Contrary to popular opinion, the U.S. Environmental Protection Agency’s (EPA) enforcement activity under the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA) has been trending upward over the last couple of years. As noted in our earlier advisory memorandum on enforcement activity under the Toxic Substances Control Act (TSCA), although most parties subject to TSCA inspections receive a “boilerplate” letter, FIFRA enforcement actions tend to be more heterogeneous. This memorandum provides guidance to FIFRA stakeholders on how to respond to a typical EPA FIFRA inspection letter. For more information, please read the full memorandum.
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