SF­
83
SUPPORTING
STATEMENT
ENVIRONMENTAL
PROTECTION
AGENCY
40
CFR
PART
167
1.
Identification
of
the
Information
Collection
1(
a)
Title
of
the
Information
Collection
Application
for
Registration
of
Pesticide­
Producing
Establishments
(
EPA
Form
3540­
8);
Notification
of
Registration
of
Pesticide­
Producing
Establishments
and
Pesticide
Report
for
Pesticide­
Producing
Establishments
(
EPA
Form
3540­
16).
EPA
ICR
Number:
0160.08
1(
b)
Short
Characterization
/
Abstract
The
Federal
Insecticide,
Fungicide,
and
Rodenticide
Act
(
FIFRA)
section
7(
a)
requires
that
any
person
who
produces
pesticides
or
active
ingredients
subject
to
the
Act
must
register
with
the
Administrator
of
EPA
the
establishment
in
which
the
pesticide
is
produced.
This
section
further
requires
that
the
application
for
registration
of
any
establishment
shall
include
the
name
and
address
of
the
establishment
and
of
the
producer
who
operates
such
an
establishment.
EPA
Form
3540­
8,
Application
for
Registration
of
Pesticide­
Producing
Establishments,
is
used
to
collect
the
establishment
registration
information
required
by
this
section.

FIFRA
section
7(
c)
requires
that
any
producer
operating
an
establishment
registered
under
section
7
report
to
the
Administrator
within
30
days
after
it
is
registered,
and
annually
thereafter
by
March
1st
for
certain
pesticide/
device
production
and
sales/
distribution
information.
The
producers
must
report
which
types
and
amounts
of
pesticides,
active
ingredients,
or
devices
are
currently
being
produced,
were
produced
during
the
past
year,
sold
or
distributed
in
the
past
year.
The
supporting
regulations
at
40
CFR
Part
167
provide
the
requirements
and
time
schedules
for
submitting
production
information.
EPA
Form
3540­
16,
Pesticide
Reports
for
Pesticide­
Producing
Establishments,
is
used
to
collect
the
pesticide
production
information
required
by
section
7(
c)
of
FIFRA.

Establishment
registration
information,
collected
on
EPA
Form
3540­
8,
is
a
one­
time
requirement
for
all
pesticide­
producing
establishments.
Pesticide
production
information,
reported
on
EPA
Form
3540­
16,
is
required
to
be
submitted
within
30
days
of
receipt
of
the
Notification
of
Registration
of
Pesticide­
Producing
Establishments,
and
annually
thereafter
on
or
before
March
1.

Attached
are
copies
of:
(
1)
Forms
3540­
8
and
3540­
16;
(
2)
instructions
for
their
completion;
(
3)
section
7
of
FIFRA;
and
(
4)
40
CFR
Part
167
(
1998),
to
further
explain
the
establishment
registration
and
reporting
requirements.
­
2­

2.
Need
for
and
Use
of
the
Collection
2(
a)
Need
/
Authority
for
the
Collection
FIFRA
section
7
states
that
required
pesticide
production
information
be
reported
annually
as
required
under
regulations
(
40
CFR
167)
as
the
Administrator
may
prescribe.

2(
b)
Practical
Utility
/
Users
of
the
Data
The
purpose
of
this
reporting
requirement
is
to
obtain
pesticide
production
information.
The
EPA
requires
this
information
in
order
to
maintain
current
and
complete
records
of
the
locations
of
all
pesticide­
producing
establishments.
This
information
provides
an
overview
of
establishments
engaged
in
pesticide
activities
and
allows
the
Agency
to
target
establishments
for
inspections
with
optimal
utilization
of
limited
inspection
resources.
Such
production
information
permits
EPA
to
trace
ineffective,
contaminated,
or
otherwise
violative
products
to
their
source,
and
minimizes
any
adverse
environmental
impact
that
might
arise
from
the
production
or
distribution
of
violative
products.
If
this
information
were
not
collected
the
Agency
would
be
unable
to
meet
the
statutory
requirements
of
FIFRA.

