2

Table of Contents

Overview......................................................................................................................................... 1

1. Background............................................................................................................................. 3

a. Status of International Review and Other Regulatory Action ............................................. 4

b. Use/Usage Information ........................................................................................................ 4

c. Toxicity................................................................................................................................ 5

d. Incidents............................................................................................................................... 6

OPP’s Incident Data System (IDS)......................................................................................... 6

SENSOR-PESTICIDES.......................................................................................................... 7

Other Incident Databases........................................................................................................ 9

e. Incident Rate Analysis......................................................................................................... 9

Data Sources ......................................................................................................................... 10

Statistical Method ................................................................................................................. 10

Results of Analysis ............................................................................................................... 11

f. Agricultural Health Study.................................................................................................. 13

2. Summary of Risks................................................................................................................. 14

3. Proposed Interim Mitigation Decision.................................................................................. 14

a. Label Amendments and Supplemental Warning Materials............................................... 14

b. Training Materials.............................................................................................................. 15

c. Prohibition of Applications with Hand-held Equipment ................................................... 15

d. Closed System Requirement.............................................................................................. 17

e. Restrict Use to Certified Applicators................................................................................. 18

4. Proposed Implementation Timeline...................................................................................... 20

5. References............................................................................................................................. 22

6. Appendices............................................................................................................................ 23

Appendix A. Paraquat Dichloride Ingestion Risk Message for Pesticide Applicators............. 23

Appendix B. Case Descriptions of 31 Moderate Severity Occupational Incidents Occurring 

Between 1998 and 2012............................................................................................................ 26

Appendix C. Paraquat/Diquat/Glyphosate/Glufosinate Incident Query Methodology ............ 32

Appendix D. Supplemental Incident Rate Tables..................................................................... 33

Appendix E. Proposed Label Amendments.............................................................................. 34

Appendix F. Summary of Proposed Supplemental Warning Materials.................................... 35
3

1. BACKGROUND

Paraquat dichloride (also referred to as paraquat) is an herbicide and desiccant classified as a

restricted use pesticide (RUP) due to high toxicity and, thus, associated concerns for human 

safety. Animal testing indicates that paraquat is acutely toxic through all routes of exposure. A 

large number of human incidents involving the ingestion of paraquat, both accidental and 

intentional, have been reported to EPA through local poison control centers, mandatory Federal 

Insecticide, Fungicide and Rodenticide Act (FIFRA) Section 6(a)(2) reports from registrants, 

other federal and state health and environmental agencies, and individual consumers. Toxicity 

information indicates that one sip can be lethal and there is no known antidote. Paraquat is a 

known suicide agent; moreover, there is a disproportionately high number of deaths resulting 

from the accidental ingestion of paraquat compared to similar pesticides. The accidental 

ingestion incidents often result from paraquat being stored in beverage containers, contrary to 

clear label language prohibiting transfer into other containers. Paraquat is also corrosive to skin 

and is associated with a number of worker incidents involving leakage or accidental spray in 

occupational settings. 

In the late 1980’s, several “safening” agents such as blue dye, a stenching agent, and an emetic 

were added to all paraquat formulations in an effort to decrease the number of incidents of 

accidental and intentional ingestion. The 1997 Reregistration Eligibility Decision1 (RED) noted a 

decline in the number of incidents, which was presumed to be associated with the “safening” 

agents. Several mitigation actions required by the RED were specifically intended to lessen the 

occupational and ecological risks posed by paraquat, including: a reduction in maximum 

application rates; additional personal protective equipment (PPE) for mixers and loaders; 

reduction of paraquat concentration in backpack sprayers; and spray drift control measures. All 

paraquat product labels clearly and prominently prohibit pouring paraquat into food or beverage 

containers via the statement “NEVER PUT INTO FOOD, DRINK OR OTHER CONTAINERS” 

and “DO NOT REMOVE CONTENTS EXCEPT FOR IMMEDIATE USE” in an effort to 

eliminate the illegal transfer of paraquat.

The 2011 EPA Office of Pesticide Programs (OPP) Registration Review Human Health Risk 

Scoping Document2 focused on inhalation exposure scenarios for registered uses, including 

occupational handler scenarios and residential bystander inhalation risk from off-target drift. 

Human incidents were reviewed and a moderately high frequency of incidents was found. In 

2013, EPA received letters from the public noting that fatalities due to accidental ingestion were 

still occurring and calling on EPA to take action. The EPA responded to these letters and 

initiated an analysis of paraquat incidents. 

At this time, EPA engaged the technical registrants in discussions of potential mitigation 

measures to address paraquat incidents. While these discussions were ongoing, EPA produced a 

paraquat safety message which describes the findings of eight incident reports citing deaths due 

to the accidental ingestion of paraquat dichloride to illustrate why pesticide applicators should 

not store pesticides, especially paraquat, in beverage or food containers. This safety message was 

distributed with corresponding slides to a listserv of pesticide safety educators in December 2014

as an interim warning while mitigation discussions between EPA and the registrants were 

ongoing. This safety message can be found in Appendix A of this document and in the paraquat 

dichloride public docket. 

 1

Available at http://www3.epa.gov/pesticides/chem_search/reg_actions/reregistration/red_PC-061601_1-Aug-97.pdf 2 Available in the public docket with the docket ID: EPA-HQ-OPP-2011-0855-0004
4

a. STATUS OF INTERNATIONAL REVIEW AND OTHER REGULATORY ACTION

Paraquat dichloride is a chemical of interest to pesticide regulatory authorities around the world. 

Paraquat is banned in 32 countries, including the European Union, based largely on human 

health concerns. 

On December 23 2015, Canada’s Pest Management Regulatory Agency (PMRA) published a 

Special Review Decision3 on paraquat highlighting human health risk and incident reports on 

both ingestion and occupational exposure. The decision addressed public comments on the 

September 2015 proposed Special Review Decision4 and listed the mitigation measures required 

to address paraquat human health concerns including: 1) designation of paraquat as a “restricted 

class” pesticide, 2) label amendments requiring additional PPE requirements and additional 

hazard warnings, 3) prohibition of tank mixing 4) a reduction in concentration of the active 

ingredient paraquat, 5) modified packaging, and 6) the development of a stewardship/outreach 

program for applicators and vendors. EPA’s proposed mitigation measures, discussed in this 

document, are largely consistent with PMRA’s mitigation approach, although EPA does not 

intend on requiring a reduced concentration of the active ingredient.

In January 2014, the California Department of Pesticide Regulations (CDPR) ranked paraquat as 

second on their Priority List for risk assessment due to occupational exposure concerns5

. 

The Center for Disease Control’s National Institute for Occupational Safety and Health (NIOSH) 

recently authored an article about human health incidents involving paraquat and diquat. The 

paper analyzes information from three incident databases, concluding that all of the incidents 

resulting in serious injury or death were preventable. The article also presents mitigation 

suggestions. The article became available online6 on January 11, 2016 and it will be available in 

print in April 2016. 

b. USE/USAGE INFORMATION

Paraquat is a rapidly acting non-selective contact herbicide and desiccant registered to control 

broad-leaf weeds and grasses on over 100 different crops. Agricultural uses include row crops, 

orchard crops, fruits, and vegetables. Non-agricultural uses include rights of way, pastures/fallow 

land, and commercial buildings/storage yards. It is used as a desiccant/harvest aid on cotton, 

potatoes, tomatoes, dry beans, soybeans, sunflower, canola, sugarcane, and pine trees. Although 

EPA has limited usage data for many of these use sites, EPA has paraquat usage data on 

approximately 50 crops. An average of 4 million pounds of paraquat were applied annually to 

over 7 million acres between 2011 and 2013. There are no products registered for homeowner 

use and no products registered for application to residential areas.

The fast action of paraquat allows more than one crop to be planted in a single growing season. 

Paraquat is also an effective desiccant. According to the Weed Science Society of America 

(WSSA) herbicidal mechanism of action classification, paraquat belongs to Group 22. The 

mechanism of action of this class of herbicide is the inhibition of the photosynthesis process. The 

 3 http://www.hc-sc.gc.ca/cps-spc/pubs/pest/_decisions/rev2015-14/index-eng.php#a1 4 http://www.hc-sc.gc.ca/cps-spc/pest/part/consultations/_rev2015-10/index-eng.php 5 http://www.cdpr.ca.gov/docs/dept/prec/2014/011714_risk_assess_prioritization_update.pdf

6 http://www.sciencedirect.com/science/article/pii/S0013935116300032
5

activity of paraquat depends on sunlight with affected plants quickly wilting and desiccating. 

Five weed species have developed resistance to paraquat in the United States, including horseweed (Conyza bonariensis and Conyza canadensis), goosegrass (Eleusine indica), dotted 

duckweed (Landoltia punctata), and American black nightshade (Solanum americanum). 

Combinations of other herbicides can be used as alternatives for paraquat. The closest alterative 

herbicides to paraquat are glufosinate and glyphosate.

c. TOXICITY

The phases of paraquat toxicity as well as potential medical treatments are described in the 

Recognition and Management of Pesticide Poisonings book (Reigart and Roberts, Chapter 12, 6th

edition, 2013). The EPA’s OPP has sponsored the series since 1973. The manual provides 

healthcare professionals with current consensus recommendations for treating patients with 

pesticide-related illnesses or injuries. 

Paraquat is known to have life-threatening effects on the gastrointestinal tract, kidney, lungs and 

other organs. The oral LD50 estimate in humans varies from as little as 3-5 mg/kg to 40 mg/kg, 

which in either case is a 10-15 ml sip of a 20% paraquat solution. Clinical signs, shock, and 

death may occur within hours to a few days. However, another source indicates patients that 

ingest less than 20 mg/kg usually recover fully (Poisoning and Overdose, 6th edition, Chapter 

122). 

The lung is the primary target organ through all routes of exposure. The primary mechanism of 

toxicity is through the generation of free radicals which results in lipid peroxidation and cell 

damage to lung tissue. Acute lung edema and early lung damage may occur within the first few 

hours. However, hemorrhage and edema fluid in the lung results in a progressive decline in 

oxygen capacity with eventual death from asphyxia and tissue anoxia. 

