Complying with pesticide label directions is the law – but it isn’t always straightforward.
Canadian growers are often reminded by chemical registrants, industry groups and their peers of the importance of following pesticide labels – and with good reason. The label is a legal document, and if growers apply products in a way that does not comply with the label, they could face serious consequences.
Growers know this and do their best to follow label directions. But according to Jason Deveau, application technology specialist with the Ontario Ministry of Agriculture, Food and Rural Affairs (OMAFRA), the lengthy and complex nature of pesticide labels makes it challenging for them to find the information they need the most, and sometimes information is missing altogether.
“Complying with the label is getting tougher and tougher,” says Deveau. “The elephant in the room is that labels have become outdated and grey, rather than clearly black and white. If following the label is the legal obligation of the grower, why is it that growers are left to interpret what they’re reading?”
The elephant in the room is that labels have become outdated and grey, rather than clearly black and white.
Deveau describes this question as “the bane of our careers” for both himself and his colleague Tom Wolf of Saskatoon-based Agrimetrix Research & Training. Together, Deveau and Wolf operate Sprayers 101, an online non-profit resource for information on safe, efficient and effective spraying practices.
Seeds of an Idea
In late 2017, the pair were invited to present about a topic of their choice in four cities over four days as part of TechTour LIVE, a farm-management seminar hosted by Real Agriculture. As Deveau and Wolf brainstormed topics to present to growers across Western Canada, Deveau says they repeatedly came back to the idea that labels have grown very long and complex and that technology has outpaced legal terminology, leading to contradictory and missing information.
So, they ultimately decided to present a method for summarizing labels. Just three black and white pages, Deveau says the Label Summary Sheet (LSS) they came up with would not replace the pesticide label, but would elevate the most relevant content, as far as actual application is concerned, to the surface and summarize it in a standardized format featuring eight sections and infographics.
“It’s not that something like storage, which we didn’t include, isn’t important – it is,” says Deveau. “But we thought very long and hard about what to include. We had to draw a line in the sand and say, ‘This is for information directly related to application only.’”
Deveau says he sees a strong need for a tool like the LSS in Canadian agriculture. Some chemical registrants release their own summaries with their products, and while Deveau says this addresses the issue, there are still inconsistencies from company to company in the layout of information, and what information is included.
“Registrants already have tech sheets. Some key information, as they see it, has been floated up into attractive, easy-to-understand documents,” he says. “And that’s great. Except when you move laterally across manufacturers or brands and you don’t find information in the same spot, or, perhaps the document has become as much a marketing exercise as an instruction manual.”
Regardless of Experience
Deveau says more work needs to be done to make sure growers have the best strategies to apply products properly and safely, and by doing so, avoid a whole host of other issues that can be connected to a lack of label clarity.
“Herbicide resistance is an excellent example of what can potentially happen if a product isn’t applied in a way that the registrant wanted it to be applied,” he says. “Drift is a problem. A loss of coverage uniformity and a loss of crop protection – all of these things can be traced back to a label that is silent on key points, contradictory, or maybe just a little behind the times.”
Deveau points to newer farmers as beneficiaries of the LSS. “There are a lot of first-time farmers out there. Some are, as I call them, ‘glyphosate babies’ who might be used to applying products with a little less care and attention than products like, for example, Dicamba require,” he says.
According to Johanna Lindeboom, agronomist with Ontario ag retailer Clark Agri Services (Clark Agri), it’s not just young and first-time farmers who could benefit from an LSS. She says even older, more experienced farmers could improve their operations if they had an LSS to reference.
“I think someone who is older and more experienced will benefit just as much from a summary sheet as someone who is younger,” says Lindeboom. “Right now in agriculture, we’re trying to fight resistance, push yields and manage our costs a bit differently. A lot of that involves using different chemicals; using something you haven’t tried before.”
Because of this, Lindeboom says regardless of the length of time a grower has been farming, if they’re trying new things on their farm, a quick-start guide to a new product could make a world of difference.
Use in a Retail Setting
Beyond farmers themselves, Deveau believes that label summary sheets would serve as a valuable resource to anyone involved in chemical sale or application, including ag retailers, allowing them to give better service to customers.
“I think somebody who is working at the point of sale would be happy to have a three-page, black and white document,” he says. “When a customer comes into a retail operation and has questions about a product, you can easily consult the sheet and say, ‘The document says you need this droplet size, and I know you’re using this kind of sprayer so here you go, this is what you need.’”
