EPA Questions Asked in Consultation for the 6(a)(2) ICR:

Name:	John Wiegand			, Company:	Canberra Corporation	

Date: 01/30/2014			, e-mail address: johnw@canberracorp.com 

(1)	Publicly Available Data

Is the data that the Agency seeks available from any public source, or
already collected by another office at EPA or by another agency?  NO

If yes, where can you find the data?  (Does your answer indicate a true
duplication, or does the input indicate that certain data elements are
available, but that they don’t meet our data needs very well?)  

(2)	 Frequency of Collection 

Can the Agency collect the information less frequently and still produce
the same outcome?	ONLY THE AGENCY CAN ANSWER THIS

(3)	Clarity of Instructions 

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

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

Do you understand that you are required to maintain records?  YES

Considering that there is no required submission format, is it difficult
to submit information in ways that are clear, logical and easy to
complete? NO – THE VOLUNTARY FORM SUFFICES FOR US.

Regarding the Voluntary Incident Reporting Forms, do you use them?  Are
they clear, logical, and easy to complete?  YES TO BOTH

(4)	Electronic Reporting and Record keeping 

The Government Paperwork Elimination Act requires agencies make
available to the public electronic reporting alternatives to paper-based
submissions by 2003, unless there is a strong reason for not doing so. 
The U.S. E.P.A. Office of Pesticide Programs has a program for
electronic study submissions, and is currently developing plans for
systems to support electronic incident reporting.  The Agency is also
concerned to protect FIFRA CBI as well as personal information.

What do you think about electronic alternatives to paper-based records
and data submissions?  WE APPROVE   Current electronic reporting
alternatives include the use of web forms/XML based submissions via the
Agency’s Internet site and magnetic media-based submissions, e.g.,
diskette, CD-ROM, etc.  Would you be interested in pursuing electronic
reporting?   YES  Are you keeping your records electronically? NOT YET -
WE WOULD USE PDF FILES  If yes, in what format?

Would you be more inclined to submit CBI on diskette, CD, or DVD, or via
web rather than on paper?  VIA WEB - CDX

What benefits would electronic submission bring you in terms of burden
reduction or greater efficiency in compiling the information?  - REDUCED
HOURLY BURDEN FOR FORM CREATION.

Burden and Costs

Are the labor rates accurate?  YES

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

Bearing in mind that the burden and cost estimates include only burden
hours and costs associated with the paperwork involved with this ICR,
e.g., the ICR does not include estimated burden hours and costs for
conducting studies, are the estimated burden hours and labor rates
accurate?  If you provide burden and cost estimates that are
substantially different from EPA’s, please provide an explanation of
how you arrived at your estimates. YES

Are there other costs that should be accounted for that may have been
missed? NO

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