FIFRA Regulations and Pesticide Registration Quiz

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Questions and Answers

What is one requirement for a pesticide product to be registered with the EPA?

It must demonstrate it performs its intended function without unreasonable adverse effects. (correct)

It must contain at least one active ingredient.

It must be significantly cheaper than competing products.

It must be approved by state regulations only.

Which of the following is NOT considered a pest under the definition provided?

Rodents

Irrigation systems (correct)

Insects

Weeds

Which substantial change occurred to FIFRA in 1972?

Banning of all chemical pesticides

Decentralization of pesticide registration processes to local authorities.

Overhaul of the Federal Environmental Pesticide Control Act (FEPCA) (correct)

Introduction of organic pesticides

What does Section 6(a)(2) of FIFRA require regarding adverse effects reporting?

Registrants must submit additional information about adverse effects as soon as it becomes available. Signup and view all the answers

Which of the following substances is classified as a pesticide?

Antimicrobial soap Signup and view all the answers

What does FIFRA require for pesticides distributed in interstate commerce?

Registration with the USDA Signup and view all the answers

Which of the following is considered misbranding under FIFRA?

The label contains false statements Signup and view all the answers

What does adulteration refer to in the context of FIFRA?

The pesticide contains an incorrect amount of active ingredient Signup and view all the answers

Which statement about the registration process under FIFRA is accurate?

Legal action is the only recourse for misbranding Signup and view all the answers

What was the notable consequence of DDT use by 1963?

A decline in bird populations across the country Signup and view all the answers

What must facilities do if they manufacture or use certain pesticides above threshold amounts?

Prepare a Toxic Release Inventory (TRI) report annually Signup and view all the answers

Which of the following is NOT a characteristic of public health antimicrobial pesticide products?

Focus on economic or aesthetic significance organisms Signup and view all the answers

What is the minimum efficacy required, as represented by a log reduction, for antimicrobial activity according to the EPA?

3-log10 reduction (≥99.9%) Signup and view all the answers

Which statement accurately describes the primary role of cleaning products compared to antimicrobial products?

Cleaning products do not have pesticidal claims and remove visible material. Signup and view all the answers

Which of the following must be verified by the EPA before a product can make efficacy claims on its label?

The intended microbial agent or group and application methodology Signup and view all the answers

Study Notes

FIFRA (Federal Insecticide, Fungicide, Rodenticide Act)

FIFRA enacted in 1947
Pesticides distributed interstate must register with USDA
Some initial labeling requirements were introduced
No real regulatory teeth; couldn't stop registration of dangerous chemicals
Lack of control over off-label use
Legal action only recourse for misbranding/adulteration

FIFRA Misbranding

False or misleading statements on the label
Missing establishment or product registration numbers
Missing required words, statements, or information
Inadequate directions for protecting health/environment
Missing warning/caution statements, or use classifications

FIFRA Adulteration

https://www.law.cornell.edu/uscode/text/7/136
Pesticide's strength/purity differs from label claims
Any substance substituted in whole/part for the pesticide
Missing valuable constituents

DDT

Used against polio
https://www.youtube.com/watch?v=yagO9jn_gMWk
Rise and fall of DDT: https://www.youtube.com/watch?v=MMSEnIVFBQ0
DDT and bald eagles impacts https://www.youtube.com/shorts/1HPWFhvynBQ
Bald eagle nesting pairs in Lower 48 states – all-time low of 417 nests in 1963, 71,400 in 2020 (Source: U.S. Fish and Wildlife Service)

FIFRA under EPA

1970: Nixon moved USDA pesticides division to EPA
1972 Federal Environmental Pesticide Control Act (FEPCA) overhauled FIFRA
DDT banned in 1972

Pesticide Registration

Pesticide – substance to prevent, destroy, repel, or mitigate pest
Exceptions: firearms, flyswatters, mousetraps
Pests: insects, rodents, worms, fungi, weeds, plants, viruses, bacteria, microorganisms, and other animal life
Examples: fungicides, herbicides, insecticides, insect repellent, weed killer, disinfectants, swimming pool chemicals, antimicrobial soap.
All pesticide products used in the US must register with EPA
Separate registration for different doses/concentrations, crops, insects, etc.
Must demonstrate product warrants the proposed claim
Performs intended function without unreasonable adverse effects
Proposed labeling complies with requirements

Adverse Effects Reporting

Section 6(a)(2) of FIFRA: registrants must report additional factual information about unreasonable adverse environment effects
Similar to reporting under Section 8(c) of the Toxic Substances Control Act (TSCA)
Manufacturers/processors of chemical substances/mixtures must keep records of significant adverse reactions

Pesticides and EPCRA

Some pesticides (aldrin, toxaphene) listed as toxic chemicals under Section 313 of EPCRA (part of TCLP tests)
Covered facilities manufacturing/processing/using these materials above threshold must prepare a Toxic Release Inventory (TRI) report annually (under EPCRA)

