PRI Evaluator: Help and FAQs

Contents

Questions about the Product Review Process

What data sources does PRI use to assign a Hazard Tier to a product?

PRI uses a variety of data sources to assign a Hazard Tier ranking to a pesticide product, according to the Hazard Tier Review Process described in the Guide to San Francisco’s Reduced Risk Pesticide List. Data sources include:

1) US EPA’s Pesticide Product Information System (PPIS) database provides the acute toxicity signal word (DANGER, WARNING, or CAUTION) and Restricted Use status.

2) Environmental Hazards are obtained from the product label and MSDS, including information on acute toxicity to birds, fish, aquatic invertebrates, other aquatic organisms, and bees.

3) Acute Human Health Hazards are obtained from the product label and MSDS, including information on skin and eye irritation, sensitization and systemic toxicity via the oral, dermal or inhalation route.

4) Hazard Information on Known Ingredients in this Product is obtained from official government lists categorizing pesticide active ingredients and inerts as to their carcinogenicity, reproductive and developmental toxicity; databases with information on physical properties of chemicals affecting their water pollution potential.

Although the Hazard Tier is not affected by the Low-Toxicity Indicators, PRI does provide this information from US EPA risk assessments, the National Organic Program, and the FIFRA Section 25(b) list.

Back To Top

When information on the product label and the MSDS conflict, which source is used for the Hazard Tier ranking?

When a conflict occurs, label-based information is used for the Hazard Tier ranking.

Back To Top

Why does a different product name appear in the search results than the name for which I searched?

The company that is the primary manufacturer of each product assigns a single product name that US EPA uses as the master name associated with a particular registration number. That name is the one that appears in the search results. However, many products that are equivalent to the master product in composition and registration number are distributed by other companies besides the original manufacturer of the product. These companies often create a different name for their product, which are referred to as “Distributor” names.

Back To Top

What types of products are prioritized for future review?

Initially, PRI has prioritized the review of pesticide products used in structural, landscape, and turf pest management, as well as invasive weed management work. Agricultural use pesticides are next in the queue. We are also working to incorporate exempt products containing only minimal risk ingredients and have approximately 50 of these products currently in the database.

Back To Top

How do reviews account for “expected” or “predicted” toxicity statements, for example ““not expected to be a sensitizer”?

Reviews do not use such phrases. These are considered as “no warning on label or MSDS” in reviews.

Back To Top

Does PRI follow a published set of guidelines for reviewing pesticide products?

The Guide to San Francisco’s Reduced Risk Pesticide List (or “San Francisco Hazard Tier Guidelines”) guides the assignment of a Hazard Tier ranking. The US EPA Label Review Manual provides additional guidance on label interpretation.

Sources for data that inform the reviews are described in San Francisco’s Hazard Tier Guidelines. PRI lists these data sources, with links to the original source, at Data Sources

Back To Top

What is a “Hazard Tier”?

See Product Rankings for a description of the Hazard Tier ranking system, which PRI uses to assign a Hazard Tier ranking to pesticide products.

Back To Top

What data sources are used for the Low Toxicity Indicators section of reviews?

Data Sources discusses sources for each of these Low Toxicity Indicators:

– FIFRA Section 25(b) Minimum Risk Pesticides
– Organic Approved Ingredient (doesn’t necessarily mean the product is approved for use in organic production)
– US EPA Biopesticide
– US EPA Waived Data Requests

Back To Top

Are the registration numbers on review pages always the US EPA Registration number?

Usually the registration number is the US EPA Registration number, but for adjuvants and exempt products registered in California, the CA registration number is used.

For exempt products that have neither an EPA nor a CA registration number, PRI has assigned a number prefaced by the word “EXEMPT.”

Back To Top

Questions about Environmental Hazards

Why does a label show no warnings, although the ingredients appear to be acutely toxic?

For indoor-use products, and for many products applied to domestic animals (see below), EPA does not require environmental hazard warnings on the label, even though the product may be toxic (EPA Label Review Manual 2011, page 8-2). The “PRI Comments” box notes when products appear to be indoor-use only, based on the product’s approved pests and sites.

