EPA Releases Reports As Part Of Agency Efforts To Optimize Pesticide Registration Processes

On October 9, 2025, as part of the reauthorization mandates of the Pesticide Registration Improvement Act of 2022 (PRIA 5), the U.S. Environmental Protection Agency (EPA) announced the availability of two reports prepared from the result of third-party audits that evaluated pesticide registration processes and functions conducted by EPA. According to EPA, the first report provides the results of the audit that focused on assessing the operational performance of EPA's Office of Pesticide Programs (OPP) and provides recommendations for improvement. The second report evaluates the gaps in OPP's training and education necessary to support its regulatory mission and implementation of PRIA 5. EPA states that it is sharing this information in an effort to improve the registration process for pesticide registrants and other stakeholders and to align with Administrator Zeldin's goals for enhanced efficiency and accountability. An independent workforce assessment to evaluate the adequacy of staffing resources, also required under PRIA 5, will be conducted next year.

Operational Performance Report

EPA states that the Operational Performance report was completed after the review of more than 100 process documents and interviews with nearly 80 EPA staff and registrants. This assessment evaluated OPP's core registration and review functions, including initial content screens and preliminary technical screens. It also included information on EPA's efforts to reduce backlogs of PRIA and non-PRIA registration submissions.

According to EPA, the report recognizes OPP's efforts in improving core operations, such as replacing its outdated internal systems with a modern internal tracking system. The assessment identifies challenges and "key barriers" that continue to impact efficiency and predictability. The barriers identified include: (1) underutilized tools and poor data quality; (2) process fragmentation and unclear ownership; and (3) limited guidance and knowledge gaps. The report states that these barriers span multiple functions and organizational levels and create ripple effects across application reviews, decision-making, and coordination, and recommends that these challenges may be addressed with adoption of better data and decision-tracking systems that are being implemented, although implementation is currently hindered by budget limitations. The report identifies a need for more standardized training and guidance to ensure uniform review procedures. For example, the analysis mentions that many reviewers "rely on outdated templates or informal peer support to learn key procedures," leading to inconsistent decisions and higher error rates.

The report goes on to identify what are called "strategic levers for improvement" — automating workflows and modernizing technology (data systems); driving standardization across processes; and what is described as "fostering a customer-focused culture."

Training Gaps Report  

As does the Operational Performance report, the Training Gaps report states that inconsistent decisions and delays would be improved by better training of staff on policies and procedures to foster uniform and consistent decisions. Under PRIA 5, OPP is required to administer internal training and education programs relating to its regulatory responsibilities and policies. The training gaps review included analysis of the inventory of existing pesticide training materials, feedback from interviews with internal OPP points of contact, workflow process maps, and insights from External Stakeholder Feedback Sessions. The training gaps report identified issues, which include difficulty locating training materials, limited cross-divisional understanding, and inconsistent workflow management.

EPA states that more than 200 distinct training actions and more than 40 supporting non-training actions are documented as part of the report and states that the actions identified largely aim to reduce reliance on informal mentoring, improve cross-divisional coordination, and strengthen communication with applicants and registrants by improving consistency, efficiency, and transparency. As required in PRIA 5, OPP plans to release a solicitation for grant proposals to continue the analysis of training needs and delivery.

Next Steps

EPA states that one of its top priorities is to reduce the backlog of pesticide regulatory actions pending review. According to EPA, since January 20, 2025, EPA has decreased this backlog by over 5,000 actions.  

EPA states it is reviewing the reports to consider how to best implement the recommendations and remains committed to "further process improvements and IT efforts to modernize key pesticide registration functions, reduce the pesticide registration backlog, and implement gold-standard science."  

Commentary

EPA's ability to meet PRIA deadlines is a long-standing sore point for the registrant community, whose members pay required PRIA fees and then face an unreliable prediction of when the PRIA action might be completed. For what are called "non-PRIA" amendments (historically referred to as "fast-track amendments") — where the submitter must wait for EPA review and approval of product changes that do not need "science review" (e.g., minor formulation changes and label changes) — hundreds of such actions have seen long delays and no declared deadline.

The design of PRIA from the start was to impose a fee to share the cost of science review work; if no science review activities were necessary, no PRIA fee would apply, nor would the review be a PRIA action. As a non-PRIA action, however, no PRIA deadline applies to such a submission. Without a PRIA deadline, such actions, until recently, languished in OPP since there were many backlogged actions subject to a PRIA deadline that were thus considered a higher priority for completion. OPP has devoted significant effort to reduce this non-PRIA action backlog and announced plans to further reduce this category by 25 percent by September 30, 2025.

Delays in PRIA actions have many causes, as outlined in the consultant reports. In addition to any internal hurdles, the ability to meet deadlines continues to be hindered by a lack of resources that are nominally required in the PRIA legislation to be provided by Congress as part of EPA's appropriated budget. In recent years, the "required" nominal share of appropriations have fallen because of Congress adding a proviso to the legislation that whatever the amount provided will be considered to meet the funding requirement. Among other factors, this had led to a significant decline in the staffing level of OPP generally, from over 600 positions in fiscal year (FY) 2021 to an estimated less than 500 for FY 2025. Some additional positions from EPA's 2025 reorganization plan are expected to bring additional staff to OPP.

Encountering uncertain completion dates is frustrating for the submitter since even a short regulatory delay can delay an entire season of use for the pesticide. Also, delays of many months can result in a delay of two (or more) growing seasons before a new product or formulation is available to growers.

The Operational Performance report states that as a regulatory agency, the OPP staff can improve "customer focus," but it has to maintain its role as a regulator to ensure applicable regulatory requirements are met before any registration approval. EPA has promised to continue to work on significantly reducing the backlog of pending submissions — and improve PRIA on-time performance generally — and the two reports and implementation of the recommendations are part of that effort.

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