Pesticides And Toxic Substances (H-7508W) 21T-1004 March 1991 Pesticide Reregistration \ ------- Contents 1 Introduction 2 The Registration Standards Program 3 Accelerated Reregistration 6 What Does Reregistration Mean? 7 The List A Pesticides 9 The List B, C And D Pesticides 10 Overall Status of List A, B, C And D Pesticides 11 Fees 12 Minor Uses And Reregistration 13 Conclusion 13 References yv Printed on Recycled Paper ------- Introduction The Environmental Protection Agency (EPA) is required by law to reregister existing pesticides that were originally registered years ago when the standards for government approval and the test data requirements were less stringent than they are today. This comprehensive reevaluation of pesticide safety in light of modern standards is critical to protecting human health and the environment, and to maintaining public confidence in our food supply. Initially, approximately 600 groups of related pesticide active ingredients, or active ingredient "cases," required reevaluation. These 600 cases involved about 45,000 formulated products. Reregistration of these chemicals proved to be a massive, complicated undertaking that has proceeded slowly. In 1988, the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA) was amended to strengthen EPA's pesticide regulatory authority and responsibilities regarding the reregistration of pesticides. These amendments mandated an accelerated reregistration scheme, to be carried out in five phases concluding in the late 1990s. The new law, known as FIFRA '88, imposes explicit duties and strict deadlines on EPA and pesticide producers or "registrants." The thrust of the phased approach is to generate a substantially complete scientific data base for each pesticide product before it is evaluated by the Agency and reregistered. The amendments also require, for the first time, that registrants bear a significant portion of the cost of reregistration by paying reregistration fees. The cost of accelerated reregistration is now estimated to be over $400 million. These and the other provisions of FIFRA '88 are described in detail in EPA's plan for implementing the amendments, which was published in the Federal Register on April 26,1989. The pesticide reregistration program mandated by FIFRA '88 has made tangible progress. This document provides a general overview of the provisions, process and status of the reregistration program. A more detailed summary of EPA's progress in implementing the reregistration provisions of FIFRA '88 will be captured and updated quarterly in the Agency's "Reregistration Progress Report," beginning in 1991. To obtain a sample copy or receive this report regularly, please contact the Special Review and Reregistration Division (H-7508W), Office of Pesticide Programs, U.S. EPA, Washington, D.C. 20460; telephone number 703-308-8000; fax number 703-308-8005. ------- The Registration Standards Program EPA began a systematic reevaluation of existing pesticides in 1980 through a process called the Registration Standards program. A Registration Standard summarized the Agency's evaluation of the available data on an existing chemical, identified and required submission of additional data, and set forth other conditions a registrant had to meet in order for EPA to reregister pesticide products containing the active ingredient. These other conditions typically included modifications to registrations, labeling, and tolerances (food residue limits), as necessary. In some cases, Registration Standard review also resulted in restricting the use of a pesticide to certified applicators, or beginning an in-depth Special Review to deal with any unreasonable risks. Pesticides that did not comply with a Standard's requirements were subject to suspension or cancellation action. When EPA established the Registration Standards program, it set priorities for conducting reviews giving priority to chemicals with the highest potential for exposure-high-volume and food-use chemicals. By December 1988, EPA had issued 194 Registration Standards, roughly 25 per year. Because chemically-related active ingredients had been grouped into Registration Standard "cases," these 194 Standards actually represent 350 individual active ingredients. The 194 Standards issued accounted for 85 to 90 percent of the total volume of conventional pesticides used in the United States. Once EPA received the data required by a Registration Standard, the Agency thoroughly reviewed those data and the pesticide's uses, and decided whether to modify the conditions of registration, require additional data or take other regulatory action. This review of data was called a second round review. The Registration Standards for most of the chemicals considered to be ready for second round review were issued in the early 1980s. Since that time, EPA's data requirements for registration and testing guidelines have