                                                                        
                                                           June 10, 2010

SUPPORTING STATEMENT FOR AN 

INFORMATION COLLECTION REQUEST (ICR)

1.	IDENTIFICATION OF THE INFORMATION COLLECTION

1(a).	Title of the Information Collection  

Pesticide Registration Fees Program

OMB Nos.:  2070-new

 		

EPA Nos.:  2330.01

1(b).	Short Characterization/Abstract 

In compliance with the Paperwork Reduction Act (PRA) (44 U.S.C. 3501 et
seq.), this document announces that Environmental Protection Agency’s
(EPA), Office of Pesticide Programs (OPP) is planning to submit a
request to consolidate several existing approved Information Collection
Requests (ICRs) to the Office of Management and Budget (OMB). Before
submitting the consolidated ICR to OMB for review and approval, EPA is
soliciting comments on specific aspects of this information collection. 
The new consolidated ICR, entitled: “Pesticide Registration Fees
Program” and identified by EPA ICR No. 2330.01 and OMB Control No.
2070-[new] will consolidate the following currently approved ICRs:
"Pesticide Registration Maintenance Fees," (EPA No. 1214.07, OMB No.
2070-0100) scheduled to expire on November 30, 2010 and “Pesticide
Registration Fee Waivers (PRIA)" (EPA No. 2147.03, OMB No. 2070-0167,)
scheduled to expire on October 31, 2010.

	

Collectively, these ICRs enable the EPA to process, grant and collect
pesticide registration fees and waivers. This information collection
will allow EPA to process requests for waivers under the Pesticide
Registration Improvement Act (PRIA). The collection also provides a
practical means of communication between the registrants and EPA’s
Office of Pesticide Program (OPP) to collect registration maintenance
fees from registrants as required by law.  EPA is specifically looking
for comments about the clarity and ease of public review this
consolidated document creates.

1(c).	The Consolidated Document

These ICRs are being consolidated in to one document because the
programs they represent share similar respondent populations,
registrants required to submit fees in order to enhance the review of
pesticide products under FIFRA. The Agency believes consolidating these
ICRs into one document will increase the clarity of review for the
public and will streamline Agency review for such programs.  

	The document is divided into two separate individual parts, Part A and
Part B.  No changes to the currently approved ICRs have been made. 

 	Part A 

Maintenance Fees are collected from pesticides registrants as required
by law.  Respondents complete and submit EPA Form 8570-30 indicating the
respondent’s liability for the registration maintenance fee. Annually
the Agency provides registrants a list of the registered products
currently with the Agency. Registrants are provided the opportunity to
review the list, determine its accuracy, and remit payment of
maintenance fee. The list of products has space identified for making
those products to be supported and those products that are cancelled.
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.  

This consolidated document does not change any substantive parts of the
original document. This document is being re-submitted to OMB for: 1)
re-assignment of OMB document tracking number and 2) public comment on
the consolidated document. 

Part B

Part B describes the Pesticide Registration Fee Waivers (PRIA) program
which authorizes EPA to process requests for waivers of fees. The
program allows for activities associated with requesting a fee waiver
and involves requesters submitting a waiver request, information to
demonstrate eligibility for the waiver, and certification of
eligibility. Waivers are available for small business, for minor uses,
and for actions solely associated with the Inter-Regional Project Number
4 (IR-4). State and federal agencies are exempt from payment of fees.

This consolidated document does not change any substantive parts of the
original document. This document is being re-submitted to OMB for: 1)
re-assignment of OMB document tracking number and 2) public comment on
the consolidated document. 

Part A 

Product Registration Maintenance Fee;

 OMB Number 2070-0100 and EPA Number 1214.08 

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

  	EPA No.: 1214.08   OMB No.: 2070-0100

1(b)  Short Characterization/Abstract:

This information 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.  

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, 2009.  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.  

2.	NEED FOR AND USE OF THE COLLECTION 

2(a)  Need/Authority for the Collection

Section 4(i)(5) of, the Federal Insecticide, Fungicide, and Rodenticide
Act  (FIFRA) (Attachment B) requires registration maintenance fees to be
applied 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.  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 through fiscal year 2012.

      

 2(b)  Practical Utility/Users of the Data

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.  The
information is 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 (i.e., the number of
registrations that a given registrant wishes to maintain and, thus, the
fee amount that will be remitted to EPA) 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 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 will publish a Federal Register (FR)
Notice announcing this proposed information collection activity and
provide a 60-day public comment period.

	

3(c)  Consultations

Consultation and/or dialogue between respondents and the Agency is
frequent and on-going.  In addition to phone conversations, e-mails, and
letters, Agency personnel 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. 

During the preparation of this ICR renewal, EPA staff contacted the
following representatives of pesticide registrants by phone or e-mail
and asked them for their assessment of the burden estimates in the ICR:

Kim Davis, 

RegWest Company, LLC

30856 Rocky Road

Greeley, CO 80631

(970) 353-0611

  HYPERLINK "mailto:Kim@regwest.com"  Kim@regwest.com 

(Consultant representing 36 companies holding 1 to 16 registrations)	Bob
Werdig

Pesticide Registration Association

715 8th Street S.E. 

Washington DC   20003

(202) 546-3260

(Consultant representing 4 companies holding 1 to 4 registrations)

Donna Leventhal

Delta Analytical

7910 Woodmont Avenue 

Bethesda, MD 20814

(301) 652-5495

(Consultant representing 22 companies holding 1 to 16 registrations)
William Mahrlburg 

Nufarm

2300 Frederick Avenue Suite 208 

St. Joseph,  MO 64504

(816) 676-9000

(Company holds 393 registrations)



All four of the above respondent representatives provided feedback to a
questionnaire about the collection process (see Attachment D).  As is
the case with pesticide registrant companies, the above respondents vary
widely in company size and structure. This variability among companies
included in this consultation resulted in variable responses.  The
average time required to complete the maintenance fee filing form
depends upon the number of registrations held by the registrant.  Larger
companies with more registered pesticide products will take longer to
complete the form, on average, than companies with fewer registrations. 
The time required to complete the form estimated by the above
respondents ranged from 10 minutes to half an hour, all less than the
estimated 0.96 hours used in this ICR renewal.  In general, it appears
that the Agency’s burden estimates used are equal to or higher than
those actually incurred, and have not been revised.

The four respondent representatives were also asked their opinion of and
desire for electronic reporting.  Again, responses varied but they
indicated some concern over security and electronic signatures.  One
respondent indicated that electronic reporting would not change the
burden relative to paper responses, one said it would actually increase
the burden, and the other two said it could increase the burden for some
and decrease it for others.  Two of the respondents said that they would
still need to send a check to EPA, even if the form were submitted
electronically, thereby undermining the benefit of electronic reporting.

	Due to these responses, and similar feedback received informally from
other registrants, it is apparent that at least some may prefer
electronic reporting and payment and that some burden reduction may be
realized.  EPA will work with the Treasury Department to implement
electronic payment of maintenance fees via http://www.pay.gov.  This
capability was in place beginning with the FY08 collection cycle. Since
then about 20% of maintenance fee payment have bee received
electronically

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,
this information collection activity 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.

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 has used automation to the extent
practicable without electronic reporting and payment.  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 makes available a simple filing form and the
ability to make electronic reporting and payment (see section 3(c),
above).  

