PESTICIDES

EPA Should Take 

Steps to Improve Its 

Oversight of 

Conditional 

Registrations

Report to the Ranking Member, 

Subcommittee on Environment and the 

Economy, Committee on Energy and 

Commerce, House of Representatives

August 2013

GAO-13-145

United States Government Accountability Office
United States Government Accountability Office

Highlights of GAO-13-145, a report to the 

Ranking Member, Subcommittee on 

Environment and the Economy, Committee on

Energy and Commerce, House of 

Representatives

August 2013

PESTICIDES

EPA Should Take Steps to Improve Its Oversight of 

Conditional Registrations

Why GAO Did This Study

As of September 2010, more than 

16,000 pesticides were registered for 

use in the United States, according 

to EPA. EPA reviews health and 

environmental effects data submitted 

by a company and may register a 

pesticide or, alternatively, grant a 

“conditional registration” for a 

pesticide under certain 

circumstances, even though some of 

the required data may not have been

submitted or reviewed. The company 

must provide the missing data within 

a specified time. In 2010, 

environmental and other groups 

charged that EPA had overused 

conditional registrations and did not 

appear to have a reliable system to 

identify whether the required data 

had been submitted. GAO was 

asked to examine issues related to 

EPA’s use of conditional registrations 

for pesticides. This report examines 

the (1) number of conditional 

registrations EPA has granted and 

the basis for these, (2) extent to 

which EPA ensures that companies 

submit the required additional data

and EPA reviews the data, and (3) 

views of relevant stakeholders on 

EPA’s use of conditional 

registrations. GAO reviewed EPA 

data and surveyed stakeholders, 

among other things.

What GAO Recommends

GAO recommends, in part, that EPA

consider and implement options for 

an automated system to better track 

conditional registrations. EPA agreed 

with GAO’s recommendations and 

noted specific actions it will take to 

implement them.

What GAO Found

The total number of conditional registrations granted is unclear, as the 

Environmental Protection Agency (EPA) reports that its data are inaccurate for 

several reasons. First, the database used to track conditional registrations does 

not allow officials to change a pesticide’s registration status from conditional to 

unconditional once the registrant has satisfied all requirements, thereby 

overstating the number of conditional registrations. Second, EPA staff have 

misused the term “conditional registration,” incorrectly classifying pesticide 

registrations as conditional when, for example, they require a label change, 

which is not a basis in statute for a conditional registration. According to EPA 

documents and officials, weaknesses in guidance and training, management 

oversight, and data management contributed to these misclassification problems. 

For example, according to EPA documents, there was limited, organized 

management oversight to ensure that regulatory actions were not misclassified 

as conditional registrations. As of July 2013, EPA officials told GAO that the 

agency has taken or is planning to take several actions to more accurately 

account for conditional registrations, including beginning to design a new 

automated data system to more accurately track conditional registrations.

The extent to which EPA ensures that companies submit additional required data 

and EPA reviews these data is unknown. Specifically, EPA does not have a 

reliable system, such as an automated data system, to track key information 

related to conditional registrations, including whether companies have submitted 

additional data within required time frames. As a result, pesticides with 

conditional registrations could be marketed for years without EPA’s receipt and 

review of these data. In the absence of a reliable system for managing 

conditional registrations, EPA relies on a variety of routine program operations, 

such as its review of a company’s changes to a pesticide registration, to discover 

that data are missing. However, these methods fall short of what is needed 

because they are neither comprehensive nor do they ensure timely submission of 

these data. According to federal internal control standards, EPA’s lack of a 

reliable system for managing conditional registrations constitutes an internal 

control weakness because the agency lacks an effective mechanism for program 

oversight and decision making.

Stakeholders GAO surveyed—representatives of consumer, environmental, 

industry, legal, producer, science, and state government groups—generally said

EPA needs to improve its conditional registration process. For example, some 

stated EPA should improve its data systems for tracking conditional registrations 

to ensure that required data are submitted and reviewed in a timely manner. 

However, stakeholder views varied on the benefits and disadvantages of 

conditionally registering pesticides. For example, some consumer, industry, legal, 

producer, and state government stakeholders stated that the conditional 

registration process promotes innovation by bringing new technologies to the 

marketplace more quickly. In contrast, some consumer, environmental, legal, 

science, and state government stakeholders voiced concerns that conditional 

registration allows products with safety that has not been fully evaluated into the 

marketplace. View GAO-13-145. For more information, 

contact J. Alfredo Gómez, (202) 512-3841 or 

gomezj@gao.gov. 
Page i GAO-13-145 Conditional Pesticide Registration

Letter 1 

Background 5

Total Number of Conditional Registrations Granted Is Unclear, as 

EPA Found Data to Be Inaccurate 12

Extent to Which EPA Ensures That Registrants Submit Additional 

Required Data and EPA Reviews These Data Is Unknown 19

Stakeholders Generally Said EPA Needs to Improve Its 

Conditional Registration Process and Had Mixed Views on the 

Value of These Registrations 29

Conclusions 36

Recommendations for Executive Action 38

Agency Comments and Our Evaluation 39

Appendix I Objectives, Scope and Methodology 41

Appendix II Comments from the Environmental Protection Agency 46

Appendix III GAO Contact and Staff Acknowledgments 50

Related GAO Products 51

Table

Table 1: OPP Actions Taken or Planned to Improve the Reliability 

of Conditional Registration Data 18

Figure

Figure 1: General Overview of EPA Pesticide Registration and 

Tolerance Setting Process 9

Contents 
Page ii GAO-13-145 Conditional Pesticide Registration

Abbreviations

DCI Data Call-In

EPA Environmental Protection Agency

FIFRA Federal Insecticide, Fungicide, and Rodenticide Act

FFDCA Federal Food, Drug, and Cosmetic Act

NRDC Natural Resources Defense Council

OMB Office of Management and Budget

OPP Office of Pesticide Programs

OPPIN Office of Pesticide Programs Information Network

PRIA Pesticide Registration Improvement Act of 2003

PRISM Pesticide Registration Information System

This is a work of the U.S. government and is not subject to copyright protection in the 

United States. The published product may be reproduced and distributed in its entirety 

without further permission from GAO. However, because this work may contain 

copyrighted images or other material, permission from the copyright holder may be 

necessary if you wish to reproduce this material separately.
Page 1 GAO-13-145 Conditional Pesticide Registration

441 G St. N.W.

Washington, DC 20548

August 8, 2013

The Honorable Paul D. Tonko

Ranking Member

Subcommittee on Environment and the Economy

Committee on Energy and Commerce

House of Representatives

Dear Mr. Tonko:

As of September 2010, more than 16,000 pesticides were registered for 

use in the United States, according to the Environmental Protection 

Agency (EPA). In addition, expenditures for pesticides—primarily for use 

in agriculture—totaled $12.5 billion in 2007, the latest year for which data 

are available from EPA. These pesticides—chemicals or biological 

substances used to destroy or control weeds or unwanted insects, fungi, 

rodents, bacteria and other pests—contribute significantly to agricultural 

productivity by preventing crop damage and improving public health by 

controlling disease-carrying pests. However, if used improperly, 

pesticides may adversely affect human health by, for example, increasing 

the risk of cancer and neurological disorders caused by pesticide 

residues on food crops. Pesticides may also damage the environment by, 

for example, killing or causing reproductive abnormalities in species other 

than those which the pesticide is intended to kill, including fish, birds, and 

other wildlife.

Under the Federal Insecticide, Fungicide, and Rodenticide Act, as 

amended, (FIFRA),1 EPA registers pesticides distributed, sold, or 

used in the United States and prescribes labeling and other regulatory 

requirements to prevent unreasonable adverse effects on the 

environment.2

 

1

Act of June 25, 1947, ch. 125, 61 Stat. 163 (codified as amended at 7 U.S.C. §§ 136-

136y).

To obtain a registration, a company or person (registrant)

2

The phrase “unreasonable adverse effects on the environment” is defined in FIFRA, in 

part, to mean (1) any unreasonable risk to man or the environment, taking into account the 

economic, social, and environmental costs and benefits of the use of any pesticide, or (2) 

a human dietary risk from residues that result from a use of a pesticide in or on any food 

inconsistent with the standard for tolerance under section 408 of the Federal Food, Drug, 

and Cosmetic Act, 21 U.S.C.§ 346a. This standard requires EPA to consider both the 

benefits and risks of using a pesticide.

 
 

Page 2 GAO-13-145 Conditional Pesticide Registration

is to submit an application containing health and environmental effects 

data and other information on a pesticide for EPA’s review.

3 After 

reviewing the information, in general, EPA may (1) register the pesticide 

and set a tolerance level (i.e., the maximum pesticide residue allowed) for 

those pesticides used on food or animal feed,4

FIFRA section 3(c)(5) and section 3(c)(7) set forth two sets of statutory 

standards under which EPA may register pesticides. EPA is authorized to 

grant registrations under section 3(c)(5) if EPA determines, among other 

things, that the application materials provided satisfy the requirements of 

the statutes and that the information those materials contain concerning 

the pesticide demonstrates that, when used in accordance with 

widespread and commonly recognized practice, the product will not 

generally cause unreasonable adverse effects on the environment. Such 

registrations are commonly referred to as “unconditional” registrations 

because they are approved without EPA imposing a requirement on the 

registrant to develop additional data.

(2) notify the registrant of 

deficiencies in the data or the need for additional information, or (3) deny 

the application.

In addition, section 3(c)(7) of FIFRA provides EPA the authority to grant a 

“conditional registration” for a pesticide product under certain 

circumstances, although some necessary data have not been provided by 

the registrant in the application. Under this authority, EPA may grant a 

conditional registration for pesticide products that are identical or 

substantially similar to pesticide products that are already registered or for 

a new use of a currently registered product as long as EPA determines, 

among other things, that the pesticide will not significantly increase the 

risk of unreasonable adverse effects on the environment. This authority 

also allows EPA to grant a conditional registration for pesticide products 

with new active ingredients where data are missing from the application 

because the requirement for the data was imposed so recently that the 

registrant did not have adequate time to generate the data and EPA 

 

3

According to Office of Pesticide Programs (OPP) officials, applicants for pesticide 

registrations are usually pesticide product manufacturers. When EPA registers an 

applicant’s pesticide product, the applicant is then called a registrant. For the purposes of 

this report, we refer to applicants as registrants.

4

Under the Federal Food, Drug, and Cosmetic Act, EPA is authorized to establish 

tolerances—or exemptions for the requirement of a tolerance—for pesticide residues that 

remain in food or animal feed. 
 

Page 3 GAO-13-145 Conditional Pesticide Registration

determines, among other things, that the pesticide will not cause 

unreasonable adverse effects on the environment during the time needed 

to generate the data.5

In 2010, an environmental group questioned EPA’s use of conditional 

registrations in the pesticide program, and other consumer and science 

groups supported this position. The environmental group charged that 

EPA had overused conditional registrations, stating that information from 

EPA’s Office of Pesticide Programs Information Network (OPPIN) data 

system showed that conditional registrations represented the majority of 

active registrations.

According to EPA officials, registrants typically 

have from 1 to 4 years to provide the missing data required by a 

conditional registration.

6

In this context, you asked us to examine EPA’s procedures for granting 

conditional registrations. Accordingly, we examined the (1) number of 

conditional pesticide registrations EPA has granted and the basis for 

granting these registrations; (2) extent to which EPA ensures that 

registrants submit the additional data required as part of conditional 

registrations and reviews these data; and (3) views of relevant 

stakeholders on EPA’s use of conditional registrations, including ways, if 

any, to improve the conditional registration process. 

The group also pointed out that the OPPIN data 

indicated that some pesticide products had been conditionally registered 

for 20 years or more.

To address these objectives, we reviewed relevant federal statutes and 

regulations, EPA guidance documents and internal reviews, federal 

internal control standards, and previous GAO and EPA Inspector General 

reports.7

 

5

An active ingredient is the chemical or substance component of a pesticide product that 

will prevent, destroy, repel, or mitigate a pest.

We also requested that EPA’s Office of Pesticide Programs 

(OPP) provide summary data on its issuance of conditional registrations, 

including (1) the number of pesticide registrations currently in conditional 

6

EPA refers to registrations that are in effect (i.e., the registration has not been suspended 

or canceled) as “active” registrations. For purposes of this report, unless otherwise 

indicated, all registrations discussed are “active.” 

7

EPA Office of Inspector General, EPA’s Pesticide Program, Report no. E1EPE2-05-

0015-4100205, Mar. 11, 1994; EPA Office of Inspector General, Pesticides: Follow-up 

Report on EPA’s Pesticide Program, Report no. 00P00011, March 27, 2000. GAO reports 

are listed under “Related GAO Products” at the end of this report. 
 

