**Supporting Statement for a Request for OMB Review under**

**the Paperwork Reduction Act**

**1. IDENTIFICATION OF THE INFORMATION COLLECTION**

> **1(a) Title and Number of the Information Collection Request**

**Title: Reporting and Recordkeeping Requirements under EPA's
Hospitals**

**for a Healthy Environment (H2E) Program**

**EPA ICR No.: 2088.02 OMB Control No.: 2070-0166**

> **1(b) Short Characterization**

The Hospitals for a Healthy Environment (H2E) program is an
Environmental Protection Agency (EPA) voluntary program that helps
hospitals enhance work place safety, reduce waste and waste disposal
costs, and become better environmental stewards and neighbors. The
program is an outcome of a partnership between the American Hospital
Association (AHA) and EPA. More specifically, the program is based on a
1998 memorandum of understanding (MOU) (Attachment A) signed by AHA and
EPA to provide health care professionals the tools and information
necessary to reduce mercury waste, reduce the overall volume of waste,
and identify pollution prevention opportunities. Within EPA, the program
was developed and is managed by EPA's Office of Pollution Prevention and
Toxics (OPPT), Pollution Prevention Division.

Since its inception, the H2E program has received high-level recognition
in the Administration for the importance of the work, as well as from
industry for its vital role in providing important technical resources
to the health care sector. H2E has been the recipient of several EPA
awards.

Health care institutions stand to gain a great deal through
participation in the H2E program, including:

-   useful technical information that will assist them in reducing cost
    of waste disposal;

-   reducing waste burden; and

-   gaining public recognition.

The H2E program is divided into two sub-programs, the Partners for
Change program and the Champions for Change program. The Partners for
Change program recognizes health care facilities that pledge support to
the H2E mission and develop goals for reducing waste and mercury in
their own facilities. The Champions for Change program recognizes
organizations that encourage and aid health care facilities to
participate as H2E Partners, provide on-going promotional or technical
assistance information, or make changes that support the goals of the
H2E program in their own institutions. An organization's decision to
participate in the H2E program is completely voluntary. Participation
begins with the completion of and submittal to EPA of either a **Partner
Registration & Pledge Form** or a **Champion Registration & Pledge
Form** that provides EPA with general organizational information. A
senior administrator or official who has authority to commit his/her
organization to the program signs the forms. Once an organization joins
the Partners for Change program, it completes and submits to EPA an
**Annual Facility Assessment Summary and Goals Form**, which establishes
a baseline for the facility's performance and allows for tracking of
progress. The organization may use the **Data Collection Tool** to help
compile the information to complete the Annual Facility Assessment
Summary. Organizations have broad flexibility in designing their
facility environmental goals. Partners and Champions may also apply for
various H2E awards by submitting an **Awards Application Form**.

EPA expects new Partners to spend time up-front in establishing a solid
foundation for H2E initiatives by documenting their environmental
baseline when they first join H2E and by setting their own facility
performance goals, and allots six months for Partners to establish their
goals. During the first year and in all subsequent years, a Partner will
submit the **Annual Facility Assessment Summary and Goals Form.** This
form is designed to help a facility establish its own environmental
baseline, continue to track its own environmental progress, provide
basic contact and facility information, waste and mercury assessment
summaries, environmental policy information, and a description of its
pollution prevention (P2)/waste reduction goals and activities. EPA
expects organizations to implement their H2E programs and report on
their progress by January 31 of each subsequent year after joining,
unless less than nine months have passed since the initial submittal.
The **Annual Facility Assessment Summary and Goals Form** is the main
way Partners for Change report their environmental progress to EPA.

EPA collects the information in hard copy form or through an online
registration and reporting system and then enters and stores it in a
database. The information collection under the H2E program is necessary
to allow EPA to:

> \$ Gauge progress of individual facilities participating in the
> program, as well as the overall success of the program;
>
> \$ Recognize Partner accomplishments;
>
> \$ Identify effective P2/waste reduction strategies to share with
> others;
>
> \$ Identify areas where additional technical assistance or information
> would be useful for individual Partners or more generally for program
> participants;

\$ Measure environmental outcomes of actions taken by facilities;

> \$ Recognize participants with significant P2/waste reduction
> accomplishments at annual national recognition ceremonies;
>
> \$ Aggregate and analyze the data in order to monitor progress towards
> meeting of the EPA/AHA agreement; and
>
> \$ Evaluate opportunities for improving the H2E program.

Recognizing Partner achievements is important to help EPA spur other
Partners on to reduce more waste. Sharing effective P2/waste reduction
strategies with others is a fundamental objective of the H2E program.

The H2E Partners for Change program currently has 1,084 Partners
representing over 5,000 facilities. EPA expects program membership to
increase by 200 Partners for each year of this ICR. During the first
year of participation in the program, the information collection
activities will cost each Partner approximately \$912 if they choose to
submit an award application and \$232 if they do not. For each
subsequent year, the information collection activities will cost each
Partner approximately \$740 if they choose to submit an award
application, and \$60 if they do not. The Agency does, however, expect
many organizations to recognize substantial cost savings through the
implementation of their P2/waste reduction initiatives.

The H2E Champions for Change program currently has 98 Champions. During
the first year of participation in the program, the information
collection activities will cost each Champion approximately \$855 if
they choose to submit an award application and \$175 if they do not. For
each subsequent year, the information collection activities will cost
each Champion approximately \$698 if they choose to submit an award
application and \$18 if they do not.

**2. NEED FOR AND USE OF THE COLLECTION**

**2(a) Need/Authority for the Collection**

Section 6604(b)(5) of the Pollution Prevention Act (PPA), 42 U.S.C.
13103(b)(5), (Attachment B) directs EPA to facilitate the adoption of
source reduction techniques by businesses, including the distribution of
source reduction information to businesses. On June 24, 1998, the
American Hospital Association (AHA) and EPA signed a landmark memorandum
of understanding (MOU) identifying goals to reduce the impact of health
care facilities on the environment. The parties to the MOU affirmed the
Congressional goals and principles set forth in the PPA, 42 U.S.C. 13101
through 13109, particularly the goal of reducing the generation of
pollution at its source, preferentially to the recycling, treatment,
and/or disposal of such waste. More specifically, the MOU identifies
goals of the virtual elimination of mercury; reduction of persistent,
bioaccumulative and toxic (PBT) chemicals; and a thirty-three percent
reduction of total waste in all hospitals by 2005 and a fifty percent
reduction by 2010.

In conjunction with the American Nurses Association and Health Care
Without Harm, AHA and EPA implemented the MOU by developing the H2E
Partners for Change and Champions for Change programs. The H2E programs'
information collection activities assist the Agency in meeting the goals
of the PPA and the MOU by facilitating the education of health care
professionals about P2/waste reduction opportunities and the
distribution of necessary source reduction tools and information. More
specifically, EPA needs to collect initial information in the **Partner
Registration & Pledge Form** to formally establish participation in the
H2E Partners for Change program, obtain general information on new H2E
Partners, and obtain a pledge of commitment to H2E's goals. EPA needs to
collect the information in the **Annual Facility Assessment Summary and
Goals Form** in order to establish an environmental baseline for each
facility, measure each participant's efforts and progress over time,
gauge overall program progress in preventing pollution and reducing
waste, and identify effective P2/waste reduction strategies for other
participants in the program. To assist hospitals collect information in
a unified manner for reporting in the Annual Facility Assessment Summary
and Goals Form, H2E has designed the **Data Collection Tool**. The Data
Collection Tool is available to be used by the public but is not
required for completion of the Annual Facility Assessment Summary and
Goals Form.

