**Attachment E Summary of Consultations**  This attachment is available as part of the electronic **Docket EPA -**  **HQ -**  **OPP -**  **2015 -**  **0231** and is part of the ICR’s Supporting Statement
**I. Companies Contacted:**  1. Ms. Patsy

L aird Labeling Specialist, Regulatory Affairs Sy ngenta Crop Protection patsy .laird@s yn genta.com 2. Ms. Barbara Del Duke Director of Public Affairs FMC Corporation barbara.delduke@fmc.com 3. Mr. S teve Bale Senior L ogistics Manager Melaleuka sbale@melaleuka.com
**II. Request for Comment Sent to Companies Contacted**  **:**
Dear Exporter : EPA I s renewing it s Information Collection Request (I CR) for Foreign Purchaser Acknowledgment Statements and we are required to ask companies with whom we are in contact concerning Foreign Purchase Acknowledgement Statements to let us know what sort of burden the requirement places on them. EPA published the following notice in the Federal Register , https://www.fe deralregister.gov/articles/2015/05/08/2015

- 11212/agency

- information

collection

- activities

- proposed

- collection

- comment - request#h

- 8 announcing a 60

- day

public notice and comment period. In addition to the public notice that EPA published in the Federal Regi ster concerning the renewal of this ICR, the Agency must consult with stakeholders who actively interact with the Agency through the use of this collection instrument, as required under 5 CFR 1320.8(d)(1). Would youlike to participate? If so please compl ete the survey questions below and return them to me within the next 21 day s. Please contact me if you want to discuss the survey
. Following are five series of questions that we need responses to. There is no requirement for you to respond , but we would ap preciate your assistance. If yo u have any questions about our request please contact me. Regards , Ron Kendall, Coordinator Foreign Purchaser Acknowledgment Statements OPP **III. Questions:**  **1) Publicly available Data**  a) Is the data that the Environmental Protection Agency seeks available from any public source, or already collected b y another office at EPA or b y another agency? b) If yes, where can you find the data? **2) Frequency of Collection**  Can the Agency

collect the information less frequently and still produce the same outcome? **3) Clarity of Instructions**  a) The I CR is intended to require that respondents provide certain data so that the Agency can use them. i) Based on the instructions (regulations, Pesticide Registration [ PR] Notices, etc.), is it clear what you are required to do and how to submit such data? ii) If not, what suggestions do you have to clarify the instructions ? b) Do you understand that you are required to maintain records? c) Considering that there is no required submission format, is it difficult to su bmit information in way s that are clear, logical and easy to complete? d) Regarding an y specific

- program forms, do you use them? Are they clear, logical and eas y to complete?**4) Electronic Reporting and Recordkeeping**  The Government Paperwork Elimination Act requires that agencies make available to the public electronic reporting alternatives to paper

- based submissions unless there is a strong reason for not doing so. One such reason is that, at the present time, the A gency is unable to ensure the security of Confidential Business Information (CBI) that might be transmitted over the Internet. What do you think about electronic alternatives to paper

- based records and data submissions? Current electronic

- reporting alt ernatives include the use of “web forms”/XML

- based submissions via the Agency’s Internet site and magnetic media

based submissions, e.g., diskette, CD

- ROOM, etc. Would you be interested in pursuing electronic reporting? Are you keeping your records electronicall y? If yes, in what format? Although the Agency

does not offer an electronic reporting option because of CBI

related securit y concerns at this time, a) Would you be more inclined to submit CBIon diskette than on paper? b) What benefits would electronic submission bring you in terms of burden reduction or greater efficiency in compiling the information? **5)** ***Burden and Costs (please see attached table**  **below that shows our estimates**  **about respondent burden and cost s**  **)** a) Are the labor rates accurate? b) The Agency assumes there are no capital costs associated with this activity
. Is that correct? c) Bearing in mind that the burden and costs estimates include only burden hours and costs associated with the paperwork involved with this I CR, (e.g., the ICR does not includ e estimated burden hours and costs for conducting studies) are the estimated burden hours and labor rates accurate? If you provide burden and cost estimates that are substantially different from the Agency ’s, please provide and explain how you arrived at your estimates. d) Are there other costs that should be accounted for that may have been missed?
Respondent Burden by

Information Collection (IC) The total annual respondent burden hours for this ICR are estimated at 24,470 hours. This accounts for 2,420 hours for the FPAS requirement, 7,200 hours for the labeling of unregistered pesticides, and 14,850 hours for the labeling of registered pesticides.The total annual respondent cost for this I CR is estimated to be $1,461,658. This

estimate is composed o f the following costs: $135,904 for the FPAS requirement, $454,180 for the labeling of unregistered pesticides, and $871,574 for the labeling of registered pesticides **Total Annual Respondent Burden Hours and Cost** In formation Collection Responses

Per Year Burden Per

Response (hours) Annual

Burden (hours) Annual

Cost ($) Foreign Purchaser Acknowledgment Statements 2,283 1.06 2,420 $135,904 Labeling for Unregistered Exported Pesticide Products 900 8 7,200 454,181 Multilingual Product Labeling for Registered Exported Pesticide Products 2,700 5.5 14,850 $871,574 Total Annual Respondent Burden 24,470 1,461,658 1 Totals may

not sum due to rounding. **IV. Responses:**  EPA received no responses to its request for comments on the I CR and the burden for this information collection.