The SunWise Program

ICR # 1904.06

U. S. Environmental Protection Agency

Office of Air and Radiation
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Part A of the Supporting Statement

1. Identification of the Information Collection

1(a) Title of Information Request

The title of this Information Collection Request (ICR) is The SunWise Program (ICR# 1904.06; 

OMB Control Number 2060-0439).

1(b) Short Characterization/Abstract

The SunWise Program was initiated in 1998 through a statutory mandate under Title IV of the 

Clean Air Act. The long term objective of the SunWise Program is to reduce the incidence of, 

and morbidity and mortality from skin cancer, cataracts, and other UV-related health effects in 

the United States. Short term objectives include: 1) reducing the risk of childhood overexposure 

to the sun by changing the knowledge, attitudes, and behaviors of elementary school children and 

their care givers; and 2) improving the availability of accurate, timely, and useful UV data 

directly to schools and communities across the United States.

The SunWise Program builds on traditional health education practices through the use of existing 

curricula, learning standards, scientific strategies, and evaluation mechanisms. The Program is a 

collaborative effort of schools, communities, health professionals, educators, environmental 

organizations, meteorologists, local governments, federal agencies, and others. Participating 

schools sponsor classroom and school activities to raise children’s awareness of stratospheric 

ozone depletion, UV radiation, and the largely preventable health risks from overexposure to the 

sun, as well as simple sun safety practices. All educators interested in participating in this 

partnership program are asked to register using the online form 

(www.epa.gov/sunwise/becoming.html and www.epa.gov/sunwise/becoming_partner.html) or a 

hard copy version distributed by EPA. EPA will use the information provided through this 

registration to maintain a database of participating schools and organizations and a mailing list 

for information distribution purposes. Participating schools and organizations receive a variety of 

materials, including a classroom “Tool Kit” of games, songs, puzzles, story books, videos, access 

to the internet UV intensity mapping/graphing tools, and more. The Tool Kit also includes 

sample sun safety policies and guidelines to help expand the sun safety message beyond the 

classroom.

Teachers who sign up for SunWise are asked to complete a survey at the end of program 

implementation. Results of these surveys are used to fine-tune existing SunWise materials and 

develop new ones that better meet our participants’ needs. Teachers are also asked if they are 

interested in administering a brief survey to their students before and after program 

implementation. The surveys will be made available on the SunWise website for all teachers that 

express interest in the survey process. Student survey responses are voluntary and anonymous. 

The results from the student surveys are used to gauge program effectiveness and also help guide 

materials development.
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SunWise is also seeking additional qualitative information regarding barriers to the promotion of 

SunWise and adoption of school policies, as well as teachers’ receptiveness to a new recognition 

program that SunWise is considering developing. The program would recognize levels of 

SunWise teaching for interested educators. The more SunWise teaching and sun safety policy

changes implemented by an educator, the higher her/his level of SunWise (similar to a bronze, 

silver and gold level) recognition. This new recognition/incentives program would allow EPA to 

get a better grasp on the level of engagement with SunWise, and would allow for future 

effectiveness studies comparing impacts on student knowledge, attitude and behavior with an 

educator’s level of engagement. To gather qualitative information on these issues, the SunWise 

Program will conduct voluntary, individual, semi-structured telephone interviews with willing 

educators.

In addition, EPA has teamed with other members of the National Council on Skin Cancer 

Prevention, which include the American Cancer Society, the American Academy of Pediatrics, 

and the Centers for Disease Control and Prevention, to support the Don’t Fry Day (DFD) 

campaign. As part of this campaign, educators are asked to pledge to incorporate sun safety into 

their spring and summer activities. The DFD pledge is available online at: 

http://www.epa.gov/sunwise/dfdpledge.html.

Further, SunWise has developed an online interactive SunWise Sun Safety Certification Program 

that enables students, adults, organizations, and employers to develop credentials on sun safety 

awareness and behaviors. In order to gauge the certification program’s effectiveness, EPA will 

be collecting information on demographics, knowledge, attitudes, intended behavior, and 

behavior of the tutorial users. User types include: outdoor recreation staff at camps, parks, 

recreation programs, sports organizations, lifeguards, etc. The certification program is available 

online at: http://www.epa.gov/sunwise/tutorial.html

Finally, EPA will pretest a new survey for SunWise non-school partners. While schools are the 

primary programmatic component of SunWise, SunWise is also promoted through registered 

501(c)(3) organizations such as science centers and camps, children's museums, and scouting 

groups, as well as other not-for-profit organizations like local, county and state health, recreation 

and education departments. The new partner survey will aim to understand how the SunWise 

Program is being implemented by non-school partners, and how it can be improved. 

PREVIOUS TERMS OF CLEARANCE:

On November 2, 2001, OMB approved ICR #1904.01 with Terms of Clearance. EPA has 

addressed OMB’s terms in the following manner.

This collection is approved in part and disapproved in part. EPA is approved to collect 

registration information and to conduct the requested student survey and teacher survey. These 

portions of the collection are approved for two years, until November 2003. OMB understands 

that EPA no longer intends to collect information under the Parent Survey and the School 

Administrator Survey. These two surveys are not approved. OMB has adjusted the burden of the 

collection accordingly from EPA's request. 
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EPA Response: We will not be surveying parents or school administrators under this ICR 

renewal.

As discussed in Part B of the revised supporting statement, EPA plans to assess two sampling 

issues in Fall 2002 based on results from the first year of the student survey: (1) whether it is 

necessary to include in the sampling protocol an approach to stratify between warm and cool 

states, and (2) whether it is necessary to include an additional sampling stage to sample 

classrooms within a school that has been selected for participation. EPA should report to OMB 

its findings with regard to these issues before beginning the second year of sampling, and advise 

OMB whether it intends in the second year of the collection to (1) stratify between warm and 

cool states in the first stage of sampling, 

EPA Response (sent to OMB on 8/29/02): We have conducted this analysis and found no 

differences between the students in the 37 cooler states versus the 13 warm states, as categorized 

by the UV Index values. We measured change in scores from pretest to posttests on children's 

knowledge of sun protection, attitudes toward the sun, and current sun protection practices and 

found minimal differences in the change. Therefore, with no differences between the two groups, 

there would be no reason to stratify our findings. 

and/or (2) add a sampling stage to sample classrooms within a selected school. 

