Information Collection Request for SDSI program Page 1 of 15

Supporting Statement for a Request for OMB Review under

The Paperwork Reduction Act

1 IDENTIFICATION OF THE INFORMATION COLLECTION

1(a) Title and Number of the Information Collection

Safer Detergent Stewardship Initiative (SDSI) Program

EPA ICR No.: 2261.02 OMB Control No.: 2070-0171

1(b) Short Characterization

This renewal information collection request (ICR) addresses the submission of 

applications to EPA for recognition under the Safer Detergent Stewardship Initiative (SDSI) 

Program. EPA announced the program as part of a Federal Register notice (71 FR 9337; 

February 23, 2006) that announced the availability of the Final Aquatic Life Ambient Water 

Quality Criteria for Nonylphenol. Nonylphenol ethoxylates (NPEs) and their breakdown 

products, such as nonylphenol, are toxic to aquatic life. SDSI will complement EPA’s Aquatic 

Life Criteria by encouraging the manufacture and use of safer surfactants, thus reducing the 

amount of nonylphenol ethoxylate surfactants and nonylphenol in streams and other water 

bodies. The Design for the Environment (DfE) program has identified safer alternatives to NPE 

surfactants through its partnership work with industry and environmental advocates; many are 

comparable in cost and are readily available.

Under SDSI, EPA recognizes environmental leaders who voluntarily commit to the use 

of safer surfactants. Safer surfactants are surfactants that break down quickly to non-polluting 

compounds. Surfactants are used in a wide variety of applications and products. Examples 

include detergents, cleaners, airplane deicers, and fire-fighting foams. SDSI is designed to

encourage a shift to safer surfactants by companies unaware of the benefits of such a change. 

SDSI is also intended to attract companies that see value in the public recognition of corporate

product stewardship that SDSI will provide.

There are two categories for recognition under SDSI: Champion and Partner. Champion 

is the highest level of recognition offered under SDSI. At this level, the participant is invited to 

an awards ceremony, is listed on the EPA SDSI website as a Champion, and may use a special 

logo in their literature to help explain their participation in the program. The Partner category

provides recognition of significant accomplishment towards the use of safer surfactants. Partners 

will be listed on the EPA SDSI website and may be granted recognition as a Champion in the 

future, if appropriate

EPA may also ask respondents with Champion status to make information available to 

EPA for review to verify that Champion status respondents have not taken action that would 

disqualify them from continued recognition and use of EPA’s SDSI logo in product literature. 

For example, in confirming continued eligibility for a formulating company, EPA would look to 
Information Collection Request for SDSI program Page 2 of 15

review information such as production-related records (which are already required by EPA) to 

ensure that the company used only safer surfactants (i.e., surfactants that break down quickly to 

non-polluting compounds) in its products.

Candidates post a statement on their website describing the actions that qualify them for 

recognition under SDSI. Candidates also complete an application that describes the actions 

taken to qualify for recognition and have it signed by a company authority (e.g., Chief Executive 

Officer, or vice president with responsibility for product formulation).

2. NEED FOR AND USE OF THE COLLECTION

2(a) Need/Authority for the Collection

Authority for SDSI derives from Section 6604 of the Pollution Prevention Act (PPA) (42 

U.S.C. 13103; see Attachment A). Section 6604(b)(5) of the PPA directs EPA to facilitate the 

adoption of source-reduction techniques by businesses. Also, Section 6604(b)(13) directs EPA 

to establish an annual awards program to recognize a company or companies that operate 

outstanding or innovative source reduction programs. EPA developed SDSI in recognition of 

these directives and through consultation with a broad range of stakeholders. 

SDSI’s information collection activities will assist the Agency in meeting the goals of the 

PPA by providing resources and recognition for businesses committed to promoting and using 

safer surfactants. In turn, SDSI will help businesses meet their corporate sustainability goals by

providing the means to, and an objective measure of, environmental stewardship. Investment 

analysts and advisers seek these types of measures in evaluating a corporation’s sustainability

profile and investment worthiness.1 SDSI is also needed to promote greater use of safer 

surfactants by companies unaware of the benefits of such a change. EPA has carefully tailored 

its request for information, and especially the SDSI Application Form (EPA Form 6300-2), to 

ensure that it only asks for information essential to verifying an applicants’ eligibility for award 

or recognition. 

