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RCED-94-171R 1 (1994-07-15)

handle is hein.gao/gaobackpp0001 and id is 1 raw text is: 




             United States
GAO          Gener Accounting Office
             Wington, D.C. 20548

             Resources, Community, and
             Economic Development Division
             B-256727


             July 15, 1994


             Dr. Lynn R. Goldman
             Assistant Administrator, Office of
               Prevention, Pesticides and Toxic
               Substances
             Environmental Protection Agency


             Dear Dr. Goldman:


             At the request of Senator John Glenn, we recently reviewed
             the process leading to EPA's February 1992 decision to
             retain 45 crop uses for a group of fungicides known as
             EBDCs (ethylene bisdithiocarbamates), while canceling 11
             uses. Although we found no significant weaknesses in the
             decision process, we did find weaknesses in EPA's
             determination of average residue estimates for EBDCs and
             ethylenethiourea (ETU), the metabolite product common to
             all EBDCs.

             During our review, we observed that EPA made numerous
             calculations in determining residue values and risk
             factors. Because many of the computations were computed
             manually and were not independently verified, we checked
             the calculations for some of the residue estimates. Using
             EPA's criteria and formula for determining average
             residues, we tested the agency's computation of the mean
             residue estimates for 17 foods and/or food forms (raw,
             frozen, paste, puree, etc.). We found 15 discrepancies in
             34 EBDC and ETU residue estimates. These discrepancies,
             which were discussed with EPA staff, appeared to be fairly
             minor--in that they generally involved decimal numbers that
             were off by one or more digits at the fourth decimal place.

             For example, we calculated a mean ETU residue estimate of
             0.0013 parts per million (ppm) for frozen broccoli, while
             EPA used 0.0021 ppm; and we calculated a mean of 0.0074 ppm
             for tomato paste, while EPA used 0.0073 ppm. Eight
             discrepancies were due to using an incorrect figure (for
             the percentage of the crop treated, for instance), four


GAO/RCED-94-171R, EBDC Residue Estimates

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