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b	. U.S. Environmental Protection Agency	17-P-0412
....\ \ Office of Inspector General	September 28, 2017
At a Glance
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Why We Did This Review
We conducted this review of
the U.S. Environmental
Protection Agency's (EPA's)
Federal Insecticide, Fungicide
and Rodenticide Act (FIFRA)
import inspection program to
determine whether the EPA is
effectively identifying imported
pesticides for inspection and
sampling to deter imports of
harmful pesticides and protect
human health and the
environment.
Illegal imports of pesticides can
present significant human
health and environmental risks,
and have been linked to
poisonings of children and pets.
Illegal imports include high-risk
pesticides that can be
counterfeit, produced at
unregistered establishments, or
produced using unauthorized
ingredients. According to the
EPA, inspections are a key
method to deter the import of
harmful pesticides.
This report addresses the
following:
•	Ensuring the safety of
chemicals.
•	Compliance with the law.
EPA Can Better Reduce Risks From
Illegal Pesticides by Effectively Identifying
Imports for Inspection and Sampling
Send all inquiries to our public
affairs office at (202) 566-2391
or visit www.epa.aov/oia.
Listing of OIG reports.
Low rates of inspections and
sampling can create a risk
that the EPA may not be
identifying or deterring the
import of pesticides harmful
to people or the environment.
What We Found
The EPA is at risk of not effectively identifying
imported pesticides for inspection and
sampling. EPA regions did not meet the
voluntary frequency goal of inspecting
2 percent of all shipments of imported
pesticides nationwide in fiscal years 2015 and
2016. In fiscal year 2016, the EPA's
10 regions conducted only 73 inspections of 46,280 pesticide shipments. This is
an inspection rate of 0.002; an inspection rate of 2 percent would have been
about 926 inspections. Consequently, there is limited assurance that imports in
violation of FIFRA will be identified or prevented entry into the United States.
We found that in two EPA regions, inspections were more likely to be conducted
close to the regional office rather than where the greatest number of pesticides
entered the region. In the last 5 years, the seven EPA regions we reviewed had
sampled and tested the integrity of only seven pesticides out of approximately
145,000 shipments of imported pesticides. Regional resources available to carry
out inspections are not considered part of strategic planning, and regional
participation in achieving the agency's inspection frequency goal is voluntary.
The EPA's implementation of the required U.S. Customs and Border Protection
Automated Commercial Enterprise system for automatic processing of import
notices will allow EPA regions more time for targeting and inspections. However,
the agency has no guidance or training available on how EPA regions can use
information from this system to target future inspections or develop their own
targeting strategies. Guidance or protocols for how EPA regions can coordinate
with U.S. Customs and Border Protection will also help to ensure that the EPA is
notified of any potentially illegal pesticides not found during the agency's review
of import notices.
Recommendations and Planned Agency Corrective Actions
We made four recommendations that the Assistant Administrator for Enforcement
and Compliance Assurance establish national compliance monitoring goals
based on regional resources; implement controls to monitor and communicate
progress on regional goals; develop guidance and train EPA regions to use the
Automated Commercial Enterprise system for regional targeting of importers,
manufacturers and pesticide products; and direct each EPA region to develop
guidance or protocols for coordinating with local U.S. Customs and Border
Protection offices regarding illegally imported pesticides. The EPA concurred with
developing protocols for coordinating with local U.S. Customs and Border
Protection offices. The remaining three recommendations are unresolved.

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