As discussed in Section 4(c), this form requires the minimum amount of
information from all firms.

This collection activity does not apply to grantees.

3(f)  Confidentiality

Product registration maintenance fee information submitted by pesticide
registrants under this ICR is 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) codes are 325320 (Pesticide and other Agricultural Chemical
Manufacturing) and 9641 (Regulation of Agricultural Marketing and
Commodities).

  

4(b)  Information Requested

4(b)(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.

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 fee amount 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.



	4(b)(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.

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.



The existing paper version 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.  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.

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 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

Experience has shown that the average burden per respondent has remained
at approximately 1 hour.  The agency believes that the number of actual
burden hours has remained steady due to the fact that registrants now
have 20 years of experience.  In 2009, 1,720 firms responded to the
collection request.  A summary of firms and their number of
registrations is provided below.

Table 1. Number of Registrations Held by Registrants (Summary)

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 consultations with several respondents, both in the past and
for this ICR renewal, we believe that the average time required to
complete the maintenance fee filing form depends upon the number of
registrations held by the registrant. Below is the breakdown of the
burden associated with the 2009 maintenance fee filing based on
registrant-supplied information.

Table 2. Respondent Burden, by Number of Registrations Held      

Number of Products	Average

 hours	Number of

Registrants	Total Hours

   1 – 10	0.75	1,477	1108

  11 – 20	1.0	95	95

  21 – 50	2.0	78	156

  51 – 100	3.0	32	96

    > 100	5.0	38	190

Totals	   

1,720	1,645



PAPERWORK BURDEN: 1,645 (total hours) / 1720 (number of respondents) =
0.956 hours per response (rounded to two digits).

These calculations were made using the average case scenario.   The
average case burden was developed from the above table.

Table 2a. Average Respondent Burden 

Collection Activities	Management	Technical	Clerical	TotalHours

Read Instructions

0.25

0.25

Plan Activities	0.20

	0.20

Review Information	0.20

	0.20

Complete Paperwork

0.20

0.20

File Information

	0.11	0.11

Total	0.40	0.45	0.11	0.96



TOTAL ANNUAL BURDEN: average hours per form (0.96) X number of
respondents (1,720) = 1,645 hours.

6(b)  Estimating Respondent Costs

  

As in 2006, the Agency estimates wages, benefits, and overhead for all
labor categories for the pesticide industry and Agency employees using
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 $109.82,
$60.39, and $35.89 per hour, respectively.  These labor rates are fully
loaded and include benefits and overhead costs. 

	

The table below describes the average costs for completing one
maintenance fee filing form.  The average hourly burden was derived from
consultation with a selected group of respondents, and is described
above.

Table 3. Average Respondent Paperwork Costs

Collection Activities	Burden Hours	Total

	Managerial

$109.82/hr.	Technical

$60.39/hr.	Clerical

$35.89/hr.	Burden

Hours	Cost



Read instructions



0.25	

	0.25	$37.06 

Plan activities	

0.20	

	

	0.2	$21.96 

Review information	

0.20	

	

	0.2	$21.96 

Complete Paperwork	

	

0.20	

	0.2	$12.08 

File Information	

	

	

0.11	0.11	$3.95 

TOTAL	0.4	0.45	0.11	0.96	$97.02 



ANNUAL PAPERWORK BURDEN: 0.96 hours X 1720 respondents = 1,645 hours.

ANNUAL PAPERWORK COSTS:

Management: 	0.40 hrs.  X  $109.82/hr.  X  1720 respondents = $75,556

Technical:	0.45 hrs.  X    $60.39/hr.  X  1720 respondents =   $46,742 

Clerical:	0.11 hrs.  X    $35.89/hr.  X  1720 respondents =     $6,790 

 TOTAL = $129,088

6(c)  Estimating Agency Burden and Cost

Agency labor rates were estimated for the relevant technical, and
clerical staff using the methodology cited above.  Technical and
clerical rates are estimated at $71.58 and $41.21 per hour,
respectively.  The Agency expends no management hours in processing
submissions. Labor rates are fully loaded and include benefits and
overhead costs. 

The cost to the Federal Government for this ICR is estimated to be
$82,987.  This estimate has two components.  The first is the annual
costs of generating listings and conducting mass mailings as well as
pre-loading tracking data.  The Agency estimates that these activities
cost $1,518.  The second component is the per submission costs totaling
$81,468, which are required on a per submission basis (see annual number
of actions in Table 4). 

Table 4. Agency Burden Hours per filing form and Total Cost

Collection Activities	 Annual Number of Actions	Burden Hours	Total



Technical

($71.58/hr)	Clerical

($41.21/hr)	Burden Hours	Cost

Generate Listings/Mass Mailing	1	8	16	24	$1,232.00 

Pre-load Tracking Data	1	4

4	$286.32 

Receive/Review Submissions	1,720

0.2	344	$14,176.24 

Enter Data into Tracking Sys.	1,720

0.2	344	$14,176.24 

Reconcile Discrepancies	100	0.5

50	$3,579.00 

Respond to Questions	300	0.5

150	$10,737.00 

Verify Payment	1,720	0.2

344	$24,623.52 

File Documents	1,720

0.2	344	$14,176.24 

TOTAL	NA	NA	NA	1,604	$82,986.56



6(d)  Bottom Line Burden Hours and Cost Tables

Table 5. Total Annual Respondent and Agency Burden and Costs

	Total Burden Hours	Total Cost

Respondent Burden	1,645	$129,088

Agency Burden	1,604	$82,987



6(e)  Reasons for Change in Burden

The total annual burden for respondents associated with this renewal is
1,645 hours.  This is the same burden estimate as in the previous ICR
renewal.   The average time required to complete the maintenance fee
filing form depends upon the number of registrants holding product
registrations and the number of registrations held by registrants. The
number of registrants and the average number of registrations held by
registrant has not changed since the previous ICR, thus no shift in the
average burden hours was required.  Cost increased since the last
renewal merely because of labor cost increase.

6(f)  Burden Statement

The annual "respondent" (applicant) burden for the Pesticide Product
Registration Maintenance Fee program is estimated to average 0.96 hours
per form, or per respondent, as there is one form per respondent. 
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 activities, reviewing the information, and
completing the maintenance fee filing form.  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, as well as on the maintenance
fee filing form itself.

The Agency has established a public docket for this ICR under Docket ID
No. EPA-HQ-OPP-2010-0049, 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.  

Submit your comments, referencing Docket ID No. EPA-HQ-OPP-2010-0049 to
(1) EPA online using www.regulations.gov (our preferred method), or by
mail to: Public Information and Records Integrity Branch (PIRIB), Mail
Code: 7502P, 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.

ATTACHMENTS TO THE SUPPORTING STATEMENT

All of the attachments listed below can be either found in the docket
for this ICR, or a link to the source is provided (unless otherwise
noted); accessible electronically through   HYPERLINK
"http://www.regulations.gov/"  www.Regulations.gov  . On the main page,
select Advanced Search from the menu bar at the top and select Docket
Search. Enter the Docket ID Number, EPA-HQ-OPP-2009-0885 in the Docket
ID field. Click on the Submit button. From the results page, you will be
able to link to the docket view or directly open select documents found
in the docket.

