A South Carolina survey of urban households revealed that

Common sense precautions were largely ignored by both white and non-white families using pesticides: 88 percent failed to employ locked storage, 66 percent stored these poisons within easy reach of small children, 54 percent stored pesticides near food or medicine, and 66 percent did not wear protective gloves while applying pesticides, nor did they wash their hands after application.1

In Quebec

The survey confirmed that farmers preferred to use the insecticide sprays at higher concentrations than those recommended by the Federal Department of Agriculture. On the average, the concentrations used were twofold stronger, but in particular cases they exceeded by far the recommended values."

One study in Iowa stated that—

A common practice of farmer's is to store unused pesticides in machine sheds or other feed storage areas in unlabeled bags. Later, the pesticide may be mistakenly mixed into livestock feed mixtures in place of salt or minerals.*

In another Iowa study questions were asked of farmers to find out their knowledge and attitudes about pesticides. One question was, "Did they agree or disagree that 2,4-D is an effective insecticide for mosquito control?" Only 53 percent answered correctly and knew that 2,4-D was not an insecticide but a weedkiller.

The insecticide shelves of Michigan's hardware, drug, garden, and other retail stores contain a great variety of insecticides in bottles, cans, and cardboard packages. The variety seems endless in some stores. The buying public has a great choice-although a somewhat confusing one. Many insecticides are in attractive looking packages with clear, readable labels, but some labels present a problem in reading and understanding.

When I looked closely at some of the pesticide containers, two probblems were evident the labeling itself and the merchandising practices. Let us take some examples of labeling problems first. These were purchased in retail stores in Michigan during 1969:

One brand of spray has a label too big for the bottle and one end covers part of the printing of the use and caution instructions. Another only states on the front part of the container, that the customer could see when it is on the shelf, that it contains an evergreen spray. Not until the buyer turns the can around and reads halfway down the information on the back does he know that it is a spray to kill insects. Sometimes the printing is so small that if a little blurred, it cannot be read without a magnifying glass.

If the customer reads the label to see what is in the product, he may be confronted with "Decachlorooctahydro-1,3,4-metheno-2H-cyclobuta (cd) Pentalen-2-one" or some other long chemical name. How many consumers could be expected to know what is in the package?

Products are constantly changing and so are the active ingredients. As a company finds better and more effective insecticides, new formulations are put on the market. The old ones remain on the shelves, however, until sold, certainly leading to confusion on the part of the buying public. In one case, two identical looking bottles with the same product name but with one saying "Garden Spray" in smaller letters and the other "Insect Spray" in smaller letters were side by side on the shelves. One contained DDT along with other ingredients, and the new product contained Carbaryl or Sevin. Unless the consumer looks closely

a See p. 327.

2 See p. 330. * See p. 334.

and picks the larger size bottles with readily readable labels, he could just as easily pick the one with DDT.

A similar situation was found with bug bombs called "Flying Insect Killer," containing DDT, next to similar bug bombs of the same brand also called "Flying Insect Killer" but not containing DDT. The ones without the DDT are the newer product, but the older one continues to be sold on the same shelf.

The Federal and State registrations require certain signal words, "Poison," "Warning," or "Caution" to appear on the label, denoting the relative toxicity of the chemical and concentration. But even the same cautionary statements on the containers vary for the same ingredients in the same concentration. Some ant traps say "WARNING: Hazardous if swallowed or absorbed through the skin. Do not get on skin, in eyes, or on clothing. Wash with soap and water after using. Do not contaminate feed or foodstuffs. Bury used traps. Keep out of reach of children and domestic animals. Do not apply to areas accessible to children and domestic animals."

Other ant traps with the same concentration of the same insecticide say only "CAUTION: Harmful if swallowed. Keep from children and domestic animals. Wash hands after punching side holes. Avoid storage near feed and foodstuffs." Certainly one of these is overly cautious, or the other is under cautious. Confusing to the buyer? Sure it is.

Precautions for use vary with different brands, even though the active pesticide ingredient is the same. For instance, one ant killer containing an arsenic solution simply states that it can be used inside of the house or in the garden, and should be kept away from children and domestic animals.

Another ant killer with an arsenic solution suggests "placing a few drops of the solution on wax paper in bottle caps and distributing where ants are troublesome, inside or outside. Do not use in locations accessible to children or pets. Avoid contact with skin, eyes, or clothing and wash thoroughly after using."

The second instructions are better, but still far from complete. Unanswered questions of the consumer are: "How should the unused material be disposed? Where can arsenic solutions be placed where ants can get to them but still be inaccessible to children?"

Even the antidote statements for the same chemical vary. Three such statements from three different products, each containing 2 to 3 percent sodium arsenate in a liquid solution are:

1. "Antidote: Give emetic of mustard and salt. Tablespoon to glass of water. Call physician at once."

2. "Antidote: Emetic-swallow large quantities of milk, raw eggs, sweet oil, flour and water followed by castor oil. Call a physician.

3. "Antidote: Induce vomiting by inserting finger in throat. Give prompt emetic of tablespoon salt or mustard in warm water. Call physician. After stomach has been emptied take large dose of milk of magnesia or empsom salts."

One might assume in reading the antidote on the second bottle that all of the ingredients listed should be mixed together and given and then the castor oil. Perhaps some people reading the antidote statement would not know what "emetic" means.

