Draft
for
Public
Comment
December
2003
Page
1
of
16
Supporting
Statement
for
an
Information
Collection
Request
1.
Identification
of
the
Information
Collection
1(
a)
Title
of
the
Information
Collection
Request
to
State
Governments
for
Ecological
Incident
Reports
OMB
No.
2070­
TBD
EPA
No.
2135.01
1(
b)
Short
Characterization/
Abstract
This
proposed
data
collection
program
is
designed
to
provide
the
Environmental
Protection
Agency
(
EPA)
with
data
on
bird
kills,
fish
kills,
and
other
nonhuman
animal
incidents
caused
by
pesticide
poisoning
("
ecological
incidents").
In
addition,
incidents
which
occur
to
plant
species
via
spray
drift
from
pesticides
will
be
collected.
The
Environmental
Fate
and
Effects
Division
(
EFED)
of
the
Office
of
Pesticide
Programs
(
OPP)
will
request
these
data
from
state
government
agencies
that
are
involved
in
investigating
and
writing
reports
on
such
incidents.
The
request
will
be
made
through
an
initial
letter
and
follow­
up
phone
call
the
first
year,
followed
by
an
annual
reminder
letter
or
phone
call
thereafter.
When
incident
reports
are
received,
EFED
will
extract
data
from
the
incident
reports
and
enter
them
into
the
Ecological
Incident
Information
System
(
EIIS),
a
national
database
of
ecological
incidents,
for
use
by
the
staff
of
OPP.
These
data
provide
important
information
on
the
field
effects
of
pesticides
that
would
help
OPP
conduct
better
ecological
risk
assessments
and
make
more
informed
decisions
for
regulation
of
pesticides.
The
annual
data
collection
would
provide
us
with
more
complete
coverage
of
ecological
incidents,
thereby
reducing
bias
associated
with
use
of
sparse
and
unevenly
reported
incident
data.
Ultimately,
collection
of
these
data
would
improve
our
capability
for
comparing
ecological
risks
among
pesticides
as
well
as
for
conducting
ecological
risk
assessments
for
individual
chemicals.

2.
Need
for
and
Use
of
the
Collection
2(
a)
Need/
Authority
for
the
Collection
A
primary
responsibility
of
EFED
is
to
conduct
ecological
risk
assessments
on
uses
of
pesticides.
A
typical
ecological
risk
assessment
includes
a
review
of
the
available
toxicity
data
for
aquatic
(
invertebrates
and
at
least
two
species
of
fish)
and
terrestrial
organisms
(
at
least
two
species
of
birds),
plants
and
mammals
as
well
as
an
assessment
of
the
exposure.
The
exposure
can
be
derived
from
modeling
and/
or
actual
field
monitoring
data.
When
there
are
available
ecological
incident
data,
based
on
the
circumstances
under
which
the
incident
occurred,
the
data
may
very
well
be
confirmatory
or
may
identify
risks
that
had
not
been
predicted
in
EPA's
risk
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assessment.
An
example
of
where
the
incident
data
identified
risk
to
terrestrial
species
but
was
not
observed
in
the
laboratory
studies
was
when
EPA
was
reviewing
dimethoate
data.
Based
on
the
avian
acute
and
dietary
studies,
it
appeared
there
was
not
a
significant
risk
to
avian
species.
However,
based
on
incident
data
reported
by
the
US
Fish
and
Wildlife
Service
(
USFWS)
and
the
state
of
Idaho,
there
was
a
high
incidence
of
sage
grouse
mortality.
After
discussion
with
the
EPA
Corvallis
Laboratory
and
the
USFWS,
it
was
determined
that
based
on
the
unusual
feeding
habits
of
the
juvenile
sage
grouse,
there
was
higher
than
estimated
exposure
within
EPA's
original
risk
assessment.
Therefore,
incident
data
not
only
increases
the
robustness
of
the
risk
assessments,
but
it
also
bolsters
the
validity
of
the
assessment.

Ultimately,
EPA
characterizes
the
level
of
risk
of
current
and
proposed
pesticide
uses
to
fish,
wildlife,
and
nontarget
plants.
The
ecological
risk
assessments
produced
by
EFED
are
used
by
the
Registration
Division
(
RD)
and
the
Special
Review
and
Reregistration
Division
(
SRRD)
to
make
regulatory
decisions
under
the
authority
of
the
Federal
Insecticide,
Fungicide,
and
Rodenticide
Act
(
FIFRA)
and
amendments.
EFED
assesses
risks
of
pesticides
by
evaluating
toxicity
data
and
modeling
of
exposure,
and
by
monitoring
actual
observed
adverse
effects
from
current
use.
Ecological
incidents
represent
the
primary
source
of
information
on
actual
field
effects
of
pesticides
to
fish
and
wildlife.
This
information
is
therefore
critical
for
EFED
to
perform
its
core
responsibility
of
assessing
ecological
risks
of
pesticides
to
nontarget
species.

