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 (I CR) 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 Non ylphenol
. Nonylphenol ethoxylates (NPEs ) and the ir breakdown products, such as non ylphenol, are toxic to aquatic life. SDS I will complement EPA’ s Aquatic Life Criteria b y encouraging the manufacture and use of safer surfactants, thus reducing the amount of nonylphenol ethoxylate surfactants and nonylph enol in streams and other water bodies. The Design for the Environment (DfE) p rogram 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 recognize s environmental leaders who voluntaril y 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 applicat ions and products. Examples include detergents, cleaners, airplane deicers, and fire
- fighting foams. SDSI i s designed to encourage a shift to safer surfactants b y 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 SDSIwill provide
. There are two categories for recognition under SDSI : Champion and Partner. Champion is the highest level of recognition offered under SDSI . At this lev el, the participant is invited to an awards ceremon y, 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 signific ant 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 avai lable to EPA for review to verify that Champion status respondents have not taken action that would disqualif y them from continued recognition and use of EPA’s SDSI logo in product literature
. For example, i n confirming continued eligibility for a formulating company , EPA would look toInformation Collection Request for SDSI program Page 2 of 15

review information such as production
- related records (which are already required b y EPA) to ensure that the compan y used only safer surfactants (i.e., surfactants that break down quickl y to non - polluting comp o unds ) in its p roducts. Candidates post a statement on their website describing the actions that qualify them for recognition under SDSI
. Candidates also complete an application that describe s the actions t aken 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 SDSIderives 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 award s program to recognize a company or companies that operate outstanding or innovative source reduction programs. EPA developed SDSI i n recognition of th e s e directive s and through consultation with a broad range of stakeholders
. SDSI ’s information colle ction 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, SDSIwill help businesses meet their corporate sustainability goals by providing the means to , and an objective measure of , environmental stewardship. Investment anal ys ts and advisers seek these ty pes of measures in evaluating a corporation’s sustainability profile and investment worthines s. 1 SDSIis also needed to promot e greater use of safer surfactants b y companies unaware of the benefits of such a change. EPA has carefull y tailored its request for information, and esp ecially the SDSIApplication 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 ) d etermine 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 bene fits,

1 “Green to Gold: How

Smart Companies Use Environmental Strategy to Innovate, Create Value, and Build Com petitive Advantage;” Daniel Esty and Andrew Winston; Yale Univ ersity Press, New Haven, CT; 2006Information Collection Request for SDSI program Page 3 of 15

EPA will use its own Inventory Update Rule 2 to establish a baseline and track changes in the levels of non ylphenol 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 h as 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, CO NS ULTATIONS, AND OTHER COLLECTION CRITERIA 3(a) Non - Duplication Respondents will not be asked to provid e information that has been or is currentl y being collected b y EPA, other federal or state agencies or proprietary sources. The information collected b y the SDSI p rogram 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 collect ed b y the SDSI p rogram does not exist elsewhere. 3(b) Public Notice Required Prior to ICR Submission to OMB Prior to submission to OMB, this I CR will be made available to the public for comment throu gh a Federal Register notice. The public will have 60 day s to provide comments. Any comments received will be given consideration when completing the supporting statement that is submitted to OMB. 3(c) Consultations EPA announced its intentions to develop the SDSI p rogram in February 2006. Since EPA announced the SDSI program in February 2006 , EPA has received significant feedback on the SDSIprogram from s takeholders. EPA continues to work closel y with stakeholders that includ e 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 peri odic 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 publ ic 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
. S takeholders wh o spoke to express support for the program at the public meeting include : Paul Anastas, Green Chemistry Institute Bill Balek, IS SA Bill Greggs, Procter & Gamble Cory Hammock, Clean Control Marsha Hardin, Reckitt Benckiser Lauren Heine, GreenBlue Ed H opkins, Sierra Club Jennifer Jackson, East Bay Municipal Utility District Jack L inard, Unilever Rich L iroff, World Wildlife Fund David L ong, SC Johnson Roger McFadden, Coastwide Chemicals Sam Moore, Burlington Chemical A minority

