Attachment E - Record of Consultations on Renewal ICR

EPA ICR No. 0155.10 OMB Control No. 2070-0029
ATTACHMENT E
Record of Consultations Between the U.S. Environmental Protection Agency and
Respondents to the Information Collection Request:
“Certification of Pesticide Applicators”
1. Ples Spradley, Associate Professor – Pesticide Safety Education, University of
Arkansas, Division of Agriculture
2. Gary Fish, Program Manager, State of Maine, Department of Agriculture, Board of
Pesticides Control
3. Adolfo R. Gallo, Program Specialist¸ Program Specialist
California Department of Pesticide Regulation (DPR), Licensing and Certification
Program
For anthrax-related products:
4. Stanley Trout, Director of Mfg. Operations, sBioMed LLC

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Consultation Questions
EPA/OPP ICR - Certification of Pesticide Applicators
OMB No: 2070-0029; EPA No: 0155.09

Contact information
Please fill in your name, title, organization, mailing address and contact information (at
least e-mail or phone number) where you prefer to be contacted. We are required to
include your name and contact information in the next Federal Register notice on this
information collection request (ICR).
Name: Ples Spradley
Title: Associate Professor – Pesticide Safety Education
Organization: University of Arkansas, Division of Agriculture
Address: 2301 S. University Ave., Little Rock, AR 72204
E-mail and phone number: [email protected], 501-671-2234

Questions regarding the ICR document
(1) Publicly Available Data
Is the information that the Agency seeks available from any public source, or already
collected by another office at EPA or by another agency?
Not that I am aware of.
If yes, where can one find the data?
(2) Frequency of collection
Can the Agency collect the information less frequently and still produce the same
outcome?
In my opinion, no.
(3) Clarity of Instructions
Based on the regulations and Agency guidance, is it clear what you are required to do
and how to submit data? If not, what suggestions do you have to clarify instructions?
Yes.
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Do you understand what records need to be kept?
Yes.
Are submission formats clear and logical?
Yes.
(4) Electronic Reporting and Record keeping
Are the Agency web-based reporting tools working well? What improvements would
you suggest for the reporting templates?
Yes, based on my knowledge of CPARD.
What benefits have electronic reporting brought you in terms of burden reduction or
greater efficiency in reporting?
Not applicable to my position.
(5) Burden and Costs
Are the labor rates and burden hour estimates in the ICR supporting statement
accurate? Bear in mind that the estimates include only burden hours and costs
associated with the paperwork involved with this ICR.
The estimates seem realistic to me.
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.
The Agency has assumed there is no capital cost associated with this activity. Is that
correct?
Yes.
Are there other costs that should be accounted for that may have been omitted?
No.

3

Consultation Questions
EPA/OPP ICR - Certification of Pesticide Applicators
OMB No: 2070-0029; EPA No: 0155.09

Contact information
Please fill in your name, title, organization, mailing address and contact information (at
least e-mail or phone number) where you prefer to be contacted. We are required to
include your name and contact information in the next Federal Register notice on this
information collection request (ICR).
Name: Gary Fish
Title: Program Manager
Organization: State of Maine, Department of Agriculture, Board of Pesticides Control
Address:28 State House Station, Augusta, ME 04333-0028
E-mail and phone number: [email protected] 207-287-7545

Questions regarding the ICR document
(1) Publicly Available Data
Is the information that the Agency seeks available from any public source, or already
collected by another office at EPA or by another agency? Not that I know of

If yes, where can one find the data?
(2) Frequency of collection
Can the Agency collect the information less frequently and still produce the same
outcome? Possibly, but it would not provide the same picture and it would become
outdated faster
(3) Clarity of Instructions
Based on the regulations and Agency guidance, is it clear what you are required to do
and how to submit data? If not, what suggestions do you have to clarify instructions?
Do you understand what records need to be kept? yes

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Are submission formats clear and logical? yes
(4) Electronic Reporting and Record keeping
Are the Agency web-based reporting tools working well? What improvements would
you suggest for the reporting templates? yes
What benefits have electronic reporting brought you in terms of burden reduction or
greater efficiency in reporting? easier storage of information
(5) Burden and Costs
Are the labor rates and burden hour estimates in the ICR supporting statement
accurate? Bear in mind that the estimates include only burden hours and costs
associated with the paperwork involved with this ICR. The salaries are high for
Maine
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.
The Agency has assumed there is no capital cost associated with this activity. Is that
correct? No, unless the agency/organization is extremely small
Are there other costs that should be accounted for that may have been omitted? No

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Contact information
Please fill in your name, title, organization, mailing address and contact information (at
least e-mail or phone number) where you prefer to be contacted. We are required to
include your name and contact information in the next Federal Register notice on this
information collection request (ICR).
Name: Adolfo R. Gallo
Title: Program Specialist
Organization: California Department of Pesticide Regulation (DPR), Licensing and
Certification Program
Address: 1001 I Street, P. O. Box 4015, Sacramento, CA 95814
E-mail and phone number: [email protected] & 916.445.3895

