1 EPA ICR No. 0155.09 OMB Control No. 2070-0029

ATTACHMENT E

Record of Consultations Between the U.S. Environmental Protection Agency and Respondents to the Information Collection Request:

“ Certification of Pesticide Applicators ”

1. Ples Spradley

, Associate Professor – Pesticide Safety Education, University of Arkansas, Division of Agriculture 2. Gary Fish, Program Manager, State of Ma ine, Department of Agriculture, Board of

Pesticides Control 3. Adolfo R. Gallo, Program Sp ecialist ̧ California Departme nt of Pesticide Regulation (DPR), Licensing and Ce rtification Program

For anthrax-related products:

4. Stanley Trout, Director of Mfg. Operations, sBioMed LLC 5. Dr. Jeffry Golden, Co-Founder and Ma naging Member, Clean Earth Technology (CET), LLC. Response was not received fr om Clean Earth Technology.2 Consultation Questions EPA/OPP ICR - Certification of Pesticide Applicators

OMB No: 2070-0029; EPA No: 0155.09



### Contact information

Please fill in your name, title, organization, mailing address and contact information (at least e-mail or phone number) where you prefer to be contacted. We are required to include your name and contact information in the next Federal Register notice on this information collection request (ICR).

Name: Ples Spradley

Title: Associate Professor – Pesticide Safety Education

Organization: University of Arka nsas, Division of Agriculture

Address: 2301 S. University Ave., Little Rock, AR 72204

E-mail and phone number: pspradley@uaex.edu , 501-671-2234



### Questions regarding the ICR document

(1) Publicly Available Data

Is the information that the Agency seeks available from any public source, or already collected by another office at EPA or by another agency?

Not that I am aware of.

If yes, where can one find the data?

(2) Frequency of collection

Can the Agency collect the information le ss frequently and still produce the same

outcome?

In my opinion, no.

(3) Clarity of Instructions

Based on the regulations and Agency guidance, is it clear what you are required to do and how to submit data? If not, what sugge stions do you have to clarify instructions?

Yes.3 Do you understand what records need to be kept?

Yes.

Are submission formats clear and logical?

Yes.

(4) Electronic Reporting and Record keeping

Are the Agency web-based reporting tools working well? What improvements would you suggest for the reporting templates?

Yes, based on my knowledge of CPARD.

What benefits have electronic reporting br ought you in terms of burden reduction or greater efficiency in reporting?

Not applicable to my position.

(5) Burden and Costs

Are the labor rates and burden hour es timates in the ICR supporting statement

accurate? Bear in mind that the esti mates include only burden hours and costs associated with the paperwor k involved with this ICR.

The estimates seem realistic to me.

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.

The Agency has assumed there is no capital co st associated with this activity. Is that

correct?

Yes.

Are there other costs that should be acc ounted for that may have been omitted?

No.4 Consultation Questions EPA/OPP ICR - Certification of Pesticide Applicators

OMB No: 2070-0029; EPA No: 0155.09



### Contact information

Please fill in your name, title, organization, mailing address and contact information (at least e-mail or phone number) where you prefer to be contacted. We are required to include your name and contact information in the next Federal Register notice on this information collection request (ICR).

Name: Gary Fish

Title: Program Manager

Organization: State of Maine, Department of Agriculture, Board of Pesticides Control

Address:28 State House Sta tion, Augusta, ME 04333-0028

E-mail and phone number: gary.fish@maine.gov 207-287-7545



### Questions regarding the ICR document

(1) Publicly Available Data

Is the information that the Agency seeks available from any public source, or already collected by another office at EPA or by another agency? Not that I know of

If yes, where can one find the data?

(2) Frequency of collection

Can the Agency collect the information le ss frequently and still produce the same outcome? Possibly, but it woul d not provide the same pi cture and it would become

outdated faster

(3) Clarity of Instructions

Based on the regulations and Agency guidance, is it clear what you are required to do and how to submit data? If not, what sugge stions do you have to clarify instructions?

Do you understand what records need to be kept? yes5 Are submission formats clear and logical? yes

(4) Electronic Reporting and Record keeping

Are the Agency web-based reporting tools working well? What improvements would you suggest for the reporting templates? yes

What benefits have electronic reporting br ought you in terms of burden reduction or greater efficiency in reporting? easier storage of information

(5) Burden and Costs

Are the labor rates and burden hour es timates in the ICR supporting statement

accurate? Bear in mind that the esti mates include only burden hours and costs associated with the paperwork involved with this ICR. The salaries are high for

Maine

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.

The Agency has assumed there is no capital co st associated with this activity. Is that correct? No, unless the agency/o rganization is extremely small

Are there other costs that should be account ed for that may have been omitted? No6 Consultation Questions EPA/OPP ICR - Certification of Pesticide Applicators

OMB No: 2070-0029; EPA No: 0155.09



### Contact information
Please fill in your name, title, organization, mailing address and contact information (at least e-mail or phone number) where you prefer to be contacted. We are required to include your name and contact information in the next Federal Register notice on this information collection request (ICR).

Name: Adolfo R. Gallo

Title: Program Specialist

Organization: California Department of Pesticide Regulation (DPR), Licensing and Certification Program

Address: 1001 I Street, P. O. Box 4015, Sacramento, CA 95814

E-mail and phone number: agallo@cdpr.ca.gov & 916.445.3895



### Questions regarding the ICR document

(6) Publicly Available Data

Q) Is the information that the Agency s eeks available from any public source, or already collected by another offi ce at EPA or by another agency? A) Yes, the agencies that provide inform ation to DPR for reporting via CPARD could also provide that same information upon request to any interested person or

government agency.

