1 **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: EPA’s Design for the Environment (DfE) Formulator Product Recognition**  **Program EPA ICR No.**  **: 2302.02**  **OMB Control No. :**  **2070 -**  **0178 1(b)**  **Short Characterization** This renewal information collection request (I CR) addresses the submission of applications to EPA for recognition under the Formulator Product Recogniti on Program (Formulator Program). DfE’s 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 alread y made great progress in developing safer, highl y 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 enjo y Agency recognition, including the use of the DfE label on products with the safest possible formulations. This ICR would enable DfE to accommodate participation by more than nine formulators each ye ar, enhance program transparency , and further promote chemical safet y. DfE participates in the development of CleanGredientsTM, 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.), CleanGredientsTM facilitates a green marketplace where formulators can select functionally app ropriate and safer ingredients. The redesign of chemi cal products offers opportunities to:
 Remove hazardous chemicals from formulations before they can enter the w orkplace, home, or environment.
 Advance energy

and water efficiency , resource conservatio n, and innovative technologies.
 Qualify

for environmentally

preferred product status, increasingl y sought by government, re tailer and consumer purchasers. Companies formulate products from a broad range of chemicals with a variety of applications. The Formulator Program is particularl y involved wi th safer cleaning products, holding tank treatments/deodorizers, industrial coatings, and inks. Cleaning products make up the majorit y of partnership products, and cleaning product manufacturers make up the lion’s share of demand for program participation by

potential partners. Third

- part y profilers review all cleaning product applications prior to DfE submission. All other product applications are submitt ed directly to DfE for review. The review team carefully reviews each product component. A literat ure review, and when appropriate, structural activity relationships, are used to understand each chemical’s health and2

environmental characteristics. The review includes all chemicals, including those in proprietary raw material blends, which ingredient su ppliers 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 s ynergies between ingredients, and places the ingredient on a continuum of improv ement relative to other similar chemicals. By means of 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 safet y in technological innovation in chemistry. In recognition of this statutory

directive, and through consultation with a broad range of stakeholders, EPA dev eloped 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. I n turn, the Formulator Program will help businesses meet corporate sustainability

goals by providing the means to, and an objective measure of, e nvironmental stewardship. Investment anal ys ts and advisers seek these ty pes of measures in evaluating a corporation’s sustainability profile and investment worthiness. 1 It is not surprising then that EPA has heard from man y organizations that Formulator P rogram 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 ch ange. DfE has carefully

tailored its request for information, and especially the Formulator Program application forms, to ensure that it only asks for information essential to verify ing 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 to: (1) review 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 compan y outlining how the compan y and EPA/DfE will wo rk together to continually

improve the health and environmen tal profile of the product(s).

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, 20063

**3. NON -**  **DUPLICATION, CONSULTATIONS, AND OTHER COLLECTION CRITERIA 3(a)**  **Non -**  **Duplication** Respondents will not be asked to provide informa tion that has been or is currentl y being collected b y 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 di ligence, 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 I CR will be made available to the public for comment through a Federal Register notice. The public will have 60 day s to provide comments. Any comments received will be given consideration when completing the supporting s tatement that is submitted to OMB. **3(c) Consultations**  Under 5 CFR 1320.8(d)(1) OMB requires agencies to consult with potential I CR respondents and data users about specific aspects of IC Rs before submitting an original or renewal I CR to 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 Collect**  **ion** Formulator Program applications will be received on an ongoing basis over the t hree ye ars covered b y this ICR. The applications are designed to be one

- time information submissions for organizations that wish to participate in the Formulator Program, with the opportunity to renew the partnership agreement at the end of the three

- ye ar partnership period. This means that once every three y ears, the organization will submit a renewal application to confirm that no changes have been made to ingredients; t his step is done in response to correspondence from DfE that reminds organizations of the terms of their partnership agreements. Without this information collection mechanism, DfE will not have the abilit y to assist formulators in developing safer, highl y 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 compl y with all regulatory guidel ines 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 solel y for4

purposes related to forming the partnership and discloses th e information only to EPA employ ees 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

us e, for

- sale chemical products. Below is a list of representative North American Industry Classification S ystem (NAICS) codes and associated industries that may be affected b y i nformation collection requirements covered under this I CR. This list is intended to be illustrative; entities from other industries may elect to appl y for recognition through the Formulator Program. However, EPA expects that most applications will come from the following industries: NAI CS Code Affected Industry 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 Man ufacturing **4(b) Information Requested**  Once a compan y 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 submi t the appropriate application. (i) Data items : Applicants for this voluntary program submit information items that vary depending upon the class of product. The items include: **Partnership Applications for Cleaning and Non -**  **Cleaning Products** Cleaning product manufacturers will submit ingredient inf ormation, as described here, to a qualified third

