Web-Distributed Labeling Workgroup Discussion Paper 

Virtual Pilot 

I. Background 

EPA’s Office of Pesticide Programs (OPP) is exploring the possibility of allowing registrants to 

distribute some portions of pesticide labeling via the internet. To support this effort, at the 

recommendation of the Pesticide Program Dialogue Committee (PPDC) subgroup for webdistributed labeling (WDL), OPP encourages the private sector to conduct a virtual pilot 

(hereafter “the Pilot”) of the web-distributed labeling concept. The Pilot would demonstrate how 

a website would be designed and how users could access labeling information using the website; 

it would not involve the actual distribution to users of any pesticide products that would rely on 

WDL approach. This issue paper presents OPP’s current thinking on the Pilot, the associated 

functional specifications, and one possible implementation strategy. 

II. WDL Virtual Pilot Overview 

This section presents a description of the Pilot, objectives, scope, assumptions, anticipated 

stakeholders, legal/ethical considerations, and metrics for program assessment. In general, the 

Pilot refers to a web-based software application that will simulate the “web-distributed labeling 

user experience” by allowing users to search for and download pesticide labeling. 

A. Objectives 

The purpose of the Pilot is two-fold: (1) to determine whether a system can be designed 

that registrants would use to distribute state-approved labeling through the internet, and 

(2) to determine whether the benefits of WDL would be appealing enough that users 

would be willing to visit a website to download and read labeling. To ensure the Pilot 

supports the purpose described above, EPA has identified the following objectives: 

• Demonstrate that state-approved pesticide labeling can be formatted 

(“segmented”) by use pattern in a manner suitable to be supplied to stakeholders 

via the internet. 

• Demonstrate that pesticide labeling can be provided accurately via the internet. 

• Document the approximate cost to third parties for preparing a small, average, and 

large label for web distribution. 

• Gather and evaluate stakeholder feedback on the usability, user understanding, 

and anticipated compliance for web-distributed labeling compared to current 

paper-based labeling. 

• Collect stakeholder feedback on the look and feel of the Pilot website(s). 

• Evaluate the appropriateness and completeness of EPA’s proposed minimum 

specifications for the web-distributed labeling website. 

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B. Scope 

To increase the likelihood of achieving the objectives described above and to limit the 

potentially overwhelming number of variables of such an effort, the scope of the Pilot 

should be limited in the following ways: 

• Issues relating to users’ access to the internet and the web-distributed labeling 

website(s), connectivity speed, and website(s) reliability are outside the scope of 

this Pilot. 

• Alternative delivery mechanisms (i.e., those other than the internet, such as a tollfree telephone number) are outside the scope of this Pilot. 

• EPA encourages multiple participants in the Pilot. 

• Each website should include, at a minimum, the labeling for at least three mock 

state-registered products supplied by EPA and three additional state-registered 

labels not supplied by EPA. 

• Residential/homeowner products are outside the scope of this Pilot. 

C. Assumptions 

To increase the likelihood of achieving the objectives described above and to clearly 

communicate expectations to potential participants, the Pilot website(s) will be designed 

based on the following assumptions: 

• Information submitted to or gathered within the scope of the Pilot should be 

considered public information and should not be subject to CBI claims. 

• All Pilot websites should meet EPA’s minimum functional specifications. 

• Each Pilot website should be an independent application that provides a single 

point of access to simulate searching and retrieving pesticide labeling from 

multiple registrants. 

• Any labeling supplied by the Pilot website(s) shall not be used to make pesticide 

applications and shall be clearly identified as not being intended for actual use. 

• EPA will supply three mock state-approved labels to be used as part of each 

website’s labeling. 

• Each Pilot website should contain the three mock state-approved labels supplied 

by EPA and the labeling for at least three more state-approved products not 

supplied by EPA. 

• Each pilot website should include at least one product registered for agricultural 

use, one product registered for non-agricultural use, and one product registered 

for antimicrobial use. 

• Although web-distributed labeling, if implemented, may specify an expiration 

date, for the purposes of the Pilot, no expiration date will be specified. 

• Although encouraged, the website(s) are not necessarily expected to meet the 

requirements specified in Section 508 of the Americans with Disabilities Act. 

• EPA is not expecting to participate in the construction of the Pilot website(s). 

• Tribal issues are not addressed in this Pilot. 

 

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D. Stakeholders 

To improve the probability of achieving the objectives described above, participants in 

the Pilot program should solicit input and feedback from the following stakeholders: 

• People who purchase and use pesticides in the course of their business 

(e.g., farmers) 

• People who apply pesticides for hire (e.g., professional or commercial 

applicators) 

• State and tribal pesticide regulatory agencies 

• Registrants/manufacturers 

• Distributors/retailers/repackaging facilities 

• Educators 

• General public 

• Public interest groups 

• EPA 

E. Legal and Ethical Considerations 

EPA is committed to ensuring that the process for getting private sector participation is 

fair, equitable, ethical, and complies with applicable laws and regulations including the 

Americans with Disabilities Act, the Paperwork Reduction Act, and the Federal 

Insecticide, Fungicide, and Rodenticide Act. As part of this commitment, the Agency 

will make every effort to engage in open dialogue with prospective/current participants 

and stakeholders. This dialogue will help ensure that private sector participants 

understand, among other things, that if EPA decides to proceed with WDL, participation 

in the Pilot does not affect any future EPA decisions to award grants or contracts in 

connection with further development of the WDL approach. 