Ecological
incidents
are
investigated
by
state
government
agencies
(
e.
g.,
state
departments
of
agriculture,
state
departments
of
natural
resources,
or
state
fish
and
game
departments).
However,
the
states
are
not
required
to
inform
the
EPA
of
these
ecological
incidents.
Currently,
many
of
these
incidents
are
never
reported
to
the
EPA,
not
entered
into
our
database,
and
therefore
are
not
included
in
the
risk
assessment
process.
Many
of
the
state
agencies
are
not
even
aware
of
our
need
for
incident
reports.
Furthermore,
most
of
the
ecological
incidents
are
not
reported
to
EPA
under
FIFRA
6(
a)(
2)
regulations
because
the
state
agencies
typically
do
not
inform
the
pesticide
registrants
when
they
determine
that
a
product
caused
an
incident,
and
the
pesticide
registrants
are
not
required
to
seek
out
this
information
from
the
states.
Even
when
the
registrants
do
become
aware
of
these
incidents,
they
report
the
information
second
hand
and
often
only
report
a
summary
of
the
events,
without
the
details
which
would
be
contained
in
the
investigatory
reports
from
the
states.
Therefore,
EPA
needs
to
ask
these
state
agencies
to
voluntarily
submit
their
incident
reports.

FIFRA
provides
the
authority
for
EPA
to
collect
information
on
adverse
field
effects
of
pesticides
to
nontarget
animals
and
plants.
Section
20(
c)
provides
authority
to
undertake
"
monitoring
of
man
and
animal
and
their
environment
for
incidental
pesticide
exposure,
including,
but
not
limited
to,
the
quantification
of
incidental
human
and
environmental
pesticide
pollution
and
the
secular
trends
thereof,
and
identification
of
the
sources
of
contamination
and
their
relationship
to
humans
and
environmental
effects."
Collection
of
incident
data
is
a
type
of
monitoring
for
incidental
pesticide
exposure
and
effects
to
nontarget
plants
and
animals.
These
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2003
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reports
identify
effects
to
the
environment
and
the
source
of
the
pesticide
contamination.
This
same
section
of
FIFRA
further
states
that
"
such
activities
shall
be
carried
out
in
cooperation
with
other
Federal,
State,
and
local
agencies."
Section
22(
b)
also
gives
authority
for
EPA
to
cooperate
with
"
any
appropriate
agency
of
any
State
or
political
subdivision
thereof"
in
carrying
out
the
provisions
of
the
Act.

2(
b)
Practical
Utility/
Users
of
the
Data
Data
extracted
from
the
incident
reports
obtained
through
this
ICR
will
be
entered
into
the
EIIS
database
and
utilized
in
a
manner
consistent
with
EPA's
Information
Quality
Guidelines.
Recognizing
the
importance
of
ecological
incidents
in
risk
assessments,
EFED
created
the
EIIS
database
to
allow
its
scientists
easy
access
to
information
on
ecological
incidents
caused
by
pesticides
that
have
occurred
throughout
the
country.
Scientists
routinely
use
this
database
to
identify
incidents
related
to
exposure
to
the
pesticides
they
are
reviewing.
They
incorporate
a
discussion
of
the
ecological
incidents
into
the
risk
assessment
review
documents,
including
chapters
for
Reregistration
Eligibility
Decisions
(
REDs)
and
New
Chemical
Reviews.
The
scientists
rely
on
this
database
as
their
primary
source
of
information
on
ecological
incidents.
Maintaining
the
database
with
current
and
accurate
information
is
therefore
critical
for
the
division.

Incident
data
in
the
EIIS
database
are
also
used
by
various
other
parties
inside
and
outside
EPA.
OPP
uses
the
data
to
assess
trends
in
pesticide
impacts
over
time
and
to
evaluate
changes
in
the
magnitude
of
adverse
ecological
effects
following
regulatory
restrictions
or
implementation
of
risk
mitigation
measures.
Ecological
incident
data
are
the
basis
for
environmental
indicators
used
to
monitor
the
performance
of
the
program
at
protecting
fish
and
wildlife
resources
from
pesticide
pollution,
and
are
the
basis
for
an
indicator
that
is
being
included
in
the
State
of
the
Environment
Report.
RD
and
SRRD
use
incident
data
in
EIIS
for
comparative
analysis
and
other
special
projects
concerning
evaluation
of
ecological
risks
of
pesticide
uses.
The
Field
and
External
Affairs
Division
also
uses
data
in
EIIS
for
assessing
ecological
risk
of
pesticides
to
threatened
and
endangered
species.
Finally,
information
from
this
database
is
supplied
to
various
outside
government
agencies
and
nongovernment
organizations
(
NGO's)
that
are
interested
in
identifying
the
frequency
of
ecological
incidents
associated
with
pesticides.
This
information
could
be
provided
in
the
form
of
an
annual
report
that
can
be
made
available
to
the
public
on
the
EPA
web
site.
Such
information
would
help
the
public
make
informed
decisions
on
choosing
safer
pesticides.

An
example
of
how
ecological
incident
reports
have
been
used
in
the
past
is
with
the
case
of
Swainson
Hawk
mortalities
in
Argentina
in
1996.
US
academicians
were
tracking
the
migration
of
Swainson
hawks
from
South
America
to
the
United
States
when
it
was
discovered
there
were
significant
die
offs
(
thousands
of
birds)
occurring
in
Argentina.
After
investigation,
it
was
discovered
that
these
birds
were
dying
after
exposure
to
grasshoppers
(
primary
food
source
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of
this
species)
feeding
on
alfalfa
treated
with
monocrotophos.
Through
negotiations
with
international
governments,
NGO's
and
private
industry,
changes
in
agricultural
practices,
and
restriction
of
this
pesticide
in
the
Swainson
Hawk
roosting
sites,
the
mortalities
had
significantly
decreased.

