November 15 , 2013

1 of 14 **SUPPORTING STATEMENT FOR AN INFORMATION COLLECTION REQUEST**  **1. IDENTIFICATION OF THE INFORMATION COLLECTION**  **1(a) Title**  **of the Information Collection**
TI TLE: Requirements for Certified Applicators Using 1080 Collars for L ivestock Protection OMB NO. 20 70

- 0074 EPA No. 1249. 1 0 **1(b) Short Characterization/Abstract**  This information collection request (I CR) is a renewal of an existing I CR that is currently approved by

OMB and is due to expire on March 3 1 , 201 4

. This information collection activity enabl e s the Environmental Protection Agency (EPA) to obtain the information needed to track the use of registered Li vestock Protection Collar products which contain solutions of Sodium Monof luoroacetate (Compound 1080 ) and the record keeping requirements impose d by an administrative judge in October 1982 and confirmed by the Agency

in 1983. This I CR potentially affects non - federal Certified Applicators in three States (New Mexico, South Dakota, and Wyoming) , the State lead agencies for pesticide regulation in those States that monitor the program and are themselves registrants of 1080 Livestock Protection Collar products , and one additional registrant. EPA also receives annual reports on use of a 1080 Li vestock Protection Collar product registered to the U.S. D epartment of Agriculture, Animal and Plant Health Inspection Service (USDA/APHI S). That product is applied in several States by employees of USDA/APHI S

. Applicators who are certified to apply livestock protection collars are required to keep records of: a) the number of collars attached on livestock; b) the pasture(s) where collared livestock were placed; c) the dates of each attachment, inspection, and removal; d) the number and locations of livestock found with ruptured or punctured collars and the apparent cause of the damage; e) the number, dates, and approximate location of all collars lost; and f) the species, locations, and dates of all suspected poisonings of humans, domestic animals or non

- target wild animals resulting from collar use. EPA rece ives annual monitoring reports regarding 1080 collars from registrants and State lead agencies. Applicators are required to maintain records . T he registrants/ state agencies do the monitoring studies and submit the reports. These records are monitored by either a) State lead agencies , or b) registrants. This IC R also covers monitoring activities associated with collar use , a s well as the preparation and submission of an annual monitoring report to EPA , that are over and above requirements that are either c onditions of registration or obligations associated with the handling and regulation of any restricted use pesticide product.November 15 , 2013

2 of 14 **2. NEED FOR AND USE OF THE COLLECTION**  **2(a) Need/Authority for the Collection**  EPA banned all predator control uses of Sodium Monofluoroacetate in 1972. In 1981 and 1982, EPA received applications to register Compound 1080 in several delivery mechanisms, one of which was the toxic collar. Following extensive public hearings in 1982, EPA's Administrative Law Judge Nissen declared, on October 22, 1982, that the Agency could register the collar, with certain specific use restrictions, after going through the normal registration process. The Administrative L aw Judge included restrictions and recordkeeping requirements in Attachme nt C of his initial decision (see Attachment A) . On October 31, 1983, then EPA Assistant Administrator Lee M. Thomas affirmed Judge Nissen's initial decision, including the use restrictions and recordkeeping requirements.
P rior to 1972, 1080 was used for predator control in a number of way s, some of which were subject to the 1982 proceedings, which either did not receive a favorable ruling from the Administrative L aw Judge or were not subsequently registered for other reasons. As there have been occasiona l reports of predator control use and other uses of 1080 by illegal methods subsequent to 1972, EPA believes that it is extremely important to account for the 1080 that is supplied for legal use so as to maintain surveillance on the toxic collar program an d to deter diversion of 1080 in the program from legal to illegal predator control use. As 1080 is a highly soluble material of potent but delayed oral toxicity , there are additional concerns about transfer of this material to persons who might use or thr eaten to use it as a weapon of terrorism. **2(b) P**  **ractical Utility/Users of the Data** As a condition of the 1080 livestock protection collar registration, EPA required submission of annual reports monitoring use of all livestock protection collar products

