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 SUPPORTING STATEMENT FOR 

AN INFORMATION COLLECTION REQUEST

1. IDENTIFICATION OF THE INFORMATION COLLECTION

1(a) Title of the Information Collection: 

TITLE: Notice of Supplemental Distribution of a Registered Pesticide Product

OMB No.: 2070-0044 EPA No.: 0278.11

1(b) Short Characterization/Abstract

This information collection activity notifies the Environmental Protection Agency (EPA) 

of supplemental distribution of registered pesticide products. As mandated by the Federal 

Insecticide, Fungicide and Rodenticide Act (FIFRA), as amended, EPA is responsible for the 

regulation of pesticides. Section 3 (e) of FIFRA (7 U.S.C. 136a (e)) allows pesticide products 

with the same formulation, label claims, and manufacturer as a registered product to be distributed 

under the same registration as the basic product (see Attachment A). Pesticide registrants may 

distribute or sell registered pesticides under a different product name in addition to the registered 

name, or under a different entity’s name and address. Such distribution and sale is termed 

“supplemental distribution” and the product is termed a “distributor product.” EPA requires 

pesticide registrants who enter into supplemental distribution agreements with other companies to 

submit EPA Form 8570-5, Notice of Supplemental Distribution of a Registered Pesticide Product

(see Attachment B). Supplemental registrations are only an extension of a currently federally 

registered pesticide product.

Distributor products must reflect any changes in formulation or labeling made to the basic 

registered product within the same timeframe imposed on that product. A distributor is considered 

an agent of the registrant; both the registrant and the distributor may be held liable for violations 

pertaining to the distributed product. In addition to notifying the Agency, an individual or entity 

may become a distributor upon meeting the regulatory conditions. Distributor products must be 

the same as the registered product, and may not be repackaged (must remain in the producer’s 

unopened container); distributor product labels must bear qualifications such as “distributed by,”

or “sold by;” the labeling must bear the same claims as the basic registered product -- with the 

exception of deletion of specific claims. In addition, although the distributed product’s name may

be different from that of the registered product, it may not be misleading. This information 

collection request (ICR) is a proposed renewal of an existing ICR currently approved by Office of 

Management and Budget (OMB) and is due to expire on July 31, 2013. 

2 NEED FOR AND USE OF THE COLLECTION

2(a) Need/Authority for the Collection

This information is required to be submitted pursuant to Section 3 (e) of FIFRA, as 
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amended. Regulations pertaining to supplemental distribution of pesticide products are contained 

in Title 40 CFR Part 152.132 (see Attachment C).

2(b) Practical Utility/Users of the Data

Section 3 (e) of FIFRA requires pesticide registrants to notify the Agency when they enter

into an agreement with a second company to distribute the registrant's product under the second 

company and product’s name. The distributor is considered an agent of the registrant for all 

intents and purposes under the Act, and both the registrant and the distributor may be held liable 

for violations pertaining to the distributor product. EPA’s Office of Pesticide Programs is 

responsible for maintaining information about supplemental distribution agreements.

3. NON DUPLICATION, CONSULTATIONS, AND OTHER COLLECTION 

CRITERIA

3(a) Non duplication

This is the only information collection activity of its kind, performed only once per receipt 

of a notice of distributor registration. Therefore, the possibility of duplication does not exist.

3(b) Public Notice Required Prior to ICR submission to OMB

Pursuant to 5 CFR 1320.8(d), EPA published a Federal Register (FR) Notice announcing 

this proposed information collection activity and providing a 60-day public comment period (77 

FR 69821; November 21, 2012). The Agency did not receive public comments.

3(c) Consultations

Under 5 CFR 1320.8(d)(1), agencies are required to consult with potential ICR 

respondents and data users about specific aspects of ICRs before submitting an original or renewal 

ICR to OMB for review and approval. During the development of this renewal ICR, EPA staff 

contacted supplemental distributors for their assessment of the regulatory burden estimates 

expressed by the Agency in this ICR. The list of representatives consulted, the questions posed 

and their responses are in attachment D. 

