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SUPPORTING STATEMENT

1. IDENTIFICATION OF THE INFORMATION COLLECTION

(a) Title of the Information Collection. 

Contractor Conflicts of Interest (Renewal)

EPA ICR 1550.10, OMB Control No. 2030-0023 

(b) Short Characterization/Abstract. The collection of this information is required to 

ensure that the Agency can effectively identify, evaluate, and take appropriate action 

concerning contractor conflicts of interest (COI). Environmental Protection Agency

(EPA) contractors are required to disclose any actual or potential COI with regard to its 

employees, corporate affiliations, and business relationships. Contractors will be required 

to maintain a database of business relationships and report information to EPA on either 

an annual basis or when work is ordered under an Agency contract. Additionally, under 

some contracts, the contractor must request written approval from the contracting officer 

to enter into a proposed contract subject to the restrictions of EPA’s Limitation of Future 

Contracting Clause. 

The Office of Management and Budget (OMB) approved the previous ICR with no terms 

of clearance.

2. NEED FOR AND USE OF THE COLLECTION

a) Need/Authority for the Collection

The Federal Acquisition Regulation (FAR), Subpart 9.5, requires contracting officers to 

analyze acquisitions to identify and evaluate potential COI, and to avoid, neutralize, or 

mitigate significant COI before contract award. EPA’s information collection is required 

to fulfill the requirements of FAR, protect the Government’s interests at contract award, 

and ensure this protection extends throughout the performance of Agency contracts. 

FAR Subpart 2.1 states organizational conflict of interest means “that because of other 

activities or relationships with other persons, a person is unable or potentially unable to 

render impartial assistance or advice to the Government, or the person’s objectivity in 

performing the contract work is or might be otherwise impaired, or a person has an unfair 

competitive advantage.” Depending on the contract terms, EPA requires the contractor to 

either certify annually or certify each time work is ordered under the contract that to the 

best of the Contractor's knowledge and belief, all actual or potential organizational 

conflicts of interest have been reported to EPA. If the contractor cannot so certify, the 

firm must provide a disclosure statement describing all relevant information concerning 

any past, present, or planned interests bearing on whether it may have a conflict of 

interest. The contracting officer and advisers will use this information to evaluate 

potential conflicts and to determine the appropriate action necessary to avoid, mitigate, or 

neutralize the disclosed conflict.
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Several examples of potential COI follow. Example 1: A contractor which may perform 

clean-up work at a Superfund site must disclose any business relationship it has with 

potentially responsible parties (PRP). Once PRPs are identified for specific sites, the 

Agency attempts to recover costs expended for cleanup through either consent 

agreements or litigation. Because EPA has the dual responsibility of cleanup and 

enforcement and because its contractors are often involved in both activities, it is 

imperative that EPA contractors are free of conflicts so as not to prejudice CERCLA 

response and enforcement/cost recovery actions. Example 2: A contractor which is tasked 

with evaluating radon measurement devices must disclose any business relationships it 

has with firms manufacturing radon measurement devises. The contractor’s objectivity

would be questioned if the firm evaluated a radon measurement device manufactured by

a company with which the contractor has an ongoing business relationship. Example 3: A 

contractor providing peer review services must disclose if any contractor employees 

assigned were substantially involved in the development of the product under review. 

The individual’s impartiality would be questioned if he or she contributed to the 

development of the product under review. 

b) Use and Users of the Data

EPA staff will use the conflict of interest plan and certifications as a means to ensure 

contractors are complying with EPA's requirements for detecting and avoiding conflicts 

of interest. If contractors submit a certification stating they have no conflicts of interest, 

the contracting officer reviews the certificate and retains the information in the official 

contract file. If contractors disclose information showing they have an actual or potential 

conflict of interest, the contracting officers and advisers (subject matter or technical 

experts, legal advisors, and procurement analysts) carefully review and analyze the 

disclosure to determine the appropriate course of action. 

Contracting officers document their determinations in the official contract file. This is 

also where they retain the original information collected. 

In general, the information collected and the determinations made will be used by the 

Agency to ensure that contractors and the EPA are adequately addressing conflict of 

interest concerns, and that the Agency is making determinations consistent with the 

exercise of common sense, good judgment, and sound discretion to protect its programs.

