Worker pesticide safety trainings are the responsibility of the agricultural establishment employer. EPA estimates that there are 312,568 establishments that hire workers, i.e., those that engage in hand labor activities in the production of crops. Operations that primarily raise livestock (NAICS 112) are not included in the estimate because it is assumed that the types of crops primarily raised do not necessitate hiring agricultural workers. Handlers that work on livestock operations are included in the handler training section below. This estimate includes establishments that do not use pesticides on the assumption that most establishments will conduct trainings early in the season before pesticide application decisions are made, but will train workers in case pesticides are needed. EPA further estimates that there will be a total of 518,487 training sessions per year given multiple trainings to accommodate different sizes of workforce across different types of farms:
 Large establishments (annual revenue of $750,000 or more) with more than 10 employees, estimated to number 16,454, hold an average of 6.4 training sessions per year;
 Large establishments (annual revenue of $750,000 or more) with fewer than 10 employees, estimated to number 40,224, hold an average of 1.45 training sessions per year;
 Small establishments (annual revenue of less than $750,000) with more than 10 employees, estimated to number 17,598, are assumed to hold an average of 3.25 training sessions per year;
 Small establishments (annual revenue between $10,000 and $750,000) with fewer than 10 employees, estimated to number 167,377, are assumed to hold an average of 1.27 training sessions per year;
 Small establishments (annual revenue less than $10,000) with fewer than 10 employees, estimated to number 70,917, are assumed to hold an average of 1.2 training sessions per year.
EPA assumes that 14% of trainings will be conducted by trainers of certified applicators, accounting for 72,588 training sessions held on 43,760 establishments; 10% of trainings will be conducted by trainers who completed a Train-the-Trainers program, accounting for 51,849 training sessions held on 31,257 establishments; and 76% of trainings will be conducted by certified applicators, accounting for 394,050 training session held on 237,551 establishments. (Table 12, lines 1-3)
	EPA estimates that there are 1,910,055 employees on farms that primarily produce crops (NAICS 111) and hire labor.  Given a new hire rate of 16%, the Agency estimates that 84% of the 215,638 handlers employed on establishments hiring workers, or 181,136, will be returning employees who will receive handler safety training. Thus, the Agency estimates that 1,728,919 workers (1,910,055 - 181,136) will be trained each year. (Table 12, line 4)
	The training time requirement for worker training sessions is estimated to take 45 minutes (0.75 hours) to cover the training content.
	Employers (numbering 312,568) are required to make a record of the training (numbering 518,497 as calculated above) and have it signed by the trained worker (numbering 1,728,919). The estimated time burden for agricultural establishment to collect signatures and file the records of training is 7 minutes (0.12 hours) per training session. The time required for workers to sign is 30 seconds (0.0083 hours) per worker. Employers are required to keep records of training for 2 years, including names of workers trained, trainer's name and eligibility, and the employer's name; date; materials used; and signature acknowledgement of receipt of training. This record must be provided to the employee upon their request. EPA estimates that one-third of workers (576,306) will request a copy, given that 28% of workers report having multiple employers. EPA assumes it takes about 2 minutes (0.033 hours) per request for the employer to copy the training record. (Table 12, lines 5-7)
      Agricultural Handler Pesticide Safety Training