EPA Response (sent to OMB on 8/29/02): We analyzed the composition of registrants in the 

SunWise database by region of the country and the number of schools that contained more than 

one classroom. It appears that 75 percent of schools in warm and cool climates have no more 

than 1 classroom per school with negligible difference by region. There is little evidence of 

clustering or differences in clustering between regions of the country. If that were the case, we 

would have to account for this effect by performing tests of intraclass correlation.

OMB also notes that EPA must include the OMB number, expiration date, and Paperwork 

Reduction Act notice on the teacher survey before using that instrument to collect information.

EPA Response: All information is now included on the teacher survey. See attachment #1a and 

1b for verification.

On February 6, 2008, OMB approved ICR #1904.03 with Terms of Clearance. EPA has 

addressed OMB’s terms in the following manner.

This ICR is approved in part. The registration of educators component is approved at this time. 

Other components of this ICR is not approved at this time, but the agency may resubmit these 

components with no significant or material change, pending the results of pre-tests that will 

examine the readability of the survey instrument.

EPA Response: The other components were resubmitted, and OMB approved the requested 

documents.
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2. Need for Use of the Collection

2(a) Need/Authority For The Collection

This collection will be used for program material distribution and to determine program 

effectiveness and participant satisfaction. 

Educators will be asked to fill out a simple registration form, which we use to mail out the 

program materials and keep track of the Program’s:

 geographic reach (Which states/regions have SunWise schools?);

 grade-level and subject-matter distribution (How many 1st grade teachers are using SunWise? 

How many math teachers are using SunWise? etc.); and

 student participation level (How many students is SunWise potentially reaching?).

Surveys to be administered include:

 Teacher online survey for measuring their receptivity to the educational component of the 

Program and experience with the SunWise Tool Kit and educational resources;

 Student survey to identify sun safety knowledge, attitudes, and behaviors among students 

before and after participation in the Program; 

 One-on-one semi-structured telephone interviews with teachers to complement the 

information collected through the self-reported Teacher Survey instrument by providing 

richer, qualitative information regarding barriers to the promotion of SunWise and adoption 

of school policies, as well as teachers’ receptiveness to a new recognition program that 

SunWise is considering developing; 

 Embedded questions within the SunWise Don’t Fry Day pledge collect information related 

to demographic and mailing information and intent for incorporating sun safety activities into 

spring and summer teaching.

 Embedded questions within the SunWise Sun Safety Certification Program measure 

receptivity to sun protection, demographic information, and current practices, attitudes and 

knowledge.

 Pretest of the partner survey for developing a survey to measure and understand partners’ 

receptivity to and use of the SunWise Tool Kit and other educational resources.

The data will be analyzed and results will indicate the Program’s effect on participants’ sun

safety knowledge, attitudes, and behaviors, as well as help SunWise understand how the Program 

is being implemented and how it can be improved. Responses to the collection of information 

are voluntary. Responses to the collection of information remain confidential, and responses to 

the student survey are anonymous.

The SunWise Program recognizes the challenge of measuring the progress and evaluating the 

effectiveness of an environmental and public health education program where the ultimate goal 

is to reduce risk and improve public health. Therefore, the continual and careful evaluation of 

program effectiveness through a variety of means, including data from pre- and post-intervention 
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surveys, tracking and monitoring of classroom activities and school policies, and experts, is 

necessary to monitor progress and refine the program. 

2(b) Practical Utility/Users of the Data

EPA/SunWise will use the survey results to review process and impact results—including cost 

effectiveness—and adapt as appropriate its messages, approaches, and materials. Survey results 

will enable EPA/SunWise to better meet the needs of its educator and student participants, with 

the long range goal of reducing the incidence and effects of skin cancer and other UV-related 

health problems among children and adults. 

Past collections have resulted in numerous publications and presentations at health-related 

conferences. Examples can be found at the links below:

- http://apha.confex.com/apha/138am/webprogram/Paper216559.html

- http://www.cdc.gov/nccdphp/conference/pdf/program_book_2009.pdf

- http://pediatrics.aappublications.org/cgi/content/abstract/121/5/e1074

- http://epa.gov/sunwise/evaluation.html

3. Nonduplication, Consultations, and Other Collection Criteria

3(a) Nonduplication

The information required to complete the survey instruments and interviews for the SunWise 

Program is not duplicative of information otherwise available to EPA. In the early stages of the 

SunWise Program’s development in 1997, several searches for information were completed in 

consult with external stakeholders, including representatives from the following organizations:

American Academy of Dermatology

American Cancer Society

Boston University Medical Center - Skin Oncology, Cancer Prevention & Control Center

Centers for Disease Control and Prevention

National Association of Physicians for the Environment

National Safety Council

The Skin Cancer Foundation

Results from these consultations indicated that no other formal, student-focused, sun safety 

programs were being implemented in the United States, nor were surveys being conducted on 

attitudes and practices of children relating to sun exposure. 

In addition, to EPA/SunWise’s knowledge, there is no other sun safety certification available to 

outdoor recreation staff in the U.S., therefore it is essential that accurate information on the users 

and use of the certification program be collected for program refinement.

Conducting timely and useful process evaluation is also of importance if the SunWise Program is 

to continue providing high-grade and pertinent resources for educators across the United States.
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3(b) Public Notice Required Prior to ICR Submission to OMB

Official notice of this proposed collection appeared in the Federal Register on September 3, 2010 

(75 FR 54143). One comment was received. Since EPA coordinates with other federal and nonfederal entities working to prevent skin cancer and other health effects from overexposure to the 

sun, and both Congress and EPA allocate funding for the program, no further justification for the 

comment is needed.

