July
28,
2006
1
SUPPORTING
STATEMENT
FOR
AN
INFORMATION
COLLECTION
REQUEST
1.
IDENTIFICATION
OF
THE
INFORMATION
COLLECTION
1(
a)
Title
of
the
Information
Collection:
Pesticide
Product
Registration
Maintenance
Fee
ICR
Numbers:
EPA
No.:
1214.07
OMB
No.:
2070­
0100
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
due
to
expire
May
31,
2007.
This
collection
provides
a
practical
means
of
communication
between
the
registrants
and
Environmental
Protection
Agency's
Office
of
Pesticide
Programs
(
OPP)
to
collect
registration
maintenance
fees
from
pesticide
registrants
as
required
by
law.
Respondents
complete
and
submit
EPA
Form
8570­
30
(
Attachment
A)
indicating
the
respondent's
liability
for
the
registration
maintenance
fee.
No
changes
in
the
substance
or
in
the
method
of
collection
is
proposed
in
this
ICR
renewal
request.
The
first
Registration
Maintenance
Fee
filing
form
was
sent
to
approximately
5,000
pesticide
registrant
firms
in
1989.
Since
then,
the
number
of
respondents
has
slowly
declined
from
approximately
2800
firms
in
1990
to
2500
in
1991,
2350
in
1992,
2250
in
1993,
and
2200
in
1994.
Since
1994,
the
number
of
registrants
to
which
these
forms
are
sent
has
declined
steadily
to
a
total
of
1,720
in
January,
2006
Each
affected
firm
is
required
to
complete
the
filing
form
and
submit
their
fee
payment
by
January
15
of
each
year.

Annually,
the
Agency
provides
registrants
a
list
of
the
registered
products
currently
registered
with
the
Agency.
Registrants
are
provided
the
opportunity
to
review
the
list,
determine
its
accuracy,
and
remit
payment
of
the
maintenance
fee.
The
list
of
products
has
space
identified
for
marking
those
products
to
be
supported
and
those
products
that
are
to
be
canceled.
The
registrants
are
also
instructed
to
identify
any
products
on
the
list
which
they
believe
to
be
transferred
to
another
company,
and
to
add
to
the
list
any
products
which
the
company
believes
to
be
registered
that
are
not
on
the
Agency­
provided
list.
The
failure
to
pay
the
required
fee
for
a
product
will
result
in
cancellation
of
that
product's
registration.

The
form
is
printed
on
3
part
NCR
paper.
The
respondent
sends
one
copy
along
with
payment
to
the
Headquarters
Accounting
Operations
Branch
Lock
Box
in
St.
Louis
and
the
second
copy
together
with
the
annotated
list
of
products
to
OPP
via
a
designated
Washington
D.
C.
area
mail
box.
The
third
copy
is
retained
by
the
respondent
for
his
own
records.
Information
contained
on
the
forms
returned
to
OPP
is
used
to
check
and
ensure
that
the
proper
amount
of
fees
have
been
submitted
by
each
registrant.
In
the
past
there
has
been
a
need
for
follow­
up
with
some
registrants
when
the
information
provided
indicates
that
there
has
been
a
misunderstanding
of
the
requirements.
For
the
most
part
these
have
been
handled
by
telephone.
July
28,
2006
2
There
is
also
a
toll
free
information
line
available
which
registrants
may
use
to
ask
questions
and
resolve
problems
regarding
their
maintenance
fee
payments.
The
information
provided
also
serves
as
an
update
for
pesticide
product
information
files.
Updates
of
the
Agency's
files
are
an
ongoing
process.

