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SUPPORTING STATEMENT FOR

AN INFORMATION COLLECTION REQUEST (ICR)

1. IDENTIFICATION OF THE INFORMATION COLLECTION

1(a) Title of the Information Collection:

Certification of Pesticide Applicators

OMB No: 2070-0029; EPA No: 0155.12

1(b) Short Characterization/Abstract

The Environmental Protection Agency (EPA) administers certification programs for pesticide 

applicators under section 11 of the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA). 

FIFRA allows EPA to classify a pesticide as “restricted use” if the pesticide meets certain toxicity or 

risk criteria. This information collection request (ICR) addresses the paperwork activities performed by 

businesses, individuals and regulators to comply with training and certification requirements associated 

with restricted use pesticides (RUPs). Because of the potential of improperly applied RUPs to harm 

human health or the environment, pesticides under this classification may be purchased and applied only 

by “certified applicators” or by persons under the direct supervision of certified applicators. To become 

a certified applicator, a person must meet certain standards of competency; these standards are met 

through completion of a certification program or test. 

States, Indian tribal governments as well as Federal agencies administer applicator certification 

programs within their jurisdictions, but each agency’s certification plan must be approved by EPA 

before it can be implemented. Agencies authorized by EPA are collectively referred to in this document 

as “authorized agencies.” Currently all 50 States as well as some Indian tribes and Federal Agencies are 

authorized to run their own certification programs. Under authorized agencies’ certification programs, 

dealerships of RUP are not required to report their dealership information and RUP sales directly to 

EPA, and such information is not included in the paperwork burden estimates of this ICR. 

In areas where no authorized agency has jurisdiction, EPA may administer a certification 

program directly, called a Federal program. Federal certification programs require RUP dealers to 

maintain records of RUP sales and to report and update their names and addresses with the pesticide 

regulatory agency for enforcement purposes. Starting in 2014, the Agency implemented an EPAadministered applicator certification program for Indian Country1

and for Navajo Nation (79 FR 7185-

89).2 Under this EPA plan, dealerships operating in Indian Country are required to report their 

dealership and individual business names and addresses to EPA Regional offices.

 

1 The term Indian Country as it applies to the EPA-administered pesticide applicator certification plan is consistent with the 

statutory definition in 18 U.S.C. § 1151.

2 EPA resource directory for the Federal Certification to Apply Restricted Use Pesticides in Indian Country

(http://www2.epa.gov/pesticide-applicator-certification-indian-country; accessed on October 31, 2014)
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This ICR also addresses how registrants of certain pesticide products are expected to perform 

specific, special paperwork activities, such as training and recordkeeping, in order to comply with the 

terms and conditions of the pesticide registration (e.g., registrants of anthrax-related pesticide products 

that assert claims to inactivate Bacillus anthracis (anthrax) spores). Paperwork activities associated with 

the use of such products are conveyed specifically as a condition of the registration.

2. NEED FOR AND USE OF THE COLLECTION

2(a) Need/Authority for the Collection

EPA needs the data from this information collection activity to ensure that restricted use 

pesticides (RUPs) are only purchased and applied by certified applicators, or individuals under their 

direct supervision. A certified applicator is a person who has demonstrated competency in the safe 

handling and application of RUPs, and who has received certification to that effect. This collection also 

makes records of specific RUP applications available for investigations or enforcement actions 

concerning possible misuses or poisoning incidents. 

The authority for this information collection activity is provided under sections 3(d) and 11 of 

FIFRA and 40 CFR part 171. Section 3(d) of FIFRA authorizes EPA to classify registered pesticides as 

either general use or restricted use (see Attachment A). RUPs are those pesticides which, absent 

additional regulatory restrictions, may cause unreasonable adverse effects on people or the environment. 

Pesticides classified as restricted use may only be used by a certified applicator, or by a person under the 

direct supervision of a certified applicator. 

Section 11(a) of FIFRA grants EPA the authority to prescribe standards for the certification of 

RUP applicators (see Attachment B). Under Section 11(a)(2) of FIFRA, EPA approves authorized 

agency certification programs. While the bulk of the certification programs are implemented by State 

agencies (all 50 States are authorized), tribes and other Federal agencies are also authorized agencies. 

The regulations in 40 CFR part 171 include procedures for certification programs for States, Federal 

agencies, Indian tribes, or U.S. territories who wish to develop and implement their own certification 

plans and programs, after obtaining EPA approval (see Attachment C). Additionally, EPA has authority 

to directly administer certification programs in areas with no authorized agency program. 

EPA issued a Pesticide Registration Notice (PR Notice), on September 3, 2008, (73 FR 51467) 

informing registrants that certain conditions of registration will apply to anthrax-related products. The

PR Notice, titled “Guidance for Antimicrobial Pesticide Products With Anthrax-Related Claims,” 

(Attachment D) specifies that products claiming to inactivate anthrax spores should be: (a) supported by 

specific sporicidal efficacy studies that are acceptable to EPA; and (b) subject to specific terms and 

conditions of registration that limit the use of these products to specifically trained persons. The training 

and reporting information activities for registrants of anthrax-related products will not be imposed on 

respondents until a registration is granted.
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2(b) Practical Utility/Users of the Data

In the Federal program, persons applying for pesticide applicator certification use a form to 

submit vital contact and identification information such as name, date of birth, and address, and for 

verification of identity and to schedule applicators for certification or recertification. This data is 

necessary to ensure that RUP applications are only carried out by or under the supervision of persons

who have demonstrated competence in their proper use. Authorized agencies use their State or tribal 

authority to obtain this information.

Federal certification programs require dealers to maintain sales records for RUPs. Dealer 

records are necessary for EPA to ensure that access to RUPs is limited to certified applicators. Stateadministered (or authorized agency) certification programs use State authority to require dealers to 

maintain sales records for RUPs, and are not included in this ICR’s paperwork burden estimates.

EPA requires a record of each application of a RUP by a certified commercial applicator under 

federally-run programs. EPA monitors these records to assure that RUPs are used only by, or under the 

direct supervision of, certified applicators, and to ensure that pesticide labeling requirements are adhered 

to by applicators. This is done by requiring applicators to record details of the RUP application. 

Without these records it would be difficult to successfully enforce against misuse, or investigate 

accidents or poisoning incidents.

RUP application records are also required for certified commercial applicators under programs 

run by States or other authorized agencies. These records are monitored to assure that RUPs are used 

only by, or under the supervision of, properly trained and certified applicators and to ensure that 

pesticide labeling requirements are adhered to by applicators. This is done by requiring applicators to 

record the application (e.g., amounts, locations, and dates) of RUPs. Without these records it would be 

difficult to successfully enforce against misuse and ensure proper training and supervision of uncertified 

applicators. EPA uses annual reports from the authorized agencies as a monitoring tool to develop 

overall data on pesticide activities for OMB, Congress, and others; to distribute EPA grant funds to 

participating authorized agencies; to target enforcement activities; and to revise certification and training 

program emphasis and requirements. 

