SUPPORTING STATEMENT FOR AN

INFORMATION COLLECTION REQUEST

1.	IDENTIFICATION OF THE INFORMATION COLLECTION

1(a)  Title of the Information Collection

TITLE:  Requirements for Certified Applicators Using 1080 Collars for
Livestock Protection

OMB NO. 2070-0074			EPA No. 1249.09

1(b)  Short Characterization/Abstract

This information collection request (ICR) is a renewal of an existing
ICR that is currently approved by OMB and is due to expire on March 31,
2014. This information collection activity enables the Environmental
Protection Agency (EPA) to obtain the information needed to track the
use of registered Livestock Protection Collar products which contain
solutions of Sodium Monofluoroacetate (Compound 1080) and the record
keeping requirements imposed by an administrative judge in October 1982
and confirmed by the Agency in 1983.  This ICR potentially affects
non-federal Certified Applicators in three States (New Mexico, South
Dakota, and Wyoming), the State lead agencies for pesticide regulation
in those States that monitor the program and are themselves registrants
of 1080 Livestock Protection Collar products, and one additional
registrant.  EPA also receives annual reports on use of a 1080 Livestock
Protection Collar product registered to the U.S. Department of
Agriculture, Animal and Plant Health Inspection Service (USDA/APHIS). 
That product is applied in several States by employees of USDA/APHIS. 
Applicators who are certified to apply livestock protection collars are
required to keep records of: a) the number of collars attached on
livestock; b) the pasture(s) where collared livestock were placed; c)
the dates of each attachment, inspection, and removal; d) the number and
locations of livestock found with ruptured or punctured collars and the
apparent cause of the damage; e) the number, dates, and approximate
location of all collars lost; and f) the species, locations, and dates
of all suspected poisonings of humans, domestic animals or non-target
wild animals resulting from collar use.

  

EPA receives annual monitoring reports regarding 1080 collars from
registrants and State lead agencies. Applicators are required to
maintain records.  The registrants/state agencies do the monitoring
studies and submit the reports.  These records are monitored by either
a) State lead agencies, or b) registrants. This ICR also covers
monitoring activities associated with collar use, as well as the
preparation and submission of an annual monitoring report to EPA, that
are over and above requirements that are either conditions of
registration or obligations associated with the handling and regulation
of any restricted use pesticide product.  

2.	NEED FOR AND USE OF THE COLLECTION

2(a) Need/Authority for the Collection

EPA banned all predator control uses of Sodium Monofluoroacetate in
1972.  In 1981 and 1982, EPA received applications to register Compound
1080 in several delivery mechanisms, one of which was the toxic collar. 
Following extensive public hearings in 1982, EPA's Administrative Law
Judge Nissen declared, on October 22, 1982, that the Agency could
register the collar, with certain specific use restrictions, after going
through the normal registration process.  The Administrative Law Judge
included restrictions and recordkeeping requirements in Attachment C of
his initial decision (see Attachment A).  On October 31, 1983, then EPA
Assistant Administrator Lee M. Thomas affirmed Judge Nissen's initial
decision, including the use restrictions and recordkeeping requirements.

Prior to 1972, 1080 was used for predator control in a number of ways,
some of which were subject to the 1982 proceedings, which either did not
receive a favorable ruling from the Administrative Law Judge or were not
subsequently registered for other reasons. As there have been occasional
reports of predator control use and other uses of 1080 by illegal
methods subsequent to 1972, EPA believes that it is extremely important
to account for the 1080 that is supplied for legal use so as to maintain
surveillance on the toxic collar program and to deter diversion of 1080
in the program from legal to illegal predator control use.  As 1080 is a
highly soluble material of potent but delayed oral toxicity, there are
additional concerns about transfer of this material to persons who might
use or threaten to use it as a weapon of terrorism.

