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

Name __Jason Castroman__________, Company____Sysco Corporation____

Date___2/18/2014_____________, e-mail address
__Castroman.Jason@corp.sysco.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?

Some of them are reported to other agencies and some of them are not. 
For example, an incident report and detailed information would be sent
to the FDA or USDA if a pesticide were to contaminate or cause injury to
human or animal food (the agency would be determined by the specific
food).  Another example would be if there is a complaint of an employee
stating that there are unsafe work conditions, or that there are no MSDS
sheets available for their bleach cleaner.  This COULD be reported to
OSHA.  “Could” is emphasized since this is the source of our
complaints and a number of them do not contact a regulatory action given
that they failed to follow directions on the label, took the product
home, mixed the product with another product, or drank the product.  So
ultimately for uniformity I would say that I do not have a problem in
reporting them to the EPA, I would probably include a note stating the
other agency’s involvement.

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?

I think that minor events can be collected yearly and major events
quarterly.  Possibly rate a class of pesticides as high risk or new
registrants required monthly?  

(3)	Clarity of Instructions 

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

This is clear.

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?

Maybe it is the way I printed the regulations, but then I expected to
see the submission instructions on page 49372 rather than 49390.

Do you understand that you are required to maintain records?  

Not really.  Since the last clause of the last sentence states,
“therefore has eliminated this requirement entirely.”  In addition,
having a beginning sentence that is vague generalizations, “most
types.”  Simply state the requirement if there is one.  A short,
separate note can be added to the bottom of this section explaining how
the record keeping requirements were reached – “series of three”,
etc.; however, in my opinion, it will probably just cause confusion and
would be better placed in guidance material than a Final Rule.

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 – We have a third party provided and we have developed a form.

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

Yes and Yes.

(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?

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

This electronic conversion NEEDS to happen!  Submitting it by web via an
excel or csv attachment would be our preference.

What benefits would electronic submission bring you in terms of burden
reduction or greater efficiency in compiling the information?  

Time savings and Cost savings.  

I no longer have to: 

Find the Report 

Open the Report 

Print the Report.  

Find the Cover Letter 

Open the Cover Letter 

Change Aspects of Template Cover Letter, such as Month, Year, Number of
incidents

Print out a cover Letter

Verify Report for accuracy 

Sign the Cover Letter

Send the Report and Cover Letter First Class letters with priority
tracking. 

Instead, I only have to:

Find the report

Open the Report 

Review Report for Accurancy

Upload Report

Burden and Costs – NA – Third party and different depart handles
costs.

Are the labor rates accurate? 

Sysco only has one item and one individual is responsible for reporting;
however, Sysco pays a third party, PROSAR, that prepares a majority of
the of the reporting for our review.  Sysco pays them Quarterly and
Annually.  This fee ends up being as if the Manager was performing the
entire process.

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

Yes, unless you consider the annual fee for PROSAR as a capital cost.

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.

For our company, only one person is responsible for reviewing the report
and submitting the information and handing the compliant when they do
arrive.  As a result, I would combine the Clerical and the Clerical
together, but then the totals are fairly accurate.

Are there other costs that should be accounted for that may have been
missed?

No

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