. Depending upon the product, the registrant or the State lead agency for pesticide regulation is designated as being responsible for submitting an annual monitoring report. The requirement to submit reports is imposed for at least the first four years of the collars' use under the registration. Factors affecting the extension of requirements to submit annual reports include: 1) quality of reports submitted previously ; 2) amount of use reported; 3) results of collar use (in terms of numbers punctured by c oyotes, numbers punctured by other causes, numbers lost, nontarget poisonings, etc.); 4) frequency and nature of violations reported ; and 5) arrangements made between EPA and registrants regarding annual reports of collar use to meet other requirements for reporting information . EPA reviews the annual reports to assess compliance with the 1982 Administrative L aw decision and the requirements of product labeling. In1992, at the request of the Texas Department of Agriculture, this requirement was discontinu ed for the Livestock Protection Collar product registered to a private company for use only

in Texas. Up to that time, the TDA had supplied 4 years of reports showing considerable use of the product. From the data supplied in those reports, EPA drew conclu sions which led to the Agency ’s agreeing to the request.November 15 , 2013

3 of 14 **3. NONDUPLICATION, CONSULTATIONS, AND OTHER COLLECTION**  **CRITERIA 3(a) Nonduplication**  The processes for recordkeeping, reporting nontarget exposure incidents, and submitting monitoring reports are not duplicative of any other known information collection requirement. This information would not be compiled or reported but for these special requirements for livestock protection collars. While certain information on collar production may be requir ed by

agencies that prepare monitoring reports, this information would not, in the main, be duplicative of the confidential production reports that all pesticide registrants must file. The reports are limited to one specific, heavily

regulated product and represent the most efficient means for others to generate and EPA to receive this information. This information may not, in all cases, be available to the State lead agencies but for the specific reporting requirements that they impose upon registrants o f 1080 livestock protection collars. **3(b) Public Notice Required Prior to ICR submission to OMB**
In proposing to renew this I CR, EPA publish ed a notice in the Federal Register that provides a 60

- day public notice and comment period on the draft I CR (see 78 FR 42774; July 17, 2013). EPA received no comments

. The FR notice and the proposed renewal I CR are located in the docket for this action, that can be accessed at http://www.regulations.gov using the docket identifier EPA

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- 0150. **3(c) Consultations**
Inaddition to the public notice that EPA published in the Federal Register concerning the renewal of this I CR, the agency consulted with stakeholders who actively interact with the agency through the use of this collection instrument. EPA staff contacted three stakeholders and received two responses. EPA asked for their asse ss ment of the regulatory burden and costs e stimates expressed by

the Agency

in this I CR, the clarity

of instruction for respondent s, the method and frequency of collection, etc. See Attachment B for the questionnaire that was used. The responses essentially

agreed with the burden estimates, stated that the instructions are clear, and had no sugge s tion for changing the collect i on methodology o r frequency . The full consultation responses from the two entities are in A ttachment C. **3(d) Effects of Less Frequent Collection**  Annual monitoring reports are the only items pertaining to collars for which EPA requires scheduled submissions. Lo nger intervals between submissions would make the information received and EPA's responses to the reports less timely . L onger intervals also would likely increase the amount of time that would be needed to prepare each individual report , increasing th e burden on submitters

.November 15 , 2013

4 of 14 **3 (e) General Guidelines**  Requiring monitoring reports to be submitted once a year , does not conflict with the general guidelines for data requesters. The required reporting of nontarget incidents, in practice, has not generat ed any

rate of submissions that could be construed as being in violation of these general guidelines. The need for such incidents to be reported rapidly is clear, however. As discussed below in Section 5(c) of this I CR, the reporting requirements for sma ll entities have been limited as much as is legally

and responsibly

possible.
**3(f) Confidentiality** Under FIFRA, h ealth and safety data submitted by

registrants are considered by EPA to contain no confidential business information (CBI ). I f registrants submit data that relate to trade secrets or commercial or financial information, such information is protected from disclosure under Section 10 of FIFRA. Confidential data submitted by registrants to EPA in response to this particular information collecti on activity will be handled strictly in accordance with provisions of the FIFRA Confidential Business In formation Security Manual ( Attachment D ) . This manual contains instructions relative to all in contact with confidential documents, including: respons ibilities of the EPA employees; phy sical security measures; CBI

copying and destruction procedures; transfer of CBI materials within the EPA to contractors or other government offices; computer security ; CBIty ping procedures; and procedures internal to EP A. The manual dictates that all CBI

must be marked or flagged as such, all CBI must be kept in secure (double

- locked) areas, and all CBI

intended to be destroyed must be cleared by a Document Control Officer and shredded. **3(g) Sensitive Questions** No in formation of a sensitive or private nature is requested in conjunction with this information collection activity . Further, this information collection activity complies with the provisions of the Privacy

Act of 1974 and OMB Circular A

- 108. The names and addresses of certified livestock protection collar applicators and any other person **s** who own property on which livestock protection collars have been or will be applied by a certified applicator are considered personal information that will not be disclose d if ever in the possession of EPA. Inaccordance with 7 USC 136i

- 1(b), unsolicited information of a sensitive or private nature included in monitoring reports already

received, or submitted in the future, will be protected from public release.

