Environmental Protection
Agency
Pesticide Programs
Washington, DC 20460
FIFRA Confidential
Business Information
Security Manual
                                  i

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FIFRA Confidential
Business  Information
Security Manual
      Revised April 24, 1981
  U.S. ENVIRONMENTAL PROTECTION AGENCY
Office of Pesticide Programs  (TS-757C)
     Washington, D.C. 20460

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                            OPP SECURITY MANUAL

                             TABLE OF CONTENTS
SECTION I.

SECTION II.
SECTION III.
SECTION IV.
SECTION VI.
INTRODUCTION

SCOPE AND DEFINITIONS

1.    Documents Covered by this Manual
2.    Definitions

RESPONSIBILITIES

1.   Division Directors
2.   Document Control Officers
3.   Document Control Assistants
4.   Second Line Supervisors
5.   First Line Supervisors
6.   Individuals
7.   Office of the Inspector General

PHYSICAL SECURITY
                1.  General Rules
                2.  Access to CBI Documents
                3.  Safeguards During  Individual Use of CBI

SECTION V.      COPYING AND DESTRUCTION

                1.  Policy on Making Copies  of  Confidential
                    Documents
                2.  CBI Copying  Facility
                3.  Authorized Document Users
                4.  Procedures for  Reviewing and Copying
                    CBI Documents
                5.  Destruction  Policy
                6.  Precautions  Against Unauthorized Disposal,
                    Salvage, or Copying
TRANSFER OF CBI MATERIALS

1.  Between OPP Divisions
2.  From OPP to OPTS
3.  From OPP to Other  Parts  of  EPA  and
    Other Federal Agencies
4.  From OPP to Higher Governmental Units
5.  From OPP to a Contractor, Subcontractor
     or Consultant
6.  Telecommunications
7.  Meetings Involving Discussion of CBI
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SECTION VII.   COMPUTER SECURITY

               1.  The Resource Access Control Facility
               2.  Encryption of Data Files
               3.  Physical Security

SECTION VIII.  CBI TYPING PROCEDURES

               1.  Documents Typed Internally
               2.  Documents Typed on Contract
SECTION IX.
DIVISION SECURITY PROCEDURES
Page

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APPENDICES

Appendix A.


Appendix B.

Appendix C.

Appendix D.

Appendix E.

Appendix F.

Appendix G.

Appendix H.


Appendix I.


Appendix J.
Access Authorization Forms and Confidentiality
Agreements

Conference Proceedings Forms

CBI Cover Sheets

User Sign Out Log

Sample Transmittal Forms

Request for Copying CBI material

Destruction Approval Form

Document Control Officer (DCOs) and
Document Control Assistants

Interagency Memorandum of Agreement
(for transfer of CBI)

Persons Authorized to Request CBI Materials from OPP
Document Center
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                                 SECTION I
                               INTRODUCTION
Confidential Business Information  (CBI) is;

"any information in any form received by EPA from any person, firm,
partnership, corporation, association, or local, state, or Federal agency
which contains trade secrets, formula, commercial or financial information,
and which has been claimed as confidential by the person submitting it  and
which has not been legally determined to be non-confidential by the EPA
General Counsel under the procedures in 40 CFR Part 3, Subpart B".

[NOTE, at present all non-published data received from a registrant under
FIFRA by OPP will be considered as CBI and treated as such.]

While FIFRA establishes the need and basis for the Agency to receive  and
use this information for official purposes; it also provides that CBI is
entitled to protection from unauthorized release, and specifies penalties
that can be imposed upon employees who are found to be responsible for
disclosure of this information to unauthorized persons.

As employees of the Office of Pesticide Programs, you handle thousands  of
documents that contain CBI in connection with your official duties.
Because your handling of these documents is complicated by needs  to provide
temporary storage, secure routing, judicious copying, and careful
accountability for so many documents, we have prepared a manual of
procedures that provides a reasonable amount of discipline and uniformity
for these activities.

This Security manual is intended to prescribe uniform standards that  will
be met within OPP to guard against inadvertent release of CBI to
unauthorized persons.  We have also provided for the development  and  use of
specific procedures by the Divisions to meet their specific needs, with the
understanding that these procedures must meet the OPP standards.  As  an
incentive for compliance, various disciplinary measures are provided  for
should these procedures be neglected.  Much more strict penalties may of
course be imposed for willful violations that result in the compromise  of
CBI.  Your attention is directed to the section on scope and definitions
for a discussion of the various types of documents and the treatment  to be
afforded to each.
                                      -1-

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This Security manual was prepared by a task force of representatives from
all OPP divisions.  It provides for document handling and other needs that
are unique to OPP, while incorporating some features of the TSCA  Security
Manual.  It contains guidelines for handling Confidential Business
Information on the work site during routine business operations,  and for
routing CBI between official users.  Safe storage facilities, procedures
for copying and contract typing, document accountability and release,
computer security, and designation of special program officials and their
responsibilities are included.  This manual is intended to be an  updatable
reference, and will be changed as needed.

As persons who are given access to these documents, you are expected to
exercise care in handling them.  This manual is a guide, but can  only help
afford the protection described in FIFRA.  Your good faith efforts are the
key.  I urge you to study this security manual and the procedures that are
specific to your division, and to work closely with your colleagues and
designated officials to make this program work.
                                            Edwin L. Johnson
                                      Deputy Assistant  Administrator
                                        for Pesticides  Programs
                                     -2-

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                                SECTION II

                          SCOPE AND DEFINITIONS

This manual specifies certain standards and procedures that deal with
protecting documents that contain CBI from inadvertent release to
unauthorized persons.  These types of documents are described below.  In
certain circumstances, documents (or parts thereof) that are normally
afforded protection may be released.  Specific criteria and procedures for
establishing the releasability of documents are covered in a companion
document (OPP Document Release Policy) which will be published separately.
While the specifics of document release are therefore beyond the scope of
this manual, a general observation is appropriate here:  that decisions to
release documents often involve review by the ISB FOI staff, Division staffs
and Directors, the DAA, and OGC.  Individuals are therefore cautioned
against making any unilateral determinations to release the documents
described below.

1.   Documents Covered by this Manual

     A.   Documents that contain information specifically protected by
          statute (FIFRA Section 10(d)(1) and (2)) must not be released,
          except as provided for by Section 10.  These documents are
          classified as CBI because they contain confidential statements of
          formula, manufacturing process, and quality control information,
          testing methods to identify inert ingredients, or production data.

     B.   Documents that contain safety and efficacy data ("Company Data"
          is the term used in OPP) that are submitted by registrants must
          be protected from release until such time as current court suits
          are resolved and the releasability of this data thereby finally
          determined.

     C.   Documents received by OPP from other organizations  (associations,
          federal, state, or local agencies) who claim they contain CBI,
          must be protected from release.

     D.   Documents developed by OPP or its contractors must  be protected
          from release until a determination is made that referenced or
          contained CBI has been removed.

     E.   Documents that are developed in OPP to express scientific or
          regulatory positions must be protected from release until a
          determination is made on their releasability.
                                     -3-

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2.   Definitions

     A.   Access;  the ability and opportunity to gain knowledge of
          Confidential Business Information in any manner whatsoever.

     B.   Archives;  any collection of information held in common by an
          organizational group, i.e./ data files under the care of any
          branch, section, division, etc.

     C.  Archiving;  maintaining a set of records or data.

     D.   Authority;  The Federal Insecticide, Fungicide and Rodenticide
          Act (FIFRA), as amended in 1978, provides in Section 7(d) and
          Section 10 that material may be entitled to treatment as trade
          secret or proprietary data.  Section 12(a)(2)(D) makes it
          unlawful for any employee to use to his own advantage or to
          reveal any confidential information (except to persons needing
          the information for the performance of official duties).  Section
          10(f) makes it unlawful for any employee to disclose confidential
          information except as authorized by Section 7 and 10.

     E.   Authorized Computer Facility!  any EPA or contractor computer
          facility which has been approved in accordance with OPP
          procedures for processing and/or retaining Confidential Business
          Information.

     F.   Authorized Person;  an Authorized Person is one who has:

          (1)  Been certified by the Division Director (or equivalent) that
               CBI is required in the performance of official duties.  This
               is accomplished by their  signing and dating Section  I of the
               "Access Authorization for FIFRA Confidential Business
               Information" form. (See Appendix A-1.)

          (2)  Signed and dated the FIFRA Confidentiality Agreement
               which is on record with their respective DCO (DCA).  This is
               accomplished by the employee completing Section  II  of the
               "Access Authorization for FIFRA Confidential Business
               Information" form.   (See  Appendix A-1.)

          (3)  Had a National Agency check, which is a review of the
               files of the Federal Bureau of Investigation (including
               fingerprint files), the Office of Personnel Management, the
               House Internal Security Committee, and the military
               services, or other Government  agencies, as appropriate.  The
               files of the Immigration  and Naturalization Service and the
               Central Intelligence Agency will be reviewed when the
               individual is  an alien or a naturalized citizen  of  the
               United States.
                                     -4-

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G.   Confidential Business Information (CBI)t "any information in
     any form received by EPA from any person, firm, partnership,
     corporation, association, or local, state, or Federal agency
     which contains trade secrets, formula, commercial or financial
     information, and which has been claimed as confidential by the
     person submitting it and which has not been legally determined to
     be non-confidential by the EPA General Counsel under the
     procedures in 40 CFR Part 3, Subpart B." [Mote:  at present all
     non-published data received from a registrant under FIFRA by OPP
     will be considered as CBI and treated as such.]

H.   Contractor or Subcontractor;  any person, association,
     partnership, corporation, firm, educational institution,
     governmental body, or other entity performing work for EPA under
     a contract or subcontract with EPA.

I.   Data;  technical information submitted by registrants and
     others under FIFRA.

J.   Disciplinary Action;  failure to conform to provisions of
     this manual may result in disciplinary action as described  in the
     EPA Conduct and Discipline Manual (chapter 5 and appendix C,
     Table of Offenses and Penalties, 35(B).

K.   Documents;  any recorded information regardless of its physical
     form or characteristics, including, written or printed material;
     data processing card decks, printouts, and tapes; maps, charts,
     drawings, working notes and papers; reproductions of such things
     by any means or process; and sound, voice or electronic
     recordings.  Usually refers to items of technical data (either
     volumes or studies) with a unique (accession) number in the OPP
     archive.

L'   Employee;  any person employed by the Environmental Protection
     Agency on a full or part time basis.  This definition does  not
     include contractors, grantees, or their  employees.

M.   Information;  knowledge which can be communicated by any  means.

N>   Penalties;  may be levied for violating  certain  provisions  of
     the law as follows:

     FIFRA Section 12(a)(2)(D) makes  it unlawful  for  any  employee  to
     use to his own advantage or to reveal any confidential
     information to unauthorized persons.  Conviction of  violating
     this section may result in penalties up  to a $10,000  fine and 3
     years in prison.
                               -5-

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     FIFRA Section 10(f) makes it unlawful for any employee to
     disclose confidential information except as authorized by
     Sections 7 and 10.  Conviction of violating this section may
     result in penalties up to a $10,000 fine and 1 year in prison.

0.   Secure Facility, Storage Room, or Area;  any building or
     portion thereof which has been inspected and approved prior to
     use by the Security and Inspection Division, EPA, for the
     handling of FIFRA Confidential Business Information materials.
     This includes door locks (either changeable combinations and/or
     key locks) and ultrasonic devices to monitor entry during non-
     working hours.

P.   Violations;  It will be considered a security violation any
     time the guidelines in this manual are not followed, whether or
     not an unauthorized disclosure takes place.  Violations will
     result in disciplinary action, which may include penalties.

Q.   Volumes;  any physical collection of data; especially the form
     submitted by the pesticide companies for consideration under
     FIFRA.
                               -6-

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                                SECTION III

                             RESPONSIBILITIES

1.   Division Directors are responsible for the protection of
     Confidential Business Information and the prevention of unauthorized
     access or release, while held within his/her division, as well as:

     A.   Approving the "Access Authorization for FIFRA Confidential
          Business Information" form (for all employees in the division
          needing CBI access) by completing Section I of the form.  (See
          Appendix A-1.)

     B.   Reviewing reports of security violations that come from
          supervisors and DCO (DCA) personnel, taking appropriate
          disciplinary action, and referring them to the Inspector
          General's Office if CBI has been compromised.  Copies of all
          violation reports will be sent to the Inspector General's Office.

     C.   Delegating any of the following responsibilities (in writing)
          under these rules to a designated representative (the Document
          Control Officer (DCO), so that the day to day administration of
          the security procedures is assured.

     D.   Obtaining the signature, EPA ID number, and employment date of
          the employee in Section II of the form entitled "Confidentiality
          Agreement for EPA Employees."  (See Appendix A-1.)

     E.   Forwarding a copy of the forms mentioned previously to the
          Division Document Control Officer (DCO) or Document Control
          ;  isistant (DCA) for retention.   (See the next subsection for
          other duties of DCO's/DCA's.)

     F.   Appointing DCO(s) and DCA(s) for his/her division, including  the
          forwarding of the necessary  signed forms (Appendix A) to the
          Security Branch of EPA (with a copy to the Office of the DAA).

          (1)  DCO's shall have a minimum of:  1 year experience with  OPP,
               be a GS  11, or higher,  and have no financial conflict  of
               interest as checked by  the DAA.

          (2)  DCA's shall be a minimum of a GS 4 clerical  and have no
               financial conflict of interest as checked by the DAA.
                                    -7-

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     G.   Establishing Division specific CBI handling procedures, tracking
          methods/ and secure areas within the division.

     H.   Assuring that a procedure exists whereby any employee terminating
          or transferring to a position not requiring access to FIFRA CBI
          is referred to a DCO prior to such action so that a Terminating
          Confidential Agreement can be obtained by the DCO.  (See Appendix
          A-2.)

2.   Document Control Officers (DCO's) are the focal point of the security
     system and are vital to the success to the system.  They are
     responsible for:

     A.   Obtaining and forwarding to the Division Director (with a copy
          to the DAA for a check against Conflict of Interest forms) once
          the Access Authorization is approved, a copy of the SF-171 for
          any employee whose appointment falls within the following
          categories:

          (1)  Per diem, intermittent, temporary or seasonal employees when
               the appointments are specifically limited to three months or
               less.

          (2)  Clerical employees similar to stenographer, typist, or law
               clerk, for four months or less as summer temporaries.

          (3)  Experts and consultants employed on an intermittent basis
               when the appointment is limited to one year or less.

          (4)  Appointments limited to 700 hours or less.

     B.   Speaking for the Division Director in matters of CBI  security, as
          delegated by the Division Director in writing.

     C.   Maintaining copies of all necessary forms used in these
          procedures as well as filing completed forms  for  future
          reference.

     D.   Producing needed procedures  (for use within  a division)  that  add
          needed detail to those outlined in this manual and distributing
          them to all appropriate staff members.  Such  procedures  may not
          conflict with the basic provisions of this manual.
                                    -8-

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E.   Establishing either a tracking system within his/her division or
     a secure reading area (see definitions: secured area) for
     safeguarding CBI materials.  (Lacking a secured area that has
     been approved by the Security Branch, the tracking system must
     meet the same criteria as that met by the division to division
     tracking system, discussed in Section VI.)