Attachment A:	EPA Form 8570-30 - Pesticide Registration Maintenance Fee
Filing Form.

Also available electronically at   HYPERLINK
"http://www.epa.gov/opprd001/forms/8570-30.pdf" 
www.epa.gov/opprd001/forms/8570-30.pdf 



Attachment B	The Federal Insecticide, Fungicide, and Rodenticide Act
(FIFRA) Section 4(i)(5).  Also available electronically at   HYPERLINK
"http://www.epa.gov/opp00001/regulating/fifra.pdf" 
http://www.epa.gov/opp00001/regulating/fifra.pdf  



Attachment C:	Worksheet for Estimating OPP ICR Wage Rates for Industry,
State and EPA Labor. Attached as part of the public docket
identification number EPA-HQ-OPP-2010-0049

Attachment D:	Record of Consultations Between US Environmental
Protection Agency and Respondents to the Information Collection Request:
“Pesticide Registration Maintenance Fee”

                      



Attachment C 

Work Sheets used to Calculate Registrant Labor Costs  

This attachment is available as part of the electronic docket EPA-HQ-OPP
and is part of the ICR’s Supporting Statement.

NAICS:  325300

Pesticide, Fertilizer, and Other Agricultural Chemical Manufacturing

Labor Category:	Formula	Managerial	Technical	Clerical

Unloaded Hourly Rate1	 = W	$51.01 	$28.05 	$16.67 

Benefits Percentage2	Lb = B/W	44%	44%	44%

Benefits per hour	B = W*Lb	$22.20 	$12.21 	$7.26 

Loaded Hourly Rate	Wb = W + B = W(1+Lb)	$73.21 	$40.26 	$23.93 

Overhead Percentage3	Lo = OH/Wb	50%	50%	50%

Overhead per hour	OH = Wb*Lo	$36.61 	$20.13 	$11.96 

Fully Loaded Hourly Rate	Wf = Wb + OH

 = W + B + OH  	$109.82 	$60.39 	$35.89 



1.  Data Source:  BLS   HYPERLINK
"http://www.bls.gov/oes/current/naics4_325300.htm" 
http://www.bls.gov/oes/current/naics4_325300.htm      May 2008 data

     NAICS 325300 - Pesticide, Fertilizer, and Other Agricultural
Chemical Manufacturing

     Standard Occupational Codes:   

       Management:   11-0000, Management Occupations  

       Technical:        19-0000, Life, Physical, and Social Science
Occupations 

       Clerical:           43-0000, Office and Administrative Support
Occupations 

2. Fringe benefits/wage per hour.   

3. U. S. Environmental Protection Agency, EPA Air Pollution Control Cost
Manual, Sixth Edition, EPA-452-02-001, January 2002, pg. 2-34.  The
loading for indirect costs is within the range of 20-70% of the load
labor rate (wage + benefits) suggested in EPA guidance.

Attachment C 

Work Sheets used to Calculate EPA Labor Costs

This attachment is available as part of the electronic docket EPA-HQ-OPP
and is part of the ICR’s Supporting Statement

NAICS: 999100 

Federal Executive Branch

Labor Category:	Formula	Managerial	Technical	Clerical

Unloaded Hourly Rate1	 = W	$49.96 	$33.25 	$19.14 

Benefits Percentage2	Lb = B/W	44%	44%	44%

Benefits per hour	B = W*Lb	$21.75 	$14.47 	$8.33 

Loaded Hourly Rate	Wb = W + B = W(1+Lb)	$71.71 	$47.72 	$27.47 

Overhead Percentage3	Lo = OH/Wb	50%	50%	50%

Overhead per hour	OH = Wb*Lo	$35.85 	$23.86 	$13.74 

Fully Loaded Hourly Rate	Wf = Wb + OH

 = W + B + OH  	$107.56 	$71.58 	$41.21 



1.  Data Source:  BLS   HYPERLINK
"http://www.bls.gov/oes/current/naics4_999100.htm" 
http://www.bls.gov/oes/current/naics4_999100.htm   May 2008 data

     NAICS  999100 -  Federal Executive Branch

     Standard Occupational Codes:   

       Management:   11-0000, Management Occupations  

       Technical:        19-0000, Life, Physical, and Social Science
Occupations 

       Clerical:           43-0000, Office and Administrative Support
Occupations 

2. Fringe benefits/wage per hour.   

3. U. S. Environmental Protection Agency, EPA Air Pollution Control Cost
Manual, Sixth Edition, EPA-452-02-001, January 2002, pg. 2-34.  The
loading for indirect costs is within the range of 20-70% of the load
labor rate (wage + benefits) suggested in EPA guidance.

Record of Consultations Between the U.S. Environmental Protection Agency
and Respondents to the Information Collection Request: “Pesticide
Product Registration Maintenance Fee”

Consultations conducted in February, 2010.

1. Kim Davis; RegWest Company, LLC

2. Bob Werdig; Pesticide Registration Association

3. Donna Levethal; Delta Analytic Corporation

4. William Mahrlburg; Nufarm Americas Inc.

Sample Consultation Questions OPP ICR Renewals 

EPA Questions asked in Consultation 

(1)	Publicly Available Data

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

If yes, where can you find the data?  (Does your answer indicate a true
duplication, or does the input indicate that certain data elements are
available, but that they don(t meet our data needs very well?)  	

(2)	 Frequency of Collection 

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

(3)	Clarity of Instructions   

The ICR is intended to require that respondents provide certain data so
that the Agency can utilize them.  

Based on the instructions (regulations, PR Notices, etc.), is it clear
what you are required to do and how to submit such data? If not, what
suggestions do you have to clarify the instructions?

Do you understand that you are required to maintain records?   

Considering that there is no required submission format, is it difficult
to submit information in ways that are clear, logical and easy to
complete?   

Are there forms associated with this process?  Do you use them?  Are
they clear, logical, and easy to complete?

(4)	Electronic Reporting and Record keeping 

The Government Paperwork Elimination Act requires agencies make
available to the public electronic reporting alternatives to paper-based
submissions by 2003, unless there is a strong reason for not doing so. 
One such reason is that, at the present time, the Agency is unable to
ensure the security of CBI that might be transmitted over the Internet.

What do you think about electronic alternatives to paper-based records
and data submissions?  Current electronic reporting alternatives include
the use of web forms(/XML based submissions via the Agency’s Internet
site and magnetic media-based submissions, e.g., diskette, CD-ROM, etc. 
Would you be interested in pursuing electronic reporting?  

Are you keeping your records electronically?   If yes, in what format?

Although the Agency does not offer an electronic reporting option
because of CBI-related security concerns at this time,  

would you be more inclined to submit CBI on diskette (CD or DVD) than on
paper?  

what benefits would electronic submission bring you in terms of burden
reduction or greater efficiency in compiling the information?  

(5)	Burden and Costs

Are the labor rates accurate? 

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

Bearing in mind that the burden and cost estimates include only burden
hours and costs associated with the paperwork involved with this ICR,
e.g., the ICR does not include estimated burden hours and costs for
conducting studies, are the estimated burden hours and labor rates
accurate? 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.

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

Answers

Answer: The average time required to complete the maintenance fee
filling form depends upon the number of registrations held by the
registrants.

Answer: Electronic reporting would not change the burden relative to
paper responses.