been revised and expanded. Consequently, as EPA completed these second round reviews, it levied yet additional data requirements, thus further postponing reregistration decisions. ------- Accelerated Reregistration By the late 1980s, it became increasingly apparent that under the Registration Standards program, EPA would not be able to complete the reregistration of existing pesticides as quickly as Congress originally envisioned. At the pace of issuing 25 Registration Standards per year, reregistration could not have been completed until well beyond the year 2000. Growing public concern about how long it would take to reassess existing pesticides, particularly those used to produce our food supply, spurred Congress to act in 1988 to substantially change EPA's approach. The FIFRA '88 amendments were signed into law by the President on October 25,1988, and became effective on December 24,1988. The reregistration provisions of FIFRA '88 establish mandatory timeframes and duties for reregistration of pesticides. The law now requires EPA to complete, over Figure 1. Pesticide Reregistration Process PHASE 1 PHASE 2 PHASE 3 PHASE 4 EPA REGBTRANT REGISTRANT EPA PHASES EPA Publish lists Of Pesticides Respond •J—a-ftit. luenoty M«*mg Stud** Agree To DoStudies Pay Fee And Reformat »»,.'«» tm - CXISQnK Stadia* Certify Access To Raw Data "Hag- Advene *•**! HMOS Pay Fee Review Phase2&3 Submissions Identify Any Other Needed Studies PubHsh Lists Of Missing Studies Require Muring Studies After AD Studies b. Review to lYear Specific Studies DueSMos. Later Review Product Specific Studies In 3 Months EPA Guidelines 12/24/W approximately a 9-year period, the reregistration review of each registered product containing any active ingredient registered before November 1, 1984. The assumption by Congress was that since EPA's most recent data requirements for registration were published in November 1984, most pesticides registered after then would have up-to-date data bases. Congress directed EPA to carry out reregistration in five phases (see Figure 1). The five phases, and what EPA has done to implement each of them to date, are described below. Phase 1: Listing of Active Ingredients Phase 1 required EPA to publish lists of pesticide active ingredients subject to reregistration and to ask registrants of pesticide products containing those ingredients whether they intended to seek reregistration. These lists had to be published within 10 months after the effective date of the amendments. EPA completed this phase of accelerated reregistration by publishing four lists of pesticides subject to reregistration. List A, by law, contains the 194 pesticide active ingredient cases (350 individual active ingredients) for which Registration Standards were issued prior to December 24,1988.1 Lists B, C and D were developed by applying the following criteria (focusing on chemicals with the highest potential for exposure): use on food or feed, whether there are residues of concern in drinking V It should be noted that the chemicals contained on List A are not-subject to the phased submission provisions of the FIFRA '88 accelerated reregistration scheme (phases 2, 3 and 4), although the List" A chemicals are subject to the fee provisions. Congress did not set a phased data submission schedule for List A chemicals because a large part of the work required of registrants for reregistration under FIFRA '88 had already been done in the Registration Standards program. Instead, EPA conducted an inventory of active ingredients on List A to determine whether the data submitted in response to Registration Standard review were sufficient to conduct a thorough evaluation and make a reregistration decision, or whether additional data are needed. The List A Inventory and its results are discussed in more detail later in this document. ------- water, edible fish or shellfish; significant outstanding data requirements prior to December 24,1988; and worker exposure. The Agency identified additional listing criteria including: Special Review status; restricted use pesticides; effects on non- target or endangered species; and dioxin/furan contamination problems. Thus, pesticides on List B are those with the highest potential exposure and List D the least. Lists B, C and D are discussed further on page 9. Table 1 Lists of Pesticides Subject to Reregistration List A B C D Date Published 2/22/89 5/25/89 7/24/89 10/24/89 # Active Ingredients 350 229 288 286 # Cases 194 149 150 118 TOTAL 1,153 611 Phase 2: Declaration of Intent and Identification of Studies Phase 2 required registrants to declare (within 3 months after publication of each chemical list) whether they intended to seek reregistration of their products. If so, they had to notify EPA, identify applicable data requirements and missing studies, commit to submitting new studies or replacing inadequate existing data, and pay the first