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SUPPORTING STATEMENT FOR

AN INFORMATION COLLECTION REQUEST (ICR)

1. IDENTIFICATION OF THE INFORMATION COLLECTION

1(a) Title and Number of the Information Collection

Pesticide Environmental Stewardship Program Annual Measures Reporting

EPA ICR No.: 2415.01 OMB Control No.: 2070-NEW

1(b) Short Characterization

This new information collection request (ICR) enables EPA to run the Pesticide 

Environmental Stewardship Program (PESP) 1. The program uses the information collected to 

establish partner membership, develop stewardship strategies, measure progress towards 

stewardship goals, and award incentives. PESP is an EPA voluntary program implemented by

the Office of Pesticide Programs (OPP). Its goal is to promote environmental stewardship to 

protect human health and the environmental. PESP encourages the use of integrated pest 

management (IPM) strategies to reduce pests and pesticide risks through partnerships with 

entities among the pesticide user community. IPM is an approach that involves making the best 

choices from among a series of pest management practices. It allows for economical pest 

management, and does so with the least possible hazard to people, property, and the 

environment.

PESP was established in 1994 with six member organizations and has grown to 314. 

While most PESP members are entities that are pesticide end-users, several others are

organizations which focus on training, educating, or influencing pesticide users. To become a 

PESP member, a pesticide user entity or an organization submits an application and a five-year 

strategy. The strategy outlines how environmental and human health risk reduction goals will be 

achieved through the implementation of IPM, or through educating others on IPM. The program 

encourages PESP members to track progress towards IPM goals: reduced use of unnecessary 

pesticides, cost reductions, and knowledge shared about IPM methodologies. Entities in the 

PESP program benefit through technical assistance, and through incentives for achievements at 

different levels. 

PESP provides incentives for advancing IPM and pesticide risk reduction through awards 

programs and public recognition. EPA recognized the performance of outstanding members by

rewarding PESP Champions.

2

 This award, first given in 2002, distinguished members by 

publicizing their outstanding efforts for promoting IPM, reducing pesticide risk, and for their 

extraordinary level of commitment to the PESP mission and objectives. In 2011, the PestWise 

Awards program broadened the existing PESP Champion Award program to foster collaborative 

 

1 The Pesticide Environmental Stewardship Program website can be found at http://www.epa.gov/pesp/

2

PESP Champions Awards, PESP Handbook (2011, p. 6): http://www.epa.gov/pestwise/pesp/documents/pesphandbook.pdf
November 2, 2012

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innovations that highlight IPM solutions to pest management problems.3 As of November, 2012, 

the PestWise program has not started conferring awards.

The incentive structure of PESP is dependent upon members’ submission to EPA of IPM 

use information and reports on the resulting environmental outcomes. For example, members 

may qualify to advance to one of three membership tiers (bronze, silver, and gold) based on 

sustained reduction of pesticide risks and an independent measure of IPM implementation.4 The 

data needed to quality is collected through the annual PESP reports. In addition, annual progress

reports (also referred to as ‘surveys’ in the PESP program) enable EPA and PESP members to 

track measure the progress being made in adopting IPM activities and reductions in risks to 

human health and the environmental. Attachment A is a flow chart that demonstrates the PESP 

membership level advancement process.

2. NEED FOR AND USE OF THE COLLECTION

2(a) Need/Authority for the Collection

Section 2(b) of the Pollution Prevention Act of 1990, 42 U.S.C. 13101(b), sets forth “the 

national policy of the United States that pollution should be prevented or reduced at the source

whenever feasible.” Section 3 defines source reduction as any practice that “reduces the amount

of any hazardous substance ... released into the environment” and “reduces the hazards to public

health and the environment associated with the release of such substances.” To implement this 

policy, Section 4(b) of the Act directs the Administrator of EPA to, among other things, 

“facilitate the adoption of source reduction techniques by business” (see Attachment B).

Section 3 of the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA) requires

EPA to regulate pesticides to prevent “unreasonable adverse effects” on human health and the 

environment (Attachment C). IPM strategies such as decreasing pesticide use and targeted 

pesticide treatment reduce the likelihood of pesticides causing unreasonable adverse effects. The

Food Quality Protection Act (FQPA) of 1996 (7 USC 136r–1) requires the U.S. Department of 

Agriculture and EPA to implement programs in research, demonstration, and education to 

support the adoption of IPM, make information on IPM widely available to pesticide users, use

IPM techniques in carrying out pest management activities, as well as promote IPM through 

procurement, regulatory policies and other activities (Attachment D). PESP is EPA’s nonregulatory approach to meeting the goals of the Pollution Prevention Act, FIFRA and FQPA to 

reduce pesticide use and risks in agricultural and non-agricultural settings.

The collection of information which documents and measures member accomplishments 

enables EPA to fairly and accurately assess program effectiveness and award benefits. 

