Attachment D_Consultations_Questions & Responses

EPA ICR No. 0278.11
Docket ID EPA-HQ-OPP-2012-0544

OMB Control No. 2070-0044
ATTACHMENT D

Consultation Questions Regarding an Information Collection Activity:
Notice of Supplemental Distribution of a Registered Pesticide Product
U.S. Environmental Protection Agency

Distributor Company Representative(s) Consulted
Elizabeth Tannehill
Mason Chemical Company
[email protected]
Zofia C. Schmidt
Buckman Laboratories, Inc. (1448)
[email protected]

I.

EPA Questions Asked in Consultation Regarding ICR the Document
(1)

(2)

Publicly Available Data
•

Is the data that the Agency seeks available from any public source, or already
collected by another office at EPA or by another agency?

•

If yes, where can you find the data? (Does your answer indicate a true
duplication, or does the input indicate that certain data elements are available, but
that they don=t meet our data needs very well?)

Frequency of Collection
•

(3)

Can the Agency collect the information less frequently and still produce the same
outcome?

Clarity of Instructions
•

The ICR is intended to require that respondents provide certain data so that the
Agency can utilize them.

•

Based on the instructions (regulations, PR Notices, etc.), is it clear what you are
required to do and how to submit such data? If not, what suggestions do you have
to clarify the instructions?

EPA ICR No. 0278.11
Docket ID EPA-HQ-OPP-2012-0544

(4)

OMB Control No. 2070-0044

•

Do you understand that you are required to maintain records?

•

Are there forms associated with this process? Do you use them? Are they clear,
logical, and easy to complete?

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.

(5)

•

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?

•

Although the Agency does not offer an electronic reporting option because of
CBI-related security concerns at this time, would you be more inclined to submit
CBI on diskette (CD or DVD) than on paper?

•

What benefits would electronic submission bring you in terms of burden
reduction or greater efficiency in compiling the information?

Burden and Costs
•

Are the labor rates accurate?

•

The Agency assumes there is no capital cost associated with this activity. Is that
correct?

•

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.

•

Are there other costs that should be accounted for that may have been missed?

EPA ICR No. 0278.11
Docket ID EPA-HQ-OPP-2012-0544
II.

OMB Control No. 2070-0044

Consultations Responses
Response 1
EPA/OPP ICR – Notice of Supplemental Distribution of a Registered Pesticide Product
U.S. Environmental Protection Agency

Contact Information
Elizabeth Tannehill
Mason Chemical Company
[email protected]

Questions and responses regarding ICR document
(1)

(2)

Publicly Available Data
•

Is the data that the Agency seeks available from any public source, or already
collected by another office at EPA or by another agency?yes

•

If yes, where can you find the data? (Does your answer indicate a true
duplication, or does the input indicate that certain data elements are available, but
that they don=t meet our data needs very well?)
on the state level

Frequency of Collection
•

(3)

Can the Agency collect the information less frequently and still produce the same
outcome? If the agency coordinated with state data then agency would not need to
collect information

Clarity of Instructions
The ICR is intended to require that respondents provide certain data so that the Agency
can utilize them.
•

Based on the instructions (regulations, PR Notices, etc.), is it clear what you are
required to do and how to submit such data? If not, what suggestions do you have
to clarify the instructions?yes

•

Do you understand that you are required to maintain records? yes

EPA ICR No. 0278.11
Docket ID EPA-HQ-OPP-2012-0544
•

(4)

OMB Control No. 2070-0044

Are there forms associated with this process? Do you use them? Are they clear,
logical, and easy to complete?yes

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.

(5)

•

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?yes

•

Are you keeping your records electronically? If yes, in what format?yes scanned

•

Although the Agency does not offer an electronic reporting option because of
CBI-related security concerns at this time, would you be more inclined to submit
CBI on diskette (CD or DVD) than on paper? No – rather submit via internet

•

What benefits would electronic submission bring you in terms of burden
reduction or greater efficiency in compiling the information? Would cut down
time spent filling out forms

Burden and Costs
•

Are the labor rates accurate?yes

•

The Agency assumes there is no capital cost associated with this activity. Is that
correct? yes

•

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.

•

Are there other costs that should be accounted for that may have been missed?no

EPA ICR No. 0278.11
Docket ID EPA-HQ-OPP-2012-0544

OMB Control No. 2070-0044

Response 2
EPA/OPP ICR – Notice of Supplemental Distribution of a Registered Pesticide Product
U.S. Environmental Protection Agency

Contact Information
Zofia C. Schmidt
Buckman Laboratories, Inc. (1448)
[email protected]
Questions and responses regarding ICR document
(1)

Publicly Available Data
•
•

(2)

Frequency of Collection
•

(3)

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
If yes, where can you find the data? (Does your answer indicate a true
duplication, or does the input indicate that certain data elements are available, but
that they don=t meet our data needs very well?)

Can the Agency collect the information less frequently and still produce the same
outcome?
- Unsure

Clarity of Instructions
The ICR is intended to require that respondents provide certain data so that the Agency
can utilize them.
•

•
•

Based on the instructions (regulations, PR Notices, etc.), is it clear what you are
required to do and how to submit such data? If not, what suggestions do you have
to clarify the instructions?
Yes
Do you understand that you are required to maintain records?
Yes
Are there forms associated with this process? Do you use them? Are they clear,
logical, and easy to complete?
- Yes

EPA ICR No. 0278.11
Docket ID EPA-HQ-OPP-2012-0544
(4)

OMB Control No. 2070-0044

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.
•

•
•

•
(5)

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?
Yes
Are you keeping your records electronically? If yes, in what format?
Although the Agency does not offer an electronic reporting option because of
CBI-related security concerns at this time, would you be more inclined to submit
CBI on diskette (CD or DVD) than on paper?
No, because of the volume of documents is relatively small.
What benefits would electronic submission bring you in terms of burden
reduction or greater efficiency in compiling the information?
May saved time (if direct e-mails)

Burden and Costs
•
•
•

•
-

Are the labor rates accurate?
Unsure
The Agency assumes there is no capital cost associated with this activity. Is that
correct?
Yes
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.
N/A
Are there other costs that should be accounted for that may have been missed?
No