SF­
83
SUPPORTING
STATEMENT
ENVIRONMENTAL
PROTECTION
AGENCY
RECORDKEEPING
REQUIREMENTS
FOR
PRODUCERS
OF
PESTICIDES
40
CFR
PART
169
1.
Identification
of
the
Information
Collection
1(
a)
Title
of
the
Information
Collection
Recordkeeping
Requirements
for
Producers
of
Pesticides
under
section
8
of
the
Federal
Insecticide,
Fungicide,
and
Rodenticide
Act
as
amended
(
FIFRA).
ICR
Number
0143.08
1(
b)
Short
Characterization/
Abstract
FIFRA
section
8
states
that
the
Administrator
of
the
Environmental
Protection
Agency
may
prescribe
regulations
requiring
pesticide
producers,
registrants
and
applicants
for
registration
to
maintain
such
records
with
respect
to
their
operations
and
the
effective
enforcement
of
this
Act
and
to
make
such
records
available
for
inspection
and
copying
as
specified
in
the
statute.
The
regulations
at
40
CFR
Part
169
(
Books
and
Records
of
Pesticide
Production
and
Distribution)
specify
the
following
records
that
producers
must
keep
and
the
disposition
of
those
records.

Producers
must
maintain
records
on
production
data
for
pesticides,
devices,
or
active
ingredients
(
including
pesticides
produced
pursuant
to
an
experimental
use
permit);
receipt
by
the
producer
of
pesticides,
devices,
or
active
ingredients
used
in
producing
pesticides;
delivery,
moving,
or
holding
of
pesticides;
inventory;
domestic
advertising
for
restricted
use
pesticides;
guarantees;
exports;
disposal;
human
testing;
and
tolerance
petitions.
Additionally,
section
8
gives
the
Agency
inspectional
authority
to
monitor
the
validity
of
research
data
(
including
raw
data),
developed
in
accordance
with
Good
Laboratory
Practice
Standards,
and
used
to
support
pesticide
registration.
These
records
generally
consist
of
the
material
produced
during
the
course
of
ordinary
business
activity,
and
are
maintained
in
the
location,
manner,
and
duration
as
is
generally
prudent
for
such
records
in
the
course
of
ordinary
business
activity.

Respondents
are
required
to
maintain
records
of
receipt,
production,
shipping,
and
inventory
for
two
years.
Records
regarding
testing
of
registered
pesticides
must
be
maintained
for
the
life
of
the
pesticide
registration,
as
such
data
are
necessary
to
support
the
regulatory
decision.

Approximately
12,953
respondents
are
currently
subject
to
this
requirement,
and
it
is
estimated
that
no
additional
respondents
per
year
will
become
subject
to
this
requirement
in
the
next
three
years.
The
cost
of
this
ICR
to
the
respondents
is
estimated
to
be
$
1,107,524.
The
estimate
of
number
of
respondents
is
based
on
the
number
of
pesticide
producers
who
have
responded
to
the
latest
mandatory
annual
reporting
response
under
FIFRA
section
7,
which
defines
the
entire
universe
of
legal
producers
of
pesticides
for
sale
or
distribution
in
the
United
States.
The
estimated
change
is
based
on
extrapolation
from
trends
in
the
number
of
reported
­
2­

producers
over
the
last
three
years.
The
estimated
cost
per
producer
has
been
estimated
to
consist
entirely
of
the
cost
of
preparing
records
for
inspection,
as
the
recordkeeping
itself
consists
of
activities
that
are
considered
to
be
customary
business
practices.

2.
Need
for
and
Use
of
the
Collection
2(
a)
Need/
Authority
for
the
Collection
FIFRA
section
8(
a)
states
that
the
Administrator
may
prescribe
regulations
requiring
producers,
registrants,
and
applicants
for
registration
to
maintain
such
records
with
respect
to
their
operations
and
the
pesticides
and
devices
produced
as
the
Administrator
determines
are
necessary
for
the
effective
enforcement
of
[
FIFRA]
and
to
make
such
records
available
for
inspection
and
copying.

FIFRA
section
12(
a)(
2)(
B)(
i)
provides
that
it
is
unlawful
for
any
person
to
refuse
to
prepare,
maintain,
or
submit
any
records
required
by
or
under
section
8
of
the
Act.