The respondents agree with the overall burden estimates expressed in the supporting 

statement. Regarding duplication of data collected under this ICR, one of the respondents stated 

that the information collected can be found at the State level, and if EPA coordinated with State 

data, the Agency would not need to collect information. 

The Agency agrees that many States’ requirements for supplemental distribution are 

virtually the same as EPA’s: EPA registration of the primary product, the same label claims and 

product formulation, and proof of notification to EPA that a registrant has entered into a 

distributor agreement. Most States conduct a review of the pesticide label to ensure compliance

with federal labeling requirements and any additional state restrictions of use. In the case of 
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supplemental distribution, States also require that EPA Form 8570-5 be submitted, with the 

primary product registered by EPA, and the primary product label approved by EPA

In addition, federal law requires that pesticides first to be registered or licensed by EPA to

be sold or distributed in the United States. Furthermore, registrants cannot legally enter into 

distribution agreements without first notifying EPA and providing distributor product and 

company information. This means distributor information would not be available to States 

without the reporting activity in this ICR. Therefore, it is not possible for EPA to obtain the 

information collected under this ICR from States.

 

3(d) Effects of Less Frequent Collection

This activity is only conducted once per "event" (one notification is submitted per

product); it is not possible to reduce the frequency of the collection. EPA must maintain the 

current frequency of this collection in order to avoid violating FIFRA Section 3 (e).

3(e) General Guidelines

Long-term recordkeeping: The only PRA-imposed guideline in 5 CFR 1320.6 that may 

be exceeded in this collection is the record-keeping retention period. The registrant and the 

distributor are expected to maintain copies of their distribution agreement (EPA Form 8570-5) as 

long as the registration is valid or until the parties notify EPA that they have voluntarily dissolved 

the distribution agreement. Registrations are valid unless they are voluntarily canceled or 

withdrawn by the registrant or until EPA has cause to suspend or cancel the registration as a result 

of the Registration Review Program or an adverse finding by the Agency. 

Since the average period of marketability of a pesticide ranges from 15 to 30 years, the 

PRA-imposed guideline indicating that data, other than health, medical, or tax records need not be 

retained for more than 3 years generally will be exceeded in this program.

Electronic submissions: OMB regulations require agencies to provide a statement 

indicating whether the proposed collection of information involves the use of automated, 

electronic, mechanical, or other technological collection techniques or other forms of information 

technology, e.g., permitting electronic submission of responses, and an explanation of the decision 

(5 CFR 1320.5(a)(iii)(E)). At this time, OPP is not offering a fully electronic submission option. 

As this information collection request indicates, both the basic product registrant and the 

distributor must sign the required notification. While EPA Form 8570-5 is available and fillable 

online, the form currently needs to be printed out to be signed and mailed. 

The Agency is actively working to extend full electronic submission options in keeping 

with the June 22, 2012 OMB memo on "Reducing Reporting and Paperwork Burdens" and other 

related policy and guidance. In the future, the Agency hopes to offer a fully electronic version of 

this form, including electronic signature and submission, through the Agency's Central Data 

Exchange (CDX). Electronic submission should reduce the time needed to complete the form and 

the activities described in Sections 4 and 5 of this ICR while improving the overall quality of 

submissions.
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3(f) Confidentiality

Product distributorship data submitted by basic product registrants under FIFRA Section 

3(e) are considered by the Office of Pesticide Programs (OPP) to contain no confidential business 

information (CBI). 

3(g) Sensitive Questions

No information of a sensitive or private nature is requested in conjunction with this 

information collection activity. Further, this information collection activity complies with 

provisions of the Privacy Act of 1974 and OMB Circular A-108.

4. THE RESPONDENTS AND THE INFORMATION REQUESTED

4(a) Respondents/NAICS Codes

Individuals or firms engaged in registration and distribution of pesticide products. The 

North American Industrial Classification System (NAICS) code for businesses participating in this 

program is 325320 (Pesticide and other Agricultural Chemical Manufacturing). 