Page 4 GAO-13-145 Conditional Pesticide Registration

status and how long they have been in this status; (2) the total number of 

current pesticide registrations (conditional and unconditional); and (3) for 

fiscal years 1997 through 2011, the number of conditional registrations 

granted for each year and the basis on which these were granted (i.e., 

identical/substantially similar pesticides, new uses, or new active 

ingredients). In addition, we asked OPP to provide information on the 

number of pesticides that (1) have a conditional registration, but the 

registrant has not submitted the additional required data by the specified 

due date; (2) have a conditional registration and the registrant has 

submitted the additional required data, but EPA has not reviewed these 

data; (3) still have a conditional registration, even though the registrant 

has submitted, and EPA has reviewed, the additional required data; and 

(4) had been changed from conditional to unconditional status. However, 

after interviewing OPP officials and reviewing past GAO, Inspector 

General, and EPA contractor studies examining OPP’s data 

management, especially its use of OPPIN, we concluded that EPA could 

not provide us with sufficiently reliable data for obtaining summary level 

information on conditional pesticide registrations. In the absence of these 

data, we discussed with OPP officials the data limitations they face using 

OPPIN and any potential workarounds they employ or are planning. In 

addition, we interviewed OPP officials and reviewed documentation they 

provided to obtain further information and clarification on EPA’s 

conditional registration process, including any planned responses to 

internal review or external stakeholder concerns. To obtain the views of 

relevant stakeholders on EPA’s conditional registration process and 

ways, if any, to improve it, we used the results of a literature search and 

other sources to develop a list of consumer, environmental, industry, 

legal, producer, science, and state government stakeholders. From this 

list, we selected a nonprobability sample of stakeholders from each 

category to contact, for a total of 35 stakeholders.8

 

8

Because this was a nonprobability sample, the information collected in response to the 

questionnaire about EPA’s use of conditional registrations cannot be generalized to all 

consumer, environmental, industry, legal, producer, science, and state government 

stakeholders but provides illustrative information on the views of such stakeholders by 

category. 

We then developed, 

pretested, and e-mailed a questionnaire to obtain these stakeholders’ 

views. Twenty-four out of 35 stakeholders provided responses to our 

questionnaire. We performed a content analysis of the questionnaire 

responses to identify common themes regarding stakeholders’ views on 
 

Page 5 GAO-13-145 Conditional Pesticide Registration

EPA’s use of conditional registrations. Appendix I provides a more 

detailed description of our objectives, scope, and methodology.

We conducted this performance audit from September 2011 to August 

2013 in accordance with generally accepted government auditing 

standards. Those standards require that we plan and perform the audit to 

obtain sufficient, appropriate evidence to provide a reasonable basis for 

our findings and conclusions based on our audit objectives. We believe 

that the evidence obtained provides a reasonable basis for our findings 

and conclusions based on our audit objectives.

The primary federal laws that govern how EPA regulates pesticides in the 

United States are FIFRA and the Federal Food, Drug, and Cosmetic Act 

(FFDCA).9 Under FIFRA implementing regulations,10 EPA is to review 

applications for pesticide products and register those that it determines 

will meet the FIFRA statutory standards for registration. If the use of a 

pesticide would result in a residue of the substance in or on food or 

animal feed, EPA may not register a pesticide under FIFRA unless it can 

determine that the residue is “safe” as defined by FFDCA. Under FFDCA, 

safe means that EPA has determined, among other things, that there is a 

reasonable certainty that no harm will result from aggregate exposure to 

the pesticide residue, including all anticipated dietary exposures and all 

other nonoccupational exposures for which there is reliable information.11

EPA may establish a tolerance level—the maximum permissible pesticide 

residue in or on food or animal feed that is sold—that meets the FFDCA 

safety standard or may choose to grant an exemption for a tolerance.12

 

9

21 U.S.C. §§ 301-399f.

1040 C.F.R. pts. 152-180.

11Nonoccupational exposures are those experienced by the general population, as 

opposed to those experienced by specific groups of pesticide users, such as farm workers 

and pest control operators.

12To make the safety finding, EPA considers, among other things, the toxicity of the 

pesticide and its breakdown products, aggregate exposure to the pesticide in foods and 

from other nonoccupational sources of exposure, and any special risks posed to infants 

and children. EPA may grant an exemption from the requirement to have a tolerance 

when there is a reasonable certainty that no harm will result from aggregate exposure, 

including all anticipated dietary exposures for which there is reliable information. 

Background 
 

Page 6 GAO-13-145 Conditional Pesticide Registration

OPP—the EPA office primarily responsible for regulating the use of 

pesticides—has regulatory staff in three divisions—Registration, 

Biopesticides and Pollution Prevention, and Antimicrobials—that are 

responsible for registering pesticides.13 The registration process formally 

begins when a registrant submits an application to OPP for a particular 

pesticide. This application is to include data to support the registration of 

the pesticide. In reviewing the application, OPP is to examine, among 

other things, the pesticide’s ingredients; the site or crop on which it is to 

be used; the amount, frequency, and timing of its use; and storage and 

disposal practices. OPP is also to review toxicity tests and studies 

showing how the pesticide affects human health and the environment. 

According to OPP officials, the length of time OPP takes from the initial 

review of an application to the final decision on whether to register a 

pesticide depends on many factors—including whether the pesticide 

being reviewed is similar to any pesticide EPA has previously reviewed—

and, according to OPP officials, can take from 3 to 24 months. After OPP 

completes its review and approves the submitted package, EPA may 

register the pesticide without imposing requirements for additional data 

(unconditional registration) under FIFRA 3(c)(5) if EPA determines, 

among other things, that use of the pesticide in accordance with label 

directions will not have unreasonable adverse effects on the 

environment.14

 

13The Registration Division is responsible for certain regulatory activities related to market 

entry of new pesticides—including product registrations, amendments, tolerances, 

experimental use permits, and emergency exemptions—associated with conventional 

pesticides, which are man-made chemicals developed and produced primarily or only for 

use as pesticides. The Biopesticides and Pollution Prevention Division is responsible for 

all regulatory activities associated with biologically based pesticides, which are chemicals 

derived from plants, fungi, bacteria or other natural substances that can be used for pest 

control, as well as for Plant-Incorporated Protectants, which refers to the material added to 

or generated in plants that have been genetically engineered to express a pesticidal 

property. The Antimicrobials Division is responsible for all regulatory activities associated 

with antimicrobial pesticides, which are chemical substances that can be used to kill 

microorganisms.

14FIFRA section 3(c)(5) provides that the EPA Administrator shall register a pesticide if the 

Administrator determines, among other things, that (1) the pesticide’s composition is such 

as to warrant the proposed claims for it; (2) its labeling and other material required to be 

submitted comply with the requirements of FIFRA; (3) it will perform its intended function 

without unreasonable adverse effects on the environment; and (4) when used in 

accordance with widespread and commonly recognized practice it will not generally cause 

unreasonable adverse effects on the environment.
 

Page 7 GAO-13-145 Conditional Pesticide Registration

Alternatively, FIFRA section 3(c)(7) allows EPA to grant a conditional 

registration for pesticides in the following circumstances:

• Identical/substantially similar pesticides (FIFRA Section 3(c)(7)(A)).

EPA may conditionally approve an application for registration or an 

amended registration for a pesticide product if the agency determines 

that

• the pesticide and proposed use are identical or substantially 

similar to any currently registered pesticide and its uses, or differ 

only in ways that will not significantly increase the risk of 

unreasonable adverse effects on the environment; and

• approving the registration or amendment in the manner proposed 

would not significantly increase the risk of any unreasonable 

adverse effect on the environment.

Each registration issued under 3(c)(7)(A) must submit or cite the same 

data that would be required for the unconditional registration of a similar 

product.

• New uses (FIFRA Section 3(c)(7)(B)). A current pesticide registration 

may be amended to allow additional uses, even if the data concerning 

the pesticide may be insufficient to support unconditional registration, 

if EPA determines that

• the applicant has submitted satisfactory data pertaining to the 

proposed additional use; and

• amending the registration would not significantly increase the risk 

of unreasonable adverse effect on the environment.
 

Page 8 GAO-13-145 Conditional Pesticide Registration

Each registrant must submit or cite the same data that would be required 

for the unconditional registration of a similar product.15

• New active ingredients (FIFRA Section 3(c)(7)(C)). A pesticide 

containing a new active ingredient not found in any currently 

registered pesticide can be conditionally registered for a period 

reasonably sufficient for the generation and submission of required 

data, if EPA determines

• insufficient time has elapsed since the imposition of the data 

requirement for those data to be developed and on the condition 

that when the agency receives such data that they do not meet or 

exceed risk criteria stated in the regulations issued under FIFRA 

and other conditions issued by the agency;

• the use of the pesticide during the period of the conditional 

registration will not cause unreasonable adverse effect on the

environment; and

• the use of the pesticide is in the public interest.

After a pesticide product is conditionally registered under FIFRA section 

(3)(c)(7), the registrant receives a notice indicating the terms of the 

conditional registration, including a list of any additional data that will 

need to be submitted and deadlines for submitting these data. Figure 1 

summarizes the pesticide registration and tolerance setting process.

 

15In addition, FIFRA implementing regulations state that EPA will not approve the 

conditional registration of a pesticide product for a new use if (1) the pesticide is the 

subject of a special review to determine if the use of the pesticide may result in 

unreasonable adverse effects based on a use of the product that results in human dietary 

exposure or (2) the proposed new use is for a major food or feed crop (such as corn or 

soy beans), or involves use on a minor food (including many fruits and vegetables) or feed 

crop for which there is an effective alternative registered pesticide that does not meet the 

FIFRA criteria for risk associated with human dietary exposure. 
 

Page 9 GAO-13-145 Conditional Pesticide Registration

Figure 1: General Overview of EPA Pesticide Registration and Tolerance Setting 

Process
 

Page 10 GAO-13-145 Conditional Pesticide Registration

According to EPA officials, once a pesticide is conditionally registered, 

EPA typically grants a period of time, generally 1 to 4 years, for the 

registrant to provide the required data. The registrant can ask EPA to 

waive the requirement for additional information or, according to EPA 

officials, extend the time frame. If the registrant does not submit the data 

specified within the required time frame, EPA can cancel the pesticide 

registration.

Before a pesticide can be sold or distributed in the United States, it must 

be registered under FIFRA.

16 At any time, EPA may initiate a suspension 

or cancellation proceeding for a pesticide registration if safety concerns 

develop. For example, EPA began proceedings to cancel some uses of 

Carbofuran17—an insecticide and nematicide that was registered to 

control pests in soils and on leaves in a variety of field, fruit, and 

vegetable crops—after the agency determined that the dietary, worker, 

and ecological risks of this pesticide were unacceptable.18

Another check on the safety of registered pesticide products is the 

requirement in FIFRA section 6(a)(2) and FIFRA implementing 

regulations that registrants report adverse effects-related information to 

EPA. For example, registrants are required to submit certain toxicity 

information concerning the product both before and after registration, 

such as information on the product’s toxicity to nontarget plant species.

In addition, as required by FIFRA,19

 

16In addition to an EPA registration, registrants must also comply with state regulations, 

some of which require registration in the state before the product can be sold or 

distributed in that state.

EPA is to review the safety of each 

registered pesticide every 15 years to help ensure that each pesticide 

registration continues to satisfy the regulatory standard. In 2007, EPA 

1774 Fed. Reg. 11,551 (Mar. 18, 2009).

18A nematicide kills nematodes, which are microscopic, worm-like organisms that feed on 

plant roots.

19FIFRA section 3(g) requires that EPA periodically reevaluate registered pesticides. 
 

Page 11 GAO-13-145 Conditional Pesticide Registration

began conducting these reviews under its registration review program.20

In 2003 amendments to FIFRA,

As a part of this program, if EPA determines that additional data are 

needed to support the continued registration of a pesticide, the agency 

may issue a Data Call-In (DCI) notice, as authorized by FIFRA section 

3(c)(2)(B), requiring the registrant to provide the data by a specific date.

Also, at any time after a pesticide is registered, a registrant may apply to 

amend the registration and, according to OPP officials, such requests are 

reviewed as though the registrant is seeking approval for a new pesticide.

While reviewing such requests, the agency may also issue a DCI notice 

requiring the registrant to provide additional data by a specific date. If a 

registrant fails to provide the data requested through a DCI, EPA may 

suspend the pesticide’s registration under authority of FIFRA section 

3(c)(2)(B).

21 pesticide registration fees paid by 

registrants were established for some registration actions, such as 

registrations for new uses of pesticides, to help pay for registration costs.

