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SUPPORTING STATEMENT FOR AN 

INFORMATION COLLECTION REQUEST (ICR)

1. IDENTIFICATION OF THE INFORMATION COLLECTION

1(a) Title and Numbers of the Information Collection 

Title: Pesticide Registration Fees Program

OMB No.: 2070-0179 EPA No.: 2330.02

1(b) Short Characterization/Abstract 

This Information Collection Requests (ICR) covers the paperwork burden hours and 

costs associated with the information collection activities under the pesticide registration fee 

programs implemented through the Office of Pesticide Programs (OPP), Environmental 

Protection Agency (EPA). Pesticide registrants are required by statute to pay an annual 

registration maintenance fee for all products registered under Section 3 and Section 24(c) of 

the Federal Insecticide, Fungicide and Rodenticide Act (FIFRA). In addition, the Pesticide 

Registration Improvement Act (PRIA) amended FIFRA in 2004 to create a registration service 

fee system for applications for specific pesticide registration, amended registration, and 

associated tolerance actions (Section 33). This ICR specifically covers the activities related to 

the collection of the annual registration maintenance fees, the registration service fees and the 

burden associated with the submission of requests for fees to be waived. 

2. NEED FOR AND USE OF THE COLLECTION

2(a) Need/Authority for the Collection

Under FIFRA, EPA must evaluate pesticides thoroughly, before they can be marketed 

and used in the United States, to ensure that they will not pose unreasonable adverse effects to 

human health and the environment. Pesticides that meet this test are granted a license or 

"registration" which permits their distribution, sale and use according to requirements set by 

EPA to protect human health and the environment.

Pesticide Product Registration Maintenance Fees

Section 4(i)(5) of FIFRA (Attachment A) requires registration maintenance fees to be 

applied to all products registered under Section 3 and Section 24(c) of FIFRA. The fees are 

paid annually for each product registered and payable on January 15 of each year. The 

authority to collect fees under the 1988 amendments would have terminated on September 30, 

1997. However, the Food Quality Protection Act (FQPA) amended FIFRA and extended the 

authority to collect these fees until September 30, 2001. The EPA Appropriation Bills of FY 

2002 and FY 2003 also extended the authority to collect maintenance fees. PRIA 1, which 

became effective on March 23, 2004, and PRIA 2 which became effective October 1, 2007

further extended the authority to collect maintenance fees through fiscal year 2012. PRIA 3 
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became effective on October 1, 2012 and extends the authority to collect maintenance fees

through FY’ 2017. Under PRIA 3 there is a new provision that allows qualified small 

businesses (defined as having ≤ 5 products, ≤ $10 M in total, global sales and ≤ 500 

employees) to seek a 25% maintenance fee reduction on their first product.

Pesticide Registration Service Fee and Waivers

Section 33 of FIFRA requires the collection of fees in order to enhance the review of 

covered pesticide products (see Attachment B for information on the current fee schedule). 

Fees collected under this program will help to reduce time frames for registration decisions; 

provide greater predictability and more accountability for those decisions; ensure that FQPA

deadlines are met; and result in more predictable and augmented funding for the pesticide 

program. Section 33 also established provisions that allow these fees to be exempted entirely.

The registration service fee system was reauthorized by the Pesticide Registration 

Improvement Extension Act (PRIA 3) until September 30, 2017. Under the sunset provisions, 

if PRIA 3 is not reauthorized, the Agency is authorized to collect reduced fees for two 

additional years – 40% reduced fees in 2018 and 70% reduced fees in 2019 below the level in 

effect on September 30, 2017.

A registration applicant may seek a waiver as a small business, defined by the PRIA as 

a business with fewer than 500 employees and on average, annual global gross revenue from 

pesticides of no more than $60 million over the most recent three-year maintenance fee billing 

cycle. For a business entity with one or more affiliates, the gross revenue limit includes total 

global revenues from pesticides for the entity and all of its affiliates, including parent and 

subsidiary entities. 

A registration applicant qualifying as a small business under the PRIA will be entitled 

to a waiver of fifty percent (50%) of its fees. In addition, 75% of a fee will be waived for small 

businesses with, on average, annual gross global revenues from pesticides over the most recent 

three-year maintenance fee billing cycle, including affiliates, of no more than $10 million. 

Small business applicants requesting waivers must provide EPA with appropriate 

documentation demonstrating that they meet these criteria.

A registration applicant may also request a minor use waiver or fee reduction if the 

applicant can demonstrate that anticipated revenues from the uses described in the registration 

application would be insufficient to justify the imposition of the full application fee. The 

Agency may grant a full exemption or a partial reduction in the fee based upon its 

consideration of the supporting documentation provided. 

In addition, under PRIA 3, the Agency must determine that the exemption is in the 

public interest. In February 2013, the Agency issued the Policy document entitled “Factors for 

IR-4 Public Interest Finding” (Attachment C) which lists the criteria under which an 

application will be presumed to be in the public interest. Since this policy exempts most, if not 

all, IR-4 registration activities, the Agency does not anticipate any additional burden will be 

imposed on IR-4. Finally, the statute exempts agencies of the Federal Government or a State 

from fees.
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The program is expected to generate in excess of $10 million in new registration 

service fees annually over five years.

