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 (ICR) addresses the submission of applications to 

EPA for recognition under the Formulator Product Recognition 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 already made great progress in developing 

safer, highly effective chemical products. Since the program’s inception in 1997, formulators have 

been using the program as a portal to OPPT’s unique chemical expertise, information resources, and 

guidance on greener chemistry. DfE Formulator partners enjoy Agency recognition, including the use 

of the DfE label on products with the safest possible formulations. This ICR would enable DfE to 

accommodate participation by more than nine formulators each year, enhance program transparency, 

and further promote chemical safety.

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 appropriate and safer ingredients.

The redesign of chemical products offers opportunities to:

 Remove hazardous chemicals from formulations before they can enter the workplace, 

home, or environment.

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

 Qualify for environmentally preferred product status, increasingly sought by government, 

retailer and consumer purchasers.

Companies formulate products from a broad range of chemicals with a variety of applications. 

The Formulator Program is particularly involved with safer cleaning products, holding tank 

treatments/deodorizers, industrial coatings, and inks. Cleaning products make up the majority of 

partnership products, and cleaning product manufacturers make up the lion’s share of demand for 

program participation by potential partners. Third-party profilers review all cleaning product 

applications prior to DfE submission. All other product applications are submitted directly to DfE for 

review.

The review team carefully reviews each product component. A literature review, and when 

appropriate, structural activity relationships, are used to understand each chemical’s health and 
 2

environmental characteristics. The review includes all chemicals, including those in proprietary raw 

material blends, which ingredient suppliers share with DfE in confidentiality. The review team then 

compares an ingredient’s characteristics to other chemicals in the same use class, considers possible 

negative synergies between ingredients, and places the ingredient on a continuum of improvement 

relative to other similar chemicals. 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 safety in technological innovation in chemistry. In recognition 

of this statutory directive, and through consultation with a broad range of stakeholders, EPA developed 

the Formulator Program.

Formulator Program information collection activities will assist the Agency in meeting the 

goals of the PPA by providing resources and recognition for businesses committed to promoting and 

using safer chemical products. In turn, the Formulator Program will help businesses meet corporate 

sustainability goals by providing the means to, and an objective measure of, environmental 

stewardship. Investment analysts and advisers seek these types of measures in evaluating a 

corporation’s sustainability profile and investment worthiness.1 It is not surprising then that EPA has 

heard from many organizations that Formulator Program partnership is an important impetus for 

prioritizing and completing the transition to safer chemical products. The Formulator Program is also 

needed to promote greater use of safer chemical products by companies unaware of the benefits of 

such a change.

DfE has carefully tailored its request for information, and especially the Formulator Program 

application forms, to ensure that it only asks for information essential to verifying applicants’ 

eligibility for recognition.

 

2(b) Practical Utility/Users of the Data

The information collected by the Formulator Program is not designed or intended to support 

regulatory decision-making by EPA. EPA uses the information collected in the Formulator Program 

application 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 company outlining how the company and EPA/DfE will work together 

to continually improve the health and environmental 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, 2006
 3

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

3(a) Non-Duplication

Respondents will not be asked to provide information that has been or is currently being 

collected by EPA, other federal or state agencies, or proprietary sources. The information collected by

the Formulator Program is unique and is not duplicative of previous information collection requests. 

As due diligence, EPA also checked with trade associations and potential partners to confirm that the 

information being collected by the Formulator Program does not exist elsewhere.

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

Prior to submission to OMB, this ICR will be made available to the public for comment 

through a Federal Register notice. The public will have 60 days to provide comments. Any comments 

received will be given consideration when completing the supporting statement that is submitted to 

OMB.

3(c) Consultations

Under 5 CFR 1320.8(d)(1) OMB requires agencies to consult with potential ICR respondents 

and data users about specific aspects of ICRs before submitting an original or renewal ICR 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 Collection

Formulator Program applications will be received on an ongoing basis over the three years 

covered by 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-year partnership period. This means that once every three years, the 

organization will submit a renewal application to confirm that no changes have been made to 

ingredients; this step is done in response to correspondence from DfE that reminds organizations of the 

terms of their partnership agreements. Without this information collection mechanism, DfE will not 

have the ability to assist formulators in developing safer, highly effective chemical products or to 

formally recognize formulators who have successfully done so.

