                             SUPPORTING STATEMENT
                  FOR AN INFORMATION COLLECTION REQUEST (ICR)

1.	IDENTIFICATION OF THE INFORMATION COLLECTION
            
      1(a).	Title of the Information Collection 
       
      Soil and Non-Soil Fumigant Risk Mitigation
      	OMB Control No.:  2070-0197  	
      	EPA No.:  2451.02
      	Docket ID No.: EPA-HQ-OPP-2018-0423	
      
      1(b).	Short Characterization/Abstract  

      In completing reviews of several soil and non-soil fumigants pursuant to section 4(g) of the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA), the Environmental Protection Agency ("EPA" or "the Agency") determined that these fumigants are eligible for reregistration only if specific risk mitigation measures, as outlined in Reregistration Eligibility Decisions (REDs) for the chemicals, are adopted and adequately implemented. This ICR addresses the paperwork activities that both users and registrants of these specific soil and non-soil fumigants must perform in order to comply with the required risk mitigation measures. 
      
      In May 2008, EPA completed REDs for a group of soil fumigant chemicals after an extensive review and public participation process.  The Agency's decision takes into account the best available information on the potential risks and benefits of soil fumigant use.  EPA published the final decision documents for public comment, and issued final REDs in June 2009. Implemented on a case-by-case basis between 2010 and 2012, these measures work together to establish a baseline for safe use of the soil fumigants throughout the United States (U.S.), reducing fumigant exposures and significantly improving safety.
      
      Pursuant to section 4(g) of FIFRA, EPA reviewed data concerning the risks and benefits of certain soil fumigant chemicals and determined that certain uses of these soil fumigants are eligible for reregistration only if certain additional risk mitigation measures were included as terms and conditions of those products' registrations.  The registrants agreed to amend their registrations to include those terms and conditions.  One of those terms and conditions is that the registrants must develop and implement training for fumigators in charge of fumigations, develop and disseminate safety information for handlers, develop and implement community outreach and education programs, and develop and implement first responder training.  
       
      Another of those terms and conditions is that the registrants must include in the labeling of their soil fumigant products certain additional directions for use.  These directions for use include requirements that users post information concerning soil fumigant applications on signs around the use site, provide notice of fumigant applications to applicable states, prepare a Fumigant Management Plan (FMP) and Post-Application Summary (PAS), participate in an EPA-approved fumigant training program, and disseminate fumigant safe handling information to handlers.  
      
      The required mitigation measures may result in a burden, applicable under the Paperwork Reduction Act (PRA), on those participating in soil fumigant applications, on those enforcing soil fumigant label requirements, and on the registrants of soil fumigant products.  These measures are designed to decrease the likelihood of exposures to these chemicals while maintaining important benefits to U.S. agriculture.  To ensure that risk mitigation measures are adequately implemented, the respondents identified below must complete the following activities:
      
 Users:  Users of soil fumigants include both certified applicators and pesticide handlers.  Applicators must understand the requirements, complete application information on posting signs, provide notice of fumigant applications to applicable states, prepare FMP and PAS, participate in an EPA-approved fumigant training program, and disseminate fumigant safe handling information to handlers.  Handlers may help in the posting of buffer zone signs, and must also complete a fumigant training program. 
 Registrants: Registrants of soil fumigant products must develop and implement training for fumigators in charge of fumigations, develop and disseminate safety information for handlers, develop and implement community outreach and education programs, and develop and implement first responder training.
 States: States are involved in the enforcement of soil fumigant label requirements, and would receive notification of fumigations in their state if they have selected this option.
      In addition to the requirements for soil fumigants, the Agency has adopted similar risk mitigation measures and labeling requirements over the past several years for five non-soil fumigant chemicals. These measures are required to be collected pursuant to their re-registration decisions. To ensure that the risk mitigation measures are adequately implemented, the respondents identified below must complete the following activities:
   
 Users: Users of certain non-soil fumigants must prepare a FMP for each application. Specific non-soil fumigant users must also participate in an EPA-approved fumigant stewardship training program. 
 Registrants: Registrants of certain non-soil fumigants must develop an EPA-approved fumigant stewardship training program for users to complete. 
      Without the complete suite of measures, these soil and non-soil fumigant chemicals do not meet the requirements to be eligible for registration or reregistration under FIFRA.  The programs and activities represented in this ICR are the result of the Agency exercising the authority of section 3(c)(2)(B) (Attachment A) or section 3(c)(5) (Attachment B) of FIFRA, which authorizes EPA to require pesticide registrants to generate and submit data to the Agency, when such data are needed to maintain an existing registration of a pesticide.  Due to the high benefits of these chemicals, there could be significant economic impact if these fumigant products are no longer available.  

2.  NEED FOR AND USE OF THE COLLECTION

      2(a).	Need/Authority for the Collection
      
      In general, authorizing legislation is contained in Section 3 of FIFRA, with implementing regulations in 40 CFR parts 152 (registration standards and general requirements), 156 (labeling), 158 (data requirements) and part 171 (certified applicators of restricted use products). Application of the requirements applied to the registration of soil and non-soil fumigants is discussed in EPA's Fumigant Reregistration Eligibility Decisions and Supporting Documents, which can be accessed using the docket numbers provided in Attachment C. See also the EPA website dedicated to soil fumigants (http://www.epa.gov/soil-fumigants) and the webpage dedicated to the regulatory status of fumigants in general (https://www.epa.gov/soil-fumigants/regulatory-status-fumigants).
      
Overview of Mandates Applicable to Registered Pesticides
      
      Sections 3(a) and 12(a)(1) of FIFRA require a person to register a pesticide product with the EPA before the pesticide product may be lawfully sold or distributed in the U.S.  A pesticide registration is a license that allows a pesticide product to be sold and distributed for specific uses under specified terms and conditions such as use instructions and precautions.  The proponent of initial or continued registration always bears the burden of demonstrating that a pesticide product meets the statutory standard for registration.  A pesticide product may be registered or remain registered only if it meets the statutory standard for registration given in section 3(c)(5) of FIFRA, which is as follows:

       Its composition is such as to warrant the proposed claims for it.
       Its labeling and other material required to be submitted comply with the requirements of this Act.
       It will perform its intended function without unreasonable adverse effects on the environment.
       When used in accordance with widespread and commonly recognized practice it will not generally cause unreasonable adverse effects on the environment.
 
      Section 2(bb) of FIFRA defines "unreasonable adverse effects on the environment'' as (1) "any unreasonable risk to man or the environment, taking into account the economic, social, and environmental costs and benefits of the use of any pesticide, or (2) a human dietary risk from residues that result from a use of a pesticide in or on any food inconsistent with the standard under section 408 of the Federal Food Drug and Cosmetic Act.''

       Section 4 of FIFRA requires EPA to reassess the health and safety data for all pesticide active ingredients registered before November 1, 1984, to determine whether these "older" pesticides meet the criteria for registration that would be expected of a pesticide being registered today for the first time.  Section 4 directs EPA to use section 3(c)(2)(B) authority to obtain the required data.  Section 4(g)(2)(A) of FIFRA calls for EPA to determine, after submission of relevant data concerning an active ingredient, whether pesticides containing the active ingredient are eligible for reregistration.  
       
      Failure of a registrant to comply with the terms and conditions of registration would lead to cancellation of its fumigant products pursuant to FIFRA section 6(b) for failure to meet the section 3(c)(5) criteria for registration. Users must comply with pesticide labeling or face civil and criminal penalties pursuant to FIFRA sections 12(a)(2)(G) and 14, and certified applicators may also be sanctioned by suspension or revocation of certification (40 CFR 171.7(b)(iii)(A)).
      
Overview of Mandates Specific to Soil Fumigants
 
       In completing its review of several soil fumigants pursuant to FIFRA section 4(g), EPA determined that certain uses of these soil fumigants are eligible for reregistration only if specific risk mitigation measures as outlined in the REDs are adopted and implemented by the registrants. 
       
       EPA completed the REDs for a group of soil fumigant chemicals in 2009, after an extensive review and public participation process.  The Agency's decision takes into account the best available information on the potential risks and benefits of soil fumigant use.   EPA considered these soil fumigants as a group in order to ensure that similar risk assessment tools and methods were used for all soil fumigants and that risk management approaches were consistent.  The chemicals included in the 2009 review are metam sodium/potassium, dazomet, chloropicrin, and methyl bromide.  The Agency had also completed a RED for another soil fumigant in 1998, 1,3-dichloropropene (Telone (R)), and registered the soil fumigant dimethyl disulfide (DMDS) in 2010.
       
       Documents to support the reregistration or registration actions for this group of chemicals can be found in the public docket at www.regulations.gov under the docket numbers provided in Attachment C.

      As described in the REDs, these soil fumigants are eligible for reregistration if certain risk mitigation measures are adopted.   This ICR accounts for the risk mitigation activities outlined in the REDs that are applicable under the PRA as information collection activities (as listed in section 4 of this ICR), and estimates the respondent burden and costs for these activities (estimates are presented in section 6 of this ICR).
      
Overview of Mandates Specific to Non-Soil Fumigants

	The Agency reviewed has reviewed five non-soil fumigants separately and completed updates for reregistation labels after an extensive review and public participation process.
	
      In 2009, the EPA expanded restrictions on aluminum and magnesium phosphide products to reduce potential exposure to phosphine fumigants. These restrictions included the requirement of developing FMPs for applications. The updated labels for products containing these active ingredients were approved by EPA in 2010. Documents regarding the requirement of FMPs on these labels are included in the public docket located at regulations.gov using Docket ID No. EPA-HQ-OPP-2013-0081.
      
