1. EPA’s Pesticide Enforcement Priorities
Rosemarie Kelley
Office of Civil Enforcement
U.S. Environmental Protection Agency

2. EPA’s Priorities Assuring the safety of chemicals 2 October 28, 2019

3. EPA Enforcement Goals 3
Aggressively go after pollution problems that matter to communities
Vigorous civil and criminal enforcement
Protect people from exposure to hazardous chemicals
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4. National Enforcement Program4
Setting program direction
Updating national policies
Providing inspection targeting and case support to the Regions
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5. National Program Managers Guidance5
Focuses resources on areas of concern
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6. National Program Managers Guidance: FIFRA6
Two Focus Areas will be national:
Imports
Supplemental Registrations
Pesticides, Chemical Regulation & Right to Know Committee
October 28, 2019

7. Imports - FIFRA 7
Agency finds numerous violations through NOAs and inspections
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8. Imports - Improved Coordination
EPA joined the Commercial Targeting and Analysis Center (CTAC)
October 28, 2019

9. National Program Managers Guidance:9
Regions choose an Optional Focus Area:
Fumigants/Fumigation
Worker Safety
These areas of focus have important EJ implications.
Fumigants/Fumigation
Intended to proactively improve compliance with label requirements and use directions for these highly toxic pesticides
Worker Safety
Regions are encouraged to support State misuse actions with federal cases that will protect agricultural farm workers and pesticide applicators from exposure to pesticides
Pesticides, Chemical Regulation & Right to Know Committee
October 28, 2019

10. National Program Managers Guidance:10
Regions choose an Optional Focus Area:
Retail Marketing
Container/Containment
Pesticides, Chemical Regulation & Right to Know Committee
October 28, 2019

11. Updating National Policies11
Harmonizing ERPs across programs
October 28, 2019
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12. Updating FIFRA Policies12
FIFRA Penalty Policy (rev. 2009)
NSI Policy (rev. 2011)
Pesticides, Chemical Regulation & Right to Know Committee
October 28, 2019

13. FIFRA Compliance Monitoring and Enforcement13
Coordinating inspections
IRLs
Stop Sale, Use, or Removal Orders
Hearings
October 28, 2019
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14. Recent FIFRA Cases Monsanto Company 14 October 28, 2019
Pesticides, Chemical Regulation & Right to Know Committee
October 28, 2019

15. Recent Accomplishments - FY2011 Case Highlights15
Millipore Corporation
Pesticides, Chemical Regulation & Right to Know Committee
October 28, 2019 15

16. Recent FIFRA Decision 99 Cents Only Stores, (EPA ALJ June 24, 2010) 16
Pesticides, Chemical Regulation & Right to Know Committee
October 28, 2019

17. Recent Enforcement Developments17
DuPont Imprelis SSURO
Pesticides, Chemical Regulation & Right to Know Committee
October 28, 2019

18. Vigorous civil enforcement
Final Thoughts
Vigorous civil enforcement
October 28, 2019