3(e) General Guidelines

The information collection activities discussed in this renewal ICR comply with all regulatory

guidelines under 5 CFR 1320.5(d)(2).

3(f) Confidentiality

Some information collected by EPA under the Formulator Program involves confidential 

business or trade secret information. The Formulator Program handles all information claimed as such 

as confidential business information in accordance with Agency confidentiality procedures (see 40 

CFR part 2, subpart B). The Formulator Program uses information provided by formulators solely for 
 4

purposes related to forming the partnership and discloses the information only to EPA employees and 

EPA contractors cleared for confidential information with a specific need to know.

3(g) Sensitive Questions

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

questions.

4. THE RESPONDENTS AND THE INFORMATION REQUESTED

4(a) Respondents and NAICS Codes

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

Below is a list of representative North American Industry Classification System (NAICS) codes 

and associated industries that may be affected by information collection requirements covered under 

this ICR. This list is intended to be illustrative; entities from other industries may elect to apply for 

recognition through the Formulator Program. However, EPA expects that most applications will come 

from the following industries:

NAICS 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 Manufacturing

4(b) Information Requested

Once a company with an interest in partnership with the Formulator Program reviews the 

program materials and decides to apply, the next step for the organization is to submit the appropriate 

application.

(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 information, as described here, to a 

qualified third-party profiler before submittal to EPA.

Information submitted to third-party profilers:

 Company name and Web site URL

 Number of employees
 5

 Company headquarters address 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-mail address of candidate’s marketing/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 concentrate

o Contains enzymes, fragrance, or VOCs

o Requires hazard labeling

o Ingredient disclosure and performance data submitted

 Packaging information:

o Percent sourced, manufactured, transported, and recycled using renewable energy

o Percent optimizing the use of renewable or recycled 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 physically designed to optimize materials and energy use

o Percent recovered and used in biological or industrial closed-loop cycles

o Packing material type and percent recycled content

o If the packaging contains heavy metals, BPA, or phthalates

 Description of all chemical ingredients in product:

o CAS number

o Chemical name

o Trade name

o Percent composition

o Ingredient class

o Supplier name

 Raw material information (EPA Form XXXX-X) (see Attachment C)

 Other product information, including product packaging description, product flashpoint, 

and flushability / compostability

 An MSDS for the product and each ingredient

 Product performance testing (any method of demonstrating product performance is 

acceptable as long as it is a commonly used industry standard)

 If available, any supplemental product or ingredient environmental health and safety 

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 safety tests

 Description of the type of training the company provides to customers on environmental 

and worker safety matters.

Information submitted to EPA:

 Summary report, containing same data items as above
 6

Adding Third-Party Partners and Products

Cleaning product manufacturers will submit information about third-party additions to DfE. To 

be label-eligible, third-party products must contain ingredients identical to those in an already DfErecognized product. The three types of third-party partners and products are private labels, licensees, 

and toll manufacturers.

Information 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 thirdparty profilers

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

profiler

 Establish agreement with third-party 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 submit DfE Form for Adding Third-Party Partners and Products (Private Label 

Companies, Licensees, 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-party profilers for distribution to potential participants;

 Answer questions posed by potential applicants regarding recognition under the Program;

 Receive the completed applications, review for accuracy, and place any necessary follow-up 

calls;

 Apply EPA’s chemical tools and expertise to understand toxicological characteristics of 

chemical ingredients and to ensure that they are the safest within their functional use class; and

 Approve candidates for recognition and notify both successful and unsuccessful applicants of 

the decisions.
 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-party profilers by 

downloading them directly from the web site of the third-party profilers. The completed applications 

can be faxed, mailed, or, if they do not contain CBI or trade secret information, they can be scanned 

and emailed to EPA.

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

system, personal computers, and applicable database software. EPA will ensure the accuracy and 

completeness of collected information by reserving the right to request proof of the list of ingredients 

(e.g., bills of lading, invoices) or other relevant documentation at any time to confirm that candidates 

have the achieved the criteria for recognition.

5(c) Small Entity Flexibility

EPA expects that some of the participants in the Formulator Program will be small entities. 

EPA has designed its application form to minimize respondent burden while obtaining sufficient and 

accurate information. In addition, given the voluntary nature of the collection, EPA expects that 

respondents will participate only if the benefits of participation outweigh the information collection 

burden.