3. NONDUPLICATION, CONSULTATIONS & OTHER COLLECTION CRITERIA

(a) NONDUPLICATION

The collection of information is not duplicative of information otherwise accessible to the 

Agency. The data is unique to each firm’s contract or order for work under a contract and 

is not available from any other source. EPA provisions have the same general objectives 

of identifying, mitigating and avoiding conflicts of interest as FAR Subpart 9.5. 

However, unlike the FAR, the EPA provisions include reporting and certification 

requirements to ensure that actual and potential conflicts of interest are reviewed not only 
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prior to contract award, but also during the period of contract performance and after 

contract performance to ensure enforcement actions are not prejudiced. This is the only

way that EPA can evaluate whether a contractor's work efforts, which may be initiated 

during the EPA contract performance period or in some cases, after contract completion, 

may present an unacceptable risk to the Agency.

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

Public comments were previously requested via the Federal Register (79 FR 11783) on 

March 3, 2014, during a 60-day comment period. No comments were received. 

(c) CONSULTATIONS

For this ICR, informal consultations were conducted with the following EPA contractors 

who provide information under EPA's conflict of interest disclosure requirements. In 

order to obtain as accurate of data as possible, the sample of firms contacted included 

small businesses, large businesses and a company new to doing business with the EPA.

The firms contacted are:

Name Phone Affiliation

Kathleen MacDougall 510-302-6292 Tetratech, Inc, Large Business

Jay Bassin 301-589-5318 EMS, Small Business

Brenda Lodge 703-364-6371 CSC, Large Business

Michael Ware 617-354-0074, ext 136 Industrial Economics, Lrg Business

Hema Patel 937-427-4148, ext 286 Intellitech, Small Business

The process each firm used for tracking contract work, reviewing the scope of work, and 

certifying there are no conflicts or disclosing the nature of an actual or potential conflict 

were virtually identical. The amount of effort involved varied on the size of the business, 

the number of affiliates, and the amount of contracting they do. 

3(d) Effects of Less Frequent Collection

See section 5(d)

3(e) General Guidelines

This ICR adheres to the guidelines stated in the 1995 Paperwork Reduction Act as amended, 

OMB's implementing regulations, OMB's Information Collection Request Handbook (EPA, 

February 1999), and other applicable OMB guidance.

3(f&g) CONFIDENTIALITY AND SENSITIVE QUESTIONS

Some of the information submitted in response to our information request is confidential 

business information (CBI). The Agency will protect CBI from release, and will disclose 

it only to the extent consistent with 40 CFR part 2, subpart B, Agency regulations, and the 

contract terms.
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This information collection complies with the Privacy Act of 1978 and OMB Circular A108, as revised and incorporated into OMB Circular A-130. We have identified no 

sensitive questions.

4. THE RESPONDENTS AND THE INFORMATION REQUESTED

a) RESPONDENTS/NAICS CODES

Respondents to this information collection activity are Agency contractors performing 

work for the Agency which requires protection from conflicts of interest. The number of 

EPA contractors who will be required to provide information under this collection is 

approximately 135. This includes 125 existing contractors and 10 contractors new to 

doing business with the EPA since the last ICR approval.

The respondents represent a variety of industries such as: remediation services (NAICS 

#562910); environmental consulting services (NAICS #541620); engineering services 

(NAICS #541330); research and development (NAICS #541712); administrative 

management and general management consulting services (NAICS #541611); and 

computer related services (NAICS #541519).

b) INFORMATION REQUESTED

(i) DATA ITEMS 

Data to be collected includes: (1) certification on either an annual basis or when work is 

ordered that conflicts have been disclosed or that none exist; (2) disclosure of actual and 

potential conflicts of interest under the contract; and (3) requests for authorization to 

enter into a certain future contract work, cited in the "Limitation of Future Contracting 

Clause” in the applicable contract.

The recordkeeping requirements associated with this request include corporate recordkeeping 

consistent with a contractor's system for identifying, mitigating, and preventing conflicts of 

interest as described in its conflict of interest plan submitted to EPA. This conflict of interest 

recordkeeping includes maintaining a database of corporate clients and contracts in order to 

identify potential conflicts and maintain records of disclosures of conflicts to demonstrate 

compliance with a contractor's conflict of interest plan. NOTE: The term "database" as used in 

this section includes any system which permits a contractor to search its records for conflicts of 

interest and may be manual or automated. The critical function of any database is that it gives the 

respondent the capability to identify any past, present, and future work which may be in conflict.

