Attachment G
Consultations conducted for the renewal of the Pesticide Registration Fee Waivers; OMB Control No.: 2070-0167 EPA ICR No.: 2147.04
Company Name: Walter G. Legge Company, Inc.
Name of person consulted: Liz Bauer
Date: 12/10/09
Q: When preparing your waiver request did you consult the Questions and Answers on the EPA website (http://www.epa.gov/pesticides/fees/questions/waivers.htm)?
A: Yes
Q: If yes, did you find it helpful and informative?
A: Not necessary. Hard to find it on the web and, once found it was hard to understand and was redundant.
Q: What improvements or clarifications would you like to see?
A: Link directly to small businesses on the pesticides web site. Reduce the number of steps to complete a small business waiver request and provide a direct link to pay.gov. EPA not always prompt in returning phone calls when there are questions.
Q: Are you aware of the industry generated form?
A: could not find it.
Q: Would you use the industry generated form (http://www.cspa.org/pdf/waiver.pdf)? If no, why not?
After receiving a copy of the form from EPA, used it.
Labor Rates:
Q: Would you say the following labor rates are accurate?
$109.82 /hr management; $60.39 /hr technical staff; $35.89 /hr clerical
Management prepares small business waiver request. Approx. $100/hr
•The agency methodology for estimating the cost and burden associated with the paperwork involved with preparing your waiver request is the following
Management: reading and comprehending the regulations, planning activities to submit the waiver request: 10 hrs; Subsequent submissions: 2 hrs
Prepares application – 3 hours provided EPA does not need to be contacted for questions.
Technical: locating and preparing copies of taxes, audits, payroll account statements, any market analysis, etc.? 40 hrs; Subsequent submissions 40 hrs
No technical support in preparing application.
Clerical: preparing the submission 10 hrs; Subsequent submissions 10 hrs
No clerical support used.
Q: Did we miss anything?
Comments:
Attachment G.1
Consultations conducted for the renewal of the Pesticide Registration Fee Waivers; OMB Control No.: 2070-0167 EPA ICR No.: 2147.04
Company Name: Falcon Lab LLC
Name of person consulted: Terry Pizzarello, COO
Date: December 14, 2009
Q: When preparing your waiver request did you consult the Questions and Answers on the EPA website?
A: Yes
Q: If yes, did you find it helpful and informative?
A: Yes
Q: What improvements or clarifications would you like to see?
A: No suggestions at this time.
Q: Are you aware of the industry generated form?
A: yes
Q: Would you use the industry generated form? If no, why not?
Yes
Labor Rates:
Q: Would you say the following labor rates are accurate?
$109.82 /hr management; $60.39 /hr technical staff; $35.89 /hr clerical
Do not know – family owned company.
•The agency methodology for estimating the cost and burden associated with the paperwork involved with preparing your waiver request is the following
Management: reading and comprehending the regulations, planning activities to submit the waiver request: 10 hrs; Subsequent submissions: 2 hrs
Management prepares the small business fee waiver request. 2.0 hours for an initial submission during a maintenance fee cycle. Subsequent application in the same year - 0.75 hours
Technical: locating and preparing copies of taxes, audits, payroll account statements, any market analysis, etc.? 40 hrs; Subsequent submissions 40 hrs
Clerical: preparing the submission 10 hrs; Subsequent submissions 10 hrs
Q: Did we miss anything?
No
Comments:
Page
| File Type | application/msword |
| File Title | Attachment G |
| Author | ctsuser |
| Last Modified By | ctsuser |
| File Modified | 2010-10-22 |
| File Created | 2010-09-29 |