1 Consultations Conducted for the Renewal of the Pesticide Registration Fee ICR 2013:

OMB Control No.: 2070-0167 EPA ICR No.: 2147.05

Company Name: RegWest Company, LLC
Name of person consulted: Kimberlee Young (formerly: Kim Davis)

Date: August 16, 2013

Q : When preparing your waiver request did you consult the Questions and Answers on the EPA website (http://www.epa.gov/pesti cides/fees/questions/waivers.htm)?

A: Yes.

Q: If yes, did you find it helpful and informative?

A: Yes.

Q: What improvements or clarif ications would you like to see?

A: Unless the regulations change, I don’t think improvements or clar ifications are needed.

Q : Are you aware of the industry generated form?

A: Yes.

Q: Would you use the industry generated form ( http://www.cspa.org/pdf/waiver.pdf)? If no, please tell us why?

A : I always use the industry-generated form.

Labor Rates:

Q: The current labor rates for this ICR proposal are $120.32 for Management; $77.85 for Technical; and $44.05 for Clerical. Would you say these labor rates are accurate?

A: Yes.

Q: The current labor burden breakdown (the aver age amount of time each labor category might spend on this task) is displayed in Tables 2, 4, 5, 6 in the supporting statement document. Are these industry averages to high, to low, or just about right for your firm?

A: Too high.

Size of your Firm:

Does your firm hold 5 or less pesticide registr ations, 6-10 registratio ns, 11-20 registrations, 21 -50 registrations, or over 50 registrations ? (See Tables 1 and 2 of the supporting
statement).

A: RegWest Company, LLC does not hold any regist rations; however, we oversee more than 50 registrations held by our clients.2 Comments:

Q: Did we miss anything?

A: Not that I can think of.1 Consultations C onducted for the R enewal of the Pesticide Registration Fee ICR 2013:

OMB Control No.: 2070

- 0167 EPA ICR No.: 2147.05

Company Name: Technology Sciences Group Inc. Name of person consulted: Amy Plato Roberts, Senior Regulatory Consultant

Date: August 7, 2013

Q : When preparing your waiver request did you consult the Questions and Answers on the EPA website (http://www.epa.gov/pesticides/fees/questions/waivers.htm)?

A: Yes.

Q: If yes, did you find it helpful and informative?

A: Yes, but it would be hel pful to see a practical example posted on the website.

Q: What improvements or clarifications would you like to see?

A: Inclusion of a practical example. Often for a company that is going through the process for

the first time there is more information needed that one would think by following the guidance. Typically a first time through the process involves the industry generated form, a letter confirming the corporate structure, information explaining affiliates, if any, tax f orms reporting revenue or a letter explaining revenue, and tax forms or a letter explaining the number of employees. It would be helpful to see a mocked up response for a company that has tax forms and for a company that does not and must provide explanat ions. An example of a company that cannot rely sole l y on tax forms for reporting revenue would be one that has sales other than pesticides and the pesticide sales have to be broken out or a foreign entity that does not use US

tax forms for revenue.

Q : Ar e you aware of the industry generated form?

A: Yes.

Q: Would you use the industry generated form ( http://www.cspa.org/pdf/waiver.pdf)? If

no, please tell us why ?

A : Yes, we do use the industry generated form as it is a helpful way to tie together the d ifferent pieces of a fee waiver request. Typically it is included with all the other documentation.

Labor Rates :

Q: The current labor rates for this ICR proposal are $120.32 for Management ; $77.85 for Technical; and $44.05 for Clerical. Would you say these labor rates are accurate?

A: Not able to comment.

Q: The current labor burden breakdown (the average amount of time each labor category might spend on this task) is displayed in Tables 2, 4, 5, 6 in the supporting statement

document. Are these industry averages to high

, to low

, or just about right for your firm?2 A: Yes, that seems accurate.

Size of your Firm:

Does your firm hold 5 or less pesticide registrations , 6

- 10 registrations, 11

- 20 registrations,

21

- 50 registrations, or over 50 registrations? (See Tables 1 and 2 of the supporting

statement )

. A: We represent a multitude of firms that hit all of the options in Tables 1 and 2.

Comments :

Q: Did we miss anything?

A: Do not believe so.