For the H2E Champions for Change program, EPA needs to collect initial
information in the **Champion Registration & Pledge Form** to establish
participation in the Champion program, obtain general contact
information, and identify the activities each Champion will conduct to
achieve the program's goals.

Both Partners and Champions may apply for various annual or one-time H2E
awards. In order to evaluate the award candidates, EPA needs to collect
information in the **Awards Application Forms** about specific
activities related to the award category.

> **2(b) Practical Utility/Users of the Data**

The information collected by the H2E program is not designed or intended
to support regulatory decision-making by EPA. EPA uses the information
collected in the **Partner Registration & Pledge Form** to: (1) update
its database containing information on H2E participants; (2) initiate
contact with the primary person in charge of the Partner's H2E
initiatives; and (3) prepare a list of H2E Partners. The information in
the database is used to track organization status and prepare reports
and mailing lists.

EPA uses the information collected in the **Annual Facility Assessment
Summary and Goals Form** to: (1) establish an environmental baseline for
each Partner; (2) record the Partner's activities and progress in the
database; (3) identify effective P2 practices to develop and disseminate
as case studies and other materials or recommend to Partners seeking
effective P2 goals; (4) identify areas where additional technical
assistance or information would be useful for individual Partners or
more generally for program participants, e.g., low mercury elimination
figures may indicate a need for increased education about alternatives
to mercury-containing devices; (5) recognize participants with
significant P2 accomplishments at annual national recognition
ceremonies; (6) aggregate and analyze the data in order to prepare and
measure progress toward the goals of the MOU; and (7) evaluate
opportunities for improving the H2E program.

EPA uses the general information collected in the **Champion
Registration & Pledge Form** to: (1) update its database containing
information on H2E participants; (2) initiate contact with the primary
person in charge of the Champion's H2E initiatives; and (3) prepare a
list of H2E Champions. The information in the database is used to track
organization status and prepare reports and mailing lists. EPA uses the
information on the activities Champions are conducting to (1) record the
Champion's activities in the database; and (2) identify areas where
additional technical assistance or information would be useful for
individual Champions or more generally for program participants.

EPA uses the information collected in the **Awards Application Form** to
evaluate the achievements award candidates have made in specific areas.

**3. NON-DUPLICATION, CONSULTATIONS, AND OTHER COLLECTION CRITERIA**

> **3(a) Non-Duplication**

EPA ensures that respondents are not requested to provide information
that has been collected by EPA or any other Federal agency. Several
health care-related organizations are members of EPA's WasteWise
Program, which collects waste reduction data from all types of
businesses and organizations, and EPA's [Energy Star®]{.smallcaps}
energy efficiency program collects data on energy use and energy
efficiency activities by hospitals. EPA coordinates H2E with these
programs to ensure non-duplication of information collection.

Many states and EPA Regions have implemented programs that address P2
activities at hospitals and health care facilities or allow for the
collection of P2 information as part of a broader collection of
environmental performance information. In nearly all cases, these
programs were incorporated into, or are based on and directly linked to,
the H2E program. For example, Ohio EPA signed the Ohio Healthy Hospitals
Pollution Prevention Initiative with the Ohio Hospital Association,
based on the federal MOU signed by EPA and AHA. Other examples include
the EPA Region 1 Mercury Challenge and Health Care Without Harm/National
Wildlife Federation's Making Medicine Mercury Free Program. In these
cases, the programs are either incorporated within or fully coordinated
with the national H2E program to ensure nonduplication of information
collection. Currently, all ten EPA Regions have coordinated H2E
programs, and 20 States are H2E Champions and are coordinating with the
national H2E program.

Where appropriate, EPA will accept other programs' reporting forms in
lieu of the H2E **Annual Facility Assessment Summary and Goals Form.**

**3(b) Public Notice Required Prior to ICR Submission to OMB**

Prior to submission to the Office of Management and Budget (OMB), this
ICR will be made available to the public for comment through a Federal
Register notice. The public will have 60 days to provide comments. Any
comments received will be given consideration when completing the
supporting statement that is submitted to OMB.

> **3(c) Consultations**

EPA has received significant feedback on the H2E program from key
stakeholders. The H2E program has involved the efforts of representative
of several stakeholder groups including the American Hospital
Association, American Nurses Association, Health Care Without Harm,
state and local government agencies, state and metropolitan health care
associations, health care environmental services professionals, health
care materials managers, physicians, nurses, waste management industry
representatives, and product manufacturers.

The H2E effort is built upon the collaborative working relationship of
this network of Partners and their commitment to the goals of mercury
elimination and waste volume and toxicity reduction in hospitals. Prior
to the implementation of the H2E Partners for Change and Champions for
Change programs, efforts focused on forming the Environmental Leadership
Council (ELC), which consists of representatives from the stakeholder
groups listed above and serves as the oversight body for the project.
ELC representatives and other stakeholders provided guidance and
feedback on the content of the program forms and the corresponding
burden hour estimates***.*** ELC members and other stakeholders
generally agreed with the content and burden hour estimates for the
program forms. EPA also posted draft versions of the forms on the H2E
Web site ([www.h2e-online.org](http://www.h2e-online.org/)) and
solicited comments, but no comments were received

By gaining an understanding of current health care providers' practices
and barriers to environmental programs, EPA was able to structure the
H2E program to best suit participant needs and minimize the information
collection burden.

Specific individuals consulted include:

Mac Robinson American Hospital Association

Patti Costello American Society for Healthcare Environmental Services

Anna Gilmore-Hall Health Care Without Harm

Laura Brannen Health Care Without Harm

Pam Hagan American Nurses Association

Tom Griffin Virginia State Department of Environmental Protection

> **3(d) Effects of Less Frequent Collection**

The **Partner Registration & Pledge Form** and **Champion Registration &
Pledge Form** are one-time information submittals for organizations that
wish to participate in the H2E Partners for Change or Champions for
Change programs, and therefore could not be conducted less frequently.
Partners submit the **Annual Facility Assessment Summary and Goals
Form** on an annual basis. Requiring this report on a less frequent
basis would hinder EPA efforts to generate relevant and timely case
studies and success stories that would be helpful to participants.
Partners and Champions may choose to apply for annual and one-time
awards by submitting the **Awards Application Form.** Requiring this
information on a less frequent basis would hinder EPA efforts to
recognize outstanding achievements and progress in the annual H2E awards
ceremonies. Less frequent data collection would hinder EPA's ability to
gauge progress by individual organizations and the program as a whole
and to gain the information necessary to publicly recognize exemplary
Partner waste reduction activities. Most importantly, less frequent data
collection would severely hinder EPA's ability to measure the program's
success as it relates to the goals outlined in the MOU.

> **3(e) General Guidelines**

All of the collection activities described within this ICR adhere to
OMB's General Guidelines.

> **3(f) Confidentiality**

No information collected by EPA under the H2E program comprises
confidential business information.

**3(g) Sensitive Questions**

No questions of a sensitive nature are asked in any of the reporting
forms.

