FIFRA COOPERATIVE AGREEMENT GUIDANCE

Transcription

1 FIFRA COOPERATIVE AGREEMENT GUIDANCE Appendix 9 EPA Pesticide State/Tribal Cooperative Agreement Application Review Procedures D. Inspection & Laboratory Time Factor Guidelines SFIREG Arlington, VA December 12 & 13, 2016

2 Ø December, 2016: Final Opportunity To Revise Guidance (State & Tribal Decisions) INSPECTION & LABORATORY TIME FACTORS PROJECT - BACKGROUND Ø December, 2014: SFIREG Tribal EPA Workgroup Formed Ø April, 2015: Survey Distributed 17 States Responded Ø June, 2015: Preliminary Data SFIREG Ø December, 2015: Laboratory Data Refined & SFIREG Ø December, 2015: Final/Revised Decision Tabled SFIREG & EPA Maintain 85% - 115% Range

3 State: Summary Inspection Activities & Types 2016 Inspection Time Data Review Current Grant Hrs (A) % Range Inspection Time (B) Inspection Hours # Responses Travel Time (C) # Responses Enforcement Hours (D) # Responses Laboratory Hours (E) Ag Use Inspections Hrs /- 9 Hrs N = /- 1.2 Hrs N = /- 6.8 Hrs N = 11 Ag Follow-Up Inspections Hrs / Hrs N = /- 1.9 Hrs N = / Hrs N = 10 Non-Ag Use Inspections Hrs /- 7.4 Hrs N = /- 1.1 Hrs N = /- 5.9 Hrs N = 11 Non-Ag Follow-Up Inspections Hrs / Hrs N = /- 1.9 Hrs N = / Hrs N = 10 Experimental Use Inspections Hrs /- 6.2 Hrs N = /- 1.7 Hrs N = /- 3.8 Hrs N = 3 Containment Inspections (non-pei) UNK / Hrs N = /- 1.7 Hrs N = /- 4.7 Hrs N = 7 Applicator License & Records Inspections Hrs 7.8 +/- 6.8 Hrs N = /- 1.4 Hrs N = /- 3.6 Hrs N = 12 Dealer Records Inspections Hrs 9.0 +/- 7.7 Hrs N = /- 1.4 Hrs N = /- 4.1 Hrs N = 12 Federal Producer Establishment Inspections (PEI) Hrs / Hrs N = /- 1.6 Hrs N = /- 6.8 Hrs N = 7 Federal Marketplace Inspections Hrs /- 7.5 Hrs N = /- 1.2 Hrs N = /- 3.4 Hrs N = 6 Federal Import Inspections Hrs / Hrs N = /- 1.5 Hrs N = /- 1.1 Hrs N = 5 Federal Export Inspections Hrs /- 5.8 Hrs N = /- 1.3 Hrs N = /- 0.0 Hrs N = 2 Sample Analysis - UNK Residues (Established Matrix) NA NA NA 46 +/- 6 Hrs N = 2 Sample Analysis - UNK Residues (Difficult Matrix) NA NA 95 +/- 7 Hrs N = 2 Sample Analysis - Formulations Hrs NA NA 18 +/- 19 Hrs N = 15 Sample Analysis - Residues for Multiple Chemistries Hrs 20 +/- 17 Hrs N = 72 # Responses Survey Notes & Instructions: 1) Time Estimates For Each Category Include Overhead For Administrative, Clerical, Program Planning & Reporting Activities. 2) Can Your State Provide An Estimate/Range Of Variability For Inspection Times? (i.e. 80% to 12%) 3) Does Your State Have Recommendations For How Complicated Investigations (i.e. Pollinators & Drift) Are Accounted For? Please Provide Additional Responses. (A) (B) ( C ) Optional (D) ( E ) 1) Current Grant Inspection Hours Includes Enforcement Time. 2) Current Time Factors Based On 1997 SFIREG Survey Data. Inspection Hours Includes: Pre-Inspection Activities (targeting, scheduling & coordination), On-Site Inspection, Sample Shipment Preparation and Post-Inspection Activities (report writing). Travel Time Is Included If Not Reported As Specific/Separate Time Factor. Travel Time For Inspections Can Be Reported As Separate Component In States Where Remote Locations/Geography Are Significant Time Management Factor. Enforcement Hours Are An Average Of Time Needed Per Inspection For Cases Requiring Enforcement Specific Activities. Laboratory Hours Are An Average Of The Sample Numbers For Each Inspection Type. Laboratory Time Does NOT Include Sample Collection And Shipping Time Because Those Are Included As Part Of The Basic/Oringinal Inspection.

