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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 

Soil Fumigant Risk Mitigation

OMB Control No.: 2070-NEW EPA No.: 2451.01

1(b). Short Characterization/Abstract 

This new information collection request (ICR) will ensure that for certain soil fumigant 

chemicals, risk mitigation measures necessary for reregistration eligibility are adequately 

implemented. In May 2008, the Environmental Protection Agency (“EPA” or “the Agency”)

completed Reregistration Eligibility Decisions (REDs) for a group of soil fumigant chemicals 

after an extensive review and public participation process. The Agency’s decision takes into 

account the best available information on the potential risks and benefits of soil fumigant use. 

EPA published the final decision documents for public comment, and issued final REDs in June 

2009. 

The Agency has determined that certain uses of these soil fumigants are eligible for 

reregistration, provided that the risk mitigation measures outlined in the REDs are adopted. The 

required mitigation measures may result in a burden, applicable under the Paperwork Reduction 

Act (PRA), on those participating in soil fumigant applications, on those enforcing soil fumigant 

label requirements, and on the registrants of soil fumigant products. These measures are 

designed to decrease the likelihood of exposures to these chemicals while maintaining important 

benefits to United States (U.S.) agriculture. To ensure that risk mitigation measures are 

adequately implemented, the respondents identified below must complete the following 

activities:

 Users – Users of soil fumigants include both certified applicators and pesticide handlers. 

Applicators must understand the new requirements, complete application information on 

posting signs, provide notice of fumigant applications to applicable states, prepare a 

Fumigant Management Plan (FMP) and Post-Application Summary (PAS), participate in

an EPA-approved fumigant training program, and disseminate fumigant safe handling 

information to handlers. Handlers may help in the posting of buffer zone signs, and must 

also complete a fumigant training program. 

 Registrants – Registrants of soil fumigant products must develop and implement training 

for fumigators in charge of fumigations, develop and disseminate safety information for 

handlers, develop and implement community outreach and education programs, and 

develop and implement first responder training.

 States – States are involved in the enforcement of soil fumigant label requirements, and 

would receive notification of fumigations in their state if they have selected this option.
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Without the complete suite of measures, these chemicals do not meet the requirements to 

be eligible for reregistration under the Federal Insecticide, Fungicide and Rodenticide Act 

(FIFRA). The programs and activities represented in this ICR are the result of the Agency

exercising the authority of section 3(c)(2)(B) or section 3(c)(5) of FIFRA, which authorizes EPA 

to require pesticide registrants to generate and submit data to the Agency, when such data are 

needed to maintain an existing registration of a pesticide. Due to the high benefits to agriculture 

from these chemicals, there could be significant economic impact if soil fumigant products are 

no longer available to American farmers. 

2. NEED FOR AND USE OF THE COLLECTION

2(a). Need/Authority for the Collection

EPA's Office of Pesticide Programs (OPP), under the Office of Chemical Safety and 

Pollution Prevention (OCSPP), will use the information collected under this ICR to ensure that 

risk mitigation measures for certain soil fumigant chemicals necessary for reregistration 

eligibility are adequately implemented. The programs and activities represented in this new ICR 

are the result of the Agency exercising the authority of section 3(c)(2)(B) (Attachment A) or 

section 3(c)(5) (Attachment B) of FIFRA, which authorizes EPA to require pesticide registrants 

to generate and submit data to the Agency when such data are needed to maintain an existing 

registration of a pesticide. 

Sections 3(a) and 12(a)(1) of FIFRA require a person to register a pesticide product with 

the EPA before the pesticide product may be lawfully sold or distributed in the U.S. A pesticide 

registration is a license that allows a pesticide product to be sold and distributed for specific uses 

under specified terms and conditions such as use instructions and precautions. The proponent of 

initial or continued registration always bears the burden of demonstrating that a pesticide product 

meets the statutory standard for registration. A pesticide product may be registered or remain 

registered only if it meets the statutory standard for registration given in section 3(c)(5) of 

FIFRA, which is as follows:

(A) Its composition is such as to warrant the proposed claims for it.

(B) Its labeling and other material required to be submitted comply with the 

requirements of this Act.

(C) It will perform its intended function without unreasonable adverse effects on the

environment.

(D) When used in accordance with widespread and commonly recognized practice it 

will not generally cause unreasonable adverse effects on the environment.

Section 2(bb) of FIFRA defines “unreasonable adverse effects on the environment'' as (1) 

“any unreasonable risk to man or the environment, taking into account the economic, social, and 

environmental costs and benefits of the use of any pesticide, or (2) a human dietary risk from 

residues that result from a use of a pesticide in or on any food inconsistent with the standard 

under section 408 of the Federal Food Drug and Cosmetic Act.''

Section 4 of FIFRA requires EPA to reassess the health and safety data for all pesticide 
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active ingredients registered before November 1, 1984, to determine whether these “older” 

pesticides meet the criteria for registration that would be expected of a pesticide being registered 

today for the first time. Section 4 directs EPA to use section 3(c)(2)(B) authority to obtain the 

required data. Section 4(g)(2)(A) of FIFRA calls for EPA to determine, after submission of 

relevant data concerning an active ingredient, whether pesticides containing the active ingredient 

are eligible for reregistration. 

EPA completed REDs for a group of soil fumigant chemicals in May 2008 after an 

extensive review and public participation process. The Agency’s decision takes into account the 

best available information on the potential risks and benefits of soil fumigant use. EPA 

published the final decision documents for public comment, and issued final REDs in June 2009. 

The chemicals included in this review are metam sodium/potassium, dazomet, chloropicrin, and 

methyl bromide. Preceding the REDs for these chemicals, the Agency had also completed a 

RED for another soil fumigant, 1,3-dichloropropene (Telone ®), in 1998. In addition to these 

chemicals, the soil fumigant dimethyl disulfide (DMDS) was registered in July 2010. 

EPA considered these soil fumigants as a group in order to ensure that similar risk 

assessment tools and methods were used for all and that risk management approaches were 

consistent. Documents to support the reregistration or registration actions for this group of 

chemicals can be found in the public docket at www.regulations.gov under the following docket 

numbers: EPA-HQ-OPP-2005-0123 (methyl bromide), EPA-HQ-OPP-2005-0124 (1,3-

dichloropropene), EPA-HQ-OPP-2005-0125 (metam sodium/potassium), EPA-HQ-OPP-2005-

0128 (dazomet), EPA-HQ-OPP-2007-0350 (chloropicrin), and EPA-HQ-OPP-2007-0092 

(DMDS). Attachment C lists these chemicals and the docket numbers.

The Agency has determined that certain uses of these soil fumigants are eligible for 

reregistration, provided that the same risk mitigation measures outlined in the REDs are adopted. 

