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B-198288 1 (1980-03-31)

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COMPTROLLER GENERAL OF THE UNITED STATES
          WASHINGTON. D.C. 20548


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The Honorable William C. Wampler
Ranking Minority Member
Committee on Agriculture
House of Representatives


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Dear Mr. Wampler:

     This is to confirm the agreements reached at a March 24, 1980,
meeting attended by you, Thomas Adams and John Hogan of the House
Agriculture Committee staff, and representatives of our Community
and Economic Development Division. The meeting was held to discuss
your March 11, 1980, letter requesting that we review the appro-
priateness of the procedures followed by the Environmental Protection
Agency (EPA) in suspending most uses of the pesticides 2, 4, 5-T and
silvex and initiating cancellation procedures on all uses of these
pesticides. At the meeting, we agreed to immediately start review-
ing the three areas discussed on page 2 of your March 11, 1980,
letter. Briefly they are:

     1. Identify and evaluate methods and procedures
         established by EPA to properly evaluate
         scientific evidence relied on by EPA to suspend
         and initiate cancellation procedures on a
         pesticide.

     2. Determine whether EPA followed these established
         methods and procedures in the case of 2, 4, 5-T
         and silvex.

     3. Identify prior GAD or National Academy of Sciences
         recommendations on pesticide regulatory issues
         which, if implemented by EPA, might have avoided
         questions of the appropriateness of EPA's
         emergency suspension and cancellation actions
         on 2, 4, 5-T and silvex.

     In performing our review, we also agreed to carefully consider
whether the Congress needs to amend the Federal Insecticide, Fungi-
cide, and Rodenticide Act (FIFRA) (7 U.S.C. 136 et seq.), as
amended to assure that EPA uses fair and equitablTe procedures when
deciding whether to suspend or cancel a pesticide. Finally, we


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B-198288


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