NACWA has asked EPA to consider the risks to utility operations and the aquatic environment when evaluating pesticides for classification as a Minimum Risk Pesticide.  This classification exempts certain pesticides from registration and other regulatory requirements under the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA).  EPA is currently considering potential modifications to the Minimum Risk Pesticide Program. 

NACWA’s comments explained that pesticides may be washed or drained into the sewer system, and even utilities with advanced treatment technologies may not remove all pesticides.  POTWs cannot control domestic use of pesticides, and most states do not allow regulation of pesticides at the local level.  It is therefore necessary for EPA to protect the wastewater treatment process, recovery of resources from wastewater, and the aquatic environment by evaluating and mitigating the risks presented by pesticides. 

Since EPA’s list of factors used to determine if a pesticide qualifies as a Minimum Risk Pesticide does not include consideration of POTWs, NACWA asked that a factor to consider pesticide impacts to POTWs be added.

NACWA supported the comments of the Bay Area Clean Water Agencies (BACWA), which has been advocating for improved consideration of pesticide impacts to POTWs.  NACWA will continue to work with BACWA to address this issue.  NACWA members with questions or information about pesticide impacts should contact Cynthia Finley, NACWA’s Director of Regulatory Affairs.