In the case of certain RUPs like anthrax-related products, the Agency requires data to ensure that 

the sale and use of registered anthrax-decontaminant products is limited to persons who are trained in 

the safe and effective use of such products. Training must be repeated every two years. The required 

registrant training will help ensure that applications of anthrax-related products are performed safely, 

effectively and in accordance with the requirements of Federal, State and local authorities. 

Due to the high risks involved in treating areas/objects contaminated with highly virulent and 

persistent anthrax spores, the Agency is limiting availability of anthrax-related products to those persons 

or companies who have a legitimate need. With this approach, these products will not to be sold, 

offered for sale, or distributed to the general public. EPA and other authorized agencies (e.g., 

Department of Homeland Security, Department of Defense, and other Federal and State agencies) will 
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use the recorded information to carry out decontamination activities and to conduct enforcement 

investigations, if needed, in the event of a bioterrorism attack. Registrants must maintain records of 

persons who have been trained and entities to which the product has been sold or distributed. Normally, 

records will not be submitted to EPA unless EPA requests them, such as in the event of a bioterrorism 

attack or in conjunction with enforcement investigations.

3. NON DUPLICATION, CONSULTATIONS, AND OTHER COLLECTION CRITERIA

3(a) Non duplication

EPA is the only Federal agency with the authority to certify applicators of restricted use 

products. However, the United States Department of Agriculture (USDA) also has regulations which 

impact certified applicators. USDA has regulations which require private applicators to maintain 

records regarding the application of RUPs. The records required by USDA under 7 CFR 110 are more 

specific than those required by EPA under 40 CFR 171.

FIFRA prohibits EPA from requiring private applicators to keep records or make reports, so 

there is no duplication of recordkeeping with regard to private applicators. EPA only requires 

recordkeeping for commercial applicators. Consequently, no duplication of requirements exists.

To prevent duplication and facilitate authorized agency reporting, EPA permits authorized 

agencies to use grant reports in lieu of separate annual reports to EPA, and authorized agencies may 

amend their plan with an addendum.

No other Federal, State, or tribal government agency requires that registrants conduct training for 

anthrax-related products, or that registrants keep information on persons trained or to whom anthraxrelated products have been sold or distributed. 

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

In proposing to renew this ICR, EPA published a Federal Register Notice (79 FR 43039) on July 

24, 2014, and provided a 60-day public notice and comment period. No public comments were 

received.

3(c) Consultations

During preparation of this ICR renewal, EPA staff contacted seven representatives from a crosssection of stakeholders to seek feedback on the burden estimates in the ICR, the clarity of instructions 

provided, and other questions pertaining to the requirements of the program. The four stakeholders

listed below responded either by email or through a phone interview. Full consultations responses from 

these stakeholders can be found in Attachment E. 
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1. Jasmine LR (Courville) Brown 

Confederated Salish and Kootenai Tribes Pesticide Program (Government Applicators)

PO Box 278 

Pablo, Montana 59855

jasmineb@cskt.org

2. Janice Cooney

Cooney Fertilizer, Inc.

1030 26th Road

Walthill, NE 68067

jycooney@yahoo.com.

3. Laurie Gordon

Oregon Department of Agriculture, 

475 NE Bellevue Dr., Ste. 110, 

Bend, OR 97701

lgordon@oda.state.or.us

4. Andrew Beck

Pennsylvania Department of Agriculture, 

2301 N. Cameron St

Harrisburg, PA 17100

andrbeck@pa.gov

While stakeholders generally found the instructions clear and agreed that the burden estimates 

for reporting and record keeping in this ICR are reasonable, a respondent under the authorized agencies 

category (Table 1 of this ICR) suggested changes to the burden estimates for two activities which are 

four times those of our estimates. This comment did not provide an explanation of how those estimates 

were derived and EPA has not changed the estimates at this time.

Another consultation response regarding tribal certification suggested that the number of dealers

in Indian country or Indian reservations cannot be just 10, as stated in Table 5a. of this ICR, but could be 

around 75. However, EPA believes that the comment was provided for dealers under the authorized 

agencies while the 10 dealerships discussed in the ICR are for the Indian country program directly 

administered by EPA.

A commercial applicator’s comment on burden estimates stated that the ICR does not reflect the 

time it takes to comply with record keeping requirements (Table 3), and provided a base-line burden of 

15 minutes per application. The ICR fully accounts for the relevant activities as listed by the 

stakeholder, and the estimated burden is 3.1 hours.

EPA received other consultations responses regarding the ease of reporting as well as accuracy 

and availability of information on its website. One of the States consulted commented on the public 

availability and duplication of the information collected under this ICR, and provided a list of online 

resources where certification/licensing and applicator training information is publicly available. ODA

pointed out that State licensing staff can be contacted for more specific data or public records requests. 
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The Agency understands that ODA’s online resources include databases where dealer, applicator

certification and dealership “licensing” information can be searched. While the suggested resources can 

provide partial information for some categories of the data required in the annual reports, the data does 

not provide the type of information that can serve its intended purpose as required by the Federal 

regulation under States’ grants agreements. In addition, as indicated in Section 3(b) of this ICR, EPA 

permits authorized agencies to use grant reports in lieu of separate annual reports to EPA to prevent 

duplication and to facilitate reporting, and authorized agencies may amend their plan with an addendum.

All 50 states currently administer the certification program based on individual state plans that 

are approved by EPA. Under a cooperative agreement with EPA, States are required to submit annual 

reports that describe program activity and planned changes to State plans. The reports detail the number 

of applicators certified, which an important piece of information as the state allocation for training is 

based on the numbers of applicators certified. These reports are the basis for the information collection 

that this request addresses.

3(d) Effects of Less Frequent Collection

Authorized agencies’3reports on certification program activities are submitted to EPA annually, 

which is a minimal reporting period. Most annual reporting information required under the regulation is 

contained in authorized agencies’ annual grant report to EPA, and can be submitted as a joint package. 

Budget requests and the distribution of cooperative agreement funds are also done on an annual basis. 

The annual report data is used to support budget requests and to apportion cooperative agreement funds.

Less frequent collection of information would be less efficient for overall reporting by authorized 

agencies. In addition, less frequent collection of information would not allow EPA to distribute these 

funds in the most equitable manner, as data demonstrating need would not be current.

For anthrax-related products, the information kept by registrants on certification, training and 

records regarding the persons to whom the product was sold will be requested only as needed (such as 

for an enforcement investigation), which should be very infrequently. Accordingly, less frequent 

collection of data would not meet the EPA’s needs.

