SUPPORTING STATEMENT FOR AN

INFORMATION COLLECTION REQUEST (ICR)  

1.	IDENTIFICATION OF THE INFORMATION COLLECTION

1(a) Title: Use of Consumer Research in Developing Improved Labeling for
Pesticide Products 

	EPA ICR No.:  2297.01

	OMB Control No.:  2070-New

	1(b) Short Characterization

The Environmental Protection Agency (EPA or the Agency) is proposing to
initiate a new information collection activity.  EPA intends to initiate
a voluntary information collection for consumer research involving the
conduct of surveys, focus groups and one-on-one interviews to test
various versions of pesticide product labels and other informational
materials developed for the general public.  The purpose for such
consumer research is to identify the consumer’s understanding of the
information on a pesticide product label.  EPA would use this
information to formulate decisions and policies affecting the labeling
of pesticide products.  The ultimate goal of this activity is to assure
that the consumer can effectively use this information to select the
pesticide product most likely to meet their needs and readily understand
label instructions regarding product use.  The collected information
would be used to revise pesticide product labels and to create other
user friendly consumer information materials.  It is anticipated that
several surveys, focus groups, and/or one-on-one interviews would be
conducted over the life of the ICR.

2.  NEED FOR AND USE OF THE COLLECTION 

	2(a) Need/Authority for the Collection 

With few exceptions, section 3 of the Federal Insecticide, Fungicide and
Rodenticide Act (FIFRA), requires all pesticides sold or distributed in
the United States to be registered by EPA.  (See attachment A). 
Pesticide registration is the process through which EPA examines the
ingredients of a pesticide; the site or crop on which it is to be used;
the amount, frequency and timing of its use; and storage and disposal
practices.  EPA evaluates the pesticide to ensure that it will not have
unreasonable adverse effects on humans, the environment and non-target
species.  The label on a pesticide package or container, and the
accompanying instructions are a key part of pesticide regulation. The
label provides critical information about how to handle and safely use
the pesticide product and avoid harm to human health and the
environment.  Every pesticide product must bear a label containing the
information specified by FIFRA as established in EPA’s labeling
regulations at 40 CFR 156.10. (See attachment B)

EPA’s pesticide product labeling requirements were primarily developed
for agricultural products.  However, overtime the market for FIFRA
regulated consumer products has grown.  Today, there is concern that the
current label requirements do not adequately address the distinction
between the needs of consumers and the needs of agricultural sector
users.  The Agency’s labeling regulations need to be updated to more
adequately address consumer needs.   

However, before initiating any formal policy or other regulatory
decision making activities to update label regulations the Agency needs
to understand basic information about consumer needs and behavior when
choosing to use a pesticide product.  Such information could readily be
obtained via various types of consumer surveys such as telephone, mail,
shopping mall intercept, internet, or in-person focus groups. Testing of
existing and/or proposed label statements in realistic situations with
typical consumers is needed to determine the clarity and
understandability of a pesticide product label, and what these label
statements are likely to communicate to consumers.  This information
collection will allow EPA to gather the necessary information about
consumer behavior, their comprehension of the information that is on a
pesticide label, and how a consumer uses this information to make their
decision to purchase.  This collection information will provide support
for the Agency’s policy and regulatory activities to revise label
language, design label metrics, and revise its labeling regulations.

	2(b) Practical Utility/Users of the Data

Insect repellents are public health pesticide products that work by
repelling insects such as mosquitoes and ticks that can harbor
microorganisms that are infectious to humans.  The diseases insects can
carry are an increasing threat to human health.  The following 
illustrates the increasing occurrence of several insect-transmitted
diseases:

Rocky Mountain Spotted Fever  (In 1997 there were 400 cases per year. 
In 2002 there were 1150 cases.  The fatality rate is greater than 20% if
untreated.)

Lyme Disease  (In 1992 there were 9000 cases per year.  Currently more
than 20,000 cases are reported each year.)

