me as a statement precipitating many
inquiries  from  consumers.  In fact, we do get a lot of inquiries from
consumers  on this.  The answers are extremely difficult.  We have two
people  that do  nothing but answer letters like this.  We try to answer
those  letters,  incidentally,  the same day that we receive them.  Sometimes
our  answer  to the  user has to be disappointing.  It is not always the
way  it  should be.

     The foregoing warnings could have been stated in substantially
fewer words and less  print and less space.  This would make a valuable
contribution  to the  user and leave  some space for good use directions.
In contrast,  the excessive verbiage and many similar statements which'
necessitates  very  small print, destroy the impact of this very important

message.  Much of this problem could be resolved by eliminating the
EPA requirement of designating each species of insect and plant species,
especially on small cans.  Why do we have to name every one to the
gardener?  To him an aphid is an aphid.  We don't need to designate a
green pea aphid.  If it kills, it kills a green pea aphid.  Most of
them wi11.

     Let's get back to reality in pesticide labeling.  Let's work
together, all of us, regulatory agencies, environmental groups,
pesticide manufacturers.  Let's work together and make these golden
rules of labeling.  Let's get the message across in the fewest possible
words, in the simplest language, and in the largest possible print.

     Nobody can argue with me on that.

     We can do this because this is really what the consumer wants and
needs.  So, unlike the presently confused and mystified consumer, these
efforts will make a greater contribution towards a public who wants to
read and they want to understand and they want to follow label instructions.

     I thank you very much.

                   Labeling Problems - User  Group

                         RICHARD E. FLOWERS
                       Flowers and Parker  Farm
                        Tunica, Mississippi

     I  have  been  asked  to discuss pesticide labeling as  seen by farmers.
It is not my purpose merely to criticize either  the chemical industry or
the government's  requirements.  Rather, I'd like to report to you how
I, as a farmer,  look at labeling.  It may be  that many other farmers share
my views; and judging by farmers I've talked  to  about pesticide labeling,
I think many do  share them.

     Also, I'd like to  say  that I do not think the  ultimate answer to
developing better pesticide labels lies in  further  government require-
ments or restrictions.  I  think the American  pesticide industry is
doing a terrific job in producing chemicals for  agriculture, and there
is no reason that private  industry cannot get together with farmers to
improve labels.   If labels  are  to be dictated by government, I greatly
fear that more confusion will  result.

     With these observations  set  out at the beginning ,then, let me
proceed to outline some of my opinions about  how pesticide labeling
could be enhanced for greater utility, safety, and  convenience.

     In our  area, we generally treat our  crops with pesticides according
 to  recommendations of Mississippi  State University  and the Mississippi
 Extension Service.  We get these  recommendations many weeks before
 planting  time and we study them to  decide which  chemicals will be
 needed,  the  quantities we will  need,  and  other  features of our chemical
 use  for  that year.  We do not try to  remember what  rates we applied
 last year or other specific details,  because  our state agricultural
 authorities  may  be relied upon to keep us  up-to-date on the latest
 scientific  information.  Their recommendations  change from season to
 season  to reflect  new  knowledge from their experiments and from  farmer

     We  do  know  which  chemicals we like and the compounds that have
 worked well  for  us  in  the past.

     Then we compare state recommendations with labels to compute our
 dosage rates.  We  know Mississippi State will never  recommend anything
 that is  not allowed on the official label, but we  still read and familiar-
 ize ourselves with pesticide labels, for application  rates  and safety
 precautions. We like  to see the full information  on  antidotes   for
 example,  in case we do have  a chemical accident.   I  personally'do not
 know of a single accident  that posed a serious  danger to  anyone   but we

always treat every chemical with great respect because we know these
chemicals are dangerous.

     Dutch Parker and I are partners in farming operations in the northern
Delta of Mississippi.  He told me when I was preparing this talk that the
most serious accident he could remember in our area was when a neighbor
applied 2, 4-DB to his cotton and that hurt only the cotton.  It did not
pose a hazard to people or the environment.

     One of the reasons I think antidote information should be on every
label is that because so few accidents occur, our physicians usually are
not familiar with antidotes for farm chemicals.  If there ever should be
a serious accident on our place, there might be a dangerous time lag
between taking the victim to the doctor and full treatment while the
physician called around to decide on the best antidote.

     Some chemicals do have good antidote information, as well as
other instructions for treatment in case of accident.   There still are
some needs in this area.

     Another need I see is for clearer and simpler directions for use.
On herbicides, for example, it is universal for rates  to be given by state
extension services and by labels on a broadcast basis, yet most labels
do not specifically point out that per-acre rates are  for broadcast
application.  This is an area of confusion and could be corrected by a
chart that shows how to break down the dose on bands of various widths.
One manufacturer of a popular soybean herbicide does have a chart on
the container showing different row spacings and different band widths,
with dosage conversions.  This is very helpful.

     I think the most important part of a pesticide label is the part
devoted to use instructions.  Even with state extension recommendations
and the chemical maker's dosages, more help is needed  with mixing and
applying.  For instance, a favorite term on many labels is "sufficient
water" to cover a given acreage.  If the label gave examples for ground
rigs and for aerial application, it would be helpful.

     Another area of confusion is the difference between amount of
technical material and amount of formulated product.  A chemical dealer
in .Mississippi tells me farmers call him often to clarify whether a
certain application rate refers to pounds or gallons of branded product
or quantity of technical material.

     Mississippi's official state recommendations are  always given as
pounds technical  material to the acre, but labels are  not usually as
clear.   I think the chemical manufacturer should spell out the exact
dosage,  if necessary giving it both as quantity of his product and

quantity of technical  material.

     Then the various  concentrations  of materials poses further
obstacles to clarity.   In a chemical  dealer's warehouse a few days
ago, I saw for myself  just how the terminology varies on several labels.
I saw about five different concentrations of MSMA from one manufacturer
and in each case, for  that manufacturer, and for all the others I saw,
the actual concentration, given  as pounds technical material, was on
the bottom of the label in very  small  type.

     Competitive considerations  cause some of this problem.  For example,
one maker of a MSMA formulation  may call six-pound material H.C., stand-
ing for "high concentration."  Another may use H.C. for a 6.6 pound
material.  Maybe both  are correct, but it is another source of confusion
for the farmer.

      I suppose most farmers know the initials E.G. stand for emulsifi-
able  concentrate and W.P. stands for wettable powder, but maybe labels
should clarify these.   I recently saw a label on an insecticide we
use on our cotton that said "water miscible."  My dictionary says this
means something that is capable of being mixed, but when I put this
compound  in my spray rig, is it necessary to recirculate it to keep it
suspended, or is it fully soluble?  These are some of the questions
raised by such obscure terms.

      From a scientific standpoint, I assume "miscible" is the only
correct term; otherwise the chemical  maker would have labeled it
concentrate.  Still, the question is raised about exactly what is to  be
done.  Can some of these terms be avoided on labels?  I hope so,
because  I think the average farmer may be more miserable than miscible
with  this kind of chemical jargon.

      Another label I saw was for a DSMA formulation, but the formulator
called  it DMA.  Mow farmers are accustomed to referring to many chemicals
by  the  commonly accepted initials, so when you leave out one letter,
you are  telling the farmer it is something different from DSMA and  this
does  not  help clarity.  On the label, of course, the full chemical
name  was  used, so technically, that compound was not mislabeled, but
nevertheless, it was confusing.

      There are also formulations of MSMA where the name of the product
designates the equivalent concentration of DSMA.  For example  one
herbicide label I saw  just the other day contained the numeral  "12"
in  the  brand.  This means that the particular MSMA formulation  in that
container is equivalent  to 12 pounds of DSMA per gallon.  To me, and
perhaps  to a lot of other farmers, this is confusing.  Maybe some
farmers would rather compute their dosages as if they are treating  with

DSMA, then use the liquid MSMA for greater ease of mixing and application.
But actually, it's probably simpler to compute your arsenical needs in
terms of MSMA to begin with, then use an appropriate concentration of

     I think the concentration should be in big type on the next line
or very near the brand name, in the case of arsenicals and perhaps
other chemicals being produced in various strength levels.  But again,
this is not a matter for law or government, regulations, but an area for
chemical manufacturers and users.

     Type size in general is important, although I realize that so many
things are required on labels that it's difficult to get them all in
and using larger type would increase this problem.  Certainly,, contrast
between the printing and the color of the label is important.  One label
on a popular and very effective cotton insecticide has black lettering
on a dark blue background and it's hard to read.

     One farmer in Tunica County, Mississippi, told me that certain
products packaged in four or more containers within an outer pasteboard
case do not have enough information on the outside of the outer carton.
This means he must open up each case before loading the product onto
his truck, to check labels on the inside containers.   If the label  was
printed on the outside carton., as well as on individual containers
inside, it would enable him to confirm the exact formulation without
opening every case to double-check the contents.

     Another area is in chemical compatibility.  If some chemicals  are
compatible with others and if a mixture is legal, this should be so
stated on the label.  And in cases where other compounds specifically are
not compatible or allowable this should be stated.  I feel that farmers
may be tempted to mix more chemicals than is best for safety of their
crops or the environment if these precautions are not taken.

     I also think the toxicity level of a material should be clearly
stated on the label.  If a compound, like most herbicides, for example,
is relatively less toxic than a phosphate insecticide, this should be
pointed out.  As I said a few minutes ago, we treat all agricultural
chemicals with great respect.  But still, if the actual toxicity is
graded, it would let the user know just which chemical deserves much
greater care and it would avoid the "cry wolf" effect of a blanket

     At this point, I'd like to say that I realize there is only so much
space on a label  and a lot of things to be printed on it, but I am simply
outlining what I  feel  are areas for improvement.  We may not even get all
of them on pesticide labels, but sooner or later3 we must begin to find

the priorities and just leave something off.   Let me continue a few
more observations about pesticide labels.

     Accepted common names,  where they exist, should be used on all
pesticide labels.  I realize firms spend millions of dollars on
advertising and promotion to extol 1  the qualities of their brands, but
still, in the interest of clarity and safety, all labels should show the
common name of the active ingredient in addition to the brand name.  If
a product's primary active chemical  is diuron, it should say diuron,
regardless of the trade name or brand.  And maybe the proper agencies
or organizations can get together and come up with a list of common names,
or initials, to designate a  specific chemical, regardless of brand name
designations.  This would be very helpful  to the farmer.

     Now, I'd like to mention some proposals  I've heard and that I hope
are never carried out.  For  example, I understand it has been proposed
to do away with the skull and crossbones to mean poison.  I think there
was some talk of putting a picture of a snake on some labels.  This would
be doing away with a universally understood symbol  and would take a re-
educational process of many  years to publicize the fact that the snake
picture means poison.

     The skull and crossbones symbol already  is understood by everyone,
including persons who cannot even read and write, and I strongly urge
that this symbol continue to be used with  no  change.

     Another change I've heard discussed and  do not favor is color coding
of pesticide containers to lump all  herbicides together under one color,
all insecticides in another  color, and so  on.   I think this is a bad
idea because all herbicides  are not alike, nor are all  insecticides alike.

     When we need one particular kind of herbicide, that's what we need,
not just any herbicide.  And the same applies to insecticides.   Perhaps
work is needed to develop better color schemes for pesticide containers,
but overall color groups are not the answer,  in my opinion.   It seems
to me such a color code would discourage label reading and make everyone
assume too much when he grabs a pesticide  container and dumps it into
the tank.  The individual brands are distinctive now and I strongly urge
that each company be allowed to design his containers following its own
freedom of expression.

     The same comments also  apply to specific wording.   Sooner or later,
if chemical companies are allowed to evolve their own label  wording
practices, they will come up with directions  and notices in farm language
and many of the problems I have discussed  today will  disappear.

     Even so, I do not think the label is  the place to carry a manufacturer's
advertising message, and by  and large, advertising  now is  at a minimum on

most pesticides.  By the  time  a  farmer gets to  the  label  on  a  pesticide,
you may assume that he's  sold  on the product or he  wouldn't  be reading
the label, so he  should be  the target of  advertising  somewhere before
the label-reading process.

     Extravagant  claims of  performance, for example,  do not  belong on a
label.  It's helpful for  the manufacturer to spell  out the purpose of a
chemical, of course, such as control of certain  weeds or  insects in a
specified crops,  but performance claims belong  in the company's advertise-
ments  rather than on the  label.