**4. THE RESPONDENTS AND THE INFORMATION REQUESTED**

> **4(a) Respondents and NAICS Codes**

The H2E Partners for Change program targets establishments primarily
engaged in furnishing medical, surgical and other health services to
individuals. Establishments of associations or groups, such as Health
Maintenance Organizations (HMOs), primarily engaged in providing medical
or other health services to members are targeted as Partners, but those
that limit their services to the provision of insurance against
hospitalization or medical costs participate as Champions. Individual
organizations may participate in the program as Partners and Champions.

While EPA focuses its H2E Partner marketing efforts on hospitals and
other health care provider organizations, the program is open to all
companies, organizations, schools, colleges, universities, and federal,
state, and local governments that are able to implement activities that
support the program's goals. The following is a list of North American
Industry Classification System (NAICS) codes and associated industries
that are most likely to be affected by information collection
requirements covered under this ICR:

[NAICS Codes]{.underline} [Affected Industry]{.underline}

6211 Offices of Physicians

> 6212 Offices of Dentists
>
> 6213 Offices of Other Health Practitioners

6214. Outpatient Care Centers

6215. Medical and Diagnostic Laboratories

> 339116 Dental Laboratories

6216. Home Health Care Services

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```
6219. Other Ambulatory Health Care Services

> 6221 General Medical and Surgical Hospitals

6222. Psychiatric and Substance Abuse Hospitals

6223. Specialty (except Psychiatric and Substance Abuse) Hospitals

```{=html}
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```
6231. Nursing Care Facilities

6232. Residential Mental Retardation, Mental Health, and Substance Abuse
      Facilities

6233. Community Care Facilities for the Elderly

> 6239 Other Residential Care Facilities

The H2E Champions for Change program targets a range of health
care-related organizations for recruitment as Champions, including
health systems, health care-related professional associations, Group
Purchasing Organizations (GPOs), member-based organizations that
champion the H2E Partners for Change program to their members (e.g.,
environmental groups, grassroots organizations), vendors, manufacturers,
consultants, and other service providers. Although these organizations
can fall under a wide range of industry sectors, most will come from the
codes listed above for Partners, or from the following NAICS codes:

#  NAICS Codes Associated Industry

8132 Grant-making and Giving Services

8133 Social Advocacy Organizations

8134 Civic and Social Organizations

8139 Business, Professional, Labor, Political, and Similar Organizations

> **4(b) Information Requested**

Once a prospective organization reviews the H2E Partners For Change
materials and decides to join the program, it submits a **Partner
Registration & Pledge Form** (Attachment C). By January 31 of each year,
Partners that joined the program by August 31 of the preceding year
report on the progress made toward achieving their goals on the **Annual
Facility Assessment Summary and Goals Form** (Attachment D).
Organizations that join the H2E Champions for Change program need only
submit the **Champion Registration & Pledge Form** (Attachment E) at the
time they join. Partners and Champions that wish to apply for awards are
required to submit the **Awards Application Form** (Attachment F) each
year in the spring, with specific dates varying each year.

All of the forms are available in hardcopy or electronic form.
Participants can use the hardcopy forms they receive from EPA by mail or
download PDF versions of the forms from the H2E Web site. Participants
will also be able to use the online registration and reporting system
(planned for 2006).

**Partner Registration & Pledge Form**

H2E Partners for Change program participants complete and submit to EPA
a standard, one-page **Partner Registration & Pledge Form** that
provides basic organization information.

> \(i\) [Data items]{.underline}:

The reporting items include:

> \$ Facility name, and Web site URL;
>
> \$ Description of facility and any relevant affiliations;
>
> \$ Name, title, address, phone number, fax number, and e-mail address
> of the Partner's primary contact person, purchasing contact person,
> and nursing contact person; and
>
> \$ Signature, name, and title of senior administrator and the date
> signed.
>
> \$ OPTIONAL: The Partner may provide additional information describing
> the organization's previous waste reduction efforts under other
> programs and previous waste assessment efforts.
>
> \(ii\) [Respondent activities]{.underline}:

Participants conduct the following activities in order to complete and
submit the **Partner Registration & Pledge Form**:

> \$ Review the H2E Partners for Change program information and overall
> H2E program information;
>
> \$ Decide whether to join the program;
>
> \$ Select a primary contact person for the program;
>
> \$ Complete the **Partner Registration & Pledge Form**, including
> obtaining the signature of a senior administrator; and
>
> \$ Submit the form through the online registration system.

**Annual Facility Assessment Summary and Goals Form**

H2E Partners for Change participants complete and submit to EPA a
standard, two-page **Annual Facility Assessment Summary and Goals Form**
that describes the Partner's P2/waste reduction goals and progress. This
form is due within six months of joining H2E (for new Partners) and by
January 31 of each subsequent year, unless less than nine months have
passed since submittal of the initial form.

> \(i\) [Data items]{.underline}:

The reporting items include:

> \$ **Section 1: Contact Information.**
>
> \-- Facility/System name;
>
> \-- Name, title, address, phone number, fax number, and e-mail address
> of the Partner's primary contact person; and
>
> \$ **Section 2: Facility Information.** The Partner completes the
> following data items depending on which facility type(s) are
> applicable:
>
> \-- If "In-Patient/Hospital" facility: number of adjusted patient
> days, number of beds, and number of staff;
>
> \-- If "Ambulatory Care/Outpatient Clinics" facility: number of
> outpatient visits and number of staff;
>
> \-- If "General Administrative" facility: number of staff;
>
> \-- If "Long Term Care" facility: number of beds and number of staff;
> and

\-- Number of FTEs employed at the facility.

> \$ **Section 3: Facility Waste Assessment Summary.**
>
> \-- Tons of solid waste generated per year, amount of solid waste as
> percent of total waste, and annual cost of solid waste management;
>
> \-- Tons of waste recycled/reused per year, amount of waste
> recycled/reused as percent of total waste, and annual cost of
> recycling/reuse activities;
>
> \-- Tons of regulated medical waste generated per year, amount of
> regulated medical waste as percent of total waste, and annual cost of
> regulated medical waste management;
>
> \-- Tons of hazardous waste generated per year, amount of hazardous
> waste as percent of total waste, and annual cost of hazardous waste
> management; and
>
> \-- Total tons of waste per year from all categories and annual cost
> of all waste management activities.
>
> \$ **Section 4: Mercury Assessment.** Partners answer "yes" or "no" to
> four mercury-related questions:
>
> \-- "Is your facility virtually mercury free?";
>
> \-- "Has your facility conducted a facility inventory of
> mercury-containing devices and chemicals?";
>
> \-- "Has your facility implemented a mercury purchasing policy?";
>
> \-- "Has your facility eliminated mercury-containing patient care
> devices?"; and
>
> \-- OPTIONAL: The Partner may provide a description of mercury
> elimination efforts to date.

\$ **Section 5: Environmental Policies.** Partners indicate whether or
not they have implemented each of the following by checking either the
"yes" or "no" box: a facility environmental commitment statement, a
comprehensive waste management policy, a mercury management/elimination
policy, and an environmentally preferable purchasing policy.