**4. THE R** **ESPONDENTS AND THE INFORMATION REQUESTED 4(a)**  **Respondents/NAICS Codes** This information collection activity applies to all certified pesticide applicators that apply 1080 collars, to the pesticide manufacturer’s whose products include 1080 collars, and t o the government agencies responsible for implementing and administering a 1080 collar monitoring program. Information available to EPA indicates that most of the certified applicators subject to thisNovember 15 , 2013

5 of 14 IC R are employees of the Animal and Plant Health Inspe ction Service (APHI S) within the US Department of Agriculture (USDA) **.** A small number of other certified applicators may also apply 1080 collars in New Mexico, South Dakota, and Wyoming, currently or in the future

. The North American Industrial Classification Sy stem codes assi gned to the businesses and other institutions participating in this program are 325300 (Pesticide, Fertilizer, and Other Agricultural Chemical Manufacturing), 926140 (Regulation of Agricultural Marketing and Commodities), and 999200 ( State Government).
**4 (b)**  **Information Requested 4(b)**  **(i) Data Items** The data that certified livestock protection collar applicators are required to record and maintain were outlined in the Initial Decision of the Administrative L aw Judge in the 1080 Pre dacide Hearings . These requirements are stipulated in "Use Restriction 5" in the technical bulletin that is part of the labeling for all L ivestock P rotection C ollar products registered as pesticides in the United States. Use Restriction numbers and conte nt vary somewhat from product to product due to additional restrictions or considerations either proposed by the registrants or required by

State lead agencies. A list of Use Restrictions can be found in Section V.B.2 of EPA’s 1995 Re

- registration Eligibil ity Decision concerning sodium fluoroacetate (Attachment E ). Registrants of livestock protection collars are required, by Use Restriction 4 of the same ty pical technical bulletin, to: ". . . keep records of all collars sold or transferred at their add ress of record. Records shall include the name, address, state where livestock protection collar certification was issued, certification number of each recipient, and dates and numbers of collars sold or transferred." Use Restriction 5, from a ty pical te chnical bulletin, reads as follows: "Each applicator shall keep records dealing with the use of livestock protection collars and the results of such use. Records shall be maintained in accordance with appropriate State or Federal regulations but for not less than two years following disposal or loss of collars. Such records shall include, but need not be limited to: (a) The number of collars attached on livestock. (b) The pasture(s) where collared livestock were placed. (c) The dates of each attachment, inspection, and removal. (d) The number and locations of livestock found with ruptured or punctured collars and the apparent cause of the damage. (e) The number of dates, and approximate location of all collars lost. (f) The species, locations, and dates of all suspected poisoni ngs of humans, domestic animals or non

- target wild animals resulting from collar use." Use Restriction 6, from the same ty pical technical bulletin, requires that "suspected" poisonings of "threate ned or endangered species,... humans, domestic animals or nontarget wildNovember 15 , 2013

6 of 14 animals" be reported, within three day s of the incident, to a designated government agency (EPA and/or the appropriate State lead agency for regulation of pesticides). EPA requires that certified applicators of livestock protection collars kee p and report only those records prescribed by Use Restrictions 5 and 6.

**4(b) (ii)**  **Respondent Activities** Certified livestock protection collar applicators are required by product labeling to prepare and maintain records of various activities associated wi th use and fate of livestock protection collars that they

purchase or obtain for use. Preparing these records consists of writing down what is done in normal use and handling of collars. The use of livestock protection collars is a labor

- intensive proces s. For a ty pical sheep operation, collar use involves the following activities: (a) corralling sheep; (b) isolating target flocks; (c) capturing appropriate livestock and equipping them with collars; (d) redeploying target and main flocks in way s that are expected to di rect coyotes' attacks toward target flocks and away from the remainder of the producer's sheep or goats ; (e) inspecting target flocks weekly (or more frequently