Earlier amendments to FIFRA, enacted in 1988, established annual 

registration maintenance fees—fees used to support the review of 

existing pesticide registrations. For fiscal year 2012, EPA reported that it 

collected a total of $37.6 million from fees, including $22 million in 

maintenance fees.22

In July 2010, an environmental group requested information from EPA 

regarding conditional registrations, including the number of conditional 

 

20Procedural regulations for the registration review of pesticides became effective on 

October 10, 2006. By law, the agency must complete the first 15-year cycle of registration 

review by October 1, 2022. The agency must complete the registration review of each new 

pesticide active ingredient within 15 years of its initial registration. Previously, EPA 

conducted similar reviews of pesticides first registered before November 1984 under its 

reregistration program. Registration review is replacing the reregistration program. Unlike 

reregistration, registration review is to operate continuously and encompass all registered 

pesticides, according to EPA. 

21The Pesticide Registration Improvement Act of 2003 (PRIA), Pub. L. No. 108-199, Div. 

G, Tit. V, § 501, 118 Stat. 419 (2004), amended FIFRA by, among other things, 

establishing pesticide registration fees for some registration actions. PRIA was 

reauthorized in 2007 (Pesticide Registration Improvement Renewal Act of 2007, Pub. L. 

No. 110-94, 121 Stat. 1000 (2007) or PRIA 2) and again in 2012 (Pesticide Registration 

Improvement Extension Act of 2012, Pub. L. No. 112-177, 126 Stat. 1327, or PRIA 3).

22EPA, Fiscal Year 2012 Justification of Appropriation Estimates for the Committee on 

Appropriations, EPA-190-R-11-003.
 

Page 12 GAO-13-145 Conditional Pesticide Registration

registrations the agency had issued, whether registrants had submitted 

the additional data required by the registrations, and whether EPA had 

reviewed the data submitted.23 OPP provided the group with information 

from the OPPIN data system on the number of pesticide registrations that 

had been categorized as conditional. Subsequently, in September 2010, 

the environmental group raised concerns about EPA’s use of its 

conditional registration authority, and several other environmental groups 

and other interested parties supported this position. Among other things, 

the environmental group asserted that EPA had overused conditional 

registrations and did not appear to have a reliable tracking system to 

identify the status of conditionally registered pesticides to ensure that 

registrants submitted, and EPA reviewed, additional data in a timely 

manner.24 In addition, the group noted that the information EPA provided 

indicated that many pesticides have remained in conditional status for 

many years. For example, the information showed that over 3,200 

pesticides had been in conditional status since 1995 (15 years) and that 

2,100 pesticides had been in conditional status since 1990 (20 years).

The number of active conditional registrations EPA has granted is 

unclear, according to OPP officials who, as a result of a 2011 EPA 

review, found the agency’s registration data to be inaccurate and the 

basis for granting some of these registrations to be inappropriately 

classified. Specifically, an internal review of OPP’s conditional registration 

program found that OPPIN does not allow officials to change a pesticide’s 

registration status from conditional to unconditional once the registrant 

has satisfied all data requirements, and the basis for many registration 

decisions was mischaracterized as conditional. In addition, based on the 

internal review, OPP officials concluded that several weaknesses 

contributed to this misclassification problem, including insufficient 

guidance and training, management oversight, and data management. As 

of July 2013, OPP officials told us that the office has taken or is planning 

to take several actions to more accurately account for conditional 

registrations.

 

23The Natural Resources Defense Council (NRDC) requested the information regarding 

EPA’s use of conditional registrations.

24The groups that concurred with NRDC’s position on EPA’s use of conditional 

registrations were Alaska Community Action on Toxics, Beyond Pesticides, Center for 

Environmental Health, Friends of the Earth U.S., Organic Consumers Association, 

Pesticide Action Network North America, and TEDX The Endocrine Disruptor Exchange.

Total Number 

of Conditional 

Registrations 

Granted Is Unclear, 

as EPA Found Data 

to Be Inaccurate
 

Page 13 GAO-13-145 Conditional Pesticide Registration

According to OPP officials, following an internal review of its conditional 

registration program that it completed in March 2011, OPP concluded that 

the OPPIN data on the number of conditional registrations were 

inaccurate. The internal review was conducted, in part, to determine the 

number of conditional registrations granted by EPA. According to 

information on OPP’s website,25 during the internal review, OPP 

determined that OPPIN contained 16,156 active pesticide registrations 

and that 11,205 (69 percent) of these pesticides were conditionally 

registered. However, OPP officials concluded, based on the internal 

review, that the data were inaccurate, and that the number of conditional 

registrations was overstated, for two reasons. First, once a registration is 

classified as conditional in OPPIN, its status in this data system cannot be 

changed from conditional to unconditional, when, for example, the 

registrant has satisfied all data requirements imposed. According to the 

internal review, OPPIN is an older system that was not designed 

specifically to track conditional registrations and thus is ill-suited for that 

purpose. To determine the current number of conditionally registered 

pesticides, OPP officials said detailed paper files that support each 

pesticide registration would need to be reviewed, which would be a very 

time-consuming process. OPP officials indicated that they plan to develop 

a new automated system for tracking conditional registrations and, in 

fiscal year 2013, they began using a portion of the registration 

maintenance fees collected annually to begin exploring the feasibility of 

implementing such a system.26

Second, as a result of the internal review, OPP found that its regulatory 

staff had incorrectly categorized the basis for many program actions in 

OPPIN as “conditional registrations” and that these incorrect 

However, these officials were uncertain 

about the ultimate cost of this system, what sources they would use for 

any additional funding, and when the system would be operational.

 

25OPP’s website can be found at 

http://www.epa.gov/pesticides/regulating/conditional-registration.html. 

26The Pesticide Registration Improvement Extension Act of 2012 amended FIFRA to 

provide, among other things, funding to improve the information systems capabilities for 

OPP; the amendments provide that this funding is to support enhancing the systems 

capacity to track pesticide registration decisions, including the status of conditional 

registrations. The amendments authorize $800,000 per year for 5 years to be set aside 

from the maintenance fees to fund these enhancements, including those related to 

conditional registrations. In addition, the amendments require, in part, that EPA report 

each year through 2017 on its progress in implementing a system for tracking the status of 

conditional registrations. 

EPA Found Conditional 

Registration Data to Be 

Inaccurate and That the 

Basis for Many 

Registrations Was 

Inappropriately Classified
 

Page 14 GAO-13-145 Conditional Pesticide Registration

categorizations resulted in an overcounting of conditional registrations.

According to the internal review, OPP staff had used conditional 

registrations to describe a variety of actions that fall outside of the 

circumstances authorized by FIFRA Section 3(c)(7). For example, 

according to OPP officials and the internal review, OPP staff had 

assigned the category “conditional registration” to situations where 

approval of a registration is contingent upon the “condition” that the 

registrant makes a change that does not involve generating additional 

data. These situations included certain changes to pesticide product 

labels—such as strengthening precautionary statements—that are not 

specified by FIFRA section 3(c)(7), according to the results of the internal 

review. Similarly, OPP staff categorized as “conditional registrations” 

situations where the agency requested registrants to provide certain 

pesticide product-specific information—such as product chemistry studies 

related to storage stability that are used to determine label 

requirements—that do not fall under FIFRA Section 3(c)(7). The incorrect 

classification of actions as conditional registrations, according to the 

internal review, may leave the agency vulnerable to allegations by 

environmental, industry, and other stakeholders who assert that EPA 

inappropriately grants conditional registrations. However, according to 

OPP officials, all of the actions that were mistakenly categorized as 

conditional registrations were legitimate program actions that were lawful 

under other sections of FIFRA. We were unable to verify this assertion. 

Further, EPA still needs to take steps to correct these misclassifications in 

order to ensure the accuracy and integrity of its data and make clear the 

statutory basis for these program actions.

Several weaknesses contributed to incorrect data entries into OPPIN.

First, according to OPP officials, OPP regulatory staff did not have 

sufficient guidance or training to help them determine when a program 

action met the criteria for conditional registration. Second, according to 

OPP’s internal review, there was limited, organized management 

oversight to ensure that regulatory actions not subject to the narrow 

scope of section 3(c)(7) were not mischaracterized by OPP staff as 

conditional registrations. As a result, as the internal review stated, the 

actions that were classified as conditional registrations have varied 

across OPP’s three divisions and by individual entering data into OPPIN 

within each division. In addition, data management weaknesses 

contributed to the misclassification of registrations or other actions as 

conditional. For example, OPP officials said that OPPIN does not 

generate management reports of summary data that could have alerted 

managers to the excessive use of “conditional registration” due to the 

Several Weaknesses 

Contributed to Incorrect 

Data Entry on Conditional 

Registrations 
 

Page 15 GAO-13-145 Conditional Pesticide Registration

inaccurate classification of actions as conditional registrations by OPP 

staff. Under the federal standards for internal control, federal agencies 

are to employ internal control activities, such as management reviews at

the functional or activity level, to help ensure that management’s 

directives are carried out and to determine if agencies are effectively and 

efficiently using resources.27

In light of the apparent widespread misclassification of regulatory actions 

as conditional registration, OPP, as part of its internal review of 

conditional registrations, analyzed data in OPPIN to, among other things, 

determine EPA’s historical use of conditional registrations, including how 

many of each of the three types of conditional registrations authorized by 

FIFRA section 3(c)(7) had been granted. The OPP official primarily 

responsible for conducting this analysis said the intent of the analysis was 

to show that (1) as noted on the OPP website, only a small portion of the 

conditional registrations granted by EPA were for new uses under section 

3(c)(7)(B) or new active ingredients under section 3(c)(7)(C), as intended, 

and (2) most of the conditional registrations granted were for identical or 

substantially similar products under section 3(c)(7)(A). However, in 

reviewing this information and related documentation, we found that the 

information on the website was unclear, contained discrepancies, and 

used technical terms without defining them, which could lead to 

misinterpretation of the information. For example, the calculations 

presented on the website to support the conclusion that the overwhelming 

majority of actions identified in OPPIN as conditional registrations fall 

outside the circumstances authorized by FIFRA section 3(c)(7) incorrectly 

grouped conditional registrations for identical or substantially similar 

products authorized by section 3(c)(7)(A) with label amendments and 

other actions that fall outside the narrow scope of section 3(c)(7). After 

meeting with OPP officials in November 2012 to discuss the analysis, 

these officials acknowledged the website could be clearer and said that 

the website would be revised to clarify any confusing language and 

correct any inaccurate statements. However, OPP had no specific plan or 

Without the ability to generate summary data 

on conditional registrations from OPPIN, OPP managers cannot easily 

conduct such reviews. However, they are still responsible for monitoring 

and ensuring the accuracy of conditional registration data.

 

27GAO, Standards for Internal Control in the Federal Government, GAO/AIMD-00-21.3.1

(Washington, D.C.: November 1999). 
 

Page 16 GAO-13-145 Conditional Pesticide Registration

time frame for doing so. As of July 2013, these clarifications and 

corrections had not been made.

Accurate and reliable data are essential to an efficient and effective 

operating environment in the federal government. To more accurately 

report on the number of pesticide products that are conditionally 

registered, OPP officials told us that the office has taken or planned to 

take the following actions:

• Beginning in the fall of 2010, representatives of the OPP divisions that 

deal with pesticide registrations began meeting with OPP 

management at least quarterly to, among other things, review 

proposed conditional registrations for pesticide products with new 

active ingredients to ensure that (1) any new conditional registrations 

granted for these products meet the circumstances outlined in FIFRA 

Section 3(c)(7)(C); (2) the additional data that would be requested as 

a part of the conditional registration are really needed; and (3) if the 

data are needed, EPA is still able to make the determination that the 

information available concerning the pesticide demonstrates that the 

FIFRA safety standard will be met, which requires that the use of the 

product during the time needed to generate the necessary data will 

not cause unreasonable adverse effects on the environment.

According to OPP officials, since they started these quarterly reviews, 

the number of conditional registrations granted for new active 

ingredients generally has dropped. For example, since starting these 

reviews, they have been able to preclude cases of misclassification of 

new active ingredient registrations as “conditional” that had been 

occurring in the past. Specifically, they noted that, prior to 2010, in 

some cases, OPP staff had classified some of these registrations as 

conditional when the additional data being requested of the registrant 

could only be generated after the date of registration, such as data 

measuring the storage stability of a commercially manufactured 

version of the newly registered pesticide product. According to OPP 

officials, they do not regard such data requirements as being within 

the scope of FIFRA section 3(c)(7).

• In 2012, OPP began revising the registration categories in OPPIN to, 

among other things, more accurately reflect those circumstances 

under which conditional registrations may be granted under FIFRA.