2(
b)
PRACTICAL
UTILITY/
USERS
OF
THE
DATA
EPA
must
be
able
to
examine
and
copy
records
at
pesticide
producers
demonstrating
the
identity,
production,
receipt,
shipment,
inventory,
advertisement,
and
guarantees
with
respect
to
all
domestically
sold
or
distributed
pesticides.
This
is
necessary
to
determine
that
such
products
are
in
compliance
with
FIFRA
and
to
support
enforcement
action
against
the
products
producers
if
they
are
not.
EPA
must
be
able
to
examine
and
copy
records
with
respect
to
exported
pesticides
in
order
to
determine
that
products
that
have
been
exported
are
in
compliance
with
labeling
and
foreign
purchaser
specification
and
acknowledgment
requirements,
and
to
take
support
enforcement
action
against
exporters
who
do
not
comply
with
FIFRA
requirements.
EPA
must
be
able
to
examine
records
of
pesticide
disposal
in
order
to
protect
public
health
and
the
environment
should
it
be
necessary
to
locate
such
disposal
sites.
EPA
must
be
able
to
access
records
regarding
testing
on
humans
to
protect
the
health
and
safety
of
such
testing
subjects
should
potential
adverse
effects
become
known.
EPA
must
be
able
to
access
records
regarding
testing
of
registered
pesticides
to
determine
the
integrity
of
such
information,
and
the
subsequent
validity
of
regulatory
decisions
based
on
such
information
that
allow
the
continued
sale
and
distribution
of
specific
pesticide
products.

These
data
may
be
used
by
enforcement
and
compliance
officers
at
the
federal
and
state
level,
and
by
regulatory
officials
at
the
federal
and
state
level.

3.
Nonduplication,
Consultations,
and
Other
Collection
Criteria
3(
a)
Nonduplication
The
records
required
to
be
maintained
are
normal
business
records
and
as
such
are
only
created
upon
the
occurrence
of
a
discrete
activity.
These
records
may
be
reproduced
at
the
time
­
3­

of
an
inspection
but
EPA
does
not
require
a
producer
to
submit
these
records
to
the
Agency.
Since
it
applies
to
the
original
records,
no
duplication
exists.

3(
b)
Public
Notice
Required
Prior
to
ICR
Submission
to
OMB
An
announcement
of
a
public
comment
period
for
the
renewal
of
this
ICR
was
published
in
the
Federal
Register
on
March
31,
2004
(
69
FR
16916).

3(
c)
Consultations
EPA
received
three
comments:
two
from
pesticide
producers
and
one
from
an
association
representing
many
industries
affected
by
the
ICR.
One
of
two
pesticide
producers
discussed
the
utility
of
production
data
reports.
The
other
producer
and
the
association
both
addressed
the
issue
of
allowing
copies
of
records
to
serve
as
replacements
for
original
records.
The
matter
of
production
data
reports
is
not
relevant
to
this
ICR,
and
that
comment
can
not
be
responded
to
in
this
supporting
statement.
The
other
comments
are
relevant
and
are
addressed
below.

The
producer
and
association
commenting
on
the
matter
of
record
copies
addressed
the
same
issues.
They
both
supported
the
need
for
Books
and
Records
recordkeeping,
but
questioned
the
accuracy
of
burden
estimates,
and
suggested
that
the
quality,
utility,
and
clarity
of
information
records
would
be
enhanced
by
allowing
records
to
be
copied,
including
in
electronic
format,
rather
than
requiring
original
records
to
be
maintained.

EPA
has
maintained
since
the
inception
of
this
ICR
that
all
of
the
records
required
to
be
maintained
by
the
relevant
regulatory
authority
are
generated
and
maintained
by
customary
business
practices.
Although
information
management
technologies
have
evolved
since
the
regulations
were
written
twenty
four
years
ago
(
reference:
45
FR
54388,
August
15,
1980)
the
need
to
generate
and
maintain
these
records
has
not
changed.
EPA
considers
the
information
collection
burden
of
this
requirement
to
continue
to
consist
solely
of
the
need
to
review
and
understand
the
regulations.

EPA's
extant
regulation
recognizes
that
the
integrity
of
data
records
can
be
assured
only
through
the
retention
of
original
records.
Allowing
replacement
of
records
with
copies
would
require
revision
of
the
regulation.
This
matter
is
dependent
on
separate
government­
and
agencywide
determinations.
It
cannot
be
addressed
in
this
ICR..