      Handler pesticide safety trainings are the responsibility of the handler employer. Handlers are trained annually and the training time for agricultural establishment handler training is estimated to take 60 minutes.
      EPA estimates that there are 221,187 establishments that hire handlers (Table 2), including establishments that do not apply pesticides on the assumption that most establishments will conduct trainings early in the season before pesticide application decisions are made, but will train handlers in case pesticides are needed.  EPA further estimates that there will be a total of 134,424 training sessions per year given the number of trainings across different sizes of farms:
 Large establishments (annual revenue of $750,000 or more), which are assumed to average 2 handlers/farm, estimated to number 79,434, will average 0.8 training sessions/year (4 trainings for every 5 farms, as some farms are able to share resources), resulting in 63,547 training sessions;
 Large-small establishments (annual revenue between $100,000 and $750,000), which are assumed to average 1 handler/farm, estimated to number 141,753, will average 0.5 training sessions/year (1 training for every 2 farms, as some farms are able to share resources), resulting in 70,877 training sessions.
	The training must be provided by persons designated by EPA, state or tribal pesticide enforcement agencies as a trainer of certified applicators or handlers; trainers that have completed an approved Train-the-Trainer course; or are certified applicators (40 CFR 171). EPA assumes that 14% of trainings will be conducted by trainers of certified applicators, accounting for 18,819 training sessions for 30,966 establishments; 10% of trainings will be conducted by trainers who completed a Train-the-Trainers program, accounting for 13,442 training sessions for 22,119 establishments; and 76% of trainings will be conducted by certified applicators, accounting for 102,162 training session for 168,102 establishments. (Table 12, lines 8-10)
	EPA estimates that there are 300,621 handlers, including those that are employed on establishments that do not hire workers. This number includes 16% (the new hire rate) of the 215,638 handlers employed on establishments that hire workers (34,502) who also receive worker safety training. (Table 12 line 11)
      Employers (numbering 221,187) are required to make a record of the training. Given a new hire rate of 16%, the Agency assumes that there will be 1.16 training occasions per establishment, or 256,577 occasions. The estimated time burden for the agricultural establishment employer to collect signatures and file the records of training is 4 minutes (0.067 hours) per training occasion. See line 12.  The record must be signed by the trained handler (numbering 300,621), which is assumed to take 30 seconds (0.0083 hours) per handler. (Table 12, line 13)
      The employer must maintain the record for 2 years and provide a record of the same information to the handler upon request. EPA estimates that 16% of handlers (48,099) will request a copy, given the new hire rate of 16%, assumed to represent the turnover rate of handlers. EPA assumes it takes about 2 minutes (0.033 hours) per request for the employer to copy the training record. (Table 12, line 14)
      CPHE Handler Pesticide Safety Training
      Handler pesticide safety trainings are the responsibility of the handler employer. Certified applicators do not need to take WPS handler training. The training time for CPHE handler training is estimated to take 60 minutes.
      EPA estimates that there are 1,936 commercial establishments that hire 14,320 handlers (D&B, 2014). EPA assumes that there will be an average of 1.3 training sessions per firm, given an average of over 7 handlers per firm and some turnover of employees. EPA, therefore, estimates a total of 2,517 training sessions per year.
      The training must be provided by persons designated by EPA, state or tribal pesticide enforcement agencies as a trainer of certified applicators or handlers; trainers that have completed an approved Train-the-Trainer course; or are certified applicators (40 CFR 171). EPA assumes that 14% of trainings will be conducted by trainers of certified applicators, accounting for 352 training sessions for 271 establishments; 10% of trainings will be conducted by trainers who completed a Train-the-Trainers program, accounting for 252 training sessions for 194 establishments; and 76% of trainings will be conducted by certified applicators, accounting for 1,913 training session for 1,471 establishments.  See lines 15-17. EPA assumes that none of the handlers are certified applicators, so all 14,320 handlers take the WPS safety training. (Table 12, line 18)
      Employers (numbering 1,936) are required to make a record of the training. Given the Agency's assumption about the average number of trainings per firm, the Agency calculates that there will be 2,517 training occasions necessitating a record. The estimated time burden for the agricultural establishment employer to collect signatures and file the records of training is 4 minutes (0.067 hours) per training occasion. See line 19. The record must be signed by the trained handler (numbering 14,320), which is assumed to take 30 seconds (0.0083 hours) per handler. (Table 12, line 20)
      The employer must maintain the record for 2 years and provide a record of the same information to the handler upon request. EPA estimates that 16% of handlers (2,291) will request a copy, given the new hire rate of 16%, assumed to represent the turnover rate of handlers. EPA assumes it takes about 2 minutes (0.033 hours) per request for the employer to copy the training record. (Table 12, line 21)
      EPA estimates that the average burden in terms of hours and costs for agricultural worker and handler employers to comply with this requirement is 2,252,912 hours and $ 67,055,858. (Table 12).

                      Table 12: Pesticide Safety Training
                                   Activity
                               Respondent Group
                             Number of Respondents
                           Total Responses Annually
                               Wage Rate ($/hr)
                               Per Event Average
                                    TOTALS

Burden (hours)
                                   Cost ($)
                                Burden (hours)
                             Cost              ($)

Train Workers on Pesticide Safety (Lines 1-3)
Trainers of Certified Applicators (14% of trainings)
                                    43,760
                                    72,588
                                     72.73
                                     0.75
                                     53.03
                                    54,441
                                   3,959,486

Trainers who completed a Train-the Trainer program (10% of  trainings)
                                    31,257
                                    51,859
                                     72.73
                                     0.75
                                     53.03
                                    38,887
                                   2,828,233