Ingestion of paraquat also causes damage to kidney proximal renal tubules which impairs the 

ability of the kidney to clear paraquat from the blood. Necrosis of muscle tissue including 

myocardium of the heart and skeletal muscle are also main features of paraquat poisoning. 

Cerebral edema and brain damage has also been reported in paraquat deaths. 

In rodents, technical grade paraquat is severely toxic following acute exposure via the dermal 

and inhalation routes (Category I) and toxic by the oral route of exposure (Category II). It is a 

dermal and ocular irritant but is not a skin sensitizer. Formulated paraquat products range from 

Category I to Category IV, depending on the percent cation and route of administration in the 

toxicity studies. However, it is noted that the repeat dermal rabbit study with Ortho paraquat 

concentrate (34.4%) resulted in scabs at the treatment site as well as epidermal necrosis, 

ulceration, acanthosis (thickening of the epidermis), and surface exudation (oozing of fluids) of 

the rabbit skin. 

In agricultural workers, is it reported that dermal exposure to concentrated paraquat results in 

localized injury at point of contact. Paraquat causes hands to become dry and fissured with 

horizontal ridging of fingernails. Chronic dermal exposure may even result in the loss of 

fingernails. Prolonged contact with skin typically creates ulceration and abrasion sufficient to 

allow systemic absorption, resulting in other pathologic processes. Fatal poisonings have been 

reported from protracted dermal contamination of abraded or eroded skin. 

Inhalation exposure through prolonged spray droplets may cause nosebleeds due to localized 
6

damage in the nose. However, systemic toxicity generally does not result due to the low vapor 

pressure and lower percent formulations in the field. 

Table 1. Acute Toxicity Profile – Paraquat Dichloride78

Guideline 

No.

Study Type [species] MRID(s) Results a Toxicity 

Category

870.1100 Acute oral [rat] 00054573

43685001

LD50 = 189 (M) or 125 

(F) mg/kg

II

870.1200 Acute dermal [rabbit] 00054574 LD50 = 174 mg/kg (M) I

870.1300 Acute inhalation [rat] 9 00046105 LC50 = 1 μg/L (M/F) I

870.2400 Acute eye irritation 

[rabbit]

00054575 Severe irritation I

870.2500 Acute dermal irritation 

[rabbit]

00054576 Slight to severe 

irritation; PIS = 2.1 III

870.2600 Skin sensitization [guinea 

pig] 00155289 Negative --

d. INCIDENTS

For the purposes of this analysis, the EPA queried OPP’s Incident Data System (IDS), Sentinel 

Event Notification System for Occupational Risk (SENSOR)-Pesticides, National Pesticide 

Information Center (NPIC), and CDPR’s Pesticide Illness Surveillance Program (PISP) 

databases. Only those cases occurring in the United States were considered in this analysis.

OPP’s Incident Data System (IDS)

OPP’s IDS includes reports of human health incidents from various sources, including 

mandatory Federal Insecticide, Fungicide and Rodenticide Act (FIFRA) Section 6(a)(2) reports 

from registrants, other federal and state health and environmental agencies, and individual 

consumers. Since 1992, OPP has compiled these reports in IDS. IDS contains reports from 

across the United States, and most incidents have all relevant product information recorded.

Reports submitted to the IDS represent anecdotal reports or allegations only, unless otherwise 

stated in the report.

IDS records incidents in one of two modules: Main IDS and Aggregate IDS:

 

• Main IDS contains incidents resulting in higher severity outcomes and provides more 

detail with regard to case specifics. This system stores incident data for death, major and 

moderate incidents, and it includes information about the location, date and nature of the 

incident. Main IDS incidents involving only one active ingredient (as opposed to 

 7 Table taken from D415809

8 The acute dermal (MRID 43685002), eye (MRID 43685003) and dermal (MRID 43685004) irritation and 

sensitization (MRID 43685005) studies are not displayed above since these studies resulted in lower toxicity and 

thus reduced toxicity category, likely due to a smaller percent of active ingredient used in the studies (D217134). 9 The test material used in the acute inhalation study was crystalline paraquat dichloride. Purity was not specified, 

but the purity of crystalline paraquat dichloride used in other studies was 99.9%. The test material used in the other 

studies was paraquat dichloride in the form of ORTHO Paraquat Concentrate 3 (end use product containing 34.4% 

paraquat cation). Results are expressed in terms of paraquat dichloride rather than paraquat cation.
7

pesticide products with multiple active ingredients) are considered to provide more 

certain information about the potential effects of exposure from the pesticide. 

• Aggregate IDS contains incidents resulting in less severe human incidents (minor, 

unknown, or no effects outcomes). These are reported by registrants only as counts in 

what are aggregate summaries.

A query of Main and Aggregate IDS for all available years (1990-2014) identifies a total of 276 

and 342 incidents involving paraquat, respectively. The Main IDS query included 27 deaths 

involving paraquat dichloride between 1990-2014. Twenty-two of these deaths involved the 

ingestion of paraquat; 11 deaths resulted from intentional ingestion, 8 deaths resulted from 

accidental ingestion. For the remaining 3 deaths, it was not clear whether the ingestion was 

accidental or intentional. Two of the paraquat deaths in Main IDS were related to an incident in 

which paraquat was mistaken for 2,4-D and a drift event ensued. The three remaining paraquat 

fatalities had unclear or unknown exposure circumstances. Since the time of the incident report, 

IDS has received reports of two additional accidental ingestion deaths in the United States. 

The Main IDS query included 22 high severity incidents involving paraquat dichloride. Nine 

cases were occupational in nature and generally involved dermal exposure. Four major severity 

cases were due to accidental ingestion, one case was a suicidal ingestion, one case was related to 

bystander drift, and seven cases were unclear or lacked case descriptions. 

181 moderate severity paraquat cases were identified in the Main IDS query. Moderate paraquat 

exposure incidents are typical handler/product user related exposures involving splashes, spills or 

equipment malfunction during the handling of the product, including mixing, loading or applying 

the product or cleaning application equipment. Most cases appear to have taken place on a farm, 

which often was the residence of the farmer/applicator; however location and occupational 

information was often sparse in the case reports. Symptoms of the moderate severity paraquat 

incidents were typically dermal irritation including blisters, rashes, and redness, followed by 

ocular exposures. Symptoms generally resolved within several days. However, there are a few 

reports of skin irritation persisting over a long period of time following a paraquat exposure and 

a few reports of injuries from occupational exposures necessitating skin grafts. Since the time of 

this analysis, EPA has received three additional reports of incidents resulting in paraquat related 

deaths in IDS. 

SENSOR-PESTICIDES

The Center for Disease Control’s National Institute for Occupational Health (CDC/NIOSH) 

manages a pesticide surveillance program and database known as SENSOR-Pesticides. This 

database includes pesticide illness case reports in 12 states from 1998-2012. The participating 

states for a given year vary depending on state and federal funding for pesticide surveillance. 

Cases of pesticide-related illnesses are ascertained from a variety of sources, including: reports 

from local Poison Control Centers, state Department of Labor workers’ compensation claims 

when reported by physicians, reports from State Departments of Agriculture, and physician 

reports to state Departments of Health. Although both occupational and non-occupational 

incidents are included in the database, the SENSOR coordinators primarily focus their follow-up 

case investigation efforts on the occupational pesticide incidents. The state SENSOR 

coordinator at the Department of Health will follow-up with cases and obtains medical records to 

verify symptoms, circumstances surrounding the exposure, severity, and outcome. Using 

standardized protocol and case definitions, SENSOR coordinators at State Departments of Health 
8

enter the incident interview description provided by the case, medical report, physician and 

patient into the SENSOR data system. All SENSOR-Pesticide cases must report a minimum of 

two health effects in order to be included in the aggregate database that EPA uses for incident 

analyses.

A query of SENSOR-Pesticides 1998-2012 identifies a total of 155 cases involving paraquat (pc 

codes 061601 and 061603); 114 of these cases involve a single active ingredient and 41 involved

multiple active ingredients. After removing intentional cases (n=4) there are 151 SENSORPesticide cases for review. There was one fatality, three high severity cases, 38 moderate 

severity cases, and 110 low severity cases. In terms of care sought by cases, 64 cases were seen 

at an emergency room or hospital (42%), 68 went to a doctor’s office (45%), nine called poison 

control, five sought no care, and five were other or unknown. 

The most frequent routes of exposure10 are dermal (n=74), ocular (n=58), and inhalation (n=41). 

Twelve SENSOR-Pesticides cases resulted from ingestion, including the fatality. This fatal case 

was an 8-year old child who accidentally drank paraquat that had been transferred into a soda 

bottle and stored in his family’s garage. Three ingestion cases involved siphoning of paraquat by 

mouth.

The most commonly affected body systems for paraquat cases are ocular, nervous system, and 

dermal symptoms. Eye pain/irritation/redness is the most frequently reported symptom, followed 

by headache and skin redness/first degree burn.

Of the 151 cases, 123 cases (81%) are work-related and 28 cases (19%) are not work-related. Of 

the 123 work-related cases, 31 moderate in severity cases and these cases are described in 

Appendix B. It is important to characterize these occupational cases because paraquat is an RUP 

intended for occupational use only by certified applicators (or those under direct supervision of a 

certified applicator). 

Of cases with a known application site (n=131); 107 cases occurred on farms or nurseries. 

Fourteen cases were made exposed and made ill at private residences. Of the cases with a 

known activity at the time of exposure (n=135); 71% of cases were handling the pesticide, 

handling includes: application (n=96), mixing/loading, transporting, or repairing pesticide 

application equipment. The other 29% of cases were conducting routine work or living activities 

at the time of exposure.

126 of the 151 cases had at least one prevention code (factor contributing to case’s illness that 

could have been prevented) assigned11. It is noteworthy that 41 cases had the contributing factor 

“required eye protection was not worn or the required eye protection was inadequate” (eye pain 

as the lead symptom supports this issue). In 20 cases, application equipment failure caused or 

contributed to the incident.