Americans with Disabilities Act 

Websites operated by the federal government must comply with section 508 of the 

Americans with Disabilities Act (ADA). While a website operated by a private sector 

entity, even if users are directed there from an EPA website, is not required to comply 

with ADA sec. 508, EPA encourages such compliance. 

Paperwork Reduction Act 

The Paperwork Reduction Act (PRA) applies to any effort by the federal government to 

collect information from 10 or more persons or entities by means of identical questions. 

The PRA requires an agency to obtain approval from the Office of Management and 

Budget for such a collection. The PRA, however, does not apply to the collection of 

information by a private party so long as the federal agency does not fund the collection--

in whole or in part--or control its content. Accordingly, private sector participants in the 

Pilot will decide what information to collect from stakeholders and what information to 

provide to EPA. 

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Federal Insecticide, Fungicide, and Rodenticide Act 

Participants in the Pilot should consult the discussion paper Container-Affixed Label and 

Web-Distributed Labeling developed for the Pesticide Program Dialogue Committee 

Web-Distributed Labeling Workgroup (http://epa.gov/pesticides/ppdc/distrlabeling/oct08/container-label.pdf) for more specific information on what is required on 

the container label and what can be included only as part of web-distributed labeling. 

F. Program Assessment 

The purpose of the Pilot is two-fold: (1) to determine whether a system can be designed 

that registrants would use to distribute state-labeling through the internet, and (2) to 

determine whether the benefits of WDL would be appealing enough that users would be 

willing to visit a website to download and read labeling. The following methods should 

be used to gauge the extent to which the Pilot was successful in answering the questions 

above. 

Feedback in the following areas would assist EPA in determining whether to proceed 

with WDL. 

• Demonstrate that state-registered pesticide labeling can be formatted by use 

pattern (“segmented”) in a manner suitable to be supplied to stakeholders via the 

internet. 

• Demonstrate that pesticide labeling can be provided accurately via the internet. 

o Conduct a quality control review for a set number of labels by comparing 

all portions of the approved labeling content with WDL content. 

• Document the approximate cost to registrants for preparing a small, average, and 

large label for web distribution. 

o Each participant should provide an estimated range for the cost of 

preparing a small, average, and large label. 

• Gather and evaluate stakeholder feedback on the usability, user understanding, 

and anticipated compliance for web-distributed labeling compared to current 

paper-based labeling. 

o All participating vendors will provide a summary of and the actual 

feedback received from users who accessed the system. 

o EPA hopes to have a response rate greater than 20% (e.g., 2 respondents 

for every 10 visitors). 

• Collect stakeholder feedback on the look-and-feel of the Pilot website(s). 

o All participating private sector participants will provide a summary of and 

the actual feedback received from users who accessed the system. 

o EPA hopes to have a response rate greater than 20% (e.g., 2 respondents 

for every 10 visitors). 

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• Evaluate the appropriateness and completeness of EPA’s proposed minimum 

specifications for the web-distributed labeling website. 

• Collect feedback from states pesticide agencies, registrants, users, and other 

stakeholders on the overall pilot, whether the website met their needs, and if 

additional functions or features should be considered. 

• Capture standard website accessibility metrics 

III. Functional Specifications 

This section presents the general functional specifications to be used to develop the webdistributed labeling virtual pilot software. Table 1 presents the minimum functional 

specifications for participation in the Pilot. Table 2 presents optional functionality specifications 

that each private sector participant may wish to include. Failure to include functional 

specifications would not preclude participation in the Pilot. 

Table 1. Minimum WDL Virtual Pilot Functional Specifications 

Category ID Specification 

WDL-1100 

The system provides a single, intuitive user interface for accessing web-distributed 

labeling. 

WDL-1120 

The system provides users the option to retrieve pesticide labeling in both Adobe PDF 

and html format. 

WDL-1130 

The Pilot clearly indicates on each webpage and printed page that any labeling 

downloaded from the website is for informational/demonstration purposes only and 

must not be used to make a pesticide application. 

WDL-1140 

When a user performs search on a product, only one version of WDL can be returned. 

That is, the database (or databases) makes available to the user only one version as the 

“current” version. 

WDL-1150 

When labeling is printed, each page must identify the state in which the product may 

be used according to the labeling being printed. 

WDL-1200 

The system allows users to search for pesticide products using the following criteria: 

EPA Registration Number or Product Name, state/territory in which the application is 

intended to be made, and Use Site(s). 

WDL-1210 The system allows users to search for multiple Use Sites. 

WDL-1220 

Users accessing labeling have to specify the state/county in which they intend to 

apply the product to execute a search. 

