Bryan Cave attorneys are well-versed with respect to the domestic and international regulation of the pesticides industry and have significant experience in the interpretation and application of applicable statutes, including the Federal Insecticide, Fungicide and Rodenticide Act (“FIFRA”) and the Federal Food, Drug and Cosmetics Act (“FFDCA”). Our experience traces from the early stages of research and development, through registration, manufacturing, marketing, sale and distribution, import and export product discontinuance and, where necessary, enforcement.
Specifically, Bryan Cave attorneys have experience with:
- Registering various insecticides, herbicides, plant-incorporated protectants and antimicrobial products for crop, commercial and personal uses, as well as in preparing responses to Petitions to Cancel registrations.
- Creating and acquiring data packages to support registrations and respond to data call-ins.
- Reviewing labels and marketing materials, including accuracy and completeness of labeling language and claims.
- Representing clients in responding to inspections, stop sale orders and other enforcement and penalty actions pursued by state and federal pesticide authorities.
- Preparing comments on proposed FIFRA and FFDCA regulations and PR Notices, including those relating to packaging, labeling, tolerance additions and deletions.
- Responding to offers to pay and other data compensation issues, including strategy relating to compensation and arbitration.
- Obtaining tolerances and tolerance exemptions for food use pesticides and inert ingredients.
- Advising clients regarding FIFRA exemptions, including the “Treated Article” exemption.
- Advising clients regarding import, export and transportation of registered and unregistered pesticides.
- Advising clients regarding adverse effects reporting requirements under state, EPA and international regulations.