As of May 2013, OPP officials said that they had completed 

development of the categories and provided training to their regulatory

staff on how to correctly assign the new categories to each type of 

registration. In July 2013, OPP officials said they had completed 

OPP Is Taking, or Plans 

to Take, Actions to More 

Accurately Account for 

Conditional Registrations
 

Page 17 GAO-13-145 Conditional Pesticide Registration

implementation of the new codes in OPPIN. In addition to the

training, OPP officials noted the training materials will be available 

online for regulatory staff to consult for guidance on an ongoing basis.

• In fiscal year 2013, OPP began using a portion of the maintenance 

fees it collects to begin development of an electronic tracking system 

for conditional registrations. As discussed, OPP officials are not 

certain what the total cost of the system will be or when the system 

will be ready for implementation.

Table 1 summarizes the status, according to OPP officials, of key actions 

taken or planned by OPP to improve the reliability of conditional 

registration data. 
 

Page 18 GAO-13-145 Conditional Pesticide Registration

Table 1: OPP Actions Taken or Planned to Improve the Reliability of Conditional Registration Data

Action Planned completion date Status 

Potential barriers that may 

affect completion

Conduct quarterly OPP 

meetings to review the status 

of conditional registrations.

Ongoing Began holding meetings in 

fall 2010.

None

Develop and implement new 

registration categories in OPPIN 

to more accurately reflect 

statutory basis for registration, 

including conditional 

registrations.

June 2013 Development of codes for these 

categories was completed in 

spring 2013. In July 2013, OPP 

officials indicated that they had 

completed the implementation 

of the new codes in OPPIN.

None

Train regulatory staff to use 

new codes.

Spring or summer 2013 Completed in spring 2013. None

Design a new automated 

system that will include tools to 

improve the identification, 

tracking, reporting, and program 

management of conditional 

registrations.

2014 or beyond In fiscal year 2013, began using 

a portion of the maintenance 

fees collected to start 

developing the system.

Complexity of system and size 

needed to manage the data.

Availability of needed funding.

Source: EPA.

While OPP officials acknowledged the need to ensure that registrations 

are accurately classified to reflect their statutory basis and to develop an 

electronic data system for tracking the status of conditional registrations, 

they stated that EPA’s past practices for managing conditional 

registrations have not created additional risks to the environment and 

have been in compliance with applicable laws. Specifically, an EPA 

attorney stated that the agency views products conditionally registered as 

identical or substantially similar to currently registered pesticides under 

section 3(c)(7)(A) and as new uses of currently registered pesticides 

under section 3(c)(7)(B) as meeting the same safety standards as 

products registered “unconditionally” under section 3(c)(5). Therefore, 

according to this official, these products do not pose unreasonable 

adverse effects on human health or the environment. Further, a Deputy 

Director of OPP said section 3(c)(7)(A) and section 3(c)(7)(B) 

registrations make up the bulk of conditionally registered pesticides. In 

addition, OPP officials stressed that the program actions that were 

mischaracterized as conditional registrations were nevertheless legitimate 

program actions. Specifically, these officials and OPP’s website note that 

most of these actions were taken pursuant to the authority of FIFRA 

implementing regulations and should have been identified as such.

Moreover, the EPA attorney stated that FIFRA does not require EPA to 
 

Page 19 GAO-13-145 Conditional Pesticide Registration

convert a registration from “conditional” to “unconditional” when all 

additional data requirements have been satisfied. So, according to this 

official, the fact that EPA has not done so in OPPIN in the past does not 

raise a legal issue. However, despite these assertions, EPA should still 

take steps to ensure that its data on the registration status of individual 

pesticide products are current and accurate.

The extent to which EPA ensures that registrants submit the additional 

data required when it grants conditional registrations or that it has 

reviewed these data is unknown. In particular, OPP does not have a 

reliable system, such as an automated data system, designed specifically 

to track key information related to conditional registrations, including 

whether registrants submitted additional data within required time frames 

and OPP reviewed these data. OPP officials acknowledged this lack of a 

comprehensive means to track the status of conditional registrations, and 

noted, as discussed, their intention to develop such a system. However, 

these officials, as well as OPP’s website, note that the conditions for most 

of these registrations have likely been satisfied as a result of routine 

program operations that, in the OPP officials’ view, constitute a quality 

assurance check. While these program operations may help to identify 

some situations where required data are missing, they fall short of what is 

needed because they are neither comprehensive nor do they ensure the 

timely submission of these data. This is a key reason that OPP officials 

are currently conducting a manual review of the files of the more than 

16,000 active pesticide registrations OPP has issued, including 

conditional registrations, to identify any missing data, misclassified 

registrations, or other problems.

OPP lacks a reliable system specifically to track the status of conditional 

registrations to ensure that additional required data are submitted and 

timely, and that OPP reviews these data. As discussed, EPA currently 

“tracks” conditional registrations in OPPIN, an older data system that was 

not designed for this purpose and that does not have, among other 

things, the capability to flag situations in which required data have not 

been submitted by registrants or reviewed by OPP. Federal internal 

control standards require, in part, that information should be recorded and 

communicated to management and others within the entity who need it 

and in a form and within a time frame that enables them to carry out their 

Extent to Which EPA 

Ensures That 

Registrants Submit 

Additional Required 

Data and EPA 

Reviews These Data 

Is Unknown

OPP’s Lack of a Reliable 

System to Track 

Conditional Registrations 

Hinders Its Ability to 

Ensure that Data Are 

Submitted, Timely, 

and Reviewed
 

Page 20 GAO-13-145 Conditional Pesticide Registration

internal control and other responsibilities.28 Thus, for an entity to run and 

control its operations, it must obtain, maintain, and use relevant, reliable, 

and timely information for program oversight and decision making.

Furthermore, the Office of Management and Budget (OMB) directs 

agency managers to take timely and effective action to correct internal 

control weaknesses.29

In addition, without a reliable tracking system, OPP may miss conditional 

pesticides where, had the additional required data been submitted and 

reviewed, OPP might have altered the terms of a registration. OPP 

officials acknowledged there have been cases in which their 

consideration of these additional data led them to make minor changes to 

a registration, although they could not recall a case where these 

additional data prompted them to cancel a registration. These officials 

emphasized, and OPP documents state, that in issuing a conditional 

registration, even though OPP may ask the registrant for additional data, 

OPP has determined that the pesticide when used in accordance with 

labeling and common practices will not cause unreasonable adverse 

effects on the environment, and that OPP’s registration decision takes 

into account the economic, social, and environmental costs and benefits

of the use of that pesticide. Nevertheless, without the ability to 

systematically track conditional registrations, OPP is not well-positioned 

to produce summary data to enable it to easily identify situations for 

priority follow-up; enforce FIFRA and its implementing regulations; and 

report to Congress and others on program status. For example, without 

this tracking, it is more difficult to identify patterns of potential problems 

for management attention, such as registrants that are repeatedly late in 

As measured against this internal control standard, 

EPA’s lack of a reliable and comprehensive means of routinely collecting 

and tracking information on conditional registrations, including the status 

of registrants’ submission of required data and OPP’s review of these 

data, constitutes an internal control weakness and leaves OPP without an 

important management tool. For example, when registrants miss due 

dates without applying for waivers or extensions, it is difficult for OPP 

without a reliable tracking system to identify these cases for priority 

follow-up and notify the registrants that their pesticide registrations could 

be cancelled.

 

28GAO/AIMD-00-21.3.1. 

29Office of Management and Budget, Management’s Responsibility for Internal Control, 

OMB Circular No. A-123, Dec. 21, 2004.
 

Page 21 GAO-13-145 Conditional Pesticide Registration

providing additional required data for their conditional registrations, which 

could be the basis for canceling these registrations.

OPP’s problems with data management have been well-documented over 

the years. GAO studies dating back to 1980, 1986, 1991 and 1992 noted 

problems with OPP data systems used to track the status of pesticide 

registrations.30 For example, the 1986 study found that OPP did not have 

a data system for monitoring whether registrants were submitting the data 

required by conditional registrations and could only determine the status 

of data submissions by performing a time-consuming manual file search.

At the time, we recommended that OPP take steps to review outstanding 

conditional registrations of new active ingredients and determine what 

progress is being made by registrants to submit the required data and 

take appropriate action. In response to our recommendation, OPP said it 

was developing a new automated system to track all outstanding data 

requirements. However, as discussed, OPP does not currently have such 

a system. The 1992 study noted that, after having spent $14 million over 

3 years in data systems development, OPP could not easily assemble 

accurate, reliable, and complete information on pesticides subject to 

reregistration (now registration review). EPA Inspector General studies in 

1994 and 2000 noted that OPP had not completed actions to improve 

information systems that contain inaccurate, incomplete, and duplicate 

data or that are not integrated.31 In addition, a 2007 EPA contractor study 

found that many of these problems persist, especially with OPPIN.32

Noting that OPPIN was launched in 2000,33

 

30These reports are listed under “Related GAO Products” at the end of this report. 

this study found that this 

system had failed to meet the needs of OPP staff and that many of these 

staff had created “one-off” (off-line) tracking systems in order to get their 

jobs done, making comprehensive, reliable status updates, such as 

whether required data had been submitted and reviewed, very difficult to 

retrieve. The study also reported that OPPIN lacks the needed data fields 

and reporting functions for detailed tracking of the status of pesticide 

31EPA Office of Inspector General, EPA’s Pesticide Program, Report no. E1EPE2-05-

0015-4100205, Mar. 11, 1994; EPA Office of Inspector General, Pesticides: Follow-up 

Report on EPA’s Pesticide Program, Report no. 00P00011, Mar. 27, 2000. 

32EPA, Evaluation of the U.S. EPA Pesticide Product Reregistration Process: 

Opportunities for Efficiency and Innovation, March 2007, done by Abt Associates under 

EPA contract EP-W-04-023.

33According to EPA, although work on OPPIN began in 2000, the system was not 

operational until 2003.
 

Page 22 GAO-13-145 Conditional Pesticide Registration

registrations, and that multiple OPP staff had expressed dissatisfaction 

with OPPIN, stating that it is not user-friendly, data are not current or 

complete, and it lacks a “report card” function to easily check the status of 

pesticide registrations, including reregistration status. Although the 

contractor study noted that OPPIN was to be retired in September 2008, 

we found, as discussed, that OPP is still using OPPIN despite its many 

limitations.

OPP officials said, and the internal review states, that the conditions for 

most conditional registrations have likely been satisfied as a result of 

routine program operations that, in their view, constitute a quality 

assurance check. However, these operations fall short of what is needed 

for quality assurance because they are neither comprehensive nor do 

they ensure the timely submission of the additional data required as a 

condition of the registration. The program operations mentioned by OPP 

include the following:

• good faith submissions made by registrants to satisfy additional data 

requirements;

• record keeping and targeted follow-up done by pesticide product 

managers;

• state pesticide registration actions that may bring to light missing data 

required by the OPP’s conditional registration of a pesticide;

• missing data identified as part of OPP’s periodic reevaluation of 

registered pesticides; and

• registrant-initiated actions, such as label change amendments, that 

bring to light missing data associated with an earlier conditional 

registration.

The program operations OPP officials identified may help identify some 

situations where required data are missing, but they each have limitations 

and fall short of what is needed, as follows:

• Registrant submissions: While undoubtedly many registrants are 

conscientious about their timely submission of additional data required 

by their conditional registrations, OPP has found cases in the past 

where required data were not submitted or were submitted late. As 

discussed, once OPP issues a conditional registration, the registrant 

can move the associated pesticide product into the marketplace. In 

that sense, the registrant’s commercialization of that product is not 

Although Helpful in 

Identifying Missing 

Information, Routine 

Program Operations Fall 

Short of What Is Needed
 

Page 23 GAO-13-145 Conditional Pesticide Registration

contingent on the registrant’s submission of the additional required 

data. In addition, because OPPIN does not have the ability to 

systematically flag missing or late data, some registrants may be 

emboldened to delay or give less priority to developing and submitting 

these additional data.