Completed PESP applications, including contact information, are preliminary to EPA’s formal

acceptance of members. Annual progress reports allow EPA to understand and assist each

 

3

 PestWise Awards program information: http://www.epa.gov/pestwise/awards/index.html

4 The PESP Member Directory website details how members can receive recognition for their achievements by 

qualifying for Bronze, Silver, and Gold tiers: http://www.epa.gov/pestwise/pesp/members/
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member’s efforts. In addition, such reports track and measure individual and overall program 

progress in adopting IPM, and the resulting reductions in risks to human health and 

environmental.

2(b) Practical Utility/Users of the Data

The information collected by PESP is not designed or intended to support EPA regulatory 

decision-making. EPA intends to use the information collected in the PESP Membership

Application and the Strategy/Reporting Form to:

(1) Identify the member’s commitment to promoting and implementing IPM practices; 

(2) Verify the member’s involvement in promoting and implementing IPM practices; 

(3) Measure environmental outcomes resulting from the member’s activities toward 

promotion and implementation of IPM, and 

(4) Determine the member’s eligibility for award or recognition under PESP.

In addition, to the extent possible, EPA will analyze the data to look for environmental 

trends and highlight program successes by posting information on the PESP website

(http://www.epa.gov/pestwise/pesp).

3. NON-DUPLICATION, CONSULTATIONS, AND OTHER COLLECTION 

CRITERIA

3(a) Non-Duplication

Respondents will not be asked to provide information that has been or is currently being 

collected by EPA, other federal or state agencies, or proprietary sources. The information 

collected by PESP is unique and is not duplicative of previous ICRs. EPA consulted with trade

associations and potential partners to confirm that the information being collected by the PESP

does not exist elsewhere.

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

Pursuant to 5 CFR 1320.8(d), EPA published a Federal Register notice (75 FR 66084, 

October 27, 2010) announcing this proposed information collection activity and provided a 60-day

public comment period. Ten comments were submitted on this proposal. Public comments for

this action and stakeholder comments other comments received regarding this ICR have been

posted in the docket at http://www.regulations.gov and may be accessed using the docket identifier 

EPA-HQ-OPP-2010-0793. EPA’s response to the comments document addresses the comments 

received during the public comment period (ATTACHMENT E).

3(c) Consultations

Stakeholder Meetings

During the development of this ICR, the Agency consulted with PESP members and 

stakeholders who actively interact with the Agency through PESP. EPA engaged in a stakeholder
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consultation process during the PESP National Conference in November 2009. 5Following the 

presentation of a proposed list of performance measures to members in attendance, EPA facilitated 

an extensive, one-and-a-half day dialogue. In January and February of 2010, EPA conducted a pilot 

exercise to assess the burden on members of submitting annual PESP progress reports. During this 

pilot, EPA asked 10 PESP members to submit an annual progress report. The results from this 

pilot exercise have informed the burden estimates of this information collection as reported in 

Section 6 of this document.

Notice and Comments

Following the publication of the first Federal Register Notice for this ICR, eight PESP 

member organizations submitted comments. Four of the comments received were in support of 

the proposed information collection activities. National Pest Management Association and 

Audubon International provided comments to the public docket in support of the measures 

proposed in the ICR. One commenter, Fischer Environmental Services, stated that the actual 

burden should be much lower that shown in the proposed ICR because the information required 

in the reporting form is already tracked in the pest control industry, and would require no extra 

work to submit over 95% of the requested data.

Three commenters expressed some concern over the specificity and the nature of the 

measurement data, asking for more flexibility to submit approximate figures and alternative 

measurement data. EPA revised some of the measures to allow for more flexibility in options as 

a result of such comments. The Agency’s responses to public comments are included in the 

docket as well as in ATTACHMENT E of this final ICR.

 

Consultation Responses

In July and August of 2012, EPA consulted with representative members from each of the 

three membership categories: IPM users, National IPM users, and IPM promoters. Three PESP 

members were provided feedback on the burden estimates associated with this ICR as well as 

comment on the reporting requirements and processes. The questions asked and responses have 

been posted in the docket and as ATTACHMENT F of the final ICR.

List of Representatives Consulted

Lonnie E. Anderson

Terminix International

landerson@terminix.com

901-597-1293 

Joellen M. Lampman

Audubon International

jlampman@auduboninternational.org

518-767-9051, ext. 114

 

5

PESP National Conference Report (2009): http://www.epa.gov/pestwise/publications/pesp/2009-conferencereport.pdf
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Bob Rosenberg

National Pest Management Association

Rosenberg@pestworld.org

571-224-0388

Two of the entities consulted, Audubon International and National Pest Management 

Association, agreed with the burden and cost estimates in this ICR for preparing and submitting 

the information required. A third respondent, Terminix International, stated that the labor rates are 

low, and that capital costs that may be incurred for software development and implementation to 

provide required data in annual surveys need to be included.

