Pesticides Regulation: Current Issues

PESTICIDES REGULATION: CURRENT I S S U E S ISSUE BRIEF NUMBER IB83095 UPDATED 05/14/84 AUTHOR: James V. Aidala Environment and Natural R e s o u r c e s Policy Division T H E . L I B R A R Y OF CONGBESS CONGRESSIONAL RESEARCH SERVICE MAJOR ISSUES SYSTEM D A T E ORIGINATED 06/01/83 FOR ADDITIONAL INFORMATION CALL 287-5700 0514 CRS- i ISSUE DEFINITION Ever since the Federal Insecticide, F u n g i c i d e , and Rodenticide Act Was completely rewritten i n 1 9 7 2 (P.L. 92-516), controversies about its implementation h a v e required frequent a n d continuing congressional a t t e n t i o n . T o ensure c l o s e oversight and a sense of accountability, Congress has been reluctant to authorize the Act for more than o n e or two y e a r s , and i t has (P.L. 94-140) enacted significant "mid-course corrections" twice -- i n 1 9 7 5 and 1976 (P.L. 95-396). T h e 9 7 t h Congress again considered reauthorizations (which expired a t the ene of FY8l), a l o n g With a series of further a m e n d m e n t s correcting problems i n the basic Act. T h e three a r e a s of most concern were (1) the handling of data for registration of pesticides; (2) public a c c e s s t o States could health and environmental d a t a ; and ( 3 ) t h e extent to which require a d e i t i o n a l data for registrations. S i n c e the 9 7 t h Congress f a i l e d to e n a c t the r e a u t h o r i z a t i o n , t h e 98th Congress had to a d d r e s s these and o t h e r issues. H o w e v e r , only a s i n g l e one-year reauthorization was passed during the first s e s s i o n , and Congress must again reconsider if major statutory amendments a r e warranted. BACKGROUND AND POLICY ANALYSIS Pesticides a r e chemicals used to control many k i n d s o f pests: insects that attack c r o p s , destroy m a t e r i a l s , and s e r v e a s disease vectors; weeds; f u n g i and other disease-causing o r g a n i s m s ; n e m a t o d e s ; and others. They have become major components of agricultural production and of health protection. Against their b e n e f i t s , certain hazards must be weighed. P e s t i c i d e s may be highly t o x i c , some a r e persistent in the e n v i r o n m e n t , and many pose r i s k s to nontarget organisms. During World War 1 1 , s y n t h e t i c organic pesticides were developed for u s e in the War effort. After the W a r , the pesticide industry expanded rapidly. In 1 9 4 7 , C o n g r e s s enacted t h e Federal Insecticide, F u n g i c i d e , and R o d e n t i c i d e Act (FIFRA) to protect f a r m e r s from ineffective and d a n g e r o u s pesticides. It accomplished this through registration of labels that were required o n a l l pesticides. T h e regulatory authority to control pesticides u s e comes through the requirement that before a pesticide c a n be m a r k e t e d , i t must be granted a " r e g i s t r a t i o n " , a decision based on a determination of what u s e s a r e s a f e and any necessary use restrictions. Over the next two d e c a d e s , concern grew a b o u t hazards to health and the environment from pesticides. I n r e s p o n s e , Congress enacted the F e d e r a l These amendments, Environmental P e s t i c i d e Control Act in 1 9 7 2 (P.L. 92-516). which rewrote F I F R A , provided for direct controls on t h e u s e of pesticides, f o r classification of selected pesticides into a restricted u s e c a t e g o r y , f o r registration of manufacturing p l a n t s , and f o r a n a t i o n a l monitoring program f o r pesticide residues. It a l s o added environmental effects t o the r i s k s t o be weighed i n t h e pesticide registration process. has had difficulty From the f i r s t , the Environmental Protection Agency with its pesticiCes regulation program and with implementing the 1 9 7 2 by amendments. T h e Agency has frequently found itself b e i n 9 criticized both proponents for greater regulation of pesticide use and by those urging l e s s government interference in the pesticide field. G e n e r a l l y , t h o s e who benefit from the sale or use of pesticides charged the Agency With unreasonably CRS- 2 IB83095 UPDATE-05/14/84 restricting pesticides and thereby