• Product manager actions: The record keeping and targeted follow-up 

done by OPP product managers also have limitations. According to 

OPP officials, each of OPP’s 20 product managers is responsible for 

tracking about 800 of the more than 16,000 active pesticide 

registrations maintained by OPP. While OPP officials acknowledged 

that each manager has a very broad span of control, there are other 

OPP regulatory staff who assist these managers. Moreover, of the 

approximately 800 registrations handled by each manager, conditional 

registrations constitute a subset, particularly for new active 

ingredients. However, we found that OPP had not provided written 

guidance to product managers on how to track the status of the 

pesticide registrations for which they are responsible. As a result, 

according to OPP officials, product managers use a variety of 

methods to track this information, including electronic spreadsheets or 

reminder notices, handwritten notes, and memory. Without OPP 

guidance on how product managers should maintain their pesticide 

registration files, in the case of the retirement or resignation of an 

experienced manager—or even the extended absence of a manager 

due to illness—other managers asked to replace or fill in for this 

manager may not be familiar with how he or she maintained files or 

data, or the extent to which this official relied on memory versus 

written records. Furthermore, requiring all product managers to track 

the status of registrations in a consistent, electronic format would help 

OPP meet the goals of an August 2012 OMB directive that, among 

other things, directs executive agencies to the fullest extent possible

to eliminate paper and use electronic record keeping to ensure 

transparency, efficiency, and accountability. The directive is 

applicable to all executive agencies and all records.34

• State registration: While state pesticides registration activities may 

help to bring to light missing data associated with conditional 

registrations issued by OPP, the extent to which this happens is 

unknown and should not be relied upon as a quality assurance check.

After OPP registers a pesticide, states also can register that pesticide 

 

34OMB, Managing Government Records Directive, M-12-18, Aug. 24, 2012.
 

Page 24 GAO-13-145 Conditional Pesticide Registration

under specific state pesticide registration laws. A state may be more 

stringent in registering a pesticide for use in that state, but its 

registration requirements generally may not be less stringent than the 

federal requirements. In addition, states generally have primary 

responsibility (known as “primacy”) for enforcement of the proper use 

of pesticides within their borders.

• Periodic review of registered pesticides: As discussed, FIFRA 

requires that EPA periodically reevaluate registered pesticides to 

ensure that each registration continues to satisfy regulatory 

standards. EPA originally did this reevaluation under its reregistration 

program, applicable to pesticides registered prior to November 1984. 

More recently, this reevaluation is being done under the agency’s 

registration review program. According to OPP officials, this periodic 

review of previously registered pesticides provides an opportunity to 

identify missing data required by a conditional registration. For 

example, these officials said any missing data related to section

3(c)(7)(A) (identical or similar) or (B) (new uses) can be identified 

through registration review. They explained that registrations under 

these sections do not impose new data requirements. Instead, these 

registrations are issued when there is an outstanding DCI, or planned 

DCI, for an identical or similar currently registered pesticide. Thus, 

according to OPP officials, because registrations under these sections 

are linked to DCIs, and OPP’s Pesticide Registration Information 

System (PRISM) is used to track DCIs,35

 

35PRISM is an OPP data system that is intended to provide a centralized source of 

information on all registered pesticide products, including chemical composition, toxicity, 

name and address of registrant, brand names, registration actions, and related data. 

they are confident in their 

ability to ensure the timely submission of required data. They noted 

that PRISM is a newer and more robust data system than OPPIN. 

They also noted that (1) most conditional registrations are made 

under sections 3(c)(7)(A) or (B), (2) the associated DCIs place a legal 

obligation on the registrant to provide the requested data, and (3) 

OPP may suspend a registration for failure to respond to a DCI.

However, we note that PRISM has apparent limitations as well. For 

example, OPP officials said that PRISM is not designed, per se, to 

track conditional registrations and therefore cannot be used to identify 

the conditional registrations, if any, associated with a particular DCI.

In addition, they said while this system is useful for tracking the status 

of DCIs on a case-by-case basis, PRISM lacks the capability to 

produce summary reports for management attention that could 
 

Page 25 GAO-13-145 Conditional Pesticide Registration

indicate, for example, the extent to which registrants are meeting the 

requirement to provide an initial response to a DCI within 90 days.36

Furthermore, as acknowledged by OPP officials, registration review is 

not helpful in tracking the status of conditional registrations made for 

new active ingredients under FIFRA section 3(c)(7)(C). For these 

registrations, there is no relationship to an identical or similar, 

currently registered pesticide. As a result, the potential exists that a 

conditionally registered pesticide under this section would continue to 

be sold and used in the United States for a number of years before 

OPP discovered that the additional data required had not been 

submitted and were late. In reviewing OPP documents related to the 

conditional registration of new active ingredients done in the early 

2000s, we noted such cases. In each case, when the associated 

pesticide product came up for registration review, OPP determined 

that some of the required data related to the original conditional 

registration had not been submitted and were late or, if submitted, had 

not been reviewed by OPP. For example, in the case of a pesticide 

product containing the active ingredient Foramsulfuron, conditionally 

registered in November 2002, two required studies on the effects of 

this pesticide on terrestrial and aquatic plants that were due in 

December 2004 had not been submitted 10 years after the conditional 

registration was issued, as determined by OPP’s registration review of 

this pesticide in 2012.37

 

36In July 2013, in its technical comments on a draft of this report, EPA stated that PRISM 

is now capable of producing summary reports for management. However, the agency 

neither explained what these reports are nor did it provide examples.

In another case, involving a pesticide product 

containing the active ingredient Acetamiprid, conditionally registered 

in March 2002, OPP discovered during its registration review of this 

pesticide in 2012, about 10 years later, that it had received, but not 

reviewed, a study related to the effects of this pesticide on 

honeybees. OPP documents indicate the registrant submitted this 

study in 2001, even before OPP granted the conditional registration. 

Acetamiprid belongs to a class of pesticides called neonicotinoids that 

some beekeepers, environmental groups, and others suspect of

having adverse effects on honeybees. 

37In July 2013, in its technical comments on a draft of this report, EPA said that after 

contacting the registrant and determining that the registrant did not intend to fulfill the 

requirements of its conditional registration for this product, the agency cancelled the 

registration in February 2013 (78 FR 8513, Feb. 6, 2013). The registrations of other 

pesticide products containing Foramsulfuron were not affected by this cancellation.
 

Page 26 GAO-13-145 Conditional Pesticide Registration

• Registrant-initiated actions: According to OPP officials, if a registrant 

applies to amend a registration, such as to make a label change, this 

action triggers an OPP review of the data supporting the pesticide 

registration and provides an opportunity to identify missing data 

associated with a conditional registration. If it is determined that data 

are missing, the agency may issue a DCI requiring the registrant to 

provide the data by a specific date. However, this mechanism to 

identify missing data is ad hoc and only applies to cases in which a 

registrant seeks to amend its registration.

In addition, OPP officials pointed to an analysis they performed as part of 

OPP’s 2011 internal review that showed registrants usually meet the 

additional data requirements associated with their conditional 

registrations on a timely basis. Specifically, OPP examined 544 

conditional registrations that it granted (1) for new uses or new active 

ingredients under FIFRA sections (3(c)(7)(B) or (C), respectively, and (2) 

from March 2004 to September 2010. According to OPP officials and the 

office’s website, these conditional registrations were selected because, as 

relatively recent registrations, they were the most likely candidates to be 

missing additional required data. In contrast, according to OPP officials, 

older conditional registrations were less likely to be missing data because 

of the application of the cited routine program operations.

To do this analysis, OPP officials said they first identified all additional 

data requirements and associated due dates for these conditional 

registrations, and then manually reviewed the files for these pesticides to 

determine if the required data were submitted and due dates met. When 

finished, OPP concluded that registrants had completed 96 percent of “all 

actions intended” for these 544 conditional registrations in a timely 

manner. OPP posted this information on its website. However, in 

reviewing the information on the website, as well as supporting 

documents provided by OPP, we were unable to verify these calculations, 

in part because OPP was unable to locate some of the supporting 

documentation. In addition, some of the documentation provided did not 

always make clear whether the submitted data had been timely or 

reviewed by OPP. Furthermore, we found that some of the statements on 

the website were confusing; used technical terms such as “registration,” 

“action,” and “decision” without defining the terms; and contained other 

discrepancies. Some of these problems have been cited by legal and 

environmental groups who found this information confusing as well.

Although OPP officials generally agreed that revisions were needed to the 

discussion on the website for clarity, OPP had no specific plan or time 

frame for doing so. Regardless of any clarifications needed to the 
 

Page 27 GAO-13-145 Conditional Pesticide Registration

website, an OPP Deputy Director expressed confidence in the results of 

this analysis. As of July 2013, the discussion of this analysis on the 

website had not been clarified.

In May 2012, OPP staff began manually reviewing the files for the more 

than 16,000 pesticide registrations granted by EPA. The purposes of this 

review include identifying all outstanding data requirements, as well as 

cases where the registration action, such as a label change amendment, 

was mischaracterized as a “conditional registration.” According to OPP 

officials, all prior registrations are being reviewed, not just those classified 

as conditional, because pesticide registrations may have long histories, 

and even though a registration may have been classified initially as 

unconditional, OPP may have imposed additional data requirements at a 

later time.

According to OPP officials, reviewing each pesticide registration file is 

time-consuming and, depending on the pesticide, may take from a few 

hours to a few days to complete. This generally includes OPP regulatory 

staff reviewing voluminous paper files associated with many of these 

pesticide registrations. According to these officials, once this review 

process is completed, OPP will have a “clean” set of data that will, among 

other things, identify (1) any missing data, (2) missed deadlines for 

registrants submitting these data, and (3) cases where the registration 

action was mischaracterized, including the misuse of “conditional 

registration.” These officials said the review results are being recorded in 

an electronic spreadsheet, known as the “master file,” for future use. For 

example, when a pesticide comes up for registration review, OPP officials 

said that staff will refer to the master file to identify any missing data that 

should be included in the DCI resulting from that review.

Although OPP’s review of prior pesticide registrations remains a work in 

progress, OPP provided an excerpt from its electronic spreadsheet 

showing the results for three pesticides that we asked about because 

other agency documents we reviewed suggested possible registration 

issues. For these pesticides, the spreadsheet indicated that most, but not 

all, of the required data had been submitted by registrants; some of these 

data were submitted from 2 to 12 months after the related due dates and, 

for one of these pesticides, no due date was specified in the registration 

notice, making it impossible to determine if the data were submitted ontime. In this last case, OPP officials stated that the lack of due dates in 

the registration notice was an unintentional oversight. Since OPP has not 

finished its review of all prior registrations, it has not yet developed 

OPP Is Manually 

Reviewing All of the 

More than 16,000 

Pesticide Registrations 

to Identify Problems 

Such as Missing Data
 

Page 28 GAO-13-145 Conditional Pesticide Registration

summary statistics on the frequency with which these types of problems 

were found. OPP officials said they plan to complete their manual review 

of prior registrations by the fall of 2013, but its completion by then will 

depend on the amount of time OPP staff can devote to this review relative 

to their other responsibilities. In addition, according to agency officials, by 

the end of calendar year 2013, they plan to make public information from 

the review about the number of active ingredients approved under FIFRA 

section 3(c)(7)(C) for which data are overdue, and those for which data 

were submitted late.

While OPP’s manual review of existing registrations may result in a clean 

data set and identify some missing data and other problems not 

discovered as a result of what OPP calls routine program operations, it is 

an interim measure. Among other things, OPP officials said their office 

needs a comprehensive automated data system for tracking conditional 

registrations. As noted by one OPP division director, “no one wants to 

have to track this information by hand” in the future. In addition, according 

to these officials, OPP does not plan to update the master file to include 

new pesticide registrations or other registration changes that occur in the 

future. They noted that the master file is retrospective, and it provides a 

snapshot in time. Instead, OPP officials said that new pesticide 

registrations and other registration changes will be entered into OPPIN 

using the new codes that OPPIN plans to introduce in June 2013. In July 

2013, EPA advised us that the codes have been entered in OPPIN.

According to these officials, the introduction of these new codes, in 

conjunction with staff training on how to use them, should preclude some 

of the misclassification problems experienced in the past until a new 

comprehensive data system is available to replace OPPIN.
 

Page 29 GAO-13-145 Conditional Pesticide Registration

The 24 stakeholders that responded to our questionnaire—including 

representatives of consumer (3), environmental (6), industry (5), legal (3), 

producer (1), science (1), and state government groups (5)—generally 

indicated that EPA needs to improve its conditional registration process 

and, in some cases, they offered suggestions for improving this 

process.38 The issues that stakeholders raised included concerns about 

the timely submission and review of required data and the misuse of the 

conditional registration designation. In addition, stakeholders’ views 

varied regarding the potential benefits and problems associated with the 

conditional registration of pesticides.

In responding to our questionnaire, respondents in the consumer, 

environmental, industry, legal, science, and state government stakeholder 

groups generally reported concerns with submission or review of required 

data as follows:

• Of the 19 respondents in the consumer, environmental, legal, 

producer, science, and state government groups, 17 reported 

concerns related to registrants not submitting additional required data 

on time, including concerns about pesticides that remain in the 

marketplace when their environmental and health impacts have not 

been fully evaluated.39

 

38Not every stakeholder responded to every question. The questions were open-ended 

and thus issues raised by stakeholders had to be “volunteered.” We did not ask each 

stakeholder to agree or disagree with particular issues. 