3.
Non
duplication,
Consultations,
and
Other
Collection
Criteria
3(
a)
Non
duplication
The
only
government
activity
we
are
aware
of
in
which
a
federal
office
contacts
state
governments
to
collect
data
on
ecological
incidents
is
done
by
the
EPA
Region
V
Office.
That
office
collects
incident
information
from
the
six
states
within
their
region.
The
Office
of
Pesticide
Programs,
working
through
the
Field
and
External
Affairs
Division
(
FEAD),
will
coordinate
efforts
with
the
regional
offices
to
ensure
that
there
is
no
duplication
of
effort
in
this
information
collection
with
EPA
regional
offices.
We
will
check
with
each
region
to
determine
if
they
are
contacting
state
agencies
to
request
incident
information.
When
the
regional
office
does
request
this
information,
we
will
not
contact
the
state
agencies
in
that
region,
but
rather
will
request
that
the
regional
office
pass
the
information
that
they
obtain
on
to
OPP.
Such
arrangement
has
already
been
established
with
Region
V.
The
US
Fish
and
Wildlife
Service
and
the
US
Geological
Survey
maintain
collections
of
information
on
ecological
incidents,
but
neither
agency
has
a
program
to
systematically
collect
incident
reports
generated
by
state
agencies.

Some
ecological
incident
data
are
reported
to
EPA
by
the
registrant
under
section
6(
a)(
2)
of
FIFRA.
The
collection
of
incident
information
being
requested
in
this
ICR,
however,
is
very
different
from
the
collection
done
under
FIFRA
Section
6(
a)(
2).
The
6(
a)(
2)
regulation
obligates
pesticide
product
registrants
to
submit
adverse
effects
information,
including
reports
of
incidents
associated
with
the
use
of
their
registered
product.
It
does
not
require
state
agencies
to
submit
any
information
about
incidents
they
investigate.
Since
the
state
agencies
and
pesticide
registrants
often
do
not
communicate
about
these
incidents,
the
pesticide
registrants
are
often
unaware
of
these
incidents,
and
therefore
the
incidents
often
do
not
get
reported
through
the
6(
a)(
2)
process.
Furthermore,
as
the
pesticide
registrants
are
not
obligated
to
investigate
such
incidents
themselves,
they
often
only
provide
a
brief
summary
of
the
incident
based
on
second­
hand
information.
When
state
agencies
investigate
incidents,
however,
they
normally
produce
a
detailed
report
that
provides
much
more
thorough
information
than
is
generally
obtained
from
6(
a)(
2)
reports.
Thus,
on
the
occasion
when
the
pesticide
registrant
does
report
on
an
incident
through
the
6(
a)(
2)
process,
EPA
still
desires
to
obtain
the
investigatory
report
from
the
state
to
get
complete
information
about
the
incident.
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December
2003
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3(
b)
Public
Notice
Required
Prior
to
ICR
submission
to
OMB
Prior
to
submission
to
OMB,
this
ICR
will
be
made
available
to
the
public
for
comment
through
a
Federal
Register
notice.
The
public
will
have
60
days
to
provide
comments.
Any
comments
received
will
be
given
consideration
when
completing
the
supporting
statement
that
is
submitted
to
OMB.

3(
c)
Consultations
EPA
staff
sent
letters
to
nine
state
government
departments
asking
them
to
assess
the
burden
that
this
data
collection
would
impose
on
them.
Letters
were
sent
to
the
following
persons:

Mr.
Linda
Coulter,
Chief
Pesticide
Section
Colorado
Department
of
Agriculture
Denver,
CO
80203
Mr.
William
Ossman,
Chief
Plant
Health
Division
Kansas
Department
of
Agriculture
Topeka,
KS
66612
Mr.
William
Stansley,
Wildlife
Toxicologist
Freshwater
Fisheries
Lab
Department
of
Environmental
Protection
State
of
New
Jersey
Trenton,
NJ
Mr.
Jim
Johnson,
Assistant
Administrator
of
Enforcement
Division
of
Wildlife
Ohio
Department
of
Natural
Resources
Columbus,
OH
43209
Mr.
Cliff
Weed,
Program
Manager
Pesticide
Management
Division
Compliance
Section
Washington
Department
of
Agriculture
Olympia,
WA
Dr.
Wayne
Faatz
Contaminates
Program
Manager
Department
of
Natural
Resources
State
of
Indiana
Indianapolis,
IN
Mr.
Sean
Strom
Wildlife
Management
Program
Department
of
Natural
Resources
State
of
Wisconsin
Madison,
WI
Mr.
Robert
Hosea,
Environmental
Specialist
Department
of
Fish
and
Game
Pesticide
Investigation
Unit
State
of
California
Sacramento,
CA
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December
2003
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16
Mr.
Mary
Ellen
Mr.
,
Chief
Pesticide
Regulations
Office
of
Plant
Industries
&
Pest
Management
Maryland
Department
of
Agriculture
Annapolis,
MD
EPA
received
only
three
responses
to
our
request
for
assistance.
Mr.
Johnson
of
the
Ohio
Department
of
Natural
Resources
and
Dr.
Faatz
of
the
Indiana
Department
of
Natural
Resources
returned
the
form
that
we
enclosed
with
the
letter.
Mr.
Johnson
said
that
his
department
would
have
approximately
two
incidents
to
report
per
year.
He
estimated
sending
us
these
incidents
would
require
0.5
hours
of
managerial
time
and
1.4
hours
of
clerical
time,
and
estimated
the
costs
of
labor
and
postage
to
be
$
31.00
per
year.
Dr.
Faatz
estimated
that
he
would
have
3­
4
incidents
to
report
per
year.
He
estimated
sending
us
these
incidents
would
require
a
total
of
three
hours
of
technical
time
at
a
total
salary
cost
of
$
35
per
year.
He
did
not
estimate
any
other
associated
costs.