In addition, EPA notes that “products applied to domestic animals, such as flea collars or ear tags may in most cases omit the [warning] statement. However, the statement may be required for a domestic-use product such as a dog dip due to the potential for contamination of water by the use of such a product.” (EPA Label Review Manual 2011, page 8-2)

Back To Top

Are the hazards of a product assessed based on the product as a whole or on the pure ingredient(s)?

It depends on whether acute toxicity or chronic toxicity is being considered.

Acute toxicity: Because acute toxicity is a function of concentration, formulated products containing an active ingredient (AI) that is highly acutely toxic in pure form will not necessarily be highly acutely toxic. It depends on the concentration of the AI and the identity and toxicity of the other ingredients in the mixture.

Chronic toxicity: Chronic toxicity such as carcinogenicity, endocrine disruption, reproductive and developmental harm can be induced by exposure to even very low doses of a chemical and is thus based on the characteristics of the specific chemical(s) in the formulated product, regardless of concentration. Generally, this information is only available for humans and not for birds, bees, fish or other aquatic organisms.

Environmental hazards: For environmental hazards, the only information typically available on the label and MSDS is for acute toxicity, generally in the form of an LD50 or LC50. A confusing aspect of the MSDS is that it will often contain acute toxicity data only for the pure ingredients, stating that the data are based solely on “active ingredient,” “components,” “technical product,” or “technical ingredient/product.” If this is the case, the environmental hazard rankings are taken solely from the product label and the MSDS is not considered in the ranking. Ecological hazard data on the MSDS are considered if the MSDS explicitly indicates that the data are based on the product, “finished product,” “similar product” “similar formulation,” “similar material,” or “product of greater concentration.”

When the MSDS does not state whether the information provided applies to the formulated product or the individual ingredient(s), the data are assumed to be product-based.

Human health hazards: For human health hazards, acute toxicity information for the formulated product is available from the label in the form of the Acute Toxicity Signal Word (DANGER, WARNING, CAUTION) and from the label or MSDS in the form of information regarding skin and eye irritation, sensitization, and systemic acute toxicity by oral, dermal or inhalation routes of exposure, normally provided as LD50 (oral, dermal) or LC50 (inhalation). If the MSDS only contains data for the pure ingredient(s), the label warnings are used exclusively for the human health hazard product rating.

Back To Top

Are toxicity data for aquatic plants (including algae) considered when assessing toxicity to “other aquatic organisms” for the purpose of reviews?

No. Aquatic plants are not considered as part of the San Francisco Hazard Tier Guidelines.

Back To Top

What organisms are included under the category of “Other Aquatic Organisms”?

The “Other aquatic organisms” category is used to account for warnings or data concerning unspecified “aquatic organisms” or specific species, other than fish and aquatic invertebrates (not including aquatic plants).

The toxicity ranking for fish and aquatic invertebrates (including estuarine species such as oyster and mysid shrimp) are specifically identified in their respective hazard categories.

Back To Top

How is the phrase “is hazardous to” or “may be hazardous to” on a product label interpreted for reviews?

“Hazardous” or “may be hazardous” is not used to assign any environmental ratings. Only environmental hazard statements commenting on the toxicity of the product to aquatic organisms (like “moderately toxic to fish”) are used in reviews.

Back To Top

How do reviews treat the words “May be fatal” (if absorbed through skin, inhaled or swallowed) on a product label?

“May be fatal” is considered to be equivalent to “Moderate Toxicity” based on EPA’s Label Review Manual, which requires “may be fatal” on labels of Acute Toxicity Category II, as explained in Chapter 7 and summarized in Table 1 (page 7-2).

Back To Top

How does US EPA assign the environmental hazard warnings on product labels?

The EPA Label Review Manual (2011, page 8-1) states: “Generally, the information contained in [the Environmental Hazards] section is based upon the results of eight basic acute toxicity studies performed on the technical grade of the active ingredient(s) in the formulation.

