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SUPPORTING
STATEMENT
FOR
AN
INFORMATION
COLLECTION
REQUEST
(
ICR)

1.
IDENTIFICATION
OF
THE
INFORMATION
COLLECTION
1(
a)
Title
of
the
Information
Collection:
Certification
of
Pesticide
Applicators
OMB
No:
2070­
0029
EPA
No:
0155.07
1(
b)
Short
Characterization/
Abstract
This
information
collection
request
is
designed
to
provide
the
Environmental
Protection
Agency
(
EPA)
with
the
authority
to
administer
and
oversee
training
and
certification
programs
for
pesticide
applicators
in
accordance
with
the
Federal
Insecticide,
Fungicide,
and
Rodenticide
Act
(
FIFRA)
and
to
enable
EPA
to
collect
certain
data
regarding
these
programs
from
States,
Indian
tribes,
and
federal
agencies
(
collectively
in
this
document
termed
"
states"
or
"
entities")
with
EPAapproved
certification
plans.

FIFRA
allows
the
EPA
to
classify
a
pesticide
as
"
restricted
use"
if
the
pesticide
meets
certain
toxicity
or
risk
criteria.
Restricted
use
pesticides,
because
of
their
potential
to
harm
human
health
or
the
environment,
may
be
applied
only
by
a
certified
applicator
or
by
a
person
under
the
direct
supervision
of
a
certified
applicator.
A
person
must
meet
certain
standards
of
competency
to
become
a
certified
applicator.
States
can
be
delegated
the
certified
applicator
program,
but
it
must
be
approved
by
the
Agency
before
it
can
be
implemented.
In
non­
participating
entities,
EPA
administers
the
certification
program.

2.
NEED
FOR
AND
USE
OF
THE
COLLECTION
2(
a)
Need/
Authority
for
the
Collection
Section
3(
d)
of
FIFRA
authorizes
EPA
to
classify
registered
pesticides
as
either
generalor
restricted­
use.
Restricted­
use
pesticides
(
RUPs)
are
those
that,
absent
additional
regulatory
restrictions,
may
cause
unreasonable
adverse
effects
on
people
or
the
environment.
Pesticides
classified
as
restricted
use
may
only
be
used
by
a
certified
applicator,
or
by
a
person
under
the
direct
supervision
of
a
certified
applicator.
A
certified
applicator
is
a
person
who
has
taken
specific
training
in
the
safe
handling
and
application
of
restricted­
use
products,
and
who
has
received
license
(
certification)
to
that
effect.
Section
11(
a)
of
FIFRA
grants
EPA
the
authority
to
prescribe
standards
for
the
certification
of
restricted­
use
pesticide
applicators.
Section
11(
a)(
2)
of
FIFRA
establishes
a
certification
program
that
allows
states
to
implement
applicator
certification
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after
the
state
program
has
been
approved
by
EPA.
While
the
bulk
of
the
certification
program
is
implemented
through
the
States,
in
non­
participating
States
or
tribes,
EPA
has
authority
to
directly
administer
certification
programs.
The
regulations
for
the
certification
program
in
Title
40
part
171
of
the
Code
of
Federal
Regulations
also
include
procedures
for
certification
programs
for
Federal
agencies
or
Indian
tribes
who
wish
to
develop
their
own
plans
in
lieu
of
using
State
certification
programs.

The
authority
for
this
information
collection
activity
is
provided
under
sections
3(
d)
and
11
of
FIFRA
and
40
CFR
part
171.

2(
b)
Practical
Utility/
Users
of
the
Data
The
annual
reports
from
the
states
are
used
as
a
monitoring
tool
to
develop
overall
data
on
pesticide
activities
for
OMB,
Congress,
and
others;
to
distribute
EPA
grant
funds
to
participating
states,
to
target
enforcement
activities,
and
to
revise
certification
and
training
program
emphasis
and
requirements.

An
application
form
is
used
to
obtain
vital
information
from
applicants
such
as
name
and
address,
and
to
schedule
applicators
for
certification
or
re­
certification.

Dealer
records
are
necessary
for
EPA
to
ensure
that
access
to
restricted
use
pesticides
is
limited
to
certified
applicators.
State­
administered
certification
programs
use
State
authority
to
require
dealers
to
maintain
records
of
restricted
use
pesticide
sales.

Application
records
are
required
by
EPA
under
federally­
run
programs
(
currently
the
Navajo
Indian
Country
program)
for
certified
commercial
applicators.
EPA
monitors
these
records
to
assure
that
restricted­
use
pesticides
are
used
only
by,
or
under
the
supervision
of,
certified
applicators
and
to
ensure
that
pesticide
labeling
requirements
are
adhered
to
by
requiring
applicators
to
record
details
of
the
restricted­
use
product
application.
Without
these
records
it
would
often
be
difficult
to
successfully
enforce
against
misuse.