Ms.
Katherine
Matherly
of
the
Washington
Department
of
Agriculture
did
not
return
the
form
but
instead
responded
with
a
letter.
Mr.
Matherly
estimated
that
they
would
have
approximately
250
cases
to
report.
She
gave
a
"
worst­
case"
estimate
of
$
750
per
year
based
on
their
fee
of
$
0.15
per
page
and
the
worst­
case
scenario
of
each
report
being
20
pages
long.
In
a
follow­
up
telephone
call
made
by
EPA
to
Ms.
Matherly,
she
revealed
that
a
summary
report
would
be
available
(
Report
"
B")
that
would
provide
sufficient
information
for
our
purposes.
Assuming
an
average
of
three
pages
per
summary
report,
the
total
cost
for
sending
just
the
summary
reports
would
be
$
112.50
per
year.
Ms.
Matherly
also
stated
that
almost
all
of
the
reports
were
complaints
of
crop
damage,
whereas
one
or
two
reports
per
year
involve
adverse
effects
to
fish
or
wildlife.
Submitting
summary
reports
only
for
the
fish
and
wildlife
incidents
would
therefore
accrue
a
cost
of
only
$
0.45
to
$
0.90
per
year.
Because
of
this
response,
we
decided
to
restrict
our
request
for
incident
reports
to
fish
and
wildlife
incidents
and
to
exclude
crop
damage
and
other
plant
incidents
not
associated
with
spray
drift.
However,
EPA
does
believe
it
is
cost
effective
to
continue
to
receive
reports
of
incidents
that
have
occurred
as
a
result
from
spray
drift
to
nontarget
plants.

Crop
damage
can
also
occur
from
plants
being
intentionally
sprayed
to
control
a
certain
insect
or
plant
disease.
These
types
of
incidents
are
generally
reported
to
the
pesticide
registrant
and
the
grower
is
subsidized
for
the
damage.
The
crop
damage
that
occurs
from
spray
drift
often
cannot
be
proven,
and
most
often
the
grower
can
lose
significant
income
as
a
result.
EFED
does
not
assess
damage
to
crops
that
are
intentionally
sprayed
as
a
mechanism
of
control;
that
is
more
of
an
efficacy
question
and
is
addressed
by
OPP's
Registration
Division.
EFED
only
gets
involved
if
phytotoxicity
occurs
to
nontarget
plants
from
spray
drift.
Draft
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Public
Comment
December
2003
Page
7
of
16
State
agencies
may
submit
the
incident
information
in
electronic
format
(
PDF,
TIFF,
WordPerfect,
Word,
etc.).
If
the
data
are
submitted
electronically,
then
EPA
expects
that
the
costs
would
be
significantly
lower.

3(
d)
Effects
of
Less
Frequent
Collection
EPA
is
requesting
incident
reports
to
be
submitted
at
least
once
per
quarter,
but
would
be
willing
to
accept
incident
reports
to
be
submitted
annually
if
the
state
agency
would
prefer.
More
frequent
reporting
would
benefit
OPP
by
providing
more
current
information
on
the
adverse
field
effects
of
pesticides.
Also,
OPP
may
need
to
conduct
an
unscheduled
review
of
pesticide
products
in
response
to
particularly
large
or
frequent
incidents.
One
example
of
where
EPA
has
responded
to
a
particularly
large
series
of
fish
kill
incidents
(
hundreds
of
incidents
involving
thousands
of
fish)
occurring
in
one
location
was
the
use
of
azinphos
methyl
on
sugarcane
in
Louisiana
in
1991.
As
a
result
of
the
reporting
and
through
negotiations
with
private
industry
and
the
state
agencies
involved,
EPA
implemented
risk
mitigation
measures
(
i.
e.,
registered
safer
pesticides,
limited
application
to
prescription
use
only,
etc.).
Thereby
reducing
the
number
of
fish
kills
every
year
until
1995,
when
no
more
fish
kills
were
observed
or
reported.
Submitting
reports
less
frequently
than
once
per
year
is
considered
inadequate
for
meeting
the
Office's
information
needs
on
ecological
incidents,
to
ensure
a
systematic
risk
assessment
processes.

3(
e)
General
Guidelines
This
ICR
does
not
include
any
third
party
burden.

Collection
of
data
through
this
ICR
may
be
made
through
electronic
submission
of
data.
Incident
reports
may
be
submitted
electronically
through
e­
mail
in
the
form
of
a
word
processing
document,
a
portable
document
format
(
PDF),
or
an
image
file.
Submission
through
fax
is
also
acceptable.

