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 Unelko Corporation (Respondent) failed to comply with Section 7(c)(l) of the Federal Insecticide, Fungicide and Rodenticide Act (FIFRA), 7 U.S.C. Section136e(c)(l), and its implementing regulations at 40 C.F.R. Section 167.85.