(ii) RESPONDENT ACTIVITIES

To properly respond to EPA’s conflict of interest disclosure requests requires the contractor to 

first maintain a list of all current contracts they are working under and the nature of the work 

they are performing under the contract. Then, the contractor must analyze interrelations between 
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the work the firm will be performing under the current contract and any work performed under 

other contracts which may cause the contractor to be unable to render impartial assistance or 

advice to EPA, impair the firm’s objectivity, or give the firm an unfair competitive advantage. 

For example, if EPA wants the contractor to assist with research on pesticide products, the 

contractor would check the work they currently perform to ensure it doesn’t involve work for 

pesticide manufacturers. A third party would question the objectivity of the contractor’s research

if the contractor’s work involved a pesticide manufactured by a firm with which the contractor 

does a significant amount of business. If the firm discovers no conflicts of interest, then it 

certifies this fact to the contracting officer. If the firm discovers an actual or potential problem, 

then the facts of the situation will be reported to the contracting officer for his or her response. 

The steps involved in this process would include:

1) Create information; (CBP = 50%) 

(a) prepare conflict of interest plan

2) Gather information; (CBP = 80%) 

(a) create a database

3) Process, compile, and review information; (CBP = 80)

(a) search database and records and

(b) maintain records

4) Identify a potential conflict of interest; (CBP = 10%)

(a) make decision and notify EPA contracting officer 

5) Complete written forms or other paperwork; (CBP = 10%)

(a) prepare annual certification, or

(b) prepare certification when work is ordered

6) Request approval to enter a future contract that may have a conflict of interest.

"Customary and usual business practice" (CBP) means efforts that are part of a company’s day to 

day work efforts and are not unique to their contracts with EPA. The percentages identified 

above were based on analysis of interviews with Agency contractors, Agency contracting staff, 

and historical data on handling conflicts of interest.

5. THE INFORMATION COLLECTED--AGENCY ACTIVITIES, COLLECTION 

METHODOLOGY AND INFORMATION MANAGEMENT

(a) AGENCY ACTIVITIES

The Agency anticipates performing the information collection activities listed below, in 

conjunction with conflict of interest requirements. (See 6(b) for calculations of the Agency's cost 

estimates.)
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(1) Analyzing the contract scope and inserting appropriate conflict of interest clauses in 

contracts;

(2) Collecting conflict of interest certifications or disclosures, or requests to review 

future contracts from the contractor;

(3) When a conflict is disclosed or a request for a future contract is made, analyzing the 

information provided and determining the appropriate measures to avoid, neutralize or mitigate 

the conflict; and 

(4) Filing certifications of no conflict or documenting action on potential conflicts of 

interest disclosures in the contract file. 

(b) COLLECTION METHODOLOGY AND MANAGEMENT

The original information collected will go directly to the Contracting Officer who has 

responsibility for making conflict of interest determinations. The information and determinations 

will be filed in the specific contract files as the official record of the Agency decision. Most

respondents will prepare their submissions electronically. Submissions are accepted in any

format so long as the required information is provided. 

(c) SMALL ENTITY FLEXIBILITY

Based on fiscal year 2012 and 2013 figures, approximately 45% of the Agency’s contracts are 

awarded to small businesses. Only the minimum information necessary to ensure that conflicts of 

interest do not exist is requested. Because the information requested is vital to monitoring 

contractor performance under Agency contracts, separate or simplified procedures cannot be 

developed for small businesses.

EPA considered alternatives to the information collection, such as establishing different 

compliance or reporting requirements or simplifying the requirements for small entities. EPA 

also considered exempting small entities from all or part of the rule. However, separate or further 

simplified requirements are not practical, because the stated objectives cannot be met under such 

alternatives. An undisclosed conflict of interest poses the same risk to EPA whether it is a 

conflict involving a large or small business contractor. EPA believes the information collection, 

along with other established internal controls within the Agency, will prevent conflicts of interest 

that may jeopardize future actions.

