Chapter 8. II. D. 4 of the Label Review Manual indicates when Ground Water Advisories are "generally" required. However many labels for outdoor use meeting the specified thresholds do not have such advisories. Imidacloprid meets the specified thresholds for the advisories and has been detected in ground water in Long Island, NY. The labeling for the agricultural product has the ground water advisory, but the label for the termiticide product does not. Why the inconsistency?
As pointed out in the Chapter 8.II.D.4, Ground Water Advisories are “generally” required. The ground water advisory is a case-by-case basis determination depending on the use site and available data. Termiticides uses are generally considered indoor uses because applications involve injection through drilled holes in slabs of constructed houses, or for pre-construction, the soil is sprayed just before the foundation is poured. Under such circumstances, the Office of Pesticide Programs has not generally required ground water advisories.
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- Topic #: 23002-25024
- Date Created: 7/12/2008
- Last Modified Since: 3/13/2013
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