Certified Applicator of RUPs* (76% of trainings)
                                    237,551
                                    394,050
                                     51.50
                                     0.75
                                     37.63
                                    295,537
                                  15,220,164
 4. Attend worker pesticide safety training
Workers (minus trained handlers 181,135)
                                   1,728,919
                                   1,728,919
                                     16.75
                                     0.75
                                     10.98
1,296,689
                                  21,719,545
5. Record and maintain records of worker training
Agricultural establishment employers
                                    312,568
                                    518,863
                                     51.50
                                     0.12
                                     5.85
                                    60,490
                                   3,115,243
6. Sign Acknowledgement of worker training
Workers (minus trained handlers)
                                   1,728,919
                                   1,728,919
                                     16.75
                                    0.0083
                                     0.12
                                    14,408
                                    241,328
7. Provide copy of record upon request
Agricultural establishment employers
                                    312,568
                                    576,306
                                    51.507
                                     0.033
                                     1.66
                                    19,018
                                    979,565
8  -  10. Train handlers of agricultural establishments
Trainers of certified applicators(14% of trainings)
                                    18,819
                                    18,819
                                     72.73
                                     1.00
                                     70.77
                                    18,819
                                   1,368,706

Trainers who completed a Train-the-Trainer program (10% of trainings)
                                    13,442
                                    13,442
                                     72.73
                                     1.00
                                     70.77
                                    13,442
                                    977,658

Certified Applicator of RUPs* (76% of trainings)
                                    102,162
                                    102,162
                                     51.50
                                     1.00
                                     50.17
                                    102,162
                                   5,261,355
11. Attend handler training on agricultural establishment
Agricultural establishment handlers
                                    300,621
                                    300,621
                                     32.11
                                     1.00
                                     30.06
                                    300,621
                                   9,652,940
12. Record and maintain records of handler training (agricultural establishment)
Agricultural establishment employers with handlers (1.16 sessions where the 0.16 is the new hire rate)
                                    221,187
                                    256,577
                                     51.50
                                     0.07
                                     5.85
                                    17,105
                                    880,914
13. Sign Acknowledgement of worker training (receive a copy upon request)
Handlers of agricultural establishments
                                    300,621
                                    300,621
                                     32.11
                                    0.0083
                                     0.25
                                     2,505
                                    80,441
14. Provide copy of record upon request
Agricultural establishment employers
                                    221,187
                                    48,099
                                     51.50
                                     0.033
                                     1.66
                                     1,587
                                    81,744
15 -17. Train handlers of CPHEs
Trainers of certified applicators (14% of 2793*1.3)
                                      271
                                      352
                                     72.73
                                     1.00
                                     70.77
                                      352
                                    25,623

Trainers who completed a Train-the Trainer program (10% of 2793*1.30
                                      194
                                      252
                                     72.73
                                     1.00
                                     70.77
                                      252
                                    18,328

Certified Applicator of RUPs (76% of the 1.3 trainings by commercial certified applicators)
                                     1,471
                                     1,913
                                     46.61
                                     1.00
                                     48.98
                                     1,913
                                    89,165
18. Attend handler training on CPHEs
CPHE Handlers
                                    14,320
                                    14,320
                                     37.68
                                     1.00
                                     34.89
                                    14,320
                                    539,578
19. Record and Maintain records of handler training (CPHE)
CPHE employers (1.3 sessions per CPHE
                                     1,936
                                     2,517
                                     46.61
                                     0.07
                                     3.27
                                      168
                                     7,821
20. Sign acknowledgement of handler training
CPHE Handlers
                                    14,320
                                    14,320
                                     37.68
                                    0.0083
                                     0.29
                                      119
                                     4,496
Provide copy of record upon request
CPHE employers
                                     1,936
                                     2,291
                                     46.61
                                     0.033
                                     1.62
                                      76
                                     3,524
TOTALS

                                   2,121,277
                                   6,147,424

                                   2,252,912
                                  67,055,858
* assume certified applicator is the agricultural establishment employer. The number of respondents will often times be smaller than the responses because there are some activities within one Information Collection that will be done once and other activities within the same Information Collection that will be done multiple times.

		 (10) Personal Protective Equipment (PPE) Information

	The WPS includes requirements for agricultural employers and CPHE employers when certain PPE is used, such as training or instructions that must be provided to employees. In summary, the Agency estimates that the average burden in terms of hours and costs for agricultural establishment employers and their handler employees to comply with these requirements is 210,833 hours and $8,995,212. (Table 13 A)

      For family farms, the Agency estimates that the average burden is 10,643 hours and $ 548,113. (Table 13 B). Lastly, for CPHEs, the Agency estimates that the average burden in terms of hours and costs for CPHE employers and their handler employees is 21,217 hours and $987,505. (Table 13 C)

	The requirements and associated assumptions used to estimate the burden in terms of hours and costs are described below:

      Respirator Users: Medical Evaluation, Fit-Testing and Respirator Training (§170.507(b)(10))

      Agricultural handlers that use products with labeling that requires a respirator must complete a medical evaluation, respirator fit test, and respirator training. Handler employers are required to keep records documenting compliance for 2 years.
 EPA assumes the handler will spend about 30 minutes filling out the medical evaluation, available on-line.
 The fit test and training takes about 30 minutes, which the Agency assumes is taking at an off-farm testing center.
 EPA assumes an agricultural employer spends about one hour of time arranging the medical evaluation, fit test and training.
 EPA assumes that collecting and storing documentation takes the employer 4 minutes (0.07 hours) per handler.

