23 - Pesticide Mitigations to Address Endangered Species Concerns

Abstract: The registration and continued use of pesticides under the Federal Insecticide, Rodenticide, and Fungicide Act (FIFRA) is complicated by the requirement for US EPA’s approved actions (i.e., registering a pesticide label) to comply with the Endangered Species Act (ESA). In 2022, EPA released a work plan and announced two pilots that explore processes and mitigations to help ensure the protection of endangered species from the use of pesticides. Examples of pesticide mitigations that are intended to reduce exposure to endangered species include general label statements, off-set requirements, application directions, wind and temperature advisories, environmental hazard statements, and geographic specific mitigations. When geographic specific mitigations are included on a pesticide label, they are commonly intended to address a species-specific concern and are accompanied by a spatial delineation identifying where mitigation is needed, also called a Pesticide Use Limitation Area (PULA). Using examples from recent registrations and actions, this presentation will discuss mosquitocide mitigations for ESA spanning from general label statements to specific mitigations, describe the PULA development process, and discuss ways to meet implementation challenges.