3(
f)
Confidentiality
Reports
on
adverse
field
effects
caused
by
pesticides
generally
do
not
include
confidential
business
information.
If
an
agency
does
submit
information
that
could
be
considered
confidential,
such
as
information
that
might
suggest
inert
ingredients
contained
in
a
product,
this
information
will
be
protected
according
to
FIFRA
regulations.
Such
data
submitted
to
the
EPA
are
handled
strictly
in
accordance
with
provisions
of
the
FIFRA
Confidential
Business
Security
Manual.
This
manual
contains
instructions
relative
to
all
contact
with
confidential
documents
including:
responsibilities
of
EPA
employees
physical
security
measures;
CBI
copying
and
destruction
procedures;
transfer
of
CBI
materials
within
the
EPA
to
contractors
or
other
government
offices;
computer
security;
CBI
typing
procedures;
and
procedures
internal
to
OPP.
The
manual
dictates
that
all
CBI
must
be
kept
in
secure
(
double­
locked)
areas,
and
all
CBI
intended
to
be
destroyed
Draft
for
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Comment
December
2003
Page
8
of
16
must
be
cleared
by
a
Document
Control
Officer
and
shredded.

3(
g)
Sensitive
Questions
No
information
of
a
sensitive
or
private
nature
is
requested
in
conjunction
with
this
collection
activity.
The
state
agencies
will
be
asked
to
exclude
or
sanitize
information
that
is
private
or
sensitive,
such
as
private
citizens'
home
phone
numbers
or
social
security
numbers.

4.
The
Respondents
and
the
Information
Requested
4(
a)
Respondents/
NAICS
Codes
Respondents
affected
by
the
collection
activities
under
this
ICR
are
state
regulatory
agencies
which
are
involved
with
investigating
and
collecting
information
on
ecological
incidents
related
to
pesticide
use.
The
Environmental
Fate
and
Effects
Division
maintains
a
database
of
contact
information
for
161
such
state
agencies.
They
include
state
departments
of
agriculture
as
well
as
other
state
departments
and
commissions
involved
with
protecting
fish,
wildlife,
and
the
environment.
The
North
American
Industrial
Classification
System
(
NAICS)
code
assigned
to
state
regulatory
agencies
is
92411.

4(
b)
Information
Requested
(
i)
Data
items,
including
record
keeping
requirements
We
are
requesting
state
agencies
submit
reports
on
ecological
incidents
attributed
to
pesticide
poisoning,
including
fish
kills,
bird
kills,
honeybee
kills,
and
any
other
reports
of
adverse
effects
to
nontarget
animals
and
plants
caused
by
pesticides.
We
expect
the
agencies
can
provide
us
with
the
information
we
desire
by
reproducing
reports
or
parts
of
reports
that
already
have
created
for
other
purposes,
without
any
reformatting
work.
Reports
of
adverse
effects
to
nontarget
plants
are
not
being
included
in
this
ICR
because
these
incidents
are
numerous
and
would
require
a
large
burden
to
the
respondents
and
EPA.
Reports
will
be
limited
to
legal
and
illegal
use
of
pesticides.
Reports
should
give
preliminary
or
final
findings
from
official
investigations.
Reports
may
be
on
for
an
individual
incident
or
a
summary
of
multiple
incidents.
Photocopies,
e­
mail
messages,
faxes,
and
scanned
images
are
acceptable.

The
minimum
information
required
on
the
incident
reports
is:

$
LocationBstate
and
county
$
Date(
s)
of
incident
(
when
observations
of
adverse
effects
began
and
ended)

$
Known
or
suspected
pesticide(
s)
to
which
animals
were
exposed
$
Number
killed
or
affected,
by
species.
Draft
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Public
Comment
December
2003
Page
9
of
16
Information
on
pesticide
exposure
is
necessary
for
attributing
the
cause
of
the
incident
to
a
pesticide
or
pesticides.
Data
on
the
species
and
number
killed
or
affected
are
obviously
necessary
for
understanding
the
nature
and
extent
of
the
incident.
The
location
and
date
are
important
for
several
reasons.
These
endpoints
serve
as
a
way
to
identify
unique
incident
events,
helping
to
avoid
counting
the
same
incident
more
than
once
or
concluding
similar
incidents
are
the
same
when
they
are
actually
separate
incidents.
They
are
also
useful
for
ascertaining
the
likelihood
of
the
cause
of
incidents
since
information
may
be
available
about
the
types
of
pesticides
are
typically
applied
in
a
given
area
and
at
a
given
time
of
the
year.
Finally,
date
and
location
information
are
important
for
conducting
temporal
and
spatial
analysis
of
incident
data,
including
analysis
of
incident
data
using
GIS.

Because
of
the
inconsistency
of
incident
investigation
and
reporting
from
state
to
state,
sometimes
the
above­
cited
information
may
be
all
that
is
available.
However,
OPP
believes
that
the
following
information
is
also
important
and
will
ask
the
states
to
supply
it
whenever
it
is
available:

$
where
(
use
pattern)
and
how
the
pesticides
were
applied
(
e.
g.,
crop,
application
rate,
and
method
of
application),

$
results
of
pesticide
residue
analysis,
findings
of
necropsy
studies,

$
a
judgment
on
the
certainty
of
the
cause
of
the
incident
(
possible,
probable,
or
highly
probable),
and
$
a
brief
description
of
conditions
which
may
have
contributed
to
the
cause
of
the
incident
(
rainfall,
wind
conditions,
improper
application,
etc.).