) to account for livestock alive, dead, or missing; to search for lost sheep (or goats) or lost coll ars; to capture livestock that require adjustments to collar position or other hands

- on attention; and to properly

handle and dispose of irreparably damaged collars; and, when collar use is to be terminated; corralling target flocks, capturing collared liv estock, removing and inspecting collars, disposing of damaged collars, and returning intact collars to proper secure storage. The recordkeeping requirements add the need to record significant data associated with collar use such as how many collars were u sed, where and when they were used, how many

were damaged, likely

causes of such damage, where collars went after use, and the occurrence of possible nontarget exposure incidents. The time and other costs associated with preparation and maintenance of sal e records are conditions of collar use which are required by the product’s labeling. Such requirements are not part of the subject I CR. Burdens related to the I CR begin with the compilation of applicator’s records and with activities associated with asse mbling data for inclusion in monitoring reports. Registrants and/or State lead agencies have developed their own instruments that facilitate appropriate recordkeeping by certified applicators. State lead agencies ty pically require certified livestock pro tection collar applicators to file periodic reports summarizing collar use. Data from these reports are included in annual monitoring reports submitted to EPA by registrants or state lead agencies. Other data that appear in monitoring reports include summaries of numbers of collars sold or otherwise legally circulated in the State and the number and nature of violations detected with regard to use or handling of livestock protection collars.November 15 , 2013

7 of 14 As with other registrants of pesticide products, livestock pro tection collar registrants are required to file annual (confidential) production reports. These reports are required of all establishments that produce pesticides or pesticide devices in the United States, pursuant to Section 7 of FIFRA. Since production does not equate with use, the I CR is not duplicative of the requirement to submit annual production reports , which is covered by a different I CR

.

**5. THE INFORMATION COLLECTED** 
**- AGENCY ACTIVITIES, COLLECTION**  **METHODOLOGY, AND INFORMATION MANAGEMENT 5(a)**  **Agency Activities** Reports of non

- target species poisonings and other incidents included in the annual monitoring reports filed with EPA by State lead agencies are reviewed by the Insecticide

Rodenticide Branch, which initiates whatever regulatory steps are warranted by

the incident and places a copy

of the incident report in the registration file for the product involved in the incident. To date, no nontarget poisoning incidents have been reported to EPA by State lead agencies. Reasons for this appear t o be the limited extent to which collars are used and the relatively low potential for occurrence and detection of nontarget incidents. However, EPA has noted , at times, instances of violations and inaccuracies in inventory in its reviews of monitoring re ports. EPA replies directly , in writing, to the originator of the report, indicating whether the report is acceptable, whether additional details are needed for the current report or future reports, and whether any

specific corrective steps are needed bas ed upon items discussed in the monitoring report. **5(b) Collection Methodology and Management** As the number of registered livestock protection collar products is very small ( 5 at present) and very few reports are expected to be received, no special prov isions for data collection and management are needed. The reports submitted are handled and processed through mechanisms that have been developed for handling a wide variety of submissions that pertain to registered pesticide products. These include rout ing the submission through the routine review process, responding to the submission in writing, and filing the submission and the response in the relevant product's registration file. These submissions are tracked by EPA's Pesticide Registration In formati on Sy stem ( PRI SM ). **5(c) Small Entity Flexibility** Most users, and the private company that is a livestock protection collar registrant, would qualify as small entities. The degree of imposition that these recordkeeping and reporting requirements impose on such individuals is minimal, considering the limited degree of latitude permitted by

the Administrative L aw Judge and the Administrator of the EPA, the extreme toxicity of Compound 1080, and the great potential for abuse of livestock protection collars if collars or their contents were to get into the hands of irresponsible persons. The main purpose of the recordkeeping requirements is to promote responsible use and handling of livestock protection collars . The mainNovember 15 , 2013

8 of 14 purpose for requiring monitoring rep orts is to establish a process through which it is mandatory to inform EPA of the results of collar use. EPA then can use the data from reports as bases for future regulatory

decisions. The mandatory

submission of periodic reports from applicators to State lead agencies based on data that they

are already

required to collect adds only a minimal amount of burden. In Texas **,** where the livestock protection collar product registered to a private firm is used, the lead agency requires the registrant to submit sales and distribution documents to the State. **5(d) Collection Schedule** Li vestock protection collar annual monitoring reports are due on a date prescribed as a condition of registration, usually February 15, for each year after the first year in which c ollars may be used legally

. As nontarget exposure incidents must be reported within three day s of their occurrence **,** there is no set schedule for collection of this information. Such reporting is required by product labeling and, therefore, is not part of this I CR. However, nontarget incidents also would be reported and discussed in monitoring reports for the year in which they occurred, with follow

- up information regarding dispositions of cases being indicated.