      In 2008, the EPA completed a RED for methyl bromide, which in turn was amended in 2009. Since the completion of the RED, the FMP section has been updated to include statements similar to those on other commodity and structural fumigant product labels. Updated labels for Tolerance Reassessment Eligibility Decision (TRED)/RED requirements for non-soil fumigant applications were approved in 2015. Additional information and documents regarding the reregistration of methyl bromide are available in the public docket located at regualtions.gov using Docket ID No.EPA-HQ-OPP-2013-0269. 
	
	In 2016, the EPA Office of Inspector General released a report on sulfuryl fluoride and made recommendations to control risks associated with residential fumigations to reduce the risk of injury or death (Attachment D). Among the recommendations, the OIG requested that EPA implement labeling changes for all three brands of sulfuryl fluoride that would require the development of FMPs for sulfuryl fluoride applications and to define the criteria for meeting an applicator stewardship training requirement. In 2017, EPA approved updated labels for sulfuryl fluoride products incorporating these recommendations. The Agency is also actively working with the sulfuryl fluoride registrants involved in the development and implementation of stewardship training programs and materials recommended in the report.  Information about EPA's registration review of sulfuryl fluoride is available at regulations.gov using Docket ID No.EPA-HQ-OPP-2009-0136. 
	
      2(b).	Practical Utility/Uses of the Data

	The information collection activities covered by this ICR will provide the risk mitigation measures identified by the EPA's Office of Pesticide Programs (OPP) in the Office of Chemical Safety and Pollution Prevention (OCSPP) as necessary for certain soil and non-soil fumigant chemicals to be eligible for reregistration under FIFRA. Without these measures, EPA may determine that products containing these chemicals do not meet the standard for registration under FIFRA section 3(c)(5). Due to the high benefits of these chemicals, there could be significant economic impact if soil or non-soil fumigant products are no longer available.

Background on Soil Fumigants

      Soil fumigants are restricted use pesticides (RUPs) that, when applied to soil, form a gas to control pests that live in the soil and can disrupt plant growth and crop production.  The fumigants are either volatile chemicals that become gases at relatively low temperatures, around 40 degrees Fahrenheit, or they are chemicals that react to produce such a gas (e.g., dazomet and metam sodium converting to methyl isothiocyanate, or MITC).  Soil fumigants are used on many high value crops, including vegetables, fruits, nuts, forest seedlings, ornamentals, and nursery crops, to control a wide range of pests including nematodes, fungi, bacteria, insects, and weeds.  Benefits analyses have indicated that fumigant use is important in a variety of crops.  If these fumigants could not be used, there would likely be significant negative economic impacts.  (These analyses are included in the Fumigant Reregistration Eligibility Decisions and Supporting Documents, which can be accessed using the docket numbers provided in Attachment C.)

      Because of the broad range of pests controlled, soil fumigants are used as part of the production of a wide variety of crops and provide high benefits for many growers. As gases, however, fumigants move from the soil to the air at the application site and may pose risks to handlers, re-entry workers, and bystanders as delineated in the Fumigant Reregistration Eligibility Decisions and Supporting Documents, including sensory irritation (stinging in eyes, nose, throat), nausea, vomiting, dizziness, headache, weakness, and collapse, and at the extreme, death. To reduce these exposures and address risks of concern, the Agency required a number of mitigation measures designed to work together to address all risks, but focus on the acute human inhalation risks that have been identified in the revised risk assessments for these fumigants. Since the exposure pathway of concern is inhalation, the population of concern is anyone who might be exposed through this pathway, which includes applicators and handlers involved in the fumigant application, and bystanders (anyone nearby the treated field).
      
	The Agency required a number of mitigation measures (as described in Section 4 of this document) that may result in a burden to those participating in soil fumigant applications, to those enforcing soil fumigant label requirements, and to those who register soil fumigant products.  These measures were designed to decrease the likelihood of exposures for the population of concern to these chemicals while maintaining their benefits to U.S. agriculture.  For example, measures such as FMPs are designed to reduce workplace injuries and accidents by prescribing a series of operational requirements and criteria.  Also, training is required to ensure applicators across the country receive the same basic level of information prior to making an application.  Although there are some areas of the country where training is currently available from states or registrants, there is currently no consistent training standard across states and regions where soil fumigation is conducted.  For the most part, people living and working near areas where fumigation is taking place do not have much knowledge about these types of applications.  In several incidents, even emergency first responders who have responded to incidents involving soil fumigants do not understand the unique chemical properties of these chemicals and have in some cases increased the exposure of bystanders to these chemicals following an incident.  

      In general, more information on the soil fumigants, including links to all of the public comments received during the reregistration process for this group of chemicals, can be found at http://www.epa.gov/soil-fumigants.
      
Background on Non-Soil Fumigants
      
      The non-soil fumigants are also volatile chemicals that become gases at relatively low temperatures, or they are chemicals that react to produce such a gas (e.g., aluminum and mangesium phosphide converting to phosphine).  All of the non-soil fumigants subject to the information collection activities of this ICR are classified as RUPs. 
      
      Specific uses of non-soil fumigants are of particular concern for a range of pest controls. Use patterns for non-soil fumigants include space fumigation for homes, railcars, mills, etc, as well as commodity fumigations on nuts, cocoa, and some fruits and vegetables. For the non-soil fumigants subject to this ICR, sulfuryl fluoride has very high benefits for its use as a termite control fumigant. Aluminum phosphide and magnesium phosphide can be used for burrowing rodent control. Methyl bromide has been used by United States Department of Agriculture's (USDA) Animal and Plant Health Inspection Service (APHIS) to treat quarantined commodities for export. 
      
      At present, EPA is only accounting for the existing information collection burdens associated with sulfuryl fluoride (labeling requirements for FMPs and stewardship training), aluminum phosphide, magnesium phosphide, and phosphine (labeling requirements for FMPs), and methyl bromide (labeling requirements for FMPs). For more information about the non-soil fumigants subject to these requirements and the registration review process for each, their respective docket identification numbers are provided online at https://www.epa.gov/soil-fumigants/regulatory-status-fumigants and in Attachment C. 

 NON-DUPLICATION, CONSULTATIONS, AND OTHER COLLECTION CRITERIA

		3(a). 	Non-duplication

      Respondents will not be asked to collect or provide information that has been or is currently being collected by EPA, other federal or state agencies or proprietary sources, or is available elsewhere.  The information collected is unique and is not duplicative of previous information collection requests. 
      
      3(b).	Public Notice
      
      As part of the renewal process, EPA will publish a notice in the Federal Register prior to submitting the ICR to OMB. Pursuant to 5 CFR 1320.8(d), any public comments received will be placed in the EPA docket, EPA-HQ-OPP-2018-0423, for this action. 	
      
      3(c).	Consultation Required Prior to ICR Submission to OMB

      As required under 5 CFR 1320.8(d)(1), the Agency will consult with stakeholders who actively interact with the Agency through the use of this collection instrument and will solicit stakeholder assessment of the regulatory burden estimates expressed by the Agency in this ICR. A record of the consultations will be placed in the EPA docket for this action.
      
      
      3(d).	Effects of Less Frequent Collection

      The Agency is not requiring regular reporting on the status of these tasks back to the Agency which will significantly reduce the burden on the respondents. Information is reported only when needed, and cannot be collected less frequently and still maintain necessary risk mitigation.  For example, certified applicators must only give FMPs to state enforcement officials when requested.

	3(e).	General Guidelines

      The information collection activities discussed in this ICR comply with all regulatory guidelines under 5 CFR 1320.5(d)(2).  Respondents are required to retain records, but respondents will not be required to retain records for more than 2 years. 
      
      3(f).	Confidentiality

      None of the information collected by EPA under this ICR comprises confidential business information. 
      3(g)	Sensitive Questions
      
      The information collection activities discussed in this document do not involve any sensitive questions. 


4.	THE RESPONDENTS AND THE INFORMATION REQUESTED

      4(a).	Respondents/NAICS Codes

      Respondents affected by the collection activities under this ICR are soil and non-soil fumigant users, specifically certified applicators and agriculture pesticide handlers (NAICS 111000  -  Agriculture, Forestry, Fishing and Hunting); soil and non-soil fumigant registrants (NAICS 325300 - Pesticide, Fertilizer, and Other Agricultural Chemical Manufacturing); and state and tribal lead agencies (NAICS 999200  -  State Government). 

      Soil and non-soil fumigant users subject to the ICR are considered "applicators" and "handlers."  Fumigants are only allowed to be applied by, or under direct supervision of, specially trained and certified applicators.  Certification programs are conducted by states, territories, and tribes in accordance with national standards.  Fumigant handlers are identified as workers working in a fumigant application block or buffer zone that performs certain kinds of tasks as specified on fumigant labels.  

      Users of soil fumigants containing the active ingredients are listed in Table 1, and non-soil fumigants are listed in Table 2. Both are subject to the collection activities specified in this ICR.

Table 1:  Soil Fumigant Active Ingredients Subject to this ICR
                               Active Ingredient
                         Pesticide Chemical (PC) Code
1, 3-dichloropropene
                                    029001
Chloropicrin
                                    081501
Dazomet
                                    035602
DMDS
                                    000011
Metam potassium
                                    039002
Metam sodium
                                    039003
Methyl bromide
                                    053201
Methyl isothiocyanate
                                    068103

Table 2:  Non- Soil Fumigant Active Ingredients Subject to this ICR
                               Active Ingredient
                         Pesticide Chemical (PC) Code
Aluminum Phosphide
                                    066501
Magnesium Phosphide
                                    066504
Methyl bromide
                                    053201
Phosphine
                                    066500
Sulfuryl Fluoride 
                                    078003


      4(b).	 Information Collected
      
      In order to be eligible for continued registration under FIFRA section 4(g), EPA determined that certain additional risk mitigation measures were necessary as terms and conditions of those registrations.  The registrants agreed, and have amended their registrations to address the specific terms and conditions that are now being applied to all soil fumigant registrations. Information about EPA's soil fumigant program is available at http://www.epa.gov/soil-fumigants. The activities are grouped according to the applicable respondent group.
      