2(b) Practical Utility/Users of the Data

As a condition of the 1080 livestock protection collar registration, EPA
required submission of annual reports monitoring use of all livestock
protection collar products.  Depending upon the product, the registrant
or the State lead agency for pesticide regulation is designated as being
responsible for submitting an annual monitoring report.  The requirement
to submit reports is imposed for at least the first four years of the
collars' use under the registration.  Factors affecting the extension of
requirements to submit annual reports include:  1) quality of reports
submitted previously; 2) amount of use reported; 3) results of collar
use (in terms of numbers punctured by coyotes, numbers punctured by
other causes, numbers lost, nontarget poisonings, etc.); 4) frequency
and nature of violations reported; and 5) arrangements made between EPA
and registrants regarding annual reports of collar use to meet other
requirements for reporting information.  EPA reviews the annual reports
to assess compliance with the 1982 Administrative Law decision and the
requirements of product labeling. In 1992, at the request of the Texas
Department of Agriculture, this requirement was discontinued for the
Livestock Protection Collar product registered to a private company for
use only in Texas. Up to that time, the TDA had supplied 4 years of
reports showing considerable use of the product. From the data supplied
in those reports, EPA drew conclusions which led to the Agency’s
agreeing to the request.

3.	NONDUPLICATION, CONSULTATIONS, AND OTHER COLLECTION CRITERIA

3(a)  Nonduplication

The processes for recordkeeping, reporting nontarget exposure incidents,
and submitting monitoring reports are not duplicative of any other known
information collection requirement.  This information would not be
compiled or reported but for these special requirements for livestock
protection collars.  While certain information on collar production may
be required by agencies that prepare monitoring reports, this
information would not, in the main, be duplicative of the confidential
production reports that all pesticide registrants must file.  The
reports are limited to one specific, heavily regulated product and
represent the most efficient means for others to generate and EPA to
receive this information.  This information may not, in all cases, be
available to the State lead agencies but for the specific reporting
requirements that they impose upon registrants of 1080 livestock
protection collars.

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

	Pursuant to 5 CFR 1320.8(d), in proposing to renew this ICR, EPA is
publishing a notice in the Federal Register that provides a 60-day
public notice and comment period.  The materials related to the proposed
renewal of this ICR, as well as any comments submitted during the public
comment period may be accessed as described in section 6(f) of this
supporting statement. 

3(c)  Consultations

Under 5 CFR 1320.8(d)(1), agencies are required to consult with
potential ICR respondents and data users about specific aspects of
ICR’s before submitting an original or renewal ICR to OMB for review
and approval. During the development of this renewal ICR, EPA staff will
contact appropriate stakeholders and ask them for their assessment of
the regulatory burden estimates expressed by the Agency in this ICR.  A
summary of these consultations will be provided in the supporting
statement during the second comment period.

	3(d)  Effects of Less Frequent Collection

Annual monitoring reports are the only items pertaining to collars for
which EPA requires scheduled submissions.  Longer intervals between
submissions would make the information received and EPA's responses to
the reports less timely.  Longer intervals also would likely increase
the amount of time that would be needed to prepare each individual
report, increasing the burden on submitters. 

	3(e)  General Guidelines

Requiring monitoring reports to be submitted once a year does not
conflict with the general guidelines for data requesters.  The required
reporting of nontarget incidents, in practice, has not generated any
rate of submissions that could be construed as being in violation of
these general guidelines.  The need for such incidents to be reported
rapidly is clear, however.  As discussed below in Section 5(c) of this
ICR, the reporting requirements for small entities have been limited as
much as is legally and responsibly possible.

3(f)  Confidentiality

Under FIFRA, health and safety data submitted by registrants are
considered by EPA to contain no confidential business information (CBI).
 If registrants submit data that relate to trade secrets or commercial
or financial information, such information is protected from disclosure
under Section 10 of FIFRA. Confidential data submitted by registrants to
EPA in response to this particular information collection activity will
be handled strictly in accordance with provisions of the FIFRA
Confidential Business Information Security Manual (Attachment D).  This
manual contains instructions relative to all in contact with
confidential documents, including:  responsibilities of the 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 EPA.  The manual dictates that all CBI must be
marked or flagged as such, 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 information collection activity.  Further, this
information collection activity complies with the provisions of the
Privacy Act of 1974 and OMB Circular A-108.  The names and addresses of
both certified livestock protection collar applicators and any other
persons who own s property on which livestock protection collars have
been or will be applied by a certified applicator are considered
personal information that will not be disclosed if ever in the
possession of EPA. In accordance with 7 USC 136i-1(b), unsolicited
information of a sensitive or private nature included in monitoring
reports already received, or submitted in the future, will be protected
from public release. 

