Attachment D -Consultation

EPA ICR No. 0278.11
0044

OMB Control No. 2070-

Notice of Supp l emental Distribution of a Registered Pesticide
Product; EPA-HQ-OPP -20 12-0544

Consultation for OPP ICR Renewals

Representative(s) Consulted

Name

Amy McCaskill

Company Represented

Bayer

Contact Information (email and mailing)

amv.mccaski llt@.baver.com
2 TW Alexander Drive
Durham, NC 27709

Questionnaire

Publicly Available Data

(I)

•

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.

•

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?)

(2)

Frequency of Collection
•

(3)

Can the Agency collect the information less frequentl y and still produce the same
outcome? No
Clarity of Instructions

The ICR is intended to require that respondents provide certai n 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

•

Do you understand that you are required to maintain records? Yes

1

EPA ICR No. 0278.11
0044

OMB Control No . 2070-

....

Notice of Supplemental Distribution of a Registered Pesticide
Product; EPA-HQ - OPP-2012-0544

•

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

•

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

(4)

Electronic Reporting and Record keeping
The Government Paperwork E limination 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 ofCBI that might be transmitted over the Internet.
•

What do you think about electronic alternatives to paper-based records and data
submissions? CmTent electronic reporting alternatives include the use of web
forms@/XML based submissions via the Agency's Internet site and magnetic mediabased submissions, e.g., diskette, CD-ROM, etc. Would you be interested in pursuing
electronic reporting? We prefer electronic alternatives; appreciated and used by our
company.

•

Are you keeping your records electronically? If yes, in what format? Yes. Mainly
scanned PDF's.

•

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.

•

What benefits would electronic submission bring you in terms of burden reduction or
greater efficiency in compiling the information? Ease of electronic fi ling and tracking.

(5)

Burden and Costs
•

Are the labor rates accurate? Yes

•

The Agency assumes there is no capital cost associated with this activity. Is that correct?
Yes.

•

Bearing in mind that the burden and cost estimates include only burden hours and costs
associated with the paperwork invo lved 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

2

.

'

r •

. EPA ICR No.

0278.11

OMB Control No.

2070-

0044
Notice of Supplemental Distribution of a Registered Pesticide
Product; EPA-HQ - OPP-2012-0544

different from EPA's, please provide an explanation of how you arri ved at your
estimates. Yes, accurate as is.
•

Are there other costs that should be accounted for that may have been missed? No.

3

EPA ICR No. 0278 . 11
0044

OMB Control No. 2070-

Notice of Supplemental Distribution of a Registered Pesticide
Product; EPA-HQ - OPP-2012-0544

Consultation for OPP ICR Renewals

Representativc(s) Consulted
Name Laura Phelps
Company Represented ADAMA Agricultural Solutions
Contact Information (email and mailing) laura.phelps@adama.corn; 3 120 Highwoods
Blvd Raleigh 27604

Questionnaire
( I)

Publicly Avai lable 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

•

If yes, where can you find the data? (Does your answer indicate a true duplication, or
does the input indicate that certain data e lements are available, but that they don=t meet
our data needs very well?)

(2)

Frequency of Collection
•

(3)

Can the Agency col lect the information less frequently and still produce the same
outcome? No, information collection is timely
Clarity of Instructio ns

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 s ubmit such data? lf not, what suggestions do you have to clarify the
instructions? How the data is subm itted is fairly straightforward but sometimes the
Agency requires data before the methods are adequately developed/ validated/ or
implemented. Often this results is wasted efforts and having to redo data to the Agency' s
satisfaction (ie polli nator studies)

•

Do you understand that you are required to maintain records? yes

1

EPA ICR No. 0278.11

OMB Control No.

2070-

1
• \

0044
Notice of Supplemental Distribution of a Registered Pesticide
Product; EPA-HQ-OPP-2012-0544

•

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

•

Are there forms associated with this process? Do you use them? Are they clear, logical,
and easy to complete? Forms are fairly straightforward but somewhat outdated especially with the new e-submission format.

(4)

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.
•

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 mediabased 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, Sharepoint

•

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

•

What benefits wou ld electronic submission bring you in terms of burden reduction or
greater efficiency in compiling the information? Less paper waste and transportation
costs; quicker to put together

( 5)

Burden and Costs
Are the labor rates accurate? yes
•

The Agency assumes there is no capital cost associated with this activity. Is that conect?
yes

•

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

2

EPA ICR No. 0278 . 11
0044

OMB Control No. 2070-

Notice of Supplemental Distribution of a Registered Pesticide
Product; EPA-HQ-OPP- 2012-0544

different from EPA's, please provide an explanation of how you arrived at your
estimates. yes
•

Are there other costs that should be accounted for that may have been missed? With esubm issions the burden has decreased

3