Attachment E

US Environmental Protection Agency
Office of Pesticide Programs
�� Pesticide Registration (PR) Notice 2011-3
Standard Format for Data Submitted Under
the Federal Insecticide, Fungicide, and
Rodenticide Act (FIFRA) and Certain Provisions
of the Federal Food, Drug, and Cosmetic Act (FFDCA)
�
November 30, 2011

Pesticide Registration (PR) Notice 2011-3

Notice To: Manufacturers, Producers, Formulators, Distributors and Registrants
Attention: Persons Responsible for Federal Registration of Pesticides Products
Subject: Standard Format for Data Submitted Under the Federal Insecticide, Fungicide, and
Rodenticide Act (FIFRA) and Certain Provisions of the Federal Food, Drug, and Cosmetic Act
(FFDCA)
I.

PURPOSE AND APPLICABILITY

This PR Notice updates and replaces Pesticide Registration Notice 86-5 and discusses both the
recommended and the required procedures for submitting FIFRA and FFDCA data. All required
procedures contained within this document, generally indicated by use of the word “must,” were
previously made mandatory by statute or regulation; this document creates no new legally
binding requirements. Where indicated by the use of non-mandatory language such as “may,”
“should” and “can,” this document provides recommendations or guidance.
The PR Notice applies to all data that are submitted to EPA to support any application, petition,
or submission intended to persuade EPA to grant, modify or leave unmodified a registration or
other approval required as a condition of sale or distribution of a pesticide. Such submissions
may include, but are not limited to, the following: an application for registration or amended
registration of a pesticide product under FIFRA section 3 or 24; a submission of data required in
conjunction with reregistration of a currently registered product under FIFRA section 4 (or its
registration review under FIFRA section 3); an application for an experimental use permit under
FIFRA section 5; a submission of data in response to a notice issued by EPA under FIFRA
section 3(c)(2)(B); a petition to establish or modify a tolerance or an exemption from the
requirement of a tolerance for a pesticide chemical residue under FFDCA section 408 as well as
studies submitted under FIFRA section 6(a)(2). (See generally, 40 CFR parts 150 – 189;
specifically, 40 CFR parts 158, 160, 161 and 174.)
II.

EFFECTIVE DATE
Effective immediately.

III.

BACKGROUND

PR Notice 86-5 has served as the Office of Pesticide Programs’ (OPP’s) data formatting
guidance since its publication on July 29, 1986. At the time PR Notice 86-5 was originally
issued, the only acceptable medium for data submission was paper. Today, advances in
information technology, statutory and regulatory changes, and new policy initiatives make this
an opportune time to update the guidance. This new guidance gives registrants the option of
submitting electronic submissions and provides a flexible but still acceptable format for data
submission, regardless of the medium in which the data are submitted. Attachment 5 contains a
listing of glossary terms used in this guidance.
1

IV.

OVERVIEW OF CHANGES

The following list is a summary of the changes recommended by this guidance. A more detailed
description of the changes to the guidance is described in sections IV and V.
Electronic submission on CD or DVD is now an option for some types of data
submissions. OPP plans to make this option available to more types of submissions.
Check the e-Submission website
(http://www.epa.gov/pesticides/regulating/registering/submissions/index.htm) for the
latest information.
Since the inception of PR Notice 86-5, Master Record Identifiers (MRIDs) have been
assigned only to data documents that comply with its formatting instructions. One
major process change being planned by OPP is that MRIDs will no longer be
assigned after these documents have been screened. MRIDs are already being preassigned, in the case of electronic submissions. Similarly, MRIDs will be assigned to
all of the data documents in a paper submission prior to our format screening process.
Submitters will continue to be notified if a document does not meet the mandatory
formatting elements.
Currently, three identical copies of all applicable data are required. This applies to
submissions that are entirely paper. Please note that as OPP phases in its up-front
imaging of paper submissions, we expect to reduce this requirement to a single copy.
For the latest information on the status of the up-front imaging effort and number of
copies required please continue to check the e-Submission website
(http://www.epa.gov/pesticides/regulating/registering/submissions/index.htm).
Previous language discouraging double-sided printing and color printing has been
eliminated.
Section G of PRN 86-5, Special Requirements for Submitting Data to the Docket, is
obsolete and has been eliminated.
Information on asserting claims of data confidentiality has been updated in
accordance with the latest edition of 40 CFR sections158, 161 and 174.
The information on flagging of studies for potential adverse effects has been updated
in accordance with the latest edition of 40 CFR sections 158 and 161.
OECD dossier format is an option that did not exist when PRN 86-5 was written.
References to the data requirements for antimicrobial pesticides, which have been
redesignated in new 40 CFR 161, have been inserted as appropriate.

