The United States Environmental Protection Agency Region II Director of the Division of Enforcement and Compliance Assistance, and the Director of the Toxics and Pesticides Enforcement Division, Office of Regulatory Enforcement (collectively "Appellant" or "EPA"), appeal an Initial Decision of the presiding Administrative Law Judge ("Presiding Officer"), arising out of an administrative enforcement action against Tifa Limited ("Tifa") for alleged violations of section 12 of the Federal Insecticide, Fungicide, and Rodenticide Act ("FIFRA"), 7 U.S.C. § 136j.