Application
records
are
also
required
for
certified
commercial
applicators
under
state­
run
programs.
These
records
are
monitored
to
assure
that
restricted­
use
pesticides
are
used
only
by,
or
under
the
supervision
of,
properly
trained
and
certified
applicators
and
to
ensure
that
pesticide
labeling
requirements
are
adhered
to
by
requiring
the
applicators
to
record
the
application
(
amounts,
locations,
and
dates)
of
restricted
use
pesticides.
Without
these
records
it
would
often
be
difficult
to
successfully
enforce
against
misuse
and
ensure
proper
training
and
supervision
of
uncertified
applicators.
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3.
NON­
DUPLICATION,
CONSULTATIONS,
AND
OTHER
COLLECTION
CRITERIA
3(
a)
Non­
duplication
EPA
is
the
only
Federal
agency
with
the
authority
to
certify
applicators
of
restricted
use
products.
However,
the
United
States
Department
of
Agriculture
(
USDA)
also
has
regulations
which
impact
certified
applicators.
In
addition
to
providing
most
of
the
training
for
certified
applicators
under
an
Interagency
Agreement
(
IAG)
with
EPA,
USDA
has
regulations
which
require
private
and
commercial
applicators
to
maintain
detailed
records
regarding
the
application
of
restricted
use
pesticides.
The
records
required
by
USDA
under
7
CFR
110
are
much
more
detailed
than
those
required
by
EPA
under
40
CFR
171.

FIFRA
prohibits
EPA
from
requiring
private
applicators
to
keep
records
or
make
reports,
so
there
is
no
duplication
with
regard
to
private
applicators.
In
addition,
although
both
USDA
and
EPA
appear
to
impose
record­
keeping
requirements
on
commercial
applicators,
EPA's
requirements
are
only
a
subset
of
USDA's
requirements
and
consist
mostly
of
information
that
is
already
maintained
by
commercial
applicators
as
part
of
their
ordinary
and
customary
business
practices.
As
such
there
is
no
contradiction
or
practical
duplication.

To
prevent
duplication
and
facilitate
State
reporting,
EPA
permits
States
to
use
grant
reports
in
lieu
of
the
separate
annual
reports,
and
States
may
amend
their
plan
with
an
addendum.

3(
b)
Public
Notice
Required
Prior
to
ICR
Submission
to
OMB
Pursuant
to
5
CFR
1320.8(
d),
EPA
will
publish
a
Federal
Register
notice
soliciting
comments
on
this
information
collection
activity
and
EPA's
intent
to
renew
the
OMB
approval
of
this
ICR.
Comments
received
will
be
considered
in
the
preparation
of
the
final
ICR
renewal.

3(
c)
Consultations
The
regulations
under
40
Code
of
Federal
Regulations,
Part
171
(
40
CFR
171)
were
published
in
the
Federal
Register
in
1974,
1975
and
1978
with
minor
modifications
in
1983
and
1984.
All
sections
of
the
regulations
provided
a
comment
period
for
interested
parties
prior
to
promulgation.
The
comments
received
were
evaluated
by
the
Agency
prior
to
issuance
of
the
final
rule.
Continuous
consultation
and/
or
dialogue
between
industry
and
the
Agency
occurs
on
an
informal,
on­
going,
"
as
needed"
basis,
primarily
during
the
submission
and
review
of
reports.
The
certified
applicator
base
has
become
stable
over
the
years.

In
addition,
during
preparation
of
this
ICR
renewal,
EPA
staff
will
contact
representatives
from
a
cross­
section
of
respondents
by
e­
mail
and
telephone
to
seek
feedback
on
the
burden
estimates
in
the
ICR,
the
clarity
of
instructions
provided,
the
feasibility
of
reporting
the
data
by
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electronic
means,
and
other
questions
pertaining
to
the
requirements
of
the
program.

3(
d)
Effects
of
Less
Frequent
Collection
Only
annual
reports
from
participating
States
are
submitted
to
EPA
on
a
routine
basis.
Annually
is
considered
a
minimal
reporting
period.
As
described
earlier,
most
annual
reporting
information
required
under
the
regulation
is
contained
in
the
annual
grant
report,
and
can
be
submitted
as
a
joint
package.
In
the
future,
states
will
be
able
to
provide
their
annual
reports
electronically
via
the
C&
T
Template.
Budget
requests
and
the
distribution
of
cooperative
agreement
funds
are
done
on
an
annual
basis.
The
annual
report
data
is
used
to
support
budget
requests
and
to
apportion
cooperative
agreement
funds.
Less
frequent
collection
of
information
would
not
allow
the
Agency
to
distribute
these
funds
in
the
most
equitable
manner,
as
data
demonstrating
need
would
not
be
accurate.