4.	THE RESPONDENTS AND THE INFORMATION REQUESTED

4(a)  Respondents/NAICS Codes

This information collection activity applies to all certified pesticide
applicators that apply 1080 collars, to the pesticide manufacturer’s
whose products include 1080 collars, and to the government agencies
responsible for implementing and administering a 1080 collar monitoring
program.  Information available to EPA indicates that most of the
certified applicators subject to this ICR are employees of the Animal
and Plant Health Inspection Service (APHIS) within the US Department of
Agriculture (USDA).  A small number of other certified applicators may
also apply 1080 collars in New Mexico, South Dakota, and Wyoming,
currently or in the future.  The North American Industrial
Classification System codes assigned to the businesses and other
institutions participating in this program are 325300 (Pesticide,
Fertilizer, and Other Agricultural Chemical Manufacturing), 926140
(Regulation of Agricultural Marketing and Commodities), and 999200
(State Government).

4(b)  Information Requested

4(b)(i)  Data Items

	The data that certified livestock protection collar applicators are
required to record and maintain were outlined in the Initial Decision of
the Administrative Law Judge in the 1080 Predacide Hearings.  These
requirements are stipulated in "Use Restriction 5" in the technical
bulletin that is part of the labeling for all Livestock Protection
Collar products registered as pesticides in the United States.  Use
Restriction numbers and content vary somewhat from product to product
due to additional restrictions or considerations either proposed by the
registrants or required by State lead agencies. A list of Use
Restrictions can be found in Section V.B.2 of EPA’s 1995
Re-registration Eligibility Decision concerning sodium fluoroacetate
(Attachment E).  

Registrants of livestock protection collars are required, by Use
Restriction 4 of the same typical technical bulletin, to: 

". . . keep records of all collars sold or transferred at their address
of record.  Records shall include the name, address, state where
livestock protection collar certification was issued, certification
number of each recipient, and dates and numbers of collars sold or
transferred."

Use Restriction 5, from a typical technical bulletin, reads as follows:

"Each applicator shall keep records dealing with the use of livestock
protection collars and the results of such use.  Records shall be
maintained in accordance with appropriate State or Federal regulations
but for not less than two years following disposal or loss of collars. 
Such records shall include, but need not be limited to:

The number of collars attached on livestock.

The pasture(s) where collared livestock were placed.

The dates of each attachment, inspection, and removal.

The number and locations of livestock found with ruptured or punctured
collars and the apparent cause of the damage.

The number, dates, and approximate location of all collars lost.

The species, locations, and dates of all suspected poisonings of humans,
domestic animals or non-target wild animals resulting from collar use."

Use Restriction 6, from the same typical technical bulletin, requires
that "suspected" poisonings of "threatened or endangered species, …
humans, domestic animals or nontarget wild animals" be reported, within
three days of the incident, to a designated government agency (EPA
and/or the appropriate State lead agency for regulation of pesticides). 
EPA requires that certified applicators of livestock protection collars
keep and report only those records prescribed by Use Restrictions 5 and
6.

4(b)(ii)  Respondent Activities

Certified livestock protection collar applicators are required by
product labeling to prepare and maintain records of various activities
associated with use and fate of livestock protection collars that they
purchase or obtain for use.  Preparing these records consists of writing
down what is done in normal use and handling of collars.