installment of the reregistration fee. If a registrant did not seek reregistration, EPA cancelled the appropriate product registrations. EPA was required by FIFRA '88 to issue guidelines to assist registrants during Phase 3 in summarizing and reformatting studies, in identifying studies which may be inadequate but still may be considered, and in "flagging" adverse effects data. The Agency issued these guidelines on December 24,1989. In addition, EPA issued detailed guidance to registrants for preparing their Phase 2 responses, and sent individual responses to registrants who supported their registrations during Phase 2 in order to improve their Phase 3 submissions. EPA and the industry completed Phase 2 activities for Lists B, C and D pesticides during 1990. Many pesticides were not supported by their registrants during this Phase, and so were cancelled. Phase 3: Summarization of Studies Phase 3 added to the responsibilities of registrants who decided to support their products for reregistration during Phase 2. During the nine months after the Phase 2 deadlines, registrants were required to resubmit existing studies that had been reformatted and summarized according to Agency guidance, to certify the availability of raw data, to "flag" studies that indicate adverse effects, to make additional commitments to satisfy all applicable data requirements, and to pay the final installment of the reregistration fee. Registrants who failed to comply were subject to cancellation action. Phase 3 activities were completed in October 1990. Phase 4: EPA Review and Data Call-in's During Phase 4, EPA must review all Phase 2 and 3 submissions and determine independently whether all applicable data requirements have actually been satisfied, and if not, require registrants to fill any unfulfilled data requirements. This activity is taking place for the List B, C and D pesticides during the time period from late 1990 through July 1992. When a registrant commits to submit new studies in Phase 2 or 3, or when EPA requires new studies during its Phase 4 review, those studies must be submitted according to schedules established by EPA, but no later than four years after the date of a registrant's commitment. Time extensions may be granted only if there are "extraordinary circumstances" beyond the registrant's control. ------- Phase 5: Reregistration Decisions In Phase 5, EPA must conduct a comprehensive review of all the studies submitted in support of an active ingredient, decide whether pesticide products containing the active ingredient are eligible for reregistration (and if so, under what conditions), decide whether product-specific studies are needed (and if so, obtain and review these studies), and reregister products or take other appropriate regulatory action. Figure 2 shows the steps and time periods involved in the Phase 5 process. Figure 2 Phases 2,3, & 4 n Phase 5 n^md^^i- . Registrant Submit studies on ktive ingredients ' ' " , Review Phase 2 & 3 'I f ' ' ' submissions, identify missing * * studies, and require , '" submission of studies to fill the remaining requirements Provide product-specific " studies ~ ,j -*.* '.suV^1" w I * »^,? -^ *\ \7 Determine rer oŁ 4 Review? studies^ Reregis- tration ------- What Does Reregistration Mean? Criteria for Reregistration Eligibility Before a pesticide product may be reregistered, its active ingredient(s) must be declared "eligible" for reregistration. EPA has proposed two broad criteria for determining such eligibility: (1) The pesticide's data base is substantially complete; and (2) The pesticide does not cause unreasonable adverse effects to people or the environment when it is used according to the product label directions and restrictions. The first criterion ensures that EPA has sufficient information with which to conduct a risk assessment. The second implies that the Agency has thoroughly reviewed the available information, has found that no further, in-depth review or regulatory action is needed, and believes that present uses of the pesticide do not pose an unreasonable risk to people or the environment when the pesticide is used in accordance with its approved labeling. EPA also is in the process of reassessing pesticide tolerances (the maximum amounts of pesticide residues that lawfully may remain in food or animal feed), and will be making any necessary changes in existing tolerances at the eligibility stage of the reregistration process. Changes in a pesticide's tolerances may reduce human exposure to the chemical, so this measure may be used to eliminate any unreasonable risks. Further, EPA is committed to improving consistency between U.S. tolerances and international tolerances established by the CODEX Alimentarius Commission. The Agency's determination of reregistration eligibility, therefore, may include changes in the pesticide's established U.S. tolerances, either to reduce risks or to