SUPPORTING STATEMENT FOR AN 

INFORMATION COLLECTION REQUEST (ICR)

1.	IDENTIFICATION OF THE INFORMATION COLLECTION

1(a)	Title and Numbers of the Information Collection  

Title: Pesticide Registration Fees Program

OMB No.:  2070-0179		EPA No.:  2330.02

1(b)	Short Characterization/Abstract 

This Information Collection Requests (ICR) covers the paperwork burden
hours and costs associated with the information collection activities
under the pesticide registration fee programs implemented through the
Office of Pesticide Programs (OPP), Environmental Protection Agency
(EPA). Pesticide registrants are required by statute to pay an annual
registration maintenance fee for all products registered under Section 3
and Section 24(c) of the Federal Insecticide, Fungicide and Rodenticide
Act (FIFRA).  In addition, the Pesticide Registration Improvement Act
(PRIA) amended FIFRA in 2004 to create a registration service fee system
for applications for specific pesticide registration, amended
registration, and associated tolerance actions (Section 33).  This ICR
specifically covers the activities related to the collection of the
annual registration maintenance fees, the registration service fees and
the burden associated with the submission of requests for fees to be
waived.  

2.	NEED FOR AND USE OF THE COLLECTION 

2(a) Need/Authority for the Collection

Under 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.

Pesticide Product Registration Maintenance Fees

≤ 5 products, ≤ $10 M in total, global sales and ≤ 500 employees)
to seek a 25% maintenance fee reduction on their first product.

Pesticide Registration Service Fee and Waivers

Section 33 of FIFRA requires the collection of fees in order to enhance
the review of covered pesticide products (see Attachment B for
information on the current 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 FQPA deadlines are met; and result in more
predictable and augmented funding for the pesticide program.  Section 33
also established provisions that allow these fees to be exempted
entirely. The registration service fee system was reauthorized by the  
HYPERLINK "http://www.epa.gov/pesticides/fees/"  Pesticide Registration
Improvement Extension Act (PRIA 3)  until September 30, 2017.  Under the
sunset provisions, if PRIA 3 is not reauthorized, the Agency is
authorized to collect reduced fees for two additional years – 40%
reduced fees in 2018 and 70% reduced fees in 2019 below the level in
effect on September 30, 2017.

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, under PRIA 3, the Agency must determine that the exemption
is in the public interest. In February 2013, the Agency issued the
Policy document entitled “Factors for IR-4 Public Interest Finding”
(Attachment C) which lists the criteria under which an application will
be presumed to be in the public interest.  Since this policy exempts
most, if not all, IR-4 registration activities, the Agency does not
anticipate any additional burden will be imposed on IR-4.  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. 

     

2(b) Practical Utility/Users of the Data

Pesticide Product Registration Maintenance Fees

In order to provide an efficient system to bill, collect, and account
for registration maintenance fees, the Agency sends a filing form 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.   In the case where the registrant requests a
small business cap and/or a 25% reduction in the first product’s fee,
the required information is used to ensure that the registrant qualifies
for the fee reduction and is used to assess and report to Congress the
impacts of maintenance fees on small businesses as required in PRIA 3.

Pesticide Registration Service Fee and Waivers

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 PRIA registration fee waiver or exemption.
 Statutorily, in instances where the applicant requests a fee waiver 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,
usually, earlier than the maximum 60 day period.

3.	NON DUPLICATION, CONSULTATIONS, AND OTHER COLLECTION CRITERIA

  

3(a) Non duplication

For pesticide product registration, 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.  Prior to implementing the
current process, the Agency considered an alternative approach which was
to simply notify registrants that fees were due for each of their
products according to a fee schedule.  Under this alternative, 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.  

For pesticide registration fee waivers, no other federal agency or EPA
program is collecting fees for the processing of applications for
pesticide registration or 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 announced and provided a 60-day public
comment period on the information collection activities as described in
this ICR (78 FR 36774, June 19, 2013).  