      Agricultural Establishments.  EPA assumes that 75% of all large agricultural establishments (annual revenue of $750,000 or more) that primarily produce crops (NAICS 111) and hire labor will have one handler undergo respirator fit testing and training, thus 42,508 establishments and handlers. Further, 75% of large-small agricultural establishments (annual revenue between $100,000 and $750,000) that primarily produce vegetables (NAICS 1112), fruits and nuts (NAICS 1113), tobacco (11191), and cotton (11192), as well as nurseries and greenhouses (NAICS 1114) and hire labor will have one handler undergo respirator fit testing and training, thus 19,090 establishments and handlers. EPA assumes that establishments that primarily produce livestock (NAICS 112) and large-small farms that produce oilseeds and grain (NAICS 1111) and other crop production, such as forage (NAICS 11193, 11194, and 11199) are less likely to utilize products requiring a respirator. In total, the Agency calculates there will be 61,598 establishments and handlers subject to the requirement. (Table 13 A)

      Family Farms.   Establishments that do not hire workers or handlers (family farm) must also comply with the respirator fit requirements if they use products covered by the WPS that require a respirator. The handlers on these crop-producing establishments are an owner/operator or the immediate family of the owner/operator. EPA assumes that 40% of large family farms (annual revenue of $750,000 or more) that use pesticides and produce oilseeds and grain (NAICS 1111), vegetables (NAICS 1112), fruits and nuts (NAICS 1113), tobacco (11191), and cotton (11192), as well as nurseries and greenhouses (NAICS 1114) will have an operator/handler undergo respirator fit testing and training, thus 4,284 establishments and handlers. Further, 40% of large-small family farms (annual revenue between $100,000 and $750,000) that primarily produce vegetables (NAICS 1112), fruits and nuts (NAICS 1113), tobacco (11191), and cotton (11192), as well as nurseries and greenhouses (NAICS 1114) will have one operator/handler undergo respirator fit testing and training, thus 2,682 establishments and handlers. In total, the Agency calculates there will be 6,966 establishments and handlers subject to the requirement. (Table 13 B)

      CPHEs.  Commercial operations will already obtain respirator fit test and training under OSHA. Under the WPS, CPHE handler employers (1,936) are required to keep records documenting the completion of medical evaluation, respirator fit testing, and respirator training for their handlers that wear respirators. EPA assumes that half of all CPHEs handlers will use a respirator for pesticide products covered by the WPS resulting in 7,160 records. (Table 13 C)

      Cleaners of PPE (§170.507(d)(8))

      Handler employers are required to inform the person who cleans or launders PPE equipment or clothing that the PPE equipment or clothing may be contaminated with pesticides, the harmful effects of exposure to pesticides and the proper method to clean contaminated personal protective equipment or clothing and how to protect themselves. EPA assumes all 304,106 agricultural establishments using pesticides and all 1,936 CPHEs will have to provide this information once annually. The person who cleans or launders is assumed to be a handler. EPA estimates that it takes agricultural and CPHE employers 5 minutes to inform cleaner/launderer persons of this information. (Table 13 A)

      Closed Systems Instructions (§170.607(d))

      Agricultural establishment employers must create and make available at the mixing or loading site operating instructions for closed systems. The employer must ensure that any handler operating the closed system is trained in its use.
       EPA assumes that it takes the employer approximately 2 hours to write down the operating instructions, but that instructions would only have to be updated about every 5 years, for an annual burden of 0.4 hours.
       EPA assumes that the employer spends about 15 minutes (0.25 hours) to train a handler to use the system.

      Agricultural Establishments.  For agricultural establishments, EPA assumes that 50% of the large and establishments producing oilseeds and grain (NAICS 1111), vegetables (NAICS 1112), fruits and nuts (NAICS 1113), tobacco (NAICS 11191), and cotton (NAICS 11192), as well as nurseries and greenhouses (NAICS 1114) or 26,314 establishments will have a closed system. EPA further assumes that 40% of large-small agricultural establishments producing vegetables (NAICS 1112), fruits and nuts (NAICS 1113), tobacco (NAICS 11191), and cotton (NAICS 11192), as well as nurseries and greenhouses (NAICS 1114) or 10,182 establishments will have a closed system. Smaller agricultural establishments (annual revenue less than $100,000) would not typically own such a system. In total, therefore, EPA calculates there will be 36,496 establishments subject to the requirement. EPA assumes an equal number of handlers will receive the training, i.e., one operator per establishment. (Table 13 A)