 

2(b) Practical Utility/Users of the Data

Pesticide Product Registration Maintenance Fees

In order to provide an efficient system to bill, collect, and account for registration 

maintenance fees, the Agency sends a filing form to all registrants of currently active products. 

The information is used by the Agency to ensure that the fees prescribed by FIFRA have been 

paid by each registrant. The information is also used to adjust OPP's computer files to reflect 

changes in the status of registrations resulting from registrant responses. In the case where the 

registrant requests a small business cap and/or a 25% reduction in the first product’s fee, the 

required information is used to ensure that the registrant qualifies for the fee reduction and is 

used to assess and report to Congress the impacts of maintenance fees on small businesses as 

required in PRIA 3.

Pesticide Registration Service Fee and Waivers

EPA is the sole intended user of the information collected. This collection of 

information is critical for the proper performance of Agency functions because the information 

collected will allow EPA to properly review a request for a waiver or exemption of fees under 

the PRIA without delay. The actual usefulness of the information to the Agency is that the 

information collected will be used to determine if the applicant qualifies for a PRIA 

registration fee waiver or exemption. Statutorily, in instances where the applicant requests a 

fee waiver or exemption, the decision review time period does not begin until either the 

Agency grants the waiver or exemption or until the registrant has paid the appropriate 

registration service fee (or, in the case of a partial waiver or fee reduction, the balance of the 

appropriate registration service fee). Processing of the application, therefore, will be delayed 

until the Agency can render a decision on the fee waiver or fee reduction or exemption request. 

With the submission of this data by the registrant, the Agency will be able to meet its statutory

obligation to grant or deny a waiver request within 60 days and, usually, earlier than the 

maximum 60 day period.

3. NON DUPLICATION, CONSULTATIONS, AND OTHER COLLECTION 

CRITERIA

 

3(a) Non duplication

For pesticide product registration, the specific information required under this ICR (i.e., 

the number of registrations that a given registrant wishes to maintain and, thus, the fee amount 

that will be remitted to EPA) does not exist in data bases at EPA or any other agency. To 

determine the amount of maintenance fees accurately, the Agency and the registrant must have 

a joint understanding concerning the number of products currently registered. Prior to 

implementing the current process, the Agency considered an alternative approach which was to 

simply notify registrants that fees were due for each of their products according to a fee 

schedule. Under this alternative, the registrant would submit payment according to their best 
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information concerning the number of registrations that they wanted to support. However, if a 

registrant submitted payment that did not correspond to the fee schedule, the Agency would be 

in a position of either unilaterally determining which registrations to cancel, or contacting each 

registrant to determine that registrant's intentions. This option was considered to be inefficient, 

and not in the best interest of the Agency or the registrants. 

For pesticide registration fee waivers, no other federal agency or EPA program is 

collecting fees for the processing of applications for pesticide registration or information for 

the waiver or exemption of such fees. As such, this information collection activity does not 

duplicate any other collection of information by the federal government.

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

Pursuant to 5 CFR 1320.8(d), EPA announced and provided a 60-day public comment 

period on the information collection activities as described in this ICR (78 FR 36774, June 19, 

2013). 

3(c) Consultations

During the preparation of this ICR renewal, EPA staff contacted Kimberlee Young, 

RegWest Inc, Amy Roberts, Technology Sciences Group Inc and Kyle Price, Nufarm 

Americas Inc to solicit stakeholder comment on the burden and costs associated with this ICR 

renewal. The Agency received two comments which have been incorporated into this 

document as Attachment G are a part of electronic docket EPA-HQ-OPP-2013-0287 for this 

action. 

Pesticide Product Registration Maintenance Fees

Consultation and/or dialogue between respondents and the Agency is frequent and ongoing. In addition to phone conversations, e-mails, and letters, Agency personnel participate in 

meetings with individual registrants as well as gatherings of large groups of registrants from 

time to time. These communications permit an exchange of issues, problems, and solutions on 

many issues. 

Pesticide Registration Service Fee Waivers

The Pesticide Registration Improvement Extension Act (PRIA 3) that was introduced 

into Congress was based upon the past experience in implementing PRIA 1 and PRIA 2, and a 

consensus reached by stakeholders, which was informed in part by technical information 

provided by the Agency. These stakeholders included CropLife America, the Consumer 

Specialty Products Association, the Chemical Producers and Distributors Association, the 

American Chemistry Council, the Natural Resources Defense Council, and Consumers Union, 

among other parties.

Consultation and/or dialogue between respondents and the Agency on the PRIA waiver 

and exemption process, content, definitions, format, and timing is frequent and on-going. In 
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addition to phone conversations, e-mails, and letters, Agency personnel participate in meetings 

with individual registrants as well as gatherings of large groups of registrants from time to 

time. These communications permit an exchange of issues, problems, and solutions on many

issues. 

3(d) Effects of Less Frequent Collection

Annual payment of maintenance fees for all pesticide products is mandated by FIFRA.

Thus, there can be no option other than to require a minimum submission of the filing form 

once a year. Less frequent information collection in this area would violate the statute.

 

For the payment of PRIA registration application fees, there is no set collection 

schedule, per se. Rather, the registration service fee is collected each time a registrant submits 

a registration application. The applicant must either pay a fee or request and be granted a 

waiver or exemption for each registration application submitted. Therefore, the frequency of 

collection depends entirely on the frequency with which applicants submit registration 

applications. EPA cannot grant a waiver or exemption when one has not been requested and 

documented. Therefore, less frequent collection is not an option.