3(c) Consultations 

During the preparation of this ICR renewal, EPA staff contacted
Kimberlee Young, RegWest Inc, Amy Roberts, Technology Sciences Group Inc
and Kyle Price, Nufarm Americas Inc to solicit stakeholder comment on
the burden and costs associated with this ICR renewal. The Agency
received two comments which have been incorporated into this document as
Attachment G are a part of electronic docket EPA-HQ-OPP-2013-0287 for
this action. 

Pesticide Product Registration Maintenance Fees

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. 

Pesticide Registration Service Fee Waivers

The Pesticide Registration Improvement Extension Act (PRIA 3) that was
introduced into Congress was based upon the past experience in
implementing PRIA 1 and PRIA 2, and a consensus reached by stakeholders,
which was informed in part 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 waiver and exemption 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. 

3(d) Effects of Less Frequent Collection

Annual payment of maintenance fees for all pesticide products is
mandated by FIFRA. 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.

  

For the payment of PRIA registration application fees, 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
applicants submit registration applications.  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

With respect to the PRA imposed guidelines contained in 5 CFR 1320.6,
the information collection activity for pesticide product registration
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 utilizes 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. 

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.

The collection activities for pesticide registration fee waivers comply
with the guidelines for information collections under the 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

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.

The information requested to document fee waiver or exemption requests
may contain 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.



9641	

Regulation of Agricultural Marketing and Commodities	

Includes government establishments responsible for agricultural pest and
weed regulation.



4(b) Information Requested

Annually, the Agency provides registrants with a list of their 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 are transferred to
another company, and to add to the list any products which the company
believes are registered that are not on the Agency-provided list. 
Respondents complete and submit EPA Form 8570-30 (Attachment D)
indicating the respondent's liability for the registration maintenance
fee.  Each affected firm is required to complete the filing form and
submit their fee payment by January 15 of each year.   The failure to
pay the required fee for a product will result in cancellation of that
product’s registration.  

4(b)(i) Data Items, Including Record Keeping Requirements

Pesticide Product Registration Maintenance Fees

Data Item 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.

Data Item 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.

Data Item 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.

Data Item  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.

Data Item E

Small Business Waiver	A small business seeking the small business cap
and/or a 25% waiver on their first product’s maintenance fee must
submit the necessary information to substantiate their claim.





Pesticide Registration Service Fee Waivers

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. 

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.  

Currently no EPA forms are associated with this information collection
activity.  The Agency will accept information that is submitted in any
format that meets the requirements of the statute.

4(b)(ii) Respondent Activities

Pesticide Product Registration Maintenance Fees

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.

Document small business claim	Provide required information to
substantiate small business cap and/or 25% first product fee reduction
claim

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.

Pesticide Registration Service Fee Waivers

	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 E).  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 

Pesticide Product Registration Maintenance Fees

The following Agency activities are necessary to process 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.

  

Pesticide Registration Service Fee Waivers

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 

Pesticide Product Registration Maintenance Fees

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.

	EPA implemented electronic payment of maintenance fees via   HYPERLINK
"http://www.pay.gov"  http://www.pay.gov 

in the FY08 collection cycle. Currently, more than 60% of maintenance
fee payments are received electronically.

Pesticide Registration Service Fee Waivers

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 

The Agency's filing form for the submission of maintenance fees requires
the minimum amount of information 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.  To qualify business must: 1) provide the
necessary data to demonstrate that the entity qualifies as a small
business, 2) identify products that firms wish to continue to support.  
 In 2012 the fee structure was changed to provide a 25% discount on the
first product supported.  Therefore, qualified small businesses with
five or fewer products receive a benefit from the discount.

Small businesses may also request a waiver of the registration service
fee.  A waiver applicant must demonstrate that it meets the criteria as
outlined in 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 

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.