      Family Farms.  For establishments that do not hire workers or handlers, i.e., rely on family labor, EPA assumes that one-third of large establishments (annual revenue of $750,000 or more) producing oilseeds and grain (NAICS 1111), vegetables (NAICS 1112), fruits and nuts (NAICS 1113), tobacco (11191), and cotton (11192), as well as nurseries and greenhouses (NAICS 1114) or 3,570 establishments will have a closed system.  Further, EPA assumes that the operator of all establishments trains one other family member in the operation of the system. (Table 13 B, Lines 4-6)

      CPHEs.  For CPHEs, EPA assumes that all 1,936 establishments have, on average 2 closed systems. Thus, they will create 3,872 sets of operating instructions.  EPA assumes that the firms will train, on average, 4 handlers to operate the system. For self-employed CPHEs (commercial applicators), the Agency assumes all of the estimated 40,336 firms will have 1 closed system. As these firms are assumed to have a single operator, there will not be training associated with these firms.

   Table 13 A:  PPE Information - Agricultural Establishments (hire workers)
                                   Activity
                               Respondent Group
                             Number of Respondents
                           Total Responses Annually
                               Wage Rate ($/hr)
                               Per Event Average
                                    TOTALS

                                Burden (hours)
                                   Cost ($)
                                Burden (hours)
                                   Cost  ($)

1. Agricultural Handler Respirator Training and Fit Test
Ag Establishment Handlers (assume 1 handler per large and large-small farm = 27.3% of handlers)
                                    61,598
                                    61,598
                                     32.11
                                     0.50
                                     15.03
                                    30,799
                                    988,956
2. Respirator Medical Evaluation
Ag Establishment Handlers
                                    61,598
                                    61,598
                                     32.11
                                     0.50
                                     15.03
                                    30,799
                                    988,956
3. Employer Administration of Respirator Fit Testing, training and medical evaluation
Ag Employer
                                    61,598
                                    61,598
                                     51.50
                                     1.00
                                     50.17
                                    61,598
                                   3,172,297
4. Record and Maintain Records
Ag Establishment Employer (assume all large and large small farms with handlers)
                                    61,598
                                    61,598
                                     51.50
                                     0.07
                                     3.34
                                     4,107
                                    211,486
5. Inform Cleaner /launderer
Ag Establishment Employer
                                    304,106
                                    304,106
                                     51.50
                                     0.083
                                     4.18
                                    25,342
                                   1,305,122
6. Cleaner/ launderer receives information
Cleaner/ launderer (assume 1 for each handler)
                                    304,106
                                    304,106
                                     32.11
                                     0.083
                                     4.18
                                    25,342
                                    813,737
7. Provide written operating instructions for closed system
Ag Employer (assume 50% of large and large-small farms)
                                    36,496
                                    36,496
                                     51.50
                                     0.40
                                     20.07
                                    14,598
                                    751,809
8. Provide Closed System Training
Ag  Establishment Employer
                                    36,496
                                    36,496
                                     51.50
                                     0.25
                                     12.54
                                     9,124
                                    469,881
9. Receive Closed System Training
Ag Establishment Handler
                                    36,496
                                    36,496
                                     32.11
                                     0.25
                                     7.52
                                     9,124
                                    292,968
10. TOTALS

                                    669,810
                                    964,091

                                    210,833
                                   8,995,212
*Estimates may not add due to rounding. Respondents are counted only once.

Table 13 B:  PPE Information - Agricultural Establishments without hiring workers or handlers
                                   Activity
                               Respondent Group
                             Number of Respondents
                           Total Responses Annually
                               Wage Rate ($/hr)
                               Per Event Average
                                    TOTALS

                                Burden (hours)
                                   Cost ($)
                                Burden (hours)
                                   Cost  ($)

1. Family Farms Respirator Training and Fit Test
Farm Operator
                                     6,966
                                     6,966
                                     51.50
                                     0.50
                                     25.09
                                     3,483
                                    179,364
2. Medical Evaluation
Farm Operator
                                     6,966
                                     6,966
                                     51.50
                                     0.50
                                     25.09
                                     3,483
                                    179,364
3. Record and Maintain Records
Farm Operator
                                     6,966
                                     6,966
                                     51.50
                                     0.07
                                     3.34
                                      464
                                    23,915
4.Provide written operating instructions for closed system
Farm Operator
                                     3,570
                                     3,570
                                     51.50
                                     0.40
                                     20.07
                                     1,428
                                    73,542
5. Provide Training for Closed Systems
Farm Operator
                                     3,570
                                     3,570
                                     51.50
                                     0.25
                                     12.54
                                      893
                                    45,964
6. Receive Training for Closed Systems
2[nd] Operator
                                     3,570
                                     3,570
                                     51.50
                                     0.25
                                     12.54
                                      893
                                    45,964
TOTALS

                                    10,536
                                    31,607

                                    10,643
                                    548,113
*Estimates may not add due to rounding. Respondents are counted only once.

