## The SunWise Program ICR # 1904.06

November 19, 2010 U. S. Environmental Protection Agency Office of Air and Radiation2 

### Part A of the Supporting Statement 1. Identification of the Information Collection 1(a) Title of Information Requ est The title of this Information Collection Request (ICR) is The SunWise Program (ICR# 1904. 06 ). 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 t erm 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, timel y, and useful UV data directly to schools and communities across the United State s. 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 pro fessionals, 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 largel y 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/becomin g.html and www.epa.gov/sunwise/becoming_partner.html ) or a hard cop y 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 infor mation distribution purposes. Participating schools and organizations receive a variet y 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 survey s 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 survey s will be made available on the SunWise website for all teachers that express interest in the survey process. S tudent s urvey

responses are voluntary

and anon ym ous. The results from the student survey s are used to gauge program effectiveness and also h elp guide materials development. 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 recognition3

program that SunWise is con sidering developing . The program would recognize levels of SunWise teaching for interested educators. The more SunWise teaching and sun safety policy changes implemented b y 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, e ducators 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 h as 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 effectivenes s, EPA will be collecting information on demographics, knowledge, attitudes, intended behavior, and behavior of the tutorial users. User typ es 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 pre test a new survey for SunWise non
- school partners. While schools are the primary progr ammatic 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 b y non - school partners, and how it can be improved. PREVIOUS TERMS OF CLEARANCE: On November 2, 2001, OMB approved ICR #190 4.01 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. EPA Response: We will not be surveying parents or school administrators under this I CR renewal.4

As discussed in Part B of the revised supporting statement, EPA plans to assess tw o 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 a dditional 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 anal ysis and found no differences between the students in the 37 cooler states vers us 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 negl ig ible difference b y 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. 

### 1. 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 1 st grade teach ers are using SunWise? How man y math teachers are using SunWise? etc.); and $ student participation level (How many students is SunWise potentially reaching?).5

Survey s 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 s chool 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 i ntent 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 kn owledge. $ Pre test 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 anal yz ed 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
. R esponses to the collection of information remain confidential , and responses to the student survey

are anony

mous . 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 survey s, tracking and monitoring of classroom act ivities 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 ada

pt 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.pdf6

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

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

### 3. Nonduplication, Consult ations, 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 earl y 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 Phy sicians for the Environment National Safety Council The Skin Cancer Foundation Results from these consultations indi cated that no other formal, student
- focused, sun safety programs were being implemented in the United States, nor were survey s being conducted on attitudes and practices of children relating to sun exposure. In addition, t o 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 usefu l process evaluation is also of importance if the SunWise Program is to continue providing high
- grade and pertinent resources for educators across the United S tates . 3(b) Public Notice Required Prior to ICR Submission to OMB Official notice of this propo sed collection appeared in the Federal Register on September 3, 2010 (75 FR 54143) . One comment was received
. Since EPA coordinates with other federal and non - federal entities working to prevent skin cancer and other health effects from overexposure to th e 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
- 40007

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

$ Dr. Barbara Gilchrest, Chair, Department of Dermatology , Boston University School of Medicine, (617) 638
- 5 538

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

School of Medicine, (781) 687
- 2865

$ Dr. Am y Mack, Ps y.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 timel y distribution of program materials and program updates to participants. SunWise depends on survey responses to

$ help guide program development; $ measure parti cipant 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 in formation 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 $ determine whether or not the tutorial is delivering the information in an easy
- to understand manner. Conducting the survey s and information collection les s frequentl y may slow down the Program’s ability to institute participants’ desired changes. 3(e) General Guidelines All OMB guidelines will be adhered to b y EPA/SunWise Program. 3(f) Confidentiality8

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 survey s are also completed on an anon ym ous ba sis (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 c ompletion with their name on it; however, the information will not be col lected b y EPA. EPA and a contractor will analyze survey results and proceed accordingl y. 3(g) Sensitive Questions The survey

instruments of this I CR contain no sensitive questions. 

### 4. The Respondents and the Information Requested 4(a) Respondent/S IC 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 (NAI CS 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/sunwis e/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 registe ring 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 I CR are as follows:

$ 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 , e ducators 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 mat erials. This information can be submitted online. Part B(i ) of the Supporting Statement provides additional information on the teacher survey design. $ Student S urvey (Attachment 3 a and 3b ): This survey will be administered by

volunteer teachers to partic ipating students before and after implementation of SunWise activities. Pre
- test and post
- test survey s are nearl y identical in content, with the exception of one question in the post
- test which is aimed at verifying that the student has participated in9

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 b y OMB (Control No. 2060
- 0439). Part B(i ) of the Support ing Statement provides additional information on the student survey design. $ Teacher Telephone I nterviews (Attachment 4): T o complement the information collected through the self
- reported Teacher Survey instrument , some teachers will be asked to partic ipate in one
- on - one, semi
- structured telephone interview s 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 con sidering 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 withi n 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 comple tion with their name on it. The information will not be collected b y 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 generall y. T he 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(ii i ) of the Supporting Statement provides additional information on the certificatio n program survey design. $ Pret est of the Partner S urvey (Attachment 5): S elected partners will be asked to pre test a survey to measure partners’ receptivity to the SunWise Tool Kit and other educational resources. Part B(i v ) of the Supporting State ment provides additional information on the pretest partner survey design. Registration forms can be submitted electronically or in hard cop y form using envelopes provided b y EPA. The teacher survey is available electronically. Teachers will be given th e option to return student survey s either b y email, fax, or postage
- paid envelopes provided by EPA. Neither the registration nor the survey s 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.10

