Profile

Keith has more than 25 years of private sector and government experience in environmental law related to chemical substances regulation, biopesticides, and genetically engineered organisms. He is a former Director of the Biopesticides and Pollution Prevention Division (BPPD) in the U.S. Environmental Protection Agency’s (EPA) Office of Pesticide Programs (OPP). Prior to becoming Director of BPPD, Keith served in EPA's Office of General Counsel (OGC), first as a staff attorney, then as an Assistant General Counsel where he supervised attorneys providing legal counsel to programs in EPA's Office of Air and Radiation, Office of Pesticide Programs, and the Office of Research and Development.

Keith’s practice focuses on the regulation of chemical substances and genetically engineered organisms. He counsels clients on legal and regulatory requirements applicable to agricultural chemical products and genetically engineered microbes, insects, and plants that are regulated by EPA, the U.S. Food and Drug Administration (FDA), and the U.S. Department of Agriculture (USDA).

Keith counsels and advises his clients using his breadth of knowledge on a variety of statutes, including the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA), the Federal Food, Drug, and Cosmetic Act (FFDCA), the Toxic Substances Control Act (TSCA), the Plant Protection Act, and the National Bioengineered Food Disclosure Standard.

Experience

Representative Matters

  • Provided to a major agribusiness company a comprehensive analysis of Federal and State statutory, regulatory, and common law requirements and principles applicable to the development, sale, and distribution of genetically engineered food crops in the United States.
  • Has counseled numerous companies on the complex regulatory scheme applicable to genetically engineered crops, insects, and animals in the United States.
  • Has counseled numerous companies on EPA's regulatory requirements under FIFRA that are applicable to biopesticides and biostimulants. 
  • Has counseled numerous companies on EPA’s regulatory requirements under TSCA that are applicable to genetically engineered microorganisms.
  • Conducted a comprehensive assessment of the environmental, health, and safety (EHS) programs of a Fortune 500 company and provided recommendations to enhance the company’s EHS effectiveness.
  • Provided legal counsel to a number of government agency clients, including BPPD, the Office of Air and Radiation, and the Office of Research and Development.
  • Extensive experience serving as EPA's lead attorney on highly technical issues of first impression under FIFRA, TSCA, and the agency’s Radiation Program.
  • Primary attorney providing advice to the Office of Pesticide Programs in a number of cases where unapproved varieties of genetically engineered foods were found in commerce.
  • Provided almost exclusive legal support to the Office of Pollution Prevention and Toxics (OPPT) in responding to a petition to regulate formaldehyde under TSCA.

Professional Experience

  • Director, Biopesticides and Pollution Prevention Division, U.S. EPA’s Office of Pesticide Programs
  • EPA’s Office of General Counsel
    • Staff Attorney
    • Assistant General Counsel

Affiliations

  • American Bar Association (ABA), Section of Environment, Energy, and Resources
    • Vice Chair for Membership, Pesticides, Chemical Regulation, and Right-to-Know Committee
  • American Association for the Advancement of Science (AAAS)
  • American Chemical Society
  • Board of Representatives, Council for Agricultural Science and Technology (2018-2021)
  • Advisory Committee, World BioProtection Forum (WBF) (2021-Present)

Credentials

Education

J.D., Georgetown University Law Center

M.S., California Institute of Technology

B.S., Jackson State University 

Bar and Court Memberships

  • District of Columbia Bar
  • Maryland Bar

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