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SUPPORTING STATEMENT

FOR AN INFORMATION COLLECTION REQUEST (ICR)

1. IDENTIFICATION OF THE INFORMATION COLLECTION 

1(a). Title of the Information Collection

Worker Protection Standard Training and Notification 

OMB No.: 2070-0148; EPA No.: 1759.06

1(b). Short Characterization/Abstract

This information collection request (ICR) estimates the third party response burden of 

paperwork activities under the Worker Protection Standard (WPS) requirements, codified under

40 Code of Federal Regulations (CFR) Part 170. The Environmental Protection Agency (EPA, or 

the Agency) is responsible for the regulation of pesticides under the Federal Insecticide, 

Fungicide, and Rodenticide Act (FIFRA). The WPS establishes requirements to protect 

agricultural workers and pesticide handlers from hazards of pesticides used on farms, on forests, 

in nurseries and in greenhouses.

The regulations contain the standard and workplace practices, which are designed to 

reduce or eliminate worker exposure to pesticides and establish procedures for responding to 

exposure-related emergencies. The practices include prohibitions against applying pesticides in a 

way that would cause exposure to workers and others; a waiting period before workers can return 

to areas treated with pesticides (restricted entry interval); basic safety training (and voluntary 

training verification) and posting of information about pesticide hazards, as well as pesticide 

application information; arrangements for the supply of soap, water, and towels in case of 

pesticide exposure; and provisions for emergency assistance. The training verification program 

facilitates compliance with the training requirements by providing a voluntary method for 

employers to verify that the required safety information has been provided to workers and 

handlers. 

Information is exchanged between agricultural employers and employees at farm, forest, 

nursery and greenhouse establishments to ensure worker safety. No information is collected by

the Agency under this ICR. It is estimated that the annual response burden is approximately 1.8 

million hours valued at $82.5 million.

NEED FOR AND USE OF THE COLLECTION 

2(a). Need/Authority for the Collection 

In accordance with FIFRA Section 25 (Attachment A), the Agency issued final 

regulations on August 21, 1992, revising the WPS at 40 CFR 170 (Attachment B). The WPS at 

40 CFR Part 170 is designed to reduce the risks of illness or injury resulting from workers’ and 
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handlers’ occupational exposure to pesticides used in the production of agricultural plants on 

farms or in nurseries, greenhouses, and forests and also from the accidental exposure of workers 

and other persons to such pesticides. It requires workplace practices designed to reduce or 

eliminate exposure to pesticides and establishes procedures for responding to exposure-related 

emergencies. The notification and training requirements are necessary to provide agricultural 

workers and pesticide handlers with the information they need to protect themselves from 

pesticide poisoning and other injuries. 

2(b). Practical Utility/Uses of the Data

Basic pesticide safety information/training, instructions on safe operations and repair of 

equipment, notification regarding use of specific pesticides, and the applicability of 

exceptions/exemptions to WPS reentry restrictions provide agricultural workers, pesticide 

handlers, agricultural employers, and medical personnel with basic information so they are more 

informed and better prepared to take precautionary or responsive measures, as appropriate. This 

training and notification are targeted to agricultural workers who perform tasks related to the 

cultivation and harvesting of plants in areas treated with pesticides, and pesticide handlers who 

mix, load, and apply pesticides for use in these areas.

Training verification certificates have been produced by the Agency for authorized 

trainers to issue to workers and handlers once they have completed the WPS training 

requirements. The EPA training verification program is a voluntary program and the issuance of 

the training verification cards is not a WPS requirement. However, agricultural employers are 

relieved of the responsibility of safety training if their agricultural workers and pesticide handlers 

possess valid EPA training verification cards. 

Participating States issue the cards to qualified training providers within the State. The 

program is intended to assist in substantiating WPS pesticide safety training, minimize the need 

for retraining (given the migrant nature of much of the workforce), offer an uncomplicated 

system for verifying training, provide a means for training quality control, and allow states 

flexibility in administering the program. 

NON-DUPLICATION, CONSULTATIONS, AND OTHER COLLECTION CRITERIA 

3(a). Non-duplication

Not applicable. This is the only notification activity of its kind and notifications required 

in this program are required only once per event. Consequently, the possibility for duplication 

does not exist. The WPS provides for an exemption from the requirements of training for 

certified applicators of restricted-use pesticides trained under the Certification and Training 

Program found in 40 CFR Part 171. Therefore, no duplication of training is imposed. 