3(c) Consultations

The following professionals were consulted during the development of the three survey

instruments:

 Alan Geller, Harvard School of Public Health, Division of Public Health Practice, (617) 495-

4000

 Dave Buller, PhD, AMC Cancer Research Center, (303) 239-3511

 Dr. Barbara Gilchrest, Chair, Department of Dermatology, Boston University School of 

Medicine, (617) 638-5538

 Dr. Donald Miller, Assistant Professor of Epidemiology and Health Policy, Boston 

University School of Medicine, (781) 687-2865

 Dr. Amy Mack, Psy.D., ICF International, (703) 219-4311

3 (d) Effects of Less Frequent Collection

SunWise depends on registration information to:

 maintain an accurate list of participants; and 

 ensure timely distribution of program materials and program updates to participants.

SunWise depends on survey responses to:

 help guide program development; 

 measure participant satisfaction with the program; 

 test new ideas for recognition and incentives; and

 elicit basic information on attitudes and practices of children and their caregivers relating 

to sun exposure.

SunWise depends on certification program information to:

 determine the current knowledge, attitudes, behavioral intentions and behaviors of 

individuals taking the tutorial; 

 determine which tutorial to provide to the user;

 measure how many and what type of users are becoming certified;

 ensure the tutorial does not take too long to complete;

 ensure rigor and enthusiasm for the tutorial; and 
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 determine whether or not the tutorial is delivering the information in an easy-tounderstand manner.

Conducting the surveys and information collection less frequently may slow down the Program’s 

ability to institute participants’ desired changes. 

3(e) General Guidelines

All OMB guidelines will be adhered to by EPA/SunWise Program.

3(f) Confidentiality

Names of participating schools and organizations may be made public. All names of registered 

educators and other participating individuals will remain confidential. All responses to the 

collection of survey information will remain confidential. All student surveys are also completed 

on an anonymous basis (no identifying information is included on the survey form). Certification 

program users will be asked to provide their first and last name so they can be given a certificate 

of completion with their name on it; however, the information will not be collected by EPA. 

EPA and a contractor will analyze survey results and proceed accordingly. 

3(g) Sensitive Questions

The survey instruments of this ICR contain no sensitive questions.

4. The Respondents and the Information Requested

4(a) Respondent/SIC and NAICS Codes

Entities potentially affected by this action are elementary, middle, and high school students and 

educators (SIC Div. I: Group 8211, NAICS code: 61111), as well as recreation workers 

(NAICS code: 813400), health educators (NAICS code: 999300), and preschool teachers 

(NAICS: 624400).

4(b) Information Requested

The registration form (Attachment 1a and 1b, also available at 

www.epa.gov/sunwise/becoming.html and www.epa.gov/sunwise/becoming_partner.html) is a 

simple, 10-minute questionnaire that asks teachers to provide: the name and contact information 

of the participating school; school composition (e.g. grade levels); and information specific to 

the interest areas of the registering teacher. The purpose of this form is to ensure that EPA 

distributes the most relevant education materials to all SunWise participants.

The survey instruments covered under this ICR are as follows:
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 Teacher Survey (Attachment 2): Educators will be asked to evaluate their and their 

students’ receptivity to sun safety resources provided by EPA. Additionally, educators 

will be asked about how they implemented the SunWise program in their 

school/classroom and how many students they reached. Finally, educators will be asked 

about areas for program growth, including their receptivity to new resources and an 

updated recognition program. Educator feedback about the usefulness of classroom and 

school materials will be vital to the refinement of program materials. This information 

can be submitted online. Part B(i) of the Supporting Statement provides additional 

information on the teacher survey design.

 Student Survey (Attachment 3a and 3b): This survey will be administered by volunteer 

teachers to participating students before and after implementation of SunWise activities. 

Pre-test and post-test surveys are nearly identical in content, with the exception of one 

question in the post-test which is aimed at verifying that the student has participated in 

SunWise. This simple, 10-minute questionnaire elicits basic information on knowledge, 

attitudes, and practices of children relating to sun exposure. The survey is identical to that 

previously approved by OMB (Control No. 2060-0439). Part B(i) of the Supporting 

Statement provides additional information on the student survey design.

 Teacher Telephone Interviews (Attachment 4): To complement the information 

collected through the self-reported Teacher Survey instrument, some teachers will be 

asked to participate in one-on-one, semi-structured telephone interviews to provide

qualitative information regarding barriers to the promotion of SunWise and adoption of 

school policies, as well as teachers’ receptiveness to a new recognition program that 

SunWise is considering developing. An interview guide with topics for discussion is 

provided in Attachment 4. Part B(ii) of the Supporting Statement provides additional 

information on the teacher survey design.

 SunWise Don’t Fry Day pledge: Embedded questions within the pledge collect 

information related to demographic information and intent for incorporating sun safety 

activities into spring and summer teaching. This information can be submitted online, and 

the pledge is available at: http://www.epa.gov/sunwise/dfdpledge.html

 SunWise Sun Safety Certification Tutorial Questions: Certification program users 

will be asked to provide their first and last name so they can be given a certificate of 

completion with their name on it. The information will not be collected by EPA. 

Additionally, users will be asked a series of questions to determine their current sun 

protection knowledge, attitudes and behaviors, and their receptivity to sun protection 

generally. The questions being asked will also help educate the user by reminding them 

of their own behavior in comparison to the desired behavior (practicing sun safety). Part 

B(iii) of the Supporting Statement provides additional information on the certification 

program survey design.

 Pretest of the Partner Survey (Attachment 5): Selected partners will be asked to pretest 

a survey to measure partners’ receptivity to the SunWise Tool Kit and other educational 

resources. Part B(iv) of the Supporting Statement provides additional information on the 

pretest partner survey design.

Registration forms can be submitted electronically or in hard copy form using envelopes 

provided by EPA. The teacher survey is available electronically. Teachers will be given the 

option to return student surveys either by email, fax, or postage-paid envelopes provided by
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EPA. Neither the registration nor the surveys require that respondents keep records or maintain 

files.