of stakeholders, repre senting the Alkylphenol Ethoxylate Research Council (APERC), alkylphenol ethoxylate (APE) 3 and alkylphenol (AP) manufacturers, and two laundry trade associations (large APE users), expressed concerns about SDSI . Their concerns are summarized in the June 1 2 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 long
lived and more toxic degradates would disqualify an applicant from recognition ; (2) requiring that a compan y eligible for recognition have a product stewardship strategy to ensure the use of safer surfactants; and (3) limiting the scope of the pro gram to those products whose use routinel y 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 I CR respondents and data users about specific aspects of I CRs before submitting an original or renewal I CR to OMB for review and approval. In accordance with this regulation, EPA will pursue additional consultations with interested parties during the development of the renewal of this collec tion. 3(d) Effects of Less Frequent Collection The SDSIApplication Form is designed to be a one
- time informatio n submission for organizations that wish to participate in the SDSI p rogram 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 ), w hich can be accessed online via Regulations.govInformation Collection Request for SDSI program Page 5 of 15

some instances, an organization that applies for Partner recognition may choose to re
- appl y at a later date for Champion recognition. Without this information, EPA will not be able to effectivel y determine whether companies are switching to safer surfactants nor recognize companies who successfully transition to safer surfactants
. 3(e) General Guidelines The infor mation collection activities discussed in this I CR comply with all regulatory guidelines under 5 CFR 1320.5(d)(2). 3(f) Confidentiality No information collected by EPA under SDSIcomprises 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 Code s 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. , non profit organizations, unions, academia) may also qualify

through active encouragement of the use of safer surfactants. Below is a list of North American Industry Classification Sy stem (NAICS) codes and associated industries that may be affected by

information collection requirements covered under this I CR. This list is intended to be illustrative; entities from other industries may elect to appl y for recognition through SDSI
. However, EPA expects that most applications wil l come from the following industries: NAI CS 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 Who lesalers 424990 Other Miscellaneous Nondurable Goods Merchant Wholesalers 4451 Grocery Stores 481 Air Transportation 561210 Facilities Support Services 561720 Janitorial ServicesInformation Collection Request for SDSI program Page 6 of 15

561740 Carpet and Upholstery Cleaning Services 611310 Colleges, Univer sities, and Professional Schools 7211 Traveler Accommodation 8123 Drycleaning and Laundry Services 4(b) Information Requested Once a prospective organization reviews the SDSImaterials and decides to apply , it submit s a SDSIApplication Form (EPA For m 6300
- 2) (see Attachment B for complete form). F orms are available in hard copy or electronic form. Participants can use the hard cop y 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 ye ars covered b y this I CR. Champion status respondents maintain information already required b y EPA, such as production
related records, that the Agency may review in order to verify that the company

used onl y safer surfactants (i.e., surfactants that break down quickly to non - polluting compounds) in its products thereb y confirming that their subsequent surfactant uses have not disqualified them from continued recognition and use of EPA’s SDSI logo in product li terature. (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;  Ty pe 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 , s howing one or more of the following (requirements vary by organization ty

pe 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 ;  T otal production or use volume of surfactants , where applicable; and  Signature, name, and title o f senior compan y 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, c andidates conduct the following activities in order to complete and submit the SDSIApplication Form ( EPA Form 6300
- 2 ) :

 Review the SDSIinformation;Information Collection Request for SDSI program Page 7 of 15

 Decide whether to appl y for recognition, and whether to appl y for partner or champion status;  Select a primary

contact pers on for the program;  Complete the SDSIApplication 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 SDSIApplication Form to potential participants, and maintain a downloadable PDF version on the SDSI website ;  Answer questions po sed 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 applicant s of the decisions. EPA is committed to evaluating whether there is a correlation between SDSIparticipation and environmental outcomes by using Inventory

Update Rule data to establish a baseline and track changes in the levels of nonylphenol ethoxylate m anufactured, 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 production
related 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 SDSIlogo in product literature. 5(b) Collectio n Methodology and Management Respondents can obtain the SDSIApplication 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. Incollecting and analyzing the information associated with this ICR, EPA will use a telephone sy stem, personal computers, and applicable database software. EPA will ensure the accuracy and completeness of collected information by reserving the right toInformation 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 i n the SDSIprogram 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 wil l 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 ye ars covered under this I CR , assuming 10 hours per respondent . No capital or operations and management costs are incurred b y respondents under this ICR. The data collection mechanism for SDSIis the SDSIApplication Form (EPA Form 6300
- 2) . In an effort to minimize burden and cost, the SDSIApplication Form was de signed with straightforward questions and in a way that one application package will serve all ty pes of participants. The expected participant categories for SDSIare as follows: chemical manufacturers, formulators, retailers / distributors, institutiona l 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 “othe rs,” it is expected that participants will represent unions , non - profits , or academia
. 6(a) Estimating Respondent Burden The average respondent burden is estimated t o be 10 hours pe r respondent
. EPA used professional judgment to arrive at a burden es timate and then consulted representatives from the participant categories to evaluate whether the burden estimate was reasonable (see section 3(c)). Burden hours for the SDSIapplication package are for reporting purposes only and include posting relevant information on the applicant website
. We expect that for a ty

