**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**

    **Title: Reporting Requirements under the EPA's Design for the
    Environment (DfE) Formulator Product Recognition Program**

    **EPA ICR No.: 2302.01 OMB Control No.: 2070-NEW**

    **1(b) Short Characterization**

DfE's Formulator Product Recognition Program (Formulator Program)
recognizes safer products where all ingredients have an environmental
and human health profile showing that they are the safest in their
functional use class. Under the encouragement of the current Formulator
Program, leading companies have already made great progress in
developing safer, highly effective chemical products. Since the
program's inception in 1997, formulators have been using the program as
a portal to OPPT's unique chemical expertise, information resources, and
guidance on greener chemistry. DfE Formulator partners enjoy Agency
recognition, including the use of the DfE logo on products with the
safest possible formulations. In the next three years, DfE expects much
greater program participation due to rising demand for safer products.
This ICR would enable DfE to accommodate participation by more than nine
formulators each year and enhance program transparency.

DfE participates in the development of CleanGredients™, a database of
safer cleaning product ingredients, which identifies safer formulations
and makes forming partnerships easier. Organized by product functional
use class (e.g., surfactants, solvents, etc.), CleanGredients™
facilitates a green marketplace where formulators can select
functionally appropriate and safer ingredients.

The redesign of chemical products offers opportunities to:

-   Remove hazardous chemicals from formulations before they can enter
    the workplace, home, or environment.

-   Advance energy and water efficiency, resource conservation, and
    innovative technologies.

-   Qualify for environmentally preferred product status, increasingly
    sought by government, retailer and consumer purchasers.

Companies formulate products from a broad range of chemicals with a
variety of applications. The Formulator Program is particularly involved
with safer cleaning products, holding tank treatments/deodorizers,
industrial coatings, and inks. Cleaning products make up the majority of
partnership products, and cleaning product manufacturers make up the
lion's share of demand for program participation by potential partners.
Third-party profilers review all cleaning product applications prior to
DfE submission. All other product applications are submitted directly to
DfE for review.

The review team applies the DfE assessment methodology, as described in
Attachment B, by carefully reviewing each product component. A
literature review, and when appropriate, structural activity
relationships, are used to understand each chemical's health and
environmental characteristics. The review includes all chemicals,
including those in proprietary raw material blends, which ingredient
suppliers share with DfE in confidentiality. The review team then
compares an ingredient's characteristics to other chemicals in the same
use class, considers possible negative synergies between ingredients,
and places the ingredient on a continuum of improvement relative to
other similar chemicals. Through its review team and methodology, DfE
provides information to formulators that helps them select from among
the safest chemicals in an ingredient class. Only formulations
containing exclusively safer ingredients are recognized by DfE.

# 2. NEED FOR AND USE OF THE COLLECTION

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

Authority for the Formulator Program derives from Section 6604(b)(5) of
the Pollution Prevention Act (PPA), 42 U.S.C. 13103(b)(5) \[see
Attachment A\], which directs EPA to facilitate the adoption of
source-reduction techniques by businesses, and the Toxic Substances
Control Act (15 U.S.C. 2601 et seq.), which encourages safety in
technological innovation in chemistry. In recognition of this statutory
directive, and through consultation with a broad range of stakeholders,
EPA developed the Formulator Program.

Formulator Program information collection activities will assist the
Agency in meeting the goals of the PPA by providing resources and
recognition for businesses committed to promoting and using safer
chemical products. In turn, the Formulator Program will help businesses
meet corporate sustainability goals by providing the means to, and an
objective measure of, environmental stewardship. Investment analysts and
advisers seek these types of measures in evaluating a corporation's
sustainability profile and investment worthiness.[^1] It is not
surprising then that EPA has heard from many organizations that
Formulator Program partnership is an important impetus for prioritizing
and completing the transition to safer chemical products. The Formulator
Program is also needed to promote greater use of safer chemical products
by companies unaware of the benefits of such a change.

DfE has carefully tailored its request for information, and especially
the Formulator application forms, to ensure that it only asks for
information essential to verifying applicants' eligibility for
recognition.

# 

##  2(b) Practical Utility/Users of the Data

The information collected by the Formulator Program is not designed or
intended to support regulatory decision-making by EPA. EPA uses the
information collected in the Formulator Program application forms to:
(1) review cleaning or other products and their components; (2) complete
chemical profiles for each product component to determine its key health
and environmental characteristics; and (3) establish a partnership
agreement with the company outlining how the company and EPA/DfE will
work together to continually improve the health and environmental
profile of the product(s).

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

##  3(a) Non-Duplication

Respondents will not be asked to provide information that has been or is
currently being collected by EPA, other federal or state agencies, or
proprietary sources. The information collected by the Formulator Program
is unique and is not duplicative of previous information collection
requests. As due diligence, EPA also checked with trade associations and
potential partners to confirm that the information being collected by
the Formulator Program does not exist elsewhere.

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

## 

Prior to submission to 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 consulted with potential respondents who manufacture cleaning and
other products made of chemical mixtures to get feedback on the
reasonableness of EPA's cost and burden estimates. EPA asked the
following questions:

-   Please provide your best estimate regarding how long it would take
    to complete the application in terms of total hours. 

-   We are also interested in how many personnel (i.e., clerical,
    technical, and managerial) it would take for applicants to review
    the program information, obtain approval from senior management and
    complete the form. 

-   In addition, please provide us with any constructive criticism /
    comments you might have regarding the application itself, questions
    posed, instructions, description of the program, etc.

EPA received feedback from the following individuals:

-   Jim McCabe, Clorox, 925-425-6674

-   Charles Reeves, Sentry Chemical, 770-723-7040

-   Victoria Finley, Osprey Biotechnics, 941-351-2700 ext. 111

-   Richard Cottrell, SYSCO, 281-584-1793

    These individuals were supportive of the ICR and said the burden
    estimates appeared reasonable. Therefore, EPA made no changes to the
    information in this supporting statement.

    Additionally, under 5 CFR 1320.8(d)(1) OMB requires agencies to
    consult with potential ICR respondents and data users about specific
    aspects of ICRs before submitting an original or renewal ICR OMB for
    review and approval. In accordance with this regulation, EPA will
    pursue additional consultations with interested parties during the
    development of the renewal of this collection.

##  3(d) Effects of Less Frequent Collection

The Formulator application forms are designed to be a one-time
information submission for organizations that wish to participate in the
Formulator Program, with the opportunity to renew the partnership
agreement at the end of the three-year partnership period. This means
that once every three years, the organization will re-submit their
application forms to confirm that no changes have been made to
ingredients; this step is done in response to correspondence from DfE
that reminds organizations of the terms of their partnership agreements.
If a formulator wishes to submit additional products for recognition
during the course of the three-year partnership, the same application
form would be used. Without this information collection mechanism, DfE
will not have the ability to assist formulators in developing safer,
highly effective chemical products or to formally recognize formulators
who have successfully done so.

##  3(e) General Guidelines

The information collection activities discussed in this renewal ICR
comply with all regulatory guidelines under 5 CFR 1320.5(d)(2).

##  3(f) Confidentiality

Some information collected by EPA under the Formulator Program involves
confidential business or trade secret information. The Formulator
Program handles all information claimed as such as confidential business
information in accordance with Agency confidentiality procedures (see 40
CFR part 2, subpart B). The Formulator Program uses information provided
by formulators solely for purposes related to forming the partnership
and discloses the information only to EPA employees and EPA contractors
cleared for confidential information with a specific need to know.

##  3(g) Sensitive Questions

The information collection activities discussed in this document do not
involve any sensitive questions.

# 4. THE RESPONDENTS AND THE INFORMATION REQUESTED

##  4(a) Respondents and NAICS Codes

The Formulator Program seeks partners from establishments engaged in the
formulation of end-use, for-sale chemical products.

Below is a list of North American Industry Classification System (NAICS)
codes and associated industries that may be affected by information
collection requirements covered under this ICR. This list is intended to
be illustrative; entities from other industries may elect to apply for
recognition through the Formulator Program. However, EPA expects that
most applications will come from the following industries:

+-----------+----------------------------------------------------------+
| [NAICS    | > [Affected Industry]{.underline}                        |
| Code]{.u  |                                                          |
| nderline} |                                                          |
+-----------+----------------------------------------------------------+
| 325510    | Paint and Coating Manufacturing                          |
+-----------+----------------------------------------------------------+
| 325611    | Soap and Other Detergent Manufacturing                   |
+-----------+----------------------------------------------------------+
| 325612    | Polish and Other Sanitation Good Manufacturing           |
+-----------+----------------------------------------------------------+
| 325910    | Printing Ink Manufacturing                               |
+-----------+----------------------------------------------------------+
| 325992    | Photographic Film, Paper, Plate, and Chemical            |
|           | Manufacturing                                            |
+-----------+----------------------------------------------------------+
| 325998    | All Other Miscellaneous Chemical Product and Preparation |
|           |                                                          |
|           | Manufacturing                                            |
+-----------+----------------------------------------------------------+

##  4(b) Information Requested

Once a company with an interest in partnership with the Formulator
Program reviews the program materials and decides to apply, the next
step for the organization is to submit the appropriate application form.
Cleaning product manufacturers will submit an Ingredient Information
Request Form to a qualified third-party profiler before submittal to
DfE. (See Attachment C for this third-party application form.) Holding
tank treatment/deodorizing, industrial coating, ink products, and other
manufacturers of innovative and environmentally safer products will
submit an Ingredient Worksheet Form directly to DfE (see Attachment D).
Applications will be received on an ongoing basis over the three years
covered by this ICR.

All forms will be available in hard copy or electronic form.
Participants can use the hard copy forms they receive from EPA by mail
or download PDF versions of the forms from the DfE or third-party
profiler Web sites.

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

The reporting items include:

-   Company name and Web site URL;

-   Name, title, address, phone number, fax number, and e-mail address
    of the candidate's primary contact person;

-   Signature, name, and title of senior company authority (e.g., CEO,
    or vice president for health and environment);

-   Description of all chemical ingredients in product;

-   An MSDS for the product and each ingredient;

-   Product performance testing (any method of demonstrating product
    performance is acceptable as long as it is a commonly used industry
    standard); and

-   Production volume of all products submitted for recognition.

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

Candidates conduct the following activities in order to complete and
submit the appropriate Formulator Program application form:

-   Review the Formulator Program application and program information;

-   If a formulator of cleaning products: fill out and submit 3^rd^
    party information request form, and establish agreement with 3^rd^
    party to review cleaning product application;

-   If not a formulator of cleaning products, submit chemical
    information to DfE;

-   If a formulator of cleaning products: Submit 3^rd^-party generated
    chemical summary report to DfE;

-   Establish partnership agreement with DfE; and

-   Provide relevant documentation to EPA upon request.

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

##  5(a) Agency Activities

Under the Formulator Program, EPA engages in the following activities
related to the Formulator application and decision process.

-   Distribute forms to potential participants, and maintain
    downloadable PDF versions on the Formulator Program Web site;

```{=html}
<!-- -->
```
-   Answer questions posed by potential applicants regarding recognition
    under the Program;

-   Receive the completed forms, review for accuracy, and place any
    necessary follow-up calls;

-   Apply EPA's chemical tools and expertise to understand toxicological
    characteristics of chemical ingredients and to ensure that they are
    the safest within their functional use class; and

-   Approve candidates for recognition and notify both successful and
    unsuccessful applicants of the decisions.