5. The Information Collected

5(a) Agency Activities

The Agency activities associated with registration of participants done through the

SunWise Program consists of the following:

 Maintain participant database;

 Maintain mailing list for information distribution purposes.

The Agency activities associated with surveying done through the SunWise Program consists of 

the following:

 Develop collection instruments;

 Answer respondent questions;

 Conduct individual telephone interviews with teachers;

 Audit and/or review data submissions;

 Reformat the data;

 Analyze the data and make program adjustments as needed;

 Store the data.

The Agency activities associated with the certification program done through the SunWise 

Program consists of the following:

 Store and consolidate data, none of which is sensitive or personal; and

 Review consolidated data and make adjustments as needed.

5(b) Collection Methodology and Management

In collecting and analyzing the information associated with this ICR, EPA will use electronic and 

hard-copy registration forms, electronic and hard-copy surveys, and telephone interviews. 

Further details on the collection methodology and management for the surveying done through 

the SunWise Program are provided below.

Registration

EPA routinely promotes the SunWise Program through presentations and exhibits at meetings of 

nurses, teachers, and other educators. Registrants provide their name and contact information, 

including the name of their school, and state whether they are a classroom teacher, health 

teacher, gym teacher, or school nurse on paper copy registration forms. This information is then 

entered into a registration and tracking system housed on EPA servers. In addition to the paper 

copy registrations, EPA also registers educators and partners through an online registration page 
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housed on EPA’s SunWise program website. All information collected is protected by adequate 

security and the system is registered with the Automated System Security Evaluation and 

Remediation Tracking (ASSERT) program to meet reporting requirements under the Federal 

Information Security Management Act (FISMA). 

The data is used to send registrants SunWise resources and alert registrants of sun safety-related 

opportunities and new resources. No personally identifiable information is shared outside of EPA 

and its contractors and grantees.

Teacher and Student Surveys

Teacher Surveys are conducted to determine: 

 Students’ satisfaction with SunWise activities and resources;

 Teachers’ satisfaction with SunWise activities and resources;

 How and how often teachers are using the SunWise materials, resources and 

programming;

 How many students are receiving SunWise education;

 If teachers are sharing resources with other teachers;

 If school policies are being changed as a result of SunWise;

 If teachers are changing their own behavior;

 If students are changing their behavior;

 If teachers have suggestions for improving or creating new SunWise resources.

EPA will send a recruitment email in the Spring/Summer timeframe each year encouraging all 

registered participants to take the SunWise Teacher Survey (Attachment 2) hosted online. 

Participants may also be recruited through additional avenues, such as recruitment letters 

distributed through the SunWise Tool Kit, educator conferences, or direct mailings. Since this 

survey will be voluntary and self-selecting, it will not be generalizable to the entire pool of 

registered SunWise teachers. However, it will be informative and provide insight into how some 

teachers utilize SunWise materials and how EPA can encourage higher use rates.

Part of the Teacher Survey will be an optional student pre-test and post-test survey using the 

validated student survey used in the previous ICR period (Attachment 3a and 3b). There will be 

no control group for this portion of the survey, and no generalizations will be made from this 

data. It will serve as a useful way to see if students are still getting the same benefit from the 

SunWise Tool Kit as in quasi-experimental study designs testing the same concepts (see previous 

ICR supporting statement for more details). Again, because this portion of the survey will be 

voluntary and self-selecting, the results will not be generalizable to every student that has 

received a SunWise education.

For those teachers that choose to participate, they will provide children with a double-sided, onepage anonymous survey instrument. After students complete the pre-test in the spring, teachers 

will lead the SunWise lessons. SunWise will recommend that participating teachers administer 

the post-test survey at least one month after teaching the SunWise lessons, and will ask teachers 

to report what the time gap was between SunWise lessons and administration of the survey. 
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All student surveys are anonymous. Since surveys are anonymous, no specific information on the 

child can be reported to parents or school staff. Surveys are done in the classroom setting, and 

conducted by the teachers; thus, it would not be feasible for the teachers to obtain consent from 

the parents and assent from the children for a classroom teaching tool.

Teachers will be instructed to return completed student surveys to EPA by one of several ways, 

including scanning and emailing the surveys, faxing the surveys, or by requesting a selfaddressed, stamped envelope from EPA.

EPA will ensure the accuracy and completeness of collected information by having all surveys 

reviewed by a contractor, grantee, or EPA staff. The data collected from the surveys will serve 

to provide information internally to help improve the SunWise Program. Since the results are 

not intended to be generalizable, no statistical approach is needed.

Part B(i) of the Supporting Statement presents more detailed information on the data collection, 

management, and analysis methods for the teacher and student surveys.

Teacher Individual Interviews

To complement the self-reported Teacher Survey instrument, individual interviews will be 

conducted with selected teachers to gather richer, qualitative information regarding: 

 Teachers’ involvement in the SunWise Program;

 If school policies are being changed as a result of SunWise and how to overcome the 

barriers to those changes;

 Which SunWise activities and resources teachers feel are the most effective; 

 How teachers’ approach to teaching SunWise activities has changed over time;

 How the SunWise Program can more effectively disseminate its materials and recruit 

more teachers;

 How the SunWise Program can encourage teachers to increase their involvement in 

SunWise and their promotion of sun safety in schools; and

 Receptiveness to an incentives or “Levels of SunWise” educator recognition program, 

and ideas for making such a program successful.

Interview participants will be recruited via a screening email to all registered SunWise educators 

asking (a) whether they have taught SunWise in the past two years; (b) how many years they

have been teaching SunWise; and (c) whether they are willing to both complete an online teacher 

survey and participate in a one-on-one telephone interview. Teachers responding positively to 

both screening questions (a) and (c) will be grouped by region and length of participation, and 

across these groups, 50 teachers will be randomly selected to participate in the interview process. 

To the extent possible, the selected teachers will represent the geographical and participation 

range of SunWise, though the sample will not necessarily be representative in a statistical sense.

