1 **Attachment E Summary of Consultations**  This attachment is available as part of the electronic **docket EPA -**  **HQ -**  **OPP -**  **2011 -**  **0 766**  and is part of the ICR’s Supporting Statement **Consultation Questions:** 1. Are the data EPA asks for available from another source? 2. Are the instructions for submission clear?

— Please include an y comments on frequency of information collection here. 3. Would y ou be interested in electronic reporting of data? 4. Do y o u find the burden and costs estimates provided in the tables below realistic for this I CR? **C om**  **panies C**  **ontacted:** A. Trace Tipton Suterra, LLC 20950 NE Talus Place, Bend, Oregon 97701 Phone: 541 - 317 - 2216 B. Jennifer J. Seifert Hacco, a Neogen Company 110 JHopkins Drive, Randolph, Wisconsin 53956 Phone: 920 - 326 - 5141 C. Ruby Ana Evans, E.I . du Pont de Nemours & Co., Inc. 12701 Almeda Road Houston, Texas 77045 Phone: 713 - 433 - 6404 D. Janelle Restum The Scotts Company 14111 Scottslawn Road Mary sville, Ohi o 43041 Phone: 937 - 578 - 5029 E. Zofia C. Schmidt Buckman Laboratories, Inc. 1256 North McLean Blvd. Memphis, Tennessee 38108 Phone: 901 - 278 - 03302

**Summary of responses:** 1. Are the data EPA asks for available from another source? A.

– no B.

– no C.

– no D.

– no E.

– no 2. Are the instructions for submission clear?

— Please include an y comments on frequency of information collection here. A.

– yes B.

– yes..... On the frequency of information collection, noted that it would be preferable if it could be collect ed on a revolving annual basis

– that is, every 12 months from the time of the original submission (per purchaser) C.

– yes, usually D.

– ye s E.

– yes 3. Would y ou be interested in electronic reporting of data? A.

– yes B.

– yes C.

– yes D.

– yes E.

– yes 4. Do y ou fi nd the burden and costs estimates provided in the tables below realistic for this ICR? A.

– yes B.

– mixed

– Ittakes more ti me to actually acquire the FPAS

– would estimate up to 7 hours. And label translations can take approximately 2 1⁄2 weeks

– from time requested by company until the time it is received

– but not sure how long it actuall y takes to do the translation itself. C.

– yes, for the FPAS, but probably longer for the labels. D.

– no – label creation and translation takes 8 weeks (from conce ption of label to printing) E.

– yes, for new products, for the same products it could be a little less. 5. other comments? A. believes that if an active ingredient is exempt from registration, then the R & D sample should be as well. B. the submission sc hedule should be a revolving one

– one ye ar from the date of receipt, rather than a calendar ye ar – they tend to receive most of them in a very short time - frame. C. no, it’s a routine part of business.3

D. doesn’t believe that the information submitted to the government is actually useful or used by any one. E. no, just a matter of complying with regulations **Summary of Consul t**  **ations** Five companies were selected at random to respond to several questions about the accuracy of the burden estimates proposed in November 2011. All five reported that the instructions for submitting the Purchaser Acknowledgement Statements are clear; that th e information is not available from an y other source; and, all five indicated an interest in electronic submissions in the future. The estimates for compl yi ng with the PAS were, as published: ANNUAL BURDEN: 1.06 hrs (64 minutes) X 2, 283 statements = 2 ,4 20 hours per year ANNUAL COSTS: $ 59 . 52 X 2, 283 respondents = $13 5 , 904 per year All five companies responded that the estimates seemed accurate. The estimates for the respondent b urden and cost for compliance with the unregistered exported pesticide p ro duct l abeling were, as published: ANNUAL BURDEN: 8 hours x 900 unregistered products = 7,200 hours ANNUAL COSTS: $504.65 x 900 unregistered products = $454,180 The responses from the five companies survey ed ranged from agreement that the estimates were accurate to an indication that they were significantly

different. One company indicated that it could take up to 8 weeks to create, translate and print a product label. There may

be differences in exactly what activities support the burden estimate. No action by EPA to change the estimates is planned. The representative from o ne compan y noted th at it would be preferable if the FPAS could be collected on a re volving annual basis

– that is, every 12 months from the time of the original submission (per purchaser) . As discussed in the supporting statement , EPA provides two reporting options. The exporter may elect to report on a per - shipment basis or to report on an annual basis, provided the exporter submits the first FPAS in the calendar year for the first shipment to a purchaser in an importing country . EPA bel ieves these two options provide flexibility for respondents to comply with the information request. EP A does not contemplate changes to the reporting options at this time.