2

V.

RELATIONSHIP OF THIS NOTICE TO OTHER OPP POLICY AND GUIDANCE
FOR SUBMITTING DATA
A. Test reports and study profile templates

This notice contains guidance for organizing and formatting submissions of supporting data but
does not address the substance of test reports themselves. Consult the OPP website at
http://www.epa.gov/pesticides/regulating/studyprofile templates/studyprofile templatelist.htm
for information on study profile templates and at
http://www.epa.gov/ocspp/pubs/frs/home/guidelin.htm for information on harmonized test
guidelines.
B. Adverse effects reporting
Detailed guidance on adverse effects reporting under FIFRA section 6(a)(2) is available at
http://www.epa.gov/pesticides/fifra6a2/.
C. Electronic submissions
At this writing, electronic submission on CD or DVD is an option for some, but not all, types of
data submissions. Electronic submission guidance is available on OPP’s website at
http://www.epa.gov/pesticides/regulating/registering/submissions/index.htm. However, OPP
continues to accept all types of data submissions in paper form.
D. OECD dossier format
There is an alternative to the overall submission format presented in this Notice for submitters
who are planning a multi-national electronic submission on CD or DVD. Information on the
OECD dossier format can be found at http://www.oecd.org. Submitters who use this format
should arrange individual documents as described in this Notice, with the exception of the
placement of any information claimed as confidential. Instead of preparing a confidential
attachment for an individual document, all confidential information should be compiled in
Document J of the dossier.
E. Technical amendments for antimicrobial pesticides, 40 CFR part 161
EPA has redesignated certain pesticide data requirements formerly located in 40 CFR 158 into a
new part 161. The data requirements that have been transferred apply to antimicrobial
pesticides. EPA has made conforming changes and cross-reference revisions to the redesignated material, including re-designation of 40 CFR part 158.32, 158.33, and 158.34 as
161.32, 161.33 and 161.34, respectively. These technical amendments, published in the Federal
Register on October 24, 2007, (72 FR 60251) preserve the original data requirements for use
with antimicrobial pesticides until such time as a final rule for antimicrobial pesticides can be
promulgated and made effective.
F. Clarification of plant-incorporated protectants data submissions
3

The characteristics of plant-incorporated protectants (PIPs), such as their production and use in
plants, their biological properties, and their ability to spread and increase in quantity in the
environment, distinguish them from traditional chemical pesticides. Therefore, PIPs are subject
to different regulatory requirements and procedures than traditional chemical pesticides. 40 CFR
174 sets forth regulatory requirements, criteria, and procedures applicable to PIPs under FIFRA
and FFDCA. When applied to PIPs, the definitions and regulations in 40 CFR 174 supersede the
regulations found in 40 CFR parts 150 through 180 to the extent that the regulations conflict.
VI.

FORMAT

A submission consists of all the documents sent to OPP at the same time in support of a single
regulatory action or a group of related actions, such as a product amendment and a related
tolerance petition. The documents should be accompanied by a transmittal document and related
administrative material (e.g., EPA Forms 8570-1, 8570-4, etc.) as appropriate. For actions
subject to a registration service fee (see FIFRA section 33), failure to comply with this guidance
may result in rejection of the action during the 21-day completeness screening. This transmittal
document and administrative material should be grouped together in the first physical volume if
the submission is on paper. Consult the e-submission XML guidance document at
http://www.epa.gov/pesticides/regulating/registering/submissions/XMLsubmissions/esubmission xml guidance document v1.pdf for specific information on the format of these
documents as files on a CD/DVD.
A detailed discussion of format elements appears below and samples of some of the elements are
attached. Except for the language of the two alternative forms of the Statement of Data
Confidentiality that can not be altered (see 40 CFR 158.33), these samples are illustrative. As
long as the required information is included and clearly identifiable, then the form of the samples
may be altered to reflect the submitter’s preference.
A. Organization of the data submission package
The following physical format guidance applies to the transmittal document and data documents
in a paper data submission. Consistency of electronic data submissions with the data
submission requirements cited in this notice will be verified electronically.
8.5 x 11-inch white paper
High contrast and good resolution
Easily removable bindings*
Pages in good condition
No fold-out or oversize pages
All pages present, consecutively paginated and in the correct order
Double-sided printing acceptable, color printing acceptable
*Two examples of adequate binding are: 1) a staple in the upper-left corner of a small document
or 2) plastic covers held together by two metal prongs. Transparent covers are preferred. Threering binders are discouraged.
4