##  5(b) Collection Methodology and Management

Cleaning product manufacturers will be able to obtain an Ingredient
Information Request Form in hard copy from EPA or by downloading it from
the Web site of the third-party profiler. Non-cleaning product
manufacturers will be able to obtain the Ingredient Information Request
Form in hard copy from EPA or by downloading it from the Formulator
Program Web site. The completed forms can be faxed, mailed, or, if they
do not contain CBI or Trade Secret information, they can be scanned and
emailed to EPA.

In collecting and analyzing the information associated with this ICR,
EPA will use a telephone system, personal computers, and applicable
database software. EPA will ensure the accuracy and completeness of
collected information by reserving the right to request proof of the
list of ingredients (e.g., bills of lading, invoices) or other relevant
documentation at any time to confirm that candidates have the achieved
the criteria for recognition.

##  5(c) Small Entity Flexibility

EPA expects that some of the participants in the Formulator Program will
be small entities. EPA has designed its application form to minimize
respondent burden while obtaining sufficient and accurate information.
In addition, given the voluntary nature of the collection, EPA expects
that respondents will participate only if the benefits of participation
outweigh the information collection burden.

##  5(d) Collection Schedule

Organizations may submit an application for recognition at any time.

# 6. ESTIMATING THE BURDEN AND COST OF THE COLLECTION

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

The data collection mechanism for the Formulators Program is the
Ingredient Information Request Form for cleaning products and the
Ingredient Worksheet for non-cleaning products. In an effort to minimize
burden and cost, both forms were designed to contain answers that do not
require significant research.

##  6(a) Estimating Respondent Burden

The average respondent burden is estimated to be 15 hours for cleaning
product formulators and 12 hours for non-cleaning product formulators
(see Exhibit 6.1). The burden associated with cleaning products is
higher because cleaning product manufacturers typically submit a greater
number of products for recognition per application than non-cleaning
product manufacturers. EPA used professional judgment to arrive at a
burden estimate and then consulted representatives from the participant
categories to make sure the burden estimates were reasonable (see
section 3(c)).

EPA expects that for a typical cleaning product formulator, program and
application review will take about 2 hours (1 managerial, 1 technical).
Filling out and submitting third-party information request forms will
take about 5 hours (4 technical, 1 clerical), and then establishing an
agreement with the third party will take about 3 hours (1 managerial, 1
technical, 1 clerical). Submitting a summary report to DfE will take
about 2 hours (1 managerial, 1 technical). Finally, establishing a
Partnership Agreement DfE will take 3 hours (1 managerial, 2 technical).

For a typical non-cleaning product formulator, program and application
review will take 2 hours (1 managerial, 1 technical). Filling out and
submitting the DfE ingredient worksheet will take about 5 hours (4
technical, 1 clerical). Finally, establishing a Partnership Agreement
with DfE will take 5 hours (1 managerial, 4 technical).

In addition to the burden associated with first-time submission of
application forms, each formulator has the opportunity to renew its
Partnership Agreement at the end of the three-year partnership period.
This means that once every three years, the formulator re-submits its
application for each partnership product to confirm that no changes have
been made to ingredients. EPA then evaluates the application. EPA
estimates that the partnership renewal process will take 5 hours (4
technical, 1 clerical) for cleaning and non-cleaning product
formulators. For purposes of this ICR, EPA expects that all cleaning and
non-cleaning product formulators will choose to renew their
partnerships. Furthermore, EPA anticipates that one in ten cleaning and
non-cleaning product formulators will need to make improvements to their
formulations so that they contain the safest ingredients within each
functional use class; in these cases, a new partnership approval
process, as described above, will be triggered. The associated burden
for completing the new partnership approval process is assumed to be the
same as first-time submission. For purposes of estimating annual cost
and burden in Exhibit 6.1, it is assumed that one-third of all
formulators over the period of this ICR will renew their partnership
agreements each year, and that one in ten formulators will need to go
through a new partnership approval process.

## 6(b) Estimating Respondent Costs

EPA estimates an average loaded hourly labor rate (base hourly rate plus
fringe and overhead) of \$68 for managerial staff, \$55 for technical
staff, and \$27 for clerical staff. These three labor rate estimates are
based upon manufacturing industry wage data from the Bureau of Labor
Statistics (BLS) *Employer Costs for Employee Compensation,
Supplementary Tables* from September 2007. The hourly labor rates
include a 17% overhead; this overhead rate is used for consistency with
OPPT economic analyses for two major rulemakings: *Wage Rates for
Economic Analyses of the Toxics Release Inventory Program* and the
*Revised Economic Analysis for the Amended Inventory Update Rule: Final
Report*. In addition, the hourly labor rates have been rounded for the
purposes of this ICR. The type of staff needed to complete the
Formulator's application forms and their associated hourly labor rates
were verified by contacting representatives from the participant
categories.

The derivation of labor rates for managerial, technical, and clerical
staff are shown in exhibit 6.1 below.

Exhibit 6.1. Derivation of Loaded Wage Rates

+---------+------+-------+-------+-------+---------+--------+--------+
| **Labor | **Wa | **F   | **Fr  | **Ove | **F     | **     | **     |
| cat     | ge** | ringe | inges | rhead | ringe + | Loaded | Loaded |
| egory** |      | Bene  | as %  | %     | o       | W      | Wages  |
|         |      | fit** | w     | w     | verhead | ages** | (roun  |
|         |      |       | age** | age** | f       |        | ded)** |
|         |      |       |       |       | actor** |        |        |
+---------+------+-------+-------+-------+---------+--------+--------+
|         | **(  | **    | **(c) | **    | **(     | **(    |        |
|         | a)** | (b)** | =(b)/ | (d)** | e)=(c)+ | f)=(a) |        |
|         |      |       | (a)** |       | (d)+1** | x      |        |
|         |      |       |       |       |         | (e)**  |        |
+---------+------+-------+-------+-------+---------+--------+--------+
| **Ma    | \$4  | \$    | 4     | 17%   | 1.65    | \      | \      |
| nageria | 1.40 | 19.74 | 7.68% |       |         | $68.18 | $68.00 |
| l**[^2] |      |       |       |       |         |        |        |
+---------+------+-------+-------+-------+---------+--------+--------+
| **P     | \$3  | \$    | 4     | 17%   | 1.67    | \      | \      |
| rofessi | 3.25 | 16.54 | 9.74% |       |         | $55.44 | $55.00 |
| onal/** |      |       |       |       |         |        |        |
|         |      |       |       |       |         |        |        |
| **      |      |       |       |       |         |        |        |
| Technic |      |       |       |       |         |        |        |
| al^2^** |      |       |       |       |         |        |        |
+---------+------+-------+-------+-------+---------+--------+--------+
| *       | \$1  | \     | 5     | 17%   | 1.67    | \      | \      |
| *Cleric | 6.40 | $8.28 | 0.49% |       |         | $27.47 | $27.00 |
| al^2^** |      |       |       |       |         |        |        |
+---------+------+-------+-------+-------+---------+--------+--------+

In exhibit 6.2 we show the breakdown of burden costs, assuming 15 hours
for cleaning product manufacturers and 12 hours for non-cleaning product
manufacturers. The third-party verification process for cleaning
products also adds a operating and management (O&M) cost of about
\$13,200 per company per application. This cost estimate is from NSF
International, which has experience conducting third-party analysis of
ingredient characteristics. For this ICR, it is assumed that the typical
cleaning product manufacturer will submit four products in an
application. Each product is assumed to contain 2 ingredients at \$500
each, 2 proprietary ingredients at \$1,000, and 1 CleanGredients™
ingredient at no charge, for a total of \$3,000 per product. In
addition, a \$3,300 administrative fee is assumed. The total will be
\$13,200 per company per application. It is assumed that the typical
non-cleaning product manufacturer will submit one product per
application. No additional capital or O&M costs are incurred by
respondents under this ICR.

**Exhibit 6.2**. Estimated Burden and Costs to Respondents

<table>
<colgroup>
<col style="width: 16%" />
<col style="width: 8%" />
<col style="width: 8%" />
<col style="width: 8%" />
<col style="width: 8%" />
<col style="width: 8%" />
<col style="width: 8%" />
<col style="width: 8%" />
<col style="width: 8%" />
<col style="width: 8%" />
<col style="width: 8%" />
</colgroup>
<tbody>
<tr class="odd">
<td rowspan="2"><strong>Collection activity</strong></td>
<td colspan="7"><strong>Hours and Costs Per Respondent</strong></td>
<td colspan="3"><strong>Total Hours and Costs</strong></td>
</tr>
<tr class="even">
<td><p><strong>Manager</strong></p>
<p><strong>$68/Hr</strong></p></td>
<td><p><strong>Technical</strong></p>
<p><strong>$55/Hr</strong></p></td>
<td><p><strong>Clerical</strong></p>
<p><strong>$27/Hr</strong></p></td>
<td><strong>Response Hours/Yr</strong></td>
<td><strong>Labor Cost/Year</strong></td>
<td><p><strong>Capital</strong></p>
<p><strong>Cost</strong></p></td>
<td><strong>O &amp; M Cost*</strong></td>
<td><strong>Number of Respon.**</strong></td>
<td><strong>Total Hours/Yr</strong></td>
<td><strong>Total Cost/Yr</strong></td>
</tr>
<tr class="odd">
<td colspan="11"><strong>Cleaning Products</strong></td>
</tr>
<tr class="even">
<td><ul>
<li><p>Review application and program information</p></li>
</ul></td>
<td>1</td>
<td>1</td>
<td>0</td>
<td>2</td>
<td>$123</td>
<td>0</td>
<td><strong>--</strong></td>
<td>30</td>
<td>60</td>
<td>$3,690</td>
</tr>
<tr class="odd">
<td><ul>
<li><p>Fill out and submit 3<sup>rd</sup> party information request
form</p></li>
</ul></td>
<td>0</td>
<td>4</td>
<td>1</td>
<td>5</td>
<td>$247</td>
<td>0</td>
<td><strong>--</strong></td>
<td>30</td>
<td>150</td>
<td>$7,410</td>
</tr>
<tr class="even">
<td><ul>
<li><p>Establish agreement with 3<sup>rd</sup> party</p></li>
</ul></td>
<td>1</td>
<td>1</td>
<td>1</td>
<td>3</td>
<td>$150</td>
<td>0</td>
<td>$13,200</td>
<td>30</td>
<td>90</td>
<td>$400,500</td>
</tr>
<tr class="odd">
<td><ul>
<li><p>Submit summary report to DfE</p></li>
</ul></td>
<td>1</td>
<td>1</td>
<td>0</td>
<td>2</td>
<td>$123</td>
<td>0</td>
<td><strong>--</strong></td>
<td>30</td>
<td>60</td>
<td>$3,690</td>
</tr>
<tr class="even">
<td><ul>
<li><p>Negotiate / establish Partnership Agreement with DfE</p></li>
</ul></td>
<td>1</td>
<td>2</td>
<td>0</td>
<td>3</td>
<td>$178</td>
<td>0</td>
<td><strong>--</strong></td>
<td>30</td>
<td>90</td>
<td>$5,340</td>
</tr>
<tr class="odd">
<td><ul>
<li><p>Renew partnership, with no changes needed</p></li>
</ul></td>
<td>0</td>
<td>4</td>
<td>1</td>
<td>5</td>
<td>$247</td>
<td>0</td>
<td><strong>--</strong></td>
<td>29</td>
<td>145</td>
<td>$7,163</td>
</tr>
<tr class="even">
<td><em>Subtotal</em></td>
<td><em>Varies</em></td>
<td><em>Varies</em></td>
<td><em>Varies</em></td>
<td><em>20</em></td>
<td><em>$1,068</em></td>
<td><em>0</em></td>
<td><em>$13,200</em></td>
<td><em>29</em></td>
<td><em>595</em></td>
<td><em>$427,793</em></td>
</tr>
<tr class="odd">
<td colspan="11"><strong>Non-Cleaning Products</strong></td>
</tr>
<tr class="even">
<td><ul>
<li><p>Review application and program information</p></li>
</ul></td>
<td>1</td>
<td>1</td>
<td>0</td>
<td>2</td>
<td>$123</td>
<td>0</td>
<td>0</td>
<td>4</td>
<td>8</td>
<td>$492</td>
</tr>
<tr class="odd">
<td><ul>
<li><p>Fill out and submit DfE ingredient worksheet</p></li>
</ul></td>
<td>0</td>
<td>4</td>
<td>1</td>
<td>5</td>
<td>$247</td>
<td>0</td>
<td>0</td>
<td>4</td>
<td>20</td>
<td>$988</td>
</tr>
<tr class="even">
<td><ul>
<li><p>Negotiate / establish Partnership Agreement with DfE</p></li>
</ul></td>
<td>1</td>
<td>4</td>
<td>0</td>
<td>5</td>
<td>$288</td>
<td>0</td>
<td>0</td>
<td>4</td>
<td>20</td>
<td>$1,152</td>
</tr>
<tr class="odd">
<td><ul>
<li><p>Renew partnership, with no changes needed</p></li>
</ul></td>
<td>0</td>
<td>4</td>
<td>1</td>
<td>5</td>
<td>$247</td>
<td>0</td>
<td>0</td>
<td>3</td>
<td>15</td>
<td>$741</td>
</tr>
<tr class="even">
<td><em>Subtotal</em></td>
<td><em>Varies</em></td>
<td><em>Varies</em></td>
<td><em>Varies</em></td>
<td><em>17</em></td>
<td><em>$905</em></td>
<td><em>0</em></td>
<td><em>0</em></td>
<td><em>3</em></td>
<td><em>63</em></td>
<td><em>$3,373</em></td>
</tr>
<tr class="odd">
<td><strong>TOTAL</strong></td>
<td><strong>Varies</strong></td>
<td><strong>Varies</strong></td>
<td><strong>Varies</strong></td>
<td><strong>37</strong></td>
<td><strong>$1,973</strong></td>
<td><strong>0</strong></td>
<td><strong>$13,200</strong></td>
<td><strong>32</strong></td>
<td><strong>658</strong></td>
<td><strong>$431,166</strong></td>
</tr>
</tbody>
</table>