**6. ESTIMATING THE BURDEN AND COST OF**  **THE COLLECTION 6(a) Estimating Respondent Burden**  EPA has reviewed the estimated burden associated with the 1080 livestock protection collar annual monitoring reports over its 20 1 0 estimates based on the reports most recently submitted to EPA. For the n ext 3 years, EPA expects that 40 certified applicators ( 30 for New Mexico and 1 0 for APHI S) will use and/or possess collars annually and, consequently , contribute information to be used in monitoring reports. EPA does not expect the burden per applicator , which is currently 40 hours , to decrease or increase over the next 3 years **.** Therefore, this figure remains unchanged from our 20 1 0 estimate. EPA points out that this estimate was developed under the assumption that, while perhaps unlikely , one non - targe t species poisoning incident will occur per year and require 10 hours of burden (which is included in the 40 hour estimate) . In all, EPA estimates the total annual burden for certified applicators of 1080 livestock protection collars to be 1600 hours (40 applicators x 40 hours)

. EPA anticipates that 4 registrants and/or State lead agencies will file annual monitoring reports based upon information obtained from those certified applicators. Note that, except in the case of the pesticide producer (for who m annual product monitoring reports are no longer required) , the registrant is a S tate or Federal Agency . T he estimated annual respondent burden for this activity is 77 hours over the next 3 years , and has not changed over the 20 1 0 estimates. The annual b urden of the States and registrants is based on the annual monitoring report alone and not other requirements related to use, administration, and regulation of 1080 L ivestock P rotection C ollars. There are currently

two States that have been reporting annu ally on L ivestock P rotection C ollar use ,November 15 , 2013

9 of 14 New Mexico and Wyoming . An other s tate , S outh Dakota may possibly becom e involved in reporting activit ies in the future. EPA estimates the total annual burden for agencies submitting annual monitoring reports to b e 308 hours (4 submitters x 77 hours)

. As with other registrants of pesticide products, livestock protection collar registrants (i.e., the producer(s), not the State agencies) are required to file annual (confidential) production reports

. There is one p roducer and four other registrants

. The estimated annual per respondent burden for this activity

is 9 hours , with a total of 36 hours per year over the next 3 years (4 producers x 9 hours)

. The Agency recognizes that the time needed to prepare reports i s affected primarily by the extent of use and the number of applicator's to be covered by the report during any

given year. Tables 1, 2, and 3 provide a breakdown of the collection activities per respondent and a general overview of how the estimates were derived. The total annual response burden imposed upon certified applicators, State agencies, and registrants associated with the use of 1080 livestock protectio n collars is estimated to be 1,9 44 hours (1600 + 308 + 36)

. **6(b) Estimating Respondent Cost s**  As in the 2010 version of this I CR, the Agency estimates wages, benefits, and overhead for all labor categories for the pesticide industry , state government and Agency employees. EPA’s estimates are based on currently available information on labor rat es from the U.S. Department of Labor and other benefits from publicly available websites. A copy of the methodology

used to re

estimate the labor rates and formulas used to derive the fully loaded rates and overhead costs that are used in this I CR are lis ted in A ttachment s F , G, and H

. To derive the labor rates for this I CR, Agency economists estimated the wages for the management, technical, and clerical labor categories using the methodology cited above. The registrant respondent costs for managerial, technical and clerical rates are estimated at $ 117.74 , $ 62.58 , and $ 37.33 per hour, respectively . These labor rates are fully loaded and in clude benefits and overhead costs. The state government respondent costs for managerial, technical and clerical rates are estimated at $ 85.67 , $ 58. 20 , and $ 40. 67 p er hour, respectively . These labor rates are fully loaded and include benefits and overhead costs. Based on EPA’s methodology for estimating pesticide

- related information collection request wage rates for industry , state, and EPA

- and based on EPA’s familiarity with the 1080 L ivestock P rotection C ollars program and experiences with USDA