Terminix specified two questions about the Strategy-Progress Reporting Form for 

Commercial-Residential Pest Control Services (see Section 4(b) of this ICR for a description of the 

form, ATTACHMENT I) for which they cannot currently produce data in their system to able to 

respond. These questions seek information on risk reduction in terms of total amount of pesticide 

applied (or purchased, if amount applied is not available), and on organizational profile measures 

in terms of the total number of non-chemical treatments in the reporting period.

Terminix’ estimate for adding data fields in their system to respond to these two 

questions is between $10,000 and $15,000. Even if those two data items were not required, 

Terminix estimates that it would cost them between $1,000 and $1,500 to completely answer all 

of the questions in the Strategy-Reporting form because they do not currently collect the data 

required. EPA has included the initial cost of the first year’s strategy and data collection setup in 

its estimates. This cost is reflected in Section 6 of this ICR in the burden and cost estimates, in 

Tables 1-3, within the line item “Plan, prepare, and setup for annual PESP surveys.” This cost is 

$2,130 for IPM Promoters, $5,788 for IPM Users, and $18,347 for National IPM Users. To 

clarify that such a cost has been included, the Agency has changed the description of this line 

item from “Prepare and submit annual PESP progress report,” which is how it appears in the 

proposed ICR.

In response to Terminix’ comment regarding the organization profile measures asking for 

the number of non-chemical treatments, the PESP program is considering alternatives, including 

offering the non-chemical treatment measures field as an optional one. PESP recognizes that 

defining and separately tracking the wide range of treatments that might fall under the nonchemical treatments category may be difficult for some entities, and is looking for strategies that 

can provide measurable results in this area.

Other Comments

Outside of public comments and consultations, over the course of preparing this ICR, EPA 

has received multiple verbal comments during conferences and consultations that suggest ways 

to improve the data collection method and to make some of the data measures less burdensome. 

Central Coast Vineyard Team, a PESP member, communicated to EPA staff its support for the

reporting of measures requested in this ICR and its recognition of the benefit of documenting

IPM implementation in agriculture. Again, as a result of these comments, EPA changed the

proposed performance measures to align with several of the PESP member’s suggestions.
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3(d) Effects of Less Frequent Collection

EPA requests that PESP members submit a progress report on certain environmental 

performance measures on an annual basis. The one year timeframe will enable EPA to develop a

good understanding of each member’s progress over time. Asking members to report less 

frequently would pose a greater burden on them, as members would then have to track their 

pesticide usage and other data over a longer period of time and, subsequently, provide a larger 

overall report to EPA. It would also delay recognition of members’ accomplishments, 

potentially depriving them of significant benefits of participation in PESP.

3(e) General Guidelines

The information collection activities discussed in this ICR comply with all regulatory

guidelines under 5 CFR 1320.5(d)(2). PESP members will not need to retain records for this 

program for more than one year. PESP progress reports will be submitted annually.

3(f) Confidentiality

EPA has implemented procedures to protect any confidential, trade secret or proprietary

information from disclosure that provide strict instructions regarding access to and contact with 

documents confidential business information (CBI). These procedures comply with EPA’s CBI 

regulations at 40 CFR Part 2, Subpart B.

3(g) Sensitive Questions

This information collection activity complies with the provisions of the Privacy Act of 

1974 and OMB Circular A-108. No information of a sensitive or private nature is requested in 

conjunction with this information collection activity. EPA aggregates data before sharing it with 

any party outside of the Agency. PESP data sharing activities protect an organization’s data by

presenting them in a general and unidentifiable manner. 

4. THE RESPONDENTS AND THE INFORMATION REQUESTED

4(a) Respondents and NAICS codes

PESP seeks members from among pesticide user companies and organizations, or entities 

that represent them, that are committed to reducing risks from pests and pesticides by practicing 

IPM. PESP members can also be companies or organizations that promote the use of IPM through 

education and training.

PESP offers three basic membership categories, and four program categories (Live, Work, 

Play, or Farm) based on possible sites where IPM will be implemented. Membership categories 

are IPM promoters, IPM users, and national IPM users. An example of an IPM promoter is a trade

or research organization. IPM users are those PESP members that would have their pesticide use

records centrally located, and national IPM users are those PESP members that would have their

pesticide use records spread across several company sites, regionally and/or nationally.
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Below is a list of North American Industry Classification System (NAICS) codes and

associated industries that may be affected by information collection requirements covered under 

this ICR. This list is intended to be illustrative; entities from other industries may elect to apply

for recognition through PESP. However, EPA expects that most applications will come from the 

following industries:

NAICS Code Affected Industry

11 Agriculture, Forestry, Fishing and Hunting

111 Crop Production

11142 Nursery and Floriculture Production

111421 Nursery and Tree Production

113 Forestry and Logging

22 Utilities

2211 Electric Power Generation, Transmission and Distribution

5617 Services to Buildings and Dwellings

56171 Exterminating and Pest Control Services

56172 Janitorial Services

56173 Landscaping Services

6111 Elementary and Secondary Schools

6112 Junior Colleges

6113 Colleges, Universities, and Professional Schools

622 Hospitals

6244 Child Day Care Services

71391 Golf Courses and Country Clubs

813312 Environment, Conservation and Wildlife Organizations

4(b) Information Requested

A prospective member completes two forms: The PESP Membership Application Form

(EPA Form 9600-02, Attachment G) and one of the two PESP Strategy/Progress Reporting forms 

described below, as applicable, with a list of IPM measures that the member has selected to 

commit to and track over time. The two PESP strategy/progress reporting forms are

 All applicants who are not commercial or residential pest control service providers use 

the Strategy/Progress Reporting Form for PESP Members that are Not 

Commercial/Residential Pest Control Services (EPA Form No. 9600-01, 

ATTACHMENT H);

 Applicants from Commercial/Residential Pest Control companies use the PESP 

Strategy/Progress Reporting Form for Residential/Commercial Pest Control Service 

Providers (EPA Form No. 9600-03, ATTACHMENT I).
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The PESP Strategy/Progress Reporting Forms are multi-purposed. Members use 

whichever form applies to them (either ATTACHMENT H or I) for submitting their initial PESP 

member strategy, the annual IPM performance report, or the five-year IPM strategy update.

By January 1

st of each year, each member reports on a common set of measures to 

document progress towards their goals. The set of measures any member reports on is determined 

by the program category into which the member belongs (Live, Work, Play, or Farm) and whether

the member is a commercial/residential pest control company. The PESP strategy process keeps 

all members—members and EPA—focused on the goal of pesticide risk reduction. Only those

members who submit annual PESP Strategy/Progress Reporting Forms will be eligible for PESP

Champions’ awards.

(i) Data Items

The following data items may be reported: 

 Organization name

 Name, title, address, phone number, fax number, and email address of primary and

secondary contacts

 Member group for which the candidate is applying (Live, Work, Play, or Farm)

 Type of organization (e.g. grower, pest management professional, promotional 

organization)

 If a membership organization, such as a trade association, the approximate number of

members 

 PESP strategy, which is a description of actions taken to qualify for membership, as 

well as selection of the IPM measures on which the candidate plans to report

 Annual report of progress with regard to certain measures of IPM implementation such 

as pesticide use and risk reduction, and organizational profile

(ii) Respondent Activities

Candidates conduct the following activities to apply for membership in PESP:

 Review PESP material, including criteria for membership tiers (Member Handbook6, 

PESP website)

 Select a primary and secondary contact person for the program

 Complete the PESP Membership Application, including affirming the endorsement of a

company authority (e.g., CEO or vice president for health and environment)

 Complete the member’s strategy in the PESP Strategy/Progress Reporting form

describing actions taken to qualify for membership, as well as selection of the IPM 

measures which anticipate and plan for a span of five years, and on which the applicant 

plans to report

 Submit completed form to EPA through the PESP Website, or by fax, mail, or e-mail

 

6

Pesticide Environmental Stewardship Program: Member Handbook (April, 2011)

http://www.epa.gov/pestwise/pesp/documents/pesp-handbook.pdf
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Candidates conduct the following activities to continue membership in PESP, to advance 

in membership levels, pass Agency environmental and criminal compliance screening, and to 

qualify for awards:

1) Submission of Annual Survey (Reporting):

 Provide an annual progress report on the selected IPM measures using the 

appropriate PESP Strategy/Progress Reporting Form

 Upon request, provide relevant documentation to EPA

2) Strateg y Update:

 Every five yea rs, submit an updated IPM strategy reflecting the organization’s 

current business practices and IPM strategy. The Agency does not require special or 

additional standards with strategy updates to continue participating in the PESP 

program. However, to receive incentives and awards, a PESP member may need to 

sustain their own performance and stay competitive with pesticide environmental 

stewardship achievements.

5. THE INFORMATION COLLECTED – AGENCY ACTIVITIES, COLLECTION 

METHODOLOGY, AND INFORMATION MANAGEMENT

5(a) Agency Activities

Under PESP, EPA engages in the following activities:

PESP Membership Application

 Distribute the PESP Membership Application Form to potential members, and maintain 

an online and downloadable (PDF) version of the form on the PESP Website;

 Answer questions posed by potential members regarding membership;

 Receive completed forms, review to make sure the activities of the prospective member

are in line with PESP goals, and place any necessary follow-up calls; and

 Approve candidates for membership and notify both successful and unsuccessful 

applicants of the decisions.

