Attachment F

Calculations Regarding Small Entities that Participate in this ICR

EPA estimated the number of small entities that participate under this ICR using information on 

company revenue and employment from Dun and Bradstreet database reported for the year 2010. 

The Dun and Bradstreet database is a comprehensive source of financial information on entities, 

including firm locations, sales, number of employees, and primary business classifications under 

North American Industrial Classification System code (NAICS). EPA assumed the majority of 

respondents are individual companies with a NAICS code 325320 (Pesticide and Other 

Agricultural Chemical Manufacturing). 

The number of companies in the Dun and Bradstreet 2010 database using this code was 892. 

EPA was able to determine the size of 882 of these individual companies. The parent company 

of the 10 remaining un-sized companies did not report enough sales or employee data to allow a 

proper analysis based on the SBA size classifications. Of the sized firms, 26.3% (232) are large 

firms or are subsidiaries of large firms, and 73.7% (650) are small firms or subsidiaries of small 

firms. Currently, 1733 companies are listed in EPA’s registration tracking database discussed in 

section 5(b). Assuming that the distribution of large and small firms is independent of NAICS 

code, EPA estimates that there are 456 (26.3% of 1733) large firms and 1277 (73.7 % of 1733) 

small firms that are potential respondents to this ICR. 

EPA also estimated the impact of this ICR on small entities by calculating the annual company 

burden as a percentage of average annual revenue. Child Resistant Packaging applications were 

submitted to the Agency by 49 parent firms between 2006 and 2009. EPA determined that 27 of 

the submitting companies were large and 21 were small based on information from the Dun and 

Bradstreet 2010 database. Table F.1 exhibits list of small entities that submitted CRP 

applications between 2006 and 2009. Companies are listed at the parent level. The table includes 

company NAICS code, annual sales, employment, US Small Business Administration (SBA) 

small business definition, and SBA size threshold. EPA was unable to size one company. 

Table F.1

Parent Company

NAICS 

Code

Annual 

Sales ($) Employees

SBA 

Definition1

SBA Size 

Threshold1

Alden - Leeds, Inc. 325998 75 E 500

American Vanguard 

Corporation 325320 237,538,000 320 E 500

Aqua Tri 424690 2,000,000 24 E 100

Biosensory Insect Control 561710 130,000 3 R 6,000,000

Bonide Products, Inc. 325998 35,700,000 200 E 500

Bug Stompers Inc 561710 200,000 3 R 6,000,000

Clarke Mosquito Control 

Products, Inc.- 325320 35,000,000 40 E 500

Control Solutions, Inc. 325320 50 E 500

Db Square LLC 561990 100,000 2 R 6,000,000
Envirosafe Technologies, Inc. 334112 2,200,000 18 E 1,000

Gil Manufacturing Inc 453998 1,100,000 11 R 6,000,000

Haco Group Inc 423610 250,000 2 E 100

McLaughlin Gormley King 

Company 325320 1,000,000 90 E 500

Pbi/Gordon Corporation 325320 300 E 500

Pic Corporation (inc) 325320 5,400,000 30 E 500

Porpoise Pool & Patio, Inc. 533110 1,000,000 280 R 6,000,000

Share Corporation 325612 16,900,000 172 E 500

Southeast Laboratories, Inc. 335314 250,000 3 E 750

Spurrier Chemical Companies, 

Inc. 325199 20,900,000 67 E 1,000

Vertex Chemical Corp 325188 52,000,000 45 E 1,000

Vetsource, Inc. 423390 3,000,000 2 E 100

1. An “E” indicates that the SBA small business definition is based on employment and an “R” 

indicates that the SBA small business definition is based on revenue from annual sales. 

Definitions and SBA size thresholds are based on the US Small Business Administration’s 2008 

“Table of Small Business Size Standards Matched to North American Industry Classification 

System Codes” available online at: 

http://www.sba.gov/idc/groups/public/documents/sba_homepage/serv_sstd_tablepdf.pdf

Table F.2 below presents the total and average revenue and employment for small companies, 

large companies, and all companies combined. As shown below in Section 6, the burden cost per 

CRP submission is estimated to be approximately $439 (Table 2, section 6). Assuming that CRP 

submissions are evenly distributed across small and large companies, an average firm would 

submit approximately 14 CRP applications per year, assuming 50 companies are responsible for 

the 685 (see Table 1, section 6) CRP submissions in a given year. This would result in an 

average annual company burden of $6,146, or 0.03% of small firm’s annual revenue, on average.

Table F.2

Total 

Number 

of Firms

Total Revenue

($)

Total 

Employee 

Size

Average Revenue1

($)

Average 

Employment1

Small Firms 21 414,668,000 1,737 23,037,111 73

Large Firms 27 312,730,280,167 598,975 12,028,087,699 23,031

All Firms 48 313,144,948,167 600,712 7,116,930,640 13,639

1 Only based on firms that report sales on D&B.