ICR Attachment I: Consultation Response from Dow AgroSciences

DowAgrcSciences Response to EPA ICR No. 0161.11, Consultation Questions
September 16, 2008
Attn: Docket ID No.: EPA-HQ-OPP-2008-0255
(1) Publicly Available Data
(1) Is the data that the Agency seeks available from any public source, or already
collected by another office at EPA or by another agency?
No, Dow AgroSciences’ data is stored in a proprietary system that is restricted to
a limited number of its employees.
(2) If yes, where can you find the data?
(2) Frequency of Collection
Can the Agency collect the information less frequently and still produce the same
outcome?
The regulation states that the Purchaser Acknowledgement Statement must be signed and
returned to the exporter prior to shipment of the product. Today the Agency does require
that the exporter submit executed Purchaser Acknowledgement Statement within 7
working days of the exporter’s receipt of the document. The Agency could allow the
exporter to accumulate the forms for a 30-day period, and submit to the Agency by the
15th day of the month after the 30-day accumulation period (e.g., collect data from
August 1 to August 31, and submit to the Agency by September 15).
(3) Clarity of Instructions
(1) The ICR is intended to require that respondents provide certain data so that the
Agency can utilize them.
(1) Based on the instructions (regulations, PR Notices, etc.), is it clear
what you are required to do and how to submit such data?
Yes, this information is typically clear.
(2) If not, what suggestions do you have to clarify the instructions?
(2) Do you understand that you are required to maintain records?
Yes, Dow AgroSciences is aware of the requirements to maintain these
documents per 40 CFR § 169.2.
(3) Considering that there is no required submission format, is it difficult to
submit information in ways that are clear, logical and easy to complete?
Dow AgroSciences had recently proposed a new format to the Agency, whereby
we could include multiple products for one customer on the same form. The
Agency accepted the new format. This has reduced the amount of paperwork

required for both the customer to sign, for Dow AgroSciences to retain on file,
and for the Agency to process.
(4) Regarding the any [specific program] forms, do you use them?
Are they clear, logical, and easy to complete?
I am unsure what you are asking in this question.
(4) Electronic Reporting and Record keeping
The Government Paperwork Elimination Act requires agencies make available to the
public electronic reporting alternatives to paper-based submissions by 2003, unless there
is a strong reason for not doing so. One such reason is that, at the present time, the
Agency is unable to ensure the security of CBI that might be transmitted over the
Internet.
(1) What do you think about electronic alternatives to paper-based records and
data submissions? Current electronic reporting alternatives include the use of
“web forms”/XML based submissions via the Agency’s Internet site and magnetic
media-based submissions, e.g., diskette, CD-ROM, etc. Would you be interested
in pursuing electronic reporting?
Are you keeping your records electronically? If yes, in what format?
Dow AgroSciences would fully support the electronic submission of these
documents to the Agency. We would like to see the ability to attach electronic
copies of the documents to the web forms / XML based submissions in the
agency’s Internet site and would value acknowledgement or confirmation that
each submission has been received by the Agency. This would, in our minds,
make the process much more efficient and help streamline the process on our end.
(2) Although the Agency does not offer an electronic reporting option because of
CBI-related security concerns at this time
(1) Would you be more inclined to submit CBI on diskette than on paper?
No, it would be just as easy for us to submit on paper. To submit on
diskette would require us to scan some of the files that are not received by
e-mail internally and then copy to diskette.
(3) What benefits would electronic submission bring you in terms of burden
reduction or greater efficiency in compiling the information?
Dow AgroSciences has a global initiative to reduce the paperwork it generates,
and electronic filing and record retention would aid in this initiative. It is much
easier to scan and retrieve electronic files than it is to search paper files for
information. Electronic submissions would help in this regard.
(5) Burden and Costs
(1) Are the labor rates accurate?

This is close to the rates for Dow AgroSciences.
(2) The Agency assumes there is no capital cost associated with this activity. Is
that correct?
Yes, this is correct.
(3) Bearing in mind that the burden and cost estimates include only burden hours
and costs associated with the paperwork involved with this ICR, e.g., the ICR
does not include estimated burden hours and costs for conducting studies, are the
estimated burden hours and labor rates accurate? If you provide burden and cost
estimates that are substantially different from EPA’s, please provide an
explanation of how you arrived at your estimates.
This is close to the rates for Dow AgroSciences..
(4) Are there other costs that should be accounted for that may have been missed?
Not that I am aware of today.