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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/pesticides/fees/questions/waivers.htm)?

A: Yes. 

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

A: Yes. 

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

A: Unless the regulations change, I don’t think improvements or clarifications 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 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? 

A: Too high. 

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: RegWest Company, LLC does not hold any registrations; however, we oversee more than 50 

registrations held by our clients. 
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Comments:

Q: Did we miss anything? 

A: Not that I can think of. 
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Consultations Conducted for the Renewal 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 helpful 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 forms 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 explanations. An example of a company that 

cannot rely solely 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: 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: Yes, we do use the industry generated form as it is a helpful way to tie together the different 

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?
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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.