Registration of Pesticides with EPA under Federal Insecticide, Fungicide and Rodenticide Act [FIFRA]

  • Evaluate and confirm product exemptions from registration (including minimum risk pesticides (25(b))
  • Develop and review product labeling
  • Perform data development and oversight
  • Manage pre-application coordination with EPA
  • Prepare and oversee Applications for New Registration
  • Prepare applications to amend product registration with EPA under FIFRA using Amendment and Notification procedures
  • Prepare responses to Registration Review Interim and Final Decisions

Other Pesticide Regulatory Functions at EPA

  • Secure EPA company and producing establishment registration numbers
  • Manage annual pesticide-producing establishment production reporting
  • Assist in participation in joint industry data-development task forces
  • Manage adverse incident reporting under FIFRA 6(a)(2)
  • Manage importation of pesticides into and exportation of pesticides from the U.S.
  • Review claims on websites for FIFRA compliance

 FIFRA Scientific Data Compensation

  • Prepare analyses of data-citation obligations to individual data owners and Task Forces
  • Prepare estimates of data compensation costs
  • In conjunction with Putsavage PLLC, assist in data compensation negotiations and data compensation arbitrations before the American Arbitration Association

 Management of Pesticide Registration and Renewal with State Registration Agencies

  • Manage state registrations and renewals for pesticide products
  • Manage state registrations and renewals for 25(b) minimum risk products and pesticide devices

Enforcement Defense

  • In cooperation with Putsavage PLLC assist in the representation of pesticide registrants and other market participants in state and federal administrative enforcement actions
  • Manage implementation of post-settlement compliance actions, including pesticide registration and label audits

Entry into the U.S. Market 

  • Assist in entering the various U.S. pesticide markets, including crop protection, biocides, household, home, lawn, garden and bio-pesticides
  • Assist in the development of products and product lines, including registration timelines
  • Review potential scientific data compensation obligations

Cannabis Cultivation 

  • Assist licensed state medical and adult-use cannabis programs in developing Integrated Pest Management programs
  • Assist in securing appropriate approvals from state pesticide registration and cannabis regulatory agencies for the use of pesticides in cannabis cultivation