He says the LSS will enable retailers to get through these conversations with their customers more quickly, instead of spending time “combing through 30 pages to find a piece of information hidden at the bottom of page 11.”
Lindeboom also sees them as an efficiency tool, as she says the team at Clark Agri is always looking to respond to customer queries as quickly as possible, and they do receive them during the application window.
“Most of the time, if we’re getting asked these questions about label directions, the customer is loading up the sprayer and heading toward the field, so we have a very short window of time to respond,” explains Lindeboom.
Because growers are working with very tight timelines, Lindeboom says if she or her colleagues aren’t able to provide an answer quickly enough, that customer may proceed with their application anyway.
Since this is also the time when agronomists are out crop scouting and driving between sites, she says it can be challenging to deliver that much-needed answer in a timely manner if they need to reference the long and complex label. “You don’t have the material at your fingertips to be doing a lot of research, you really need to access the crucial information quickly,” she says.
Lindeboom says the agronomy team at Clark Agri spends significant time over the winter drafting their own versions of label summary sheets to reference during the busy season, but she thinks an officially registered LSS would be “a huge help.”
“It would probably eliminate a lot of the work we’re doing on our own right now and would eliminate the possibility of human error from copying things from year to year,” she says. “It would be reliable, because it would have gone through that really critical process of registration.”
The Future of the LSS
Working toward registration, Deveau and Wolf have collaborated with universities, extension and industry. Right now, their vision of the LSS is a discussion-piece only. The two have made proposals to adopt the LSS, or something similar, as a registered document to CropLife Canada, The American Society of Agricultural and Biological Engineers and an International Organization for Standardization (ISO) mirror committee (Equipment for Crop Protection).
“When you’re in a highly regulated industry, change comes very gradually,” says Russel Hurst, vice president of stewardship and sustainability with CropLife Canada. Hurst has worked with Deveau on numerous projects in the past and facilitated a meeting between Deveau, Wolf and CropLife Canada’s Chemistry, Science and Regulatory Committee in the summer of 2018.
Hurst describes the reaction from the committee to the LSS proposal as mixed – neither completely positive nor negative – but says the committee agreed that this idea is worth pursuing over the coming years.
“As with any new concept, it’s going to take some time for people to digest,” he says. “It’s early days still, but there was interest among the registrants about the concept of a standardized product summary that is very application focused, leaving all of the intricate details to the full label.”
Deveau and Wolf remain confident in the potential for positive impact on the industry, and Deveau thinks most people agree something is needed. Just as he sees gains for farmers and retailers, Deveau says there is opportunity for chemical companies to gain new perspective and use it to enhance value for the end user.
“For example, if we put together one of our summary sheets and find little or no information on sprayer clean-out, Tom and I don’t invent information and we don’t reinterpret it,” he says. “In that case we could bring that back to the registrant, and maybe help to develop that information or bring it forward.”
Continuing the Conversation
Deveau and Hurst both see any formal adoption at least a few years in the making, with many more consultations along the way.
“Right now, we want to refine our thinking and gather information,” says Hurst. “Let’s work through the process, consult with the right stakeholders and get the right feedback. But at the end of the day, any chance we get to put more information in growers’ hands that allows them to do a better job, a safer job and to use these products as they’re meant to be used, is a good thing.”
Deveau says he and Wolf are always open to talking with growers, registrants and other stakeholders about the LSS. In their initial round of presentations as part of TechTour LIVE in spring 2018, Deveau says they spoke to over 1,400 growers during the four days of the seminar.
“1,400 people in four days was just mind boggling,” he says. “It was a great adventure.”
The two opened the floor to the audience at the end of each presentation, and he said growers were not shy about sharing their thoughts on the LSS format and the information, resulting in lively discussion and tough decisions to make. As conversations about the LSS continue, Deveau says although different people may have different ideas about what should be included, clarity, brevity and functionality must remain paramount for the LSS to serve its intended purpose.
“We need some way to clarify and to return the label to what it was originally intended to be: an instruction manual for safe and effective application,” he says. “Standardizing seems like the best way to help everybody.”
The current version of the LSS features eight consistent sections with corresponding infographics to organize information. The eight sections are:
- Banner Section,
- Resistance Management/Planting Restrictions,
- Environmental Conditions,
- Sprayer Settings,
- Handling Safety (PPE),
- Rates and Restricted Entry Levels,
- Equipment Cleanout.
Each LSS includes the disclaimer: “This document is intended to summarize, not substitute the full product label. Please read the pesticide label.”
What do you think about the concept of Label Summary Sheets? Take the poll here.
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