Answer: Electronic reporting would increase the burden for some and
decrease it for others.

Part B 

Pesticide Registration Fee Waivers;

OMB Number 2070-0167 and EPA Number 2147.04 

SUPPORTING STATEMENT FOR AN

INFORMATION COLLECTION REQUEST (ICR)

1.	IDENTIFICATION OF THE INFORMATION COLLECTION

1(a)	Title of the Information Collection:  

Pesticide Registration Fee Waivers

OMB Control No.: 2070-0167	EPA ICR No.: 2147.04

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
October 31, 2010.  This information collection allows the Environmental
Protection Agency (EPA) to process requests for waivers and exemptions
of fees under the Pesticide Registration Improvement Renewal Act of 2007
(PRIA 2) which established Section 33 of the Federal Insecticide,
Fungicide and Rodenticide Act (FIFRA).  The ICR covers the collection
activities associated with requesting a fee waiver or exemption and
involves requesters submitting a waiver or exemption request,
information to demonstrate eligibility for the waiver or exemption, and
certification of eligibility.  Waivers are available for small
businesses and minor uses and exemptions are available for minor uses
and actions solely associated with the Inter-Regional Research Project
Number 4 (IR-4).  State and federal agencies are exempt from the payment
of fees.  This ICR provides burden hour and labor cost estimates for
both applicants for fee waivers and EPA employees who process and
approve or deny waiver requests.

2.	NEED FOR AND USE OF THE COLLECTION

2(a) 	Need/Authority for the Collection

Under the Federal Insecticide, Fungicide and Rodenticide Act (FIFRA),
EPA must evaluate pesticides thoroughly, before they can be marketed and
used in the United States, to ensure that they will not pose
unreasonable adverse effects to human health and the environment.
Pesticides that meet this test are granted a license or "registration"
which permits their distribution, sale and use according to requirements
set by EPA to protect human health and the environment.  

The PRIA amended FIFRA to provide for the collection of fees in order to
enhance the review of covered pesticide products (see Attachment A and
Attachment F for information on the PRIA fee schedule).  Fees collected
under this program will help to reduce time frames for registration
decisions; provide greater predictability and more accountability for
those decisions; ensure that Food Quality Protection Act (FQPA)
deadlines are met; and result in more predictable and augmented funding
for the pesticide program.  The program provides stability in funding
for EPA’s Office of Pesticide Programs (OPP) over five years, October
1, 2007 to September 30, 2012.  The program’s fee schedule under PRIA
2 will be phased out beginning on October 1, 2012, and ending on
September 30, 2014.  As indicated above, the PRIA also established
provisions that allow these fees to be exempted entirely.

A registration applicant may seek a waiver as a small business, defined
by the PRIA as a business with fewer than 500 employees and on average,
annual global gross revenue from pesticides of no more than $60 million
over the most recent three-year maintenance fee billing cycle. For a
business entity with one or more affiliates, the gross revenue limit
includes total global revenues from pesticides for the entity and all of
its affiliates, including parent and subsidiary entities.  

A registration applicant qualifying as a small business under the PRIA
will be entitled to a waiver of fifty percent (50%) of its fees.  In
addition, 75% of a fee will be waived for small businesses with, on
average, annual gross global revenues from pesticides over the most
recent three-year maintenance fee billing cycle, including affiliates,
of no more than $10 million.  Small business applicants requesting
waivers must provide EPA with appropriate documentation demonstrating
that they meet these criteria.

A registration applicant may also request a minor use waiver or fee
reduction if the applicant can demonstrate that anticipated revenues
from the uses described in the registration application would be
insufficient to justify the imposition of the full application fee.  The
Agency may grant a full exemption or a partial reduction in the fee
based upon its consideration of the supporting documentation provided.  

In addition, the statute states that the Agency shall exemption the
registration service fee for an application if the Administrator
determines that two criteria are met:  that the application is solely
associated with IR-4 tolerance petition and that the exemption is in the
public interest.  The Agency anticipates that most applications
submitted by the IR-4 program would qualify for the exemption.  Finally,
the statute exempts agencies of the Federal Government or a State from
fees.

The program is expected to generate in excess of $10 million in new
registration service fees annually over five years and allows applicants
for pesticide registrations submitted prior to  March 23, 2004 to pay a
portion of the fee voluntarily.  

2(b) 	Practical Utility/Users of the Data

EPA is the sole intended user of the information collected.  This
collection of information is critical for the proper performance of
Agency functions because the information collected will allow EPA to
properly review a request for a waiver or exemption of fees under the
PRIA without delay.  The actual usefulness of the information to the
Agency is that the information collected will be used to determine if
the applicant qualifies for a fee waiver or fee reduction or exemption. 
Statutorily, in instances where the applicant requests a fee waiver or
fee reduction or exemption, the decision review time period does not
begin until either the Agency grants the waiver or exemption or until
the registrant has paid the appropriate registration service fee (or, in
the case of a partial waiver or fee reduction, the balance of the
appropriate registration service fee).  Processing of the application,
therefore, will be delayed until the Agency can render a decision on the
fee waiver or fee reduction or exemption request.  With the submission
of this data by the registrant, the Agency will be able to meet its
statutory obligation to grant or deny a waiver request within 60 days
and, potentially, earlier than the maximum 60 day period.

3.	NON DUPLICATION, CONSULTATIONS, AND OTHER COLLECTION CRITERIA

3(a) 	Non duplication

No other federal agency or EPA program is collecting fees for the
processing of applications for pesticide registration or, therefore,
information for the waiver or exemption of such fees. As such, this
information collection activity does not duplicate any other collection
of information by the federal government.

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

	Pursuant to 5 CFR 1320.8(d), EPA will publish a Federal Register (FR)
Notice announcing this proposed information collection activity and
provide a 60-day public comment period. 

3(c) 	Consultations

Prior to passage, the PRIA had been developed over a multi-year period
based upon input from the pesticide industry, industry trade
associations, public interest groups, and the Agency.  The legislation
to reauthorize the Pesticide Registration Improvement Act (PRIA) that
was introduced into Congress known as PRIA 2 was based upon the past
experience in implementing PRIA and a consensus reached by stakeholders,
informed by technical information provided by the Agency.  These
stakeholders included CropLife America, the Consumer Specialty Products
Association, the Chemical Producers and Distributors Association, the
American Chemistry Council, the Natural Resources Defense Council, and
Consumers Union, among other parties.

Consultation and/or dialogue between respondents and the Agency on the
PRIA waivers and exemptions process, content, definitions, format, and
timing is frequent and on-going.  In addition to phone conversations,
e-mails, and letters, Agency personnel 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. 

	On March 1, 2009, the Agency published the fifth annual report
providing an update on “Implementing the Pesticide Registration
Improvement Act -- Fiscal Year 2008.”  The report, available at  
HYPERLINK
"http://www.epa.gov/pesticides/fees/2008annual_report/pria_annual_report
_2008.html" 
http://www.epa.gov/pesticides/fees/2008annual_report/pria_annual_report_
2008.html 

  (see also Attachment B), discusses in detail the processes that have
been streamlined and the stakeholder involvement during FY 2008, the
first year of PRIA 2.  