- part y pro filer before submittal to EPA. In formation submitted to third

- part y profilers:  Com pany

name and Web site URL  Number of emplo ye es5

 Company

headquarters ad dress and manufacturing address  Name, title, phone number, and e

- mail address of the candidate’s signatory contact person (e.g., CEO, or vice president for health and environment)  Name, title, phone number, and e

- mail address of candidate’s technical contact person  Name, title, phone number, and e

- m ail address of candidate’s ma rketing/outreach contact person  Product information (name, UPC, sector, production volume, pH, product form )  Product characteristics on whether or not the product is: o An EPA registered pesticide o A direct release product o A conce ntrate o Contains enzy

mes, fragrance, or VOCs o Requires hazard labeling o In gredient disclosure and performance data submitted  Packaging information: o Percent sourced, manufactured, transported, and recy cled using renewable energy o Percent optimizing the use of renewab le or recy cled source materials o Percent manufactured using clean production technologies and best practices o Percent made from materials healthful in all probably end

- of

- life scenarios o Percent ph ys icall y designed to op timize materials and energy use o Percent recovered and used in biological o r industrial closed

- loop cy cles o Packing material t ype and percent recycled content o If the packaging contains heav y metals, BPA, or phthalates  Description of all chemical ingredients in product: o CAS number o Chemical name o Trade name o Percent composition o In gredient class o Supplier name  Raw material information (EPA Form XXXX

- X) (see Attachment C)  Other product information, including product packaging description, product flashpoint, an d flushability

/ compostability  An MSDS for the product and each ingredient  Product performance testing (an y m ethod of demonstrating product performance is acceptable as long as it is a co mmonly used industry

standard)  If available, an y supplemental product or ingredient environmental he alth and safet y information., such as: o Biodegradation tests on individual ingredients o Acute aquatic toxicity tests on product as a whole or individual ingredients o Human health and safet y tests  Description of the t ype of training the compan y provides to cus tomers on environmental and worker safety

matters. In formation submitted to EPA:  Summary report, containing same data items as above6

**Adding Third -**  **Party Partners and Products** Cleaning product manufacturers will submit information about third

- part y addit ions to DfE. To be label

- eligible, third

- party products must contain ingredients identical to those in an already DfE

recognized product. The three t ypes of third

- part y partners and products are private labels, licensees, and toll manufacturers. In format ion submitted to EPA:  DfE Form for Adding Third

- Party Partners and Products (Private Label Companies, Licensees, or Toll Manufacturers) (EPA Form XXXX

- X) (See Attachment D) (ii) Respondent activities : **Applicants for Cleaning and Non -**  **Cleaning Product Formulation Partnerships**   Review program information, including instructions on submitting information to third

party profi lers  Submit information described in section 4(b)(i) of this supporting statement to third

- party profiler  Establish agreement with thi rd

- part y profiler  Submit summary

report to DfE  Negotiate / establish Partnership Agreement with DfE  Renew partnership, with no changes needed  Site audit (See Attachment E) **Adding Third -**  **Party Partners and Products**  Review program information  Fill out and su

bmit DfE Form for Adding Third

- Party Partners and Products (Private Label Companies, L icensees, or Toll Manufacturers)
**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 applications to third

- part y profilers for distrib ution to potential participants;  Answer questions posed by potential applicants regarding recognition under the Program;  Receive the completed applications, review for accuracy, and plac e an y necessary follow

- up calls;  Apply EPA’s chemical tools and expertise to understand toxicological characte ristics 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.7

**5(b) Collection Methodology and Management**  Cleaning and non

- cleaning product manufacturers may obtain applications for providing ingredient information for the chemical summaries that will be developed by third

