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Impact of EPA’s

Conventional Reduced

Risk Pesticide Program

Is Declining 

Report No. 14-P-0322 July 24, 2014

U.S. ENVIRONMENTAL PROTECTION AGENCY

OFFICE OF INSPECTOR GENERAL
Report Contributors: Jerri Dorsey

Gabrielle Fekete

Jeffrey Harris

Kathryn Hess

Thane Thompson

Abbreviations

CRRP Conventional Reduced Risk Pesticide

EPA U.S. Environmental Protection Agency

FIFRA Federal Insecticide, Fungicide and Rodenticide Act

IR-4 Interregional Research Project No. 4

OIG Office of Inspector General

OPP Office of Pesticide Programs

PRIA Pesticide Registration Improvement Act

USDA U.S. Department of Agriculture

Cover photos: From left: ground-based equipment applying agricultural chemicals; 

crop-duster applying agricultural chemicals by air. (EPA photos)

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 14-P-0322

July 24, 2014

Why We Did This Review

We conducted this review of the 

U.S. Environmental Protection 

Agency’s (EPA’s) Conventional

Reduced Risk Pesticide (CRRP) 

Program to determine whether it 

was meeting its goal of reducing 

risks to human health and the 

environment by encouraging the 

development, registration and 

use of pesticide products that 

are lower risk. 

Pesticides are widely used in 

agricultural, commercial and 

household settings. Once 

released into the environment, 

pesticides have the potential to 

pollute rivers, groundwater, air, 

soil, wildlife and food. The EPA 

developed the CRRP Program to 

quickly register reduced risk

alternatives to those currently on 

the market. Reduced risk 

pesticides are designed to be 

less harmful to humans, birds, 

fish and/or plants; have lower

potential for groundwater 

contamination; and require lower

application rates. 

This report addresses the 

following EPA goal or 

cross-agency strategy:

 Ensuring the safety of 

chemicals and preventing 

pollution.

For further information, 

contact our public affairs office at 

(202) 566-2391.

The full report is at:

www.epa.gov/oig/reports/2014/ 

20140724-14-P-0322.pdf

 

Impact of EPA’s Conventional Reduced Risk 

Pesticide Program Is Declining

 What We Found

The impact of the CRRP Program has 

declined over the last 10 years. The CRRP 

Program is registering fewer reduced-risk 

pesticides compared to the number 

registered prior to the 2004 implementation 

of the Pesticide Registration Improvement 

Act (PRIA). In our opinion, PRIA is a factor in declining CRRP impact because it 

increased the cost to register reduced risk pesticides and decreased the timeto-market savings that reduced risk pesticides previously had over conventional 

pesticides. The EPA does not have the statutory authority to provide feereduction incentives for companies continuing to develop and register reduced 

risk pesticides.

Implementing steps to remove participation obstacles can increase participation 

and the impacts of the CRRP Program. Moreover, improving the measurement 

of the program’s outcomes can more accurately capture the impacts of the 

CRRP Program. The program’s existing performance measure focuses on the 

use of reduced risk pesticides in agriculture. The measure does not capture the 

complete population of CRRP products in the marketplace. For example, CRRP 

products used in non-agricultural markets—such as residences or around food 

products—are not captured, and the EPA has not developed ways to cost

effectively collect non-agricultural use data. 

Noteworthy Achievements 

The CRRP Program has succeeded in bringing reduced risk pesticides to 

market since 1994. More than 727 reduced risk pesticide uses have been 

approved and reduced risk pesticides account for approximately 22 percent of 

farm acres treated in the United States each year. Also, the CRRP Program has

successfully partnered with the Interregional Research Project No. 4 to make 

reduced risk pesticides widely available to a diverse population of growers.

Recommendations and Agency Response

We recommend that the Assistant Administrator for Chemical Safety and 

Pollution Prevention seek authority from Congress to reduce PRIA application 

fees for reduced risk pesticides to increase participation, and develop measures 

that better capture the impact of the entire CRRP Program. The EPA agreed 

with our recommendations and has proposed acceptable corrective actions. 

All recommendations are resolved. 

