What EPA’s registration reviews mean to PMPs

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December 13, 2021

Greg Baumann

Greg Baumann, a PMP Hall of Famer (Class of 2013), is Global VP of regulatory and technical services for Nisus Corp.

By federal law, pesticides must be reviewed by the U.S. Environmental Protection Agency (EPA) every 15 years. This is a long process, governed by many pages of regulations and procedures.

This ongoing program began before 2010 for all eligible active ingredients (AIs) that made the “cut” of the previous reviews via Reregistration Eligibility Decisions, or REDs.

First, the EPA determines a review strategy for each AI category. It issues a data call-in for what its team views as gaps in the database, or “data gaps.” Sometimes, these data needs weren’t even on the radar years ago, such as effects on pollinators.

When a data call-in is issued, registrants (manufacturers) must decide whether the cost of generating scrutinized third-party credible data is worth the return on investment. Rather than each registrant generating its own data, some registrants might form task forces to share the cost, which can be millions of dollars. In certain cases, the cost isn’t worth it, and registrants cancel registrations. The industry loses that product forever.

The new-data generation process can take years. The studies are then reviewed by the EPA, which can take a year or more. Its teams use the study data to assess risks considering human health, as well as residential and occupational exposure.

Concurrently, the EPA conducts an environmental risk assessment that includes the effects on aquatic organisms, such those found in surface water; terrestrial use effects on birds, mammals and pollinators; and leaching of the product into the soil.

Finally, the EPA releases the long-awaited Draft Risk Assessment and receives public comments. Up to a year later, the EPA issues a response to each comment.

After that, a Proposed Interim Decision is issued — which might require canceling certain uses for the AI due to a lack of data, poor results, or registrant request. A canceled use might be broad and beyond the scope of our industry’s concern (such as canceling uses for a forest pest), or it can affect our industry directly because of inadequate data to support something like bed bugs, for example.

A comment period follows, and after months or years, a Registration Review Interim Decision is issued. This is, for all practical purposes, a near-final decision. Future evaluations will be conducted through the Endocrine Disruptor Screening Program and to comply with the Endangered Species Act, but those won’t likely occur for years.

All told, today’s registration review process typically takes at least 10 years. And it almost always results in mandatory label changes.

This process scrutinizes many of the products pest management professionals use regularly. It uses a meticulous, scientific approach to ensure these products are thoroughly reviewed for safety. Having the process in place means the products we use have the registrants’ full commitment to use the best science available.


WDI guru receives career honors

PHOTO: CPCA

From left are Emilio Polce, Joe Giaimo, Jeff Millette and Sheila Haddad during the CPCA Fall Conference. PHOTO: CPCA

It is important to recognize those who have bettered our industry through their efforts. For example, during its fall conference, the Connecticut Pest Control Association (CPCA) presented the 2021 Lifetime Achievement Award to wood-destroying insect (WDI) pest management guru Joe Giaimo. The president of Crest Termite Control in East Haven, Conn., has been a mentor to pest management professionals (PMPs) nationwide for more than 30 years, addressing challenging WDI inspection and control issues. He has spent years contributing to educational programs nationally, enthusiastically serving on public policy committees to nudge lenders on inspection issues, and giving one-on-one advice to new business owners.

Giaimo is a passionate industry advocate, and is one of the original work group members who helped the National Pest Management Association (NPMA) develop the original NPCA-1 form — now the NPMA-33 form — that is used for real estate inspections in most states.

Congratulations, Joe, from a grateful industry! — G.B.

About the Author

Greg Baumann is Vice President, Technical Services & Regulatory Affairs for Nisus Corp.

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