> \$ **Section 6: H2E Goals.** Partners are asked to list their H2E
> goals and describe source reduction, mercury elimination, recycling,
> reuse, and donation activities they will implement to achieve each
> goal.
>
> \-- The H2E goals the Partner plans to undertake and the source
> reduction, mercury elimination, recycling, reuse, and donation
> activities the Partner will implement to achieve each goal.

EPA assumes that participating organizations keep facility information,
waste assessment, and policy data as a common business practice. The
other data items do not require any record-keeping activities, and
therefore burden associated with recordkeeping is not included in this
ICR.

> \(ii\) [Respondent activities]{.underline}:

Participants conduct the following activities in order to complete and
submit the **Annual Facility Assessment Summary and Goals Form**:

> \$ Review the information contained in the H2E Self-Assessment Guide
> (available on the H2E Web site), which describes how to conduct
> baseline waste assessments and identify P2 opportunities;
>
> \$ Conduct at least a cursory review of materials used or disposed of
> by the organization (level of detail and effort will vary among
> organizations and may include establishing a P2/waste reduction team)
> to determine cost effective H2E goals;

\$ Set up a measurement/tracking system for P2/waste reduction
activities, if such a system is not already established (level of detail
and effort will vary among organizations);

\$ Collect and review records to assess progress during the reporting
year;

> \$ Complete the **Annual Facility Assessment Summary and Goals Form**;
>
> \$ Fax the completed form, or submit the form through the online
> reporting system; and
>
> \$ Respond to questions to clarify data and/or goals.

**Champion Registration & Pledge Form**

Champions complete and submit to EPA a standard, one-page **Champion
Registration & Pledge Form** that provides basic association information
and describes recruitment and promotional activities.

> \(i\) [Data items]{.underline}:

The reporting items include:

> \$ Organization name and Web site URL;
>
> \$ Name, title, address, phone number, fax number, and e-mail address
> of the Champion's principal contact person;
>
> \$ Approximate number of health care facilities associated with the
> organization;
>
> \$ Type of program that the organization belongs to;
>
> \$ Whether the organization in compliance with all OHSA and EPA
> regulations;
>
> \$ Planned recruitment, outreach and education, and internal P2/waste
> reduction activities; and
>
> \$ Signature, name, and title of senior official and the date signed.
>
> \(ii\) [Respondent activities]{.underline}:

Champions conduct the following activities in order to complete and
submit the **Champion Registration & Pledge Form**:

> \$ Review the H2E Champions for Change program information and overall
> H2E program information;
>
> \$ Select a primary contact person for the Champion H2E program;
>
> \$ Complete the **Champion Registration & Pledge Form**, including
> obtaining the signature of a senior official;
>
> \$ Plan and describe recruitment, outreach and education, and internal
> P2/waste reduction activities; and
>
> \$ Fax or submit the form through the online registration system.

**Awards Application Form**

H2E Partners for Change program participants may choose to complete and
submit a **Partners and Champions Awards Application Forms** that
provides basic organization information and designation of the award for
which the organization is applying. In addition, award applicants are
required to describe how their organization has met the evaluation
criteria for the award.

> \(i\) [Data items]{.underline}:

The reporting items include:

> \$ Date and facility name;
>
> \$ Name, title, department, address, phone number, fax number, and
> e-mail address of the organization's primary and secondary contact
> person;
>
> \$ Indication of whether or not the organization has received the
> award in the past;
>
> \$ Checklist of actions and materials required to complete award
> application packet; and
>
> \$ Signature and printed name of contact person.
>
> \(ii\) [Respondent activities]{.underline}:

Participants conduct the following activities in order to complete and
submit the **Awards Application Form**:

> \$ Select one of the following awards categories: H2E Partner
> Recognition, Making Medicine Mercury-Free Award, H2E Partners for
> Change Award, H2E Environmental Leadership Award, H2E Sustained
> Environmental Leadership Award, and H2E Champion Award;
>
> \$ Complete the **Awards Application Form**;
>
> \$ Describe how their organization meets the evaluation criteria for
> the award and submit checklist if applicable;
>
> \$ Submit supporting material such as photographs, newsletters,
> fliers, and policies; and
>
> \$ Fax or mail the form and supporting materials to EPA.

**5. THE INFORMATION COLLECTED\--AGENCY ACTIVITIES, COLLECTION
METHODOLOGY, AND INFORMATION MANAGEMENT**

> **5(a) Agency Activities**

Under the H2E program, EPA engages in the following activities related
to the four reporting forms:

**Partner Registration & Pledge Form**

> \$ Distribute the **Partner Registration & Pledge Form** to potential
> participants, maintain a downloadable PDF version on the H2E Web site,
> and make it available as part of an online registration system;
>
> \$ Answer questions posed by potential participants regarding
> membership in the program; and
>
> \$ Receive completed forms, enter information into a database, conduct
> quality assurance/quality control (QA/QC) on data entry, and place a
> welcome call to the new Partner.

**Annual Facility Assessment Summary and Goals Form**

> \$ Distribute the **Annual Facility Assessment Summary and Goals
> Form** to program Partners, maintain a downloadable PDF version on the
> H2E Web site, and make it available as part of an online reporting
> system;
>
> \$ Maintain a tracking system and develop/revise standard data
> reports;
>
> \$ Answer questions regarding the **Annual Facility Assessment Summary
> and Goals Form**;
>
> \$ Share information with interested Partners on possible goals for
> their organization;
>
> \$ Receive the completed forms, review for accuracy, and place any
> necessary follow-up calls;
>
> \$ Enter information into a database and conduct QA/QC on data entry;
> and
>
> \$ Develop and make publicly available an annual summary of overall
> program progress and case studies of highly successful programs.

##  Champion Registration & Pledge Form

> \$ Distribute the **Champion Registration & Pledge Form** to program
> Partners, maintain a downloadable PDF version on the H2E Web site, and
> make it available as part of an online registration system;
>
> \$ Answer questions posed by potential Champions regarding membership
> in the program; and
>
> \$ Receive completed forms, enter information into a database, conduct
> QA/QC on data entry, and place a welcome call to the new Champion.

##  Awards Application Form

> \$ Distribute the **Awards Application Form** to program participants
> when requested and maintain a downloadable PDF version on the H2E Web
> site;
>
> \$ Answer questions posed by potential award applicants regarding the
> awards and award application process;

\$ Receive completed forms and supporting materials and make award
selections; and

\$ Notify both successful and unsuccessful applicants of the award
decisions.

> **5(b) Collection Methodology and Management**

Respondents will be able to obtain the reporting forms in hardcopy from
EPA or by downloading them from the H2E Web site. The completed forms
can be faxed or mailed to EPA, or submitted through the online
registration system.

In collecting and analyzing the information associated with this ICR,
EPA uses a telephone system, personal computers, an online registration
and reporting system, and applicable database software. EPA ensures the
accuracy and completeness of collected information by reviewing each
submittal. EPA enters the information obtained from the forms into a
database and conducts QA/QC on data entry. The Agency uses software to