The
Office
of
Compliance
(
OC)
in
the
Office
of
Enforcement
and
Compliance
Assurance
(
OECA)
collects
the
establishment
and
pesticide
production
information
for
compliance
purposes
and
risk
assessment.
This
information
is
used
by
EPA
Regional
pesticide
enforcement
and
compliance
staffs,
the
OC,
the
Office
of
Civil
Enforcement
(
OCE),
and
the
Office
of
Pesticide
Programs
(
OPP)
within
the
Office
of
Prevention,
Pesticides
and
Toxic
Substances
(
OPPTS),
as
well
as
the
U.
S.
Department
of
Agriculture
(
USDA),
the
Food
and
Drug
Administration
(
FDA),
other
Federal
agencies,
States
under
Cooperative
Enforcement
Agreements,
and
the
public.

EPA
Headquarters,
Regions,
and
the
States
use
the
data
for
targeting
inspection
activities,
compliance
and
outreach,
and
enforcement
actions.
Establishment
registration
and
production
data
are
used
to:
identify
where
specific
pesticides
are
made;
target
inspections
in
response
to
tips
or
complaints
of
producer
violations;
determine
where
violative
products
found
in
the
marketplace
were
produced,
thus
facilitating
recalls
of
problem
products;
facilitate
the
issuance
of
Stop
Sale,
Use,
or
Removal
Orders
for
violative
products;
help
locate
production
sites
of
canceled
or
suspended
products;
and
assist
in
notifying
producers
of
regulatory
actions
or
requirements.

3.
Nonduplication,
Consultations
and
Other
Collection
Criteria
3(
a)
Nonduplication
No
agency
besides
EPA,
nor
any
other
program
within
EPA,
requests
this
information.
The
Agency,
under
section
29
of
FIFRA,
does
collect
a
subset
of
production
data
for
conditionally
registered
pesticides
only.
However,
this
production
data
for
conditionally
registered
pesticides
does
not
fulfill
the
requirements
of
section
7
of
FIFRA.
Therefore,
no
­
3­

duplication
exists.

3(
b)
Public
Notice
Required
Prior
to
ICR
Submission
to
OMB
The
Federal
Register
notice
required
by
5
CFR
1320.8(
d)
was
published
January
26,
2005
at
70
FR
3700­
3701.

3(
c)
Consultations
Two
comments
were
received
in
response
to
the
Federal
Register
Notice.
One
comment
was
submitted
by
a
private
citizen
and
the
other
was
submitted
by
an
organization
representing
private
companies
affected
by
this
ICR.
These
comments
are
addressed
separately
below.

The
private
citizen
expressed
concern
as
to
whether
this
Information
Collection
represented
any
utility
to
the
Agency.
This
concern
is
directly
answered
in
Section
2
of
this
Supporting
Statement,
that
details
the
need
and
use
of
the
data
collected
under
this
ICR.

The
private
industry
organization
Biotechnology
Industry
Organization
(
BIO)
submitted
comments
directed
toward
the
applicability
of
this
ICR
to
plant­
incorporated
protectants
(
PIPs).
BIO
stated
that
the
provisions
of
FIFRA
section
7
are
inapplicable
to
PIPs
and
the
plants
that
produce
them,
or,
alternatively,
that
PIPs
and
the
plants
that
produce
them
should
be
excluded
from
establishment
registration
and
production
reporting
under
FIFRA
section
7.

PIPs
comprise
pesticidal
substances
produced
inside
living
plants
and
the
genetic
material
necessary
for
their
production,
and
also
any
inert
ingredients
contained
in
the
plant
or
the
produce
thereof.
EPA
regulates
PIPs
under
the
statutory
authorities
that
it
uses
to
regulate
pesticides.
See
Regulations
Under
the
Federal
Insecticide,
Fungicide,
and
Rodenticide
Act
for
Plant­
Incorporated
Protectants,
66
Fed.
Reg.
37772
(
July
19,
2001).
The
issues
raised
by
BIO
were
addressed
in
the
ICR
for
the
July
19,
2001,
PIPs
rule:
"
The
final
rule
does
not
otherwise
contain
any
new
information
collection
requirements
that
require
additional
review
and
approval
by
the
Office
of
Management
and
Budget
(
OMB)
under
the
Paperwork
Reduction
Act
(
PRA)
(
44
U.
S.
C.
3501
et
seq.)
in
accordance
with
the
procedures
at
5
CFR
1320.11.
The
clarifications
contained
in
the
final
rule
that
are
related
to
information
collection
activities
that
are
part
of
registration
activities,
e.
g.,
data
requirements
for
pesticide
registrations,
are
already
approved
by
OMB
under
the
PRA
and
that
approval
is
not
impacted
by
the
clarification
provided
in
the
final
rule.
Information
collection
activities
related
to
pesticide
registration
are
approved
under
OMB
Control
Nos.
2070­
0060,
2070­
0024,
2070­
0040."
(
EPA
ICR
#
1693.02;
OMB
Control
#
2070­
0142)."

