Consultation

Attachment E
Supplemental Distributor Information Collection Activity
Consultation Process: Standard Questions

Questions:
1. Is the EPA Form 8570-5, Notice of Supplemental Distribution of a Registered Pesticide
Product, available from any public source? If yes, where can you find the form?
2. The ICR is intended to require that respondents provide certain data so that the Agency can
utilize them. Based on the instructions, is it clear to respondents what they are required to do and
how to submit such data? If not, what suggestions do you have to clarify the instructions?
3. Do respondents understand what they are required to submit or maintain in their records? Is
the reporting form clear, logical, and easy to complete?
4. The Government Paperwork Elimination Act requires agencies make available to the public
electronic reporting alternatives to paper-based submissions by 2003, unless there is a strong
reason for not doing so. If the Agency were able to ensure the security of CBI that might be
transmitted over the Internet and the reporting form could be completed electronically, would you
be interested in submitting it electronically? Current electronic reporting alternatives include the
use of “web forms”/XML based submissions via the Agency’s internet site and magnetic mediabased submissions (i.e., on diskette, CD-ROM, etc.) Are you interested in using, or are they
currently utilizing, electronic reporting/record-keeping options?
5. Where a reporting requirement includes a signature requirement, consider whether a secure
electronic signature method (such as Private Key Infrastructure) should be required if submitting
electronically; whether a less secure method (such as the use of PINs and passwords) would be
more appropriate; or, whether a signed cover sheet may be sufficient for the Agency’s purposes
when data is submitted on disk.
6. If you prefer one method to another, does your choice balance burdens and costs against
electronic data and signature security integrity?
7. If an electronic reporting option is not offered because of CBI-related concerns, would you be
more inclined to submit CBI on diskette than on paper? What benefits would you realize?
(Burden reduction? Greater efficiency in compiling the information?).
8. The labor rates included in the Agency’s estimated burden hours and costs are a U.S. average
that includes costs for overhead and benefits. These estimates include only burden hours and
costs associated with the paperwork involved with this ICR (i.e., the Agency does not include
estimated burden hours and costs for usual and customary business practices such as R&D,
marketing, etc.). Are the estimated burden hours and labor rates accurate?

9. Are there other costs that should be accounted for that may have been missed, such as
capital/start-up/M&O expenditures? If so, please provide an explanation of how you
arrived at your estimate of burden and cost if substantially different than EPA’s estimate.