B. Transmittal Document (Sample provided in Attachment 1)
The transmittal document is the first item in each submission. This document discusses basic
information-- i.e., who is submitting the information, what regulatory actions are involved, the
date of transmittal, a list of documents in the package and the contact information. Specifically,
this document identifies:
the submitting company’s name and address, its EPA-assigned company number(s) if
one has been previously assigned, and contact information, preferably including fax
number and email address in addition to name and phone number and the regulatory
or other action(s) identified by EPA-assigned number (such as the EPA registration
number, case number or decision number) in support of which the package is being
submitted. If no number has been assigned by EPA, describe the type of request: data
call-in notice of MM/DD/YY, experimental use permit, etc.;
the transmittal date; and
a list of all documents included in the package in the order of their appearance. They
should be grouped by discipline (e.g., product chemistry, toxicology, environmental
fate) and arranged in ascending order by guideline number within each discipline.
Submitters commonly provide this information in a cover letter. This is adequate so long as all
of the elements above are included.
C. Individual documents
A data document is most commonly the report of a single scientific investigation including all
supporting analyses required for logical completeness. It may also be a compilation of product
chemistry data, a summary document that relates to two or more other documents in the
submission, a rationale for a data waiver request, or any other document that addresses a data
requirement. If a study is a commentary on or supplement to another previously submitted
document, or if it responds to EPA questions raised with respect to an earlier document, then
submitters should include on the title page the EPA MRID of the earlier document, if known.
Previously submitted documents should not be resubmitted unless specifically requested by OPP.
Each document should be consecutively paginated beginning with the title page and continuing
throughout the document, including any appendices. If it is extremely long, binding in multiple
volumes may be necessary. In this case, the pagination should continue consecutively through
all of the physical volumes. Each physical volume should be plainly identified by its title and its
position in the multi-volume sequence (e.g., volume 1 of N, 2 of N, etc.). An English translation
must be provided for any information in another language, as specified in 40 CFR 158.32(c)(4).
Currently, three identical copies of all applicable data are required. This applies to submissions
that are entirely paper. Please note that as OPP phases in its up-front imaging of paper
submissions, we expect to reduce this requirement to a single copy. For the latest information on
5

the status of the up-front imaging effort and number of copies required, please continue to check
the e-Submission website
(http://www.epa.gov/pesticides/regulating/registering/submissions/index.htm).
1. Document Title Page (Sample provided in Attachment 2)
Contains the following information for unpublished documents*:
Document title. This should be as descriptive as possible and include the substance(s)

or product tested.

Test guideline(s) http://www.epa.gov/oppts/pubs/frs/home/guidelin.htm

Author(s). Submitters should cite only individuals with primary intellectual

responsibility for the content of the document.

Study completion date, if applicable; otherwise submitters should use the date on

which the document was created.

Performing laboratory(ies). If the document reports work done by one or more labs,

submitters should include on the title page the name and address of the performing

lab(s) and the lab’s internal project number(s) for the work

Laboratory project identifier. Submitters should clearly distinguish between the lab’s

project identifier and any other reference numbers provided by the sponsor or

submitter.

Total page count for the document (Page 1 of xx).

*Published documents should be identified by the relevant facts of publication, such as journal

title, volume, issue, page range and publication date.

2. Statement of Confidentiality Claim
The regulations that address data confidentiality requirements are specific to the three categories
below. The first category represents the majority of documents submitted to the Office of
Pesticide Programs.
All pesticides other than antimicrobial pesticides and plant-incorporated protectants,

Antimicrobial pesticides, and

Plant-incorporated protectants (PIPs).