3(e) General Guidelines

With respect to the PRA imposed guidelines contained in 5 CFR 1320.6, the

information collection activity for pesticide product registration has the following features:

 The respondents are required to respond on an annual basis and hence the quarterly 

response limitation is not applicable

 The respondents are not required to keep records relating to this information collection 

for a period of more than 3 years.

 This information collection activity does not utilize a statistical survey. The 

requirement to collect maintenance fees for all products means that all pesticide 

registrants submit replies.

 The respondents are given at least 30 days to respond.

 The information collection under this ICR can be held confidential under long 

established procedures for properly handling Confidential Business Information. 

Confidentiality is discussed in more detail below. 

 The respondents are not required to submit more than an original and two copies of any 

document.

 The ICR is for processing of fees mandated by Congress. No provision in the law 

allows for remuneration of respondents.

 This information collection activity utilizes automation to the extent practicable without 
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electronic reporting and payment. For example, the name and address of each 

respondent is pre-printed by computer, alleviating the registrant of the burden of 

writing it in. A computer generated listing of products is also provided, and the 

registrant must only circle an appropriate keyword (CAN, PAY) etc. Because the 

regulated community runs the gamut from large multinational corporations to small 

sole proprietor firms, some with limited technological capabilities, the Agency makes 

available a simple filing form and the ability to make electronic reporting and payment.

 As discussed in Section 4(c), this form requires the minimum amount of information 

from all firms.

 This collection activity does not apply to grantees.

The collection activities for pesticide registration fee waivers comply with the 

guidelines for information collections under the PRA. There is no record keeping requirement 

for information submitted under this information collection.

A registration applicant eligible for a fee waiver or exemption must submit their signed 

request for the waiver, certification of eligibility, and required documentation demonstrating 

eligibility. The industry has developed a form for the small business fee waiver request. Many

requesters use this form, although the Agency does not require it. Most waivers are granted 

based on the small business status of the applicant, and Confidential Business Information is 

included in their submission (e.g., gross global revenues, business structures and employment 

levels). Although EPA would accept waiver requests sent in Adobe PDF format on CD-ROM, 

the Agency’s expectation based on experience is that the majority of registrants want to send 

their requests in writing with ink signatures. In the future, if it appears that electronic 

submission of waiver requests by e-mail is beneficial and feasible for respondents and EPA, we 

will seek to facilitate such submissions.

3(f) Confidentiality

Product registration maintenance fee information submitted by pesticide registrants 

under this ICR is considered by OPP to contain no confidential business information (CBI). If, 

however, registrants submit data that contains CBI or relates to trade secrets or commercial or 

financial information, such information is protected from disclosure under section 10 of 

FIFRA.

The information requested to document fee waiver or exemption requests may contain 

CBI. However, data and/or information submitted to the Agency in conjunction with service 

fee waiver or exemption requests may be claimed as trade secret or commercial or financial 

information and will be protected from disclosure under FIFRA section 10 and the associated 

regulation as contained in 40 CFR Part 2, Subpart B. Information claimed as CBI is protected 

from public disclosure unless the Administrator determines that disclosure is in the public 

interest. OPP routinely handles CBI data, and personnel are familiar with security procedures 

in accordance with provisions of the FIFRA Confidential Business Security Manual to ensure 

confidentiality. If any information is submitted that applicants claim as confidential, the 

Agency will employ the established procedures for handling such material.
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3(g) Sensitive Questions

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

collection activity. Further, this information collection 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

The North American Industrial Classification System (NAICS) codes assigned to the 

parties responding to this information collection are as follows:

NAICS Code Category Description

32532 Pesticide and other agricultural 

chemical manufacturing

individuals or entities engaged in activities 

related to the registration of a pesticide 

product

32518 Other Basic Inorganic 

Chemical Manufacturing

manufacturers of inorganic chemicals used 

as inert ingredients in pesticide products

32519 Other Basic Organic Chemical 

Manufacturing

manufacturers of organic chemicals used as 

inert ingredients in pesticide products.

9641 Regulation of Agricultural 

Marketing and Commodities

Includes government establishments 

responsible for agricultural pest and weed 

regulation.

4(b) Information Requested

Annually, the Agency provides registrants with a list of their products currently

registered with the Agency. Registrants are provided the opportunity to review the list, 

determine its accuracy, and remit payment of the maintenance fee. The list of products has 

space identified for marking those products to be supported and those products that are to be

canceled. The registrants are also instructed to identify any products on the list which they

believe are transferred to another company, and to add to the list any products which the 

company believes are registered that are not on the Agency-provided list. Respondents 

complete and submit EPA Form 8570-30 (Attachment D) indicating the respondent's liability

for the registration maintenance fee. Each affected firm is required to complete the filing form 

and submit their fee payment by January 15 of each year. The failure to pay the required fee 

for a product will result in cancellation of that product’s registration. 
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4(b)(i) Data Items, Including Record Keeping Requirements

Pesticide Product Registration Maintenance Fees

Data Item A --

Registrant

Identification

Registrant Name and Address are pre-printed. The registrant needs to 

complete this section only to indicate a name and/or address change.