     Some of the  problems with labels are slowly being solved  by the
increased tendency toward aerial  application and bulk delivery.  This is
outside the scope of my subject  today, but I think  it's worth  mentioning
that the time may come when farmers rarely see  labels of  certain common
pesticides.  The  bulk dealers  and aerial  applicators will be concerned
with labels and presumably  they  are licensed and otherwised restricted
to  assure competent use of  pesticides.

     In such cases, there may  be a need to distribute safety,  antidote,
and accident treatment information in some other way in case a farm
worker is accidentally exposed to a pesticide during aerial application.

     Some pesticides bear complete information on container disposal  and
others do not.  Certainly,  every label should have  this information.   The
disposal instructions should spell out clearly how  to decontaminate the
container, then how and where  to dispose of it.  I  know local  laws have
a bearing on this, but some disposal information could be included.
Some firms still  do not include  disposal data, though.  Still  others  do
not have enough information.

     One that I saw last week>outlines decontamination procedures
including rinsing with water and  "an alkaline detergent" before
disposing of the  container  in  an  isolated area.  I'm not sure which
detergents are alkaline.  Presumably, some of them  are acid.    In any
case,  the manufacturer could offer more help, it seems to me.  If he
doesn't want to single out any one brand name for detergents, maybe
he  could list several, as the  dishwasher manufacturers do.

     And yet, the official recommendations of the National Agricultural
Chemicals Association outline  a  rinse-and-drain  procedure before container
disposal that does not include the detergent rinse  step.   So what does
the farmer do?  Is it necessary  to use the detergent?  If so, which one?
I  raise these questions to illustrate the decision-making process that
goes on in every  field where powerful  chemicals  are being used.  Farmers
want to practice absolutely maximal  safety.   They are not looking for
shortcuts and I  think their chemical safety record  is proof of their

sincere attitude toward safety.

     I also think it is apparent to many farmers that some of the state-
ments on labels are disclaimers  for the protection of the manufacturer
only.  That's a wise precaution, of course, and I don't blame any
business for trying to protect itself from legal action.  Nevertheless,
if the label is more user-oriented, it will be read more often with
greater understanding and this should help the maker of the chemical,
the user, and the environment.

     I think there has been too  much emphasis on possible misuse of
farm chemicals of all kinds.   As hard as chemicals are to get and as
expensive as they are now, you are a lot more likely to find farmers
using too few and too little  than too many and too much.

     When you are paying many dollars for a gallon or two of a chemical
and it will go only so far, assuming you can find the chemicals you need,
you are not going to double up on the rate.  You are going to read that
label and you are going to check with the county agent and the state
cotton specialist or soybean  specialist until you understand clearly how
much you are supposed to use.  Then you will use only that amount.  And
you are going to use it the right way, because if you don't, you'll  be
throwing money away.  Economic pressure is a good safety incentive.

     To summarize my feelings about pesticide labels, I  believe most
chemicals now are adequately  labeled and I know it will  never be
possible to have every conceivable need covered on any one label.   With
the observations I have made, labels would be more user-oriented and thus,
of more help than presently,  it  seems to me.

     But I think there has been  a lot of progress in a fast-moving field
and I believe the chemical manufacturers are responsive  to the needs of
their customers.  I look for  more improvements in the future.

     I would like to thank the Environmental Protection  Agency for asking
me to share my thoughts with  you and I would like to thank the members
of the chemical industry for  the wonderful chemical  tools  they are
providing for farmers.  I would  not want to be farming today without
these chemical tools and I think this feeling is universal  among farmers
of my area.

     Working together, we can improve pesticides and pesticide labels
to benefit every one concerned.   A lot of people may not think farmers
are as concerned about the environment as they should be,  but the  facts
show that farmers have suffered  very few serious accidents   After all
we not only make our living from healthy soils and environments, but we
live and raise our families in the same local environment  where we
produce our crops.

                 Labeling Problems - Environmental View

                             James P. Rod
                      Assistant to the President
                       National Audubon Society

     Ladies and gentlemen, I am here partially to represent the National
Audubon Society, partially to represent myself, and partially to represent
the environment in general.

     For some of you who may think that we are still little old ladies
in tennis shoes, I can assure you The National Audubon Society has grown
considerably in the last decade.  We now have about 325,000 members in
this country and several hundred overseas.  Most of our members are
organized into better than 320 chapters in cities across the country, and
in 300 affiliated clubs in many other cities across the country.

     It is true that we are one of the oldest and one of the largest
environmental or conservation groups in this country.  It is also true
that we did have our beginnings 75 years ago in the field of bird pro-
tection.  At that time we were interested in protecting egrets and
herons from hunters who killed birds on the nest and used the plumes
to decorate their hats or sold them to millinery companies who sold
the hats with the plumes on them to women.

     Back then there were not many pesticides to worry about, very few
in fact.  Most of the environmental problems that we were concerned
with then were simple.  Someone was shooting egret.  Someone was  doing
this or doing that.  Things were easy to cope with.

     For many years we were interested primarily in bird protection.
Twenty years ago, or even longer ago than that, we began finally  to see
the whole picture of the environment.  It is a world that is good for
birds, and we have discovered it is also going to be a world good for
people and vice versa.

     To that end we broadened our base considerably and broadened the
scope of our educational work throughout the schools and with civic
groups all over the country.

     We have a joint scientific staff that we have established with the
Massachusetts Audubon Society and several people from Johns-Hopkins and
MIT.   The field of pesticides is one in which the National Audubon
Society has been interested for a long time.  Many of our staff people
have done some of the original  work on DDT and some other persistent
pesticides.   We were involved in some of the classical work long before

Rachel Carson published her book in 1962, Silent Spring.   We  are still
engaged—we find it hard to believe—in fights, mostly verbal,  with
some segments of the pesticide industry and some scientists who do not
really see our point of view.   This is fine.   It gives us something to
talk to them about.

     We cannot all  agree on everything.  There are some who  believe even
today that DDT is nearly non-toxic and nearly harmless and doesn't last
for more than a week or two when sprayed or dusted here and  there.

     We have some evidence to  the contrary, but that is beside the point.
We think we know what we are talking about,, at least we hope  we do when
it comes to pesticides.

     It is not amusing to me but interesting  to see these learned people,
scientists, agricultural spokesmen giving a great deal of thought all
day long today and tomorrow to something which, in most cases,  is even
printing on a can.   A $10,000  bill would not  incite this  much interest
among this wide a segment of people all over  the country. Anyway, we
are here to talk about pesticide labels.   More often than not they are
pieces of paper stuck on a can or a bottle or a bag or a  box.  They are
on there for a reason, naturally, to tell  us  what we need to  know when
we want to use the product and what we need to avoid when we  are using
the product.

     We feel, as do many environmental groups, that many  times—far too
often—the pesticide label  is  not fulfilling  the function that  we
believe it should.   I did not  attend all  the  morning session, but I have
been interested in the comments by the speakers this afternoon.   I find,
much to my amazement, that we  are not too far away from many  of the
viewpoints in industry and agriculture.

     That is encouraging.  The preamble to the amended FIFRA  Regulations
makes a point that was not made in the original regulations,  or the pro-
posed rules.  It is a basic problem recognized by the Congress  that,
despite extensive labeling and use instructions, pesticides were being
misused on a large scale.  Some pesticides were being applied at rates
many times the label concentrations to combat insect resistance.   Applica-
tors were being injured by acutely toxic pesticides because they did not
use the prescribed safety measures or misunderstood their proper use.

     Spray tanks which had been filled with pesticides were washed and
indiscriminately drained.  The environment was being unknowingly and
unnecessarily exposed to toxic and persistent chemicals.

     Label regulations simply  were not providing the necessary  control
over some pesticides to prevent their improper use and resultant

 environmental  damage.

     This  is  the point we tried to make all along.  The onus cannot and
 should  not be placed on the label alone.  The label should be and can be
 a  useful tool  for all of us to use when considering the application of
 various pesticides.

     Before going into the label itself—and that will not take long
 because a  good label, as has been pointed out many times here, simply
 should  be  clear and plain and concise and easily readable and say it all
 once and stop there, let me make a remark on something else.

     I was  interested just the other day in reading a magazine ad for a
 new Shell  line of Aerosol Pesticides.  I bring this up because on some
 of the  slides  we saw earlier, we saw the warning "Keep Out of Reach of
 Children."  We know that does not work too well.  There are something
 like 500,000  children poisoned every year in this country in the home,
 not all pesticides, of course—medicines, floor wax, all sorts of things.
 Several thousands of those children die, not because they could not read
 the label, but because the pesticides were within their reach.

     The point is, kids are going to be able to get at these things no
 matter what you do with them.  I get upset when I stroll through a
 department store, as I did this last weekend, and see many pesticides —
 among them chlordane, a very toxic one, in glass bottles with screw
 metal tops any child can open.

     Just  the  fact the label says "Keep Out of the Reach of Children"
 does not mean  they are going to be kept out of the reach of children.
 That is why the advertisement for the Shell Aerosols I saw so impressed
 me.  The Aerosol container has on top of it a completely closed cap.
 The only way  this can be opened is if one slides his fingers up under
 the cap and finally reaches the spray button.

     The point is young children with short fingers cannot reach the
 button.  It is that simple.   You do not have to necessarily keep it out
 of their reach.  Once they get their hands on it, they cannot use it.
 If it is literally impossible for them to open it, or spray it, or spill
 it, or break  it, you do not need to worry about that.   That is why I am
 so distressed when I see so many insecticides and pesticides and
 rodenticides  in glass containers, in metal containers, with easily-
 removed lids,  in plastic bags, or other containers children can open

     It is  fine to have the warning on the label, but we very much would
 like to see more thought given to making the containers childproof to
begin with.  This has been taken up and been fairly successful by the

by the medicine manufacturers.  Aspirin bottles and all sorts of things
these days have lids that are at least difficult for children to remove.
Once they figure it out9 of course, the protection is gone.   If the lid
is impossible for that child to remove until he is 12 years  old, the
problem is nearly solved in itself.

     Another point that bothers me—and I know it bothers many others--
is the fact that, as was pointed out this morning and this afternoon,
better than 50 percent of the pesticide purchases are made in depart-
ment stores and grocery stores, supermarkets, etc.--by homeowners.

     I have noticed in what appears to me to be an alarming  number of
cases that pesticides are on shelves much too close to food  products.
It is very true that many people buy their rose dust and their tomato
dust and this and that in the supermarket.   I think that the pesticides,
and in fact all these dangerously toxic chemicals, should be in a section
of the supermarket—say between the light bulbs and the dust mops and a
long way from the food.

     Maybe we could even go a step further to surround the shelves with
the display of all  the garden chemicals with a red ribbon or something
and maybe even a poison sign.  Maybe that is overstating the case for
insecticides.  But I believe these things should not be near the food.
They should not be easily accessible to children.   Many times in the
grocery store, bottles of chlordane—right  on the bottom shelf--will
be found in eight ounce, twelve ounce, and  sixteen ounce bottles.
They can easily be broken in the aisle or opened up by a child.

     While we are in the supermarket and on the subject of labels, I
want to mention two other things, "Right Guard Deodorant" and "Ivory
Liquid Dish Washing Detergent."  I was in Texas about six months ago
looking at rattlesnake roundups.  During part of the snake show, some
of the people wandered around spraying the  rattlesnakes with  "Right
Guard Deodorant" -- spraying them very heavily in  the faces.   They
claimed they did this for a couple of reasons.   One, they said this
deadens the heat sensory bite of the rattlesnake so it is not too apt to
strike, and two, it just plain calms them down.   Well, if you read the
label  on the back of the "Right Guard" container,  it says, "Intentional
Misuse Can Be Fatal  or Harmful."  These snakes were being poisoned to
one degree or another.  The point is that this same warning  is found on
many pesticide labels:  "May Be Fatal.  May Be Harmful  if such and such
is done."

     I think we have subjected the consumer to this warning  so often
and so many times before that he may not pay as  much attention to it
on the pesticide as  he should.   We will  all  agree  chlordane  in liquid
form is probably more toxic and dangerous than "Right Guard  Geodorant."

     If we are going to agree that many of these insecticides are so
toxic that the warning, "May be Fatal, May be Harmful," is not enough,
then, conversely, we may say, "So What?  My underarm deodorant says the
same thing.  I don't know anybody who has died from that."

     Why can't we say on the label, "This Product May Kill You."  Put it
in great big red letters, and then go on to say,  "Or it Certainly May
Make You Very 111 If You Don't Follow These Directions Below Explicitly."