4 D. TIME FACTOR GUIDELINES (~PAGE #97) AS A RESULT OF A SURVEY CONDUCTED IN 1997, EPA, IN CONSULTATION WITH SFIREG, DEVELOPED THE FOLLOWING OUTPUT TIME FACTORS FOR USE AS A GUIDE IN EVALUATING PESTICIDES ENFORCEMENT COOPERATIVE AGREEMENT APPLICATIONS WITH REGARD TO INSPECTION AND SAMPLE ANALYSIS ACTIVITIES. THESE TIME FACTORS ARE USED FOR COMPARING THE NUMBER OF INSPECTIONAL AND/OR ANALYTICAL WORK HOURS TO BE FUNDED WITH THE NUMBER OF INSPECTIONS TO BE CONDUCTED AND THE NUMBER OF SAMPLES TO BE COLLECTED AND/OR ANALYZED. THE TIME FACTOR VALUES SHOULD TAKE INTO ACCOUNT ALL INSPECTION OR ANALYTICAL TIME SPENT TO COMPLETE AN ACTIVITY, INCLUDING TRAVEL TIME, DOCUMENT PREPARATION, SAMPLE SHIPMENT, ETC. THE WORK HOURS SHOULD ALSO INCLUDE THE PRORATED TIME FOR ADMINISTRATIVE ACTIVITIES OF INSPECTORS AND CHEMISTS. IN GENERAL, ONLY THE INSPECTION AND ANALYTICAL WORK HOURS SHOULD BE USED TO CALCULATE PRODUCTIVITY LEVELS. ADDITIONAL TIME SPENT BY STAFF OTHER THAN INSPECTORS OR CHEMISTS FOR ADMINISTRATIVE, CASE PREPARATION, LEGAL, CLERICAL, AND PROGRAM PLANNING ACTIVITIES TIME MAY BE CHARGED IF THE ACTIVITIES ARE PREREQUISITES TO CONDUCTING THE ACTIVITY. REGIONS WILL USE THE TIME FACTORS AS A GUIDE FOR NEGOTIATING AND EVALUATING PESTICIDE ENFORCEMENT APPLICATIONS. WITH REGARD TO INSPECTION AND SAMPLING ACTIVITIES, THE PROJECTED NUMBER OF INSPECTIONS, SAMPLES, AND ANALYSES MULTIPLIED BY THE ESTABLISHED TIME FACTORS SHOULD APPROXIMATELY EQUAL THE NUMBER OF WORK HOURS WHICH EACH GRANTEE REQUESTED TO COMPLETE THE PROJECTED OUTPUTS UNDER THE COOPERATIVE AG REEMENT. THE AGENCY CONSIDERS PRODUCTIVITY LEVELS BETWEEN 85% AND 115% OF THE ESTABLISHED STANDARD TO BE IN THE ACCEPTABLE RANGE. IT IS UNDERSTOOD THAT DEVIATIONS FROM THESE TIME FACTORS MAY OCCUR BECAUSE OF DIFFERENCES IN TRAVEL TIME, LOCAL PROCEDURES, ETC. TO ENSURE EQUAL TREATMENT OF ALL GRANTEES, A NORMAL WORK YEAR CONSISTS OF 1800 HOURS AFTER ALLOWING FOR LEAVE AND HOLIDAYS.

5 TOPICS FOR DECISION-MAKING Ø Inspection Time Factors: Retain or Revise? Hours or Range? State or Tribal Factors? Ø Time Factor Narrative: A Different Approach? Ø Enforcement Time Factors: Included In Inspections or Not? How To Utilize This Data Element? Ø Travel Time Factors: Inspection Hours Adjustment? Regional Negotiation Topic? Geography Abundant States (Only)? Ø Lab Analysis Data: How To Use This Data?

6 TOPICS FOR DECISION-MAKING Ø Inspection Time Factors: Revision Options (Multiple Choice) State: Summary Inspection Activities & Types Current Grant Hrs (A) % Range Inspection Hours Enforcement Laboratory Inspection Time (B) Travel Time (C) Inspection Hours (D) Hours (E) (Only) % Range Proposed Grant Hrs Inspection & Travel Inspection & Enforcement Ag Use Inspections Hrs /- 9 Hrs 2.4 +/- 1.2 Hrs 7.9 +/- 6.8 Hrs Hrs Ag Follow-Up Inspections Hrs / Hrs 2.7 +/- 1.9 Hrs / Hrs Hrs Non-Ag Use Inspections Hrs /- 7.4 Hrs 2.4 +/- 1.1 Hrs 7.5 +/- 5.9 Hrs Hrs Non-Ag Follow-Up Inspections Hrs / Hrs 2.7 +/- 1.9 Hrs / Hrs Hrs Experimental Use Inspections Hrs /- 6.2 Hrs 3.1 +/- 1.7 Hrs 5.7 +/- 3.8 Hrs Hrs Containment Inspections (non-pei) UNK / Hrs 2.8 +/- 1.7 Hrs 6.3 +/- 4.7 Hrs Hrs Applicator License & Records Inspections Hrs 7.8 +/- 6.8 Hrs 2.4 +/- 1.4 Hrs 5.7 +/- 3.6 Hrs Hrs Dealer Records Inspections Hrs 9.0 +/- 7.7 Hrs 2.4 +/- 1.4 Hrs 5.9 +/- 4.1 Hrs Hrs Federal Producer Establishment Inspections (PEI) Hrs / Hrs 2.9 +/- 1.6 Hrs 6.1 +/- 6.8 Hrs Hrs Federal Marketplace Inspections Hrs /- 7.5 Hrs 2.8 +/- 1.2 Hrs 5.5 +/- 3.4 Hrs Hrs Federal Import Inspections Hrs / Hrs 3.4 +/- 1.5 Hrs 3.2 +/- 1.1 Hrs Hrs Federal Export Inspections Hrs /- 5.8 Hrs 2.6 +/- 1.3 Hrs 3.0 +/- 0.0 Hrs Hrs Sample Analysis - UNK Residues (Established Matrix) NA NA NA 46 +/- 6 Hrs Sample Analysis - UNK Residues (Difficult Matrix) NA NA 95 +/- 7 Hrs Sample Analysis - Formulations Hrs NA NA 18 +/- 19 Hrs Sample Analysis - Residues for Multiple Chemistries Hrs 20 +/- 17 Hrs Inspection, Travel & Enforcement