4(b) Information Requested

 (i) Data Items, Including Record Keeping Requirements

Pursuant to 40 CFR 152.132, supplemental distribution of a registered pesticide is 

permitted if the registrant meets all of the conditions and submits a completed and signed EPA 

Form 8570-5, Notice of Supplemental Distribution of a Registered Pesticide Product. Sub-section 

152.132 (a) requires the registrant to furnish the following information:

• EPA registration number of the product to be distributed;

• EPA-assigned distributor company number; 

• Name of the registered product to be distributed;

• Name and address of the basic product registrant;

• Name to be used on the distributed product;

• Name and address of the distributor;

• Signature and title of the distributor and date signed; and 

• Signature and title of the basic product registrant and date signed.

(ii) Respondent Activities

For each distributor product, the basic product registrant must send to EPA a completed 

Form 8570-5, signed by both the basic product registrant and the distributor (see Attachment E for 

instructions and EPA’s requirements). Responsibility for regulatory compliance rests primarily 

with the basic product registrant. However, both the registrant and the distributor may be held 
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liable for any violation of FIFRA. 

A registrant wishing to distribute a registered product under a different name or through a 

different company goes through the process summarized below:

Summary of Steps to Notify EPA of Supplemental Distribution Agreement

Read Read form and instructions;

Request If necessary, obtain an EPA company number for the supplemental distributor;

Compile Assemble information; review for accuracy and completeness;

Submit Submit EPA Form 8570-5 to the Agency; 

Store File or otherwise maintain the information.

Before distribution and sale of EPA-registered pesticides, a company must have an EPAassigned company number. If the distributor company is different from the registrant of the 

product and has not previously obtained an EPA company number, the company needs to obtain

one before submitting the form to EPA (see Attachment F for instructions on how to obtain an 

EPA company number). 

The Agency estimates that one-third of the responses submitted to EPA on Form 8570-5 

are completed using newly-assigned company numbers. This is a conservative estimate because 

the number of entities submitting requests to EPA for company number assignment as part of the 

process for a supplemental distribution agreement is often very low compared to the total number 

of forms that use newly-assigned distributor company numbers. The primary reason for such a

discrepancy is that companies often establish multiple distribution agreements for multiple 

products, either with the same or with different registrants, and notifications for all of those

products get submitted around the same time period. The exact number of company number 

requests that are submitted specifically for the purposes of becoming a distributor cannot be 

determined at this time, and EPA has used a larger estimate of one-third.

5. THE INFORMATION COLLECTED - AGENCY ACTIVITIES, COLLECTION 

METHODOLOGY, AND INFORMATION MANAGEMENT

5(a) Agency Activities

Upon receipt of Notices of Supplemental Distribution of a Registered Pesticide Product, 

EPA Form 8570-5, the front-end process involves the following activities:

• receive distribution notices

• pin-punch forms with date of receipt

• make copies of the forms

• screen forms for completeness of information; contact the registrant when needed

• send letters of receipt to the registrants, including copies of the pin-punched forms
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• if items need to be corrected, include a correction checklist with the letter

• send forms for review and follow up by product teams where the original product 

was registered;

• enter information from reviewed forms in database under the basic registration file

• scan original forms into an electronic filing system

Consistent with labeling regulation 40 CFR 156.10, starting in 2010, a product team 

reviews the product information submitted on the form. The team verifies the registered product

information and ensures that the distributor product name is in compliance with labeling as well as 

supplemental distribution regulations. If needed, EPA staff follows up with the registrant through 

the OPP division where the original product is registered. After product team review, the 

information is entered in an electronic database under the original registration of the product. The 

pin-punched forms are maintained in electronic records.

Summary of Steps for Reviewing and Recording Notification Information

Assign Assign an EPA company number to the supplemental distributor if the 

company does not already have one.

Verify Verify the regulatory status of the primary registration that is to be 

supplementally distributed;

Acknowledge receipt Provide receipt of the supplemental distribution notice by mailing a copy of it 

to the distributor company;

Product information 

review

Check distributor product information; if necessary, follow-up with registrant; 

make decisions.

