A ttachment D : Record of Consultations

This attachment is available as part of the electronic docket EPA

- HQ

- OPP

- 2013

- 0494 and is part

of the ICR’s Supporting Statement

.

List of individuals/companies contacted.

1. Name: Jamie Staley

Title: Registration Manager

Co: Pioneer Hi

- Bred International, Inc.

Phone: 515

- 535

- 6946

E

- mail: Jamie

. staley@pioneer.com

Comment : No comment provided

2. Name: Dan Jenkins

Title: U.S. Agency Regulatory Affairs Lead

Co: Monsanto Company

Phone: 202

- 383

- 2851

E

- mail: D aniel.j.jenkins@monsanto.com

Comment : No comment provided

3. Name: Nicholas Storer, Ph.D.

Tiltle : Global Leader, Scientific & US Regulatory Affairs

Co: Dow AgroSciences LLC

Ph one: 301 946 1721

E

- mail: nstorer@dow.com

Comment: See a ttached1 Consultation Questionnaire for OPP ICR :

Plant

- Incorporated Protectants; CBI Substantiation and Adverse Effects Reporting

OMB Control # 2070

- 0 142 )

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

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

respondents and the responses received, written comments, verbal responses or e

- mail, etc.

will become a part of the electronic public comment docket for this ICR renewal.

(1) Pu blicly Available Data

$ Is the data that the Agency seeks available from any public source, or already

collected by another office at EPA or by another agency?

Not to our knowledge

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

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

that they don ’ t meet our data needs very well?)

(2) Frequency of Collection

$ Is the submission of CBI Substantiation Claims or Adverse Effects Reports too

frequent ?

Submission is required only as situations arise and is therefore not too frequent

(3) Clarity of Instr uctions

$ The ICR is intended to require that respondents provide certain data so that the

Agency can utilize them.

$ Based on the instructions (regulations, PR Notices, etc.), is it clear what you are

required to do and how to submit such data? If not, what suggestions do you have

to clarify the instructions?

Requirements are clear

$ Do you understand that you are required to maintain records?

Yes

(4) Electronic Reporting and Record keeping

The Government Paperwork Elimination Act requires agencies make available to the

pub lic electronic reporting alternatives to paper

- based submissions by 2003, unless there

is a strong reason for not doing so. One such reason is that, at the present time, the

Agency is unable to ensure the security of CBI that might be transmitted over the

Internet.

$ What do you think about electronic alternatives to paper

- based records and data

submissions? Would you be interested in pursuing electronic reporting?2

Electronic submission, if secure and CBI maintained, using a simple and flexible format,

and a simple process, would b e acceptable.

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

Yes

Although the Agen cy does not offer an electronic reporting option because of CBI

- related

security concerns at this time,

$ W hat benefits would electronic submission bring you in terms of burden

reduction or greater efficiency in compiling the information?

Reduced duplication of work , decreased administration associated with physical

documents

(5) Burden an d Costs

The following questions refer to Tables 1 and 2 in Section 6 of the ICR (see the Section 6

excerpt that is attached). Tables 1 and 2 provide EPA’s estimate of the averag e

respondent burden and cost estimates for Substantiation of CBI Claims and Adverse

Effects Reporting , respectively

. $ The Agency assumes there is no capital cost associated with this activity. Is that

correct? Correct

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

costs as sociated with the paperwork involved with this ICR, e.g., the ICR does not

include estimated burden hours and costs for conducting studies, are the estimated

burden hours and labor rates accurate? If you provide burden and cost estimates

that are substanti ally different from EPA ’ s, please provide an explanation of how

you arrived at your estimates. Burden and costs of rep orting are minimal fiven

the documentation requirements

$ Are there other costs that should be accounted for that may have been missed?

No

.