PPDC Web-Distributed Labeling Work Group Discussion Paper 

Alternate Delivery Mechanisms for Web-Distributed Labeling
 

Issue 

EPA must ensure that all pesticide users have access to any pesticide labeling delivered through a webbased system. As such, alternate mechanisms of delivery must be developed to provide pesticide labeling to 

those users who do not have access to the web and/or the necessary technology to download and print 

pesticide labels. 

Goals of Web-Distributed Labeling 

Web-distributed labeling will address certain deficiencies of the current paper-based labeling system 

including simplifying the container label content and allowing for rapid updating and distribution of labels 

and labeling. This will benefit not only external stakeholders including users, industry, states/international 

regulatory agencies, non-governmental organizations, but also EPA HQ and Regional employees. 

Background 

According to the Pew Internet & American Life Project, of the 304 million people in the U.S., 165 million 

are internet users (25 million 12-17 years old). Approximately half of the working aged people in the U.S. 

are not internet users and would probably not have access to pesticide labeling distributed solely by the web. 

Furthermore, individuals may have internet access but lack the equipment to download large files 

(connection speed) or print them (hardware). The internet can be accessed through a dial-up connection, 

which relies on a land line phone and modem, or through a broadband (high-speed) connection, which 

includes cable, satellite, fiber optic, and wireless connections among others. 

Additional data on computer and internet access specific to farms is available from USDA’s National 

Agricultural Statistics Service (See Tables 1 and 2; the totals do not include Alaska and Hawaii). These 

data indicate that many farms do not have internet access, and of those that do have access, many have 

slower access speed. The data presented in Tables 1 and 2 is from 2007 but a review of data from previous 

years shows that the percentage of farms with internet access has been increasing. In addition, the 

percentage of farms relying on dial-up is decreasing as users switch to higher access speeds. 

Table 1. Percent Farm Computer Usage and Ownership in 2007 

Percent of Farms 

with Computer 

Access 

Percent of Farms 

that Own or Lease 

a Computer 

Percent of Farms 

with Internet 

Access 

United States 63 59 55 

Source: USDA NASS, 2007, Farm Computer Usage and Ownership 

Table 2. Primary Method of Internet Access for Farms with Internet Access, 2007 

Percent with 

Dial-up 

Percent with 

DSL 

Percent with 

Cable 

Percent 

with 

Satellite 

Percent 

with 

Wireless 

Percent 

with Other/ 

Unknown 

United States 47 27 7 7 7 5 

Source: USDA NASS, 2007, Farm Computer Usage and Ownership 

March 3, 2009 1 of 6 PPDC Discussion Paper Draft 
The amount of time it takes to download labeling will depend on the type of access and file size. Most 

labeling files are expected to be less than 1 MB, although download times for a larger file size is shown to 

provide perspective. 

Table 3. Time Needed to Download Two Different File Sizes at Various Download Speeds 

Download Speed 1 MB 10 MB 

56 Kb/s (dial up) 2.5 min 25 min 

128 Kb/s (DSL) 65 sec 11 min 

256 Kb/s (DSL) 32 sec 5.5 min 

768 Kb/s (DSL) 11 sec 2 min 10 sec 

T1 (1.544 Mb/s) 5.4 sec 54 sec 

Thin Ethernet (10 Mb/s) 0.84 sec 84 sec 

T3 (44.736 Mb/s) 0.19 sec 1.9 sec 

In order to ensure all users have access to web-distributed labeling, alternate delivery mechanisms must be 

explored. 

Alternate Delivery Mechanisms 

The alternate delivery mechanisms discussed in this issue paper are faxing and U.S. Mail. This paper also 

discusses alternate locations that may have internet access, such as the place of purchase, libraries, schools, 

and county extension offices. Both faxing and the U.S. mail alternatives must be developed in conjunction 

with a toll-free hotline number. According to the CTIA-Wireless Association, over 250 million Americans 

now subscribe to a cellular-phone service (nearly 83 percent of the population). When land line telephone 

users are added, the percentage of people with access to phone service increases to nearly 100%. 

