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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

Title: Assessment of Environmental Performance Standards and Ecolabels 

for Federal Procurement

EPA ICR No.: 2516.01 OMB Control No.: 2070-NEW

1(b) Short Characterization/Abstract

On November 27, 2013, EPA issued for public comment Draft Guidelines for Product 

Environmental Performance Standards and Ecolabels for Voluntary Use in Federal Procurement; 

see Attachments 5 and 6. As stated in the Federal Register notice (78 FR 70938; see Attachment 

3), EPA’s goal in developing these Guidelines is to create a “transparent, fair, and consistent 

approach to selecting product environmental performance standards and ecolabels to support the 

Agency’s mission and federal sustainable acquisition mandates.” The fundamental aim of the 

Guidelines is to establish a cross-sector framework to be used in recognizing non-governmental 

environmental standards (and consequently, environmentally preferable products meeting these 

standards) for use in federal procurement. 

The draft Guidelines include four sections:

1. Guidelines for the Process for Developing Standards refers to the procedures used to 

develop, maintain, and update an environmental standard. 

2. Guidelines for the Environmental Effectiveness of the Standards refers to the criteria in 

the environmental standard or ecolabel that support the claim of environmental preferability. 

3. Guidelines for Conformity Assessment refers to the procedures and practices by which 

products are assessed for conformity to the requirements specified by standards and ecolabeling 

programs. 

4. Guidelines for Management of Ecolabeling Programs refers to the organizational and 

management practices of an ecolabeling program.

EPA has responded to public comments and released a new version of the Guidelines at 

http://www.epa.gov/draftGuidelines/responses.html. The majority of public comments supported 

EPA undertaking -- with key external entity and stakeholder participation -- additional work to 

further refine the Guidelines and test a potential approach to assessing standards and ecolabels. 

Therefore, in this next phase of work, EPA is contracting with an entity to convene a 
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coordinating Governance Committee, product category-specific multi-stakeholder panels, and an 

independent assessment entity(ies) to develop and pilot test an approach in three to four sectors.

EPA has chosen the following three purchase categories to pilot in 2015: furniture, 

building flooring, and building paints/coatings/removers. An additional to-be-determined product 

category may be addressed depending upon available resources and other considerations.

These sectors were chosen because they meet some or all of the following criteria:

 Potentially significant environmental and/or human health impact (based on lifecycle 

assessments and hazard and risk assessments)

 Opportunity for environmental and/or human health improvement through private sector 

standards/ecolabels;

 Significant volume of federal purchases; and

 Current federal sustainable acquisition mandates in the category are limited, out-of-date, 

and/or could be augmented with private sector standards.

2. NEED FOR AND USE OF THE COLLECTION

2(a) Need/Authority for the Collection

EPA is engaging in this collection pursuant to the authority in the Pollution Prevention 

Act (42 U.S.C.A. section 13103(b)(11); see Attachment 1) which requires EPA to “Identify

opportunities to use Federal procurement to encourage source reduction” and section 12(d) of the 

“National Technology Transfer and Advancement Act of 1995” (Pub. L. 104-113; hereinafter 

“the NTTAA;” see Attachment 2), which requires Federal agencies to “use technical standards 

that are developed or adopted by voluntary consensus standards bodies, using such technical 

standards as a means to carry out policy objectives or activities.” Federal agencies need this 

assessment per the Guidelines to determine which, among sometimes dozens of private sector 

standards within a single purchase category, are appropriate and effective in meeting federal 

procurement goals and mandates.

Federal agencies must comply with the following sustainability-related purchasing 

mandates: section 2(h) of Executive Order 13514 (Federal Leadership in Environmental, Energy

and Economic Performance), section 6002 of the Resource Conservation and Recovery Act, 

section 9002 of the Farm Security and Rural Investment Act of 2002, The Energy Policy Act, 

section 2(d) of Executive Order 13423 (Strengthening Federal Environmental, Energy, and 

Transportation Management) (72 FR 3919, January 26, 2007), and the FAR, including FAR Part 

23 (Environment, Energy and Water Efficiency, Renewable Energy Technologies, Occupational 

Safety, and Drug-Free Workplace) (see

http://www.whitehouse.gov/omb/procurement_index_green).
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Section 2(h) of Executive Order 13514 states that: “The Head of each Agency shall . . . 

advance sustainable acquisition to ensure that 95 percent of new contract actions including task 

and delivery orders, for products and services with the exception of acquisition of weapon 

systems, are . . . energy-efficient (Energy Star or Federal Energy Management Program (FEMP) 

designated), water-efficient, biobased, environmentally preferable (e.g., Electronic Product 

Environmental Assessment Tool (EPEAT) certified), non-ozone depleting, contain recycled 

content, or are non-toxic or less toxic alternatives, where such products and services meet 

agency performance requirements.”