The Agency

activities a ssociated 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, n one of which is sensitive or personal; and $ Review consolidated data and make adjustments as needed. 5(b) Collection Methodology and Management In collecting and anal yz ing the information associated with this I CR, EPA will use electronic and hard
- cop y registration forms, electronic and hard
- copy survey s , 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 teac her, gy

m teacher, or school nurse on paper copy registration forms. This information is then entered into a registration and tracking s ys tem housed on EPA servers. In addition to the paper copy registrations, EPA also registers educators and partners throu gh an online registration page housed on EPA’s SunWise program website. All information collected is protected b y adequate security and the s ys tem is registered with the Automated Sy stem Security Evaluation and Remediation Tracking (ASSERT) program to meet reporting requirements under the Federal In formation 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 personall y identifiable information is shared outside of EPA and its contractors and grantees. Teacher and Student Survey s Teacher Survey s are conducted to determine:11

$ 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 man y 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 tim eframe 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, e ducator 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 util ize 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 3 a 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 testi ng 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. F or those teachers that choose to participate, they will provide children with a double
- sided, one
page anon ym ous survey

instrument. After students complete the pre
- test in the spring, teachers will lead the SunWise lessons. SunWise will recommend that part icipating 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
. All student survey s are anony mous. S ince surveys are anon ym ous, no specific information on the child can be reported to parents or school staff. Survey s are done in the classroom setting, and conducted b y 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 survey s to EPA by one of several way s, including scanning and emailing the survey s, faxing the survey s, or b y requesting a self
addressed, stamped envelope from EPA. EPA will ensure the accuracy and completeness of collected information by having all survey s reviewed b y a contractor, grantee , or EPA staff. The data collected from the survey s will serve12

to provide information inte rnally 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 anal ys is methods for the teacher and student survey s. 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 effectivel y 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 scree ning 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. T eachers 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 randoml y selected to participate in the intervi ew 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 taken the online survey , EPA will set up a convenient time to interview each of the selected teachers. Te achers will participate in one online survey and one telephone interview per year over a three ye ar period, with slightly different informational goals for each year. In the first year, the interview will include discussion about the development of an educ ator 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.13

Part B(ii) of the Supporting Statement presents more detailed information on the data collection, management, and anal ys is 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 ye ar (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. T he pledge is availa ble 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 analy sis methods for the tutorial/certification program. EPA plans to periodically review data collecte d 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 b e shared with partners and the public for improved tailoring of interventions to the outdoor recreation audience. Pretest Partner Survey EPA will undertake pre testing of a survey for non
- school partners participating in the SunWise Program. These partn ers may include state and local health departments, childcare centers, museums, camps, and science centers. The purpose of the survey will be generall y to better understand how non
- school partners are interacting with the SunWise Program, as well as to de termine:

$ How and how often partners are using the SunWise materials, resources and programming; $ How man y 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 improvi ng or creating new SunWise resources. The pre testing 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 understand14

what the questions are aski ng 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 partn ers to p articipate in the pre testing 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 p artners indicating their willingness to participate, EPA will sort the partners into ty pes of partners (e.g., health departments, childcare centers, camps, and educational centers such as museums or science centers) and randomly

select participants from ea ch 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 anal ys is 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. Teacher and Student Surveys: All program participants are invited to take the Teacher Survey at an y time during the ye ar. 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 survey s will be asked to administer the pre
- tests before teachin g the SunWise lessons, and then to administer the post
- test survey at least one month after teaching the SunWise lessons
. Teacher Interviews: P articipants (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 ye ar period.15

Don’t Fry Day Pledge: All educators are invited to take the DFD pledge at any time during the ye ar. A recruitment email will be sent in the Spring to all registrants encourag ing 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 an y time during the ye ar. 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 SunW ise 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 onl y 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 th e 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 ye ar and takes app roximately 20 minutes to complete. If the teacher decides to conduct the student pre
- and post
- test survey s , additional time burden will be experienced by the teacher to administer the student survey s (noted below). During the development phase of the student survey s, 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 ye ar 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:16 Annual Respondent B urden - 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 Educat or 0.83 Don’t Fry Day Pledge: Educators will be invited to take the Don’t Fry Day pledge at any time throughout the ye ar. The pledge can be completed online and requires participants to fill out their name, address, school, and commitment to sun protec tion. The total respondent burden is estimated to be 5 minutes per year. Annual estimated respondent burden: Annual Respondent Burden - Pl edge Survey Group Hour Burden Educator 0.08
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 Questions17 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 way s to improve it. The total respondent burden is thus estimated at 50 minutes
. Annual estimated respondent burden:

Annual Respondent Burden - Pa rtner Survey Survey Group Hour Burden Non
- school Partner 0.83 6(b) Estimating Respondents Costs The Bureau of Labor Statistics figures 1 were used to determine labor costs for these tables. In order to account for benefits and overhead, the average hourl y wage rate of $36.45 for a teacher and $12.04 for a recreation worker (i.e., outdoor educator) w ere 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 hourl y labor cost , since these occupations are considered typical of SunWise’s non
- school partners . This averaged hourly labor cost of $18.40 was increased b y 110% for a labor cost of $38 .63 per hour for partners to account for benefits and overhead
.