      Users of soil and non-soil fumigants will need to engage in the activities identified in Table 3 and 4, respectively, to assure compliance with fumigant label requirements. Note that compliance with the label-required training is a condition of product use. Because these soil and non-soil fumigants are RUPs, only certified applicators or handlers under their supervision may purchase or use them. Users must comply with pesticide labeling or face civil and criminal penalties pursuant to FIFRA sections 12(a)(2)(G) and 14, and certified applicators may also be sanctioned by suspension or revocation of certification (40 CFR 171.7(b)(iii)(A)).

Table 3: User (applicators and/or handlers) Activities for Soil Fumigants
                                     Burden
                                  Description
Understand the requirements

(applicator's responsibility)
Learn/refresh understanding of fumigant requirements applicable to users that are provided on the fumigant product labels, and additional information on these requirements available at http://www.epa.gov/soil-fumigants/what-are-soil-fumigants.  

Posting 

(applicator or handler's responsibility)
As specified on the product label, obtain signs from product dealers (provided to dealers by registrants); fill in (1) product name, and (2) contact information for the fumigator; place signs at usual points of entry and along likely routes of approach unless a physical barrier (fence, wall) prevents access to the buffer; remove signs after buffer zone time period has ended.

Information on buffer zone posting can be found at http://www.epa.gov/soil-fumigants/buffer-zone-fact-sheets. 

Notify State Lead Agencies (SLAs)

(applicator's responsibility)
Applicators must check the EPA fumigant website for a list of states that require notification. If applicable, provide the following to the SLA:  contact information for the fumigator and owner/operator; location of the field to be treated; product name and registration number; and when the fumigation is expected to occur.

Information on notification to SLAs can be found at http://www.epa.gov/soil-fumigants/complying-required-state-and-tribal-notification-soil-fumigation

Fumigant Management Plan (FMP) and a post-application summary (PAS) 

(applicator's responsibility)
As specified on the product label, prepare a written FMP for each fumigation to include the following:  information on the site, fumigator, and owner/operator; fumigation procedures; buffer determinations; information on worker protection; procedures for air monitoring, posting, communication among key parties; and record keeping; emergency response plans and procedures for addressing accidental fumigant releases.  

Results of air monitoring for handlers, air monitoring results between buffers and bystanders, as well as any deviations from the FMP must be recorded in a PAS. 

Both documents must be filed and retained by both the certified applicator and the property owner for at least 2 years, and available to disclose to enforcement personnel or handlers participating in the application if requested.  

Information on FMPs can be found at http://www.epa.gov/soil-fumigants/introduction-soil-fumigant-management-plan

Applicator Training

(applicator's responsibility)
Applicators must attend a soil fumigant training program designed by the registrant and approved by EPA to specifically cover the following topics:
how to correctly apply the fumigant, how to protect handlers and bystanders, how to determine buffer zone distances, how to develop an FMP and post-fumigation summary report, how to determine when unfavorable conditions exist, and how to comply with the required GAPs.  

The applicators participation in the training must be documented in the FMP.  

Information on applicator training can be found at http://www.epa.gov/soil-fumigants/soil-fumigant-training-certified-applicator

Disclosure to Handlers 

(applicator and handler's responsibilities)
Applicators are responsible for disseminating fumigant specific information prior to each fumigation to every handler participating in the application.  

Information on handler information can be found at 
http://www.epa.gov/soil-fumigants/safety-information-fumigant-handler


Table 4: User (applicators and/or handlers) Activities for Non-Soil Fumigants
                                    Burden
                                  Description
Fumigant Management Plan (FMP) 

(applicator's responsibility)

Required only for the following commodity fumigants: 
    sulfuryl fluoride,
    methyl bromide,
    phosphine, aluminum phosphide, and magnesium phosphide
As specified on the product label, prepare a written FMP for each fumigation to include the following as specified on individual product labels:  information on the site, fumigator, and owner/operator; fumigation procedures; buffer determinations; information on worker protection; procedures for air monitoring, posting, communication among key parties; and record keeping; emergency response plans and procedures for addressing accidental fumigant releases.  

FMPs must be filed and retained by both the certified applicator and the property owner, and available to disclose to enforcement personnel or handlers participating in the application if requested.  

Stewardship Training

(applicator's responsibility)

Required only for
    sulfuryl fluoride structural fumigations
Applicators must attend a fumigant stewardship training program designed by the registrant and approved by EPA. 

      Registrants of soil and non-soil fumigants will need to engage in the activities identified in Table 5 and 6 in order for their product to remain eligible for registration under FIFRA section 3.  Failure of a registrant to comply with the terms and conditions of registration would lead to cancellation of its soil fumigant products pursuant to FIFRA section 6(b) for failure to meet the section 3(c)(5) standard for registration. 
      
      Please note that EPA has included certain aspects of these requirements in the Data Call-In (DCI) notices that are being sent to the fumigant registrants.  The DCI is requiring registrants to submit proposals on how they are planning to address each of the reregistration requirements listed below.  The registrant's burden covered in the DCI ICR (OMB Control No. 2070-0174) has not been duplicated here.  The burden and activities listed below deal with development and implementation of requirements and therefore fall outside of the scope of the DCI ICR.




Table 5:  Registrant Activities for Soil Fumigants
                                    Burden
                                  Description
Training:
Develop/update and implement training for fumigators in charge of fumigations

Prepare training materials, develop channels for training fumigators, and design and implement mechanisms for tracking fumigators who successfully complete training.
Update training materials periodically.
Disseminate training materials (either electronically, by paper, or in person).
This may be done by registrants individually, or collaboratively through a soil fumigant registrant task force or group.

As discussed in Table 2, information on applicator training, including already approved courses that are available, can be found at
http://www.epa.gov/soil-fumigants/soil-fumigant-training-certified-applicator
 
Handler Information:
Develop/update and disseminate safety information for handlers
Prepare safety training materials for handlers and make them available to fumigators to provide to fumigant handlers under their supervision.
Update safety information periodically.
Disseminate training materials (either electronically or by paper)

As discussed in table 2, information on handler information can be found at http://www.epa.gov/soil-fumigants/safety-information-fumigant-handler.

Community Outreach:
Develop/update and implement community outreach and education programs
Design and implement outreach programs to provide communities with information about soil fumigants, buffer zones, early signs of exposure, and what to do in case of an exposure, emergency, or incident; Update community outreach program periodically.

Information on community outreach can be found at http://www.epa.gov/soil-fumigants/community-outreach-and-education-soil-fumigant

First Responder Training:
Develop/update and implement first responder training
Identify communities in which fumigants are used which do not already have information or training on appropriate response to soil fumigant incidents, and develop and incorporate training for first responders into existing programs; Update first responder training periodically.  

Information on first responder training can be found at http://www.epa.gov/soil-fumigants/community-outreach-and-education-soil-fumigant




Table 6:  Registrant Activities for Non-Soil Fumigants
                                    Burden
                                  Description
Stewardship Training:
Develop/update and implement stewardship training for fumigators in charge of fumigations

Applies only to registrants of:
    sulfuryl fluoride structural products. 
Prepare training materials, develop channels for training fumigators, and design and implement mechanisms for tracking fumigators who successfully complete training.

All registrants much have a documented stewardship program and provide initial and recurrent AI-specific training for fumigators as a condition of sale. The training curriculum and content must be developed by each registrant and must have a tracking system to verify condition of sale. 
 

	

      State Lead Agencies (SLAs) may engage in the activities identified in Table 7. Although not required, pesticide SLAs may also provide applicators EPA-approved alternatives to registrant-sponsored training.

Table 7: State Activities for Soil Fumigants Only
                                    Burden
                                  Description
Receive Notice to States
State Lead Agencies (SLAs) have the option to receive notice prior to soil fumigant applications.  

As discussed in table 2, information on notification to SLAs can be found at http://www.epa.gov/soil-fumigants/complying-required-state-and-tribal-notification-soil-fumigations  


5.	THE INFORMATION COLLECTED  -  AGENCY ACTIVITIES, COLLECTION METHODOLOGY, AND INFORMATION MANAGEMENT

      5(a).	Agency Activities

      This ICR primarily involves activities conducted for the purpose of submitting or providing information to third parties. EPA, however, does receive and review training and safety information materials developed or updated by registrants prior to their distribution to third parties. EPA implements the fumigant mitigation measures as part of the reregistration program.

Table 8: Agency Activities
                                    Burden
                                  Description
EPA Review, Coordination, and Implementation Responsibilities
EPA has the responsibility to implement the fumigant mitigation measures, review and approve training and safety materials that are submitted, and coordinate reviews among experienced professionals.  

      
      
      
      5(b).	Collection Methodology and Management

      This ICR primarily involves activities conducted for the purpose of submitting or providing information to third parties. For the information that EPA may collect in the future under this ICR (i.e., training and safety information materials), registrants will submit the materials as needed and EPA will track, review and approve any new or updated materials consistent with current Agency processes and procedures for the submission of pesticide information to the Agency.
       
      5(c).	Small Entity Flexibility 

      The reregistration eligibility of the soil and non-soil fumigants depends upon applicators receiving the various information and training required in the fumigant labels. These cannot be reduced for small establishments without seriously compromising the protections offered to applicators and bystanders.  As such, small entities are required to follow the same requirements as larger establishments.  

      5(d).	Collection Schedule

      This ICR primarily involves activities conducted for the purpose of submitting or providing information to third parties.  For registrants who must submit training and safety information materials to the Agency for review, there is no set collection schedule as registrants submit materials only when developed or updated.  EPA periodically checks the fumigant risk mitigation measures as a part of the registration review program. 
      