EPA is requiring a suite of complementary mitigation measures to protect handlers, reentry

workers, and bystanders from risks resulting from exposure to the soil fumigants. While these 

measures are designed to work together to address all risks, the new mitigation measures have a 

specific focus on the acute human inhalation risks that have been identified in the revised risk 

assessments for these fumigants. This ICR accounts for the additional risk mitigation activities 

outlined in the REDs that are applicable under the PRA, and documents the respondent burden 

and costs for these activities.

In addition, when the new soil fumigant DMDS was registered in 2010, the conditions of 

the registration required products containing this active ingredient to include the same risk 

mitigation measures to those that were required in the REDs for the other chemicals. Similarly, 

these measures are required to ensure handlers, reentry workers, and bystanders who may be 

exposed to soil fumigants are protected. 

Without the complete suite of measures, these chemicals do not meet the eligibility

requirements for reregistration under FIFRA. EPA may determine that products containing these 

chemicals do not meet the 3(c)(5) standard for registration under FIFRA. Due to the high 

benefits to agriculture, there could be significant economic impact if soil fumigant products are 

no longer available. 
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2(b). Practical Utility/Uses of the Data

Background on Soil Fumigants

Soil fumigants are pesticides that, when applied to soil, form a gas to control pests that 

live in the soil and can disrupt plant growth and crop production. The fumigants are either 

volatile chemicals that become gases at relatively low temperatures, around 40 degrees 

Fahrenheit, or they are chemicals that react to produce such a gas (e.g., dazomet and metam 

sodium converting to methyl isothiocyanate, or MITC). Soil fumigants are used on many high 

value crops, including vegetables, fruits, nuts, forest seedlings, ornamentals, and nursery crops, 

to control a wide range of pests including nematodes, fungi, bacteria, insects, and weeds. 

Benefits analyses have indicated that fumigant use is important in a variety of crops. If these 

fumigants could not be used, there would likely be significant negative economic impacts.

Because of the broad range of pests controlled, soil fumigants are used as part of the 

production of a wide variety of crops and provide high benefits for many growers. As gases, 

however, fumigants move from the soil to the air at the application site and may pose risks to 

handlers, re-entry workers, and bystanders. To reduce these exposures and address risks of 

concern, the Agency has required a number of mitigation measures designed to work together to 

address all risks, but focus on the acute human inhalation risks that have been identified in the 

revised risk assessments for these fumigants.

Bystanders, who are not involved in the fumigant application but who live, work, go to 

school, or are otherwise located in nearby areas, may be exposed to airborne fumigants that 

move off the application site. Bystanders also include agricultural workers in nearby fields who 

are not involved with the fumigant application. Incidents of bystander exposure demonstrate that 

fumigants have the potential to move off site at concentrations that produce adverse health 

effects in humans, over periods of several hours to days after application. These health effects 

may range from mild and reversible eye irritation to more severe and irreversible effects, 

depending on the fumigant and the level of exposure.

The Agency is requiring a number of mitigation measures (as described in Section 4 of 

this document) that may result in a burden to those participating in soil fumigant applications, to 

those enforcing soil fumigant label requirements, and to those who register soil fumigant 

products. These measures are designed to decrease the likelihood of exposures to these 

chemicals while maintaining their benefits to U.S. agriculture. For example, measures such as 

FMPs are designed to reduce workplace injuries and accidents by prescribing a series of 

operational requirements and criteria. Also, training is required to ensure applicators across the 

country receive the same basic level of information prior to making an application. Although 

there are some areas of the country where training is currently available from states or 

registrants, there is currently no consistent training standard across states and regions where soil 

fumigation is conducted. For the most part, people living and working near areas where 

fumigation is taking place do not have much knowledge about these types of applications. In 

several incidents, even emergency first responders who have responded to incidents involving 
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soil fumigants do not understand the unique chemical properties of these chemicals and have in 

some cases increased the exposure of bystanders to these chemicals following an incident.1

In general, more information on the soil fumigants, including links to all of the public 

comments received during the reregistration process for this group of chemicals, can be found at 

http://www.epa.gov/pesticides/reregistration/soil_fumigants/index.htm.

3. NON-DUPLICATION, CONSULTATIONS, AND OTHER COLLECTION 

CRITERIA

3(a). Non-duplication

Respondents will not be asked to collect or provide information that has been or is 

currently being collected by EPA, other federal or state agencies or proprietary sources, or is 

available elsewhere. The information collected is unique and is not duplicative of previous 

information collection requests. 

3(b). Public Notice

Pursuant to 5 CFR 1320.8(d), EPA published a Federal Register (FR) Notice (77 FR 

39699, July 5, 2012) announcing this proposed information collection activity and provided a 60-

day public comment period. The Agency established a public docket for this proposal, which 

can be accessed at http://www.regulations.gov using the docket identifier EPA-HQ-OPP-2011-

1036. The Agency did not receive any comments during the public comment period. 

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

In addition to the public notice published in the Federal Register concerning the 

development of this ICR, the Agency has and will continue to consult with stakeholders and 

respondents who actively interact with the Agency. For example, in developing the REDs the 

Agency used a thorough, multi-step, comprehensive process to elicit public comment, provide 

responses, and revise the decisions as appropriate. Starting in 2004, EPA held a series of public 

meetings to discuss the proposed risk assessment methods which the Agency then used to 

develop draft risk assessments. In 2005, EPA incorporated new modeling tools developed by

industry and reviewed by the Scientific Advisory Panel (SAP) into the risk assessments, 

presented the preliminary risk assessments at another public meeting, and opened the first public 

comment period soliciting comments on the Agency’s assessment. In 2007, EPA issued 

responses to public comments on the revised risk and benefits assessments, and issued risk 

mitigation proposals for public comment. EPA then held a series of public meetings around the 

country to get input on the risk mitigation proposals. Then in 2008, EPA published REDs for 

public comment. The REDs showed label statements that would be used to mitigate risks and 

how the new measures would be implemented. In 2009, EPA published amended REDs that 

were revised based on public comments on the 2008 REDs. EPA continues to work closely with 

stakeholders to help ensure new label changes are implemented in a timely manner, and that 

 

1

Summary Fumigants Group Incident Report. R. Allen. 4/17/07. 

http://www.regulations.gov/#!documentDetail;D=EPA-HQ-OPP-2005-0125-0075
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users and enforcement personnel are prepared when these changes take effect. For more 

information, EPA’s fumigant webpage2contains a number of implementation resources as well 

as background information on these decisions.

Before sending this ICR to OMB for review and approval, EPA staff contacted five 

representatives from a cross-section of respondents 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. Based on the comments received during the consultation process, EPA has made 

changes to the original burden estimates in section 6 of this supporting statement. EPA has 

summarized those comments and describes how EPA has changed its original estimates below. 

For representatives’ contact information and their complete responses to the consultation 

questions, please see Attachment D. 