- EPA estimates the fully

- loaded labor rate of a certified applicator of 1080 L ivestock P rotection C ollars to be app roximately equal to the state government clerical labor rate of $ 40. 67 /hr (includes the base wage rate, benefits, and overhead). The total annual cost for all respondents associated with this information collection activity is estimated to be approximatel y $77,044 . In summary :

 Certified applicators: $ 65,072November 15 , 2013

10 of 14  States: $ 16,3 13
 Registrants: $ 1,9 50 The annual cost for a single respondent is:
 Certified applicator: $ 1,627
 State: $ 4,07 8
 Registrant: $4 8 7 Tables 1 through 3 present information for esti mating costs based on the burden hours/costs per respondent. **Table 1. Annual Certified Applicator Burden/Cost Estimates Collection Activities**  **Burden Hours Total**  **Cost a**  1. Read/hear rule or any collection instrument 3 $ 122.01 2. Receive training b

-- -- 3. Plan activities 3 $ 122.01 4. Create information 3 $ 122.01 5. Gather information 18 $ 732.06 6. Process and review information for accuracy 5 $ 203.35 7. Record, disclose, or display the information 5 $ 203.35 8. Store, file or mai ntain the information 3 $ 122.01 TOTAL 40 $ 1,626.80 (a) Certified Applicator ($ 40. 67 /hr) (b) The burden associated with the training of certified applicators is accounted for under the ICR for the A gency Certification and Training Program (EPA ICR# 0155 ; OMB Control No. 2070

- 0029). ANNUAL BURDEN: Hour Total (40) x Number of Respondents (40) = 1,600 ANNUAL COST: Cost Total ($ 1,6 27 ) x Number of Respondents (40) = $ 65,072 **Table 2. Annual State Agency Burden/Cost Estimates Collection Activities**  **Bur den Hours (per year)**  **Total Cost**  Management ($ 85.67 /hr) Tech.

($ 58.20 /hr) Clerical

($ 40. 67 /hr)
1. Read/hear rule or any collection instrument 0 2 0 $116. 40 2. Plan activities 0 10 0 $ 582November 15 , 2013

11 of 14 3. Create information 0 15 0 $ 873 4. Gather information 0 14 0 $ 814.80
5. Process, compile, and review information for accuracy

and appropriateness 0 13 0 $ 756.60 6. Record, disclose, display or report the information 0 0 20 $ 813.40 7. Store, file or maintain the

infor mation 0 0 3 $ 122.01 TOTAL 0 54 23 $4, 078.21 ANNUAL BURDEN: Hour Total (77) x Number of Respondents (4) = 308 ANNUAL COST: Cost Total ($ 4, 078 ) x Number of Respondents (4) = $ 16, 313
**Table 3. Annual Registrant Burden/Cost Estimates** ***** *****

**C ollection Activities**  **Burden Hours (per year) Total Cost**  **Management ($**  **117.74 /hr)**  **Tech.**

**($ 62.58**  **/hr) Clerical** 

**($ 37.33**  **/hr)**
1. Read/hear rule or any collection instrument 0 2 0 $ 125.16 2. Plan activities 0 1 0 $ 62.58 3. Create info rmation 0 0 0 $0.00 4. Gather information 0 2 0 $ 125.16
5. Process, compile, and review information for accuracy

and appropriateness 0 1 0 $ 62.58 6. Record, disclose, display or report the information 0 0 2 $ 74.66 7. Store, file or maintain the information 0 0 1 $ 37.33

TOTAL 0 6 3 $ 487.47 ** In all but one case, the registrant is the State and, therefore, covered under State burdens (Table 2). ANNUAL BURDEN: Hour Total (9) x Number of Respondents (4) = 36November 15 , 2013

12 of 14 ANNUAL C OST: Cost Total ($ 487 ) x Number of Respondents (4) = 1,9 50
**6(c) Estimating Agency Burden and Cost** The Agency's total annual burden associated with the 1080 livestock program has changed based upon more accurate estimates of the resources required t o complete tasks specifically associated with annual monitoring reports. To derive the labor rates for this I CR, Agency economists estimated the wages for the management, technical, and clerical labor categories using the methodology cited above. The E PA labor rates for this renewal for technical and clerical rates are estimated at $ 78.24 , and $ 44.61 per hour, respectively . These labor rates are fully loaded and include benefits and overhead costs. For this I CR, we estimate the annual Agency burden to be 104 hours and the total annual Agency cost to be $ 8, 137