Data Item B –

EPA Company

Numbers

If a firm has been assigned more than one company number, the firm

may combine its fee payments under a single number by writing in all 

of the company numbers for which the firm is paying.

Data Item C --

Maintenance Fee 

Calculation

The respondent must fill in the number of registrations for which he is 

paying the fee, number of registrations which he believes to be 

transferred, number of registrations to be canceled, number of 

registrations which he believes to be in error, total fee amount due, 

and check number.

Data Item D --

Authorized Company

Representative or 

Agent

The respondent must print the name and title of the company 

representative or agent. The respondent must sign and date the form, 

and provide the telephone number of the respondent.

Data Item E

Small Business 

Waiver

A small business seeking the small business cap and/or a 25% waiver 

on their first product’s maintenance fee must submit the necessary

information to substantiate their claim.

Pesticide Registration Service Fee Waivers

A registration applicant who seeks a small business waiver must submit a waiver 

request with appropriate documentation demonstrating that he meets the criteria established in 

the PRIA, i.e., that he has fewer than 500 employees and has no more than $60 million in 

annual global gross revenue from pesticides, averaged over the most recent three maintenance 

fee billing cycles, including any such revenue from affiliates. For this purpose, the applicant 

may be required to submit documentation regarding numbers of employees and, on behalf of 

itself and its affiliates, gross revenue figures, and information on revenue from pesticides over 

a three-year period.

A registration applicant who seeks a minor use waiver or exemption must provide 

supporting documentation that anticipated revenues from the uses that are the subject of the

application would be insufficient to justify imposition of the full registration fee. 

A registration applicant seeking an IR-4 exemption must merely request the waiver on 

Form 8570-1 (Application for Pesticide Registration, approved under OMB Control #2070-

0060) and submit the application at the same time that the IR-4 tolerance petition is submitted. 

The Agency will, in turn, determine whether the application is solely associated with a 

tolerance petition submitted by IR-4 and that the waiver is in the public interest.

Although there is no record keeping requirement, PRIA provides that an application 
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shall be subject to a registration service fee if, at any time, EPA determines that (i) the 

documentation supporting the waiver request is not accurate or (ii) based on the documentation 

or any other information, the waiver or reduction should not have been granted. Therefore, it is 

anticipated that applicants will retain copies of their submissions as well as documents 

demonstrating that the applicant is eligible for the waiver or reduction. 

Currently no EPA forms are associated with this information collection activity. The 

Agency will accept information that is submitted in any format that meets the requirements of 

the statute.

4(b)(ii) Respondent Activities

Pesticide Product Registration Maintenance Fees

Activities in which a registrant must engage in order to comply with this collection 

include the following:

Read instructions Read accompanying instructions to understand how to fill out form, 

annotate list of registrations, and calculate fee due.

Plan Activities Plan the activities necessary to respond to the billing. 

Review Information Review the attached listing of registrations and compare to the firm's 

records.

Complete Paperwork

Annotate attached listing of registrations to indicate which products 

the respondent is paying and which products are to be canceled or 

transferred.

Document small 

business claim

Provide required information to substantiate small business cap and/or 

25% first product fee reduction claim

File Information

Maintain a copy of the form in company files. Although this is not 

required, the Agency assumes that most companies will retain this 

information as a common business practice.

The existing paper version form is printed on 3 part NCR paper. The respondent sends 

one copy along with payment to the Headquarters Accounting Operations Branch Lock Box in 

St. Louis and the second copy together with the annotated list of products to OPP via a 

designated Washington D.C. area mail box. The third copy is retained by the respondent for 

his own records. Information contained on the forms returned to OPP is used to check and 

ensure that the proper amount of fees have been submitted by each registrant. In the past there 

has been a need for follow-up with some registrants when the information provided indicates 

that there has been a misunderstanding of the requirements. For the most part these have been 

handled by telephone. There is also a toll free information line available which registrants may

use to ask questions and resolve problems regarding their maintenance fee payments. The 

information provided also serves as an update for pesticide product information files. Updates 

of the Agency’s files are an ongoing process.

Pesticide Registration Service Fee Waivers

Guidance on the content and submission of fee waiver requests is available on EPA’s 

website at http://www.epa.gov/pesticides/fees/questions/waivers.htm (also, see Attachment E). 
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If a registration applicant wishes to request a fee waiver or exemption, at a minimum, it must 

undertake the following activities:

 Generate and submit the necessary materials to support the request.

 

 Indicate that a waiver or exemption is requested and that the appropriate documentation 

supporting the request is enclosed or has been otherwise submitted to the Agency.

5. THE INFORMATION COLLECTED - AGENCY ACTIVITIES, COLLECTION

METHODOLOGY, AND INFORMATION MANAGEMENT

5(a) Agency Activities

Pesticide Product Registration Maintenance Fees

The following Agency activities are necessary to process the information request:

Develop Letter Prepare a cover/transmittal letter to be included in the package.

Answer Questions Staff a toll free information line to respond to any questions that 

respondents have regarding payment requirements.

Review Submissions Review submitted forms and annotated listings for completeness.

Record Submissions

Record information provided by respondents into a tracking 

system. Make adjustments to Product Information Master Files as 

required.

Verify Payments Cross check payment information from Financial Management 

Division to ensure that payment has been received.

Store Data Image all forms, listings, and telephone conversation logs for 

archiving.