A. Documents supporting all pesticides other than antimicrobial pesticides and plantincorporated protectants (See 40 CFR 158.33):

6

One of the two statements below must appear on the second page of each data document. The
wording of these statements is prescribed by 40 CFR 158.33. Neither deviations from the text of
these two statements nor claims or markings on the document or its attachments other than the
statement provided on page 2 of the document will be recognized as asserting a claim of
confidentiality. The statement must be signed and dated by an authorized representative of the
submitter.
1)

NO CLAIM OF CONFIDENTIALITY

No claim of confidentiality, on any basis whatsoever, is made for any information
contained in this document. I acknowledge that information not designated as
within the scope of FIFRA sec. 10(d)(1)(A), (B), or (C) and which pertains to a
registered or previously registered pesticide is not entitled to confidential treatment
and may be released to the public, subject to the provisions regarding disclosure to
multinational entities under FIFRA 10(g).
Submitter: _______signature_________ Date: __________

Typed Name of Signer: ______________________________

Typed Name of Company: ___________________________

2)

CLAIM OF CONFIDENTIALITY

Information claimed as confidential has been removed to a confidential attachment.
Submitter: _______signature_________ Date: __________

Typed Name of Signer: ______________________________

Typed Name of Company: ___________________________

Use of the statement above requires that all information claimed as confidential be submitted in a
separate confidential attachment to the document and cross referenced to the specific location
from which it was removed. The confidential attachment must have its own title page and be
paginated separately from the non-confidential document.
In the confidential attachment, information claimed confidential under FIFRA 10(d)(1)(A), (B)
and (C) must be individually identified.
FIFRA 10(d)(1)(A): Information that consists of (or whose disclosure would in turn
disclose) manufacturing or quality control processes.
FIFRA 10(d)(1)(B): Information that consists of (or whose disclosure would in turn
disclose) the details of any methods for testing, detecting, or measuring the quantity of
any deliberately added inert ingredient of a pesticide.
FIFRA 10(d)(1)(C): Information that consists of (or whose disclosure would in turn
disclose) the identity or percentage quantity of any deliberately added inert ingredient of
a pesticide.
7

Sample cross references between the non-confidential document and its confidential attachment
are provided in Attachment 3.
3)
VOLUNTARY RELEASE OF INFORMATION TO STATES AND FOREIGN
GOVERNMENTS (40 CFR 158.33(c)(4))
In addition to the required use of one of the two confidentiality statements above, submitters are
encouraged to include an additional statement to allow EPA to share information with state and
foreign governments to facilitate coordination of pesticide reviews. EPA will not consider such
a statement to be a waiver of confidentiality or proprietary claims for the information. The
statement is as follows:
I authorize the Environmental Protection Agency to release any information
contained in this document to State and foreign governments, without relinquishing
proprietary rights or any confidentiality claims asserted above.
Submitter: _______signature_________ Date: __________

Typed Name of Signer: ______________________________

Typed Name of Company: ___________________________

Information designated as releasable to state or foreign governments in accordance with the
above statement may be released to those governments without further notice to the submitter.
EPA will inform the state or foreign government of any confidentiality claims associated with
the information.
B. Documents supporting antimicrobial pesticides (See 40 CFR 161.33):
40 CFR 161.33 is the regulation that currently governs the procedures for claims of
confidentiality of data in antimicrobial pesticide documents. One of the two statements below
must appear on the second page of each data document. The statement must be signed and dated
by an authorized representative of the submitter.
1)

NO CLAIM OF CONFIDENTIALITY

If no claim of confidentiality is being made for information described by FIFRA section
10(d)(1)(A), (B), (C), or if such information is not contained in the body of the study, the
Statement of Data Confidentiality Claims must include the following statement. This
statement must bear the name, title and signature of the submitter or his properly
designated agent, and the date of signature:
No claim of confidentiality is made for any information contained in this study on
the basis of its falling within the scope of FIFRA sec. 10(d)(1)(A), (B), or (C).
Submitter: _______signature_________ Date: __________
8

Typed Name of Signer: ______________________________

Typed Name of Company: ___________________________

2)