\* The cost for third-party review and verification assumes that the
typical application submitted by a cleaning product manufacturer will
contain four products. Each product will contain 2 ingredients at \$500
each and 2 proprietary ingredients at \$1,000, for a total of \$3,000
per product. Also assumes a \$3,300 administrative fee. The total will
be \$13,200 per company per application.

\*\*This column reports the number of respondents after accounting for
the partnership renewal process. Assumes that one in ten formulators
will need to make changes to their formulations and go through a new
partnership process which includes same collection steps -- i.e., 1 of
29 cleaning product formulators (for a total of 30) and 1 of 3
non-cleaning product formulators (for a total of 4).

## 6(c) Estimating Agency Burden and Costs 

Exhibit 6.3 presents the estimated Agency burden hours and costs
associated with the information collection activities under this ICR.
EPA based its burden estimates on its experience managing other
voluntary programs.

Agency labor costs are calculated based on hourly basic rates for
federal employees in the Washington-Baltimore area published by the
Office of Personnel Management effective January 2008[^3]. The average
hourly labor rate for managerial staff is estimated as the rate for a
GS-13 Step 5 employee, for technical staff as a GS-10 Step 10 employee,
and for clerical staff as GS-5 Step 1. These GS-level assumptions are
consistent with those used in past EPA OPPT ICRs. The hourly rates were
multiplied by an assumed loading factor of 1.6 to reflect Federal fringe
benefits and overhead. This loading factor is from an EPA guide,
*Instructions for Preparing Information Collection Requests (ICRs)*
(OPPE, 1992, page 30, footnote 9).

The resulting average hourly labor rates, rounded to the nearest dollar
amount, are \$72 for managerial staff, \$53 for technical staff, and
\$24 for clerical staff. The Agency expects most activities related to
this ICR to be performed by managerial staff (25 percent) and technical
staff (75 percent).

**Exhibit 6.3**. Annual Agency Burden/Cost

<table style="width:100%;">
<colgroup>
<col style="width: 16%" />
<col style="width: 9%" />
<col style="width: 9%" />
<col style="width: 9%" />
<col style="width: 9%" />
<col style="width: 9%" />
<col style="width: 8%" />
<col style="width: 9%" />
<col style="width: 8%" />
<col style="width: 8%" />
<col style="width: 0%" />
</colgroup>
<tbody>
<tr class="odd">
<td rowspan="2"><strong>Collection activity</strong></td>
<td colspan="6"><strong>Hours and Costs Per Respondent</strong></td>
<td colspan="3"><strong>Total Hours and Costs</strong></td>
<td></td>
</tr>
<tr class="even">
<td><p><strong>Manager</strong></p>
<p><strong>$72/Hr</strong></p></td>
<td><p><strong>Technical</strong></p>
<p><strong>$53/Hr</strong></p></td>
<td><strong>Agency Hours/Yr</strong></td>
<td><strong>Labor Cost/Year</strong></td>
<td><p><strong>Capital/</strong></p>
<p><strong>Startup Cost</strong></p></td>
<td><strong>O &amp; M Cost</strong></td>
<td><strong>Number of Respon.*</strong></td>
<td><strong>Total Hours/Yr</strong></td>
<td colspan="2"><strong>Total Cost/Yr</strong></td>
</tr>
<tr class="odd">
<td colspan="11">Cleaning Products</td>
</tr>
<tr class="even">
<td><ul>
<li><p>Review program information</p></li>
</ul></td>
<td>0</td>
<td>1</td>
<td>1</td>
<td>$53</td>
<td>0</td>
<td>0</td>
<td>30</td>
<td>30</td>
<td colspan="2">$1,590</td>
</tr>
<tr class="odd">
<td><ul>
<li><p>Review 3<sup>rd</sup>-party summary</p></li>
</ul></td>
<td>0</td>
<td>7</td>
<td>7</td>
<td>$371</td>
<td>0</td>
<td>0</td>
<td>30</td>
<td>210</td>
<td colspan="2">$11,130</td>
</tr>
<tr class="even">
<td><ul>
<li><p>Negotiate / establish Partnership Agreement with
formulator</p></li>
</ul></td>
<td>2</td>
<td>4</td>
<td>6</td>
<td>$356</td>
<td>0</td>
<td>0</td>
<td>30</td>
<td>180</td>
<td colspan="2">$10,680</td>
</tr>
<tr class="odd">
<td><ul>
<li><p>Review partnership renewal, with no changes needed</p></li>
</ul></td>
<td>1</td>
<td>1</td>
<td>2</td>
<td>$125</td>
<td>0</td>
<td>0</td>
<td>29</td>
<td>58</td>
<td colspan="2">$3,625</td>
</tr>
<tr class="even">
<td><em>Subtotal</em></td>
<td><em>Varies</em></td>
<td><em>Varies</em></td>
<td><em>16</em></td>
<td><em>$905</em></td>
<td><em>0</em></td>
<td><em>0</em></td>
<td><em>29</em></td>
<td><em>478</em></td>
<td colspan="2"><em>$27,025</em></td>
</tr>
<tr class="odd">
<td colspan="11">Non-Cleaning Products</td>
</tr>
<tr class="even">
<td><ul>
<li><p>Review program information</p></li>
</ul></td>
<td>0</td>
<td>1</td>
<td>1</td>
<td>$53</td>
<td>0</td>
<td>0</td>
<td>4</td>
<td>4</td>
<td colspan="2">$212</td>
</tr>
<tr class="odd">
<td><ul>
<li><p>Review product submissions and complete chemical
profiles</p></li>
</ul></td>
<td>0</td>
<td>29</td>
<td>29</td>
<td>$1,537</td>
<td>0</td>
<td>0</td>
<td>4</td>
<td>116</td>
<td colspan="2">$6,148</td>
</tr>
<tr class="even">
<td><ul>
<li><p>Negotiate / establish Partnership Agreement with
formulator</p></li>
</ul></td>
<td>2</td>
<td>6</td>
<td>8</td>
<td>$462</td>
<td>0</td>
<td>0</td>
<td>4</td>
<td>32</td>
<td colspan="2">$1,848</td>
</tr>
<tr class="odd">
<td><ul>
<li><p>Review partnership renewal, with no changes needed</p></li>
</ul></td>
<td>1</td>
<td>1</td>
<td>2</td>
<td>$125</td>
<td>0</td>
<td>0</td>
<td>3</td>
<td>6</td>
<td colspan="2">$375</td>
</tr>
<tr class="even">
<td><em>Subtotal</em></td>
<td><em>Varies</em></td>
<td><em>Varies</em></td>
<td><em>40</em></td>
<td><em>$2,177</em></td>
<td><em>0</em></td>
<td><em>0</em></td>
<td><em>3</em></td>
<td><em>158</em></td>
<td colspan="2"><em>$8,583</em></td>
</tr>
<tr class="odd">
<td><strong>TOTAL</strong></td>
<td><strong>Varies</strong></td>
<td><strong>Varies</strong></td>
<td><strong>56</strong></td>
<td><strong>$3,082</strong></td>
<td><strong>0</strong></td>
<td><strong>0</strong></td>
<td><strong>32</strong></td>
<td><strong>636</strong></td>
<td colspan="2"><strong>$35,608</strong></td>
</tr>
</tbody>
</table>

\*This column reports the number of respondents after accounting for the
partnership renewal process. Assumes that one in ten formulators will
need to make changes to their formulations and go through a new
partnership process which includes same collection steps -- i.e., 1 of
29 cleaning product formulators (for a total of 30) and 1 of 3
non-cleaning product formulators (for a total of 4).

## 6(d) Estimating the Respondent Universe and Total Burden and Costs

## 

EPA estimates that 96 formulators will submit applications over the
three-year life of the clearance. EPA expects the participation will
ramp up over the three year period, but for the purposes of estimating
annual cost and burden in Exhibit 6.2, it is assumed that 32 formulators
will submit applications per year. This estimate is based on historical
data and the assumption that participation will increase over the next
three years in response to greater consumer demand for green products.
Furthermore, EPA estimates that of the applications, about 90 percent
(or 29 per year) will be cleaning products, with the remainder being
non-cleaning products. The annual burden hours and cost associated with
this information collection are 658 hours and \$431,166, respectively.

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

a\. Respondent Tally

Exhibit 6.4 below summarizes the total annual estimated respondent
burden and cost. These estimates represent the average burden in any
given year over the three years covered by this ICR.