adversely affecting the Nation's agricultural economy. Others charged the Agency with not being r e s t r i c t i v e enough and thereby allowing human beings and the environment t o be exposed t o potentially hazardous chemicals. Issues of widespread concern have been Agency r e s o u r c e s , deadlines, data v a l i d i t y , data c o n f i d e n t i a l i t y , and hazard assessment. E P A 1 s difficulties in carrying out the provisions of FIF-RA and t h e controversies inherent in the task of balancing benefits and risks .in regulating pesticide uses have led t h e FIFRA legislati,ve committees to l i m i t T h e committees thus a r e authorizations for t h e Act to one or two years. assured of contznuing oversight and increased sensitivity of the Agency to congressional concerns. T h u s , virtually every year t h e most immediate pesticide issue is reauthorization cf FIFRA. In the reauthorization p r o c e s s , a number of other i s s u e s recur: Implementation Problems. Example: The 1 9 7 2 amendments required EPA t o reregister some 5 0 , 0 0 0 pesticide u s e s , a The workload that proved impossible in the 4 y e a r s allowed. deadline was f i r s t extended i n 1 9 7 5 , and then generic registration was established i n 1978. Additional flexibility may b e needed. Decision Formulation. Efforts to increase acceptability of EPA decisions led Congress i n 1 9 7 5 to require EPA to consult with USDA on decisions. Congress later included provisions for CongreSSiOnal vetoes of EPA regulations: amendments providing congressional vetoes were enacted i n 1980. Another proposal h a s been for establishment of a scientific forum for resolution of controversial decisions. Controversial Decisions. Examples: EPA restricted t h e use of m i r e x , a pesticide used to k i l l the imported f i r e ant. There have been unsuccessful legislative efforts to r e v e r s e this decision. A similar controversy surrounds the d o m e s t i c use of the herbicide 2 , 4 , 5 - T , which i s restricted because of possible health dangers ( 2 , 4 , 5 - T was a component of Agent Orange, used ia V i e t n a m , and a l l e g a t i o n s of health damages to veterans have a l s o led to congressional concern). 95-396) CElminated 6 y e a r s of The F e d e r a l P e s t i c i d e Act Of 1 9 7 8 (P.L. efforts to overcome implementation obstacles and other problems a r i s i n g from t h e 1 9 7 2 amendments to the Federal Insecticide, Fungicide a n d Rodenticide Act. B r i e f l y , the 1 9 7 8 Pesticide Act expedited the registration and classification processes by providing for registration on t h e basis of t h e generic chemical rather than end-product, allowing conditional r e g i s t r a t i o n , developing special limited data requirements for regiscering minor uses of pesticides, providing the developer of a pesticide with a 10-year exclusive u s e of data p e r i o d , and allowing currently approved pesticides to be classifieC f o r either general or restricted use without waiting for finalization of the re-registration process. In addition,. S t a t e s were giver. requirements primary enforcement responsibilities for the Act after meecing for adequate pesticide use l a w s , r e g u l a t i o n s , and enforcement procedures. To CRS- 3 IB83095 UPDATE-05/14/84 improve E P A ' s risk a s s e s s m e n t analysis that leads t o decisions by the A d m i n i s t r a t o r , the n e w Act required the Agency to obtain operating g u i d e l i n e s from i t s scientific adv-isory p a n e l , whose existence was extended u n t i l September 1981. C o m m e n t s , e v a l u a t i o n s , and recommendations of the panel a r e published in the Federal Register. The 1 9 7 8 Pesticide Act required the Agency, in coordination with U S D A , to conduct research i n t o integrated pest management, defined a s the balanced use of such c u l t u r a l , biological, and chemical measures a s a r e most a p p r o p r i a t e to a particular situation. EPA's monitoring activities a r e to i n c l u d e developing procedures f o r monitoring a i r , s o i l , w a t e r , m a n , p l a n t s , and a n i m a l s f o r incidental pesticide exposure and quantifying t h i s exposure a s well