2(b) Practical Utility/Users of the Data

The information collected by the SDSI program is not designed or intended to support 

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

Application Form to: (1) identify the candidate’s commitment to promoting and using safer 

surfactants; (2) verify the candidate’s involvement in promoting and using safer surfactants; and 

(3) determine the candidate’s eligibility for award or recognition under SDSI. 

In addition, EPA and stakeholders will be able to track the progress of the program, both 

on the level of participation and expected environmental benefits. For environmental benefits, 

 

1

“Green to Gold: How Smart Companies Use Environmental Strategy to Innovate, Create Value, and Build 

Competitive Advantage;” Daniel Esty and Andrew Winston; Yale University Press, New Haven, CT; 2006
Information Collection Request for SDSI program Page 3 of 15

EPA will use its own Inventory Update Rule2to establish a baseline and track changes in the 

levels of nonylphenol ethoxylate manufactured, imported and used in the U.S. EPA may also 

make use of ongoing studies that monitor the level of contaminants, like nonylphenol, in various 

water bodies and sediment. EPA will review information sources for endpoints such as level of 

program participation, trends in surfactant use, and levels of toxic surfactant degrades in waters 

and sediment. Although EPA has not yet evaluated whether there is a correlation between SDSI 

participation and environmental outcomes, EPA remains committed to measuring the 

effectiveness of this program over the next three years. 

3. NON-DUPLICATION, CONSULTATIONS, AND OTHER COLLECTION 

 CRITERIA

3(a) Non-Duplication

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

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

collected by the SDSI program is unique and is not duplicative of previous information 

collection requests. When developing the program, EPA also checked with trade associations

and potential partners to confirm that the information being collected by the SDSI program does 

not exist elsewhere.

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

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

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

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

submitted to OMB.

3(c) Consultations

EPA announced its intentions to develop the SDSI program in February 2006. Since 

EPA announced the SDSI program in February 2006, EPA has received significant feedback on 

the SDSI program from stakeholders. EPA continues to work closely with stakeholders that 

include surfactant manufacturers, cleaning product formulators, environmentalists, water 

treatment facilities, and cleaning industry trade associations.

 

2 The Inventory Update Rule (IUR) requires companies that manufacture, import or use certain chemicals listed on 

the TSCA inventory to report to EPA information about these chemicals (e.g., production/use volume) on a periodic 

basis. IUR reporting occurs every five years. Companies are currently providing information for calendar year 

2005.
Information Collection Request for SDSI program Page 4 of 15

On June 12, 2006, DfE held a public meeting to take comments on SDSI. Senior 

managers from EPA’s Office of Science and Technology (Office of Water) and Office of 

Pollution Prevention and Toxics provided overviews of EPA’s Aquatic Life Criteria for 

Nonylphenol and SDSI. A clear majority of stakeholders representing a broad range of interests 

– surfactant manufacturers, cleaning product formulators, environmentalists, a water treatment 

facility, and a cleaning industry trade association – expressed strong support for SDSI. 

Stakeholders who spoke to express support for the program at the public meeting include:

Paul Anastas, Green Chemistry Institute 

Bill Balek, ISSA

Bill Greggs, Procter & Gamble

Cory Hammock, Clean Control

Marsha Hardin, Reckitt Benckiser

Lauren Heine, GreenBlue

Ed Hopkins, Sierra Club

Jennifer Jackson, East Bay Municipal Utility District

Jack Linard, Unilever 

Rich Liroff, World Wildlife Fund

David Long, SC Johnson 

Roger McFadden, Coastwide Chemicals

Sam Moore, Burlington Chemical

A minority of stakeholders, representing the Alkylphenol Ethoxylate Research Council 

(APERC), alkylphenol ethoxylate (APE)3and alkylphenol (AP) manufacturers, and two laundry

trade associations (large APE users), expressed concerns about SDSI. Their concerns are 

summarized in the June 12 public meeting notes.