2.
NEED
FOR
AND
USE
OF
THE
COLLECTION
2(
a)
Need/
Authority
for
the
Collection
On
October
25,
1988,
the
Federal
Insecticide,
Fungicide,
and
Rodenticide
Act
was
amended
in
several
significant
ways.
Among
the
new
provisions
of
the
Act
was
the
institution
of
registration
maintenance
fees
(
FIFRA)
Section
4(
i)(
5),
Attachment
B.
These
fees
apply
to
all
products
registered
under
Section
3
and
Section
24(
c)
of
FIFRA.
The
fees
are
to
be
paid
annually
for
each
product
registered
and
payable
on
January
15
of
each
year
beginning
in
1989.
The
authority
to
collect
fees
under
the
1988
amendments
would
have
terminated
on
September
30,
1997.
However
the
Food
Quality
Protection
Act
extended
the
authority
to
collect
these
fees
until
September
30,
2001.
The
EPA
Appropriation
Bills
of
FY
2002
and
FY
2003
also
extended
the
authority
to
collect
maintenance
fees.
The
Pesticide
Registration
Improvement
Act
(
PRIA),
which
became
effective
on
March
23,
2004
further
extended
the
authority
to
collect
maintenance
fees
thru
fiscal
year
2008.

In
order
to
provide
an
efficient
system
to
bill,
collect,
and
account
for
registration
maintenance
fees,
the
Agency
has
used
a
filing
form
which
is
sent
to
all
registrants
of
currently
active
products.

2(
b)
Practical
Utility/
Users
of
the
Data
The
data
are
used
by
the
Agency
to
ensure
that
the
fees
prescribed
by
FIFRA
have
been
paid
by
each
registrant.
The
information
is
also
used
to
adjust
OPP's
computer
files
to
reflect
changes
in
the
status
of
registrations
resulting
from
registrant
responses.

3.
NON
DUPLICATION,
CONSULTATIONS,
AND
OTHER
COLLECTION
CRITERIA
3(
a)
Non
duplication
The
specific
information
required
under
this
ICR
does
not
exist
in
data
bases
at
EPA
or
any
other
agency.
To
determine
the
amount
of
maintenance
fees
accurately,
the
Agency
and
the
registrant
must
have
a
joint
understanding
concerning
the
number
of
products
currently
registered.
An
alternative
approach
considered
prior
to
seeking
approval
for
the
original
maintenance
fee
filing
form
(
ICR)
was
to
simply
notify
registrants
that
fees
were
due
for
each
of
their
products
according
to
a
fee
schedule.
The
registrant
would
submit
payment
according
to
their
best
information
concerning
the
number
of
registrations
that
they
wanted
to
support.
However,
if
a
registrant
submitted
payment
that
did
not
correspond
to
the
fee
schedule,
the
July
28,
2006
3
Agency
would
be
in
a
position
of
either
unilaterally
determining
which
registrations
to
cancel,
or
contacting
each
registrant
to
determine
that
registrant's
intentions.
This
option
was
considered
to
be
inefficient,
and
not
in
the
best
interest
of
the
Agency
or
the
registrants.

3(
b)
Public
Notice
Required
Prior
to
ICR
Submission
to
OMB
Pursuant
to
5
CFR
1320.8(
d),
EPA
is
publishing
a
Federal
Register
(
FR)
notice
soliciting
comment
on
this
information
collection
activity
and
the
Agency's
intent
to
renew
the
OMB
approval
of
this
ICR.
The
FR
notice
and
the
proposed
renewal
ICR
as
well
as
any
public
comment
are
located
in
the
docket
for
this
action,
which
can
be
accessed
at
http://
www.
regulations.
gov
using
the
docket
indentifier
EPA­
HQ­
OPP­
2006­
0666.

3(
c)
Consultations
During
preparation
of
this
ICR
renewal,
EPA
staff
will
contact
representatives
from
a
cross­
section
of
pesticide
registrant
companies
by
e­
mail
and
telephone
to
seek
feedback
on
the
PRIA
waiver
process.
Their
responses
to
EPA's
consultation
efforts
will
be
summarized
and
made
publicly
available.

In
addition
to
these
consultation
activities,
dialogue
between
industry
and
the
Agency
on
the
PRIA
waivers
process,
content,
definitions,
format,
and
timing
is
frequent
and
on­
going.
In
addition
to
phone
conversations,
e­
mails,
and
letters,
Agency
staff
participate
in
meetings
with
individual
registrants
as
well
as
gatherings
of
large
groups
of
registrants
from
time
to
time.
These
communications
permit
an
exchange
of
issues,
problems,
and
solutions
on
many
issues.