In addition, 3 of the 8 respondents from 

consumer groups and state government were generally concerned 

that, when registrants are allowed to miss due dates without any 

follow-up from EPA, there is little incentive for the registrants to submit 

the additional data and take the data requirements seriously. Further, 

4 of the 17 respondents from consumer, environmental, legal, and 

state government groups reported that EPA should cancel 

registrations for those registrants who do not submit required data on 

time.

39OPP officials noted that they share these concerns, but they stated that the results of 

OPP’s internal review of conditional registrations convinced them that these concerns 

have no basis.

Stakeholders 

Generally Said EPA 

Needs to Improve 

Its Conditional 

Registration Process 

and Had Mixed Views 

on the Value of These 

Registrations 

Respondents Generally 

Reported That EPA Needs 

to Improve Its Conditional 

Registration Process
 

Page 30 GAO-13-145 Conditional Pesticide Registration

• Of the 19 respondents from environmental, industry, legal, and state 

government groups, 8 reported concerns about EPA’s record keeping 

related to conditional registrations, including the agency’s ability to 

ensure the receipt and review of required data. Specifically, one 

industry stakeholder stated that EPA does not effectively track the 

receipt and review of required data and said, in particular, EPA does 

not always acknowledge receipt of required information and does not 

always notify recipients whether the data submitted satisfied the 

condition.40

Stakeholders representing environmental, industry, and state government 

groups generally reported concern with EPA issuing conditional 

registrations for circumstances that were outside of the permissible 

situations stated in FIFRA. Examples are as follows:

However, 4 of the 5 respondents from industry stated the 

public faced little risk when required data are not submitted or 

reviewed, pointing out that before EPA conditionally registers a 

pesticide, the agency must determine that the pesticide meets FIFRA 

registration standards.

• Of the 16 respondents representing these groups, 10 reported 

concern that EPA was overusing conditional registrations. Three of 

the 5 environmental stakeholders that had these concerns generally

stated that conditional registrations were originally intended to be 

used in limited circumstances where a public need was established—

such as the need to quickly approve the use of a pesticide to prevent 

significant crop damage and economic loss—and that EPA’s current 

practices for issuing conditional registrations are not in keeping with 

this original intent.41

• Of the 5 respondents from industry, 3 stated that there are cases 

when EPA grants a conditional registration for a pesticide that should 

have qualified for an unconditional registration. These stakeholders 

reported that, in some of these cases, EPA had granted a conditional

 

40EPA officials noted that there is no legal requirement for EPA to acknowledge receipt of 

required information or notify registrants whether the data submitted satisfy the condition 

imposed.

41EPA officials noted that the public interest finding only applies to FIFRA section 

3(c)(7)(C) related to conditional registration of pesticide products with new active 

ingredients, and not to sections 3(c)(7)(A) or (B) related to conditional registration of 

products that are identical or substantially similar to products already registered or new 

uses of products already registered, respectively. 
 

Page 31 GAO-13-145 Conditional Pesticide Registration

registration for reasons that were outside of those permissible 

circumstances outlined in FIFRA, such as the need for labeling 

changes and potential data requirements that could be imposed in the 

future as a result of the registration review process. Of these three 

industry stakeholders, two were aware of EPA’s recent efforts to 

ensure that conditional registrations are granted only in appropriate 

circumstances, as described on the agency’s website, and these 

stakeholders were supportive of these efforts.

In keeping with these concerns, respondents from environmental, 

industry, producer, and state government groups generally offered 

suggestions for improving EPA’s conditional registration process.

Following are examples:

• Of the 16 respondents representing environmental, industry, and state 

government groups, 7 generally stated that EPA needs a better 

system for tracking the status of conditional registrations, including its 

review of required data.

• Of the 10 respondents representing industry and state government 

groups, 6 stated that it would be helpful if EPA developed a way to 

share information about conditional registrations with external 

stakeholders. For example, a respondent from a state government 

group suggested that EPA create a notification and tracking system 

for states that specifically lists the status of conditional registrations 

and any pending data requirements. The stakeholder stated that this 

system would facilitate the exchange of information between EPA and 

the states. Also, a respondent representing an industry group stated 

that EPA should develop a system similar to one used by California’s 

Department of Pesticide Regulation; the respondent stated that this 

system allows registrants to access information on the status of their 

pesticide registration applications pending before that state and about 

their conditionally registered products.

• Of the 5 industry respondents, 2 suggested that EPA address 

concerns about overuse of conditional registrations by taking steps to 

ensure that these registrations only are used according to the explicit 

criteria set forth in FIFRA section 3(c)(7).
 

Page 32 GAO-13-145 Conditional Pesticide Registration

Of the 17 respondents representing consumer, industry, legal, producer, 

and state government groups, 14 stated that there were significant 

benefits in conditionally registering pesticides. They generally noted that 

the conditional registration process is an important and effective 

mechanism that gives EPA the flexibility to allow pesticides to move to the 

market more quickly, and that quicker movement to the market, in turn, 

provides users and growers with faster access to the pesticides they 

need. For example, one respondent commented that conditional 

registrations are especially valuable in situations where users have a 

much more limited choice of pesticides that meet their needs, such as 

growers of specialty crops.42

In contrast, 13 of the 18 respondents representing consumer, 

environmental, legal, science, and state government groups stated that 

there were numerous negative impacts caused by conditionally 

registering pesticides. For example, all 13 of the respondents concerned 

with negative impacts reported that conditionally registering pesticides 

can delay EPA’s ability to mitigate public health and environmental 

impacts caused by pesticides. These respondents generally stated that 

EPA is not conducting a full, rigorous review of conditionally registered 

pesticides and therefore is allowing these pesticides into the marketplace 

without complete data, such as toxicity tests and studies that demonstrate 

the pesticides’ impact on the environment. Eight of these 13 respondents 

who expressed concern with conditionally registering a new use of a 

pesticide generally noted that, without a full, rigorous review, EPA may 

miss problems caused by the new use that may not have occurred with 

the original use.

Seven of these 14 respondents also 

generally stated that conditional registrations promote innovation by 

bringing new technologies and products to the marketplace faster.

43

 

42Specialty crops include fruits and vegetables, tree nuts, dried fruits, and nursery crops 

(e.g., flowers).

Four of the 13 respondents also stated that, especially 

in the cases that involve pesticides with new active ingredients, a 

conditional registration should only be granted if a critical need for the 

pesticide can be demonstrated. Six of the 13 respondents stated that the 

risks posed by conditionally registering new active ingredients were so 

great that EPA should discontinue this type of conditional registration. In 

43EPA officials stated that EPA must have all of the data pertaining to a new use of a 

pesticide before approving the use. Thus, according to these officials, EPA fully evaluates 

the human health and environmental impacts of adding the new use.

Some Respondents 

Stated That Conditional 

Registrations Offer 

Benefits, and Others 

Stated That They Pose 

Serious Risks
 

Page 33 GAO-13-145 Conditional Pesticide Registration

elaborating on their concerns, 12 of the 18 respondents from consumer, 

environmental, legal, science, and state government groups cited 

examples of conditionally registered pesticides that, in their opinion, 

should not have been conditionally registered. The three pesticide 

products mentioned most frequently by these respondents were the 

following:

Background: According to EPA documents, in 2003, EPA conditionally 

registered the insecticide Clothianidin, which the agency had identified as 

an alternative to older, more toxic insecticides. As one of the conditions of 

the registration, EPA required the manufacturer, Bayer CropScience, to 

submit a study evaluating the effects on honeybees of prolonged 

exposure to Clothianidin. In 2007, the agency reviewed this study and 

determined that it satisfied EPA’s field study guidelines. However, in 2010 

and again in 2012, numerous entities, including consumer and 

environmental groups, petitioned EPA to discontinue use of Clothianidin, 

charging, among other things, that it posed an imminent hazard to 

honeybees. In 2010, EPA decided to reevaluate the study and ultimately 

determined that there were some deficiencies in the study but that the 

registered uses of Clothianidin met the FIFRA standard for registration.

According to Bayer CropScience, the use of Clothianidin was necessary 

to prevent crop damage from pesticide-resistant pests and the dying of 

honeybees in 2008, which environmental groups claimed was caused by 

Clothianidin, was actually a result of a variety of factors, including 

incorrect application of the pesticide.

Stakeholder comments: Half (9 of 18) of the respondents representing 

consumer, environmental, legal, science, and state government groups 

raised concerns about the insecticide Clothianidin. For example, of the 9 

respondents who raised concerns, 6 generally reported that EPA should 

not have conditionally registered this pesticide in 2003 without all the data 

needed to establish that the pesticide would not significantly increase 

unreasonable adverse effects to pollinators, including honeybees. Two of 

these 6 respondents reported that the failure to do so has allowed the 

widespread use of a pesticide that, in their view, has caused the death of 

honeybee colonies and irreparably damaged the environment and 

livelihoods of beekeepers. Four of the 6 respondents said that it is 

irresponsible for EPA to refuse to discontinue the registration of this 

Clothianidin
 

Page 34 GAO-13-145 Conditional Pesticide Registration

product when the agency eventually determined that the pollinator study 

submitted by the company was inadequate.44

Background: According to EPA documents, in August 2010, EPA 

conditionally registered the active ingredient of the pesticide Imprelis. This 

pesticide, manufactured by DuPont, was a low-toxicity herbicide used to 

control weeds, vines, and grasses on nonfood use sites, such as weeds 

around an office building. EPA stated that the studies originally submitted 

for Imprelis were adequate to make a finding for the registration but also 

concluded that two additional studies (on toxicity and reproduction) were 

required to confirm the conclusions from existing data. However, in the 

summer of 2011, EPA received reports from several states that this 

pesticide may have caused injury to certain species of evergreen trees, 

particularly Norway spruce and white pine. In a June 2011 letter, DuPont 

cautioned professional applicators not to use Imperils near certain 

species of trees, including Norway spruce and white pine. On August 4, 

2011, DuPont voluntarily suspended sales of Imprelis and, on August 11, 

2011, EPA issued a stop-sale order directing DuPont to immediately halt 

the sale, use, or distribution of Imprelis. According to EPA, it issued this 

stop-sale order because it had reason to believe the product was 

misbranded and the agency had obtained new information, not available 

during the registration process, that showed Imprelis was toxic to certain 

trees. Currently, EPA is evaluating the tree damage to determine what 

caused the injuries. DuPont has since started a return and refund 

program for Imprelis users.

Stakeholder comments: Of the 7 respondents representing environmental 

and science groups, 4 raised concerns about the pesticide Imprelis.

According to 3 of these 4 stakeholders, EPA did not properly consider the 

“unreasonable effects on the environment” of this pesticide, specifically 

effects on organisms that this pesticide was not intended kill, including 

trees. One stakeholder reported that the experience with this pesticide 

illustrates what can happen when EPA allows a pesticide product to 

proceed to the marketplace without complete information and, in this 

 

44As of January 2013, EPA officials noted that the agency is considering a request for 

suspension of this product. EPA denied a previous request to suspend this product.

According to these officials, the current suspension request is based on a dispute related 

to the science underlying the registration, not the fact that the registration is conditional 

per se. EPA officials also noted that because EPA is involved in active litigation on 

Clothianidin, they are unable to respond to these stakeholder comments.

Imprelis
 

Page 35 GAO-13-145 Conditional Pesticide Registration

stakeholder’s opinion, confirms that the conditional registration process 

actually allows EPA to bypass statutory safeguards and rush pesticides 

with unknown and unevaluated risks to market.45

Background: According to EPA documents, in December 2011, EPA 

issued a conditional registration for a pesticide product containing 

nanosilver as a new active ingredient. As we reported in May 2010, 

nanosilver is one of a number of nanomaterials, which are materials that 

occur at the scale of nanometers—the equivalent of one-billionth of a 

meter, increasingly being used in commercial and industrial products.46

The antimicrobial pesticide product, HeiQ AGS-20, is a silver-based 

nanomaterial for use as a preservative for textiles. As a condition of 

registration, EPA is requiring the registrant, HeiQ Materials AG, to submit 

a number of studies to confirm the agency’s assessment that the product 

will not cause unreasonable adverse effects on the environment. These 

studies include toxicity studies for occupational, residential, and 

environmental exposure scenarios.47

 

45EPA officials noted that the additional data it required for the conditional registration of 

Imprelis were related to human health, specifically dietary/food exposure. According to 

these officials, EPA received required studies from the company related to nontarget 

plants. EPA reviewed these studies, found no concerns, and the product was conditionally 

approved. However, after the product was marketed, it became apparent that it was killing 

trees. According to EPA officials, based on the studies the company submitted, there was 

no reason to suspect that the product would impact trees. However, a study specifically for 

effects on trees was neither required by EPA nor submitted by the company. EPA officials 

stated that the tree deaths were very unfortunate and made the product unacceptable and 

that if EPA had known about the impacts on trees at the time the product was being 

considered for registration, the agency might not have registered the product at all. EPA 

officials stated that this was not a case where the agency failed to anticipate risks, rather, 

it was a risk that the standard data requirements did not capture and a risk that only came 

to light after the product was registered and marketed.