 10 Cases may report multiple routes of exposure. 11 In 2009, SENSOR-Pesticides began requiring prevention coding for cases that had an identifiable contributing 

factors, such as: early re-entry, PPE not worn, spill/splash, equipment failure, improper storage, drift, etc. Cases 

may have multiple prevention codes.
9

Other Incident Databases

The National Pesticide Information Center (NPIC) prepared a special report of paraquat incidents 

from 1/1/07 – 5/31/13. There a total of four cases; no fatalities were reported. However, one case 

involved paraquat ingestion from a suicide attempt. CDPR confirmed that from 1992-2010, there 

were a total of four paraquat ingestion cases reported (out of 101 total paraquat-related cases 

reported) to the Pesticide Illness Surveillance Program, three of which resulted in death. In their 

10/7/13 letter to EPA, the American Association of Poison Control Centers noted a total of 50 

paraquat deaths reported to the National Poison Data System (NPDS) from 1983 to 2011. Of the 

50 deaths, 33 were intentional exposures (suicides), 15 were due to unintentional exposure, and 

two were of unknown cause.

For more information on human ingestion incidents, refer to Paraquat Dichloride: Review of 

Human Ingestion Incidents, dated May 21, 2014 in the Registration Review docket for paraquat 

dichloride (Docket ID: EPA-HQ-OPP-2011-0855).

e. INCIDENT RATE ANALYSIS

In 2015, the EPA conducted an incident rate analysis which compared paraquat incidents to 

incidents associated with comparable chemicals. Three herbicides, glyphosate, glufosinate, and 

diquat, were selected for this comparison because they are potential paraquat alternatives for the 

herbicidal use. The detailed incident rate analysis is available in the docket (EPA-HQ-OPP2011-0855).

Glufosinate is a non-selective systemic herbicide that can be used as a burn-down treatment 

before planting or emergence of any conventional crops. In addition, glufosinate can be applied 

as a post-emergence treatment to manage weeds in fields planted with herbicide resistant crop 

varieties such as corn, canola, cotton, soybean, and sugar beet. According to the WSSA 

mechanism of action classification, glufosinate belongs to Group 10. Herbicides of this family 

inhibit the enzyme glutamine synthetase in plants, leading to a complete breakdown of ammonia 

metabolism and consequent inhibition of photosynthesis. Only one weed species, Italian ryegrass 

(Lolium multiflorum) has developed resistance to glufosinate in the United States.

Glyphosate (N-(phosphonomethyl) glycine) is also a non-selective contact-type herbicide used to 

manage annual and perennial weeds in many crops. As a burn-down treatment, glyphosate is 

applied before cultivation of crop lands to control the existing weeds in the field. It is absorbed 

through foliage and translocated to growing points. According to the WSSA herbicide 

mechanism of action classification, this herbicide belongs to Group 9. The mechanism of action 

of this herbicide is inhibition of the (EPSP) 5-enolpyruvylshikimate-3-phosphate enzyme 

involved in biosynthesis of aromatic amino acids (phenylalanine, tyrosine, and tryptophan). 

These amino acids are essential for the protein synthesis in plant species. There are 15 confirmed 

weed species in the United States that have developed resistance to glyphosate and over 100 

resistant weed species worldwide. 

Diquat dibromide is a non-selective fast-acting postemergence herbicide registered on numerous 

agricultural crops and for homeowner use. Its primary agricultural use is as a desiccant. Other 

important uses are for the control of aquatic weed and for spot weed control in residential 

settings. According to the WSSA mechanism of action classification, diquat dibromide belongs 

to Group 22. Herbicides of this family are Photosystem I electron diverters that ultimately 

destroys the integrity of cell membranes, leading to rapid leaf wilting and desiccation.
10

Data Sources

Single active ingredient incident case reports in the SENSOR database for the four herbicides

between 1998 and 2011 were included in this analysis. Any intentional exposure or multiple 

active ingredient cases were excluded. Only SENSOR incident case reports with farm or 

agricultural use sites recorded were included in the analysis because the survey usage data used 

to normalize the incident counts was agricultural in nature. Table 1 below summarizes the cases 

included in the incident rate analysis. 

The use/usage data was obtained from an agricultural marketing firm which produces survey 

estimates regarding use/usage data. Three normalization parameters were chosen, including the 

amount of active ingredient (a.i.) used in pounds, the area treated with the a.i. in acres, and the 

(estimated) number of people using the a.i. (projected number of survey respondents) for each of 

the four herbicides during 1998-2011 period (all values represent the totals over these years and 

are rounded). These data reflect the same time period over which the incidents were accumulated 

and was restricted to the specific states participating in the SENSOR program12. The three 

normalization factors can be considered as rough measures of the geographical extent of the use 

(acres treated), the intensity of use (pounds applied) and the number of users (projected sample) 

and can be seen on the right hand side of Table 2.

Table 2. SENSOR-Pesticides Case Counts / Agricultural Use Data

a.i.

Number of Incidents

Of Given Severity

(numerator)

Usage Metric

(denominator)

High Moderate Low Total Pounds used Acres applied Respondents

Diquat 0 0 3 3 700,000 2,200,000 9,500

Glufosinate 0 1 4 5 13,600,000 30,300,000 140,000

Glyphosate 0 24 124 148 732,000,000 870,000,000 2,400,000

Paraquat 1 19 52 72 27,000,000 58,000,000 200,000

Statistical Method

A Poisson regression model was used to estimate and compare the incident rates between the 

herbicides. The number of incidents were normalized by setting the total amount of a.i. used 

(expressed per unit of 100,000 pounds), the total areas treated (in units of 100,000 acres), and the 

number of respondents (in thousands) as offset values in the models (i.e. using as denominators 

to calculate incident rates). 

Two different incident rates were estimated through two separate analyses: (i) incident rates of 

cases including only high and moderate severity outcomes; and (ii) incident rates of all cases 

including high, moderate and low severity outcomes. The differences in incident rates among the 

herbicides were estimated and presented in terms of incident rates ratios (IRRs).

 12 SENSOR states included: Arizona, California, Florida, Iowa, Louisiana, Nebraska, New Mexico, New York, 

North Carolina, Michigan, Oregon, Texas, and Washington.
11

In addition, a second analysis of the data was performed which explores the tendency of one 

pesticide to have a systematically more severe outcome given a case than another pesticide. This 

potential for a systematic “shift” towards more severe cases was evaluated by using a 

proportional odds (aka ordinal logistic regression) model. The tendency toward a case resulting 

in a more severe outcome with one herbicide compared to another is expressed in terms of an 

estimated odds ratio. For example, if an odds ratio > 1 is produced when herbicide “X” is 

compared to herbicide “Y”, this indicates that incidents associated with exposure to herbicide 

“X” are more likely to be more severe than incidents associated with exposure to herbicide “Y”.

Results of Analysis

The estimated incident rate of cases for high13 and moderate severity14 outcomes of the 

herbicides are presented in Table 3. 

Table 3. Incident Rate for High & Moderate Severity 

SENSOR-Pesticides Cases

a.i.

Incident rate per 

100,000 pounds 

applied

Incident rate per 

100,000 acres treated

Incident rate per 

1,000 respondents

Diquat 0.000 (NA, NA) 0.000 (NA, NA) 0.000 (NA, NA)

Glufosinate 0.007 (0.001, 0.052) 0.003 (0.000, 0.023) 0.007 (0.001, 0.050)

Glyphosate 0.003 (0.002, 0.005) 0.003 (0.002, 0.004) 0.010 (0.007, 0.015)

Paraquat 0.075 (0.048, 0.116) 0.034 (0.022, 0.053) 0.092 (0.059, 0.143)

The results in Table 3 indicate that the incident rate for incidents classified as having high and 

moderate severity outcomes for paraquat are 0.075 incidents per 100,000 lbs used. Alternatively, 

these rates can also be expressed in terms of acres treated and rate per 1000 respondents and –

when expressed in this way – are 0.034 incidents per 100K acres treated or 0.092 incidents per 

1000 respondents. These rates are substantially higher than those for glyphosate, glufosinate, and 

diquat. 

 

These comparisons can also be usefully expressed as incident rate ratios (IRRs) along with the 

95% confidence intervals which is standard practice in the descriptive epidemiology literature.

For high and moderate severity outcomes, these IRRs are presented in Table 4. Note that diquat 

is not included in Table 4 because there are no reported incident with high or moderate severity 

outcomes in SENSOR.

 13 SENSOR defines “high” severity cases as “The illness or injury is severe enough to be considered life threatening 

and typically requires treatment. This level of effect commonly involves hospitalization to prevent death.”

14 SENSOR defines “moderate” severity cases as cases of less severe illness or injury often involving systemic 

manifestations. Generally treatment was provided.
12

Table 4. Comparisons of Incident Rate Ratio for High & Moderate Severity Outcomes

SENSOR-Pesticides Cases

per 100,000 pounds per 100,000 acres applied per 1,000 respondents

Comparison Incident Rate Ratio 

(95% CI)

PvalueIncident Rate Ratio 

(95% CI)

PvalueIncidence Rate Ratio 

(95% CI)

Pvalue

Glufosinate vs. Glyphosate 2.24 (0.30, 16.54) 0.4301 1.20 (0.16, 8.88) 0.8576 0.71 (0.10, 5.24) 0.7359

Paraquat vs. Glufosinate 10.21 (1.37, 76.11) 0.0233 10.37 (1.39, 77.30) 0.0224 12.98 (1.74, 96.70) 0.0124

Paraquat vs. Glyphosate 22.85 (12.62, 

41.36) <.0001 12.46 (6.88, 22.55) <.0001 9.20 (5.08, 16.65) <.0001

The results in Table 4 show that the incident rate of high and moderate severity outcome cases 

for paraquat was significantly higher than that of glufosinate or glyphosate using any of the three 

methods for normalizing exposure. For example, the incident rate for high and moderate severity 

outcomes normalizing by amount a.i. used for paraquat is about 10.21 times greater than the 

corresponding rate for glufosinate and 22.85 times that of glyphosate. 

The estimated incident rate for all cases including high, moderate, and low severity outcomes are 

presented in Table B1, while the comparisons of incident rates of all cases including high, 

moderate, and low severity outcomes among the herbicides are presented in Table B2 in 

Appendix D. 