 

Pesticide Registration Service Fee Waivers

The Agency is expected to engage in the following activities:

 Review and evaluate fee waiver requests. Notify applicant of decision.

 Verify payments. Cross check payment information from Financial Management Division.

 Store the data. Image all forms, listings, telephone conversations, etc., for archiving.

5(b) Collection Methodology and Management

Pesticide Product Registration Maintenance Fees

For the past 17 years, the Agency has employed the same method of collecting 

maintenance fees. This method involves using OPP master files of product information to 

identify the firms to which the billing information is to be sent. Computer generated listings of 
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products are mailed to each firm along with the Maintenance Fee Filing Form. The registrant 

is instructed to circle the word PAY, CAN, XFR, ERR, next to each Registration Number to 

indicate if he wants to pay for the registration, cancel the registration, indicate if he believes 

that the registration was transferred, or if the registration is listed in error.

The list of registrations is pre-loaded into a tracking file, and only the PAY, CAN, 

XFR, ERR indicator is keyed manually for each product. Company name and address 

information is also pre-loaded reducing the data entry burden for the maintenance fee filing 

forms. The total number of products for each company is calculated by computer, and totals 

entered from the filing form are verified by computer to ensure that all items balance. In 

addition, data entry for all forms is quality checked visually.

Receipt of payment is entered by the Financial Management Division into the 

Integrated Financial Management System (IFMS). This information is then extracted and 

posted to the maintenance fee tracking system to close out each record. Results are made 

available to OPP staff on request as soon as the information is entered into the tracking system.

EPA implemented electronic payment of maintenance fees via http://www.pay.gov

in the FY08 collection cycle. Currently, more than 60% of maintenance fee payments are 

received electronically.

Pesticide Registration Service Fee Waivers

Fee payments are sent to the Financial Management Division in St. Louis, MO and 

entered in to the Agency's Integrated Financial Management System (IFMS). Payment 

information is extracted from IFMS and loaded into OPP's tracking system (OPPIN). Payment 

is due at time of application. If additional payment is required, invoices are generated and sent 

both electronically and in paper. All payments and invoices are generated electronically and 

tracked in OPPIN. Incoming letters, fee waiver and exemption applications, mail receipts, 

petitions, and other types of correspondence from registrants will be retained in hard copy for a 

period of time and then imaged for long term electronic storage. 

Procedures for evaluating fee waiver and exemption requests will not change. 

Information and materials submitted to justify a fee waiver are screened for completeness by

the receiving division. Economic data are sent to OPP’s Biological and Economic Analysis 

Division for analysis. The Agency will keep applicants informed of the status of the waiver 

application throughout the process by telephone and by mail.

5(c) Small Entity Flexibility

The Agency's filing form for the submission of maintenance fees requires the minimum 

amount of information needed to provide adequate communication between pesticide product 

registrants and the Agency. The needs of small businesses were of primary concern in 

designing the filing form. The respondents are asked to provide only readily available 

information. To qualify business must: 1) provide the necessary data to demonstrate that the 

entity qualifies as a small business, 2) identify products that firms wish to continue to support. 
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In 2012 the fee structure was changed to provide a 25% discount on the first product supported. 

Therefore, qualified small businesses with five or fewer products receive a benefit from the 

discount.

Small businesses may also request a waiver of the registration service fee. A waiver 

applicant must demonstrate that it meets the criteria as outlined in PRIA. The information that 

needs to be compiled in order to make this determination is information that companies 

routinely collect and maintain in the normal course of business.

5(d) Collection Schedule

The payment of maintenance fees for all pesticide products is mandated in FIFRA to 

occur annually. Thus, there can be no option other than to require a minimum submission of 

the filing form once a year. Less frequent information collection in this area would violate the 

statute.

The registration service fee is collected each time a registrant submits a registration 

application. The applicant must either pay a fee or request and be granted a waiver or 

exemption for each registration application submitted if the application is within the scope of 

one of the 140 fee categories.

6. ESTIMATING THE BURDEN AND COST OF THE COLLECTION

6(a) Estimating Respondent Burden

Pesticide Product Registration Maintenance Fees

Experience has shown that the average burden per respondent has remained at 

approximately 1 hour. The agency believes that the number of actual burden hours has 

remained steady due to the fact that registrants now have 20 years of experience. In 2013 there 

were 1,744 firms with registrations. A summary of firms and their number of registrations is 

provided below.
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Table 1. Number of Registrations Held by Registrants (Summary)

Number of 

Products

Number of 

Registrants

Registrants 

Cumulative Total

Cumulative %

1 – 5 1,337 1,337 77%

6 – 10 156 1,493 86%

11 – 20 100 1,593 91%

21 – 50 84 1,677 96%

51 - 100 32 1,709 98%

> 100 35 1,744 100%

Based on consultations with several respondents, both in the past and for this ICR 

renewal, we believe that the average time required to complete the maintenance fee filing form 

depends upon the number of registrations held by the registrant. Below is the breakdown of the 

burden associated with the maintenance fee filing based on registrant-supplied information.

Table 2. Respondent Burden, by Number of Registrations Held 

Number of 

Products

Average Hours Number of

Registrants

Total Hours

 1 – 5 1.0 1,337 1,337

6 – 10 0.75 156 117

11 – 20 1.0 100 100

21 – 50 2.0 84 168

51 – 100 3.0 32 96

> 100 5.0 35 175

Totals 1,744 1,993

PAPERWORK BURDEN: 1,993 (total hours) / 1744 (number of respondents) = 1.14 hours 

per response (rounded to two decimals).

