EPA's Central Data Exchange (CDX) Available for Pesticide Establishment Reporting

The US Environmental Protection Agency (EPA) has been working to shift its data collection and reporting functions from paper to electronic submissions.  On December 18, 2015, EPA announced that pesticide establishments could use EPA's Central Data Exchange, or CDX, to submit their annual reports.  EPA will for the time being continue to accept paper copies of the report.  The CDX for pesticides is called the Pesticide Submissions Portal (PSP). 

Sections 7 and 17 of the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA) require pesticide producing establishments, which includes establishments that produce or distribute a pesticide, an active ingredient, or a pesticide device, to submit annual pesticide establishment production reports, EPA Form 3540-16, by March 1 of each calendar year. The report must be filed even in cases where the pesticide establishment had no pesticide or device production. All reporting can be done by mail, or and now can be submitted online electronically.

EPA held four public webinars explaining the CDX registration and report submission process in December and may hold additional webinars in January. The Agency has also posted information on reporting requirements for 2015, a PDF version of EPA Form 3540-16, and contact information for pesticide establishment coordinators on its Pesticide Establishment webpage. 

Registering for PSP in CDX for the pesticide program is different than that which has been in use for the Office of Pollution Prevention and Toxic Substances for some time.  Both registrants and consultants can file reports. The reports must be completed online and cannot yet be completed offline to be uploaded. The Registration User Guide for PSP is available here. Contact the CDX Help Desk's toll-free line at 888-890-1995 or 970-494-5500 for callers from Puerto Rico and Guam for assistance. 

Establishment reports need to be submitted starting this month. 

Contact Keller and Heckman LLP at pesticide@khlaw.com if you have any questions on reporting requirements under FIFRA, the CDX registration process, electronic report submissions, need assistance in preparing the reports, or any other FIFRA related issues.