The teachers that are not selected will still be encouraged to take the online survey, but will not 

be part of the group that will be individually interviewed. After the selected participants have 
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taken the online survey, EPA will set up a convenient time to interview each of the selected 

teachers. 

Teachers will participate in one online survey and one telephone interview per year over a three 

year period, with slightly different informational goals for each year. In the first year, the 

interview will include discussion about the development of an educator recognition or incentives 

program, while interviews in later years may focus on other areas of interest, such as parental 

involvement. 

Since participation is both voluntary and self-selecting, the results of this qualitative study will 

not be generalizable to the entire pool of registered SunWise teachers. The data collected from 

the interviews will serve only to provide information internally to help improve the SunWise 

Program and the development of a new recognition program. 

Part B(ii) of the Supporting Statement presents more detailed information on the data collection, 

management, and analysis methods for the teacher interviews.

SunWise Don’t Fry Day Pledge

EPA will collect information as educators complete the pledge online. Prior to Don’t Fry Day

each year (the Friday before Memorial Day), EPA will review the information collected and 

summarize participation for promotional efforts. Additionally, EPA will mail a poster and 

stickers to all educators taking the pledge. The pledge is available at: 

http://www.epa.gov/sunwise/dfdpledge.html

Certification Tutorial

EPA will collect information as participants take the tutorial. Many of the questions will help 

instill the information they are learning through the tutorial. Part B(iii) of the Supporting 

Statement presents more detailed information on the data collection, management, and analysis 

methods for the tutorial/certification program.

EPA plans to periodically review data collected from the certification program/tutorial and make 

refinements to the program as necessary. The knowledge gained through this information 

collection will inform programmatic decisions, and allow EPA to gain a better understanding of 

the target audience to determine if additional intervention is needed in the outdoor recreation 

setting. While results cannot be generalized to the general outdoor recreation staff population due 

to the limitation of self-selection, the information will be informative and will be shared with 

partners and the public for improved tailoring of interventions to the outdoor recreation audience.

Pretest Partner Survey

EPA will undertake pretesting of a survey for non-school partners participating in the SunWise 

Program. These partners may include state and local health departments, childcare centers, 

museums, camps, and science centers. The purpose of the survey will be generally to better
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understand how non-school partners are interacting with the SunWise Program, as well as to 

determine:

 How and how often partners are using the SunWise materials, resources and 

programming;

 How many children are receiving SunWise education through non-school partners;

 Children’s satisfaction with SunWise activities and resources;

 Partners’ satisfaction with SunWise activities and resources;

 If partners are sharing resources with other partners;

 If partner organizations’ sun safety policies are being changed as a result of SunWise;

 If partners have suggestions for improving or creating new SunWise resources.

The pretesting is intended to determine the validity and effectiveness of the survey questions—

e.g., whether questions measure what they are supposed to measure, whether partners understand 

what the questions are asking are asking, and whether the questions are the right questions to 

gain a better understanding of how partners are interacting with the SunWise Program.

EPA will send a recruitment email in the Spring/Summer timeframe encouraging registered 

partners to participate in the pretesting of the partner survey (Attachment 5). Participants may

also be recruited through additional avenues, such as recruitment letters distributed through the 

SunWise Tool Kit, educator conferences, or direct mailings. From those partners indicating their 

willingness to participate, EPA will sort the partners into types of partners (e.g., health 

departments, childcare centers, camps, and educational centers such as museums or science 

centers) and randomly select participants from each group for a total of 30 participants. 

Depending on available resources and other constraints, the survey may be self-administered 

with feedback gathered from each participant over the telephone, or the survey may be 

administered in-person either in an individual or group setting, with feedback gathered through 

in-person interviews. In either case, participants will be asked if they understood all questions 

and whether there were questions they would suggest removing or adding to better reflect the 

participation of partners in the Program. Based on this feedback, EPA will revise the partner 

survey. 

Part B(iv) of the Supporting Statement presents more detailed information on the data collection, 

management, and analysis methods for pretesting the partner survey.

5(c) Small Entity Flexibility

Not applicable.

5(d) Collection Schedule

Registration: All teachers are required to register for the Program if they wish to receive the 

SunWise Tool Kit (www.epa.gov/sunwise/becoming.html and 

www.epa.gov/sunwise/becoming_partner.html) and regular program updates. 
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Teacher and Student Surveys: All program participants are invited to take the Teacher Survey

at any time during the year. As noted above, recruitment emails will be sent in the 

Spring/Summer to all registrants encouraging them to take the Teacher Survey, but it is always 

optional. 

Teachers who opt for their classrooms to participate in the student pre-test and post-test surveys 

will be asked to administer the pre-tests before teaching the SunWise lessons, and then to 

administer the post-test survey at least one month after teaching the SunWise lessons.

Teacher Interviews: Participants (as selected using the method described in Part B(ii) of the 

Supporting Statement will complete the online survey and one telephone interview per year over 

the three year period.

Don’t Fry Day Pledge: All educators are invited to take the DFD pledge at any time during the 

year. A recruitment email will be sent in the Spring to all registrants encouraging them to take 

the pledge, but participation is always optional. Participants may also be recruited through 

additional avenues, such as educator conferences.

Certification Tutorial: All outdoor educators are invited to take the certification tutorial at any 

time during the year. 

Partner Survey Pretesting: The partner survey will be pretested once in the three-year ICR 

period.

6. Estimating the Burden and Cost of the Collection

6(a) Estimating Respondent Burden

Registration: EPA developed the SunWise Program Registration Form with the Agency’s 

Internet Support Team in Research Triangle Park, North Carolina. Input from a five-person focus 

group was used to determine average completion time. Teachers are asked to complete the 

registration form only once during their participation in the program for a total registrant burden 

of 10 minutes.

Annual estimated respondent burden: 

Annual Respondent Burden- Registration

Registrant Group Hour Burden

Educator 0.17

Teacher and Student Surveys: During the development of the teacher survey, EPA, in consult 

with a contractor and less than nine educators reviewed the teacher survey to determine 

appropriate content and survey completion time. The teacher survey is administered one time 

each year and takes approximately 20 minutes to complete. If the teacher decides to conduct the 
16

student pre- and post-test surveys, additional time burden will be experienced by the teacher to 

administer the student surveys (noted below).