This
information
is
important
for
evaluating
the
certainty
of
the
cause
of
the
incident.
It
also
helps
OPP
to
weigh
the
contribution
of
various
factors,
such
as
application
method
and
weather
conditions,
in
causing
the
exposure
and
effects
to
the
nontarget
organism.
This
allows
EPA
to
develop
more
effective
regulatory
measures
to
reduce
risk
to
nontarget
organisms.

Detailed
incident
data
are
key
to
confirming
ecological
risk.
In
fact,
in
the
regulatory
history
of
pesticides,
evidence
from
ecological
incident
data
have
played
a
key
role
in
decisions
to
cancel
pesticide
uses.
For
example,
DDT
was
cancelled
in
part
because
its
agricultural
use
caused
egg
shelling
thinning,
and
a
decrease
in
survival
of
avian
species,
especially
noticeable
in
raptors.
Diazinon
was
cancelled
for
use
on
golf
courses
and
sod
farms
as
a
result
of
the
reported
waterfowl
mortality
for
this
particular
use
pattern
of
diazinon.
The
use
of
tributyltin
compounds
on
small
watercraft
caused
shell
deformities
on
the
Pacific
oyster,
eventually
affecting
food
production.
After
a
series
of
international
negotiations
and
a
congressional
hearing,
this
pesticide
was
cancelled
for
this
use
to
limit
exposure
and
therefore
mitigate
risk.
These
are
only
a
few
examples
of
how
incident
data
has
been
used
in
the
past
for
regulatory
decisions.

(
ii)
Respondent
Activities
Draft
for
Public
Comment
December
2003
Page
10
of
16
A
State
must
engage
in
the
following
activities
in
order
to
comply
under
this
data
collection
program:

Respondent
Activity
Description
1.
Read
instructions
Read
instructions
provided
on
how
to
submit
information.

2.
Compile
and
review
information
Search
files
and/
or
computerized
document
storage
for
new
reports
on
fish
kills,
bird
kills,
and
other
ecological
incidents.
("
New
reports"
are
those
that
were
produced
within
the
past
year
or
since
the
last
submission,
whichever
is
shorter.)
Identify
incidents
associated
with
pesticide
use
only.

3.
Reproduce
reports
Reproduce
reports
through
photocopying,
scanning,
or
copying
electronic
files.

4.
Submit
reports
Package
hard
copies
of
reports
and
mail
them
or
fax
them
to
EPA,
or
send
electronic
copies
of
reports
to
EPA
through
e­
mail.

5.
Record
keeping
Record
which
reports
were
submitted
to
avoid
duplication.

5.
The
Information
Collected
B
Agency
Activities,
Collection
Methodology,
and
Information
Management
5(
a)
Agency
Activities
Agency
Activity
Description
1.
Receive
information
Receive
reports
through
mail,
fax,
or
email.

2.
Log
in
and
scan
documents
Reports
are
logged
in
initially
in
an
EFED
database.
They
are
then
sent
to
IRSD,
where
they
are
scanned,
assigned
an
identification
number,
and
logged
into
the
Incident
Data
System.

3.
Enter
data
into
database
Incident
reports
are
then
returned
to
EFED.
EFED
staff
read
and
extract
pertinent
data
from
each
report
and
enter
the
data
into
the
Ecological
Incident
Information
System
(
EIIS).
This
system,
which
is
stored
on
a
shared
drive
on
the
LAN,
makes
the
data
available
to
all
OPP
staff.
Draft
for
Public
Comment
December
2003
Page
11
of
16
4.
Data
quality
review
A
staff
member,
different
from
the
one
who
entered
the
data,
evaluates
the
data
in
the
database
against
the
original
report
and
corrects
any
data
errors.

5.
File
incident
reports
Paper
copies
of
the
reports
are
currently
filed
in
cabinets
by
the
PC
Code
(
unique
identification
numbers
for
pesticide
active
ingredients).
Reports
are
made
available
for
EFED
staff
to
review.
In
the
future,
we
plan
to
scan
the
reports
and
put
the
images
on
a
searchable
database.

5(
b)
Collection
Methodology
and
Management
Data
extracted
from
incident
reports
are
stored
and
managed
in
the
EIIS
database.
EIIS
is
a
relational
database
that
uses
Lotus
Approach
as
the
data
base
management
system
(
DBMS).
Several
forms
are
used
for
entering
data
of
different
types.
The
first
form
is
for
entering
general
attributes
of
the
incident,
such
as
date,
location,
and
type
of
incident.
A
second
form
is
then
used
to
enter
information
on
each
pesticide
involved
in
the
incident,
including
the
active
ingredient
name,
the
product
name,
the
treatment
site,
use
rate,
and
method
of
application.
This
form
also
includes
a
discussion
of
the
certainty
that
each
pesticide
was
a
significant
causal
factor
for
the
incident.
A
third
form
is
used
to
enter
information
on
each
species
affected,
including
species
name,
number
of
individuals
affected,
type
of
response
to
the
pesticide,
and
route
of
exposure.
Also
entered
on
this
form
are
diagnostic
findings,
such
as
measurements
of
cholinesterase
inhibition
and
concentrations
of
pesticide
residues
detected
in
tissue
samples
taken
from
the
carcass.
Finally,
a
fourth
form
is
used
to
record
concentrations
of
pesticide
residues
detected
in
other
samples
taken
from
the
environment
and
other
environmental
measurements.

