Sector
Crop Protection
Since 1988, we have provided regulatory and environmental strategy support for crop protection products from bench to market and through end-user support. Regulatory requirements differ across the globe and are ever-changing. CSI is positioned to assist with global regulatory and scientific needs.
In the US and Europe, we provide agrochemical firms with regulatory and scientific services to comply with the US Environmental Protection Agency (EPA) Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA) and the EU Plant Protection Products Regulation (EC) No 1107/2009. Additionally, we assist companies with fulfilling US State pesticide registration and European Economic Area (EEA) Member State and UK requirements. We support clients with global registration requirements, and have provided successful regulatory support in Canada, Latin America, South America, Asia, and Africa.
CSI develops environmental strategies to address ecological inquiries that arise during the pesticide development and registration process. We apply our extensive knowledge in agriculture, the regulatory arena, risk assessment, at-risk species, conservation measures, economics, and spatial analysis to provide comprehensive crop protection product support for our clients. CSI integrates a variety of data to provide a comprehensive picture of issues affecting product registration and works to find reasonable solutions.
Experienced Support For:
- Regulatory Strategy
- Dossier Preparation & Submission
- Regulatory Agency Liaison
- Human Health & Environmental Risk Assessment
- Endangered Species Analysis & Strategy
- Endocrine Disruptor Data Review
- Task Force Representation & Administration
- Applied Economic Analysis
- Spatial Analysis & Data Systems
- Classification, Labelling, and Packaging (CLP)
Crop Protection Support in North America
EPA Regulatory Support
- Regulatory strategies for FIFRA-regulated pesticide active substances (ingredients), biopesticides, microbial and antimicrobial products
- Agency liaison and negotiation, EPA registration, and registration review package preparation and submission, including electronic submission through EPA’s online portals
- Identification of required studies to support registration intent and data gap analysis
- Placement and monitoring of tests at Contract Research Organizations (CRO), review and interpretation of study results, and verification of compliance with Good Laboratory Practice (GLP) standards
- Preparation of data waivers and DERs
State Registration Management
- First-time registration and registration renewal support in all 50 states, California, District of Columbia, and US territories
- State and California submission packages (applications, labels, safety data sheets, technical data, reports, authorization letters, and efficacy reports)
Environmental Fate & Ecotoxicology Data Review
- Classification, Labelling, and Packaging (CLP)
- Soil, water, sediment, and air DT50 values
- Adsorption/desorption and leaching potential
- Non-target organism toxicity endpoints and no observed effect concentrations (NOECs)
Applied Economics Support
- Extensive experience in production agriculture, economics, and conservation
- Pesticide use characterization and historical usage information
- Provide public comments on proposed registration decisions, developed use profiles, and other topics related to agriculture and pesticide uses
- Conduct economic impact analysis and develop benefit assessments
Endangered Species Analysis & Strategy
- Conduct assessments for species listed under the US Endangered Species Act (ESA) to determine potential effects from use of pesticides and product-relevant mitigation measures
- Use best available data to develop informed and defensible recommendations
- Combine economics, species status, conservation, and industry knowledge to assist clients in identifying solutions that are reasonable for the registrant and end-users and also protective of species
- Build and maintain collaborative relationships with multiple organization-levels within the USEPA, US Fish and Wildlife Service (FWS), US National Marine Fisheries Service (NMFS), US Department of Agriculture (USDA), state and regional-level agencies, and other entities
Spatial Analysis & Data Systems
- Compile, manage, and analyze spatial data to assess overlap of product use with listed species ranges and other areas of concern using Geographic Information Systems (GIS), databases, and custom programming
- Organize layers of information into illustrations to facilitate communication
- Assess data for explanatory patterns and relationships
Task Force Representation & Administration
- Client representation on industry trade association consortia
- Serve in management, administrative, and lead technical roles on chemical task forces, including the FIFRA Endangered Species Task Force (FESTF)
Litigation Support
- Data compensation evaluations
- Intellectual property assessment
- Scientific case preparation
- Expert witness testimony
Crop Protection Support in Europe (EEA)
The Plant Protection Products Regulation (EC) No 1107/2009 applies to the European Economic Area (EEA) – the 27 EU Member States, plus Iceland, Liechtenstein and Norway – and imposes significant obligations on companies placing plant protection products on the EEA market.