3(e) General Guidelines

FIFRA section 11(a)(1) requires that EPA use a form for applicators to apply for certification 

whenever the Agency administers the Certified Pesticide Applicator program in the place of a program

administered by an authorized agency. The two forms used for this collection activity are EPA Form 

8500-17-N, Request for Pesticide Applicator Certification in Navajo Indian Country (Attachment F) for 

use in Navajo Indian Country, and EPA Form 8500-17, Request for Pesticide Applicator Certification in 

Indian Country (Attachment G) to be used nationally for all Indian Country except Navajo. In Navajo 

Indian Country, the previous form will continue to be used. The recordkeeping activities briefly 

 

3

“Authorized agencies” are defined in section 1(b) of this ICR as EPA-authorized agencies of States and Indian tribal 

governments as well as Federal agencies.
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described herein will not exceed OMB’s guideline that agencies not require records to be retained for 

more than 3 years (5 CFR 1320.5(d)(2)(iv)). 

3(f) Confidentiality

The activities or records proposed in this information collection do not include any confidential 

business information (CBI). Date of birth, which falls under the Privacy Act as personally identifying 

information (PII), is collected in the process of certifying individuals to apply restricted use pesticides 

(RUPs) as private or commercial applicators. This information is collected to differentiate between 

individuals sharing the same names. The Agency published a Privacy Act System of Record Notice 

(SORN) in January of 2013 (77 FR 2060) covering application forms for RUP applicator certification 

under certification plans administered by EPA regional offices or the Office of Pesticide Programs, as 

described in (75 FR 49489; August 13, 2010). This system of records, entitled ‘‘Records of Pesticide

Applicators Certified Under EPA Administered Certification Plans,’’ covers identification information 

such as birth dates. Records covered by this system of record notice are subject to Agencywide security 

requirements governing all Privacy Act database systems at EPA. System administrators may disclose 

certain personal information (e.g., names, addresses, EPA certification numbers, categories of

certification) upon request as described in the section describing routine uses of records maintained in 

the system. The Tribal Pesticide Program Council and other tribes requested EPA to make certain 

information available online to facilitate their ability to confirm private and commercial certifications. 

The Agency plans to publish only the name, zip code and certification information for private 

applicators.

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, as amended, “Responsibilities for the Maintenance of Records about 

Individuals by Federal Agencies.”

4. THE RESPONDENTS AND THE INFORMATION REQUESTED

4(a) Respondents/NAICS codes

The North American Industrial Classification System (NAICS) codes for respondents 

participating in the data collection activity are noted here:

Applicators on Farms (“Private Applicators”): 

111 Crop Production

112 Animal Production
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Commercial Services Applicators:

561710 Exterminating and Pest Control Services

Administration of Certification Programs by States/Tribal Lead Agencies (“authorized 

agencies”):

924110 Environmental protection program administration

926140 Pest control programs, agricultural, governmental

Pesticide Dealers (only for EPA-administered programs – the Federal Certification Plan for 

Indian Country):

444220 Retail Nursery, Lawn, and Garden Supply stores

424910 Agricultural chemicals merchant wholesalers

Pesticide and Other Agricultural Chemical Manufacturing: 

32532 Individuals or entities engaged in activities related to the registration of a pesticide 

product

4(b) Respondent Activities

(i) Information Collections (ICs)

The respondent activities covered in this ICR have been organized according to the following

ICs in the electronic ICR submission system (ROCIS):

 Annual Reports

 Application for Federal Pesticide Applicator Certification

 Recordkeeping by Federally-Certified Commercial Applicators (RUPs)

 Recordkeeping by Commercial Applicators (RUPs)

 Recordkeeping by Restricted Use Pesticide Dealers in Indian Country

 Reporting by Restricted Use Pesticide Dealers in Indian Country

 Training of Some Federally-Certified Private Applicators

 Submission of Anthrax-Related Training and Examination Materials by Registrants

 Records for Anthrax-Related Training and Sales/Distribution by Registrants

 (ii) Data items, including reporting and recordkeeping requirements

Annual Reporting by Authorized Agencies on Certification and Training Programs

Annual reports are required from States, Indian tribes, and Federal agencies with EPA-approved 

certification plans. These authorized agencies must develop reports based on the requirements in the 

regulations, including information on their respective program activity, such as the number, type, and 

category of applicators certified and recertified, and any significant changes to their plans. 
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Dealer Reporting in Federal (EPA-administered) Programs Indian Country

The regulations require dealers under Federal programs to report to EPA the business name as 

well as the name and address for each dealership. The report must only be submitted once, but updated 

information must be submitted if the dealership information changes. This information is used for 

inspection and enforcement purposes. 

Application for Certification in EPA-administered Programs in Indian Country

In Federal programs, regulations require that an application form (EPA Form 8500-17-N, 

Request for Pesticide Applicator Certification in Navajo Indian Country (Attachment F); and EPA Form

8500-17, Request for Pesticide Applicator Certification in Indian Country; (see Attachment G) be 

completed for persons seeking certification or recertification. The forms are necessary for EPA to 

certify and recertify applicators, by obtaining vital information on certified applicators such as name, 

date of birth address, and type and category of certification. 

EPA administers a Federal program (for both private and commercial applicators) throughout 

Indian Country nationally during this ICR renewal cycle; one of the application forms listed above must 

be submitted to obtain certification. This program expanded on an existing program to certify 

applicators in Navajo Indian Country. Applicators with current certification from an authorized agency

will be eligible for certification in Indian Country with proof of certification and a completed form. 

Private applicators will also be given the option to complete training and submit a completed form in 

lieu of a current existing certification. 

Private Applicator Training – Federal Programs

In accordance with FIFRA Section 11(2), and 40 CFR 171.11(d)(1), EPA has developed a 

training program that private applicators can take to obtain training, as described in the regulations, as 

well as submit the completed form in order to obtain their certification. This training is not required 

since these applicators still have the option to submit proof of current certification from an authorized 

agency with a completed form to receive their federal certification (see Attachment G).

Dealer Recordkeeping in Federal (EPA-administered) Programs in Indian Country

The regulations require dealers under Federal programs to keep records of the sale of RUPs for 

24 months. Dealer records are maintained at the pesticide dealership, and are not routinely submitted to 

EPA; however, they may be collected as part of an investigation or enforcement action. This is 

necessary for EPA to ensure that access to RUPs is limited to certified applicators, or those under their 

direct supervision. Without the ability to limit access to RUPs, there would be little purpose in 

certifying applicators or classifying pesticides as restricted use. This provision is solely intended to 

provide EPA with the authority to impose dealer recordkeeping in entities with EPA-administered 

programs. Programs administered by authorized agencies must use their own laws and regulations to 

require dealers to maintain records of RUP sales. 

