# Regarding Labeling, (4) Other Comments on the Re smethrin RED, and (5) Pyrethroids Labeling

Initiative.

An updated label table accompanies this document and reflects the changes to the

Resmethrin RED based on public comments a nd the Pyrethroids Labeling Initiative.

Attachments:

• Revised Labeling Changes Summary Table for Resmetherin

• Appendix E: EPA’s Batching of Resmethrin Products for Meeting Acute Toxicity Data

Requirements for Reregistration

• Appendix F: Supplement for PDCI Special Study for Arthropods: Pests of Public Health

Importance and Structural Pests

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# SRRD’s Response to Public Comments to the

Resmethrin Reregistration Eligibility Decision

I. Public Health Uses

Comment: The Delaware Mosquito Control Secti on (DMCS) and Maryland Mosquito Control

Section (MMCS) commented that the underlined portion of following Environmental Hazard

Statement (EHS) is problematic:

“This pesticide is toxic to aquatic organism s, including fish, crustaceans, and oysters.

Runoff from treated areas or deposition of spray droplets into a body of water may be

hazardous to fish, crustaceans and oysters.”

DMCS and MMCS also suggested adding to resmethrin labels the following statement, placing it

at the end of the Environmental Hazard s section on all mosquitocide labels:

“When this product is applied in accordan ce with all label requirements and conditions,

its use poses no unreasonable risks to human health, aquatic organisms, wildlife or the

environment.”

SRRD Response: The Environmental Hazard Statement (EHS) for adult mosquito control

programs is in accordance with EPA’s Pes ticide Registration (PR) Notice 2005-1 (link:

http://www.epa.gov/PR_Notices/pr2005-1.pdf ), “Labeling Statements on Products Used for

Adult Mosquito Contro l.” After considerable pu blic input and discussions with stakeholders the

Agency has adopted this language for all products used in wide area adult mosquito control, not

just the labels for products with resmethrin. Th erefore, the environmental hazard statement will

not be removed or revised to include the sugges tion above for resmethrin products used for wide

area adult mosquito control.

Comment: DMCS commented that the following part of the EHS, “(w)hen applying as a wide

area mosquito adulticide, do not apply over bodies of water (lakes, rivers, permanent streams,

natural ponds, commercial fish ponds, swamps, marshes or estuaries), except when...weather

conditions will facilitated movem ent of applied material away from the water in order to

minimize incidental deposition in to the body of water,” should be advisory, not mandatory, since

resmethrin will cause very little to no adverse effects to non-target organisms. MMCS submitted

similar comments.

SRRD Response: See response above.

Comment: The American Mosquito Control Associat ion (AMCA) recommend a more careful

distinction be made between bodies of open wa ter (e.g. lakes, ponds, or rivers), and bodies of

water characterized by emergent vegetation (e.g. marches or swamps). AMCA also proposed the

following change in label language:

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# “Do not apply over OPEN bodies of water (l akes, rivers, permanent streams, natural

ponds, commercial fish ponds, swamps, marshes or the open waters of estuaries), except

when necessary to target areas where adult mosquitoes are present, and weather

conditions will facilitate mo vement of applied material away from the OPEN water in

order to minimize incidental de position into the water body.”

Further, AMCA recommend this label language s hould be in the Directions for Use Section, and

not the Environmental Hazards Section.

SRRD Response: See response above.

Comment: Beyond Pesticides commented that use of resmethrin for mosquito abatement is not

effective and that resmet hrin should not be approved for mosquito abatement.

SRRD Response: The 2006 Resmethrin RED found the regist ered uses of resmethrin, including

the mosquito abatement use, eligible for reregist ration. All resmethrin products with directions

for use as mosquito abatement are classified as Restricted Use and may only be used by certified

applicators or persons under thei r direct supervision. EPA is cu rrently issuing a product-specific

DCI for resmethrin which will require new efficacy studies to support resmethrin’s uses against

public health pests, including the mosquito abatement use. Depending on the results of the

efficacy studies, EPA may require additional label changes.

II. Registration Review of Pyrethroid Chemicals

Comment: The California Stormwater Quality Associ ation (CASQA), the California Regional

Water Quality Control Board, San Francisco Bay Region (Water Board), and the San Francisco

Department of Environment (SFE) stated concerns that the pyrethroids are not scheduled for

Registration Review until 2010, and mitigation would not occur until 2011. They stated that this

puts municipalities in an untenabl e position because they must comply with the Clean Water Act

immediately. They requested Re gistration Review be initiated immediately for the pyrethroids

or a special review be initiated. Additionally, according to the Water Board, pyrethroids are

anticipated to be the cause of impaired wate r bodies listed on the 2008 303(d) list.

SRRD Response: The Permethrin, Resmethrin, Cypermethr in, Pyrethrins, Piperonyl Butoxide,

and MGK-264 Reregistration Eligibility Decisions were signed in Spring/Summer 2006, and

decisions for non-food pyrethroi ds, including allethrin stereo isomers, tetramethrin, and

sumethrin, were completed in 2008. Therefore, the 2010 date for Registration Review to begin

for the pyrethroid, pyrethrins, and synergists (P PS) group of chemicals allows time for the risk

mitigation and label changes identified in these REDs to be incorporated. Further, in the recent

PPS REDs, the Agency identified a number of limitations in the rere gistration of these

chemicals, such as no urban/residential model av ailable to assess potential ecological risks from

residential uses; and an inability to assess (or compare) ecological impa cts from PPS chemicals

as a group because a large majority were registered after 1984.