During the preparation of this ICR renewal, EPA staff contacted the
following representatives of pesticide registrants by phone or e-mail
and asked them for their assessment of the burden estimates in the ICR:

Liz Bauer, Walter G. Legge Company, Inc., 800-345-3443,
liz@leggesystems.com

Terry Pizzarello, Falcon Lab LLC, 917-886-4687,   HYPERLINK
"mailto:tjpizza@optonline.net"  tjpizza@optonline.net 

Elizabeth Tannehill, Mason Chemical Company, 800-362-1855,   HYPERLINK
"mailto:liz@maquat.com"  liz@maquat.com 

Sherry Hutcheson, Phoenix Environmental Care LLC, 229-245-8856,  
HYPERLINK "mailto:sherry.hutcheson@phoenixenvcare.com" 
sherry.hutcheson@phoenixenvcare.com 

William Stoneman, W.F. Stoneman Company, LLC on behalf of Canada Inc.,
608-268-7040, billstoneman@charter.net

All five of the above respondent representatives provided feedback to a
questionnaire about the collection process and the burden and labor rate
estimates used by EPA (see Attachments C – C.4).  As is the case with
pesticide registrant companies, the above respondents vary widely in
company size and structure. This variability among companies included in
this consultation resulted in variable responses.  Four out of the five
agreed with the labor rates for management with one respondent a family
member of a family owned company.  Four out of the five respondents
reported that the fee waiver requests were prepared by management and
only one responded that technical and clerical staff was involved in
preparing a request.  This later respondent did agree with the Agency
labor rate estimates for all labor categories.   Overall, it appears
that the labor rate estimates used by EPA are reasonable, and these
consultations did not provide sufficient basis to amend them.

With respect to respondent burden, if management developed the requests,
the Agency estimate was higher than that reported.  Managers reported
spending an average of three hours preparing a request.  Whether
managers commonly prepare fee waiver requests can not be estimated from
this small sample.  The one company that reported having managers,
technical staff and clerical staff involved in the preparation of a
request reported that the burden was close to the Agency’s estimate. 
Consequently, the Agency did not revise its estimates.

3(d) 	Effects of Less Frequent Collection

  

There is no set collection schedule, per se.  Rather, the registration
service fee is collected each time a registrant submits a registration
application.  The applicant must either pay a fee or request and be
granted a waiver or exemption for each registration application
submitted.  Therefore, the frequency of collection depends entirely on
the frequency with which an applicant submits registration applications
for which they are eligible for a fee waiver or exemption.  EPA cannot
grant a waiver or exemption when one has not been requested and
documented.  Therefore, less frequent collection is not an option.

3(e) 	General Guidelines

This collection activity complies with the guidelines for information
collections under the Paperwork Reduction Act (PRA).  There is no record
keeping requirement for information submitted under this information
collection.

A registration applicant eligible for a fee waiver or exemption must
submit their signed request for the waiver, certification of
eligibility, and required documentation demonstrating eligibility.  The
industry has developed a form for the small business fee waiver request.
 Many requesters use this form, although the Agency does not require it.
 Most waivers are granted based on the small business status of the
applicant, and Confidential Business Information is included in their
submission (e.g., gross global revenues, business structures and
employment levels).  Although EPA would accept waiver requests sent in
Adobe PDF format on CD-ROM, the Agency’s expectation based on
experience is that the majority of registrants want to send their
requests in writing with ink signatures.  In the future, if it appears
that electronic submission of waiver requests by e-mail is beneficial
and feasible for respondents and EPA, we will seek to facilitate such
submissions.

3(f) 	Confidentiality

The information requested to document fee waiver or exemption requests
may contain confidential business information (CBI).  However, data
and/or information submitted to the Agency in conjunction with service
fee waiver or exemption requests may be claimed as trade secret or
commercial or financial information and will be protected from
disclosure under FIFRA section 10 and the associated regulation as
contained in 40 CFR Part 2, Subpart B.  Information claimed as CBI is
protected from public disclosure unless the Administrator determines
that disclosure is in the public interest.  OPP routinely handles CBI
data, and personnel are familiar with security procedures in accordance
with provisions of the FIFRA Confidential Business Security Manual to
ensure confidentiality.  If any information is submitted that applicants
claim as confidential, the Agency will employ the established procedures
for handling such material.

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

The North American Industrial Classification System (NAICS) codes
assigned to the parties responding to this information collection are as
follows:

NAICS Code	

Category	

Description



32532	

Pesticide and other agricultural chemical manufacturing	

individuals or entities engaged in activities related to the
registration of a pesticide product



32518	

Other Basic Inorganic Chemical Manufacturing	

manufacturers of inorganic chemicals used as inert ingredients in
pesticide products



32519	

Other Basic Organic Chemical Manufacturing	

manufacturers of organic chemicals used as inert ingredients in
pesticide products.



4(b) 	Information Requested

	4(b)(i)	    Data items, including record keeping requirements

A registration applicant who seeks a small business waiver must submit a
waiver request with appropriate documentation demonstrating that he
meets the criteria established in the PRIA, i.e., that he has fewer than
500 employees and has no more than $60 million in annual global gross
revenue from pesticides, averaged over the most recent three maintenance
fee billing cycles, including any such revenue from affiliates.  For
this purpose, the applicant may be required to submit documentation
regarding numbers of employees and, on behalf of itself and its
affiliates, gross revenue figures, and information on revenue from
pesticides over a three-year period.

A registration applicant who seeks a minor use waiver or exemption must
provide supporting documentation that anticipated revenues from the uses
that are the subject of the application would be insufficient to justify
imposition of the full registration fee.  

A registration applicant seeking an IR-4 exemption must merely request
the waiver on Form 8570-1 (Application for Pesticide Registration,
approved under OMB Control #2070-0060) and submit the application at the
same time that the IR-4 tolerance petition is submitted.  The Agency
will, in turn, determine whether the application is solely associated
with a tolerance petition submitted by IR-4 and that the waiver is in
the public interest (see Attachment E).

Although there is no record keeping requirement, PRIA provides that an
application shall be subject to a registration service fee if, at any
time, EPA determines that (i) the documentation supporting the waiver
request is not accurate or (ii) based on the documentation or any other
information, the waiver or reduction should not have been granted. 
Therefore, it is anticipated that applicants will retain copies of their
submissions as well as documents demonstrating that the applicant is
eligible for the waiver or reduction.  

There are currently no EPA forms associated with this information
collection activity.  However, an industry workgroup comprised of
representatives of registrant companies and trade associations designed
a form for assisting pesticide registrants when they submit small
business waiver requests under PRIA.  The form is available
electronically through the Consumer Specialty Products Association’s
web site (  HYPERLINK
"http://www.cspa.org/public/news/fees_document.pdf" 
http://www.cspa.org/public/news/fees_document.pdf ).  EPA does not
sponsor this form and its use is strictly voluntary.  The Agency will
accept information that is submitted via the industry form as well as
any other format that meets the requirements of the statute.

	4(b)(ii)	    Respondent Activities

	Guidance on the content and submission of fee waiver requests is
available on EPA’s website at   HYPERLINK
"http://www.epa.gov/pesticides/fees/questions/waivers.htm" 
http://www.epa.gov/pesticides/fees/questions/waivers.htm  (also, see
Attachment D).  If a registration applicant wishes to request a fee
waiver or exemption, at a minimum, it must undertake the following
activities:

     ·	Generate and submit the necessary materials to support the
request.

