### Web-Distribution of Labeling Work group Discussion Paper Education & Culture Change
Issue An effective communication strategy that inform s pesticide users about the transition to web-distributed labeling, how to obtain labe ling, and their continue d responsibility to comp ly with the lab e ling is neces sary to ensu re th at web-dis tributed lab e ling provides at least the sam e , if not a greater , level of protection for public health and the environm ent as traditional paper-based labeling. Background Product labeling is the prim ary m echanism used by EPA to communicate critical inform ation to the pesticide user. The labeli ng contains use directions, health and safety inform ation, and instructions for proper dispos al, as well as other important inform ation. Both FIFRA and pesticid e labe ling regulations assum e that users will follow the use instructions on the label and labeling for regi stered products; users that do not comp ly with labeling directions are subject to penalties f o r non-co mpliance. To protect human health and the environm ent from the risk s associated with p e sticide m i suse or mi sapplication, it is of the utm o st importa nce that pesticide users follow labeling instru ctions. Traditionally, labeling h a s accomp anied the p r o duct and is p r ovided to u s ers at the point of sale, comm only as a leaflet or booklet. W e b-distributedlabeling would make the m o st current version of pesticid e labeling ava ilab l e to us e r s on the internet and through alternate d e liv ery m echan is m s
. This change will affect s t akeholders th rough out the product distribution chain. Registran t s, states and EPA will m ove towards electronic labeling, distribu tors will not be ab le to referen c e the lab e ling accomp anying a product when m aking sales, and users would have to adap t to a new way of getting product labeling. The responsibilities of the user to obtain and follow all label and labeling instructions would not change under a web-distributed labeling system

. If users do not obtain and f o llow the labeling as required, ther e is a poten tial for incr eased risk to both the public and environm ent. Theref ore, it is essential to develop and implem ent a comp rehensive communication plan to educat e users and those who educate or m ake recomm endations to users a bout web-distributed labeling. Any outreach effort mu s taddress the anticipated confusion with both papercontainer labels being on som e products wh ile a sm all sub-set of products carry the w e bdistributed labeling. It is likely that especially during the pilot, users will have the option of purchasin g the product accomp anied by the full labeling, A clear, con s isten tm e ssage delivere d repea t edly to the us er, and on which he will act, is a critical component to achieving the culture change necessary for web-distributed labeling to b e successf ul. W e b-distri buted lab e ling will be a m a jor change f o r pesticide users. Altho ugh m a ny may be fam iliar with us in g the in ternet, they hav e not relied onit for pesticide labeling. In addition to ensuring the m e ssage reaches the pesticide user, it is critical to educate the stake holders engaged throughout the lifecycle of a pesticide. A

Nove m b er 18, 2008 Page 1 of 4num b er of pathways exist that provide in form ation to pesticide users: pesticide m a nufacturers, trade associations, user groups , cooperative extension service, dealers, state regu latory agencies , and state enforcem ent program s. Educati ng these stakeholders will be a n e cessary component of successful implem entation of web-distributed labeling; helping them to understand the functionality andbene fits of web-distribu ted lab e ling will allow them to pass the in f o rm ation to the end use r
. This paper will exp l ore the type s of co mmunication m e ssages, how they will be delivered and who should be involved in developm ent and dissem i nation of the inform ation. The m e ssa ges for the p ilot and full-scale implem entation will b e similar. Although it m a y be necessary to tailo r the information to spec ific audien ces, locations and products for the pilot, the underlying issues are the sam e
. What types of communications are anticipated? W i despread cultu re chan ge will require a sus t ain e d and conce n trat ed ef f

o rt thatinc l ud es comp le m e nt ary outreachfrom EPA, registran t s, Cooperativ e Extension p e rsonnel, S t ate Lead Agencies, trade associations, user groups, d ealers and consultants. It will be critical to communi cate the following key points in a re peated, clear and consistent m a nner to all users so they recognize and act on the m e ssage s, i.e. download and comp ly with labeling.

• W e b-distri b u ted lab e lin g will r e plac e paper
- base d labeling o n som e products in the m arketplace, but no t all p r oducts

• There are several ways to obtain web-ba sed labeling: intern et download, fax, or m a il

• Users still mu st have a copy of labeling at the tim e of application and comply with all use restric ti ons and instructions A well-structured, consistent m e ssage for adaptation and use by all stakeholders will facilitate dissem ination of consistent inform ation to users through a number of avenues. Som e of the decisions on what to include in the m e ssage and how m a terials should be developed w ill b e based on other asp ects of implem entation of the progr am , including the types of products to carry web-distributed labeling or paper labels, the alternate delivery m echanis m , and labeling lifespan. T h e m e ssage m a y have to be refined at the state and local level, depending on the resources availabl e to the p e sticide user. For example, in som e localities a user may be able to access the internet or ob tain labeling through his local lib rary, dealer, cou n ty exten s io n agent or crop advisor. Regard less of such potential local differences, all communications shoul d contain the underlying m e ssages above.
In addition to the bas i c m e ssages outlin ed above, the communication m e ssages and strategies sh ould highlig ht the ben e fits of web-distribu ted lab e ling to eachstakeho l der group. Users in particu l ar will benefit by ha v i ng access to m o re conc ise labeling tailored to use in a s p ecific s t ate, on a specific cr op and possibly using a specific application m e thod. In addition, if the websites offer additio nal features that woul d appeal to u s ers – e.g., dem ons tration videos or other educa tional inf o rm ation, messages should emphasize these f eatu r e s
. Further, it is m o re lik ely th a tothe r stakeho l de rs will em brace the i r roles in supporting web-distributed labeling if they are educated on how the initiative will enhance, simplify or otherwise improve thei r experience with pesticide labeling. EP A,

