Attachment D

 

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.