WDL-1270 The website tracks standard website accessibility metrics 

WDL-1310 

Before being allowed to print labeling, users have to validate labeling to be 

downloaded for example by verifying an image of the container label or entering the 

EPA registration number a second time 

WDL-1320 

The system provides the pesticide labeling in its entirety for the use pattern(s) 

specified 

WDL-1340 

The system provides the ability to compare the most recent version of the pesticide 

labeling to (a) the previous version of the pesticide labeling, (b) a previous version of 

the pesticide labeling as specified by the user. 

WDL-1350 

The system timestamps all pages of the pesticide labeling (MM/DD/YYYY, 

HH:MM:SS) based on when the labeling was rendered 

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Category ID Specification 

WDL-1360 

The system includes a header on all pages of the pesticide labeling including the 

Product Name, EPA Registration Number, Page X of Y, and, if filtered, the use 

pattern(s)/site(s) selected. 

WDL-1370 The system displays the date on which the labeling was posted to the website 

WDL-1380 The system displays the date on which the labeling was approved by EPA 

WDL-1390 

The system displays the date on which the labeling was registered by the state 

authority 

WDL-1400 

The system provides the option for users to subscribe to an email notification program 

that alerts the user to the availability of an updated version of the particular product 

labeling 

WDL-1410 Users do not have to enter personal information to view pesticide labeling 

WDL-1420 

The system clearly indicates any area that might collect personal information and 

provides the user an opportunity to access that feature of the system without 

providing personal information. 

WDL-1430 

The system provides secure connection capability for companies to upload/edit 

labeling content 

WDL-1450 

The system clearly indicates that historical labeling must not be used to make a 

pesticide application 

WDL-1460 

All portions of the system including all content downloaded/printed from the system 

include a legal disclaimer as specified by EPA's Office of General Counsel 

WDL-1470 

The system provides the option for users to specify the font size for viewing/printing 

the labeling 

WDL-1480 

The system provides the ability for users, especially those with slow internet 

connections, to receive pesticide labeling via email 

WDL-1490 

The system permits users to bookmark the website, but it prevents users from 

bookmarking specific pesticide labeling 

Table 2. Optional WDL Virtual Pilot Functional Specifications 

Category ID Specification 

WDL-2100 The system provides a standardized format for pesticide labeling 

WDL-2120 

The system offers users access to additional, non-labeling content, e.g., 

demonstration videos, rate calculators, MSDS sheets, etc. 

WDL-2130 

The system provides the option to refine search criteria by application method and 

application type. 

WDL-2140 The system provides the ability to download historical versions of pesticide labeling 

WDL-2150 

The system allows users to compare labeling and portions of labeling from two or 

more versions of labeling (current, historical, or a combination thereof).

WDL-2160 

The system allows users access county-specific information (e.g., endangered species 

bulletins). 

IV. Implementation Strategy 

This section presents an approach and tentative schedule for implementing a web-distributed 

labeling pilot. EPA anticipates that the three main stages of the strategy will be participant 

identification, Pilot execution, and Pilot follow-up. 

A. Participant Identification 

In an effort to solicit participation from a wide variety of vendors, including those that 

may not be entirely familiar with OPP’s mission, the Agency anticipates performing the 

following actions: 

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• Create a webpage on the EPA website outlining a description of the Pilot, the 

functional specifications, and how to contact EPA to express interest. 

• Announce the availability of the website, including a brief background of the 

WDL Pilot, in the Federal Register and through a listserv. 

Once identified, participants will engage in a dialogue with EPA to gain a better 

understanding of EPA’s expectations for Pilot participants and to request feedback on the 

proposed approach. The Agency will encourage participants to maintain this dialogue, to 

the extent appropriate, throughout the execution of the Pilot. 

B. Pilot Execution 

After meeting to clarify expectations for the Pilot, participants should independently or 

collaboratively develop their version of the WDL Pilot. This should include providing 

EPA with instructions for accessing the Pilot website, the dates during which the 

participant intends to conduct and gather feedback on the Pilot, and a tentative date for 

meeting with the Agency to present an analysis of the Pilot including feedback received. 

EPA will also schedule at least one meeting during Pilot execution during which all 

participants will have the opportunity to report on the status of their Pilot and present any 

issues or information that may benefit EPA or other participants. 

C. Pilot Follow-Up 

At the conclusion of the Pilot, each participant should prepare and present an analysis of 

the Pilot including feedback received and a program assessment as specified in this 

document. EPA will post a summary analysis of the entire Pilot program on the website. 

D. Schedule 

A tentative schedule for implementing the Pilot within 18 months is presented in Table 3. 

Table 3. WDL Virtual Pilot Tentative Schedule 

Pilot Phase Milestone Responsible 

Party 

Elapsed Time 

(months) 

Create webpage on EPA website with instructions for 

participating in Pilot; publish notice of availability of 

webpage in Federal Register 

Participant EPA 0 

Identification 

Submit expression of interest to EPA Participants 3 

Conduct kick-off meeting EPA/Participants 4 

Develop web-distributed labeling pilot website Participants 8 

Pilot Execution 

Conduct and gather feedback on the Pilot websites Participants 14 

Analyze feedback received on the Pilot website Participants 16 

Present analysis to EPA Participants 17 

Pilot Follow-Up 

Post combined results of program assessment EPA 18 

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