2415.03 Attachment D

Docket ID: EPA-HQ-OPP-2016-0078

ATTACHMENT D

OMB Control No.: 2070-0188
EPA ICR No.: 2415.03

Record of Consultations between the U.S. Environmental Protection Agency and
Respondents to the Information Collection Request:
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Docket ID: EPA-HQ-OPP-2016-0078

**

ATTACHMENT D

OMB Control No.: 2070-0188
EPA ICR No.: 2415.03

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(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, some of the information is available at the state or local level but this is the
only national survey.

$

(2)

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?)

Frequency of Collection
$

Can the Agency collect the information less frequently and still produce the same
outcome?
No, due to the changing nature of mosquito-borne disease and mosquito control
techniques an annual update is appropriate.

(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. Currently, we are unable to use forms and submit an annual written report.
We rely on feedback from our liaison if more information is required.

$

Do you understand that you are required to maintain records?

$

Yes.

$

Considering that there is no required submission format, is it difficult to submit
information in ways that are clear, logical and easy to complete?

$

We use a past report for our format, but it is difficult to know what might be
meaningful to the EPA.

$

Are there forms associated with this process? Do you use them? Are they clear,
logical, and easy to complete?

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Docket ID: EPA-HQ-OPP-2016-0078

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(4)

ATTACHMENT D

OMB Control No.: 2070-0188
EPA ICR No.: 2415.03

Not at this time. We have developed forms for our members to complete when
compiling the data.

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.
$

$
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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, in an Excel spreadsheets and Access database.

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?

Yes. This would simplify the process. Currently we are sending reports as an
attachment to an email.
$
$
what benefits would electronic submission bring you in terms of burden reduction
or greater efficiency in compiling the information?
Reporting would be straight- orward and standardized across the membership.
(5)

Burden and Costs
$
$

$

Are the labor rates accurate? ??
The Agency assumes there is no capital cost associated with this activity. Is that
correct?
Yes, to date.
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.

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OMB Control No.: 2070-0188
Docket ID: EPA-HQ-OPP-2016-0078

ATTACHMENT D

EPA ICR No.: 2415.03

I have not seen estimates, but it takes our members time to compile their data for
our annual survey and then it takes me about one day to put everything together for
submission.
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Are there other costs that should be accounted for that may have been missed?

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Docket ID: EPA-HQ-OPP-2016-0078

B.
From:
To:
Subject:
Date:
Attachments:

ATTACHMENT D

OMB Control No.: 2070-0188
EPA ICR No.: 2451.03

Responses from Rollins, Inc.

Negash, Lily
Tanner, Lee
Consultations Responses from Rollins, Inc.
Wednesday, August 10, 2016 6:06:00 PM
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Hi Lee,
This response from Rollins, Inc., below will be posted to the docket in PDF format.
Lily G. Negash
Coordinator: GHS, NEPA
U.S. Environmental Protection Agency
Mailcode 7506P - 1200 Pennsylvania Ave., N.W., Washington, DC 20460
Phone: 703-347-8515 | negash.lily@epa.gov
__________________________________

Click to Find the Insect Repellent that is Right for You.

From: Kim Kelley Tunis [mailto:kkelley@rollins.com]
Sent: Tuesday, July 26, 2016 3:41 PM
To: Tanner, Lee
Cc: Wayne Golden
Subject: FW: 30 days to complete the PESP Survey - White House Renewal - Can you help?
Lee,
Please see my responses below.  Please, let me know if you have any questions or would like to
discuss further.
Thanks!
Kim
Kim Kelley-Tunis | Director, Quality Assurance and Claims
2170 Piedmont Road, N.E.
Atlanta, GA 30324
Phone 404.877.4593 Fax 404.877.4454 Cell 919.601.4773

P Please consider the environment before printing this email.
From: Kim Kelley Tunis
Sent: Monday, May 02, 2016 3:38 PM
To: Wayne Golden
Subject: RE: 30 days to complete the PESP Survey - White House Renewal - Can you help?