Commercial Applicator Records of RUP Use – Federal Programs

Commercial applicators under EPA-administered programs must generate records on the kinds, 

amounts, uses, dates and places of RUP applications immediately after the application is complete. 
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Specifically, EPA requires commercial applicators to record the following information: the name and 

address of the person for whom the pesticide was applied; the location of the application; the target 

pest(s); the specific crop or commodity, as appropriate; the name and registration number of the 

pesticide applied; the amount applied and percent active ingredient per unit of pesticide used; and the 

type and amount of leftover pesticide disposed of with the method and location of disposal. Records 

must be retained for two years. Records are not required to be submitted, but they must be made 

available to EPA or officials of authorized agencies upon request. Records collected may become part 

of an enforcement action or investigation.

Commercial Applicator Records of RUP Use – Programs under Authorized Agencies

Commercial applicators under programs administered by authorized agencies must generate 

records on RUP applications immediately after the application is complete. In programs administered 

by authorized agencies, the information recorded includes what EPA requires (described above in 

Federal programs) as well as any requirements by the authorized agency. 

Records are not required to be submitted, but they must be made available to EPA or officials of 

authorized agencies upon request. Records collected may become part of an enforcement action or 

investigation.

Anthrax-Related Products: Training and Examination Materials

Registrants of anthrax-related products develop training and examination materials and submit 

them to EPA as part of the application for registration or amendment for EPA’s review and approval. At 

a minimum, these materials will include:

 Characteristics of and human health hazards posed by B. anthracis spores;

 Personal Protective Equipment (PPE) appropriate for protection against both B. anthracis spores 

and the pesticide product itself;

 Detailed instructions for safe and effective use of the pesticide product and any associated 

equipment;

 Detailed review of all steps involved in the decontamination process as provided in guidance 

from Federal agencies as well as review of applicable federal statutory and regulatory 

requirements and guidance; and

 A written examination.

Registrants will use the examination to assess whether the trained applicator's competency on the 

above issues is acceptable.

Anthrax-Related Products: Records of Persons Trained by the Registrant

Registrants of anthrax-related products will keep records of the persons who complete training 

on the use of their products. Such information would include, at a minimum, the person’s name, 

address, telephone number, and date of completion of training. 
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Anthrax-Related Products: Records of Persons to Whom Registrant Sells/Distributes Product

Registrants of anthrax-related products will keep records of the persons/entities to whom they 

sell or distribute their products. Such information would include, at minimum, the person’s or entity’s 

name, address, telephone number, date, and amount of product. 

 (iii) Respondent Activities

Typically, authorized agencies respondents will perform the following activities:

Activity Detail

Read rules or other instructions Read applicable regulations, 40 CFR 171, grant requirements, and 

other applicable requirements

Receive Training Administered by EPA-approved program or EPA

Create information Document activities/applications

Gather information Collect records needed to develop annual report

Review Review information for accuracy

Complete written forms or other 

instruments

Extract data from records and compile into reporting format

Record, disclose, display, or 

report the information

Compile report and submit. Record maintenance for preparation of 

the next annual report, such as grant reports and hard copy and 

computer records of data required in the annual report.

Store, file, or maintain 

information.

Store and retain records.

A typical registrant of an anthrax-related product will perform the following activities:

Activity Detail

Read rules or other instructions Read applicable regulations (40 CFR 152) and guidance (PR Notices, 

etc.) 

Develop training & exam, and 

recordkeeping method

Document development of materials and recordkeeping methods

Review Review information for accuracy

Submit training and exam 

materials to EPA

Compile training and exam materials and submit to EPA

Gather and review information Collect and review recordkeeping information

Submit recordkeeping

information, if requested.

Compile report and submit, if requested. 

Record, store, file, or maintain 

information.

Record, store and retain records.
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5. THE INFORMATION COLLECTED - AGENCY ACTIVITIES, COLLECTION 

METHODOLOGY, AND INFORMATION MANAGEMENT

5(a) Agency Activities

In continuing this collection for Federal certification programs and authorized agencies, EPA 

will:

 Prepare reports

 Answer respondent questions.

 Review data submissions.

 Record data submissions.

 Develop/maintain a master database for data submissions.

 Reformat and distribute data.

 Store data.

 Administer training.

For anthrax-related products, EPA will:

 Answer respondent questions.

 Review training and examination materials.

 Record data.

 Maintain data.

 Store data.

 

5(b) Collection Methodology and Management

Authorized agencies: Annual reports from authorized agencies are required. EPA allows 

respondents to use their end-of-year grant reporting to fulfill the annual report requirement under this 

collection program to the extent that information contained in such grant reports satisfies 40 CFR part 

171 requirements. Certain minor reporting elements which may be outside the scope of the grant reports 

may be provided in whatever fashion the respondent finds most convenient and least burdensome. The 

information required under this program is generally included in the grant reports as a 2-3 page 

addendum to that report. A web-based template for electronic completion and submission of the annual 

reports (Certification Plan and Annual Reporting Database4) has been used by all states since 2006. 

EPA does not require the submission of dealer records or commercial applicator records, but rather 

requires that they furnish records for inspection and copying upon request. 

Dealership information: As of a few years ago, all 50 States in the U.S. run their own Pesticide 

Application Certification programs, and dealership information for the States is no longer reportable to 

 

4 The Certification Plan and Annual Reporting Database is available at: 

http://cpard.wsu.edu/login.aspx?ReturnUrl=%2fDefault.aspx
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EPA. With the implementation of the Federal Certification plan for Indian Country in 2014, however, 

RUP dealers under this program are required to report each dealership’s name and address to the 

appropriate EPA Regional offices. There are currently 10 RUP dealers under this EPA-administered 

program. 

Applicators: The applicator certification application form is used as an initial reference point 

for potential certified applicators in Federal programs. In addition to basic questions about the 

certification desired, the forms require identification information such as name, address, date of birth. 

Applicants to the Federal certification program mail completed forms to the respective EPA Regional 

office, which compiles and maintains data on program operations. The public may access information 

about the program and its operations data through the appropriate EPA Regional office. Contact 

information can be found in the instructions section of the Federal certification form.

Private applicators in the Federal plan now have the option of taking an EPA-developed course, 

then use an auto-generated code provided after their classes end to fill in the form to attest that they have 

completed the course. 

Anthrax-related materials: Training materials submitted by registrants will be handled like any 

other registration data submissions. That is, each document will be assigned a Master Record 

Identification (MRID) number, converted to an electronic copy, and stored in EPA’s existing data

library. Applicable records for sale, use and training shall be available on site for inspection as needed. 

5(c) Small Entity Flexibility

This information collection applies specifically to individuals who are certified applicators. 

EPA believes that the records required of certified pesticide applicators and their employees are minimal 

and would generally be kept for the applicators’ own use even in the absence of this regulation. In 

Federal programs for Indian Country, where EPA administers the certification program, dealers are also 

required to keep records. EPA does not require the submission of records kept by dealers or commercial 

applicators, but rather requires that they furnish records for inspection and copying upon request.