West Nile Virus  (In 1999 there were  62 cases per year, with 7 deaths. 
In 2006 there were over 4,000 cases, with 161 deaths.   In 1999 the
virus was found in one state.  In 2005, the virus was in 92 % of the
states.)

These increasing occurrences have created more media attention on the
risks of insect-transmitted diseases and as a result the public is
seeking more information on the types of insect repellents which can be
used for disease avoidance and effective self-protection.  There are
three primary methods of protecting oneself from insect bites:

Avoid areas with high concentrations of insects

Wear protective clothing

Use an insect repellent

In many cases, an insect repellent is the most feasible method of
protection.  Since disease can be transmitted via a single bite it is
important to assure that the insect repellent is efficacious and is
applied correctly.

The Agency will use this information collection to develop policy and
regulation to provide consistent, meaningful and transparent risk
reduction and efficacy information to the public.  Any new policy
developed would be implemented to improve insect repellent pesticide
labels and other supporting consumer materials. 

The Agency believes that any user of an insect repellent should be able
to locate on the label information such as:

How much of the repellent to apply to their skin

The pests that the product effectively kills or repels

How often to reapply the product

Understand how to store, and dispose of products safely and with minimal
effect on the environment

The consumer should also be able to compare products intended for
similar uses. 

EPA evaluates and controls insect repellent risks through the
registration process.  The existing labels on consumer pesticide
products adequately convey certain information to the public.  However,
EPA believes that improvements are possible.  The Agency believes,
especially for insect repellents, that it has identified additional
information that should be on the label.  Such information would include
the specific protection time for each species as determined by the
efficacy data. But, the Agency lacks information on the kinds of
information that the public would find useful on an insect repellent
label, the types of formats that would provide the clearest, most
understandable information, and/or the amount of technical detail
needed.  

Through the use of “focus groups” (groups of individuals brought
together for moderated discussions typically formed to gain insight and
understanding of attitudes and perceptions held by the public
surrounding a particular issue); and “one-on-one interviews”
(individual interviews in which a respondent will provide feedback about
pesticide labels) EPA will learn more about the consumer perspective. 
The information collected through the surveys and focus groups will help
the Agency to determine if additional and/or revised labeling
requirements are needed and if a redesign of pesticide product labels
will provide clearer consumer information.  

EPA will develop information specific to the particular collection
activity, including survey tools or instruments, to be used in gathering
the data that are expected to help the Agency determine if additional
and/or revised labeling requirements are needed for consumer products. 
Over the lifetime of the ICR, the Agency would also use surveys
periodically to seek input on related performance measures, i.e.,
overall increased understanding of insect repellent labels.  

	As appropriate, EPA would collect both qualitative and quantitative
types of information.  Qualitative research can be used to gain
insights, investigate ways to explore issues, or ways to word survey
questions.  Such research often consists of open-ended structured
discussions or interviews with individuals or small groups of
individuals, and therefore can provide in-depth information. 
Information from qualitative surveys cannot be extrapolated or
generalized to a larger population.  Quantitative research involves
larger groups of respondents in order to produce statistically
significant findings.

The information collected through the voluntary surveys and focus groups
are expected to assist EPA in designing insect repellent pesticide
product labels that provide even clearer and more transparent
information.  The information is likely to be collected via a
contractor.  Once the information from the surveys has been translated
into label revisions, consumers will be able to make better decisions
about whether to purchase and use a given insect repellent.  By enabling
consumers to make better choices in regard to protecting their health,
EPA will more effectively carry out its mandate to protect the public
from unreasonable risks to human health

3. NON-DUPLICATION, CONSULTATIONS, AND OTHER COLLECTION CRITERIA 

	3(a) Non-Duplication 

Efficacy for agricultural products can be readily observed.  For
example, if the weeds die after a pesticide application, or if there is
a noticeable reduction in a significant insect infestation, then the
user believes the product to be effective. Also, there are readily
available, reliable sources of information on efficacy of agricultural
products and expertise for agricultural product users such as the United
States Department of Agriculture Extension Service, State Departments of
Agriculture, and academia.  Agricultural producers routinely consult
with these organizations for questions on comparing two agricultural
pesticides and the most appropriate pesticide for their use.  