a s identifying i t s source and relationship to human and environmental effects. In the 96th C o n g r e s s , legislation on pesticides primarily concerned extending authorizations. Action on this legislacion a l s o gave t h e H o u s e and Senate Committees o n Agriculture t h e opportunity to o v e r s e e EFA's pesticide programs and decisions. During the 1 s t session, legislation to a u t h o r i z e FIFRA programs for F Y 8 0 died when t h e House and Senate were unable to reach conference agreement o n a congressional veto provision. In t h e second session, Congress passed H.R. 7 0 1 8 , which was signed a s P.L. 96-539 o n Dec. 1 7 , 1980. It authorized $77.5 million for F Y 8 1 a n d , r e t r o s p e c t i v e l y , $72.16 million f o r FY80. It added some procedural requirements for scientific review of decisions to suspend uses of pesticides and for peer r e v i e w of scientific studies conducted under authority of FIFRA. Also (after i n i t i a l rejection of H.R. 7 0 1 8 on the floor), i t included a c o n g r e s s i o n a l v e t o provision. LEGISLATIVE ACTIVITY -- 9 7 T H CONGRESS T h e 9 7 t h Congress could not a g r e e on a bill reauthorizing FIFRA. continues, however, under %he FY8'3 appropriations bill (P.L. 97-272). Funding Controversial issues behind the law's implementation surfaced a n d were unable to be resolved legislatively. T h e stalemate c a m e about when the House-passed bill (H.R. 5 2 0 3 ) , though reported by t h e Senate Agriculture Committee with a m e n d m e n t s , was not brought to the Senate f l o o r for a vote. T h e three major i s s u e s behind this bill were: (1) exclusive use of registration data (H.R. 5203 granted registrants "exclusive use" of their data for fifteen years) ; (2) public a c c e s s to pesticides registration health and safety data (attempts were made to require a reading room concept f o r public review of d a t a , but H.R. 5203, a s passed, only required EPA to expeditiously implement a public a c c e s s system according to existing provisions of t h e 1 9 7 8 FIFRA); a n d (3) State requirements for registration data beyond that required by the Federal s t a t u t e (attempts to restrict States' ability t o r e q u i r e additional data failed) . - CRS- 4 I383095 (For a full description of these issues and t h e 5203 in t h e ' 9 7 t h C o n g r e s s , see archived I B 7 7 0 7 4 Through t h e 97th Congress.) UPDATE-05/14/84 legislative trail of H.R. -- An Overview of Issues In the closing days of the 97th C o n g r e s s , the House Sub.committee on Department O p e r a t i o n s , R e s e a r c h , and Foreign Agriculture released a draft staff report which continued to fuel t h e controversies surrounding t h e implementation of PIFRA. The major issues examined i n the draft r e p o r t , "Regulatory P r o c e d u r e s and Public Health Issues i n the E P A t s Office of Pesticide P r o g r a m s u (Opp), were: (1) Are FIFRA registration requirements being circumvented through abuse of Emergency Exemptions and Special Local Need provisions? (2) Have EPA/OPP'S risk assessment policies -- i n c l u d i n g both the interpretation of c h r o n i c health test d a t a and allowable levels of estimated risk -- changed significantly s i n c e 1 9 8 0 , while avoiding procedures for peer review and public comment? (3) Are OPP's current decisions regarding a l l o w a b l e especially i n light of pesticide resiCues possible changes in risk assessment policies -- adequately protecting human health and the environment? -- (4) Is the a m o u n t , q u a l i t y , and management of t h e d a t a base upon which pesticide decisions a r e made a d e q u a t e for OPP to make informed decisions? a n d (5) Has t h e pesticide program received adequate f i n a n c i a l resources to properly implement the requirements of FIFRA? LEGISLATIVE ACTIVITY -- 9 8 T H CONGRZSS As one of i t s f i r s t orders of business in the 98th C o n g r e s s , on Feb. 22 and 23, 1 9 8 3 , the Subcommittee on Department Operation, R e s e a r c h , and F o r e i g n Agriculture held a hearing on the draft report. Some c r i t i c s claimed the staff report shows the need f o r major revisions in FIFRA to a