Piscicide Pesticide Reregistration and NPDES Permit Processes

The piscicides rotenone and antimycin cleared the reregistration process in 2007 under the authority of the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA) by the EPA.  Reregistration requires the assessment of physical, chemical, public health and environmental data to allow for assessments of risk estimating the impacts to human health and the environment.  As part of the reregistration process, restrictions were placed on their use to mitigate (lessen) unnecessary and potentially harmful exposures to humans and the environment.  These use restrictions have been described in detail in standard operating procedure manuals for both piscicides.   The EPA is now under a mandate to develop wastewater discharge (National Pollution Discharge Elimination System [NDPES]) permits for the application of pesticides in and around water under the authority of the Clean Water Act (CWA).  The proposed permit conditions will likely be finalized in 2011, but many states including California, Washington and Montana already issue NPDES permits for the application of rotenone and antimcyin.  The current status of the NPDES permit conditions will be discussed in relations to harmonization of the use conditions for rotenone and antimycin.