“These eight studies are: (1) avian oral LD50(with mallard or bobwhite quail), (2) avian dietary LC50 (mallards), (3) avian dietary LC50 (bobwhite quail), (4) freshwater fish LC50 (rainbow trout), (5) freshwater fish LC50 (bluegill sunfish), (6) acute LC50 freshwater invertebrates (Daphnia magna or water flea), (7) honeybee contact LD50, and (8) mammalian acute oral LD50. For specific data requirements, see 40 CFR Part 158.

“In addition, data concerning a product’s potential to be transported to groundwater, surface water, aquatic sediment, to drift, to adversely affect non-target plants and bees provide important information. Data include, but are not limited to, results from hydrolysis, batch equilibrium, aerobic soil metabolism, field dissipation, and prospective groundwater studies.”

Back To Top

How does PRI decide which products are labeled as Bee-Toxic?

We flag the following types of products as “Bee-Toxic”:

  1. All products that are highly toxic to bees, according to the label or MSDS (LD50 < 2 ug/bee)
  2. All products that are moderately toxic to bees, according to the label or MSDS (LD50 between 2 and 11 ug/bee)
  3. All of the products containing systemic neonicotinoid insecticides, because these chemicals can be taken up systemically by plants and expressed in the pollen and nectar on which bees feed. Even low concentrations of neonicotinoids have been shown to have adverse effects on bees.
  4. All products containing insect growth regulators that inhibit the maturation of bees from a larva to a mature adult.
  5. All products containing chlorothalonil, boscalid, fipronil, and pyraclostrobin, based on research showing that these chemicals impair bees’ immune system and/or have other toxicity to bees. References to the journal articles summarizing this research are provided below:

    Products that are applied as a spot treatment on domestic animals, products in enclosed bait stations, and gels intended for use in cracks and crevices are not flagged as bee-toxic.

    • Pettis JS, Lichtenberg EM, Andree M, Stitzinger J, Rose R, vanEngelsdorp D. 2013. Crop Pollination Exposes Honey Bees to Pesticides Which Alters Their Susceptibility to the Gut Pathogen Nosema ceranae. PLoS ONE 8:e70182; doi:10.1371/journal.pone.0070182.
    • Aufauvre J, Misme-Aucouturier B, Viguès B, Texier C, Delbac F, Blot N. 2014. Transcriptome Analyses of the Honeybee Response to Nosema ceranae and Insecticides. G. Smaggheed. PLoS ONE 9:e91686; doi:10.1371/journal.pone.0091686.

    Products that are applied as a spot treatment on domestic animals, products in enclosed bait stations, and gels intended for use in cracks and crevices are not flagged as bee-toxic.
    Back To Top

    Questions about Human Health Hazards

    If a product label or MSDS says that inhalation of the product “may cause irritation,” how does that information affect the Hazard Tier rating?

    Mild respiratory irritation is not reflected in reviews because San Francisco’s Hazard Tier Guidelines do not include this as a criterion for a Hazard Tier ranking. Such language is coded as “No warning on label or MSDS.”

    High or moderate acute inhalation toxicity is captured by the signal word on the label (DANGER, WARNING, CAUTION). Systemic toxicity via inhalation is captured by the “Inhalation Toxicity” category in the “Acute Human Health Hazards” section.

    Back To Top

    Are the hazards of a product assessed based on the product as a whole or on the pure ingredient(s)?

    It depends on whether acute toxicity or chronic toxicity is being considered.

    Acute toxicity: Because acute toxicity is a function of concentration, formulated products containing an active ingredient (AI) that is highly acutely toxic in pure form will not necessarily be highly acutely toxic. It depends on the concentration of the AI and the identity and toxicity of the other ingredients in the mixture.

    Chronic toxicity: Chronic toxicity such as carcinogenicity, endocrine disruption, reproductive and developmental harm can be induced by exposure to even very low doses of a chemical and is thus based on the characteristics of the specific chemical(s) in the formulated product, regardless of concentration. Generally, this information is only available for humans and not for birds, bees, fish or other aquatic organisms.

