August 31, 2010
SUPPORTING STATEMENT FOR AN
INFORMATION COLLECTION REQUEST
1. IDENTIFICATION OF THE INFORMATION COLLECTION
1(a) Title of the Information Collection
TITLE: Requirements for Certified Applicators Using 1080 Collars for Livestock Protection
OMB NO. 2070-0074 EPA No. 1249.09
1(b) Short Characterization/Abstract
This information collection request (ICR) is a renewal of an existing ICR that is currently approved by OMB and is due to expire on November 30, 2010. This information collection activity enables the Environmental Protection Agency (EPA) to obtain the information needed to track the use of registered 1080 collars and the record keeping requirements imposed by an administrative judge in October 1982 and confirmed by the Agency in 1983. This ICR affects Certified Applicators, four States (Montana, New Mexico, South Dakota, and Wyoming) that monitor the program, and one registrant. Applicators who are certified to apply livestock protection collars are required to keep records of: a) the number of collars attached on livestock; b) pasture(s) where collared livestock were placed; c) the dates of each attachment, inspection, and removal; d) the number and locations of livestock found with ruptured or punctured collars and the apparent cause of the damage; e) the number, dates, and approximate location of all collars lost; and f) the species, locations, and dates of all suspected poisonings of humans, domestic animals or non-target wild animals resulting from collar use.
EPA receives annual monitoring reports from registrants, certified applicators, and State lead agencies. Applicators maintain records, and the registrants/state agencies do monitoring studies and submit the reports. These records are monitored by either a) State lead agencies, or b) registrants. This ICR also covers monitoring activities associated with collar use and to the preparation and submission of an annual monitoring report to EPA that are over and above requirements that are either conditions of registration or obligations associated with the handling and regulation of any restricted use pesticide product.
2. NEED FOR AND USE OF THE COLLECTION
2(a) Need/Authority for the Collection
EPA banned all predator uses of Sodium Monofluoroacetate (Compound 1080) in 1972. In 1981 and 1982, EPA received applications to register 1080 in several delivery mechanisms, one of which was the toxic collar. Following extensive public hearings in 1982, EPA's Administrative Law Judge Nissen declared, on October 22, 1982, that the Agency could register the collar, with certain specific use restrictions, after going through the normal registration process. The Administrative Law Judge included restrictions and recordkeeping requirements in Attachment C of his initial decision (see Attachment A). On October 31, 1983, then EPA Assistant Administrator Lee M. Thomas affirmed Judge Nissen's initial decision, including the use restrictions and recordkeeping requirements.
Prior to 1972, 1080 was used for predator control in a number of ways, some of which were subject to the 1982 proceedings, which either did not receive a favorable ruling from the Administrative Law Judge or were not subsequently registered for other reasons. As there have been occasional reports of predator control use and other uses of 1080 by illegal methods subsequent to 1972, EPA believes that it is extremely important to account for the 1080 that is supplied for legal use so as to maintain surveillance on the toxic collar program and to deter diversion of 1080 in the program from legal to illegal predator control use. As 1080 is a highly soluble material of potent but delayed oral toxicity, there are additional concerns about transfer of this material to persons who might use or threaten to use it as a weapon of terrorism.
2(b) Practical Utility/Users of the Data
As a condition of the 1080 livestock protection collar registration, EPA has required submission of annual reports monitoring use of all livestock protection collar products. Depending upon the product, the registrant or the State lead agency for pesticide regulation is designated as being responsible for submitting an annual monitoring report. The requirement to submit reports is imposed for at least the first four years of the collars' use under the registration. Factors affecting the extension of requirements to submit annual reports include: 1) quality of reports submitted previously; 2) amount of use reported; 3) results of collar use (in terms of numbers punctured by coyotes, numbers punctured by other causes, numbers lost, nontarget poisonings, etc.); 4) frequency and nature of violations reported; and 5) arrangements made between EPA and registrants regarding annual reports of collar use to meet other requirements for reporting information. EPA reviews the annual reports to assess compliance with the 1982 Administrative Law decision and the requirements of product labeling.
