November 17, 2009 

Questions for Small Entity Representatives 

Small Business Advocacy Review Panel on 

Insect Repellents: Reconsideration of Exemption; 

Revising the Minimum Risk Pesticide Exemption to Remove 

Skin-Applied Insect Repellents 

For each of the approaches under discussion, please let us know of any alternate solutions 

that provide flexibility or decrease economic impact for small entities while still 

accomplishing the stated goal. 

In your written comments after our discussion, please also consider including answers to 

the questions below. Your feedback to this Panel is not limited to the questions in this 

document. 

 

Tips for most effective comments: 

• We are interested in as much information as you can provide. Providing examples 

or reasons for why you think an approach won’t work is more helpful than just 

stating that it is a bad idea. 

• Be specific on why an approach would be difficult or burdensome for you. 

• Suggest detailed alternatives you think would meet the criteria. 

• Your detailed input on cost can help us choose the most cost-effective options. 

Questions: Costs and regulations

1. How much would each approach we described cost you? Please break down 

any cost estimates into: 

• Monetary estimates 

• Time (including whose time, e.g. clerical, technical, managerial, 

owner) 

• Materials 

2. Do you have suggestions for how these approaches could be modified to be 

more workable for your company? Do you have suggestions for entirely 

alternate approaches? 

• In what ways would these modifications or alternatives help? (Lower 

cost, less complicated process, etc) 

• Please estimate the costs of any modifications or alternative 

approaches. 

3. Do you have information we should consider regarding non-regulatory 

approaches? 

4. Please describe how you currently test your skin-applied insect repellent 

products. 

• Toxicity 

• Efficacy 

• What are the costs associated with those tests? 

1
November 17, 2009 

5. Letting required changes to labels take place over a long period of time can 

sometimes reduce the cost of those changes. 

• If the labels for your product(s) were required to change, what 

timeframe for implementing this would have the lowest cost? 

• What would that cost be? 

• If that timeframe was shortened, how much would the cost to your 

company increase? 

Questions: Insect repellents and other pesticides 

6. Do you produce or sell other minimum-risk pesticides (such as products for 

use in lawns, gardens, or homes, products for use on pets/animals, etc)? 

7. Do you produce or sell: 

• Any pesticides registered with EPA? 

• Any skin-applied insect repellents registered with EPA? 

• If not currently, have you in the past registered pesticides with EPA? 

8. Regarding minimum-risk, skin-applied insect repellents, what does your 

company do? 

• Manufacture 

• Repackage 

• Distribute 

• Market 

• Wholesale 

• Retail sale / direct to consumer sales 

• Other 

9. How many minimum-risk, skin-applied insect repellent products does your 

company have? 

10. What portion of your company’s revenue or income is derived from 

minimum-risk, skin-applied insect repellents? 

11. Can you provide us with copies of labels from your skin-applied insectrepellent products? 

12. Does your company provide any non-pesticide products or services? If so, 

please describe them. 

Questions: Small entities 

13. Would a specific flexibility for small entities be useful to you? 

• Examples: more time to comply with requirements, more streamlined 

process, assistance with understanding requirements 

• Please be specific with suggested alternatives and why the flexibility is 

needed for small entities (and not for larger firms). 

14. What criteria should be used to define a small entity eligible for flexibility? 

• Revenue? Number of employees? Other criteria? 

2
November 17, 2009 

• Please suggest a number in the category you choose, and any 

information that can support your choice. 

3