Although the information collection requirements for small and large business are the same, 

EPA’s consultations with small businesses (included in 5b below) confirmed that the workload is 

generally less for small businesses because they have less complex organizational structures, 

fewer contracts, and less data to maintain and search than large businesses. Based on the 

information provided by both large and small businesses, it’s estimated that large businesses 
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spend approximately 150% more time on COIs than do small businesses.

The EPA awarded 45% of its contracts to small businesses in FY2012 and 45% in FY2013. 

However, despite the fact the overall makeup of EPA contracts is 45% small business and 55% 

large business; this does not correlate to an accurate number for calculating COI estimates. As 

mentioned, the COI process is more cumbersome for large businesses because they have more 

contracts and more business relationships. As a result, they are also more likely to have a COI 

than a small business. Therefore, in order to calculate a number for FY2014, the responses from 

large businesses is used rather than the small. The responses from the small businesses would 

substantially skew the data which could potentially result in underestimating the actual costs 

associated with the ICR. The responses from large businesses in FY2014 remain similar to the 

last ICR. Since the process has not changed, this would be expected. Surveying more contractors 

would likely result in similar results. 

(d) COLLECTION SCHEDULE AND EFFECT OF LESS FREQUENT COLLECTION

Depending on the type of contract, this information collection requires contractors to certify, 

either annually or for individual work orders, that they have no conflict of interest. If the 

contractor detects an actual or potential conflict, then the firm must disclose the nature of the 

conflict. The annual certification requirement is possible where the nature of the work the 

contractor is performing is sufficiently known in advance to allow certifying for an entire year. 

More frequently, EPA requires its contractors to certify or disclose with each order for work 

under the contract. This requirement for reporting when specific work is ordered is essential 

under contracts with a wide scope where it is not possible to know in advance the exact type of 

work needed or the exact location the work will be performed. For example, most Superfund 

contracts are performed at multiple sites and there is little or no advance notice of where such 

work will be assigned because of our changing cleanup priorities. Therefore, a contractor is in a 

better position to identify its conflicts or potential contracts when work is ordered compared to 

when the basic contract is awarded. We are unable to further reduce this requirement without 

handicapping our ability to ensure our contractors do not work in areas where their objectivity

may be impaired, or where their actions may adversely affect enforcement actions or cost 

recovery from polluters.

There is also no set schedule for submission of requests for authorization to enter into a contract 

for non-EPA work cited in the "Limitation of Future Contracting Clause." This clause identifies 

outside work that could pose a significant conflict of interest with work performed for EPA and 

may impair EPA contractor performance or harm enforcement actions. These requests are 

required to be submitted if and when a contractor wants to request authorization to enter into 

such high risk contracts. Such requests are essential in order that EPA has the opportunity to 

protect its enforcement actions from an unacceptable risk of prejudice before it occurs. This is 

essential to protecting the Government interests.

6. ESTIMATING THE BURDEN AND COST OF THE COLLECTION
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(a) ESTIMATING THE RESPONDENT BURDEN AND COSTS

(i) General Notes

Respondent burden in complying with the COI information collection is broken down 

into the following tasks. Each task will be separately addressed in the narrative, and the 

all tasks will be summarized in the table at the end of this section:

1. Prepare Conflict of Interest Plan (one-time burden)

2. Create a Database (one-time burden)

3. Storage and Maintenance of Records (recurring burden) 

4. Search Data Base Records for Possible COI (recurring burden)

5. Identify Potential COI, Record Decision, and Notify EPA (recurring burden)

6. Request Approval for Future Contract (recurring) 

EPA’s conflict of interest information requirements have been in effect since 1994. 

Additionally, the Federal Acquisition Regulation (FAR) Subpart 9.5 has rules and 

procedures in place to identify, evaluate, and resolve organizational and consultant 

conflicts of interest. Firms doing business with the Federal Government as prime 

contractors or subcontractors must meet the FAR requirements for identifying conflicts of 

interest. Given EPA’s long history with requiring conflict of interest information, the 

vast majority of EPA contractors have established systems for tracking the work they

perform and identifying areas which may raise issues concerning the contractors’ 

impartiality or objectivity

Onetime costs, such as COI plan development and creation of a database were discussed 

in prior requests and continue to apply only to contractors who have never done any work 

as either a prime contractor or subcontractor on a Government contract involving a 

potential for conflict of interest. EPA’s initial request for information collection 

clearance, which was submitted in 1994, utilized a seven year period to allocate onetime, 

non-recurring costs associated with COI plan development and database creation. The 

seven year period was chosen because most Agency Superfund contracts average seven 

years. Now that the seven years has passed, and burden hours for the seven years were 

covered in EPA’s initial and first two renewal ICRs, none of the original allocation of 

one-time costs remains. Any burden associated with tasks 1 and 2 will only be incurred 

by contractors and subcontractors who have never contracted with EPA. 