     These things can kill  people.  If we say you will be killed or you
may very well be killed, instead of — you might be harmed if you do not
use this just exactly right, we might get the point across.

     I said I wanted to mention "Ivory Liquid Detergent."  One of our
Audubon people about a month ago phoned me and told me with  considerable
interest that she had discovered "Ivory Liquid Dishwashing Detergent" --
in the little plastic spray, bottles -- to be one of the most potent and
effective insecticides she had ever run across.   There are no labels,
of course, cautioning us not to misuse "Ivory Liquid Detergent."  She
discovered spraying or dripping this right out of the bottle onto insects
of many kinds, and spiders, too, causes them to die -- just  like that --
they do not squirm or wiggle or keel over or wander off.  It is instant.
I did not believe her.  I tried it myself.  By golly, it worked.  It
works faster than most insecticides I have sprayed on insects.   I don't
know why it works.   I don't know what is in "Ivory Detergent,"  but by
golly, it is an insecticide.

     John Dingell has made a point this afternoon about the  symbol  on the
insecticide label.   I believe, myself, that the skull and crossbones is
a good symbol and should stay as the symbol.   I  do not think the rattle-
snake or any other snake ought to be the subject of a symbol.   I happen
to like snakes.   That is just one of the reasons.

     John Dingell has suggested going a step further.  This  indicates
one of the basic problems with the pesticide label:   the same label has
to be read and understood by a wide segment of the people all  around the
country or even outside the country.  There are greatly varying levels
of either idiocy or sophistication, depending upon the person reading this
label.   I think that the label has to be comprehensible to the lowest
common demoninator among the possible users.   Many people buy these
products that are,  frankly, illiterate.  Many people that can read are
not well-educated and do not get as much useful  information  from a label
as they should.

     John Dingell has suggested additional labels, additional symbols.
For example, a dead fish, or a dead bird next to the skull and crossbones,
or a stream or lake or a pond with a big red X through it.  Maybe this

will help get the point across in addition to spelling out on the
label that birds or other non-target species may be killed.   The
skull and crossbones is the useful, easily understood symbol.  It
could well be that most people would associate a dead bird or a dead
fish with a red X through It with a skull and crossbones and think,
Gee, maybe I had better read this more carefully, if, indeed that
pesticide is that toxic.

     I want to comment briefly on some of the comments made this
afternoon.  Dr. Wells said that standard labels should contain
standard use rules.  The labels must be standardized, some way, some-
how.  Maybe the entire label can be standardized; but some of the useful
information on the label has to be standardized.

     Mr. Flowers made the statement then that he believed that the govern-
ment interference with the label and with the wording on the label is
just going to lead to further confusion.  Me will all admit that is true
in many fields of the federal government.  But, in this particular
instance, we are going to have to standardize the label.  We are going
to have to do it through symposia like this, through input from many
varied groups and individuals and consumers who can get together and
study proposals and eventually communicate these warnings the same way
all the time.

     Mr. Jones, whose vegetable book I have been using in my garden for
sometime—incidentally, it is a dandy one—mentioned training the public
in the proper use of these pesticides.  I think that is a good point.
He is the one that made the point that 50 percent of the people or more
buy their pesticides in supermarkets, garden centers, or drugstores,
and really do not know how to use them or they don't pay enough attention
to the label.

     We are all bad label  readers.   How many people knew "Right Guard
was harmful or fatal?  Not very many.

     I do wish to take exception to a couple of points Mr.  Jones made.
He is worried about repetition and redundancy on the label.   It is better
to have repetition and redundancy than to take the risk of not informing
the consumer.  It may be that saying something twice or three times will
simply turn people off; but we have always thought at National  Audubon,
if it is worth saying, it is certainly worth repeating.   Some of these
warnings are not meant to be taken'lightly.   They are serious warnings.
If people stumble across essentially the same warning two or three times
as they read through a label, maybe it will  stick in their minds.

     The very commendable statement on a label:   "No Adverse Effect on
the Environment," is an oversimplification because, even we  at National
Audubon Society know, as all of you do, there is going to be some

adverse effect on the environment no matter what insecticide you use.
We are never going to achieve any pesticide or rodenticide or fungicide
or insecticide or any other kind of a "cide" that has no adverse effect
on the environment.

     It is written into the federal regulations that we want to minimize
the risk of adverse environmental impact, but we are never going to
eliminate it completely.  The National Audubon Society has long had a
reputation of compromise if the benefits far outweigh the unavoidable
environmental bad effects.  We will go along with it.  We always have.
We have been inviting wool growers out west for years on coyote control.
We do not say don't kill coyotes.  We say, let us not poison them all.
If there is an individual coyote doing damage, let's kill it, and kill
it humanely.  The same thing is true of pesticides.   We recognize they
are necessary.  They always will be.  There are going to be some adverse
environmental effects.  We just don't want avoidable adverse effects.

     Mr. Flowers mentioned that economic incentive is a good safety
measure.  I am not so sure I agree with that.

     It is true that in many cases when people pay good money for
pesticides, especially when buying them in bulk, they usually will
not overapply them.   If you have a thousand acre farm and this stuff
costs you a few hundred dollars, you are going to put it on as thinly
as possible to do the job.

     On the other hand, I'm afraid many private individual  consumers
look at their rose dust or their tomato dust or their aphid killer  and
say, "Gee, a teaspoonful does not sound like much, maybe I  had better
use a half of a bottle.  This costs 69 cents; if a little bit is good,
a lot is better."  I  don't think there that we have  the economic
incentive we might have in agriculture.   We have to  be careful about
application rates on  the label.

     Dr.  Wells mentioned the most crucial communication of all is to
the user.   We have to agree with that.

     Mr.  Buffalo says he has reviewed around five thousand labels a
year.   That is a lot  more than I have ever looked at.  I think that's
a lot more than anyone in the National Audubon Society has ever looked
at.  We agree there  are far too many inconsistencies and problems with
the pesticide label  throughout the market.   Mr. Buffalo also believes
that EPA is going to  have to tighten up their guidelines.  We agree
with that, also.

     I  have in front  of me some  comments made by our staff.  It was
asserted by industry  that adequate labeling would take care of the

problem.  Although labeling is currently inadequate in many cases,
improved labeling, we believe, will not solve the problems associated
with misuse, overuse and accidents; skill and knowledge, not labels,
prevent accidents.  Certainly, certification of applicators was
intended by FEPCA to assure high standards in the responsibility of
those applicators having access to those dangerous pesticides.

     We want to say it again, if it is worth saying, it is worth saying
more than once.  The onus should not be on the label.  It must not be on
the label.  The label is and can be a useful tool and should be viewed
as a useful tool.  We think that all necessary information should be
on the label in clear,, readable plain English -- and perhaps in some
other languages, too, if there is room on the label for it.  If there
is not, let us look into this business of more symbols:  The skull and
crossbones is good but perhaps some others will  be equally effective.
At least people might see those if they don't take the time to read
the entire label.

     The warning or caution on the pesticide label should include not
only the hazard to human health or the potential hazard to human health
but the potential hazard to non-target wildlife.

     As you well know, there are many pesticides and insecticides on the
market today, and some that are no longer so widely used, such as DDT,
that do not have any target species.  They will  kill everything, or
nearly everything.  They will  disrupt or disarrange breeding cycles of
a lot of other things, even if they don't kill  it.

     We have to be very careful  about non-target species.  I disagree
that all the target species should not be listed on the label.  They
should be.  The consumer should be instructed to use the insecticide
only for those species that are his targets, and should additionally be
aware that many non-target species might be affected.

     Our concern is with the safety of the general public just as much
as it is with the safety of the general  environment, because the
general public is part of the environment.

     We believe there has not yet been a study  of how the general public,
including farmers as well as other heavy users,  actually use pesticide
labels.  Has anybody done a study on how people  use the label  or what
they do with it, or how much attention they do  pay to it and what it all
means to them?  This is a prerequisite for deciding what will  have to
go on the label.  No matter how good that label  is, if the people don't
read it, and won't read it, it is no good to us  or them or the industry
or anybody else.  It has got to be read.

      We  have  been  talking  about overuse and misuse of pesticides.  There
 is  a  strange  phenomenon  that  has been discussed and explored by many
 people,  that  is, using pesticides in lower than recommended dosages.
 This  is  often necessary  in coordinated pesticide control programs and

      The draft regulations say that use of any pesticide in a manner in-
 consistent with its labeling  shall not be permitted.  That means that
 you can't put it on in any less quantity than recommended; it means
 you can't overuse  it, too.

      This is  actually a problem.  It may not sound like one, but it is.
 The question  of whether an integrated pest manager can legally recommend
 use of pesticides  at lower application rates than are called for on the
 label was raised by Dr. Rosemary Von Runker at the meeting of the
 Hazardous Materials Advisory  Committee.  EPA officials present at the
 meeting were  unable to answer the question to the satisfaction of Dr.
 Von Runker and the rest of the committee.  This was noted in the
 Pesticide Chemical News.   As  far as I know, that particular controversy
 hasn't been resolved.  Is it  legal to use less than the prescribed
 dosage?  Apparently, it is not.  What will happen if people do?

      I want to talk about one other thing while we are talking about non-
 target wildlife.   We were talking about snakes a few minutes ago.   In the
 mail  from the Texas Audubon people I received a little flyer on snake stock.
 This  is a reptilicide, one of the first and maybe the only one that has
 ever  come on  the market.   I talked to some of the EPA people over the
 break and none of  them have ever heard of it.   It is certainly not

      It is manufactured in Odessa, Texas.   It not only repels  snakes and
 all other reptiles but kills them on contact.   This stuff is to be
 trickled around your camp site or sprinkled around the garage to keep
 snakes, presumably venomous snakes off the premises.   It not only repels
 snakes; it kills them on  contact.   If you know anything about cold
 blooded vertebrates, snakes in particular, you know they are hard to kill.
 They  don't succumb to a lot of things that would quickly do in a warm
 blooded animal.  I  don't  know what is in this  reptilicide.   The little
 picture on the xerox copy I have is too blurred for me to read the
 active ingredients.  Never once in this flyer do they mention poisonous
 snakes or venomous snakes.   They say it is harmless to children and pets,
 guaranteed as  completely  effective as a repellant and a reptilicide against
 snakes of any  size or variety.

      I don't want to get  into the ecological  ramifications of snake use-
 fulness,  but in most areas  of the country it is recognized that venomous
snakes are not much of a  problem at all.   On the contrary,  the useful
species,  which far outnumber venomous snakes,  are very useful*

     This stuff, when you sprinkle it around your dairy, your stables,
and everywhere else they recommend, will solve what was until now a
constant problem with snakes.  How many of you farmers and homeowners
have had a constant problem with snakes and need this?  I told you I
spent a few months in Texas a few months ago looking at the rattlesnake
problem.  Some Texans will admit it is not all that bad.  Let me mention
that I was near Webb Air Force Base.  There have been more people
killed in Howard County, Texas in the last 15 years from airplane
crashes between light planes and sand hill cranes than have been killed
by snakebite.

     Jim Dewey of New York said this morning that few people actually
read the Iabels3 and if we need a reappraisal of what we are going to
use the label for, Dr.  Dewey made a good argument for using the label
again as a useful tool.  It cannot be the only answer.  Many of the
problems that we now face and will continue to face—problems of
accidents and misuse—will be eliminated when the restricted use
pesticides will be applied only by certified applicators and/or with
specific regulatory restrictions, which we don't have now.

     General  use pesticides ought to be only those which are generally
and genuinely safe to use in the home and around the home,  given the
current pattern of misuse in most household uses of pesticides.   Not
everybody uses even the general  use, fairly low toxicity pesticides the
way they should.

     This we  believe is going to be the best way to solve many of the
problems that have been brought out today.   If we can get certified
applicators to use the  restricted use pesticides and make sure the only
pesticides that get into the hands of the housewife are the general
use pesticides and -- all  those are equipped with easily readable,
distinct, legible labels—we will all  be a long way ahead.

     Thank you.

                     ALVIN S. SCHECHTER - PRESIDENT
                          SCHECHTER & LUTH,  INC.

     I am president of Schechter & Luth of New York City.   Although  some
of the publicity for the symposium you may have seen described  my company
as an advertising agency, I must tell  you we are not.   Rather,  Schechter
& Luth is a communications design firm.  By that, I mean that we  specialize
in developing basic concepts for telling people what products are, product
names, communications strategies, and package design,   We  are also deeply
involved in other areas of marketing communication, such as corporate
identity, corporate image, trademarks, logo  types,  and  so  on.  As a  result,
my discussion will  deal with the advertising and marketing view of pesti-
cide labeling, rather than the advertising agencies'  view of this subject.

