PPDC Web-Distributed Labeling Work Group Discussion Paper Alternate Delivery Mechanisms for Web-Distributed Labeling
Issue EPA must ensure that all pesticide users have ac cess to any pesticide labeling delivered through a webbased system. As such, alternate m echanisms of delivery must be devel oped 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 deficien cies 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 on ly external stakeholders including users, industry, states/international regulatory agencies, non-governmental organizati ons, 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 y ears old). Approximately half of th e 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 e quipment 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 broadba nd (high-speed) connection, which includes cable, satellite, fiber optic, and wireless connections among others. Additional data on computer and in ternet 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 di al-up is decreasing as users switc h 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 Co mputer Usage and Ownership Table 2. Primary Method of Internet A ccess 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 Co mputer Usage and Ownership

March 3, 2009 1 of 6 PPDC Discussion Paper DraftThe amount of time it takes to downl oad 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 Diff erent 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 issu e paper are faxing and U.S. Mail. This paper also discusses alternate locations that may have internet acce ss, such as the place of purchase, libraries, schools, and county extension offices. Both faxing and the U.S. mail alternatives must bedeveloped 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 popul ation). When land line telephone users are added, the percentage of people with access to phone serv ice increases to nearly 100%. The toll-free hotline number would need the following ch aracteristics 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 Endangere d Species Protection Bulleti ns (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 include s a toll-free number that users can call to have a Bulletin mailed or faxed to them. Curre ntly there OPP staff answer s the number and monitors the voicemail. It is unknown at this point how freque ntly the number will be called compared to users obtaining the Bulletins from the website. The alternate delivery options for web-distributed labe ling 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 DraftFAXING As stated above, this option must be developed in conjunction w ith a toll-free hotline through which pesticide users can request additional labeling for pestic ides participating in web-distributed labeling. Once the user requests the labeling through the hotline, it need s to be delivered to the us er. Faxing the label is a feasible option if the user has or has access to a fax. As with labeli ng distributed from the web, the user would not incur any costs for calli ng the hotline to request to have the labeling faxed, but would be responsible for any costs associatedwith receiving labeling distributedthrough faxing, such as paper and ink, or printing fees. These costs would be minimal if the user owns a fax machin e, 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 pes ticides in the course of their wo rk, such as commercial pesticide applicators, because this group is mo re likely to own fax machines. Itis 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 pe sticides participating in web-dist ributed labeling. Once requested by the user through the hotline number, th e labeling could be sent to the userthrough 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 deliv ery charges could significan tly increase the cost depending on the service and size of the labeling be ing 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 ge t to the recipient. This time is in addition to any processing time needed to select, print, and prepare th e 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 poten tially 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 us er or charge th e registrant.

LIBRARIES Most public libraries provide inte rnet access to the public. Accord ing to a 2007-2008 American Library Association survey, almost 99 percent of public librari es have internet access, with the majority having connection speeds greater than 769 kbps. In a survey from the previous year, ru ral libraries had a higher March 3, 2009 3 of 6 PPDC Discussion Paper Draftpercentage of slower internet speeds compared to urban and suburban librar ies. On average, rural libraries have 7 to 8 computers available for the public to use. Public libraries play a large role in providing intern et access to communities. For pesticide users near a library, this appears to be a re alistic option for accessing web-distributed labeling, although internet connection speeds, availability of computer s, and printing capability may be limited.
SCHOOLS According to a U.S. Department of Education, National Center for Edu cation Statistics report 1
, 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 th e sample size was fairly small (roughly 1.5% of schools), the survey included a represen tative sample of schools nationwide. Although many schools made internet access available out side of school hours, this use appears to be intended for students. It is not cl ear 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 ev ery 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 admi nistration of the altern ate delivery mechanism (maintaining the toll-free hotline, mailing and faxing the labels) needs to be addressed. Users should not be charged for accessing web-distri buted 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 co sts 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, Nation al 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 DraftRecommendation 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 differe nt user communities and each provides a niche delivery mechanism that a speci fic user may need or rely on to access and obtain pesticide labeling. Therefore, for th e full project, all altern atives should be develope d in order for EPA to meet its responsibility. With each alternative devel oped, EPA will ensure that all pesticide users have access to web-distributed labeling. Just as with web-di stributed 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, ther e 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 develo ped and available for users. Many of the users buying these products are expected to have access to web-di stributed 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 th e 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 alternativ e delivery mechanisms.

March 3, 2009 5 of 6 PPDC Discussion Paper DraftWeb-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:



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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