                          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. 1249.11; Docket ID No. EPA-HQ-OPP-2013-0150

      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 applicators certified to use 1080 livestock protection collars, and reporting agencies that are required to compile and submit annual monitoring reports on use of the collars to EPA. Only three remaining agencies are required to submit annual monitoring reports (termed "reporting agencies" in this ICR): the state lead agencies for pesticide regulation in New Mexico and Wyoming, and the Animal and Plant Health Inspection Service (APHIS) within the US Department of Agriculture (USDA). Although these reporting agencies do not produce 1080 collars, each became a registrant of a 1080 collar product for the purpose of implementing and administering a 1080 collar monitoring program in order to allow possession and use of the collars by certified applicators under their purview. [1]

      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 nontarget wild animals resulting from collar use. Certified applicators in New Mexico and Wyoming, as well as in several states where USDA/APHIS administers the 1080 collar program, keep records of their use of the collars and provide them to their respective reporting agencies, who compile the information and submit it to EPA in their annual monitoring reports.

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 reporting agency 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 the reporting agencies 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), EPA is publishing a Federal Register (FR) Notice soliciting comment on this information collection activity and the agency's intent to renew the OMB approval of this ICR.  The FR Notice and the proposed renewal are located in the docket for this action, which can be accessed at: http://www.regulations.gov using the docket ID number EPA-HQ-OPP-2016-0460.  

      3(c)  Consultations

      During preparation of this ICR renewal, EPA staff will contact respondent representatives to seek feedback on the burden estimates in the ICR and the clarity of guidance provided.  Their responses to EPA's consultation efforts will be summarized and made publicly available with the final ICR renewal request, as Attachment B.
      
	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 certified livestock protection collar applicators and any other persons who own 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

      Entities potentially affected by this ICR are certified pesticide applicators that apply or hold inventory of 1080 collars, and to the reporting agencies (state government, NAICS 999200) responsible for implementing and administering a 1080 collar monitoring program.  Certified applicators subject to this ICR now or in the future are applicators certified to apply 1080 collars in New Mexico and Wyoming, as well as employees of the Animal and Plant Health Inspection Service (APHIS) within the US Department of Agriculture (USDA).  

      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 D). 

      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 of dates, and approximate location of all collars lost.
                   The species, locations, and dates of all suspected poisonings of humans, domestic animals or nontarget 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 applicable reporting agency).  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; 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.

Reporting agencies have developed their own instruments that facilitate appropriate recordkeeping by certified applicators.  Reporting 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 reporting 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 nontarget species poisonings and other incidents included in the annual monitoring reports filed with EPA by reporting agencies are reviewed by the Invertebrate and Vertebrate Branch 3, 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 reporting 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 (3 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
      
      Respondents under this ICR are applicators certified to use 1080 livestock protection collars, and reporting agencies that are required to compile and submit annual monitoring reports to EPA. Only three remaining agencies are required to submit annual monitoring reports (termed "reporting agencies" in this ICR): the state lead agencies for pesticide regulation in New Mexico and Wyoming, and the Animal and Plant Health Inspection Service (APHIS) within the US Department of Agriculture (USDA). Although these reporting agencies do not produce 1080 collars, each became a registrant of a 1080 collar product for the purpose of implementing and administering a 1080 collar monitoring program in order to satisfy requirements initially imposed by an administrative law judge, and thereby allow possession and use of the collars by certified applicators under their purview. Applicable certified applicators are required to keep records of their use of 1080 collars and provide them to their respective reporting agencies, who compile the information and submit it to EPA in their annual monitoring reports. There is only one registrant that produces the 1080 collars. That registrant does not administer a monitoring program or submit monitoring reports, and is not a respondent under this ICR. 

      EPA has reviewed the estimated burden associated with the 1080 livestock protection collar annual monitoring reports over its previous estimates based on the reports most recently submitted to EPA.  Since the last renewal of this ICR, South Dakota has cancelled their registration of 1080 livestock protection collars, thereby ending the program, i.e., the use and monitoring of the product has ceased, as have all reporting and recordkeeping requirements in the state. Wyoming has indicated that currently they have no applicators certified for the use, and no collars in inventory, although they have not yet cancelled their registration. Therefore, for this ICR renewal, there are no certified applicators to incur burden in either South Dakota or Wyoming, but it is assumed that Wyoming will still submit a monitoring report and incur that burden. Therefore, for the next 3 years, EPA estimates that 30 certified applicators (20 for New Mexico, 0 for Wyoming, and 10 for APHIS) will use and/or possess collars annually and, consequently, contribute information to their respective reporting agency, to be used in annual monitoring reports by the agencies. EPA does not expect the burden per applicator, which is currently 40 hours, to decrease or increase over the next 3 years.  Therefore, this figure remains unchanged from our previous 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 1200 hours (30 applicators x 40 hours).