There is no comparable source of information regarding efficacy
information for public health pesticides such as insect repellents.  On
its website, the Centers for Disease Control states that an
EPA-registered insect repellent product should be used.  But, neither
EPA nor the CDC has posted the information on the efficacy of individual
pesticide products on their websites.  Generally, the information that
is most available to the public on efficacy of insect repellents is
anecdotal information in popular magazines. While studies of comparative
efficacy are available in journals such as the New England Journal of
Medicine, most members of the public do not read such journals.  EPA
believes that efficacy information should be available on the label at
the time of purchase. 

	In 1990 a survey was conducted to determine the human use and exposure
to the insect repellent chemical DEET (N.N-diethyl-metatoluamide). This
survey was conducted to determine the incidence of exposure to DEET
repellent products, the frequency of usage, the areas of the body to
which DEET was applied, the amount of DEET applied, if the DEET was
applied in a manner consistent or inconsistent with the label, and the
type of DEET insect repellent.  The design of this survey will be
considered as the Agency and its contractors work to design the surveys,
focus groups, and one-on-one interviews.

	To date the Agency’s is unaware of any survey that has been conducted
concerning the usefulness and understandability of insect repellent
labels.  However, in 1996, the Agency launched a voluntary project the
Consumer Labeling Initiative (CLI) 

(Federal Register on March 22, 1996 (61 FR 12011)(FRL-4956-8).  The
purpose of the project was to "…ensure that consumers have and
understand the information they need in order to make responsible
product choices based on their own needs and values, and to use chosen
products safely as directed.  This voluntary project is not intended to
produce new regulations or mandatory requirements.”  The CLI surveys
were voluntarily undertaken and funded by industry and trade association
Partners of CLI.  The CLI partners conducted surveys concerning the
labels of certain kinds of pesticide products used by consumers in and
around their homes. However, none of the CLI surveys concerned insect
repellent pesticide products. Insect repellents are distinctly different
than other pesticide products:  the insect repellent is deliberately
applied to human skin.   The findings and conclusions of the CLI, as
well as the survey instruments themselves, will serve as the primary
basis for EPA’s contractor to begin the preparations for the survey(s)
to be conducted under this new ICR.  For additional information see  
HYPERLINK "http://www.epa.gov/oppt/labeling" 
http://www.epa.gov/oppt/labeling .  

	3(b) Public Notice Required Prior to ICR Submission to OMB 

	Pursuant to 5 CFR 1320.8(d), EPA has published a Federal Register (FR)
notice announcing this proposed information collection activity and a
60-day public comment period.  The Agency has established a public
docket for this proposal, which can be accessed at   HYPERLINK
"http://www.regulations.gov"  http://www.regulations.gov  using the
docket identifier EPA-HQ-OPP-2008-0156.  Any comments received will be
given consideration when completing the supporting statement that is
submitted to OMB.

	3(c) Consultations

	Consultations with the general public have not been conducted since EPA
was not able to readily identify potential respondents.  Since these
surveys would be conducted with members of the general public, there are
no established, organized entities with whom EPA has a purposeful
relationship.  However, EPA personnel with the assistance of those
industries with the expertise in consumer marketing and survey design
will develop the instruments for the surveys, focus groups, and
one-on-one interviews.  As appropriate EPA will establish panels of
experts to help design and implement the surveys.  The overall
conclusions (descriptive and summary statistics) of the surveys will be
publicly-available. 

