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Voluntary 6(a)(2) Incident

Reporting Forms


Guidance Documents

August 4, 1998

Table of Contents


Introduction 3
General Considerations 4
Reporting categories and Time Frames (TABLE) 5
Incident Reporting Process (SCHEMATIC) 6
Trade & Professional Association contact list 6

Key to Form Data Fields 7

Administrative/ Pesticide/Incident Data 7
Human Incident Information Data 8
Fish, Wildlife or Other Non-Target Organisms Data 9
Domestic Animal Data 10
Detections of Pesticides in Surface Water Data 11
Detections of Pesticides in Groundwater Data 12
Property Damage with Risk of Human Injury Data 13
Unauthorized Residue in Food & Feed 14
Individual Incident Forms 15
Administrative/ Pesticide/Incident Form 15
Human Incident Information Form 16
Fish, Wildlife or Other Non-Target Organisms Form 17
Domestic Animal Form 18
Detections of Pesticides in Surface Water Form 19
Detections of Pesticides in Groundwater Form 20
Property Damage with Risk of Human Injury Form 21
Unauthorized Residue in Food & Feed Form 22
Aggregate Reporting Key 23
Summary of Exposure Types & Severity Categories Included in Aggregate Reporting (Table) 24
Aggregate Form Example I 25
Aggregate Form Example II 26

Information Regarding the Use of the

Voluntary 6(a)(2) Incident Reporting Forms


A number of industry trade organizations, registrants, professional groups and other interested parties have worked together in cooperation with the EPA to develop a set of reporting forms that can be used by Registrants to report 6(a)(2) related incidents to the EPA. These forms and their corresponding guidance documents provide useful tips and suggestions for meeting reporting requirements under 6(a)(2). Use of these specific forms for required reporting is voluntary. These forms have been developed to meet incident reporting requirements. EPA supports their use in 6(a)(2) compliance efforts as well as other methods of reporting to achieve the same purpose.
There are two sets of forms to reflect the two methods of reporting incidents to the Agency. Incidents that are of a more significant nature must be reported individually. Incidents that are either minor or more commonly encountered must be reported in aggregate. Severity categories and their respective reporting requirement are noted in the guidance instructions.
Typically, the single incident forms can be used to collect data regarding any incident. After the severity category of any given incident is determined the appropriate method of reporting that incident to the EPA can then be determined.
The single incident forms are divided into two specific areas. The first area describes “administrative data” or general demographic and product information that is gathered for any incident. There are seven supplemental addenda relating to the seven incident types i.e., human, domestic animal, fish/wildlife/plant/other non-target organisms, groundwater, surface water, food and feed, and property damage with risk of human injury. After collecting the information and the severity classification is determined, the Registrant can then ascertain whether the incident must be reported individually or in aggregate. If the incident must be reported individually the single incident forms can be used to submit the information directly. If the incident must be reported in aggregate certain information must be transferred to the aggregate report form and submitted in that manner.
General guidance information is provided in this document to aid in the completion of these forms. For further, or more specific guidance, consult 40 CFR Part 159.184 for full text and definitions. Some additional information is provided in Pesticide Registration Notice (PR Notice) 98-3.
These forms contain fields for reporting of information which may or may not be required to be reported to EPA under FIFRA 6(a)(2) and the regulations at 40 CFR 159.152 et.seq.. Use of this form is voluntary and is not intended to infer that any designated fields should be submitted to EPA or to mandate reporting of any specific information to EPA. Registrants/or applicants should consult their own legal counsel or FIFRA 6(a)(2) Reporting Officers before responding.

General Considerations:

  • Due to the nature of incidents and how they are typically reported through the 6(a)(2) process, Registrants do not guarantee the authenticity or accuracy of information contained in the reports required to be submitted to the Agency.

  • The forms contain some fields of data that are optional. These fields are used to aid the Registrant in general data collection purposes. In some cases these fields represent data that are not required but can be submitted to document important information the Registrant believes is vital to a better understanding of the incident.

  • The information collected on the form for Domestic Animal data is not required for single incident reporting as none of the severity classifications related to domestic animals are reported individually. All of these incidents are submitted on the aggregate forms. Data collected on the domestic animal form may be required by the EPA in cases of incident follow-up.

  • The Registrant is only required to submit information that has been provided. No investigation or follow-up is required, but may be useful if further information helps qualify or clarify reported incidents.

  • A portion of the category of H–E (anticipated or “may suffer” clinical effects) has been dropped from the reporting requirement by the EPA until further notice (see PR notice 98-4). The category of H-E is now limited to adverse effects that are unspecified or unknown.

