Regarding Labeling, (4) Other Comments on the Resmethrin 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 and 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 

2
SRRD’s Response to Public Comments to the 

Resmethrin Reregistration Eligibility Decision 

I. Public Health Uses 

Comment: The Delaware Mosquito Control Section (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 organisms, 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 Hazards section on all mosquitocide labels: 

 

“When this product is applied in accordance 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 Pesticide Registration (PR) Notice 2005-1 (link: 

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

Adult Mosquito Control.” After considerable public 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. Therefore, the environmental hazard statement will 

not be removed or revised to include the suggestion 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 movement of applied material away from the water in order to 

minimize incidental deposition into 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 Association (AMCA) recommend a more careful 

distinction be made between bodies of open water (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: 

 

3
“Do not apply over OPEN bodies of water (lakes, 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 movement of applied material away from the OPEN water in 

 order to minimize incidental deposition into the water body.” 

Further, AMCA recommend this label language should 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 resmethrin should not be approved for mosquito abatement. 

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

the mosquito abatement use, eligible for reregistration. 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 their direct supervision. EPA is currently 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 Association (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 untenable position because they must comply with the Clean Water Act 

immediately. They requested Registration 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 water bodies listed on the 2008 303(d) list. 

SRRD Response: The Permethrin, Resmethrin, Cypermethrin, Pyrethrins, Piperonyl Butoxide, 

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

decisions for non-food pyrethroids, including allethrin stereoisomers, tetramethrin, and 

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

for the pyrethroid, pyrethrins, and synergists (PPS) 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 reregistration of these 

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

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

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

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

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

4
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 PPS chemicals, both agricultural and residential 

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

Department of Pesticide Regulation (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 any 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 submitted 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 opportunity for public input during development of the DCI. They 

also commented that the CDPR has placed all pyrethroids into re-evaluation and requested that 

EPA review all data submitted to CDPR. 

SRRD Response: The Agency is in the process of planning 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. Since this will be the first chance to evaluate all 

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

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

CDPR, and the two organizations have 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 require data exploring the potential 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 directions 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 maximum 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 buildings 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.” 

5
Comment: The Los Angeles County Sanitation Districts (LACSD) and Tri-TAC suggested EPA 

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

 

“This pesticide is extremely toxic to fish, 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 – including indoor use products – should be labeled 

with the aquatic environmental hazard statement required for outdoor products.” 

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

EPA hopes to reduce the overall amount of resmethrin 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 discharge information on the product label, which is 

included below. 

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

required for all indoor use products. 

 

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

 contaminate water when disposing of equipment wash waters.” 

For commercial, industrial, and institutional use products packaged in containers equal or greater 

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

 

“Do not discharge effluent containing this product into lakes, streams, ponds, estuaries, 

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

Pollutant Discharge Elimination System (NPDES) permit and the permitting authority 

has been notified in writing prior to discharge. Do not discharge effluent containing this 

product to sewer systems without previously notifying the local sewage treatment plant 

authority. For guidance contact 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 intended to prevent the release of resmethrin into 

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

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

comments. 

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

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

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

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

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

6
statements. Therefore, the Resmethrin RED labeling will be updated to require the same 

environmental hazard statements for residential 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 have 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, which 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 aquatic habitat can occur, is 

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

application.” 

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

quality stewardship concepts. CASQA recommended 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 following 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 changing label language is an unrealistic method 

of risk mitigation and stated that EPA must use other 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 label is a violation of the Federal Insecticide, 

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

violations. Based on the results of the risk assessments conducted for the 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 necessary to protect fish; therefore, resmethrin is 

classified as Restricted Use due to acute fish toxicity. If the new data 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 & Indoor Metered Spray Systems

 

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

 metered spray systems” because the directions 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 approved for use in misters to prevent any improper 

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

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

IV. Other Comments on the Resmethrin RED 

Comment: LACSD and Tri-TAC requested that EPA include a time schedule for the aquatic 

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

 

SRRD Response: EPA is currently issuing a product-specific 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 Registration Review. Currently, the pyrethroid 

chemicals are scheduled to begin 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 alternatives assessment that considers both low risk 

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

insecticide application; and assessing whether urban uses of pyrethroids pose unreasonable 

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

Water Act. 

SFE also submitted a similar comment suggesting 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 labeled uses of resmethrin and 

pyrethroids in general, and particularly for outdoor urban uses. 

