The U.S. Environmental Protection Agency (EPA), Region IX, through the duly delegated Assistant Director of the Enforcement and Compliance Assurance Division ( Complainant ), alleges that Sunland Chemical and Research Corp. (Respondent) failed to
comply with Section 7(c)(l) of the Federal Insecticide, Fungicide and Rodenticide Act (FIFRA), 7 U.S.C. Section 136e(c)(l), and its implementing regulations at 40 C.F.R. Section 167.85.