6.3 Directions for Use, REI, PHI, and SDS
Key Takeaways
- Directions for Use are the legally binding use pattern: labeled sites, pests, rates, methods, timing, buffers, PPE, and prohibitions, including agricultural versus non-agricultural boxes.
- FIFRA section 2(ee) allows limited uses that are not inconsistent with labeling, such as a lower rate or an unlabeled pest on a labeled site unless the label forbids those deviations; it never authorizes a higher rate, a shorter PHI, or an unlabeled site.
- The restricted-entry interval (REI) is the WPS clock before unprotected agricultural workers may enter a treated area; the preharvest interval (PHI) is the crop-specific clock before harvest to keep residues within tolerance.
- Agricultural Use Requirements implement 40 CFR 170 (training, notification, REI, early-entry PPE); Non-Agricultural Use Requirements cover turf, golf, rights-of-way, interiors, and many mosquito uses and often require waiting until sprays dry.
- The Safety Data Sheet (SDS, formerly MSDS) is a 16-section OSHA workplace hazard-communication companion; it does not replace the label and cannot authorize off-label use.
Directions for Use are the legally binding use pattern
Everything above the Directions for Use heading tells you what you are holding. Directions for Use tell you whether you may use it here, now, at this rate, with this equipment. EPA requires the misuse statement in this section. Practically, this is the recipe GDA will compare to your tank, your GPS log, and your Rule 40-21-5 record.
Directions specify sites (peanuts, cotton, bearing pecans, residential turf, ornamental beds, mosquito adulticiding habitats, rights-of-way), pests, rates (amount per acre or per gallon of mix), maximum seasonal amounts, application methods (broadcast, band, chemigation, aerial, ULV), timing (growth stage, pre-bloom, dusk), spray-drift buffers, PPE, and prohibitions (do not apply through any irrigation system; do not use on golf greens; not for use on crops). If the site is not listed, the use is not legal. Your commercial category does not rewrite that list.
Storage and disposal directions in this section (or a labeled box nearby) are still directions: temperatures, locked storage, triple rinse, and container recycling. National Core tells you to read them before you store or dispose, not after the rinse water has already hit a ditch.
FIFRA section 2(ee): limited exceptions, not a loophole
FIFRA section 2(ee) lists uses that are not "inconsistent with labeling" even though the booklet does not spell them out. Classic Core teaching:
- Apply at a dosage, concentration, or frequency less than specified, unless the label prohibits deviation
- Apply against a target pest not named, if the application is to a labeled crop, animal, or site, unless the label says the product may be used only for listed pests
- Employ a method of application not prohibited
- Mix the pesticide with a fertilizer if not prohibited
Section 2(ee) does not let you raise the rate, shorten the interval between sprays, shorten the PHI, apply to an unlabeled site, or ignore a prohibition. You cannot 2(ee) your way into chemigation when the label says do not apply through any irrigation system. You cannot 2(ee) a cotton rate onto peaches. Written 2(ee) bulletins from a registrant are recommendations that must stay consistent with the registered label; they are not a second registration.
Agricultural Use Requirements versus Non-Agricultural Use Requirements
Look for two boxes that candidates mash together.
Agricultural Use Requirements appear when the product is labeled for WPS sites: farms, forests, nurseries, and greenhouses producing agricultural plants (40 CFR Part 170). The box tells you to use the product in accordance with the labeling and the Worker Protection Standard. It points to handler PPE, the restricted-entry interval (REI), notification to workers, and early-entry exceptions. A Tift County peanut field, a Crisp County cotton field, a pecan nursery, and a sod farm producing turf for sale are agricultural uses when the box is on that label.
Non-Agricultural Use Requirements apply to uses outside WPS: residential and commercial turf and ornamentals that are not agricultural production, golf courses that are not producing sod as a crop, rights-of-way, interiorscapes, and many public-health mosquito applications. These boxes often say keep people and pets out until sprays have dried or dusts have settled. That is not an REI, and it is not Georgia's landscape posting rule.
Rule 40-21-9 landscape posting (sign at the primary entry until the day after application, plus a written statement) is a Georgia notice rule for landscape applications. It sits beside the label; it does not replace WPS REI posting on a peanut farm, and a WPS REI sign does not satisfy 40-21-9 on a Gwinnett office-park lawn. Chapter 4 teaches the 4-by-5-inch sign. This chapter's job is to keep the clocks straight.
REI versus PHI: two clocks on the same peanut or cotton label
The restricted-entry interval (REI) is the time after the application during which unprotected workers may not enter the treated area. It lives under Agricultural Use Requirements. WPS labeling states: do not enter or allow worker entry into treated areas during the REI. EPA's default floor is 4 hours unless a longer REI is on the label; some products list 12, 24, 48 hours or several days. No agricultural worker may enter during the first 4 hours except narrow WPS exceptions. After 4 hours but before the REI ends, only trained early-entry workers doing allowed short-term tasks may enter, and they must wear the early-entry PPE listed on the label — not street clothes, not the mix-load coveralls you left on the truck seat.
WPS also requires notification: oral warnings and/or posted warning signs at treated-area entrances. Some highly toxic products require both (double notification). Posted application information and SDS access at a central location are WPS employer duties. On a South Georgia peanut crew, that means the REI sign stays up until the interval expires, even if the foliage looks dry in two hours of July sun. On cotton, a harvest-aid or insecticide REI can block scouts, irrigators, and module-builder crews. If you tank-mix, use the most restrictive REI and the most restrictive handler PPE among the products in the tank.