F.   The daily oversight of the security system, as well as occasional
     checks of the system such as spot checks for CBI not secured.

G.   Communication between his/her division and other divisions in the
     matter of CBI security, and communication with the chief DCO in
     the Program Support Division.

H.   Controlling all secured storage and/or reading areas within his/
     her division.  (See section on Physical Security.)

I.   Permitting access to only those individuals who are "authorized
     persons" and maintaining a current list of those persons for his/
     her division.

J.   Evaluating the present security measures and determining if they
     are sufficient to the current needs of the division and OPP.

K.   Reporting security violations to the Division Director so that  a
     review may be made.

L.   Conducting and/or arranging any necessary briefings on security.

M.   Controlling all movement of CBI into and out of the division, and
     assuring that all necessary transmittal forms are  signed,
     correctly filed and available for inspection.   (See  Section on
     Transmittal of CBI Materials for details.)

N.   Ensuring that proper covers are attached to make the CBI
     instantly identifiable before these  documents leave  the control
     of the DCO (DCA).  (See Appendix C for copies of covers.)

O.   Expediting requests for necessary locks and security equipment  as
     needed, as well as arranging for the changing of locks and
     combinations due to the termination  or transfer of authorized
     persons.
                               -9-

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     P.    Approving destruction of obsolete CBI in accordance with
          records retention schedules.  (See Document Management Section,
          Information Services Branch, PSD, for details on schedules.)

     Q.    Submitting and updating the list of CBI copying approval
          officials.

     R.    Approving any individual filing/storage used to hold CBI material
          within the division space.

     S.    Acting as liaison between contractors and the division, Contracts
          Management Division and the Security Branch of the Facilities and
          Support Services Division and the Inspector General's Office.

     T.    Delegating portions of his/her authority to designated
          representative(s) (Document Control Assistant(s) (DCA) as
          approved by his/her Division Director.

3.   Document Control Assistants (DCA's) are responsible for:

     A.    The actual logging of documents to comply with the tracking
          system(s).

     B.    Other duties of the DCO as delegated to them in writing by the
          DCO and/or Division Director.

4.   Second Line Supervisors (Deputy Division Directors, Branch Chiefs,
     etc.) are responsible for:

     A.    Any responsibilities of the Division Director as assigned, except
          the first, since the authorization signature may be given by the
          Division Director or the Acting Division Director only.  Such
          delegation of authority should be in signed memo form and
          distributed for inclusion in the manuals held within the
          appropriate division.

     B.    Documenting any security problems for the Division Director and
          contacting the appropriate DCO (DCA) for a speedy solution.

5.   First Line Supervisors (Section Chiefs, Team Leaders, etc.) are
     responsible for:

     A.    Being familiar with the information contained in this manual.

     B.    Ensuring  the day to day compliance with the rules by the workers
          under their supervision and providing positive  guidance as
          needed.
                                    -10-

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     C.   Ascertaining that the employees have become familiar with the
          rules in this manual and that they are being followed on a
          regular basis.

     D.   Encouraging a positive attitude so that the success of these
          measures is assured within their work area.

     E.   Counseling workers not meeting these standards of conduct and/or
          reporting violations of security to his/her Supervisor for
          referral to the Division Director.

     F.   Approving in writing the copying of CBI materials.

     G.   Reflecting proper or improper handling of CBI in the yearly
          Performance Appraisal under the current headings of:
          Cooperativeness, Judgement and Attitude.

     H.   Checking that the physical security of his/her work area is
          assured either personally at the end of the work day, or
          assigning in writing a qualified person for this duty.   It must
          be possible for a DCO (DCA) to conduct periodic checks on the
          security of any given area at the end of the work day and be able
          to verify (from a written log, posted memo, etc.) who was
          assigned that duty.

6.   Individuals (Non-supervisory and non-DCO's) are responsible for:

     A.   Reading this manual and being familiar with its contents.

     B.   Following the procedures in this manual and the specific division
          procedures that are incorporated herein.

     C.   Reporting security violations to their supervisor.

7.   Office of the Inspector General (OIG)

     The OIG is responsible for conducting investigations of  cases that
     involve the apparent unlawful disclosure of FIFRA Confidential
     Business Information and for auditing OPP  investigations that have not
     been referred to the OIG.  The following procedures apply:

     A.   OIG investigations shall be requested by the DAA, or by a
          Division Director through the DAA.  A statement of  the
          circumstances of the subject disclosure shall be  provided with
          the request.

     B.   A report of the results of OIG  investigations will  be provided  to
          the DAA and to the Department of Justice/  if appropriate.

     C.   Violations of provisions of this manual will be reviewed by the
          appropriate Division Director.  A  second review will be performed
          at the DAA level in cases where personnel  are involved  in
          additional violations and/or when  an  actual compromise  may  have
          occurred.  Copies of Division and  DAA level reviews will be
          provided to OIG for audit and possible further investigation if
          the OIG feels this is necessary.
                           •
                                    -11-

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                                SECTION IV

                             PHYSICAL SECURITY

It is the general policy of OPP to use physical measures whenever possible
to safeguard Confidential Business Information.  This includes
providing, where possible, for meeting areas away from the working areas of
OPP employees where such working areas cannot provide privacy and other
means of restricting access to CBI documents or information by unauthorized
persons.

1.   General Rules

     A.   All new Confidential Business Information received in the Office
          of Pesticide Programs shall be referred to the Process
          Coordination Branch of the Registration Division for the
          assignment of a unique identification number to allow for
          tracking.

     B.   CBI documents are to be easily identifiable by the use of special
          covers, stamps, etc.  (See Appendix C-1 to C-3.)

     C.   Documents are to be stored in approved secured file equipment,
          data/mail/correspondence storage rooms, and other approved
          secured storage areas.

     D.   File equipment must be secured by three-way changeable
          combination locks as approved by the Security Branch.

     E.   It is the responsibility of the Supervisor of his/her area  to
          insure at the close of business that doors in any secured
          work area are locked, alarms activated if appropriate and that
          CBI documents in unsecured work areas have been placed in secured
          storage.  This authority may be delegated in writing by  the
          Division Director to the DCO (DCA).

     F.   Secured storage cabinets, rooms, etc. will be clearly marked as
          such.

2.   Access to CBI Documents

     A.   Authorized EPA employees will obtain all CBI documents  incoming
          to the division from another division through their Document
          Control Officer (DCO) or Document  Control Assistant  (DCA).

     B.   The employee will sign for the CBI  document  (see  Log  Sheet
          Appendix D).

     C.   If a secure area is designated and an employee  needs  access to
          CBI documents but does not need to remove them  from this secure
          storage area, access will be obtained by authorized persons from
                                    -12-

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          the DCO (DCA).  A sign-in/sign-out log will  be  used to  verify
          names against the authorization list.

     D.    No documents will be allowed to leave  a secure  storage  area
          without following established Divisional procedures as  specified
          in the individual division-produced additions to this manual.

     E.    When an employee terminates his/her employment  or is reassigned
          within the Agency, or when access is no longer  required,  the
          combinations to locks which the employee has had access must  be
          changed.

     F.    The Administrative Officer of the division will not sign  off  an
          employee's exit clearance before receiving clearance from the
          DCO (DCA) and the OPP Document Center that the  employee has
          returned all CBI documents which were charged out to him/her, and
          obtaining a signed Confidential Termination agreement (see
          Appendix A-2).

3.   Safeguards During Individual Use of CBI

     A.    All CBI documents must be handled by authorized personnel only.

     B.    When unauthorized persons are present, documents must be covered,
          turned face down, removed from area or otherwise protected.

     C.    Each person is responsible for securing any CBI documents in his/
          her possession.  When persons are reviewing or processing CBI
          documents, these documents are considered their responsibility
          until properly placed in secured storage or transferred to
          another authorized person. During the review and handling
          process, persons in possession of these documents  are responsible
          for protecting or securing these documents before  leaving  their
          work area for any reason.

     D.    CBI must be stored in approved secure locked files or  secured
          rooms when not in use and at close of business.

     E.    Each person must safeguard keys and combinations  to files, safes,
          rooms, etc.  Keys and combinations to CBI files must be  retained
          in a secured place in the work area and not  removed except with
          the written approval of the DCO  (DCA).  Lost keys  or suspected
          breach of security in respect to combinations  must be  reported
          immediately (no later than COB that working  day)  to the  DCO  (DCA)
          so that immediate changes can be carried out.
                                    -13-

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F.   Data of a confidential nature given to any other OPTS employee or
     non-OPTS employee for review must be locked in a secure file
     (protected by three way changeable combination locks or kept in a
     secured area) when not in use as provided for under these
     regulations.  Employees transferring data to other authorized
     persons must inform them that this is a CBI document before
     transferring it to them.  Data transferred out of the Division
     should go only through the DCO (See Section VI for details on
     transferring CBI material.)
                               -14-

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                                  SECTION V

                           COPYING AND DESTRUCTION


1.    Policy On Making Copies j>f Confidential Documents

     A.    Any reproduction of documents containing OPP Confidential
          Business Information shall be kept to an absolute minimum.

     B.    Copies of any part of a CBI document in any form (e.g.,  paper or
          fiche) will be made only at the OPP Document Center,  Room 312,
          Crystal Mall Building 2).  Division copy centers may
          be established when copying equipment becomes available.

     C.    Confidentiality of data in the OPP document system shall be
          indicated as follows:

          (1)  All company data are Confidential Business Information
               unless otherwise marked.

          (2)  All Pesticide Document Management System (PDMS) studies
               beginning with the Master Record identification numbers
               (MRID) 00 (zero zero) are CBI unless otherwise marked.

          (3)  All PDMS studies with MRID numbers beginning with 05 (zero
               five) are not CBI.

     D.    Each copy of a CBI document shall be marked with a control number
          and its existence and disposition shall be recorded on a document
          control record.

     E.    All hard copy reproduction shall be done on pink paper so as  to
          readily reflect its CBI classification.

     F.    Microfiche copies containing CBI shall be produced with  a red
          stripe in the label area.

     G.    If copies (including extracts or citations  from CBI documents)
          are to be sent from one division to another within OPP,  or  are
          sent outside OPP, persons sending such documents are reminded
          that they are individually responsible to establish an  audit
          trail through the Division Document Control Officer (DCO) or
          Document Control Assistant (DCA) for the accountability of  all
          copies (see transfer rules in Section VI).

2.   CBI Copying Facility

     A.    The OPP Document Center is located  in rooms 310/312, CM-2.   It
          serves as the custodian of all company data and pesticide  studies
          entered into the Pesticide Document Management  System  (PDMS).
                                    -15-

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          The document mode is microfiche, from which copies are made by
          Document Center personnel only.  The center can produce copies:

               (1)  From paper to paper
               (2)  From microfiche to paper
               (3)  From microfiche to microfiche

     B.   The OPP Document Center is a restricted area, to which only
          assigned operating personnel are admitted.  All requests will be
          presented to the clerk on duty at the entrance, following the
          procedures in paragraph 4, below.

3.   Authorized Document Users

     Division Directors will furnish the OPP Document Center a list of
     employees having CBI clearance who are authorized to have access to
     Confidential Business Information in the Document Center.  Format of
     the list should be similar to the example shown as Appendix J.

4.   Procedures for Reviewing and Copying CBI Documents

     A.   To obtain CBI material from the OPP Document Center, the
          requestor's name must appear on the access list approved
          by his/her division director.  The requestor must also present
          his/her EPA identification badge prior to receiving any CBI.

     B.   The OPP Document Center will provide data for quick reference
          work at the center or carry-out copies (fiche and/or paper) for
          use in the requestor's office.  In either case, the requestor
          must sign for the data when received.  This will be done on a
          charge-out record prepared for each recipient of CBI.  When a
          document is returned to the center, appropriate annotation and
          signatures will be made on the record to reflect such return.
          Prior to departure from his/her OPP assignment, the recipient of
          CBI from the OPP Document Center must return all charged-out
          documents or present an acceptable audit trail that will release
          him/her from accountability.

     C.   Release of CBI to non-OPP and other Federal  agency personnel will
          be in accordance with the provisions of Section VI of this
          manual.

     D.   A registrant's request to review or obtain a copy of his
          previously submitted data will be honored only upon
          presentation of acceptable credentials and approval by  the
          Program Support Division's Document Control  Officer.

          If the request involves copy work, the DCO will coordinate the
          transaction with the Information Sources Section of the
          Information Services Branch, Program Support Division,  so  that
          the cost of reproduction can be collected.
                                    -16-

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5.   Destruction Policy

     Destruction of FIFRA Confidential Business Information shall be in
     accordance with the following:

     A.   Destruction shall be performed by a Document Control Officer or a
          Document Control Assistant under the DCO's supervision.  A
          record of CBI destruction shall be maintained by each DCO.

     B.   CBI material that was obtained from the OPP Document Center shall
          be returned to the center for disposition when the OPP recipient
          has no further need for it.  Destruction will be accomplished by
          the Program Support Division's Document Control Officer.

     C.   CBI material that was not obtained from the OPP Document Center
          shall be destroyed by the DCO of the office or Division having
          custody of such material.  This includes but is not limited to
          printed materials, micrographic images and typewriter  ribbons.

     D.   Destruction of CBI on film and paper stock shall be accomplished
          by processing the material through the Paper Pulverizer located
          in a secured area at Waterside Mall.  CBI stored on magnetic
          materials shall be destroyed by degaussing or with an  overwrite
          program as authorized and supervised by the appropriate DCO.

6.   Precautions Against Unauthorized Disposal, Salvage, or Copying

     Division DCO's and DCA's shall be responsible for instructing all
     persons cleared for access to CBI against unauthorized disposal  and
     copying.  Bad copies or brief extracts from CBI materials are not  to
     be placed in salvage such as  "Use it Again, Sam" boxes.  Copying of
     CBI materials is strictly prohibited in any form except when
     accomplished in the OPP Document Center.
                                    -17-

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                                SECTIOH VI

                         TRANSFER OF CBI MATERIALS

1.    Between OPP Divisions

     A.    All data leaving a Division must be logged out by the DCO (DCA)
          using the prescribed form (See Appendix D).   The unique control
          number(s) assigned by the Process Coordination Branch, Registra-
          tion Division and the transaction date will be entered on the log
          by the DCO (DCA).

     B.    CBI transfers shall require the use of a cover sheet and receipt
          form as follows:

          (1)  A CBI cover sheet stating that the material is CBI will be
               affixed to the document or, if covers are unavailable, the
               standard stamp of red ink will be used on the cover.  (See
               Appendix C-1 to C-3.)

          (2)  A receipt form (See Appendix E-2) will be attached to the
               package and a copy shall be pulled and properly filed for
               future reference.

     C.    No documents containing CBI will be transferred from one division
          to another without going through one DCO (DCA) to the other
          Division's DCO (DCA).

     D.    All incoming CBI will be processed by the DCO (DCA) so that every
          document containing CBI will be the responsibility of that DCO
          (DCA) until transferred to an authorized person.  That person
          will be accountable for that document until it has been
          transferred, in accordance with prescribed procedures, to another
          authorized person.

     E.    No CBI will be received by a division DCO without going through
          the proper procedures for archiving incoming data including the
          use of the following log-in procedure.  (The procedure prescribed
          by this manual is designed for secured areas only—divisions
          without a secured area will produce a written tracking procedure
          for use within their division.)