A
staff
member
carefully
reads
each
report
and
extracts
all
of
the
available
information
into
these
database
forms.
He
then
prints
a
report
from
the
database
that
contains
all
of
the
attributes
of
that
incident.
A
second
staff
member
then
checks
the
database
report
and
compares
it
to
the
original
report
to
check
for
errors.
After
any
errors
have
been
corrected,
the
printed
database
report
is
attached
to
the
original
source
report
and
both
are
stored
in
file
cabinets
by
PC
Code.
In
the
future,
we
plan
to
scan
all
new
incident
reports
and
store
the
images
in
a
document
storage
database.

Scientists
in
EFED,
as
well
as
other
staff
throughout
OPP,
may
access
data
in
the
EIIS
database
through
a
Lotus
Approach
DBMS
maintained
on
the
office's
LAN.
People
may
conduct
standard
searches
for
incidents
by
PC
Code
or
incident
number,
or
custom
searches
based
on
any
combination
of
attributes.
Staff
can
print
two
types
of
standard
reports
from
the
database.
One
is
a
summary
report
for
all
the
incidents
related
to
that
active
ingredient.
The
other
is
a
report
Draft
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Comment
December
2003
Page
12
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16
showing
all
of
the
attributes
for
a
selected
incident
or
incidents.

In
addition
to
this
routine
management
of
new
incident
reports,
reports
that
are
of
special
significance
or
relevant
to
current
risk
assessment
activities
will
be
photocopied
and
provided
to
the
appropriate
staff
in
EFED.
This
will
allow
the
information
to
be
immediately
available
for
inclusion
in
ecological
risk
assessments
currently
being
conducted.

5(
c)
Small
Entity
Flexibility
Not
applicable.
There
are
no
small
entities
among
the
States
under
this
program.

5(
d)
Collection
Schedule
The
collection
schedule
will
be
flexible
and
left
to
the
state
office
to
determine.
States
would
be
encouraged
to
submit
incidents
on
a
regular
quarterly
schedule,
although
other
regular
or
irregular
schedules
would
be
acceptable.
At
a
minimum,
we
ask
that
each
state
submit
incident
reports
at
least
once
a
year.

6.
Estimating
the
Burden
and
Cost
of
the
Collection
6(
a)
Estimating
Respondent
Burden
Based
on
the
survey
EPA
conducted
with
the
various
states
agencies,
the
overall
respondent
burden
associated
with
this
collection
is
estimated
to
be
340
hours
per
year.
Since
state
agencies
are
being
asked
only
to
supply
information
in
the
form
of
incident
reports
which
they
have
already
prepared
for
their
own
use,
the
respondent
burden
is
based
only
on
the
amount
of
time
required
to
collect
the
reports
and
submit
them
to
EPA.
This
burden
was
estimated
from
the
results
of
consultation
that
EPA
conducted
with
staff
of
state
government
agencies,
as
described
in
section
3(
c)
of
this
document.
Averaging
the
responses
received
in
this
consultation
yielded
the
estimate
of
2.27
hours
required
per
year
for
a
single
respondent
to
complete
each
type
of
collection
activity,
as
shown
in
the
tables
in
section
6(
b).
Total
respondent
burden
was
estimated
by
multiplying
the
estimated
annual
burden
per
a
single
respondent
by
the
total
number
of
respondents.
OPP
has
identified
approximately
150
state
agencies
which
we
will
ask
to
submit
incident
information.
Multiplying
2.27
hours
by
150
respondents
yielded
the
total
annual
burden
estimate
of
340
hours.

6(
b)
Estimating
Respondent
Costs
The
following
estimates
are
based
on
averages
of
the
hours
of
burden
estimated
by
category
from
two
responses
we
received
from
our
consultation.
Only
two
of
the
three
responses
we
received
included
estimated
hours
by
categories.
The
estimates
in
this
table
are
the
annual
Draft
for
Public
Comment
December
2003
1These
labor
rates
reflect
employee
compensation
statistics
for
state
governments
from
the
Department
of
Labor,
Division
of
Employment
Cost
Trends.
The
technical
labor
rate
for
state
governments
was
adjusted
because
the
statistics
combined
technical
employees
with
higher
paid
professionals
(
such
as
doctors
and
lawyers).
These
rates
were
calculated
in
2003
using
the
NASA
Gross
Domestic
Product
Deflator
Inflation
Calculator
for
the
years
1999
to
2002.
The
rates
are
fully
loaded,
i.
e.,
they
consist
of
wages/
salary,
benefits,
and
compensation
for
each
labor
classification
plus
an
overhead
multiplier
of
1.9.

Page
13
of
16
costs
and
burdens
for
one
respondent
to
comply
with
our
data
request.

STATE
GOVERNMENT
HOURS,
RATES1
TOTAL
Collection
Activities
Mgmt
$
84/
hr
Tech.
$
63/
hr
Cler.
$
32/
hr
Hours
Costs
Read
Instructions
0.25
0.25
0.25
0.75
$
44.75
Compile
and
review
information
0.5
0.25
0.75
$
39.50
Reproduce
reports
0.25
0.01
0.26
$
16.07
Submit
reports
0.25
0.01
0.26
$
16.07
TOTAL
0.25
1.25
0.52
1.76
$
116.39
ANNUAL
BURDEN:
1.76
hours/
respondent
x
150
respondents
(
approximate)
=
264
hours
ANNUAL
COSTS:
$
116.39/
respondent
x
150
respondents
(
approximate)
=
$
17,459
(
i)
Estimating
Labor
Costs
Since
the
respondents
would
only
be
asked
to
reproduce
and
submit
reports
that
they
have
already
produced,
the
majority
of
the
costs
for
their
ICR
would
be
for
labor.
The
only
cost
other
than
labor
would
be
that
for
postage.
Therefore,
the
total
annual
labor
costs
are
estimated
as
the
total
annual
costs
($
17.459)
minus
the
annual
postage
costs
($
1,200),
which
equals
$
16,259.