3. NONDUPLICATION, CONSULTATIONS, AND OTHER COLLECTION CRITERIA
3(a) Nonduplication
The processes for recordkeeping, reporting nontarget exposure incidents, and submitting monitoring reports are not duplicative of any other known information collection requirement. This information would not be compiled or reported but for these special requirements for livestock protection collars. While certain information on collar production may be required by agencies that prepare monitoring reports, this information would not, in the main, be duplicative of the confidential production reports that all pesticide registrants must file. The reports are limited to one specific, heavily regulated product and represent the most efficient means for others to generate and EPA to receive this information. This information may not, in all cases, be available to the State lead agencies but for the specific reporting requirements that they impose upon registrants of 1080 livestock protection collars.
3(b) Public Notice Required Prior to ICR submission to OMB
In proposing to renew this ICR, EPA published a Federal Register Notice that provides a 60-day public notice and comment period. EPA received no comments.
3(c) Consultations
In addition to the public notice described in section 3(b) of this ICR as required under 5 CFR 1320.8(d)(1), EPA staff contacted three relevant stakeholders and asked them for their assessment of the regulatory burden estimates expressed by the Agency in the draft ICR. See Attachment B for the questionnaire that was used. EPA consulted with the following individuals:
Ann Nasr
USDA/APHIS
301-734-5170
Kent Drake
Wyoming Department of Agriculture
307-777-6781
Bonnie Rabe
New Mexico Department of Agriculture
575-646-2133
The Agency received one response from APHIS via email and another from the Wyoming Department of Agriculture, both of which have been included in Attachment C. While responses generally indicated that the burden and labor cost estimates as stated in the ICR were reasonable and accurate, one respondent also commented on the need to add Cost of Living costs (2-3 percent/year) to each year since the last report on this information.
The Agency uses wage and benefit statistics from the Bureau of Labor Statistics which are updated periodically to reflect inflation and cost of living adjustments. As such, the Agency believes that the burden estimates in this ICR do not need to be adjusted further. Please see Attachments F, G, and H for the methodology used to estimate the wages of personnel associated with the reporting of this ICR.
3(d) Effects of Less Frequent Collection
Annual monitoring reports are the only items pertaining to collars for which EPA requires scheduled submissions. Longer intervals between submissions would make the information received and EPA's responses to the reports less timely. Longer intervals also would likely increase the amount of time that would be needed to prepare each individual report, increasing the burden on submitters.
3(e) General Guidelines
Requiring monitoring reports to be submitted once a year does not conflict with the general guidelines for data requesters. The required reporting of nontarget incidents, in practice, has not generated any rate of submissions that could be construed as being in violation of these general guidelines. The need for such incidents to be reported rapidly is clear, however. As discussed below in Section 5(c) of this ICR, the reporting requirements for small entities have been limited as much as is legally and responsibly possible.
3(f) Confidentiality
Under FIFRA, health and safety data submitted by registrants are considered by EPA to contain no confidential business information (CBI). If registrants submit data that relates to trade secrets or commercial or financial information, such information is protected from disclosure under Section 10 of FIFRA. Confidential data submitted by registrants to EPA in response to this particular information collection activity will be handled strictly in accordance with provisions of the FIFRA Confidential Business Information Security Manual (Attachment D). This manual contains instructions relative to all in contact with confidential documents, including: responsibilities of the EPA employees; physical security measures; CBI copying and destruction procedures; transfer of CBI materials within the EPA to contractors or other government offices; computer security; CBI typing procedures; and procedures internal to EPA. The manual dictates that all CBI must be marked or flagged as such, all CBI must be kept in secure (double-locked) areas, and all CBI intended to be destroyed must be cleared by a Document Control Officer and shredded.
3(g) Sensitive Questions
No information of a sensitive or private nature is requested in conjunction with this information collection activity. Further, this information collection activity complies with the provisions of the Privacy Act of 1974 and OMB Circular A-108. The names and addresses of both certified livestock protection collar applicators and any other person who owns property on which livestock protection collars have been or will be applied by a certified applicator are considered personal information that will not be disclosed if ever in the possession of EPA. In accordance with 7 USC 136i-1(b), unsolicited information of a sensitive or private nature included in monitoring reports already received, or submitted in the future, will be protected from public release.