The use of livestock protection collars is a labor-intensive process. 
For a typical sheep operation, collar use involves the following
activities:

corralling sheep;

isolating target flocks;

capturing appropriate livestock and equipping them with collars;

redeploying target and main flocks in ways that are expected to direct
coyotes' attacks toward target flocks and away from the remainder of the
producer's sheep or goats;

inspecting target flocks weekly (or more frequently) to account for
livestock alive, dead, or missing; to search for lost sheep (or goats)
or lost collars; to capture livestock that require adjustments to collar
position or other hands-on attention; and to properly handle and dispose
of irreparably damaged collars; and, when collar use is to be
terminated; corralling target flocks, capturing collared livestock,
removing and inspecting collars, disposing of damaged collars, and
returning intact collars to proper secure storage.

The recordkeeping requirements add the need to record significant data
associated with collar use such as how many collars were used, where and
when they were used, how many were damaged, likely causes of such
damage, where collars went after use, and the occurrence of possible
nontarget exposure incidents.  The time and other costs associated with
preparation and maintenance of sale records are conditions of collar use
which are required by the product’s labeling.  Such requirements are
not part of the subject ICR.  Burdens related to the ICR begin with the
compilation of applicator’s records and with activities associated
with assembling data for inclusion in monitoring reports.

Registrants and/or State lead agencies have developed their own
instruments that facilitate appropriate recordkeeping by certified
applicators.  State lead agencies typically require certified livestock
protection collar applicators to file periodic reports summarizing
collar use.  Data from these reports are included in annual monitoring
reports submitted to EPA by registrants or state lead agencies.  Other
data that appear in monitoring reports include summaries of numbers of
collars sold or otherwise legally circulated in the State and the number
and nature of violations detected with regard to use or handling of
livestock protection collars.

	As with other registrants of pesticide products, livestock protection
collar registrants are required to file annual (confidential) production
reports.  These reports are required of all establishments that produce
pesticides or pesticide devices in the United States, pursuant to
Section 7 of FIFRA.  Since production does not equate with use, the ICR
is not duplicative of the requirement to submit annual production
reports, which is covered by a different ICR.

5.	THE INFORMATION COLLECTED - AGENCY ACTIVITIES, COLLECTION

METHODOLOGY, AND INFORMATION MANAGEMENT

5(a)  Agency Activities

Reports of non-target species poisonings and other incidents included in
the annual monitoring reports filed with EPA by State lead agencies are
reviewed by the Insecticide-Rodenticide Branch, which initiates whatever
regulatory steps are warranted by the incident and places a copy of the
incident report in the registration file for the product involved in the
incident.  To date, no nontarget poisoning incidents have been reported
to EPA by State lead agencies.  Reasons for this appear to be the
limited extent to which collars are used, and the relatively low
potential for occurrence and detection of nontarget incidents.  However,
EPA has noted, at times, instances of violations and inaccuracies in
inventory in its reviews of monitoring reports.

EPA replies directly, in writing, to the originator of the report,
indicating whether the report is acceptable, whether additional details
are needed for the current report or future reports, and whether any
specific corrective steps are needed based upon items discussed in the
monitoring report.

	5(b)  Collection Methodology and Management

As the number of registered livestock protection collar products is very
small (5 at present) and very few reports are expected to be received,
no special provisions for data collection and management are needed. 
The reports submitted are handled and processed through mechanisms that
have been developed for handling a wide variety of submissions that
pertain to registered pesticide products.  These include routing the
submission through the routine review process, responding to the
submission in writing, and filing the submission and the response in the
relevant product's registration file.  These submissions are tracked by
EPA's Pesticide Registration Information System (PRISM).

5(c)  Small Entity Flexibility

Most users, and the private company that is a livestock protection
collar registrant, would qualify as small entities.  The degree of
imposition that these recordkeeping and reporting requirements impose on
such individuals is minimal, considering the limited degree of latitude
permitted by the Administrative Law Judge and the Administrator of the
EPA, the extreme toxicity of Compound 1080, and the great potential for
abuse of livestock protection collars if collars or their contents were
to get into the hands of irresponsible persons.  The main purpose of the
recordkeeping requirements is to promote responsible use and handling of
livestock protection collars.  The main purpose for requiring monitoring
reports is to establish a process through which it is mandatory to
inform EPA of the results of collar use.  EPA then can use the data from
reports as bases for future regulatory decisions.