      
6. 	ESTIMATING THE BURDEN AND COST OF THE COLLECTION

	6(a).	Methodology for Estimating Respondent Labor Cost

	Respondent cost is based on the burden as described above and summarized below, and wages, benefits and overhead for all labor categories for affected industries, state government, and EPA employees.  This approach uses a transparent and consistent methodology and current publicly-available data to provide more accurate estimates and allow easy replication of the estimates of wages, benefits and overhead.

	Methodology:	The methodology uses data on each sector and labor type for an unloaded wage rate (hourly wage rate), and calculates the loaded wage rate (unloaded wage rate + benefits), and the fully loaded wage rate (loaded wage rate + overhead).  Costs are indexed to 2017 dollars. 

	Wage Rates:  Wages are estimated for occupations (management, technical, and clerical) within applicable sectors.  The Agency uses average unloaded wage data for the relevant sectors available in the National Industry-Specific Occupational Employment and Wage Estimates from the Bureau of Labor Statistics (BLS) at http://www.bls.gov/oes/current/oes_nat.htm.  For loaded wage rates, benefits represent 46.5% of unloaded wage rates, based on benefits for all civilian non-farm workers, from http://www.bls.gov/news.release/ecec.t01.htm.  Fully loaded wage rates include an additional 50% on top of the loaded wage rate to capture overhead costs (EPA guidelines 20-70%).  The data and calculations for wage rates used in this document are presented in Attachment F.

	Sectors: The specific North American Industry Classification System (NAICS) code and website for each sector is included in that sector's wage rate table.  Within each sector, the wage data are provided by Standard Occupational Classification (SOC).  The SOC system is used by Federal statistical agencies to classify workers into occupational categories for the purpose of collecting, calculating, or disseminating data (see http://www.bls.gov/oes/current/oes_stru.htm ).  
	
	There are three categories of respondents: certified applicators and handlers, registrants and states.  The cost associated with each is described in this section.
      
      
      6(b). Estimating Soil Fumigant Respondent Burden 
            
      The burden associated with this collection of information is described in detail in the following sections.  The respondents include certified applicators, pesticide handlers, fumigant registrants and states.  To estimate the respondent burden, the Agency used current information and statistics from a variety of sources as explained in this chapter, on the number of fumigant applications made annually, the number of certified applicators and pesticide handlers that apply or handle fumigants, and the number of fumigant registrants.  This information comes from a variety of sources including state reports, previous EPA analyses, and other EPA databases.  
      
      Certified applicators and pesticide handlers have paperwork burden associated with fumigant application activities, such as understanding the requirements, posting treatment areas and developing a FMP.  For pesticide handlers, burden is estimated per application, where an application is the delivery of a pesticide to a field or application block. It is estimated that the burden associated with the first application after the labels have been updated with the new mitigation measures will be highest, mostly due to the time necessary to develop the FMP (12 hours).  Each of the other paperwork related activities is estimated to take no more than an hour.  Total burden for the first application following the changes to the label is estimated to be nearly 15 hours, while each subsequent application using the updated labels is estimated to take less than 4 hours.  The Agency estimates 12,651 soil fumigant applications are made in the U.S. each year.  

      Requirements currently exist to ensure that certified applicators and agricultural handlers possess general pesticide use and safety information.  Applicators must be determined to be competent to become certified, and to maintain their certification they must either receive training or be recertified by exam on a schedule determined by the state (Certification of Pesticide Applicators, 40 CFR 171).  That schedule ranges, depending on the state, from 1 to 5 years.  Under the agricultural Worker Protection Standard (40 CFR 170), agricultural handlers are required to receive general pesticide safety training at least once every 5 years.  Burdens from those requirements are included in currently-approved ICRs for those two rules (Certification of Pesticide Applicators (OMB Control No. 2070-0029) and Worker Protection Standard Training and Notification (OMB Control No. 2070-0148)), and are not included here.
      
      The soil fumigant label revisions establish training requirements specific to soil fumigation for certified applicators and handlers on the safe and appropriate use of these products. Soil fumigant applicators are required by the product labels approved in accordance with 3(c)(5) to receive this fumigant-specific training every 3 years; handlers involved in soil fumigant application must be provided with the specific safe handling information annually in accordance with fumigant product labels approved under EPA's authority under 3(c)(5).  Burdens from these fumigant-specific requirements are included in this ICR and are separate and distinct from the requirements cited above under the Certification of Pesticide Applicators ICR (OMB Control No. 2070-0029) and the agricultural Worker Protection Standard ICR (OMB Control No. 2070-0148). There are an estimated 4,884 certified applicators applying soil fumigants and 14,652 pesticide handlers of soil fumigants subject to these training requirements as specified by product labels approved in accordance with 3(c)(5). This is based on an estimate of three pesticide handlers per one certified applicator. 
      
      Registrant burden is associated with the development and dissemination of fumigant application, handler safety and first responder training materials.  They must also develop and implement a community outreach program.  The majority of the burden associated with these activities is in the one-time development of the materials. The one-time material development costs were included in the previous ICR. The annual or "on-going" costs are the ones included in this ICR. The annual dissemination of fumigant training and handler safety materials is estimated to take 22 hours per registrant for each activity, while the implementation of the community outreach program is estimated to take 120 hours per registrant annually, and the dissemination of first responder training is estimated to take 120 hours per registrant annually. Registrants have the option of forming task forces if it is in their interest, and may provide data submissions through this collective group. There are currently six task forces that were established by the registrants, at the discretion of the registrants, prior to the activities associated with the label mitigation measures identified in this data collection request.  These same task forces are responsible for disseminating the required materials.
      
      States are responsible for enforcement and compliance of the fumigant application-related requirements.  It is estimated that states will spend an average of 15 minutes per application on enforcement and compliance activities.  Given the EPA's estimate of 12,651 fumigant applications made per year, state activities amount to more than 3,000 hours per year.  Estimates and methodology are addressed in Tables 15 and 16.

      The detailed burden estimates and calculations are presented below for each respondent group, along with costs. The burden for certified applicators and pesticide handlers is shown in Tables 9, 10, 11, and 12; burden for registrants of soil fumigant products in Tables 13 and 14; and burden for states in Tables 15 and 16.

 Certified Applicators and Pesticide Handlers 
      The estimated costs of paperwork activities for certified applicators and pesticide handlers are shown in Tables 9, 10, 11, and 12, along with burden.  Tables 9 and 10 list the estimated costs associated with paperwork for user application activities, while Tables 11 and 12 list the costs associated with training activities. Wage rates are based on NAICS code 111000 - Agriculture, Fishing, Forestry and Hunting.  They are loaded to account for some benefits paid by the employer, but do not account for overhead.  The loaded wage rate for certified applicators ($37.31) is based on the scientist/technician labor category, while the pesticide handler wage is based on an average of the loaded wage rate for the scientist/technician and agriculture worker labor categories (($37.31 + $17.40)/2) = $27.35, reflecting a higher skilled worker (see Attachment F).
	
		(1a) User Application Activities for Soil Fumigant Applications
      Table 9 summarizes the burden and cost for paperwork activities per soil fumigant application for certified applicators and pesticide handlers.  Table 10 summarizes the burden and cost per year.  The annual burden and cost is based on the number of applications made per year.  EPA estimates 12,651 applications are made per year by certified applicators and pesticide handlers based on historical pesticide usage data for the soil fumigants.  

      In addition to the hourly burden and cost of compliance with the product labels as approved in accordance with FIFRA section 3(c)(5), applicators are required to purchase signs for the posting requirement and tubes and pumps for the air monitoring requirement. BEAD previously estimated that the sign cost is $0.09 per sheet and assuming 4 sheets per application (posting at 2 points of entry to the treated field and 2 postings along routes of approach to the treated field on average), the cost per application is $0.36.  The total annual material cost for posting, assuming 12,651 applications per year, is $4,554. When this sign cost estimate is inflated to 2017, to account for the general increase in price-level since that time, the total annual cost is $5,566 (i.e. $0.11 per sheet). This cost is inflated using the CPI (consumer price index) inflation calculator from BLS[5]. With 37,953 applications over 3 years, the total estimated 3-year cost is $16,699.  
      
      Monitoring devices must be used during methyl bromide applications and if sensory irritation occurs while applying other fumigants.  Each application requires a pump to be on-site, and a new tube is necessary for every measurement.  BEAD previously estimated that the cost of a Draeger tube for monitoring the air at an application site is $16 on average and the cost of a Draeger pump is $405.  When these costs are adjusted to reflect 2017 price levels, the cost for the tube is $17 and $435 for the pump. Assuming one tube per application, the total annual cost of the tubes is $217,332 ($17 per tube per application multiplied by 12,651 applications). Over 3 years, the total cost of the tubes is $651,995. Assuming each certified applicator (there are an estimated 4,884 certified applicators) purchases one new pump every 3 years, the total 3-year cost for the pumps is $2,123,807, for an average of $707,936 per year. The 3-year total cost of materials is $2,792,501 (sign posts: $16,699, tubes: $651,995, and pumps: $2,123,807).
      
