Label Interpretation Concerning No Foam® B Bio-Degradable Spreader-Activator-Buffer (California Registration No. CA-1050775-50008-AA)

This label interpretation concerning the spray adjuvant NO FOAM® B BIO-DEGRADABLE SPREADER-ACTIVATOR-BUFFER (NO FOAM B) (label enclosed) (California Registration Number 1050775-50008-AA) responds to a recent question, “Can NO FOAM® B be used for structural uses or is NO FOAM® B use limited to agricultural uses only?”

Labeling for NO FOAM® B, under “Directions for Use” states:

• NO FOAM B is a Spreader-Activator-Buffer designed to increase the efficiency of various agricultural chemicals and aid the reduction of pH in aqueous systems. It should be used in buffering highly alkaline water. It also assures quick wetting and uniform coverage of an agricultural spray. NO FOAM B is especially beneficial in improving the efficiency of organic phosphate pesticides.

Title 40 of the Code of Federal Regulations (40 CFR), Part 156 – Labeling Requirements, section 156.10 (i)(2)(iii) states:

• Contents of Directions for Use. The directions for use shall include the following, under the headings “Directions for Use”: The site(s) of application, as for example the crops, animals, areas, or objects to be treated.

It should be noted that the U.S. Environmental Protection Agency (U.S. EPA) does not register spray adjuvants, such as No Foam B as pesticides. However, spray adjuvants are registered as pesticides in California and are registered using the same U.S. EPA registration requirement above.

According to the requirement of 40 CFR section 156.10 (i)(2)(iii), NO FOAM® B labeling “Directions for Use” indicates “various agricultural chemicals” as the “sites” or “objects” to be treated. Therefore, NO FOAM® B is registered for use with agricultural chemicals only. Any use with structural use pesticides is prohibited.

It is important to note “FOR AGRICULTURAL SPRAYS” appears above the beaker style logo in the middle panel of the label and shows a strong indication NO FOAM® B is registered for agricultural sprays.

The legal “site(s)” registered for the product NO FOAM® B are located under the “Directions for Use.” Moreover, when interpreting any pesticide label, the “site(s)” registered will be found only under the labels “Directions for use” statement.

If you have any questions, please contact the senior pesticide use specialist/liaison serving your county.

Sincerely,