Clapp, Brian 

From: 

Sent: 

To: 

Cc: 

Subject: 

Hello Brian, 

Brad Miller <bmiller@bifma.org> 

Monday, April 20, 2015 6:02 PM 

Clapp, Brian 

Kinn, Alison; Shannon, Julie 

Re: Request for Assistance; "Assessment of Environmental Performance Standards and 

Ecolabels for Federal Procurement" ICR 

We would like to provide input on your questions and wish to have the ANSI/BIFMA e3 Furniture Sustainability Standard 

and the level Certification Program reviewed as part of the pilot program. 

I do not believe that the data that EPA seeks under this Information Collection Request is already available or 

systematically collected by other agencies. It seems that what is being sought will be critical in terms of determining how 

well existing standards and ecolabels would measure up to the EPA Guidance. 

Electronic submission is a nice option that expedites the process for all parties. I don't know that a high security PIN or 

password system is necessary. I wouldn't think there would be any danger of confidential documents being required to 

ascertain what is necessary for the request. A jpeg of an electronic "signature" should be the maximum unique 

requirement if even that is needed. 

EPA's estimated burden and costs seem reasonable. This Assessment of Environmental Performance Standards and 

Ecolabels is urgently needed so that federal procurement professionals can make more fully informed decisions when 

making purchasing decisions. 

Sincerely, 

Brad Miller 

BIFMA 

Din:ctor of J\thocaC) & Sustainahility 

678 Front /we. :--.JW. Stc. 150 

Grand Rapids. :V1l -1950-1 -5368 

616-2!\5-3%3 

bmilkr·'Zilbifma.org 

\\'Ww.hifma.org 

On Apr 20, 2015, at 2:59 PM, Clapp, Brian <Ciapp.Brian@epa.gov> wrote: 

Mr. MillerOn March 19, 2015, EPA published a Notice in the Federal Register (80 FR 06275) titled "Agency 

Information Collection Activities; Proposals, Submissions, and Approvals: Assessment of 

Environmental Performance Standards and Ecolabels for Federal Procurement; EPA ICR No. 

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2516.01, OMB Control No. 2070-new." (See 

http://www.regulations.gov/#!documentDetaii;D=EPA-HQ-OPPT-2014-0838-0001) This Notice 

refers to EPA's intention to request new Office of Management and Budget (OMB) clearance of 

an information collection related to the assessment of environmental performance standards 

and ecolabels for Federal procurement. 

In addition to the public notice and comment requirement that the above Notice initiates, OMB 

regulations at 5 CFR 1320.8(d)(1)) require agencies to consult with potential respondents and 

data users about specific aspects of an information collection request (ICR) before submitting it 

to OMB for review and approval, regardless, in the case of ICR renewals, of whether changes 

have or have not been made to the collection activity. 

As part of this required consultation, I am contacting you to solicit your input. Please note that 

if you take this opportunity to provide input, your name, affiliation, e-mail address, phone 

number and any information you provide (e.g., copies of e-mails) will be incorporated and 

attached to the ICR supporting statement, which will be a public document. In addition, the 

OMB Desk Examiner for the ICR in question may contact you to verify the accuracy of any 

comments EPA identifies in the ICR. 

EPA solicits your input on the following questions: 

Are the data that EPA seeks under this ICR available from any public source, or already collected 

by another EPA office or by another agency? If so, where can the data be found? 

Is it clear what is required for data submission? If not, are there any suggestions for clarifying 

instructions? 

Would you be interested in an electronic/data submission option? What type of alternative 

would you be most likely to utilize- web form, diskette, CD-ROM? 

For electronic submission, how should signature requirements be handled- Private Key 

Infrastructure, PINS and passwords, signed paper cover sheet? 

Do you agree with EPA's estimated burden and costs (the ICR addresses only the costs 

associated with paperwork)? Are the Bureau of Labor Statistics (BLS) labor rates accurate? If 

you have any reason to consider the BLS labor rates as used by EPA inaccurate or inappropriate, 

explain your rationale. 

To access the Federal Register Notice, the ICR supporting document, and any public comments 

received to date, go to: 

o www.regulations.gov/ 

o enter EPA-HQ-OPPT-2014-0838 in the Enter Keyword or ID field 

o click on "Search" 

o then click on any of the documents listed within the docket to read the document; you will be 

most interested in the Supporting Statement, identified by its title beginning "Information 

Collection Request..." 

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Your response will be greatly appreciated. If you have any comments in response to the above 

questions, or with respect to any other part of the information collection, please respond by 

return e-mail by May 18, 2015. EPA will consider those responses, as well as any public 

comment received in response to the Federal Register Notice identified above, in preparing a 

final document for OMB review. 

Thank you for your assistance. If you have any questions, please do not hesitate to contact me. 

Brian Clapp, Environmental Protection Specialist 

Chemistry, Economics, and Sustainable Strategies Division 

Office of Pollution Prevention and Taxies/Office of Chemical Safety and Pollution Prevention 

Environmental Protection Agency 

Washington, DC 20460 

202-564-8838 

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