Overview
Title
Agency Information Collection Activities; Renewal Request Submitted to OMB for Review and Approval; Comment Request; Experimental Use Permits (EUPs) for Pesticides (Renewal)
Agencies
ELI5 AI
The Environmental Protection Agency (EPA) wants permission to keep asking companies questions about using special test permits for pesticides to make sure they are safe. They are checking with another group if it's okay to keep doing this, and people can say what they think until February 10, 2021.
Summary AI
The Environmental Protection Agency (EPA) has submitted a request to renew their authority to collect information regarding Experimental Use Permits (EUPs) for pesticides. This collection helps the EPA decide whether to issue EUPs, which allow pesticide companies to temporarily use pesticides for research purposes before registration. The request will be reviewed by the Office of Management and Budget (OMB), and public comments are invited until February 10, 2021. The renewal does not impact prior estimates of the time or costs involved, which anticipate 567 hours of effort from 31 respondents, at a total cost of $37,497.
Abstract
The Environmental Protection Agency (EPA) has submitted an information collection request (ICR), Experimental Use Permits (EUPs) for Pesticides (EPA ICR Number 0276.17 and OMB Control Number 2070- 0040), to the Office of Management and Budget (OMB) for review and approval in accordance with the Paperwork Reduction Act. This is a proposed extension of an existing ICR, which is currently approved through February 28, 2021. Public comments were previously requested via the Federal Register on August 17, 2020. A fuller description of the ICR is given below, including its estimated burden and cost to the public. An agency may not conduct or sponsor and a person is not required to respond to a collection of information unless it displays a current valid OMB control number.
Keywords AI
Sources
AnalysisAI
The Environmental Protection Agency (EPA) is seeking to renew its authorization to gather information regarding Experimental Use Permits (EUPs) for pesticides. Essentially, this renewal would allow pesticide companies to temporarily utilize pesticides for research purposes before they are registered for broader use. The EPA has submitted this request to the Office of Management and Budget (OMB), and public feedback on this matter is encouraged until February 10, 2021.
Document Overview
This document primarily serves as a formal notice of the EPA’s request to continue collecting information that assists in the issuance of EUPs. An Experimental Use Permit allows for the intentional testing of pesticides, which are either new to the market or an unregistered use of existing pesticides, to gather the necessary data to support their official registration. The expected effort and cost involved in this process, as previously calculated, remain unchanged.
Significant Issues and Concerns
There are a few noteworthy issues and concerns presented by this document.
Firstly, there is potential confusion surrounding the timeline of the current authority, as it mentions approval only through February 28, 2021. Given the document's January 2021 publication date, clarifying the updated deadline for approval would serve to prevent misunderstandings.
Another point involves the estimated costs section which indicates a cost of $0 for certain non-burden hour paperwork but then includes seemingly unrelated text about "print page 1960." This could be a typographical error or formatting issue, possibly misleading readers.
Additionally, some sections of the document utilize complex language and regulatory jargon, such as "FIFRA section 5," which could hinder comprehension by laypersons unfamiliar with these terms. Simplifying or explaining such references would make the content more accessible to the general public.
The document also assumes readers understand how to submit feedback and access related documents online. This process may not be straightforward for individuals unacquainted with government procedures, suggesting a need for more detailed guidance.
Lastly, the document does not detail how the information collection may enhance public health or environmental safety, which represents an oversight considering the potential real-world implications of pesticide testing and registration.
Public Impact
The renewal of this information collection request has implications both broadly and for specific stakeholder groups.
For the general public, the continuation of EUPs is a step in ensuring that pesticides undergo rigorous testing, which can lead to safer usage in agricultural practices. The public might view this positively, associating it with enhanced food safety and environmental health.
However, the document could also raise concerns about the potential for temporary pesticide use without full registration, especially if the potential environmental or health impacts are not effectively communicated.
Stakeholder Impact
For stakeholders like pesticide manufacturers, this document represents continuity in regulatory processes that allow them to innovate and test new uses or products under specific bounding conditions. This could aid in the advancement and safety verification of agricultural chemicals, directly impacting the business strategies of these companies.
On the other hand, environmental advocacy groups might express concerns about the implications this testing could have on ecosystems or human health, particularly if transparency and public input are perceived as insufficient.
In sum, while this document addresses necessary regulatory processes for pesticide testing, enhancing clarity, public engagement, and explaining broader societal benefits would improve its effectiveness and acceptance.
Financial Assessment
In examining the financial elements of the Federal Register document concerning the renewal of Experimental Use Permits (EUPs) for pesticides, a few key points deserve attention:
The document indicates an estimated total cost of \$37,497 associated with the information collection process for obtaining Experimental Use Permits. This amount primarily reflects the burden on respondents, who are mainly entities involved in Pesticide and other Agricultural Chemical Manufacturing.
Interestingly, the document states that there are no additional costs for non-burden hour paperwork, noted with an estimate of \$0. This implies that the financial burden strictly pertains to administrative time and effort, without extra financial demands for materials or external services. Although this is straightforward, the sentence structure includes the phrase "(print page 1960)", which could be an editorial oversight or formatting glitch. This could confuse readers trying to understand the cost details because it disrupts the flow of information.
Importantly, while these costs are outlined, there is a lack of transparency regarding how the expenditure aligns with broader goals, such as improving environmental safety or public health. Explaining how these costs contribute to achieving regulatory compliance or ensuring safe pesticide use could provide clearer insight into the value derived from these financial allocations.
Lastly, the context in which these costs are embedded might pose challenges for some readers. The detailed regulatory references assume a level of understanding about the federal permitting process and the complexity surrounding FIFRA (Federal Insecticide, Fungicide, and Rodenticide Act) compliance. Simplifying this language or providing additional context in terms of financial impact would benefit stakeholders who are not intimately familiar with the regulatory jargon. This approach could also enhance public engagement in the commentary process, ensuring feedback is rooted in a clearer financial understanding.
Issues
• The document should reflect the updated deadline for the ICR approval, as the current approval is noted to end on February 28, 2021, but the document is from January 2021, which may cause confusion.
• The estimated total costs section mentions an estimated cost of $0 for non-burden hour paperwork costs but then continues with 'print page 1960,' which might be a typographical error or formatting issue.
• The language used in some sections could be considered complex for the general public, especially the jargon related to regulatory procedures such as FIFRA section 5 and the specific requirements for EUPs.
• The document assumes familiarity with the process of submitting comments and accessing the docket online, which could be difficult for individuals not experienced with these processes.
• No information is provided to suggest how the collection of this information improves public health or environmental safety, which might be valuable for context.