4. THE RESPONDENTS AND THE INFORMATION REQUESTED
4(a) Respondents/NAICS Codes
This information collection activity applies to all certified pesticide applicators that apply 1080 collars, to the pesticide manufacturer’s whose products include 1080 collars, and to the government agencies responsible for implementing and administering a 1080 collar monitoring program. Information available to EPA indicates that most, if not all, of the certified applicators subject to this ICR are employees of the Animal and Plant Health Inspection Service (APHIS) within the US Department of Agriculture (USDA), although a small number of other certified applicators may also apply 1080 collars. The North American Industrial Classification System codes assigned to the businesses and other institutions participating in this program are 325300 (Pesticide, Fertilizer, and Other Agricultural Chemical Manufacturing), 926140 (Regulation of Agricultural Marketing and Commodities), and 999200 (State Government).
4(b) Information Requested
4(b)(i) Data Items
The data that certified livestock protection collar applicators are required to record and maintain were outlined in the Initial Decision of the Administrative Law Judge in the 1080 Predacide Hearings. These requirements are stipulated in "Use Restriction 5" in the technical bulletin that is part of the labeling for all livestock protection collar products registered as pesticides in the United States. Use Restriction numbers and content vary somewhat from product to product due to additional restrictions or considerations either proposed by the registrants or required by State lead agencies. The complete list of Use Restrictions can be found in Section V.B.2 of EPA’s 1995 Re-registration Eligibility Decision concerning sodium fluoroacetate (Attachment E).
Registrants of livestock protection collars are required, by Use Restriction 4 of the same typical technical bulletin, to:
". . . keep records of all collars sold or transferred at their address of record. Records shall include the name, address, state where livestock protection collar certification was issued, certification number of each recipient, and dates and numbers of collars sold or transferred."
Use Restriction 5, from a typical technical bulletin, reads as follows:
"Each applicator shall keep records dealing with the use of livestock protection collars and the results of such use. Records shall be maintained in accordance with appropriate State or Federal regulations but for not less than two years following disposal or loss of collars. Such records shall include, but need not be limited to:
The number of collars attached on livestock.
The pasture(s) where collared livestock were placed.
The dates of each attachment, inspection, and removal.
The number and locations of livestock found with ruptured or punctured collars and the apparent cause of the damage.
The number, dates, and approximate location of all collars lost.
The species, locations, and dates of all suspected poisonings of humans, domestic animals or non-target wild animals resulting from collar use."
Use Restriction 6, from the same typical technical bulletin, requires that "suspected" poisonings of "threatened or endangered species,… humans, domestic animals or nontarget wild animals" be reported, within three days of the incident, to a designated government agency (EPA and/or the appropriate State lead agency for regulation of pesticides). EPA requires that certified applicators of livestock protection collars keep and report only those records prescribed by Use Restrictions 5 and 6.
4(b)(ii) Respondent Activities
Certified livestock protection collar applicators are required by product labeling to prepare and maintain records of various activities associated with use and fate of livestock protection collars that they purchase or obtain for use. Preparing these records consists of writing down what is done in normal use and handling of collars.
The use of livestock protection collars is a labor-intensive process. For a typical sheep operation, collar use involves the following activities:
corralling sheep;
isolating target flocks;
capturing appropriate livestock and equipping them with collars;
redeploying target and main flocks in ways that are expected to direct coyotes' attacks toward target flocks and away from the remainder of the producer's sheep;
inspecting target flocks weekly (or more frequently) to account for livestock alive, dead, or missing; to search for lost sheep or lost collars; to capture livestock that require adjustments to collar position or other hands-on attention; and to properly handle and dispose of irreparably damaged collars; and, when collar use is to be terminated; corralling target flocks, capturing collared livestock, removing and inspecting collars, disposing of damaged collars, and returning intact collars to proper secure storage.
The recordkeeping requirements add the need to record significant data associated with collar use such as how many collars were used, where and when they were used, how many were damaged, likely causes of such damage, where collars went after use, and the occurrence of possible nontarget exposure incidents. The time and other costs associated with preparation and maintenance of sale records are conditions of collar use which are required by the product’s labeling. Such requirements are not part of the subject ICR. Burdens related to the ICR begin with the compilation of applicator’s records and with activities associated with assembling data for inclusion in monitoring reports.
