FIFRA Compliance

Providing Expert Advice and Water Quality Impact Assessments for Agriculture & Turf

The pesticide law, FIFRA (Federal Insecticide, Fungicide, and Rodenticide Act) and its regulations, constitutes a mature but complex environmental statute. It is difficult to achieve the burden of proof that there will be "...a reasonable certainty that no harm to any population subgroup will result from exposure to [pesticide x]." This goal is dictated by the Food Quality Protection Act (FQPA) of 1996. This effort requires the use of appropriate, valid, and often cutting-edge risk assessment methods, often including computer simulations models. In addition, we assist pesticide registrants by conducting ground water and surface water quality impact studies and risk assessments. These field and modeling studies can support pesticide registration at the federal and state levels, as well as internal corporate decision-making. Finally, we conduct and support risk assessments for threatened and endangered species.

  • Sample Problems
    • Agriculture: Evaluation of water quality monitoring results from cotton areas of an herbicide with complex environmental chemistry. Used PRZM-EXAMS model system for an insecticide applied to sugarcane, and a molluscicide applied to citrus and tomatoes.

    • Industrial: Evaluation of potential water quality impacts of a once-through disinfectant proposed for Wastewater Treatment Plants (WWTP) using the CORMIX and EXAMS models.

    • Turf: Presentations in 2002 and 2007 at EPA's Office of Pesticide Programs Environmental Modeling Public Meeting providing guidance on modeling potential turf pesticide impacts on water quality. Integrated evaluation of ground water, surface water, fish, sediment, and atmospheric modeling and monitoring related to reregistration of a turf fungicide.

New White Paper on a Microbiocide Used in Hydraulic Fracturing

ETS recently wrote a white paper describing the environmental risks of the use of a microbiocide in hydraulic fracturing (“hydrofracking”). Hydrofracking is an old technology that is used in many different industries (e.g., water wells, oil and gas production, etc.). Its use has become more publicized recently due to concerns about vertical cross-contamination by methane and brines (e.g., Warner et al., 2012, PNAS). ETS’ white paper was submitted to the US EPA’s Office of Pesticide Programs, and it focused on the use of a naturally-occurring microbiocide. This substance would be used to control bacterial growth in several hydrofracking-related activities such as drilling, well completion, and gas production. Contact us for more information about this white paper.