>

	3(d) Effects of Less Frequent Collection

	

	Each survey or focus group will be a one-time collection exercise for
the enrolled participants.  EPA anticipates conducting two to six
collection activities per year over three (3) years. Without the
collected information, it will be extremely difficult to determine the
impact(s) of various types of presentations of the information on insect
repellent labels.  The Agency will not be able to ascertain the overall
improvement of the public’s ability to read a label and choose the
formulation that meets their specific need.  Once the information from
the surveys has been translated into label revisions, consumers will be
able to make a more informed choice about purchasing and using a
pesticide product.  By enabling consumers to make better choices in
regard to protecting their health, EPA will more effectively carry out
its mandate to protect the public from unreasonable risks to human
health.

	3(e) Compliance with General OMB Guidelines

  SEQ CHAPTER \h \r 1 This collection of information will be collected
in accordance with all OMB guidelines under 5 CFR 1320.6.  Respondents
will be asked to participate in the consumer research activities only
once and their participation will be voluntary. There will be no need
for participants to maintain records or submit proprietary trade
secrets.  

	3(f) Confidentiality 

	No proprietary trade secrets or other proprietary information will be
collected.  EPA will collect only the information necessary to evaluate
proposed labeling statements.  Confidentiality of respondent information
will be ensured to the maximum extent allowed by law.  Participation
will be voluntary, and respondents will not be identified in released
information.  There will be complete protection of any demographic
information collection from participant—full names, phone numbers and
addresses will not be associated with responses.  Consumer research
conducted will fully conform to federal regulations – specifically the
Privacy Act of 1974 (5 U.S.C. 552a), the Hawkins-Stafford Amendments of
1988 (P.L 100-297), and the Computer Security Act of 1987.  

	3(g) Sensitive Questions 

The information requested under this voluntary collection does not
include questions of a sensitive nature.  No personal or private
questions will be asked.  EPA will collect only the information
necessary to evaluate the proposed labeling statements.  All responses
will remain strictly confidential, and EPA will guarantee to all survey
participants that their responses will remain private.  

	3(h) Electronic Reporting. 

	There will be no direct electronic submission scheme for this
collection.  However, the Agency does intend to pursue the use of
internet surveys, such as those customer satisfaction surveys that are
already on the Agency’s website. 

4. THE RESPONDENTS AND THE INFORMATION REQUESTED 

	4(a) Respondents

	Potential respondents affected by these voluntary collection activities
will mainly include members of the general public. 

	4(b) Respondent Activities

	Mail surveys and web-based surveys may involve the following
activities:

Read instructions

Complete questionnaire

Return/submit questionnaire

Telephone surveys may involve the following activities:

Listen to instructions

Provide oral response

Focus Groups and interviews may involve the following activities:

Listen to instructions

Participate in discussions

Complete any forms or materials

  SEQ CHAPTER \h \r 1 5.  THE INFORMATION COLLECTED - AGENCY ACTIVITIES,
COLLECTION METHODOLOGY, AND INFORMATION MANAGEMENT

	5(a)	Agency Activities

	EPA or its contractor will perform the following activities:

Develop survey design; assemble data sources (mail and/or internet
address lists, etc.)

Pretest the survey

Internal EPA review and approval of survey

Submit specific survey design, including collection methodology, sample
size, incentive plans, and pre-test results, to OMB for clearance under
the PRA

Disseminate survey to respondents

Gather information from respondents

Review and analyze the information obtained

Prepare findings

Use the data to inform the design of label statements for pesticide
products

Repeat above sequence to test the design

File and store submissions

Provide an aggregated report of the information obtained and the overall
conclusions and results

	5(b)	Collection Procedures

	EPA could collect information by any of the following methods:
telephone, mail, shopping mall intercept, internet survey, and
face-to-face focus groups and interviews.  The surveys will be designed
to be completed by individuals and/or households, not small businesses. 
An advantage of collecting information via mail and internet surveys is
the flexibility that such a collection offers the respondent.  Surveys
can be completed at the convenience of the respondent.  There is no need
to arrange times for interviews.