pical entity , program and application review will take about one ho ur (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 compan y website will take 1 hour (1Information Collection Request for SDSI program Page 9 of 15

technic al) . 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) E stimating 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 table 5 and are presented in Exhibit 6.2 of this supporting statement . The ty pe of staff needed to complete the SDSIApplication Form and their associated hourl y labor rates were verified b y 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
- ye ar life of the clearance. This estimate is based on the actu al number of SDSI applications submitted over the last three ye ars (84 applications). It is estimated that EPA will receive about one half as many applications (or 42 applications) over the three
- ye ar cycle of this I CR , based on the assumption that many c ompanies in the potential universe of respondents have either already applied or have decided not to participate. Over the next three ye ars, EPA expects additional companies will apply that may not have previously

heard of SDSI or who have onl y recently m et 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, in stitutional purchasers, and others. The total burden hours and labor cost s associated with this information collection over the three
- ye ar cycle are 420 hours and $ 23,310 , respectivel y (see Exhibit 6.1)
. The annual burden and cost, therefore, are 140 hour s and $7,770. This I CR 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 I CR. Other direct costs (cop yi ng, 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 (hourl y 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 activiti es to be performed b y 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.pdfInformation Collection Request for SDSI program Page 11 of 15

Exhibit 6.1. Estimated Burden and Costs to Respondents 6 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 CPrivate Sector Che mi cal Manufacturers 1  Review application and program information 0 1 0 0 1 0 1 $70 $61 $29 $61  Obtain senior approva l 1 1 1 1 1 1 3 $70 $61 $29 $160  Complete and submit package 7 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 package 6 0 4 1 0 128 32 160 $70 $61 $29 $8,736  Post information on website 0 1 0 0 32 0 32 $70 $6 1 $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 package 6 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 package 6 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

-- -- -- $555Private SectorandLocalGovernment 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 pac kage 6 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 p articipant 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 Labo r Rates using Q 2 2010 Data

Labor Category Data Sources a Wage Fringe Benefit Fringes

as % wage Over head % 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 indu stries , “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

Manufactur ing 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, em ployer 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 . Es timated Total Respondent Burden and Cost Summary Total Number of Respondents Total Burden Hours Total Labor Cost

42 (3 years) 420 (3 years) $ 23,310 a (3 years) 14 (annual) 140 (annual) $7,770 (annual) a This ICR incurs no capital or O EM costs.b. Agency Tall y Exhibit 6. 5 . Average Estimated Agency Burden and Cost Summary

Burden Hours Total L abor Cost 162 $ 8,076 6(f) Reasons for Change in Burden There is a decrease of 3, 61 0 hours (from 3,750 hours to 140 hours) in the total estimated annual respondent burden compared with that identified in the information collection most recentl y approved b y 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 Sta tement 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 b y 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 s ys tems for the purposes of collecting, validating, and verifying information, processing and maintaining information, and disclosing and providing information; adjust the existing way s to compl y with any previously applicable in structions 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 spo nsor, 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. To comment on the Agen cy'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 I CR under Docket I D 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 Doc ket Center Public Readin g Room is open from 8:30 a.m. to 4:30 p.m., Monday through Friday , excluding legal holiday s. The telephone number for the 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 avai lable electronically . When in the sy stem, 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, Washingto n, D.C. 20503, Attention: Desk Officer for EPA. Pleaseinclude the EPA Docket ID Number EPA
- HQ
- OPPT
- 2010
- 0874 , and OMB Control Number

2070
- 0171 in an y correspondence.ATTACHMENTS TO THE SUPPORTING STATEMENT

Attachments to the supporting s tatement 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