**Exhibit 6.4. Total Annual Estimated Respondent Burden and Cost
Summary**

  ----------------------- ----------------------- -----------------------
  **Total \# of           **Average Burden        **Annual Cost**
  Respondents**           Hours**                 

  32                      658                     \$431,166
  ----------------------- ----------------------- -----------------------

b\. Agency Tally

Exhibit 6.5 below summarizes the total annual estimated agency burden
and cost. These estimates represent the average burden in any given year
over the three years covered by this ICR.

**Exhibit 6.5. Total Annual Estimated Agency Burden and Cost Summary**

  ----------------------------------- -----------------------------------
  **Burden Hours**                    **Annual Cost**

  636                                 \$35,608
  ----------------------------------- -----------------------------------

##  6(f) Reasons for Change in Burden

Since this is a new ICR, change in respondent burden is not applicable.

##  6(g) Burden Statement

The annual public burden for this collection of information is estimated
at 15 hours per response for formulators of cleaning products and 12
hours per response for formulators of non-cleaning products, including
time for reviewing instructions, gathering information, and completing
and reviewing the application. 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. The OMB control numbers for EPA's regulations
in title 40 of the CFR, after appearing in the [Federal
Register]{.underline}, are listed in 40 CFR part 9 and included on the
related collection instrument or form, if applicable.

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-2008-0219. The docket is available for public viewing at the
Pollution Prevention and Toxics Docket in the EPA Docket Center
(EPA/DC). The EPA/DC Public Reading Room is located in the EPA West
Building, Room 3334, 1301 Constitution Ave., NW., Washington, DC. The
EPA/DC 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
EPA/DC Public Reading Room is (202) 566-1744, and the telephone number
for the Pollution Prevention and Toxics Docket is (202) 566-0280. An
electronic version of the public docket is available through the Federal
Docket Management System (FDMS) at
[[www.regulations.gov]{.underline}](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. Please include the
EPA Docket ID No. EPA-HQ-OPPT-2008-0219 and OMB control number 2070-NEW
in any correspondence.

**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-OPPT-2008-0219. These attachments are available for online
viewing at www.regulations.gov or otherwise accessed as described in
Section 6(g) of the Supporting Statement.

  --------------- ---------------------------------------------------------------------------------------------------------------------------------------------------------------
  **Attachment    **42 USC 13103 - Pollution Prevention Act Section 6604**. Also available at online at the US House of Representatives' Office of the Law Revision Counsel's [US
  A:**            Code
                  website](http://uscode.house.gov/uscode-cgi/fastweb.exe?getdoc+uscview+t41t42+7517+0++()  AND ((42) ADJ USC)%3ACITE AND (USC w%2F10 (13103))%3ACITE         )

  **Attachment    **Design for the Environment Formulator Program Elements: A Discriminating and Protective Approach to Cleaning Product Review and Recognition**
  B:**            

  **Attachment    **Formulation Information Request for Cleaning Products**
  C:**            

  **Attachment    **DfE Formulator Initiative: Ingredient Worksheet**
  D**:            
  --------------- ---------------------------------------------------------------------------------------------------------------------------------------------------------------

# 

# ATTACHMENT A

**Pollution Prevention Act Section 6604(b)(5)**

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

\[Electronic copy available as part of the electronic copy of the ICR's
Supporting Statement.\]

**SEC. 6604. EPA ACTIVITIES.**

\(a\) AUTHORITIES.---The Administrator shall establish in the Agency an
office to carry out the functions of the Administrator

under this subtitle. The office shall be independent of the Agency's
single-medium program offices but shall have the authority to review and
advise such offices on their activities to promote a multimedia approach
to source reduction. The office shall be under the direction of such
officer of the Agency as the Administrator shall designate.

\(b\) FUNCTIONS.---The Administrator shall develop and implement a
strategy to promote source reduction. As part of the strategy, the
Administrator shall---

> \(1\) establish standard methods of measurement of source reduction;
>
> \(2\) ensure that the Agency considers the effect of its existing and
> proposed programs on source reduction efforts and shall review
> regulations of the Agency prior and subsequent to their proposal to
> determine their effect on source reduction;
>
> \(3\) coordinate source reduction activities in each Agency Office and
> coordinate with appropriate offices to promote source reduction
> practices in other Federal agencies, and generic research and
> development on techniques and processes which have broad
> applicability;
>
> \(4\) develop improved methods of coordinating, streamlining and
> assuring public access to data collected under Federal environmental
> statutes;
>
> \(5\) facilitate the adoption of source reduction techniques by
> businesses. This strategy shall include the use of the Source
> Reduction Clearinghouse and State matching grants provided in this
> subtitle to foster the exchange of information regarding source
> reduction techniques, the dissemination of such information to
> businesses, and the provision of technical assistance to businesses.
> The strategy shall also consider the capabilities of various
> businesses to make use of source reduction techniques;
>
> \(6\) identify, where appropriate, measurable goals which reflect the
> policy of this subtitle, the tasks necessary to achieve the goals,
> dates at which the principal tasks are to be accomplished, required
> resources, organizational responsibilities, and the means by which
> progress in meeting the goals will be measured;
>
> \(8\) 1 establish an advisory panel of technical experts comprised of
> representatives from industry, the States, and public interest groups,
> to advise the Administrator on ways to improve collection and
> dissemination of data;
>
> \(9\) establish a training program on source reduction opportunities,
> including workshops and guidance documents, for State and Federal
> permit issuance, enforcement, and inspection officials working within
> all agency program
>
> \(10\) identify and make recommendations to Congress to eliminate
> barriers to source reduction including the use of incentives and
> disincentives;
>
> \(11\) identify opportunities to use Federal procurement to encourage
> source reduction;
>
> \(12\) develop, test and disseminate model source reduction auditing
> procedures designed to highlight source reduction opportunities; and
>
> \(13\) establish an annual award program to recognize a company or
> companies which operate outstanding or innovative source reduction
> programs.

# 

# 

# 

# 

# 

# 

# 

# 

# ATTACHMENT B

**Design for the Environment Formulator Program Elements: A
Discriminating and**

**Protective Approach to Cleaning Product Review and Recognition**

![](media/image1.png){width="0.9166666666666666in"
height="0.9166666666666666in"}**Design for the Environment Formulator
Program Elements:**

***A Discriminating and Protective Approach to Cleaning Product***

***Review and Recognition***

**January 2008**

Situated in the U.S. EPA's Office of Pollution Prevention and Toxics
(OPPT), the Design for the Environment (DfE) Formulator Program is a
product formulator's gateway to OPPT's unique chemical expertise,
information resources, and guidance on greener chemistry. The program
gathers hazard information on chemical ingredients and works with OPPT's
science experts to assess this information and compare the relative
safety of chemicals.

Since 1997, DfE has offered recognition to those companies who design
for the environment and human health by using only safer chemicals. To
date around 300 chemical products have been recognized by the program. A
complete list of partner companies and products can be found at:
<http://www.epa.gov/dfe/pubs/projects/formulat/formpart.htm>.

***What Makes DfE Formulator Review Unique?*** The DfE Program is
distinct from all other product recognition or ecolabeling programs
because of two defining characteristics: its assessment methodology and
its technical review team. The DfE technical review team has many years
of experience and is highly skilled at assessing chemical hazards,
applying predictive tools, and identifying safer substitutes for
chemicals of concern.

The review team applies the DfE assessment methodology by carefully
reviewing each product component[^4], starting with the chemical
component's structure, to determine its key health and environmental
characteristics. (The review includes all chemicals, including those in
proprietary raw material blends, which manufacturers share with DfE in
confidentiality). The review team then compares an ingredient's
characteristics to other chemicals in the same use class, considers
possible negative synergies between ingredients, and places the
ingredient on a continuum of improvement relative to other similar
chemicals.

![](media/image2.wmf){width="3.7597222222222224in"
height="2.3555555555555556in"}

Through its review team and methodology, DfE provides information to
formulators that helps them select from among the safest chemicals in an
ingredient class. The approach is adaptable to changing circumstances
and new information, emphasizing continuous improvement as the
opportunities for safer formulations grow with chemical innovation.

***How Does DfE's Component-Based Review Compare with Other
Product-Based Approaches?*** The following examples showcase some of the
key benefits of DfE's component-based review and the extra measure of
protection it often provides:

[DfE uncovers chemicals of concern that can be masked by raw material
blends or by dilution in water]{.underline}. By focusing at the
component level and on key inherent characteristics, DfE is able to
carefully scrutinize formulations and make meaningful calls on potential
concerns. For example, a surfactant that is acutely toxic to aquatic
organisms and environmentally persistent can appear to pose a low
concern when blended with other less toxic and less persistent
surfactants. Similarly, water, typically the largest percentage
ingredient even in concentrates, can mask the effects of a hazardous
chemical.

[DfE spots negative synergies between product components]{.underline}.
These potentially dangerous chemical combinations pose concerns for both
acute and longer-term effects. For example, oxidizing agents, like
hydrogen peroxide, can release the sensitizing potential of certain
citrus fragrances; another example, mixing nitrogen-containing compounds
with amines will create nitrosamines, potent carcinogens.

[DfE uses its expert knowledge and predictive tools to supplement lists
of chemicals of concern]{.underline}. Few chemicals in commerce have
been adequately tested, especially for chronic effects, like cancer and
developmental toxicity and thus lists of chemicals with these effects
are partial at best. DfE uses its knowledge of the structural
similarities between chemicals and its predictive models to flag product
components with similar potential effects.

[DfE screens all fragrances and dyes for chemicals that may pose serious
health or environmental effects]{.underline}. Some of the chemicals of
most potential concern in cleaning products are those in fragrances and
dyes. Chemical ingredients in these classes can include sensitizers,
carcinogens, and environmentally toxic and persistent compounds. Small
quantities don't necessarily mean small hazards: A person, once
sensitized to a chemical, can have an allergic response even if exposed
at levels below those that initially induced sensitization.

[DfE recommends safer substitutes for chemicals of concern]{.underline}.
Sustainability requires innovation and continuous improvement. The DfE
program works directly with EPA's Green Chemistry specialists to
identify and recommend safer chemicals to its formulator partners,
continuously raising the bar and redefining the meaning of
environmentally preferable products.

The following matrix highlights many of the elements reviewed by the DfE
Formulator Program team. The matrix should help purchasing entities and
others understand what DfE considers in its review, what its recognition
means, and how they should view products that carry the DfE logo. DfE
compares and balances product characteristics in determining the
appropriateness and type of DfE recognition.