8
9

SRRD Response: As stated above, EPA is in the process of planning for the Registration 

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

Agency will have to evaluate all 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 Registration 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 the 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 time the assessments were conducted. Registration 

Review for pyrethroid chemicals will be starting in 2010, and is intended to make sure that, as 

the ability to assess risk evolves and as policies and practices change, 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 pesticides 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 the 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 existing concerns regarding exposure of aquatic organisms and 

habitats to pyrethroid chemicals. To address 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 largely based on non-agricultural best management and 

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

“Environmental Hazard General Labeling Statements on Outdoor Residential Use Products” on 

all pyrethroid non-agricultural outdoor products. These environmental 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 the “Directions for Use” and “Environmental Hazards 

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

label table.
Revised Labeling Changes Summary Table for Resmethrin

This Labeling Changes Summary Table includes labeling changes based on comments received during the Public the Resmethrin RED, as well as labeling changes developed in consultation with various stakeholders as part of t

Labeling Initiative. In order to be eligible for reregistration, amend all product labels to incorporate the risk mitioutlined in Section IV of the Resmethrin RED. The following table describes how language on the labels should 

Table 25: Summary of Labeling Changes for Resmethrin 

Description Manufacturing Use Products 

Formulation instructions required on all manufacturing use products 

“Only for formulation into an insecticide for the following use(s) [fill blank only with those uses 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.” 

One of these statements may be added to a label to allow reformulation of the product for a specific use or all additional uses supported by a formulator or user group 

“This product may be used to formulate products for specific use(s) not listed on the MP label if the formulator, user group, or grower has complied with U.S. EPA submission requirements regarding support of such use(s).” “This product may be used to formulate products for any additional use(s) not listed on the MP label if the formulator, user group, or grower has complied with U.S. EPA submission requirements regarding support of such use(s).” 

Environmental Hazards Statements Required by the RED and Agency Label Policies 

"Environmental Hazards This product is toxic to fish, aquatic invertebrates, and oysters/shrimp. Do not discharge effluent containing this product into lakes, streams, ponds, estuaries, oceans, or other waters unless in accordance with the requirements of a National Pollution Discharge Elimination System (NPDES) permit and the permitting authority has been notified in writing prior to discharge. Do not discharge effluent containing this product to sewer systems without previously notifying the local sewage treatment plant authority. For guidance contact your State Water Board or Regional Office of the EPA." 

10
End Use Products Intended for Occupational Use 

Excludes Products Intended for Use in Wide Area Mosquito Abatement Programs (See below requirem

PPE Requirements Established by the RED1

for Liquid Formulations (excludes formulations applied via ready-to-use aerosols) 

“Personal Protective Equipment (PPE) Some materials that are chemical-resistant to this product are (registrant inserts correct 

chemical-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 selection 

chart. 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/NIOSH approval 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 the pesticide product contains, or is used with, oil. 

PPE Requirements Established by the RED1

for Ready-to-use Aerosol Products 

“Personal Protective Equipment (PPE) Some materials that are chemical-resistant to this product are (registrant inserts correct 

chemical-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 selection 

chart. All applicators and other handlers must wear: - long sleeved shirt, long pants, and - socks plus shoes, and - chemical-resistant gloves.” 

11
User Safety Requirements “Follow manufacturer's instructions for cleaning/maintaining PPE. If no such instructions for 

washables exist, use detergent and hot water. Keep and wash PPE separately from other laundry.” 

User Safety Recommendations “User Safety Recommendations 

Users should wash hands before eating, drinking, chewing gum, using tobacco, or using the toilet. Users should remove clothing/PPE immediately if pesticide gets inside. Then wash thoroughly and put on clean clothing. Users should remove PPE immediately after handling this product. Wash the outside of gloves before removing. As soon as possible, wash thoroughly and change into clean clothing.” 

Environmental hazard statements on Liquid Concentrate outdoor products (e.g., soluble concentrates and emulsifiable concentrates) Note: Products with indoor uses only see below 

“Environmental Hazards This 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 is not predicted for the next 24 hours will help to ensure that wind or rain does not blow or wash 

pesticide off the treatment area. Rinsing application equipment over the treated area will help avoid run off to water bodies or drainage systems. This product may contaminate water through runoff. This product has a potential for runoff for several days after application. Poorly draining soils and soils with shallow water tables are more prone to produce runoff that contains this product. A level, well maintained vegetative buffer strip between areas to which this product is applied and surface water features such as 

ponds, steams, and springs will reduce the potential for contamination of water from rainfallrunoff. Runoff of this product will be reduced by avoiding applications when rainfall is 

forecasted to occur within 48 hours. Sound erosion control practices will reduce this product’s 

contribution 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 to blooming crops or weeds while bees are actively 

visiting the treatment area. See Directions for Use for additional requirements.” 