Annual PESP Progress Report

 Answer questions posed by members regarding annual reporting;

 Receive completed annual progress reports, review for accuracy, and conduct any

necessary follow-up communication;

 Perform analyses of the data received in the annual progress reports as necessary.

Five-Year PESP Strategy Update

 Answer questions posed by members regarding 5-year strategy updates;

 Receive updated strategy, review for accuracy, and conduct any necessary follow-up 

communication;
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 Approve or request further development of strategy updates.

PESP Award and Incentives

• Review performance

• Nominate awardee(s)

• Hold award ceremony; give awards

In addition to the above listed activities the Agency also performs an environmental and 

criminal compliance screening to ensure that all members are good actors. We perform this task by

checking Agency data bases both at headquarters and the regions. 

5(b) Collection Methodology and Management

Prospective members will be able to obtain the PESP Membership Application and 

PESP Strategy/Progress Reporting Forms online. In collecting and analyzing the information 

associated with this ICR, EPA will use a telephone system, personal computers, and applicable 

database software.

All forms were designed to have a minimum burden on the user. The technology in the 

PESP Strategy/Progress Reporting Forms provides users with the option of partially completing

a form, saving the unfinished form, then returning later to complete the form. Once complete, 

the form is submitted online. Upon submission, the measurement data are transmitted into an 

EPA-managed Customer Relationship Management system. This technology can aggregate 

measures and display data in a variety of graphical and tabular forms. The Agency will leverage

this data and technology to achieve the following key goals:

1. Develop case studies to demonstrate the economic value of implementing IPM

2. Reduce burden on members who are promoting IPM to users and collecting IPM

implementation data (especially those collecting data on pesticide usage). EPA maintains 

the current list of registered products. To analyze the pesticide usage one must have the

capacity to assess a constantly changing list of registered pesticides for a particular 

industry. It is easier for EPA to provide this service because we already maintain this 

information

3. Provide farmers and grower associations with data on effective IPM techniques and 

pesticide usage (combat resistance, pest issues, and invasive species)

4. Prevent access to and distribution of business information reported by PESP members. 

Data will only be shared publicly in aggregate form unless otherwise specified and agreed 

to by the affected PESP member(s).

5(c) Small Entity Flexibility

EPA expects that many of the members in PESP will be small entities. EPA has designed 

its forms to minimize respondent burden while obtaining sufficient and accurate information. 
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PESP is a flexible program, particularly with regard to the PESP strategy. Although a

comprehensive strategy outline is provided to prospective members, not all of the points in this 

outline will apply to every prospective member. For example, prospective members who are

primarily educational organizations would not complete the portion of the PESP Strategy/Progress

Reporting Form having to do with pesticide use. Likewise, some members will elect to not

address every point in the PESP strategy outline, due to a lack of resources to collect the necessary

information. For these reasons, EPA will review members’ annual progress reports, making

allowances on a case-by-case basis for the inapplicability of certain elements and the members’ 

abilities to provide the information. Since membership in PESP is voluntary, members may also

elect to withdraw from the program, at any time, if they do not wish to submit the annual reporting 

data needed to maintain membership in the voluntary program and assess eligibility for 

membership tier.

5(d) Collection Schedule

Organizations may submit the one-time PESP Application Form and PESP strategy

package at any time. PESP progress reports are due to EPA by October 1

st of each year.

6. ESTIMATING THE BURDEN AND COST OF THE COLLECTION

6(a) Estimating Respondent Burden

Respondent paperwork burden of participating in the PESP consists primarily of the 

administrative burden associated with filling in and submitting a PESP Membership Application, 

preparing and submitting a PESP strategy (using the PESP Strategy/Progress Reporting Form), and 

preparing and submitting an annual PESP progress report (using the PESP Strategy/Progress 

Reporting Form). Only new members fill out and submit the PESP Membership Application (one 

time). All members prepare and submit an annual PESP progress report using the PESP

Strategy/Progress Reporting Form. Each member’s IPM strategy is updated once every five 

years.

Burden estimates were prepared for the average time necessary to perform each activity for

each member category. Member categories are IPM promoters, IPM users, and national IPM 

users. An example of an IPM promoter would be a trade or research organization. IPM users are

those PESP members that would have their pesticide use records centrally located, and national

IPM users are those PESP members that would have their pesticide use records spread across 

several company sites, regionally and/or nationally, and thus have a larger burden associated with 

annual reporting. Burden estimates are based on interviews conducted with current PESP

members and Agency experience interacting with PESP members.