Q) If yes, where can one find the data? A) It can be requested from each agency that provides the information to DPR.

(7) Frequency of collection

Q) Can the Agency collect the information less frequently and still produce the same

outcome? A) Yes; the state reporting agencies can provide accurate and timely information biannually to US EPA. US EPA could stag ger reporting deadlines within the regions to ease reviewing and assessment burdens. Biannual reporting and analysis would have minimal impact on decisions and ac tions regarding states’ programs. We assume that collecting the information less frequently would not adversely impact the funding formula, reduce the c ooperative agreement reimbursement level, or disrupt the cooperative agreement funding process.7 (8) Clarity of Instructions

Q) Based on the regulations and Agency guida nce, is it clear wh at you are required to do and how to submit data? If not, what suggestions do you have to clarify

instructions? A) Yes, for the most part, over the years th e written instructions and guidelines have become clearer to understand. However, a ny annual changes to the CPARD template

should be identified and summarized in a written document and online at the CPARD log in page.

Q) Do you understand what records need to be kept? A) Yes Are submission formats clear and logical? Q) Mostly, yes.

(9) Electronic Reporting and Record keeping

Q) Are the Agency web-based reporting to ols working well? What improvements would you suggest for the reporting templates? A) Yes, for the most part. However, any changes to the CPARD template should be

identified and summarized in a written document sent to eac h SLA CPARD/State Plan manager and also posted online at th e CPARD log in page. These changes would

include different or additi onal reporting requirements, re vised information formats, additional check/mark boxes, more detailed requested information, etc.

Q) What benefits have electronic repor ting brought you in terms of burden reduction or greater efficiency in reporting? A) The CPARD system saves time and e ffort, especially with standardized information format, saves time over the narr ative report format, and time is saved with the “copy and transfer to the next y ear report” feature, which is pretty sweet. (10) Burden and Costs

Q) Are the labor rates and burden hour estimates in the ICR supporting statement

accurate? Bear in mind that the esti mates include only burden hours and costs associated with the paperwor k involved with this ICR. A) Close, but not accurate; our data is presented in Table DPR-1 that follows.

Q) 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. A) Estimate costs are based on estimated staff time and accurate staff costs.

Q) The Agency has assumed there is no capital cost associated with this activity. Is

that correct?8 A) Correct.

Q) Are there other costs that should be accounted for that may have been omitted? A) None to suggest at this time.

Table DPR-1 – DPR Burden and Cost Estimates for Annual Information Reporting and Maintaining Certification and Trai ning Program State Plan on CPARD

Collection Activities Annual Burden Hours Per Respondent TOTALS

Program Specialist $44.05/hr Staff Services Analyst $32.83/hr Read/hear rule or any collective instrument instruction (incl. compliance determination) 2 0 2

Create information 1 0 1

Gather information 8 4 12 Process, compile, review info for accuracy 4 1 5 Complete written forms or other instruments 2 0 2 Record, disclose, display, or report the

information 24 1 25

Store, file, or maintain the information 2 0 2 DPR TOTAL HOURS reporting on CPARD 43 X 44.05 = $1,894.15 6 X 32.83 = $196.98 (43 X 44.05) + (6 X 32.83) =

$2,091.13 DPR TOTAL COSTS reporting on CPARD $1,894.15 $196.98 $2,091.139 Consultation Questions EPA/OPP ICR - Certification of Pesticide Applicators

Anthrax-Related Products

OMB No: 2070-0029; EPA No: 0155.09



### Contact information

Please fill in your name, title, organization, mailing address and contact information (at least e-mail or phone number) where you prefer to be contacted. We are required to include your name and contact information in the next Federal Register notice on this information collection request (ICR).

Name: Stanley Trout

Title: Director of Mfg. Operations

Organization: sBioMed LLC

Address: 1272 So. 1380 West, Orem, UT 84058

E-mail and phone number: stan.trout@sbiomed.com , 801.847.330110 

### Questions regarding the ICR document

(11) Publicly Available Data

Is the information that the Agency seeks available from any public source, or already collected by another office at EPA or by another agency?

NO. The information that is required of a registrant for an anthrax decontamination product will only be maintained by the registrant.

If yes, where can one find the data?

(12) Frequency of collection

Can the Agency collect the information le ss frequently and still produce the same

outcome ? There is no collection schedule w ith anthrax decontamination products. Data should be current at any given time. Na mes of those trained as well as those that product is sold to should be available at any given notice.

(13) Clarity of Instructions

Based on the regulations and Agency guidance, is it clear what you are required to do and how to submit data? If not, what sugge stions do you have to clarify instructions?

Do you understand what records need to be kept? Yes, it is quite clear on what information is required from a registrant for an anthrax decontamination product. Basically those that are trai ned and those that buy the product. Those should almost always be one in the same.

Are submission formats clear and logical?

(14) Electronic Reporting and Record keeping

Are the Agency web-based reporting tools working well? What improvements would you suggest for the reporting templates ? I believe there are no web based tools for registrants selling anthra x decontamination products

.

What benefits have electronic reporting br ought you in terms of burden reduction or greater efficiency in reporting?

(15) Burden and Costs

Are the labor rates and burden hour es timates in the ICR supporting statement

accurate? Bear in mind that the esti mates include only burden hours and costs associated with the paperwor k involved with this ICR.11 Labor rates and burden hours have accurately been defined w ith respect to registrants training and keeping records for those that receive training as well as those that purchase product.

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.

The Agency has assumed there is no capital co st associated with this activity. Is that

correct?

Are there other costs that should be acc ounted for that may have been omitted?