     From looking at the program for the last day,  I  guess that we are
somewhat unique in this program in that most people are concerned with
those aspects of labeling which tell  you how not, when  not and  why not
to use a product.  We are hopefully going to be talking about motivations
on why to use and buy the product.

     While Schechter & Luth has grown up on  the consumer side of  the
business, our viewpoint as marketing men has also been  shaped by  our
exposures to companies on the industrial  side.   These clients include
such household names as Exxon and Eli  Lilly.  On the  consumer side,
Johnson Wax, and Warner-Lambert are among our clients.   So we have a
foot in each camp through exposure to the marketing,  packaging, and
label problems in both the industrial  and consumer  sectors.

     In our presentation today, I will  attempt  to focus on issues
which pertain to both sectors, although we may  use  one  or  another
examples to make our points.   I understand you  are  a  very  diverse
audience consisting of both corporate marketing people, and regulators
from a variety of governmental agencies.   What  I  will have to say will
pertain to both groups, although from by background it  should be  clear
that I represent a marketing point of view.

     As marketing and government people, it  comes as  no revelation to
you that your functions are often at odds with  one  another.   This is
typically the case today where the role of government in many walks
of life is increasingly regulatory in nature.

     In the pesticides industry, which has its  own  special  problems,
there is a particular sensitivity when government and industry  find
themselves in conflict.  From the marketing  viewpoint,  pesticides
are unique in that the problems they pose can be approached, dealt
with, but never resolved.

     Misused, these products are extremely dangerous to both humans  and
the environment, and how an individual product performs is highly depend-
ent upon factors such as application, the skill of the user, how the
product is diluted or mixed, the equipment used to distribute it, and
so on.

     With performance, the vital factor to the farmer, the manufacturer
is constantly under pressure from ever-increasing competition.  As more
and more new products are developed, packaged^ and introduced, the oppor-
tunity to formulate unique broad spectrum products is sharply reduced.
More and more competing products are taking on a parity with one another.
That is more or less similar to the consumer marketing field.  The result
is increasing the importance of the marketing function.

     The proliferation of products is no doubt confusing to the farmer  who
is bombarded with a seemingly endless array of advertising messages in  his
specialty publications.  In this competitive situation, some manufacturers
may feel justified in minimizing risks and emphasizing benefits in their
packaging and promotion.

     Regulatory agencies may feel  this situation calls for tighter controls.
Government and users are both; concerned with how the label can be planned
and regulated to minimize risks of misapplication.  Both want to eliminate
misrepresentation and human hazard.

     The government's prime objectives we think, is to eliminate risk.
On the other hand, the marketing man wants his label  to sell his product
and to help protect his position in the marketplace.   Clearly, there must
be a certain amount of natural  antagonism between these two points of view.

     These conflicting objectives  go right to the heart of this country's
distribution system.  This is,  of course, not a new problem.  It is sur-
prising that this symposium on  pesticide labeling is the first of its
kind.  Ideally, such meetings should have begun years ago and should be
held on a regular basis.  The fact that we are here today is encouraging,
and so we have the opportunity  to  jointly air problems and see if we can
find adequate solutions.

     In my view, you have to start considering these problems long before
you get to the design of a label.   For example, as a producer, how do you
begin to develop a basis for a  sound business philosophy which will  produce
results that will be good for both the environment and your company? With-
out such a philosophy and the resultant business strategy, it is difficult
to be innovative, let alone creative.  This is where a company like ours
often enters the picture as marketing communications people.

     Here are some key elements in developing a sound business philosophy
we have worked out for some of  our clients.   First, identify with the
market, be it the farmer, housewife, or institution.   Know the users'

 viewpoint.   Be  aware  that being  in this industry involves a  long-term
 commitment.   As  such, your  company must have the resources necessary
 to meet  extensive  product development and testing costs.  This, un-
 fortunately,  but necessarily, eliminates the small operator.  Second,
 you must be  dedicated to product innovation, even though this is in-
 creasingly difficult.  By definition, innovation and uniqueness are
 rare  and can  almost never be achieved unless there is dedication to
 excel.   Of course, the more nearly unique your product, the more you
 can afford to have it stand alone.  As the few unique products diminish
 in number, there is an increasing tendency to promote the corporate
 image.   Third, be creative.  These factors have to be boldly communicated;
 this  can  be accomplished best and most efficiently and at lowest unit
 cost  through  the creative function.

      Now, what should the communications strategy be in reaching your
 audience?  One method is through unique product names.   Spectracide,
 for example, attempts to convey a suggestive marketing message through
 both  the  name itself and the graphics surrounding the name.   Lasso is
 a colloquialism with no specific meaning.   Newer products with names in
 this  vein are Mowdown, Prefox, Prowl, and Roundup.   There tend to be
 a lot of  sound-alikes around a successful  product.

     These new names are so new that they have yet to establish
 franchises for themselves, although they have the potential  to
 accomplish this, given sufficient promotional support.   They are
 typical of the new type of name being increasingly used as  the
 suggestive names have been exhausted and the acronyms become
 increasingly confusing.

     These acronyms, or coin names, are the most difficult  and con-
 fusing kinds of names for the farmer.  According to a recent article
 in "Successful Farming," here are acronyms of a few insecticides  which
 are either new or have been approved for new or changed application:
 Disiston, Diphonate, Furadan, Pencap, Temic.   The same  article lists
 these new herbicides:   Basal in, Basagran,  Cobex, Igran, Kersh,  Crenite,
 Lexon, Rotate Sunitol, Surflan, and Rolban.   Probably at least 90 percent
 of all such names cannot be distinguished  by the farmer from other
 similar sounding names.   Paradoxically,  however, two of the  most  success-
 ful names in marketing in this industry  are Treflan and Aatrex,  both

     Another factor in the proliferation of new names bombarding  the
 user stems from variations in changes in the formulation of  this
product.   Like a look at this ad for Lasso,  and this  ad for  Lasso-2.
While, as we said before, Lasso is  a good  example of a  colloquial  name,
Lasso-2 is a different product, a new granular formulation.   The  farmer
can't help but be confused by the way the  package presents  this

     This leads us to another aspect of the communications  strategy,
the use of the corporate endorsement as a means of gaining  user  in-
tention and recognition.  If new product names are meaningless until
they establish their own franchises, they can be helped over their
hurdles by relating to the export name.  As such, we can expect
greater use of corporate names and corporate enforcements in the
future in this industry.

     To effectively accomplish a corporate enforcement the  producer
has at his disposal first the trademark, which might be suggestive of
high technology, or product characteristic; and secondly, his trade
dress or common look which when applied to his product serves to extend
the confidence of the corporation of that product.  If you  take  the
famous Shell mark, commonly associated with this multi-national  corpora-
tion's gas stations, and apply it to agricultural products'  packaging,
this would convey to the farmer that the product has the backing of
a major international company.

     Earlier I mentioned the Exxon Chemical  Company.  That  program
established a format for the presentation of agricultural chemicals
packaging, using the elements just discussed.   We utilized  a system
in that program for identifying types of pesticides and complete
formal standards for identifying labels in many, many communities
around the world.  Standards such as were established; we recommend
as increasingly appropriate for the industry as a whole.  To be  sure
that there are no misunderstanding or misconception of these standards,
they do not mean rubber stamp conformity.  In  no way would  a competitor's
product have to adhere to similar standards that would reduce all  products
to look-alikes.  We are really referring to standards that  have  to do
with the caution and hazard information.

     On the subject of standardization,, let's  come forcefully to grips
with the natural antagonism between marketing  and regulatory objectives.
Ours is a highly individual competitive universe wherein  each product
is striving for recognition.  With truly unique products  increasingly
rare, any element of distinctiveness is indeed a plus.   Such an  element
can be a unique name, or a unique color and package format,  or a unique
advertising concept.  It's been suggested also that certain  colors be
standardized throughout the industry to identify specific pesticides.
If this were to happen, it would reduce the corporate impression,  and
such a development would, in our view, be unreasonable and  unnecessary
regulation, unless of course, the standard colors for the particular
statement happen to be your corporate colors.

     Standardization which serves to curtail any basic marketing tool
has got to be a hindrance to marketing objectives.   This  is  the  point
in which the interests of the regulatory man and the marketing man
clash.  Each should understand the other's position.   As  regulation
has long been a part of this industry, it remains for those  of use in

to somehow establish a unique and memorable product image within this
regulated market.

     For regulation is not on the wane obviously.   Rather regulation
is growing more stringent with the passage of time.  Each new require-
ment by a regulatory agency further reduces our options.   In the past,
the military used this method to systematically remove individuality
when it was deemed necessary that sameness prevail.  There are those
who would no doubt like to see the same situation  prevail in our

     The regulatory position in the case of human  drugs is well-known.
Medicine should be marketed under generic names.  Perhaps the chief
governmental  advocate of this school  of thought concerning the drug
industry is Senator Nelson of Wisconsin, who has proposed before the
Kennedy Committee hearings that all prescription drug advertising for
doctors be outlawed.   Well, today's meeting is obviously  not the proper
forum for discussion  of this issue.  But it may be instructive to con-
sider pesticides for  a moment from a  similar viewpoint.  The crux of the
matter as it pertains to this industry is whether  pesticide product
packaging should have any marketing function at all.

     We believe it can be demonstrated that there  are some compelling
reasons why pesticide labels should have a marketing  function and why
it is in the interests of everybody here to protect that  function.
In our society, that  is in terms of what the world as our consumers,
both industrial and retail, perceive  it, the unique trade dress of
a label helps to establish the function of the product in the users
mind.  It is expected of products which are from different sources
are expected to look  different.  As pesticides vary considerably as
to the purpose and methods of applications, customers need all  the
guidance they can get.  In this regard, the marketing functions serves
to communicate also the corporate identity of the  producer, expressed
through his trademark or corporate house mark.  This  represents both
security and responsibility.  It serves the good guys who have built
marketing equities over the long-term and stands to enhance their
position through immediate recognition of their products  by the farmer.
This, of course, is basic to the trademark way of  doing things.  By
denying the marketing function, regulators restrict the producer by
preventing him from achieving the rewards that would  accrue to him
from product quality  and history of responsibility.  Keep in mind
that such a restriction would also affect the farmer  who  makes a
commitment and feels  that he makes a  relationship  every time he buys
a pesticide.

     How then can marketing and regulation be meshed  so that free
enterprises and safety both prevail?   As a marketer,  I propose an
approach that leaves  the marketing man with most of his available

options intact while improving the communication of the hazards  and
risks to a point which should more than satisfy the regulatory posi-
tion.  It is a solution where if neither side wins, no one has to
surrender unconditionally.  From the marketing man's standpoint, it
recognizes the inevitability of recognition.   Our proposal simply
gives recognition to the grave concern expressed in all quarters
about the caution statements which must appear on our labels.   Let
these caution statements be completely described so that there is
no latitude whatever for diluting the warning and thus giving  the
appearance that one product is less dangerous or more safe than another.
In other words, let's remove the handling of  caution statements or hazard
statements from an area of competitiveness between companies.

     This is what has been done in the cigarette industry with a great
deal of simplicity.  It's on a very simplistic basis.  The problems
presented to the cigarette industry, as one that works within  that
industry, are relatively simply compared to the pesticide industry.
I do propose that ground rules call  for a bolder standardized  statement
of risks.  This reduction of options for the  statement of caution would
eliminate the possibility of making one product appear more safe than
another by perhaps reduced sizes, color contrast, etc., in that area.

     Such mandatory controls will serve to add greater clarity to these
statements.  They will  be in keeping with the recent court ruling which
held, according to Business Week Magazine, that -- I quote --  "standard
of clarity, applicable to a package label, is not what it says to the
reasonable consumer, but what it says to the  ignorant, the unthinking,
and credulous."

     For better communication and clarity, we also propose the introduc-
tion of verbal symbols  for human caution and  environmental caution which
it can be clearly demonstrated that, the skull  and crossbones  has a long
history of being a key to making people focus on that attention.  There
are somewhat less frightening symbols, which  would make,  we think, the
applier and user, be it the farmer,  farm helper, the applicator, or the
housewife take a look and understand where to look.   Such symbols will
better focus user attention on text, which can also be standardized as
to location, size, sequence, and even language.   They may also play a
role relative to federal  interagency discussions in which a need has
been expressed for an agreement, on uniformity of labeling between the
agencies concerning tests used to develop safety and language  statements.