Antimicrobial Pesticides

FIFRA defines antimicrobial pesticide as a pesticide intended to disinfect, sanitize, reduce, or mitigate growth/development of microorganisms; protect inanimate objects; industrial processes/systems; surfaces; water; or chemical substances from contamination/fouling/deterioration caused by bacteria, viruses, fungi, protozoa, algae, or slime
EPA: an "agent that kills microbial growth"

Public Health Antimicrobial Pesticide Products

Products that claim to control microorganisms threatening human health
Control of specific pathogens/infectious organisms
Microbial sterilants, disinfectants, virucides, sanitizers, tuberculocidals for infectious/pathogenic microorganisms
Fungicides for use against infectious/pathogenic fungi
Antimicrobial water/microbial purification systems

Non-Public Health Antimicrobial Pesticide Products

Target organisms not normally causing infection/disease
Label claim for economically/aesthetically significant microorganisms
Examples: algeaecides, slimicides, preservatives

Cleaning Products vs Antimicrobial Products

Cleaning removes visible organic/inorganic materials (water, mechanical action, detergents, enzymes)
Cleaning products don't claim to be pesticides; merely clean or remove material from surfaces/water/air

Label Claims and Specific Use Conditions

EPA requires sufficient data in application paperwork to verify label claims: whether antimicrobial is one agent or a group, appropriate application methods
Labeling prohibits special use claims without efficacy data for the specific use
Claims must include efficacy against designated test strains using EPA methodologies
Efficacy is 3-log10 reduction over a certain contact time period

Disinfectants and Contact Time

https://www.uvm.edu/safety/commonly-used-disinfectants-chart

OSHA vs FIFRA for Labeling

1910.1200: OSHA doesn't require labeling for certain chemicals subject to TSC Act or to labeling requirements of other federal acts (Food, Drug, and Cosmetic Act (FDA); Federal Alcohol Administration Act; CPSC)
FIFRA labeling can differ from OSHA labeling, and thus potentially mislead workers

FIFRA Labeling vs OSHA Labeling

EPA does not adopt Globally Harmonized System (GHS) classification and labeling for pesticides
EPA uses caution along with danger/warning words in signaling; OSHA only uses danger/warning
EPA use skull and crossbones and flame pictograms; OSHA uses health hazard pictogram

Pesticide Disposal

Pesticide products listed in 40 CFR 261.31 or 261.33 or exhibiting hazardous waste characteristics become hazardous wastes when discarded
https://web.archive.org/web/20130606152552/https://psep.cce.cornell.edu/facts-slides-self/facts/pesthazard.aspx
Rinsate should be disposed/reused at application site
Commercial pesticide product containers can be reused. Some states have programs for this

Food Quality Protection Act (FQPA)

1996; replaced Delaney Clause
Pesticide residue on food unsafe unless EPA sets a tolerance level and the residue is below that level.
Tolerance established based on risk assessment.
https://www.epa.gov/laws-regulations/summary-food-quality-protection-act
https://www.epa.gov/pesticide-science-and-assessing-pesticide-risks/assessing-human-health-risk-pesticides
https://www.ecfr.gov/current/title-40/chapter-I/subchapter-E/part-180 (180.103)

Factors for Tolerance Establishment

Aggregate non-occupational exposure from pesticide (diet, home use, drinking water)
Cumulative effects in human body
Increased susceptibility in infants, children, and other sensitive subpopulations
Effects similar to naturally-occurring estrogens/other endocrine disruption effects

Pesticides and the Clean Water Act

Section 301: pesticide manufacturers/formulators must get discharge permits if they release effluent into any body of water
Runoff from agricultural application is considered a nonpoint pollution source.

Integrated Pest Management

Limits pesticide use to only needed applications
Encourages use of biopesticides like Bacillus thuringiensis

Homework 7

Pesticide Labels: OSHA Outlines Differences between FIFRA and HazCom
https://ehsdailyadvisor.blr.com/2019/02/pesticide-labels-osha-outlines-differences-between-fifra-and-hazcom/
EPA: https://www.epa.gov/sites/production/files/2014-04/documents/pr2012-1.pdf

Pesticide Applicators

Restricted Use Pesticides: too hazardous for general use but could be used safely by trained personnel under the direct supervision of a certified applicator
Applicators require specific training and testing
State-level requirements vary

Agricultural Workers

40 CFR Part 170 Worker Protection Standard (not OSHA): Pesticide safety training; notification of pesticide applications; PPE use; restricted entry intervals following pesticide applications; decontamination supplies; emergency medical assistance.

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Description

Test your knowledge on the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA). This quiz covers essential aspects such as registration requirements, definitions, and significant changes to pesticide regulations. Learn about the implications of pesticide use and what constitutes misbranding and adulteration.