achieve harmonization with international standards. When EPA determines that an active ingredient is eligible for reregistration, the Agency issues a Reregistration Eligibility Document (RED), summarizing the studies reviewed and the findings reached. Through the RED, EPA requests any needed generic data, product-specific studies and revised labeling. Once such data and labeling are received and accepted, and when all their uses are eligible, individual pesticide products are reregistered. Products with more than one active ingredient may be reregistered only after REDs have been issued for all of their active ingredients. Moreover, products containing certain ("List 1") toxic inert ingredients will not be reregistered until the inert is removed or EPA receives data indicating that the inert will not cause unreasonable risks. Once a pesticide product is reregistered, it is not regarded as permanently acceptable. EPA does not intend reregistration to eliminate the need for continual reassessment of pesticides; reregistration is only a milestone in a continuing review process. Reregistered pesticides will be reassessed as new data are received or new concerns are identified. New information received by the Agency may trigger a Special Review or cancellation action, at any time. ------- The List A Pesticides What they Are The pesticides on List A are those 194 active ingredient cases, or those 350 individual active ingredients, for which EPA had issued Registration Standards prior to December 24, 1988, the effective date of the FIFRA '88 amendments. Because of the way in which EPA prioritized pesticides for review under the Registration Standards program, the List A pesticides are primarily food use chemicals, and they represent approximately 85-90 percent of the total volume of conventional pesticides currently used in the United States. Because the List A pesticides are those to which people and the environment are most exposed, they are EPA's highest priority for reregistration review. The list A Inventory During 1989, the Agency developed an inventory of all the active ingredient cases in List A, to determine whether the data submitted during Registration Standard and second round reviews were sufficient to conduct a thorough evaluation and make a reregistration decision about each case, or whether further data were needed. The objective of this project was to identify action needed to expedite the reregistration of each List A chemical case. The List A inventory, issued in March 1990, showed that 11 of the 194 pesticide active ingredient cases on List A were ready for a reregistration decision. At the other end of the spectrum, 28 cases were no longer being supported for reregistration. The remaining 155 cases were in various stages of the data call-in (DCI) and review process. The List A review process and the results of the inventory project were discussed in EPA's March 1990 "Reregistration Plan for Chemicals on List A." Figure 3 Reregistration Process, List A Chemicals Pre-FIFRA '88 FIFRA '88 Reregistration Decision on A.I. and Issue RED Document Product Reregistration Follow-up to Registration Standard *~ Inventory Reregistration Review Special Review Cancellation ------- The Review Process and General Status In framing the accelerated reregistration scheme of FIFRA '88, Congress recognized that pesticide registrants had already developed a significant amount of new data in support of those pesticides for which Registration Standards had been issued. Therefore, FIFRA '88 specified that the List A pesticides move from Phase 1 of the process directly to Phase 5. That is, unlike pesticides on Lists B, C and D, they are not subject to the data submission provisions of Phases 2, 3 and 4, but may be considered for reregistration based on relevant studies that have already been submitted or are scheduled to be submitted to EPA. The reregistration review process for pesticides on List A is illustrated in Figure 3 on page 7. Once EPA is satisfied that appropriate data requirements have been levied for a pesticide active ingredient case, and has received valid studies to fulfill those data requirements, the Agency places the pesticide into the queue of cases awaiting reregistration review. As noted above, 11 pesticides were fully ready for reregistration review when EPA's inventory of List A pesticides was completed in early 1990. Drawing from those 11 pesticide cases, the Agency issued the first two Reregistration Eligibility Documents (REDs) by the end of 1990; several others will follow in 1991. In the interest of conducting a truly accelerated program and completing the reregistration of all relevant pesticides in a timely way, EPA is issuing the REDs as final documents while simultaneously circulating them for public comment. The Agency is proceeding this way based on its experience in issuing Registration Standards. Although EPA