        Table 13 C:  Personal Protective Equipment Information  - CPHEs
                                   Activity
                               Respondent Group
                             Number of Respondents
                           Total Responses Annually
                               Wage Rate ($/hr)
                               Per Event Average
                                    TOTALS

                                Burden (hours)
                                   Cost ($)
                                Burden (hours)
                                   Cost  ($)

1. Record and Maintain Records of Respirator  Fit Test and Training
CPHE Employer
                                     1,936
                                     7,160
                                     46.61
                                     0.07
                                     3.43
                                      501
                                    23,361
2. Inform Cleaner/ launderer
CPHE Employer (assumes 1 CPHE Cleaner/ Launderer/ CPHE)
                                    1,936
                                     1,936
                                     46.61
                                     0.083
                                     4.08
                                      161
                                     7,520
3. Cleaner/ launderer receives information
Cleaner/
launderer (assumes 1 CPHE Cleaner/
Launderer/ CPHE)
                                    1,936
                                     1,936
                                     37.68
                                     0.083
                                     2.91
                                      161
                                     6,079
4. CPHE Employer Provide written operating instructions for closed system
CPHE Employer
                                     1,936
                                    3,872
                                     46.61
                                     0.40
                                     19.99
                                     1,549
                                    72,190
5. CPHE Employer Provides Closed System Training
CPHE Employer
                                     1,936
                                     1,936
                                     46.61
                                     0.40
                                     19.99
                                      774
                                    36,095
6. CPHE Handler Receives Closed System Training
CPHE Handler (assumes 4 CPHE handlers/ CPHE)
                                     7,744
                                     7,744
                                     46.61
                                     0.25
                                     8.72
                                     1,936
                                    90,237
7. CPHE Self-Employed Provide written operating instructions for closed system
CPHE Employer
                                    40,336
                                    40,336
                                     46.61
                                     0.40
                                     19.99
                                    16,134
                                    752,024
TOTALS

                                    11,616
                                    64,920

                                    21,217
                                    987,505
*Estimates may not add due to rounding. Respondents are counted only once. The number of respondents will often times be smaller than the responses because there are some activities within one Information Collection that will be done once and other activities within the same Information Collection that will be done multiple times.

      (11) Exceptions/Exemptions (§170.605)

	Notification of Exceptions for Early - Entry Activities

	     If the agricultural employer directs a worker to perform activities in a treated area where an REI is in effect (i.e., early entry), the agricultural employer must notify the worker of certain required information regarding that entry, including the location of the early-entry area where work activities are to be performed, pesticide(s) applied, dates and times that the REI begins and ends, the exception to the regulation that allows the early entry description of the tasks performed under the exception, whether contact with treated surfaces is permitted, amount of time the worker is allowed in the treated area, PPE required by the labeling for early entry, and the location of the pesticide safety information and decontamination supplies. The employer must ensure that each early-entry worker has been informed of the labeling requirements and statements related to human hazards, precautions, first aid, and user safety and instructed in prevention, recognition, and first aid treatment of heat-related illness.

      EPA assumes that there will be an event necessitating early entry associated with one out of 50 pesticide applications. EPA further assumes that there are 20 pesticide applications per agricultural establishment per year, on average, implying a 40% chance of an event occurring on an establishment. Given 252,940 farms employing workers and using pesticides, the Agency estimates there will be 101,176 early entry events per year, on average. EPA assumes that it takes the agricultural employer 6 minutes (0.10 hours) on average to obtain the required information and another 6 minutes (0.10 hours) to provide it to the workers going into the treated area.

      EPA assumes that 50% of workers on an establishment will be involved in early entry activities should they occur. Given a 40% chance of an event occurring on an establishment, the Agency estimates that approximately 20% of the 1,742,988 workers employed on an agricultural establishment that applies pesticides, or 348,598 workers, are involved in early-entry events per year. As above, 6 minutes of each involved worker's time will be required for each oral notification during any early-entry events.