12
Environmental hazard 

statements on Liquid Ready-toUse consumer outdoor products (except aerosols) Note: Products with indoor uses only see below 

“Environmental Hazards This 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 is not predicted for the next 24 hours will help to ensure that wind or rain does not blow or wash 

pesticide off the treatment area. This product may contaminate water through runoff. This product has a potential for runoff for several days after application. Poorly draining soils and soils with shallow water tables are more prone to produce runoff that contains this product. A level, well maintained vegetative buffer strip between areas to which this product is applied and surface water features such as 

ponds, steams, and springs will reduce the potential for contamination of water from rainfallrunoff. Runoff of this product will be reduced by avoiding applications when rainfall is 

forecasted to occur within 48 hours. Sound erosion control practices will reduce this product’s 

contribution 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 to blooming crops or weeds while bees are actively 

visiting the treatment area. See Directions for Use for additional requirements.” 

Environmental Hazard Statements for Ready to Use aerosol and fogger outdoor products 

“This pesticide is toxic to fish, aquatic invertebrates, and oysters/shrimp. Do not apply directly 

to 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 Directions 

for Use for additional precautions and requirements.” "This product may contaminate water through runoff. This product has a potential for runoff for several days after application. Poorly draining soils and soils with shallow water tables are 

more prone to produce runoff that contains this product. A level, well maintained vegetative buffer strip between areas to which this product is applied and surface water features such as ponds, steams, and springs will reduce the potential for contamination of water from rainfallrunoff. Runoff of this product will be reduced by avoiding applications when rainfall is 

forecasted to occur within 48 hours. Sound erosion control practices will reduce this product’s 

contribution to surface water contamination.” “This product is highly toxic to bees exposed to direct treatment on blooming crops or weeds. 

13
Do not apply this product or allow it to drift to blooming crops or weeds while bees are actively 

visiting the treatment area.” 

Environmental Hazards for products that only contain indoor use sites 

Note to registrant: Products labeled solely for indoor use except as noted below may omit the Environmental Hazards statements. Such products must have the following statement in the Directions for Use: “For indoor use only.” 

Environmental Hazards for Indoor Use Products packaged in containers equal to or greater than 5 gallons or 50 lbs 

“This pesticide is toxic to fish, aquatic invertebrates, and oysters/shrimp. Do not discharge 

effluent containing this product into lakes, streams, ponds, estuaries, oceans, or other waters 

unless in accordance with the requirements of a National Pollution Discharge Elimination System (NPDES) permit and the permitting authority has been notified in writing prior to discharge. Do not discharge effluent containing this product to sewer systems without previously notifying the local sewage treatment plant authority. For guidance contact your State Water Board or Regional Office of the EPA." 

Restricted-Entry Interval for products with directions for use within the scope of the Worker Protection Standard for Agricultural Pesticides (WPS) 

“Do not enter or allow worker entry into treated areas during the restricted entry interval (REI) 

of 12 hours.” 

Entry Restrictions for all products with indoor use sites AND directions for use outside the 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 the treated area. Post signs on entrances stating that the area has been treated with resmethrin and that it is to remain closed for at least 4 hours after application. Do not re-enter and do not allow anyone else to re-enter the site for 4 hours. Ventilate thoroughly before anyone is allowed to re-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 of space.” 

Early Entry Personal Protective Equipment for products with directions for use within the scope of the WPS 

“PPE required for early entry to treated areas that is permitted under the Worker Protection 

Standard and that involves contact with anything that has been treated, such as plants, soil, or 

water, is: - coveralls, - shoes plus socks 

14
- chemical-resistant gloves made of any waterproof material.” 

Additional Application Restrictions For General Outdoor Surface and Space Sprays, except for outdoor fogging 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, except 

for 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 surfaces such 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 the exceptions above the exceptions may be eliminated from the label. 