Registrants and/or State lead agencies have developed their own instruments that facilitate appropriate recordkeeping by certified applicators. State lead agencies typically require certified livestock protection collar applicators to file periodic reports summarizing collar use. Data from these reports are included in annual monitoring reports submitted to EPA by registrants or state lead agencies. Other data that appear in monitoring reports include summaries of numbers of collars sold or otherwise legally circulated in the State and the number and nature of violations detected with regard to use or handling of livestock protection collars.
As with other registrants of pesticide products, livestock protection collar registrants are required to file annual (confidential) production reports. These reports are required of all establishments that produce pesticides or pesticide devices in the United States, pursuant to Section 7 of FIFRA. Since production does not equate with use, the ICR is not duplicative of the requirement to submit annual production reports, which is covered by a different ICR.
5. THE INFORMATION COLLECTED - AGENCY ACTIVITIES, COLLECTION
METHODOLOGY, AND INFORMATION MANAGEMENT
5(a) Agency Activities
Reports of non-target species poisonings and other incidents included in the annual monitoring reports filed with EPA by State lead agencies are reviewed by the Insecticide-Rodenticide Branch, which initiates whatever regulatory steps are warranted by the incident and places a copy of the incident report in the registration file for the product involved in the incident. To date, no nontarget poisoning incidents have been reported to EPA by State lead agencies. Reasons for this appear to be the limited extent to which collars are used, and the relatively low potential for occurrence and detection of nontarget incidents. However, EPA has noted instances of violations and inaccuracies in inventory in its reviews of monitoring reports.
EPA replies directly, in writing, to the originator of the report, indicating whether the report is acceptable, whether additional details are needed for the current report or future reports, and whether any specific corrective steps are needed based upon items discussed in the monitoring report.
5(b) Collection Methodology and Management
As the number of registered livestock protection collar products is very small (6 at present) and very few reports are expected to be received, no special provisions for data collection and management are needed. The reports submitted are handled and processed through mechanisms that have been developed for handling a wide variety of submissions that pertain to registered pesticide products. These include routing the submission through the routine review process, responding to the submission in writing, and filing the submission and the response in the relevant product's registration file. These submissions are tracked by EPA's Pesticide Registration Information System (PRISM).
5(c) Small Entity Flexibility
Most users, including the private company that is a livestock protection collar registrant, would qualify as small entities. The degree of imposition that these recordkeeping and reporting requirements impose on such individuals is minimal, considering the limited degree of latitude permitted by the Administrative Law Judge and the Administrator of the EPA, the extreme toxicity of Compound 1080, and the great potential for abuse of livestock protection collars should collars or their contents get into the hands of irresponsible persons. The main purpose of the recordkeeping requirements is to promote responsible use and handling. The main purpose for requiring monitoring reports is to establish a process through which it is mandatory to inform EPA of the results of collar use. EPA then can use the data from reports as bases for future regulatory decisions.
The mandatory submission of periodic reports from applicators to State lead agencies based on data that they are already required to collect adds only a minimal amount of burden. In the State where the livestock protection collar product registered to a private firm is used, the lead agency requires the registrant to submit sales and distribution documents to the State.
5(d) Collection Schedule
Livestock protection collar annual monitoring reports are due on a date prescribed as a condition of registration, usually February 15, for each year after the first year in which collars may be used legally.
As nontarget exposure incidents must be reported within three days of their occurrence there is no set schedule for collection of this information. Such reporting is required by product labeling and, therefore, is not part of this ICR. However, nontarget incidents also would be reported and discussed in monitoring reports for the year in which they occurred, with follow-up information regarding dispositions of cases being indicated.
6. ESTIMATING THE BURDEN AND COST OF THE COLLECTION
6(a) Estimating Respondent Burden
EPA has revised the estimated burden associated with the 1080 livestock protection collar annual monitoring reports over its 2007 estimates based on the reports most recently submitted to EPA. For the next 3 years, EPA expects that 40 certified applicators (30 for New Mexico and 10 for APHIS) will use and/or possess collars annually and, consequently, contribute information to be used in monitoring reports. EPA does not expect the burden per applicator, which is currently 40 hours, to decrease over the next 3 years and remains unchanged over our 2007 estimate. EPA points out that this estimate was developed under the assumption that, while perhaps unlikely, one non-target species poisoning incident will occur per year and require 10 hours of burden (which is included in the 40 hour estimate). In all, EPA estimates the total annual burden for certified applicators of 1080 livestock protection collars to be 1600 hours (40 applicators x 40 hours).