CLAIM OF CONFIDENTIALITY

Any information claimed to be confidential under FIFRA 10(d)(1)(A) through (C) must
be contained in a separate attachment to the study. If any information is included in the
body of the study rather than in the confidential attachment, the submitter waives a claim
of confidentiality for such information under FIFRA section 10(d)(1)(A), (B) or (C). The
attachment must have a cover page that is clearly marked to indicate that the material
contained in the attachment falls within the scope of FIFRA section 10(d)(1)(A), (B) or
(C). Each item in the attachment must be numbered. For each item, the submitter must
cite the applicable portion of FIFRA section 10(d)(1)(A), (B) or (C) on which the claim
of confidentiality is based. In addition, for each item, the submitter must provide a list of
page numbers in the study where the item is cited (i.e., identified by number). Each item
in the attachment must be referenced in the body of the study by its number in the
attachment.
The following statement must appear on the Statement of Data Confidentiality Claims and must
bear the name, title, and signature of the submitter or his properly designated agent, and the date
of signature:
Information claimed as confidential on the basis of its falling within the scope of
FIFRA sec. 10(d)(1)(A), (B), or (C) has been removed to a confidential appendix,
and is cited by cross-reference number in the body of the study.
Submitter: _______signature_________ Date: __________

Typed Name of Signer: ______________________________

Typed Name of Company: ___________________________

Sample cross references between the non-confidential document and its confidential attachment
are provided in Attachment 3.
Any information not described by FIFRA section 10(d)(1)(A), (B), or (C) for which a claim of
confidentiality is made must be submitted in accordance with the following procedures:
The information must be clearly marked in the body of the study as being claimed
confidential.
A separate Supplemental Statement of Data Confidentiality Claims must be submitted,
identifying by page and line number the location within the study of each item claimed
confidential, and stating the basis for the claim.
The Supplemental Statement of Data Confidentiality Claims must bear the name, title
and signature of the submitter or his properly designated agent, and the date of
signature.
9

C. Documents supporting plant-incorporated protectants (PIPS) (See 40 CFR 174.9):
Although it is strongly recommended that the submitter minimize the amount of data and other
information claimed as Confidential Business Information, a submitter may assert a claim of
confidentiality for all or part of the information submitted to EPA in a submission for a plantincorporated protectant. To assert such a claim, the submitter must comply with all of the
following procedures:
Any claim of confidentiality must accompany the information at the time the information
is submitted to EPA. Failure to assert a claim at that time constitutes a waiver of
confidentiality for the information submitted, and the information may be made available
to the public, subject to section 10(g) of FIFRA, with no further notice to the submitter.
Any claim of confidentiality must be accompanied, at the time the claim is made, by
comments substantiating the claim and explaining why the submitter believes that the
information should not be disclosed. The submitter must address each of the following
points in substantiation. EPA will consider incomplete all plant-incorporated protectant
submissions containing information claimed as CBI that are not accompanied by
substantiation and will suspend any applicable review of such submissions until the
required substantiation is provided.
1. The portions of the information that are alleged to be entitled to confidential
treatment;
2. The period of time for which confidential treatment is desired by the business
(e.g., until a certain date, until the occurrence of a specified event or
permanently);
3. The purpose for which the information was furnished to EPA and the
approximate date of submission, if known;
4. Whether a business confidentiality claim accompanied the information when
it was received by EPA;
5. Measures taken by the business to guard against undesired disclosure of the
information to others;
6. The extent to which the information has been disclosed to others, and the
precautions taken in connection therewith;
7. Pertinent confidentiality determinations, if any, by EPA or other federal
agencies, and a copy of any such determination, or reference to it, if available;
8. Whether the business asserts that disclosure of the information would be
likely to result in substantial harmful effects on the business's competitive
position, and if so, what those harmful effects would be, why they should be
viewed as substantial and an explanation of the causal relationship between
disclosure and such harmful effects; and
9. Whether the business asserts that the information is voluntarily submitted
information as defined in §2.201(i), and if so, whether and why disclosure of
the information would tend to lessen the availability to EPA of similar
information in the future.
10

3. Statement of compliance or non-compliance with good laboratory practice (GLP)
standards (40 CFR 160)
Sample compliance statements are provided in Attachment 4. This statement is required only if a
document meets the following definition of a study:
Study means any experiment at one or more test sites, in which a test

substance is studied in a test system under laboratory conditions or in the

environment to determine or help predict its effects, metabolism, product

performance (efficacy studies only as required by 40 CFR 158.400 or

161.640, as applicable), environmental and chemical fate, persistence and

residue, or other characteristics in humans, other living organisms, or

media. The term “study” does not include basic exploratory studies
carried out to determine whether a test substance or a test method has any

potential utility. [Excerpt from 40 CFR 160.3]

