Attachment G Consultation

Consultations Conducted for the Renewal of the Pesticide Registration Fee ICR 2013:
OMB Control No.: 2070-0167
EPA ICR No.: 2147.05

Company Name: RegWest Company, LLC
Name of person consulted: Kimberlee Young (formerly: Kim Davis)
Date: August 16, 2013
Q: When preparing your waiver request did you consult the Questions and Answers on the
EPA website (http://www.epa.gov/pesticides/fees/questions/waivers.htm)?
A: Yes.
Q: If yes, did you find it helpful and informative?
A: Yes.
Q: What improvements or clarifications would you like to see?
A: Unless the regulations change, I don’t think improvements or clarifications are needed.
Q: Are you aware of the industry generated form?
A: Yes.
Q: Would you use the industry generated form (http://www.cspa.org/pdf/waiver.pdf)? If
no, please tell us why?
A: I always use the industry-generated form.
Labor Rates:
Q: The current labor rates for this ICR proposal are $120.32 for Management; $77.85 for
Technical; and $44.05 for Clerical. Would you say these labor rates are accurate?
A: Yes.

Q: The current labor burden breakdown (the average amount of time each labor category
might spend on this task) is displayed in Tables 2, 4, 5, 6 in the supporting statement
document. Are these industry averages to high, to low, or just about right for your firm?
A: Too high.

Size of your Firm:
Does your firm hold 5 or less pesticide registrations, 6-10 registrations, 11-20 registrations,
21 -50 registrations, or over 50 registrations? (See Tables 1 and 2 of the supporting
statement).
A: RegWest Company, LLC does not hold any registrations; however, we oversee more than 50
registrations held by our clients.
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Comments:
Q: Did we miss anything?
A: Not that I can think of.

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Consultations Conducted for the Renewal of the Pesticide Registration Fee ICR 2013:
OMB Control No.: 2070-0167
EPA ICR No.: 2147.05

Company Name: Technology Sciences Group Inc.
Name of person consulted: Amy Plato Roberts, Senior Regulatory Consultant
Date: August 7, 2013
Q: When preparing your waiver request did you consult the Questions and Answers on the
EPA website (http://www.epa.gov/pesticides/fees/questions/waivers.htm)?
A: Yes.
Q: If yes, did you find it helpful and informative?
A: Yes, but it would be helpful to see a practical example posted on the website.
Q: What improvements or clarifications would you like to see?
A: Inclusion of a practical example. Often for a company that is going through the process for
the first time there is more information needed that one would think by following the guidance.
Typically a first time through the process involves the industry generated form, a letter
confirming the corporate structure, information explaining affiliates, if any, tax forms reporting
revenue or a letter explaining revenue, and tax forms or a letter explaining the number of
employees. It would be helpful to see a mocked up response for a company that has tax forms
and for a company that does not and must provide explanations. An example of a company that
cannot rely solely on tax forms for reporting revenue would be one that has sales other than
pesticides and the pesticide sales have to be broken out or a foreign entity that does not use US
tax forms for revenue.
Q: Are you aware of the industry generated form?
A: Yes.
Q: Would you use the industry generated form (http://www.cspa.org/pdf/waiver.pdf)? If
no, please tell us why?
A: Yes, we do use the industry generated form as it is a helpful way to tie together the different
pieces of a fee waiver request. Typically it is included with all the other documentation.
Labor Rates:
Q: The current labor rates for this ICR proposal are $120.32 for Management; $77.85 for
Technical; and $44.05 for Clerical. Would you say these labor rates are accurate?
A: Not able to comment.

Q: The current labor burden breakdown (the average amount of time each labor category
might spend on this task) is displayed in Tables 2, 4, 5, 6 in the supporting statement
document. Are these industry averages to high, to low, or just about right for your firm?
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A: Yes, that seems accurate.

Size of your Firm:
Does your firm hold 5 or less pesticide registrations, 6-10 registrations, 11-20 registrations,
21 -50 registrations, or over 50 registrations? (See Tables 1 and 2 of the supporting
statement).
A: We represent a multitude of firms that hit all of the options in Tables 1 and 2.

Comments:
Q: Did we miss anything?

A: Do not believe so.

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