3(
d)
Effects
of
less
Frequent
Collection
The
payment
of
maintenance
fees
for
all
pesticide
products
is
mandated
in
FIFRA
amendments
to
occur
annually.
Thus,
there
can
be
no
option
other
than
to
require
a
minimum
submission
of
the
filing
form
once
a
year.
Less
frequent
information
collection
in
this
area
would
violate
the
statute.

3(
e)
General
Guidelines
With
respect
to
the
PRA
imposed
guidelines
contained
in
5
CFR
1320.6,
the
filing
form
has
the
following
features:

 
The
respondents
are
required
to
respond
on
an
annual
basis
and
hence
the
quarterly
response
limitation
is
not
applicable
 
The
respondents
are
not
required
to
keep
records
relating
to
this
information
collection
for
a
period
of
more
than
3
years.
July
28,
2006
4
 
This
information
collection
activity
does
not
utilize
a
statistical
survey.
The
requirement
to
collect
maintenance
fees
for
all
products
means
that
all
pesticide
registrants
submit
replies.

 
The
respondents
are
given
at
least
30
days
to
respond.

 
The
information
collection
under
this
ICR
can
be
held
confidential
under
long
established
procedures
for
properly
handling
Confidential
Business
Information.
Confidentiality
is
discussed
in
more
detail
below.

 
The
respondents
are
not
required
to
submit
more
than
an
original
and
two
copies
of
any
document.

 
The
ICR
is
for
processing
of
fees
mandated
by
Congress.
No
provision
in
the
law
allows
for
remuneration
of
respondents.

 
This
information
collection
activity
uses
automation
to
the
extent
that
is
practicable.
For
example,
the
name
and
address
of
each
respondent
is
pre­
printed
by
computer,
alleviating
the
registrant
of
the
burden
of
writing
it
in.
A
computer
generated
listing
of
products
is
also
provided,
and
the
registrant
must
only
circle
an
appropriate
keyword
(
CAN,
PAY)
etc.
Because
the
regulated
community
runs
the
gamut
from
large
multinational
corporations
to
small
sole
proprietor
firms,
some
with
limited
technological
capabilities,
the
Agency
believes
that
a
simple
filing
form
is
most
applicable.

 
As
discussed
in
Section
4(
c),
this
form
requires
the
minimum
amount
of
information
from
all
firms.
July
28,
2006
5
 
This
collection
activity
does
not
apply
to
grantees.

3(
f)
Confidentiality
Product
registration
maintenance
fee
information
submitted
by
pesticide
registrants
under
this
ICR
are
considered
by
OPP
to
contain
no
confidential
business
information
(
CBI).
If,
however,
registrants
submit
data
that
contains
CBI
or
relates
to
trade
secrets
or
commercial
or
financial
information,
such
information
is
protected
from
disclosure
under
section
10
of
FIFRA.
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
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.
Further,
this
information
collection
activity
complies
with
the
provisions
of
the
Privacy
Act
of
1974
and
OMB
circular
A­
108.

4.
THE
RESPONDENTS
AND
THE
INFORMATION
REQUESTED
4(
a)
Respondents/
NAICS
Codes
All
pesticide
registrants
holding
currently
active
registrations
under
FIFRA
section
3
and
Section
24(
c)
are
subject
to
this
information
collection
activity.
These
include
pesticide
companies
and
state
governments.
The
North
American
Industrial
Classification
System
(
NAICS)
code
is
325320
(
Pesticide
and
other
Agricultural
Chemical
Manufacturing)
and
9641
(
Regulation
of
Agricultural
Marketing
and
Commodities).

4(
b)
Information
Requested
(
i)
Data
Items,
Including
Record
Keeping
Requirements
Part
A
­­
Registrant
Identification
Registrant
Name
and
Address
are
pre­
printed.
The
registrant
needs
to
complete
this
section
only
to
indicate
a
name
and/
or
address
change.
July
28,
2006
6
Part
B
­­
EPA
Company
Numbers
If
a
firm
has
been
assigned
more
than
one
company
number,
the
firm
may
combine
its
fee
payments
under
a
single
number
by
writing
in
all
of
the
company
numbers
for
which
the
firm
is
paying.