Pesticide Registration Service Fee Waivers

In calculating the potential respondent burden, the Agency estimated 307 responses per 

year for requesting fee waivers or reductions or exemptions, based on the numbers of fee 

waiver or exemption applications during the maintenance fee cycle for FY2012. 

IR-4 waiver requests are not accounted for in this burden estimation. To be eligible for 

the IR-4 exemption under PRIA 2, the application must be solely associated with a tolerance 

petition submitted by the IR-4 program and the exemption must be in the public interest. To 

facilitate this request, the applicant may simply include the statement "This application is being 

submitted with a tolerance petition submitted in connection with IR-4. I request EPA to 

exempt the registration service fee for this application under the IR-4 waiver provisions of 

FIFRA Section 33(b)(7)(E)" on Form 8570-1 (Application for Pesticide Registration). Burden 

hours associated with completing this form are already covered by the ICR entitled 

“Application for New or Amended Registration” approved under OMB Control Number 2070-

0060. EPA is not requiring registrants to submit additional information. The Agency will 

determine whether the application is solely associated with a tolerance petition submitted by

IR-4 and whether the exemption is in the public interest.
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Minor use waiver or exemption requests are not considered in estimating respondent 

burden because since March 23, 2004, only thirteen requests have been received out of several 

thousand applications.

There are three types of small business waiver applications. The first type, Type A, is a 

first-time applicant requesting fee waiver or reduction. The second type, Type B, is an 

application requesting another fee waiver or reduction within the same maintenance fee billing 

cycle. The third type, Type C, is from an applicant who has applied for a fee waiver in a prior 

maintenance fee billing cycle but not in the current cycle. EPA assumes that the respondent 

burden and cost for the Type B application is the lowest because Type B applicants will only

need to certify that there have been no changes to the information previously submitted or, in 

the alternative, only provide documentation with respect to those elements that have changed. 

Type C applications, on the other hand, will need to submit all the documentation supporting 

the waiver request, providing updated financial and employee information. EPA assumes, 

however, that the cost and burden on most Type C applicants will be less than first time 

applicants because applicants will already be familiar with the waiver requirements and, in 

many cases, should have a portion of the supporting financial and business affiliation 

documentation is readily available. The cost and burden on the Type A applicants will be the 

same as those for the first-year applicants. Type A applicants have the most burden because

EPA assumes that every new applicant seeking a waiver of the registration service fee will

want to familiarize him/herself with the criteria from the outset. Thus this burden is considered 

a one-time burden that will occur the first time the applicant submits a registration application 

under the PRIA. 

Based on the number of waiver requests EPA actually received during FY 2012, EPA 

estimates that less than 1600 requests for registration actions will be received per year, of 

which 307 will request fee waivers or reductions. Of the 307 responses EPA estimates that 

11% (34 out of 307) will be the first-time applicants (Type A), 59% (181 out of 307) will be 

the Type B applications, and 30% (92 out of 307) will be Type C applications each year, EPA 

estimates of respondent burden hours per response, for each of the three response types, were 

corroborated by representative respondents in consultations (see section 3(c) of this supporting 

statement) and have not been revised for this ICR renewal. The burden per response, number 

of responses, and total burden for each of the three response types are presented in Tables 4, 5, 

6, and 10.

6(b) Estimating Respondent Costs

Labor Costs

OPP uses labor cost estimates from the BLS (Bureau of Labor Statistics) with respect to 

wages, benefits and overhead for all labor categories for affected industries, state government, 

and EPA employees. This approach provides a transparent and consistent methodology using 

current publicly-available data to provide more accurate estimates and allow easy replication of 

the estimates.
October 2013

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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 the paperwork cost. 

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/oessrci.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: Unless stated otherwise, all benefits represent 44% 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 

44% 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.

Attachment F contains worksheets providing the breakout of these costs. Costs are 

based on 2011 data. 

To derive the labor rates for this ICR, Agency economists estimated the wages for the 

management, technical, and clerical labor categories using the methodology cited above. The 

respondent costs for this renewal for managerial, technical and clerical rates are estimated at 

$124, $61, and $37 per hour, respectively. These labor rates are fully loaded and include 

benefits and overhead costs.

Pesticide Product Registration Maintenance Fees

The upper part table below describes the average burden and costs for completing one 

maintenance fee filing form. The average total hourly burden was derived from Table 2 and 

the allocation of the hours between collection activities and types of labor was derived from

consultation with a selected group of respondents. The lower part of the table estimates the 

total annual burden and costs for all respondents.
October 2013

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Table 3. Average Respondent Paperwork Burden and Costs

Collection 

Activities

Burden Hours Total

Mgmt Technical Clerical

$124.10 $61.21 $36.79 Hours Costs

per hour per hour per hour

Read instructions 0.3 0.3 $18.36 

Plan activities 0.24 0.24 $29.78 

Review information 0.24 0.24 $29.78 

Complete Paperwork 0.24 0.24 $14.69 

File Information 0.123 0.123 $4.52 

TOTAL 0.48 0.54 0.123 1.143 $97.15 

Annual Costs Hours per 

response

x 

Responses 

per year

= Hours 

per year

x Wage 

per hour

= Costs 

per year

Management: 0.48 1,744 837 $124.10 $103,888 

Technical: 0.54 1,744 942 $61.21 $57,643 

Clerical: 0.12 1,744 215 $36.79 $7,891 

TOTAL 1.14 1,744 1,993 $169,422 

Numbers may not calculate exactly because they are displayed as rounded.
October 2013

