### 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 ofthe pilot program. I do not believe that the data that EPA seeks underthis Information Collection Request is already available or systematically collected by otheragencies. It seems that what is being sought will be critical in terms ofdetermining 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 knowthat a high security PIN or password system is necessary. I wouldn't think there would be any danger ofconfidential documents being required to ascertain what is necessary forthe request. Ajpeg ofan electronic "signature" should be the maximum unique requirement ifeven 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
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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. 12516.01, 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 ofan information collection request (ICR) before submitting it to OMB for review and approval, regardless, in the case of ICR renewals, ofwhether changes have or have not been made to the collection activity. As part ofthis requi red consultation, I am contacting you to solicit your input. Please note that ifyou 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 forthe 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 underthis ICR available from any public source, or already collected by another EPA office or by another agency? Ifso, 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 ofthe 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..."

2Your response will be greatly appreciated. Ifyou have any comments in response to the above questions, or with respect to any other part ofthe 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. Ifyou 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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