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

Name __Chandrika Moudgal___________________, Company_The Clorox
Company_______

Date_____2-21-2014_________________, e-mail address
_chandrika.moudgal@clorox.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? YES

(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, for the most
part. If the Agency is considering an electronic submission system, more
clarity around the timing and ease of electronic submission will be
beneficial. Additionally, if the Agency may consider uploading of
prefilled forms into the electronic system to avoid duplicated work
streams, especially since a lot of the incident data are collected by
Poison Control Centers.

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? To some extent, YES. A clear and logical format will enable
consistent reporting each time which may also benefit the Agency from a
review perspective.

Regarding the Voluntary Incident Reporting Forms, do you use them?  Are
they clear, logical, and easy to complete? Unable to provide a response
since I am not familiar with this voluntary reporting form.

(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?  Current electronic reporting alternatives include
the use of web forms/XML based submissions via the Agency’s Internet
site and magnetic media-based submissions, e.g., diskette, CD-ROM, etc. 
Would you be interested in pursuing electronic reporting?  Are you
keeping your records electronically?  If yes, in what format? Yes,
keeping electronic records in PDF format.

Would you be more inclined to submit CBI on diskette, CD, or DVD, or via
web rather than on paper?  Would prefer a web based submission

What benefits would electronic submission bring you in terms of burden
reduction or greater efficiency in compiling the information? Can
compile the incident data and submit the same per Agency’s requirement
using a single button push using a web based system.

Burden and Costs

Are the labor rates accurate? YES

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

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?  YES;  If you provide burden and cost estimates that are
substantially different from EPA’s, please provide an explanation of
how you arrived at your estimates.

Are there other costs that should be accounted for that may have been
missed? Contractual services costs don’t seem have been accounted for.

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