Process information Enter information from EPA Form 8570-5 (Notice of Supplemental 

Distribution of a Registered Pesticide Product) into an electronic "Distributor 

File," a part of the Office of Pesticide Programs Integrated Network (OPPIN);

File and maintain 

information 

Electronically file date-stamped form in the regulatory file of the parent 

Section 3 registration. This file is maintained by the Office of Pesticide 

Programs at the Information Services Center.

5(b) Collection Methodology and Management

Registrants voluntarily enter into agreements with distributors. They are required, under 

FIFRA, to notify the Agency of these agreements. EPA maintains the original notifications in the 

regulatory file of the parent Section 3 registration at the Office of Pesticide Programs Information 

Services Center.

5(c) Small Entity Flexibility

Most of the companies participating in this program would qualify as small entities. The 

Agency closely examined potential burdens to small entities and instituted changes to this program 

in 1984. At that time, OMB approved the changes. The Agency also re-evaluated the general 

burden categories in 1986. The Agency believes that the burden imposed by this activity has been 

minimized to what is believed to be the minimal level at which this program can effectively 
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function under the requirements specified in the FIFRA and the regulations for the enforcement of 

FIFRA.

5(d) Collection Schedule

Not applicable. This activity is conducted only once per "event" when the registrant 

submits a Notice of Supplemental Distribution of a Registered Pesticide Product, to the Agency. 

Therefore, there is no set schedule for collection of this information.

6. ESTIMATING THE BURDEN AND COST OF THE COLLECTION

6(a) Estimating Respondent Burden

The burden associated with this collection of information is estimated to be approximately 

19 minutes per response. The respondent burden estimate on the per-response basis has changed 

slightly from previous years due to a previously unaccounted-for activity which is conservatively 

estimated to apply to one-third of the responses submitted. 

To complete Form 8570-5, a distributor’s EPA-assigned company number must be 

included. Distributors without an EPA company number must send a formal request letter on 

company letter-head to the Agency to get one assigned (Attachment F). EPA estimates that onethird of the responses submitted to EPA on Form 8570-5 are completed using newly-assigned 

company numbers. This is a conservative estimate; the actual number may be much lower 

because companies often enter into distributor agreements to distribute two or more registered 

products. The number of entities submitting requests to EPA for company number assignment 

during the reporting period is far fewer than the total number of forms that use newly-assigned 

distributor company numbers. The exact number of company number requests that are submitted 

specifically for the purposes of becoming a distributor cannot be determined at this time, and EPA 

has used the larger estimate of one-third. The additional step is estimated to add 4.8 minutes to 

the previously approved total per-response burden of approximately 14.5 minutes. Therefore, the 

total respondent burden is estimated to be 19 minutes per response.

However, due to an overall decrease in the number of supplemental distribution 

notifications received by the Agency over the last several years, the total burden hours have also 

decreased. Whereas EPA had expected to receive about 1,895 notice submissions annually over 

the past 3 years, based on the actual number of submissions received annually over that period 

(1,764 in FY2009, 1,365 in FY2010, and 1,224 in FY2011), the Agency now expects to receive 

only 1,451 notice submissions annually over the next 3 years. Given this change, EPA estimates 

the total annual burden associated with the notice of supplemental distribution of a registered 

pesticide product to be 387 hours, as shown below:

Total annual notification burden for forms without additional step (obtaining 

EPA-assigned company number)

= number of ALL responses per year x time to complete notification 

without additional step
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= 1,451 x 0.24 hours 

= 248.24 hours

Total annual notification burden for forms with additional step (obtaining EPAassigned company number)

= number of responses needing company numbers assigned per year x time 

to obtain EPA-assigned company number

= (1,451 x 1/3) x 0.08 hours

= 38.72 hours

Total annual respondent burden = 387 hours

6(b) Estimating Respondent Costs

Consistent with recent ICR renewals, OPP is using labor cost estimates from Agency 

economists with respect to wages, benefits and overhead for all labor categories for affected 

industries, state government, and EPA employees. This approach uses a transparent and

consistent methodology and current publicly-available data to provide more accurate estimates and 

allow easy replication of the estimates.