    

     ·	Indicate that a waiver or exemption is requested and that the
appropriate documentation supporting the request is enclosed or has been
otherwise submitted to the Agency.

5.	THE INFORMATION COLLECTED - AGENCY ACTIVITIES, COLLECTION 
METHODOLOGY, AND INFORMATION MANAGEMENT

5(a) 	Agency Activities

The Agency is expected to engage in the following activities:

Review and evaluate fee waiver requests.  Notify applicant of decision.

	Verify payments. Cross check payment information from Financial
Management Division.

	Store the data.  Image all forms, listings, telephone conversations,
etc., for archiving.

5(b) 	Collection Methodology and Management

Fee payments are sent to the Financial Management Division in St. Louis,
MO and entered in to the Agency's Integrated Financial Management System
(IFMS).  Payment information is extracted from IFMS and loaded into
OPP's tracking system (OPPIN).  Payment is due at time of application. 
If additional payment is required, invoices are generated and sent both
electronically and in paper.    All payments and invoices are generated
electronically and tracked in OPPIN.  Incoming letters, fee waiver and
exemption applications, mail receipts, petitions, and other types of
correspondence from registrants will be retained in hard copy for a
period of time and then imaged for long term electronic storage.  

Procedures for evaluating fee waiver and exemption requests will not
change.  Information and materials submitted to justify a fee waiver are
screened for completeness by the receiving division.  Economic data are
sent to OPP’s Biological and Economic Analysis Division for analysis. 
The Agency will keep applicants informed of the status of the waiver
application throughout the process by telephone and by mail.

5(c)    Small Entity Flexibility

Small businesses may request a waiver of the registration service fee. 
A waiver applicant must demonstrate that it meets the criteria as
outlined in the PRIA.  The information that needs to be compiled in
order to make this determination is information that companies routinely
collect and maintain in the normal course of business.

5(d) 	Collection Schedule

There is no set collection schedule, per se.  Rather, the registration
service fee is collected each time a registrant submits a registration
application.  The applicant must either pay a fee or request and be
granted a waiver or exemption for each registration application
submitted if the application is within the scope of one of the 140 fee
categories.

6.	ESTIMATING THE BURDEN AND COST OF THE COLLECTION 

6(a) 	Estimating Respondent Burden

In calculating the potential respondent burden, the Agency estimated 310
responses per year for requesting fee waivers or reductions or
exemptions, based on the numbers of fee waiver or exemption 
applications during the maintenance fee cycle for the year of 2008.  

IR-4 waiver requests are not accounted for in this burden estimation. 
To be eligible for the IR-4 exemption under PRIA 2, the application must
be solely associated with a tolerance petition submitted by the IR-4
program and the exemption must be in the public interest.  To facilitate
this request, the applicant may simply include the statement "This
application is being submitted with a tolerance petition submitted in
connection with IR-4.  I request EPA to exemption the registration
service fee for this application under the IR-4 waiver provisions of
FIFRA Section 33(b)(7)(E)." on Form 8570-1 (Application for Pesticide
Registration).  Burden hours associated with completing this form are
already covered by the ICR entitled “Application for New or Amended
Registration” approved under OMB Control Number 2070-0060.  EPA is not
requiring that registrants submit additional information.  The Agency
will determine whether the application is solely associated with a
tolerance petition submitted by IR-4 and whether the exemption is in the
public interest.

	Minor use waiver or exemption requests are not considered in estimating
respondent burden because since March 23, 2004, only thirteen requests
have been received out of several thousand applications.

There are three types of small business waiver applications. The first
type, Type A, is a first-time applicant requesting fee waiver or
reduction.  The second type, Type B, is an application requesting
another fee waiver or reduction within the same maintenance fee billing
cycle. The third type, Type C, is from an applicant who has applied for
a fee waiver in a prior maintenance fee billing cycle but not in the
current cycle.  EPA assumes that the respondent burden and cost for the
Type B application is the lowest because Type B applicants will only
need to certify that there have been no changes to the information
previously submitted or, in the alternative, only provide documentation
with respect to those elements that have changed.  Type C applications,
on the other hand, will need to submit all the documentation supporting
the waiver request, providing updated financial and employee
information. EPA assumes, however, that the cost and burden on most Type
C applicants will be less than first time applicants because applicants
will already be familiar with the waiver requirements and, in many
cases, should have a portion of the supporting financial and business
affiliation documentation is readily available. The cost and burden on
the Type A applicants will be the same as those for the first-year
applicants.  EPA assumes that every new applicant seeking a waiver of
the registration service fee will want to familiarize him/herself with
the criteria from the outset, thus this burden is considered a one-time
burden that will occur the first time the applicant submits a
registration application under the PRIA.  

	Based on the number of waiver requests EPA actually received during the
first full year of PRIA 2, the maintenance billing cycle for 2008, EPA
estimates that 1800 requests for registration actions will be received
per year, of which 293 will request fee waivers or reductions. Of the
293 responses EPA estimates that 11% (31 out of 293) will be the
first-time applicants (Type A), 59% (174 out of 293) will be the Type B
applications, and 30% (88 out of 293) will be Type C applications each
year,  EPA estimates of respondent burden hours per response, for each
of the three response types, were corroborated by representative
respondents in consultations (see section 3(c) of this supporting
statement) and have not been revised for this ICR renewal.  The burden
per response, number of responses, and total burden for each of the
three response types are presented in Tables 1, 2, 3, and 5, below.

6(b) 	Estimating Respondent Costs

Consistent with recent ICR renewals, OPP is using labor cost estimates
from Agency economists with respect to wages, benefits and overhead for
all labor categories for affected industries, state government, and EPA
employees.  This approach uses a transparent and consistent methodology
and current publicly-available data to provide more accurate estimates
and allow easy replication of the estimates.

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 the Agency’s staffing 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.  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.

Attachments G – G.1 contain worksheets providing the breakout of these
costs.  Costs are indexed to 2008 data.  

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 $109.82,
$60.39, and $35.89 per hour, respectively.  These labor rates are fully
loaded and include benefits and overhead costs.

 EPA expects that applicants will incur minor expenses that are not
directly related to paperwork activities, such as the costs of producing
photocopies and postage costs.  EPA estimates that these costs will
average about $10 per applicant and has factored these costs into the
estimated total cost figures. Annual respondent burden and costs could
vary with such factors as business structure of waiver applicants and
types of information submitted.  Therefore, the actual respondent burden
and costs to a respondent could be higher or lower than the estimated
respondent burden and costs reflected in tables 1, 2, and 3. 