          (1)  Each document is received by the DCO (DCA) and  is entered  in
               the log (Appendix D) using the previously assigned document
               control number and recording the date of the transaction.
                                   -18-

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          (2)  If CBI cover sheets are not attached, they are affixed at
               this time or failing their availability,  the cover of the
               documents are stamped in red ink with the statement
               "Confidential Business Information.  Does not contain
               National Security Information (E.O. 12065)."

          (3)  Documents are then filed in secured file cabinets.

     F.    If documents are to be signed out to a person in an open work
          area rather than kept in a secured area, they must be logged out
          by the DCO (OCA) and then signed for by the person that will have
          physical possession of the documents, using the procedures
          outlined in the division-produced tracking system and stored in
          an approved storage cabinet with proper locks, etc., when not in
          use.  It is up to each Division to determine whether its CBI
          documents will be controlled in a secure area or by individual
          employees in prescribed filing equipment.

     G.    The transmittal form must be signed by the receiving DCO (DCA)
          and returned to the transmitting DCO (DCA) for retention and
          clearing of the tracking records.  (See Appendix E-2).

2.   From OPP to OPTS

     All CBI documents leaving OPP to other parts of the Office of
     Pesticides and Toxic Substances (OPTS) will go through an OPP DCO
     (DCA) to the appropriate DCO (DCA) in OPTS with the transfer documents
     used by OPP for interdivisional transfer of documents.   (See Appendix
     D,  and E-2).

3.   From OPP to Other Parts of EPA and Other_ Federal Agencies

     A.    Transfer of CBI to other federal agencies shall be  preceded by
          the establishment of an interagency memorandum of  agreement.
          (See Appendix I)

     B.    All CBI documents leaving OPP to other  Federal components  shall
          proceed through the division DCO, wih the approval  of  the
          Division Director, and be entered into  the appropriate  tracking
          system.

     C.    Anyone receiving the CBI material shall  sign  the  proper transfer
          form (Appendix E-2) and be informed by  the DCO of  the  proper
          physical security measures that  should  be taken  to safeguard  that
          material.

4.   From OPP to High Governmental Units

     Material requested by a Congressional Committee, the  Office of the
     President, GAO and any foreign govenment  shall be  sent by the
     appropriate DCO  (DCA) to the Office of the Deputy  Assistant
     Administrator for the Office of Pesticide Programs (External Affairs
     Unit).  All material containing CBI will proceed to Congress through
     that office and no other.

                                     -19-

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5.   From OPP to a Contractor, Subcontractor or Consultant

     A.   No confidential business information shall be disclosed to a
          contractor unless all of the following conditions are met.

          (1)  The contract must authorize the disclosure of CBI to the
               Contractor, and the Contractor must have agreed to the
               clause entitled "Treatment of Confidential Business
               Information" before receiving such information.

          (2)  The contractor's security plan and facility requirements
               for safeguarding Confidential Business Information must be
               approved by the Program Project Officer and the OPP Security
               Officer before any CBI is disclosed to the Contractor.

          (3)  A notice that CBI is to be disclosed to the Contractor must
               be published in the Federal Register in accordance with 40
               CFR 2.301(h)(2)(iii) and the prescribed waiting period must
               be adhered to before such disclosure is made.  The OPP
               office managing the contract shall provide the Information
               Services Branch, Program Support Division with the
               information needed for the Federal Register notice.

     B.   Transfer procedures for Documents containing Confidential
          Business Information to Contractors, Subcontractors, or
          Consultants.

          (1)  The (Contract) Project Officer responsible for the contract
               or subcontract shall request the necessary CBI from  the
               appropriate DCO (DCA).  This written request  shall include
               the identity of the contractor or subcontract and the number
               of the contract or subcontract.

          (2)  Upon receipt of such a request the DCO  (DCA)  shall provide
               the requested CBI to the  (Contract) Project Officer  in
               accordance with the procedures prescribed earlier in this
               section for transferring  documents from one division to
               another or in accordance with the division procedures  for
               transfer within a division.

          (3)  The (Contract) Project Officer shall  furnish  the  CBI to  the
               contractor or subcontractor  in accordance with the
               procedures as described earlier  in this section for  transfer
               from one OPP division to  another.

          (4)  The (Contract) Project Officer shall  obtain  a written
               receipt for the CBI from  the contractor or  subcontractor and
               send it to the appropriate DCO  (DCA)  who shall enter it  in
               the log.   (Appendix E-2).
                                    -20-

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6.   Telecoinmuni cat ions

     With the permission of a Division Director or the data submitter,
     FIFRA CBI can be transmitted electronically through telecopier
     lines to secure areas within EPA or to the data submitter whose
     material is involved.  The telecopier will be used for such
     transmission only by authorized EPA personnel who will ensure
     that no unauthorized person can see or otherwise gain access to
     the CBI being received or transmitted.

7.   Meetings Involving Discussion of CBI

     For any meeting, symposium, panel discussion, or seminar at which
     FIFRA CBI will be discussed, the meeting chairperson shall provide a
     FIFRA CBI Sign-In Sheet  (Appendix B-1, B-2) if there are attendees who
     have not had prior access to the CBI to be discussed.  In addition,
     the chairperson will retain the option to require a sign-in sheet
     whenever he/she thinks it necessary.  All attendees must sign  it and
     record their EPA identification badge number.  The chairperson shall
     give the sign-in sheet to the local DCO/DCA who will retain it for 1
     year.

     The chairperson must also ensure that only authorized persons  are
     present and shall announce FIFRA CBI is to be discussed.  When
     necessary, the chairperson shall review with the attendees their
     responsibility for safeguarding CBI in any and all forms, including,
     but not limited to, any  notes taken and any subsequent discussions.

     No recording is to be made of the meeting unless the chairperson has
     authorized it.  If authorized, the recording must be treated  as  all
     other confidential business information and entered into the  document
     control system.

     The meeting room shall be  secured  after the meeting by the
     chairperson.  This includes cleaning all chalkboards, destroying,  by
     approved methods, all tear sheets  and other notes,  and ensuring  that
     nothing is left in the room that could  lead to the  unauthorized
     disclosure of FIFRA CBI.

     When notes containing FIFRA CBI  are taken  from  a  document,  a meeting,
     or anyother source, the  notes must be protected  as  CBI.   If  the  notes
     are to be circulated to  other  authorized persons,  they must  be entered
     into the document control  system.  The  taking of  notes  is  discouraged
     and should be kept to a  practical  minimum.   Any  document generated
     from notes shall be treated  as  described  in  Section IV of  this manual.
                                    -21-

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                          SECTION VII

                        COMPUTER SECURITY

The Resource Access Control Facility (RACF) is maintained by the
contractor at Research Triangle Park, N.C., for use by EPA.   RACF uses
a series of profile tables/ which contain descriptions of users,
groups of users, and data resources, to check access authorization.
These include:

A.   User Profiles containing attributes that define the user's
     authority to access data resources and issue RACF commands.

B.   Group Profiles containing a list of the members in the group and
     the authorities of each member.

C.   Data Resource Profiles (DRP) containing a list of authorized
     users and groups of users and the access authority of each.  Also
     the DRP contains the universal access authority (UACC) to be
     granted to users who are not specifically granted or denied
     access.

D.   Authorization checking is the basis for deciding whether a
     processing function or an access to protected resources should be
     allowed or prevented.  RACF performs authority checking without
     any user or operator intervention.  If the access is authorized,
     it is allowed; if unauthorized, it is denied.

E.   The Data Administrator (PSD) can, at any time, change any of the
     authorization parameters.

Encryption of Data Files will be performed on computer records
pertaining to production data volumes reported by registrants/
manufacturers.  These data files will be maintained at Research
Triangle Park in an encrypted mode so that any unauthorized user
cannot obtain volume information.  The data records will be decoded
for processing of a retrieval request.  All temporary data sets will
be purged upon completion of the processing run.

Physical Security of the OPP computer room is protected by double
locks on both access doors in non-prime shift hours.  Prime shift
security is maintained by a minimum  of two computer operators
physically in the room.  Jobs security/logging uses the following
technique:

A.   When a job is printed, the operator removes  it from  the printer.
                               -22-

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B.   The operator then logs it in using a Data  100 CRT which creates a
     permanent computer file containing information about the account,
     initials, lines of print, job number, time of day, cost and other
     job parameters.

C.   The operator then places the non CBI printout in that  user's bin
     and the user picks up the materials.

D.   CBI jobs shall be under a unique account name that indicates that
     the printout contains protected material.

E.   The operator shall intercept the jobs containing CBI and call
     the DCO (DCA).  These printouts will not go  into the user's bin
     for pickup.

F.   The DCO (DCA) shall pick up the hard copy  (printouts)  from the
     operator and lock them in a secure cabinet until the authorized
     official claims them by signing the official log which includes
     the job number and date.  (See Appendix D).
                               -23-

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                          SECTION VIII

                      CBI TYPING PROCEDURES

Documents Typed Internally

Each division is instructed to produce procedures for the protection
of draft material containing CBI and the protection of such drafts and
ribbons held within a division which include:

A.   The responsibility of the drafter of a document to put a CBI
     cover sheet on material to be typed so that all who handle it are
     aware it is to be protected.

B.   Assigning the typing of such a draft to authorized typists only.

C.   The locking in a secured cabinet or room; the handwritten draft,
     incomplete or undelivered typed versions of the draft, and the
     ribbon or disc used to produce the document.

D.   The return of all materials used to produce the CBI containing
     document to the drafter.

E.   The destruction (See Section IV) of all the draft copies and the
     ribbon/disc used for their production.

Documents Typed on Contract

Procedures for transferring draft CBI material to the contractor for
typing are indicated below.

A.   Drafters of CBI material are to place a red cover sheet over the
     CBI rough draft material.

B.   Place the draft inside two envelopes before hand carrying
     document to DCO (DCA) for transmittal to the contractor.

C.   The inner envelope should be addressed to the  contractor and
     have "CONFIDENTIAL BUSINESS INFORMATION" stamped or printed on
     the envelope, and the phrase "TO BE OPENED BY  ADDRESSEE ONLY"
     printed or stamped on the envelope.

D.   The outer envelope should be a regular envelope  (not  an
     interoffice envelope) and have the recipient's full mailing
     address on it.  There should be nothing written on outside
     indicating that CBI material is contained in it.
                               -24-

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E.   The drafter will attach to the outside of the double envelope a
     correctly completed EPA Request for Typing/Editing Form (EPA Form
     7710-9), with "CONFIDENTIAL BUSINESS INFORMATION" printed or
     typed and underlined in the comments section, Block 20 of the
     form (see Appendix E-1).

F.   The drafter will ensure that the CBI document is hand carried to
     the DCO (DCA) and ensure that the drafter/secretary signs the
     Confidential Document Control Log transferring control
     responsibility over to the DCO (DCA).  (See Appendix D).

G.   The DCO sends the draft to the contractor for typing.

H.   The DCO (DCA) will ensure that the Branch (drafter/secretary)
     hand carries the draft document back to the Branch once the CBI
     document is returned to the DCO (DCA) and signs the Confidential
     Business Information Control Log transferring control
     responsibility back to the drafter.  (See Appendix D).

I.   The DCO (DCA)will monitor the flow of CBI rough draft materials
     between the EPA and the contractor as outlined below:

     (1)  Ensure that the outer envelope of the double-envelope
          confidential package is addressed to the contractor.

     (2)  Ensure that a receipt form (see Appendix E-2) identifying
          the document is inserted into the inner envelope.   (This
          receipt form is signed by the contractor security officer
          and returned to the Division DCO (DCA) acknowledging
          receipt.  The receipts will be maintained by the DCO  (or
          DCA) until the typed document is received from the
          contractor.

     (3)  Ensure that the CBI document is assigned an OPP  CBI control
          number and that this control number  is  added to  the bottom
          right hand corner of the EPA Form 7710-9  (Appendix  E-1).

     (4)  Ensure that the necessary control copy  (yellow,  (Contract
          Project Officer's copy) of EPA  Form  7710-9 has been pulled
          and the form has been properly  completed  including  the
          addition of "Confidential Business Information"  to  the
          comments section.   (See Appendix E-1).

     (5)  Ensure that the contractor's messenger  signs  the Confi-
          dential Business Information Control Log  when  picking up and
          returning CBI documents, thereby transferring  control
          responsibility to the Contractor while  the  document is
          being typed.  (See  Appendix D).
                               -25-

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                                   SECTION IX

                          DIVISION SECURITY PROCEDURES

Responsibilities of the Division Director, Document Control Officer,  Document
Control Assistants, supervisors and individual employees are described in
sections III through VIII of this manual.  Those sections give mandatory
procedures to be followed in receiving and logging CBI into the Division,
transferring the CBI material within the division, protection while using the
material, storing, copying, destroying, transferring to another Division, to
other programs in EPA, or to a contractor cleared for handling of CBI.

The Document Control Officer in each division is the focal point of the
security system, having the responsibilities listed in paragraph 2 of section
III.  Division DCO's are named below:
Benefits and Field Studies Division

    Loa Herbert                   CM-2, Room 211           557-7244

Hazard Evaluation Division

    Ken Condra                    CM-2, Room 815           557-7347

Program Support Division

    Emory Eldredge                CM-2, Room 312           557-7151

Registration Division

   Edward Gross                   CM-2, Room 509           557-7123

Special Pesticides Review Division

    Jane Babcock                  CM-2, Room 724-A         557-3043
Procedures for internal security operation within each division are provided
in this section—
                                                                Page
    Benefits and Field Studies Division	 .BFSD-1

    Hazard Evaluation Division Program Support Division.........HED-1

    Program Support Division	 .PSD-1

    Registration Division	RD-1

    Special Pesticide Review Division	SPRD-1
                                       26

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                   BENEFITS AND FIELD  STUDIES DIVISION
                           SECURITY PROCEDURES

The Benefits and Field Studies Division (BFSD)  differs  from the Manual by
using the following divisional procedures to track Confidential Business
Information (CBI) documents within the division:

A.   Procedures for tracking incoming CBI Data:

     The Document Control Officer  (DCO) or the  Document Control Assistant
     (DCA) logs in all CBI data received by or  transmitted to the
     Designated Security Area in the following  manner:

     (1)  Record document control number in log.

     (2)  Attach red or white (contractor) cover  sheets.  If cover sheet
          is not available or time does not permit, stamp document in red
          ink with statement "Confidential Business Information.   Does not
          contain National Security Information.   (e.o. 12065)."   File
          document in prescribed cabinets in secured area.

B.   Procedures for tracking outgoing CBI Data:

     All data leaving a division must be logged out by the DCO or
     designated DCA.  The DCO or DCA will log out data in the following
     manner:

     (1)  Record control numbers or note date in  control log and  insure
          that the red or white cover sheet or stamp is affixed to the
          document.

     (2)  Insure that the receipt  form shown is attached to the package;
          the hold copy is pulled and properly filed for future reference;
          and that the person transmitting the document signs the control
          log.

C.   Document Management Responsibilities:

     (1)  Inventory

          The DCO is responsible for inventorying all CBI data held by the
          division at least once a year.  The DCO will also insure
          division procedures by spot checks and by insuring the
          availability of proper equipment and locks.  The DCO also
          directs the disposition  of all CBI documents as required by
          these procedures.

