0161.17 Attach B- Consultation

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EPA ICR NO. 0161.17

OMB CONTROL NO. 2070-0027
Attachment B: Consultation Summary
Stakeholder Engagement

Greetings,
I am with the Office of Pesticide Programs/Worker Protection and Intergovernmental Affairs
Branch at the U.S. Environmental Protection Agency (EPA). I am writing to you today to
request your assistance on an Information Collection Request (ICR). For the past few months,
EPA has been updating the ICR for the Foreign Purchaser Acknowledgement Statement of
Unregistered Pesticides. As part of our consultation process, we are requesting comments from
industry on this ICR renewal proposal.
Our records indicate that in the past you may have participated as a representative of your
company in responding to the EPA’s questions on this ICR. The questionnaire should only take
about 15 minutes and your response is voluntary. Should you choose to respond, we ask that you
do not submit any sensitive, confidential business information or business phone numbers as part
of your response. For your convenience, an ICR supporting statement, and an ICR questionnaire
is attached.
You may complete the ICR questionnaire and submit the completed questionnaire to the EPAHQ-OPP-2021-0749 at Regulations.gov or to me directly, by January 23rd.
We greatly appreciate your time and participation.
Stakeholders Contacted:
1. FMC Corporation
2. Koch Agronomic Services LLC
3. Kocide LLC
4. Neogen Corporation
5. Syngenta

Stakeholder Response: No comments.

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OMB CONTROL NO. 2070-0027

Consultation Questions
Foreign Purchaser Acknowledgment Statement of Unregistered Pesticides; Renewal
(1) 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 do not meet our data needs very well?)

(2) Frequency of Collection
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?

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

(4) 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.
$

What do you think about electronic alternatives to paper-based records and data
submissions?

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

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

(5) Burden and Costs
A. Is the identified NAICS code representative of your industry?

B. The Agency assumes there is no capital cost associated with this information collection
activity. Is that correct? If not, please describe the investment associated with this
activity.

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.

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OMB CONTROL NO. 2070-0027

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

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