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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 Maine, Department of Agriculture, Board of 

Pesticides Control 

3. Adolfo R. Gallo, Program Specialist ̧ California Department of Pesticide Regulation 

(DPR), Licensing and Certification Program 

For anthrax-related products: 

4. Stanley Trout, Director of Mfg. Operations, sBioMed LLC 

5. Dr. Jeffry Golden, Co-Founder and Managing Member, Clean Earth Technology 

(CET), LLC. 

Response was not received from Clean Earth Technology. 
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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 Arkansas, 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 less 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 suggestions do you have to clarify instructions? 

Yes. 
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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 brought 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 estimates in the ICR supporting statement 

accurate? Bear in mind that the estimates include only burden hours and costs 

associated with the paperwork 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 cost associated with this activity. Is that 

correct? 

Yes. 

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

No. 
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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 Station, 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 less frequently and still produce the same 

outcome? Possibly, but it would not provide the same picture 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 suggestions do you have to clarify instructions? 

Do you understand what records need to be kept? yes 
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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 brought 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 estimates in the ICR supporting statement 

accurate? Bear in mind that the estimates 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 cost associated with this activity. Is that 

correct? No, unless the agency/organization is extremely small 

Are there other costs that should be accounted for that may have been omitted? No 
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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 seeks available from any public source, or 

already collected by another office at EPA or by another agency? 

A) Yes, the agencies that provide information 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 stagger reporting deadlines within the regions 

to ease reviewing and assessment burdens. Biannual reporting and analysis would 

have minimal impact on decisions and actions regarding states’ programs. We 

assume that collecting the information less frequently would not adversely impact the 

funding formula, reduce the cooperative agreement reimbursement level, or disrupt 

the cooperative agreement funding process.
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(8) Clarity of Instructions 

Q) Based on the regulations and Agency guidance, is it clear what 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 the written instructions and guidelines have 

become clearer to understand. However, any 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 tools 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 each SLA CPARD/State 

Plan manager and also posted online at the CPARD log in page. These changes would 

include different or additional reporting requirements, revised information formats, 

additional check/mark boxes, more detailed requested information, etc.

Q) What benefits have electronic reporting brought you in terms of burden reduction 

or greater efficiency in reporting? 

A) The CPARD system saves time and effort, especially with standardized 

information format, saves time over the narrative report format, and time is saved 

with the “copy and transfer to the next year 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 estimates include only burden hours and costs 

associated with the paperwork 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? 
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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 Training 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 $2,091.13 

 
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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, 801.847.3301 
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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 less frequently and still produce the same 

outcome? There is no collection schedule with anthrax decontamination products. 

Data should be current at any given time. Names 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 suggestions 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 trained 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 anthrax decontamination products. 

What benefits have electronic reporting brought you in terms of burden reduction or 

greater efficiency in reporting? 

(15) Burden and Costs 

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

accurate? Bear in mind that the estimates include only burden hours and costs 

associated with the paperwork involved with this ICR. 
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Labor rates and burden hours have accurately been defined with 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 cost associated with this activity. Is that 

correct? 

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