Pesticide Label Changes to Protect Endangered Species

The Environmental Protection Agency (EPA) ensures that pesticides comply with the requirements of the Endangered Species Act (ESA). In 2023, EPA developed a workplan that outlines a new approach to ensure that pesticide registrations and label changes are ESA-compliant without overburdening applicators.

The changes discussed below currently apply ONLY to application of conventional pesticides on agricultural lands. It does not apply to application to turf, ornamentals, greenhouses, or nurseries, nor application of organic pesticides.

Bulletins Live! Two

Bulletins Live! Two (BLT) is an EPA webtool that includes a map of the U.S. marked with clickable, highlighted areas where endangered species or habitat exist and have pesticide application restrictions. These geographic regions are called Pesticide Use Limitation Areas (PULAs). EPA can add new information about species or habitats to BLT without having to reissue product labels.

Many pesticide labels now include language within the Directions for Use section under a heading called “Endangered and Threatened Species Protection Requirements.” This means that the active ingredient for that pesticide has application restrictions where certain endangered species exist in the U.S. The language will state that you are required to visit Bulletins Live! Two before making an application.

On BLT, you will need to save a pdf of the Bulletin you will generate for your spray location, whether it is within a PULA or not. A Bulletin consists of:

• Application Month and Geographic location
• Application Products
• Pesticide Use Limitation Summary Table - current restrictions such as no-spray zones, buffer strip requirements, and timing restrictions during sensitive breeding or migration period.
• Codes and Limitations Table

Currently, the only area of Utah with pesticide use limitation areas is the southwest region, where protections for the Utah prairie dog are in place. In that region, there are restrictions on use of gopher rodenticides, and the Bulletins there will list the restrictions.

How to Use BLT

If stated on the label, go to Bulletins Live! Two (BLT; allow time for the map to load) and zoom into Utah by scrolling on the map. Again, allow time for the highlighted areas to show up.

On the left side of the map, select the month that the application will be made. Note that the Bulletin must include a date that is before the application. It cannot be generated at the end of the season.

On the map, zoom closer to your city/region and click on the location where you plan to make an agricultural pesticide application.

You will notice that the box in the top right of the map that says “Printable Bulletin” will turn from red to green. Click on the green link and download the pdf to your computer to save to your pesticide records.

Alternatively, on BLT, you may enter your zip code or geographic coordinates and the planned date of application. The map will zoom to this location and the “Printable Bulletin” icon will turn green.

Applicator Requirement

If the label requires visiting Bulletins Live! Two, and:

• your farm is located within a PULA:  You must download and save the Bulletin pdf with your farm records, and follow the pesticide requirements in the Bulletin. You may download the bulletin up to six months prior to application.  
• your farm is NOT located within a PULA: You must download and save the blank Bulletin with your farm records, showing that you followed label requirements. You also must check the site again within six months for any additional changes.

For both of the above scenarios, note that the Bulletin is only valid for the Application Month you selected. You must download a new Bulletin for each month you intend to spray a product at a given location. 

For Utah farms not located in the current PULA, we recommend visiting BLT in spring of each year and generating one Bulletin (which will be blank) for each month of the season and saving the pdfs in your records. They can be generated up to six months in advance.

Mitigating Runoff – Points on the Label

Labels may include a number value from 1 to 9 (Points) under the heading, “Mandatory Runoff Mitigation” to reduce the possibility of the pesticide spreading in soils or groundwater. EPA is determining the Point value for each active ingredient by mathematical models of exposure and toxicity impacts to listed endangered species. The more toxic a product, the higher the point value. 

 

Points will NOT apply in the following scenarios of application:

• Application area is less than 1/10th acre
• Application is a spot-spray (backpack spray)
• Application is chemigation in sub-surface drip
• Application is soil injection
• There is a managed area covering at least 1,000 ft located on downslope side of the treated field
  • For example, this could be another agricultural site, road, building, or irrigation source.

How it Works

The EPA has developed a list of farm runoff mitigation measures, each with a corresponding point value. If a point value is provided on the pesticide label, the applicator or farm must match that value via mitigation practices from EPA’s list in order to qualify for applying that pesticide.

Thankfully, the points system should not overly burden Utah farmers. One reason is that ALL applicable agricultural applicators are “credited” with at least 2 points and can apply products labeled with 2 points or less without further action. Read on to see why.

In the western U.S., the climate is arid and most farmland is flat, while in the East, rainfall can be high and farmland can be hilly. Therefore, the risk of pesticides running off the land varies depending on geographic location. To account for this variability, the EPA assigned every county in the U.S. with runoff vulnerability levels from Very Low to High.

Most counties in Utah are assigned Low and Very Low runoff risk levels, which provides point “credits” to farms.

The Utah map shows that counties in southern and central Utah have a Very Low risk for runoff and  are “credited” with 6 points. Farmers there  can apply pesticides with 6 points or less without any further action. Counties in central and northern Utah have 3 credit points, while Davis and Weber counties have 2 credit points.

There may be instances where your credit points are lower than the points listed on the label. EPA’s Runoff and Erosion Mitigation Menu and Runoff Calculator will help determine how many additional points your farm operation can earn in order to use that pesticide. You may already be implementing some common practices that count toward the points on the label, such as:

• Tracking and recording your farm practices = 1 point
• Working with a technical expert (such as USU Extension) = 1 point
• Vegetative barriers = 1 to 3 points
• Contour farming (growing crops with rows parallel to the slope) = 2 points
• Drip or micro-sprinkler irrigation = 2 to 3 points

Even if your farm meets the required mitigation points, it is still important to review the Mitigation Menu to ensure full compliance with the specific measures required for your product and location.