published those documents in draft for public comment, responses usually were limited to inquiries from registrants about data requirements. The Agency believes that registrants will have ample opportunity to raise issues with EPA about the REDs. In addition, a public docket will be opened for each pesticide long before its RED is issued, providing interested members of the public sufficient opportunity to follow the progress of each pesticide's reregistration review. EPA will carefully consider public comments received on the REDs, and will amend the documents as necessary based on those comments. During 1991, EPA's focus for the List A pesticides is to continue the ongoing reregistration reviews. The Agency also is calling in any additional studies needed, and continuing the evaluation of studies already received for the remaining List A pesticides (those that have not dropped out of the process) so that more will become ready for reregistration review. ------- The List B, C And D Pesticides What they Are As directed by Congress through the FIFRA '88 amendments, besides List A, EPA constructed three additional lists (B, C and D) of pesticide active ingredients that were contained in products first registered before November 1,1984, and for which Registration Standards had not been issued. In developing these three lists, EPA was directed by Congress to prioritize chemically-related active ingredient cases, giving precedence to chemicals with the greatest exposure potential. While List A contains most of the major agricultural pesticides used in the U.S. today, Lists B, C and D each contain a mix of many types of pesticides (insecticides, fungicides, herbicides, disinfectants, wood preservatives, etc.) used in a variety of settings (agricultural, industrial, residential, etc.). Each list consists of pesticides with less potential for human exposure than those on the preceding list. Most of the registered microbial and biochemical pesticides are included on List D. Table 1 on page 4 shows the number of pesticide cases and active ingredients that were placed on each list, and the date that each list was published in the Federal Register. List B, C and D Review Process and Schedule Pesticides on Lists B, C and D are being reviewed through the full five-phase process described earlier in this document. The schedule set forth by Congress for completing each phase, by list, appears in Table 2. Activities for Phases 2 and 3 are completed. Because of the size, complexity and newness of the tasks at hand, EPA was unable to complete Phase 4 activities for the List B pesticides on schedule. Following a revised schedule issued in January 1991, the Agency will complete its Phase 4 List B review in June 1991. This is likely to cause a delay in completion of Phase 4 for List C pesticides. By the end of Phase 4, EPA will know how many additional studies the pesticide industry must generate and submit during the next four years. This will provide a good estimate of how many studies EPA will have to review for Lists B, C and D during Phase 5. Meanwhile, however, EPA will begin Phase 5 for some List B, C and D chemicals, where data bases are essentially complete. General Status of list B, C and D Pesticides Since Lists B, C and D were published, many of the chemicals have not been supported for reregistration. Between early 1989 and March 1991, the total number of List B, C and D active ingredients to be reregistered decreased by more than one half. In terms of chemical cases, the decline also was dramatic. At the end of Phase 4, (as the Agency did at the end of Phases 2 and 3), EPA will give public notice regarding the unsupported uses to see if anyone wants to support them. Table 2 Statutory Schedule for Reviewing Lists B, C & D Phase 2 Phase 3 Phase 4 ListB IJstC ListD 8/24/89 10/24/89 1/24/90 5/24/90 7/24/90 10/24/90 10/24/90 7/24/91 7/24/92 ------- Overall Status Of List A, B, C And D Pesticides • I 'he overall trend for all four lists is a •*• substantial reduction in the number of pesticides being supported for reregistration. As Table 3 below shows, since EPA began implementing the accelerated reregistration program under FIFRA '88, the number of active ingredients supported has decreased by nearly one half, and the number of active ingredient cases has decreased by almost one third. EPA generally views this decline in pesticide active ingredients and cases as a positive result of the reregistration process. In many instances, the pesticides that dropped out were ones that had not been produced or marketed in the United States for many years, but were still registered and carried in EPA's records. However, this massive decline in pesticide registrations could have a negative impact on some growers and other pesticide users who depend on certain so-called "minor uses," as described later in this document. Table 3 List A, B, C and D Pesticides Supported Over Time Supported in Dec. 1988 Supported In March 1991 AI's Cases AI's Cases List A ListB ListC ListD TOTAL 350 229 288 286 194 149 150 118 1,153 611 293 141 124 113 671 159 109 83 66 417 These numbers will change frequently as the cancellation process required by FIFRA is implemented. 