It is anticipated that some of the work associated with COIs would be done by contractors 

in the normal course of business as a customary and usual business practice (CBP), such 

as maintaining records of who they do business with. The CBP in this ICR are based on 

knowledge of the business practices of anticipated respondents and from a review of 

information received from EPA contractors who provided data in response to our 

consultations. In our burden calculations, the CBP is subtracted from the overall total 
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burden to show the new estimated burden anticipated for this requirement. The 

calculations for CBP are described below for each category of effort.

In accordance with the provisions of FAR Part 31, EPA anticipates that costs incurred in 

complying with this information collection request will be chargeable to Government 

contracts.

(ii) Labor Costs: For all tasks below, the hours are allocated among labor categories in 

the same manner as the original ICR hours: 25% Management, 50% 

Technical, and 25% Clerical. 

(1) Prepare Conflict of Interest (COI) Plan. (Non-recurring one-time effort) In its 

initial request, EPA estimated 1,170 hours per plan as a non-recurring one-time 

cost, because once contractors have prepared a COI Plan, it will only be necessary

to update and/or modify it. We continue to utilize the estimate of 1,170 hours per 

plan for any firms who have never previously done business with EPA or been a 

prime or subcontractor on a Federal Government contract involving conflict of 

interest provisions. For new respondents, we retain the original CBP of 50%. 

This results in an estimate of 585 hours for each of the estimated 10 new 

respondents. In order to allocate the 585 hours across the seven year period of 

performance, we have divided the 585 by 7 to arrive at an average 84 hours per 

respondent per year to prepare the initial COI plan. Total burden per year for the 

10 new respondents is 840. 

BURDEN: 84 hours per respondent X 10 new respondents = 840 hours 

for 10 new respondents

(2) Create Data Base. (Non-recurring one-time effort) Our estimate of 700 hours 

reflects EPA's best estimate based on information received from respondents. 

The CPB for this line item is 80%, resulting in total hours of 140. This line item is 

also a non-recurring one-time burden. Also, as described in task 1 above, these 

hours are allocated over a seven year period of performance and only for new 

respondents, which is anticipated to be 10 per year. Therefore, our estimate 

includes 140 hours per response for new respondents, divided by 7 years which 

equals 20 hrs per year, times 10 respondents or 200 hours total for new 

respondents.

BURDEN: 20 hours per respondent X 10 new respondents = 200 hours 

for 10 new respondents

(3) Storage and Maintenance of Records. The estimate for storing and 

maintaining records is 484 hours. The CBP for this line item remains at 80% to 

reflect that most firms routinely keep lists of their contract work and have

experience in keeping conflict of interest records for Federal contracts. 
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Therefore, a total of 154 hours of storage and maintenance of records activity is 

associated with this collection request. 

BURDEN: 154 hours per respondent

(4) Search Data Base Records for Possible COI. The number of times work is 

ordered under an EPA contract varies greatly; however, for purposes of this ICR 

we retain the estimate that 75 work orders will be issued in a given year. Of this 

number, approximately 16% will be for the same Superfund site for which a 

previous work order has been issued. Since contractors are not required to submit 

more than one certification or disclosure per Superfund site, then contractors will 

only do certifications or disclosures for 63 work orders. 

The average time required to perform each search is estimated to be 8 hours. In

our interviews with contractors, we found firms typically perform a key word 

search (key words such as type of work, location, names of affiliates) in an 

automated database. The database search would take less than an hour; however, 

an employee with the appropriate expertise must review the search findings for 

accuracy. Eight hours includes the database search time, ensuring the findings are 

appropriate, and possibly querying contractor project staff as well as records. 

Based on interviews with contractors, the CBP for this line item is 10%. Few 

public sector contracts require searching the previous conflict of interest records; 

however, some state or local contracts may require it. Therefore, the hours 

associated with this collection request for data base searches is 7 hours.