Docket ID: EPA-HQ-OPP-2016-0078

ATTACHMENT D

OMB Control No.: 2070-0188
EPA ICR No.: 2451.03

Wayne,
Below are my notes regarding the documents you provided.  I know that this is very wordy, but I
wanted to be thorough.  I understand what the purpose of these document are, but quantifying IPM
through product application rates and customer service records is only capturing a small piece of
the picture.  The other problem, technology has not caught up with the industry, allowing us to
capture the specifics of any given service.   With that being said, some of the information that they
are requesting for collection may be incredibly difficult to collect, especially for larger companies
with multiple locations.   
Document 2016_ICR_PESP_Supplement_Draft:
· First page – environmental should be corrected to say environment
· First page, last two sentences - IPM is defined as a more economical method for pest
control.  As we know, that is not the case.  It also states that IPM results in the least
hazardous control methods, this too is not always accurate.  They may want to look up the
formal definition of IPM and go with a more clinical definition that is void of opinion
· Page 2, second paragraph – the last sentence implies that reduced pesticide use will reduce
all risks in both agricultural and non-agricultural settings.  They may want to be more clear
as to the types of risks (pesticide exposure)
· There are also several areas within the document that should be rewritten to provide
greater clarity on the objectives and scope of the program
Document EPA-HQ-Opp-2016-0078-003 (PESP Strategy / Progress Reporting Form
Some of the information required for submission may be difficult to provide by larger companies and
requires greater clarification
· Organizational Profile Measures
o Total Accounts under Management
§ Should these account be broken out by service type – Residential, Commercial,
or both
·

Depending upon which account types, this number could greatly
skew the data

§ Does this number only represent number of active accounts at time of
reporting – one-time service or ongoing service
o Total Service Calls
§ This goes back to the previous bullet point of one-time or ongoing service –
These numbers may be vastly different at the time of reporting if a company
is only reporting ongoing service
·

Measures Reporting – Organizational Profile Measures
o Total acres under IPM
§ If a company is following an IPM program, all locations serviced would need to
be measured.  This information is rarely collected, and when it is, it is

Docket ID: EPA-HQ-OPP-2016-0078

ATTACHMENT D

OMB Control No.: 2070-0188
EPA ICR No.: 2451.03

primarily for larger commercial accounts.  The total number of acres treated
would only really be relevant in an agricultural setting or if lawn care is the
primary control method being practiced.  This would not be a big issue for
commercial pest control companies that are limited in their exterior
treatment within 6’ of the immediate perimeter of the structure
o Total accounts under IPM
§ Unless IPM has a different definition with the PESP program, this number
should be the same as the Total Accounts Managed
o Total Service Call-backs
§ Need greater clarity as to what type of account is being serviced to determine
which calls constitute a call-back
o Total Non-Chemical Treatments only
§ This may be extremely difficult to quantify since all customer visits generate a
service ticket.  This particular piece of data may only be able to be
quantified by reviewing every ticket that has been completed to determine
whether a product was used during the service
o Use of Spot Treatments
§ This may be a question that can be omitted.  Based on most label’s current
language, the majority of applications made are either going to be a spot or
crack and crevice application
o Formal sanitation / housekeeping protocols in place?
§ This should be changed to read that “Customer provided with pest specific
sanitation / housekeeping protocols.”  How do you ask a residential
customer to implement a formal sanitation protocol?
·

Pesticide Risk Reduction and Usage
o Total amount of pesticides applied or purchased
§ Purchasing numbers are probably easier for a larger company to provide.
However, providing the complete list of products purchased may also
become somewhat cumbersome, especially when you start pulling in all
one-time purchases that may be very situational
o Total service calls using Biopesticides
§ It may be best to rely on the purchase data provided above, and just identify
which of the products are biopesticides.  Identifying which accounts have
had a service utilizing biopesticides may be extremely difficult
o Total service calls using no pesticides
§ This, is some regards is a duplicate of the question within “Measures Reporting
– Organizational Profile Measures”.  What is the definition of pesticide?
Does the application of a 25b product fall within this category or the
previous?

·

Measures Reporting – IPM / PESP Education and Reporting
o In general, providing the numbers requested in the survey is doable, but difficult for

Docket ID: EPA-HQ-OPP-2016-0078

ATTACHMENT D

OMB Control No.: 2070-0188
EPA ICR No.: 2451.03

larger companies.  It is relatively easy to provide those hours where training events
are provided by the “corporate” office.  But when training opportunities are
provided on the local level, this becomes very difficult to quantify.  This is also the
case for training provided to customers.  IT becomes very difficult to provide a
number to all those customers that have received training.
o Total customers following IPM guidance
§ This is a very subjective number.  When things within an account are going
well, respondents will say their participation is 100%, but when things are
going poorly, compliance will be 0%.  J

Kim Kelley-Tunis
Director, Quality Assurance and Claims
Rollins