EPA anticipates that 4 registrants and/or State lead agencies will file annual monitoring reports based upon information obtained from those certified applicators. Note that, except in the case of the pesticide producer, the registrant is the State. The estimated annual respondent burden for this activity is 77 hours over the next 3 years, and has not changed over the 2007 estimates. The annual burden of the States and registrants is based on the annual monitoring report alone and not other requirements related to use, administration, and regulation of 1080 livestock protection collars. There are currently two States that have been reporting annually on livestock protection collar use, with two other States possibly becoming involved in that activity in the future. EPA estimates the total annual burden for agencies submitting annual monitoring reports to be 308 hours (4 submitters x 77 hours).
As with other registrants of pesticide products, livestock protection collar registrants (i.e., the producer(s), not the State agencies) are required to file annual (confidential) production reports. There are four producers. The estimated annual per respondent burden for this activity is 9 hours, with a total of 36 hours per year over the next 3 years (4 producers x 9 hours). The annual respondent burden is less than in the previous ICR because of a correction in the calculation. As in the current ICR, the previous estimate for the number of registrants was 4, with a burden of 9 hours per respondent. However, the total annual respondent burden was calculated as 45 hours per registrant instead of 36.
The Agency recognizes that the time needed to prepare reports is affected primarily by the extent of use and the number of applicator's to be covered by the report during any given year. Tables 1, 2, and 3 provide a breakdown of the collection activities per respondent and a general overview of how the estimates were derived. The total annual response burden imposed upon certified applicators, State agencies, and registrants associated with the use of 1080 livestock protection collars is estimated to be 1,944 hours (1600 + 308 + 36).
6(b) Estimating Respondent Costs
As in the previous version of this ICR, the Agency estimates wages, benefits, and overhead for all labor categories for the pesticide industry, state government and Agency employees. The Agency estimates are based on currently available information on labor rates from the U.S. Department of Labor and other benefits from publicly available websites. A copy of the methodology used to re-estimate the labor rates and formulas used to derive the fully loaded rates and overhead costs that are used in this ICR are listed in Attachments F, G, and H.
To derive the labor rates for this ICR, Agency economists estimated the wages for the management, technical, and clerical labor categories using the methodology cited above. The registrant respondent costs for managerial, technical and clerical rates are estimated at $109.82, $60.39, and $35.89 per hour, respectively. These labor rates are fully loaded and include benefits and overhead costs.
The state government respondent costs for managerial, technical and clerical rates are estimated at $79.61, $55.72, and $37.31 per hour, respectively. These labor rates are fully loaded and include benefits and overhead costs.
Based on EPA’s methodology for estimating pesticide-related information collection request wage rates for industry, state, and EPA - and based on EPA’s familiarity with the 1080 livestock protection collars program and experiences with USDA - EPA estimates the fully-loaded labor rate of a certified applicator of 1080 livestock protection collars to be approximately equal to the state government clerical labor rate of $37.31/hr (includes the base wage rate, benefits, and overhead).
The total annual cost for all respondents associated with this information collection activity is estimated to be approximately $77,044. In summary:
Certified applicators: $59,696
States: $15,468
Registrants: $1,880
The annual cost for a single respondent is:
Certified applicator: $1,492
State: $3,867
Registrant: $470
Tables 1 through 3 present information for estimating costs based on the burden hours/costs per respondent.
Table 1. Annual Certified Applicator Burden/Cost Estimates
|
Collection Activities |
Burden Hours |
Total Costa |
1. |
Read/hear rule or any collection instrument |
3 |
$111.93 |
2. |
Receive training b |
-- |
-- |
3. |
Plan activities |
3 |
$111.93 |
4. |
Create information |
3 |
$111.93 |
5. |
Gather information |
18 |
$671.58 |
6. |
Process and review information for accuracy |
5 |
$186.55 |
7. |
Record, disclose, or display the information |
5 |
$186.55 |
8. |
Store, file or maintain the information |
3 |
$111.93 |
|
TOTAL |
40 |
$1,492.40 |
(a) Certified Applicator ($37.31/hr)
(b)The burden associated with the training of certified applicators is accounted for under the ICR for the Agency Certification and Training Program (EPA ICR# 0155; OMB Control No. 2070-0029).