Additionally, the WPS training verification program was explicitly developed to eliminate 

duplication of training.
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3(b). Public Notice

In preparing to renew this ICR, EPA will publish a Federal Register (FR) Notice 

announcing this proposed information collection activity and provide a 60-day public comment 

period. Any public comment received for this action will be posted at 

http://www.regulations.gov using the docket identifier EPA-HQ-OPP-2010-0896.

3(c). Consultations Required Prior to ICR Submission to OMB

In addition to the public notice that EPA will publish in the Federal Register concerning 

the development of this ICR, the Agency will consult with stakeholders who actively interact 

with the Agency through the WPS program. EPA will solicit and publish stakeholder assessment 

of the regulatory burden estimates expressed by the Agency in this ICR (Attachment C). 

3(d). Effects of Less Frequent Collection

Not applicable. Training/notifications in this program are required only once per event, as 

specified in 40 CFR 170. Consequently, the possibility for less frequent training/notification does 

not exist under current regulations, or without increased risk to agricultural workers and 

handlers. 

3(e). General Guidelines

Two of the general guidelines of the Paperwork Reduction Act (PRA) are not met by this 

ICR. First, the information (e.g., safety information, training materials, and signs for posting) 

that employers are required to provide to workers and handlers is generally information that is 

not maintained by the employer and must be developed or purchased. Second, small entities are 

required to follow the same requirements as larger establishments under the WPS, unless 

exempted as a solely family-operated establishment. 

Availability and Maintenance of Notice Information

The information that EPA requires agricultural employers provide to workers and 

handlers (e.g., safety information, training materials, signs for posting, etc.) is not typically

maintained by the employer. Employers will generally need to develop or purchase these 

materials. However, some of the information may customarily be maintained, but in a different 

format than is required by the rule. Specifically, the pesticide application information that is 

required to be centrally posted may be maintained by the employer in various other forms, such 

as bills, receipts for pesticides purchased, or service contracts for individual applications by

commercial applicators. 

Location information may be maintained in the form of field maps. The WPS requires 

that certain information about each application be centrally posted; including the location of the 

application, information about the pesticide, date and time of application and restricted entry

interval, but the format of such information posting is left to the individual employer. Materials 

containing guidance on this required information have been distributed widely. 
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Small Entity Flexibility

Small entities are required to follow the same requirements as larger establishments under 

the WPS, unless exempted as a solely family-operated establishment. The protections of the 

WPS depend upon workers receiving the various training and notifications contained in the rule. 

These cannot be reduced for small establishments without seriously compromising the 

protections offered to workers and handlers.

3(f). Confidentiality

Not applicable. The Agency is not collecting information in conjunction with this 

activity. Further, this activity complies with the provisions of the Privacy Act of 1974 and OMB 

circular A-108.

4. THE RESPONDENTS AND THE INFORMATION REQUESTED 

4(a). Respondents/NAICS Codes

Respondents affected by the collection activities under this ICR are agricultural 

employers, including employers in farms as well as nursery, forestry, and greenhouse 

establishments. There are approximately 309,085 agricultural establishments in the U.S. that 

both hire labor and use pesticides, and 3 million to 4 million farm workers. The North American 

Industrial Classification System (NAICS) codes assigned to the parties responding to this 

information are as follows: 

NAICS Code Examples of Potentially Affected Entities 

111 Crop production Agricultural employers - farms 

115 Support activities for 

agriculture and forestry Agricultural employers - greenhouses and forestry 

Workers’ burden hours and cost estimates are included in the total burden and cost for 

this information collection (and in Table 1 under section 6(b) of this document) because workers 

must spend the time necessary to receive training and notifications from their employers. 

However, the requirements for all training/notifications are on the employer. It is assumed that 

workers are generally paid during training/notifications. Therefore, the burden and cost are 

effectively borne by the agricultural employer, even though the workers’ time and wage rate are 

also used in the estimation.

4(b). Information Requested

(i). Data items, including recordkeeping requirements

(1). Central Information:
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Safety Poster. The agricultural employer must display pesticide safety information 

in a central location on the agricultural establishment, providing pesticide safety 

concepts and emergency medical care information. EPA supported the 

development of posters which are readily available at no cost from EPA or at a 

very low cost from commercial supply (at $2.50 each). Employers need only add 

the name of the nearest medical care facility and post the poster in a central

location. Employers are not obligated to use the EPA-developed poster and may

create their own so long as the ten basic points described in 40 CFR 170.135(b) 

are included.