+---------------+-------------------------------+----------------------+
| **Review      | **Assessment Approach**       | **Comments**         |
| elements**    |                               |                      |
+===============+===============================+======================+
| Aquatic       | Acute aquatic toxicity for a  |                      |
| Toxicity -    | *component* is evaluated in   |                      |
| Acute         | conjunction with the          |                      |
|               | chemical's other attributes;  |                      |
|               | focus is on the key           |                      |
|               | distinguishing                |                      |
|               | characteristics that make one |                      |
|               | chemical safer than another.  |                      |
|               | For example, all              |                      |
|               | high-functioning surfactants  |                      |
|               | have high aquatic toxicity    |                      |
|               | (low LC~50~ values). Safer    |                      |
|               | surfactants are those that    |                      |
|               | are readily biodegradable and |                      |
|               | do not degrade to chemicals   |                      |
|               | that are persistent or toxic. |                      |
+---------------+-------------------------------+----------------------+
| Aquatic       | DfE considers data if         |                      |
| Toxicity -    | available or estimation       |                      |
| Chronic       | models, and in particular     |                      |
|               | limits those *components*     |                      |
|               | whose aquatic toxicity        |                      |
|               | increases through long-term   |                      |
|               | (chronic) exposure.           |                      |
+---------------+-------------------------------+----------------------+
| Acute Dermal, | When data are available, DfE  |                      |
| Oral and      | follows the UN's Globally     |                      |
| Inhalation    | Harmonized System for rating  |                      |
| Toxicities    | acute dermal, oral and        |                      |
| (LD~50~)      | inhalation toxicities. No     |                      |
|               | *components* classified under |                      |
|               | "Danger" are found in         |                      |
|               | DfE-recognized products. At a |                      |
|               | minimum, each *component* has |                      |
|               | an*:*                         |                      |
|               |                               |                      |
|               | 1)  Acute dermal toxicity     |                      |
|               |     LD~50~ \> 1000 mg/kg.     |                      |
|               |                               |                      |
|               | 2)  Acute oral toxicity       |                      |
|               |     LD~50~ \> 300mg/kg, and   |                      |
|               |                               |                      |
|               | 3)  Acute inhalation toxicity |                      |
|               |     LC~50~ \>10 mg/L.         |                      |
|               |                               |                      |
|               | For components without data,  |                      |
|               | DfE relies on the judgment of |                      |
|               | its technical experts to      |                      |
|               | identify chemicals that, by   |                      |
|               | analogy, pose a potential     |                      |
|               | acute dermal toxicity hazard. |                      |
+---------------+-------------------------------+----------------------+
| Alkylphenol   | DfE-recognized products do    | DfE has identified   |
| ethoxylates   | not contain APEs. APEs, like  | surfactants that are |
| (APEs)        | all surfactants, are compared | safer than APEs, and |
|               | based on their key            | have comparable      |
|               | distinguishing                | performance and      |
|               | characteristics:              | price. In the        |
|               |                               | context of its       |
|               | 1)  Rate of biodegradation,   | product reviews, DfE |
|               |                               | provides this        |
|               | 2)  Aquatic toxicity, and     | information on safer |
|               |                               | substitutes to its   |
|               | 3)  Degradation products.     | formulator partners. |
|               |                               |                      |
|               | APEs do not have acceptable   | See also the section |
|               | profiles because they degrade | titled               |
|               | to products that are          | 'Surfactants'.       |
|               | increasingly toxic and are    |                      |
|               | potential endocrine mimics.   |                      |
+---------------+-------------------------------+----------------------+
| Bi            | DfE uses data, models, and    |                      |
| oaccumulation | EPA's expert judgment to      |                      |
|               | assess a *component's*        |                      |
|               | potential to bioaccumulate.   |                      |
|               | Bioaccumulation potential is  |                      |
|               | reviewed in conjunction with  |                      |
|               | a chemical's other            |                      |
|               | attributes. Depending upon    |                      |
|               | certainty of effect,          |                      |
|               | component class, and          |                      |
|               | percentage in the             |                      |
|               | formulation, DfE limits       |                      |
|               | components that may           |                      |
|               | bioaccumulate.                |                      |
+---------------+-------------------------------+----------------------+
| B             | DfE evaluates biodegradation  |                      |
| iodegradation | for all *components* in       |                      |
|               | conjunction with a chemical's |                      |
|               | other attributes; focus is on |                      |
|               | the key characteristics that  |                      |
|               | make one chemical safer than  |                      |
|               | another. For ingredients,     |                      |
|               | like surfactants, where rate  |                      |
|               | of biodegradation is key to   |                      |
|               | safer chemistry, a            |                      |
|               | DfE-recognizable chemical is  |                      |
|               | readily biodegradable and,    |                      |
|               | very importantly, its         |                      |
|               | degradation products are of   |                      |
|               | low concern.                  |                      |
+---------------+-------------------------------+----------------------+
| Ca            | DfE-recognized products do    | Few chemicals in     |
| rcinogenicity | not contain known, probable   | commerce have been   |
|               | or possible human carcinogens | sufficiently tested  |
|               | as defined by:                | to determine their   |
|               |                               | potential for human  |
|               | 1)  IARC,                     | carcinogenicity. In  |
|               |                               | the absence of       |
|               | 2)  NTP,                      | testing, EPA's       |
|               |                               | ONCOLOGIC model and  |
|               | 3)  U.S. EPA, and             | expert judgment help |
|               |                               | fill data gaps. The  |
|               | 4)  OSHA.                     | referenced lists     |
|               |                               | cover only those     |
|               | In addition, DfE reviews      | chemicals which have |
|               | cancer concerns through:      | been fully evaluated |
|               |                               | by the agencies. It  |
|               | 1)  Published cancer studies, | is likely that other |
|               |                               | carcinogenic,        |
|               | 2)  Potential synergistic     | mutagenic, and       |
|               |     effects between           | reproductively toxic |
|               |     components that may       | (CMR) chemicals have |
|               |     produce carcinogenic      | not yet been         |
|               |     byproducts (e.g.          | identified.          |
|               |     nitrosating agents and    |                      |
|               |     amines form the           |                      |
|               |     carcinogenic              |                      |
|               |     nitrosamines),            |                      |
|               |                               |                      |
|               | 3)  EPA's ONCOLOGIC model,    |                      |
|               |     and                       |                      |
|               |                               |                      |
|               | 4)  EPA's expert judgment.    |                      |
+---------------+-------------------------------+----------------------+
| Other Chronic | Depending on component class, |                      |
| Health        | certainty of effect, and      |                      |
| Effects       | percentage in formulation,    |                      |
|               | DfE limits *components* that  |                      |
| \_\_\_\_\_\_\ | may pose other potential      |                      |
| _\_\_\_\_\_\_ | chronic health or internal    |                      |
|               | organ effects. Potential      |                      |
| Basic         | concerns for chronic health   |                      |
| Internal      | effects are identified        |                      |
| Organ Effects | through published studies,    |                      |
| (Including    | internal EPA databases, and   |                      |
| Endocrine     | comparison to chemical        |                      |
| System &      | analogs.                      |                      |
| Blood)        |                               |                      |
|               |                               |                      |
| \_\_\_\_\_\_\ |                               |                      |
| _\_\_\_\_\_\_ |                               |                      |
|               |                               |                      |
| Central       |                               |                      |
| Nervous       |                               |                      |
| System (CNS)  |                               |                      |
| Effects       |                               |                      |
+---------------+-------------------------------+----------------------+
| C             | DfE considers wipe            |                      |
| ompostability | composition and ability to    |                      |
|               | decompose as key              |                      |
|               | characteristics for           |                      |
|               | disposable cleaning wipes     |                      |
|               | when they are the intended    |                      |
|               | method of application for a   |                      |
|               | cleaning formulation. At a    |                      |
|               | minimum, wipes must be made   |                      |
|               | entirely of compostable       |                      |
|               | material.                     |                      |
+---------------+-------------------------------+----------------------+
| Dibutyl       | DfE-recognized products do    | Dibutyl phthalate, a |
| phthalate     | not contain this and other    | plasticizer, can     |
|               | phthalates of concern, based  | also be found in     |
|               | on key characteristics for    | fragrances.          |
|               | plasticizers.                 |                      |
+---------------+-------------------------------+----------------------+
| Energy        | DfE considers the energy      |                      |
| Efficiency    | efficiency of products by     |                      |
|               | comparing product efficiency  |                      |
|               | to that typical of the class, |                      |
|               | recognizing the important     |                      |
|               | source reduction benefits     |                      |
|               | from this efficiency measure. |                      |
+---------------+-------------------------------+----------------------+
| E             | DfE-recognized products do    | Algal blooms         |
| utrophication | not contain inorganic         | possible at          |
|               | phosphates (known to be       | concentrations of    |
|               | present or intentionally      | less than 200 parts  |
|               | added), because of their      | per billion (about   |
|               | potential for eutrophication. | 0.000002%) in 96     |
|               |                               | hours (certain       |
|               |                               | inorganic phosphates |
|               |                               | have produced        |
|               |                               | exponential growth   |
|               |                               | of green algae at    |
|               |                               | levels as low as 50  |
|               |                               | parts per billion).  |
+---------------+-------------------------------+----------------------+
| Flammability  | DfE takes note of *product*   | Flashpoint is        |
|               | flashpoint as appropriate and | generally not a      |
|               | seeks to ensure low concerns  | concern when dealing |
|               | for combustibility.           | with water-based     |
|               |                               | mixtures. Flammable  |
|               |                               | liquids are          |
|               |                               | regulated by:        |
|               |                               |                      |
|               |                               | -   49               |
|               |                               | CFR173.120 (a) (5) - |
|               |                               |     Flammable Liquid |
|               |                               |     Definition       |
|               |                               |                      |
|               |                               | -   49CFR173.150 (e) |
|               |                               |     Aqueous          |
|               |                               |     Solutions of     |
|               |                               |     Alcohol          |
|               |                               |                      |
|               |                               | -                    |
|               |                               |  40CFR261.21 (a) (1) |
|               |                               |     Characteristic   |
|               |                               |     of Ignitability  |
+---------------+-------------------------------+----------------------+
| Fluo          | Based on EPA\'s concerns for  | The ideal, green     |
| rosurfactants | persistence, bioaccumulation  | chemistry surfactant |
|               | in humans, and potential      | and surface          |
|               | toxicity, DfE-recognized      | treatment chemical,  |
|               | products do not contain any   | including wetting    |
|               | fluorosurfactants that have a | and leveling agents, |
|               | fluorinated chain of eight or | would be a chemical  |
|               | more carbons (C8). All        | that readily         |
|               | fluorosurfactants that do not | degrades to          |
|               | have a C8 or longer chain     | non-toxic            |
|               | will be reviewed on a         | degradants, has low  |
|               | case-by-case basis by DfE.    | toxicity, does not   |
|               |                               | persist, or          |
|               |                               | metabolize to        |
|               |                               | chemicals of concern |
|               |                               | in humans or other   |
|               |                               | species, and         |
|               |                               | performs well when   |
|               |                               | compared to          |
|               |                               | traditional wetting  |
|               |                               | agents. As green     |
|               |                               | chemistry            |
|               |                               | innovations occur in |
|               |                               | this ingredient      |
|               |                               | class (as with all   |
|               |                               | ingredient classes), |
|               |                               | DfE may shift its    |
|               |                               | continuum of         |
|               |                               | improvement and no   |
|               |                               | longer allow         |
|               |                               | previously           |
|               |                               | acceptable           |
|               |                               | surfactants and      |
|               |                               | surface treatment    |
|               |                               | chemicals.           |
+---------------+-------------------------------+----------------------+
| Fragrances    | DfE works directly with       | Following IFRA's     |
|               | fragrance houses to improve   | Code of Practice may |
|               | their formulations.           | not be sufficiently  |
|               | C*omponents* are screened     | protective when a    |
|               | for:                          | fragrance is added   |
|               |                               | to a cleaning        |
|               | 1)  Sensitization,            | product. The         |
|               |                               | sensitization        |
|               | 2)  Carcinogenicity,          | potential of         |
|               |                               | terpenes (considered |
|               | 3)  Mutagenicity,             | both fragrances and  |
|               |                               | solvents) can be     |
|               | 4)  Reproductive toxicity,    | released when        |
|               |                               | combined with        |
|               | 5)  Environmental             | oxidizers, such as   |
|               |     persistence,              | hydrogen peroxide.   |
|               |                               |                      |
|               | 6)  Aquatic toxicity, and     |                      |
|               |                               |                      |
|               | 7)  Other hazard              |                      |
|               |     characteristics.          |                      |
+---------------+-------------------------------+----------------------+
| Heavy metals  | DfE-recognized products do    | Unavoidable, *de     |
|               | not contain heavy metals.     | minimis* levels may  |
|               |                               | be present, e.g.,    |
|               |                               | from inorganic       |
|               |                               | materials mined from |
|               |                               | the earth.           |
+---------------+-------------------------------+----------------------+
| Labeling      | Memorandum of Understanding   | OSHA, DOT, and other |
| Requirements  | requires each partner company | authorities require  |
|               | to provide its customers with | manufacturers to     |
|               | information on environmental  | provide handling and |
|               | and worker safety matters.    | other worker safety  |
|               |                               | information.         |
+---------------+-------------------------------+----------------------+
| Mutagenicity  | Depending on component class  |                      |
|               | and certainty of effect, DfE  |                      |
|               | limits *components* that are  |                      |
|               | potential mutagens. Potential |                      |
|               | concerns for mutagenicity are |                      |
|               | identified through published  |                      |
|               | studies, internal EPA         |                      |
|               | databases, and comparison to  |                      |
|               | chemical analogs. DfE often   |                      |
|               | looks at multiple             |                      |
|               | mutagenicity test results,    |                      |
|               | and exercises expert judgment |                      |
|               | in interpreting and           |                      |
|               | characterizing the potential  |                      |
|               | hazard.                       |                      |
+---------------+-------------------------------+----------------------+
| Oz            | DfE-recognized products do    | The Montreal         |
| one-depleting | not contain ozone-depleting   | Protocol (1987)      |
| compounds     | compounds.                    | initiated the        |
|               |                               | phase-out of HCFCs   |
|               | <http://www.epa.gov/          | and banned almost    |
|               | ozone/science/ods/index.html> | all CFCs, including  |
|               |                               | those used as        |
|               |                               | propellants in       |
|               |                               | cleaning products.   |
+---------------+-------------------------------+----------------------+
| Packaging     | DfE encourages the use of     |                      |
|               | environmentally friendlier    |                      |
|               | packaging, but does not       |                      |
|               | require specific types of     |                      |
|               | packaging.                    |                      |
+---------------+-------------------------------+----------------------+
| Photochemical | DfE seeks to minimize VOCs    |                      |
| Smog,         | and limits components that    |                      |
| Tropospheric  | are also Hazardous Air        |                      |
| Ozone         | Pollutants (HAPs) or are on   |                      |
| Production,   | EPA's Toxics Release          |                      |
| and Indoor    | Inventory (TRI) DfE strives   |                      |
| Air Quality   | to optimize the health and    |                      |
|               | environmental preferability   |                      |
|               | of products. The lowest       |                      |
|               | possible VOC-level may not    |                      |
|               | correspond to the safest      |                      |
|               | formulation.                  |                      |
+---------------+-------------------------------+----------------------+
| Product       | To ensure a baseline measure  |                      |
| Performance   | of performance, DfE asks all  |                      |
| Testing       | partners to demonstrate that  |                      |
|               | their products perform        |                      |
|               | effectively. Potential        |                      |
|               | partners may submit           |                      |
|               | appropriate test results as   |                      |
|               | specified in Appendix I or    |                      |
|               | provide equivalent            |                      |
|               | performance tests agreed upon |                      |
|               | by DfE.                       |                      |
+---------------+-------------------------------+----------------------+
| Quality       | The Partnership Agreement     |                      |
| Assu          | between EPA/DfE and the       |                      |
| rance/Control | partner company affirms that  |                      |
|               | those ingredients disclosed   |                      |
|               | to EPA during the product     |                      |
|               | review process are in fact    |                      |
|               | the only ingredients          |                      |
|               | intentionally added or known  |                      |
|               | to be present. EPA is         |                      |
|               | currently exploring           |                      |
|               | additional methods such as    |                      |
|               | composition analysis for      |                      |
|               | ensuring further quality      |                      |
|               | control.                      |                      |
+---------------+-------------------------------+----------------------+
| Reproductive  | DfE reviews reproductive      | Similarly, lists of  |
| and           | toxicity concerns through:    | reproductive toxins  |
| Developmental |                               | are limited by lack  |
| Toxicity      | 1)  Published studies on      | of scientific        |
|               |     reproductive toxicity,    | studies and          |
|               |     and                       | comprehensive agency |
|               |                               | assessments.         |
|               | 2)  EPA's expert judgment.    |                      |
|               |                               |                      |
|               | In addition, DfE supplements  |                      |
|               | its reviews with the          |                      |
|               | following lists:              |                      |
|               |                               |                      |
|               | 1)  California's Proposition  |                      |
|               |     65 -- Safe Drinking Water |                      |
|               |     and Toxic Enforcement Act |                      |
|               |     of 1986.                  |                      |
+---------------+-------------------------------+----------------------+
| Respiratory   | A *component's* potential for | DfE is able to       |
| Sensitization | respiratory sensitization is  | consider multiple    |
|               | reviewed in conjunction with  | factors in its       |
|               | the chemical's other          | review, and make     |
|               | attributes. Depending upon    | educated judgments   |
|               | certainty of effect,          | because of the       |
|               | component class, and          | diverse expertise of |
|               | percentage in the             | its technical        |
|               | formulation, DfE limits       | workgroup. Since     |
|               | *components* that may cause   | most chemicals lack  |
|               | respiratory sensitization.    | a complete health    |
|               |                               | and environmental    |
|               |                               | profile, expert      |
|               |                               | judgment is critical |
|               |                               | to the accurate      |
|               |                               | characterization of  |
|               |                               | potential hazards.   |
+---------------+-------------------------------+----------------------+
| Skin and Eye  | To minimize potential for     | Most cleaning        |
| Irritation    | dermal and eye irritation or  | products have        |
|               | injury, product pH should be  | ingredients, like    |
|               | ≥ 2 and ≤ 11.5. Depending on  | surfactants, that    |
|               | percentage in the             | are expected skin    |
|               | formulation, DfE limits       | and eye irritants,   |
|               | *components* that are         | especially at        |
|               | suspected or known severe     | concentrated levels. |
|               | skin and eye irritants.       | OSHA requires        |
|               |                               | product-level        |
|               |                               | irritation           |
|               |                               | information on all   |
|               |                               | MSDSs, if any        |
|               |                               | positive results are |
|               |                               | available.           |
+---------------+-------------------------------+----------------------+
| Skin          | Depending on component class, | Sensitization        |
| Sensitization | certainty of effect, and      | potential often      |
|               | percentage in the             | depends on component |
|               | formulation, DfE limits       | class and chemical   |
|               | *components* that are         | synergies. OSHA      |
|               | suspected or known skin       | requires             |
|               | sensitizers. DfE reviews      | product-level        |
|               | product formulations for      | sensitization        |
|               | negative synergistic effects  | information on all   |
|               | between *components* (e.g.    | MSDSs, if any        |
|               | byproducts of limonene and    | positive results are |
|               | oxidizing agents).            | available.           |
+---------------+-------------------------------+----------------------+
| Surfactants   | DfE has developed a screen    | <http://www.e        |
|               | for surfactants that          | pa.gov/dfe/pubs/proj |
|               | considers acute aquatic       | ects/gfcp/index.htm> |
|               | toxicity and biodegradation   |                      |
|               | as key characteristics for    |                      |
|               | this chemical class.          |                      |
|               | Components that have a        |                      |
|               | relatively high acute         |                      |
|               | toxicity (\<10 ppm) must      |                      |
|               | biodegrade within a 10-day    |                      |
|               | window.                       |                      |
+---------------+-------------------------------+----------------------+
| Training      | Memorandum of Understanding   | OSHA, DOT, and other |
|               | requires each partner company | authorities require  |
|               | to provide its customers with | manufacturers to     |
|               | information on environmental  | provide handling and |
|               | and worker safety matters.    | other worker safety  |
|               |                               | information.         |
+---------------+-------------------------------+----------------------+

