SUPPORTING STATEMENT FOR AN

INFORMATION COLLECTION REQUEST

1.	IDENTIFICATION OF THE INFORMATION COLLECTION

1(a).	Title of the Information Collection

TITLE:  Recordkeeping Requirements for Certified Applicators Using 1080
Collars for Livestock Protection

OMB NO. 2070-0074			EPA No. 1249.08

1(b).	Short Characterization/Abstract

This information collection request (ICR) is a proposed renewal of an
existing ICR that is currently approved by OMB and is due to expire on
May 31, 2007.  This information collection activity enables the
Environmental Protection Agency (EPA) to obtain the information needed
to track the use of registered 1080 collars and the record keeping
requirements imposed by an administrative judge in October 1982 and
confirmed by the Agency in 1983.  This ICR affects four States (Montana,
New Mexico, South Dakota, and Wyoming) that monitor the program plus one
additional registrant.  Applicators who are certified to apply livestock
protection collars are required to keep records of:  a) number of
collars purchased; b) number of collars attached on livestock; c)
pasture(s) where collared livestock were placed; d) number and locations
of livestock found with ruptured or punctured collars and the apparent
cause of the damage; e) the dates of each attachment, inspection, and
removal; f) number, dates, and approximate location of all collars lost;
g) locations, and dates of all suspected poisonings of humans, domestic
animals or non-target wild animals resulting from collar use location
and species data on each animal poisoned as an apparent result of the
toxic collar.  This Supporting Statement pertains to monitoring
activities associated with collar use and to the preparation and
submission of an annual monitoring report to EPA that are over and above
requirements that are either conditions of registration or obligations
associated with the handling and regulation of any restricted use
pesticide product. 

 Applicators maintain records, and the registrants/lead agencies do
monitoring studies and submit the reports.  These records are monitored
by either the:  a) State lead agencies or b) registrants.  EPA receives
annual monitoring reports from registrants or State lead agencies.

2.	NEED FOR AND USE OF THE COLLECTION

2(a).  Need/Authority for the Collection

The Administrator of the EPA banned all predator uses of Sodium
Monofluoroacetate (Compound 1080) in 1972.  In 1981 and 1982, EPA
received applications to register 1080 in several delivery mechanisms,
one of which was the toxic collar.  Following extensive public hearings
in 1982, EPA's Administrative Law Judge Nissen declared, on October 22,
1982, that the Agency could register the collar, with certain specific
use restrictions, after going through the normal registration process. 
The Administrative Law Judge included restrictions and recordkeeping
requirements in Attachment C of his initial decision.  On October 31,
1983, then EPA Assistant Administrator Lee M. Thomas affirmed Judge
Nissen's initial decision, including the use restrictions and
recordkeeping requirements.

Prior to 1972, 1080 was used for predator control in a number of ways,
some of which were subject to the 1982 proceedings, which either did not
receive a favorable ruling from the Administrative Law Judge or were not
subsequently registered for other reasons. As there have been occasional
reports of predator control use and other uses of 1080 by illegal
methods subsequent to 1972, EPA believes that it is extremely important
to account for the 1080 that is supplied for legal use so as to maintain
surveillance on the toxic collar program and to deter diversion of 1080
in the program from legal to illegal predator control use.  As 1080 is a
highly soluble material of potent but delayed oral toxicity, there are
additional concerns about transfer of this material to persons who might
use or threaten to use it as a weapon of terrorism.

2(b).  Practical Utility/Users of the Data

As a condition of the 1080 livestock protection collar registration, EPA
has required submission of annual reports monitoring use of all
livestock protection collar products.  Depending upon the product, the
registrant or the State lead agency for pesticide regulation is
designated as being responsible for submitting an annual monitoring
report.  The requirement to submit reports is imposed for at least the
first four years of the collars' use under the registration.  Factors
affecting the extension of requirements to submit annual reports
include:  1) quality of reports submitted previously; 2) amount of use
reported; 3) results of collar use (in terms of numbers punctured by
coyotes, numbers punctured by other causes, numbers lost, nontarget
poisonings, etc.); 4) frequency and nature of violations reported; and
5) arrangements made between EPA and registrants regarding annual
reports of collar use to meet other requirements for reporting
information.  EPA reviews the annual reports to assess compliance with
the 1982 Administrative Law decision and the requirements of product
labeling.