Treatment-Specific Information. The agricultural employer must display at a 

central location the following: the location and description of a treated area; the 

product name, EPA registration number, and active ingredient(s) of the pesticide; 

the time and date of application; and the restricted-entry interval for each 

pesticide application, if workers will be on the establishment within a specified 

time period during or following application.

(2). Training: 

Basic Pesticide Safety Information. The agricultural employer must assure that 

each agricultural worker who has not received the complete pesticide safety 

training is provided basic pesticide information specified in 40 CFR 170.130(a)(3) 

in a manner the worker can understand. 

Agricultural Worker Training. The agricultural employer must assure that each 

agricultural worker is trained in pesticide safety in a manner that the worker can 

understand within 5 days of employment on the establishment, or before workers 

enter treated areas to perform early-entry activities. The person who conducts the 

training must meet the criteria described in 40 CFR 170.130(c)(2) and the training 

must cover the eleven points described in 40 CFR 170.130(c)(3). 

Pesticide Handler Training. The handler employer must assure that each pesticide 

handler is trained in pesticide safety, covering the 13 points described in 40 CFR 

170.230(c) before they perform any handling task.

EPA supported the development of pesticide safety training materials for 

agricultural workers, pesticide handlers, and trainers for both groups of 

employees. Through the cooperation of the pesticide chemical industry, state 

agencies, and others, the materials were produced in large volume and distributed 

for no cost. Additional materials are commercially available for minimal cost 

(training handbooks available at $1.00 or less, trainer notebooks available at 

$3.50, and a reference guide is available at $3.50 each). Additionally, the Agency 

has supported training efforts conducted by national farm worker organizations 

across the country, focusing on entry points and key paths for the migrant farm 

worker workforce.
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(3). Training Verification:

The EPA training verification program is a voluntary program and is intended to 

relieve agricultural employers of the burden of repeat training of individuals in a 

mobile work force. Employers are relieved of the responsibility of safety training 

if their agricultural workers and pesticide handlers possess valid EPA training 

verification cards. States that agree to participate in EPA's voluntary training 

verification program submit an agreement form to EPA indicating the name of a 

State WPS contact and the number of training verification cards that they wish to 

receive from EPA. This is a one-time filing. Participating States will issue EPA 

training verification cards to qualified training providers within the State. As a 

condition for being allowed to provide cards to workers and handlers, trainers are 

asked to keep class rosters of the names of those they have trained. 

(4). Treatment-Specific Worker/Handler Notification:

Oral Notification and/or posting warning signs. Whenever specified on the 

pesticide label, the employer must notify workers who come within 1/4 mile of a 

treated area within a specified time period of any pesticide application. 

Notification may be either by posting a warning sign or by providing information 

orally, unless the pesticide label requires both posting and oral notification. 

Required specifications for the warning signs are contained in the 40 CFR 

170.120(c). Signs are commercially available for approximately $2.00 each. The 

oral notification must be in a manner that the worker can understand, and include 

the location and description of the treated area, the time during which entry is 

restricted, and instructions not to enter the treated area until the restricted-entry

interval has expired.

(5). Handler and Emergency Information:

Handler Notice to Employer. Before the application of any pesticide on or in an 

agricultural establishment, the handler employer shall provide or assure the 

agricultural employer for the establishment is aware of the specific location and 

description of the treated area; the time and date of application; the product name, 

EPA registration number, and active ingredient(s); the restricted-entry interval; 

and whether posting and oral notification are required. 

Safe Operation and Repair. The handler employer must assure that before the 

handler uses any equipment for mixing, loading, transferring, or applying 

pesticides, the handler is instructed in the safe operation of the equipment. 

Emergency Information. If the employer has reason to believe that a person who 

is or has been employed by an agricultural establishment or a commercial 

pesticide handling establishment to perform pesticide handling tasks has been 

poisoned or injured by exposure to pesticides as a result of that employment, the 
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employer must provide that person or treating medical personnel information 

about the pesticide, the antidote and first aid information from the product label, 

the circumstances of handling the pesticide, and the circumstances of exposure to 

the pesticide. 