In order to address these limitations and allow th e Registration Review risk assessments to be

more refined, there are several on- going efforts to prepare in adva nce for Registration Review of

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# the PPS chemicals. These efforts may include determining whether the pyrethroids share a

common mode of action; revising spray drift language for pyrethroid agricultural labels;

identifying a model and appropriate scenarios for use in urban run-off modeling; compiling

detailed use and usage information about the PP S chemicals, both agricultural and residential

uses; and identifying data needs. Additionally, the Agency is coordinating with the California

Department of Pesticide Regula tion (CDPR), which is currently conducting its reevaluation of

pyrethroids. The reevaluation includes calling in new and additional data, which will be useful

to the Agency’s Registration Review process of the PPS chemicals which begins in 2010 for

some chemicals. Therefore, the Agency does not believe it would be prudent to initiate the

Registration Review of the PPS chemicals a ny earlier than currently scheduled.

Comment: CASQA, the Water Board, and SFE commented that resmethrin should be included in

any pyrethroids group DCI. They commented that EPA should require submittal of these data as

soon as possible, and that submitt ed data should be shared with the public in a timely manner,

because it may be critical to their water quality compliance activities. They requested that EPA

consult with them and offer an oppor tunity for public input during development of the DCI. They

also commented that the CDPR has placed all py rethroids into re-evalu ation and requested that

EPA review all data submitted to CDPR.

SRRD Response: The Agency is in the process of pl anning for the pyrethroid Registration

Review process. As part of the initial phase of Registration Review, a preliminary work plan

will provide an opportunity for stakeholders to comment on the anticipated data the Agency will

require in order to complete a risk assessment. Si nce this will be the firs t chance to evaluate all

of the pyrethroids, pyrethrins, and synergists at once it will be a good opportuni ty to call in data

necessary to assess the chemicals together. The Agency is continuing to coordinate with the

CDPR, and the two organizations ha ve continued to share data and reviews on these chemicals.

III. Comments Regarding Labeling

Comment: CASQA, the Water Board, and SFE submitted similar comments suggesting that EPA

provide flexibility to reduce the treated area in building perimeter treatments by requiring

product labels to clarify that widths narrower than those specified on the label are allowable.

They also suggested that EPA requi re data exploring the pot ential to revise label directions for

“band around building” applications, and that EPA require manufacturers to determine the

minimum band width and application frequency for ant control.

SRRD Response: The Agency believes that the use direct ions referenced above, which call for a

band up to 6 to 10 feet away from the building and up to 3 feet up the walls of the building,

already allow for applications less than the maxi mum height and width specified on the label.

However, in order to ensure this flexibility is clear to all applicators, the following statement has

been added to the amended label table:

“For Band applications to and around build ings foundations, band up to a maximum of

10 feet away from the building and up to a maximum of 3 feet up the walls of the

building.”

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# Comment: The Los Angeles County Sanitation Distri cts (LACSD) and Tri-TAC suggested EPA

add aquatic hazard label language to a ll indoor-use products, such as:

“This pesticide is extremely toxic to fis h, aquatic organisms, and oysters/shrimp. Local

sewage treatment agency regulations should be consulted before any indoor use that

may result in a down-the-drain discharge.”

Also, SFE commented that “all products – incl uding indoor use products – should be labeled

with the aquatic environmental hazard st atement required for outdoor products.”

SRRD Response: Through various labeling initiatives (som e discussed in the Section V below)

EPA hopes to reduce the overall amount of resmet hrin discharged into both storm water and

sewage drainage systems. However, at this time, the Agency does not believe adding aquatic

environmental hazard statements, similar to the environmental hazard statements on outdoor

products, is appropriate on indoor use products, since local sewage treatment plants may not be

equipped to deal with many consumer calls. For cases when indoor products may be formulated

in a large package, the product must contain disc harge information on the product label, which is

included below.

The following environmental hazard s statements, which were required in the original RED, are still

required for all i ndoor use products.

“This pesticide is toxic to aquatic organisms, including fish and invertebrates. Do not

contaminate water when disposi ng of equipment wash waters.”

For commercial, industrial, and institutional use pr oducts packaged in contai ners equal or greater

than 5 gallons or 50 labs, add the following statement:

“Do not discharge effluent containing this pr oduct into lakes, str eams, ponds, estuaries,

oceans, or other waters unless in accordan ce with the requirements of a National

Pollutant Discharge Elimination System (N PDES) permit and the permitting authority

has been notified in writing prio r to discharge. Do not disc harge effluent containing this

product to sewer systems without previously notifying the local se wage treatment plant

authority. For guidance contac t your State Water Board or Regional Office of the EPA.”

Comment: CASQA recommended the Agency clarify the additional application restrictions for

outdoor residential products on the label intende d to prevent the release of resmethrin into

urban sewers and streams. CASQA stated the lan guage would more fully meet this intent if

modified as stated in their comments. Th e Water Board and SFE also submitted similar

comments.

SRRD Response : Since the resmethrin RED was finalize d, the Agency has finalized PR Notice

2008-1 that allows registrants to voluntarily change their envi ronmental hazard statements on

residential products so users will be able to better understand how to apply consumer products to

minimize environmental risk. The statements in cluded in this PR Notice are similar to the

language that was required in the resmethrin RED, and the intention is the same for both

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# statements. Therefore, the Resmethrin RED labeling will be updated to require the same

environmental hazard statements for residentia l products that are included in PR Notice 2008-1.

Comment: CASQA also stated that professional products for urban use (i.e., products for

landscaping, rights of way, etc.) should ha ve stewardship language on their labels. CASQA

included labeling suggestions in their comments. The Water Board and SFE also submitted

similar comments.

SRRD Response : The Agency agrees that resmethrin products for professional use should have

language on the labels to prevent the run-off of resmethrin residues down storm drains.