3(
e)
General
Guidelines
Pursuant
to
5
CFR
1320.6,
the
Agency
seeks
OMB
approval
of
EPA
Form
8500­
17
for
use
whenever
the
Agency
administers
the
Certified
Pesticide
Applicator
program
in
the
place
of
a
State­
administered
program.
The
Agency's
use
of
such
a
form
under
these
circumstances
is
required
by
FIFRA
section
11(
a)(
1).
This
information
collection
activity
does
not
exceed
any
other
of
the
Paperwork
Reduction
Act
guidelines
contained
at
5
CFR
1320.6.

3(
f)
Confidentiality
The
activities
or
records
proposed
in
this
regulation
will
not
involve
any
confidentiality
concerns
or
information.

3(
g)
Sensitive
Questions
The
activities
proposed
in
this
regulation
will
not
involve
any
sensitive
questions.

4.
THE
RESPONDENTS
AND
THE
INFORMATION
REQUESTED
4(
a)
Respondents/
NAICS
codes
The
North
American
Industrial
Classification
System
(
NAICS)
code
for
respondents
participating
in
the
data
collection
activity
are
noted
here:
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Farms:

11
Crop
Production
112
Animal
Production
Commercial
Services:

561710
Exterminating
and
Pest
Control
Services
Administration
of
Certification
Programs
by
States/
Tribal
Lead
Agencies:

924110
Environmental
protection
program
administration
926140
Pest
control
programs,
agricultural,
governmental
Pesticide
Dealers
(
only
for
EPA­
administered
programs)

444220
Retail
Nursery,
Lawn,
and
Garden
Supply
stores
424910
Agricultural
chemicals
merchant
wholesalers
4(
b)
Information
Requested
i.
Data
items,
including
recordkeeping
requirements
A.
Annual
Reports
Annual
reports
are
required
from
States,
Indian
tribes,
and
Federal
agencies
with
EPA­
approved
certification
plans.
These
entities
are
required
to
develop
reports
based
on
the
requirements
in
the
regulations,
including
information
on
their
respective
program
activity,
such
as
the
number
of
applicators
certified
and
any
significant
changes
to
their
plans.

B.
Application
for
certification
in
EPA­
administered
programs
(
Colorado
and
Navajo
Indian
Country)

Currently,
EPA
administers
the
private
applicator
certification
program
in
one
state,
Colorado.
The
regulations
require,
in
EPA­
administered
programs,
an
application
form
be
completed
for
persons
seeking
certification
or
re­
certification.
The
forms
are
necessary
for
EPA
to
schedule
certification
and
re­
certification,
and
to
obtain
vital
information
such
as
name
and
address.

EPA
is
implementing
a
certified
applicator
program
in
the
Navajo
Indian
Country.
Both
commercial
and
private
applicators
will
be
covered
by
this
program,
and
a
form
to
apply
will
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be
required.
Applicators
with
current
certification
from
New
Mexico,
Utah,
and
Arizona
will
be
eligible
for
certification
in
the
Navajo
Indian
Country
with
proof
of
certification
and
a
completed
form.
There
are
currently
40
applicators
that
will
need
certification
in
Navajo
Indian
Country,
and
we
expect
that
all
will
apply
in
the
first
year
of
the
program.

The
regulations
do
not
require
States
to
use
the
EPA's
application
form,
they
may
use
similar
forms
developed
to
meet
their
specific
needs.
A
copy
of
EPA's
application
form
for
requesting
certification
is
attached.

C.
Dealer
record­
keeping
in
EPA­
administered
programs
(
Colorado
and
Navajo
Indian
Country)

The
regulations
require
dealers
under
EPA­
administered
programs
to
keep
records
of
the
sale
of
restricted­
use
products
for
24
months.
Dealer
records
are
maintained
at
the
pesticide
dealership,
and
are
not
routinely
submitted
to
EPA;
however
they
may
be
collected
as
part
of
an
investigation
or
enforcement
action.
This
is
necessary
for
EPA
to
ensure
that
access
to
restricted
use
pesticides
is
limited
to
certified
applicators,
or
those
under
their
supervision.
Without
the
ability
to
limit
access
to
restricted
use
pesticides,
there
would
be
little
purpose
in
certifying
workers
or
classifying
pesticides
for
restricted
use.
This
provision
is
solely
intended
to
provide
EPA
with
the
authority
to
impose
dealer
record­
keeping
in
entities
with
EPA­
administered
programs.
State­
administered
programs
must
use
State
authority
to
require
dealers
to
maintain
records
of
restricted­
use
pesticide
sales.