U.S. Environmental Protection Agency

Office of Inspector General

At a Glance

The number of newly registered 

reduced risk pesticides may 

continue to decline unless the 

EPA can reduce barriers to 

participation.
July 24, 2014

MEMORANDUM

SUBJECT: Impact of EPA’s Conventional Reduced Risk Pesticide Program Is Declining

Report No. 14-P-0322

FROM: Arthur A. Elkins Jr.

TO: Jim Jones, Assistant Administrator

Office of Chemical Safety and Pollution Prevention

This is our report on the subject evaluation conducted by the Office of Inspector General (OIG) of the 

U.S. Environmental Protection Agency (EPA). This report contains findings that describe problems the 

OIG has identified and corrective actions the OIG recommends. This report represents the opinion of the 

OIG and does not necessarily represent the final EPA position. Final determinations on matters in this 

report will be made by EPA managers in accordance with established audit resolution procedures. 

The EPA office having primary responsibility for the issues evaluated in this report is the Office of 

Chemical Safety and Pollution Prevention’s Office of Pesticide Programs.

Action Required

You are not required to provide a written response to this final report because you provided agreed-to 

corrective actions and planned completion dates for the report recommendations. The OIG may make 

periodic inquiries on your progress in implementing these corrective actions. Should you choose to 

provide a final response, we will post your response on the OIG’s public website, along with our 

memorandum commenting on your response. You should provide your response as an Adobe PDF file 

that complies with the accessibility requirements of Section 508 of the Rehabilitation Act of 1973, as 

amended. 

We will post this report to our website at http://www.epa.gov/oig. 

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

WASHINGTON, D.C. 20460

THE INSPECTOR GENERAL
Impact of EPA’s Conventional Reduced Risk 14-P-0322

Pesticide Program Is Declining

Table of Contents

Purpose...................................................................................................................... 1

Background ............................................................................................................... 1

Noteworthy Achievements ....................................................................................... 3

Scope and Methodology........................................................................................... 3

CRRP Registrations and Participation Declined

Following Statutory Changes ............................................................................. 4

Incomplete Measures Leave Impacts Unreported................................................... 5

Conclusions............................................................................................................... 7

Recommendations .................................................................................................... 7

Agency Comments and OIG Evaluation .................................................................. 7

Status of Recommendations and Potential Monetary Benefits ............................. 9

Appendices

A Agency Response to Draft Report .................................................................. 10

B Distribution ....................................................................................................... 13
14-P-0322 1

Purpose

We conducted this review of the U.S. Environmental Protection Agency’s 

(EPA’s) Conventional Reduced Risk Pesticide (CRRP) Program to determine 

whether it was meeting its goal of reducing risks to human health and the 

environment by encouraging registration of pesticides that are lower risk than 

existing alternatives.

Background

The EPA gets its authority to regulate pesticides under the Federal Insecticide, 

Fungicide and Rodenticide Act (FIFRA).

1 The EPA defines a pesticide as any 

substance intended to destroy, prevent or repel pests, such as insects, weeds, fungi 

and rodents. Pesticides are an integral part of agriculture. Many household 

products are also pesticides, including insect repellents for personal use, weed 

killers, disinfectants and some swimming pool chemicals. Once released into the 

environment, pesticides have the potential to pollute rivers, groundwater, air, soil, 

wildlife and food. Pesticides are regulated by FIFRA through an application 

review and approval process. A product must be registered for each crop, indoor

use, or use on or near food. To be used in other ways, the product must also be 

registered for those uses, either with the original application or in a separate 

application.

The CRRP Program is implemented by the Office of Chemical Safety and 

Pollution Prevention’s Office of Pesticide Programs (OPP). The goal of this 

program is to promote the development and registration of lower-risk pesticides. 

These products are intended to reduce risks to human health and the environment

when compared to existing conventional pesticides currently on the market. The 

CRRP Program expedites the review of reduced risk pesticide applications so that 

these products are available to growers as soon as possible. Expected participants 

in this program are the chemical companies that submit pesticide registration 

applications to the EPA. In return for making a reduced risk product and for 

participating in the CRRP Program, the manufacturer’s registration application is 

expedited through the review process, shortening the process by up to 6 months. 

To participate in the CRRP Program, the applicant must develop a “reduced risk 

rationale” document. The rationale outlines the reasons why the participant’s

product satisfies the CRRP criteria and should be identified as a reduced risk 

product. It includes risk comparison information between the chemical being 

considered for reduced risk status and chemicals currently in the marketplace for 

that use. The development of the rationale document can take hundreds of work

hours to complete.