Annual Respondent Burden and Cost
- Registration Registrant Group # of res ponses 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

1 http://www.bls.gov/oes/2009/may/oes_nat.htm and http://stats.bls.gov/ne ws.release/ecec.t02.htm18

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 Lab or 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 * (0.1 2 * 0) = 0 Outdoor Educator 1 0. 12 1 * 0. 12 * $ 25.28 = $ 3.03

Annual Respondent Burden and Cost

– Partner Survey Pretestin g 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 Cost19

Registration: Registration inf ormation 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 I CRs. 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 $1 3 0 per hour. The EPA employees will take 4 hours/month or 48 hours per year. The cost of thi s 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 ye ar on the maintenance and enhancement of the registration and tracking s ys tem at an annual cost of $ 31,200
. Finally , EPA will manually input all information received via hard
- cop y registration form onto the database. The costs of this lab or are estimated to be 2000 hours per ye ar 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 Su rveys: The contractor assists EPA in data collection and anal ys is. 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 ye ar . At an aver age rate of $1 3 0.00 per hour, the total cost for the contractor is about $1 9 , 5 00 annually. Agency burden to manage this contract is estimated at 4 hours/month or 48 hours annuall y. The cost of this labor will be calculated based on a GS 13 Step 1 pay lev el ($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 EPA (3
- Year ICR) 594 $68,328.86 Teacher Interviews: The contractor assists EPA in data collection and analysis. The contractor also provide s technical support in the development and deplo ym ent of the survey s 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 burde n to manage this contract is estimated at 4 hours/month or 48 hours annuall y. 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 Step20

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/ Surveyi ng 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 anal ys is function, agency burden is estimated at 2 hours/month or 24 hours annuall y. 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 anal yz e the data every other ye ar (i.e., during ye ar 1 and ye ar 3 of the ICR). To perform this task, EPA has contracted for a total of 200 professional hours, 100 hours for each year of anal ys is. In addition, EPA has contracted a total of 12 h ours each ye ar 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). Agency Burden an d 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 developm ent and deplo ym ent of the partner survey s and interview s in the pretesting process . To perform these functions, EPA21

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

or the contractor is about $11,7 00. 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 lab or 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 Burd en 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 1,000 Students per ye ar 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 $110,990.2522 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 H ours (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 ye ar 12 $0.00 100 $0.00 1,5 00 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 $965.7423 (A) Number to register (B)

Total Hours (C)

Rate per hour ($) (D) # of responses (E)

Total Cost E=B*C Total (Annual) - Year 3 25 30 $965.74 ICR Total (3 years) 25 30 $965.74 Total ICR Total Registration + Surveys + Tutorial + Interviews + Pledge (average annual)* 1,615 8,960 $100,171.56

ICR Total Registration + Surveys + Tutori al + 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 Educators 3,735 $285,895.58 Outdoor Educators 540 $28,704.38 Non
- school Partners 25 $965.74 EPA 8,798 $431,134.11 Subtotal (respondents) 4,846 $315,565.69 Subtotal (government) 8,798 $431,134.11 Total 13,644 $746,699.80

Bottom Line Burden and Costs (Average Annual) *24 Bottom Line Burden and Costs (Average Annual) * Burden Hours Total Costs ($) Students 182 0 Educators 1245 95298.525 Outdoor Educators 180 9568.125 Partners 8 321.9125 EPA 2933 $143,711.37 Subtotal (respondents) 1,615 $105,188.56 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 Cha nge in Burden There is an increase of 2,738 hours annuall y in the total estimated burden currentl y identified in the OMB Inventory

of Approved ICR Burdens . Fewer hours for EPA are anticipated for the survey work due to a decreased level of sophisti cation in the analy sis and decreased effort being needed to solicit survey

responses. More hours we re 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. Finally , registering such a large number of teachers has result ed in more hours needed at EPA. Hours and burden for educators is about the same; hours for students has also decreased significantly
. The b ottom line burden hours increased along with the total cost. 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 for the teacher interview with survey , 5 minut es 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 sy stems for the purposes of collecting, validating, and verifying information; processing and maintaining information, and disclosing and providing information; adjust the existing way s to comply with an y 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. An25

agency may not conduct or sponsor, and a person is not required to respond to, a collection of information unless it display s 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 15.26



### Part B (i) of the Supporting Statement

– Teacher and Student Surveys SECTION I

– SURVEY OBJECTIVES, KEY VARIABLES, AND OTHER PRELIMINARIES 1(a) Survey Objectives EPA’s SunW ise Program provides sun protection education via a standardized curriculum to school children in grades K
- 8 in public, parochial, and charter schools. More than 25,000 schools and 3,00 0,000 children have received SunWise education since the 1999
- 2000 school year. EPA proposes to conduct customer satisfaction and process
- related evaluative survey s with the teachers using the program. The Teacher Survey and Individual Interview will dete rmine:

$ 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 man y students are re ceiving 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. The data will be anal yz ed , and results, although not generalizable, will indicate how the Program is being implemented and how it can improve. The primary

objective of the optional student survey s is 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). B ecause this portion of the survey will b e voluntary

and self
- selecting, the results will not be generalizable to every student that has received a SunWise education. 1(b) Key Variables Satisfaction ; frequency

of use; number of students participating; number and ty pes of activities taught; scho ol policy

change; student and teacher knowledge, attitudes and behavior; way s to improve the program
. 1(c) Statistical Approach The primary

objective in conducting the SunWise Teacher Survey is to understand how the SunWise program is being implemented, and how it can be improved. It is not practical to survey every teacher that participates in the SunWise Program, however. Since the results are not intended to be generalizable to the complete pool of SunWise teachers , no statistical approach is needed.27

The student survey s will serve as a useful way to see if students are still getting the same benefit from the SunWise Tool Kit as in previous years. However, because these survey s are optional and self
- selecting, and the results are not intended to be ge neralizable, no statistical approach is needed. 1(d) Feasibility EPA has reviewed the administrative procedures necessary to conduct the SunWise teacher and student surveys and has determined that it is feasible to continue with the survey s . The Teacher Survey was reviewed b y educators and survey specialists to ensure that the questions asked will reveal sufficient information to evaluate the implementation of the SunWise Program and how it could be improved, especially by adding an incentives or “Levels of SunWise” recognition program. The student survey was previously pretested as described in Section III below. In addition, EPA has funding to conduct the survey and provide the necessary anal ys is of the resulting data. 

### SECTION II

– SURVEY DESIGN 2(a) Target Population and Coverage A self
- selected sample from all participating SunWise teachers will be used. SunWise teachers are very diverse , with some in school s and others in recreation programs and other organizations
. 2(b) Sample Design School fa culty

and other educators register for the SunWise program through EPA. Registrants provide their name and contact information, including the name of their school/organization, and state whether they

are a classroom teacher, health teacher, gy m teacher, s chool nurse, or other. Recruitment emails will be sent to all registered SunWise schools and partners. Participants may also be recruited through additional avenues, such as recruitment letters distributed through the SunWise Tool Kit, educator conferenc es, or direct mailings. However, many will not participate in the survey
. 2(b)ii Sample Size EPA anticipates sending recruitment emails to more than 35,000 formal and informal educators, however onl y 1 , 300 are expected to actually participate in the sur

vey . This number is based on previous survey

participation. 2(b)iii Stratification Variables None.28

2(b)iv Sampling Method As noted above, r ecruitment emails will be sent to all teachers who have registered for the SunWise Program since the program be gan in 1999. Because participation in the teacher survey is voluntary , the sampling method is voluntary self
- selection
. Inclusion criteria: Signed up with the SunWise program. Exclusion criteria: In complete Teacher Survey
. 2(b)v Multi - Stage Sampling None. 2(c) Precision Requirements 2(c)i Precision Targets N/A 2(c)ii Nonsampling Error N/A 2(d) Questionnaire Design The Teacher Survey was derived from a SunWise instrument previously approved b y OMB on November 2, 2001 and April 15, 2008 (I CR #19 04.01 and #1904.04). It is based on the instrument approved b y OMB in the most recent ICR (ICR #1904.04, April 15, 2008). The Teacher Survey was updated based on pre testing with nine teachers. The student survey

is derived from a SunWise instrument previ ously approved by

OMB on November 2, 2001, and most recentl y approved on February 28 , 20 1 0
. 

### SECTION III

– PRETESTS AND PILOT TESTS To pre test the revised SunWise Teacher Survey , less than nine teachers attending conferences that SunWise attended compl ete d the survey and then participate d in an interview with staff from EPA. The pre testing focused on the readability and understandab ility

of the Teacher S urvey . Teachers had no suggestions for revisions to the Teacher Survey
. The survey was also time
t ested to ensure completion in 20 minutes or less
. The pre testing of the student survey was conducted under the previous I CR (1904.04). It focused on the readability

and understandability

of the questions and possible responses; following the pre test, the survey

was revised to: (1) include instructions for students to turn over the two
- page, double
- sided survey ; (2) increase the font of multiple choice instructions; (3) put all questions29

referring to “last summer” together in a box at the end of the survey ; (4) delete one question that students found difficult; (5) revise the wording of several questions to clarify question meaning; (6) add a new response choice for wh y students do not wear sunscreen; and (7) increase the response scale for several questions from a three
- point to a five
- point scale. 

### SECTION IV

– COLLECTION METHODS AND FOLLOW - UP 4(a) Collection Methods Teacher Survey s are not anony mous and are administered online. All student survey s will be anon ym ous. Student survey s are administered in the classroom setting, and conducted b y 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. In addition, all student survey s are anony mous, and thus no specific information on a child can be reported to parents or school staff. Student survey s will be returned to EPA by one of several methods: scanned and emailed; faxed; or sent through U.S. Postal Service using a self
- addressed, postage
paid envelope s upplied by EPA. 4(b) Survey Response and Follow - Up The target response rate is approximately 3 to 4 percent among all teachers registered for the SunWise Program, although some of those teachers may no longer be teaching the Program
. Actual response rate will be measured based on the number of teachers that submit survey s divided by

the number of total teachers signed up for the program. No additional follow
- up will occur unless there are questions with the survey , or if additional clarification is neces sary on suggested improvements. 