Finally, the analysis of the tendency for exposure of one pesticide to result in a systematically 

more severe outcome compared to another pesticide using the numbers of SENSOR-Pesticides 

incidents are presented in Table 5.

Table 5. Comparison of tendency of more severe outcomes

Comparison Odds Ratio (95% CI) P-value

Glufosinate vs. Glyphosate 1.290 (0.267, 6.222) 0.7512

Paraquat vs. Glufosinate 1.562 (0.320, 7.626) 0.5812

Paraquat vs. Glyphosate 2.015 (1.251, 3.245) 0.0039

The results in Table 5 show that reported cases associated with paraquat exposures tended to be 

more severe than cases associated with glyphosate (2.02 (1.25, 3.25)). More specifically, the 

odds of a random case associated with paraquat to be more severe than one associated with 

glyphosate was a statistically significant 2.015, or approximately twice as likely. Comparing 

paraquat with glufosinate, on the other hand, produced a non-significant Odds Ratio of 1.56 

(95% CI: 0.320, 7.626). 
13

f. AGRICULTURAL HEALTH STUDY

The Agricultural Health Study (AHS) is a high quality, prospective epidemiology study 

evaluating the link between pesticide use and various health outcomes including cancer (more 

information is available at http://www.niehs.nih.gov/research/atniehs/labs/epi/studies/ahs/). The 

AHS includes private and commercial pesticide applicators and their spouses. If there are AHS 

findings relevant to a particular pesticide going through registration review, the Agency ensures

those findings are considered in the problem formulation/scoping phase of the process and, if 

appropriate, fully reviewed in the risk assessment phase of the process. The AHS includes 

information on use of 50 different pesticide active ingredients commonly used in agriculture.

The following AHS review information is taken from the 2011 paraquat dichloride incident and 

epidemiology scoping memo (D392273). Since that time, more epidemiological findings have 

published. There is a large body of epidemiology data on paraquat dichloride use and 

Parkinson’s disease. For the purposes of this current incident review, only acute exposure to 

paraquat dichloride has been considered. However, as part of the comprehensive human health 

risk assessment scheduled for 2017, chronic effects will be reviewed. 

In the AHS, the authors have reported notable associations between paraquat and the following 

endpoints: thyroid disease; Parkinson’s disease; two respiratory outcomes (wheeze and chronic 

bronchitis) among non-smoking women; and an evaluation of all cancers in relation to paraquat 

use over the lifetime. With the exception of the research study on Parkinson’s disease, all 

investigations were preliminary, and not based upon prior knowledge of a role for paraquat (i.e.,

no a priori) hypotheses. Animal studies and other epidemiologic evaluations have suggested that 

paraquat (and also the pesticide rotenone) may be causative agents (or contributors) in the 

etiology of Parkinson’s disease. Strengths of the AHS epidemiology study include its large 

sample size, and prospective nature of the data collection, as well as high response rate; 

limitations include the narrow generalizability of the results (primarily performed among white, 

male, pesticide applicators), and lack of knowledge of exposure periodicity and time of cessation 

of exposure. Results are briefly summarized below.

In two AHS studies, modest associations were observed between paraquat, as well as other 

pesticides, and both wheeze (OR 1.27 (95% CI 1.04, 1.56), and chronic bronchitis (among nonsmoking women) (OR 1.91 (95% CI 1.02, 3.55)). Overall, these studies are not strongly 

supportive of a link between paraquat and respiratory health outcomes measured,; exposure 

measurement error may explain these results. EPA will continue to monitor this literature 

through the registration review process. In addition, while there is limited a priori evidence as to 

a role for paraquat in thyroid disease, authors reported a statistically-significant elevated odds of 

hypothyroidism (under-active thyroid gland) among women who reported exposure to paraquat 

(OR 1.8 95% CI 1.1, 2.8). Alternative explanations may also exist at this time, and have not been 

completely investigated. Concerning Parkinson’s disease, authors reported elevated odds of 

Parkinson’s disease among those who used paraquat in comparison to those who did not (OR 2.5 

(95% CI 1.4, 4.7)). This result is supportive of the toxicological findings. In addition, AHS 

authors compared cancer incidence between users and non-users of paraquat, and did not observe 

strong evidence of an association between paraquat and any cancer outcome evaluated (including 

all cancers combined, prostate, lung, and colon). Elevated risks were observed with respect to 

non-Hodgkin lymphoma (NHL) however, these results could be otherwise explained. As stated 

by the authors, “There was some suggestion of a possible link between paraquat exposure and 

NHL risk in humans, but the inconsistency in exposure level trend suggests that this could be a 

chance finding”. In summary, based upon preliminary investigations within the AHS, authors 
14

observed some evidence of a possible role for paraquat in relation to wheeze as well as chronic 

bronchitis among non-smoking women, and thyroid disease. However, at this time other 

explanations cannot be excluded, and additional replication is needed. Authors did not observe 

strong evidence of an association with cancer. Concerning Parkinson’s disease, recent 

evaluations support observations in experimental toxicology.

2. SUMMARY OF RISKS

The number and severity of human health incidents associated with paraquat dichloride is of 

great concern to the EPA. Based on toxicity data and incident reporting, it clear that paraquat is a 

highly toxic substance through all routes of exposure -- ingestion, inhalation, and contact with 

the skin and eyes. Furthermore, paraquat is routinely misused and misuse can cause injury or 

fatality. Paraquat is frequently transferred to drink and other inappropriate containers, contrary to 

clear label directions prohibiting and warning against such transfers. There are numerous 

incidents, many involving children, of paraquat being accidentally ingested from a beverage 

container. The results of such ingestion are typically catastrophic, resulting in life-threating 

injury or death. Occupational incidents resulting in dermal injury severe enough to require skin 

grafts as a result of paraquat leaks, spills, and spraying are common with paraquat dichloride. 

Some fatalities have also resulted from paraquat dermal exposure.

In addition, the AHS suggests that chronic exposure to lower levels of paraquat plays a role in 

wheezing and chronic bronchitis among non-smoking women and thyroid disease and alludes to 

a potential link between paraquat dichloride and Parkinson’s disease.

3. PROPOSED INTERIM MITIGATION DECISION

The EPA has concluded that the following mitigation measures are necessary to minimize human 

health incidents associated with paraquat: (1) label changes emphasizing paraquat toxicity and 

supplemental warning materials, (2) targeted stewardship/training materials for paraquat users, 

(3) prohibition of application from hand-held equipment, (4) a closed-system requirement 

(similar to the lock-and-load system) for transferring paraquat out of all containers, and (5)

restricting the use of paraquat to certified applicators only (i.e., prohibiting application by 

individuals working under the supervision of a certified applicator). The Agency believes that 

these measures are necessary to adequately address the human health risk concerns highlighted 

through the paraquat incident analysis. EPA has had discussions with the paraquat technical 

registrants that suggest that the mitigation measures could be adopted voluntarily. 

For details on the potential impacts of the following mitigation measures to include cost 

estimates and their sources, see the Paraquat: Potential Impacts of Proposed Mitigation 

Measures document in the paraquat dichloride docket (EPA-HQ-OPP-2011-0855).

a. LABEL AMENDMENTS AND SUPPLEMENTAL WARNING MATERIALS

EPA is proposing to require all paraquat dichloride product labels to be updated to highlight 

ingestion risk and clarify toxicity. In addition, EPA will require supplemental warning materials 

to be included on or with all paraquat product packages. The supplemental warning materials 

will consist of (1) a warning sticker affixed to the cap of all paraquat containers with the text 

“DANGER-ONE SIP CAN KILL” in English and Spanish accompanied by the image of a skull 

and crossbones symbol; (2) a “product package safety requirements sticker (PSSR) reiterating 

important warning statements (in Spanish, English, and pictogram form) to be affixed to the 
15

opposite side of the label on each paraquat container; (3) a product warning handout called a 

“counter card” reiterating the same important warning information (in Spanish, English, and 

pictogram format) to be distributed with every paraquat container with the intention of the 

dissemination this important information to any person who might handle paraquat. A summary 

of the proposed label amendments and mock-ups of the supplemental warning materials can be 

found in Appendices D and E. 

b. TRAINING MATERIALS

Given the highly toxic nature of paraquat and its history of misuse, EPA proposes requiring the 

technical registrants to develop comprehensive, paraquat-specific training materials for 

applicators. These training materials should consist of information highlighting paraquat toxicity 

and the risks associated with the use and misuse of paraquat in addition to appropriate handling, 

storage, disposal, and PPE requirements and instructions. All applicators handling paraquat 

dichloride should take the training, which will be available online, and retain documentation of 

successful completion. EPA’s intention is for the training website to be listed on all paraquat 

dichloride product labels and successful completion to be a condition of use.

For the proposed changes to the standards for certification of pesticide applicators, EPA 

estimated the cost of developing training materials for certified applicators ranging from $3,100 

to $4,700, depending on the length of training required. The estimates were based on the amount 

of staff time it would take to revise the materials, with a staff wage of $39 per hour. The task of 

developing or adapting training materials for a 12 hour training session was estimated to take 

100 hours of staff time, for a total cost of about $3,900 dollars every two years. We use that 

estimate for the cost of developing paraquat-specific training materials, as well. The estimate for 

the certification rule was based on materials were for training applicators on all the topics within 

a certification category, rather than just safe use of one particular pesticide. However, those costs 

were based on adapting existing material for training programs. Although safety information for 

paraquat and the closed systems already exist, they would need to be adapted. In addition, the 

mitigation proposal suggests that a website training be available, so 100 hours of staff time 

seems like an appropriate estimate. We do not include additional cost estimates for tracking or 

monitoring the status of certified applicators, however. The cost of $3,900 per developed training 

is a one-time cost, but it may need to be duplicated if more than one closed system is used for

paraquat containers.

Guidance for Commenters: Additional areas of information related to the training 

materials requested for this proposed interim mitigation decision, and of particular interest to 

EPA, are described below.

• Identification of additional information that would be helpful to include in the 

training materials.

• Comments related to the feasibility of this training.

• Additional information that would be helpful in reducing exposure to paraquat.