4

EPA has taken steps to ameliorate these 

concerns. These steps include (1) clarifying that the intent of the program is to encourage the use 

of safer surfactants; the use of any surfactants (not solely NPE surfactants) that degrade to longlived and more toxic degradates would disqualify an applicant from recognition; (2) requiring 

that a company eligible for recognition have a product stewardship strategy to ensure the use of 

safer surfactants; and (3) limiting the scope of the program to those products whose use routinely 

results in their discharge to the environment; products such as ink, paint, and oil are not included.

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

respondents and data users about specific aspects of ICRs before submitting an original or 

renewal ICR to OMB for review and approval. In accordance with this regulation, EPA will 

pursue additional consultations with interested parties during the development of the renewal of 

this collection.

3(d) Effects of Less Frequent Collection

The SDSI Application Form is designed to be a one-time information submission for 

organizations that wish to participate in the SDSI program as either a Partner or Champion. In 

 

3 NPEs are part of the APE family of chemicals.

4 The meeting notes are available in the public docket (Docket ID No. EPA-HQ-OPPT-2006-0343), which can be 

accessed online via Regulations.gov
Information Collection Request for SDSI program Page 5 of 15

some instances, an organization that applies for Partner recognition may choose to re-apply at a 

later date for Champion recognition. Without this information, EPA will not be able to 

effectively determine whether companies are switching to safer surfactants nor recognize 

companies who successfully transition to safer surfactants.

3(e) General Guidelines

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

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

3(f) Confidentiality

No information collected by EPA under SDSI comprises confidential business 

information.

3(g) Sensitive Questions

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

sensitive questions.

4. THE RESPONDENTS AND THE INFORMATION REQUESTED

4(a) Respondents and NAICS Codes

SDSI seeks partners from establishments engaged in the production or use of surfactants, 

as well as establishments involved in the purchasing, distribution or use of products containing 

surfactants, whose use routinely results in their discharge to the environment. Others (e.g., nonprofit organizations, unions, academia) may also qualify through active encouragement of the 

use of safer surfactants.

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

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

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

for recognition through SDSI. However, EPA expects that most applications will come from the 

following industries:

NAICS Code Affected Industry

3256 Soap, Cleaning Compound, and Toilet Preparation Manufacturing

424490 Other Grocery and Related Products Merchant Wholesalers 

424690 Other Chemical and Allied Products Merchant Wholesalers

424990 Other Miscellaneous Nondurable Goods Merchant Wholesalers

4451 Grocery Stores

481 Air Transportation

561210 Facilities Support Services

561720 Janitorial Services
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561740 Carpet and Upholstery Cleaning Services

611310 Colleges, Universities, and Professional Schools

7211 Traveler Accommodation

8123 Drycleaning and Laundry Services

4(b) Information Requested

Once a prospective organization reviews the SDSI materials and decides to apply, it 

submits a SDSI Application Form (EPA Form 6300-2) (see Attachment B for complete form). 

Forms are available in hard copy or electronic form. Participants can use the hard copy forms 

they receive from EPA by mail or download PDF versions of the forms from the SDSI website. 

Applications will be received on an ongoing basis over the three years covered by this ICR. 

Champion status respondents maintain information already required by EPA, such as productionrelated records, that the Agency may review in order to verify that the company used only safer 

surfactants (i.e., surfactants that break down quickly to non-polluting compounds) in its products 

thereby confirming that their subsequent surfactant uses have not disqualified them from 

continued recognition and use of EPA’s SDSI logo in product literature.

(i) Data items:

The reporting items include:

 Facility name and website URL;

 Name, title, address, phone number, fax number, and e-mail address of the candidate’s 

primary contact person;

 Status (partner or champion) for which the candidate is applying;

 Type of organization (e.g. manufacturing, purchasing, retail);

 Description of facility and any relevant affiliations;

 Descriptions of actions taken to qualify for recognition;

 Commitment statement, on the company’s website or other public documents, showing 

one or more of the following (requirements vary by organization type and recognition 

level): evidence of a full or intended transition to safer surfactants; a strategy to ensure 

that only safer surfactants are used or purchased by specified dates; a written 

commitment to a full transition to safer surfactants within a specific time period; 

activities taken to date to promote the use of safer surfactants;

 Total production or use volume of surfactants, where applicable; and

 Signature, name, and title of senior company authority (e.g., CEO or vice president for 

health and environment).