Therefore, in addition to the revisions made to the environmental hazard statements, the

following statements have been added to the amended resmethrin label table for end use products

primarily intended for occupational use, whic h includes occupational use by commercial pest

control operators:

“Application directly into sewers or drains, or to any area like a gutter where

drainage to sewers, storm drains, water bodies, or aqua tic habitat can occur, is

prohibited. Do not allow the product to enter any drai n during or after

application.”

Comment: CASQA submitted comments suggesting that EPA use icons to communicate water

quality stewardship concepts. CASQA recomme nded that EPA require resmethrin and other

pyrethroid product labels to include compelling icons to quickly convey potential water quality

and environmental risks to residential users, and suggested that the icon types proposed for

metaldehyde labels are a good example.

SRRD Response: EPA does not anticipate adding icons to the resmethrin labels at this time, but

may consider the suggestion during Registration Review.

Comment: Valent Biosciences submitted the followi ng comment on the environmental hazards

statements:

Environmental Hazards

Delete the word “precautions” from the last sentence “See directions for use for

additional precautions and requirements” because the header “precautionary

statements” is used for other types of statements and this could cause confusion.

SRRD Response: The suggested change has been made in the revised version of the label table.

Comment: Beyond Pesticides commented that c hanging label language is an unrealistic method

of risk mitigation and stated that EPA must use othe r risk mitigation measures (i.e. restrict use)

to be effective.

SRRD Response: The label on a pesticide package or container and the accompanying

instructions are a key part of regulating pesticides. Using a pesticide in a manner that is

7

# inconsistent with the use directions on the la bel is a violation of th e Federal Insecticide,

Fungicide, and Rodenticide Act (FIFRA) and can re sult in enforcement actions to correct the

violations. Based on the results of the risk a ssessments conducted for th e Resmethrin RED, EPA

believes that changes to the labeling are needed to reduce potential risks to human health and the

environment. In addition, for one of the uses of resmethrin, the mosquito abatement use, the

Agency has determined additional steps are necessa ry to protect fish; ther efore, resmethrin is

classified as Restricted Use due to acute fish toxicity. If the new da ta and risk assessments

indicate changes to the mitigation or registered uses, this will be addressed during Registration

Review.

Comment: Valent Biosciences suggested the following labeling changes:

Automatic Misting Systems & I ndoor Metered Spray Systems

Delete statements “Do not use in automatic misting systems” and “Do not use in indoor

metered spray systems” because the dire ctions for use are not on the label and the

statements would imply that the product was previously registered for these uses.

SRRD Response: The label language referenced above is a part of EPA’s goal to ensure that

only pesticides that have been evaluated for use in misters are used in misters. EPA has included

this statement on the label of products not approv ed for use in misters to prevent any improper

use in residential misting systems, since S ection 2(ee) of FIFRA permits the use of any

application methods that are not specifical ly prohibited by the pesticide’s labeling.

IV. Other Comments on the Resmethrin RED

Comment: LACSD and Tri-TAC request ed that EPA include a tim e schedule for the aquatic

toxicity tests required in the RED (and comp lete testing prior to Registration Review).

SRRD Response: EPA is currently issuing a product-sp ecific DCI for resmethrin based on the

data needs identified in the 2006 Resmethrin RED. Results of these studies will be considered

when risk assessments are conducted during Re gistration Review. Cu rrently, the pyrethroid

chemicals are scheduled to begi n Registration Review in 2010.

Comment: The Water Board and CASQA suggested steps to be taken in the near term in their

comments to the Agency. These steps include EPA completing a cumulative environmental risk

assessment for pyrethroids; completing an alternativ es assessment that considers both low risk

and non-pesticide alternatives; co mpleting a cluster assessment for problematic outdoor urban

insecticide applicati on; and assessing whether urban uses of pyrethroids pose unreasonable

risks, taking into account th e above information and the cost of non-compliance with the Clean

Water Act.

SFE also submitted a similar comment suggesti ng EPA complete a cumulative human health risk

assessment and an alternatives/benefits assessment to evaluate the wide range of pesticidal,

cultural, and physical controls that are available for the labe led uses of resmethrin and

pyrethroids in general, and par ticularly for outdoor urban uses.

8

# 9 SRRD Response: As stated above, EPA is in the pro cess of planning for the Registration

Review of pyrethroids, pyrethrins, and synergis ts chemicals which is the first opportunity the

Agency will have to evaluate a ll of the pyrethroids at the same time. In the Resmethrin RED, a

number of issues related to water modeling were raised. The Agency is planning to continue to

address these issues in Registra tion Review and consider benefits when necessary for resmethrin

and the other pyrethroids.

Comment: Beyond Pesticides commented that “EPA must incorporate expected increases in

market share into exposures for all scenarios. The entire market for non- agricultural insecticide

use is changing as a result of the phase out of most urban uses of diazinon and chlorpyrifos

(Dursban) as well as possible restrictions to other organophosphate and carbamate insecticides.

The possibility of a market increase must be accounted for in the exposure assessments.”

SRRD Response: The 2006 Resmethrin RED considered th e registered uses of resmethrin at

that time. Likewise, the exposure scenarios in the risk assessments for the RED reflect data

available to the EPA on use patterns at the tim e the assessments were conducted. Registration

Review for pyrethroid chemicals wi ll be starting in 2010, and is in tended to make sure that, as

the ability to assess risk evolve s and as policies and practices ch ange, all registered pesticides

continue to meet the statutory standard of no unreasonable adverse effects. Changes in science,

public policy, and pesticide use practices will occur over time. Through the Registration Review

program, the Agency periodically reevaluates pestic ides to make sure that as change occurs,

products in the marketplace can be used safely. EPA will request up-to-date use and usage

information for resmethrin during the upcoming Registration Review process and incorporate

changes as applicable in th e risk assessments conducted for Registration Review.

