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SUPPORTING STATEMENT FOR

AN INFORMATION COLLECTION REQUEST (ICR)

1. IDENTIFICATION OF THE INFORMATION COLLECTION

1(a) Title of the Information Collection:

Certification of Pesticide Applicators

OMB No: 2070-0029; EPA No: 0155.12

1(b) Short Characterization/Abstract

The Environmental Protection Agency (EPA) administers certification programs for 

pesticide applicators under section 11 of the Federal Insecticide, Fungicide, and Rodenticide Act 

(FIFRA). FIFRA allows EPA to classify a pesticide as “restricted use” if the pesticide meets 

certain toxicity or risk criteria. This information collection request (ICR) addresses the 

paperwork activities performed by various EPA-authorized agencies of States and Indian tribal 

governments as well as Federal agencies (collectively referred to in this document as “authorized 

agencies”) and activities performed by firms and individual applicators in the course of training 

and certifying persons who apply restricted use pesticides. Because of their potential to harm 

human health or the environment, restricted use pesticides may be purchased and applied only by 

a “certified applicator” or by a person under the direct supervision of a certified applicator. A 

person must meet certain standards of competency to become a certified applicator; these 

standards are met through completion of a certification program or test. Authorized agencies 

administer certified applicator programs within their jurisdictions, but each agency’s certification 

plan must be approved by EPA before it can be implemented. In areas where no authorized 

agency has jurisdiction, EPA may administer a certification program directly, called a Federal 

program.

This ICR also addresses how registrants of certain pesticide products are expected to 

perform specific, special paperwork activities, such as training and recordkeeping, in order to 

comply with the terms and conditions of the pesticide registration (e.g., registrants of anthraxrelated pesticide products that assert claims to inactivate Bacillus anthracis (anthrax) spores). 

Paperwork activities associated with the use of such products are conveyed specifically as a 

condition of the registration.

2. NEED FOR AND USE OF THE COLLECTION

2(a) Need/Authority for the Collection

EPA needs the data from this information collection activity to ensure that restricted use 

pesticides (RUPs) are only purchased and applied by certified applicators, or individuals under 

their direct supervision. A certified applicator is a person who has demonstrated competency in 
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the safe handling and application of RUPs, and who has received certification to that effect. This 

collection also makes records of specific RUP applications available for investigations or 

enforcement actions concerning possible misuses or poisoning incidents. 

The authority for this information collection activity is provided under sections 3(d) and 

11 of FIFRA and 40 CFR part 171. Section 3(d) of FIFRA authorizes EPA to classify registered 

pesticides as either general use or restricted use (see Attachment A). RUPs are those that, absent 

additional regulatory restrictions, may cause unreasonable adverse effects on people or the 

environment. Pesticides classified as restricted use may only be used by a certified applicator, or 

by a person under the direct supervision of a certified applicator. Section 11(a) of FIFRA grants

EPA the authority to prescribe standards for the certification of RUP applicators (see Attachment 

B). Under Section 11(a)(2) of FIFRA, EPA approves authorized agency certification programs. 

While the bulk of the certification programs are implemented by State agencies (all 50 States are 

authorized), a few tribes and Federal agencies are also authorized; additionally, EPA has 

authority to directly administer Federal certification programs in areas where there is no 

authorized agency program. The regulations for the certification program in 40 CFR part 171

include procedures for certification programs for States, Federal agencies, Indian tribes, or U.S. 

territories who wish to develop and implement their own certification plans and programs, after 

obtaining EPA approval (see Attachment C). 

In the case of certain RUPs, like anthrax-related products, the Agency needs the data to 

ensure that the sale and use of registered anthrax-related products is limited to persons who are 

trained in the safe and effective use of such products. For anthrax-related products, the Agency 

is concerned with the high risks involved in treating areas/objects contaminated with highly 

virulent and persistent anthrax spores. Reducing these risks, which include exposure to the 

anthrax spores, the pesticide product, and any areas ineffectively decontaminated, requires that 

treatments be performed correctly and with the approval of responsible regulatory authorities. 

To minimize the risks of improper and unsafe applications, the Agency is limiting availability of 

anthrax-related products to those persons or companies who have a legitimate need. With this 

approach, these products will not to be sold, offered for sale, or distributed to the general public. 

The Agency is also requiring purchasers of anthrax-related products to be specifically trained in 

the product application (to assure it is done safely and effectively) and in the overall process of 

decontamination in response to an intentional attack with bacterial spores. Training must be 

repeated every two years. Registrants must maintain records of persons who have been trained 

and entities to which the product has been sold or distributed. Normally, records will not be 

submitted to EPA unless EPA requests them, such as in the event of a bioterrorism attack or in 

conjunction with enforcement investigations.

EPA issued a Pesticide Registration Notice (PR Notice), on September 3, 2008, (73 FR 

51467) informing registrants that certain conditions of registration will apply to anthrax-related 

products. The PR Notice, titled “Guidance for Antimicrobial Pesticide Products With AnthraxRelated Claims,” (Attachment D) specifies that products claiming to inactivate anthrax spores 

should be: (a) supported by specific sporicidal efficacy studies that are acceptable to EPA; and 

(b) subject to specific terms and conditions of registration that limit the use of these products to 

specifically trained persons. The training and reporting information activities for registrants of 

anthrax-related products will not be imposed on respondents until a registration is granted.
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2(b) Practical Utility/Users of the Data

EPA uses annual reports from the authorized agencies as a monitoring tool to develop 

overall data on pesticide activities for OMB, Congress, and others; to distribute EPA grant funds 

to participating authorized agencies; to target enforcement activities; and to revise certification 

and training program emphasis and requirements. 

In a Federal program, persons applying for pesticide applicator certification use a form to 

submit vital contact and identification information such as name, date of birth, and address, and 

for verification of identity and to schedule applicators for certification or recertification. This 

data is necessary to differentiate between two individuals who may share the same name, to 

ensure that RUP applications are only carried out by or under the supervision of persons who 

have demonstrated competence in their proper use. Authorized agencies use their State or tribal 

authority to obtain this information.

Federal certification programs require dealers to maintain sales records for RUPs. Dealer 

records are necessary for EPA to ensure that access to RUPs is limited to certified applicators. 

State-administered (or authorized agency) certification programs use State authority to require 

dealers to maintain sales records for RUPs, and are not included in this ICR’s paperwork burden

estimates. RUP dealers are required to report and update their names and addresses with the 

pesticide regulatory agency for enforcement purposes. All 50 States in the U.S. currently run 

their own Pesticide Application Certification programs, and dealership information for the States 

is no longer reportable to EPA. In 2014, with the implementation of an EPA-administered 

Applicator Certification program for Indian Country, and for Navajo Nation, dealership name 

and address must be reported to the appropriate EPA Regional offices.

