1

Consultation Questionnaire for OPP ICR:

Compliance Requirement for Child-Resistant Packaging

OMB Control # 2070-0052)

• Completed by:

Amy Plato Roberts

Technology Sciences Group, Inc.

712 5th Street, Suite A, 

Davis, CA 95616, 

Telephone: (530) 757-1432, 

Email: ARoberts@TSGUSA.COM

Updated ICR Document:

A list of the consultation questions asked and the responses thereto become a part of the 

electronic public comment docket for this ICR renewal. Thus, a list of questions asked the 

respondents and the responses received, either written comments, verbal responses or email, etc. will become a part of the electronic public comment docket for this ICR renewal.

EPA Questions asked in Consultation

(1) Publicly Available Data

$ Is the Child-Resistant Packaging (CRP) data that the Agency seeks for your 

product(s) available from any public source, or already collected by another office 

at EPA or by another agency? No not that I am aware of.

$ If yes, where can you find the CRP data? (Does your answer indicate a true 

duplication, or does the input indicate that certain data elements are available, but 

that they are not specific to your package/bait station?) 

(2) Frequency of Collection 

$ Is submitting CRP certification with/without data when a change in packaging 

occurs too frequent? No.

(3) Clarity of Instructions 

$ CRP regulations require respondents provide CRP certifications, CRP test data, 

and CRP exemption requests to ensure that the Agency can ascertain if CRP is 

protecting children from serious illness or injury resulting from handling, using, 

or ingesting certain products. 

$ Based on the regulations, PR Notices, CRP webpage, etc., is it clear what type of 

CRP information you are required to submit (e.g. CRP certification with/without 

data, etc.) and how to submit such data? If not, what suggestions do you have to 

clarify the instructions? It would be helpful to have more a clear process on 
2

determining if a product is subject to CPR. A decision tree that works through the 

criteria and exemptions (much like the PRIA decision tree) would be very helpful.

$ Do you understand that you are required to maintain CRP records for the life of 

the pesticide product registration? Yes

$ There are no forms associated with CRP. Is the submission format for CRP 

certifications and/or CRP data, clear, logical, and easy to complete? Yes, but it 

would be helpful for EPA to post example for reference.

 

(4) Electronic Reporting and Record keeping 

The Government Paperwork Elimination Act requires agencies make available to the 

public electronic reporting alternatives to paper-based submissions by 2003, 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 CBI that might be transmitted over the 

Internet.

$ Currently CRP data may be submitted electronically in addition to a hard copy to 

expedited data analysis. What do you think about this option? Other electronic 

reporting alternatives include the use of Aweb forms@/XML based submissions 

via the Agency=s Internet site and magnetic media-based submissions, e.g., 

diskette, CD-ROM, etc. Electronic submission via portal would be preferred. 

Electronic submission via a CD ROM works fine though.

$ Are you keeping your records electronically? If yes, in what format? Adobe 

Acrobat (pdf)

(5) Burden and Costs

• Are the clerical and technical burden hours in the 2 tables below accurate? These figures 

are based on 2013 projections. Table I associates the various types of CRP actions a 

respondent may do and the number of technical hours and clerical hours per event.

Please note this table reflects 2010 comments regarding burden hours per CRP action.

Please remember this burden may cover more than one product registration. Table II

spreads out a 4.2 hour burden per action in 0.1 hour increments. This not the time for 

self-certification without data or any other specific CRP type action. This is the time 

average based on registration actions spread out over self certification, certification with 

data, exemptions, etc. The time per action multiplied by the number of actions, and the 

sum of all registration actions time spent divided by the number of actions. For example

using burden estimates say 10 registration actions with say 6 being self certifications 

@1.5 hr =9, 3 certification with data @ 11 hr =33, and 1 exemption at 5.9 hr. This would 

provide 47.9 hrs for 10 registration actions with an average time per action being 4.8 hr. 