3(
d)
Effects
of
Less
Frequent
Collection
Each
record
required
relates
to
a
separate,
discrete
business
activity.
Each
record
is
generated
only
once
in
the
course
of
each
activity.
It
would
not
be
possible
to
reduce
the
collection
frequency
without
removing
certain
activities
from
compliance
altogether.

3(
e)
General
Guidelines
­
4­

None
of
the
reporting
or
recordkeeping
requirements
contained
in
40
CFR
Part
169
or
otherwise
pertinent
to
this
request
violate
any
of
the
regulations
established
by
OMB
in
5
CFR
1320.6.

3(
f)
Confidentiality
The
required
information
consists
of
emissions
data
and
other
information
that
have
been
determined
not
to
be
private.
However,
any
information
submitted
to
the
agency
for
which
a
claim
of
confidentiality
is
made
will
be
safeguarded
according
to
the
Agency
policies
set
forth
in
Title
40,
Chapter
1,
Part
2,
Subpart
B
­
Confidentiality
of
Business
Information
(
see
40
CFR
2;
41
FR
36902,
September
1,
1976;
amended
by
43
FR
40000,
September
8,
1978;
43
FR
42251,
September
20,
1978;
44
FR
17674,
March
23,
1979).

3(
g)
Sensitive
Questions
None
of
the
reporting
or
recordkeeping
requirements
contained
in
40
CFR
Part
169
or
otherwise
pertinent
to
this
request
contain
sensitive
questions.

4.
The
Respondents
and
the
Information
Requested
4(
a)
Respondents/
SIC
Codes
The
three­
digit
Standard
Industrial
Classification
codes
assigned
to
pesticide
producers
are
286
and
287.

4(
b)
INFORMATION
REQUESTED
(
i)
Data
Items
All
data
in
this
ICR
that
is
recorded
is
required
by
40
CFR
Part
169.
Under
this
requirement
producers
of
pesticides
must
maintain:

(
A)
In
a
current
status:

­
Inventory
records
with
respect
to
types
and
amounts
of
pesticides
and
active
ingredients
or
quantities
of
devices
in
stock.
These
records
may
be
discarded
when
updated
with
more
current
records.
(
169.2(
e))

(
B)
For
one
(
1)
year:

­
copies
of
all
guarantees
given
pursuant
to
section
12(
a)(
2)(
C)
of
the
Act.
(
169.2(
g))

(
C)
For
two
(
2)
years:
­
5­

­
Records
showing
the
product
name,
EPA
registration
number,
experimental
use
permit
number,
amounts
per
batch
and
batch
identification
numbers
of
pesticides
produced.

­
Records
showing
the
brand
names
and
quantities
of
pesticides
produced.
(
169.2(
b))

­
Records
showing
the
following
information
regarding
receipt
by
the
producer
of
pesticides,
devices,
and
active
ingredients:
brand
name
of
pesticide
or
device
or
common/
chemical
name
of
active
ingredient;
name
and
address
of
shipper;
name
of
delivering
carrier;
date
received;
and
quantities
received.
(
169.2(
c))

­
Records
showing
the
following
information
regarding
shipment
by
the
producer
of
pesticides,
devices,
and
active
ingredients:
brand
name
of
pesticide
or
device
or
common/
chemical
name
of
active
ingredient;
name
and
address
of
consignee;
in
the
case
of
pesticides
produced
pursuant
to
sections
5,
18,
or
24
of
the
Act,
the
information
required
under
these
sections
and
any
regulations
promulgated
thereto
regarding
the
distribution
of
such
pesticides;
name
of
originating
carrier;
date
shipped
or
delivered
for
shipment;
and
quantities
shipped
or
delivered
for
shipment.
(
169.2(
d))

­
Copies
of
all
domestic
advertising
of
the
restricted
uses
of
any
restricted
use
pesticide
that
the
producer
caused
to
have
prepared.
(
169.2(
f))

