Record of Consultations Between the U.S. Environmental Protection Agency
and

Respondents to the Information Collection Request:

“Pesticide Registration Fee Waivers”

(Consultations conducted in June, 2006)

Jim Kunstman;  PBI/Gordon

Jim Messina;  Exponent, Agent for SePro and Ajay North America

Terry Pizzarello;  Falcon Labs

Judith Thompson;  Hacco Inc.

Company Name: PBI/Gordon

Name of person consulted: Jim Kunstman

Date: 6/2006

Q: When preparing your waiver request did you consult the Questions and
Answers on the EPA website?

A: Yes, though less often as a result of experience

Q: If yes, did you find it helpful and informative?

A: Yes 

Q: What improvements or clarifications would you like to see?

A:  No suggestions at this time.

Q: Are you aware of the industry generated form?

A: Yes.  Assisted in generating it.

Q: Would you use the industry generated form?   If no, why not?	

Uses the industry generated form on the web.

Labor Rates:

Q: Would you say the following labor rates are accurate?

$130/hr management; $88/hr technical staff; $40/hr clerical –
estimates for management and technical staff are reasonable.  The
estimate for clericals in the company’s regulatory staff when
considering benefits may be low and $50/hr may be more accurate.

•The agency methodology for estimating the cost and burden associated
with the paperwork involved with preparing your waiver request is the
following 

Management: reading and comprehending the regulations, planning
activities to submit the waiver request: 10 hrs; Subsequent submissions:
2 hrs

The first submission during a maintenance fee billing cycle probably
requires 12 hours of management time to gather documents and
information.  Subsequent submissions during a maintenance fee cycle do
not require management time.  The company has an electronic system to
generate pesticide sales information.  The first application in the 2006
cycle was complex due to additional financial information to support
average global pesticide sales of less than $60 million.

Technical:  locating and preparing copies of taxes, audits, payroll
account statements, any market analysis, etc.?  40 hrs; Subsequent
submissions 40 hrs

Subsequent submissions in a maintenance fee cycle take 1 hour to prepare
because of the company’s automated systems.

Clerical: preparing the submission 10 hrs; Subsequent submissions 10hrs

Clerical assistance is not used because financial and personnel
information are kept at the management level.

Q: Did we miss anything?

Comments:

Mr. Kunstman asked about the electronic notification of fee payment. 
His observation was that after the move, the Agency’s system was not
notifying registrants of payments.

Mr. Kunstman also observed that fee waivers were being processed in less
time than previously.

Company Name: Exponent, Agent for SePro and Ajay North America

Name of person consulted: Jim Messina

Date: 6/2006

Q: When preparing your waiver request did you consult the Questions and
Answers on the EPA website?

A: Yes

Q: If yes, did you find it helpful and informative?

A: Yes

Q: What improvements or clarifications would you like to see?

A:  The overheads from a  presentation on fee waivers during a 2004 PRIA
workshop are hard to find.  It defined the criteria for a 50% and 100%
waiver.

Q: Are you aware of the industry generated form?

A:   Yes

Q: Would you use the industry generated form?   If no, why not?

Uses own with the same information and on company letterhead.

Labor Rates:

Q: Would you say the following labor rates are accurate?

$130/hr management; $88/hr technical staff; $40/hr clerical

As a consulting firm, charges are $175/hr management, $100/hr technical,
and considering the level of clerical expertise, $65/hr clerical.

•The agency methodology for estimating the cost and burden associated
with the paperwork involved with preparing your waiver request is the
following :

Management: reading and comprehending the regulations, planning
activities to submit the waiver request: 10 hrs; Subsequent submissions:
5 hrs

Technical:  locating and preparing copies of taxes, audits, payroll
account statements, any market analysis, etc.:  40 hrs; Subsequent
submissions 40 hrs

Clerical: preparing the submission 10 hrs; Subsequent submissions 10hrs

The first application took the most time.  Most of the hours were at the
technical level.  Management spends about 2 to 3 hours in directing and
reviewing the work on the first fee waiver submission.  The remainder of
the work is generally performed by technical staff.  Since a portion of
the work is conducted by the client company, the amount of clerical time
varies substantially and consequently difficult to estimate.  Between
Mr. Messina’s consulting firm and the client company, approximately 4
hours were spent on reading regulations and obtaining the tax
information, 1 to 4 hours copying the information and putting together
the submission, 1 to 4 hours by the client filing the information, and
1-6 hours to respond to any questions from the Agency.