Questions regarding the ICR document
(6) Publicly Available Data
Q) Is the information that the Agency seeks available from any public source, or
already collected by another office at EPA or by another agency?
A) Yes, the agencies that provide information to DPR for reporting via CPARD could
also provide that same information upon request to any interested person or
government agency.
Q) If yes, where can one find the data?
A) It can be requested from each agency that provides the information to DPR.
(7) Frequency of collection
Q) Can the Agency collect the information less frequently and still produce the same
outcome?
A) Yes; the state reporting agencies can provide accurate and timely information
biannually to US EPA. US EPA could stagger reporting deadlines within the regions
to ease reviewing and assessment burdens. Biannual reporting and analysis would
have minimal impact on decisions and actions regarding states’ programs. We
assume that collecting the information less frequently would not adversely impact the
funding formula, reduce the cooperative agreement reimbursement level, or disrupt
the cooperative agreement funding process.
(8) Clarity of Instructions
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Q) Based on the regulations and Agency guidance, is it clear what you are required to
do and how to submit data? If not, what suggestions do you have to clarify
instructions?
A) Yes, for the most part, over the years the written instructions and guidelines have
become clearer to understand. However, any annual changes to the CPARD template
should be identified and summarized in a written document and online at the CPARD
log in page.
Q) Do you understand what records need to be kept?
A) Yes
Are submission formats clear and logical?
Q) Mostly, yes.
(9) Electronic Reporting and Record keeping
Q) Are the Agency web-based reporting tools working well? What improvements
would you suggest for the reporting templates?
A) Yes, for the most part. However, any changes to the CPARD template should be
identified and summarized in a written document sent to each SLA CPARD/State
Plan manager and also posted online at the CPARD log in page. These changes would
include different or additional reporting requirements, revised information formats,
additional check/mark boxes, more detailed requested information, etc.

Q) What benefits have electronic reporting brought you in terms of burden reduction
or greater efficiency in reporting?
A) The CPARD system saves time and effort, especially with standardized
information format, saves time over the narrative report format, and time is saved
with the “copy and transfer to the next year report” feature, which is pretty sweet.
(10)
Burden and Costs
Q) Are the labor rates and burden hour estimates in the ICR supporting statement
accurate? Bear in mind that the estimates include only burden hours and costs
associated with the paperwork involved with this ICR.
A) Close, but not accurate; our data is presented in Table DPR-1 that follows.
Q) 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.
A) Estimate costs are based on estimated staff time and accurate staff costs.

Q) The Agency has assumed there is no capital cost associated with this activity. Is
that correct?
A) Correct.
Q) Are there other costs that should be accounted for that may have been omitted?
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A) None to suggest at this time.
Table DPR-1 – DPR Burden and Cost Estimates for Annual Information Reporting
and Maintaining Certification and Training Program State Plan on CPARD
Annual Burden Hours Per Respondent
Collection Activities

Read/hear rule or any collective instrument
instruction (incl. compliance determination)
Create information
Gather information
Process, compile, review info for accuracy
Complete written forms or other instruments
Record, disclose, display, or report the
information
Store, file, or maintain the information
DPR TOTAL HOURS reporting on CPARD
DPR TOTAL COSTS reporting on CPARD

Program Specialist
$44.05/hr

TOTALS

2

Staff Services
Analyst
$32.83/hr
0

2

1
8
4
2
24

0
4
1
0
1

1
12
5
2
25

2
43 X 44.05 =
$1,894.15
$1,894.15

0
6 X 32.83 =
$196.98
$196.98

(43 X 44.05) +
(6 X 32.83) =
$2,091.13

2

$2,091.13

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Consultation Questions
EPA/OPP ICR - Certification of Pesticide Applicators
Anthrax-Related Products
OMB No: 2070-0029; EPA No: 0155.09

Contact information
Please fill in your name, title, organization, mailing address and contact information (at
least e-mail or phone number) where you prefer to be contacted. We are required to
include your name and contact information in the next Federal Register notice on this
information collection request (ICR).
Name: Stanley Trout
Title: Director of Mfg. Operations
Organization: sBioMed LLC
Address: 1272 So. 1380 West, Orem, UT 84058
E-mail and phone number: [email protected], 801.847.3301

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Questions regarding the ICR document
(11)

Publicly Available Data

Is the information that the Agency seeks available from any public source, or already
collected by another office at EPA or by another agency?
NO. The information that is required of a registrant for an anthrax decontamination
product will only be maintained by the registrant.
If yes, where can one find the data?
(12)

Frequency of collection

Can the Agency collect the information less frequently and still produce the same
outcome? There is no collection schedule with anthrax decontamination products.
Data should be current at any given time. Names of those trained as well as those that
product is sold to should be available at any given notice.
(13)

Clarity of Instructions

Based on the regulations and Agency guidance, is it clear what you are required to do
and how to submit data? If not, what suggestions do you have to clarify instructions?
Do you understand what records need to be kept? Yes, it is quite clear on what
information is required from a registrant for an anthrax decontamination product.
Basically those that are trained and those that buy the product. Those should almost
always be one in the same.
Are submission formats clear and logical?
(14)

Electronic Reporting and Record keeping

Are the Agency web-based reporting tools working well? What improvements would
you suggest for the reporting templates? I believe there are no web based tools for
registrants selling anthrax decontamination products.
What benefits have electronic reporting brought you in terms of burden reduction or
greater efficiency in reporting?
(15)

Burden and Costs

Are the labor rates and burden hour estimates in the ICR supporting statement
accurate? Bear in mind that the estimates include only burden hours and costs
associated with the paperwork involved with this ICR.

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Labor rates and burden hours have accurately been defined with respect to registrants
training and keeping records for those that receive training as well as those that
purchase product.
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.
The Agency has assumed there is no capital cost associated with this activity. Is that
correct?
Are there other costs that should be accounted for that may have been omitted?

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