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 I effect°" See 5 U.SoC_ 551(4) (APA definition of "rule_') o But
 I even if this were an adjudication rather than rulemaking_ it is
 clear that agencies may adopt principles of general applicability
 I for the first time in an adjudications See National Labor
 Relations Board v. Bell Aerospace Co. t 416 UoSo 267, 294 (1974)
 ("the Board is not precluded from announcing new principles in an
 adjudicative proceedingS'); Securities and Exchanqe Commission v.
 Chenery__Cq_rp__, 332 UoS. 194, 201 (1947) (Chener_L_II) (agency had
 duty to decide specific case based on proper standards
 "regardless of whether those standards previously had been
 I spelled out in a general rule or regulation_) o The FOIA
 i provision cited by petitioners does not prevent adoption of
 general policies in specific case adjudications but instead
 prevents enforcement actions directed against individuals based
 on "secret" policies previously adopted. Cf. Stuart-James Co. v.
 Securities and Exchange Commission, 857 F.2d 796, 800 (D.C. Cir.
 I 1988).
 The fact that the Administrator took no enforcement action
 I against petitioners, who themselves initiated the proceeding by
 filing petitions as '_interested part[ies] '_ (see 21 U.S.C.
 I 811(a)), also precludes petitioners from showing that they were
 i _'adversely affected _' by any purportedly secret policy, as
 required to state a claim under 5 UoSoC. 552(a) (]) (D) o
 Petitioners cite no case in which this FOIA provision was applied
 in favor of a rulemaking participant as opposed to an party

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