• Information related to the illegal transfer and/or distribution of paraquat.

c. PROHIBITION OF APPLICATIONS WITH HAND-HELD EQUIPMENT

The EPA is proposing to prohibit the use of all handheld application equipment, including 

backpack sprayers and hand gun sprayers, for paraquat dichloride. A large number of the 

paraquat incidents involve backpack leaks and accidentally spraying oneself while applying 
16

paraquat via handgun or backpack sprayers. Incident reports note that leakage and spraying of 

paraquat dichloride onto skin results in severe burns which can necessitate skin grafts, and 

sometimes death. The anticipated impact of this mitigation measure on human health risk 

associated with the use of paraquat is a decrease in dermal exposure and subsequently a decrease 

in occupational incidents.

Prohibition of hand-held equipment may cause growers to change to an alternative chemical, or 

mixtures of chemicals, to achieve similar weed control.

Paraquat is a rapidly acting, broad-spectrum, chemical used as an herbicide and as a desiccant, 

with relatively rapid burndown efficacy. Survey and extension data suggest that hand-held 

applications of paraquat are made for weed control and not as a crop desiccant. Paraquat’s 

combination of characteristics are not found in any other single alternative herbicide. The two 

herbicides that are most similar to paraquat are glufosinate and glyphosate. Table 1 compares 

the characteristics of these three herbicides.

Table 6. Characteristics of paraquat, glufosinate, and glyphosate

Characteristics Paraquat Glufosinate Glyphosate

Weed Selectivity Non selective Non selective Non selective

Application

Pre-plant

Post directed

No paraquat tolerant crops.

Pre-plant

Post-emergence on 

Liberty Link crops.

Pre-plant

Post-emergence on Roundup 

Ready crops

Hand-held equipment Permitted Permitted Permitted

Herbicide activity Contact Contact Systemic

Coverage Complete coverage of 

foliage is needed

Complete coverage of 

foliage is needed

Complete coverage of foliage 

is not needed

Activity Very rapid action Rapid action Slow action

Rain-fastness 15 to 30 minutes 4 hours Varies by product (30 min to 

several hours)

Crop rotational 

interval 0 days Crop dependent(0 to 180 days)

Crop dependent

(0 to 30 days)

Approximate cost per 

acre

$7.25 $11.27 $4.83

Depending on the particular combination of characteristics the grower requires, either glufosinate 

or glyphosate may be selected with a concomitant change in per-acre costs. Other growers will 

select a combination of active ingredients to provide the desired combination of characteristics.

Currently it is not possible to quantify the impacts of switching to alternatives because of limited 

information on the use sites where hand-held application equipment is commonly used. The large 

number of herbicides that could be tank mixed to achieve similar characteristics also complicates 

the quantification. 

The use of small volumes of paraquat may indicate that growers use hand-held equipment. 

Paraquat is sold in several sizes of containers ranging size from one gallon to 2,000 gallons. The 

one gallon containers are only sold in Puerto Rico. Discussions with weed scientists in Puerto 

Rico suggest that paraquat is commonly applied by hand. If true, then the prohibition of handheld equipment in this area may have a larger regional impact.

Guidance for Commenters: Additional areas of information related to the proposed 

prohibition of hand-held applications requested for this proposed interim mitigation decision, 

and of particular interest to EPA, are described below.
17

• Use sites where hand-held application equipment is commonly used.

• Information on the hand-held application of paraquat as a desiccant.

• Identification of the most likely herbicide mixtures that would have the similar 

characteristics to paraquat.

• Information related to handheld paraquat usage in Puerto Rico.

d. CLOSED SYSTEM REQUIREMENT

EPA is proposing that all paraquat containers be engineered so that paraquat may only be 

removed from the container using closed system technology meeting the following criteria: 1) 

The closed system must connect to the container in a way that the closed system is the only 

feasible way to remove paraquat from the container without destroying the container, 2) screw 

caps that can be removed allowing paraquat to be poured or siphoned from the container are 

prohibited, and 3) the closed system must remove the paraquat from its original container and 

transfer the paraquat to the application equipment through connecting hoses, pipes and couplings 

that are sufficiently tight to prevent exposure of the mixer or loader to the paraquat (except for 

the negligible escape associated with normal operation of the system). The anticipated impacts of 

this mitigation measure on paraquat human health risk include the elimination of the opportunity 

for paraquat to be illegally decanted into beverage (or any other secondary) containers and a 

reduction in spills and dermal exposure thus minimizing incidents resulting from improper use of 

PPE and the unsafe handling of paraquat. 

EPA is aware that it is common practice for mixers/loaders/applicators to conduct “jar tests” in 

order to determine the compatibility of pesticide, fertilizer, and other chemicals applied to fields 

via tank mix. However, the practice of jar testing with paraquat presents an exposure concern as 

it increases the likelihood of accidental spills/splashes and the improper storage of paraquat. Jar 

testing will not be possible with the closed system packaging that EPA is proposing to require. In 

addition, jar testing directly conflicts with the label direction, “NEVER PUT INTO FOOD, 

DRINK OR OTHER CONTAINERS”. In lieu of jar testing, EPA recommends that the paraquat 

technical registrants develop a reference material listing compatible tank mixes or new 

technology that would allow for safe compatibility testing (for example, application systems 

which would keep the two co-applied chemicals separate until immediately before application, or 

one-time-use closed containers designed and labeled specifically for compatibility testing).

Requiring closed systems would require users of paraquat who do not have closed systems to 

purchase them, and users with closed systems may need to pay for upgrades to bring the system 

into compliance with paraquat standards. For information on the cost of adopting a closed system 

for farmers, EPA contacted an industry representative who manufactures and sells closed 

systems and closed system components. The reported cost of a system that corresponded to the 

mitigation requirements was $500 to $700 per unit. There is also a small additional cost for 

closures on the pesticide container that cannot be removed and mate with the closed system. As a 

baseline, EPA assumes that all growers and certified applicators will need to purchase a new 

system that meets the standards for the paraquat mitigation. Many growers and commercial 

applicators, particularly large ones, may already have closed systems to minimize exposure to 

pesticides from mixing and loading activities. However, we cannot assume that these existing 

systems will be compatible with what is required for paraquat.

Based on available usage data, about 25,000 farms apply paraquat annually. Some of these farms 

may already have systems for handling pesticides that reduce the exposure to workers, handlers 
18

and applicators, but those systems may not be designed for and compatible with closures for 

paraquat containers. If all of those growers need to pay for and install new equipment with a cost 

of $500 to $700, then the total, one-time cost to growers will be from $12.5 million to $17.5 

million. There is a great deal of uncertainty around this estimate. Some growers, particularly 

large ones may have systems that are compatible with a new closure system for paraquat, or 

would face lower costs for adapting an existing system. It is also possible that other paraquat 

users, faced with expensive, one-time upgrade costs, will either switch to alternative chemicals

or hire commercial pesticide applicators for paraquat treatments. It is also possible that paraquat 

manufacturers may subsidize the cost of new closed systems. 

These estimates are limited by uncertainties in the actual costs of closed systems, the number of 

applicators who would need to buy such systems, whether existing systems would be compatible 

with new standard closures, and any training costs associated with closed systems.

Guidance for Commenters: Additional areas of information related to the proposed closed 

system requirement requested for this proposed interim mitigation decision, and of particular 

interest to EPA, are described below.

• Additional information on the cost of closed systems, including the number of 

affected parties and any training costs associated with closed systems.

• Information related to the importance of tank mixing paraquat dichloride.

• Common tank mix combinations including paraquat dichloride.

• Information related to known compatible and incompatible tank mix combinations for 

paraquat dichloride.

e. RESTRICT USE TO CERTIFIED APPLICATORS

Paraquat dichloride is currently classified as a restricted use pesticide (RUP). As a RUP, 

paraquat can be used by certified applicators or those under their supervision. There are different 

interpretations of “supervision” on a state-by-state basis. In some cases, “supervision” can mean 

that the certified applicator is available through a phone call. The breadth of information the EPA 

has on human incidents suggests that misuse, including decanting of paraquat into other 

containers, is occurring despite the current RUP classification. As a result, to be protective of 

human health, the EPA is proposing to restrict the use of paraquat even further, by only allowing

certified applicators who have met the applicatory competency standards established by states, 

tribal, and federal agencies to use or handle paraquat. The anticipated impacts of this mitigation 

measure include decreased occupational and ingestion risk, the reduction of paraquat availability 

and exposure to persons not knowledgeable about the proper use and handling of paraquat, and a 

general decrease in misuse. 

This mitigation measure would increase costs to growers to the extent that certified applicators 

have a higher opportunity cost of time or charge more for application services than those who 

currently apply paraquat under their supervision. The additional cost of this requirement can be 

estimated by the difference in wages between certified applicators and those they supervise. As 

part of the proposed revisions to the standards for certified applicators, OPP has estimated wage 

rates and the number of applicators by state for certified applicators and those who apply RUPs

under their direct supervision. Certified pesticide applicators can either be commercial, when 

they apply pesticides for hire, or private if they apply pesticides on their own farm or without 

pay. The estimated cost for an hour of time is $52 for private certified applicators and $21 for 
19

commercial certified applicators. The difference in cost for these two is based on the cost of time 

being higher for private applicators, who are farmers and business owners. For uncertified 

applicators under the supervision of a certified applicator, the estimated wage rates are $18 for 

those supervised by commercial applicators, and $21 for those supervised by private applicators. 

Available pesticide use data indicate that an annual average of 7.5 million acres were treated 

with paraquat as an herbicide from 2009 – 2014, and about 5 million of those acres were farmer 

applied; the remainder were applied by custom applicators or the applicator was not identified. 

In addition, paraquat is widely used as a desiccant on some crops, such as cotton and potato. The 

data available to EPA does not cover other desiccant uses, but for cotton and potato alone, about 

1.9 million acres are treated with paraquat annually; about 1.4 million acres (74%) of those acres 

are treated by the farmer, with the rest (about 500,000 acres) treated by custom applicators. EPA 

does not have information on the acreage of other crops treated with paraquat as a desiccant. 

