Page **1** of **3 ATTACHMENT**  **D Record of Consultations for the**  **Experimental Use Permits (EUPs) for Pesticides ICR**
List of individuals/companies contacted 1 : Dan Jenkins U.S. Agency

Regulatory

Affairs Lead Monsanto Company Washington , DC 20005 Phone: ( 202 ) 383

- 2851 Email: daniel.j.jenkins@monsanto.com Cry stal Lay

ton Regulatory

Product Manager Landis International, Inc. 3185 Madison Highway Valdosta, GA 31601 USA Phone: (229) 247

- 6472 Email: clay

ton@landis intl.com Jerry Wells Sy ngenta Crop Protection, Inc. 410 Swing Road, P.O. Box 18300 Greensboro, NC 27419

- 8300 Phone: (336) 632

- 6324 Email: jerry .wells@sy

ngenta.com

1 EPA did not receive any responses to the consultation questionsPage **2** of **3 EPA Consultation Questionnaire for**  **the EUP**  **s for Pesticides ICR**  **1) Publicly Available Data**  i. Is the data that the Agency seeks available from any public source, or already collected by another office at EPA or by another agency ? ii. If yes, where can you find the data? (Does y our answer indicate a true duplication, or does the input indicate that certain data elements are available, but that they don’t meet our data needs very

well?) **2) Frequency of Collection**  C an the Agency

collect the information less frequently and still produce the same outcome? **3) Clarity of Instructions**  i. The I CR is intended to require that respondents provide certain data so that the Agency can utilize them. a) Based on the instructions (regulations, PR Notices, etc.), is it clear what yo u are required to do and how to submit such data? b) If not, what suggestions do y ou have to clarify the instructions? ii. Do y ou understand that you are required to maintain records? iii. Considering that there is no required submission format, is it difficult to submit information in way s that are clear, logical and easy to complete? iv. Regarding the an y [specific program] forms, do you use them? Are they clear, logical, and eas y to complete? **4) Electronic Reporting and Record keeping**  The Government Paperwork Elimi nation Act requires agencies make available to the public electronic reporting alternatives to paper

- based submissions by 2003, unless there is a strong reason for not doing so. One such reason is that, at the present time, the Agency is unable to ensure the securit y of CBI that might be transmitted over the Internet. i. What do y ou think about electronic alternatives to paper

- based records and data submissions? Current electronic reporting alternatives include the use of “web forms”/XML based submissions via the Agency ’s Internet site and magnetic media

- based submissions , e.g., diskette, CD

- ROM, etc. Would y ou be interested in pursuing electronic reporting?Page **3** of **3**

A re you keeping your records electronically ? If ye s, in what format? ii. Although the Agency does not offer an electronic reporting option because of CBI

- related securit y concerns at this time a) w ould y ou be more inclined to submit CBIon diskette than on paper? b) what benefits would electronic submission bring you in terms of burden reduction or greater efficiency

in compiling the information? 5) **Burden and Costs** i. Are the labor rates accurate? ii. The Agency

assumes there is no capital cost associated with this activity . Is that correct? iii. Bearing in mind that the burden and cost estimates include only burden hours and costs associated with the paperwork involved with thi s ICR, e.g., the ICR does not include estimated burden hours and costs for conducting studies, are the estimated burden hours and labor rates accurate? If you provide burden and cost estimates that are substantially different from EPA’s, please provide an explanation of how y ou arrived at y our estimates. iv. Are there other costs that should be accounted for that may have been missed?