4. Flagging of studies for potential adverse effects (See CFR 158.34 and 161.34)
Any study of a type listed in tables 1 and 2 below must include the appropriate one of the two
statements below, together with the signature of the authorized representative of the submitter
and the date of signature on its fourth page.
1)

If the study does not meet or exceed criteria listed in the table:

I have applied the criteria of 40 CFR 158.34/40 CFR 161.34 for flagging studies for
potential adverse effects to the results of the attached study. This study neither
meets nor exceeds any of the applicable criteria.
Submitter: _______signature_________ Date: __________

Typed Name of Signer: ______________________________

Typed Name of Company: ___________________________

11

2)

If the study meets or exceeds criteria listed in the table:

I have applied the criteria of 40 CFR 158.34/40 CFR161.34 for flagging studies for
potential adverse effects to the results of the attached study. This study meets or
exceeds the criteria numbered [insert all applicable reporting codes].
Submitter: _______signature_________ Date: __________
Typed Name of Signer: ______________________________
Typed Name of Company: ___________________________

12

Table 1 - Flagging Criteria for All Pesticides other than Antimicrobials
(See 40 CFR 158.34)

Study Types
Carcinogenicity or combined
chronic feeding study

Guideline
No.
870.4200
870.4300

Prenatal developmental toxicity
Reproduction and fertility
Developmental neurotoxicity

870.3700
870.3800
870.6300

Neurotoxicity

870.6100
870.6200

Chronic feeding
Carcinogenicity
Reproduction and fertility
Prenatal developmental toxicity
Developmental neurotoxicity
Acute or 90-day neurotoxicity

870.4100
870.4200
870.3800
870.3700
870.6300
870.6200

Criteria: Treated animals show any of the following:
An incidence of neoplasms in males or females which
increases with dose (positive trend p≤ 0.05); or

Criteria
No.
1

A statistically significant (pairwise p≤ 0.05) increase of
any type of neoplasm in any test group, males or females at
any does level, compare to concurrent control animals of
the same sex; or

2

An increase in any type of uncommon or rare neoplasms in
any test group, males or females animals at any dose level,
compared to concurrent controls of the same sex; or

3

A decrease in the time to development of any type of
neoplasms in any test group, males or females at any dose
level, compared to concurrent controls of the same sex.
When compared to concurrent controls, treated offspring
show a dose-related increase in malformations, pre- or
post-natal deaths, or persistent functional behavioral
changes on a litter basis in the absence of significant
maternal toxicity at the same dose level.
When compared to concurrent controls, treated animals
show a statistically or biologically significant increase in
neuropathological lesions or persistent functional or
behavioral changes.
The no observed adverse effect level (NOAEL) from one
of these studies is less than the NOAEL currently used by
the Agency as the basis for either the acute or chronic
reference dose.

4

13

5

6

7

Table 2 - Flagging Criteria for Antimicrobial Pesticides
(See 40 CFR 161.34)

Toxicity studies

Oncogenicity [or combined
oncogenicity/chronic feeding
study]

Pesticide
assessment
guideline
No.
83-2

or
Subchronic feeding study

82-1

Teratogenicity

83-3

Neurotoxicity

81-7

Chronic feeding study or
combined chronic
feeding/oncogenicity study

83-1

Reproduction study

83-4

Subchronic feeding study

82-1

Criteria

Reporting
code

Treated animals show any of the following:
An incidence of neoplasms in males or females which
increases with dose;
or
A statistically significant (p≤ 0.05) incidence of any type
of neoplasm in any test group (male or female animals at
any does level), compared to concurrent control animals of
the same sex;
or
An increase in any type of uncommon or rare neoplasms in
any test group (male or female animals at any dose level)
compared to concurrent control animals;
or
A decrease in the time to development of any type of
neoplasms in any test group (male or female animals at any
dose level) compared to concurrent control animals
When compared with concurrent controls, treated animals
show a dose-related increase in malformations (or deaths)
on a litter basis in the absence of significant maternal
toxicity at the same dose levels.
When compared with controls, treated animals show a
response indicative of acute delayed neurotoxicity
Cholinesterase inhibition NOEL less than 10 times the
current existing ADI.
or
General (systemic) toxicity NOEL less than 100 times the
current existing ADI.
Reproductive effects NOEL less than 100 times the current
ADI
Cholinesterase inhibition NOEL less than 100 times the
current ADI.
or
General (systemic) toxicity NOEL less than 1000 times the
current existing ADI.