d d r e s s both current a n 8 more longstanding questions about implementing FIFRA. Nonetheless, on Apr. 2 7 , 1 9 8 3 , Representative B r o w n , chairman of the S u b c o m m i t t e e , introduced H.R. 2 7 8 5 , proposing only minor amendments, reinstating the Scientific Advisory P a n e l , and reauthorizing FIFRA f o r one year. It was explained that a t this time the issues raised by t h e staff report would be best dealt with through continuing o v e r s i g h t hearings of the program instead of additional legislative changes'. The Subcommittee considered the bill on Apr. 2 7 , and it approved H.R. 2785 a f t e r a m e n d i n g it t o reauthorize FIFRA for 2 years. On May 3 the full Agriculture Committee amended the bill to be only a one-year r e a u t h o r i z a t i o n , a n d i t was reported to the House on May 1 0 ( H - R e p t . 98-104). On May 1 7 , 1 9 8 3 , the bill was called up by t h e House under Suspension of Rules and passed by voice vote. In the S e n a t e , on May 1 1 , Senator H e l m s , chairman of the Agriculture C o m m i t t e e , introduced the Administration S i l l , S. 1 2 6 3 , which is a simple reauthorization of FIFRA for 2 years (including reactivating the S c i e n t i f i c . CRS- 5 Advisory Panel). IB83095 UPDATE-05/14/84 T h e Committee held hearings o n the bill on May 24, 1983. T h e debate over a two-year a s opposed to a one-year extension reflects concern over the magnitude of the FIFRA implementatio'n problems at EPA. Supporters of the one-year extension wanc the opportunity to r e v i e w EPA's progress in overcoming these difficulties a s soon a s possible. S u p p o r t e r s of t h e two year e x t e n s i o n , while not necessarily downplaying the s i g n i f i c a n c e of the p r o b l e m s , a r g u e t h a t during 1 9 8 4 , a Presidential election y e a r , Congress will not be a b l e t o g i v e FIFRA the kind of thoughtful review i t deserves. L a t e i n the f i r s t session t h e Senate nonetheless decided to a c c e p t the House bill with the one-year reauthorization. On Nov. 4 the bill w a s Cischarged from the Commitcee by unanimous consent. F i n a l l y , on t h e l a s t day of the first s e s s i o n , Nov. 1 8 , E . R . 2785 passed the Senate w ~ t h o u t amendment by voice vote. It was signed into law Dec. 2 , 1 9 8 3 (P.L. 98-201). A further complication in considering FIFRA arises from a n Apr. 1 9 , 1 9 8 3 , decision of the U.S. District Court for the Eastern D i s t r i c t of Missouri that held certain provisions of FIFRA unconstitutional (Monsanto Co. v. Acting Administrator, U.S. Environmental Protection Agency). T h e decision referred to the provisions regarding registrant d a t a sharing and compensation for use of the data a s well a s public disclosure of that data. T h e Agency i s currently considering implications of the ruling for t k e pr-oduct registration p r o c e s s , . a n d h a s appealed -the decision. Most recently, an extensive package of FIFRA a m e n d m e n t s was introduced i n (Proxmire both t h e House and Senate. H.R. 3 8 1 8 (Harkin e t al.) and S. 1 7 7 4 et al.) i s titled t h e FIFRA Reform A c t , " t o better protect t h e environment and man from t h e hazards of pesticides." It i s supported b y a coalition of environmental and farm labor groups. Hearings on the bill h a v e been held by the DORFA subcommittee in late 1983. In the S e n a t e , no action on t h e bill has been scheduled. An i s s u e of increasing congressional concern h a s been t h e pesticide Ethylene D i b r o m i d e , which has caused cancer in laboratory a n i m a l s tests. EPA suspended most EDB u s e i n September 1983. No EDB residue levels i n f o o d had been established a s s a f e by E P A , and in December S t a t e officials i n Florida issued stop sale o r d e r s for f o o d s which contained a n y detectable l e v e l s of EDB. Other States began to conduct their own a n a l y s e s and pressed EPA to d e t e r m i n e allowable levels. Finally in February and March of 1 9 8 4 , EPA announced recommended levels a s a guide to State actions. However, controversies surrounding the regulatory history of EDE and i t s possible health risks have