EPA requires a record of each application of a RUP by a certified commercial applicator 

under federally-run programs (such as the Indian Country programs). EPA monitors these 

records to assure that RUPs are used only by, or under the direct supervision of, certified 

applicators, and to ensure that pesticide labeling requirements are adhered to by applicators.

This is done by requiring applicators to record details of the RUP application. Without these

records it would be difficult to successfully enforce against misuse, or investigate accidents or 

poisoning incidents.

RUP application records are also required for certified commercial applicators under 

programs run by states or other authorized agencies. These records are monitored to assure that 

RUPs are used only by, or under the supervision of, properly trained and certified applicators and 

to ensure that pesticide labeling requirements are adhered to by applicators. This is done by 

requiring applicators to record the application (e.g., amounts, locations, and dates) of RUPs. 

Without these records it would be difficult to successfully enforce against misuse and ensure 

proper training and supervision of uncertified applicators.

For anthrax-related products, EPA and other authorized agencies (e.g., Department of 

Homeland Security, Department of Defense, and other Federal and State agencies) will use the 

recorded information to carry out decontamination activities and to conduct enforcement 
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investigations, if needed, in the event of a bioterrorism attack. 

The required registrant training will help assure that applications of anthrax-related 

products are performed safely, effectively and in accordance with the requirements of Federal, 

State and local authorities. The utility of records kept by registrants on trained persons and 

persons to whom anthrax-related products are sold is twofold:

 EPA and other responsible agencies will be able to know who is qualified to buy and use 

these products and thereby be able to carry out effective and timely decontamination 

activities in the event of a bioterrorism attack; and

 Human health and the environment will be protected because only persons who are 

properly trained will be able to apply these products.

3. NON DUPLICATION, CONSULTATIONS, AND OTHER COLLECTION 

CRITERIA

3(a) Non duplication

EPA is the only Federal agency with the authority to certify applicators of restricted use 

products. However, the United States Department of Agriculture (USDA) also has regulations 

which impact certified applicators. USDA has regulations which require private applicators to 

maintain records regarding the application of RUPs. The records required by USDA under 7 

CFR 110 are more specific than those required by EPA under 40 CFR 171.

FIFRA prohibits EPA from requiring private applicators to keep records or make reports, 

so there is no duplication of recordkeeping with regard to private applicators. EPA only requires 

recordkeeping for commercial applicators. Consequently, no duplication of requirements exists.

To prevent duplication and facilitate authorized agency reporting, EPA permits 

authorized agencies to use grant reports in lieu of separate annual reports to EPA, and authorized 

agencies may amend their plan with an addendum. 

No other Federal, State, or tribal government agency requires that registrants conduct 

training for anthrax-related products, or that registrants keep information on persons trained or to 

whom anthrax-related products have been sold or distributed. 

3(b) Public Notice Required Prior to ICR Submission to OMB

In proposing to renew this ICR, EPA is publishing a Federal Register Notice that 

provides a 60-day public notice and comment period.

3(c) Consultations

During the development of this renewal ICR, EPA staff will contact appropriate stakeholders and 
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ask them for their assessment of the regulatory burden estimates expressed by the Agency in this 

ICR. A summary of these consultations will be provided in the supporting statement during the 

second comment period (Attachment E).

3(d) Effects of Less Frequent Collection

Authorized agencies’ reports on certification program activities are submitted to EPA

annually, which is a minimal reporting period. Most annual reporting information required 

under the regulation is contained in authorized agencies’ annual grant report to EPA, and can be 

submitted as a joint package. Budget requests and the distribution of cooperative agreement 

funds are also done on an annual basis. The annual report data is used to support budget requests 

and to apportion cooperative agreement funds. Less frequent collection of information would be 

less efficient for overall reporting by authorized agencies. In addition, less frequent collection of 

information would not allow EPA to distribute these funds in the most equitable manner, as data 

demonstrating need would not be current.

For anthrax-related products, the information kept by registrants on certification, training 

and records regarding the persons to whom the product was sold will be requested only as 

needed (such as for an enforcement investigation), which should be very infrequently. 

Accordingly, less frequent collection of data would not meet the EPA’s needs.

3(e) General Guidelines

FIFRA section 11(a)(1) requires that EPA use a form for applicators to apply for 

certification whenever the Agency administers the Certified Pesticide Applicator program in the 

place of a program administered by an authorized agency. The two forms used for this collection 

activity are EPA Form 8500-17-N, Request for Pesticide Applicator Certification in Navajo 

Indian Country (Attachment F) for use in Navajo Indian Country, and EPA Form 8500-17,

Request for Pesticide Applicator Certification in Indian Country (Attachment G) to be used 

nationally for all Indian Country except Navajo. In Navajo Indian Country, the previous form 

will continue to be used. The recordkeeping activities briefly described herein will not exceed 

OMB’s guideline that agencies not require records to be retained for more than 3 years (5 CFR 

1320.5(d)(2)(iv)). 

3(f) Confidentiality

The activities or records proposed in this information collection do not include any 

confidential business information (CBI) and will not involve any confidentiality concerns or 

information.

3(g) Sensitive Questions

One item of information of a sensitive or private nature that is requested on applicator 

certification forms in conjunction with this collection activity is dates of birth. This information 

collection activity complies with the provisions of the Privacy Act of 1974 and OMB Circular A108 (as amended), “Responsibilities for the Maintenance of Records about Individuals by 
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Federal Agencies.”

