4.3 Directions for Use, REI, and PHI

Directions for Use are the enforceable work order

The Directions for Use section is the work order. Near the top you will find the federal misuse sentence: it is a violation of federal law to use the product in a manner inconsistent with its labeling. This section teaches you what to extract: site, pest, rate, timing, method, and spray volume, plus the clocks (restricted-entry interval (REI) and preharvest interval (PHI)), worker notification, mixing and loading, chemigation, endangered-species bulletins, 24(c) sheets, storage, disposal, and container handling.

Every direction is product-specific. A cotton rate is not a wheat rate. A pasture grazing restriction is not a wheat PHI. A turf "until sprays have dried" sentence is not a 12-hour agricultural REI.

Oklahoma adds two gates the federal label cannot waive: the product must be registered for sale and use in Oklahoma, and you must be certified and licensed in the category that matches the site. Category 7a restaurants and the three-foot "immediately adjacent" rule define where your credential applies. They do not add a site the label omitted, raise a rate, or shorten an REI.

Site, pest, rate, timing, method, and spray volume

Read the crop or site list as a closed list. If winter wheat is named and rye is not, do not treat rye as close enough. If bearing fruit is excluded, a backyard apple in Norman is excluded even on a 7a account. Food-handling establishments, hospitals, schools, and restaurants appear only when listed; 7a permission to work in restaurants is an ODAFF site category, not a blanket label expansion.

The pest list is also closed for labeled uses, with narrow federal FIFRA section 2(ee) exceptions that cannot raise the rate, shorten PHI or REI, or add chemigation. Independent Core study treats 2(ee) as an exception with walls, not as a dealer loophole. If the target pest is not on the label and no lawful exception applies, pick another product.

Rate is amount of product per acre, per 1,000 square feet, per gallon of mix, or as a percentage of spray. Do not exceed the labeled rate. Applying above the label is a federal and state violation even if a neighbor wanted a hotter mix on Palmer amaranth. Applying below a labeled range can be lawful when the label gives a range and does not set a mandatory minimum for resistance or efficacy—but starving a rate is not a PHI shortcut and can drive resistance (Chapter 9). Stacking two products with the same active ingredient can still exceed that active ingredient's seasonal maximum even if each jug is "within its own rate."

Timing includes crop stage, pest stage, seasonal cutoffs, rainfast periods, pre-graze intervals, and PHI. Method includes ground boom, aerial, airblast, chemigation, crack-and-crevice, bait placement, and ultra-low volume. If the label says ground only, aerial is not a 2(ee) add-on. Spray volume (gallons per acre) and nozzle or coverage language are directions when the label states them—especially for herbicides that need coverage or for canopy penetration in cotton.

Worked Oklahoma reads:

• Wheat: 1.0 pint per acre, ground or aerial, a stated gallons-per-acre minimum by air, REI 12 hours, PHI 60 days, and a separate grazing interval—each clause is separate.
• Cotton: band versus broadcast rates are not interchangeable without doing the math.
• Pasture: "Do not cut for hay until 30 days" can sit beside a different grazing interval.
• Turf: 1.5 ounces per 1,000 square feet is not "about a jug a lawn."
• Restaurant: crack-and-crevice into voids is not a broadcast kitchen fog unless that method is labeled.

Restricted-entry interval versus preharvest interval

The restricted-entry interval is the time after the application during which agricultural workers (other than trained, equipped early-entry workers) must not enter the treated area. On Worker Protection Standard–covered products it lives in the Agricultural Use Requirements box, with the sentence "Do not enter or allow worker entry into treated areas during the restricted-entry interval (REI)." A single REI may apply to all labeled uses, or crop-specific REIs appear next to each crop, preceded or followed by "Restricted-entry interval" or "REI" (40 CFR 156.208). Typical values are 4, 12, 24, or 48 hours, sometimes days. Fumigant entry restrictions are case-by-case and may use air-concentration criteria rather than a simple hour count.

Early entry during the REI is allowed only under Worker Protection Standard rules and the early-entry PPE on that label. Early entry is not a PHI waiver and is not a loophole for harvesting wheat.

The preharvest interval is the minimum time between the last application and harvest of the crop (or, for some labels, grazing, haying, or feeding). PHI protects residue tolerances—legal maximum residues on food or feed. It is usually stated in days in the crop directions ("Do not apply within 30 days of harvest"). PPE does not shorten PHI. Washing grain does not shorten PHI. A buyer who needs the field this week cannot buy a shorter PHI.

REI and PHI run on different clocks. A wheat herbicide can have REI 12 hours (scouts may enter the next morning in ordinary work clothes after the REI) and PHI 60 days (you still cannot harvest). A cotton insecticide can have REI 48 hours and PHI 14 days. Always take both numbers.

Non-agricultural uses (most landscape turf, many rights-of-way, interior 7a) do not put worker-entry rules inside the Agricultural Use Requirements box. Look instead for Non-Agricultural Use Requirements: keep people other than the applicator and pets out during application, and do not enter until sprays have dried. Sod farms, greenhouses, nurseries, and farms are agricultural Worker Protection Standard sites; a Stillwater sod farm uses the REI, while a commercial office lawn usually uses the non-agricultural re-entry sentence.