3.	NONDUPLICATION, CONSULTATIONS, AND OTHER COLLECTION CRITERIA

3(a).  Nonduplication

The processes for recordkeeping, reporting nontarget exposure incidents,
and submitting monitoring reports are not duplicative of any other known
information collection requirement.  This information would not be
compiled or reported but for these special requirements for livestock
protection collars.  While certain information on collar production may
be required by agencies that prepare monitoring reports, this
information would not, in the main, be duplicative of the confidential
production reports that all pesticide registrants must file.  The
reports are limited to one specific, heavily regulated product and
represent the most efficient means for others to generate and EPA to
receive this information.  This information may not, in all cases, be
available to the State lead agencies but for the specific reporting
requirements that they impose upon registrants of 1080 livestock
protection collars.

3(b).  Public Notice Required Prior to ICR submission to OMB

In proposing to renew this ICR, EPA is publishing a Federal Register
Notice that provides a 60-day public notice and comment period.

3(c).  Consultations

During the development of this renewal ICR, EPA staff will contact
appropriate stakeholders and ask them for their assessment of the
regulatory burden estimates expressed by the Agency in this ICR.  A
summary of these consultations will be provided in the supporting
statement during the second comment period.

3(d).  Effects of Less Frequent Collection

Annual monitoring reports are the only items pertaining to collars for
which EPA requires scheduled submissions.  Longer intervals between
submissions would make the information received and EPA's responses to
the reports less timely.  Longer intervals likely also would increase
the amount of time that would be needed to prepare each individual
report.  Reports submitted to date have been as short as a one-page
letter and as long as several pages of text followed by several pages of
tables and/or other attachments.  Data collection and table preparation
appear to be the major burdens associated with monitoring reports.  

	3(e).  General Guidelines

Requiring monitoring reports to be submitted once a year does not
conflict with the general guidelines for data requesters.  The required
reporting of nontarget incidents, in practice, has not generated any
rate of submissions that could be construed as being in violation of
these general guidelines.  The need for such incidents to be reported
rapidly is clear, however.  As discussed below in Section 5(c) of this
ICR, the reporting requirements for small entities have been limited as
much as is legally and responsibly possible.

3(f).  Confidentiality

Health and safety data submitted by registrants under FIFRA are
considered by EPA to contain no confidential business information (CBI).
 If registrants submit data that relates to trade secrets or commercial
or financial information, such information is protected from disclosure
under Section 10 of FIFRA. Confidential data submitted by registrants to
EPA in response to this particular information collection activity, it
will be 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 the 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
EPA.  The manual dictates that all CBI must be marked or flagged as
such, all CBI must be kept in secure (double-locked) areas, and all CBI
intended to be destroyed 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 information collection activity.  Further, this
information collection activity complies with the provisions of the
Privacy Act of 1974 and OMB Circular A-108.  The names and addresses of
both certified livestock protection collar applicators and any other
person who owns property on which livestock protection collars have been
or will be applied by a certified applicator are considered personal
information that will not be disclosed if ever in the possession of EPA.
Unsolicited information of a sensitive or private nature included in
monitoring reports already received, or submitted in the future, will be
protected from public release, in accordance with 7 USC 136i-1(b). 

4.	THE RESPONDENTS AND THE INFORMATION REQUESTED

4(a).	Respondents/NAICS Codes

This information collection activity applies to all certified pesticide
applicators that apply 1080 collars, to the pesticide manufacturer’s
whose products include 1080 collars, and to the government agencies
responsible for implementing and administering a 1080 collar monitoring
program.  Information available to EPA indicates that most, if not all,
of the certified applicators subject to this ICR are employees of the
Animal and Plant Health Inspection Service (APHIS) within the US
Department of Agriculture (USDA), although a small number of other
certified applicators may also apply 1080 collars.  The North American
Industrial Classification System codes assigned to the businesses and
other institutions participating in this program are 325320 (Pesticide
and other Agricultural Chemical Manufacturing), 926140 (Regulation of
Agricultural Marketing and Commodities) and 9241 (Administration of
Environmental Quality Control Programs).