The data must be submitted within 4 

years (i.e., by December 2015) to avoid cancellation of the conditional 

registration. The registrant agreed with the agency’s decision to grant a 

conditional registration. The registrant stated that this registration was 

46GAO, Nanotechnology: Nanomaterials Are Widely Used in Commerce, but EPA Faces

Challenges in Regulating Risk, GAO-10-549 (Washington, D.C.: May 25, 2010).

47EPA has previously addressed toxicity concerns regarding nanosilver. In 2010, EPA 

issued its State of the Science Literature Review: Everything Nanosilver and More in 

which EPA reported that there is clear evidence that nanosilver is toxic to aquatic and 

terrestrial organisms and may be detrimental to human health. In this report, EPA noted 

that several studies have shown that nanosilver can be released into the wastewater 

stream during washing, such as from socks containing nanosilver. The nanosilver 

released may disrupt the helpful bacteria used in wastewater treatment processes or be 

released into the environment.

Nanosilver 
 

Page 36 GAO-13-145 Conditional Pesticide Registration

appropriate because (1) the company had insufficient time to generate 

certain required data, (2) use of the pesticide is in the public interest, and 

(3) use of the pesticide during the period needed to generate and review 

the required data will not cause unreasonable adverse effects. The 

registration of this product is being challenged in a lawsuit by the Natural 

Resources Defense Council.48

Stakeholder comments: Eight of the 18 respondents representing 

consumer, environmental, legal, science, and state government groups 

raised concerns about the conditional registration of the nanosilver 

product HeiQ AGS-20. Among other things, these respondents stated that 

there was a significant lack of data needed to fully evaluate the safety of 

this product, including a lack of data on potential human health effects.

One stakeholder pointed out that silver is highly toxic to both humans and 

the environment and, when used at the nanoscale level, the science is 

still developing on how such nanoparticles behave. Another stakeholder 

said this conditional registration is particularly troubling because EPA’s 

Office of the Inspector General recently concluded that the EPA lacks an 

effective program to collect information and monitor the possible health 

risks posed by nanomaterials,49 and because the National Research 

Council similarly found that the federal government needs an improved 

plan and additional funding to assess the environmental and health risks 

posed by nanomaterials.50

OPP faces a formidable task in managing the registrations of more than 

16,000 pesticide products. This includes periodically reconsidering 

whether older registrations continue to meet the regulatory standard and 

 

48EPA officials said that the basis of the Natural Resources Defense Council lawsuit is not 

a challenge of EPA’s use of conditional registrations under FIFRA section 3(c)(7) or 

whether EPA met the standards for granting a conditional registration under this statute.

Rather, according to these officials, the lawsuit questions an aspect of the risk 

assessment methodology that EPA used in this case to make the determination of no 

unreasonable adverse effects.

49EPA Office of the Inspector General, EPA Needs to Manage Nanomaterial Risks More 

Effectively, Report no. 12-P-0162, Dec. 29, 2011. OPP officials noted that the Office of the 

Inspector General advised EPA to develop a better internal process for sharing data 

across program offices. According to these officials, EPA has implemented this 

recommendation, and an Inspector General official concurred.

50National Research Council of the National Academies, A Research Strategy for 

Environmental, Health, and Safety Aspects of Engineered Nanomaterials, the National 

Academies Press (Washington, D.C.: 2012).

Conclusions 
 

Page 37 GAO-13-145 Conditional Pesticide Registration

reviewing applications submitted each year for new or amended 

registrations. The pesticide products that the agency registers play a 

critical role in food production by helping to minimize crop losses due to 

pests and weeds. In addition, pesticide products have helped improve 

public health by controlling disease-carrying pests, such as insects and 

rodents. At the same time, consumers rely on OPP to ensure that 

registered pesticide products do not cause unreasonable adverse effects 

on the environment or human health when used according to the label 

instructions approved by the agency.

OPP faces challenges in tracking key information specifically related to 

conditional registrations, and, as a result, is unable to produce accurate

information on the current number of these registrations. OPP’s lack of a 

reliable and comprehensive means of routinely collecting and tracking 

information on conditional registrations, including the status of registrants’ 

submission of required data and OPP’s review of these data, leaves it 

without an important management tool. Because OPP is not 

systematically tracking whether registrants of conditionally registered 

pesticides submitted additional required data, and whether OPP reviewed 

these data, it may not be able to identify situations in which the additional 

data would suggest the need to alter a registration. Furthermore, without 

the ability to systematically track conditional registrations, OPP is not 

well-positioned to produce summary data to enable it to easily identify 

situations for priority follow-up; enforce FIFRA and its implementing 

regulations; and report to Congress and others on program status.

Furthermore, OPP’s use of conditional registrations for actions other than 

those that meet the criteria outlined in FIFRA Section 3(c)(7) has created 

confusion for its staff, and may leave OPP vulnerable to charges by 

environmental, industry, and other stakeholders who assert that it 

inappropriately grants conditional registrations. According to OPP officials 

and documents, weaknesses in guidance and training, management 

oversight, and data management contributed to the misclassification of 

other pesticide-related activities as conditional registrations. OPP has 

raised the visibility of these issues by holding meetings at least quarterly 

with representatives of the OPP divisions that issue pesticide registrations 

to discuss any conditional registrations being considered for new active 

ingredients to ensure they meet the statutory criteria outlined in FIFRA 

Section 3(c)(7) and that the additional information requested is indeed 

needed to unconditionally register the pesticide. In addition, OPP has 

taken or plans to take other actions to ensure that staff appropriately 

grant conditional registrations and registrants submit required data; 

however, these are short-term solutions that do not fully address the 
 

Page 38 GAO-13-145 Conditional Pesticide Registration

problems identified. As OPP officials and stakeholders recognize, OPP 

needs a comprehensive automated data system to track conditional 

registrations from the time the conditional registration is granted until 

additional data requested is received and reviewed. However, OPP 

previously stated over 25 years ago that it planned to develop an 

automated system for tracking conditional registrations of new active 

ingredients, but it did not follow through with this plan. OPP has secured 

funding through FIFRA amendments to begin the development of such a 

system, but much work remains to be done and will depend on a further 

commitment of needed resources.

Moreover, OPP lacks written guidance or a consistent methodology for 

how product managers are to maintain their pesticide registration files.

Allowing product managers to use disparate methods to collect and keep 

information on the pesticides they are responsible for makes it more 

difficult to develop summary information about the status of pesticide 

registrations overall, which could be useful information for managing the 

pesticide registration program. Also, as the extensive amount of time and 

effort needed in OPP’s ongoing review of all registered pesticides 

demonstrates, product managers’ current methods are not sufficient to 

efficiently track this information. It will take time and money to develop an 

automated system for tracking the progress of conditionally registered 

pesticides but, in the interim, OPP is further hampered in its efforts to be 

informed about the status of conditional registrations because product 

managers do not use a consistent system for tracking their status, 

including when data are submitted by registrants and reviewed by OPP.

Furthermore, OPP’s reliance on the institutional knowledge of its product 

managers and the records they keep is problematic for other reasons, 

including the loss of knowledge and experience of these employees as 

they retire or are replaced by new employees.

Finally, OPP has also not clearly and concisely communicated the results 

of its analyses of conditional registrations on its website. It is important for 

agencies to ensure that information placed on their websites is accurate 

and free of discrepancies. OPP officials have acknowledged the need to 

correct the agency’s website on conditional registrations and remove any 

confusing or inaccurate statements.

To improve EPA’s management of the conditional registration process, 

we recommend that the Administrator of EPA direct the Director of the 

Office of Pesticide Programs to take the following three actions:

Recommendations for 

Executive Action
 

Page 39 GAO-13-145 Conditional Pesticide Registration

• Complete plans to automate data related to conditional registrations to 

more readily track the status of these registrations and related 

registrant and agency actions and identify potential problems requiring 

management attention,

• Pending development of an automated data system for tracking the 

status of conditional registrations, develop guidance to ensure that 

product managers use a uniform methodology to track and document 

this information, including when data are submitted by registrants and 

reviewed by EPA, in the files maintained by each pesticide product 

manager.

• Review and correct, as appropriate, OPP’s website on conditional 

registrations to ensure that the information presented is clear, 

concise, and accurate, including defining technical terms.

We provided a draft of this report to EPA for review and comment. In 

written comments, which are included in appendix II, EPA agreed with the 

report’s recommendations. Regarding the first recommendation, EPA said 

that its implementation plan to automate data related to conditional 

registrations includes (1) development of new codes for identifying 

conditional registration decisions in OPPIN; (2) training its staff on use of 

the new categories represented by these new codes, and making the 

training available online for guidance; and (3) changes to its databases to 

allow staff to check more easily whether there are any outstanding 

requests for data on any pesticide active ingredients. EPA also said it 

plans to develop a more comprehensive system for tracking conditional 

registrations; however, the agency’s ability to do so depends on the 

availability of funding and the complexity of incorporating changes in the 

databases. Regarding the second recommendation, EPA said it is

developing a standard operating procedure for staff to follow when 

entering data into the computerized tracking system about the statutory 

basis for registration decisions. According to EPA, this procedure, 

together with the new training for staff, should ensure that conditional 

registration decisions are properly identified in the OPPIN database going 

forward. The agency said it expects to complete the procedure by the end 

of calendar year 2013. EPA added that the status of products previously 

approved under conditional registration authority is also being reviewed 

and updated, as necessary. For the third recommendation, EPA said by 

the end of 2013 it will revise its website on conditional registration to both 

clarify and update the information presented. In addition, EPA indicated 

the website will include an outline of ongoing agency work to strengthen 

Agency Comments 

and Our Evaluation
 

Page 40 GAO-13-145 Conditional Pesticide Registration

its conditional pesticide registration program. EPA also provided technical 

comments, which we incorporated as appropriate.

As agreed with your office, unless you publicly announce the contents of 

this report earlier, we will plan no further distribution until 30 days from the 

report date. At that time, we will send copies of this report to the 

Administrator of EPA, the appropriate congressional committees, and 

other interested parties. In addition, the report will be available at no 

charge on the GAO website at http://www.gao.gov. 

If you or your staff members have any questions about this report, please 

contact me at (202) 512-3841 or gomezj@gao.gov. Contact points for our 

Offices of Congressional Relations and Public Affairs may be found on 

the last page of this report. GAO staff who made key contributions to this 

report are listed in appendix III. 

Sincerely yours,

J. Alfredo Gómez

Director, Natural Resources and Environment
Appendix I: Objectives, Scope and 

Methodology

Page 41 GAO-13-145 Conditional Pesticide Registration

Our objectives were to examine the (1) number of conditional pesticide 

registrations the Environmental Protection Agency (EPA) has granted and 

the basis for granting these registrations; (2) extent to which EPA ensures 

that registrants submit the additional data EPA required as part of 

conditional registrations and reviews these data; and (3) views of relevant 

stakeholders on EPA’s use of conditional registrations, including ways, if 

any, to improve the conditional registration process. To address these 

objectives, we reviewed relevant federal statutes and regulations,1 EPA 

program and guidance documents,2 federal internal control standards,3

and previous GAO and EPA Inspector General reports.4

 

1

These statutes and regulations include Federal Insecticide, Fungicide, and Rodenticide 

Act, Act of June 25, 1947, ch. 125, 61 Stat. 163 (codified as amended at 7 U.S.C. §§ 136-

136y); Federal Food, Drug, and Cosmetic Act, 21 U.S.C. §§ 301-399f; Food Quality 

Protection Act of 1996, Pub. L. No. 104-170 110 Stat. 1489; Pesticide Registration 

Improvement Act of 2003, Pub. L. No. 108-199 Div. G. Tit. V. § 501. 118 Stat. 419 (2004); 

and relevant parts from title 20 of the Code of Federal Regulations. 