- part y profilers by downloading them directly from the web site of the third

- part y profilers. The completed applications can be faxed, mailed, or, if they do not contain CBI or t rade s ecret information, they can be scanned and emailed to EPA. In collecting and anal yz ing the information associated with th is I CR, EPA will use a telephone sy stem, 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 wil l 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 applicati on for recognition at an y time.
**6. ESTIMATING THE BURDEN AND COST OF TH**  **E COLLECTION 6(a)**  **Estimating Respondent Burden** The average respondent burden is estimated to be 25.5 hours for cleaning and non

- cleaning product formulators and 9.5 hours for cleaning product formulators wishing to add third

- part y partners and products (see Exhibit 6.2). 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 t ypical cleaning or non

- cleaning product formulator, program and application review will take about 2 hours (1 managerial, 1 technical). Filling out and submitting third

- part y profiler information request forms will take about 7.5 hours (6 technical, 1.5 clerical), and then establishing an agreement with the third

- par ty profiler 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). Finall y, establishing a Partnership Agreement DfE will take 3 hour s (1 managerial, 2 tech nical). For a t ypical addition of a third

- part y partner and products, program and application review will take about 2 hours (1 managerial, 1 technical). Filling out and submitting one DfE Form for Adding Third

- Part y Partners and Products (Private Label C ompanies, Licensees, or Toll Manufacturers) is estimated to take about 2.5 hours (2 technical, 0.5 clerical). On average, a partner8

will fill out 3 third

- party

partners and products forms annually . Therefore, it is estimated that it will take one responden t 7.5 hours (6 technical, 1.5 clerical) to add third

- part y partners and products. In addition to the burden associated with first

- time submission of applications, each formulator has the opportunity

to renew its Partnership Agreement at the end of the thr ee - ye ar partnership period. This means that once every three y ears, 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 th e partnership renewal process will take 5 hours (4 technical, 1 clerical) for cleaning and n on - cleaning product formulators. For purposes of this I CR, EPA expects that 96 (see Section 6(e) on estimating the respondent universe) cleaning and non

- cleaning p roduct formulators will choose to renew their partnerships. Furthermore, EPA anticipates that one in ten cleaning and non

- cleaning product formulators over the three

- ye ar period of this ICR 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 sam e as first

- time submission. For purposes of estimating annual cost and burden in Exhibit 6.2, it is assumed that one

- third of the 96 formulators (or 29 cleaning product and 3 non

- cleaning product formulators) over the three

- year period of this I CR will re new their partnership agreements each ye ar. It is also assumed that over the three

ye ar period of this I CR, one in ten formulators (or 3 cleaning product and 1 non

- cleaning product formulators) will need to go through a new partnership approval process, w hich on an annual basis translates into two formulators per ye ar (1 cleaning product and 1 non

- cleaning product formulator). As part of the application process, the third

- part y profiler will also reserve the right to visit site facilities to verify

that e ach partnership product contains the same ingredients, in the same volumes, that are reported b y the company as part of the DfE recognition process. The site auditor will review batch tickets associated with each recognized product to ensure that ingredie nt claims are accurate. For purposes of estimating annual cost and burden in Exhibit 6.2, it is assumed that about 33% of formulators will get audited each year over the three

- ye ar period of this I CR (i.e., 10 cleaning product and 1 non

- cleaning product f ormulators). Each audit is estimated to require two hours of a technical person’s time and one hour of a clerical person’s time. Additional information about the audit process can be found in Attachment E of this I CR. **6(b) Estimating Respondent Costs**  EP A estimates an average loaded hourl y labor rate (base hourly rate plus fringe and overhead) of $71 for managerial staff, $65 for technical staff, and $30 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 March 2012. The hourl y labor rates include a 17% overhead; this overhead rate is used for consistency with OPPT economic anal ys es for two major rulemakings: Wage Rates for Economic Analyses of the Toxics Release Inventory Program 2 and the Revised Ec onomic Analysis for the Amended Inventory Update Rule: Final Report

. 3 In addition, the hourly labor rates have been rounded for the purposes of this ICR. The

2 EPA, 2002b. U.S. EPA, Office of Pollution Prevention and Toxics, Economic and Policy Analysis Branch, Wage Rates for Economic Analysis of the Toxics Release Inventory Program. Washington, DC: June 10, 2002. 3 EPA, 2002