As shown in Tables 1 through 3, EPA estimates the paperwork burden to prepare and 

submit the five year PESP strategy (using the applicable PESP Strategy/Progress Reporting Form) 

to be 10 managerial hours; the burden to prepare and submit the PESP Membership Application

for all members is estimated to be 2 managerial hours. 
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The burden hours for the annual progress report, however, vary by type of member. The 

total annual burden hours to prepare and submit the annual progress report or survey are 25, 100, 

and 300 for IPM promoters, IPM users, and national IPM users, respectively. For each type of 

member 20% of the hours are managerial, 70% technical, and 10% clerical. In the first year, these 

hours are used to plan, prepare, and setup to submit the annual PESP surveys. For subsequent 

years, the paperwork burden estimates are to prepare and submit the survey.

As shown in Table 4, EPA estimates that an average of 424 entities will participate in the 

PESP per year for the three year ICR period (369 in year one, 424 in year two, and 479 in year 

three). The yearly increase in the number of members is based on the estimate that an average of 

55 new members will join per year in all membership categories, combined. Based on existing 

PESP data, 181 members are IPM promoters, 179 are IPM users, and 64 are national IPM users. 

EPA estimates an average of 43,000 annual hours for all members at a cost of $2.76 million per 

year.

6(b) Estimating Respondent Costs

Consistent with recent ICR renewals, OPP is using labor cost estimates from Agency

economists with respect to wages, benefits and overhead for all labor categories for affected 

industries, state government, and EPA employees. This approach uses a transparent and consistent 

methodology and current publicly available data to provide more accurate estimates and allow easy

replication of the estimates.

Methodology: The methodology uses data on each sector and labor type for an Unloaded

wage rate (hourly wage rate), and calculates the Loaded wage rate (unloaded wage rate +

benefits), and the fully loaded wage rate (loaded wage rate + overhead). Fully loaded wage rates 

are used to calculate respondent costs. Costs are indexed to 2009 dollars.

Unloaded Wage Rate: Wages are estimated for occupations (management, technical, and 

clerical) within applicable sectors. The Agency uses average wage data for the relevant sectors 

available in the National Industry-Specific Occupational Employment and Wage Estimates from 

the Bureau of Labor Statistics (BLS) at http://www.bls.gov/oes/current/oessrci.htm.

Sectors: The specific NAICS code and website for each sector is included in that sector’s 

wage rate table. Within each sector, the wage data are provided by Standard Occupational 

Classification (SOC). The SOC system is used by Federal statistical agencies to classify workers 

into occupational categories for the purpose of collecting, calculating, or disseminating data (see 

http://www.bls.gov/oes/current/oes_stru.htm). The managerial labor rate is based on the SOC for

management occupations, and the clerical labor rate is based on the SOC for office and 

administrative support occupations. The technical labor rate is based on the SOC for life, physical

and social science occupations for IPM promoters and National IPM users. For IPM users the 

technical rate is based on first-line supervisors/managers of landscaping, lawn service, and grounds 

keeping workers.

Loaded Wage Rate: Benefits represent 44% of unloaded wage rates, based on benefits for

all civilian non-farm workers, from http://www.bls.gov/news.release/ecec.t01.htm.
November 2, 2012

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Fully Loaded Wage Rate: The loaded wage rate is multiplied by 50% (EPA guidelines 20-

70%) to get overhead costs.

A copy of the formula work sheets used to estimate the labor rates based on 2011 data and 

to derive the fully loaded rates and overhead costs for this new ICR are listed in ATTACHMENT 

J. Tables 1, 2, and 3 below provide member burden and cost estimates by activity for IPM 

promoters, IPM users, and national IPM users, respectively.

Table 1: Average Annual Burden and Cost Estimates for IPM Promoters

Collection Activities

per IPM Promoter

Burden Hours Total

Management Technical Clerical

$141.39 $75.73 $38.90 Hours Costs

per hour per hour per hour

Activities for current members

Prepare and submit PESP 

strategy2 2.0 0.0 0.0 2.0 $283

Prepare and submit PESP annual 

Survey3 5.0 17.5 2.5 25.0 $2,130

TOTAL BURDEN per member 7.0 17.5 2.5 27.0 $2,412

Activities for new members

Complete and submit application 

form1 2.0 0.0 0.0 2.0 $283

Prepare and submit PESP 

strategy2 10.0 0.0 0.0 10.0 $1,414

Plan, prepare, and setup for 

annual PESP surveys

3 5.0 17.5 2.5 25.0 $2,130

TOTAL BURDEN per member 17.0 17.5 2.5 37.0 $3,826

All IPM Promoters Existing 

members

Hours per 

member

Total 

hours

Cost per 

member Total cost

Current members – 3 year 

annual average

166 27 4,482 $2,412 $400,444

New members per year 15 37 555 $3,826 $57,393

TOTAL 3 year annual 

average for all members 181 5,037 $457,837

Wage rate source: BLS for NAICS 541600 - Management, Scientific, and Technical 

Consulting Services.

1. Only new members fill out and submit a PESP Membership Application.

2. All members prepare and submit PESP strategy once every five years. For current 

members: 10 hours per strategy / 5 years = 2 hours per year.

