Uniform Policies

PREAMBLE: The following Uniform Policies are designed primarily for the guidance of State Pesticide Control Officials in those states which have adopted the Uniform State Pesticide Act, but should be used by other state officials insofar as their statutes will permit.

REGISTRATION

Resolved that the uniform application forms for registration should be used by state control officials. Two specimens or exact copies of the labeling of each proposed product should be submitted with the application. Also, there should be submitted the name and percentage of each active ingredient and the total percentage of inert ingredients in the product, the proposed directions for use, and a list of the specific pests for control of which it is to be sold, if such information is not contained in the labeling. Such other pertinent information concerning inert ingredients and physical properties of the product shall also be included on request. (Tentative 1967) (Adopted 1968)

Resolved that products which are discontinued by a manufacturer be reregistered for a period of two years. Said two year limit covers the year in which the item is declared to be discontinued by the registrant and one additional year to permit time for distributors to dispose of shelf stocks. (Revised, Tentative 1970) (Adopted 1971)

REGULATIONS

Advance notices of proposed rules, regulations, restricted lists, amendments, related subjects and hearings thereon should be sent to all pesticide registrants of record, and to trade associations that have so requested, in order to develop useful information from these interested parties. Since many have no other source, notices should preferably be mailed as early as possible but as least for delivery at the time of publication of the local notice of hearing.

NOTE: Deleted uniform policies were adopted many years ago and have become obsolete through preemption by provisions in FIFRA or its regulations.

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Allowed Deviations of Analytical Results from Label Claims for Active Ingredients in Pesticide Formulations (Adopted by AAPCO March, 1998)

The Laboratory Liaison Committee suggests that the allowed deviations of analytical results from label claims on pesticide formulation be based on Horwitz’ expected Standard Deviation (HSD) calculations (Horwitz, Analytical Chemistry 54:1, 67A-76A, 1982). The following equations are used to calculate allowed deviations:

Horwitz Between-Laboratory Coefficient of Variation = HCV(%) = 2(1 – 0.5 log (claim%/100)) Horwitz Standard Deviation = HSD = (Claim%)(HCV%)/100

In general, a “passed” judgment on a pesticide formulation can be made if the analytical results are within the following guidelines:

for “uniform” samples: -3HSD/+6HSD
for “non-uniform” samples: -4HSD/+8HSD

For examples of allowed deviations, please refer to the following table. Additional considerations:

“Uniform” samples are homogeneous products which can be analyzed by established procedures. In most cases, validated analytical methods are available for these samples.

Non-uniform” samples are non-homogeneous samples or products which are difficult to sample or subsample. These products may not be uniformly mixed or packaged and include some special formulations like natural products. These types of samples include fertilizer containing pesticides, pesticides in pressurized containers, strips, plastic bands, collars, grain and other carriers. Natural product formulations such as rotenone and pyrethrin are also included in this group. When it is necessary to use methods which are not validated for accuracy, precision, and reproducibility in a specific matrix, the “non- uniform” guidelines may be used for allowed deviations. States may use judgment in placing a sample into the “uniform” or “non-uniform” category.

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