ANNUAL BURDEN: Hour Total (40) x Number of Respondents (40) = 1,600
ANNUAL COST: Cost Total ($1,492) x Number of Respondents (40) = $$59,696
Table 2. Annual State Agency Burden/Cost Estimates
Collection Activities |
Burden Hours (per year) |
Total Cost |
|||
|
Management ($79.61/hr) |
Tech. ($55.72/hr) |
Clerical |
|
|
1. |
Read/hear rule or any collection instrument |
0 |
2 |
0 |
$111.44 |
2. |
Plan activities |
0 |
10 |
0 |
$557.20 |
3. |
Create information |
0 |
15 |
0 |
$835.80 |
4. |
Gather information |
0 |
14 |
0 |
$780.08 |
5. |
Process, compile, and review information for accuracy and appropriateness |
0 |
13 |
0 |
$724.36 |
6. |
Record, disclose, display or report the information |
0 |
0 |
20 |
$746.20 |
7. |
Store, file or maintain the information |
0 |
0 |
3 |
$111.93 |
|
TOTAL |
0 |
54 |
23 |
$3,867.01 |
ANNUAL BURDEN: Hour Total (77) x Number of Respondents (4) = 308
ANNUAL COST: Cost Total ($3,867) x Number of Respondents (4) = $$15,468
Table 3. Annual Registrant Burden/Cost Estimates**
Collection Activities
|
Burden Hours (per year) |
Total Cost
|
|||
Management ($109.82/hr) |
Tech. ($60.39/hr) |
Clerical ($35.89/hr) |
|||
1. |
Read/hear rule or any collection instrument |
0 |
2 |
0 |
$120.78 |
2. |
Plan activities |
0 |
1 |
0 |
$60.39 |
3. |
Create information |
0 |
0 |
0 |
$0.00 |
4. |
Gather information |
0 |
2 |
0 |
$120.78 |
5. |
Process, compile, and review information for accuracy and appropriateness |
0 |
1 |
0 |
$60.39 |
6. |
Record, disclose, display or report the information |
0 |
0 |
2 |
$71.78 |
7. |
Store, file or maintain the information |
0 |
0 |
1 |
$35.89 |
|
TOTAL |
0 |
6 |
3 |
$470.01 |
** In all but one case, the registrant is the State and, therefore, covered under State burdens (Table 2).
ANNUAL BURDEN: Hour Total (9) x Number of Respondents (4) = 36
ANNUAL COST: Cost Total ($470) x Number of Respondents (4) = $1,880
6(c) Estimating Agency Burden and Cost
The Agency's total annual burden associated with the 1080 livestock program has changed based upon more accurate estimates of the resources required to complete tasks specifically associated with annual monitoring reports.
To derive the labor rates for this ICR, Agency economists estimated the wages for the management, technical, and clerical labor categories using the methodology cited above. The EPA labor rates for this renewal for technical and clerical rates are estimated at $71.58, and $41.21 per hour, respectively. These labor rates are fully loaded and include benefits and overhead costs. For this ICR, we estimate the annual Agency burden to be 104 hours and the total annual Agency cost to be $7,444. The annual Agency burden is less than in the previous ICR because of a correction in the calculation as indicated in Section 6(a) of this ICR.
