For FIFRA and ESA interactions, we entered 2022 with several major new actions. EPA announced a shift in FIFRA/ESA policy, and also posted their registration decision on Enlist herbicides. Two weeks later, FWS completed their first full pesticide consultation under the previous “interim process,” which reflected different policy and approach. Immediately thereafter, the NMFS BiOp on 3 organophosphates was released. These collectively reflect on old and new policies, and a new FIFRA/ESA approach to a registration. Each assessment can be valuable training for the next, but only when there is a stable platform to support them. What does this mean for the future? With the new 2022 policy, which will focus on all new active ingredients (and uses), registrants were advised by EPA of resultant registration delays of up to a year, potentially losing any efficiencies gained under the <i>old</i> process and questioning if we will have an efficient, predictable, reasonable, science-based process. Since not all chemistries are equal (there is a huge difference in types, purpose, and properties), companies will need to be prepared to reposition submissions and carefully support how they move through a new and untested process. Complexity does not end with agencies and registrant; perspectives from land managers, applicators, state enforcement agencies and others must be understood and incorporated into use and mitigation decisions. Currently, stakeholders have no example of consistency: EPA is implementing a new policy; BiOps issued under the former policy differ from one another on a species-specific basis. How do you determine when a generic mitigation vs species-specific mitigation should be developed? If a stakeholder or land manager applies it to land use and pest management, will that be durable? Will the new process lead to burdensome overprotection? How many different sizes of buffers can you have across different technologies, how are they established, and how do you ensure the latest application technology is being used? The new policy has potential to overlook important details and skip multiple decisions necessary to a well-functioning regulatory platform. How do we find balance? This presentation will explore these questions and consider potential consequences of regulatory and registrant pathways and their subsequent impact on necessary (versus excessive) species protection and the protection of the nation’s food, fiber, and public health resources.

Simplicity v. Complexity: Finding the balance between safe pesticide use and meaningful mitigation strategies

Fall 2022 abstracts, posters, and presentations will launch in mid-September.

ACS Fall 2022

The official archive and repository for all ACS Meetings & Expositions abstracts and select posters or presentations.