4(b).	Information Requested

(i)  Data Items, Including Record Keeping Requirements

The data that certified livestock protection collar applicators are
required to record and maintain were outlined in the Initial Decision of
the Administrative Law Judge in the 1080 Predacide Hearings.  This
decision was upheld and amplified in the Final Decision rendered by Lee
Thomas, acting for then EPA Administrator William Ruckelshaus. 
Administrator Ruckelshaus recused himself from the decision due to his
earlier involvement in the 1972 decision, leading to the cancellation of
predacidal uses of Compound 1080.  These requirements are stipulated in
"Use Restriction 5" in the technical bulletin that is part of the
labeling for all livestock protection collar products registered as
pesticides in the United States.  Use Restriction 5, from a typical
technical bulletin, reads as follows:

"Each applicator shall keep records dealing with the use of livestock
protection collars and the results of such use.  Records shall be
maintained in accordance with appropriate State or Federal regulations
but for not less than two years following disposal or loss of collars. 
Such records shall include, but need not be limited to:

The number of collars attached on livestock.

The pasture(s) where collared livestock were placed.

The dates of each attachment, inspection, and removal.

The number and locations of livestock found with ruptured or punctured
collars and the apparent cause of the damage.

The number, dates, and approximate location of all collars lost.

The species, locations, and dates of all suspected poisonings of humans,
domestic animals or non-target wild animals resulting from collar use."

Use Restriction 6, from the same typical technical bulletin, requires
that "suspected" poisonings of "threatened or endangered species,…
humans, domestic animals or nontarget wild animals" be reported, within
three days of the incident, to a designated government agency (EPA
and/or the appropriate State lead agency for regulation of pesticides). 
EPA requires that certified applicators of livestock protection collars
keep and report only those records prescribed by Use Restrictions 5 and
6.

Registrants of livestock protection collars are required, by Use
Restriction 4 of the same typical technical bulletin, to 

". . . keep records of all collars sold or transferred at their address
of record.  Records shall include the name, address, state where
livestock protection collar certification was issued, certification
number of each recipient, and dates and numbers of collars sold or
transferred."

Use Restriction numbers and content vary somewhat from product to
product due to additional restrictions or considerations either proposed
by the registrants or required by State lead agencies. The complete list
of Use Restrictions can be found in Section V.B.2 of EPA’s 1995
Re-registration Eligibility Decision concerning sodium fluoroacetate
(see http://www.epa.gov/oppsrrd1/REDs/3073.pdf) 

(ii)  Respondent Activities

Certified livestock protection collar applicators are required by
product labeling to prepare and maintain records of various activities
associated with use and fate of livestock protection collars that they
purchase or obtain for use.  Preparing these records consists of writing
down what is done in normal use and handling of collars.

The use of livestock protection collars is a labor-intensive process. 
For a typical sheep operation, collar use involves the following
activities:

corralling sheep;

isolating target flocks;

capturing appropriate livestock and equipping them with collars;

redeploying target and main flocks in ways that are expected to direct
coyotes' attacks toward target flocks and away from the remainder of the
producer's sheep;

inspecting target flocks weekly (or more frequently) to account for
livestock alive, dead, or missing; to search for lost sheep or lost
collars; to capture livestock that require adjustments to collar
position or other hands-on attention; and to properly handle and dispose
of irreparably damaged collars; and, when collar use is to be
terminated; corralling target flocks, capturing collared livestock,
removing and inspecting collars, disposing of damaged collars, and
returning intact collars to proper secure storage.