(6). Use of Exceptions/Exemptions Notification:

Use of Exceptions/Exemptions Notice. Employers must notify workers, either in 

writing or orally, in a language the worker understands, if the establishment is 

operating under conditions of an EPA-approved exception/exemption to the early 

entry provisions of the WPS. The exceptions/exemptions are intended to provide 

flexibility, if needed, to growers to conduct certain otherwise prohibited activity

during a time period when exposure to pesticide residues is of concern. 

There are currently two nationwide exceptions and one exemption for which third 

party notification would be required. They include some circumstances for 

conducting irrigation activities, some circumstances for conducting activities 

which result in limited contact with pesticide treated surfaces, and some 

circumstances for conducting crop advising activities, all during a restricted entry

interval following pesticide application. 

(ii) Respondent Activities

In assuring that training is provided to their workers and handlers and providing WPS 

notifications, agricultural employers generally engage in the following activities:

Activity Description

Learn rule requirements Read WPS, 40 CFR Part 170, and read specific pesticide labels.

Acquire poster and warning 

signs

Create own pesticide safety poster and warning sign, obtain poster 

and signs free if available from EPA and States, or purchase for low 

cost from commercial supply.

Fill in medical information on 

safety poster and post specific 

application information

Fill in the name of the nearest medical care facility on the centrallydisplayed pesticide safety poster; record the location and description 

of the treated area, the product name, and active ingredient(s) of the 

pesticide, the time and date the pesticide is to be applied, and the 

restricted-entry interval for the pesticide at a central location for 

each pesticide application. 

Post notices or provide oral 

notification

Post the basic pesticide safety poster at a central location; post 

warning signs at usual points of entry or in corners of the treated 

area for each application or provide oral notification to workers 

Arrange for training of workers 

and pesticide handlers

Become an authorized WPS trainer or arrange for state personnel or 

other qualified trainer to train workforce. Arrange for training all 

new employees within 5 days of their employment. 
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Issue and review training 

verification cards

Obtain verification cards and issue to workers or handlers after 

training is completed or arrange for an authorized WPS trainer to 

provide verification cards.

Provide treatment information 

to employers, handlers and 

medical personnel

For pesticide treatments performed for hire, notify the agricultural 

employer of the specifics of the treatment (time, product used, 

REI's, etc.) and ensure that handlers have label information available 

during application. If a medical emergency exists, provide medical 

personnel with specific information from the pesticide label and the 

circumstances of application.

Notify workers and handlers of 

terms of exceptions/exemptions 

allowing for tasks to be 

performed in treated areas 

When using WPS exceptions or exemptions, the agricultural 

employer must explain the exception to the workers and handlers.

5. THE INFORMATION COLLECTED – AGENCY ACTIVITIES, COLLECTION 

METHODOLOGY, AND INFORMATION MANAGEMENT

5(a). Agency Activities

Not applicable. This ICR involves activities conducted by third parties. EPA does not 

collect any information under this ICR. Participating States are responsible for implementing 

voluntary training verification programs.

5(b). Collection Methodology and Management

Not applicable. This ICR involves activities conducted by third parties. EPA does not 

conduct any activities under this ICR. Participating States are responsible for implementing 

voluntary training verification programs. 

5(c). Small Entity Flexibility

The protections of the WPS depend upon workers receiving the various training and 

notifications contained in the rule. These cannot be reduced for small establishments without 

seriously compromising the protections offered to workers and handlers. As such, small entities 

are required to follow the same requirements as larger establishments under the WPS, unless 

exempted as a solely family-operated establishment under 40 CFR 170.204(a). Under this 

exemption, the owner of an agricultural establishment is not required to provide certain 

protections to himself or members of his immediate family who are performing handling tasks on 

their own agricultural establishment. 

5(d). Collection Schedule

Not applicable. This ICR involves activities conducted by third parties. EPA does not 

conduct any activities or collect any information under this ICR. Participating States are 

responsible for implementing voluntary training verification programs.
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6. ESTIMATING THE BURDEN AND COST OF THE COLLECTION 

Estimated burden hours and cost associated with training and information exchanges 

required by the Worker Protection Standard are detailed in this section. These estimates are listed 

in Table 1 in section 6(b) and are based on the agricultural establishment and employment 

figures used in the WPS regulatory impact analysis, as well as information obtained by the 

Agency during the implementation of the WPS and from contacts at the state level and within the 

US Department of Agriculture (USDA).