The toll-free hotline number would need the following characteristics or functions to ensure faxing and 

sending labels via mail are viable alternatives: 

• Nearly 24-hour access 

• No charge to callers 

• Multilingual 

• Non-automation (live people) 

• Ability to isolate specific uses of a pesticide product 

• Ability to fax and send via mail 

• Ability to quickly respond to user requests 

A similar system was created to distribute Endangered Species Protection Bulletins (Bulletins) under the 

Endangered Species Protection Program (ESPP). The ESPP system is not currently operational as there are 

no Bulletins referenced on the labels yet. However, the system includes a toll-free number that users can 

call to have a Bulletin mailed or faxed to them. Currently there OPP staff answers the number and monitors 

the voicemail. It is unknown at this point how frequently the number will be called compared to users 

obtaining the Bulletins from the website. 

The alternate delivery options for web-distributed labeling are described below. Each option description 

includes a brief explanation of the delivery mechanism and a general assessment of the option’s user 

friendliness, cost, and timeliness. 

March 3, 2009 2 of 6 PPDC Discussion Paper Draft 
FAXING 

As stated above, this option must be developed in conjunction with a toll-free hotline through which 

pesticide users can request additional labeling for pesticides participating in web-distributed labeling. Once 

the user requests the labeling through the hotline, it needs to be delivered to the user. Faxing the label is a 

feasible option if the user has or has access to a fax. As with labeling distributed from the web, the user 

would not incur any costs for calling the hotline to request to have the labeling faxed, but would be 

responsible for any costs associated with receiving labeling distributed through faxing, such as paper and 

ink, or printing fees. These costs would be minimal if the user owns a fax machine, but could be higher if 

the user must visit a copy center such as Kinko’s to receive the fax. This alternate mechanism would best 

serve pesticide users that apply pesticides in the course of their work, such as commercial pesticide 

applicators, because this group is more likely to own fax machines. It is not clear how many small farm 

users have fax machines. It is possible that a local library or county extension office could receive the fax 

for the user to pickup, but they may not be able to accommodate the additional demand on their equipment 

or staff time. 

MAILING 

Again, this option must be developed in conjunction with a toll-free hotline through which pesticide users 

can request additional labeling for pesticides participating in web-distributed labeling. Once requested by 

the user through the hotline number, the labeling could be sent to the user through the mail. The user will 

not bear any costs associated with requesting the labeling through the U.S. mail for standard delivery. 

Expedited delivery (i.e. overnight, next day etc.) could be offered for an additional charge. The standard 

mailing charges would be minimal, but expedited delivery charges could significantly increase the cost 

depending on the service and size of the labeling being delivered. Unlike web and fax distribution of 

labeling, this alternate mechanism is accessible by all pesticides users. 

First class mail takes about 1 to 3 days, on average, to get to the recipient. This time is in addition to any 

processing time needed to select, print, and prepare the labeling to be mailed. This processing time needs to 

be minimized to make the alternate delivery mechanism feasible. 

Other Locations to Access the Internet 

PLACE OF PURCHASE 

The place of purchase may have the required internet connection and hardware to download and print web 

labeling for the customer during the time of purchase (the place of purchase potentially could also use the 

fax mechanism described above if it lacked the required infrastructure to retrieve labeling from the web). 

The pesticide dealer would incur the costs associated with selecting and printing the labeling from the web 

but may pass this cost onto the user or charge the registrant. 

LIBRARIES 

Most public libraries provide internet access to the public. According to a 2007-2008 American Library 

Association survey, almost 99 percent of public libraries have internet access, with the majority having 

connection speeds greater than 769 kbps. In a survey from the previous year, rural libraries had a higher 

March 3, 2009 3 of 6 PPDC Discussion Paper Draft 
percentage of slower internet speeds compared to urban and suburban libraries. On average, rural libraries 

have 7 to 8 computers available for the public to use. 