First, in the original supporting statement, EPA did not specify additional capital or 

operation and maintenance costs. Several of the representatives commented that EPA should 

consider the costs associated with creating buffer zone signs. Additionally, several commenters 

also suggested that there are costs associated with purchasing air monitoring equipment that EPA 

did not address. EPA agrees that these are additional costs, and has accounted for them in section 

6(b)(1)(a) of the supporting statement. None of the representatives provided estimates for costs 

associated with these items, so EPA has provided an estimate for each of these based off of 

current market prices for the materials and equipment. 

Second, in the original supporting statement, EPA had indicated that it would take 

approximately 30 minutes to post buffer zone signs (see Table 6). Several commenters suggested 

that this was too short of a time to post signs for buffer zones. These commenters suggested that 

it could take anywhere from 1 to 2 hours to post the necessary signs. EPA has changed its 

estimate from 30 minutes to 1 hour based on these recommendations, accounting for the time it 

takes to both post and remove these signs after the buffer zone time period has expired. 

Third, one commenter stated that EPA did not assign a cost to the distribution of training 

materials listed in Table 10. However, EPA did include the distribution of materials as a 

“clerical task” in all cases, so the time associated with this activity is listed in the “clerical”

column. In reviewing the initial supporting statement and representative comments pertaining to 

this particular, EPA has decided to include 10 hours under the “technical” category for that 

activity in addition to the time accounted for in the “clerical” category. EPA has also changed 

the name of that activity from “Distribute Training Materials” to “Maintain/Distribute Training 

Materials.” EPA felt that in addition the distribution of training materials at the clerical staff 

level, technical staff will also be needed to ensure that the fumigant training materials for 

certified applicators is up to date.

EPA also received two comments regarding EPA’s estimate that it takes 30 minutes to 

read a soil fumigant label (see Table 6). The representatives suggested that it could take 2-3 

hours to read a soil fumigant label. EPA has changed the activity name to “Understanding 

requirements,” but it has not changed the burden estimate. Reading the label is the law for all 

 

2 http://www.epa.gov/pesticides/reregistration/soil_fumigants/index.htm
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pesticide products, but the Agency did want to capture the additional time it may take to 

understand the suite of fumigant risk mitigation measures. These measures are included on 

fumigant product labels, but could also be learned in REDs or on EPA’s fumigant webpage. 

Additionally, 30 minutes is an average for all soil fumigant applications. Certified applicators 

will likely make multiple fumigant applications, oftentimes with the same soil fumigant. The 

initial application will take more time to understand the requirements as suggested by the 

representatives, but EPA believes that subsequent applications will require less time as the 

certified applicator will already be familiar with the requirements. Therefore, EPA has decided 

not to change this estimate. 

For the representatives’ complete responses to the consultation questions, as well as 

EPA’s responses to those comments, please see Attachment D of this supporting statement. 

 

3(d). Effects of Less Frequent Collection

The Agency is not requiring regular reporting on the status of these tasks back to the 

Agency which will significantly reduce the burden on the respondents. Information is reported 

only when needed, and cannot be collected less frequently and still maintain necessary risk 

mitigation. For example, certified applicators must only give FMPs to state enforcement 

officials when requested.

3(e). General Guidelines

The information collection activities discussed in this ICR comply with all regulatory

guidelines under 5 CFR 1320.5(d)(2). Respondents are required to retain records, but 

respondents will not be required to retain records for more than 2 years. 

3(f). Confidentiality

None of the information collected by EPA under this ICR comprises confidential 

business information.

3(g) Sensitive Questions

The information collection activities discussed in this document do not involve any

sensitive questions. 

4. THE RESPONDENTS AND THE INFORMATION REQUESTED

4(a). Respondents/NAICS Codes

Respondents affected by the collection activities under this ICR are soil fumigant users,

specifically certified applicators and agriculture pesticide handlers (NAICS 111000 –

Agriculture, Forestry, Fishing and Hunting); soil fumigant registrants (NAICS 325300 -

Pesticide, Fertilizer, and Other Agricultural Chemical Manufacturing); and state and tribal lead 

agencies (NAICS 999200 – State Government).
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Soil fumigant users subject to the ICR are considered “applicators” and “handlers”. Soil 

fumigants are only allowed to be applied by, or under direct supervision of, specially trained and 

certified applicators. Certification programs are conducted by states, territories, and tribes in 

accordance with national standards. Fumigant handlers are identified as workers working in a 

fumigant application block or buffer zone that performs certain kinds of tasks as specified on 

fumigant labels. 

Users of soil fumigants containing the active ingredients listed in Table 1 are subject to 

the collection activities specified in this ICR.

Table 1: Active Ingredients Subject to this ICR

Active Ingredient Pesticide Chemical (PC) Code

1, 3-dichloropropene 029001

Chloropicrin 081501

Dazomet 035602

DMDS 000011

Metam sodium 039003

Metam potassium 039002

Methyl bromide 053201

Methyl isothiocyanate 068103

4(b). Information Collected

Users of soil fumigants will need to engage in the following activities to assure 

compliance with new fumigant label requirements:

Table 2: User (applicators or handlers) Activities

Burden Description

Understand the 

requirements

(applicator’s 

responsibility)

Learn/refresh understanding of fumigant requirements.

While all of the new requirements are on fumigant labels, EPA has also 

provided information on these requirements at 

http://www.epa.gov/pesticides/reregistration/soil_fumigants/index.htm. 

Specific links to new requirements are included below.

Posting:

Fill-in application 

information on 

signs and post 

buffer zones 

(applicator or 

handler’s 

responsibility)

Obtain signs from product dealers (provided to dealers by registrants); fill 

in (1) product name, and (2) contact information for the fumigator; place 

signs at usual points of entry and along likely routes of approach unless a 

physical barrier (fence, wall) prevents access to the buffer; remove signs 

after buffer zone time period has ended.

Information on buffer zone posting can be found at 

http://www.epa.gov/pesticides/reregistration/soil_fumigants/factsheets/sfmposting-2012.pdf

State Lead 

Agencies (SLAs):

Applicators must check the EPA fumigant website for a list of states that 

require notification.
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Check EPA 

website to 

determine if notice 

is required and 

provide notice of 

applications to 

applicable SLAs

(applicator’s 

responsibility)

Provide to the SLA that require notification, the following: contact 

information for the fumigator and owner/operator; location of the field to 

be treated; product name and registration number; and when the fumigation 

is expected to occur.

Information on notification to SLAs can be found at 

http://www.epa.gov/pesticides/reregistration/soil_fumigants/statenotices/

Fumigant 

Management Plan 

(FMP):

Prepare a FMP and 

a post-application

summary (PAS)

(applicator’s 

responsibility)

Prepare a written FMP for each fumigation to include the following: 

information on the site, fumigator, and owner/operator; fumigation 

procedures; buffer determinations; information on worker protection; 

procedures for air monitoring, posting, communication among key parties; 

and record keeping; emergency response plans and procedures for 

addressing accidental fumigant releases. 

