EPA ICR No. 0155.09                                       OMB Control
No. 2070-0029

ATTACHMENT E

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

Respondents to the Information Collection Request:

“Certification of Pesticide Applicators”

1. Dale W. Dubberly;  Florida Department of Agriculture and Consumer
Services

2. Larry G. Olsen;  U.S. Department of Agriculture, Cooperative
Extension Service; 		Michigan State University

3. Jack Peterson;  Arizona Department of Agriculture

Consultation Questions

OPP ICR - Certification of Pesticide Applicators

OMB No:  2070-0029;  EPA No:  0155.09

Contact information

Please fill in your name, title and contact information (at least e-mail
or phone number) where you prefer to be contacted.  We are required to
include your name and contact information in the next Federal Register
notice on this information collection request (ICR).

Name: Dale W. Dubberly

Title: Chief, Bureau of Compliance Monitoring

Address: 3125 Conner Blvd. Tallahassee, Fl 32399-1650

E-mail and phone number: dubberd@doacs.state.fl.us

Questions regarding the ICR document

Publicly Available Data

Is the information that the Agency seeks available from any public
source, or already collected by another office at EPA or by another
agency?  No.

If yes, where can one find the data?

Frequency of collection

Can the Agency collect the information less frequently and still produce
the same outcome? No.

Clarity of Instructions

Based on the regulations and Agency guidance, is it clear what you are
required to do and how to submit data? Yes. If not, what suggestions do
you have to clarify instructions?

Do you understand what records need to be kept? Yes.

Are submission formats clear and logical? Yes.

Electronic Reporting and Record keeping

Are the Agency web-based reporting tools working well?  Yes. What
improvements would you suggest for the reporting templates?

What benefits have electronic reporting brought you in terms of burden
reduction or greater efficiency in reporting? The primary benefit is the
amount of time preparing written reports vs. entering the data on-line.
A savings of staff and clerical time assembling the data.

Burden and Costs

Are the labor rates and burden hour estimates in the ICR supporting
statement accurate? Yes. Bear in mind that the estimates include only
burden hours and costs associated with the paperwork involved with this
ICR.

If you provide burden and cost estimates that are substantially
different from EPA’s, please provide an explanation of how you arrived
at your estimates.

The Agency has assumed there is no capital cost associated with this
activity.  Is that correct? I would suggest that IT be included as a
capital cost.

Are there other costs that should be accounted for that may have been
omitted? No.

Consultation Questions

OPP ICR - Certification of Pesticide Applicators

OMB No: 2070-0029; EPA No: 0155.09

Contact information

Please fill in your name, title and contact information (at least e-mail
or phone number) where you prefer to be contacted. We are required to
include your name and contact information in the next Federal Register
notice on this information collection request (ICR).

Name: Larry G. Olsen

Title: 	

	Extension State Agriculture Program Leader

	Entomology, Professor

	NC IPM Center Co-Director

Address: 

	108 Agriculture Hall

	Michigan State University

	East Lansing, MI 48824

E-mail and phone number:

	  HYPERLINK "mailto:olsenl@msu.edu"  olsenl@msu.edu 

	517-355-2308

Questions regarding the ICR document

Publicly Available Data

Is the information that the Agency seeks available from any public
source, or already collected by another office at EPA or by another
agency?

I am not aware of any other source of the certification information
requested by this notice. 

Restricted pesticide use records are required to be generated by rule
for the USDA Agricultural Marketing Service - Recordkeeping Branch.
However, these data are not required to be submitted and therefore are
not summarized nor publicly available. 

If yes, where can one find the data?

The USDA National Agriculture Statistic Service conducts surveys of
chemical use including both restricted and general use pesticides and
makes them available in both printed and electronic formats. 

Both sources of pesticide use information are more detailed than
required by EPA, so no additional burden is required by applicators as
proposed in this rule. 

There are also reports of pesticide use records available from private
sources at a cost.

Frequency of collection

Can the Agency collect the information less frequently and still produce
the same outcome?

This data needs to be collected at least annually as proposed in this
ICR. The data reports are necessary to justify the grant allocations
through the Cooperative Agreements.  

Clarity of Instructions

Based on the regulations and Agency guidance, is it clear what you are
required to do and how to submit data?  If not, what suggestions do you
have to clarify instructions?

