Compliance Requirement for Child Resistant Packaging (Renewal)

Forms and Documents

Forms and supporting documents for this ICR

Document	Type	Status	Availability
Attachment_G_Listing of Related Regulations.doc	Supplementary Document	Uploaded 2013-12-05	Available
Attachment F_Calculations Regarding Small Entities.pdf	Supplementary Document	Uploaded 2013-12-05	Available
Attachment E_Worksheet Used to Calculate Labor Costs.pdf	Supplementary Document	Uploaded 2013-12-05	Available
Attachment_D_-_PR_Notice_97-9.pdf	Supplementary Document	Uploaded 2013-12-05	Available
Attachment C_Record of Consultations.pdf	Supplementary Document	Uploaded 2013-12-05	Available
Attachment A_FIFRA section 25.pdf	Supplementary Document	Uploaded 2013-12-05	Available
Attachment B_40 CFR 157.pdf	Supplementary Document	Uploaded 2013-12-05	Available
0616ss11.docx	Supporting Statement A	Uploaded 2014-05-15	Available

IC Document Collections

Information collection document groups

IC ID	Collection	Type	Status	Form
24899	Compliance Requirement for Child-Resistant Packaging		Modified

ICR Details

OMB Control No: 2070-0052	ICR Reference No: 201405-2070-001
Status: Historical Active	Previous ICR Reference No: 201009-2070-002
Agency/Subagency: EPA/OCSPP	Agency Tracking No: 0616.11
Title: Compliance Requirement for Child Resistant Packaging (Renewal)
Type of Information Collection: Extension without change of a currently approved collection	Common Form ICR:  No
Type of Review Request: Regular
OIRA Conclusion Action: Approved without change	Conclusion Date: 07/14/2014
	Date Received in OIRA: 05/28/2014
Terms of Clearance: In accordance with 5 CFR 1320, the information collection is approved for another 3 years.

table that charts list comparision

	Inventory as of this Action	Requested	Previously Approved
Expiration Date	07/31/2017	36 Months From Approved	07/31/2014
Responses	685	0	1,165
Time Burden (Hours)	5,507	0	4,893
Cost Burden (Dollars)	0	0	0

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Abstract: This information collection program is designed to provide EPA with assurances that the packaging of pesticide products sold and distributed to the general public in the United States meets standards set forth by the Agency pursuant to the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA). Registrants must certify to the Agency that the packaging or device meets these standards. There are no forms associated with this information collection activity.

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Authorizing Statute(s): US Code: 7 USC 136w(c)(3) Name of Law: Section 25(c)(3) of the Federal Insecticide, Rodenticide and Fungicide Act
  

Citations for New Statutory Requirements: None

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Associated Rulemaking Information
RIN:	Stage of Rulemaking:	Federal Register Citation:	Date:
	Not associated with rulemaking

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Federal Register Notices & Comments
60-day Notice:	Federal Register Citation:	Citation Date:
	78 FR 59014	09/25/2013
30-day Notice:	Federal Register Citation:	Citation Date:
	79 FR 30604	05/28/2014
Did the Agency receive public comments on this ICR? No

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Number of Information Collection (IC) in this ICR: 1

table that charts list of burden

IC Title	Form No.	Form Name
Compliance Requirement for Child-Resistant Packaging

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ICR Summary of Burden

table that charts list of burden

	Total Approved	Previously Approved	Change Due to New Statute	Change Due to Agency Discretion	Change Due to Adjustment in Estimate	Change Due to Potential Violation of the PRA
Annual Number of Responses	685	1,165	0	0	-480	0
Annual Time Burden (Hours)	5,507	4,893	0	0	614	0
Annual Cost Burden (Dollars)	0	0	0	0	0	0

Burden increases because of Program Change due to Agency Discretion: No

Burden Increase Due to:

Burden decreases because of Program Change due to Agency Discretion: No

Burden Reduction Due to:

Short Statement: The estimated total respondent burden is expected to increase by 614 hours from 4,893 for the previous ICR renewal hours to 5,507 hours for this renewal. The increase is in burden is a result of a number of factors. First, the average burden hours per response increased from 4.20 hours to 8.04 hours per submission. The average burden per response is an average overall all response types. Based on comments received during consultations with stakeholders, EPA increased the burden per response for CRP certifications that do not require data. Second, there has been a change in the distribution of responses among the four response types. The number of responses is expected to decrease from 1,165 in the last ICR approval to 685. Although the estimated number of responses for the current ICR renewal is expected to be significantly less than the last ICR approval, there is a net shift from less-burdensome (CRP certifications without data) to more-burdensome (CRP certifications with data) type responses. This increase is partially due to the expiration of the exclusive use period for certain pesticide chemicals; registrants with products using these chemicals will be required to provide their own CRP test data, which will have to be reviewed for human safety/health risk concerns.

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Annual Cost to Federal Government: $1,528,145

Does this IC contain surveys, censuses, or employ statistical methods? No

Is the Supporting Statement intended to be a Privacy Impact Assessment required by the E-Government Act of 2002? No

Is this ICR related to the Affordable Care Act [Pub. L. 111-148 & 111-152]? No

Is this ICR related to the Dodd-Frank Wall Street Reform and Consumer Protection Act, [Pub. L. 111-203]? No

Is this ICR related to the American Recovery and Reinvestment Act of 2009 (ARRA)? No

Is this ICR related to the Pandemic Response? Uncollected

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Common Form ICR:  No

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On behalf of this Federal agency, I certify that the collection of information encompassed by this request complies with 5 CFR 1320.9 and the related provisions of 5 CFR 1320.8(b)(3).

The following is a summary of the topics, regarding the proposed collection of information, that the certification covers:

(a) It is necessary for the proper performance of agency functions;

(b) It avoids unnecessary duplication;

(c) It reduces burden on small entities;

(d) It uses plain, coherent, and unambiguous language that is understandable to respondents;

(e) Its implementation will be consistent and compatible with current reporting and recordkeeping practices;

(f) It indicates the retention periods for recordkeeping requirements;

(g) It informs respondents of the information called for under 5 CFR 1320.8 (b)(3) about:

(i) Why the information is being collected;

(ii) Use of information;

(iii) Burden estimate;

(iv) Nature of response (voluntary, required for a benefit, or mandatory);

(v) Nature and extent of confidentiality; and

(vi) Need to display currently valid OMB control number;

(h) It was developed by an office that has planned and allocated resources for the efficient and effective management and use of the information to be collected.

(i) It uses effective and efficient statistical survey methodology (if applicable); and

(j) It makes appropriate use of information technology.

If you are unable to certify compliance with any of these provisions, identify the item by leaving the box unchecked and explain the reason in the Supporting Statement.

Certification Date: 05/28/2014

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