### SECTION V

– ANALYZING AND REPORTING SURVEY RESULTS 5(a) Data Preparation All Teacher Survey data will automatically be entered into a database hosted on the EPA server. All student survey

data will be entered into a data base, including survey s with questions that have not been completed. A double
- entry protocol will be observed throughout data entry to ensure accuracy . 5(b) Analysis The data obtained through this survey will be reviewed and anal yz ed using descriptive s tatistical methods in the aggregate for the purpose of determining satisfaction; frequency of use; number of students participating; number and types of activities taught; school policy change; student and teacher knowledge, attitudes and behavior; ways to improve the program. All of this information will give EPA insight into how best to improve the program, and how the program is30

being used. The results will not be generalizable to the total pool of SunWise teachers or students , but will nonetheless be in formative
. 5(c) Reporting Results The results of the survey

will not be written up formally , rather they will be used internall y b y the SunWise program to understand how the SunWise program is being implemented, and how it can be improved. The raw surv ey data will be maintained by EPA . EPA will share the information with a contractor , but will remain unavailable to the public.31



### Part B (ii) of the Supporting Statement

– Teacher Interviews SECTION I

– SURVEY OBJECTIVES, KEY VARIABLES, AND OTHER PRELIM INARIES 1(a) Survey Objectives EPA’s SunW ise Program provides sun protection education via a standardized curriculum to school children in grades K
- 8 in public, parochial, and charter schools. More than 25,000 schools and 3,000,000 children have received SunWise education since the 1999
- 2000 school year. EPA proposes to conduct customer satisfaction and process
- related evaluative survey s with the teachers using the program. The teacher telephone interviews will gather 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 effectivel y disseminate its materials and recruit more teachers ; $ How the SunWise Program can encourage teachers to increase their involve ment 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. The information will be analyzed and results, although not generalizable, will indicate how the Program is being implemented and how it can improve. 1(b) Key Variables Involvement ; school policy change; frequency

of use; number and types of activities taught; most effective activities and resources; interes t in a recognition program; motivation for increased participation; effort involved in recognition program. 1(c) Statistical Approach The primary

objective in conducting the SunWise teacher interviews is to gather qualitative information on how the SunWi se program is being implemented, and how it can be improved. Since the results are not intended to be generalizable to the complete pool of SunWise teachers , no statistical approach is needed. 1(d) Feasibility EPA has reviewed the administrative procedures necessary to conduct the SunWise teacher interview s and has determined that it is feasible to continue with the interview s . In addition,32

EPA has funding to conduct the interview and provide the necessary anal ys is of the resulting data. 

### SECTION II

– S URVEY DESIGN 2(a) Target Population and Coverage The target population consists of teachers that have taught the SunWise Program in the past two ye ars; these teachers span the United States. 2(b) Sample Design 2(b) i Sampling Frame The sampling frame con sists of all teachers that have registered for the SunWise Program. 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 the y 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. 2(b)ii Sample Size EPA anticipates 200 teachers will respond positively to both screening ques tions (a) and (c) described in section 2(b)i above; however onl y 50 will be selected to participate in the interview process . 2(b)iii Stratification Variables None. 2(b)iv Sampling Method As noted, 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 ye ars 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. T eachers responding positively to both screening questions (a) and (c) , will be grouped b y region and length of participation, and across these groups 50 teachers will be randomly selected to participate in the intervi ew process. To the extent possible, the selected teachers will represent the geographical and participation range of those teachers responding positively to the screening questions (i.e., a sample of a sample) , though the sample will not necessarily be rep resentative 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. Inclusion criteria: Registered with the SunWise Program; h as taught SunWise in the past two ye ars; indicated willingness to participate in an interview through the screening email
.33

Exclusion criteria: In complete Teacher Survey
. 2(b)v Multi - Stage Sampling None. 2(c) Precision Requirements 2(c)i Precision Tar gets N/A 2(c)ii Nonsampling Error N/A 2(d) Questionnaire Design An interview guide with topics of discussion (Attachment 4 ) was developed by a team of contractor s , a grantee , and EPA staff , and reviewed by

educational and survey

experts . 

### SECTION III

– PRETESTS AND PILOT TESTS Given the semi
- structured approach to the teacher interviews and the qualitative nature of the study , pilot testing is not needed. The interview guide was reviewed b y educational and survey experts to ensure that the question s asked will reveal sufficient information to evaluate the implementation of the SunWise Program and how it could be improved, especiall y b y adding an incentives or “Levels of SunWise” recognition program. 

### SECTION IV

– COLLECTION METHODS AND FOLLOW - UP 4( a) Collection Methods Selected participants will be asked to complete the online teacher survey , as provided in Attachment 2 and described in Part B(i) of the Supporting Statement. After the participants have completed the online survey , EPA will arrange a convenient time to interview each of the selected teachers via the telephone
. Teachers will participate in one online survey and one telephone interview per year over a three ye ar 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. Teachers may receive an annual incentive for their participation in the survey and interview, such as a $25 gift certificate to a bookstore of their choosing to purchase classroom resources.34

4(b) Survey Response and Follow - Up The target response rate is approximately 80 percent , with a total of 50 teachers participating in the interviews . Actual response rate will be measured based on the number of teachers that participate in the interviews divided by the number of teachers that indicated interest and were selected to participate
. Follow
- up emails and telephone calls will be made to all teachers who were selected to participate but have not responded to an initial interview invitation. These follow
- ups will explain the importance of the interviews and strongl y encourage teachers to participate. In addition, if fewer than 50 positive responses to the initial screening questions are received, EPA will follow up with an additional recruitment email encouraging participation and may also recruit participants through conferences, direc t mailings, and other means. 

