Pesticide Product Registration and Compliance
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Geosyntec was retained to support registration and market introduction of pesticide products and devices in the United States under the Federal Insecticide, Fungicide and Rodenticide Act (FIFRA) and in Canada under the Pest Control Products Act (PCPA). This involved home-swimming-pool water purifiers and residential cleaning products utilizing multiple pesticidal mechanisms and substances focused on antimicrobial claims.

Geosyntec's Scope of Services

Geosyntec provided support in product regulatory status determinations under FIFRA and PCPA for ionizer, ultraviolet light (UVC), copper filter and HEPA-filter-containing products. Based on review of specific product claims, pesticidal modes of action and chemicals/substances used, and efficacy data, products were categorized as being pesticidal products requiring registration, pesticide devices not requiring registration and cleaning products that did not come under the jurisdiction of either FIFRA or PCPA. In some instances, product categorization and requirements varied between FIFRA and PCPA for the same product. Following regulatory status determination, Geosyntec managed the following activities in support of product registration and market launches:

  • Evaluating existing product characterization, toxicity, and efficacy data
  • Identifying similar registered pesticide products and supporting data studies
  • Meeting with and advocating on behalf of companies with regulators
  • Scoping, placing, and monitoring product toxicity, physical characteristic, and efficacy studies
  • Preparing FIFRA antimicrobial pesticide registration applications and labels
  • Responding to regulator requests
  • Determining pesticide device, strategy, claims, labels, data, and regulatory tracking
  • Completing state-level registrations
  • Reviewing operations, product claims, label and marketing material content to support market launch as a non-pesticide product

Home-swimming-pool and residential cleaning products were successfully positioned and launched in both the United States and Canada in compliance with FIFRA and PCPA. Additional pesticidal products are currently under development and registration review.

Geosyntec was initially brought into the project to address impoundment of products at a United States port of entry by the USEPA as improperly labeled pesticide products. Geosyntec reviewed and revised all product claims and marketing materials and assisted in significant revisions and subsequent negotiations with USEPA regarding product status under FIFRA. The project resulted in the release of products for sale.

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Project Summary

  • Location: Canada and the United States
  • Client: Confidential Client
  • Project Practice Areas: Environmental Management
  • Services Provided: Toxicology and Regulatory Subject Matter Expertise; FIFRA; TSCA; Chemicals Management; Product Safety Assessment; Risk Assessment; Data Management; Regulatory Compliance
  • Type of Work: Product Safety; Toxicology; Regulatory Support
  • Governing Regulation: Federal