Table 9.  Certified Applicator and Pesticide Handler Burden and Cost for User Application Activities per Soil Fumigant Application, By Activity (4,884 certified applicators and 14,652 handlers)

                                   Category
                                       
                                   Activity
                                       
                                   Frequency
                                       
                             Certified applicators
                              Pesticide handlers
                                    Total 
                                       
                                       
                                       
                                     Hours
                                     Cost
                                ($37.31 /hr)[1]
                                     Hours
                                 Cost ($27.35
                                     /hr)1
                                     Hours
                                    Cost[2]
Read the Label
Learn/refresh understanding of fumigant requirements
Annual

                                                                           0.50
                                                                         $18.66
                                                                           0.00
                                                                          $0.00
                                                                           0.50
                                                                         $18.66
Posting
    
Fill In Information on Signs
Per application
                                                                           0.13
                                                                          $4.85
                                                                           0.00
                                                                          $0.00
                                                                           0.13
                                                                          $4.85

Post and remove the Signs
Per application
                                                                           0.00
                                                                          $0.00
                                                                           1.00
                                                                         $27.35
                                                                           1.00
                                                                         $27.35
Check EPA website to determine if notice is required and provide notice of applications to applicable SLAs
 
Prepare the information required in the notice.
Per application
                                                                           0.17
                                                                          $6.34
                                                                           0.00
                                                                          $0.00
                                                                           0.17
                                                                          $6.34

Send the notice via paper or electronic means.
Per application
                                                                           0.05
                                                                          $1.87
                                                                           0.00
                                                                          $0.00
                                                                           0.05
                                                                          $1.87
Prepare a Fumigant Management Plan (FMP) and a post-application summary (PAS)
 
 
 
Prepare Initial Plan
Per initial application
                                                                          12.00
                                                                        $447.72
                                                                           0.00
                                                                          $0.00
                                                                          12.00
                                                                        $447.72

Prepare Subsequent Plan
Per subsequent Application
                                                                           1.00
                                                                         $37.31
                                                                           0.00
                                                                          $0.00
                                                                           1.00
                                                                         $37.31

Create Post Fumigation Report
Per application
                                                                           1.00
                                                                         $37.31
                                                                           0.00
                                                                          $0.00
                                                                           1.00
                                                                         $37.31

File and Disclose Plan
Per application
                                                                           0.05
                                                                          $1.87
                                                                           0.00
                                                                          $0.00
                                                                           0.05
                                                                          $1.87
Total Burden and Cost Per Initial and Subsequent Application[3]


Initial Application
                                                                          13.90
                                                                         518.61
                                                                           1.00
                                                                          27.35
                                                                          14.90
                                                                        $545.96


Subsequent Application
                                                                           2.90
                                                                         108.20
                                                                           1.00
                                                                          27.35
                                                                           3.90
                                                                        $135.55
Numbers may not add due to rounding.
1 - Cost is equal to the hours times the wage rate ($/hr).
2 - Total hours and cost are the sum of certified applicator and pesticide handler hours and cost. 
3  -  Initial Application is equal to the sum of each activity less prepare subsequent plan.  Subsequent application hours and cost is equal to the sum of each activity less prepare initial application.

Table 10.  Total Annual Certified Applicator and Pesticide Handler Burden and Cost for User Application Activities (4,884 certified applicators and 14,652 handlers)

                                     Year
                                       
                             Certified applicators
                              Pesticide handlers
                                    Total 
                                       
                                     Hours
                                     Cost
                                ($37.31 /hr)[1]
                                     Hours
                                     Cost
                                 ($27.35 /hr)1
                                     Hours
                                    Cost[2]
Year 1
                                                                        175,849
                                                                     $6,560,922
                                                                         12,651
                                                                       $346,005
                                                                        188,500
                                                                     $6,906,927
Year 2
                                                                        175,849
                                                                     $6,560,922
                                                                         12,651
                                                                       $346,005
                                                                        188,500
                                                                     $6,906,927
Year 3
                                                                        106,268
                                                                     $3,964,874
                                                                         12,651
                                                                       $346,005
                                                                        118,919
                                                                     $4,310,879
3 Year
 Annual Average
                                                                        152,655
                                                                     $5,695,573
                                                                         12,651
                                                                       $346,005
                                                                        165,306
                                                                     $6,041,578
3 Year
 Total
                                                                        457,966
                                                                    $17,086,719
                                                                         37,953
                                                                     $1,038,015
                                                                        495,919
                                                                    $18,124,733
Numbers may not add due to rounding.
1 - Cost is equal to the total hours and cost for the initial and subsequent application as listed in rows 11 and 12 of Table 6 multiplied times the number of applications.  EPA assumes that fumigations occur once every two years, and that 100% of fumigations in year 1 and 2 are first time fumigation, and 50% of fumigations are first time fumigations starting in year 3. The estimated number of applications per year is as follows: 
			Initial Applications	Subsequent Applications
Year 1			12,651			0
Year 2			12,651			0
Year 3			6,326			6,326
3 Year Average		10,543			2,109
3 Year Total		31,628			6,326
For Example: For certified applicators in Year 3 the hours are equal to following:
Certified applicator: (13.90 hours/application x 6,326 applications) + (2.90 hours/application x 6,326 applications)
2 - Total hours and cost are the sum of certified applicator and pesticide handler hours and cost. 

      (1b)  Training Activities Related to Soil Fumigations 
      Table 11 summarizes the burden and cost for certified applicators and pesticide handlers for training activities per trainee, while Table 12 summarizes the burden and cost per year of training activities.  The annual burden and cost is based on the number of certified applicators and pesticide handlers involved with soil fumigant applications.  EPA estimates that there are 4,884 certified applicators and 14,652 handlers. This is based on data submitted to EPA on the number of certified applicators and the assumption of three pesticide handlers per certified applicator.   
        
Table 11.  Certified Applicator and Pesticide Handler Burden and Cost for Training Activities per Applicator, By Activity (4,884 certified applicators and 14,652 handlers)

                                   Category
                                       
                                   Activity
                                   Frequency
                             Certified applicators
                              Pesticide handlers
                                    Total 
                                       
                                       
                                       
                                     Hours
                                     Cost
                                ($37.31 /hr)[1]
                                     Hours
                                 Cost ($27.35
                                     /hr)1
                                     Hours
                                    Cost[2]
Applicators must take registrant developed and EPA approved fumigant training
Training as required by product labels approved in accordance with 3(c)(5)
Once Every 3 Years
                                                                           8.00
                                                                        $298.48
                                                                           0.00
                                                                          $0.00
                                                                           8.00
                                                                        $298.48

Retain training documentation as required by product labels approved in accordance with 3(c)(5)
Once Every 3 Years
                                                                           0.05
                                                                          $1.87
                                                                           0.00
                                                                          $0.00
                                                                           0.05
                                                                          $1.87
Handlers must receive fumigant specific information
Fumigant specific safety information as required by product labels approved in accordance with 3(c)(5) 
Annual[3]
                                                                           0.08
                                                                          $2.98
                                                                           1.00
                                                                         $27.35
                                                                           1.08
                                                                         $30.33
Numbers may not add due to rounding.
1 - Cost is equal to the hours times the wage rate ($/hr).
2 - Total hours and cost are the sum of certified applicator and pesticide handler hours and cost.
3  -  Information is disseminated to pesticide handlers on a per application basis.  Estimates presented here are the total estimated annual burden of all applications conducted by a certified applicator or pesticide handler in a given year.

Table 12.  Total Annual Certified Applicator and Pesticide Handler Burden and Cost for Training Activities (4,884 certified applicators and 14,652 handlers)

                                     Year
                                       
                             Certified applicators
                              Pesticide handlers
                                    Total 
                                       
                                     Hours
                                     Cost
                                ($37.31 /hr)[1]
                                     Hours
                                     Cost
 ($27.35 /hr)1
                                     Hours
                                    Cost[2]
Year 1
                                                                         39,707
                                                                     $1,481,465
                                                                         14,652
                                                                       $400,732
                                                                         54,359
                                                                     $1,882,197
Year 2
                                                                            391
                                                                        $14,578
                                                                         14,652
                                                                       $400,732
                                                                         15,043
                                                                       $415,310
Year 3
                                                                            391
                                                                        $14,578
                                                                         14,652
                                                                       $400,732
                                                                         15,043
                                                                       $415,310
3 Year
 Annual Average
                                                                         13,496
                                                                       $503,540
                                                                         14,652
                                                                       $400,732
                                                                         28,148
                                                                       $904,272
3 Year
 Total
                                                                         40,488
                                                                     $1,510,621
                                                                         43,956
                                                                     $1,202,197
                                                                         84,444
                                                                     $2,712,817
Numbers may not add due to rounding.
1 - Cost is equal to the total hours and costs as listed Table 8 times the number of certified applicators and pesticide handlers that apply or handle soil fumigants. For Example: For certified applicators in Year 1 the hours are equal to following:
Certified applicator: (8.00 hours/applicator + 0.05 hours/applicators + 0.08 hours/applicator) x (4,884 applicators)
2 - Total hours and cost are the sum of certified applicator and pesticide handler hours and cost. 


 Registrants of Soil Fumigant Products
      The estimated paperwork costs for soil fumigant registrants are shown in Tables 13 and 14.  Wage rates are for NAICS 325300 - Pesticide, Fertilizer, and Other Agricultural Chemical Manufacturing and are fully loaded to account for benefits and overhead.  EPA estimates that there are 6 registrant task forces that will develop and distribute the required materials based on correspondence with these task forces. Table 13 shows the estimates of burden and cost per registrant task force to distribute training materials; prepare and distribute safety information; implement community outreach; and distribute first responder training materials. Table 14 shows the annual cost across all registrants of the activities taking into account the frequency of the activity. The management wage rate is $140.57/hr. The technical wage rate is $72.88 /hr. The clerical wage rate is $47.30 /hr.