­
In
the
case
of
pesticides,
devices,
and
active
ingredients
used
in
producing
pesticides
intended
solely
for
export:
copies
of
specifications
or
directions
of
the
foreign
purchaser
for
production
of
such
pesticides,
devices,
and
active
ingredients;
copies
of
labels
or
labeling
required
to
comply
with
section
17(
a)(
1)
of
the
Act;
and
for
any
pesticide
not
registered
under
section
3
or
sold
under
section
6(
a)(
1)
of
the
Act,
a
copy
of
the
statement
from
the
foreign
purchaser
acknowledging
that
the
foreign
purchaser
is
aware
that
the
product
is
not
registered
in
the
United
States
and
cannot
be
sold
for
use
in
the
United
States.
(
169.2(
h))

(
D)
For
twenty
(
20)
years,
or
forwarded
after
three
(
3)
years
to
EPA
for
maintenance:

­
Records
of
the
method
of
disposal,
data
or
dates
of
disposal,
location
of
disposal
sites,
and
types
and
amounts
of
pesticides
or
pesticide
active
ingredients
disposed
of
by
the
producer
or
contractor,
deviations
from
normal
practice,
and
records
on
disposal
of
pesticides,
active
ingredients,
or
containers
specified
pursuant
to
section
19
of
the
Act
or
regulations
promulgated
thereto.
(
169.2(
i))

­
Records
of
any
tests
conducted
on
human
beings
whether
conducted
by
or
paid
for
­
6­

by
the
producer,
including:
the
names
and
addresses
of
subjects
tested,
dates
and
types
of
tests;
written
consent
of
subjects
to
test;
instructions
to
subjects
regarding
purpose,
nature,
foreseeable
health
consequences
of
the
tests;
and
any
records
of
adverse
effects
either
before
or
after
the
tests.
(
169.2(
j))

(
E)
For
as
long
as
a
registration
is
valid
and
the
producer
is
in
business:

­
records
containing
research
data
relating
to
registered
pesticides
including
data
submitted
to
the
EPA
in
support
of
a
registration
or
tolerance
petition,
and
all
underlying
raw
data.
(
169.2(
k))

This
period
of
retention
is
necessary
to
allow
the
agency
to
evaluate
the
validity
of
data
used
to
support
pesticide
registrations
at
any
time
during
the
period
that
the
product
is
registered.
Without
these
data
the
Agency
would
not
be
able
to
support
its
regulatory
decision
allowing
the
product
to
be
registered.

(
ii)
Respondent
Activities
­
Read
instructions­
40
CFR
Part
169
regulations.

­
Plan
activities­
CBP
­
Gather
information­
CBP
­
Plan
and
review
information
for
accuracy­
CBP
­
Store,
file,
and
maintain
the
information­
CBP
CBP­
"
Customary
and
Usual
Business
Practice"

During
the
course
of
normal
and
prudent
business
operations,
a
producer
would
plan
his
and
his
staff's
information
collection
activities,
arrange
for
the
collection,
review
himself
or
have
staff
review
the
information
for
accuracy,
and
arrange
to
maintain
or
store
the
information
detailed
under
3(
b).
The
information
required
to
be
kept
is
generally
information
that
prudent
businesses
would
maintain.
The
Agency
does
not
specify
in
the
regulation
how
the
data
to
be
gathered
must
be
organized.
Therefore,
producers
can
continue
to
gather
the
required
data
in
a
manner
consistent
with
their
customary
and
usual
business
practices.
­
7­

5.
The
Information
Collected
­­
Agency
Activities,
Collection
Methodology,
and
Information
Management
5(
a)
Agency
Activities
In
this
collection
the
Agency
will:
1)
answer
producers'
questions;
2)
may
audit
or
review
data
collected;
3)
provide
appropriate
protection
of
confidential
business
information;
and
4)
store
long­
term
data,
if
requested.

5(
b)
Collection
Methodology
and
Management
Producers
determine
how
best
to
comply
with
the
requirements
for
recordkeeping
under
FIFRA
section
8.
They
may
collect
and
store
the
required
data
electronically.
The
Agency,
through
State,
headquarters
or
EPA
Regional
inspectors,
may
periodically
audit
or
review
the
data
at
sites
chosen
by
individual
producers.
Other
than
review
during
periodic
inspections,
those
records
will
generally
not
be
submitted
to
the
Agency
unless
the
Agency
requests
them
for
a
specific
reason,
such
as
a
need
to
review
research
data
supporting
a
registration
or
in
the
preparation
of
an
enforcement
case.