aggregate data obtained from **Annual Facility Assessment Summary and
Goals Forms.** The aggregate data are used to identify prominent
P2/waste reduction strategies, and to develop and publish an annual
summary of overall Partner progress and case studies of highly
successful P2/waste reduction activities.

> **5(c) Small Entity Flexibility**

EPA expects that some of the participants in the H2E program will be
small entities. EPA has designed its reporting forms to minimize
respondent burden while obtaining sufficient and accurate information.
Reporting will be further facilitated by the creation of an online
registration and reporting system, which was partially implemented in
2004. The H2E program was designed to be highly flexible. Organizations
can choose their own goals based on individual organization needs and
resources. In addition, the burden associated with the H2E program is
inherently reduced since the initial agreement to participate is
voluntary.

> **5(d) Collection Schedule**

Organizations may submit **Partner Registration & Pledge Forms** to join
the H2E Partners for Change program at any time. Within six months after
a participant joins the program, it should submit the **Annual Facility
Assessment Summary and Goals Forms**. **Annual Facility Assessment
Summary and Goals Forms** are also due to EPA by January 31 of every
subsequent year that the Partner participates in the program, unless
less than nine months have passed since submittal of the initial form.
Organizations may submit **Champion Registration & Pledge Forms** to
join the H2E Champions for Change program at any time. Partners and
Champions may choose to apply for awards by submitting the **Awards
Application Form**; award applications are due January 1 of each year.

**6. ESTIMATING THE BURDEN AND COST OF THE COLLECTION**

> **6(a) Estimating Respondent Burden**

Exhibit 6.1 presents the burden hours and costs for all respondents
during each of the three years covered under this ICR.

The **Partner Registration & Pledge Form** contains basic questions and
only applies for the first year, thus the burden is expected to be
minimal. The overall burden is estimated to be 1.7 hours per
participant. This burden level is an estimate based on EPA's experience
with other voluntary programs and based on the advice of H2E partnering
organizations. Burden hours for the **Partner Registration & Pledge
Form** are for reporting only.

Completing the **Annual Facility Assessment Summary and Goals Form**
involves assessing hospital waste and developing goals and a system to
track progress. The annual labor burden for this collection activity is
estimated at 5.25 hours per participant the first year and 1.75 hours
per participant in subsequent years. Burden hours for the **Annual
Facility Assessment Summary and Goals Form** are largely for reporting
activities, since the recordkeeping activities are considered to be
customary business practices.

The **Champion Registration & Pledge Form** asks for basic information
and requests brief/general descriptions of promotional activities thus
the burden is expected to be minimal. The overall burden, as shown in
Exhibit 6.1, is estimated to be 2.7 hours per participant. This burden
level is based on EPA experience with similar voluntary programs and
based on the advice of H2E partnering organizations. All burden hours
for the **Champion Registration & Pledge Form** are for reporting only.
In addition to answering basic questions similar to those listed on the
Partner registration and pledge form, the H2E Champions are requested to
plan and describe recruitment, outreach and education, and internal
P2/waste reduction activities. After the first year, Champions will be
asked to provide an informal update each year (no form required)
regarding the ways in which they promote the H2E program on a continued
basis. EPA estimates that the burden of this update will be 0.5 hours
per Champion per year.

EPA estimates that 10 percent of Partners and Champions will apply for
awards each year. The overall burden required to prepare supporting
application materials and to complete the **Awards Application Form** is
estimated to be 20 hours per applicant.

> **6(b) Estimating Respondent Costs**

EPA estimates an average hourly labor rate (hourly rate plus overhead)
of \$60 for managerial staff, \$35 for technical staff, and \$20 for
clerical staff. The hourly labor rates were provided by Dartmouth
Hitchcock Medical Center in Lebanon, New Hampshire, and reflect national
averages. It is presumed that technical staff will complete 80 percent
of the tasks listed in Exhibit 6.1, clerical staff will complete 15
percent, and managerial staff will complete 5 percent.

No capital or operations and management costs are incurred by
respondents under this ICR.

## Exhibit 6.1. Estimated Annual Burden and Costs to Respondents

+--------------------+--------+--------+----+-----+-----+----+------+
| **Collection       | *      | **Est  | *  |     |     |    | **T  |
| Activity**         | *Estim | imated | *T |     |     |    | OTAL |
|                    | ated** | resp   | OT |     |     |    | CO   |
|                    |        | onse** | AL |     |     |    | ST** |
|                    | **\#   |        | BU |     |     |    |      |
|                    | of     | **time | RD |     |     |    |      |
|                    | Respo  | in     | EN |     |     |    |      |
|                    | nses** | h      | ** |     |     |    |      |
|                    |        | ours** |    |     |     |    |      |
+====================+========+========+====+=====+=====+====+======+
|                    |        |        | *  | **  | **  | *  |      |
|                    |        |        | *M | T** | C** | *T |      |
|                    |        |        | ** |     |     | ot |      |
|                    |        |        |    | **( | **( | al |      |
|                    |        |        | ** | 80% | 15% | ** |      |
|                    |        |        | (5 | )** | )** |    |      |
|                    |        |        | %) |     |     | *  |      |
|                    |        |        | ** |     |     | *H |      |
|                    |        |        |    |     |     | ou |      |
|                    |        |        |    |     |     | rs |      |
|                    |        |        |    |     |     | ** |      |
+--------------------+--------+--------+----+-----+-----+----+------+
| **Partner          | 200    |        |    |     |     |    |      |
| Registration       |        |        |    |     |     |    |      |
| Form**             |        |        |    |     |     |    |      |
+--------------------+--------+--------+----+-----+-----+----+------+
| Review program     |        | 0.5    | 5  | 80  | 15  | 1  | \$   |
| information        |        |        |    |     |     | 00 | 3400 |
+--------------------+--------+--------+----+-----+-----+----+------+
| Obtain senior      |        | 1.0    | 10 | 160 | 30  | 2  | \$   |
| approval           |        |        |    |     |     | 00 | 6800 |
+--------------------+--------+--------+----+-----+-----+----+------+
| Complete and       |        | 0.2    | 2  | 32  | 6   | 40 | \$   |
| submit form        |        |        |    |     |     |    | 1360 |
+--------------------+--------+--------+----+-----+-----+----+------+
| ##### Subtotal     | *      | *      | ** | *   | **5 | *  | **\  |
|                    | *200** | *1.7** | 17 | *27 | 1** | *3 | $115 |
|                    |        |        | ** | 2** |     | 40 | 60** |
|                    |        |        |    |     |     | ** |      |
+--------------------+--------+--------+----+-----+-----+----+------+
|                    |        |        |    |     |     |    |      |
+--------------------+--------+--------+----+-----+-----+----+------+
| **Annual Facility  | 1000   |        |    |     |     |    |      |
| Assessment Summary |        |        |    |     |     |    |      |
| and Goals Form**   |        |        |    |     |     |    |      |
+--------------------+--------+--------+----+-----+-----+----+------+
| Review H2E         |        | 0.5    | 25 | 400 | 75  | 5  | \$1  |
