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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.: 2415.03 OMB Control No.: 2070-0188

1(b) Short Characterization

This 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 partnership program implemented by 

the Office of Pesticide Programs (OPP) established in 1994. Its goal is to promote environmental 

stewardship to protect human health and the environment. 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.

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: reductions in unnecessary use 

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

PESP benefit from technical assistance, and through incentives for achievements at different 

levels. 

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.2 The 

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

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

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

 1 The Pesticide Environmental Stewardship Program website can be found at http://www.epa.gov/pesp/ 2 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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health and the environment. 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 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

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 the 

environment.

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.
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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), in proposing to renew this ICR, EPA will publish a Federal 

Register notice announcing this proposed information collection activity and provide a 60-day

public comment period. 

3(c) Consultations

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

renewal of this ICR, the Agency will consult, as required under 5 CFR 1320.8(d)(1), with 

stakeholders who actively interact with the Agency through the use of this collection instrument.

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

stakeholders. EPA engaged in a stakeholder consultation process during a PESP National 

Conference in November 2009.3 Following 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.

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 

 3 PESP National Conference Report (2009): http://www.epa.gov/pestwise/publications/pesp/2009-conferencereport.pdf
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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 progress reports will be submitted annually. PESP 

members will not need to retain records for this program for more than one year. 

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.

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:
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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).

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.
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By January 1st 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 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 Champion

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 Handbook4, 

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

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:

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

http://www.epa.gov/pestwise/pesp/documents/pesp-handbook.pdf
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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 years, 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;

• Approve or request further development of strategy updates.

PESP Award and Incentives

• Review performance

• Nominate awardee(s)
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• Hold award ceremony; give awards

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

criminal compliance screening. We perform this task by checking Agency databases 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 a

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 the Agency already maintain this 

information.

3. Provide growers 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. 

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
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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 participation 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 1st of each year.

6. ESTIMATING THE BURDEN AND COST OF THE COLLECTION

6(a) Estimating Respondent Burden

Respondent paperwork burden of participating in 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 2 through 4, 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. 

The burden hours for the annual progress report, however, vary by type of member. This 

activity also represents the majority of burden hours for all types of members. 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, as shown in Table 1 below. 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.
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Table 1: Total Burden Hours for Submitting Annual PESP Surveys

As shown below in Table 5, EPA estimates that an average of 419 entities will participate 

in the PESP per year during the next three year ICR period. That estimate is based on the current 

number of existing members and average number of new members joining during the last three 

years. As of January 2016, PESP had 396 existing members. On average, 23 new members joined 

each year during the previous three years in all membership categories, combined. The number 

419 assumes that each year, for the next three years, 23 new members will join. Based on existing 

PESP data, 108 members are IPM promoters, 225 are IPM users, and 63 are national IPM users. 

EPA estimates an average of 47,665 annual hours for all members at a cost of $3.07 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. 

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

clerical) within applicable sectors. The Agency uses average wage data for 2014 (published in 

2015) 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 

Management

20%

Technical

70%

Clerical

10%

Total 

Hours

IPM Promoters 5 17.5 2.5 25

IPM Users 20 70 10 100

National IPM Users 60 210 30 300
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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 46% of unloaded wage rates, based on benefits for

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

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 2014 data and 

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

Tables 2, 3, and 4 below provide member burden and cost estimates by activity for IPM promoters,

IPM users, and national IPM users, respectively.

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

Collection Activities

per Promoters

Burden Hours Total

Management Technical Clerical Hours Costs

$150.10 $75.76 $41.52 

per hour per hour per hour

Activities for current participants

Prepare and submit PESP 

strategy2 2.0 0.0 0.0 2.0 $300

Prepare and submit PESP 

annual Survey

5.0 17.5 2.5 25.0

$2,180

TOTAL BURDEN 7.0 17.5 2.5 27.0 $2,480

Activities for new participants

Fill out and submit 

application form1 2.0 0.0 0.0 2.0 $300

Prepare and submit PESP 

strategy

10.0 0.0 0.0 10.0

$1,501

Plan, prepare, and setup for 

annual PESP surveys3

5.0 17.5 2.5 25.0

$2,180

TOTAL BURDEN 17.0 17.5 2.5 37.0 $3,981

Total Burden and Cost Estimates - IPM Promoters

All Promoters Existing 

participants

Hours per 

participant

Total 

hours

Cost per 

participant

Total cost

Current participants - 3 years 

average 109 27

 

2,934 $2,480 $269,526

New participants per year 1 37 25 $3,981 $2,654

Total - 3 year average 109

 

2,959 $272,180

Wage rate source: BLS for NAICS 541600 - Management, Scientific, and Technical Consulting Services.
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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 3: Average Annual Burden and Cost Estimates for IPM Users