Those
records
pertaining
to
disposal
of
pesticide
and
human
testing,
which
are
required
to
be
retained
for
20
years,
may
be
turned
over
to
the
Agency
for
storage
after
3
years.
The
Agency
then
stores
those
records
in
the
form
in
which
they
are
submitted.
If
a
producer
submits
section
8
records
to
the
Agency,
that
portion
of
the
records
which
are
not
classified
as
Confidential
Business
Information
(
CBI)
could
be
accessed
by
the
public
through
the
Freedom
of
Information
Act.

5(
c)
Small
Entity
Flexibility
The
information
collected
under
ICR
#
0143
does
not
negatively
impact
small
businesses,
since
the
records
required
to
be
maintained
are
those
which
qualify
as
"
customary
and
usual
business
activity."
To
the
extent
that
larger
businesses
can
use
economies
of
scale
to
reduce
their
burden,
the
overall
burden
will
be
reduced.
However,
even
though
the
recordkeeping
and
reporting
requirements
are
the
same
for
small
and
larger
businesses,
the
Agency
considers
these
requirements
the
minimum
needed
to
ensure
compliance
and,
therefore,
cannot
reduce
them
further
for
small
businesses.

5(
d)
Collection
Schedule
There
is
no
specified
collection
schedule.
Production
of
records
for
Agency
review
occurs
at
the
time
of
routine
inspection,
which
occurs
approximately
every
two
to
three
years,
or
when
a
specific
need
arises
to
evaluate
the
compliance
of
a
producer.
For
the
purposes
of
estimation,
this
is
assumed
to
be
annual,
which
overstates
the
actual
collection
burden.
­
8­

6.
Estimating
the
Burden
and
Cost
of
the
Collection
The
records
that
must
be
maintained
for
purposes
of
FIFRA
section
8
are
generally
those
that
a
responsible
company
would
maintain
as
good
business
practice.
It
is
estimated
that
the
burden
for
a
producer
to
prepare
for
the
possibility
of
an
on­
site
EPA
inspection
of
those
records,
is
two
hours
per
year.
The
burden
is
due,
therefore,
less
to
the
actual
recordkeeping
requirement
itself
than
to
the
burden
placed
upon
the
record
keeper
in
locating
and
presenting
these
records
to
an
inspector.
While
the
actual
burden
that
falls
upon
a
company
undergoing
an
inspection
may
be
greater
than
the
estimated
two
hours,
a
given
company
will
undergo
an
inspection
no
more
often
than
once
every
two
to
three
years,
if
that
frequently.
EPA
estimates
that
approximately
one
hour
is
spent
by
management
employees
in
the
planning
and
reviewing
of
the
records
for
presentation
to
an
EPA
inspector
and
one
hour
by
a
clerical
employee
in
the
planning,
gathering,
and
maintenance
of
the
information.

Table
2
documents
the
computation
of
individual
burdens
for
each
of
the
recordkeeping
and
reporting
requirements
applicable
to
the
industry.
The
individual
burdens
are
expressed
under
standardized
headings
believed
to
be
consistent
with
the
concept
of
burden
under
the
Paperwork
Reduction
Act.
Where
appropriate,
specific
tasks
and
major
assumptions
have
been
identified.

Responses
to
this
information
collection
are
mandatory,
as
required
at
FIFRA
sections
8
and
12(
a)(
2)(
B).
The
Agency
may
not
conduct
or
sponsor,
and
a
person
is
not
required
to
respond
to,
a
collection
of
information
unless
it
displays
a
currently
valid
OMB
control
number.

6(
a)
Estimating
Respondent
Burden
The
average
annual
burden
to
industry
over
the
next
three
years
from
these
recordkeeping
and
reporting
requirements
is
estimated
at
two
(
2)
person­
hours.
These
hours
are
based
on
Agency
knowledge
and
experience
with
the
pesticides
program,
the
previously
approved
ICR,
and
any
comments
received
about
time
to
prepare
reports.