     In making his proposal, we would like to offer a caution  of our
own to the EPA.   When new rules are promulgated, it should be  done with
greater sensitivity than has been shown in the past by some regulatory
agencies, particularly with regard to the design function.  Otherwise
the label could be unecessarily damaged from  a marketing  standpoint.
We certainly hope that would not be the result of our recommendations
today.  It is imperative that the integrity of the basic  trade dress

of the package be maintained during the process of standardizing the
hazards' statements.  Let me add quickly that no more than this area
of the label should be standardized.  The other elements such as trade-
mark, format, colors, topography, should be left free of any constraints
subject only to marketing needs and objectives.  A good example of  this
is color.  We feel that color could easily be flexible to allow for
adherence or conformity with a given company's trade style.   There  are
a.certain amount of people that are colorbind in any case, so that  color
should not be a key to this kind of statement.

     If this proposal  should eventually be adopted, the marketing function
would be allowed free creative rein to work with trademark,  colors, names,
and topography to develop labels that communicate successfully, yet
minimize use and misapplication.  This means that good communications
would be the result.

                   Improving Label  Communications

                           RUDY N.  SALCEDO
                   Department of City Development
                          City of Milwaukee

     I will depart slightly from my prepared text today because after
hearing the presentations yesterday, I  decided to modify my text.   I
didn't want to overkill  some points.

     I would like to thank the Environmental Protection Agency for
inviting me to participate in this  symposium today.   Pesticide labeling
is a field of great interest to me.  As many of you  know, I have
accepted an appointment as the environmental scientist for the City
of Milwaukee.   My interest includes an  interest in the quality of  life,
noise levels,  air quality., water quality.   I can say that our goal  today
is the preservation and protection  of human lives.

     I will start my presentation with  one basic premise, and that is
in the end we  are writing pesticide labels for the pesticide user.
Let's keep that in mind.   We want him to know how to use the pesticide

     With that premise in minds I will  present and interpret some
findings of our study on  improving  the  communication adequacy of
pesticide labels sponsored by the Pesticide Regulation Division, U. S.
Department of Agriculture, in 1968.  Please remember that the data I
am presenting  to you will be at least four years old.   I will share
with you some  of the rationale that went into the study we conducted.
I will also present a lesson in typography.   Dr.  Evans, who worked with
us very closely on the four-year study, will present the second phase
of our study on motivating pesticide users to read pesticide labels as
sponsored by the EPA.  We are both  grateful  for the  opportunity to be
able to be associated with this research project.  We received
tremendous cooperation from the pesticide  industry and our sponsors.

     I would guess that when you hear the  term "pesticide label,"
many of you will think of your own  respective organization's pesticide
labels.   That  is expected.

     Since there were thirty-seven  thousand registered pesticide labels
at the time of our study, we decided to describe what we thought was
the average pesticide label.  We systematically selected a random
sample of pesticide labels from the thirty-seven thousand and wrote
for those labels, either  through the USDA, or directly to the industry.
We received very good cooperation.

      I will present to you some characteristics of what we found
was the average mode of pesticide labels.  I think this is a unique
study.  To our knowledge, no study of this kind existed at that time.
I don't know whether such a study has been done since.

     Now, what does the average pesticide label look like?  In
terms of physical size, the average pesticide label is smaller than
eight and a half inches by eleven inches.  The labels we studied
ranged in size from two inches by two and a half inches -- that small --
to thirty-seven and a half inches by thirty-two inches.  You can guess
that is a fertilizer sack with some insecticide! properties.   Of
course, the rest of the labels are between those two extremes.   The
average pesticide label has 487 words printed on it.  If a speed reader
reads them, it would take him one minute to read them.  A speed reader
reads about six hundred words a minute.  The shortest label  had twenty-
one words, while the longest label had two thousand three hundred
words.  Again, divided by four hundred or six hundred, it would be
about four or six minutes depending upon how fast one reads.   The
longest label  had 2, 195 words of cautions and directions in  its infor-

     Those examples indicate the great diversity and sizes among pesticide
labels.  This  information is important because the Act, FIFRA,  requires
certain minimums in terms of label contents and how the label  informa-
tion should be printed.

     Think:  Two and a half inches by two9 compared with thirty-seven
and a half inches by thirty-two inches.

     The average pesticide label was fairly difficult to read.   It had
a reading ease score of 57.03, which means that it was good  only for
people with at least 10 to 12.9 years of formal  education.  In  1971,
this comprised sixty-seven percent of the U.  S.  population.   The
reading score, of course, is an index determined by word length and
sentence length.  In general, the longer the sentence, the less under-
standable it is and the more complex it is.

     While we  strongly recommend that label  writers test readability
of their labels, there are many shorthand readability formulas  available,
and it does not matter which formula is used because the results of the
readability tests are normally highly correlated.

     Interpretation Number Seven of the regulations for the  enforcement
of the Act says that the directions for use must be stated in terms
which can be easily read and understood by the average person likely to
use the pesticide.   Given diversity of the pesticide labels,  it would

be safe to say that not all of the more than thirty-seven thousand
pesticide labels we had at that time were addressed to the same types
of individuals.  Hence, we must ask ourselves the question:   What are
the characteristics of the average person most likely to use our pesti-
cides?  In other words, who are we communicating with?  This may sound
academic to you, but it really has some practical implications.  I will
come back to this point later.

     Now, how legible must the average pesticide label be?  Different
people have defined the term legibility many different ways.  Among the
terms are speed of reading., following directions, comprehension, and
preference.  There are many factors that influence the legibility of
print.  For example3 type size, indentation of paragraphs, color of
print and background, and type form.

     We compared the average pesticide label  against the legibility
standards that we found in our research and/or review of literature.
Here is what we learned:  First, one-point leading -- the difference
between lines of print -- was the norm3 thirty percent, for cautions
and directions for use.  Another twenty percent were solid with no
leading at all.  Our review of literature indicated that two-point
leading was best for most type sizes.   One-point leading is  no better
than when there is no leading at all.   A large number of pesticide
labels can improve on leading.  Second., the small words, "Caution,"
"Danger," "Poison," and "Warning," in the front label  were generally
written in type sizes that were legible,, 80.5 or larger.  Third,
twenty-three percent of the headings, that is, directions for use, were
printed in ten-point type.  This type is acceptable.   However, sixteen
percent of the headings or directions for use, were printed  in 7.5 or
smaller.   Thirty percent of the texts of directions for use  were printed
in seven-point type or smaller.  Five labels  had texts smaller than 6.5.
According to legibility studies, six-point type is highly illegible
and eight-point type should be the smallest type size allowable.

     Among the three type sizes that we discussed and studied, that is,
six point, eight point, and eleven point, readers definitely favored
eleven point type.  Six point type was least  preferred by our readers.
Other studies have long shown this, and what  we did was provide further
support to that long known fact.  When we deviate from eleven point type,
therefore, let us realize that we are cutting out the legibility.   Eighty
percent of the labels did not indent paragraphs.   Legibility studies
indicated that paragraphs should be indented  for increased legibility.
Of course, there is a modification of savings.   When  we indent paragraphs;
we tend to use fewer words.

      Black  print  on white background was the color combination on  all
 elements  of the pesticide label.  This combination has a very good
 brightness  contrast.  Our review of literature indicated that bright-
 ness  contrast  between background is the most important factor when  it
 comes  to  color, and that the greater the brightness contrast between
 print  and background, the more legible the text.  We recommend dark
 prints on light background.  There are some good color combinations
 such  as blue on yellow, green on white, red on white, and others.  We
 should avoid combinations such as violet on blue, red on green, and
 white on  black.   I won't comment on export colors at this time.  It
 might be  possible that color combinations might be attached to trade
 name or company name or something like that.  As I said,, violet on
 blue, red on green, and white on black have poor brightness contrasts.
 Hence they  have poor legibility.

      If editorial considerations demand that words be printed in small
 type, printed  in  red, red is the attention color.  It may be effective
 to use bolder  type to focus attention on key words like caution, danger,
 directions, and dosages or application rates, such as pounds, pints,
 times a day, and  so on.  The requirement of printing poison, danger
 and the skull  and crossbones in red and all caps on contrasting back-
 grounds for highly toxic pesticides appears to have solid empirical

     The  skull and crossbones on chemical  labels, because of their
 extensive usage through the years, have come close to being the
 traditional  symbols for highly toxic pesticides.   Let us  consider this
 before we replace them with other symbols  that have yet to  be tested.
 I know there are many symbols being considered to replace the skull
 and crossbones.  Let us be careful.  We would have much learning  or un-
 learning  and reeducating to do if we replaced the skull  and crossbones
 now; unless  more reliable evidence is presented showing a better
 alternative, we should continue using the  skull and crossbones.   This
 point was made by a gentleman yesterday, Mr.  Flowers.

     In summary, special  attention must be given to type  size,  leading,
 indentation  of paragraphs, color combinations of print and  background,
 and type  form  in improving the legibility  of pesticide labels.  The
 specific  type sizes, leading, et cetera, which  I've mentioned,  should
 be viewed as guides and suggestions.   They are  not recommendations  on
 th'is point.   Based on what we have learned, we  should also  study  the
 problem of label  size, but since our research was not addressed to  that,
we cannot reasonably recommend that as  a direction for work.   Instead,
 it might be  a good idea to study from the  standpoint of benefit-cost
 analysis.   What do we gain and what do  we  lose?  In the end,  how  do
we stand?

     Our laboratory experiments on legibility also show that the label
most rapidly read was not the most preferred nor the best understood.
There was a time when many people thought that the label that was most
rapidly read was the most preferred and best understood label.  Our
research did not show that.   Therefore,, we should choose one definition
of legibility, and I suggest that we define legibility of pesticide labels
in terms of label preference.  Label preference is partially influenced
by such factors as type size, heading,  color combinations, and so on.

     If we do that, we won't separate the physical attributes of the
label from the human factors.  Our preoccupation with legibility is due
to our interest in seeing that the literate reader is able to read the
label.  Let us help him see  clearly what he is supposed to read.  We
should also present him with a label that he would want to read.

     How understandable is the pesticide label terminology?  We also
studied readers' comprehension of fifty label  terms.   We found in our
systematic random sample that farmers in Champaign County, Illinois,
comprehended most label terms.   Our conclusion that pesticide label
terminology was easy to understand was  contrary to the conclusion
reached by two earlier studies of essentially  the same terms.  Most of
the studies, including ours,, came out with somewhat similar statistics
on the proportion of respondents who understood the specific terms.  The
difference was the interpretation of those terms,   I  think we were
more relaxed on this point.   However2 it is fair to say that the
comprehension of pesticide label terms  should  not be  taken for granted.

     For example, while most label terms were  easy to understand, the
following terms were very difficult, to  understand:  germs, herbicide,
controls, fungicide, systemic insecticides and inhalation of mist.
Each of these terms were understood by  at most fifty  percent of our
sample; the lowest was twenty-eight percent.   At this point, a word of
caution:   There is a strong  temptation  to search for  substitute words
and phrases for the terms that are difficult to understand.   The word
"hazardous" has been substituted for "dangerous."   Some people may
understand the term "hazardous" but not "dangerous."   Then again, other
people may understand the term "dangerous" but not the word "hazardous."
The point is that it is very difficult  to find many words that every-
body can understand.

     Accepting this, we devised a different approach  with this rationale.
We know that there are people who scored very  well on the pesticide label
terminology tests, and that  other people scored very  poorly on the same
tests.   Our next step, therefore3 was to identify these groups who
scored high or low in this test.  To guide our research we asked
ourselves what factors influenced our readers'  ability to comprehend

pesticide  label terms.  The first is education.  The other is attitude
toward the pesticide  label.

     The relationship we found is that the higher one's education and
the more favorable his attitudes toward the pesticide label, the more
likely he will score  highly in the pesticide label terminology test.