      EPA anticipates that three reporting agencies will file annual monitoring reports based upon information obtained from the certified applicators. The estimated annual burden per respondent for this activity is 77 hours, and has not changed over the 2013 estimates.  The annual burden of the reporting agencies is based on the annual monitoring report alone, and no other requirements related to use, administration, and regulation of 1080 livestock protection collars. There are currently two states (New Mexico and Wyoming) and one federal agency (USDA/APHIS) that are required to submit livestock protection collar monitoring reports annually. EPA estimates the total annual burden for agencies submitting annual monitoring reports to be 231 hours (3 submitters x 77 hours). 

      The Agency recognizes that the time needed to prepare reports is affected primarily by the extent of use and the number of applicators to be covered by the report during any given year.  Tables 1 and 2 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 and reporting agencies associated with the use of 1080 livestock protection collars is estimated to be 1,431 hours (1,200 + 231).
      
      6(b)  Estimating Respondent Costs

      The Agency estimates wages, benefits, and overhead for all labor categories for state government and EPA 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 that are used in this ICR are listed in Attachment E and F.
      
      The state government wage rates for managerial, technical and clerical rates are estimated at $91.23, $62.31, and $42.65 per hour, respectively. These rates are used for reporting agencies responsible for submitting annual monitoring reports. These labor rates are fully loaded to include benefits and overhead costs.  

	Based on EPA's familiarity with the 1080 Livestock Protection Collars program and experiences with reporting agency employees implementing the program, 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 $42.65/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 $64,213.  In summary:
      
      The total annual cost for all respondents, by respondent type:
 Certified applicators:  $51,175
 Reporting agencies:  $13,038
         
      The annual cost for a single respondent:  
 Certified applicator:  $1,706
 Reporting agency:  $4,346
      
      Tables 1 and 2 present estimated annual burden hours and costs per respondent, with total annual burden for all respondents calculated below each table.
      
Table 1. Annual Certified Applicator Burden/Cost Estimates for Recordkeeping
                                       
                                       
                                       
                             Collection Activities
                                       
                                 Burden Hours
                          (per respondent, per year)
                                       
                                    Cost[a]
                                       
                                      1.
                                       
                  Read/hear rule or any collection instrument
                                       3
                                                                        $127.94
                                       
                                      2.
                                       
                             Receive training [b]
                                      --
                                                                             --
                                       
                                      3.
                                       
                                Plan activities
                                       3
                                                                        $127.94
                                       
                                      4.
                                       
                              Create information
                                       3
                                                                        $127.94
                                       
                                      5.
                                       
                              Gather information
                                      18
                                                                        $767.62
                                       
                                      6.
                                       
                  Process and review information for accuracy
                                       5
                                                                        $213.23
                                       
                                      7.
                                       
                 Record, disclose, or display the information
                                       5
                                                                        $213.23
                                       
                                      8.
                                       
                    Store, file or maintain the information
                                       3
                                                                        $127.94
                                       
                                       
                                       
                                     TOTAL
                                      40
                                                                      $1,705.82
(a) Certified Applicator ($42.65/hr)
(b)The burden associated with the training of certified applicators is accounted for under the ICR for Certification of Pesticide Applicators (EPA ICR# 0155; OMB Control No. 2070-0029).

TOTAL ANNUAL BURDEN:  Annual hours per respondent (40) x number of respondents (30) = 1,200
TOTAL ANNUAL COST:  Annual cost per respondent ($1,706) x number of respondents (30) = $51,175



Table 2. Annual Reporting Agency Burden/Cost Estimates for Monitoring Reports
                                       
                                       
                             Collection Activities
                                       
                                 Burden Hours 
                          (per respondent, per year)
                                       
                                       
    Cost
                                       
                                       
                                       
                                       
                                  Management
                                  ($91.23/hr)
                                       
                                     Tech.
                                  ($62.31/hr)
                                       
                                   Clerical
                                  ($42.65/hr)
                                       
                                       
                                       
                                      1.
                                       
                  Read/hear rule or any collection instrument
                                       
                                       0
                                       
                                       2
                                       
                                       0
                                                                       $124.63 
                                       
                                      2.
                                       
                                Plan activities
                                       
                                       0
                                       
                                      10
                                       
                                       0
                                                                       $623.15 
                                       
                                      3.
                                       