Via the NTTAA, Congress required Federal agencies to “use technical standards that are 

developed or adopted by voluntary consensus standards bodies, using such technical standards as 

a means to carry out policy objectives or activities,” except when an agency determines that such 

use “is inconsistent with applicable law or otherwise impractical.” Office of Management and 

Budget (OMB) Circular A-119 (titled “Federal Participation in the Development and Use of 

Voluntary Consensus Standards and in Conformity Assessment Activities”) reaffirms Federal 

agency use of non-governmental standards in procurement.

While Federal purchasing policy is clear for the several standards and ecolabels that are 

listed in statute, regulation, or Executive Order, the lack of independently assessed information 

about and federal guidance on using other product environmental performance standards and 

ecolabels often results in an inconsistent approach by Federal purchasers and confusion and 

uncertainty for vendors and manufacturers.

2(b) Practical Utility/Users of the Data

As envisioned by EPA and supported by public comment, it would not be practical for 

individual procurement officers or even individual federal agencies to assess and make 

determinations regarding which standards and ecolabels are appropriate and effective in meeting 

federal procurement goals and mandates. Therefore, EPA is proposing to test an approach that 

could serve government-wide interest in assessing and selecting standards and ecolabels to 

support the aforementioned environmentally preferable purchasing goals and mandates in a fair,

transparent, and consistent manner based on agreed upon guidelines and independent assessment.

The guidelines to be used for assessing standards and ecolabels include criteria for both 

the process by which standards and ecolabels are developed and managed and the effectiveness 

of the standards and ecolabels in protecting environmental and human health. Some of this 

information can be collected by reading the standard; other aspects need to be collected via 

assessment tools and/or interviews.
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3. NON-DUPLICATION, CONSULTATIONS, AND OTHER COLLECTION 

CRITERIA

3(a) Non-duplication

There has been no other effort to systematically collect such comprehensive information

about standards and ecolabels. Additionally, where public sources of data are available, they will 

be consulted in lieu of asking respondents to do so.

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

In proposing to renew this ICR, EPA provided a 60-day public notice and comment 

period that ended on May 18, 2015 (80 FR 14372, March 19, 2015). EPA received comments 

from nine respondents during the comment period. The respondents were: Business and 

Institutional Furniture Manufacturers Association (BIFMA); Fores Stewardship Council US; 

Forest Stewardship Council; NSF International; Sustainable Forestry Initiative, Inc.; SCS Global 

Services; TUV Rheinland; UL LLC; and World Wildlife Fund. Copies of the comments that 

EPA received are found in Docket ID Number EPA-HQ-OPPT-2014-0838. A copy of EPA’s 

response to the comments is included as Attachment 7.

3(c) Consultations

In 2011 and 2012, EPA and the General Services Administration (GSA) convened 

several listening sessions to solicit input regarding the Federal Government's role in 

sustainability. A number of sessions were held following the release of the National Academy of 

Sciences report “Sustainability and the U.S. EPA.” Other sessions were held under the auspices 

of the Interagency Workgroup established by GSA per section 13 of Executive Order 13514: 

Federal Leadership in Environmental, Energy, and Economic Performance (74 FR 52117, 

October 8, 2009).

EPA heard some common themes from suppliers, manufacturers, environmental 

organizations, multi-stakeholder bodies, regulatory partners, standards development 

organizations, ecolabel programs, and others. Key points included: (1) The desire for greater 

clarity in the marketplace regarding standards and ecolabels and (2) the opportunity to leverage 

the Federal Government's purchasing power toward sustainability goals.