The recordkeeping requirements add the need to record significant data
associated with collar use such as how many collars were used, where and
when they were used, how many were damaged, likely causes of such
damage, where collars went after use, and the occurrence of possible
nontarget exposure incidents.  The time and other costs associated with
preparation and maintenance of such records are conditions of collar use
which are required by the product’s labeling.  Such requirements are
not part of the subject ICR.  Burdens related to the ICR begin with the
compilation of applicator’s records and with activities associated
with assembling data for inclusion in monitoring reports.

Registrants and/or State lead agencies have developed their own
instruments that facilitate appropriate recordkeeping by certified
applicators.  State lead agencies typically require certified livestock
protection collar applicators to file periodic reports summarizing
collar use.  Data from these reports are included in annual monitoring
reports submitted to EPA by registrants or state lead agencies.  Other
data that appear in monitoring reports include summaries of numbers of
collars sold or otherwise legally circulated in the State and the number
and nature of violations detected with regard to use or handling of
livestock protection collars.

As with other registrants of pesticide products, livestock protection
collar registrants are required to file annual (confidential) production
reports.  These reports are required of all establishments that produce
pesticides or pesticide devices in the United States, pursuant to
Section 7 of FIFRA.  Since production does not equate with use, the ICR
is not duplicative of the requirement to submit annual production
reports.

5.	THE INFORMATION COLLECTED - AGENCY ACTIVITIES, COLLECTION

METHODOLOGY, AND INFORMATION MANAGEMENT

5(a).  Agency Activities

Reports of non-target species poisonings and other incidents included in
the annual monitoring reports filed with EPA by State lead agencies are
reviewed by the Insecticide-Rodenticide Branch, which initiates whatever
regulatory steps are warranted by the incident and places a copy of the
incident report in the registration file for the product involved in the
incident.  To date, no nontarget poisoning incidents have been reported
to EPA by State lead agencies.  Reasons for this appear to be the
limited extent to which collars are used, and the relatively low
potential for occurrence and detection of nontarget incidents.  However,
EPA has noted instances of violations and inaccuracies in inventory in
its reviews of monitoring reports.

EPA replies directly, in writing, to the originator of the report,
indicating whether the report is acceptable, whether additional details
are needed for the current report or future reports, and whether any
specific corrective steps are needed based upon items discussed in the
monitoring report.

	5(b).  Collection Methodology and Management

As the number of registered livestock protection collar products is very
small (6 at present) and very few reports are expected to be received,
no special provisions for data collection and management are needed. 
The reports submitted are handled and processed through mechanisms that
have been developed for handling a wide variety of submissions that
pertain to registered pesticide products.  These include routing the
submission through the routine review process, responding to the
submission in writing, and filing the submission and the response in the
relevant product's registration file.  These submissions are tracked by
EPA's Office of Pesticide Programs Information System (OPPIN).

5(c).  Small Entity Flexibility

Most users, including the private company that is a livestock
protection collar registrant, would qualify as small entities.  The
degree of imposition that these recordkeeping and reporting requirements
impose on such individuals is minimal, considering the limited degree of
latitude permitted by the Administrative Law Judge and the Administrator
of the EPA, the extreme toxicity of Compound 1080, and the great
potential for abuse of livestock protection collars should collars or
their contents get into the hands of irresponsible persons.  The main
purpose of the recordkeeping requirements is to promote responsible use
and handling.  The main purpose for requiring monitoring reports is to
establish a process through which it is mandatory to inform EPA of the
results of collar use.  EPA then can use the data from reports as bases
for future regulatory decisions.

The mandatory submission of periodic reports from applicators to State
lead agencies based on data that they are already required to collect
adds only a minimal amount of burden.  In the State where the livestock
protection collar product registered to a private firm is used, the lead
agency requires the registrant to submit sales and distribution
documents to the State.

5(d).  Collection Schedule

As nontarget exposure incidents must be reported within three days of
their occurrence there is no set schedule for collection of this
information.  Such reporting is required by product labeling and,
therefore, is not part of this ICR.  However, nontarget incidents also
would be reported and discussed in monitoring reports for the year in
which they occurred, with follow-up information regarding dispositions
of cases being indicated.    

