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 t hat 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 sugges tions 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 th e 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?

• W hat 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 h ours 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 sugges tions do you have to clarify the instructions? yes

• Do you understand that you are required to maintain records? yesEPA 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 repo rting 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 r ecords 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 e lectronic 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 do es 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? noEPA 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 fro m 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 sugges tions 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?

- YesEPA 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 repo rting 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 rec ords 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 pr ovide 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