Worker notification

Worker Protection Standard notification tells workers when an area is under an REI. Some products require oral warning. Some require posted warning signs at entrances. Some double-notification products require both—often because of high acute toxicity or another EPA decision. The Agricultural Use Requirements box states when double notification applies. Notification is not optional on a custom-application wheat crew that still has employees who might enter. Chapter 2's Worker Protection Standard section is the full worker-and-handler framework; here, find the notification sentence on this label and do what it says.

For 7a restaurants, notification looks different: occupants, managers, and re-occupancy times come from the Directions for Use (vacate, cover food, ventilate, do not reenter until spray has dried or a stated time), not from a farm REI box.

Mixing, loading, application, storage, disposal, and container handling

Mixing and loading directions may specify order of addition, agitation, spray-tank materials, water pH, and incompatibility. If the label says do not mix with a named group, a jar test does not legalize that mix. Closed-system or engineering-control language, when present, is part of the handler directions.

Application directions include boom height, droplet quality, wind-speed windows, buffers, and the standard agricultural sentence: do not apply this product in a way that will contact workers or other persons, either directly or through drift; only protected handlers may be in the area during application.

Storage directions: store in the original container, in a locked, ventilated place, away from food and feed, at labeled temperatures, and do not contaminate water, food, or feed by storage or disposal. Chapter 12 expands Oklahoma storage practice; the label is still the product-specific rule.

Disposal splits leftover pesticide (mix, rinsate) from the container. Follow the Storage and Disposal heading. Container Handling on many nonrefillable rigid containers of dilutable product requires triple rinsing or pressure rinsing promptly after emptying, then recycle or dispose as directed. Do not reuse a nonrefillable jug for water on the next wheat job. Oklahoma's Unwanted Pesticide Disposal Program is the place for leftover concentrate the label tells you not to dump; it does not rewrite the rinse method on the jug.

Chemigation only when labeled

Chemigation is application through an irrigation system. EPA's chemigation policy, as carried in the Label Review Manual from PR Notice 87-1, is binary for the products it covers: the label either includes chemigation directions (system types, backflow, supervision, extra statements for Toxicity Category I products) or it states "Do not apply this product through any type of irrigation system." If the prohibition is there, a Harmon County cotton pivot is not a sprayer. You cannot add chemigation with a 2(ee) recommendation. If chemigation is labeled, those system instructions are as enforceable as the rate.

Endangered species and Bulletins Live! Two

When Directions for Use include an Endangered Species Protection statement that sends you to EPA bulletins, you must obtain the Bulletin for the county, product, and month of application. EPA's Bulletins Live! Two system is the current lookup. Bulletins may be pulled up to six months before the application; you must use the Bulletin that is valid for the month you actually apply. When the label references them, Bulletins are enforceable FIFRA use limitations. They do not replace Oklahoma restrictions, including southwestern restricted-area herbicide rules from Chapter 3. If the Bulletin shows no extra limitation that month, you still follow the rest of the label. Search with the Section 3 EPA Registration Number, not only an SLN number.

Special Local Need 24(c) supplemental labeling

A FIFRA Section 24(c) Special Local Need registration lets a state register an additional use to meet a local need. The SLN labeling is supplemental. Carry and follow both the container's Section 3 label and the 24(c) sheet. The SLN cannot be used in another state, cannot be used after it expires, and cannot be used if EPA has denied the use. Oklahoma still expects in-state product registration and a matching category. An SLN that adds a cotton use does not let a 3a turf applicator make that application.

Do not exceed the labeled rate, and keep Oklahoma's extra gates

Exceeding rate, site, number of applications, or the minimum interval between applications is inconsistent with labeling. Then apply Oklahoma's gates: in-state registration of that product, and your category. 7a plus a restaurant is still wrong if the label forbids food areas. 1a plus wheat is still wrong if wheat is not a labeled crop. 3a plus turf is still wrong during an REI on a sod farm if you send unprotected workers in.

Oklahoma scenarios

Caddo County wheat. REI 12 hours, PHI 60 days. Scouting tomorrow in work clothes can be lawful after the REI; harvesting next week is not.

Harmon County cotton chemigation. The label says "Do not apply this product through any type of irrigation system." Injecting into the pivot is a misuse even if gallons-per-acre math is perfect.

Osage County pasture. Haying interval 37 days, grazing interval 7 days. Those are PHI-like clocks, not REIs.

Payne County turf: sod farm versus office park. Sod farm: Agricultural Use Requirements and REI. Office park: Non-Agricultural Use Requirements until sprays dry.

Norman 7a restaurant. Cover food, treat cracks, reenter as labeled, stay within three (3) feet outdoors. The three-foot rule does not authorize a broadcast parking-lot spray at 20 feet, and it does not replace a label that says do not use in food-handling establishments.

Exam traps for this section

• Treating REI and PHI as the same clock.
• Chemigating when the label prohibits irrigation-system application, or adding chemigation through a 2(ee) note.
• Leaving the 24(c) sheet at the office.
• Skipping Bulletins Live! Two when the label directs you there.
• Using the 7a three-foot restaurant rule as a substitute for labeled sites, rates, or food-area directions.
• Exceeding rate to make it work on resistant weeds.