Table 13.  Soil Fumigant Registrant Burden and Cost, By Activity

                                   Category
                                       
                                   Activity
                                   Frequency
                                  Management
                                   Technical
                                   Clerical
                                    Total 
                                       
                                       
                                       
                                     Hours
                                    Cost[1]
                                     Hours
                                    Cost[1]
                                     Hours
                                    Cost 1
                                     Hours
                                    Cost[2]
Fumigant Training
Handler Safety Information


Maintain/Disseminate training materials (either electronic, paper, or in person)
Annually
                                                                           0.00
                                                                          $0.00
                                                                          10.00
                                                                           $729
                                                                          12.00
                                                                           $568
                                                                          22.00
                                                                         $1,296

Disseminate training materials (either electronic or paper)
Annually
                                                                           0.00
                                                                          $0.00
                                                                           0.00
                                                                          $0.00
                                                                          12.00
                                                                           $568
                                                                          12.00
                                                                           $568
Community Outreach Program
Implement the program in high fumigant use areas
Annually
                                                                          40.00
                                                                         $5,623
                                                                          40.00
                                                                         $2,915
                                                                          40.00
                                                                         $1,892
                                                                         120.00
                                                                        $10,430
First Responder Training
Disseminate the training in high fumigant use areas
Annually
                                                                           0.00
                                                                          $0.00
                                                                           0.00
                                                                          $0.00
                                                                         120.00
                                                                         $5,676
                                                                         120.00
                                                                         $5,676
Fumigant Training

Maintain/Disseminate training materials (either electronic, paper, or in person)
Annually
                                                                           0.00
                                                                          $0.00
                                                                          10.00
                                                                           $729
                                                                          12.00
                                                                           $568
                                                                          22.00
                                                                         $1,296
Numbers may not add due to rounding.
1 - Cost is equal to the hours times the wage rate ($/hr). Management wage rate is $140.57/hr. Technical wage rate is $72.88 /hr. Clerical wage rate is $47.30 /hr. 
2 - Total hours and cost are the sum of managerial, technical and clerical hours and cost. 


Table 14.  Total Annual Registrant Burden and Cost (6 registrant task forces) 

                                     Year
                                       
                                  Managerial
                                       
                                   Technical
                                   Clerical
                                    Total 
                                       
                                     Hours
                                     Cost
                                ($140.57/hr)[1]
                                     Hours
                                     Cost
                                ($72.88 /hr)[1]
                                     Hours
                                 Cost ($47.30
                                     /hr)1
                                     Hours
                                    Cost[2]
Year 1
                                                                            240
                                                                        $33,737
                                                                            300
                                                                        $21,864
                                                                          1,104
                                                                        $52,219
                                                                          1,644
                                                                       $107,820
Year 2
                                                                            240
                                                                        $33,737
                                                                            300
                                                                        $21,864
                                                                          1,104
                                                                        $52,219
                                                                          1,644
                                                                       $107,820
Year 3
                                                                            240
                                                                        $33,737
                                                                            300
                                                                        $21,864
                                                                          1,104
                                                                        $52,219
                                                                          1,644
                                                                       $107,820
3 Year
 Annual Average
                                                                            240
                                                                        $33,737
                                                                            300
                                                                        $21,864
                                                                          1,104
                                                                        $52,219
                                                                          1,644
                                                                       $107,820
3 Year
 Total
                                                                            720
                                                                       $101,210
                                                                            900
                                                                        $65,592
                                                                          3,312
                                                                       $156,658
                                                                          4,932
                                                                       $323,460
Numbers may not add due to rounding.
1 - Cost is equal to the total hours and cost in Table 13 multiplied times the estimated number of registrant task forces (6).  There are 14 registrants represented by the 6 registrant task forces.  For Example: The Year 1 number of managerial hours is equal to the hours per registrant for each of the activities times 6:  (80 hours/registrant+0 hours/registrant+40 hours/registrant+0 hours/registrant+80 hours/registrant+40 hours/registrant+80 hours/registrant+0 hours/registrant) x (6 registrants)
2 - Total hours and cost are the sum of managerial, technical and clerical hours and cost. 

 State Activities Related to Soil Fumigations
      The burden for states per application for compliance and enforcement activities is shown in Table 15.  Wage rates are for NAICS 999200  -  State Government and are fully loaded to account for benefits and overhead.  EPA's requirements are for only those states with high fumigant use, and currently, EPA estimates that there are 15 states that account for the majority of fumigant use and are considered high use: California, Washington, Idaho, Oregon, Wisconsin, Michigan, Florida, Minnesota, North Carolina, Virginia, Arizona, Nevada, Georgia, Colorado, and North Dakota.  This is based on an EPA analysis of fumigant pesticide usage and U.S. crop acreage grown which showed that a majority of soil fumigant usage occurred in 15 states. Costs are measured on a per application basis. Annual burden, assuming more than 12,651 fumigant applications per year, is shown in Table 16. The Agency estimates that all of the paperwork burden for responding to this ICR will be conducted by clerical (or administrative) staff.

Table 15.  State Burden and Cost per Application

                                     Year
                                   Activity
                                       
                                   Frequency
                                       
                                   Clerical
                                    Total 
                                       
                                       
                                       
                                     Hours
                                     Cost 
                                 ($43.68 /hr)1
                                     Hours
                                    Cost[2]
State Compliance and Enforcement
Paperwork for Compliance and Enforcement
                                       
                                       
                                   Annually
                                     0.25
                                       
                                       
                                    $10.92
                                       
                                       
                                     0.25
                                       
                                       
                                    $10.92
                                       
                                       
Numbers may not add due to rounding.  State management and technical staff are not estimated to be impacted by this ICR.
1 - Cost is equal to the hours times the wage rate ($/hr).
2 - Total hours and cost are the sum of managerial, technical and clerical hours and cost.  Since only clerical staff is impacted, the total hours and cost are equal to the clerical hours and cost.

Table 16.  Total Annual State Burden and Cost

                                     Year
                                   Clerical
                                    Total 
                                       
                                     Hours
                                     Cost 
                                 ($43.68 /hr)1
                                     Hours
                                    Cost[2]
Year 1
                                                                          3,163
                                                                       $138,149
                                                                          3,163
                                                                       $138,149
Year 2
                                                                          3,163
                                                                       $138,149
                                                                          3,163
                                                                       $138,149
Year 3
                                                                          3,163
                                                                       $138,149
                                                                          3,163
                                                                       $138,149
3 Year Annual Average
                                                                          3,163
                                                                       $138,149
                                                                          3,163
                                                                       $138,149
3 Year Total
                                                                          9,488
                                                                       $414,447
                                                                          9,488
                                                                       $414,447
Numbers may not add due to rounding.  State management and technical staff are not estimated to be impacted by this ICR.
1 - Cost is equal to the total hours and cost per application as listed in Table 15 multiplied times the number of applications.  EPA assumes that fumigations occur once every two years, and that 100% of fumigations in year 1 and 2 are first time fumigation, and 50% of fumigations are first time fumigations starting in year 3. The estimated number of applications per year as follows: 
			Initial Applications	Subsequent Applications
Year 1			12,651			0
Year 2			12,651			0
Year 3			6,326			6,326
3 Year Average		10,543			2,109
3 Year Total		31,628			6,326
For Example: For states in Year 1, the hours are equal to the following: (0.25 hours/application x 12,651 applications)
2 - Total hours and cost are the sum of managerial, technical and clerical hours and cost.  Since only clerical staff is impacted, the total hours and cost are equal to the clerical hours and cost.

      
      6(c).	Estimating Agency Burden and Cost for Soil Fumigations
      
      Agency burden is shown in Tables 17 and 18.  To determine Agency costs, the Agency used the Bureau of Labor Statistics estimates of labor rates for the North American Industry Classification System code for the Federal Executive Branch (NAICS 999100). Wage rates are fully loaded to account for benefits and overhead.  Table 17 shows the burden and cost per activity for the Agency, while Table 18 is the annual burden and cost across all activities.  Agency costs are based on managerial and technical hours spent on compliance and enforcement activities.

Table 17.  Agency Burden and Cost

                                   Category
                                       
                                   Activity
                                       
                                   Frequency
                                       
                                  Managerial
                                   Technical
                                    Total 
                                       
                                       
                                       
                                     Hours
                                     Cost
                               ($129.84 /hr)[1]
                                     Hours
                                 Cost ($85.51
                                     /hr)1
                                     Hours
                                    Cost[2]
Federal Compliance and Enforcement
Compliance
Training and Stakeholder
Engagement
Annually
                                                                            104
                                                                     $13,503.36
                                                                          1,092
                                                                     $93,376.92
                                                                          1,196
                                                                    $106,880.28
Numbers may not add due to rounding.  Agency clerical staff are not impacted by this ICR.
1 - Cost is equal to the hours times the wage rate ($/hr).
2 - Total hours and cost are the sum of managerial, technical hours and cost. 



Table 18.  Total Annual Agency Burden and Cost 

                                     Year
                                       
                                  Managerial
                                   Technical
                                    Total 
                                       
                                     Hours
                                     Cost
                               ($129.84 /hr)[1]
                                     Hours
                                     Cost 
                                    ($85.51
                                     /hr)1
                                     Hours
                                    Cost[2]
Year 1
                                                                            104
                                                                        $13,503
                                                                          1,092
                                                                        $93,377
                                                                          1,196
                                                                       $106,880
Year 2
                                                                            104
                                                                        $13,503
                                                                          1,092
                                                                        $93,377
                                                                          1,196
                                                                       $106,880
Year 3
                                                                            104
                                                                        $13,503
                                                                          1,092
                                                                        $93,377
                                                                          1,196
                                                                       $106,880
3 Year
 Annual Average
                                                                            104
                                                                        $13,503
                                                                          1,092
                                                                        $93,377
                                                                          1,196
                                                                       $106,880
3 Year
 Total
                                                                            312
                                                                        $40,510
                                                                          3,276
                                                                       $280,131
                                                                          3,588
                                                                       $320,641
Numbers may not add due to rounding.
1 - Cost is equal to the total hours and cost across activities based on frequency from Table 17.  For example: Years 1 to 3  only include the activities incurred annually (104 hours).
2 - Total hours and cost are the sum of managerial and technical hours and cost. 

      
      6(d).	Bottom Line Burden Hours and Cost for Soil Fumigations
      
      Tables 19 and 20 summarize the total annual respondent and Agency burden for soil fumigations, respectively.  Including the cost to applicators for the materials required for compliance with the posting and air monitoring requirements ($2,792,501), the total 3 year respondent cost is          $24,367,959.
      