Part
C
­­
Maintenance
Fee
Calculation
The
respondent
must
fill
in
the
number
of
registrations
for
which
he
is
paying
the
fee,
number
of
registrations
which
he
believes
to
be
transferred,
number
of
registrations
to
be
canceled,
number
of
registrations
which
he
believes
to
be
in
error,
total
amount
of
fee
due,
and
check
number.

Part
D
­­
Authorized
Company
Representative
or
Agent
The
respondent
must
print
the
name
and
title
of
the
company
representative
or
agent.
The
respondent
must
sign
and
date
the
form,
and
provide
the
telephone
number
of
the
respondent.

(
ii)
Respondent
Activities
Activities
in
which
a
registrant
must
engage
in
order
to
comply
with
this
collection
include
the
following:

Read
instructions
Read
accompanying
instructions
to
understand
how
to
fill
out
form,
annotate
list
of
registrations,
and
calculate
fee
due.

Plan
Activities
Plan
the
activities
necessary
to
respond
to
the
billing.

Review
Information
Review
the
attached
listing
of
registrations
and
compare
to
the
firm's
records.

Complete
Paperwork
Annotate
attached
listing
of
registrations
to
indicate
which
products
the
respondent
is
paying
and
which
products
are
to
be
canceled
or
transferred.
July
28,
2006
7
File
Information
Maintain
a
copy
of
the
form
in
company
files.
Although
this
is
not
required,
the
Agency
assumes
that
most
companies
will
retain
this
information
as
a
common
business
practice.

5.
THE
INFORMATION
COLLECTED
­
AGENCY
ACTIVITIES,
COLLECTION
METHODOLOGY,
AND
INFORMATION
MANAGEMENT
5(
a)
Agency
Activities
The
following
activities
are
necessary
to
conduct
the
information
request:

Develop
Letter
Prepare
a
cover/
transmittal
letter
to
be
included
in
the
package.

Answer
Questions
Staff
a
toll
free
information
line
to
respond
to
any
questions
that
respondents
have
regarding
payment
requirements.

Review
Submissions
Review
submitted
forms
and
annotated
listings
for
completeness.

Record
Submissions
Record
information
provided
by
respondents
into
a
tracking
system.
Make
adjustments
to
Product
Information
Master
Files
as
required.

Verify
Payments
Cross
check
payment
information
from
Financial
Management
Division
to
ensure
that
payment
has
been
received.

Store
Data
Image
all
forms,
listings,
and
telephone
conversation
logs
for
archiving.

5(
b)
Collection
Methodology
and
Management
For
the
past
17
years,
the
Agency
has
employed
the
same
method
of
collecting
maintenance
fees.
This
method
involves
using
OPP
master
files
of
product
information
to
identify
the
firms
to
which
the
billing
information
is
to
be
sent.
Computer
generated
listings
of
products
July
28,
2006
8
are
mailed
to
each
firm
along
with
the
Maintenance
Fee
Filing
Form.
The
registrant
is
instructed
to
circle
the
word
PAY,
CAN,
XFR,
ERR,
next
to
each
Registration
Number
to
indicate
if
he
wants
to
pay
for
the
registration,
cancel
the
registration,
indicate
if
he
believes
that
the
registration
was
transferred,
or
if
the
registration
is
listed
in
error.

The
list
of
registrations
is
pre­
loaded
into
a
tracking
file,
and
only
the
PAY,
CAN,
XFR,
ERR
indicator
is
keyed
manually
for
each
product.
Company
name
and
address
information
is
also
pre­
loaded
reducing
the
data
entry
burden
for
the
maintenance
fee
filing
forms.
The
total
number
of
products
for
each
company
is
calculated
by
computer,
and
totals
entered
from
the
filing
form
are
verified
by
computer
to
ensure
that
all
items
balance.
In
addition,
data
entry
for
all
forms
is
quality
checked
visually.

Receipt
of
payment
is
entered
by
the
Financial
Management
Division
into
the
Integrated
Financial
Management
System
(
IFMS).
This
information
is
then
extracted
and
posted
to
the
maintenance
fee
tracking
system
to
close
out
each
record.
Results
are
made
available
to
OPP
staff
on
request
as
soon
as
the
information
is
entered
into
the
tracking
system.

