<
33
\
^t0SrX
&
V PRO^4-0
o
2
Lll
o
U.S. Environmental Protection Agency
Office of Inspector General
At a Glance
2006-P-00003
October 19, 2005
Catalyst for Improving the Environment
Why We Did This Review
We initiated this review to
evaluate the Environmental
Protection Agency's (EPA's)
activities to implement the
Food Quality Protection Act
(FQPA) of 1996. We sought
to determine whether EPA
allows for sufficient public
participation in the pesticide
decision-making process.
Background
FQPA changed the way EPA
regulates pesticides. FQPA
emphasized the potential for
infants and children to be
especially sensitive to
pesticides and the need to
provide them adequate
protection. FQPA imposed
many new requirements on
EPA, including the need to
review and reregister older
pesticides to ensure they meet
newer standards.
Changes Needed to Improve Public Confidence in
EPA's Implementation of the Food Quality Protection Act
What We Found
This is the first in a series of planned reports on the Agency's FQPA
implementation efforts. To ensure adequate protection of children, FQPA
required EPA to make significant changes to the pesticide reregistration process.
Despite numerous changes to the process, internal and external stakeholders
expressed continued reservations over aspects of the process.
EPA allowed public comment periods when developing the Agency's major
FQPA science policy papers, and developed and implemented a public comment
policy for all pesticide reregistrations in 2002. Prior to this policy, however, the
Office of Pesticide Programs did not always solicit public comments prior to
issuance of final pesticide reregistration decisions. We believe EPA must ensure
that at least one public comment period is held prior to final pesticide
reregistration decisions. Providing opportunities for public participation is
important for increasing transparency, improving decision making, and increasing
overall public confidence.
Though EPA has an on-going research agenda related to the protection of
subgroups, OPP lacks a methodology to identify and assess major subgroups of
consumers, such as farm children, in the pesticide reregistration decision making
process. EPA should respond promptly and directly to requests and petitions from
external stakeholders. Such a methodology and responsiveness are needed to
improve public confidence.
For further information,
contact our Office of
Congressional and Public
Liaison at (202) 566-2391.
To view the full report,
click on the following link:
www.epa.aov/oia/reports/2006/
20051019-2006-P-00003.pdf
To view attachments to EPA's
response, click on:
www.epa.aov/oia/reports/2006/
20051019-2006-P-00003A.pdf
What We Recommend
We recommend that EPA's Office of Pesticide Programs allow at least one formal
public comment period prior to the issuance of final and interim reregistration
decisions. We recommend that the Office develop a defined methodology for
considering subgroups, and work with the Office of Research and Development to
continue to address these issues. We also recommend that EPA respond promptly
to requests and petitions from external stakeholders. EPA generally agreed with
the recommendations, although the Agency expressed concern that our report did
not sufficiently discuss their efforts. We made revisions when appropriate.

-------