The label is the law is a saying that exists with pesticide
regulators, sometimes coining it as “Enforcement 101.”
With our busy schedules, it is often necessary to revisit
the basics. The addition of technology and electronic services
can cause us to make shortcuts in daily decisions.
Q. Isn’t reading the label old fashioned?
A. Reading and following the label associated with the pesticide
application is a requirement that has never changed.
The county biologist inspecting your pesticide application will check
for compliance with the label in hand (on the container) and any
supplemental information such as a section(s) 24(c), 2(ee), 18 and/or
permit conditions.
Q. Don’t the written recommendations provide all
the information I need?
A. Yes, but the PCA might not include label and/or permit condition
information such as wind speed (mph), vulnerable crop(s), buffer
zones, restricted entry intervals and pre-harvest intervals. In addition,
non-restricted materials and/or private applicator applications do not
always require written recommendations.
The responsibility for compliance includes the PCA, grower and
applicator, but will fall on the person with the label in hand at the time
of application. An important rule to follow: Whatever is listed on
the label is not an option.
Q. Is it just the pest, or the crop, that must be listed on the label?
A. Some people misunderstand and believe that only the pest needs
to be listed on the label. Actually, the crop shall be on the label, and
the pest must be included as the control could happen through incidental
use.
The U.S. EPA establishes a residue tolerance for the active ingredient
on the commodity as the final process in registering the pesticide.
All pesticides sold and used in California must first be registered
with the U.S. EPA and then go through the process with the Department
of Pesticide Regulation.
Q. Why is any of this important?
A. Countries receiving California rice, such as Japan, test for approximately
600 chemicals. Any illegal detection could cause California rice to fail the chemical test, resulting in rejected commodity shipments.
Worse case scenario is a crop destruct for illegal residue.
Add to this, heightened awareness of food safety concerns from the
public. In the end, the California rice industry suffers a loss of credibility
with customers domestically and abroad.
The California Rice Commission supports the advances in technology
for pesticide applications. However, reading and comparing
available labels to those on the container is a proactive approach to
credibility in stewardship and maintaining a high reputation with
our public stakeholders.
This article was originally published in the California Rice
Commission September 2011 newsletter. |
