Mitigation Tracker

******* CURRENT RELEASE INFORMATION *******

The current version of the ESA Mitigation Tracker available is ver. 0.2 (Beta) and was released on 10/24/2025.  

********** DISCLAIMERS ********** 

INFORMATION IN THIS SPREADSHEET IS NOT A SUBSTITUTE FOR THE LABEL AND CANNOT BE USED FOR PESTICIDE APPLICATION INSTRUCTIONS.

The information provided on this website is for general informational purposes only.  The FIFRA Endangered Species Task Force (FESTF) makes no warranties or representations about the completeness, reliability, or accuracy of this information. Any reliance you place on such information is strictly at your own risk. 

Pesticide applicators should not rely on this spreadsheet to identify use requirements on any product labels, as this spreadsheet does not include complete directions, restrictions, and/or mitigations that appear on each label. Pesticide applicators should fully read the label for the products they intend to use prior to application; if applicators have any questions on labels they should reach out to their local agricultural extension specialists (https://extension.org/find-cooperative-extension-in-your-state/) or relevant state regulatory officials (https://npic.orst.edu/reg/state_agencies.html).

This spreadsheet is an unofficial compilation of information contained in decision documents issued by EPA, FWS, and NMFS and published online at www.regulations.gov (with a few noted exceptions).  The information contained in this spreadsheet is copied from those official documents. This spreadsheet may not contain the most current document.  Always consult the Docket ID for each action for the most current information.

The information in this spreadsheet is intended solely to facilitate longitudinal and categorical comparisons of mitigations derived from risk assessments focusing on exposure to species that are listed under the Endangered Species Act ESA). There is uncertainty as to when these mitigations will actually appear on pesticide labels available to users in the marketplace. In the spreadsheet we distinguish between "Proposed" decisions from EPA, which are generally followed by public comments and revisions, and "Final" decisions from EPA (or the Services), which are generally followed by the issuance of product labels.

Description of selected column headings:

Chemical class: analogous to chemical "family" or "group," and according to IUPAC (the International Union of Pure and Applied Chemistry) or Chemical Abstracts Service (CAS).

RAC Group: according to the relevant Resistance Action Committee (RAC) as follows:

FRAC - FRAC Code List (2024): Fungal control agents sorted by cross-resistance pattern and mode of action1

HRAC - WSSA/HRAC Herbicide Site of Action Classification List, last updated May 5, 20212

IRAC - IRAC Mode of Action Classification Scheme, ver.11.4, May 20253

Registration Category: broadly determined by which Environmental Protection Agency (EPA) Office of Pesticide Programs (OPP) division has authority over the decision, with "conventional" decisions going through the Pesticide Re-evaluation or Registration Divisions (PRD/RD), and "non-conventional" decisions going through the Antimicrobial or Biopesticides and Pollution Prevention Divisions (AD/BPPD).

Decision Status: designated by EPA or the appropriate service, "Proposed Interim Decisions" (in the case of registration review) or "Proposed Decision" (in the case of new active ingredients / uses) are considered to be "Proposed," while "Interim Decisions", "Decisions," or label amendments following the issuance of Biological Opinions (BiOps) are considered to be "Final." To emphasize that for "Proposed" decisions there are not changes imminent to product labels we have shaded in grey the rows for active ingredients with these draft decisions that are still subject to public comment periods, revisions following public comment periods, or are otherwise still subject to changes that will be represented by a final decision document of some sort.

Use sites: taken directly from the decision document, but aligned with the suggested terms in EPA's "OPPEL Smartlabel Vocabulary Guide"4

Application equipment, method and type: taken directly from the decision document, but aligned with the suggested terms in EPA's "OPPEL Smartlabel Vocabulary Guide" 4these

ESA Consultation Triggered: when EPA is able to make a "No Effects" (or "NE") determination for a given active ingredient then it is not obligated (per the Endangered Species Act) to initiate consultations with FWS and / or NMFS; in the case of "NE" determinations this cell will state "No." When EPA makes a "May Affect" determination it is required to initiate consultation with the Services in the form of informal (when EPA arrives at "Not likely to Adversely Affect" or "NLAA") for species with "MA" determinations) or formal ((when EPA arrives at "Likely to Adversely Affect" or "LAA") for species with "MA" determinations") consultations.

Non-reducible buffers: these are intended to represent buffers requirements that are on labels to mitigate risks to human health (e.g., non-occupational/bystanders) or non-listed species (e.g., general buffers to aquatic habitat). These buffers are "baseline" label buffer requirements derived from a more typical FIFRA risk assessment process and generally not reducible, i.e., not eligible for the reduction options that are available for additional "Ecological Buffers" to mitigate risks specifically for listed species.

Reducible drift buffers: these spray drift buffers are explicitly required to reduce exposure to listed species or their critical habitats, and stem from EPA's implementation of the "Strategy approach" and associated listed species-specific risk assessments. Requirements for these buffers include options to reduce the width of the buffer, either through options on the label itself or by directing the user to EPA's Mitigation Menu website for drift buffer reduction options. 

PULAs (No/Yes): note that all decisions with "NE" calls will not have PULAs and so "N/A" is denoted in these cells; for decisions with "May Affect" determinations by EPA (i.e., "NLAA" or "LAA") there will be either a "No" or "Yes" in these cells. For cells with a "Yes" visit EPA's Bulletin Live! Two Webpage for more information.5

  1. FRAC Code List 2024: Fungal control agents sorted by cross-resistance pattern and mode of action
  2. 2024 HRAC Global Herbicide MoA Classification List
  3. IRAC Mode of Action Classification Scheme, ver. 1.4, May 2025
  4. EPA's "OPPEL Smartlabel Vocabulary Guide"
  5. EPA's Bulletins Live! Two

Release schedule:
  -  BETA versions (i.e., ver. < 1.0) will be released throughout Fall 2025 to facilitate feedback.
  -  Ver. 1.0 will be released 1/1/2026, with subsequent updates to follow as described below.

Update schedule:
  -  Conventional pesticides will be updated quarterly on the first day of the Fiscal Year (FY) quarter.
  -  Non-conventional pesticides will be updated twice a year to correspond with FY quarters 2 and 4.

Next update (anticipated release date  of 1/1/2026) will include:

  • Standardization of application equipment, method and type descriptions

If you have any questions - or want to report an inaccuracy in the data, please contact Cameron Douglass, technical consultant for FESTF ([email protected])

Mitigation Tracker Public

Mitigation Tracker - Public