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Pesticide Registration Fee Waivers

Table 4. Annual Respondent Burden and Cost Estimates (Type A)

Collection Activities

Type A

Burden Hours Total

Mgmt Technical Clerical

$124.10 $61.21 $36.79 Hours Costs

per hour per hour per hour

Read regulation and plan 

activities 7 0 0 7 $869 

Generate materials for 

waiver request for 

submission to EPA

0 24 0 24 $1,469 

Store/maintain/submit and 

produce information 0 0 6 6 $221 

TOTAL 7 24 6 37 $2,558 

Annual Costs 

Hours 

per 

response

x 

Responses 

per year

= Hours 

per year

x Wage 

per hour

= Costs 

per year

Management: 7 34 238 $124.10 $29,536 

Technical: 24 34 816 $61.21 $49,946 

Clerical: 6 34 204 $36.79 $7,504 

 Total 37 34 1,258 $86,986 
October 2013

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Table 5. Annual Respondent Burden and Cost Estimates (Type B)

Collection Activities

Type B

Burden Hours Total

Mgmt Technical Clerical

$124.10 $61.21 $36.79 Hours Costs

per hour per hour per hour

Read regulation and plan 

activities 2 0 0 2 $248 

Generate materials for 

waiver request for 

submission to EPA

0 4 0 4 $245 

Store/maintain/submit and 

produce information 0 0 6 6 $221 

TOTAL 2 4 6 12 $714 

Annual Costs 

Hours 

per 

response

x 

Responses 

per year

= Hours 

per year

x Wage 

per hour

= Costs 

per year

Management: 2 181 362 $124.10 $44,925 

Technical: 4 181 724 $61.21 $44,315 

Clerical: 6 181 1,086 $36.79 $39,949 

 Total 12 181 2,172 $129,188 
October 2013

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Table 6. Annual Respondent Burden and Cost Estimates (Type C)

Collection Activities

Type C

Burden Hours Total

Mgmt Technical Clerical

$124.10 $61.21 $36.79 Hours Costs

per hour per hour per hour

Read regulation and plan 

activities 2 0 0 2 $248 

Generate materials for 

waiver request for 

submission to EPA

0 19 0 19 $1,163 

Store/maintain/submit and 

produce information 0 0 6 6 $221 

TOTAL 2 19 6 27 $1,632 

Annual Costs 

Hours 

per 

response

x 

Responses 

per year

= Hours 

per year

x Wage 

per hour

= Costs 

per year

Management: 2 92 184 $124.10 $22,835 

Technical: 19 92 1,748 $61.21 $106,992 

Clerical: 6 92 552 $36.79 $20,305 

 Total 27 92 2,484 $150,132 

6(c) Estimating Agency Burden and Cost

Labor Costs

Agency labor rates are estimated for the relevant technical and clerical staff using the 

methodology described in 6(b) above. Management, technical and clerical rates are estimated 

at $120, $78 and $44 per hour, respectively. Labor rates are fully loaded and include benefits 

and overhead costs. 

Pesticide Product Registration Maintenance Fees

The cost to the Federal Government for this ICR is estimated to be $90,454. This 

estimate has two components. The first is the annual costs of generating listings and 

conducting mass mailings as well as pre-loading tracking data. The Agency estimates that 

these activities cost $1,639. The second component is the per submission costs totaling 

$88.815 (see annual number of actions in Table 2). The Agency expends no management hours 

in processing maintenance fee submissions.
October 2013

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Table 7. Agency Burden Hours per Filing Form and Total Cost

Collection Activities

Burden Hours Total per Activity Annual 

Number 

of 

Actions

Total all 

Activities

Technical Clerical

Burden 

Hours Cost Burden Hours $77.85 $44.05 Cost

per hour per hour

Generate Listings/Mass 

Mailing 8 16 24 $1,328 1 24 $1,328 

Pre-load Tracking Data 4 4 $311 1 4 $311 

Receive/Review Submissions 0.2 0.2 $9 1,744 349 $15,364 

Enter Data into Tracking Sys. 0.2 0.2 $9 1,744 349 $15,364 

Reconcile Discrepancies 0.5 0.5 $39 100 50 $3,892 

Respond to Questions 0.5 0.5 $39 300 150 $11,677 

Verify Payment 0.2 0.2 $16 1,744 349 $27,154 

File Documents 0.2 0.2 $9 1,744 349 $15,364 

TOTAL NA NA NA NA NA 1623 $90,454 
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Pesticide Registration Fee Waivers

The Agency’s burden consists of reviewing, evaluating, and notifying applicants of the 