The question in Table II is then how would you divide the 4.8 hr (4.2 hr in the chart) 

between the various steps in collection action such as read instructions, prepare 

submission etc. 

• Bearing in mind that the burden and cost estimates include only burden hours and costs 

associated with the paperwork involved with CRP, e.g., the document does not include 
3

estimated burden hours and costs for conducting studies. If you provide burden estimates 

substantially different from EPA’s, please provide an explanation of how you arrived at 

your estimates.

Table I

(Average estimated industry burden per response type)

Type of Response No. of 

Responses

Technical 

Burden 

Clerical 

Burden

Total Hours 

per Event

Hours Per 

Event

Hours Per 

Event

CRP certification 798 1.0 0.5 1.5 

CRP certification with data 296 8.0 3.0 11.0

Exempt from CRP due to 

large package size

34 1.0 0.0 1.0

Exempt from CRP due to 

lack of toxicity, packaging, 

no residential use, lower 

product toxicity

37 8.0 3.0 11.0

Table II

(Distribution of Burden among various activities.

Based on projection Total Burden 4.2 Hrs/Respondent Action)

COLLECTION ACTIVITIES

Burden Hours TOTAL

Tech. 

$60.39/hr.

Clerical 

$35.89/hr.

Burden

Hours

Cost

Read instructions 0.18 0.00 0.18 $10.57 

Plan activities 0.22 0.00 0.22 $13.29

Create information including 

electronic format of data 1.20 0.00 1.20 $72.47

Process, compile, and complete 

written compliance document 1.10 0.90 1.90 $98.73

Review submission 0.30 0.00 0.40 $18.12

Store, submit, file, or maintain 

data 0.00 0.30 0.30 $10.77

TOTAL 3.00 1.20 4.20 $223.94
4
1

Consultation Questionnaire for OPP ICR:

Compliance Requirement for Child-Resistant Packaging

OMB Control # 2070-0052)

• Completed by:

Mark Jernigan

Regulatory Affairs Manager

Bio-Lab, Inc.

Telephone: 678-502-4149

Email: mark.jernigan@chemtura.com

Updated ICR Document:

A list of the consultation questions asked and the responses thereto become a part of the 

electronic public comment docket for this ICR renewal. Thus, a list of questions asked the 

respondents and the responses received, either written comments, verbal responses or email, etc. will become a part of the electronic public comment docket for this ICR renewal.

EPA Questions asked in Consultation

(1) Publicly Available Data

$ Is the Child-Resistant Packaging (CRP) data that the Agency seeks for your 

product(s) available from any public source, or already collected by another office 

at EPA or by another agency? No

$ If yes, where can you find the CRP data? (Does your answer indicate a true 

duplication, or does the input indicate that certain data elements are available, but 

that they are not specific to your package/bait station?) 

(2) Frequency of Collection 

$ Is submitting CRP certification with/without data when a change in packaging 

occurs too frequent? No

(3) Clarity of Instructions 

$ CRP regulations require respondents provide CRP certifications, CRP test data, 

and CRP exemption requests to ensure that the Agency can ascertain if CRP is 

protecting children from serious illness or injury resulting from handling, using, 

or ingesting certain products. 

$ Based on the regulations, PR Notices, CRP webpage, etc., is it clear what type of 

CRP information you are required to submit (e.g. CRP certification with/without 

data, etc.) and how to submit such data? If not, what suggestions do you have to 

clarify the instructions? It would be helpful if EPA maintained a list of 

packages/closures for which data has been reviewed and accepted. This would 

allow registrants to know that data not required when certification submitted for 
2

these packages/closures. Appendix A of PR Notice 97-9 should be updated to 

include Microsoft Excel files (xlsx) as acceptable format.

$ Do you understand that you are required to maintain CRP records for the life of 

the pesticide product registration? Yes

$ There are no forms associated with CRP. Is the submission format for CRP 

certifications and/or CRP data, clear, logical, and easy to complete? CRP 

certification – guidance acceptable. CRP data – It would be helpful to have an 

electronic template of fields with sample data for guidance.