Livestock protection collar annual monitoring reports are due on a date
prescribed as a condition of registration, usually February 15, for each
year after the first year in which collars may be used legally.

6.	ESTIMATING THE BURDEN AND COST OF THE COLLECTION

6(a).  Estimating Respondent Burden

EPA has revised the estimated burden associated with the 1080 livestock
protection collar annual monitoring reports over its 2003 estimates
based on the reports most recently submitted to EPA.  For the next 3
years, EPA expects that 40 certified applicators (30 for New Mexico and
10 for APHIS) will use and/or possess collars annually and,
consequently, contribute information to be used in monitoring reports. 
EPA does not expect the burden per applicator (40 hours) will decrease
over the next 3 years and remains unchanged over our 2003 estimate.  EPA
points out that this estimate was developed under the assumption that,
while perhaps unlikely, one non-target species poisoning incident will
occur per year and require 10 hours of burden.  In all, EPA estimates
the total annual burden for certified applicators of 1080 livestock
protection collars to be 1600 hours.

EPA anticipates that 3-5 registrants and/or State lead agencies will
file annual monitoring reports based upon information obtained from
those certified applicators.  Note that, except in the case of the
pesticide producer, the registrant is the State.  EPA assumed for the
sake of this burden analysis, as we did in 2003, that the number of
entities submitting annual monitoring reports is 4.  The estimated
respondent burden for this activity (77 hours) over the next 3 years is
unchanged over the 2003 estimates.  The annual burden of the States and
registrants is based on the annual monitoring report alone and not other
requirements related to use, administration, and regulation of 1080
livestock protection collars.  There are currently two States and one
registrant that have been reporting annually on livestock protection
collar use, with two other States possibly becoming involved in that
activity in the future.  EPA estimates the total annual burden for
agencies submitting annual monitoring reports to be 308 hours. 

As with other registrants of pesticide products, livestock protection
collar registrants (i.e., the producer(s), not the State agencies) are
required to file annual (confidential) production reports.  The annual
response burden for the submission of production reports is estimated to
be 45 hours, and is unchanged over EPA’s 2003 estimate.  EPA
recognizes that the time needed to prepare reports is affected primarily
by the extent of use and the number of applicator's to be covered by the
report during any given year.

Tables 1, 2, and 3 provide a breakdown of the collection activities per
respondent and a general overview of how the estimates were derived. 
The total annual response burden imposed upon certified applicators,
State agencies, and registrants associated with the use of 1080
livestock protection collars is estimated to be 1,953 hours.

6(b).  Estimating Respondent Costs

For a period of some years, when estimating labor rates for most OPP
program ICR renewals, the Agency adjusted the ICR renewal labor rates by
using the NASA Gross Domestic Product (GDP) Deflator Inflation
Calculator to index the labor cost for a particular year.  However, in
July 2006, Agency economists completely re-estimated wages, benefits,
and overhead for all labor categories for the pesticide industry, state
government and Agency employees.  The Agency analysis uses currently
available information on labor rates and other benefits from publicly
available websites.  A copy of the methodology used to re-estimate the
labor rates and formulas used to derive the fully loaded rates and
overhead costs are listed in attachment A.

To derive the labor rates for this ICR, Agency economists estimated the
wages for the management, technical, and clerical labor categories using
the methodology cited above.  The industry respondent costs for this
renewal for managerial, technical and clerical rates are estimated at
$100.86, $64.80, and $33.05 per hour, respectively.  These labor rates
are fully loaded and include benefits and overhead costs.  	

The state government respondent costs for this renewal for managerial,
technical and clerical rates are estimated at $71.41, $49.38, and $33.78
per hour, respectively.  These labor rates are fully loaded and include
benefits and overhead costs.  

	Based on EPA’s methodology for estimating pesticide-related
information collection request wages rates for industry, state, and EPA
- and based on EPA’s familiarity with the 1080 livestock protection
collars program and experiences with USDA - EPA estimates the
fully-loaded labor rate of a certified applicator of 1080 livestock
protection collars to be approximately equal to the state government
clerical labor rate of $33.78/hr (includes the base wage rate, benefits,
and overhead).