In
Colorado,
dealers
of
pesticide
products
are
required
to
create
and
maintain
records;
however,
there
are
currently
no
pesticide
dealers
in
Navajo
Indian
Country.

D.
Commercial
Applicator
Records
­
EPA­
managed
programs
Commercial
applicators
under
EPA­
administered
programs
must
keep
records
on
the
kinds,
amounts,
uses,
dates
and
places
of
restricted­
use
pesticide
applications
immediately
after
the
application
is
complete.
Records
must
be
retained
for
two
years.
Records
are
not
required
to
be
submitted,
but
they
must
be
made
available
to
EPA
or
State
officials
upon
request.
Records
collected
may
become
part
of
an
enforcement
action
or
investigation.

E.
Commercial
Applicator
Records
­
State­
managed
programs
Commercial
applicators
under
State­
administered
programs
must
keep
records
on
the
kinds,
amounts,
uses,
dates
and
places
of
restricted­
use
pesticide
applications
immediately
after
the
application
is
complete.
Records
must
be
retained
for
two
years.
Records
are
not
required
to
be
submitted,
but
they
must
be
made
available
to
EPA
or
State
officials
upon
request.
Records
collected
may
become
part
of
an
enforcement
action
or
investigation.
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ii.
Respondent
Activities
A
typical
respondent
will
perform
the
following
activities:

Read
rules
or
other
instructions
Read
applicable
regulations,
40
CFR
171,
grant
requirements,
and
other
applicable
requirements
Receive
Training
Administered
by
EPA
approved
program
or
EPA
Create
information
Document
activities/
applications
Gather
information
Collect
records
needed
to
develop
annual
report
Review
Review
information
for
accuracy
Complete
written
forms
or
other
instruments
Extract
data
from
records
and
compile
into
reporting
format
Record,
disclose,
display,
or
report
the
information
Compile
report
and
submit.
Record
maintenance
for
preparation
of
the
next
annual
report,
such
as
grant
reports
and
hard
copy
and
computer
records
of
data
required
in
the
annual
report.

Store,
file,
or
maintain
information.
Store
and
retain
records.
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5.
THE
INFORMATION
COLLECTED
­
AGENCY
ACTIVITIES,
COLLECTION
METHODOLOGY,
AND
INFORMATION
MANAGEMENT
5(
a)
Agency
Activities
In
continuing
this
collection,
EPA
will:

Prepare
report
(
Region
9
for
Navajo
Indian
Country)
Region
9
will
submit
report
for
this
federallyimplemented
plan
Answer
respondent
questions
Answer
respondent
questions
Review
data
Review
data
submissions
Record
data
Record
submissions
Maintain
data
Develop/
maintain
a
master
data
base
for
data
submissions
Reformat
data
Reformat
and
distribute
data
Store
data
Store
data
5(
b)
Collection
Methodology
and
Management
Dealer
and
commercial
applicator
records
are
not
routinely
collected.
Annual
reports
from
EPA­
approved
certified
programs
are
required.
The
Agency
allows
respondents
to
utilize
their
end­
of­
year
grant
reports
to
fulfill
the
annual
report
requirement
under
this
program
to
the
extent
that
information
contained
in
such
grant
reports
satisfies
Part
171
requirements.
Certain
minor
reporting
elements
which
may
be
outside
the
scope
of
the
grant
reports
may
be
provided
in
whatever
fashion
the
respondent
finds
most
convenient
and
least
burdensome.
The
information
required
under
this
program
was
generally
included
in
the
grants
reports
as
a
2­
3
page
addendum
to
that
report.

The
applicator
certification
form
is
used
as
an
initial
reference
point
for
potential
certified
applicators
in
EPA­
administered
programs.
The
form
requires
only
basic
information
such
as
name
and
address.
For
EPA­
administered
programs
the
respective
Regions
compile
and
maintain
data
on
program
operations.
The
public
may
access
the
data
by
contacting
the
appropriate
EPA
Regional
offices.
DRAFT
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February
10,
2004
Page
9
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20
5(
c)
Small
Entity
Flexibility
These
regulations
apply
specifically
to
individuals
who
are
certified
applicators.
EPA
believes
that
the
records
required
of
certified
pesticide
applicators
and
their
employees
are
minimal
and
would
generally
be
kept
for
the
applicators'
own
use
even
in
the
absence
of
this
regulation.
In
Colorado
and
Navajo
Indian
Country,
where
EPA
administers
the
certification
program,
dealers
are
also
required
to
keep
records.
EPA
does
not
require
the
submission
of
dealer
records,
but
rather
requires
that
the
dealer
furnish
records
for
inspection
and
copying
upon
request.

