Pesticides:

Export of Unregistered Pesticides Is Not Adequately Monitored by EPA

RCED-89-128: Published: Apr 25, 1989. Publicly Released: May 4, 1989.

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In response to a congressional request, GAO reviewed the Environmental Protection Agency's (EPA) implementation of the Federal Insecticide, Fungicide, and Rodenticide Act's (FIFRA) provisions regarding pesticide notification requirements.

GAO found that: (1) EPA lacked an effective program to monitor pesticide manufacturers' compliance with pesticide export notification requirements; (2) pesticide notices did not include sufficient and meaningful information for foreign governments to adequately identify pesticide products; (3) the EPA policy of exempting unregistered pesticide products because of their similarity and use hindered its efforts to monitor pesticide manufacturers' compliance with the notification requirements; (4) EPA received notices from about 26 percent of companies that exported 80 percent of unregistered pesticide products to the United States; (5) EPA lacked internal procedures for preparing and issuing notices to foreign countries and international organizations regarding significant action on individual pesticides; and (6) an EPA booklet on cancelled, suspended, or restricted pesticides was outdated, and foreign governments lacked current pesticide guidelines.

Status Legend:

More Info
  • Review Pending-GAO has not yet assessed implementation status.
  • Open-Actions to satisfy the intent of the recommendation have not been taken or are being planned, or actions that partially satisfy the intent of the recommendation have been taken.
  • Closed-implemented-Actions that satisfy the intent of the recommendation have been taken.
  • Closed-not implemented-While the intent of the recommendation has not been satisfied, time or circumstances have rendered the recommendation invalid.
    • Review Pending
    • Open
    • Closed - implemented
    • Closed - not implemented

    Recommendations for Executive Action

    Recommendation: The Administrator, EPA, should annually update and issue to all parties concerned, including foreign governments, its booklet on suspended, cancelled, and restricted pesticides.

    Agency Affected: Environmental Protection Agency

    Status: Closed - Implemented

    Comments: The suspended and cancelled booklet was revised and issued in February 1990.

    Recommendation: The Administrator, EPA, should develop internal criteria and procedures for determining whether and when to prepare and issue a notice of regulatory action, including specifying what constitutes a significant action on a pesticide.

    Agency Affected: Environmental Protection Agency

    Status: Closed - Implemented

    Comments: EPA's revised pesticide export policy statement, published in the Federal Register on February 18, 1993, has identified regulatory actions requiring a notification and has established guidance on the timing of the notices.

    Recommendation: The Administrator, EPA, should regularly provide information to the Food and Drug Administration (FDA) to assist in its monitoring of pesticide residues on imported food.

    Agency Affected: Environmental Protection Agency

    Status: Closed - Not Implemented

    Comments: EPA cited several factors as limiting the usefulness of the information to FDA and concluded that the benefits to FDA did not justify the time and effort needed to provide information that might be claimed as confidential by the vendor. The agencies have yet to agree to implement this recommendation. Due to the age of the recommendation and agency inaction, GAO is deleting it from the open recommendation list.

    Recommendation: The Administrator, EPA, should take appropriate actions to strengthen EPA oversight of pesticide exports, including changing EPA enforcement policy concerning an unregistered pesticide currently used for Section 17(a) notices, which in effect exempts a large number of pesticides claimed to be similar to registered pesticides. Such a change would be consistent with the way EPA treats an unregistered pesticide used throughout the rest of the pesticide program.

    Agency Affected: Environmental Protection Agency

    Status: Closed - Implemented

    Comments: EPA's revised pesticide export policy statement, published in the Federal Register on February 18, 1993, no longer exempts unregistered pesticides similar to those already registered from export reporting requirements.

    Recommendation: The Administrator, EPA, should take appropriate actions to strengthen EPA oversight of pesticide exports, including requiring manufacturers to improve the quality and type of information included in the export notices, such as reporting full chemical descriptions.

    Agency Affected: Environmental Protection Agency

    Status: Closed - Implemented

    Comments: EPA's revised pesticide export policy statement, published in the Federal Register on February 18, 1993, has expanded the information required in export notices to provide better identification of the pesticide being exported.

    Recommendation: The Administrator, EPA, should take appropriate actions to strengthen EPA oversight of pesticide exports, including monitoring compliance with the notification requirements by matching export notice information with export production data.

    Agency Affected: Environmental Protection Agency

    Status: Closed - Implemented

    Comments: EPA has taken actions to automate export notices. But, EPA is working to correct a number of technical problems with its automated production tracking system before any enhancements, such as matching export notices, can be added. It still has not completed the work or begun matching. Due to the age of the recommendation, GAO is deleting it from the open recommendation list.

    Recommendation: The Administrator, EPA, should establish guidance on section 17(a) transmittal procedures for sending notices to foreign governments. In addition, in cooperation with the Department of State, EPA should annually update and send both section 17(a) and 17(b) guidance to U.S. embassies.

    Agency Affected: Environmental Protection Agency

    Status: Closed - Implemented

    Comments: Under EPA's revised export policy, EPA will send section 17(a) notices and advance section 17(b) notices directly to the foreign governments. EPA also will continue to send section 17(b) notices to the State Department.

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