BURDEN: 7 x 63 = 441 hours per respondent

(5) Identify Potential COI, Record Decision. Execute Work Order or the Annual 

Certification, and Notify the EPA of the Decision. This category reflects the 

management and technical activity in the search and certification effort that a 

contractor must perform. In accordance with the contract terms, the contractor is 

required to submit either a onetime certification or individual certifications when 

work is ordered under the contract. Of the 63 worker orders requiring certification 

or disclosure, approximately 17% of cases (11 work orders per year), only an 

annual certification is required. The remaining 52 orders will require individual 

certification or disclosure.

Our estimate is 28 hours to complete an annual certification (in 11 cases) and 4

hours to complete a per work order review (in 52 cases). The CBP factor for this 

task is very low because most of this effort is associated solely with EPA 

requirements. The estimate of 10% for CBP is associated with an identification of 

a conflict of interest on a private contract which requires management attention 

but may not require the documentation and certification process required by EPA. 

BURDEN: 11 x 28 = 308 (annual certification)
11

52 x 4 = 208 (work order certifications)

 516 hours per respondent

(6) Request Approval to Contract. The estimate utilized is identical to that 

provided in the ICR for the proposed rule and for previous renewals. It is based 

upon an average estimate of five requests per respondent per year with an 

associated effort of 20 hours per request, or 100 hours per respondent. This 

review and approval time has remained fairly constant over the years and is not 

expected to change during the three year period covered by this renewal. This is 

exclusively a requirement for the Federal Government and therefore no CBP is 

assigned.

BURDEN: 100 hours per respondent

Summary of Annual Time Burden

Total annual respondent burden for new respondents, which includes all tasks, is 1,315 hours 

times 10 new respondents for a total of 13,150 hours.

Total annual respondent burden for respondents which are not new, i.e., performing only tasks 3 

through 6, is 1,211 hours times 125 respondents for a total of 151,375 hours

Task 1 Task 2 Task 3 Task 4 Task 5 Task 6 Total

Per Respondent 84 20 154 441 516 100 1,315

New Respondents 840 200 1,540 4,410 5,160 1,000 13,150

Old Respondents 0 0 19,250 55,125 64,500 12,500 151,375

Total 840 220 20,790 59,535 69,660 13,500 164,525

Respondents Hours

10 new respondents 13,150

125 not new respondents 151,375

Total 164,525

Annual time burden for all respondents, all tasks, is 164,525 hours. Estimated burden per 

respondent is (total hours divided by all 135 respondents) is 1,218.70.

Breakdown of Costs Burden

The following chart shows the labor costs associated with the burden hours discussed in the 

previous section. The mean hourly labor rates are from the 2012 Bureau of Labor national mean 

statistics. For business/financial management the rate was $52.20; for a conservation scientist

(technical) the rate was $30.57; and for administrative staff the rate was $16.54. To calculate a

fully loaded rate, an overhead of 100% was added to the hourly rate. As discussed in the 
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previous section, for each task it is calculated 25% of the effort would be managerial, 50% would 

be technical, and 25% would be administrative.

 

Hourly Effort Cost 

Rate (Hours)

New Respondents Only

Task I Prepare COI Plan

Management $104.40 21 $2,192.40

Technical $61.14 42 $2,567.88

Administrative $33.08 21 $ 694.68 

Subtotal 84 $5,454.96

Task 2 Create Database

Management $104.40 5 $522.00

Technical $61.14 10 $ 611.40

Administrative $33.08 5 $ 165.40

Subtotal 20 $1,298.80

All Respondents

Task 3 Storage & Maintenance

Management $104.40 38.5 $4,019.40

Technical $61.14 77 $ 4,707.78

Administrative $33.08 38.5 $ 1,273.58

Subtotal 154 $10,000.76

Task 4 Search Database

Management $104.40 110.25 $11,510.10

Technical $61.14 220.5 $13,481.37

Administrative $33.08 110.25 $ 3,647.07

Subtotal 441 $28,638.54

Task 5 Certify/Disclose

Management $104.40 129 $13,467.60

Technical $61.14 258 $15,774.12

Administrative $33.08 129 $ 4,267.32 

Subtotal 516 $33,509.04

Task 6 Request Approval to Contract

Management $104.40 25 $2,610.00

Technical $61.14 50 $ 3,057.00

Administrative $33.08 25 $ 827.00

Subtotal 100 $ 6,494.00
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New respondent costs for tasks 1 and 2 are $6,753.76 x 10 responses = $67,537.60

For respondents performing tasks 3 through 6, the total annual costs are $78,642.34, x 135 

responses is $10,616,715.90. The total cost for all respondents is $10,684,253.50. For each 

respondent, the cost is $79,142.62.

