Foreign Purchaser Acknowledgment Statement of Unregistered Pesticides (Non-substantive change)

Forms and Documents

Document	Type	Status	Availability
Justification-Non-sub change__2070-0027.docx	Justification for No Material/Nonsubstantive Change	Uploaded 2021-06-30	Repair queued
FPAS Screen Shots__2070-0027.pptx	Supplementary Document	Uploaded 2021-06-30	Repair queued
FPAS Quick Guide__2070-0027.docx	Supplementary Document	Uploaded 2021-06-30	Repair queued

IC Document Collections

IC ID	Collection	Type	Status	Form
24862	Foreign Purchaser Acknowledgment Statement of Unregistered Pesticides		Unchanged
187532	Multilingual Product Labeling for Registered Exported Pesticide Products		Unchanged
187531	Labeling for Unregistered Exported Pesticide Products		Unchanged

ICR Details

OMB Control No: 2070-0027	ICR Reference No: 202106-2070-003
Status: Received in OIRA	Previous ICR Reference No: 201903-2070-002
Agency/Subagency: EPA/OCSPP	Agency Tracking No: 0161.15
Title: Foreign Purchaser Acknowledgment Statement of Unregistered Pesticides (Non-substantive change)
Type of Information Collection: No material or nonsubstantive change to a currently approved collection	Common Form ICR:  No
Type of Review Request: Regular	Date Submitted to OIRA: 07/21/2021

	Requested	Previously Approved
Expiration Date	12/31/2022	12/31/2022
Responses	5,134	5,134
Time Burden (Hours)	16,660	16,660
Cost Burden (Dollars)	0	0

---

Abstract: In order to facilitate the timely submission of FPAS paper documents during the COVID-19 public health emergency and to clear any backlog in submission of FPAS paper documents after the COVID-19 public health emergency, EPA is introducing a temporary, voluntary electronic reporting option. Electronic submissions of FPAS will be done via the Pesticide Submission Portal (“PSP” or “Pesticide Portal” ) which is accessed through EPA’s Central Data Exchange (CDX). Registered CDX users will be able to select “FPAS Submission” for a dropdown menu and upload one or more attachments for their submission. Consistent with paper FPAS submissions, there are no forms for this activity. The EPA does not currently provide a template nor mandate the use of a common form. Therefore, the exporter must develop and use their own FPAS. In preparing the statement, the exporter is free to format the document in any manner as long as it includes all of the required information. The exporter must obtain the signed statement from the foreign purchaser before the pesticide can be shipped. The regulatorily required content for FPAS submissions is described at https://www.epa.gov/pesticides/importing-and-exporting-pesticides.

---

Authorizing Statute(s): US Code: 7 USC 136o Name of Law: Section 17 of the Federal Insecticide, Fungicide, and Rodenticide Act
  

Citations for New Statutory Requirements: None

---

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

---

Federal Register Notices & Comments
60-day Notice:	Federal Register Citation:	Citation Date:
	83 FR 35273	07/25/2018
30-day Notice:	Federal Register Citation:	Citation Date:
	84 FR 11296	03/26/2019
Did the Agency receive public comments on this ICR? Yes

---

Number of Information Collection (IC) in this ICR: 3

IC Title	Form No.	Form Name
Foreign Purchaser Acknowledgment Statement of Unregistered Pesticides
Labeling for Unregistered Exported Pesticide Products
Multilingual Product Labeling for Registered Exported Pesticide Products

---

ICR Summary of Burden

	Total Request	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	5,134	5,134	0	0	0	0
Annual Time Burden (Hours)	16,660	16,660	0	0	0	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: There was no change in the estimated average response time for respondents. There is a decrease of 1,333 hours in the total estimated respondent burden compared with the ICR currently approved by OMB. This decrease reflects a reduction in the annual number of foreign purchaser acknowledgment statements received by EPA (from 3,024 to 2,774), which resulted in a corresponding decrease in the estimated annual burden hours for respondents (from 3,205 to 2,940 hours); and a reduction in the estimated annual burden associated with labeling requirements. The respondent burden associated with labeling requirements for unregistered exported pesticides decreased from 4,888 to 4,480 hours; and from 9,900 to 9,240 hours associated with labeling requirements for registered exported pesticides. The decrease in burden associated with labeling requirements is due to a reduction in the number of respondents per calendar years 2015-2017. Total labor costs for respondents decreased due to a decrease in the estimated number of respondents per calendar year from 2015-2017 and an update to the wage rate estimates, which incorporated higher estimates for benefits than was used in the previous renewal. These changes qualify as adjustments. There were program changes affecting the Agency burden estimate. There is an increase of 421 hours in the total estimated Agency burden compared with that identified in the ICR currently approved by OMB. The total Agency burden increased due to an increase in the EPA estimated hourly burden from 0.17 hours (around 10 minutes) per statement to 0.33 hours (around 20 minutes) per statement. This increase is due to processes added to ensure proper review of FPAS statements before being sent to the importing country. There has also been a change in the system used and steps for storing digital copies of the FPAS. Total labor costs for the Agency also increased due to changes in the wage rates made to reflect current wage rates. The new wage estimates incorporated higher estimates for benefits than was used in the previous renewal. These changes are an adjustment.

---

Annual Cost to Federal Government: $78,932

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

Does this ICR request any personally identifiable information (see OMB Circular No. A-130 for an explanation of this term)? Please consult with your agency's privacy program when making this determination.     No

Does this ICR include a form that requires a Privacy Act Statement (see 5 U.S.C. §552a(e)(3))? Please consult with your agency's privacy program when making this determination.     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? Yes

---

Common Form ICR:  No

---

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: 07/21/2021

---