Table 1: Annual Respondent Burden and Cost Estimates (Type A)

COLLECTION ACTIVITY	

Burden Hours (per year)	

Total

	Management $109.82/hr	Technical $60.39/hr	Clerical $35.89/hr	

Hours	

Costs ($)



Read regulation and plan activities	

7	

0	

0	

7	769



Generate materials for waiver request for submission to EPA	

0	

24	

0	

24	1,449



Store/maintain/submit and produce information	

0	

0	

6	

6	215



Totals	

7	

24	

6	

37	2,433

PAPERWORK BURDEN AND COST: 

37 hours/response x 31 responses = 1,147 total hours

$2,433/response x 31 responses = $75,423

NON-PAPERWORK COSTS:

$10 (postage and paper copies) x 31 responses = $310

TOTAL ANNUAL RESPONDENT COST (TYPE A): 

$75,423 (paperwork) + $310 (non-paperwork) = $75,733

Table 2: Annual Respondent Burden and Cost Estimates (Type B)

COLLECTION ACTIVITY	

Burden Hours (per year)	

Total

	Management $109.82/hr	Technical $60.39/hr	Clerical $35.89/hr	

Hours	

Costs ($)



Read regulation and plan activities	

2	

0	

0	

2	220



Generate materials for waiver request for submission to EPA	

0	

4	

0	

4	242



Store/maintain/submit and produce information	

0	

0	

6	

6	215



Totals	

2	

4	

6	

12	677

PAPERWORK BURDEN AND COST: 

12 hours/response x 174 responses = 2,088 total hours

$659/response x 174 responses = $114,666

NON-PAPERWORK COSTS:

$10 (postage and paper copies) x 174 responses = $1,740

TOTAL ANNUAL RESPONDENT COST (TYPE B): 

$114,666 (paperwork) + $1,740 (non-paperwork) = $116,406

Table 3: Annual Respondent Burden and Cost Estimates (Type C)

COLLECTION ACTIVITY	

Burden Hours (per year)	

Total

	Management $109.82/hr	Technical $60.39/hr	Clerical $35.89/hr	

Hours	

Costs ($)



Read regulation and plan activities	

2	

0	

0	

2	220



Generate materials for waiver request for submission to EPA	

0	

19	

0	

19	1,147



Store/maintain/submit and produce information	

0	

0	

6	

6	215



Totals	

2	

19	

6	

27	1,582

PAPERWORK BURDEN AND COST: 

27 hours/response x 88 responses = 2,376 total hours

$1631/response x 88 responses = $143,528

NON-PAPERWORK COSTS:

$10 (postage and paper copies) x 88 responses = $880

TOTAL ANNUAL RESPONDENT COST (TYPE C): 

$143,528 (paperwork) + $80 (non-paperwork) = $143,608

6(c) 	Estimating Agency Burden and Cost

The Agency’s burden consists of reviewing, evaluating, and notifying
applicants of the Agency’s decision to grant or deny fee waiver
requests; entering data into tracking systems; verifying fee payment;
and storing/maintaining this information.  Table 4 estimates EPA’s
burden for performing these activities.  Agency labor costs for this
renewal for managerial, technical and clerical rates are estimated at
$107.56, $71.58, and $41.21 per hour, respectively.  These labor rates
are fully loaded and include benefits and overhead costs.

Table 4: Annual Agency Burden and Cost Estimates 

COLLECTION ACTIVITY	

Burden Hours (per year)	

Total

	

Management.$107.56/hr	

Technical

$71.58/hr	

Clerical

$41.21/hr	

Hours	

Costs ($)



Review submitted waiver request and notify requestor of decision	

1	

20	

2	

23	1,622



Enter data into tracking systems	

0	

0	

0.5	

0.5	21



Verify payment	

0	

0	

0.5	

0.5	21



Store/maintain/submit information	

0	

0	

1	

1	41



Totals	

1	

20	

4	

25	1,704

ANNUAL BURDEN: 25 hours/response x 293 responses = 7,325 Hours

ANNUAL COSTS: $1610/response x 293 responses = $471,730

	6(d) 	Bottom Line Burden Hour and Cost Tables

Table 5: Total Annual Burden and Cost Estimates

	

	TOTAL ESTIMATES

	

	Hours	

	Costs



Applicant -Annual

 (Type A + Type B + Type C)	5,611	335,747



                Type A	1,147	75,733



                Type B	2,088	116,406



                Type C	2,376	143,608



Agency - Annual	

7,325	

$471,730



6(e) 	Reasons For Changes In Burden

The total estimated annual respondent burden for this ICR has decreased
by 2,757 hours, from 8,368 hours in the existing ICR, to 5,611 hours for
this renewal.  The average estimated burden per response for each of the
three types of applications has not changed:  37 hours for Type A, 12
hours for Type B, and 27 hours for Type C.  These estimates of burden
per response were corroborated by consultations with respondents (see
section 3(c) of this supporting statement).  However, the total number
of responses per year decreased from 389 to 293, and the percentage of
the total received for each type changed significantly.   Both the total
number of waiver requests received, and the number (or percentage) of
each of the three types of responses, were based on EPA estimates in the
current ICR, as the program was still very new and a year’s worth of
observations were not available.  However in this renewal request, the
annual number and distribution of responses among the three types are
based on actual responses received.  The major shift in the distribution
of responses to the least-burdensome type (Type B), resulted in the
lower total estimated burden.  

	6(f) 	Burden Statement

The annual public reporting and recordkeeping burden for this collection
of information is estimated to average 37, 12, and 27 hours per
response, for the three different types of applications.  According to
the PRIA, “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 includes the time needed to read the new regulation, review
instructions, plan activities, assemble pertinent materials, and
transmit or otherwise disclose the information.  An agency may not
conduct or sponsor, and a person is not required to respond to, a
collection of information that is subject to the PRIA unless the Agency
displays a currently valid OMB control number.  The OMB control numbers
for EPA's regulations in title 40 of the CFR, after initial display in
the final rule, are listed in 40 CFR part 9. Since the collection
activities in this ICR are contained in the PRIA and not a current
regulation, the OMB control number for this collection activity appears
in this ICR. 

The Agency has established a public docket for this ICR under Docket ID
No. EPA-HQ-OPP-2009-0885, 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.  

Submit your comments, referencing Docket ID No. EPA-HQ-OPP-2009-0885 to
(1) EPA online using www.regulations.gov (our preferred method), or by
mail to: Public Information and Records Integrity Branch (PIRIB), Mail
Code: 7502P, 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. Include docket ID No.
EPA-HQ-OPP-2009-0885 and OMB control number 2070-0167 in any
correspondence but do not submit fee waiver requests to these
addresses.ATTACHMENTS TO THE SUPPORTING STATEMENT

	All of the attachments listed below can be either found in the docket
for this ICR, or a link to the source is provided (unless otherwise
noted); accessible electronically through   HYPERLINK
"http://www.regulations.gov/"  www.Regulations.gov  . On the main page,
select Advanced Search from the menu bar at the top and select Docket
Search. Enter the Docket ID Number, EPA-HQ-OPP-2009-0885 in the Docket
ID field. Click on the Submit button. From the results page, you will be
able to link to the docket view or directly open select documents found
in the docket.