The mandatory submission of periodic reports from applicators to State
lead agencies based on data that they are already required to collect
adds only a minimal amount of burden.  In Texas, where the livestock
protection collar product registered to a private firm is used, the lead
agency requires the registrant to submit sales and distribution
documents to the State.

5(d)  Collection Schedule

Livestock protection collar annual monitoring reports are due on a date
prescribed as a condition of registration, usually February 15, for each
year after the first year in which collars may be used legally.

As nontarget exposure incidents must be reported within three days of
their occurrence, there is no set schedule for collection of this
information.  Such reporting is required by product labeling and,
therefore, is not part of this ICR.  However, nontarget incidents also
would be reported and discussed in monitoring reports for the year in
which they occurred, with follow-up information regarding dispositions
of cases being indicated.    

6.	ESTIMATING THE BURDEN AND COST OF THE COLLECTION

6(a)  Estimating Respondent Burden

EPA has reviewed the estimated burden associated with the 1080 livestock
protection collar annual monitoring reports over its 2010 estimates
based on the reports most recently submitted to EPA.  For the next 3
years, EPA expects that 40 certified applicators (30 for New Mexico and
10 for APHIS) will use and/or possess collars annually and,
consequently, contribute information to be used in monitoring reports. 
EPA does not expect the burden per applicator, which is currently 40
hours, to decrease over the next 3 years.  Therefore, this figure
remains unchanged over our 2010 estimate.  EPA points out that this
estimate was developed under the assumption that, while perhaps
unlikely, one non-target species poisoning incident will occur per year
and require 10 hours of burden (which is included in the 40 hour
estimate).  In all, EPA estimates the total annual burden for certified
applicators of 1080 livestock protection collars to be 1600 hours (40
applicators x 40 hours).

EPA anticipates that 4 registrants and/or State lead agencies will file
annual monitoring reports based upon information obtained from those
certified applicators.  Note that, except in the case of the pesticide
producer (for whom annual product monitoring reports are no longer
required), the registrant is a State or Federal Agency.  The estimated
annual respondent burden for this activity is 77 hours over the next 3
years, and has not changed over the 2010 estimates.  The annual burden
of the States and registrants is based on the annual monitoring report
alone and not other requirements related to use, administration, and
regulation of 1080 Livestock Protection Collars.  There are currently
two States that have been reporting annually on Livestock Protection
Collar use, New Mexico and Wyoming.   Another state, South Dakota may
possibly become involved in reporting activities in the future.  EPA
estimates the total annual burden for agencies submitting annual
monitoring reports to be 308 hours (4 submitters x 77 hours). 

As with other registrants of pesticide products, livestock protection
collar registrants (i.e., the producer(s), not the State agencies) are
required to file annual (confidential) production reports.  There is one
producer and four other registrants. The estimated annual per respondent
burden for this activity is 9 hours, with a total of 36 hours per year
over the next 3 years (4 producers x 9 hours).  

The Agency recognizes that the time needed to prepare reports is
affected primarily by the extent of use and the number of applicator's
to be covered by the report during any given year.  Tables 1, 2, and 3
provide a breakdown of the collection activities per respondent and a
general overview of how the estimates were derived.  The total annual
response burden imposed upon certified applicators, State agencies, and
registrants associated with the use of 1080 livestock protection collars
is estimated to be 1,944 hours (1600 + 308 + 36).

6(b)  Estimating Respondent Costs

As in the 2010 version of this ICR, the Agency estimates wages,
benefits, and overhead for all labor categories for the pesticide
industry, state government and Agency employees.  EPA’s estimates are
based on currently available information on labor rates from the U.S.
Department of Labor 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 that
are used in this ICR are listed in Attachments F, G, and H.