Collection Activities

per IPM User

Burden Hours Total

Management 1st Line 

Supervisor

Clerical Hours Costs

$100.08 $51.73 $32.66 

per hour per hour per hour

Activities for current participants

Prepare and submit PESP 

strategy2 2 0 0 2 $200

Prepare and submit PESP 

annual Survey

20 70 10 100

$5,949

TOTAL BURDEN 22 70 10 102 $6,149

Activities for new participants

Fill out and submit 

application form1 2 0 0 2 $200

Prepare and submit PESP 

strategy

10 0 0 10

$1,001

Plan, prepare, and setup for 

annual PESP surveys3

20 70 10 100

$5,949

TOTAL BURDEN 32 70 10 112 $7,150

Total Burden and Cost Estimates - IPM Users

IPM Users Existing 

participants

Hours per 

participant

Total 

hours

Cost per 

participant

Total cost

Current participants - 3 years 

average 224 102 22,882 $6,149 $1,379,501

New participants per year 21 112 2,389 $7,150 $152,536

Total - 3 year average 245 25,271 $1,532,037

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.

*Estimates may not add due to rounding, 224.3 + 21.3 = 245.7
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Table 4: Average Annual Burden and Cost Estimates for National IPM Users.

Collection Activities

per National IPM User

Burden Hours Total

Management Technical Clerical

$115.81 $54.43 $36.85 Hours Costs

per hour per hour per hour

Activities for current participants

Prepare and submit PESP strategy2 2 0 0 2 $232

Prepare and submit PESP annual 

Survey

60 210 30 300 $19,484

TOTAL BURDEN 62 210 30 302 $19,716

Activities for new participants

Fill out and submit application form1 2 0 0 2 $232

Prepare and submit PESP strategy 10 0 0 10 $1,158

Plan, prepare, and setup for 

annual PESP surveys3

60 210 30 300 $19,484

TOTAL BURDEN 72 210 30 312 $20,874

Total Burden and Cost Estimates - National IPM Users

National IPM Users Existing 

participa

nts

Hours per 

participant Total 

hours

Cost per 

member Total cost

Current participants - 3 years 

average 64 302

 

19,227 $19,716 $1,255,250

New participants per year

1 312

 

208 $20,874 $13,916

Total - 3 year average 65

 

19,435 $1,269,166

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.
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Table 5 summarizes the number of members and the average annual burden and cost over a three 

year period for both existing and new members. 

Table 5: Three-year Average Total Annual Burden Hours and Cost for all Members

Members Total hours Total cost

IPM Promoters 109 2,959 $272,180

IPM Users 246 25,271 $1,532,037

National IPM Users 64 19,435 $1,269,166

All Members 419 47,665 $3,073,383

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

hours and cost.

Table 6: Average Annual Agency Burden and Cost

FTEs (full time equivalent person years) Total 

burden 

hours

Wage 

per 

hour

Total 

Cost 

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

Managerial 0.00 0.00 0.00 0.00 0.00 0.00 0.63 0.63

 

1,310 $124.09 $163

Technical 0.01 0.00 0.00 0.01 0.00 0.00 5.69 5.71

 

11,884 $81.53 $969

Clerical 0.00 0.00 0.00 0.00 0.00 0.00 0.25 0.25

 

523 $46.42 $24

Total 0.02 0.00 0.00 0.01 0.00 0.00 6.56 6.59

 

13,717 $1,156

Annual Agency burden hours, 13,717, were calculated by multiplying the number of

hours per FTE (2,080) by the number of FTE’s (6.59). The annual Agency costs, $1.16 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
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15

labor rates for 2014 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. 

6(d) Bottom Line Burden Hours and Costs

Table 7: Total Annual Burden and Cost Summary

Total hours Total cost

Respondents

IPM Promoters 2,959 $272,180

IPM Users 25,271 $1,532,037

National IPM Users 19,435 $1,269,166

Total 47,665 $3,073,383

Agency

Total 13,717 $1,155,789

6(e) Reasons For Changes in Burden

There is an increase of 4,642 hours in the total estimated respondent burden compared 

with that identified in the ICR currently approved by OMB. This increase reflects EPA's 

updating of burden estimates for this collection based upon historical information on the number 

of PESP members. Members are classified as IMP Promoters, IPM Users, and National IMP 

Users. Based on revised estimates, the number of IPM Promoters has decreased, the number of 

IMP users has increased, and the number of National IPM users has not changed since the last

ICR renewal. While the estimated burden per response has not changed for any category, the 

shift in membership types has resulted in a net increase in the overall burden. This change is an 

adjustment

6(f) Burden Statement

The annual respondent burden for this ICR is estimated to average 47,665 hours (2,959

for IPM promoters, 25,271 hours for IPM users, and 19,435 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-2016-0078, which is available for online viewing at http://www.regulations.gov, or in 

person viewing at the EPA Docket Center Public Reading Room, William Jefferson Clinton 

West Building, Room 3334, 1301 Constitution Avenue, NW, Washington, DC 20004. The EPA 

Docket Center is open from 8:30 a.m. to 4 p.m., Monday through Friday, excluding federal 

holidays. The docket center telephone number is (202) 566-1744. 
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You may submit comments 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-HQOPP-2016-07078 and OMB control number 2070-NEW in any correspondence.

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-2016-0078.

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

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

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

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

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

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

IPM Users, National IPM Users, and EPA