     (2)  Employee Clearance when  leaving OPP

          The Security Division of EPA will not sign off on an employee's
          clearance until the Administrative Officer of the responsible
          division has signed off.  The Administrative Officer of the
          division will not sign off on an employee's clearance before
          receiving clearance from the DCO  (DCA) that the employee has
          returned all CBI documents.

                                 BFSD-1

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           BFSl) Attachment  1
    ENVIRONMENTAL PROTECTION AGENCIT
FIFRA CONFIDENTIAL BUSINESS INFORMATION
           USER SIGN OUT LOG
(Date/Time
| Checked
I out
|Date
1
|TlM
1
(Data
1
|Tl«e
1
(Date
1
|TlM
1
(Date
I
|Tt««
1
(Data
1
iTime
1
(Data
1
|T1««
1
|0«t«
1
(TIM
1
(Date
1
|T laa
1
(Data
1
iTUie
1
(Date
1
(Tine
1
| Oft Document
Control Number/
Copy Number




'
.





EPA ID
Number










USER IN FORMAT
Last Name
•









CON
Signature










1
1 DCO
Initial










1
Data
Returned











DCO
Initial










1
Date
Destroyed











DCO
Initial





-





Comments









•


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                          BFSD ATTACHMENT 2
MEMORANDUM

SUBJECT:  Security of Public Law 92-516 Section 7 Data

FROM    :

TO      :  Recipients of Section 7 Production Data


The attached Section 7 material (Production Data) is provided per your
request.  It consists of 	pages of computer printout.  This information
is considered priviledged and it must be severely restricted in its
dissemination, being made available only to those Environmental Protection
Agency officials with valid need for it.  Duplication of any of the material
on a copying machine is not authorized.

Unauthorized disclosure of the attached information is punishable by a $10,000
fine or imprisonment of not more than three years, or both.  (Section 14 (b)
(3), Public Law 92-516).

Upon completion of your analysis of the information, it should be returned to
Room B-17, East Tower, for subsequent destruction.  Until that time you are
personally accountable for the security of the material.
                                   CERTIFICATE

I have read and will abide by the above conditions while the Section 7 data is
in my possession.
Printed Name                                          Signature
Organization                                          Office Telephone Number
Date Returned to SSB                                  Signature
Date Destroyed by SSB                                 Signature
                                     BFSD-3

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                           HAZARD EVALUATION DIVISION
                               SECURITY PROCEDURES

    1.   General Procedures

         A.   Incoming Data

              Confidential Business Information is  routinely  received in BED
              as part of company registration data.  Such  information normally
              comes from one of the following sources:   Registration Division
              product managers; Program Support Division;  Special  Pesticide
              Review Division; or Benefit and Field Study  Division.

              The principal source of CBI data is the  Registration Division
              and such data is normally transported to and from HED Branches
              by a designated Personnel Control Clerk* on  the HED  Director's
              Staff.  The Division Branches then handle the CBI data in
              accordance with the attached descriptive statements.

              CBI data transferred to or from approved contractors or other
              sources is handled through  the DCO.  If  a question arises/ the
              matter is to be referred to the Chief/ Information Services
              Branch, Program Support Division.

         B.   HED Tracking System

              (1)  Input

                   a.   Material is received by the HED Document Control
                        Assistant and logged in. Pertinent identifying data
                        are entered into the log.  The documents designating
                        type of material  are appropriately stamped.

                   b.   The material is hand delivered in  CBI covers, as
                        specified by the  manual, to the designated cleared HED
                        staff for study.

                   c.   The material is then shelved in accession  number order
                        in a conserva-file drawer which has combination locks.

              (2)  Usage of CBI

                   a.   Outside EPA:  Material reviewed by other agencies  or
                        by consultants follows the  manual  procedures.

                   b.   Within EPA:  Access to CBI  is  available to EPA
                        employees who have been cleared according  to  FIFRA;
                        Manual Procedures Division. Material may  only be
                        removed through DCO or DCA  by  a cleared employee.  The
                        request form is filled out  by  the  requestor.  The  DCA
                        prepares two 3X5 cards with borrower's name,  etc.  One
                        card is placed in a red plastic cover with a  pocket,

*The current designated Pesticide Control Clerk is  Marvin  Hawkins

                                      HED-1

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                    and placed in numerical  order  in  secured file.  The
                    other 3X5 card is placed numerically in a 3X5 file of
                    all CBI material.  Transmittal of such material
                    follows procedures as outlined in the FIFRA Manual.

               c.   Typing:  CBI material for typing  is hand carried to
                    the contractor for typing by cleared typist or sent in
                    double envelopes as specified  in  the manual.

               d.   Copying:  Only to be done by a secured copier.

               e.   Destruction of material:  A form  requesting
                    destruction is filled out and  approved; the material
                    is then shredded in the  designated area.

2.   Branch Procedures

     A.   Ecological Effects Branch

          Since RD actions (Sections 3, 5, 18 and  24(c) may contain CBI
          materials, these are handled in a  guarded manner.  Following
          delivery to the Branch these are logged  in  and immediately
          assigned to a specific reviewer.  Actions may be placed in
          Branch holding files until picked  up by  the assignee.

          Reviewers are instructed to place  all such  materials and copies
          of their reviews in secure locations inside locked file cabinets
          before leaving work each day .

          (1)  RD submitted data (some of which may be considered
               confidential) is attached with the  complete review for
               pickup and return to RD via personal carrier.  When reviews
               are sent to the typing contractor for  typing, they are
               placed in double envelopes, marked  "CONFIDENTIAL BUSINESS
               INFORMATION" and "To Be Opened By Addressee Only" — with
               the Standard red 8 1/2 x 11"  insert which cautions that
               some information within may be entitled to treatment as
               trade secret or proprietary data under Section  7  (d) and
               Section 10 of FIFRA.

          (2)  Since the Branch also transmits copies of specific reviews
               to either the Office of Endangered  Species  (USFWS/DOI) and
               the National Marine Fisheries Service  (DOC) in  seeking
               formal consultations regarding pesticidal effects on
               endangered or threatened species, the  same  red  8  1/2 x  11"
               cover described above is attached.

          (3)  Unpublished studies reviewed  during Registration  Standard
               activities are to be disposed of by shredding,  using the
               shredder in the llth floor copying  room.  Data  evaluation
               records sent to the typing contractor  for final typing also
               are accompanied by the red 8  1/2 x  11" insert as  described
               in #1 abovet
                                 RED-2

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     (4)  All Branch personnel have completed  the  Standard OPP form
          "Access Authorization for FIFRA Confidential Business
          Information."

     (5)  In addressing RPAR matters dealing with  fish and wildlife
          risk assessment/  the Branch receives both published and
          unpublished studies.  These documents, when confidential,
          are kept secure in locked files when not in use.   All  such
          documents are returned to SPRD upon  completion  of  review or
          are kept under lock.

B.   Environmental Fate Branch

     CBI is received by EFB where it undergoes either an  in-house
     review or is assigned to an EFB contractor  for  review.

     (1)  Review Procedures

          a.   In House

               When the data is to be reviewed in-house,  it  is kept
               secured until assigned to a reviewer.  The reviewer
               evaluates/reviews the data at his/her official work
               station, or, under special circumstances,  at  locations
               outside the Agency.  If CBI is  to be  retained
               overnight, it is secured in locked  Agency  files,  or
               under special circumstances, it is  secured by the
               reviewer at a location outside  the  Agency.

          b.   Contractor Review

               EFB also has data reviewed by a contractor.   The
               contractor,  with security clearance,  picks up CBI in  a
               secured van for delivery to the contractor's
               location.  The contractor evaluates/reviews and stores
               the data under secured conditions.  Upon  completion of
               the review,  the CBI is returned via secured van where
               it is held in secured EFB files.  Dissemination is
               only to Branches and Divisions  within the  Agency. The
               contractor may retain a copy of the final  review  it
               generated until termination of  the  contract.

     (2)  Dissemination

          Copies of the reviewer's completed evaluation,  with
          confidential notation, are disseminated  to other Agency
          locations via hand delivery, Agency  mail or registered mail
          with copy retained by EFB.  Dissemination  outside  the
          Agency does not occur via EFB directly except  under  FIFRA,
          Section 10 (emergency dealing with protecting  against  an
          unreasonable adverse effect to health  or the environment)
          or under an FOI request which is sent  directly to OGC, if
                             HED-3

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          requested.  The CBI, from which the reviewer's  evaluation
          was generated, is either retained and secured in  EFB,
          returned to the originating Division or Branch  in the
          Agency or is destroyed.

C.   Health Effects Branch

     Health Effects Branch follows the standard HED tracking
     procedures.

D.   Residue Chemistry Branch

     (1)  Tracking:  All petitions and registration actions are
          assumed to be CBI.  These documents are received  from  the
          HED Pesticide Control Clerk.  They are placed in  the RCB
          in-box and logged in by the Branch Secretary.  The Branch
          Secretary routes the material to the appropriate  section.
          The Section Head keeps the material in a locked file
          cabinet until assigned to a reviewer.  The reviewer keeps
          the material in a locked filing cabinet until the review is
          initiated.  Once under review the material is kept on  the
          reviewer's desk during the day and locked in a  filing
          cabinet at night.

          Once the review is completed the material is returned  to
          the Section Head for secondary review.  The Section Head
          again keeps the materials in a locked filing cabinet until
          the secondary review is completed.  At this time  the
          petition is filed in the Lektrievers, Times II  files or
          filing cabinets, all of which can be locked.

     (2)  Filing:  Registration Standards data are kept in  locked
          filing cabinets.  Much of the Registration Standards data
          are for older chemicals and thus available in the open
          literature.

     (3)  Access:  Access to the Branch files during non-work hours
          is controlled as follows.  All doors to room 810  are locked
          each night.  All door locks except the main entrance door
          cannot be opened except by keys available from  the RCB
          Branch Chief/Deputy Branch Chief, Division Office or
          Guards.  The main RCB entrance to room 810 is locked with  a
          combination lock.  The combination lock is available to all
          RCB Branch Personnel.

E.   Toxicology Branch

     (1)  Tracking:  All registrations and petitions received in TOX
          are considered CBI.  The Pesticide Control Clerk  puts  the
          action packages in the box for the Environmental  Protection
          Specialist.  This person logs the actions in and places the
          unassigned actions in a locked file cabinet.  After the
          actions are assigned to a reviewer, the reviewer keeps the
          actions in a lockable file cabinet.  While under active

                             HED-4

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          review the actions are kept  on  the  reviewer's desk during
          the day and are placed in a  lockable  file cabinet at
          night.  After the review has been completed the whole
          package is given to the Section Head  for secondary review.
          The actions are kept in a lockable  file cabinet until
          secondary review is complete.  The  actions then go to the
          Registration Coordinator for another  secondary review -
          again the actions are kept in a lockable file cabinet.  The
          actions then go to the Branch Chief for final sign-off and
          again are kept in a lockable file cabinet.  At this time
          the registration and petition actions are returned to the
          Environmental Protection Specialist where they are logged
          out and returned according to manual  procedures.

(2)   Storing:  Data for Registration Standards  and RPAR is kept in
     lockable file cabinets as much as possible.  Much of this data
     is available in general literature.

(3)   Access:   All hall doors into the  Toxicology Branch are locked by
     both key and combination locks.   The keys  and the combination
     are available to TOX Branch personnel on an "as-needed" basis.
                            HED-5

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BED Attachment 1
NUMBER





1














CHEMICAL







'












DATE
| RECEIVED














1
1
1
1
1
I
I
1
| TOX. BR.




















I CHEN. BR.




















I EEB




















I RETURNED TO










I
B


.






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                                                           HED Attachment  2
                                            Date Out EFB:
To:    Product Manager
       TS-767

From:  Dr. Willa Garner
       Chief, Review Section No. 1
       Environmental Fate Branch
Attached please find the environmental fate review of:

Reg./File No.:	

Chemical:
Type Product:

Product Name:

Company Name:
Submission Purpose:
  t;

ZBB Code:

Date In:
Date Completed:

Deferrals To:
ACTION CODE:

EFB #
        Ecological Effects Branch

        Residue Chemistry Branch

       Toxicology Branch
                                      HED-7

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              PROGRAM SUPPORT DIVISION  SECURITY PROCEDURES

1.   INPUT

     All CBI received in any element of Program Support Division must  be
     delivered to the PSD Document Control Officer for entry into the  CBI
     tracking system.

2.   CONTROL

     A.   The Document Control Officer logs in all CBI for the Division
          and its Branches, and transfers CBI to the Document Control
          Assistant in each branch of PSD as appropriate.   Each branch DCA
          maintains the branch tracking system and is responsible for  CBI
          security in the branch.

     B.   Most CBI entering the Division is company data from applicants
          for registration and is received from the Registration Division
          after that division assigns an accession number to the
          document.  When received in the Document Management Section,
          Information Services Branch,  the control clerk will add the
          accession number to the computer inventory record and will also
          make the code entry showing that the document was transferred to
          Raven Systems and Research, Inc., for processing into the
          Pesticide Document Management System.  After updating the
          computer record, the control clerk will deliver the CBI document
          to Raven personnel in the OPP Document Center.  The Raven
          recipient will sign a receipt which will be filed in the
          Document Management Section for tracking.

     C.   A record of all CBI received from the contractor as an output
          from PDMS processing will be kept in the Document Management
         . Section.  When such data are transferred to other OPP users, a
          signature for each item of CBI material shall be obtained from
          the recipient.  In most cases, the computer listing which
          accompanies the CBI material can be used as the control record
          and receipt form.

3.   STORAGE AND USE

     Microfiche masters of original submissions and PDMS studies are
     stored in the OPP Document Center (room 310, Crystal Mall Building
     2), and are made available as described in Section V of this manual.

4.   TRACKING AND TRANSFERRING

     Complete tracking is practiced from accession to transfer or
     destruction, as described in Section VI of this manual.

5.   DESTRUCTION

     Shredding is performed as provided for fiche, paper documents, and
     typewriter ribbons.  Magnetic recordings may be demagnetized.  (See
     Section V.)

                                  PSD-1

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6.   ACCESS TO COMPUTER STORAGE AND PRINTOUTS

     Access to computer storage and production  is  controlled  (see Section
     VII).
                                 PSD-2

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            REGISTRATION DIVISION SECURITY  PROCEDURES
       s
                            Contents

Product Manager Team Security Procedures 	   RD-2
A.   New Registrations	RD-2
B.   Amended Registrations	   RD-6
C.   Tolerance Petitions 	   RD-6
D.   Amended Tolerance  Petitions 	 ....   RD-8
E.   RPARs	RD-8
F.   Congressional Material  	   RD-B
G.   Miscellany	RD-8
Process Coordination Branch Security Procedures  	   RD-9
A.  Coordination Section  	   RD-9
B.  Emergency Response  Section   	 	   RD-11
Technical Support Section Security Procedures  .........   RD-14
Appendix 1 - Log Form
                               RD-1

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1.  Product Manager Team Security Procedures

    A.    New Registrations.   The following procedures are to be followed
          in handling CBI submitted in support  of a new registration:

          (1)  CBI material coming into a Product Manager team from the
               Process Coordination Branch (PCB) to support a new
               registration action will have  on it a CBI red cover sheet
               (or if unavailable, the alternate cover specified in
               Section VI, IB(2)) identifying it as CBI.  Upon receiving
               such material, the receiving clerk or other authorized
               person will immediately log the  jacket in (or see that it
               is logged in)  and move it to the appropriate reviewer for
               review.  Should such initial CBI material enter the PM team
               directly without going through PCB, the Product Manager
               Team OCA shall immediately take  it to the Liaison Team in
               PCB for processing.  If the DCA  cannot take it to PCB
               immediately, the liaison team  DCA in PCB should be
               contacted by phone and requested to pick up the CBI.  If
               the DCA in PCB is not available, the alternate DCA there
               should be contacted.  If neither of them is available, the
               head of the Coordination Section or the next in authority
               should be contacted.  At no time should CBI be
               unnecessarily delayed in moving  to PCB.

