Comment submitted by Jim T Criswell, Pesticide Safety Education

These comments represent those of the Pesticide Safety Education Program and not those of Oklahoma State University. EPA has used the term "handlers" in required labeling for the registrant. This term is only defined in 40 CFR 170 under the Worker Protection Standard. Persons making pesticide applications outside of the WPS regulation are not defined as handlers but mixer loaders or applicators. We suggest that EPA refrain from using the term "handlers" except when it applies to WPS applications. This clarifies the label and removes much confusion in the applicator and regulatory community. Jim T Criswell Pesticide Coordinator