5(d) Collection Schedule

Organizations may submit an application for recognition at any time.

6. ESTIMATING THE BURDEN AND COST OF THE COLLECTION

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-party 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 typical cleaning or non-cleaning product formulator, program and

application review will take about 2 hours (1 managerial, 1 technical). Filling out and submitting 

third-party profiler information request forms will take about 7.5 hours (6 technical, 1.5 clerical), and 

then establishing an agreement with the third-party 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). Finally, establishing a Partnership Agreement DfE will take 3 hours (1 managerial, 2 

technical).

For a typical addition of a third-party 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-Party Partners and Products (Private Label Companies, Licensees, or Toll 

Manufacturers) is estimated to take about 2.5 hours (2 technical, 0.5 clerical). On average, a partner 
 8

will fill out 3 third-party partners and products forms annually. Therefore, it is estimated that it will 

take one respondent 7.5 hours (6 technical, 1.5 clerical) to add third-party 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 three-year partnership period. 

This means that once every three years, the formulator re-submits its application for each partnership 

product to confirm that no changes have been made to ingredients. EPA then evaluates the application. 

EPA estimates that the partnership renewal process will take 5 hours (4 technical, 1 clerical) for 

cleaning and non-cleaning product formulators.

For purposes of this ICR, EPA expects that 96 (see Section 6(e) on estimating the respondent 

universe) cleaning and non-cleaning product formulators will choose to renew their partnerships. 

Furthermore, EPA anticipates that one in ten cleaning and non-cleaning product formulators over the 

three-year 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 same 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 ICR will renew their partnership agreements each year. It is also assumed that over the threeyear period of this ICR, one in ten formulators (or 3 cleaning product and 1 non-cleaning product 

formulators) will need to go through a new partnership approval process, which on an annual basis 

translates into two formulators per year (1 cleaning product and 1 non-cleaning product formulator).

As part of the application process, the third-party profiler will also reserve the right to visit site 

facilities to verify that each partnership product contains the same ingredients, in the same volumes, 

that are reported by the company as part of the DfE recognition process. The site auditor will review 

batch tickets associated with each recognized product to ensure that ingredient 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-year period of this ICR (i.e., 10 cleaning product 

and 1 non-cleaning product formulators). 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 ICR.

6(b) Estimating Respondent Costs

EPA estimates an average loaded hourly 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 hourly 

labor rates include a 17% overhead; this overhead rate is used for consistency with OPPT economic 

analyses for two major rulemakings: Wage Rates for Economic Analyses of the Toxics Release 

Inventory Program2and the Revised Economic 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

type of staff needed to complete the Formulator’s applications and their associated hourly labor rates 

were verified by contacting representatives from the participant categories.

The derivation of labor rates for managerial, technical and clerical staff 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)

Managerial4$43.21 $20.53 47.51% 17% 1.65 $71.09 $71.00

Professional/

Technical2 $38.71 $19.71 50.92% 17% 1.68 $65.00 $65.00

Clerical2

$17.87 $9.03 50.53% 17% 1.68 $29.94 $30.00

Exhibit 6.2 shows the breakdown of burden costs, assuming 25.5 hours for cleaning and noncleaning product manufacturers and 9.5 hours for cleaning product formulators wishing to add thirdparty partners and products. The third-party 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 typical 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 CleanGredientsTM ingredient at 

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 company per application. No additional capital or O&M costs 

are incurred by respondents under this ICR.

 

4 Bureau of Labor Statistics (BLS) Employer Costs for Employee Compensation, Supplementary Tables. From 

Supplementary Table 2, Employer costs per hour worked for employee compensation and costs as a percent of total 

compensation: Private industry workers in manufacturing industries, by occupational group, establishment size and 

bargaining status, March 2012. Available at: http://www.bls.gov/ncs/ect/sp/ecsuptc22.pdf
 10

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 

$71/Hr $65/Hr $30/Hr Cost Cost/Yr

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 cost for third-party profiler review and verification assumes that the typical application submitted by a cleaning product manufacturer will contain four products. Each product 

will contain 2 ingredients at $650 each and 1 proprietary ingredient at $1,300, for 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-year 

period will need to make changes to their formulations and go through a new partnership process which includes same collection 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 product 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 additional 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 ICR. EPA based its burden estimates on its 

experience managing other voluntary programs.

