Attachment F_Calculations Regarding Small Entities

Attachment F
Calculations Regarding Small Entities that Participate in this ICR
EPA estimated the number of small entities that participate under this ICR using information on
company revenue and employment from Dun and Bradstreet database reported for the year 2010.
The Dun and Bradstreet database is a comprehensive source of financial information on entities,
including firm locations, sales, number of employees, and primary business classifications under
North American Industrial Classification System code (NAICS). EPA assumed the majority of
respondents are individual companies with a NAICS code 325320 (Pesticide and Other
Agricultural Chemical Manufacturing).
The number of companies in the Dun and Bradstreet 2010 database using this code was 892.
EPA was able to determine the size of 882 of these individual companies. The parent company
of the 10 remaining un-sized companies did not report enough sales or employee data to allow a
proper analysis based on the SBA size classifications. Of the sized firms, 26.3% (232) are large
firms or are subsidiaries of large firms, and 73.7% (650) are small firms or subsidiaries of small
firms. Currently, 1733 companies are listed in EPA’s registration tracking database discussed in
section 5(b). Assuming that the distribution of large and small firms is independent of NAICS
code, EPA estimates that there are 456 (26.3% of 1733) large firms and 1277 (73.7 % of 1733)
small firms that are potential respondents to this ICR.
EPA also estimated the impact of this ICR on small entities by calculating the annual company
burden as a percentage of average annual revenue. Child Resistant Packaging applications were
submitted to the Agency by 49 parent firms between 2006 and 2009. EPA determined that 27 of
the submitting companies were large and 21 were small based on information from the Dun and
Bradstreet 2010 database. Table F.1 exhibits list of small entities that submitted CRP
applications between 2006 and 2009. Companies are listed at the parent level. The table includes
company NAICS code, annual sales, employment, US Small Business Administration (SBA)
small business definition, and SBA size threshold. EPA was unable to size one company.

Table F.1
Parent Company
Alden - Leeds, Inc.
American Vanguard
Corporation
Aqua Tri

NAICS
Code
325998

Annual
Sales ($)

Employees
75

SBA
Definition1
E

SBA Size
Threshold1
500

325320

237,538,000

320

E

500

424690

2,000,000

24

E

100

561710

130,000

3

R

6,000,000

Bonide Products, Inc.

325998

35,700,000

200

E

500

Bug Stompers Inc
Clarke Mosquito Control
Products, Inc.Control Solutions, Inc.

561710

200,000

3

R

6,000,000

325320

35,000,000

40

E

500

50

E

500

Db Square LLC

561990

2

R

6,000,000

Biosensory Insect Control

325320
100,000

Envirosafe Technologies, Inc.

334112

2,200,000

18

E

1,000

Gil Manufacturing Inc

453998

1,100,000

11

R

6,000,000

Haco Group Inc
McLaughlin Gormley King
Company
Pbi/Gordon Corporation

423610

250,000

2

E

100

325320

1,000,000

90

E

500

325320

300

E

500

Pic Corporation (inc)

325320

5,400,000

30

E

500

Porpoise Pool & Patio, Inc.

533110

1,000,000

280

R

6,000,000

Share Corporation

325612

16,900,000

172

E

500

Southeast Laboratories, Inc.
Spurrier Chemical Companies,
Inc.
Vertex Chemical Corp

335314

250,000

3

E

750

325199

20,900,000

67

E

1,000

325188

52,000,000

45

E

1,000

Vetsource, Inc.

423390

3,000,000

2

E

100

1. An “E” indicates that the SBA small business definition is based on employment and an “R”
indicates that the SBA small business definition is based on revenue from annual sales.
Definitions and SBA size thresholds are based on the US Small Business Administration’s 2008
“Table of Small Business Size Standards Matched to North American Industry Classification
System Codes” available online at:
http://www.sba.gov/idc/groups/public/documents/sba_homepage/serv_sstd_tablepdf.pdf
Table F.2 below presents the total and average revenue and employment for small companies,
large companies, and all companies combined. As shown below in Section 6, the burden cost per
CRP submission is estimated to be approximately $439 (Table 2, section 6). Assuming that CRP
submissions are evenly distributed across small and large companies, an average firm would
submit approximately 14 CRP applications per year, assuming 50 companies are responsible for
the 685 (see Table 1, section 6) CRP submissions in a given year. This would result in an
average annual company burden of $6,146, or 0.03% of small firm’s annual revenue, on average.
Table F.2
Total
Number
of Firms

Total Revenue
($)

Total
Employee
Size

Average Revenue1 Average
($)
Employment1

Small Firms

21

414,668,000

1,737

23,037,111

73

Large Firms

27

312,730,280,167

598,975

12,028,087,699

23,031

All Firms
48
313,144,948,167
1
Only based on firms that report sales on D&B.

600,712

7,116,930,640

13,639