We also 

reviewed EPA’s fiscal year 2011–2015 strategic plan; EPA’s fiscal year 

2011 and 2012 annual performance plans; EPA’s budget justification 

documents for fiscal years 2012 and 2013; Office of Pesticide Programs’ 

(OPP) pesticide registration work plans for fiscal years 2001 through 

2012; OPP notices of pesticide registration for conditionally registered 

pesticides; and Federal Register notices related to OPP’s registration 

decisions. In addition, we interviewed OPP officials and reviewed 

documentation they provided to obtain further information and clarification 

2

These program and guidance documents included EPA, Conditional Registrations – 

Summary and Analysis, Office of Pesticide Program Internal Review, Spring 2011; 

Pesticide Programs: Conditional Registration of New Pesticides, F.R. Vol. 51, No. 43, p.p. 

7628-7634; and EPA Biological and Economic Analysis Division (BEAD), Guidance for 

BEAD Review: Public Interest Findings for Conditional Registration.

3

GAO, Internal Control Management and Evaluation Tool, GAO-01-1008G (Washington, 

D.C.: August 2001); GAO/AIMD-00-21.3.1; Office of Management and Budget, 

Management’s Responsibility for Internal Control, OMB Circular No. A-123, Dec. 21, 2004; 

Office of Management and Budget, Managing Government Records Directive, M-12-18, 

Aug. 24, 2012.

4

Previous GAO reports reviewed are listed in “Related GAO Products” at the end of this 

report. Previous EPA Inspector General reports include: EPA Office of Inspector General, 

EPA Needs to Manage Nanomaterial Risks More Effectively, Report no. 12-P-0162, Dec. 

29, 2011; EPA Office of Inspector General, EPA Needs to Comply with the Federal 

Insecticide, Fungicide, and Rodenticide Act and Improve Its Oversight of Exported NeverRegistered Pesticides, Report no. 10-P-0026, Nov. 10, 2009; EPA Office of Inspector 

General, Office of Inspector General Semiannual Report to the Congress, Report no. 

EPA-350-K-00-002, November 2000; EPA Office of Inspector General, EPA’s Pesticide 

Program, Report no. E1EPE2-05-0015-4100205, Mar. 11, 1994. 

Appendix I: Objectives, Scope and 

Methodology 
Appendix I: Objectives, Scope and 

Methodology

Page 42 GAO-13-145 Conditional Pesticide Registration

on EPA’s conditional registration process, including any planned 

responses to internal review or external stakeholder concerns.

Furthermore, we reviewed recent literature related to pesticide 

registration, including information and documents found on the websites 

of a variety of consumer, environmental, industry, legal, producer, 

science, and state government organizations.

To examine the number of conditional pesticide registrations EPA has 

granted and the basis for them, we requested that OPP provide us with 

summary data on (1) the number of pesticide registrations currently in 

conditional status and how long they have been in this status; (2) the total 

number of current pesticide registrations (conditional and unconditional); 

and (3) for fiscal years 1997 through 2011, the number of conditional 

registrations granted for each year and the basis on which these were 

granted. We asked for information for 1997 through 2011 because 

reviewing registrations from this period could address the concerns that 

environmental and other groups raised that some pesticides may have 

been in conditional status for many years and also take into account key 

changes made to the pesticide registration and tolerance setting 

processes that occurred after 1996.5

To address the second objective—the extent to which EPA ensures that 

registrants submit the additional data required as part of conditional 

We intended to assess the reliability 

of the data that we requested from EPA and conduct electronic testing on 

data fields necessary for our analysis; however, after interviewing OPP 

officials and reviewing past GAO, Inspector General, and EPA contractor 

studies examining OPP’s data management, especially its use of the

Office of Pesticide Programs Information Network (OPPIN), we concluded 

that EPA could not provide us with sufficiently reliable data for obtaining 

summary level information on conditional pesticide registrations. In the 

absence of these data, we discussed with OPP officials the capabilities 

and limitations of OPPIN and any potential work-arounds they employ or 

are planning for. In addition, we reviewed and discussed with these 

officials a recent analysis of OPPIN data that OPP conducted to 

determine how many of the conditional registrations granted were outside 

of the permissible circumstances outlined in the Federal Insecticide, 

Fungicide, and Rodenticide Act (FIFRA). The results of this analysis were 

included in an OPP internal review report and posted on OPP’s website.

 

5

These key changes followed implementation of the Food Quality Protection Act of 1996.
Appendix I: Objectives, Scope and 

Methodology

Page 43 GAO-13-145 Conditional Pesticide Registration

registrations and reviews these data—we interviewed OPP officials about 

how they manage conditional registration data requirements. We also 

asked OPP to provide information on the number of pesticides that (1) 

have a conditional registration, but the registrant has not submitted the 

additional required data by the specified due date; (2) have a conditional 

registration and the registrant has submitted the additional required data, 

but EPA has not reviewed these data; (3) still have a conditional 

registration, even though the registrant has submitted, and EPA has 

reviewed, the additional required data; and (4) had been changed from

conditional to unconditional status. However, OPP officials said they 

could not provide these data because they do not have an automated 

data system that tracks this information, but that they did analyze a 

subset of 544 conditional registrations to try to determine whether 

registrants had submitted the required data and posted the results of this 

analysis on OPP’s website.

To obtain the views of relevant stakeholders on EPA’s conditional 

registration process and ways, if any to improve it, we administered a 

questionnaire to 35 professionals in the consumer, environmental, 

industry, legal, producer, science, and state government fields. We used 

a multistage process to identify our final nonprobability sample of 35 

potential respondents.6

 

6

Because this was a nonprobability sample, the information collected in response to the 

questionnaire about EPA’s use of conditional registrations cannot be generalized to all 

consumer, environmental, industry, legal, producer, science, and state government 

stakeholders but provides illustrative information on the views of such stakeholders by 

category.

This process included (1) conducting a literature 

search to identify groups or individuals who had recently published 

articles on registration (including conditional registration) of pesticides, (2) 

asking agency and other relevant officials for recommendations of 

knowledgeable parties in each of these areas, and (3) asking prospective 

stakeholders for suggestions of other potential stakeholders. Through 

these methods, we arrived at an initial list of 148 potential stakeholders 

that were divided, based on their institutional affiliation, into the seven 

categories listed above. We then narrowed this list by (1) performing 

online searches of the professional affiliations of each stakeholder to 

determine whether they would likely have sufficient knowledge about 

EPA’s conditional registration of pesticides and (2) conducting screening 

interviews, by phone and e-mail, to determine whether the individuals 

were sufficiently familiar with EPA’s process for registering pesticides and 
Appendix I: Objectives, Scope and 

Methodology

Page 44 GAO-13-145 Conditional Pesticide Registration

to secure their commitment to participate in our survey. After this process 

was completed, we arrived at a list of 35 stakeholders to whom we sent, 

via e-mail, our questionnaire.

The questionnaire asked about, among other things, (1) problems, if any, 

associated with each of the permissible situations for which registrations 

can be conditionally granted; (2) risks, if any, associated with registrants 

not submitting data required by a conditional registration in a timely 

manner; (3) pesticides with conditional registrations that stakeholders 

believe should not have been conditionally registered; and (4) 

suggestions for improving EPA’s conditional registration process. In 

preparing to administer this questionnaire, we conducted three pretests to 

ensure that the questions were clear, terminology was used appropriately, 

and the questionnaire was unbiased. We used the results of our pretests 

to revise the questions as needed. The questions were open-ended, and 

thus issues raised by stakeholders had to be “volunteered.” We did not 

ask each stakeholder to agree or disagree with particular issues.

The administration period for this questionnaire was from July through 

September 2012. Of the 35 participating stakeholders, 24 provided 

complete, valid questionnaire responses.7

 

7

Seven stakeholders did not respond to our request to complete the questionnaire.

Although three stakeholders provided complete responses, we did not consider them valid 

because they responded as individuals instead of as representatives of their respective 

organizations. Another stakeholder declined to fill out the questionnaire.

The organizations that 

participated as stakeholders were Akin Gump, LLP; American Chemistry 

Council; American Farm Bureau Federation; Beyond Pesticides; 

California Department of Pesticide Regulation; Center for Biological 

Diversity; Center for Environmental Health; Center for Food Safety; 

Center for Science in the Public Interest; Council of Producers and 

Distributors of Agrotechnology; CropLife America; Dow Agrosciences, 

LLC; Earthjustice; Environmental Working Group; Food and Water Watch; 

Florida Department of Agriculture and Consumer Services; Iowa 

Department of Agriculture; McDermott, Will and Emery, LLP; Natural 

Resources Defense Council; New York State Department of 

Environmental Conservation; Pesticide Action Network North America; 

Syngenta Crop Protection, LLC; Texas Department of Agriculture; and 

The Endocrine Disruption Exchange. The results of this questionnaire 

cannot be generalized to all parties knowledgeable about the conditional 

registration of pesticides; rather our analysis of the results of this 
Appendix I: Objectives, Scope and 

Methodology

Page 45 GAO-13-145 Conditional Pesticide Registration

questionnaire identifies common themes present in the responses of 

those who participated in our questionnaire.

We analyzed stakeholder responses to the questionnaire to identify 

themes and develop summary findings. Two GAO analysts separately 

conducted this analysis and placed users’ responses into one or more 

categories, then compared these analyses. All initial disagreements 

regarding the categorizations of stakeholders’ responses were discussed 

and reconciled. The analysts then tallied the number of responses in each 

category.

We conducted this performance audit from September 2011 to August 

2013 in accordance with generally accepted government auditing 

standards. Those standards require that we plan and perform the audit to 

obtain sufficient, appropriate evidence to provide a reasonable basis for 

our findings and conclusions based on our audit objectives. We believe 

that the evidence obtained provides a reasonable basis for our findings 

and conclusions based on our audit objectives.
Appendix II: Comments from the 

Environmental Protection Agency

Page 46 GAO-13-145 Conditional Pesticide Registration

Appendix II: Comments from the 

Environmental Protection Agency
Appendix II: Comments from the 

Environmental Protection Agency

Page 47 GAO-13-145 Conditional Pesticide Registration
Appendix II: Comments from the 

Environmental Protection Agency

Page 48 GAO-13-145 Conditional Pesticide Registration
Appendix II: Comments from the 

Environmental Protection Agency

Page 49 GAO-13-145 Conditional Pesticide Registration
Appendix III: GAO Contact and Staff 

Acknowledgments

Page 50 GAO-13-145 Conditional Pesticide Registration

J. Alfredo Gómez, (202) 512-3841 or gomezj@gao.gov

In addition to the individual named above, James R. Jones, Jr., Assistant 

Director; Jameal Addison; Kevin Bray; Kirsten B. Lauber; Robin Marion; 

Lisa Shames; Carol Herrnstadt Shulman; Kathryn Smith; and Lisa Turner

made key contributions to this report. Colleen M. Candrl, Joyce Evans, 

Dan Royer, and Kiki Theodoropoulos also made important contributions 

to this report.

Appendix III: GAO Contact and Staff 

Acknowledgments 

GAO Contact

Staff 

Acknowledgments 
Related GAO Products

Page 51 GAO-13-145 Conditional Pesticide Registration

Nanotechnology: Improved Performance Information Needed for 

Environmental, Health, and Safety Research. GAO-12-427. Washington, 

D.C.: May 21, 2012.

Agricultural Chemicals: USDA Could Enhance Pesticide and Fertilizer 

Usage Data, Improve Outreach, and Better Leverage Resources. 

GAO-11-37. Washington, D.C.: November 4, 2010.

Pesticides on Tobacco: Federal Activities to Assess Risks and Monitor 

Residues. GAO-03-485. Washington, D.C.: March 26, 2003.

Agricultural Pesticides: Management Improvements Needed to Further 

Promote Integrated Pest Management. GAO-01-815. Washington, D.C.: 

August 17, 2001.

Children and Pesticides: New Approach to Considering Risk is Partly in 

Place. GAO/HEHS-00-175. Washington, D.C.: September 11, 2000.

Pesticides: Improvements Needed to Ensure the Safety of Farmworkers 

and Their Children. GAO/RCED-00-40. Washington, D.C.: March 14, 

2000.

GAO Products Related to Pesticide Regulation. GAO/RCED-95-272R. 

Washington, D.C.: September 26, 1995.

Pesticides: Information Systems Improvements Essential for EPA’s 

Reregistration Efforts. GAO/IMTEC-93-5. Washington, D.C.: November 

23, 1992.

Pesticides: EPA’s Information Systems Provide Inadequate Support for 

Reregistration. GAO/T-IMTEC-92-3. Washington, D.C.: October 30, 1991.

Pesticides: EPA’s Formidable Task to Assess and Regulate Their Risks. 

GAO/RCED-86-125. Washington, D.C.: April 18, 1986.

Natural Resources and Environment: Delays and Unresolved Issues 

Plague New Pesticide Protection Programs. GAO/CED-80-32. 

Washington, D.C.: February 15, 1980.

Related GAO Products

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