    Environmental hazards: For environmental hazards, the only information typically available on the label and MSDS is for acute toxicity, generally in the form of an LD50 or LC50. A confusing aspect of the MSDS is that it will often contain acute toxicity data only for the pure ingredients, stating that the data are based solely on “active ingredient,” “components,” “technical product,” or “technical ingredient/product.” If this is the case, the environmental hazard rankings are taken solely from the product label and the MSDS is not considered in the ranking. Ecological hazard data on the MSDS are considered if the MSDS explicitly indicates that the data are based on the product, “finished product,” “similar product” “similar formulation,” “similar material,” or “product of greater concentration.”

    When the MSDS does not state whether the information provided applies to the formulated product or the individual ingredient(s), the data are assumed to be product-based.

    Human health hazards: For human health hazards, acute toxicity information for the formulated product is available from the label in the form of the Acute Toxicity Signal Word (DANGER, WARNING, CAUTION) and from the label or MSDS in the form of information regarding skin and eye irritation, sensitization, and systemic acute toxicity by oral, dermal or inhalation routes of exposure, normally provided as LD50 (oral, dermal) or LC50 (inhalation). If the MSDS only contains data for the pure ingredient(s), the label warnings are used exclusively for the human health hazard product rating.

    Back To Top

    How is the phrase “is hazardous to” or “may be hazardous to” on a product label interpreted for reviews?

    “Hazardous” or “may be hazardous” is not used to assign any environmental ratings. Only environmental hazard statements commenting on the toxicity of the product to aquatic organisms (like “moderately toxic to fish”) are used in reviews.

    Back To Top

    How do reviews treat the words “May be fatal” (if absorbed through skin, inhaled or swallowed) on a product label?

    “May be fatal” is considered to be equivalent to “Moderate Toxicity” based on EPA’s Label Review Manual, which requires “may be fatal” on labels of Acute Toxicity Category II, as explained in Chapter 7 and summarized in Table 1 (page 7-2).

    Back To Top

    Questions about Water Pollution Potential

    Is water contamination potential included among Hazard Tier ranking criteria?

    Yes. Three sources are specified in San Francisco’s Hazard Tier Guidelines: the GUS index, DPR Specific Numeric Values, and product label warnings. The first two are discussed in detail at Data Sources in the Water Pollution Potential section.

    Regarding label warnings, San Francisco Hazard Tier Guidelines(Sept 2012) states that “In addition to the GUS index and DPR’s assessment, information on pesticide water contamination potential is noted from product label warnings” and “In rare cases where a label ground-water advisory occurs but the GUS index or DPR assessment did not indicate high mobility, the label advisory is given priority.”

    Back To Top

    How is a label statement that an ingredient or product “has properties and characteristics associated with chemicals detected in groundwater” used in product reviews?

    The phrase is added to the “Hazard Tier Assessment” box. According to EPA’s Label Review Manual (2011), “the need for a groundwater label advisory is based on the environmental fate properties of the chemical and/or detections of the chemical in groundwater” and “there are two groundwater label advisory options available … One option is for chemicals with little or no monitoring data that have environmental fate properties similar to pesticides that have been found in groundwater. The other option is for chemicals that have actually been found in groundwater.”

    When EPA requires a groundwater warning, one of the following two phrases is required on the product label:

    1. Laboratory/Field Data-based warning:
    “Groundwater Advisory: This chemical has properties and characteristics associated with chemicals detected in groundwater. This chemical may leach into groundwater if used in areas where soils are permeable, particularly where the water table is shallow”.

    2. Groundwater Monitoring-based warning:
    “Groundwater Advisory: [Name of chemical or a degradate of chemical] is known to leach through soil into groundwater under certain conditions as a result of label use. This chemical may leach into groundwater if used in areas where soils are permeable, particularly where the water table is shallow”

    Back To Top

    Questions about Active ingredients

    Are the hazards of a product assessed based on the product as a whole or on the pure ingredient(s)?

    It depends on whether acute toxicity or chronic toxicity is being considered.

    Acute toxicity: Because acute toxicity is a function of concentration, formulated products containing an active ingredient (AI) that is highly acutely toxic in pure form will not necessarily be highly acutely toxic. It depends on the concentration of the AI and the identity and toxicity of the other ingredients in the mixture.