6(a). Estimating Respondent Burden

New entrant rule familiarization

There are an estimated 309,085 establishments that hire labor and use pesticides, and are 

therefore affected by the WPS requirements. New agricultural employers must learn the rule 

requirements when they enter the industry. It is assumed that of the affected entities, as many as 

50,000 may be new entrants each year. It is further assumed that learning the requirements of 

the rule takes an average of 30 minutes.

Central Information. 

It is assumed that there is one centrally-posted safety poster per establishment that hires 

labor and uses pesticides (309,085). However, as the poster could last indefinitely, not all 

establishments need a new poster every year. It is assumed that affected establishments put up a 

safety poster once every 3-4 years, with an assumption of 100,000 safety poster events annually. 

It is also assumed that an average of 10 minutes is needed to fill in medical information on the 

safety poster, and to post it.

For treatment-specific information, it is assumed that there will be one centrally posted 

notice per pesticide treatment per establishment that hires labor. It is also assumed that it will 

take an average of ten minutes for employers to post the notice. 

Annual notifications equal the number of establishments that use pesticides and hire labor 

(309,085) multiplied by the average number of pesticide treatments (approximately 3.5) per 

establishment. The average number of pesticide treatments (3.5) is a good proxy only if each 

time a grower applied a pesticide he treated his entire acreage that normally is treated in a year. 

This is not always the case since many grow multiple crops, and even within a single crop a 

farmer may not treat all acres the same, or not all at once. A correction for this is to multiply the 

average number of pesticide treatments by an assumed factor of 3 (EPA estimate based on 

general knowledge) to equal an average of approximately 10.5 pesticide treatments per 

establishment, and accordingly, an estimated 3,245,393 treatment-specific central notification 

events.

Training

The estimated burden and cost to farmers for the time taken to train workers and pesticide 
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handlers is based on the Agency’s experience obtained during the implementation of the WPS, as 

well as from additional information provided by personnel from the USDA and state agricultural 

agencies. The number of events is based on either the number of agricultural establishments or 

individuals involved, or a multiple of this number based on the estimated number of occurrences 

per year. The time for each event is based on field experience in accomplishing such events and 

is for a typical year.

Training verification.

Upon the completion of the training, the WPS provides for the issuance of "EPAapproved Worker Protection Standard training certificates" to workers and handlers to allow 

employers to verify that workers and handlers have received WPS safety training. The EPA 

Training Verification Program is a voluntary program and the issuance of the training 

verification cards is not a WPS requirement. However, agricultural employers are relieved of the 

responsibility of safety training if their agricultural workers and pesticide handlers possess valid 

EPA training verification cards. Participating States will issue the cards to qualified training 

providers within the State. The program is intended to assist in substantiating WPS pesticide

safety training, minimize the need for retraining (given the migrant nature of much of the 

workforce), offer an uncomplicated system for verifying training, provide a means for training 

quality control, and allow states flexibility in administering the program. The verification activity

has a total annual burden of 4,765 burden hours (sum of burden to gather information and file or 

disclose information) and is covered in this ICR. 

Treatment-Specific Worker and Handler Notification.

It is assumed that: employers either orally notify workers of pesticide treatments or post 

treated areas (except for pesticides which are Toxicology Category I for dermal or eye, which 

require both); greenhouses will always post treated areas, and all others will always orally notify

workers; for non-greenhouse establishments notification (one oral and/or one posted) is 

necessary for each pesticide treatment when workers will be within 1/4 mile of the treated area 

during the restricted entry interval (REI); oral notification takes 5 minutes; posted notification 

takes 8 minutes.

Total oral notification events are calculated as the number of oral notifications on nongreenhouse establishments, which orally notify workers of all treatments when workers will be 

within 1⁄4 mile, plus the number of oral notifications on greenhouse establishments, which orally 

notify workers only for Toxicity Category I treatments. Therefore, for all establishments other 

than greenhouses, multiply the number of establishments which hire labor and use pesticides 

(309,085) by the average number of pesticide treatments per establishment per year (10.5), and 

multiply by the average percent probability that workers will be within 1/4 mile of the treated 

area during the REI (50%). For greenhouses, multiply the number of establishments (11,350) by

the average number of treatments made per greenhouse establishment per year (50), and multiply

by the percent of treatments which are Toxicology Category I for dermal or eye (5%).