14

1
2

3

4
5

6
7
8
9
10
11

ATTACHMENT 1
SAMPLE TRANSMITTAL DOCUMENT

Submitter:
Smith Chemical Corp.

1234 West Smith Street

Cincinnati, OH 98765

Company Contact: _____(signature)_____

Typed Name of Signer: _______________

Phone:
_______________________

Fax:
_____optional___________

Email address: _____ optional__________

Regulatory Action in Support of Which this Package is Submitted:
EPA registration number: 98765-1, My Flea Product

Amendment to add ticks to the label.

Submission date:
MM/DD/YY
List of Submitted Documents:
Volume 1

Administrative materials (This list is for illustration purposes and does not
attempt to list all of the necessary forms to support a specific regulatory
action.)
Amendment form
Data Matrix
Proposed label text
Confidential Statement of Formula

Volume 2

Title of first data document (Guideline No.)

Volume 3

Title of second data document (Guideline No.)

16

ATTACHMENT 2
SAMPLE TITLE PAGE

TITLE
Product ABCXYZ

Acute Oral Toxicity in Rats

TEST GUIDELINE
OPPTS 870.1100

AUTHOR
John C. Davis

STUDY COMPLETION DATE
01/22/2008

PERFORMING LABORATORY
ABC Agricultural Laboratories
940 West Bay Drive
Wilmington, DE 33445

LABORATORY PROJECT ID
ABC 08-34

PAGE COUNT
1 of 35

17

ATTACHMENT 3
SAMPLE CROSS REFERENCES TO A CONFIDENTIAL ATTACHMENT
Reference on page 12 of the non-confidential text:
Information claimed confidential has been removed to the confidential attachment. See
Cross Reference 1.
Reference on page 18 of the non-confidential text:
Information claimed confidential has been removed to the confidential attachment. See
Cross Reference 2.
Complementary reference in the confidential attachment:
Cross Reference 1, page 12

FIFRA reference: 10(d)(1)(A)

Reproduce the deleted text here.
Complementary reference in the confidential attachment:
Cross Reference 3, page 18

FIFRA reference: 10(d)(1)(B)

Reproduce the deleted text here.

18

ATTACHMENT 4
SAMPLE GOOD LABORATORY PRACTICE COMPLIANCE STATEMENTS
Example 1:
This study was conducted in accordance with 40 CFR 160.
Study Director: _________signature_____________ Date: ________
Typed Name of Signer: _____________________________________
Typed Name of Laboratory: _________________________________
Sponsor: ______________signature_____________ Date: ________
Typed Name of Signer: _____________________________________
Typed Name of Company: ___________________________________
Submitter: _____________signature_____________ Date: ________
Typed Name or Signer: _____________________________________
Typed Name of Company: __________________________________
Example 2:
The following is a detailed description of all differences between the practices used in the study
and those required by 40 CFR 160:
______________________________________________________________________________
______________________________________________________________________________
Study Director: _________signature_____________ Date: ________
Typed Name: _____________________________________________
Typed Name of Laboratory: _________________________________
Sponsor: ______________signature_____________ Date: ________
Typed Name of Signer: _____________________________________
Typed Name of Company: __________________________________
Submitter: _____________signature_____________ Date: ________
Typed Name of Signer: _____________________________________
Typed Name of Company: __________________________________
Example 3:
The submitter of this study neither sponsored this study nor conducted it and does not know
whether the study was conducted in accordance with 40 CFR 160.
Submitter: _____________signature_____________ Date: ________
Typed Name of Signer: _____________________________________
Typed Name of Company: __________________________________
19

ATTACHMENT 5
GLOSSARY
Applicant:

Any person or entity who sends any application, petition, or other
submission to OPP with the intention to persuade OPP to grant, modify, or
leave unmodified a registration or other approval required as a condition
of sale or distribution of a pesticide. (See 40 CFR 158.3).

Author(s):

Individual(s) primarily responsible for the intellectual content of a
document. In the case of a document that meets the definition of a “study’
in 40 CFR 160.3, the study director should be identified as the author.