| Assessment Guide   |        |        |    |     |     | 00 | 7000 |
+--------------------+--------+--------+----+-----+-----+----+------+
| Collect            |        | 4.0    | 2  | 3   | 600 | 40 | \$13 |
| data/review        |        |        | 00 | 200 |     | 00 | 6000 |
| records            |        |        |    |     |     |    |      |
+--------------------+--------+--------+----+-----+-----+----+------+
| Complete form      |        | 0.25   | 12 | 200 | 3   | 2  | \$   |
|                    |        |        | .5 |     | 7.5 | 50 | 8500 |
+--------------------+--------+--------+----+-----+-----+----+------+
| Fax/mail form to   |        | 0.25   | 12 | 200 | 3   | 2  | \$   |
| EPA                |        |        | .5 |     | 7.5 | 50 | 8500 |
+--------------------+--------+--------+----+-----+-----+----+------+
| Respond to EPA     |        | 0.25   | 12 | 200 | 3   | 2  | \$   |
| questions          |        |        | .5 |     | 7.5 | 50 | 8500 |
+--------------------+--------+--------+----+-----+-----+----+------+
| ##### Subtotal     | **     | **     | *  | **  | **7 | ** | **\$ |
|                    | 1000** | 5.25** | *2 | 420 | 87. | 52 | 1758 |
|                    |        |        | 62 | 0** | 5** | 50 | 00** |
|                    |        |        | .5 |     |     | ** |      |
|                    |        |        | ** |     |     |    |      |
+--------------------+--------+--------+----+-----+-----+----+------+
| #####              |        |        |    |     |     |    |      |
+--------------------+--------+--------+----+-----+-----+----+------+
| #                  | 1000   |        |    |     |     |    |      |
| #### Annual Facili |        |        |    |     |     |    |      |
| ty Assessment Summ |        |        |    |     |     |    |      |
| ary and Goals Form |        |        |    |     |     |    |      |
|                    |        |        |    |     |     |    |      |
| **(Subsequent      |        |        |    |     |     |    |      |
| Years)**           |        |        |    |     |     |    |      |
+--------------------+--------+--------+----+-----+-----+----+------+
| ##### Rev          |        | 0.5    | 25 | 400 | 75  | 5  | \$1  |
| iew previous goals |        |        |    |     |     | 00 | 7000 |
|  and set new goals |        |        |    |     |     |    |      |
+--------------------+--------+--------+----+-----+-----+----+------+
| ##### Collect data |        | 0.5    | 25 | 400 | 75  | 5  | \$1  |
|                    |        |        |    |     |     | 00 | 7000 |
+--------------------+--------+--------+----+-----+-----+----+------+
| #                  |        | 0.25   | 12 | 200 | 3   | 2  | \$   |
| #### Complete form |        |        | .5 |     | 7.5 | 50 | 8500 |
+--------------------+--------+--------+----+-----+-----+----+------+
| ##### Fa           |        | 0.25   | 12 | 200 | 3   | 2  | \$   |
| x/mail form to EPA |        |        | .5 |     | 7.5 | 50 | 8500 |
+--------------------+--------+--------+----+-----+-----+----+------+
| ##### Respon       |        | 0.25   | 12 | 200 | 3   | 2  | \$   |
| d to EPA questions |        |        | .5 |     | 7.5 | 50 | 8500 |
+--------------------+--------+--------+----+-----+-----+----+------+
| ##### Subtotal     | **     | **     | ** | **  | **2 | ** | **\  |
|                    | 1000** | 1.75** | 87 | 140 | 62. | 17 | $595 |
|                    |        |        | .5 | 0** | 5** | 50 | 00** |
|                    |        |        | ** |     |     | ** |      |
+--------------------+--------+--------+----+-----+-----+----+------+
| #####              |        |        |    |     |     |    |      |
+--------------------+--------+--------+----+-----+-----+----+------+
| #####              | 10     |        |    |     |     |    |      |
|  Champion Registra |        |        |    |     |     |    |      |
| tion / Update Form |        |        |    |     |     |    |      |
+--------------------+--------+--------+----+-----+-----+----+------+
| Review program     |        | 0.5    | 0. | 4.0 | 0   | 5  | \    |
| information        |        |        | 25 |     | .75 |    | $170 |
+--------------------+--------+--------+----+-----+-----+----+------+
| Obtain senior      |        | 1.0    | 0  | 8.0 | 1.5 | 10 | \    |
| approval           |        |        | .5 |     |     |    | $340 |
+--------------------+--------+--------+----+-----+-----+----+------+
| Identify           |        | 1.0    | 0  | 8.0 | 1.5 | 10 | \    |
| activities         |        |        | .5 |     |     |    | $340 |
+--------------------+--------+--------+----+-----+-----+----+------+
| Complete and       |        | 0.1    | 0. | 0.8 | 0   | 1  | \$34 |
| submit form        |        |        | 05 |     | .15 |    |      |
+--------------------+--------+--------+----+-----+-----+----+------+
| **Subtotal**       | **10** | *      | *  | **  | *   | ** | *    |
|                    |        | *2.6** | *1 | 20. | *3. | 26 | *\$8 |
|                    |        |        | .3 | 8** | 9** | ** | 84** |
|                    |        |        | ** |     |     |    |      |
+--------------------+--------+--------+----+-----+-----+----+------+
|                    |        |        |    |     |     |    |      |
+--------------------+--------+--------+----+-----+-----+----+------+
| **Awards           | 100    |        |    |     |     |    |      |
| Application Form** |        |        |    |     |     |    |      |
+--------------------+--------+--------+----+-----+-----+----+------+
| Select award       |        | 0.5    | 2  | 40  | 7.5 | 50 | \$   |
| category           |        |        | .5 |     |     |    | 1700 |
+--------------------+--------+--------+----+-----+-----+----+------+
| Complete Form      |        | 0.25   | 1. | 20  | 3   | 25 | \    |
|                    |        |        | 25 |     | .75 |    | $850 |
+--------------------+--------+--------+----+-----+-----+----+------+
| Describe how       |        | 18.0   | 90 | 1   | 270 | 18 | \$6  |
| organization meets |        |        |    | 440 |     | 00 | 1200 |
| evaluation         |        |        |    |     |     |    |      |
| criteria           |        |        |    |     |     |    |      |
+--------------------+--------+--------+----+-----+-----+----+------+
| Submit supporting  |        | 1.0    | 5  | 80  | 15  | 1  | \$   |
| materials          |        |        |    |     |     | 00 | 3400 |
+--------------------+--------+--------+----+-----+-----+----+------+
| Fax/mail form to   |        | 0.25   | 1. | 20  | 3   | 25 | 850  |
| EPA                |        |        | 25 |     | .75 |    |      |
+--------------------+--------+--------+----+-----+-----+----+------+
| **Subtotal**       | *      | **20** | *  | **  | *   | ** | **\  |
|                    | *100** |        | *1 | 160 | *30 | 20 | $680 |
|                    |        |        | 00 | 0** | 0** | 00 | 00** |
|                    |        |        | ** |     |     | ** |      |
+--------------------+--------+--------+----+-----+-----+----+------+
| **YEAR 1**         |        |        |    |     |     |    |      |
+--------------------+--------+--------+----+-----+-----+----+------+
| Partner            | 200    | 1.7    | 17 | 272 | 51  | 3  | \$1  |
| Registration Form  |        |        |    |     |     | 40 | 1560 |
+--------------------+--------+--------+----+-----+-----+----+------+
| Annual Facility    | 200    | 5.25   | 52 | 840 | 15  | 10 | \$3  |
| Assessment (First  |        |        | .5 |     | 7.5 | 50 | 5700 |
| Year)              |        |        |    |     |     |    |      |
+--------------------+--------+--------+----+-----+-----+----+------+
| Annual Facility    | 1000   | 1.75   | 87 | 1   | 26  | 17 | \$5  |
| Assessment         |        |        | .5 | 400 | 2.5 | 50 | 9500 |
|                    |        |        |    |     |     |    |      |
| (Subsequent Years) |        |        |    |     |     |    |      |
+--------------------+--------+--------+----+-----+-----+----+------+
| Champion           | 10     | 2.6    | 1  | 2   | 3.9 | 26 | \    |
| Registration Form  |        |        | .3 | 0.8 |     |    | $884 |