3. New members plan, prepare, and setup for the PESP survey during the first year. After the 

first year current members submit the annual PESP survey.
November 2, 2012

Page 14 of 18

Table 2: Average Annual Burden and Cost Estimates for IPM Users

Collection Activities

per IPM User

Burden Hours Total

Management

Technical

(1st Line 

Supervisor)

Clerical

Hours Costs

$93.97 $51.55 $30.06

per hour per hour per hour

Activities for current members

Prepare and submit PESP 

strategy2 2 0 0 2 $188

Prepare and submit PESP 

annual Survey3 20 70 10 100 $5,788

TOTAL BURDEN per 

member 22 70 10 102 $5,976

Activities for new members

Fill out and submit application 

form1 2 0 0 2. $188

Prepare and submit PESP 

strategy2 10 0 0 10 $940

Plan, prepare, and setup for 

annual PESP surveys

3 20 70 10 100 $5,788

TOTAL BURDEN per 

member 32 70 10 112 $6,916

All IPM Users Existing 

members

Hours per 

member

Total 

hours

Cost per 

member Total cost

Current members - 3 year

annual average

154 102 15,708 $5,976 $920,356

New members per year 25 112 2,800 $6,916 $172,902

TOTAL 3 year annual average

for all members

179 18,508 $1,093,257

Wage rate source: BLS for NAICS 561710 - Exterminating and Pest Control Services.

1. Only new members fill out and submit a PESP Membership Application.

2. All members prepare and submit PESP strategy once every five years. For current 

members: 10 hours per strategy / 5 years = 2 hours per year.

3. New members plan, prepare, and setup for the PESP survey during the first year. After the 

first year current members submit the annual PESP survey.
November 2, 2012

Page 15 of 18

Table 3: Average Annual Burden and Cost Estimates for National IPM Users.

Collection Activities

per National IPM User

Burden Hours Total

Management Technical Clerical

$108.17 $51.50 $34.69 Hours Costs

per hour per hour per hour

Activities for current members

Prepare and submit PESP strategy22 - - 2 $216

Prepare and submit PESP annual 

Survey3 60 210 30 300 $18,347

TOTAL BURDEN per 

member 62 210 30 302 $18,563

Activities for new members

Fill out and submit application form12 - - 2 $216

Prepare and submit PESP strategy210 - - 10 $1,082

Plan, prepare, and setup for 

annual PESP surveys

3 60 210 30 300 $18,347

TOTAL BURDEN per 

member 72 210 30 312 $19,645

All National IPM Users Existing 

members

Hours per 

member

Total 

hours

Cost per 

member Total cost

Current members - 3 year annual 

average

49 302 14,798 $18,563 $909,595

New members per year 15 312 4,680 $19,645 $294,674

TOTAL 3 year annual average for

all members

64 19,478 $1,204,269

Wage rate source: BLS for NAICS 311000 - Food Manufacturing.

1. Only new members fill out and submit a PESP Membership Application.

2. All members prepare and submit PESP strategy once every five years. For current 

members: 10 hours per strategy / 5 years = 2 hours per year.

3. New members plan, prepare, and setup for the PESP survey during the first year. After the 

first year current members submit the annual PESP survey.

Table 4 summarizes the number of members and the average annual burden and cost over a three 

year period for both existing and new members. 

Table 4: Three-year Average Total Annual Burden Hours and Cost for all Members

Members Total hours Total cost

IPM Promoters 181 5,037 $457,837

IPM Users 179 18,508 $1,093,257

National IPM Users 64 19,478 $1,204,269

All Members 424 43,023 $2,755,363
November 2, 2012

Page 16 of 18

6(c) Estimating Agency Burden and Cost

For this ICR, the Agency is using internal data from OPP Divisions that provide 

significant support and analysis for PESP. These data are taken from the Time and Attendance

Information System (TAIS), which archives the Agency’s Full Time Equivalents (FTEs) for

most OPP program activities. The ICR contains appropriate FTE activity data from the

Antimicrobials Division (AD), Biological and Economic Analysis Division (BEAD),

Biopesticide and Pollution Prevention Division (BPPD), Environmental Fate and Effects 

Division (EFED), Health Effects Division (HED), Registration Division (RD), and the Pesticide

Reevaluation Division (PRD). The Agency believes that using data from the TAIS reflects 

internal operations for implementing and administering PESP activities.

Table 5 shows the FTEs by division and type of labor and summarizes the total burden 

hours and cost.