      EPA estimates that the total average burden in terms of hours and costs for agricultural employers and their worker/handler employees to comply with this requirement is 55,095 hours and $1,626,014. (Table 14)

        Table 14:  Notification of Exception for Early-Entry Activities
                                   Activity
                               Respondent Group
                             Number of Respondents
                           Total Responses Annually
                                   Wage Rate
                               Per Event Average
                                    TOTALS

                                (3-yr. average)
                                    ($/hr)
                                    Burden
                                     Cost
                                    Burden
                                     Cost

                                    (hours)
                                      ($)
                                    (hours)
                                      ($)
Gather information
Ag. Establishment Employer
                                    101,176
                                    101,176
                                     51.5
                                     0.10
                                     5.02
                                    10,118
                                    521,056
Provide Oral Notifications
Ag. Establishment Employer
                                    101,176
                                    101,176
                                     51.5
                                     0.10
                                     5.02
                                    10,118
                                    521,056
Receive Oral Notification
Ag. Worker ᵻ
                                    348,598
                                    348,598
                                     16.75
                                     0.10
                                     1.46
                                    34,860
                                    583,902
TOTALS

                                    449,774
                                    550,950

                                    55,095
                                   1,626,014
*Estimates may not add due to rounding. Respondents are counted only once.
ᵻ Assume 20% of 1,813,475 agricultural workers.

      6(c).	Estimating Agency Burden and Cost

      This ICR involves activities conducted by respondents, including notification to third parties. EPA does not conduct any activities or collect any information under this ICR so there is no Agency burden and cost to estimate.

      6(d).	Estimating the Total Burden and Costs

The following section provides the respondents' total burden and cost for the activities detailed in the previous tables. Using the estimates for the number of respondents for each activity and the associated per respondent burden and cost estimates derived in the preceding sections, the Agency calculated the total annual burden and costs (Table 15). Because the Agency does not collect information, the Agency does not have any associated burden or cost.

      6(e).	Total Annual Burden Hours and Cost Tables

            Table 15: Total Estimated Annual Burden Hours And Costs

                                     Hours
                                     Costs
Respondents
                                  10,448,160
                                 $433,264,055
Agency
                                      n/a
                                      n/a

      6(f).	Cross-walk of ICs to Supporting Statement

IC Title
Supporting Statement Crosswalk
1
Rule Familiarization
Table 4
2
Agricultural Employers Display Basic Safety Information
Table 5
3
Agricultural Employers Record/Maintain Pesticide Application Records and Copy of Safety Data Sheet and Provide upon Request
Table 6
4
Agricultural Employer Notifies Agricultural Workers of Restricted Entry Areas
Table 7
5
Agricultural Workers Receive Restricted Entry Area Notifications from Agricultural Employer
Table 7
6
Agricultural Employers Provide Establishment-Specific Information to Handlers and Agricultural Workers
Table 8
7
Agricultural Workers and Agricultural/Commercial Handlers Receive Establishment-Specific Information from Agricultural Employer
Table 8
8
Agricultural Employer Notification to Commercial Handler Employer of Restricted Entry Interval
Table 9
9
Commercial Handler Employer Notifies Handler Employee of Treated Areas under an REI on Agricultural Establishment
Table 9
10
Commercial Handler Receives Agricultural Establishment Restricted Entry Interval Information from Employer
Table 9
11
Agricultural and Commercial Handler Employers Inform Handlers about Application/Label Information
Table 9
12
Agricultural and Commercial Handler Employers Inform Handlers about Safe Operation, Cleaning and Repair of Equipment
Table 10
13
Handlers Receive Information About Safe Operation, Cleaning and Repair of Equipment from Agricultural and Commercial Handler Employers
Table 10
14
Agricultural and Commercial Handler Employers Provide Information Required for Emergency Assistance to Medical Personnel
Table 11
15
Agricultural Employers Provide Agricultural Worker Pesticide Safety Training
Table 12
16
Agricultural Workers Attend and Acknowledge Pesticide Safety Training Provided by Agricultural Employers
Table 12
17
Agricultural Employers Maintain Records of Agricultural Worker Pesticide Safety Training and Provide upon Request
Table 12
18
Agricultural Employers Provide Handler Pesticide Safety Training
Table 12
19
Agricultural Handler Employees Attend and Acknowledge Pesticide Safety Training Provided by Employers
Table 12
20
Agricultural Employers Maintain Records of Handler Pesticide Safety Training and Provide upon Request
Table 12
21
Commercial Handler Employers Provide Handler Pesticide Safety Training
Table 12
22
Commercial Handler Employees Attend and Acknowledge Pesticide Safety Training Provided by Employers
Table 12
23
Commercial Handler Employers Maintain Records of Handler Pesticide Safety Training
Table 12
24
Agricultural and Commercial Handlers Receive Respirator Training and Fit Test, and Complete Medical Evaluation
Table 13
25
Agricultural and Commercial Handler Employers Create and Maintain Medical Evaluation, Respirator Fit Testing, and Respirator Training Records
Table 13
26
Agricultural and Commercial Handler Employers Notify Cleaners/Launderers of Personal Protective Equipment of Potential Contamination, Adverse Effects, Cleaning Methods, and Precautions
Table 13
27
Agricultural and Commercial Employers Provide Training and Operating Instructions for Closed System
Table 13
28
Agricultural and Commercial Handlers Receive Training and Operating Instructions for Closed System
Table 13
29
REI - Early Entry Exception: Agricultural Employers Provide Early Entry Notification and Information to Agricultural Workers
Table 14
30
REI - Early Entry Exception: Agricultural Workers Receive Info Orally from Agricultural Employer
Table 14