          (2)  If in the course of reviewing  the submission, the reviewer
               finds it necessary to photocopy  CBI for transmittal outside
               Registration Division, he/she  will obtain from his/her DCA
               the form entitled REQUEST TO COPY OPTS CONFIDENTIAL
               BUSINESS INFORMATION.  After filling out the request  form,
               the reviewer will obtain hisAier Product Manager's
               concurrence on the form approving the  request.  The form
               will then be taken by the reviewer, DCA, or other
               authorized person on the team  to the OPP Confidential
               Document Copy Center where the requested number of copies
               will be made by the DCA operator in charge.  These copies
               must be numbered and tracked.   (A Product Manager desiring
               to photocopy CBI may fill out  the same form at the OPP
               Confidential Document Copy Center without getting his
               supervisor's approval.)  When  the reviewer is no longer
               actively working on the submission, the  jacket should be
              / stored in a secured cabinet as specified in  Section  IV of
               this manual or returned to the Registration  Division  File
               Room.

          (3)  When a reviewer requests a review of  a submission
               containing CBI from Technical  Support  Section  (TSS),  the
               reviewer will log out the data on the  Data Review  Record.
               After obtaining a CBI red cover sheet  or a substitute as
               specified in Section VI, IB(2) from the  DCA  and  affixing  it
               on top of the CBI-containing material,  the  reviewer  will
               then hand carry the material to the  DCA or clerk in  the TSS
               for logging in.   (The Herbicide-Fungicide  TSS  requires  that
               all CBI material be received by the  DCA only.)

                                  RD-2

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(4)   When  a reviewer  requests a review of a submission
     containing CBI from  the Hazard Evaluation Division (HED),
     he/she will:•

     a.    Log the data out on the Data Review Record form,
          including assigning a control number and dating.

     b.    Obtain from the Product Manager Team DCA a CBI red
          cover sheet or  if unavailable, use the alternative
          specified in Section VI, 1B(2), and the "Receipt of
          Confidential Data" form.

     c.    Attach the  cover sheet and the Data Review Record on
          top of the  data.

     d.    Give the package to the Product Manager Team DCA to
          hand carry  to PCS for prioritizing and completion
          date, from  where it will be sent to HED.

     e.    When the CBI is returned to PCB, the reviewer, DCA, or
          other authorized person on the Product Manager Team
          will pick up the material.  The DCA will log the
          material back in on the Data Review Record form.

     f.    If the registration is approved:

          ^.   The reviewer will take the jacket to the DCA so
               that the DCA can log it out on the Data Review
               Record (including assigning a control number and
               dating) to the contractor for microfilming and
               coding.

          2^,   The reviewer will indicate clearly on the
               "Receipt of Confidential Data" form that the
               material is to be microfilmed and coded and that
               upon completion of the work, the confidential
               material is to be returned to the reviewer by  the
               contractor.

          J3_«   The reviewer will insert the jacket in a brown,
               gummed envelope with the words CONFIDENTIAL
               BUSINESS INFORMATION and TO BE OPENED  BY
               ADDRESSEE  ONLY printed or stamped on the outside,
               and seal.  If more than one jacket  is  involved,
               the reviewer will use a 12 x 10 x 8 shipping box
               ordered through the GSA supply store with  just
               the contractor's full mailing address on it and
               put it at  the contractor's pick-up  station.

          ^.   The reviewer will place the envelope in a  second
               brown, gummed envelope with only the contractor's
               full mailing address on it and put  it  at the
               contractor's pick-up station.
                        RD-3

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          ^.    When the  jacket(s) is  (are) returned from the
               contractor,  the Product Manager Team OCA will log
               it  (them)  in on the Data Review Record and return
               it  (them)  directly to  the RD File Room.

     g.    If  the registration  is denied:

          _!_.    The reviewer will keep the jacket in a secured
               cabinet as specified in Section IV, or give the
               jacket to the Product  Manager Team DCA, who will
               hand carry it to the RD File Room.

          2.    If  after  the 75-day waiting period, the
               registrant withdraws the application, the
               reviewer  will give the jacket to the Product
               Manager Team DCA, who  will hand carry it to the
               RD  File Room.

(5)   When a reviewer requests  typing  of material containing CBI
     from a contractor,  he/she will:

     a.    Obtain a CBI red cover sheet or if unavailable, use
          the alternate  cover  specified in Section VI, from the
          DCA and  place  it over the CBI-containing material.

     b.    Place the material in a brown, gummed envelope
          addressed to the contractor with the words
          CONFIDENTIAL BUSINESS INFORMATION and TO BE OPENED BY
          ADDRESSEE ONLY printed or stamped on the outside.  If
          the material is too  bulky for an envelope, use a 12 x
          10  x 8 shipping box  with just the contractor's full
          mailing  address on it.

     c.    Place the envelope inside a second brown, gummed
          envelope with  only the contractor's full mailing
          address  on it.

     d.    Obtain from the Product Manger Team DCA an EPA Form
          7710-9 "Request for  Typing/Editing," and after filling
          out the  form completely, including inserting the words
          CONFIDENTIAL BUSINESS INFORMATION  (see item 20 in
          Appendix E-l of the  Security Manual), attach the form
          to the outside of the envelope or shipping box.

     e.    Give the package to  the Product Manager Team DCA, who
          will retain the yellow control copy from EPA Form
          7710-9 and put the package  at the contractor's pick-up
          station.

     f.    When the material is returned from the contractor to
          the PM team, the DCA will record it on the yellow
          control  copy from EPA Form  7710-9 and hand the
          material to the reviewer or hold it in a security
                        RD-4

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          cabinet  as  specified in Section IV, until such time as
          he/she can  hand  it to the reviewer.

(6)   When a reviewer  requests microfilming of a change in
     labeling and/or  confidential formula in a registration
     jacket,  he/she will:

     a.    Obtain a CBI  red cover sheet  (or if unavailable, use
          the alternate cover specified in Section VI) and the
          receipt  form  entitled "Receipt of Confidential Data"
          from the Product Manager Team DCA.  Place the red
          cover sheet on top of the confidential data in the
          jacket and  affix the receipt form to the front of the
          jacket*

     b.    Take the registration jacket to the DCA, who will log
          the jacket  out on the Microfilm Service
          Request/Transmittal form.

     c.    Indicate clearly on the  "Receipt of Confidential Data"
          form that the material in the jacket is to be
          microfilmed,  and that upon  completion of the
          microfilming  the jacket  is  to be returned to the
          reviewer by the  contractor.

     d.    Insert the  jacket in a brown, gummed envelope with  the
          words CONFIDENTIAL BUSINESS INFORMATION and TO BE
          OPENED BY ADDRESSEE ONLY printed or stamped on the
          outside, and  seal.  If more than one jacket is
          involved, use a  12 x 10  x 8 shipping box ordered
          through  the GSA  supply store with only the
          contractor's  full mailing address on it.

     e.    Place the envelope in a  second brown, gummed  envelope
          with only the contractor's  full mailing address on  it
          and put  it  at the contractor's pick-up station.

     f.    When the jacket(s) is  (are) returned from the
          contractor  to the reviewer, the Product Manager Team
          DCA will return  it  (them) directly  to the RD  File  Room.

(7)   When a reviewer  requests coding  of a change in labeling
     and/or confidential formula,  he/she will:

     a.    Obtain a CBI  red cover  sheet (or  if unavailable, use
          the alternate cover  specified in  Section VI,  and the
          receipt  form  entitled  "Receipt of  Confidential Data"
          from the DCA.  Place the red cover  sheet on top of  the
          confidential  data in the jacket and affix the receipt
          form to  the front of the jacket.

     b.    Take the material to the Product  Manager Team DCA  so
          that the DCA  can log the material  out on the  ICS Data
          Request  form.

                        RD-5

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          c.   Indicate clearly on the "Receipt of Confidential Data"
               form that the material is to be coded,  and that upon
               completion of the coding the confidential material is
               to be returned to the reviewer by the contractor.

          d.   Place the CBI red cover sheet on top of the
               confidential material, insert the material in a brown,
               gummed envlope with the words CONFIDENTIAL BUSINESS
               INFORMATION and TO BE OPENED BY ADDRESSEE ONLY printed
               or stamped on the outside, and seal.  If the material
               is too bulky for the envelope, use a 12 x 10 x 8
               shipping box ordered through the GSA supply store with
               just the contractor's full mailing address on it and
               put it at the contractor's pick-up station.

          e.   Place the envelope in a second brown, gummed envelope
               with only the recipient's full mailing address on it
               and put it at the contractor's pick-up station.

          f.   When the jacket(s) is (are) returned from the
               contractor, the Product Manager Team DCA will return
               it (them) directly to the RD File Room.

B.   Amended Registrations.  The following procedures are to be
     followed in handling CBI submitted in support of an amended
     registration:

     (1)  Upon receiving an amendment containing confidential data in
          the mail, the reviewer will obtain from the PM Team DCA a
          CBI red cover sheet (or if unavailable will use the
          alternate cover specified in Section VI, 1B(2)), affix the
          cover sheet to the top of the material, and have the DCA
          take it to PCB for an accession number; the PM Team DCA
          will then return with the accessioned material to the team
          for further processing as described in Ic or d.

     (2)  If the amendment is received through PCB, the reviewer will
          follow the procedures for new registrations in 1.

     (3)  Where a reviewer from TSS or BED requests CBI, the PM
          Team's reviewer will obtain the information from the
          Company Data Library and transmit the material according to
          the procedures in Ic or d.

     (4)  If the registration is approved, the procedures specified
          in Id (6) of this Section will be followed.  If the
          registration is denied, the procedures specified in Id (7)
          will be followed.

C.   Tolerance Petitions.  The following procedures are to be
     followed in handling CBI submitted in support of a tolerance or
     exemption from tolerance:
                             RD-6

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(1)   A tolerance petition  coming  into the Product Manager Team
     through PCS will have a  CBI  red cover sheet (or if
     unavailable/ the alternative specified in Section VI,
     1B(2))  on it identifying it  as containing CBI.  Upon
     receiving the petition,  the  receiving cleric or otherwise
     authorized person will immediately  log the petition in as
     usual (or see that it is logged in) and move it to the
     appropriate reviewer  for review.  The reviewer will
     transmit the necessary copies of CBI-containing data to HED
     in accordance with the procedures specified in 1 d(l)-(5).
     Duplicate numbered copies of the data will be given to the
     DCA to  take to the Company Data Library for storage or
     disposal.

(2)   If in the course of reviewing the submission, the reviewer
     finds it necessary to photocopy CBI for transmittal outside
     Registration Division, he/she will  obtain from the DCA the
     form entitled REQUEST TO COPY OPTS  CONFIDENTIAL BUSINESS
     INFORMATION.  After filling  out the request form, the
     reviewer will obtain  his/her Product Manager's concurrence
     on the  form approving the request.  The form will then be
     taken by the reviewer, DCA,  or otherwise authorized person
     on the  team to the OPP Confidential Document Copy Center
     where the requested number of copies will be made by the
     DCA operator in charge.   The copies will be numbered,
     logged  and entered into  the  tracking system.   (A product
     manager desiring to photocopy CBI may fill out the same
     form at the OPP Confidential Document Copy Center without
     getting his branch chief's approval.)  When the reviewer is
     no longer actively working on the submission, the
     correspondence jacket will be stored in a secured cabinet
     as specified in Section  IV,  1, of this manual unless the
     material in it is used as a  reference source,  in which case
     it will be kept locked in the reviewer's desk.

(3)   In those cases where  a reviewer  requests typing of material
     containing CBI from a contractor, he/she will  follow the
     procedures specified  in  1 e.

(4)   In those cases where  a reviewer or  Product Manager sends a
     Federal Register document accompanied by Chemistry and
     Toxicology Branch reviews which contain CBI to the Federal
     Register Section or hand carries  a  final document
     accompanied by such reviews  for concurrence, he/she will:

     a.   Obtain a CBI red cover  sheet  (or if unavailable, use
          the alternative  specified  in  Section VI,  lb(2)) from
          the DCA and place it on top  of the CBI-containing
          material.

     b.   Transmit the material in a  brown,  gummed envelope with
          the words CONFIDENTIAL  BUSINESS  INFORMATION  stamped or
          printed on the outside.
                        RD-7

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D.   Amended Tolerance Petitions.  Ihe following procedures  are  to  be
     followed in handling CBI submitted in support of an amended
     tolerance petition.

     (1)  Upon receiving an amendment containing confidential data  in
          the mail, the reviewer will obtain from the PM Team DCA a
          CBI red cover sheet (or if unavailable, use the alternative
          specified in Section VI, lb(2)), affix the cover sheet to
          the top of the material, and take it to PCB for an
          accession number, then return with the material to the team
          for further processing as set forth in 3a and b.

     (2)  If the amendment containing confidential data is received
          through PCB and the reviewer requests an BED review, he/she
          will transmit the data in accordance with the procedures
          specified in lD(l)-(5).

     (3)  When a reviewer from BED requests CBI in order to  review
          the amendment, the PM Team reviewer will obtain the
          information from the Company Data Library and transmit the
          material according to the procedures in lD(l)-(5).

     (4)  Upon completion of the amendment action (approval  or
          rejection), the correspondence jacket will either  be kept
          in a secured cabinet as specified in Section IV, 1, or
          transferred to the Company Data Library by the DCA.

E.   RPARs.  In those cases where a reviewer from the Special
     Pesticide Review Division (SPRD) requests CBI in connection with
     a Rebuttable Presumption Against Registration action, the PM
     Team reviewer or otherwise authorized person will obtain the
     data from the DCA in the Company Data Library, return with  the
     CBI to the team where it will be transferred to SPRD in
     accordance with the procedures set forth in ld(l)-(5).   When the
     material is returned to the PM Team reviewer from SPRD, he/she
     will return it to the Company Data Library or give it to the DCA
     or otherwise authorized person, who will return it to the
     Company Data Library.

F.   Congressional Material.  In transmitting CBI to a Congressional
     Committee, obtain the blue Privileged Information Control Record
     from the DCO and affix it to the front of the envelope
     containing the CBI.  As in Section VI 4A of the manual, this
     material is transmitted through the office of the Deputy
     Assistant Administrator of OPP.

