### Attachment F

Calculations Regarding Small Entities that Participate in this ICR

EPA estimated the number of small entities t hat 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 l ocations, 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

Ag ricultural 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 compani es 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

f irms. 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 firm s 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

Definition 1 SBA Size

Threshold 1

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

Con trol Solutions, Inc. 325320 50 E 500

Db Square LLC 561990 100,000 2 R 6,000,000Envirosafe 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 K ing

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 Laborat ories, 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 b ased 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 Matc hed 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, se ction 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 submis sions 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 Revenue 1



### ($) Average

Employment 1

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.