Subsequent applications in the same year took less time, as the
information was copied.  At most 5 to 6 hours.  The first fee waiver in
a maintenance fee billing cycle takes about as much time as the first
fee waiver submission.

Q: Did we miss anything?

Comments:

Clients from smaller companies required more time to obtain information
because they may have neither filing systems nor support staff.

Company Name: Falcon Labs

Name of person consulted: Terry Pizzarello

Date: 6/16/2006

Q: When preparing your waiver request did you consult the Questions and
Answers on the EPA website?

A: Yes

Q: If yes, did you find it helpful and informative?

A: Yes 

Q: What improvements or clarifications would you like to see?

Q: Are you aware of the industry generated form?

A: Yes.  

Q: Would you use the industry generated form?   If no, why not?

A;  Yes

Labor Rates:

Q: Would you say the following labor rates are accurate?

$130/hr management; $88/hr technical staff; $40/hr clerical

Company is a small family operated company with no clerical staff. 
First pesticide application.

Management: reading and comprehending the regulations, planning
activities to submit the waiver request: 10 hrs; Subsequent submissions:
2 hrs

Most of the work was done by the company Vice-President, Ms. Pizzarello.
 She spent about 20 minutes reading the material on the web site.  Spent
about 1 hour with a pesticide consultant at $150/hr who answered those
questions that could not be answered from the web site.  Her accountant
spent about an hour collecting the financial information.  She estimates
that she spent a total of five hours on preparing and mailing the
application.

Technical:  locating and preparing copies of taxes, audits, payroll
account statements, any market analysis, etc.?  40 hrs; Subsequent
submissions 40 hrs

All work was performed by management.

Clerical: preparing the submission 10 hrs; Subsequent submissions 10hrs

Company used no clerical support.

Q: Did we miss anything?

Comments:

It was a simple process for the company.

Company Name: Hacco Inc.

Name of person consulted: Judith Thompson

Date: 6/16/2006

Q: When preparing your waiver request did you consult the Questions and
Answers on the EPA website?

A:  Obtained information on the process from another company.   Company
submitted their only fee waiver application in 2005.

Q: If yes, did you find it helpful and informative?

A:  Since the Ms. Thompson was not familiar with the process, the fee
waiver application was submitted in response to the Agency’s bill or
fee invoice.

Q: What improvements or clarifications would you like to see?

A:  Ms. Thompson would like to be able to find information on fee
categories or action codes and what needs to be submitted for a small
business easily on the web.  She had to pull the information from
different web locations. 

Q: Are you aware of the industry generated form?

A: Yes.  Used some of it and submitted a certification from their Chief
Financial Officer.

Q: Would you use the industry generated form?   If no, why not?

	Addressed the same questions - CFO signed certification

Labor Rates:

Q: Would you say the following labor rates are accurate?

$130/hr management; $88/hr technical staff; $40/hr clerical

Salary and benefits for technical staff are closer to $65/hr.  For
clerical staff $40/hr is in the ballpark, though $30/hr would also be
reasonable.

Management: reading and comprehending the regulations, planning
activities to submit the waiver request: 10 hrs; Subsequent submissions:
2 hrs

Management took 10 to 12 hours.

Technical:  locating and preparing copies of taxes, audits, payroll
account statements, any market analysis, etc.?  40 hrs; Subsequent
submissions 40 hrs

Technical staff took 35 hours which included all clerical duties.

Clerical: preparing the submission 10 hrs; Subsequent submissions 10hrs

No clericals – the company has minimum clerical staff.

Q: Did we miss anything?

Comments:

Ms. Thompson went to the web site to find where to send  her
applications.  The web site for the interpretations of the fee
categories and guidance on small businesses were forwarded to her.