Table 1. Methodology Used to Calculate Labor Costs

Labor Cost 

Approach

Description

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 data from 2011, 

which is the most recent.

Unloaded 

Wage Rate:

Wages are estimated for occupations (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. Within 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:

Benefits represent 43% of unloaded wage rates, based on benefits for all civilian nonfarm workers, from http://www.bls.gov/news.release/ecec.t01.htm. 

Fully Loaded 

Wage Rate:

The loaded wage rate is multiplied by 50% (EPA guidelines 20-70%) to get overhead 

costs.

 

A copy of the formula work sheets used to estimate the labor rates and to derive the 
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registrants’ fully loaded rates and overhead costs for this renewal are listed in Attachment G.

Table 2. Estimated Respondent Burden/Cost per Supplemental Distribution Application 

REGISTRANT HOURS, RATES TOTAL

Collection Activities

Mgmt, $/hr Technical, $/hr Clerical, $/hr

$ 124.10 $ 61.21 $ 36.79 Hours Costs

Read instructions 0.08 - - 0.08 $9.93 

Process, compile, review 

information for accuracy and 

appropriateness 0.05 - - 0.05 $6.21 

If necessary, obtain an EPA 

company number for the 

supplemental distributor - - 0.08 0.08 $2.94 

Complete and submit EPA Form 

8570-5 0.03 - - 0.03 $3.72 

Store, file, or maintain 

information - - 0.08 0.08 $2.94 

Total 0.16 0.00 0.16 0.32 $23.78 

ANNUAL BURDEN: 387 Hours

ANNUAL COSTS: $34,505 

6(c) Estimating Agency Burden and Cost

To determine Agency costs, the Agency used the Bureau of Labor Statistics estimates of 

labor rates for the North American Industry Classification System code for the Federal Executive 

Branch (NAICS 999100).

Table 3 summarizes the Agency process in reviewing the supplemental distribution 

applications, with associated hours and costs for each task. A copy of the formula work sheets 

used to estimate the labor rates and to derive the Agency’s fully loaded rates and overhead costs 

for this renewal are listed in Attachment H.

Table 3. Estimated Agency Burden/Cost per Supplemental Distribution Application 

REGISTRANT HOURS, RATES * TOTAL

Collection Activities Mgmt, $/hr Technical, $/hr Clerical, $/hr Hours Costs

$ 120.32 $ 77.85 $ 44.05 

If necessary, assign an EPA 

company number to the 

supplemental distributor.

- - 0.08 0.08 $3.52 

Verify, acknowledge receipt1 - - 0.03 0.03 $1.51 

• Initial product screening2 - 0.36 - 0.36 $27.90 

• Product review meeting2 0.63 - - 0.63 $75.46 
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• Process disapproved 

product distribution 

information2

- 0.42 - 0.42 $32.42 

Process: Enter form information 

into electronic file in OPPIN - 0.50 - 0.50 $38.93 

File and maintain information - 0.02 - 0.02 $1.30 

Total 0.63 1.29 0.03 1.95 $52.78 

* U.S. Department of Labor, Bureau of Labor Statistics. (2012) May 2011 National Industry-Specific Occupational 

Employment and Wage Estimates; NAICS 999100 – Federal Executive Branch (OES Designation). Available from

BLS Web site at http://www.bls.gov/oes/current/naics4_999100.htm 1 Approximately 90% of forms received by EPA are completed correctly and undergo standard processing, 

requiring only clerical and technical labor types. 

2 The rest of the forms (approximately 10%) require review by the Agency's product review team, requiring 

all three types of labor.

The total annual Agency burden associated with the notice of supplemental distribution of 

a registered pesticide product is 970 hours. This represents an increase over the Agency burden 

estimated for the 2009 ICR (625 hours) due to a review process that was implemented in 2010. 