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 registrant respondent costs for
managerial, technical and clerical rates are estimated at $117.74,
$62.58, and $37.33 per hour, respectively.  These labor rates are fully
loaded and include benefits and overhead costs.  	

The state government respondent costs for managerial, technical and
clerical rates are estimated at $85.67, $58.20, and $40.67 per hour,
respectively.  These labor rates are fully loaded and include benefits
and overhead costs.  

	Based on EPA’s methodology for estimating pesticide-related
information collection request wage rates for industry, state, and EPA -
and based on EPA’s familiarity with the 1080 Livestock Protection
Collars program and experiences with USDA - EPA estimates the
fully-loaded labor rate of a certified applicator of 1080 Livestock
Protection Collars to be approximately equal to the state government
clerical labor rate of $40.67/hr (includes the base wage rate, benefits,
and overhead).

The total annual cost for all respondents associated with this
information collection activity is estimated to be approximately
$77,044.  In summary:

Certified applicators:  $65,072

States:  $16,313

Registrants:  $1,950

  

The annual cost for a single respondent is:  

Certified applicator:  $1,627

State:  $4,078 

Registrant:  $487  

Tables 1 through 3 present information for estimating costs based on the
burden hours/costs per respondent.

Table 1. Annual Certified Applicator Burden/Cost Estimates

	

Collection Activities	

Burden Hours	

Total Costa



1.	

Read/hear rule or any collection instrument	3	$122.01



2.	

Receive training b	--	--



3.	

Plan activities	3	$122.01



4.	

Create information	3	$122.01



5.	

Gather information	18	$732.06



6.	

Process and review information for accuracy	5	$203.35



7.	

Record, disclose, or display the information	5	$203.35



8.	

Store, file or maintain the information	3	$122.01



	

TOTAL	40	$1,626.80

(a) Certified Applicator ($40.11/hr)

(b)The burden associated with the training of certified applicators is
accounted for under the ICR for the Agency Certification and Training
Program (EPA ICR# 0155; OMB Control No. 2070-0029).

ANNUAL BURDEN:  	Hour Total (40) x Number of Respondents (40) = 1,600

ANNUAL COST:  		Cost Total ($1,627) x Number of Respondents (40) =
$65,072

Table 2. Annual State Agency Burden/Cost Estimates

Collection Activities	

Burden Hours (per year)	

Total Cost



	

Management

($85.67/hr)	

Tech.

($58.20/hr)	

Clerical

($40.67/hr)	





1.	

Read/hear rule or any collection instrument	

0	

2	

0	$116.40 



2.	

Plan activities	

0	

10	

0	$582 



3.	

Create information	

0	

15	

0	$873 



4.	

Gather information	

0	

14	

0	$814.80 



5.	

Process, compile, and review information for accuracy and
appropriateness	

0	

13	

0	$756.60 



6.	

Record, disclose, display or report the information	

0	

0	

20	$813.40 



7.	

Store, file or maintain the information	

0	

0	

3	$122.01 



	

TOTAL	

0	

54	

23	$4,078.21 



ANNUAL BURDEN:  	Hour Total (77) x Number of Respondents (4) = 308

ANNUAL COST:  		Cost Total ($4,078) x Number of Respondents (4) =
$16,313

Table 3. Annual Registrant Burden/Cost Estimates**

Collection Activities

	

Burden Hours (per year)	

Total Cost



	

Management

($117.74/hr)	

Tech.

($62.58/hr)	

Clerical

($37.33/hr)

	

1.	

Read/hear rule or any collection instrument	

0	

2	

0	$125.16 



2.	

Plan activities	

0	

1	

0	$62.58 



3.	

Create information	

0	

0	

0	$0.00 



4.	

Gather information	

0	

2	

0	$125.16 



5.	

Process, compile, and review information for accuracy and
appropriateness	

0	

1	

0	$62.58 



6.	

Record, disclose, display or report the information	

0	

0	

2	$74.66 



7.	