G.   Miscellany.  Problems arising in connection with infrequent
     actions which are covered in other sections of this manual, such
     as destruction of CBI, transmittal of CBI outside EPA,  requests
     from registrants to photocopy their own CBI, and requests from
     divisions other than HED and SPRD for CBI, should be referred to
     the DCO.  Any CBI problems not covered by these procedures
     should be referred to the DCO.  In any unusual situation
     involving CBI, do not act on your own; always call the DCO.

                             RD-8

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2.   PROCESS COORDINATION BRANCH PROCEDURES

     The following security procedures for the Process Coordination Branch
     are listed by administrative or operational units:

     A.   Coordination Section.

          (1)  Nail Room.  The mail clerks will separate out the
               CBI-marked mail from the non-CBI mail by putting the CBI
               mail in a locked  box, which will be transported on the mail
               cart along with the non-CBI mail as part of the regular
               mail run.  The CBI mail will  be delivered along with the
               non-CBI mail except that it will be kept in the locked box
               until it is brought to its destination.  The mail room will
               never be left open unattended.  No employees other than
               mail room personnel will normally be permitted inside.  If
               for any reason, mail room personnel cannot be in
               attendance, the door will be  locked and a sign posted on it
               saying when the personnel will return.

          (2)  Registration Support Team. The DCA in the Registration
               Support Team will receive the submission (registration
               application/amendment or tolerance petition/amendment) and
               determine whether or not it contains CBI unless the
               submitter has already claimed that it contains CBI.  If it
               does and it is a  registration action, the DCA will hand
               carry the submission to the clerk- typist, who assigns a
               file symbol and registration  number.  If the submission is
               a tolerance petition, the DCA will hand carry it to a team
               member, who puts  it in a jacket and assigns a petition
               number.  The clerk- typist will stamp on the jacket
               CONFIDENTIAL BUSINESS INFORMATION  - DOES NOT CONTAIN
               NATIONAL SECURITY INFORMATION (E.O. 12065) and place a CBI
               red cover sheet (or a substitute as specified in Section
               VI, 1B(2) of this manual) on  top of the material.  The
               submission will then be processed  through the team as usual
               in accordance with the regular work procedures as well as
               the routine security procedures outlined in Section  IV of
               this manual.

          (3)  Liaison Team.

               a.   Upon receipt of the submission from the clerk-typist
                    in the Registration Support Team, the Liaison Team
                    clerk will hand carry the  submission as usual to the
                    pesticide clerk on the Product Manager Team.  If the
                    Liaison Team clerk is unable  to  complete delivery of
                    the submission by close  of business, he/she will store
                    it in a secured cabinet  as  specified in Section IV, 1,
                    and make delivery the morning of the next work  day.

                    (In the case of confidential  data to be sent to HED,
                    'the originator will already have prepared the package
                                  RD-9

-------
     in accordance with security procedures;  thus,  the
     Liaison Team Chemist in addition to performing the
     usual operations of prioritization  and assignment of a
     projected completion date,  need only  fill out  the Data
     Review Record when the package goes out  to  HED and
     when it comes back in.)

b.   Upon receiving in the mail an inert ingredient
     submission containing confidential  data  which  must  be
     sent to HED for review, the Inert Ingredient Product
     Manager will:

     _1_.   Obtain from the DC A in the Liaison  Team the form
          entitled REQUEST TO COPY OPTS  CONFIDENTIAL
          BUSINESS INFORMATION.  After filling out  the
          request form, the Inerts Product Manager  will
          obtain the Coordination Section  Chief's
          concurrence on the form approving the  request.
          The form will then be taken by the  Inerts PM or
          otherwise authorized person on the  team to the
          OPP Confidential Document Copy Center  where the
          required number of copies will be made by the  DCA
          operator in charge.

     2.   Log the data out on the Data Review Record
          (including assigning a control number  and dating).

     3»   Obtain from the Liaison Team DCA a  CBI red cover
          sheet (or if unavailable, use  the alternate cover
          specified in Section VI, 1B(2))  and the "Receipt
          of Confidential Data" form.

     4^   Attach the cover sheet and the Data Review Record
          on top of the data.

c.   Give the package to the DCA of the Inert Ingredient
     Product Manager Team to hand carry to the Liaison Team
     Chemist (for prioritizing and completion date) from
     where it will be transferred to HED.

d.   When the CBI is returned to PCB, the  Liaison Team
     Leader, DCA, or otherwise authorized  person on the
     Inert Ingredient Product Manager Team will pick up  the
     material.  The DCA will log the material back  in on
     the Data Review Record.

e.   Where the Liaison Team Leader is to transmit to OGC a
     final Federal Register document which includes HED
     reviews containing CBI, the Team Leader will obtain
     from the Liaison Team DCA a CBI red cover sheet (or a
     substitute as specified in Section VI,  1B(2)>  and the
     "Receipt of Confidential Data" form and attach them to
     the front of the document folder, place the folder in
                   RD-10

-------
               a brown, gummed envelope,  seal  and address the
               envelope, and then take the package to the DC A, who
               will stamp on the outside  CONFIDENTIAL BUSINESS
               INFORMATION - DOES NOT CONTAIN  NATIONAL  SECURITY
               INFORMATION (E.O. 12065).   The  Team Leader will then
               give the package to the Coordination  Section
               Secretary, who will hand carry  the package to OGC.
               The Secretary will pick up the  package from OGC when
               it has been signed off (including the "Receipt of
               Confidential Data") and return  the package to the Team
               Leader.
B.   Emergency Response Section.

     (1)  Emergency Exemption Team.
               The Emergency Exemption Team receives specific
               exemption requests from states and Government agencies
               through the mail room, the Process Coordination
               Branch, the Communications Center, and Federal
               Express.  After processing the request in accordance
               with established team procedures,  the Secretary will
               transmit the request to the front-end reviewer to
               determine whether scientific reviews are needed.  If
               in connection with a specific exemption request, the
               front-end reviewer receives CBI, he/she should obtain
               from the Emergency Response Section DCA a CBI red
               cover sheet (or a substitute as specified in Section
               VI, paragraph 1B(2)) and attach it to the material if
               this has not already been done.  In the course of
               reviewing such a CBI-containing request, all reviewers
               will follow the routine security procedures outlined
               in Section XV, (paragraph 3), of this manual.  In
               those cases where a review is requested from the
               Hazard Evaluation Division (HED),  the front-end
               reviewer will:

               JL.   Obtain from his/her DCA the form entitled REQUEST
                    TO COPY OPTS CONFIDENTIAL BUSINESS INFORMATION.
                    After filling out the request form, the reviewer
                    will obtain his/her supervisor's concurrence on
                    the form approving the request.  The form will
                    then be taken by the reviewer, DCA, or otherwise
                    authorized person on the team to the OPP
                    Confidential Document Copy Center where the
                    requested number of copies will be made by the
                    DCA operator in charge.  The copies will be
                    numbered and entered into the tracking system.
                    (A supervisor desiring to photocopy CBI may fill
                    out the same form at the OPP Confidential
                    Document Copy Center without getting his/her
                    supervisor's approval.)  While the reviewer is no
                    longer actively working on the request, the
                             RD-11

-------
               jacket should be stored in a secured  cabinet  as
               specified in Section IV of this manual.

          2.   Log out the data on the usual Data Review  Record
               (including assigning a control number and  dating).

          3^   Obtain from the Emergency Response Section DCA a
               CBI red cover sheet (or if unavailable,  use the
               alternate cover specified in Section  VI, 1B(2))
               and the "Receipt of Confidential  Data" form.

          ^.   Attach the cover sheet and Data Review Record on
               top of the data.

          ^.   Rand carry the package to PCB (for prioritizing
               and completion date) from where it will  be sent
               to HED.

          £•   When the CBI is returned to PCB,  the  front-end
               reviewer or other authorized person in the
               Emergency Response Team will pick up  the material.

          !_•   After the reviews are completed,  should a
               reviewer find it necessary to destroy extra
               copies of confidential data, he/she will:

               a^   Obtain from the Emergency Response Section
               ~    DCA the form entitled REQUEST TO DESTROY
                    OPTS CONFIDENTIAL BUSINESS  INFORMATION.

               b.   Fill out the form and have  it approved by
               ~~    the DCO.

               c.   Hand carry the data in a brown,  gummed
                    envelope or 12 x 10 x 8 shipping box  to the
                    OPTS Paper Pulverizer in Waterside Mall,
                    where it will be destroyed  by authorized
                    personnel.

b.   Where a reviewer receives a tolerance petition/amendment
     containing CBI, the reviewer will:

     TL»   Follow the routine security procedures outlined in
          Section IV, 3, and transmit the necessary copies of
          confidential data to HED in accordance with the
          procedures specified in 2a(l)(a)-(e)  in this section
          of the security manual.

     2.   Where the reviewer is to transmit to OGC a final
          Federal Register document which includes HED reviews
          containing CBI, the reviewer will obtain from the
          Emergency Response Section DCA a CBI red cover sheet
          (or a substitute as specified in Section VI, 1B(2))
          and the "Receipt of Confidential Data" form and attach

                        RD-12

-------
     them to the front of the document folder, place the
     folder in a brown, gummed envelope,  seal and address
     the envelope,  and then take the package to the OCA,
     who will stamp on the outside CONFIDENTIAL BUSINESS
     INFORMATION -  DOES NOT CONTAIN NATIONAL SECURITY
     INFORMATION (E.O. 12065).  The reviewer will then
     either hand carry the package to OGC or give the
     package to an  otherwise authorized person who will
     hand carry it  to OGC.  The reviewer  or otherwise
     authorized person will pick up the package from OGC
     when it has been signed off (including the "Receipt of
     Confidential Data" form).

3_.   Where the reviewer is to transmit to RED or SPRD a
     final Federal  Register document which includes HED
     reviews containing CBI, the reviewer will obtain from
     the DCA a CBI  red cover sheet (or a  substitute as
     specified in Section VI, 1B(2)) and  the  "Receipt of
     Confidential Data" form and attach them to the front
     of the document folder, place the folder in a brown,
     gummed envelope, seal and address the envelope, and
     then take the  package to the DCA, who will stamp on
     the outside CONFIDENTIAL BUSINESS  INFORMATION - DOES
     NOT CONTAIN NATIONAL SECURITY INFORMATION  (E.O.
     12065).  After logging out the document  on the Data
     Review Record, the reviewer will  then hand carry the
     package with copies of the Submission Review Record
     attached to the Liaison Team Chemist for
     prioritization and completion date.   When  the signed
     document comes back from HED or SPRD (including the
     "Receipt of Confidential Data"),  the reviewer or
     otherwise authorized person will  pick it up  from PCB.

4^.   Where the reviewer is to transmit  to the Director  of
     the Registration Division a final Federal  Register
     document which includes HED reviews  containing  CBI,
     the reviewer will place the document with  the  CBI  red
     cover sheet (or its substitute)  in the out box  of  the
     Emergency Response Section from where it will  be
     delivered by the Section Secretary or otherwise
     authorized person to the office of the PCB Chief  for
     concurrence and transmittal to the Registration
     Division Director's office for sign-off.  (After
     sign-off by the Director, the document will  be
     forwarded to the Federal Register Section by the
     Director's office using its own delivery procedures.)

5.   After the reviews are completed/  should the reviewer
     find it necessary to destroy extra copies  of
     confidential data, he/she will:

     a.   Obtain from the Emergency Response Section DCA
          the form entitled REQUEST TO DESTROY OPTS
          CONFIDENTIAL BUSINESS INFORMATION.

                   RD-13

-------
                    Jb.   Fill out the form and  have  it approved by the DCO.

                    £.   Hand carry the data  in a  brown,  (jammed envelope
                         or 12 x 10 x 8 shipping box to the OPTS Paper
                         Pulverizer in Waterside Mall, where it will be
                         destroyed by authorized personnel.

          (2)   I.  D. Team.  When in the course  of  reviewing an enforcement
               action, the reviewer requires  a  registration jacket
               containing CB1, he/she will have the  I. D. Team clerk get
               it  from the Product Manager Team and  process it in
               accordance with the usual work procedures.  In the course
               of  reviewing the material,  the reviewer should follow the
               routine security procedures outlined  in Section IV, 3, of
               this manual.  In those cases where  a  reviewer requests a
               review from a Technical Support  Section  (TSS), the
               Emergency Response Section's DCA will log  out the data on
               the Data Review Record (including assigning a control
               number and dating).  After obtaining  a CBI red cover sheet
               (or a substitute as specified  in Section VI, 1B(2)) from
               the Response Section DCA and affixing it on top of the
               CBI-containing material, the reviewer will give the jacket
               to  the I. D. Team clerk, who will then hand carry the
               material to the receiving clerk  or  DCA  in  a TSS for logging
               in.  (The Herbicide-Fungicide  TSS requires that all CBI
               material be received by the DCA  only.)  When the TSS clerk
               delivers the material with the completed TSS review back to
               the I. D. Team, the I. D. clerk  will  immediately log the
               jacket back in and hand the package to  the reviewer.  Every
               effort should be made to minimize the time that the jacket
               lies around in the in-box.   When the  reviewer no  longer
               needs the registration jacket, he/she will give it to the
               I.  D. clerk, who will log it out and  hand  carry it back  to
               the original Product Manager Team.

3.   TECHNICAL SUPPORT SECTION SECURITY PROCEDURES

     A.   Upon receipt of a registration jacket and/or a  submission  to  be
          reviewed, the TSS clerk or DCA will log  in the  material  in the
          Section's log book and then store the package  in a  secured
          cabinet  as specified in Section IV, 1, of  this  manual  until  a
          reviewer is ready to work on the submission.  The jacket  or
          submission should already be stamped  CONFIDENTIAL BUSINESS
          INFORMATION - DOES NOT CONTAIN NATIONAL  SECURITY INFORMATION
          (E.O. 12065) and contain a red CBI, cover sheet  over  the
          confidential data.  If this has not been done,  the  clerk  or
          secretary should give the package to  the section's  DCA, who will
          correct the deficiencies.

     B.   In the course of reviewing the submission, the  reviewer will
          follow the routine security procedures outlined in Section IV,
          3, of this manual.
                                  RD-14

-------
(1)   In those cases where a reviewer  requests typing of a  review
     containing CBI from a contractor,  he/she will:

     a.   Obtain a CBI red cover sheet  (or  a substitute as
          specified in Section VI,  1B(2)) from  the  DCA and place
          it on top of the draft.

     b.   Place the material in a brown,  gummed envelope  (or a
          12 x 10 x 8 shipping box ordered  through  the GSA
          supply store if a large number  of reviews are
          involved) addressed to the contractor with the  words
          CONFIDENTIAL BUSINESS INFORMATION and TO  BE  OPENED BY
          ADDRESSEE ONLY printed or stamped on  the  outside.

     c.   Place the envelope inside a second brown, gummed
          envelope with only the recipient's full mailing
          address on it if the 12 x 10 x  8  shipping box  is not
          used.

     d.   Obtain from the DCA, EPA Form 7710-9 "Request for
          Typing/Editing," and after filling out the form
          completely, including  inserting the words CONFIDENTIAL
          BUSINESS INFORMATION in block 20, attach the form to
          the outside of the envelope or 12 x 10 x 8 shipping
          box.

     e.   Give the package to the DCA, who will retain the
          yellow control copy from EPA Form 7710-9.

(2)  The DCA will then hand carry the package to the branch
     office, where he/she will put it in the contractor's
     pick-up box.

