Attachment E: EPA response to CSPA comment on proposed ICR

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UNITED STATES ENV IRONMENTAL PROTECTION
AGENCY
WASHINGTON, D .C. 20460

Ms Brigid D. Klein

OFFICE OF
PREVENTION, PESTICIDES AND
TOXIC SUBSTANCES

Vice President and General Counsel
Consumer Specialty Products Association
90017 t" Street, NW, Suite 300
Washington, DC 20006

Dear Ms. Klein :
Thank you for your comments on the proposed
Information Collection Request
(ICR) "Use of Consumer Research in Developing
Improved Labeling for Pesticides"
(EPA ICR No. 2297 .01, OMB Control No.
2070-new).
An ICR is a set of documents that describe
reporting, record keeping, survey, or
other information collection requirements imposed
on the public by the Environmental
Protection Agency or any other federal agency . It
also estimates the cost and time for the
public to respond . The ICR is a mechanism to
approve the collection of information and
to detail the estimated burden, not the
actual means to do the research . For this reason,
the request for comment on this ICR focused
on cost and burden estimates . The
comments submitted by CSPA on behalf of the DEET
Task Force (DTF) were related to
the ultimate research EPA might do under the
ICR, in addition to related EPA insect
repellent projects. Therefore, your comments
will not be addressed when the ICR is
published .
However, I wanted to assure you that we received,
read, and considered your
input on our ongoing projects . EPA appreciates
the DTF support for the objectives
outlined in the proposed ICR and values private and
public sector cooperation, especially
in the area of pesticide labeling. With respect
to the DTF comment related to stakeholder
participation in the design of the consumer surveys,
EPA plans to conduct stakeholder
consultations with public and private sector stakeholders
during the design of the surveys .
The DTF recommendation for a three-tiered
research program (exploratory phase,
propose labeling and refinement phase, and
implementation phrase) clearly reflects DTF
experience with consumer research . We look
forward to working with the DTF and other
stakeholders to use that expertise to its fullest extent .
EPA will continue open communication with
DTF regarding the finalization of
the Agency's efficacy testing guidelines for
repellents, any potential actions related to the
FIFRA 25(b) exemption, and our consideration
of protection times on product labeling.

Internet.Address (URL) 0 http ://www .epa .gov
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EPA strongly believes that all of these related
initiatives will have a positive
impact on public health . EPA looks forward to the
continued dialogue with DTF in
pursuing this shared public health goal .
Sincerely,

Debra Edwards, Ph .D ., Director
Office of Pesticide Programs