V. Pyrethroids Labeling Initiative

Recent pyrethroid data submitted to the Agency, as well as water quality monitoring efforts in

California, have highlighted ex isting concerns regarding exposu re of aquatic organisms and

habitats to pyrethroid chemicals. To addre ss these concerns, the Agency has worked with

various stakeholders to develop label statements specific to pyrethroid non-agricultural use

patterns which will serve to reduce potential runoff and drift that can result from non-agricultural

applications of pyrethroid end-use products.

The label statements appearing in the Directions for Use section of the label include formulationand use-specific statements, which are largel y based on non-agricultural best management and

good stewardship practices. The Agency is also implementing the PR Notice 2008-1

“Environmental Hazard General Labeling Statem ents on Outdoor Residential Use Products” on

all pyrethroid non-agricultural out door products. These environm ental hazard statements are

also formulation- specific and contain clear, concise, easy-to-read information which will also

serve to reduce potential off-site runoff and drift.

The new label statements to be included in th e “Directions for Use” and “Environmental Hazards

Statement” sections of revised resmethrin produc t label(s) are included in the attached amended

label table.Revised Labeling Changes Summary Table for ResmethrinThis Labeling Changes Summary Table includes labeling changes based on comments received during the Public Comment period onthe Resmethrin RED, as well as labeling changes developed in consultation with variousstakeholders as part of the PyrethroidsLabeling Initiative. In order to be eligible for reregistration, amend all product labels to incorporate the risk mitigation measuresoutlined in Section IV of the Resmethrin RED. The followingtable describes how language on the labels should be amended.Table 25: Summary of Labeling Changes for ResmethrinDescriptionManufacturing Use ProductsPlacement on LabelFormulation instructionsrequired on all manufacturinguse products“Only for formulation into an insecticide for the following use(s) [fill blank only with thoseuses that are being supported by MP registrant].”“Not for formulation into end use products for use in indoor metered spray systems.”“Not for formulation into end use products for use in outdoor misting systems.”Directions for UseOne of these statements may beadded to a label to allowreformulation of the productfor a specific use or alladditional uses supported by aformulator or user group“This product may be used to formulate products for specific use(s) not listed on the MP labelif the formulator, user group, or grower has complied with U.S. EPA submission requirementsregarding support of such use(s).”“This product may be used to formulate products for any additional use(s) not listed on the MPlabel if the formulator, user group, or grower has complied with U.S. EPA submissionrequirements regarding support of such use(s).”Directions for UseEnvironmental HazardsStatements Required by theRED and Agency LabelPolicies"Environmental HazardsThis product is toxic to fish, aquatic invertebrates, and oysters/shrimp. Do not dischargeeffluent containing this product into lakes, streams, ponds, estuaries, oceans, or other watersunless in accordance with the requirementsof a National Pollution Discharge EliminationSystem (NPDES) permit and the permitting authority has been notified in writing prior todischarge. Do not discharge effluent containing this product to sewer systems withoutpreviously notifying the local sewage treatment plant authority. For guidance contact yourState Water Board or Regional Office of the EPA."Precautionary Statements10End Use Products Intended for Occupational UseExcludes Products Intended for Usein Wide Area Mosquito AbatementPrograms (See below requirements)PPE Requirements Establishedby the RED1for Liquid Formulations(excludes formulations appliedvia ready-to-use aerosols)“Personal Protective Equipment (PPE)Some materials that are chemical-resistant to this product are (registrant inserts correctchemical-resistant material). If you want more options, follow the instructions for category[registrant inserts A,B,C,D,E,F,G,or H] on an EPA chemical-resistance category selectionchart.All mixers, loaders, applicators, and other handlers must wear:- long sleeved shirt and long pants,- socks plus shoes, and- chemical resistant gloves.Applicators using handheld fog equipment must wear:- coveralls over long sleeved shirt and long pants,- chemical-resistant gloves,- chemical-resistant footwear plus socks,- chemical-resistant headgear, if overhead exposure,- chemical-resistant apron when mixing, loading, and cleaning equipment or spills, and- A NIOSH-approved respriator with-- a dust/mist filter with MSHA/NIOSHapproval number prefix TC-21C or-- any N* R, P, or He filter.”*Instruction to Registrant: Drop the “N” type prefilter from the respirator statement, if thepesticide product contains, or is used with, oil.Immediately following/belowPrecautionary Statements:Hazards to Humans and DomesticAnimalsPPE Requirements Establishedby the RED1for Ready-to-use AerosolProducts“Personal Protective Equipment (PPE)Some materials that are chemical-resistant to this product are (registrant inserts correctchemical-resistant material). If you want more options, follow the instructions for category[registrant inserts A,B,C,D,E,F,G,or H] on an EPA chemical-resistance category selectionchart.All applicators and other handlers must wear:- long sleeved shirt, long pants, and- socks plus shoes, and- chemical-resistant gloves.”Immediately following/belowPrecautionary Statements:Hazards to Humans and DomesticAnimals11User Safety Requirements“Follow manufacturer's instructions for cleaning/maintaining PPE. If no such instructions forwashables exist, use detergent and hot water. Keep and wash PPE separately from otherlaundry.”Precautionary Statements:Hazards to Humans and DomesticAnimals immediately followingthe PPE requirementsUser Safety Recommendations“User Safety RecommendationsUsers should wash hands before eating, drinking, chewing gum, using tobacco, or using thetoilet.Users should remove clothing/PPE immediately if pesticide gets inside. Then wash thoroughlyand put on clean clothing.Users should remove PPE immediately after handling this product. Wash the outside of glovesbefore removing. As soon as possible, wash thoroughly and change into clean clothing.”Precautionary Statements under:Hazards to Humans