EPA
recognizes
that
there
are
issues
associated
with
how
section
7
applies
to
PIPs
and
will
continue
working
closely
with
industry
to
address
its
concerns.
However,
as
discussed
above,
FIFRA
section
7
does
apply
to
PIPs.
EPA
has
been
regularly
receiving
registrations
of
PIP­
producing
establishments
and
has
regularly
received
reports
regarding
PIP
production.
PIP
producer
registrations
and
reports
are
part
of
the
aggregate
total
burden
estimated
by
this
ICR.
­
4­

3(
d)
Effects
of
Less
Frequent
Collection
EPA
Form
3540­
8
is
a
one­
time
requirement
for
information
used
to
register
pesticide­­
producing
establishments.
EPA
Form
3540­
16
must
be
submitted
by
all
establishments
subject
to
section
7
of
FIFRA,
30
days
after
notification
of
the
initial
assignment
of
an
establishment
registration
number,
and
thereafter
on
an
annual
basis.
The
statute
dictates
the
time
schedule
in
which
reporting
must
occur.
Therefore,
EPA
could
not
carry
out
the
requirements
of
the
statute
if
EPA
collected
such
data
on
a
less
frequent
reporting
schedule.

Additionally,
if
the
information
were
not
submitted,
the
EPA
would
be
unable
to
fulfill
its
statutory
responsibilities
relative
to
the
review
and
registration
of
pesticides
and
the
protection
of
human
health
and
the
environment.

3(
e)
General
Guidelines
None
of
the
reporting
or
record
keeping
requirements
contained
in
40
CFR
167
or
otherwise
pertinent
to
this
request
violate
any
of
the
regulations
established
by
OMB
in
5
CFR
1320.6.

3(
f)
Confidentiality
The
information
collected
on
EPA
Form
3540­
8
does
not
involve
any
confidentiality
concerns
or
sensitive
questions.
However,
pesticide
producers
must
report
certain
confidential
business
information
(
CBI)
on
EPA
Form
3540­
16,
including
the
amounts
of
pesticides
produced,
sold,
and
distributed,
under
FIFRA
section
7
requirements.
EPA
safeguards
trade
secrets
in
accordance
with
FIFRA
sections
7(
d)
and
10.
The
Agency's
copies
of
individual
firms'
reports
are
stored
in
secure
file
cabinets
within
CBI
security
areas.
Confidential
business
information
pertaining
to
specific
data
on
any
one
firm
cannot
be
released
to
the
public.

3(
g)
Sensitive
questions
This
information
collection
activity
does
not
involve
any
questions
of
a
sensitive
nature.

4.
The
Respondents
and
the
Information
Requested
4(
a)
Respondents
NAICS
Codes
Establishments
producing
pesticide
products,
pesticide
chemical
ingredients,
and
devices
are
subject
to
FIFRA.
The
six­
digit
sector/
sub­
sector
United
States
North
American
Industry
Classification
System
(
NAICS)
Codes
assigned
to
the
businesses
and
other
institutions
participating
in
this
program
include
primarily
Manufacturing,
Sectors
31­
33;
and
Agricultural,
Forestry,
Fishing
&
Hunting,
Sector
11.
­
5­

4(
b)
Information
Requested
(
i)
Data
Items
All
data
in
this
ICR
that
is
recorded
is
required
by
section
7
of
FIFRA
and
the
supporting
regulations
at
40
CFR
167.
Under
this
requirement
producers
of
pesticides
must
report
to
the
Agency
annually
the
amounts
of
pesticides
produced,
repackaged,
relabeled;
the
amount
sold
or
distributed
in
U.
S.
markets;
the
amount
sold
or
distributed
in
Foreign
markets;
and
the
amount
anticipated
to
be
produced
in
the
following
year.