Table 4. Annual Agency Burden/Cost Estimates
Collection Activities
|
Burden Hours (annual) |
Total Cost
|
||
Tech. ($71.58/hr) |
Clerical ($41.21/hr) |
|||
1. |
Develop any correspondence needed |
8 |
0 |
$572.64 |
2. |
Answer respondents’ questions |
2 |
0 |
$143.16 |
3. |
Review data submissions |
10 |
0 |
$715.80 |
4. |
Analyze data submissions |
4 |
0 |
$286.32 |
5. |
Store data |
2 |
0 |
$143.16 |
|
TOTAL |
26 |
0 |
$1,861.08 |
ANNUAL BURDEN: Hour Total (26) x Number of Respondents (4) = 104
ANNUAL COST: Cost Total ($1,861) x Number of Respondents (4) = $7,444
6(d) Bottom Line Burden Hours and Costs
Table 5. Bottom Line Burden Hours and Costs/Master Table
|
Total Burden Hours |
Total Cost ($) |
Certified Applicator (Table 1) |
1,600 |
$59,696 |
State (Table 2) |
308 |
$15,468 |
Registrant (Table 3) |
36 |
$1,880 |
Bottom Line Respondent Total |
1,944 |
$77,044 |
Agency Total |
104 |
$7,444 |
6(e) Reasons for Change in Burden
The total annual respondent burden hours reflects a change from the previous ICR by 9 hours, from 1,953 to 1,944. This change is due to a correction to the 2007 cost estimate tables for registrants from 45 to 36 hours, as indicated in Section 6(a) of this ICR.
6(f) Burden Statement
The annual respondent burden for the 1080 livestock collar program is estimated to average 40 hours per certified applicator response, 77 hours per State agency response, and 9 hours per registrant participating in the program. Under the Paperwork Reduction Act, “burden” means the total time, effort, or financial resources expended by persons to generate, maintain, retain, or disclose or provide information to or for a Federal agency. For this collection, it is the time reading the regulations, planning the necessary data collection activities, conducting tests, analyzing data, generating reports and completing other required paperwork, and storing, filing, and maintaining the data. An agency may not conduct or sponsor, and a person is not required to respond to, a collection of information unless it displays a currently valid OMB control number. The OMB control number for this information collection appears at the beginning and the end of this document.
Submit your comments, referencing Docket ID No. EPA‑HQ‑OPP‑2009-884 to (1) EPA online using www.regulations.gov (our preferred method), or by mail to: Public Information and Records Integrity Branch (PIRIB), Mail Code: 7502P, Office of Pesticide Programs (OPP), Environmental Protection Agency, 1200 Pennsylvania Ave., NW, Washington, DC 20460, and (2) OMB by mail to: Office of Information and Regulatory Affairs, Office of Management and Budget (OMB), Attention: Desk Officer for EPA, 725 17th Street, NW, Washington, DC 20503.
Use EPA’s electronic docket and comment system at www.regulations.gov, to submit or view public comments, access the index listing of the contents of the docket, and to access those documents in the docket that are available electronically. Once in the system, select “docket search,” then key in the docket ID number identified above. Please note that EPA’s policy is that public comments, whether submitted electronically or in paper, will be made available for public viewing at www.regulations.gov as EPA receives them and without change, unless the comment contains copyrighted material, CBI, or other information whose public disclosure is restricted by statute. For further information about the electronic docket, go to www.regulations.gov.
Attachments to the Supporting Statement
All of the attachments listed below can be found in the docket for this ICR (unless otherwise noted); accessible electronically through www.Regulations.gov . On the main page, select Advanced Search from the menu bar at the top and select Docket Search. Enter the Docket ID Number, EPA-HQ-OPP-2009-0884 in the Docket ID field. Click on the Submit button. From the results page, you will be able to link to the docket view or directly open select documents found in the docket.
Attachment A: EPA’s Administrative Law Judge’s 1982 Decision on Restrictions and Recordkeeping Requirements (pp. 217-219, “Attachment C, Use Restrictions”)
Attachment B: Sample Consultation Questionnaire
Attachment C: Consultations Responses
Attachment D: Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA) Confidential Business Security Manual
Attachment E: EPA’s 1995 Re-registration Eligibility Decision Concerning Sodium Fluoroacetate
Attachment F: Methodology for Estimating OPP ICR Wage Rates for States and Applicators
Attachment G: Methodology for Estimating OPP ICR Wage Rates for Registrants
Attachment H: Methodology for Estimating OPP ICR Wage Rates for EPA
| File Type | application/msword |
| File Title | SUPPORTING STATEMENT FOR AN |
| Author | NMARTIN |
| Last Modified By | ctsuser |
| File Modified | 2010-09-03 |
| File Created | 2010-08-16 |