Table 19.  Total Annual Respondent Burden and Cost for Soil Fumigations

                            Information Collection
                                  Respondent
                               No. of Responses
                                 Burden Hours
                                     Costs
Fumigant User Application Activities (Table 9)
                             Certified Applicators
                                    12,651
                                    152,655
                                $5,695,573[1] 

                              Pesticide Handlers
                                    12,651
                                    12,651
                                   $346,005 
Fumigant Training Activities (Table 11)
                             Certified Applicators
                                     4,884
                                    13,496
                                   $503,540 

                              Pesticide Handlers
                                    14,652
                                    14,652
                                   $400,732 
Distribution of Training & Informational Materials (Table 13)
                                  Registrants
                                       6
                                     1,644
                                   $107,820 
Paperwork for Compliance and Enforcement in High Use States 
                                State Agencies
                                    12,651
                                     3,163
                                   $138,149 
(Table 15)




Total Annual Average
                                       
                                    57,495
                                    198,262
                                  $7,191,819
[1] Costs for certified applicators also include the capital costs for purchasing buffer zone signs and air monitoring equipment (pumps and tubes).  See section 6(b)(1a) and Table 7. 


Table 20.  Total Annual Agency Burden and Cost for Soil Fumigations

Year
Total Hours[1]
Total Cost[1]
Year 1
1,196
$106,880
Year 2
1,196
$106,880
Year 3
1,196
$106,880
3 Year Annual Average
1,196
$106,880
3 Year Total
3,588
$320,641
1  -  Total hours and cost are a sum of total hours and cost for the Agency.  See Table 18.

      
      6(e). Estimating Non-Soil Fumigant Respondent Burden

      Table 21 summarizes the burden and cost for paperwork activities per non-soil fumigant application for certified applicators and pesticide handlers for the five non-soil active ingredients subject to this ICR as listed in Table 2. The annual burden and cost is based on the time it takes to make a non-soil fumigation application and the number of applications made per year. Based on a review of two comprehensive labels for soil and non-soil fumigants (metam sodium[s] and methyl bromide[ns]), EPA estimates that the burden or time needed for non-soil fumigants to be about a third of what is required for soil fumigations. Generally, this difference in estimation is due to the difference in requirements on the labels for both types, e.g. the necessary procedures of what must be done before, during, and after a fumigation. The requirements are similar for both types, but for soil fumigations there are typically more `elements' or requirements on the labels. 

      Table 22 summarizes the burden and cost per year for all non-soil fumigations. The wage rates used for all respondents in this section, non-soil fumigation, are the same as those used earlier for soil fumigations. There are an estimated 23,378 applicators applying non-soil fumigants and 70,134 pesticide handlers of non-soil fumigants. This is based on an estimate of three pesticide handlers per one certified applicator. Data available to EPA show that on average each certified applicator is doing about one fumigation per month or 11.26 /year. This is based on data from two states (CA and FL) with a high number of fumigations per year. Since comprehensive national level data on the number of non-soil fumigations is not available to EPA, these high use states provide a low-end estimate of the annual number of applications. One of the primary reasons why getting an estimate (annual or otherwise) for non-soils fumigations is more difficult than for soil fumigations is due to the nature of the sites, i.e. fields (mostly agricultural) for soil fumigation and structures (houses, grain silos, railway cars, buildings in whole or part, etc.) and commodities (strawberries, ham, almonds, quarantine items, etc.) for non-soil fumigations. Some homes, buildings, and commodities may be fumigated every year, by the same pest control company or under contract, such that the time required for all subsequent similar applications to that same site is reduced significantly. The current data does not make a distinction between initial and subsequent applications, but the annual number of applications by type (structural or commodity) does not fluctuate significantly in either state, which lends some support to the aforementioned assumption that subsequent applications are occurring. Nevertheless, since there is no way to determine what percent of applications may be subsequent applications with reduced burden time and cost, the estimation of burden below counts the annual average number of applications in each year as being initial applications. EPA estimates 263,200 non-soil fumigation applications (23,378 applicators x 11.26 applications/year) are made per year by certified applicators and pesticide handlers to non-soil sites.

Table 21.  Certified Applicator and Pesticide Handler Burden and Cost for User Application Activities per Non-Soil Fumigant Application, By Activity (23,378 certified applicators and 70,134 handlers)

                                   Category
                                   Activity
                                   Frequency
                             Certified applicators
                              Pesticide handlers
                                       
                                       



                                     Hours
                                     Cost
                                     Hours
                                 Cost ($27.35
                                     Hours
                                    Cost[2]




                                ($37.31 /hr)[1]

                                     /hr)1


Read the Label
Learn/refresh understanding of fumigant requirements
Annual
                                      0.5
                                    $18.66
                                       0
                                     $0.00
                                      0.5
                                    $18.66
Prepare a Fumigant Management Plan (FMP)
Prepare Initial Plan
Per initial application
                                       4
                                    $149.24
                                       0
                                     $0.00
                                       4
                                    $149.24

File and Disclose Plan
Per application
                                     0.05
                                     $1.87
                                       0
                                     $0.00
                                     0.05
                                     $1.87
Posting
Fill in information on Signs
Per application
                                     0.13
                                       
                                     $4.85
                                       0
                                     $0.00
                                     0.13
                                     $4.85

Post and remove the Signs
Per application
                                     0.00
                                       
                                     $0.00
                                       1
                                    $27.35
                                       1
                                    $27.35
Numbers may not add due to rounding.  
1 - Cost is equal to the hours times the wage rate ($/hr).
2 - Total hours and cost are the sum of managerial, technical hours and cost. 


Table 22. Total Annual Certified Applicator and Pesticide Handler Burden and Cost for Non-Soil User Application Activities (23,378 certified applicators and 70,134 handlers)

                                     Year
                                       
                             Certified applicators
                              Pesticide handlers
                                    Total 
                                       
                                     Hours
                                     Cost
                                ($37.31 /hr)[1]
                                     Hours
                                     Cost
 ($27.35 /hr)1
                                     Hours
                                    Cost[2]
Year 1
                                                                     1,231,776 
                                                                    $45,957,563
                                                                       263,200 
                                                                     $7,198,520
                                                                     1,494,976 
                                                                    $53,156,083
Year 2
                                                                     1,231,776 
                                                                    $45,957,563
                                                                       263,200 
                                                                     $7,198,520
                                                                     1,494,976 
                                                                    $53,156,083
Year 3
                                                                     1,231,776 
                                                                    $45,957,563
                                                                       263,200 
                                                                     $7,198,520
                                                                     1,494,976 
                                                                    $53,156,083
3 Year
 Annual Average
                                                                     1,231,776 
                                                                    $45,957,563
                                                                       263,200 
                                                                     $7,198,520
                                                                     1,494,976 
                                                                    $53,156,083
3 Year  Total
                                                                     3,695,328 
                                                                   $137,872,688
                                                                       789,600 
                                                                    $21,595,560
                                                                     4,484,928 
                                                                   $159,468,248
Numbers may not add due to rounding.  
1 - Cost is equal to the hours times the wage rate ($/hr).
2 - Total hours and cost are the sum of managerial, technical hours and cost.

      Table 23 below gives the burden estimate for sulfuryl fluoride registrants with structural fumigation products to complete and implement a stewardship plan for their products as describes as listed in Table 6. As with the estimation of the time required to prepare a non-soil FMP, this plan was assumed to take roughly a third of the time that was estimated for registrants of soil fumigants to do the similar, but more involved task of developing, maintaining, and disseminating soil fumigant training materials. There are two sulfuryl fluoride registrants with registrations that make them subject to this stewardship requirement. Table 24 below shows that the average annual burden to both registrants is expected to be 115 hours and $8,524, while the total burden for the three years covered by this ICR is expected to be 345 hours and $25,572.

Table 23. Non-Soil Fumigant Registrant Burden and Cost, By Activity (2 registrants)
 
                                   Category
                                   Activity
                                   Frequency
                                  Management 
                                       
                                   Technical
                                       
                                   Clerical
                                       
                                     Total
                                       



                                     Hours
                                       
                                     Cost
                                   $141 /hr
                                     Hours
                                       
                                     Cost
                                   $73 /hr 
                                     Hours
                                       
                                     Cost
                                   $47 /hr 
Hours
 
Cost
 
Steward-ship Training
Develop training materials
One time
                                                                             27
                                                                         $3,749
                                                                             53
                                                                         $3,887
                                                                             27
                                                                         $1,261
                                                                            107
                                                                         $8,897

Maintain/Disseminate training materials (either electronic, paper, or in person
Annually
                                                                              0
                                                                             $0
                                                                             10
                                                                           $729
                                                                             12
                                                                           $568
                                                                             22
                                                                         $1,296
Numbers may not add due to rounding.  
1 - Cost is equal to the hours times the wage rate ($/hr).
2 - Total hours and cost are the sum of managerial, technical hours and cost. 

Table 24. Total Annual Non-Soil Fumigant Registrant Burden and Cost (2 registrants)

                                     Year
                                       
                                  Managerial
                                   Technical
                                   Clerical
                                     Total
                                       
                                     Hours
                                     Cost
                                ($140.57/hr)[1]
                                     Hours
                                     Cost
                                ($72.88 /hr)[1]
                                     Hours
                                     Cost 
                                 ($47.30 /hr)1
                                     Hours
                                    Cost[2]
Year 1
                                      53
                                    $7,497 
                                      127
                                    $9,231 
                                      77
                                    $3,658 
                                      257
                                   $20,386 
Year 2
                                       0
                                      $0 
                                      20
                                    $1,458 
                                      24
                                    $1,135 
                                      44
                                    $2,593 
Year 3
                                       0
                                      $0 
                                      20
                                    $1,458 
                                      24
                                    $1,135 
                                      44
                                    $2,593 
3 Year
 Annual Average
                                      18
                                    $2,499 
                                      56
                                    $4,049 
                                      42
                                    $1,976 
                                      115
                                    $8,524 
3 Year
 Total
                                      107
                                    $7,497 
                                      167
                                   $12,147 
                                      125
                                    $5,928 
                                      345
                                   $25,572 
Numbers may not add due to rounding.  
1 - Cost is equal to the hours times the wage rate ($/hr).
2 - Total hours and cost are the sum of managerial, technical hours and cost. 

