Consultation Responses

Responses:
V. Goncarovs
Research International
Regulatory Consultants
P.O. Box 15125
Arlington, VA 22215
(703) 920-6773

regulatory@consultant.com
1.

Not aware of any other public source other than the EPA Website.

2.

The instructions are very clear on what to do and how to submit the form.

3.

Yes, very clear

4.

Yes - believe this is a very good idea. Currently not using any type of electronic
reporting/recording options.

5.

Yes, some type of security measure should be in place.

6.

Whatever is easiest for the Agency

7.

There is no CBI information submitted in supplemental distributor forms. However,
would be even more inclined if there was the allowance to submit the form to the Agency
as a PDF attachment via email.

8.

Yes, that is about the average cost.

9.

No, could not think of any other costs that should be accounted for that may have been
missed, and burden and cost substantially the same as EPA’s.

Christina Swick
Lewis & Harrison
122 C St., NW, Suite 740
Washington, DC 20001
(202) 393-3903
wmccombie@lewisharrison.com
Response: “I’ve reviewed the ICR Renewal for notification of supplemental registration and
concur with the information provided by Wendy McCombie in 2003 and have no further
comments at this time.”
Wendy McCombie consultation response for 2003:
1.

No - download it from EPA’s website

2.

The instructions are very clear on what to do and how to submit the form.

3.

Same as answer to question 2.

4.

Yes - believe this is a very good idea. Currently not using any type of electronic
reporting/recording options.

5.

Would prefer passwords if submitting electronic signatures

6.

It doesn’t matter.

7.

There is no CBI information submitted in supplemental distributor forms

8.

Yes, I think that would be about average.

9.

No, could not think of any other costs that should be accounted for that may have been
missed, and our burden and costs are substantially the same as EPA’s.

Kim Davis
RegWest Company, LLC
30856 Rocky Road
Greeley, CO 80631
(970) 353-0611
kim@regwest.com
1.

Still download from EPA pesticides website.

2.

I suggest that the submission address be provided somewhere in the form; I suggest this
information be placed in the “Instructions” section, immediately after “This Notice of
Supplemental Distribution must be submitted by the basic registrant.” Otherwise, the
instructions are clear overall.

3.

Yes, the form is clear, logical and easy to complete.

4.

Yes, I would be interested in submitting the form electronically. It is very simple these
days to scan documents and email them. Sending the completed form in pdf format would
save courier expenses and speed up the signature and submission processes.

5.

I have no security concerns about signatures. It is pretty standard practice nowadays to
email as much as possible, including signed documents.

6.

Once again, I have no security concerns regarding signed documents or signatures.

7.

There is no CBI presented on this form.

8.

The burden rate (approximately 15 minutes) is a good estimate.

9.

No other costs are associated with the preparation of this form.