emerged a s a major pesticide issue for the second session of the 9 8 t h Congress. (For further i n f o r m a t i o n , see C R S Info Pak Ethylene D i b r o m i d e , IP0280E.) In light of the EDB s i t u a t i o n , H.R. 5 4 9 5 (Waxman) h a s been i n t r o d u c e d to a c h i e v e two broad goals. F i r s t , t h e bill would grant EPA and FDA authority to more quickly r e v o k e or impose residue tolerances i n certain emergency situations. S e c o n d , i t would greatly accelerate the development of chronic and other health d a t a for pesticides which d o not have a complete or reliable data base which f u l f i l l s all current regulatory requirements. T h e bill only covers pesticides f o r which there 1 s a food tolerance granted under t3e Federal F o o d , D r u g , and Cosmetic Act. Hearings on the bill a r e scheduled fcr May 1984. Related Issues CRS- 6 IB83095 UPDATE-05/14/84 T h e issue of data compensation and z r a d e secrets would be a f f e c t e d by patent legislation being considered in the Senate: S. 1 3 0 6 , supported by t h e National Agricultural Chemicals Association, would add u p to 7 y e a r s to pesticide patents. T h e problem of Agent Orange and possible health effects suffered by Vietnam veterans was the subject of several b i l l s , including: H.R. 4 6 2 , H.R. (For further information see IB83043 -1 9 6 1 , H.R. 2 0 9 , S. 7 8 6 , an'd S. 991. Agent Orange: V e t e r a n s 1 Complaints and S t u d i e s of Health Effects.) On the domestic use side of the 2 , 4 , 5,-T/dioxin i s s u e , H.R. 2 7 9 9 would promote forestry employment, c o n ~ r o lvegetation expenditures, and f o s t e r safe use of herbicides on public forest lands. Another herbicide-related issue concerns restrictions on t h e use of foreign aid f u n d s to f i n a n c e herbicide spraying of marijuana. The restriction a r o s e from concern that marijuana sprayed With the herbicide paraquat might contain residues that could harm users. H.Res. 1 4 3 , h o w e v e r , would direct that the U.S. should attempt to persuade Columbia t o begin such a n eradication program. . F i n a l l y , the issue of exports of hazardous substances has been reopened by Congress since President Reagan rescinded President C a r t e r ' s Executive Order setting out a Federal regulatory policy f o r dealing with exports of hazardous s u b s t a n c e s , including the export of pesticides that a r e banned o r restricted domestically. H.R. 2467 would reestablish a Federal policy o n t h e export of hazardous substances. LEGISLATION P.L. 9 8 - 2 0 1 , H.R. 2785 Amends t h e provisions of the F e d e r a l Insecticide, Fungicide, and Rodenticide Act relating L O the s c i e n t i f ~ cadvisory panel and e x t e n d s t h e authorization for appropriations for such Act. Introduced Apr. 27, 1983; referred t o CommLtzee on Agriculture. Reported May 1 1 , 1983 (H.Rept. 98-104); passed House May 1 7 , 1 9 8 3 , amended. Passed S e n a t e Nov. 1 8 , 1963. Signed i n t o l a w Dec. 2 , 1983. H.R. 2799 (Weaver) Defines the conditions for use of phenoxy herbicides on F e d e r a l lands managed by the Bureau of Land Management o r by the United S t a t e s Forest Service. Introduced Apr. 2 7 , 1 9 8 3 ; referred to more t h a n o n e committee. Amends t h e Federal Insecticide, F u n g i c i d e , and R o d e n t i c i d e Act t o require t h e denial of regi'stration of a pesticide Unless there i s submitted certain third-party data demonstrating that such pesticide will not cuase unreasonable a d v e r s e effects on the environment. Introduced May 10, 1983; referred to House Committee on Agriculture. ' H.R. 3 2 5 4 (Heftel) Protects the American public from c o n s u m i n g potentially unsafe pesticiee CRS- 7 residues on imported foodstuffs; to foster prudent and equitable regulatory r e q u i r e m e n t s a n d s t a n d a r e s f o r U.5. producers of agricultural commodities competing with producers in other countries in international and domestic markets; and to improve the international exchange of scientific information o n t h e p r o p e r t i e s , s a f e t y , b e n e f i t s , a n d r i s k s o f p e s t i c i d e use. Introduced J u n e 8 , 1983; referred to