and DomesticAnimals immediately followingEngineering Controls(Must be placed in a box.)Environmental hazardstatements on LiquidConcentrate outdoor products(e.g., soluble concentrates andemulsifiable concentrates)Note: Products with indooruses only see below“Environmental HazardsThis pesticide is toxic to fish, aquatic invertebrates, and oysters/shrimp.To protect the environment, do not allow pesticide to enter or run off into storm drains,drainage ditches, gutters or surface waters. Applying this product in calm weather when rain isnot predicted for the next 24 hours will help to ensure that wind or rain does not blow or washpesticide off the treatment area. Rinsing application equipment over the treated area will helpavoid run off to water bodies or drainage systems.This product may contaminate water through runoff. This product has a potential for runoff forseveral days after application. Poorly drainingsoils and soils with shallow water tables aremore prone to produce runoff that contains this product. A level, well maintained vegetativebuffer strip between areas to which this productis applied and surface water features such asponds, steams, and springs will reduce the potential for contamination of water from rainfallrunoff. Runoff of this productwill be reduced by avoiding applications when rainfall isforecasted to occur within48 hours. Sound erosion control practices will reduce this product’scontribution to surface water contamination.This product is highly toxic to bees exposed to direct treatment on blooming crops or weeds.Do not apply this product or allow it to drift toblooming crops or weeds while bees are activelyvisiting the treatment area.See Directions for Use for additional requirements.”Environmental Hazard Statement12Environmental hazardstatements on Liquid Ready-toUse consumer outdoor products(except aerosols)Note: Products with indooruses only see below“Environmental HazardsThis pesticide is toxic to fish, aquatic invertebrates, and oysters/shrimp.To protect the environment, do not allow pesticide to enter or run off into storm drains,drainage ditches, gutters or surface waters. Applying this product in calm weather when rain isnot predicted for the next 24 hours will help to ensure that wind or rain does not blow or washpesticide off the treatment area.This product may contaminate water through runoff. This product has a potential for runoff forseveral days after application. Poorly drainingsoils and soils with shallow water tables aremore prone to produce runoff that contains this product. A level, well maintained vegetativebuffer strip between areas to which this productis applied and surface water features such asponds, steams, and springs will reduce the potential for contamination of water from rainfallrunoff. Runoff of this productwill be reduced by avoiding applications when rainfall isforecasted to occur within48 hours. Sound erosion control practices will reduce this product’scontribution to surface water contamination.This product is highly toxic to bees exposed to direct treatment on blooming crops or weeds.Do not apply this product or allow it to drift toblooming crops or weeds while bees are activelyvisiting the treatment area.See Directions for Use for additional requirements.”Environmental Hazard StatementEnvironmental HazardStatements for Ready to Useaerosol and fogger outdoorproducts“This pesticide is toxic to fish, aquatic invertebrates, and oysters/shrimp.Do not apply directlyto or near water. Drift and run-off may be hazardous to fish in water adjacent to treated areas.Do not contaminate water when disposing of equipment, washwater, or rinsate. See Directionsfor Use for additional precautions and requirements.”"This product may contaminate water through runoff. This product has a potential for runofffor several days after application. Poorly draining soils and soils with shallow water tables aremore prone to produce runoff that contains this product. A level, well maintained vegetativebuffer strip between areas to which this productis applied and surface water features such asponds, steams, and springs will reduce the potential for contamination of water from rainfallrunoff. Runoff of this productwill be reduced by avoiding applications when rainfall isforecasted to occur within48 hours. Sound erosion control practices will reduce this product’scontribution to surface water contamination.”“This product is highly toxic to bees exposed to direct treatment on blooming crops or weeds.Environmental Hazard Statement13Do not apply this product or allow it to drift toblooming crops or weeds while bees are activelyvisiting the treatment area.”Environmental Hazards forproducts that only containindoor use sitesNote to registrant:Products labeled solely for indoor use except as noted below may omit the EnvironmentalHazards statements. Such products must havethe following statement in the Directions forUse:“For indoor use only.”Precautionary Statementsimmediately following the UserSafety RecommendationsEnvironmental Hazards forIndoor Use Products packagedin containers equal to or greaterthan 5 gallons or 50 lbs“This pesticide is toxic to fish, aquatic invertebrates, and oysters/shrimp. Do not dischargeeffluent containing this product into lakes, streams, ponds, estuaries, oceans, or other watersunless in accordance with the requirementsof a National Pollution Discharge EliminationSystem (NPDES) permit and the permitting authority has been notified in writing prior todischarge. Do not discharge effluent containing this product to sewer systems withoutpreviously notifying the local sewage treatment plant authority. For guidance contact yourState Water Board or Regional Office of the EPA."Precautionary StatementsRestricted-Entry Interval forproducts with directions for usewithin the scope of the WorkerProtection Standard forAgricultural Pesticides (WPS)“Do not enter or allow worker entry into treated areas during therestricted entry interval (REI)of 12 hours.”Directions for Use, UnderAgricultural Use RequirementsBoxEntry Restrictions for allproducts with indoor use sitesAND directions for use outsidethe scope of the WPS.For products applied as crack and crevice and surface sprays:“Do not enter or allow other people (or pets) to enter the treated area until sprays have dried.”For products applied as space sprays or fogs:“Close doors, windows and shut off all ventilation equipment before application. Leave thetreated area. Post signs on entrances stating that the area has been treated with resmethrin andthat it is to remain closed for at least 4 hours after application. Do not re-enter and do not allowanyone else to re-enter the site for 4 hours. Ventilate thoroughly before anyone is allowed tore-enter.