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 

Pesticide Product Registration Maintenance Fees

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 2013 there were 1,744 firms with
registrations.  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 – 5	1,337	1,337	77%

6 – 10	156	1,493	86%

11 – 20	100	1,593	91%

21 – 50	84	1,677	96%

51 - 100	32	1,709	98%

> 100	35	1,744	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 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 – 5	1.0	1,337	1,337

6 – 10	0.75	156	117

11 – 20	1.0	100	100

21 – 50	2.0	84	168

51 – 100	3.0	32	96

> 100	5.0	35	175

Totals

1,744	1,993

PAPERWORK BURDEN:  1,993 (total hours) / 1744 (number of respondents) =
1.14 hours per response (rounded to two decimals).

Pesticide Registration Service Fee Waivers

In calculating the potential respondent burden, the Agency estimated 307
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 FY2012.  

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 exempt 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 registrants to 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.  Type A applicants have the most burden because 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 FY
2012, EPA estimates that less than 1600 requests for registration
actions will be received per year, of which 307 will request fee waivers
or reductions. Of the 307 responses EPA estimates that 11% (34 out of
307) will be the first-time applicants (Type A), 59% (181 out of 307)
will be the Type B applications, and 30% (92 out of 307) 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 4, 5, 6, and 10.

6(b) Estimating Respondent Costs

Labor Costs

OPP uses labor cost estimates from the BLS (Bureau of Labor Statistics)
with respect to wages, benefits and overhead for all labor categories
for affected industries, state government, and EPA employees.  This
approach provides a transparent and consistent methodology using 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 paperwork cost.  

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 ""     HYPERLINK
"http://www.bls.gov/oes/current/oessrci.htm" 
http://www.bls.gov/oes/current/oessrci.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 44% 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 44% 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.

Attachment F contains worksheets providing the breakout of these costs. 
Costs are based on 2011 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 $124, $61, and
$37 per hour, respectively.  These labor rates are fully loaded and
include benefits and overhead costs.

Pesticide Product Registration Maintenance Fees

The upper part table below describes the average burden and costs for
completing one maintenance fee filing form.  The average total hourly
burden was derived from Table 2 and the allocation of the hours between
collection activities and types of labor was derived from consultation
with a selected group of respondents.  The lower part of the table
estimates the total annual burden and costs for all respondents.

Table 3. Average Respondent Paperwork Burden and Costs

Collection Activities	Burden Hours	Total

	Mgmt	Technical	Clerical	Hours	Costs

	$124.10 	$61.21 	$36.79 



	per hour	per hour	per hour



Read instructions	 	0.3	 	0.3	$18.36 

Plan activities	0.24	 	 	0.24	$29.78 

Review information	0.24	 	 	0.24	$29.78 

Complete Paperwork	 	0.24	 	0.24	$14.69 

File Information	 	 	0.123	0.123	$4.52 

TOTAL	0.48	0.54	0.123	1.143	$97.15 

Annual Costs 	Hours per response	x  Responses per year	=  Hours 

per year	x  Wage 

per hour	=  Costs 

per year

Management:	0.48	1,744	837	$124.10 	$103,888 

Technical:	0.54	1,744	942	$61.21 	$57,643 

Clerical:	0.12	1,744	215	$36.79 	$7,891 

TOTAL	1.14	1,744	1,993	 	$169,422 

Numbers may not calculate exactly because they are displayed as rounded.

Pesticide Registration Fee Waivers

Table 4. Annual Respondent Burden and Cost Estimates (Type A)

Collection Activities

Type A	Burden Hours	Total

	Mgmt	Technical	Clerical	Hours	Costs

	$124.10 	$61.21 	$36.79 



	per hour	per hour	per hour



Read regulation and plan activities	7	0	0	7	$869 

Generate materials for waiver request for submission to EPA	0	24	0	24
$1,469 

Store/maintain/submit and produce information	0	0	6	6	$221 

TOTAL	7	24	6	37	$2,558 

Annual Costs 	Hours per response	x  Responses per year	=  Hours 

per year	x  Wage 

per hour	=  Costs 

per year

Management:	7	34	238	$124.10 	$29,536 

Technical:	24	34	816	$61.21 	$49,946 

Clerical:	6	34	204	$36.79 	$7,504 

            Total	37	34	1,258	 	$86,986 



Table 5. Annual Respondent Burden and Cost Estimates (Type B)