Results of air monitoring for handlers, air monitoring results between 

buffers and bystanders, as well as any deviations from the FMP must be 

recorded in a PAS. 

Both documents must be filed and retained by both the certified applicator 

and the property owner for at least 2 years, and available to disclose to 

enforcement personnel or handlers participating in the application if 

requested. 

Information on FMPs can be found at 

http://www.epa.gov/pesticides/reregistration/soil_fumigants/soil-fummgmt-plans-templates.html

Applicator 

Training:

Applicators must 

take registrant 

developed and 

EPA approved 

fumigant training

(applicator’s 

responsibility)

Applicators must attend a soil fumigant training program designed 

specifically to cover the following topics:

how to correctly apply the fumigant, how to protect handlers and 

bystanders, how to determine buffer zone distances, how to develop an 

FMP and post-fumigation summary report, how to determine when 

unfavorable conditions exist, and how to comply with the required GAPs. 

The applicators participation in the training must be documented in the 

FMP. 

Information on applicator training can be found at

http://www.epa.gov/pesticides/reregistration/soil_fumigants/soil-fumhandlers.html#applicators

Handler 

Information:

Handlers must 

receive fumigant 

Applicators are responsible for disseminating fumigant specific 

information prior to each fumigation to every handler participating in the 

application. 
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specific 

information 

(applicator and 

handler’s 

responsibilities)

Information on handler information can be found at 

http://www.epa.gov/pesticides/reregistration/soil_fumigants/soil-fumhandlers.html#handlers

EPA has included certain aspects of these requirements in the Data Call-In (DCI) notices 

that are being sent to the fumigant registrants. The DCI is requiring registrants to submit 

proposals on how they are planning to address each of the reregistration requirements listed 

below. The registrant’s burden covered in the DCI ICR (OMB Control No. 2070-0174) has not 

been duplicated here. The burden and activities listed below deal with development and 

implementation of requirements and therefore fall outside of the scope of the DCI ICR.

Table 3: Registrant Activities

Burden Description

Training:

Develop/update and 

implement training for 

fumigators in charge of 

fumigations

Prepare training materials, develop channels for training 

fumigators, and design and implement mechanisms for tracking 

fumigators who successfully complete training.

Update training materials periodically.

Disseminate training materials (either electronically, by paper, 

or in person)

As discussed in Table 2, information on applicator training can 

be found at 

http://www.epa.gov/pesticides/reregistration/soil_fumigants/soilfum-handlers.html#applicators

Handler Information:

Develop/update and 

disseminate safety 

information for handlers

Prepare safety training materials for handlers and make them 

available to fumigators to provide to fumigant handlers under 

their supervision.

Update safety information periodically.

Disseminate training materials (either electronically or by paper)

As discussed in table 2, information on handler information can 

be found at 

http://www.epa.gov/pesticides/reregistration/soil_fumigants/soilfum-handlers.html#handlers

Community Outreach:

Develop/update and 

implement community

outreach and education 

programs

Design and implement outreach programs to provide 

communities with information about soil fumigants, buffer 

zones, early signs of exposure, and what to do in case of an 

exposure, emergency, or incident;

Update community outreach program periodically.

Information on community outreach can be found at 

http://www.epa.gov/pesticides/reregistration/soil_fumigants/soilfum-communities.html
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First Responder Training:

Develop/update and 

implement first responder 

training

Identify communities in which fumigants are used which do not 

already have information or training on appropriate response to 

soil fumigant incidents, and develop and incorporate training for 

first responders into existing programs; Update first responder 

training periodically. 

Information on first responder training can be found at 

http://www.epa.gov/pesticides/reregistration/soil_fumigants/soilfum-communities.html

Table 4: State Activities

Burden Description

Notice to States State Lead Agencies (SLAs) have the option to receive notice prior to 

fumigant applications. 

As discussed in table 2, information on notification to SLAs can be 

found at 

http://www.epa.gov/pesticides/reregistration/soil_fumigants/statenotices/

5. THE INFORMATION COLLECTED – AGENCY ACTIVITIES, COLLECTION 

METHODOLOGY, AND INFORMATION MANAGEMENT

5(a). Agency Activities

This ICR primarily involves activities conducted for the purpose of submitting or 

providing information to third parties. EPA, however, does receive and review training and 

safety information materials developed or updated by registrant task forces prior to their 

distribution to third parties. EPA implements the soil fumigant mitigation measures as part of the 

reregistration program.

Table 5: Agency Activities

Burden Description

EPA Review, Coordination, and 

Implementation Responsibilities

EPA has the responsibility to implement the soil fumigant 

mitigation measures, review and approve materials that are 

submitted, and coordinate reviews among experienced 

professionals. 

5(b). Collection Methodology and Management

This ICR primarily involves activities conducted for the purpose of submitting or 

providing information to third parties. For the information that EPA may collect in the future

under this ICR (i.e., training and safety information materials), registrant task forces will submit 

the materials as needed and EPA will track, review and approve any new or updated materials 
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consistent with current Agency processes and procedures for the submission of pesticide 

information to the Agency.

5(c). Small Entity Flexibility

The reregistration eligibility of the soil fumigants depend upon applicators receiving the 

various information and training required in the soil fumigant labels. These cannot be reduced 

for small establishments without seriously compromising the protections offered to applicators 

and bystanders. As such, small entities are required to follow the same requirements as larger 

establishments. 

5(d). Collection Schedule

This ICR primarily involves activities conducted for the purpose of submitting or 

providing information to third parties. For registrant task forces who must submit training and 

safety information materials to the Agency for review, there is no set collection schedule as 

registrant task forces submit materials only when developed or updated. EPA periodically

checks the fumigant risk mitigation measures as a part of the registration review program.

6. ESTIMATING THE BURDEN AND COST OF THE COLLECTION

6(a). Estimating Respondent Burden

The burden associated with this collection of information is described in detail in the 

following sections. The respondents include certified applicators, pesticide handlers, fumigant 

registrants and states. To estimate the respondent burden, the Agency used current information 

and statistics on the number of fumigant applications made annually, the number of certified 

applicators and pesticide handlers that apply or handle soil fumigants, and the number of 

fumigant registrants. 

Certified applicators and pesticide handlers have paperwork burden associated with 

fumigant application activities, such as understanding the requirements, posting treatment areas 

and developing a FMP. It is estimated that the burden associated with the first application will 

be highest, mostly due to the time necessary to develop the FMP (12 hours). Each of the other 

paperwork related activities is estimated to take no more than an hour. Total burden for the first 

application is estimated to be nearly 15 hours, while each subsequent application is estimated to 

take less than 4 hours. The Agency estimates that more than 12,000 soil fumigant applications 

are made in the U.S. each year. 