(3)  When the typed final is returned from the contractor,  the
     DCA will pick it up from the return box in the branch
     office, log it in on the yellow control copy  of  the  EPA
     Form 7710-9, and hand  it to the reviewer  or hold it  in a
     secured cabinet as  specified in Section IV, 1, until such
     time as he/she can  hand  it  to the reviewer.

(4)  When the typed final has been signed off  and  is  ready to go
     back to the originator,  the reviewer will link it up with
     the rest of the original  jacket and/or submission and hand
     the package to  the  clerk  or DCA,  who will log it out in the
     Section Log Book and  return it  to the originator.
                        RD-15

-------
                             REGISTRATION DIVISION DATA REVIEW RECORD

  Confidential Business Information - Does Hot Contain National Security Information (1.0. 12065)

    Chemical  lame
                                                               I To Be Completed By PM
    Identifying "umber    3.  Action Code  4.  Accession Bumber
                                                                 5.  Record Mumber	
                                                                 6.  lUterence Number	
                                                                 7.  Data Received (SPA)_
                                                                 8.  Statutory Due
                                                                 9.  Product Manager
                                                                 10.  PN Team Number
                                                               I To Be Completed By PCB
                                                               I
                                                               111.  Data Sent to HRD/TSS
                                                               I
                                                               |12.  Priority Humber	
                                                               I
                                                               (13.  Projected Return Date
14.  CHECK TUX FOLLOWING IF APPLICABLE:

    MPublic Health/Quarantine   MHinor Use
    QSubstitute Chemical        l_|Part of IPM
    j~!Seasonal Concern           |_|Review Requires
     ~                               Less Than 4 Hrs.

15.  INSTRUCTIONS TO REVIEWER

    A.  HBD   IJTotal Assessment - 3(c)(5)  C.  IJ BFSD  D.   Q  TSS/RD  I.   Q Other
              |_|Incremental Risk Assessment -
               ~" 3{c)(7) and/or B.L. Johnson F.  Instructions	
                 memo of May 12, 1977.
    B.  SPRD  (Send Copy of Form to SPRD PM)

              |  (Chemical Undergoing Active
              ~ RPAR Review

              |_|Chemical Undergoing Active
                 Registration Standards Review

16.  Related Actions:
              17.  3(c)(l)(D)

              I  |  Use Any or  All Available Information    |_|  Use Only Attached Data
              I  I  Use Only the Attached Data'for Formulation and Any or All Available
                   Information.  On the Technical or Manufacturing Chemical.

              18.  Reviews Sent To:  |~|TB  M RGB  |~|EEB  |~|EFB  |~|EF   |~|CH   |~|PL
19








TO








TYPE OF REVIEW
TOXICOLOGY
ECOLOGICAL EFFECTS
RESIDUE CHEMISTRY
ENVIRONMENTAL FATE
CHEMISTRY
EFFICACY
PRECAUT. LABELING
ECONOMIC ANALYSIS
REGIS.








PETIT.








EUP








SLN








SEC. 18








INERT








US








OTHER |
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
          20.  |_l  Label Submitted With Application Attached.
                                                                  21.   |_|  Confidential Statement
                                                                            of Formula Attached
          22.

          23.

          24.
                |_|   Representative Labels Showing Accepted Uses Attached.

                Data Returned to RD   (to be completed by BED) 	
               Include an Original and 4 (four) Copies of This Completed Form for Bach Branch
               Checked for Review.
                                                   RD-16

-------
                    SPECIAL PESTICIDE REVIEW DIVISION
                           SECURITY PROCEDURES

1.   Procedures for Receiving CBI into  SPRP Document Control Officer
     Responsibilities

     As soon as documents containing CBI are received in SPRD, they will
     be hand carried to the DCO/DOA located in Room 724B.  The DCO/DCA
     will maintain a control log and using the FIFRA procedures will
     transmit the information to the appropriate branch, assuring that the
     project manager signs for the information.  The DCO will assure that
     this data is kept in an approved CBI file cabinet.

     In the event that the chemical has not been assigned to a branch, the
     DCO/DCA will log in the CBI information and retain it in her/his
     locked file until it is assigned.

     The DCO also maintains a separate  log transmitting to and receiving
     data from the typing contractor and ensures that the log is
     initialled when data is picked up  and delivered by the contractor and
     the branch involved.  See Attachment 3.

2.   Section Chief and Project Manager  Responsibilities

     The section chief is responsible for overseeing the security of the
     CBI information within his/her section.

     The project manager is responsible for maintaining security of the
     data he/she is currently working on.  He/she  is also responsible for
     obtaining any information not previously assigned from the DCO and
     signing for it.  The project manager will be  responsible for logging
     CBI information through the DCO/DCA when sending the information to
     another division for review.

3-   Procedure for Safeguarding Proprietary Information from Unauthorized
     Release

     Project managers must prepare and  attach a bibliographic  reference
     sheet to all packages submitted by the Special  Pesticide  Review
     Division (SPRD) to other groups for validation  or assessment.
     References must be identified as to their status  if  they  are
     confidential from a company source.  Data referenced may have
     originally been submitted to EPA by registrants of pesticide products
     and/or petitioners for a tolerance.  The company has certain rights
     to confidentiality of such data under appropriate statutes.

     It is the responsibility of each Project Manager  to  assure  the status
     of all references before they are  released to any other  group, either
     inside or outside the Agency.  Project Managers can  refer to agency
     regulations for safeguarding proprietary data for definitions and
     examples of confidential data.  These regulations were published
                                 SPRD-1

-------
         in the Federal Register and SPRO's Administrative Officer has a copy
         on file.  The PM's can also consult the Office of Pesticide Programs
         Freedom of Information (FOI) Officer or staff in the Information
         Services Branch, Program Support Division for clarification of the
         status of a document or assistance in obtaining clearance.  The FOI
         Officer maintains a listing of data and companies to which the data
         belong.  The status of data submitted to the Agency for registration
         of pesticide products is considered confidential unless otherwise
         identified under the FOI.  If all or part of such data has been
         officially cleared through the FOI system, then an official letter
         written by the FOI office will be included in the file indicating
         such.  The Project Manager must place a copy of this release letter
         in the RPAR files and indicate the status in bibliographic citations.

         Data found in the open literature through either computer based
         searches or manual searches are totally releaseable without going
         through the FOI officer.  If a reference found in the open literature
         is also cited in a company file, then the reference would not be
         considered confidential or trade secret if it is identical in all
         respects.

         An example of how references should be marked follows.  All citations
         are non-confidential unless marked with the C.  C indicates
         confidential data which should not be released.

                                  BIBLIOGRAPHY*

         1.   Amer, S.M. And E.M. Ali
              Cytological Effects of Pesticides
              Cytologia,  39:633-643.  1974

         2.   Buu-Hoi, N.P. et al.
              Biochemistry:  Carcinominmetic Properties of
              Tetrachloro-2,3,7,8  Debenz o-p-dioxin.
              C.R. Acad. Sc. Paris,x272:1447-1450.  1971

         3.   Goto, M. Et al.
              Contributions to the Ecological Chemistry.  II.
              Hepatoma Formation in Mice after Administration
              of high Doses of BHC isomers.
              Ehcmosphere.  1 (6):279-282.  1972

         4.   Green, Sidney
              Cytogenetic Evaluation of Several Dioxins in the
              rat.  Draft Documents (Confidential).

*A11 requests for copies of the referenced material must be submitted to the
Freedom of Information Officer, Office of Pesticide Programs.  A cost of $0.20
per page is charged for reproduction.
                                     SPRD-2

-------
     Confidential/proprietary information used during the RPAR process and
     ultimately retained as part of the administrative record must be
     identified with a confidential red cover sheet (Appendix C2 in
     manual).  The precautionary statements on the red cover sheet are to
     be followed without exception.

     SPRD's DCO maintains a supply of confidential red border cover
     sheets.  Work papers and working drafts must be stamped with "FOR
     OFFICIAL USE ONLY ~ Public availability to be determined unde 5
     U.S.C. 522."  All branches have been given a supply of these stamps
     and others can be purchased at the GSA Self-Service Store.

4.   COMPUTER SECURITY

     The Special Pesticide Review Division has a secure,
     password-protected computer system which is limited to authorized
     users only.  Ihe system also has the capability to keep records on
     system use by each operator.

     The system has both a back up disk and tape which enable the Division
     to recover accidently lost information if the disk or tape systems
     fail.  These disks and tapes are stored in a locked cabinet at the
     end of each working day.
                                 SPRD-3

-------
                                                                 SPRD Attachment 1
    ENVIRONMENTAL PROTECTION AGENCY
SPRD CONFIDENTIAL BUSINESS INFORMATION
        INVENTORY LOG AND USER
           COPY SIGN OUT LOG
a



















SPRD
Doc.
No.



















No.
of
Pages



















Rec.
From



















Description



















Cover
sheet
Attached



















Date/Time
Checked
Out



















Last
Name
















.


Signature



















Date
Returned



















Destroyed
Date
Name
ID
Recp.
Rec.
















Returned
to
Sender
Date
Name
ID

















DCO
Initials






«•
*
CO








1
1

-------
                                                              SPRD Attachment 2

                    CONFIDENTIAL BUSINESS INFORMATION RECEIPT
Control No.
Raven Request No.

Branch
Preparer's Name & Phone Number:
              Received by
                         Contractor's Signature

              Date
RETURN THIS FORM TO TS-791,
Special Pesticide Review Division
Room 724B, Crystal Mall Bldg. 2
                                      SPRD-5

-------
                                                                    SPRD  Attachment  3
CONFIDENTIAL BUSINESS INFORMATION TRANSMITTING LOG:
Brancii    (Contractor  (C.B.T.

           Request No. (Control No.
             Signature,  Date &  Time of  Persons Transmitting/Receiving Document
     In  to Dir Off    Out to Contractor
In from Contractor
In to Branch
                                                                                       VO


                                                                                       §
                                                                                       0.
                                                                                       w

-------
                                 APPENDIX A-1
I.  ACCESS AUTHORIZATION FOR FIFRA CONFIDENTIAL BUSINESS INFORMATION (CBI)
Full Name                EPA ID    '   Position        Office (include Division
IT IS THE RESPONSIBILITY OF EACH AUTHORIZING OFFICIAL**TO ENSURE THAT EMPLOYEES
UNDER HIS/HER SUPERVISION OBTAIN ACCESS ONLY TO THAT INFORMATION REQUIRED TO
PERFORM OFFICIAL DUTIES UNDER FIFRA.
Signature of Authorizing Official                            Date
Title                                                 Location
Local Document Control Officer  (DCO)	Phone	

Designating Officials Must be Division Directors  (or Equivalent) or Above
II.

                   CONFIDENTIALITY AGREEMENT  FOR  EPA  EMPLOYEES

I understand that I will have access  to  certain Confidential  Business
information submitted under the Federal  Insecticide,  Fungicide  and  Rodenticide
Act as amended by PL 92-396.  This access  has been  granted  in accordance  with
my official duties as an employee of  the Environmental  Protection Agency.

I understand that the FIFRA Confidential Business Information may not  be
disclosed except as authorized by FIFRA  and Agency  regulations.   I  understand
that undersection 10f of FIFRA, I am  liable to a  possible fine  of up to $10,000
and/or imprisonment for up to one year if  I will  fully  disclose FIFRA Confiden-
tial Business Information to any person  not authorized  to receive it.   Addi-
tionally, I understand that according to section  114(b)(3), FIFRA provides for
a penalty of up to $10,000 and up to  three (3) years  imprisonment for
disclosure of formula information (manufacturing  process, quality control
processess, and production data) with intent  to defraud.

I agree that I will treat FIFRA Confidential  Business Information furnished to
me as confidential and that I will follow  the procedures  set forth  in the
Office of Pesticide Programs Security Manual.

I have read and understand the procedures.

I am aware that I may be subject to criminal  penalties  under 18 U.S.C. 1001 if
I have made any statement of material facts knowing that  such statement is
false or if I willfully conceal any material  fact.
Signature                                    Date
Name  (Print)                                 EPA I.D. Number

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                                 APPENDIX A-2

                        CONFIDENTIALITY AGREEMENT FOR

             UNITED STATES EMPLOYEES UPON TERMINATION OR TRANSFER

In accordance with my official duties as an employee of the United  States,  I
have had access to Confidential Business Information under the  Federal
Insecticide, Fungicide, and Rodenticide Act as  amended  (FIFRA,  7  U.S.C.  136 et
seq.).  I understand that FIFRA Confidential Business information may not  be
disclosed except as authorized by FIFRA or Agency regulations.

I certify that I have returned all copies of any FIFRA  Confidential Business
information in my possession to the appropriate document control  officer
specified in the procedures set forth in FIFRA  Confidential Business
Information Security Manual.

I agree that I will not remove any copies of FIFRA  Confidential Business
Information from the premises of the Agency upon my termination or  transfer.
I further agree that I will not disclose any FIFRA  Confidential Business
Informtion to any person after my termination or transfer.

I understand that as an employee of the United  States who has had access to
FIFRA Confidential Business Information, under  section  10(f)  of FIFRA I  am
liable for a possible fine of up to $10,000 and/or  imprisonment for up  to  one
year if I willfully disclose FIFRA Confidential Business Information to  any
person.  Additionally, I understand that according  to section 14(b)(3),  FIFRA
provides for a penalty of up to $10,000 and up  to three (3) years imprisonment
for disclosure of formula information  (manufacturing process, quality control
processes, and production data) with intent to  defraud.

If I am still employed by the United States, I  also understand that I may be
subject to disciplinary action for violation of this agreement.

I am aware that I may be subject to criminal penalties  under  18 U.S.C.  1001 if
I have made any statement of material facts knowing that such statement is
false or if I willfully conceal any material fact.
              SIGNATURE                                     DATE
             NAME                                           ID NUMBER

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                                APPENDIX  B-1

                  FIFRA CONFIDENTIAL  BUSINESS INFORMATION
                     MEETING  SIGN-IN  SHEET (EPA ONLY)
DATE:                             TIME:
PLACE: (Room)	  (Building)	 (City)_

CHAIRPERSON:
SUBJECT OF MEETING:
NAME  (PRINT)      	SIGNATURE	OFFICE/DIVISION/BRANCH     EPA ID
         THIS SIGN-UP SHEET MUST BE GIVEN  TO  THE APPROPRIATE DCO/DC;.

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                               APPENDIX B-2




                            CBI MEETING REPORT




Date 	 Time 	 Location




Subject 	




{and/or) 	            	
EPA Reg. No. 	Pesticide Petition No.