Committee on Agriculture. - H.R. 3818 (Harkin) Amends the Federal Insecticide, Fungicide, and Rodenticide Act to better protect the environment and man from the hazards of pesticides, and for other putposes. I n t r o d u c e d Aug. 4 , 1 9 8 3 ; r e f e r r e d t o C o m m i t t e e o n A g r i c u l t u r e . H.R. 5495 (Waxman) the Federal Food, Drug, and Cosmetic Act to A m e n d s s e c t i o n 408 of authorize emergency actzon with respect to pesticide chemicals which present an imminent hazard to the public health, to.revise the procedures under such section for changes in tolerances and exemptions for pesticide chemicals, and for other purposes. Introduced Apr. 1 2 , 1984; referred to Committee on Energy and Commerce. Amends the Federal Insecticide, Fungicide, and Rodenticide Act to direct the Administrator of the Environmental Protection Agency to maintain a biological pesticide testing facility. I n t r o d u c e d Mar. 1 1 , 1 9 8 3 ; r e f e r r e d t o Committee on Agriculture, Nutrition, and Forestry.' S. 1 2 6 3 ( H e l m s by r e q u e s t ) Amends and excends the Federal Insecticide, F u n g i c i d e , and Rodenticide A c t , a s a m e n d e d , f o r 2 years. Introduced May 1 1 , 1 9 8 3 ; referred t o Committee on Agriculture. S. 1 7 7 4 ( P r o x m i r e ) Amends the Federal Insecticide, Fungicide and Rodenticide Act to better protect the environment and man from the hazards of pesticides, and for other purposes. I n t r o d u c e d Aug. 4 , 1 9 8 3 ; r e f e r r e d t o C o m m i t t e e o n A g r i c u l t u r e , Nutrition, and Forestry. HEARINGS U.S. Congress. House. Committee on Agriculture. Subcommittee on Department Operations, Research, and Foreign Agriculture. "EPA Pesticide Regulatory Program Study." Hearings, 97th Dec. 1 7 , 1982. Congress, 2d session. R E P O R T S AND C O N G R E S S I O N A L D O C U M E N T S U.S. Congress. House. Committee on Agriculture. Federal Insecticide, Fungicide, and Rodenticide Act Amendments of 1982. Washington, R e p o r t t o a c c o m p a n y H.R. 5 2 0 3 . K a y 1 7 , 1 9 8 2 . U.S. G o v t . P r i n t . O f f . , 1 9 8 2 . At h e a d o f t i t l e : 97th Congress, 2d session. House. CRS- E IB83095 UPDATE-O5/i4/84 R e p o r t no. 37-566. U.S. Congress. House. Committee o n Agriculture. Federal I n s e c t i c i d e , F u n g i c ~ d e ,and Rodenticide Act Extension. Report t o accompany H.R. 2785. May 1 1 , 1983. W a s h i n g t o n , U.S. Govt. Print. Off., 1983. U.S. Congress. Senate. Committee o n A g r i c u l t u r e , Nutrition and Forestry. F e d e r a l Insecticide, F u n g i c i d e , and Rodenticide Act. Sept. 2 0 , 1982. Washington, U.S. Govt. Print. O f f . , 1982. At head of title: 97th C o n g r e s s , 2d session. Senate. Report no. 97-551. CHRONOLOGY OF EVENTS 05/24/83 -- Senate Agriculture Committee held hearings on S. 1263. 05/17/83 -- House passed H.R. 05/11/83 -- 05/10/83 -- 05/03/83 -- 04/27/83 -- 12/17/80 -- H.R. 09/30/78 -- Passage of the Federal Pesticide C o n t r o l Act of 1 9 7 8 , P.L. 95-395. 11/28/75 -- 10/21/72 -- 2 7 8 5 , with amendments. FIPRA r e a u t h o r i z a t i o n , with a m e n d m e n t s , introduced i n Senate ( S . 1263). House Committee on Agriculture reported H.R. (H.Rept. 98-104) . 2785 House Committee on Agriculture considered and marked up H.R. 2875. FIFRA reauthorization, with amenCments, introduced i n House (H.R. 2785). 7 0 1 8 signed i n t o l a w a s P.L. 96-539. Passage of FIFRA r e a u t h o r i z a t i o n s , P.L. deadlines extended to October 1977. 94-140; Passage of the Federal Environmental Pesticide Control Act of 1 9 7 2 , P.L. 92-516. ADDiTiONAL R E F E R E N C E SOURCES Environmental and Energy Study Conference. Update. Pesticide bill opponents put o n the b r a k e s , by Laurie Baker. U.S. Congress. 5 1 5 House Annex 2. Washington. National Academy of Sciences. Regulating pesticides. Prepared by the C o m m i t t e e o n Prototype Explicit Analyses for P e s t i c i d e s , National Research Council. W a s h i n g t o n , D.C. 1980. Special pesticide registration by t h e Environmental Protection Agency should be improved. R e p o r t to the Congress by t h e Comptroller General of the U n i ~ e d States. Washington, CRS- 9