. U.S. EPA , Office of Pollution Prevention and Toxics, Economic and Policy Analysis Branch. Revised Economic Analysis for the Amended Inventory Update Rule: Final Report. Washington, DC. August 2002.9

ty pe of staff needed to complete the Formulator’s applications and their associated hourl y labor rates were verified b y contacting representatives from the participant categories. The derivation of labor rates for managerial, technical and clerical staff is shown in Exhibit 6.1. **Exhibit 6.1. Derivation of Loaded Wage Rates in 2012$**  **Labor category**  **Wage Fringe**  **Benefit Fringes as** 

**% wage Overhead** 

**% wage Fringe +** 

**overhead factor**  **Loaded**

**Wages Loaded** 

**Wages (rounded)**  **(a) (b)**  **(c)=(b)/(a) (d)**  **(e)=(c)+(d)+1 (f)=(a)**   **(e) Managerial**  4 $ 43.21 $ 20.53 47.51 % 17% 1.65 $ 71.09 $ 71 .00 **Professional/ Technical**  **2** $ 38.71 $ 19.71 50.92 % 17% 1.6 8 $ 65.00 $ 6 5.00 **Clerical 2**  $ 17.87 $ 9.03 50.53 % 17% 1.6 8 $ 29.94 $ 30 .00 E xhibit 6.2 show s the breakdown of burden costs, assuming 25.5 hours for cleaning and non

cleaning product manufacturers and 9.5 hours for cleaning product formulators wishing to add third

party partners and products. The third

- part y profiler verification process for cleaning products also adds an operating and management (O&M) cost of about $12,400 per company per application. This cost estimate is from NSF International, which has experience as a third

- party profiler of ingredient characteristics. For this ICR, it is assumed that ty pical cleaning and non

- cleaning product manufacturers will submit four products in an application. Each product is assumed to contain 2 ingredients at $650 each, 1 proprietary ingredient at $1,300 each, and 3 CleanGredients TM ingredient a t no charge, for a total of $2,600 per product. In addition, a $500 administrative fee per product is assumed. The total will be $12,400 per compan y per application. No additional capital or O&M costs are incurred b y respondents under this I CR.

4 Bureau of Labor Statistics (BLS) Employer Costs for Employee Compensation, Supplementary Tables. From Supplementary Table 2, Employer costs per hour w orked for employee compensation and costs as a percent of total compensation: Private industry w orkers in manufacturing industries, by occ upational group, establishment size and bargaining status, March 2012

. A vailable at: http://www.bls.gov/ncs/ect/sp/ecsuptc22.pdf10

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

**Collection activity Hours and Costs Per Respondent**  **Total Hours and Costs Mgr.**  **Tech. Cler.**  **Response Hours/Yr**  **Labor**

**Cost/Year Capital**  **O & M Cost** * **Number of**

**Respon.  ** Total**

**Hours/Yr Total** 

**Cost/Yr $71/Hr**  **$65/Hr $30/Hr**  **Cost Cleaning and Non**  **- Cleaning Products**  Review program information 1.0 1.0

- 2.0 $136 $0 $0 34 68 $4,624 Fill out and submit third

- party information request form

- 6.0 1.5 7.5 $435 $0 $0 34 255 $14,790 Establish agreement with third

- party profiler 1.0 1.0 1.0 3.0 $166 $0 $12,400 34 102 $427,244 Submit summary report to DfE 1.0 1.0

- 2.0 $136 $0 $0 34 68 $4,624 Negotiate / establish Partnership Agreement with DfE 1.0 2.0

- 3.0 $201 $0 $0 34 102 $6,834 Renew partnership, with no changes needed

- 4.0 1.0 5.0 $290 $0 $0 32 160 $9,280 Site audit

- 2.0 1.0 3.0 $160 $0 $0 11 33 $1,760 Subtotal 4.0 17.0 4.5 25.5 $1,524 $0 $12,400 32 788 $469,156 **Adding Third -**  **Party Partners and Products** Review program information 1.0 1.0

- 2.0 $136 $0 $0 34 68 $4,624 Fill out and submit DfE Form for Adding Third

- Party Partners and Products

- 6.0 1.5 7.5 $435 $0 $0 34 255 $14,790 Subtotal 1.0 7.0 1.5 9.5 $571 $0 $0 34 323 $19,414 **TOTAL 66**  **1,111 $488,570**  * The cos t for third

