Careful attention has been given to the definition of the term "ingredient statement. There are two options for an ingredient statement on the label of pesticides as set forth in the uniform act. Option 1, which is preferred, consists of a statement of the name and percentage of each active ingredient, together with the total percentage of inert ingredients in the economic poison. Option 2 is a statement of the name of each active ingredient together with the name of each inert ingredient and the total percentage of inert ingredients, if there are any in the economic poison. The act provides that Option 1 shall apply if the preparation is highly toxic to man and, furthermore, in case an economic poison contains arsenic in any form, there must be shown a statement of the percentage of total arsenic expressed as metallic and water-soluble arsenic expressed as metallic. This requirement is the same as that in the Federal act.

Because many pesticides can cause serious injury if improperly handled, precautions or appropriate information concerning the particular hazards is a necessary part of adequate labeling. Sometimes the existence or the severity of a hazard is not discovered until accidents occur after a product has been marketed. The complete toxicological properties of all pesticides are not available, and not infrequently labeling of products requires revision in light of newly developed information. As individual States attempt to get adequate precautionary labeling of hazardous materials, there is need for uniform action to avoid conflicting requirements and multiplication of the manufacturer's problems. Several manufacturers' organizations have realized that development of proper labeling of hazardous chemicals is a part of good business procedure. They have found that attacking the problem themselves does much to forestall the need for corrective action by State administrations, therefore avoiding troublesome conflicts that arise when each State attempts to solve the problem separately.

The Manufacturing Chemists' Association has studied the problem and issued a guide for the preparation of warning labels.

The problem of precautionary labeling of pesticides is further complicated by the fact that, in many States, some poisonous or caustic pesticides come under the jurisdiction of a pharmacy act as well as a pesticide act. In other States the labeling of hazardous pesticides is left solely to one administration.

Some laws require protective coloring of certain poisonous materials. In general, the requirements pertain only to calcium arsenate, lead arsenate, and sodium fluoride; but additional chemicals may be included. The need for such legislation, and the consequent problem of uniform action by different States, is avoided when manufacturers on their own initiative color the chemicals that might be confused with foodstuffs.

One of the purposes of pesticide laws is to assure delivery of materials that conform to the guaranteed analysis shown on the label. This requires sampling products offered for sale in the State and performing the necessary examinations and chemical and physical analyses. The sampling should be on a scale large enough to provide an adequate analysis of the materials used and to make certain that they comply with the law. Publication of the official findings is a benefit of a well-functioning law.

In the administration of laws covering such a highly technical and rapidly expanding field as economic poisons, there should be free exchange of information among regulatory officials, Federal and State. An Association of Economic Poisons Control Officials has been formed. Its executive committee meets regularly with representatives of the Federal office to consider matters of policy, particularly with regard to proper labeling requirements. Such cooperation, recognized by provisions in both the uniform State act and the Federal Insecticide, Fungicide, and Rodenticide Act of 1947, has been beneficial to users of pest-control materials as well as to manufacturers. Many things, such as information with regard to the toxicity of a particular chemical, can best be developed by a Federal agency and then distributed to the State officials.

California has a law with regard to prohibiting the sale of fresh or dried fruits or vegetables carrying deleterious spray residue. Although other States did not have such a specific law, the same control may be exercised through the different State food and drug acts.

ALL IN ALL, economic poisons probably are as closely regulated as any other class of materials generally sold. Besides Federal registration before a product can be shipped in interstate commerce, State laws require registration in the individual States.

In the enforcement of these laws, official samples are drawn from materials offered for sale, and analyses are made to determine if the products correspond to guarantee. Sale of a deficient material is a violation which is usually considered a misdemeanor. Also, publishing the analyses of official samples serves as a strong deterrent to sale of adulterated materials.

Effective enforcement by regulatory offices assures purchasers of properly labeled pest-control materials that conform to the guarantee stated on the label by the manufacturer.

ALLEN B. LEMMON is chief of the Bureau of Chemistry, California Department of Agriculture. The Bureau administers laws relating to the labeling and sale in California of agricultural chemicals, including economic poisons. Mr. Lemmon received a bachelor's degree in engineering from Stanford University in 1930 and a degree of engineer in 1932. He joined the California Department of Agriculture in 1933, as an inspector of economic poisons and fertilizers, and advanced to chief of the Bureau of Chemistry in 1946.