General Application Restrictions for all products 

“Application directly into sewers or drains, or to any area like a gutter where drainage to sewers, storm drains, water bodies, or aquatic habitat can occur, is prohibited. Do not allow the product to enter any drain during or after application.” 

General Application Restrictions 

“Do not apply this product in a way that will contact workers or other persons, either directly or 

through drift. Only protected handlers may be in the area during application.” 

Use-Specific Application Restrictions 

Labeling 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 and maximum allowable rate per year must be listed as pounds or gallons of formulated products per 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.” OR 

15
For ready-to-use products, registrants must amend their labels to specify use rates that result in 

no more than 0.25 lb ai per acre. Products labeled for use in Space Applications (Greenhouses; Indoor Food Handling/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.” 

OR For ready-to-use products, registrants must amend their labels to specify use rates that result in no more than 0.001 lb ai per 1000 ft2. 

Products labeled for use in Surface Crack and Crevice Application (Greenhouses; Indoor Food 

Handling/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.” 

OR For ready-to-use products, registrants must amend their labels to specify use rates that result in no more than 0.242 lb ai per 1000 ft2

Products 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 is prepared or served, 

do not apply this product while food is exposed or being processed. Cover or remove all exposed food, packaging material, and food contact surfaces. Do not apply directly to food, packaging material, or any food contact surfaces. Remove or cover dishes, utensils, food processing equipment and food preparation surfaces before use of this product. All food processing surfaces and equipment in the treatment area must be covered or washed with an effective cleaning compound followed by a potable water rinse 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 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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For End-Use Products Intended for Wide Area Mosquito Abatement Programs Only 

Restricted Use Pesticide “Restricted Use Pesticide. Due to Acute Fish Toxicity. For retail sale to and use only by 

certified applicators or persons under their direct supervision and only for those uses covered by the certified applicator’s certification. Direct supervision for this product is defined as the certified applicator being physically present during mixing, loading, equipment repair and equipment cleaning. Certified applicators must ensure that all persons involved in these activities under their direct supervision are informed of the precautionary statements.” 

PPE Requirements Established by the RED1

“Personal Protective Equipment (PPE) Some materials that are chemical-resistant to this product are (registrant inserts correct 

chemical-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 selection 

chart. 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.” 

User Safety Requirements “Follow manufacturer's instructions for cleaning/maintaining PPE. If no such instructions for 

washables exist, use detergent and hot water. Keep and wash PPE separately from other laundry.” 

Engineering Controls Engineering Controls: 

“Applicators using ground mechanical application equipment must use an enclosed cab that has a nonporous barrier that totally surrounds the occupants and prevents contact with pesticides outside the cab. Must be provided and have immediately available for use upon exiting the cab chemical-resistant gloves.”  “Pilots must use an enclosed cockpit. The cockpit must have a nonporous barrier that totally surrounds the occupants and prevents contact with pesticides outside the cab. Pilots must wear 

the PPE specified in this label for applicators.” 

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User Safety Recommendations “User Safety Recommendations 

Users should wash hands before eating, drinking, chewing gum, using tobacco, or using the toilet. Users should remove clothing/PPE immediately if pesticide gets inside. Then wash thoroughly and put on clean clothing. Users should remove PPE immediately after handling this product. Wash the outside of gloves before removing. As soon as possible, wash thoroughly and change into clean clothing.” 

Environmental Hazards “This pesticide is toxic to aquatic organisms, 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.” “Do not apply when bees are visiting the treatment area, except when applications are made to prevent or control a threat to public and/or animal health determined by a state, tribal, or local 

health or vector control agency on the basis of documented evidence of disease causing agents 

in vector mosquitoes or the occurrence of mosquito-borne disease in animal or human 

populations, or if specifically approved by the state or tribe during a natural disaster recovery effort.” “Before making the first application in a season, it is advisable to consult with the state or tribal 

agency with primary responsibility for pesticide regulation to determine if other regulatory 

requirements 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 areas 

where adult mosquitoes are present, and weather conditions will facilitate movement of applied 

material 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.” 

Use-Specific Application Restrictions 

Use-Specific Application Restrictions “For use by federal, state, tribal, or local government officials responsible for public health or vector control, or by persons certified in the appropriate category or otherwise authorized by the state or tribal lead pesticide regulatory agency to perform adult mosquito control applications, or by persons under their direct supervision.” 

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“Do not apply more than 0.007 lb ai/acre per application.” 