- party profiler review and verification assumes that the typical application submitted by a cleaning product manufacturer will contain four p roducts. Each product will contain 2 ingredients at $ 650 each and 1 proprietary ingredient at $ 1,300 , f or a total of $ 2,600 per product. Also assumes a $ 500 administrative fee per product

. The total cost per product is $3,100. The total will be $ 12,400 per company per application. **This column reports the number of annual respondents after accounting for the partnership renewal process and site audits . Assumes that one in ten formulators over the three

- ye ar period will need to make changes to their formulations and go through a new partnership process which includes same collectio n steps. On an annual basis, this translates to 1 of 29 cleaning product formulators (for a total of 30) and 1 of 3 non

- cleaning product formulators (for a total of 4). Also assumes that about 33% of cleaning product formulators (i.e., 10) and non

- cleaning produc t formulators (i.e., 1) will be subject to site audits each year. See Section 6(a) for additional explanation. Assumes that 34 partners will submit applications to add third

- party partners and products based on historical data. See Section 6(e) for additio nal explanation.11

**6(c) Estimating Agency Burden**  Exhibit 6.3 presents the estimated Agency burden hours and costs associated with the information collection activities under this I CR. EPA based its burden estimates on its experience m anaging other voluntary programs. EPA expects that review of the program application forms for a t ypical cleaning or non

cleaning product formulator will take about 1 hour (1 technical). Reviewing the third

- part y profiler information summary report will take about 10.5 hours (10.5 technical). Establishing a Partnership Agreement with the formulator will take about 6 hours (2 managerial, 4 technical). Reviewing the partnership renewal and assuming that no changes are needed is estimated at 2 hours (1 manag erial, 1 technical). The burden for reviewing the DfE Form for adding third

- part y partners and products is estimated to take about 3 hours (3 tech nical). **6(d) Estimating Agency Costs**  Agency labor costs are calculated based on hourly basic rates for federal employ ees in the Washington

- Baltimore area published b y the Office of Personnel Management effective January 2012 5 . The average hourly labor rate for managerial staff is estimated as the rate for a GS

- 13 Step 5 employ ee, for technical staff as a G S

- 10 Step 10 employ ee, and for clerical staff as GS

- 5 Step 1. These GS

- level assumptions are consistent with those used in past EPA OPPT ICRs. The hourl y rates were multiplied by an assumed loading factor of 1.6 to reflect Federal fringe benefits and ove rhead. 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 $77 for managerial staff, $57 for technical staff, and $26 for clerical staff. The Agency expects most activities related to this I CR to be performed by managerial staff (25 percent) and technical staff (75 percen t).

5 OPM, 2012. Salary Table 2012

- DCB , Washington Baltimore Northern Virginia, DC

- MD

- PA

- VA

- WV

. Available at http://www.opm.gov/oca/12tables/pdf/dcb_h.pdf12 **Exhibit 6.3. Annual Agency Burden/Cost** 

**Collection activity Hours and Costs Per Respondent**  **Total Hours and Costs Mgr.**  **$77/Hr Technical** 

**$57/Hr Agency** 

**Hours/Yr Labor** 

**Cost/Year Capital/** 

**Startup Cost O & M** 

**Cost Number of** 

**Respon.*** **Total**

**Hours/Yr Total** 

**Cost/Yr Cleaning and Non**  **- Cleaning Products**  Review program application forms

- 1.0 1.0 $57 $0 $0 34 34 $1,938 Review third

- party profiler summary

- 10.5 10.5 $599 $0 $0 34 357 $20,349 Negotiate / establish Partnership Agreement with formulator 2.0 4.0 6.0 $382 $0 $0 34 204 $12,988 Review partnership renewal, with no changes needed 1.0 1.0 2.0 $134 $0 $0 32 64 $4,288 Subtotal 3.0 16.5 19.5 $1,172 $0 $0 32 659 $39,563 **Adding Third -**  **Party Partners and Products** Review DfE Form for Adding Third

