Attachment
E
Supplemental
Distributor
Information
Collection
Activity
Consultation
Process:
Standard
Questions
Questions:

1.
Is
the
EPA
Form
8570­
5,
Notice
of
Supplemental
Distribution
of
a
Registered
Pesticide
Product,
available
from
any
public
source?
If
yes,
where
can
you
find
the
form?

2.
The
ICR
is
intended
to
require
that
respondents
provide
certain
data
so
that
the
Agency
can
utilize
them.
Based
on
the
instructions,
is
it
clear
to
respondents
what
they
are
required
to
do
and
how
to
submit
such
data?
If
not,
what
suggestions
do
you
have
to
clarify
the
instructions?

3.
Do
respondents
understand
what
they
are
required
to
submit
or
maintain
in
their
records?
Is
the
reporting
form
clear,
logical,
and
easy
to
complete?

4.
The
Government
Paperwork
Elimination
Act
requires
agencies
make
available
to
the
public
electronic
reporting
alternatives
to
paper­
based
submissions
by
2003,
unless
there
is
a
strong
reason
for
not
doing
so.
If
the
Agency
were
able
to
ensure
the
security
of
CBI
that
might
be
transmitted
over
the
Internet
and
the
reporting
form
could
be
completed
electronically,
would
you
be
interested
in
submitting
it
electronically?
Current
electronic
reporting
alternatives
include
the
use
of
"
web
forms"/
XML
based
submissions
via
the
Agency's
internet
site
and
magnetic
mediabased
submissions
(
i.
e.,
on
diskette,
CD­
ROM,
etc.)
Are
you
interested
in
using,
or
are
they
currently
utilizing,
electronic
reporting/
record­
keeping
options?

5.
Where
a
reporting
requirement
includes
a
signature
requirement,
consider
whether
a
secure
electronic
signature
method
(
such
as
Private
Key
Infrastructure)
should
be
required
if
submitting
electronically;
whether
a
less
secure
method
(
such
as
the
use
of
PINs
and
passwords)
would
be
more
appropriate;
or,
whether
a
signed
cover
sheet
may
be
sufficient
for
the
Agency's
purposes
when
data
is
submitted
on
disk.

6.
If
you
prefer
one
method
to
another,
does
your
choice
balance
burdens
and
costs
against
electronic
data
and
signature
security
integrity?

7.
If
an
electronic
reporting
option
is
not
offered
because
of
CBI­
related
concerns,
would
you
be
more
inclined
to
submit
CBI
on
diskette
than
on
paper?
What
benefits
would
you
realize?
(
Burden
reduction?
Greater
efficiency
in
compiling
the
information?).

8.
The
labor
rates
included
in
the
Agency's
estimated
burden
hours
and
costs
are
a
U.
S.
average
that
includes
costs
for
overhead
and
benefits.
These
estimates
include
only
burden
hours
and
costs
associated
with
the
paperwork
involved
with
this
ICR
(
i.
e.,
the
Agency
does
not
include
estimated
burden
hours
and
costs
for
usual
and
customary
business
practices
such
as
R&
D,
marketing,
etc.).
Are
the
estimated
burden
hours
and
labor
rates
accurate?
9.
Are
there
other
costs
that
should
be
accounted
for
that
may
have
been
missed,
such
as
capital/
start­
up/
M&
O
expenditures?
If
so,
please
provide
an
explanation
of
how
you
arrived
at
your
estimate
of
burden
and
cost
if
substantially
different
than
EPA's
estimate.