There
are
currently
no
dealers
in
the
Navajo
Indian
Country.

5(
d)
Collection
Schedule
There
is
not
a
collection
schedule
per
se.
Commercial
applicators
must
generate
records
on
the
kinds,
amounts,
uses,
dates,
and
locations
of
restricted
use
pesticide
applications
immediately
after
pesticide
application,
and
are
required
to
maintain
these
records
for
two
years.
Although
the
records
are
maintained
locally
and
are
not
required
to
be
submitted
to
EPA
or
the
State,
they
must
be
made
available
for
State
or
EPA
officials
upon
request.
Records
collected
may
become
part
of
an
investigation
or
enforcement
action.

6.
ESTIMATING
THE
BURDEN
AND
COST
OF
COLLECTION
6(
a)
Estimating
Respondent
Burden
In
estimating
the
average
respondent
burden
related
to
the
information
collection
components
of
the
Agency's
certification
system,
the
Agency
based
the
burden
hour
estimates
on
the
Office
of
Pesticide
Programs'
extensive
experience
and
knowledge
of
the
Certification
and
Training
Program,
Regional
contacts
and
budget
staffing
records
of
the
Regional
offices,
and
information
obtained
from
USDA,
State
Agencies,
and
other
resources.
The
total
annual
burden
for
EPA's
State,
Federal,
and
Tribal
partners
to
report
is
estimated
to
be
4,412
hours,
with
an
average
burden
of
77.4
hours
for
each
of
the
57
participating
entities.
The
average
per
State
burden
is
based
on
several
estimates
that
were
provided
to
EPA
by
participating
States.

The
total
annual
burden
for
certifying
applicators
where
EPA
implements
the
certification
program
in
Colorado
for
private
applicators
and
for
commercial
and
private
applicators
in
the
Navajo
Indian
Country
is
estimated
to
be
517
hours,
with
an
average
burden
estimate
of
0.17
hours
per
respondent.
This
burden
is
based
on
completing
applications.
Since
the
Federal
Program
is
actually
managed
by
Agency
personnel,
this
burden
estimate
is
based
on
the
experience
of
the
personnel
running
the
program
in
EPA's
Region
8.
The
total
annual
burden
and
cost
of
pesticide
DRAFT
FOR
PUBLIC
COMMENT
February
10,
2004
1
Source:
US
Bureau
of
Labor
Statistics,
Office
of
Employment
and
Unemployment
Statistics,
ES­
202
Program,
1989.
Wage
Rates
of
State
Government
Workers.
Non­
published
data.
Adjusted
for
current
year
with
inflation
factors.

Page
10
of
20
dealers'
record­
keeping
in
Colorado
is
estimated
to
be
an
annual
burden
of
1,330
hours
with
an
average
per
respondent
burden
of
5
hours.
These
estimates
were
derived
from
contacts
within
the
State
of
Colorado,
in
conjunction
with
discussions
with
the
EPA
Regional
office
personnel
that
run
the
other
half
of
the
program
in
Colorado.

The
total
annual
burden
for
record­
keeping
by
commercial
applicators
where
EPA
implements
the
certification
program
in
the
Navajo
Indian
Country
is
estimated
to
be
108.5
hours,
with
an
average
burden
estimate
of
3.1
hours
per
respondent.

Commercial
applicators
and
firms
under
state­
administered
programs
are
also
subject
to
certain
record­
keeping
requirements,
the
information
that
EPA
requires
to
maintain
them
under
40
CFR
171.
Specifically,
EPA
requires
commercial
applicators
to
record
the
following
information:
the
name
and
address
of
the
person
for
whom
the
pesticide
was
applied;
the
location
of
the
application;
the
target
pest(
s);
the
specific
crop
or
commodity,
as
appropriate;
the
name
and
registration
number
of
the
pesticide
applied;
the
amount
applied
and
percent
active
ingredient
per
unit
of
pesticide
used;
and
the
type
and
amount
of
leftover
pesticide
disposed
of
with
the
method
and
location
of
disposal.
The
Agency
estimates
that
421,000
commercial
applicators
will
be
subject
to
the
record­
keeping
requirements
for
a
total
annual
respondent
burden
of
1,305,000
hours.
The
average
per­
respondent
burden
is
3.1
hours.

