Background: The 2018 Farm Bill established the Interagency Working Group (IWG) for FIFRA and the Endangered Species Act (ESA). Since then, the American Mosquito Control Association (AMCA) has been working to address data gaps and concerns regarding pesticides used in public health programs. The USDA Office of Pest Management Policy (OPMP) was created in 1998 to coordinate USDA policy on pest management and pesticides. OPMP provides interagency coordination with EPA as well as with state regulators and industry stakeholders.
State agencies, often housed in State Departments of Agriculture, have been the primary leads since the 1970’s along with the U.S. EPA to administer FIFRA laws and support the development of scientifically-based pesticide labels that can be clearly read and safely administered by applicators. A handful of states allow county and municipal governments to impose additional pesticide regulations without the benefit of expert review.
Discussion: To carry out their review of pesticides, the EPA must use the best available data and develop appropriate methodology that reliably assesses the potential risk to the species. The USDA OPMP can assist by quantifying the benefits of public health pesticides, including the negative impacts of intense mosquito bites and arboviruses on livestock and other animals. AMCA, along with the pesticide policy coalition, supports efforts in the 2023 farm bill to provide USDA a greater role in all actions affecting the sale, distribution and use of pesticides; including actions taken under the Endangered Species Act.
In recent years we have seen actions from localities that directly and unjustifiably contradict EPA’s scientific findings on pesticide safety. These actions risk creating an unworkable, inconsistent patchwork of state or municipal labels and regulations that can quickly disrupt our ability to prevent VBD outbreaks by restricting access to these much-needed tools. Ensuring that pesticides are properly regulated is imperative for our health and safety. Since the 1970s, state lead agencies have worked with the EPA through cooperative agreements to administer and enforce FIFRA laws and support the development of science-based pesticide labels.
Support for state-level pesticide preemption language within the Farm Bill will ensure that those with expertise at State agencies and EPA can determine pesticide usage regulations and continue to provide consistent pesticide registration and oversight.
The American Mosquito Control Association (“AMCA”) strongly supports the “Reducing Regulatory Burdens Act of 2023” (HR 5089) and urges quick consideration in Congress. This legislation will eliminate costly, duplicative, and unnecessary Clean Water Act National Pollutant Discharge Elimination System (NPDES) permit requirements which impact our member's ability to adequately control mosquitoes.
NEEDED ACTION: Support language within the Farm Bill that would: reauthorize the Interagency Working Group on FIFRA/ESA; support an enhanced role for USDA’s Office of Pest Management Policy in federal pesticide regulation; provide pesticide preemption language preventing localities from regulating pesticides and maintain oversight by each state’s lead agency and the U.S. Environmental Protection Agency; and reduce regulatory burdens associated with pesticide applications that are duplicative of protections to water quality and aquatic organisms already regulated under FIFRA.