The Interagency Workgroup developed an initial set of draft Guidelines and contracted 

with Big Room Inc. (developers of www.EcoLabelIndex.com) to test the feasibility and 

appropriateness of the draft Guidelines. Big Room Inc. conducted a survey of a subset of 

government and non-governmental (less than nine) environmental performance standards and 

ecolabel developers. Based on the results of the study and external stakeholder input, EPA

revised the draft Guidelines and released them for public comment in November 2013.
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Additionally, 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 ICR to OMB 

for review and approval. In accordance with this regulation, EPA submitted questions to nine

parties via e-mail. The individuals contacted were:

Mark Rossolo, UL mark.rossolo@ul.com

 Jessica Evans, NSF jevans@nsf.org

 Mark Petruzzi, Green Seal mpetruzzi@greenseal.org

Brad Miller, BIFMA bmiller@bifma.org

Dean Thompson, Resilient Floor Coverings dean.thompson@rfci.com

Bridgett Luther, Cradle to Cradle bridgett@c2certified.org

Robert Frisbee, Green Electronics Council rfrisbee@greenelectronicscouncil.org

Steve Mawn, ASTM smawn@astm.org

Anne Calas, ANSI acaldas@ansi.org

EPA received one response to its solicitation for consultations. Copies of EPA’s 

consultation e-mail to the above potential respondents, and of the response that EPA received, 

are included in Attachment 8.

3(d) Effects of Less Frequent Collection

This pilot effort will inform the frequency of information collection appropriate for 

Federal procurement needs. It is likely that the frequency of information collection will be 

dependent upon 1) future business models for collection (e.g., if there is a greater reliance on the 

private sector’s conformity assessment infrastructure versus federal sponsorship/funding of 

assessments), 2) the speed of market transformation toward sustainability in particular sectors, 

and 3) changes in standards and ecolabel trends in particular sectors.

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

It is not expected that any information collected in this ICR will involve confidential 

business or trade secret information. 

3(g) Sensitive Questions

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

sensitive questions. 
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4. THE RESPONDENTS AND THE INFORMATION REQUESTED

4(a) Respondents/SIC Codes

Respondents will be standards development organizations, ecolabel programs, and 

certification entities that have product environmental performance standards and/or ecolabels 

that (1) cover one or more of the three (3) identified product categories; and (2) could be 

considered for use in United States federal procurement per Executive Order (E.O.) 13514, the 

Federal Acquisition Regulation (FAR) 23.103, and U.S. government standards policy, as a part 

of the pilot project.

EPA has chosen the following three (3) purchase categories to pilot in 2015 – furniture, 

building flooring, and building paints/coatings/removers. An additional to-be-determined sector 

may be piloted, depending upon available resources and other considerations.

SIC codes:

Furniture, for example:

251 Household Furniture

252 Office Furniture

253 Public Building and Related Furniture

Flooring, for example:

227 Carpets and Rugs

1752 Floor Laying and Other Floor Work, Not Elsewhere Classified

2426 Hardwood Dimension and Flooring Mills

3996 Linoleum, Asphalted-Felt-Base, and other Hard Surface Floor Coverings, 

not elsewhere classified

3253 Ceramic Wall and Floor Tile

Paints, Coatings, and Removers, for example:

2851 Paints, Varnishes, Lacquers, Enamels, and Allied Products

These sectors were chosen because they meet some or all of the following criteria:

o Potentially significant environmental and/or human health impact (based on 

lifecycle assessments and hazard and risk assessments)

o Opportunity for environmental and/or human health improvement through private 

sector standards/ecolabels;

o Significant volume of federal purchases; and

o Current federal sustainable acquisition mandates in the category are limited, outof-date, and/or could be augmented with private sector standards.
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4(b) Information Requested

Respondents will:

 Self-assess per product-category specific checklists based on EPA’s draft 

Guidelines for Product Environmental Performance Standards and Ecolabels, and

 Participate in a follow-up interview(s) with an Independent Assessment Entity.

5. THE INFORMATION COLLECTED–AGENCY ACTIVITIES, COLLECTION 

METHODOLOGY, AND INFORMATION MANAGEMENT

This section provides information on the Agency activities that correspond with each 

piece of information collected, data management, small business burden, and collection 

schedules.

5(a) Agency Activities

EPA will be contracting with an entity (or entities) to convene the multi-stakeholder 

panels charged with developing the checklists by which standards and ecolabels will be 

independently assessed. EPA subject matter experts will participate in the multi-stakeholder 

panels (one per panel), which will follow consensus decision-making approaches.

5(b) Collection Methodology and Management

An independent assessment entity(ies) will be brought in by EPA’s contractor to manage 

the information collection per internationally recognized conformity assessment protocols (e.g., 

ISO, ANSI).

5(c) Small Entity Flexibility

It is expected that some of the participants in the pilot effort will be small standards 

development and ecolabel program entities. The pilot shall be designed to minimize respondent 

burden while obtaining sufficient and accurate information. In addition, given the voluntary

nature of the collection, it is expected that respondents will participate only if the benefits of 

participation (greater access to the federal marketplace) outweigh the information collection 

burden. 