(
ii)
Respondent
Activities
S
Read
instructions
(
provided
with
each
EPA
Form)

S
Plan
the
reporting
activity
S
Gather
information
S
Plan
and
review
information
for
accuracy
S
Store,
file
and
maintain
the
information
During
the
course
of
normal
business
operations,
a
producer
would
plan
and
maintain
the
information
required
to
comply
with
this
information
collection
activity,
arrange
for
the
collection,
review
the
information
for
accuracy,
and
arrange
to
maintain
or
store
the
information.
The
information
required
to
be
reported
is
information
that
the
producer
would
generally
maintain
as
prudent
business
practices.
The
Agency
does
not
specify
in
the
regulation
how
the
data
to
be
gathered
must
be
organized,
however,
the
Agency
does
supply
a
reporting
form
which
provides
for
the
reporting
of
the
required
information
in
a
consistent
manner.

5.
The
Information
Collected
 
Agency
Activities,
Collection
Methodology,
and
Information
Management
5(
a)
Agency
Activities
In
this
collection
the
Agency
will:
1)
answer
companies'
and
producers'
questions;
2)
will
review
the
data
collected;
3)
provide
appropriate
protection
of
confidential
business
information;
and
4)
store
collected
data
both
electronically
and
in
paper
file
system.

5(
b)
Collection
Methodology
and
Management
Producers
determine
how
to
best
comply
with
the
requirements
for
record
keeping
under
FIFRA
section
7.
They
may
collect
and
store
the
required
data
electronically
or
by
paper
copy.

The
Agency
in
turn
annually
provides
forms
for
pesticide­
producing
establishments
to
report
their
collected
and
stored
information.

5(
c)
Small
Entity
Flexibility
­
6­

The
information
collected
under
this
ICR
does
not
significantly
impact
small
businesses,
since
the
information
being
reported
is
that
which
their
records
would
be
considered
as
"
customary
and
usual
business
activities."
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
record
keeping
and
reporting
requirements
are
the
same
for
small
and
large
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
The
collection
schedule
established
in
the
regulations
at
40
CFR
167.85(
d)
requires
that
each
producer
report
pesticide
production
information
within
30
days
of
receipt
of
the
Notification
of
assignment
of
their
establishment
number
(
EPA
Form
3540­
8A)
from
the
Agency;
thereafter,
each
produced
is
required
to
report
their
pesticide
production
information
by
March
1st
annually.
The
Agency
normally
mails
out
reporting
forms
each
December
in
order
to
provide
enough
time
for
producers
to
comply
with
the
reporting
requirements
by
the
March
1
date.

6.
Estimating
the
Burden
and
Cost
of
the
Collection
6(
a)
Estimating
Respondent
Burden
The
estimates
for
EPA
Form
3540­
8
are
based
on
discussions
with
the
industry.
The
onetime
submission
of
information
is
of
such
a
nature
as
to
demand
no
research
of
company
records
or
calculations;
it
is
easily
completed
by
clerical
personnel
and
reviewed
and
signed
by
a
company
officer.
The
completion
of
the
application
rarely
exceeds
the
estimated
hourly
rate.
See
Table
1
for
respondent
burden
estimates.

Burden
estimates
for
EPA
Form
3540­
16
are
based
on
the
results
of
interviews
with
a
cross­
section
of
industry
respondents.
We
asked
six
industry
representatives
of
the
respondent
universe
­­
small
businesses,
firms
with
multiple
establishments,
and
repackagers
­­
to
estimate
the
amount
of
time
they
typically
spent
gathering,
compiling,
and
filling
out
information
for
the
report.

From
these
interviews
we
learned
that,
generally,
the
information
is
already
assembled
and
compiled
so
filling
out
the
form
involves
little
burden.
See
Table
2
for
the
respondent
burden
estimates
for
EPA
Form
3540­
16.

