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SUPPORTING STATEMENT FOR AN

INFORMATION COLLECTION REQUEST

1. IDENTIFICATION OF THE INFORMATION COLLECTION

1(a) Title of the Information Collection

TITLE: Requirements for Certified Applicators Using 1080 Collars for Livestock Protection

OMB NO. 2070-0074 EPA No. 1249.10

1(b) Short Characterization/Abstract

This information collection request (ICR) is a renewal of an existing ICR that is currently

approved by OMB and is due to expire on March 31, 2014. This information collection activity

enables the Environmental Protection Agency (EPA) to obtain the information needed to track the 

use of registered Livestock Protection Collar products which contain solutions of Sodium 

Monofluoroacetate (Compound 1080) and the record keeping requirements imposed by an 

administrative judge in October 1982 and confirmed by the Agency in 1983. This ICR 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 Livestock Protection Collar product 

registered to the U.S. Department of Agriculture, Animal and Plant Health Inspection Service

(USDA/APHIS). That product is applied in several States by employees of USDA/APHIS. 

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 receives annual monitoring reports regarding 1080 collars from registrants and State 

lead agencies. Applicators are required to maintain records. The 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 ICR also covers monitoring activities associated with collar use, as 

well as the preparation and submission of an annual monitoring report to EPA, that are over and 

above requirements that are either conditions of registration or obligations associated with the 

handling and regulation of any restricted use pesticide product. 
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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 Law Judge included restrictions and recordkeeping requirements in Attachment 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.

Prior to 1972, 1080 was used for predator control in a number of ways, some of which were 

subject to the 1982 proceedings, which either did not receive a favorable ruling from the 

Administrative Law Judge or were not subsequently registered for other reasons. As there have been 

occasional 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 and 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 threaten to use it as a weapon of terrorism.

2(b) Practical 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

coyotes, 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 Law decision and the 

requirements of product labeling. In 1992, at the request of the Texas Department of Agriculture, 

this requirement was discontinued 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 conclusions 

which led to the Agency’s agreeing to the request.
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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 required 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 of 1080 

livestock protection collars.

3(b) Public Notice Required Prior to ICR submission to OMB

In proposing to renew this ICR, EPA published a notice in the Federal Register that provides 

a 60-day public notice and comment period on the draft ICR (see 78 FR 42774; July 17, 2013). 

EPA received no comments. The FR notice and the proposed renewal ICR are located in the docket

for this action, that can be accessed at http://www.regulations.gov using the docket identifier EPAHQ-OPP-2013-0150.

3(c) Consultations

In addition to the public notice that EPA published in the Federal Register concerning the 

renewal of this ICR, 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 assessment of the regulatory burden and costs estimates 

expressed by the Agency in this ICR, the clarity of instruction for respondents, 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 

suggestion for changing the collection methodology or frequency. The full consultation responses 

from the two entities are in Attachment C.

3(d) Effects of Less Frequent Collection

Annual monitoring reports are the only items pertaining to collars for which EPA requires 

scheduled submissions. Longer intervals between submissions would make the information 

received and EPA's responses to the reports less timely. Longer intervals also would likely increase 

the amount of time that would be needed to prepare each individual report, increasing the burden on 

submitters. 
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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 

generated 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 ICR, the reporting requirements for small entities have been limited as 

much as is legally and responsibly possible.

3(f) Confidentiality

Under FIFRA, health and safety data submitted by registrants are considered by EPA to 

contain no confidential business information (CBI). If 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 collection activity will be handled strictly in accordance with provisions of 

the FIFRA Confidential Business Information Security Manual (Attachment D). This manual 

contains instructions relative to all in contact with confidential documents, including: 

responsibilities of the EPA employees; physical security measures; CBI copying and destruction 

procedures; transfer of CBI materials within the EPA to contractors or other government offices; 

computer security; CBI typing procedures; and procedures internal to EPA. 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 information 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 persons 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 disclosed if ever in the possession of EPA. In accordance 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 RESPONDENTS 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 to 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 this
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ICR are employees of the Animal and Plant Health Inspection Service (APHIS) 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 System codes assigned 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 Law Judge in the 1080 

Predacide Hearings. These requirements are stipulated in "Use Restriction 5" in the technical 

bulletin that is part of the labeling for all Livestock Protection Collar products registered as 

pesticides in the United States. Use Restriction numbers and content 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 Eligibility Decision concerning sodium fluoroacetate (Attachment E). 

Registrants of livestock protection collars are required, by Use Restriction 4 of the same 

typical technical bulletin, to: 

". . . keep records of all collars sold or transferred at their address 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 typical technical 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 poisonings of humans, 

domestic animals or non-target wild animals resulting from collar use."

Use Restriction 6, from the same typical technical bulletin, requires that "suspected" 

poisonings of "threatened or endangered species,... humans, domestic animals or nontarget wild 
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animals" be reported, within three days 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 keep 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 with 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 process. For a typical 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 ways that are expected to direct 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 collars; 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 livestock, 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 used, 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 sale records are conditions of collar use which are required by the product’s 

labeling. Such requirements are not part of the subject ICR. Burdens related to the ICR begin with 

the compilation of applicator’s records and with activities associated with assembling 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 typically require certified 

livestock protection 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.
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As with other registrants of pesticide products, livestock protection 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 ICR is not duplicative of the 

requirement to submit annual production reports, which is covered by a different ICR.

