Foreign Purchaser Acknowledgment Statement of Unregistered Pesticides

Forms and Documents

Document Name	Status
0161.14 SS_Attachment F_2018-10-29.docx Supplementary Document	2019-03-12
0161.14 SS_Attachment E_2018-10-29.docx Supplementary Document	2019-03-12
0161.14 SS_Attachment D_2018-10-29.docx Supplementary Document	2019-03-12
0161.14 SS_Attachment C_2018-10-29.docx Supplementary Document	2019-03-12
0161.14 SS_Attachment B_2018-10-29.pdf Supplementary Document	2019-03-12
0161.14 SS_Attachment A_2018-10-29.pdf Supplementary Document	2019-03-12
0161ss14.docx Supporting Statement A	2019-03-12

IC Document Collections

IC ID	Document Title	Status
24862	Foreign Purchaser Acknowledgment Statement of Unregistered Pesticides	Modified
187532	Multilingual Product Labeling for Registered Exported Pesticide Products	Modified
187531	Labeling for Unregistered Exported Pesticide Products	Modified

ICR Details

OMB Control No: 2070-0027	ICR Reference No: 201903-2070-002
Status: Active	Previous ICR Reference No: 201511-2070-001
Agency/Subagency: EPA/OCSPP	Agency Tracking No: 0161.14
Title: Foreign Purchaser Acknowledgment Statement of Unregistered Pesticides
Type of Information Collection: Revision of a currently approved collection	Common Form ICR:  No
Type of Review Request: Regular
OIRA Conclusion Action: Approved without change	Conclusion Date: 12/04/2019
	Date Received in OIRA: 03/26/2019
Terms of Clearance:

	Inventory as of this Action	Requested	Previously Approved
Expiration Date	12/31/2022	36 Months From Approved	12/31/2019
Responses	5,134	0	5,435
Time Burden (Hours)	16,660	0	17,993
Cost Burden (Dollars)	0	0	0

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Abstract: This ICR fulfills the statutory mandates in section 17 of the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA). Specifically, the information collection activities covered by this ICR enables EPA to provide notice to foreign purchasers of unregistered pesticides exported from the US that the pesticide product cannot be sold in the US. FIFRA section 17(a)(2) requires an exporter of any pesticide not registered under FIFRA section 3 or sold under FIFRA section 6(a)(1) to obtain a signed statement from the foreign purchaser acknowledging that that purchaser is aware that the pesticide is not registered for use in, and cannot be sold in, the United States. A copy of this statement must be transmitted to an appropriate official of the government in the importing country. This ICR also includes the burden imposed by export labeling requirements, which meet the definitions of third-pary disclosure. In addition to the export notification for unregistered pesticides, FIFRA requires that all pesticides include appropriate labeling. There are different requirements for registered and unregistered products. This information collection has been constant since implementation of the 1993 pesticide export policy governing the export of pesticides, devices, and active ingredients used in producing pesticides.

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Authorizing Statute(s): US Code: 7 USC 136o Name of Law: Section 17 of the Federal Insecticide, Fungicide, and Rodenticide Act
  

Citations for New Statutory Requirements: None

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Associated Rulemaking Information
RIN:	Stage of Rulemaking:	Federal Register Citation:	Date:
	Not associated with rulemaking

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Federal Register Notices & Comments
60-day Notice:	Federal Register Citation:	Citation Date:
	83 FR 35273	07/25/2018
30-day Notice:	Federal Register Citation:	Citation Date:
	84 FR 11296	03/26/2019
Did the Agency receive public comments on this ICR? Yes

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Number of Information Collection (IC) in this ICR: 3

IC Title	Form No.	Form Name
Foreign Purchaser Acknowledgment Statement of Unregistered Pesticides
Labeling for Unregistered Exported Pesticide Products
Multilingual Product Labeling for Registered Exported Pesticide Products

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ICR Summary of Burden

	Total Approved	Previously Approved	Change Due to New Statute	Change Due to Agency Discretion	Change Due to Adjustment in Estimate	Change Due to Potential Violation of the PRA
Annual Number of Responses	5,134	5,435	0	0	-301	0
Annual Time Burden (Hours)	16,660	17,993	0	0	-1,333	0
Annual Cost Burden (Dollars)	0	0	0	0	0	0