4. THE RESPONDENTS AND THE INFORMATION REQUESTED

4(a) Respondents/NAICS codes

The North American Industrial Classification System (NAICS) code for respondents 

participating in the data collection activity is noted here:

Applicators on Farms: 

111 Crop Production

112 Animal Production

Commercial Services Applicators:

561710 Exterminating and Pest Control Services

Administration of Certification Programs by States/Tribal Lead Agencies:

924110 Environmental protection program administration

926140 Pest control programs, agricultural, governmental

Pesticide Dealers (only for EPA-administered programs):

444220 Retail Nursery, Lawn, and Garden Supply stores

424910 Agricultural chemicals merchant wholesalers

Pesticide and Other Agricultural Chemical Manufacturing: 

32532 Individuals or entities engaged in activities related to the registration of a 

pesticide product

4(b) Respondent Activities

(i) Information Collections (ICs)

The respondent activities covered in this ICR have been organized according to 

the following ICs in the electronic ICR submission system (ROCIS):

 Annual Reports

 Application for Federal Pesticide Applicator Certification

 Recordkeeping by Federally-Certified Commercial Applicators (RUPs)

 Recordkeeping by Commercial Applicators (RUPs)

 Recordkeeping by Restricted Use Pesticide Dealers in Indian Country

 Reporting by Restricted Use Pesticide Dealers in Indian Country

 Training of Some Federally-Certified Private Applicators

 Submission of Anthrax-Related Training and Examination Materials by 

Registrants
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 Records for Anthrax-Related Training and Sales/Distribution by 

Registrants

 (ii) Data items, including reporting and recordkeeping requirements

Annual Reporting by Authorized Agencies on Certification and Training Programs

Annual reports are required from States, Indian tribes, and Federal agencies with EPAapproved certification plans. These authorized agencies must develop reports based on the 

requirements in the regulations, including information on their respective program activity, such 

as the number, type, and category of applicators certified and recertified, and any significant 

changes to their plans. 

Dealer Reporting in Federal (EPA-administered) Programs Indian Country

The regulations require dealers under Federal programs to report to EPA the business 

name as well as the name and address for each dealership. The report must only be submitted 

once, but updated information must be submitted if the dealership information changes. This 

information is used for inspection and enforcement purposes. 

Application for Certification in EPA-administered Programs in Indian Country

In Federal programs, regulations require that an application form (EPA Form 8500-17-N, 

Request for Pesticide Applicator Certification in Navajo Indian Country (Attachment F); and

EPA Form 8500-17, Request for Pesticide Applicator Certification in Indian Country; (see 

Attachment G) be completed for persons seeking certification or recertification. The forms are 

necessary for EPA to certify and recertify applicators, by obtaining vital information on certified 

applicators such as name, date of birth address, and type and category of certification. 

EPA administers a Federal program (for both private and commercial applicators)

throughout Indian Country nationally during this ICR renewal cycle; one of the application 

forms listed above must be submitted to obtain certification. This program expanded on an 

existing program to certify applicators in Navajo Indian Country. Applicators with current 

certification from an authorized agency will be eligible for certification in Indian Country with 

proof of certification and a completed form. Private applicators will also be given the option to 

complete training and submit a completed form in lieu of a current existing certification. 

Private Applicator Training – Federal Programs

In accordance with FIFRA Section 11(2), and 40 CFR 171.11(d)(1), EPA has developed 

a training program that private applicators can take to obtain training, as described in the 

regulations, as well as submit the completed form in order to obtain their certification. This 

training is not required since these applicators still have the option to submit proof of current 

certification from an authorized agency with a completed form to receive their federal 

certification (see Attachment G).
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Dealer Recordkeeping in Federal (EPA-administered) Programs in Indian Country

The regulations require dealers under Federal programs to keep records of the sale of 

RUPs for 24 months. Dealer records are maintained at the pesticide dealership, and are not 

routinely submitted to EPA; however, they may be collected as part of an investigation or 

enforcement action. This is necessary for EPA to ensure that access to RUPs is limited to 

certified applicators, or those under their direct supervision. Without the ability to limit access to 

RUPs, there would be little purpose in certifying applicators or classifying pesticides as restricted 

use. This provision is solely intended to provide EPA with the authority to impose dealer 

recordkeeping in entities with EPA-administered programs. Programs administered by 

authorized agencies must use their own laws and regulations to require dealers to maintain 

records of RUP sales. 

Commercial Applicator Records of RUP Use – Federal Programs

Commercial applicators under EPA-administered programs must generate records on the kinds, 

amounts, uses, dates and places of RUP applications immediately after the application is 

complete. Specifically, EPA requires commercial applicators to record the following 

information: the name and address of the person for whom the pesticide was applied; the location 

of the application; the target pest(s); the specific crop or commodity, as appropriate; the name 

and registration number of the pesticide applied; the amount applied and percent active 

ingredient per unit of pesticide used; and the type and amount of leftover pesticide disposed of 

with the method and location of disposal. Records must be retained for two years. Records are 

not required to be submitted, but they must be made available to EPA or officials of authorized 

agencies upon request. Records collected may become part of an enforcement action or 

investigation.

Commercial Applicator Records of RUP Use – Programs under Authorized Agencies

Commercial applicators under programs administered by authorized agencies must 

generate records on RUP applications immediately after the application is complete. In 

programs administered by authorized agencies, the information recorded includes what EPA 

requires (described above in Federal programs) as well as any requirements by the authorized 

agency. 

Records are not required to be submitted, but they must be made available to EPA or 

officials of authorized agencies upon request. Records collected may become part of an 

enforcement action or investigation.

Anthrax-Related Products: Training and Examination Materials

Registrants of anthrax-related products develop training and examination materials and 

submit them to EPA as part of the application for registration or amendment for EPA’s review 

and approval. At a minimum, these materials will include:

 Characteristics of and human health hazards posed by B. anthracis spores;
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 Personal Protective Equipment (PPE) appropriate for protection against both B. anthracis

spores and the pesticide product itself;

 Detailed instructions for safe and effective use of the pesticide product and any 

associated equipment;

 Detailed review of all steps involved in the decontamination process as provided in 

guidance from Federal agencies as well as review of applicable federal statutory and 

regulatory requirements and guidance; and

 A written examination.

Registrants will use the examination to assess whether the trained applicator's 

competency on the above issues is acceptable.

Anthrax-Related Products: Records of Persons Trained by the Registrant

Registrants of anthrax-related products will keep records of the persons who complete 

training on the use of their products. Such information would include, at a minimum, the 

person’s name, address, telephone number, and date of completion of training. 

Anthrax-Related Products: Records of Persons to Whom Registrant Sells/Distributes 

Product

Registrants of anthrax-related products will keep records of the persons/entities to whom 

they sell or distribute their products. Such information would include, at minimum, the person’s 

or entity’s name, address, telephone number, date, and amount of product. 

 (iii) Respondent Activities

Typically, authorized agencies respondents will perform the following activities:

Activity Detail

Read rules or other instructions Read applicable regulations, 40 CFR 171, grant requirements, and 

other applicable requirements

Receive Training Administered by EPA-approved program or EPA

Create information Document activities/applications

Gather information Collect records needed to develop annual report

Review Review information for accuracy

Complete written forms or other 

instruments

Extract data from records and compile into reporting format

Record, disclose, display, or 

report the information

Compile report and submit. Record maintenance for preparation of 

the next annual report, such as grant reports and hard copy and 

computer records of data required in the annual report.

Store, file, or maintain 

information.

Store and retain records.