Agency’s decision to grant or deny fee waiver requests; entering data into tracking systems; 

verifying fee payment; and storing/maintaining this information. Table 8 estimates EPA’s 

burden for performing these activities.1 

Table 8. Annual Agency Burden and Cost Estimates 

Collection Activities

Burden Hours Total

Mgmt Technical Clerical

$120.32 $77.85 $44.05 Hours Costs

per hour per hour per hour

Review submitted waiver 

request and notify requestor 

of decision

1 20 2 23 $1,765 

Enter data into tracking 

systems 0 0 0.5 0.5 $22 

Verify payment 0 0 0.5 0.5 $22 

Store/maintain/submit 

information 0 0 1 1 $44 

TOTAL 1 20 4 25 $1,854 

Annual Costs 

Hours 

per 

response

x 

Responses 

per year

= Hours 

per year

x Wage 

per hour

= Costs 

per year

Management: 1 307 307 $120.32 $36,938 

Technical: 20 307 6,140 $77.85 $477,999 

Clerical: 4 307 1,228 $44.05 $54,090 

 Total 25 307 7,675 $569,027 

6(d) Bottom Line Burden Hours and Cost Tables

Table 9. Total Annual Respondent and Agency Burden and Costs for Pesticide Product 

Registration Maintenance Fees

TOTAL ESTIMATES

Burden Hours Costs

Respondent Burden 1,993 $169,422 

Agency Burden 1,623 $90,454 

 

1 All table totals have been rounded to the nearest dollar or hour.
October 2013

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Table 10. Total Annual Burden and Cost Estimates for Pesticide Registration Fee 

Waivers

TOTAL ESTIMATES

Burden Hours Costs

 Type A 1,258 $86,986

 Type B 2,172 $129,188

 Type C 2,484 $150,132

Total Applicant -Annual

(Type A + Type B + Type C) 5,914 366,306

Agency - Annual 7,675 $569,027

Table 11. Combined Respondent Burden for the Pesticide Registration Fees Program 

ICR 

PROGRAMS TOTAL ESTIMATES

Burden Hours Costs

Pesticide Product Registration 

Maintenance Fee 1,993 $169,422 

Pesticide Registration Fee Waivers 5,914 $366,306 

Total 7,907 $535,728 

6(e) Reasons for Change in Burden

The total annual burden for respondents associated with pesticide product registration is 

1,993 hours, up from 1,651 hours, previously. The reason for the increase was a refinement in 

the estimate per response from 0.96 to 1.14 hours and a slight increase in the number of 

responses. Costs also increased since the last renewal because of labor cost increases.

The total estimated annual respondent burden for the pesticide registration service fee 

waivers information collection has increased slightly from 5,611 hours in the existing ICR, to 

5,914 hours for this renewal due to a slight increase in the number of responses. The average 

estimated burden per response for each of the three types of applications has not changed: 37 

hours for Type A, 12 hours for Type B, and 27 hours for Type C. In this renewal request, the 

annual number and distribution of responses among the three types are based on actual 

responses received. 

6(f) Burden Statement

The annual "respondent" (applicant) burden for the Pesticide Product Registration 

Maintenance Fee program is estimated to average 1.14 hours per form, or per respondent, as 

there is one form per respondent. The annual public reporting and recordkeeping burden for 
October 2013

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the collection of information for Pesticide Registration Service Fee Waivers is estimated to 

average 37, 12, and 27 hours per response, for the three different types of applications. Under 

PRA, “burden” is defined at 5 CFR 1320.3(b).

An agency may not conduct or sponsor, and a person is not required to respond to, a 

collection of information that is subject to the PRIA unless the Agency displays a currently

valid OMB control number. The OMB control numbers for EPA's regulations in title 40 of the 

CFR, after initial display in the final rule, are listed in 40 CFR part 9. Since the collection 

activities in this ICR are contained in the statute and not a current regulation, the OMB control 

number for this collection activity appeared in the Federal Register, and on the collection 

instruments. 

The Agency has established a public docket for this ICR under Docket ID No. EPAHQ-OPP-2013-0287, which is available for online viewing at http://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-2013-0287 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. Since an OMB Control Number has not yet been 

assigned to this ICR, please include docket ID No. EPA-HQ-OPP-2013-0287 in any

correspondence but do not submit any fees or fee waiver requests to these addresses.

ATTACHMENTS TO THE SUPPORTING STATEMENT

All of the attachments listed below can be either found in the docket for this ICR, or a 

link to the source is provided (unless otherwise noted); accessible electronically through 

http://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-2013-0287

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 The Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA) 

Section 4(i)(5) is available as part of the docket EPA-HQ-OPP-2013-

0287. 

Attachment B: Pesticide Registration Improvement Extension Act (PRIA 3) fees. 

Available electronically at 

http://www.epa.gov/pesticides/regulating/fees/tool/category-table.html
October 2013

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Attachment C: Guidance on IR-4 Exemptions. Available electronically at 

http://www.epa.gov/pesticides/fees/questions/guidance_ir-4.htm

Attachment D: EPA Form 8570-30 - Pesticide Registration Maintenance Fee Filing 

Form is available as part of the docket EPA-HQ-OPP-2013-0287.

Attachment E: Guidance on How to Request Small Business Fee Waivers. Available 

electronically at 

http://www.epa.gov/pesticides/fees/questions/waivers.htm

Attachment F: Worksheet for Estimating OPP ICR Wage Rates for Industry, and EPA 

Labor is available as a docket attachment EPA-HQ-OPP-2013-0287.

Attachment G: Consultations – Stakeholder response to consultation questions are

available as part of the docket EPA-HQ-OPP-2013-0287.