     Knowing this, we could modify the question about the questions we
asked earlier.  Remember, we asked with whom we were communicating.
Now we could ask what were the educational characteristics and the
attitudes toward the  pesticide label of the average person most likely
to use our brand?  Those are very important questions.   I am suggesting
that if your pesticide user was highly educated and had favorable
attitudes toward pesticide labels, perhaps you don't need to worry
that much about the ability to understand the pesticide label.   The
likelihood of their reading and understanding the pesticide label  is
relatively great.   Conversely, the chances of their having pesticide
accidents will be relatively small.   Remember, however, that I  said
perhaps we should worry very much if our pesticide users are less
educated and have very unfavorable attitudes toward the pesticide

     I  have confined my comments to the label communications, partly
because what we researched is graphics or non-verbal  communications in
labels.  I strongly suggest that the pesticide industry and the
Environmental Protection Agency look seriously at this.

     Non-verbal symbols may be a helpful  procedure for  communicating
with illiterate, less educated, or non-English-speaking pesticide
users.   There are thousands of people in  this category.   I know
this from  a study done by Penn State University, bearing Jim Benin's
and John Ritch's name.  I think this kind of study is a step in  the
right direction, but I think we are a long way from the last word  in
the matter.  In fact, I don't even think  we are close and we should
continue our studies.

     I  said earlier that we write labels  for the users.   What do our
readers say about the pesticide labels?  As part of our study we also
asked our respondents to react to a number of statements about  the
pesticide label.  Here are some of the results:  First,  forty-five
percent of the city residents and thirty-nine percent of the farmers
agreed  with the statement, "The cautions  and directions  on pesticide
labels  are written in such small type that one needs  a  magnifying  glass
to read them."  Second, thirty-eight percent of the city residents
and thirty-four percent of the farmers agreed with the  statement,  "The

pesticide label is designed mainly to sell or advertise the product."
Third, forty percent of the city residents and thirty-seven percent
of the farmers disagreed with the statement, "The pesticide label
contains all the precautions and directions one needs to know in using
the pesticide safely."  Next, forty-six percent of the city residents
and forty-five percent of the farmers agreed with the statement,
"Pesticide labels contain many scientific terms that are difficult to
understand."  Last, forty-five percent of the city residents and thirty-
seven percent of the farmers agreed with the statement, "Pesticide
labels put too much emphasis on brand names and too little emphasis
on cautions and directions for use."

     Gentlemen, I am not saying these statements  are true.   But I am
reporting what these respondents of ours agreed with.   To them, those
things are true.  Many actual and potential pesticide users have
unfavorable attitudes toward the pesticide label.   The lesson, I think,
is that we may make the best label  very legible and very understandable,
and still come up short, because the users may not read the label.
We realize that even the best people can only do  so much.   Other routes
of consumer education should be used in communicating  safety methods
to pesticide users.   This is where  Dr.  Evans1  report will  begin.

     I thank you.

                 Improving Label Reading Via Motivation

                           JAMES F. EVANS
              Department of Agricultural Communications
                       University of Illinois
     Good morning.

     We have the label and its potentials.  We have goals of public
welfare.  We have goals of marketing and goals of the user of pesti-
cides.  How do they fit fogether?

     The experience I will talk about seems to dovetail nicely with
some suggestions yesterday about moving beyond the label itself and
our disucssion this morning about innovative marketing communications.
This label may be complete and accurate, easy to read, and understand;
but even the best label cannot communicate unless and until it is read.
Under actual conditions, the pesticide label is still at the mercy of
the user.  Many persons do not read labels on the pesticides they use.
That fact has been documented by a number of studies, and probably the
experience of each of us.

     Sometimes the conditions do not encourage label  reading, even if
the user is inclined to do so.  These facts of life lead us to look
outside the label for ways to stimulate readership as a means of pro-
moting safe and effective use of pesticides.  We did  so in two steps
during 1970 to 1972.

     First, we asked what is being done now to encourage the reading of
pesticide labels?  Who is trying?  To what audiences  are these efforts
aimed?  By what communications media?  With what persuasive appeals?
Second, we asked how effective are these efforts?

     We approached the first question about what is being done through
several related efforts.   We conducted a nation-wide  search for communi-
cation materials that encouraged pesticide label  reading.  That search
resulted in locating 496 printed pieces from public and private agencies
dating back to 1957, plus 143 electronic pieces,  information pieces,
from public and private agencies.  These are films, slides, and other
electronic types of communication.

     In addition, we analyzed the content of pesticide advertisements
in four selected magazines.   The question was this:  "To what extent do
pesticide marketers use their advertisements in popular magazines to
encourage label  reading?"  The magazines in this  judgment sample
included Better Homes and Gardens, and American Home, both of which, of

course, are urban oriented, and Farm Journal and Progressive Farmer,
both rural oriented magazines.  We analyzed all issues of the four
magazines from 1968 to 1970.

     This is what those studies revealed.   The greater burden in
promoting the safe use of pesticides was being borne by various
educational and public agencies.  More than half of the printed materials
were from public sources.  More than ninety percent of the electronic
materials were from public sources.

     Of the 639 communication materials that we analyzed seventy-eight
percent were in printed form.  These were  articles and logos, advertising
pieces, posters, balloons, bulletins, staffers, folders, exhibit materials,
sales, and technical brochures.  The rest  were films,  tapes, disks, and

     Most of the printed materials were aimed at the professional
audience, including farmers and other commercial  users.   On the other
hand, most of the electronic  pieces  were aimed at the  nonprofessionals,
the homemakers, the weekend gardners, and  other non-commercial  users.

     Seventy-one percent of the printed pieces had either positive or
negative appeals to encourage label  reading.   Others used no appeal
except advertising.

     Our earlier review of literature had  indicated that the statement,
"Read the label," that is, the unsupported imperative  statement alone,
is not sufficient to influence attitudes or behavior.

     Among the printed pieces, the most often used positive appeal  was
to safety.  Twenty-seven percent of  the printed pieces  appealed to safety.

     The appeal  to economy or profit through  the  proper  use of  pesticides
ranged next, twenty-one percent, followed  by  appeals to  good health and
freedom from injury, totaling fourteen percent.   Environmental  contamina-
tion as a negative appeal  accounted  for only  ten  percent.

     The electronic items or  pieces  that we looked at  emphasized many
of the same positive appeals, and often in combinations:   Good  health,
clean environment, and economy.   Profit got less  emphasis  in the electronic
materials used than in the printed materials  used.   The  electronic
materials used negative appeals concentrated  on combinations involving
death, injury, contamination, and financial  loss.   Ninety-two percent
of the printed pieces  told the individual  reader  to protect himself
from pesticide accidents.   Very few  of the appeals  included the protection
of family members, friends, pets, or similar  value to  others.

      Our review of literature  suggested  that  it  is  fruitful  and  helpful
 to  include  many references  to  appeals.   The electronic  items we  looked
 at  were  more  inclined  to  do so.  About sixty  percent  of the  electronic
 materials included appeals  to  protect other people, or  pets, or  the

      In  advertisement,  pesticide marketers made  limited use  of their
 space  in the  four  magazines  to encourage  label reading.  Only one out of
 three  pesticide advertisements encouraged pesticide label reading.  Only
 two percent of  the words  used  in these advertisements mentioned  label
 reading, about  seventeen  hundered words  out of a total  of nearly more than
 seventy-two thousand.   Advertisers used  smaller  type  to encourage label
 reading than  to promote the  product.  The largest type  size of the body
 copy of the pesticide  ads in this sample was  usually  eighteen point.
 The smallest  was usually  eight-point.  On the other hand, the largest
 type size of  the read-the-label messages in these ads was usually ten-
 point  and the smallest  was  usually six-point.

     Let me summarize  briefly  our recommendations connected with these
 content analyses.   First, a  joint interest involving a  larger industry
 role can increase  the  total  amount of attention devoted  to encouraging
 pesticide users  to  read the  label and follow the directions.   The level
 of  information  effort  found  in this study seemed modest  in relation  to
 the scope and importance  of  pesticide use.  Second, urban residents
 should be primary  audiences  of pesticide education programs,,  because
 they stand to profit most from such campaigns.  Third, messages  to
 encourage pesticide label  reading should contain active appeals,  negative
 or  positive,  and in combinations.  Fourth, appeals should be  directed
 not only to the  individual  readers but also to those others  they  value.
 Fifth, public and  private agencies concerned with pesticide  safety should
 consider using  interpersonal communication through local groups,  for
 example, as well as efforts  through the mass media to  encourage  pesticide
 label   reading.

     Moving then to the second question I asked at the beginning:  Will
 it work?  That was  the next question.  It was vitally  important,  it
 seemed to us, and  a question that would be difficult to answer,  because
 if our proposals had any merit for those who might spend thousands of
 dollars to try, they should stand up under trial.  Our decision  then  was
 to set up such  a trial, a formal  field experiment.

     Here is how it worked:   A one-month mass  communication  campaign  was
 conducted in Quincy, Illinois, to improve audience knowledge  of  and
 attitudes toward the pesticide label  and the safe use  of pesticides.
The City of Decatur, Illinois was the matched control  community,  where
 no information campaign was conducted.   Interviews  in  both communities
 before and after the campaign determined what effects, if any, the
 campaign had in terms of audience knowledge and attitudes.

     Our previous research, plus a review of guidelines for information
campaign funding directed our efforts in the test community.   Television,
radio, newspapers, and direct mail  were the channels of communication
that we used in the campaign, which took place during May 1972.   Local
stations and newspapers donated time and space as a public service.   The
cooperative extension service was identified as the source of this

     The central theme selected for the campaign was a slogan:  "Take
a Look and Live."  It appeared not in the headlines, but as a tag line
in all of the pieces.  Two complete news articles were published by  the
local daily newspaper during the month of the test.  In addition, five
public service advertisements appeared in the same papers.  The two
local television stations used a set of four, one-minute television
public service announcements.  Usage on these television spots totaled
eighty showings, according to the logs, or roughly three a day during
the campaign.  Three local radio stations in the community used the  set
of four one-minute public service spots which actually were the sound
tracks from these TV spots.  The usage of those totaled one hundred
forty-two airings, or roughly five a day.  Direct mail pieces went to
all heads of households in Quincy at one-week intervals during the month.

     You can anticipate some of our campaign goals.  We wanted to inform
the audience about specific dangers of misusing pesticides, to inform the
audience about three important elements of the pesticide label,  the
directions for use, cautions, and ingredients statement, and the functions
of each, and to develop favorable attitudes toward the pesticide label
and the safe use of pesticides.

     How did we measure results?  Five dependent variables were  used to
measure possible effects of the campaign.  Two of these variables involved
levels of knowledge; one of which we called general knowledge, or knowledge
that most people would have had regardless of the information in the
campaign.  Other questions tested knowledge that the audiences could
answer correctly only if they were exposed to this particular campaign.
Then we used three kinds of attitude variables:  One measured changes
in attitudes about the use of pesticides, the second measured attitudes
about the safe use of pesticides, and the third measured attitudes
toward the pesticide label itself.

     Our dependent variable involved behavioral intentions of citizens;
specifically, we asked respondents to state how they have used or intend
to use the information from this campaign.

     In our pre-test, we expected no significant differences  between
the two communities in any of these variables.  However, on the post-
test, we expected the Decatur community to show no significant change

 in any of  the  variables; however, we espected the Quincy community to
 show  significant changes in campaign-based knowledge, in attitudes
 towards  the pesticide label, in attitudes towards the safe use of
 pesticides, and in behavioral intentions.  Beyond that, we expected
 post-test  measures in Quincy, the test community, to exceed those in
 the control community.

      This  is what happened.

      Before the campaign, the respondents from Decatur and Quincy did
 not differ in  the dependent variables which we measured.  This was
 expected.  After the campaign, one-fourth of the post-test respondents
 in Quincy  had  been exposed to the information campaign.

      We  observed significant differences between respondents of the pre-
 test  and the post-test persons interviewed in Quincy, the test community.
 The post-test  group in Quincy had higher average scores in campaign
 specific knowledge, in attitudes towards the pesticide label, and
 attitudes  towards the safe use of pesticides than did their pre-test
 counterparts in the same community.  These were part of the critical
 results.   They were expected.  On the other hand, we observed no
 difference between the pre-test and post-test measures in our control
 community. Decatur.  This was also expected.

      How about differences between post-test measures in the two cities?
 Quincy showed  higher scores than did Decatur in campaign-based knowledge
 and behavioral intentions, which was expected.   No other differences
were  observed  between the two groups.