“Do not apply more than 0.2 lb ai/acre per year in any treated area. More frequent treatments may be made to prevent or control a threat to public and/or animal health determined by a state, tribal, or local health or vector control agency on the basis of documented evidence of disease 

causing agents in vector mosquitoes or the occurrence of mosquito-borne disease in animal or 

human populations, or if specifically approved by the state or tribe during a natural disaster recovery 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 (Dv 0.5 < 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 test facility using a laxer-based measurement instrument must be used to adjust equipment to produce acceptable droplet size spectra. Application equipment must be tested at least annually to confirm that pressure at the nozzle and nozzle flow rate(s) are properly calibrated.” “Aerial Application: Spray equipment must be adjusted so that the volume median diameter produced is less than microns (Dv 0.5 < 60 um) and that 90% of the spray is contained in droplets smaller than microns (Dv 0.9 < 80 um). The effects of flight speed, and for non-rotary nozzles, nozzle angle on the droplet size spectrum must be considered. Directions from the equipment manufacturer or vendor, pesticide registrant or a test facility using a wind tunnel and laser-based measurement instrument must be used to adjust equipment to produce acceptable droplet size spectra. EQUIPMENT CALIBRATION: Application equipment must be tested at least annually to confirm that pressure at the nozzle and nozzle flow rate(s) are properly calibrated.” 

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RELEASE 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.” 

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End Use Products Primarily Used by Consumers 

Application Restrictions “Do not apply this product in a way that will contact any person or pet, either directly or 

through drift. Keep people and pets out of the area during application.” 

Entry Restrictions 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 treated area closed for at least 2 hours after application. Do not remain in treated area(s). Ventilate thoroughly for 20 minutes with fresh air before re-occupying treated area(s).” 

Environmental hazard statements on Liquid Concentrate outdoor products (e.g., soluble concentrates and emulsifiable 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 is not predicted for the next 24 hours will help to ensure that wind or rain does not blow or wash pesticide off the treatment area. Rinsing application equipment over the treated area will help avoid 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 to blooming crops or weeds while bees are actively visiting the treatment area. See Directions for Use for additional requirements.”

Environmental hazard statements 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 is not predicted for the next 24 hours will help to ensure that wind or rain does not blow or wash pesticide off the treatment area. This product is highly toxic to bees exposed to direct treatment on blooming crops or weeds. 

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Do not apply this product or allow it to drift to blooming crops or weeds while bees are actively 

visiting the treatment area. See Directions for Use for additional requirements.”

Environmental Hazard Statements for Ready to Use aerosol and fogger consumer outdoor products 

“This pesticide is toxic to fish, aquatic invertebrates, and oysters/shrimp. Do not apply directly 

to 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 Directions 

for Use for additional precautions and requirements.” "This product may contaminate water through runoff. This product has a potential for runoff for several days after application. Poorly draining soils and soils with shallow water tables are 

more 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 applications 

when rainfall is forecasted to occur within 48 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 to blooming crops or weeds while bees are actively visiting the treatment area.” 

Additional Application Restrictions For General Outdoor Surface and Space Sprays, except for outdoor fogging 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, except 

for 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 surfaces such 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 the exceptions above the exceptions may be eliminated from the label.

General Application Restrictions for all products 

“Application directly into sewers or drains, or to any area like a gutter where drainage to sewers, storm drains, water bodies, or aquatic habitat can occur, is prohibited. Do not allow the product to enter any drain during or after application.” 

Use-Specific Application Restrictions 

Labeling required on all products applied as sprays:

“Do not use in indoor metered spray systems.” “Do not use in automatic misting systems.” 

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APPLICATION 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 application rate per year. The rate must be listed as pounds or gallons of formulated product per acre or 1000 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 maximum application 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 product while food is exposed or being processed. Cover or remove all exposed food and food contact surfaces. Do not apply directly to food, packaging material, or any food contact surfaces.” “Remove or cover dishes, utensils, food processing equipment and food preparation surfaces 

before use of this product. All food processing surfaces and equipment in the treatment area should be covered or washed with an effective cleaning compound followed by a potable water rinse after use of this product.” 
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Products labeled for use on and around buildings and other structures:  “For Band applications to and around buildings 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.”

1 PPE that is established on the basis of Acute Toxicity of the end-use product must be compared to the active ingredient PPE in this d

protective PPE must be placed in the product labeling. For guidance on which PPE is considered more protective, see PR Notice 93-7