 

(4) Electronic Reporting and Record keeping 

The Government Paperwork Elimination Act requires agencies make available to the 

public electronic reporting alternatives to paper-based submissions by 2003, 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 CBI that might be transmitted over the 

Internet.

$ Currently CRP data may be submitted electronically in addition to a hard copy to 

expedited data analysis. What do you think about this option? Other electronic 

reporting alternatives include the use of Aweb forms@/XML based submissions 

via the Agency=s Internet site and magnetic media-based submissions, e.g., 

diskette, CD-ROM, etc. No experience with electronic submission to provide 

comment.

$ Are you keeping your records electronically? No If yes, in what format?

(5) Burden and Costs

• Are the clerical and technical burden hours in the 2 tables below accurate? These figures 

are based on 2013 projections. Table I associates the various types of CRP actions a 

respondent may do and the number of technical hours and clerical hours per event.

Please note this table reflects 2010 comments regarding burden hours per CRP action.

Please remember this burden may cover more than one product registration. Table II

spreads out a 4.2 hour burden per action in 0.1 hour increments. This not the time for 

self-certification without data or any other specific CRP type action. This is the time 

average based on registration actions spread out over self certification, certification with 

data, exemptions, etc. The time per action multiplied by the number of actions, and the 

sum of all registration actions time spent divided by the number of actions. For example

using burden estimates say 10 registration actions with say 6 being self certifications 

@1.5 hr =9, 3 certification with data @ 11 hr =33, and 1 exemption at 5.9 hr. This would 

provide 47.9 hrs for 10 registration actions with an average time per action being 4.8 hr. 

The question in Table II is then how would you divide the 4.8 hr (4.2 hr in the chart) 

between the various steps in collection action such as read instructions, prepare 

submission etc. 

• Bearing in mind that the burden and cost estimates include only burden hours and costs 

associated with the paperwork involved with CRP, e.g., the document does not include 
3

estimated burden hours and costs for conducting studies. If you provide burden estimates 

substantially different from EPA’s, please provide an explanation of how you arrived at 

your estimates.

Table I

(Average estimated industry burden per response type)

Type of Response No. of 

Responses

Technical 

Burden 

Clerical 

Burden

Total Hours 

per Event

Hours Per 

Event

Hours Per 

Event

CRP certification 798 1.0 0.5 1.5 

CRP certification with data 296 8.0 3.0 11.0

Exempt from CRP due to 

large package size

34 1.0 0.0 1.0

Exempt from CRP due to 

lack of toxicity, packaging, 

no residential use, lower 

product toxicity

37 8.0 3.0 11.0

Table II

(Distribution of Burden among various activities.

Based on projection Total Burden 4.2 Hrs/Respondent Action)

COLLECTION ACTIVITIES

Burden Hours TOTAL

Tech. 

$60.39/hr.

Clerical 

$35.89/hr.

Burden

Hours

Cost

Read instructions 0.18 0.00 0.18 $10.57 

Plan activities 0.22 0.00 0.22 $13.29

Create information including 

electronic format of data 1.20 0.00 1.20 $72.47

Process, compile, and complete 

written compliance document 1.10 0.90 1.90 $98.73

Review submission 0.30 0.00 0.40 $18.12

Store, submit, file, or maintain 

data 0.00 0.30 0.30 $10.77

TOTAL 3.00 1.20 4.20 $223.94
4

Child-Resistant Packaging Information Collection Request (ICR)

Annual Respondent Burden by Response Type

Type of Response No. of 

Responses

Technical 

Burden 

Clerical 

Burden

Aggregate 

Burden

Hours 

Per 

Event

Tota

l

Hours 

Per 

Event

Tota

l

CRP certification 13 2 26

CRP certification 

with data 3 6 18

Exempt from CRP 

due to large 

package size

0

Exempt from CRP 

due to lack of 

toxicity, 

packaging, no 

residential use, 

lower product 

toxicity

0

TOTAL 16 44

Annual Respondent Burden/ Cost Estimates

COLLECTION 

ACTIVITIES

Burden Hours TOTAL

Tech. 

