The Center for Biological Diversity (“CBD”) submitted a July 28th petition to the United States Environmental Protection Agency (“EPA”) requesting that the agency’s regulations be revised to:

. . .restore the requirement that all applicants of the registrants provide data on the potential synergistic effects of pesticides during the registration process and provide a clear, science-based definition of ‘synergistic effects’ to comply with its duties under the Federal Insecticide, Fungicide, and Rodenticide Act (“FIFRA”).

The petition was submitted pursuant to the Administrative Procedures Act.

The CBD alleges that EPA’s regulations have since 1984 expressly provided that the agency could request additional data and testing from a pesticide applicant or registrant regarding the potential synergistic effects of a pesticide active ingredient if other active ingredients, inert ingredients or any additional substance that could act as a synergistic. The organization states that in 2007 EPA revised its regulations and deleted § 158.75(b) with a cursory explanation (i.e., paragraph (b) deleted as “unnecessary”.)

CBD argues that EPA’s actions were a mistake. It contends that without expressly requiring applicants to provide information on synergy it is highly likely that EPA is underestimating the negative impact on the environment of pesticide exposure in its analyses.

The petition requests that EPA restore the strength of the regulatory requirements. It argues that such efforts would provide the agency with information necessary for it to comply with its duty under FIFRA and ensure that its registration of pesticides would not result in unreasonable adverse effects on the environment.

A copy of the petition can be downloaded here.