Attachment A	Pesticide Registration Improvement Renewal Act of 2007 –
Available electronically at   HYPERLINK
"http://www.epa.gov/pesticides/regulating/fees/index.htm" 
http://www.epa.gov/pesticides/regulating/fees/index.htm  



Attachment B	Implementing the Pesticide Registration Improvement Act –
Fiscal Year 2008.  Available electronically at    HYPERLINK
"http://www.epa.gov/pesticides/fees/2008annual_report/pria_annual_report
_2008.html" 
http://www.epa.gov/pesticides/fees/2008annual_report/pria_annual_report_
2008.html  



Attachment C	Record of Consultations Between the U.S. Environmental
Protection Agency and Respondents to the Information Collection Request:
 “Pesticide Registration Fee Waivers” 



Attachment D	Guidance on How to Request Small Business Fee Waivers. 
Available electronically at   HYPERLINK
"http://www.epa.gov/pesticides/fees/questions/waivers.htm" 
http://www.epa.gov/pesticides/fees/questions/waivers.htm  



Attachment E	Guidance on IR-4 Exemptions.  Available electronically at  
HYPERLINK
"http://www.epa.gov/pesticides/fees/questions/guidance_ir-4.htm" 
http://www.epa.gov/pesticides/fees/questions/guidance_ir-4.htm 



Attachment F	PRIA 2 fees.  Available electronically at   HYPERLINK
"http://www.epa.gov/pesticides/regulating/fees/tool/category-table.html"
 http://www.epa.gov/pesticides/regulating/fees/tool/category-table.html 
and the Federal Register announcement of the current fee schedule is
available on   HYPERLINK
"http://www.epa.gov/fedrgstr/EPA-PEST/2008/August/Day-05/p17936.htm" 
http://www.epa.gov/fedrgstr/EPA-PEST/2008/August/Day-05/p17936.htm 



Attachment G	Worksheet for Estimating OPP ICR Wage Rates for Industry,
State and EPA Labor is attached below.





	.

Attachment C 

Consultations Between the US Environmental Protection Agency and
respondents to the Information Collection Request: Pesticide
Registration Fee Waivers; OMB Control No.: 2070-0167	EPA ICR No.:
2147.04

 

Company Name:  Walter G. Legge Company, Inc.

Name of person consulted:  Liz Bauer

Date: 12/10/09

Q: When preparing your waiver request did you consult the Questions and
Answers on the EPA website
(http://www.epa.gov/pesticides/fees/questions/waivers.htm)?

A:  Yes

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

A:  Not necessary.  Hard to find it on the web and, once found it was
hard to understand and was redundant.

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

A:   Link directly to small businesses on the pesticides web site. 
Reduce the number of steps to complete a small business waiver request
and provide a direct link to pay.gov.  EPA not always prompt in
returning phone calls when there are questions.

Q: Are you aware of the industry generated form?

A:  could not find it.  

Q: Would you use the industry generated form
(http://www.cspa.org/pdf/waiver.pdf)?   If no, why not?

	

After receiving a copy of the form from EPA, used it.

Labor Rates:

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

$109.82 /hr management; $60.39 /hr technical staff; $35.89 /hr clerical 

Management prepares small business waiver request.  Approx. $100/hr

•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

Prepares application – 3 hours provided EPA does not need to be
contacted for questions.

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

No technical support in preparing application.

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

No clerical support used.

Q: Did we miss anything?

Comments:

Attachment C.1

Consultations conducted for the renewal of the Pesticide Registration
Fee Waivers; OMB Control No.: 2070-0167	EPA ICR No.: 2147.04

Company Name:  Falcon Lab LLC

Name of person consulted:  Terry Pizzarello, COO

Date: December 14, 2009 

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:   No suggestions at this time.

Q: Are you aware of the industry generated form?

A:  yes

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

Yes

Labor Rates:

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

$109.82 /hr management; $60.39 /hr technical staff; $35.89 /hr clerical 

Do not know – family owned company.

•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

Management prepares the small business fee waiver request.   2.0 hours
for an initial submission during a maintenance fee cycle.  Subsequent
application in the same year -   0.75 hours

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 10 hrs

Q: Did we miss anything?

 No

Comments:

Attachment G

Work Sheets used to Calculate Registrant Labor Costs  

This attachment is available as part of the electronic docket EPA-HQ-OPP
and is part of the ICR’s Supporting Statement.

NAICS:  325300

Pesticide, Fertilizer, and Other Agricultural Chemical Manufacturing

Labor Category:	Formula	Managerial	Technical	Clerical

Unloaded Hourly Rate1	 = W	$51.01 	$28.05 	$16.67 

Benefits Percentage2	Lb = B/W	44%	44%	44%

Benefits per hour	B = W*Lb	$22.20 	$12.21 	$7.26 

Loaded Hourly Rate	Wb = W + B = W(1+Lb)	$73.21 	$40.26 	$23.93 

Overhead Percentage3	Lo = OH/Wb	50%	50%	50%

Overhead per hour	OH = Wb*Lo	$36.61 	$20.13 	$11.96 

Fully Loaded Hourly Rate	Wf = Wb + OH

 = W + B + OH  	$109.82 	$60.39 	$35.89 



1.  Data Source:  BLS   HYPERLINK
"http://www.bls.gov/oes/current/naics4_325300.htm" 
http://www.bls.gov/oes/current/naics4_325300.htm      May 2008 data

     NAICS 325300 - Pesticide, Fertilizer, and Other Agricultural
Chemical Manufacturing

     Standard Occupational Codes:   

       Management:   11-0000, Management Occupations  

       Technical:        19-0000, Life, Physical, and Social Science
Occupations 

       Clerical:           43-0000, Office and Administrative Support
Occupations 

2. Fringe benefits/wage per hour.   

3. U. S. Environmental Protection Agency, EPA Air Pollution Control Cost
Manual, Sixth Edition, EPA-452-02-001, January 2002, pg. 2-34.  The
loading for indirect costs is within the range of 20-70% of the load
labor rate (wage + benefits) suggested in EPA guidance.

Attachment G

Work Sheets used to Calculate EPA Labor Costs

This attachment is available as part of the electronic docket EPA-HQ-OPP
and is part of the ICR’s Supporting Statement

NAICS: 999100 

Federal Executive Branch

Labor Category:	Formula	Managerial	Technical	Clerical

Unloaded Hourly Rate1	 = W	$49.96 	$33.25 	$19.14 

Benefits Percentage2	Lb = B/W	44%	44%	44%

Benefits per hour	B = W*Lb	$21.75 	$14.47 	$8.33 

Loaded Hourly Rate	Wb = W + B = W(1+Lb)	$71.71 	$47.72 	$27.47 

Overhead Percentage3	Lo = OH/Wb	50%	50%	50%

Overhead per hour	OH = Wb*Lo	$35.85 	$23.86 	$13.74 

Fully Loaded Hourly Rate	Wf = Wb + OH

 = W + B + OH  	$107.56 	$71.58 	$41.21 



1.  Data Source:  BLS   HYPERLINK
"http://www.bls.gov/oes/current/naics4_999100.htm" 
http://www.bls.gov/oes/current/naics4_999100.htm   May 2008 data

     NAICS  999100 -  Federal Executive Branch

     Standard Occupational Codes:   

       Management:   11-0000, Management Occupations  

       Technical:        19-0000, Life, Physical, and Social Science
Occupations 

       Clerical:           43-0000, Office and Administrative Support
Occupations 

2. Fringe benefits/wage per hour.   

3. U. S. Environmental Protection Agency, EPA Air Pollution Control Cost
Manual, Sixth Edition, EPA-452-02-001, January 2002, pg. 2-34.  The
loading for indirect costs is within the range of 20-70% of the load
labor rate (wage + benefits) suggested in EPA guidance.

 All table totals have been rounded to the nearest dollar or hour after
all computations were made; in 2008 dollars.

 All table totals have been rounded to the nearest dollar or hour after
all computations were made; in 2008 dollars.

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