Calculations for Annual Number of Oral Notifications
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Non-greenhouse establishments 

309,085 establishments * 10.5 treatments annually * 50% probability of workers present 

within 1⁄4 mile of the treated area during re-entry interval = 1,622,696 oral notifications 

annually by non-greenhouse establishments

Greenhouse establishments

11,350 establishments * 50 treatments annually * 5% of treatments involving pesticides 

that are classified as Toxicology Category I for dermal or eye = 28,375 oral 

notifications annually by greenhouse establishments

Total Annual Number of Oral Notifications

1,651,071 (i.e., 1,622,696 + 28,375)

Total posted notifications are calculated as the number of posted notifications on nongreenhouse establishments, which do posted notifications only for Toxicity Category I treatments 

and when workers will be within 1⁄4 mile, plus the number of posted notifications on greenhouse 

establishments, which do posted notifications for all treatments. Therefore, for all 

establishments other than greenhouses, multiply the number of establishments (309,085) by the 

average number of pesticide treatments per establishment per year (10.5), multiply by the percent 

of treatments which are Toxicology Category I for dermal or eye (5%), and multiply by the 

average percent probability that workers will be within 1/4 mile of the treated area during the 

REI (50%). For greenhouses, multiply the number of establishments (11,350) by the average 

number of treatments made per greenhouse establishment per year (50).

Calculations for Annual Number of Posted Notifications

Non-greenhouse establishments 

309,085 establishments * 10.5 treatments annually * 50% probability of workers 

present within 1⁄4 mile of the treated area during re-entry interval * 5% of treatments 

involving pesticides that are classified as Toxicology Category I for dermal or eye = 

81,135 posted notifications annually by non-greenhouse establishments

Greenhouse establishments

11,350 establishments * 50 treatments annually = 567,500 posted notifications 

annually by greenhouse establishments

Total Annual Number of Posted Notifications

648,635 (i.e., 81,135 + 567,500)

Handler and Emergency Information.

Using the estimates for worker and handler notification and training, the number of 

events for handler-initiated notifications and the number of handler sessions on safe equipment 

operations was estimated. It was assumed that each commercial application would trigger a 

handler notification to the agricultural employer and that the same number of handlers would 

need instruction in safe equipment operation as would need the pesticide safety training.
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It was also assumed that 1% of workers and handlers trained in any given year would 

require medical attention and request that pesticide-specific emergency information be provided 

to medical personnel. These workers and handlers are the most likely to be entering treated areas 

during the course of their employment. 

Exceptions/Exemptions Notification.

There are 279,359 farms with irrigation in the United States (1992 Census). The average 

annual number of pesticide applications is estimated to be 3.5 for irrigated acres. It is assumed to 

take about 2.5 minutes to supply the information to the irrigation workers. It is further assumed 

that 20% of the pesticide treatments would invoke the irrigation exception. The same working 

assumptions have been applied to the limited contact exception.

Crop advisors often enter fields, orchards, or other crop production areas to scout for 

pests, monitor the effectiveness of recent pesticide treatments, and determine the need and timing 

for additional treatments. The crop advisor exemption allows for entry into treated areas during 

a restricted entry interval in certain circumstances. It is estimated that there are 10,000 such 

instances annually for crop advisors when the crop advisor employer is required to notify their 

employees who will enter the treated area, of the restricted entry status and use of the exemption. 

The estimated average burden for notification of the crop advisor exemption is 15 minutes. This 

average burden is considerably longer than for notification of the two exceptions, discussed 

above. The longer time is primarily because the crop advisor work may involve more contact 

with treated plant surfaces than the exceptions do, and crop advisors must be advised of the 

necessary personal protective equipment to be used for the specific crop, pesticide, and situation.

6(b). Estimating Respondent Costs

Agency economists revised the estimated wages, benefits and overhead for all labor 

categories for affected industries, state government, and EPA employees based on publicly

available data from the US Bureau of Labor Statistics. The formulas used to estimate the labor 

rates and formulas used to derive the fully loaded rates and overhead costs for this ICR renewal 

are presented in Attachment D.

Methodology: The methodology uses data on each sector and labor type for an Unloaded 

wage rate (hourly wage rate), and calculates the Loaded wage rate (unloaded wage rate + 

benefits), and the Fully loaded wage rate (loaded wage rate + overhead). Fully loaded wage rates 

are used to calculate respondent costs. This renewal uses 2009 data.

Unloaded Wage Rate: Wages are estimated for labor types (management, technical, and 

clerical) within applicable sectors. The Agency uses average wage data for the relevant sectors 

available in the National Industry-Specific Occupational Employment and Wage Estimates from 

the Bureau of Labor Statistics (BLS) at http://www.bls.gov/oes/current/oes_nat.htm. 