During the development phase of the student surveys, EPA, in consult with a contractor, 

pretested the survey with 9 children to determine appropriate content and survey completion 

time. The student survey will be administered once in years 1 and 3 (i.e., pre-test for Group A 

and post-test for Group B) and twice in year 2 (i.e., post-test from Group A and pre-test for 

Group B). Each survey will take approximately 10 minutes to complete, for an annual per 

student burden of 10 minutes. 

Annual estimated respondent burden: 

Annual Respondent Burden- Surveys

Survey Group Hour Burden

Student 0.17

Educator – No student survey 0.33

Educator – Yes student survey 0.5

Teacher Interviews: Some selected teachers will both complete the online teacher survey

(estimated at 20 minutes, as discussed above), as well as participate in a 30 minute interview 

with EPA and/or a contractor, for a total annual per teacher burden of 50 minutes.

Annual estimated respondent burden: 

Annual Respondent Burden- Interviews/Surveys

Survey Group Hour Burden

Educator 0.83

Don’t Fry Day Pledge: Educators will be invited to take the Don’t Fry Day pledge at any time 

throughout the year. The pledge can be completed online and requires participants to fill out their 

name, address, school, and commitment to sun protection. The total respondent burden is 

estimated to be 5 minutes per year.

Annual estimated respondent burden: 

Annual Respondent Burden- Pledge

Survey Group Hour Burden

Educator 0.08
17

Certification Tutorial: Users will be asked a series of questions about sun protection to 

determine their demographics (no personal identifiers will be captured), knowledge, attitudes, 

behavior, perception of others they work with, and the environmental conditions in the place 

where they work. They will also be asked to enter their first and last names so it can be put into a 

certificate that they can print. This information will not be saved by EPA. The total respondent 

burden is estimated to be 7 minutes.

Annual estimated respondent burden: 

Annual Respondent Burden –Tutorial/Certificate Questions

Survey Group Hour Burden

Student 0.12

Outdoor Educator 0.12

Partner Survey Pretesting: To pretest a new survey for SunWise non-school partners, some 

selected partners will complete the survey (estimated at 20 minutes, based on the survey’s 

similarity to the teacher survey described above), as well as participate in a 30 minute interview 

with EPA and/or a contractor to discuss the survey and ways to improve it. The total respondent 

burden is thus estimated at 50 minutes.

Annual estimated respondent burden: 

Annual Respondent Burden- Partner Survey

Survey Group Hour Burden

Non-school Partner 0.83

6(b) Estimating Respondents Costs

The Bureau of Labor Statistics figures1 were used to determine labor costs for these tables. In 

order to account for benefits and overhead, the average hourly wage rate of $36.45 for a teacher 

and $12.04 for a recreation worker (i.e., outdoor educator) were increased by 110% for a labor 

cost of $76.55 per hour for teachers and $25.28 per hour for outdoor educators. 

For partners, the average of the average hourly wage of $23.59 for a health educator and $13.20 

for a preschool teacher was calculated to determine the hourly labor cost, since these occupations 

are considered typical of SunWise’s non-school partners. This averaged hourly labor cost of 

$18.40 was increased by 110% for a labor cost of $38.63 per hour for partners to account for 

benefits and overhead.

 

1

http://www.bls.gov/oes/2009/may/oes_nat.htm and http://stats.bls.gov/news.release/ecec.t02.htm
18

Annual Respondent Burden and Cost- Registration

Registrant Group # of responses per 

participant

Hour 

Burden

Labor Cost

Educator 1 0.17 1 * 0.17 * $76.55 = $13.01

Annual Respondent Burden and Cost – Teacher and Student Surveys

Survey Group # of responses per 

participant

Hour 

Burden

Labor Cost

Student 1 0.17 1 * 0.17 * $0 = 0

Educator – No 

student survey

1 0.33 1 * 0.33 * $76.55 = $25.26

Educator – Yes 

student survey

1 0.5 1 * 0.5 * $76.55 = $38.27

Annual Respondent Burden and Cost – Teacher Interviews/Surveys

Survey Group # of responses per 

participant

Hour 

Burden

Labor Cost

Educator 1 0.83 1 * 0.83 * $76.55 = $63.79

Annual Respondent Burden and Cost – Don’t Fry Day Pledge

Survey Group # of responses per 

participant

Hour 

Burden

Labor Cost

Educator 1 0.08 1 * 0.08 * $76.55 = $6.38

Annual Respondent Burden and Cost – Tutorial/Certificate Questions

Survey Group # of responses per 

participant

Hour 

Burden

Labor Cost

Student 1 0.12 1 * (0.12 * 0) = 0

Outdoor Educator 1 0.12 1 * 0.12 * $25.28 = $3.03
19

Annual Respondent Burden and Cost – Partner Survey Pretesting

Survey Group # of responses per 

participant

Hour 

Burden

Labor Cost

Non-school Partner 1 0.83 1 * 0.83 * $38.63 = $32.19

The respondents will have no capital/startup or O&M costs.

6(c) Estimating Agency Burden and Cost

Registration: Registration information collection is done primarily through a website database 

feature. The start-up cost associated with designing the registration web page was approximately

$25,000, but that money has already been spent prior to previous ICRs. Maintenance of the 

website is estimated to involve three types of staff: EPA personnel, Grantees through the Senior 

Environmental Employee (SEE) Program, and contractor staff costing $130 per hour. The EPA 

employees will take 4 hours/month or 48 hours per year. The cost of this labor is calculated 

based on a GS 13 Step 1 pay level living in Washington, DC ($68.26/hour using the salary

associated with this grade and step, multiplied by a benefits factor of 1.6), making the total 

annual cost $3,276.29. The contractor will spend 240 hours per year on the maintenance and 

enhancement of the registration and tracking system at an annual cost of $31,200. 

