Attachment C 

Consultations Between the US EPA 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 C.2 

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

Company Name:  Mason Chemical Company 

Name of person consulted: Elizabeth Tannehill

Date: December 14, 2009

Q: When preparing your waiver request did you consult the Questions and
Answers on the EPA website?

A:  Not any more, very familiar with them.

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

A: 

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

A:  None

Q: Are you aware of the industry generated form?

A: use the voluntary industry generated form

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

Use the form

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 

•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 application – 4 hours for initial application
per maintenance fee cycle, subsequent application within a maintenance
fee cycle  – less than 1 hour.  Agency estimated labor rate for
management is reasonable.

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?

Attachment C.3 

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

Company Name: Phoenix Environmental Care LLC

Name of person consulted: Sherry Hutcheson

Date: 12/15/09

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: No

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

A: 

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

A:  

Q: Are you aware of the industry generated form
(http://www.cspa.org/pdf/waiver.pdf)?

A:

Q: Would you use the industry generated form? yes

  If no, why not?	

Labor Rates:

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

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

•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: 7 hrs; Subsequent submissions:
2 hrs

Technical:  locating and preparing copies of taxes, audits, payroll
account statements, any market analysis, etc.?  24 hrs; Subsequent
submissions 4 hrs

Clerical: preparing the submission  6 hrs; Subsequent submissions 6 hrs

Q: Did we miss anything? No

Comments:

Attachment C.4 

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

Company Name: Canada Inc.

Name of person consulted:   William Stoneman, consultant

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:   post the name of the contact on the guidance web page

Q: Are you aware of the industry generated form?

A: yes

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

	

Used it once, prefer to send a letter answering questions.

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 rate is reasonable.  Neither technical nor clerical staff
involved in waiver request preparation. 

•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 (both consultant and Canada, Inc.) did all of the work on the
small business fee waiver request.  3 hours spent to prepare an initial
application.  

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:

