California AG Filed Comments Criticizing EPA’s Deficient Ecological Risk Assessment for Pesticide Flonicamid

JANUARY 16, 2020

California Attorney General Xavier Becerra filed comments criticizing the Environmental Protection Agency’s (EPA) draft ecological risk assessment for the pesticide flonicamid, prepared as part of the pesticide registration review process. The comments emphasized that the EPA improperly concluded that a “full assessment of pollinator risk cannot be conducted” simply because the agency had not received required data on the pesticide’s impact from its manufacturer ISK Biosciences. The comments emphasized that under the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA), the EPA cannot proceed with a pesticide registration unless the agency determines that the pesticide “will not cause unreasonable adverse effects on the environment,” yet the agency attempted to move forward in this case despite its own acknowledgement that it “could not fully assess flonicamid’s risks to pollinators.” The comments urged the EPA to obtain the missing data, revise the draft assessment accordingly, and recirculate it for further public comment.