6(
b)
Estimating
Respondent
Costs
(
i)
Estimating
Labor
Costs
Since
the
regulation
and
associated
information
collection
has
a
minor
economic
impact
on
respondents,
a
regulatory
impact
analysis
was
not
conducted..
This
ICR
uses
estimates
of
labor
rates
and
associated
costs
based
on
Department
of
Commerce
Bureau
of
Labor
Statistics
­
7­

estimates.
Specifically
this
ICR
uses
the
November,
2003
National
Industry­
Specific
Occupational
Employment
and
Wage
Estimates
for
the
industry
NAICS
code
325300
(
Pesticide,
Fertilizer
and
other
Agricultural
Chemical
Manufacturing,
which
is
presumed
to
dominate
this
sector.
Although
the
NAICS
code
115100
also
applies
to
this
ICR,
but
since
the
sector
115100
wage
estimates
are
slightly
lower
than
sector
325300,
this
ICR
errs
on
the
side
of
overestimating
wage
costs.).
The
mean
hourly
wage
rates
for
NAICS
code
325300
were:
management,
$
45.25;
technical
(
engineering),
$
32.22;
and
clerical
(
administrative),
$
15.24.
A
factor
of
1.10
was
added
to
adjust
for
benefit
costs,
and
an
additional
inflation
factor
of
1.05
was
included
(
from
the
CPI
calculator
located
at
the
Department
of
Commerce
web
site.)
with
respective
total
wage
costs
of
$
99.78,
$
71.05,
and
$
33.60.

Application
for
Registration
of
Pesticide­
Producing
Establishments
(
EPA
Form
3540­
8):

Public
reporting
burden
for
this
collection
of
information
is
estimated
to
average
0.30
hours
(
18
minutes)
per
response,
including
time
for
reviewing
instructions,
searching
existing
data
sources,
gathering
and
maintaining
the
data
needed,
and
completing
the
review
and
collection
of
information.

Notification
of
Registration
of
Pesticide­
Producing
Establishments
(
EPA
Form
3540­
8A):

There
is
no
public
reporting
burden
for
this
information.

Pesticide
Report
for
Pesticide­
Producing
Establishments
(
EPA
Form
3540­
16)

Public
reporting
burden
for
this
collection
of
information
is
estimated
to
average
1.43
hour
(
1
hour
and
26
minutes)
per
response,
including
time
for
reviewing
instructions,
searching
existing
data
sources,
gathering
and
maintaining
the
data
needed,
and
completing
the
review
and
collection
of
information.

See
Tables
1
and
2
for
the
respondent
cost
estimates
for
EPA
Forms
3540­
8
and
3540­
16,
respectively.
There
is
no
cost
to
the
respondent
for
EPA
Form
3540­
8A.

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

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

6(
c)
Estimate
of
Agency
Burden
and
Costs
The
costs
to
the
Government
for
the
Application
for
Registration
of
Pesticide­
Producing
Establishments
(
EPA
Form
3540­
8),
and
the
Notification
of
Registration
of
Pesticide­
Producing
­
8­

Establishments
(
EPA
Form
3540­
8A)
are
based
on
one
work­
year
to
review
and
process
applications.
Other
direct
costs
are
limited
to
printing
costs
for
instructions
and
reporting
forms,
review
of
the
data,
mailing
costs,
etc.
The
number
of
respondents
(
700)
are
estimated
based
on
the
average
annual
number
of
applicants
registering
establishments
over
past
three
year
periods.
See
Table
3
for
Agency
burden
and
cost
estimates.

The
costs
to
the
Government
for
the
Pesticide
Report
for
Pesticide­
Producing
Establishments
(
EPA
Form
3540­
16)
is
based
on
one
work­
year
to
review
and
process
production
reports.
Other
direct
costs
are
limited
to
printing
costs
for
instructions
and
reporting
forms.
The
number
of
respondents
is
the
number
of
active
pesticide­
producing
establishments
registered
with
EPA
(
13,000)
See
Table
4
for
Agency
burden
and
cost
estimates.

This
ICR
consolidated
all
government
labor
costs
to
that
of
a
GS­
13
step
1,
as
the
bulk
of
the
work
is
performed
at
this
level.
The
minor
shares
of
burden
carried
by
management
and
clerical
staff
have
been
judged
approximately
equal
and
thus
balance
out
if
the
entire
burden
is
estimated
at
the
GS­
13/
1
level.

