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 Laird

Labeling Specialist, Regulatory Affairs

Syngenta Crop Protection

patsy.laird@syngenta.com

2. Ms. Barbara Del Duke

Director of Public Affairs

FMC Corporation

barbara.delduke@fmc.com

3. Mr. Steve Bale

Senior Logistics Manager

Melaleuka

sbale@melaleuka.com

II. Request for Comment Sent to Companies Contacted:

Dear Exporter:

EPA Is renewing its Information Collection Request (ICR) 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.federalregister.gov/articles/2015/05/08/2015-11212/agency-informationcollection-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 Register 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 you 
like to participate? If so please complete the survey questions below and return them to 

me within the next 21 days. 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 appreciate your assistance. If you 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 by another office at EPA or by 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 ICR 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 submit 

information in ways that are clear, logical and easy to complete?

d) Regarding any specific-program forms, do you use them? Are they clear, logical 

and easy 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 

Agency 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 alternatives include the use of “web 

forms”/XML-based submissions via the Agency’s Internet site and magnetic mediabased submissions, e.g., diskette, CD-ROOM, etc. Would you be interested in 

pursuing electronic reporting? Are you keeping your records electronically? If yes, in 

what format?

Although the Agency does not offer an electronic reporting option because of CBIrelated security concerns at this time,

a) Would you be more inclined to submit CBI on 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 costs)

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 ICR, (e.g., the ICR 

does not include 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 ICR is estimated to be $1,461,658. This 

estimate is composed of 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

Information 

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 ICR and the burden for this 

information collection.