### SECTION V

– ANALYZING AND REPORTING SURVEY RESULTS 5(a) Data Preparation The interviewer and/or assistant will take notes during the interview
. 5(b) Analysis The information obtained through these interviews will be anal yz ed qualitatively through a sy stematic content anal ys is to identify key findings based on response frequency and emphasis. While these findings will give EPA insight into how best to improve the program, and how the program is being used , the results will not be generalizable to the total pool of SunWise teachers
. 5(c) Reporting Results The results of the qualitative content anal ys is will be written up in a summary report, which may also be shared on the EPA website and with partners and interested partie s. The individual interview notes will be maintained by EPA and/or an EPA contractor and will remain confidential
.35



### Part B(iii) of the Supporting Statement

– Certification Program SECTION I

– SURVEY OBJECTIVES, KEY VARIABLES, AND OTHER PRELIMINARIES 1(a) Survey Objectives To expand the SunWise Program beyond the formal classroom, EPA has developed an online tutorial and certification questions to educate outdoor recreation staff who supervise teens and pre - teens about the importance of s un safety . Outdoor recreation staff who supervise teens and pre - teens include camp counselors, swim instructors, and parks and recreation staff/educators. By way of this voluntary

tutorial/certification program, EPA looks to educate outdoor recreation sta ffers that supervise teens and pre
- teens about the importance of sun safety for them and the yo uth in their care. This can be done through a number of way s including smart
- scheduling, positive role
- modeling and other policy changes at individual camps, po ols or centers. Upon completion, each user will be able to email their certificate of accomplishment to their supervisor. Whole camps will then be able to state that their staff has taken the EPA Sun Safety Certification, meaning they understand the importance of sun safety, and know how to prevent sun damage in children. A series of survey

questions are included throughout the tutorial and must be answered to advance through and complete the tutorial/certification program
. EPA intends to meet two main obj ectives through asking the survey questions. The primary

objective is to determine the current sun protection knowledge, attitudes, practices, intended practices, and teaching habits of outdoor educators, as well as basic demographic information (e.g. age , gender, education). Responses to the tutorial/certification questions will also determine the environmental conditions (i.e., policies) already in place to minimize UV damage to the staff and visitors, and the perceived cultural norms of camp staff. Th is information will help inform SunWise program decisions such as framing a sun safety message and developing materials for pre
- service teachers and outdoor educators to promote sun protection outside of the formal classroom. The secondary

objective is to gather feedback on the usefulness of the certification program. This feedback will help the Agency determine if online media is an effective method of teaching sun safety lessons, and whether additional resources are needed for outdoor recreation faciliti es. 1 (b) Key Variables Key variables considered in this tutorial/certification program are demographic information about the educator (e.g., age, gender, education), the age range of children being supervised b y the educator, the educator’s sun safety prac tices and intended practices, and policies related to sun safety implemented by the educator’s program or organization. 1(c) Statistical Approach The primary

objective of the tutorial/certification program questions is to measure the sun protection attitu des, practices, intended practices, and teaching habits of outdoor educators. Every outdoor educator that participates in the tutorial/certification will be asked to respond to36

the questions that are built into the online program. It is not practical, ho wever, to require all outdoor educators to participate in the tutorial/certification program, so participation will be voluntary and self
- selecting. From this group, the Agency will be able to draw conclusions about outdoor educators in general. Anecdotal information is not sufficient for this purpose, and thus EPA has chosen a standardized questionnaire
- based approach for this survey
. The tutorial/certification program asks a series of questions about outdoor educators’ sun protection attitudes, practice s, intended practices, and teaching habits. EPA intends to have each educator onl y complete the survey once during the period for which this ICR is in effect. An anal ys is of these results will give a snapshot of outdoor educators’ behaviors, and will help the Agency to better understand the challenges associated with promoting sun safety in outdoor education programs. 1(d) Feasibility EPA has determined that an online, voluntary , self
- selecting tutorial/certification program is a feasible way

to gather in formation regarding sun protection in an outdoor education setting. In addition, EPA has developed the online tutorial/certification program, and has funding to collect and review responses and perform necessary updates to the program. 

### SECTION II

– SURVEY DESIGN 2(a) Target Population and Coverage The target population consists of outdoor recreation staff members that supervis e teens and pre
teens. Because the tutorial/certification program is self
- selecting and voluntary , the coverage of this population i s not known. 2(b) Sample Design 2(b) i Sampling Frame The sampling frame is all U.S. outdoor recreation staff members at programs included in the mailing lists from the American Camp Association (ACA) and the National Recreation and Park Association (NRPA ) , which are updated regularl y . The sampling frame will be identified by the purchase of these e
- mail lists. Survey participants will be recruited via a targeted email to all programs in the ACA and NRPA lists, which will direct participants to the EPA w ebsite. Advertisements for the tutorial/certification program will also be placed on the EPA SunWise Web site and ACA and NRPA Web sites. In addition, participants will be recruited at conferences related to sun safety and education, and EPA may also rea ch out to sports coaching associations for participant recruiting.37