      6(g).	Reasons for Changes in Burden

      The total estimated annual respondent burden for this renewal ICR is 10,448,160 hours. There is no change in the total estimated annual respondent burden from the previous ICR because the number of respondents for the WPS are based primarily on data EPA obtains from the USDA's Census of Agriculture, with the most recent being the 2012 Census. Therefore, the estimated number of potential respondents has remained unchanged until the next available census.

      The burden in this ICR reflects the many regulatory requirements in the WPS regulations, as well as estimates of the number of respondents/responses based on the most current information that is available to EPA. The regulatory requirements include modifications to restrictions in field entry activities during restricted entry intervals; increased hazard communications; increased training (for both workers and handlers); increased posting of pesticide application information; provisions for information during emergency assistance; and recordkeeping for training, application-specific information, and respirator requirements.

      6(h).	Burden Statement

      The total annual respondent burden for providing the training and notifications associated with the Agricultural Worker Protection Standard Regulations is estimated to be 10,448,160 hours. This total estimate includes the third party WPS training and notification requirements, e.g., provisions requiring employers to: provide employees with pesticide-specific treatment (application) information, ensure that employees receive basic pesticide safety training, provide emergency information on pesticide treatments, and notify employees when an exception/exemption to the WPS is being implemented, and provisions requiring handler notification to employers regarding pesticide treatments (applications), etc.

	The annual public reporting and recordkeeping burden for this collection of information is estimated to average about 6 minutes per response. Burden means the total time, effort, or financial resources expended by persons to generate, maintain, retain, or disclose or provide information to or for a Federal agency.  This includes the time needed to review instructions; develop, acquire, install, and utilize technology and systems for the purposes of collecting, validating, and verifying information, processing and maintaining information, and disclosing and providing information; adjust the existing ways to comply with any previously applicable instructions and requirements; train personnel to be able to respond to a collection of information; search data sources; complete and review the collection of information; and transmit or otherwise disclose the information.  An agency may not conduct or sponsor, and a person is not required to respond to, a collection of information unless it displays a currently valid OMB control number.  The OMB control numbers for EPA's regulations are listed in 40 CFR part 9 and 48 CFR chapter 15.

	To comment on the Agency's need for this information, the accuracy of the provided burden estimates, and any suggested methods for minimizing respondent burden, including the use of automated collection techniques, EPA has established a public docket for this ICR under Docket ID Number EPA-HQ-OPP-2018-0031, which is available for online viewing at www.regulations.gov, or in person viewing at the OPP Docket in the EPA Docket Center (EPA/DC), EPA West, Room 3334, 1301 Constitution Avenue, NW, Washington, D.C.  The EPA Docket Center Public Reading Room is open from 8:30 a.m. to 4:30 p.m., Monday through Friday, excluding legal holidays.  The telephone number for the Reading Room is<PHONE_NUMBER>, and the telephone number for the OPP Docket is<PHONE_NUMBER>.  An electronic version of the public docket is available at www.regulations.gov.  This site can be used to submit or view public comments, access the index listing of the contents of the public docket, and to access those documents in the public docket that are available electronically.  When in the system, select "search," then key in the Docket ID Number identified above.  Also, you can send comments to the Office of Information and Regulatory Affairs, Office of Management and Budget, 725 17th Street, NW, Washington, D.C. 20503, Attention: Desk Officer for EPA.  Please include the EPA Docket ID Number EPA-HQ-OPP-2018-0031 and OMB Control Number 2070-0190 in any correspondence.

7.	ATTACHMENTS TO THE SUPPORTING STATEMENT

Attachments to the supporting statement are available in the public docket established for this ICR under docket identification number EPA-HQ-OPP-2018-0031.  These attachments are available for online viewing at www.regulations.gov or otherwise accessed as described in section 6(h) of the supporting statement, and as noted below.

Attachment A:
[Reserved for "Record of Consultations"]
Attachment B:
Display Related to OMB Control #2070-0190  -  Listings of Related Regulations in 40 CFR 9.1