Public libraries play a large role in providing internet access to communities. For pesticide users near a 

library, this appears to be a realistic option for accessing web-distributed labeling, although internet 

connection speeds, availability of computers, and printing capability may be limited. 

SCHOOLS 

According to a U.S. Department of Education, National Center for Education Statistics report1, 

approximately 99 percent of schools had internet access in 2001. About 85 percent of the schools used 

broadband to access the internet in 2001. Although the sample size was fairly small (roughly 1.5% of 

schools), the survey included a representative sample of schools nationwide. 

Although many schools made internet access available outside of school hours, this use appears to be 

intended for students. It is not clear if non-students needing internet access would be able to access the 

school facilities. 

USDA COOPERATIVE STATE RESEARCH, EDUCATION, AND EXTENSION SERVICE 

Cooperative extension offices are another potential point through which users could access web-distributed 

labeling. There are local and regional offices, as well as a state office in every state and territory. It appears 

that these offices are spread across the state. Many counties may have their own local office, although some 

offices may serve more than one county. 

Alternate Delivery Mechanism Operation 

Although beyond the scope of this paper at this time, the administration of the alternate delivery mechanism 

(maintaining the toll-free hotline, mailing and faxing the labels) needs to be addressed. 

Users should not be charged for accessing web-distributed labeling, whether obtained directly from the 

internet or through an alternate delivery mechanism. Users would be responsible for costs associated with 

the printing and/or faxing (e.g., paper and ink) but these costs are expected to be minimal. If a user obtains 

the labeling from another location, such as the place of purchase or library, the third-party may charge the 

user for the service. 

1 U.S. Department of Education, National Center for Education Statistics. Internet Access in U.S. Public 

Schools and Classrooms: 1994–2001, NCES 2002-018, by Anne Kleiner and Elizabeth Farris. Project 

Officer: Bernard Greene. Washington, DC: 2002. 

March 3, 2009 4 of 6 PPDC Discussion Paper Draft 
Recommendation and Conclusions 

FULL PROJECT 

It is necessary to ensure that all users can access web-distributed labeling in order to assure that they have 

the information needed to protect human health and the environment. As described above, not all users 

have internet access or the ability to download and print large files. Each of the alternate delivery 

mechanisms in the issue paper offer unique advantages and disadvantages to different user communities and 

each provides a niche delivery mechanism that a specific user may need or rely on to access and obtain 

pesticide labeling. Therefore, for the full project, all alternatives should be developed in order for EPA to 

meet its responsibility. With each alternative developed, EPA will ensure that all pesticide users have 

access to web-distributed labeling. Just as with web-distributed labeling, a culture change is necessary so 

that users understand how to use the alternate delivery mechanisms. For users that may go to an alternative 

location to obtain internet access, there will need to be an educational outreach effort not only for the user 

but possibly for the alternative location as well. 

PILOT 

For a pilot project, the alternatives need be developed and available for users. Many of the users buying 

these products are expected to have access to web-distributed labeling through the internet as described 

above. Due to the limited scope, the alternative delivery mechanisms may not need to be fully developed. 

However, the pilot should employ both alternatives in order to gauge the effectiveness of each in ensuring 

that all pesticide users can access web-distributed labeling in a realistic, timely manner. On such a small 

scale, having the registrants or the website host involved in the pilot develop and maintain a hotline and 

mail/fax the labels appears appropriate and the most efficient use of resources since a limited number of 

registrants (or website host) would need to agree to act as the alternative delivery mechanisms. 

March 3, 2009 5 of 6 PPDC Discussion Paper Draft 
Web-Distributed Labeling System Diagram: 

Source: Web-Based Distribution of Electronic Labeling, Presentation to the PPDC, October 17-18, 2007 

Faxing and Mailing System with Hotline Diagram: 

Or 

Source: Web-Based Distribution of Electronic Labeling, Presentation to the PPDC, October 17-18, 2007 

March 3, 2009 6 of 6 PPDC Discussion Paper Draft