Sample Questions for Consultations on the Renewal of the Pesticide Registration Fee ICR 2013: OMB Control No.: 2070-0179; EPA ICR No.: 2330.3 

Attached is a copy of the sample questions which will be used during the consultation process. Any stakeholder response to consultation questions received will become available as part of the docket EPA-HQ-OPP-2016-0463.  
 
Company Name:  
Name of person consulted:  
Date: 
 
Web Page Information:  

 When preparing your waiver request did you consult the EPA website https://www.epa.gov/pria-fees/pria-fee-waivers-small-businesses#contents?
 
 If yes, did you find it helpful and informative? 

 What improvements or clarifications would you like to see? 

Labor Rates: 
 
 The current labor rates for this ICR proposal are $126.45 for Management; $71.69 for Technical; and $42.97 for Clerical. Keeping in mind the estimates presented are average for the industry.  Would you say these labor rates are accurate?  Many companies no longer use the Clerical wage rate.  Does your company use Clerical labor for the activities associated with this ICR?  
 
 The current labor burden breakdown (the average amount of time each labor category might spend on this task) is displayed in Tables 2, 4, 5, 6 in the supporting statement document. Keeping in mind that estimates presented are average for the industry.  Are these industry averages too high, too low, or just about right for your firm?   
 

Size of your Firm:  
 
 Does your firm hold 5 or fewer pesticide registrations, 6-10 registrations, 11-20 registrations, 21 -50 registrations, or over 50 registrations? If your company is a consultant firm which provides this service for the pesticide industry, can you estimate the size categories of your clientele?  (Sample response," Our consulting firm has approximately 30 clients. 90 % of our clients have less than 20 registrations with EPA the remaining 10 % have over 50 registrations.")      
 
 
Electronic Payments: 

 Since 2015, EPA has collected PRIA and Registration Maintenance fees using electronic payment via www.pay.gov.  Do you have any comments about the use of this system?    



Additional Comments: 

 Do you have any other comments about the burden or costs associated with this ICR activity?  

 
 
 