+--------------------+--------+--------+----+-----+-----+----+------+
| Awards Application | 100    | 20     | 1  | 1   | 300 | 20 | \$6  |
| Form               |        |        | 00 | 600 |     | 00 | 8000 |
+--------------------+--------+--------+----+-----+-----+----+------+
| #### TOTAL         | **     | **     | *  | *   | **7 | ** | **\$ |
|                    | 1510** | 31.3** | *2 | *41 | 74. | 51 | 1756 |
|                    |        |        | 58 | 32. | 9** | 66 | 44** |
|                    |        |        | .3 | 8** |     | ** |      |
|                    |        |        | ** |     |     |    |      |
+--------------------+--------+--------+----+-----+-----+----+------+
|                    |        |        |    |     |     |    |      |
+--------------------+--------+--------+----+-----+-----+----+------+
| **YEAR 2**         |        |        |    |     |     |    |      |
+--------------------+--------+--------+----+-----+-----+----+------+
| Partner            | 200    | 1.7    | 17 | 272 | 51  | 3  | \$1  |
| Registration Form  |        |        |    |     |     | 40 | 1560 |
+--------------------+--------+--------+----+-----+-----+----+------+
| Annual Facility    | 200    | 5.25   | 52 | 840 | 15  | 10 | \$3  |
| Assessment         |        |        | .5 |     | 7.5 | 50 | 5700 |
|                    |        |        |    |     |     |    |      |
| (First Year)       |        |        |    |     |     |    |      |
+--------------------+--------+--------+----+-----+-----+----+------+
| Annual Facility    | 1200   | 1.75   | 1  | 1   | 315 | 21 | \$7  |
| Assessment         |        |        | 05 | 680 |     | 00 | 1400 |
|                    |        |        |    |     |     |    |      |
| (Subsequent Year)  |        |        |    |     |     |    |      |
+--------------------+--------+--------+----+-----+-----+----+------+
| Champion           | 10     | 2.6    | 1  | 2   | 3.9 | 26 | \    |
| Registration Form  |        |        | .3 | 0.8 |     |    | $884 |
+--------------------+--------+--------+----+-----+-----+----+------+
| Champion Update    | 20     | 5.2    | 2  | 4   | 7.8 | 52 | \$   |
|                    |        |        | .6 | 1.6 |     |    | 1768 |
+--------------------+--------+--------+----+-----+-----+----+------+
| Awards Application | 100    | 20     | 1  | 1   | 300 | 20 | \$6  |
| Form               |        |        | 00 | 600 |     | 00 | 8000 |
+--------------------+--------+--------+----+-----+-----+----+------+
| **TOTAL**          | **     | **     | *  | *   | **8 | ** | **\$ |
|                    | 1730** | 36.5** | *2 | *44 | 35. | 55 | 1893 |
|                    |        |        | 78 | 54. | 2** | 68 | 12** |
|                    |        |        | .4 | 4** |     | ** |      |
|                    |        |        | ** |     |     |    |      |
+--------------------+--------+--------+----+-----+-----+----+------+
|                    |        |        |    |     |     |    |      |
+--------------------+--------+--------+----+-----+-----+----+------+
| **YEAR 3**         |        |        |    |     |     |    |      |
+--------------------+--------+--------+----+-----+-----+----+------+
| Partner            | 200    | 1.7    | 17 | 272 | 51  | 3  | \$1  |
| Registration Form  |        |        |    |     |     | 40 | 1560 |
+--------------------+--------+--------+----+-----+-----+----+------+
| Annual Facility    | 200    | 5.25   | 52 | 840 | 15  | 10 | \$3  |
| Assessment         |        |        | .5 |     | 7.5 | 50 | 5700 |
|                    |        |        |    |     |     |    |      |
| (First Year)       |        |        |    |     |     |    |      |
+--------------------+--------+--------+----+-----+-----+----+------+
| Annual Facility    | 1400   | 2.45   | 1  | 1   | 36  | 24 | \$8  |
| Assessment         |        |        | 22 | 960 | 7.5 | 50 | 3300 |
|                    |        |        | .5 |     |     |    |      |
| (Subsequent Year)  |        |        |    |     |     |    |      |
+--------------------+--------+--------+----+-----+-----+----+------+
| Champion           | 10     | 2.6    | 1  | 2   | 3.9 | 26 | \    |
| Registration Form  |        |        | .3 | 0.8 |     |    | $884 |
+--------------------+--------+--------+----+-----+-----+----+------+
| Champion Update    | 30     | 5.2    | 2  | 4   | 7.8 | 52 | \$   |
|                    |        |        | .6 | 1.6 |     |    | 1768 |
+--------------------+--------+--------+----+-----+-----+----+------+
| Awards Application | 100    | 20     | 1  | 1   | 300 | 20 | \$6  |
| Form               |        |        | 00 | 600 |     | 00 | 8000 |
+--------------------+--------+--------+----+-----+-----+----+------+
| **TOTAL**          | **     | **     | *  | *   | **8 | ** | **\$ |
|                    | 1940** | 37.2** | *2 | *47 | 87. | 59 | 2012 |
|                    |        |        | 95 | 34. | 7** | 18 | 12** |
|                    |        |        | .9 | 4** |     | ** |      |
|                    |        |        | ** |     |     |    |      |
+--------------------+--------+--------+----+-----+-----+----+------+
|                    |        |        |    |     |     |    |      |
+--------------------+--------+--------+----+-----+-----+----+------+
| **3-YEAR TOTAL**   | **     |        | *  | **  | *   | *  | **\$ |
|                    | 5180** |        | *8 | 133 | *24 | *1 | 5661 |
|                    |        |        | 32 | 21. | 97. | 66 | 68** |
|                    |        |        | .6 | 6** | 8** | 52 |      |
|                    |        |        | ** |     |     | ** |      |
+--------------------+--------+--------+----+-----+-----+----+------+

**6(c) Estimating the Respondent Universe and Total Burden and Costs
Burden**

EPA estimates that over the three-year life of the clearance, 600
hospitals will join the H2E program and complete the **Partner
Registration & Pledge Form** and **Annual Facility Assessment Summary
and Goals Form**. In addition, 30 Champions will complete the **Champion
Registration & Pledge Form** and updates. EPA estimates that Partners
and Champions will submit approximately 300 awards applications over the
three-year period. The total burden hours associated with this
information collection is 16,652 hours and \$566,168.

> **6(d) Estimating Agency Burden and Costs**

Exhibit 6.2 presents the estimated Agency burden hours and costs
associated with the information collection activities under this ICR.
Other direct costs (copying, printing, telephone, and mailing expenses)
are also included. EPA based its burden estimates on its experience
managing other voluntary programs.

Based on the general schedule (GS) pay schedule, EPA estimates an
average hourly labor rate (hourly rate plus the standard government
overhead factor of 1.6) of \$54 for managerial staff, \$39 for technical
staff, and \$18 for clerical staff. The Agency expects most activities
to be performed by managerial staff (25 percent) and technical staff (75
percent). When clerical staff is utilized, clerical activities will
constitute one percent of the work (with technical staff at 74 percent).

## Exhibit 6.2. Annual Agency Burden/Cost 

+--------------------+----------------+---------------+---------------+
| **Activities**     | **Hours**      | **Other       | **TOTAL       |
|                    |                | Direct        | COST**        |
|                    |                | Costs**       |               |
+====================+================+===============+===============+
| **Partner Pledge   | ##             |               |               |
| and Registration   |  For 200 forms |               |               |
| Form**             |                |               |               |
+--------------------+----------------+---------------+---------------+
| Distribute Forms   | **20**         | \$100         | \$950         |
+--------------------+----------------+---------------+---------------+
| Answer Questions   | **30**         | \$250         | \$1,533       |
+--------------------+----------------+---------------+---------------+
| Record/Enter Forms | **20**         | \$100         | \$950         |
+--------------------+----------------+---------------+---------------+