  • Exposure type and severity categories of humans and domestic animals take into account both duration and intensity of clinical effects. As noted in PR Notice 98-3 for human incidents:

“The persistence of symptoms or the development of delayed symptoms should be considered when classifying severity. For example, human cases may report developing common symptoms like headaches, general weakness, memory and concentration problems, depression, irritability, muscular aches and pains, or shortness of breath. If these symptoms last for just a few days and are minimally troublesome (do not require treatment) then they would be classified as minor (H-D). However, if symptoms persist for one month or longer they would be classified as moderate (H-C). Symptoms persisting for two or more months that significantly alter daily activities would be classified as major (H-B).”

Generally, major effects would include “life threatening” or effects resulting in “residual disability”. They could also include “adverse reproductive” effects.

Moderate effects are typically “more pronounced, more prolonged, or of a more systemic nature than minor effects”. Examples include, “isolated brief seizures”, “gastro-intestinal systems leading to dehydration” and “corneal abrasions.”

Minor effects would include effects such as “skin rash, itching, conjuctivitis (red, tearing eyes), drowsiness, transient cough, headache, joint pain, agitation, restlessness, or mild gastro-intestinal symptoms such as self-limited diarrhea, stomach cramps, or nausea. These effects are reported to have lasted less than one month.”

Note: See PR Notice 98-3 for a more detailed description of severity categorization for humans and domestic animals.

  • The following table provides a quick reference guide to reporting timeframes and content:



Other Reporting Categories


Human Deaths (H-A)

ASAP-No Later than 15 days
Submission Format: Individual Report
Provide detailed information for each incident

Scientific Studies described in (159.165)

Information about discontinued studies (159.167)

Human epidemiology and exposure studies (159.167)

Detection of a unauthorized pesticide in or on food or feed (159.178)

Detection of metabolites, degradates, contaminates, impurities (159.179)

Failure of performance studies related to public health products (159.188 (a)(2), (b)(2))

Substantiated incidents of pest resistance (159.188 (c))

Other information described in (159.195)

Property Damage with risk to human health (PD-A) and other information (159.195)

Submit within 30 calendar days
Submission Format:

- Individual Report (Food/Feed, Property Damage with risk of injury to humans)
- For all other submissions refer to 159.156

Human – Major (H-B)

Human – Moderate (H-C)
Major – Wildlife (W-A)

Plant (P-A)

Detection of pesticide in water at levels greater than
MCL/HAL (G-A) (159.178 (b) & 159.184 (c)(5))
Efficacy failure incidents regarding public health products(159.188 (a)(1) & (b)(1))

Accumulate 1 Month
Submit by the end of the month following the accumulation period.
Submission Format: Individual Report
Provide detailed information for each incident as required in section 159.184(c)

Human – Minor (H-D)

Unspecified or Unknown effects (H-E)

All Domestic Animal (D-A,B,C,D,E)

All Other Categories for

Wildlife (W-B)

Plant (P-B)

Detection of pesticide in water below MCL/HAL but otherwise reportable (G-B,C) ((159.178 (b) & 159.184 (c)(5))

Accumulate 3 Months
Submit by the end of the 2nd month following the accumulation period
Submission Format: Aggregate
Aggregate and submit count of incidents and effects for each product or AI as required in section 159.184 (e)

Incomplete toxicological and ecological studies

(159.165 (d))

Consult sec. 159.165 (d) when testing is completed but study not finalized

  • The overall flow of the reporting process is depicted in the following diagram:

  • Original and updated versions of these forms and guidance tools are available from the following organizations. These organizations have been closely involved in the form development process and serve as a valuable resource to their constituents and others interested in 6(a)(2) related efforts.

American Crop Protections Association Chemical Specialties Manufacturers Association

1156 Fifteenth St., NW, Suite 400 1913 Eye St. NW

Washington, DC 20005 Washington, DC 20006

Phone: (202) 296-1585 Phone: (202) 872-8110

Fax: (202) 463-0474 Fax: (202) 872-8114

Staff contact: Ray McAllister Staff contact: Steve Kellner

Web site: Web site:
Chemical Manufacturers Association International Sanitary Supply Association

1300 Wilson Blvd. 7373 North Lincoln Ave.

Arlington, VA 22209 Lincolnwood, IL 60646-1799

Phone: (703) 741-5637 Phone: (847) 982-0800

Fax: (703) 741-6091 Fax: (847) 982-1012

Staff contact: Has Shah Staff contact: Bill Balek

Web site: Web site:
Chemical Producers and Distributors Association PROSAR Product Safety Call Center

1430 Duke Street 2635 University Ave W. Suite 195

Alexandria, VA 22314 St. Paul, Minnesota 55114

Phone: (703) 548-7700 Phone: (651) 917-6100

Fax: (703) 548-3149 Fax: (651) 641-0341

Staff contact: Warren Stickle Staff contact: Joele Schmitz

Web site: Web site:
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