EPA ICR No. 0278.11 OMB Control No. 2070-0044

Docket ID EPA-HQ-OPP-2012-0544 

ATTACHMENT D

Consultation Questions Regarding an Information Collection Activity:

Notice of Supplemental Distribution of a Registered Pesticide Product

U.S. Environmental Protection Agency

Distributor Company Representative(s) Consulted

Elizabeth Tannehill

Mason Chemical Company

liz@maquat.com

Zofia C. Schmidt

Buckman Laboratories, Inc. (1448)

zcschmidt@buckman.com

I. EPA Questions Asked in Consultation Regarding ICR the Document

(1) Publicly Available Data

• Is the data that the Agency seeks available from any public source, or already 

collected by another office at EPA or by another agency?

• If yes, where can you find the data? (Does your 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

• Can the Agency collect the information less frequently and still produce the same 

outcome? 

(3) Clarity of Instructions

 

• The ICR is intended to require that respondents provide certain data so that the 

Agency can utilize them. 

• Based on the instructions (regulations, PR Notices, etc.), is it clear what you are 

required to do and how to submit such data? If not, what suggestions do you have 

to clarify the instructions?
EPA ICR No. 0278.11 OMB Control No. 2070-0044

Docket ID EPA-HQ-OPP-2012-0544 

• Do you understand that you are required to maintain records? 

• Are there forms associated with this process? Do you use them? Are they clear, 

logical, and easy to complete?

(4) Electronic Reporting and Record keeping

The Government Paperwork Elimination 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 security of CBI that might be transmitted over the 

Internet.

• What do you 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 you be interested 

in pursuing electronic reporting? 

• Are you keeping your records electronically? If yes, in what format?

• Although the Agency does not offer an electronic reporting option because of 

CBI-related security concerns at this time, would you be more inclined to submit 

CBI on diskette (CD or DVD) than on paper? 

• What benefits would electronic submission bring you in terms of burden 

reduction or greater efficiency in compiling the information?

 

(5) Burden and Costs

• Are the labor rates accurate? 

• The Agency assumes there is no capital cost associated with this activity. Is that 

correct? 

• Bearing in mind that the burden and cost estimates include only burden hours and 

costs associated with the paperwork involved with this 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 

you arrived at your estimates.

• Are there other costs that should be accounted for that may have been missed?
EPA ICR No. 0278.11 OMB Control No. 2070-0044

Docket ID EPA-HQ-OPP-2012-0544 

II. Consultations Responses

Response 1

EPA/OPP ICR – Notice of Supplemental Distribution of a Registered Pesticide Product

U.S. Environmental Protection Agency

Contact Information

Elizabeth Tannehill

Mason Chemical Company

liz@maquat.com

Questions and responses regarding ICR document

(1) Publicly Available Data

• Is the data that the Agency seeks available from any public source, or already 

collected by another office at EPA or by another agency?yes

• If yes, where can you find the data? (Does your 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?) on the state level

(2) Frequency of Collection 

• Can the Agency collect the information less frequently and still produce the same 

outcome? If the agency coordinated with state data then agency would not need to 

collect information

(3) Clarity of Instructions 

The ICR is intended to require that respondents provide certain data so that the Agency 

can utilize them. 

• Based on the instructions (regulations, PR Notices, etc.), is it clear what you are 

required to do and how to submit such data? If not, what suggestions do you have 

to clarify the instructions?yes

• Do you understand that you are required to maintain records? yes
EPA ICR No. 0278.11 OMB Control No. 2070-0044

Docket ID EPA-HQ-OPP-2012-0544 

• Are there forms associated with this process? Do you use them? Are they clear, 

logical, and easy to complete?yes

(4) Electronic Reporting and Record keeping 

The Government Paperwork Elimination 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 security of CBI that might be transmitted over the 

Internet.

• What do you 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 you be interested 

in pursuing electronic reporting?yes

 

• Are you keeping your records electronically? If yes, in what format?yes -

scanned

• Although the Agency does not offer an electronic reporting option because of 

CBI-related security concerns at this time, would you be more inclined to submit 

CBI on diskette (CD or DVD) than on paper? No – rather submit via internet

• What benefits would electronic submission bring you in terms of burden 

reduction or greater efficiency in compiling the information? Would cut down 

time spent filling out forms

(5) Burden and Costs

• Are the labor rates accurate?yes

• The Agency assumes there is no capital cost associated with this activity. Is that 

correct? yes

• Bearing in mind that the burden and cost estimates include only burden hours and 

costs associated with the paperwork involved with this 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 you arrived at your estimates.

• Are there other costs that should be accounted for that may have been missed?no
EPA ICR No. 0278.11 OMB Control No. 2070-0044

Docket ID EPA-HQ-OPP-2012-0544 

Response 2

EPA/OPP ICR – Notice of Supplemental Distribution of a Registered Pesticide Product

U.S. Environmental Protection Agency

Contact Information

Zofia C. Schmidt 

Buckman Laboratories, Inc. (1448)

zcschmidt@buckman.com

Questions and responses regarding ICR document

(1) Publicly Available Data

• Is the data that the Agency seeks available from any public source, or already 

collected by another office at EPA or by another agency?

- NO

• If yes, where can you find the data? (Does your 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 

• Can the Agency collect the information less frequently and still produce the same 

outcome? 

- Unsure

(3) Clarity of Instructions 

The ICR is intended to require that respondents provide certain data so that the Agency 

can utilize them. 

• Based on the instructions (regulations, PR Notices, etc.), is it clear what you are 

required to do and how to submit such data? If not, what suggestions do you have 

to clarify the instructions?

- Yes

• Do you understand that you are required to maintain records? 

- Yes 

• Are there forms associated with this process? Do you use them? Are they clear, 

logical, and easy to complete?

- Yes
EPA ICR No. 0278.11 OMB Control No. 2070-0044

Docket ID EPA-HQ-OPP-2012-0544 

(4) Electronic Reporting and Record keeping 

The Government Paperwork Elimination 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 security of CBI that might be transmitted over the 

Internet.

• What do you 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 you be interested 

in pursuing electronic reporting?

- Yes

• Are you keeping your records electronically? If yes, in what format?

• Although the Agency does not offer an electronic reporting option because of 

CBI-related security concerns at this time, would you be more inclined to submit 

CBI on diskette (CD or DVD) than on paper? 

- No, because of the volume of documents is relatively small.

• What benefits would electronic submission bring you in terms of burden 

reduction or greater efficiency in compiling the information? 

- May saved time (if direct e-mails)

(5) Burden and Costs

• Are the labor rates accurate?

- Unsure

• The Agency assumes there is no capital cost associated with this activity. Is that 

correct? 

- Yes

• Bearing in mind that the burden and cost estimates include only burden hours and 

costs associated with the paperwork involved with this 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 you arrived at your estimates.

- N/A

• Are there other costs that should be accounted for that may have been missed?

- No