                              Create information
                                       
                                       0
                                       
                                      15
                                       
                                       0
                                                                       $934.72 
                                       
                                      4.
                                       
                              Gather information
                                       
                                       0
                                       
                                      14
                                       
                                       0
                                                                       $872.41 
                                       
                                      5.
                                       
   Process, compile, and review information for accuracy and appropriateness
                                       
                                       0
                                       
                                      13
                                       
                                       0
                                                                       $810.09 
                                       
                                      6.
                                       
              Record, disclose, display or report the information
                                       
                                       0
                                       
                                       0
                                       
                                      20
                                                                       $852.91 
                                       
                                      7.
                                       
                    Store, file or maintain the information
                                       
                                       0
                                       
                                       0
                                       
                                       3
                                                                       $127.94 
                                       
                                       
                                       
                                     TOTAL
                                       
                                       0
                                       
                                      54
                                       
                                      23
                                                                     $4,345.84 

TOTAL ANNUAL BURDEN:  Annual hours per respondent (77) x number of respondents (3) = 231
TOTAL ANNUAL COST:  Annual cost per respondent ($4,346) x number of respondents (3) = $13,038

	
6(c)  Estimating EPA Burden and Cost

      The Agency's total annual burden associated with the 1080 livestock program is based on estimates of the resources required to complete tasks specifically associated with annual monitoring reports submitted to EPA.  Each reporting agency (respondent) provides one monitoring report (response) per year.
      
      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 $81.37, and $46.41 per hour, respectively.  These labor rates are fully loaded and include benefits and overhead costs.  For this ICR, we estimate the total annual Agency burden to be 78 hours and the total annual Agency cost to be $6,347.  


Table 3.  Annual EPA Burden/Cost Estimates
                                       
                                       
                             Collection Activities
                                       
                                       
                                       
                                       
                           Burden Hours per Response
                                       
                                  Total Cost
                                       
                                       
                                       
                                       
                                     Tech.
                                  ($81.37/hr)
                                       
                                   Clerical
                                  ($46.41/hr)
                                       
                                       
                                      1.
                                       
                       Develop any correspondence needed
                                       
                                       8
                                       
                                       0
                                                                       $650.96 
                                       
                                      2.
                                       
                        Answer respondents' questions
                                       
                                       2
                                       
                                       0
                                                                       $162.74 
                                       
                                      3.
                                       
                            Review data submissions
                                       
                                      10
                                       
                                       0
                                                                       $813.70 
                                       
                                      4.
                                       
                           Analyze data submissions
                                       
                                       4
                                       
                                       0
                                                                       $325.48 
                                       
                                      5.
                                       
                                  Store data
                                       
                                       2
                                       
                                       0
                                                                       $162.74 
                                       
                                       
                                       
                                     TOTAL
                                       
                                      26
                                       
                                       0
                                                                     $2,115.63 

ANNUAL BURDEN:  	Hours per response (26) x Number of Responses per year (3) = 78 
ANNUAL COST: 		Cost per response ($2,116) x Number of Responses per year (3) = $6,347
      

      6(d)  Bottom Line Burden and Costs
                                       
Table 4.  Annual Bottom Line Burden and Costs/Master Table
                                       
                                       
                                       
                              Total Burden Hours
                                       
                                     Total
                                   Cost ($)

Certified Applicator (Table 1)
                                     1,200
                                                                        $51,175

Reporting Agency (Table 2)
                                      231
                                                                      $13,038  

Bottom Line Respondent Total
                                     1,431
                                                                        $64,213

Agency Total
                                      78
                                                                         $6,347
      
	6(e)  Reasons for Change in Burden

      The total annual respondent burden estimate is reduced from the currently approved ICR due to two adjustments: (1) cancellation of the 1080 Livestock Protection Collar registration formerly held by the South Dakota Department of Agriculture, thus ending their program and all burdens associated with it, and (2) removal of burden associated with submission of annual Livestock Protection Collar production reports, which was erroneously included in the previous renewal of this ICR.
	
	6(f)  Burden Statement

      The annual respondent burden for the 1080 livestock protection collar program is estimated to average 40 hours per certified applicator response and 77 hours per reporting agency response. 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-2016-0460 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 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 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-2016-0460 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 B:           Reserved for Consultation Responses 

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

Attachment D:	EPA's 1995 Re-registration Eligibility Decision Concerning Sodium Fluoroacetate
	
Attachment E:	Methodology for Estimating OPP ICR Wage Rates for Reporting Agencies and Certified Applicators

Attachment F:	Methodology for Estimating EPA Wage Rates