6(
b)
Estimating
Respondent
Costs
(
i)
Estimating
Labor
Costs
This
ICR
uses
labor
rates
of
Executive,
Administrative,
and
Managerial
($
58.69,
based
on
$
27.94
per
hour
+
110%
overhead)
and
Clerical
($
26.80,
based
on
$
12.78
per
hour
+
110%
overhead).
These
rates
were
from
the
United
States
Department
of
Commerce
Bureau
of
Labor
Statistics,
March
1998,
Table
2:
Employment
Costs
for
Civilian
Workers
by
Occupational
and
Industry
Group,
as
used
in
the
last
ICR,
and
adjusted
using
the
DOC
CPI
calculator,
which
adjusted
with
a
total
inflation
factor
of
1.164
for
the
seven­
year
period
from
1998
to
2004.
Costs
are
determined
to
be
equally
divided
between
managerial
and
clerical,
for
an
average
overall
hourly
cost
of
$
42.75
including
overhead.
­
9­

(
ii)
Estimating
Capital
and
Operations
and
Maintenance
Costs
The
only
type
of
industry
costs
associated
with
the
information
collection
activity
in
the
standards
are
labor
costs.

(
iii)
Capital/
Start­
up
vs.
Operating
and
Maintenance
(
O&
M)
Costs
This
is
not
applicable
as
there
are
no
capital/
start­
up
costs.

6(
c)
Estimating
Agency
Burden
and
Cost
As
part
of
an
existing
and
ongoing
program,
the
developmental
costs
for
this
information
collection
activity
are
minimal,
and
includes
only
the
preparation
of
a
written
justification,
narrative,
and
description
for
the
clearance
request,
and
the
preparation
of
and
description
for
the
clearance
request,
and
the
preparation
of
the
SF
83.
The
EPA
estimates
such
costs
at
a
GS­
13
(
step
1)
salary
level
for
two
work
weeks.
Since
these
activities
occur
only
in
the
three­
year
clearance
period,
their
cost
on
a
pro­
rated
annual
basis
is
one­
third
of
the
total
one­
time
cost.
The
estimated
cost
is
$
1990.08
(
hourly
rate
of
$
34.55,
with
an
additional
benefits
multiplication
factor
of
1.16,
multiplied
by
80
hours,
and
that
number
divided
by
3).
As
a
recordkeeping
requirement,
rather
than
a
reporting
requirement,
there
are
no
additional
Federal
costs
directly
associated
with
this
information
collection
activity.
Details
upon
which
this
estimate
is
based
appear
in
Table
1:
Agency
Burden.

6(
d)
Estimating
the
Respondent
Universe
and
Total
Burden
and
Costs
The
number
of
existing
respondents
subject
to
40
CFR
Part
169
is
12,953
The
number
of
new
respondents
subject
to
40
CFR
Part
169
from
the
previous
ICR
is
618,
which
is
an
adjustment
reflecting
fluctuations
in
the
numbers
of
respondents
.
The
total
annual
labor
costs
are
$
1,107,524
and
total
annual
capital
and
O&
M
costs
to
the
regulated
entity
are
$
0
dollars.
Details
upon
which
this
estimate
is
based
appear
in
Table
2:
Industry
Burden
­
10­

6(
e)
Bottom
Line
Burden
Hours
And
Cost
Tables
TABLE
1.
AVERAGE
ANNUAL
EPA
RESOURCE
REQUIREMENT
FOR
PESTICIDE
PRODUCERS,
40
CFR
PART
169
Activity
(
A)
EPA
hr/
Occurrence
(
B)
Occurrences
(
C)
a
EPA
hr/
yr
(
D)
b
EPA
Cost
($)

Preparation
of
ICR
80
0.333
26.666
$
1,990
TOTAL
ANNUAL
HOURS
26.666
$
2,990
Salary:
(
1
person
x
27.666hrs/
year
x
$
74.63/
hr)
=
$
1,990/
year
TOTAL
ANNUAL
COST
TO
EPA
=
$
1,990
a
AXB=
C
b
Assume
an
hourly
wage
of
$
34.55
plus
116
percent
to
account
for
benefits
and
overhead
which
equals
$
74.63.
This
amount
was
multiplied
by
the
hours
per
year
in
Column
C.