Taken together, this information reflects about 6.4 million acres treated by farmers, and about 3

million acres treated by custom applicators, which we assume to be commercial applicators. 

The difference in hourly cost is $31 for every hour of application being made by a certified 

private applicator instead of an applicator under their supervision, and $3 per hour for 

commercial applicators instead of an applicator under their supervision. To estimate the amount 

of application time that would need to be substituted, we begin with available usage data, which 

shows about 7.5 million acres treated with paraquat annually. There are a range of estimates of 

the number of acres that can be treated by a sprayer in an hour’s time. We use an estimate of 10 

acres per hour, which corresponds to a 20 foot sprayer, the lowest reported in that study. This is 

a low estimate of the number of acres per hour that can be treated, which may correspond to a 

small sprayer in an orchard. Larger sprayers on field crops can apply faster; for example, 28 

acres per hour on field crops in Illinois, 44 to 46 acres per hour in Minnesota, or 55 acres per 

hour in Iowa. Using a low estimate of acres treated per hour will inflate the estimated costs of 

requiring all applications to be made by a certified applicator. 

If a sprayer can treat 10 acres per hour, then nationally that requires 640,000 hours of applicator 

time by private applicators, and 300,000 hours by commercial applicators. If an applicator can 

treat 10 acres per hour, then substituting a certified applicator for an uncertified applicator under 

their supervision costs $3.10 per acre for private applicators and $0.30 for commercial 

applicators.

To estimate the total cost of requiring application by certified applicators only, we need to 

estimate the number of acres treated with paraquat by certified applicators compared to those

under their supervision. The Economic Analysis for the proposed changes to the certification 

standards estimated that there were about 82,000 private certified applicators nationwide, and 

about 2,800 noncertified applicators under their supervision. There were about 414,000 certified 

commercial applicators, and 947,000 uncertified applicators under the supervision of a certified

applicators. If the ratio of noncertified to certified applicators reflects the proportion of paraquat 

acreage treated by noncertified applicators, then about 3.3% of the 6.4 million acres treated 

annually by private applicators and about 70% of the 3 million acres treated by commercial 

applicators are treated by uncertified applicators under the supervision of certified applicators. 

That implies that about 211,000 additional acres would need to be treated by private applicators 

at an additional cost of $3.10 per acre, and an additional 2.1 million acres would need to be 

treated by commercial applicators at an additional cost of $0.30 per acre.

The total additional cost from requiring only certified applicators to apply paraquat is $1.3 
20

million annually, almost equally divided between private (about $655,000) and commercial 

(about $626,000). 

There are important uncertainties with this estimate. The actual acreage treated with paraquat 

may differ, since EPA has little data on desiccant uses other than cotton and potato. The wage 

rates, especially for commercial applicators, may not reflect those of applicators applying 

paraquat in an agricultural section, as they were taken from a document that attempts to estimate 

the wages of all commercial applicators. Wages may differ for commercial applicators in lawn 

care, for example, and agricultural custom applicators. There are a range of estimates for how 

much acreage an applicator can treat in an hour, and we chose a relatively low one; higher 

treatment rates would lower the cost estimate. Also, we implicitly assume here that acreage 

treated by people supervised by private applicators will instead by treated by private certified 

applicators. It may be that, instead, commercial certified applicators will be hired at lower cost 

than private certified applicators.

Guidance for Commenters: Additional areas of information related to the proposed 

restriction of use to certified applicators only requested for this proposed interim mitigation 

decision, and of particular interest to EPA, are described below.

• Information on the time needed to train and license applicators to obtain a certified 

pesticide applicator license.

• Information on the number of acres treated by certified applicators and the number of 

acres treated by those under the supervision of a certified applicator by crop.

4. PROPOSED IMPLEMENTATION TIMELINE

EPA is currently working with the technical registrants to implement the first two components of 

the mitigation package: (1) new labeling and supplemental warning materials; and (2) new 

targeted training materials. EPA anticipates that both of these risk reduction measures will be 

approved and in use prior to publication of the final mitigation decision later in 2016. 

The third component – prohibition of hand-held applications – will occur through label 

amendments. To allow current paraquat users sufficient time to switch to alternate products for 

situations where hand-held equipment is necessary, EPA anticipates allowing registrants one 

year from the date of publication of the final mitigation decision for submission of revised labels 

prohibiting application by hand-held equipment.

The fourth component of the mitigation – change in packaging line to a closed system – will 

require packaging design, testing, and manufacturing changes. The fifth component – the 

requirement for paraquat to be applied by certified applicators only – will require some current 

paraquat users to be trained as certified applicators or to transition to alternate products. To allow 

time for implementation of these two components of the mitigation, EPA is proposing to allow 

paraquat registrants a maximum of two years from the publication of the final mitigation 

decision switch to new packaging and submit revised labeling to implement these two risk 

reduction measures. 
21

Mitigation Measure Proposed Implementation 

Timing

Label Amendments 2016

Paraquat Specific Training Materials 2016

Prohibition of Hand Application 2017

Closed System Requirement 2018

Restricted Use to Certified Applicators 2018

Guidance for Commenters: Additional areas of information related to the proposed 

implementation timeline requested for this proposed interim mitigation decision, and of 

particular interest to EPA, are described below.

• Information related to the feasibility of the proposed timeline and any challenges that 

might impact this proposed schedule.
22

5. REFERENCES

[Amended] Paraquat & Herbicide Alternatives: Incident Rate Analysis. James Nguyen and 

Elizabeth Evans. January 20, 2016.

Paraquat Dichloride (Paraquat) Human Health Risk Scoping Document in Support of 

Registration Review. Becky Daiss, Thurston Morton, and Ray Kent. December 6, 2011.

Paraquat Dichloride: Review of Human Ingestion Incidents. Evans, Elizabeth. May 21, 2014.

Paraquat Dichloride: Review of Human Incidents. Khin Swe Oo. December 12, 2011.

Paraquat: Potential Impacts of Proposed Mitigation. Jonathan Becker, Bill Chism, Sunil 

Ratnayake, and Derek Berwald. March 2, 2016.
23

6. APPENDICES 

APPENDIX A. PARAQUAT DICHLORIDE INGESTION RISK MESSAGE FOR PESTICIDE 

APPLICATORS.

Paraquat Dichloride: One Sip Can Kill.

The Accidental Poisoning Problem 

The California Poison Control System and the Central California Children’s Hospital reviewed 

data from 1998-2009 and identified more than 1,400 cases of accidental poisonings caused by 

storage of non-food substances in soda bottles, unmarked bottles, cups or glasses. Several of the 

deaths involved the accidental ingestion of pesticides, including paraquat.15

Recent Deaths from the Accidental Ingestion of Paraquat 

The California Poison Control System and the American Association of Poison Control Centers 

(AAPCC) recently sent letters of concern to EPA regarding a series of deaths from accidental 

ingestion of the pesticide paraquat in the San Joaquin Valley of California. AAPCC cited 50 

deaths from paraquat; at least 12 were from accidental ingestion of paraquat from a beverage 

container. 

This is a major concern to EPA because paraquat is a Restricted Use Pesticide that should not be 

accessible to the general public and, as with all pesticides, should never be placed into a 

beverage container. Paraquat is highly toxic to humans; one small accidental sip can be fatal and 

there is no antidote. 

The product labels clearly prohibit pouring paraquat into food or beverage containers with the 

prominently-placed statements “NEVER PUT INTO FOOD, DRINK OR OTHER 

CONTAINERS” and “DO NOT REMOVE CONTENTS EXCEPT FOR IMMEDIATE USE.” 

Paraquat Use Profile 

Paraquat dichloride, commonly referred to as “paraquat,” is an herbicide registered in the United 

States since 1964 to control weeds in many agricultural and non-agricultural use sites. It is also 

applied as a pre-harvest desiccant on some crops including cotton. 

All paraquat products registered for use in the United States are Restricted Use Pesticides 

(RUPs), which can only be sold to and used by certified applicators (and applicators under their 

 15 Epidemiology of Accidental Poisoning Caused by Storage of Non-Food Substances in Food Containers and 

unmarked Bottles/Containers. Geller RJ, Kezirian R, Bangar P, Strong D, Carlson T. Children’s Hospital Central 

California; California Poison Control System (CPCS). Found online at:

http://informahealthcare.com/doi/pdf/10.1080/15563650903076924
24

direct supervision). There are no homeowner uses and no products registered for application in 

residential areas.

EPA Incident Investigation

The fatalities resulting from paraquat products transferred into beverage containers in California 

prompted EPA to investigate all reported cases. EPA conducted an investigation of all reports of 

fatal and high-severity paraquat incidents. EPA identified 27 paraquat fatality reports to date in 

its Incident Data System (IDS). The IDS database contains all registrant submissions of adverse 

health effects from pesticide products, as required by federal law (FIFRA §6(a)(2)). More than 

80% of all identified paraquat fatality cases reported to IDS were due to ingestion of the product.

 

At least eight of these 27 deaths were due to the accidental ingestion of paraquat. All eight of 

these accidental deaths involved transfer of paraquat into a beverage container. Several of these 

cases have occurred recently. A review of the SENSOR-Pesticides data identified additional 

ingestion cases, including the fatal case of an 8-year-old child who drank the paraquat out of a 

soda bottle.

True Stories

In 2013, a 70-year-old female ingested some contents of a re-used iced tea bottle that 

contained paraquat, unknown to her. She went to the hospital awake and alert with persistent 

vomiting. Over the course of a 16-day admission, she evolved the classic picture of paraquat 

ingestion: corrosive gastrointestinal injury plus kidney and respiratory failure leading to 

death. 

In 2010, a 44-year-old male mistakenly drank paraquat, which he thought was fruit juice. He 

developed difficulty breathing and vomited blood. He was admitted to the hospital intensive 

care unit where he died after 20 days of aggressive treatment.

In 2008, an 8-year-old boy drank paraquat that had been put in a Dr. Pepper bottle, which he 

found on a window sill in the garage. He died in the hospital 16 days later. His older brother 

had used the product on weeds around the house and put it in the bottle in the garage. The 

older brother obtained the product from a family friend who is a certified Restricted Use 

Pesticide applicator. 