Requirements currently exist to ensure that certified applicators and agricultural handlers 

possess general pesticide use and safety information. Applicators must be determined to be 

competent to become certified, and to maintain their certification they must either receive 

training or be recertified by exam on a schedule determined by the state (Certification of 

Pesticide Applicators, 40 CFR 171). That schedule ranges, depending on the state, from 1 to 5 

years. Under the agricultural Worker Protection Standard (40 CFR 170), agricultural handlers 

are required to receive general pesticide safety training at least once every 5 years. Burdens 
March 25, 2013

Page 13 of 25

from those requirements are included in currently-approved ICRs for those two rules

(Certification of Pesticide Applicators (OMB Control No. 2070-0029) and Worker Protection 

Standard Training and Notification (OMB Control No. 2070-0148)), and are not included here.

The soil fumigant label revisions establish training requirements specific to soil 

fumigation for certified applicators and handlers on the safe and appropriate use of these 

products. Soil fumigant applicators are required to receive this fumigant-specific training every 3 

years; handlers involved in soil fumigant application must be provided with the specific safe 

handling information annually. Burdens from these fumigant-specific requirements are included 

in this ICR and are separate and distinct from the requirements cited above under the 

Certification of Pesticide Applicators ICR (OMB Control No. 2070-0029) and the agricultural 

Worker Protection Standard ICR (OMB Control No. 2070-0148). There are an estimated 4,458 

certified applicators applying soil fumigants and 13,374 pesticide handlers of soil fumigants 

subject to these training requirements.

Registrant burden is associated with the development and dissemination of fumigant 

application, handler safety and first responder training materials. They must also develop and 

implement a community outreach program. The majority of the burden associated with these 

activities is in the one-time development of the materials. An estimated 320 hours will be spent 

by each registrant developing the fumigant training materials; 120 hours will be spent developing 

the handler safety materials; and 240 hours will be spent developing the first responder training 

and developing the community outreach program. The annual dissemination of fumigant 

training and handler safety materials is estimated to take 22 hours per registrant for each activity, 

while the implementation of the community outreach program is estimated to take 120 hours per 

registrant annually, and the dissemination of first responder training is estimated to take 120 

hours per registrant annually. There are six task forces that will be developing and disseminating 

the required materials.

States are responsible for enforcement and compliance of the fumigant applicationrelated requirements. It is estimated that states will spend an average of 15 minutes per 

application on enforcement and compliance activities. Given the more than 12,000 fumigant 

applications made per year, state activities amount to more than 3,000 hours per year.

The detailed burden estimates and calculations are presented below for each respondent 

group, along with costs. The burden for certified applicators and pesticide handlers is shown in 

Tables 6, 7, 8, and 9; burden for registrants of soil fumigant products in Tables 10 and 11; and 

burden for states in Tables 12 and 13.

6(b). Methodology for Estimating Respondent Cost

Respondent cost is based on the burden as described above and summarized below, and 

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

and EPA employees. This approach uses a transparent and consistent methodology and current 

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

estimates of wages, benefits and overhead.
March 25, 2013

Page 14 of 25

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). Costs are indexed to 

2010 dollars. 

Wage Rates: Wages are estimated for occupations (management, technical, and clerical) 

within applicable sectors. The Agency uses average unloaded 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. For loaded 

wage rates, benefits represent 44% of unloaded wage rates, based on benefits for all civilian nonfarm workers, from http://www.bls.gov/news.release/ecec.t01.htm. Fully loaded wage rates 

include an additional 50% on top of the loaded wage rate to capture overhead costs (EPA 

guidelines 20-70%). The data and calculations for wage rates used in this document are 

presented in Attachment E.

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 ). 

There are three categories of respondents: certified applicators and handlers, registrants 

and states. The cost associated with each is described in this section.

(1) Certified Applicators and Pesticide Handlers 

The estimated costs of paperwork activities for certified applicators and pesticide 

handlers are shown in Tables 6, 7, 8, and 9, along with burden. Tables 6 and 7 list the estimated 

costs associated with paperwork for user application activities, while Tables 8 and 9 list the costs 

associated with training activities. Wage rates are based on NAICS code 111000 - Agriculture, 

Fishing, Forestry and Hunting. They are loaded to account for some benefits paid by the 

employer, but do not account for overhead. The loaded wage rate for certified applicators

($33.24) is based on the scientist/technician labor category, while the pesticide handler wage is 

based on an average of the loaded wage rate for the scientist/technician and agriculture worker 

labor categories (($33.24+$13.40)/2 = $23.32), reflecting a higher skilled worker (see 

Attachment E).

(1a) User Application Activities

Table 6 summarizes the burden and cost for paperwork activities per soil fumigant 

application for certified applicators and pesticide handlers. Table 7 summarizes the burden and 

cost per year. The annual burden and cost is based on the number of applications made per year. 

EPA estimates that more than 12,000 applications are made per year by certified applicators and 

pesticide handlers based on historical pesticide usage data for the soil fumigants. 

In addition to the hourly burden and cost of compliance with the application 

requirements, applicators are required to purchase signs for the posting requirement and tubes 
March 25, 2013

Page 15 of 25

and pumps for the air monitoring requirement. The sign cost is $0.09 per sheet3and assuming 4 

sheets per application (posting at 2 points of entry to the treated field and 2 postings along routes 

of approach to the treated field on average), the cost per application is $0.36. The total annual 

material cost for posting, assuming 12,651 applications per year, is $4,554. With 37,953 

applications over 3 years, the total estimated 3 year cost is $13,663. 

Monitoring devices must be used during methyl bromide applications and if sensory

irritation occurs while applying other fumigants. Each application requires a pump to be on-site, 

and a new tube is necessary for every measurement. The cost of a Draeger tube for monitoring 

the air at an application site is $16 on average4and the cost of a Draeger pump is $4055. 

Assuming one tube per application, the total annual cost of the tubes is $202,416 ($16 per tube 

per application multiplied by 12,651 applications). Over 3 years, the total cost of the tubes is 

$607,248. Assuming each certified applicator (there are an estimated 4,458 certified applicators) 

purchases one new pump every 3 years, the total 3 year cost for the pumps is $1,805,490, for an 

average of $601,830 per year. Burden for this measurement is included in the FMP estimates 

since the labels require measurements to be recorded in the PAS.

The material cost of compliance is equal to the cost of purchasing the signs for posting 

plus the cost of the tubes and pumps for air monitoring. The total 3 year cost is $2,426,401, for 

an average annual cost of $808,800.