A typical registrant of an anthrax-related product will perform the following activities:
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Activity Detail

Read rules or other instructions Read applicable regulations (40 CFR 152) and guidance (PR 

Notices, etc.) 

Develop training & exam, and 

recordkeeping method

Document development of materials and recordkeeping methods

Review Review information for accuracy

Submit training and exam 

materials to EPA

Compile training and exam materials and submit to EPA

Gather and review information Collect and review recordkeeping information

Submit recordkeeping

information, if requested.

Compile report and submit, if requested. 

Record, store, file, or maintain 

information.

Record, store and retain records.

5. THE INFORMATION COLLECTED - AGENCY ACTIVITIES, COLLECTION 

METHODOLOGY, AND INFORMATION MANAGEMENT

5(a) Agency Activities

In continuing this collection for Federal certification programs and authorized agencies, 

EPA will:

- Prepare reports (EPA Regions for Indian Country). For this, EPA Regional offices will 

prepare and submit reports for the Federal plans in Indian Country.

- Answer respondent questions.

- Review data submissions.

- Record data submissions.

- Develop/maintain a master database for data submissions.

- Reformat and distribute data.

- Store data.

- Administer training.

For anthrax-related products, EPA will:

- Answer respondent questions.

- Review training and examination materials.

- Record data.

- Maintain data.

- Store data.
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5(b) Collection Methodology and Management

Authorized agencies: Annual reports from authorized agencies are required. EPA 

allows respondents to use their end-of-year grant reporting to fulfill the annual report 

requirement under this collection program to the extent that information contained in such grant 

reports satisfies 40 CFR part 171 requirements. Certain minor reporting elements which may be 

outside the scope of the grant reports may be provided in whatever fashion the respondent finds 

most convenient and least burdensome. The information required under this program is 

generally included in the grant reports as a 2-3 page addendum to that report. A web-based 

template for electronic completion and submission of the annual reports (Certification Plan and 

Annual Reporting Database, available at 

http://cpard.wsu.edu/login.aspx?ReturnUrl=%2fDefault.aspx) has been used by all states since 

2006. EPA does not require the submission of dealer records or commercial applicator records, 

but rather requires that they furnish records for inspection and copying upon request. 

Dealership information: As of a few years ago, all 50 States in the U.S. run their own 

Pesticide Application Certification programs, and dealership information for the States is no 

longer reportable to EPA. With the implementation of the Federal Certification plan for Indian 

Country in 2014, however, RUP dealers under this program are required to report each 

dealership’s name and address to the appropriate EPA Regional offices. There are currently 10 

RUP dealers under this EPA-administered program. 

Applicators: The applicator certification application form is used as an initial reference 

point for potential certified applicators in Federal programs. In addition to basic questions about 

the certification desired, the forms require identification information such as name, address, date 

of birth. Federal certification program applicants mail completed forms to the respective EPA 

Regional office, which compiles and maintains data on program operations. The public may 

access information about the program and its operations data through the appropriate EPA 

Regional office. Contact information can be found in the instructions section of the Federal 

certification form.

Private applicators in the Federal plan now have the option of taking an EPA-developed 

course, then use an auto-generated code provided after their classes end to fill in the form to 

attest that they have completed the course.

Anthrax-related materials: Training materials submitted by registrants will be handled 

like any other registration data submissions. That is, each document will be assigned a Master 

Record Identification (MRID) number, converted to an electronic copy, and stored in EPA’s 

existing data library. Applicable records for sale, use and training shall be available on site for 

inspection as needed. 

5(c) Small Entity Flexibility

This information collection applies specifically to individuals who are certified 

applicators. EPA believes that the records required of certified pesticide applicators and their 
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employees are minimal and would generally be kept for the applicators’ own use even in the 

absence of this regulation. In Federal programs for Indian Country, where EPA administers the 

certification program, dealers are also required to keep records. EPA does not require the 

submission of records kept by dealers or commercial applicators, but rather requires that they 

furnish records for inspection and copying upon request.

Most affected entities (certified applicators, pesticide dealers) are small entities. The 

information collected and the recordkeeping required is the minimum required by regulation and 

that is necessary to implement a successful certification program.

Pursuant to FIFRA Section 11(a)(2), the optional training program that EPA has 

developed does not require that applicators take examinations for private pesticide application 

certification applicants. In lieu of taking this optional training, applicants for private applicator 

certification still have the option to submit proof of current certification from an authorized 

agency with a completed form to receive their federal certification

For anthrax-related products, regulations apply specifically to registrants, most of whom 

are likely to be small entities. EPA believes that the records required of registrants are minimal. 

The information collected and the recordkeeping is the minimum necessary to meet the 

conditions of registration described in the PR Notice: Guidance for Antimicrobial Pesticide 

Products with Anthrax-Related Claims.

5(d) Collection Schedule

There is no set collection schedule for commercial applicators. Commercial applicators 

must generate records on the kinds, amounts, uses, dates, and locations of RUP applications 

immediately after pesticide application, and are required to maintain these records for two years. 

Similarly, dealer records of RUP sales are required to be maintained for two years. 

Although the commercial applicator records and the dealer records are maintained locally and 

are not required to be submitted to EPA or the authorized agencies, they must be made available 

for EPA or authorized agency officials upon request. Records collected may become part of an 

investigation or enforcement action. Commercial applicators in EPA-administered programs 

must also submit an application form for certification or recertification, whenever needed.

Authorized agencies with an EPA-approved plan to administer their own applicator 

certification program must submit a report annually. The annual reporting period allows for 

efficiency in authorized agencies as most required information is contained in their end-of-year 

grant report, which can be submitted as a joint package. The annual reporting cycle also 

facilitates equitable apportionment of cooperative agreement funds to authorized agencies, based 

on data submitted.

There is no collection schedule for any data for anthrax-related products. Training and 

examination materials are only submitted with the application for registration or amendment. 

Information about training, sale, and distribution of anthrax-related products, including to whom 

product is sold, is not submitted unless EPA requests it, which would likely be infrequently.
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6. ESTIMATING THE BURDEN AND COST OF COLLECTION

6(a) Estimating Respondent Burden

Authorized Agencies’ Reporting for Certification and Training Programs

Authorized Agencies’ reports on certification and training programs: EPA based the 

respondents’’ burden hour estimates on experience with and knowledge of the Certification and 

Training Program; Regional contacts and budget staffing records of the Regional offices; and 

information obtained from the consultation process, USDA, authorized agencies, and other 

resources. The total annual burden for EPA’s State, Federal, and Tribal partners (authorized 

agencies) to report on certification and training programs is estimated to be 4,409 hours, with an 

average annual burden of 77.4 hours for each of the 57 participating entities (see Table 1). The 

average per-State burden was based on several estimates provided to EPA by participating 

States.