Most affected entities (certified applicators, pesticide dealers) are small entities. The information 

collected and the recordkeeping required is the minimum required by regulation and that is necessary to 

implement a successful certification program.

Pursuant to FIFRA Section 11(a)(2), the optional training program that EPA has developed does 

not require that applicators take examinations for private pesticide application certification applicants.

In lieu of taking this optional training, applicants for private applicator certification still have the option 

to submit proof of current certification from an authorized agency with a completed form to receive their 

federal certification

For anthrax-related products, regulations apply specifically to registrants, most of whom are 

likely to be small entities. EPA believes that the records required of registrants are minimal. The 
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information collected and the recordkeeping is the minimum necessary to meet the conditions of 

registration described in the PR Notice: Guidance for Antimicrobial Pesticide Products with AnthraxRelated Claims.

5(d) Collection Schedule

There is no set collection schedule for commercial applicators. Commercial applicators must 

generate records on the kinds, amounts, uses, dates, and locations of RUP applications immediately after 

pesticide application, and are required to maintain these records for two years. 

Similarly, dealer records of RUP sales are required to be maintained for two years. Although the 

commercial applicator records and the dealer records are maintained locally and are not required to be 

submitted to EPA or the authorized agencies, they must be made available for EPA or authorized agency 

officials upon request. Records collected may become part of an investigation or enforcement action. 

Commercial applicators in EPA-administered programs must also submit an application form for 

certification or recertification, whenever needed.

Authorized agencies with an EPA-approved plan to administer their own applicator certification 

program must submit a report annually. The annual reporting period allows for efficiency in authorized 

agencies as most required information is contained in their end-of-year grant report, which can be 

submitted as a joint package. The annual reporting cycle also facilitates equitable apportionment of 

cooperative agreement funds to authorized agencies, based on data submitted.

There is no collection schedule for any data for anthrax-related products. Training and 

examination materials are only submitted with the application for registration or amendment. 

Information about training, sale, and distribution of anthrax-related products, including to whom product 

is sold, is not submitted unless EPA requests it, which would likely be infrequently.

6. ESTIMATING THE BURDEN AND COST OF COLLECTION

6(a) Estimating Respondent Burden

Authorized Agencies’ Reporting for Certification and Training Programs

Authorized Agencies’ reports on certification and training programs: EPA based the 

respondents’’ burden hour estimates on experience with and knowledge of the Certification and Training 

Program; Regional contacts and budget staffing records of the Regional offices; and information 

obtained from the consultation process, USDA, authorized agencies, and other resources. The total 

annual burden for EPA’s State, Federal, and Tribal partners (authorized agencies) to report on 

certification and training programs is estimated to be 4,409 hours, with an average annual burden of 77.4 

hours for each of the 57 participating entities (see Table 1). The average per-State burden was based on 

several estimates provided to EPA by participating States.
January 27, 2015

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Certification and/or training applications under EPA-Administered Program

EPA now administers two separate programs under the Federal certification plan for Indian 

Country throughout the US: a Federal plan for Navajo Indian Country, and a national Federal plan for all 

other Indian Country. The national plan was implemented beginning February 6, 2014 and the number 

of applicators utilizing the program is not yet known. The burden and cost estimates below represent a 

single estimate for both Federal plans in Indian Country throughout the U.S. Although the plan for 

Navajo Indian Country has been in effect for several years, and the national plan was only recently 

implemented, the combined burden estimates are based on the maximum burdens anticipated in any year 

during this ICR renewal cycle.

The Agency estimates that 8,300 application forms will be submitted for both commercial and 

private pesticide applicator certification/ re-certification in the EPA-implemented program in Indian 

Country once a 3-year ICR cycle, resulting in an annual average of 2,767 applications for certification in 

the Federal program. With an average per-response burden estimate of 0.17 hours (10 minutes), the 

total annual burden for completing certification application forms for both commercial and private 

applicators is estimated to be 470 hours (see Table 2a). Since the Federal Program is managed by 

Agency personnel, this burden estimate is based on the experience of the personnel in EPA’s Region 9, 

which runs the program in Navajo Indian Country, and extrapolated to all of Indian Country. 

The optional, EPA-administered course for private applicators in the Federal plan is expected to 

take up to 12.1 hours total. Further, the Agency estimates that up to 30 private applicators will choose 

the optional training5in the next three years, with an average of 10 such trainees every year. The 

estimated total annual burden for this response is 121 hours (Table 2b).

Recordkeeping for RUP Sales and Pesticide Applications

Commercial applicators under the Federal (EPA-administered) program: The total annual burden 

of recordkeeping for restricted use pesticide applications by commercial applicators under Federal 

certification programs (Indian Country throughout the U.S.) is estimated to be 10,044 hours, with an 

average burden estimate of 3.1 hours per response, for each of an estimated 3,240 responses (see Table 

3).

Commercial applicators under programs administered by “authorized agencies”: Commercial 

applicators and firms under authorized programs are also required to generate and maintain records of 

RUP applications immediately after the application. The Agency estimates that 421,000 commercial 

applicators will be subject to the recordkeeping requirements, for a total annual response burden of 

1,305,100 hours. The average per-response burden is 3.1 hours (see Table 4).

 

5 Private Pesticide Applicator Certification (Indian Country)

http://www2.epa.gov/pesticide-applicator-certification-indian-country/training-private-applicators-indian-country
January 27, 2015

Page 16 of 26

Dealer sales of RUP Products under Federal (Indian Country, EPA-administered) programs:

RUP dealers are required to record sales of RUPs and maintain these records. In this ICR, only the cost 

and burden estimates for dealer recordkeeping under federal certification programs are included. All 50 

States have implemented certification programs which they currently administer. States’ certification 

programs use State authority to require dealers to maintain sales records for RUPs, and are not included 

in the estimates of this ICR.

The Agency estimates that there are 10 RUP dealers in Indian Country. Each RUP dealer has 

approximately 39 RUP sales transactions per year, which require approximately 3 minutes of dealer 

burden per transaction. This results in 19.50 hours total annual burden to collect and record information 

(Table 5a).

RUP Dealership Information Reporting

Dealership information under EPA-administered programs: RUP dealers are required to report 

the name of the business and each dealership’s names and address to EPA only once. However, updated 

information must be submitted if the dealership information changes. This may include a new company 

submitting contact information, and existing company submitting a name change, or contact information 

change such as an address or telephone number change, or an company that is no longer in business 

submitting information. 

Based on the current number of 10 dealers under the Federal program, the Agency estimates that 

approximately one third of the 10 respondents will require some type of information change over a three 

year period, or approximately one RUP dealer per year. Each of the dealership information reporting 

activities is estimated to require approximately 1 hour of dealer burden. This results in an annual total 

burden of approximately one hour to collect, submit, and maintain information (Table 5b).