**[Appendix I:]{.underline} Product Performance Testing under EPA's
Design for the Environment Formulator Program**

DfE believes performance testing requirements should be product category
specific, and will accept any valid and scientifically sound method of
demonstrating product performance. Examples of performance requirements
that are acceptable to DfE include but are not limited to:

[Glass Cleaners]{.underline} -- Meets user requirements for cleaning,
streaking and smearing when tested according to CSPA method DCC09 or
equivalent method agreed upon by EPA DfE.

[General Purpose Cleaners]{.underline} -- Meets user requirements for
soil removal on relevant substrates when tested according to ASTM method
D4488-95, CAN/CGSB 2-GP-11, Method 20.3, or equivalent method agreed
upon by EPA DfE.

[Carpet Cleaners]{.underline} -- Perform equal to or better than
nationally recognized carpet cleaners in the same category using CSMA
DCC-03 and AATCC Test Method 171-1995 or equivalent method agreed upon
by EPA DfE.

[Washroom Cleaners]{.underline} -- Meets user requirements for soil
removal using ASTM D5343 or equivalent method agreed upon by EPA DfE.

# ATTACHMENT C

####### 

**Formulation Information Request for Cleaning Products**

Formulation Information Request for Cleaning Products

**[Why did I receive this request?]{.underline}**

For a cleaning product to bear the EPA Design for the Environment (DfE)
logo, a company must first complete a hazard-based third party review of
all the ingredients that make up your product. The third party reviewer,
NSF International, will review each ingredient for environmental and
human health information, confirm that your components meet the DfE
Formulator criteria and then will recommend your product to EPA. The
attached forms will initiate this review. Once NSF International has
received the forms below, a business contract will be sent to your
company with a cost estimate for this review.

**[Who is NSF?]{.underline}**

NSF International (NSF) is an independent, not-for-profit organization
of scientists, engineers, technicians, educators, and analysts. NSF
currently provides testing, certification, and audit services for more
than 130,000 products in 82 countries worldwide. It is a trusted neutral
non-governmental agency, serving government, industry, and consumers in
achieving solutions to problems relating to public health and the
environment since 1944. The mission of NSF is to provide clients and the
general public with objective, high quality, timely, third-party
certification services. Services include development of consensus
standards, voluntary product testing and certification with policies and
practices which protect the integrity of registered Marks, education and
training, and research and demonstration, all relating to public health
and the environmental sciences.

**[What information do I provide?]{.underline}**

To begin the review process of a product, a Formulator must first submit
the full product information; this will consist of information on
**all** ingredients in the product (no minimum concentration). Each
ingredient should have a single CAS# associated with it, however, if an
ingredient is made up of more than one component, all CAS#s should be
listed on the Product Information Form. To clarify, an ingredient is the
whole ingredient as sold to a formulator and a component is each
individual chemical within that ingredient. If your company does not
have access to this information due to the proprietary nature of the
ingredient, please provide the supplier's name and contact information.
The Form must include CAS#s, chemical names, trade names, and % in the
formulation for each component in the ingredient. Please submit:

-   Product Information Request Form

    -   Complete sections 1-3 only once per submission

    -   Complete sections 4 for each product

-   A MSDS for the product and each ingredient

-   Product performance testing: Any valid and scientifically sound
    method of demonstrating product performance is acceptable.