(ii) Respondent activities:

Candidates post a statement on their website describing the actions that qualify them for 

recognition under SDSI. In addition, candidates conduct the following activities in order to 

complete and submit the SDSI Application Form (EPA Form 6300-2):

 Review the SDSI information;
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 Decide whether to apply for recognition, and whether to apply for partner or champion 

status;

 Select a primary contact person for the program;

 Complete the SDSI Application Form, including obtaining the signature of a company

authority (e.g., CEO or vice president for health and environment);

 Describe how their organization meets the evaluation criteria for the relevant recognition;

 Fax, mail, or scan and e-mail the signed completed form to EPA; and

 Provide relevant documentation to EPA upon request.

5. THE INFORMATION COLLECTED – AGENCY ACTIVITIES, COLLECTION 

METHODOLOGY, AND INFORMATION MANAGEMENT

5(a) Agency Activities

Under SDSI, EPA engages in the following activities related to the SDSI Application Form:

 Distribute the SDSI Application Form to potential participants, and maintain a 

downloadable PDF version on the SDSI website;

 Answer questions posed by potential applicants regarding recognition under the 

Initiative; 

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

calls; and

 Approve candidates for recognition and notify both successful and unsuccessful 

applicants of the decisions.

EPA is committed to evaluating whether there is a correlation between SDSI participation 

and environmental outcomes by using Inventory Update Rule data to establish a baseline and 

track changes in the levels of nonylphenol ethoxylate manufactured, imported and used in the 

U.S. EPA may also make use of ongoing studies that monitor the level of contaminants, like 

nonylphenol, in various water bodies and sediment. EPA will review information sources for 

endpoints such as level of program participation, trends in surfactant use, and levels of toxic 

surfactant degradates in waters and sediment. EPA may also review a respondent’s productionrelated records to verify that the company used only safer surfactants (i.e., surfactants that break 

down quickly to non-polluting compounds) in its products thereby confirming that their 

subsequent surfactant uses have not disqualified them from continued recognition and use of 

EPA’s SDSI logo in product literature.

5(b) Collection Methodology and Management

Respondents can obtain the SDSI Application Form in hard copy from EPA or by

downloading it from the SDSI website. The signed, completed forms can be faxed, mailed, or 

scanned and e-mailed to EPA. In collecting and analyzing the information associated with this 

ICR, EPA will use a telephone system, personal computers, and applicable database software. 

EPA will ensure the accuracy and completeness of collected information by reserving the right to 
Information Collection Request for SDSI program Page 8 of 15

request the list of ingredients (e.g., bills of lading, invoices) or other relevant documentation at 

any time to confirm that candidates have the achieved the criteria for recognition. 

5(c) Small Entity Flexibility

EPA expects that some of the participants in the SDSI program will be small entities. 

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

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

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

collection burden.

5(d) Collection Schedule

Organizations may submit a one-time application for recognition as Partners or 

Champions at any time.

6. ESTIMATING THE BURDEN AND COST OF THE COLLECTION

Exhibit 6.1 presents the estimated burden hours and costs for all respondents during each 

of the three years covered under this ICR, assuming 10 hours per respondent. No capital or 

operations and management costs are incurred by respondents under this ICR.

The data collection mechanism for SDSI is the SDSI Application Form (EPA Form 6300-

2). In an effort to minimize burden and cost, the SDSI Application Form was designed with 

straightforward questions and in a way that one application package will serve all types of 

participants. The expected participant categories for SDSI are as follows: chemical 

manufacturers, formulators, retailers / distributors, institutional purchasers, and “others.” 

Among these participant categories, it is expected that the chemical manufacturers, formulators, 

retailers / distributors, and institutional purchasers will be private sector institutions. Within the 

participant category “others,” it is expected that participants will represent unions, non-profits, or 

academia. 

6(a) Estimating Respondent Burden

The average respondent burden is estimated to be 10 hours per respondent. EPA used

professional judgment to arrive at a burden estimate and then consulted representatives from the 

participant categories to evaluate whether the burden estimate was reasonable (see section 3(c)). 

Burden hours for the SDSI application package are for reporting purposes only and include 

posting relevant information on the applicant website. 