6(
b)
Estimating
Respondent
Costs
Respondent
costs
are
based
on
technical,
managerial,
and
clerical
burden
hours
estimated
at
$
73,
$
61,
and
$
47
per
hour,
respectively,
for
states.
These
labor
rates
were
supplied
by
the
Bureau
of
Labor
Statistics1,
and
represent
loaded
labor
rates,
i.
e.
salary
and
overhead
costs.
There
are
no
managerial
or
clerical
costs
associated
with
this
ICR
for
respondents
representing
pesticide
dealers
in
Colorado.
However,
the
technical
cost
for
these
respondents
is
estimated
at
$
19
per
hour.
The
cost
of
$
19
per
hour
was
based
on
figures
given
by
owners
of
small
retail
stores
($
10
per
hour
plus
10%
overhead
plus
15%
benefits
indexed
to
1998
dollars
and
corrected
using
inflation
factors).
The
burden
hour
estimates
were
derived
from
knowledge
of
the
Certification
and
Training
Program.
This
program
is
run
out
of
EPA
Region
8,
thus
staffing
requirements
are
well­
known.
There
are
no
capital
expenditures
associated
with
this
information
collection
activity.

The
following
tables
illustrate
the
estimated
burden
and
costs
associated
with
the
information
collection
activities
of
this
program.
Using
the
hourly
rates
mentioned
above,
the
estimated
average
cost
per
participating
State
is
$
4,080,
with
the
total
cost
for
States
under
this
DRAFT
FOR
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February
10,
2004
Page
11
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20
requirement
estimated
to
be
$
232,560.
The
estimated
average
cost
for
certifying
private
applicators
in
Colorado
and
commercial
and
private
applicators
in
the
Navajo
Indian
Country
is
$
3.20
per
respondent,
with
the
total
cost
estimated
to
be
$
9,728.
The
total
estimated
cost
for
the
record­
keeping
requirements
of
Colorado's
pesticide
dealers
is
$
25,270;
averaging
$
95
per
response.

The
annual
respondent
cost
for
commercial
applicator
record­
keeping
in
Navajo
Indian
Country
is
estimated
at
$
2,065,
with
an
average
per­
respondent
cost
of
$
59.
Commercial
applicator
programs
run
under
State
authority
have
an
estimated
cost
of
nearly
$
25
million,
based
on
2001
commercial
applicator
count
of
421,000.
Again,
the
per­
respondent
cost
is
estimated
at
$
59.
See
Tables
4
and
5
for
further
details.
DRAFT
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February
10,
2004
Page
12
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20
Table
1.
Annual
Respondent
Cost/
Burden
Estimates
for
state
Annual
Reports
on
Certification
and
Training
Programs
Annual
Burden
Hours
TOTALS
Collection
Activities
Tech.
$
61/
hr
Clerical
$
47/
hr
Hours
Cost
$

Read/
hear
rule
or
any
collective
instrument
instruction
(
incl.
compliance
determination)
0.25
0
0.25
15
Create
information
5
0
5
305
Gather
information
5
0
5
305
Process,
compile,
review
info
for
accuracy
1
0
1
61
Complete
written
forms
or
other
instruments
0.5
0.5
1
54
Record,
disclose,
display,
or
report
the
information
20
45
65
3335
Store,
file,
or
maintain
the
information
0
0.1
0.1
5
TOTAL
31.75
45.6
77.35
4080
Annual
Burden:
Hr
Total
(
77.4)
x
No.
of
respondents
(
57)
=
4,412
hrs
Annual
Cost:
Cost
Total
($
4080)
x
No.
of
respondents
(
57)
=
$
232,560
DRAFT
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February
10,
2004
Page
13
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Table
2.
Annual
Respondent
Burden
Estimates
for
Certified
Applicators
in
Federal
Programs
(
Colorado
and
Navajo
Indian
Country)
for
Completion
of
EPA
Application
Forms
(
private
and
commercial
applicators
in
Navajo
Indian
Country;
private
only
in
Colorado)

Collection
Activities
Tech.
$
19/
hr
Hours
Cost
$

Read/
hear
rule
or
any
collective
instrument
instruction
(
incl.
compliance
determination)
0.07
0.07
1.30
Complete
written
forms
or
other
instruments
0.10
0.10
1.90
TOTAL
0.17
0.17
3.20
Annual
Burden:
Hr
Total
(
0.17)
x
No.
of
respondents
3,040
=
517
hrs
Annual
Cost:
Cost
Total
($
3.20)
x
No.
of
respondents
3,040
=
$
9728.00
There
are
approximately
12,000
private
applicators
in
Colorado;
they
must
be
re­
certified
every
4
years
(
3,000
recertified
annually,
on
average).
In
Navajo
Indian
Country,
35
commercial
and
5
private
applicators
will
need
to
complete
application
forms
to
apply
for
certification.