10 New Respondents

Task 1 5,454.96

Task 2 1,298.80

Total 6,753.76

10 New Respondents 67,537.60

135 All Respondents

Task 3 10,000.76

Task 4 28,638.54

Task 5 33,509.04

Task 6 6,494.00

Total 78,642.34 10,616,715.90

Total All Respondents 10,684,253.50

Each Respondent 79,142.62

(ii) Capital/Start-up Costs

Because it will not be necessary for respondents to acquire any capital goods to 

provide the requested information, EPA has estimated no incurred capital/start-up 

costs.

(iii) Operating and Maintenance Costs

Operating and maintenance costs, which include such items as file storage, photo 

copying, and postage, are negligible.

(b) ESTIMATING AGENCY BURDEN AND COST

The Agency based its burden estimates on actual experience in collecting, reviewing, and 

approving contractors’ conflict of interest submissions. EPA has recognized a need to collect 

conflict of interest information from more than just its Superfund contracts. This resulted in a 

135 respondents and is still an accurate number from FY2013 and is being used for the purposes 

of calculating the subject renewal. Additionally, we note in this ICR that EPA does not keep 

conflict of interest certifications or disclosures centrally. This information is collected, reviewed, 

and documented in the contract file by the contracting officer. 
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Due to the complexity of the task, as well as the experience and skill required in reviewing

contractors’ conflict of interest submissions, it is estimated that this effort will be performed by a 

Grade 14 contracting officer. The contracting personnel who review the submissions also 

document their findings in the contracting file. Contract files contain CBI, so there are no 

additional measures required for the conflict of interest information collected. No administrative 

support is used in this effort. The first task, reviewing the contractor’s conflict of interest plan is 

done before the contract is awarded on a one time basis. (In Section 6 of this ICR, this was task 

one for contractors.) Tasks 2 and 3 below are recurring efforts. The second task, reviewing 

certifications and disclosures, includes annual and by work order certifications and disclosures as 

well as requests. (This was task 5 for contractors.) The third task is reviewing requests for 

approval of future contract. (This was task 6 for contractors.)

The hourly rate for a step five, GS-14 is $46.45 (according the Office of Personnel Management 

Salary Table 2014-GS). A rate of 65%, or $30.19, was added to cover overhead costs. The 

loaded rate equals $76.64 per hour. 

 

ANNUAL AGENCY BURDEN/COST ESTIMATES

Collection Activity Burden Hours per year Cost (based 

on rate of $76.64)

1. Answer Respondent Questions 250 $19,160.00

2. Reviewing the contractor’s conflict of 240 $18,393.60

interest plan

 

3. a. Reviewing annual certifications or 22 $1,686.08

disclosures and documenting the file

(11x2=22)

b. Reviewing work order certifications or 14,040 $1,076,025.60

disclosures and documenting the file

52x135=7,020 responses

7020x2 hours

4. Reviewing requests for approval for future 100 $ 7,664.00

contracting and documenting the contract file

TOTAL: 14,652 $1,122,929.28

 
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c) Reasons for Change in Burden

There is an increase of 10,899 hours in the total estimated respondent burden compared with the 

ICR currently approved by OMB. The reason for this change is due to a correction of the 

calculations for the 10 new respondents.

d) BURDEN STATEMENT

Burden Statement: The annual public reporting and recordkeeping burden for this collection of 

information is estimated to average 1,218.70 hours per response. 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 Number EPA-HQ-OARM-2014-0058, which is available for online viewing at 

www.regulations.gov, or in person viewing at the Office of Environmental Information in the 

EPA Docket Center (EPA/DC), EPA West, Room 3334, 1301 Constitution Avenue, NW, 

Washington, D.C. 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 Office of Environmental Information 

is (202) 566-1752. 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-OARM-2014-0058 and OMB Control Number 2030-0023 in any correspondence.