Nove m b er 18, 2008 Page 2 of 4States and registrants could be nef it f r o m a stream lined workf l ow, m o re tim e ly realiza tion of changes to labeling, and increased comp lia nce due to m o re concise labeling. Dealers will be ab le to direct us ers to a webs ite fo r the m o st current p r oduct labeling, rather th an handling paper-based updates and lengthy labeli ng attached to or accompanying pesticide contain e rs. Tying the be nef its in to th e communications m e ssa ge will be a n important part of m arketing web-distributed labeling and achieving culture change.
Who should be involved? A core set o f m a terials n eed to be de veloped. Is s u es f o r consideration inc l ude who will be respons ib le for develo ping and funding the m a terials. The multiple sou r ces of inform ation available to users should be represented in the developm ent of the communications m e ssage. A non-exhaustive li st of potential participants follows.
EPA EPA uses labels and labeling as the prim ary m echanism through which to communicate with pesticide users. E P A bears a responsib ility to support efforts for users to download and f o llow labeling requ irem ents in order to ens u re tha ttran sition i ng to a new syste m does not result in any reducti on in protection to the public and the environm ent. Registrants Registrants are responsible for ensuring that co mplete and accurate labeling is distributed with each p r oduct. Man y registran t s have strong stewardsh i p program s, providing training and outreach on their produc ts to dealers and users. Cooperative Extension S e rvice USDA’s Cooperative Extension Service (C ES) includes state level coordinators, specialists and county agents. CES serves prim arily agricultural (private) and commercial pesticide users, pr oviding initial certification training, re certification training and inform a tion on pests, pesticides and othe r related issues. Since CES is a prim ary source of delivering new inform ation to pesticid e users, it is critical to ensu re CES is engaged in developm ent and dissemi nation of the necessary communication m e ssages. State Regulatory and Enforcem ent Agencies As co-regulators, state lead agencies (SLAs) register products, certi fy certain types of pesticide applicators and have authority to conduct certain enforcem ent actions. SLAs are often front-line com municators with those undergoing routine and targeted inspections, providing complian ce as sistan ce or admi niste r in g penalties, depending on the circum stances. Trade Associations & User Groups Trade associations and usergroups support the needs of their m e m b ers. These organizations represent groups of growers, dealers, for mulators and distributors or registrants, all of whom have a stake inensuring that web-di stributed labeling is implem ented effectively and efficien tly.
Pestic ide De alers & Advisors

Nove m b er 18, 2008 Page 3 of 4Pesticide dealers often do m o re than se ll pesticide products. Often they provide additional s e rvices to th eir cus t om ers suchas inform ation and advice to people m aking decis i ons ab out selecting a pesticide. They serve as a critical li nk between the pesticide registrant and the user.
Pestic ide Us ers Users will b e an essen tial component of th e communication strategy. Affecting cultu r e change throughout the user community would benefit from word of m outh endorsem e nts of

the web-distri buted labeling sys t e m
. Feedb ack f r om users will a l so he lp ta ilor the both m e ssage and the web-distributed labeling system , m aking them m o re effe ctive and responsive to the needs of users.

Howw ill the message s be deliver e d ? The organizations listed above should be involved in developing a strategy for collaboratively conducting outreach in order to ensure that culture change regarding webdistributed labeling occurs in the m o st effective m a nner possibl e. This message will be delivered most effectively if responsib ility is shared, becau se each ind i vidual organizationhas its own expertise, ex peri en ce andreach into the user community.
The sam e message shou ld be presen ted mu ltiple tim e s and by multiple sou r ces to rea c h all us ers. T o ensure th at users recog n i ze th e m e ssage in ev ery possible scenario, web

distributed labeling should have a logo or slogan that is used on all m a terials, reg ard le ss of who deve lops or delivers them

. The m e ssa ge should be conveyed so that the audience understand s how they will benefit, e. g. downl oad labels for specific uses and acces s to new uses in a m o re tim el y m a nner. Enforcem ent, through comp liance assistance and potential penalties, should be employed to reinforce the m e ssage. Users need to understand the new labeling distribution system before these products becom e m ar k eted nationally. Especially for pur p o ses of the p ilot, it will b e critic al to have suf f i cient le ad tim e bef o re implem entati on in order to begin outreach to pesticide users and other stakeholders. Those deliver ing the web-distributedlabeling m e ssage to users should have an understanding of it a nd their role as educators and inform ation sources at least 6 m onths before the pilo t begins. EPA mu st recognize the tim i ng of training for large portions of the country occu rs during the late fall and w i nter season. Training during growing season does not happen.

Conclusion This paper o u tlin es the k e y m e ssages associat ed with implementation of web-distribu ted labeling, the key particip ants for outreac h, and a broad outlin e of how the m e ssages should be delivered. Many issues su rrounding th is issue, including who will pay for the program , who will de live r the m a teria l s, what m a teria l s will b e developed and who will develop m a terials depend on further refinem e nt of the scope, pilo t, hosting, and lifespan issues.

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