COMPLAINT ALLEGES ONE COUNT OF FAILURE TO MAINTAIN ALL UN- DERLYING RAW DATA SUBMITTED IN SUPPORT OF A PESTICIDE REG- ISTRATION, A VIOLATION OF FIFRA SEC.8,7 U.S.C. SEC 136F. ANALYSIS FIFRA SEC.8(A) AUTHORIZES EPA TO PRESCRIBE REGULATIONS RE- QUIRING PESTICIDE PRODUCERS TO MAINTAIN RECORDS WITH RESPECT TO PRODUCTION OPERATIONS, AND THE PESTICIDES AND DEVICES PRODUCED THEREBY, AS DEEMED NECESSARY FOR THE EFFECTIVE EN- FORCEMENT OF THE ACT. 40 C.F.R. SEC.169.2(K) REQUIRES THAT ALL PRODUCERS OF PESTICIDES, PESTICIDE DEVICES, OR ACTIVE IN GREDIENTS USED IN PRODUCING PESTICIDES MUST KEEP RECORDS CONTAINING RESEARCH DATA RELATING TO REGISTERED PESTICIDES, INCLUDING ALL TEST REPORTS SUBMITTED TO EPA IN SUPPORT OF REGISTRATION OR IN SUPPORT OF A TOLERANCE PETITION, ALL UN- DERLYING RAW DATA, AND INTERPRETATIONS AND EVALUATIONS THEREOF. FIFRA SEC.12(A)(2)(B), 7 U.S.C. SEC.136J(A)(2)(B), PROVIDE THAT IT IS UNLAWFUL TO REFUSE TO KEEP RECORDS REQUIRED BY FIFRA SEC.8. ON OR ABOUT JULY 20, 1979, JULY 23, 1979, AND AUGUST 6, 1979, ALCO CHEMICAL CORPORATION SUBMITTED TO THE AGENCY RE- PORTS OF TESTS IN SUPPORT OF THE REGISTRATION OF A PESTICIDE PRODUCT PRODUCEDBY THE COMPANY. THE PESTICIDE PRODUCT WAS SUBSEQUENTLY REGISTERED BY EPA BASED UPON THE SUBMITTED TEST REPORTS. ON MARCH 19, 1986, ALCO CHEM