5(
c)
Small
Entity
Flexibility
The
Agency's
filing
form
for
the
submission
of
maintenance
fees
requires
the
minimum
amount
of
information
that
is
needed
to
provide
adequate
communication
between
pesticide
product
registrants
and
the
Agency.
The
needs
of
small
businesses
were
of
primary
concern
in
designing
the
filing
form.
The
respondents
are
asked
to
provide
only
readily
available
information.
Experience
indicates
that
there
is
no
need
for
more
involved
reporting
by
large
business
concerns
to
meet
Agency
needs.
Hence,
there
is
no
separate
requirement
for
small
businesses
versus
large
business.
Only
the
basic
requirement
to
identify
products
that
firms
wish
to
continue
to
support
is
imposed
on
all
registrants.
In
1990
the
fee
structure
was
changed
to
provide
a
50%
discount
on
the
first
product
supported.
Therefore,
companies
with
only
one
registered
product
received
the
greatest
benefit
from
the
discount.

5(
d)
Collection
Schedule
The
payment
of
maintenance
fees
for
all
pesticide
products
is
mandated
in
FIFRA
to
occur
annually.
Thus,
there
can
be
no
option
other
than
to
require
a
minimum
submission
of
the
filing
form
once
a
year.
Less
frequent
information
collection
in
this
area
would
violate
the
statute.

6.
ESTIMATING
THE
BURDEN
AND
COST
OF
THE
COLLECTION
6(
a)
Estimating
Respondent
Burden
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
methods
such
as
the
NASA
Gross
Domestic
Product
(
GDP)
Deflator
Inflation
Calculator
to
index
the
labor
cost
for
a
July
28,
2006
9
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
C.

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
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.

Experience
has
shown
that
the
average
burden
per
respondent
has
remained
at
approximately
1
hour.
The
agency
believes
that
the
decline
in
actual
burden
hours
is
due
to
the
fact
that
registrants
now
have
17
years
of
experience
with
the
form,
and
the
attrition
of
former
pesticide
firms
that
no
longer
hold
pesticide
registrations
not
required
to
complete
this
form.
In
2006,
1,720
firms
responded
to
the
collection
request.
A
summary
of
firms
and
their
number
of
registrations
is
provided
below.

Number
of
Products
Number
of
Registrants
Registrants
Cumulative
total
Cumulative
%

1
 
10
1,477
1,477
86%

11
 
20
95
1,572
91%

21
 
50
78
1,650
96%

50
­
100
32
1,682
98%

>
100
38
1,720
100%

Based
on
conversations
with
several
respondents,
we
believe
that
the
average
time
required
to
complete
the
maintenance
fee
filing
form
depends
upon
the
number
of
registrations
held
by
the
registrant.
A
list
of
the
registrants
contacted
is
contained
in
Attachment
D.
Below
is
the
breakdown
of
the
burden
associated
with
the
2006
maintenance
fee
filing
based
on
registrantsupplied
information.

Number
of
Products
Avg
Time
(
hrs.)
Number
of
Registrants
Tot.
Hr.

1
 
10
0.75
1,477
1108
11
 
20
1.0
95
95
July
28,
2006
10
21
 
50
2.0
78
156
51
 
100
3.0
32
96
>
100
5.0
38
190
Totals
1,720
1,645
1645
(
total
hours)
/
1720
(
number
of
respondents)
=
0.96
hr.
0.96
hr
=
average
amount
of
time
required
to
complete
the
maintenance
fee
filing
form
These
calculations
were
made
using
the
average
case
scenario.
The
average
case
burden
was
developed
from
the
above
table.

Respondent
Burden
For
Completing
The
Maintenance
Fee
Filing
Form:
Burden
Hours
(
per
form)

Collection
Activities
Management
Technical
Clerical
Hour
s
1.
Read
Instructions
0.25
0.25
2.
Plan
Activities
0.20
0.20
3.
Review
Information
0.20
0.20
4.
Complete
Paperwork
0.20
0.20
5.
File
Information
0.11
0.11
Total
0.40
0.45
0.11
0.96
Total
Annual
Burden:
Avg.
Hr.
per
form
(
0.96)
X
No.
Of
Respondents
(
1720)
=
1645
hrs.