Authorized Agent:

A person residing in the United States who is designated by an applicant
to act as his agent. If an applicant wishes to designate an agent, he must
send the Agency a letter stating the name and U.S. mailing address of his
agent. (See 40 CFR 152.50(b)(3).) If an authorized agent signs any of the
statements described in this notice, then it should be made clear that he is
doing so as the applicant’s (submitter’s) authorized agent.

Data:

Information submitted by an applicant to satisfy an Agency data
requirement such as those published in 40 CFR parts 158 and 161, or any
other information requested by EPA or presented by the applicant in
support of a scientific or regulatory decision by OPP. Includes, but is not
limited to, data to support registration review, adverse effects information
submitted under FIFRA 6(a)(2), information supporting applications for
new or amended registration, experimental use permits, tolerance petitions
and tolerance exemption petitions. This information is contained in
documents that are collectively referred to as data. Studies (see definition
below) are a subset of data. Studies are subject to the requirements of 40
CFR 160, OPP’s Good Laboratory Practice Standards (GLPs).

20

MRID:

Master Record Identifier. A unique 8-digit number assigned to each
document submitted to OPP. These documents are permanent records;
you do not need to resubmit any document that has already been assigned
a MRID unless specifically requested to do so by OPP. Use the MRID to
cite a previously submitted document that supports a new regulatory
action. Never re-use an MRID; EPA assigns a new MRID to an amended
document in order to preserve the integrity of the records in our database.

OECD Dossier:

The Organization for Economic Co-operation and Development (OECD)
has developed a format for pesticide data submissions that is accepted by
numerous countries including the United States. See http://www.oecd.org.

Performing
Laboratory:
Person:

Plant-incorporated
protectant (PIP):

Facility/facilities where a study or part of a study is conducted.
Includes an individual, partnership, corporation, association, scientific or
academic establishment, government agency, or organizational unit
thereof, and any other legal entity. (See 40 CFR 160.3.)
A pesticidal substance that is intended to be produced and used in a living
plant, or in the produce thereof, and the genetic material necessary for
production of such a pesticidal substance. It also includes any inert
ingredient contained in the plant, or produce thereof. (See 40 CFR 174.3)

Sponsor:

A person who initiates and supports, by the provision of financial or other
resources, a study. (See 40 CFR 160.3.)

Study:

Any experiment at one or more test sites in which a test substance is
studied in a test system under laboratory conditions or in the environment
to determine or help predict its effects, metabolism, product performance,
environmental and chemical fate, persistence and residue, or other
characteristics in humans, other living organisms or media. The term
“study” does not include basic exploratory studies carried out to determine
whether a test substance or a test method has any potential utility. (See 40
CFR 160.3.)

Study Completion
Date:
Study Director:
Study Profile
Template:

Date the final report is signed by the study director. (See 40 CFR 160.3.)
Individual responsible for the overall conduct of a study. (See 40 CFR
160.3 and 160.33.)
A study profile records basic study information such as materials,
methods, results, and the applicant’s conclusions in a standard format
21

known as the template that mirrors the template used by EPA science
reviewers in preparing their Data Evaluation Records (DERs).
Submission:

Consists of all the documents sent to OPP at the same time in support of a
single regulatory action or a group of related actions, such as a product
amendment and a related tolerance petition by an Applicant (see definition
above). The documents should be accompanied by a transmittal document
and related administrative material (e.g., EPA Forms 8570-1, 8570-4, etc.)
as appropriate. This transmittal document and administrative material
should be grouped together in the first physical volume if the submission
is on paper. Consult the e-submission XML guidance document at
http://www.epa.gov/pesticides/regulating/registering/submissions/XMLsu
bmissions/e-submission_xml_guidance_document_v1.pdf for specific
information on the format of these documents as files on a CD/DVD.

Submitter:

Any person making a submission to OPP.

Test Guideline:

Number that identifies a published testing procedure. The OCSPP
harmonized test guidelines are available at:
http://www.epa.gov/ocspp/pubs/frs/home/guidelin.htm

Transmittal
Document:

Provides the who, what, when and why of the data submission by
identifying the submitter, submission date, regulatory action being
supported, and a list of the documents included in the submission. See 40
CFR 158.32(b), 161.32(a).

22