Applicator training and sales of anthrax-related products

In estimating the average respondent burden related to the information collection components on 

anthrax-related products, EPA based the burden hour and cost estimates on its experience and 

information obtained from the consultation process and other resources. The total annual burden for 

affected registrants for training and examination activities is estimated to be 50 hours, with an average 

burden of 25 hours each for approximately 2 registrants (see Table 6). The total annual burden for 

recordkeeping of persons trained and persons/entities to whom anthrax-related products are sold or 

distributed is estimated to be 37 hours, with an average burden of 18.5 hours for each of 2 registrants 

(see Table 7).

6(b) Estimating Respondent Costs

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

for affected industries, state government, and EPA employees based on publicly available data from the 

US Bureau of Labor Statistics. The formulas used to estimate the labor rates and formulas used to derive 
January 27, 2015

Page 17 of 26

the fully loaded rates and overhead costs for this ICR renewal are listed in Attachment H.

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 2013 data.

Unloaded Wage 

Rate

Wages are estimated for labor types (management, technical, and clerical) within 

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

available in the National Industry-Specific Occupational Employment and Wage 

Estimates from the Bureau of Labor Statistics (BLS) at 

http://www.bls.gov/oes/current/oes_nat.htm. 

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

website for each sector is included in that sector’s wage rate table (see Attachment H). 

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 45% of unloaded wage rates, based on 

benefits for all civilian nonfarm workers, from 

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

which 45% is not applicable, the applicable percentage will be stated.

Fully Loaded 

Wage Rate

We multiply the loaded wage rate by 50% (EPA guidelines 20-70%) to get overhead 

costs.

The following tables illustrate the estimated burden and costs associated with the information 

collection activities of this program.6 For annual report activities, the estimated average annual cost per 

participating State or other authorized agency is about $3,739.58, with the total annual cost for all 

authorized agencies estimated to be $213,156.06 (Table 1).

The estimated average annual cost for certifying commercial and private applicators in Indian 

Country is $5.48 per respondent, with the total annual cost for all certified applicators estimated to be 

about $15,163.16 (Table 2a). 

The optional, EPA-administered training course for private applicators in the Federal plan is 

expected to cost $390.10 per response. Based on 10 private applicators opting for the course, the total 

annual cost estimates for this activity are $3,901 (Table 2b).

The total annual respondent cost for all commercial applicator recordkeeping of RUP 

applications in Indian Country is estimated at $323,805.60 with an average annual per-respondent cost 

 

6 Values are rounded to the nearest two decimal places, and actual column totals may be slightly higher or lower.
January 27, 2015

Page 18 of 26

of $99.94 (Table 3). 

Recordkeeping of applications by all commercial applicators under State authority has an 

estimated total annual cost of $42,074,740, based on the commercial applicator count of 421,000, with 

an average annual per-respondent cost of about $99.94 (Table 4). 

The estimated average annual cost per respondent for all RUP dealers in Indian Country to 

record sales and maintain records is $2.30, with the total annual cost for all 10 RUP dealers estimated to 

be approximately $896.22. This assumes 39 RUP sales transactions per dealer per year, with 3 minutes 

required during each transaction, or approximately 19.5 hours per year for the 10 respondents over the 

course of a year (Table 5a).

Under the Federal certification plan, the agency estimates that a third of the current respondents 

are either new or have had to submit dealership change information every year. Using the same 

respondent numbers to forecast for the next three years, with a conservative per-activity burden of 1 

hour, and a per-response average annual cost of $45.96 (10 dealers x 1/3 x wage rate), EPA estimates 

the total annual cost for this activity at $153.05 (Table 5b).

For registrants of anthrax-related products, the estimated average annual cost per registrant for 

training and examination materials is about $1,718.66, with the total annual cost for all registrants 

estimated to be almost $3,437.32 (Table 6). 

The estimated average annual cost to these respondents for recordkeeping activities is approximately 

$1,306.29 per registrant, with the total annual cost for all registrants estimated to be about $2,612.58

(Table 7).

Table 1. Average Annual Respondent Burden and Cost Estimates to Authorized Agencies for 

Annual Reports on Certification and Training Programs

Collection Activities

Annual Burden Hours Per 

Respondent TOTALS

Tech.

$59.17/hr.

Clerical

$40.81/hr. Hours Cost$

Read/hear rule or any collection instrument instruction 

(incl. compliance determination) 0.25 0 0.25 14.79

Create information 5 0 5 295.85

Gather information 5 0 5 295.85

Process, compile, review info for accuracy 1 0 1 59.17

Complete written forms or other instruments 0.5 0.5 1 49.99

Record, disclose, display, or report the information 20 45 65 3,019.85

Store, file, or maintain the information 0 0.1 0.1 4.08

TOTAL 31.75 45.6 77.35 3,739.58

TOTAL ANNUAL BURDEN: 77.35 hrs. /respondent x 57 respondents = 4,409 hrs.

TOTAL ANNUAL COST: $3,739.58/respondent x 57 respondents = $213,156.06
January 27, 2015

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NAICS codes

State government: 999200

Technical, Life, Physical, and Social Science Occupations: 19-0000

Clerical, Office and Administrative Support Occupations: 43-0000

Table 2a. Certified Applicators in Federal Programs (Indian Country) for Completion of EPA 

Form to Apply for Certification 

Collection Activities Annual Burden and Cost Per Respondent

Tech. Hours

$32.24/hr.

Total Hours Cost

$

Read/hear rule or any collection instrument instruction (incl. 

compliance determination)

0.07 0.07 2.26

Complete written forms or other instruments 0.10 0.10 3.22

TOTAL 0.17 0.17 5.48

TOTAL ANNUAL BURDEN: 0.17 hrs. /respondent x 2,767 respondents = 470.39 hrs.

TOTAL ANNUAL COST: $5.48/respondent x 2,767 respondents = $15,163.16

NAICS code: 37-3012 

Pesticide Handlers, Sprayers, and Applicators, Vegetation: 37-3012

Table 2b. Optional Private Applicator Training in Federal Programs (Indian Country) 

Collection Activities Annual Burden and Cost Per Respondent

Tech. Hours

$32.24/hr.

Total Hours Cost

$

Read/hear rule or any collection instrument instruction (incl. 

compliance determination) 0.07 0.07 2.26

Complete optional EPA-administered training program 12 12 386.88

Complete written forms or other information 0.03 0.03 0.97

TOTAL 12.1 12.1 390.10

TOTAL ANNUAL BURDEN: 12.1 hrs. /respondent x 10 respondents = 121 hrs.

TOTAL ANNUAL COST: $390.1/respondent x 10 respondents = $3901.00

NAICS code: 37-3012 Pesticide Handlers, Sprayers, and Applicators, Vegetation
January 27, 2015

Page 20 of 26

Table 3. Average Annual Respondent Burden and Cost Estimates for Commercial Applicators in 

Federal Programs (Indian Country) for Recordkeeping for RUP Applications

Collection Activities Annual Burden and Cost Per Respondent

Tech. Hours

$32.24/hr.