-   Any other supplemental product or ingredient environmental health
    and safety information. If available, please submit:

    -   Biodegradation tests on individual ingredients

    -   Acute aquatic toxicity tests on product as a whole or individual
        ingredients

    -   Human health and safety tests

**[Will my information remain confidential?]{.underline}**

Only NSF authorized personnel are permitted accesses to the information
provided on this form. The security of this form and the information it
contains is maintained through our confidential business information
procedures and will [not]{.underline} be revealed or provided to
applicants, their suppliers, or other parties without your company's
prior written consent.

+-------------------------------------------+--------------------------+
| # Product Information Request Form        | ######                   |
|                                           |                          |
| #                                         | ###### NSF USE ONLY      |
|                                           |                          |
|                                           | DCC:                     |
|                                           | [**     **]{.underline}  |
+-------------------------------------------+--------------------------+

**The information requested on this form is important to NSF.**

**[Please complete and return this form as soon as possible, or call
651-493-4247 for assistance.]{.underline}**

######## Company information: 

> Company name [     ]{.underline} Company contact [     ]{.underline}
>
> Address [     ]{.underline} Telephone number [(     )     \
>      ]{.underline} FAX number [(     )     ]{.underline}\
> [     ]{.underline} Email [     ]{.underline}

######## 2. Certification statement:

> I hereby certify that, to the best of my knowledge, the information
> provided to NSF is accurate and complete.
>
> Signature [     ]{.underline} Date [     ]{.underline}
>
> For forms submitted electronically, check this box to indicate
> agreement to the Certification Statement above (required).
>
> Typed or printed name [     ]{.underline}\
> Position/Title [     ]{.underline}

**3. Return instructions:**

> **To send by e-mail,** completely fill out the form, and type your
> name and contact information in Section 4. Check the box indicating
> your agreement with the certification statement. **Send your e-mail to
> <tmcgrath@nsf.org>.**
>
> **To send by fax,** completely fill out and sign the form, then fax to
> **734-827-3871**. This fax number goes to a secure computer in the
> Toxicology Services department of NSF International.
>
> **To send by U.S. mail or courier,** insert completed form in an
> envelope marked \"Confidential Business Information,\" seal in an
> outer envelope, and return to:
>
> Amy Rice
>
> Toxicology Department, Formulator Program
>
> NSF International
>
> 789 Dixboro Road
>
> Ann Arbor, MI. 48105
>
> USA

######## Product information:

##  Product Name/Trade designation

> [     ]{.underline}

0.  Product general information:

    0.  Type of product (all purpose, glass cleaner, floor care...etc.)
        [     ]{.underline}

        Consumer Product or Industrial & Institutional Product

        pH of product: [     ]{.underline}

        Check here if product is an aerosol

        Check here if product is registered with EPA Office of
        Pesticides

        Production volume (lbs/yr) [     ]{.underline}\_\_\_\_\_\_\_

        Check here if product performance data is attached to the
        submission

4.3 Ingredient Worksheet: For sample form and instructions, please see
the last page of this form.

+---+--------------+--------+--------+----------+--------+----+----+
| C | Chemical     | Ingr   | Trade  | Sup      | Other  | \% | Pr |
| A | Name         | edient | Name   | plier(s) | supp   |    | op |
| S |              | Class  |        | (Include | orting | C  | ri |
| N | \[2\]        | (Surfa | \[4\]  |          | inform | om | et |
| o |              | ctant, |        | A        | ation: | po | ar |
| . |              | Frag   |        | lternate | Number | si | y? |
|   |              | rance, |        | Su       | of     | ti |    |
| \ |              | so     |        | ppliers) | ethoxy | on | \  |
| [ |              | lvent, |        |          | lates, | \  | [8 |
| 1 |              | bu     |        | 1        | a      | [7 | \] |
| \ |              | ilder, |        | Supplier | verage | \] |    |
| ] |              | che    |        | per line | chain  |    |    |
|   |              | lator, |        |          | l      |    |    |
|   |              | pH     |        | \[5\]    | ength. |    |    |
|   |              | adj    |        |          | ..etc. |    |    |
|   |              | ustor. |        |          |        |    |    |
|   |              | ..etc) |        |          | \[6\]  |    |    |
|   |              |        |        |          |        |    |    |
|   |              | \[3\]  |        |          |        |    |    |
+---+--------------+--------+--------+----------+--------+----+----+
| * | **     **    | **     | **     | *        | **     | *  |    |
| * |              |     ** |     ** | *     ** |     ** | *  |    |
|   |              |        |        |          |        |    |    |
|   |              |        |        |          |        |    |    |
|   |              |        |        |          |        | ** |    |
|   |              |        |        |          |        |    |    |
|   |              |        |        |          |        |    |    |
| * |              |        |        |          |        |    |    |
| * |              |        |        |          |        |    |    |
+---+--------------+--------+--------+----------+--------+----+----+
| * | **     **    | **     | **     | *        | **     | *  |    |
| * |              |     ** |     ** | *     ** |     ** | *  |    |
|   |              |        |        |          |        |    |    |
|   |              |        |        |          |        |    |    |
|   |              |        |        |          |        | ** |    |
|   |              |        |        |          |        |    |    |
|   |              |        |        |          |        |    |    |
| * |              |        |        |          |        |    |    |
| * |              |        |        |          |        |    |    |
+---+--------------+--------+--------+----------+--------+----+----+
| * | **     **    | **     | **     | *        | **     | *  |    |
| * |              |     ** |     ** | *     ** |     ** | *  |    |
|   |              |        |        |          |        |    |    |
|   |              |        |        |          |        |    |    |
|   |              |        |        |          |        | ** |    |
|   |              |        |        |          |        |    |    |
|   |              |        |        |          |        |    |    |
| * |              |        |        |          |        |    |    |
| * |              |        |        |          |        |    |    |
+---+--------------+--------+--------+----------+--------+----+----+
| * | **     **    | **     | **     | *        | **     | *  |    |
| * |              |     ** |     ** | *     ** |     ** | *  |    |
|   |              |        |        |          |        |    |    |
|   |              |        |        |          |        |    |    |
|   |              |        |        |          |        | ** |    |
|   |              |        |        |          |        |    |    |
|   |              |        |        |          |        |    |    |
| * |              |        |        |          |        |    |    |
| * |              |        |        |          |        |    |    |
+---+--------------+--------+--------+----------+--------+----+----+
| * | **     **    | **     | **     | *        | **     | *  |    |
| * |              |     ** |     ** | *     ** |     ** | *  |    |
|   |              |        |        |          |        |    |    |
|   |              |        |        |          |        |    |    |
|   |              |        |        |          |        | ** |    |
|   |              |        |        |          |        |    |    |
|   |              |        |        |          |        |    |    |
| * |              |        |        |          |        |    |    |
| * |              |        |        |          |        |    |    |
+---+--------------+--------+--------+----------+--------+----+----+
| * | **     **    | **     | **     | *        | **     | *  |    |
| * |              |     ** |     ** | *     ** |     ** | *  |    |
|   |              |        |        |          |        |    |    |
|   |              |        |        |          |        |    |    |
|   |              |        |        |          |        | ** |    |
|   |              |        |        |          |        |    |    |
|   |              |        |        |          |        |    |    |
| * |              |        |        |          |        |    |    |
| * |              |        |        |          |        |    |    |
+---+--------------+--------+--------+----------+--------+----+----+
| * | **     **    | **     | **     | *        | **     | *  |    |
| * |              |     ** |     ** | *     ** |     ** | *  |    |
|   |              |        |        |          |        |    |    |
|   |              |        |        |          |        |    |    |
|   |              |        |        |          |        | ** |    |
|   |              |        |        |          |        |    |    |
|   |              |        |        |          |        |    |    |
| * |              |        |        |          |        |    |    |
| * |              |        |        |          |        |    |    |
+---+--------------+--------+--------+----------+--------+----+----+
| * | **     **    | **     | **     | *        | **     | *  |    |
| * |              |     ** |     ** | *     ** |     ** | *  |    |
|   |              |        |        |          |        |    |    |
|   |              |        |        |          |        |    |    |
|   |              |        |        |          |        | ** |    |
|   |              |        |        |          |        |    |    |
|   |              |        |        |          |        |    |    |
| * |              |        |        |          |        |    |    |
| * |              |        |        |          |        |    |    |
+---+--------------+--------+--------+----------+--------+----+----+
| * | **     **    | **     | **     | *        | **     | *  |    |
| * |              |     ** |     ** | *     ** |     ** | *  |    |
|   |              |        |        |          |        |    |    |
|   |              |        |        |          |        |    |    |
|   |              |        |        |          |        | ** |    |
|   |              |        |        |          |        |    |    |
|   |              |        |        |          |        |    |    |
| * |              |        |        |          |        |    |    |
| * |              |        |        |          |        |    |    |
+---+--------------+--------+--------+----------+--------+----+----+
| * | **     **    | **     | **     | *        | **     | *  |    |
| * |              |     ** |     ** | *     ** |     ** | *  |    |
|   |              |        |        |          |        |    |    |
|   |              |        |        |          |        |    |    |
|   |              |        |        |          |        | ** |    |
|   |              |        |        |          |        |    |    |
|   |              |        |        |          |        |    |    |
| * |              |        |        |          |        |    |    |
| * |              |        |        |          |        |    |    |
+---+--------------+--------+--------+----------+--------+----+----+
| * | **     **    | **     | **     | *        | **     | *  |    |
| * |              |     ** |     ** | *     ** |     ** | *  |    |
|   |              |        |        |          |        |    |    |
|   |              |        |        |          |        |    |    |
|   |              |        |        |          |        | ** |    |
|   |              |        |        |          |        |    |    |
|   |              |        |        |          |        |    |    |
| * |              |        |        |          |        |    |    |
| * |              |        |        |          |        |    |    |
+---+--------------+--------+--------+----------+--------+----+----+

**Omission of information may significantly delay the completion of the
review process.**

**ALL INFORMATION CONTAINED ON THIS PAGE IS CONFIDENTIAL**

# [Formulation information: What should I enter in each column?]{.underline}

\[1\] The **CAS number** (Chemical Abstracts Service registry number) is
a systematic numbering convention that uniquely identifies each
chemical. You may be able to find this information on the MSDS for the
ingredient. If the ingredient is a mixture of several chemicals, enter
the word "mixture." There are multiple resources available on the web
and elsewhere for finding specific CAS numbers (e.g.,
<http://chem.sis.nlm.nih.gov/chemidplus/cmplxqry.html>). All CAS numbers
are up to nine digits, which are separated into three groups by hyphens.
The first part of the number, starting from the left, has up to six
digits; the second part after the first hyphen has two digits. Finally,
the third part of the CAS number following the last hyphen is single
digit. For example, a CAS number may look 123456-12-1. If it is not in
this format, it is not a valid CAS number. If you cannot determine a CAS
number for an ingredient, leave this area blank.

\[2\] The **chemical name** for each component can be found on the MSDS.

\[3\] The ingredient class can refer to: surfactants, solvents,
chelators, fragrances, preservatives/biocide, builders, hydrotropes,
sequestrants, dispersants, sanitizer, dyes/colorants,
enzyme/microorganisms, fragrances, and other.

\[4\] The **trade name** is the unique name or number of the ingredient
as you buy it from your supplier. This information can be obtained from
your purchasing department.

\[5\] The **supplier** is the company from whom you buy this ingredient.
If you know that your supplier is a distributor, and you know the name
of the company that manufactures the ingredient, please enter both
company names here. Write (D) after the distributor's name, and (M)
after the manufacturer's name. For each ingredient that you buy from
more than one supplier, please enter each chemical name, trade name,
supplier, and % on a separate line.

\[6\] A single surfactant CAS number may represent a wide range of
carbon chain length and/or number of ethoxylates. Detailed information
on the specific chemical you are using will help NSF perform an accurate
review of your chemical.

\[7\] The percentage in the ingredient must be completed for each
component. The total of all components must always equal 100%.

\[8\] Check here if your product contains an ingredient purchased from
an outside company and your company is not aware of the exact
composition of that ingredient (i.e. you do not have CAS#s for a
proprietary ingredient).