	5(c)	Small Entity Flexibility

	The surveys will be designed to be completed by individuals and/or
households, not small businesses.  

	5(d)	Collection Schedule

	EPA anticipates conducting two to six surveys per year, over the next
three years.  Surveys will be conducted according to the needs of the
individual projects.

6	ESTIMATING THE BURDEN AND COST OF THE COLLECTION 

	6(a)	Estimating Respondent Burden

	To estimate the Paperwork Reduction Act (PRA) burden hours and costs,
and the potential number of respondents, EPA used historical respondent
information from other surveys, and projected respondent information
from the recently approved ICR entitled “Focus Groups as Used by EPA
for Economics Projects” (ICR No.2205.01) and the Customer Satisfaction
Surveys ICR (No 1711.05), and the Agency’s best professional judgment.
Table 1 below describes the respondent burden hours and costs.

TABLE 1.   TOTAL THREE YEAR RESPONDENT BURDEN/COST ESTIMATES

Testing Instruments	Estimated Number of Respondents	Estimated Response
Time (min) per Respondent	Estimated Respondent Time (hours) Over Next
Three Years	Estimated Respondent Costs

($25.16/hr)

Focus Groups	72	120	144	3623.04

Shopping Mall Intercept or Telephone Interviews	1000	20	333	8378.28

Written or Web-based Surveys	2000	20	667	16,781.72

Totals	3072	160	1144	$28,783.04

 Estimated average respondent burden = 2.9 hours 

Little is required of a survey respondent, for web-based or written
surveys.  The respondent reads the instructions, answers the questions,
and then mails or submits the survey.  For mall intercept and telephone
interviews, and focus groups, the respondent merely answers the
questions.

There are no capital expenditures, or operation and maintenance costs
associated with this information collection activity.  The only cost to
respondents is their time. However, to value the respondents’ time,
information from the Bureau of Labor Statistics was used.  (  HYPERLINK
"http://www.bls.gov/opub/ted/2006/sept/wk4/art01.htm" 
http://www.bls.gov/opub/ted/2006/sept/wk4/art01.htm )  This information
indicated that employer costs for June 2006 averaged $7.39 per hour. 
Wages averaged $17.77 per hour.  Thus, the total compensation is $25.16
per hour.

	6(b)	Estimating Agency Burden

Total costs will depend on the costs necessary to develop, pre-test,
conduct, and follow-up the survey.  EPA could incur costs such as hiring
contractors to develop and conduct the surveys.  There could also be
travel to focus group cities for both agency and contractor personnel,
and renting meeting space.  Agency personnel would evaluate and then
determine how to use the information collected to revise insect
repellent labels. Lower costs would eventually be incurred by subsequent
use of the same or similar questions.  Costs for agency managerial and
agency technical staff were determined using the methodology below. 
Attachment B contains a worksheet providing the breakout of these costs.
 Costs are indexed to 2006 data.  

Methodology:	The methodology uses data on each sector and labor type for
an Unloaded wage rate (hourly wage rate), and calculates the Loaded wage
rate (unloaded wage rate + benefits), and the Fully loaded wage rate
(loaded wage rate + overhead).  Fully loaded wage rates are used to
calculate respondent costs.  

Unloaded Wage Rate:  Wages are estimated for labor types (management,
technical, and clerical) within applicable sectors. The Agency uses
average wage data for the relevant sectors available in the National
Industry-Specific Occupational Employment and Wage Estimates from the
Bureau of Labor Statistics (BLS) at   HYPERLINK
"http://www.bls.gov/oes/current/oes_nat.htm" 
http://www.bls.gov/oes/current/oes_nat.htm .  

Sectors: The specific North American Industry Classification System
(NAICS) code and website for each sector is included in that sector’s
wage rate table (see Attachment F).  Within each sector, the wage data
are provided by Standard Occupational Classification (SOC).  The SOC
system is used by Federal statistical agencies to classify workers into
occupational categories for the purpose of collecting, calculating, or
disseminating data (see   HYPERLINK
"http://www.bls.gov/oes/current/oes_stru.htm" 
http://www.bls.gov/oes/current/oes_stru.htm  ).  