10 ------- Fees FIFRA '88 provided EPA new resources to conduct the reregistration program in the form of fees payable by pesticide registrants. To help support the cost of accelerated reregistration and other provisions of the new law, FIFRA '88 established two types of fees: a one-time reregistration fee for each active ingredient, and an annual registration maintenance fee to be paid for each registered product. Reregistration Fees For each active ingredient used on major food or animal feed crops, registrants were required to pay a one-time reregistration fee totalling $150,000. In most cases, an initial payment of $50,000 was due during Phase 2, and the balance in Phase 3. For pesticide active ingredients not intended for major food or feed uses, registrants had to pay a fee of not more than $150,000 and not less than $50,000. The exact fee depended on, among other things, whether a Registration Standard had been issued for the pesticide and the extent of data required for reregistration. These active ingredient fees were apportioned among the registrants of each active ingredient, based on their market shares. Reregistration fee reductions or waivers were granted for certain pesticide registrants—for example, those with low production or minor use products. For small businesses, the reregistration fee was based on a graduated rate. EPA initially assumed that reregistration fees would provide $34 million to support the program. By early 1991, the Agency had received only $27.5 million in reregistration fees, and adjusted its expectations. EPA now anticipates that final receipts will total no more than $30 million. Maintenance Fees Unlike the one-time reregistration fee, which is levied on the basis of active ingredients, the annual maintenance fee is assessed for each individual pesticide product. In 1989, for up to 200 products per company, the fee was $425 per product for the first 50 products and $100 per product for the rest. In 1990, the fee was raised to a flat $1,300 per product, with a fifty percent reduction applied to the first product only. In both years, there was a maximum limit or cap on the total annual maintenance fee payable by any registrant: registrants with up to 50 registrations could be charged no more than $20,000, and those with more than 50 registrations could be charged no more than $35,000 each. The objective of the maintenance fee program is to generate approximately $14 million annually for the Agency's revolving fund, which is used to support the reregistration program. However, due to the caps involved, the total amount of funds generated in 1990 was only $11.5 million, far below the amount that is needed. Due to this shortfall, EPA has proposed eliminating the statutory fee caps to raise the $14 million that is needed annually. The Agency also is considering additional options to adequately fund the program. Imposing the maintenance fee provisions of FIFRA '88 had a massive "house- cleaning" effect on EPA's product registration files and records during the first year of the program, and a less drastic but still significant effect in the second year. The first year's fees were due to EPA on March 1,1989. Many registrants chose not to support their registrations, and EPA cancelled about 20,000 products for nonpayment of maintenance fees in October 1989. Similarly, EPA cancelled an additional 4,500 products in February 1991 for nonpayment of fees that had been due on March 1,1990. While most of the cancellations were for inactive registrations of products that had not been produced for some time, some active registrations also were involved. EPA recognized the potentially serious impact that these cancellation actions could have on users of so-called "minor use" pesticides if needed active ingredients were to disappear from the market entirely. Therefore, in both years, EPA deferred cancellation for certain products and provided a grace period during which affected users could pursue alternatives to cancellation. 