$60.39/h

r.

Clerical 

$35.89/hr

.

Burden

Hours

Cost

Read instructions 0.2 0.00 0.2

Plan activities 0.2 0.00 0.2

Create information 

including 

electronic format 

of data 0.9 0.00 0.9

Process, compile, 

and complete 

written compliance 

document 1.0 0 1.0

Review submission 0.3 0 0.3

Store, submit, 

file, or maintain 

data 0.2 0 0.2

TOTAL 2.8 0 2.8
1

Consultation Questionnaire for OPP ICR:

Compliance Requirement for Child-Resistant Packaging

OMB Control # 2070-0052)

• Complete by:

James L. Kunstman Ph.D. Craig Martens

Director of Regulatory Services Federal Registrations Manager

PBI/Gordon Corporation PBI/Gordon Corporation

1217 W. 12th Street 1217 W. 12th Street

Kansas City, MO 64101 Kansas City, MO 64101

jkunstman@pbigordon.com cmartens@pbigordon.com

Updated ICR Document:

A list of the consultation questions asked and the responses thereto become a part of the 

electronic public comment docket for this ICR renewal. Thus, a list of questions asked the 

respondents and the responses received, either written comments, verbal responses or email, etc. will become a part of the electronic public comment docket for this ICR renewal.

EPA Questions asked in Consultation

(1) Publicly Available Data

$ Is the Child-Resistant Packaging (CRP) data that the Agency seeks for your 

product(s) available from any public source, or already collected by another office 

at EPA or by another agency?

Response: Our sources of information are the catalogs/ publications/literature 

provided by the packaging suppliers. The format of this information may be 

written documents or may be presented on the company’s websites. 

$ If yes, where can you find the CRP data? (Does your answer indicate a true 

duplication, or does the input indicate that certain data elements are available, but 

that they are not specific to your package/bait station?) 

Response: As a registrant, we obtain our Child Resistant Packaging (CRP) 

information from the representative of the packaging supplier or from the 

supplier’s websites. 

(2) Frequency of Collection 

$ Is submitting CRP certification with/without data when a change in packaging 

occurs too frequent? 

Response: Our current residential product lineup is narrow, our products are 

substantially similar to existing products, most of our individual products do not 

meet the toxicity criteria defined in 40 CFR Part 157, and our packaging is 

described as rigid, non-refillable plastic containers with standardized closures. So, 

we believe that providing this information to the Agency for these types of 
2

household products at the time of registration and/or registration review is 

adequate and additional or new certifications should not be needed.

Our current products for occupational users are substantially similar to existing 

products and within the scope of the Child Resistant Packaging requirements. 

Again, our CRP packaging is described as rigid, non-refillable plastic containers 

with standardized closures. We submit certification statements for each 

registration that the container design and closures meet the CRP requirements 

when the product is distributed and sold. Unless there is good cause such as a 

change in the formulation or a change in the packaging, then additional or new 

certifications for packaging are unnecessary. 

(3) Clarity of Instructions 

$ CRP regulations require respondents provide CRP certifications, CRP test data, 

and CRP exemption requests to ensure that the Agency can ascertain if CRP is 

protecting children from serious illness or injury resulting from handling, using, 

or ingesting certain products. 

$ Based on the regulations, PR Notices, CRP webpage, etc., is it clear what type of 

CRP information you are required to submit (e.g. CRP certification with/without 

data, etc.) and how to submit such data? If not, what suggestions do you have to 

clarify the instructions?

Response: The information provided by the Agency is clear and accurate. 