5(d) Collection Schedule

Collection of information for the pilot program is anticipated to be completed by the end 

of 2015. The need for and timing of future collection of information will be determined, in 

consultation with other federal agencies and the public, following the pilot.
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6. ESTIMATING THE BURDEN AND COST OF THE COLLECTION

6(a) Estimating Respondent Burden and Cost

Table 1 presents the estimated respondent burden hours and costs associated with the 

information collection activities under this ICR. EPA based its burden estimates on a survey of a 

subset of government and non-governmental (less than 9) environmental performance standards 

and ecolabel developers. The survey respondents were contacted for an interview following the 

survey and were asked how long it had taken them to complete the survey. Two respondents took 

as little as 30 minutes to complete the survey, seven respondents took 2-6 hours, two respondents 

took 16 hours, and one respondent (who covered three different ecolabels in its responses) took 

50-60 hours. The average time spent per ecolabel on completing the survey was 8.5 hours.

The average burden is estimated to be 8.5 hours per response. This estimate is based on 

the length of time needed to complete an assessment. Only standard development organizations 

and ecolabels who volunteer for assessment will be included in the pilot program. For each of the 

four product categories, EPA expects 5 respondents to volunteer to complete the assessment. 

Each respondent is expected to provide up to 2 responses. For the four product categories, there 

is an estimated total burden of 340 hours.

In order to estimate total respondent cost associated with this ICR, wages for managerial 

and professional/technical labor were taken from the Bureau of Labor Statistics (BLS) Employer 

Costs for Employee Compensation (ECEC) data, for December 2013, for manufacturing

industries. The cost of fringe benefits such as paid leave and insurance, specific to each labor 

category, are taken from the same ECEC series. Fringe benefits as a percent of wages are 

calculated separately for each labor category. For example, for December 2013, the average 

wage rate for professional/technical labor was $39.70, the average fringe benefit was $21.14. 

Fringe benefits as a percent of wages were $21.14/$39.70, or approximately 53.3 percent. 

An additional loading factor of 17 percent is applied to wages to account for overhead. 

This approach is used for consistency with Office of Pollution Prevention and Toxics economic 

analyses for two major rulemakings: Wage Rates for Economic Analyses of the Toxics Release 

Inventory Program (2002), and the Revised Economic Analysis for the Amended Inventory 

Update Rule: Final Report (2002). This overhead loading factor is added to the benefits loading 

factor, and the total is then applied to the base wage to derive the fully loaded wage. For 

example, the December 2013 fully loaded wage for professional/technical labor is $39.70 × 

(1+0.532494 + 0.17) = $67.59.

The average cost per response is $617.78. This cost is calculated by dividing the average 

burden of 8.5 hours per response by 4.25 hours of managerial labor and 4.25 hours of 

professional/technical labor. 
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Table 1. Estimated Burden and Cost to Respondents

Product 

Categories

Number of 

Respondents

Response

per 

respondent

Total Burden and Wage Rate by Labor 

Category

Total 

Burden 

(Hours)

Total Cost 

($) Managerial Technical 1

Hours Wage ($) Hours Wage ($)

Furniture 5 2 4.25 $77.77 4.25 $67.59 85 $6,177.80

Building Flooring 5 2 4.25 $77.77 4.25 $67.59 85 $6,177.80

Building Paints/

Coatings/Removers 5 2 4.25 $77.77 4.25 $67.59 85 $6,177.80

Other Category 5 2 4.25 $77.77 4.25 $67.59 85 $6,177.80

Total 20 -- -- -- -- -- 340 $24,711.20

1Total Cost is calculated by multiplying burden hours by the wage rate for each labor category and summing across 

labor categories, and then multiplying by total number of responses.

6(b) Estimating Agency Burden and Cost

Table 2 presents the estimated Agency burden hours and costs associated with the 

information collection activities under this ICR. EPA based its burden estimates on previous 

Agency efforts in convening multi-stakeholder groups and developing environmentally

preferable purchasing guidance. In addition, EPA’s contractor statement of work for this effort 

has been negotiated and awarded at this level of effort. 