Collection Activities

Type B	Burden Hours	Total

	Mgmt	Technical	Clerical	Hours	Costs

	$124.10 	$61.21 	$36.79 



	per hour	per hour	per hour



Read regulation and plan activities	2	0	0	2	$248 

Generate materials for waiver request for submission to EPA	0	4	0	4	$245


Store/maintain/submit and produce information	0	0	6	6	$221 

TOTAL	2	4	6	12	$714 

Annual Costs 	Hours per response	x  Responses per year	=  Hours 

per year	x  Wage 

per hour	=  Costs 

per year

Management:	2	181	362	$124.10 	$44,925 

Technical:	4	181	724	$61.21 	$44,315 

Clerical:	6	181	1,086	$36.79 	$39,949 

            Total	12	181	2,172	 	$129,188 



Table 6. Annual Respondent Burden and Cost Estimates (Type C)

Collection Activities

Type C	Burden Hours	Total

	Mgmt	Technical	Clerical	Hours	Costs

	$124.10 	$61.21 	$36.79 



	per hour	per hour	per hour



Read regulation and plan activities	2	0	0	2	$248 

Generate materials for waiver request for submission to EPA	0	19	0	19
$1,163 

Store/maintain/submit and produce information	0	0	6	6	$221 

TOTAL	2	19	6	27	$1,632 

Annual Costs 	Hours per response	x  Responses per year	=  Hours 

per year	x  Wage 

per hour	=  Costs 

per year

Management:	2	92	184	$124.10 	$22,835 

Technical:	19	92	1,748	$61.21 	$106,992 

Clerical:	6	92	552	$36.79 	$20,305 

            Total	27	92	2,484	 	$150,132 



6(c) Estimating Agency Burden and Cost

Labor Costs

Agency labor rates are estimated for the relevant technical and clerical
staff using the methodology described in 6(b) above.  Management,
technical and clerical rates are estimated at $120, $78 and $44 per
hour, respectively.  Labor rates are fully loaded and include benefits
and overhead costs. 

Pesticide Product Registration Maintenance Fees

The cost to the Federal Government for this ICR is estimated to be
$90,454.  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 $1,639.  The second component is the per submission costs totaling
$88.815 (see annual number of actions in Table 2). The Agency expends no
management hours in processing maintenance fee submissions.

 Table 7. Agency Burden Hours per Filing Form and Total Cost

Collection Activities	Burden Hours	Total per Activity	Annual Number of
Actions	Total all Activities

	Technical	Clerical	Burden Hours	Cost

Burden Hours	Cost

	$77.85	$44.05







per hour	per hour





	Generate Listings/Mass Mailing	8	16	24	$1,328 	1	24	$1,328 

Pre-load Tracking Data	4	 	4	$311 	1	4	$311 

Receive/Review Submissions	 	0.2	0.2	$9 	1,744	349	$15,364 

Enter Data into Tracking Sys.	 	0.2	0.2	$9 	1,744	349	$15,364 

Reconcile Discrepancies	0.5	 	0.5	$39 	100	50	$3,892 

Respond to Questions	0.5	 	0.5	$39 	300	150	$11,677 

Verify Payment	0.2	 	0.2	$16 	1,744	349	$27,154 

File Documents	 	0.2	0.2	$9 	1,744	349	$15,364 

TOTAL	NA	NA	NA	NA	NA	1623	$90,454 



Pesticide Registration Fee Waivers

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 8 estimates EPA’s
burden for performing these activities.  