11 ------- Minor Uses And Reregistration A pesticide "minor use" is generally considered any use with limited market potential which does not generate sufficient economic return to the registrant to offset the cost of the fees or the data required for registration or reregistration. A pesticide use may be "minor" because it is for a specialty crop grown by only a few persons on small acreages (that is, it is a minor use on a specialty or minor crop), or because the use is infrequently needed or is limited to a small percentage of the total acreage of a major crop (that is, it is a minor use on a major crop). Minor uses are especially vulnerable during the reregistration process, as fees are levied and data requirements are imposed. Pesticide registrants may choose to delete minor uses from their product labels rather than provide the data needed to support those uses during reregistration. Or, they may voluntarily cancel registrations of minor use products. Similarly, low volume pesticides may be withdrawn from the market by their registrants if sales of the products do not provide sufficient economic return to offset the cost of developing the data required to support reregistration. Interregional Research Project Number 4 (or IR-4) serves as a national coordinator for identifying and developing the data needed to support minor uses. Based on information obtained from pesticide registrants, IR-4 estimates that up to 1000 pesticide minor uses needed for commodity production in the U.S. may not be supported for reregistration. In response, IR-4 has developed a strategy for developing residue data in support of reregistration of up to 1000 priority minor uses, and supporting registration of 2400 new pesticide uses. IR-4 estimates that the cost of this program would be about $8 million in fiscal year 1991, and about $12 million a year in fiscal years 1992 through 1997. Although the 1990 Farm Bill authorized a substantial increase in funding for IR-4, the actual IR-4 appropriation for fiscal year 1991 is only about $3 million. However, this represents more than a 50 percent increase over the fiscal year 1990 funding level of $1.9 million. EPA has supported the IR-4 program for many years to facilitate the registration of needed minor uses. The Agency is continuing to work closely with IR-4 in giving minor uses special consideration during the reregistration review process. EPA is preparing data development schedules which will allow full utilization of IR-4 resources. The Agency will advise IR-4 of the status of pesticide reregistration activities throughout the process. For example, the Agency will provide IR4 copies of data call-in notices and will notify IR-4 of pesticide cancellations prior to publication of notices in the Federal Register. EPA will review data for pesticide minor uses that IR-4 identifies as "not supported by the registrant but needed for commodity production," to determine whether additional residue data are needed. Finally, the Agency will publish notices regarding voluntary cancellations in the Federal Register, and will undertake other outreach activities to notify interested parties and provide them the opportunity to support reregistration of minor uses. 12 ------- Conclusion References As a result of FIFRA '88, EPA has greatly accelerated the pesticide reregistration process. Because of the sheer volume of data to be managed and reviewed, and the number of administrative actions and decisions to be made during the process, a new and more efficient infrastructure had to be developed and set in motion within the Agency. Now that many of the necessary new internal systems and procedures are in place and working, and a number of attendant policy and procedural issues have been resolved, EPA is moving ahead briskly with the reregistration effort. By issuing Reregistration Eligibility Documents for two pesticide active ingredient cases in late 1990, EPA set the stage for the first product reregistrations, anticipated in 1991. The wave of eligibility decisions and product reregistrations will rise steadily during the 1990s, until the task set forth by Congress and the American public is completed and all existing pesticides are reregistered. The Federal Insecticide, Fungicide, and Rodenticide Act as Amended, October 1988. "Federal Insecticide, Fungicide, and Rodenticide Act Amendments of 1988; Schedule of Implementation," Federal Register, April 26,1989. Federal Register publication of Lists A, B, C and D: List A: FR 2/22/89, pages 7740-7750. List B: FR 5/25/89, pages 22706-22714. List C: FR 7/24/89, pages 30846-30855. List D: FR 10/24/89, pages 43388-43396. "FIFRA Accelerated Reregistration. Phase 3 Technical Guidance," OPTS/EPA, December 24,1989. "Reregistration Plan for Chemicals on List A," EPA, March 1990. Materials distributed during EPA's Reregistration Workshop, September 24-25, 1990, Arlington, VA.: • Status of Reregistration Activities • Pesticide Reregistration Policy Proposals • Slides for Pesticide Reregistration Policy Meeting Reregistration Eligibility Documents and RED FACTS Fact Sheets for Fosetyl-Al and Heliothis zea NPV, OPTS/EPA, January 1991. "Pesticide Reregistration Handbook: How to Respond to the Reregistration Eligibility Document (RED)," OPP/EPA, January 1991. Letter to Interested Parties signed by Allan S. Abramson, Acting Director, Special Review and Reregistration Division, OPP\EPA, January 10,1991, and attached List B Phase IV Data Call-In Schedule, dated January 14,1991. 13 ------- |