| Mail Partner       | **10**         | \$600         | \$988         |
| Packets            |                |               |               |
+--------------------+----------------+---------------+---------------+
| **Subtotal**       | **80**         | **\$1,050**   | **\$4,421**   |
+--------------------+----------------+---------------+---------------+
| **Annual Facility  | ##             |               |               |
| Assessment and     | For 1000 forms |               |               |
| Goals Form**       |                |               |               |
+--------------------+----------------+---------------+---------------+
| Distribute Form    | **40**         | \$200         | \$1900        |
+--------------------+----------------+---------------+---------------+
| Maintain Database  | **80**         | \$00          | \$3,500       |
+--------------------+----------------+---------------+---------------+
| Answer Questions   | **60**         | \$500         | \$3,066       |
+--------------------+----------------+---------------+---------------+
| Review Submitted   | **80**         | \$200         | \$3,600       |
| Data               |                |               |               |
+--------------------+----------------+---------------+---------------+
| Enter/QA Data in   | **100**        | \$100         | \$4,350       |
| Database           |                |               |               |
+--------------------+----------------+---------------+---------------+
| Develop Report/    | **80**         | \$300         | \$3,600       |
| Share Information  |                |               |               |
+--------------------+----------------+---------------+---------------+
| **Subtotal**       | **440**        | **\$1000**    | **\$16,416**  |
+--------------------+----------------+---------------+---------------+
| **Champion         | #              |               |               |
| Registration       | # For 50 forms |               |               |
| Form**             |                |               |               |
+--------------------+----------------+---------------+---------------+
| Distribute Forms   | **3**          | \$10          | \$217         |
+--------------------+----------------+---------------+---------------+
| Answer Questions   | **10**         | \$150         | \$578         |
+--------------------+----------------+---------------+---------------+
| Record/Enter Forms | **4**          | \$75          | \$246         |
+--------------------+----------------+---------------+---------------+
| Mail Champion      | **4**          | \$60          | \$455         |
| Packets            |                |               |               |
+--------------------+----------------+---------------+---------------+
| **Subtotal**       | **21**         | **\$295**     | **\$1,496**   |
+--------------------+----------------+---------------+---------------+
| **Awards           | **For 100      |               |               |
| Application Form** | forms**        |               |               |
+--------------------+----------------+---------------+---------------+
| Distribute Forms   | **8**          | \$28          | \$368         |
+--------------------+----------------+---------------+---------------+
| Answer Questions   | **20**         | \$200         | \$1,050       |
+--------------------+----------------+---------------+---------------+
| Make Award         | **10**         | \$150         | \$575         |
| Selections         |                |               |               |
+--------------------+----------------+---------------+---------------+
| Notify Applicants  | **4**          | \$28          | \$198         |
| of Decision        |                |               |               |
+--------------------+----------------+---------------+---------------+
| **Subtotal**       | **42**         | **\$406**     | **\$2,191**   |
+--------------------+----------------+---------------+---------------+
| **Year 1 Total**   | **583**        | **\$2,751**   | **\$27,805**  |
+--------------------+----------------+---------------+---------------+
| **Year 2 Total**   | **613**        | **\$2,893**   | **\$31,090**  |
+--------------------+----------------+---------------+---------------+
| **Year 3 Total**   | **643**        | **\$3,034**   | **\$34,374**  |
+--------------------+----------------+---------------+---------------+
| **3-Year Total**   | **1,839**      | **\$8,678**   | **\$93,269**  |
+--------------------+----------------+---------------+---------------+

**6(e) Bottom Line Burden Hours and Cost Tables**

> \(i\) Respondent Tally

## Exhibit 6.3. Average Annual Estimated Respondent Burden and Cost Summary

  -------------- --------------- ---------------------- --------------------
                 **AVERAGE \# OF **AVERAGE ANNUAL       **AVERAGE ANNUAL
                 RESPONDENTS**   BURDEN HOURS**         COST**

  **TOTAL**      1,727           5,501                  \$188,723
  -------------- --------------- ---------------------- --------------------

\(ii\) Agency Tally

**Exhibit 6.4.** Average Annual Estimated Agency Burden and Cost Summary

  ----------------- --------------------------- -------------------------
                    **ANNUAL BURDEN HOURS**     **ANNUAL COST**

  **TOTAL**         613                         \$31,090
  ----------------- --------------------------- -------------------------

**6(f) Reasons for Change in Burden**

There is a decrease of 4,609 hours (from 10,110 hours to 5,501 hours) in
the total estimated respondent burden compared with that identified in
the information collection most recently approved by OMB. The changes in
the burden estimates are based on actual program experience from
conducting the H2E program over the past three years. The number of new
Partner facilities recruited per year has been revised downward to
reflect average recruit numbers. Similarly, the number of award
applicants has also been revised downward to reflect the number of award
applications received per year.

**6(g) Burden Statement**

The annual public burden for this collection of information, which is
approved under OMB Control No. 2070-0166, is estimated to range between
0.5 and 20 hours per response, depending upon the type of information
the respondent provides. According to the Paperwork Reduction Act,
"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. For this collection it 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 number for this information
collection appears above. In addition, the OMB control numbers for EPA's
regulations, after initial display in the Federal Register, are listed
in 40 CFR part 9, as well as in any applicable collection instrument.

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 No.
EPA-HQ-OPPT-2005-0458, which is available for public viewing at the EPA
Public Reading Room, Room B102, EPA West Building, 1301 Constitution
Avenue, N.W., Washington, D.C., from 8:30 a.m. to 4:30 p.m., Monday
through Friday, excluding legal holidays (202-566-0280). An electronic
version of the public docket is available through the Federal Docket
Management System (FDMS) at
[www.regulations.gov](http://www.regulations.gov/). Use FDMS 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. Once 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, DC 20503,
Attention: Desk Office for EPA.

**ATTACHMENTS**

Attachment A. Memorandum of Understanding between AHA and EPA

Attachment B. Section 6604(b)(5) of the Pollution Prevention Act, 42
U.S.C. 13103(b)(5)

Attachment C. Partner Registration & Pledge Form

Attachment D. Annual Facility Assessment Summary and Goals Form

Attachment E. Champion Registration & Pledge Form

Attachment F. Awards Application Form

**ATTACHMENT A**

**MEMORANDUM OF UNDERSTANDING BETWEEN AHA AND EPA**

> **ATTACHMENT B**

**SECTION 6604(B)(5) OF THE POLLUTION PREVENTION ACT**

**42 U.S.C. 13103(b)(5)**

**ATTACHMENT C**

**PARTNER REGISTRATION & PLEDGE FORM**

**ATTACHMENT D**

**ANNUAL FACILITY ASSESSMENT SUMMARY AND GOALS FORM**

**ATTACHMENT E**

**CHAMPION REGISTRATION & PLEDGE FORM**

**ATTACHMENT F**

**AWARDS APPLICATION FORM**