Finally, EPA will manually input all information received via hard-copy registration form onto 

the database. The costs of this labor are estimated to be 2000 hours per year at a SEE Program 

pay level of $40,000 annually. 

Agency Burden and Costs - Registration

Burden Hours Total Costs ($)

EPA (Annual) 2,288 $74,476.29 

EPA (3-Year ICR) 6,864 $223,428.86 

Teacher and Student Surveys: The contractor assists EPA in data collection and analysis. The 

contractor also provided technical support in the development of the surveys. To perform these 

functions, EPA will contract for a total of 150 professional hours per year. At an average rate of 

$130.00 per hour, the total cost for the contractor is about $19,500 annually. Agency burden to 

manage this contract is estimated at 4 hours/month or 48 hours annually. The cost of this labor 

will be calculated based on a GS 13 Step 1 pay level ($68.26/hour using the salary associated 

with this grade and step, multiplied by a benefits factor of 1.6). Total hours (48) amounts to a 

total agency labor cost of $3,276.29/per annum.

Agency Burden and Costs- Teacher and Student Surveying

Burden Hours Total Costs ($)

EPA (Annual) 198 $22,776.29 
20

Agency Burden and Costs- Teacher and Student Surveying

EPA (3-Year ICR) 594 $68,328.86 

Teacher Interviews: The contractor assists EPA in data collection and analysis. The contractor 

also provides technical support in the development and deployment of the surveys and interview 

questions. To perform these functions, EPA will contract for a total of 150 professional hours 

per year. At an average rate of $130.00 per hour, the total cost for the contractor is about 

$19,500 annually. Agency burden to manage this contract is estimated at 4 hours/month or 48 

hours annually. Agency burden associated with the coordination and participation in interviews 

is estimated at 50 hours per year. The cost of this labor will be calculated based on a GS 13 Step 

1 pay level ($68.26/hour using the salary associated with this grade and step, multiplied by a 

benefits factor of 1.6). Total hours (98) amounts to a total agency labor cost of $6,689.09/per 

annum.

Agency Burden and Costs- Teacher Interviewing/Surveying

Burden Hours Total Costs ($)

EPA (Annual) 248 $26,189.09 

EPA (3-Year ICR) 744 $78,567.26 

Don’t Fry Day Pledge: To perform the data collection and analysis function, agency burden is 

estimated at 2 hours/month or 24 hours annually. The cost of this labor will be calculated based 

on a GS 13 Step 1 pay level ($68.26/hour using the salary associated with this grade and step, 

multiplied by a benefits factor of 1.6). Total hours (24) amounts to a total agency labor cost of 

$1,638/per annum.

Agency Burden and Costs- Don’t Fry Day Pledge

Burden Hours Total Costs ($)

EPA (Annual) 24 $1,638.14 

EPA (3-Year ICR) 72 $4,914.43 

Certification Tutorial: The contractor will maintain the tutorial, including the data collection 

component. The contractor will also analyze the data every other year (i.e., during year 1 and 

year 3 of the ICR). To perform this task, EPA has contracted for a total of 200 professional

hours, 100 hours for each year of analysis. In addition, EPA has contracted a total of 12 hours 

each year for maintenance. At an average rate of $130.00 per hour, the total cost for the 

contractor is $13,000 per year for data collection in year 1 and 3, and $1,560 per year for 

maintenance. Agency burden to manage this contract is estimated at 4 hours/month or 48 hours 

annually. The cost of this labor will be calculated based on a GS 13 Step 1 pay level 

($68.26/hour using the salary associated with this grade and step, multiplied by a benefits factor 

of 1.6).
21

 Agency Burden and Costs – Tutorial/Certification

Burden Hours Total Costs ($)

EPA (Annual) – Year 1 and 3 160 $17,836.29 

EPA (Annual) - Years 2 60 $4,836.29 

EPA (3-Year ICR) 380 $40,508.86

Partner Survey Pretesting: The contractor will assist EPA in the development and deployment 

of the partner surveys and interviews in the pretesting process. To perform these functions, EPA 

will contract for a total of 90 professional hours in year 3. At an average rate of $130.00 per 

hour, the total cost for the contractor is about $11,700. Agency burden to manage this contract is 

estimated at 2 hours/month or 24 hours in year 3. Agency burden associated with the 

coordination and participation in pretesting interviews is estimated at 30 hours in year 3. The 

cost of this labor will be calculated based on a GS 13 Step 1 pay level ($68.26/hour using the 

salary associated with this grade and step, multiplied by a benefits factor of 1.6). Total hours 

(54) amounts to a total agency labor cost of $3,685.82 in year 3.

Agency Burden and Costs- Partner Survey

Burden Hours Total Costs ($)

EPA (Annual) – Year 3 144 $15,385.82 

EPA (3-Year ICR) 144 $15,385.82 

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

Registration

(A)

Number to register

(B)

Total Hours

(C)

Rate per hour ($)

(D)

# of 

responses

(E)

Total Cost

E=B*C

3,500 Educators 595 $76.55 3,500 $45,544.28 

Total (Annual) 595 3,500 $45,544.28 

ICR Total (3 years) 1,785 10,500 $136,632.83 

Student and Teacher Surveys

(A)

Number to be 

surveyed

(B)

Total Hours

(C)

Rate per hour ($)

(D)

# of 

responses

(E)

Total Cost

E=B*C
22

(A)

Number to be 

surveyed

(B)

Total Hours

(C)

Rate per hour ($)

(D)

# of 

responses

(E)

Total Cost

E=B*C

1,000 Students per 

year

170 $0.00 1,000 $0.00 

1,000 Educators –

No student survey

333 $76.55 1,000 $25,515.00 

300 Educators –

Yes student survey

150 $76.55 300 $11,481.75 

Average Total 

(Annual) 

653 2300 $36,996.75 

ICR Total (3 years) 1,960 6,900 $110,990.25 

Teacher Interviews and Surveys

(A)

Number to register

(B)

Total Hours

(C)

Rate per hour ($)

(D)