Total 

Hours

Cost

$

Read/hear rule or any collection instrument instruction (incl. 

compliance determination)

0.2 0.2 6.45

Create information 2 2 64.48

Store, file, or maintain the information 0.9 0.9 29.02

TOTAL 3.1 3.1 99.94*

TOTAL ANNUAL BURDEN: 3.1 hrs. /respondent x 3,240 respondents = 10,044 hrs.

TOTAL ANNUAL COST: $99.94/respondent x 3,240 respondents = $323,805.60

NAICS code: 37-3012 Pesticide Handlers, Sprayers, and Applicators, Vegetation

Table 4. Average Annual Respondent Burden and Cost Estimates for Commercial Applicators 

and Firms under Authorized Agency Programs for Recordkeeping for RUP Applications

Collection Activities Annual Burden and Cost Per Respondent

Tech. Hours

$32.24/hr.

Total Hours Cost

$

Read/hear rule or any collection instrument instruction 

(incl. compliance determination)

0.2 0.2 6.45

Create information 2 2 64.48

Store, file, or maintain the information 0.9 0.9 29.02

TOTAL 3.1 3.1 99.94

TOTAL ANNUAL BURDEN: 3.1 hrs. /respondent x 421,000 respondents = 1,305,100 hrs.

TOTAL ANNUAL COST: $99.94/respondent x 421,000 respondents = $42,074,740

NAICS code: 37-3012 Pesticide Handlers, Sprayers, and Applicators, Vegetation

Table 5a. Dealers in Federal Programs (Indian Country) for RUP Sales Recordkeeping 

Collection Activities

Annual Burden and Cost Per Respondent

Tech. Hours

Total Hours

Cost

$45.96/hr. $

Read/hear rule or any collection instrument 

instruction (incl. compliance determination) 0.02 0.02 0.92

Create information 0.02 0.02 0.92

Store, file or maintain the information 0.01 0.01 0.46

TOTAL 0.05 0.05 2.30

TOTAL ANNUAL BURDEN: (.05 hrs. /respondent x 10 respondents) x 39 responses per respondent = 19.5 hrs.

TOTAL ANNUAL COST: ($2.30/respondent x 10 respondents) x 39 responses per respondent = $896.22
January 27, 2015

Page 21 of 26

NAICS code: 444200 Retail Nursery, Lawn and Garden Supply Stores.

Table 5b. Dealers in Federal Programs (Indian Country) for Reporting Dealerships’ Name and 

Address Changes

Collection Activities Annual Burden and Cost Per Respondent

Tech. Hours

$45.96/hr.

Total Hours Cost

$

Read/hear rule or any collection instrument instruction 

(incl. compliance determination)

0.2 0.2 9.19

Create information 0.3 0.3 13.79

Report dealership contact information 0.4 0.4 18.38

Store, file or maintain the information 0.1 0.1 4.60

TOTAL 1 1 45.96

TOTAL ANNUAL BURDEN: 1 hrs. /response x 10 dealers x 1/3 = 3.33 hrs.

TOTAL ANNUAL COST: $45.96 /response x 10 respondents x 1/3 = $153.05

NAICS code: 444200 Retail Nursery, Lawn and Garden Supply Stores.

Anthrax Related Activities

Table 6. Anthrax-related products: Average Annual Respondent (Registrant) Burden and Cost 

Estimates for Training and Examination Materials

Collection Activities Annual Burden Hours Per 

Respondent

TOTALS

Tech.

$70.61/hr.

Clerical

$39.55/hr.

Hours Cost

$

Read/hear PR Notice (guidance) 0.5 0 0.5 35.31

Develop Training & Examination Materials 20 0 20 1,412.20

Review information for accuracy 2 0 2 141.22

Submit training and exam materials to EPA 1 1 2 110.16

Record, store, and file the information 0 0.5 0.5 19.78

TOTAL 23.5 1.5 25 1,718.66

TOTAL ANNUAL BURDEN: 25 hrs. /respondent x 2 respondents = 50 hrs.

TOTAL ANNUAL COST: $1,718.66/respondent x 2 respondents = $3,437.32

 Standard Occupational Codes: 325300

 Management: 11-0000, Management Occupations

 Technical: 19-0000, Life, Physical, and Social Science Occupations

 Clerical: 43-0000, Office and Administrative Support Occupations
January 27, 2015

Page 22 of 26

Table 7. Anthrax-related products: Average Annual Respondent (Registrant) Burden and Cost 

Estimates for Recordkeeping

Collection Activities Annual Burden and Cost Per Respondent

Tech. Hours

$70.61/hr.

Total 

Hours

Cost

$

Read/hear PR Notice (guidance) 0.5 0.5 35.31

Gather and review information 10 10 706.10

Record, store, and file the information 5 5 353.05

Submit information, only if requested 3 3 211.83

TOTAL 18.5 18.5 1,306.29

TOTAL ANNUAL BURDEN: 18.5 hrs. /respondent x 2 respondents = 37 hrs.

TOTAL ANNUAL COST: $1,306.29/respondent x 2 respondents = $2,612.58

Standard Occupational Codes: 325300

 Management: 11-0000, Management Occupations

 Technical: 19-0000, Life, Physical, and Social Science Occupations

 Clerical: 43-0000, Office and Administrative Support Occupations

6(c) Estimating Agency Burden and Cost 

Certification Programs: Based on experience, the Agency has estimated the annual burden to 

the federal government to review the submissions of annual reports and applications for certification. In 

addition, starting in February, 2014, an optional certification training is provided through EPA-affiliated 

employees, currently running once a month. Each training module takes 12 hours to provide. The 

Agency may offer the training quarterly, or as needed, in future years. The Agency’s total annual 

burden associated with the certification of pesticide applicators program is estimated at 2,260.1. The 

total annual cost to the Agency is estimated at $182,021.66. The burden and cost to the Agency 

increased from the estimates in the last ICR renewal due to an increase in the number of 

respondents/responses in Indian Country.

Anthrax-related products: The Agency estimates the annual burden to the Federal government 

to review the registrants’ training material submissions to be 75 hours. The total annual cost to the 

Agency is estimated at $6,013.50. 

Total Agency burden: The Agency estimates the total annual burden to the Federal government 

associated with the certification of pesticide applicators program and anthrax-related products training 

materials to be 2,335.1. The total annual cost to the Agency for these reviews is $188,035.16. 
January 27, 2015

Page 23 of 26

Table 8a. Annual Agency Burden and Cost Estimates - Burden to EPA Regional Offices for 

Indian Country Program and for Processing Annual Reports from Authorized Agencies Prior to 

Submission to Headquarters

Collection Activities Mgmt. hours

$121.44/hr.

