Attachment D

Attachment D- Copy of the 6(a)(2) Consultation Questionnaire
(OMB No. 2070-0039; EPA No. 1204.13)
(rev.4/26/18)

Name:
Date:
(1)

Company:

Publicly Available Data
a) Is the data that the Agency seeks available from any public source, or already
collected by another office at EPA or by another agency?
b) 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?)

(2)

Frequency of Collection
a) Can the Agency collect the information less frequently and still produce the same
outcome?

(3)

Clarity of Instructions
a) The ICR is intended to require that respondents provide certain data so that the
Agency can utilize them.
b) 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?
c) Do you understand that you are required to maintain records?
d) Considering that there is no required submission format, is it difficult to submit
information in ways that are clear, logical and easy to complete?

(4)

Electronic Reporting and Record keeping
Applications for pesticide registration can be submitted electronically, including forms,
studies, and draft product labeling. Applicants need not submit multiple electronic copies
of any pieces of their applications. The Pesticide Submission Portal (PSP) is accessed
through EPA’s Central Data Exchange (CDX) Network and requires user registration.
Registrants currently submitting CDs or DVDs using the e-Dossier downloadable tool or
their own builder tools based on EPA’s XML guidance may use the portal and forego the
courier costs of sending to EPA. OPP encourages electronic submission for FIFRA
section 6(a)(2) data. For more information, see: https://www.epa.gov/pesticideregistration/electronic-submissions-pesticide-applications
1. Do you use the PSP portal for 6(a)(2) data submission?
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2. If yes, do you have any comment on the PSP portal submission process?
3. If you are not using the PSP portal to submit 6(a)(2) data, tell us what process you
are using to submit data to us and why.
(5)

Burden and Costs
a) Are the labor rates accurate?
b) The Agency assumes there is no capital cost associated with this activity. Is that correct?
c) 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.
d) Are there other costs that should be accounted for that may have been missed?

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