	Table 25 summarizes the total average annual respondent burden and cost for non-soil fumigations.  Burden hours and costs are measured on a per application basis for certified applicators and handlers, but on a per (stewardship) plan basis for registrants. The average number of responses for all respondents is expected to be around 526,402. The burden hours are estimated to be 1,495,106 and the cost associated with this amount of time for all respondents is estimated to be $53,165,471 annually. 

Table 25. Total Annual Respondent Burden and Cost for Non-Soil Fumigations

                            Information Collection
                                  Respondent
                               No. of Responses
                                 Burden Hours
                                 Burden Costs
Fumigant User Application Activities  (Table 19)
Certified Applicators
                                       
                                    263,200
                                       
                                   1,231,776
                                       
                                 $45,957,563 
 
Pesticide Handlers
                                    263,200
                                    263,200
                                  $7,198,520 
Development and Distribution of Training & Informational Materials  (Table 21)
Registrants
                                       
                                       2
                                      115
                                    $8,524 
Total Annual Average 
                                    526,402
                                   1,495,091
                                 $53,164,607 

      
      6(f). Estimating Agency Burden and Cost for Non-Soil Fumigations

      Table 26 shows the Agency burden for non-soil fumigations. The Agency will review the stewardship plans related to sulfuryl fluoride's structural uses. This review is expected to take 124 hours and cost $10,664. 
Table 26. Agency Non-soil Fumigation Burden and Cost

                                   Category
                                       
                                   Activity
                                       
                                   Frequency
                                       
                                  Managerial
                                       
                                   Technical
                                       
                                     Total
                                        
                                       
                                       
                                       
                                     Hours
                                     Cost
                               ($129.84 /hr)[1]
                                     Hours
                                 Cost ($85.51
                                     /hr)1
                                     Hours
                                    Cost[2]
Federal Compliance and Enforcement
Review stewardship plans
One time
                                                                             2 
                                                                        $288.53
                                                                             10
                                                                     $10,375.21
                                                                            124
                                                                        $10,664
Numbers may not add due to rounding.  Agency clerical staff are not impacted by this ICR.
1 - Cost is equal to the hours times the wage rate ($/hr).
2 - Total hours and cost are the sum of managerial, technical hours and cost. 

      6(g).	Bottom Line Burden Hours and Cost for Fumigations (Soil and Non-Soil)

      Tables 27 and 28 summarize the total annual respondent and Agency burden for all fumigations (soil and non-soil), respectively. The total annual respondent burden hours for fumigation is 1,693,367, of which 198,261 hours are related to soil fumigations and 1,495,106 hours are related to non-soil fumigations. The total annual respondent burden cost for fumigation is $60,357,290, of which $7,191,819 is related to soil fumigations and $53,165,471 is related to non-soil fumigations. The total annual Agency burden hours for fumigation is 1,320, of which 1,196 are related to soil fumigations and 124 are related to non-soil fumigations. The total annual Agency burden cost for fumigation is $117,544, of which $106,880 is related to soil fumigations and $10,664 is related to non-soil fumigations.


Table 27.  Total Annual Respondent Burden Hour and Cost for Fumigations (Soil and Non-soil)

                                  Respondent
                                 Burden Hours
                                 Burden Costs
                               Soil Fumigations
Certified Applicators
                                    166,152
                                $6,199,113[1]  
Pesticide Handlers
                                    27,303
                                   $746,737 
Registrants
                                     1,644
                                   $107,820 
State Agencies
                                     3,163
                                   $138,149 
Total (soil)
                                    198,262
                                  $7,191,819 
                             Non-soil Fumigations
Certified Applicators
                                   1,231,776
                                 $45,957,563 
Pesticide Handlers
                                    263,200
                                  $7,198,520 
Registrants
                                      115
                                    $8,524 
Total (non-soil)
                                   1,495,091
                                 $53,164,607 
 
Total (soil and non-soil)
                                   1,693,353
                                  $60,356,426
[1] Costs for certified applicators also include the capital costs. See section 6(b)(1a) and Table 7.
Table 28. Total Annual Agency Burden Hour and Cost for Fumigations (Soil and Non-soil)
                                Fumigation Type
                                 Burden Hours
                                 Burden Costs
Soil Fumigation
                                     1,196
                                   $106,880 
Non-soil Fumigation
                                      124
                                   $10,664 
Total
                                     1,320
                                   $117,544


      6(f).	Reasons for Change in Burden

      For the soil fumigations, the change in burden hours from 197,646 to 198,262 is primarily due to updating the estimate of the number of applicators certified and handlers for soil fumigations. The change in cost is due to updating the wages to 2017 based on BLS data as described in section 6 (b). For the non-soil fumigations, the increase in burden from 0 to 1,495,091 hours is related to the implementation of statutory responsibilities associated with the registration review of pesticides. The difference in burden hours for these two types of fumigations is driven by the annual estimate of applications. It is estimated that there are 12,651 soil and 263,200 non-soil fumigation applications per year. Certain uses of non-soil fumigants are eligible for continued registration, provided that the risk mitigation measures outlined in Proposed Interim Decisions are adopted. The activities covered by this ICR will be used to ensure that the soil and non-soil fumigant risk mitigation measures are adequately implemented, and accounts for the burden on respondents to adopt those risk mitigation measures. The annual respondent burden for this ICR is estimated to be 1,693,352 burden hours for both soil and non-soil fumigations. 

      
      
      6(g).	Burden Statement

      The total estimated annual soil fumigation respondent paperwork burden to comply with this information collection activity is 198,261 hours.  This estimate includes the time needed for certified applicators (166,152 hours), pesticide handlers (27,303 hours), registrants (1,644 hours), and states (3,163 hours) to conduct soil fumigant application related paperwork activities. For certified applicators, the burden for this collection is estimated to be 2.9 to 13.9 hours per soil fumigant application, and 0.08 to 8.13 hours per certified applicator per year for training.  For pesticide handlers, the burden for this collection is estimated to average 1 hour per soil fumigant application, and 1 hour per pesticide handler per year for safety training.  The burden for registrant task forces to implement fumigant training and distribute informational materials is estimated to be 274 hours per task force per year.  For states, the burden for this collection is estimated to average 0.25 hours per application.

      The total estimated annual non-soil fumigation respondent paperwork burden to comply with this information collection activity is 1,495,091 hours.  This estimate includes the time needed for certified applicators (1,231,776 hours), pesticide handlers (263,200 hours), and registrants (115 hours) to conduct non-soil fumigant application related paperwork activities. For certified applicators, the burden for this collection is estimated to be 4.68 hours per non-soil fumigant application. For pesticide handlers, the burden for this collection is estimated to average 1 hour per non-soil fumigant application. The burden for sulfuryl fluoride registrants (structural uses only) to implement stewardship plans and distribute informational materials is estimated to be 57.6 hours per registrant per year. There is no state burden associated with non-soil fumigation as it relates to this collection request.
      
      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 numbers for EPA's regulations in title 40 of the CFR, after appearing in the Federal Register, are listed in 40 CFR Part 9, and included on the related collection instrument or form, if applicable.

      To comment on the Agency's need for this information, the accuracy of the provided burden estimates, and any suggested methods for minimizing respondent burden, including the use of automated collection techniques, EPA has established a public docket for this ICR under docket ID No. EPA-HQ-OPP-2018-0423, which is available for public viewing at the OPP Docket in the EPA Docket Center, EPA West, Rm. 3334, 1200 Pennsylvania Ave, NW, Washington, DC 20460-0001.  This docket facility is open from 8:30 a.m. to 4:30 p.m., Monday through Friday, excluding legal holidays.  The OPP Docket telephone number is (703) 305-5805.  An electronic version of the public docket is available through Federal eRulemaking Portal, http://www.regulations.gov.  Follow the online instructions for viewing documents and submitting comments. You can also send comments to the Office of Information and Regulatory Affairs, Office of Management and Budget, 725 17th Street, NW, Washington, DC 20503, Attention: Desk Office for EPA.  Please include the docket ID No. EPA-HQ-OPP-2018-0423 and OMB control number 2070-0197 in any correspondence.
                                        
 

 7.	ATTACHMENTS TO THE SUPPORTING STATEMENT
 
       Attachments to the supporting statement are available in the public docket established for this ICR under docket identification number EPA-HQ-OPP-2018-0423.  These attachments are available for online viewing at www.regulations.gov or otherwise accessed as described in section 6(f) of the supporting statement.
 
 Attachment A:	7 U.S.C. 136a - FIFRA section 3(c)(2)(B). This is also available online at the House of Representatives' US Code Website
 
 Attachment B:	7 U.S.C. 136a - FIFRA Section 3(c)(5). This is also available online at the House of Representatives' US Code Website
 
 Attachment C:	Docket Numbers for Fumigant Reregistration Eligibility Decisions and Supporting Documents
 
 Attachment D:	EPA OIG Report: Additional Measures Can Be Taken to Prevent Deaths and Serious Injuries From Residential Fumigations. This is also available online at https://www.epa.gov/sites/production/files/2016-12/documents/_epaoig_20161212-17-p-0053.pdf. 
 
 Attachment E	[Reserved for Consultations Summary]
 
 Attachment F:	Worksheet for Estimating OPP ICR Wage Rates for Industry, State and EPA Labor Costs
 
 Attachment G:	Fumigant Management Plans (FMP) Information and Templates. Available at https://www.epa.gov/soil-fumigants/fumigant-management-plan-templates-phase-2-files-listed-chemical 
 
Attachment H: 	Identifying Fumigant High-Use Areas Using Metam-Sodium as an Example
