It’s a familiar spot to find yourself in. You want to spray a new product. Or maybe you want to tank mix two chemistries that you’ve never sprayed together before. The crop is ready, the sprayer is set, but now you see there are label questions about specific rates, ground speeds, buffer zones, clean-out procedures and more.
And until you line up all the answers, you’re supposed to let the weeds/diseases/insects keep growing.
Dr. Jason Deveau and Dr. Tom Wolf have been working together to find a solution, now dubbed the Label Summary Sheet (LSS). It’s still a work-in-progress with Deveau and Wolf going back and forth — almost on a daily basis — adjusting the wording or responding to feedback they’ve received in a summary of the first four examples. (Working with Purdue University extension staff, that number is growing.)
The initiative is explained in a pair of documents the two have posted online. They’re available at: sprayers101.com/label_1/ and sprayers101.com/label_2/, and provide four summary examples for Pristine, Dual II Magnum, Liberty 150 and Traxos. The summaries for the first two are just three pages each compared to the pesticide labels which run 25 and 38 pages, respectively. The LSS for the latter two are each two pages versus their labels which are 20 and 12 pages, respectively.
Each summary contains up to eight sections of content:
- Banner Section which includes manufacturer’s name and contact information, commercial product name with a date that indicates the current pesticide label, plus four icons that represent the most common application systems.
- Resistance Management and Planting Restrictions.
- Environmental Conditions which includes weather, set-backs and buffer zones, all of which reflect the method of application and concerns about adjacent or downwind areas.
- Sprayer Settings with the six most commonly asked questions from an applicator when calibrating or adjusting a sprayer prior to use. This section is organized according to the target crop and method of application.
- Handling Safety (personal protection equipment) covers all manner of protective products, from gloves and coveralls to respirator and footwear.
- Mixing is important given the trend in tank mixing different products. The section summarizes restrictions that are noted on the label.
- Rates and Restricted Entry Intervals seeks to simplify what can be a very complicated table, with rates, volumes and restricted entry intervals by crop. When more detailed information is required, it refers the reader directly to the page in the label itself.
- Equipment Cleanout offers applicators a step-by-step breakdown of necessary cleanout procedures. If there is no cleanout procedure, the user is offered a triple-rinse protocol.
Seeking to improve
The two specialists are adamant that these summaries do not replace the formal labels for any crop protectant product, nor are they a negative statement against product registrants or the Pest Management Regulatory Agency (PMRA). Instead, they’re hoping to offer these quick-reference summaries as a long-term means of encouraging registrants and the PMRA to adjust the label wording, provide simpler directions and remove some of the outdated or convoluted specifications that are part of so many product labels.
“The label needs to be taken seriously because it specifies the legal requirements for the use of a product,” says Wolf, president of Agrimetrix Research and Training. “Failure to use the product according to label directions can result in legal action. Therefore, it needs to contain the best information, and it needs to be easy to obtain.”
Wolf and Deveau have found this especially important for new applicators who look to a label for use instructions. The two know from reading labels that many are weak in the area of application instructions, including rates or ground speeds. Most are inconsistent or poorly organized, with information seemingly haphazardly placed throughout a document.
This led to the question, “If someone needed to make a spray application right away, how easy would it be to find out how to make this application according to label directions?”
“The LSS addresses, to a degree, concerns about the level of literacy that some applicators may have,” says Wolf. “In some ag sectors, applicators may be short-term or migrant workers. It’s important that they understand the safety precautions for themselves and the environment prescribed in the label.”
In reviewing existing labels to create an LSS, Wolf and Deveau found many cases of very old language referring to practices that are no longer possible, or to old products that are no longer available. They also found information gaps surrounding things like rainfastness, i.e. gaps that might be filled by registrants during the LSS creation process.
“In order for this to be taken seriously it has to reflect label content — we don’t invent or interpret anything, even if we’d like to sometimes,” says Deveau, application technology specialist with the Ontario Ministry of Agriculture, Food and Rural Affairs (OMAFRA). “I’d be pleased if operators used the LSSs in conjunction with the label, but they have no legal teeth at the moment — it’s still only a proposal that continues to change and evolve.”
The intent in developing the LSS is to address aspects related to applications, obviously a point of interest to both Wolf and Deveau. When an applicator can’t find the information they need at the time of application, it’s either because it’s too hard to find, there are redundancies in the label instructions or the label is what Deveau calls “silent.”
“When labels are silent on critical aspects of application, it’s a problem for first-time applicators who may not have the experience to know the best way to proceed,” says Deveau. “This can reduce the efficacy of the application or increase the potential for off-target drive — or both. Reducing pesticide drift has always been a concern but it is perhaps more important now than ever before. Today’s applicators need clearer guidance on how to keep it on target. The LSS endeavours to gather up those critical points and organize them in a clear, concise and consistent format.”
When a label is silent on something important, asks Deveau, who is the person who has to make the difficult decision? It’s the applicator, and sometimes in order to “do the job right,” it means contravening the label and its instructions. And when an applicator has to make that leap or ignore old advice that’s no longer relevant (and given that the label is treated as a legal document), Deveau states that it’s unfair to the applicators to place them in the line of fire.
Concerns about environmental impacts factor into this exercise as well. If a product can cause harm, this harm should be identified and the mitigation measures to prevent harm should be front and centre. Wolf also refers to Xtend and Enlist technologies and how the dicamba- and 2,4-D-based labels required a complete re-evaluation of application instructions, ensuring they were correct, that they protected the environment and could be easily followed.
Tank mixing has also become a more frequently employed practice, and Wolf acknowledges the need for clearer language and specifications that reflect that trend.
“Tank mixes add a whole other layer of complexity,” he says. “We want the label to be respected and followed and to achieve that, we need to speak in plain terms.”
There are far more bio-rational agrichemicals available to applicators and there is continued scrutiny on pesticides to ensure they have the least potential for environmental impact, but the biggest change, says Deveau, has been the public’s perception of how those chemicals are used.
“There is greater attention on application and farm practices than ever before… people are watching,” says Deveau. “Proper application was always important, but now it also helps the public retain their confidence in crop protection methods.”
The response overall has been very positive. Deveau notes that the purpose of releasing the two articles online was to provide examples of the LSS, but also to encourage feedback from potential users. That’s led to almost daily discussions between Deveau and Wolf to deal with suggestions concerning wording or the language being used, what’s important and relevant, as well as omissions or continuation of “inappropriate language.”
Of course the greatest challenge in developing the LSSs for chemical products is the acceptance from both the product registrants — the chemical companies — and the PMRA.
“We have much work left to do to get buy-in,” says Wolf. “In the meantime, CropLife Canada represents chemical companies and we have indeed consulted with them, and we expect them to share this proposal with their member companies.”
Wolf agrees that buy-in must also come from the PMRA since they’re the regulators that register product uses according to the label.
The hope, says Deveau, is that when he and Wolf work with the registrant or the PMRA, any deficiency on the label can be addressed. Says Deveau: “The best hope is that the label becomes so good that the LSS becomes redundant.”