We expect that for a typical entity, program and application review will take about one 

hour (technical staff). Obtaining approval, which is likely to involve verifying assumptions with 

staff and ensuring support from multiple levels of management, will take about 3 hours (1 

managerial, 1 technical, 1 clerical). Completing the application form will take about 5 hours (4 

technical, 1 clerical) and posting information on a company website will take 1 hour (1 
Information Collection Request for SDSI program Page 9 of 15

technical). Included in the application form estimate of 5 hours is the potential burden that 

would be incurred if EPA finds it necessary to verify the information in the application. For 

purposes of the burden estimate, EPA assumes that it will need to verify information from one

organization in each participant category, and each audit will take about 8 hours. This burden, 

when distributed among all participants, is about 57 minutes per participant ((8 hrs x 5 

participants) / 42 total participants).

6(b) Estimating Respondent Costs

EPA estimates an average hourly labor rate (base hourly rate plus fringe and overhead) of 

$70 for managerial staff, $61 for technical staff, and $29 for clerical staff. These three labor rate 

estimates are taken from the Office of Personnel Management 2010 General Schedule salary

table5and are presented in Exhibit 6.2 of this supporting statement. The type of staff needed to 

complete the SDSI Application Form and their associated hourly labor rates were verified by 

contacting representatives from the participant categories.

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

EPA estimates that 42 applications will be submitted over the three-year life of the 

clearance. This estimate is based on the actual number of SDSI applications submitted over the 

last three years (84 applications). It is estimated that EPA will receive about one half as many 

applications (or 42 applications) over the three-year cycle of this ICR, based on the assumption 

that many companies in the potential universe of respondents have either already applied or have 

decided not to participate. Over the next three years, EPA expects additional companies will 

apply that may not have previously heard of SDSI or who have only recently met the criteria for 

Champion or Partner. Furthermore, based on past experience with SDSI, EPA estimates that the 

vast majority of participating companies will be formulators, along with a small number of 

chemical manufacturers, retailers / distributors, institutional purchasers, and others. The total 

burden hours and labor costs associated with this information collection over the three-year cycle 

are 420 hours and $23,310, respectively (see Exhibit 6.1). The annual burden and cost, therefore, 

are 140 hours and $7,770. This ICR does not impose capital or O&M costs.

6(d) Estimating Agency Burden and Costs

Exhibit 6.3 presents the estimated Agency burden hours and costs associated with the 

information collection activities under this ICR. Other direct costs (copying, printing, telephone, 

and mailing expenses) are also included. EPA based its burden estimates on its experience 

managing this information collection and other voluntary programs.

Based on the general schedule (GS) pay schedule, EPA estimates an average hourly labor 

rate (hourly rate plus the standard government overhead factor of 1.6) of $62 for managerial 

staff, $46 for technical staff, and $21 for clerical staff. 9 The Agency expects most activities to 

be performed by managerial staff (25 percent) and technical staff (75 percent).

 

5 OPM 2010 General Schedule Salary Table, available at http://www.opm.gov/oca/10tables/pdf/gs_h.pdf

9 EPA labor costs are based on annual federal wage rates published by the Office of Personnel Management for the 

2010 General Schedule (Base) Pay Tables. These three labor rates were estimated using the following GS-levels: 
Information Collection Request for SDSI program Page 10 of 15

 

GS-13 Step-5 for managerial staff ($38.92/hour), GS-10 Step-10 for technical staff ($28.51/hour), and GS-5 Step-1 

for clerical staff ($13.10/hour). http://www.opm.gov/oca/10tables/pdf/gs_h.pdf
Information Collection Request for SDSI program Page 11 of 15

Exhibit 6.1. Estimated Burden and Costs to Respondents6

Type of 

Affected 

Public

Collection activity Estimated burden per 

response (hours)