Certification and/or training applications under EPA-Administered Program

EPA now administers two separate programs under the Federal certification plan for 

Indian Country throughout the US: a Federal plan for Navajo Indian Country, and a national 

Federal plan for all other Indian Country. The national plan was implemented beginning 

February 6, 2014 and the number of applicators utilizing the program is not yet known. The 

burden and cost estimates below represent a single estimate for both Federal plans in Indian 

Country throughout the U.S. Although the plan for Navajo Indian Country has been in effect for 

several years, and the national plan was only recently implemented, the combined burden 

estimates are based on the maximum burdens anticipated in any year during this ICR renewal 

cycle.

The Agency estimates that 8,300 application forms will be submitted for both 

commercial and private pesticide applicator certification/ re-certification in the EPAimplemented program in Indian Country once a 3-year ICR cycle, resulting in an annual average 

of 2,767 applications for certification in the Federal program. With an average per-response

burden estimate of 0.17 hours (10 minutes), the total annual burden for completing certification 

application forms for both commercial and applicators is estimated to be 470 hours (see Table 

2a). Since the Federal Program is managed by Agency personnel, this burden estimate is based 

on the experience of the personnel in EPA’s Region 9, which runs the program in Navajo Indian 

Country, and extrapolated to all of Indian Country. 

The optional, EPA-administered course for private applicators in the Federal plan is expected to 

take up to 12.1 hours total. Further, the Agency estimates that up to 30 private applicators will 

choose the optional training1in the next three years, with an average of 10 such trainees every 

 

1 Private Pesticide Applicator Certification (Indian Country)

http://www2.epa.gov/pesticide-applicator-certification-indian-country/training-private-applicators-indian-country
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year. The estimated total annual burden for this response is 121 hours (Table 2b).

Recordkeeping for RUP Sales and Pesticide Applications

Commercial applicators under the Federal (EPA-implemented) program: The total annual 

burden of recordkeeping for restricted use pesticide applications by commercial applicators 

under Federal certification programs (Indian Country throughout the U.S.) is estimated to be 

10,044 hours, with an average burden estimate of 3.1 hours per response, for each of an 

estimated 3,240 responses (see Table 3).

Commercial applicators under programs administered by authorized agencies: 

Commercial applicators and firms under authorized programs are also required to generate and 

maintain records of RUP applications immediately after the application. The Agency estimates 

that 421,000 commercial applicators will be subject to the recordkeeping requirements, for a 

total annual response burden of 1,305,100 hours. The average per-response burden is 3.1 hours

(see Table 4).

Dealer sales of RUP Products under Federal (Indian Country, EPA-Implemented) 

programs: RUP dealers are required to record sales of RUPs and maintain these records. In this 

ICR, only the cost and burden estimates for dealer recordkeeping under federal certification 

programs are included. All 50 States have implemented certification programs which they 

currently administer. States’ certification programs use State authority to require dealers to 

maintain sales records for RUPs, and are not included in the estimates of this ICR.

The Agency estimates that there are 10 RUP dealers in Indian Country. Each RUP dealer 

has approximately 39 RUP sales transactions per year, which require approximately 3 minutes of 

dealer burden per transaction. This results in 19.50 hours total annual burden to collect and 

record information (Table 5a).

RUP Dealership Information Reporting

Based on the current number of dealers under the Federal program, the Agency estimates 

that approximately one third of the 10 respondents will require some type of information change 

over a three year period. This may include a new company submitting contact information, and 

existing company submitting a name change, or contact information change such as an address 

or telephone number change, or an company that is no longer in business submitting information. 

This action is estimated to require approximately 1 hour of dealer burden per change. This results 

in an annual total burden of approximately 3.33 hours to collect, submit, and maintain

information (Table 5b).

Applicator training and sales of anthrax-related products

In estimating the average respondent burden related to the information collection 

components on anthrax-related products, EPA based the burden hour and cost estimates on its

experience and information obtained from the consultation process and other resources. The total 

annual burden for affected registrants for training and examination activities is estimated to be 50 
July 10, 2014

Page 15 of 25

hours, with an average burden of 25 hours each for approximately 2 registrants (see Table 6). 

The total annual burden for recordkeeping of persons trained and persons/entities to whom 

anthrax-related products are sold or distributed is estimated to be 37 hours, with an average 

burden of 18.5 hours for each of 2 registrants (see Table 7).

6(b) Estimating Respondent Costs

Agency economists revised the estimated wages, benefits and overhead for all labor 

categories for affected industries, state government, and EPA employees based on publicly 

available data from the US Bureau of Labor Statistics. The formulas used to estimate the labor 

rates and formulas used to derive the fully loaded rates and overhead costs for this ICR renewal 

are listed in Attachment H.

Methodology The methodology uses data on each sector and labor type for an Unloaded 

wage rate (hourly wage rate), and calculates the Loaded wage rate (unloaded 

wage rate + benefits), and the Fully loaded wage rate (loaded wage rate + 

overhead). Fully loaded wage rates are used to calculate respondent costs. 

This renewal uses 2013 data.

Unloaded 

Wage Rate

Wages are estimated for labor types (management, technical, and clerical) 

within applicable sectors. The Agency uses average wage data for the 

relevant sectors available in the National Industry-Specific Occupational 

Employment and Wage Estimates from the Bureau of Labor Statistics (BLS) 

at http://www.bls.gov/oes/current/oes_nat.htm. 

Sectors The specific North American Industry Classification System (NAICS) code 

and website for each sector is included in that sector’s wage rate table (see 

Attachment H). Within each sector, the wage data are provided by Standard 

Occupational Classification (SOC). The SOC system is used by Federal 

statistical agencies to classify workers into occupational categories for the 

purpose of collecting, calculating, or disseminating data (see 

http://www.bls.gov/oes/current/oes_stru.htm).

Loaded Wage 

Rate

Unless stated otherwise, all benefits represent 45% of unloaded wage rates, 

based on benefits for all civilian nonfarm workers, from 

http://www.bls.gov/news.release/ecec.t01.htm. However, if other sectors are 

listed for which 45% is not applicable, the applicable percentage will be 

stated.

Fully Loaded 

Wage Rate

We multiply the loaded wage rate by 50% (EPA guidelines 20-70%) to get 

overhead costs.