- Ventilate thoroughly for 20 minutes for treatment of less than 10,000 cubic feet of space.- Ventilate thoroughly for 60 minutes for treatment of less than 50,000 cubic feet of space.- Ventilate thoroughly for 120 minutes for treatment of greater than 50,000 cubic feet ofspace.”If no WPS uses on the product,place the appropriate statementin the Directions for Use UnderGeneral Precautions andRestrictions If the product alsocontains WPS uses, then create aNonAgricultural UseRequirements box as directed inPR Notice 93-7 and place theappropriate statement inside thatbox.Early Entry Personal ProtectiveEquipment for products withdirections for use within thescope of the WPS“PPE required for early entry totreated areas that is permitted under the Worker ProtectionStandard and that involves contact with anythingthat has been treated, such as plants, soil, orwater, is:- coveralls,- shoes plus socksDirections for Use Inside theAgricultural Use RequirementsBox14- chemical-resistant gloves madeof any waterproof material.”Additional ApplicationRestrictions For GeneralOutdoor Surface and SpaceSprays, except for outdoorfogging devices.“Do not water the treated area to the point of run-off.All outdoor applications must be limited to spot or crack-and-crevice treatments only, exceptfor the following permitted uses:(1) Treatment to soil or vegetation around structures;(2) Applications to lawns, turf, and other vegetation;(3) Applications to building foundations, up to a maximum height of 3 feet.Other than applications to building foundations,all outdoor applications to impervious surfacessuch as sidewalks, driveways, patios, porches and structural surfaces (such as windows, doors,and eaves) are limited to spot and crack-and-crevice applications, only.”Note to registrant: If the end use product does not contain directions for use consistent with theexceptions above the exceptions maybe eliminated from the label.Directions for UseGeneral ApplicationRestrictions for all products“Application directly into sewers or drains,or to any area like a gutter where drainage tosewers, storm drains, water bodies, or aquatic habitat can occur, is prohibited. Do not allow theproduct to enter any drain during or after application.”Directions for UseGeneral ApplicationRestrictions“Do not apply this product in a way that will contact workers or other persons, either directly orthrough drift. Only protected handlers may be in the area during application.”Place in the Direction for Usedirectly above the AgriculturalUse Box.Use-Specific ApplicationRestrictionsLabeling required on all products:“Do not use in indoor metered spray systems.”“Do not use in automatic misting systems.”Note: Registrants must amend the label to include the maximum allowable application rate andmaximum allowable rate per year must be listed as pounds or gallons of formulated productsper acre or 1000 ft2, not just as pounds active ingredient per acre or 1000 ft2.Products labeled for use on Livestock, Farm Animals, and Pets (Direct Application):“Do not apply with product containing more than 0.35% ai.”Products labeled for use in Outdoor Sites (Commercial, Recreational, Domestic Outdoor Sites,Agricultural Structures, Agricultural Premises, and Agricultural Equipment):“Do not apply more than 0.25 lb ai per acre.”ORDirections for Use15For ready-to-use products, registrants must amend their labels to specify use rates that result inno more than 0.25 lb ai per acre.Products labeled for use in Space Applications (Greenhouses; Indoor FoodHandling/Processing/Eating Establishments; Commercial Structure Premises and Equipment;Domestic Structure Premises and Equipment):“Do not apply more than 0.001 lb ai per 1000 ft2.”ORFor ready-to-use products, registrants must amend their labels to specify use rates that result inno more than 0.001 lb ai per 1000 ft2.Products labeled for use in Surface Crack and Crevice Application (Greenhouses; Indoor FoodHandling/Processing/Eating Establishments; Commercial Structure Premises and Equipment;Domestic Structure Premises and Equipment):“Do not apply more than 0.242 lb ai per 1000 ft2.”ORFor ready-to-use products, registrants must amend their labels to specify use rates that result inno more than 0.242 lb ai per 1000 ft2Products labeled for indoor use sites:“Remove pets, birds, and cover aquariums and turn off air pumps before application.In food processing operations, homes, or any other location where food isprepared or served,do not apply this product while food is exposed or being processed. Cover or remove allexposed food, packaging material,and food contact surfaces. Donot apply directly to food,packaging material, or any food contact surfaces.Remove or cover dishes, utensils, food processing equipment and food preparation surfacesbefore use of this product. All food processing surfaces and equipment in the treatment areamust be covered or washed with an effective cleaning compound followed by a potable waterrinse after use of this product.”Products labeled for use on and around buildings and other structures:“For Band applications to and around buildings foundations, band up to a maximum of10 feet away from the building and up toa maximum of 3 feet up the walls of thebuilding.”16For End-Use Products Intended for Wide Area Mosquito Abatement Programs OnlyRestricted Use Pesticide“Restricted Use Pesticide. Due toAcute Fish Toxicity. For retail sale to and use only bycertified applicators or persons under their direct supervision and only for those uses coveredby the certified applicator’s certification. Direct supervision for this product is defined as thecertified applicator being physically present during mixing, loading, equipment repair andequipment cleaning. Certified applicators must ensure that all persons involved in theseactivities under their direct supervision areinformed of the precautionary statements.”Top front panelPPE Requirements Establishedby the RED1“Personal Protective Equipment (PPE)Some materials that are chemical-resistant to this product are (registrant inserts correctchemical-resistant material). If you want more options, follow the instructions for category[registrant inserts A,B,C,D,E,F,G,or H] on an EPA chemical-resistance category selectionchart.All mixers, loaders, applicators, and other handlers must wear:- long sleeved shirt and long pants,- socks plus shoes, and- chemical-resistant gloves for all handlers except applicators.See engineering controls for additional requirements.”Immediately following/belowPrecautionary Statements:Hazards to Humans and DomesticAnimalsUser Safety Requirements“Follow manufacturer's instructions for cleaning/maintaining PPE. If no such instructions forwashables exist, use detergent and hot water. Keep and wash PPE separately from otherlaundry.”Precautionary Statements:Hazards to Humans and DomesticAnimals immediately followingthe PPE requirementsEngineering ControlsEngineering Controls:“Applicators using ground mechanical application equipment must use an enclosed cab that hasa nonporous barrier that totally surrounds the occupants and prevents contact with pesticidesoutside the cab. Must be provided and have immediately available for use upon exiting the cabchemical-resistant gloves.”