2(b)ii Sample Size Because the tutorial/certification program is self
- selecting and voluntary , it is not possible to pre determine a specific sample size . Ho wever, EPA anticipates about 1,0 00 outdoor recreation staff members will complete the tutorial/certification program. 2(b)iii Stratification Variables None. 2(b)iv Sampling Method Because participation in the tutorial/certification program is voluntary , the sampling method is voluntary s elf
- selection. Because the survey questions must be answered to advance through the tutorial, all outdoor educators that elect to participate in the certification program will necessarily complete the survey . There is sampling bias associated with self
- sel ection on both an individual and an organizational level as camps or programs may require all of their educators to take the tutorial; however, because participation in the certification program is voluntary , self
- selection is the only feasible sampling me thod available to the Agency
. 2(c) Precision Requirements 2(c)i Precision Targets Based on an assumed sample size of 1,000 participants, the Agency ’s precision target is ±3.1 percentage points at a 95 percent confidence level for aggregated question resp onses (i.e., the estimated percentage of all potential respondents that give a certain answer to a given survey question). For question responses for sample subsets (e.g., the percentage of male respondents that give a certain answer to a given survey que stion), the uncertainty in the estimated percentages will be greater. 2(c)ii Non - sampling Error It is expected that the largest non
- sampling error will be the result of non
- response. 2(d) Questionnaire Design The tutorial/certification questions were derived from those developed in a 2008 study by Glanz et al
. 2 InGlanz et al. (2008), a group of investigators evaluated available questionnaire measures of sun exposure and protection in order to propose a core set of standardized survey items for a range o f age groups (adults, adolescents aged 11 to 17, and children 10 years or younger). The investigators used these core questions in cognitive testing and found that they had good clarity and applicability

for measuring sun exposure and sun protection behav iors across a broad range of populations. In addition, it was determined that these methods are appropriate for studies tracking morbidity

and/or mortality

and evaluating prevention program effects.

2 Glanz, K, Yaroch, AL, Dancel, M, Saraiya, M, Crane, LA, Buller, DB, Manne, S, O’Riordan, DL, Heckman, CJ, Hay, J, Robinson, JK. Measures of Sun Exposure and Sun Protection Practices for Behavioral and Epidemiologic Research. Archives of Dermatology . 2008; 144 (2); 217
- 222.38

Based on this study, participants are asked a series of questions throughout the tutorial about themselves, their sun protection
- related behavior and their experience with the tutorial. These questions are meant as a self
- assessment tool and must be answered in order to complete the tutorial . Participants are encouraged to think about how they can improve their current behavior while answering. The questions are incorporated into each of the five sections of the on
- line tutorial/certification program:  Introduction: provides a brief overview of the tutorial.  UV Basics: emphasizes the importance of knowing the facts about UV radiation.  Louder than W

ords: describes sun safe actions and provides information on sun protection attire and SPF sunscreen.  Do As I Do: provides insight to participant’s ability to influ ence young people, and offers suggestions for modeling sun safe behaviors.  Before You Go: summarizes information from the tutorial, provides links to additional resources, and presents questions about participant’s intentions to follow suggestions present ed in the tutorial. The training is expected to take approximately 45 minutes to complete , of which approximately 7 minutes will be for answering the survey questions
. 

### SECTION III

– PRETESTS AND PILOT TESTS No pilot testing of the tutorial/certification q uestions is planned. 

### SECTION IV

– COLLECTION METHODS AND FOLLOW - UP 4(a) Collection Methods Tutorial/certification program participants will complete the tutorial/certification online through the EPA SunWise Program website, and responses will be automatica lly submitted electronicall y upon completion. All tutorials/certifications are anony mous, and no personal information will be stored. 4(b) Survey Response and Follow - Up Because outdoor educators self
- select to complete the tutorial and certification ques tions, no response rate will be specificall y measured, although EPA will keep count of the number of respondents. No follow
- up will be performed with outdoor educators that complete the tutorial/certification program.39



### SECTION V

– ANALYZING AND REPORTING SU RVEY RESULTS 5(a) Data Preparation No personal information will be stored. Responses to questions presented in the tutorial will be collected and stored automatically upon completion, and will be reviewed by EPA to help determine necessary

changes to make to the tutorial and program. 5(b) Analysis Data obtained through the tutorial/certification will help EPA gain a better understanding of adjustments to make to the SunWise tutorial/certification program to better educate outdoor recreation staff. In ad dition, responses will provide EPA with an idea of the ty pes of sun safety policies implemented in outdoor education programs, policy effectiveness, as well as possible areas of improvement to increase sun protection. Basic descriptive statistic al anal ys e s will be used to describe and present a basic summary of responses collected and organize them in a logical manner. Data will be aggregated to calculate, for example, the percentage of outdoor educators that practice a certain sun safety behavior, or the mean number of times outdoor educators remind teens and pre
- teens in their care about sun protection , along with 95% confidence intervals . Data will also be parsed for comparison b y different demographic or other categorical variables in order to compare, for example, the percentage s of male versus female outdoor educators that remind children to protect themselves from the sun. Differences in percentages will be calculated together with 95 percent confidence intervals and statistical tests to determine whether the differences are statistically significant. 5(c) Reporting Results In formation from tutorial/certification responses will serve to inform EPA of program areas needing improvement to better reach the target audience, as well as increase sun safety awareness and practices in informal and outdoor education settings. Raw survey

data will be kept confidential. EPA plans to share aggregated findings with partners and the public to improve sun safety education.40