The preharvest interval (PHI) is a different clock. It is the minimum time between the last application and harvest (or grazing, cutting hay, or other labeled commodity event) so residues stay within the tolerance. PHI is crop-specific: the same insecticide may have one PHI on cotton and another on peanuts or soybeans. PHI does not tell field workers when they may walk in without PPE. REI does not tell the grower when the gin or the buying point will accept the crop. You can satisfy REI and still be too early to harvest, or you can be past PHI for a scout wearing street clothes who still cannot legally enter because REI has not expired.
| Clock or document | What it protects | Where it lives | Georgia snapshot |
|---|---|---|---|
| REI | Agricultural workers entering treated plants/soil | Agricultural Use Requirements (WPS) | Peanut fungicide or cotton insecticide: scouts stay out or wear early-entry PPE until the hours elapse |
| PHI | Residue on harvested food or feed | Crop table in Directions for Use | Days after last cotton or peanut application before harvest |
| Non-ag reentry | Residents, customers, pets, the public | Non-Agricultural Use Requirements | Office-park turf: typically until sprays dry |
| Rule 40-21-9 posting | Landscape notice to the public | Georgia rule, not the federal REI box | Sign until the day after a commercial landscape application |
| SDS | Workplace hazard communication | OSHA 16-section sheet | Mix-pad spill, transport, fire; does not set PHI or add a crop |
Mosquito ULV and turf: Directions for Use in non-ag clothing
A Category 41 ULV adulticide label will specify equipment type, droplet-size limits (often a volume median diameter range), vehicle speed, flow rate, release height, wind, and whether the product is applied undiluted. Those numbers are the use pattern. Putting the same concentrate through a hydraulic boom calibrated for peanuts, or thermal-fogging when the label allows only cold ULV, is inconsistent with labeling. Many public-health labels say not for use on crops. Bee and aquatic statements in the environmental box pair with dusk or night timing in Directions for Use. Follow both.
A Category 24 ornamental label may list phytotoxic species, maximum temperatures, and "do not overlap spray swaths on..." language. Over-application on azaleas is a Directions-for-Use violation even when the Non-Agricultural Use Requirements box only mentioned keeping pets off until dry. Test spots and plant lists are part of the legally binding pattern, not customer-service tips.
SDS (formerly MSDS): companion, not a second label
Manufacturers must provide a Safety Data Sheet for workplace hazard communication under OSHA (aligned with the Globally Harmonized System). Older manuals say Material Safety Data Sheet (MSDS); the current document is the SDS. Employers whose employees handle the concentrate keep SDS copies available. The Core Manual still treats this sheet as required companion information.
A GHS SDS has 16 sections, including identification, hazards, composition, first aid, fire-fighting, accidental release, handling and storage, exposure controls and PPE, physical properties, stability, toxicology, ecology, disposal, transport, and regulatory information. That is why emergency responders want the SDS at a mix-pad fire.
The SDS does not replace the label. It does not add peanuts to a cotton-only product, shorten a PHI, waive an REI, or authorize ULV when the label forbids it. PPE on an SDS can differ from labeled handler PPE because OSHA and FIFRA answer different questions. For pesticide use, GDA and EPA enforce the label. Use the SDS for spill chemistry, transport classification, and occupational exposure context. If the SDS is more protective for pouring concentrate, a professional follows the stricter handling practice — and still applies the product only as the label allows.
When to reread: mix, apply, store, dispose, and after amendments
Section 6.1 started the Core list at buying. Finish it:
- Mixing and loading: PPE, dilution order, agitation, incompatible mixes, dump-pad statements, and anti-siphon if you are injecting into irrigation (the Anti-Syphon Device Act is a separate Georgia duty; the label still must allow chemigation).
- Applying: site, rate, method, buffers, bee windows, ULV droplet limits, REI posting, non-ag reentry.
- Storing: temperature, segregation, original containers, Keep Out of Reach of Children.
- Disposing: leftover mix, rinsate, and container instructions; do not invent a ditch-disposal method because the SDS has an ecology section.
- After label amendments: EPA can change REI, PPE, pollinator language, or the crop table while the brand on the warehouse rack stays the same. Last year's booklet on this year's lot is how good crews make federal misuse cases.
Reread the current container labeling at each of those gates. Keep the SDS in the shop binder for emergencies. Do not let the SDS talk you into an off-label peanut, cotton, turf, or mosquito use.
On a Tift County peanut label, the Agricultural Use Requirements box lists a 24-hour REI and the crop table lists a 14-day PHI. Field scouts want to walk the treated peanuts in street clothes 8 hours after the spray, and the grower wants to dig 10 days after the last application. Which statement is correct?
A shop SDS for a cotton harvest aid lists different gloves than the handler PPE box on the container label and describes a spill-neutralizing mixture. The producer wants to use the SDS glove line as permission to apply the product to an unlabeled vegetable garden beside the gin. What is the correct role of the SDS?
A Category 41 crew wants to put a crop insecticide through a truck ULV nozzle because the common name matches their usual adulticide, and a Category 24 crew wants to raise a turf herbicide rate to "burn down" boxwoods the label lists as sensitive. What does Directions for Use require?