“Pilots must use an enclosed cockpit. The cockpit must have a nonporous barrier that totallysurrounds the occupants and prevents contact withpesticides outside the cab. Pilots must wearthe PPE specified in this label for applicators.”Precautionary Statements:Hazards to Humans and DomesticAnimals (Immediately followingPPE and User SafetyRequirements.)17User Safety Recommendations“User Safety RecommendationsUsers should wash hands before eating, drinking, chewing gum, using tobacco, or using thetoilet.Users should remove clothing/PPE immediately if pesticide gets inside. Then wash thoroughlyand put on clean clothing.Users should remove PPE immediately after handling this product. Wash the outside of glovesbefore removing. As soon as possible, wash thoroughly and change into clean clothing.”Precautionary Statements under:Hazards to Humans and DomesticAnimals immediately followingEngineering Controls(Must be placed in a box.)Environmental Hazards“This pesticide is toxic to aquatic organisms, including fish, crustaceans, and oysters. Runofffrom treated areas or deposition of spray droplets into a body of water may be hazardous tofish, crustaceans, and oysters.”“Do not apply when bees are visiting the treatment area, except when applications are made toprevent or control a threat to public and/or animalhealth determined by astate, tribal, or localhealth or vector control agency on the basis ofdocumented evidence ofdisease causing agentsin vector mosquitoes or theoccurrence of mosquito-bornedisease in animal or humanpopulations, or if specifically approved by the state or tribe during a natural disaster recoveryeffort.”“Before making the first application in a season, it isadvisable to consult with the state or tribalagency with primary responsibility for pesticideregulation to determine if other regulatoryrequirements exist.”“Do not apply over bodies of water (lakes, rivers, permanent streams, natural ponds,commercial fish ponds, swamps, marshes or estuaries), except when necessary to target areaswhere adult mosquitoes are present, and weather conditions will facilitate movement of appliedmaterial away from the water in order to minimize incidental deposition into the water body.Do not contaminate bodies of water when disposing of equipment rinsate or washwaters.”Precautionary Statementsimmediately following the UserSafety RecommendationsUse-Specific ApplicationRestrictionsUse-Specific Application Restrictions“For use by federal, state, tribal, or local government officials responsible for public health orvector control, or by persons certified in the appropriate category or otherwise authorized bythe state or tribal lead pesticide regulatory agency to perform adult mosquito controlapplications, or by persons under their direct supervision.”Use-Specific ApplicationRestrictions18“Do not apply more than 0.007lb ai/acre per application.”“Do not apply more than 0.2 lb ai/acre per yearin any treated area. More frequent treatmentsmay be made to prevent or control a threat to public and/or animal health determined by a state,tribal, or local health or vectorcontrol agency on the basis ofdocumented evidence of diseasecausing agents in vector mosquitoes or the occurrence of mosquito-borne disease in animal orhuman populations, or if specifically approved by the state or tribe during a natural disasterrecovery effort.”Products must comply with EPA PR Notice 2005-1.WIND SPEED:“Do not apply when wind speed is 0 mph.”DROPLET SIZE:“Ground-based application:Spray equipment must be adjusted so that the volume median diameter is less than microns (Dv0.5 < 8-30 um) and that 90% of the spray is contained in droplets smaller than microns (Dv 0.9< 50 um). Directions from the equipment manufacturer or vendor, pesticide registrant or a testfacility using a laxer-based measurement instrument must be used to adjust equipment toproduce acceptable droplet size spectra. Application equipment must be tested at least annuallyto confirm that pressure at the nozzle andnozzle flow rate(s) are properly calibrated.”“Aerial Application:Spray equipment must be adjusted so that thevolume median diameter produced is less thanmicrons (Dv 0.5 < 60 um) and that 90% of the spray is contained in droplets smaller thanmicrons (Dv 0.9 < 80 um). The effects of flight speed, and for non-rotary nozzles, nozzle angleon the droplet size spectrum must be considered.Directions from the equipment manufactureror vendor, pesticide registrant or a testfacility using a wind tunnel and laser-basedmeasurement instrument must be used to adjust equipment to produce acceptable droplet sizespectra.EQUIPMENT CALIBRATION:Application equipment must be tested at leastannually to confirm that pressure at the nozzleand nozzle flow rate(s) are properly calibrated.”19RELEASE HEIGHT:Fixed wing:“Apply using a nozzle height of no less than 100 feet above the ground or canopy.”Rotary wing:“Apply using a nozzle height of no less than 75 feet above the ground or canopy.”20End Use Products Primarily Used by ConsumersApplication Restrictions“Do not apply this product in a way that will contact any person or pet, either directly orthrough drift. Keep people and pets out of the area during application.”Directions for Use underGeneral Precautions andRestrictionsEntry RestrictionsFor products applied as crack and crevice and surface sprays:“Do not enter or allow other people (or pets) to enter the treated area until sprays have dried.”For products applied as space sprays or fogs:“Close doors, windows and shut off all ventilation equipment before application. Leave treatedarea closed for at least 2 hours after application. Do not remainin treated area(s). Ventilatethoroughly for 20 minutes with