Burden increases because of Program Change due to Agency Discretion: No

Burden Increase Due to:

Burden decreases because of Program Change due to Agency Discretion: No

Burden Reduction Due to:

Short Statement: There was no change in the estimated average response time for respondents. There is a decrease of 1,333 hours in the total estimated respondent burden compared with the ICR currently approved by OMB. This decrease reflects a reduction in the annual number of foreign purchaser acknowledgment statements received by EPA (from 3,024 to 2,774), which resulted in a corresponding decrease in the estimated annual burden hours for respondents (from 3,205 to 2,940 hours); and a reduction in the estimated annual burden associated with labeling requirements. The respondent burden associated with labeling requirements for unregistered exported pesticides decreased from 4,888 to 4,480 hours; and from 9,900 to 9,240 hours associated with labeling requirements for registered exported pesticides. The decrease in burden associated with labeling requirements is due to a reduction in the number of respondents per calendar years 2015-2017. Total labor costs for respondents decreased due to a decrease in the estimated number of respondents per calendar year from 2015-2017 and an update to the wage rate estimates, which incorporated higher estimates for benefits than was used in the previous renewal. These changes qualify as adjustments. There were program changes affecting the Agency burden estimate. There is an increase of 421 hours in the total estimated Agency burden compared with that identified in the ICR currently approved by OMB. The total Agency burden increased due to an increase in the EPA estimated hourly burden from 0.17 hours (around 10 minutes) per statement to 0.33 hours (around 20 minutes) per statement. This increase is due to processes added to ensure proper review of FPAS statements before being sent to the importing country. There has also been a change in the system used and steps for storing digital copies of the FPAS. Total labor costs for the Agency also increased due to changes in the wage rates made to reflect current wage rates. The new wage estimates incorporated higher estimates for benefits than was used in the previous renewal. These changes are an adjustment.

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Annual Cost to Federal Government: $78,932

Does this IC contain surveys, censuses, or employ statistical methods? No

Does this ICR request any personally identifiable information (see OMB Circular No. A-130 for an explanation of this term)? Please consult with your agency's privacy program when making this determination.     No

Does this ICR include a form that requires a Privacy Act Statement (see 5 U.S.C. §552a(e)(3))? Please consult with your agency's privacy program when making this determination.     No

Is this ICR related to the Affordable Care Act [Pub. L. 111-148 & 111-152]? No

Is this ICR related to the Dodd-Frank Wall Street Reform and Consumer Protection Act, [Pub. L. 111-203]? No

Is this ICR related to the American Recovery and Reinvestment Act of 2009 (ARRA)? No

Is this ICR related to the Pandemic Response? Uncollected

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Common Form ICR:  No

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On behalf of this Federal agency, I certify that the collection of information encompassed by this request complies with 5 CFR 1320.9 and the related provisions of 5 CFR 1320.8(b)(3).

The following is a summary of the topics, regarding the proposed collection of information, that the certification covers:

(a) It is necessary for the proper performance of agency functions;

(b) It avoids unnecessary duplication;

(c) It reduces burden on small entities;

(d) It uses plain, coherent, and unambiguous language that is understandable to respondents;

(e) Its implementation will be consistent and compatible with current reporting and recordkeeping practices;

(f) It indicates the retention periods for recordkeeping requirements;

(g) It informs respondents of the information called for under 5 CFR 1320.8 (b)(3) about:

(i) Why the information is being collected;

(ii) Use of information;

(iii) Burden estimate;

(iv) Nature of response (voluntary, required for a benefit, or mandatory);

(v) Nature and extent of confidentiality; and

(vi) Need to display currently valid OMB control number;

(h) It was developed by an office that has planned and allocated resources for the efficient and effective management and use of the information to be collected.

(i) It uses effective and efficient statistical survey methodology (if applicable); and

(j) It makes appropriate use of information technology.

If you are unable to certify compliance with any of these provisions, identify the item by leaving the box unchecked and explain the reason in the Supporting Statement.

Certification Date: 03/26/2019

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