Federal Insecticide, Fungicide and Rodenticide Act (FIFRA)

EPA Pesticide Classification Explained

Federal Insecticide, Fungicide and Rodenticide Act (FIFRA)

FIFRA was enacted in 1947 and has been amended several times since then. The most important amendment to FIFRA is the 1972 Federal Environmental Pesticide Control Act (FEPCA). It deals with protection of both public health and the environment.

FIFRA governs the licensing of pesticides. It gives the U. S. Environmental Protection Agency (EPA) the power to approve pesticides before they can be sold in the United States. Each use for a pesticide must receive EPA approval. The pesticide also must receive an EPA registration number. These rules enable EPA to make sure the pesticide will not cause "unreasonable human health or environmental effects."

All schools that use pesticides are subject to provisions under FIFRA. The most important of which is that the label is a legal document; any time a pesticide is misapplied it is a violation of FIFRA.

For more information about FIFRA - http://cfpub.epa.gov/schools/index.cfm

EPA Pesticide Classification Explained

Pesticides are classified in several ways, each having its own value for a given purpose. Some pesticides are classified by the EPA as restricted-use pesticides (RUP's) which means that the product has the potential to harm humans or the environment, if it is not used correctly. Only a certified applicator may mix, load, apply, or direct the use of restricted-use pesticides. There are very few situations where RUP's should be used in or around schools.

Pesticides are also classified based on their toxicity level. Acute (fast acting, single dose, immediate response) toxicity values of a pesticide determine the toxicity category of the pesticide and the signal word(s) required on the pesticide label. The toxicity category is assigned on the basis of the highest measured toxicity, oral, dermal, or inhalations; effects on the eyes and external injury to the skin are also considered. The toxicity category and, therefore, the signal word(s) are based on the total formulation. Thus, products containing the same active ingredient but in different formulations may bear different signal words.

Toxicity in pesticides are given in terms of LD50 (Lethal Dose Fifty), expressed as milligrams of toxicant per kilogram of body weight, the dose that kills 50 percent of the test animals. This rating only tells us how much chemical it takes to kill half the test animals.

Some parents want to know about the dangers of pests and about the pest control products that are used in their children's schools to control these pests. This information should be made available to parents, as long as the information disclosed is factual and disclosed in a manner that does not create an undue burden on schools.

Parents should be informed about the pest problems children could face in school buildings and on school grounds, including cockroaches, rodents, mosquitoes, ticks, fire ants, stinging insects, poison ivy, bacteria and viruses. They should also be advised that all pest control products used in schools are thoroughly tested and registered for that use with the U.S. Environmental Protection Agency and the appropriate state regulatory agency. Schools should also provide to interested parents information about pest management products being used and additional information about the school's IPM program.

In implementing right-to-know provisions as part of a school IPM plan, it is important that the limitations of school resources be taken into account. For example, it is unreasonable to notify all parents in a school district before all pesticide applications, including products used in rest rooms, cafeterias and other school facilities. Notifying parents at the beginning of a school year about the school district's integrated pest management plan and allowing parents who wish to be notified about specific pesticide applications is a much better use of school resources.

The issue of right-to-know and public participation is incorporated into several federal and state laws. The Emergency-Planning and Community Right-to-know Act (EPCRA), for example, requires companies to report to EPA releases of any pollutants into the environment. It also requires companies to prepare and submit plans to the agency about how the company would clean up any chemical accident and notify the surrounding community about the incident.

This information is available to the public; although EPA is re-evaluating how much and what types of information should be publicly disclosed in light of the September 11 terrorist attacks. After the attacks, EPA removed from the Internet company chemical emergency risk management plan data, out of concern that this information could be used by terrorist organizations to plan additional attacks against the United States.

At a recent Environmental Law Institute conference on right-to-know, Elaine Stanley, director of EPA's Office of Information Analysis and Access, said the agency is "trying to figure out whether there are better ways to manage the public dissemination of information," such as making available less-detailed information, or making it available to a smaller, more limited group of people.