The following tables illustrate the estimated burden and costs associated with the 

information collection activities of this program.2 For annual report activities, the estimated 

average annual cost per participating State or other authorized agency is about $3,739.58, with 

the total annual cost for all authorized agencies estimated to be $213,156.26 (Table 1).

 

2 Values are rounded to the nearest two decimal places, and actual column totals may be slightly higher or lower.
July 10, 2014

Page 16 of 25

The estimated average annual cost for certifying commercial and private applicators in 

Indian Country is $5.48 per respondent, with the total annual cost for all certified applicators 

estimated to be about $15,163.16 (Table 2a). 

The optional, EPA-administered training course for private applicators in the Federal plan 

is expected to cost $390.10 per response. Based on 10 private applicators opting for the course, 

the total annual cost estimates for this activity are $3,901 (Table 2b).

The total annual respondent cost for all commercial applicator recordkeeping of RUP 

applications in Indian Country is estimated at $323,805.60 with an average annual perrespondent cost of $99.94 (Table 3). 

Recordkeeping of applications by all commercial applicators under State authority has an 

estimated total annual cost of $42,074,740, based on the commercial applicator count of 421,000, 

with an average annual per-respondent cost of about $99.94 (Table 4). 

The estimated average annual cost per respondent for all RUP dealers in Indian Country 

to record sales and maintain records is $2.30, with the total annual cost for all 10 RUP dealers 

estimated to be approximately $896.22. This assumes 39 RUP sales transactions per dealer per 

year, with 3 minutes required during each transaction, or approximately 19.5 hours per year for 

the 10 respondents over the course of a year (Table 5a).

Under the Federal certification plan, the agency estimates that a third of the current 

respondents are either new or have had to submit dealership change information every year. 

Using the same respondent numbers to forecast for the next three years, with a conservative peractivity burden of 1 hour, and a per-response average annual cost of $45.96 (10 x 1/3 x wage

rate), EPA estimates the total annual cost for this activity at $153.05 (Table 5b).

For registrants of anthrax-related products, the estimated average annual cost per 

registrant for training and examination materials is about $1,718.66, with the total annual cost for 

all registrants estimated to be almost $3,437.32 (Table 6). 

The estimated average annual cost to these respondents for recordkeeping activities is 

approximately $1,306.29 per registrant, with the total annual cost for all registrants estimated to 

be about $2,612.58 (Table 7). 
July 10, 2014

Page 17 of 25

Table 1. Average Annual Respondent Burden and Cost Estimates to Authorized 

Agencies for Annual Reports on Certification and Training Programs

Collection Activities

Annual Burden Hours Per 

Respondent TOTALS

Tech.

$59.17/hr

Clerical

$40.81/hr Hours Cost$

Read/hear rule or any collection instrument 

instruction (incl. compliance determination) 0.25 0 0.25 14.79

Create information 5 0 5

 

295.85

Gather information 5 0 5 295.85

Process, compile, review info for accuracy 1 0 1 59.17

Complete written forms or other instruments 0.5 0.5 1

 

49.99

Record, disclose, display, or report the 

information 20 45 65 3,019.85

Store, file, or maintain the information 0 0.1 0.1 

4.08

TOTAL 31.75 45.6 77.35 3,739.58

TOTAL ANNUAL BURDEN: 77.35 hrs/respondent x 57 respondents = 4,409 hrs.

TOTAL ANNUAL COST: $3,739.58/respondent x 57 respondents = $213,156.06

NAICS codes

State government: 999200

Technical, Life, Physical, and Social Science Occupations: 19-0000

Clerical, Office and Administrative Support Occupations: 43-0000

Table 2a. Certified Applicators in Federal Programs (Indian Country) for 

Completion of EPA Form to Apply for Certification 

Collection Activities Annual Burden and Cost Per Respondent

Tech. Hours

$32.24/hr

Total Hours Cost

$

Read/hear rule or any collective instrument 

instruction (incl. compliance determination)

0.07 0.07 2.26

Complete written forms or other instruments 0.10 0.10 3.22

TOTAL 0.17 0.17 5.48

TOTAL ANNUAL BURDEN: 0.17 hrs/respondent x 2,767 respondents = 470.39 hrs.

TOTAL ANNUAL COST: $5.48/respondent x 2,767 respondents = $15,163.16

NAICS code: 37-3012 

Pesticide Handlers, Sprayers, and Applicators, Vegetation: 37-3012
July 10, 2014

Page 18 of 25

Table 2b. Optional Private Applicator Training in Federal Programs (Indian 

Country) 

Collection Activities Annual Burden and Cost Per Respondent

Tech. Hours

$32.24/hr

Total Hours Cost

$

Read/hear rule or any collection instrument 

instruction (incl. compliance determination) 0.07 0.07 2.26

Complete optional EPA-administered training 

program 

12 12 386.88

Complete written forms or other information 0.03 0.03 0.97

TOTAL 12.1 12.1 390.10

TOTAL ANNUAL BURDEN: 12.1 hrs. /respondent x 10 respondents = 121 hrs.

TOTAL ANNUAL COST: $390.1/respondent x 10 respondents = $3901.00

NAICS code: 37-3012 Pesticide Handlers, Sprayers, and Applicators, Vegetation

Table 3. Average Annual Respondent Burden and Cost Estimates for Commercial 

Applicators in Federal Programs (Indian Country) for Recordkeeping for RUP 

Applications

Collection Activities Annual Burden and Cost Per Respondent

Tech. Hours

$32.24/hr

Total 

Hours

Cost

$

Read/hear rule or any collective instrument 

instruction (incl. compliance determination)

0.2 0.2 6.45

Create information 2 2 64.48

Store, file, or maintain the information 0.9 0.9 29.02

TOTAL 3.1 3.1 99.94*

TOTAL ANNUAL BURDEN: 3.1 hrs. /respondent x 3,240 respondents = 10,044 hrs.

 TOTAL ANNUAL COST: $99.94/respondent x 3,240 respondents = $323,805.60

NAICS code: 37-3012 Pesticide Handlers, Sprayers, and Applicators, Vegetation

Table 4. Average Annual Respondent Burden and Cost Estimates for Commercial 

Applicators and Firms under Authorized Agency Programs for Recordkeeping for 

RUP Applications

Collection Activities Annual Burden and Cost Per Respondent

Tech. Hours

$32.24/hr

Total Hours Cost

$

Read/hear rule or any collective 

instrument instruction (incl. 

0.2 0.2 6.45
July 10, 2014

Page 19 of 25

compliance determination)

Create information 2 2 64.48

Store, file, or maintain the information 0.9 0.9 29.02

TOTAL 3.1 3.1 99.94

 TOTAL ANNUAL BURDEN: 3.1 hrs. /respondent x 421,000 respondents = 1,305,100 hrs.