The
estimates
for
Agency
costs
for
EPA
Forms
3540­
8,
3540­
8A,
and
3540­
16
are
shown
in
Tables
3
and
4,
respectively.

6(
d)
Estimating
the
Respondents
Universe
and
Total
Burden
and
Costs
As
of
December,
2004,
there
were
13,000
active
pesticide­
producing
establishments
registered
with
EPA.
While
the
actual
number
of
registered
establishments
fluctuates
somewhat,
the
average
over
the
past
three
year
period
has
appeared
to
stabilize
approximately
at
the
present
level.
For
purposes
of
this
ICR,
EPA
assumes
that
the
number
of
newly­
registered
establishments
in
any
period
of
time
will
approximately
equal
the
number
of
currently
registered
establishments
going
out
of
business.
The
total
annual
labor
costs
are
$
14,021
+
$
1,226,940
=
$
1,240,961.
Details
upon
which
this
estimate
is
based
appear
in
Tables
1
&
2:
Respondent
Burden.
­
9­

6(
e)
Bottom
Line
Burden
Hours
and
Cost
Tables
Table
1
Respondent
Burden
Hours
and
Costs
for
Application
for
Registration
of
Pesticide­
Producing
Establishments
(
EPA
Form
3540­
8)

ACTIVITIES
ANNUAL
BURDEN
HOURS
TOTAL
HOURS
TOTAL
COST
$
Mgmt
Tech
Cler
$
100
$
71
$
34
a.
Read
or
Hear
Any
Instructions
14
21
0
35
$
2,891
b.
Plan
Activities
0
0
0
0
$
0
c.
Create
Information
0
0
0
0
$
0
d.
Gather
Information
0
0
0
0
$
0
e.
Process,
Compile,
and
Review
the
Information
0
35
0
35
$
2,485
f.
Complete
Written
Form(
s)
0
70
0
70
$
4,970
g.
Record,
Disclose,
Display,
or
Report
the
Information
0
35
0
35
$
2,485
h.
Store,
File,
or
Maintain
the
Information
0
0
35
35
$
1,190
TOTAL
14
161
35
210
$
14,021
Annual
Burden
Hour
total
=
210*
Annual
Cost
total
=
$
14,021*

*
assumes
700
responses
annually
***
NOTE:
Numbers
in
the
Tables
(
1­
4)
may
vary
slightly
because
of
a
rounding
factor.
­
10­

Table
2
Respondent
Burden
Hours
and
Costs
for
Pesticide
Report
for
Pesticide­
Producing
Establishments
(
EPA
Form
3540­
16)

ACTIVITIES
ANNUAL
BURDEN
HOURS
TOTAL
HOURS
TOTAL
COST
$
Mgmt
Tech
Cler
$
100
$
71
$
34
a.
Read
or
Hear
Any
Instructions
1300
1950
0
3250
$
268,450
b.
Plan
Activities
1300
1950
0
3250
$
268,450
c.
Create
Information
0
0
0
0
$
0
d.
Gather
Information
0
2080
0
2080
$
147,680
e.
Process,
Compile,
and
Review
the
Information
0
2210
0
2210
$
156,910
f.
Complete
Written
Form(
s)
0
3250
0
3250
$
230,750
g.
Photocopying
Form(
s)
0
0
1300
1300
$
44,200
h.
Record,
Disclose,
Display,
or
Report
the
Information
0
0
2210
2210
$
75,140
i.
Store,
File,
or
Maintain
the
Information
0
0
1040
1040
$
35,360
TOTAL
2600
11440
4550
18590
$
1,226,940
Annual
Burden
Hour
total
=
18,590*
Annual
Cost
total
=
$
1,226,940*

*
assumes
13,000
responses
annually
***
NOTE:
Numbers
in
the
Tables
(
1­
4)
may
vary
slightly
because
of
a
rounding
factor.
­
11­

Table
3
Annual
Agency
Burden/
Cost
Estimates
for
Application
and
Notification
for
Pesticide­
Producing
Establishments
(
EPA
Form
3540­
8
and
EPA
Form
3540­
8A)

