Overview
Title
Agency Information Collection Activities; Submission to the Office of Management and Budget for Review and Approval; Comment Request; Standards for Pesticide Containers and Containment (Renewal)
Agencies
ELI5 AI
The EPA wants to keep checking that businesses use safe pesticide containers, and they’re asking people if they have any thoughts about this. It’s like making sure toy boxes stay sturdy and safe, and everyone has until February 3, 2025, to say what they think.
Summary AI
The Environmental Protection Agency (EPA) has submitted a request to renew its information collection activities related to standards for pesticide containers and containment. This renewal request, under the Paperwork Reduction Act, seeks to extend the approval for collecting certain records from businesses involved in pesticide production and repackaging. These records help ensure compliance with regulations on container design, residue removal, and containment structure maintenance. Public comments are open until February 3, 2025, and can be submitted online or via mail.
Abstract
The Environmental Protection Agency (EPA) has submitted an information collection request (ICR), Standards for Pesticide Containers and Containment (EPA ICR Number 1632.07 and OMB Control Number 2070-0133) 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 the ICR, which is currently approved through January 31, 2025. Public comments were previously requested via the Federal Register on April 22, 2024. This notice allows for an additional 30 days for public comments.
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AnalysisAI
The Environmental Protection Agency (EPA) has announced its intent to renew the information collection processes associated with the standards for pesticide containers and containment. This renewal is pursuant to the requirements set by the Paperwork Reduction Act and involves extending the approval for collecting records from entities involved in pesticide production and repackaging. These records are crucial for ensuring compliance with regulations related to container design, residue removal, and containment structure maintenance. Feedback from the public is encouraged and can be submitted until February 3, 2025, both online and through mail.
Summary of the Document
The notice outlines the EPA's submission for renewing an information collection request under the Office of Management and Budget (OMB). This renewal aims to continue monitoring compliance with pesticide regulations. It involves entities that handle pesticide containers, ensuring they maintain records on container design, residue removal, and the management of containment structures to adhere to established safety and environmental standards.
Significant Issues and Concerns
The document raises a few concerns. First, there is a lack of explicit criteria around what qualifies for "on-site inspection" by the EPA. This ambiguity might lead to inconsistent enforcement or understanding of the compliance checks. Second, while the document advises on excluding profanity, threats, or sensitive business information in public comments, it does not provide clear definitions for these terms, which could result in varied interpretations. Third, the increase in costs related to agricultural pesticide refiller expenses is noted as an adjustment but is not explained in detail, leaving questions about the underlying reasons for this cost rise.
Fourth, changes in cost figures for the regulated community and the agency itself due to wage rate adjustments are mentioned without a transparent breakdown of these figures, possibly raising concerns among stakeholders about the calculations' validity. Lastly, the document refers to "Entities potentially affected" without offering precise examples, which might confuse stakeholders unfamiliar with the regulatory landscape.
Public and Stakeholder Impact
Broadly, this document underscores the EPA’s ongoing efforts to maintain rigorous safety standards in the pesticide industry, potentially benefitting public health and the environment by ensuring that such entities conform to necessary safety measures. However, ambiguity in inspection criteria or cost adjustments can impact how effectively these measures are implemented or received by the public.
For specific stakeholders like agrichemical retailers, pesticide formulators and refillers, or commercial applicators, this renewal could mean continued diligence in record maintenance and compliance with EPA standards. While this ensures safer practices, it may also involve operational costs associated with these record-keeping and compliance efforts. On the other hand, the lack of clarity in criteria and cost justifications could cause uncertainty and concern about regulatory expectations and financial implications.
Overall, while the document seeks to reinforce important environmental and public health protections, it simultaneously underscores the need for clearer communication and transparency in regulatory practices and their costs.
Financial Assessment
The document details a financial analysis and cost estimation associated with the renewal of the information collection request concerning pesticide containers and containment. It references several key financial figures and adjustments associated with this regulatory process.
Financial Summary
The document outlines the total estimated costs as $10,864,047 per year, which notably includes $419,875 allocated annually towards capital investment or maintenance and operational costs. This comprehensive cost estimation accounts for all the operational efforts required to maintain compliance with the standards for pesticide containers and containment.
Adjustments in Costs
The document indicates specific changes in costs for the regulated community and the Agency. The regulated community is expected to see an increase of $1,830,391. This increase is attributed to wage rate adjustments based on the Bureau of Labor Statistics (BLS) data. Similarly, the Agency will see a cost change of $1,747, again related to wage rate adjustments. These figures underscore an important financial dynamic whereby changes in wage rates can significantly affect overall compliance costs for both regulated entities and the government.
Additionally, the document highlights an increase in capital costs amounting to $83,975, particularly due to the rising expenses linked to agricultural pesticide refillers. However, the rationale behind this specific adjustment in capital costs lacks detailed explanation, which could lead to questions from stakeholders about the reasons for these increases.
Financial References and Issues
The document vaguely touches on several critical issues that intertwine with the financial details. While it provides specific numerical values associated with cost changes, it does not expound upon how these figures were calculated or their underlying causes. For instance, although it cites adjustments due to BLS wage rate fluctuations, it leaves the methodology and detailed breakdown of these calculations unspecified. This absence of transparency could lead to concerns about the basis for these cost changes and whether they were comprehensively evaluated.
Further, while the document does mention entities potentially affected by the pesticide container regulations, it does not provide detailed examples. This lack of clarity can make it challenging for stakeholders to understand their financial responsibilities or potential adjustments they might need to anticipate.
Overall, while the document provides a snapshot of the financial impacts of this regulatory extension, it leaves several open questions regarding the specific paths and calculations that lead to the enumerated financial adjustments. Stakeholders might benefit from more explicit commentary or supplementary material explaining these figures in greater detail.
Issues
• The document does not specify the criteria for 'on-site inspection' by EPA which might lead to ambiguity or inconsistent application of the inspections.
• The document lacks clarity on what constitutes 'profanity, threats, information claimed to be Confidential Business Information (CBI) or other information whose disclosure is restricted by statute', which could be subjective and lead to inconsistent handling of comments.
• The increase in capital costs of $83,975 due to agricultural pesticide refiller costs is mentioned as an adjustment but lacks detailed explanation of the reasons behind this adjustment.
• The document mentions a change in costs for the regulated community of $1,830,391 and for the Agency of $1,747 due to BLS wage rate adjustments without detailing how these new figures were calculated, potentially leading to concerns about the basis for these cost changes.
• The phrase 'respondents/affected entities' mentions 'Entities potentially affected' but does not provide explicit examples of such entities, which could lead to confusion or misinterpretation among stakeholders not familiar with the technical terms.