We’ve identified and discussed shortcomings in the content and design of today’s pesticide labels in an earlier article. From the perspective of the spray applicator, the information needed most often can be difficult to locate, anachronistic, contradictory, subjective or even missing from the label altogether. To truly encourage an applicator to read and follow the label we need a consistent, concise and clear format that summarizes critical content.
To that end, we have worked with growers, university/government extension and industry to develop a prototype we’re calling the “Label Summary Sheet”, or LSS for short. We presented the concept in a series of public presentations in western Canada as part of the RealAgriculture TechTour Live event in 2018. You can watch a recording of part of that event at the end of this article.
The LSS does not replace or interpret the current label, which is a legal document. It is a summary intended to accompany it. At this stage the LSS is simply a proposal. These documents are not intended for use right now; we hope they will grow and change for the better as they stimulate discussion.
Consider this metaphor: You have just purchased a laptop. When you unbox it, you get an in-depth instruction guide that covers everything from operation to trouble shooting and includes all the legal riders. It’s a daunting technical document that you likely won’t read unless something goes wrong. Knowing that, manufacturers include a graphic and accessible quick start-up guide that summarizes the most common and critical issues. It doesn’t replace the instruction manual, it just augments it. If you can’t find what you need in the quick start-up guide, you are referred to the more fulsome description in the instruction manual. Think of the pesticide label as the instruction manual and the LSS as the quick start-up guide.
Some agrichemcial companies recognize this need and have developed short documents to summarize key aspects of the label, but they are inconsistent and brand-specific marketing documents that do not always contain the information we are proposing. Here, for example, is the technology sheet for Integrity herbicide.
We tested the versatility of our LSS format by summarizing four diverse pesticide labels. Our selections are not intended to imply that these labels are particularly deficient. Only that they are commonly used, somewhat complicated and represent the spectrum of pesticide categories and application methods.
Download and look at the variety of labels we have summarized as examples. They are available here:
- Pristine (LSS: 3 pages. Pesticide Label: 25 pages)
- Dual II Magnum (LSS: 3 pages. Pesticide Label: 38 pages)
- Liberty 150 (LSS: 2 pages. Pesticide Label 20 pages)
- Traxos (LSS: 2 pages. Pesticide Label: 12 pages)
Note that each LSS features the same section headings and a relatively consistent layout, no matter the manufacturer. Generic icons are used to illustrate content and make it easier for users to navigate without language barriers. The LSS are black and white to facilitate reproduction and refer back to their respective pesticide labels (i.e. the online PDF, not the booklets that come with the pesticides).
LSS Sections
Here is the Pristine LSS broken down by section to highlight the key features.
1. Banner Section
The banner is at the top of every LSS. It gives the commercial product name and the date to ensure the LSS reflects the current pesticide label. Four icons represent the most common application technologies: Horizontal boom sprayer, airblast, aerial and handheld. If an application method is prohibited, a banned symbol appears (such as aerial in this case). Note we have left room for RPAAS (UAV’s) anticipating the day we have products registered for that technology. The table notes the type of pesticide (e.g. fungicide, insecticide, adjuvant, etc.). The mode of action and active ingredient(s) are noted, as well as the formulation and the Pest Control Product number.
2. Resistance Management / Planting Restrictions
Intended to provide key information on managing pesticide resistance, this section reflects label content about carry over and the rotation of active ingredients. Further, to aid in application decisions, it reflects any restrictions around maximum number of applications, sequential applications or plant back issues following use.
3. Environmental Conditions
Any restrictions regarding weather conditions during or after application are noted here. This includes set-backs or buffer zones that reflect method of application and the nature of the adjacent or downwind area in question.
4. Sprayer Settings
This section includes the six most commonly asked questions an applicator has when calibrating or adjusting their sprayer prior to use. It is organized by target crop and method of application. When the label provides a high level of detail, the user is referred to the correct page. Note the use of graphics to quickly direct the reader to the information they need. Any additional qualifications found in the label relating to sprayer settings are indicated in the notes beneath the table.
5. Handling Safety (PPE)
The concept for this simple and graphic table originated in France, and was communicated to us by Dr. Carol Black of Washington State University. This unambiguous format encourages the use of PPE while ensuring the handler uses the appropriate level of protection for each activity.
6. Mixing
As operators tank mix more products to curtail resistance, improve efficacy or improve productivity, there is a greater chance of chemical or physical incompatibility. This section summarizes any restrictions noted in the label. Learn more by downloading Purdue Universities’ publication “Avoid Tank Mixing Errors“.
7. Rates and Restricted Entry Intervals
This table can be quite complicated depending on the pesticide label. It summarizes the rates, volumes and restricted entry intervals by crop. It reflects the broadest range of product rates listed in the label. Restricted entry duration is affected by the post application activity, and this is captured in the REI column. If more detail is required, the user is referred to the appropriate page(s) of the label. Any additional qualifications found in the label relating to rates, volumes or REI are indicated in the notes beneath the table.
8. Equipment Cleanout
Finally, equipment cleanout is summarized (where possible) in a sequence of steps. When the pesticide label is silent on the cleanout procedure, the user is provided with the triple rinse protocol, which is generally held to be the industry best-practice.
Adoption
To date, this proposal has been made to Croplife Canada, the American Society of Agricultural and Biological Engineers (ASABE), an International Organization for Standardization (ISO) mirror committee (Equipment for crop protection) and more than 1,400 growers and stakeholders across Canada.
Our suggestion for adoption of the LSS (in its current form or something similar) is that regulatory agencies commission a working group comprised of representatives from grower groups, industry and government to oversee the process. The working group would support registrants as they populate (or update) the LSS template when a new product is submitted for registration, or as part of the natural review cycle.
Should the registrant encounter duplicate, missing or contradictory information while completing the LSS, it should be considered an opportunity to remedy the problem on the pesticide label. This will clarify the safest and most effective use of the pesticide for the applicator, who is currently forced to selectively ignore or interpret such errors. To our minds, this was the intent of the original labelling system, and the inclusion of the LSS is a simple and effective way to achieve that goal.
The Confusicol Sketch
In 2018 we participated in Real Agriculture’s TechTour Live event that toured four major cities in Western Canada in four days. We presented the “Confusicol sketch” as a light-hearted way to open a discussion with the audience on the strengths and weaknesses of Canadian pesticide labels and how the Label Summary Sheet might be a viable supplement. Here’s one of the live takes, warts and all. Turns out live sketch comedy is tricky…