6(
b)
Estimating
Respondent
Costs
The
table
below
describes
the
average
costs
for
completing
one
maintenance
fee
filing
form.
The
average
hourly
burden
was
derived
from
conversations
with
a
selected
group
of
respondents,
and
is
described
above.

Respondent
Costs
for
Completing
the
Maintenance
Fee
Filing
Form:
Burden
Hours
(
per
form)

Collection
Activities
Mgmt.
($
100.86/
hr)
Tech.
($
64.80/
hr)
Cler.
($
33.05/
hr)
Costs
($)

1.
Read
Instructions
0.25
16.20
July
28,
2006
11
2.
Plan
Activities
0.20
20.17
3.
Review
Information
0.20
20.17
4.
Complete
Paperwork
0.20
12.96
5.
File
Information
0.11
3.64
TOTALS
0.4
(
40.34)
0.45
(
29.16)
0.11
(
3.64)
73.14
0.4
Mgmt
Hr.
X
$
100.86
=
40.34
0.45
tech
Hr.
X
$
64.80
=
29.16
0.11
cler
Hr.
X
$
33.05
=
3.64
$
73.14
average
cost
for
completing
one
maintenance
fee
filing
form
July
28,
2006
12
$
73.14
(
average
cost
for
completing
one
maintenance
fee
filing
form)
X
1720
(
respondents)
=
$
125,801
total
cost
6(
c).
Estimating
Agency
Burden
and
Cost
The
cost
to
the
Federal
Government
for
this
ICR
is
estimated
to
be
$
86,319.
This
is
based
on
actual
experience,
and
the
following
table
and
calculations
reflect
averages.

Agency
Burden
Hours
per
filing
form
and
Total
Cost
Collection
Activities
Mgmt.
($
93.07/
hr)
Tech.
($
66.34/
hr)
Cler.
($
47.17/
hr)
Cost
($)

1.
Generate
Listings/
Mass
Mailing*
8
16
1285.44
2.
Pre­
load
Tracking
Data*
4
265.36
3.
Receive/
Review
Submissions
0.2
16,226.4
8
4.
Enter
Data
into
Tracking
Sys.
0.2
16,226.4
8
5.
Reconcile
Discrepancies
0.5
3,317
6.
Respond
to
Questions
0.5
9,951
7.
Verify
Payment
0.2
22,820.9
6
8.
File
Documents
0.2
16.226.4
8
Total
13.2
16.6
86,319.2
0
*
Estimated
burden
hours
for
items
1
and
2
reflect
the
entire
set
of
forms
and
the
entire
set
of
data
pre­
loaded.
The
unit
cost
for
this
operation
is
so
small
that
it
would
not
be
appropriate
to
express
these
figures
in
terms
of
units.
All
other
figures
reflect
the
burden
for
processing
an
average
filing
form.
Item
3:
1720
responses
X
0.2
hr.
X
$
47.17
per
hour
=
16,226.48
Item
4:
1720
responses
X
0.2
hr.
X
$
47.17
per
hour
=
16,226.48
Item
5:
100
discrepancies
X
0.5
hr.
X
$
66.34
per
hour
=
3,317
Item
6:
300
questions
X
0.5
hr
X
$
66.34
per
hour
=
9,951
Item
7:
1720
payments
X
0.2
hr
X
$
66.34
per
hour
=
22,820.96
July
28,
2006
13
Item
8:
1720
responses
X
0.2
hr.
X
$
47.17
per
hour
=
16,226.48
6(
d).
Bottom
Line
Burden
Hours
and
Cost
Tables
Total
Annual
Respondent
and
Agency
Burden
and
Costs
Total
Hours
Costs
Annual
Respondent
Burden/
Cost
Estimates
1,645
$
125,801
Annual
Agency
Burden/
Cost
Estimates
1,604
$
86,319
6(
e)
Reasons
for
Change
in
Burden
The
total
annual
burden
for
respondents
associated
with
this
renewal
is
1,645
hours.
This
reflects
a
decrease
of
118
hours
from
the
last
renewal
period.
The
decrease
represents
the
steady
decline
of
the
number
of
pesticide
registrants
and,
therefore,
participation
under
this
program.
In
2006,
the
projected
estimate
is
1,720
registrants.
This
represents
a
decrease
of
157
respondents
from
the
1,877
reported
in
the
last
ICR
renewal.
The
average
time
required
to
complete
the
maintenance
fee
filing
form
depends
upon
the
number
of
registrations
held
by
the
registrant.
In
addition
to
fewer
respondents
in
2006,
a
smaller
percentage
of
registrants
held
a
small
number
of
registered
products.
This
shift
to
a
slightly
larger
average
number
of
registrations
per
registrant
resulted
in
a
slight
increase
in
the
average
burden
hours
required
to
complete
the
form,
from
0.94
hours
in
the
last
ICR
renewal,
to
0.96
hours.

