Environmental Enforcement Under FIFRA: Increased Scrutiny Reaches More Consumer Products
Developing Compliance Programs in Response to Recent EPA Actions
Recent Miracle Gro settlement garners $12.5 million
Recording of a 90-minute CLE webinar with Q&A
This CLE course will discuss recent Federal Insecticide, Fungicide and Rodenticide Act (FIFRA) enforcement actions by the EPA, including the $12.5 million settlement with Miracle Gro. The panel will also address FIFRA's regulation of consumer products and the potential consequences of making public health claims regarding the products.
Outline
- Introduction to FIFRA
- Regulation of consumer products as a pesticide
- Distinction between antimicrobials vs. other pesticides
- The "applied to" exemption from FIFRA
- Consequences of making public health claims
- Elements of a FIFRA registration including a discussion of the data requirement
Benefits
The panel will review these and other key questions:
- What products are covered by FIFRA?
- What marketing claims made for consumer products can trigger the application of FIFRA?
- What are the exemptions to the statute?
- What are the elements of FIFRA registration?
Following the speaker presentations, you'll have an opportunity to get answers to your specific questions during the interactive Q&A.
Faculty

Tricia Foley
Partner
Day Pitney
She focuses on business and regulatory aspects of environmental law, and is experienced in green and sustainable... | Read More
She focuses on business and regulatory aspects of environmental law, and is experienced in green and sustainable business practices and carbon reduction programs. She has extensive experience representing PRPs and PRP groups at multiparty Superfund sites. She was an adjunct professor of environmental law at the University of Hartford and is a frequent author and speaker on environmental topics.
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Robert Brennis
Brennis Consulting Services
He worked 17 years at the EPA as product manager in the Insecticide Branch and Antimicrobial Division. He worked... | Read More
He worked 17 years at the EPA as product manager in the Insecticide Branch and Antimicrobial Division. He worked closely with the green labeling groups and drafted the exemptions for certain safe products from registration requirements and defined the regulatory requirements regarding pesticide treated articles. He now consults clients on EPA registration of pesticide and antimicrobial products.
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Elizabeth Leaderman
Associate
Day Pitney
She is an associate in the firm's Real Estate, Environmental and Land Use department. Her practice focuses on... | Read More
She is an associate in the firm's Real Estate, Environmental and Land Use department. Her practice focuses on environmental law and Liz counsels clients on a wide variety environmental compliance and enforcement matters under the Clean Water Act, CERCLA, the Clean Air Act, and various state laws. Her work involves regular contact with the United States EPA, state agencies and the City of New York.
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