"The company submitting the application would have had to document effectiveness"

For EPA approval of pesticides no efficacy documentation is required.  EPA looks at efficacy as a matter between the buyer and seller and if there is an argument it is to be settled in court.  EPA only considers safety to the environment, safety to the applicator and safety to the consumer in its registration process.  The FDA on the other hand registers products mainly on proof of efficacy and cares far less about safety to the environment, applicators and consumers.  Thus, FDA is happy to register drugs that are known to cause cancer in test animals while EPA automatically refuses registration of such products.

Dick

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