Points will NOT apply in the following scenarios of application:

• Application area is less than 1/10th acre
• Application is a spot-spray (backpack spray)
• Application is chemigation in sub-surface drip
• Application is soil injection
• There is a managed area covering at least 1,000 ft located on downslope side of the treated field
• For example, this could be another agricultural site, road, building, or irrigation source.

Mitigating Spray Drift

Standardized (baseline) spray drift mitigation requirements will be included on all pesticide labels as they have in the past, and these apply to all applications.

In addition, some labels (depending on their toxicity) will include application buffer requirements under the heading, “Mandatory Spray Drift Management” to protect non-target areas from spray drift. If the downwind side of your farmland is adjacent to a non-target area (typically described on the label), then you must follow the buffer-width requirement. If the downwind side of your farmland is adjacent to managed areas (roads, hedgerows, mowed grass, ditches, canals, pasture, or rangeland), you do not need to worry about the buffer.

Buffer widths will be clearly specified on the pesticide label and may range from 0 to 160 feet for ground applications. There are mitigations that you can implement (or may already have) that will reduce the width requirement of the buffer.

For example, one scenario to reduce the buffer width requirement is when the humidity at the time of application is less than 60%, the width of the buffer can be reduced by 10%. For example, if a 20-foot spray buffer is required, humidity is low, and the downwind side of your farm is near a non-target area, the buffer should be 18 feet. This 10% buffer-width reduction will apply to most applications made in Utah.

For additional mitigations and farm practices to reduce the buffer width, the EPA provides a Spray Drift Buffer Calculator. Some of these practices include reducing the application rate, using larger droplet sizes, using a hooded sprayer, and using a drift-reducing adjuvant.

Summary for Applicators

• Always read the complete pesticide label.
• If a label directs you to Bulletins Live! Two (located under a heading called Endangered and Threatened Species Protection Requirements), be sure to download and save a Bulletin at least once per season or before each application.
• Meet required runoff points by knowing your county’s credit points and using approved mitigation practices.
• If a non-target area listed on the label is adjacent to the downwind edge of your farm, maintain a buffer zone and use approved spray drift-reduction methods.

FAQ's

Who does this apply to?
The updated requirements apply to applicators of conventional agricultural-use pesticides, including farmers, commercial applicators, and crop advisors. However, we recommend all pesticide users stay informed.

What is considered an agricultural use?
Any land planted with row crops, specialty crops, orchards, vineyards, Christmas trees, sod farms, and flooded crops.

How do I know if a pesticide has Endangered Species Act (ESA) restrictions?
The label will include the requirements under the “Directions for Use” section.

Do I need to change how I apply pesticides right away?
Not necessarily. Pesticide labels with runoff mitigation points and spray drift language will be updated gradually over time as products go through the registration review process. 

Do the Bulletins change?
They can. They may be updated as new scientific information becomes available or as species statuses change. EPA requires applicators check and record Bulletins on BLT for the application area every six months at a minimum, or more frequently if you're applying in sensitive areas or during key seasons.

What products are included in Utah’s single PULA?
As of 2025, there is one type of pesticide use limitation area (PULA) in Utah to protect the Utah prairie dog. This PULA is located in the southwest part of the state. There are eight active ingredients with restrictions in the PULA, and they are all applied as gas cartridges. Product names include The Giant Destroyer, Smoke ‘Em, Revenge Rodent Smoke Bomb, Amdro Gopher Gasser, and several others.

Where can I find instructions on using Bulletins Live! Two?
EPA provides a BLT tutorial with a link to pdf instructions and a Q&A page.

Do runoff points apply to every pesticide application?
No. Runoff points are not needed for applications on less than 1/10th of an acre, backpack applications, chemigation in sub-surface drip, soil or tree injections, or if there is a 1,000-foot-wide managed area on the downslope edge of the treated field (which includes untreated portions of the field, roads and other paved or gravel surfaces, mowed or bare ground, unoccupied buildings with walls and/or roof, hedgerows and conservation land, and on farm irrigation ponds).

Where does the buffer need to be located to reduce spray drift?
When a buffer is required, it should be located at the downwind edge of the sprayed field.

What can be counted as a buffer?
A buffer can be a managed area immediately adjacent to the treated field, such as an untreated portion of the field, roads and other paved or gravel surfaces, mowed or bare ground, unoccupied buildings with walls and/or roof, hedgerows and conservation land, and on-farm irrigation ponds.

Does Utah have endangered or threatened species?
Yes, approximately 45. These include birds such as the California condor and Gunnison sage-grouse, fish such as bonytail and humpback chub, plants such as dwarf bear-poppy and Navajo sedge, insects such as the nokomis fritillary, mammals such as the black-footed ferret and Utah prairie dog, and reptiles such as the desert tortoise.

What happens if I do not follow these ESA requirements?
If you fail to follow label statements or an applicable Bulletin, whether that failure results in harm to a listed endangered or threatened species or not, you will be subject to enforcement under the misuse provisions of FIFRA section 12(a)(2)(G). Unauthorized take (killing) of listed species will subject you to enforcement under the ESA.

Resources for Understanding ESA Pesticide Label Changes

Bulletins Live! Two (BLT) is the geographic database to determine pesticide use limitation areas and print Bulletins (extensions of a pesticide label) for the pesticide to be applied. Note that the page may load slowly.

Endangered Species Protection Bulletins provides instructions for using BLT

Endangered Species Workplan is EPA’s guiding document to ensure pesticides do not threaten endangered species.

Pesticides and Endangered Species Educational Resources Toolbox catalogs educational resources including guidance documents, handouts, presentations, informational webinars, and other resources relating to EPA’s endangered species work.