Table 5: Average Annual Agency Burden and Cost

FTEs (full time equivalent person years) Total 

burden 

hours

Wage 

per hour

Total 

Cost 

Division BEAD RD EFED PRD HED AD BPPD Total $1000s

Managerial <0.01 <0.01 <0.01 0.00 0.01 0.01 0.77 0.79 1,641 $120.32 $197

Technical 0.01 <0.01 0.02 0.00 0.07 0.07 6.96 7.13 14,836 $77.85 $1,155

Clerical <0.01 <0.01 <0.01 0.00 <0.01 <0.01 0.31 0.31 650 $44.05 $29

Total 0.02 <0.01 0.03 0.00 0.08 0.08 8.03 8.23 17,127 $1,381

Annual Agency burden hours, 17,127 were calculated by multiplying the number of

hours per FTE (2080) by the number of FTE’s, 8.23. The annual Agency costs, $1.38 million 

were calculated by multiplying the burden hours for each type of labor by their loaded wage 

rates, and summing the costs for all types of labor.

To determine Agency costs, the Agency used the Bureau of Labor Statistics estimates of

labor rates for 2011 for the NAICS code for the Federal Executive Branch (NAICS 999100). 

The managerial labor rate is based on the SOC (Standard Occupational Classification) for

management occupations; the technical labor rate is based on the SOC for life, physical and 

social science occupations; and the clerical labor rate is based on the SOC for office and 

administrative support occupations. The labor rates are fully loaded and include benefits and 

overhead. 
November 2, 2012

Page 17 of 18

6(d) Bottom Line Burden Hours and Costs

Table 6: Total Annual Burden and Cost Summary

Total hours Total cost

Respondents 43,023 $2,755,363

IPM Promoters 5,037 $457,837

IPM Users 18,508 $1,093,257

National IPM Users 19,478 $1,204,269

Agency 17,127 $1,381,050

6(e) Reasons For Changes in Burden

This is a new ICR.

6(f) Burden Statement

The annual respondent burden for this ICR is estimated to average 43,023 hours (5,037 

for IPM promoters, 18,508 hours for IPM users, and 19,478 hours for national IPM users). This 

includes time to fill out and submit the PESP Membership Application, prepare and submit the 

PESP strategy, and plan, setup, prepare and submit the annual PESP progress report.

The Agency has established a public docket for this ICR under Docket ID No. EPA-HQOPP-2010-0793, which is available for online viewing at http://www.regulations.gov, or in 

person viewing at the OPP Regulatory Public Docket in Rm. S-4400, One Potomac Yard (South 

Building), 2777 S. Crystal Drive, Arlington, VA. This docket facility is open from 8:30 a.m. to 4 

p.m., Monday through Friday, excluding legal holidays. The docket telephone number is (703)

305-5805. Comments are accepted regarding the Agency's need for this information, the 

accuracy of the provided burden estimates and any suggested methods for minimizing respondent 

burden, including the use of automated collection techniques.

Comments may be submitted to EPA electronically through http://www.regulations.gov

or by mail addressed to Director, Collection Strategies Division, U.S. Environmental Protection 

Agency (2822T), 1200 Pennsylvania Ave., NW, Washington, D.C. 20460. You can also send 

comments to the Office of Information and Regulatory Affairs, of the Office of Management 

and Budget, 725 17th Street, NW, Washington, DC 20503, Attention: Desk Office for EPA. 

Include docket ID No. EPA-HQ-OPP-2010-0793 and OMB control number 2070-NEW in any

correspondence
November 2, 2012

Page 18 of 18

LIST OF ATTACHMENTS

All of the attachments listed below can be found in the docket for this ICR or a hyperlink is 

provided for the source documentation. The docket for the action is accessible electronically

through http://www.regulations.gov using the docket identifier EPA-HQ-OPP-2010-0793.

ATTACHMENT A: PESP Membership Levels Flow Chart

ATTACHMENT B: 42 UCS 133 Pollution Prevention Act of 1990, available at 

http://www.gpo.gov/fdsys/pkg/USCODE-2009-

title42/pdf/USCODE-2009-title42-chap133.pdf

ATTACHMENT C: 7 USC 136a_Registration of Pesticides

ATTACHMENT D: USC 136r–1, The Food Quality Protection Act, available at 

http://www.gpo.gov/fdsys/pkg/USCODE-2010-title7/pdf/USCODE2010-title7- chap6-subchapII-sec136r-1.pdf.

ATTACHMENT E: Response to Public Comments on the Pesticide Environmental 

Stewardship Program Annual measures Reporting Information Collection 

Request

ATTACHMENT F: EPA Response to PESP ICR Comments Posted 3-20-12

ATTACHMENT G: PESP Membership Application (EPA Form No. 9600-02)

ATTACHMENT H: Strategy/Reporting Form for PESP Members that are Not 

Commercial/Residential Pest Control Services (EPA Form No. 9600-01).

ATTACHMENT I: PESP Strategy/Progress Reporting Form for Residential/Commercial Pest 

Control Service Providers (EPA Form No. 9600-03)

ATTACHMENT J: Worksheets Used to Calculate Labor Costs for IPM Promoters,

IPM Users, National IPM Users, and EPA