### Part B (iv) of the Supporting Statement

– Pretesting the Partner Survey SECTION I

– SURVEY OBJECTIVES, KEY VARIABLES, AND OTHER PRELIMINARIES 1(a) Survey Objectives EPA’s SunW ise Program provides sun protection education via a standardized curriculum and other resources (i.e. , Sun Safety Tut orial) to children in grades K
- 8 in communities at 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. About 4,6 00 informal education centers have registered with SunWise since the 1999
- 2000 school year. EPA will undertake pre testing of a survey for non
- school partners participating in the SunWise Program. These partners may in clude state and local health departments, childcare centers, museums, camps, and science centers. The purpose of the survey will be generall y to better 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 man y children are receiving SunWise education through non
- school partners ; $ Children’s satisfaction with SunWise activities and resources; $ Partners’ sati sfaction 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 pre testing is intended to determine the validity , reliability , 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. 1(b) Key Variables Understandability, validity, reliability , and effectiveness of questions; right questions for understanding partner participation in SunWise. 1(c) Statistical Approach The primary

objective of the pretesting is to gather information that will help EPA develop a new questionnaire for SunWise non
- school partners, and to determine the validity , reliability , and effectiveness of initial draft questions
. N o statistical approach is needed.41

1(d) Feasibility EPA has reviewed the administrative procedures necessary to pretest the SunWise partner survey and has determined that it is feasible to continue with the pretesting
. EPA has funding to conduct the pretesting and use the resulting input to revise the partner survey
. 

### SECTION II

– SURVEY DESIGN 2(a) Target Population and Coverage The target population includes all non
- school partner s registered with the SunWise Program, or approximately 4 , 6 00 organizations. These organizations include 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. 2(b) Sample Design 2(b) i Sampling Frame Partners register for the SunWise program through EPA. Registrants provide their name and contact information, including the name of their o rganization, and state what their role is
. EPA will send a recruitment email to all registered SunWise partners in the Spring/Summer timeframe encouraging them to participate in the pilot testing of the partner survey (Attachment 5). Participants may

also b e recruited through additional avenues, such as recruitment letters distributed through the SunWise Tool Kit, educator conferences, or direct mailings. However, many may choose not to participate. 2(b)ii Sample Size EPA anticipates sending a recruitment email to about 4,6 00 non - school partners , however onl y 30 will be selected for participation in the survey pretesting
. 2(b)iii Stratification Variables None. 2(b)iv Sampling Method From those partners responding positively to the recruitment email , EPA will sort the willing partners into ty

pes of organizations (e.g., health , recreation, and educational d epartments; childcare centers; camps and scouting groups; and educational centers such as museums or science centers) and randomly select participant s from each group for a total of 30 participants. The number of participants selected from each group will be weighted based on the overall composition of SunWise registered partners. Inclusion criteria: Registered with the SunWise program.42

Exclusion cr iteria: Non
- response . 2(b)v Multi - Stage Sampling None. 2(c) Precision Requirements 2(c)i Precision Targets N/A 2(c)ii Nonsampling Error N/A 2(d) Questionnaire Design The partner survey for pretesting derived from a SunWise teacher instrument prev iously approved b y OMB on November 2, 2001 and April 15, 2008 (I CR #1904.01 and #1904.04). Because this information collection consists of pretesting with the goal of developing a new survey for SunWise non
- school partners, the design of the survey will n ecessarily

change through the pretesting process and additional or different questions may be pretested with partners . The draft survey for pretesting is provided in Attachment 5. 

### SECTION III

– PRETESTS AND PILOT TESTS This information collection consist s of pretesting for the development of a new survey for SunWise non
- school partners. 

### SECTION IV

– COLLECTION METHODS AND FOLLOW - UP 4(a) Collection Methods Depending on available resources and other constraints, the survey may be self
- administered with f eedback 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 unders tood all questions , whether the survey

was easy to complete, 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
. EPA will also measure the time it takes for each respondent to complete the survey (estimated at less than 20 minutes).43

4(b) Survey Response and Follow - Up The target response rate is approximately 80 percent. Actual response rate will be measured based on the number of partners that participate in the pretesting divided by the number of partners that indicated interest and were selected to participate. Follow
- up emails and telephone calls will be made to all partners who were selected to participate but have not responded to an initial invitation. These follow
- ups will explain the importance of the pretesting and strongl y encourage partners to participate. 

### SECTION V

– ANALYZING AND REPORTING SURVEY RESULTS 5(a) Data Preparation All survey

data will be entered into a database. A double
- entry protocol will be observed throughout data entry

to ensure accuracy . During interviews with partners following pretesting of the survey , the interviewer and/or assistant will take detailed notes. 5(b) Analysis The survey data and qualitative input obtained through the pretesting will be aggregated and anal yz ed for the purpose of determining the validity , reliability , and effectiveness of survey questions. All of this information will be used by EPA to revise the survey questions. 5(c) Reporting Results The results of the pretesting will be used b y EPA to revise the partner survey. The raw survey and interview data will be maintained by EPA and/or an EPA contractor and will remain unavailable to the public.