The table on page 7 is not clear when it refers to “Respondent
Activities”. The respondents participating in the data collection
activity listed on page 5 in the NAICS codes are numerous, and most of
them do not need to report on all the individual items listed in the
table. Another column listing who has to report which item would be
helpful and clarify the intent of the ICR.

Section 5 “Information Collected…..”  Agency Activities is
misleading. Does this refer to EPA or the State Lead Agencies for
pesticide regulation?

The reminder of the ICR appears to be very clear in it’s directions. 

Do you understand what records need to be kept?

Once the clarification is made relative to who needs to report what, the
ICR is clear on what data needs to be generated and reported.

 

Are submission formats clear and logical?

Not having to report any of this information, I am not sure how
practical, clear and user friendly the submission formats are. 

Electronic Reporting and Record keeping

Are the Agency web-based reporting tools working well?  What
improvements would you suggest for the reporting templates?

Not having to report any of this information, I am not sure how
practical, clear and user friendly the reporting system is. However,
according to our State Lead Agency Pesticide Section manager, the
electronic reporting system works great and gets easier each year as
only updates are needed from previous year reports.  

  

What benefits have electronic reporting brought you in terms of burden
reduction or greater efficiency in reporting?

Not having to report any of this information, the electronic reporting
has no bearing on the USDA Cooperative Extension Service where I work.  


 

Burden and Costs

Are the labor rates and burden hour estimates in the ICR supporting
statement accurate?  Bear in mind that the estimates include only burden
hours and costs associated with the paperwork involved with this ICR.

The numbers presented look to be reasonable.

 

If you provide burden and cost estimates that are substantially
different from EPA’s, please provide an explanation of how you arrived
at your estimates.

Not needed.

The Agency has assumed there is no capital cost associated with this
activity.  Is that correct?

Yes.

Are there other costs that should be accounted for that may have been
omitted? 

No.

Consultation Questions

OPP ICR - Certification of Pesticide Applicators

OMB No:  2070-0029;  EPA No:  0155.09

Contact information

Please fill in your name, title and contact information (at least e-mail
or phone number) where you prefer to be contacted.  We are required to
include your name and contact information in the next Federal Register
notice on this information collection request (ICR).

Name:  Jack Peterson		

Title:  Associate Director, Environmental Services Division

Address:  AZ Dept. of Ag, 1688 W Adams St., Phoenix, AZ 85007

E-mail and phone number:     HYPERLINK "mailto:jpeterson@azda.gov" 
jpeterson@azda.gov    602-542-3575

Questions regarding the ICR document

Publicly Available Data

Is the information that the Agency seeks available from any public
source, or already collected by another office at EPA or by another
agency?

I am uncertain I understand this question.  State’s do record checks
on both commercial and private applicators.  USDA pays some states to do
this.  States or the EPA in Navajo country are the only ones who track
certified applicators renewals or initial.  

If yes, where can one find the data?

Frequency of collection

Can the Agency collect the information less frequently and still produce
the same outcome?

I believe once a year reporting would suffice if it were timed with when
the various information is used by the EPA.  It currently is reported
twice per year.  

Clarity of Instructions

Based on the regulations and Agency guidance, is it clear what you are
required to do and how to submit data?  If not, what suggestions do you
have to clarify instructions?

For tracking certified applicators – yes.  

Do you understand what records need to be kept?

Yes

Are submission formats clear and logical?

Yes for us using the CPARD system it is.  

Electronic Reporting and Record keeping

Are the Agency web-based reporting tools working well?  What
improvements would you suggest for the reporting templates?  

At this point nothing, however, should an issue arrive I would hope that
changes could be made without some sort of immense movement of the
earth.

We use the CPARD database and it is easy to use and I find it very
useful in looking into other state’s programs.  This is a help in
dealing with reciprocal certifications.

What benefits have electronic reporting brought you in terms of burden
reduction or greater efficiency in reporting?   See above.  This has
made reporting very easy.  

Burden and Costs

Are the labor rates and burden hour estimates in the ICR supporting
statement accurate?  Bear in mind that the estimates include only burden
hours and costs associated with the paperwork involved with this ICR.

Yes, the entire discussion seemed on the mark.

If you provide burden and cost estimates that are substantially
different from EPA’s, please provide an explanation of how you arrived
at your estimates.

The Agency has assumed there is no capital cost associated with this
activity.  Is that correct?  Yes – a person may choose to purchase
computer software to make these records

Are there other costs that should be accounted for that may have been
omitted?

No, I thought the cost review was very adequate