Registration Dossier Preparation & Submission
- Preparation and submission of active substance dossiers for EEA registrations including synthetic pesticides, biopesticides, and microbial products for compliance with Plant Protection Product legislation
- Preparation and submission of product dossiers for EEA Member States (including zonal and mutual recognition), and Article 53 Emergency Authorisations
- Liaison with European regulatory agencies including European Food Safety Authority (EFSA), European Chemicals Agency (ECHA), and the European Commission, in addition to EEA Member State national regulatory authorities
- Support for Post Annex I (re-)registration
- Extensive experience with International Uniform ChemicaL Information Database (IUCLID)
- Organisation for Economic Co-operation and Development (OECD) format dossiers
Regulatory Strategy
- Identification of required studies to support registration intent and data gap analysis
- Placement and monitoring of tests at Contract Research Organizations (CRO), review and interpretation of study results, and verification of compliance with Good Laboratory Practice (GLP) standards/Good Efficacy Practice (GEP) standards
- Preparation of data waivers
Hazard, Exposure & Risk Assessments for Human Health & Environment
- Extensive experience in all aspects of human health and environmental assessment
- Application of various models, including: Chesar, ConsExpo, EUROPOEM, FOCUS, and PERSAM
- Quantitative Structure-Activity Relationship (QSAR) modeling, e.g. OECD Toolbox, EPI Suite
- Endocrine Disruptor (ED) assessments in accordance with EFSA/ECHA guidance
- Classification, Labelling and Packaging (CLP)
Litigation Support
- Data compensation evaluations
- Intellectual property assessment
- Scientific case preparation
- Expert witness testimony
Crop Protection Support in Europe (UK)
Although the UK left the EU on 31st January 2020, the Plant Protection Products Regulation was transposed into UK law almost unchanged, so the provisions of the Regulation apply in full in the UK.
Registration Dossier Preparation & Submission
- Preparation and submission of active substance dossiers for UK registrations including synthetic pesticides, biopesticides, and microbial products for compliance with Plant Protection Product legislation
- Preparation and submission of UK product dossiers, including national addenda and Article 53 Emergency Authorisations
- Liaison with UK national regulatory authority, and European regulatory agencies including European Food Safety Authority (EFSA), European Chemicals Agency (ECHA) and the European Commission
- Support for Post Annex I (re-)registration
- Extensive experience with International Uniform ChemicaL Information Database (IUCLID)
Regulatory Strategy
- Identification of required studies to support registration intent, data gap analysis, placement, and monitoring of tests at contract research organizations, review and interpretation of study results, and verification of compliance with Good Laboratory Practice (GLP)/Good Efficacy Practice (GEP) standards
- Preparation of data waivers
- Organisation for Economic Co-operation and Development (OECD) format dossiers
- Litigation support including data compensation evaluations, intellectual property assessment, scientific case preparation, and expert witness testimony
Hazard, Exposure & Risk Assessments for Human Health & Environment
- Extensive experience in all aspects of human health and environmental assessment
- Application of various models, including: Chesar, ConsExpo, UK POEM, FOCUS, and PERSAM
- Quantitative Structure-Activity Relationship (QSAR) modeling, e.g. OECD Toolbox, EPI Suite
- Endocrine Disruptor (ED) assessments in accordance with EFSA/ECHA guidance
- Classification, Labelling and Packaging (CLP)
Industry Note: Bilingual Labeling Support
The Environmental Protection Agency (EPA) is prioritizing the importance of bilingual pesticide labeling to enhance accessibility and safety information for farmworkers. Bilingual labeling requirements were formalized in February 2023 with the passage of the Pesticide Registration Improvement Extension Act (PRIA) V.
The required Spanish translations are available in the EPA Spanish Translation Guide (https://www.epa.gov/pesticide-labels/spanish-translation-guide-pesticide-labeling). These translations must be included on the primary product label on the product container itself. Alternatively, for space restricted labels, a QR code linking to the product SDS (at a minimum) can replace the translated text. The new requirements outline the deadlines by which bilingual labeling must be implemented for each product category from December 2025 to December 2030.
Contact us to discuss how we can ensure your compliance with bilingual labeling requirements.