Labor
rates
for
both
respondents
and
Agency
personnel
in
this
ICR
have
decreased.
In
previous
renewal
cycles,
the
Agency
only
adjusted
the
labor
rates
to
account
for
inflation.
However,
for
this
renewal,
Agency
economists
have
completely
re­
estimated
labor
rates,
benefits
and
overhead
costs
for
both
respondents
and
Agency
personnel.
This
Agency
analysis
was
completed
in
July,
2006.
The
Agency
believes
this
is
a
more
realistic
estimate
of
the
average
respondent
and
Agency
costs.
As
a
result
of
both
the
smaller
number
of
respondents
and
the
lower
estimated
labor
rates,
there
is
a
decrease
of
$
52,889
in
the
estimated
total
annual
respondent
cost
(
from
$
178,690
to
$
125,801).
This
change
is
an
adjustment.

6(
f)
Burden
Statement
The
annual
"
respondent"
(
applicant)
burden
for
the
Pesticide
Product
Registration
July
28,
2006
14
Maintenance
Fee
program
is
estimated
to
average
0.96
hours
per
form.
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
appear
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.

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.
All
documents
in
the
docket
are
listed
in
the
docket
index.
Although
listed
in
the
index,
some
information
is
not
publicly
available,
e.
g.,
CBI
or
other
information
whose
disclosure
is
restricted
by
statute.
Certain
other
material,
such
as
copyrighted
material,
is
not
placed
on
the
Internet
and
will
be
publicly
available
only
in
hard
copy
form.
EPA
has
established
a
public
docket
for
this
ICR
under
Docket
ID
No.
EPA­
HQ­
OPP­
2006­
0660,
Publicly
available
docket
materials
are
available
either
in
the
electronic
docket
at
http://
www.
regulations.
gov,
or,
if
only
available
in
hard
copy,
at
the
OPP
Regulatory
Public
Docket
in
Rm.
S­
4400,
One
Potomac
Yard
(
South
Building),
2777
S.
Crystal
Drive,
Arlington,
VA.
The
hours
of
operation
of
this
Docket
Facility
are
from
8:
30
a.
m.
to
4
p.
m.,
Monday
through
Friday,
excluding
legal
holidays.
The
Docket
telephone
number
is
(
703)
305­
5805.

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.
EPA
­
HQ­
OPP­
2006­
0660
and
OMB
Control
No.
2070­
0100
in
any
correspondence.
July
28,
2006
15
ATTACHMENTS
TO
THE
SUPPORTING
STATEMENT
Attachment
A
EPA
Form
8570­
30
­
Pesticide
Registration
Maintenance
Fee
Filing
Form
Available
electronically
at
www.
epa.
gov/
opprd001/
forms/
8570­
30.
pdf
and
in
the
docket
for
this
information
collection
activity.

Attachment
B:
The
Federal
Insecticide,
Fungicide,
and
Rodenticide
Act
(
FIFRA)
Section
4(
i)(
5).
Available
electronically
at
http://
www.
epa.
gov/
pesticides/
fifra.
htm
and
in
the
docket
for
this
information
collection
activity.

Attachment
C
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.