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 InsecticideRodenticide 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 to 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 reports.

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 based 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 provisions 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 routing 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 Information System 

(PRISM).

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 Law 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 main 
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purpose for requiring monitoring reports 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

Livestock 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 collars may

be used legally.

As nontarget exposure incidents must be reported within three days 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 ICR. 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 2010 estimates based on the reports most recently submitted to 

EPA. For the next 3 years, EPA expects that 40 certified applicators (30 for New Mexico and 10 for 

APHIS) 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 2010 estimate. EPA points out that this estimate was developed under the assumption that, 

while perhaps unlikely, one non-target 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 whom annual product monitoring reports are no longer required), 

the registrant is a State or Federal Agency. The estimated annual respondent burden for this activity

is 77 hours over the next 3 years, and has not changed over the 2010 estimates. The annual burden 

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 Livestock Protection Collars. 

There are currently two States that have been reporting annually on Livestock Protection Collar use,
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New Mexico and Wyoming. Another state, South Dakota may possibly become involved in 

reporting activities in the future. EPA estimates the total annual burden for agencies submitting 

annual monitoring reports to be 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 producer 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 is 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 

protection collars is estimated to be 1,944 hours (1600 + 308 + 36).

6(b) Estimating Respondent Costs

As in the 2010 version of this ICR, 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 rates from the U.S. Department of 

Labor and other benefits from publicly available websites. A copy of the methodology used to reestimate the labor rates and formulas used to derive the fully loaded rates and overhead costs that 

are used in this ICR are listed in Attachments F, G, and H.

To derive the labor rates for this ICR, 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 include 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 per 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 Livestock 

Protection Collars program and experiences with USDA - EPA estimates the fully-loaded labor rate 

of a certified applicator of 1080 Livestock Protection Collars to be approximately 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 approximately $77,044. In summary:

 Certified applicators: $65,072
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 States: $16,313

 Registrants: $1,950

The annual cost for a single respondent is: 

 Certified applicator: $1,627

 State: $4,078

 Registrant: $487 

Tables 1 through 3 present information for estimating costs based on the burden hours/costs 

per respondent.

Table 1. Annual Certified Applicator Burden/Cost Estimates

Collection Activities Burden Hours Total Costa

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 maintain 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 Agency 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 ($1,627) x Number of Respondents (40) = $65,072

Table 2. Annual State Agency Burden/Cost Estimates

Collection Activities Burden 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 $582
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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 

information 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**

Collection 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 information 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) = 36
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ANNUAL COST: Cost Total ($487) x Number of Respondents (4) = 1,950

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 to complete tasks specifically

associated with annual monitoring reports. 

To derive the labor rates for this ICR, Agency economists estimated the wages for the 

management, technical, and clerical labor categories using the methodology cited above. The EPA 

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 ICR, 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 needed 8 0 $625.92

2. Answer respondents’ questions 2 0 $156.48

3. Review data submissions 10 0 $782.40

4. Analyze 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 ($2,034) 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 ($)

Certified Applicator (Table 1) 1,600 $65,072

State (Table 2) 308 $16,313
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Registrant (Table 3) 36 $1,950

Bottom Line Respondent Total 1,944 $83,335

Agency Total 104 $8,137

6(e) Reasons for Change in Burden

The total annual respondent burden hours estimate does not change from the currently

approved ICR. 

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 response, 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, analyzing data, 

generating reports and completing other required paperwork, and storing, filing, and maintaining the 

data. An agency may not conduct or sponsor, and a person is not required to respond to, a collection 

of information unless it displays a currently valid OMB control number. The OMB control number 

for this information collection appears at the beginning and the end of this document.

Submit your comments, referencing Docket ID No. EPA-HQ-OPP-2013-0150 to (1) EPA 

online using www.regulations.gov (our preferred method), or by mail to: Public Information and 

Records Integrity Branch (PIRIB), Mail Code: 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 Officer for EPA, 725 17th Street, NW, Washington, DC 20503.

Use EPA’s electronic docket and comment system 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 the docket that are available electronically. Once in the system, 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 copyrighted material, CBI, or other information whose public disclosure is restricted by

statute. For further information about the electronic docket, go to www.regulations.gov.
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Attachments to the Supporting Statement

All of the attachments listed below can be found in the docket for this ICR (unless otherwise 

noted); accessible electronically 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-HQ-OPP-2013-0150 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 Law Judge’s 1982 Decision on Restrictions and 

Recordkeeping Requirements (pp. 217-219, “Attachment C, Use 

Restrictions”)

Attachment B: Sample Consultations Questionnaire

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 ICR Wage Rates for States and Applicators

Attachment G: Methodology for Estimating OPP ICR Wage Rates for Registrants

Attachment H: Methodology for Estimating OPP ICR Wage Rates for EPA