TABLE
2.
ANNUAL
BURDEN
OF
REPORTING
AND
RECORDKEEPING
REQUIREMENTS
FOR
PESTICIDE
PRODUCERS,
40
CFR
PART
169
Recordkeeping
requirements
(
A)
Occurences/
hours
per
occurence
(
B)
Hours/
respondent
/
year
(
C=
AXB)
Respondent
/
year
(
D)
Respondents
per
year
(
E=
CXD)
Hours
per
year
(
F)
a
Cost/
year,
$

A.
Read
Instructions
1
0.5
0.5
12,953
6,477
$
276,892
B.
Plan
Activities
1
0.5
0.5
12,953
6,477
$
276,892
C.
Implement
Activities
1
1.0
1.0
12,953
12,953
$
553,741
D.
Develop
Record
System
­
­
N/
A
b
­
­

E.
Time
to
Enter
Information
­
­
N/
A
b
­
­

F.
Audits
­
­
N/
A
c
­
­

TOTAL
ANNUAL
BURDEN
­
­
25,907
$
1,107,524
a
Assume
an
hourly
wage
of
$
20.36
plus
110
percent
overhead
costs,
which
equals
$
42.75.
This
amount
was
multiplied
by
the
hours
per
year
in
Column
E.
b
Assume
that
this
is
in
accordance
with
customary
business
practices
with
no
additional
burden
to
the
respondent.
c
Burden
for
audits
is
included
in
activities
A­
C
.

6(
f)
Reasons
for
Change
in
Burden
The
increase
in
burden
of
1,235
hours
annually
is
an
adjustment
due
to
a
change
in
the
number
of
respondents
since
the
last
ICR.
6(
g)
Burden
Statement
The
annual
public
reporting
and
recordkeeping
burden
for
this
collection
of
information
is
­
11­

estimated
to
average
2
hours
per
response.
Burden
means
the
total
time,
effort,
or
financial
resources
expended
by
persons
to
generate,
maintain,
retain,
or
disclose
or
provide
information
to
or
for
a
Federal
agency.
This
includes
the
time
needed
to
review
instructions;
develop,
acquire,
install,
and
utilize
technology
and
systems
for
the
purposes
of
collecting,
validating,
and
verifying
information,
processing
and
maintaining
information,
and
disclosing
and
providing
information;
adjust
the
existing
ways
to
comply
with
any
previously
applicable
instructions
and
requirements;
train
personnel
to
be
able
to
respond
to
a
collection
of
information;
search
data
sources;
complete
and
review
the
collection
of
information;
and
transmit
or
otherwise
disclose
the
information.
An
agency
may
not
conduct
or
sponsor,
and
a
person
is
not
required
to
respond
to,
a
collection
of
information
unless
it
displays
a
currently
valid
OMB
control
number.
The
OMB
control
numbers
for
EPA's
regulations
are
listed
in
40
CFR
part
9
and
48
CFR
chapter
15.
To
comment
on
the
Agency's
need
for
this
information,
the
accuracy
of
the
provided
burden
estimates,
and
any
suggested
methods
for
minimizing
respondent
burden,
including
the
use
of
automated
collection
techniques,
EPA
has
established
a
public
docket
for
this
ICR
under
Docket
ID
No.
OECA­
2004­
0017,
which
is
available
for
public
viewing
at
the
Enforcement
and
Compliance
Docket
and
Information
Center
in
the
EPA
Docket
Center
(
EPA/
DC),
EPA
West,
Room
B102,
1301
Constitution
Ave.,
NW,
Washington,
DC.
The
EPA
Docket
Center
Public
Reading
Room
is
open
from
8:
30
a.
m.
to
4:
30
p.
m.,
Monday
through
Friday,
excluding
legal
holidays.
The
telephone
number
for
the
Reading
Room
is
(
202)
566­
1744,
and
the
telephone
number
for
the
Enforcement
and
Compliance
Docket
is
(
202)
564­
1927).
An
electronic
version
of
the
public
docket
is
available
through
EPA
Dockets
(
EDOCKET)
at
http://
www.
epa.
gov/
edocket.
Use
EDOCKET
to
submit
or
view
public
comments,
access
the
index
listing
of
the
contents
of
the
public
docket,
and
to
access
those
documents
in
the
public
docket
that
are
available
electronically.
Once
in
the
system,
select
"
search,"
then
key
in
the
docket
ID
number
identified
above.
Also,
you
can
send
comments
to
the
Office
of
Information
and
Regulatory
Affairs,
Office
of
Management
and
Budget,
725
17th
Street,
NW,
Washington,
DC
20503,
Attention:
Desk
Office
for
EPA.
Please
include
the
EPA
Docket
ID
No.
(
OECA­
2004­
0017)
and
OMB
control
number
(
2070­
0028)
in
any
correspondence.

Part
B
of
the
Supporting
Statement
This
part
is
not
applicable
because
no
statistical
methods
were
used
in
collecting
this
information.