fresh air before re-occupying treated area(s).”Directions for use under GeneralPrecautions and RestrictionsEnvironmental hazardstatements on LiquidConcentrate outdoor products(e.g., soluble concentrates andemulsifiable concentrates)For products that have outdoor uses:“This product is extremely toxic to fish, aquatic invertebrates, and oysters/shrimp.To protect the environment, do not allow pesticide to enter or run off into storm drains,drainage ditches, gutters or surface waters. Applying this product in calm weather when rain isnot predicted for the next 24 hours will help to ensure that wind or rain does not blow or washpesticide off the treatment area. Rinsing application equipment over the treated area will helpavoid run off to water bodies or drainage systems.This product is highly toxic to bees exposed to direct treatment on blooming crops or weeds.Do not apply this product or allow it to drift toblooming crops or weeds while bees are activelyvisiting the treatment area.See Directions for Use for additional requirements.”Environmental Hazard StatementEnvironmental hazardstatements on Liquid Ready-toUse consumer outdoor products(except aerosols)For products that have outdoor uses:“This product is extremely toxic to fish, aquatic invertebrates, and oysters/shrimp.To protect the environment, do not allow pesticide to enter or run off into storm drains,drainage ditches, gutters or surface waters. Applying this product in calm weather when rain isnot predicted for the next 24 hours will help to ensure that wind or rain does not blow or washpesticide off the treatment area.This product is highly toxic to bees exposed to direct treatment on blooming crops or weeds.Environmental Hazard Statement21Do not apply this product or allow it to drift toblooming crops or weeds while bees are activelyvisiting the treatment area.See Directions for Use for additional requirements.”Environmental HazardStatements for Ready to Useaerosol and fogger consumeroutdoor products“This pesticide is toxic to fish, aquatic invertebrates, and oysters/shrimp.Do not apply directlyto or near water. Drift and run-off may be hazardous to fish in water adjacent to treated areas.Do not contaminate water when disposing of equipment, washwater, or rinsate. See Directionsfor Use for additional precautions and requirements.”"This product may contaminate water through runoff. This product has a potential for runofffor several days after application. Poorly draining soils and soils with shallow water tables aremore prone to produce runoff that contains this product. Avoid applying this product to ditches,swales, and drainage ways. Runoff of this product will be reduced by avoiding applicationswhen rainfall is forecasted tooccur within48 hours."“This product is highly toxic to bees exposed to direct treatment on blooming crops or weeds.Do not apply this product or allow it to drift toblooming crops or weeds while bees are activelyvisiting the treatment area.”Environmental Hazard StatementAdditional ApplicationRestrictions For GeneralOutdoor Surface and SpaceSprays, except for outdoorfogging devices.“Do not water the treated area to the point of run-offAll outdoor applications must be limited to spot or crack-and-crevice treatments only, exceptfor the following permitted uses:(1) Treatment to soil or vegetation around structures;(2) Applications to lawns, turf, and other vegetation;(3) Applications to building foundations, up to a maximum height of 3 feet.Other than applications to building foundations,all outdoor applications to impervious surfacessuch as sidewalks, driveways, patios, porches and structural surfaces (such as windows, doors,and eaves) are limited to spot and crack-and-crevice applications, only.”Note to registrant: If the end use product does not contain directions for use consistent with theexceptions above the exceptions may be eliminated from the label.Directions for UseGeneral ApplicationRestrictions for all products“Application directly into sewers or drains,or to any area like a gutter where drainage tosewers, storm drains, water bodies, or aquatic habitat can occur, is prohibited. Do not allow theproduct to enter any drain during or after application.”Directions for UseUse-Specific ApplicationRestrictionsLabeling required on all products applied as sprays:“Do not use in indoor metered spray systems.”“Do not use in automatic misting systems.”Directions for Use2223APPLICATION RATE RESTRICTIONS:Products containing greater than 0.35% ai must not be labeled for use on pets.Note: Registrants must amend the label to reflect the below maximum allowable applicationrate per year. The rate must be listed as pounds or gallons of formulated product per acre or1000 ft2, not just as pounds active ingredient per acre or 1000 ft2. For ready-to-use products,registrants must amend their labels to specify use rates that will result in the below maximumapplication rates.Products labeled for use in Outdoor Sites (Backyard, patios, and ornamentals):Maximum application rate 0.25 lb ai per acre.Products labeled for Space Application (domestic dwellings):Maximum application rate 0.001 lb ai per 1000 ft2.“Do not use more than 3 times a year.”Products labeled for Surface Crack and Crevice Application (domestic dwellings):Maximum application rate 0.242 lb ai per 1000 ft2.OTHER RESTRICTIONS:Products labeled for use in indoor use sites:“Remove pets, birds, and cover aquariums and turn off air pumps before application.”“In homes or any other location where food is prepared or served, do not apply this productwhile food is exposed or being processed. Cover or remove all exposed food and food contactsurfaces. Do not apply directlyto food, packaging material,or any food contact surfaces.”“Remove or cover dishes, utensils, food processing equipment and foodpreparation surfacesbefore use of this product. All food processing surfaces and equipment in the treatment areashould be covered or washed with an effective cleaning compound followed by a potable waterrinse after use of this product.”24Products labeled for use on and around buildings and other structures:“For Band applications to and around buildings foundations, band up to a maximum of10 feet away from the building and up toa maximum of 3 feet up the walls of thebuilding.”1PPE that is established on the basis of Acute Toxicity of the end-use product must be compared to the active ingredient PPE inthis document. The moreprotective PPE must be placed in the product labeling. For guidance on which PPE is considered more protective, see PR Notice93-7.