On April 29, 2025, the EPA published its final Insecticide Strategy, following the release of the draft version in July 2024. The insecticide strategy is part of a broader suite of regulatory efforts, including the previously released Herbicide and Rodenticide Strategies and the upcoming Fungicide Strategy, aimed at improving compliance with the Endangered Species Act. These strategies stem from a settlement between the EPA and environmental groups in a lawsuit coined the "Megasuit," and represent an attempt by the EPA to preserve access to key pesticide chemistries while minimizing risks to federally listed species. While resulting strategies produced by the EPA are complex and may require time to learn and implement effectively, they offer a more balanced approach to pesticide use and endangered species protection than before the creation of the EPA's new strategy.
The final Insecticide Strategy largely mirrors the format and structure of the Herbicide Strategy and only contains minor revisions from the initial draft Insecticide Strategy. For additional background, readers are encouraged to consult previous IPR articles on the Herbicide Strategy and Draft Insecticide Strategy, as well as this excellent explanatory presentation by Dr. Aaron Hager (UIUC Crop Sciences Department) on the framework of the Herbicide Strategy.
Basic Structure
The EPA's Insecticide Strategy is built in a three-step framework as follows:
Identify potential population-level impacts
The EPA is evaluating how insecticides may realistically impact threatened and endangered species at the population level. This step involves a more realistic interpretation of toxicity data, chemical endpoints, and exposure effects in agricultural settings and the relevant listed species.
Develop mitigation measures to reduce off-target movement
Through this step, the EPA defines a set of mitigation practices to reduce spray drift, runoff, and erosion. The agency categorized runoff and erosion mitigations in the following ways:
- Pesticide Runoff Vulnerability and Field Characteristics – exp. Field slope, mitigation tracking, and conservation programs
- Application mitigations – exp. Rate reductions, soil incorporation, and tillage practices
- In-field mitigations – exp. Tillage practices, cover crops
- Field adjacent mitigations – exp. Grassed waterways, riparian areas, and vegetative filter strips
- Runoff/discharge capture systems – exp. Water retention and drainage systems
Each mitigation is assigned a point value called "mitigation relief points." Insecticide labels will begin to require applicators to accumulate a minimum number of points per individual field before applying a product. The necessary points correspond to the level of risk they pose to endangered species, described as follows:
- Low risk: up to 3 points
- Medium risk: up to 6 points
- High risk: up to 9 points
The maximum number of points required should be nine, even if the application requires additional points from being in a PULA, as determined through the Bulletins Live! Two website (See Step 3). This mitigation points system mirrors the structure introduced in the Herbicide Strategy.
Additionally, spray drift mitigations are necessary through the implementation of spray drift buffers. Buffers apply to the downwind edge of the field at the time of the application and are dependent on the type of equipment that is performing the application. Maximum buffers are set at "300, 85, and 100 ft for aerial, airblast, and ground applications, respectively" according to the Insecticide Strategy. Managed areas such as roads or other agricultural fields can be subtracted from the maximum spray drift buffer. Applicators can also reduce buffers through mitigations specific to the application equipment. Each mitigation implemented will reduce the spray drift buffer by a specified percentage of the maximum spray drift buffer determined by the product label.
Designate Pesticide Use Limitation Areas (PULAs)
Lastly, the EPA has identified Pesticide Use Limitation Areas (PULAs) for special mitigations. These areas are in specific geographical zones requiring additional protections due to the likely presence of listed species, including designated critical habitats. PULA creation will protect species like the Karner blue butterfly or the American burying beetle, which were previously native to Illinois and are now on the Endangered Species List. PULA requirements include increased relief points, spray drift buffers, or additional in-field requirements based on crop type, especially when an endangered species may exist within the confines of a field because of that crop. For example, restrictions may exist in some areas on cucurbit applications during or before flowering to prevent exposure to an at-risk pollinator. These in-field use restrictions within PULAs are unique to the Insecticide Strategy and not part of other EPA pesticide strategies.
How the Implementation Will Work
Over the next several years, insecticide product labels will begin incorporating elements of the EPA's Insecticide Strategy. The most consistent location that will receive changes is under the "Endangered Species Protection Requirements" section of the label, although location and format may vary between products. The label may include the basic mitigation relief points that the applicator must meet per field before applying a product. Each product label will consist of a link or QR code that will direct applicators to the Bulletins Live! Two website, which will help determine if a given field falls within the confines of a PULA. Bulletins Live! Two will require the location, date of application, and the products’ EPA registration number, and will provide information on any PULA requirements.
Once a field's PULA status is determined, the applicator must consult the Mitigation Menu website, a companion website that outlines all approved mitigation practices and their corresponding point values. Once again, mitigations must be calculated field by field, based on site-specific characteristics. To streamline this process, the EPA has provided a spray-drift-and-runoff-mitigation-calculator , which helps applicators estimate point totals and additional requirements such as spray drift buffer zones. Because some mitigation practices involve advanced planning, it is critical to plan mitigations ahead of the growing season. For regulatory flexibility, EPA allows applicators to rely on the information from the Mitigation Menu and Bulletins Live! Two for up to six months after accessing, enabling some lead time in decision making.
Even after meeting mitigation point requirements, spray drift buffer requirements may necessitate further calculations. These buffers typically apply to the downwind edge at the time of application. However, wind direction is difficult to predict in advance, so applicators may need to plan for buffers on multiple field edges. Spray drift buffers particularly apply to fields adjacent to "unmanaged" areas. In contrast, field edges bordering "managed areas" may not require a buffer. The spray-drift-and-run-off-mitigation-calculator will be integral in calculating buffers and recognizing where they are not necessary. The required spray drift buffers will appear with label changes or on Bulletins Live! Two (not all insecticides require a buffer). If a managed area lies between the treated field and an unmanaged area, its width can be subtracted from the distance of the buffer needed. Then, refer to the EPA's Mitigation Menu for options that further reduce the buffer distance.
Spray buffer mitigation example:
A ground boom application requires a 100-foot spray buffer from an unmanaged aquatic area like a stream. If there is a 25-foot-wide road (managed) between the field and the stream, the effective buffer drops to 75 feet (100 ft – 25 ft =75 ft). If the product label allows adjustment of spray droplet size and the applicator increases droplet size from "fine" to "medium," a 75% reduction may be applied to the remaining buffer:
- 75 ft x 0.75 = 56.25 ft
- 75 ft – 56.25 ft = 18.75 ft final required buffer
Suppose wind direction changes after the initial application, and a different side of the field becomes downwind. In that case, the applicator may re-enter and spray areas that were previously within the buffer zone, assuming all label and mitigation requirements are still met.
Final Thoughts
When I first wrote about the draft Insecticide Strategy in October 2024, I was concerned about the complexity and potential burden it could place on agricultural applicators. However, after better understanding the finalized strategy, the EPA has done a reasonable job balancing the dual priorities of protecting critical insecticide chemistries and complying with the Endangered Species Act to safeguard at-risk species.
While the learning curve will be steep, the strategy's built-in flexibility should help applicators adapt during the early implementation phases. Fortunately, the Insecticide Strategy will be applied gradually, with changes appearing as product labels are updated. As the rollout continues, more detailed guidance and support should become available. In the meantime, Illinois applicators should regularly check for updated insecticide labels containing additions for relief point requirements, monitor for state or university educational programs, which will be critical in supporting a smooth transition, and familiarize themselves with the EPA resources referenced throughout this article.
Photo credit: Karner blue butterfly, Catherine Herms, The Ohio State University, Bugwood.org
ABOUT THE AUTHOR: John Schepis provides subject matter expertise and training in pesticide safety with an emphasis on entomology.