ACTIVITIES
ANNUAL
BURDEN
HOURS
TOTAL
COSTS
$

a.
Preparation
for
Printing
of
Reporting
Forms
and
Instructions
90
$
6,772
b.
Respond
to
Inquiries
1120
$
84,269
c.
Review
Information
for
Accuracy
520
$
39,125
d.
Record
Form
Submission
and
Assign
Establishment
Number
185
$
13,919
e.
Store
and
Maintain
Data
140
$
10,534
f.
Prepare
Notification
195
$
14,672
TOTAL
2330
$
175,309
Other
Annual
Agency
Costs*
associated
with
Table
3:

1.
Printing
of
Reporting
Forms
and
Instructions.
.
.
.
.
$
1,166
2.
Purchase
Cost
of
Mailing
Envelopes.
.
.
.
.
.
.
.
.
.
$
117
3.
Postal
Mailing
Costs.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
$
408
Other
Annual
Total
Costs
.
.
.
.
.
.
.
$
1,691
*
Other
Agency
Annual
Costs
were
estimated
by
adjusting
the
previous
ICR
for
number
of
respondents
and
inflation.

Burden
Cost
+
Other
costs
are:
$
175,309
+
$
1,691
=
$
177,000
***
NOTE:
Numbers
in
the
Tables
(
1­
4)
may
vary
slightly
because
of
a
rounding
factor.
­
12­

Table
4.
Annual
Agency
Burden
Cost
Estimates
for
Pesticide
Report
for
Pesticide­
Producing
Establishments
(
EPA
Form
3540­
16)

ACTIVITIES
ANNUAL
BURDEN
HOURS
ANNUAL
COST
a.
Preparation
for
Printing
of
Reporting
Forms
and
Instructions
90
$
6,772
b.
Respond
to
Inquiries
1375
$
103,455
c.
Review
Information
for
Accuracy
1050
$
79,002
d.
Record
and
Enter
Data
into
Electronic
Database
1060
$
79,754
e.
Store
and
Maintain
Data
430
$
32,353
f.
Prepare
Annual
Solicitation/
Mailings
130
$
9,781
TOTAL
4135
$
311,117
Other
Annual
Agency
Costs
associated
with
Table
4:

1.
Printing
of
Report
Form
and
Instructions.
.
.
.
.
.
.
$
1,160
2.
Mailing
Envelope
Costs.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
$
1,391
3.
Postage
Mailing
Costs
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
$
17,388
Other
Annual
Agency
Costs
.
.
.
.
.
.
$
19,939
Burden
Cost
+
Other
Costs
are:
$
311,117
+
$
19,939
=
$
331,056
*
Other
Agency
Annual
Costs
were
estimated
by
adjusting
the
previous
ICR
for
number
of
respondents
and
inflation.

$
177,000
(
Table
#
3)
+
$
331,056
(
Table
#
4)
=
$
508,056
COMBINED
AGENCY
BURDEN
COSTS
FOR
THIS
ICR
=
$
508,056
***
NOTE:
Numbers
in
the
Tables
(
1­
4)
may
vary
slightly
because
of
a
rounding
factor.

6(
f)
Program
Changes
and
Adjustments
­
13­

No
program
changes
occurred
affecting
the
burden
estimates
of
this
ICR.
Adjustments
to
the
burden
estimates
per
response
resulted
from
(
1)
adjustments
in
the
salary
computation
for
industry
to
reflect
current
wage
scales,
(
2)
adjustments
in
the
salary
computation
for
Agency
personnel
to
reflect
current
wage
scales,
(
3)
adjustments
for
inflation,
and
(
4)
adjustment
to
the
number
of
respondents.

6(
g)
Burden
Statement
The
annual
public
reporting
and
recordkeeping
burden
for
this
collection
of
information
is
estimated
to
average
1.45
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
0053,
which
is
available
for
public
viewing
at
the
Enforcement
and
Compliance
Docket
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
0053)
and
OMB
control
number
(
2070­
0078)
in
any
correspondence.

Part
B
of
the
Supporting
Statement
This
part
is
not
applicable
to
this
collection.