Sectors: The specific North American Industry Classification System (NAICS) code and 

website for each sector is included in that sector’s wage rate table (see Attachment G). Within 
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each sector, the wage data are provided by Standard Occupational Classification (SOC). The 

SOC system is used by Federal statistical agencies to classify workers into occupational 

categories for the purpose of collecting, calculating, or disseminating data (see 

http://www.bls.gov/oes/current/oes_stru.htm ).

Loaded Wage Rate: Unless stated otherwise, all benefits represent 43% of unloaded 

wage rates, based on benefits for all civilian non-farm workers, from 

http://www.bls.gov/news.release/ecec.t01.htm. However, if other sectors are listed for which 

43% is not applicable, the applicable percentage will be stated.

Fully Loaded Wage Rate: We multiply the loaded wage rate by 50% (EPA guidelines 

20-70%) to get overhead costs.

The total respondent burden is estimated to be 1,776,131 hours annually. The total 

respondent cost for this ICR renewal is estimated to be $82,462,645 annually. The labor rates 

for the farm workers and growers subject to the WPS requirements ($19.87/hr and $53.89/hr, 

respectively) were estimated using the methodology cited above. Workers’ burden hours and 

cost estimates are included in Table 1 and in the total burden and cost for this information 

collection because workers must spend the time necessary to receive training and notifications 

from their employers. However, the requirements for all training/notifications are on the 

employer. It is assumed that workers are generally paid during training/notifications. Therefore, 

the burden and cost are effectively borne by the agricultural employer, even though the workers’ 

time and wage rate are also used in the estimation.
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Table 1 - Total Annual Burden and Cost Estimates

Category Activity Total No. Per Event Average TOTALS1

People/ Events

Grower ($53.89r)2 Worker ($19.87hr.)2 Total per Event

Burden

(hours)

Cost

Burden ($)

(minutes)

Cost

($)

Burden

(minutes)

Cost

($)

Burden

(minutes)

Cost

($)

New Entrant Rule 

Familiarization

Learn requirements (new 

entrants) 50,000 30 26.95 0 0.00 30.00 26.95 25,000 1,347,500

Central Information

Safety Poster 100,000 10 8.98 0 0.00 10.00 8.98 16,667 889,000

Treatment-specific 

information 3,245,393 10 8.98 0 0.00 10.00 8.98 540,899 29,143,629

Training

Basic Safety Info 

Conveyance 169,000 2 1.79 0 0.00 2.00 1.79 5,633 302,510

Ag. Worker Training 339,000 20 17.96 20 6.62 40.00 24.58 226,000 8,332,620

Pesticide Handler Training 185,000 25 22.45 20 6.62 45.00 29.07 138,750 5,377,950

Training 

Verification

Gather Information 35,733 5 4.49 0 0.00 5.00 4.49 2,978 160,441

File or Disclose Info 35,733 3 2.70 0 0.00 3.00 2.70 1,787 96,479

Treatment-specific 

worker/handler 

Notification

Oral Notifications 1,651,071 5 4.49 0 0.00 5.00 4.49 137,589 7,413,309

Posted Notifications 648,635 8 7.19 0 0.00 8.00 7.19 86,485 4,663,686

Handler and 

Emergency 

Information

Handler Notice of Ag. 

Employer & Labeling Info.

1,875,705 10 8.98 5 1.66 15.00 10.64 468,926 19,957,501

Safe Operation and Repair 185,000 10 8.98 10 3.32 20.00 12.30 61,667 2,275,500

Provide Emergency Info. 

on Pesticide Treatments

52,400 20 17.96 10 3.32 30.00 21.28 26,200 1,115,072

Exceptions/ 

Exemptions 

Notification

Irrigation Exception 195,300 2.5 2.25 2.5 0.83 5.00 3.08 16,275 601,524

Limited Contact Exception 195,300 2.5 2.25 2.5 0.83 5.00 3.08 16,275 601,524

Crop Advisor Exemption 10,000 15 13.47 15 4.97 30.00 18.44 5,000 184,400

TOTALS 1,776,131 82,462,645

 

1 Totals were determined as follows: Total Burden Hours: (total # events x burden minutes)÷60. Total Costs: (total # events x total per-event costs).