 TOTAL ANNUAL COST: $99.94/respondent x 421,000 respondents = $42,074,740

 

NAICS code: 37-3012 Pesticide Handlers, Sprayers, and Applicators, Vegetation

Table 5a. Dealers in Federal Programs (Indian Country) for RUP Sales 

Recordkeeping and for Reporting Dealerships’ Name and Address

Collection Activities

Annual Burden and Cost Per Respondent

Tech. Hours Total Hours Cost

$45.96/hr $

Read/hear rule or any collective 

instrument instruction (incl. 

compliance determination)

0.02 0.02 0.92

Create information 0.02 0.02 0.92

Store, file or maintain the 

information 0.01 0.01 0.46

TOTAL 0.05 0.05 2.30

TOTAL ANNUAL BURDEN: (.05 hrs. /respondent x 10 respondents) x 39 responses per 

respondent = 19.5 hrs.

TOTAL ANNUAL COST: ($2.30/respondent x 10 respondents) x 39 responses per respondent

= $896.22

NAICS code: 444200 Retail Nursery, Lawn and Garden Supply Stores.

Table 5b. Dealers in Federal Programs (Indian Country) for Reporting Dealerships’ 

Name and Address Changes

Collection Activities Annual Burden and Cost Per Respondent

Tech. Hours

$45.96/hr

Total Hours Cost

$

Read/hear rule or any collective 

instrument instruction (incl. 

compliance determination)

0.2 0.2 9.19

Create information 0.3 0.3 13.79

Report dealership contact information 0.4 0.4 18.38

Store, file or maintain the information 0.1 0.1 4.60

TOTAL 1 1 45.96
July 10, 2014

Page 20 of 25

TOTAL ANNUAL BURDEN: 1 hrs. /response x (10 respondents x 1/3) respondents = 3.33 hrs.

TOTAL ANNUAL COST: $45.96/response x (10 respondents x 1/3) respondents = $153.05

NAICS code: 444200 Retail Nursery, Lawn and Garden Supply Stores.

Anthrax Related Activities

Table 6. Anthrax-related products: Average Annual Respondent (Registrant) 

Burden and Cost Estimates for Training and Examination Materials

Collection Activities Annual Burden Hours 

Per Respondent

TOTALS

Tech.

$70.61/hr

Clerical

$39.55/hr

Hours Cost

$

Read/hear PR Notice (guidance) 0.5 0 0.5 35.31

Develop Training & Examination 

Materials

20 0 20 1,412.20

Review information for accuracy 2 0 2 141.22

Submit training and exam materials to 

EPA

1 1 2 

110.16

Record, store, and file the information 0 0.5 0.5 19.78

TOTAL 23.5 1.5 25 1,718.66

TOTAL ANNUAL BURDEN: 25 hrs. /respondent x 2 respondents = 50 hrs.

TOTAL ANNUAL COST: $1,718.66/respondent x 2 respondents = $3,437.32

 Standard Occupational Codes: 325300

 Management: 11-0000, Management Occupations

 Technical: 19-0000, Life, Physical, and Social Science Occupations

 Clerical: 43-0000, Office and Administrative Support Occupations

Table 7. Anthrax-related products: Average Annual Respondent (Registrant) 

Burden and Cost Estimates for Recordkeeping

Collection Activities Annual Burden and Cost Per Respondent

Tech. 

Hours

$70.61/hr

Total 

Hours

Cost

$

Read/hear PR Notice (guidance) 0.5 0.5 35.31

Gather and review information 10 10 706.10

Record, store, and file the information 5 5 353.05

Submit information, only if requested 3 3 211.83

TOTAL 18.5 18.5 1,306.29

TOTAL ANNUAL BURDEN: 18.5 hrs. /respondent x 2 respondents = 37 hrs.

TOTAL ANNUAL COST: $1,306.29/respondent x 2 respondents = $2,612.58
July 10, 2014

Page 21 of 25

Standard Occupational Codes: 325300

 Management: 11-0000, Management Occupations

 Technical: 19-0000, Life, Physical, and Social Science Occupations

 Clerical: 43-0000, Office and Administrative Support Occupations

6(c) Estimating Agency Burden and Cost 

Certification Programs: Based on experience, the Agency has estimated the annual 

burden to the federal government to review the submissions of annual reports and applications 

for certification. The Agency’s total annual burden associated with the certification of pesticide 

applicators program is estimated at 2,144 hours. The total annual cost to the Agency is estimated 

at $168,590. The burden and cost to the Agency have increased from the estimates in the last 

ICR renewal due to an increase in the number of respondents in Indian Country.

Anthrax-related products: The Agency estimates the annual burden to the Federal 

government to review the registrants’ training material submissions to be 75 hours. The total 

annual cost to the Agency is estimated at $5,868. 

Total Agency burden: The Agency estimates the total annual burden to the Federal 

government associated with the certification of pesticide applicators program and anthrax-related 

products training materials to be 2,219 hours. The total annual cost to the Agency for these 

reviews is $174,458. 

Table 8a. Annual Agency Burden and Cost Estimates - Burden to EPA Regional 

Offices for Indian Country Program and for Processing Annual Reports from 

Authorized Agencies Prior to Submission to Headquarters

Collection Activities Mgmt. hours

$121.44/hr

Tech. hours

$80.18/hr

Clerical

hours

$45.18/hr

Total 

Hours

Cost

$

Prepare Regional 

Reports - for Federal 

Programs in Indian 

Country3

0 936 0 936 75,048.48

Answer respondent 

questions

7.1 228 0 235.1 19,143.26

Audit/review 

submissions

15 638 0 653 52,976.44

Reformat and 

distribute data

0 50 0 50 4,009.00

Store, file, or maintain 0 17 3 20 1,498.60

 

3 For nine Regional Reports on federal programs in Indian Country with a burden of 104 hours of technical time per 

report. Although there are ten EPA Regional Offices, one Region has no federally recognized tribes. The plan for 

Navajo country will be included in the Region 9 Report. 
July 10, 2014

Page 22 of 25

the information

TOTAL 22.1 1,869 3 1894.1 152,675.78

 NAICS 999100 - Federal Executive Branch Standard Occupational Codes:

 Management: 11-0000, Management Occupations

 Technical: 19-0000, Life, Physical, and Social Science Occupations

 Clerical: 43-0000, Office and Administrative Support Occupations

Table 8b. Annual Agency Burden and Cost Estimates - Burden to Headquarters for 

Review of Submitted Annual Reports

Collection Activities Tech. Hours $80.18/hr Cost $

Answer respondent questions 116 9,300.88

Audit/review submissions 93 7,456.74

Reformat and distribute data 29 2,325.22

Store, file, or maintain the information 12 962.16

TOTAL 250 20,045.00 

 NAICS 999100 - Federal Executive Branch Standard Occupational Codes:

 Management: 11-0000, Management Occupations

 Technical: 19-0000, Life, Physical, and Social Science Occupations

 Clerical: 43-0000, Office and Administrative Support Occupations

Table 8c. Annual Agency Burden and Cost Estimates - Burden to Headquarters for 

Review of Submitted Training and Examination Materials for Anthrax-related 

Products

Collection Activities Tech. Hours

$80.18/hr

Cost

$

Answer respondent questions 3 240.54

Audit/review submissions 60 4,810.80

Reformat and distribute data 6 481.08

Store, file, or maintain the information 6 481.08

TOTAL 75 6,013.50

NAICS 999100 -Federal Executive Branch Standard Occupational Codes:

Management: 11-0000, Management Occupations

 Technical: 19-0000, Life, Physical, and Social Science Occupations

Clerical: 43-0000, Office and Administrative Support Occupations
July 10, 2014

Page 23 of 25

6(d) Bottom Line Burden Hours and Cost Table

Table 9. Bottom Line Annual Burden and Cost Table

Respondent Total Burden Hours Total Cost ($)

States (Table 1) 4,409 213,156.06

Federal program - certified applicators 

(Tables 2 and 3)

Table 2a 470 15,163.16

Table 2b 121 3901.00

Table 3 10,044 323,805.60

State-administered programs - commercial 

applicators (Table 4) 1,305,100 42,074,740.00

RUP dealer burden for recordkeeping of 

RUP sales (Table 5a) 19.50 896.22

RUP dealer burden for reporting 

informational changes (Table 5b) 3.3 153.05

Anthrax-related products - registrants 

(Tables 6 and 7)

Table 6 50 3,437.32

Table 7 37 2,612.58

Respondent Total 1,320,254 42,637,864.99

Agency Total Burden Hours Total Cost ($)

EPA Regional Offices (Table 8a) 1,894.10 152,675.78

EPA Headquarters (Table 8b) 250 20,045.00

EPA Headquarters – review of registrant 

training materials for anthrax-related 

products (Table 8c)

75 6,013.50

Agency Total 2,219 182,734.28

6(e) Reasons for Change in Burden

The total estimated respondent burden for this renewal ICR reflects a net decrease of 415

hours. This decrease reflects EPA's updating of burden estimates, addition of a recentlyimplemented optional, voluntary offering, and a change in the number of entities whose 

certification programs are directly overseen by EPA. This change is both an adjustment and the 

result of a program change.

6(f) Burden Statement

The total annual respondent burden associated with this ICR is estimated to be 1,320,254

hours, and the total annual respondent cost associated is $42,637,864.99.
July 10, 2014

Page 24 of 25

According to the Paperwork Reduction Act, “burden” means the total time, effort, or 

financial resources expended by persons to generate, maintain, retain, disclose, or provide 

information to or for a Federal agency. For this collection, it is the time reading the regulations, 

planning the necessary data collection activities, analyzing data, generating reports and 

completing other required paperwork, and storing, filing, and maintaining the data. The agency 

may not conduct or sponsor, and a person is not required to respond to, a collection of 

information unless it displays a currently valid OMB control number. The OMB control number 

for this information collection appears at the beginning and end of this document. In addition 

OMB control numbers for EPA’s regulations, after initial display in the final rule, are listed in 40 

CFR Part 9. 

The Agency has established a public docket for this ICR under Docket ID No. EPA-HQOPP-2014-0446, which is available for online viewing at www.regulations.gov, or in person at 

the OPP Regulatory Public Docket in Rm. S-4400, One Potomac Yard (South Building), 2777 S. 

Crystal Drive, Arlington, VA. This docket facility is open from 8:30 a.m. to 4 p.m., Monday

through Friday, excluding legal holidays. The docket telephone number is (703) 305-5805. You 

may submit comments regarding the Agency's need for this information, the accuracy of the 

provided burden estimates and any suggested methods for minimizing respondent burden, 

including the use of automated collection techniques.

Submit your comments, referencing Docket ID No. EPA-HQ-OPP-2014-0446 and OMB 

Control No. 2070-0029, to (1) EPA online using www.regulations.gov (our preferred method), or 

by mail to: Public Information and Records Integrity Branch (PIRIB), Mail Code: 7502P, Office 

of Pesticide Programs (OPP), Environmental Protection Agency, 1200 Pennsylvania Ave., NW, 

Washington, DC 20460, and (2) OMB by mail to: Office of Information and Regulatory Affairs, 

Office of Management and Budget (OMB), Attention: Desk Officer for EPA, 725 17th Street, 

NW, Washington, DC 20503.
July 10, 2014

Page 25 of 25

ATTACHMENTS TO THE SUPPORTING STATEMENT

Attachments to the supporting statement are available in the public docket established for this 

ICR under docket identification number EPA-HQ-OPP-2014-0446. These attachments are 

available for online viewing at www.regulations.gov or otherwise accessed as described in 

section 6(f) of the supporting statement, and as noted below.

Attachment A: 7 U.S.C. 136a(d) - FIFRA Section 3(d) - Also available at online at the 

US House of Representatives’ US Code website

Attachment B: 7 U.S.C. 136i - FIFRA Section 11 - Also available at online at the US 

House of Representatives’ US Code website

Attachment C: 40 CFR 171 - Certification of Pesticide Applicators - Also available 

online at the National Archives and Records Administration’s Electronic 

CFR Website

Attachment D: Pesticide Registration (PR) Notice 2008-2 - “Guidance for 

Antimicrobial Pesticide Products With Anthrax-Related Claims”

Also available at: http://www.epa.gov/PR_Notices/index.htm

Attachment E: (Reserved) Record of Consultations

Attachment F: EPA Form 8500-17-N – Request for Pesticide Applicator Certification in 

Navajo Indian Country and Instructions. Also available at: 

http://www.epa.gov/oppfead1/safety/applicators/2007/navajo.htm

Attachment G: EPA Form 7100-01 – Request for Pesticide Applicator Certification in 

Indian Country and Instructions

Attachment H: Wage Rate Tables (Commercial Pesticide Applicators, Pesticide 

Registrants, Dealers, State Government, and EPA)

Attachment I: Display Related to OMB Control #2070-0029 – Listings of Related 

Regulations in 40 CFR 9.1