• Embed Doc
  • Copy Link
  • Readcast
  • Collections
  • CommentGo Back
Download
 
UNITED STATES ENVIRONMENTAL PROTECTION AGENCYBEFORE
THE
ADMINISTRATOR
7~
Lrty28
A
8:
36
In the Matter of
1
S.L. Cowley
&
Sons Mfg.
1
FIFRA Docket No. 341
CO.,
Inc.
1
Registrant
1
1
INITIAL DECISION0
F
EDWARD
B.
FINCHADMINISTRATIVE LAW JUDGE
By
Notice of Intent to Cancel Registration, dated November 22,1974, 39
F.R.
40980, and letter dated November 23, 1974,EPAX 1
GGG,
S.L. Cowley
&
Sons Mfg. Co., Inc., was notifiedthat
it
was the intention of the United States EnvironmentalProtection Agency (EPA) to cancel registration of Cowl ey 'sOriginal Rat and Mouse Poison, EPA Reg. No. 505-1, for fail
-
ure to meet efficacy requirements.
\
Upon the filing of objections and a request for hearing,EPAX 1 111, this proceeding was initiated. 40
CFR
164.20.
A
prehearing conference was held on May 12, 1975, atwhich agreement was reached by counsel for informal exchange
 
of efficacy studies and other related matters.
A
furtherprehearing conference was held on December 22, 1975, and areport of that conference was issued on December 23, 1975.Hearings were held on January 27, 28, and 29, 1976 andon March 3, 1976, at which Registrant was represented byMichael S. Yaroschuk, Esq. and Respondent was represented byWilliam
A.
White.Briefs were filed by Registrant and Respondent on April 9,1976 and rep1 ies on May
3,
1976.BackgroundS.
L.
Cowley
&
Sons Manufacturing Company, Inc., is asmall family business begun about forty years ago.The com-pany at present consists of
T.C.
Cowley, his wife, and twohelpers.The company has no regular sales force and engagesin no advertising or other promotions.Essentially,
its
cus-tomers are regular repeat customers built
up
over the years.The product is manufactured almost on a per order basis; thatis, during the busy season the product is
run
in small batches,usually enough to
run
for two to four weeks, and shipped di-
-
rectly to customers.
At
no time is a large inventory developed.During the year 1972 no more than 15,000 cases were producedand sold. The company's gross annual volume for 1971 -1 972was approximately $45,000.
of 00

Leave a Comment

You must be to leave a comment.
Submit
Characters: ...
You must be to leave a comment.
Submit
Characters: ...