ABSTRACT
The concept of an ecological baseline can be found in a number of places in Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA). Specifically, the standard for registration under FIFRA is designed to address a large array of ecological, as well as human health, concerns. FIFRA also contains provisions that are compatible with the ecological concept of adaptive management. The emergency exemption provision of section 18 of FIFRA authorizes Environmental Protection Agency (EPA) to grant an emergency exemption to any state or federal agency under emergency conditions. EPA has established that DDT is toxic to non-target insects and animals, persistent in the environment, mobile and transferable and that it builds up in the food chain. One of FIFRAs most significant shortcomings that contributes to its failure to adequately protect ecological resources is its cost/benefit approach to registration and cancellation. FIFRAs cost/benefit approach also raises concerns regard to pesticidal genetically modified organisms (GMOs).