The total annual cost for all respondents associated with this
information collection activity is estimated to be approximately
$70,261.59; in summary:

Certified applicators:  $54,048

States:  $13,773.84

Registrants:  $2,439.75.

  

The annual cost for a single respondent is:  

Certified applicator:  $1,351.20

State:  $3,443.46  

Registrant:  $487.95.   

Tables 1 though 3 present information for estimating costs based on the
burden hours/costs per respondent.

Table 1. Annual Certified Applicator Burden/Cost Estimates

	

Collection Activities	

Burden Hours	

Cost



	

	

Certified Applicator ($33.78.38/hr)	





1.	

Read/hear rule or any collection instrument	

3	

$101.34



2.	

Receive training	

--	

--



3.	

Plan activities	

3	

$101.34



4.	

Create information	

3	

$101.34



5.	

Gather information	

18	

$608.04



6.	

Process and review information for accuracy	

5	

$168.90



7.	

Record, disclose, or display the information	

5	

$168.90



8.	

Store, file or maintain the information	

3	

$101.34



	

TOTAL	

40	

$1,351.20



ANNUAL BURDEN:  	Hour Total (40) x Number of Respondents (40) = 1,600

ANNUAL COST:  		Cost Total ($1,351.20) x Number of Respondents (40) =
$54,048



Table 2. Annual State Agency Burden/Cost Estimates

	

Collection Activities	

Burden Hours (per year)	

Cost



	

	

Management

($71.41/hr)	

Tech.

($49.38/hr)	

Clerical

($33.78/hr)	





1.	

Read/hear rule or any collection instrument	

0	

2	

0	

$98.76



2.	

Plan activities	

0	

10	

0	

$493.80



3.	

Create information	

0	

15	

0	

$740.70



4.	

Gather information	

0	

14	

0	

$691.32



5.	

Process, compile, and review information for accuracy and
appropriateness	

0	

13	

0	

$641.94



6.	

Record, disclose, display or report the information	

0	

0	

20	

$675.60



7.	

Store, file or maintain the information	

0	

0	

3	

$101.34



	

TOTAL	

0	

54	

23	

$3,443.46



ANNUAL BURDEN:  	Hour Total (77) x Number of Respondents (4) = 308

ANNUAL COST:  		Cost Total ($3,443.46) x Number of Respondents (4) =
$13,773.84

Table 3. Annual Registrant Burden/Cost Estimates

	

Collection Activities	

Burden Hours (per year)	

Cost



	

	

Management

($100.86/hr)	

Tech.

($64.80/hr)	

Clerical

($33.05/hr)	





1.	

Read/hear rule or any collection instrument	

0	

2	

0	

$129.60



2.	

Plan activities	

0	

1	

0	

$64.80



3.	

Create information	

0	

0	

0	

$0



4.	

Gather information	

0	

2	

0	

$129.60



5.	

Process, compile, and review information for accuracy and
appropriateness	

0	

1	

0	

$64.80



6.	

Record, disclose, display or report the information	

0	

0	

2	

$66.10



7.	

Store, file or maintain the information	

0	

0	

1	

$33.05



	

TOTAL	

0	

6	

3	

$487.95



ANNUAL BURDEN:  	Hour Total (9) x Number of Respondents (5) = 45

ANNUAL COST:  		Cost Total ($487.95) x Number of Respondents (5) =
$2,439.75

	6(c).  Estimating Agency Burden and Cost

The Agency's total annual burden associated with the 1080 livestock
program has changed based upon more accurate estimates of the resources
required to complete tasks specifically associated with annual
monitoring reports.  

To derive the labor rates for this ICR, Agency economists estimated the
wages for the management, technical, and clerical labor categories using
the methodology cited above.  The EPA labor rates for this renewal for
managerial, technical and clerical rates are estimated at $93.07,
$66.34, and $47.17 per hour, respectively.  These labor rates are fully
loaded and include benefits and overhead costs.  	For this ICR, we
estimate the annual burden to be 130 hours and the total annual cost to
be $9,490.