An example of a completed formulation is shown below:

+---------+-----+-------+-------+-----------+--------+------+------+
| CAS No. | Ch  | Ingre | Trade | Su        | Other  | \%   | Prop |
|         | emi | dient | Name  | pplier(s) | supp   |      | riet |
| \[1\]   | cal | Class |       | (Include  | orting | Com  | ary? |
|         | N   |       | \[4\] |           | inform | posi |      |
|         | ame | \[3\] |       | Alternate | ation: | tion | \    |
|         |     |       |       | S         | Number | \    | [8\] |
|         | \[  |       |       | uppliers) | of     | [7\] |      |
|         | 2\] |       |       |           | ethoxy |      |      |
|         |     |       |       | 1         | lates, |      |      |
|         |     |       |       | Supplier  | a      |      |      |
|         |     |       |       | per line  | verage |      |      |
|         |     |       |       |           | chain  |      |      |
|         |     |       |       | \[5\]     | l      |      |      |
|         |     |       |       |           | ength. |      |      |
|         |     |       |       |           | ..etc. |      |      |
|         |     |       |       |           |        |      |      |
|         |     |       |       |           | \[6\]  |      |      |
+---------+-----+-------+-------+-----------+--------+------+------+
| 681     | Alc | Surfa | Surfa | Company A | C      | 14   |      |
| 31-39-5 | oho | ctant | ctant |           | 12-15, |      |      |
|         | ls, |       | 1     |           | A      |      |      |
|         | Et  |       |       |           | verage |      |      |
|         | hox |       |       |           | 7EO    |      |      |
|         | yla |       |       |           |        |      |      |
|         | ted |       |       |           |        |      |      |
+---------+-----+-------+-------+-----------+--------+------+------+
| 677     | Met | So    | So    | Company B | C12-18 | 36   |      |
| 62-38-3 | hyl | lvent | lvent |           |        |      |      |
|         | soy |       | 1     |           |        |      |      |
|         | ate |       |       |           |        |      |      |
+---------+-----+-------+-------+-----------+--------+------+------+
| ?       | ?   | Bu    | Bu    | Company C | ?      | 5    | X    |
|         |     | ilder | ilder |           |        |      |      |
|         |     |       | 1     |           |        |      |      |
+---------+-----+-------+-------+-----------+--------+------+------+
| 77      | Wa  | So    | So    | Company D |        | 45   |      |
| 32-18-5 | ter | lvent | lvent |           |        |      |      |
|         |     |       | 2     |           |        |      |      |
+---------+-----+-------+-------+-----------+--------+------+------+

# 

# 

# 

# 

# 

# 

# 

# 

# 

# 

# ATTACHMENT D

**DfE Formulator Initiative: Ingredient Worksheet**

<table style="width:100%;">
<colgroup>
<col style="width: 8%" />
<col style="width: 15%" />
<col style="width: 13%" />
<col style="width: 11%" />
<col style="width: 12%" />
<col style="width: 2%" />
<col style="width: 11%" />
<col style="width: 3%" />
<col style="width: 1%" />
<col style="width: 1%" />
<col style="width: 2%" />
<col style="width: 3%" />
<col style="width: 2%" />
<col style="width: 6%" />
<col style="width: 2%" />
<col style="width: 2%" />
</colgroup>
<tbody>
<tr class="odd">
<td colspan="16"><img src="media/image3.png"
style="width:1.02778in;height:1.02778in" /></td>
</tr>
<tr class="even">
<td colspan="2"></td>
<td colspan="4"></td>
<td colspan="10"><strong>Product Information</strong></td>
</tr>
<tr class="odd">
<td colspan="2" rowspan="2">Company Name:</td>
<td colspan="3"></td>
<td></td>
<td colspan="8">Is the product registered with EPA Office of Pesticides?
(Y/N)</td>
<td></td>
<td></td>
</tr>
<tr class="even">
<td colspan="4"></td>
<td colspan="10"></td>
</tr>
<tr class="odd">
<td colspan="2">Product:</td>
<td colspan="3"></td>
<td></td>
<td colspan="4">Is the product an aerosol? (Y/N)</td>
<td></td>
<td colspan="5"></td>
</tr>
<tr class="even">
<td colspan="2"></td>
<td colspan="4"></td>
<td colspan="10"></td>
</tr>
<tr class="odd">
<td colspan="2"></td>
<td colspan="4"></td>
<td>Enter pH of product</td>
<td></td>
<td colspan="8"></td>
</tr>
<tr class="even">
<td colspan="2"></td>
<td colspan="4"></td>
<td colspan="10"></td>
</tr>
<tr class="odd">
<td colspan="2"></td>
<td colspan="4"></td>
<td colspan="3">Enter Date of Form Submittal</td>
<td colspan="4"></td>
<td colspan="3"></td>
</tr>
<tr class="even">
<td colspan="2"></td>
<td colspan="4"></td>
<td colspan="10"></td>
</tr>
<tr class="odd">
<td></td>
<td colspan="2"><strong>Chemical Name</strong></td>
<td><strong>CAS Registry #</strong></td>
<td colspan="8"><strong>Trade Name</strong></td>
<td colspan="4"><strong>% by weight in formula</strong></td>
</tr>
<tr class="even">
<td rowspan="2"><strong>Surfactant</strong></td>
<td colspan="2"></td>
<td></td>
<td colspan="8"></td>
<td colspan="4"></td>
</tr>
<tr class="odd">
<td colspan="2"></td>
<td></td>
<td colspan="8"></td>
<td colspan="4"></td>
</tr>
<tr class="even">
<td rowspan="2"><strong>Hydrotrope</strong></td>
<td colspan="2"></td>
<td></td>
<td colspan="8"></td>
<td colspan="4"></td>
</tr>
<tr class="odd">
<td colspan="2"></td>
<td></td>
<td colspan="8"></td>
<td colspan="4"></td>
</tr>
<tr class="even">
<td rowspan="2"><strong>Builder</strong></td>
<td colspan="2"></td>
<td></td>
<td colspan="8"></td>
<td colspan="4"></td>
</tr>
<tr class="odd">
<td colspan="2"></td>
<td></td>
<td colspan="8"></td>
<td colspan="4"></td>
</tr>
<tr class="even">
<td rowspan="2"><strong>Sequestrant</strong></td>
<td colspan="2"></td>
<td></td>
<td colspan="8"></td>
<td colspan="4"></td>
</tr>
<tr class="odd">
<td colspan="2"></td>
<td></td>
<td colspan="8"></td>
<td colspan="4"></td>
</tr>
<tr class="even">
<td rowspan="2"><strong>Dispersant</strong></td>
<td colspan="2"></td>
<td></td>
<td colspan="8"></td>
<td colspan="4"></td>
</tr>
<tr class="odd">
<td colspan="2"></td>
<td></td>
<td colspan="8"></td>
<td colspan="4"></td>
</tr>
<tr class="even">
<td rowspan="2"><strong>Solvent</strong></td>
<td colspan="2"></td>
<td></td>
<td colspan="8"></td>
<td colspan="4"></td>
</tr>
<tr class="odd">
<td colspan="2"></td>
<td></td>
<td colspan="8"></td>
<td colspan="4"></td>
</tr>
<tr class="even">
<td rowspan="2"><strong>Sanitizer</strong></td>
<td colspan="2"></td>
<td></td>
<td colspan="8"></td>
<td colspan="4"></td>
</tr>
<tr class="odd">
<td colspan="2"></td>
<td></td>
<td colspan="8"></td>
<td colspan="4"></td>
</tr>
<tr class="even">
<td rowspan="2"><p><strong>Enzyme/</strong></p>
<p><strong>Micro-organism</strong></p></td>
<td colspan="2"></td>
<td></td>
<td colspan="8"></td>
<td colspan="4"></td>
</tr>
<tr class="odd">
<td colspan="2"></td>
<td></td>
<td colspan="8"></td>
<td colspan="4"></td>
</tr>
<tr class="even">
<td rowspan="2"><strong>Preservative/Biocide</strong></td>
<td colspan="2"></td>
<td></td>
<td colspan="8"></td>
<td colspan="4"></td>
</tr>
<tr class="odd">
<td colspan="2"></td>
<td></td>
<td colspan="8"></td>
<td colspan="4"></td>
</tr>
<tr class="even">
<td rowspan="2"><strong>Fragrance</strong></td>
<td colspan="2"></td>
<td></td>
<td colspan="8"></td>
<td colspan="4"></td>
</tr>
<tr class="odd">
<td colspan="2"></td>
<td></td>
<td colspan="8"></td>
<td colspan="4"></td>
</tr>
<tr class="even">
<td rowspan="2"><strong>Colorant</strong></td>
<td colspan="2"></td>
<td></td>
<td colspan="8"></td>
<td colspan="4"></td>
</tr>
<tr class="odd">
<td colspan="2"></td>
<td></td>
<td colspan="8"></td>
<td colspan="4"></td>
</tr>
<tr class="even">
<td rowspan="3"><strong>Other</strong></td>
<td colspan="2"></td>
<td></td>
<td colspan="8"></td>
<td colspan="4"></td>
</tr>
<tr class="odd">
<td colspan="2"></td>
<td></td>
<td colspan="8"></td>
<td colspan="4"></td>
</tr>
<tr class="even">
<td colspan="2"></td>
<td></td>
<td colspan="8"></td>
<td colspan="4"></td>
</tr>
<tr class="odd">
<td></td>
<td colspan="2"></td>
<td></td>
<td colspan="8"></td>
<td colspan="4"><strong>Total = 100%</strong></td>
</tr>
</tbody>
</table>

[^1]: "Green to Gold: How Smart Companies use environmental strategy to
    innovate, create value, and build competitive advantage\" by Daniel
    Esty and Andrew Winston, Yale University Press, New Haven, 2006

[^2]: Bureau of Labor Statistics (BLS) *Employer Costs for Employee
    Compensation, Supplementary Tables.* From Supplementary Table 2,
    Employer costs per hour worked for employee compensation and costs
    as a percent of total compensation: Private industry workers in
    manufacturing industries, by occupational group, establishment size
    and bargaining status, September 2007. Available at:
    http://www.bls.gov/ncs/ect/sp/ecsuptc4.pdf

[^3]: OPM, 2008. Salary Table 2008-DCM. Available at
    http://www.opm.gov/oca/08tables/pdf/dcb_h.pdf

[^4]: A *component* is a chemical as identified by its Chemical Abstract
    Service (CAS) number. An *ingredient* may be one component or a
    blend of multiple components.