The tasks marked by the superscript 2 represent the new review process in which some of the 

product information must be reviewed by the Agency to determine that supplemental distributed 

product names are consistent with 40 CFR 156.10 (5) and are not “misleading.” The annual total 

Agency cost is $76,589, increased from $25,905 of the 2009 ICR.

6(d) Bottom Line Burden Hours and Cost Tables

Total Annual Respondent and Agency Burden and Costs

Total

Hours Costs

Annual Respondent Burden/Cost Estimates 387 $34,505 

Annual Agency Burden/Cost Estimates 970 $76,589

6(e) Reasons for Change in Burden

The total annual respondent burden associated with the notice of supplemental distribution 

of a registered pesticide product is 387 hours, a 68 hour decrease from 455 hours estimated in the 

ICR from 2009. This decrease is an adjustment. The average number of supplemental 

registrations received by the EPA over the last three years is approximately 1,451 responses per 

year (1,764 in FY2009, 1,365 in FY2010, and 1,224 in FY2011). Based on these numbers, the 

Agency estimates that it will receive an average of 1,451 supplemental registrations annually for 

the next three years. 

6(f) Burden Statement

The total estimated annual respondent paperwork burden to comply with this information 

collection activity is 387 hours, or about 19 minutes per response, adjusted up from 15 minutes per 
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response from the last renewal. The per-response increase is due to the inclusion of a required 

step in the notification process that was not previously considered as part of this ICR but is 

estimated to apply to a third of the responses. This estimate includes the time needed to review 

instructions; utilize technology and systems for the purposes of collecting, validating, and 

verifying information, processing and maintaining information, and disclosing and providing 

information; adjust the existing ways to comply with any previously applicable instructions and 

requirements; train personnel to respond to a collection of information; search existing data 

sources; complete and review the collection of information; and transmit or otherwise disclose the 

information. An 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 numbers for EPA’s regulations in title 40 of the CFR, after appearing in the Federal 

Register, are listed in 40 CFR part 9, and included on the related collection instrument or form, if 

applicable (see Attachment I).

The Agency has established a public docket for this ICR under Docket ID No. EPA-HQOPP-2012-0544, 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 

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-2012-0544 and OMB 

Control No. 2070-0044, 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.
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ATTACHMENTS LIST

All of the attachments listed below can be found in the docket for this ICR (unless otherwise 

noted), accessible electronically through www.Regulations.gov . On the main page, select 

Advanced Search from the menu bar at the top and select Docket Search. Enter the Docket ID 

Number, EPA-HQ-OPP-2012-0544, in the Docket ID field. Click on the Submit button. From 

the results page, you will be able to link to the docket view or directly open select documents 

found in the docket.

Attachment A 7 U.S.C. 136a – Section 3 of FIFRA. Also available at online at the US House 

of Representatives’ US Code website.

Attachment B

EPA Form 8570-5 - Notice of Supplemental Distribution of a Registered 

Pesticide Product 

Also online at http://www.epa.gov/opprd001/forms/8570-5.pdf

Attachment C

40 CFR Part 152.132 - Obligations and Rights of Registrants -

Supplemental Distribution. Also available online at the National Archives 

and Records Administration’s Electronic CFR Website.

Attachment D Consultations: List of Standard Questions and Industry Responses

Attachment E

Requirements for Approval of Supplemental Distribution 

Also available at: 

http://www.epa.gov/opprd001/registrationmanual/chapter9.html

Attachment F How to Obtain an EPA Company Number

http://www.epa.gov/pesticides/registrationkit/company-num_addr-chg.pdf

Attachment G Work Sheets used to Calculate Registrant Labor Costs

Attachment H Work Sheets used to Calculate EPA & Federal Government Labor Costs 

Attachment I

Display Related to OMB Control #2070-0044 – Listings of Related 

Regulations in 40 CFR 9.1

Also available online at the National Archives and Records Administration’s

Electronic CFR Website.