    Chronic toxicity: Chronic toxicity such as carcinogenicity, endocrine disruption, reproductive and developmental harm can be induced by exposure to even very low doses of a chemical and is thus based on the characteristics of the specific chemical(s) in the formulated product, regardless of concentration. Generally, this information is only available for humans and not for birds, bees, fish or other aquatic organisms.

    Environmental hazards: For environmental hazards, the only information typically available on the label and MSDS is for acute toxicity, generally in the form of an LD50 or LC50. A confusing aspect of the MSDS is that it will often contain acute toxicity data only for the pure ingredients, stating that the data are based solely on “active ingredient,” “components,” “technical product,” or “technical ingredient/product.” If this is the case, the environmental hazard rankings are taken solely from the product label and the MSDS is not considered in the ranking. Ecological hazard data on the MSDS are considered if the MSDS explicitly indicates that the data are based on the product, “finished product,” “similar product” “similar formulation,” “similar material,” or “product of greater concentration.”

    When the MSDS does not state whether the information provided applies to the formulated product or the individual ingredient(s), the data are assumed to be product-based.

    Human health hazards: For human health hazards, acute toxicity information for the formulated product is available from the label in the form of the Acute Toxicity Signal Word (DANGER, WARNING, CAUTION) and from the label or MSDS in the form of information regarding skin and eye irritation, sensitization, and systemic acute toxicity by oral, dermal or inhalation routes of exposure, normally provided as LD50 (oral, dermal) or LC50 (inhalation). If the MSDS only contains data for the pure ingredient(s), the label warnings are used exclusively for the human health hazard product rating.

    Back To Top

    Questions about Inert ingredients

    Do reviews consider all inert ingredients?

    Not necessarily. All ingredients found on a product’s label and MSDS are listed in the “Active Ingredients” and “Other Known Ingredients” boxes on the product detail page, and all of these ingredients are considered in the Hazard Tier ranking. However, inert ingredients are not required to be listed on the label or MSDS unless they have some level of toxicity that requires listing. Most “inert” ingredients are considered to be confidential business information by the product manufacturers. Therefore, not all inerts in a product are necessarily considered in Hazard Tier rankings.

    Back To Top

    If a product states that it “may include trace amounts of” a substance, is the substance added to the list of ingredients?

    Yes. If a product includes this statement, it is probably because the ingredient is a known carcinogen or other hazard, and California’s Proposition 65 (”Prop 65”) mandates that this statement be included.

    Back To Top

    Questions about Reviews of Your Company’s Products

    What if I believe that the Hazard Tier ranking has been incorrectly assigned or wish to have a product reevaluated based on new information?

    Contact PRI at support@pesticideresearch.com and provide some details about the points of disagreement and/or any updated information. We will get back within several working days, under normal circumstances.

    Back To Top

    How can I request a review of a particular product?

    Subscribers may contact PRI at support@pesticideresearch.com to request a review of a product or products.

    If you are a manufacturer and wish to have your products reviewed, you can expedite this process by sending an Excel file containing the following information to support@pesticideresearch.com:

    Product name

    • US EPA product registration number, if any
    • Permanent link to label
    • Permanent link to MSDS

    We’ll review the products as soon as reasonably possible.

    Back To Top

    Questions about Group Subscriptions

    How can a Group Administrator add a new user to their group and manage group member access?

    Add users to your group:

    1) Log into the PRI Pesticide Product Evaluator. As a group administrator you can select Account in the top right corner to access the Group Management interface.
    2) Select the Manage User tab and click on Add User. Fill in the required fields, including your team member’s name and email address. Please note that all entered email addresses must be from your institution to be accepted.
    3) Click on the Submit button to send an email invitation that will allow your team member to complete the registration process. You may invite up to nine people in your organization to join your group.

    Manage group member access:

    To delete a colleague’s account and allow a new team member to access the Product Evaluator in their place, click on Delete next to the current group member’s name. Then proceed to invite the new user to your group as described above.

    Back To Top

UA-21813186-1