The
cost
of
$
19
was
based
on
figures
given
by
owners
of
small
retail
stores
($
10/
hour
plus
10%
overhead
plus
15%
benefits
indexed
to
1998
dollars,
with
an
inflation
factor
of
1.21).
The
burden
hour
estimates
were
derived
from
knowledge
of
the
certification
and
training
program.
DRAFT
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February
10,
2004
Page
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Table
3.
Annual
Respondent
Cost/
Burden
Estimates
for
Pesticide
Dealers
for
Record­
keeping
Requirements
for
Restricted
Use
Pesticide
Certification
(
Colorado)

Collection
Activities
Tech.
$
19/
hr
Hours
Cost
$

Read/
hear
rule
or
any
collective
instrument
instruction
(
incl.
compliance
determination)
0.5
0.5
9.50
Process,
compile,
review
info
for
accuracy
1
1
19
Complete
written
forms
or
other
instruments
2.5
2.5
47.50
Record,
disclose,
display,
or
report
the
information
0.5
0.5
9.50
Store,
file,
or
maintain
the
information
0.5
0.5
9.50
TOTAL
5
5
95
Annual
Burden:
Hr
Total
(
5)
x
No.
of
respondents
(
266)
=
1,330
hrs
Annual
Cost:
Cost
Total
($
95)
x
No.
of
respondents
(
266)
=
$
25,270
There
are
266
pesticide
dealers
in
Colorado.
The
cost
of
$
19
was
based
on
figures
given
by
owners
of
small
retail
stores
($
10/
hour
plus
10%
overhead
plus
15%
benefits
indexed
to
1998
dollars,
with
an
inflation
factor
of
1.21).
The
burden
hour
estimates
were
derived
from
knowledge
of
the
certification
and
training
program.
DRAFT
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February
10,
2004
Page
15
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20
Table
4.
Annual
Respondent
Burden
Estimates
for
Commercial
Applicators
­
record­
keeping
in
Navajo
Indian
Country
Collection
Activities
Tech.
$
19/
hr
Hours
Cost
$

Read/
hear
rule
or
any
collective
instrument
instruction
(
incl.
compliance
determination)
0.2
0.2
3.80
Create
information
2
2
38
Store,
file,
or
maintain
the
information
0.9
0.9
17
TOTAL
3.1
3.1
59
Annual
Burden:
Hr
Total
(
3.1)
x
No.
of
respondents
(
35)
=
109
hrs
Annual
Cost:
Cost
Total
($
59)
x
No.
of
respondents
(
35)
=$
2065
The
cost
of
$
19
was
based
on
figures
given
by
owners
of
small
retail
stores
($
10/
hour
plus
10%
overhead
plus
15%
benefits
indexed
to
1998
dollars,
with
an
inflation
factor
of
1.21).
The
burden
hour
estimates
were
derived
from
knowledge
of
the
certification
and
training
program.
DRAFT
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February
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2004
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Table
5.
Annual
Respondent
Burden
Estimates
for
Commercial
Applicators
and
Firms
for
Recordkeeping
under
State
authority
Collection
Activities
Tech.
$
19/
hr
Hours
Cost
$

Read/
hear
rule
or
any
collective
instrument
instruction
(
incl.
compliance
determination)
0.2
0.2
3.80
Create
information
2
2
38
Store,
file,
or
maintain
the
information
0.9
0.9
17
TOTAL
3.1
3.1
59
Annual
Burden:
Hr
Total
(
3.1)
x
No.
of
respondents
(
421,000)
=
1,305,100
hrs
Annual
Cost:
Cost
Total
($
59)
x
No.
of
respondents
(
421,000)
=$
24,839,000
The
cost
of
$
19
was
based
on
figures
given
by
owners
of
small
retail
stores
($
10/
hour
plus
10%
overhead
plus
15%
benefits
indexed
to
1998
dollars,
with
an
inflation
factor
of
1.21).
The
burden
hour
estimates
were
derived
from
knowledge
of
the
certification
and
training
program.
DRAFT
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February
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2004
Page
17
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20
(
c)
Estimating
Agency
Burden
and
Cost
The
Agency
normally
estimates
the
annual
burden
to
the
federal
government
to
review
the
submissions.
The
Agency's
total
burden
associated
with
the
certification
of
pesticide
applicators
program
is
estimated
at
1857
hours.
The
total
cost
to
the
Agency
is
estimated
at
$
63,753.

The
previous
ICR
estimated
a
significantly
higher
burden,
based
on
proposed
changes
to
the
regulations.
However,
these
proposed
changes
did
not
take
place
and
the
burden
calculated
here
reflects
the
current
process.