 

1 7 U.S. Code § 136a - Registration of pesticides.
14-P-0322 2

The EPA cites a number of advantages to CRRPs over existing non-CRRPs, 

including low impact on human health; lower toxicity to non-target organisms 

(birds, fish, plants); low potential for groundwater contamination; low application

rates; low pest resistance potential; and compatibility with Integrated Pest 

Management practices. The EPA notes there are marketing advantages to 

receiving reduced risk status, although companies are not allowed to put a 

reduced risk pesticide claim on their labels. Also, some end users give preference 

to crops treated with reduced risk pesticide products.

The CRRP Program began in 1992 and the EPA approved 14 reduced risk 

pesticides between 1993 and 1997. The Food Quality Protection Act of 1996 

formalized the program in statute, mandating that the EPA provide guidance to 

the applicants and implement the CRRP Program by 1997. Until 2004, when the 

Pesticide Registration Improvement Act (PRIA) was passed, the EPA reviewed

pesticides under a priority system set annually by growers, industry, 

manufacturers and the EPA working together. The chemicals or ingredients that 

were on the priority list each year were more likely to get reviewed.

In 2004, Congress amended FIFRA by adding PRIA to the statute.2 The PRIA 

amendment did not change the way the EPA reviewed pesticide applications. 

PRIA instead established required timelines for the review of all applications, not 

just the chemicals prioritized under the traditional process. According to an 

industry representative, before PRIA was enacted the average time for a regular 

New Active Ingredient approval was 38 months, compared to 14 months for 

New Active Ingredient CRRP products. In 2014, the review timeframe fell to 

24 months for non-CRRP products and 18 months for CRRP products.

Table 1: FY 2014-2015 New Active Ingredient pesticide fees and review time

Action decision

EPA review 

time (months)

FY 2014-2015 

EPA registration 

service fee 

New Active Ingredient, Food Use 24 $597,683

New Active Ingredient, Food Use, Reduced Risk 18 597,683

New Active Ingredient, Non-Food Use; Outdoor 21 415,241

New Active Ingredient, Non-Food Use; Outdoor, Reduced Risk 16 415,241

New Active Ingredient, Non-Food Use; Indoor 20 230,947

New Active Ingredient, Non-Food Use; Indoor, Reduced Risk 14 230,947

Source: OPP.

In addition to revising review timelines, PRIA also implemented pesticide 

registration service fees, which add costs to the registration process. The highest

registration fees apply to “New Active Ingredients.” As shown in table 1, while 

the EPA review time is reduced under PRIA the review time is still less for 

 

2 The original PRIA statute—passed in 2004—was in effect from March 23, 2004, until September 30, 2007, and is 

now referred to as PRIA 1. PRIA 2 was in effect from October 1, 2007, through September 30, 2012. PRIA 3 came 

into effect on October 1, 2012, and is slated to expire on September 30, 2017.
14-P-0322 3

reduced risk pesticide registrations. The EPA’s pesticide registration fees are the 

same regardless if it is a CRRP or non-CRRP.

Another significant participant in the CRRP Program is the Interregional 

Research Project No. 4, commonly known as IR-4. Sponsored by Rutgers 

University, IR-4 is a non-profit program that works in partnership with the 

U.S. Department of Agriculture (USDA), the land grant university system, the 

EPA, the agrochemical industry, commodity groups and growers. It is often not 

cost effective for the manufacturer to develop residue data to support registration 

for minor use crops like blueberries, strawberries or carrots. IR-4 conducts 

residue field trials and submits tolerance petitions for these minor use crops.

Noteworthy Achievements

The CRRP Program has been successful in bringing reduced risk pesticides to 

market since 1993. Fifty-six new reduced risk pesticides and 727 reduced risk 

pesticide uses for existing chemicals have been approved, and more than 

20 percent of agricultural pesticides applied today are reduced risk products. 

This means that, each year, reduced risk pesticides are applied to approximately

20 percent, or 169 million acres, of U.S. farmland. Further, the CRRP Program

has actively partnered with Rutgers University’s IR-4 program to expand the use 

of CRRPs to additional crops.