      In summary, let me return to the question that sparked this effort:
 "Will  it work?"  The answer in our opinion is:   "Yes, it can."  Efforts
 to encourage label reading and the safe use of pesticides can work if
we are aggressive enough.  We can make headway in our shared goals if we
 apply what we  know now about pesticide users and about effective
 communications methods.   We see no signs of insurmountable psychological
 barriers in this method.  Money is a limiting factor, but probably not
 the key factor.  You probably would be surprised at the low level of
budget involved in the preparation of this educational material.  The
 key in our judgment rather is commitment:  the willingness to set goals,
work  together, use solid guidelines wherever we can find them, and tap
 the wealth of  ideas and resources available among all of us who care
 about the safe and effective use of pesticides.

     Thank you.


                     THE HONORABLE MARK ANDREWS
            Congressional Representative - North Dakota

     Thank you.  It is certainly good to be with you this morning.

     As many of you know, I am a farmer who comes from a small town in
North Dakota called Mapleton.   Back in the '30s when things were tough,
things were so bad that we could only have one rat in our city dump,
and he had to go to a neighboring town called Casselton to get his meal.

     Bringing that up as background, I would like to visit with you for
a few minutes the way a member of Congress, who sits on the committee
funding the Environmental Protection Agency, and all the consumer
functions of our government, as well as the Department of Agriculture,
sees it at this particular point in time.

     Of course, it is a pleasure for me to speak to all of you on this
subject of pesticide labeling.  As you know, in the hearings before
our subcommittee, I have attempted to examine some of the problems
in the pesticide area.  I certainly hope that in yesterday's and today's
sessions you have had and will have the same opportunity.

     When Congress passed the  1972 amendments to the Federal Insecticide,
Fungicide and Rodenticide Act, one of the most important changes was
making it unlawful for any person to use any registered pesticide in a
manner inconsistent with its labeling.

     Because of this provision, the label  now becomes the cornerstone
of the regulatory process, and Congress intended that labeling be that
cornerstone.  We certainly need an effective and strong labeling program
in order to assure the safe and effective use of pesticides in our
environment.  In order to accomplish the goal of safe pesticide use,
proper regulation and consumer attention to label instructions must be
utilized, but caution in regulation is also needed.

     It doesn't make much sense for EPA to ban a pesticide for
agricultural application when  the only misuse or accidents caused by
the pesticide is from consumer application of the pesticide in the
aerosol spray cans obtained from the corner grocery stores.

     Industry often fails to provide for noticeable, informative and
effective labeling for the housewife on the small aerosol spray cans.
In my judgment more protection and stronger regulations are needed for
the consumer who uses very limited amounts of pesticides, but where
there is a maximum amount of danger to exposure.

      If this is not done, fanners and professional applicators who need
 large volumes of pesticides to control insects and disease will have to
 pay the price because of a few consumer mistakes that could have been
 corrected by both government and industry action in providing proper

     As a farmer, I cannot underscore enough the need for farmers to
have all of the available pesticide tools so that he can minimize crop
damage and control  the insects, weeds, plant diseases, rodents, and
other pests.

     Advantages to livestock producers, of course, are also important.
But in addition to agriculture, we have to remember the pesticide
benefits to preservers of our forests and park lands, as well as house-
wives who need pesticides to control beetles, ants, and other bugs.

     With more than 32,000 pesticide products made from one or more  of
900 chemical compounds that are currently registered by the EPA, it  is
natural  that there are increased risks and hazards in the use of pesti-
cides by government, consumers, industry, and agriculture.  These risks
to human health and the environment certainly dictate a stringent
government pesticide program, so we can insure a strong and a safe

     But this responsibility and strong feeling that most people have
to preserve our environment must be pursued reasonably.

     The EPA has to be careful  that it doesn't over regulate and over-
control  our farm producers when attempting to minimize the risks and
hazards of using pesticides.

     Noone wants to go back to a wormy apple; noone wants to see the
cost of production go up and up.  But increased production costs will
continue if effective and safe pesticides are not available.

     Before slapping extensive and over-reaching re-entry standards,
protective clothing standards, and certification standards for appli-
cation on our Nation's farmers, the EPA would do well  to note the first
and most avid environmentalists this country ever had were farmers.

     Long before the environmental movement in this country began,
farmers were protecting our soil by planting tree belts and grassways
in coulees.  The track record of the Soil Conservation Service in the
Department of Agriculture and their efforts in this area speak for

     Actually, I myself am a third-generation fanner on the same land
that my grandfather started out on in the territorial days of Dakota.
Our son, who is now married and living in a trailer house on the same
land, will be the fourth generation.

     As farmers, my son and I want to make sure that we haven't adversely
affected our land and that the fields are indeed more fertile and better,
and that we have the wildlife that we need to support.

     One of the pride and joys of my  son's life is the fact that we have
12 or 13 deer that happen to live and browse on a river that goes through
our land.  Ne planted more trees and  provided more pasture and grazing
land to take care of these deer, and  the ducks and the prairie chickens.
We also hope a few pheasants will begin to become re-established.

     So farmers are environmentalists.  However, in order for this
country to benefit from their environmental experience, the farmers
must have an input and communication  avenue into the decision making
process of the agency that is regulating their activities.  Otherwise,
the farmer-grower will be placed in such a situation that his operations
and ability to function on a daily basis are hindered.

     In addition, the fanner has to have an understanding of these
programs and the need for them, in order for these programs to work.
You can have all the labels in the world, but if the fanner feels that
the labels are a bunch of "hocus-pocus", dreamed up by a group of
impractical theorists some place in the dark of night and then put on
a can, the response to those labels isn't going to be all that good.

     In other words, if we are to have an effective regulation program,
we have to have the understanding and the comprehension of the people
who are regulated.  They have to feel they are being given a fair shake.

     It is fine, of course, to include trade groups, the pesticide
industry, and the environmental interest groups, but you must include
the actual user.  How many farmers were consulted on the proposed regu-
lations?  And I mean real farmers who know the practicality of a proposal?
How many commercial applicators who live with the need for a sensible
and safe use of pesticides on a day-by-day basis were contacted?

     This problem of communication between the agency proposing the
regulations and the persons who are going to be regulated doesn't
just include the farmer.  It includes all of us, whether we represent
the State or the Federal government,  industry, environmental groups,
or agriculture.

      What we need is frank  communication  between  the  opposing,  if you
 want to use that word,  or the varied  interests, if you would  rather use
 that word.

      As a Congressman,  I  am often put in  a position of a middleman and
 I  am dismayed by the  lack of candor sometimes on  all  sides.

      Industry is  reluctant to attack the  problem  head-on because  they
 fear retaliation  by the governing agencies or a destruction of  their
 working  relationship.

     This type of attitude accomplishes nothing,  and  I urge government
 and  industry to  lay their chips on the table and  resolve their  differ-
 ences now before  the  actual  users are placed in even more emergency
 situations than  they  now face.

     There are many experiences which we  can and must learn from.   Take,
 for  instance, the herbicide 2,4,5,T, which was used for preservation  of
 our  rangeland and forest lands.  Because  of a deficient manufacturing
 process, some batches of this herbicide produced by industry contained
 the  contaminant  tetra-dioxin in large amounts, which was teratogenic
 in nature.

     Now what do you  do?  Do you suspend  the chemical  immediately?  Do
you  take the 2,4,5,T, away from the people being asked by this Nation
 and  by the consumer of this  Nation to produce more beef?

     Industry certainly was  wrong by not clearing up its manufacturing
 process and making sure our environment and health care were not harmed.

     But EPA only compounded the problem by jumping in and initiating
 cancellation proceedings that are still  underway.  They are now conducting
 an exploratory hearing, as you know.

     Meanwhile,  industry claims they have cleaned up their manufacturing
 process whereby  1/10  of one  ppm of tetra-dioxin is present in  2,4,5,T,
which is in line with the President's Advisory Committee Report  on this

     The point I  am trying to make is that we now have an action-
 reaction situation that would have been handled better if EPA  had
 contacted industry and said  "Clean up your manufacturing process,  not
 only in the case  of making 2,4,5,T, but in the case of many other  chemicals."
 If they found dioxin  in 2,4,5,T, what have they found  in MCP or  2-4-D or
 any  of the other chemicals now on the shelf that are being used?

     Why cancel a herbicide if the problem isn't the uerbicide itself but
rather a contaminant resulting from deficient manufacturing?  These are
the questions that I think need to be answered.

     Besides the communications problem, the EPA also has to streamline
their procedures so that labeling and registration applications are
handled much more expeditiously.   Delays and bureaucratic red tape
facing developers seem insurmountable.

     A more expeditious labeling clearing procedure is needed for several

     First, newer and more effective pesticides  to meet additional demands
won't be developed if delays in clearance are not eliminated.

     One industry source I have had contact with indicated it would now
take from 3 to 4 years to obtain the required data needed to register a
label for the chemical endovan, or SD-29761, which is used to control
wild oats in wheat.

     This particular chemical, endovan,  is already being used in several
foreign countries, including our good Canadian neighbor to the north.
If it is registered abroad, why can't data developed in its foreign
application be used here for domestic clearance?

     Although it is true that producers  of endovan have not yet applied
with EPA for registration, action taken  recently by our executive branch
of government doesn't protect our consumer—that's for sure.   By this I
mean the decision to lift Canadian wheat import  quotas.

     Supposedly, endovan poses too many  threats  for use in our country,
but then we open up the gate and allow wheat to  come in through the
border because millers were saying that  bread was going up to a dollar
a loaf.

     The lifting of quotas has resulted  in millions of bushels of
imported wheat, some of which was treated by endovan while grown in
Canada, being able to reach our American Consumers.

     So now we have the American consumer eating flour produced from
wheat that has been treated with endovan.  As you know, you can only
have it one way or the other.  If we are going to protect the consumer
from so-called dangerous pesticides—then lets stop food products
produced in other countries that contain residue levels of these
dangerous chemicals from reaching our nation's consumers.

      If we don't have a strong enough case to do that, then maybe we  ought
 to take alook at how we can expedite clearance of these new chemicals  so
 that facers  and agHcu?tural operators have the ability to produce food
 more efficiently and  cheaper.

      Our  bureaucratic red tape discouraging us from using endovan for
 another three  to four years will  result in farmers  seeing a large part
 of  their  crops destroyed by wild  oats.

     This is not the only example.   My  own experience in attempting to
clear other pesticides has  been equally frustrating.   Although data have
existed for one type of grain or  one form of product, EPA officials
maintain this  data can't be used  on similar grains  because of varying
residues levels.

     Toxaphene is a good example  of this  problem.

     Toxaphene is a relatively  safe chemical.   Certainly safer than some
of the others  that are used.   Toxaphene has been cleared on food corn,
which is about as direct from the field to the consumer as you can get.

     But toxaphene has never been cleared for use on  sunflowers.  And
as you know, sunflowers go  through a long process whereby they are
squeezed into oil.  Finally, this sunflower oil  reaches the ultimate
consumer but by a much longer process than corn.  Certainly, if the
chemical is safe on cannery corn, it ought to be safe on sunflowers.

     The answer we receive from manufacturers is that they do not apply
for the registration of toxaphene on sunflowers  because it costs too
much to produce the data on sunflowers  when compared  with company profits
accruing from the use of toxaphene on minor crops such as sunflowers.

     Now, if we are going to be able to protect our environment and
encourage farmers to use safer chemicals, we have to  have some method
that will  result in the registration of chemicals on  minor crops that
have already been tested and cleared for major crops.  What can be done
to eliminate the enormous expense and capital needed  by industry to
register pesticides?

     Maybe a system whereby government  paid for the laboratory and
data gathering costs and industry in turn rebated to the government
a certain percentage of the product marketed is a feasible solution.

     Not only would this result in uniformity ot testing and laboratory
procedures, but  it would also lead to increased availability of chemicals
for minor crops—crops that industry now doesn't spend time on due to the
lack of potential profit to be gained subsequent to registration.

     In addition, substitute pesticides that have been cleared to take
the place of pesticides that have been banned could be thoroughly studied
and analyzed so that minimal adverse environmental  impact occurs.  For
example, the substitute for banned DDT is parathion—a chemical  that not
only kills insects, but also the birds, rabbits, and other wild game.
The result in many cases is that we are forced to rely on more damaging
pesticides than need be.

     More effective pesticides for major crops are  also needed.   Using
endovan as an example again, industry estimated that it would take
$1 million to $3 million to develop the necessary data for performance,
residues, toxicology and effects on the environment.  With such huge
investments of capital  needed to register, Congress should start con-
sidering ways to help finance clearing of new pesticides.

     I would be most interested in your comments on a government rebate
system on registration of pesticides.  If we can encourage development
by making registration easier, faster, and cheaper, we have probably
served the taxpayers and consumers far better.