Party Partners and Products

- 3.0 3.0 $171 $0 $0 34 102 $5,814 Subtotal

- 3.0 3.0 $171 $0 $0 34 102 $5,814 **TOTAL 66**  **761 $45,377**  * This column reports the number of respondents after accounting for the partnership renewal process. Assu me s 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). Assumes that 34 partners will submit applications to add third

- party partners and products based on historical data.13

**6(e) Estimating the Respondent Universe and Total Burden and Costs**  EPA estimates that 96 formulators will submit applications over the three

- ye ar life of the clearance. EPA expects the participation will ramp up over the three ye ar period, but for the purposes of estimating annual cost and burden in Exhibit 6.2, it is assumed that 32 cleaning and non - cleaning products formulators will submit applications per y ear. This estimate is based on historical data and the assumption that par ticipation will increase over the next three y ears in response to greater consumer demand for green products. EPA also estimates that of the applications, about 90 percent (or 29 per ye ar) will be cleaning products, with the remainder being non

- cleaning p roducts. The EPA estimates that an additional 34 applications will be received annuall y to add third

- part y partners and products. This estimate is based on the number of partners that submitted third

- part y partners and products applications over the last ye ar and is expected to remain constant over the course of this I CR period. Therefore, it is estimated that a total of 66 respondents will submit applications under the Formulator program each ye ar. The annual burden hours and cost associated with this inf ormation collection are 1,111 hours and $488,570 respectivel y. **6(f) 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 ye ar over the three ye ars covered b y this I CR. **Exhibit 6.4. Total Annual Estimated Respondent Burden and Cost Summary Total # of Respondents**  **Average Burden Hours Annual Cost** 

66 1,111 $ 488,570 b. Agency

Tall y Exhibit 6.5 below summarizes the total annual estimated agency burden and cost. These estimates represent the average burden in an y given y ear over the three y ears covered by this ICR. **Exhibit 6.5. Total Annual Estimated Agency Burden and Cost Su mmary** 

**Burden Hours Annual Cost**  761 $ 45,377 **6(g) Reasons for Change in Burden**  There is a an increase of 420 hours (from 691 hours to 1,111 hours) in the total estimated respondent burden compared with that identified in the I CR currentl y approved by OMB . This increase reflects EPA's estimate of the number of applications the Agency will receive annuall y14

to add third

- part y partners and products. This estimate is based on the historical number of respondent s that submitted third

- part y partners and produ cts applications in the last y ear ; this number is expected to remain constant over the next three y ears . EPA did not consider this factor in the previous I CR submission. **6(h) Burden Statement**  The annual public burden for this collection of information i s estimated to be 25.5 hours per response for formulators of cleaning and non

- cleaning products and 9.5 hours for cleaning product formulators wishing to add third

- part y partners and products, including time for reviewing instructions, gathering informatio n, and completing and reviewing the application. Burden is defined in 5 CFR 1320.3(b). An agency may not conduct or sponsor, and a person is not required to respond to, a collection of information unless it display s a currentl y valid OMB control number. The OMB control number for this information collection appears above. The OMB control n umbers for EPA’s regulations in title 40 of the CFR, after appearing in the Federal Register , are listed in 40 CFR part 9 and included on the related collection instrument or form, if applicable. The Agency

has established a public docket for this I CR und er Docket ID No. EPA

- HQ

OPPT

- 20 12

- 0 675 , which is available for online viewing at www.regulations.gov, or in

- person 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 EP A West Building, Room 3334, 1301 Constitution Ave., N.W., 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 holiday s. 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. You may submit comments regarding the Agency's need for this information, the accuracy of the provided burden estimates and any suggested methods for mi nimizing respondent burden, including the use of automated collection techniques. Submit y our comments, referencing Docket ID No. EPA

- HQ

- OPPT

- 2012

- 0675 and OMB Control No. 2070

- 0178 , to (1) EPA online using www.regulations.gov (our preferred method), or b y mail to: Pollution Prevention and Toxics Docket, Environmental Protection Agency Docket Center (EPA/DC), Mailcode: 28221T, 1200 Pennsy lvania Ave., N.W., Washington, DC 20460, and (2) OMB b y mail to: Office of Information and Regulatory Affairs, Office of Management and Budget (OMB), Attention: Desk Officer for EPA, 725 17th Street, N.W., Washington, DC 20503.