Loaded Wage Rate: Unless stated otherwise, all benefits represent 43% of
unloaded wage rates, based on benefits for all civilian non-farm
workers, from   HYPERLINK "http://www.bls.gov/news.release/ecec.t01.htm"
 http://www.bls.gov/news.release/ecec.t01.htm . However, if other
sectors are listed for which 43% is not applicable; the applicable
percentage will be stated.

Fully Loaded Wage Rate: We multiply the loaded wage rate by 50% (EPA
guidelines 20-70%) to get overhead costs.

TABLE 2. Estimated Three Year Agency Burden Costs Estimates for Focus
Group

	Collection 

Activities	

	Burden Hours 	

Total

	

	Mgmt.

	$101.16/hr	

	Tech.

	$66.88/hr	

	Contractor 

		EPA 

Hours	       EPA 

Cost



Develop focus sessions	0	40	

$6000.00 per

focus group	40	2,675.20



Obtain approval	2	10

12	871.12



Conduct focus groups	0	10

10	668.80



Review data 	0	5

5	334.40



Analyze results	1	20

21	1,438.76



Store and maintain results	0	10

10	338.80



Prepare findings	2	30

32	2,208.72



TOTAL	

5	

125	

$6,000	

130	

$8,865.80



Estimated per EPA focus group costs are: Contractor Costs ($6,000) + EPA
Costs ($8,865.80) = $14,865.80

TABLE 3.  Estimated Three Year Agency Burden Costs Estimates for
Shopping Mall Intercept or Telephone Interviews

	Collection 

Activities	

	Burden Hours 	

Total

	

	Mgmt.

	$101.16/hr	

	Tech.

	$66.88/hr	

	Contractor 

		

EPA

Hours	

EPA

Cost



Develop questions	0	40	

$75,000/

1000 responses	40	2,675.20



Obtain approval	2	10

12	871.12



Conduct interviews	0	10

10	668.80



Review data 	0	20

20	1,337.60



Analyze results	1	80

81	5,451.56



Store and maintain results	0	10

10	668.80



Prepare findings	2	30

32	2,208.72



TOTAL	

5	

200	

$75,000	

205	

$13,881.80

Total EPA shopping mall intercept or telephone interviews costs are:

 	Contractor costs ($75,000) + EPA Costs ($13,881.80) = $88,881.80

TABLE 4.  Estimated Three Year Agency Burden Costs Estimates for Written
or Web-based Surveys

	Collection 

Activities	

Totals

	

	Mgmt.

	$101.16/hr	

	Tech.

	$66.88/hr	

EPA

Hours	

EPA

Cost



Develop survey questions	0	100	100	6,688.00



Obtain approval	2	10	12	871.12



Conduct survey	0	40	40	2,675.20



Review data 	0	40	40	2,675.20



Analyze results	1	40	41	2,776.36



Store and maintain results	0	10	10	668.80



Prepare findings	2	30	32	2,208.72



TOTAL	

5	

270	

275	

$18,897.80

Total EPA written or web-based survey costs are: $18,897.80

 

TABLE 5.  Estimated Three Year Bottom Line Burden Hours and Cost Tables/
Master Table







Hours	

 Cost 

Respondents 

Focus Groups	144	$3,623.04

Shopping Mall Intercept or Telephone Interviews	

333	$8,378.28

Written or Web-based Surveys	

667	$16,781.72

Respondent 3 yr Totals 	1,144	$28,783.04

Respondent Annual Total	381.34	$9,594.35



Agency 



Focus Groups +

(contractor costs $6,000)	130

	($8,865.80 + 6,000)

$14,865.80

Shopping Mall Intercept or Telephone Interviews

+ (contractor costs 75,000)	205	($13,881.80+$75,000)