(
ii)
Estimating
Capital
and
Operations
and
Maintenance
Costs
No
capital,
operational,
or
maintenance
costs
are
expected
except
for
postage
for
mailing
the
reports
to
us.
If
reports
are
mailed
quarterly
at
a
cost
of
$
3
per
package,
then
the
total
annual
Draft
for
Public
Comment
December
2003
Page
14
of
16
costs
would
be
$
12
per
respondent.
Assuming
that
one
third
of
the
respondents
would
avoid
this
cost
by
submitting
reports
electronically,
the
total
annual
postage
cost
is
estimated
as
$
12
x
100
respondents
or
$
1200.

(
iii)
Capital/
Start­
up
Operating
and
Maintenance
(
O&
M)
Costs
No
costs
are
expected.

(
iv)
Annualizing
Capital
Costs
No
costs
are
expected.
Draft
for
Public
Comment
December
2003
Page
15
of
16
6(
c)
Estimating
Agency
Burden
and
Cost
ANNUAL
AGENCY
BURDEN/
COST
ESTIMATES
The
following
are
estimates
of
EPA
burden
for
processing
incident
reports
received
annually
from
a
single
respondent.
Agency
labor
rates
are
based
on
Office
of
Personnel
Management
salary
tables
for
federal
employees
for
the
years
1999
through
2001
and
include
benefits
and
overhead
costs,
as
well
as
locality
pay
for
the
Washington,
DC­
Baltimore
area.

COLLECTION
ACTIVITIES
HOURS,
RATES
TOTAL
Mgmt.
$
96/
hr
Tech.
$
70/
hr
Cler.
$
33/
hr
Hours
Costs
Receive
information
0.5
0.5
1.0
$
51.50
Log
in
and
scan
documents
0.1
3
3.1
$
219.60
Enter
data
into
database
0.3
6
6.3
$
448.80
Data
quality
review
0.1
3
3.1
$
219.60
File
incident
reports
0.1
0.5
2
2.6
$
110.60
TOTAL
0.6
13
2.5
16.1
$
1050.10
ANNUAL
BURDEN:
16.1
hours
x
150
state
agency
x
2
responses/
agency/
year
=
4830
hours.

ANNUAL
COSTS:
$
1050.10
x
150
state
agency
x
2
responses/
agency/
year
=
$
315,030
Annual
costs
and
burdens
were
estimated
based
on
the
cost
and
burdens
that
are
associated
with
processing
incidents
reports
that
we
already
receive
from
a
few
states
and
agencies.
There
are
approximately
150
state
agencies
that
we
expect
to
contact
to
request
to
send
us
incident
reports.
If
EPA
chooses
to
submit
reports
quarterly,
they
would
prepare
and
mail
four
packages
to
us
a
year.
However,
since
some
agencies
will
report
to
us
only
once
a
year
and
some
will
choose
not
to
report
incidents
to
us
at
all,
we
are
estimating
an
average
of
two
responses
per
agency
per
year.
Draft
for
Public
Comment
December
2003
Page
16
of
16
6(
d)
Bottom
Line
Burden
Hours
and
Cost
Tables
Bottom
Line
Burden
Hours
and
Cost
TOTAL
Hours
Costs
Respondent
Burden
Estimate
264
$
17,459
Agency
Burden
Estimate
4,830
$
315,030
6(
e)
Reasons
for
Change
in
Burden
Not
applicable.
This
is
an
application
for
a
new
ICR.

6(
f)
Burden
Statement
The
annual
respondent
burden
for
this
collection
of
information
is
estimated
to
average
approximately
1.76
hours
per
response,
including
the
time
for
reading
instructions,
compiling
and
reproducing
incident
reports,
and
submitting
the
reports.
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.
The
OMB
control
numbers
for
EPA's
regulations
in
title
40
of
the
CFR,
after
appearing
in
the
Federal
Register,
are
listed
in
40
CFR
part
9,
and
included
on
the
related
collection
instrument
or
form,
if
applicable.

To
comment
on
EPA'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.
OPP­
2003­
0241,
which
is
available
for
public
viewing
at
the
OPP
Docket
in
the
Public
Information
and
Records
Integrity
Branch,
Rm.
119,
Crystal
Mall
#
2,
1921
Jefferson
Davis
Hwy.,
Arlington,
VA.
This
docket
facility
is
open
from
8:
30
a.
m.
to
4:
00
p.
m.,
Monday
through
Friday,
excluding
legal
holidays.
The
docket
telephone
number
is
(
703)
305­
5805.

An
electronic
version
of
the
public
docket
for
this
proposed
ICR
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
Officer
for
EPA.
Please
include
the
EPA
Docket
ID
No.
OPP­
2003­
0241
and
OMB
Control
No.
2070­
TBD
in
any
correspondence.