 

3 Source: Staples, 2008

4 Draeger tubes are sold in packages of 10 for as much as $160 per package. Source: AFC International, Inc., 2012.

5 Source: AFC International, Inc., 2012.
March 25, 2013

Page 16 of 25

Table 6. Certified Applicator and Pesticide Handler Burden and Cost for User Application 

Activities per Application, By Activity

Category Activity Frequency Certified 

Applicator

Hours

Cost

(@$33.24/hr)1

Pesticide 

Handler

Hours

Cost

(@$23.32/hr)

1

Total

Hours

Cost2

Understanding 

requirements

Learn/refresh 

understanding of 

fumigant 

requirements

Annual 0.50

$16.62

0

$0

0.50

$16.62

Posting Fill in 

Information

Per 

Application

0.13

$4.32

0

$0

0.13

$4.32

Post/Remove 

Signs

Per 

Application

0

$0

1.0

$23.32

1.0

$23.32

Notice to SLA Prepare 

information in 

Notice

Per 

Application

0.17

$5.65

0

$0

0.17

$5.65

Send Notice Per 

Application

0.05

$1.66

0

$0

0.05

$1.66

Fumigant 

Management

Plan

Prepare Initial 

Plan

Per Initial 

Application

12.00

$398.88

0

$0

12.00

$398.88

Prepare 

Subsequent Plan

Per 

Subsequent

Application

1.00

$33.24

0

$0

1.00

$33.24

Create Post 

Fumigation 

Report

Per 

Application

1.00

$33.24

0

$0

1.00

$33.24

File and Disclose 

Plan

Per 

Application

0.05

$1.66

0

$0

0.05

$1.66

Total Burden and Cost Per Initial and Subsequent Application3

Initial 

Application

13.90

$462.04

1.0

$23.32

14.90

$485.36

Subsequent 

Application

2.90

$96.40

1.0

$23.32

3.90

$119.72

Numbers may not add due to rounding.

1 - Cost is equal to the hours times the wage rate ($/hr).

2 - Total hours and cost are the sum of certified applicator and pesticide handler hours and cost. 

3 – Initial Application is equal to the sum of each activity less prepare subsequent plan. Subsequent application 

hours and cost is equal to the sum of each activity less prepare initial application.
March 25, 2013

Page 17 of 25

Table 7. Total Annual Certified Applicator and Pesticide Handler Burden and Cost for 

User Application Activities

Year Certified Applicator

Hours

Cost1

Pesticide Handler

Hours

Cost1

Total

Hours

Cost2

Year 1 175,849

$5,845,217

12,651

$295,021

188,500

$6,140,239

Year 2 175,849

$5,845,217

12,651

$295,021

188,500

$6,140,239

Year 3 106,268

$3,532,362

12,651

$295,021

118,919

$3,827,383

3 Year Annual 

Average

152,655

$5,074,265

12,651

$295,021

165,306

$5,369,287

3 Year Total 457,966

$15,222,796

37,953

$885,064

495,919

$16,107,860

Numbers may not add due to rounding.

1 - Cost is equal to the total hours and cost for the initial and subsequent application as listed in rows 11 and 12 of 

Table 6 multiplied times the number of applications. EPA assumes that fumigations occur once every two years, 

and that 100% of fumigations in year 1 and 2 are first time fumigation, and 50% of fumigations are first time 

fumigations starting in year 3. The estimated number of applications per year is as follows: 

Initial Applications Subsequent Applications

Year 1 12,651 0

Year 2 12,651 0

Year 3 6,326 6,326

3 Year Average 10,543 2,109

3 Year Total 31,628 6,326

For Example: For certified applicators in Year 3 the hours are equal to following:

Certified applicator: (13.90 hours/application x 6,326 applications) + (2.90 hours/application x 6,326 applications)

2 - Total hours and cost are the sum of certified applicator and pesticide handler hours and cost. 

(1b) Training Activities

Table 8 summarizes the burden and cost for certified applicators and pesticide handlers 

for training activities per trainee, while Table 9 summarizes the burden and cost per year of 

training activities. The annual burden and cost is based on the number of certified applicators 

and pesticide handlers involved with soil fumigant applications. EPA estimates that there are 

4,458 applicable certified applicators and 13,374 handlers. This is based on data submitted to 

EPA on the number of certified applicators and the assumption of three pesticide handlers per 

certified applicator. 

 
March 25, 2013

Page 18 of 25

Table 8. Certified Applicator and Pesticide Handler Burden and Cost for Training 

Activities per Applicator, By Activity

Category Activity Frequency Certified 

Applicator

Hours and

Cost

(@$33.24/hr)1

Pesticide 

Handler

Hours and

Cost

(@$23.32/hr)1

Total

Hours and

Cost2

Applicator 

Fumigant 

Training

Mandatory

Training

Once Every

3 Years

8.00

$265.92

0

$0

8.00

$265.92

Retain Training 

Documentation

Once Every

3 Years

0.05

$1.66

0

$0

0.05

$1.66

Handler 

Safety

Information

Fumigant 

Specific Safety 

Information 

Annual30.08

$2.66

1.00

$23.32

1.08

$25.98

Numbers may not add due to rounding.

1 - Cost is equal to the hours times the wage rate ($/hr).

2 - Total hours and cost are the sum of certified applicator and pesticide handler hours and cost.

3 – Information is disseminated to pesticide handlers on a per application basis. Estimates presented here are the 

total estimated annual burden of all applications conducted by a certified applicator or pesticide handler in a given 

year.

Table 9. Total Annual Certified Applicator and Pesticide Handler Burden and Cost for 

Training Activities

Year Certified Applicator

Hours and Cost1

Pesticide Handler

Hours and Cost1

Total

Hours and Cost2

Year 1 36,244

$1,204,735

13,374

$311,882

49,618

$1,516,617

Year 2 357

$11,855

13,374

$311,882

13,731

$323,736

Year 3 357

$11,855

13,374

$311,882

13,731

$323,736

3 Year Annual Average 12,319

$409,482

13,374

$311,882

25,693

$721,363

3 Year Total 36,957

$1,228,445

40,122

$935,645

77,079

$2,164,090

Numbers may not add due to rounding.

1 - Cost is equal to the total hours and costs as listed Table 8 times the number of certified applicators and pesticide 

handlers that apply or handle soil fumigants. EPA estimates an applicable 4,458 certified applicators and 13,374 

pesticide handlers. 

For Example: For certified applicators in Year 1 the hours are equal to following:

Certified applicator: (8.00 hours/applicator + 0.05 hours/applicators + 0.08 hours/applicator) x (4,458 applicators)

2 - Total hours and cost are the sum of certified applicator and pesticide handler hours and cost. 