Printing on the label of some containers is small and runs halfway around the can, necessitating constantly turning the can back and

forth to read the writing, making it difficult to follow from line to line. This can be aggravating to the reader.

However, not all the problems are on the label. Merchandising practices complicate the problem.

No label, no matter how clearly written or printed, can be read when price tags are placed over part of the label or packets of free seeds are taped over the active ingredients, the cautionary statements, or the directions for use.

Bottles with the labels completely missing are occasionally found in stores and can still be purchased. Of course, it is hoped that no one planning to use an insecticide would buy an unlabeled bottle, but they do exist.

Hazardous poisons, some extremely toxic, are prominently displayed on store shelves where anyone, young or old, can purchase them. Sodium arsenite, strychnine, sodium cyanide gas, and phosphorus are but four of the highly poisonous materials available for home use. It is not easy to understand why these materials are on the market when much safer chemicals are available for control of the same pests.

Another merchandising practice, especially prevalent in drug and hardware stores, is keeping old pesticides on the shelves, presumably with the hope of eventually selling them. Just a few examples of the products still available for sale are: cardboard bellows-like package containing pyrethin and suggested for use in controlling pests of "victory gardens," which has probably been on the shelf for 25 years; a DDT product last manufactured in 1948 but still for sale; pyrethrin insect spray over 15 years old according to the manufacturer; a fly spray produced before the time when the ingredients had to be listed on the label. It is doubtful if all the insecticide ingredients are still effective but they are still for sale. If a child were poisoned by the materials in some of these old bottles, the poison control center could not advise the physician as to the proper antidote without a timeconsuming chemical analysis.

"TEPP" these letters stand for tetraethyl pyrophosphate the most toxic insecticide commercially available. Several times more poisonous than parathion, a single drop of the concentrated TEPP in the eye of a human can be fatal. It seems almost inconceivable that this product was sold at one time in 4-ounce bottles for use by the home gardener-but it was.

In 1957, the manufacturer tried to recall this product from sale for garden use and was largely successful. However, in at least one store in Michigan, in 1969, this product was still for sale. Hopefully, anyone who did buy it would follow the precautions on the label and wear goggles, an approved respirator, rubber gloves, protective clothing, and very carefully follow the other safety precautions.

These are only a few of the problems facing the consumer as he looks for something to kill the bugs on his roses or tomatoes, or tries to make his backyard barbecue more pleasant by getting rid of the mosquitoes. But they do serve to point up a need for action by the consuming public by State and Federal agencies.

New laws and regulations are needed, and more manpower is essential for better enforcement of existing laws.

Problems require solutions. Sometimes the solutions are simple and can be accomplished with no additional expenses. Sometimes the changes required to solve the problem will involve considerable sums

of money. But even these will be cheap in comparison to human lives saved, sicknesses averted, and protection of other creatures and our environment.

Just what are some of the solutions to the pesticide labeling and merchandising problem? Possible answers might be:

For the consumer

1. Do not buy any pesticide without a USDA registration number, as it would be at least 5 years old.

2. Ask the store owner to remove any price label covering part of the printing on the label so you can read it.

3. If you do not understand the label, ask the sales person to explain it.

4. Do not buy any unlabeled pesticide or a container with partly missing or unreadable label.

5. Buy only products with labels you can read and understand, including the ingredients, uses, restrictions and safety precautions.

6. Be cautious in buying new pesticide products, particularly for novel uses unless recommended by State health, agriculture, extension or natural resources agency. Remember that registration of the pesticide by State or Federal agencies does not mean endorsement.

For State and Federal agencies

1. Adequate funding of regulatory and enforcement agencies so that additional inspections can be made.

2. Greater restriction of certain toxic chemicals from inclusion in pesticide products for home and garden use.

3. Minimum size printing specifications for all information on pesticide labels.

4. Require the provision of a place on label for price marking or application of price label so that label printing is not covered. Restrict price marking to that area.

5. Require date on label, with expiration date indicating the length of time the active ingredients will remain effective in storage, both in unopened container and after opening.

6. Provide legal mechanism for removing from sale pesticides no longer registered by either the U.S. Department of Agriculture or the Michigan Department of Agriculture, providing, however, in most cases, a definite grace period.

7. Remove from sale in all stores all pesticide products which do not bear a USDA or Michigan Department of Agriculture registration number.

8. Require all antidote statements for the same chemical to be similar on all packages.

9. Require the signal words and warning statements on all packages containing the same ingredient and concentration to be the same.

10. Require identification of new product formulations when replacing products of the same name when both will be sold so that customers will know the replacement product.

11. Specify restriction on the label stating where pesticide formulation should not be used if likely to be used for other purposes, for example: surface sprays should not be used for space sprays; or, flying insect sprays should not be used for insects on plants unless specifically stated on label.

12. Require that the printing on the label must be in strongly contrasting color to the background color.

13. Containers should be designed so that small amounts of the material can be poured out without dribbling down the outside of the bottle or can.

14. Directions for disposing of the empty container or surplus pesticide should be required to be included on the label.

And of very great importance:

15. Conduct a more intensive educational program to inform the public as to the meaning of the signal words required on pesticide labels "poison," "warning," " "caution."

(The following reports were cited in Dr. Flink's testimony :)