The former NOP director Audit Report 01601-03-Hy 3 7 stated that the decision not to require regular residue testing was based on officials’ concerns about the cost of testing, and their position that the NOP regulations are process-based rather than a zero tolerance standard. The former director also stated that certifying agents did not want to pay for the cost of residue testing and that residue testing raises complex issues that must be addressed on an operation-by-operation basis. The former director also stated that the Office of the General Counsel (OGC) cleared the regulations before issuance. We discussed this issue with an.