Scope and Methodology

We conducted this audit from April 2013 to April 2014, in accordance with 

generally accepted government auditing standards. Those standards require that 

we plan and perform the audit to obtain sufficient, appropriate evidence to 

provide a reasonable basis for our findings and conclusions based on our 

objective. We believe that the evidence obtained provides a reasonable basis for 

the results reported based upon our objective, and that our conclusions are 

sufficiently based on evidence collected during the course of this audit.

To address our objective, we reviewed and analyzed relevant federal statutes, 

regulations and guidance. We interviewed officials, managers and staff in OPP.

We also reviewed five CRRP Program application documents to determine the 

type of information provided to the EPA to make its reduced risk decisions. 

Finally, we gathered information from several organizations that work with the 

EPA in the manufacture and registration of CRRPs.
14-P-0322 4

CRRP Registrations and Participation Declined Following

Statutory Changes 

The impact of the CRRP Program has been declining for the past 10 years. The 

program is not registering as many CRRP products nor attracting as many CRRP 

applications as before the implementation of the PRIA 1.

3 One factor is that the 

PRIA pesticide registration service fees are the same regardless of whether an 

application is a CRRP or non-CRRP product. While the CRRP applicant could 

still get its product to market more quickly than a non-CRRP product, the 

applicant must weigh the time advantage against paying both the application costs 

and the CRRP-rationale development costs. Moreover, the time-to-market benefit 

from participation has reduced significantly since the inception of the program.

Challenges to the success of the CRRP Program were introduced with the passage 

of the original PRIA legislation. PRIA 1 not only introduced registration service 

fees, it also changed application review timeframes, which narrowed the gap 

between regular applications and CRRP application review. These review 

timeframe reductions continued with subsequent PRIA revisions. By the time 

PRIA 3 was enacted, reductions in all regular pesticide registration review 

timeframes had been established. As shown in figure 1, CRRP New Chemical 

registrations generally increased since the program was piloted in 1994, peaking 

in 2000, when seven New Chemical CRRP products were registered. After the 

implementation of PRIA 1, the number of new chemical registrations decreased 

by 71 percent, and there have only been 11 new chemical registrations since 2004.

Figure 1: New Chemical CRRP registrations per year, 1994–2013

Source: Office of Inspector General (OIG) analysis of OPP data.

 

3 An application is the submission of paperwork by the manufacturer seeking the registration of a reduced risk 

product. A registration means that the reduced risk application has been approved and the chemical is registered by 

the EPA as a conventional reduced risk product.

0

1

2

3

4

5

6

7

8

19941995199619971998199920002001200220032004200520062007200820092010201120122013

New chemicals per year

PRIA enacted, 2004
14-P-0322 5

Similarly, the data in figure 2 illustrates that registration of New Uses for Existing 

Chemicals fell by 72 percent after PRIA 1 was enacted. 

Figure 2: Existing Chemical, New Use CRRP registrations per year, 1997–2013

Source: OIG analysis of OPP data.

OPP staff agreed that PRIA has had a significant adverse impact on the number of 

applications received, and the number of registrations achieved, by the CRRP

Program. The EPA has only an advisory role in specifying the timelines for 

application reviews and does not have the authority to change the fee schedule 

under PRIA. Further, OPP staff informed us that, in their opinion, the PRIA 3 

review timeframes could not reasonably be reduced any further or the scientific 

review may not be sufficient. As a result, fee reductions seem to be the only 

viable option to increase participation in the CRRP Program.

While the EPA does not have the authority to reduce registration service fees, the 

agency is authorized to exempt those registration applications associated with

IR-4 submissions. With the decline in participation, the CRRP Program’s human 

health and environmental impacts may also be declining. To encourage increased 

participation in the CRRP Program, the EPA should seek the authority to reduce 

the fees for CRRP applications. Even a 10-percent reduction for a “New Active 

Ingredient, Food Use” product would reduce the fee by nearly $60,000.

Incomplete Measures Leave Impacts Unreported

The EPA’s CRRP Program does not have complete measures to determine the 

impacts of the entire CRRP effort. The EPA’s current performance measure does 

not completely capture the entire population of CRRP products, and is limited 

only to products with agricultural uses. The EPA measures its outcome as the 

“percentage of agricultural acres treated with reduced risk pesticides.” As shown 

0

20

40

60

80

100

120

140

160

180

Registrations per year

PRIA enacted, 2004
14-P-0322 6

in figure 3, usage of CRRP products increased from approximately 3 percent in 

1998 to 22 percent in 2012.