. **Table 4. Annual Agency Burden/Cost Estimates**

**Collection Activities Burden Hours (annual)**  **Total Cost**  Tech. ($ 78.24 /hr) Clerical

($ 44.61 /hr) 1. Develop any

correspondence need ed 8 0 $ 625.92 2. Answer respondents’ questions 2 0 $ 156.48 3. Review data submissions 10 0 $ 782.40 4. Analy

ze data submissions 4 0 $ 312.96 5. Store data 2 0 $ 156.48

TOTAL 26 0 $ 2,034.24 ANNUAL BURDEN: Hour Total (26) x Number of Respondents (4) = 104 ANNUAL COST: Cost Total ($ 2,0 3 4 ) x Number of Respondents (4) = $8, 137 **6(d) Bottom Line Burden Hours and Costs Table 5.**  **Annual Bottom Line Burden Hours and Costs/Master Table**  **Total Burden Hours**  **Total**

**Cost ($)** Ce rtified Applicator (Table 1) 1,600 $ 65,072 State (Table 2) 308 $ 16,313November 15 , 2013

13 of 14 Registrant (Table 3) 36 $ 1,950 Bottom L ine Respondent Total 1,944 $ 83,335 Agency Total 104 $ 8,137
**6(e) Reasons for Change in Burden** The total annual respondent burden hour s estimate does not change from the currently approved IC R

. **6(f) Burden Statement** The annual respondent burden for the 1080 livestock collar program is estimated to average 40 hours per certified applicator response, 77 hours per State agency respon se, and 9 hours per registrant participating in the program. Under the Paperwork Reduction Act, “burden” means the total time, effort, or financial resources expended by persons to generate, maintain, retain, or disclose or provide information to or for a Federal agency . For this collection, it is the time reading the regulations, planning the necessary data collection activities, conducting tests, analy zing data, generating reports and completing other required paperwork, and storing, filing, and maintai ning the data. An agency

may not conduct or sponsor, and a person is not required to respond to, a collection of information unless it display s a currently valid OMB control number. The OMB control number for this information collection appears at the be ginning and the end of this document. Submit your comments, referencing Docket ID No. EPA

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- 0150 to (1) EPA online using www.regulations.gov (our preferred method), or by mail to: Public Information and Records Integrity

Branch (PIRI B), Mail Cod e: 7502P, Office of Pesticide Programs (OPP), Environmental Protection Agency , 1200 Pennsylvania Ave., NW, Washington, DC 20460, and (2) OMB by mail to: Office of Information and Regulatory Affairs, Office of Management and Budget (OMB), Attention: Desk Of ficer for EPA, 725 17th Street, NW, Washington, DC 20503. Use EPA’s electronic docket and comment sy stem at www.regulations.gov, to submit or view public comments, access the index listing of the contents of the docket, and to access those documents in th e docket that are available electronically . Once in the sy stem, select “docket search,” then key

in the docket ID number identified above. Please note that EPA’s policy is that public comments, whether submitted electronically or in paper, will be made available for public viewing at www.regulations.gov as EPA receives them and without change, unless the comment contains copy

righted material, CBI , or other information whose public disclosure is restricted by statute. For further information about the el ectronic docket, go to www.regulations.gov

.November 15 , 2013

14 of 14 **Attachments to the Supporting Statement** All of the attachments listed below can be found in the docket for this I CR (unless otherwise noted); accessible electro nically through **www.Regulations.gov** . On the main page, select **Advanced Search** from the menu bar at the top and select **Docket Search** . Enter the Docket ID Number, EPA

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- 0 150 in the **Docket ID** field. Click on the **Submit button** . From the results page, you will be able to link to the docket view or directly open select documents found in the docket. **Attachment A:** EPA’s Administrative L aw Judge ’s 1982 Decision on Restrictions and

Recordkeeping Requirements (p p. 217

- 219, “Attachment C, Use Restrictions”) **Attachment B:** Sample Consultations Questionn aire **Attachment C:** Consultations Responses **Attachment D**  **:** Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA) Confidential

Business Security

Manual **Attachment E**  **:** EPA’s 1995 Re

- registration Eligibility Decision Concerning Sodium Fluoroacetate **Attachment F**  **:** Methodology for Estimating OPP I CR Wage Rates for States and Applicators **Attachment G:** Methodology for Estimating OPP I CR Wage R ates for Registrants **Attachment H:** Methodology for Estimating OPP I CR Wage Rates for EPA