FIFRA, ESA, and Pesticide Consultation: Understanding and Addressing the Complexities

This paper explores the complexities and challenges that arise when trying to align the mandates of the Endangered Species Act (ESA) and the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA), particularly in the context of pesticide regulation and the conservation of endangered species. It examines the difficulties faced by the Environmental Protection Agency (EPA) in approving pesticides under FIFRA in compliance with the ESA and discusses the differing definitions and approaches to risk between the two regulatory frameworks. The paper aims to propose solutions for better integration of the two acts to improve their functionality and effectiveness in achieving their respective goals.

CAST Issue Paper 75 Task Force Members

Chairs

Bernalyn McGaughey, President and CEO, Compliance Services International, Lakewood, WA
Stanley Culpepper, Professor of Crop and Soil Sciences, University of Georgia, Athens, GA

Authors

Michael Aerts, Vice President, Science and Regulatory Affairs, Florida Fruit and Vegetable Association, Maitland, FL
Gary Bahr, Science Liaison, Washington State Department of Agriculture, Olympia, WA
Richard Brain, Environmental Toxicologist, Syngenta Crop Protection, Greensboro, NC
Leah Duzy, Agricultural Economist, Compliance Services International, Lakewood, WA
David Epstein, Retired, Northwest Horticultural Council, Yakima, WA
Valery Forbes, Dean, Charles E. Schmidt College of Science, Florida Atlantic University, Boca Raton, FL
Ashlea Frank, Principal Consultant, Compliance Services International, Lakewood, WA
Taylor Randell-Singleton, Associate Professor, University of Georgia, Athens, GA
Brigit Rollins, Staff Attorney, National Agricultural Law Center, Fayetteville, AR
Michael Willett, Director, Integrated Plant Health Strategies, LLC, Yakima, WA

Reviewers

Cameron Douglass, Agronomist/Weed Scientist, Office of Pest Management Policy, USDA, Washington, D.C.
Andrew Goetz, Manager, Regulatory Strategy and Stewardship, BASF, Cary, NC

CAST Liaison

Tony Burd, Senior Regulatory Stewardship Manager, Syngenta, Greensboro, NC

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