Figure 3: Percentage of agricultural acres treated with reduced risk pesticides,

1998-2012

Source: OIG analysis of OPP data.

This measure calculates the percentage of agricultural acre treatments made using 

reduced risk pesticides based on data collected from the USDA. Analysis of the 

data is used to determine the overall level of CRRP product usage across more 

than 843 million acres that are regularly farmed in the United States.

OPP staff told us that this increase is the result of two specific chemicals on three 

crops. The first—glyphosate (Roundup®)—was used on genetically modified 

“Roundup-resistant” corn and soybeans and is responsible for roughly 75 percent 

of the annual agricultural acre treatments of reduced risk pesticides. The second—

Bacillus thuringiensis—is a naturally occurring bacterium that is genetically 

spliced to corn and cotton seeds and makes up about 20 percent of the remaining 

reduced risk pesticides’ annual agricultural acre treatments. All other agriculturaluse CRRP products make up the remaining 5 percent of the measure above.

Although the agricultural pesticide application captures the majority of CRRP 

usage, there are also several CRRP products that are not registered for agricultural 

use. These CRRP products are mostly used in non-agricultural commercial 

applications, and some are used indoors or around food products. According to 

OPP staff, non-agricultural-product use is very difficult to collect because the 

applications are made by a diverse set of pesticide users to a wide range of use 

sites.

0

5

10

15

20

25

1996 1998 2000 2002 2004 2006 2008 2010 2012 2014

Percentage of Agricultural Acres 

Treated with Reduced-Risk Pesticides
14-P-0322 7

OPP staff mentioned that California requires reporting of commercial applications 

but the EPA does not currently collect this type of data. When we discussed this 

issue further, the PRIA Ombudsman indicated that it could be important to begin 

trying to capture this data for future measurements. Although the non-agricultural 

chemicals are only a small percentage of the overall effort, this could change in 

the future. Without measures that capture all agricultural and non-agricultural uses 

of CRRP pesticides, the EPA cannot accurately determine the outcomes and 

impacts of the CRRP Program’s efforts.

Conclusions

The EPA is required by law to implement the CRRP Program, but over the last 

several years participation in the program has waned. Without a reduction in

barriers, participation in the CRRP Program may continue to decline. Numerous 

obstacles impact the number of products that are registered under the program, 

and the agency does not currently have the authority to reduce these barriers. 

Further, the CRRP Program’s measures do not report results from all likely 

impacts from the program. The EPA must address the participation barriers, as 

well develop and implement representative measures, to better capture the 

impacts of the CRRP Program. 

Recommendations

We recommend that the Assistant Administrator for Chemical Safety and 

Pollution Prevention:

1. Reduce participation barriers for the CRRP Program by seeking statutory 

authority from Congress to reduce application fees for approved CRRP 

registrations.

2. Develop and implement measures for non-agricultural uses of CRRP 

products so that OPP’s data are representative of the CRRP Program’s 

entire effort.

Agency Comments and OIG Evaluation

The agency agreed with our findings and recommendations, and provided 

corrective actions and estimated completion dates that meet the intent of the 

recommendations. The agency’s response to the first recommendation is 

contingent, in part, on a reauthorization of PRIA after the current legislation

expires in September 2017. The agency’s response to the second recommendation 

is contingent on the availability of information to support an appropriate measure 

of reduced-risk non-agricultural pesticide usage. At a meeting to discuss the 

agency’s comments on the report, the agency was advised that the OIG will be 

monitoring the status of each corrective action after each estimated completion 

date. Based on this meeting and the agency’s written response, we have 
14-P-0322 8

determined that the recommendations are resolved and open with corrective 

actions ongoing. No further response to this report is required. The agency’s 

detailed response is in appendix A. The agency also provided technical comments 

on the draft report, which we have incorporated into our report as appropriate. 
14-P-0322 9

Status of Recommendations and 

Potential Monetary Benefits

RECOMMENDATIONS

POTENTIAL MONETARY 

BENEFITS (in $000s)

Rec. 

