Pesticide Registration Process Adds New Stakeholder Procedures for Endangered Species Act Consultations

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The Environmental Protection Agency (EPA) is adding new stakeholder input procedures to its pesticide registration review process and consultations under the Endangered Species Act (ESA), including a broader role for the U.S. Department of Agriculture (USDA). EPA released a paper discussing these changes entitled, “Enhancing Stakeholder Input in the Pesticide Registration Review and ESA Consultation Processes and Development of Economically and Technologically Feasible Reasonable and Prudent Alternatives.” The paper was put together by the EPA, the USDA, the National Marine Fisheries Service (NMFS) and the U.S. Fish and Wildlife Service (USFWS).

What are the new changes?

The EPA will offer a new upfront “Focus” meeting at the beginning of each pesticide registration review for each active ingredient, as well as more opportunities for informal input from outside stakeholders in the consultation between the agencies. The “Focus” meeting will look at the current uses of the pesticide, product label clarity, and consider the potential for minimizing exposure and reducing risk early. The EPA will also initiate the ESA consultation process later on in the registration review process in hopes that more information will be available for ecological risk assessments and it will allow for more thorough dialogue with stakeholders.

Advice: Watch Closely as this New Process Develops

This is a complicated process already, with serious technical issues and the difficult political and public policy tradeoffs between the missions of the competing agencies involved. Those interested in the pesticide registration process should watch this closely as it’s about to become more complicated.