Table 8. Annual Agency Burden and Cost Estimates 

Collection Activities	Burden Hours	Total

	Mgmt	Technical	Clerical	Hours	Costs

	$120.32 	$77.85 	$44.05 



	per hour	per hour	per hour



Review submitted waiver request and notify requestor of decision	1	20	2
23	$1,765 

Enter data into tracking systems	0	0	0.5	0.5	$22 

Verify payment	0	0	0.5	0.5	$22 

Store/maintain/submit information	0	0	1	1	$44 

TOTAL	1	20	4	25	$1,854 

Annual Costs 	Hours per response	x  Responses per year	=  Hours 

per year	x  Wage 

per hour	=  Costs 

per year

Management:	1	307	307	$120.32 	$36,938 

Technical:	20	307	6,140	$77.85 	$477,999 

Clerical:	4	307	1,228	$44.05 	$54,090 

            Total	25	307	7,675	 	$569,027 



6(d) Bottom Line Burden Hours and Cost Tables

Table 9. Total Annual Respondent and Agency Burden and Costs for
Pesticide Product Registration Maintenance Fees

	TOTAL ESTIMATES

	Burden Hours	Costs

Respondent Burden	1,993	$169,422 

Agency Burden	1,623	$90,454 



Table 10. Total Annual Burden and Cost Estimates for Pesticide
Registration Fee Waivers

	TOTAL ESTIMATES

	Burden Hours		Costs

                Type A	1,258	$86,986

                Type B	2,172	$129,188

                Type C	2,484	$150,132

Total Applicant -Annual

 (Type A + Type B + Type C)	5,914	366,306

Agency - Annual	7,675	$569,027



Table 11. Combined Respondent Burden for the Pesticide Registration Fees
Program ICR 

PROGRAMS 	TOTAL ESTIMATES

	Burden Hours	Costs

Pesticide Product Registration Maintenance Fee	1,993	$169,422 

Pesticide Registration Fee Waivers 	5,914	$366,306 

Total	7,907	$535,728 



6(e) Reasons for Change in Burden

The total annual burden for respondents associated with pesticide
product registration is 1,993 hours, up from 1,651 hours, previously. 
The reason for the increase was a refinement in the estimate per
response from 0.96 to 1.14 hours and a slight increase in the number of
responses.  Costs also increased since the last renewal because of labor
cost increases.

The total estimated annual respondent burden for the pesticide
registration service fee waivers information collection has increased
slightly from 5,611 hours in the existing ICR, to 5,914 hours for this
renewal due to a slight increase in the number of responses.  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.  In this renewal request, the annual number and
distribution of responses among the three types are based on actual
responses received.  

6(f) Burden Statement

The annual "respondent" (applicant) burden for the Pesticide Product
Registration Maintenance Fee program is estimated to average 1.14 hours
per form, or per respondent, as there is one form per respondent.  The
annual public reporting and recordkeeping burden for the collection of
information for Pesticide Registration Service Fee Waivers is estimated
to average 37, 12, and 27 hours per response, for the three different
types of applications.  Under PRA, “burden” is defined at 5 CFR
1320.3(b).

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 statute and
not a current regulation, the OMB control number for this collection
activity appeared in the Federal Register, and on the collection
instruments. 

The Agency has established a public docket for this ICR under Docket ID
No. EPA-HQ-OPP-2013-0287, which is available for online viewing at
http://  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-2013-0287 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.  Since an OMB Control Number has
not yet been assigned to this ICR, please include docket ID No.
EPA-HQ-OPP-2013-0287 in any correspondence but do not submit any fees or
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 http://  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-2013-0287 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.

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http://www.epa.gov/pesticides/fees/questions/waivers.htm 

Attachment F:	Worksheet for Estimating OPP ICR Wage Rates for Industry,
and EPA Labor is available as a docket attachment EPA-HQ-OPP-2013-0287. 

Attachment G:	Consultations – Stakeholder response to consultation
questions are available as part of the docket EPA-HQ-OPP-2013-0287.  

 

 All table totals have been rounded to the nearest dollar or hour.

October 2013

Page   PAGE  23  of   NUMPAGES  24 