No. Page No. Subject Status1 Action Official

Planned 

Completion 

Date

Claimed 

Amount

Agreed-To 

Amount

1 7 Reduce participation barriers for the CRRP 

Program by seeking statutory authority from 

Congress to reduce application fees for approved 

CRRP registrations.

O Assistant Administrator for 

Chemical Safety and 

Pollution Prevention

09/30/2017

2 7 Develop and implement measures for nonagricultural uses of CRRP products so that OPP’s 

data are representative of the CRRP Program’s 

entire effort.

O Assistant Administrator for 

Chemical Safety and 

Pollution Prevention

06/30/2015

1 O = recommendation is open with agreed-to corrective actions pending 

C = recommendation is closed with all agreed-to actions completed 

U = recommendation is unresolved with resolution efforts in progress
14-P-0322 10

Appendix A

Agency Response to Draft Report

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

 WASHINGTON, D.C. 20460

June 16, 2014

MEMORANDUM

SUBJECT: Comments on Draft Report "Impact of EPA's Conventional Reduced Risk

Pesticide Program Is Declining" Project No. OPE-FY13-0003

FROM: James Jones, Assistant Administrator

Office of Chemical Safety and Pollution Prevention

TO: Carolyn Copper, Assistant Inspector General

Office of Program Evaluation

This memorandum is in response to the Office of Inspector General's (OIG) April 29, 2014, 

Draft Report, entitled Impact of EPA's Conventional Reduced Risk Pesticide Program Is 

Declining (Project No. OPE-FY13-0003) which evaluated the Agency's Conventional Reduced 

Risk Pesticide Program (CRRP). The Office of Chemical Safety and Pollution Prevention 

(OCSPP) appreciates the OIG's efforts to review the CRRP and the OIG's interest in improving 

this program. The Agency agrees with the OIG that some improvements can be made to the 

program, yet we would like to offer information to better characterize this program. We support 

both of the recommendations made by the OIG and have provided corrective actions with 

timeframes. We have also attached a track changes version of the draft report with edits that 

clarify goals and details of the CRRP.

I. Background

EPA believes it is critical to view the CRRP in the context of EPA's overall pesticide 

registration program and the requirements of the Pesticide Registration Improvement Act 

(PRIA), as amended. The Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA) 

requires that, before selling or distributing a pesticide in the United States, a person or company 

must obtain a registration, or license, from EPA, unless the product is exempt from pesticide 

registration. Before registering a new pesticide or new use for a registered pesticide, EPA must 

first ensure that the pesticide, when used according to label directions, can be used without 

posing unreasonable risks to human health or the environment.

OFFICE OF CHEMICAL SAFETY 

AND POLLUTION PREVENTION
14-P-0322 11

In 2004, at the behest of a coalition of industry trade associations and environmental advocacy 

groups (the PRIA Coalition), Congress enacted PRIA and amended FIFRA to add required fees 

and specific decision timeframes for the review of 90 covered pesticide application categories. 

(Prior to PRIA, FIFRA did not require EPA to make decisions on most types of applications for 

registration within specific deadlines.) PRIA was subsequently amended two more times (2007 

and 2012), with changes adding covered pesticide application categories - there are now 189 

covered categories -as well as fee and timeframe changes. Under PRIA significantly greater 

predictability was achieved regarding when a regulatory decision would be made for both 

reduced risk and non-reduced risk covered applications. PRIA has also resulted in a smaller 

differential in the decision time frames between reduced risk and non-reduced risk applications 

than what existed prior to PRIA. The additional resources provided by PRIA fees were used, in 

part, to reduce by about 6 months (from 24 months (before PRIA) to 18 months) the average 

amount of time to make regulatory decisions on applications to register products containing 

new reduced risk active ingredients (AIs). While the PRIA fees for new AI and new use 

applications, whether reduced risk or not, are the same, the decision timeframes under PRIA for 

new, reduced risk AI and new uses applications are shorter compared to non-reduced risk 

applications - six months for new AIs and five months for new uses.

EPA's CRRP is a voluntary program that offers faster review times for reduced risk pesticides. 

The goal of CRRP is to register commercially viable alternatives to riskier conventional 

pesticides such as neurotoxins, carcinogens, and developmental and reproductive toxicants. 