Tech. hours

$80.18/hr.

Clerical

hours

$45.18/hr.

Total 

Hours

Cost

$

Prepare Regional Reports - for 

Federal Programs in Indian Country

(including collecting dealer reports)7

0 1040 0 1040 83,387.2

Answer respondent questions 7.1 228 0 235.1 19,143.26

Audit/review submissions 15 638 0 653 52,976.44

Reformat and distribute data 0 50 0 50 4,009.00

Store, file, or maintain the 

information

0 17 3 20 1,498.60

TOTAL 22.1 1,869 3 1998.10 161,014.5

 NAICS 999100 - Federal Executive Branch Standard Occupational Codes:

 Management: 11-0000, Management Occupations

 Technical: 19-0000, Life, Physical, and Social Science Occupations

 Clerical: 43-0000, Office and Administrative Support Occupations

Table 8b. Annual Agency Burden and Cost Estimates - Burden to Headquarters for Review of 

Submitted Annual Reports and Administering Training

Collection Activities Tech. Hours

$80.18/hr. Cost $

Administer/provide private applicator training 12 962.16

Answer respondent questions 116 9,300.88

Audit/review submissions 93 7,456.74

Reformat and distribute data 29 2,325.22

Store, file, or maintain the information 12 962.16

TOTAL 262 21,007.16

 NAICS 999100 - Federal Executive Branch Standard Occupational Codes:

 Management: 11-0000, Management Occupations

 Technical: 19-0000, Life, Physical, and Social Science Occupations

 Clerical: 43-0000, Office and Administrative Support Occupations

 

7 The EPA-administered plan for Navajo Country and for the National Indian Country plans are included in Regions’ reports.
January 27, 2015

Page 24 of 26

Table 8c. Annual Agency Burden and Cost Estimates - Burden to Headquarters for Review of 

Submitted Training and Examination Materials for Anthrax-related Products 

Collection Activities Tech. Hours

$80.18/hr.

Cost

$

Answer respondent questions 3 240.54

Audit/review submissions 60 4,810.80

Reformat and distribute data 6 481.08

Store, file, or maintain the information 6 481.08

TOTAL 75 6,013.50

NAICS 999100 -Federal Executive Branch Standard Occupational Codes:

Management: 11-0000, Management Occupations

 Technical: 19-0000, Life, Physical, and Social Science Occupations

Clerical: 43-0000, Office and Administrative Support Occupations

6(d) Bottom Line Burden Hours and Cost Table

Table 9. Bottom Line Annual Burden and Cost Table

Respondent Total Burden Hours Total Cost ($)

States (Table 1) 4,409 213,156.06

Federal program - certified applicators (Tables 

2 and 3)

Table 2a 470 15,163.16

Table 2b 121 3901.00

Table 3 10,044 323,805.60

State-administered programs - commercial 

applicators (Table 4) 1,305,100 42,074,740.00

RUP dealer burden for recordkeeping of RUP 

sales (Table 5a) 19.50 896.22

RUP dealer burden for reporting informational 

changes (Table 5b) 3.3 153.05

Anthrax-related products - registrants (Tables 

6 and 7)

Table 6 50 3,437.32

Table 7 37 2,612.58

Respondent Total 1,320,254 42,637,864.99

Agency Total Burden Hours Total Cost ($)

EPA Regional Offices (Table 8a) 1,998.1 161,014.5

EPA Headquarters (Table 8b) 2620 21,007.16

EPA Headquarters – review of registrant 

training materials for anthrax-related products 

(Table 8c)

75 6,013.50

Agency Total 4,693.1 188,035.16
January 27, 2015

Page 25 of 26

6(e) Reasons for Change in Burden

The total estimated respondent burden for this renewal ICR reflects a net decrease of 415 hours. 

This decrease reflects EPA's updating of burden estimates, addition of a recently-implemented optional, 

voluntary offering, and a change in the number of entities whose certification programs are directly 

overseen by EPA. The burden changes are the result of both adjustments and program changes.

6(f) Burden Statement

The total annual respondent burden associated with this ICR is estimated to be 1,320,254 hours, 

and the total annual respondent cost associated is $42,637,864.99.

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

resources expended by persons to generate, maintain, retain, disclose, or provide information to or for a 

Federal agency. For this collection, it is the time reading the regulations, planning the necessary data 

collection activities, analyzing data, generating reports and completing other required paperwork, and 

storing, filing, and maintaining the data. The agency may not conduct or sponsor, and a person is not 

required to respond to, a collection of information unless it displays a currently valid OMB control 

number. The OMB control number for this information collection appears at the beginning and end of 

this document. In addition OMB control numbers for EPA’s regulations, after initial display in the final 

rule, are listed in 40 CFR Part 9. 

The Agency has established a public docket for this ICR under Docket ID No. EPA-HQ-OPP2014-0446, which is available for online viewing at www.regulations.gov, or in person 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-2014-0446 and OMB Control 

No. 2070-0029, 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.
January 27, 2015

Page 26 of 26

ATTACHMENTS TO THE SUPPORTING STATEMENT

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

docket identification number EPA-HQ-OPP-2014-0446. These attachments are available for online 

viewing at www.regulations.gov or otherwise accessed as described in section 6(f) of the supporting 

statement, and as noted below.

Attachment A: 7 U.S.C. 136a(d) - FIFRA Section 3(d) - Also available at online at the 

US House of Representatives’ US Code website

Attachment B: 7 U.S.C. 136i - FIFRA Section 11 - Also available at online at the US 

House of Representatives’ US Code website

Attachment C: 40 CFR 171 - Certification of Pesticide Applicators - Also at National 

Archives and Records Administration’s Electronic CFR Website

Attachment D: Pesticide Registration (PR) Notice 2008-2 - “Guidance for Antimicrobial 

Pesticide Products With Anthrax-Related Claims”

Also available at: http://www.epa.gov/PR_Notices/index.htm

Attachment E: Record of Consultations

Attachment F: EPA Form 8500-17-N – Request for Pesticide Applicator Certification in 

Navajo Indian Country and Instructions. Also available at: 

http://www.epa.gov/oppfead1/safety/applicators/2007/8500-17-N-form.pdf

Attachment G: EPA Form 8500-17 – Request for Pesticide Applicator Certification in 

Indian Country and Instructions. Form is available at 

http://www2.epa.gov/sites/production/files/2013-

12/documents/applicator_form.pdf, and instructions at 

http://www2.epa.gov/sites/production/files/2014-

02/documents/application-instructions-certification-indian-country-2_0.pdf

Attachment H: Wage Rate Tables (Commercial Pesticide Applicators, Pesticide 

Registrants, Dealers, State Government, and EPA)

Attachment I: Display Related to OMB Control #2070-0029 – Listings of Related 

Regulations in 40 CFR 9.1