2 Updated estimates of fully loaded wage rates based on NAICS Sector 11. Source: US Bureau of Labor Statistics http//www.bls.gov/oes/current/naics2_11.htm 

See part 6(b) and Attachment D for sources and methodology for deriving these estimates.
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6(c). Estimating Agency Burden and Cost

Not applicable. This ICR involves activities conducted by third parties. EPA does not 

conduct any activities or collect any information under this ICR. Participating States are 

responsible for implementing voluntary training verification programs. As such, EPA does not 

incur any burden or cost under this ICR.

6(d). Bottom Line Burden Hours and Cost Tables

Bottom Line Estimated Burden Hours And Costs

Hours Costs

Respondents 1,776,131 $82,462,645

Agency n/a n/a

6(e). Reasons for Changes in Burden

The total estimated annual respondent burden for this ICR renewal is 1,776,131 hours, 

which has not changed from the currently-approved ICR. 

6(f). Burden Statement

The total annual respondent burden for providing the training and notifications associated 

with the Worker Protection Standard is estimated to be 1,776,131 hours, with the incremental 

burden of the various activities ranging from 2 minutes per respondent to provide initial basic 

safety information to 45 minutes per respondent for handler training. This total estimate includes 

the third party WPS training and notification requirements, e.g., provisions requiring employers 

to: provide employees with pesticide-specific treatment (application) information in the form of 

oral or written notification, assure that employees receive basic pesticide safety information or 

training, provide emergency information on pesticide treatments, and notify employees when an 

exception/exemption to the WPS is being implemented, as well as a voluntary program to verify

training and relieve duplication of training, and provisions requiring handler notification to 

employers regarding pesticide treatments (applications).

According to the Paperwork Reduction Act, “burden” means the total time, effort, or 

financial resources expended by persons to generate, maintain, retain, disclose, or provide 

information to or for a Federal agency. The agency may not conduct or sponsor, and a person is 

not required to respond to, a collection of information unless it displays a currently valid OMB 

control number. The OMB control number for this information collection appears at the 

beginning and end of this document. In addition OMB control numbers for EPA’s regulations, 

after initial display in the final rule, are listed in 40 CFR Part 9 (Attachment E). 

The Agency has established a public docket for this ICR under Docket ID No. EPA-HQOPP-2010-0896, which is available for online viewing at www.regulations.gov, or in person 

viewing at the OPP Regulatory Public Docket in Rm. S-4400, One Potomac Yard (South 
February 4, 2011

Page 16 of 17

Building), 2777 S. Crystal Drive, Arlington, VA. This docket facility is open from 8:30 a.m. to 4 

p.m., Monday through Friday, excluding legal holidays. The docket telephone number is (703) 

305-5805. You may submit comments regarding the Agency's need for this information, the 

accuracy of the provided burden estimates and any suggested methods for minimizing 

respondent burden, including the use of automated collection techniques. 

Submit your comments, referencing Docket ID No. EPA-HQ-OPP-2010-0896 and OMB 

Control No. 2070-0148, to (1) EPA online using www.regulations.gov (our preferred method), or 

by mail to: Public Information and Records Integrity Branch (PIRIB), Mail Code: 7502P, Office 

of Pesticide Programs (OPP), Environmental Protection Agency, 1200 Pennsylvania Ave., NW, 

Washington, DC 20460, and (2) OMB by mail to: Office of Information and Regulatory Affairs, 

Office of Management and Budget (OMB), Attention: Desk Officer for EPA, 725 17th Street, 

NW, Washington, DC 20503.
February 4, 2011

Page 17 of 17

ATTACHMENTS TO THE SUPPORTING STATEMENT

Attachments to the supporting statement are available in the public docket established for this 

ICR under docket identification number EPA-HQ-OPP-2010-0896. These attachments are 

available for online viewing at www.regulations.gov or otherwise accessed as described in 

section 6(f) of the supporting statement, and as noted below.

Attachment A: 7 U.S.C. 136w - FIFRA Section 25 - Also available online at the US 

House of Representatives’ US Code website

Attachment B: 40 CFR 170 - Worker Protection Standard - Also available online at the 

National Archives and Records Administration’s Electronic CFR Website

Attachment C: [Reserved for Record of Consultations]

Attachment D: Wage Rate Tables for Agricultural Employers and Agricultural 

Workers

Attachment E: Display Related to OMB Control #2070-0148 -Listings of Related 

Regulations in 40 CFR 9.1