In 2003, a 49-year-old male took a sip from his coffee cup in which he had poured paraquat 

because the product’s bottle was deteriorating. He realized his mistake and went to the 

Emergency Department. At that time, he was vomiting, cold and sweating profusely. Doses 

of activated charcoal were administered and his stomach was pumped; morphine was 

provided for esophageal pain; and he was intubated to support breathing function on the 

fourth day. Aggressive supportive care continued until he died on the tenth day.

In 2000, a 15-month-old boy ingested paraquat that had been transferred into a Gatorade 

container and stored inappropriately. The boy survived in the hospital for 13 days after the 

ingestion and received aggressive treatment but died after suffering acute kidney and liver 

failure.

In 2000, an 18-month-old boy ingested an unknown amount of paraquat solution from a 

bottle found in his father’s landscaping truck. He received multiple-dose activated charcoal 

treatment two hours after the ingestion. He suffered from lack of oxygen during the first 24 

hours followed by progressive liver, kidney, and cardio-pulmonary dysfunction. The boy 

died 11 days after the ingestion.
25

EPA Response

While EPA determines the appropriate regulatory response, we want to warn the applicator 

community about the high toxicity of paraquat.

It is the responsibility of pesticide applicators to ensure that RUP products are used safely and 

appropriately, including never transferring any pesticide product, including paraquat, into a 

beverage container. 

The Solution is YOU

ONE SIP CAN KILL!

To prevent the severe injury and/or death from paraquat ingestion, a paraquat product must: 

• Be used only by a certified applicator or under the direct supervision of a certified applicator;

• Never be transferred to a food, drink or any other container; 

• Always be kept secured to prevent access by children and/or other unauthorized persons;

• Never be stored in or around residential dwellings; and

• Never be used around home gardens, schools, recreational parks, golf courses or 

playgrounds.

Paraquat Dichloride Information Resources

• EPA’s Paraquat Dichloride Registration Review Docket, EPA-HQ-OPP-2011-0855, for 

information on EPA’s current re-evaluation of paraquat. This docket includes a letter from 

Dr. Gellar (California Poison Control System), the EPA response, and the AAPCC letter. 

http://www.regulations.gov/#!docketDetail;D=EPA-HQ-OPP-2011-0855

• Syngenta’s Paraquat Information Center: www.paraquat.com/safety
26

APPENDIX B. CASE DESCRIPTIONS OF 31 MODERATE SEVERITY OCCUPATIONAL INCIDENTS 

OCCURRING BETWEEN 1998 AND 2012.

SENSOR-Pesticides 1998-2011 Occupational

Paraquat Cases of High/Moderate Severity

cexpid Year State Severity Equipment Site Health 

Effects

Case 

Description

Prevention 

Narrative

WA00318 2011 WA 3 09 02 He

stopped 

spraying 

because 

of the 

pain of 

his back. 

He 

complaine

d at the 

hospital 

of itching 

and 

irritation 

at night. 

The MD

He applied 

glyphosate 

from August 

8th to August 

9th. He applied 

the paraquat 

from August 

10th to the 

12th. His back 

pack had a leak 

and he was 

getting his back 

wet while 

spraying. He 

thought it was 

just sweat. He 

did not wash 

until getting 

home.

The back 

pack 

sprayer 

was in 

disrepair. It 

had a leak 

and his 

back was 

with the 

spray. He 

did not 

wash at the 

ranch. He 

would get 

home and 

take a 

shower 

after work. 

He did not 

wear an 

apron or 

chemical 

resistant 

suit as 

indicted in 

the label 

of 

Gramoxone

WA00351 2011 WA 3 11 01 He had a tank 

in a tractor. He 

was burning 

weeds. He went 

to put another 

tank & the 

nozzles 

clogged. He 

moved it up, 

gave it 

pressure, then it 

exploded. 

Sprayed in his 

eyes. There 

was a hose 

about 30 ft 

away. Where 

he rinsed out 

his eye. 

The hose 

clogged. It 

was 4-6 

months old, 

he doesn't 

know who 

used it 

prior. It 

was 

corroded. 

The safety 

glasses 

were 

insufficient 

but it was 

too hot to 

wear all 

protective 
27

equipment. 

they fog.

NC04257 2011 NC3 99 01 Farmworker 

working on a 

farm got 

paraquat 

dichloride on 

his feet and 

developed 

burns.

Farm 

worker 

working on 

a farm got 

paraquat 

dichloride 

on his feet 

and 

developed 

burns.

FL03996 2010 FL3 99 99 gramoxone 

inteon was 

splashed on the 

face of 28 year

old male 

patient at work. 

He works with 

the product 

regularly.

NC02597 2010 NC3 99 01 Meds 

received. 

Could not 

contact 

despite 

multiple 

attempts. 

Offered 

resources 

to wife 

and sent 

letter.

Farmer 

spraying 

gramoxone in 

field and 

believes he got 

the mist in his 

eyes.

Man got 

Gramoxone 

in eyes on 

his farm.

CA18227 2010 CA3 11 01 Spraying 

gramoxone and 

was exposed 

when it leaked 

into the cab of 

the tractor

WA03025 2009 WA3 11 01 A 30 y/o male 

spraying an 

herbicide in a 

vineyard had 

ocular and 

dermal 

exposure when 

he was 

accidentally 

sprayed 

He was 

wearing 

safety 

glasses, not 

goggles or 

face shield. 

However, 

the label 

did require 

protective 

eye wear 

but was not 

specific as 
28

to type. 

According 

to L&I he 

did not 

decontamin

ate 

properly 

and likely 

rubbed his 

eyes.

WA02659 2007 WA3 11 01 A 27 y/o farm 

worker arrived 

at the E.R. 

complaining of 

cardiovascular, 

neurological 

and G.I. 

symptoms. 

LA02842 2007 LA3 12 99 erythema, 

hives, 

burns

spilled 

(gramoxone) 

on foot 

Monday while 

at work; went 

to MD 

Thursday

LA02664 2007 LA3 99 01 chest pain 

(non 

cardiac), 

dyspnea, 

tachycardi a

sugar cane 

farmer applied 

(gramoxone 

inteon) last 

week, hose 

broke; had 

symptoms for 

two weeks after 

exposure

CA14394 2005 CA3 09 01 He was 

carrying 

paraquat in a 

backpack 

container for 6-

10 hours and 

some of the 

paraquat leaked 

onto his back

LA02037 2005 LA3 11 01 CO 

dermal 

and ocular 

irritation, 

and 

erythema; 

referred to 

LDAF; 

txd at ER 

8 days > 

exp

Exposed to 

gramaxone at 

work when 

hose burst 

during 

spraying.
29

LA01063 2004 LA3 99 01 CO 

dypsnea, 

headache, 

chest 

pain, 

blurred 

vision; 

sores on 

tongue

Spraying 

gramoxone and 

diuron on 

peach plants @ 

work and some 

blew back on 

him; referred to 

LDAF

According 

to "label" 

variable, 

violations 

occurred. Label says 

that 

pesticide 

shouldn’t 

make 

contact 

with any 

person

OR01222 2004 OR3 99 02 Symptom s started 

following 

last day of 

work, 

Setting

irrigation 

pipes for 

one 

month 

around 

trees.

No mask was 

used. Jose 

bought his own 

gloves & 

rubber suit, no 

rubber boots.

WA01130 2003 WA3 09 01 A 25 y/o male 

developed 

neurological, 

gastrointestinal 

and ocular 

symptoms 

while spraying. 

Sought medical 

treatment

LA00439 2003 LA3 13 01 confused, 

near 

syncopal , 

unable to 

talk for 

some 

minutes

ER report 

states patient

was working 

over tank of 

gramoxone & 

vehicle 

solvents and 

wind caused 

him to inhale 

strong fumes

CA13372 2003 CA3 99 01 Working as a 

sprayer using 

paraquat. 

Patient feels 

dizzy and chest 

hurts. Doctor 

states "no 

specific event-

patient 

questions 
30

cumulative 

injury"

NY00510 2001 NY3 11 01 MD 

suspects 

pesticide 

poisoning -low 

WBC's. 2 

signs 

fungicide 

poisoning -weight 

loss&

anemia.

Reason 

for low 

cholineste

rase not 

determine

d.

Farmer reports 

occasional 

exposure to 

pesticides when 

ground 

spraying, due 

to wind shift. 

Sole applicator 

for farm for 2 

yrs.

TX01844 2000 TX3 15 10 Case exposed 

to paraquat 

(gramoxone) 

when hand 

spray tank fell 

over. Hands 

exposed. 

Thumb nail 

became 

infected 

CA07798 2000 CA3 99 01 Patient exposed 

while spraying 

paraquat from a 

tractor and 

wearing a 

mask. He 

exited behind 

the tractor, took 

off his mask 

and talked to a 

supervisor and 

was exposed

for 30 min. 

Developed 

chest pain, 

cough, 

shortness of 

breath, and 

pleuritic chest 

pain

Patient 

exposed 

while 

spraying 

paraquat 

from a 

tractor and 

wearing a 

mask. He 

exited 

behind the 

tractor, 

took off his 

mask and 

talked to a 

supervisor 

and was 

exposed for 

30 min.

Developed 

chest pain, 

cough, 

shortness 

of breath, 
31

and 

pleuritic 

chest pain.

CA04770 1999 CA3 99 99 Spilled 

gramoxone on 

boots, did not 

irrigate right 

away

FL00647 1999 FL3 09 02 Patient has 

rash, blistering 

on back from 

exposure to 

backpack 

sprayer leaks. 

CA05752 1999 CA3 99 01 Exposed to 

chemicals with 

possible 

inhalation to 

paraquat and 

guthion. 

Developed 

cough, 

shortness of 

breath, and 

pleuritic chest 

pain.

CA03860 1998 CA3 99 01 Eye exposure 

to paraquat 

while spraying.

CA03776 1998 CA3 10 01 Using paraquat 

while wearing 

gloves and 

gloves leaked. 

