gerey >; && 4 - 4 SZ 3 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY , ef WASHINGTON, D.C. 20460 Ae page? : PEesTicipes ANO TOXIC SUBSTANCES ADDITIONAL BACKGROUND ON THE IBT REVIEW PROGRAM In 1976, during a routine lab. inspection of one of IBT's facilities, FDA discoverd deficiencies in the manner in which studies were being conducted and discrepancies between those studies and their raw data. In 1977, EPA placed a moratorium on registration actions involving data developed at [BT as a result of this information. In the same year, EPA notified registrants that they were required to audit the raw data and validate both those IBT studies which were pivotal to the data base of pesticides already registered and all those which were supporting new registration actions. In 1978 a joint EPA/FDA audit of IBT's two other facilities uncovered problems similar to those discovered during the initial audit. In March of that year EPA required registrants to submit to EPA the raw data for the IBT studies so that a review of registrant audits could be conducted. EPA referred this case to the Department of Justice for ; investigation in April 1978. At approximately the same time, the U.S. and Canada were negotiating an agreement to share - the task of spot checking registrants' audits of IBT studies. Through these checks, however, it became apparent that registrants’ audits routinely overlooked some areas of concefn. As a result, Canada and the U.S. agreed to review each audit ' and study. Mutual agreement was reached as to which studies would be reviewed by each country. It was also decided that each country would accept the other's determination as to validity. However, due to differences in data requirements, each country would independently evaluate whether studies met their regulatory requirements, and determine the need for replacement studies. , 8