# of 

responses

(E)

Total Cost

E=B*C

50 Educators 42 $76.55 50 $3,189.38 

Total (Annual) 42 50 $3,189.38 

ICR Total (3 years) 125 150 $9,568.13 

Don’t Fry Day Pledge

(A)

Number to register

(B)

Total Hours

(C)

Rate per hour ($)

(D)

# of 

responses

(E)

Total Cost

E=B*C

1,500 Educators 125 $76.55 1500 $9,568.13 

Total (Annual) 125 1500 $9,568.13

ICR Total (3 years) 375 4,500 $28,704.38 

Tutorial/Certificate

(A)

Number to be 

surveyed

(B)

Total Hours

(C)

Rate per hour ($)

(D)

# of 

responses

(E)

Total Cost

E=B*C

100 Students per 

year

12 $0.00 100 $0.00 
23

(A)

Number to be 

surveyed

(B)

Total Hours

(C)

Rate per hour ($)

(D)

# of 

responses

(E)

Total Cost

E=B*C

1,500 Outdoor 

Educators 

180 $25.28 1,500 $4,551.12 

Average Total 

(Annual) 

192 1,600 $4,551.12

ICR Total (3 years) 576 4,800 $13,653.36 

Partner Surveys

(A)

Number to register

(B)

Total Hours

(C)

Rate per hour ($)

(D)

# of 

responses

(E)

Total Cost

E=B*C

30 Partners 25 $38.63 30 $965.74 

Total (Annual) -

Year 3 

25 30 $965.74 

ICR Total (3 years) 25 30 $965.74 

Total

ICR TotalRegistration + 

Surveys + Tutorial 

+ Interviews + 

Pledge (average 

annual)* 

1,615 8,960 $100,171.56

ICR TotalRegistration + 

Surveys + Tutorial 

+ Interviews + 

Pledge (3 years) 

4,846 26,880 $300,514.67

*Represents average annual cost, however not all activities will occur during all three years of the ICR, as described 

above.

6(e) Bottom Line Burden Hours and Cost Tables

Bottom Line Burden and Costs (3-Year ICR)

Burden Hours Total Costs ($)

Students 546 $0.00
24

Bottom Line Burden and Costs (3-Year ICR)

Educators 3,735 $285,895.58

Outdoor Educators 540 $13,653.36

Non-school Partners 25 $965.74

EPA 8,798 $431,134.11

Subtotal (respondents) 4,846 $300,514.67

Subtotal (government) 8,798 $431,134.11

Total 13,644 $731,648.78

Bottom Line Burden and Costs (Average Annual)*

Burden Hours Total Costs ($)

Students 182 0

Educators 1245 $95,298.53

Outdoor Educators 180 $4,551.12

Partners 8 $321.91

EPA 2933 $143,711.37

Subtotal (respondents) 1,615 $100,171.56

Subtotal (government) 2,933 $143,711.37

Total 4,548 $248,899.93

*Represents average annual cost, however not all activities will occur during all three years of the ICR, as described 

above.

6(f) Reasons for Change in Burden

There is a decrease of 195 hours annually in the total estimated burden currently identified in the 

OMB Inventory of Approved ICR Burdens. More hours were added for teachers participating in 

an individual interview. Hours were subtracted for teachers administering the student survey. 

Hours were added for teachers participating in the Don’t Fry Day pledge. Hours and burden for 

educators is about the same; hours for students has also decreased significantly.

6(g) Burden Statement

The annual public reporting and record keeping burden for this collection of information is 

estimated to average 10 minutes per response for the registration, 10 minutes per response for the 

student survey, 20 minutes per response for the educator survey without the student survey, 30 

minutes per response for the educator survey with the student survey, 50 minutes per response 
25

for the teacher interview with survey, 5 minutes per response for the Don’t Fry Day pledge, 7 

minutes per response for the certification tutorial program, and 50 minutes per response for 

pretesting the partner survey. Burden means the total time, effort, or financial resources 

expended by persons to generate, maintain, retain, disclose, or provide information to or for a 

Federal agency. This includes the time needed to review instructions; develop, acquire, install, 

and utilize technology and systems for the purposes of collecting, validating, and verifying 

information; processing and maintaining information, and disclosing and providing information; 

adjust the existing ways to comply with any previously applicable instructions and requirements; 

train personnel to be able to respond to a collection of information; search data sources; complete 

and review the collection of information; and transmit or otherwise disclose the information. An 

agency may not conduct or sponsor, and a person is not required to respond to, a collection of 

information unless it displays a currently valid OMB control number. The OMB control 

numbers for EPA’s regulations are listed in 40 CFR Part 9 and 48 CFR Chapter 15.

To comment on the Agency's need for this information, the accuracy of the provided burden 

estimates, and any suggested methods for minimizing respondent burden, including the use of 

automated collection techniques, EPA has established a public docket for this ICR under Docket 

ID Number EPA-HQ-OAR-2007-0069, which is available for online viewing at 

www.regulations.gov, or in person viewing at the Air and Radiation Docker in the EPA Docket 

Center (EPA/DC), EPA West, Room 3334, 1301 Constitution Avenue, NW, Washington, D.C. 

The EPA Docket Center Public Reading Room is open from 8:30 a.m. to 4:30 p.m., Monday

through Friday, excluding legal holidays. The telephone number for the Reading Room is (202) 

566-1744, and the telephone number for the Air and Radiation Docket is (202) 566-1742. An 

electronic version of the public docket is available at www.regulations.gov. This site can be 

used to submit or view public comments, access the index listing of the contents of the public 

docket, and to access those documents in the public docket that are available electronically. 

When in the system, select “search,” then key in the Docket ID Number identified above. Also, 

you can send comments to the Office of Information and Regulatory Affairs, Office of

Management and Budget, 725 17th Street, NW, Washington, D.C. 20503, Attention: Desk 

Officer for EPA. Please include the EPA Docket ID Number EPA-HQ-OAR-2007-0069 and 

OMB Control Number 2060-0439 in any correspondence.