Company(s) Involved	




Pesticide Company Representatives







Printed                         Signed









Printed                         Signed









Printed                         Signed







Brief Summary of Discussion  (For additional space  see addendum)
Action Taken or Recommendation
EPA Representatives Office
Recorder

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                      APPENDIX C-l
   CONFIDENTIAL BUSINESS INFORMATION
               DOES NOT CONTAIN
NATIONAL SECURITY INFORMATION (EO 12065)
     CONFIDENTIAL BUSINESS INFORMATION
                 DOES NOT CONTAIN
  NATIONAL SECURITY INFORMATION (EO  12065)
    SOME INFORMATION IN THE ATTACHED MATERIAL MAY BE ENTITLED
    TO TREATMENT AS TRADE SECRET OR PROPRIETARY DATA UNDER
    SECTION 7(d) AND SECTION 10 THE FEDERAL INSECTICIDE, FUNGICIDE
    AND RODENT1CIDE ACT (FIFRA) AS AMENDED,
SOME INFORMATION IN THE ATTACHED MATERIAL MAY BE ENTITLED
TO TREATMENT AS TRADE SECRET OR PROPRIETARY DATA UNDER
SECTION 7(d) AND SECTION 10 THE FEDERAL INSECTICIDE, FUNGICIDE
ANDRODENTICIDE ACT (FIFRA) AS AMENDED.

ANY PERSON HANDLING OR USING THE ATTACHED DATA IN ANY WAY
IS RESPONSIBLE FOR PREVENTING UNAUTHORIZED DISCLOSURE WHILE
IN HIS POSSESSION. SECTION 12(a)(2)(D) MAKES IT UNLAWFUL FOR ANY
EMPLOYEE TO USE TO HIS OWN ADVANTAGE OR TO REVEAL ANY CON-
FIDENTIAL INFORMATION (EXCEPT TO PERSONS NEEDING THE INFOR-
MATION FOR THE PERFORMANCE OF OFFICIAL DUTIES). A PENALTY OF
UP TO $10,000 FINE AND UP TO 3 YEARS IMPRISONMENT MAY RESULT
FROM CONVICTION OF A VIOLATION ON SECTION 12(a)(2)(D).

SECTION 10(f) MAKES IT A CRIME FOR ANY EMPLOYEE TO DISCLOSE
CONFIDENTIAL INFORMATION EXCEPT AS AUTHORIZED BY SECTION 7
AND 10 OF FIFRA. A PENALTY OF UP TO $10,000 FINE AND UP TO ONE
YEAR IN JAIL MAY RESULT FROM CONVICTION OF A VIOLATION OF
SECTION 10(f).

THE ATTACHED INFORMATION IS NOT TO BE PUBLISHED, REPRODUCED,
PUBLICLY DISCUSSED,  INCLUDED IN RESPONSE TO AN FOI REQUEST
OR OTHERWISE RELEASED WITHOUT THE EXPLICIT WRITTEN AUTHORI-
ZATION OF THE APPROPRIATE DIVISION DIRECTOR OR HIS DESIGNEE.

-------
                     APPENDIX  C-2
   CONFIDENTIAL BUSINESS INFORMATION
                DOES NOT CONTAIN
NATIONAL SECURITY INFORMATION (EO 12065)
  SOME INFORMATION IN THE ATTACHED MATERIAL MAY BE ENTITLED
  TO TREATMENT AS TRADE SECRET OR PROPRIETARY DATA UNDER
  SECTION 7(d) AND SECTION 10 THE FEDERAL INSECTICIDE, FUNGICIDE
  AND RODENTICIDE ACT (FIFRA) AS AMENDED.

  ANY PERSON HANDLING OR USING THE ATTACHED DATA IN ANY WAY
  IS RESPONSIBLE FOR PREVENTING UNAUTHORIZED DISCLOSURE WHILE
  IN HIS POSSESSION. SECTION 12(a)(2)(D) MAKES IT UNLAWFUL FOR ANY
  EMPLOYEE TO USE TO HIS OWN ADVANTAGE OR TO REVEAL ANY CON-
  FIDENTIAL INFORMATION (EXCEPT TO PERSONS NEEDING THE INFOR-
  MATION FOR THE PERFORMANCE OF OFFICIAL DUTIES). A PENALTY OF
  UP TO $10,000 FINE AND UP TO 3 YEARS IMPRISONMENT MAY RESULT
  FROM CONVICTION OF A VIOLATION ON SECTION 12(a){2)(D).

  SECTION 10(f) MAKES IT A CRIME FOR ANY EMPLOYEE TO DISCLOSE
  CONFIDENTIAL INFORMATION EXCEPT AS AUTHORIZED BY SECTION 7
  AND 10 OF FIFRA. A PENALTY OF UP TO $10,000 FINE AND UP TO ONE
  YEAR IN JAIL MAY RESULT FROM CONVICTION OF A VIOLATION OF
  SECTION 10(f).

  THE ATTACHED INFORMATION IS NOT TO BE PUBLISHED, REPRODUCED,
  PUBLICLY DISCUSSED, INCLUDED IN RESPONSE TO AN FOI REQUEST
  OR OTHERWISE RELEASED WITHOUT THE EXPLICIT WRITTEN AUTHORI-
  ZATION OF THE APPROPRIATE DIVISION DIRECTOR OR HIS DESIGNEE.

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                     V-
            APPENDIX O3
mloam Biuitss mmxim - DOES
NOT CONTAIN NATKOL SECORiTY INFORMATION
(E.0.12065)

-------
    tttVIRGNHKNTAL PROTECTION AGENCY
PIFRA CONFIDENTIAL BUSINESS INFORMATION
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USER INFORMATION
Last NAM










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Date
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Contents











-------
                                            APPENDIX E-l
DATE OF REQUEST
                                 REQUEST FOR TYPING/EDITINC
                                                                        REQUEST NUMBER
                                                                        2N9   35557
                                         REQUESTOR
NAME
                                  OFFICE
                                                     LOCATION
                                                                              PHONE NO.
                                       TYPE OF ORIGINAL
        '• | MEMO
                       i  I FORM LETTER
                           !|REPORT
                                       TYPING REQUIRED
               DOUBLE-SPACED DRAFT





                    TYPED FINAL
                         ^DOUBLE-SPACED DRAFT, SPECIAL FORMAT





                         ~3CLEAN TYPED FINAL. SPECIAL FORMAT
                EDITING REQUIRED
                              MAGNETIC CARD REQUIRED
   9 ~1 LIGHT EDITING
SUBSTANTIVE EDITING
10
                                 REQUESTED TURNAROUND TIME
  11  j  | OVERNIGHT
  1  I 24 HOUR
    CD 2 DAY
                                                     DAY
                                        ACTION DATES
                                     .BATE?
RECEIVED BY PROJECT OFFICER
                                      12
                                               RECEIVED FROM CONTRACTOR
                                                                                  15
REJECTED BY PROJECT OFFICER
                                       13
                                               RETURNED TO ORIGINATOR
                                                                                   16
SENT TO CONTRACTOR
                                        14
                                          COMMENTS
 17




 18




 19




 20 CONFIDENTIAL BUSINESS  DtfORMATION




 21 Enter log number
EPA HQ Foim 7710-9(7-71)
                     COPY 1-To b* retained by ORIGINATOR

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                        APPENDIX E-2
RECEIPT OF CONFIDENTIAL DATA
I have received the Confidential Material submitted by
       (Name)                 (Branch)                (Room)
       (Date)                 Document Control Assistant






       	 please acknowledge
I have received the Confidential Material submitted to




me from 	.







       (Date)(Name)

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                             APPENDIX E-3
                    FIFRA Federal Non-OPTS Employee
                       Confidentiality Agreement
     I understand that as an employee of a Federal agency that has
obtained certain Confidential Business Information submitted to the
Environmental Protection Agency under the Federal Insecticide, Fungicide,
and Rodenticide Act  (FIFRA)  (7 U.S.C. 136 et seg..), I will have accesss
to such information.  This access has been granted in accordance with my
official duties under a law to protect health or  the environment or for
specific law enforcement purposes.

     I understand that FIFRA Confidential Business Information may not be
disclosed by me except as authorized by FIFRA, the agreement between my
agency and the Environmental Protection Agency, and the security procedures
in effect at my agency.  I understand that under  section 10(f)(3) of FIFRA,
I am liable for a possible fine of up to $10,000  and/or imprisonment for up
to three years if I  willfully disclose FIFRA Confidential Business
Information to any person not authorized to receive it.  In addition, I
understand that I may be subject to disciplinary  action for violation of
this agreement up to and including dismissal.

     I agree that I  will treat any FIFRA Confidential Business Information
furnished to me as confidential and that I will follow the security
procedures in effect at my agency for the handling of this type of
information.  I have been informed of and understand the procedures.
Signature                               Date
Typed Name
Title                                   Telephone No.

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                               APPENDIX E-4
            FIFRA Contractor Employee Confidentiality Agreement
     I understand that as an employee of a contractor performing work for
the United States Environmental Protection Agency, I will have access to
certain Confidential Business Information submitted under the Federal
Insecticide, Fungicide, and Rodenticide Act  (FIFRA) (7 U.S.C.
136 et seq.).  This access has been granted  to me  in order to perform my
work under the contract.

     I understand that FIFRA Confidential Business Information may not be
disclosed by me except as authorized by FIFRA, the contract, and the
security procedures used by my employer under the  contract.  I understand
that under section 14(b)(3) of FIFRA, I am liable  for a possible fine of up
to $10,000 and/or imprisonment for up to three years if I willfully
disclose FIFRA Confidential Business Information to any person not
authorized to receive it.  In addition, I understand that I may be subject
to disciplinary action for violation of this agreement up to and including
dismissal.

     I agree that I will treat any FIFRA Confidental Business Information
furnished to me as confidential and that I will follow the security
procedures used by my employer under the contract.  I have been informed of
and understand the procedures.
Signature                              Date
Name

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                                  APPENDIX F
REQUEST TO COPY OPTS CONFIDENTIAL BUSINESS INFORMATION
Requestor's Name


Organization 	
                           Date
(Please Print)

       Mail Code
Phone No.
I request that the following documents which may contain OPTS Confidential
Business Information be copied.  I understand that I am responsible and
accountable for all copies until I transfer custody.
No.










1
Description (Ace. #, Reg #, etc)




~





Number of
Original Pages










Number of |
Copies 1










Document
Control No.










Requestor's Signature

Approval 	
               (Please Print)
                 (Signature)
Title
Organization
Copies Produced
     Mail Code

             By
 Phone No.
                      (date)
                            (DCO/DCA)

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                                       APPENDIX G
                REQUEST TO DESTROY OPTS CONFIDENTIAL BUSINESS INFORMATION
Requestor's Name


Organization 	
                          Date
(Please Print)

      Mail Code
Phone No.
I request that the following documents which may contain OPTS Confidential
Business Information be destroyed.
Room No.
1
2
3
4
5
6
7
8
9
10
Description (Ace. #, Reg #, etc)










Document Controlled
(Yes or No)

.








Document Control
Number




.





Requestor's Signature

Approval 	
                                       (DCO Only)
              (Please Print)
                (Signature)
Title
Organization
Copies Produced
    Mail Code

            By
 Phone No.
                      (date)
                           (DCO/DCA)

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                                Appendix H

                     Document Control Officers (DCOs)
                                   and
                       Document Control Assistants (DCAs)
Benefits and Field Studies Division

 DCO 	

 DCA 	

 DCA
(Name)
(Name)
             (Name)

Hazard Evaluation Division

 DCO 	

 DCA 	

 DCA '
(Name)
(Name)
             (Name)

Program Support Divison

 DCO 	

 DCA 	

 DCA
(Name)
(Name)
             (Name)

Registration Division

 DCO 	

 DCA 	

 DCA
(Name)
(Name)
             (Name)

Special Pesticides Review Division

 DCO 	

 DCA 	

 DCA
(Name)
(Name)
             (Name)
(Room)
(Room)
                                      (Room)
(Room)
(Room)
                                      (Room)
(Room)
(Room)
                                      (Room)
vRoom)
(Room)
                                      (Room)
(Room)
(Room)
                                      (Room)
(Phone)
(Phone)
              (Phone)
(Phone)
(Phone)
              (Phone)
(Phone)
(Phone)
              (Phone)
(Phone)
(Phone)
              (Phone)
(Phone)
(Phone)
              (Phone)

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                                      Appendix I

Procedures for Obtaining Interagency Agreements for
Furnishing FIFRA Confidential Business Information.
                                                                               \

a.  If a particular Federal agency will have a continuing need for FIFRA Confidential
    Business Information, the agency may obtain an interagency memorandum of agree-
    ment for access to FIFRA Confidential Business Information.

b.  The Deputy Assistant Administrator for Pesticide Programs may negotiate an inter-
    agency agreement, in accordance with EPA Order 1610, with another Federal agency
    for access to FIFRA Confidential Business Information if:

    (1)  The agreement meets the requirements of 40 CFR Part 2.

    (2)  The other agency agrees to treat all FIFRA Confidential Business Information
         obtained from EPA in accordance with the agreement,

    (3)  The agreement sets forth the purposes for which the information is needed
         and those purposes are in connection with the agency's duties under any laws
         to protect health or the environment or for specific law enforcement purposes,

    (4)  The agreement specifies the security procedures that will be used for pro-
         tecting the information, and the Deputy Assistant Administrator for Pesti-
         cide Programs determines that the procedures will provide at least the same
         degree of protection as these procedures (or the other agency has adopted
         these procedures for purposes of the agreement), and

    (5)  The agreement specifies the procedures that will be followed by the other
         agency in making specific requests for information under the agreement and to
         whom the requests will be addressed.

c.  The Deputy Assistant Administrator for Pesticide Programs or his/her designee,
    shall notify the appropriate DCO's of the agreement and the procedures to be fol-
    lowed in responding to specific requests.

d.  Under such an agreement, if the applicable procedures in 40 CFR Part 2 have been
    followed, a DCO may furnish Confidential Business Information to another Federal
    agency, in accordance with Chapter III of these Procedures, without receiving
    specific authorization from the Deputy Assistant Administrator for Pesticide Pro-
    grams for each request.

5.  Violations.

    a.   Any violation of another Federal agency's security procedures, when there is
         no evidence of unauthorized disclosure, shall be investigated by that agency
         and appropriate remedial action taken to correct the procedural deficiencies.

    b.   Any alleged or actual unauthorized disclosure of FIFRA Confidential Business
         Information by another Federal agency shall be reported immediately by that
         agency to the EPA Inspector General's office and the Deputy Assistant
         Administrator for Pesticide Programs.

    c.   Any violations of the security provisions of an interagency agreement under
         this chapter shall be investigated by the EPA Inspector General's office which
         shall report to the Deputy Assistant Administrator for Pesticide Programs.  If
         the Deputy Assistant Administrator for Pesticide Programs finds that the other
         agency has violated the terms of the interagency agreement, he or she may
         terminate that agency's right of access pending resolution of the matter.

    d.   If the investigation by OIG develops information reflecting a possible crim-
         inal violation, the case shall be referred to the Department of Justice.

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                                APPENDIX J

                       PERSONS AUTHORIZED TO REQUEST
                  CBI MATERIALS FROM OPP DOCUMENT CENTER

Division:	 Office Symbol: 	
1.  The following named personnel assigned to this Division are authorized
to withdraw CBI material from the OPP Document Center in accordance with
Section V of the FIFRA CBI Security Manual.

a.  Branch:	
Names of Individuals     Badge Number        Room       Telephone
b.  Branch: 	
Names of Individual      Badge Number         Room       Telephone
                       Certificate  of  CBI  Clearance

All persons named above  are  cleared by this  Division  for access to CBI.
The access authorization forms  and  agreements specified in the FIFRA CBI
Manual are on  file with  the  Division Document Control Officer.
Signature:	  Date
              Division  Document Control  Officer

-------