Table 4.  Annual Agency Burden/Cost Estimates

	

Collection Activities	

Burden Hours (annual)	

Cost



	

	

Tech.

($66.34/hr)	

Clerical

($47.17/hr)	





1.	

Develop any correspondence needed	

8	

0	

$530.72



2.	

Answer respondents’ questions	

2	

0	

$132.68



3.	

Review data submissions	

10	

0	

$663.40



4.	

Analyze data submissions	

4	

0	

$265.36



5.	

Store data	

2	

0	

$132.68



	

TOTAL	

26	

0	

$1,724.84



ANNUAL BURDEN:  	Hour Total (26) x Number of Respondents (5) = 130

ANNUAL COST: 		Cost Total ($1,724.84) x Number of Respondents (5) =
$8,624.20

6(d). Table 5.  Bottom Line Burden Hours and Costs/Master Table

	

Total Burden Hours	

Total

Cost ($)



Certified Applicator (Table 1)	

1,600	

$54,048



State (Table 2)	

308	

$13,773.84



Registrant (Table 3)	

45	

$2,439.75



Bottom Line Respondent Total	

1,953	

$70,261.59



Agency Total	

130	

$8,624.20



	6(e).	Reasons for Change in Burden

The total annual respondent burden hours have increased from the
previous ICR by 200 hours, from 1,753 to 1,953, based on increase in
expected numbers of certified applicators (from 35 certified applicators
in 2003 to 40 in the current ICR).  In addition, the total annual
respondent costs have increased from $54,800 to approximately $70,262
based on increases in number of responses and recalculated labor rates
(EPA methodology for estimating pesticide-related information collection
request wage rates for industry, state, and EPA.)  This change is an
adjustment.

	

	6(f).	Burden Statement

The annual respondent burden for the 1080 livestock collar program is
estimated to average 40 hours per certified applicator response, 77
hours per State agency response, and 9 hours per registrant
participating in the program.  According to the Paperwork Reduction Act,
“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.  For this collection, it
is the time reading the regulations, planning the necessary data
collection activities, conducting tests, 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 the
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.

Submit your comments, referencing Docket ID No. EPA-HQ-OPP-2006-0631 to
(1) EPA online using www.regulations.gov (our preferred method), or by
mail to: Public Information and Records Integrity Branch (PIRIB), Mail
Code: 7502C, Office of Pesticide Programs (OPP), Environmental
Protection Agency, 1200 Pennsylvania Ave., NW, Washington, DC 20460, and
(2) OMB by mail to: Office of Information and Regulatory Affairs, Office
of Management and Budget (OMB), Attention: Desk Officer for EPA, 725
17th Street, NW, Washington, DC 20503.

Use EPA’s electronic docket and comment system at www.regulations.gov,
to submit or view public comments, access the index listing of the
contents of the docket, and to access those documents in the docket that
are available electronically.  Once in the system, select “docket
search,” then key in the docket ID number identified above.   Please
note that EPA’s policy is that public comments, whether submitted
electronically or in paper, will be made available for public viewing at
www.regulations.gov as EPA receives them and without change, unless the
comment contains copyrighted material, CBI, or other information whose
public disclosure is restricted by statute.  For further information
about the electronic docket, go to   HYPERLINK
"http://www.regulations.gov"  www.regulations.gov .

Attachments to the Supporting Statement

Attachment A:	Methodology for Estimating OPP ICR Wage Rates for
Industry, State and EPA Labor Costs; Memo From Richard Keigwin, Director
Biological and Economic Analysis Division, to Bill Diamond, Arnold
Layne, Lois Rossi and Elizabeth Leovey July 25, 2006.   Available in the
docket for this information collection activity.

	

      The burden associated with the training of certified applicators
is accounted for under the ICR for the Agency Certification and Training
Program (EPA ICR# 0155; OMB Control No. 2070-0029). 

     In all but one case, the registrant is the State and, therefore,
covered under State burdens (Table 2).

July 25, 2006