EPA expects that review of the program application forms for a typical cleaning or noncleaning product formulator will take about 1 hour (1 technical). Reviewing the third-party 

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 managerial, 1 technical).

The burden for reviewing the DfE Form for adding third-party partners and products is 

estimated to take about 3 hours (3 technical).

6(d) Estimating Agency Costs

Agency labor costs are calculated based on hourly basic rates for federal employees in 

the Washington-Baltimore area published by the Office of Personnel Management effective 

January 20125. The average hourly labor rate for managerial staff is estimated as the rate for a 

GS-13 Step 5 employee, for technical staff as a GS-10 Step 10 employee, and for clerical staff 

as GS-5 Step 1. These GS-level assumptions are consistent with those used in past EPA OPPT 

ICRs. The hourly rates were multiplied by an assumed loading factor of 1.6 to reflect Federal 

fringe benefits and overhead. This loading factor is from an EPA guide, Instructions for 

Preparing Information Collection Requests (ICRs) (OPPE, 1992, page 30, footnote 9).

The resulting average hourly labor rates, rounded to the nearest dollar amount, are $77 

for managerial staff, $57 for technical staff, and $26 for clerical staff. The Agency expects 

most activities related to this ICR to be performed by managerial staff (25 percent) and 

technical staff (75 percent).

 

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.pdf
 12

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 ThirdParty 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. Assumes that one in ten formulators will need to make changes to their 

formulations and go through a new partnership process which includes same collection steps – i.e., 1 of 29 cleaning product formulators (for a total of 30) and 1 of 3 non-cleaning product 

formulators (for a total of 4). 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-year life of the 

clearance. EPA expects the participation will ramp up over the three year period, but for the 

purposes of estimating annual cost and burden in Exhibit 6.2, it is assumed that 32 cleaning and 

non-cleaning products formulators will submit applications per year. This estimate is based on 

historical data and the assumption that participation will increase over the next three years in 

response to greater consumer demand for green products. EPA also estimates that of the 

applications, about 90 percent (or 29 per year) will be cleaning products, with the remainder 

being non-cleaning products. The EPA estimates that an additional 34 applications will be 

received annually to add third-party partners and products. This estimate is based on the number 

of partners that submitted third-party partners and products applications over the last year and is 

expected to remain constant over the course of this ICR period. Therefore, it is estimated that a 

total of 66 respondents will submit applications under the Formulator program each year. The 

annual burden hours and cost associated with this information collection are 1,111 hours and 

$488,570 respectively.

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 year over the three years covered by 

this ICR.

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 Tally

Exhibit 6.5 below summarizes the total annual estimated agency burden and cost. These 

estimates represent the average burden in any given year over the three years covered by this 

ICR.

Exhibit 6.5. Total Annual Estimated Agency Burden and Cost Summary

Burden Hours Annual Cost

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 ICR currently approved by OMB. This 

increase reflects EPA's estimate of the number of applications the Agency will receive annually 
 14

to add third-party partners and products. This estimate is based on the historical number of 

respondents that submitted third-party partners and products applications in the last year; this 

number is expected to remain constant over the next three years. EPA did not consider this factor 

in the previous ICR submission.

6(h) Burden Statement

The annual public burden for this collection of information is 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-party partners and products, including time for 

reviewing instructions, gathering information, 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 displays a currently valid OMB 

control number. The OMB control number for this information collection appears above. The 

OMB control numbers for EPA’s regulations in title 40 of the CFR, after appearing in the 

Federal Register, 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 ICR under Docket ID No. EPA-HQOPPT-2012-0675, 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 EPA 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 holidays. The telephone number 

for the EPA/DC Public Reading Room is (202) 566-1744, and the telephone number for the 

Pollution Prevention and Toxics Docket is (202) 566-0280.

You may submit comments regarding 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. Submit your 

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 by mail to: 

Pollution Prevention and Toxics Docket, Environmental Protection Agency Docket Center 

(EPA/DC), Mailcode: 28221T, 1200 Pennsylvania Ave., N.W., Washington, DC 20460, and (2) 

OMB by 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.