Total burden (hours) Hourly labor cost Total 

labor cost

M T C M T C Total M T C

Private Sector

Chemical Manufacturers 1

 Review application and program information 0 1 0 0 1 0 1 $70 $61 $29 $61 

 Obtain senior approval 1 1 1 1 1 1 3 $70 $61 $29 $160 

 Complete and submit package7 0 4 1 0 4 1 5 $70 $61 $29 $273 

 Post information on website 0 1 0 0 1 0 1 $70 $61 $29 $61 

Subtotal 1 1 7 2 1 7 2 10 -- -- -- $555 

Formulators 32

 Review application and program information 0 1 0 0 32 0 32 $70 $61 $29 $1,952 

 Obtain senior approval 1 1 1 32 32 32 96 $70 $61 $29 $5,120 

 Complete and submit package6 0 4 1 0 128 32 160 $70 $61 $29 $8,736 

 Post information on website 0 1 0 0 32 0 32 $70 $61 $29 $1,952 

Subtotal 32 1 7 2 32 224 64 320 -- -- -- $17,760 

Institutional Purchasers 4

 Review application and program information 0 1 0 0 4 0 4 $70 $61 $29 $244 

 Obtain senior approval 1 1 1 4 4 4 12 $70 $61 $29 $640 

 Complete and submit package6 0 4 1 0 16 4 20 $70 $61 $29 $1,092 

 Post information on website 0 1 0 0 4 0 4 $70 $61 $29 $244 

Subtotal 4 1 7 2 4 28 8 40 -- -- -- $2,220 

Retailers/Distributors 1

 Review application and program information 0 1 0 0 1 0 1 $70 $61 $29 $61 

 Obtain senior approval 1 1 1 1 1 1 3 $70 $61 $29 $160 

 Complete and submit package6 0 4 1 0 4 1 5 $70 $61 $29 $273 

 Post information on website 0 1 0 0 1 0 1 $70 $61 $29 $61 

Subtotal 1 1 7 2 1 7 2 10 -- -- -- $555

Private Sector 

and 

Local 

Government

Others (e.g. non-profits, unions, academia) 4

 Review application and program information 0 1 0 0 4 0 4 $70 $61 $29 $244 

 Obtain senior approval 1 1 1 4 4 4 12 $70 $61 $29 $640 

 Complete and submit package6 0 4 1 0 16 4 20 $70 $61 $29 $1,092 

 Post information on website 0 1 0 0 4 0 4 $70 $61 $29 $244 

Subtotal 4 1 7 2 4 28 8 40 -- -- -- $2,220 

Total (3 years) 42 420 $23,310 

 

6 This ICR does not impose capital or OEM costs.

7

Includes burden of verifying data (about 8 hours), which EPA estimates will only need to be done for 1 organization in each participant category. This burden, when distributed among all 

participants, is about 57 minutes per participant ((8 hrs x 5 participants) / 42 total participants).
Exhibit 6.2. Derivation of Respondent Loaded Labor Rates using Q2 2010 Data

Labor 

Category Data Sources a Wage Fringe Benefit

Fringes 

as % 

wage

Overhead % 

wage b

Fringe + 

overhead 

factor

Loaded 

Wages

(a) (b) (c)=(b)/

(a) (d) (e)=(c)+(d)+1

(f)=(a) 

× (e)

Managerial

BLS ECEC, Private 

Manufacturing industries, “Mgt, 

Business, and Financial”

$43.06 $19.31 44.84% 17.00% 1.618 $69.69

Professional/ 

Technical

BLS ECEC, Private 

Manufacturing industries, 

“Professional and related” 

$36.31 $18.08 49.79% 17.00% 1.668 $60.56

Clerical

BLS ECEC, Private 

Manufacturing industries, 

“Office and Administrative 

Support” 

$17.27 $8.48 49.10% 17.00% 1.661 $28.69

Notes:

a

(BLS, 2010). http://www.bls.gov/ncs/ect/sp/ecsuphst.pdf Bureau of Labor Statistics, Employer Costs for Employee 

Compensation – December 2006-June 2010, "Table 2: Private Manufacturing Industry Workers, by occupational group, 

employer costs per hours worked for employee compensation and costs as a percentage of total compensation"

b An overhead rate of 17% was used based on assumptions in Wage Rates for Economic Analyses of the Toxics Release Inventory 

Program (Rice, 2002), and the Revised Economic Analysis for the Amended Inventory Update Rule: Final Report (EPAB, 2002).