(2) Registrants of Soil Fumigant Products

The estimated paperwork costs for soil fumigant registrants are shown in Tables 10 and 

11. Wage rates are for NAICS 325300 - Pesticide, Fertilizer, and Other Agricultural Chemical 

Manufacturing and are fully loaded to account for benefits and overhead. EPA estimates that 
March 25, 2013

Page 19 of 25

there are 6 registrant task forces that will develop and distribute the required materials based on 

correspondence with these task forces. Table 10 shows the estimates of burden and cost per 

registrant task force to develop and distribute training materials; prepare and distribute safety 

information; design and implement community outreach; and develop and distribute first 

responder training materials. Table 11 shows the annual cost across all registrants of the 

activities taking into account the frequency of the activity.

Table 10. Soil Fumigant Registrant Burden and Cost, By Activity

Category Activities Frequency Management

Hours and

Cost

(@$120.28/

hr)1

Technical

Hours 

and

Cost

(@$60.85/

hr)1

Clerical

Hours 

and

Cost

(@$37.11/

hr)1

Total

Hours 

and

Cost2

Fumigant

Training

Develop/Update

Training

Materials

One Time 80.00

$9,622.40

160.00

$9,736.00

80.00

$2,968.80

320.00

$22,327

Maintain / 

Distribute

Training

Materials

Annually 0

$0

10

$608.50

12.00

$445.32

22.00

$1,054

Handler 

Safety

Information

Prepare/Update

Information

One Time 40.00

$4,811.20

40.00

$2,434.00

40.00

$1,484.40

120.00

$8,730

Distribute 

Training

Materials

Annually 0

$0

0

$0

12.00

$445.32

12.00

$445

Community

Outreach

Program

Design/Update

Program

One Time 80.00

$9,622.40

80.00

$4,868.00

80.00

$2,968.80

240.00

$17,459

Implement

Program in

High Use 

Areas

Annually 40.00

$4,811.20

40.00

$2,434.00

40.00

$1,484.40

120.00

$8,730

First 

Responder

Training

Develop/Update 

Training 

Materials

One Time 80.00

$9,622.40

80.00

$4,868.00

80.00

$2,968.80

240.00

$17,459

Distribute

Material in

High Use 

Areas

Annually 0

$0

0

$0

120.00

$4,453.20

120.00

$4,453

Numbers may not add due to rounding.

1 - Cost is equal to the hours times the wage rate ($/hr).

2 - Total hours and cost are the sum of managerial, technical and clerical hours and cost. 
March 25, 2013

Page 20 of 25

Table 11. Total Annual Registrant Burden and Cost 

Year Managerial

Hours and Cost1

Technical

Hours and Cost1

Clerical

Hours and Cost1

Total

Hours and Cost2

Year 1 1,920

$230,938

2,460

$149,691

2,784

$103,314

7,164

$483,943

Year 2 240

$28,867

300

$18,255

1,104

$40,969

1,644

$88,092

Year 3 240

$28,867

300

$18,255

1,104

$40,969

1,644

$88,092

3 Year Annual 

Average

800

$96,224

1,020

$62,067

1,664

$61,751

3,484

$220,042

3 Year Total 2,400

$288,672

3,060

$186,201,201

4,992

$185,253

10,452

$660,126

Numbers may not add due to rounding.

1 - Cost is equal to the total hours and cost in Table 10 multiplied times the estimated number of registrant task 

forces (6). For Example: The Year 1 number of managerial hours is equal to the hours per registrant for each of the 

activities times 6: (80 hours/registrant+0 hours/registrant+40 hours/registrant+0 hours/registrant+80 

hours/registrant+40 hours/registrant+80 hours/registrant+0 hours/registrant) x (6 registrants)

2 - Total hours and cost are the sum of managerial, technical and clerical hours and cost. 

(3) States

The burden for states per application for compliance and enforcement activities is shown 

in Table 12. Wage rates are for NAICS 999200 – State Government and are fully loaded to 

account for benefits and overhead. EPA’s requirements are for only those states with high 

fumigant use, and currently, EPA estimates that there are 15 states that account for the majority

of fumigant use and are considered high use: California, Washington, Idaho, Oregon, Wisconsin, 

Michigan, Florida, Minnesota, North Carolina, Virginia, Arizona, Nevada, Georgia, Colorado, 

and North Dakota. This is based on an EPA analysis of fumigant pesticide usage and U.S. crop 

acreage grown which showed that a majority of soil fumigant usage occurred in 15 states.6 

Costs are measured on a per application basis. Annual burden, assuming more than 12,000 

fumigant applications per year, is shown in Table 13. The Agency estimates that all of the

paperwork burden for responding to this ICR will be conducted by clerical (or administrative) 

staff.

 

6 The EPA document can be found at http://www.regulations.gov/#!documentDetail;D=EPA-HQ-OPP-2005-0125-

0516.
March 25, 2013

Page 21 of 25

Table 12. State Burden and Cost per Application

Category Activities Frequency Clerical

Hours and 

Cost

(@$39.20/hr)1

Total

Hours and 

Cost2

State Compliance 

and Enforcement

Paperwork for 

Compliance and 

Enforcement 

Annually 0.25

$9.80

0.25

$9.80

Numbers may not add due to rounding. State management and technical staff are not estimated to be impacted by 

this ICR.

1 - Cost is equal to the hours times the wage rate ($/hr).

2 - Total hours and cost are the sum of managerial, technical and clerical hours and cost. Since only clerical staff is 

impacted, the total hours and cost are equal to the clerical hours and cost.

Table 13. Total Annual State Burden and Cost

Year Clerical

Hours and Cost1

Total

Hours and Cost2

Year 1 3,163

$123,980

3,163

$123,980

Year 2 3,163

$123,980

3,163

$123,980

Year 3 3,163

$123,980

3,163

$123,980

3 Year Annual Average 3,163

$123,980

3,163

$123,980

3 Year Total 9,488

$371,939

9,488

$371,939

Numbers may not add due to rounding. State management and technical staff are not estimated to be impacted by 

this ICR.

1 - Cost is equal to the total hours and cost per application as listed in Table 7 multiplied times the number of 

applications. EPA assumes that fumigations occur once every two years, and that 100% of fumigations in year 1 

and 2 are first time fumigation, and 50% of fumigations are first time fumigations starting in year 3. The estimated 

number of applications per year as follows: 

Initial Applications Subsequent Applications

Year 1 12,651 0

Year 2 12,651 0

Year 3 6,326 6,326

3 Year Average 10,543 2,109

3 Year Total 31,628 6,326

For Example: For states in Year 1, the hours are equal to the following: (0.25 hours/application x 12,651

applications)

2 - Total hours and cost are the sum of managerial, technical and clerical hours and cost. Since only clerical staff is 

impacted, the total hours and cost are equal to the clerical hours and cost.