$88,881.80

Written or Web-based Surveys	275	$18,897.80

Agency Three Year Totals	1260	$416,454

Agency Annual Total	420	$138,818



	6(e)	Burden Statement

The total annual respondent burden for the ICR entitled Use of Consumer
Research in Developing Improved Labeling for Insect Repellents, a new
ICR, is estimated to be 381.34 hours at a cost of $9,594.35.  According
to the PRA, “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 responding to survey questions or participating in a
focus group.  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 will appear
on the information collection instrument as applicable, i.e., form or
instructions.       

The Agency has established a public docket for this ICR under Docket ID
No. EPA-HQ-OPP-2008-0156, which is available for online viewing at  
HYPERLINK "http://www.regulations.gov"  www.regulations.gov , or in
person viewing at the OPP Regulatory Public Docket in Rm. S-4400, One
Potomac Yard (South Building), 2777 S. Crystal Drive, Arlington, VA. 
This docket facility is open from 8:30 a.m. to 4 p.m., Monday through
Friday, excluding legal holidays.  The docket telephone number is (703)
305-5805.  You may submit comments regarding 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.  

	Comments may be submitted to EPA electronically through
http://www.regulations.gov or by mail addressed to Director, Collection
Strategies Division, U.S. Environmental Protection Agency (2822T), 1200
Pennsylvania Ave., NW, Washington, D.C. 20460.  You can also send
comments to the Office of Information and Regulatory Affairs, Office of
Management and Budget, 725 17th Street, NW, Washington, DC 20503,
Attention: Desk Office for EPA.  Include docket ID No.
EPA-HQ-OPP-2008-0156 and OMB control number 2070-TBD in any
correspondence but do not submit information under this collection to
these addresses.

ATTACHMENTS TO THE SUPPORTING STATEMENT

Attachments to the supporting statement are available in the public
docket established for this Information Collection Request (ICR) under
the docket identification number EPA-HQ-OPP-2008-0156.  These
attachments are available for online viewing at   HYPERLINK
"http://www.regulations.gov_"  www.regulations.gov  or otherwise
accessed as described in the sections below.  

Attachment A 7 U.S.C. 136a - FIFRA Section 3 - This attachment is
available as part of the Docket EPA-HQ-OPP-2008-0156 or can be accessed
via the internet at:   HYPERLINK
"http://www4.law.cornell.edu/uscode/7/usc_sec_07_00000136---a000-.html" 
http://www4.law.cornell.edu/uscode/7/usc_sec_07_00000136---a000-.html 

Attachment B 40CFR 156.10 This attachment is available as part of the
Docket EPA-HQ-OPP-2008-0156 or can be accessed via the internet at:  
HYPERLINK
"http://www.access.gpo.gov/nara/cfr/waisidx_07/40cfrv23_07.html" 
http://www.access.gpo.gov/nara/cfr/waisidx_07/40cfrv23_07.html 

Attachment C Agency Labor Cost Worksheet 2006 Data This attachment is
available only as part of the Docket EPA-HQ-OPP-2008-0156. 

Attachment A

7 U.S.C. 136a - FIFRA Section 3

Attachment B

40CFR 156.10

Attachment C

Agency Labor Cost Worksheet 2006 Data

 June 22, 2007 presentation “Vector-Borne Diseases and Public
Health” of Dr Ali Khan, MD, MPH, National Center for Zoonotic,
Vector-Borne and Enteric Diseases, Centers for Disease Control and
Prevention

 December 2006 presentation “Insect Repellents & Efficacy Data: 
Increased Public Health Protection” of William Diamond, Director Field
and External Affairs Division, OPP, EPA

 Fradin and Day, “Comparative Efficacy of Insect Repellents Against
Mosquito Bites” July 4, 2002, N Engl J Med, Vol. 347, No.1, pages
13-18.

March 4, 2008

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