Table
6a.
Annual
Agency
Burden/
Cost
Estimates
­
burden
to
Regional
Offices
Collection
Activities
Mgmnt
hours
($
46)
Tech.
hours
($
33)
Clerical
hours
($
18)
Total
Hours
Cost
Prepare
Report
­
Region
9
for
Navajo
Plan
0
104
0
104
3,432
Answer
respondent
questions
7.1
228
0
235.1
7,851
Audit/
review
submissions
18.8
798
0
816.8
27,199
Record/
enter
submissions
0
200
0
200
6,600
Reformat
and
distribute
data
0
91.2
0
91.2
3,009
Store,
file,
or
maintain
the
information
0
68.4
11.4
79.8
2,462
TOTAL
25.9
1489.6
11.4
1526.9
50,553
The
salaries
used
for
management,
technical,
and
clerical
were
GS
13
step
8,
GS
12
step
2,
and
GS
6
step
4,
respectively.
These
burden
hours
are
estimated
based
on
information
provided
by
four
regional
offices,
and
wages
are
adjusted
with
an
inflation
factor.
Total
hours
result
in
aggregate
of
0.72
FTE.
DRAFT
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February
10,
2004
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18
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Table
6b.
Annual
Agency
Burden/
Cost
Estimates
­
Headquarters
estimates
for
Review
of
submitted
reports
Collection
Activities
Tech.
Hours
@
$
40/
hr
Cost
$

Answer
respondent
questions
100
4,000
Audit/
review
submissions
100
4,000
Record/
enter
submissions
80
3,200
Reformat
and
distribute
data
40
1,600
Store,
file,
or
maintain
the
information
10
400
TOTAL
330
13,200
The
total
Federal
burden
for
the
review
of
the
submissions
and
development
of
the
Navajo
Indian
Country
report
is
estimated
at
$
63,753
and
1857
hours,
or
approximately
0.9
FTE.
DRAFT
FOR
PUBLIC
COMMENT
February
10,
2004
Page
19
of
20
(
d)
Bottom
Line
Burden
Hours
and
Cost
Table
Table
7.
Bottom
Line
Burden
Hours
and
Cost
Table
(
i)
Respondent
Tally
Total
Burden
Hours
Total
Cost
($)

States
(
Table
1)
4,412
232,560
Federal
program
­
certified
applicators
(
Tables
2
and
4)
517
109
9,728
2,065
State­
administered
programs
­
certified
applicators
1,305,000
24,839,000
Pesticide
Dealers
(
Table
3)
1,330
25,270
Bottom
Line
Respondent
total
1,311,368
25,108,623
(
ii)
Agency
Tally
1,857
63,753
(
e)
Reasons
for
Change
in
Burden
The
previous
ICR
included
substantial
federal
burden
for
implementing
significant
changes
to
the
regulation.
Those
changes
were
not
realized,
therefore,
the
anticipated
increases
in
the
federal
burden
are
not
included
in
this
ICR.

The
public
burden
compared
to
the
previous
ICR
has
increased
slightly,
from
1,285,865
to
1,311,368
hours,
due
to
an
increase
in
the
number
of
certified
commercial
applicators.
Burden
from
programs
administered
by
EPA
increased,
as
the
Navajo
Indian
Country
plan
for
applicators
is
expected
to
initiate
soon,
and
the
number
of
applicators
certifying
is
increased
in
the
counts.
The
cost
burden
has
risen
as
well,
primarily
as
a
result
of
inflation,
from
$
21,456,058
to
$
25,108,623.

(
f)
Burden
Statement
The
annual
burden
for
this
collection
is
estimated
to
average
5
hours
for
pesticide
dealer
record­
keeping
in
Colorado,
0.17
hours
for
certifying
applicators
in
Colorado
and
in
the
Navajo
Indian
Country,
and
77.4
hours
for
each
state
to
submit
annual
reports.
Certified
commercial
applicators
have
an
annual
average
burden
of
3.1
hours
for
preparing
and
maintaining
required
records.
DRAFT
FOR
PUBLIC
COMMENT
February
10,
2004
Page
20
of
20
According
to
the
Paperwork
Reduction
Act,
"
burden"
means
the
total
time,
effort,
or
financial
resources
expended
by
persons
to
generate,
maintain,
retain,
disclose,
or
provide
information
to
or
for
a
Federal
agency.
For
this
collection,
it
is
the
time
reading
the
regulations,
planning
the
necessary
data
collection
activities,
analyzing
data,
generating
reports
and
completing
other
required
paperwork,
and
storing,
filing,
and
maintaining
the
data.
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
number
for
this
information
collection
appears
at
the
beginning
and
end
of
this
document.
In
addition
OMB
control
numbers
for
EPA's
regulations,
after
initial
display
in
the
final
rule,
are
listed
in
40
CFR
part
9.

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.
OPP­
2003­
0357,
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
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
ICR
renewal
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
0357
and
OMB
Control
No.
2070­
0029
in
any
correspondence.