Store, file or maintain the information	

0	

0	

1	$37.33 



	

TOTAL	

0	

6	

3	$487.47 

** In all but one case, the registrant is the State and, therefore,
covered under State burdens (Table 2).

ANNUAL BURDEN:  	Hour Total (9) x Number of Respondents (4) = 36

ANNUAL COST:  		Cost Total ($487) x Number of Respondents (4) = 1,950

	6(c)  Estimating Agency Burden and Cost

The Agency's total annual burden associated with the 1080 livestock
program has changed based upon more accurate estimates of the resources
required to complete tasks specifically associated with annual
monitoring reports.  

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 EPA labor rates for this renewal for
technical and clerical rates are estimated at $78.24, and $44.61 per
hour, respectively.  These labor rates are fully loaded and include
benefits and overhead costs.  For this ICR, we estimate the annual
Agency burden to be 104 hours and the total annual Agency cost to be
$8,137.  

Table 4.  Annual Agency Burden/Cost Estimates

Collection Activities

	

Burden Hours (annual)	

Total Cost



	

Tech.

($78.24/hr)	

Clerical

($44.61/hr)

	

1.	

Develop any correspondence needed	

8	

0	$625.92 



2.	

Answer respondents’ questions	

2	

0	$156.48 



3.	

Review data submissions	

10	

0	$782.40 



4.	

Analyze data submissions	

4	

0	$312.96 



5.	

Store data	

2	

0	$156.48 



	

TOTAL	

26	

0	$2,034.24 



ANNUAL BURDEN:  	Hour Total (26) x Number of Respondents (4) = 104

ANNUAL COST: 		Cost Total ($2,034) x Number of Respondents (4) = $8,137

6(d)  Bottom Line Burden Hours and Costs

Table 5.  Bottom Line Burden Hours and Costs/Master Table

	

Total Burden Hours	

Total

Cost ($)



Certified Applicator (Table 1)	1,600	$65,072



State (Table 2)	308	$16,313



Registrant (Table 3)	36	$1,950



Bottom Line Respondent Total	1,944	$83,335



Agency Total	104	$8,137



	6(e)  Reasons for Change in Burden

The total annual respondent burden hours does not change from the
previous 2010 ICR.  

	

	6(f)  Burden Statement

The annual respondent burden for the 1080 livestock collar program is
estimated to average 40 hours per certified applicator response, 77
hours per State agency response, and 9 hours per registrant
participating in the program.  Under 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 data
collection activities, conducting tests, analyzing data, generating
reports and completing other required paperwork, and storing, filing,
and maintaining the data.  An 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.

Submit your comments, referencing Docket ID No. EPA-HQ-OPP-2013-0150 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.

Use EPA’s electronic docket and comment system at www.regulations.gov,
to submit or view public comments, access the index listing of the
contents of the docket, and to access those documents in the docket that
are available electronically.  Once in the system, select “docket
search,” then key in the docket ID number identified above.   Please
note that EPA’s policy is that public comments, whether submitted
electronically or in paper, will be made available for public viewing at
www.regulations.gov as EPA receives them and without change, unless the
comment contains copyrighted material, CBI, or other information whose
public disclosure is restricted by statute.  For further information
about the electronic docket, go to   HYPERLINK
"http://www.regulations.gov"  www.regulations.gov .

Attachments to the Supporting Statement

	All of the attachments listed below can be found in the docket for this
ICR (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-2013-0150
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’s Administrative Law Judge’s 1982 Decision on
Restrictions and Recordkeeping Requirements (pp. 217-219, “Attachment
C, Use Restrictions”)

Attachment D:  	Federal Insecticide, Fungicide, and Rodenticide Act
(FIFRA) Confidential Business Security Manual

Attachment E:	EPA’s 1995 Re-registration Eligibility Decision
Concerning Sodium Fluoroacetate

	

Attachment F:	Methodology for Estimating OPP ICR Wage Rates for States
and Applicators

Attachment G:	Methodology for Estimating OPP ICR Wage Rates for
Registrants

Attachment H:	Methodology for Estimating OPP ICR Wage Rates for EPA

May 22, 2013

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