Exhibit 6.3. Agency Burden/Cost 

Activities Hours per Labor 

Category

Labor Cost per

Hour a

Total Cost per 

Activity

Total Hours and Cost

SDSI application form Mgmt Tech. Mgmt Tech. Mgmt Tech. Hours per 

Activity

Cost per 

Activity

Distribute forms 7 23 $62 $46 $434 $1,058 30 $1,492

Answer questions 7 23 $62 $46 $434 $1,058 30 $1,492

Record / enter forms 10 30 $62 $46 $620 $1,380 40 $2,000

Verify information; Make 

awards selection 12 38 $62 $46 $744 $1,748 50 $2,492

Notify applicants of decision 3 9 $62 $46 $186 $414 12 $600

Total 39 123 -- -- $2,418 $5,658 162 $8,076

a As seen in footnote 9, labor cost per hour is a loaded wage. The General Schedule hourly wage is inflated by an 

overhead factor of 1.60.

6(e) Bottom Line Burden Hours and Cost Tables

a. Respondent Tally

Exhibit 6.4. Estimated Total Respondent Burden and Cost Summary

Total Number of Respondents Total Burden Hours Total Labor Cost

42 (3 years) 420 (3 years) $23,310a(3 years)

14 (annual) 140 (annual) $7,770 (annual)

a This ICR incurs no capital or OEM costs.
b. Agency Tally

Exhibit 6.5. Average Estimated Agency Burden and Cost Summary

Burden Hours Total Labor Cost

162 $8,076

6(f) Reasons for Change in Burden

There is a decrease of 3,610 hours (from 3,750 hours to 140 hours) in the total estimated 

annual respondent burden compared with that identified in the information collection most 

recently approved by OMB. This decrease reflects improved estimates of the number of 

applications EPA expects to receive, based on actual experience in administering the SDSI

program. The decrease is an adjustment.

6(g) Burden Statement

The annual public reporting and recordkeeping burden for this collection of information 

is estimated to average 10 hours per response, including time for reviewing instructions, 

gathering information, and completing and reviewing the application. Burden means the total 

time, effort, or financial resources expended by persons to generate, maintain, retain, or disclose 

or provide information to or for a Federal agency. This includes the time needed to review 

instructions; develop, acquire, install, and utilize technology and systems for the purposes of 

collecting, validating, and verifying information, processing and maintaining information, and 

disclosing and providing information; adjust the existing ways to comply with any previously

applicable instructions and requirements; train personnel to be able to respond to a collection of 

information; search data sources; complete and review the collection of information; and 

transmit or otherwise disclose the information. An agency may not conduct or sponsor, and a 

person is not required to respond to, a collection of information unless it displays a currently

valid OMB control number. The OMB control numbers for EPA's regulations are listed in 40 

CFR part 9 and 48 CFR chapter 15.

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

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

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

Docket ID No. EPA-HQ-OPPT-2010-0874, which is available for online viewing at 

www.regulations.gov, or in person viewing at the EPA Docket Center (EPA/DC), EPA West, 

Room 3334, 1301 Constitution Ave., NW, Washington, DC. The EPA Docket Center Public 

Reading Room is open from 8:30 a.m. to 4:30 p.m., Monday through Friday, excluding legal 

holidays. The telephone number for the Reading Room is (202) 566-1744, and the telephone 

number for the Pollution Prevention and Toxics Docket is (202) 566-0280. An electronic 

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

or view public comments, access the index listing of the contents of the public docket, and to 

access those documents in the public docket that are available electronically. When in the 

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

comments to the Office of Information and Regulatory Affairs, Office of Management and 

Budget, 725 17th Street, NW, Washington, D.C. 20503, Attention: Desk Officer for EPA. Please 
include the EPA Docket ID Number EPA-HQ-OPPT-2010-0874, and OMB Control Number 

2070-0171 in any correspondence.
ATTACHMENTS TO THE SUPPORTING STATEMENT

Attachments to the supporting statement are available in the public docket established for this 

ICR under docket identification number EPA-HQ-OPPT-2010-0874. These attachments are 

available for online viewing at www.regulations.gov or otherwise accessed as described in 

section 6(f) of the supporting statement.

Attachment A: 42 USC 13103 - Pollution Prevention Act Section 6604. Also available 

at online at the US House of Representatives’ Office of the Law Revision 

Counsel’s U.S. Code website

Attachment B: EPA Form 6300-2 - SDSI Application Form