If a pesticide registered under the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA) is accidentally spilled, must it be reported?
Yes. Accidents, spills, improper application, and improper disposal are within the scope of the release notification provisions of CERCLA and must be reported. EPA's interpretation of the pesticide exemption in CERCLA section 103 covers only the normal application of registered pesticides in ways that are consistent with the pesticides' purpose.