EPA’s regulation at 40 CFR § 159.158(a) provides that risk/benefit information subject to reporting under FIFRA section 6(a)(2) includes opinions and conclusions of certain employees and agents of registrants. Some registrants have objected to this provision because they believe it requires reporting of all opinions and conclusions of attorneys. EPA is issuing this PRN to inform registrants of EPA’s opinion that an attorney’s professional legal judgment is not an opinion or conclusion that is reportable under 40 CFR part 159. 

• PRN 2000-8: Reportability of Attorneys’ Opinions and Conclusions Under 40 CFR Part 159 and FIFRA Section 6(a)(2) (PDF)(3 pp, 8 K)