Developed 

shortness of 

breath, 

hyperventilatio

n, and a runny 

nose.
32

APPENDIX C. PARAQUAT/DIQUAT/GLYPHOSATE/GLUFOSINATE INCIDENT QUERY 

METHODOLOGY

1. Query of SENSOR-Pesticides case reports from 1998-2011

2. PC Codes query

a. Pc_code1 = 417300 or 103607 or 103605 or 103604 or 103608 or 103601 or 

103603 or 128501 or 128850 or 032201 or 032202 or 016061 or 016063

b. Pc_code2 is null 

c. This yields the total cases with a single active ingredient from above only

3. Intentional Exposures Removed: “Intnexpo does not = 1”

4. Includes only Application site (Appsite) = 01

a. Appsite 01 = Farm, all farms, orchard crop production excluding nursery, 

livestock and forest

5. Results: 

a. N= 228 cases total

b. (see “Single AI HerbicideCaseCompareAPPSITE1_becker.xlsx)

6. In the Excel output from Access, “Chemical” column was added and populated with 

chemical name (diquat, glufosinate, glyphosate, paraquat) that corresponded to pc_code1

SENSOR-Pesticides Query Results

Chemical Severity Total

High Mod Low

diquat 3 3

glufosinate 1 4 5

glyphosate 24 124 148

paraquat 1 19 52 72

Total 1 44 183 228
33

APPENDIX D. SUPPLEMENTAL INCIDENT RATE TABLES

Table B1. Incident Rate for All 

SENSOR-Pesticide Cases

a.i.

Incident rate per 

100,000 pounds used

Incident rate per 

100,000 acres applied

Incident rate per 

1,000 respondents

Diquat 0.425 (0.137, 1.318) 0.139 (0.045, 0.430) 0.318 (0.103, 0.987)

Glufosinate 0.037 (0.015, 0.088) 0.017 (0.007, 0.040) 0.035 (0.015, 0.085)

Glyphosate 0.020 (0.017, 0.024) 0.017 (0.014, 0.020) 0.062 (0.053, 0.073)

Paraquat 0.270 (0.214, 0.340) 0.123 (0.098, 0.156) 0.332 (0.263, 0.418)

Table B2. Comparisons of Incident Rate Ratio for All 

SENSOR-Pesticide Cases

per 100,000 pounds per 100,000 acres applied per 1,000 respondents

Comparison

Incidence Rate Ratio (95% 

CI) P-value

Incidence Rate Ratio 

(95% CI) P-value

Incidence Rate Ratio 

(95% CI) P-value

Paraquat vs. Diquat 0.634 (0.200, 2.013) 0.4400 0.891 (0.281, 2.828) 0.8450 1.042 (0.328, 3.306) 0.9447

Paraquat vs. Glufosinate 7.354 (2.971, 18.205) <.0001 7.469 (3.017, 18.490) <.0001 9.344 (3.775, 23.132) <.0001

Paraquat vs. Glyphosate 13.340 (10.066, 17.679) <.0001 7.273 (5.488, 9.639) <.0001 5.370 (4.052, 7.117) <.0001

Diquat vs. Glufosinate 11.592 (2.770, 48.506) 0.0008 8.381 (2.003, 35.071) 0.0036 8.970 (2.144, 37.535) 0.0027

Diquat vs. Glyphosate 21.027 (6.705, 65.945) <.0001 8.161 (2.602, 25.595) 0.0003 5.155 (1.644, 16.167) 0.0049

Glufosinate vs. Glyphosate 1.814 (0.744, 4.423) 0.1903 0.974 (0.399, 2.374) 0.9533 0.575 (0.236, 1.401) 0.2231

The results show that the incident rates of all cases including high, moderate, and low severity 

outcomes of paraquat and diquat were significantly higher than that of glufosinate or glyphosate

in all three ways of normalizing by amount a.i. used (pounds), by number of treated acres, and by 

the number of respondents. For example, the incident rate of all cases including high, moderate, 

and low outcomes normalizing by amount a.i. used of paraquat was estimating about 7.35 times 

of glufosinate and 13.34 times of glyphosate.
34

APPENDIX E. PROPOSED LABEL AMENDMENTS

Proposed label amendments Location on label

DANGER/PELIGRO On First Page

POISON/VENENO

CORROSIVE TO SKIN AND EYES/ CORROSIVO A LA PIEL 

Y A LOS OJOS

KEEP OUT OF REACH OF CHILDREN/MANTENER FUERA 

DEL ALCANCE DE LOS NIÑOS 

READ ENTIRE LABEL PRIOR TO USING THIS PRODUCT/

LEA TODA LA ETIQUETA ANTES DE UTILIZAR ESTE 

PRODUCTO

IN THE CASE OF AN ACCIDENT, SEEK IMMEDIATE 

MEDICAL ATTENTION. SYMPTOMS ARE PROLONGED, 

PAINFUL, AND CAN BE FATAL/EN CASO DE ACCIDENTE, 

BUSQUE ATENCIÓN MÉDICA INMEDIATAMENTE.

Si usted no entiende la etiqueta, busque a alguien para que se la 

explique a usted en detalle”. (If you do not understand the label, 

find someone to explain it to you in detail).

Danger – Fatal If Swallowed Or Inhaled/LETAL SI SE INGIERE 

O INHALA 

In Warning Box (or 

Area) within the first two 

Causes Severe Eye Injury/ CAUSA DAÑO SEVERO EN LOS pages

OJOS

Corrosive To Skin/CORROSIVO A LA PIEL

NEVER TRANSFER THIS PRODUCT INTO FOOD OR 

BEVERAGE CONTAINERS OR CONTAINERS NOT 

EXPLICITLY INTENDED FOR PESTICIDES/NUNCA 

TRANSFEIERA ESTE PRODUCTO EN ALIMENTOS O 

BEBIDAS EN RECIPIENTES O ENVASES NO 

EXPRESAMENT PREVISTO PARA PESTICIDES

Store Tightly Closed In Original Container, And In A Locked

Place Away From Children And Animals/ALMACENE EN 

CONTENDOR ORIGINAL COMPLETAMENTE CERRADO 

EN UN LUGAR CON LLAVE LEJOS DE NIÑOS Y/Ó 

ANIMALES

Never Use this product In Residential Or Public Recreational 

Settings (E.G. Homes, Home Gardens, Schools, Recreational 

Parks, Golf Courses, and/or Playgrounds)/NUNCA UTILICE 

ESTE PRODUCTO EN ÁREAS RESIDENCIALES Y/Ó 

LUGARES RECREACIONALES ABIERTOS AL PÚBLICO 

(E.G. Casas/Hogares, Jardines, Escuelas, Parques Recreacionales 

y/ó Infantiles y Campos de Golf)

This product is toxic! An alerting agent (odor) has been added to 

help prevent accidental ingestion/Este producto es TÓXICO! Un 

agente de alerta (olor) se ha añadido para ayudar a evitar la 

ingestión accidental

See Back Of Product Container For Important Safety 

Information/Ver Detrás del Contendor del Producto para 

Información de Seguridad Importante
35

APPENDIX F. SUMMARY OF PROPOSED SUPPLEMENTAL WARNING MATERIALS

1. Mock-up of sticker to be affixed to the cap of all paraquat dichloride product containers

DANGER – ONE SIP CAN KILL

PELIGRO - UN SORBO PUEDE MATAR

2. Product Package Safety Requirements Sticker (PPSR) to be affixed to all paraquat 

dichoride product containers

Required Language Language Format

NEVER TRANSFER THIS PRODUCT 

INTO FOOD OR BEVERAGE 

CONTAINERS OR CONTAINERS NOT 

EXPLICITLY INTENDED FOR 

PESTICIDES

English, Spanish, Pictogram

ONE SIP CAN KILL English, Spanish, Pictogram

CONTACT WITH SKIN MAY RESULT IN 

POISONING

English, Spanish, Pictogram

EXPOSURE TO EYES MAY CAUSE 

SUBSTANTIAL EYE INJURY

English, Spanish, Pictogram

PARAQUAT SHOULD NEVER BE USED 

IN RESIDENTIAL OR PUBLIC 

RECREATIONAL SETTINGS (E.G. 

HOMES, HOME GARDENS, SCHOOLS, 

RECREATIONAL PARKS, GOLF 

COURSES, AND/OR PLAYGROUNDS)

English, Spanish, Pictogram

PARAQUAT SHOULD ALWAYS BE 

STORED TIGHTLY CLOSED IN 

ORIGINAL CONTAINER, AND IN A 

LOCKED PLACE AWAY FROM 

CHILDREN AND ANIMALS

English, Spanish, Pictogram

READ ENTIRE LABEL PRIOR TO 

OPENING THIS PRODUCT

English, Spanish, Pictogram
36

3. Paraquat Dichloride Safety Counter Card to be distributed with all paraquat dichloride 

products

Required Language Language Format

NEVER TRANSFER [PRODUCT NAME]

INTO FOOD OR BEVERAGE 

CONTAINERS OR CONTAINERS NOT 

EXPLICITLY INTENDED FOR [PRODUCT 

NAME]

English, Spanish, Pictogram

ONE SIP CAN KILL English, Spanish, Pictogram

CONTACT WITH SKIN MAY RESULT IN 

POISONING

English, Spanish, Pictogram

EXPOSURE TO EYES MAY CAUSE 

SUBSTANTIAL EYE INJURY

English, Spanish, Pictogram

PARAQUAT SHOULD NEVER BE USED 

IN RESIDENTIAL OR PUBLIC 

RECREATIONAL SETTINGS (E.G. 

HOMES, HOME GARDENS, SCHOOLS, 

RECREATIONAL PARKS, GOLF 

COURSES, AND/OR PLAYGROUNDS)

English, Spanish, Pictogram

PARAQUAT SHOULD ALWAYS BE 

STORED TIGHTLY CLOSED IN 

ORIGINAL CONTAINER, AND IN A 

LOCKED PLACE AWAY FROM 

CHILDREN AND ANIMALS

English, Spanish, Pictogram

READ ENTIRE LABEL PRIOR TO 

OPENING THIS PRODUCT

English, Spanish, Pictogram

DISREGARDING LABEL DIRECTIONS IS 

A VIOLATION OF FEDERAL LAW AND 

IS PUNISHABLE BY SUCH

English, Spanish