OCM-OPTS HAS REFERRED FOR OECM-SLD CONCURRENCE AN ADMINIS- TRATIVE COMPLAINT AGAINST THE ROHM AND HAAS COMPANY, INC. OF PHILADELPHIA, PA. COMPLAINT ALLEGES FIFTEEN COUNTS OF FAIL- URE TO MAINTAIN ALL UNDERLYING RAW DATA SUBMITTED IN SUPPORT OF VARIOUS PESTICIDE REGISTRATIONS, VIOLATIONS OF FIFRA SEC. 8, 7 U.S.C. SEC.136F. FIFRA SEC.8(A) AUTHORIZES EPA TO PRESCRIBE REGULATIONS RE- QUIRING PESTICIDE PRODUCERS TO MAINTAIN SUCH RECORDS WITH RESPECT TO THEIR 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, DEVICES, OR ACTIVE INGREDIENTS USED IN PRODUCING PESTICIDES MUST KEEP RECORDS CONTAINING RE SEARCH DATA RELATING TO REGISTERED PESTICIDES INCLUDING ALL TEST REPORTS SUBMITTED TO EPA IN SUPPORT OF REGISTRATION OR IN SUPPORT OF A TOLERANCE PETITION, ALL UNDERLYING RAW DATA, AND INTREPRETATIONS AND EVALUATIONS THEREOF. FIFRA SEC.12(A)(2)(B), 7 U.S.C. SEC136J(A)(2)(B), PROVIDES THAT IT IS UNLAWFUL TO REFUSE TO KEEP RECORDS REQUIRED BY SEC.8. ON SEVERAL OCCASIONS BETWEEN NOVEMBER 9, 1976 AND FEB. 4, 1985, ROHM AND HAAS COMPANY SUBMITTED TO THE AGENCY REPORTS OF TESTS, CONDUCTED ON ITS BEHALF BY CANNON LABORATORIES, IN SUPPORT OF THE REGISTRATION OF VARIOUS PESTICIDE PRODUCTS PRODUCED BY THE COMPANY. THE VARIOUS