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*. U.S. Environmental Protection Agency	21-P-0070
Office of Inspector General	February 8,2021
(Mj
At a Glance
Why We Did This Audit
The U.S. Environmental
Protection Agency's Office of
Inspector General conducted
this audit to review the EPA's
adherence to applicable
regulations, policies, and
procedures in assessing the
risks of pesticides to human
health and the environment
during the pesticide registration
process.
Pursuant to Federal Insecticide,
Fungicide, and Rodenticide Act
requirements, the EPA's Office
of Pesticide Programs regulates
all pesticides that are sold and
distributed in the United States.
For each pesticide registration
application, the OPP has the
discretion to unconditionally
register the pesticide under
FIFRA Section 3(c)(5) if the
application is complete and all
criteria are met or to
conditionally register the
pesticide under FIFRA
Section 3(c)(7) if additional data
are needed.
This audit addresses the
following:
•	Ensuring the safety of
chemicals.
This audit addresses a top EPA
management challenge:
•	Complying with key internal
control requirements (data
quality).
Address inquiries to our public
affairs office at (202) 566-2391 or
OIG WEBCOMMENTS@epa.gov.
List of OIG reports.
EPA Mostly Adheres to Regulations When
Assessing Risks of New Pesticides but Should
Improve Internal Controls
By implementing stronger
internal controls, the EPA can
decrease the risk of issuing a
pesticide registration that does
not comply with regulatory
requirements.
What We Found
For the nine unconditional pesticide
registrations we reviewed, we found that the
OPP is mostly adhering to applicable
regulations, policies, and procedures in
assessing the risks of the pesticides to
human health and the environment during
the issuance process for unconditional
pesticide registrations. Federal regulation 40 C.F.R. § 152.112, Approval of
registration under FIFRA sec. 3(c)(5), establishes eight criteria for the issuance
of an unconditional pesticide registration. The OPP fully complied with four of
these criteria, while two were not applicable to the pesticide registrations that we
reviewed. The two remaining criteria address, in part, toxicology and ecological
data requirements that the OPP must assess to determine whether the
pesticide's intended use will have unreasonable adverse effects on human
health and the environment. For these two criteria, the OIG:
•	Independently verified that the OPP met all toxicology data requirements.
The OPP develops a summary table addressing toxicology data
requirements for pesticide registrations.
•	Could not independently verify that the OPP met all ecological data
requirements. The OPP does not develop a summary table addressing
ecological data requirements for pesticide registrations.
In addition, the OPP lacks a standard operating procedure governing how to
conduct initial pesticide registrations to ensure adherence to 40 C.F.R.
§ 152.112. The lack of an ecological data requirement summary table and a
standard operating procedure for initial registrations increases the risk that the
OPP will issue a pesticide registration that does not comply with the pesticide
registration statutes and regulations.
Recommendations and Planned Agency Corrective Actions
We make two recommendations to the assistant administrator for Chemical
Safety and Pollution Prevention: (1) develop and incorporate an ecological data
requirement summary table or similar internal control into the OPP's ecological
risk assessments and (2) develop and implement a standard operating
procedure for the initial registration of a pesticide. The Agency provided
acceptable corrective actions, and both recommendations are resolved with
corrective actions pending.

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