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EPA’s Pesticide Enforcement Priorities
Rosemarie Kelley Office of Civil Enforcement U.S. Environmental Protection Agency
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EPA’s Priorities Assuring the safety of chemicals 2 October 28, 2019
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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 October 28, 2019 October 28, 2019
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National Enforcement Program
4 Setting program direction Updating national policies Providing inspection targeting and case support to the Regions October 28, 2019 October 28, 2019
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National Program Managers Guidance
5 Focuses resources on areas of concern October 28, 2019 October 28, 2019
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National Program Managers Guidance: FIFRA
6 Two Focus Areas will be national: Imports Supplemental Registrations Pesticides, Chemical Regulation & Right to Know Committee October 28, 2019
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Imports - FIFRA 7 Agency finds numerous violations through NOAs and inspections October 28, 2019 October 28, 2019
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Imports - Improved Coordination
EPA joined the Commercial Targeting and Analysis Center (CTAC) October 28, 2019
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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
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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
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Updating National Policies
11 Harmonizing ERPs across programs October 28, 2019 October 28, 2019
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Updating FIFRA Policies
12 FIFRA Penalty Policy (rev. 2009) NSI Policy (rev. 2011) Pesticides, Chemical Regulation & Right to Know Committee October 28, 2019
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FIFRA Compliance Monitoring and Enforcement
13 Coordinating inspections IRLs Stop Sale, Use, or Removal Orders Hearings October 28, 2019 October 28, 2019
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Recent FIFRA Cases Monsanto Company 14 October 28, 2019
Pesticides, Chemical Regulation & Right to Know Committee October 28, 2019
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Recent Accomplishments - FY2011 Case Highlights
15 Millipore Corporation Pesticides, Chemical Regulation & Right to Know Committee October 28, 2019 15
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Recent FIFRA Decision 99 Cents Only Stores, (EPA ALJ June 24, 2010) 16
Pesticides, Chemical Regulation & Right to Know Committee October 28, 2019
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Recent Enforcement Developments
17 DuPont Imprelis SSURO Pesticides, Chemical Regulation & Right to Know Committee October 28, 2019
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Vigorous civil enforcement
Final Thoughts Vigorous civil enforcement October 28, 2019
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