The CRRP expedites the review and regulatory decision-making process for conventional 

pesticides that pose less risk to human health and the environment than existing conventional 

alternatives. This program does not apply to biological or antimicrobial pesticides, which are 

handled through separate expediting processes. In order to qualify for CRRP status, the 

applicant must provide a "reduced risk rationale" that compares risk endpoints for the chemical 

in question to those for registered pesticides currently being used on the crop(s) for which 

CRRP status is being sought. The reduced risk standard is a comparative standard, so once a 

reduced risk pesticide has been registered for a crop, the next reduced risk application for that 

crop is compared to it. The reduced risk standard is not static over time but becomes more 

difficult to achieve as more reduced risk pesticides are registered. Even without PRIA, one 

would expect a diminishing number of reduced risk pesticides as the standard becomes 

increasingly more difficult to meet.

EPA's CRRP is a voluntary program that offers faster review times for reduced risk 

pesticides. The goal of CRRP is to register commercially viable alternatives to riskier 

conventional pesticides such as neurotoxins, carcinogens, and developmental and

reproductive toxicants. The CRRP expedites the review and regulatory decision-making

process for conventional pesticides that pose less risk to human health and the environment

than existing conventional alternatives.This program does not apply to biological or

antimicrobial pesticides, which are handled through separate expediting processes. In order

to qualify for CRRP status, the applicant must provide a "reduced risk rationale" that

compares risk endpoints for the chemical in question to those for registered pesticides

currently being used on the crop(s) for which CRRP status is being sought. The reduced

risk standard is a comparative standard, so once a reduced risk pesticide has been registered

for a crop, the next reduced risk application for that crop is compared to it. The reduced risk
14-P-0322 12

standard is not static over time but becomes more difficult to achieve as more reduced risk

pesticides are registered. Even without PRIA, one would expect a diminishing number of

reduced risk pesticides as the standard becomes increasingly more difficult to meet.

II. OCSPP Responses to OIG's Recommendations

As required by EPA Order 2750, "EPA's Audit Management Process," we are

addressing the OIG's recommendations as follows:

OIG recommended that the Assistant Administrator for Chemical Safety and Pollution

Prevention take the following actions:

1. Reduce participation barriers for the CRRP Program by seeking statutory

authority from Congress to reduce application fees for approved CRRP registrations.

OCSPP Response: OCSPP Response: While OCSPP is constrained from seeking such 

statutory change from Congress directly, we maintain a positive relationship with the PRIA 

Coalition and can discuss this with the Coalition. In addition, if the Coalition were to seek 

another renewal of PRIA when the law expires in 201 7, EPA will transmit this recommended 

change to the fees charged to applicants for reduced risk products to the Coalition. Transmittal 

of this recommendation will occur within 30 days from when the Coalition approaches EPA 

regarding PRIA renewal.

2. Develop and implement measures for non-agricultural uses of CRRP

products so that OPP's data are representative of the CRRP Program's entire

effort.

OCSPP Response: OCSPP believes it is valuable to pursue this recommendation, even

though the non-agricultural pesticide usage data available to create a measure similar to the 

current agricultural CRRP products measure has significant limitations. We note that there

are very few non-agricultural CRRP products, and OCSPP does not have data representative 

of the national non-agricultural uses. The available data islimited in its scope and coverage

of non-agricultural marketsin the following ways: not every non-agricultural market is

captured in the data, the data collected is not consistent from market to market, and the data

is not collected every year. Thus, in the past, we have not used the data to develop a national

non-agricultural CRRP usage performance measure. However, within one year, OCSPP will

explore the use of the available data to determine the possibility of creating a standardized 

measure for non-agricultural uses.

Attachment: Technical Corrections to DRAFT OIG Report
14-P-0322 13

Appendix B

Distribution

Office of the Administrator

Assistant Administrator for Chemical Safety and Pollution Prevention

Agency Follow-Up Official (the CFO)

Agency Follow-Up Coordinator

General Counsel

Associate Administrator for Congressional and Intergovernmental Relations

Associate Administrator for External Affairs and Environmental Education

Deputy Assistant Administrator for Chemical Safety and Pollution Prevention

Director, Office of Pesticide Programs, Office of Chemical Safety and Pollution Prevention

Audit Follow-Up Coordinator, Office of Chemical Safety and Pollution Prevention

Audit Follow-Up Coordinator, Office of Pesticide Programs, Office of Chemical Safety and 

Pollution Prevention