     No matter what type of decision is made, one thing is clear:  We
must expedite our registration process, expand the  data base and con-
solidate data used on similar plant species so that industry can develop
new effective pesticides.  Otherwise, we will have  situations like we
had in North Dakota where toxaphene was given an emergency clearance
for control of thistle caterpillars on sunflowers.   After the thistle
caterpillers were taken care of, sunflower beetles  began causing problems
in sunflowers.

     Since toxaphene wasn't cleared for sunflower beetles, sunflower
farmers were placed in a dilemma.   But lo and behold, someone told
these farmers that if you find a thistle caterpillar in your fields,
you can legally use toxaphene again.   And then,  perhaps by some  accident,
the sunflower beetles would incidentally be killed  in the process of
killing that one thistle caterpillar.

     Other reasons why we must expedite this labeling process deals
directly with our food supply.  Because of rising food prices and
decreased grain reserves, farmers  are being asked to produce record
food crops.

     If farmers don't have the necessary pesticides to maintain  an
increased crop production, this goal  can't be accomplished and no
doubt unfair criticism will be directed at farmers  for not provid-
ing huge supplies of food products for consumers.

     However, it should be noted that an expeditious labeling pro-
cedure resulting in an increased food supply also has a direct benefit
on this country's international problems.

     Let's look for a minute at farm exports and their favorable result
in the balance of trade.  Last year $19 billion of farm exports  bailed
this nation out of a balance of payments.

     Everybody knows about the energy crisis.   Everybody knows what
happened to the price of gasoline and the availability and the price
of fuel oil.

     Everybody should know that when they increased the price of crude
landed on our coasts, they created a whale of an impact on our balance
of payments problem.  I think people ought to take a look at the unique
bonus agriculture gave.  Our agricultural  exports increased last year
by nine and three-tenths billion dollars.   This more than offset the
$7.5 billion deficit by trade in non-agricultural products—things like
foreign cars, televisions and everything else we import from abroad to
maintain our high standard of living.

     In talking about agriculture, you are not just talking about the
five percent of the Nation that are farmers.  You are talking about
the ability to bring in the fuel that means jobs and industry, that
means maintaining the petrochemical industry we have built up, and
that means giving us our high standard of living in America.

     This matter is far too important to just deal  with casually.  For
the first time since 1970 the U.S. has had a favorable balance of trade.
I think we have to recognize that food can win a whale of a lot  more
friends for this nation than all the atomic weaponry and other govern-
ment junkets  that have occurred in this country.

     I found  this out ten or eleven years  ago in Latin America.

     You remember the news headlines at that time.   They were pitching
rotten eggs and all kinds of vegetables at Robert Kennedy.   Latin
Americans were even more hostile to Americans in the small  towns where
my wife and I were visiting.

     But I soon found out that once it was learned that I was a  farmer,
the leaders of the various villages and towns gave us the red carpet

     Why were they our friends?  Because they respected our country's
agricultural  productivity.

     I think it is time all of us realize that the God-given ability
to produce food is the key to better understanding in a smaller  and
more complex world in which we live.  Agriculture not only benefits
consumers, but also our country's stature in this world.

     Historians are now starting to write that the need for food by
the North Vietnamese and Russians and our wheat sales abroad helped

greatly in bringing an end to that confrontation.

     It can also be argued that our food and fiber contributed to the
cease fire obtained between Syria and Israel.

     When problems developed over two weeks ago, who flew to Syria but


     Because the Russians still need food for their consumers.  In my
opinion, it was for this reason that Gromyko went to Syria to help
Secretary Kissinger bring an end to the fighting.  And now we have
the first agreement between Syria and Israel since they became countries.

     Because of the unique contribution made by agriculture we must do
everything we possibly can to see that more effective and safer chemicals
reach our farmers.

     In my remarks today, I have focused primarily on the problems we
all face in the registration and labeling of pesticides.   The delays,
expense and lack of communication are but a few.

     However, it is the solution to these problems that is the tougher

     And it is my hope that the sessions you had yesterday and are
having today will go a long ways in providing the proper solutions.

     This is not an easy area.  The technical problems are many.

     But you must continue to strive toward the goal that results in
pesticides being available to effectively kill  off disease and harmful
insects so food production is increased, while at the same time guaran-
teeing a strong and healthy environment in which we live.

                     THE HONORABLE RUSSELL E. TRAIN
                     Environmental Protection Agency

     It has been said that a miracle product is anything that will do what
its label says it will do.  I think that you will agree with me that this
somewhat jaundiced logic can be applied to pesticides and labeling as well.

     We could not dispute the intentionally lethal effect that pesticides
have on those pests for whom they were intended any more than we can dispute
the harmful effects that they can have, when improperly used, on human
health and the environment.  This is why we have a Federal Environmental
Pesticide Control Act, why this Act makes it unlawful for any person "to
use any registered pesticide in a manner inconsistent with its labeling"
and why we have invited all of you to this symposium.  It is primarily --
sometimes only — through the label that the consumer learns how to use a
pesticide properly and how to avoid its potential hazards.  How effectively
a label gets those messages across can mean the difference between life and
death.  It is the pesticide label that is the cornerstone of EPA's regula-
tory process.

     Today I am going to cover briefly three areas of primary concern to
us all:  regulations and the necessity for them; communication and why it
is needed; and finally, the need for cooperation among all concerned.

     At the time the 1972 Amendments to the Federal Insecticide Fungicide,
and Rodenticide Act were written, the House Agriculture Committee was in
agreement that there was a very real need to strengthen regulatory control
over both the use and users of pesticides.  This included speeding up the
procedures for the barring of pesticides found to be undesirable.  It
meant streamlining the methods by which new means of pest control and new
methods developed become broadly available.  It also meant strengthening
the enforcement mechanism to protect against misuse of any biologically
effective materials.  Finally, it meant creating a framework in which
research could produce a more meaningful data base to insure the develop-
ment of better ways to use existing pesticides, as well as to develop
alternative materials and methods of pest control.  As we move ahead with
administration of the statute and gain experience with its implementation,
I am confident that these broad purposes will be fulfilled.

     I will not go into the various amendments that have been made to the
law.  I am sure that they have been under active discussion here and will
probably receive more comments before everyone leaves.  Permit me to say
however, that the new regulations calling for the classification of
chemicals, the certification of applicators, the registration of plants,
and all the other changes, are geared to fulfilling the intent of Congress
in this particular matter and providing for a safer environment.

     EPA recognizes that pesticides have played an important role in the
production of food and fiber not only for this country, but for the rest
of the world.  Pests will always be with us, and in order for man to
survive, he must have suitable means of controlling the insects and weeds
that continuously threaten his comfort, health, and livelihood.  In
accepting that fact, we have registered over 32,000 pesticide products.
But at the same time, we realize that the benefits to man's health, welfare
and comfort brought about by the use of chemical pesticides can be offset
by the deleterious effects of their use.

     I have been told that the domestic consumption of pesticides now
amounts to almost one billion pounds of active ingredients a year.  That
to me is a rather awesome statistic, but it may very well be in keeping
with current needs.  And we concede that with these needs must go certain
risks to the environment.  For no matter how carefully one applies pesti-
cides under the present circumstances, there is always the possibility of
material going to where it should not go; the possibility that the
material will enter our streams, rivers, and lakes; the possibility of
damage to the living environment by many different routes.

     We must also consider the human element — the people who are
engaged in the production, distribution and sale of pesticides, the
people engaged in the application of these products, and the people
working in the fields.  And we must consider the general public which
uses pesticides in its home environment.

     The point that I am making is that we must balance the risks of
using such products against their benefits.  And in seeing that the
balance is struck, it is the role of the Environmental Protection Agency
to assess the facts and to act positively through the promulgation and
enactment of rules and regulations.

     It should be obvious that if these regulations are followed correctly,
pesticides, while remaining effective, will not be as accessible to
unconstrained use as they have been in the past.  Accordingly, we can
look forward with confidence to a reduction in the number of people
injured because they either did not know what they were handling, or just
did not respect what it was.   Adherence to the regulations should also
bring about a lessening of environmental damage.  Securing these benefits
justifies the complexities and difficulties of administration and

     A few minutes ago I described the pesticide label as the cornerstone
of EPA's regulatory process.   I said this because, under the amendments
to the law, anyone who uses a pesticide in a manner inconsistent with its
label  is in violation of the law.

     This means that attention must be drawn to the piece of paper glued
 to the bag, the printed message on the lithographed drum or can, or
 whatever legal method is used by the manufacturer to provide the necessary
 information.  This places responsibility on all concerned.  More than ever
 before, the manufacturer must insure that he is providing all the informa-
 tion that is required.  The seller must be sure that his information is
 up-to-date and available to the customer.  But it is the last person in
 this chain, the user, for whom this information is of paramount importance.
 It is here that the buck stops.

     If the users do not follow the instructions that are printed on the
 labels, they are running the risk of injury to themselves and others.  I
 am sure you are familiar with the hazardous practices that can endanger
 others — the user who thoughtlessly dumps unused portions of spray
 material down the drain, or stores it in an improper, unlabelled container.

     We do not need scientific degrees or a vast storehouse of technical
 data to understand that improper use, storage or disposal of pesticides
 can lead to problems, some of which may be tragic when little children
 are involved.

     We cannot guarantee against all  risks, but we can act to reduce
 risks to acceptable levels.   Communications play a vital role in this

     Project Safeguard was a good example of EPA efforts in this area.
This was conceived as a pesticide safety program whose aims were to alert
small-acreage farmers to the possible dangers of using pesticides of high
toxicity as replacements for DDT, and to alert them also against misuse of
these products by means of instruction in proper use.  Fifteen states were
included in the project.  Communications cut across many lines, reaching
from the Federal  government to the various State governments, community
groups and industry.   To be sure, there were some difficulties with the
program, but overall  it was  a very effective approach to the problem of
getting pesticide safety information  to the target audiences.  With this
encouraging experience, it is our intention to continue this type of
approach in the future, and to expand its scope.

     But as I  stated earlier, the ultimate solution to the problem lies
in the hands of the user, and it is at this level  that education is most
needed.  This  Agency can do just so much in fostering education.  We can
study and learn the best techniques for passing information along.   But
when the buck finally stops, no person sitting in Washington can prevent
a little child from reaching for tragedy.  The farmer, the homeowner, the
parent, must all  bear this responsibility.  If you begin now to communicate
effectively, you may lessen  the number of times this tragedy is acted out,
and our efforts will  be justified.

     This leads to the final area I would like to cover, and that is
cooperation.  The concept of this symposium is not unique.  What may be
unique, however, is the act of all the parties in attendance to establish
what I feel is a necessary dialogue.  All of us at one time or another
have learned that if we had stopped long enough to discuss a heated issue
calmly for a few minutes, we wouldn't have ended up with a black eye.

     There have been many black eyes given and received over the issue
of pesticides.  Long before the Environmental Protection Agency became a
reality, government and industry were finding their relationships less
than cordial.  Environmental groups reacted to the problems of the day, and
the industry returned the fire.  Now, for the first time, the Registration
Division of the Office of Pesticide Programs is saying to all interested
parties, "Something must be done to improve the pesticide label, its
standards and its guidelines.   Let's get together and see what can be
achieved."  My hope is that the dialogue established here will  be as
fruitful as the recent one between EPA and the Chevron Chemical  Company
over the issue of preventing accidental  paraquat ingestion.  Through
mutual cooperation and effort, improved labeling, communications and
possible formulation modifications were agreed upon to both parties'
satisfaction and the general public's benefit.

     It is a sign that an agency is maturing when it feels  confident
enough to discuss important issues in open forum.   The report of the
President's Science Advisory Committee -- Panel  on Chemicals  and Health--
last September recommended that regulatory agencies improve public
understanding regarding decisions that they make, that the  agencies  make
clear the content and importance of their actions, and that the  "pros
and cons" supporting regulatory decisions of public interest  be  made
available.   In other words, we should bring the public,  and that includes
all the various factions  represented here, into the picture.

     By virtue of your response to this  symposium, I  feel  that we have
made a positive beginning.   Let us hope  that a  meaningful  dialogue
continues,  and that some  firm  results are achieved.   Digest what you
have heard,  let us know what you think,  and let us get on with the job
of working  together to provide and protect our  food and  fiber.   And,
at the same time, let us  work  together to improve  and protect our
environment and our health.