Agency wage rate data used to calculate labor costs were gathered from the U.S. Office 

of Personnel Management Salary Table 2013-DCB, for a GS-14, step 5, employee in the 

Washington, D.C. area. A loading factor of 1.6 was applied to the base rate to arrive at the 2013 

loaded salary of $190,781 per year. The hourly wage rate was computed by dividing the loaded 

wage by 2,080 hours, the hours associated with a full time employee. This loaded hourly wage

rate of $91.72 was used in calculations of Agency cost.
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Table 2. Estimated Burden and Cost to Agency

Collection Activity EPA Burden 

(Hours)

EPA Costs ($)

Develop sector specific assessment tools/checklists based on 

draft guidelines 3,000 $275,160

Issue assessment tool/checklist to applicant SDOs and 

ecolabel programs (respondents) 50 $4,586

Follow up with respondents via phone interviews 250 $22,930

Prepare analysis and report of the assessment results 400 $36,688

Determine if/how to recognize conforming standards and 

ecolabels 300 $27,516

Total 4,000 $366,880

6(c) Bottom Line Burden Hours and Cost Tables

a. Respondent Tally

Table 3 summarizes the total annual estimated respondent burden and cost. These 

estimates represent the average burden in any given year over the three years covered by this 

ICR. However, the assessment tool and its respective results are only expected to be conducted 

once over the three-year period.

Table 3. Total Annual Estimated Respondent Burden and Cost Summary

Total Number of Respondents Average Burden Hours Annual Cost

20 340 $24,711.20

b. Agency Tally

Table 4 summarizes the total annual estimated Agency burden and cost (including 

contractor cost). These estimates represent the average burden in any given year over the three 

years covered by this ICR. However, the assessment tool and its respective results are only 

expected to be conducted once over the three-year period.

Table 4. Total Annual Estimated Agency Burden and Cost Summary

Burden Hours Annual Cost

4,000 $366,880

6(d) Reasons for Change in Burden

Since this is a new ICR, change in burden is not applicable.
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6(e) Burden Statement

The annual public burden for this collection of information is estimated to be 8.5 hours

per response. Burden is defined in 5 CFR 1320.3(b). 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 number for this information collection appears 

above. The OMB control numbers for EPA’s regulations in title 40 of the CFR, after appearing 

in the Federal Register, are listed in 40 CFR part 9 and included on the related collection 

instrument or form, if applicable.

The Agency has established a public docket for this ICR under Docket ID No. EPA-HQOPPT-2014-0838, which is available for online viewing at www.regulations.gov, or in-person 

viewing at the Pollution Prevention and Toxics Docket in the EPA Docket Center (EPA/DC). 

The EPA/DC Public Reading Room is located in the EPA West Building, Room 3334, 1301 

Constitution Ave., N.W., Washington, DC. The EPA/DC 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 EPA/DC Public Reading Room is (202) 566-1744, and the telephone number for the 

Pollution Prevention and Toxics Docket is (202) 566-0280.

You may submit comments regarding 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. Submit your 

comments, referencing Docket ID No. EPA-HQ-OPPT-2014-0838 and OMB Control No. 2070-

NEW, to (1) EPA online using www.regulations.gov (our preferred method), or by mail to: 

Pollution Prevention and Toxics Docket, Environmental Protection Agency Docket Center 

(EPA/DC), Mail Code: 28221T, 1200 Pennsylvania Ave., N.W., Washington, DC 20460, and (2) 

OMB by mail to: Office of Information and Regulatory Affairs, Office of Management and 

Budget (OMB), Attention: Desk Officer for EPA, 725 17th Street, N.W., Washington, DC 

20503.
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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-2014-0838. The attachments are

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

section 6(e) of the supporting statement.

Attachment 1: Pollution Prevention Act, 42 U.S.C. 13101 et seq.

Attachment 2: National Technology Transfer and Advancement Act of 1995, 15 U.S.C. 

Attachment 3: Federal Register Notice, November 27, 2013, “Draft Guidelines for 

Product Environmental Performance Standards and Ecolabels for

Voluntary Use in Federal Procurement” (78 FR 70938)

Attachment 4: Federal Register Notice, February 27, 2014, “Draft Guidelines for Product 

Environmental Performance Standards and Ecolabels for Voluntary Use in 

Federal Procurement” (79 FR 11102)

Attachment 5: Draft Guidelines for Product Environmental Performance Standards and 

Ecolabels for Voluntary Use in Federal Procurement – Revised Guidelines 

on the Environmental Effectiveness of the Standards (Section II)

Attachment 6: Draft Guidelines for Product Environmental Performance Standards and 

Ecolabels for Voluntary Use in Federal Procurement – Section I (Process 

for Developing Standards, Section III (Conformity Assessment), and 

Section IV (Management of Ecolabeling Programs)

Attachment 7: Copies of Public Comments and EPA’s Response to Comments

Attachment 8: Copy of EPA’s Consultation E-mail to Potential Respondents and Copy of 

Response that EPA Received