Overview
Title
Agency Information Collection Activities; Submission to the Office of Management and Budget for Review and Approval; Notice of Arrival of Pesticides and Devices Under Section 17(c) of FIFRA (Renewal)
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The EPA wants to continue getting a heads-up when pesticides and certain devices are brought into the U.S. This helps them keep track of what's coming in and make sure it's safe for everyone.
Summary AI
The Environmental Protection Agency (EPA) has submitted a request to the Office of Management and Budget (OMB) for renewing the process in which importers notify the arrival of pesticides and devices in the U.S., as required by law. This request includes collecting information either through paper forms or electronically, and it aims to ensure the EPA can manage and plan for these shipments. The request also notes an increase in the number of electronic submissions and the costs associated with the process. Public comments on this request are open until February 3, 2025.
Abstract
The Environmental Protection Agency (EPA) has submitted the following information collection request (ICR), Notice of Arrival of Pesticides and Devices Under Section 17(c) of FIFRA (EPA ICR Number 0152.15 and OMB Control Number 2070-0020), to the Office of Management and Budget (OMB) for review and approval in accordance with the Paperwork Reduction Act (PRA). This is a proposed extension of ICR, which is currently approved through January 31, 2025. Public comments were previously requested via the Federal Register on June 24, 2024 during a 60 day comment period. This notice allows for an additional 30 days for public comments.
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AnalysisAI
General Summary
This document is a notice from the Environmental Protection Agency (EPA), submitted to the Office of Management and Budget (OMB), requesting renewal of an information collection process related to the importation of pesticides and devices into the United States. The notice pertains specifically to how notifications of such imports are handled by both paper forms and electronic submissions. The renewal seeks to extend the current process, which is operational through January 31, 2025, and provides an additional period for public comments until February 3, 2025.
Significant Issues or Concerns
One of the primary concerns noted in the document is an increase in the number of annual submissions of Notices of Arrival (NOAs) of pesticides and devices through an electronic system known as the Automated Commercial Environment (ACE). The increases are significant, adding over 75,000 submissions annually, along with a corresponding uptick in costs and labor hours. However, the document lacks a comprehensive explanation for this surge in electronic submissions, which raises questions about the underlying factors causing this change.
Moreover, there is a notable rise in the estimated financial costs due to updated wage rates, amounting to an additional $2.7 million. The document does not provide a detailed breakdown of these costs, which may interest those concerned with government spending and accountability.
Public Impact
The proposed renewal and the associated changes largely impact importers of pesticides and related devices by mandating that they comply with updated submission processes. For the general public, the process aims to ensure that substances coming into the country meet safety standards as enforced by the EPA. This notice may reassure people that the agency is committed to efficient oversight of environmental and public safety standards.
However, the increased costs and procedural changes could result in higher operational expenses for businesses, potentially affecting the prices of products for consumers, particularly items relying on imported pesticides.
Impact on Specific Stakeholders
For importers and businesses involved with agricultural chemicals and pest management products, this document signifies a need to stay apprised of regulatory changes and potentially increase resource allocation for compliance. The burden of increased submissions and costs associated with conforming to these processes may strain smaller businesses or those with limited resources.
Conversely, those involved with environmental protection and public health may view these protocols positively as they contribute to enhanced scrutiny and oversight. Enhanced electronic tracking capabilities could lead to more robust data collection, beneficial in tracing and responding to potential public health concerns arising from imported pesticides.
Overall, while the document seeks to establish efficient operations in line with existing laws, it may necessitate further explanation to stakeholders about cost increases and procedural adjustments. Providing clearer insight into complex regulatory references and technical jargon could also enhance understanding and compliance amongst the affected parties.
Financial Assessment
The document from the Environmental Protection Agency (EPA) discusses the renewal of a notice related to the arrival of pesticides and devices. It includes financial references that shed light on the estimated costs associated with the procedure and the changes observed over time.
Summary of Financial References
The text mentions that the total estimated costs amount to $5,478,039 per year. This figure reflects the annual expenses associated with processing notices of arrival (NOAs) of pesticides and devices. Notably, these costs include $0 annualized capital investment or maintenance and operational costs, which suggests that all expenses are related to labor and processing rather than physical infrastructure or equipment.
Analysis of Financial Allocations and Related Issues
The text also reports an increase in respondent costs by $2,724,517, attributed to changes necessary to reflect current wage rates. This suggests that the financial burden has grown largely due to higher labor costs, which points to a possible increase in wages or additional time required for processing due to more submissions.
The document highlights a significant increase in the annual number of NOAs submitted electronically through the ACE system by 75,892. Such a change leads to increased estimated burden hours and costs. However, the document lacks an explanation for why there's such a substantial increase in submissions, which raises questions about whether the cost estimations have been fully justified. Understanding the reasons behind the surge in submissions could clarify how these financial projections have been calculated and whether they accurately reflect the reality.
Moreover, while the document outlines the cost increases due to wage rate adjustments, it omits further details or a breakdown of these costs. Providing a detailed explanation could help identify any potential inefficiencies or areas of concern that might require attention. A clearer depiction of how the additional costs are allocated could be important for assessing whether there is any unnecessary or excessive spending.
In essence, while the document provides a concise overview of the financial expectations and changes, it leaves room for improvement in clarifying the rationale behind the cost estimates and increases. A more comprehensive analysis with a breakdown of costs would benefit a broader audience in understanding financial allocations related to this public notice.
Issues
• The document mentions an increase in the annual number of NOAs submitted electronically through the ACE system by 75,892, resulting in increases in both the estimated burden hours and costs. It does not specify why there's such a significant increase in submissions, which may require further clarification to ensure these estimates are justified.
• The estimated costs have increased by $2,724,517 because of changes to reflect the current wage rates. However, it does not provide context or a breakdown of these costs, which could be important to identify any wasteful or unjustified spending.
• The document refers to several regulatory codes (e.g., 40 CFR 152.25(f), FIFRA sections 3 and 25, and 19 CFR 12.112) without explanation of their relevance or implications, which may make it difficult for non-experts to understand the requirements.
• The use of technical terms and acronyms such as ICR, OMB, NOA, EPA Form 3540-1, ACE, and PGA Message Set can make the document difficult to understand without a glossary or further explanation.
• The section on respondents/affected entities lists NAICS codes that might not be familiar to all readers, potentially limiting comprehension without additional context or explanation.
• The abstract mentions 'information collection activities and related estimated burden and costs that are summarized in this document,' but these summaries are lengthy and contain technical jargon, potentially complicating interpretation by a general audience.