FIFRA, ESA and Pesticide Consultation: Identifying and Overcoming the Complexities from a Growers Perspective

For decades growers have been engaged in developing workable approaches to reducing impacts of pesticides on non-target species. These efforts not only yield positive benefits for the environment but often provide growers with substantial economic and ecological benefits that accrue from the conservation of beneficial species. Over the last several decades, the focus on pesticide use has shifted from optimizing on-farm pest management to the responsibilities and obligations created by label changes driven by the Endangered Species Act of 1973 (ESA) to pesticide actions under the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA).

Recently fulfilling understanding and meeting those obligations of the ESA has become more difficult as advocacy organizations began filing procedurally based lawsuits against the EPA for perceived violations of the ESA, resulting in court rulings intervening in the FIFRA process. Judicial rulings are especially challenging for the EPA in assessing the impacts of pesticide use on listed (threatened and endangered) species while meeting court-ordered deadlines in shortened timeframes and with declining staffing levels.

Why has consultation among federal agencies addressing the Endangered Species Act of 1973 (ESA) proven to be such a difficult task in assessing the risk of pesticide use and delivering regulatory actions that protect species in a practicable manner that allows farmers to provide food security for the nation?

Chairs

• Bernalyn McGaughey Compliance Services International Lakewood, WA
• Stanley Culpepper University of Georgia Athens, GA

Authors

• Michael Aerts Florida Fruit and Vegetable Association Maitland, FL
• David Epstein Northwest Horticultural Council Yakima, WA
• Michael Willett Integrated Plant Health Strategies, LLC Yakima, WA

Reviewers

• Cameron Douglass USDA Washington, D. C.
• Andrew Goetz BASF Cary, NC

CAST Liaison

• Tony Burd – Syngenta Greensboro, NC

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