6(c). Estimating Agency Burden and Cost

Agency burden is shown in Tables 14 and 15. To determine Agency costs, the Agency

used the Bureau of Labor Statistics estimates of labor rates for the North American Industry

Classification System code for the Federal Executive Branch (NAICS 999100). Wage rates are 
March 25, 2013

Page 22 of 25

fully loaded to account for benefits and overhead. Table 14 shows the burden and cost per 

activity for the Agency, while Table 15 is the annual burden and cost across all activities. 

Agency costs are based on managerial and technical hours spent on compliance and enforcement 

activities.

Table 14. Agency Burden and Cost

Category Activities Frequency Management

Hours and Cost

(@$119.85/hr)1

Technical

Hours and Cost

(@$71.58/hr)1

Total

Hours and 

Cost2

Federal 

Compliance 

and 

Enforcement

Review 

Registrant 

Training 

Materials

One Time 80.00

$9,588.00

1,092.00

$78,165.36

1,172

$87,753

Develop User 

Tools and 

Templates

One Time 40.00

$4,794.00

1,092.00

$78,165.36

1,132

$82,959

Review 

Labels and 

Materials

One Time 40.00

$4,794.00

2,184.00

$156,330.72

2,224

$161,125

Compliance

Training and 

Stakeholder

Engagement

Annually 104.00

$12,464.40

1,092.00

$78,165.36

1,196

$90,630

Numbers may not add due to rounding. Agency clerical staff are not impacted by this ICR.

1 - Cost is equal to the hours times the wage rate ($/hr).

2 - Total hours and cost are the sum of managerial, technical hours and cost. 

Table 15. Total Annual Agency Burden and Cost 

Year Managerial

Hours/Cost1

Technical

Hours/Cost1

Total

Hours/Cost2

Year 1 264

$31,640

5,460

$390,827

5,724

$422,467

Year 2 104

$12,464

1,092

$78,165

1,196

$90,630

Year 3 104

$12,464

1,092

$78,165

1,196

$90,630

3 Year Annual 

Average

157

$18,856

2,548

$182,386

2,705

$201,242

3 Year Total 472

$56,569

7,644

$547,158

8,116

$603,727

Numbers may not add due to rounding.

1 - Cost is equal to the total hours and cost across activities based on frequency from Table 14. For example: The 

Year 1 number of managerial hours is equal to the sum of the hours for each activity: 80 hours + 40 hours + 40 

hours + 104 hours. Years 2 and 3 only include the activities incurred annually (104 hours).

2 - Total hours and cost are the sum of managerial and technical hours and cost. 
March 25, 2013

Page 23 of 25

6(d). Bottom Line Burden Hours and Cost

Tables 16 and 17 summarize the total annual respondent and Agency burden,

respectively. Including the cost to applicators for the materials required for compliance with the 

posting and air monitoring requirements ($2,426,401), the total 3 year respondent cost is 

$21,730,417.

Table 16. Annual Respondent Burden and Cost

Information Collection Respondent No. of 

Responses

Burden 

Hours

Costs

Fumigant User 

Application Activities 

(Table 7)

Certified 

Applicators

12,651 152,655 $5,883,0651

Pesticide Handlers 12,651 12,651 $295,021

Fumigant Training 

Activities (Table 9)

Certified 

Applicators

4,458 12,319 $409,482

Pesticide Handlers 13,374 13,374 $311,882

Development and 

Distribution of Training & 

Informational Materials 

(Table 11)

Registrants 6 3,484 $220,042

Paperwork for Compliance 

and Enforcement in High 

Use States 

(Table 13)

State Agencies 12,651 3,163 $123,980

Total Annual Average 55,791 197,646 $7,243,472

1- Costs for certified applicators include the capital costs of $808,800 for purchasing buffer zone 

signs and air monitoring equipment (pumps and tubes). See section 6(b)(1a) and Table 7. 

Table 17. Annual Agency Burden and Cost

Year Total Hours1 Total Cost1

Year 1 5,724 $422,467

Year 2 1,196 $90,630

Year 3 1,196 $90,630

3 Year Annual Average 2,705 $201,242

3 Year Total 8,116 $603,727

1 – Total hours and cost are a sum of total hours and cost for the Agency. See Table 15.

6(e). Reasons for Change in Burden

This is a new ICR.

6(f). Burden Statement

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

collection activity is 197,646 hours. This estimate includes the time needed for certified 
March 25, 2013

Page 24 of 25

applicators (164,974 hours), pesticide handlers (26,025 hours), registrants (3,484 hours), and 

states (3,163 hours) to conduct fumigant application related paperwork activities (see section

6(b) and 6 (d)). For certified applicators, the burden for this collection is estimated to be 2.9 to 

13.9 hours per soil fumigant application, and 0.08 to 8.13 hours per certified applicator per year

for training. For pesticide handlers, the burden for this collection is estimated to average 1 hour 

per soil fumigant application, and 1 hour per pesticide handler per year for safety training. The 

burden for registrant task forces to develop, distribute, and implement fumigant training and 

informational materials is estimated to be 274 to 1,194 hours per task force per year. For states, 

the burden for this collection is estimated to average 0.25 hours per application.

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

collection of information unless it displays a currently valid OMB control number. The OMB 

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

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

if applicable.

To comment on 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, EPA has established a public docket for this ICR under 

docket ID No. EPA-HQ-OPP-2011-1036, which is available for public viewing at the OPP 

Docket in the EPA Docket Center, EPA West, Rm. 3334, 1200 Pennsylvania Ave, NW, 

Washington, DC 20460-0001. This docket facility is open from 8:30 a.m. to 4:30 p.m., Monday

through Friday, excluding legal holidays. The OPP Docket telephone number is (703) 305-5805. 

An electronic version of the public docket is available through Federal eRulemaking Portal, 

http://www.regulations.gov. Follow the online instructions for viewing documents and 

submitting comments. You can also send comments to the Office of Information and Regulatory

Affairs, Office of Management and Budget, 725 17th Street, NW, Washington, DC 20503, 

Attention: Desk Office for EPA. Please include the docket ID No. EPA-HQ-OPP-2011-1036 

and OMB control number 2070-NEW in any correspondence.
March 25, 2013

Page 25 of 25

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-2011-1036. These attachments are 

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

section 6(f) of the supporting statement.

Attachment A: 7 U.S.C. 136a - FIFRA section 3(c)(2)(B). This is also available online at 

the House of Representatives’ US Code Website

Attachment B: 7 U.S.C. 136a - FIFRA Section 3(c)(5). This is also available online at the 

House of Representatives’ US Code Website

Attachment C: Docket Numbers for Fumigant Reregistration Eligibility Decisions and 

Supporting Documents

Attachment D: Record of Consultations Between the U.S. Environmental Protection 

Agency and Respondents to the Information Collection Request: “Soil 

Fumigant Risk Mitigation”

Attachment E: Worksheet for Estimating OPP ICR Wage Rates for Industry, State and 

EPA Labor Costs