Last week, the Committee on Ecological Risk Assessment of the National Academy of Sciences released a report urging reform in the registration of pesticides under the Federal Insecticide, Fungicide, and Rodenticide Act. The report focuses on Endangered Species Act consultation among the Environmental Protection Agency, the United States Fish & Wildlife Service, and the National Marine Fisheries Service concerning the impact of pesticide use on protected species. The report recommends that the three agencies use a common approach—an ecological risk assessment—to assess pesticides’ environmental impacts, and that this approach include an exposure analysis, an effects analysis, and a risk characterization.
What the impacts of the agencies’ adoption of this approach on productive activity is hard to say. At first blush, the recommended change would seem to streamline the consultation process for pesticide registration, and would in practice give more sway to EPA. But greater efficiency in regulation doesn’t necessarily mean more liberty. Members of the House Committees on Agriculture and Natural Resources, however, have already criticized the report for not auditing more of the pesticide consultation process, in particular the reasonableness of various alternatives that the wildlife agencies impose on EPA’s pesticide registration.