$ Do you understand that you are required to maintain CRP records for the life of 

the pesticide product registration? 

Response: We understand record-keeping requirements as stated in 40 CFR Part 

157.

$ There are no forms associated with CRP. Is the submission format for CRP 

certifications and/or CRP data, clear, logical, and easy to complete?

Response: We believe that a cover letter with a certification statement and the

Application for Pesticide Amendment (EPA Form 8570-1) as described in 

Pesticide Registration Notice (PRN) 96-2 is adequate and offers the registrant 

more flexibility than a new form. 

(4) Electronic Reporting and Record keeping 

The Government Paperwork Elimination Act requires agencies make available to the 

public electronic reporting alternatives to paper-based submissions by 2003, 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 CBI that might be transmitted over the 

Internet.

$ Currently CRP data may be submitted electronically in addition to a hard copy to 

expedited data analysis. What do you think about this option? Other electronic 

reporting alternatives include the use of Aweb forms@/XML based submissions 

via the Agency=s Internet site and magnetic media-based submissions, e.g., 

diskette, CD-ROM, etc. 
3

$ Are you keeping your records electronically? If yes, in what format?

Response: We currently keep all records in .pdf format, housed in a searchable 

database.

(5) Burden and Costs

• Are the clerical and technical burden hours in the 2 tables below accurate? These figures 

are based on 2013 projections. Table I associates the various types of CRP actions a 

respondent may do and the number of technical hours and clerical hours per event.

Please note this table reflects 2010 comments regarding burden hours per CRP action.

Please remember this burden may cover more than one product registration. Table II

spreads out a 4.2 hour burden per action in 0.1 hour increments. This not the time for 

self-certification without data or any other specific CRP type action. This is the time 

average based on registration actions spread out over self certification, certification with 

data, exemptions, etc. The time per action multiplied by the number of actions, and the 

sum of all registration actions time spent divided by the number of actions. For example

using burden estimates say 10 registration actions with say 6 being self certifications 

@1.5 hr =9, 3 certification with data @ 11 hr =33, and 1 exemption at 5.9 hr. This would 

provide 47.9 hrs for 10 registration actions with an average time per action being 4.8 hr. 

The question in Table II is then how would you divide the 4.8 hr (4.2 hr in the chart) 

between the various steps in collection action such as read instructions, prepare 

submission etc. 

• Bearing in mind that the burden and cost estimates include only burden hours and costs 

associated with the paperwork involved with CRP, e.g., the document does not include 

estimated burden hours and costs for conducting studies. If you provide burden estimates 

substantially different from EPA’s, please provide an explanation of how you arrived at 

your estimates.

Table I

(Average estimated industry burden per response type)

Type of Response No. of 

Responses

Technical 

Burden 

Clerical 

Burden

Total Hours 

per Event

Hours Per 

Event

Hours Per 

Event

CRP certification 798 1.0 0.5 1.5 

CRP certification with data 296 8.0 3.0 11.0

Exempt from CRP due to 

large package size

34 1.0 0.0 1.0
4

Exempt from CRP due to 

lack of toxicity, packaging, 

no residential use, lower 

product toxicity

37 8.0 3.0 11.0

Table II

(Distribution of Burden among various activities.

Based on projection Total Burden 4.2 Hrs/Respondent Action)

COLLECTION ACTIVITIES

Burden Hours TOTAL

Tech. 

$60.39/hr.

Clerical 

$35.89/hr.

Burden

Hours

Cost

Read instructions 0.18 0.00 0.18 $10.57 

Plan activities 0.22 0.00 0.22 $13.29

Create information including 

electronic format of data 1.20 0.00 1.20 $72.47

Process, compile, and complete 

written compliance document 1.10 0.90 1.90 $98.73

Review submission 0.30 0.00 0.40 $18.12

Store, submit, file, or maintain 

data 0.00 0.30 0.30 $10.77

TOTAL 3.00 1.20 4.20 $223.94